IR 05000324/2019002

Integrated Inspection Report 05000324/2019002 and 05000325/2019002; 07200006/2019001

ML19221B744
Person / Time
Site:	Brunswick, 07200006
Issue date:	08/09/2019
From:	Bradley Davis NRC/RGN-II/DRP/RPB4
To:	William Gideon Duke Energy Progress
References
IR 2019002
Download: ML19221B744 (37)

Text

ust 9, 2019

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2019002 AND 05000325/2019002; 07200006/2019001

Dear Mr. Gideon:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On July 25, 2019, the NRC inspectors discussed the results of this inspection with Mr. K. Moser and other members of your staff. The results of this inspection are documented in the enclosed report.

Four findings of very low safety significance (Green) are documented in this report. Four of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or 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.

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. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Bradley J. Davis, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000324 and 05000325 07200006 License Nos. DPR-62 and DPR-71

Enclosure:

Inspection Report 05000324/2019002 And 05000325/2019002; 07200006/2019001

Inspection Report

Docket Numbers: 05000324 and 05000325 07200006 License Numbers: DPR-62 and DPR-71 Report Numbers: 05000324/2019002 and 05000325/2019002 07200006/2019001 Enterprise Identifier: I-2019-002-0025 I-2019-001-0123 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant Location: Southport, NC Inspection Dates: April 1, 2019 to June 30, 2019 Inspectors: G. Smith, Senior Resident Inspector J. Steward, Senior Resident Inspector J. Diaz-Velez, Senior Health Physicist R. Kellner, Senior Health Physicist A. Nielsen, Senior Health Physicist M. Schwieg, Reactor Inspector T. Stephen, Senior Resident Inspector Approved By: Bradley J. Davis, 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 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 Inadvertent Start of the No. 1 Emergency Diesel Generator (EDG)

Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.13 Systems NCV 05000324,05000325/2019002-01 Management Closed A self-revealed Green NCV of TS 5.4.1a, was identified for the licensees failure to implement the procedural guidance associated with maintenance on the No. 1 emergency diesel generator (EDG-1).

Failure to periodically calibrate radiation monitoring equipment.

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.3] - Change 71124.05 Radiation Safety NCV 05000324,05000325/2019002-02 Management Closed The inspectors identified a Green NCV of 10 CFR 20.1501(c) for failure to periodically calibrate area radiation monitoring equipment used to perform dose rate measurements.

Specifically, on or around July 13, 2017, the licensee discontinued periodic calibrations of 52 Area Radiation Monitors (ARMs) distributed throughout the plant and began operating them in a run-to-failure mode.

Inadequate Procedure Resulted in Inoperable Safety Relief Valves Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - Resources 71153 Systems NCV 05000324,05000325/2019002-03 Closed A self-revealed Green non-cited violation (NCV) of TS 3.4.3, Safety/Relief Valves (SRVs),

was identified when the licensee discovered two of the 11 safety relief valves (SRVs) as-found lift set points were outside of the +/- 3 percent pressure band required for their operability.

Unit 1 Reactor Coolant System Leak Due to Reference Leg Failure Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green None (NPP) 71153 NCV 05000324,05000325/2019002-04 Closed A self-revealed Green NCV of 10 CFR Part 50 Appendix B, Criterion III, design control, was identified for the licensees failure to adequately address material incompatibilities of Titanium-Nickel (TiNi) couplings located in a hydrogen environment.

Additional Tracking Items Type Issue Number Title Report Status Section LER 05000324,05000325/ LER 2018-003-00 for Brunswick 71153 Closed 2018-003-00 Steam Electric Plant, Unit No. 1,

Setpoint Drift in Main Steam Line Safety/Relief Valves Results in Two Valves Inoperable.

PLANT STATUS

Unit 1 began the inspection period in Mode 4 following a leak from the 'B' train reference leg which necessitated a plant shutdown on March 28, 2019. On April 10, following leak repairs, Unit 1 was taken critical and ultimately reached 100 percent rated thermal power (RTP) on April 13, where it continued to operate until April 21 when the unit experienced an automatic scram due to a false high RCS level indication. Following investigation of the reactor scram and venting of the level transmitters, the unit was returned to 100 percent RTP on April 23 where it continued to operate until June 19, when power was reduced to 50 percent RTP to perform power suppression testing to locate a leaking fuel assembly. Following power suppression testing, the unit was restored to 100 percent RTP where it continued to operate for the remainder of the inspection period.

Unit 2 began the inspection period in Mode 4 due to an ongoing refueling outage that was commenced on March 2. On April 11, the Unit 2 reactor was taken critical and synched to the grid on April 13. Power ascension and startup testing continued until April 17 when the unit reached 95 percent RTP. Unit 2 remained at 95 percent RTP until April 20 due to limitations associated with the condensate demineralization trains. On April 21, power was reduced to repairs to the 5B feed water heater as a result of a steam leak. Following repairs to the 5B feed water heater, the unit was restored to 100 percent RTP on April 28 where it continued to operate until May 6 when power was reduced to 80 percent RTP due to a fire in the 2B heater drain pump. Following swapping of heater drain pumps, the unit was restored to 100 RTP percent on May 7, where it continued to essentially operate for the remainder 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 plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.01 - Adverse Weather Protection Summer Readiness Sample (IP Section 03.01)

(1) The inspectors evaluated summer readiness of offsite and alternate alternating current (AC) power systems. This evaluation included a tour of the switchyard and transformer areas.

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Emergency diesel generator (EDG)-2 while EDG-1 was out of service (OOS) for a planned maintenance outage on May 10

(2) Unit 1 A train standby gas treatment (SBGT) while B train SBGT was OOS for planned maintenance on June 3

(3) Unit 1 'B' conventional service water (CSW) train and the Unit 1 nuclear service water (NSW) train while the Unit 1 'A' CSW pump was being replaced on June 18

(4) Unit 1 'B' residual heat removal (RHR) train while Unit 1 'A' RHR train was OOS for a planned maintenance outage on June 27

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1 Reactor Building High Pressure Coolant Injection Room (-17 elevation) on April 16

(2) Unit 2 Cable Spreading Room and Unit 2 'B' Battery Room (23 elevation) on April 17

(3) Unit 1 Reactor Building North RHR Pump Room (-17 elevation) on June 25

(4) Unit 1 Reactor Building South RHR Pump Room (-17 elevation) on June 25

71111.06 - Flood Protection Measures Inspection Activities - Underground Cables (IP Section 02.02c.)

The inspectors evaluated cable submergence protection in:

(1) Cable vaults 2-MH-6NW, 2-MH-WTI, and 2-MH-WT3

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) The inspectors observed and evaluated licensed operator performance in the main control room during the Unit 2 reactor startup and approach to criticality on April 11

(2) The inspectors observed and evaluated licensed operator performance in the Control Room during power suppression testing on June 21

(3) The inspectors observed and evaluated licensed operator performance in the Control Room during a Unit 1 down power and rod pattern adjustment on June 27 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated the Cycle 2 licensed operator re-qualification simulator exam on May 16. This exam included an inadvertent initiation of reactor core isolation cooling (RCIC), a stuck open relief valve, and an anticipated transient without scram

71111.12 - Maintenance Effectiveness Quality Control (IP Section 02.02)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) The inspectors reviewed Engineering Change (EC) #413668 to verify that commercial grade dedication activities were performed in accordance with NRC regulations. This EC provided the commercial grade dedication requirements for Pomona Model 72920 panel mount IEC1010 jacks for sheathed plugs. These test jacks are used in a variety of safety related applications. This commercial grade dedication review was also performed in accordance with IP 43004, Inspection of Commercial Grade Dedication.

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Yellow Shutdown Risk due to a Unit 2 freeze seal established to enable replacement of a Cryofit coupling on April 10

(2) Elevated Risk due to EDG-1 wholesale bearing change out on May 10

(3) Emergent Failure of Unit 2 'B' traveling screen on May 30

(4) Emergent Failure of Unit 2 high pressure coolant injection (HPCI) pump on June 12

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) CR 2268627: EDG-4 Auto Voltage Regulator not functioning properly

(2) CR 2269293/2196953: Two SRVs lifted during Unit 1 reactor scram

(3) CR 2271117: Excessive air from core spray (CS) high point vent

(4) CR 2273196: Water intrusion into Unit 2 RCIC pump

71111.19 - Post-Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests (PMT):

(1) 0PT-80.5, Mid-Cycle Maintenance Outage Reactor Pressure Vessel Pressure Test, Rev. 7, following replacement of several Cryofit couplings on Unit 1

(2) 0PT-09.2, HPCI System Operability Test, Rev. 152 following replacement of Unit 2 Electronic Governor Remote (EGR) Servo valve

(3) 1PT-24.1-1, Service Water Pump and Discharge Valve Operability Test, Unit 1 A CSW pump replacement

(4) 0PT-12.2A, No. 1 Diesel Generator Monthly Load Test, following EDG-1 bearing replacement

==71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (2 Samples 1 Partial)

(1) The inspectors evaluated a Unit 1 forced outage due to a reactor coolant system leak from the beginning of the inspection period to April 10 (2) (Partial) The inspectors completed an evaluation of the Unit 2 refueling outage, B2R24, from the beginning of the inspection period to April 12

(3) The inspectors evaluated a Unit 1 forced outage due to an automatic reactor scram from April 21 to April 27

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

In-service Testing (IP Section 03.01)==

(1) 0PT-09.2, HPCI System Operability Test, Rev. 152 on June 13

(2) 0PT-07.2.4B, Core Spray Operability Test - Loop B, Rev. 85 on May 2

(3) 1PT-24.1-1, Service Water Pump Operability Test, Rev. 94 on June 28

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) 0OI-02.3, Drywell Leakage Control, Rev. 7 due to elevated RCS leakage on June 24

71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02)

The inspectors evaluated:

(1) The inspectors evaluated a simulator-based licensed operator requalification training evolution contributing to the Drill and Exercise Performance (DEP) NRC performance indicator (PI) involving an anticipated transient without scram on May 16,

RADIATION SAFETY

==71124.02 - Occupational ALARA Planning and Controls Verification of Dose Estimates and Exposure Tracking Systems (IP Section 02.02) (1 Partial)

The inspectors evaluated dose estimates and exposure tracking (1) (Partial)

The inspectors evaluated dose estimates and exposure tracking. The inspectors reviewed the following ALARA planning documents:

• ALARA Plan 2691, B2R24 Reactor Reassembly Activities, Revisions 0 and 1

• ALARA In Progress Review (Other - Prior to the start CRD exchange) and ALARA Critique, ALARA Plan 2672, CRD Activities

• ALARA In Progress Review (50%, 85%, and 93%) and ALARA Critique, ALARA Plan 2691, B2R24 Reactor Reassembly Activities

• ALARA In Progress Review (50%) and ALARA Critique, ALARA Plan 2692, Reactor Maintenance Window

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

The Inspectors evaluated the licensees performance in mitigating airborne radioactive material and use of respiratory protection equipment.

Engineering Controls (IP Section 02.01)==

The inspectors evaluated equipment used to mitigate and monitor airborne radioactivity.

Samples included the following:

(1) Installed ventilation system maintenance records

• Work Order 2019226401, Control Building Emergency Filter System Test (A Train)

• Work Order 2019252201, Control Building Emergency Filter System Test (B Train)

Temporary ventilation system maintenance records

• HEPA 1704, Filtration Seal Test, 2/23/19 Portable or installed monitoring systems

• ICAM 4565

• ICAM 11712 Use of Respiratory Protection Devices (IP Section 02.02) (1 Sample)

The inspectors evaluated the licensees use and maintenance of respiratory protection equipment. This included review of respirator qualification records, inspection of respirators ready-for-use, and the following samples:

(1) TEDE-ALARA evaluations for the use of respiratory protection equipment

• B1R22 Drywell Dome Tensioning Respiratory protection used during work activities

• None were available during this inspection Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)

The inspectors evaluated the licensees storage and maintenance of self-contained breathing apparatus (SCBA) for emergency use. This included review of SCBA qualification records and the following samples:

(1) Periodic inspection records for staged SCBAs (ready-for-use)

• SCBA Inspection Report, 12/27/18

• SCBA Inspection Report, 1/18/19 SCBA maintenance records

• SCBA 1830280, Flow Test Results, 8/10/17 and 8/2/18

• SCBA 3870026, Flow Test Results, 8/10/17 and 8/2/18

==71124.04 - Occupational Dose Assessment The inspectors evaluated the licensees performance in estimating and recording doses received by occupationally exposed workers.

Source Term Categorization (IP Section 02.01)==

(1) The inspectors evaluated the licensees characterization of their radioactive source term and the use of scaling factors to account for hard-to-detect radionuclide activity

External Dosimetry (IP Section 02.02) (1 Sample)

(1) The inspectors evaluated the licensees program for issuance, storage, and use of external dosimetry

Internal Dosimetry (IP Section 02.03) (1 Sample)

(1) The inspectors evaluated the licensees internal dosimetry program, including review of individual intake assessments and internal dose evaluations (as available). No samples can be listed due to Personally Identifiable Information (PII) restrictions.

Special Dosimetric Situations (IP Section 02.04) (1 Sample)

(1) The inspectors evaluated special dosimetric situations (as available), including dose assessments for declared pregnant workers, neutron exposure records, shallow dose assessments, and implementation of EDEX methodologies. No samples can be listed due to PII restrictions.

==71124.05 - Radiation Monitoring Instrumentation Inspectors evaluated licensees performance in the utilization and maintenance of radiation monitoring instruments that were used to monitor areas, materials and workers. Inspectors reviewed calibration records and alarm setpoints, evaluated sources for calibration and source checks, and observed a sample of daily source checks and instrumentation usage.

Walk Downs and Observations (IP Section 02.01)==

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

(1) During plant walkdowns, the inspectors evaluated and observed material condition, calibration stickers, and source check status for at least five portable survey instruments and three personnel contamination monitors. Inspectors also observed source check demonstrations on portable instrumentation. Inspectors also evaluated the use of at least five area radiation monitors and continuous air monitors.

Calibration and Testing Program (IP Section 02.02) (1 Sample)

The inspectors reviewed the calibration/testing frequency, methods and records for various types of monitoring, survey and analysis instrumentation. Inspectors reviewed results of the Inter-laboratory comparison program. Some instruments and records reviewed include but were not limited to the following:

(1) Laboratory Instruments evaluated

• 0E&RC-2173 TN-05 - Calibration and Operation of the Alpha/Beta Gas Flow Proportional Counter, cal. dates: January 17, 2019; September 21, 2018 and August 24, 2018

• 0E&RC-2173 TN-06 - Calibration and Operation of the Alpha/Beta Gas Flow Proportional Counter, cal. dates: August 10, 2018, and December 6, 2018 Whole Body Counter

• BNPFS1 APEX Invivo Extended Fastscan Counting System, cal. date:

December 6, 2017

• BNPFS1 APEX Invivo Extended Fastscan Counting System, cal. date:

December 5, 2018

• BNPFS2 APEX Invivo Extended Fastscan Counting System, cal. date:

December 6, 2017

• BNPFS2 APEX Invivo Extended Fastscan Counting System, cal. date:

December 5, 2018 Post-Accident Monitoring Instrumentation+

• Unit 2 AMI Postaccident High Range Rad Mon (WO 13528226.01), cal. date March 28, 2017

• Unit 1 AMI Postaccident High Range Rad Mon (WO 13530128.01), cal. date March 5, 2016

• Unit 1 AMI Postaccident High Range Rad Mon (WO 20105887.01), cal. date March 11, 2018

+ Unable to perform calibration observations during inspection activities Personnel contamination monitors, portal monitors and small article monitors

• CRONOS-4 ID:11652 (SN: 1211-201), cal. date: July 10, 2018

• CRONOS-4 ID:11653 (SN: 1112-233), cal. date: July 10, 2018

• CRONOS-4 ID:11523 (SN: 1112-203), cal. date: February 18, 2018

• GEM-5 ID:11650 (SN:1112-252), cal. date: November 6, 2018

• GEM-5 ID:11651 (SN:0808-142), cal. date: November 8, 2018

• ARGOS-5AB (SN:1312-5AB), cal. date: November 20, 2018

• ARGOS-5AB (SN:1312-308), cal. date: November 20, 2018 Portable survey instruments, area radiation monitors (ARMs) and continuous air monitors (CAMs)

• L-Model 177 ID:07038 (SN:276608), cal. date: August 17, 2018

• L-Model 177 ID:10386 (SN:019641), cal. date: June 8, 2018

• ROTEM Telepole ID:02710 (SN:6601-006), cal. date: December 17, 2018

• U1 TB Sampling Station ARM (WO 2038108-01), cal. date: February 17, 2019

• U1 Hot Machine Shop ARM (WO 20272253-02), cal. date: February 13, 2019

• U1 TB Breezeway ARM (WO 20272253-02), cal. date: February 13, 2019

• U2 TB Breezeway ARM (WO 1924532-01), cal. date: October 11, 2013

• iCAM ID:11712 (SN:3113), cal. date: February 19, 2019

• iCAM ID:13221 (SN: 6195), cal. date: January 7, 2019 Source check demonstration

• ROTEM Telepole ID:02710 (SN:6601-006), cal. date: December 17, 2018

• ROTEM Telepole ID:11481 (SN:6606-085), cal. date: , February 8, 2019

• L-Model 9-3 (ion chamber) ID:12978 (SN:288626), cal. date: October 25,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) Unit 1 (4/01/18-3/31/19)

(2) Unit 2 (4/01/18-3/31/19)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (4/01/18-3/31/19)

(2) Unit 2 (4/01/18-3/31/19)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (4/01/18-3/31/19)

(2) Unit 2 (4/01/18-3/31/19)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) 06/01/2018 to 04/01/2019 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) 06/01/2018 to 04/01/2019

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) The inspectors completed a review of the licensees corrective action program. This review focused on identifying any trends that might be indicative of a more significant safety issue.

===71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01) (1 Sample 1 Partial)

(1) (Partial) The inspectors evaluated the Brunswick Unit 1 declaration of a Notice of Unusual Event (NOUE) and licensees response from March 28-29, 2019.

(2) The inspectors evaluated the Brunswick's declaration of a NOUE on May 6 due to a fire in the Unit 2 B heater drain pump.

Event Report (IP Section 03.02) ===

The inspectors evaluated the following licensee event report (LER):

(1) LER 05000325/2018-003-00, Setpoint Drift in Main Steam Line Safety/Relief Valves Results in Two Valves Inoperable (ADAMS accession: ML18221A552). The circumstances surrounding this LER are documented in the Results section of this inspection report.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants

(1) The inspectors evaluated the licensees independent spent fuel storage installation (ISFSI) Unit 1 cask loading on May 30. Specifically, the inspectors observed the following activities;

• Heavy load movement of transfer cask

• Transfer and transport evolutions

• Radiological field surveys

• Toured and inspected ISFSI pad

INSPECTION RESULTS

Observation: Semi-Annual Trend Review 71152 The inspectors performed a trend analysis on the licensees corrective action program to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on equipment performance trends, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of January 2019 through June 2019, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends. Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.

The inspectors noted a negative trend with respect to reactor fuel performance. Specifically, the condition reports (CRs) below noted three separate fuel leaks for three separate fuel cycles encompassing both Unit 1 and Unit 2. Fuels leaks typically drive the licensee to suppress the affected fuel assembly by inserting the closest control rod. The flux suppression also limits rates of power increase and increases the number of rod programming changes. The inspectors discussed this negative trend with the licensee.

• CR 2078244 (Unit 1, 2016)

• CR 2176522 (Unit 2, 2018)

• CR 2276790 (Unit 1, 2019)

Inadvertent Start of the No. 1 Emergency Diesel Generator (EDG)

Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.13 Systems NCV 05000324,05000325/2019002-01 Management Closed A self-revealed Green NCV of TS 5.4.1a, was identified for the licensees failure to implement the procedural guidance associated with maintenance on the No. 1 emergency diesel generator (EDG-1).

Description:

On May 9, 2019, EDG-1 experienced an unexpected start during a planned maintenance outage. The main work activity was a wholesale change out of all the shaft journal bearings in the machine. In addition, other ancillary maintenance tasks were performed including replacement of a response time relay (RTR) under work order (WO)20133023. Task 4 of this WO tested the EDG-1 RTR where the relay was energized (cycled)from an external source. The RTR test was originally planned to be performed while control power was removed from the EDG-1 start circuit. However, due to a clearance lift during the relay testing, the control power circuit was energized and starting air was available. This action energized the relay that opened a solenoid valve that admitted starting air to the EDG-1. The starting air was placed in service as a result of lifting the clearance. After the EDG-1 was started, the operator in the field secured the machine by tripping the EDG-1 fuel racks as the emergency stop push button was effectively removed from the circuit during the relay testing.

Subsequent investigation into this event revealed that the cycling of the RTR with control power energized and starting air available led to the inadvertent start of EDG-1. Investigation also noted that the procedure used for the post maintenance test (PMT) of the RTR relay, 0PIC-TMR006A, Calibration of Allen Bradley Model 700-RTC Time Delay Unit had a prerequisite to validate that control power for the relay being tested was under a clearance. In the lead up to the relay testing, day shift technicians did note the presence of voltage in the control power circuit; however, this information was not adequately communicated to the relief maintenance crew on the night shift. The licensee ultimately noted several instances in the work control process that could have precluded this event.

Corrective Actions: The immediate corrective action was to conduct a prompt investigation response team (PIRT). This effort evaluated the human performance aspects of the event in order to gain insights on any latent weaknesses. Additionally, the PIRT reviewed the event from an organizational and programmatic aspects to gain an understanding of any process weakness embedded within the organization.

Corrective Action References: NCR 2272174

Performance Assessment:

Performance Deficiency: The licensees failure to preclude an inadvertent start of the EDG-1 during plant maintenance was a performance deficiency. Specifically, the licensee failed to adhere to a procedure-required maintenance prerequisite.

Screening: The performance deficiency (PD) was more than minor because it was associated with the configuration attribute of the Mitigating System cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the PD was associated with the shutdown configuration of the EDG-1 that resulted in an unexpected start of the diesel and had the potential to damage the machine if all required systems were not functional.

Significance: The finding was screened in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) For Findings At Power dated June 19, 2012. The finding was screened under Exhibit 2, Mitigating Systems Screening Questions, Section A, Mitigating SSCs and Functionality Since the finding: 1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), 2) did not represent a loss of system and/or function, 3) was not an actual loss of function of at least a single train for greater than its technical specification (TS) allowed outage time, and 4) did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; the finding screened to GREEN (very low safety significance).

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities.

Enforcement:

Violation: Technical Specification 5.4.1.a, Administrative Control (Procedures), stated in part, that written procedures shall be established, implemented, and maintained covering the following activities including the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972 (Safety Guide 33, November 1972). Safety Guide 33, Appendix A,Section I.1 stated, in part that maintenance that can affect the performance of safety-related equipment should be properly planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, on May 9, 2019, the licensee failed to implement adequate instructions and appropriate steps in WO 20133023 to preclude an inadvertent start of the EDG-1 during relay testing. Safety-related equipment included all the EDGs.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to periodically calibrate radiation monitoring equipment.

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.3] - Change 71124.05 Radiation Safety NCV 05000324,05000325/2019002-02 Management Closed The inspectors identified a Green NCV of 10 CFR 20.1501(c) for failure to periodically calibrate area radiation monitoring equipment used to perform dose rate measurements.

Specifically, on or around July 13, 2017, the licensee discontinued periodic calibrations of 52 Area Radiation Monitors (ARMs) distributed throughout the plant and began operating them in a run-to-failure mode.

Description:

During a review of calibration records, NRC inspectors identified that Area Radiation Monitors 2-D22-K600-2-11 and 2-D22-K600-2-9 had not been calibrated since 2012 and 2013, respectively even though the licensee had established a calibration periodicity of four years. Upon further review, the NRC inspectors identified that on June 26, 2017, the licensee initiated an Action Request (AR #02133314) to stop performing calibrations of several Area Radiation Monitors (ARMs) throughout the plant and consider operating them until a failure occurs (run-to-failure). Area Radiation Monitors are listed in the Licensees Updated Final Safety Analysis Report (UFSAR), Chapter 12, Tables 12-8 and 12-9, and are used to

(1) perform measurements of gamma radiation levels in fuel handling areas,

(2) perform measurements of gamma radiation levels in several plant buildings and spaces,

(3) detection of inadvertent or unauthorized movement of radioactive material, (4)provide information of abnormal migrations in or from process streams supplemental to process radiation monitors, and

(5) provide supplemental information to be used in preparation of radiation survey reports. The change evaluation was completed on July 13, 2017 and resulted in 52 area radiation monitors being removed from a routine calibration schedule and placed in a run-to-failure operating mode. The inspectors determined that the change was approved by the licensee without involvement of the Radiation Protection organization, and without recognizing that Area Radiation Monitors are used to perform radiological surveys as defined in 10 CFR Part 20.

Corrective Actions: The licensee entered the issue in the corrective action program requesting to reinstate the periodic calibration of affected ARMs.

Corrective Action References: Corrective Action Request #02269618

Performance Assessment:

Performance Deficiency: Failure to periodically calibrate area radiation monitoring equipment used to evaluate dose rate measurements as required by 10 CFR Part 20.

Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The finding was not related to As Low As Reasonably Achievable planning, nor did it involve an overexposure or substantial potential for overexposure, and the ability to assess dose was not compromised. Therefore, the inspectors determined the finding to be of very low safety significance (Green).

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. A cross cutting aspect in change management was identified because the licensees change process did not identify that the equipment calibration requirements of 10 CFR Part 20 were applicable to Area Radiation Monitors.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) 20.1501(c) requires in part, that the licensee ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluents) are calibrated periodically for the radiation measured.

Contrary to the above, the licensee failed to ensure that Area Radiation Monitors 2-D22-K600-2-11 and 2-D22-K600-2-9, used for quantitative radiation measurements were calibrated at the established interval (every 4 years). Specifically, Area Radiation Monitors 2-D22-K600-2-11 and 2-D22-K600-2-9 were not calibrated since 2012 and 2013, respectively. In addition, the licensee failed to ensure that 52 Area Radiation Monitors be calibrated periodically for the radiation measured. Specifically, as of July 17, 2017, the licensee discontinued the periodic calibrations of 52 Area Radiation Monitors distributed throughout the plant and began operating them in a run-to-failure mode.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Inadequate Procedure Resulted in Inoperable Safety Relief Valves Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - Resources 71153 Systems NCV 05000324,05000325/2019002-03 Closed A self-revealed Green non-cited violation (NCV) of TS 3.4.3, Safety/Relief Valves (SRVs),was identified when the licensee discovered two of the 11 safety relief valves (SRVs) as-found lift set points were outside of the +/- 3 percent pressure band required for their operability.

Description:

Licensee event report (LER) 05000325/2018-003-00 was associated with two of the 11 SRVs as-found setpoints being outside of the +/- 3 percent pressure setpoint band required for their operability. This was discovered on June 11, 2018, following as-found testing results conducted on all 11 SRVs that were removed during the refueling outage. The licensee determined that the out of tolerance lift pressure of the two SRV pilot discs was due to corrosion bonding of the pilot disc to the valve seat. The licensee determined that these two SRVs were inoperable for an indeterminate period of time from March 23, 2016, when the unit entered Mode 2 (beginning of operating cycle) to March 3, 2018, when the unit entered Mode 4 (beginning of refueling outage). The inspectors reviewed the licensee event report and determined that the report adequately documented the summary of the event including the cause and potential safety consequences.

Corrective Actions: The licensee replaced all eleven of the Unit 1 SRV pilot valves with refurbished valves during the Spring 2018 Unit 1 refueling outage. Corrective actions have been completed which included revised procedures and work instructions to ensure a more consistent surface preparation and proper quality checks of SRV pilot disc surface conditions prior to applying the platinum coating. Additionally, the licensee is part of the industry-led boiling water reactors owners group which is researching several new corrective actions aimed to eliminate the SRV setpoint drift issue due to corrosion bonding of the pilot valves.

Corrective Action References: NCR 2212540

Performance Assessment:

Performance Deficiency: Failure to provide an adequate procedure and work instructions with sufficient detail to ensure consistent pilot valve surface preparation prior to platinum coating was the Performance Deficiency. Specifically, the inadequate procedure led to a degraded platinum coating on the pilot valve seating surfaces that allowed corrosion bonding of the SRV pilot discs to pilot seats which resulted in the out of tolerance lift setpoints of the two SRVs.

Screening: The performance deficiency (PD) was more than minor because it affected the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Significance: The significance of this finding was evaluated using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012.

This finding was determined to be Green, very low safety significance, because all of the associated mitigating systems screening questions were answered No. Additionally, the licensees Cycle 21 reload safety analysis report determined that the SRVs remained capable of performing their safety function to prevent over-pressurization of the reactor coolant system (RCS).

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The inspectors determined the finding had a cross-cutting aspect of Resources in the Human Performance area because adequate procedures and work instructions were not provided to ensure an adequate application of the platinum coating of the SRV pilot valve seats.

Enforcement:

Violation: Brunswick Steam Electric Plant, Unit 1 Limiting Condition of Operation (LCO) 3.4.3, Safety/Relief Valves (SRVs) required the safety function of ten

(10) SRVs shall be operable in Modes 1, 2 and 3. When the LCO was not met, Condition A was applicable which required that with one or more required SRVs inoperable, that the unit be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Contrary to the above, two required SRVs were inoperable from March 23, 2016, to March 3, 2018, and Unit 1 was not placed in Mode 3 and Mode 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, respectively.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Unit 1 Reactor Coolant System Leak Due to Reference Leg Failure Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green None (NPP) 71153 NCV 05000324,05000325/2019002-04 Closed A self-revealed Green NCV of 10 CFR Part 50 Appendix B, Criterion III, design control, was identified for the licensees failure to adequately address material incompatibilities of Titanium-Nickel (TiNi) couplings located in a hydrogen environment.

Description:

On March 28, 2019, at 1419, the Unit 1 control room operators received a feed water (FW) control system trouble alarm and noted that the channel B reactor coolant system (RCS) level channel B (N004B) had failed high. Since the A channel was selected as the control channel, no effect was seen on FW or any anomalies noted in RCS level. The operators also noted an almost simultaneous increase in drywell pressure. The operators entered 0AOP-14.0, Abnormal Primary Containment Conditions, and began venting the drywell. The operators also noticed several other failed RCS level instruments, all located in the division II or B train and thus diagnosed a failed reference leg that affected B train instruments. The reference leg fault was deemed to be a mechanical failure inside the drywell as there was a corresponding increase in drywell pressure due to the unisolable leak. The operators began a down power at 1427 to take the unit off line, in accordance with the normal operating procedure 0GP-5, Unit Shutdown. At 1442, the operators estimated the leak rate to be 53 gpm based on drywell floor drain pump out rate. The shift manager declared a notice of unusual event (NOUE) at 1450 due to the emergency action level (EAL) SU5.1, RCS leakage. EAL SU5.1 required a NOUE if RCS unidentified leakage exceeded 10 gallons per minute (gpm) for over 15 minutes. The reactor was manually scrammed at 1603 with the unit at 34% in accordance with the 0GP-5. On March 29, 2019 at 0238, Unit 1 entered mode 4.

Following the plant cooldown to ambient conditions, a drywell entry was made where it was discovered that the B train reference leg exhibited a guillotine shear at a coupling connection. Upon discovery of the condition, the licensee formulated a full root cause team to analyze the coupling failure. At the time of the coupling failure, Unit 2 was undergoing a refueling outage. The root cause team initially focused their efforts on the extent of condition which included Unit 2. The licensee determined the root cause to be hydrogen embrittlement of the TiNi coupling. The extent of condition noted that there were 705 couplings installed in Unit 1 and 730 couplings in Unit 2. The licensees root cause required all couplings exposed to a high pressure steam and hydrogen environment be removed. Following removal of designated couplings, Unit 1 was turned to service on April 10 and Unit 2 was returned to service on April 13.

This particular coupling was manufactured by Raychem Inc. with a trade name of Cryofit. The Cryofit coupling was made of TiNi and installed using a cryogenic process. These couplings were installed in the late 1980s at Brunswick. The inspectors noted that the NRC issued IN 91-87 in Dec 1991 to alert addressees of possible hydrogen embrittlement of Raychem Cryofit Couplings that could result in failure. Specifically, at Seabrook Station in July 1991, the licensee measured unidentified leakage rate greater than 1.0 gpm (TS limit), while at 100% power. The source of the leakage was in the gas space sampling line from the pressurizer and was caused by a guillotine break at the midpoint of a Raychem Cryofit coupling. The cause of the failure was hydrogen embrittlement of the TiNi (exposed to a high hydrogen environment in conjunction with a high pressure and temperature environment). At the time of the IN review, the licensee deemed the Seabrook event to be not related as Seabrook operated at higher pressure and hydrogen concentration than Brunswick.

Corrective Actions: The licensee performed a full root cause on this event in order to fully understand the issue as well as the extent of condition. Corrective actions included the removal of all couplings exposed to a high pressure steam and hydrogen environment. In all, 15 couplings were cut out on Unit 1 and five were cut out on Unit 2. The Cryofit couplings were ultimately replaced with a welded connection.

Corrective Action References: NCR 2265623

Performance Assessment:

Performance Deficiency: The licensees failure to ensure material compatibility of the Cryofit coupling used within a hydrogen environment was a performance deficiency.

Screening: The performance deficiency (PD) was more than minor because it was associated with the design control attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that could upset plant stability and challenge critical safety functions during power operations. Specifically, the PD resulted in an unisolable RCS leak.

Significance: The finding was screened in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) For Findings At Power dated June 19, 2012. The finding was screened under Exhibit 1, Initiating Events Screening Questions, Section A, Mitigating SSCs and Functionality. Under the loss of coolant accident (LOCA) initiators category, the finding: 1) did not result in exceeding the RCS leak rate for a small LOCA and 2) did not affect other systems used to mitigate a LOCA resulting in a total loss of their function (e.g., Interfacing System LOCA). Specifically, the leak was within the capacity of the normal makeup system and thus not considered a small LOCA. Based on the fact that the finding did not adversely affect the LOCA initiator, the finding screened to GREEN (very low safety significance).

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III, requires in part that measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.

Contrary to the above, from sometime in the late 1980s to March 28, 2019, the licensee failed to establish measures for the selection and review of suitability of the TiNi couplings in hydrogen environments, where the coupling was required to operate. The material incompatibility resulted in a mechanical failure of the Cryofit coupling which caused an unisolable leak within the RCS. The coupling was installed in the safety-related B train reference leg of the RCS level instrumentation system.

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 July 25, 2019, the inspectors presented the integrated inspection results to Mr. K. Moser, plant manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures CSD-EG-ALL- Nuclear Switchyard Interface Agreement Revision 1

2000.1

71111.01 Procedures CSD-EG-ALL- Nuclear Switchyard Operating Guidelines Revision 4

2000.2

71111.01 Procedures NGGM-IA-0003 NGG Interface Agreement Revision 11

71111.04 Procedures 0OP-50.1 Diesel Generator Emergency Power System Operating Revision 96

Procedure

71111.04 Procedures 1OP-10 Standby Gas Treatment System Operating Procedure Revision 68

71111.04 Procedures 1OP-17 Residual Heat Removal System Operating Procedure Revision 134

71111.04 Procedures 1OP-43 Service Water System Operating Procedure Revision 136

71111.04 Procedures SD-10 Standby Gas Treatment System Revision 8

71111.04 Procedures SD-17 Residual Heat Removal System Revision 20

71111.04 Procedures SD-39 Emergency Diesel Generators Revision 22

71111.04 Procedures SD-43 Service Water System Revision 27

71111.05Q Fire Plans AD-EG-ALL-1532 NFPA 805 Pre-Fire Plans Revision 1

71111.05Q Fire Plans CSD-BNP-PFP- Control Building Pre-fire Plans Revision 5

0CB

71111.05Q Fire Plans CSD-BNP-PFP- Reactor Building Pre-Fire Plans Revision 1

1RB

71111.05Q Procedures 0ASSD-00 Users Guide Revision 45

71111.05Q Procedures 0ASSD-01 Alternate Safe Shutdown Procedure Index Revision 41

71111.05Q Procedures 0PFP-013 General Fire Plan Revision 54

71111.05Q Procedures 0PLP-01.2 Fire Protection System Operability, Action, and Surveillance Revision 51

Requirements

71111.05Q Procedures AD-EG-ALL-1520 Transient Combustible Control Revision 11

71111.06 Procedures 0SMP-CBL012 Tan Delta Testing of Wetted Cables 6

71111.06 Procedures AD-EG-ALL-1615 Cable Aging Management Program - Implementation 1

71111.11Q Miscellaneous LORX-207 Simulator Exercise Guide - Inadvertent RCIC Initiation, 1

Stuck Open Relief Valve, and ATWS

71111.12 Engineering EC 413668 Commercial Grade Item - Test Jack 0

Changes

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.12 Procedures AD-EG-ALL-1103 Procurement Engineering Products 4

71111.12 Procedures AD-EG-ALL-1210 Maintenance Rule Program 1

71111.13 Procedures 0AP-025 BNP Integrated Scheduling 57

71111.13 Procedures AD-OP-ALL-0201 Protected Equipment 5

71111.13 Procedures AD-WC-ALL-0200 Online Work Management 13

71111.13 Procedures AD-WC-ALL-0250 Work Implementation and Completion 9

71111.13 Procedures AD-WC-ALL-0410 Work Activity Integrated Risk Management 7

71111.15 Procedures AD-OP-ALL-0105 Operability Determinations and Functionality Assessments 4

71111.19 Engineering 400467 SW Pump Replacement Installation Rev. 10

Changes

71111.19 Procedures 0PT-09.2 HPCI System Operability Test Rev. 152

71111.19 Procedures 0PT-09.2 HPCI System Operability Test Rev. 152

71111.19 Procedures 1PT-24.1-1 Service Water Pump and Discharge Valve Operability Test Rev. 94

71111.19 Procedures 1PT-24.1-1 Service Water Pump and Discharge Valve Operability Test Rev. 94

71111.19 Work Orders 13458094

71111.19 Work Orders 20177462

71111.19 Work Orders 20335061

71111.19 Work Orders 20335159

71111.20 Procedures 0GP-02 Approach to Criticality and Pressurization of the Reactor 115

71111.20 Procedures 0GP-05 Unit Shutdown 180

71111.20 Procedures 0GP-06 Cold Shutdown to Refueling (Head Unbolted) 45

71114.06 Procedures 0PEP-02.1.1 Emergency Control - Unusual Event, Alert, Site Area 31

Emergency and General

Emergency

71114.06 Procedures AD-EP-ALL-0101 Emergency Classification 1

71124.02 Miscellaneous Brunswick 05/14/2019

Nuclear Plant

(BNP), Unit 2,

Refueling Outage

B2R24 Exposure

Summary

71124.02 Miscellaneous Summary - 05/15/2015

Inspection Type Designation Description or Title Revision or

Procedure Date

Robotic Cavity

Cleaning with

Rolls Royce

71124.03 Calculations TEDE-ALARA 1R22 Drywell Dome Tensioning 4/1/18

Evaluation

71124.03 Calibration HEPA Unit 1704 HEPA Filtration Seal Test 2/23/19

Records

71124.03 Calibration SCBA Unit Functional Test - Flow Check 8/10/17 and

Records 1830280 8/2/18

71124.03 Calibration SCBA Unit Functional Test - Flow Check 8/10/17 and

Records 3870026 8/2/18

71124.03 Corrective Action Condition Report

Documents 02266918

Resulting from

Inspection

71124.03 Miscellaneous Breathing Air Test Analyses of Plant Air Systems and Compressed Air for 12/6/18

Records SCBA

71124.03 Miscellaneous Inspection SCBA Inspection 1/18/19

Certificate

71124.03 Procedures 0E&RC-0220 Respiratory Protection Program Rev. 51

71124.03 Procedures 0E&RC-0229 Control and Use of HEPA Air Filtration Units Rev. 11

71124.03 Procedures 0E&RC-0292 SCBA Use and Maintenance Rev. 19

71124.03 Procedures 0PEP-04.6 Radiological Emergency Kit Inventories Rev. 35

71124.03 Radiation BNP-M- U2 HPCI Room

Surveys 20170323-11

71124.03 Radiation Work 2535 BOP & RB - Mechanical PM & CM Activities Excluding Rev. 5

Permits (RWPs) Drywell

71124.03 Work Orders 2019226401 Control Building Emergency Recirculation Air Filtration 6/11/18

System Test - U2 A Train

71124.03 Work Orders 2019252201 Control Building Emergency Recirculation Air Filtration 8/28/18

System Test - U2 B Train

71124.04 Calculations 2018 Alpha Rev. 2

Characterization

71124.04 Calculations GEL Laboratories Tritium Bioassay - Nuclear Divers 3/11/19

Inspection Type Designation Description or Title Revision or

Procedure Date

Certificate of

Analysis

71124.04 Calculations RWP 2503 Non-uniform Radiation Field Task Evaluation Form 3/9/17

71124.04 Calculations RWP 2535 Intake Assessment 4/5/17

71124.04 Corrective Action Condition Report

Documents 02111278

71124.04 Corrective Action Condition Report

Documents 02195622

71124.04 Miscellaneous NVLAP Certificate Duke Energy Dosimetry Laboratory 4/1/18 -

3/31/19

71124.04 Procedures AD-RP-ALL-2015 Alpha Radiation Characterization Rev. 3

71124.04 Procedures AD-RP-ALL-4015 Dosimetry in Gradient Radiation Fields Rev. 0

71124.04 Procedures TE-RP-ALL-4001 Declared Pregnant Worker Rev. 3

71124.05 Calibration 0E&RC-0295 Operation and Calibration of the Canberra ICAM and ICAM March 28,

Records EnRad ID: 11712 PING 2018

71124.05 Calibration 0E&RC-0295 SN: iCAM PING Calibration Record April 11,

Records 4565 2018

71124.05 Calibration 0E&RC-0295 Sn: iCAM PING Calibration Record December 2,

Records 4565 2016

71124.05 Calibration 0E&RC-2173 TN- Calibration and Operation of the Alpha/Beta Gas Flow January 17,

Records 05 Proportional Counter 2019

71124.05 Calibration 0E&RC-2173 TN- Calibration and Operation of the Alpha/Beta Gas Flow September

Records 05 Proportional Counter 21, 2018

71124.05 Calibration 0E&RC-2173 TN- Calibration and Operation of the Alpha/Beta Gas Flow August 24,

Records 05 Proportional Counter 2018

71124.05 Calibration 0E&RC-2173 TN- Calibration and Operation of the Alpha/Beta Gas Flow August 10,

Records 06 Proportional Counter 2018

71124.05 Calibration 0E&RC-2173 TN- Calibration and Operation of the Alpha/Beta Gas Flow December 6,

Records 06 Proportional Counter 2018

71124.05 Calibration 0PIC-ETU003 for U1 TB Sampling Station ARM February 17,

Records 1-D22-RM-K600- 2019

1-11, WO #2038108-01

71124.05 Calibration 0PIC-ETU003 for U1 Hot Machine Shop ARM February 13,

Inspection Type Designation Description or Title Revision or

Procedure Date

Records 1-D22-RM-K600- 2019

1-7, WO #20272253-02

71124.05 Calibration 0PIC-ETU003 for U1 TB Breezeway ARM February 13,

Records 1-D22-RM-K600- 2019

1-9, WO #20272253-02

71124.05 Calibration 0PIC-ETU003 for U2 TB Breezeway ARM October 11,

Records 2-D22-RM-K600- 2013

2-9, WO #1924532-01

71124.05 Calibration 0PIC-RE004 for U1 TB Sampling Station ARM February 17,

Records 1-D22-RE-N001- 2019

1-11, WO #2038108-01

71124.05 Calibration 0PIC-RE004 for U1 Hot Machine Shop ARM February 13,

Records 1-D22-RE-N002- 2019

1-7, WO #20272253-02

71124.05 Calibration 0PIC-REU004 for U1 TB Breezeway ARM February 13,

Records 1-D22-RE-N001- 2019

1-9, WO #20272253-02

71124.05 Calibration BNP ID: 11R009 Co-60 Gamma Standard November 9,

Records 2011

71124.05 Calibration BNP ID: 11R010 Co-60 Gamma Standard November 9,

Records 2011

71124.05 Calibration BNP ID: 14R004 Cs-137 Gamma Standard March 10,

Records 2014

71124.05 Calibration BNP ID: 15R001 Tc-99 Beta Wide Area Reference Source October 7,

Records 2014

71124.05 Calibration BNP ID: 15R002 Tc-99 Beta Wide Area Reference Source October 7,

Records 2014

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Calibration BNP ID: 15R004 Tc-99 Beta Wide Area Reference Source October 7,

Records 2014

71124.05 Calibration BNPFS1 BNPFS1, APEX Invivo Extended Fastscan Counting System December 6,

Records Calibration 2017

71124.05 Calibration BNPFS1 BNPFS1, APEX Invivo Extended Fastscan Counting System December 5,

Records Calibration 2018

71124.05 Calibration BNPFS2 BNPFS2, APEX Invivo Extended Fastscan Counting System December 6,

Records Calibration 2017

71124.05 Calibration BNPFS2 BNPFS2, APEX Invivo Extended Fastscan Counting System December 5,

Records Calibration 2018

71124.05 Calibration C91-070, Am-241 Certificate of Calibration October 30,

Records 47mm Simulated 1990

Filter in Aluminum

Planchet

(Standard

Radionuclide

Source)

71124.05 Calibration C95-027, 43mm Certificate of Calibration May 4, 1995

Records Tc-99 Simulated

Filter in Aluminum

Planchet

(Standard

Radionuclide

Source)

71124.05 Calibration EnRad ID: 02246, ROTEM Telepole (Out of Service, Broken, Instrument lost March 13,

Records Sn: 6605-097 for over a year)) 2018

71124.05 Calibration EnRad ID: 02710, Certificate of Calibration (ROTEM Telepole) December

Records Sn:6601-006 17, 2018

71124.05 Calibration EnRad ID: 03523, Certificate of Calibration (L-3030P Smear Counter) September

Records Sn: 275380 19, 2018

71124.05 Calibration EnRad ID: 07038, Certificate of Calibration (L-177) August 17,

Records Sn: 276608 2018

71124.05 Calibration EnRad ID: 10386, Certificate of Calibration (L-177) June 8, 2018

Records Sn: 19641

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Calibration EnRad ID: 11481, Certificate of Calibration (ROTEM Telepole) February 8,

Records Sn: 6606-085 2019

71124.05 Calibration EnRad ID: 11523, Certificate of Calibration (CRONOS-4) February 18,

Records Sn: 1211-203 2019

71124.05 Calibration EnRad ID: 11556 Verification of the Calibration of the Hopwell BX3 Calibrator February 25,

Records 2019

71124.05 Calibration EnRad ID: 11650, Certificate of Calibration (GEM-5) November 6,

Records Sn: 1112-252 2018

71124.05 Calibration EnRad ID: 11651, Certificate of Calibration (GEM-5) November 8,

Records Sn: 0808-142 2018

71124.05 Calibration EnRad ID: 11652, Certificate of Calibration (CRONOS-4) July 10,

Records Sn: 1211-201 2018

71124.05 Calibration EnRad ID: 11653, Certificate of Calibration (CRONOS-4) July 10,

Records Sn: 1112-233 2018

71124.05 Calibration EnRad ID: 11712, Certificate of Calibration (ICAM) February 19,

Records Sn: 3113 2019

71124.05 Calibration EnRad ID: 11787 Verification of the Calibration of the

J.L. Shepherd Model 89 February 25,

Records Calibrator 2019

71124.05 Calibration EnRad ID: 12308, Certificate of Calibration (ARGOS-5AB) November

Records Sn: 1312-5AB 20, 2018

71124.05 Calibration EnRad ID: 12309, Certificate of Calibration (ARGOS-5AB) November

Records Sn: 1312-308 20, 2018

71124.05 Calibration EnRad ID: 12978, Certificate of Calibration (L-9-3) October 25,

Records Sn: 288626 2018

71124.05 Calibration EnRad ID: 13099, Certificate of Calibration (L-177) September

Records Sn: 312581 6, 2019

71124.05 Calibration EnRad: ID 13221, Certificate of Calibration January 7,

Records Sn: 6195 2019

71124.05 Calibration Exradin Model: Report of Calibration for Ionization Chamber July 27,

Records A3, Sn: 2017

XR152091

71124.05 Calibration Exradin Model: Report of Calibration for Ionization Chamber July 27,

Records A5, Sn: 2017

XY150093

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Calibration Exradin Model: Report of Calibration for Ionization Chamber July 27,

Records A6, Sn: 2017

XQ152603

71124.05 Calibration L-2241, Sn: Sn: 274064 (Detector Model 43-92-Alpha Detector, Sn: October 31,

Records 274064 PR300309) 2017

71124.05 Calibration L-2241, Sn: Sn: 274064 (Detector Model 43-92-Alpha Detector, Sn: December

Records 274064 PR300309) 19, 2018

71124.05 Calibration L-2241, Sn: Sn: 279845 (Detector Model 43-92-Alpha Detector, Sn: October 31,

Records 279845 PR300311) 2017

71124.05 Calibration L-2241, Sn: Sn: 315596 (Detector Model 43-92-Alpha Detector, Sn: October 31,

Records 315596 PR346186) 2017

71124.05 Calibration L-2241, Sn: Sn: 315596 (Detector Model 43-92-Alpha Detector, Sn: December

Records 315596 PR346186) 19, 2018

71124.05 Calibration L-2241, Sn: Sn: 315624 (Detector Model 43-92-Alpha Detector, Sn: October 31,

Records 315624 PR346179) 2017

71124.05 Calibration L-2241, Sn: Sn: 315624 (Detector Model 43-92-Alpha Detector, Sn: December

Records 315624 PR346179) 19, 2018

71124.05 Calibration MGP Electronic Certificate of Calibration February 19,

Records Dosimeter Sn: 2019

25506

71124.05 Calibration MGP Electronic Certificate of Calibration February 20,

Records Dosimeter Sn: 2019

2916

71124.05 Calibration MGP Electronic Certificate of Calibration November

Records Dosimeter Sn: 16, 2018

891523

71124.05 Calibration Standard Imaging Report of Calibration for Electrometer July 27,

Records SuperMAX, Sn: 2017

P160264

71124.05 Calibration Victoreen 878-10, Certificate of Compliance January 14,

Records Sn: 116 2005

71124.05 Miscellaneous 1st QTR Analytics 1st QTR Results of Radiochemistry Cross Check Program March 20,

Cross Check 2017

Program

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Miscellaneous 1st QTR 1st QTR Results of Radiochemistry Cross Check Program April 16,

Radiochemistry 2018

Cross Check

Program

71124.05 Miscellaneous 2nd QTR 2nd QTR Results of Radiochemistry Cross Check Program July 6, 2017

Analytics Cross

Check Program

71124.05 Miscellaneous 2nd QTR 2nd QTR Results of Radiochemistry Cross Check Program May 11,

Radiochemistry 2018

Cross Check

Program

71124.05 Miscellaneous 3rd QTR Analytics 3rd QTR Results of Radiochemistry Cross Check Program October 19,

Cross Check 2017

Program

71124.05 Miscellaneous 3rd QTR 3rd QTR Results of Radiochemistry Cross Check Program August 10,

Radiochemistry 2018

Cross Check

Program

71124.05 Miscellaneous 4th QTR Analytics 4th QTR Results of Radiochemistry Cross Check Program January 30,

Cross Check 2018

Program

71124.05 Miscellaneous TN-05 Alpha TN-05 Alpha Source Check Control Chart April 1, 2019

Source Check

Control Chart

(1/4/2019 -

4/1/2019)

71124.05 Miscellaneous TN-05 Alpha/Bkg TN-05 Alpha/Bkg Control Chart April 1, 2019

Control Chart

(1/4/2019 -

4/1/2019)

71124.05 Miscellaneous TN-05 Beta TN-05 Beta Source Check Control Chart April 1, 2019

Source Check

Control Chart

(1/4/2019 -

Inspection Type Designation Description or Title Revision or

Procedure Date

4/1/2019)

71124.05 Miscellaneous TN-05 Beta/Bkg TN-05 Beta/Bkg Control Chart April 1, 2019

Control Chart

(1/4/2019 -

4/1/2019)

71124.05 Miscellaneous TN-05 Lab Stats TN-05 Lab Stats Pack - Logbook Entries Report April 1, 2019

Pack - Logbook

Entries Report

(10/1/2018 -

4/1/2019)

71124.05 Miscellaneous TN-05 Response TN-05 Response Data Report - Alpha Source Check April 1, 2019

Data Report -

Alpha Source

Check (1/4/2019 -

4/1/2019)

71124.05 Miscellaneous TN-05 Response TN-05 Response Data Report - Alpha/Bkg April 1, 2019

Data Report -

Alpha/Bkg

(1/4/2019 -

4/1/2019)

71124.05 Miscellaneous TN-05 Response TN-05 Response Data Report - Beta/Bkg April 1, 2019

Data Report -

Beta/Bkg

(1/4/2019 -

4/1/2019)

71124.05 Miscellaneous TN-06 Alpha TN-06 Alpha Source Check Control Chart April 1, 2019

Source Check

Control Chart

(1/4/2019 -

4/1/2019)

71124.05 Miscellaneous TN-06 Alpha/Bkg TN-06 Alpha/Bkg Control Chart April 1, 2019

Control Chart

(1/4/2019 -

4/1/2019)

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Miscellaneous TN-06 Lab Stats TN-06 Lab Stats Pack - Logbook Entries Report April 1, 2019

Pack - Logbook

Entries Report

(10/1/2018 -

4/1/2019)

71124.05 Miscellaneous TN-06 Response TN-06 Response Data Report - Alpha Source Check April 1, 2019

Data Report -

Alpha Source

Check (1/4/2019 -

4/1/2019)

71124.05 Miscellaneous TN-06 Response TN-06 Response Data Report - Alpha/Bkg April 1, 2019

Data Report -

Alpha/Bkg

(1/4/2019 -

4/1/2019)

71124.05 Procedures AD-RP-ALL-7007 APEX Invivo Whole Body Counter Calibration February 15,

2017

71124.05 Procedures EnRad-Proc-826 Calibration and Quality Assurance of Canberra Argos Rev. 006

Personnel Monitors

71124.05 Procedures EnRad-Proc-839 Calibration of Canberra Gem-5 Portal Monitor Rev. 006

71124.05 Procedures EnRad-Proc-857 Calibration and Quality Assurance of Canberra Cronos Tool Rev. 002

Equipment Monitor

71124.05 Self-Assessments 01988036 BNP Instruments Self-Assessment November

21, 2016

71124.05 Work Orders 13528226.01 Unit 2 AMI Postaccident High Range Rad Mon One Point March 28,

Cal Check 2017

71124.05 Work Orders 13530128.01 Unit 1 AMI Postaccident High Rad Mon One Point Cal March 5,

Check 2016

71124.05 Work Orders 20105887.01 Unit 1 AMI Postaccident High Range Rad Mon One Point March 11,

Cal Check 2018

71151 Corrective Action BNP Liquid

Documents Effluent Release,

Permit Number:

L-2019-

Inspection Type Designation Description or Title Revision or

Procedure Date

71151 Corrective Action Brunswick

Documents Nuclear Plant

(BNP) Gaseous

Effluent Release,

Permit Number:

G-2019-

71151 Corrective Action Electronic 06/01/2018 to 04/01/2019

Documents Dosimeter Dose

and Dose Rate

Alarm Logs

71151 Corrective Action Gamma

Documents Spectroscopy

Analysis Result,

Apex Analysis

Report, Sample

Number #####,

Salt Water

Release Tank

71151 Corrective Action Gamma

Documents Spectroscopy

Analysis Result,

Apex Analysis

Report, Sample

Number ####,

Stack - Particulate

ST - P

71151 Corrective Action Gamma

Documents Spectroscopy

Analysis Result,

Apex Analysis

Report, Sample

Number ###,

Stack - Gas ST -

G

Inspection Type Designation Description or Title Revision or

Procedure Date

71151 Corrective Action NCR 02193863,

Documents NCR 02190366,

and NCR

247729

71151 Miscellaneous Open EMS Gas Status Summary Report, Brunswick Q 1, 05/20/2019

2019

71151 Miscellaneous Open EMS Liquid Status Summary Report, Brunswick Q 1, 05/20/2019

2019

71151 Miscellaneous MSPI Availability Emergency AC Power Report 04/01/18 -

03/31/19

71151 Miscellaneous Safety System Functional Failure Report 04/01/18 -

03/31/19

71151 Miscellaneous MSPI Availability Cooling Water System Report 04/01/18 -

03/31/19

71151 Miscellaneous Brunswick Steam 04/25/2019

Electric Plant

Units 1 and 2

Annual

Radioactive

Effluent Release

Report - 2018

71151 Miscellaneous Permit Number: Brunswick Nuclear Plant (BNP) Gaseous Effluent Release 04/02/2019

G-2019-0091

71151 Miscellaneous Permit Number: BNP Liquid Effluent Release 3/23/2019

L-2019-0054

71151 Miscellaneous Sample Number Gamma Spectroscopy Analysis Result, Apex Analysis 3/23/2019

190614_1 Report, Salt Water Release Tank U1 SWRT

71151 Miscellaneous Sample Number Gamma Spectroscopy Analysis Result, Apex Analysis 04/02/2019

190685_1 Report, Stack - Gas

71151 Miscellaneous Sample Number Gamma Spectroscopy Analysis Result, Apex Analysis 04/02/2019

190685_2 Report, Stack - Particulate

71151 Miscellaneous Sample Number Gamma Spectroscopy Analysis Result, Apex Analysis 04/02/2019

190685_3 Report, Stack - Charcoal

Inspection Type Designation Description or Title Revision or

Procedure Date

71151 Miscellaneous UDO (Unusual

Dosimetry

Occurrence)

Investigation,

Number 18-0011

71152 Procedures AD-PI-ALL-0100 Corrective Action Program 21

71153 Corrective Action Post Trip Review March 28,

Documents for the Brunswick 2019

Unit 1 scram

71153 Corrective Action RCE 2212540 Safety Relief Valves' Lift Pressure Outside of Technical 08/13/2018

Documents Specification Requirements

71153 Miscellaneous ANP-3457P Brunswick Unit 1 Cycle 21 Reload Safety Analysis 0

71153 Miscellaneous Brunswick Unit 1 March 28-29,

operator and 2019

engineering logs

71153 Miscellaneous NFR Compliance March 25-31,

documentation for 2019

Brunswick Unit 1

operators

71153 Procedures 0AOP-14.0 Abnormal Primary Containment Conditions Revision 31

71153 Procedures 0CM-VSR509 Main Steam Relief Valves Target Rock Model 7567 Air 27

Operators and Pilot Assembly, Disassembly, Inspection and

Reassembly

71153 Procedures 0GP-05 Unit Shutdown Revision 190

71153 Procedures 0OI-01.01 BNP Conduct of Operations Supplement Revision 97

71153 Procedures 0OI-01.06 Post Trip Review Revision 51

71153 Procedures 0OI-37.11 Transient Mitigation Guidelines Revision 6

71153 Procedures 1-APP-A-04 Annunciator Response for Panel A-04 Revision 59

71153 Procedures 1-APP-A-07 Annunciator Response for Panel A-07 Revision 55

71153 Procedures 1-APP-UA-23 Annunciator Response for Panel UA-23 Revision 81

71153 Procedures 1OP-10 Standby Gas Treatment System Operating Procedure Revision 68

71153 Procedures 1PT-01.7 Heatup/Cooldown Monitoring Revision 10

34