ML092580351

Final Significance Determination of White Finding and Notice of Violation (NRC Inspection Report No. 05000325/2009010 and 05000324/2009010), Brunswick Steam Electric Plant

ML092580351
Person / Time
Site:	Brunswick
Issue date:	09/14/2009
From:	Reyes L Region 2 Administrator
To:	Waldrep B Carolina Power & Light Co
References
EA-09-121, IR-09-010
Download: ML092580351 (6)

See also: IR 05000324/2009010

Text

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

SAM NUNN ATLANTA FEDERAL CENTER

61 FORSYTH STREET, SW, SUITE 23T85

ATLANTA, GEORGIA 30303-8931

September 14, 2009

EA-09-121

Mr. Benjamin C. Waldrep

Vice President

Carolina Power and Light Company

Brunswick Steam Electric Plant

P.O. Box 10429

Southport, NC 28461

SUBJECT: FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING AND NOTICE

OF VIOLATION (NRC INSPECTION REPORT NO. 05000325/2009010 AND

05000324/2009010), BRUNSWICK STEAM ELECTRIC PLANT

Dear Mr. Waldrep:

This letter provides you the final significance determination of the preliminary White finding

discussed in NRC Inspection Report No. 05000325/2009009 and 05000324/2009009, dated

June 17, 2009. The inspection finding was assessed using the Significance Determination

Process and was preliminarily characterized as White, a finding with low to moderate increased

importance to safety, that may require additional NRC inspections. The finding involved a failure

to correctly designate termination points for linking control power to the emergency diesel

generator (EDG) lockout relay reset circuitry during the implementation of a design change,

which resulted in a loss of EDG local control function.

At your request, a Regulatory Conference was held on July 28, 2009, to discuss your views on

this issue. During the meeting, you and your staff described Carolina Power and Light

Companys (CP&L) assessment of the significance of the finding, root causes, and detailed

corrective actions. You highlighted eight differences between CP&Ls risk assessment and the

NRCs preliminary estimate as documented in our Inspection Report of June 17, 2009. Based

on this risk assessment, CP&L concluded that the finding should be appropriately characterized

as having a very low to low increased importance to safety (i.e., Green). You agreed with the

NRCs characterization of the design change error as a violation of 10 CFR 50, Appendix B,

Criterion III.

After considering the information developed during the inspection and information provided by

CP&L during and after the conference, the NRC has concluded that the inspection finding is

appropriately characterized as White, a finding with low to moderate increased importance to

safety, which may require additional NRC inspections. In summary, the NRC concluded that a

revision to its preliminary estimate was warranted based on some of the information provided by

CP&L. However, the NRC staff did not agree with CP&Ls contentions with regard to:

(i) refinements to the Motor Control Center Fire Growth Factor; (ii) additional credit for solid

bottom cable trays to both delay fire growth and prevent fire damage for low heat release rate

fires; (iii) additional credit for cables sprayed with Flame-Master 71A or Flame-Master 77 flame-

retardant coatings; and (iv) entry into the Alternate Safe Shutdown procedure by control room

operators. As a result, the NRCs final estimate of the change in core damage frequency for the

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CP&L 2

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finding was reduced, but remained above the White threshold. The NRCs detailed assessment

is fully described in Enclosure 2.

You have 30 calendar days from the date of this letter to appeal the staff=s significance

determination for this finding. Such appeals will be considered to have merit only if they meet

the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.

The NRC has also determined that the failure to correctly designate termination points for linking

control power to the EDG lockout relay reset circuitry during the implementation of a design

change is a violation of 10 CFR 50, Appendix B, Criterion III, as cited in the enclosed Notice of

Violation (Notice) (Enclosure 1). The circumstances surrounding the violation were described in

NRC Inspection Report No. 05000325/2009009 and 05000324/2009009, dated June 17, 2009.

For administrative purposes, this letter is issued as a separate NRC Inspection Report,

No. 05000325/2009010 and 05000324/2009010. In accordance with the NRC Enforcement

Policy, the Notice is considered an escalated enforcement action because it is associated with a

White finding. Accordingly, Apparent Violation 05000325,324/2009009-01 is now Violation

05000325,324/2009009-010, Inability to Operate the EDGs Locally as Required by the Safe

Shutdown Analysis Report.

The NRC has concluded that the information regarding the reason for the violation, the

corrective actions taken and planned to correct the violation and prevent recurrence, and the

date when full compliance was achieved is already adequately addressed on the docket in the

information presented by CP&L at the conference of July 28, 2009. Therefore, you are not

required to respond to this letter unless the description therein does not accurately reflect your

corrective actions or your position.

Because plant performance for this issue has been determined to be in the regulatory response

band, we will use the NRC Action Matrix to determine the most appropriate NRC response for

this event. We will notify you, by separate correspondence, of that determination.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,

Enclosure 1, and your response (should you choose to provide one), will be made available

electronically for public inspection in the NRC Public Document Room or from the NRC=s

document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html. However, because of the sensitive information contained in Enclosure 2, and in

accordance with 10 CFR 2.390, a copy of Enclosure 2 will not be available for public inspection

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.

Sincerely,

/RA/

Luis A. Reyes

Regional Administrator

Docket Nos.: 50-325, 50-324

License Nos.: DRP-71, DRP-62

Enclosures: 1. Notice of Violation

2. NRC Basis for Final Significance Determination (OFFICIAL USE ONLY -

SECURITY-RELATED INFORMATION)

cc w/encls: (See page 3)

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CP&L 3

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cc w/encls: Phyllis N. Mentel

Christos Kamilaris Manager, Support Services

Director Brunswick Steam Electric Plant

Fleet Support Services Progress Energy Carolinas, Inc.

Carolina Power & Light Company P.O. Box 10429

P.O. Box 1551 Southport, NC 28461-0429

Raleigh, NC 27602-1551

Brian C. McCabe

Edward L. Wills, Jr. Manager, Nuclear Regulatory Affairs

Plant General Manager Progress Energy Carolinas, Inc.

Brunswick Steam Electric Plant P.O. Box 10429

Progress Energy Carolinas, Inc. Southport, NC 28461-0429

P. O. Box 10429

Southport, NC 28461-0429

R. J. Duncan, II

Vice President

Nuclear Operations

Carolina Power & Light Company

P.O. Box 165, Mail Zone 1

New Hill, NC 27562-0165

Gene Atkinson

Supervisor, Licensing/Regulatory Programs

Brunswick Steam Electric Plant

Progress Energy Carolinas, Inc.

P.O. Box 10429

Southport, NC 28461-0429

Allen K. Brittain

Manager, Nuclear Plant Security

Brunswick Steam Electric Plant

Progress Energy Carolinas, Inc.

P.O. Box 10429

Southport, NC 28461-0429

Michael J. Annacone

Director Site Operations

Brunswick Steam Electric Plant

Progress Energy Carolinas, Inc.

P.O. Box 10429

Southport, NC 28461-0429

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_________________________ XG SUNSI REVIEW COMPLETE

OFFICE RII:DRS RII:DRS RII:DRS RII:DRS RII:EICS RII:ORA OE

SIGNATURE RA RA RA RA RA RA

NAME RODRIGUEZ MACDONALD NEASE KENNEDY EVANS MCCREE

DATE 9/2/2009 9/3/2009 9/4/2009 9/9/2009 9/1/2009 9/10/2009

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES N

OFFICE NRR RII:ORA

SIGNATURE RA

NAME REYES

DATE 9/ /2009 9/14/2009 9/ /2009 9/ /2009 9/ /2009 9/ /2009 9/ /2009

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES N

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NOTICE OF VIOLATION

Carolina Power and Light Company Docket Nos. 50-325, 50-324

Brunswick Steam Electric Plant License Nos. DRP-71, DRP-62

Units 1 and 2 EA-09-121

During an inspection completed by the NRC on June 17, 2009, a violation of NRC requirements

was identified. In accordance with the NRC Enforcement Policy, the violation is set forth below:

10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures

shall be established to assure that the design basis is correctly translated into

specifications, drawings, procedures and instructions.

Section 9.5.1 of the Updated Final Safety Analysis Report (UFSAR) states, in part, that the

effects of fire on safe shutdown systems have been evaluated in the "Safe Shutdown

Analysis Report" and that this document is hereby incorporated by reference into the

FSAR.

"Safe Shutdown Analysis Report," Calculation BNP-E-9.004, states that The AC

Emergency Power System is equipped with key-locked isolation switches located on the

local diesel generator electrical panel and on each emergency bus section. These

switches allow isolation of the diesel generators and emergency buses from the control

circuit conductors routed through the Control Building. In the event that a fire forces an

evacuation of the Control Room or in any way affects control of the diesel generators and

emergency buses from the Control Room, safe shutdown equipment can be operated

locally by placing these NORMAL/LOCAL switches in the LOCAL position.

Contrary to the above, on June 7, 2007, the licensee failed to correctly translate the

design basis into specifications, drawings, procedures and instructions. Specifically,

during the implementation of Engineering Change 66274 to replace control relays on all

four Emergency Diesel Generators (EDG), termination points for linking control power to

the EDG lockout relay reset circuitry were incorrectly designated such that the EDGs could

not be operated locally.

This violation is associated with a White finding for Units 1 and 2.

The NRC has concluded that information regarding the reason for the violation, the corrective

actions taken and planned to correct the violation and prevent recurrence and the date when full

compliance will be achieved is already adequately addressed on the docket in the information

provided by Carolina Power and Light Company during the Regulatory Conference of July 28,

2009. However, if the description therein does not accurately reflect your position or your

corrective actions, you are required to submit a written statement or explanation under 10 CFR 2.201. In that case, or if you choose to respond, clearly mark your response as a Reply to a

Notice of Violation, EA-09-121 and send it to the Director, Office of Enforcement, U.S. Nuclear

Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-

2738, with a copy to the Regional Administrator, U.S., Nuclear Regulatory Commission, Region

II, and a copy to the NRC Resident Inspector at your facility that is the subject of this NOV.

Enclosure 1

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14

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NOV 2

If you contest this enforcement action, you should also provide a copy of your response, with the

basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001.

Because your response will be publicly available in the NRC Public Document Room or from the

NRC=s document system (ADAMS), to the extent possible, it should not include any personal

privacy, proprietary, or safeguards information so that it can be made available without redaction. If

personal privacy or proprietary information is necessary to provide an acceptable response, then

please provide a bracketed copy of your response that identifies the information that should be

protected and a redacted copy of your response that deletes such information. If you request

withholding of such material, you must specifically identify the portions of your response that you

seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why

the disclosure of information will create an unwarranted invasion of personal privacy or provide the

information required by 10 CFR 2.390(b) to support a request for withholding confidential

commercial or financial information). If safeguards information is necessary to provide an

acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

Dated this 14th day of September 2009

Enclosure 1

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