Text

Integrated Inspection Report 05000324/2021004 and 05000325/2021004
	ML22042B121
Person / Time
Site:	Brunswick
Issue date:	02/14/2022
From:	Stewart Bailey; NRC/RGN-II/DRP/RPB4
To:	Krakuszeski J; Duke Energy Progress
References
	05000324/2021004, 05000325/2021004, IR 2021004
	Download: ML22042B121 (17)
	v • d • e

February 14, 2022

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2021004 AND 05000325/2021004

Dear Mr. Krakuszeski:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On January 27, 2022, 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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:

DPR-62 and DPR-71

Report Numbers:

05000324/2021004 and 05000325/2021004

Enterprise Identifier:

I-2021-004-0013

Licensee:

Duke Energy Progress, LLC

Facility:

Brunswick Steam Electric Plant

Location:

Southport, NC

Inspection Dates:

October 01, 2021 to December 31, 2021

Inspectors:

G. Smith, Senior Resident Inspector

C. Curran, Project Engineer

C. Fontana, Emergency Preparedness Inspector

S. Sanchez, Senior Emergency Preparedness Inspector

M. Schwieg, Senior Reactor Inspector

J. Walker, Emergency Response Inspector

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 Promptly Analyze Laboratory Surveillance Data Results in a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000325,05000324/2021004-01 Open/Closed

[H.1] -

Resources 71152 A self-revealed Green finding and associated Non-cited Violation (NCV) of Unit 1 and Unit 2 Technical Specification (TS) 3.7.3 was identified when the licensee failed to restore the B train of control room emergency ventilation (CREV) to an operable status within the allowed outage time. Specifically, the Unit 2 'B' CREV train was inoperable for appropriately 17 days while TS Limiting Condition for Operation (LCO) 3.7.3 required both units to be placed in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months following 7 days of inoperability.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000325,324/2020-005-00 LER 2020-005-00 for Brunswick Steam Electric Plant (BSEP), Unit 1 Condition Prohibited by Technical Specifications due to Ventilation Charcoal Sample Lab Results.

71153 Closed

PLANT STATUS

Unit 1 began the period at 100 percent (full) rated thermal power (RTP) and operated there until November 19, 2021, when power was reduced to 70 percent RTP for a planned control rod sequence exchange. Following the sequence exchange, as well as one follow on rod improvement, the unit was restored to full RTP on November 23. The unit continued to operate at full power until December 18, when the turbine generator was taken offline to repair a 250F "hot spot" on the main generator's 'B' phase no-load disconnect (NLD). The elevated temperature was discovered during a routine thermography exam. During the repairs, the reactor remained critical and in Mode 1 at 20 percent RTP. Following repairs to the NLD, the main generator was synched to the grid on December 20 and power ascension was commenced. Full power was reached on December 24, following two rod improvements, and the unit continued to operate at full power for the remainder of the inspection period.

Unit 2 began the period at 100 percent RTP and operated there until December 3, 2021, when power was reduced to 70 percent RTP for a planned control rod sequence exchange and turbine valve testing. Following the testing and sequence exchange, as well as two follow on rod improvements, the unit was restored to full RTP on December 7, where the unit continued to operate until December 14 when power was reduced to 95 percent RTP in order to replace resin in a condensate ion exchanger. Following replacement of the resin, the unit was restored to full RTP on December 16 where it continued to operate for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met, consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

standby liquid control (SLC) system

emergency diesel generators

service water system.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1)emergency diesel generator No.1 (EDG-1) following a maintenance outage on October 25, 2021

(2) Unit 2 A residual heat removal (RHR) train while the B RHR train was out-of-service (OOS) for a planned outage on November 19

(3) Unit 2 B RHR train while the A RHR train was OOS for a planned outage on December 9.

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the safety-related Unit 2 nuclear service water system on November 18, 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)supplemental EDG platform on October 12, 2021 (2)transformer yard area on October 12, 2021 (3)modular chiller plant on October 13, 2021 (4)augmented Off-Gas (AOG) Building on October 14, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 2 Reactor Building on October 25, 2021

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." During the week of November 22, 2021, the inspector performed an in-office review of the overall pass/fail results of the individual operating examinations, the crew simulator operating examinations, and the biennial written examinations in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 3.03, "Requalification Examination Results," of IP 71111.11.

The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam completed on October 1, 2021.

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 a down-power to 70 percent RTP for control rod sequence exchange and valve testing on November 19, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated two separate simulator exams on November 3 and November 10, 2021. Both simulator exams were part of the licensed operator continuing training Cycle 5. Both scenarios consisted of a reactor building ventilation radiation monitor failure, a loss of conventional service water, and an anticipated transient without scram with main steam isolation valves closure.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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 2 experienced forced outages as a result of two separate failures of the main generator no-load disconnects in September and October of 2020

(2) Unavailability hours for Unit 2 station auxiliary transformer was exceeded in March 2021.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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)elevated site risk due to service water bay cleaning conducted from October 19-November 19, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1)reactor water cleanup system inlet line inboard isolation valve failed local leak rate testing (NCR 2261604)

(2)missed leakage check for standby liquid control 'B' train relief valve (CR 2382978)

(3)10CFR50.46 ATRIUM 11 PCT LOCA Impact for Brunswick (NCR 2381141)

(4) EDG-1 Starting Air Receiver Possible Air leak (NCR 2402260)

(5) NOS Audit: Battery Testing Concerns (NCR 2402631)

(6) Improper response to auto voltage adjustment during EDG-4 run (NCR 2409059).

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)addition of EDG-4 synchronization check relay (EC 408566).

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1)0LP-UI006B, "DG Output Ammeter Transducer Loop Calibration," Rev. 4, following replacement of EDG-1 output ammeter in accordance with (IAW) work order (WO)

===20462982-01 (2)0PT-09.2, "HPCI System Operability Test," Rev. 153, following preventative maintenance (PM) on an overload relay associated with motor-operated valve (1-E41-F001) IAW WO 20293876-01 (3)0PT-09.2, "HPCI System Operability Test," Rev. 153, following a mechanical and lubrication PM on a motor-operated valve (1-E41-F004) IAW WO 20390296-01 (4)0PT-09.2, "HPCI System Operability Test," Rev. 153, following a mechanical and lubrication PM on a motor-operated valve (1-E41-F001) IAW WO 20469935-01 (5)0PT-09.2, "HPCI System Operability Test," Rev. 153, following a 125 Volt circuit breaker PM associated with motor-operated valve (1-E41-F001) IAW WO 20432108-01 (6)0PT-09.2, "HPCI System Operability Test," Rev. 153, following a 125 volt circuit breaker PM associated with motor-operated valve (1-E41-F004)

IAW WO 20443346-01 (7)0PT-12.2D, "No.4 Diesel Generator Monthly Load Test," Rev. 126, following replacement of a relay on EDG-4 IAW WO 20508199 (8)0PT-12.2C, "No.3 Diesel Generator Monthly Load Test," Rev. 121, following performance of 72-month PM IAW WO 20388524.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22

(1)1MST-HPC127Q, "HPCI and RCIC CST Low Water Level Instrument Channel Cal, Rev 10, completed on October 6, 2021 (2)0MST-CV23R, Main Steam Line Radiation Monitor Detector Calibration, Rev. 40, completed on December 2, 2021 (3)0OP-39 EDG-3 12hr run completed on December 5, 2021 (4)0MST-PCIS29Q PCIS Rx Water LL2 AND LL3 DIV II Trip Unit Channel Cal and Functional Test," Rev. 10, completed on December 13, 2021.

Inservice Testing (IP Section 03.01)===

Main article: IP 20462

(1)0PT-09.2, Unit 1 "HPCI Operability Test," Rev. 153, completed on November 3, 2021 (2)0PT-10.1.1, Unit 2 "RCIC IST," completed on November 12, 2021 (3)0PT-08.2.2C, LPCI/RHR System Operability Test - Loop A, Rev. 97, completed on December 15, 2021.

FLEX Testing (IP Section 03.02) (1 Sample)

(1)0PT-12.27, Rev. 5, "Flex Diesel Generator 1 and 2 Test Procedure,'" Rev 5, completed on November 25, 2021.

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of November 15, 2021.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated readiness of the Emergency Response Organization during the week of November 15, 2021.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted Emergency Action Level and Emergency Plan changes during the week of November 15, 2021. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the Emergency Preparedness Program during the week of November 15,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS07: High Pressure Injection Systems (IP Section 02.06)===

Main article: IP 71151