ML13107B507

Notice of Enforcement Discretion (NOED) for Brunswick Steam Electric Plant, Unit 1 (NOED No. 13-2-001)

ML13107B507
Person / Time
Site:	Brunswick
Issue date:	04/17/2013
From:	Croteau R Division Reactor Projects II
To:	Annacone M Carolina Power & Light Co
References
Download: ML13107B507 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 April 17, 2013 Mr. Michael Annacone Vice President Carolina Power and Light Company Brunswick Steam Electric Plant P.O. Box 10429

Southport, NC 28461

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 [NOED NO. 13-2-001]

Dear Mr. Annacone:

By letter dated April 15, 2013, you requested that the NRC exercise discretion to not enforce compliance with the actions required in Brunswick Steam Electric Plant (BSEP), Unit No. 1, required actions of Technical Specification (TS) 3.7.3, "Control Room Emergency Ventilation (CREV) System;" TS 3.8.1, "AC Sources - O perating;" TS 3.8.4, "DC Sources - Operating;" and TS 3.8.7, "Distribution Systems - Operating." You informed the NRC that Carolina Power and Light would request an NOED Monday morning of April 15, 2013 through the NRC senior resident inspector. Your letter documented information which was subsequently discussed with the NRC staff during a telephone conference later that day at 1:00 p.m. (all times refer to

Eastern Daylight Time). The principal NRC staff members who participated in the telephone conference are listed in the Enclosure.

To summarize, you stated that in preparation for the Unit 2 Division II emergency buses E4/E8 outage, the following Limiting Condition for Operations (LCO) action statements were entered for Unit 1:

TS 3.8.7, Condition C, entered at 7:15 a.m. on April 8, 2013, when DC control power supplies were re-aligned, (This condition was exited on April 14, 2013 at 1:16 p.m. when DC control power was returned to its normal source);

TS 3.7.3, Condition A, entered at 3:30 p.m. on April 8, 2013, when the 2A train of the Control Room Emergency Ventilation System was manually placed in the Radiation/Smoke protection mode;

TS 3.8.4, Condition A, entered at 4:45 p.m. on April 8, 2013, when the Division II battery chargers, 2B-1 and 2B-2, were de-energized to install temporary power for the E4/E8 bus outage.

Subsequent to beginning the Division II emergency buses E4/E8 work window, the following

LCO action statements were entered for Unit 1:

M. Annacone 2 TS 3.8.1, Condition B, and TS 3.8.7, Condition A, were entered at 5:40 p.m. on April 8, 2013, when the Division II emergency buses E4/E8 were removed from service.

On April 11, 2013, at approximately 4:30 a.m., a degraded condition was identified on the E8 power transformer. During preventive maintenance, the E8 transformer core was megger tested and an unsatisfactory reading of 0.21 M was obtained. The desired value is greater than or equal to 100 M. A visual inspection of the transformer core indicated that the transformer may have been overheated. A decision was made to replace the transformer. At that time, the necessary replacement parts were available onsite and the established work schedule provided for completion of the work before the applicable TS LCO action statements would expire. Late on April 14, 2013, associated work and testing activities were recognized that extended the work completion time beyond those allowed by the TS. Specifically, replacement and testing of the new transformer to restore operability would result in exceeding the completion times of TS 3.7.3, Required Action A.1; TS 3.8.1, Required Action B

.3; TS 3.8.4, Required Action A.1; and TS 3.8.7, Required Action A.1. The TS completion times scheduled to expire were as follows: TS 3.8.7, Required Action A.1, 3:15 p.m. on April 15, 2013; TS 3.7.3, Action A.1, 3:30 p.m. on April 15, 2013; TS 3.8.4, Required Action A.1, 4:45 p.m. on April 15, 2013; and TS 3.8.1, Required Action B.3, 5:40 p.m. on April 15, 2013.

You requested that an NOED be granted pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section 3.8 of the Enforcement Policy and NRC Inspection Manual Chapter 0410 and that the NOED be effective until April 17, 2013, at 3:15 a.m. for those required actions specified above.

This letter documents our telephone conversation of April 15, 2013 at 1:00 p.m., when we orally granted your NOED request at 2:05 p.m. We understand that the condition which prompted

your request for this NOED was corrected allowing BSEP to exit from the TS action statements listed above at 3:20 a.m. on April 16, 2013.

The NRC staff determined that the requested NOED was necessary to avoid an unnecessary transient as a result of compliance with the license conditions and, thus, minimize potential

safety consequences and operational risks. The NRC staff's basis for this discretion considered: (1) No other Unit 1 discretionary maintenance activity is in progress; (2) Unit 1 Nuclear Service Water Pumps 1A and 1B will be running; (3) Temporary Power will be provided to the 1-E11-F015B, Low Pressure Coolant Injection (LPCI) B Inboard Injection Valve, 1-E11-F017B, LPCI B Outboard Injection Valve, and 1-E11-F028B, Suppression Pool Spray B Isolation Valve. This temporary power is being supplied from the Southport feeder, and as such, is not sensitive to switchyard or plant-centered events. Cables associated with the temporary power are routed away from ignition sources such that the risk associated with failure of the cables due to fire is minimized; (4) Temporary Power will be provided to the 1-B32-F031B Reactor Recirculation Pump 1B Discharge Valve, and 1-B32-F032B Reactor Recirculation Pump 1B Discharge Bypass Valve. This temporary power is being supplied from the Southport feeder, and as such, is not sensitive to switchyard or plant-centered events; (5) The following equipment will be protected: Offsite power source s; Emergency Diesel Generators 1, 2, and 3; High Pressure Coolant Injection; Reactor Core Isolation Cooling; 1A Residual Heat Removal (RHR) and RHR Service Water; 1A and 1B Core Spray; 1A and 1B Nuclear Service Water Pumps; the temporary power cables to the 1-E11-F015B, 1-E11-F017B, 1-E11-F028B, 1-B32-F031B, and 1-B32-F032B valves; and Severe Accident Mitigation Alternative A 1 diesel generator; (6) A dedicated operator will be stationed on the 20 foot elevation of the Unit 1 M. Annacone 3

Reactor Building to re-energize 1-E11-F015B and 1-E11-F028B, if needed for accident conditions; (7) Minimizing transmission activity that could impact offsite power and notify the Energy Control Center of the plant's condition and to communicate the need for timely notification of any grid issues; (8) A fire watch will be maintained in the cable spread room during the period of enforcement discretion; (9) That your calculated Incremental Conditional Core Damage Probability and Incremental Conditional Large Early Release Probability values did not exceed the threshold guidance provided in Inspection Manual Chapter 0410 and were consistent with values calculated by NRC reactor analysts; (10) the proposed path to resolve the situation was understood such that there was a high likelihood that planned actions to resolve the situation could be completed within the proposed NOED time frame; (11) That the noncompliance would not be of potential detriment to the public health and safety; and (12) That

the NRC staff was independently verifying some of these conditions and actions. On the basis of the NRC staff's evaluation of your request, we have concluded that granting this NOED is consistent with the Enforcement Policy and NRC staff guidance. The NRC staff also determined that the action is consistent with protecting the public health and safety, and that safety will not be impacted unacceptably by exercising this discretion. Therefore, as we informed you at 2:05 p.m. on April 15, 2013, we exercised discretion to not enforce compliance with the completion times associated with TS 3.7.3, Required Action A.1; TS 3.8.4, Required Action A.1; TS 3.8.1, Required Action B.3; and TS 3.8.7, Required Action A.1 until April 17, 2013, at 3:15 a.m. As stated during the conference call and in your letter, the NRC Staff acknowledges that you determined that a follow up license amendment is not necessary.

Sincerely, /RA/

Richard P. Croteau, Director Division of Reactor Projects Docket No.: 50-325 License No.: DPR-71

Enclosure:

List of Participants cc w/encl: (See page 4)

_________________________

X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:EICS NRR SIGNATURE VIA E-mail /RA/ /RA/ /VIA E-mail /Confference Call/ NAME JDodson RMusser RCroteau CEvans JMonninger DATE 4/17/2013 4/17/2013 4/17/2013 4/17/2013 4/17/2013 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO M. Annacone 4

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

D.J (Regis) Repko 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

Gregory D. Kilpatrick 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/encls cont'd - See page 5)

M. Annacone 5

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 6

Letter to Michael J. Annacone from Richard P. Croteau dated April 17, 2013

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 [NOED NO. 13-2-001]

Distribution w/encl:

C. Evans, RII EICS L. Douglas, RII EICS OE Mail RIDSNRRDIRS PUBLIC R. Pascarelli, NRR RidsNrrPMBrunswick Resource

Enclosure List of Participants

NRC Region II Attendees V. McCree, Regional Administrator

L. Wert, Deputy Regional Administrator R. Croteau, Director, Division of Reactor Projects W. Jones, Deputy Director, Division of Reactor Projects R. Musser, Chief, Reactor Projects Branch 4 G. Hopper, Chief, Reactor Projects Branch 7

R. Bernhard, Senior Reactor Analyst R. Rodriguez, Team Leader, Reactor Projects Branch 7 T. Su, Reactor Inspector, Division of Reactor Safety M. Catts, Senior Resident Inspector, Brunswick M. Schwieg, Resident Inspector, Brunswick

NRC HQ Attendees C. Gratton, NRR J. Monninger, NRR J. Quichocho, NRR J. Rowley, NRR A. Zoulis, NRR G. Matharu, NRR

P. Sahay, NRR S. Weerakkody, NRR M. Hamm, NRR

Licensee Attendees M. Annacone, Site VP R. Davis-Zapata, Supervisor Corporate PRA Modeling B. McCabe, Manager - Nuclear Regulatory Issues B. Murray, Site Licensing A. Padleckas, Operations - Shift Manager A. Pope, Mgr - Org Effectiveness J. Price, Director - Site Engineering R. Repko, Senior VP - Nuclear Operations B. Rishel, Manager - Corporate PRA M. Turkal, Site Licensing E. Wills, Director - Site Operations