Jan 28: The Terribly Uncertainty In The TDAFW Pump NOED At Millstone

(What they really knew but didn't tell and what they assumed they knew in the NOED)

The NRC and Millstone sets this document in utter certainty that they have a god's eye view...they perfectly have all the information associated with risk and the conditions (information) with the TDAFW pumps.

NOTICE OF ENFORCEMENT DISCRETION FOR DOMINION NUCLEAR CONNECTICUT,INC. REGARDING MILLSTONE POWER STATION UNIT 3

[TAC NO. MF3393, NOED NO. 14-1-01]

Dear Mr. Heacock:

By letter dated January 28, 2014, Dominion Nuclear Connecticut (DNC), Inc. requested that the U.S. Nuclear Regulatory Commission (NRC) exercise discretion to not enforce compliance with the actions required in Millstone Power Station (MPS) Unit 3 Technical Specification (TS) 3.7.1.2,“Auxiliary Feedwater (AFW) System,” Action C, to restore the Turbine Driven Auxiliary Feedwater (TDAFW) pump to operable status within 72 hours. This letter documented information

On January 23, 2014, at 1:50 p.m., during a planned surveillance test, the MPS Unit 3 TDAFW pump tripped on an over speed condition and was declared inoperable by plant operators. After review of the troubleshooting data, the most probable cause was identified by station personnel that insufficient force was being transferred via the linkage to the turbine steam supply control valve.

You stated that at 1:50 p.m. on January 23, 2014, MPS Unit 3 operators entered TS 3.7.1.2, Action C. Further, TS 3.7.1.2 requires that if 3.7.1.2, Action C, cannot be met within 72 hours, operators at Unit 3 are required to shutdown the reactor and place the unit in at least hot standby within 6 hours and in hot shutdown within the following 12 hours. You sought enforcement discretion to allow for continued operation in violation of TS 3.7.1.2 in order to permit additional time for station personnel to make repairs, perform testing activities, and restore the TDAFW pump to operable status. An additional 72 hours (NOED completion time) was requested beyond the TS completion time allowance to restore the TDAFW pump to an operable condition, such that the need for enforcement discretion would no longer be required at 1:50 p.m. on January 29, 2014. This letter documents the telephone conversation between DNC and NRC staff on January 26, 2014, which concluded at approximately 1:00 p.m., when the NRC staff verbally granted a NOED for 36 hours. Your written request reflected this 36 hour authorization. Subsequent to that call, station personnel restored the TDAFW pump to operable status, allowing operators at Unit 3 to exit TS 3.7.1.2, Action C, and terminate the NOED at 5:05a.m on January 27, 2014.

During the teleconference on January 26, 2014, and further elaborated in your January 28, 2014 letter, your staff indicated that from a risk perspective, it was unnecessary to place MPS Unit 3 into a plant shutdown in that MPS Unit 3 was operating in a stable configuration with offsite power and both MPS Unit 3 Emergency Diesel Generators available, along with the Station Blackout (SBO) Diesel Generator. Based on actual plant conditions on January 26, 2014, quantitatively your staff estimated the Incremental Conditional Core Damage Probability (ICCDP) to be approximately 2.97E-08, and the Incremental Conditional Large Early Release Probability (ICLERP) to be approximately 1.88E-09. Additionally, it was noted that the estimated ICCDP and ICLERP values did not take into account various additional conservatisms associated with compensatory actions which had been put in place. The results of your staff’s quantification were independently corroborated by NRC analysts and were determined to meet the guidance thresholds as articulated in Inspection Manual Chapter (IMC) 0410, “Notices of Enforcement Discretion,” (ADAMS Reference Number ML13071A487).

Your staff implemented compensatory risk management measures prior to entering the period of the enforcement discretion, which were to remain in effect throughout the proposed period of discretion and were independently verified by NRC inspectors. The compensatory measures included staging an operator continuously at the station blackout diesel generator, performing no planned switchyard maintenance, protecting the motor-driven auxiliary feedwater trains and condensate and main feedwater systems, and implementing fire risk management actions. The compensatory actions were intended to increase operator awareness of plant conditions, to reduce the likelihood of losing redundant trains, and to reduce the likelihood and consequences of initiating events. Your staff also stated that no severe weather was forecast, which could challenge offsite power availability during the proposed period of enforcement discretion, grid conditions were normal, and no maintenance would be performed on safety-related equipment.

Your staff stated that the proposed change did not involve a significant hazard based on the three standards set forth in 10 CFR 50.92(c), and did not involve adverse consequences to the environment such that the proposed change meets the categorical exclusion set forth in 10 CFR 51.22(c)(9). The MPS Facility Safety Review Committee reviewed and concurred with the NOED request. Because the request was a one-time extension of the required completion times for repairs, your staff stated that a follow-up license amendment request was not required.

Based on the NRC staff’s evaluation of your request, the NRC has concluded that granting this NOED is consistent with the NRC’s Enforcement Policy and staff guidance. In addition, it meets Section 3.0.3 (b) of IMC 410 in that compliance with the TS would result in an unnecessary down-power or a shutdown of the reactor without a corresponding health and safety benefit.

Therefore, as communicated to your staff at 12:44 p.m. on January 26, 2014, the NRC exercised discretion to not enforce compliance with TS 3.7.1.2, Action C, for an additional period of 36 hours, which expired at 1:50 a.m. January 28, 2014. In addition, as discussed on January 26, 2014, the NRC staff agreed with your determination that a follow-up TS amendment is not needed. The staff concluded that an amendment (either a temporary or permanent amendment) is not necessary because this NOED involves a nonrecurring noncompliance and only involves a single request to not enforce compliance for36 hours with TS 3.7.1.2, Action C, to restore the TDAFW pump to an operable status within 72 hours.

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.