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

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 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

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)

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 PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE X NON-SENSITIVE ADAMS: X Yes ACCESSION NUMBER:_________________________ 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 OFFICIAL RECORD COPY DOCUMENT NAME: G:\DRPII\RPB4\BRUNSWICK\LIV Denial\BRU LIV denial NRC final response 2012.docx

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 cont'd 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 Licensee's Response:

The NRC staff reviewed CP&L's response and concluded that, the LIV occurred as stated in

section 4OA7 of Integrated Inspection Report 05000325, 324/2011004 dated November 14,

2011. The NRC's 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 licensee's documentation withdrawing Licensing Event

Report 2-2011-001; the licensee's 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 licensee's 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 staff's 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 licensee's 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 licensee's 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 licensee's calculation and should be evaluated as a degraded condition. This

degraded condition has a clear and quantifiable impact on the instrument's 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 licensee's 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.