IR 05000324/2020002

Integrated Inspection Report 05000324/2020002 and 05000325/2020002

ML20224A228
Person / Time
Site:	Brunswick
Issue date:	08/11/2020
From:	Stewart Bailey NRC/RGN-II/DRP/RPB4
To:	Krakuszeski J Duke Energy Progress
References
IR 2020002
Download: ML20224A228 (21)

Text

August 11, 2020

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2020002 AND 05000325/2020002

Dear Mr. Krakuszeski:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On August 3, 2020, 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Brunswick Steam Electric Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Brunswick Steam Electric Plant. 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,

/RA/

Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket Nos. 05000325 and 05000324 License Nos. DPR-71 and DPR-62

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000325 and 05000324

License Numbers:

DPR-71 and DPR-62

Report Numbers:

05000325/2020002 and 05000324/2020002

Licensee:

Duke Energy Progress, LLC

Facility:

Brunswick Steam Electric Plant

Location:

Southport, NC

Inspection Dates:

April 01, 2020 to June 30, 2020

Inspectors:

G. Smith, Senior Resident Inspector

J. Steward, Resident Inspector

J. Diaz-Velez, Senior Health Physicist

B. Kellner, Senior Health Physicist

Approved By:

Stewart N. Bailey, 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

Inadequate Plant Procedure Leads to the Unexpected Opening of all Main Steam Bypass Valves Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000325/2020002-01 Open/Closed

[H.1] -

Resources 71153 A self-revealing Green non-cited violation (NCV) was identified for the licensees failure to maintain adequate procedural guidance related to establishment of the desired reactor coolant system (RCS) pressure set-point in the turbine control system (TCS). The procedural flaw resulted in an inappropriate RCS pressure set-point that resulted in a plant transient caused by the unanticipated opening of all steam bypass valves as well as a subsequent depressurization of the RCS. The operators responded by inserting a manual reactor scram, closing the main steam isolation valves (MSIVs), and stabilizing the RCS in Mode 3.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000325/2020-001-00 Manual Reactor Scram During Startup due to all Bypass Valves Fully Opening 71153 Closed LER 05000325/2019-003-00 False High Reactor Water Level Results in Automatic Specified System Actuations.

71153 Closed

PLANT STATUS

Unit 1 began the inspection period at 96 percent rated thermal power (RTP) following a refueling outage completed in the first quarter. Following two rod improvements on April 2 and April 3, the unit was restored to 100 percent RTP on April 4. On April 8, the unit was reduced in power to approximately 50 percent RTP in order to perform power suppression testing. This testing was necessary to deduce the location of a potential fuel leak discovered as a result of routine chemistry sampling. Following completion of power suppression testing, the unit began a slow power ascension. 100 percent RTP was achieved on April 21 and the unit continued to operate at that power level until June 13, when the unit was shut down for a mid-cycle outage in order to locate and discharge the potential failed fuel assemblies discovered during the power suppression testing. Following fuel sipping activities, the licensee noted one definitively failed assembly and ultimately discharged eight total assemblies from the core into the spent fuel pool.

The licensee then took the reactor critical on June 21, closed the generator output breaker on June 22, and began a slow power ascension. The unit reached 95 percent RTP on June 28, where power was maintained due to an exhausted condensate demineralizer. The unit ended the period at 95 percent RTP.

Unit 2 began the period at 100 percent RTP and operated there until May 29, when power was reduced to 70 percent RTP for a control rod sequence exchange, control rod drive maintenance, condenser maintenance, and turbine valve testing. Following completion of these activities, the unit was restored to 100 percent RTP on May 31, where it continued to operate until the end 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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

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 a local weather disturbance on April 30, 2020. Additionally, the inspectors also evaluated the licensee's preparation for an impending severe weather condition caused by Tropical Storm Arthur on May 11, 2020.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) Unit 1 reactor building closed cooling water system following completion of the Unit 1 March refueling outage on April 2, 2020

(2) Unit 1 and Unit 2 cable spreading room ventilation system while 2E condensing unit was out-of-service (OOS) for annual maintenance om April 23, 2020

(3) Unit 1 and Unit 2 nuclear service water (NSW) and conventional service water (CSW)systems while Unit 2 'A' NSW pump was OOS for planned maintenance on May 4, 2020

(4) Unit 1 B core spray (CS) train while A CS train OOS for planned maintenance on May 26, 2020

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

(1) On April 16, 2020, the inspectors completed an evaluation of system configuration during a complete walkdown of the safety-related standby liquid control (SLC)system.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 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 1 reactor building (RB) 20 and 9 elevation (EL), (NE RHR heat exchanger, 1PFP-RB1-01E and SE RHR heat exchanger, 1PFP-RB1-01F) on April 2, 2020

(2) Unit 2 RB 80 EL (East, 2PFP-RB2-01K and West, 2PFP-RB2-01J) on April 8, 2020

(3) Emergency diesel generator (EDG) building 23 EL on April 13, 2020

(4) Unit 1 RB 80 EL (East, 1PFP-RB1-01K and West, 1PFP-RB1-01J) on April 16, 2020

(5) EDG building 50 EL on April 20, 2020

(6) EDG fuel storage tank underground enclosure on May 18, 2020

(7) Radioactive waste building, 23 EL, (0PFP-RW-01B) on May 21, 2020

(8) Transmission yard and relay house on May 28, 2020.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

On June 8, 2020, the inspectors completed an evaluation of the internal flooding mitigation protections in the:

(1) Unit 1 reactor building

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

On June 30, 2020, the inspectors completed an evaluation of the readiness and performance of:

(1) EDG-2 jacket water heat exchanger

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 power suppression testing to determine the location of a fuel assembly leak on April 8, 2020

• Pressurization of the Unit 1 reactor coolant system on June 22, 2020

• Testing related to the cycling of D outboard MSIV switch to re-energize the associated DC solenoid on June 22, 2020

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed operator simulator exercise on May 28, 2020. The scenario involved a loss of suppression pool cooling followed by a loss of Bus E4, small break loss-of coolant accident (LOCA) and emergency depressurization.

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)1F safety relief valve (SRV) main and pilot valve replacement under work order (WO) 20390561

(2) EDG-2 maintenance outage completed on June 5, 2020.

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 spent fuel time to boil less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> on April 27, 2020

(2) Emergent failure of SLC pump discharge relief on June 1, 2020

(3) Emergent failure of main steam line 'D' temperature instrument that resulted in a half group one isolation on June 3, 2020

(4) Elevated risk due to a EDG-2 maintenance outage. The outage performed various activities including the 24-month preventative maintenance tasks, and was completed on June 4, 2020

(5) Elevated risk due to a Unit 2 high pressure coolant injection (HPCI) outage completed on June 8, 2020

71111.15 - Operability Determinations and Functionality Assessments

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

On June 30, 2020, the inspectors completed an evaluation of the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Mathematical model for [motor-operated valve] MOV qualified life is non-conservative (NCR 2318490).

(2) B1C23 power plex basedeck error identified during start-up (NCR 2322744)

(3) Unit 2 EDG-2 VR-1B auxiliary relay failed preventing closure of DG output breaker (NCR 2308597)

(4) Unit 1 RCS fuel leak (NCR 2323829)

(5) Unit 2 HPCI legacy debris found during drain valve flush (NCR 2334099)

(6) EDG-3 trip logic relay time longer than expected (NCR 2323829)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

On June 30, 2020, the inspectors completed an evaluation of the following temporary or permanent modifications:

(1) Unit 1 alternate decay heat removal system (EC 277991 - primary loop and EC

===276939 - secondary loop)

(2) Unit 2 alternate decay heat removal system (EC 277583 - primary loop and EC 276247 - secondary loop)

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01)===

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) PMT on 1-E21-F004A, core spray outboard injection valve in accordance with (IAW)

WO 20295081 and WO 20248177

(2) PMT for replacement of 1-C41-F029B, SLC pump discharge relief valve IAW WO

===20256696 (3)2-VA-A-SF-DG feed circuit breaker PMT IAW WO 20133016 (4)1-SW-684, EDG-2 Unit 1 SW check valve inspection during EDG-2 maintenance outage IAW WO 20298425 (5)2-SW-684, EDG-2 Unit 2 SW check valve inspection during EDG-2 maintenance outage IAW WO 20298424

(6) PMT on EDG-2 fuel injectors and starting air valves, following 24 month maintenance IAW WOs 20208924 and 20298259

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated the unit 1 mid cycle outage that was conducted from June 13 to June 22, 2020, to locate and discharge failed fuel assemblies noted during power suppression testing conducted on April 10, 2020.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Unit 1 power suppression testing (on April 8, 2020

(2) Unit 1 EDG-2 LOOP/LOCA loading testing on April 10, 2020

71114.06 - Drill Evaluation

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

The inspectors evaluated:

(1) Licensed operator requalification simulator training observation scenario that involved a loss of suppression pool cooling followed by a loss of Bus E4, small break LOCA and emergency depressurization on May 28,

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (4 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) Unit 1, turbine building ventilation system

(2) Unit 2, turbine building ventilation system

(3) Liquid radioactive waste discharge system (common)

(4) Main stack wide range noble gas monitor

Sampling and Analysis (IP Section 03.02) (3 Samples)

(1) Radioactive Effluent Release, Liquid Release Permit L-2020-0099, Unit 1 Salt Water Release Tank (SWRT), 06/14/2020

(2) Radioactive Effluent Release, Gaseous Release Permit G-2020-0180, Main Vent Stack, 06/16/2020

(3) Eckert &Ziegler Analytics Inter Laboratory Cross Check Program Results, 1st and 2nd Quarter 2020, 22 May 2020

Dose Calculations (IP Section 03.03) (3 Samples)

The inspectors evaluated the following dose calculations:

(1) Main Stack Post-Release Cumulative Dose Calculation, Gaseous Release Permit, Turbine Building Vent, 05/19/2020

(2) Liquid Release Post-Release Cumulative Dose Calculation Liquid Release Permit L-2020-0089, Unit 2 Salt Water Release Tank (SWRT), 05/22/2020

(3) Annual Radiological Effluent Release Reports:

• Brunswick Steam Electric Plant Units 1 and 2, Annual Radioactive Effluent Release Reports, 2018 and 2019

Abnormal Discharges (IP Section 03.04) (1 Sample)

(1) No abnormal discharges occurred during the inspection period therefore, none were available for review.

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

GPI Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative Program to identify incomplete or discontinued program elements.

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, 2019 - March 31, 2020)

(2) Unit 2 (April 1, 2019 - March 31, 2020)

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

(1) Unit 1 (April 1, 2019 - March 31, 2020)

(2) Unit 2 (April 1, 2019 - March 31, 2020)

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

(1) Unit 1 (April 1, 2019 - March 31, 2020)

(2) Unit 2 (April 1, 2019 - March 31, 2020)

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) April 1, 2019 to April 30, 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) On June 30, 2020, the inspectors completed a review of the licensees corrective action program. This review focused on identifying any trends that might be indicative of a more significant safety issue. The inspectors did note an observation that is documented in the results section of this report.

71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

On June 30, 2020, the inspectors completed an evaluation the following licensee event reports (LERs):

(1) LER 05000325/2019-003-00, False High Reactor Water Level Results in Automatic Specified System Actuations (ADAMS Accession No. ML19170A398). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements. This item is closed.

(2) LER 05000325/2020-001-00, Manual Reactor Scram During Startup Due to all Bypass Valves Fully Opening (ADAMS Accession No. ML20141L763). The inspection conclusions associated with this LER are documented as NCV 05000325/2020002-01 in this report under Inspection Results under Section 71153.

This item is closed.

INSPECTION RESULTS

Observation: Semi-Annual Trend Review 71152 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 2020 through June 2020, 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.

The inspectors noted the continuation of a negative trend with respect to reactor fuel performance. This trend was originally documented in inspection report 05000325,324/2019002. Specifically, the condition reports (CRs) below noted four separate fuel leaks for four separate fuel cycles encompassing both Unit 1 and Unit 2. The most recent Unit 1 fuel leak noted in this inspection report provided evidence of a continuation of this trend. Fuels leaks typically drive the licensee to suppress the affected fuel assembly by inserting the closest control rod. The flux suppression also limits rates of power increase and increases the number of rod programming changes. The inspectors discussed this negative trend with the licensee. The inspectors noted that the licensee has continued to address this negative trend and has sufficiently engaged the fuel manufacturer in order to more fully understand this phenomenon.

• CR 2078244 (Unit 1, 2016)

• CR 2176522 (Unit 2, 2018)

• CR 2276790 (Unit 1, 2019)

• CR 2323829 (Unit 1, 2020)

Inadequate Plant Procedure Leads to the Unexpected Opening of all Main Steam Bypass Valves Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events

Green NCV 05000325/2020002-01 Open/Closed

[H.1] -

Resources 71153 A self-revealing Green non-cited violation (NCV) was identified for the licensees failure to maintain adequate procedural guidance related to establishment of the desired RCS pressure set-point in the turbine control system (TCS). The procedural flaw resulted in an inappropriate RCS pressure set-point that resulted in a plant transient caused by the unanticipated opening of all steam bypass valves as well as a subsequent depressurization of the RCS. The operators responded by inserting a manual reactor scram, closing the main steam isolation valves (MSIVs), and stabilizing the RCS in Mode 3.

Description:

On March 22, the Unit 1 operators were in the process of bringing Unit 1 back on line following the B1R23 refueling outage. Reactor power was being maintained at 2 percent RTP. At 1229, while establishing main condenser vacuum, the operators noted that all four main steam bypass valves unexpectedly opened. Initially, the operators believed the bypass valves' operation to be a spurious opening, as the actual RCS pressure was at approximately 90 psi while the RCS pressure set-point was believed to be set to 100 psi. The operators attempted to close the bypass valves but were unsuccessful. Due to the uncontrolled depressurization of the RCS and uncontrolled positive reactivity addition, the operators inserted a manual reactor scram. The operators then stabilized the plant in Mode 3 by closing all four MSIVs to arrest the RCS depressurization.

Subsequent investigation revealed the RCS pressure set-point was mistakenly set to one psi instead of 100 psi while executing plant startup procedure, 0GP-01, "Prestartup Checklist."

which was previously performed a few days earlier. This error was not caught during subsequent startup activities. The bypass valves receive a control signal from the TCS to maintain RCS pressure at the desired set-point. They provide a path for main steam to be directly dumped to the main condenser to maintain RPS steam pressure at the desired value. Since the bypass valves have a corresponding low vacuum interlock due to their association with the main condenser, they would have been prevented from opening due to the lack of vacuum in the main condenser, regardless of the deviation from the pressure set-point. However, once vacuum was established by the operators, the low vacuum interlock cleared and the bypass valves responded by opening to lower RCS pressure from 90 psi down to one psi.

The licensee performed a detailed root cause analysis of this event in order to develop a definitive root cause and uncover any latent organizational weaknesses. The licensee ultimately concluded that the procedural guidance for the operator in setting the RCS pressure set-point was less than adequate. The procedural step 6.2.1.a of 0GP-01 simply stated "Adjust pressure set to 100 psi." The investigators noted that procedure, 1OP-25, "Main Steam System Operating Procedure," step 6.3.8 had detailed guidance that included nine individual steps to accomplish the same task of adjusting the RCS pressure set-point.

The step in 0GP-01 essentially relied on the operator's "skill-of-the-craft" knowledge.

Additionally, the licensee noted a lack of operator proficiency in adjusting the TCS set-point as well as lack of intrusive oversight by supervision.

Corrective Actions: The licensee modified plant procedures to provide clear and consistent guidance for adjusting the RCS pressure set-point within the TCS.

Corrective Action References: CR 2321700

Performance Assessment:

Performance Deficiency: The licensees failure to develop detailed guidance to properly enter the RCS pressure set-point into the TCS during plant startup was a performance deficiency (PD). This PD coupled with a lack of operator proficiency led to the improper set-point and ultimately unexpected opening of all steam bypass valves with the reactor critical in Mode 2.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure indirectly resulted in a reactor trip transient.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Manual Chapter 0609, Significance Determination Process (SDP), Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The SDP process for Findings At-Power. Specifically, using Attachment 0609.04, the finding was determined to adversely affect the Initiating Events cornerstone since the finding was related to a manual reactor trip and thus was a transient initiator contributor. Using Table 3 of 0609.04, the finding was required to be further evaluated using Appendix A since the finding was related to initiating events and was not related to shutdown operations, licensed operator requalification, maintenance rule risk assessments, fire protection, etc.

Using Appendix A (Exhibit 1), the finding was determined to be of very low safety significance (Green) because the finding was not related to a Loss Of Coolant Accident (LOCA), support system, steam generator tube rupture, or external events initiators. Although the finding did result a reactor trip, it did not cause or result in the loss of mitigation equipment relied upon to place the plant in a stable shutdown condition. Additionally, the manual reactor trip occurred from 2 percent RTP and thus did not challenge any thermal limits or maximum licensed thermal power.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. This finding has a cross-cutting aspect in the resources component of human performance (H.1)because the organization did not provide the operations personnel with an adequate and detailed procedure in order to accurately enter the RCS pressure set-point into the TCS.

Enforcement:

Violation: Technical Specification 5.4.1a, Procedures, states that written procedures shall be established, implemented, and maintained covering the following activities: a) the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972 (Safety Guide 33, November 1972). Regulatory Guide 1.33, Section 4, states in part that procedures should be prepared for the startup, operation, and shutdown of safety-related BWR systems including the turbine generator system as well as the main steam system (reactor vessel to turbine).

Contrary to the above, from March 2018 to March 2020, the licensee failed to maintain procedure 0GP-01, "Prestartup Checklist," such that adequate guidance was provided to the operator to enter the required RCS pressure set-point into the TCS. This culminated on March 22, 2020, when the RCS pressure set-point was improperly entered into the TCS by the control room operator and resulted in the unexpected opening of all four steam bypass valves which resulted in an uncontrolled depressurization of the RCS and a follow-on manual reactor scram.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

The disposition of this violation closes LER 05000325/2020-001-00, Manual Reactor Scram During Startup Due to all Bypass Valves Fully Opening.

EXIT MEETINGS AND DEBRIEFS

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

• On August 3, 2020, the inspectors presented the integrated inspection results to John Krakuszeski and other members of the licensee staff.

• On June 24, 2020, the inspectors presented the radiation safety inspection results to Jerry Johnson, Chemistry Superintendent, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Miscellaneous

DBD-144

External and Internal Flooding

Procedures

0AI-68

Brunswick Nuclear Plant Response to Severe Weather

Warnings

0AOP-13.0

Operation during Hurricane, Flood Condition, Tornado, or

Earthquake

71111.04

Drawings

D-02547

Reactor Building Standby Liquid Control System Piping

Diagram

D-25038, sheet 2

Reactor Building Closed Cooling Water System Piping

Diagram

D-25038, sheet 3

Reactor Building Closed Cooling Water System Piping

Diagram

F-04080

Control Building Air Flow Diagram

Miscellaneous

SD-37

Control Building Heating, Ventilation and Air Conditioning

System

Updated FSAR Section 9.3.4

Standby Liquid Control System

Procedures

0OP-37

Control Building Ventilation System Operating Procedure

1OP-05

Standby Liquid Control System

1OP-18

Core Spray System Operating Procedure

1OP-21

Reactor Building Closed Cooling Water System Operating

Procedure

1OP-43

Service Water System Operating Procedure

135

2OP-05

Standby Liquid Control System

2OP-43

Service Water System Operating Procedure

168

SD-43

Service Water System

71111.05

Fire Plans

0PFP-013

General Fire Plan

AD-EG-ALL-1532

NFPA 805 Pre-Fire Plans

CSD-BNP-PFP-

0DG

Diesel Generator Building Prefire Plans

CSD-BNP-PFP-

0MBOCA

Miscellaneous Buildings - Owner Controlled Area

CSD-BNP-PFP-

Power Block Auxiliary Areas Pre-fire Plans

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

0PBAA

CSD-BNP-PFP-

1RB

Reactor Building Pre-fire Plans

CSD-BNP-PFP-

2RB

Reactor Building Pre-fire Plans

Procedures

0PLP-01.2

Fire Protection System Operability, Action, and Surveillance

Requirements

AD-EG-ALL-1520

Transient Combustion Control

71111.07A

Procedures

0ENDP-2704

Administrative Control of NRC Generic Letter 89-13

Requirements

71111.11Q Miscellaneous

0ENP-24.21

Fuel Integrity Monitoring

LORX-019

Suppression Pool Cooling with RHR Pump Trip, Loss of

Turbine Building Cooling Water, Loss of Buses 2C and E4,

Small Break LOCA and Emergency Depressurization

Procedures

0GP-12

Power Changes

71111.12

Corrective Action

Documents

21942

1F SRV Main and Pilot Valve Replacement

03/24/2020

71111.13

Procedures

0MST-DG500R

Emergency Diesel Generators 24 Month Inspection

AD-OP-ALL-0201

Protected Equipment

71111.15

Corrective Action

Documents

2308597

Unit 2 EDG-2 VR-1B Auxiliary Relay failed preventing

closure of DG Output Breaker

6/30/2020

29223

EDG-3 Trip Relay Time longer than expected

5/7/2020

2334099

Unit 2 HPCI Legacy Debris Found During Drain Valve Flush

6/29/2020

71111.19

Procedures

0PM-BKR003

Preventive Maintenance of General Electric 480VAC Motor

Control Center Compartments

0PT-06.1

Standby Liquid Control System Operability Test

0PT-07.2.4A

Core Spray System Operability Test - Loop A

0PT-11.1.2

Automatic Depressurization System and Safety Relief Valve

Operability Test

71111.22

Procedures

0PT-12,1B

No. 2 Diesel Generator Loop/Loca Loading Test

71124.06

Calculations

Part 61 Analysis

2018 DAW Smears Part 61

11/07/2018

Miscellaneous

List of Effluent Monitors Not In Service > 1 Day Since June

2018 (compensatory sampling required)

05/27/2020

Excel Spreadsheet, Radwaste System Tank and Vessel

06/09/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Inspection Schedule

2018 Annual

XOQDOQ

Modeling and

Meteorological

Evaluation for

Brunswick

Nuclear Station

Memorandum, From: Stanton Lanham, Meteorology, FSO,

To: Bradley Bagwell, Brunswick Nuclear Station

03/06/2019

2019 Annual

XOQDOQ

Modeling and

Meteorological

Evaluation for

Brunswick

Nuclear Plant

Memorandum, From: Stanton Lanham, Meteorology (FSO),

To: Bradley Bagwell, Brunswick Nuclear Station

04/03/2020

Adverse

Condition

Monitoring and

Contingency

Planning (ACMP)

Unit 1 Operation with Failed Fuel (Rev 0.)

04/06/2020

Self-Assessments 02313553

20 Radioactive Effluents / REMP Assessment

05/29/2020

20-BNP-

RPCH-01

Nuclear Oversight Audit - BNP Radiation and Chemistry

06/04/2020

71124.07

Calculations

2018 Land Use

Census

Spreadsheet

Dose Calculations

(Reprinted)

ODCM calculations for identified changes in 2018 Land Use

Census data.

05/03/2020

2019 Land Use

Census

Spreadsheet

Dose Calculations

(Reprinted)

ODCM calculations for identified changes in 2019 Land Use

Census data.

04/22/2020

Calibration

0E&RC-3107

Calibration and Use of Environmental Air Samplers (BNP-1,

05/11/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Records

BNP-2, BNP-3, BNP-4, BNP-5, BNP-6, BNP-10, and BNP-

2)

Corrective Action

Documents

ARs 02325175,

250000,

228049,

232796,

2325643,

258317,

289000,

236457,

259274,

289196,

238598

Corrective Action Reports

Miscellaneous

2018 Land Use

and Garden

Census Results

2018 Land Use and Garden Census Results

06/16/2018

2019 Land Use

and Garden

Census Results

2019 Land Use and Garden Census Results

06/20/2019

RA-19-0130

Annual Radioactive Effluent Release Report - 2018

04/25/2019

RA-19-0140

Annual Radiological Environmental Operating Report - 2018

05/13/2019

RA-20-0078

Annual Radioactive Effluent Release Report - 2019

04/28/2020

RA-20-0079

Annual Radiological Environmental Operating Report - 2019

04/28/2020

Procedures

0#&RC-3297

Groundwater Extraction Well System Operation and

Maintenance

Rev. 7

0E&RC-3101

Radiological Environmental Monitoring Program

Rev. 39

0E&RC-3104

Land Use Census

Rev. 12

0E&RC-3107

Calibration and Use of Environmental Air Samplers

Rev. 8

0E&RC-3250

Groundwater Monitoring Program

Rev. 43

0E&RC-3252

Operation and Maintenance of the Groundwater

Management System

Rev. 6

0E&RC-3298

Groundwater Extraction Compressed Air System

Rev. 8

0E&RC-3299

Groundwater Extraction Wet Well System

Rev. 4

0PM-MET001

Meteorology Tower Equipment Calibration and Function

Rev. 8

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Test

AD-CP-ALL-0014

Land Use Census Evaluation

Rev. 2

AD-CP-ALL-0017

Radiological Groundwater Protection

Rev. 3

AD-OP-ALL-0101

Event Response and Notifications

Rev. 12

ENRAD

Procedure 206

Calibration of Tennelec Series 5 Low Background Counting

Instruments Using Eclipse Software

Rev. 12

Work Orders

281025-02

Perform 0PM-MET001 on the Met. Tower

10/26/2019

284015-01

0-GWM-TNK-PMP-1: Replace Pump and Clean Tank/Piping

09/17/2019

20438046-02

Perform 0PM-MET001 on the Met. Tower

2/12/2020

71151

Calculations

G-2020-0158

Radioactive Effluent Gaseous Release Permit, Unit 2

Turbine Building

05/21/2020

G-2020-0180

Radioactive Effluent Gaseous Release Permit, Main Plant

Vent Stack

06/24/2020

L-2020-0099

Radioactive Effluent Liquid Release Permit, Unit 1 Salt

Water Release Tank

06/14/2019

Corrective Action

Documents

ARs 02283027,

2325175

Corrective Action Report

Procedures

AD-PIALL-0700

Performance Indicators

Rev. 4

AD-RP-ALL-1101

Performance Indicators (PI) for the Occupational and Public

Radiation Safety Cornerstones

Rev. 0