Text

NRC Integrated Inspection Report 05000325/2018001 and 05000324/2018001
	ML18122A331
Person / Time
Site:	Brunswick
Issue date:	05/02/2018
From:	Steven Rose; NRC/RGN-II/DRP/RPB4
To:	William Gideon; Duke Energy Progress
References
	IR 2018001
	Download: ML18122A331 (22)
	v • d • e

May 2, 2018

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT 05000325/2018001 AND 05000324/2018001

Dear Mr. Gideon:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Steam Electric Plant, Units 1 and 2. On April 19, 2018, 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.

NRC inspectors documented one self-revealing finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. 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.

If you disagree with a 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; 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 05000325/2018001 and 05000324/2018001

Inspection Report

Docket Numbers:

50-325, 50-324

License Numbers:

DPR-71, DPR-62

Report Numbers:

05000325/2018001, 05000324/2018001

Enterprise Identifier: I-2018-001-0053

Licensee:

Duke Energy Progress, LLC

Facility:

Brunswick Steam Electric Plant, Units 1 & 2

Location:

Southport, NC

Inspection Dates:

January 1, 2018 to March 31, 2018

Inspectors:

G. Smith, Senior Resident Inspector

J. Steward, Resident Inspector

M. Schwieg, Reactor Inspector

W. Loo, Senior Health Physicist

J. Panfel, Health Physicist

B. Collins, Reactor Inspector

S. Freeman, Senior Reactor Analyst

Approved By:

S. Rose, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Enclosure

SUMMARY

The NRC continued monitoring licensees performance by conducting a quarterly integrated inspection at Brunswick Steam Electric Plant Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/index.html for more information. Any NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

Inadequate Instruction to Perform Inspections on Emergency Ventilation Dampers Cornerstone Significance Cross-cutting Aspect Report Section Barrier Integrity Green NCV 05000324/2018001-01 05000325/2018001-01 Closed H.5 - Work Management 71153 A self-revealing Green NCV of TS 5.4.1a, Procedures, was identified when the licensee failed to properly provide adequate work instructions associated with the control room emergency damper inspections. Specifically, the licensee disconnected the damper air supply line without adequate work instruction guidance, which caused a loss of Control Building Heating,

Ventilation and Air Conditioning (HVAC) and Control Room Emergency Ventilation (CREV)

Systems resulting in a safety system functional failure.

Additional Tracking Items

Type Issue number Title Report Section Status LER 05000325/2017-003-00 Unplanned Inoperability of CREV and Control Building HVAC 71153 Closed

PLANT STATUS

Unit 1 began the inspection period at 100 percent rated thermal power and operated there until January 28, 2018, when operators began a coast down into a refueling outage. On March 3, 2018, Unit 1 was shut down from 85 percent and remained shut down in a refueling outage for the remainder of the period.

Unit 2 began the period at 100 percent rated thermal power and operated there until February 16, 2018, when the unit was taken off-line for a forced outage due to a hot spot on the main turbine generator disconnect link (A phase). Following repairs, the unit was returned to 100 percent rated thermal power on February 20, 2018, and essentially operated at this level for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for winter storm Grayson on January 8, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2 Standby Liquid Control System following maintenance on January 11, 2018

(2) Unit 2 B and C Conventional Service Water (CSW) while 2 A CSW pump was out-of-service (OOS) for planned maintenance on February 17, 2018

(3) Emergency Diesel Generator (EDG)-1 while EDG-2 was OOS for installation of an automatic voltage regulator on February 28, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the control rod drive system between February 12 and March 23, 2018.

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas between February 8 and March 23, 2018:

(1) Unit 2 reactor building 20 elevation

(2) Unit 1 drywell

(3) Unit 1 turbine building 20 elevation

(4) Unit 1 turbine building 45 elevation

(5) Unit 1 turbine building 70 elevation

Annual Inspection (1 Sample)

The inspectors evaluated the fire brigade performance during a fire drill on February 8, 2018.

71111.08 - Inservice Inspection Activities

Main article: IP 71111.08

The inspectors evaluated boiling water reactor non-destructive testing by observing/reviewing the following examinations from February 5 to February 9, 2018:

(1) Ultrasonic Examination a) 10 core spray system nozzle inner radius (1-B11-RPV-N5A-IRS), ASME Class 1 (observed)b) Reactor pressure vessel Ring 1 longitudinal seam weld @ 255° (1B11-RPV-E4B),

ASME Class 1 (observed)c) 12 feedwater system nozzle extension-to-safe end weld (1B21N4A-2-SW1-2),

ASME Class 1 (observed)

(2) Liquid Penetrant Examination a) WO 20191808-1, 20 service water system reducer-to-flange weld (1-SW-911),

ASME Class 3 (reviewed; associated with welding package, which was also reviewed)

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated Cycle 1 of operator retraining on March 2, 2018.

Operator Performance (2 Samples)

The inspectors observed and evaluated:

(1) Unit 1 Final Feed water Temperature Reduction on January 18, 2018

(2) Unit 2 EDG-4 Monthly Load Test on January 18, 2018

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 2 high pressure coolant injection (HPCI) valve packing failure on March 9, 2018

Quality Control (QC) (1 Sample)

The inspectors evaluated the below quality control activities between March 8 and March 22, 2018:

(1) QC inspection of Unit 1 reactor coolant system (RCS) level indicator LI-R610 installation

(2) QC torqueing inspection of U-clamp on the Unit 1 D residual heat removal service water system booster pump

(3) QC cleanliness inspection of backup nitrogen check valves1-RNA-V-305 and -307

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) EDG-3/2A nuclear service water (SW) pump/supplemental EDG outage, on January 9, 2018

(2) EDG-2 outage automatic voltage regulator modification, on March 2, 2018

(3) Yellow plant status control risk as a result of electrical power on March 8, 2018, due to U1 unit auxiliary transformer outage

(4) Emergent failure of the 1B1 battery during following a test discharge failure, on March 16, 2018

71111.15 - Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) CR 2174081 - ISFSI HSM-001 prompt determination of operability for concrete spalling noted behind roof vent, on January 8, 2018

(2) CR 2178808 - complex programmable logic device (CPLD) relays installed in EDGs, on February 7, 2018

(3) CR 2175636 - Shells found in EDG-3 Jacket water heat exchanger, on February 12, 2018

(4) CR 2172700 - HPCI steam valve packing leak, on March 23, 2018

71111.19 - Post Maintenance Testing

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) WO 20019415, 2A Conventional SW pump conduit rerouting, on March 2, 2018

(2) WO 20040133, 2-SW-V-685, check valve removal and inspection, on March 2, 2018

(3) WO 20062954, EDG-2 post maintenance test (PMT) from automatic voltage regulator (AVR) modification, on March 9, 2018

(4) WO 20040132, 1-SW-V-685, check valve exam, on March 23, 2018

(5) Control Rm In-leakage Test, Final Report via Vendor, on March 29, 2018

71111.20 - Refueling and Other Outage Activities

Main article: IP 71111.20

The inspectors evaluated refueling outage B1R-22 activities from March 2, 2018, to March 31, 2018.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine

Main article: IP 71111.22

(1) 0PT-12.2D Rev.118, EDG-4 Monthly Load Test, on January 26, 2018

(2) WO 20180054, Functional Test of Service Water Building Sump Pump, on February 28, 2018

(3) 0PT-46.6 Rev 6, Control Room In leakage Tracer Gas Test, on February 16, 2018

(4) 0PT-12.1A, Rev. 5, No. 1 Diesel Generator LOOP/LOCA Loading Test, on March 23, 2018

Containment Isolation Valve (1 Sample)

(1) 0PT-20.3A.5 Rev. 13, MSIV Leak Test, 1-B21-F028B, post maintenance LLRT per WO 20238741, on March 21,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation

Radioactive Material Storage

Main article: IP 71124.08

The inspectors evaluated the licensees radioactive material storage.

Radioactive Waste System Walk-down (1 Sample)

The inspectors evaluated the licensees radioactive waste processing facility during plant walkdowns.

Waste Characterization and Classification (1 Sample)

The inspectors evaluated the licensees radioactive waste characterization and classification.

Shipment Preparations (1 Sample)

The inspectors evaluated the licensees radioactive material shipment preparation processes.

Shipment Records (1 Sample)

The inspectors evaluated the licensees non-excepted package shipment records.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified on March 16, 2018, the licensees performance indicators submittals listed below for the period from January 1, 2017 through December 31, 2017.===

Main article: IP 71151

(1) Unit 1 and Unit 2 Unplanned Scrams per 7000 Critical Hours

(2) Unit 1 and Unit 2 Unplanned Power Changes per 7000 Critical Hours

(3) Unit 1 and Unit 2 Unplanned Scrams with Complications

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:

(1) CR 2097378 - Tracer gas test failure on main control room on March 23, 2018

71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

Main article: IP 71153

The inspectors evaluated the following licensee event report which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000325/2017-003-00, Unplanned Inoperability of CREV and Control Building HVAC, on March 30,

INSPECTION RESULTS

Inadequate Instruction to Perform Inspections on Emergency Ventilation Dampers Cornerstone Significance Cross-cutting Aspect Report Section Barrier Integrity

Green NCV 05000324/2018001-01 05000325/2018001-01 Closed H.5 - Work Management 71153

Introduction:

A self-revealing Green NCV of TS 5.4.1a, Procedures, was identified when the licensee failed to properly preplan and perform work instructions associated with the control room emergency ventilation (CREV) damper inspections. Specifically, the licensee disconnected the damper airline without work instruction guidance, which caused a loss of control building heating, ventilation and air conditioning (HVAC) and CREV systems, resulting in a safety system functional failure.

Description:

The first event occurred at 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months on June 5, 2017. The licensee was performing a work order (WO) 20036198-02 task to inspect 2-VA-2J-D-CB, Emergency Recirculation Damper. During the task, but without WO guidance, the licensee disconnected a damper actuator instrument airline to cycle the 2J damper to the open position. Afterwards, it was determined that disconnecting the damper actuator instrument airline had caused the Emergency Recirculation Damper 2J to become non-functional rendering both divisions of the CREV system inoperable. The CREV system was restored to operable status by 1009 hours0.0117 days 0.28 hours 0.00167 weeks 3.839245e-4 months .

The second event occurred at 1352 hours0.0156 days 0.376 hours 0.00224 weeks 5.14436e-4 months on June 5, 2017. The licensee was performing a WO 20036198-04 task to inspect 2-VA-2A-EAD-CB, Control Room Emergency Supply Fan A Inlet Isolation Damper. During the task, but without WO guidance, the licensee disconnected a damper actuator instrument airline to cycle the 2A damper to the open position. When the damper actuator airline was disconnected, the control building instrument air system pressure decrease resulted in subsequent loss of the control building HVAC and CREV systems. This event was self-revealing with the trip of both running control building HVAC units (1D-CU-CB and 2D-CU-CB control building air conditioning and Supply Fans). The technical specifications for this condition requires both units to be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The affected systems were restored by 1407 hours0.0163 days 0.391 hours 0.00233 weeks 5.353635e-4 months .

In both events, the CREV system dampers were temporarily disabled by the loss of their pneumatic supply. With the CREV dampers unable to respond as required, the CREV system was inoperable and its safety function was lost. The CREV safety function is to minimize infiltration of contaminated air by removing radioactive particles, smoke and toxic gases from the control room envelope. The combined duration of inoperability was 54 minutes. The control building HVAC system was inoperable only during the second event.

The duration of inoperability was 15 minutes. There was no adverse impact on temperature or humidity in the control building during this event.

The licensee performed a root cause evaluation and determined the work order instructions did not contain precautions or limitations about operating dampers and the maintenance leadership has failed to effectively enforce work control standards to align workers and their behaviors to achieve successful maintenance execution.

Additionally, in August of 2015, Brunswick transitioned from PassPort to Consolidated Asset Suite. When this change happened, the instructions for all of the damper seal inspection tasks were revised, removing critical aspects that the damper seal should be inspected in the damper-closed position.

Inspectors determined from August 2015 until June 2017, the work order instruction was not maintained or properly planned when the instruction was revised to remove the damper inspection while in the closed position.

Corrective Actions: Corrective actions included restoring the affected pneumatic air supply, revising work order instructions to prevent damper operation, and improvements in crew performance standards.

Corrective Action Reference: NCR 2129139

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to properly preplan and establish adequate work instructions for the emergency damper inspections was a performance deficiency.

Screening: The performance deficiency was more than minor because it was associated with Procedural Quality attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The CREV safety function is to minimize infiltration of contaminated air by removing radioactive particles was lost from the control room envelope.

Significance: The finding was screened in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power dated June 19, 2012.

The finding was screened by Exhibit 3 - Barrier Integrity Screening Questions, under Section C - Control Room, Auxiliary, Reactor, or Spent Fuel Pool Building. Since the control room radiological barrier function and the barrier function against smoke or a toxic atmosphere were inoperable, a detailed risk evaluation was required. A regional senior reactor analyst (SRA) conducted the risk assessment using SAPHIRE software Version 8.1.6 and the Standardized Plant Analysis Risk (SPAR) Models, Version 8.50, for each of Units 1 and 2. Because the control room ventilation systems were not specifically modeled in SPAR, the SRA used human error probability (HEP) as a surrogate for the degraded condition. Also, given that no human errors were actually made and control room temperature remained less than 70 degrees Fahrenheit, the SRA increased each HEP by a factor of 10 for the degraded condition. The exposure time was one hour. The dominant sequences, which accounted for approximately 50 percent of the change, included loss of conventional service water with operator failure to initiate suppression pool cooling, fire water injection, or control low pressure coolant injection at low pressures, and loss of condenser heat sink with operator failure to depressurize the reactor or vent containment. The result was a change in core damage frequency of less than 1E-7/year for each unit and was primarily mitigated by the short exposure time. Because the change was less than 1E-7/year, no further analysis was needed for external events or large early release, and this finding was determined to be of very low safety significance (Green).

Cross-cutting Aspect: The finding had a cross-cutting aspect in the Work Management component of the Human Performance cross-cutting area (H.5), which required the organization to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, the licensee failed to plan, control, and execute the CREV work activities, which resulted in a loss of the CREV and control room HVAC systems.

Enforcement:

Violation: Technical Specification 5.4.1a, Procedures, states that written procedures shall be established, implemented, and maintained covering the following activities: a) the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972 (Safety Guide 33, November 1972). Regulatory Guide 1.33, Appendix A, November 1972 (Safety Guide 33, November 1972),Section I, states in part that maintenance which can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstance. WO 20036198 was a documented instruction for safety-related ventilation system dampers.

Contrary to the above, from August 2015 until June 2017, the licensee failed to properly preplan and maintain adequate work instructions for the damper inspections on the CREV and control room HVAC systems. As a result, the CREV and control room HVAC systems became inoperable and could not perform their safety function.

Disposition: This violation is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On April 19, 2018, the inspectors presented the inspection results to R. Gideon, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Common Documents Reviewed

Updated Final Safety Analysis Report

Individual Plant Examination

Individual Plant Examination of External Events

Technical Specifications and Bases

Technical Requirements Manual

Control Room Narrative Logs

Plan of the Day

71111.01 - Adverse Weather Protection

Procedures

0OI-01.03, Non-Routine Activities, Rev 70

0AP-062, Seasonal Preparations, Rev. 6

71111.04 - Equipment Alignment

Procedures

0OP-39, Diesel Generator Operating Procedure, Rev. 190

2OP-43, Service Water System Operating Procedure, Rev. 166

2OP-05, Standby Liquid Control System, Rev. 69

SD-05, Standby Liquid Control System, Rev.11

1OP-08, Control Rod Drive Hydraulic System Operating Procedure, Rev. 100

2OP-08, Control Rod Drive Hydraulic System Operating Procedure, Rev. 106

DBD-08, Control Rod Drive System, Rev. 9

SD-08, CRD Hydraulic System, Rev 13

Drawings

D-02547, Rev. 34

71111.05AQ - Fire Protection Annual/Quarterly

Procedures

0FPP-060 Fire Drill Program, Rev. 2

99-F-RB-03, Fire Drill Scenario Guide, Rev. 2

0PFP-013, General Fire Plan, Rev. 52

CSD-BNP-PFP-1RB, Unit 2 Reactor Building Pre-fire Plans Rev. 1

CSD-BNP-PFP-2RB, Unit 2 Reactor Building Pre-fire Plans Rev. 0

CSD-BNP-PFP-1TB, Turbine Building Pre-fire Plans, Rev. 3

71111.08 - Inservice Inspection Activities

Work Orders

20181808-011-SW-142-30-157: Repair Conventional and Vital Headers Drain Pipe, 3/13/18

Procedures

NDE-NE-ALL-6213, Utilization of PDI-UT-13 Procedure for Manual Phased Array Ultrasonic

Examination of Reactor Pressure Vessel Nozzle to Shell Welds and Nozzle Inner Radius

Regions Rev. 001

ISwT-PDI-AUT5 IHI Southwest Technologies, Inc. Operating Procedure: Automated Inside

Surface Ultrasonic Examination of Pressure Vessel Welds Using Phased Array Rev. 2

ISwT-NDE2 IHI Southwest Technologies, Inc. Operating Procedure: Ultrasonic Linearity

Measurements Rev. 0

54-ISI-869-000 AREVA Inc. Nondestructive Examination Procedure: Procedure for Encoded

Phased Array Ultrasonic Examination of Dissimilar Metal Piping Welds Rev. 000

AD-NE-ALL-1103 Calibration and Control of NDE Examination Equipment Rev. 0

Corrective Action

2194822 NCR: WO 20191808-01 Material Issued not in accordance with Spec 248-117,

3/28/18

2190611 AR: Nozzle N4A Weld 1B21N4A-2-SW1-2 Flaw Identified, 3/12/18

Other

VEN-18-003 Ultrasonic Examination Record (N5A Inner Radius), 3/13/18

Z3668 Zetec Calibration Certificate: TOPAZ 32/128PR (SN 665462), 1/16/17

Z3987 Zetec Calibration Certificate: DYNARAY-128/128PR, 1/29/18

N1051823 Weldstar Certificate of Compliance/Conformance, 9/19/14

N845297 Weldstar Certificate of Compliance, 10/12/09

Carolina Power & Light Company Procedure Qualification Record, 8/26/76

Carolina Power & Light Company Procedure Qualification Record, 10/20/80

243 Carolina Power & Light Company Procedure Qualification Record, 4/5/94

53320 AREVA Certificate of Calibration: Digital Thermometer (SN 160067), 2/9/18

51-9280231-000 AREVA Inc. Engineering Information Record: Automated Dissimilar Metal

Weld Examination Phased Array Technique Sheets for Brunswick Unit 1 B122 Spring 2018

Rev. 0

1-B11-0968 IHI Southwest Technologies Examination Summary Record (Ring 1 Longitudinal

Weld @ 255°), 3/20/18

1-FW-115-VIP Framatome Automated Ultrasonic Phased Array Examination Summary Sheet

(1B21N4A-2-SW1-2), 3/12/18

WPS 08 2 30 Carolina Power & Light Company Welding Procedure Specification Rev. 1

MAGNAFLUX Certificate of Certification: Ultragel II (Batch 14M076), 12/19/14

Duke Energy Certificate of Method Qualification: UT LII-N (May), 9/12/17

Duke Energy Visual Acuity Record (May), 9/6/17

Standards Laboratory Instrument Certification: IR Thermometer (ID G503098), 6/5/17

Day & Zimmerman Vision Acuity Record (Masey), 3/12/18

Day & Zimmerman Certification Record: PT LII (Masey), 5/4/16

Duke Energy Record of Welder Performance Qualification Test (Edwards), 8/30/17

Duke Energy Record of Welder Performance Qualification Test (Maloney), 2/24/16

MAGNAFLUX Certification: Spotcheck, SKC-S (Batch 16G17K), 7/29/16

MAGNAFLUX Certification: Spotcheck, SKL-SP2 (Batch 17B04K), 2/8/17

MAGNAFLUX Certification: Spotcheck, SKD-S2 (Batch 16L16K), 2/5/16

Review and Acceptance of Vendor Personnel and Examinations: UT LIII (Delgado), 3/3/18

Framatome Indication Notification Report: N4A Safe End to Pipe DM Weld

(1B21N4A-2-SW1-2), 3/12/18

Framatome Certificate of Personnel Qualification: UT LIII (Breza), 3/26/18

71111.11 - Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

0GP-13, Increasing Unit Capacity at End of Core Cycle, Rev. 48

Lesson Plans

OPS-EDG-DLA, Manual Transfer of Emergency Bus Supply from EDG to Normal Feeder,

Rev. 0

Other

LOR Exam 18-1 Version A Rev. 0

LOR Exam 18-1 Version B Rev. 0

71111.12 - Maintenance Effectiveness

Procedures

AD-EG-ALL-1210, Maintenance Rule Program, Rev. 1

Condition Reports

CR 2172700, Unit 2 HPCI Team Supply Packing Failure

Work Orders (WO)

WO12227572

WO20104840

WO12100401

WO12100402

Miscellaneous

NUMARC 93-01, Industry Guidelines for monitoring the effectiveness of maintenance at Nuclear

Power Plants, Rev. 4A

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Procedures

AD-OP-ALL-0201, Protected Equipment, Rev. 04

0AP-022, BNP Outage Risk Management, Rev. 56

AD-WC-ALL-0250, Work Implementation and Completion, Rev. 04

AD-WC-ALL-0410, Work Activity Integrated Risk Management, Rev. 03

AD-WC-ALL-0200, Online Work Management, Rev. 08

AD-OP-ALL-0201, Protected Equipment, Rev. 04

AD-WC-ALL-0430, Outage Risk Review, Rev. 02

0AP-025, BNP Integrated Scheduling, Rev. 56

71111.15 - Operability Determinations and Functionality Assessments

Procedures

NUHOMS Amend 10, Technical Specifications, Transnuclear, Inc., Storage System, Rev. 1

0ISFS-100, Horizontal Storage Module Assembly, Rev. 2

FP-86004, Transnuclear Dry Fuel Storage System, Rev. A

AD-OP-ALL-0105, Operability Determinations and Functionality Assessments, Rev. 4

AD-OP-ALL-0100, Corrective Action Program, Rev. 11

Condition Reports

CR 02174081, Inspection of ISFSI HSM and Prompt Operability Determination

CR 02178808, CPLD relays installed in EDGs

CR 2175636, Shells found in EDG-3 Jacket water HX

CR 2172700, HPCI steam valve packing leak

Drawings

F-08602, sheet 8, ISFSI Project Horizontal Storage Module Layout Details

71111.19 - Post Maintenance Testing

Procedures

0PLP-20, Post-Maintenance Testing Program, Rev. 49

Work Orders

WO 20019415, 2A Conventional SW pump conduit rerouting

WO 20040133, 2-SW-V-685, Check valve removal and inspection

WO 20062954, EDG-2 PMT from AVR modification

WO 20040132 1-SW-V-685 Check valve exam

Miscellaneous

Control Room In-leakage Test - Final Report from Vendor on January 18, 2018

71111.20 - Refueling and Other Outage Activities

Procedures

0FH-11, Fuel Handling, Rev. 107

0ENP-24.12, Preparation of Core Component Sequence Sheets, Rev. 50

0GP-05, Unit Shutdown, Rev 185

0GP-08, Refueling to Cold Shutdown, Rev 51

0GP-07, Preparations for Core Alterations, Rev 63

0GP-01, Pre-startup Checklist, Rev 197

0GP-02, Approach to Criticality and Pressurization of the Reactor, Rev 114

0GP-03, Unit Startup and Synchronization, Rev 88

0GP-04, Increasing Turbine Load to Rated Power, Rev 121

Clearance

25660

71111.22 - Surveillance Testing

Procedures

0PT-12.2D, NO.4 Diesel Generator Monthly Load Test, Rev. 118

0PT-46-6, Control Room Inleakage Tracer Gas Test, Rev. 6

0OI-2.3, Drywell Leakage Control, Rev.7

0PT-12.1B, No. 2 Diesel Generator LOOP/LOCA Loading Test, Rev. 5

AD-OP-ALL-1000, Conduct of Operations, Attachment 1, Adverse Condition Monitoring and

Contingency Planning Form for Unit 2 elevated drywell floor drain leakage, Rev. 9

IMC 2515 Appendix D, Plant Status, Attachment 1, Assessing RCS Unidentified Leakage Rate

Trend, effective January 1, 2018

0PT-20.3A.5, MSIV Leak Test, sec 7.3.3; Rev. 13

0ENP-16.4, Use of Leak Detection Equipment, Rev. 23

Condition Reports

2190194

Work Orders

2097378

20180054

Drawings

D-25021 sheet 1B, Rx Bldg Nuc Stm Supply Piping Diagram, Rev. 55

Miscellaneous

Lagus Applied Technology, Inc ltr dtd Feb 12, 2018, addressing preliminary tracer gas test

results from testing performed 2/7 - 2/9/18

71124.01 - Radiological Hazard Assessment and Exposure Controls

Procedures, Guidance Documents and Manuals

0AI-112, Control of Materials In Spent Fuel Pool, Rev. No. 27

0E&RC-0040, Administrative Controls for High Radiation Areas, Locked High Radiation Areas,

and Very High Radiation Areas, Rev. 43

0E&RC-0101, Performance and Tracking of Routine Surveillances, Rev. 8

0E&RC-0112, Discrete Radioactive Particle Control, Rev. 6

0E&RC-0115, Use and Calibration of the Small Article Monitors, Rev. 21

0E&RC-0117, Control of Work in the Hot Machine Shop, Rev. 5

0E&RC-0118, Decontamination for Areas, Materials, and Tools, Rev. 19

0E&RC-0229, Control and Use HEPA Air Filtration Units, Rev. 11

0E&RC-0241, Health Physics Coverage in Drywells During Fuel and Irradiated Component

Movement, Rev. 19

0E&RC-0261, Drywell Entry, Rev. 29

0E&RC-0500, Inventory Control and Leak Testing of Radioactive Sources, Rev. 27

0E&RC-0598, Control of Radwaste Containers in Interim Storage, Rev. 5

AD-PI-ALL-0100, Corrective Action Program, Rev. 13

AD-RP-ALL-0002, Radiation and Contamination Surveys, Rev. 0

AD-RP-ALL-0003, Radiological Air Sampling, Rev. 0

AD-RP-ALL-0004, Radiological Posting and Labeling, Rev. 0

AD-RP-ALL-0005, Access Controls for High and Locked High Radiation Areas, Rev. 0

AD-RP-ALL-0006, Personnel Contamination Monitoring, Rev. 0

AD-RP-ALL-0007, Control of Radioactive Material, Rev. 0

AD-RP-ALL-0008, Use and Control of HEPA Filtration and Vacuum Equipment, Rev. 0

AD-RP-ALL-0010, Radiological Job Coverage, Rev. 0

AD-RP-ALL-0011, Radiological Protection Fundamentals, Rev. 0

AD-RP-ALL-1000, Conduct of Radiation Protection, Rev. 4

AD-RP-ALL-2000, Preparation and Management of Radiation Work Permits, Rev. 3

AD-RP-ALL-2003, Investigation of Unusual Radiological Occurrences, Rev. 3

AD-RP-ALL-2004, Management of Large Scale Contamination Events, Rev. 0

AD-RP-ALL-2007, Radiation Protection Outage Readiness, Rev. 1

AD-RP-ALL-2007, Remote Monitoring, Rev. 4

AD-RP-ALL-2011, Radiation Protection Briefings, Rev. 3

AD-RP-ALL-2014, Work in Alpha Environments, Rev. 6

AD-RP-ALL-2015, Alpha Radiation Characterization, Rev. 2

AD-RP-ALL-2020, Radiological Controls for Diving Operations, Rev. 2

AD-RP-ALL-3002, Unconditional Release of Material, Rev. 1

AD-RP-ALL-3003, Outside Radioactive Material Container Inventory and Control, Rev. 2

AD-RP-ALL-7004, Operation of Air Sampling Equipment, Rev. 3

Records and Data

Analysis Report for Sample IDs: 180457_2, HP Charcoal Air Sample U1 TB 70 I/S Tb Shell,

03/03/18; 180464_1, HP Charcoal Air Sample U/1 Turbine 70 Manway, 03/04/18;

180465_2, HP Charcoal Air Sample U1 Turbine 70 Manway, 03/04/18; and 180467_1, HP

Charcoal Air Sample U/1 70 TB, 03/04/18

3, Clean Material Survey - Container Contents, 0E&RC-0216, Control and

Monitoring of Nonradioactive Plant Waste and Scrap, Rev. 31, Survey No. 082917-005,

08/29/17

7, Radioactive Source Inventory Reports, 0E&RC-0500, Inventory Control and Leak

Testing of Radioactive Sources, Rev. 27, 08/04/17 and 02/05/18

BNP 10 CFR Part 61 Radioactive Waste Stream Sample Information, 02/08/18

Brunswick Nuclear Plant Radiological Survey, Survey Nos: BNP-M-20180303-2, Map 2,

DW01_DW-5.001, 03/03/18, and Map 3, DW02_DW-17.001, 03/03/18; BNP-M-20180303-

26, DW03_DW-38.001, 03/03/18; BNP-M-20180304-7, DW05_DW67.001, 03/04/18; BNP-

M-20180304-11, DW05_DW67.001, 03/04/18; BNP-M-20180304-17, U1 RB Torus Pre Dive

Survey, 03/04/18; BNP-M-20180305-7, DW05_DW-67.001, 03/05/18; BNP-M-20180306-1,

DW05_DW-67.001, 03/06/18; BNP-M-20180306-7, DW05_DW-67.001, 03/06/18, 05:03;

BNP-M-20180306-7, DW05_DW-67.001, 03/06/18, 21:03; BNP-M-20180306-9, DW05_DW-

67.001, 03/06/18; BNP-M-20180306-11, DW09_DW-17 SRMA Replace/Remove,

03/06/18; and BNP-M-20180307-3, DW05_DW-67.001, 03/07/18

Brunswick Nuclear Project, Radiological Survey Record, One Line Air Sample Survey Form,

Survey No. 030718-009, Sampler Nos. HD-11825 (U1 DW Equip Hatch) and PA-12925 (U1 DW

PH), 03/07/18

National Source Tracking System, Annual Inventory Reconciliation Report, 01/11/18

Radiation Work Permit (RWP) Number (No.) 1500, Misc - High Radiological Risk Activities

LHRA/HCA (High Risk Activities), Task No. 3, RB, Torus Diving (Divers Only) - High Risk -

HRA/CA

RWP No. 1500, Misc - High Radiological Risk Activities LHRA/HCA (High Risk Activities), Task

No. 11, DW - Nuclear Instrumentation Activities (SRM/IRM Remove/Replace) - IER 11-41

High Risk Activities (LHRA/HCA/ARA), Rev. 1

RWP No. 1530, Operations Activities, Task No. 1, DW - OPS Activities - Medium Risk -

LHRA/HCA, Rev. 3

RWP No. 1539, TB Turbine/Generator System - Inspection & Repairs - Crew, Task No. 1, TB

Turbine Generator System - Inspections and Repairs - Low Risk Activities (RA/CA), Rev. 2

RWP No. 1540, Circ Water Activities, Task No. 1, TB, Circ Water System - Inspections and

Repairs - Low Risk Activities (RA/CA), Rev. 1

RWP No. 1554, RB Emergent RWCU Piping Replacement, Task No. 1, RB - RWCU Piping

Replacement L86 and Support - Low Risk - (RA/CA), Rev. 2

RWP No. 1574, NDE Complex Inspections, Task No. 1, DW NDE Complex Inspection

Activities - Medium Risk in LHRA/CA, Rev. 1

Work Order Package (WOP) 20143242 01, 2-F16-MIS, Perform Quarterly U/2 Spent Fuel Pool

Inspection, 12/05/17, Procedure No. 0AI-112, Control of Materials In Spent Fuel Pool,

Rev. No. 27, 12/05/17

WOP 20157065 01, Perform the Unit 1 Spent Fuel Pool Inspection, 02/06/18, Procedure No.

0AI-112, Control of Materials In Spent Fuel Pool, Rev. No. 27, 02/06/18

Corrective Action Program (CAP) Documents

2111178

2114719

2147461

2189186

Quick-Hitter Self-Assessment Report, No. 02086194-05, RP Field Operations, Undated

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling,

Storage, and Transportation

Procedures, Guidance Documents and Manuals

AD-PI-ALL-0100, Corrective Action Program, Rev. 13

AD-RP-ALL-0007, Control of Radioactive Material, Rev. 0

AD-RP-ALL-3003, Outside Radioactive Material Container Inventory and Control, Rev. 2

AD-RP-ALL-5000, Preparation and Shipment of Radioactive Material, Rev. 1

AD-RP-ALL-5002, 10 CFR 61 Radioactive Waste Classification, Rev. 0

Carolina Power & Light Company, Brunswick Nuclear Plant, Process Control Program (PCP),

Rev. 5

HPS-NGGC-0002, Vendor Cask Utilization Procedure, Rev. 24

0OI-03.10, Transferring Spent Resins of Filter Media to the Radwaste Processing Area, Rev. 12

Shipping Records and Radwaste Data

2015 and 2016 Annual Radioactive Effluent Release Report, Brunswick Steam Electric Plant

BNP 10 CFR Part 61 Radioactive Waste Stream Sample Information, 02/08/2018

List of All Abandoned Solid and Liquid Radwaste Processing Equipment, 2018

Shipment No.16-139

Shipment No.16-154

Shipment No.17-145

Shipment No.17-151

Shipment No.17-158

Shipment No.17-216

Shipping Logbook, Jan 2016 - Feb 2018

RC6C003G, Radiation Control Technicians Lesson Plan - Radioactive Material Shipping and

Regulatory Awareness, 05/2016

CAP Documents

2016-BNP-RP-01, Nuclear Oversight - Audit of Brunswick Radiation Protection, 06/02/16

2016944

2019275

2027786

2032219

2032676

2033531

2035377

2041791

2042597

2042953

2043481

2045838

2099171

2103619

2136550

2147461

2190058

2033860

2090604

71151 - Performance Indicator Verification

Other

Operator narrative logs from 2017

71152 - Problem Identification and Resolution

Procedures

AD-HU-ALL-0001, Human Performance Program, Rev. 12

AD-PI-ALL-0100, Corrective Action Program, Rev. 18

AD-SY-ALL-0401, Fitness for Duty Program, Rev. 2

AD-SY-ALL-0460, Managing Fatigue and Work Hour Limits, Rev. 1

AD-SY-ALL-1000, Conduct of Security, Rev. 2

AD-SY-ALL-0520, Security Training, Rev. 3

AD-PI-ALL-0101, Root Cause Evaluation, Rev. 04

AD-PI-ALL-0102, Apparent Cause Evaluation, Rev. 04

AD-PI-ALL-0103, Quick Cause Evaluation, Rev. 04

AD-PI-ALL-0400, Operating Experience Program, Rev. 05

71153 - Follow-up of Events and Notices of Enforcement Discretion

Condition Report

2129139; Unplanned Inoperability of CREV and Control Building HVAC, Rev. 1

2185263; Unit 2 Phase A Main Generator No Load Disconnect indicating 282 degrees

Fahrenheit

Drawings

F-04080 Sheet1; Control Room Air Flow Diagram, Rev. 15

F-04080 Sheet1; Control Room Air Flow Diagram, Rev. 5

Miscellaneous

LER 2017-003-000; Control Room Air Conditioning and Emergency Ventilation Systems

Rendered Inoperable, Rev. 0

RCE 02129139; Unplanned Inoperability of CREV and Control Building HVAC, Rev. 1

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

May 2, 2018

William R. Gideon

Site Vice President

Brunswick Steam Electric Plant

8470 River Rd. SE (M/C BNP001)

Southport, NC 28461

SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION

REPORT 05000325/2018001 AND 05000324/2018001

Dear Mr. Gideon:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Brunswick Steam Electric Plant, Units 1 and 2. On April 19, 2018, 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.

NRC inspectors documented one self-revealing finding of very low safety significance (Green) in

this report. This finding involved a violation of NRC requirements. 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.

If you disagree with a 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

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the

NRC resident inspector at the Brunswick Steam Electric Plant.

W. Gideon

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 05000325/2018001 and

05000324/2018001

cc w/ encl: Distribution via ListServ

ML18122A331

OFFICE

RII:DRP

RII:DRS

RII:DRP

NAME

GSmith

JSteward

BCollins

JPanfel/Loo

WLoo

DJackson

DATE

4/30/2018

5/01/2018

4/30/2018

5/2/2018

4/30/18

5/2/2018

OFFICE

RII:DRP

NAME

MSchwieg

JDodson

SFreeman

SRose

DATE

5/1/2018

5/2/2018

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers:

50-325, 50-324

License Numbers:

DPR-71, DPR-62

Report Numbers:

05000325/2018001, 05000324/2018001

Enterprise Identifier: I-2018-001-0053

Licensee:

Duke Energy Progress, LLC

Facility:

Brunswick Steam Electric Plant, Units 1 & 2

Location:

Southport, NC

Inspection Dates:

January 1, 2018 to March 31, 2018

Inspectors:

G. Smith, Senior Resident Inspector

J. Steward, Resident Inspector

M. Schwieg, Reactor Inspector

W. Loo, Senior Health Physicist

J. Panfel, Health Physicist

B. Collins, Reactor Inspector

S. Freeman, Senior Reactor Analyst

Approved By:

S. Rose, Chief

Reactor Projects Branch 4

Division of Reactor Projects

SUMMARY

The NRC continued monitoring licensees performance by conducting a quarterly integrated

inspection at Brunswick Steam Electric Plant Units 1 and 2 in accordance with the Reactor

Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the

safe operation of commercial nuclear power reactors. Refer to

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/index.html for more information. Any NRC and

self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

Inadequate Instruction to Perform Inspections on Emergency Ventilation Dampers

Cornerstone

Significance

Cross-cutting

Aspect

Report

Section

Barrier Integrity

Green NCV 05000324/2018001-01

05000325/2018001-01

Closed

H.5 - Work

Management

71153

A self-revealing Green NCV of TS 5.4.1a, Procedures, was identified when the licensee failed

to properly provide adequate work instructions associated with the control room emergency

damper inspections. Specifically, the licensee disconnected the damper air supply line without

adequate work instruction guidance, which caused a loss of Control Building Heating,

Ventilation and Air Conditioning (HVAC) and Control Room Emergency Ventilation (CREV)

Systems resulting in a safety system functional failure.

Additional Tracking Items

Type

Issue number

Title

Report

Section

Status

LER 05000325/2017-003-00

Unplanned Inoperability of

CREV and Control Building

HVAC

71153

Closed

PLANT STATUS

Unit 1 began the inspection period at 100 percent rated thermal power and operated there until

January 28, 2018, when operators began a coast down into a refueling outage. On

March 3, 2018, Unit 1 was shut down from 85 percent and remained shut down in a refueling

outage for the remainder of the period.

Unit 2 began the period at 100 percent rated thermal power and operated there until

February 16, 2018, when the unit was taken off-line for a forced outage due to a hot spot on the

main turbine generator disconnect link (A phase). Following repairs, the unit was returned to

100 percent rated thermal power on February 20, 2018, and essentially operated at this level for

the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for winter

storm Grayson on January 8, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Unit 2 Standby Liquid Control System following maintenance on January 11, 2018

(2) Unit 2 B and C Conventional Service Water (CSW) while 2 A CSW pump was out-of-

service (OOS) for planned maintenance on February 17, 2018

(3) Emergency Diesel Generator (EDG)-1 while EDG-2 was OOS for installation of an

automatic voltage regulator on February 28, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the control

rod drive system between February 12 and March 23, 2018.

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas between February 8 and March 23, 2018:

(1) Unit 2 reactor building 20 elevation

(2) Unit 1 drywell

(3) Unit 1 turbine building 20 elevation

(4) Unit 1 turbine building 45 elevation

(5) Unit 1 turbine building 70 elevation

Annual Inspection (1 Sample)

The inspectors evaluated the fire brigade performance during a fire drill on

February 8, 2018.

71111.08 - Inservice Inspection Activities (1 Sample)

The inspectors evaluated boiling water reactor non-destructive testing by

observing/reviewing the following examinations from February 5 to February 9, 2018:

(1) Ultrasonic Examination

a) 10 core spray system nozzle inner radius (1-B11-RPV-N5A-IRS), ASME Class 1

(observed)

b) Reactor pressure vessel Ring 1 longitudinal seam weld @ 255° (1B11-RPV-E4B),

ASME Class 1 (observed)

c) 12 feedwater system nozzle extension-to-safe end weld (1B21N4A-2-SW1-2),

ASME Class 1 (observed)

(2) Liquid Penetrant Examination

a) WO 20191808-1, 20 service water system reducer-to-flange weld (1-SW-911),

ASME Class 3 (reviewed; associated with welding package, which was also

reviewed)

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated Cycle 1 of operator retraining on March 2, 2018.

Operator Performance (2 Samples)

The inspectors observed and evaluated:

(1) Unit 1 Final Feed water Temperature Reduction on January 18, 2018

(2) Unit 2 EDG-4 Monthly Load Test on January 18, 2018

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Unit 2 high pressure coolant injection (HPCI) valve packing failure on March 9, 2018

Quality Control (QC) (1 Sample)

The inspectors evaluated the below quality control activities between March 8 and

March 22, 2018:

(1) QC inspection of Unit 1 reactor coolant system (RCS) level indicator LI-R610 installation

(2) QC torqueing inspection of U-clamp on the Unit 1 D residual heat removal service water

system booster pump

(3) QC cleanliness inspection of backup nitrogen check valves1-RNA-V-305 and -307

71111.13 - Maintenance Risk Assessments and Emergent Work Control (4 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) EDG-3/2A nuclear service water (SW) pump/supplemental EDG outage, on

January 9, 2018

(2) EDG-2 outage automatic voltage regulator modification, on March 2, 2018

(3) Yellow plant status control risk as a result of electrical power on March 8, 2018, due to

U1 unit auxiliary transformer outage

(4) Emergent failure of the 1B1 battery during following a test discharge failure, on

March 16, 2018

71111.15 - Operability Determinations and Functionality Assessments (4 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) CR 2174081 - ISFSI HSM-001 prompt determination of operability for concrete spalling

noted behind roof vent, on January 8, 2018

(2) CR 2178808 - complex programmable logic device (CPLD) relays installed in EDGs, on

February 7, 2018

(3) CR 2175636 - Shells found in EDG-3 Jacket water heat exchanger, on February 12,

2018

(4) CR 2172700 - HPCI steam valve packing leak, on March 23, 2018

71111.19 - Post Maintenance Testing (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) WO 20019415, 2A Conventional SW pump conduit rerouting, on March 2, 2018

(2) WO 20040133, 2-SW-V-685, check valve removal and inspection, on March 2, 2018

(3) WO 20062954, EDG-2 post maintenance test (PMT) from automatic voltage regulator

(AVR) modification, on March 9, 2018

(4) WO 20040132, 1-SW-V-685, check valve exam, on March 23, 2018

(5) Control Rm In-leakage Test, Final Report via Vendor, on March 29, 2018

71111.20 - Refueling and Other Outage Activities (1 Sample)

The inspectors evaluated refueling outage B1R-22 activities from March 2, 2018, to

March 31, 2018.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (4 Samples)

(1) 0PT-12.2D Rev.118, EDG-4 Monthly Load Test, on January 26, 2018

(2) WO 20180054, Functional Test of Service Water Building Sump Pump, on

February 28, 2018

(3) 0PT-46.6 Rev 6, Control Room In leakage Tracer Gas Test, on February 16, 2018

(4) 0PT-12.1A, Rev. 5, No. 1 Diesel Generator LOOP/LOCA Loading Test, on

March 23, 2018

Containment Isolation Valve (1 Sample)

(1) 0PT-20.3A.5 Rev. 13, MSIV Leak Test, 1-B21-F028B, post maintenance LLRT per

WO 20238741, on March 21, 2018

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area

controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician

proficiency.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation

Radioactive Material Storage (1 Sample)

The inspectors evaluated the licensees radioactive material storage.

Radioactive Waste System Walk-down (1 Sample)

The inspectors evaluated the licensees radioactive waste processing facility during plant

walkdowns.

Waste Characterization and Classification (1 Sample)

The inspectors evaluated the licensees radioactive waste characterization and

classification.

Shipment Preparations (1 Sample)

The inspectors evaluated the licensees radioactive material shipment preparation

processes.

Shipment Records (1 Sample)

The inspectors evaluated the licensees non-excepted package shipment records.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified on March 16, 2018, the licensees performance indicators submittals

listed below for the period from January 1, 2017 through December 31, 2017. (6 Samples)

(1) Unit 1 and Unit 2 Unplanned Scrams per 7000 Critical Hours

(2) Unit 1 and Unit 2 Unplanned Power Changes per 7000 Critical Hours

(3) Unit 1 and Unit 2 Unplanned Scrams with Complications

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issue:

(1) CR 2097378 - Tracer gas test failure on main control room on March 23, 2018

71153 - Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (1 Sample)

The inspectors evaluated the following licensee event report which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000325/2017-003-00, Unplanned Inoperability of CREV

and Control Building HVAC, on March 30, 2018

INSPECTION RESULTS

Inadequate Instruction to Perform Inspections on Emergency Ventilation Dampers

Cornerstone

Significance

Cross-cutting

Aspect

Report

Section

Barrier Integrity

Green

NCV 05000324/2018001-01

05000325/2018001-01

Closed

H.5 - Work

Management

71153

Introduction: A self-revealing Green NCV of TS 5.4.1a, Procedures, was identified when the

licensee failed to properly preplan and perform work instructions associated with the control

room emergency ventilation (CREV) damper inspections. Specifically, the licensee

disconnected the damper airline without work instruction guidance, which caused a loss of

control building heating, ventilation and air conditioning (HVAC) and CREV systems, resulting

in a safety system functional failure.

Description: The first event occurred at 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months on June 5, 2017. The licensee was

performing a work order (WO) 20036198-02 task to inspect 2-VA-2J-D-CB, Emergency

Recirculation Damper. During the task, but without WO guidance, the licensee disconnected

a damper actuator instrument airline to cycle the 2J damper to the open position. Afterwards,

it was determined that disconnecting the damper actuator instrument airline had caused the

Emergency Recirculation Damper 2J to become non-functional rendering both divisions of the

CREV system inoperable. The CREV system was restored to operable status by 1009 hours0.0117 days 0.28 hours 0.00167 weeks 3.839245e-4 months .

The second event occurred at 1352 hours0.0156 days 0.376 hours 0.00224 weeks 5.14436e-4 months on June 5, 2017. The licensee was performing a

WO 20036198-04 task to inspect 2-VA-2A-EAD-CB, Control Room Emergency Supply Fan A

Inlet Isolation Damper. During the task, but without WO guidance, the licensee disconnected

a damper actuator instrument airline to cycle the 2A damper to the open position. When the

damper actuator airline was disconnected, the control building instrument air system pressure

decrease resulted in subsequent loss of the control building HVAC and CREV systems. This

event was self-revealing with the trip of both running control building HVAC units (1D-CU-CB

and 2D-CU-CB control building air conditioning and Supply Fans). The technical

specifications for this condition requires both units to be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The affected systems were restored by 1407 hours0.0163 days 0.391 hours 0.00233 weeks 5.353635e-4 months .

In both events, the CREV system dampers were temporarily disabled by the loss of their

pneumatic supply. With the CREV dampers unable to respond as required, the CREV

system was inoperable and its safety function was lost. The CREV safety function is to

minimize infiltration of contaminated air by removing radioactive particles, smoke and toxic

gases from the control room envelope. The combined duration of inoperability was

minutes. The control building HVAC system was inoperable only during the second event.

The duration of inoperability was 15 minutes. There was no adverse impact on temperature

or humidity in the control building during this event.

The licensee performed a root cause evaluation and determined the work order instructions

did not contain precautions or limitations about operating dampers and the maintenance

leadership has failed to effectively enforce work control standards to align workers and their

behaviors to achieve successful maintenance execution.

Additionally, in August of 2015, Brunswick transitioned from PassPort to Consolidated Asset

Suite. When this change happened, the instructions for all of the damper seal inspection

tasks were revised, removing critical aspects that the damper seal should be inspected in the

damper-closed position.

Inspectors determined from August 2015 until June 2017, the work order instruction was not

maintained or properly planned when the instruction was revised to remove the damper

inspection while in the closed position.

Corrective Actions: Corrective actions included restoring the affected pneumatic air supply,

revising work order instructions to prevent damper operation, and improvements in crew

performance standards.

Corrective Action Reference: NCR 2129139

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to properly

preplan and establish adequate work instructions for the emergency damper inspections was

a performance deficiency.

Screening: The performance deficiency was more than minor because it was associated with

Procedural Quality attribute of the Barrier Integrity cornerstone, and adversely affected the

cornerstone objective to provide reasonable assurance that physical design barriers protect

the public from radionuclide releases caused by accidents or events. The CREV safety

function is to minimize infiltration of contaminated air by removing radioactive particles was

lost from the control room envelope.

Significance: The finding was screened in accordance with IMC 0609, Appendix A, The

Significance Determination Process (SDP) For Findings At-Power dated June 19, 2012.

The finding was screened by Exhibit 3 - Barrier Integrity Screening Questions, under

Section C - Control Room, Auxiliary, Reactor, or Spent Fuel Pool Building. Since the

control room radiological barrier function and the barrier function against smoke or a toxic

atmosphere were inoperable, a detailed risk evaluation was required. A regional senior

reactor analyst (SRA) conducted the risk assessment using SAPHIRE software Version 8.1.6

and the Standardized Plant Analysis Risk (SPAR) Models, Version 8.50, for each of Units 1

and 2. Because the control room ventilation systems were not specifically modeled in SPAR,

the SRA used human error probability (HEP) as a surrogate for the degraded condition. Also,

given that no human errors were actually made and control room temperature remained less

than 70 degrees Fahrenheit, the SRA increased each HEP by a factor of 10 for the degraded

condition. The exposure time was one hour. The dominant sequences, which accounted for

approximately 50 percent of the change, included loss of conventional service water with

operator failure to initiate suppression pool cooling, fire water injection, or control low

pressure coolant injection at low pressures, and loss of condenser heat sink with operator

failure to depressurize the reactor or vent containment. The result was a change in core

damage frequency of less than 1E-7/year for each unit and was primarily mitigated by the

short exposure time. Because the change was less than 1E-7/year, no further analysis was

needed for external events or large early release, and this finding was determined to be of

very low safety significance (Green).

Cross-cutting Aspect: The finding had a cross-cutting aspect in the Work Management

component of the Human Performance cross-cutting area (H.5), which required the

organization to implement a process of planning, controlling, and executing work activities

such that nuclear safety was the overriding priority. Specifically, the licensee failed to plan,

control, and execute the CREV work activities, which resulted in a loss of the CREV and

control room HVAC systems.

Enforcement:

Violation: Technical Specification 5.4.1a, Procedures, states that written procedures shall be

established, implemented, and maintained covering the following activities: a) the applicable

procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972 (Safety

Guide 33, November 1972). Regulatory Guide 1.33, Appendix A, November 1972 (Safety

Guide 33, November 1972),Section I, states in part that maintenance which can affect the

performance of safety-related equipment should be properly preplanned and performed in

accordance with written procedures, documented instructions, or drawings appropriate to the

circumstance. WO 20036198 was a documented instruction for safety-related ventilation

system dampers.

Contrary to the above, from August 2015 until June 2017, the licensee failed to properly

preplan and maintain adequate work instructions for the damper inspections on the CREV

and control room HVAC systems. As a result, the CREV and control room HVAC systems

became inoperable and could not perform their safety function.

Disposition: This violation is being treated as a Non-Cited Violation, consistent with

Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public

disclosure.

On April 19, 2018, the inspectors presented the inspection results to

R. Gideon, Site Vice

President, and other members of the licensee staff.