IR 05000324/2019011: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(4 intermediate revisions by the same user not shown)
Line 18: Line 18:


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


==SUBJECT:==
==SUBJECT:==
Line 34: Line 34:


Sincerely,
Sincerely,
/RA/
/RA/  
James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000324 and 05000325 License Nos. DPR-62 and DPR-71
 
James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety  
 
Docket Nos. 05000324 and 05000325 License Nos. DPR-62 and DPR-71  


===Enclosure:===
===Enclosure:===
As stated
As stated  


==Inspection Report==
==Inspection Report==
Docket Numbers: 05000324 and 05000325 License Numbers: DPR-62 and DPR-71 Report Numbers: 05000324/2019011 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 Enclosure
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=
=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.
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   Report Aspect          Section Mitigating             Green                                       None (NPP)      71111.21M Systems                NCV 05000324,05000325/2019011-01 Closed 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.
===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   Report Aspect          Section Mitigating             Green                                       [H.3] - Change   71111.21M Systems                NCV 05000324,05000325/2019011-02            Management Closed 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,
Failure to Follow Calculation Control Process Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000324,05000325/2019011-02 Closed
  "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,
[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,  
  "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.
"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.
===Additional Tracking Items===
None.


=INSPECTION SCOPES=
=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.
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==
==REACTOR SAFETY==
===71111.21M - Design Bases Assurance Inspection (Teams)
The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:


===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)
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (4 Samples)
: (1) E4 Bus - Division II Emergency Switchgear
: (1) E4 Bus - Division II Emergency Switchgear
Line 91: Line 137:
* System and component level performance monitoring
* System and component level performance monitoring
* Equipment protection from fire, flood, and water intrusion or spray
* 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) ===
* 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}}
{{IP sample|IP=IP 71111.21|count=1}}
: (1) Unit 1 Air-Operated Valve (AOV) 1-CAC-V216 - Hardened Wetwell Vent Line Isolation Valve
: (1) Unit 1 Air-Operated Valve (AOV) 1-CAC-V216 - Hardened Wetwell Vent Line Isolation Valve
Line 98: Line 146:
* Maintenance effectiveness; Procedures for preventive maintenance, inspection, and testing to compare maintenance practices against industry and vendor guidance.
* 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
* 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)
* 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
===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
: (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
: (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)
: (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)===
 
===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
: (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
: (2) NRC Information Notice 2013-17, Significant Plant Transient Induced by Safety-Related Direct Current Bus Maintenance at Power


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Failure to Properly Size and Evaluate the Acceptability of MOV Thermal Overloads Cornerstone           Significance                               Cross-Cutting       Report Aspect              Section Mitigating             Green                                     None (NPP)          71111.21M Systems                NCV 05000324,05000325/2019011-01 Closed 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 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:=====
=====Description:=====
Line 120: Line 172:
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.
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
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:
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,
* 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,
* 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,
Line 131: Line 182:
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 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
Corrective Action References: NCRs 02289038 and 02291385 and NTM 2289996  


=====Performance Assessment:=====
=====Performance Assessment:=====
Line 138: Line 189:
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.
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
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.
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.
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.
Line 148: Line 198:
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
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     Report Aspect            Section Mitigating             Green                                     [H.3] - Change     71111.21M Systems                NCV 05000324,05000325/2019011-02 Management Closed 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.
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:=====
=====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
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.
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.
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.
Line 164: Line 217:
Corrective Actions: The licensee generated NCRs 2290331 and 2289038 and updated the affected calculations to reflect the current MOV parameters from PVT results.
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
Corrective Action References: NCRs 2290331 and 2289038  


=====Performance Assessment:=====
=====Performance Assessment:=====
Line 171: Line 224:
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.
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
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.
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.
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:=====
=====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
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.
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.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Line 188: Line 239:
=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Inspection Type       Designation   Description or Title                                     Revision or
Inspection
Procedure                                                                                      Date
Procedure
71111.21M Calculations 04KV-002       4.16kV Emergency Bus Degraded Grid Voltage Relay         Rev. 4
Type
Designation
Description or Title
Revision or
Date
71111.21M Calculations
04KV-002
4.16kV Emergency Bus Degraded Grid Voltage Relay
Setpoint Calc
Setpoint Calc
0B21-0199     ECCS Analysis Results                                   Rev. 8
Rev. 4
0B21-0199     ECCS Analysis Results                                   Rev. 8
0B21-0199
0BNP-TR-006   MOV Design Basis Information GL-89-10 & GL-96-05         Rev. 6
ECCS Analysis Results
0E41-1001     High Pressure Coolant Injection System - Condensate     Rev. 3
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
Storage Tank Level Low Uncertainty and Setpoint
Calculation (E41-LSL-N002(3) Loops)
Calculation (E41-LSL-N002(3) Loops)
0E41-1001     High Pressure Coolant Injection System - Condensate     Rev. 3
Rev. 3
Storage Tank Level- Low Uncertainty And Setpoint
0E41-1001
High Pressure Coolant Injection System - Condensate
Storage Tank Level-Low Uncertainty And Setpoint
Calculation (E41-LSL-N002(3) LOOPS)
Calculation (E41-LSL-N002(3) LOOPS)
0E51-0028     Reactor Core Isolation Cooling System - Condensate       Rev. 3
Rev. 3
0E51-0028
Reactor Core Isolation Cooling System - Condensate
Storage Tank Level - Low Uncertainty And Scaling
Storage Tank Level - Low Uncertainty And Scaling
Calculation (E51-LSL-4463(4) LOOPS)
Calculation (E51-LSL-4463(4) LOOPS)
0EOP-WS-13.1   LPCI/RHR Vortex Limit (2 Pumps) Plus HPCI and RCIC       Rev. 6
Rev. 3
0EOP-WS-13.1
LPCI/RHR Vortex Limit (2 Pumps) Plus HPCI and RCIC
Vortex Determination
Vortex Determination
0RNA-0001     Instrument Air Nitrogen Backup System Volume             Rev. 4
Rev. 6
0RNA-0001
Instrument Air Nitrogen Backup System Volume
Requirements
Requirements
27-8-E41-06F NPSH Requirements - RCIC and HPCI                       Rev. 1
Rev. 4
ANP-3105NP     Brunswick Units 1 and 2 LOCA Break Spectrum Analysis for Rev. 1
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
ATRIUM 10XM Fuel for MELLLA+ Operation
BNP-E-1.012   Safety Related AC Control Loop Voltage Analysis         Rev. 9
Rev. 1
BNP-E-2.002   480V AC Safety Related MOVs Electrical Protection       Rev. 16
BNP-E-1.012
BNP-E-2.007   U2 480V Vital MCC Calculations                           Rev. 19
Safety Related AC Control Loop Voltage Analysis
BNP-E-6.085   Unit 2 125/250V DC Coordination/Protection Calculation   Rev. 7
Rev. 9
BNP-E-6.093   Unit 1 125/250V DC Coordination/Protection Calculation   Rev. 6
BNP-E-2.002
BNP-E-6.095   Unit 1 125/250V DC Coordination/Protection Calculation   Rev. 7
480V AC Safety Related MOVs Electrical Protection
BNP-E-6.120   125/250VDC System Battery Load Study                     Rev. 12
Rev. 16
BNP-E-6.121   Electrical Analysis for Safety Related DC Circuits       Rev. 10
BNP-E-2.007
BNP-E-7.002   AC Auxiliary Electrical Distribution System Voltage/Load Rev. 14
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
Flow/Fault Current Study
BNP-E-8.010   AC Coordination Study                                   Rev. 23
Rev. 14
Inspection Type             Designation     Description or Title                                       Revision or
BNP-E-8.010
Procedure                                                                                              Date
AC Coordination Study
BNP-E-8.010     AC Coordination Study                                     Rev. 24
Rev. 23  
BNP-E-8.014     Motor Torque Analysis for AC MOVs                         Rev. 18
 
BNP-MECH-1-     AOV Setup Calculation for 1-CAC-V216-AO                    Rev. 1
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
CAC-V216-AO
BNP-MECH-       Differential Pressure Calcualtions for 1/2-CAC-V7-AO, -V8- Rev. 0
AOV Setup Calculation for 1-CAC-V216-AO
AOV-DP-CAC      AO, -V216-AO Inboard Suppression Pool Purge Exhaust,
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
Outboard Suppression Pool Purge Exhaust, and Hardened
Wetwell Vent Isolation Air-Operated Valves
Wetwell Vent Isolation Air-Operated Valves
BNP-PSA-034,   Operator Action Summary Reports                            Rev. 17
Rev. 0
BNP-PSA-034,
Appendix C
Appendix C
M-89-0021       HPCI/RCIC NPSH with Suction from the CST                   Rev. 0
Operator Action Summary Reports
SA-E51-739     Stress Analysis for RCIC Exhaust Pipe Due to Water         Rev. 0
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
Hammer Loads
Corrective Action 02085737,
Rev. 0
Documents        02086053,
Corrective Action
Documents
2085737,
2086053,
27923-23,
27923-23,
2063268,
2063268,
Line 245: Line 367:
630621, 633538,
630621, 633538,
27745, 508592,
27745, 508592,
709200
709200  
Corrective Action AR 02287837     0CM-PVT500                                                 dated
 
Documents                                                                                    08/20/2019
Corrective Action
Resulting from    AR 02288218     DBAI 2019 - BNP-E-1.012 & 1.013 Not updated for 7.002     dated
Documents
Inspection                        Rev 14                                                     08/22/2019
Resulting from
AR 02288751     NRC Identified: Typographical Error Found in UFSAR         dated
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
08/26/2019
AR 02288836     MOV Hydraulic Lock Monitoring Program                     dated
AR 02288836
MOV Hydraulic Lock Monitoring Program
dated
08/26/2019
08/26/2019
AR 02289038     DBAI 2019 - BNP-E-8.013 & 8.014, Att. F Errors             dated
AR 02289038
DBAI 2019 - BNP-E-8.013 & 8.014, Att. F Errors
dated
08/27/2019
08/27/2019
AR 02289460     Revise BNP-E-7.002 Assumption 3.2.2.9                     dated
AR 02289460
08/29/2019
Revise BNP-E-7.002 Assumption 3.2.2.9
Inspection Type     Designation   Description or Title                                     Revision or
dated
Procedure                                                                                  Date
08/29/2019  
AR 02289996   Corrections to BNP-E-8.013 & BNP-E-8.014                 dated
 
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
09/03/2019
AR 02290331   2019 DBAI: 0BNP-TR-006 attachment 4 not updated           dated
AR 02290331
2019 DBAI: 0BNP-TR-006 attachment 4 not updated
dated
09/04/2019
09/04/2019
AR 02290559   Administrative Update to UFSAR Section 6.3.3.3           dated
AR 02290559
Administrative Update to UFSAR Section 6.3.3.3
dated
09/05/2019
09/05/2019
AR 02291132   2019 NRC DBAI: Conservatism in MOV motor torque           dated
AR 02291132
methodology                                               09/10/2019
2019 NRC DBAI: Conservatism in MOV motor torque
AR 02291159    HPCI and RCIC Overspeed Evaluation Discrepancies        dated
methodology
dated
09/10/2019
09/10/2019
AR 02291174  2019 DBAI - BNP response to IN 2013-17 did not fully eval dated
AR 02291159
HPCI and RCIC Overspeed Evaluation Discrepancies
dated
09/10/2019
09/10/2019
AR 02291176   2019 DBAI: Replacemnt of Program MOV sprng packs not     dated
AR 02291174
timely                                                    09/10/2019
2019 DBAI - BNP response to IN 2013-17 did not fully eval
AR 02291385   2019 NRC DBAI - Procedure Corrections - EGR-NGGC-         dated
dated
0106 & 0101                                               09/11/2019
09/10/2019
AR 02291396  2019 DBAI IST Program Document Issue                      dated
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
09/11/2019
AR 02291577   DBAI 2019 - BNP-E-8.013 & 8.014, Table G Errors         dated
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
09/12/2019
Drawings 0-FP-84314   8" Class 300 Wafer A31A Valve Assemby and Bettis N721-   Rev. B
Drawings
0-FP-84314
8" Class 300 Wafer A31A Valve Assemby and Bettis N721-
SR80 Fail Close Actuator
SR80 Fail Close Actuator
1-FP-05887,   Auto Depressurization System Elementary Diagram Unit 1    Rev. M
Rev. B
1-FP-05887,
Sheet 2
Sheet 2
D-02041       Service Water System Piping Diagram                       Rev. 66
Auto Depressurization System Elementary Diagram Unit 1
D-02523 Sh. 1 Reactor Building High Pressure Coolant Injection System   Rev. 59
Rev. M
D-02041
Service Water System Piping Diagram
Rev. 66
D-02523 Sh. 1
Reactor Building High Pressure Coolant Injection System
Piping Diagram
Piping Diagram
D-02523 Sh. 2 Reactor Building High Pressure Coolant Injection System   Rev. 53
Rev. 59
D-02523 Sh. 2
Reactor Building High Pressure Coolant Injection System
Piping Diagram
Piping Diagram
D-02529 Sh. 1 Reactor Building Reactor Core Isolation Cooling System   Rev. 64
Rev. 53
D-02529 Sh. 1
Reactor Building Reactor Core Isolation Cooling System
Piping Diagram
Piping Diagram
D-02529 Sh. 2 Reactor Building Reactor Core Isolation Cooling System   Rev. 46
Rev. 64
D-02529 Sh. 2
Reactor Building Reactor Core Isolation Cooling System
Piping Diagram
Piping Diagram
D-02537       Reactor Building Service Water System Piping Diagram     Rev. 99
Rev. 46
Inspection Type         Designation     Description or Title                                       Revision or
D-02537
Procedure                                                                                            Date
Reactor Building Service Water System Piping Diagram
D-70029         Reactor Building Instrument Air Supply System Piping       Rev. C
Rev. 99  
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
D-70029
Reactor Building Instrument Air Supply System Piping
Diagram
Diagram
F-03000         Main One Line Diagram 230KV and 24KV Systems               Rev. 40
Rev. C
F-03002         4160V System Switchgear One Line Diagram                   Rev. 33
F-03000
F-03003         4160V Emergency System Switchgear E3 & E4 One Line         Rev. 19
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
Diagram
F-03026         Emergency Key One Line Diagram                             Rev. 13
Rev. 19
F-03050         480V MCC 2XB One Line Diagram                             Rev. 94
F-03026
FSP-27059       Reactor Building, Unit 1 Hardened Wetwell Vent Piping     Rev. 2
Emergency Key One Line Diagram
LL-03024, Sht. 7 125-250 Volt DC System Control Building Distribution Panel Rev. 28
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"
4B - "H24"
LL-90046         CAC System Hardened Wetwell Vent Valve V216 Control       Rev. 1
Rev. 28
LL-90046
CAC System Hardened Wetwell Vent Valve V216 Control
Wiring Diagram
Wiring Diagram
Engineering   400921           Long Term Division II Load Management
Rev. 1
Changes      407321           Evaluation Of DC Load Profile And Battery Voltages
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
Following The Restoration Of DC Battery Chargers To The
DC System During A DBA (LOOP/LOCA)
DC System During A DBA (LOOP/LOCA)
411708           Reduce Loads On 125/250 VDC Switchboard 1B-1 and 1B-2
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 Revise 1st Minute Test Load in MST for 1A-1 1A-2, 1B-1
and 1B-2 Batteries
and 1B-2 Batteries
EC 276098
EC 276098  
EC 294259       Unit 1, Phase 1 & 2, Hardened Containment Vent System     Rev. 12
 
EC 294259
Unit 1, Phase 1 & 2, Hardened Containment Vent System
Upgrades in Repsonse to EA 12-109 (Mechanical)
Upgrades in Repsonse to EA 12-109 (Mechanical)
EC 298197       Acceptability of Shaft to Bowl Bearing Clearance and       Rev. 0
Rev. 12
EC 298197
Acceptability of Shaft to Bowl Bearing Clearance and
Impeller Wear Ring Clearance for 2C CSW Pump 2-SW-2C-
Impeller Wear Ring Clearance for 2C CSW Pump 2-SW-2C-
Conv-PMP
Conv-PMP
EC 299442
Rev. 0
EC 406293       Evaluation of Instrument Uncertainty Calculations not for Rev. 0
EC 299442  
 
EC 406293
Evaluation of Instrument Uncertainty Calculations not for
Limiting Safety System Settings or Automatic Protective
Limiting Safety System Settings or Automatic Protective
Functions
Functions
Engineering   ESR 96-00253    Service Water Pump Bearing Clearance Evaluation.          06/21/1999
Rev. 0
Engineering
Evaluations
Evaluations
Miscellaneous                 4KV Metal Clad Switchgear Template                         Rev. 4
ESR 96-00253
03FSAR-041       Licensing Document Change Request                         dated
Service Water Pump Bearing Clearance Evaluation.
Inspection Type Designation     Description or Title                                     Revision or
06/21/1999
Procedure                                                                                  Date
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
1/26/04
04FSAR-017       Licensing Document Change Request                         dated
04FSAR-017
Licensing Document Change Request
dated
7/14/04
7/14/04
04TSB-04         Licensing Document Revision Request                       Rev. 0
04TSB-04
238-044         Procurement of Product - Lubricated Service Water Pumps - Rev. 12
Licensing Document Revision Request
Rev. 0
238-044
Procurement of Product - Lubricated Service Water Pumps -
AL6XN
AL6XN
5170             System Health Report, Medium Voltage AC Distribution     Q2-2019
Rev. 12
AR 102456       Operability Determination                                 dated
5170
System Health Report, Medium Voltage AC Distribution
Q2-2019
AR 102456
Operability Determination
dated
8/28/03
8/28/03
CPL-01           TECHNICAL SPECIFICATION REVISION REQUEST                 dated
CPL-01
DEGRADED VOLTAGE RELAYS                                   06/29/1982
TECHNICAL SPECIFICATION REVISION REQUEST
CPL-02           ADEQUACY OF STATION ELECTRIC DISTRIBUTION                 dated
DEGRADED VOLTAGE RELAYS
SYSTEMS VOLTAGES                                         11/23/1982
dated
CSD-EG-BNP-     BNP IST Program Plan - 5th Interval                      Rev. 0
06/29/1982
CPL-02
ADEQUACY OF STATION ELECTRIC DISTRIBUTION
SYSTEMS VOLTAGES
dated
11/23/1982
CSD-EG-BNP-
20
20
DBD-51           DC Electrical System                                     Dated
BNP IST Program Plan - 5th Interval
Rev. 0
DBD-51
DC Electrical System
Dated
6/7/2017
6/7/2017
Docket 50-       Staff Positions Relative to Emergency Power Systems       dated
Docket 50-
25/50-324                                                                06/03/1977
25/50-324
EC 280671 Att. O HPCI and RCIC Pump Discharge Pressure Evaluation         Rev. 4
Staff Positions Relative to Emergency Power Systems
EC 412996       1-E11-F048B-MO (1B RHR HX BYPASS VLV) with an             Rev. 0
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
Aluminum Rotor Motor
EC 46911         HPCI Function Update                                     Rev. 0
Rev. 0
EC 54587         Basis for the 1(2)-E41-LSL-N002 and 1(2)-E41-LSL-N003     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
Setpoints
FP-82508         Bettis General Operating and Maintenance Instructions for Rev. D
Rev. 0
FP-82508
Bettis General Operating and Maintenance Instructions for
Pneumatic Rotary Valve Actuators
Pneumatic Rotary Valve Actuators
FP-84867         Technical Manual for Installation, Operation and         Rev. D
Rev. D
FP-84867
Technical Manual for Installation, Operation and
Maintenance of Johnston Pump Company 27CC - 2 Stage
Maintenance of Johnston Pump Company 27CC - 2 Stage
Service Water Pumps
Service Water Pumps
GD-79-3307       LESSONS LEARNED SHORT TERM REQUIREMENTS                   dated
Rev. D
GD-79-3307
LESSONS LEARNED SHORT TERM REQUIREMENTS
dated
2/31/1979
2/31/1979
GD-79-612       ON- SITE EMERGENCY POWER SYSTEMS                         dated
GD-79-612
03/06/1979
ON-SITE EMERGENCY POWER SYSTEMS
Inspection Type       Designation Description or Title                                       Revision or
dated
Procedure                                                                                    Date
03/06/1979  
JOG-TD-01   Spring Relaxation for Air Operators                       Rev. 2
 
LAP-83-551   REQUEST FOR ADDITIONAL INFORMATION                         dated
Inspection
ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES                   11/30/1983
Procedure
NEDC-32973P Safety Analysis Evaluations Relative to Measurement       Rev. 0
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
Uncertainties for the BWR/4
NLS-84-363   ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES                   dated
Rev. 0
NLS-84-363
ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES
dated
08/30/1984
08/30/1984
NLS-84-515   RESPONSE TO REQUEST FOR ADDITIONAL                         dated
NLS-84-515
INFORMATION: 1) ADEQUACY OF STATION ELECTRIC               01/18/1985
RESPONSE TO REQUEST FOR ADDITIONAL
INFORMATION: 1) ADEQUACY OF STATION ELECTRIC
SYSTEM VOLTAGE 2) TECHNICAL SPECIFICATIONS OF
SYSTEM VOLTAGE 2) TECHNICAL SPECIFICATIONS OF
DEGRADED VOLTAGE RELAYS
DEGRADED VOLTAGE RELAYS
NLS-85-321   AMENDMENT TO FACILITY OPERATING LICENSE                   dated
dated
01/18/1985
NLS-85-321
AMENDMENT TO FACILITY OPERATING LICENSE
dated
05/23/1985
05/23/1985
NLS89072     Letter - SAFER/GESTR-LOCA Analysis                         dated
NLS89072
Letter - SAFER/GESTR-LOCA Analysis
dated
3/29/89
3/29/89
NLU-80-338   SAFETY EVALUATION BY THE OFFICE OF NUCLEAR                 dated
NLU-80-338
REACTOR REGULATION SUPPORTING AMENDMENT                   06/11/1980
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR
REACTOR REGULATION SUPPORTING AMENDMENT
NO. 28 TO FACILITY LICENSE NO. DPR-71 AND
NO. 28 TO FACILITY LICENSE NO. DPR-71 AND
AMENDMENT NO. 51 TO FACILITY LICENSE NO. DPR-62
AMENDMENT NO. 51 TO FACILITY LICENSE NO. DPR-62
NLU-83-70   PLANT SHIELDING MODIFICATIONS, NUREG-0737 ITEM             dated
dated
II.B.2.2                                                   01/27/1983
06/11/1980
NO-80-1093   ADEQUACY OF STATION ELECTRICAL DISTRIBUTION               dated
NLU-83-70
SYSTEMS VOLTAGE                                           07/24/1980
PLANT SHIELDING MODIFICATIONS, NUREG-0737 ITEM
NRC89401     Letter - SAFER/GESTR-LOCA Analysis                         dated 6/1/89
II.B.2.2
PMCR 2063268 Modify Existing 125VDC Panel PMs to include Breaker       Dated
dated
Testing                                                    9/20/2016
01/27/1983
SPEC 248-164 Specification for Procurement of Class 2 Buttery Valve and Rev. 1
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
Spare Parts for Hardened Wetwell Vent Containment
Isolation.
Isolation.
TIA 2003-05 NRC Policy Questions on Technical Specification Adequacy   dated
Rev. 1
and Related Technical Specification Operability           1/16/04
TIA 2003-05
Procedures 0AOP-12.0   Loss of Uninterruptible Power Supply (UPS)                 Rev. 26
NRC Policy Questions on Technical Specification Adequacy
0AOP-39.0   Loss of DC Power                                           Rev. 47
and Related Technical Specification Operability
0AP-064     Time Critical Actions/Time Sensitive Actions Supplement   Rev. 5
dated
Inspection Type Designation   Description or Title                                   Revision or
1/16/04
Procedure                                                                              Date
Procedures
0CM-PVT500     Disassembly and Rebuild: Service Water Pump, Johnston   Rev. 35
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
Pump Company
0ENP-646       Post Test Evaluation of AOV Diagnostics                 Rev. 2
Rev. 35
0EOP-01-EDP   Emergency Depressurization                             Rev. 6
0ENP-646
0EOP-01-SBO-15 Primary Containment Isolation                           Rev. 1
Post Test Evaluation of AOV Diagnostics
0EOP-01-SEP-01 Primary Containment Venting                             Rev. 28
Rev. 2
0MST-ADS41BR ADS Loop B Logic Sys Functional and Simulated Auto       Rev. 3
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
Actuation Test
0PM-BKR-001   ITE 4KV Breaker and Compartment Checkout               Rev. 54
Rev. 3
0PM-RLY-033   Functional Testing of Thermal Overload Relays           Rev. 24
0PM-BKR-001
0PT-10.1.1     RCIC System Operability Test                           Rev. 107
ITE 4KV Breaker and Compartment Checkout
0PT-10.1.3     RCIC System Operability Test - Flow Rates at 150 PSIG   Rev. 60
Rev. 54
0PT-20.3       Local Leakrate Testing                                 Rev. 86
0PM-RLY-033
1MST-BAT11AR   125 VDC Battery 1A-1 Service Capacity Test             Rev. 8
Functional Testing of Thermal Overload Relays
1OP-19         High Pressure Coolant Injection System Operating       Rev. 99
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
Procedure
1OP-24         Containment Atmosphere Control System                   Rev. 110
Rev. 99
2EOP-01-RVCP   Reactor Vessel Control                                 Rev. 11
1OP-24
2MST-BAT11DR 125 VDC Battery 2B-2 Service Capacity Test               Rev. 7
Containment Atmosphere Control System
2PT-24.1-2     Service Water Pump and Discharge                       Rev. 86
Rev. 110
AD-EG-ALL-1117 Design Analyses and Calculations                       Rev. 5
2EOP-01-RVCP
AD-EG-ALL-1431 Air Operated Valve Scope and Categorization             Rev. 1
Reactor Vessel Control
AD-EG-ALL-1432 Air Operated Valve Design Basis Review                 Rev. 0
Rev. 11
AD-EG-ALL-1433 Air Operated Valve Testing Requirements                 Rev. 1
2MST-BAT11DR
AD-EG-ALL-1434 Air Operated Valve Tracking and Trending Requirements   Rev. 1
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
CAP-NGGC-0202 Operating Experience and Construction Experience Program Rev. 23
EGR-NGGC-     Electrical Calculation of Motor Output Torque for AC/DC Rev. 12
EGR-NGGC-
0101          MOVs
0101
EGR-NGGC-     AC/DC Overcurrent Protection and Coordination          Rev. 5
Electrical Calculation of Motor Output Torque for AC/DC
MOVs
Rev. 12
EGR-NGGC-
0106
0106
EGR-NGGC-     Air Operated Valve Reliability Program                  Rev. 10
AC/DC Overcurrent Protection and Coordination
Rev. 5
EGR-NGGC-
205
205
NGG-PMB-SOV- NGG Equipment Reliability Template SOlenoid Operated     Rev. 0
Air Operated Valve Reliability Program
Inspection Type       Designation Description or Title                         Revision or
Rev. 10
Procedure                                                                        Date
NGG-PMB-SOV-
NGG Equipment Reliability Template SOlenoid Operated
Rev. 0  
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Valves (SOV)
Valves (SOV)
SORMC-NUC-   System Operations Reference Manual Carolinas Rev. 24
SORMC-NUC-
050
050
Work Orders 12068756-01,
System Operations Reference Manual Carolinas
Rev. 24
Work Orders
2068756-01,
2068759-11,
2068759-11,
234502-01,
234502-01,
Line 461: Line 851:
1895617-01,
1895617-01,
20034690-01
20034690-01
18
}}
}}

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