IR 05000324/2024004

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Integrated Inspection Report 05000324/2024004 and 05000325/2024004
ML25042A096
Person / Time
Site: Brunswick  
Issue date: 02/12/2025
From: Katie Mccurry
Division of Operating Reactors
To: Krakuszeski J
Duke Energy Progress
References
IR 2024004
Download: ML25042A096 (1)


Text

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2024004 AND 05000325/2024004

Dear John A. Krakuszeski:

On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On January 23, 2025, 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, Katherine H. McCurry, Chief Projects Branch 2 Division of Operating Reactor Safety 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:

05000324/2024004 and 05000325/2024004

Enterprise Identifier:

I-2024-004-0014

Licensee:

Duke Energy Progress, LLC

Facility:

Brunswick Steam Electric Plant

Location:

Southport, NC

Inspection Dates:

October 1, 2024, to December 31, 2024

Inspectors:

S. Battenfield, Operations Engineer

C. Curran, Resident Inspector

K. Kirchbaum, Senior Operations Engineer

M. Riley, Senior Project Engineer

G. Smith, Senior Resident Inspector

Approved By:

Katherine H. McCurry, Chief

Projects Branch 2

Division of Operating Reactor Safety

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 05000325/2024-001-00

LER 2024-001-00 for

Brunswick Steam Electric

Station, Unit 1 - Primary

Containment Penetration

Local Leak Rate Testing

Failure

71153

Closed

PLANT STATUS

Unit 1 began the period at 100 percent (full) rated thermal power (RTP) and operated there until

October 16, 2024, when the unit was taken off-line for a forced outage due to a tube leak in the

2A feedwater heater. Following repairs to the feedwater heater, plant startup was

commenced. The reactor was taken critical at 1002 on October 28 and the unit was restored to

full RTP on November 1, where it continued to operate for the remainder of the inspection

period.

Unit 2 began the period at full RTP and operated there until November 7, 2024, when power

was reduced to 80 percent RTP to perform a control rod improvement. Following the rod

improvement, the unit was restored to full RTP on September 9, where it continued to operate

until November 16 when power was reduced to 70 percent RTP to perform a control rod

sequence exchange and turbine valve testing. Following the valve testing, the sequence

exchange, and subsequent rod improvement, the unit was restored to full RTP on November 19,

where it continued to operate unit December 23 when the unit began a power coast down due

to maximum recirculation flow and an all-rods-out condition. Unit 2 power reached 96 percent

RTP at the end 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 DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Plant Status, 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 cold weather preparations for the following systems: conventional service

water (CSW), nuclear service water (NSW), and the transformer yard on November

21, 2024.

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)

Unit 2 NSW and CSW while the Unit 2 A CSW pump was out-of-service (OOS) due

to discharge strainer maintenance on October 1, 2024

(2)

Unit 2 A train residual heat removal (RHR) train while the B RHR train was OOS for

a maintenance outage on October 10, 2024

(3)

Unit 2 NSW and CSW while the Unit 2 C CSW pump was OOS due to discharge

strainer maintenance on December 17, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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)

Unit 2 reactor building -17 elevation in the core spray diagonals on October 13, 2024

(2)

supplementary diesel generator platform on December 29, 2024

(3)

modular chiller plant on December 29, 2024

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated external flooding mitigation protections in the emergency

diesel generator (EDG) and service water buildings.

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

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

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 (10 CFR) 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's

Licenses." The inspector performed an in-office review of the overall pass/fail results of the

individual operating examinations and the crew simulator operating examinations in

accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification

Program and Licensed Operator Performance." These results were compared to the

thresholds established in Section 3.03, "Requalification Examination Results," of IP 71111.11.

(1)

The inspectors reviewed and evaluated the licensed operator examination failure

rates for the requalification annual operating exam completed on October 2, 2024.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1)

Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification

written examination administered in September 2023.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the facility licensees annual requalification

operating test.

Administration of an Annual Requalification Operating Test

The inspectors evaluated the effectiveness of the facility licensee in administering

requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility

licensee is effectively evaluating their licensed operators for mastery of training

objectives.

Requalification Examination Security

The inspectors evaluated the ability of the facility licensee to safeguard examination

material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the

licensee and reviewed the adequacy of re-examinations for licensed operators who

did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators

meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the facility licensees control room

simulator in modeling the actual plant and for meeting the requirements contained in

10 CFR 55.46.

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 Unit 2 down power to perform a control rod improvement as well as the

subsequent power ascension on October 1, 2024.

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

(1)

The inspectors observed and evaluated an annual simulator operating exam in

accordance with LREG 019, Rev. 0, on October 1, 2024. This operating exam was a

small break loss of coolant accident followed by an emergency depressurization and

included numerous equipment failures.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 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 1 steam bypass valve internal leakage at hydraulic operator (nuclear condition

report (NCR) 2508676)

(2)

maintenance rule periodic evaluation (PE) performed in accordance with 10 CFR

50.65(a)(3). The PE covered a period of June 1, 2021, to June 28, 2023, and was

documented under self-assessment #2475529.

(3)

Bus 1C to E2 master and slave breakers failed to close (NCR 2505184)

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control (QC)

activities to ensure the following SSC remains capable of performing its intended function:

(1)

1.

ultrasonic testing of Unit 1 and Unit 2 standby liquid control piping (work order

[WO] 20683104 and WO 20683110)

2.

pipe wall thickness measurements on main control room HVAC air

compressor 'B' receiver tank (WO 20642799)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 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)

elevated risk due to Unit 2 'A' CSW pump strainer planned maintenance on October

2, 2024

(2)

elevated risk due to Unit 2 B train RHR outage on October 10, 2024

(3)

elevated risk due to emergent failure of Unit 1 B CSW discharge strainer shear

pin on November 5, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the

following operability determinations and functionality assessments:

(1)

material & test equipment #G502345 was identified as out of tolerance (NCR

2521573)

(2)

closing differential pressure in calculation, BNP-MECH-MOV-DP, was not consistent

with design specification (NCR 2531237)

(3)

Unit 1 reactor core isolation cooling containment isolation valves failed local leak rate

testing (NCR 02505461)

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)

temporary modification associated with the drywell chillers (engineering change #412528)

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated forced outage activities on Unit 1 from October 16 to

October 29, 2024. Unit 1 was shutdown to Mode 4 to perform repairs to the 2A

feedwater heater following a tube rupture that occurred on October 15.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system

operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (3 Samples)

(1)

2PT-24.1-2, Service Water Pump and Discharge Valve Operability Test, Rev 93,

following disassembly and inspection of the Unit 2 A CSW pump discharge strainer

in accordance with (IAW) WO 20621895

(2)

0OP-39, Diesel Generator Operating Procedure, Rev. 204, following replacement of

a failed air start relay, 2-DG2-RTR, IAW WO 20699620

(3)

flow timer testing following replacement of Timer 2-LO-TM-1 on EDG-1 IAW WO 20699701

Surveillance Testing (IP Section 03.01) (5 Samples)

(1)

0PT-08.13.L, Service Water Valve SW-V106 Local Control and Manual Operability

Test, Rev. 12, on November 4, 2024

(2)

0PT-08.2.2C, "LPCI/RHR System Operability - Loop A, Rev. 101, performed on

December 12, 2024

(3)

0MST-HPCI42R, HPCI Auto Actuation and Isolation Logic System (Online)

Functional Test, Rev. 9, performed IAW WO 20615169

(4)

0MST-RCIC26Q, "RCIC Reactor High Water Level Trip Unit Channel Calibration,"

Rev. 5, performed IAW WO 20675365

(5)

0MST-RHR22Q, RHR LPCI ADS CS LL3, HPCI RCIC LL2 Division I TR Unit

Channel Calibration, Rev 12, performed IAW WO 20684209

Inservice Testing (IST) (IP Section 03.01) (2 Samples)

(1)

0PT-10.1.1, RCIC System Operability Test, Rev. 110, completed on Unit 1 on

October 10, 2024.

(2)

0PT-10.1.1, RCIC System Operability Test, Rev. 110, completed on Unit 2 on

October 12, 2024.

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (1 Sample)

The inspectors evaluated:

(1)

a simulator-based licensed operator requalification examination scenario on

November 7, 2024 (0700 and 0900 crews). Note this sample was performed in lieu of

the required emergency preparedness drill evaluation as there were no reasonable

opportunities given to the inspectors during the 2024 inspection cycle.

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) (2 Samples)

(1)

Unit 1 (October 1, 2023 through September 30, 2024)

(2)

Unit 2 (October 1, 2023 through September 30, 2024)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1)

Unit 1 (October 1, 2023 through September 30, 2024)

(2)

Unit 2 (October 1, 2023 through September 30, 2024)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1)

Unit 1 (October 1, 2023 through September 30, 2024)

(2)

Unit 2 (October 1, 2023 through September 30, 2024)

71152A - Annual Follow-up Problem Identification and Resolution

Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1)

Appendix J penetration failure (NCR 2505461) that occurred on February 17,

2024. The inspectors verified the associated corrective actions were appropriate and

completed as scheduled.

71152S - Semiannual Trend Problem Identification and Resolution

Semiannual Trend Review (Section 03.02) (1 Sample)

(1)

The inspectors reviewed the licensees corrective action program to identify potential

trends in equipment performance that might be indicative of a more significant safety

issue. The inspectors did not identify any adverse trends

71153 - Follow Up of Events and Notices of Enforcement Discretion

Event Follow up (IP Section 03.01) (2 Samples)

(1)

The inspectors evaluated a loss of secondary containment due to a one-inch hole that

was identified in the Unit 1 service water (SW) discharge piping at 1640 on December

4, 2024. The inspectors verified the licensees response to this event was

appropriate and adequate. The inspectors also reviewed the initial licensee

notifications to verify that they met the requirements specified in 10 CFR 50.72. The

event was reported to the NRC pursuant to 10 CFR 50.72(b)(3)(v)(C) at 1901 on

December 4, 2024, as an event or condition that could have prevented a safety

function and was documented as event notification57454. The safety function

of secondary containment was restored at 1730 following a temporary repair to the

SW piping. The issue was documented in the licensees corrective action program as

NCR 2537559. Following additional analysis, the licensee determined that secondary

containment remained operable based on the small hole size and that secondary

containment maintained adequate leak tightness, thereby ensuring the technical

specification required vacuum could be established and maintained, and releases to

the environment following a postulated accident would be within regulatory limits. The

licensee retracted this event on January 23, 2025.

(2)

The inspectors evaluated an event that involved the concurrent loss of two EDGs and

the licensees response on December 6, 2024. Specifically, on December 5 at 1745,

EDG-2 was declared OOS due to the failure of an air start relay. The licensee

entered limiting condition for operation 3.8.1 Action D. Subsequently, during a tour of

the EDG building, an auxiliary operator (AO) noted EDG-1 had low lube oil

temperature and EDG-1 was declared OOS at 2358. This required entry into Action

G which required restoration of one EDG within two hours or be in Mode 3 within

twelve hours. The licensee's initial action was to attempt to restore oil temperature to

specification by starting the auxiliary oil pump. At 0148, Action G was exited and

entry was made back into Action D as EDG-2 was still OOS. The inspectors also

reviewed the initial licensee notifications to verify that they met the requirements

specified in 10 CFR 50.72. The event was reported to the NRC pursuant to 10 CFR

50.72(b)(3)(v)(C) at 1700 on December 6, 2024, as an event or condition that could

have prevented a safety function and documented as EN 57459. The licensee

deemed two or more failed EDGs to be a loss of safety function. The issue was

documented in the licensees corrective action program as NCR 2537738. Following

additional analysis, the licensee determined that EDG-1 was never inoperable, and

the indicated temperature noted by the AO was not indicative of the system bulk oil

temperature due to a failure of a 3-way valve controller. The licensee retracted this

event on December 12, 2024.

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1)

LER 05000325/2024-001-00, "Primary Containment Penetration Local Leak Rate

Testing Failure" (Adams Accession No. ML #24102A123). The inspectors determined

that the cause of the condition described in the LER was not reasonably within the

licensee's ability to foresee and correct, and therefore was not reasonably

preventable. No performance deficiency or violation of NRC requirements was

identified. This LER is closed.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

On January 23, 2025, the inspectors presented the integrated inspection results to John and other members of the licensee staff.

On September 13, 2024, the inspectors presented the 71111.11 exit inspection results to

Bryan Wooten, acting plant general manager, and other members of the licensee staff.