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{{#Wiki_filter:January 29, 2008Carolina Power and Light CompanyATTN:Mr. Benjamin WaldrepVice PresidentBrunswick Steam Electric Plant
{{#Wiki_filter:January 29, 2008
Carolina Power and Light Company
ATTN: Mr. Benjamin Waldrep
        Vice President
Brunswick Steam Electric Plant
P. O. Box 10429
P. O. Box 10429
Southport, NC 28461SUBJECT:BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTIONREPORT NOS. 05000324/2007005 AND 05000325/2007005Dear Mr. Waldrep:
Southport, NC 28461
On December 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed aninspection at your Brunswick Units 1 and 2 facilities. The enclosed integrated inspection report
SUBJECT:       BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION
documents the inspection findings, which were discussed on January 22, 2008, with you andother members of your staff. The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.  
              REPORT NOS. 05000324/2007005 AND 05000325/2007005
Dear Mr. Waldrep:
On December 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Brunswick Units 1 and 2 facilities. The enclosed integrated inspection report
documents the inspection findings, which were discussed on January 22, 2008, with you and
other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.On the basis of the results of this inspection, no findings of significance were identified.
personnel.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC's
On the basis of the results of this inspection, no findings of significance were identified.
document system (ADAMS). ADAMS is accessible from the NRC Web site at
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Sincerely,/RA/Randall A. Musser, Chief Reactor Projects Branch 4
and its enclosure will be available electronically for public inspection in the NRC Public
Division of Reactor ProjectsDocket Nos.: 50-325, 50-324License Nos:DPR-71, DPR-62Enclosure:Inspection Report 05000325, 324/2007005w/Attachment: Supplemental Informationcc w/encl: (See page 2)  
Document Room or from the Publicly Available Records (PARS) component of NRC's
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
                                      Sincerely,
                                      /RA/
                                      Randall A. Musser, Chief
                                      Reactor Projects Branch 4
                                      Division of Reactor Projects
Docket Nos.:           50-325, 50-324
License Nos:           DPR-71, DPR-62
Enclosure:     Inspection Report 05000325, 324/2007005
              w/Attachment: Supplemental Information
cc w/encl: (See page 2)
 


OFFICERII:DRPRII:DRPRII:DRPRII:DRSRII:DRSRII:DRSRII:DRS
 
SIGNATURE/RA//RA By e-mail//RA by e-mail//RA/NAMER MusserJ AustinS RutledgeG WilsonDATE1/29/081/30/081/30/081/29/08
OFFICE            RII:DRP        RII:DRP        RII:DRP        RII:DRS      RII:DRS    RII:DRS    RII:DRS
E-MAIL COPY?    YESNO      YESNO      YESNO      YESNO      YESNO      YESNO      YESNO   
SIGNATURE         /RA/           /RA By e-mail/ /RA by e-mail/ /RA/
2 CP&Lcc w/encl:Director, Site Operations
NAME              R Musser        J Austin      S Rutledge    G Wilson
DATE                    1/29/08        1/30/08        1/30/08        1/29/08
E-MAIL COPY?         YES      NO    YES      NO  YES      NO  YES      NO  YES    NO  YES    NO  YES   NO
 
CP&L                                    2
cc w/encl:
Director, Site Operations                 John H. O'Neill, Jr.
Brunswick Steam Electric Plant            Shaw, Pittman, Potts & Trowbridge
Carolina Power & Light Company            2300 N. Street, NW
Electronic Mail Distribution              Washington, DC 20037-1128
J. Paul Fulford, Manager                  Beverly Hall, Chief, Radiation
Performance Evaluation and                Protection Section
Regulatory Affairs PEB 5                N. C. Department of Environment
Carolina Power & Light Company            and Natural Resources
Electronic Mail Distribution              Electronic Mail Distribution
Terry D. Hobbs, Plant General Manager    Peggy Force
Brunswick Steam Electric Plant            Assistant Attorney General
Carolina Power & Light Company            State of North Carolina
P. O. Box 10429                          Electronic Mail Distribution
Southport, NC 28461
                                          Chairman of the North Carolina
Donald L. Griffith                        Utilities Commission
Manager - Training                        c/o Sam Watson, Staff Attorney
Progress Energy Carolinas, Inc.          Electronic Mail Distribution
Brunswick Steam Electric Plant
Brunswick Steam Electric Plant
Carolina Power & Light Company
Electronic Mail Distribution              Robert P. Gruber
Electronic Mail DistributionJ. Paul Fulford, ManagerPerformance Evaluation and
                                          Executive Director
  Regulatory Affairs    PEB 5
Randy C. Ivey                            Public Staff NCUC
Carolina Power & Light Company
Manager - Support Services                4326 Mail Service Center
Electronic Mail DistributionTerry D. Hobbs, Plant General ManagerBrunswick Steam Electric Plant
Progress Energy Carolinas, Inc.           Raleigh, NC 27699-4326
Carolina Power & Light Company
P. O. Box 10429
Southport, NC 28461Donald L. GriffithManager - Training
Progress Energy Carolinas, Inc.
Brunswick Steam Electric Plant
Brunswick Steam Electric Plant
Electronic Mail DistributionRandy C. IveyManager - Support Services
Electric Mail Distribution                Public Service Commission
Progress Energy Carolinas, Inc.
                                          State of South Carolina
Brunswick Steam Electric Plant
Garry D. Miller, Manager                  P. O. Box 11649
Electric Mail DistributionGarry D. Miller, ManagerLicense Renewal
License Renewal                           Columbia, SC 29211
Progress Energy
Progress Energy
Electronic Mail DistributionAnnette H. Pope, SupervisorLicensing/Regulatory Programs
Electronic Mail Distribution              David R. Sandifer
Carolina Power and Light Company
                                          Brunswick County Board of
Electronic Mail DistributionDavid T. ConleyAssociate General Counsel - Legal Dept.
Annette H. Pope, Supervisor                Commissioners
Progress Energy Service Company, LLC
Licensing/Regulatory Programs             P. O. Box 249
Carolina Power and Light Company         Bolivia, NC 28422
Electronic Mail Distribution
                                          Warren Lee
David T. Conley                          Emergency Management Director
Associate General Counsel - Legal Dept.   New Hanover County Department of
Progress Energy Service Company, LLC       Emergency Management
Electronic Mail Distribution              230 Government Center Drive
                                          Suite 115
James Ross                                Wilmington, NC 28403
Nuclear Energy Institute
Electronic Mail Distribution
Electronic Mail Distribution
James RossNuclear Energy Institute
 
Electronic Mail DistributionJohn H. O'Neill, Jr.Shaw, Pittman, Potts & Trowbridge
CP&L                                        3
2300 N. Street, NW
Report to Ben Waldrep from Randall A. Musser dated January 29, 2008
Washington, DC  20037-1128Beverly Hall, Chief, RadiationProtection Section
SUBJECT:       BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION
N. C. Department of Environment
                REPORT NOS. 05000324/2007005 AND 05000325/2007005
  and Natural Resources
Distribution w/encl:
Electronic Mail Distribution Peggy ForceAssistant Attorney General
S. Bailey, NRR
State of North Carolina
Electronic Mail DistributionChairman of the North Carolina  Utilities Commission
c/o Sam Watson, Staff Attorney
Electronic Mail DistributionRobert P. GruberExecutive Director
Public Staff  NCUC
4326 Mail Service Center
Raleigh, NC  27699-4326Public Service CommissionState of South Carolina
P. O. Box 11649
Columbia, SC  29211David R. SandiferBrunswick County Board of
  Commissioners
P. O. Box  249
Bolivia, NC  28422Warren LeeEmergency Management Director
New Hanover County Department of
  Emergency Management
230 Government Center Drive
Suite 115
Wilmington, NC  28403
3 CP&LReport to Ben Waldrep from Randall A. Musser dated January 29, 2008SUBJECT:BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTIONREPORT NOS. 05000324/2007005 AND 05000325/2007005Distribution w/encl
:S. Bailey, NRR
R. Pascarelli, NRR
R. Pascarelli, NRR
C. Evans, RII
C. Evans, RII
L. Slack, RII  
L. Slack, RII
RIDSNRRDIRS
RIDSNRRDIRS
OE Mail
OE Mail
PUBLICNRC Resident InspectorU.S. Nuclear Regulatory Commission
PUBLIC
NRC Resident Inspector
U.S. Nuclear Regulatory Commission
8470 River Road, SE
8470 River Road, SE
Southport, NC 28461  
Southport, NC 28461
EnclosureU. S. NUCLEAR REGULATORY COMMISSIONREGION IIDocket Nos:50-325, 50-324License Nos:DPR-71, DPR-62
 
Report Nos:05000325/2007005 and 05000324/2007005
            U. S. NUCLEAR REGULATORY COMMISSION
Licensee:Carolina Power and Light (CP&L)
                                REGION II
Facility:Brunswick Steam Electric Plant, Units 1 & 2
Docket Nos:       50-325, 50-324
Location:8470 River Road SESouthport, NC 28461Dates:October 1, 2007 through December 31, 2007
License Nos:       DPR-71, DPR-62
Inspectors:J. Austin, Senior Resident InspectorS. Rutledge, Resident Inspector  
Report Nos:       05000325/2007005 and 05000324/2007005
Approved by:Randall A. Musser, Chief Reactor Projects Branch 4
Licensee:         Carolina Power and Light (CP&L)
Division of Reactor Projects  
Facility:         Brunswick Steam Electric Plant, Units 1 & 2
EnclosureSUMMARY OF FINDINGSIR 05000325/2007005, 05000324/2007005; 10/01/07- 12/31/07;  Brunswick SteamElectric Plant, Units 1 and 2.The report covered a 3-month period of inspection by resident inspectors and one seniorreactor inspector.  One Green non-cited violation (NCV) was identified.  The significanceof most findings is indicated by their color (Green, White, Yellow, Red) using Inspection
Location:         8470 River Road SE
Manual Chapter (IAC) 0609, "Significance Determination Process" (SDP).  The NRC's
                  Southport, NC 28461
program for overseeing the safe operation of commercial nuclear power reactors is
Dates:             October 1, 2007 through December 31, 2007
described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December
Inspectors:       J. Austin, Senior Resident Inspector
                  S. Rutledge, Resident Inspector
Approved by:       Randall A. Musser, Chief
                  Reactor Projects Branch 4
                  Division of Reactor Projects
                                                              Enclosure


2006.A.NRC-Identified and Self-Revealing FindingsNONEB.Licensee-Identified FindingsNONE
                                SUMMARY OF FINDINGS
EnclosureREPORT DETAILSSummary of Plant StatusUnit 1Unit 1 began the inspection period operating at full power. On October 6, power wasreduced to 93 percent to perform a control rod improvement. The unit was restored to
  IR 05000325/2007005, 05000324/2007005; 10/01/07- 12/31/07; Brunswick Steam
full power the same day. On October 13, power was reduced to 93 percent to perform a
  Electric Plant, Units 1 and 2.
control rod improvement. The unit was returned to full power the same day. On
  The report covered a 3-month period of inspection by resident inspectors and one senior
October 20, power was reduced to 93 percent to perform a control rod improvement.  
  reactor inspector. One Green non-cited violation (NCV) was identified. The significance
Full power was restored the same day. On October 27, power was reduced to 93
  of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection
percent to perform a control rod improvement. Full power was achieved later that day.  
  Manual Chapter (IAC) 0609, Significance Determination Process (SDP). The NRC's
On November 3, power was reduced to 67 percent to facilitate valve testing. The unit
  program for overseeing the safe operation of commercial nuclear power reactors is
was returned to full power later that day. On November 4, power was reduced to 95
  described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December
percent to perform a control rod improvement. Full power was restored on November 5.  
  2006.
A. NRC-Identified and Self-Revealing Findings
  NONE
B. Licensee-Identified Findings
  NONE
                                                                                    Enclosure
 
                                REPORT DETAILS
Summary of Plant Status
Unit 1
Unit 1 began the inspection period operating at full power. On October 6, power was
reduced to 93 percent to perform a control rod improvement. The unit was restored to
full power the same day. On October 13, power was reduced to 93 percent to perform a
control rod improvement. The unit was returned to full power the same day. On
October 20, power was reduced to 93 percent to perform a control rod improvement.
Full power was restored the same day. On October 27, power was reduced to 93
percent to perform a control rod improvement. Full power was achieved later that day.
On November 3, power was reduced to 67 percent to facilitate valve testing. The unit
was returned to full power later that day. On November 4, power was reduced to 95
percent to perform a control rod improvement. Full power was restored on November 5.
On November 11, power was reduced to 90 percent to perform a control rod
On November 11, power was reduced to 90 percent to perform a control rod
improvement. Full power was achieved later that day. On November 16, power was
improvement. Full power was achieved later that day. On November 16, power was
reduced to 91 percent to perform a control rod improvement. The unit was returned to
reduced to 91 percent to perform a control rod improvement. The unit was returned to
full power November 17. On November 24, power was reduced to 90 percent for control
full power November 17. On November 24, power was reduced to 90 percent for control
rod testing. Full power was restored later that day. The unit remained at full power for
rod testing. Full power was restored later that day. The unit remained at full power for
the remainder of the inspection period.Unit 2Unit 2 began the inspection period operating at full power. On October 1, a powerascension occurred from main turbine valve testing. Full power was restored later that
the remainder of the inspection period.
day.   On October 1, power was reduced to 95 percent to perform a control rod
Unit 2
improvement. Full power was restored later that day. On October 1, power was
Unit 2 began the inspection period operating at full power. On October 1, a power
reduced to 96 percent to perform a control rod improvement. The unit was returned to
ascension occurred from main turbine valve testing. Full power was restored later that
full power later that day. On October 2, power was reduced to 98 percent to perform a
day. On October 1, power was reduced to 95 percent to perform a control rod
control rod improvement. Full power was restored later that day. On November 8,
improvement. Full power was restored later that day. On October 1, power was
power was reduced to 71 percent for a Whiteville line outage. Power was returned to
reduced to 96 percent to perform a control rod improvement. The unit was returned to
full later that day. On November 9, power was reduced to 98 percent for a control rod
full power later that day. On October 2, power was reduced to 98 percent to perform a
improvement. Full power was restored later that day. On November 17, power was
control rod improvement. Full power was restored later that day. On November 8,
reduced to 68 percent for main turbine valve, reactor feed pump and scram time testing.  
power was reduced to 71 percent for a Whiteville line outage. Power was returned to
The unit was returned to full power on November 18. On November 18, power was
full later that day. On November 9, power was reduced to 98 percent for a control rod
improvement. Full power was restored later that day. On November 17, power was
reduced to 68 percent for main turbine valve, reactor feed pump and scram time testing.
The unit was returned to full power on November 18. On November 18, power was
reduced to 94 percent for xenon build-up following main turbine valve testing and control
reduced to 94 percent for xenon build-up following main turbine valve testing and control
rod sequence exchange. Full power was returned on November 19. On November 19,
rod sequence exchange. Full power was returned on November 19. On November 19,
power was reduced to 85 percent to perform a control rod improvement. Full power was
power was reduced to 85 percent to perform a control rod improvement. Full power was
restored November 20. On November 20, power was reduced to 95 percent to perform
restored November 20. On November 20, power was reduced to 95 percent to perform
a control rod improvement. Full power was achieved November 21, 2007. The unit
a control rod improvement. Full power was achieved November 21, 2007. The unit
remained at full power for the remainder of the inspection period.  
remained at full power for the remainder of the inspection period.
3Enclosure1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, Barrier Integrity1R01Adverse Weather Protection    a.Inspection ScopeThe inspectors assessed the effectiveness of the licensee's cold weather protectionprogram as it related to ensuring that the facility's service water pumps, emergency
                                                                                Enclosure
diesel generators, and condensate storage tank low level switches would remain
functional and available in cold weather conditions.  In addition to reviewing the
licensee's program-related documents and procedures, walkdowns were conducted of
the freeze protection equipment (e.g., heat tracing, area space heaters, etc.) associated
with the above systems/components.  Licensee problem identification and resolution
associated with cold weather protections was also assessed.  *AR 246713, Unit 2 condensate storage tank heat trace inoperable*AR 253047, Emergency diesel generator #1 jacket water heater temperatureswitch    b.FindingsNo findings of significance were identified.1R04Equipment Alignment .1Partial System Walkdowns    a.Inspection ScopeThe inspectors performed three partial walkdowns of the below-listed systems to verifythat the systems were correctly aligned while the redundant train or system was
inoperable or out-of-service (OOS) or, for single train risk significant systems, while the
system was available in a standby condition.  The inspectors assessed conditions such
as equipment alignment (i.e., valve positions, damper positions, and breaker alignment)
and system operational readiness (i.e., control power and permissive status) that could
affect operability.  The inspectors verified that the licensee identified and resolved
equipment alignment problems that could cause initiating events or impact mitigating
system availability.  The inspectors reviewed Administrative Procedure
ADM-NGGC-0106, Configuration Management Program Implementation, to verify that
available structures, systems or components (SSCs) met the requirements of the
configuration control program.  Documents reviewed are listed in the Attachment.*2A Nuclear service water pump when the 2B nuclear service water pump wasOOS for scheduled maintenance on October 3, 2007
4Enclosure*Unit 2 RCIC when the Unit 2 HPCI was OOS for seal repair on October 15, 2007 *EDG #2, #3, and #4 while EDG #1 was OOS for scheduled maintenance onNovember 19, 2007To assess the licensee's ability to identify and correct problems, the inspectors reviewedthe following Action Requests (ARs):*AR 251684, RCIC extent of condition evaluation using Panametrics*AR 252203, U2 RCIC seal purge line orifice missing
*AR 259682, U1 RCIC steam supply drain pot steam leak
*AR 254033, EDG starting air pilot air lines support discrepancies
*AR 254280, EDG #3 brush inspection meg readings
*AR 259504, EDG #1 generator vibration alarm
 
    b.FindingsNo findings of significance were identified. .2Complete System Walkdown    a.Inspection ScopeThe inspectors conducted a detailed review of the alignment and condition of the Unit 2high pressure coolant injection system.  The inspector reviewed the Updated Final
Safety Analysis Report, associated attachments of Operating Procedure 2OP-19, High
Pressure Coolant Injection System Operating Procedure, 0PT-09.2, HPCI System
Operability Test and the systems diagrams (drawing numbers D-02523 and LL-09272)
in determining correct system lineup.  The inspectors also reviewed maintenance history
of the system. To assess the licensee's identification and resolutions of problems, the inspectorsreviewed the following:*AR 250203, HPCI inoperable due to pump seal leakage*AR 225856, HPCI lube oil coolers debris
*AR 229349, HPCI condensate pump trip
*AR 251647, U2 HPCI vacuum tank level issues
*AR 251490, Water in U2 HPCI lube oil    b.FindingsNo findings of significance were identified.
5Enclosure1R05Fire Protection .1Fire Area Walkdowns    a.Inspection ScopeThe inspectors reviewed ARs and work orders (WOs) associated with the firesuppression system to confirm that their disposition was in accordance with Procedure
0AP-033, Fire Protection Program Manual.  The inspectors reviewed the status of
ongoing surveillance activities to verify that they were current to support the operability
of the fire protection system.  In addition, the inspectors observed the fire suppression
and detection equipment to determine whether any conditions or deficiencies existed
which would impair the operability of that equipment.  The inspectors toured the
following six areas important to reactor safety and reviewed the associated prefire plans
to verify that the requirements for fire protection design features, fire area boundaries,
and combustible loading were met.  Documents reviewed are listed in the Attachment.*Units 1 and 2 Control Building, - 49' elevation (2 areas)*Units 1 and 2 Control Building, - 23' elevation (2 areas)
*Units 1 and 2 Reactor Building - 17' elevation (2 areas)


    b.FindingsNo findings of significance were identified. .2Fire Drill    a.Inspection ScopeOn October 6, 2007, the inspectors observed a plant fire drill at the auxiliary boiler unitlocated outside near the Emergency Diesel Generator Building, to assess the firebrigade performance and to verify that proper firefighting techniques for the type of fireencountered were utilized.  The inspectors monitored the fire brigade's use of protectiveequipment and firefighting equipment to verify that preplanned firefighting proceduresand appropriate firefighting techniques were used, and to verify that the directions of thefire brigade leader were thorough, clear, and effective.  The inspectors attended thecritique to confirm that appropriate feedback on performance was provided to brigademembers and to ensure that areas for improvement were properly identified for licenseefollow-up. In preparing for the drill, the inspectors reviewed the preplanned drillscenario, Brunswick Nuclear Plant Drill Scenario Guide, 99-F-0S, Revision 1.     b.FindingsNo findings of significance were identified.  
                                                3
6Enclosure1R06Flood Protection Measures .1Internal Flooding   a.Inspection ScopeThe inspectors reviewed the licensee's internal flooding analysis as described inUpdated Final Safety Analysis Report (UFSAR) Section 3.4.2, Protection From InternalFlooding.  Due to the risk significance of equipment in the Service Water and
1.     REACTOR SAFETY
Emergency Diesel Generator Buildings, the inspectors reviewed UFSAR Section 3.4.2
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
analysis of the effects of postulated piping failures for these two areas to determine if
1R01 Adverse Weather Protection
the analysis assumptions and conclusions were based on the current plant
    a. Inspection Scope
configuration. The internal flooding design features and equipment for coping with
      The inspectors assessed the effectiveness of the licensees cold weather protection
internal flooding was inspected for the equipment located in these buildings. The
      program as it related to ensuring that the facilitys service water pumps, emergency
walkdown included sources of flooding and drainage, sump pumps, level switches,
      diesel generators, and condensate storage tank low level switches would remain
watertight doors, curbs, pedestals and equipment mounting. Documents reviewed are
      functional and available in cold weather conditions. In addition to reviewing the
listed in the Attachment.   b.    FindingsNo findings of significance were identified. .2External Flooding    a.Inspection ScopeThe inspectors reviewed the licensee's external flooding analysis as described inUFSAR Section 3.4.1, Protection from External Flooding, to determine the external flood
      licensees program-related documents and procedures, walkdowns were conducted of
control design features.  Walkdowns were conducted to inspect the external flood
      the freeze protection equipment (e.g., heat tracing, area space heaters, etc.) associated
protection barriers including watertight doors, curbs, sealing of external building
      with the above systems/components. Licensee problem identification and resolution
penetrations below flood line, and the sump pumps and level alarm circuits.  Areas
      associated with cold weather protections was also assessed.
reviewed included the Emergency Diesel Generator Building, and the Service Water
      *      AR 246713, Unit 2 condensate storage tank heat trace inoperable
Building.  The inspector reviewed the procedures for coping with external flooding
      *      AR 253047, Emergency diesel generator #1 jacket water heater temperature
contained in Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During
              switch
Hurricane, Flood Conditions, Tornado, or Earthquake.  Other documents reviewed are
     b. Findings
listed in the Attachment.    b.   FindingsNo findings of significance were identified.  
      No findings of significance were identified.
7Enclosure1R11Licensed Operator Requalification .1Quarterly Review   a.Inspection ScopeThe inspectors observed licensed operator performance and reviewed the associatedtraining documents during annual dynamic simulator examination sessions for trainingcycle 2007-05. The simulator observations and review included evaluations of
1R04 Equipment Alignment
emergency operating procedure and abnormal operating procedure utilization.  The
.1   Partial System Walkdowns
inspectors reviewed Procedure 0TPP-200, Licensed Operator Continuing Training
    a. Inspection Scope
Program, to verify that the program ensures safe power plant operation.  Simulator
      The inspectors performed three partial walkdowns of the below-listed systems to verify
sessions were observed on November 20, 2007. The scenarios tested the operators'
      that the systems were correctly aligned while the redundant train or system was
ability to respond to secondary plant failures, loss of emergency power, and an
      inoperable or out-of-service (OOS) or, for single train risk significant systems, while the
automatic trip without a scram followed by a rupture of the scram discharge volume.  
      system was available in a standby condition. The inspectors assessed conditions such
The inspectors reviewed operator activities to verify consistent clarity and formality of
      as equipment alignment (i.e., valve positions, damper positions, and breaker alignment)
communication, conservative decision-making by the crew, appropriate use of
      and system operational readiness (i.e., control power and permissive status) that could
procedures, and proper alarm response.  Group dynamics and supervisory oversight,
      affect operability. The inspectors verified that the licensee identified and resolved
including the ability to properly identify and implement appropriate Technical
      equipment alignment problems that could cause initiating events or impact mitigating
Specification (TS) actions, regulatory reports, and notifications, were observed. The
      system availability. The inspectors reviewed Administrative Procedure
inspectors observed instructor critiques and preliminary grading of the operating crews
      ADM-NGGC-0106, Configuration Management Program Implementation, to verify that
and assessed whether appropriate feedback was planned to be provided to the licensed
      available structures, systems or components (SSCs) met the requirements of the
operators.      b.FindingsNo findings of significance were identified.1R12Maintenance Effectiveness    a.Inspection ScopeFor the two equipment issues described in the ARs listed below, the inspectors reviewedthe licensee's implementation of the Maintenance Rule (10 CFR 50.65) with respect tothe characterization of failures, the appropriateness of the associated Maintenance Rulea(1) or a(2) classification, and the appropriateness of the associated a(1) goals andcorrective actions. The inspectors reviewed the work controls and work practicesassociated with the degraded performance or condition to verify that they wereappropriate and did not contribute to the issue. The inspectors also reviewed operationslogs and licensee event reports to verify unavailability times of components andsystems, if applicable.  Licensee performance was evaluated against the requirementsof Procedure ADM-NGGC-0101, Maintenance Rule Program.
      configuration control program. Documents reviewed are listed in the Attachment.
*AR 242066, BNP response to operating experience 2007-08 degradation ofburied piping*AR 256103, Loss of full out indications on the full core display
      *      2A Nuclear service water pump when the 2B nuclear service water pump was
8Enclosure    b.FindingsNo findings of significance were identified.1R13Maintenance Risk Assessments and Emergent Work Evaluation   a.Inspection ScopeThe inspectors reviewed the licensee's implementation of 10 CFR 50.65 (a)(4)requirements during scheduled and emergent maintenance activities, using Procedure
              OOS for scheduled maintenance on October 3, 2007
0AP-025, BNP Integrated Scheduling and Technical Requirements Manual 5.5.13,
                                                                                          Enclosure
Configuration Risk Management Program. The inspectors reviewed the effectiveness of
 
risk assessments performed due to changes in plant configuration for maintenance
                                                4
activities (planned and emergent).  The review was conducted to verify that, upon
      *        Unit 2 RCIC when the Unit 2 HPCI was OOS for seal repair on October 15, 2007
unforseen situations, the licensee had taken the necessary steps to plan and control the
      *        EDG #2, #3, and #4 while EDG #1 was OOS for scheduled maintenance on
resultant emergent work activities. The inspectors reviewed the applicable plant risk
              November 19, 2007
profiles, work week schedules, and maintenance WOs for the following five conditions:*AR 250203, HPCI inoperable due to pump seal leakage*AR 255545, Unexpected annunciators during performance test (PT-12.2a) forEDG #1*AR 257721, Unit 1 condensate storage tank instrumental vent line excessive
      To assess the licensees ability to identify and correct problems, the inspectors reviewed
sloping*AR 257744, EDG #3 jacket water leakage from flexmaster jumpers
      the following Action Requests (ARs):
*AR 256079, 1-E11-F017B inoperable due to high energy line break issues at themotor control cubicle compartment    b.FindingsNo findings of significance were identified.1R15Operability Evaluations   a.Inspection ScopeThe inspectors reviewed the operability evaluations associated with the six issuesdocumented in the ARs listed below, which affected risk significant systems or
      *        AR 251684, RCIC extent of condition evaluation using Panametrics
components, to assess, as appropriate:  1) the technical adequacy of the evaluations; 2)
      *        AR 252203, U2 RCIC seal purge line orifice missing
the justification of continued system operability; 3) any existing degraded conditions
      *        AR 259682, U1 RCIC steam supply drain pot steam leak
used as compensatory measures; 4) the adequacy of any compensatory measures in
      *        AR 254033, EDG starting air pilot air lines support discrepancies
place, including their intended use and control; and 5) where continued operability was
      *        AR 254280, EDG #3 brush inspection meg readings
considered unjustified, the impact on any TS limiting condition for operation and the risk
      *        AR 259504, EDG #1 generator vibration alarm
significance. In addition to the reviews, discussions were conducted with the applicable
  b. Findings
system engineer regarding the ability of the system to perform its intended safety
      No findings of significance were identified.
function.
.2    Complete System Walkdown
9Enclosure*AR 249130, 1A Residual heat removal heat exchanger degradation duringtesting (OPF08.1.4A) *AR 245864, E-4 Loss of coolant accident logic relay 27E2 de-energized*AR 250793, Unit 2 RCIC operability concern
   a. Inspection Scope
*AR 252203, Unit 2 RCIC seal purge line orifice missing
      The inspectors conducted a detailed review of the alignment and condition of the Unit 2
*AR 251885, Unit 2 HPCI main pump seal leak exceeds posting
      high pressure coolant injection system. The inspector reviewed the Updated Final
*AR 251490, Water in Unit 2 HPCI lube oil    b.FindingsNo findings of significance were identified.1R19Post-Maintenance Testing    a.Inspection ScopeFor the five maintenance activities listed below, the inspectors reviewed the post-maintenance test procedure and witnessed the testing and/or reviewed test records to
      Safety Analysis Report, associated attachments of Operating Procedure 2OP-19, High
confirm that the scope of testing adequately verified that the work performed was
      Pressure Coolant Injection System Operating Procedure, 0PT-09.2, HPCI System
correctly completed. The inspectors verified that the test demonstrated that the affected
      Operability Test and the systems diagrams (drawing numbers D-02523 and LL-09272)
equipment was capable of performing its intended function and was operable in
      in determining correct system lineup. The inspectors also reviewed maintenance history
accordance with TS requirements. The inspectors reviewed the licensee's actions
      of the system.
against the requirements in Procedure 0PLP-20, Post Maintenance Testing Program. *PT 9.2 HPCI Operability Test following inboard seal failure*WO 114145 RCIC system fill and vent after pump maintenance
      To assess the licensees identification and resolutions of problems, the inspectors
*WO 1137349 Inspection of HPCI sump after drain down
      reviewed the following:
*AR 250499, Basis for changing piping test plan not understood
      *        AR 250203, HPCI inoperable due to pump seal leakage
*AR 247456, Balance of plant under-voltage relays not tested as required    b.FindingsNo findings of significance were identified.
      *        AR 225856, HPCI lube oil coolers debris
1R22Surveillance Testing .1Routine Surveillance Testing    a.Inspection ScopeThe inspectors either observed surveillance tests or reviewed test data for the three risk
      *        AR 229349, HPCI condensate pump trip
significant SSC surveillances, listed below, to verify the tests met TS surveillance
      *        AR 251647, U2 HPCI vacuum tank level issues
requirements, UFSAR commitments, in-service testing (IST) requirements, and licensee
      *        AR 251490, Water in U2 HPCI lube oil
procedural requirements. The inspectors assessed the effectiveness of the tests in
  b. Findings
demonstrating that the SSCs were operationally capable of performing their intended
      No findings of significance were identified.
safety functions.  
                                                                                      Enclosure
10Enclosure*0PT-09.2mst-HPCI 23Q, High Pressure Coolant Injection System operability test,performed on Unit 2 on October 22, 2007 *2O1-03.2, Control Operator Daily Surveillance Report (including drywell leakagerate determination), performed the week of November 12, 2007.0PT-9.3a, High Pressure Coolant Injection System Component Test, performedon Unit 1 on December 7, 2007.     b. FindingsNo findings of significance were identified. .2In-service Surveillance Testing    a.Inspection ScopeThe inspectors reviewed the performance of Periodic Test 0PT-9.7, High PressureCoolant Injection System Valve Operability Test, performed on Unit 1 on December 7,2007.  The inspectors evaluated the effectiveness of the licensee's American Society ofMechanical Engineers (ASME) Section XI testing program to determine equipmentavailability and reliability.  The inspectors evaluated selected portions of the followingareas: 1) testing procedures; 2) acceptance criteria; 3) testing methods; 4) compliancewith the licensee's IST program, TS, selected licensee commitments, and coderequirements; 5) range and accuracy of test instruments; and 6) required correctiveactions. The inspectors also assessed any applicable corrective actions taken.To assess the licensee's ability to identify and correct problems, the inspector reviewedAR 214876 which documented that the Unit 1 A conventional service water pump wasdiscovered to be in the Alert range following testing on November 30, 2006.    b.FindingsNo findings of significance were identified.1EP6Drill Evaluation   a.Inspection ScopeThe inspectors observed site emergency preparedness training drill/simulator scenariosconducted on October 30, 2007 and November 8, 2007.  The inspectors reviewed the
 
drill scenario narrative to identify the timing and location of classifications, notifications,
                                                  5
and protective action recommendations development activities. The inspectors
1R05 Fire Protection
evaluated the drill conduct from the control room simulator, technical support center,
.1    Fire Area Walkdowns
and the emergency operations facility. During the drill, the inspectors assessed the
    a. Inspection Scope
adequacy of event classification and notification activities. The inspectors observed
      The inspectors reviewed ARs and work orders (WOs) associated with the fire
portions of the licensee's post-drill critiques at the technical support center and
      suppression system to confirm that their disposition was in accordance with Procedure
emergency operating facility.
      0AP-033, Fire Protection Program Manual. The inspectors reviewed the status of
11EnclosureThe inspectors verified that the licensee properly evaluated the drill's performance withrespect to performance indicators and assessed drill performance with respect to drill
      ongoing surveillance activities to verify that they were current to support the operability
objectives. To assess the ability of the licensee to identify and correct problems, the
      of the fire protection system. In addition, the inspectors observed the fire suppression
inspectors reviewed the following corrective action documents that were generated as a
      and detection equipment to determine whether any conditions or deficiencies existed
result of the drill:*AR 252936, knowledge gap in the required actions associated with the ReactorBuilding positive pressure as defined in AST documentation*AR 252937, rewording of SPDS indication to prevent human error
      which would impair the operability of that equipment. The inspectors toured the
*AR 254108, JIC positions not filled during ERO drill    b.FindingsNo findings of significance were identified.
      following six areas important to reactor safety and reviewed the associated prefire plans
    
      to verify that the requirements for fire protection design features, fire area boundaries,
1R23Temporary Plant Modifications    a.Inspection ScopeThe inspectors reviewed Operating Manual 0PLP-22, Temporary Changes, to assessthe implementation of Engineering Change (EC) 67830, Reactor Core Isolation CoolingSystem Low Suction Pressure Trip Delay which was implemented on October 21, 2007. The inspectors reviewed the EC to verify that the modification did not affect thefunctional capability of the EDG, that the modification was properly installed, andappropriate post-installation testing was performed.    b.FindingsNo findings of significance were identified.4.OTHER ACTIVITIES
      and combustible loading were met. Documents reviewed are listed in the Attachment.
4OA1Performance Indicator (PI) Verification    a.  Inspection ScopeThe inspectors sampled licensee data for the performance indicators (PIs) listed below. To verify the accuracy of the PI data reported during the period reviewed, PI definitions
      *        Units 1 and 2 Control Building, - 49' elevation (2 areas)
and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev.
      *       Units 1 and 2 Control Building, - 23' elevation (2 areas)
5 were used to verify the basis for each data element.Reactor Safety CornerstoneThe inspectors sampled licensee submittals for the Units 1 and 2 PIs listed below for theperiod January 2007 through November 2007.
      *       Units 1 and 2 Reactor Building - 17' elevation (2 areas)
12Enclosure*High Pressure Coolant Injection System*Reactor Core Isolation Cooling System A sample of plant records and data was reviewed and compared to the reported data toverify the accuracy of the PIs.  The licensee's corrective action program records were
    b. Findings
also reviewed to determine if any problems with the collection of PI data had occurred.
      No findings of significance were identified.
Documents reviewed are listed in the Attachment.    b.FindingsNo findings of significance were identified.4OA2Identification and Resolution of Problems .1Routine Review of ARsTo aid in the identification of repetitive equipment failures or specific humanperformance issues for followup, the inspectors performed frequent screenings of items
.2   Fire Drill
entered into the licensee's CAP. The review was accomplished by reviewing daily ARs. .2Annual Sample Review    a.Inspection ScopeThe inspectors performed an in-depth annual sample review of plant operatorworkarounds as documented in licensee's operator workaround program and corrective
    a. Inspection Scope
action documents. This review was performed to verify that the licensee identified
      On October 6, 2007, the inspectors observed a plant fire drill at the auxiliary boiler unit
operator workarounds at an appropriate threshold, entered the issues into the CAP, and
      located outside near the Emergency Diesel Generator Building, to assess the fire
planned or implemented appropriate corrective actions.  The inspectors reviewed the
      brigade performance and to verify that proper firefighting techniques for the type of fire
actions taken to verify that the licensee had adequately addressed the following
      encountered were utilized. The inspectors monitored the fire brigades use of protective
attributes:*Complete, accurate, and timely identification of the problem *Evaluation and disposition of operability and reportability issues
      equipment and firefighting equipment to verify that preplanned firefighting procedures
*Consideration of previous failures, extent of condition, generic or common causeimplications*Prioritization and resolution of the issue commensurate with the safetysignificance*Identification of the root cause and contributing causes of the problem
      and appropriate firefighting techniques were used, and to verify that the directions of the
*Identification and implementation of corrective actions commensurate with thesafety significance of the issue The inspectors reviewed the associated corrective action for AR 250203, Unit 2 highpressure coolant injection pump seal failure that occurred on October 10, 2007.
      fire brigade leader were thorough, clear, and effective. The inspectors attended the
13Enclosure    b.Findings and ObservationsNo findings of significance were identified. .3 Semi-Annual Trend Review    a.Inspection ScopeThe inspectors performed a review of the licensee's CAP and associated documents toidentify trends that could indicate the existence of a more significant safety issue. Thereview was focused on repetitive equipment issues but also considered the results offrequent inspector CAP item screening (discussed above), licensee trending efforts, andlicensee human performance results.  The review considered the period of July throughDecember 2007. The review further included issues documented outside the normalCAP in major equipment lists, repetitive and/or rework maintenance lists, operationalfocus list, control room deficiency list, outstanding work order list, quality assuranceaudit/surveillance reports, key performance indicators, and self-assessment reports. The inspectors compared and contrasted their results with the results contained inmultiple root cause evaluations the licensee has performed over the last 2 quarters. Corrective actions associated with a sample of the issues identified in the licensee'strend reports were reviewed for adequacy.  The inspectors also evaluated the reportsagainst the requirements of the licensee's CAP as specified in Nuclear GenerationGroup Standard Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR50, Appendix B.      b.Assessment and ObservationsNo findings of significance were identified. The inspectors noted a trend in the controland retrieval of foreign material in systems and the adverse effects this has had onsystem performance; this was exemplified by the following identified issues:1) Foreign material found in the 1B Residual Heat Removal (RHR) Room cooler(AR243465); 2) Metallic foreign material found in the 1B RHR Heat Exchanger(AR246790); 3) 1D RHRSW Booster pump failed to start was bound by valve pin (AR243867); 4) Unit 2 HPCI main pump inboard seal failure due to blockage of seal coolingline (AR250203). The inspectors have determined that the licensee has addressed allimmediate operability concerns, and is currently developing long-term improvements.4OA6Meetings, Including ExitExit Meeting SummaryOn January 24, 2008, the resident inspectors presented the inspection results toMr. Waldrep and other members of his staff.  The inspectors confirmed that proprietaryinformation was not provided or examined during the inspection.ATTACHMENT:  SUPPLEMENTAL INFORMATION
      critique to confirm that appropriate feedback on performance was provided to brigade
AttachmentSUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicensee PersonnelG. Atkinson, Supervisor - Emergency PreparednessL. Beller, Superintendent Operations Training  
      members and to ensure that areas for improvement were properly identified for licensee
A. Brittain, Manager - Security  
      follow-up. In preparing for the drill, the inspectors reviewed the preplanned drill
D. Griffith, Manager - Training Manager  
      scenario, Brunswick Nuclear Plant Drill Scenario Guide, 99-F-0S, Revision 1.
    b. Findings
      No findings of significance were identified.
                                                                                        Enclosure
 
                                                6
1R06 Flood Protection Measures
.1   Internal Flooding
    a. Inspection Scope
      The inspectors reviewed the licensees internal flooding analysis as described in
      Updated Final Safety Analysis Report (UFSAR) Section 3.4.2, Protection From Internal
      Flooding. Due to the risk significance of equipment in the Service Water and
      Emergency Diesel Generator Buildings, the inspectors reviewed UFSAR Section 3.4.2
      analysis of the effects of postulated piping failures for these two areas to determine if
      the analysis assumptions and conclusions were based on the current plant
      configuration. The internal flooding design features and equipment for coping with
      internal flooding was inspected for the equipment located in these buildings. The
      walkdown included sources of flooding and drainage, sump pumps, level switches,
      watertight doors, curbs, pedestals and equipment mounting. Documents reviewed are
      listed in the Attachment.
    b. Findings
      No findings of significance were identified.
.2   External Flooding
    a. Inspection Scope
      The inspectors reviewed the licensees external flooding analysis as described in
      UFSAR Section 3.4.1, Protection from External Flooding, to determine the external flood
      control design features. Walkdowns were conducted to inspect the external flood
      protection barriers including watertight doors, curbs, sealing of external building
      penetrations below flood line, and the sump pumps and level alarm circuits. Areas
      reviewed included the Emergency Diesel Generator Building, and the Service Water
      Building. The inspector reviewed the procedures for coping with external flooding
      contained in Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During
      Hurricane, Flood Conditions, Tornado, or Earthquake. Other documents reviewed are
      listed in the Attachment.
    b. Findings
      No findings of significance were identified.
                                                                                        Enclosure
 
                                                  7
1R11 Licensed Operator Requalification
.1    Quarterly Review
    a. Inspection Scope
      The inspectors observed licensed operator performance and reviewed the associated
      training documents during annual dynamic simulator examination sessions for training
      cycle 2007-05. The simulator observations and review included evaluations of
      emergency operating procedure and abnormal operating procedure utilization. The
      inspectors reviewed Procedure 0TPP-200, Licensed Operator Continuing Training
      Program, to verify that the program ensures safe power plant operation. Simulator
      sessions were observed on November 20, 2007. The scenarios tested the operators
      ability to respond to secondary plant failures, loss of emergency power, and an
      automatic trip without a scram followed by a rupture of the scram discharge volume.
      The inspectors reviewed operator activities to verify consistent clarity and formality of
      communication, conservative decision-making by the crew, appropriate use of
      procedures, and proper alarm response. Group dynamics and supervisory oversight,
      including the ability to properly identify and implement appropriate Technical
      Specification (TS) actions, regulatory reports, and notifications, were observed. The
      inspectors observed instructor critiques and preliminary grading of the operating crews
      and assessed whether appropriate feedback was planned to be provided to the licensed
      operators.
    b. Findings
      No findings of significance were identified.
1R12 Maintenance Effectiveness
    a. Inspection Scope
      For the two equipment issues described in the ARs listed below, the inspectors reviewed
      the licensees implementation of the Maintenance Rule (10 CFR 50.65) with respect to
      the characterization of failures, the appropriateness of the associated Maintenance Rule
      a(1) or a(2) classification, and the appropriateness of the associated a(1) goals and
      corrective actions. The inspectors reviewed the work controls and work practices
      associated with the degraded performance or condition to verify that they were
      appropriate and did not contribute to the issue. The inspectors also reviewed operations
      logs and licensee event reports to verify unavailability times of components and
      systems, if applicable. Licensee performance was evaluated against the requirements
      of Procedure ADM-NGGC-0101, Maintenance Rule Program.
      *        AR 242066, BNP response to operating experience 2007-08 degradation of
                buried piping
      *        AR 256103, Loss of full out indications on the full core display
                                                                                        Enclosure
 
                                              8
  b. Findings
    No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation
  a. Inspection Scope
    The inspectors reviewed the licensees implementation of 10 CFR 50.65 (a)(4)
    requirements during scheduled and emergent maintenance activities, using Procedure
    0AP-025, BNP Integrated Scheduling and Technical Requirements Manual 5.5.13,
    Configuration Risk Management Program. The inspectors reviewed the effectiveness of
    risk assessments performed due to changes in plant configuration for maintenance
    activities (planned and emergent). The review was conducted to verify that, upon
    unforseen situations, the licensee had taken the necessary steps to plan and control the
    resultant emergent work activities. The inspectors reviewed the applicable plant risk
    profiles, work week schedules, and maintenance WOs for the following five conditions:
    *        AR 250203, HPCI inoperable due to pump seal leakage
    *        AR 255545, Unexpected annunciators during performance test (PT-12.2a) for
              EDG #1
    *        AR 257721, Unit 1 condensate storage tank instrumental vent line excessive
              sloping
    *       AR 257744, EDG #3 jacket water leakage from flexmaster jumpers
    *       AR 256079, 1-E11-F017B inoperable due to high energy line break issues at the
              motor control cubicle compartment
  b. Findings
    No findings of significance were identified.
1R15 Operability Evaluations
   a. Inspection Scope
    The inspectors reviewed the operability evaluations associated with the six issues
    documented in the ARs listed below, which affected risk significant systems or
    components, to assess, as appropriate: 1) the technical adequacy of the evaluations; 2)
    the justification of continued system operability; 3) any existing degraded conditions
    used as compensatory measures; 4) the adequacy of any compensatory measures in
    place, including their intended use and control; and 5) where continued operability was
    considered unjustified, the impact on any TS limiting condition for operation and the risk
    significance. In addition to the reviews, discussions were conducted with the applicable
    system engineer regarding the ability of the system to perform its intended safety
    function.
                                                                                      Enclosure
 
                                                9
      *      AR 249130, 1A Residual heat removal heat exchanger degradation during
              testing (OPF08.1.4A)
      *      AR 245864, E-4 Loss of coolant accident logic relay 27E2 de-energized
      *       AR 250793, Unit 2 RCIC operability concern
      *      AR 252203, Unit 2 RCIC seal purge line orifice missing
      *       AR 251885, Unit 2 HPCI main pump seal leak exceeds posting
      *      AR 251490, Water in Unit 2 HPCI lube oil
    b. Findings
      No findings of significance were identified.
1R19 Post-Maintenance Testing
    a. Inspection Scope
      For the five maintenance activities listed below, the inspectors reviewed the post-
      maintenance test procedure and witnessed the testing and/or reviewed test records to
      confirm that the scope of testing adequately verified that the work performed was
      correctly completed. The inspectors verified that the test demonstrated that the affected
      equipment was capable of performing its intended function and was operable in
      accordance with TS requirements. The inspectors reviewed the licensees actions
      against the requirements in Procedure 0PLP-20, Post Maintenance Testing Program.
      *      PT 9.2 HPCI Operability Test following inboard seal failure
      *      WO 114145 RCIC system fill and vent after pump maintenance
      *      WO 1137349 Inspection of HPCI sump after drain down
      *       AR 250499, Basis for changing piping test plan not understood
      *       AR 247456, Balance of plant under-voltage relays not tested as required
    b. Findings
      No findings of significance were identified.
1R22 Surveillance Testing
.1    Routine Surveillance Testing
    a. Inspection Scope
      The inspectors either observed surveillance tests or reviewed test data for the three risk
      significant SSC surveillances, listed below, to verify the tests met TS surveillance
      requirements, UFSAR commitments, in-service testing (IST) requirements, and licensee
      procedural requirements. The inspectors assessed the effectiveness of the tests in
      demonstrating that the SSCs were operationally capable of performing their intended
      safety functions.
                                                                                        Enclosure
 
                                                  10
      *        0PT-09.2mst-HPCI 23Q, High Pressure Coolant Injection System operability test,
                performed on Unit 2 on October 22, 2007
      *        2O1-03.2, Control Operator Daily Surveillance Report (including drywell leakage
                rate determination), performed the week of November 12, 2007.
      C        0PT-9.3a, High Pressure Coolant Injection System Component Test, performed
                on Unit 1 on December 7, 2007.
    b. Findings
      No findings of significance were identified.
.2   In-service Surveillance Testing
    a. Inspection Scope
      The inspectors reviewed the performance of Periodic Test 0PT-9.7, High Pressure
      Coolant Injection System Valve Operability Test, performed on Unit 1 on December 7,
      2007. The inspectors evaluated the effectiveness of the licensees American Society of
      Mechanical Engineers (ASME) Section XI testing program to determine equipment
      availability and reliability. The inspectors evaluated selected portions of the following
      areas: 1) testing procedures; 2) acceptance criteria; 3) testing methods; 4) compliance
      with the licensees IST program, TS, selected licensee commitments, and code
      requirements; 5) range and accuracy of test instruments; and 6) required corrective
      actions. The inspectors also assessed any applicable corrective actions taken.
      To assess the licensees ability to identify and correct problems, the inspector reviewed
      AR 214876 which documented that the Unit 1 A conventional service water pump was
      discovered to be in the Alert range following testing on November 30, 2006.
    b. Findings
      No findings of significance were identified.
1EP6 Drill Evaluation
    a. Inspection Scope
      The inspectors observed site emergency preparedness training drill/simulator scenarios
      conducted on October 30, 2007 and November 8, 2007. The inspectors reviewed the
      drill scenario narrative to identify the timing and location of classifications, notifications,
      and protective action recommendations development activities. The inspectors
      evaluated the drill conduct from the control room simulator, technical support center,
      and the emergency operations facility. During the drill, the inspectors assessed the
      adequacy of event classification and notification activities. The inspectors observed
      portions of the licensees post-drill critiques at the technical support center and
      emergency operating facility.
                                                                                            Enclosure
 
                                              11
      The inspectors verified that the licensee properly evaluated the drills performance with
      respect to performance indicators and assessed drill performance with respect to drill
      objectives. To assess the ability of the licensee to identify and correct problems, the
      inspectors reviewed the following corrective action documents that were generated as a
      result of the drill:
      *      AR 252936, knowledge gap in the required actions associated with the Reactor
              Building positive pressure as defined in AST documentation
      *      AR 252937, rewording of SPDS indication to prevent human error
      *      AR 254108, JIC positions not filled during ERO drill
  b. Findings
      No findings of significance were identified.
1R23 Temporary Plant Modifications
  a. Inspection Scope
      The inspectors reviewed Operating Manual 0PLP-22, Temporary Changes, to assess
      the implementation of Engineering Change (EC) 67830, Reactor Core Isolation Cooling
      System Low Suction Pressure Trip Delay which was implemented on October 21, 2007.
      The inspectors reviewed the EC to verify that the modification did not affect the
      functional capability of the EDG, that the modification was properly installed, and
      appropriate post-installation testing was performed.
  b. Findings
      No findings of significance were identified.
4.    OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
  a. Inspection Scope
      The inspectors sampled licensee data for the performance indicators (PIs) listed below.
      To verify the accuracy of the PI data reported during the period reviewed, PI definitions
      and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev.
      5 were used to verify the basis for each data element.
      Reactor Safety Cornerstone
      The inspectors sampled licensee submittals for the Units 1 and 2 PIs listed below for the
      period January 2007 through November 2007.
                                                                                      Enclosure
 
                                                  12
      *        High Pressure Coolant Injection System
      *        Reactor Core Isolation Cooling System
      A sample of plant records and data was reviewed and compared to the reported data to
      verify the accuracy of the PIs. The licensees corrective action program records were
      also reviewed to determine if any problems with the collection of PI data had occurred.
      Documents reviewed are listed in the Attachment.
    b. Findings
      No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1    Routine Review of ARs
      To aid in the identification of repetitive equipment failures or specific human
      performance issues for followup, the inspectors performed frequent screenings of items
      entered into the licensees CAP. The review was accomplished by reviewing daily ARs.
.2    Annual Sample Review
    a. Inspection Scope
      The inspectors performed an in-depth annual sample review of plant operator
      workarounds as documented in licensees operator workaround program and corrective
      action documents. This review was performed to verify that the licensee identified
      operator workarounds at an appropriate threshold, entered the issues into the CAP, and
      planned or implemented appropriate corrective actions. The inspectors reviewed the
      actions taken to verify that the licensee had adequately addressed the following
      attributes:
      *        Complete, accurate, and timely identification of the problem
      *        Evaluation and disposition of operability and reportability issues
      *        Consideration of previous failures, extent of condition, generic or common cause
                implications
      *        Prioritization and resolution of the issue commensurate with the safety
                significance
      *        Identification of the root cause and contributing causes of the problem
      *        Identification and implementation of corrective actions commensurate with the
                safety significance of the issue
      The inspectors reviewed the associated corrective action for AR 250203, Unit 2 high
      pressure coolant injection pump seal failure that occurred on October 10, 2007.
                                                                                        Enclosure
 
                                                  13
    b. Findings and Observations
      No findings of significance were identified.
.3    Semi-Annual Trend Review
    a. Inspection Scope
      The inspectors performed a review of the licensees CAP and associated documents to
      identify trends that could indicate the existence of a more significant safety issue. The
      review was focused on repetitive equipment issues but also considered the results of
      frequent inspector CAP item screening (discussed above), licensee trending efforts, and
      licensee human performance results. The review considered the period of July through
      December 2007. The review further included issues documented outside the normal
      CAP in major equipment lists, repetitive and/or rework maintenance lists, operational
      focus list, control room deficiency list, outstanding work order list, quality assurance
      audit/surveillance reports, key performance indicators, and self-assessment reports.
      The inspectors compared and contrasted their results with the results contained in
      multiple root cause evaluations the licensee has performed over the last 2 quarters.
      Corrective actions associated with a sample of the issues identified in the licensees
      trend reports were reviewed for adequacy. The inspectors also evaluated the reports
      against the requirements of the licensees CAP as specified in Nuclear Generation
      Group Standard Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR
      50, Appendix B.
    b. Assessment and Observations
      No findings of significance were identified. The inspectors noted a trend in the control
      and retrieval of foreign material in systems and the adverse effects this has had on
      system performance; this was exemplified by the following identified issues:
      1) Foreign material found in the 1B Residual Heat Removal (RHR) Room cooler
      (AR243465); 2) Metallic foreign material found in the 1B RHR Heat Exchanger
      (AR246790); 3) 1D RHRSW Booster pump failed to start was bound by valve pin (AR
      243867); 4) Unit 2 HPCI main pump inboard seal failure due to blockage of seal cooling
      line (AR250203). The inspectors have determined that the licensee has addressed all
      immediate operability concerns, and is currently developing long-term improvements.
4OA6 Meetings, Including Exit
      Exit Meeting Summary
      On January 24, 2008, the resident inspectors presented the inspection results to
      Mr. Waldrep and other members of his staff. The inspectors confirmed that proprietary
      information was not provided or examined during the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
                                                                                          Enclosure
 
                                SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
Licensee Personnel
G. Atkinson, Supervisor - Emergency Preparedness
L. Beller, Superintendent Operations Training
A. Brittain, Manager - Security
D. Griffith, Manager - Training Manager
L. Grzeck, Lead Engineer - Technical Support
L. Grzeck, Lead Engineer - Technical Support
S. Howard, Manager - Operations
S. Howard, Manager - Operations
R. Ivey, Manager - Site Support Services
R. Ivey, Manager - Site Support Services
T. Pearson, Supervisor - Operations Training  
T. Pearson, Supervisor - Operations Training
A. Pope, Supervisor - Licensing/Regulatory Programs
A. Pope, Supervisor - Licensing/Regulatory Programs
S. Rogers, Manager - Maintenance
S. Rogers, Manager - Maintenance
Line 291: Line 619:
M. Turkal, Lead Engineer - Technical Support
M. Turkal, Lead Engineer - Technical Support
M. Williams, Manager - Operations Support
M. Williams, Manager - Operations Support
E. Wills, Plant General ManagerNRC PersonnelRandall Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects Region II  
E. Wills, Plant General Manager
AttachmentLIST OF ITEMS OPENED, CLOSED, AND DISCUSSEDOpened and Closed
NRC Personnel
None Discussed NoneLIST OF DOCUMENTS REVIEWEDSection 1R01: Adverse Weather ProtectionPlant Operating Manual (POM), Volume VII, Operating Instruction 0OI-01.03, Non-RoutineActivities
Randall Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects Region II
POM, Volume XII, Preventive Maintenance 0PM-HT001, Preventive Maintenance on PlantFreeze Protection and Heat Tracing SystemSection 1R04: Equipment AlignmentPOM, Volume III, Operating Procedure 2OP-39, High Pressure Coolant Injection SystemOperating Procedure
                                                                                  Attachment
POM, Volume III, 0OP-39, Diesel  
 
Generator Operating ProcedureSystem Description SD-39, Emergency Diesel Generators Section 1R05: Fire ProtectionPOM, Volume XIX, Prefire Plan 0PFP-DG, Diesel Generator Building Prefire PlansPOM, Volume XIX, Prefire Plan 0PFP-PBAA, Power Block Auxiliary Areas Prefire Plans
                  LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None
Discussed
None
                            LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Plant Operating Manual (POM), Volume VII, Operating Instruction 0OI-01.03, Non-Routine
Activities
POM, Volume XII, Preventive Maintenance 0PM-HT001, Preventive Maintenance on Plant
Freeze Protection and Heat Tracing System
Section 1R04: Equipment Alignment
POM, Volume III, Operating Procedure 2OP-39, High Pressure Coolant Injection System
Operating Procedure
POM, Volume III, 0OP-39, Diesel Generator Operating Procedure
System Description SD-39, Emergency Diesel Generators
Section 1R05: Fire Protection
POM, Volume XIX, Prefire Plan 0PFP-DG, Diesel Generator Building Prefire Plans
POM, Volume XIX, Prefire Plan 0PFP-PBAA, Power Block Auxiliary Areas Prefire Plans
POM, Volume XIX, Prefire Plan 1PFP-RB, Unit 1 Reactor Building Prefire Plans
POM, Volume XIX, Prefire Plan 1PFP-RB, Unit 1 Reactor Building Prefire Plans
 
Section 1R06: Flood Protection Measures
Section 1R06: Flood Protection MeasuresPOM, Volume XXI, Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During         Hurricane, Flood Conditions, Tornado, or Earthquake
POM, Volume XXI, Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During
POM, Volume X, Periodic Test (PT) 0PT-34.2.2.1, Fire Door, ASSD Access/Egress Door,  
Hurricane, Flood Conditions, Tornado, or Earthquake
POM, Volume X, Periodic Test (PT) 0PT-34.2.2.1, Fire Door, ASSD Access/Egress Door,
Severe Weather Door Inspections
Severe Weather Door Inspections
Updated Final Safety Analysis Report Chapters 2 and 3
Updated Final Safety Analysis Report Chapters 2 and 3
                                                                                Attachment
}}
}}

Revision as of 19:54, 14 November 2019

IR 05000325-07-005, 05000324-07-005; on 10/01/07- 12/31/07; Brunswick Steam Electric Plant, Units 1 and 2
ML080350426
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 01/29/2008
From: Randy Musser
Division Reactor Projects II
To: Waldrep B
Carolina Power & Light Co
References
IR-07-005
Download: ML080350426 (23)


See also: IR 05000324/2007005

Text

January 29, 2008

Carolina Power and Light Company

ATTN: Mr. Benjamin Waldrep

Vice President

Brunswick Steam Electric Plant

P. O. Box 10429

Southport, NC 28461

SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION

REPORT NOS. 05000324/2007005 AND 05000325/2007005

Dear Mr. Waldrep:

On December 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Brunswick Units 1 and 2 facilities. The enclosed integrated inspection report

documents the inspection findings, which were discussed on January 22, 2008, with you and

other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

On the basis of the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter

and its enclosure will be available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRC's

document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Randall A. Musser, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Docket Nos.: 50-325, 50-324

License Nos: DPR-71, DPR-62

Enclosure: Inspection Report 05000325, 324/2007005

w/Attachment: Supplemental Information

cc w/encl: (See page 2)

OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS RII:DRS RII:DRS

SIGNATURE /RA/ /RA By e-mail/ /RA by e-mail/ /RA/

NAME R Musser J Austin S Rutledge G Wilson

DATE 1/29/08 1/30/08 1/30/08 1/29/08

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

CP&L 2

cc w/encl:

Director, Site Operations John H. O'Neill, Jr.

Brunswick Steam Electric Plant Shaw, Pittman, Potts & Trowbridge

Carolina Power & Light Company 2300 N. Street, NW

Electronic Mail Distribution Washington, DC 20037-1128

J. Paul Fulford, Manager Beverly Hall, Chief, Radiation

Performance Evaluation and Protection Section

Regulatory Affairs PEB 5 N. C. Department of Environment

Carolina Power & Light Company and Natural Resources

Electronic Mail Distribution Electronic Mail Distribution

Terry D. Hobbs, Plant General Manager Peggy Force

Brunswick Steam Electric Plant Assistant Attorney General

Carolina Power & Light Company State of North Carolina

P. O. Box 10429 Electronic Mail Distribution

Southport, NC 28461

Chairman of the North Carolina

Donald L. Griffith Utilities Commission

Manager - Training c/o Sam Watson, Staff Attorney

Progress Energy Carolinas, Inc. Electronic Mail Distribution

Brunswick Steam Electric Plant

Electronic Mail Distribution Robert P. Gruber

Executive Director

Randy C. Ivey Public Staff NCUC

Manager - Support Services 4326 Mail Service Center

Progress Energy Carolinas, Inc. Raleigh, NC 27699-4326

Brunswick Steam Electric Plant

Electric Mail Distribution Public Service Commission

State of South Carolina

Garry D. Miller, Manager P. O. Box 11649

License Renewal Columbia, SC 29211

Progress Energy

Electronic Mail Distribution David R. Sandifer

Brunswick County Board of

Annette H. Pope, Supervisor Commissioners

Licensing/Regulatory Programs P. O. Box 249

Carolina Power and Light Company Bolivia, NC 28422

Electronic Mail Distribution

Warren Lee

David T. Conley Emergency Management Director

Associate General Counsel - Legal Dept. New Hanover County Department of

Progress Energy Service Company, LLC Emergency Management

Electronic Mail Distribution 230 Government Center Drive

Suite 115

James Ross Wilmington, NC 28403

Nuclear Energy Institute

Electronic Mail Distribution

CP&L 3

Report to Ben Waldrep from Randall A. Musser dated January 29, 2008

SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION

REPORT NOS. 05000324/2007005 AND 05000325/2007005

Distribution w/encl:

S. Bailey, NRR

R. Pascarelli, NRR

C. Evans, RII

L. Slack, RII

RIDSNRRDIRS

OE Mail

PUBLIC

NRC Resident Inspector

U.S. Nuclear Regulatory Commission

8470 River Road, SE

Southport, NC 28461

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos: 50-325, 50-324

License Nos: DPR-71, DPR-62

Report Nos: 05000325/2007005 and 05000324/2007005

Licensee: Carolina Power and Light (CP&L)

Facility: Brunswick Steam Electric Plant, Units 1 & 2

Location: 8470 River Road SE

Southport, NC 28461

Dates: October 1, 2007 through December 31, 2007

Inspectors: J. Austin, Senior Resident Inspector

S. Rutledge, Resident Inspector

Approved by: Randall A. Musser, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000325/2007005, 05000324/2007005; 10/01/07- 12/31/07; Brunswick Steam

Electric Plant, Units 1 and 2.

The report covered a 3-month period of inspection by resident inspectors and one senior

reactor inspector. One Green non-cited violation (NCV) was identified. The significance

of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection

Manual Chapter (IAC) 0609, Significance Determination Process (SDP). The NRC's

program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December

2006.

A. NRC-Identified and Self-Revealing Findings

NONE

B. Licensee-Identified Findings

NONE

Enclosure

REPORT DETAILS

Summary of Plant Status

Unit 1

Unit 1 began the inspection period operating at full power. On October 6, power was

reduced to 93 percent to perform a control rod improvement. The unit was restored to

full power the same day. On October 13, power was reduced to 93 percent to perform a

control rod improvement. The unit was returned to full power the same day. On

October 20, power was reduced to 93 percent to perform a control rod improvement.

Full power was restored the same day. On October 27, power was reduced to 93

percent to perform a control rod improvement. Full power was achieved later that day.

On November 3, power was reduced to 67 percent to facilitate valve testing. The unit

was returned to full power later that day. On November 4, power was reduced to 95

percent to perform a control rod improvement. Full power was restored on November 5.

On November 11, power was reduced to 90 percent to perform a control rod

improvement. Full power was achieved later that day. On November 16, power was

reduced to 91 percent to perform a control rod improvement. The unit was returned to

full power November 17. On November 24, power was reduced to 90 percent for control

rod testing. Full power was restored later that day. The unit remained at full power for

the remainder of the inspection period.

Unit 2

Unit 2 began the inspection period operating at full power. On October 1, a power

ascension occurred from main turbine valve testing. Full power was restored later that

day. On October 1, power was reduced to 95 percent to perform a control rod

improvement. Full power was restored later that day. On October 1, power was

reduced to 96 percent to perform a control rod improvement. The unit was returned to

full power later that day. On October 2, power was reduced to 98 percent to perform a

control rod improvement. Full power was restored later that day. On November 8,

power was reduced to 71 percent for a Whiteville line outage. Power was returned to

full later that day. On November 9, power was reduced to 98 percent for a control rod

improvement. Full power was restored later that day. On November 17, power was

reduced to 68 percent for main turbine valve, reactor feed pump and scram time testing.

The unit was returned to full power on November 18. On November 18, power was

reduced to 94 percent for xenon build-up following main turbine valve testing and control

rod sequence exchange. Full power was returned on November 19. On November 19,

power was reduced to 85 percent to perform a control rod improvement. Full power was

restored November 20. On November 20, power was reduced to 95 percent to perform

a control rod improvement. Full power was achieved November 21, 2007. The unit

remained at full power for the remainder of the inspection period.

Enclosure

3

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

The inspectors assessed the effectiveness of the licensees cold weather protection

program as it related to ensuring that the facilitys service water pumps, emergency

diesel generators, and condensate storage tank low level switches would remain

functional and available in cold weather conditions. In addition to reviewing the

licensees program-related documents and procedures, walkdowns were conducted of

the freeze protection equipment (e.g., heat tracing, area space heaters, etc.) associated

with the above systems/components. Licensee problem identification and resolution

associated with cold weather protections was also assessed.

switch

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed three partial walkdowns of the below-listed systems to verify

that the systems were correctly aligned while the redundant train or system was

inoperable or out-of-service (OOS) or, for single train risk significant systems, while the

system was available in a standby condition. The inspectors assessed conditions such

as equipment alignment (i.e., valve positions, damper positions, and breaker alignment)

and system operational readiness (i.e., control power and permissive status) that could

affect operability. The inspectors verified that the licensee identified and resolved

equipment alignment problems that could cause initiating events or impact mitigating

system availability. The inspectors reviewed Administrative Procedure

ADM-NGGC-0106, Configuration Management Program Implementation, to verify that

available structures, systems or components (SSCs) met the requirements of the

configuration control program. Documents reviewed are listed in the Attachment.

OOS for scheduled maintenance on October 3, 2007

Enclosure

4

  • Unit 2 RCIC when the Unit 2 HPCI was OOS for seal repair on October 15, 2007
  • EDG #2, #3, and #4 while EDG #1 was OOS for scheduled maintenance on

November 19, 2007

To assess the licensees ability to identify and correct problems, the inspectors reviewed

the following Action Requests (ARs):

  • AR 251684251684 RCIC extent of condition evaluation using Panametrics
  • AR 254033254033 EDG starting air pilot air lines support discrepancies

b. Findings

No findings of significance were identified.

.2 Complete System Walkdown

a. Inspection Scope

The inspectors conducted a detailed review of the alignment and condition of the Unit 2

high pressure coolant injection system. The inspector reviewed the Updated Final

Safety Analysis Report, associated attachments of Operating Procedure 2OP-19, High

Pressure Coolant Injection System Operating Procedure, 0PT-09.2, HPCI System

Operability Test and the systems diagrams (drawing numbers D-02523 and LL-09272)

in determining correct system lineup. The inspectors also reviewed maintenance history

of the system.

To assess the licensees identification and resolutions of problems, the inspectors

reviewed the following:

b. Findings

No findings of significance were identified.

Enclosure

5

1R05 Fire Protection

.1 Fire Area Walkdowns

a. Inspection Scope

The inspectors reviewed ARs and work orders (WOs) associated with the fire

suppression system to confirm that their disposition was in accordance with Procedure

0AP-033, Fire Protection Program Manual. The inspectors reviewed the status of

ongoing surveillance activities to verify that they were current to support the operability

of the fire protection system. In addition, the inspectors observed the fire suppression

and detection equipment to determine whether any conditions or deficiencies existed

which would impair the operability of that equipment. The inspectors toured the

following six areas important to reactor safety and reviewed the associated prefire plans

to verify that the requirements for fire protection design features, fire area boundaries,

and combustible loading were met. Documents reviewed are listed in the Attachment.

  • Units 1 and 2 Control Building, - 49' elevation (2 areas)
  • Units 1 and 2 Control Building, - 23' elevation (2 areas)
  • Units 1 and 2 Reactor Building - 17' elevation (2 areas)

b. Findings

No findings of significance were identified.

.2 Fire Drill

a. Inspection Scope

On October 6, 2007, the inspectors observed a plant fire drill at the auxiliary boiler unit

located outside near the Emergency Diesel Generator Building, to assess the fire

brigade performance and to verify that proper firefighting techniques for the type of fire

encountered were utilized. The inspectors monitored the fire brigades use of protective

equipment and firefighting equipment to verify that preplanned firefighting procedures

and appropriate firefighting techniques were used, and to verify that the directions of the

fire brigade leader were thorough, clear, and effective. The inspectors attended the

critique to confirm that appropriate feedback on performance was provided to brigade

members and to ensure that areas for improvement were properly identified for licensee

follow-up. In preparing for the drill, the inspectors reviewed the preplanned drill

scenario, Brunswick Nuclear Plant Drill Scenario Guide, 99-F-0S, Revision 1.

b. Findings

No findings of significance were identified.

Enclosure

6

1R06 Flood Protection Measures

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed the licensees internal flooding analysis as described in

Updated Final Safety Analysis Report (UFSAR) Section 3.4.2, Protection From Internal

Flooding. Due to the risk significance of equipment in the Service Water and

Emergency Diesel Generator Buildings, the inspectors reviewed UFSAR Section 3.4.2

analysis of the effects of postulated piping failures for these two areas to determine if

the analysis assumptions and conclusions were based on the current plant

configuration. The internal flooding design features and equipment for coping with

internal flooding was inspected for the equipment located in these buildings. The

walkdown included sources of flooding and drainage, sump pumps, level switches,

watertight doors, curbs, pedestals and equipment mounting. Documents reviewed are

listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 External Flooding

a. Inspection Scope

The inspectors reviewed the licensees external flooding analysis as described in

UFSAR Section 3.4.1, Protection from External Flooding, to determine the external flood

control design features. Walkdowns were conducted to inspect the external flood

protection barriers including watertight doors, curbs, sealing of external building

penetrations below flood line, and the sump pumps and level alarm circuits. Areas

reviewed included the Emergency Diesel Generator Building, and the Service Water

Building. The inspector reviewed the procedures for coping with external flooding

contained in Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During

Hurricane, Flood Conditions, Tornado, or Earthquake. Other documents reviewed are

listed in the Attachment.

b. Findings

No findings of significance were identified.

Enclosure

7

1R11 Licensed Operator Requalification

.1 Quarterly Review

a. Inspection Scope

The inspectors observed licensed operator performance and reviewed the associated

training documents during annual dynamic simulator examination sessions for training

cycle 2007-05. The simulator observations and review included evaluations of

emergency operating procedure and abnormal operating procedure utilization. The

inspectors reviewed Procedure 0TPP-200, Licensed Operator Continuing Training

Program, to verify that the program ensures safe power plant operation. Simulator

sessions were observed on November 20, 2007. The scenarios tested the operators

ability to respond to secondary plant failures, loss of emergency power, and an

automatic trip without a scram followed by a rupture of the scram discharge volume.

The inspectors reviewed operator activities to verify consistent clarity and formality of

communication, conservative decision-making by the crew, appropriate use of

procedures, and proper alarm response. Group dynamics and supervisory oversight,

including the ability to properly identify and implement appropriate Technical

Specification (TS) actions, regulatory reports, and notifications, were observed. The

inspectors observed instructor critiques and preliminary grading of the operating crews

and assessed whether appropriate feedback was planned to be provided to the licensed

operators.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

For the two equipment issues described in the ARs listed below, the inspectors reviewed

the licensees implementation of the Maintenance Rule (10 CFR 50.65) with respect to

the characterization of failures, the appropriateness of the associated Maintenance Rule

a(1) or a(2) classification, and the appropriateness of the associated a(1) goals and

corrective actions. The inspectors reviewed the work controls and work practices

associated with the degraded performance or condition to verify that they were

appropriate and did not contribute to the issue. The inspectors also reviewed operations

logs and licensee event reports to verify unavailability times of components and

systems, if applicable. Licensee performance was evaluated against the requirements

of Procedure ADM-NGGC-0101, Maintenance Rule Program.

  • AR 242066242066 BNP response to operating experience 2007-08 degradation of

buried piping

  • AR 256103256103 Loss of full out indications on the full core display

Enclosure

8

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed the licensees implementation of 10 CFR 50.65 (a)(4)

requirements during scheduled and emergent maintenance activities, using Procedure

0AP-025, BNP Integrated Scheduling and Technical Requirements Manual 5.5.13,

Configuration Risk Management Program. The inspectors reviewed the effectiveness of

risk assessments performed due to changes in plant configuration for maintenance

activities (planned and emergent). The review was conducted to verify that, upon

unforseen situations, the licensee had taken the necessary steps to plan and control the

resultant emergent work activities. The inspectors reviewed the applicable plant risk

profiles, work week schedules, and maintenance WOs for the following five conditions:

EDG #1

  • AR 257721257721 Unit 1 condensate storage tank instrumental vent line excessive

sloping

  • AR 257744257744 EDG #3 jacket water leakage from flexmaster jumpers

motor control cubicle compartment

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the operability evaluations associated with the six issues

documented in the ARs listed below, which affected risk significant systems or

components, to assess, as appropriate: 1) the technical adequacy of the evaluations; 2)

the justification of continued system operability; 3) any existing degraded conditions

used as compensatory measures; 4) the adequacy of any compensatory measures in

place, including their intended use and control; and 5) where continued operability was

considered unjustified, the impact on any TS limiting condition for operation and the risk

significance. In addition to the reviews, discussions were conducted with the applicable

system engineer regarding the ability of the system to perform its intended safety

function.

Enclosure

9

testing (OPF08.1.4A)

  • AR 245864245864 E-4 Loss of coolant accident logic relay 27E2 de-energized

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

For the five maintenance activities listed below, the inspectors reviewed the post-

maintenance test procedure and witnessed the testing and/or reviewed test records to

confirm that the scope of testing adequately verified that the work performed was

correctly completed. The inspectors verified that the test demonstrated that the affected

equipment was capable of performing its intended function and was operable in

accordance with TS requirements. The inspectors reviewed the licensees actions

against the requirements in Procedure 0PLP-20, Post Maintenance Testing Program.

  • PT 9.2 HPCI Operability Test following inboard seal failure
  • AR 250499250499 Basis for changing piping test plan not understood
  • AR 247456247456 Balance of plant under-voltage relays not tested as required

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

.1 Routine Surveillance Testing

a. Inspection Scope

The inspectors either observed surveillance tests or reviewed test data for the three risk

significant SSC surveillances, listed below, to verify the tests met TS surveillance

requirements, UFSAR commitments, in-service testing (IST) requirements, and licensee

procedural requirements. The inspectors assessed the effectiveness of the tests in

demonstrating that the SSCs were operationally capable of performing their intended

safety functions.

Enclosure

10

performed on Unit 2 on October 22, 2007

  • 2O1-03.2, Control Operator Daily Surveillance Report (including drywell leakage

rate determination), performed the week of November 12, 2007.

C 0PT-9.3a, High Pressure Coolant Injection System Component Test, performed

on Unit 1 on December 7, 2007.

b. Findings

No findings of significance were identified.

.2 In-service Surveillance Testing

a. Inspection Scope

The inspectors reviewed the performance of Periodic Test 0PT-9.7, High Pressure

Coolant Injection System Valve Operability Test, performed on Unit 1 on December 7,

2007. The inspectors evaluated the effectiveness of the licensees American Society of

Mechanical Engineers (ASME)Section XI testing program to determine equipment

availability and reliability. The inspectors evaluated selected portions of the following

areas: 1) testing procedures; 2) acceptance criteria; 3) testing methods; 4) compliance

with the licensees IST program, TS, selected licensee commitments, and code

requirements; 5) range and accuracy of test instruments; and 6) required corrective

actions. The inspectors also assessed any applicable corrective actions taken.

To assess the licensees ability to identify and correct problems, the inspector reviewed

AR 214876214876which documented that the Unit 1 A conventional service water pump was

discovered to be in the Alert range following testing on November 30, 2006.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed site emergency preparedness training drill/simulator scenarios

conducted on October 30, 2007 and November 8, 2007. The inspectors reviewed the

drill scenario narrative to identify the timing and location of classifications, notifications,

and protective action recommendations development activities. The inspectors

evaluated the drill conduct from the control room simulator, technical support center,

and the emergency operations facility. During the drill, the inspectors assessed the

adequacy of event classification and notification activities. The inspectors observed

portions of the licensees post-drill critiques at the technical support center and

emergency operating facility.

Enclosure

11

The inspectors verified that the licensee properly evaluated the drills performance with

respect to performance indicators and assessed drill performance with respect to drill

objectives. To assess the ability of the licensee to identify and correct problems, the

inspectors reviewed the following corrective action documents that were generated as a

result of the drill:

  • AR 252936252936 knowledge gap in the required actions associated with the Reactor

Building positive pressure as defined in AST documentation

  • AR 252937252937 rewording of SPDS indication to prevent human error

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed Operating Manual 0PLP-22, Temporary Changes, to assess

the implementation of Engineering Change (EC) 67830, Reactor Core Isolation Cooling

System Low Suction Pressure Trip Delay which was implemented on October 21, 2007.

The inspectors reviewed the EC to verify that the modification did not affect the

functional capability of the EDG, that the modification was properly installed, and

appropriate post-installation testing was performed.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee data for the performance indicators (PIs) listed below.

To verify the accuracy of the PI data reported during the period reviewed, PI definitions

and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev.

5 were used to verify the basis for each data element.

Reactor Safety Cornerstone

The inspectors sampled licensee submittals for the Units 1 and 2 PIs listed below for the

period January 2007 through November 2007.

Enclosure

12

A sample of plant records and data was reviewed and compared to the reported data to

verify the accuracy of the PIs. The licensees corrective action program records were

also reviewed to determine if any problems with the collection of PI data had occurred.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of ARs

To aid in the identification of repetitive equipment failures or specific human

performance issues for followup, the inspectors performed frequent screenings of items

entered into the licensees CAP. The review was accomplished by reviewing daily ARs.

.2 Annual Sample Review

a. Inspection Scope

The inspectors performed an in-depth annual sample review of plant operator

workarounds as documented in licensees operator workaround program and corrective

action documents. This review was performed to verify that the licensee identified

operator workarounds at an appropriate threshold, entered the issues into the CAP, and

planned or implemented appropriate corrective actions. The inspectors reviewed the

actions taken to verify that the licensee had adequately addressed the following

attributes:

  • Complete, accurate, and timely identification of the problem
  • Evaluation and disposition of operability and reportability issues
  • Consideration of previous failures, extent of condition, generic or common cause

implications

  • Prioritization and resolution of the issue commensurate with the safety

significance

  • Identification of the root cause and contributing causes of the problem
  • Identification and implementation of corrective actions commensurate with the

safety significance of the issue

The inspectors reviewed the associated corrective action for AR 250203250203 Unit 2 high

pressure coolant injection pump seal failure that occurred on October 10, 2007.

Enclosure

13

b. Findings and Observations

No findings of significance were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to

identify trends that could indicate the existence of a more significant safety issue. The

review was focused on repetitive equipment issues but also considered the results of

frequent inspector CAP item screening (discussed above), licensee trending efforts, and

licensee human performance results. The review considered the period of July through

December 2007. The review further included issues documented outside the normal

CAP in major equipment lists, repetitive and/or rework maintenance lists, operational

focus list, control room deficiency list, outstanding work order list, quality assurance

audit/surveillance reports, key performance indicators, and self-assessment reports.

The inspectors compared and contrasted their results with the results contained in

multiple root cause evaluations the licensee has performed over the last 2 quarters.

Corrective actions associated with a sample of the issues identified in the licensees

trend reports were reviewed for adequacy. The inspectors also evaluated the reports

against the requirements of the licensees CAP as specified in Nuclear Generation

Group Standard Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR

50, Appendix B.

b. Assessment and Observations

No findings of significance were identified. The inspectors noted a trend in the control

and retrieval of foreign material in systems and the adverse effects this has had on

system performance; this was exemplified by the following identified issues:

1) Foreign material found in the 1B Residual Heat Removal (RHR) Room cooler

(AR243465243465; 2) Metallic foreign material found in the 1B RHR Heat Exchanger

(AR246790246790; 3) 1D RHRSW Booster pump failed to start was bound by valve pin (AR

243867); 4) Unit 2 HPCI main pump inboard seal failure due to blockage of seal cooling

line (AR250203250203. The inspectors have determined that the licensee has addressed all

immediate operability concerns, and is currently developing long-term improvements.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 24, 2008, the resident inspectors presented the inspection results to

Mr. Waldrep and other members of his staff. The inspectors confirmed that proprietary

information was not provided or examined during the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. Atkinson, Supervisor - Emergency Preparedness

L. Beller, Superintendent Operations Training

A. Brittain, Manager - Security

D. Griffith, Manager - Training Manager

L. Grzeck, Lead Engineer - Technical Support

S. Howard, Manager - Operations

R. Ivey, Manager - Site Support Services

T. Pearson, Supervisor - Operations Training

A. Pope, Supervisor - Licensing/Regulatory Programs

S. Rogers, Manager - Maintenance

B. Waldrep, Site Vice President

T. Sherrill, Engineer - Technical Support

T. Trask, Manager - Engineering

J. Titrington, Manger - Nuclear Assessment Services

M. Turkal, Lead Engineer - Technical Support

M. Williams, Manager - Operations Support

E. Wills, Plant General Manager

NRC Personnel

Randall Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects Region II

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Plant Operating Manual (POM), Volume VII, Operating Instruction 0OI-01.03, Non-Routine

Activities

POM, Volume XII, Preventive Maintenance 0PM-HT001, Preventive Maintenance on Plant

Freeze Protection and Heat Tracing System

Section 1R04: Equipment Alignment

POM, Volume III, Operating Procedure 2OP-39, High Pressure Coolant Injection System

Operating Procedure

POM, Volume III, 0OP-39, Diesel Generator Operating Procedure

System Description SD-39, Emergency Diesel Generators

Section 1R05: Fire Protection

POM, Volume XIX, Prefire Plan 0PFP-DG, Diesel Generator Building Prefire Plans

POM, Volume XIX, Prefire Plan 0PFP-PBAA, Power Block Auxiliary Areas Prefire Plans

POM, Volume XIX, Prefire Plan 1PFP-RB, Unit 1 Reactor Building Prefire Plans

Section 1R06: Flood Protection Measures

POM, Volume XXI, Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During

Hurricane, Flood Conditions, Tornado, or Earthquake

POM, Volume X, Periodic Test (PT) 0PT-34.2.2.1, Fire Door, ASSD Access/Egress Door,

Severe Weather Door Inspections

Updated Final Safety Analysis Report Chapters 2 and 3

Attachment