IR 05000324/2023010

Biennial Problem Identification and Resolution Inspection Report 05000324/2023010 and 05000325/2023010

ML23285A036
Person / Time
Site:	Brunswick
Issue date:	10/17/2023
From:	Matthew Fannon Division Reactor Projects II
To:	Krakuszeski J Duke Energy Progress
References
IR 2023010
Download: ML23285A036 (1)

Text

October 17, 2023

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000324/2023010 AND 05000325/2023010

Dear John A. Krakuszeski:

On September 14, 2023, 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 you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution 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 problem identification and resolution 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, and 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, Signed by Fannon, Matthew on 10/17/23 Matthew S. Fannon, 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: 05000324/2023010 and 05000325/2023010 Enterprise Identifier: I-2023-010-0031 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant Location: Southport, NC Inspection Dates: August 28, 2023 to September 14, 2023 Inspectors: C. Curran, Resident Inspector D. Jung, Resident Inspector S. Obadina, Reactor Operations Engineer J. Seat, Senior Project Engineer Approved By: Matthew S. Fannon, 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.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.

• Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors conducted an in-depth corrective action program review of the following systems or portions thereof: emergency alternating current power system, direct current power system, and high pressure coolant injection. The inspectors also conducted a five-year review of conditions associated with the emergency diesel generator system. The corrective actions for the following non-cited violations were evaluated as part of the assessment:

05000325/2022004-01; 05000324,05000325/2022403-01; 05000324,05000325/2022403-02; 05000325/2022001-01; 05000324,05000325/221004-01;05000324/2021003-01; 05000324,05000325/2021003-02; and 05000324,05000325/2021010-01.

• Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

• Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through 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 PI&R Assessment 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 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 September 14, 2023, 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 0CONT-0001 Primary Containment Appendix J Allowable Leakage

Corrective Action NCR 2165289 Emergency Diesel Generator #4 Main Bearings #7 and #8

Documents found degraded

NCR 2379355 IST Program classification of valves

NCR 2384029 DBAI POV Inspection Unresolved Issue (URI) initiated

NCR 2390723 Flaws in Evaluation Basis used to exclude valves from LLRT

NCR 2397152 PMAD - Establish Hardened Containment Vent System

Testing PM Routes

NCR 2397922 Hardened Containment Vent System Testing Routes Not

Established IAW NEI 13-02

NCR 2398526 Missed Appendix J LLRT 1-E11-F009

NCR 2418712 Temporary Loss of Shutdown Cooling

NCR 2442814 Failure to establish logical and physical boundaries to control

data transfer between boundaries

NCR 2444139 Failure to implement control E.5.8, Monitoring Physical

Access

Engineering EC 0000301289

Changes

Miscellaneous B1R24 Post Outage Report

CSD-EG-BNP- BNP IST Program Plan - 5th Interval

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RA-19-0176 HVCS Final Integrated Plan

Procedures 0ENP-16.8 Containment Leakage Tracking

0PT-20.15 Hardened Containment Vent System Piping and Valve Test

0PT-20.3-E11 Local LeakRate Testing for Residual Heat Removal System

AD-EG-ALL-1612 Environmental Qualification (EQ) program

AD-PI-ALL-0400 Operating Experience Program

Work Orders WO 13316872

WO 20283156

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