IR 05000324/2021010

Temporary Instruction 2515/193 Inspection Report 05000324/2021010 and 05000325/2021010

ML21298A002
Person / Time
Site:	Brunswick
Issue date:	10/22/2021
From:	Shawn Smith NRC/RGN-III/DRP/RPB6
To:	Krakuszeski J Duke Energy Progress
References
IR 2021010
Download: ML21298A002 (11)

Text

October 22, 2021

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 -TEMPORARY INSTRUCTION 2515/193 INSPECTION REPORT 05000324/2021010 AND 05000325/2021010

Dear Mr. Krakuszeski:

On September 24, 2021, the U.S. Nuclear Regulatory Commission ( NRC) completed an inspection at Brunswick Steam Electric Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspe ction are documented in the enclosed report.

One finding of very low safety significance (Green) is document ed in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a fin ding not associated with a regulatory requirement in this report, you should provide a res ponse 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 Inspect or 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/

Steven P. Smith, Chief Reactor Projects Branch 6 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: 05000324/2021010 and 05000325/2021010

Licensee: Duke Energy Progress, LLC

Facility: Brunswick Steam Electric Plant

Location: Southport, North Carolina

Inspection Dates: September 20, 2021 to September 24, 2021

Inspectors: B. Bishop, Sr. Project Engineer D. Jackson, Sr. Project Engineer

Approved By: Steven P. Smith, Chief Reactor Projects Branch 6 Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng the licensees performance by conducting a Reliable Hardened Containment Vent TI-193 Inspection at Brunswick Steam Electric Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing t he 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

Hardened Containment Vent System Preventative Maintenance not P erformed Within Periodicity Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.5] - Work 2515/193 FIN 05000325,05000324/2021010-01 Management Open/Closed The inspectors identified a finding of very low safety significance (Green) for the failure to perform required surveillances within periodicity for the h ardened containment vent system (HCVS).

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Wa ter Reactor Inspection Program - Operations Phase. The inspectors reviewed selected p rocedures and records, observed activities, and interviewed personnel to assess licens ee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergen cy declared by the President of the United States on the public health risks of the coronavi rus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline insp ections were evaluated to determine if all or a portion of the objectives and requirement s stated in the IP could be performed remotely. If the inspections could be performed remot ely, they were conducted per the applicable IP. In some cases, portions of an IP were comple ted remotely and on site. The inspections documented below met the objectives and requirement s for completion of the IP.

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNOR MAL

2515/193 - Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operat ion under Severe Accident Conditions

Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (1 Sample)

Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the reliable hardened containment wetwell vent as described in the plant specific submittals and the associated NRC safety evaluation (ADAMS Accession No. ML19284C833) and determi ned that the licensee was in compliance with NRC Order EA-13-109 Phase 1, R eliable, Severe Accident Capable Wetwell Venting System (ADAMS Accession No. M L13143A321).

The inspectors evaluated licensee implementation of the appropr iate elements of the reliable hardened containment wetwell vent as described in the plant specific submittals and the associated NRC safety evaluation. Specifical ly, the inspectors evaluated licensee implementation of the hardened containment v ent system (HCVS)

functional requirements, design features, maintenance and testi ng, quality standards, and programmatic requirements as described in Appendix A of Tem porary Instruction (TI) 2515/193 Revision 1.

The inspectors verified that the licensee satisfactorily:

• Installed the HCVS to meet the performance objectives outlined in Order EA-13-109;

• Installed the HCVS system with the design features specified i n Order EA-13-109;

• Designed the HCVS to meet the quality standards described in O rder EA-13-109;

• Developed and implemented adequate maintenance and testing of HCVS equipment to ensure their availability and capability;

• Developed and issued procedures to safely operate the HCVS usi ng normal power supplies, during Extended Loss of All AC Power (ELAP), an d a postulated severe accident scenario, and integrated the procedu res into existing plant procedures; and

• Trained their staff to assure personnel can proficiently opera te the HCVS.

Based on samples selected for review, the inspectors verified t hat the licensee satisfactorily implemented appropriate elements of the reliable wetwell venting strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee was in compliance w ith NRC Order EA-13-109 Phase 2, Reliable, Severe Accident Capable Drywell (or alternative strategy)

Venting System (ADAMS Accession No. ML13143A321).

The inspectors evaluated licensee implementation of the appropr iate elements of the reliable wetwell venting strategy as described in the plant spe cific submittals and the associated NRC safety evaluation. Specifically, the inspectors evaluated licensee implementation of Severe Accident Water Addition / Severe Accident Water Management (SAWA/SAWM) functional requirements, installed instr umentation, maintenance and testing, and programmatic requirements as descr ibed in Appendix B of TI 2515/193, Revision 1.

The inspectors verified that the licensee satisfactorily develo ped a strategy making it unlikely that venting from the containment drywell would be nec essary. As part of that strategy, the licensee:

• Implemented the SAWA/SAWM systems as defined and fulfilled fun ctional requirements for installed and portable equipment.

• Installed and/or identified the previously installed instrumen tation necessary to implement SAWM;

• Developed and implemented adequate maintenance and testing of SAWA/SAWM equipment to ensure availability and capability;

• Developed and issued procedures to safely operate the SAWA/SAW M during an ELAP and during postulated severe accident scenario, and int egrated their procedures into their existing plant procedures such that entry into and exiting from the procedures are clear when using existing plant procedu res; and

• Trained their staff to assure personnel can proficiently opera te the HCVS during ELAP and accident scenarios.

INSPECTION RESULTS

Hardened Containment Vent System Preventative Maintenance not P erformed Within Periodicity Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.5] - Work 2515/193 FIN 05000325,05000324/2021010-01 Management Open/Closed The inspectors identified a finding of very low safety signific ance (Green) for the failure to perform required surveillances within periodicity for the harde ned containment vent system (HCVS).

Description: Order EA-13-109, Attachment 2, Section 1.2.13, re quires that the HCVS include features and provisions for the operation, testing, inspection, and maintenance adequate to ensure that reliable function and capability are maintained. Re levant guidance is found in NEI 13-02 Sections 5.4 and 6.2; and HCVS-FAQs-05 and -06.

Brunswicks HCVS Final Integrated Plan, RA-19-0176, Table 3-3, includes testing and inspection requirements. Contrary to the self-imposed surveilla nce requirements, some of Brunswicks HCVS preventative maintenance (PM) work orders were not scheduled, and one had not been completed within periodicity. Among the activities that had not been completed since the initial HCVS modification were valve strokes of the H CVS valves, CAC-V7 and CAC-V216, from the remote operating station, stroke test of the HCVS check valve, CAC-V5002, and visual inspection of the HCVS rooftop weather caps, CAC-75-12-154A. The visual inspection of the weather caps had exceeded its periodic ity requirement. The aforementioned valve strokes from the remote operating station were past the recommended periodicity of Table 3-3 but within the 25 percent surveillance grace period. All of these are new PMs and were not captured in a PM change request (PMCR) or PM requirement (PMRQ), therefore, it is possible that several of them would no t have been performed within periodicity prior to the licensee becoming aware of it.

Corrective Action References: AR 02397922, 02397152 Performance Assessment:

Performance Deficiency: The inspectors determined the licensee s failure to implement testing and inspection requirements for the HCVS in accordance with the Brunswick Final Integrated Plan, Table 3-3, was a performance deficiency.

Screening: The inspectors determined the performance deficienc y was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone ob jective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, failure to inspect the we ather cap could have allowed undetected degradation and entry of debris/precipitation.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 3, Barrier Integrity Screening Questions, the inspectors determined the fi nding was of very low safety significance (Green) because it did not represent an actual ope n pathway in the physical

integrity of reactor containment (valves, airlocks, etc.), fail ure of containment isolation system (logic and instrumentation), failure of containment pressure co ntrol equipment (including SSCs credited for compliance with Order EA-13-109), failure of containment heat removal components, or failure of the plants severe accident mitigatio n features (AP1000); nor did it involve an actual reduction in function of hydrogen igniters in the reactor containment.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and mana gement of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee failed to ensure that testing and inspection requi rements identified in the HCVS engineering change were translated and implemented into prevent ive maintenance routes (PMCRs nor PMRQs) within the work management system to ensure c ompletion.

Enforcement: Inspectors did not identify a violation of regulatory requireme nts associated with this finding.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On September 24, 2021, the inspectors presented the Reliable H ardened Containment Vent TI-193 Inspection results to John A. Krakuszeski and othe r members of the licensee staff.

6