IR 05000324/2021002
| ML21223A155 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/11/2021 |
| From: | Stewart Bailey Division Reactor Projects II |
| To: | Krakuszeski J Duke Energy Progress |
| T Francis | |
| References | |
| IR 2021002 | |
| Download: ML21223A155 (25) | |
Text
August 11, 2021
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2021002 AND 05000325/2021002
Dear Mr. Krakuszeski:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On July 29, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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:
05000324/2021002 and 05000325/2021002
Enterprise Identifier: I-2021-002-0008
Licensee:
Duke Energy Progress, LLC
Facility:
Brunswick Steam Electric Plant
Location:
Southport, NC
Inspection Dates:
April 1, 2021 to June 30, 2021
Inspectors:
G. Smith, Senior Resident Inspector
M. Schwieg, Reactor Inspector
J. Diaz-Velez, Senior Health Physicist
B. Kellner, Senior Health Physicist
J. Rivera, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000325/2020-002-00 LER 2020-002-00 for Brunswick Steam Electric Plant, Unit 1, Technical Specification Required Shutdown due to Unidentified Leakage 71153 Closed
PLANT STATUS
Unit 1 began the period at 100 percent (full) rated thermal power (RTP) and operated there until May 1, 2021, when the unit was shut down mid-cycle to replace a leaking seal package on the 'B' recirculation pump. Following replacement of the seal packages on both the 'A' and 'B' recirculation pumps, the unit was taken critical and the output breaker closed on May 12, 2021.
On May 13, 2021, a power ascension was commenced, and the unit reached full power on May 20, 2021. The unit continued to operate at essentially full power for the remainder of the inspection period.
Unit 2 began the period shut down for a refueling outage. Following completion of the refueling outage, the unit was taken critical on April 4, 2021. On April 5, 2021, the output breaker was closed, and a power ascension was commenced. The unit reached full power on April 9, 2021.
The unit continued to operate there until June 7, 2021, when power was reduced to 75 percent RTP for a control rod improvement. Following completion of the rod improvement, the unit was restored to full power on June 9, 2021, where it continued to operate until the end of the 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.
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 and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion 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 some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 high pressure coolant injection (HPCI) system on April 15, 2021
- (2) Unit 1 residual heat removal (RHR) torus suction system on April 21, 2021
- (3) Diesel generator building instrument air system on June 18, 2021
- (4) Unit 1 'B' train RHR while 'A' train was out-of-service for planned maintenance on June 23, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the safety-related Unit 1 and Unit 2 core spray (CS) systems completed on May 26, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Service water (SW) building elevation (EL) 4' on April 9, 2021
- (2) SW building EL 20' on April 9, 2021
- (3) Diesel generator fuel oil tank cells #1 thru #4 on May 27, 2021
- (4) Control building EL 49' (main control room) on June 1, 2021
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill in the service water building on April 19, 2021
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
On June 30, 2021, the inspectors completed an evaluation of the internal flooding mitigation protections in the:
- (1) SW building
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 initial pressurization of the reactor coolant system following a refueling outage on April 4, 2021
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator continuing training (loss of 2XDB bus, inadvertent core spray initiation, reactor water cleanup (RWCU) system rupture) on June 24, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 1 'B' recirculation pump seal degradation and subsequent replacement (Nuclear Condition Report (NCR) 2379462)
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Commercial grade dedication package associated with a Watt/Var transducer used in the safety-related emergency diesel generators (EDGs)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Unit 1 shutdown risk during maintenance outage to replace the 'B' recirculation pump seal package on May 7, 2021.
- (2) Emergent failure of TE 2-B21-TE-N013A results in half scram during testing on June 15, 2021
- (3) Emergent failure of the Unit 1 'B' control rod drive pump on June 17, 2021
- (4) Unit 1 A RHR Outage on June 23, 2021
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) Unit 1 Drywell Equipment Drain leakage in Action Level 1 (NCR 2379462)
- (2) Unit 2 'B' North Hotwell In-Leakage (NCR 2378093)
- (3) Unit 1 SC Torus Line Plate Inspection Results Exceed Acceptance Criteria (NCR 2374037)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Diesel fuel oil tank room aqueous film forming foam (AFFF) degradation (EC 419628)
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
(1)0PT-80.1, Reactor Pressure Vessel ASME Section XI Pressure Test (2)0PT-34.5.4.0, Foam Concentrate Performance Evaluation and Level Verification (3)0PM-RLY035, Function Test of E3-E1 Cross-tie Breaker Lockout Relay
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated the Unit 2 refueling outage (B2R25) from March 5, 2021 to April 5, 2021
- (2) The inspectors evaluated the Unit 1 forced outage to repair a failing recirculating pump seal from May 1 to May 12, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
(1)0PT-12.2C, No. 3 Diesel Generator Monthly Load Test on June 10, 2021
- (2) EDG-4 LOOP/LOCA Loading Test (RS) on June 16, 2021
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated an emergency drill conducted on April 20, 2021
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated a simulator training session that involved a RWCU system rupture on June 24,
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 identifies 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)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
- (1) The inspectors reviewed the following:
Radiation Work Packages
- RWP # 2503 - CRD Activities-Including Support Activities (locked high radiation area (LHRA)/HCA), Rev: 11
- RWP # 2523 - 117' FLOOD UP ACTIVITIES, Rev: 08
- RWP # 2526 - 117' - REASSEMBLY ACTIVITIES, Rev: 06
Electronic Alarming Dosimeter (ED) Alarms
- Reviewed ED dose and dose rate alarm logs from January 2020 through January 2021. No unplanned or unexpected alarms occurred.
Labeling of Containers
- Observed 15 radioactive material containers at various locations inside the protected area and radiologically controlled area (RCA) with appropriate Radioactive Material labeling
- Observed 6 in service HEPA units and vacuums appropriately labeled as Radioactive Material in the RCA
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) The inspectors verified the following sealed sources are accounted for and are intact:
- Category 2 Cs-137 source ID# 10R008 (Hopewell shielded box calibrator/irradiator)
- Category 2 Cs-137 source ID# 84R106 (Shepherd shielded box calibrator/irradiator)
- (2) Observed workers undressing, and monitoring after exiting the drywell and refueling cavity contaminated areas, including RP monitoring for discrete hot particles, as applicable
- (3) Observed licensee surveys of personnel and potentially contaminated material leaving the RCA
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- RWP # 2503, Control Rod Drive (CRD) Activities [removal, replacement, adjustments, etc.]
- (2) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- RWP # 2523, 117' Flood up Activities [Fuel Pool Gate Seal, In-vessel inspection, IER L2 19-6 Inspections, etc.]
- (3) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- (4) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas (VHRA):
- (1) Unit 1 and Unit 2 condenser bays (4 entry points each) LHRA
- (3) Unit 1 and Unit 2 drywell (2 entry points) VHRA
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
Through direct observation, interviews, or discussions with workers and RP technicians, the inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensees radiological work planning.
- (1) The inspectors reviewed the following activities:
- ALARA Plan 2503 - B2R25 Control Rod Drive Exchange And Support Activities, 2/2/2021
- (2) The inspectors reviewed the following activities:
- ALARA Tracking Sheet 2513T - B2R25 Shielding Project, 2/1/2021
- (3) The inspectors reviewed the following activities:
- ALARA Plan 2523 - B2R25 Refuel Floor Maintenance, 2/2/2021
- (4) The inspectors reviewed the following activities:
- ALARA Plan 2526 - B2R25 Reassembly Activities, 2/2/2021
- (5) The inspectors reviewed the following activities:
- ALARA Plan 2553 - Drywell Welding Equipment Drains, 2/2/2021
- (6) The inspectors reviewed the following activities:
- ALARA Tracking Sheet 2552T - Welding 2/1/2021
Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (3 Samples)
The inspectors evaluated dose estimates and exposure tracking.
- (1) The inspectors reviewed the following as low as reasonably achievable planning documents:
- ALARA Plan 1503 - B1R23 Control Rod Drive Exchange and Support Activities, Revisions 0, 1, & 2 (February and March 2020)
Additionally, the inspectors reviewed the following radiological outcome evaluations:
- ALARA Plan 1503 - B1R23 Control Rod Drive Exchange and Support Activities, 50 and 75 % in-progress reviews and Post Job Review
- (2) The inspectors reviewed the following as low as reasonably achievable planning documents:
- ALARA Plan 1504 - B1R23 Refuel Floor Decontamination Support, Revision 0, 2/11/2020
Additionally, the inspectors reviewed the following radiological outcome evaluations:
- ALARA Plan 1504 - B1R23 Refuel Floor Decontamination Support, 50% in-progress review and Post Job Review
- (3) The inspectors reviewed the following as low as reasonably achievable planning documents:
- ALARA Plan 1523 - B1R23 Refuel Floor Maintenance Window Activities, Revision 0 & 1, 2/11/2020 & 3/13/2020
Additionally, the inspectors reviewed the following radiological outcome evaluations:
- ALARA Plan 1523 - B1R23 Refuel Floor Maintenance Window Activities, Post Job Review
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (4 Samples)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls.
- (1) The inspectors reviewed the following activities:
- Temporary Shielding Request (TSR #) 2 -RF21-01 - Reactor Recirculation Piping
- TSR # 2 -RF21-28 - RWCU Heat Exchangers
- TSR # 2 -RF21-08 - RB 117' Shield Racks
- (2) The inspectors reviewed the following activities:
In progress reviews for the following ALARA Plans (APs):
- AP 2523, B2R25 Refueling Maintenance, at 50%
- AP 2522, Unit 2 Refuel Disassembly, at 50%
- (3) The inspectors reviewed the following activities:
Post Job ALARA review of the following ALARA Plan
- (4) The inspectors reviewed the following activities:
TEDE-ALARA evaluations for the following work activities:
- CRD exchange
- refuel disassembly
- cavity decontamination
- refuel assembly
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance:
(1)by observation via video monitoring of work performed for refueling, CRD exchange preparations, reactor reassembly activities [RWPs 2503 and 2526], and during direct observation while onsite.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
(1)
- Unit 1 standby gas treatment system Trains A and B (2)
- Unit 2 control building emergency filter system Trains A and B
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Temporary Ventilation System Setups
- HEPAs - #6, #9, #19, #1478, #1702
- Air Vacuums - #1614, #1619
- (2) Portable or Installed Monitoring Systems
- iCam (portable continuous air monitor), Enrad # 13220 located in the unit control room stairwell
- iCam, Enrad # 12695 and 11774 located in the hallways on the 20' elevation
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices. Observed in-field applications; verifying the licensee validated the level of protection provided by the devices; inspecting the material condition of devices, reviewing records and certification of devices issued for use; reviewing the qualifications of workers that use the devices; and observing workers donning, doffing and testing devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) Reviewed Brunswick Nuclear Plant - TLD-ED Correlations for the 1st Semi-Annual 2020 Monitoring Period
Internal Dosimetry (IP Section 03.03) (3 Samples)
The inspectors evaluated the internal dosimetry program implementation.
- (1) The inspectors reviewed the following:
In-Vitro Internal Monitoring
- Reviewed results of baseline Tritium bioassay analysis of eight
- (8) divers performing radiological diving during the 2021 Unit 2 outage.
- (2) The inspectors reviewed the following:
Whole Body Counts
- Reviewed positive body count records for eight
- (8) workers installing shielding in the reactor cavity during the 2020 Unit 1 refueling outage
- (3) The inspectors reviewed the following:
Dose Assessments Performed Using Air Sampling and Derived Air Concentration-Hour Monitoring
- Internal dose assessments for eight
- (8) workers installing shielding in the reactor cavity during the 2020 Unit 1 refueling outage (based on whole body counts).
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situation:
- (1) Licensees implementation of requirements to manage radiation protection of declared pregnant workers for three workers.
- (2) Licensees implementation and application of NRC-approved external dosimetry methods (i.e. EDEX) for Control Rod Drive changeouts during 2021 Unit 2 outage.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (6 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Area radiation monitor (ARM) in control room
- (2) Portal monitor (GEM-5) at RCA exit
- (3) Small article monitor (Cronos) at RCA exit
- (4) Personnel contamination monitor (Argos) at RCA exit
- (5) High range portable survey instrument (Telepole) in instrumentation lab
- (6) Continuous air monitors (iCAMs) in various locations in the reactor building
Calibration and Testing Program (IP Section 03.02) (11 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Whole body counter (WBC) no. BNPFS2
- (2) Unit 2 drywell high range area radiation monitor
- (3) Count room gamma detector no. 3
- (4) Count room alpha and beta Tennelec detector no. TH-05
- (5) Electronic dosimeter serial no. 867834
- (6) Count room Tricarb tritium counter serial no. SGLO30201363
- (7) GEM-5 serial no. 11698
- (8) Cronos-4 serial no. 11652
- (9) Argos 5AB serial no. 12309
- (10) Telepole serial no. 02131
- (11) Ludlum model 12-4 Remball serial no. 12141
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Main stack gaseous effluent monitor
- (2) Liquid waste discharge effluent monitor
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (April 1, 2020 through March 31, 2021)
- (2) Unit 2 (April 1, 2020 through March 31, 2021)
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1 (April 1, 2020 through March 31, 2021)
- (2) Unit 2 (April 1, 2020 through March 31, 2021)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1 (April 1, 2020 through March 31, 2021)
- (2) Unit 2 (April 1, 2020 through March 31, 2021)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) Unit 1 (January 1, 2020 through January 1, 2021)
Unit 2 (January 1, 2020 through January 1, 2021)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) Unit 1 (May 1, 2020 through January 1, 2021)
Unit 2 (May 1, 2020 through January 1, 2021)
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in equipment performance that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) NCR 2370489: Invalid Unit 2 Group 6 Initiation
===71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02)===
The inspectors evaluated the following licensee event report (LER):
- (1) LER 05000325/2020-002-00, Technical Specification Required Shutdown Due to Unidentified Leakage (ADAMS Accession No. ML20140A004). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.
Personnel Performance (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees performance regarding an event that occurred on February 17, 2021. The event was an invalid group 6 isolation and was reported to the NRC on April 4, 2021, under event notification 55191. This 60-day notification was in lieu of a written LER as allowed by 10 CFR 50.73(a)(1). The group 6 actuation was considered invalid pursuant to 10 CFR 50.73(a)(2)(iv)(A) and 10 CFR 50.73(a)(2)(iv)(B). The operators responded to the event in accordance with required procedures.
INSPECTION RESULTS
Observation: Semi-Annual Trend Review 71152 The inspectors performed a trend analysis on the licensees corrective action program to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on equipment performance trends, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of January 2021 through June 2021, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends. Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.
During this review, the inspectors did note that two recent operating cycles on both units were affected by degrading recirculation pump seals. Just prior to the March 2021, Unit 2 refueling outage, Unit 2 experienced a degrading 'B' recirculation pump seal. This was evidenced by a deviation from expected seal pressure parameters and increased drywell leakage. In this case, the licensee was able to continue to operate plant until Unit 2 was shut down for a refueling outage on March 5, 2021. During this refueling outage both the 'A' and 'B' seal packages were replaced. Also, during the latter part of April 2021, the operators noted degrading trends on the Unit 1 'B' recirculation pump seal. In this case, it was determined by the licensee that the best path forward was to remove the unit from service for a mid-cycle outage and replace the seal package, as discussed in Section 71111.20 of this report. Unit 1 was shut down from May 1 to May 12 to replace both the 'A' and 'B recirculation pump seal packages.
The inspectors noted that the typical life cycle for a seal package is six years. In both the cases noted above, the seal package did not last the expected six years. This negative trend was communicated to the licensee that the seal packages may not be operating or installed to their optimal performance.
Observation: Annual Follow-up of Selected Issue: Invalid Unit 2 Group 6 Isolation (NCR 2370489)71152 The inspectors conducted a detailed review of NCR 2370489, Invalid Unit 2 Secondary Containment and Group 6 Isolation. The inspectors chose this sample because it dealt with the barrier integrity cornerstone. During performance of a Unit 2 Group 6 isolation functional test, the secondary containment isolation signal was received after the reactor building ventilation radiation monitor exceeded the setpoint. The licensee determined the isolation was invalid and realigned the reactor building ventilation. When the ventilation was restored, the radiation monitor output returned to normal.
The licensee performed a detailed root cause analysis and developed several corrective actions to address the deficiencies. The root cause was determined to be moisture intrusion into the electronics within the detector assembly or signal cable connector. The inspectors determined that the licensees plan to address this issue was reasonably commensurate with the safety significance of the equipment that might be affected by this type of equipment failure.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 29, 2021, the inspectors presented the integrated inspection results to John A. Krakuszeski and other members of the licensee staff.
- On April 6, 2021, the inspectors presented the radiation safety inspection results to John A. Krakuszeski and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
D-02526
Reactor Building Residual Heat Removal piping diagram
D-25023
Reactor Building High Pressure Coolant Injection System
Procedures
Residual Heat Removal System Operating Procedure
139
Core Spray System Operating Procedure
Core Spray System Operating Procedure
SD-18
Core Spray 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
AD-OP-ALL-0207
Fire Brigade Administrative Controls
CSD-BNP-PFP-
0DG
Diesel Generator Building Prefire Plans
71111.11Q Procedures
Approach to Criticality and Pressurization of the Reactor
24
AD-OP-ALL-1000
Conduct of Operations
Engineering
Changes
Commercial Grade (CG) dedication package for a
Westinghouse transducer
Procedures
AD-EG-ALL-1210
Procedures
BNP Integrated Scheduling
AD-OP-ALL-0201
Protected Equipment
AD-WC-ALL-0200
On-Line Work Management
AD-WC-ALL-0250
Work Implementation and Completion
AD-WC-ALL-0410
Work Activity Integrated Risk Management
Procedures
AD-OP-ALL-0105
Operability Determinations and Functionality Assessments
Engineering
Changes
DG Fuel Tank Room AFFF degradation
Procedures
Functional Test and Lubrication Check of Lockout Relays
0PT-80.1
Reactor Pressure Vessel ASME Section XI Pressure Test
Work Orders
20437758
Procedures
Approach to Criticality and Pressurization of the Reactor
24
Unit Startup and Synchronization
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Increasing Turbine Load to Rated Power
130
Unit Shutdown
2
Procedures
0PT-12.1D
No. 4 Diesel Generator LOOP/LOCA Test
0PT-12.2C
No. 3 Diesel Generator Monthly Load Test
20
0PT-34.5.4.0
Foam Concentrate Performance Evaluation and Level
Verification
Corrective Action
Documents
NCRs 02282724,
2320188,
2320798,
2320935,
2321363,
2326606,
2330059,
2333210,
2334856,
2334857,
2339395,
2355138 and
2366896
Corrective Action Reports
Miscellaneous
2019 Alpha
Characterization
Report
2019 Alpha Characterization Report
04/13/2020
Procedures
0E&RC-0040
ADMINISTRATIVE CONTROLS FOR HIGH RADIATION
AREAS, LOCKED HIGH RADIATION AREAS, AND VERY
AD-PI-ALL-0100
CORRECTIVE ACTION PROGRAM
AD-RP-ALL-0002
RADIATION AND CONTAMINATION SURVEYS
AD-RP-ALL-0003
RADIOLOGICAL AIR SAMPLING
AD-RP-ALL-0004
RADIOLOGICAL POSTING AND LABELING
AD-RP-ALL-0005
ACCESS CONTROLS FOR HIGH AND LOCKED HIGH
RADIATION AREAS
AD-RP-ALL-0006
PERSONNEL CONTAMINATION MONITORING
AD-RP-ALL-0007
CONTROL OF RADIOACTIVE MATERIAL
AD-RP-ALL-0009
RADIOGRAPHY
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-RP-ALL-0010
RADIOLOGICAL JOB COVERAGE
AD-RP-ALL-2002
SRD ALARMS
AD-RP-ALL-2004
MANAGEMENT OF LARGE SCALE CONTAMINATION
EVENTS
AD-RP-ALL-2008
REMOTE MONITORING
AD-RP-ALL-2011
RADIATION PROTECTION BRIEFINGS
AD-RP-ALL-2017
ACCESS CONTROLS TO VERIFY HIGH RADIATION AREA
AND SUPPLEMENTAL ACCESS CONTROLS FOR HRA
AND LHRA
AD-RP-ALL-2020
RADIOLOGICAL CONTROLS FOR DIVING OPERATIONS
Radiation Surveys 511436001 IL
Nuclide Distribution Report (DAW)
09/08/2020
BNP-M-
201227-8
ISFSI Survey
2/27/2020
BNP-M-
210305-7
Unit 2 Refueling Building - Shield Block removal
03/05/2021
BNP-M-
210306-26
Unit 2 Reactor Cavity Initial Entry
03/06/2021
BNP-M-
210306-41
Unit 2 Drywell initial Entry
03/6/2021
BNP-M-
210306-42
Unit 2 Drywell Initial Entry Survey
03/06/2021
BNP-M-
210306-5
Unit 2 Drywell Initial Entry Survey
03/06/2021
BNP-M-
210307-14
Unit 2 Reactor Cavity - Rx Head detailed survey
03/07/2021
BNP-M-
210309-24
Unit 2 Drywell 67' Elevation - Nozzle Shields open
03/09/2021
BNP-M-
21031321-020
BNP BRAC DETERMINATION
03/13/2021
BNP-M-
210323-19
U-2 Turbine Building - Valve 2-MVD-S1 Breach
03/23/2021
BNP-M-
210323-9
Unit 2 RWCU Heat Exchanger insulation replacement
03/23/2021
BNP-M-
Unit 2 TIP Drive Boxes [Incore drives]
03/25/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
210325-10
BNP-M-
210328-11
Unit 2 Fuel Pool heat exchanger room Fill and Vent by Ops
03/28/2021
BNP-M-
210329-1
Unit 2 Reactor Cavity Post Drain Down/Pre Decon
03/29/2021
BNP-M-
210330-1
Unit 2 Reactor Cavity Post Decon and after reactor head set
03/30/2021
Radiation Work
Permits (RWPs)
List of 2021 Unit 2
Outage RWPs
(B2R25)
Including dose and dose rate alarm setpoints by task.
01/25/2021
List of Active
21 Online
Including dose and dose rate alarm setpoints.
01/25/2021
Self-Assessments 02169344-05
Radioactive Material Management
05/24/2018
248333-05
BNP ALARA Self-Assessment
09/12/2019
248336-05
Internal Dosimetry
2/12/2019
2307278-05
RP Field Operations
10/08/2020
2307279-05
BNP Respiratory Protection Program Assessment
09/17/2020
ALARA Plans
21 Site ALARA goals
2/18/2021
2018 - 2022
Brunswick Nuclear Plant ALARA Long Range Plan
2018
UPDATE
20
Brunswick Nuclear Plant ALARA Long Range Plan, including
source term reduction initiatives
2/11/2019
Calculations
-RF21-01
Temporary Shielding Request (TSR), U2 DW 5', 17' and 38',
GA dose rate reduction on RCR piping from 5' to 48'
Elevations
2/04/2021
-RF21-08
Unit 2 117' Refuel Floor, RB 117' Shield Racks
2/04/2021
2-RF21-05
Temporary Shielding Request, U2 Rx Cavity Inner & Outer
Bellows, Reduce GA Dose Rates for Rx disassembly and
reassembly
2/04/2021
Miscellaneous
Special ALARA Committee Meeting Minutes
01/13/2021
Special ALARA Committee Meeting Minutes
01/20/2021
ALARA Committee Meeting Minutes
01/25/2021
Brunswick Unit 2 BRAC Survey Data - 2005 through 2021
03/21/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Power BI Brunswick ALARA Dose tracking reports 3/6/2021
through 3/31/2021
Procedures
Cobalt Reduction Program
AD-RP-ALL-9000
ALARA PROGRAM
AD-RP-ALL-9001
ALARA PLANNING
MNT-NGGC-0003
Radiation Shielding Use
Calculations
Air Sample obtained inside the tent during 2B Turbine rotor
blade sand blasting activity
3/11/2021
Gamma Spec #
210478
Air sample obtained during MSR Cross-Over Piping breach
3/9/2021
Gamma Spec #
210580
Air Sample obtained in the U-2 Drywell under vessel during
SRM installation
3/22/2021
Calibration
Records
S/N 2870260
SCBA Annual Flow Tests dated 8/28/2019 and 8/27/2020
S/N 4821117
SCBA Annual Flow Tests dated 8/28/2019 and 8/26/2020
S/N 8030114807
PortaCount Pro Model 8030 Calibration Certificate
11/20/2020
S/N 8030114808
PortaCount Pro Model 8030 Calibration Certificate
2/03/2020
Serial Number
(S/N) 1830280
Self-Contained Breathing Apparatus (SCBA) Annual Flow
Tests dated 8/28/2019 and 8/27/2020
Corrective Action
Documents
NCRs 02264578,
276211,
278444,
286549,
287736,
2304096 and
2334838
Corrective Action Documents
Miscellaneous
Scott SCBA Maintenance and Overhaul Technician
Certification for Vallen Distribution Inc. service personnel
2/28/2020
0E&RC-0292
Monthly SCBA and Respirator Inspection and Inventory -
January 2021
01/19/2021
0E&RC-0292
Monthly SCBA and Respirator Inspection and Inventory -
February 2021
2/09/2021
Procedures
0E&RC-0135
SAMPLING OF BREATHING AIR
0E&RC-0136
SET UP AND USE OF AIR LINE RESPIRATORY
PROTECTION DEVICES
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0E&RC-0225
TESTING OF HEPA PARTICULATE FILTERS AND SEALS
0E&RC-0229
CONTROL AND USE OF HEPA AIR FILTRATION UNITS
0E&RC-0311
CALIBRATION OF AIR SAMPLING EQUIPMENT
0E&RC-0351
OPERATION OF ECONOAIR L-5P LAPEL AIR SAMPLERS
AD-RP-ALL-0008
USE AND CONTROL OF HEPA FILTRATION AND VACUUM
EQUIPMENT
AD-RP-ALL-2014
WORK IN ALPHA ENVIRONMENTS
AD-RP-ALL-2015
ALPHA RADIATION CHARACTERIZATION
AD-RP-ALL-2019
TEDE-ALARA EVALUATIONS AND DAC-HOUR TRACKING
AD-RP-ALL-6001
QUANTITATIVE FIT TESTING
AD-RP-ALL-6002
INSPECTIONS OF SELF-CONTAINED BREATHING
APPARATUS (SCBA) AND ASSOCIATED EQUIPMENT
AD-RP-ALL-6005
POWERED AIR-PURIFYING RESPIRATORS
PD-RP-ALL-6000
RESPIRATORY PROTECTIVE EQUIPMENT APPROVAL
AND ISSUE
Radiation Surveys
Radioactive Air Sample Log and sample results from 3/6/2021
to 3/26/2021.
Work Orders
20101777 01
LR, Perform 1-SGT-1B, 1PT-15.1.2B Filter Test
20192264 01
CB Emergency Filter System Test (A Train)
20192794 01
LR, Perform 1PT-15.1.2A, SBGT 1A Filter Test
272257 02
LR, Perform 1MST-SBGT500B Filter Test
20342806 08
LR, Perform 1MST-SBGT500A, SBGT 1A Filter Test
20348040 01
CB Emergency Filter System Test (A Train)
Calculations
RWP 2500, Task
AD-RP-All-4015, Attachment 3, Multi-Pack Form EDEX
calculations for eight (8) individuals performing CRD exchange
activities - 3/16/2021 to 3/19/2021.
Corrective Action
Documents
NCRs 02263673,
269618,
2319556,
2320487,
2323566, and
2344441
Engineering
Evaluations
CSD-RP-ALL-
4001
Brunswick Passive Whole Body Sensitivity Study
5/25/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Dosimetry
Technical Report:
14-02
BNP DSC/ISFSI NEUTRON TLD CORRECTION FACTOR
VALIDATION
09/25/2014
Miscellaneous
Whole Body Counter nuclide libraries for routine analysis and
screening for medical isotopes.
2/10/2021
CFR Part 61
Brunswick Dry Active Waste Characterization [Nuclide
Distribution Report]
09/08/2020
In-Vitro Bioassay
GEL Laboratories Tritium Bioassay Sample analysis results -
Work Order #s 536569 and 536647.
Bioassay samples obtained 3/3/and 3/4/2021.
NVLAP LAB
CODE: 100505-0
Duke Energy Dosimetry Laboratory NVLAP Certificate of
Accreditation - 2019, 2020, and 2021
Procedures
AD-RP-ALL-0006
Personnel Contamination Monitoring
AD-RP-ALL-2003
Investigation of Unusual Radiological Occurrences
AD-RP-ALL-2010,
Skin Dose
Skin Dose from Contamination
AD-RP-ALL-4014
Dosimetry Management
CSD-RP-ALL-
4016
Prospective Determination for Occupational Exposure
TE-RP-ALL-2007
Neutron Dose Tracking
TE-RP-ALL-4001
Declared Pregnant Worker
Self-Assessments Self-Assessment
2300425
20 Dosimetry Lab Internal Audit
8/4/2020
Self-Assessment
Number:
248336
Brunswick Internal Dosimetry
2/12/2019
Self-Assessment
Number:
2307281-05
Brunswick External Dosimetry
2/3/2020
Self-Assessment:
2300428
Duke Energy Dosimetry Laboratory 2020 NVLAP On-Site
Assessment
9/16/2020
71151
Calculations
BNP-MECH-MSPI BNP Mitigating System Performance Index Plant Basis
Document
Corrective Action
NCRs 02320798,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
2332479,
2337906,
2340880,
2359530, and
2360615
Miscellaneous
Brunswick 2020 Annual Radioactive Liquid Release Summary
Report [including MEI total dose and isotopic release totals for
the year]
2/18/2021
Brunswick 2020 Annual Radioactive Gaseous Release
Summary Report [including MEI total dose and isotopic
release totals for the year]
2/18/2021
Electronic Dosimeter (ED) Dose and Dose Rate Alarm Logs
from 1/1/2020 through 1/31/2021
Procedures
AD-PI-ALL-0700
Performance Indicators
AD-PI-ALL-0700
Performance Indicators
Corrective Action
Documents
Invalid U2 Group 6
0