IR 05000324/2017003
| ML17311A770 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/07/2017 |
| From: | Steven Rose NRC/RGN-II/DRP/RPB4 |
| To: | William Gideon Duke Energy Progress |
| References | |
| IR 2017003 | |
| Download: ML17311A770 (32) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 7, 2017
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 05000325/2017003 AND 05000324/2017003
Dear Mr. Gideon:
On September 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Steam Electric Plant, Units 1 and 2. On October 25, 2017, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection. However, the inspectors documented a licensee-identified violation, which was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or the significance of the violation, 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, and the NRC Resident Inspector at the Brunswick Steam Electric Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Steven D. Rose, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62
Enclosure:
IR 05000325, 324/2017003 w/Attachment: Supplementary Information
REGION II==
Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62 Report No.: 05000325/2017003, 05000324/2017003 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant, Units 1 & 2 Location: Southport, NC Dates: July 1, 2017 through September 30, 2017 Inspectors: G. Smith, Senior Resident Inspector M. Schwieg, Resident Inspector A. Patz, Resident Inspector (Sections 1R05Q, 1R19, 1R22)
S. Sanchez, Sr. Emergency Preparedness Inspector (Sections 1EP2, 1EP3, 1EP4, 1EP5, 4OA1)
C. Fontana, Emergency Preparedness Inspector (Sections 1EP2, 1EP3, 1EP4, 1EP5, 4OA1)
J. Panfel, Heath Physicist (Sections 1EP2, 1EP3, 1EP4, 1EP5, 4OA1)
W. Loo, Sr. Health Physicist (Sections 2RS2, 4OA1)
J. Rivera, Health Physicist (2RS5)
Approved by: Steven D. Rose, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY
Integrated Inspection Report 05000325/2017003, 05000324/2017003; July 1, 2017, through
September 30, 2017; Brunswick Steam Electric Plant, Units 1 and 2.
The report covered a three-month period of inspection by resident inspectors and regional inspectors. There were no NRC-identified violations 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 April 29, 2015. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated November 1, 2016. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.
A violation of very low safety significance, which was identified by the licensee, was reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program (CAP). The violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent rated thermal power (RTP). On August 25, 2017, power was reduced to 70 percent for control rod sequence and valve testing.
The power was returned to 100 percent on August 27, 2017. On August 30, 2017, the power was reduced to 85 percent for a control rod improvement. The power was returned to 100 percent on August 31, 2017. On September 29, 2017, the power was reduced to 70 percent for a control rod improvement. The power was returned to 100 percent on September 30, 2017, and remained at or near 100 percent RTP for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent RTP. On July 13, 2017, power was reduced to 88 percent to repair the 230 kV Whiteville line. After repairs, power was returned to 100 percent on July 14, 2017. On September 15, 2017, the power was reduced to 70 percent for control rod sequence testing. The power was returned to 100 percent on September 18, 2017. The unit remained at or near 100 percent RTP for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed the licensees preparations to protect risk-significant systems from Hurricane Harvey and Hurricane Irma between August 28 and September 12, 2017. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures, including operator staffing, before the onset of and during the adverse weather conditions. The inspectors reviewed the licensees plans to address the ramifications of potentially lasting effects that could have resulted from the adverse weather conditions. The inspectors verified that operator actions specified in the licensees adverse weather procedure maintain 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 walk downs 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
a. Inspection Scope
.1 Partial Walkdown
The inspectors verified that critical portions of the four selected systems were correctly aligned by performing partial walkdowns. The inspectors selected these particular 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
.
The inspectors selected the following systems or trains to inspect:
- Unit 1 reactor core isolation cooling system while high pressure coolant injection system (HPCI) was out-of-service (OOS) for planned maintenance
- Unit 1 emergency diesel generator (EDG) No. 4
- Unit 1 A train residual heat removal (RHR) while B train RHR was OOS for planned maintenance
.2 Complete System Walkdown
The inspectors verified the alignment of the control building ventilation system. 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 systems 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 order (WOs). 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 (71111.05Q/A - 5 samples)
a. Inspection Scope
.1 Quarterly Inspection
The inspectors evaluated the adequacy of selected pre-fire plans 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 four fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the
.
- Unit 1 HPCI room, -17 ft. elevation, 1PFP-RB1-02
- Unit 1 RHR room, -17 ft. elevation, 1PFP-RB1-01C
- Unit 1 Reactor Building East Central, 20 ft. Elevation, 1PFP-RB1-01G
- Diesel Generator basement, 2ft. elevation, 0PFP-DG-1
.2 Annual Inspection
The inspectors evaluated the licensees fire brigade performance during an actual fire on August 3, 2017, and assessed the brigades capability to meet fire protection licensing basis requirements. The fire was associated with the turbine building crane motor on Unit 2. No flames were noted, however, a burning smell was exhibited. The fire was extinguished and electrical power was removed within 15 minutes. The inspectors observed the following aspects of fire brigade performance:
- capability of fire brigade members
- leadership ability of the brigade leader
- use of turnout gear and fire-fighting equipment
- team effectiveness
- compliance with site procedures The inspectors also assessed the ability of control room operators to combat potential fires, including identifying the location of the fire, dispatching the fire brigade, and sounding alarms. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
Internal Flooding The inspectors reviewed related flood analysis documents and walked down the area 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.
- Control Building
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
a. Inspection Scope
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
On September 15, 2017, the inspectors observed an evaluated simulator scenario administered to an operating crew as part of the annual requalification operating test required by 10 CFR 55.59, Requalification. The scenario involved the loss of a DC motor control center followed by a spurious 2B core spray actuation signal. Eventually, the scenario evolved to a line rupture in the reactor water cleanup system and failure of the HPCI system that necessitated an emergency depressurization.
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
- simulator performance Documents reviewed are listed in the attachment.
.2 Resident Inspector Quarterly Review of Licensed Operator Performance in the Actual
Plant/Main Control Room The inspectors observed licensed operator performance in the main control room during licensee procedure 2AOP-04, Low Core Flow, when the 2B recirculation pump variable frequency drive tripped on an internal fault. This fault caused core flow to drop by four percent. Additionally, the inspectors evaluated the execution of clearances in the main control room.
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
- management and supervision 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.
- service water building high room temperature
- maintenance rule a(3) evaluation report (2015 - 2017)
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the five 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.
- Yellow risk due to Unit 2 B RHR/Residual Heat Removal Service Water (RHRSW)outage on July 5, 2017
- Yellow risk due to Unit 1 B RHR/RHRSW outage on August 2, 2017
- Elevated risk due to 2A nuclear service water pump outage on August 10, 2017
- Elevated risk due to planned Unit 2 A train RHR outage on August 31, 2017
- Emergent failure of EDG No. 2 on September 22, 2017
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
Operability and Functionality Review The inspectors selected the six 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 (TS) 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 TS 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.
- EDG No. 1 time delay relay failure, condition report (CR) 2136973
- EDG No. 4 unable to reach 3850 kW, CR 2138157
- EDG No. 4 tripped due to frequency/kilowatt, CR 2151329
- RHRSW leak, CR 2141499
- EDG Loose lug on degraded voltage relay, CR 2144019
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors either observed post-maintenance testing or reviewed the test results for the 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.
- WO 20183414, Unit 1 HPCI turbine bearing oil pressure low, July 13, 2017
- WO 20076379, 2A CREV maintenance outage, July 24, 2017
- WO 20034694, EDG No. 4 emergency auto-start relay replacement on July 19, 2017
- WO 13457478, Replace 2A nuclear service water pump on August 10, 2017
- WO 20100391, Repair EDG No. 2 field flash relay on September 18, 2017 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 four surveillance tests listed below and either observed the test or reviewed test results to verify testing activities adequately demonstrated that the affected structures, systems and components remained capable of performing the intended safety functions (under conditions as close as practical to design bases conditions or as required by TS) and maintained their operational readiness.
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-07.2.4B, Core Spray System Operability Test
- 0PT-34.2.2.1, Fire Door Inspections
- 0PT-08.2.2B, LPCI/RHR System Operability Test - Loop B
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
The inspectors evaluated the adequacy of the licensees methods for testing and maintaining the alert and notification system in accordance with NRC Inspection Procedure (IP) 71114, Attachment 02, Alert and Notification System Evaluation. The applicable planning standard, 10 CFR Part 50.47(b)(5), and its related 10 CFR Part 50, Appendix E requirements were used as reference criteria. The criteria contained in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, were also used as a reference.
The inspectors reviewed various documents which are listed in the Attachment and interviewed personnel responsible for system performance. This inspection activity satisfied one inspection sample for the alert and notification system on a biennial basis.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03 -
1 sample)
a. Inspection Scope
The inspectors reviewed the licensees Emergency Response Organization (ERO)augmentation staffing requirements and process for notifying the ERO to ensure the readiness of key staff for responding to an event and timely facility activation. The qualification records of key position ERO personnel were reviewed to ensure all ERO qualifications were current. A sample of problems identified from augmentation drills or system tests performed since the last inspection was reviewed to assess the effectiveness of corrective actions. The inspection was conducted in accordance with NRC IP 71114, Attachment 03, Emergency Response Organization Staffing and Augmentation System. The applicable planning standard, 10 CFR 50.47(b)(2), and its related 10 CFR Part 50, Appendix E, requirements were used as reference criteria.
The inspectors reviewed various documents which are listed in the Attachment. This inspection activity satisfied one inspection sample for the ERO staffing and augmentation system on a biennial basis.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Since the last NRC inspection of this program area, one change was made to the Radiological Emergency Plan, no changes were made to the emergency action levels, and several changes were made to the implementing procedures. The licensee determined that, in accordance with 10 CFR 50.54(q), the Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspectors reviewed these changes to evaluate for potential reductions in the effectiveness of the Plan. However, this review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.
The inspection was conducted in accordance with NRC IP 71114, Attachment 04, Emergency Action Level and Emergency Plan Changes. The applicable planning standards of 10 CFR 50.47(b), and its related requirements in 10 CFR Part 50, Appendix E were used as reference criteria. The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspectors reviewed the corrective actions identified through the Emergency Preparedness program to determine the significance of the issues, the completeness and effectiveness of corrective actions, and to determine if issues were recurring. The licensees post-event after action reports, self-assessments, and audits were reviewed to assess the licensees ability to be self-critical, thus avoiding complacency and degradation of their emergency preparedness program. Inspectors reviewed the licensees 10 CFR 50.54(q) change process, personnel training, and selected screenings and evaluations to assess adequacy. The inspectors toured facilities and reviewed equipment and facility maintenance records to assess licensees adequacy in maintaining them. The inspectors evaluated the capabilities of selected radiation monitoring instrumentation to adequately support Emergency Action Level (EAL)declarations.
The inspection was conducted in accordance with NRC IP 71114, Attachment 05, and Maintenance of Emergency Preparedness. The applicable planning standards, related 10 CFR 50, Appendix E requirements, and 10 CFR 50.54(q) and
- (t) were used as reference criteria. The inspectors reviewed various documents which are listed in the
. This inspection activity satisfied one inspection sample for the maintenance of emergency preparedness on a biennial basis.
b. Findings
No findings were identified.
RADIATION SAFETY
(RS)
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS2 Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
a. Inspection Scope
Work Planning and Exposure Tracking The inspectors reviewed work activities and their collective exposure estimates for the last Unit 2 refueling outage (RFO) (B223R1). In addition, the inspectors reviewed activities and ALARA planning packages associated with the ongoing Unit 1 dry fuel storage fuel loading campaign. The inspectors reviewed ALARA planning packages for Unit 2 RFO B223R1 activities related to the following high collective exposure tasks: In-Service Inspection/Non-Destructive Examination, reactor reassembly, and insulation activities. For the selected tasks, the inspectors reviewed established dose goals and discussed assumptions regarding the bases for the current estimates with responsible ALARA planners. The inspectors evaluated the incorporation of exposure reduction initiatives and operating experience, including historical post-job reviews, into radiation work permit requirements. Day-to-day collective dose data for the selected tasks were compared with established dose estimates and evaluated against procedural criteria (work-in-progress review limits) for additional ALARA review. Where applicable, the inspectors discussed changes to established estimates with ALARA planners and evaluated them against work scope changes or unanticipated elevated dose rates.
Source Term Reduction and Control The inspectors reviewed the collective exposure three-year rolling average from 2013 - 2015. Source term reduction initiatives, including cobalt reduction and zinc injection, were reviewed and discussed with cognizant licensee staff. The inspectors also reviewed temporary shielding packages for Unit 2 RFO B223R1.
Problem Identification and Resolution The inspectors reviewed and discussed selected CAP documents associated with ALARA program implementation. The inspectors evaluated the licensees ability to identify and resolve the issues. The inspectors also reviewed recent self-assessment results.
Inspection Criteria ALARA program activities were evaluated against the requirements of Updated Final Safety Analysis Report (UFSAR) Section 12, TS Section 5.4, 10 CFR Part 20, and approved licensee procedures. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation (71124.05 - 3 Samples)
a. Inspection Scope
The inspectors reviewed the licensees radiation monitoring instrumentation programs to verify the accuracy and operability of radiation monitoring instruments used to monitor areas, materials, and workers to ensure a radiologically safe work environment during normal operations and under postulated accident conditions.
Walkdowns and Observations During tours of the site areas, the inspectors observed installed radiation detection equipment including the following instrument types: area radiation monitors (ARMs),continuous air monitors (CAMs), personnel contamination monitors (PCMs), small article monitors (SAMs), and portal monitors (PMs). The inspectors observed the calibration status, physical location, material condition and compared TSs for this equipment with UFSAR requirements. In addition, the inspectors observed the calibration status and functional checks of selected in-service portable instruments and discussed the bases for established frequencies and source ranges with radiation protection staff personnel.
The inspectors reviewed periodic source check records for compliance with plant procedures and manufacturers recommendation for selected instruments and observed the material condition of sources used.
Calibration and Testing Program The inspectors reviewed calibration data for selected ARMs, PCMs, PMs, SAMs, and laboratory instruments as well as the last calibration and methodology for the whole body counter. The inspectors reviewed calibration data, methodology used and the source certification for the Unit 1 dry well high-range radiation monitor. The current output values for the portable instrument calibrator and the instrument certifications used to develop them were reviewed by the inspectors. The inspectors reviewed the licensees process for investigating instruments that were removed from service for calibration or response check failures and discussed specific instrument failures with plant staff. In addition, the inspectors reviewed 10 CFR Part 61 data to determine if sources used in the maintenance of the licensees radiation detection instrumentation were representative of radiation hazards in the plant and scaled appropriately for hard to detect nuclides.
Problem Identification and Resolution The inspectors reviewed and discussed selected CAP documents associated with radiological instrumentation including licensee-sponsored assessments. The inspectors evaluated the licensees ability to identify and resolve issues.
Inspection Criteria Operability and reliability of selected radiation detection instruments were reviewed against details documented in the following: 10 CFR Part 20; NUREG-0737, Clarification of TMI Action Plan Requirements; UFSAR Chapter 12, TS Section 3.3.3.1, and applicable licensee procedures. Documents reviewed are listed in the report
.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
.1 Emergency Preparedness PIs
The inspectors sampled licensee submittals relative to the three PIs listed below for the period July 1, 2016, through June 30, 2017. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used to confirm the reporting basis for each data element.
Emergency Preparedness Cornerstone
- Drill/Exercise Performance (DEP)
- Emergency Response Organization Readiness
- Alert and Notification System (ANS) Reliability For the specified review period, the inspectors examined data reported to the NRC, procedural guidance for reporting PI information, and records used by the licensee to identify potential PI occurrences. The inspectors verified the accuracy of the PI for ERO drill and exercise performance through review of a sample of drill and event records.
The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO. The inspectors verified the accuracy of the PI for alert and notification system reliability through review of a sample of the licensees records of periodic system tests. The inspectors also interviewed the licensee personnel who were responsible for collecting and evaluating the PI data. Licensee procedures, records, and other documents reviewed within this inspection area are listed in the Attachment. This inspection satisfied three inspection samples for PI verification on an annual basis.
.2 Radiation Safety PIs
Occupational Radiation Safety Cornerstone The inspectors reviewed the Occupational Exposure Control Effectiveness PI results for the Occupational Radiation Safety Cornerstone from January 2016 through June 2017.
For the assessment period, the inspectors reviewed electronic dosimeter alarm logs and CAP documents related to controls for exposure significant areas. Documents reviewed are listed in the Attachment.
Public Radiation Safety Cornerstone The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from January 2016 through June 2017. For the assessment period, the inspectors reviewed cumulative and projected doses to the public contained in liquid and gaseous release permits and CAP documents related to Radiological Effluent TS/Offsite Dose Calculation Manual issues.
The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in the Attachment.
.3 Reactor Safety PIs
The inspectors reviewed a sample of the performance indicator data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between July 1, 2016, and June 30, 2017 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: Barrier Integrity
- reactor coolant system leak rate for Unit 1 and Unit 2
- reactor coolant system specific activity for Unit 1 and Unit 2
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
The inspectors screened items entered into the licensees CAP 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 Annual Followup of Selected Issues
a. Inspection Scope
The inspectors conducted a detailed review of the CRs below:
- CR 2132988, Unit 1 250 V DC battery ground
- CR 2129416, 3 of 11 Unit 2 Cycle 22 SRV lift pressures found outside TS The inspectors evaluated the following attributes of the licensees actions:
- complete and accurate identification of the problem in a timely manner
- evaluation and disposition of operability and reportability issues
- consideration of extent of condition, generic implications, common cause, and previous occurrences
- classification and prioritization of the problem
- identification of root and contributing causes of the problem
- identification of any additional condition reports
- completion of corrective actions in a timely manner Documents reviewed are listed in the attachment.
b. Findings
A licensee-identified violation is documented in Section 4OA7.
4OA3 Follow-up of Events
a. Inspection Scope
(Closed) Licensee Event Report (LER) 05000324/2017-003-00, Setpoint Drift in Main Steam Line Safety/Relief Valves Results in Three Valves Inoperable On June 5, 2017, the licensee received the results of testing of 11 main steam line safety relief valves (SRVs) removed from Unit 2 during the spring RFO. Three of the 11 valves were found to have as-found lift setpoints of their pilot valves outside the
+/- 3 percent tolerance required by TS 3.4.3. Although the SRV setpoint limits required by the TS were exceeded, the plant condition (three valves out of tolerance) was bounded by the Brunswick Unit 2 Cycle 22 Reload Safety Analysis, which demonstrated that the SRVs could have performed their safety function of limiting reactor vessel overpressure.
Specifically, the analysis concluded that with at least five total SRVs operable, the overpressure safety function would not be challenged. TS 3.4.3 requires 10 of the 11 installed SRVs to be operable. Since less than 10 SRVs were operable, this event was reported by the licensee in accordance with 10 CFR 50.73(a)(2)(i)(B) for operation prohibited by the plants TS. The SRV pilot valves were replaced with certified spares before the startup of Unit 2. The licensee revised a procedure to reduce corrosion bonding by improving surface preparation of SRV pilot valve discs.
b. Findings
The enforcement action associated with this LER is documented in Section 4OA7. No additional findings were identified during the review of this LER. This LER is closed.
4OA6 Meetings, Including Exit
On October 25, 2017, the inspectors presented the inspection results to Mr. Gideon and other members of the licensee staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
4OA7 Licensee Identified Violation
The following finding of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as a NCV.
1. 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states in part that activities affecting quality shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, from August 2015 until April 2017, Unit 2 SRV pilot valves did not incorporate precision grinding to remove micro-cracking layer as described in licensee procedure OCM-VSR509, Main Steam Relief Valves Target Rock Model 7567 Air Operators and Pilot Assembly, Disassembly, Inspection, and Reassembly. This resulted in 3 of the 11 SRVs being out of tolerance. Since less than 10 SRVs were operable, Unit 2 operation was prohibited by TS 3.4.3. The licensee took corrective action to replace all of the pilot valves with the correct surface finish. This violation was determined to be of very low safety significance (Green) because the violation did not represent a loss of safety function since this condition was supported by the Brunswick Unit 2 Cycle 22 Reload Safety
Analysis.
Specifically, the analysis concluded that with at least five total SRVs operable, the overpressure safety function would not be challenged. The licensee entered this issue into their CAP as CR 2129416.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- K. Allen Director, Design Engineering
B. Bagwell Environmental & Chemistry
- A. Baker Supervisor, Environmental & Chemistry
- J. Berry Supervisor, LOCT Training
- P. Brown Manager, Nuclear Performance Improvement
- B. Bryant Manager, Nuclear Oversight
J. Bryant Regulatory Affairs
R. Carpenter Radiation Monitor Engineer
- P. Dubrouillet Director, Nuclear Engineering, Mechanical Systems
- C. Dunsmore Manager, Nuclear Outage
W. Gideon Vice President
- L. Grzeck Manager, Nuclear Regulatory Affairs
- J. Hicks Manager, Nuclear Training
- B. Houston Manager, Nuclear Maintenance
- J. Johnson Manager, Nuclear Chemistry
- K. Krueger Manager, Nuclear Operations
- J. McAdoo Manager, Nuclear Rad Protection
- M. McPherson Director, Nuclear Organizational Effectiveness
K. Moser Plant Manager
B. Murray Licensing
- J. Nolin General Manager, Nuclear Engineering
- W. Orlando Superintendent, E/I&C
O. Paladiy Welding Engineer/Repair & Replacement Engineer
- A. Padleckas Assistant Ops Manager, Training
- D. Petrusic Superintendent, Environmental & Chemistry
- J. Pierce Manager, Nuclear Work Management
E. Rau Operations Training
- M. Regan Project Manager, Major Projects
L. Rohrbaugh Operator Training
- M. Smiley Manager, Nuclear Ops Training
L. Spencer Operator Training
- S. West Director, Nuclear Plant Security
- R. Wiemann Director, Nuclear Engineering, Electrical Reactor Systems
E. Williams Operations Manager
S. Williams BWRVIP Program Engineer
C. Winslow ISI Program Engineer
State of North Carolina
P. Cox Department of Health and Human Services
NRC Personnel
- S. Rose Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
- 05000324/2017-003-00 LER Setpoint Drift in Main Steam Line Safety/Relief Valves Results in Three Valves Inoperable (Section 4OA3)