IR 05000324/2020001
| ML20133K026 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/12/2020 |
| From: | Stewart Bailey NRC/RGN-II/DRP/RPB4 |
| To: | Krakuszeski J Duke Energy Progress |
| References | |
| IR 2020001 | |
| Download: ML20133K026 (26) | |
Text
May 12, 2020
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2020001 AND 05000325/2020001
Dear Mr. Krakuszeski:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On April 30, 2020, 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.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. 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 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 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects
Docket Nos. 05000324 and 05000325 License Nos. DPR-62 and DPR-71
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000324 and 05000325
License Numbers:
Report Numbers:
05000324/2020001 and 05000325/2020001
Enterprise Identifier: I-2020-001-0035
Licensee:
Duke Energy Progress, LLC
Facility:
Brunswick Steam Electric Plant
Location:
Southport, NC
Inspection Dates:
January 01, 2020 to March 31, 2020
Inspectors:
G. Smith, Senior Resident Inspector
J. Steward, Resident Inspector
B. Collins, Senior Reactor Inspector
J. Diaz-Velez, Senior Health Physicist
W. Pursley, Health Physicist
Approved By:
Stewart N. Bailey, Chief
Reactor Projects Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Brunswick Steam Electric Plant, 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 https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Comply with Radiation Work Permit Requirements Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000325,05000324/2020001-01 Open/Closed
[H.8] -
Procedure Adherence 71124.01 A self-revealing, Green, Non-Cited Violation of Brunswick Nuclear Plant Technical Specification 5.4.1.a was identified when two workers entered a posted high radiation (HRA)on a radiation work permit (RWP) that did not authorize HRA entry.
Failure to Correct Non-Cited Violations for MOVs in EQ service Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000325,05000324/2020001-02 Open/Closed
[H.6] - Design Margins 71152 The NRC identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion XVI for the licensees failure to correct NCV 05000324, 325/2018011-02. Specifically, the licensee failed to identify the actual temperatures in Limitorque motor operated valves (MOVs) that was caused by space heaters (wire wound power resistors)installed in the limit switch compartment (LSC) and correct the degradation to environmentally qualified (EQ) components.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000324,05000325/20 19004-01 Limitorque MOV space heater impact on qualified life 71152 Closed
PLANT STATUS
Unit 1 began the inspection period at 100 percent rated thermal power (RTP) and essentially operated there until February 29, 2020, when the unit was shut down for a refueling outage. Noted exceptions included January 3, February 1, and February 15 where the unit was down-powered to approximately 70 percent RTP for three separate control rod improvements. In each case, the unit was restored to 100 percent RTP the following day. Additionally, on January 17, power was reduced to 70 percent RTP for turbine valve testing and power was subsequently restored to 100 percent RTP the following day. Following completion of the refueling outage, the reactor was taken critical on March 22 at 0922. However at 1255, the reactor was manually scrammed from approximately two percent RTP due to an unexpected opening of all four steam bypass valves. Following investigation and resolution of the steam bypass valves opening, the reactor was taken critical at 0730 the following day on March 23. However, at approximately 1205 on March 24, a reactor shutdown was commenced from approximately 22 percent RTP due to high drywell leakage in excess of technical specifications (TS). Subsequent investigation revealed the source of the leak to be a safety relief valve (SRV) in conjunction with leakage past its associated vacuum breaker directly into the drywell atmosphere. Following replacement of the leaking SRV, as well as rebuilding of its associated vacuum breaker, the reactor was taken critical again on March 27 at 0426. Power escalation was commenced following the main generator output breaker closure on March 28 at 0046, and the unit ended the period at approximately 96 percent RTP.
Unit 2 operated at essentially 100 percent RTP for the entire inspection period with the exception of February 23 and February 25 where the unit was down-powered to approximately 70 percent RTP for two control rod improvements. Additionally, on March 25, the unit was down-powered to approximately 60 percent RTP for main turbine control valve no. 1 repairs. In all three cases, power was restored to 100 percent the following day.
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 performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week during which they conducted plant status activities as described in IMC 2515, Appendix D, and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to reschedule the inspectionto a later date.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Emergency diesel generator (EDG)-4 while EDG-3 was out-of-service (OOS) for annual preventative maintenance on February 05, 2020
- (2) Conventional service water (CSW) and nuclear service water (NSW) while the 2A NSW and 1C CSW pumps were OOS for bay cleaning on February 11, 2020.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1 reactor building (RB) 50 elevation, West Central Zone, 1PFP-RB1-01H(WC)on January 24, 2020
- (2) Unit 1 Drywell on March 20, 2020
- (3) Control Building 49' elevation (main control room) on March 30, 2020
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Partial)
(1)
(Partial)
The inspectors evaluated the onsite fire brigade training and performance during a Unit 1 'A' standby gas treatment (SBGT) fan charcoal bed fire drill on January 24, 2020.
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
The inspectors evaluated boiling water reactor non-destructive testing by reviewing the following examinations from March 2 - 6, 2020:
(1)03.01.a - Nondestructive Examination and Welding Activities.
1. Ultrasonic Examination (UT)
a. 28" recirculation system pipe-to-branch weld (1B32RECIRC-28-B-10),
ASME Class 1 (observed)b. 28" recirculation system pipe-to-elbow weld (1B32RECIRC-28-B-7),
ASME Class 1 (observed)c. 4 reactor pressure vessel head meridional welds (1B11-RPV-AA through -AD), ASME Class 1 (observed)
2. Magnetic Particle Testing (MT)
a. reactor pressure vessel head-to-flange weld (1B11-RPV-C), ASME Class 1 (observed)
3. Liquid Penetrant Examination (PT)
a. 6" service water system piping repair weld (191888), ASME Class 3, WO20356248-07 (weld sample; reviewed)
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during Unit 1 downpower to 92 percent and implementation of final feedwater temperature reduction in accordance with 0GP-13, increasing unit capacity at end of core cycle on February 20, 2020. Additionally, on March 22, 23, and 27, the inspectors observed and evaluated licensed operator performance in the Control Room during three separate Unit 1 reactor start-ups.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated Cycle 1 licensed operator requalification classroom on February 20, 2020
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
On March 31, 2020, the inspectors completed an evaluation of the effectiveness of maintenance to ensure the following structures, systems, and components(SSCs) remain capable of performing their intended function:
- (1) Loss of control power failure on EDG-3 that originally occurred on September 16, 2018.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;
- (1) Emergent failure of the Unit 1 'A' recirculating pump variable frequency drive programmable logic controller on January 9, 2020
- (2) Emergent failure of 1-B21-XY-5949B channel A2-3 (RCIC ambient steam leak delta-temperature detector) failed downscale on February 13, 2020
- (3) Emergent failure of electro-hydraulic control pressure switch on CV-1 on March 24, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Nuclear Condition Report (NCR) 2308428: Unit 1 reactor core isolation cooling (RCIC) trip push button on the reactor turbine generator board failed on January 9, 2020.
- (2) NCR 2313927: 2-SW-V685 bolting material discrepancy on February 20, 2020
- (3) NCR 2318610: Unit 1 pipe stress calculation SA-SW-766/767 discrepancy on March 30, 2020
- (4) NCR 2321800: Unit 2 EHC-PSL-1756 failed control valve pressure switch caused a half scram on March 31, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post maintenance test (PMT) activities to verify system operability and functionality:
===20373566 on January 15, 2020 (2)2B NSW pump PMT per 2PT-24.1-2, service water pump and discharge valve operability test on January 15, 2020 (3)2D circulating water intake pump PMT following replacement of a grounded lube oil pump motor per WO 20381938 on February 05, 2020 (4)0PT-12.4D, EDG-4 Fuel Oil Test following 2-FOD-V55 check valve rebuild of the 4B fuel oil transfer pump on February 18, 2020 (5)1-CAC-V49 and 1-CAC-V50, drywell head purge exchange valve PMT per WO 20347580 on March 18, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01)===
- (1) The inspectors evaluated the Brunswick Unit 1 refueling outage (B1R23) activities from February 28 to March 28, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
(1)0PT-12.2D, EDG-4 monthly load test on January 16, 2020 (2)1PT-15.1.1A, Unit 1 standby gas treatment '1A' heater operability test on March 3, 2020 (3)0PT-12.2C, EDG-3 monthly load test on February 28, 2020 (4)0PT-80.5, Unit 1 mid cycle maintenance outage reactor pressure vessel test (hydro) on March 30, 2020
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
(1)
'D' Main Steam Isolation Valve (MSIV) local leak rate testing performed on March 6, 2020.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Emergency preparedness drill on February 19,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identified the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated radiological protection-related instructions to plant workers.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) Observed contamination controls around the Unit 1 spent fuel pool (SFP) during fuel movement.
- (2) Observed surveys of potentially contaminated materials and tools at main RCA release point and discussed instrument sensitivity with RP technician performing the surveys.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) Attended pre-job brief for workers performing shielding installation on feedwater nozzles in the Unit 1 Drywell on RWP 1513.
- (2) Observed workers in the Unit 1 Drywell on RWP 1503 decoupling the control rod drives. This work required respiratory protection in the form personal air purifying respirators.
- (3) Attended pre-job brief and observed NDE work in drywell under RWP - 1574, Complex NDE Activities. Work was high risk due to contamination levels and dose rates.
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Observed locked high radiation area (LHRA) controls for the Unit 1 Drywell during the refueling outage.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation
Radioactive Material Storage (IP Section 02.01)
The inspectors evaluated radioactive material storage.
- (1) The inspectors toured the following areas:
- Low Level Shipping Warehouse
- Resin Processing (Blue Building)
- Radioactive Waste Processing
- Radioactive Waste Control Room
- Radioactive Waste Loading Dock
The inspectors performed container checks (e.g., swelling, leakage and deformation)on multiple containers while walking down areas listed above.
Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)
The inspectors evaluated the following radioactive waste processing systems and processes during plant walkdowns:
- (1) Liquid or Solid Radioactive Waste Processing Systems
- U1/U2 Condensate Phase Separators
- Floor Drain Sample Tanks
- Waste Collector Tank Radioactive Waste Resin and/or Sludge Discharges Processes
- Spent Resin Tank
- Waste Sludge Tank
Waste Characterization and Classification (IP Section 02.03) (1 Sample)
The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:
- Dry Active Waste
- Bead Resin
- Condensate Filter Demineralizer
Shipment Preparation (IP Section 02.04) (1 Sample)
The inspectors evaluated the following radioactive material shipment preparation processes:
- Shipment #20-038
- Receipt of Shipment #R20-041
Shipping Records (IP Section 02.05) (1 Sample)
The inspectors evaluated the following non-excepted package shipment records:
- 20-038
- 19-029
- 19-137
- 19-142
- 18-148
- 18.149
- 18-161
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 (January 01, 2019 - December 31, 2019)
- (2) Unit 2 (January 01, 2019 - December 31, 2019)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 1 (January 01, 2019 - December 31, 2019)
- (2) Unit 2 (January 01, 2019 - December 31, 2019)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
- (1) Unit 1 (January 01, 2019 - December 31, 2019)
- (2) Unit 2 (January 01, 2019 - December 31, 2019)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) 04/01/2019 - 12/31/2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
On March 31, the inspectors completed a review of the licensees implementation of its corrective action program related to the following issue:
71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated the Unit 1 manual reactor scram and the licensees response on March 22, 2020. The reactor was manually scrammed from 2 percent RTP due to an apparent spurious opening of all four main turbine bypass valves. The event (event notification54597) was reported to the NRC pursuant to 10 CFR 50.72(b)(2)(iv)(B) due to the reactor protection system manual actuation.
- (2) The inspectors evaluated a forced Unit 1 reactor shutdown due to high drywell floor drain leakage and licensees response on March 24, 2020. The reactor was shut down from approximately 22 percent RTP due to measured drywell floor drain leakage in excess TS Action 3.4.4.A. The event (EN 54603) was reported to the NRC pursuant to 10 CFR 50.72(b)(2)(i) due to a plant shutdown required by TS as well as 10 CFR 50.72(b)(3)(iv)(A) for a valid system actuation (Low Level I) following the manual scram.
INSPECTION RESULTS
Failure to Comply with Radiation Work Permit Requirements Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety
Green NCV 05000325,05000324/2020001-01 Open/Closed
[H.8] -
Procedure Adherence 71124.01 A self-revealing, Green, Non-Cited Violation of Brunswick Nuclear Plant Technical Specification 5.4.1.a was identified when two workers entered a posted high radiation area (HRA) on a radiation work permit (RWP) that did not authorize HRA entry.
Description:
On March 1, 2020, two contract insulators were assigned a task to remove insulation from a main steam line drain valve located in the unit 1 main steam isolation valve (MSIV) pit. During the work order briefing the workers supervisor reviewed the work order which directed use of RWP 1531, Task 6 for this evolution. The work order also stated, Contact RP prior to work start for requirements. RWP 1531, Task 6 stated "RP Briefing Prior to Starting Work and Intermittent RP Coverage Required, and included a hold point that states RP survey required prior to installing, modifying, or removing insulation. The workers signed on to RWP 1531, Task 6 without contacting radiation protection (RP) and went to the MSIV pit entry point which was a posted HRA and was barricaded with a swing gate. RWP 1531, Task 6 did not authorize entry into an HRA, and Brunswick TS 5.7.1.e, HRA, requires workers be knowledgeable of dose rates in an HRA before entry. The workers entered the area and removed highly contaminated insulation from the piping per the work order instructions without being informed of the dose rates in the MSIV pit and without other critical radiological information to perform the task.
RP surveys of the area confirmed dose rates in the MSIV pit were 130 milliroentgen per hour (mr/hr) at thirty centimeters and contamination levels were as high as 500,000 disintegrations per minute per 100 square centimeters. One of the workers alarmed the personnel contamination monitor while exiting the radiological controlled area. The licensee determined the individual received a measurable internal dose from airborne radioactivity that was created when the highly contaminated insulation was removed.
Corrective Actions: The licensee took immediate corrective action including restricting RCA access for the individuals involved and performing confirmatory surveys of the area. In addition, the licensee established an event investigation team to perform a causal analysis and determine if additional actions are necessary.
Corrective Action References: AR 02318788
Performance Assessment:
Performance Deficiency: The workers failure to comply with instructions in the work order, RWP 1531, Task 6 and plant TS requirements for entry into an HRA was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The performance deficiency was determined to be more than minor because it was associated with the human performance attribute of the occupational radiation safety cornerstone objective to ensure adequate protection of worker health and safety from radioactive materials. The failure to comply with RWP requirements, work order instructions and radiological postings impacted the effectiveness of the radiation protection program such that the licensees ability to provide adequate protection to ensure unintended dose to workers was challenged.
Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The finding was of very low safety significance (Green) because it was not an ALARA planning issue, there was no overexposure nor potential for an overexposure, and the licensees ability to assess dose was not compromised.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. The workers' failure to follow the work order and RWP requirements rendered multiple barriers inherent in the RP program ineffective.
Enforcement:
Violation: A self-revealing, Green, Non-Cited Violation of Brunswick Nuclear Plant TS 5.4.1.a. TS 5.4.1. a requires, in part, that written procedures be established, implemented, and maintained for activities recommended in Regulatory Guide 1.33, Appendix A, dated November 1972. Regulatory Guide 1.33, Appendix A, section 7, recommends procedures for control of radioactivity (for limiting materials released to environment and limiting personnel exposure) including procedures restricting activities in HRAs, surveys and monitoring and RWPs. The licensee established BNP RWP 1531, RB/TB/BOP - Insulation Remove/Replace - Excluding Drywell - Low Risk (RA/CA) Task 6, for insulation removal/replacement activities. RWP 1531, Task 6 did not authorize entry into HRAs and required workers to obtain an RP briefing prior to removing insulation. In addition, Brunswick TS 5.7.1.e, requires, in part, that personnel making entries in HRAs be made knowledgeable of the dose rates in the area. Contrary to the above, on March 1st, 2020, the licensee failed to maintain requirements in RWP 1531 when two workers entered the RCA working under RWP 1531, task 6 without
- (1) obtaining an RP brief prior to removing insulation and (2)entered an HRA without knowledge of the dose rates in the area.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Correct Non-Cited Violations for MOVs in EQ service Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000325,05000324/2020001-02 Open/Closed
[H.6] - Design Margins 71152 The NRC identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion XVI for the licensees failure to correct NCV 05000324, 325/2018011-02. Specifically, the licensee failed to identify the actual temperatures in Limitorque motor operated valves (MOVs) that was caused by space heaters (wire wound power resistors)installed in the limit switch compartment (LSC) and correct the degradation to environmentally qualified (EQ) components.
Description:
The NRC reviewed the corrective actions for NCV 05000324, 325/2018011-02 (ADAMS Accession No. ML18176A352). The review was to verify that corrective actions commensurate with the significance of the NCV were identified and implemented by the licensee. The NCV was written because the licensee failed to account for high temperatures in LSCs causing unmonitored and unplanned thermal aging degradation. High wattage space heaters, designed to be used for less than one year, were installed inside the LSCs of Limitorque MOVs near sensitive EQ components for twenty-two years. The NCV pointed out that the temperatures were higher than were being accounted for in qualified life calculations. The NCV also pointed out that these high temperatures were discernable by reviewing information in a Nuclear Utility Group for EQ (NUGEQ) letter and operating experience of burnt wires documented in Information notice (IN) 86-71, Recent Identified Problems with Limitorque Motor Operators. The licensee was aware that wire insulation burns above 347°F.
The licensee did not accept the validity of the information in the NCV and maintained that they could not obtain the heater specifications to determine the actual temperature for analyses, and that their temperature was established by their Appendix B Vendor. The licensee responded, in lieu of a separate analysis to determine actual heat rise, and in absence of any design inputs currently available in our records management system to perform a separate analysis, Brunswick used the heat rise value from the NUGEQ Clarification Letter, approved by Limitorque, as design input from our Appendix B supplier and applied this heat rise to all components within the LSC. Thus, the licensee increased their heat rise value by 3.6°F for uncertainty without any supporting data regarding the actual expected temperature. There was no documentation from Limitorque that validated the temperatures being used by the licensee.
While performing a technical review of the space heaters and their possible effects, the inspectors determined the following: The space heaters were actually power resistors that had no temperature controls. Each power resistor was a 25-watt Ward Leonard-Ohmite design. According to the Ward Leonard-Ohmite documentation, a single power resistor mounted in an open air 104 °F ambient environment (i.e. not enclosed in a box) and powered by 120Vac it would be expected to have a surface temperature of at least 502°F. This temperature is higher than what was identified in the NCV. Many MOVs had multiple power resistors that would multiply the power dissipation up to 50-watts. In a representative sample MOV observed by the inspectors at the licensee facilities, an SMB-0 Limitorque actuator had dual 25-watt resistors mounted adjacent to the phenolic part of the limit switch mechanism. The inspectors determined the aging of components in the LSCs would be affected by the heat flux radiating from these resistors. The inspectors determined that the resistors would produce more MOV degradation than what was being accounted for by the licensee. The licensee did not perform corrective actions for the NCV adequate to identify the aging affects prior to a loss of the MOVs intended safety function. As a result of this technical review a new violation was proposed.
The licensee wanted to independently verify the assertions made by the inspectors technical review; the licensee proposed a test to measure resistor temperatures. The inspectors issued an unresolved item URI 05000324, 325/2019004-01 (ADAMS Accession No.
ML20042E097) until the results of the test were made available. Reviewing the test report, the inspectors noted it did not bound all configurations of LSCs. The report did validate the inspectors calculations that the licensee had made non-conservative assumptions regarding the environment surrounding the electrical components within the valves. The temperatures measured in the tested configuration were significant enough to show that many of the LSC components are currently beyond their qualified lives. In addition, the testing did result in some burnt wires in the LSC as found in IN 86-71.
Corrective Actions: The licensee wrote a new corrective action report because of the test results, NCR 02318490, Mathematical Model for MOV Qualified Life is Nonconservative.
The licensee stated that compartment components should be considered operable but degraded to 10 CFR 50.49(e) until all significant types of aging degradation that can affect the components functional capability are fully assessed through corrective action.
Corrective Action References: NCR 2214514, NCR 2274126, NCR 02318490
Performance Assessment:
Performance Deficiency: The failure to address the degrading effects on thermal degradation that was identified in NCV 05000324, 325/2018011-02 on Limitorque MOVs was a performance deficiency (PD).
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform corrective actions adequate to identify aging effects that could degrade the performance of MOVs prior to being called upon to perform a safety function, and the failure to address the adequacy of the EQ program used to identify such aging issues affected the reliability and capability of systems that respond to initiating events.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the qualification of a mitigating structure, system, and component (SSC), and the SSC maintained its operability.
Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment. Specifically, the licensee failed to maintain MOVs within EQ design margins and failed to guard the qualified life of the MOV components. The licensee failed to place special attention to defense in depth and safety related equipment.
Enforcement:
Violation: Title 10 CFR 50, Appendix B, Criterion XVI, requires, in part, that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, since 2018, the licensee failed to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, the licensee failed to identify and correct degradation from space heaters that reach more than 500°F inside limit switch compartments of Limitorque motor operated valves after they received non-cited violation (NCV) 05000324, 325/2018011-02.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
The disposition of this finding and associated violation closes URI:
05000324,05000325/2019004-01.
Unresolved Item (Closed)
Limitorque MOV space heater impact on qualified life URI 05000324,05000325/2019004-01 71152
Description:
The NRC opened an unresolved item (URI) following a review of the corrective actions for non-cited violation (NCV) 05000324, 325/2018011-02 (ADAMS Accession No.
ML18176A352). The NCV was specifically for not considering potential degradation from space heaters inside the limit switch compartments (LSC) for Limitorque motor operated valves (MOV). The Appendix B supplier, Limitorque, offered these space heaters (resistors)as an optional accessory for short term storage in damp locations, limited to less than one year, per the user instructions in licensee files (FP-20243). However, the licensee used the heaters in service for 22 years until 1997 when they were turned off. The resistors did not perform any safety function, were not safety related, and were not part of the MOV qualification. As a corrective action in the licensees evaluation, the heat rise value in various Qualification Data Packages (QDPs) was raised to 12 °C from 10 °C. The licensee stated, in part, this value is from our Appendix B supplier, adjusted 20% higher to account for uncertainty. The current licensee position stated, In lieu of a separate analysis to determine actual heat rise, and in absence of any design inputs currently available in our records management system to perform a separate analysis, the licensee used the heat rise value from the NUGEQ Clarification Letter, approved by Limitorque, as design input from our Appendix B supplier and applied this heat rise to all components within the LSC. However, the nuclear utility group for environmental qualification (NUGEQ) supplied the 10 °C and was not an Appendix B supplier. No testing or analysis was provided to substantiate the NUGEQ temperature. The heater surface temperatures specified by the heater manufacturer (Ward-Leonard/Ohmite) indicated they could reach as high as 300°C when operated at full power in open air. The manufacturer specified that the heater temperatures were certified by the Underwriters Laboratories (UL) which used testing as a verification method. The degrading temperatures effects of the heaters on other components were not verified during Limitorque qualification testing. The original performance deficiency specified, that "the failure to address the degrading effects of space heaters in Limitorque MOVs was a performance deficiency (PD)". Testing or analytical methods for determining the degrading effects of the space heaters would account for the verified manufacturer temperatures (UL verified temperatures) in conjunction with installation configurations, which further affect the temperatures (applied power, ambient temperature rise, enclosure temperature rise, and resistor grouping temperature rise). The installed configurations included 25 watt single resistors and parallel resistors in the 40 to 50 watt range that are inside small unventilated enclosures. The failure to determine the degrading effects of the heaters in their installed configurations by test or analysis in accordance with IEEE 323-1974, Section 6, "Qualification Procedures and Methods," was a performance deficiency.
As described in the prior violation, Information notice (IN) 86-71, Recent Identified Problems with Limitorque Motor Operators, was issued to notify licensees of high temperature damage to MOVs caused by these resistors. The warning and other information was available at the time the licensee evaluated the effect on qualified life of the MOVs in around 1997. The licensee did not correct the prior violation (NCV 05000325/2018011,05000324/2018011-02)in that they neither identified potential degraded conditions inside the LSCs of the MOVs nor adequately evaluated the impact on the environmentally qualified life of the components.
Corrective Action Reference(s): CR 2214514
Observation: NCR 2236839 71152 This issue was chosen as it dealt with a potential failure mode that could render an EDG OOS due to a hard ground in the safety-related DC bus. The issue came to light following Hurricane Florence in September 2018. Following receipt of a hard ground on the Unit 2 DC bus, the operator noted the "governor at set-point" light on EDG-3 was not lit. Troubleshooting revealed that relay 2-DG3-27GP was de-energized which rendered EDG-3 OOS. A follow-on investigation concluded there was a design deficiency in the EDG governor control circuit in that a hard ground in the DC bus could result in an excessive voltage to be applied to the metal oxide varistor (MOV) located in the control circuit. Ultimately, the licensee implemented a modification to replace all the MOVs in all four EDGs which would be less susceptible to this phenomenon. As of the end of 2019, all MOVs were replaced under Engineering Change (EC) 279468. There were no findings of significance identified during this review. The inspectors determined that the causal analysis was thorough and that immediate and long-term corrective actions appeared to be adequate.
The inspectors reviewed these actions and verified that they addressed the cause and were actually being implemented. 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
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 30, 2020, the inspectors presented the integrated inspection results to John Krakuszeski, Site Vice President and other members of the licensee staff.
- On March 5, 2020, the inspectors presented the inservice inspection results to John Krakuszeski, Site Vice President and other members of the licensee staff.
- On March 5, 2020, the inspectors presented the radiation protection inspection results to Karl Moser, Plant General Manager and other members of the licensee staff.
THIRD PARTY REVIEWS
In accordance with the Office of the Executive Director for Operations (OEDO) Procedure 0220, "Coordination with the Institute of Nuclear Power Operations," inspectors reviewed the Institute on Nuclear Power Operations Plant Evaluation Report dated February 2019. The report identified no safety significant issues that required independent NRC follow up.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
D-02266, Sheet
2B
Starting Air for Diesel Generators Piping Diagram
D-02266, Sheet
2D
Starting Air for Diesel Generators Membrane Dehydrator
Detail Diesel Generator No. 4
D-02266, Sheet
2E
Starting Air for Diesel Generators 3 and 4 Piping Diagram
D-02271, Sheet
2B
Piping Diagram Diesel Generator Lube Oil System
Procedures
Diesel Generator Operating Procedure
2
Service Water System Operating Procedure
137
Service Water System Operating Procedure
168
Service Water System
SD-43
Service Water System
Fire Plans
General Fire Plan
AD-EG-ALL-1532
NFPA 805 Pre-Fire Plans
CSD-BNP-PFP-
0CB
Control Building Pre-Fire Plans
Procedures
Fire Drill Program
0PLP-01.2
Fire Protection System Operability, Action, and Surveillance
Requirements
AD-EG-ALL-1520
Transient Combustible Control
71111.08G Calibration
Records
Ray-Check Mfg. Inc. Certificate of Compliance: Angle Beam
Test Block (SNs 16-4061, 16-4108 through -4121)
10/26/16
GE Inspection Technologies Phased Array Probe
Specification/Certificate of Conformance (115-000-292)
August 16,
2019
689277
Standards Laboratory Instrument Certification:
Thermometer, Infrared - SN 31420250WS
7/2/2019
Drawings
16-453-4
FlawTech PDI Alternative ASME Calibration Block, 304
Stainless Steel (Block # PDI-UT-2A-H)
Rev. 0
PDIUT2M1
FlawTech PDI Alternative ASME Calibration Block, 316
Stainless Steel (Block # PDI-UT-2-M1)
Rev. 1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Magnaflux Certification: 8A Red Powder, Batch 18D007
04/03/2018
Brunswick Nuclear Plant Parts Database Entry: 10.2 LB
Weight Bar (SN A288)
3/5/2020
Sonic Systems International, Inc. Certificate of Qualification:
MT II (Regan)
1/28/2020
Sonic Systems International, Inc. Vision Acuity Record
(Regan)
09/06/2019
Sonic Systems International, Inc. Certificate of Qualification:
MT II (Williams)
2/11/2019
Sonic Systems International, Inc. Vision Acuity Record
(Williams)
09/06/2019
Duke Energy Record of Welder Performance Qualification
Test (Thompson, GTSM0101-01)
07/12/2017
Duke Energy Record of Welder Performance Qualification
Test (Grice, GTSM0101-01)
07/25/1991
Day & Zimmerman Certification Record: MT LII (Gallagher)
1/12/2020
Day & Zimmerman Certification Record: PT LII (Gallagher)
1/12/2020
Day & Zimmerman Vision Acuity Record (Gallagher)
1/12/2020
Duke Energy Visual Acuity Record (Jensen)
6/12/2019
Duke Energy Certificate of Method Qualification: UT II-N
(Jensen)
2/20/2020
Duke Energy Visual Acuity Record (May)
1/28/2020
Duke Energy Certificate of Method Qualification: UT II-N
(Jensen)
09/12/2017
Sonic Systems International, Inc. Certificate of Qualification:
UT II-PDI (Setzer)
1/31/2020
Sonic Systems International, Inc. Vision Acuity Record
(Setzer)
2-25-2020
Magnaflux Certification: Ultragel II Couplant, Batch 19H060
8/21/2019
Magnaflux Certification: Ultragel II Couplant, Batch 16B022
2/05/2016
Procedure Qualification Record
11/10/93
GTSM0101-01
Weld Procedure Specification
Rev. 10
L-102E
Procedure Qualification Record
9-18-98
Procedure Qualification Record
9-25-75
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedure Qualification Record
7-9-75
L-146D
Procedure Qualification Record
06/11/97
NDE Reports
2162
Duke Energy Magnetic Particle Examination Report (1-SW-
5597)
2/27/2020
2972
Duke Energy Magnetic Particle Examination Report (1-SW-
5596)
03/17/2020
MT-20-003,,
dated
Magnetic Particle Examination Record (1B11-RPV-C)
3/3/2020
UT-20-008
UT Calibration/Examination Record (1B32RECIRC-28-B-7)
3/4/2020
UT-20-009
UT Calibration/Examination Record (1B32RECIRC-28-B-10)
3/4/2020
VEN-20-004
Ultrasonic Examination Record (1B11-RPV-AA)
3/3/2020
VEN-20-005
Ultrasonic Examination Record (1B11-RPV-AB)
3/3/2020
VEN-20-006
Ultrasonic Examination Record (1B11-RPV-AC)
3/3/2020
VEN-20-007
Ultrasonic Examination Record (1B11-RPV-AD)
3/3/2020
Procedures
NDE-NE-ALL-
3101
Magnetic Particle Examination
Rev. 002
NDE-NE-ALL-
4101
Liquid Penetrant Examination
Rev. 002
NDE-NE-ALL-
6102
Utilization of PDI-UT-2 Generic Procedure for the Ultrasonic
Examination of Austenitic Pipe Welds
Rev. 002
NDE-NE-ALL-
212
Utilization of PDI-UT-12 Procedure for Manual Phased Array
Ultrasonic Examination of Reactor Pressure Vessel Welds
Rev. 002
NDE-NE-ALL-
6403
Straight Beam Ultrasonic Examination
Rev. 000
71111.11Q Miscellaneous
B1R23 Outage Modifications, Shutdown Risk and SOER 90-
Licensed Operator Requalification Program presentation
2/06/2020
Technical Specifications 3.05, 3.9 and 3.10, and Water
Inventory Control
2/20/2020
Procedures
Approach to Criticality and Pressurization of the Reactor
21
Increasing Unit Capacity at End of Core Cycle
AD-OP-ALL-1000
Conduct of Operations
Miscellaneous
Database
Maintenance Rule Database
3/31/20
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Industry Guidelines for monitoring the effectiveness of
maintenance at Nuclear
Power Plants
4A
Procedures
AD-EG-ALL-1210
Corrective Action
Documents
2309241
Procedures
BNP Integrated Scheduling
Definition of Instrument Channels and Trip Systems for
Selected Instruments
Ad-OP-ALL-0201
Protected Equipment
AD-WC-ALL-
200
Online Work Management
AD-WC-ALL-
250
Work Implementation and Completion
AD-WC-ALL-
0410
Work Activity Integrated Risk Management
Work Orders
20162738
Corrective Action
Documents
2308428,
2313927,
2313927,
21800
Procedures
AD-OP-ALL-0105
Operability Determinations and Functionality Assessments
AD-PI-ALL-0100
Corrective Action Program
Work Orders
20162153,
20169508
Procedures
0PT-16.1.1
Containment Atmosphere Control System Valve Operability
2PT-24.1-2
Service Water Pump and Discharge Valve Operability Test
Work Orders
20373566,
1345807,
2643,
20381938,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
20347580
Procedures
Approach to Criticality and pressurization of the Reactor
20
Unit Startup and Synchronization
Increasing Turbine Load to Rated Power
28
Unit Shutdown
196
Cold Shutdown to Refueling (Head Unbolted)
Preparations for Core Alterations
Refueling to Cold Shutdown
Reactor Vessel Disassembly
Procedures
0PT-12.27
Flex Diesel Generator 1 and 2 Test Procedure
0PT-12.2C
No. 3 Diesel Generator Monthly Load Test
117
0PT-12.2D
NO.4 Diesel Generator Monthly Load Test
21
0PT-80.5
Mid Cycle Maintenance Outage Reactor Pressure Vessel
Pressure Test
1PT-15.1.1A
Standby Gas Treatment 1A Heater Operability Test
270-0089-
SPEC-001
Plan for Temperature Rise of Space Heaters in Limitorque
Valve Actuators
Work Orders
20372063,
20379045,
20379046,
20343411,
20389350
Miscellaneous
BNP-QD-20-01
Emergency Preparedness Drill guide for Q1 2020
Emergency Drill
2/19/2020
Procedures
AD-EP-ALL-0002
NRC Regulatory Assessment Performance Indicator
Guideline Emergency Preparedness Cornerstone
Corrective Action
Documents
CR 02318587
CR 02318788
03/02/2020
Procedures
AD-RP-ALL-0002
RADIATION AND CONTAMINATION SURVEYS
REVISION 2
AD-RP-ALL-0005
ACCESS CONTROLS FOR HIGH AND LOCKED HIGH
RADIATION AREAS
REVISION 1
AD-RP-ALL-2000
PREPARATION AND MANAGEMENT OF RADIATION
WORK PERMITS (RWP)
REVISION 4
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-RP-ALL-3002
UNCONDITIONAL RELEASE OF MATERIAL
REVISION 1
PD-RP-ALL-0001
Radiation Worker Responsibilities
Current
Revision
Radiation
Surveys
BNP-M-
2019090719-003
Quarterly ISFSI Survey
09/07/2019
BNP-M-
20191215-003
Quarterly ISFSI Survey
2/15/2019
BNP-M-
200229-26
SMIV Pit 20- & 30-foot elevations - Initial Entry
2/29/2020
BNP-M-
200301-33
1R42_1RB MISV Verifying Conditions and Downpost HRA
03/01/2020
Radiation Work
Permits (RWPs)
1503 Task 1
CRD Activities-Including Support Act.(LHRA/HCA)
01/29/2020
RWP - 1500
High Radiological Risk Activities during B1R23 - DW Entry
Including Minor Repairs - HIGH RISK - VHRA/HCA
01/29/2020
RWP 1509 Task
Outboard MSIV ACTIVITIES System Breach - MEDIUM
RISK - (LHRA/HCA)
01/29/2020
RWP-1532
RB/TB/BOP - Insulation Remove/Replace - Excluding
Drywell - Low Risk (RA/CA)
Self-Assessments QRPT 2248333-
BNP ALARA Self-Assessment
09/09/2019
Work Orders
248820 04
1-MS-F038A Remove/Install Insulation
03/01/2020
Corrective Action
Documents
Resulting from
Inspection
Incoming EMPTY package without UN2908 markings
Miscellaneous
ES-OWM-QA-
2019-002
Certificate of Conformance for EnergySolutions Transport
Cask Package (8-120B-6)
February 13,
2019
Shipping Records Shipping
Packages 20-
038,19-029, 19-
137,19-142, 18-
148, 18.149, and
Shipping Packages
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
18-161
71151
Procedures
AD-PI-ALL-0700
Performance Indicators
Corrective Action
Documents
NCR 2231056
2-DG3-27GP: Relay is de-energized and should not be
09/17/2018
NCR 2230971
DG3 Governor Control Light at Setpoint and Light is Out
09/16/2018
NCR 2236839
Design Deficiency Discovered in EDG Governor Control
Circuit
10/11/2018
Procedures
AD-PI-ALL 0100
Corrective Action Program
SD-39
Miscellaneous
Event Reporting Guidelines
Procedures
Unit Shutdown
198
Reactor Scram
17