IR 05000324/2019011: Difference between revisions

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{{Adams
{{Adams
| number = ML19120A430
| number = ML19289B887
| issue date = 04/30/2019
| issue date = 10/16/2019
| title = Notification of Brunswick Steam Electric Plant Design Bases Assurance Inspection (Team) - U.S. Nuclear Regulatory Commission Inspection Report 05000325/2019011 and 05000324/2019011
| title = Design Basis Assurance Inspection (Teams) Inspection Report 05000324/2019011 and 05000325/2019011
| author name = Montgomery J
| author name = Baptist J
| author affiliation = NRC/RGN-II/DRS/EB1
| author affiliation = NRC/RGN-II
| addressee name = Gideon W R
| addressee name = Krakuszeski J
| addressee affiliation = Duke Energy Progress, LLC
| addressee affiliation = Duke Energy Progress, LLC
| docket = 05000324, 05000325
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| license number = DPR-062, DPR-071
| contact person =  
| contact person = Archer L
| document report number = IR 2019011
| document report number = IR 2019011
| document type = Letter
| document type = Inspection Report, Letter
| page count = 5
| page count = 21
}}
}}


Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:**
{{#Wiki_filter:October 16, 2019


/RA/  
==SUBJECT:==
BRUNSWICK STEAM ELECTRIC PLANT - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000324/2019011 AND 05000325/2019011


excluding including
==Dear Mr. Krakuszeski:==
On September 13, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
 
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
 
If you contest the violations or significance or severity of the violations 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.
 
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. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
 
Sincerely,
/RA/
 
James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety
 
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:
05000324/2019011 and 05000325/2019011
 
Enterprise Identifier: I-2019-011-0007
 
Licensee:
Duke Energy Progress, LLC
 
Facility:
Brunswick Steam Electric Plant
 
Location:
Southport, NC
 
Inspection Dates:
August 19, 2019 to September 13, 2019
 
Inspectors:
C. Franklin, Reactor Inspector
 
J. Montgomery, Senior Reactor Inspector
 
G. Ottenberg, Senior Reactor Inspector
 
M. Riley, Reactor Inspector
 
C. Baron, Mechanical Contractor
 
G. Nicely, Electrical Contractor
 
Approved By:
James B. Baptist, Chief
Engineering Branch 1
Division of Reactor Safety
 
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) 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===
Failure to Properly Size and Evaluate the Acceptability of MOV Thermal Overloads Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000324,05000325/2019011-01 Closed None (NPP)71111.21M The team identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion III, "Design Control," for the licensee's failure to translate design basis MOV requirements into sufficient procedural guidance to size and evaluate motor-operated valve (MOV) thermal overloads (TOLs) properly. Specifically, the licensee's procedure for sizing and evaluating TOLs, EGR-NGGC-0106, AC and DC Overcurrent Protection and Coordination Revision 5, did not incorporate guidance to properly size or evaluate the MOV TOLs during all design basis conditions.
 
Failure to Follow Calculation Control Process Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000324,05000325/2019011-02 Closed
[H.3] - Change Management 71111.21M The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion V,
"Instructions, Procedures and Drawings," for the licensee's failure to follow their AD-EG-ALL-1117, Design Analyses and Calculations, procedure. Specifically, procedure AD-EG-ALL-1117, section 4.2, required the verifier to identify that the design inputs were accurate and complete, however, the licensee did not identify all design inputs for calculations 0BNP-TR-006, "MOV Design Basis Information GL89-10 & GL 96-05," and BNP-E-8.013/BNP-E-8.014,
"Motor Torque Analysis for AC MOVs." As a result, the licensee failed to update the affected calculations following motor-operated valve (MOV) testing or maintenance, the results of which could change the results of the calculations.
 
===Additional Tracking Items===
None.
 
=INSPECTION SCOPES=
 
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
 
==REACTOR SAFETY==
===71111.21M - Design Bases Assurance Inspection (Teams)
 
The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
 
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (4 Samples)
: (1) E4 Bus - Division II Emergency Switchgear
* Material condition and configuration review performed during a visual non-intrusive inspection to assess material condition, the presence of hazards, and consistency of installed equipment with design documentation and analyses
* Normal, abnormal, and emergency operating procedures
* Breaker Maintenance effectiveness; Procedures for preventive maintenance, inspection, and testing to compare maintenance practices against industry and vendor guidance
* Component health reports, corrective maintenance records, and corrective action history
* Coordination and interface with the transmission system operator for plant voltage requirements and notification set points
* Electrical calculations:(Load flow, bus loading and voltage drop, Degraded and loss of voltage protection, Protective relay and breaker settings and coordination, Short circuit and breaker duty analysis)
: (2) Motor-Operated Valve (MOV) 2-E11-F007B - RHR Minimum Flow Bypass Valve to the Suppression Pool (Electrical Interfaces)
* Calculations: (Motor Torque Determination, MOV Protection Thermal Overload Sizing and Evaluations, MOV motive and control power, available torque calculations)
* Adherence to vendor and industry maintenance and technical updates
* Material condition and configuration review performed during a visual non-intrusive inspection to assess material condition, the presence of hazards, and consistency of installed equipment with design documentation and analyses
: (3) Unit 2 125V DC Distribution Panel 4-B
* Material condition and configuration reviewed performed during a visual non-intrusive inspection to assess material condition, the presence of hazards, and consistency of installed equipment with design documentation and analyses
* Procedures for maintenance and testing of breakers to compare practices against industry guidance
* Component health reports and corrective action history
* Calculations: (Bus loading and voltage drop, short circuit analysis, breaker coordination study)
* Surveillance testing of battery power supply attributes inspected (e.g.,
maximum available fault current)
: (4) Unit 1 Reactor Core Isolation Cooling (RCIC) Pump, E51-C001
* Material condition and installed configuration (e.g., visual inspection/walkdown)
* Normal, abnormal, and emergency operating procedures
* Consistency among design and licensing bases and other documents/procedures
* System health report, maintenance effectiveness and records, and corrective action history
* Equipment/environmental controls and qualification
* Design calculations
* Surveillance testing and recent test results
* System and component level performance monitoring
* Equipment protection from fire, flood, and water intrusion or spray
* Heat removal cooling water and ventilation
 
Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02)===
{{IP sample|IP=IP 71111.21|count=1}}
: (1) Unit 1 Air-Operated Valve (AOV) 1-CAC-V216 - Hardened Wetwell Vent Line Isolation Valve
* Material condition and configuration review performed during a visual non-intrusive inspection to assess material condition, the presence of hazards, and consistency of installed equipment with design documentation and analyses
* Normal, abnormal and emergency operating procedures
* Maintenance effectiveness; Procedures for preventive maintenance, inspection, and testing to compare maintenance practices against industry and vendor guidance.
* Component health reports, corrective maintenance records, and corrective action history
* Calculations: (actuator output capability and margins, air supply and control power, required design basis capability, uncertainty assumptions)
 
===Modification Review - Permanent Mods (IP Section 02.03) (4 Samples)===
: (1) EC 406293, Evaluation of Instrument Uncertainty Calculations not for Limiting Safety System Settings or Automatic Protective Functions
: (2) EC 298197, Acceptability of Shaft to Bowl Bearing Clearance and Impeller Wear Ring Clearance for 2C CSW PUMP 2-SW-2C-CONV-PMP
: (3) EC 412996, Replace the 1-E11-F048B-MO (1B RHR HX BYPASS VLV) with an Aluminum Rotor Motor
: (4) EC 407321, Evaluation Of DC Load Profile And Battery Voltages Following The Restoration Of DC Battery Chargers To The DC System During A DBA (LOOP/LOCA)
 
===Review of Operating Experience Issues (IP Section 02.06) (2 Samples)===
: (1) NRC Regulatory Issue Summary (RIS) 2011-12, Rev. 1, Adequacy of Station Electric Distribution System Voltages
: (2) NRC Information Notice 2013-17, Significant Plant Transient Induced by Safety-Related Direct Current Bus Maintenance at Power
 
==INSPECTION RESULTS==
Failure to Properly Size and Evaluate the Acceptability of MOV Thermal Overloads Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
 
Green NCV 05000324,05000325/2019011-01 Closed
 
None (NPP)71111.21M The team identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion III, "Design Control," for the licensee's failure to translate design basis MOV requirements into sufficient procedural guidance to size and evaluate motor-operated valve (MOV) thermal overloads (TOLs) properly. Specifically, the licensee's procedure for sizing and evaluating TOLs, EGR-NGGC-0106, AC and DC Overcurrent Protection and Coordination Revision 5, did not incorporate guidance to properly size or evaluate the MOV TOLs during all design basis conditions.
 
=====Description:=====
TOLs are installed to protect MOV actuator motors from failure due to heating caused by prolonged exposure to high current. The TOLs trip to interrupt the current to the MOV motor, which prevents the valve from moving. In nuclear power plant applications, the criterion for establishing an MOV TOL trip set point should be for the valve to complete its safety function (e.g., drive the valve to its proper position to mitigate the effects of an accident) rather than to protect the motor from destructive heating. MOVs may be required to operate at the beginning of an accident when other large motors are also starting, which could result in bus voltage dropping low enough to stall the MOV until voltage recovers. If these voltage dips occur while power to the MOV is being supplied from the offsite power source, and voltage doesnt recover quickly (generally within 5 seconds), then the MOV may continue to stall until the degraded voltage protection system time delay relay (described in TS 3.3.8.1) actuates. This causes the plant to disconnect from the offsite power source, and switch to the emergency diesel generators. During this time, the stalled MOVs could be experiencing high currents and generating excessive heat within both the actuator motor and the TOL, which can cause the TOL to actuate and trip the power to the MOV if not sized adequately to operate through the event without tripping. Similarly, MOVs may also have a jogging or throttling requirement during the accident which requires multiple starts of its motor within a short period of time. These demands would add additional heat to the MOV motor and TOL, which can also cause the TOL to actuate and trip the power to the MOV.
 
The inspection team reviewed Attachment F, DVR and TOL Evaluation, of calculations BNP-E-8.013 and BNP-E-8.014, Motor Torque Analysis for AC Motor Operated Valves, to evaluate how the licensee confirmed that the MOV TOLs were sized appropriately for degraded grid voltage conditions concurrent with accident conditions. During the team's review of the calculations, the team discovered several errors in the calculation methodology that were non-conservative and required the licensee to re-evaluate them. The licensee captured these errors in their corrective action program as action requests (ARs) 2289038 and 2289996. Once the licensee corrected the errors in their calculation, the team discovered that the TOLs for nine MOVs had the potential to trip before the valves performed their safety function, if the MOV was taken out of its normal position and the MOV received an accident signal to reposition back to its normal safety-function position.
 
Upon discovering that the TOLs were undersized, the inspection team reviewed the procedural guidance in BNP Standard Procedure EGR-NGGC-0106, AC and DC Overcurrent Protection and Coordination, Revision 5, which the licensee used to size various electrical protective devices.
 
The team observed that section 9.3.14, Considerations for AC and DC Protective Device Selection, described that protective devices must be adequately sized for the operating scenarios under consideration, such as during starting of other loads simultaneously or during a degraded voltage condition where the inrush current of a starting motor may continue until the voltage recovers to the point at which the devices can operate. However, section 9.6, MOV Motor Circuit Protection, which the licensee used for sizing MOV TOLs specifically, did not reference or include the guidance described in subsection 9.3.14. Additionally, in section 9.6 there was no specific guidance for various scenarios required by the station MOVs design bases, including:
* Considering a sustained degraded grid voltage and its associated 11 second maximum time delay allowed by the degraded grid voltage relay setpoints required by TS 3.3.8.1,
* The allowances given in Generic Letter 89-10, Supplement 1, and utilized by the station MOV program to delay starting of MOVs for approximately 5 seconds during upstream motor starting which may result in stall conditions for that time,
* Sizing TOLs for MOVs that have a jogging/throttling function post-event.
* Establishing the trip setpoint of the TOLs with all uncertainties resolved in favor of completing the safety-related action, rather than protecting the motor.
 
Because of the inadequate procedural guidance, the team determined that calculation BNP-E-2.002, 480V AC Auxiliary Safety-related MOV Electrical Protection, Rev. 16, which sized the TOLs for MOVs, did not ensure that the safety function of the MOVs would be met, as it did not account for the different operating scenarios described above. Several of the TOLs were undersized in favor of providing protection for the MOV motor, rather than ensuring the safety function would be completed. NCR 2291385 was generated to evaluate the procedural adequacy.
 
Corrective Actions: The licensee entered the issue into their corrective action program and evaluated the MOVs' capability to respond to accident conditions due to being in their normal required position prior to the event. The licensee further initiated plans to improve the guidance in procedures for sizing and evaluating MOV TOLs.
 
Corrective Action References: NCRs 02289038 and 02291385 and NTM 2289996
 
=====Performance Assessment:=====
Performance Deficiency: The team determined the licensee's failure to translate design basis MOV requirements into sufficient procedural guidance in EGR-NGGC-0106 to size and evaluate the MOV TOLs properly was a performance deficiency.
 
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, nine MOVs were identified that had under-sized TOLs and had the potential to trip during an accident concurrent with a degraded voltage condition, and the improper TOL sizing challenges the capability of the MOVs during degraded grid voltage design conditions.
 
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors evaluated the finding in accordance with the NRC Inspection Manual Chapter (IMC) 0609, Attachment 4, "Initial Characterization of Findings," issued October 7, 2016, for Mitigating Systems, and IMC 0609, Appendix A, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because finding was a design deficiency and the affected SSCs maintained their operability. Specifically, the licensee justified the MOVs would be able to perform their safety function under predicted transient voltage conditions during a design basis accident, although they would be challenged under concurrent accident and degraded voltage scenarios.
 
Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
 
=====Enforcement:=====
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, required, in part that Measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, since at least the last revision to procedure EGR-NGGC-0106 in April 2016, the licensee did not assure that applicable regulatory requirements and the design bases were correctly translated into procedures. Specifically, procedure EGR-NGGC-0106 did not incorporate guidance to properly evaluate the MOV TOLs during design basis accidents concurrent with degraded grid voltage design conditions allowed by the setpoints in plant technical specifications for the degraded grid voltage relays or other different MOV operating scenarios required by the station MOVs design bases.
 
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
 
Failure to Follow Calculation Control Process Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
 
Green NCV 05000324,05000325/2019011-02 Closed
 
[H.3] - Change Management 71111.21M The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion V, "Instructions, Procedures and Drawings," for the licensee's failure to follow their AD-EG-ALL-1117, Design Analyses and Calculations, procedure. Specifically, procedure AD-EG-ALL-1117, section 4.2, required the verifier to identify that the design inputs were accurate and complete, however, the licensee did not identify all design inputs for calculations 0BNP-TR-006, "MOV Design Basis Information GL89-10 & GL 96-05," and BNP-E-8.013/BNP-E-8.014, "Motor Torque Analysis for AC MOVs." As a result, the licensee failed to update the affected calculations following motor-operated valve (MOV) testing or maintenance, the results of which could change the results of the calculations.
 
=====Description:=====
The purpose of calculations BNP-E-8.013 and BNP-E-8.014 was to calculate available MOV motor torque during extreme bus voltages, and the purpose of calculation 0BNP-TR-006 was to document design basis information for Generic Letter (GL) 89-10 and GL 96-05 MOVs. Additionally, each motor-operated valve (MOV) included in the licensee's MOV program has an associated calculation that determines the margin available to operate the MOV during design basis scenarios. The individual MOV margin calculations get updated occasionally following Periodic Verification Testing (PVT) if the results of the testing indicate a change in a parameter that led to an increase or decrease in the calculated margin for the MOV. The margin calculations compare available MOV output thrust/torque to the thrust/torque required to make the valve change position. The determination of available thrust/torque is dependent on the voltage of the electrical source supplying power to the MOV motor; the determination of the required thrust/torque is dependent on mechanical properties of the valve and piping system including various parameters that add load to the valve.
 
The inspectors identified that calculations BNP-E-8.013, BNP-E-8.014, and 0BNP-TR-006 included assumptions based on MOV margins determined at a specific time, but they did not get revised and updated properly following results of MOV PVT that changed the assumed inputs into the calculations. Failing to update the calculations following changes to a MOV PVT margin can result in misidentifying that either the MOV will not stall (failing to begin to move or continue to change position) at all, or misidentifying the point at which an MOV has the potential of stalling during periods of transient voltages as a result of accident initiated load sequencing. This may result in failing to identify that a thermal overload (TOL) was insufficiently sized for the expected stall conditions during a degraded grid voltage condition. TOLs are included in the MOV electrical power path and can trip to interrupt the current being provided to the MOV motor to protect the motor from failure due to prolonged heating. However, if the TOL is not sized properly, the TOL could trip before the valve has moved to its required safety-function position.
 
4 of 0BNP-TR-006 evaluated a list of MOVs subject to electrical transient voltages during an accident to determine whether or not the MOV would stall during the transient, but had not been updated due to changes in assumed loading or other MOV adjustments since November 15, 2016. Attachment F of BNP-E-8.013/-014 evaluated the acceptability of TOLs for safety-related MOVs during a degraded voltage concurrent with an accident and used MOV margins to determine the voltage at which the MOVs may stall as input to the analysis. The team observed the MOV PVT margins assumed in the calculations had not been updated since Attachment F was added under revision 10 in 2014.
 
Section 5.2.7.i.(3) of procedure AD-EG-ALL-1117 required the licensee to clearly identify design inputs and associated reference sources in the body of the calculation. It also stated, "Refer to Attachment 18, Design Input Considerations, for the list of Design Input considerations." Consideration of electrical requirements and design inputs which could be invalidated by field activities were included in Attachment 18. The discovery of a parameter during PVT beyond that previously assumed, or the intentional adjustment of an MOV parameter (such as packing load adjustments) during implementation of field work on MOVs should have been considered as having the potential to impact a design input into calculations BNP-E-8.013, BNP-E-8.014, and 0BNP-TR-006. Also, sections 5.3.8 and 5.3.9, stated that the responsible Engineering Manager was to ensure documents impacted by Calculation conclusions are identified and appropriate processes are initiated to track and implement required changes." Additionally, procedure AD-EG-ALL-1117 section 4.2, required the Design Verifier to identify that the design inputs were accurate and complete.
 
The inspectors determined that because calculations BNP-E-8.013, BNP-E-8.014, and 0BNP-TR-006 did not identify the MOV margin calculations as providing design inputs into the calculations, they were not being updated as required. Upon discovery by the inspection team, the licensee updated the affected calculations to reflect the current MOV margins reflected by PVT results and determined the MOVs remained capable of performing their safety functions.
 
Corrective Actions: The licensee generated NCRs 2290331 and 2289038 and updated the affected calculations to reflect the current MOV parameters from PVT results.
 
Corrective Action References: NCRs 2290331 and 2289038
 
=====Performance Assessment:=====
Performance Deficiency: The licensee's failure to follow their AD-EG-ALL-1117, "Design Analyses and Calculations" Rev. 5 procedure was a performance deficiency.
 
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, failing to update calculations 0BNP-TR-006 and BNP-E-8.013/8.014 following changes to MOV parameters could lead to failing to identify that a valve may stall during the predicted voltage transient or failing to identify that a TOL was insufficiently sized for the expected stall conditions during a degraded grid voltage condition.
 
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors evaluated the finding in accordance with the NRC Inspection Manual Chapter (IMC) 0609, Attachment 4, "Initial Characterization of Findings," issued October 7, 2016, for Mitigating Systems, and IMC 0609, Appendix A, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating structure, system or component (SSC) and the SSC maintained its operability or functionality. Specifically, the licensee updated the affected calculations to reflect current MOV periodic verification testing results and determined the MOVs would be capable of performing their safety functions.
 
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. In this case, the licensee did not use their established process for implementing calculation changes.
 
=====Enforcement:=====
Violation: 10 CFR Part 50, Appendix B, Criterion V, required in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, Brunswick did not accomplish an activity affecting quality in accordance with their procedure. Specifically, procedure AD-EG-ALL-1117, section 4.2, required the verifier to identify that the design inputs were accurate and complete, and the licensee did not identify all design inputs for calculations 0BNP-TR-006, BNP-E-8.013, and BNP-E-8.014.
 
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
 
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
* On September 13, 2019, the inspectors presented the design basis assurance inspection (teams) 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
71111.21M Calculations
04KV-002
4.16kV Emergency Bus Degraded Grid Voltage Relay
Setpoint Calc
Rev. 4
0B21-0199
ECCS Analysis Results
Rev. 8
0B21-0199
ECCS Analysis Results
Rev. 8
0BNP-TR-006
MOV Design Basis Information GL-89-10 & GL-96-05
Rev. 6
0E41-1001
High Pressure Coolant Injection System - Condensate
Storage Tank Level Low Uncertainty and Setpoint
Calculation (E41-LSL-N002(3) Loops)
Rev. 3
0E41-1001
High Pressure Coolant Injection System - Condensate
Storage Tank Level-Low Uncertainty And Setpoint
Calculation (E41-LSL-N002(3) LOOPS)
Rev. 3
0E51-0028
Reactor Core Isolation Cooling System - Condensate
Storage Tank Level - Low Uncertainty And Scaling
Calculation (E51-LSL-4463(4) LOOPS)
Rev. 3
0EOP-WS-13.1
LPCI/RHR Vortex Limit (2 Pumps) Plus HPCI and RCIC
Vortex Determination
Rev. 6
0RNA-0001
Instrument Air Nitrogen Backup System Volume
Requirements
Rev. 4
27-8-E41-06F
NPSH Requirements - RCIC and HPCI
Rev. 1
ANP-3105NP
Brunswick Units 1 and 2 LOCA Break Spectrum Analysis for
ATRIUM 10XM Fuel for MELLLA+ Operation
Rev. 1
BNP-E-1.012
Safety Related AC Control Loop Voltage Analysis
Rev. 9
BNP-E-2.002
480V AC Safety Related MOVs Electrical Protection
Rev. 16
BNP-E-2.007
U2 480V Vital MCC Calculations
Rev. 19
BNP-E-6.085
Unit 2 125/250V DC Coordination/Protection Calculation
Rev. 7
BNP-E-6.093
Unit 1 125/250V DC Coordination/Protection Calculation
Rev. 6
BNP-E-6.095
Unit 1 125/250V DC Coordination/Protection Calculation
Rev. 7
BNP-E-6.120
25/250VDC System Battery Load Study
Rev. 12
BNP-E-6.121
Electrical Analysis for Safety Related DC Circuits
Rev. 10
BNP-E-7.002
AC Auxiliary Electrical Distribution System Voltage/Load
Flow/Fault Current Study
Rev. 14
BNP-E-8.010
AC Coordination Study
Rev. 23
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
BNP-E-8.010
AC Coordination Study
Rev. 24
BNP-E-8.014
Motor Torque Analysis for AC MOVs
Rev. 18
BNP-MECH-1-
CAC-V216-AO
AOV Setup Calculation for 1-CAC-V216-AO
Rev. 1
BNP-MECH-
AOV-DP-CAC
Differential Pressure Calcualtions for 1/2-CAC-V7-AO, -V8-
AO, -V216-AO Inboard Suppression Pool Purge Exhaust,
Outboard Suppression Pool Purge Exhaust, and Hardened
Wetwell Vent Isolation Air-Operated Valves
Rev. 0
BNP-PSA-034,
Appendix C
Operator Action Summary Reports
Rev. 17
M-89-0021
HPCI/RCIC NPSH with Suction from the CST
Rev. 0
SA-E51-739
Stress Analysis for RCIC Exhaust Pipe Due to Water
Hammer Loads
Rev. 0
Corrective Action
Documents
2085737,
2086053,
27923-23,
2063268,
2105119,
2165651,
630621, 633538,
27745, 508592,
709200
 
Corrective Action
Documents
Resulting from
Inspection
AR 02287837
0CM-PVT500
dated
08/20/2019
AR 02288218
DBAI 2019 - BNP-E-1.012 & 1.013 Not updated for 7.002
Rev 14
dated
08/22/2019
AR 02288751
NRC Identified: Typographical Error Found in UFSAR
dated
08/26/2019
AR 02288836
MOV Hydraulic Lock Monitoring Program
dated
08/26/2019
AR 02289038
DBAI 2019 - BNP-E-8.013 & 8.014, Att. F Errors
dated
08/27/2019
AR 02289460
Revise BNP-E-7.002 Assumption 3.2.2.9
dated
08/29/2019
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AR 02289996
Corrections to BNP-E-8.013 & BNP-E-8.014
dated
09/03/2019
AR 02290331
2019 DBAI: 0BNP-TR-006 attachment 4 not updated
dated
09/04/2019
AR 02290559
Administrative Update to UFSAR Section 6.3.3.3
dated
09/05/2019
AR 02291132
2019 NRC DBAI: Conservatism in MOV motor torque
methodology
dated
09/10/2019
AR 02291159
HPCI and RCIC Overspeed Evaluation Discrepancies
dated
09/10/2019
AR 02291174
2019 DBAI - BNP response to IN 2013-17 did not fully eval
dated
09/10/2019
AR 02291176
2019 DBAI: Replacemnt of Program MOV sprng packs not
timely
dated
09/10/2019
AR 02291385
2019 NRC DBAI - Procedure Corrections - EGR-NGGC-
0106 & 0101
dated
09/11/2019
AR 02291396
2019 DBAI IST Program Document Issue
dated
09/11/2019
AR 02291577
DBAI 2019 - BNP-E-8.013 & 8.014, Table G Errors
dated
09/12/2019
Drawings
0-FP-84314
8" Class 300 Wafer A31A Valve Assemby and Bettis N721-
SR80 Fail Close Actuator
Rev. B
1-FP-05887,
Sheet 2
Auto Depressurization System Elementary Diagram Unit 1
Rev. M
D-02041
Service Water System Piping Diagram
Rev. 66
D-02523 Sh. 1
Reactor Building High Pressure Coolant Injection System
Piping Diagram
Rev. 59
D-02523 Sh. 2
Reactor Building High Pressure Coolant Injection System
Piping Diagram
Rev. 53
D-02529 Sh. 1
Reactor Building Reactor Core Isolation Cooling System
Piping Diagram
Rev. 64
D-02529 Sh. 2
Reactor Building Reactor Core Isolation Cooling System
Piping Diagram
Rev. 46
D-02537
Reactor Building Service Water System Piping Diagram
Rev. 99
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
D-70029
Reactor Building Instrument Air Supply System Piping
Diagram
Rev. C
F-03000
Main One Line Diagram 230KV and 24KV Systems
Rev. 40
F-03002
4160V System Switchgear One Line Diagram
Rev. 33
F-03003
4160V Emergency System Switchgear E3 & E4 One Line
Diagram
Rev. 19
F-03026
Emergency Key One Line Diagram
Rev. 13
F-03050
480V MCC 2XB One Line Diagram
Rev. 94
FSP-27059
Reactor Building, Unit 1 Hardened Wetwell Vent Piping
Rev. 2
LL-03024, Sht. 7
25-250 Volt DC System Control Building Distribution Panel
4B - "H24"
Rev. 28
LL-90046
CAC System Hardened Wetwell Vent Valve V216 Control
Wiring Diagram
Rev. 1
Engineering
Changes
400921
Long Term Division II Load Management
407321
Evaluation Of DC Load Profile And Battery Voltages
Following The Restoration Of DC Battery Chargers To The
DC System During A DBA (LOOP/LOCA)
411708
Reduce Loads On 125/250 VDC Switchboard 1B-1 and 1B-2
and Revise 1st Minute Test Load in MST for 1A-1 1A-2, 1B-1
and 1B-2 Batteries
EC 276098
 
EC 294259
Unit 1, Phase 1 & 2, Hardened Containment Vent System
Upgrades in Repsonse to EA 12-109 (Mechanical)
Rev. 12
EC 298197
Acceptability of Shaft to Bowl Bearing Clearance and
Impeller Wear Ring Clearance for 2C CSW Pump 2-SW-2C-
Conv-PMP
Rev. 0
EC 299442
 
EC 406293
Evaluation of Instrument Uncertainty Calculations not for
Limiting Safety System Settings or Automatic Protective
Functions
Rev. 0
Engineering
Evaluations
ESR 96-00253
Service Water Pump Bearing Clearance Evaluation.
06/21/1999
Miscellaneous
4KV Metal Clad Switchgear Template
Rev. 4
03FSAR-041
Licensing Document Change Request
dated
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1/26/04
04FSAR-017
Licensing Document Change Request
dated
7/14/04
04TSB-04
Licensing Document Revision Request
Rev. 0
238-044
Procurement of Product - Lubricated Service Water Pumps -
AL6XN
Rev. 12
5170
System Health Report, Medium Voltage AC Distribution
Q2-2019
AR 102456
Operability Determination
dated
8/28/03
CPL-01
TECHNICAL SPECIFICATION REVISION REQUEST
DEGRADED VOLTAGE RELAYS
dated
06/29/1982
CPL-02
ADEQUACY OF STATION ELECTRIC DISTRIBUTION
SYSTEMS VOLTAGES
dated
11/23/1982
CSD-EG-BNP-
20
BNP IST Program Plan - 5th Interval
Rev. 0
DBD-51
DC Electrical System
Dated
6/7/2017
Docket 50-
25/50-324
Staff Positions Relative to Emergency Power Systems
dated
06/03/1977
EC 280671 Att. O
HPCI and RCIC Pump Discharge Pressure Evaluation
Rev. 4
EC 412996
1-E11-F048B-MO (1B RHR HX BYPASS VLV) with an
Aluminum Rotor Motor
Rev. 0
EC 46911
HPCI Function Update
Rev. 0
EC 54587
Basis for the 1(2)-E41-LSL-N002 and 1(2)-E41-LSL-N003
Setpoints
Rev. 0
FP-82508
Bettis General Operating and Maintenance Instructions for
Pneumatic Rotary Valve Actuators
Rev. D
FP-84867
Technical Manual for Installation, Operation and
Maintenance of Johnston Pump Company 27CC - 2 Stage
Service Water Pumps
Rev. D
GD-79-3307
LESSONS LEARNED SHORT TERM REQUIREMENTS
dated
2/31/1979
GD-79-612
ON-SITE EMERGENCY POWER SYSTEMS
dated
03/06/1979
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
JOG-TD-01
Spring Relaxation for Air Operators
Rev. 2
LAP-83-551
REQUEST FOR ADDITIONAL INFORMATION
ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES
dated
11/30/1983
NEDC-32973P
Safety Analysis Evaluations Relative to Measurement
Uncertainties for the BWR/4
Rev. 0
NLS-84-363
ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES
dated
08/30/1984
NLS-84-515
RESPONSE TO REQUEST FOR ADDITIONAL
INFORMATION: 1) ADEQUACY OF STATION ELECTRIC
SYSTEM VOLTAGE 2) TECHNICAL SPECIFICATIONS OF
DEGRADED VOLTAGE RELAYS
dated
01/18/1985
NLS-85-321
AMENDMENT TO FACILITY OPERATING LICENSE
dated
05/23/1985
NLS89072
Letter - SAFER/GESTR-LOCA Analysis
dated
3/29/89
NLU-80-338
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR
REACTOR REGULATION SUPPORTING AMENDMENT
NO. 28 TO FACILITY LICENSE NO. DPR-71 AND
AMENDMENT NO. 51 TO FACILITY LICENSE NO. DPR-62
dated
06/11/1980
NLU-83-70
PLANT SHIELDING MODIFICATIONS, NUREG-0737 ITEM
II.B.2.2
dated
01/27/1983
NO-80-1093
ADEQUACY OF STATION ELECTRICAL DISTRIBUTION
SYSTEMS VOLTAGE
dated
07/24/1980
NRC89401
Letter - SAFER/GESTR-LOCA Analysis
dated 6/1/89
PMCR 2063268
Modify Existing 125VDC Panel PMs to include Breaker
Testing
Dated
9/20/2016
SPEC 248-164
Specification for Procurement of Class 2 Buttery Valve and
Spare Parts for Hardened Wetwell Vent Containment
Isolation.
Rev. 1
TIA 2003-05
NRC Policy Questions on Technical Specification Adequacy
and Related Technical Specification Operability
dated
1/16/04
Procedures
0AOP-12.0
Loss of Uninterruptible Power Supply (UPS)
Rev. 26
0AOP-39.0
Loss of DC Power
Rev. 47
0AP-064
Time Critical Actions/Time Sensitive Actions Supplement
Rev. 5
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0CM-PVT500
Disassembly and Rebuild: Service Water Pump, Johnston
Pump Company
Rev. 35
0ENP-646
Post Test Evaluation of AOV Diagnostics
Rev. 2
0EOP-01-EDP
Emergency Depressurization
Rev. 6
0EOP-01-SBO-15 Primary Containment Isolation
Rev. 1
0EOP-01-SEP-01
Primary Containment Venting
Rev. 28
0MST-ADS41BR
ADS Loop B Logic Sys Functional and Simulated Auto
Actuation Test
Rev. 3
0PM-BKR-001
ITE 4KV Breaker and Compartment Checkout
Rev. 54
0PM-RLY-033
Functional Testing of Thermal Overload Relays
Rev. 24
0PT-10.1.1
RCIC System Operability Test
Rev. 107
0PT-10.1.3
RCIC System Operability Test - Flow Rates at 150 PSIG
Rev. 60
0PT-20.3
Local Leakrate Testing
Rev. 86
1MST-BAT11AR
25 VDC Battery 1A-1 Service Capacity Test
Rev. 8
1OP-19
High Pressure Coolant Injection System Operating
Procedure
Rev. 99
1OP-24
Containment Atmosphere Control System
Rev. 110
2EOP-01-RVCP
Reactor Vessel Control
Rev. 11
2MST-BAT11DR
25 VDC Battery 2B-2 Service Capacity Test
Rev. 7
2PT-24.1-2
Service Water Pump and Discharge
Rev. 86
AD-EG-ALL-1117
Design Analyses and Calculations
Rev. 5
AD-EG-ALL-1431
Air Operated Valve Scope and Categorization
Rev. 1
AD-EG-ALL-1432
Air Operated Valve Design Basis Review
Rev. 0
AD-EG-ALL-1433
Air Operated Valve Testing Requirements
Rev. 1
AD-EG-ALL-1434
Air Operated Valve Tracking and Trending Requirements
Rev. 1
CAP-NGGC-0202 Operating Experience and Construction Experience Program Rev. 23
EGR-NGGC-
0101
Electrical Calculation of Motor Output Torque for AC/DC
MOVs
Rev. 12
EGR-NGGC-
0106
AC/DC Overcurrent Protection and Coordination
Rev. 5
EGR-NGGC-
205
Air Operated Valve Reliability Program
Rev. 10
NGG-PMB-SOV-
NGG Equipment Reliability Template SOlenoid Operated
Rev. 0
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Valves (SOV)
SORMC-NUC-
050
System Operations Reference Manual Carolinas
Rev. 24
Work Orders
2068756-01,
2068759-11,
234502-01,
13503714-01,
24561-01,
20022842-01,
20107653-03,
20107653-04,
20123051-01,
255536-01,
20120570-01,
20120570-02,
20120570-03,
20120570-04,
20120570-08,
13522687-08,
20136720-01,
1895617-01,
20034690-01
}}
}}

Latest revision as of 21:36, 2 January 2025

Design Basis Assurance Inspection (Teams) Inspection Report 05000324/2019011 and 05000325/2019011
ML19289B887
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 10/16/2019
From: James Baptist
NRC/RGN-II
To: Krakuszeski J
Duke Energy Progress
Archer L
References
IR 2019011
Download: ML19289B887 (21)


Text

October 16, 2019

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000324/2019011 AND 05000325/2019011

Dear Mr. Krakuszeski:

On September 13, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or significance or severity of the violations 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.

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

Sincerely,

/RA/

James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety

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:

05000324/2019011 and 05000325/2019011

Enterprise Identifier: I-2019-011-0007

Licensee:

Duke Energy Progress, LLC

Facility:

Brunswick Steam Electric Plant

Location:

Southport, NC

Inspection Dates:

August 19, 2019 to September 13, 2019

Inspectors:

C. Franklin, Reactor Inspector

J. Montgomery, Senior Reactor Inspector

G. Ottenberg, Senior Reactor Inspector

M. Riley, Reactor Inspector

C. Baron, Mechanical Contractor

G. Nicely, Electrical Contractor

Approved By:

James B. Baptist, Chief

Engineering Branch 1

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) 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

Failure to Properly Size and Evaluate the Acceptability of MOV Thermal Overloads Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000324,05000325/2019011-01 Closed None (NPP)71111.21M The team identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion III, "Design Control," for the licensee's failure to translate design basis MOV requirements into sufficient procedural guidance to size and evaluate motor-operated valve (MOV) thermal overloads (TOLs) properly. Specifically, the licensee's procedure for sizing and evaluating TOLs, EGR-NGGC-0106, AC and DC Overcurrent Protection and Coordination Revision 5, did not incorporate guidance to properly size or evaluate the MOV TOLs during all design basis conditions.

Failure to Follow Calculation Control Process Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000324,05000325/2019011-02 Closed

[H.3] - Change Management 71111.21M The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion V,

"Instructions, Procedures and Drawings," for the licensee's failure to follow their AD-EG-ALL-1117, Design Analyses and Calculations, procedure. Specifically, procedure AD-EG-ALL-1117, section 4.2, required the verifier to identify that the design inputs were accurate and complete, however, the licensee did not identify all design inputs for calculations 0BNP-TR-006, "MOV Design Basis Information GL89-10 & GL 96-05," and BNP-E-8.013/BNP-E-8.014,

"Motor Torque Analysis for AC MOVs." As a result, the licensee failed to update the affected calculations following motor-operated valve (MOV) testing or maintenance, the results of which could change the results of the calculations.

Additional Tracking Items

None.

INSPECTION SCOPES

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

REACTOR SAFETY

===71111.21M - Design Bases Assurance Inspection (Teams)

The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:

Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (4 Samples)

(1) E4 Bus - Division II Emergency Switchgear
  • Material condition and configuration review performed during a visual non-intrusive inspection to assess material condition, the presence of hazards, and consistency of installed equipment with design documentation and analyses
  • Normal, abnormal, and emergency operating procedures
  • Breaker Maintenance effectiveness; Procedures for preventive maintenance, inspection, and testing to compare maintenance practices against industry and vendor guidance
  • Component health reports, corrective maintenance records, and corrective action history
  • Coordination and interface with the transmission system operator for plant voltage requirements and notification set points
  • Electrical calculations:(Load flow, bus loading and voltage drop, Degraded and loss of voltage protection, Protective relay and breaker settings and coordination, Short circuit and breaker duty analysis)
(2) Motor-Operated Valve (MOV) 2-E11-F007B - RHR Minimum Flow Bypass Valve to the Suppression Pool (Electrical Interfaces)
  • Calculations: (Motor Torque Determination, MOV Protection Thermal Overload Sizing and Evaluations, MOV motive and control power, available torque calculations)
  • Adherence to vendor and industry maintenance and technical updates
  • Material condition and configuration review performed during a visual non-intrusive inspection to assess material condition, the presence of hazards, and consistency of installed equipment with design documentation and analyses
(3) Unit 2 125V DC Distribution Panel 4-B
  • Material condition and configuration reviewed performed during a visual non-intrusive inspection to assess material condition, the presence of hazards, and consistency of installed equipment with design documentation and analyses
  • Procedures for maintenance and testing of breakers to compare practices against industry guidance
  • Component health reports and corrective action history
  • Calculations: (Bus loading and voltage drop, short circuit analysis, breaker coordination study)
  • Surveillance testing of battery power supply attributes inspected (e.g.,

maximum available fault current)

(4) Unit 1 Reactor Core Isolation Cooling (RCIC) Pump, E51-C001
  • Material condition and installed configuration (e.g., visual inspection/walkdown)
  • Normal, abnormal, and emergency operating procedures
  • Consistency among design and licensing bases and other documents/procedures
  • System health report, maintenance effectiveness and records, and corrective action history
  • Equipment/environmental controls and qualification
  • Design calculations
  • Surveillance testing and recent test results
  • System and component level performance monitoring
  • Equipment protection from fire, flood, and water intrusion or spray
  • Heat removal cooling water and ventilation

Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02)===

(1) Unit 1 Air-Operated Valve (AOV) 1-CAC-V216 - Hardened Wetwell Vent Line Isolation Valve
  • Material condition and configuration review performed during a visual non-intrusive inspection to assess material condition, the presence of hazards, and consistency of installed equipment with design documentation and analyses
  • Normal, abnormal and emergency operating procedures
  • Maintenance effectiveness; Procedures for preventive maintenance, inspection, and testing to compare maintenance practices against industry and vendor guidance.
  • Component health reports, corrective maintenance records, and corrective action history
  • Calculations: (actuator output capability and margins, air supply and control power, required design basis capability, uncertainty assumptions)

Modification Review - Permanent Mods (IP Section 02.03) (4 Samples)

(1) EC 406293, Evaluation of Instrument Uncertainty Calculations not for Limiting Safety System Settings or Automatic Protective Functions
(2) EC 298197, Acceptability of Shaft to Bowl Bearing Clearance and Impeller Wear Ring Clearance for 2C CSW PUMP 2-SW-2C-CONV-PMP
(3) EC 412996, Replace the 1-E11-F048B-MO (1B RHR HX BYPASS VLV) with an Aluminum Rotor Motor
(4) EC 407321, Evaluation Of DC Load Profile And Battery Voltages Following The Restoration Of DC Battery Chargers To The DC System During A DBA (LOOP/LOCA)

Review of Operating Experience Issues (IP Section 02.06) (2 Samples)

(1) NRC Regulatory Issue Summary (RIS) 2011-12, Rev. 1, Adequacy of Station Electric Distribution System Voltages
(2) NRC Information Notice 2013-17, Significant Plant Transient Induced by Safety-Related Direct Current Bus Maintenance at Power

INSPECTION RESULTS

Failure to Properly Size and Evaluate the Acceptability of MOV Thermal Overloads Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000324,05000325/2019011-01 Closed

None (NPP)71111.21M The team identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion III, "Design Control," for the licensee's failure to translate design basis MOV requirements into sufficient procedural guidance to size and evaluate motor-operated valve (MOV) thermal overloads (TOLs) properly. Specifically, the licensee's procedure for sizing and evaluating TOLs, EGR-NGGC-0106, AC and DC Overcurrent Protection and Coordination Revision 5, did not incorporate guidance to properly size or evaluate the MOV TOLs during all design basis conditions.

Description:

TOLs are installed to protect MOV actuator motors from failure due to heating caused by prolonged exposure to high current. The TOLs trip to interrupt the current to the MOV motor, which prevents the valve from moving. In nuclear power plant applications, the criterion for establishing an MOV TOL trip set point should be for the valve to complete its safety function (e.g., drive the valve to its proper position to mitigate the effects of an accident) rather than to protect the motor from destructive heating. MOVs may be required to operate at the beginning of an accident when other large motors are also starting, which could result in bus voltage dropping low enough to stall the MOV until voltage recovers. If these voltage dips occur while power to the MOV is being supplied from the offsite power source, and voltage doesnt recover quickly (generally within 5 seconds), then the MOV may continue to stall until the degraded voltage protection system time delay relay (described in TS 3.3.8.1) actuates. This causes the plant to disconnect from the offsite power source, and switch to the emergency diesel generators. During this time, the stalled MOVs could be experiencing high currents and generating excessive heat within both the actuator motor and the TOL, which can cause the TOL to actuate and trip the power to the MOV if not sized adequately to operate through the event without tripping. Similarly, MOVs may also have a jogging or throttling requirement during the accident which requires multiple starts of its motor within a short period of time. These demands would add additional heat to the MOV motor and TOL, which can also cause the TOL to actuate and trip the power to the MOV.

The inspection team reviewed Attachment F, DVR and TOL Evaluation, of calculations BNP-E-8.013 and BNP-E-8.014, Motor Torque Analysis for AC Motor Operated Valves, to evaluate how the licensee confirmed that the MOV TOLs were sized appropriately for degraded grid voltage conditions concurrent with accident conditions. During the team's review of the calculations, the team discovered several errors in the calculation methodology that were non-conservative and required the licensee to re-evaluate them. The licensee captured these errors in their corrective action program as action requests (ARs) 2289038 and 2289996. Once the licensee corrected the errors in their calculation, the team discovered that the TOLs for nine MOVs had the potential to trip before the valves performed their safety function, if the MOV was taken out of its normal position and the MOV received an accident signal to reposition back to its normal safety-function position.

Upon discovering that the TOLs were undersized, the inspection team reviewed the procedural guidance in BNP Standard Procedure EGR-NGGC-0106, AC and DC Overcurrent Protection and Coordination, Revision 5, which the licensee used to size various electrical protective devices.

The team observed that section 9.3.14, Considerations for AC and DC Protective Device Selection, described that protective devices must be adequately sized for the operating scenarios under consideration, such as during starting of other loads simultaneously or during a degraded voltage condition where the inrush current of a starting motor may continue until the voltage recovers to the point at which the devices can operate. However, section 9.6, MOV Motor Circuit Protection, which the licensee used for sizing MOV TOLs specifically, did not reference or include the guidance described in subsection 9.3.14. Additionally, in section 9.6 there was no specific guidance for various scenarios required by the station MOVs design bases, including:

  • Considering a sustained degraded grid voltage and its associated 11 second maximum time delay allowed by the degraded grid voltage relay setpoints required by TS 3.3.8.1,
  • The allowances given in Generic Letter 89-10, Supplement 1, and utilized by the station MOV program to delay starting of MOVs for approximately 5 seconds during upstream motor starting which may result in stall conditions for that time,
  • Sizing TOLs for MOVs that have a jogging/throttling function post-event.
  • Establishing the trip setpoint of the TOLs with all uncertainties resolved in favor of completing the safety-related action, rather than protecting the motor.

Because of the inadequate procedural guidance, the team determined that calculation BNP-E-2.002, 480V AC Auxiliary Safety-related MOV Electrical Protection, Rev. 16, which sized the TOLs for MOVs, did not ensure that the safety function of the MOVs would be met, as it did not account for the different operating scenarios described above. Several of the TOLs were undersized in favor of providing protection for the MOV motor, rather than ensuring the safety function would be completed. NCR 2291385 was generated to evaluate the procedural adequacy.

Corrective Actions: The licensee entered the issue into their corrective action program and evaluated the MOVs' capability to respond to accident conditions due to being in their normal required position prior to the event. The licensee further initiated plans to improve the guidance in procedures for sizing and evaluating MOV TOLs.

Corrective Action References: NCRs 02289038 and 02291385 and NTM 2289996

Performance Assessment:

Performance Deficiency: The team determined the licensee's failure to translate design basis MOV requirements into sufficient procedural guidance in EGR-NGGC-0106 to size and evaluate the MOV TOLs properly was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, nine MOVs were identified that had under-sized TOLs and had the potential to trip during an accident concurrent with a degraded voltage condition, and the improper TOL sizing challenges the capability of the MOVs during degraded grid voltage design conditions.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors evaluated the finding in accordance with the NRC Inspection Manual Chapter (IMC) 0609, Attachment 4, "Initial Characterization of Findings," issued October 7, 2016, for Mitigating Systems, and IMC 0609, Appendix A, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because finding was a design deficiency and the affected SSCs maintained their operability. Specifically, the licensee justified the MOVs would be able to perform their safety function under predicted transient voltage conditions during a design basis accident, although they would be challenged under concurrent accident and degraded voltage scenarios.

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, required, in part that Measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, since at least the last revision to procedure EGR-NGGC-0106 in April 2016, the licensee did not assure that applicable regulatory requirements and the design bases were correctly translated into procedures. Specifically, procedure EGR-NGGC-0106 did not incorporate guidance to properly evaluate the MOV TOLs during design basis accidents concurrent with degraded grid voltage design conditions allowed by the setpoints in plant technical specifications for the degraded grid voltage relays or other different MOV operating scenarios required by the station MOVs design bases.

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

Failure to Follow Calculation Control Process Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000324,05000325/2019011-02 Closed

[H.3] - Change Management 71111.21M The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion V, "Instructions, Procedures and Drawings," for the licensee's failure to follow their AD-EG-ALL-1117, Design Analyses and Calculations, procedure. Specifically, procedure AD-EG-ALL-1117, section 4.2, required the verifier to identify that the design inputs were accurate and complete, however, the licensee did not identify all design inputs for calculations 0BNP-TR-006, "MOV Design Basis Information GL89-10 & GL 96-05," and BNP-E-8.013/BNP-E-8.014, "Motor Torque Analysis for AC MOVs." As a result, the licensee failed to update the affected calculations following motor-operated valve (MOV) testing or maintenance, the results of which could change the results of the calculations.

Description:

The purpose of calculations BNP-E-8.013 and BNP-E-8.014 was to calculate available MOV motor torque during extreme bus voltages, and the purpose of calculation 0BNP-TR-006 was to document design basis information for Generic Letter (GL) 89-10 and GL 96-05 MOVs. Additionally, each motor-operated valve (MOV) included in the licensee's MOV program has an associated calculation that determines the margin available to operate the MOV during design basis scenarios. The individual MOV margin calculations get updated occasionally following Periodic Verification Testing (PVT) if the results of the testing indicate a change in a parameter that led to an increase or decrease in the calculated margin for the MOV. The margin calculations compare available MOV output thrust/torque to the thrust/torque required to make the valve change position. The determination of available thrust/torque is dependent on the voltage of the electrical source supplying power to the MOV motor; the determination of the required thrust/torque is dependent on mechanical properties of the valve and piping system including various parameters that add load to the valve.

The inspectors identified that calculations BNP-E-8.013, BNP-E-8.014, and 0BNP-TR-006 included assumptions based on MOV margins determined at a specific time, but they did not get revised and updated properly following results of MOV PVT that changed the assumed inputs into the calculations. Failing to update the calculations following changes to a MOV PVT margin can result in misidentifying that either the MOV will not stall (failing to begin to move or continue to change position) at all, or misidentifying the point at which an MOV has the potential of stalling during periods of transient voltages as a result of accident initiated load sequencing. This may result in failing to identify that a thermal overload (TOL) was insufficiently sized for the expected stall conditions during a degraded grid voltage condition. TOLs are included in the MOV electrical power path and can trip to interrupt the current being provided to the MOV motor to protect the motor from failure due to prolonged heating. However, if the TOL is not sized properly, the TOL could trip before the valve has moved to its required safety-function position.

4 of 0BNP-TR-006 evaluated a list of MOVs subject to electrical transient voltages during an accident to determine whether or not the MOV would stall during the transient, but had not been updated due to changes in assumed loading or other MOV adjustments since November 15, 2016. Attachment F of BNP-E-8.013/-014 evaluated the acceptability of TOLs for safety-related MOVs during a degraded voltage concurrent with an accident and used MOV margins to determine the voltage at which the MOVs may stall as input to the analysis. The team observed the MOV PVT margins assumed in the calculations had not been updated since Attachment F was added under revision 10 in 2014.

Section 5.2.7.i.(3) of procedure AD-EG-ALL-1117 required the licensee to clearly identify design inputs and associated reference sources in the body of the calculation. It also stated, "Refer to Attachment 18, Design Input Considerations, for the list of Design Input considerations." Consideration of electrical requirements and design inputs which could be invalidated by field activities were included in Attachment 18. The discovery of a parameter during PVT beyond that previously assumed, or the intentional adjustment of an MOV parameter (such as packing load adjustments) during implementation of field work on MOVs should have been considered as having the potential to impact a design input into calculations BNP-E-8.013, BNP-E-8.014, and 0BNP-TR-006. Also, sections 5.3.8 and 5.3.9, stated that the responsible Engineering Manager was to ensure documents impacted by Calculation conclusions are identified and appropriate processes are initiated to track and implement required changes." Additionally, procedure AD-EG-ALL-1117 section 4.2, required the Design Verifier to identify that the design inputs were accurate and complete.

The inspectors determined that because calculations BNP-E-8.013, BNP-E-8.014, and 0BNP-TR-006 did not identify the MOV margin calculations as providing design inputs into the calculations, they were not being updated as required. Upon discovery by the inspection team, the licensee updated the affected calculations to reflect the current MOV margins reflected by PVT results and determined the MOVs remained capable of performing their safety functions.

Corrective Actions: The licensee generated NCRs 2290331 and 2289038 and updated the affected calculations to reflect the current MOV parameters from PVT results.

Corrective Action References: NCRs 2290331 and 2289038

Performance Assessment:

Performance Deficiency: The licensee's failure to follow their AD-EG-ALL-1117, "Design Analyses and Calculations" Rev. 5 procedure was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, failing to update calculations 0BNP-TR-006 and BNP-E-8.013/8.014 following changes to MOV parameters could lead to failing to identify that a valve may stall during the predicted voltage transient or failing to identify that a TOL was insufficiently sized for the expected stall conditions during a degraded grid voltage condition.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors evaluated the finding in accordance with the NRC Inspection Manual Chapter (IMC) 0609, Attachment 4, "Initial Characterization of Findings," issued October 7, 2016, for Mitigating Systems, and IMC 0609, Appendix A, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating structure, system or component (SSC) and the SSC maintained its operability or functionality. Specifically, the licensee updated the affected calculations to reflect current MOV periodic verification testing results and determined the MOVs would be capable of performing their safety functions.

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. In this case, the licensee did not use their established process for implementing calculation changes.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion V, required in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, Brunswick did not accomplish an activity affecting quality in accordance with their procedure. Specifically, procedure AD-EG-ALL-1117, section 4.2, required the verifier to identify that the design inputs were accurate and complete, and the licensee did not identify all design inputs for calculations 0BNP-TR-006, BNP-E-8.013, and BNP-E-8.014.

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

EXIT MEETINGS AND DEBRIEFS

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

  • On September 13, 2019, the inspectors presented the design basis assurance inspection (teams) 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

71111.21M Calculations

04KV-002

4.16kV Emergency Bus Degraded Grid Voltage Relay

Setpoint Calc

Rev. 4

0B21-0199

ECCS Analysis Results

Rev. 8

0B21-0199

ECCS Analysis Results

Rev. 8

0BNP-TR-006

MOV Design Basis Information GL-89-10 & GL-96-05

Rev. 6

0E41-1001

High Pressure Coolant Injection System - Condensate

Storage Tank Level Low Uncertainty and Setpoint

Calculation (E41-LSL-N002(3) Loops)

Rev. 3

0E41-1001

High Pressure Coolant Injection System - Condensate

Storage Tank Level-Low Uncertainty And Setpoint

Calculation (E41-LSL-N002(3) LOOPS)

Rev. 3

0E51-0028

Reactor Core Isolation Cooling System - Condensate

Storage Tank Level - Low Uncertainty And Scaling

Calculation (E51-LSL-4463(4) LOOPS)

Rev. 3

0EOP-WS-13.1

LPCI/RHR Vortex Limit (2 Pumps) Plus HPCI and RCIC

Vortex Determination

Rev. 6

0RNA-0001

Instrument Air Nitrogen Backup System Volume

Requirements

Rev. 4

27-8-E41-06F

NPSH Requirements - RCIC and HPCI

Rev. 1

ANP-3105NP

Brunswick Units 1 and 2 LOCA Break Spectrum Analysis for

ATRIUM 10XM Fuel for MELLLA+ Operation

Rev. 1

BNP-E-1.012

Safety Related AC Control Loop Voltage Analysis

Rev. 9

BNP-E-2.002

480V AC Safety Related MOVs Electrical Protection

Rev. 16

BNP-E-2.007

U2 480V Vital MCC Calculations

Rev. 19

BNP-E-6.085

Unit 2 125/250V DC Coordination/Protection Calculation

Rev. 7

BNP-E-6.093

Unit 1 125/250V DC Coordination/Protection Calculation

Rev. 6

BNP-E-6.095

Unit 1 125/250V DC Coordination/Protection Calculation

Rev. 7

BNP-E-6.120

25/250VDC System Battery Load Study

Rev. 12

BNP-E-6.121

Electrical Analysis for Safety Related DC Circuits

Rev. 10

BNP-E-7.002

AC Auxiliary Electrical Distribution System Voltage/Load

Flow/Fault Current Study

Rev. 14

BNP-E-8.010

AC Coordination Study

Rev. 23

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

BNP-E-8.010

AC Coordination Study

Rev. 24

BNP-E-8.014

Motor Torque Analysis for AC MOVs

Rev. 18

BNP-MECH-1-

CAC-V216-AO

AOV Setup Calculation for 1-CAC-V216-AO

Rev. 1

BNP-MECH-

AOV-DP-CAC

Differential Pressure Calcualtions for 1/2-CAC-V7-AO, -V8-

AO, -V216-AO Inboard Suppression Pool Purge Exhaust,

Outboard Suppression Pool Purge Exhaust, and Hardened

Wetwell Vent Isolation Air-Operated Valves

Rev. 0

BNP-PSA-034,

Appendix C

Operator Action Summary Reports

Rev. 17

M-89-0021

HPCI/RCIC NPSH with Suction from the CST

Rev. 0

SA-E51-739

Stress Analysis for RCIC Exhaust Pipe Due to Water

Hammer Loads

Rev. 0

Corrective Action

Documents

2085737,

2086053,

27923-23,

2063268,

2105119,

2165651,

630621, 633538,

27745, 508592,

709200

Corrective Action

Documents

Resulting from

Inspection

AR 02287837

0CM-PVT500

dated

08/20/2019

AR 02288218

DBAI 2019 - BNP-E-1.012 & 1.013 Not updated for 7.002

Rev 14

dated

08/22/2019

AR 02288751

NRC Identified: Typographical Error Found in UFSAR

dated

08/26/2019

AR 02288836

MOV Hydraulic Lock Monitoring Program

dated

08/26/2019

AR 02289038

DBAI 2019 - BNP-E-8.013 & 8.014, Att. F Errors

dated

08/27/2019

AR 02289460

Revise BNP-E-7.002 Assumption 3.2.2.9

dated

08/29/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AR 02289996

Corrections to BNP-E-8.013 & BNP-E-8.014

dated

09/03/2019

AR 02290331

2019 DBAI: 0BNP-TR-006 attachment 4 not updated

dated

09/04/2019

AR 02290559

Administrative Update to UFSAR Section 6.3.3.3

dated

09/05/2019

AR 02291132

2019 NRC DBAI: Conservatism in MOV motor torque

methodology

dated

09/10/2019

AR 02291159

HPCI and RCIC Overspeed Evaluation Discrepancies

dated

09/10/2019

AR 02291174

2019 DBAI - BNP response to IN 2013-17 did not fully eval

dated

09/10/2019

AR 02291176

2019 DBAI: Replacemnt of Program MOV sprng packs not

timely

dated

09/10/2019

AR 02291385

2019 NRC DBAI - Procedure Corrections - EGR-NGGC-

0106 & 0101

dated

09/11/2019

AR 02291396

2019 DBAI IST Program Document Issue

dated

09/11/2019

AR 02291577

DBAI 2019 - BNP-E-8.013 & 8.014, Table G Errors

dated

09/12/2019

Drawings

0-FP-84314

8" Class 300 Wafer A31A Valve Assemby and Bettis N721-

SR80 Fail Close Actuator

Rev. B

1-FP-05887,

Sheet 2

Auto Depressurization System Elementary Diagram Unit 1

Rev. M

D-02041

Service Water System Piping Diagram

Rev. 66

D-02523 Sh. 1

Reactor Building High Pressure Coolant Injection System

Piping Diagram

Rev. 59

D-02523 Sh. 2

Reactor Building High Pressure Coolant Injection System

Piping Diagram

Rev. 53

D-02529 Sh. 1

Reactor Building Reactor Core Isolation Cooling System

Piping Diagram

Rev. 64

D-02529 Sh. 2

Reactor Building Reactor Core Isolation Cooling System

Piping Diagram

Rev. 46

D-02537

Reactor Building Service Water System Piping Diagram

Rev. 99

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

D-70029

Reactor Building Instrument Air Supply System Piping

Diagram

Rev. C

F-03000

Main One Line Diagram 230KV and 24KV Systems

Rev. 40

F-03002

4160V System Switchgear One Line Diagram

Rev. 33

F-03003

4160V Emergency System Switchgear E3 & E4 One Line

Diagram

Rev. 19

F-03026

Emergency Key One Line Diagram

Rev. 13

F-03050

480V MCC 2XB One Line Diagram

Rev. 94

FSP-27059

Reactor Building, Unit 1 Hardened Wetwell Vent Piping

Rev. 2

LL-03024, Sht. 7

25-250 Volt DC System Control Building Distribution Panel

4B - "H24"

Rev. 28

LL-90046

CAC System Hardened Wetwell Vent Valve V216 Control

Wiring Diagram

Rev. 1

Engineering

Changes

400921

Long Term Division II Load Management

407321

Evaluation Of DC Load Profile And Battery Voltages

Following The Restoration Of DC Battery Chargers To The

DC System During A DBA (LOOP/LOCA)

411708

Reduce Loads On 125/250 VDC Switchboard 1B-1 and 1B-2

and Revise 1st Minute Test Load in MST for 1A-1 1A-2, 1B-1

and 1B-2 Batteries

EC 276098

EC 294259

Unit 1, Phase 1 & 2, Hardened Containment Vent System

Upgrades in Repsonse to EA 12-109 (Mechanical)

Rev. 12

EC 298197

Acceptability of Shaft to Bowl Bearing Clearance and

Impeller Wear Ring Clearance for 2C CSW Pump 2-SW-2C-

Conv-PMP

Rev. 0

EC 299442

EC 406293

Evaluation of Instrument Uncertainty Calculations not for

Limiting Safety System Settings or Automatic Protective

Functions

Rev. 0

Engineering

Evaluations

ESR 96-00253

Service Water Pump Bearing Clearance Evaluation.

06/21/1999

Miscellaneous

4KV Metal Clad Switchgear Template

Rev. 4

03FSAR-041

Licensing Document Change Request

dated

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1/26/04

04FSAR-017

Licensing Document Change Request

dated

7/14/04

04TSB-04

Licensing Document Revision Request

Rev. 0

238-044

Procurement of Product - Lubricated Service Water Pumps -

AL6XN

Rev. 12

5170

System Health Report, Medium Voltage AC Distribution

Q2-2019

AR 102456102456Operability Determination

dated

8/28/03

CPL-01

TECHNICAL SPECIFICATION REVISION REQUEST

DEGRADED VOLTAGE RELAYS

dated

06/29/1982

CPL-02

ADEQUACY OF STATION ELECTRIC DISTRIBUTION

SYSTEMS VOLTAGES

dated

11/23/1982

CSD-EG-BNP-

20

BNP IST Program Plan - 5th Interval

Rev. 0

DBD-51

DC Electrical System

Dated

6/7/2017

Docket 50-

25/50-324

Staff Positions Relative to Emergency Power Systems

dated

06/03/1977

EC 280671 Att. O

HPCI and RCIC Pump Discharge Pressure Evaluation

Rev. 4

EC 412996

1-E11-F048B-MO (1B RHR HX BYPASS VLV) with an

Aluminum Rotor Motor

Rev. 0

EC 46911

HPCI Function Update

Rev. 0

EC 54587

Basis for the 1(2)-E41-LSL-N002 and 1(2)-E41-LSL-N003

Setpoints

Rev. 0

FP-82508

Bettis General Operating and Maintenance Instructions for

Pneumatic Rotary Valve Actuators

Rev. D

FP-84867

Technical Manual for Installation, Operation and

Maintenance of Johnston Pump Company 27CC - 2 Stage

Service Water Pumps

Rev. D

GD-79-3307

LESSONS LEARNED SHORT TERM REQUIREMENTS

dated

2/31/1979

GD-79-612

ON-SITE EMERGENCY POWER SYSTEMS

dated

03/06/1979

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

JOG-TD-01

Spring Relaxation for Air Operators

Rev. 2

LAP-83-551

REQUEST FOR ADDITIONAL INFORMATION

ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES

dated

11/30/1983

NEDC-32973P

Safety Analysis Evaluations Relative to Measurement

Uncertainties for the BWR/4

Rev. 0

NLS-84-363

ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES

dated

08/30/1984

NLS-84-515

RESPONSE TO REQUEST FOR ADDITIONAL

INFORMATION: 1) ADEQUACY OF STATION ELECTRIC

SYSTEM VOLTAGE 2) TECHNICAL SPECIFICATIONS OF

DEGRADED VOLTAGE RELAYS

dated

01/18/1985

NLS-85-321

AMENDMENT TO FACILITY OPERATING LICENSE

dated

05/23/1985

NLS89072

Letter - SAFER/GESTR-LOCA Analysis

dated

3/29/89

NLU-80-338

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR

REACTOR REGULATION SUPPORTING AMENDMENT

NO. 28 TO FACILITY LICENSE NO. DPR-71 AND

AMENDMENT NO. 51 TO FACILITY LICENSE NO. DPR-62

dated

06/11/1980

NLU-83-70

PLANT SHIELDING MODIFICATIONS, NUREG-0737 ITEM

II.B.2.2

dated

01/27/1983

NO-80-1093

ADEQUACY OF STATION ELECTRICAL DISTRIBUTION

SYSTEMS VOLTAGE

dated

07/24/1980

NRC89401

Letter - SAFER/GESTR-LOCA Analysis

dated 6/1/89

PMCR 2063268

Modify Existing 125VDC Panel PMs to include Breaker

Testing

Dated

9/20/2016

SPEC 248-164

Specification for Procurement of Class 2 Buttery Valve and

Spare Parts for Hardened Wetwell Vent Containment

Isolation.

Rev. 1

TIA 2003-05

NRC Policy Questions on Technical Specification Adequacy

and Related Technical Specification Operability

dated

1/16/04

Procedures

0AOP-12.0

Loss of Uninterruptible Power Supply (UPS)

Rev. 26

0AOP-39.0

Loss of DC Power

Rev. 47

0AP-064

Time Critical Actions/Time Sensitive Actions Supplement

Rev. 5

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

0CM-PVT500

Disassembly and Rebuild: Service Water Pump, Johnston

Pump Company

Rev. 35

0ENP-646

Post Test Evaluation of AOV Diagnostics

Rev. 2

0EOP-01-EDP

Emergency Depressurization

Rev. 6

0EOP-01-SBO-15 Primary Containment Isolation

Rev. 1

0EOP-01-SEP-01

Primary Containment Venting

Rev. 28

0MST-ADS41BR

ADS Loop B Logic Sys Functional and Simulated Auto

Actuation Test

Rev. 3

0PM-BKR-001

ITE 4KV Breaker and Compartment Checkout

Rev. 54

0PM-RLY-033

Functional Testing of Thermal Overload Relays

Rev. 24

0PT-10.1.1

RCIC System Operability Test

Rev. 107

0PT-10.1.3

RCIC System Operability Test - Flow Rates at 150 PSIG

Rev. 60

0PT-20.3

Local Leakrate Testing

Rev. 86

1MST-BAT11AR

25 VDC Battery 1A-1 Service Capacity Test

Rev. 8

1OP-19

High Pressure Coolant Injection System Operating

Procedure

Rev. 99

1OP-24

Containment Atmosphere Control System

Rev. 110

2EOP-01-RVCP

Reactor Vessel Control

Rev. 11

2MST-BAT11DR

25 VDC Battery 2B-2 Service Capacity Test

Rev. 7

2PT-24.1-2

Service Water Pump and Discharge

Rev. 86

AD-EG-ALL-1117

Design Analyses and Calculations

Rev. 5

AD-EG-ALL-1431

Air Operated Valve Scope and Categorization

Rev. 1

AD-EG-ALL-1432

Air Operated Valve Design Basis Review

Rev. 0

AD-EG-ALL-1433

Air Operated Valve Testing Requirements

Rev. 1

AD-EG-ALL-1434

Air Operated Valve Tracking and Trending Requirements

Rev. 1

CAP-NGGC-0202 Operating Experience and Construction Experience Program Rev. 23

EGR-NGGC-

0101

Electrical Calculation of Motor Output Torque for AC/DC

MOVs

Rev. 12

EGR-NGGC-

0106

AC/DC Overcurrent Protection and Coordination

Rev. 5

EGR-NGGC-

205

Air Operated Valve Reliability Program

Rev. 10

NGG-PMB-SOV-

NGG Equipment Reliability Template SOlenoid Operated

Rev. 0

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Valves (SOV)

SORMC-NUC-

050

System Operations Reference Manual Carolinas

Rev. 24

Work Orders

2068756-01,

2068759-11,

234502-01,

13503714-01,

24561-01,

20022842-01,

20107653-03,

20107653-04,

20123051-01,

255536-01,

20120570-01,

20120570-02,

20120570-03,

20120570-04,

20120570-08,

13522687-08,

20136720-01,

1895617-01,

20034690-01