IR 05000324/2021012
| ML21236A173 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/24/2021 |
| From: | Stewart Bailey NRC/RGN-II/DRP/RPB4 |
| To: | Krakuszeski J Duke Energy Progress |
| References | |
| IR 2021012 | |
| Download: ML21236A173 (12) | |
Text
August 24, 2021
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000324/2021012 AND 05000325/2021012
Dear Mr. Krakuszeski:
On July 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Brunswick Steam Electric Plant and discussed the results of this inspection with John and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment as well as interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
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: DPR-62 and DPR-71 Report Numbers: 05000324/2021012 and 05000325/2021012 Enterprise Identifier: I-2021-012-0011 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant Location: Southport, SC Inspection Dates: July 12, 2021 to July 30, 2021 Inspectors: C. Safouri, Senior Resident Inspector (Team Lead)
D. Jackson, Senior Project Engineer M. Donithan, Operations Engineer B. Towne, Resident Inspector Approved By: Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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
None.
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), inspectors were directed to begin telework. In addition, 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the aging management program. The inspectors also reviewed the corrective actions, open at the time of completion of the documented IP 95001 Supplemental Inspection (ADAMS Accession Number ML19289A011), dated October 16, 2019, associated with the Unit 1 Reactor Coolant System Leakage performance indicator crossing the green-to-white threshold in the Barrier Integrity Cornerstone. The inspectors verified these corrective actions had been completed as scheduled. However, the following corrective actions remained open and require subsequent NRC review: 2265623-37, EOC-AS4 (CORR); 2265623-38, EOC-AS5 (CORR); and 2265623-40, RC1-EREV2 (EREV).
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B 1. Corrective Action Program Effectiveness Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports as described in licensee procedure AD-PI-ALL-0100, "Corrective Action Program," and managements expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.
Problem Prioritization and Evaluation: Based on the review of condition reports, the inspectors concluded that problems were prioritized and evaluated in accordance with the condition report significance determination guidance in procedure AD-PI-ALL-0100. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated.
Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected . For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed condition reports and effectiveness reviews to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.
2. Operating Experience The inspectors determined that the station's processes for the use of industry and NRC operating experience information were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed.
3. Self-Assessments and Audits The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.
Self-assessments were generally detailed and critical. The inspectors verified that condition reports were created to document areas for improvement and findings resulting from self-assessments, as well as verified that actions had been completed consistent with those recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.
4. Safety Conscious Work Environment Based on interviews with plant staff and reviews of the latest safety culture survey results to assess the safety conscious work environment on site, the inspectors found no evidence of challenges to the safety conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 30, 2021, the inspectors presented the biennial problem identification and resolution inspection results to John A. Krakuszeski and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Calculations SA-E11-502 Stress Analysis for RHR Pumps 1B & 1D Discharge 5
Corrective Action Nuclear Condition 2281389, 2284206, 2287386, 2293843, 2304996, 2305838,
Documents Reports (NCRs) 2332592, 2335949, 2349867, 2351669, 2269646, 2271658,
274560, 2278424, 2279743, 2282484, 2282721, 2291142,
2344012, 2374676, 2281669, 2281677, 2285581, 2287588,
296662, 2297142, 2302607, 2303339, 2305503, 2317262,
267556, 2268639, 2269084, 2269779, 2279694, 2308172,
2341264, 2343883, 2349753, 2369431, 2359462, 2284092,
266414, 2269729, 2270874, 2144578, 2188317, 2221085,
254200, 2195563, 2387981, 2387982, 2387983, 2387984,
2387985, 2271198, 2300444, 2260472, 2267026, 2269618,
280655, 2283394, 2284008, 2284660, 2285129, 2286448,
288878, 2289038, 2290331, 2290655, 2291385, 2294630,
295123, 2300444, 2304068, 2305663, 2317682, 2318788,
20467, 2321660, 2322706, 2326377, 2331407, 2338449,
2340656, 2343895, 2347250, 2352130, 2356033, 2356580,
2364279, 2367475, 2370869, 2371042, 2371050, 2371507,
2378701, 2381039, 2384462, 2260949, 2261683, 2261828,
261846, 2262053, 2266407, 2267133, 2267154, 2267466,
269794, 2270110, 2270279, 2270994, 2270998, 2271254,
271953, 2273360, 2273610, 2275426, 2276611, 2276738,
277159, 2277506, 2278361, 2278518, 2279905, 2280085,
280577, 2281400, 2282070, 2283081, 2283117, 2285650,
287466, 2288927, 2289172, 2289684, 2289919, 2289987,
293774, 2297423, 2298744, 2304709, 2308961, 2316242,
22874, 2324073, 2351273, 2356365, 2358956, 2374571
Nuclear Task 2285581, 2288256
Management
(NTM)
Root Cause 2321942, 2323829, 2265623, 2321700
Evaluations
(RCE)
Inspection Type Designation Description or Title Revision or
Procedure Date
Engineering 412996 Replace the 1-E11-F048B-MO (1B RHR Hx Bypass Vlv) with 0
Changes an Aluminum Rotor
413030 1-E11-F007B-MO Replacement Actuator Evaluation New 0
Motor Curve
Miscellaneous BNP PRA Top 10 List
BNP Corrective Action Program Health Report Card 06/24/2021
Operator Workarounds and Operator Burdens, various
reports dated April 2019 through May 2021
LOR-CLS-LP-19- Lesson Plan - Loss of SDC Case Study 0
5-1
LOR-CLS-LP- Lesson Plan - Outage LCOs 5
200-B
SD-17 Residual Heat Removal System Description 02/14/2019
Procedures 0GP-01 Prestartup Checklist 208
0GP-02 Approach to Criticality and Pressurization of the Reactor 124
0GP-04 Increasing Turbine Load to Rated Power 130
1OP-02 Reactor Recirculation System 134
1OP-17 Residual Heat Removal System 139
1OP-19 High Pressure Coolant Injection System 101
1OP-25 Main Steam System 65
1PT-24.1-1 Service Water Pump and Discharge Valve Operability Test 96
1PT-24.1-1 Service Water Pump and Discharge Valve Operability Test 95
AD-EG-ALL-1176 Preparation of Engineering Documents 4
AD-EG-ALL-1206 Equipment Reliability Classification 5
AD-EG-ALL-1210 Maintenance Rule Program 3
AD-HU-ALL-0001 Human Performance Program 16
AD-LS-ALL-0003 NRC Audit and Inspection Activities 9
AD-NO-ALL-0202 Employee Concerns Program 4
AD-NO-ALL-0204 Nuclear Safety Culture Program 3
AD-OP-ALL-0105 Operability Determinations 6
AD-OP-ALL-0202 Aggregate Operator Impact Assessment 3
AD-PI-ALL-0100 Corrective Action Program 25
AD-PI-ALL-0101 Root Cause Evaluation 8
Inspection Type Designation Description or Title Revision or
Procedure Date
AD-PI-ALL-0105 Effectiveness Reviews 2
AD-PI-ALL-0106 Cause Investigation Checklists 6
AD-PI-ALL-0200 Performance Trending 11
AD-PI-ALL-0300 Self-Assessment and Benchmark Programs 5
AD-PI-ALL-0400 Operating Experience Program 10
AD-PI-ALL-0401 Significant Operating Experience Program 8
AD-PI-ALL-1000 Conduct of Performance Improvement 9
AD-WC-ALL-0210 Work Request Initiation, Screening, Prioritization and 14
Classification
AD-WC-ALL-0250 Work Implementation and Completion 12
Self-Assessments Service Water Station Health Reports 2019Q3 - 2021Q1
RPS Station Health Reports Q42020 - Q12021
Station Sciences BNP Performance Trending Report - 3rd
Triannual Period 2020
Security BNP Performance Trending Report - 3rd Triannual
Period 2020
BNP 2020 Mid-Cycle Assessment
2019-BNP-MNT- NOS Audit - BNP Maintenance and Special Processes
2019-BNP-OPT- NOS Audit - BNP Operations Training
2019-FLEET- NOS Audit - Fleet Corrective Action Program
CAP-LSA-01
20-BNP-OTSL- NOS Audit - BNP Operations, Technical Specifications, and
Licensing
20-FLEET- NOS Audit - Fleet Performance Improvement and Corrective
CAP-01 Action Program
245353 Reactivity Management Assessment
245353 Reactivity Management 06/13/2019
246065 2019 Annual CAQ EC Assessment for BNP
299532-05 BNP Operator Fundamentals 11/15/2020
2306631 Corrective Action Program - Cause Evaluation Quality 10/25/2020
2306633 Corrective Action Program (CAP) processes and 01/10/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
requirements
2306633 CAP Compliance
2364310 Fatigue Rule 2021
2364754 Readiness Assessment for the 2021 BNP PI&R Inspection
BNP-SITE- BNP Performance Trending Report 3rd Triannual Period 03/20/2021
1497.02-2020-3 Year, September 1 - December 31, 2020
Work Orders Work Orders 12192261
(WOs)
Work Requests 20146479, 20162013, 20184435, 20191397, 20199364,
(WRs) 20148785, 20195457, 20146996, 20149336, 20346420
9