ML12326A721: Difference between revisions
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
||
(3 intermediate revisions by the same user not shown) | |||
Line 3: | Line 3: | ||
| issue date = 11/20/2012 | | issue date = 11/20/2012 | ||
| title = IR 05000325-11-004, 05000325-11-004, on 12/14/2011 and 11/14/2011, Response to Disputed Non-Cited Violation - Brunswick Steam Electric Plant - NRC Integrated Inspection | | title = IR 05000325-11-004, 05000325-11-004, on 12/14/2011 and 11/14/2011, Response to Disputed Non-Cited Violation - Brunswick Steam Electric Plant - NRC Integrated Inspection | ||
| author name = Croteau R | | author name = Croteau R | ||
| author affiliation = NRC/RGN-II/DRP | | author affiliation = NRC/RGN-II/DRP | ||
| addressee name = Annacone M | | addressee name = Annacone M | ||
Line 17: | Line 17: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter: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 | |||
Mr. | 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 | |||
License Nos.: DPR-71, DPR-62 | |||
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: Randy C. Ivey | |||
Plant General Manager Manager, Nuclear Oversight | |||
Brunswick Steam Electric Plant Brunswick Steam Electric Plant | |||
Progress Energy Progress Energy Carolinas, Inc. | |||
Electronic Mail Distribution Electronic Mail Distribution | |||
Edward L. Wills, Jr. Paul E. Dubrouillet | |||
Director Site Operations Manager, Training | |||
Brunswick Steam Electric Plant Brunswick Steam Electric Plant | |||
Electronic Mail Distribution Electronic Mail Distribution | |||
J. W. (Bill) Pitesa Joseph W. Donahue | |||
Senior Vice President Vice President | |||
Nuclear Operations Nuclear Oversight | |||
Duke Energy Corporation Progress Energy | |||
Electronic Mail Distribution Electronic Mail Distribution | |||
John A. Krakuszeski Senior Resident Inspector | |||
Plant Manager U.S. Nuclear Regulatory Commission | |||
Brunswick Steam Electric Plant Brunswick Steam Electric Plant | |||
Electronic Mail Distribution U.S. NRC | |||
8470 River Road, SE | |||
Lara S. Nichols Southport, NC 28461 | |||
Deputy General Counsel | |||
Duke Energy Corporation John H. O'Neill, Jr. | |||
Electronic Mail Distribution Shaw, Pittman, Potts & Trowbridge | |||
2300 N. Street, NW | |||
M. Christopher Nolan Washington, DC 20037-1128 | |||
Director - Regulatory Affairs | |||
General Office Peggy Force | |||
Duke Energy Corporation Assistant Attorney General | |||
Electronic Mail Distribution State of North Carolina | |||
P.O. Box 629 | |||
Michael J. Annacone Raleigh, NC 27602 | |||
Vice President | |||
Brunswick Steam Electric Plant Chairman | |||
Electronic Mail Distribution North Carolina Utilities Commission | |||
Electronic Mail Distribution | |||
Annette H. Pope | |||
Manager-Organizational Effectiveness Robert P. Gruber | |||
Brunswick Steam Electric Plant Executive Director | |||
Electronic Mail Distribution Public Staff - NCUC | |||
4326 Mail Service Center | |||
Lee Grzeck Raleigh, NC 27699-4326 | |||
Regulatory Affairs Manager | |||
Brunswick Steam Electric Plant | |||
Progress Energy Carolinas, Inc. (cc w/encl - continued) | |||
Electronic Mail Distribution | |||
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 | |||
In | 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. | |||
Enclosure | |||
2 | |||
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. | |||
Enclosure | |||
3 | |||
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. | |||
Enclosure | |||
}} | }} |
Latest revision as of 20:50, 11 November 2019
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: Randy C. Ivey
Plant General Manager Manager, Nuclear Oversight
Brunswick Steam Electric Plant Brunswick Steam Electric Plant
Progress Energy Progress Energy Carolinas, Inc.
Electronic Mail Distribution Electronic Mail Distribution
Edward L. Wills, Jr. Paul E. Dubrouillet
Director Site Operations Manager, Training
Brunswick Steam Electric Plant Brunswick Steam Electric Plant
Electronic Mail Distribution Electronic Mail Distribution
J. W. (Bill) Pitesa Joseph W. Donahue
Senior Vice President Vice President
Nuclear Operations Nuclear Oversight
Duke Energy Corporation Progress Energy
Electronic Mail Distribution Electronic Mail Distribution
John A. Krakuszeski Senior Resident Inspector
Plant Manager U.S. Nuclear Regulatory Commission
Brunswick Steam Electric Plant Brunswick Steam Electric Plant
Electronic Mail Distribution U.S. NRC
8470 River Road, SE
Lara S. Nichols Southport, NC 28461
Deputy General Counsel
Duke Energy Corporation John H. O'Neill, Jr.
Electronic Mail Distribution Shaw, Pittman, Potts & Trowbridge
2300 N. Street, NW
M. Christopher Nolan Washington, DC 20037-1128
Director - Regulatory Affairs
General Office Peggy Force
Duke Energy Corporation Assistant Attorney General
Electronic Mail Distribution State of North Carolina
P.O. Box 629
Michael J. Annacone Raleigh, NC 27602
Vice President
Brunswick Steam Electric Plant Chairman
Electronic Mail Distribution North Carolina Utilities Commission
Electronic Mail Distribution
Annette H. Pope
Manager-Organizational Effectiveness Robert P. Gruber
Brunswick Steam Electric Plant Executive Director
Electronic Mail Distribution Public Staff - NCUC
4326 Mail Service Center
Lee Grzeck Raleigh, NC 27699-4326
Regulatory Affairs Manager
Brunswick Steam Electric Plant
Progress Energy Carolinas, Inc. (cc w/encl - continued)
Electronic Mail Distribution
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
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.
Enclosure
2
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.
Enclosure
3
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.
Enclosure