IR 05000324/2019010
| ML19184A199 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/02/2019 |
| From: | Bradley Davis NRC/RGN-II/DRP/RPB4 |
| To: | William Gideon Duke Energy Progress |
| References | |
| IR 2019010 | |
| Download: ML19184A199 (10) | |
Text
uly 2, 2019
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000325/2019010 AND 05000324/2019010
Dear Mr. Gideon:
On May 23, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Brunswick Steam Electric Plant, Units 1 and 2, and 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 NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
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/
Bradley J. Davis, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 05000325 and 05000324 License Nos.: DPR-71 and DPR-62
Enclosure:
Inspection Report 05000325/2019010 and 05000324/2019010
Inspection Report
Docket Numbers: 05000325 and 05000324 License Numbers: DPR-71 and DPR-62 Report Numbers: 05000325/2019010 and 05000324/2019010 Enterprise Identifier: I-2019-010-0013 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant Location: Southport, NC Inspection Dates: May 6, 2019 to May 24, 2019 Inspectors: G. Eatmon, Resident Inspector (Team Lead)
S. Seaton, Project Engineer J. Steward, Resident Inspector R. Taylor, Senior Project Engineer Approved By: Bradley J. Davis, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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 No findings were identified.
Additional Tracking Items None.
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 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 - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
- Operating Experience: The inspectors assessed the effectiveness of the stations processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Observation: Corrective Action Program 71152B Corrective Action Program Assessment Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.
Effectiveness of Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating Nuclear Condition Reports (NCRs) as described in licensee procedure AD-PI-ALL-100, "Corrective Action Program," and managements expectation that employees were encouraged to initiate NCRs for any reason. Additionally, site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Inspectors walked down, reviewed NCRs, and reviewed system health trending for the following systems: emergency AC and DC power, high pressure coolant injection, reactor core isolation cooling, containment atmospheric control, reactor protection system, instrument and control circuitry, residual heat removal and low-pressure coolant injection. Based on the inspectors' reviews and walkdowns of accessible portions of those systems, the inspectors determined that deficiencies were being identified and placed in the CAP.
Effectiveness of Prioritization and Evaluation of Issues: Based on the review of NCRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the corrective action program requirements. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had generally conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures, cause determinations were appropriate, and reviews considered the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used to evaluate NCRs depending on the type and complexity of the issue consistent with the applicable cause evaluation procedures.
Effectiveness of Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The team reviewed performance indicators, NCRs, and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
Observation: Use of Operating Experience 71152B The inspectors examined the licensee's program for obtaining and using industry operating experience (OE). This included review of procedure AD-PI-ALL-400, "Operating Experience (OE) Program," selected corrective action program action requests, and the licensees OE database to assess the effectiveness of how external and internal OE data was evaluated at the plant. Additionally, the inspectors selected OE documents such as NRC generic communications, licensee event reports, vendor notifications, and plant internal OE items which had been issued since May 2017 to verify whether the licensee had appropriately evaluated each notification for applicability to the station, and whether issues identified through these reviews were entered into the CAP.
The inspectors determined that licensee's processes for the use of industry and NRC operating experience information were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed.
Observation: Self-Assessments and Audits 71152B The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution.
The inspectors evaluated the self-assessments and audits for the Engineering, Operations, Chemistry and Radiation Protection, Emergency Preparedness, and Maintenance departments. The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.
Observation: Safety Conscious Work Environment 71152B Based on a sample size of approximately 18 people interviewed from a cross-section of plant employees, the team found no evidence of challenges to a safety-conscious work environment. Employees interviewed appeared knowledgeable of avenues to raise safety concerns and appeared willing to raise nuclear safety concerns through at least one of the several means available.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 23, 2019, the inspector presented the biennial problem identification and resolution inspection results to William R. Gideon and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action ACE 2043067 HPCI Aux Oil Pump Motor Overload
Documents ACE 2078244 Unit 1 B1C21/Unit 2 B2C23 Fuel Leak Identified 07/16/2018
ACE 2101084 EDG1 Linkshaft Hydraulic Cylinder Pipe Fitting Leak
ACE 2113066 EDG #4 Overspeed Trip Setpoint Exceeded During PMT
NCRs 2235563, 2221378, 2147485, 2218272, 2273398, 2130274,
2134749, 2141531, 2147349, 2138448, 2147521, 2223615,
2130878, 2130998, 2131762, 2136854, 2157530, 2173000,
2177326, 2204618, 2204786, 2208666, 2212579, 2212857,
213558, 2254859, 2259496, 2260454, 2261445, 2264530,
2132899, 2141836, 2151791, 2152659, 2157127, 2177656,
2191246, 2204223, 2220070, 2220071, 2220072, 2225114,
25219, 2230918, 2254759, 2264848, 2265061, 2265128,
2113800, 2113799, 2073255, 2153101, 2208359, 2121027,
2172725, 2132974, 2239777, 2123657, 2125870, 2216314,
25767, 2237808, 2157530, 22170872, 1964624,
2047836, 2258039, 2259143, 2273398
QCE 2119256 1-CAC-SV-1261 GP6 Valve Found Open After Isolation Sign
QCE 2139056 Maintenance Rule Performance Criteria Exceeded - System
6140 (Atlas Copco Base Air Compressors)
QCE 2157530 2-E41-F001 HPCI Steam Supply Valve Stroked too Fast
QCE 2172700 U2 HPCI 2-E41-F001 HPCI Steam Supply Packing Failure
QCE 721993 DG4 Starting Air Compressor Excessive Run Time
QCE 735820 conventional SW Line 2-SW-100-30-157 Degradation
RCE 02115035- Missed Fire Watch Tour
RCE 2045123 Trip Of 2C CSW Pump
RCE 2217082 BNP OPS Training Station Identified Finding
RCE 598294 RHR Hx A Bypass Valve, 2-E11-F048A, low stress high
cycle fatigue
Inspection Type Designation Description or Title Revision or
Procedure Date
Corrective Action NCRs 2272166, 2272168, 2273609, 2273610, 2274126
Documents Work Request 20142187, 20142188
Resulting from
Inspection
Miscellaneous EN 53123 Event Notification
Operability REW 2172700 2-E41-F001 packing failure past operability evaluation
Evaluations Temperature Unit 2 HPCI Temperature Trace 12/17/2017
Trace
Procedures 0PM-MO504 Mechanical Inspection and Lubrication of Limitorque Revision 44
Operators
1PT-40.2.12 Main Turbine Bypass Valves Operability Test
AD-NO-ALL-0201 Responding to NRC Allegations and Comprehensive Revision 2
Employee Concerns
AD-NO-ALL-0202 Employee Concerns Program Revision 2
AD-NO-ALL-1000 Conduct of Nuclear Oversight Revision 8
AD-OP-ALL-0105 Operability Determinations and Functionality Assessments Revision 4
AD-PI-ALL-0400 Operating Experience Program Revision 7
AD-PI-ALL-100 Corrective Action Program Revision 20
AD-PI-ALL-400 Operating Experience Program Revision 7
Self-Assessments BNP Performance Trending Report (2018 3T) 3/16/2019
2172757-05 Closed Cooling Water 09/01/2018
2018-BNP-EMP- Performance Review Brunswick Emergency Preparedness
PR-01 Audit
2018-BNP- BNP Radiation Protection and Chemistry Audit
RPCH-01
2018-FLEET- 2018 Fleet Corrective Action Program Audit
CAP-01
2083804 Problem Identification and Resolution (PI&R) Assessment 2/9/2017
2089314 2017 BNP EP Program Readiness Pre-Assessment for NRC 05/22/2017
IP71114 Inspection
2171469 Problem Identification and Resolution (PI&R) Readiness 12/7/2018
Assessment
2172756 Analytical QC Program Self-Assessment 11/05/2018
Inspection Type Designation Description or Title Revision or
Procedure Date
BNP-RPS- Radiation Protection Performance Trending Report
1497.02-2018-3
System Health Residual Heat Removal Q1-2019
Report
System Health High Pressure Coolant Injection Q1-2019
Report
System Health Reactor Core Isolation Cooling Q1-2019
Report
Work Orders 20321137,
20319947,
254231,
20192985,
203433,
20159550,
20316016,
20143134,
20188616,
20188562,
10104524
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