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 P Division Reactor Projects II
To:	Annacone M Carolina Power & Light Co
References
IR-11-004
Download: ML12326A721 (9)

See also: IR 05000325/2011004

Text

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 NRC's "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 NRC's 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)