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Category:Letter type:BSEP
MONTHYEARBSEP 19-0012, Submittal of 2018 Sea Turtle Annual Report2019-01-17017 January 2019 Submittal of 2018 Sea Turtle Annual Report BSEP 18-0052, Annual Radiological Environmental Operating Report - 20172018-05-10010 May 2018 Annual Radiological Environmental Operating Report - 2017 BSEP 18-0051, Annual Radioactive Effluent Release Report - 20172018-04-26026 April 2018 Annual Radioactive Effluent Release Report - 2017 BSEP 18-0045, Request for License Amendment: Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time2018-04-25025 April 2018 Request for License Amendment: Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time BSEP 18-0054, Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential.2018-04-24024 April 2018 Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential. BSEP 18-0048, Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations2018-04-11011 April 2018 Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations BSEP 18-0044, Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D2018-04-11011 April 2018 Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D BSEP 18-0046, Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2018-04-10010 April 2018 Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0047, Supplement to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for End of Interval Leakage Test2018-04-0505 April 2018 Supplement to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for End of Interval Leakage Test BSEP 18-0041, Request for License Amendment to Revise the Technical Specifications to Relocate the Pressure-Temperature Limit Curves to a Pressure and Temperature Limits Report2018-04-0404 April 2018 Request for License Amendment to Revise the Technical Specifications to Relocate the Pressure-Temperature Limit Curves to a Pressure and Temperature Limits Report BSEP 18-0043, Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D2018-03-31031 March 2018 Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D BSEP 18-0035, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-29029 March 2018 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0042, Cycle 22 Core Operating Limits Report (COLR)2018-03-27027 March 2018 Cycle 22 Core Operating Limits Report (COLR) BSEP 18-0040, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test2018-03-23023 March 2018 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test BSEP 18-0039, Proposed In-Service Inspection Alternative for Application of Dissimilar Metal Weld Full Structural Overlay - Nozzles N4A and N4D2018-03-19019 March 2018 Proposed In-Service Inspection Alternative for Application of Dissimilar Metal Weld Full Structural Overlay - Nozzles N4A and N4D BSEP 18-0034, Corrected Affidavit Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-16016 March 2018 Corrected Affidavit Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0032, Additional Testing Information Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-14014 March 2018 Additional Testing Information Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0026, Additional Information Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination2018-03-0707 March 2018 Additional Information Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination BSEP 18-0014, Fifth 10-Year Inservice Testing Program Plan2018-02-19019 February 2018 Fifth 10-Year Inservice Testing Program Plan BSEP 18-0021, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865). Without Proprietary Enclosure2018-02-0505 February 2018 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865). Without Proprietary Enclosure BSEP 18-0017, Revision to Radiological Emergency Response Plan and Implementing Procedure2018-01-30030 January 2018 Revision to Radiological Emergency Response Plan and Implementing Procedure BSEP 18-0015, Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations2018-01-23023 January 2018 Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations BSEP 18-0013, Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-01-23023 January 2018 Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control BSEP 18-0001, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2018-01-23023 January 2018 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements BSEP 18-0012, Application to Revise Technical Specifications to Adopt TSTF-208, Revision 0, Extension of Time to Reach Mode 2 in LCO 3.0.32018-01-23023 January 2018 Application to Revise Technical Specifications to Adopt TSTF-208, Revision 0, Extension of Time to Reach Mode 2 in LCO 3.0.3 BSEP 18-0009, 2017 Sea Turtle Annual Report2018-01-15015 January 2018 2017 Sea Turtle Annual Report BSEP 17-0098, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors2018-01-10010 January 2018 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors BSEP 17-0119, Snubber Program Plan for Fifth 10-Year Interval Inservice Testing Program2018-01-10010 January 2018 Snubber Program Plan for Fifth 10-Year Interval Inservice Testing Program BSEP 17-0115, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-01-0404 January 2018 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control BSEP 17-0110, Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions2017-12-20020 December 2017 Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions BSEP 17-0121, Post-Examination Documentation and Comments for Operator Retake Initial Examination2017-12-14014 December 2017 Post-Examination Documentation and Comments for Operator Retake Initial Examination BSEP 17-0120, Withdrawal of Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension..2017-12-12012 December 2017 Withdrawal of Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension.. BSEP 17-0118, Supplement to Response to Request for Additional Information Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel..2017-12-0707 December 2017 Supplement to Response to Request for Additional Information Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel.. BSEP 17-0117, Response to Request for Additional Information (Probabilistic Risk Assessment and Human Performance Branches) Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1 AC Sources..2017-12-0606 December 2017 Response to Request for Additional Information (Probabilistic Risk Assessment and Human Performance Branches) Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1 AC Sources.. BSEP 17-0116, Response to Request for Additional Information Regarding Request for Risk- Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of ..2017-12-0404 December 2017 Response to Request for Additional Information Regarding Request for Risk- Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of .. BSEP 17-0104, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination2017-11-29029 November 2017 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination BSEP 17-0111, Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements2017-11-28028 November 2017 Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements BSEP 17-0109, Response to Request for Additional Information Regarding Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times And.2017-11-24024 November 2017 Response to Request for Additional Information Regarding Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times And. BSEP 17-0108, Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements2017-11-22022 November 2017 Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements BSEP 17-0017, Submittal of Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material2017-11-15015 November 2017 Submittal of Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material BSEP 17-0100, Fifth 10-Year Inservice Testing Interval2017-11-0202 November 2017 Fifth 10-Year Inservice Testing Interval BSEP 17-0089, Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion2017-11-0101 November 2017 Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 17-0093, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2017-11-0101 November 2017 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 17-0078, Request for License Amendment - DC Sources - Operating Surveillance Requirement (SR) 3.8.4.52017-10-0303 October 2017 Request for License Amendment - DC Sources - Operating Surveillance Requirement (SR) 3.8.4.5 BSEP 17-0076, Registration for Use of General License Spent Fuel Casks2017-09-0606 September 2017 Registration for Use of General License Spent Fuel Casks BSEP 17-0081, Revision to Radiological Emergency Response Plan Implementing Procedures2017-09-0505 September 2017 Revision to Radiological Emergency Response Plan Implementing Procedures BSEP 17-0039, Submittal of Response to Inspection Report 05000324/2015404 and 05000325/2015404, Dated March 30, 2015, Inspection of Interim Cyber Security Milestones 1-7 and Target Set Requirements2017-08-15015 August 2017 Submittal of Response to Inspection Report 05000324/2015404 and 05000325/2015404, Dated March 30, 2015, Inspection of Interim Cyber Security Milestones 1-7 and Target Set Requirements BSEP 17-0071, ISFSI - Registration for Use of General License Spent Fuel Casks2017-08-15015 August 2017 ISFSI - Registration for Use of General License Spent Fuel Casks BSEP 17-0064, Application of Dissimilar Metal Weld Full Structural Overlay on Reactor Pressure Vessel Nozzle N92017-07-10010 July 2017 Application of Dissimilar Metal Weld Full Structural Overlay on Reactor Pressure Vessel Nozzle N9 BSEP 17-0060, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.2017-06-29029 June 2017 Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control. 2019-01-17
[Table view] Category:Licensee Response to Notice of Violation
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DUKE George T. Hamrick Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 10 CFR 2.201 June 30, 2014 Serial: BSEP 14-0075 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Reply to a Notice of Violation, EA-14-048
Reference:
Letter from Richard P. Croteau (USNRC) to George T. Hamrick (Duke Energy Progress, Inc.), Brunswick Steam Electric Plant-NRC Inspection Report Nos.
05000325/2014011 and 05000324/2014011; Final Significance Determination and Notice of Violation, dated May 29, 2014, ADAMS Accession Number ML14149A149 Ladies and Gentlemen:
Pursuant to the provisions of 10 CFR 2.201, Duke Energy Progress, Inc., is providing a reply to Notice of Violation EA-14-048 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.
The response to Notice of Violation EA-14-048 is enclosed.
This letter contains no regulatory commitments. Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.
Sincerely, George T. Hamrick GTH/mkb
Enclosure:
Reply to a Notice of Violation, EA-14-048
-iA~&l
U.S. Nuclear Regulatory Commission Page 2 of 2 cc:
U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510
Enclosure Page 1 of 3 Reply to a Notice of Violation, EA-14-048 Statement of Violation Appendix B to 10 CFR Part 50, Criterion XVI, CorrectiveAction, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, the licensee failed to promptly identify and correct conditions adverse to quality, and failed to correct and preclude repetition of a significant condition adverse to quality, as evidenced by the following two examples:
- 1. From 1995 to 2012, the licensee failed to identify and correct conditions adverse to quality involving degraded and nonconforming flood penetration seals and openings in multiple safety-related buildings, including the service water building (SWB), reactor building (RB),
and emergency diesel generator building (EDGB). In 2012, the licensee identified but failed to correct over 450 work requests/work orders/nuclear condition reports for degraded and/or nonconforming flood protection features, the majority of which were attributed to degraded or nonconforming flood penetration seals. Specifically, the licensee identified degraded flood penetration wall seals, conduit seals, an EDGB roll up door seal, and a 3-inch gap in the seal along the bottom of the Unit 2 RB railroad door which would have allowed leakage into the SWB, RB, and EDGB during a probable maximum hurricane.
- 2. As of December 31, 2013, the licensee failed to correct and preclude repetition of a significant condition adverse to quality which was originally identified in 2011. Specifically, the licensee's corrective action to preclude repetition of the NRC-identified White finding from 2011 was to "develop an engineering program in accordance with licensee procedure EGR-NGGC-0008, Engineering Programs, to mitigate the consequences of external events (flooding, high winds, and seismic). This program, or programs, must ensure appropriate equipment classifications, with interfacing programs of maintenance rule (MR) and zero tolerance for equipment failures. The program must ensure performance of necessary operation, maintenance, testing, and inspection activities in accordance with the work management process to maintain needed design features." However, the licensee failed to adequately develop this engineering program to mitigate the consequences of external events (flooding, high winds, and seismic).
This violation is associated with a Green Significance Determination Process finding.
Duke Energy Response Duke Energy admits to this violation.
- 1. Reason for the Violation The failure to promptly identify and correct conditions adverse to quality and to correct and preclude repetition of a significant condition adverse to quality was documented in Condition Report (CR) 690721. The cause evaluation for CR 690721 identified the following causes associated with this violation.
Enclosure Page 2 of 3 Cause
- The Brunswick organization did not understand the impact of flooding events to safety-related equipment and structures.
ContributingCauses
- Design basis information related to external flooding is not clearly available to station personnel.
- Less than adequate oversight of Corrective Action Program (CAP) product quality.
- 2. Corrective Steps Taken and the Results Achieved The following corrective actions have been taken to address the stated violations.
" Work requests, work orders, and condition reports, as cited in the violation, have been completed.
- A formal external events program was implemented and is controlled by OENP-66, External Events ProtectionProgram. Methods for conducting inspections, documenting inspection results, and evaluating inspection results are described in OENP-66. Seismic components are monitored through inspections established by EGR-NGGC-0351, Condition Monitoring of Structures.
- A Priority 2 (i.e., Urgent, in accordance with AD-WC-ALL-0210, Work Request Initiation, Screening, Prioritizationand Classification)work management priority was established for repair of degraded flood protection devices.
" Flooding functions, as identified in technical report OBNP-TR-019, External Event ProtectionFeatures,Revision 2, have been included in the Maintenance Rule scope.
- Preventive maintenance (PM) tasks have been established for sump pumps and check valves that are identified as flood protection features in OBNP-TR-019.
Additional corrective actions have been taken to address the identified causes.
- A case study of the issue has been presented to site leadership.
- A flooding topical design basis document (i.e., DBD-144, Externaland Internal Flooding Topical Design Basis Document) was developed.
- Flood barrier deficiencies are now tracked and discussed in the daily Operational Focus Meeting to ensure appropriate prioritization based on imminent flooding threats.
- To evaluate the extent of condition for CAP closure deficiencies, Brunswick performed a review of corrective actions to prevent recurrence (CAPRs) and corrective actions (CORRs) associated with root cause and apparent cause evaluations closed in the last three years. Identified deficiencies were captured in the CAP.
- A monthly Nuclear Safety Risk Oversight Meeting has been established to track timeliness and quality of adverse condition responses that could increase nuclear safety risk.
- Department Performance Improvement Oversight Committees (i.e., Department.
PIOCs) have been established. Mentors are assigned for each Department PIOC to drive quality and consistency.
Enclosure Page 3 of 3
- Examples of "what good looks like" for CAP deliverables were developed and communicated to the Brunswick Performance Improvement Specialists.
- A new standard template for corrective action closure has been implemented to strengthen the site's CAP item closure.
The above corrective actions ensure that the station is currently prepared for external flood events and that flood protection deficiencies can be appropriately identified, prioritized, and receive the appropriate management attention. In addition, the External Events Protection Program has been implemented to address flooding and high wind events. Furthermore, the actions taken to strengthen the CAP process will help to minimize the potential for similar issues to arise.
- 3. Corrective Steps That Will Be Taken The following corrective actions are planned.
- A comprehensive review of the Updated Final Safety Analysis Report is in progress, which includes a review of sections applicable to external events. This review is currently scheduled to be completed by August 28, 2014.
- An effectiveness review will be performed for root cause evaluations documented in Condition Report (CR) 490292 (i.e., 4 Day Fuel Oil Tank Enclosure Degradation) and CR 629064 (i.e., Service Water Building Flood Inspection Aggregate Evaluation Results). These reviews are currently scheduled to be completed by September 11, 2014.
" A method to provide fleet oversight of the Brunswick external events program will be implemented. The action is currently scheduled to be completed by October 30, 2014.
- A review and update, as necessary, of the Brunswick design basis information for high winds will be completed. This review is currently scheduled to be completed by February 26, 2015.
- An effectiveness review will be performed for apparent cause evaluation documented in CR 690721 (i.e., Apparent Cause for Notice of Violation EA-1 4-048). This review is currently scheduled to be completed by March 31, 2015.
The above corrective actions will further institutionalize external event design basis requirements.
- 4. Date When Full Compliance Will Be Achieved Full compliance with Appendix B to 10 CFR Part 50, Criterion XVI, CorrectiveAction, with respect to the examples cited in this violation, has been achieved. Furthermore, the actions established in the cause evaluation will help ensure the site's awareness and fleet oversight of external event issues and help drive cultural changes at the site. The remaining planned corrective actions and any new deficiencies associated with external events will be addressed in accordance with the CAP.