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#REDIRECT [[IR 05000324/2022004]]
{{Adams
| number = ML23033A525
| issue date = 02/08/2023
| title = Integrated Inspection Report 05000324/2022004 and 05000325/2022004
| author name = Fannon M
| author affiliation = NRC/RGN-II/DRP
| addressee name = Krakuszeski J
| addressee affiliation = Duke Energy Progress, LLC
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| contact person =
| document report number = IR 2022004
| document type = Inspection Report, Letter
| page count = 15
}}
See also: [[see also::IR 05000324/2022004]]
 
=Text=
{{#Wiki_filter:February 8, 2023
John A. Krakuszeski
Site Vice President
Duke Energy Progress, LLC
8470 River Road SE
M/C BNP04
Southport, NC 28461-0429
SUBJECT:          BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION
                  REPORT 05000324/2022004 AND 05000325/2022004
Dear Mr. John A. Krakuszeski:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Brunswick Steam Electric Plant. On February 2, 2023, the NRC inspectors
discussed the results of this inspection with you and other members of your staff. The results of
this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding
involved a violation of NRC requirements. We are treating this violation as a non-cited violation
(NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at
Brunswick Steam Electric Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC
Resident Inspector at Brunswick Steam Electric Plant.
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
 
J. Krakuszeski                            2
                                      Sincerely,
                                                            Signed by Fannon, Matthew
                                                            on 02/08/23
                                      Matthew S. Fannon, Chief
                                      Reactor Projects Branch 4
                                      Division of Reactor Projects
Docket Nos. 05000324 and 05000325
License Nos. DPR-62 and DPR-71
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
 
 
ML23033A525
                          X      Non-Sensitive              X  Publicly Available
    X  SUNSI Review
                                Sensitive                    Non-Publicly Available
  OFFICE RII/DRP        RII/DRP                RII/DRP
  NAME    G. Smith      A. Wilson              M. Fannon
  DATE    02/03/2023    02/03/2023            02/08/2023
                                 
                          U.S. NUCLEAR REGULATORY COMMISSION
                                        Inspection Report
Docket Numbers:        05000324 and 05000325
License Numbers:      DPR-62 and DPR-71
Report Numbers:        05000324/2022004 and 05000325/2022004
Enterprise Identifier: I-2022-004-0016
Licensee:              Duke Energy Progress, LLC
Facility:              Brunswick Steam Electric Plant
Location:              Southport, NC
Inspection Dates:      October 01, 2022, to December 31, 2022
Inspectors:            C. Curran, Resident Inspector
                      G. Smith, Senior Resident Inspector
                      J. Steward, Senior Resident Inspector
                      J. Viera, Senior Operations Engineer
Approved By:          Matthew S. Fannon, 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
  Failure of Unit 2 High Pressure Coolant Injection (HPCI) Controller
  Cornerstone          Significance                                  Cross-Cutting      Report
                                                                      Aspect            Section
  Mitigating          Green                                          [H.7] -            71152A
  Systems              NCV 05000325,05000324/2022004-01              Documentation
                      Open/Closed
  A self-revealed Green finding and associated Non-Cited Violation (NCV) of Technical
  Specification (TS) 5.4.1.a was identified for the failure to establish work instructions to verify
  operability of the HPCI flow controller.
                                  Additional Tracking Items
  Type      Issue Number                Title                              Report Section    Status
  LER        05000325/2022-001-00        Licensee Event Report              71153            Closed
                                        (LER) 2022-001-00 for
                                        Brunswick Steam Electric
                                        Plant, Unit 1, High Pressure
                                        Coolant Injection Inoperable
                                                  2
 
PLANT STATUS
Unit 1 began the period at 100 percent rated thermal power (RTP) and operated there until
December 9, 2022, when power was reduced to 70 percent RTP for a planned control rod
sequence exchange. Following the sequence exchange, as well as two follow-on rod
improvements, the unit was restored to full RTP on December 16, 2022, where the unit
essentially operated for the remainder of the period.
Unit 2 began the period at RTP, and operated there until October 6, 2022, when power was
reduced to 85 percent RTP due to loss of one of the four off site power lines
(Whiteville). System procedures require the turbine output to be less than 830 megawatts when
only three of the four off site power lines are available. Following repairs to the Whiteville line,
the unit was restored to full RTP on October 7. On November 4, the unit was reduced to 60
percent RTP for turbine control/stop valve closure testing and a rod pattern
adjustment. Following completion of the valve testing and rod pattern adjustment, the unit was
restored to full RTP on November 6. On November 26, power was reduced to 47 percent RTP
as a result of a trip of the 'B' recirculation pump. This put the unit into single loop
operation. Investigation revealed that a coolant leak within the variable frequency drive (VFD)
caused an electrical short and an ultimate failure of the VFD which caused the recirculation
pump trip. Following replacement of all twelve VFD cells, the recirculation pump was restarted,
and a controlled power ascension was commenced on November 28. Full RTP was attained on
December 8, and the unit continued to essentially operate there for the remainder of the period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of
IPs. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel to assess licensee performance and compliance with Commission rules
and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
    (1)    On October 12, 2022, the inspectors completed an evaluation and a walkdown of
            flood protection barriers, mitigation plans, procedures, and equipment to verify
            consistency with the licensees design requirements and risk analysis assumptions for
            coping with external flooding.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
                                                    3
 
    The inspectors evaluated system configurations during partial walkdowns of the following
    systems/trains:
    (1)    '2A' control room emergency ventilation (CREV) train while the '2B' CREV train was
          out-of-service for planned maintenance on November 9, 2022
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
    (1)    The licensee completed the annual requalification operating examinations required to
          be administered to all licensed operators in accordance with Title 10 of the Code of
          Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's
          "Operator's Licenses." During the week of November 7, 2022, the inspector
          performed an in-office review of the overall pass/fail results of the individual operating
          examinations and the crew simulator operating examinations in accordance with
          Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification
          Program." These results were compared to the thresholds established in Section
          3.03, "Requalification Examination Results," of IP 71111.11.
          The inspectors reviewed and evaluated the licensed operator examination failure
          rates for the requalification annual operating exam completed on October 5, 2022.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1
Sample)
    (1)    The inspectors observed and evaluated licensed operator performance in the main
          control room during a power reduction to 60 percent RTP in order to perform a control
          rod improvement, conduct main steam line isolation valve and turbine control/stop
          valve closure testing, and replace a condensate resin bed on November 4, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (5 Samples)
    The inspectors evaluated the effectiveness of maintenance to ensure the following
    structures, systems, and components (SSCs) remain capable of performing their intended
    function:
    (1)    Loss of power to Unit 1 HPCI flow controller on July 25, 2022, (nuclear condition
          report (NCR) 2434489)
    (2)    Unit 1 'D' residual heat removal (RHR) pump trip on March 24, 2022, (NCR 2418646)
    (3)    Unit 2 reactor building (RB) radiation monitor (2-D12-RM-K609A) spiked causing RB
          ventilation isolation on August 6, 2022, (NCR 2437011 and NCR 2437874)
    (4)    480-volt breaker issues on March 12, 2022, (NCR 2419650)
    (5)    Unit 1 C conventional service water pump shear pin sheared on May 11, 2022, (NCR
          2427130)
                                                  4
 
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
  The inspectors evaluated the accuracy and completeness of risk assessments for the
  following planned and emergent work activities to ensure configuration changes and
  appropriate work controls were addressed:
  (1)    Elevated risk due to maintenance on Unit 1 C circulating water pump and C
          conventional service water pump on December 15, 2022
  (2)    Emergent failure of Unit 2 balance of plant annunciator power supply on December
          22, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
  The inspectors evaluated the licensee's justifications and actions associated with the
  following operability determinations and functionality assessments:
  (1)    '1B' RHR valve operability (NCR 2440234)
  (2)    Pipe stress calculations not analyzed to maximum allowed temperature (NCR
          02426668)
  (3)    B1C24 new fuel upper tie plates with nonconforming dimensions (NCR 2413961)
  (4)    Pencil sized leak between 2-SW-V160 and 2SW-V193 (NCR 2438788)
  (5)    Cracks in the Unit 1 south core spray concrete columns (NCR 2427216)
  (6)    Pressure switch (2-FO-PDS-6530-4) as-left reset left low out of tolerance (NCR
          2431537)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1
Sample)
  The inspectors evaluated the following temporary or permanent modifications:
  (1)    Engineering Change 407070 - Install carbon fiber reinforced polymer (CFRP) on
          buried service water line 1-SW-100/199-30-157
Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)
  (1)    The inspectors verified the site Severe Accident Management Guidelines were
          updated in accordance with the boiling water reactor generic severe accident
          technical guidelines and validated in accordance with NEI 14-01, Emergency
          Response Procedures and Guidelines for Beyond Design Basis Events and Severe
          Accidents, Revision 1.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
                                                5
 
  The inspectors evaluated the following post-maintenance testing (PMT) activities to verify
  system operability and/or functionality:
  (1)    0PT-08.2.2B, "LPCI/ RHR System Operability Test - Loop B," Rev. 110, after hinge
          pin replacement on the '1B' RHR check valve in accordance with (IAW) work order
          (WO) 20318536-01
  (2)    2-OP-02, "Reactor Recirculation System Operating Procedure," Rev. 185, following
          2B VFD cell replacement IAW WO 2057072
  (3)    PMT associated with the 2-SCW-2B-SW-TRVL-SCRN replacement IAW WO
          20413408 on October 31, 2022
  (4)    PMT associated with the '1B' nuclear service water strainer disassembly inspection
          IAW WO 20526905 on October 27, 2022
  (5)    0PT-07.2.4B, "Core Spray System Operability Test - Loop B," Rev. 86, following tan
          delta testing of the Unit 1 'B' core spray pump cable IAW WO 20478897-01
  (6)    0PT-07.2.4B, "Core Spray System Operability Test - Loop B," Rev. 86, following 1-
          E21-F031B (core spray min flow bypass valve) breaker and relay preventative
          maintenance IAW WO 20429155-01
  (7)    1PT-24.1-1, "Service Water Pump and Discharge Valve Operability Test," Rev. 98,
          following motor operated valve testing on 1-SW-V15 (conventional service water
          discharge valve) IAW WO 20493391-01
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (8 Samples)
  (1)    0PT-07.2.4B, Core Spray System Operability Test - Loop B, Rev. 86, IAW WO
          20547794
  (2)    0PT-40.2.8, Main Steam Line Isolation Valve Closure Test, Rev. 35, IAW WO
          20556595
  (3)    2PT-40.2.9, Turbine Control Valve/Stop Valve Closure Test, Rev. 25, IAW WO
          20554996
  (4)    0PT-15.7, "Standby Gas Treatment System Operability Test," Rev. 46, IAW WO
          20550238 and 0PT-15.6, "Standby Gas Treatment System Operability," Rev. 36, IAW
          WO 20562679
  (5)    0PT-09.2, "HPCI System Operability Test," Rev. 154, IAW WO 20550240 and WO
          20510617
  (6)    0PT-08.2.2B, "LPCI/RHR System Operability Test - Loop B," Rev. 110, IAW WO
          20550247
  (7)    0PT-13.1, Reactor Recirculation Jet Pump Operability," Rev. 48, performed on
          November 30, 2022
  (8)    0MST-RHR23Q, RHR-LPCI ADS CS LL3, PDCI RCIC LL2 DIV II Trip Unit Channel
          Calibration, Rev. 10, IAW WO 20556157
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
                                                  6
 
The inspectors verified licensee performance indicators submittals listed below:
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
  (1)    Unit 1 (October 1, 2021, through September 30, 2022)
  (2)    Unit 2 (October 1, 2021, through September 30, 2022)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
  (1)    Unit 1 (October 1, 2021, through September 30, 2022)
  (2)    Unit 2 (October 1, 2021, through September 30, 2022)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
  (1)    Unit 1 (October 1, 2021, through September 30, 2022)
  (2)    Unit 2 (October 1, 2021, through September 30, 2022)
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
  The inspectors reviewed the licensees implementation of its corrective action program
  related to the following issues:
  (1)    The Unit 1 HPCI system was declared inoperable upon discovery of the HPCI flow
          controller without power. It was determined that an intermittent connection in the flow
          controller fuse holder was the cause.
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
  (1)    The inspectors reviewed the licensees corrective action program for potential
          adverse trends in operations and maintenance that might be indicative of a more
          significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample)
  The inspectors evaluated the following licensee event reports (LERs):
  (1)    LER 05000325/2022-001-00, High Pressure Coolant Injection (HPCI) Inoperable
          (ADAMS Accession No. ML22255A164). The inspection conclusions associated with
          this LER are documented in this report under Inspection Results Section 71152. This
          LER is closed.
INSPECTION RESULTS
  Failure of Unit 2 High Pressure Coolant Injection (HPCI) Controller
                                                7
 
Cornerstone          Significance                                Cross-Cutting      Report
                                                                  Aspect            Section
Mitigating            Green                                        [H.7] -            71152A
Systems              NCV 05000325,05000324/2022004-01 Documentation
                      Open/Closed
A self-revealed Green finding and associated Non-Cited Violation (NCV) of Technical
Specification (TS) 5.4.1.a was identified for the failure to establish work instructions to verify
operability of the HPCI flow controller.
Description: On July 15, 2022, with Unit 1 in Mode 1 at approximately 96% power for
planned maintenance on the A Condensate Deep-bed Demineralizer, the HPCI system was
declared inoperable upon discovery of a loss of power to the HPCI flow controller during a
board walkdown. The licensee's initial investigation revealed that the HPCI flow controller
lost power as a result of an intermittent connection in the flow controller fuse holder. The
controller fuse holder was tightened by maintenance and the HPCI controller was declared
operable on July 16, 2022, at 12:10 EDT following associated post maintenance testing. The
licensee's subsequent investigation revealed that the controller was recently replaced in May
2022. During this replacement, the tightness of controller connection to the fuse holder was
not verified as the maintenance procedure did not require this step. The licensee assumed
that the vendor had verified all aspects of the controller module were inspected. The
licensee's post maintenance testing in May, following the controller replacement, verified the
HPCI controller to be operable. However, over the next few months the electrical
connections became less robust until the connection began exhibiting intermittent continuity
and eventually led to the failure noted on July 15. The inspectors noted that reactor core
isolation cooling (RCIC) system and automatic depressurization system remained operable
during this event. On September 12, 2022, the licensee issued LER 2022-001-00 (see
section 71153 of this report) in accordance with 10 CFR 50.73(a)(2)(v)(D) as a condition that
could have prevented fulfillment of the safety function needed to mitigate the consequences
of an accident. In the LER, the licensee concluded that the cause of the event was
inadequate procedural guidance associated with ensuring tightness of the fuse holder.
Corrective Actions: In addition to securing the fuse in the fuse holder, the licensee added
instructions to the associated maintenance procedure to check the fuse holder tightness prior
to returning the HPCI and RCIC flow controllers to service following replacement and
calibration.
Corrective Action References: NCR 02434489
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to establish maintenance
instructions for the HPCI flow controller to ensure continued availability was a performance
deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Procedure Quality 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. Specifically, the failure to verify the tightness of the HPCI flow controller fuse
connection resulted in the inoperability of HPCI for 24 hours.
Significance: The inspectors assessed the significance of the finding using Inspection
Manual Chapter (IMC) 0609, Significance Determination Process (SDP), Attachment 4,
                                                8
 
Initial Characterization of Findings, and Appendix A, The Significance Determination
Process for Findings At-Power. Specifically, using Attachment 4, the finding was determined
to adversely affect the Mitigating Systems cornerstone since the finding was related to an
inoperable mitigating system. Using IMC 0609, Appendix A, Exhibit 2, the finding was
determined to be of very low safety significance (Green) since the finding represented an
inoperable single train TS system that did not exceed the TS 3.5.1 allowed outage time of 14
days. An exposure time of 1 day (2 shifts) was assumed because the main control room
control boards are frequently inspected and scanned by the operators.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains
complete, accurate and up-to-date documentation.
Enforcement:
Violation: TS 5.4.1.a, Administrative Control (Procedures), states 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). Safety Guide 33, Appendix A, Section I.1,
states 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 requirements of TS 5.4.1.a, on May 3, 2022, the licensee failed to establish
instructions during maintenance that affected the performance of safety-related
equipment. Specifically, the licensee did not establish steps in WO 20304709 02 and
Procedure 1-E41-FIC-R600, "Replace Controller, HPCI Turbine Flow," to prevent the loss of
power to the HPCI controller.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Observation: Semi-Annual Trend Review                                                  71152S
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 July -
December 2022, 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.
During this review, the inspectors noted what appeared to be an excessive number of safety
system actuations in the past year. Specifically, since December 2021 through the end of
2022, seven safety system actuations occurred. Of these seven only one was a "valid"
actuation while the five of the remaining six were "invalid" actuations. One actuation was
considered "non-valid."
                                                9
 
The valid actuation (NCR 2408197) was a loss of the E-3 bus caused by a washer that
inadvertently contacted the connections associated with the bus under voltage relay. This
resulted in a stripping of the bus and ultimately a loss of the E-3 bus since the emergency
diesel generator No. 3 was under clearance. The inspectors noted no performance
deficiency during this event since the washer was never noted on any design drawings.
The January 4, 2022, actuation occurred during routine testing of the primary containment
isolation system (PCIS). During testing, channel 'A2' gave a partial isolation for group 2 and
secondary containment isolation. The cause was attributed to dirty contacts on an
electromechanical relay. The relay was replaced.
On March 5, 2022, during a refueling outage, the '1D' RHR pump tripped as a result of the
RHR suction valve, 1E11-F-08, inadvertently closing due to a momentary group 8 signal. The
momentary group 8 signal was attributed to a momentary pressure spike caused by flashing
due to operation on a single reactor recirculation pump while in mode 3 with speeds lower
than 30%. The licensee has made a procedure change to operate at slightly higher
recirculation flows while in mode 3 in addition to the evaluation of a new time delay on the
associated relays to eliminate the negative effects of a momentary pressure spike.
On March 7, 2022, Unit 1 experienced a low level 3 actuation due to inadequate maintenance
planning that removed two level transmitters from service during a refueling outage. These
two transmitters met the emergency core cooling system (ECCS) logic and ultimately resulted
in a low level 3 ECCS signal. A green NCV was documented in Brunswick Integrated
Inspection Report 05000324/2022001 and 05000325/2022001 (ADAMS Accession No.
ML22130A108).
On August 6 and August 12, 2022, Unit 2 RB 'A' radiation monitor, 2D12-RM-K609A, spiked
high causing a secondary containment isolation and a PCIS group 6 actuation. The radiation
monitor indicated radiation levels as high as 6 millirem per hour (mr/hr) while the 'B' channel
indicated normal background levels of 0.12 mr/hr. Based on the licensee's investigation, the
'A ' RB radiation monitor was determined to be failed due to a faulty sensor/convertor. The
detector had recently been replaced in April 2022.
On November 9, 2022, a degraded jumper in the main stack radiation monitor on Unit 1
caused a fuse to blow and ultimately led to a group 6 PCIS isolation. The radiation monitor
was subsequently repaired.
The inspectors performed a detailed review of the above actuations but could not identify a
common theme between all seven events. The inspectors discussed this negative trend with
the licensee.
  NCR #        Date          Event                          Type      Event Notification (EN) /
                                                                      LER Number
  2408197      12/6/2021    Loss of E-3 Bus                Valid    EN 55627, LER 1-2021-
                                                                      001
  2410783      1/4/2022      Group 6 PCIS Actuation        Invalid  EN 55756
  2418646      3/5/2022      1D RHR Pump Trip              Not      Not Applicable
                                                            Valid
  2418712      3/7/2022      Low Level 3 Actuation          Invalid  EN 55859
  2437011      8/6/2022      Group 6 PCIS Actuation        Invalid  EN 56138
                                              10
 
  2437874      8/12/2022      Group 6 PCIS Actuation        Invalid  EN 56138
  2449077      11/9/2022      Group 6 PCIS Actuation        Invalid  EN 56287
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
      On February 2, 2023, the inspectors presented the integrated inspection results to John
      A. Krakuszeski and other members of the licensee staff.
                                                11
 
DOCUMENTS REVIEWED
Inspection Type              Designation Description or Title                                        Revision or
Procedure                                                                                            Date
71152A    Corrective Action AR 02434489 Loss of Power to Unit 1 High Pressure Coolant Injection      07/15/2022
            Documents                    System Flow Controller
            Procedures        0PIC-UC013  Calibration of Yokogawa Manual or Programable Indicating    13
                                          Controller Models SMLD and SLPC
71153      Corrective Action AR 02434489 Loss of Power to Unit 1 High Pressure Coolant Injection Flow 07/15/2022
            Documents                    Controller
                                                    12
}}

Latest revision as of 11:06, 17 April 2023

Integrated Inspection Report 05000324/2022004 and 05000325/2022004
ML23033A525
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 02/08/2023
From: Matthew Fannon
Division Reactor Projects II
To: Krakuszeski J
Duke Energy Progress
References
IR 2022004
Download: ML23033A525 (15)


See also: IR 05000324/2022004

Text

February 8, 2023

John A. Krakuszeski

Site Vice President

Duke Energy Progress, LLC

8470 River Road SE

M/C BNP04

Southport, NC 28461-0429

SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION

REPORT 05000324/2022004 AND 05000325/2022004

Dear Mr. John A. Krakuszeski:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at Brunswick Steam Electric Plant. On February 2, 2023, the NRC inspectors

discussed the results of this inspection with you and other members of your staff. The results of

this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding

involved a violation of NRC requirements. We are treating this violation as a non-cited violation

(NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this

inspection report, you should provide a response within 30 days of the date of this inspection

report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional

Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at

Brunswick Steam Electric Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC

Resident Inspector at Brunswick Steam Electric Plant.

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public

Inspections, Exemptions, Requests for Withholding.

J. Krakuszeski 2

Sincerely,

Signed by Fannon, Matthew

on 02/08/23

Matthew S. Fannon, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Docket Nos. 05000324 and 05000325

License Nos. DPR-62 and DPR-71

Enclosure:

As stated

cc w/ encl: Distribution via LISTSERV

ML23033A525

X Non-Sensitive X Publicly Available

X SUNSI Review

Sensitive Non-Publicly Available

OFFICE RII/DRP RII/DRP RII/DRP

NAME G. Smith A. Wilson M. Fannon

DATE 02/03/2023 02/03/2023 02/08/2023

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000324 and 05000325

License Numbers: DPR-62 and DPR-71

Report Numbers: 05000324/2022004 and 05000325/2022004

Enterprise Identifier: I-2022-004-0016

Licensee: Duke Energy Progress, LLC

Facility: Brunswick Steam Electric Plant

Location: Southport, NC

Inspection Dates: October 01, 2022, to December 31, 2022

Inspectors: C. Curran, Resident Inspector

G. Smith, Senior Resident Inspector

J. Steward, Senior Resident Inspector

J. Viera, Senior Operations Engineer

Approved By: Matthew S. Fannon, 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

Failure of Unit 2 High Pressure Coolant Injection (HPCI) Controller

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green [H.7] - 71152A

Systems NCV 05000325,05000324/2022004-01 Documentation

Open/Closed

A self-revealed Green finding and associated Non-Cited Violation (NCV) of Technical

Specification (TS) 5.4.1.a was identified for the failure to establish work instructions to verify

operability of the HPCI flow controller.

Additional Tracking Items

Type Issue Number Title Report Section Status

LER 05000325/2022-001-00 Licensee Event Report 71153 Closed

(LER) 2022-001-00 for

Brunswick Steam Electric

Plant, Unit 1, High Pressure

Coolant Injection Inoperable

2

PLANT STATUS

Unit 1 began the period at 100 percent rated thermal power (RTP) and operated there until

December 9, 2022, when power was reduced to 70 percent RTP for a planned control rod

sequence exchange. Following the sequence exchange, as well as two follow-on rod

improvements, the unit was restored to full RTP on December 16, 2022, where the unit

essentially operated for the remainder of the period.

Unit 2 began the period at RTP, and operated there until October 6, 2022, when power was

reduced to 85 percent RTP due to loss of one of the four off site power lines

(Whiteville). System procedures require the turbine output to be less than 830 megawatts when

only three of the four off site power lines are available. Following repairs to the Whiteville line,

the unit was restored to full RTP on October 7. On November 4, the unit was reduced to 60

percent RTP for turbine control/stop valve closure testing and a rod pattern

adjustment. Following completion of the valve testing and rod pattern adjustment, the unit was

restored to full RTP on November 6. On November 26, power was reduced to 47 percent RTP

as a result of a trip of the 'B' recirculation pump. This put the unit into single loop

operation. Investigation revealed that a coolant leak within the variable frequency drive (VFD)

caused an electrical short and an ultimate failure of the VFD which caused the recirculation

pump trip. Following replacement of all twelve VFD cells, the recirculation pump was restarted,

and a controlled power ascension was commenced on November 28. Full RTP was attained on

December 8, and the unit continued to essentially operate there for the remainder of the period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed activities described in IMC 2515,

Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of

IPs. The inspectors reviewed selected procedures and records, observed activities, and

interviewed personnel to assess licensee performance and compliance with Commission rules

and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) On October 12, 2022, the inspectors completed an evaluation and a walkdown of

flood protection barriers, mitigation plans, procedures, and equipment to verify

consistency with the licensees design requirements and risk analysis assumptions for

coping with external flooding.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

3

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) '2A' control room emergency ventilation (CREV) train while the '2B' CREV train was

out-of-service for planned maintenance on November 9, 2022

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The licensee completed the annual requalification operating examinations required to

be administered to all licensed operators in accordance with Title 10 of the Code of

Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's

"Operator's Licenses." During the week of November 7, 2022, the inspector

performed an in-office review of the overall pass/fail results of the individual operating

examinations and the crew simulator operating examinations in accordance with

Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification

Program." These results were compared to the thresholds established in Section

3.03, "Requalification Examination Results," of IP 71111.11.

The inspectors reviewed and evaluated the licensed operator examination failure

rates for the requalification annual operating exam completed on October 5, 2022.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1

Sample)

(1) The inspectors observed and evaluated licensed operator performance in the main

control room during a power reduction to 60 percent RTP in order to perform a control

rod improvement, conduct main steam line isolation valve and turbine control/stop

valve closure testing, and replace a condensate resin bed on November 4, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (5 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following

structures, systems, and components (SSCs) remain capable of performing their intended

function:

(1) Loss of power to Unit 1 HPCI flow controller on July 25, 2022, (nuclear condition

report (NCR) 2434489)

(2) Unit 1 'D' residual heat removal (RHR) pump trip on March 24, 2022, (NCR 2418646)

(3) Unit 2 reactor building (RB) radiation monitor (2-D12-RM-K609A) spiked causing RB

ventilation isolation on August 6, 2022, (NCR 2437011 and NCR 2437874)

(4) 480-volt breaker issues on March 12, 2022, (NCR 2419650)

(5) Unit 1 C conventional service water pump shear pin sheared on May 11, 2022, (NCR

2427130)

4

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the

following planned and emergent work activities to ensure configuration changes and

appropriate work controls were addressed:

(1) Elevated risk due to maintenance on Unit 1 C circulating water pump and C

conventional service water pump on December 15, 2022

(2) Emergent failure of Unit 2 balance of plant annunciator power supply on December

22, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the

following operability determinations and functionality assessments:

(1) '1B' RHR valve operability (NCR 2440234)

(2) Pipe stress calculations not analyzed to maximum allowed temperature (NCR

02426668)

(3) B1C24 new fuel upper tie plates with nonconforming dimensions (NCR 2413961)

(4) Pencil sized leak between 2-SW-V160 and 2SW-V193 (NCR 2438788)

(5) Cracks in the Unit 1 south core spray concrete columns (NCR 2427216)

(6) Pressure switch (2-FO-PDS-6530-4) as-left reset left low out of tolerance (NCR

2431537)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1

Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change 407070 - Install carbon fiber reinforced polymer (CFRP) on

buried service water line 1-SW-100/199-30-157

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site Severe Accident Management Guidelines were

updated in accordance with the boiling water reactor generic severe accident

technical guidelines and validated in accordance with NEI 14-01, Emergency

Response Procedures and Guidelines for Beyond Design Basis Events and Severe

Accidents, Revision 1.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

5

The inspectors evaluated the following post-maintenance testing (PMT) activities to verify

system operability and/or functionality:

(1) 0PT-08.2.2B, "LPCI/ RHR System Operability Test - Loop B," Rev. 110, after hinge

pin replacement on the '1B' RHR check valve in accordance with (IAW) work order

(WO) 20318536-01

(2) 2-OP-02, "Reactor Recirculation System Operating Procedure," Rev. 185, following

2B VFD cell replacement IAW WO 2057072

(3) PMT associated with the 2-SCW-2B-SW-TRVL-SCRN replacement IAW WO 20413408 on October 31, 2022

(4) PMT associated with the '1B' nuclear service water strainer disassembly inspection

IAW WO 20526905 on October 27, 2022

(5) 0PT-07.2.4B, "Core Spray System Operability Test - Loop B," Rev. 86, following tan

delta testing of the Unit 1 'B' core spray pump cable IAW WO 20478897-01

(6) 0PT-07.2.4B, "Core Spray System Operability Test - Loop B," Rev. 86, following 1-

E21-F031B (core spray min flow bypass valve) breaker and relay preventative

maintenance IAW WO 20429155-01

(7) 1PT-24.1-1, "Service Water Pump and Discharge Valve Operability Test," Rev. 98,

following motor operated valve testing on 1-SW-V15 (conventional service water

discharge valve) IAW WO 20493391-01

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability

and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (8 Samples)

(1) 0PT-07.2.4B, Core Spray System Operability Test - Loop B, Rev. 86, IAW WO 20547794

(2) 0PT-40.2.8, Main Steam Line Isolation Valve Closure Test, Rev. 35, IAW WO 20556595

(3) 2PT-40.2.9, Turbine Control Valve/Stop Valve Closure Test, Rev. 25, IAW WO 20554996

(4) 0PT-15.7, "Standby Gas Treatment System Operability Test," Rev. 46, IAW WO 20550238 and 0PT-15.6, "Standby Gas Treatment System Operability," Rev. 36, IAW

WO 20562679

(5) 0PT-09.2, "HPCI System Operability Test," Rev. 154, IAW WO 20550240 and WO 20510617

(6) 0PT-08.2.2B, "LPCI/RHR System Operability Test - Loop B," Rev. 110, IAW WO 20550247

(7) 0PT-13.1, Reactor Recirculation Jet Pump Operability," Rev. 48, performed on

November 30, 2022

(8) 0MST-RHR23Q, RHR-LPCI ADS CS LL3, PDCI RCIC LL2 DIV II Trip Unit Channel

Calibration, Rev. 10, IAW WO 20556157

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

6

The inspectors verified licensee performance indicators submittals listed below:

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 (October 1, 2021, through September 30, 2022)

(2) Unit 2 (October 1, 2021, through September 30, 2022)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 (October 1, 2021, through September 30, 2022)

(2) Unit 2 (October 1, 2021, through September 30, 2022)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (October 1, 2021, through September 30, 2022)

(2) Unit 2 (October 1, 2021, through September 30, 2022)

71152A - Annual Follow-up Problem Identification and Resolution

Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) The Unit 1 HPCI system was declared inoperable upon discovery of the HPCI flow

controller without power. It was determined that an intermittent connection in the flow

controller fuse holder was the cause.

71152S - Semiannual Trend Problem Identification and Resolution

Semiannual Trend Review (Section 03.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential

adverse trends in operations and maintenance that might be indicative of a more

significant safety issue.

71153 - Follow Up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000325/2022-001-00, High Pressure Coolant Injection (HPCI) Inoperable

(ADAMS Accession No. ML22255A164). The inspection conclusions associated with

this LER are documented in this report under Inspection Results Section 71152. This

LER is closed.

INSPECTION RESULTS

Failure of Unit 2 High Pressure Coolant Injection (HPCI) Controller

7

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green [H.7] - 71152A

Systems NCV 05000325,05000324/2022004-01 Documentation

Open/Closed

A self-revealed Green finding and associated Non-Cited Violation (NCV) of Technical Specification (TS) 5.4.1.a was identified for the failure to establish work instructions to verify

operability of the HPCI flow controller.

Description: On July 15, 2022, with Unit 1 in Mode 1 at approximately 96% power for

planned maintenance on the A Condensate Deep-bed Demineralizer, the HPCI system was

declared inoperable upon discovery of a loss of power to the HPCI flow controller during a

board walkdown. The licensee's initial investigation revealed that the HPCI flow controller

lost power as a result of an intermittent connection in the flow controller fuse holder. The

controller fuse holder was tightened by maintenance and the HPCI controller was declared

operable on July 16, 2022, at 12:10 EDT following associated post maintenance testing. The

licensee's subsequent investigation revealed that the controller was recently replaced in May

2022. During this replacement, the tightness of controller connection to the fuse holder was

not verified as the maintenance procedure did not require this step. The licensee assumed

that the vendor had verified all aspects of the controller module were inspected. The

licensee's post maintenance testing in May, following the controller replacement, verified the

HPCI controller to be operable. However, over the next few months the electrical

connections became less robust until the connection began exhibiting intermittent continuity

and eventually led to the failure noted on July 15. The inspectors noted that reactor core

isolation cooling (RCIC) system and automatic depressurization system remained operable

during this event. On September 12, 2022, the licensee issued LER 2022-001-00 (see

section 71153 of this report) in accordance with 10 CFR 50.73(a)(2)(v)(D) as a condition that

could have prevented fulfillment of the safety function needed to mitigate the consequences

of an accident. In the LER, the licensee concluded that the cause of the event was

inadequate procedural guidance associated with ensuring tightness of the fuse holder.

Corrective Actions: In addition to securing the fuse in the fuse holder, the licensee added

instructions to the associated maintenance procedure to check the fuse holder tightness prior

to returning the HPCI and RCIC flow controllers to service following replacement and

calibration.

Corrective Action References: NCR 02434489

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to establish maintenance

instructions for the HPCI flow controller to ensure continued availability was a performance

deficiency.

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the Procedure Quality 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. Specifically, the failure to verify the tightness of the HPCI flow controller fuse

connection resulted in the inoperability of HPCI for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Significance: The inspectors assessed the significance of the finding using Inspection

Manual Chapter (IMC) 0609, Significance Determination Process (SDP), Attachment 4,

8

Initial Characterization of Findings, and Appendix A, The Significance Determination

Process for Findings At-Power. Specifically, using Attachment 4, the finding was determined

to adversely affect the Mitigating Systems cornerstone since the finding was related to an

inoperable mitigating system. Using IMC 0609, Appendix A, Exhibit 2, the finding was

determined to be of very low safety significance (Green) since the finding represented an

inoperable single train TS system that did not exceed the TS 3.5.1 allowed outage time of 14

days. An exposure time of 1 day (2 shifts) was assumed because the main control room

control boards are frequently inspected and scanned by the operators.

Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains

complete, accurate and up-to-date documentation.

Enforcement:

Violation: TS 5.4.1.a, Administrative Control (Procedures), states 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). Safety Guide 33, Appendix A,Section I.1,

states 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 requirements of TS 5.4.1.a, on May 3, 2022, the licensee failed to establish

instructions during maintenance that affected the performance of safety-related

equipment. Specifically, the licensee did not establish steps in WO 20304709 02 and

Procedure 1-E41-FIC-R600, "Replace Controller, HPCI Turbine Flow," to prevent the loss of

power to the HPCI controller.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Observation: Semi-Annual Trend Review 71152S

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 July -

December 2022, 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.

During this review, the inspectors noted what appeared to be an excessive number of safety

system actuations in the past year. Specifically, since December 2021 through the end of

2022, seven safety system actuations occurred. Of these seven only one was a "valid"

actuation while the five of the remaining six were "invalid" actuations. One actuation was

considered "non-valid."

9

The valid actuation (NCR 2408197) was a loss of the E-3 bus caused by a washer that

inadvertently contacted the connections associated with the bus under voltage relay. This

resulted in a stripping of the bus and ultimately a loss of the E-3 bus since the emergency

diesel generator No. 3 was under clearance. The inspectors noted no performance

deficiency during this event since the washer was never noted on any design drawings.

The January 4, 2022, actuation occurred during routine testing of the primary containment

isolation system (PCIS). During testing, channel 'A2' gave a partial isolation for group 2 and

secondary containment isolation. The cause was attributed to dirty contacts on an

electromechanical relay. The relay was replaced.

On March 5, 2022, during a refueling outage, the '1D' RHR pump tripped as a result of the

RHR suction valve, 1E11-F-08, inadvertently closing due to a momentary group 8 signal. The

momentary group 8 signal was attributed to a momentary pressure spike caused by flashing

due to operation on a single reactor recirculation pump while in mode 3 with speeds lower

than 30%. The licensee has made a procedure change to operate at slightly higher

recirculation flows while in mode 3 in addition to the evaluation of a new time delay on the

associated relays to eliminate the negative effects of a momentary pressure spike.

On March 7, 2022, Unit 1 experienced a low level 3 actuation due to inadequate maintenance

planning that removed two level transmitters from service during a refueling outage. These

two transmitters met the emergency core cooling system (ECCS) logic and ultimately resulted

in a low level 3 ECCS signal. A green NCV was documented in Brunswick Integrated

Inspection Report 05000324/2022001 and 05000325/2022001 (ADAMS Accession No.

ML22130A108).

On August 6 and August 12, 2022, Unit 2 RB 'A' radiation monitor, 2D12-RM-K609A, spiked

high causing a secondary containment isolation and a PCIS group 6 actuation. The radiation

monitor indicated radiation levels as high as 6 millirem per hour (mr/hr) while the 'B' channel

indicated normal background levels of 0.12 mr/hr. Based on the licensee's investigation, the

'A ' RB radiation monitor was determined to be failed due to a faulty sensor/convertor. The

detector had recently been replaced in April 2022.

On November 9, 2022, a degraded jumper in the main stack radiation monitor on Unit 1

caused a fuse to blow and ultimately led to a group 6 PCIS isolation. The radiation monitor

was subsequently repaired.

The inspectors performed a detailed review of the above actuations but could not identify a

common theme between all seven events. The inspectors discussed this negative trend with

the licensee.

NCR # Date Event Type Event Notification (EN) /

LER Number

2408197 12/6/2021 Loss of E-3 Bus Valid EN 55627, LER 1-2021-

001

2410783 1/4/2022 Group 6 PCIS Actuation Invalid EN 55756

2418646 3/5/2022 1D RHR Pump Trip Not Not Applicable

Valid

2418712 3/7/2022 Low Level 3 Actuation Invalid EN 55859

2437011 8/6/2022 Group 6 PCIS Actuation Invalid EN 56138

10

2437874 8/12/2022 Group 6 PCIS Actuation Invalid EN 56138

2449077 11/9/2022 Group 6 PCIS Actuation Invalid EN 56287

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On February 2, 2023, the inspectors presented the integrated inspection results to John

A. Krakuszeski and other members of the licensee staff.

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DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152A Corrective Action AR 02434489 Loss of Power to Unit 1 High Pressure Coolant Injection 07/15/2022

Documents System Flow Controller

Procedures 0PIC-UC013 Calibration of Yokogawa Manual or Programable Indicating 13

Controller Models SMLD and SLPC

71153 Corrective Action AR 02434489 Loss of Power to Unit 1 High Pressure Coolant Injection Flow 07/15/2022

Documents Controller

12