ML12326A721

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

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

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

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