IR 05000324/2022002: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:August 5, 2022
{{#Wiki_filter:==SUBJECT:==
 
==SUBJECT:==
BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2022002 AND 05000325/2022002
BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2022002 AND 05000325/2022002


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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.
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, Signed by Fannon, Matthew on 08/05/22 Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000324 and 05000325 License Nos. DPR-62 and DPR-71
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:===
===Enclosure:===
As stated
As stated  


==Inspection Report==
==Inspection Report==
Docket Numbers: 05000324 and 05000325 License Numbers: DPR-62 and DPR-71 Report Numbers: 05000324/2022002 and 05000325/2022002 Enterprise Identifier: I-2022-002-0016 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant Location: Southport, NC Inspection Dates: April 01, 2022 to June 30, 2022 Inspectors: C. Curran, Resident Inspector A. Rosebrook, Senior Reactor Analyst M. Schwieg, Senior Reactor Inspector J. Seat, Senior Project Engineer G. Smith, Senior Resident Inspector J. Steward, Senior Resident Inspector Approved By: Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
Docket Numbers:
05000324 and 05000325
License Numbers:
DPR-62 and DPR-71
Report Numbers:
05000324/2022002 and 05000325/2022002
Enterprise Identifier:
I-2022-002-0016
Licensee:
Duke Energy Progress, LLC
Facility:
Brunswick Steam Electric Plant
Location:
Southport, NC
Inspection Dates:
April 01, 2022 to June 30, 2022
Inspectors:
C. Curran, Resident Inspector
A. Rosebrook, Senior Reactor Analyst
M. Schwieg, Senior Reactor Inspector
J. Seat, Senior Project Engineer
G. Smith, Senior Resident Inspector
J. Steward, Senior Resident Inspector
Approved By:
Matthew S. Fannon, Chief
Reactor Projects Branch 4
Division of Reactor Projects


=SUMMARY=
=SUMMARY=
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===List of Findings and Violations===
===List of Findings and Violations===
No findings or violations of more than minor significance were identified.
No findings or violations of more than minor significance were identified.


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==REACTOR SAFETY==
==REACTOR SAFETY==
==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection==
===Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)===
===Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)===
: (1) From April 12 through April 14, 2022, the inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal high temperatures for the following systems:
: (1) From April 12 through April 14, 2022, the inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal high temperatures for the following systems:
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==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment==
===Partial Walkdown Sample (IP Section 03.01) (5 Samples)===
===Partial Walkdown Sample (IP Section 03.01) (5 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) 2C and 2E main control room (MCR) heating, ventilating, air conditioning (HVAC)units while the 1D MCR HVAC unit was out-of-service (OOS) for replacement on April 26, 2022
(1)2C and 2E main control room (MCR) heating, ventilating, air conditioning (HVAC)units while the 1D MCR HVAC unit was out-of-service (OOS) for replacement on April 26, 2022
: (2) Unit 2 high pressure coolant injection (HPCI) system while the Unit 2 reactor core isolation cooling system was OOS for planned maintenance on April 26, 2022
: (2) Unit 2 high pressure coolant injection (HPCI) system while the Unit 2 reactor core isolation cooling system was OOS for planned maintenance on April 26, 2022
: (3) Unit 2 nuclear service water and conventional service water (CSW) while Unit 2 'B' CSW pump was OOS for planned maintenance on May 11, 2022
: (3) Unit 2 nuclear service water and conventional service water (CSW) while Unit 2 'B' CSW pump was OOS for planned maintenance on May 11, 2022
: (4) Unit 2 B residual heat removal (RHR) train while A train was OOS for planned maintenance on May 25, 2022
: (4) Unit 2 B residual heat removal (RHR) train while A train was OOS for planned maintenance on May 25, 2022 (5)emergency diesel generators (EDGs) -2, -3, and -4 while EDG-1 was OOS for a maintenance outage on June 22, 2022
: (5) emergency diesel generators (EDGs) -2, -3, and -4 while EDG-1 was OOS for a maintenance outage on June 22, 2022


==71111.05 - Fire Protection==
==71111.05 - Fire Protection==
===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)===
===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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:
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) Fire area RB2-01-D in the Unit 2 southeast RHR room on April 14, 2022
: (1) Fire area RB2-01-D in the Unit 2 southeast RHR room on April 14, 2022
: (2) Control building HVAC room on April 26, 2022
: (2) Control building HVAC room on April 26, 2022 (3)1A, 1B, 2A, 2B battery rooms in the 23 elevation of the control building on May 5, 2022
: (3) 1A, 1B, 2A, 2B battery rooms in the 23 elevation of the control building on May 5, 2022
: (4) Unit 1 reactor building -17 elevation on May 5, 2022
: (4) Unit 1 reactor building -17 elevation on May 5, 2022
: (5) Service water building 20 and 4 elevations on May 10, 2022
: (5) Service water building 20 and 4 elevations on May 10, 2022
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==71111.06 - Flood Protection Measures==
==71111.06 - Flood Protection Measures==
===Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)===
===Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)===
The inspectors evaluated internal flooding mitigation protections in the:
The inspectors evaluated internal flooding mitigation protections in the:
: (1) safety-related manholes (NS3, NS2, 5NW) on April 21, 2022
(1)safety-related manholes (NS3, NS2, 5NW) on April 21, 2022 (2)emergency diesel generator building and 4-day fuel oil tank rooms on May 18, 2022
: (2) emergency diesel generator building and 4-day fuel oil tank rooms on May 18, 2022


==71111.11Q - Licensed Operator Requalification Program and 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)
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 control room during Unit 1 reactor startup on April 2, 2022.
: (1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 reactor startup on April 2, 2022.
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==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness==
===Maintenance Effectiveness (IP Section 03.01) (2 Samples)===
===Maintenance Effectiveness (IP Section 03.01) (2 Samples)===
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
: (1) relay failure (high contact resistance) that resulted in a spurious partial Group 6 and secondary containment isolation (NCR 2410783) on January 4, 2022
(1)relay failure (high contact resistance) that resulted in a spurious partial Group 6 and secondary containment isolation (NCR 2410783) on January 4, 2022
: (2) EDG-1 maintenance outage conducted from June 20 through June 29, 2022
: (2) EDG-1 maintenance outage conducted from June 20 through June 29, 2022


==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
===Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)===
===Risk Assessment and Management Sample (IP Section 03.01) (6 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:
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) emergent failure of reactor building radiation monitor on April 14, 2022
(1)emergent failure of reactor building radiation monitor on April 14, 2022 (2)emergent steam leak in the Unit 2 main steam isolation valve (MSIV) pit discovered on May 8, 2022 (3)elevated risk due to 2B CSW pump strainer planned maintenance from May 9 through May 12, 2022 (4)emergent failure of 1C CSW pump strainer shear pin on May 11, 2022 (5)elevated risk due to Unit 1 A train RHR outage on May 25, 2022 (6)elevated risk due to EDG-1 maintenance outage on June 23, 2022
: (2) emergent steam leak in the Unit 2 main steam isolation valve (MSIV) pit discovered on May 8, 2022
: (3) elevated risk due to 2B CSW pump strainer planned maintenance from May 9 through May 12, 2022
: (4) emergent failure of 1C CSW pump strainer shear pin on May 11, 2022
: (5) elevated risk due to Unit 1 A train RHR outage on May 25, 2022
: (6) elevated risk due to EDG-1 maintenance outage on June 23, 2022


==71111.15 - Operability Determinations and Functionality Assessments==
==71111.15 - Operability Determinations and Functionality Assessments==
===Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)===
===Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)===
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
: (1) 2-B32-F031B actuator rating exceeded (NCR 2414157)
(1)2-B32-F031B actuator rating exceeded (NCR 2414157)
: (2) RHR valve weight analysis discrepancy (NCR 2417296)
: (2) RHR valve weight analysis discrepancy (NCR 2417296)
: (3) deterioration of concrete wall in Unit 2 reactor building (NCR 2305749)
(3)deterioration of concrete wall in Unit 2 reactor building (NCR 2305749)
: (4) reanalysis of HPCI pump time limit to rated speed and flow (NCR 2419332)
(4)reanalysis of HPCI pump time limit to rated speed and flow (NCR 2419332)


==71111.18 - Plant Modifications==
==71111.18 - Plant Modifications==
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
The inspectors evaluated the following temporary or permanent modifications:
: (1) control building HVAC modification (Engineering Change 417875) completed on June 16, 2022
(1)control building HVAC modification (Engineering Change 417875) completed on June 16, 2022


==71111.19 - Post-Maintenance Testing==
==71111.19 - Post-Maintenance Testing==
===Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)===
===Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)===
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
: (1) 0PT-09.2 HPCI operability test after replacement of the flow controller FIC-R600 in accordance with (IAW) work order (WO) 20304709
(1)0PT-09.2 HPCI operability test after replacement of the flow controller FIC-R600 in accordance with (IAW) work order (WO) 20304709 (2)2B standby gas treatment system (SBGT) system following planned maintenance to replace drain piping IAW WO 20372477 (3)1A SBGT system following planned maintenance to recoat drain line piping IAW WO  
: (2) 2B standby gas treatment system (SBGT) system following planned maintenance to replace drain piping IAW WO 20372477
: (3) 1A SBGT system following planned maintenance to recoat drain line piping IAW WO


===20377862
===20377862 (4)2B CSW pump strainer planned maintenance and inspection IAW WO's 20399034 and 20412939 (5)0PT-09.2, HPCI operability test following replacement of the Unit 2 HPCI EGR servo motor IAW WO 20525661
: (4) 2B CSW pump strainer planned maintenance and inspection IAW WO's 20399034 and 20412939
: (5) 0PT-09.2, HPCI operability test following replacement of the Unit 2 HPCI EGR servo motor IAW WO 20525661
: (6) G31-F001, reactor water cleanup (RWCU) inboard suction valve following valve replacement IAW WO 20377862
: (6) G31-F001, reactor water cleanup (RWCU) inboard suction valve following valve replacement IAW WO 20377862
: (7) G31-F004, RWCU outboard suction valve following valve replacement IAW WO 20377862
: (7) G31-F004, RWCU outboard suction valve following valve replacement IAW WO 20377862


==71111.20 - Refueling and Other Outage Activities==
==71111.20 - Refueling and Other Outage Activities==
 
Refueling/Other Outage Sample (IP Section 03.01)===
Refueling/Other Outage Sample (IP Section 03.01) ===
{{IP sample|IP=IP 20377|count=1}}
{{IP sample|IP=IP 20377|count=1}}
: (1) The inspectors evaluated Unit 1 refueling outage (B1R24) activities from March 5, 2022 to April 4, 2022, when the main generator was synched to the grid.
: (1) The inspectors evaluated Unit 1 refueling outage (B1R24) activities from March 5, 2022 to April 4, 2022, when the main generator was synched to the grid.


==71111.22 - Surveillance Testing==
==71111.22 - Surveillance Testing==
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:


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===RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)===
===RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)===
: (1) Unit 1 reactor coolant system (RCS) leakage IAW 0OI-02.3, "Drywell Leakage             Control," on June 30, 2022
: (1) Unit 1 reactor coolant system (RCS) leakage IAW 0OI-02.3, "Drywell Leakage Control," on June 30, 2022


==71114.06 - Drill Evaluation==
==71114.06 - Drill Evaluation==
===Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)===
===Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)===
The inspectors evaluated:
The inspectors evaluated:
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==OTHER ACTIVITIES - BASELINE==
==OTHER ACTIVITIES - BASELINE==
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
{{IP sample|IP=IP 71151|count=2}}
{{IP sample|IP=IP 71151|count=2}}
: (1) Unit 1 (April 1, 2021 through March 31, 2022)
: (1) Unit 1 (April 1, 2021 through March 31, 2022)
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: (2) Unit 2 (April 1, 2021 through March 31, 2022)
: (2) Unit 2 (April 1, 2021 through March 31, 2022)


===71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) ===
===71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)===
{{IP sample|IP=IP 71152|count=1}}
{{IP sample|IP=IP 71152|count=1}}
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
: (1) NCR 2379462: Reactor recirculation pump seal premature failure
: (1) NCR 2379462: Reactor recirculation pump seal premature failure


===71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02) ===
===71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)===
{{IP sample|IP=IP 71152|count=1}}
{{IP sample|IP=IP 71152|count=1}}
: (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in operations and maintenance that might be indicative of a more significant safety issue.
: (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in operations and maintenance that might be indicative of a more significant safety issue.


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Observation: Reactor Recirculation Pump Seal Premature Failure                         71152A The inspectors conducted a detailed review of NCR 2379462, Reactor Recirculation Pump Seal Premature Failure. The inspectors chose this sample because it dealt with the barrier integrity cornerstone involving the recirculation pump seals. On February 15, 2021, the second stage seal of the Unit 2 'B' recirculation pump was noted to be degrading. Based on the rate of degradation, the decision was made to replace the seal package during the upcoming March 2021 refueling outage. Following replacement of both the 'A' and 'B' seal packages during the refueling outage, operators noted a similar degrading second stage seal on the Unit 1 'B' recirculation pump on April 19, 2021. The decision was made to enter a maintenance outage on April 30 as the rate of seal degradation was excessive and the seal would not last until the next refueling outage in March 2022. The recirculation pump seals have an expected life of six years, yet the inspectors observed that the seals are degrading prior to reaching the end of their expected life cycle.
Observation: Reactor Recirculation Pump Seal Premature Failure 71152A The inspectors conducted a detailed review of NCR 2379462, Reactor Recirculation Pump Seal Premature Failure. The inspectors chose this sample because it dealt with the barrier integrity cornerstone involving the recirculation pump seals. On February 15, 2021, the second stage seal of the Unit 2 'B' recirculation pump was noted to be degrading. Based on the rate of degradation, the decision was made to replace the seal package during the upcoming March 2021 refueling outage. Following replacement of both the 'A' and 'B' seal packages during the refueling outage, operators noted a similar degrading second stage seal on the Unit 1 'B' recirculation pump on April 19, 2021. The decision was made to enter a maintenance outage on April 30 as the rate of seal degradation was excessive and the seal would not last until the next refueling outage in March 2022. The recirculation pump seals have an expected life of six years, yet the inspectors observed that the seals are degrading prior to reaching the end of their expected life cycle.


The licensee performed a detailed root cause analysis in order to understand the failure mechanism and develop corrective actions to address the deficiencies. The root cause was determined to be self-induced electro-corrosion of the second stage secondary seal. Several corrective actions have been implemented including the replacement of all 4 seals on both units. The inspectors noted that this will be a long-term effort as the design changes to address the direct cause of the electro-corrosion are still being developed. The inspectors determined that the licensees plan to address this issue was reasonably commensurate with the safety significance of the equipment that might be affected by this type of equipment failure.
The licensee performed a detailed root cause analysis in order to understand the failure mechanism and develop corrective actions to address the deficiencies. The root cause was determined to be self-induced electro-corrosion of the second stage secondary seal. Several corrective actions have been implemented including the replacement of all 4 seals on both units. The inspectors noted that this will be a long-term effort as the design changes to address the direct cause of the electro-corrosion are still being developed. The inspectors determined that the licensees plan to address this issue was reasonably commensurate with the safety significance of the equipment that might be affected by this type of equipment failure.


Observation: Semi-Annual Trend Review                                                   71152S The inspectors performed a trend analysis on the licensees corrective action program to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on equipment performance trends, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of January
Observation: Semi-Annual Trend Review 71152S The inspectors performed a trend analysis on the licensees corrective action program to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on equipment performance trends, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of January  
  - June 2022, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends.
- June 2022, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends.


Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.
Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.
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=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Inspection Type         Designation   Description or Title                                         Revision or
Inspection
Procedure                                                                                            Date
Procedure
71111.01  Miscellaneous SD-50         230 KV Electric Distribution System                         01/14/2020
Type
Procedures   CSD-EG-ALL-   Nuclear Switchyard Operating Guidelines                      08/30/2018
Designation
Description or Title
Revision or
Date
Miscellaneous
SD-50
230 KV Electric Distribution System
01/14/2020
71111.01
Procedures
CSD-EG-ALL-
2000.2
2000.2
71111.04  Miscellaneous SD-37         Control Building Heating, Ventilation, and Air-Conditioning 16
Nuclear Switchyard Operating Guidelines
08/30/2018
SD-37
Control Building Heating, Ventilation, and Air-Conditioning
System
System
SD-39         Emergency Diesel Generators                                 22
Miscellaneous
Procedures    0OP-37         Control Building Ventilation System Operating Procedure     75
SD-39
0OP-39         Diesel Generator Operating Procedure                         198
Emergency Diesel Generators
2OP-17         Residual Heat Removal System Operating Procedure             185
0OP-37
2OP-19         High Pressure Coolant Injection System Operating             147
Control Building Ventilation System Operating Procedure
0OP-39
Diesel Generator Operating Procedure
198
2OP-17
Residual Heat Removal System Operating Procedure
185
2OP-19
High Pressure Coolant Injection System Operating
Procedure
Procedure
2OP-43         Service Water System Operating Procedure                     175
147
SD-17         Residual Heat Removal System                                 20
2OP-43
SD-19         High Pressure Coolant Injection (HPCI) System               25
Service Water System Operating Procedure
SD-43         Service Water System                                         27
175
71111.05  Engineering   288259        Seismic Verification of Fire Protection Piping              05/18/2022
SD-17
Residual Heat Removal System
SD-19
High Pressure Coolant Injection (HPCI) System
71111.04
Procedures
SD-43
Service Water System
Engineering
Changes
Changes
Fire Plans    CSD-BNP-PFP-   Control Building Pre-Fire Plans                              5
288259
Seismic Verification of Fire Protection Piping
05/18/2022
CSD-BNP-PFP-
0CB
0CB
CSD-BNP-PFP-   Miscellaneous Buildings Pre-Fire Plans - Protected Area      1
Control Building Pre-Fire Plans
CSD-BNP-PFP-
0MBPA
0MBPA
CSD-BNP-PFP-   Power Block Auxiliary Areas Pre-Fire Plans (SW, RW, AOG,     4
Miscellaneous Buildings Pre-Fire Plans - Protected Area
0PBAA          TY, EY, PDC, DGS, MCP)
Fire Plans
Miscellaneous 0FPP-031       Fire Brigade Staffing Roster and Equipment Requirements     34
CSD-BNP-PFP-
18-F-OS-01     Insulator Shop Fire Drill Scenario Guide                     05/18/2022
0PBAA
21-F-SB-01     Service Building Air HVAC Room Fire Drill Scenario Guide     05/18/2022
Power Block Auxiliary Areas Pre-Fire Plans (SW, RW, AOG,
Procedures    0AOP-13.0     Operation During Hurricane, Flood Conditions, Tornado, or   73
TY, EY, PDC, DGS, MCP)
0FPP-031
Fire Brigade Staffing Roster and Equipment Requirements
18-F-OS-01
Insulator Shop Fire Drill Scenario Guide
05/18/2022
Miscellaneous
21-F-SB-01
Service Building Air HVAC Room Fire Drill Scenario Guide
05/18/2022
0AOP-13.0
Operation During Hurricane, Flood Conditions, Tornado, or
Earthquake
Earthquake
0PFP-013       General Fire Plan                                           55
0PFP-013
0PLP-01.2     Fire Protection System Operability, Action, and Surveillance 51
General Fire Plan
0PLP-01.2
Fire Protection System Operability, Action, and Surveillance
Requirements
Requirements
AD-EG-ALL-1520 Transient Combustible Control                               13
71111.05
Inspection Type             Designation   Description or Title                                       Revision or
Procedures
Procedure                                                                                              Date
AD-EG-ALL-1520
CSD-BNP-PFP-   Reactor Building Prefire Plans                              2
Transient Combustible Control
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CSD-BNP-PFP-
1RB
1RB
71111.06  Corrective Action 555550         Fire Protection Piping Seismic Support Documentation       05/17/2022
Reactor Building Prefire Plans
Documents         AS 681677-05   Assignment Summary                                         07/29/2019
555550
Corrective Action 20537521      Work Order                                                  05/19/2022
Fire Protection Piping Seismic Support Documentation
05/17/2022
Corrective Action
Documents
AS 681677-05
Assignment Summary
07/29/2019
Corrective Action
Documents
Documents
Resulting from
Resulting from
Inspection
Inspection
Engineering      DBD-144       External and Internal Flooding Topical Design Basis         1
20537521
Evaluations                     Document
Work Order
PS-FP-G008     Analysis to Seismically Qualify Select Fire Protection Pipe 0
05/19/2022
DBD-144
External and Internal Flooding Topical Design Basis
Document
Engineering
Evaluations
PS-FP-G008
Analysis to Seismically Qualify Select Fire Protection Pipe
Supports in the Diesel Generator Building
Supports in the Diesel Generator Building
Miscellaneous    BNP-12-0104   Long Range Plan                                             05/18/2022
BNP-12-0104
UFSAR section Diesel Generator Building Internal Flooding Protection      27
Long Range Plan
05/18/2022
Miscellaneous
UFSAR section
3.4.2.2
3.4.2.2
Work Orders      20335906 02   BNP Man Hole Inspection AD-EG-ALL-1214                     05/24/2021
Diesel Generator Building Internal Flooding Protection
20449286 02   (LR) FOUR YEAR MAN HOLE INSPECTION PER AD-EG-               02
20335906 02
BNP Man Hole Inspection AD-EG-ALL-1214
05/24/2021
20449286 02
(LR) FOUR YEAR MAN HOLE INSPECTION PER AD-EG-
BNP-1214
BNP-1214
20449286 02   INSPECT MAN HOLE, DOCUMENT EGR-NGGC-0351                   02
20449286 02
INSPECT MAN HOLE, DOCUMENT EGR-NGGC-0351
INSPECTION
INSPECTION
20449286 02   BNP Man Hole Inspection AD-EG-BNP-1214                     10/11/2021
71111.06
71111.11Q Miscellaneous      LORX-202       Simulator Guide - Recirculation Loop 'A' flow transmitter   10b
Work Orders
20449286 02
BNP Man Hole Inspection AD-EG-BNP-1214
10/11/2021
LORX-202
Simulator Guide - Recirculation Loop 'A' flow transmitter
failure, RBCCW high radiation, LOOP, Small Break LOCA
failure, RBCCW high radiation, LOOP, Small Break LOCA
Segment 22-1   LOCT examination 2022 Cycle 1                              01/13/22
10b
Segment 22-1
Version A
Version A
Segment 22-1  LOCT Examination 2022 Cycle 1                               01/19/22
LOCT examination 2022 Cycle 1
01/13/22
Miscellaneous
Segment 22-1
Version B
Version B
Procedures       0GP-02         Approach to Criticality and Pressurization of the Reactor   128
LOCT Examination 2022 Cycle 1
71111.12  Procedures        AD-EG-ALL-1210 Maintenance Rule Program                                   3
01/19/22
AD-WC-ALL-     ON-LINE WORK MANAGMENT                                      20
71111.11Q
Procedures
0GP-02
Approach to Criticality and Pressurization of the Reactor
28
AD-EG-ALL-1210
Maintenance Rule Program
AD-WC-ALL-
200
200
AD-WC-ALL-     WORK IMPLEMENTATION AND COMPLETION                          15
ON-LINE WORK MANAGMENT
71111.12
Procedures
AD-WC-ALL-
250
250
71111.13   Corrective Action 2426363        Unit 2 MSIV Pit Steam Leak                                 05/09/2022
WORK IMPLEMENTATION AND COMPLETION
Inspection Type             Designation     Description or Title                                         Revision or
71111.13
Procedure                                                                                                Date
Corrective Action
26363
Unit 2 MSIV Pit Steam Leak
05/09/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Documents
Procedures        0AP-025         BNP Integrated Scheduling                                   60
0AP-025
AD-OP-ALL-0201 Protected Equipment                                         9
BNP Integrated Scheduling
AD-WC-ALL-     On-Line Work Management                                      20
AD-OP-ALL-0201
Protected Equipment
AD-WC-ALL-
200
200
AD-WC-ALL-     Work Implementation and Completion                          15
On-Line Work Management
AD-WC-ALL-
250
250
AD-WC-ALL-     Work Activity Integrated Risk Management                    13
Work Implementation and Completion
Procedures
AD-WC-ALL-
0410
0410
Work Orders       20225913        2-MS-F038D-MO, Backseat Valve Potential MSIV Pit Steam       05/10/2022
Work Activity Integrated Risk Management
Work Orders
225913
2-MS-F038D-MO, Backseat Valve Potential MSIV Pit Steam
Leak
Leak
71111.15  Calculations     0HPCI-0011     HPCI RESPONSE TIME REQUIREMENT                               002
05/10/2022
Corrective Action Action Request: 2-B32-F031B Actuator Rating Exceeded                         01/31/2022
Calculations
Documents         02414157
0HPCI-0011
Action Request: RHR Valve Weight Analysis Discrepancy                        02/23/2022
HPCI RESPONSE TIME REQUIREMENT
2
Action Request:
2414157
2-B32-F031B Actuator Rating Exceeded
01/31/2022
Corrective Action
Documents
Action Request:
2417296
2417296
Corrective Action 20226189        Work Request to drive repairs noted during inspection of the 05/12/2022
RHR Valve Weight Analysis Discrepancy
Documents                        Unit 1 South Core Spray Room EL -17'
2/23/2022
Resulting from   2427216        1-RB1-BLG-EL-17-1 Cosmetic Defect on Unit 1 SCE             05/12/2022
226189
Inspection                        Concrete Columns
Work Request to drive repairs noted during inspection of the
Drawings          9527-F-02501   Unit 1 Reactor Building Plan Below Grade EL (-) 17' - 0"     29
Unit 1 South Core Spray Room EL -17'
05/12/2022
Corrective Action
Documents
Resulting from
Inspection
27216
1-RB1-BLG-EL-17-1 Cosmetic Defect on Unit 1 SCE
Concrete Columns
05/12/2022
27-F-02501
Unit 1 Reactor Building Plan Below Grade EL (-) 17' - 0"
General Arrangement
General Arrangement
F-01230         Unit 2 Reactor Building Concrete Plan EL 20' - 0" - West     16
Drawings
Engineering      A/R 02423550   50.59 Screen to Extend HPCI Response Time                   Rev 00
F-01230
Evaluations      A/R 02423553    10 CFR 50.59 Evaluation to extend HPCI response time        Rev 00
Unit 2 Reactor Building Concrete Plan EL 20' - 0" - West
Operability      2305749        Repair Cosmetic Defect Void in Unit 2 Drywell Exterior Wall  05/12/2022
A/R 02423550
Evaluations      AD-OP-ALL-0105  OPERABILITY DETERMINATIONS                                  6
50.59 Screen to Extend HPCI Response Time
Procedures        0SPP-CEM500    Installation of Concrete and Grout                          25
Rev 00
AD-OP-ALL-0105  Operability Determinations                                  6
Engineering
71111.18  Engineering       EC 417875      50.59 Screen for EC 417875                                  Rev 00
Changes          EC 417875      CB HVAC Condensing Unit 1D Replacement                      Rev 015
Engineering      A/R 2391929    50.59 Screen for EC 417875                                  Rev 00
Evaluations
Evaluations
Inspection Type             Designation   Description or Title                                     Revision or
A/R 02423553
Procedure                                                                                            Date
CFR 50.59 Evaluation to extend HPCI response time
Procedures       PD-EG-ALL-1130 Engineering Change Program                               Rev 1
Rev 00
71111.19  Corrective Action 2426126        1-E41-V6 Flow Inst Connection Spraying Leak              05/05/2022
2305749
Repair Cosmetic Defect Void in Unit 2 Drywell Exterior Wall
05/12/2022
Operability
Evaluations
AD-OP-ALL-0105
OPERABILITY DETERMINATIONS
0SPP-CEM500
Installation of Concrete and Grout
71111.15
Procedures
AD-OP-ALL-0105
Operability Determinations
EC 417875
50.59 Screen for EC 417875
Rev 00
Engineering
Changes
EC 417875
CB HVAC Condensing Unit 1D Replacement
Rev 015
71111.18
Engineering
Evaluations
A/R 2391929
50.59 Screen for EC 417875
Rev 00
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
PD-EG-ALL-1130
Engineering Change Program
Rev 1
Corrective Action
Documents
Documents
Resulting from
Resulting from
Inspection
Inspection
Procedures        0PLP-20       Post-Maintenance Testing Program                         55
26126
0PM-STR500    
1-E41-V6 Flow Inst Connection Spraying Leak
: [[contact::R.P. Adams Self-Cleaning Strainers]], Model VWS 10 through 37
05/05/2022
0PT-09.2       HPCI System Operability Test                             153
0PLP-20
Work Orders      20304709       1-E41-FIC-R600, Replace Controller, HPCI Turb Flo Ind     05/03/2022
Post-Maintenance Testing Program
0PM-STR500
: [[contact::R.P. Adams Self-Cleaning Strainers]], Model VWS 10 through
Procedures
0PT-09.2
HPCI System Operability Test
153
20304709
1-E41-FIC-R600, Replace Controller, HPCI Turb Flo Ind
Controller
Controller
20372477       2B SBGT Drain Line Repairs                               05/16/2022
05/03/2022
20377862       Recoat 1A SBGT Drain Line Piping                         05/20/2022
20372477
20399034,     2B CSW Strainer maintenance                              05/20/2022
2B SBGT Drain Line Repairs
05/16/2022
20377862
Recoat 1A SBGT Drain Line Piping
05/20/2022
20399034,
20412939
20412939
20525661-06   Unit 2 HPCI Servo Replacement                             3/12/22
2B CSW Strainer maintenance
71111.20  Procedures        0GP-02         Approach to Criticality and Pressurization of the Reactor 128
05/20/2022
0GP-03         Unit Startup and Synchronization                         98
71111.19
0GP-04         Increasing Turbine Load to Rated Power                   132
Work Orders
71111.22  Procedures        0OI-02.3       Drywell Leakage Control                                   9
20525661-06
0PT-08.2.2B   LPCI/RHR SYSTEM OPERABILTIY TEST - LOOP B                 110
Unit 2 HPCI Servo Replacement
0PT-12.1A     No.1 Emergency Diesel Generator LOOP/LOCA Loading         11
3/12/22
0GP-02
Approach to Criticality and Pressurization of the Reactor
28
0GP-03
Unit Startup and Synchronization
71111.20
Procedures
0GP-04
Increasing Turbine Load to Rated Power
2
0OI-02.3
Drywell Leakage Control
0PT-08.2.2B
LPCI/RHR SYSTEM OPERABILTIY TEST - LOOP B
110
71111.22
Procedures
0PT-12.1A
No.1 Emergency Diesel Generator LOOP/LOCA Loading
Test
Test
71114.06  Procedures        AD-EP-ALL-002 NRC Regulatory Assessment Performance Indicator           7
AD-EP-ALL-002
NRC Regulatory Assessment Performance Indicator
Guideline Emergency Preparedness Cornerstone
Guideline Emergency Preparedness Cornerstone
AD-EP-ALL-0101 Emergency Classification                                 3
AD-EP-ALL-0101
CSD-EP-BNP-   EAL Wallchart (Both Hot and Cold)                        4
Emergency Classification
71114.06
Procedures
CSD-EP-BNP-
0101-02
0101-02
71151      Engineering      BNP-MECH-     BNP Mitigating System Performance Index Plant Basis       2
EAL Wallchart (Both Hot and Cold)
Evaluations       MSPI          Document
BNP-MECH-
BNP-PSA-069   NRC Mitigating System Performance Index (MSPI) PRA       17
MSPI
BNP Mitigating System Performance Index Plant Basis
Document
71151
Engineering
Evaluations
BNP-PSA-069
NRC Mitigating System Performance Index (MSPI) PRA
Input Document
Input Document
71152A     Procedures       AD-PI-ALL-0100 Corrective Action Program                                 27
71152A
71152S     Procedures       AD-PI-ALL-0100 Corrective Action Program                                 27
Procedures
AD-PI-ALL-0100
Corrective Action Program
71152S
Procedures
AD-PI-ALL-0100
Corrective Action Program
14
14
}}
}}

Latest revision as of 16:13, 27 November 2024

Integrated Inspection Report 05000324/2022002 and 05000325/2022002
ML22216A254
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 08/05/2022
From: Matthew Fannon
NRC/RGN-II/DRP/RPB4
To: Krakuszeski J
Duke Energy Progress
References
IR 2022002
Download: ML22216A254 (16)


Text

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2022002 AND 05000325/2022002

Dear Mr. Krakuszeski:

On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On July 20, 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:

05000324/2022002 and 05000325/2022002

Enterprise Identifier:

I-2022-002-0016

Licensee:

Duke Energy Progress, LLC

Facility:

Brunswick Steam Electric Plant

Location:

Southport, NC

Inspection Dates:

April 01, 2022 to June 30, 2022

Inspectors:

C. Curran, Resident Inspector

A. Rosebrook, Senior Reactor Analyst

M. Schwieg, Senior Reactor Inspector

J. Seat, Senior Project Engineer

G. Smith, Senior Resident Inspector

J. Steward, Senior Resident Inspector

Approved By:

Matthew S. Fannon, Chief

Reactor Projects Branch 4

Division of Reactor Projects

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 shutdown for a refueling outage. On April 2, 2022, the reactor was taken critical and a plant startup was commenced. On April 4, the main generator output breaker was closed and a power ascension was commenced. On April 5, power was stabilized at 30 percent rated thermal power (RTP) in order to perform condenser dimple plug testing to locate leaking water-box tubes. Following completion of dimple plug testing, a power ascension was commenced and Unit 1 reached 100 percent (full) RTP on April 15 following two rod improvements. Unit 1 continued to operate at full RTP until April 19 when power was reduced to 96 percent RTP due to a failure of a cell in the variable frequency drive (VFD) associated with the 'B' recirculation pump motor. Following the bypass of the 1B2 cell in the 'B' VFD, Unit 1 was restored to full RTP on the same day and continued to operate there until May 19 when power was reduced to 80 percent RTP due to a loss of one of the four Unit 1 off-site power lines (Weatherspoon). Following repairs to the Weatherspoon line, Unit 1 was restored to full RTP on May 21 and continued to operate at or near full RTP for the remainder of the inspection period.

Unit 2 began the period at full RTP and operated there until May 7, when power was reduced to 70 percent RTP in order to insert a second suppression rod due to an existing fuel leak. Following insertion of a second suppression rod, Unit 2 was restored to full power on May 8 and continued to operate there until May 20 when power was reduced to 70 percent RTP for the purpose of performing a control rod sequence exchange as well as insert a third suppression rod. Following the sequence exchange and suppression rod insertion, Unit 2 was restored to full RTP on May 25 following one rod improvement. Unit 2 continued to operate at or near full RTP for the remainder of the inspection period.

INSPECTION SCOPES

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

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) From April 12 through April 14, 2022, the inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal high temperatures for the following systems:

offsite AC power systems and onsite alternate AC systems, including the switchyard and transformers

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)2C and 2E main control room (MCR) heating, ventilating, air conditioning (HVAC)units while the 1D MCR HVAC unit was out-of-service (OOS) for replacement on April 26, 2022

(2) Unit 2 high pressure coolant injection (HPCI) system while the Unit 2 reactor core isolation cooling system was OOS for planned maintenance on April 26, 2022
(3) Unit 2 nuclear service water and conventional service water (CSW) while Unit 2 'B' CSW pump was OOS for planned maintenance on May 11, 2022
(4) Unit 2 B residual heat removal (RHR) train while A train was OOS for planned maintenance on May 25, 2022 (5)emergency diesel generators (EDGs) -2, -3, and -4 while EDG-1 was OOS for a maintenance outage on June 22, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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) Fire area RB2-01-D in the Unit 2 southeast RHR room on April 14, 2022
(2) Control building HVAC room on April 26, 2022 (3)1A, 1B, 2A, 2B battery rooms in the 23 elevation of the control building on May 5, 2022
(4) Unit 1 reactor building -17 elevation on May 5, 2022
(5) Service water building 20 and 4 elevations on May 10, 2022
(6) Unit 1 reactor building 20 elevation on May 11, 2022

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during announced fire drills conducted on May 18, 2022, in the service building HVAC room and on May 24, 2022, in the insulator shop (yard area).

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)

The inspectors evaluated internal flooding mitigation protections in the:

(1)safety-related manholes (NS3, NS2, 5NW) on April 21, 2022 (2)emergency diesel generator building and 4-day fuel oil tank rooms on May 18, 2022

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 reactor startup on April 2, 2022.

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

(1) The inspectors observed and evaluated two operating crews during a simulator exam on April 21, 2022. The simulator exam was part of the licensed operator continuing training cycle 2. The scenario consisted of a recirculation loop flow transmitter failure, a reactor building closed cooling water heat exchanger leak, a loss of off-site power, and a small break loss of coolant accident.
(2) On May 19, 2022, the inspectors completed a review and evaluation of a written exam given in licensed operator continuing training cycle 1 conducted during the first quarter of 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1)relay failure (high contact resistance) that resulted in a spurious partial Group 6 and secondary containment isolation (NCR 2410783) on January 4, 2022

(2) EDG-1 maintenance outage conducted from June 20 through June 29, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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)emergent failure of reactor building radiation monitor on April 14, 2022 (2)emergent steam leak in the Unit 2 main steam isolation valve (MSIV) pit discovered on May 8, 2022 (3)elevated risk due to 2B CSW pump strainer planned maintenance from May 9 through May 12, 2022 (4)emergent failure of 1C CSW pump strainer shear pin on May 11, 2022 (5)elevated risk due to Unit 1 A train RHR outage on May 25, 2022 (6)elevated risk due to EDG-1 maintenance outage on June 23, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

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

(1)2-B32-F031B actuator rating exceeded (NCR 2414157)

(2) RHR valve weight analysis discrepancy (NCR 2417296)

(3)deterioration of concrete wall in Unit 2 reactor building (NCR 2305749)

(4)reanalysis of HPCI pump time limit to rated speed and flow (NCR 2419332)

71111.18 - Plant Modifications

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

The inspectors evaluated the following temporary or permanent modifications:

(1)control building HVAC modification (Engineering Change 417875) completed on June 16, 2022

71111.19 - Post-Maintenance Testing

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

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

(1)0PT-09.2 HPCI operability test after replacement of the flow controller FIC-R600 in accordance with (IAW) work order (WO) 20304709 (2)2B standby gas treatment system (SBGT) system following planned maintenance to replace drain piping IAW WO 20372477 (3)1A SBGT system following planned maintenance to recoat drain line piping IAW WO

===20377862 (4)2B CSW pump strainer planned maintenance and inspection IAW WO's 20399034 and 20412939 (5)0PT-09.2, HPCI operability test following replacement of the Unit 2 HPCI EGR servo motor IAW WO 20525661

(6) G31-F001, reactor water cleanup (RWCU) inboard suction valve following valve replacement IAW WO 20377862
(7) G31-F004, RWCU outboard suction valve following valve replacement IAW WO 20377862

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01)===

(1) The inspectors evaluated Unit 1 refueling outage (B1R24) activities from March 5, 2022 to April 4, 2022, when the main generator was synched to the grid.

71111.22 - Surveillance Testing

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

Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) Loss of offsite power/loss of coolant accident (LOOP/LOCA) test on April 7, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Unit 2 'B' RHR quarterly surveillance on June 4, 2022

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Unit 1 reactor coolant system (RCS) leakage IAW 0OI-02.3, "Drywell Leakage Control," on June 30, 2022

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 two separate operating crews on April 22, 2022. The simulator examination included a drill/exercise performance opportunity.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 1 (April 1, 2021 through March 31, 2022)
(2) Unit 2 (April 1, 2021 through March 31, 2022)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (April 1, 2021 through March 31, 2022)
(2) Unit 2 (April 1, 2021 through March 31, 2022)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (April 1, 2021 through March 31, 2022)
(2) Unit 2 (April 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 2379462: Reactor recirculation pump seal premature failure

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in operations and maintenance that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Observation: Reactor Recirculation Pump Seal Premature Failure 71152A The inspectors conducted a detailed review of NCR 2379462, Reactor Recirculation Pump Seal Premature Failure. The inspectors chose this sample because it dealt with the barrier integrity cornerstone involving the recirculation pump seals. On February 15, 2021, the second stage seal of the Unit 2 'B' recirculation pump was noted to be degrading. Based on the rate of degradation, the decision was made to replace the seal package during the upcoming March 2021 refueling outage. Following replacement of both the 'A' and 'B' seal packages during the refueling outage, operators noted a similar degrading second stage seal on the Unit 1 'B' recirculation pump on April 19, 2021. The decision was made to enter a maintenance outage on April 30 as the rate of seal degradation was excessive and the seal would not last until the next refueling outage in March 2022. The recirculation pump seals have an expected life of six years, yet the inspectors observed that the seals are degrading prior to reaching the end of their expected life cycle.

The licensee performed a detailed root cause analysis in order to understand the failure mechanism and develop corrective actions to address the deficiencies. The root cause was determined to be self-induced electro-corrosion of the second stage secondary seal. Several corrective actions have been implemented including the replacement of all 4 seals on both units. The inspectors noted that this will be a long-term effort as the design changes to address the direct cause of the electro-corrosion are still being developed. The inspectors determined that the licensees plan to address this issue was reasonably commensurate with the safety significance of the equipment that might be affected by this type of equipment failure.

Observation: Semi-Annual Trend Review 71152S The inspectors performed a trend analysis on the licensees corrective action program to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on equipment performance trends, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of January

- June 2022, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends.

Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.

During this review, the inspectors noted the reemergence of a negative trend with respect to reactor fuel performance. In Brunswick inspection report 05000324/2019002 and 05000325/2019002 (ADAMS Accession No. ML19221B744), the inspectors noted a negative trend based on three separate fuel cycles experiencing fuel failures. Following these failures, the licensee aggressively addressed the failures by performing detailed root cause evaluations. No definitive cause was noted. However, some of the failures were attributed to potential negative effects from foreign material. Additionally, one failure was attributed to a manufacturing defect. In order to address the foreign material, the license chose to clean all fuel assemblies during the upcoming refueling outages as well as perform a foreign object search and retrieval (FOSAR) activity. As of June 30, 2022, the fuel cleaning and FOSAR activities have been completed on both Unit 1 and Unit 2 during the most recent refueling outages. Since the initial determination of a negative trend in 2019, the inspectors noted two more cycles (Unit 1 in 2020 and Unit 2 in 2022) where fuel failures were encountered.

Despite the fuel cleaning and FOSAR efforts, Unit 2 recently experienced another fuel failure in April 2022 which necessitated flux suppression. Even given the flux suppression, the Unit 2 reactor coolant system activity has remained elevated. In summary, the condition reports (CRs) noted below document that five of the past seven fuel cycles on Unit 1 and Unit 2 experienced fuel leaks. Fuels leaks typically drive the licensee to suppress the neutron flux of the affected fuel assembly by inserting control rod(s) in the vicinity of the fuel leak. The inserted control rod can result in reduction of margin to thermal limits, limit rates of power increase, and increase the number of rod programming changes. The inspectors discussed this negative trend with the licensee.

  • CR 2416401 (Unit 2, 2022)
  • CR 2323829 (Unit 1, 2020)
  • CR 2276790 (Unit 1, 2019)
  • CR 2176522 (Unit 2, 2018)
  • CR 2078244 (Unit 1, 2016)

EXIT MEETINGS AND DEBRIEFS

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

On July 20, 2022, the inspectors presented the integrated inspection results to John A.

Krakuszeski and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Miscellaneous

SD-50

230 KV Electric Distribution System

01/14/2020

71111.01

Procedures

CSD-EG-ALL-

2000.2

Nuclear Switchyard Operating Guidelines

08/30/2018

SD-37

Control Building Heating, Ventilation, and Air-Conditioning

System

Miscellaneous

SD-39

Emergency Diesel Generators

0OP-37

Control Building Ventilation System Operating Procedure

0OP-39

Diesel Generator Operating Procedure

198

2OP-17

Residual Heat Removal System Operating Procedure

185

2OP-19

High Pressure Coolant Injection System Operating

Procedure

147

2OP-43

Service Water System Operating Procedure

175

SD-17

Residual Heat Removal System

SD-19

High Pressure Coolant Injection (HPCI) System

71111.04

Procedures

SD-43

Service Water System

Engineering

Changes

288259

Seismic Verification of Fire Protection Piping

05/18/2022

CSD-BNP-PFP-

0CB

Control Building Pre-Fire Plans

CSD-BNP-PFP-

0MBPA

Miscellaneous Buildings Pre-Fire Plans - Protected Area

Fire Plans

CSD-BNP-PFP-

0PBAA

Power Block Auxiliary Areas Pre-Fire Plans (SW, RW, AOG,

TY, EY, PDC, DGS, MCP)

0FPP-031

Fire Brigade Staffing Roster and Equipment Requirements

18-F-OS-01

Insulator Shop Fire Drill Scenario Guide

05/18/2022

Miscellaneous

21-F-SB-01

Service Building Air HVAC Room Fire Drill Scenario Guide

05/18/2022

0AOP-13.0

Operation During Hurricane, Flood Conditions, Tornado, or

Earthquake

0PFP-013

General Fire Plan

0PLP-01.2

Fire Protection System Operability, Action, and Surveillance

Requirements

71111.05

Procedures

AD-EG-ALL-1520

Transient Combustible Control

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CSD-BNP-PFP-

1RB

Reactor Building Prefire Plans

555550

Fire Protection Piping Seismic Support Documentation

05/17/2022

Corrective Action

Documents

AS 681677-05

Assignment Summary

07/29/2019

Corrective Action

Documents

Resulting from

Inspection

20537521

Work Order

05/19/2022

DBD-144

External and Internal Flooding Topical Design Basis

Document

Engineering

Evaluations

PS-FP-G008

Analysis to Seismically Qualify Select Fire Protection Pipe

Supports in the Diesel Generator Building

BNP-12-0104

Long Range Plan

05/18/2022

Miscellaneous

UFSAR section 3.4.2.2

Diesel Generator Building Internal Flooding Protection

20335906 02

BNP Man Hole Inspection AD-EG-ALL-1214

05/24/2021

20449286 02

(LR) FOUR YEAR MAN HOLE INSPECTION PER AD-EG-

BNP-1214

20449286 02

INSPECT MAN HOLE, DOCUMENT EGR-NGGC-0351

INSPECTION

71111.06

Work Orders

20449286 02

BNP Man Hole Inspection AD-EG-BNP-1214

10/11/2021

LORX-202

Simulator Guide - Recirculation Loop 'A' flow transmitter

failure, RBCCW high radiation, LOOP, Small Break LOCA

10b

Segment 22-1

Version A

LOCT examination 2022 Cycle 1

01/13/22

Miscellaneous

Segment 22-1

Version B

LOCT Examination 2022 Cycle 1

01/19/22

71111.11Q

Procedures

0GP-02

Approach to Criticality and Pressurization of the Reactor

28

AD-EG-ALL-1210

Maintenance Rule Program

AD-WC-ALL-

200

ON-LINE WORK MANAGMENT

71111.12

Procedures

AD-WC-ALL-

250

WORK IMPLEMENTATION AND COMPLETION

71111.13

Corrective Action

26363

Unit 2 MSIV Pit Steam Leak

05/09/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

0AP-025

BNP Integrated Scheduling

AD-OP-ALL-0201

Protected Equipment

AD-WC-ALL-

200

On-Line Work Management

AD-WC-ALL-

250

Work Implementation and Completion

Procedures

AD-WC-ALL-

0410

Work Activity Integrated Risk Management

Work Orders

225913

2-MS-F038D-MO, Backseat Valve Potential MSIV Pit Steam

Leak

05/10/2022

Calculations

0HPCI-0011

HPCI RESPONSE TIME REQUIREMENT

2

Action Request:

2414157

2-B32-F031B Actuator Rating Exceeded

01/31/2022

Corrective Action

Documents

Action Request:

2417296

RHR Valve Weight Analysis Discrepancy

2/23/2022

226189

Work Request to drive repairs noted during inspection of the

Unit 1 South Core Spray Room EL -17'

05/12/2022

Corrective Action

Documents

Resulting from

Inspection

27216

1-RB1-BLG-EL-17-1 Cosmetic Defect on Unit 1 SCE

Concrete Columns

05/12/2022

27-F-02501

Unit 1 Reactor Building Plan Below Grade EL (-) 17' - 0"

General Arrangement

Drawings

F-01230

Unit 2 Reactor Building Concrete Plan EL 20' - 0" - West

A/R 02423550

50.59 Screen to Extend HPCI Response Time

Rev 00

Engineering

Evaluations

A/R 02423553

CFR 50.59 Evaluation to extend HPCI response time

Rev 00

2305749

Repair Cosmetic Defect Void in Unit 2 Drywell Exterior Wall

05/12/2022

Operability

Evaluations

AD-OP-ALL-0105

OPERABILITY DETERMINATIONS

0SPP-CEM500

Installation of Concrete and Grout

71111.15

Procedures

AD-OP-ALL-0105

Operability Determinations

EC 417875

50.59 Screen for EC 417875

Rev 00

Engineering

Changes

EC 417875

CB HVAC Condensing Unit 1D Replacement

Rev 015

71111.18

Engineering

Evaluations

A/R 2391929

50.59 Screen for EC 417875

Rev 00

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

PD-EG-ALL-1130

Engineering Change Program

Rev 1

Corrective Action

Documents

Resulting from

Inspection

26126

1-E41-V6 Flow Inst Connection Spraying Leak

05/05/2022

0PLP-20

Post-Maintenance Testing Program

0PM-STR500

R.P. Adams Self-Cleaning Strainers, Model VWS 10 through

Procedures

0PT-09.2

HPCI System Operability Test

153

20304709

1-E41-FIC-R600, Replace Controller, HPCI Turb Flo Ind

Controller

05/03/2022

20372477

2B SBGT Drain Line Repairs

05/16/2022

20377862

Recoat 1A SBGT Drain Line Piping

05/20/2022

20399034,

20412939

2B CSW Strainer maintenance

05/20/2022

71111.19

Work Orders

20525661-06

Unit 2 HPCI Servo Replacement

3/12/22

0GP-02

Approach to Criticality and Pressurization of the Reactor

28

0GP-03

Unit Startup and Synchronization

71111.20

Procedures

0GP-04

Increasing Turbine Load to Rated Power

2

0OI-02.3

Drywell Leakage Control

0PT-08.2.2B

LPCI/RHR SYSTEM OPERABILTIY TEST - LOOP B

110

71111.22

Procedures

0PT-12.1A

No.1 Emergency Diesel Generator LOOP/LOCA Loading

Test

AD-EP-ALL-002

NRC Regulatory Assessment Performance Indicator

Guideline Emergency Preparedness Cornerstone

AD-EP-ALL-0101

Emergency Classification

71114.06

Procedures

CSD-EP-BNP-

0101-02

EAL Wallchart (Both Hot and Cold)

BNP-MECH-

MSPI

BNP Mitigating System Performance Index Plant Basis

Document

71151

Engineering

Evaluations

BNP-PSA-069

NRC Mitigating System Performance Index (MSPI) PRA

Input Document

71152A

Procedures

AD-PI-ALL-0100

Corrective Action Program

71152S

Procedures

AD-PI-ALL-0100

Corrective Action Program

14