IR 05000324/2009006

IR 05000325-09-006, 05000324-09-006; 04/20/2009 - 05/08/2009; Brunswick Steam Electric Plant, Units 1 and 2; Biennial Inspection of the Identification and Resolution of Problems

ML091730006
Person / Time
Site:	Brunswick
Issue date:	06/19/2009
From:	Vias S Reactor Projects Branch 7
To:	Waldrep B Carolina Power & Light Co
References
IR-09-006
Download: ML091730006 (30)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION une 19, 2009

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000325/2009006 AND 05000324/2009006

Dear Mr. Waldrep:

On May 8, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Steam Electric Plant Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on May 8, 2009, with you and other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution (PI&R) program. However, during the inspection, some examples of minor problems were identified associated with identification of plant issues, problem evaluation, implementation of timely corrective actions and preventive maintenance, and evaluation of operating experience.

CP&L 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Steven J. Vias, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos. 50-325, 50-324 License Nos. DPR-71, DPR-62

Enclosure:

Inspection Report 05000325/2009006 and 05000324/2009006 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-325, 50-324 License Nos: DPR-71, DPR-62 Report No: 05000325/2009006 and 05000324/2009006 Licensee: Carolina Power and Light Company (CP&L)

Facility: Brunswick Steam Electric Plant, Units 1 and 2 Location: 8470 River Road SE Southport, NC 28461 Dates: April 20 - 24, 2009 May 4 - 8, 2009 Inspectors: J. Rivera-Ortiz, Senior Reactor Inspector, Team Leader G. Kolcum, Resident Inspector, Brunswick R. Berryman, Senior Reactor Inspector S. Atwater, Senior Reactor Inspector S. Rose, Senior Reactor Inspector Approved by: Steven J. Vias, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000325/2009006, 05000324/2009006; 04/20/2009 - 05/08/2009; Brunswick Steam

Electric Plant, Units 1 and 2; biennial inspection of the identification and resolution of problems.

The inspection was conducted by four senior reactor inspectors and a resident inspector. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

Identification and Resolution of Problems The inspection team concluded that, in general, problems were adequately identified, prioritized, and evaluated; and effective corrective actions were implemented. Site management was actively involved in the corrective action program (CAP) and focused appropriate attention on significant plant issues. The team found that employees were encouraged by management to initiate ARs to address plant issues.

The licensee was effective at identifying problems and entering them into the CAP for resolution, as evidenced by the relatively few deficiencies identified by the NRC that had not been previously identified by the licensee during the review period. The threshold for initiating action requests (ARs) was appropriately low, as evidenced by the type of problems identified and large number of ARs entered annually into the CAP. Action requests normally provided complete and accurate characterization of the problem. However, the team identified two minor equipment issues during system walkdowns involving selected risk-significant safety-related systems, which were not already entered into the CAP.

Generally, prioritization and evaluation of issues were adequate consistent with the licensees CAP guidance. Formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems did address the cause of the problems. The age and extensions for completing evaluations were closely monitored by plant management, both for high priority nuclear condition reports (NCRs), as well as for adverse conditions of less significant priority. Also, the technical adequacy and depth of evaluations (e.g., root cause investigations) were typically adequate. However, the team identified a minor issue associated with the problem evaluation of a risk significant system, which could have resulted in unresolved issues with incomplete corrective actions.

Corrective actions were generally effective, timely, and commensurate with the safety significance of the issues. However, the team identified two minor issues associated with inadequate and untimely corrective actions that allowed potential unresolved conditions adverse to quality to remain uncorrected involving degraded equipment performance. This example of inadequate corrective actions did not represent a significant safety concern but reflected a lack of attention to detail in the implementation of corrective actions and preventive maintenance activities.

The operating experience program was effective in screening operating experience for applicability to the plant, entering items determined to be applicable into the CAP, and taking adequate corrective actions to address the issues. External and internal operating experience was adequately utilized and considered as part of formal root cause evaluations for supporting the development of lessons learned and corrective actions for CAP issues. However, the team identified an example where a Significant Adverse Condition Investigation report did not evaluate the applicable operating experience as directed by the licensees investigation procedure.

The licensees audits and self-assessments were critical and effective in identifying issues and entering them into the corrective action program. These audits and assessments identified issues similar to those identified by the NRC with respect to the effectiveness of the CAP.

Based on general discussions with licensee employees during the inspection, targeted interviews with plant personnel, and reviews of selected employee concerns records, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP as well as the employee concerns program to resolve those concerns.

NRC Identified and Self-Revealing Findings

None

Licensee Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program (CAP)

(1) Inspection Scope The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of action requests (ARs), which were then processed into the CAP as nuclear condition reports (NCRs). The inspectors selected and reviewed a sample of NCRs that had been issued between February 2008 and April 2009. This period of time was purposefully chosen to follow the last Biennial Problem Identification and Resolution (PI&R)inspection conducted in February 2008. This review was performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP for resolution. Where possible, the inspectors independently verified that the corrective actions were implemented as intended.

Within the time frame described above, the inspectors selected NCRs from principally four specific areas of interest. The first inspection area consisted of a detailed review of selected NCRs associated with two risk-significant systems: Service Water (SW) and Instrument Air. The inspectors conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed NCRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP for resolution. Items reviewed generally covered a 15-month period of time; however, in accordance with the inspection procedure, the inspectors performed a five-year review of age-dependent issues for the selected risk significant systems.

The second inspection area consisted of a representative number of NCRs that were assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, emergency preparedness, and security. This selection was performed to ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP). These NCRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors also attended meetings where NCRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

For the third inspection area, the inspectors selected a sample of NRC issued non-cited violations and findings, licensee identified violations, and Licensee Event Reports, to verify the effectiveness of the licensees CAP implementation regarding NRC inspection findings and reportable events issued since the previous 2008 PI&R inspection.

The fourth inspection area covered the review of NCRs associated with selected issues of interest, specifically maintenance rule functional failures, non-conforming/degraded conditions, post maintenance testing issues, and diesel generator (DG) performance issues. The inspectors reviewed the NCRs to verity that problems were identified, evaluated, and resolved in accordance with the licensees procedures and applicable NRC Regulations.

Among the four areas mentioned above, the team conducted a detailed review of selected root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the NCRs and the guidance in licensee procedure CAP-NGGC-0205, Significant Adverse Condition Investigations and Adverse Condition Investigations-Increased Rigor. The inspectors assessed if the licensee had adequately determined the cause(s)of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

Additionally, the team performed Control Room walkdowns to assess the main control room (MCR) deficiency list and to ascertain if deficiencies were entered into the CAP.

Operator Workarounds and Operator Burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

Finally, the team reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified. The inspectors attended various plant meetings to observe management oversight and implementing functions of the corrective action process.

These included Management Review of NCRs meetings and Unit Evaluators meetings.

Documents reviewed partially or in their entirety during this inspection are listed in the

.

(2) Assessment Identification of Issues The team determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on the type of problems entered into the CAP; the review of licensee requirements for initiating NCRs as described in licensee procedure CAP-NGGC-0200, Corrective Action; the management expectation that employees were encouraged to initiate NCRs for any concern regardless of whether it is a potential, suspect, or actual problem; a review of system health reports; and on inspectors observations during plant walkdowns. Trending was generally effective in monitoring and identifying plant issues. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. However, the team identified two minor equipment issues during walkdowns of the two risk-significant plant systems, which were not previously identified by the licensee.

• The 1A Nuclear Service Water (NSW) pump motor showed evidence of an active oil leak that appeared to be coming from the lower bearing sight glass. This oil leak was neither identified through a previous extent of condition evaluation for a 1A NSW pump issue nor through previous system walkdowns by Operations or Systems Engineering. The licensee initiated NCR 331824 to address this issue and determined that the quantified oil leak was small and had no impact on the operability of the 1A NSW pump.

• One of the Unit 1 SW strainers for the Circulating Water system, 1-SW-ST-3, showed evidence of recent leakage from a drain plug on the bottom. The leakage rate was evaluated at less than one drop per minute and not an operability concern. Initial extent of condition review identified that this strainer also had a leak from the same place a year ago and was addressed under WO 1139291. That work order stated that the plug had corrosion on the threads but it did not appear that the plug was replaced. The licensee initiated NCR 331832 to address this issue.

Prioritization and Evaluation of Issues Based on the review of audits conducted by the licensee and the assessment conducted by the inspection team during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the NCR Processing Guidelines in CAP-NGGC-0200. Each NCR written was assigned a priority level at the NCR review meetings. Management reviews of NCRs were thorough, and adequate consideration was given to system or component operability and associated plant risk.

The team determined that the station had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures, and assigned cause determinations were appropriate considering the significance of the issues being evaluated. A variety of causal-analysis techniques were used depending on the type and complexity of the issue consistent with licensee procedure CAP-NGGC-0205, Significant Adverse Condition Investigations and Adverse Condition Investigations-Increased Rigor.

The team determined that generally, the licensee had performed evaluations that were technically accurate and of sufficient depth. The team further determined that operability, reportability, and degraded or non-conforming condition determinations had been completed consistent with the guidance contained in CAP-NGGC-0200, and OPS-NGGC-1305, Operability Determinations.

However, the team identified a minor issue in this assessment area during the review of NCRs for the selected risk significant systems:

• On 06/21/2007, NCR 219625 (Priority 2) was initiated to evaluate frequent pedestal bearing high temperature alarms on DGs #2 and #3 during extended runs. The concern was that pedestal bearing (i.e., generator outboard bearing) temperature could potentially exceed the action limit temperature or the manufacturers maximum operating temperature under abnormal (high) outside air temperatures. The licensee determined the required cooling air temperature and flow for the continuous operation of the DGs pedestal bearing and implemented corrective actions to ensure adequate cooling air was supplied to the bearings. Simultaneously with the pedestal bearing high temperature alarms, the DG cell exhaust damper temperature controllers (non safety-related) had experienced frequent set-point drifts.

Specifically, there were instances where the exhaust dampers opened at a temperature higher than the desired set-point.

Based on the history of continuous performance problems with the exhaust damper temperature controllers and the instances where the DG pedestal bearing temperatures reached the alarm setpoint, the inspectors found that the licensee did not fully consider the potential impact of these issues on the capability of the ventilation system to perform its function. Specifically, the licensee did not fully recognize that the continuous problems with the exhaust damper controllers could challenge the operability of the DG cell components, including the pedestal bearings, on certain summer days where the outside temperature could exceed the design temperature and the DG cell exhaust dampers could fail to open at the required settings. As a result of the inspectors observation, the licensee performed an analysis and determined that no operability concerns existed with regard to the capability of the DG ventilation system to perform its function under abnormal (high)outside temperatures. The inspectors reviewed the licensees analysis and concluded that although the DG cell exhaust dampers were opening at a temperature higher than the set-point, they still were actuating at temperatures below the DG operability limits and sufficient margin existed to maintain operability.

The licensee generated NCR 334703 to address this issue.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected in accordance with the licensee CAP procedures. For the significant conditions adverse to quality reviewed, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, NCRs, and discussions with licensee staff demonstrated that the significant conditions adverse to quality had not recurred.

Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were scheduled consistent with licensee procedures. However, during the review of NCRs for the selected risk significant systems, the team identified two minor issues regarding adequacy and timeliness of corrective actions, and implementation of adequate preventive maintenance:

• As previously mentioned, the exhaust damper temperature controllers (non safety-related pneumatic controllers) for the DG cells had experienced frequent set-point drifts. NCR 231765 was initiated in 2007 to address, in part, the temperature controllers problem and the apparent cause determination identified that poor instrument air quality was the most probable cause for the controller issues.

Corrective actions to obtain an air sample and replace the air filter for these controllers were extended several times without fully recognizing the potential impact of the exhaust dampers issue on the operability of the DGs. As previously discussed, the licensee did not fully understand if the ventilation system was able to maintain the required pedestal bearing temperature under abnormal (high) outside air temperatures combined with the exhaust dampers opening at higher temperatures than the desired set-point. Consequently, the licensee did not give the proper priority to the assigned corrective actions, as evidenced by the multiple times these actions were extended. The licensee obtained the instrument air sample in May 2008 and replaced the air filter in May 2009. The team determined that this issue did not represent a significant safety concern based on the inspectors review of the licensees analysis, which determined that the DG building ventilation system was able to provide adequate cooling to maintain DG operability considering that the exhaust damper controllers were opening at temperatures higher than the set-point.

However, this issue reflected a lack of attention to detail in the implementation of corrective actions. The licensee generated NCRs 334285 and 334294 to address this issue.

• The inspectors identified that the aforementioned instrument air filter (component ID 2-IAI-FLT-052) did not have a specific preventive maintenance schedule. The filters vendor stated that the filters useful life ends when the resistance to flow becomes too high or the maximum permissible pressure is reached. The inspectors found that the filter was original equipment and no tests existed to monitor its performance. In addition, the filter was classified as an Important component, for which the licensees guidance for PM administration (ADM-NGGC-0203) recommends PM to be performed to meet the Maintenance Rule performance criteria. The team determined that this issue did not represent a significant safety concern based on the as found condition of the filter and the inspectors review of the licensees analysis, which determined that the DG building ventilation system was able to provide adequate cooling to maintain DG operability considering that the exhaust damper controllers were opening at temperatures higher than the set-point.

However, this issue reflected a lack of attention to detail in the implementation of preventive maintenance activities. The licensee generated NCR 334294 to address this issue.

(3) Findings No findings of significance were identified.

b. Assessment of the Use of Operating Experience (OE)

(1) Inspection Scope The team examined licensee programs for reviewing industry operating experience, reviewed licensees procedure CAP-NGGC-0202, Operating Experience Program, reviewed the licensees operating experience database, and interviewed the OE Coordinator, to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, etc.), which had been issued since February, 2008, to verify whether the licensee had appropriately evaluated each notification for applicability to the Brunswick Plant, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the

.

(2) Assessment Based on interviews with the OE coordinator and a review of documentation related to the review of operating experience issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant.

Industry OE was evaluated at either the corporate or plant level depending on the source and type of document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in apparent cause and root cause evaluations in accordance with licensee procedure CAP-NGGC-0205, Significant Adverse Condition Investigations and Adverse Condition Investigations-Increased Rigor. During the review of apparent cause and root cause evaluations, the team noted the following performance deficiency of minor significance:

• Significant Adverse Condition Investigation report for NCR 281950, Unplanned Limiting Condition of Operation Entry - Control Building Ventilation Isolation, did not evaluate the applicable operating experience as directed by investigation procedure CAP-NGGC-0205, which requires that the OE review needs to determine if OE exists that would have prevented the event. The licensee considered several examples of applicable OE as part of the investigation; however the investigation report did not determine if the available OE could have prevented the event. The team concluded that this issue was of minor significance because it had no safety impact on the resolution of the problem addressed by NCR 281950. The licensee initiated NCR 332068 to address this issue.

(3) Findings No findings of significance were identified.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The team reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure CAP-NGGC-0201, Self-Assessment and Benchmark Programs.

(2) Assessment The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical, as evidenced by findings consistent with the teams independent review. Self-Assessment findings related to issues or weaknesses were entered into the CAP and tracked to completion based on the NCR priority level. Corrective actions for Self-Assessment findings were adequate to address the issues. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends. The team concluded that the self-assessments and audits were an effective tool to identify adverse trends.

(3) Findings No findings of significance were identified.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The team randomly interviewed 34 on-site workers from Maintenance, Security, Operations, Chemistry, and Engineering organizations regarding their knowledge of the corrective action program at Brunswick and their willingness to write NCRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP coordinator. Additionally, the team reviewed the latest Safety Culture Assessment to evaluate the thoroughness and self-criticism of the licensee's assessment, and to verify that problems identified were appropriately prioritized and entered into the CAP for resolution. Finally, the inspectors reviewed a sample of completed ECP reports to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment Based on the interviews conducted and the NCRs reviewed, the team determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

(3) Findings No findings of significance were identified.

4OA6 Meetings, Including Exit

On May 8, 2009, the inspectors presented the inspection results to Mr. Benjamin C.

Waldrep and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

B. Stackhouse, Engineering Supervisor

B. Waldrep, Site Vice-President

E. Conway, Securitas Training Supervisor

E. Harkcom, Service Water System Engineer

G. Atkinson, Licensing Supervisor

G. Elders, System Engineer

H. Danforth, Progress Energy Security Supervisor

J. Anderson, Lead Diesel Generator System Engineer

J. Gilbert, System Engineer

J. Westbrook, Self Evaluation Supervisor

M. Alford, System Engineer

M. Annacone, Director Site Operations

N. Smith, Supervisor - Electrical/I&C Systems

P. Dorosko, System Engineer

T. Sherrill, Licensing Engineer

W. Richardson, Diesel Generator System Engineer

NRC

G. Kolcum, Resident Inspector

P. OBryan, Senior Resident Inspector

S. Vias, Chief, Reactor Projects Branch 7, DRP

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None

Closed

None

Discussed

None