ML12326A721
| ML12326A721 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/20/2012 |
| From: | Croteau R Division Reactor Projects II |
| To: | Annacone M Carolina Power & Light Co |
| References | |
| IR-11-004 | |
| Download: ML12326A721 (9) | |
See also: IR 05000325/2011004
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
November 20, 2012
Mr. Michael Annacone
Vice President
Carolina Power and Light Company
Brunswick Steam Electric Plant
P.O. Box 10429
Southport, NC 28461
SUBJECT:
RESPONSE TO DISPUTED NON-CITED VIOLATION - BRUNSWICK STEAM
ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT NOS.:
05000325/2011004 AND 05000324/2011004 DATED NOVEMBER 14, 2011
Dear Mr. Annacone:
Thank you for your reply dated December 14, 2011, to the licensee identified violation (LIV)
issued on November 14, 2011, concerning activities conducted at your facility.
In your reply, you disputed the LIV, concerning Technical Specification (TS) 3.3.6.1, Primary
Containment Isolation Instrumentation, discussed in section 4OA7 of Integrated Inspection
Report 05000325,324/2011004 based on the following: The incorrectly installed flow element
did not render the reactor water clean-up (RWCU) Differential Flow - High instrumentation
(Function 5.a of TS Table 3.3.6.1-1) inoperable. Operability of the RWCU Differential Flow-
High instrumentation is dependent upon: meeting the TS required allowable value of equal to or
less than 73 gallons per minutes (gpm); and the overall ability of the instrument loop to perform
its intended safety function. The flow element installation error did not affect the transmitter or
trip device and, as such, did not prevent the RWCU Differential Flow - High instrumentation to
meet the TS allowable value of equal to or less than 73 gpm. The amount of uncertainty
introduced by this condition was not sufficient to render the instrument loop incapable of
performing its intended safety function (assuring that the 300 gpm analytical limit would not be
exceeded). Therefore, a violation of TS 3.3.6.1 did not occur.
After consideration of your reply, the Nuclear Regulatory Commission (NRC) has concluded
that, for the reasons presented in the enclosure to this letter, the LIV occurred as stated in
section 4OA7 of Integrated Inspection Report 05000325, 324/2011004 dated November 14,
2011. This matter was the subject of a Task Interface Agreement (TIA) dated November 9,
2012, which is an attachment to this letter. No additional written response is required from you
at this time. We will review your corrective actions for this violation during routine baseline
inspections.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its
enclosure, and your response, if you choose to provide one, will be made available
electronically for public inspection in the NRC Public Document Room or from the NRCs
M. Annacone
2
document systems (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/readingrm/adams.html. To the extent possible, your response should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction.
Should you have any questions concerning this letter, please contact Mr. Randall A. Musser, at
(404) 997-4603.
Sincerely,
/William Jones RA for/
Richard P. Croteau, Director
Division of Reactor Projects
Docket Nos.: 50-325, 50-324
Enclosure: Evaluation and Conclusion
w/Attachment: Task Interface Agreement dated November 9, 2012.
cc w/encl: (See page 3)
_________________________
X SUNSI REVIEW COMPLETE G
FORM 665 ATTACHED
OFFICE
RII:DRP
RII:DRP
RII:DPR
HQ:OE
RII:DRP
SIGNATURE
RAM for JD
/RA/
/RA/
Via Email
/RA/
NAME
JDodson
RMusser
WJones
GGulla
RCroteau
DATE
11/20/2012
11/20/2012
11/20/2012
11/19/2012
11/20/2012
E-MAIL COPY?
YES
NO YES
NO
YES
NO YES
NO YES
NO
M. Annacone
3
cc w/encl:
Plant General Manager
Brunswick Steam Electric Plant
Progress Energy
Electronic Mail Distribution
Edward L. Wills, Jr.
Director Site Operations
Brunswick Steam Electric Plant
Electronic Mail Distribution
J. W. (Bill) Pitesa
Senior Vice President
Nuclear Operations
Duke Energy Corporation
Electronic Mail Distribution
John A. Krakuszeski
Plant Manager
Brunswick Steam Electric Plant
Electronic Mail Distribution
Lara S. Nichols
Deputy General Counsel
Duke Energy Corporation
Electronic Mail Distribution
M. Christopher Nolan
Director - Regulatory Affairs
General Office
Duke Energy Corporation
Electronic Mail Distribution
Michael J. Annacone
Vice President
Brunswick Steam Electric Plant
Electronic Mail Distribution
Annette H. Pope
Manager-Organizational Effectiveness
Brunswick Steam Electric Plant
Electronic Mail Distribution
Lee Grzeck
Regulatory Affairs Manager
Brunswick Steam Electric Plant
Progress Energy Carolinas, Inc.
Electronic Mail Distribution
Randy C. Ivey
Manager, Nuclear Oversight
Brunswick Steam Electric Plant
Progress Energy Carolinas, Inc.
Electronic Mail Distribution
Paul E. Dubrouillet
Manager, Training
Brunswick Steam Electric Plant
Electronic Mail Distribution
Joseph W. Donahue
Vice President
Nuclear Oversight
Progress Energy
Electronic Mail Distribution
Senior Resident Inspector
U.S. Nuclear Regulatory Commission
Brunswick Steam Electric Plant
U.S. NRC
8470 River Road, SE
Southport, NC 28461
John H. O'Neill, Jr.
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, NW
Washington, DC 20037-1128
Peggy Force
Assistant Attorney General
State of North Carolina
P.O. Box 629
Raleigh, NC 27602
Chairman
North Carolina Utilities Commission
Electronic Mail Distribution
Robert P. Gruber
Executive Director
Public Staff - NCUC
4326 Mail Service Center
Raleigh, NC 27699-4326
(cc w/encl - continued)
M. Annacone
4
cc: w/encl contd
Anthony Marzano
Director
Brunswick County Emergency Services
Electronic Mail Distribution
Public Service Commission
State of South Carolina
P.O. Box 11649
Columbia, SC 29211
W. Lee Cox, III
Section Chief
Radiation Protection Section
N.C. Department of Environmental Commerce & Natural Resources
Electronic Mail Distribution
Warren Lee
Emergency Management Director
New Hanover County Department of Emergency Management
230 Government Center Drive
Suite 115
Wilmington, NC 28403
M. Annacone
5
Letter to Michael Annacone from Richard P. Croteau dated November 20, 2012
SUBJECT:
RESPONSE TO DISPUTED NON-CITED VIOLATION - BRUNSWICK STEAM
ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT NOS.:
05000325/2011004 AND 05000324/2011004 DATED NOVEMBER 14, 2011
Distribution w/encl:
J. Baptist, RII
L. Douglas, RII
G. Gulla, OE
OE Mail
RIDSNRRDIRS
PUBLIC
RidsNrrPMBrunswick Resource
Enclosure
EVALUATION AND CONCLUSION
The licensee identified violation (LIV), concerning Technical Specification (TS) 3.3.6.1, Primary
Containment Isolation Instrumentation, discussed in section 4OA7 of Integrated Inspection
Report 05000325, 324/2011004 was identified during a routine Nuclear Regulatory Commission
(NRC) inspection conducted between July 1 and September 30, 2011, at the Brunswick Steam
Electric Plant in Southport, NC. In their letter dated December 14, 2011, the licensee, Carolina
Power and Light Company (CP&L), disagreed with the violation. Specifically, the licensee
stated that a violation of TS 3.3.6.1 did not occur.
Specific Basis for Disputing Licensee Identified Violation
The licensee cited the following reasons as their basis for disputing the violation: The
incorrectly installed flow element did not render the reactor water clean-up (RWCU) Differential
Flow - High instrumentation (Function 5.a of TS Table 3.3.6.1-1) inoperable. Operability of the
RWCU Differential Flow- High instrumentation is dependent upon: meeting the TS required
allowable value of equal to or less than 73 gpm; and the overall ability of the instrument loop to
perform its intended safety function. The flow element installation error did not affect the
transmitter or trip device and, as such, did not prevent the RWCU Differential Flow - High
instrumentation to meet the TS allowable value of equal to or less than 73 gpm. The amount of
uncertainty introduced by this condition was not sufficient to render the instrument loop
incapable of performing its intended safety function (assuring that the 300 gpm analytical limit
would not be exceeded). Therefore, a violation of TS 3.3.6.1 did not occur.
NRC Evaluation of Licensees Response:
The NRC staff reviewed CP&Ls response and concluded that, the LIV occurred as stated in
section 4OA7 of Integrated Inspection Report 05000325, 324/2011004 dated November 14,
2011. The NRCs basis for this determination is as follows:
The NRR staff evaluation included review of the Brunswick-2 UFSAR; Brunswick-2 Technical
Specifications for Limiting Conditions for Operation applicability, Surveillance Requirement
applicability and Table 3.3.6.1-1, Primary Containment Isolation Instrumentation, Function 5.a,
RWCU Differential Flow - High; the licensees documentation withdrawing Licensing Event
Report 2-2011-001; the licensees operability determination (AR 479248-21) and the regulations
under Title 10 of the Code of Federal Regulations (10 CFR) Part 50.36, Technical
Specifications.
The licensees contested violation letter BSEP 11-0108, dated December 14, 2011, stated that
operability of the RWCU Differential Flow - High instrumentation is dependent upon:
(1) Meeting the TS required allowable value of less or equal than 73 gpm and (2) the overall
ability of the instrument loop to perform its intended safety function. The flow safety function of
the instrument loop is met when it can be demonstrated that the analytical limit is met. The
staffs evaluation of the information provided by the licensee, confirms that sufficient safety
margin was available and the additional error did not prevent the loop from meeting the
analytical limit for the RWCU Differential Flow - High instrumentation function.
2
Enclosure
Under 10 CFR 50.36(c)(2) Limiting conditions for operation, (i) Limiting conditions for operation
are the lowest functional capability or performance levels of equipment required for safe
operation of a facility. When a limiting condition for operation is not met, the licensee shall
follow any remedial action permitted by the technical specifications until the condition can be
met. Whether a TS LCO is satisfied cannot solely be determined by the successful
performance of licensee surveillance procedures. It is possible that the surveillance procedures
are not adequate to demonstrate a system, subsystem, component, or device is capable of
performing its specified safety function(s). The surveillance procedures corresponding to the
Surveillance Requirements (SR) for RWCU System differential flow-high presume that the flow
element is installed correctly. SR 3.3.6.1.6 requires performance of a channel calibration once
every 24 months. The TS definition for Channel Calibration establishes requirements to verify
that channel safety functions will be met. The pertinent part of the definition of Channel
Calibration is:
A Channel Calibration shall be the adjustment, as necessary, of the channel
output such that it responds within the necessary range and accuracy to known
values of the parameter that the channel monitors. The Channel Calibration shall
encompass all devices in the channel required for channel Operability and the
Channel Functional Test. Calibration of instrument channels with resistance
temperature detector (RTD) or thermocouple sensors may consist of an in-place
qualitative assessment of sensor behavior and normal calibration of the
remaining adjustable devices in the channel.
Thus, the TS Allowable Value (AV) does not account for an incorrectly installed flow element
unless the calibration procedure adjusts the channel output to respond within the necessary
range and accuracy to known values of the parameter that the channel monitors.
The NRC staff reviewed the licensees description of the RWCU high differential flow
surveillance procedure documents. The procedure for SR 3.3.6.1.6 does not evaluate the
channel sensor (flow element), does not compare the calculated flow to a known value of the
actual plant flow rate, and does not include an in situ qualitative assessment of sensor behavior
similar to the comparison required to be performed for RTD or thermocouple sensors. RWCU
high differential flow surveillance procedures neither address an incorrectly installed flow
element nor require the TS AVs to be verified to ensure that passing the channel calibration test
validates that the TS LCO has been satisfied. Therefore, the incorrectly installed flow element
created an unaccounted-for error, because the calculated TS AV did not address the condition
of an incorrectly installed sensor and no in-situ qualitative assessment of sensor behavior was
performed. Furthermore, the Channel Calibration did not compare calculated flow to a known
value of actual flow. In this instance, there is a valid argument for stating that the safety
significance of this degraded condition is low, because the estimate of the magnitude of the
unaccounted for error is small compared to the remaining safety margin after accounting for all
identified errors. The regulations under 10 CFR 50.36(b) require plant-specific TSs be derived
from the analyses and evaluations included in the UFSAR. The Brunswick-2 TSs AV is the LCO
(10 CFR 50.36(c)(2)(i)) and it is the AV that establishes an appropriate margin to the UFSAR
Analytical Limit for RWCU system isolation on high differential flow. The purpose of SR 3.3.6.1.6 is to verify that the RWCU Differential Flow - High instrumentation is operable when
channel output is such that it responds within the necessary range and accuracy to known
values of the RWCU flow to isolate RWCU on a sensed differential flow of equal to or less than
73 gpm.
3
Enclosure
Region II staff consulted the NRR Technical Specifications Branch and the Instrumentation and
Control Branch. NRR concurs with the RII position outlined in this assessment. The
assessment, in summary, states that the licensees assertion that the instrument inaccuracy
associated with the flow orifice installation error is not applicable to the TS AV is not appropriate
because allocation of instrument inaccuracy introduced by maintenance errors is not accounted
for in the licensees calculation and should be evaluated as a degraded condition. This
degraded condition has a clear and quantifiable impact on the instruments ability to perform its
TS required function of isolating the RWCU system piping with a setpoint of less than or equal
to 73 gpm.
NRC Conclusion:
Based on the NRC assessment of the condition of the Brunswick-2 RWCU system with the inlet
flow orifice installed backwards, the NRC staff has concluded that TS Table 3.3.6.1-1, Function
5.a was inoperable from the date the orifice was installed backwards during the Unit 2 refueling
outage in April 2011, until the date in August 2011, when the orifice was reinstalled correctly.
The licensees evaluation of the condition is not correct and the LIV issued in Inspection Report
05000325, 324/2011004 is valid. Furthermore, the condition is reportable as a condition
prohibited by TS per 10 CFR Part 50.73(a)(2)(i)(B). For the reasons stated above, the NRC
concludes that the violation occurred.