05000325/LER-2012-002

LER-2012-002, C Progress Energy
MAY 0 2 2012
SERIAL: BSEP 12-0046 10 CFR 50.73
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, DC 20555-0001
Subject: Brunswick Steam Electric Plant, Unit No. 1
Renewed Facility Operating License No. DPR-71
Docket No. 50-325
Licensee Event Report 1-2012-002
Ladies and Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Part 50.73, Carolina Power
& Light Company, now doing business as Progress Energy Carolinas, Inc., submits the
enclosed Licensee Event Report (LER). This report fulfills the requirement for a written
report within sixty (60) days of a reportable occurrence.
Please refer any questions regarding this submittal to Mr. Lee Grzeck, Acting Supervisor
Licensing/Regulatory Programs, at (910) 457-2487.
Sincerely,
Joseph M. Frisco, Jr.
Plant General Manager
Brunswick Steam Electric Plant
MAT/mat
Enclosure:
Licensee Event Report
Progress Energy Carolinas, Inc.
Brunswick Nuclear Plant /65)-
P.O. Box 10429 iota.
Southport, NC 28461
Document Control Desk
BSEP 12-0046 / Page 2
cc (with enclosure):
U. S. Nuclear Regulatory Commission, Region II
ATTN: Mr. Victor M. McCree, Regional Administrator
245 Peachtree Center Ave. N.E., Suite 1200
Atlanta, GA 30303-1257
U. S. Nuclear Regulatory Commission
ATTN: Mr. Philip B. O'Bryan, 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 366U U.S. NUCLEAR REGULATORY COMMISSION
(10-2010)
LICENSEE EVENT REPORT (LER)
(See reverse for required number of
digits/characters for each block)
1. FACILITY NAME
Brunswick Steam Electric Plant (BSEP), Unit 1
4. TITLE
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2. DOCKET NUMBER 3. PAGE
05000325 1 of 3
Implementation of Enforcement Guidance Memorandum (EGM) 11-003

Brunswick Steam Electric Plant (Bsep), Unit 1
Event date:	03-08-2012
Report date:	05-02-2012
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3252012002R00 - NRC Website

Energy Industry Identification System (EIIS) codes are identified in the text as [XX].

Introduction Initial Conditions At the time of the event, Unit 1 was in Mode 5, at 0 percent of rated thermal power (RTP).

Reportability Criteria On March 8, 2012, and on March 13, 2012, Unit 1 implemented 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. Consistent with EGM 11-003, secondary containment [NG] operability was not maintained during Operations With a Potential for Draining the Reactor Vessel (OPDRV) activities, and Required Action C.1 of Technical Specification (TS) 3.6.4.1, "Secondary Containment," was not completed. This condition is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B) as operation prohibited by the plant's TSs.

Event Description

On October 4, 2011, the NRC issued EGM 11-003. EGM 11-003 provides generic enforcement discretion to allow implementation of specific interim actions as an alternative to full compliance with plant technical specifications related to secondary containment operability during Mode 5 OPDRV activities. To ensure compliance with the interim actions specified in the EGM, BSEP developed plant procedure OSP-12-001, "EGM 11-003 OPDRV Activities." This procedure, which contains actions which met or exceeded those specified in EGM 11-003, was implemented on two occasions during the spring 2012 Unit 1 refueling outage. The following summarizes the OPDRV activities during which secondary containment was inoperable.

OPDRV Activity Start� End 1. Drained a portion of the March 8, 2012 at 2200 Eastern�March 10, 2012 at 0200 EST.

recirculation loops to support Standard Time (EST) chemical decontamination of the reactor recirculation system.

2. Replaced 12 Local Power Range March 13, 2012 at 0800 Eastern March 15, 2012 at 0733 EDT.

Monitors (LPRMs). Daylight Time (EDT) Event Cause Implementation of EGM 11-003 during the Unit 1 refueling outage was a planned activity. As such, there was no root cause evaluation of the event.

Safety Assessment The safety significance of this event is minimal. As discussed in EGM 11-003, enforcement discretion related to secondary containment operability during Mode 5 OPDRV activities is appropriate because the associated interim actions necessary to receive the discretion ensure an adequate level of safety. To ensure compliance with the interim actions specified in the EGM, BSEP developed plant procedure OSP-12-001.

This procedure was implemented for both of the OPDRV activities during which secondary containment was not operable.

Corrective Actions

BSEP will submit a license amendment request to adopt a Technical Specifications Task Force (TSTF) traveler associated with generic resolution of this issue, within four months after the issuance of the Notice of Availability of the TSTF traveler.

Previous Similar Events

A review of LERs and corrective action program condition reports for the past three years did not identify any similar previous occurrences.

Commitments No regulatory commitments are contained in this report.