IR 05000324/2014005

NRC Integrated Inspection Report Nos. 05000325/2014005 and 05000324/2014005

ML15030A237
Person / Time
Site:	Brunswick
Issue date:	01/30/2015
From:	Hopper G NRC/RGN-II/DRP/RPB4
To:	William Gideon Duke Energy Progress
References
IR 2014005
Download: ML15030A237 (35)

Text

UNITED STATES uary 30, 2015

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT NOS. 05000325/2014005 AND 05000324/2014005

Dear Mr. Gideon:

On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Unit 1 and 2 facilities. The enclosed integrated inspection report documents the inspection findings, which were discussed on January 20, 2015, with you and other members of your staff.

One NRC-identified finding and one self-revealing finding of very low safety significance (Green)

were identified during this inspection. These findings were determined to involve a violation of NRC requirements. The NRC is treating these findings as non-cited violations (NCVs)

consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or the significance of the violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Brunswick Steam Electric Plant.

If you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the Brunswick Steam Electric Plant. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's 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 System (PARS)

component of NRC's Agencywide Documents Access and Management 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/

George T. Hopper, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62

Enclosure:

Inspection Report 05000325, 324/2014005 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62 Report No.: 05000325/2014005, 05000324/2014005 Licensee: Duke Energy Progress, Inc.

Facility: Brunswick Steam Electric Plant, Units 1 & 2 Location: Southport, North Carolina Dates: October 1, 2014 through December 31, 2014 Inspectors: A. Scarbeary, Senior Resident Inspector (Acting)

M. Catts, Senior Resident Inspector M. Schwieg, Resident Inspector G. Kolcum, Senior Resident Inspector, North Anna (Section 4OA2)

M. Bates, Senior Operations Engineer, RII (Section 1R11)

Approved by: George T. Hopper, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000325, 324/2014005; October 1, 2014, through December 31, 2014; Duke Energy

Progress, Inc., Brunswick Steam Electric Plant, Units 1 and 2, Operability Determinations and Functional Assessments, Surveillance Testing.

This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. There was one NRC-identified and one self-revealing violation documented in this report. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP)dated June 2, 2011. The cross-cutting aspects are determined using IMC 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

Green.

The NRC-identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, for the failure to ensure adequate tornado missile protection for the emergency diesel generator (EDG) 4-day fuel oil tank ventilation piping. Specifically, it was determined that the ventilation piping could be sheared with a design basis tornado missile at the 4-day fuel oil tank building roof level and water intrusion into the EDG fuel oil system would occur during a design basis rain event that would prevent the diesel from performing its required safety function. The licensee documented this issue in their corrective action program (CAP) and performed corrective actions to install concrete blocks around the piping.

The inspectors determined that the finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it is associated with the Mitigating Systems Cornerstone attributes of Protection Against External Factors and Equipment Performance, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, it was determined that the ventilation piping could be sheared with a design basis tornado missile at the 4-day fuel oil tank building roof level and water intrusion into the EDG fuel oil system would occur during a design basis rain event that would prevent the EDG from performing its required safety function. Using IMC 0609, Appendix A, issued June 19, 2012, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined the finding screened to a detailed risk evaluation since the EDG1 fuel oil system was assumed to be completely failed due to a tornado, and it would degrade one or more trains of a system that supports a risk significant system or function. The regional Senior Reactor Analyst performed a detailed risk evaluation by using a qualitative screening analysis to determine the significance of the finding. Tornado initiating event frequency was derived from Nation Weather Service data. Because of the low likelihood of a tornado powerful enough to throw an object of sufficient size to damage the piping, the remote chance the thrown object would strike the vent pipe, and because the remaining EDGs would not be impacted in the same way by the tornado, the finding was determined to be

Green.

The inspectors did not identify a cross-cutting aspect associated with this finding because the finding is an old design issue that has been in place since original plant construction. (Section 1R15)

Green.

A Green self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, was identified for the failure to conduct the number 3 EDG monthly load test in accordance with the prescribed technical specification surveillance test procedure. Specifically, plant personnel performing the load test on EDG3 manually synched the generator out-of-phase to its corresponding emergency bus, causing equipment damage to the collector ring and brushes and the silicon controlled rectifier (SCR) circuitry. The licensee documented the issue in their CAP, completed a prompt investigation, and performed a root cause evaluation. The EDG was immediately repaired and additional corrective actions include: 1) revise all EDG monthly load test procedures with cautions to emphasize the importance of synching the generator properly and performing the steps of the procedure as prescribed; and 2) install synch check relays on all manually paralleled generators.

The finding was more than minor in accordance with IMC 0612, Appendix B, because it is associated with the Mitigating Systems Cornerstone attribute of Human Performance, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, plant personnel performing the local load test on EDG3 manually synched the generator out-of-phase to its corresponding emergency bus, resulting in extended EDG3 inoperability and equipment damage to the collector ring, brushes, and the SCR circuitry. Utilizing IMC 0609, Appendix A, Exhibit 1, effective July 1, 2012, the finding screened as Green by answering no to the question related to an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for >24 hrs. The finding had a cross-cutting aspect in the area of Human Performance related to the aspect of Avoid Complacency, in that individuals failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes, and implement appropriate error reduction tools. In this event, the operators had an inaccurate risk perception that the evolution of increasing load on the EDG was more critical than synching the generator properly. This was emphasized during the pre-job brief and not identified by the supervisory oversight of the evolution. [H.12] (Section 1R22)

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at rated thermal power (RTP). On December 19, 2014, the unit was downpowered to 70 percent for a control rod sequence exchange. The unit was returned to RTP on December 21, 2014 and remained at or near RTP for the remainder of the inspection period.

Unit 2 began the inspection period at RTP. On October 10, 2014, the unit was downpowered to 70 percent for a control rod sequence exchange. The unit was returned to RTP on October 11, 2014. On November 18, 2014, the unit was downpowered to 70 percent for a control rod sequence exchange. The unit was returned to RTP on November 19, 2014. On December 5, 2014, the unit was downpowered to 70 percent for a control rod sequence exchange. The unit was returned to RTP on December 6, 2014, and remained at or near RTP for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Seasonal Extreme Weather Conditions

The inspectors conducted a detailed review of the stations seasonal preparation procedures written for winter conditions. The inspectors verified that weather-related equipment deficiencies identified during the previous year had been placed into the work control process and/or corrected before the onset of seasonal extremes. The inspectors evaluated the licensees implementation of seasonal preparation procedures and compensatory measures before the onset of, and during, winter weather conditions. The inspectors walked down the following buildings that are designed to protect risk-significant systems:

• Service Water Building

• Intake Structure and Circulating Water Pump Bay

• EDG Building

• Control Building Documents reviewed are listed in the attachment.

.2 Impending Adverse Weather Conditions

The inspectors reviewed the licensees preparations to protect risk-significant systems during a tornado watch on November 17, 2014. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures, including operator staffing, before the onset of the adverse weather conditions. The inspectors reviewed the licensees plans to address the ramifications of potentially lasting effects that may result from a tornado. The inspectors verified that operator actions specified in the licensees adverse weather procedure maintained readiness of essential systems. The inspectors verified that required surveillances were current, or were scheduled and completed, if practical, before the onset of anticipated adverse weather conditions. The inspectors also verified that the licensee implemented periodic equipment walkdowns or other measures to ensure that the condition of plant equipment met operability requirements. Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. The inspectors selected systems for assessment because they were a redundant or backup system or train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. Documents reviewed are listed in the attachment.

The inspectors selected the following three systems or trains to inspect:

• Unit 2 reactor core isolation cooling system (RCIC);

• Unit 1 core spray (CS) south; and

• Unit 1 division I backup nitrogen system.

.2 Complete Walkdown

The inspectors verified the alignment of the EDG system on October 28-31, 2014. The inspectors selected this system for assessment because it is a risk-significant mitigating system. The inspectors determined the correct system lineup by reviewing plant procedures, drawings, the updated final safety analysis report, and other documents.

The inspectors reviewed records related to the system outstanding design issues, maintenance work requests, and deficiencies. The inspectors verified that the selected system was correctly aligned by performing a complete walkdown of accessible components.

To verify the licensee was identifying and resolving equipment alignment discrepancies, the inspectors reviewed corrective action documents, including condition reports and outstanding work orders. The inspectors also reviewed periodic reports containing information on the status of risk-significant systems, including maintenance rule reports and system health reports. Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Inspection

The inspectors evaluated the adequacy of selected pre-fire plans and fire protection procedures by comparing the pre-fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the pre-fire plans, the inspectors assessed the following items:

• control of transient combustibles and ignition sources

• fire detection systems

• water-based fire suppression systems

• gaseous fire suppression systems

• manual firefighting equipment and capability

• passive fire protection features

• compensatory measures and fire watches

• issues related to fire protection contained in the licensees CAP The inspectors toured the following fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the attachment.

• 2PFP-RB-1c, 2PFP-RB-1d, and 2PFP-RB-2, Unit 2 Reactor Building South and North Residual Heat Removal Room (RHR), High Pressure Coolant Injection (HPCI)

Room, -17 Elevation;

• 2PFP-CB-6 and 1PFP-CB-5 , Unit 1 & 2 Control Building Cable Spreading Room, 23 Elevation;

• 2PFP-TB2-04 & 05, 2PFP-TB2-07, 2PFP-TB2-06, 2PFP-TB2-01A & 01B, 2PFP-TB2-01H, and 2PFP-TB2-01C, Unit 2 Turbine Building Reactor Feedwater Pump, Heater Drain Pump, Condensate Booster Pump, Breezeway North & South, Condensate Pump, Mechanical Vacuum Pump Areas, 20 Elevation;

• 2PFP-TB2-01D, 2PFP-TB2-01E, 2PFP-TB2-01F, and 2PFP-TB2-01G, Unit 2 Turbine Building Air Compressor, 2A Air Dryer, 4 kV Switchgear, Hydrogen Seal Oil Areas, 20 Elevation; and

• 0PFP-DG-1, DG Building Basement, 2 Elevation.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

.1 Internal Flooding

The inspectors reviewed related flood analysis documents and walked down the areas listed below containing risk-significant structures, systems, and components susceptible to flooding. The inspectors verified that plant design features and plant procedures for flood mitigation were consistent with design requirements and internal flooding analysis assumptions. The inspectors also assessed the condition of flood protection barriers and drain systems. In addition, the inspectors verified the licensee was identifying and properly addressing issues using the CAP. Documents reviewed are listed in the attachment.

• Unit 1 and 2, Turbine Building, 38 and 20 Elevations

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

Annual Review The inspectors verified the readiness and availability of the 2A turbine building closed cooling water system heat exchanger (HX) to perform its design function by observing the licensees HX inspections and reviewing the data from those inspections in response to a leak identified in the channel head area of the HX. The inspectors also verified the licensee appropriately implemented the periodic maintenance method, as well as their implementation of biofouling controls. Additionally, the inspectors verified that the licensee entered any significant issues from the HX inspection into the CAP and that the licensees corrective actions were appropriate. Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

The inspectors observed an evaluated simulator scenario, LOT-EOP-016, Reference Leg Plugging, Loss of Level Instrumentation requiring RPV Flooding, administered to an operating crew on November 12, 2014, conducted in accordance with the licensees accredited requalification training program.

The inspectors assessed the following:

• licensed operator performance;

• the ability of the licensee to administer the scenario and evaluate the operators;

• the quality of the post-scenario critique; and

• simulator performance.

Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Review of Licensed Operator Performance

The inspectors observed licensed operator performance in the main control room during a deep downpower evolution on Unit 1 on December 19, 2014.

The inspectors assessed the following:

• use of plant procedures;

• control board manipulations;

• communications between crew members;

• use and interpretation of instruments, indications, and alarms;

• use of human error prevention techniques;

• documentation of activities; and

• management and supervision.

Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

.3 Annual Review of Licensee Requalification Examination Results

a. Inspection Scope

On August 29, 2014, the licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with 10 CFR 55.59(a)(2), Requalification Requirements, of the NRCs Operators Licenses. The inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program. These results were compared to the thresholds established in Section 3.02, Requalification Examination Results, of IP 71111.11. Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors assessed the licensees treatment of the two issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and records to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. Documents reviewed are listed in the attachment.

• Unit 1 and Unit 2 HPCI F003, turbine steam supply outboard isolation valve, and F001, steam supply valve, steam leaks

• Unit 1 125/250V DC Switchboard 1B incorrect torque values

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the four maintenance activities listed below to verify that the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the CAP. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities. Documents reviewed are listed in the attachment.

• Unit 1 and Unit 2 elevated risk due to EDG1 unplanned inoperability on October 2, 2014;

• Unit 2 yellow risk condition for RHR system and CS system technical specification surveillance testing on October 8, 2014;

• Unit 1 elevated risk due to EDG1 and 1B conventional service water (CSW) train concurrently scheduled maintenance outages on October 27-28, 2014; and

• Unit 2 elevated risk for new fuel receipt and inspections and Unit 1 emergent work on the 1B-1 Isophase bus cooling fan during the week of December 8-12, 2014.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors selected the three operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.

Documents reviewed are listed in the attachment.

• 2A residual heat removal service water system check valve failure, CR 707742;

• EDG 4-day fuel oil tank ventilation piping not protected against tornado missiles, CR 686589; and

• Unit 1 reactor building ventilation exhaust fans trip, CR 720215.

b. Findings

Introduction.

The NRC identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for failure to ensure adequate tornado missile protection for the EDG 4-day fuel oil tank ventilation piping.

Description.

On May 8, 2014, during a walkdown, the inspectors noted that the EDG 4-day fuel oil tank ventilation piping was not protected from tornado-borne missiles. The inspectors questioned the licensee on the whether this piping needed to be tornado-protected, and if so, could it withstand the design basis tornado and rain event. On August 14, 2014, under WO 13421302, the licensee took corrective actions to place concrete blocks around the ventilation piping. An engineering evaluation was then performed that identified the worst case design basis tornado and rainfall scenario conditions and what effect those would have on EDG operation. It was determined that with the maximum 24-hour rainfall rate and a tornado missile shearing the ventilation piping at the roof level, the worst case scenario was the EDG1 4-day tank filling with water which would be transferred over to the EDG1 saddle tank. The saddle tank would fill to a level high enough to impact EDG operation in less than two hours. Following this evaluation, the licensee completed engineering change (EC) 96860 to install concrete barrier pads around the ventilation piping at the 4-day tank roof level to preclude a tornado missile impact at the most vulnerable part of the piping, and also preclude water accumulation on the roof from entering the EDG 4-day tanks. The inspectors reviewed the engineering evaluation, EC, and interviewed engineering personnel to understand the scenario and the impact to plant operation.

The Brunswick Original Final Safety Analysis Report (Appendix F) and Updated Final Safety Analysis Report (UFSAR), Chapter 3, contain the language of the regulatory requirements for the general design criteria listed in 10 CFR Part 50, Appendix A, and how the licensee complies with those criteria. Criterion 2 for protection against natural phenomena states, in part, that structures, systems, and components (SSCs) important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. The licensees statement of compliance states, SSCs important to safety have been designed with appropriate margin for uncertainties, to permit safe plant operation or shutdown even under conditions of the most severe natural phenomena which have been conservatively postulated to occur at the site. Criterion 4 for missile design bases states, in part, that SSCs important to safety shall be appropriately protected against dynamic effects, including the effects of missiles, which may result from events and conditions outside the nuclear power unit.

The licensees statement of compliance states, SSCs important to safety have been designed with full consideration of the combined effects of the normal and postulated accident environment, including the effects of pipe whipping or other dynamic effects resulting from the accidents. Section 3.5.1.4 of the UFSAR contains the specific analysis of four potential tornado-borne missiles and the effects on the plant. The impact of one of these missiles, shearing the EDG 4-day fuel oil tank ventilation line, along with water intrusion into the system from the design basis rainfall event, would prevent the EDG (an SSC important to safety) from performing its required safety function of providing a reliable source of AC power to the engineered safety features for safe shutdown of the plant or during design basis accidents.

Analysis.

The inspectors determined the failure to ensure adequate tornado missile protection for the EDG 4-day fuel oil tank ventilation piping was a performance deficiency that warranted a significance determination. The inspectors determined that the finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it is associated with the Mitigating Systems Cornerstone attributes of Protection Against External Factors and Equipment Performance, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it was determined that the ventilation piping could be sheared with a design basis tornado missile at the 4-day fuel oil tank building roof level and water intrusion into the EDG fuel oil system would occur during a design basis rain event that would prevent the EDG from performing its required safety function. Using IMC 0609, Appendix A, issued June 19, 2012, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined the finding screened to a detailed risk evaluation since the EDG1 fuel oil system was assumed to be completely failed due to a tornado, and it would degrade one or more trains of a system that supports a risk significant system or function. The regional Senior Reactor Analyst performed a detailed risk evaluation by using a qualitative screening analysis to determine the significance of the finding.

Tornado initiating event frequency was derived from Nation Weather Service data.

Because of the low likelihood of a tornado powerful enough to throw an object of sufficient size to damage the piping, the remote chance the thrown object would strike the vent pipe, and because the remaining EDGs would not be impacted in the same way by the tornado, the finding was determined to be Green. The inspectors did not identify a cross-cutting aspect associated with this finding because the finding is an old design issue that has been in place since original plant construction.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis, as defined in Part 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, since the initial construction of both units, until August 14, 2014, the licensee failed to translate the appropriate tornado missile protection requirements into the design of the EDG 4-day fuel oil tank ventilation piping. The licensee performed corrective actions to install concrete blocks around the tank ventilation piping. This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensees CAP as CR 686589.

(NCV 05000324; 325/2014005-01, Failure to Protect Emergency Diesel Generator 4-Day Fuel Oil Tank Ventilation Piping from Tornado Missiles)

1R18 Plant Modifications

a. Inspection Scope

The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modification did not degrade the design bases, licensing bases, and performance capability of risk significant structures, systems and components. The inspectors also verified modification performed during plant configurations involving increased risk did not place the plant in an unsafe condition. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with the modification. Documents reviewed are listed in the attachment.

• Addition of supplemental diesel generator to lengthen the time of the EDG Limiting Condition for Operation (LCO) including mechanical and electrical connections, and acceptance testing (EC 79694).

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors either observed post-maintenance testing (PMT) or reviewed the test results for the six maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.

• Work Order (WO) #13309525, EDG1 Ventilation Damper Temperature Controller, October 2, 2014;

• WO #13450687, EDG1 PMT run after maintenance outage, October 31, 2014;

• WO #13445330, EDG3 Emergency Control Relay (ECR) failure, October 15, 2014;

• WO #13435593, Unit 1 Division II Nitrogen Backup valve failure, September, 13, 2014;

• WO #13442338, 1-SW-1B-CONV-PMP-STR, 1B CSW Pump Strainer: Strainer Through-Wall Leak, October 9, 2014; and

• WO #13437731, 1-SW-1C-CONV-PMP-STR-M, 1C CSW Pump Strainer: Not Working When Expected, September 24, 2014 and WO #13441022, 1-SW-1B-NUC-PMP-STR, 1B Nuclear Service Water Pump Strainer: Perform Internal Inspection of Strainer, October 2, 2014.

The inspectors evaluated these activities for the following:

• Acceptance criteria were clear and demonstrated operational readiness

• Effects of testing on the plant were adequately addressed

• Test instrumentation was appropriate

• Tests were performed in accordance with approved procedures

• Equipment was returned to its operational status following testing

• Test documentation was properly evaluated Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing. Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.

Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the attachment.

Routine Surveillance Tests

• 0PT-12.2C, DG3 Monthly Load Test;

• 2PT-24.1-2, Service Water Pump and Discharge Valve Operability Test;

• 2MST-RPS26R, Reactor Protection System High Drywell Pressure Instrumentation Channel Calibration Test; and

• 0MST-IRM21FR, Intermediate Range Monitor Channel F Calibration/Functional Test.

In-Service Tests

• 0PT-10.1.1, RCIC System Operability Test

b. Findings

Introduction:

A Green self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the failure to conduct the EDG3 monthly load test in accordance with the prescribed technical specification surveillance test procedure. This resulted in EDG3 being manually synched out-of-phase to its corresponding emergency bus.

Description:

On November 9, 2014, the EDG3 monthly load test was being performed using technical specification surveillance procedure, 0PT-12.2C, in which the diesel generator would be started, synched, and loaded locally at the control panel in the diesel room. The non-licensed operator (NLO1) who was manipulating the controls was qualifying for the task under a task performance evaluation (TPE) which was being administered by a long-time qualified non-licensed operator (NLO2) and overseen in the field by an experienced senior reactor operator (SRO). Once EDG3 was started and all appropriate parameters were established, the SRO went to verify personnel were clear of the switchgear room prior to the operators closing the EDG output breaker. After receiving the all-clear, NLO1 and NLO2 proceeded with the procedure without the SRO having returned from the switchgear room. To synch the generator, NLO1 had one hand on the output breaker switch and one hand on the governor control switch, to raise load after the breaker had closed. NLO1 watched the synchroscope until it was at approximately the 9 oclock position then looked up at the Output Kilowatt Meter to watch for increasing the load. NLO2 watched the synchroscope until the 11 oclock position then focused on the hand manipulations of the trainee. NLO1 attempted to close the output breaker when the synchroscope was believed to be at the 12 oclock position. Immediately there was a loud bang in the room, vibrations felt by the operators from EDG3, and several alarms were received in the control room and locally on the control panel. NLO2 took control of the switches and shut down EDG3 using the Emergency Stop pushbutton.

The steps of synching and loading the EDG were considered critical steps in accordance with procedure 0PT-12.2C. A pre-job brief was held earlier that day where defense mechanisms and human performance tools that could be used as barriers to prevent an incident were discussed, such as a dry run of the synch in the field before performing the steps and use of flagging to verify the proper switches were being manipulated. Through interviews after the event, NLO1 indicated knowledge of the importance of synching the generator in-phase but also stated that there was a large emphasis during preparation for the activity of quickly increasing the load on the generator to prevent a reverse power condition. Section 7.3 of 0PT-12.2C contains a caution statement before performing these steps that states, if load is not raised immediately after closing the generator breaker, the EDG may trip on reverse power, and a note in this section states to perform these steps without delay. However, the procedure directs the steps in this section to be performed in sequence. The steps clearly direct verification of the closing of the EDG onto its emergency bus before proceeding with increasing load on the engine.

The licensee performed an equipment failure investigation immediately following the shutdown of EDG3 and identified some pitting on the collector ring of the EDG, a failed SCR, and a faulted SCR exciter circuit diode. All of these items were repaired/replaced and were all identified to be results of the out-of-synch evolution, not causes. The licensee completed a prompt investigation and a root cause evaluation of the event.

Several opportunities for improvement were identified in the areas of operator fundamentals (performing two-handed evolutions), performance of the pre-job brief (appropriate emphasis on the risk-significance of all critical steps in the task and review of applicable OE), training of non-licensed operators and the execution of TPEs, and supervisory oversight of higher risk evolutions.

Analysis:

The inspectors determined that the failure to conduct the EDG3 monthly load test in accordance with the prescribed technical specification surveillance test procedure was a performance deficiency. The inspectors determined that the finding was more than minor in accordance with IMC 0612 Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it is associated with the Mitigating Systems Cornerstone attribute of Human Performance, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, plant personnel performing the local load test on EDG3 manually synched the generator out-of-phase to its corresponding emergency bus, resulting in extended EDG3 inoperability and equipment damage to the collector ring, brushes, and the SCR circuitry. Utilizing IMC 0609, Appendix A, Exhibit 1, effective July 1, 2012, the finding screened as Green by answering no to the Mitigating SSCs and Functionality question related to an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for >24 hrs.

The finding had a cross-cutting aspect in the area of Human Performance related to the aspect of Avoid Complacency, in that individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes, and individuals implement appropriate error reduction tools [H.12]. In this event, the operators had an inaccurate risk perception that the evolution of increasing load on the EDG was more critical than synching the generator properly. This was emphasized during the pre-job brief and not identified by the supervisory oversight of the evolution.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with instructions, procedures, or drawings appropriate to the circumstances.

Contrary to this, on November 9, 2014, the licensee did not conduct the EDG3 monthly load test in accordance with the prescribed technical specification surveillance test procedure, 0PT-12.2C. The corrective actions for this issue are to 1) revise all EDG monthly load test procedures with cautions to emphasize the importance of synching the generator properly and performing the steps of the procedure as prescribed; 2)revise operator training lesson plans for performing EDG synching evolutions, as well as guidance on when and how to perform two-handed evolutions; 3) install synch check relays on all manually paralleled generators; and 4) ensure roles and responsibilities are well understood for TPE evaluators and oversight. This violation is being treated as an NCV, consistent with section 2.3.2.a of the Enforcement Policy. The licensee documented this issue in condition report CR 717634. (NCV 05000324/2014005-02, Failure to Follow Emergency Diesel Generator No. 3 Monthly Load Test Surveillance Procedure)

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between October 1, 2013, and September 30, 2014 to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures.

The inspectors verified the accuracy of reported data that were used to calculate the value of each PI. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data. Documents reviewed are listed in the attachment.

Cornerstone: Mitigating Systems

• HPCI system

• RCIC system

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

The inspectors screened items entered into the licensees CAP in order to identify repetitive equipment failures or specific human performance issues for followup. The inspectors reviewed condition reports, attended screening meetings, or accessed the licensees computerized corrective action database.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors reviewed issues entered in the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on a trend for secondary containment integrity program, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of July 2014 to December 2014 although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends.

Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.

Documents reviewed are listed in the attachment.

b. Findings and Observations

No findings were identified.

.3 Annual Followup of Selected Issues

a. Inspection Scope

The inspectors performed a review regarding the licensees assessments and corrective actions for CR 690721 and Reply to Notice of Violation, EA-14-048, involving the failure of the licensee to promptly identify and correct conditions adverse to quality associated with flood protection of multiple safety-related buildings, as documented in BSEP 14-0075. The inspectors performed the review to ensure that the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors also evaluated the CR against the requirements of the licensees CAP as specified in procedures, CAP-NGGC-0200, Condition Identification and Screening Process; CAP-NGGC-0205, Condition Evaluation and Corrective Action Process; CAP-NGGC-0206, Performance Assessment and Trending; and 10 CFR Part 50, Appendix B. Documents reviewed are listed in the attachment.

b. Findings and Observations

No findings were identified. The inspectors verified that the licensee implemented the corrective actions identified in Reply to Notice of Violation, EA-14-048, and that those actions were appropriate. The following open corrective action items will be reviewed after completion in 2015:

• A review and update, as necessary, of the Brunswick design basis for high winds;

• An effectiveness review performed for the apparent cause evaluation documented in AR 690721, Apparent Cause for Notice of Violation, EA-14-048; and

• An effectiveness review performed for the root cause evaluation documented in AR 490292, 4 Day Fuel Oil Tank Enclosure Degradation.

4OA3 Follow-up of Events

.1 (Closed) Event Notification (EN) 50459, Loss of Emergency Preparedness Sirens

a. Inspection Scope

For the plant event listed below, the inspectors reviewed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional NRC personnel, and compared the event details with criteria contained in IMC 0309, issued October 28, 2011, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that the licensee made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR 50.72. The inspectors reviewed the licensees follow-up actions related to the events to assure that the licensee implemented appropriate corrective actions commensurate with their safety significance. This constitutes one sample. Documents reviewed are listed in the attachment.

• On September 15, 2014, it was determined that the ability to activate the 38 emergency sirens within the 10-mile emergency planning zone (EPZ) was lost.

The activation capability was restored within two hours when a loose cable was discovered and replaced. The event did not result in any adverse impact since the county back-up routing was available to notify the public. The licensee wrote CR 708969 to address this event.

b. Findings

No findings were identified.

.2 (Closed) Licensee Event Report (LER) 2014-002-00, Secondary Containment Loss of

Safety Function Due to Opening in Reactor Building Roof Drain Line and Event Notification (EN) 50046, Loss of Secondary Containment due to Opening in Reactor Building Roof Drain Piping

a. Inspection Scope

On April 20, 2014, the licensee identified pooled water on the floor on the 80-foot elevation of the Unit 2 reactor building. Upon further investigation, a through-wall leak in the Unit 2 reactor building 8-inch roof drain pipe was identified. The leak size was estimated to exceed the maximum allowable margin of the secondary containment pressure boundary, which resulted in secondary containment being considered inoperable per technical specifications. On April 20, 2014, the NRC was notified of the event per Event Notification 50046. On June 19, 2014, the licensee submitted LER 2-2014-002 for a condition prohibited by the plants technical specifications and that could have prevented fulfillment of the safety function of secondary containment to control the release of radioactive material to the public. On November 17, 2014, an engineering evaluation was completed which performed a more detailed characterization of the affected section of the Unit 2 reactor building roof drain piping. It was determined the leakage area did not exceed the allowable leakage margin and, therefore, secondary containment was still operable and capable of fulfilling its safety function. As a result, LER 2-2014-002 was cancelled on December 4, 2014. The inspectors reviewed the engineering evaluation and did not identify any issues with the retraction of the LER.

The licensees immediate corrective action was to install a patch to seal the leak and is planning to replace the Unit 1 and Unit 2 reactor building roof drain piping in future refueling outages. The licensee entered this issue into the CAP as CR 690674.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Closed) URI 05000324; 325/2014004-02, Tornado Protection of the Emergency Diesel

Fuel Oil Tank Vent Lines

a. Inspection Scope

The inspectors completed a review of URI 05000324; 325/2014004-02, Tornado Protection of the Emergency Diesel Fuel Oil Tank Vent Lines. On May 8, 2014, during a walkdown, the inspectors noted that the EDG 4-day fuel oil tank vent lines were not protected from tornado-borne missiles. The inspectors questioned the licensee on the whether these vents needed to be tornado-protected, and if so, could they withstand the design basis tornado and rain event. On August 14, 2014, the licensee took corrective actions to place concrete blocks around the vent lines. An engineering evaluation was then performed that identified the worst case design basis tornado and rainfall scenario conditions and what effect those would have on EDG operation. It was determined that with the maximum 24-hour rainfall rate and a tornado missile shearing the ventilation piping at the roof level, the worst case scenario was EDG1 4-day tank filling with water which would be transferred over to the EDG saddle tank. The saddle tank would fill to a level high enough to impact EDG operation in less than two hours. The licensee completed EC 96860 to install concrete barrier pads around the ventilation piping at the 4-day tank roof level to preclude a tornado missile impact at the most vulnerable part of the piping, and also preclude water accumulation on the roof from entering the EDG 4-day tanks. The inspectors reviewed the engineering evaluation, EC, and interviewed engineering personnel to understand the scenario and the impact to plant operation.

Documents reviewed are listed in the attachment.

b. Findings

An NRC-identified violation was identified and documented in section 1R15 of this report. This URI is closed.

4OA6 Meetings, Including Exit

An interim exit was conducted on December 12, 2014, by Greg Kolcum to present the inspection results of the focused PI&R sample related to flooding issues to Mr. William R. Gideon and other members of the licensees staff.

On January 20, 2015, the resident inspectors presented the inspection results to Mr. William R. Gideon and other members of the licensees staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

W. Gideon Vice President

J. Krakuszeski Plant Manager

K. Allen Director, Design Engineering

A. Brittain Director, Nuclear Plant Security

S. Brown Manager, Nuclear Oversight

K. Crocker Manager, Nuclear Emergency Preparedness

S. Gordy Manager, Maintenance

L. Grzeck Manager, Nuclear Regulatory Affairs

K. Hamm Superintendent, Mechanical Mnt

R. Heiber Superintendent, Nuclear Maintenance

J. Hicks Manager, Nuclear Training

B. Houston Manager, Nuclear Rad Protection

F. Jefferson Director, Nuclear Engineering

J. Johnson Manager, Nuclear Chemistry

J. Kalamaja Manager, Nuclear Operations

J. Nolin General Manager, Nuclear Engineering

W. Orlando Superintendent, E/I&C

A. Padleckas Assistant Ops Manager, Shift

F. Payne Manager, Nuclear Work Management

A. Pope Director, Nuclear Operating Experience

M. Schultheis Manager, Nuclear Performance Improvement

M. Smiley Manager, Nuclear Ops Training

R. Wiemann Director, Electrical/Rx Systems

E. Williams Superintendent, Nuclear Maintenance

NRC Personnel

G. Hopper Chief, Reactor Projects Branch 4

J. Dodson Senior Project Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000324; 325/2014005-01 NCV Failure to Protect Emergency Diesel Generator 4-Day Fuel Oil Tank Ventilation Piping from Tornado Missiles (Section 1R15)

05000324/2014005-02 NCV Failure to Follow Emergency Diesel Generator No. 3 Monthly Load Test Surveillance Procedure (Section 1R22)

Closed

Event Notification 50459 EN Loss of Emergency Siren Activation Capability (Section 4OA3.1)

05000325; 324/2014004-02 URI Tornado Protection of the Emergency Diesel Fuel Oil Tank Vent Lines (Section 4OA5.2)

05000324/2014-002-00 LER Secondary Containment Loss of Safety Function Due to Opening in Reactor Building Roof Drain Line (Section 4OA3.2)

Event Notification 50046 EN Loss of Secondary Containment due to Opening in Reactor Building Roof Drain Piping (Section 4OA3.2)