IR 05000324/2025001
| ML25120A072 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/02/2025 |
| From: | Matthew Fannon NRC/RGN-II/DORS/EB2 |
| To: | Krakuszeski J Duke Energy Progress |
| References | |
| IR 2025001 | |
| Download: ML25120A072 (1) | |
Text
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2025001 AND 05000325/2025001
Dear John A. Krakuszeski:
On March 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On April 24, 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.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations 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.
May 2, 2025 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, Matthew S. Fannon, 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:
Report Numbers:
05000324/2025001 and 05000325/2025001
Enterprise Identifier:
I-2025-001-0020
Licensee:
Duke Energy Progress, LLC
Facility:
Brunswick Steam Electric Plant
Location:
Southport, NC
Inspection Dates:
January 01, 2025 to March 31, 2025
Inspectors:
C. Curran, Resident Inspector
J. Diaz-Velez, Senior Health Physicist
A. Nielsen, Senior Health Physicist
D. Restrepo, Health Physicist
A. Ruh, Senior Reactor Inspector
G. Smith, Senior Resident Inspector
Approved By:
Matthew S. Fannon, 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
Failure to Maintain Minimum Inventory of SCBA Components in Required Storage Areas Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000325,05000324/2025001-01 Open/Closed
[H.2] - Field Presence 71124.03 The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Technical Specification 5.4.1 for the licensees failure to implement procedures related to the use of respiratory protection equipment. Specifically, several self-contained breathing apparatus (SCBA) units in the main control room and technical support center (TSC) were found to be missing air bottles. Therefore, the licensee did not have the minimum number of SCBA units available for emergency use, as required by procedures.
Failure to Follow a Radiation Work Permit Requirement Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000325,05000324/2025001-02 Open/Closed
[H.14] -
Conservative Bias 71124.03 A self-revealed Green finding and associated NCV of Technical Specification 5.4.1 was identified when the licensee failed to implement radiation work permit (RWP) requirements for drywell dome removal work during the B2R27 outage. Specifically, RWP 1522 required the use of respiratory protection equipment for drywell dome removal, but face shields were used instead. As a result, five workers received unplanned intakes of radioactive material.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000325,05000324/20 24-002-00 LER 2024-002-00 for Brunswick Steam Electric Plant Units 1 & 2, Automatic Start of Emergency Diesel Generator due to Emergency Bus De-energization 71153 Closed
PLANT STATUS
Unit 1 began the period at 100 percent rated thermal power (RTP) and operated there until January 6, 2025, when power was reduced to 70 percent RTP to perform a control rod sequence exchange and turbine valve testing. Following the sequence exchange, valve testing and one follow on rod improvement, the unit was restored to 100 percent RTP on January 8, where it continued to operate for the remainder of the inspection period.
Unit 2 began the period at 96 percent RTP with all-rods-out condition and at maximum recirculation flow in a power coast down. The power coast down lasted until February 28, 2025, when power reached 80 percent RTP. On the evening of February 28, Unit 2 was taken offline and the licensee commenced a refueling outage (RFO). Following completion of the RFO, the unit was taken critical on March 28 and reached Mode 1 on March 29. Following generator synchronization on March 30, a power ascension commenced. The unit reached 89 percent RTP by 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 D, 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 record low temperatures on January 7, 2025.
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather during Winter Storm Enzo on January 21, 2025.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 nuclear service water (NSW) and conventional service water (CSW) while the Unit 2 A CSW pump was out-of-service (OOS) due to bay cleaning activities on January 29, 2025
- (2) Emergency diesel generator (EDG)-1, 2, and 3 while EDG-4 was OOS due to a maintenance outage on February 3, 2025
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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 1 reactor building 20 elevation on January 17, 2025
- (2) Unit 1 reactor building 50 elevation on January 24, 2025
- (3) Unit 1 reactor building 61', 77', and 80 elevations on February 18, 2025
- (4) Unit 1 reactor building 98 and 117 elevations on February 20, 2025
- (5) Unit 2 turbine building 20 elevation steam affected areas (condenser bay steam jet air ejector room, main feedwater pump rooms) on March 10, 2025
- (6) Unit 2 turbine building 45 elevation steam affected areas (condenser bay) on March 20, 2025
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 2 'B' residual heat removal (RHR) heat exchanger
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
The inspectors evaluated boiling water reactor non-destructive testing by reviewing the following examinations from March 5 - March 8, 2025:
(1)
1. Ultrasonic examination of reactor pressure vessel nozzle N5B nozzle to safe-
end dissimilar metal weld, 2-B11-N5B-8-FWRN17, work order (WO) 20637621
2. Magnetic particle examination of east service water manway, 2-SW-103-30-
157, WO 20658330
3. Visual examination of torus liner below water line with pitting accepted for
continued service, 2-SC-ML-B9-BWL, WO 20535660
4. Pressure boundary welds on 'C' inboard main steam isolation valve body drain
line, 2-B21-28-2-600, WO 12118874
5. Service water through-wall leak on 1-SW-106-20-157, nuclear condition report
(NCR) 2537558
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 Unit 2 final feedwater temperature reduction and Unit 2 down power on February 28, 2025.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
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 'A' and 'C' quadvoter, 1-EHC-QVTR-SOV-A&C, failure to reset (NCR 2509415)
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) Emergent failure of EDG-2 lube oil temperature switch on January 28, 2025
- (2) Elevated risk due to maintenance outage associated with EDG-4 on February 4
- (3) Reactor coolant system heat removal by natural circulation operation while in Mode 5 on Unit 2 from March 10 through March 13
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Pinhole leak immediately upstream of 1-SW-V159 (NCR 2535429)
- (2) Investigate Unit 1 feedwater heater 2A high level (NCR 2532034)
- (3) Through-wall leak downstream of 1E11-PDV-F068A (NCR 2537559)
- (4) Motor-operated valve, 1E11-PDV-F068B, thermal overload in mid-position (NCR
===2541178)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Engineering change (EC) 425109, Unit 1 Temporary Bypass of 1A Recirc Runback Limiter 1"
- (2) EC 422063, RHR-SDC High Pressure Trip Logic Time Delay Replacement
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01)===
- (1) The inspectors evaluated refueling outage B2R27 activities from March 1 through March 30.
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) Post-maintenance testing on the EDG-1 pre-lube pump following pump and filter replacement in accordance with (IAW) WO 20706822 (2)0PT-12.2B, No. 2 Diesel Generator Monthly Load Test, Revision 124 following replacement of the EDG-2 lube oil cooler inlet high temperature switch IAW WO
20709243 (3)0PT-12.2D, No. 4 Diesel Generator Monthly Load Test, Revision 129 following replacement of the EDG-4 speed sense switch, 2-DG4-SCS-6568-4 IAW WO 20511635 Surveillance Testing (IP Section 03.01)
(1)0MST-RHR23Q, RHR LPCI ADS CS LL3, HPCI RCIC LL2 Division II TR Unit Channel Calibration, Revision 10 performed on December 12, 2024
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
- (1) The inspectors observed the site's first quarter emergency drill/exercise conducted on January 15, 2025. The scenario consisted of a loss of offsite power followed by a small break loss of coolant accident and concluded with an un-isolable steam rupture. The inspectors evaluated performance in the simulator, technical support center, and the operational support center.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Radiation protection (RP) personnel controlling material entering and exiting the radiologically controlled area (RCA)
- (2) RP personnel controlling contamination at the Unit 2, reactor building, 20 ft. control rods drives hatch contamination area
Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (2) Unit 2, 2-G31-F004 Replacement - Low Risk - Support Activities (LHRA/CA), RWP 2558, Task 4
- (3) Unit 2, Nuclear Station Services Activities, (RWP 2529 - Chemistry/RP, Multiple Tasks, Low/Medium Risk - RA/HRA/LHRA/CA)
- (4) Unit 2, DW Manual ISI Activities, Medium Risk in LHRA/HCA RWP 2517 Task 8 (Finger Ring Dosimetry Required)
- (5) Unit 2, RB-Radiography Activities - (RWCU HRA/CA RWP2501, Task 2)
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
- (1) Unit 1, 20 ft. JSAE Room A - Locked High Radiation Area (LHRA)
- (4) Unit 2, 80 ft. Fuel Pool Cooling Room - LHRA
- (5) Unit 2, Drywell Entry Point - LHRA Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Control room emergency ventilation system trains 2A and 2B
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Portable high efficiency particulate air (HEPA) filtration unit, Serial #1478 (setup for use on Unit 2 turbine building) [Dispersed oil particulate (DOP) test due date 1/31/26]
- (2) Portable HEPA filtration unit, Serial #3 (available for use on Unit 2 turbine building)
[DOP test due date 1/31/26]
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) Personnel contamination event (PCE) #24-002, event dated 02/12/2024
- (2) PCE #24-003, event dated 02/12/2024
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Declared pregnant workers, who declared on 02/28/2025, 06/03/2024, and 11/03/2022.
- (2) Multipack EDEX for workers 205523, V601727, V402241, V205797, 209589, and
===205483.
- (3) Bioassays for workers 314319, 314289, 561695, and 314303.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01)===
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Gamma spectroscopy equipment and liquid scintillation counters in the chemistry count room
- (2) Tennelec automated alpha/beta counters in the RP count room
- (3) Fastscan whole body counter in dosimetry office
- (4) Portable ion chambers stored 'ready for use'
- (5) Portable telepoles stored 'ready for use'
- (6) Portable neutron survey meters stored 'ready for use'
- (7) Personnel contamination monitors at the RCA exit
- (8) Portal monitors at the RCA exit
- (9) Small article monitors at the RCA exit
- (10) Area radiation monitors in the radwaste building and Unit 1 reactor building
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Enrad number 13851, Argos personnel contamination monitor, 05/24/2023 and 05/14/2024
- (2) Enrad number 13593, Chronos small article monitor, 05/24/2023 and 05/14/2024
- (3) Enrad number 13591, Gem-5 portal monitor, 05/24/2023 and 05/14/2024
- (4) BNPFS1, Fastscan whole body counter, 11/15/24
- (5) High-purity germanium detector number 1, 08/24/2024 (6)1-1, Control room area radiation monitor, 06/03/2023
- (7) Unit 2 drywell high range area radiation monitors, channels 4195, 4196, 4197, 4198, 02/15/2023
- (8) A256FE, Electronic dosimeter, 11/14/2024
- (9) TN-06, Tennelec alpha/beta counter, 12/12/2024
- (10) Enrad number 12712, Ludlum 12-4 neutron survey meter, 10/14/2024
- (11) Enrad number 10273, Ludlum 9-3 ion chamber, 01/28/2025
- (12) Enrad number 07592, Telepole, 11/18/2024
- (13) NAI well counter, 02/20/2025
- (14) Enrad number 13020, Ludlum-177 frisker, 12/04/2024 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (3 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Main stack monitor, 02/01/2021 and 04/19/2023
- (2) Main stack monitor flow rate, 01/25/2021 and 11/16/2022
- (3) Liquid radwaste monitor, 11/17/2021 and 11/16/2023
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 (January 1 through December 31, 2024)
- (2) Unit 2 (January 1 through December 31, 2024)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 1 (January 1 through December 31, 2024)
- (2) Unit 2 (January 1 through December 31, 2024)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
- (1) Unit 1 (January 1 through December 31, 2024)
- (2) Unit 2 (January 1 through December 31, 2024)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) March 8, 2024, through February 18, 2025 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) March 8, 2024, through February 18, 2025
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)4kV emergency bus degraded voltage relay failure (NCR 2505753) that resulted in a de-energization of safety-related bus E-2 and an automatic start of EDG-2
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000324,05000325/1,2-2024-002-00, Automatic Start of Emergency Diesel Generator due to Emergency Bus De-energization (ADAMS Accession No. ML24102A124). 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 nor violation of NRC requirements was identified. This LER is Closed.
INSPECTION RESULTS
Failure to Maintain Minimum Inventory of SCBA Components in Required Storage Areas Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000325,05000324/2025001-01 Open/Closed
[H.2] - Field Presence 71124.03 The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Technical Specification 5.4.1 for the licensees failure to implement procedures related to the use of respiratory protection equipment. Specifically, several self-contained breathing apparatus (SCBA) units in the main control room and technical support center (TSC) were found to be missing air bottles. Therefore, the licensee did not have the minimum number of SCBA units available for emergency use, as required by procedures.
Description:
On March 26, 2025, during a walk-down of SCBA kits stored for emergency use, the inspectors identified that three of 15 SCBA kits in the main control room and four of 10 SCBA kits in the TSC did not contain air cylinders. The inspectors also observed that there were no spare air cylinders in either of the storage areas to account for the missing cylinders. Per the licensees program, a SCBA kit is comprised of a Scott Air-Pak 4.5 and Scott carbon composite air cylinder stored in a closed plastic container with a plastic tamper seal, with Scott AV-3000 full-face masks stored in a nearby cabinet. Without air cylinders, the SCBA units cannot be used to provide respiratory protection to emergency response workers and are effectively inoperable. Licensee procedure 0E&RC-0292, SCBA Use and Maintenance," required that 15 SCBA units be available for use in the main control room and 10 units be available in the TSC. The inspectors noted that all the SCBA containers were closed, with plastic tamper seals intact, and had been recently inspected by the offsite vendor that maintains SCBA equipment for the licensee and performs monthly surveillances.
Corrective Actions: The licensee installed air cylinders in SCBA kits that were missing them and conducted a walkdown of all SCBA storage areas to assess the extent of condition.
Corrective Action References: NCR 2548919
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to have the minimum number of SCBA units available for use by emergency response workers, as required by licensee procedure, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. If SCBA kits were called upon for use in the event of an accident, several of them would have been unavailable.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix B, Emergency Preparedness SDP. The finding was determined to be of very low safety significance (Green), because it involved a degradation of radiological protection equipment used during accident conditions to protect emergency workers from internal radiation exposure. The inspectors noted that most of the required SCBA units in both locations were operable, and that the licensee has a control room emergency ventilation system that would add an additional layer of worker protection from internal exposure during a radiological emergency.
Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel.
This cross-cutting aspect was assigned because the performance deficiency stemmed directly from the licensees failure to ensure oversight of a contactors work activities.
Enforcement:
Violation: Technical Specification 5.4.1, Procedures, requires the licensee to implement the procedures recommended by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), November 1972. Regulatory Guide 1.33 recommends procedures for the use of respirator equipment. Licensee procedure 0E&RC-0292, SCBA Use and Maintenance, requires the licensee to maintain 15 SCBA units available for emergency use in the main control room and 10 units in the TSC. Contrary to this, on March 26, 2025, the licensee had 12 SCBA units available for emergency use in the main control room and six in the TSC.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Follow a Radiation Work Permit Requirement Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000325,05000324/2025001-02 Open/Closed
[H.14] -
Conservative Bias 71124.03 A self-revealed Green finding and associated Non-cited Violation (NCV) of Technical Specification 5.4.1 was identified when the licensee failed to implement radiation work permit (RWP) requirements for drywell dome removal work during the B2R27 outage. Specifically, RWP 1522 required the use of respiratory protection equipment for drywell dome removal, but face shields were used instead. As a result, five workers received unplanned intakes of radioactive material.
Description:
On February 12, 2024, during the B2R27 refueling outage, workers were removing drywell dome studs in support of drywell dome removal and reactor disassembly. This work involved the use of pneumatic tooling in a high contamination area (HCA) with removable contamination levels up to 440,000 disintegrations per minute per 100 cm2. Upon exiting the reactor cavity, six workers could not pass the gamma-sensitive portal monitors at the radiological controlled area (RCA) exit point and were instructed to report to Dosimetry for additional monitoring. Follow-up whole body counting showed low level intakes of Cobalt-60 in five of the six workers. All intakes were below licensee screening levels for the assignment of internal dose (< 10 mrem committed effective dose equivalent).
The inspectors noted that RWP 1522, Disassembly Activities, stated that powered air purifying respirators (PAPRs) will be issued to all qualified personnel for this job task, and that licensee procedure PD-RP-ALL-0001, Radiation Responsibilities, required all individuals to review, understand, and comply with RWP requirements. The as low as reasonably achievable (ALARA) plan for this work activity also required the use of PAPRs, unless an approved total effective dose equivalent (TEDE)-ALARA evaluation determined that respirators were not needed. Although no TEDE-ALARA evaluation was performed to justify a reduction in the level of protective gear, the workers were instructed by RP technicians to wear face shields for this activity instead of PAPRs. Interviews with licensee staff indicated that pre-job briefings for this job task did not include a discussion of past practices, such as the use of PAPRs. Furthermore, the potential for resuspension of particulate dust through the use of pneumatic equipment in an HCA was not recognized and evaluated.
Corrective Actions: The licensee revised their outage refuel floor RWPs to have specific task numbers for activities requiring respiratory protection and task numbers for activities not requiring respiratory protection to reduce confusion among RP technicians and workers.
Corrective Action References: NCR 2504788
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to comply with RWP requirements, as required by licensee procedure, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to follow RWP requirements related to respiratory protection in areas with significant removable surface contamination, while using equipment that could increase the risk of airborne radioactivity, could result in unintended dose.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The finding was determined to be of very low safety significance (Green) because it did not result in an overexposure beyond regulatory limits, there was no substantial potential for overexposure, and the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. This cross-cutting aspect was assigned because the licensee displayed non-conservative decision making when they deviated from RP guidance documents and past job history and failed to account for the entire work scope.
Enforcement:
Violation: Technical Specification 5.4.1, Procedures, requires the licensee to implement the procedures recommended by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), November 1972. Regulatory Guide 1.33 recommends procedures for an RWP system. Licensee procedure PD-RP-ALL-0001, Radiation Responsibilities, requires all individuals to review, understand, and comply with RWP requirements. Licensee RWP 1522, Disassembly Activities, states that PAPRs will be issued to all qualified personnel. Contrary to this, on February 12, 2024, workers performing drywell dome disassembly activities under RWP 1522 were issued face shields instead of PAPRs.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 24, 2025, the inspectors presented the integrated inspection results to John A.
Krakuszeski and other members of the licensee staff.
- On March 18, 2025, the inspectors presented the in-service inspection results to Michael Classe and other members of the licensee staff.
- On March 27, 2025, the inspectors presented the occupational radiation safety baseline inspection results to John A. Krakuszeski and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
2461741
Corrective Action
Documents
Resulting from
Inspection
2547126
Error in BNP FAC Program Susceptibility Document
1-FP-60879
Service Water System (1-SW-ISO-26) Piping Isometric
D-02521
Reactor Building Nuclear Steam Supply System Piping
Diagram
D-02537
Reactor Building Service Water System Piping Diagram
104
D-02537
Reactor Building Service Water System Piping Diagram
FSP-02210
Service Water Buried Yard Piping 2-SW-103-30-157 East
Accessway Branch
A
Drawings
FSP-02692
Reactor Building Nuclear Boiler Steam Elev. 20'-0"
297461
Addition of a Coupling to Line 2-B21-51-2-600 and Replace
MSIV Drain Piping With High Trace Chrome Piping
Engineering
Changes
23794
Install CFRP on Buried 2-SW-103-30-157 Between SW
Intake Structure and U-2 Reactor Building
License Renewal Flow Accelerated Corrosion Aging
Management Program
BNP-PM5-001
Brunswick Nuclear Plant Unit 1 and 2 ASME Section
Program Fifth Interval Inservice Inspection Basis
FAC-BNP-
1610.001
U1 & U2 Brunswick Flow Accelerated Corrosion Program
System Susceptibility Analysis and Erosion Program
Development
Miscellaneous
Specification 248-
117
Installation of Piping Systems
0PT-20.5.1
Primary Containment Inspection
2/28/2023
BNP-PM5-002-
B2R26-RPT (Part
3)
Underwater Construction Company (UCC) SC Torus
Subsurface Examination Final Report
NDE Reports
VE-25-002
B2-01280
03/14/2025
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-EG-ALL-1610
Flow Accelerated Corrosion Implementation
AD-EG-ALL-1620
Nuclear Welding Program
AD-NE-ALL-1101
Training, Qualification, and Certification of Nondestructive
Examination Personnel
AD-NE-ALL-1103
Calibration and Control of NDE Examination Equipment
EPRI-DMW-PA-1
Procedure for Manual Phased Array Ultrasonic Examination
NDE-NE-ALL-
3101
Magnetic Particle Examination
NDE-NE-ALL-
6304
Utilization of EPRI-DMW-PA-1 Procedure for Manual
Phased Array Ultrasonic Examination of Dissimilar Metal
NDE-NE-ALL-
7701
Visual Examination of Welds and Brazed Joints
WLD-EG-ALL-
20
General Welding
Procedures
WLD-EG-ALL-
1630
Nuclear Welder and Fitter Handbook
Corrective Action
Documents
- 02515294,
2518688,
2538494,
2543819,
2531278,
2534378,
2540832,
2509355, and
2538668
Various
ALARA Plans
22
Reactor Disassembly Activities
01/31/2024
Corrective Action
Documents
NCR 02548695
Missing Record
Corrective Action
Documents
Resulting from
SCBA Walkdown Deltas
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
AD-EP-BNP-0407
Emergency Facilities and Equipment
Revision 7
OE&RC-0292
SCBA Use and Maintenance
Revision 21
Procedures
PD-RP-ALL-0001
Radiation Workers Responsibilities
Revision 15
Radiation
Surveys
BNP-M-
240212-8
1R11_1RB 117' DW Dome On Reassembly
2/12/2024
Radiation Work
Permits (RWPs)
22
117' - Disassembly Activities
Revision 04
2043896703
RT, 2-VA-2B-EAF-CB: PERFORM 0PT-21.2B
3/08/2023
Work Orders
2047468410
PERFORM CREV FILTER TRAY CHANGEOUT PER 0CM-
FLT506
8/21/2022
Corrective Action
Documents
NCRs 02489321,
2510598, and
2517100
Various
Corrective Action
Documents
Resulting from
Inspection
Engineering
Evaluations
WP-RP-ALL-7017
Optimization of Calibration Frequency for Radiation
Protection Handheld Instrumentation