IR 05000325/2013008
| ML13107B403 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/15/2013 |
| From: | Vias S J NRC/RGN-II/DRS/EB3 |
| To: | Annacone M J Carolina Power & Light Co |
| References | |
| IR-13-008 | |
| Download: ML13107B403 (15) | |
Text
April 15, 2013
Mr. Michael Vice President Brunswick Steam Electric Plant P.O. Box 10429 Southport, NC 28461-0429
SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - U.S. NUCLEAR REGULATORY COMMISSION POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL, INSPECTION REPORT 05000324/2013008
Dear Mr. Annacone:
On March 15, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a post-approval site inspection for License Renewal at your Brunswick Steam Electric Plant, Unit 2, in accordance with NRC Inspection Procedure (IP) 71003. The enclosed inspection report documents the inspection results that were discussed with you, and other members of your staff on March 15, 2013.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed plant activities, and interviewed personnel. No findings were identified during this inspection.
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter, its Enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Steven J. Vias, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-324 License No. DPR-62
Enclosure:
NRC Post-Approval Site Inspection For License Renewal, Inspection Report 05000324/2013008
w/Attachment:
Supplemental Information
cc: (See page 3 and 4)
SUMMARY OF FINDINGS
IR 05000324/2013008; March 11 - 15, 2013; Brunswick Steam Electric Plant, Unit 2; Post- Approval Site Inspection for License Renewal, Phase 1.
The report covers an inspection conducted by two regional inspectors in accordance with NRC Manual Chapter 2515 and NRC Inspection Procedure 71003, Post-Approval Site Inspection for License Renewal. Based on the sample selected for review, the inspectors determined that commitments, license conditions, and regulatory requirements associated with the renewed facility operating license were met. The inspectors also determined that the licensee had administrative controls in place to ensure completion of pending actions scheduled both prior and during the period of extended operation (PEO).
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006. No findings were identified during this inspection.
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Other Activities
.1 Post-Approval Site Inspection for License Renewal - IP 71003 (Phase 1)
a. Inspection Scope
(1) Implementation of License Conditions and Commitments, including Aging Management Programs The inspectors reviewed a sample of license renewal activities scheduled for the Unit 2 spring 2013 refueling outage, which was the last outage prior to the period of extended operation (PEO). The inspectors selected this refueling outage because it would present the best opportunity to observe one-time inspections associated with license renewal commitments. The inspection's objective was to maximize observations of the actual implementation of license renewal activities before the beginning of the PEO (December 28, 2014), and verify that the licensee completed the necessary actions to: (a) comply with the conditions stipulated in the renewed facility operating license; (b)meet the license renewal commitments described in the NRC Safety Evaluation Report (SER) (ADAMS Accession Number ML061730123/129); and (c) meet the future inspection activities described in the Updated Final Safety Analysis Report (UFSAR) supplement submitted pursuant to 10 CFR 54.21(d). The license renewal application (LRA) for Brunswick Steam Electric Plant is documented in NUREG-1856 are publicly available on ADAMS under accession numbers ML043060411.
The inspectors reviewed supporting documents; conducted interviews with licensee staff; observed in-process outage activities; and performed visual inspection of structures, systems, and components (SSCs) including those not accessible during power operation. The commitment items and Aging Management Programs (AMPs) selected for the inspection sample are summarized below based on their description in Appendix A of the LRA. The specific inspection activities conducted for each AMP are also described below. Specific documents reviewed are listed in the report attachment.
- One-Time Inspection Program (UFSAR Chapter 18.A.1.1.15 and NRC SER Commitment Item 11) Commitment Item 11 specified that the licensee would develop and implement a One-Time Inspection Program that uses one-time inspections to verify the effectiveness of various aging management programs and confirm the absence of various aging effects. The Program scope included Water Chemistry and Fuel Oil Chemistry verifications specified by NUREG-1801, as well as plant-specific inspections where inspection results could reasonably be extrapolated through the period of extended operation. The inspectors reviewed the licensing basis, implementing procedures, engineering evaluations, personnel qualifications, and relevant condition reports in accordance with IP 71003 to verify that the one-time inspection program was conducted as stated in the commitment. The inspectors also verified that for those one-time inspections which were not complete at the time of the inspection, the licensee had a plan in place to complete these inspections prior to the start of the PEO. The inspectors noted that there was only one activity associated with the One-Time Inspection Program which would not be completed prior to the start of the PEO: the replacement of the core plate plugs. In a letter dated February 14, 2013, the NRC issued a SER (ADAMS Accession Number ML130037A408) accepting the licensee's revised Commitment regarding the replacement of the core plate plugs, which stated that the licensee would attempt to replace the plugs during the 2013 refueling outage, but that if any problems were encountered, the plug replacement would be completed during the 2015 refueling outage. The letter also states that operation beyond 2015 with the original core plate plugs is not justified. The LRA identified that the replacement of the core plate plugs was part of the Reactor Vessel and Internals Structural Integrity Program (Commitment Item 22). This Commitment is addressed later in this report section, however, because the replacement of the core plate plugs was being implemented and tracked as part of the One-Time Inspection Program, the activity is described here.
Commitment Item 18 specified that accessible non-environmental qualification (EQ) electrical cables and connections installed in adverse localized environments would be visually inspected at least once every 10 years with the initial inspection being completed prior to the end of the initial operating license term. These inspections would confirm that changes in ambient conditions would not lead to age-related degradation of the cable jackets and connector coverings as a result of reduced insulation resistance and subsequent electrical failure.
The inspectors reviewed the licensing basis, implementing procedures, engineering evaluations, personnel qualifications, and relevant condition reports in accordance with IP 71003, "Post-Approval Site Inspection for License Renewal," to verify that the non-EQ cable inspections performed during an on-line period in 2012 and the spring 2013 outage were implemented as stated in the commitment. Additionally, the inspectors directly observed the inspections associated with the following equipment:
- Unit 2 Condenser and Feed Water Heater Area (Room TB2-8E)
- Unit 2 Feed Water Heater 2-3A, 4A, 5A (Room TB2-13)
- Unit 2 Reactor Feed Pump 2B (Room TB2-5)
- Unit 2 Turbine Building 20' Elevation Main Hallway
- Buried Piping Program (UFSAR Chapter 18.A.1.1.17 and NRC SER Commitment Item 13) Commitment Item 13 specified that the licensee would: develop and implement procedure requirements to ensure an appropriate inspection on as-found coating and material condition is performed whenever buried piping in the scope of the program is exposed, or as a minimum, once every 10 years; add precautions concerning excavation and use of backfill to the excavation procedure to include precautions for license renewal piping; and add a requirement that coating inspections shall be performed by qualified personnel and that a coating engineer should assist in evaluation of any coating degradation noted during the inspection. These actions were intended to address loss of material due to general, pitting and crevice corrosion on buried carbon steel, stainless steel, and cast iron piping components. The inspectors reviewed the licensing basis, implementing procedures, engineering evaluations, and relevant condition reports in accordance with IP 71003 to verify that the buried pipe inspections were conducted as stated in the commitment.
Additionally, the inspectors directly observed the inspection of a portion of recently-excavated Service Water (SW) piping to verify that inspection procedures were followed and any adverse conditions found were entered in the licensee corrective action program and evaluated properly in accordance with the license renewal commitment.
- Reactor Vessel and Internals Structural Integrity Program (UFSAR Chapter 18.A.1.1.30 and NRC SER Commitment Item 22)
Commitment Item 22 specified that the licensee would enhance the existing Reactor Vessel and Internals Structural Integrity Program by: incorporating augmented inspections of the top guide; establishing inspection criteria for the VT-3 examination of the Core Shroud Repair Brackets; revising the scope of the Program described in the UFSAR Supplement to state that the Program implements the Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines listed below; and revising the scope of the Program described in the UFSAR Supplement to manage aging issues associated with the Core Spray lines and spargers, the steam dryers and feedwater spargers, the core plate plugs, and the Access Hole Cover welds.
- BWRVIP-94 BWRVIP-139 (when approved by NRC) The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection procedures to verify that the program was developed as described in the LRA and the corresponding SER. Additionally, the inspectors reviewed final examination data sheets, and portions of the corresponding digital video disks (DVDs), for the visual examinations of the reactor vessel internal components listed below, to verify that the implementation of the program was in accordance with the established procedures, and consistent with the program attributes described in the in the licensing basis documents.
- Visual Examination (VT-1) of Core Spray T Box
- Visual Examination (VT-3) of Core Spray Lower Bracket
- Flow-Accelerated Corrosion Inspection Program (UFSAR Chapter 18.A.1.1.5 and NRC SER Commitment Item 2) Commitment Item 2 specified that prior to the PEO, the Flow Accelerated Corrosion (FAC) Program would be updated to include additional components potentially susceptible to FAC. The processes in the existing FAC Program would be used to evaluate and predict the susceptibility of piping to FAC using a computer model specifically developed for FAC analysis. The FAC model would predict FAC rates in piping, and calculates the time remaining until reaching the defined critical wall thickness. The detection of wall thinning would include various examination methods such as Ultrasonic testing (UT), Radiographic testing (RT), and visual examinations. The enhanced examination methods and frequencies would be based on industry and plant specific operating experience as opposed to computer modeling.
Examinations to detect erosion, erosion-corrosion, as well as FAC, would be performed as part of the existing FAC Program on those additional components identified.
The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection and test procedures to verify that the program was developed as described in the LRA and the corresponding SER. The inspectors directly observed the UT examination of 2-MD-31-18-A-5, an 18"/10" tee in the Moisture Separator/Reheater Drains system. The inspectors also reviewed documentation associated with this inspection. The inspectors reviewed these activities to verify that the implementation of the program was in accordance with the established procedures and consistent with the program attributes described in the licensing basis documents.
- Open-Cycle Cooling Water (UFSAR Chapter 18.A.1.1.7 and NRC SER Commitment Item 4) Commitment Item 4 specified that the licensee would enhance the existing Open-Cycle Cooling Water Program by: revising the Program scope to include portions of the Service Water (SW) system credited in the Aging Management Review (including non-safety related piping); inspecting and trending degradation/aging of the Residual Heat Removal (RHR) heat exchangers using Eddy Current Testing (ET); inspecting SW pump casings using representative sample-type selection techniques; inspecting and verifying flow for various SW heat exchangers; performance testing of RHR and Emergency Diesel Generator heat exchangers.
The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection and test procedures to verify that the program was developed as described in the LRA and the corresponding SER. The inspectors also directly observed licensee personnel during the execution of the inspections listed below to verify that the implementation of the program was in accordance with the established procedures and consistent with the program attributes described in the licensing basis documents.
- Isophase Bus Duct Inspections (UFSAR Chapter 18.A.1.1.33 and NRC SER Commitment Item 25) Commitment Item 25 specified that the licensee would develop and implement a new Phase Bus Aging Management Program. This program would include: inspections of the interior of the bus enclosure; use of the Structures Monitoring Program (UFSAR Chapter 18.A.1.1.23 and NRC SER Commitment Item 16) for inspections of the external surfaces of the phase bus housing; and utilization of thermography or resistance measurement to inspect the phase bus connections. The Program would be implemented prior to the PEO, and activities described in the Program would continue during the PEO on a regular frequency as Preventative Maintenance effort.
The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection and test procedures to verify that the program was implemented as described in the LRA and the corresponding SER. Additionally, the inspectors directly observed portions of the inspections of the phase bus to verify that the implementation of the program was in accordance with the established procedures and consistent with the program attributes described in the licensing basis documents.
- ASME Section XI, Subsection IWE Program (UFSAR Section 18.A.1.1.18) There was no specific Commitment Item identified in the NRC SER associated with the existing ASME Section XI, Subsection IWE Program, however, the LRA specified that this AMP would consist of periodic visual inspections of steel containment structures. The ASME Section XI, Subsection IWE Program was established as an AMP to provide reasonable assurance that the aging effects of the steel containment liner, integral attachments, airlocks, hatches, drywell head, torus liner, downcomers, vent header, seals, gaskets, moisture barriers, and pressure retaining bolting are adequately managed such that their intended functions would be maintained during the period of extended operation.
The inspectors directly observed a portion of the general inspection of the drywell containment liner to verify that ASME Section XI, Subsection IWE requirements were met, inspection procedures were followed and that any adverse conditions identified were entered in the licensee corrective action program and evaluated properly in accordance with the Aging Management Program. (2) Review of Newly-Identified SSCs This inspection requirement will be completed during the second implementation phase of IP 71003.
(3) Review of the Description of AMPs and Time-Limited Aging Analyses (TLAAs) in the UFSAR Supplement The review of the description of AMPs and TLAAs in the UFSAR supplement submitted pursuant 10 CFR 54.21(d) will be completed during the second implementation phase of IP 71003.
(4) Review of License Renewal Commitment Changes As part of the review of license renewal commitments described in section 4OA5.1.a of this report, the inspectors reviewed license renewal commitment change documents to verify the licensee adequately evaluated, and reported when necessary, changes to regulatory commitments from the SER for license renewal in accordance with NEI 99-04 as endorsed by Regulatory Information Summary (RIS) 2000-017; changes to AMPS, TLAAs and other license renewal activities incorporated as part of the UFSAR supplement in accordance with 10 CFR 50.59; and submitted license amendment requests in accordance with 10 CFR 50.59 for changes to license conditions that were added as part of the renewed operating license. The inspectors also reviewed the licensee's procedures for commitment revision to obtain reasonable assurance that future changes to (or elimination of) license commitments would follow the guidance in NEI 99-04, and would properly evaluate, report, and approve changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59.
b. Findings and Observations
No findings were identified. The inspectors determined that the licensee met the license renewal commitments, license conditions, and applicable regulatory requirements for the inspection samples selected for review. The inspectors determined that the overall implementation of Aging Management Program activities reviewed during the Unit 2 spring 2013 refueling outage was consistent with the license renewal commitments. The inspectors also determined that the licensee had administrative controls in place to ensure completion of pending actions scheduled both prior and during the period of extended operation.
4OA6 Management Meetings
Exit Meeting Summary On March 15, 2013, the inspectors presented the inspection results to Mr. Michael J. Annacone, Site Vice President, and other members of the licensee staff.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Rich, License Renewal Implementation
- J. Lane, License Renewal Implementation
- C. Mallner, License Renewal Implementation
- W. Murray, Licensing/Regulatory Programs
LIST OF REPORT ITEMS
Opened
None
Opened and Closed
None
Closed
- None
DOCUMENTS REVIEWED
Procedures
- 0ENP-649, One Time Inspection Program, Rev 4 0PM-IPB001A, Clean, Inspect, and Megger Isophase Bus from Main Transformer to No-Load Disconnect, Rev. 2 0PT-20.5.1, Primary Containment Inspection, Rev 22
- 2PM-MEC501, Inspection Criteria for Service Water Valves, Rev. 16
- EGR-NGGC-0209, Buried Piping Program, Rev 4
- EGR-NGGC-0507, Cable Aging Management Program, Rev 3
- ESG-0007N, Cable and Connections Inspection Training Guide, Rev 4 ESG0087N, Common ESP Training Guide, Generic Letter 89-13, Rev. 1
- NDEP-0454, Digital Ultrasonic Thickness Measurement, Rev. 4
- NDEP-1012, Gridding of Components for Flow Accelerated Corrosion (FAC), Rev. 10
Work Orders
- 1295480-02, Visual Examination of B21-F013K Relief Line to Torus
- 24073-01, Replace 2-SW-V106
- 2041570-01, License Renewal, U2 On-Line Cable Inspection
Drawings
- BN-43.0.01, Service Water System, Rev. 2
- PS-P-2102-3, Turbine Bldg. Elev.70'-0" - Moisture Separator-Reheater Drains Piping, Rev. 3
Condition Reports
- AR 00327231, 2-B21-11-10-304 Degraded Wall Thickness
- AR 00594559, External Corrosion on 2-SW-103-30-157 Buried Pipe
- AR 00594854, Clarify Signature Requirements in
- EGR-NGGC-0507 Data Sheet
- AR 00594879, Training Guide Record for Cable Inspection Not Processed
- AR 00595185, Adherence to License Renewal Procedure Requirements
Other Documents
- BNP-LR-632, License Renewal Aging Management Program Description of the One-Time Inspection Program, Rev. 4
- BNP-LR-664, License Renewal Aging Management Program Description of the Electrical Cables and Connections not Subject to 10CFR50.49 Environmental Qualification Requirements Program, Rev. 1 Certificate of Qualification and Certification Summary - UT Level II (Pride)
- Certificate of Qualification and Certification Summary - UT Level II (Shelton)
- Flow Assisted Corrosion Test Data Sheet - 2MD31-15L UT Analysis Report - 2MD31-15L UT Analysis Report - 2MD31-15L-BR
- UT Analysis Report - 2MD31-15L-DS
- Vision Acuity Certification (Pride)
- Vision Acuity Certification (Shelton)