05000324/LER-2011-001-02, Regarding Condition Prohibited by Technical Specifications Due to RWCU Instrumentation Inoperable
| ML13032A072 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/20/2013 |
| From: | Krakuszeski J Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BSEP 13-0005 LER 11-001-02 | |
| Download: ML13032A072 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 3242011001R02 - NRC Website | |
text
Duke Energy 10 CFR 50.73 January 20, 2013 Serial: BSEP 13-0005 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Brunswick Steam Electric Plant, Unit No. 2 Docket No. 50-324 Licensee Event Report 2-2011-001, Supplement 2 References
- 1. Brunswick Licensee Event Report (LER) 2-2011-001, "Condition Prohibited by Technical Specifications due to RWCU Instrumentation Inoperable," dated September 26, 2011 ADAMS Accession Number ML11277A025
- 2. Brunswick Licensee Event Report (LER) 2-2011-001, Supplement (Withdrawal),
"Condition Prohibited by Technical Specifications due to RWCU Instrumentation Inoperable," dated November 20, 2011 ADAMS Accession Number ML11333A012
- 3. Brunswick Response to Integrated Inspection Report Nos.: 05000325/2011004 and 05000324/2011004, dated December 14, 2011 ADAMS Accession Number ML11356A087
- 4. NRC Letter dated November 20, 2012, "Response to Disputed Non-Cited Violation -
Brunswick Steam Electric Plant - NRC Integrated Inspection Report Nos.:
05000325/2011004 and 05000324/2011004 Dated November 14, 2011," ADAMS Accession Number ML12326A721 On September 26, 2011, Carolina Power & Light Company (CP&L) submitted LER 2-2011-001 (i.e., Reference 1) in accordance with 10 CFR 50.73(a)(2)(i)(B). The LER reported a condition prohibited by Technical Specifications (TS) due to inoperable Reactor Water Cleanup (RWCU) system instrumentation, and that an evaluation was in progress to substantiate the operability of the RWCU instrumentation. On November 20, 2011, a supplement withdrawing LER 2-2011-001 (i.e., Reference 2) was submitted based on CP&L's conclusion that the RWCU system instrumentation was operable and no condition prohibited by TSs existed. This was followed, on December 14, 2011, by a CP&L submittal denying a licensee identified violation regarding this issue (i.e., Reference 3). In a letter dated November 20, 2012 (i.e., Reference 4),
the NRC provided a determination that the RWCU system instrumentation was, in fact, inoperable. Based on this determination, CP&L submits the enclosed LER 2-2011-001, Supplement 2, in accordance with 10 CFR 50.73(a)(2)(i)(B).
U.S. Nuclear Regulatory Commission Page 2 of 2 Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.
Sincerely, John A. Krakuszeski Plant Manager Brunswick Steam Electric Plant MAT/mat
Enclosure:
LER 2-2011 -001, Supplement 2 cc (with enclosure):
U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Mr. Christopher Gratton (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Brunswick Steam Electric Plant (BSEP), Unit 2 05000324 1 of 3
- 4. TITLE Condition Prohibited by Technical Specifications due to RWCU Instrumentation Inoperable
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FACILITY NAME DOCKET NUMBER I __
FACILITY NAME DOCKET NUMBER 07 28 2011 2011-001-02 01 20 2013
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
[1 20.2201(b)
El 20.2203(a)(3)(i)
[E 50.73(a)(2)(i)(C)
E] 50.73(a)(2)(vii) 1 El 20.2201(d)
El 20.2203(a)(3)(ii)
El 50.73(a)(2)(ii)(A)
LI 50.73(a)(2)(viii)(A)
El 20.2203(a)(1)
LI 20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
[] 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
El 50.36(c)(1)(i)(A)
El 50.73(a)(2)(iii)
[1 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(a)(2)(ii)
[I 50.36(c)(1)(ii)(A)
[E 50.73(a)(2)(iv)(A)
El 50.73(a)(2)(x)
El 20.2203(a)(2)(iii)
[L 50.36(c)(2)
EL 50.73(a)(2)(v)(A)
El 73.71 (a)(4) 100 El 20.2203(a)(2)(iv)
El 50.46(a)(3)(ii)
E] 50.73(a)(2)(v)(B)
El 73.71 (a)(5)
EI 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A)
El 50.73(a)(2)(v)(C)
El OTHER El 20.2203(a)(2)(vi)
[
50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
Specify in Abstract below or in describe flow directional characteristics of the orifice. Second, the individual planning the work activity did not provide the rigor commensurate with the importance of the task in researching available reference documents.
Work instructions are typically developed from numerous sources including plant procedures, approved vendor manual, available work history, system and component drawings, engineering references, and planner knowledge. In this case, a single foreign print for an orifice flange arid plate was included in the electronic work order package material. This was the basis for the planner's understanding of the orifice design. This drawing did not provide any schematic diagram or specification text that indicated that the orifice plate was flow directional. Therefore, the planner was unaware of the need for any specific orifice plate orientation instructions to be included in the work package.
Safety Assessment
The safety significance of this condition is considered minimal. BSEP determined that the approximately 18 percent error associated with the incorrectly installed RWCU inlet flow orifice was within the existing margin to the analytical limit. The flow element installation error did not affect the operation of the transmitter or trip device and as such, the additional error did not prevent the loop from meeting the analytical limit for the RWCU Differential Flow - High function.
Corrective Actions
The following corrective actions have been completed.
o The 2-G31-FE-N035 flow orifice was removed and properly reinstalled.
The drawings associated with the Unit 1 and Unit 2 RWCU System flow orifices have been revised to indicate proper installation orientation.
Available data was reviewed to validate proper orientation of flow orifices installed in plant systems over the past five years.
Expectations were reinforced with work planners to ensure that the significance of the components being worked and the consequence of error during maintenance matches the level of effort put forth in planning the work instructions, including research of reference documents and determining post-maintenance testing requirements.
Previous Similar Events
A review of LERs and corrective action program condition reports for the past three years did not identify any previous similar occurrence.
Commitments
No regulatory commitments are contained in this report.
NRC FORM 366 (10-2010)