05000325/LER-2012-006, (Bsep), Unit 1, Operation Prohibited by Technical Specifications Due to Operation with a Potential for Draining the Reactor Vessel (OPDRV)

(Bsep), Unit 1, Operation Prohibited by Technical Specifications Due to Operation with a Potential for Draining the Reactor Vessel (OPDRV)

ML12348A396
Person / Time
Site:	Brunswick
Issue date:	11/19/2012
From:	Krakuszeski J Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 12-0129 LER 12-006-00
Download: ML12348A396 (5)

LER-2012-006, (Bsep), Unit 1, Operation Prohibited by Technical Specifications Due to Operation with a Potential for Draining the Reactor Vessel (OPDRV)

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3252012006R00 - NRC Website

text

PDuke E Energy 10 CFR 50.73 NOV 19 2012 Serial: BSEP 12-0129 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Brunswick Steam Electric Plant, Unit No. 1 Docket No. 50-325 Licensee Event Report 1-2012-006 In accordance with the Code of Federal Regulations, Title 10, Part 50.73, Carolina Power &

Light Company submits the enclosed Licensee Event Report (LER). This report fulfills the requirement for a written report within sixty (60) days of a reportable occurrence.

This document contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

Sincerely, r"' Cf John A. Krakuszeski Plant Manager Brunswick Steam Electric Plant MAT/mat

Enclosure:

Licensee Event Report IZ4

U.S. Nuclear Regulatory Commission Page 2 of 2 cc (with enclosure):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010)

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

3. PAGE Brunswick Steam Electric Plant (BSEP), Unit 1 05000325 1 of 3

4. TITLE Operation Prohibited by Technical Specifications due to Operation With a Potential for Draining the Reactor Vessel (OPDRV)

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FACILITY NAME DOCKET NUMBER NUMBER NO.

FACILITY NAME DOCKET NUMBER 09 19 2012 2012-006-00 11 19 2012

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)

El 20.2201(b)

El 20.2203(a)(3)(i)

El 50.73(a)(2)(i)(C)

LI 50.73(a)(2)(vii) 4 El 20.2201(d)

El 20.2203(a)(3)(ii)

LI 50.73(a)(2)(ii)(A)

El 50.73(a)(2)(viii)(A)

EL 20.2203(a)(1)

El 20.2203(a)(4)

El 50.73(a)(2)(ii)(B)

LI 50.73(a)(2)(viii)(B)

El 20.2203(a)(2)(i)

L-50.36(c)(1)(i)(A)

L-50.73(a)(2)(iii)

LI 50.73(a)(2)(ix)(A)

10. POWER LEVEL [L 20.2203(a)(2)(ii)

[] 50.36(c)(1)(ii)(A)

EL 50.73(a)(2)(iv)(A)

[0 50.73(a)(2)(x)

[J 20.2203(a)(2)(iii)

[] 50.36(c)(2)

[] 50.73(a)(2)(v)(A) 1] 73.71 (a)(4) 000 El 20.2203(a)(2)(iv)

El 50.46(a)(3)(ii)

[J 50.73(a)(2)(v)(B)

L] 73.71(a)(5)

El 20.2203(a)(2)(v)

EL 50.73(a)(2)(i)(A)

El 50.73(a)(2)(v)(C)

El OTHER El 20.2203(a)(2)(vi)

[

50.73(a)(2)(i)(B)

LI 50.73(a)(2)(v)(D)

Specify in Abstract below or in result in draining or siphoning the reactor vessel below the top of the fuel, without taking credit for mitigating measures. This is consistent with EGM 11-003. However, the procedure also included a qualifying statement that leakage through mechanical joints (e.g., valve or flange packing leaks, seat leakage through an isolation valve, flange leakage, etc.) is not an OPDRV. This guidance was inappropriately used to conclude that the conditions established to perform the 1 B recirculation pump seal replacement were not an OPDRV.

Safety Assessment

The safety significance of this condition is considered minimal. At the time of the event, Unit 1 was in Mode 4, at 0 percent of RTP. The EDGs, offsite power, and required Emergency Core Cooling systems were operable. As such, the available makeup capability far exceeded the 10 gpm valve seal leakage rate.

Corrective Actions

The following corrective actions were completed.

Secondary containment was restored to operable status at approximately 2120 hours0.0245 days <br />0.589 hours <br />0.00351 weeks <br />8.0666e-4 months <br /> EDT on September 19, 2012.

A standing instruction was issued to ensure secondary containment remained operable during work activities associated with 1B and 1A reactor recirculation pump seals.

The following corrective action is planned.

Plant procedure 001-01.01 will be revised to delineate conditions of an OPDRV and differentiate between implementation of EGM 11-003 and other conditions. This revision is currently planned to be completed by February 28, 2013, prior to the next scheduled outage for either unit.

Previous Similar Events

A review of LERs and corrective action program condition reports identified the following previous similar occurrence.

LER 1-2012-002, dated May 12, 2012, reported planned implementation of the guidance of EGM 11-003, "Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements During Operations With a Potential for Draining the Reactor Vessel," dated October 4, 2011. Since this was a preplanned activity, there were no corrective actions that could have prevented the event discussed in LER 1-2012-006.

Commitments

No regulatory commitments are contained in this report.

)N NRC FORM 366 (10-2010)