ML14184B383

Reply to a Notice of Violation, EA-14-048

ML14184B383
Person / Time
Site:	Brunswick
Issue date:	06/30/2014
From:	Hamrick G T Duke Energy Carolinas, Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 14-0075, EA-14-048
Download: ML14184B383 (5)

Text

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 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

Reference:

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, Corrective Action, 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.

Contributing Causes* 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 Protection Program. 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, Prioritization and 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 Protection Features, 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, External and 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, Corrective Action, 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.