IR 05000324/2018010
| ML18071A151 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/12/2018 |
| From: | Shane Sandal Reactor Projects Region 2 Branch 6 |
| To: | William Gideon Progress Energy Carolinas |
| References | |
| IR 2018010 | |
| Download: ML18071A151 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION rch 12, 2018
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - NRC TEAM INSPECTION REPORT 05000325/2018010 AND 05000324/2018010
Dear Mr. Gideon:
On February 1, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Steam Electric Plant, Units 1 and 2 facilities. 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.
The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.
The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Shane Sandal, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62
Enclosure:
IR 05000325, 324/2018010
Inspection Report
Docket Numbers: 50-325, 50-324 License Numbers: DPR-71, DPR-62 Report Numbers: 05000325/2018010, 05000324/2018010 Enterprise Identifier: I-2018-010-0046 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant, Units 1 and 2 Location: Southport, NC Inspection Dates: January 29 - February 1, 2018 Inspectors: R. Rodriguez, Senior Project Engineer (Team Leader)
M. Catts, Senior Project Engineer, Region I S. Freeman, Senior Reactor Analyst K. Roche, Reactor System Engineer, NRR Approved By: S. Sandal, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY
The NRC continued monitoring licensees performance by conducting a Temporary Instruction 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool (SFP) Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, inspection (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML15257A188) at Brunswick Steam Electric Plant, Units 1 and 2, 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 No findings were identified.
Additional Tracking Items Type Issue number Title Report Status Section TI TI 2515/191 Inspection of the Implementation of Other Closed Mitigation Strategies and Spent Fuel Pool Activities Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans
TABLE OF CONTENTS
INSPECTION SCOPES
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
INSPECTION RESULTS
..............................................................................................................
EXIT MEETINGS AND DEBRIEFS
.............................................................................................. 6
DOCUMENTS REVIEWED
.......................................................................................................... 7
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedure (IP) 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. Documents reviewed by
inspectors are listed in the documents reviewed section of this report. 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.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool
Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose
Assessment Plans
Inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying
Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis
External Events, (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses With Regard to
Reliable Spent Fuel Pool Instrumentation, (ML12054A679) were in place and were being
implemented by the licensee. Additionally, the inspection verified implementation of staffing and
communications information provided in response to the March 12, 2012, request for
information letter (ML12053A340) and multiunit dose assessment information provided per
COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for
Japan Lessons Learned, dated March 27, 2013 (ML12339A262).
(1) Based on samples selected for review, the inspectors verified that the licensee
satisfactorily implemented appropriate elements of the Diverse and Flexible Coping
Strategies (FLEX) as described in the plant specific submittals and the associated safety
evaluation (ML16335A031) and determined that the licensee is in compliance with NRC
Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation
Strategies for Beyond-Design-Basis External Events (ADAMS Accession No.
ML12056A045). The inspectors verified the licensee satisfactorily:
a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX
strategies for postulated external events;
b) integrated their FSGs into their existing plant procedures such that entry into and
departure from the FSGs were clear when using existing plant procedures;
c) protected FLEX equipment from site-specific hazards;
d) developed and implemented adequate testing and maintenance of FLEX equipment
to ensure their availability and capability;
e) trained their staff to assure personnel proficiency in the mitigation of
beyond-design basis events; and
f) developed the means to ensure the necessary off-site FLEX equipment would be
available from off-site locations.
(2) Based on samples selected for review, the inspectors verified that the licensee
satisfactorily implemented appropriate elements of the FLEX strategy as described in the
plant specific submittals and the associated safety evaluation (ML16335A031) and
determined that the licensee was in compliance with NRC Order NRC Order EA-12-
051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool
Instrumentation (ADAMS Accession No. ML12054A679). The inspectors verified the
licensee satisfactorily:
a) installed the SFP instrumentation sensors, cabling and power supplies to provide
physical and electrical separation as described in the plant specific submittals and
safety evaluation;
b) installed the SFP instrumentation display in the location, environmental conditions
and accessibility as described in the plant specific submittals;
c) trained their staff to assure personnel proficiency with the maintenance, testing, and
use of the SFP instrumentation; and
d) developed and issued procedures for maintenance, testing and use of the reliable
SFP instrumentation.
(3) The inspectors reviewed information provided in the licensees multi-unit dose submittal
and in response to the NRCs March 12, 2012, request for information letter
(ML12053A340), and verified that the licensee satisfactorily implemented enhancements
pertaining to Near-Term Task Force (NTTF) Recommendation 9.3 response to a large
scale natural emergency event that results in an extended loss of all alternating current
(ac) power (ELAP) to all site units and impedes access to the site. The inspectors
verified the following:
a) the licensee satisfactorily implemented required staffing changes to support a
multi-unit ELAP scenario;
b) EP communications equipment and facilities are sufficient for dealing with a
multi-unit ELAP scenario; and
c) the licensee implemented multi-unit dose assessment capabilities (including releases
from SFPs) using the licensees site-specific dose assessment software and
approach.
The inspectors verified that noncompliances with requirements, and standards identified during
the inspection were entered into the licensee's corrective action program as appropriate.
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
No proprietary information was retained by the inspectors or documented in this report.
- On February 1, 2018, the inspectors presented the inspection results to Mr. R. Gideon and
other members of the licensees staff.
- On February 28, 2018, the lead inspector presented the final inspection results to
Mr. L. Grzeck and Mr. T. Sherrill.
DOCUMENTS REVIEWED
Condition Reports Initiated as a Result of the Inspection
CR 2181612, Door blocks
CR 2181431, Flex during hurricane
CR 2181297, Temporary External Flood Barrier Control Labeling
AR 2181247, CR block doors open PRR
CR 2181255, KRRK key control
CR 2181006, low fuel level
AR 2180830, Batt Indication
Procedures
0EOP-01-SEP-01, Primary Containment Venting, Rev. 27
0EOP-01-FSG-02, Portable Pump RPV Injection, Rev. 2
0EOP-01-FSG-04, FLEX Diesel Generator Alignment, Rev. 2
0EOP-01-FSG-05, FLEX Pneumatic Alignment, Rev. 3
0EOP-01-FSG-06, Flex Fuel Oil Transfer, Rev. 1
0EOP-01-FSG-07, Portable Pump Setup and Operation, Rev. 2
0EOP-01-FSG-09, FLEX NSRC Generator Operation, Rev. 2
0EOP-01-SEP-12, Fuel Pool Level Control, Rev. 3
0EOP-01-SEP-14, Fuel Pool Spray, Rev. 2
AD-WC-ALL-0420, Shutdown Risk Management, Rev. 1
0AP-022, BNP Outage Risk Management, Rev. 57
0LP-LT008, VEGAPULS 62 ER Level Transmitter Calibration, Rev. 4
0E&RC-1010, Diesel Fuel Oil Testing Program, Rev. 53
0PLP-01.4, Fukushima Flex System Availability, Action, and Surveillance Requirements, Rev. 5
0AI-68, Brunswick Nuclear Plant Response to Severe Weather Warnings, Rev. 52
0OI-02.3, Drywell Leakage Control, Rev. 7
0E0P-01-UG, Attachment 33, Emergency Operating Procedures Toolbox Inventory Checklists,
Rev. 69
0E0P-01-UG, Attachment 34, FLEX Building Inventory, Rev. 70
2EOP-01-RSP, Station Blackout, Rev. 16
2EOP-01-RVCP, Reactor Vessel Level Control, Rev. 10
AOP-14, Abnormal Primary Containment Condition, Rev. 30
0EOP-01-SBO-02, Attachment 1, Control Room Alternate Ventilation, Rev 6
0EOP-01-FSG-04, FLEX Diesel Generator Alignment, Rev 3. - Battery Room ventilation.
0PEP-04.2, Emergency Facilities and Equipment, Rev. 45
AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment, Rev 6
Drawings
D-25027, Sheet 1A, Reactor Building Reactor Water Cleanup System Piping Diagram, Rev. 27
D-25027, Sheet 1B, Reactor Building Reactor Water Cleanup System Piping Diagram, Rev. 41
LL-09341, Sheet 5, Emergency Power System 120/208 Volts AC, 3Ph, 4W Distribution Panel
2B, Rev. 38
LL-09341, Sheet 4, Emergency Power System 120/208 Volts AC, 3Ph, 4W Distribution Panel
2A, Rev. 31
LL-93041, Sheet 4, Emergency Power System 120/208 Volts AC, 3Ph, 4W Distribution Panel
1B, Rev. 44
SK-89578-Z-7012, Sheet 1, Spent Fuel Pool Level Indication Channel A & B Conduit Routing
Block Diagram, Rev. C
SK-89577-Z-7009, Unit 1 Spent Fuel Pool Elevation View with Levels Indicated, Rev. A
F-02508, Reactor Building Arrangement and Details Fuel Pool, Rev. 9
DE-02515, Sheet 1A and 1D, Reactor Building Containment Atmospheric Control Piping
Diagram, Rev. 68
Calculations
14-4019.010 Finite Element Analysis of Condensate Storage Tanks for Units 1 & 2, Rev. 0
31116-CALC-C-001, Flex Diesel Generator Hardened Enclosure Design, Rev. 7
Work Orders
WO 20143258-01, Monthly Flex Equipment Inspections, dated 12/20/2017
WO 20127524-01, Quarterly Flex Equipment Inspections, dated 10/9/2017
WO 20102559-01, Annual Flex Equipment Inspections, dated 7/25/2017
WO 20138817-01, Biennial Flex Equipment Inspections, dated 7/18/2017
WO 13540928-01, SFP Level Transmitters Calibration 0LP-LT008, dated 3/9/2017
0PEP-04.2, Attachment 1, BNP Monthly Communications Test, Rev 45, Completed 1/11/2018
0PEP-04.2, Attachment 11, Emergency Preparedness Beyond Design Basis External Event
Response Equipment, Rev 45, Completed 12/30/2018
Design Changes
EC 95856R3, BNP Condensate Storage Tank Natural Phenomena Hazards Evaluation, Rev. 3
Corrective Action Documents
1956980 1962602 2017949 2162307 2162314 2162063
2145577 2137711 2120314 2105006 2088489 2093431
1964263 2085580 2167571
Others
Areva Test Plan 51-9225570-001, Through Air Radar Spent Fuel Pool Level Instrument (SFPLI)
Site Acceptance Test (SAT) Plan for Duke Energy, Revision 1
Specification NCP-G-0001, Common Diesel Fuel Oil (Grade 2D) Testing Specification, Rev. 6
CSD-EG-BNP-8888, Mitigating Beyond Design Basis Events (MBDBE) Program Document,
Rev. 3
Vendor Tech Manual for FLEX Diesel Generator
Vendor Tech Manual for FLEX Pump
Vendor Tech Manual for FLEX Air Compressor
TAP-418, Non-Licensed Operator Training Program, Rev. 18
Brunswick Non-Licensed Operator Continuing Training Program, Rev. 1
EPQ-001, Att. 9, Brunswick Nuclear Plant FLEX qualification Checklist, Rev. 21
UFSAR Section 2.4.5, Probable Maximum Surge and Seiche Flooding, Rev. 25
SAFER Response Plan for Brunswick Steam Electric Plant, Rev. 2
Memorandum of Agreement Between Duke Energy Progress (Brunswick) and North Carolina
Emergency Management, dated June 15, 2017
NEI 12-01 Phase 1 Extended Loss of AC (ELAP) ERO Staffing Analysis Report, Rev. 0
Letter, CAROLINA POWER & LIGHT COMPANY'S AND FLORIDA POWER
CORPORATION'S RESPONSE TO FOLLOW-UP LETTER ON TECHNICAL ISSUES
FOR RESOLUTION REGARDING LICENSEE COMMUNICATION SUBMITTALS
ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 9.3 (TAC N
- O.
ME7951), dated Feb 22, 2013
9