IR 05000324/2022003

Integrated Inspection Report 05000324/2022003 and 05000325/2022003

ML22311A024
Person / Time
Site:	Brunswick
Issue date:	11/07/2022
From:	Matthew Fannon NRC/RGN-II/DRP/RPB4
To:	Krakuszeski J Duke Energy Progress
References
IR 2022003
Download: ML22311A024 (15)

Text

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2022003 AND 05000325/2022003

Dear Mr. Krakuszeski:

On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On October 31, 2022, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000324 and 05000325 License Nos. DPR-62 and DPR-71

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000324 and 05000325

License Numbers: DPR-62 and DPR-71

Report Numbers: 05000324/2022003 and 05000325/2022003

Licensee: Duke Energy Progress, LLC

Facility: Brunswick Steam Electric Plant

Location: Southport, NC

Inspection Dates: July 1, 2022 to September 30, 2022

Inspectors: C. Curran, Resident Inspector M. Donithan, Senior Reactor Inspector C. Fontana, Emergency Preparedness Inspector J. Hickman, Resident Inspector K. Kirchbaum, Operations Engineer S. Sanchez, Senior Emergency Preparedness Insp G. Smith, Senior Resident Inspector J. Steward, Senior Resident Inspector J. Viera, Senior Operations Engineer J. Walker, Emergency Response Inspector

Approved By: Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Brunswick Steam Electric Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the period at 100 percent rated thermal power (RTP) and operated there until September 9, 2022, when power was reduced to 60 percent RTP for a planned control rod sequence exchange and turbine valve testing. Following the testing and sequence exchange, as well as two follow-on rod improvements, the unit was restored to RTP on September 16, 2022, where the unit essentially operated for the remainder of the period.

Unit 2 began the period at RTP, and operated there until August 26, 2022, when power was reduced to 60 percent RTP for a planned control rod sequence exchange and turbine valve testing. Following the testing and sequence exchange, as well as two follow-on rod improvements, the unit was restored to RTP on August 31, 2022, where the unit essentially operated for the remainder of the period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather caused by Hurricane Ian from September 28 to September 30, 2022.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 'B' core spray (CS) train while the 'A' train was out-of-service (OOS) for planned maintenance on July 19, 2022

(2) Emergency diesel generator (EDG)-1, EDG-3, and EDG-4 while EDG-2 was OOS for a maintenance outage from July 25 to July 28

(3) Unit 2 reactor core isolation cooling (RCIC) system while Unit 2 high pressure coolant injection (HPCI) system was OOS for planned maintenance on August 3

(4) Unit 2 'A' residual heat removal (RHR) train while the 'B' train was OOS for planned maintenance on August 10

(5) Unit 1 'A' RHR train while 'B' train was OOS for a discharge check valve repair on September 28.

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 RCIC system that was completed on August 23, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 2 reactor building (RB) 20 elevation on July 11, 2022

(2) Unit 2 RB -17 elevation on July 11, 2022

(3) Unit 1 RB 50 elevation on August 17, 2022

(4) Unit 2 RB 50 elevation on August 18, 2022.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

The inspectors completed an inspection to verify the licensee's ability to evaluate the performance of their licensed operators during the conduct of examinations, to assess their ability to properly develop and administer requalification annual operating tests and biennial written examinations, to evaluate the performance of the control room simulator and their testing and maintenance of the simulator, to ensure that licensed individuals satisfy the conditions of their licenses, and to assess their effectiveness in ensuring that operator license conditions are satisfied.

(1) Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examinations administered during the annual requalification cycle of August and September, 2021.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test

The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security

The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution

The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) The inspectors observed and evaluated licensed operator performance in the main control room during a power reduction to 60 percent RTP in order to perform a control rod sequence exchange, conduct turbine valve testing, and repair a circulating water leak on September 9, 2022.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated a simulator exam scenario given to an operating crew on August 9, 2022. The scenario consisted of a condenser tube leak, an anticipated transient without scram (ATWS), and a control rod drive (CRD)failure. This evaluated scenario was part of licensed operator continuing training (Cycle 4).

(2) The inspectors observed and evaluated a simulator exam scenario given to an operating crew on September 27, 2022. The scenario consisted of a transformer trip, a loss of offsite power, and a large break loss of coolant accident. This evaluated scenario was part of the annual licensed operator examination (Cycle 5).

71111.12 - Maintenance Effectiveness

Aging Management (IP Section 03.03) (1 Sample)

The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:

(1) Unit 1 conventional service water piping inspection conducted during March 2022 refueling outage.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Elevated risk due to Unit 1 'A' train CS outage from July 18 to July 19, 2022

(2) Elevated risk due to EDG-2 maintenance outage on July 28, 2022

(3) Elevated risk due to Unit 2 HPCI outage and A control room emergency ventilation system planned maintenance on August 4, 2022

(4) Elevated risk due to Unit 2 B train RHR maintenance outage on August 10, 2022

(5) Elevated risk due to Unit 1 B RHR check valve maintenance on September 28, 2022.

71111.15 - Operability Determinations and Functionality Assessments

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

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 1 bypass valve #2 failure (nuclear condition report (NCR) 2433353)

(2) Loss of power to Unit 1 HPCI flow controller (NCR 2434489)

(3) EDG-1 KVAR power oscillations (NCR 2434517)

(4) Powerplex explicit water rod deficiency (NCR 2434561)

(5) In-service testing (IST) relief valve schedules are not in compliance (NCR 2365556)

(6) Potential thru-wall leak on Unit 1 'B' nuclear service water (NSW) pump discharge piping (NCR 2442398).

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the following post-maintenance testing (PMT) activities to verify system operability and/or functionality:

(1) 0PT-12.2A, No. 1 Diesel Generator Monthly Load Test after cylinder o-ring replacement on August 25, 2022

(2) 0PT-12.2B, No. 2 Diesel Generator Monthly Load Test after cylinder o-ring replacement on September 26, 2022

(3) PMT associated with the replacement of A train core spray discharge line relief valve, 1E-21-F012A, in accordance with (IAW) work order (WO) 20240640

(4) PMT associated with the replacement of damaged section of HPCI line 1-E41-V6-1/2-605 IAW WO 20419829.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Inservice Testing (IP Section 03.01) (1 Sample)

(1) 0PT-10.1.1, RCIC System Operability Test" conducted on September 16, 2022

FLEX Testing (IP Section 03.02) (2 Samples)

(1) 0PT-12.27, FLEX Diesel Generator 1 and 2 Test Procedure on September 26, 2022

(2) Quarterly surveillance of equipment located in the FLEX building on July 12, 2022.

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11) (1 Sample)

(1) The inspectors evaluated the biennial emergency plan exercise during the week of July 25, 2022. The simulated scenario began with an inadvertent high pressure coolant injection pump start that caused thermal stresses to reactor coolant piping and the reactor fuel due to cold water injection at 100 percent power. The subsequent reactor coolant leak caused pressure to rise in containment, thus meeting the conditions for declaration of an Alert. The combination of thermal stresses and a reactor scram caused fuel damage with increasing drywell radiation levels to the point of meeting the conditions for declaring a Site Area Emergency. Finally, a simulated drop in containment pressure from the release of radioactive gases into the reactor building, met the conditions for declaring a General Emergency, and allowed the Offsite Response Organizations to demonstrate their ability to implement emergency actions.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted emergency action level, emergency plan, and emergency plan implementing procedure changes during the week of July 25, 2022. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) A simulator examination (training evolution) given to an operating crew during licensed operator requalification training on August 9, 2022. The simulator examination included a drill/exercise performance opportunity.

71114.08 - Exercise Evaluation - Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise at least 30 days prior to the day of the exercise.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===

(1) Unit 1 (July 1, 2021 through June 30, 2022)

(2) Unit 2 (July 1, 2021 through June 30, 2022)

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1 (July 1, 2021 through June 30, 2022)

(2) Unit 2 (July 1, 2021 through June 30, 2022)

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) October 1, 2021, through March 31, 2022

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) October 1, 2021, through March 31, 2022

EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) October 1, 2021, through March 31, 2022

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) NCR 2323829: Unit 1 Fuel Leak.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow Up (IP Section 03.01)

Hurricane Ian:

(1) The inspectors evaluated effects of Hurricane Ian as well as the licensees response to the storm on September 30. Region II activated the incident response center (IRC)at 1100. The two resident inspectors were on site at the time and served as "storm riders" along with a third inspector sent from the Region II office. In this capacity, the inspectors verified the safe operation of the facility during the hurricane and also ensured continued oversight during the storm in case access to the facility was impacted. The maximum sustained winds were noted to be approximately 45mph and no significant impacts were noted on site. Both units continued to operate during the storm at 100 percent RTP. Following passing of Hurricane Ian and a subsequent drop in sustained wind speeds, the IRC was stood down at

INSPECTION RESULTS

Observation: Unit 1 Fuel Leak 71152A The inspectors conducted a detailed review of NCR 2323829, Unit 1 Fuel Leak." The inspectors chose this sample because it dealt with the Barrier Integrity Cornerstone involving the fuel rod cladding. On April 4, 2020, following a return to 100 percent RTP, a fuel failure was identified on Unit 1 from fuel cycle B1C23 as a result of radiochemistry samples and the steam jet air ejector radiation monitor readings. The unit had just completed a refueling outage (RFO) in March 2020. Power suppression testing was performed, and the fuel leak was suppressed using control rods. On June 13, Unit 1 was shut down to perform a maintenance outage to identify and discharge the leaking assembly. Mast sipping, performed on all fuel assemblies, identified assembly A22709 as the leaking fuel assembly. Ultimately, eddy current testing revealed defects on fuel rods A01 and A07 of assembly A22709. This assembly was ultimately not returned to the core and discharged to the spent fuel pool. Additionally, three other suspect fuel assemblies were discharged as well. All were of the older Areva Atrium 10 style fuel assemblies and not the newer Atrium 11 fuel design.

The licensee performed a root cause analysis in order to understand the failure mechanism and develop corrective actions to address the deficiencies. This analysis also incorporated a fuel failure from the previous fuel cycle, B1C22. Similarly, during the refueling outage in March, fuel assembly A22779 from fuel cycle B1C22 was determined to be failed and was suppressed during the previous cycle. Specifically, rod F01 was noted to have a defect and the assembly was discharged during the March 2020 refueling outage. The "most likely" root cause of both failures was determined to be debris-induced failure. The licensee could not rule out this failure mode due to indications of fretting potentially caused by foreign material.

Several corrective actions have been implemented including the performance of ultrasonic fuel cleaning on both units of all assemblies reinserted into the core during the subsequent RFO on each unit. This was performed in 2021 (Unit 2) and 2022 (Unit 1). Additionally, a full core offload was subsequently done during the RFO in 2021 (Unit 2) and 2022 (Unit 1) to perform a foreign object search and retrieval (FOSAR) evolution which was performed to identify and remove any foreign material trapped in the lower vessel internals.

The inspectors noted that the root cause was detailed and comprehensive. The corrective actions also addressed the potential cause. However, it should be noted that another fuel failure was noted on February 16, 2022, on Unit 2. This was after the performance of the ultrasonic fuel cleaning and the FOSAR in 2021. Due to this recent failure, the inspectors noted that management may need to revisit the root cause to ensure this new failure is bounded by the previous analysis. The licensee plans to discharge the affected Unit 2 assembly in the upcoming April 2023 RFO.

EXIT MEETINGS AND DEBRIEFS

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

On October 31, 2022, the inspectors presented the Integrated Inspection results to John A. Krakuszeski and other members of the licensee staff.

On July 29, 2022, the inspectors presented the Emergency Preparedness Exercise Inspection results to Mr. John A. Krakuszeski and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures 0AI-68 Brunswick Nuclear Plant Response to Severe Weather 63

Warnings

AOP-13 Operating During Hurricane, Flood Conditions, Tornado, or 73

Earthquake

71111.04 Drawings D-02524 SH0001 Reactor Building Core Spray System Piping Diagram 044

D-O2524 SH0001 Reactor Building Core Spray System Piping Diagram 044

Procedures 0OP39 Diesel Generator Operating Procedure 198

1OP-18 Core Spray System Operating Procedure 64

2OP-16 Reactor Core Isolation Cooling System Operating Procedure128

2OP-17 Residual Heat Removal System Operating Procedure 186

SD-16 Reactor Core Isolation Cooling System 13

SD-17 Residual Heat Removal System 20

SD-18 Core Spray System 6

SD-39 Emergency Diesel Generators 22

71111.05 Fire Plans 0PFP-013 General Fire Plan 54

CSD-BNP-PFP-Reactor Building Pre-fire Plans 2

1RB

CSD-BNP-PFP-Reactor Building Pre-fire Plans 0

2RB

Procedures 0AP-033 Fire Protection Program Manual 26

0PLP-01.2 Fire Protection System Operability, Action, and Surveillance 51

Requirements

AD-FP-ALL-1520 Transient Combustible Control 0

71111.11B Miscellaneous AOT-OJT-JP-Crew D, Week 2, Job Performance Measures Misc

010-A01, AOT-

OJT-JP-041-A03,

LOT-SIM-JP-032-

10, LOT-SIM-JP-

29-01, LOT-SIM-

JP-002-A03,

LOT-ADM-JP-

2-01, LOT-

Inspection Type Designation Description or Title Revision or

Procedure Date

ADM-JP-201-D14

LORX-014 Crew D, Week 2 Scenario 2 Revision 19

LORX-029 Crew A, Week 4 Scenario 1 Revision 10

LORX-043 Crew D, Week 2 Scenario 1 Revision 03

LORX-051 Crew C, Week 1 Scenario 1 Revision 05

LOT-OJT-JP-300- Crew C, Week 1, Job Performance Measures Misc

J25, LOT-SIM-

008-005,

LOT-SIM-JP-037-Crew A, Week 4, Job Performance Measures Revision 0

009

NRC Biennial RO and SRO Written Exams 08/23/2021

Requalification

Written Exams

Procedures AD-TQ-ALL-0068 Licensed Operator Continuing Training Program Revision 12

AD-TQ-ALL-0101 Conduct of the Systematic Approach to Training Revision 12

AD-TQ-ALL-0320 Development of Simulator Training and Evaluation Guides Revision 9

AD-TQ-ALL-0420 Conduct of Simulator Training and Evaluation Revision 19

AD-TQ-ALL-230 Licensed Operator Requalification Annual and Biennial Revision 11

Exam Development

71111.11Q Miscellaneous LORX-029 MCC 2XC Trip, Instrument Air Leak, MTLO Temperature 10

Controller Failure, Loss of Off-Site Power Large Break

LOCA

LORX-141 LOP Instrumentation Failure (TS), Condenser Tube Leak, 06C

ATWS, SLC Pump 2A Trip, CRD FCV A Failure, 2E11-F048

B HX BPV Failure

Procedures 0GP-12 Power Changes 95

71111.12 Procedures AD-EG-ALL-1210 Maintenance Rule Program 3

AD-WC-ALL-0200 On-line Work Management 20

AD-WC-ALL-0250 Work Implementation and Completion 15

71111.13 Procedures AD-OP-ALL-0201 Protected Equipment 9

AD-WC-ALL-0200 On-Line Work Management 20

AD-WC-ALL-0250 Work Implementation and Completion 15

AD-WC-ALL-0410 Work Activity Integrated Risk Management 13

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.15 Corrective Action AR 02434489 Loss of power to U1 HPCI flow controller 07/15/2022

Documents

Miscellaneous RA-22-0242 Licensee Event Report for HCPI inoperability 09/12/2022

Procedures AD-OP-ALL-0105 Operability Determinations 6

71111.19 Procedures 0PLP-20 Post-Maintenance Testing Program 55

0PT-12.2A NO. 1 Diesel Generator Monthly Load Test 124

0PT-12.2B NO. 2 Diesel Generator Monthly Load Test 121

Work Orders 2012976901 2-DG2-ENG Replace Cylinder O-Rings 08/09/2022

2012976907 2-DG2-ENG Replace Cylinder O-Rings (6R) 08/11/2022

2016110305 2-DG1-ENG Replace Cylinder O-Rings 07/10/2022

2016110313 2-MUD-JKT-WTR-HTR-1, Remove JW Piping 07/07/2022

2016110314 2-MUD-JKT-WTR-HTR-1 07/12/2022

206110317 2-DG1-ENG Replace Cylinder O-Rings 07/13/2022

71111.22 Procedures 0ENP-16.1 IST Pump and Valve Data 36

0ENPP-17 Pump and Valve Inservice Testing (IST) 40

0OP-39.2 Flex Diesel Generator Operating Procedure 7

0PT-12.27 Flex Diesel Generator 1 and 2 Test Procedure 07/22/2022

0PT-12.27 Flex Diesel Generator 1 and 2 Test Procedure 005

Work Orders 20483828-01 Annual Flex Equipment Inspection 07/07/2022

20529082-01 Quarterly Flex Equipment Inspection run-test 07/07/2022

71114.06 Procedures AD-EP-ALL-0002 NRC Regulatory Assessment Performance Indicator 6

Guideline Emergency Preparedness Cornerstone

71151 Miscellaneous NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7

RCS Activity Chemistry Data 07/01/2021 -

06/30/2022

RCS Leakage OPS Leakage Database 07/01/2021 -

06/30/2022

Procedures AD-PI-ALL-0700 Performance Indicators 5

71153 Procedures 0AI-68 Brunswick Nuclear Plant Response to Severe Weather 63

Warnings

AOP-13 Operating During Hurricane, Flood Conditions, Tornado, or 73

Earthquake

13