IR 05000324/2019011: Difference between revisions
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
| (4 intermediate revisions by the same user not shown) | |||
| Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#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 | 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 | ===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 | 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. | ===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. | |||
==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: | |||
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) | ||
===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 | 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 | 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 | Inspection | ||
Procedure | |||
71111.21M Calculations 04KV-002 | 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 | Rev. 4 | ||
0B21-0199 | 0B21-0199 | ||
0BNP-TR-006 | ECCS Analysis Results | ||
0E41-1001 | 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 | 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 | 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 | Rev. 3 | ||
0EOP-WS-13.1 | |||
LPCI/RHR Vortex Limit (2 Pumps) Plus HPCI and RCIC | |||
Vortex Determination | Vortex Determination | ||
0RNA-0001 | Rev. 6 | ||
0RNA-0001 | |||
Instrument Air Nitrogen Backup System Volume | |||
Requirements | Requirements | ||
27-8-E41-06F NPSH Requirements - RCIC and HPCI | Rev. 4 | ||
ANP-3105NP | 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 | Rev. 1 | ||
BNP-E-2.002 | BNP-E-1.012 | ||
BNP-E-2.007 | Safety Related AC Control Loop Voltage Analysis | ||
BNP-E-6.085 | Rev. 9 | ||
BNP-E-6.093 | BNP-E-2.002 | ||
BNP-E-6.095 | 480V AC Safety Related MOVs Electrical Protection | ||
BNP-E-6.120 | Rev. 16 | ||
BNP-E-6.121 | BNP-E-2.007 | ||
BNP-E-7.002 | 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 | Rev. 14 | ||
Inspection Type | BNP-E-8.010 | ||
AC Coordination Study | |||
BNP-E-8.010 | Rev. 23 | ||
BNP-E-8.014 | |||
BNP-MECH-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- | 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 | Outboard Suppression Pool Purge Exhaust, and Hardened | ||
Wetwell Vent Isolation Air-Operated Valves | Wetwell Vent Isolation Air-Operated Valves | ||
BNP-PSA-034, | Rev. 0 | ||
BNP-PSA-034, | |||
Appendix C | Appendix C | ||
M-89-0021 | Operator Action Summary Reports | ||
SA-E51-739 | 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 | Rev. 0 | ||
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 | |||
Corrective Action | |||
Documents | |||
Resulting from | |||
AR 02288751 | 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 | AR 02288836 | ||
MOV Hydraulic Lock Monitoring Program | |||
dated | |||
08/26/2019 | 08/26/2019 | ||
AR 02289038 | AR 02289038 | ||
DBAI 2019 - BNP-E-8.013 & 8.014, Att. F Errors | |||
dated | |||
08/27/2019 | 08/27/2019 | ||
AR 02289460 | AR 02289460 | ||
08/29/2019 | Revise BNP-E-7.002 Assumption 3.2.2.9 | ||
Inspection Type | dated | ||
08/29/2019 | |||
AR 02289996 | |||
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 | AR 02290331 | ||
2019 DBAI: 0BNP-TR-006 attachment 4 not updated | |||
dated | |||
09/04/2019 | 09/04/2019 | ||
AR 02290559 | AR 02290559 | ||
Administrative Update to UFSAR Section 6.3.3.3 | |||
dated | |||
09/05/2019 | 09/05/2019 | ||
AR 02291132 | AR 02291132 | ||
methodology | 2019 NRC DBAI: Conservatism in MOV motor torque | ||
methodology | |||
dated | |||
09/10/2019 | 09/10/2019 | ||
AR | AR 02291159 | ||
HPCI and RCIC Overspeed Evaluation Discrepancies | |||
dated | |||
09/10/2019 | 09/10/2019 | ||
AR 02291176 | AR 02291174 | ||
2019 DBAI - BNP response to IN 2013-17 did not fully eval | |||
AR 02291385 | dated | ||
0106 & 0101 | 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 | 09/11/2019 | ||
AR 02291577 | 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 | 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, | Rev. B | ||
1-FP-05887, | |||
Sheet 2 | Sheet 2 | ||
D-02041 | Auto Depressurization System Elementary Diagram Unit 1 | ||
D-02523 Sh. 1 Reactor Building High Pressure Coolant Injection System | 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. 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. 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. 64 | ||
D-02529 Sh. 2 | |||
Reactor Building Reactor Core Isolation Cooling System | |||
Piping Diagram | Piping Diagram | ||
D-02537 | Rev. 46 | ||
Inspection Type | D-02537 | ||
Reactor Building Service Water System Piping Diagram | |||
D-70029 | 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 | Rev. C | ||
F-03002 | F-03000 | ||
F-03003 | 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 | Rev. 19 | ||
F-03050 | F-03026 | ||
FSP-27059 | Emergency Key One Line Diagram | ||
LL-03024, Sht. 7 | 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 | Rev. 28 | ||
LL-90046 | |||
CAC System Hardened Wetwell Vent Valve V216 Control | |||
Wiring Diagram | Wiring Diagram | ||
Engineering | 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 | Following The Restoration Of DC Battery Chargers To The | ||
DC System During A DBA (LOOP/LOCA) | DC System During A DBA (LOOP/LOCA) | ||
411708 | 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 | |||
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 | 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 | 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 | Rev. 0 | ||
Engineering | |||
Evaluations | Evaluations | ||
Miscellaneous | ESR 96-00253 | ||
03FSAR-041 | Service Water Pump Bearing Clearance Evaluation. | ||
Inspection Type Designation | 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 | 1/26/04 | ||
04FSAR-017 | 04FSAR-017 | ||
Licensing Document Change Request | |||
dated | |||
7/14/04 | 7/14/04 | ||
04TSB-04 | 04TSB-04 | ||
238-044 | Licensing Document Revision Request | ||
Rev. 0 | |||
238-044 | |||
Procurement of Product - Lubricated Service Water Pumps - | |||
AL6XN | AL6XN | ||
5170 | Rev. 12 | ||
AR 102456 | 5170 | ||
System Health Report, Medium Voltage AC Distribution | |||
Q2-2019 | |||
AR 102456 | |||
Operability Determination | |||
dated | |||
8/28/03 | 8/28/03 | ||
CPL-01 | CPL-01 | ||
DEGRADED VOLTAGE RELAYS | TECHNICAL SPECIFICATION REVISION REQUEST | ||
CPL-02 | DEGRADED VOLTAGE RELAYS | ||
SYSTEMS VOLTAGES | dated | ||
CSD-EG-BNP- | 06/29/1982 | ||
CPL-02 | |||
ADEQUACY OF STATION ELECTRIC DISTRIBUTION | |||
SYSTEMS VOLTAGES | |||
dated | |||
11/23/1982 | |||
CSD-EG-BNP- | |||
20 | 20 | ||
DBD-51 | BNP IST Program Plan - 5th Interval | ||
Rev. 0 | |||
DBD-51 | |||
DC Electrical System | |||
Dated | |||
6/7/2017 | 6/7/2017 | ||
Docket 50- | Docket 50- | ||
25/50-324 | |||
EC 280671 Att. O HPCI and RCIC Pump Discharge Pressure Evaluation | Staff Positions Relative to Emergency Power Systems | ||
EC 412996 | 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 | Rev. 0 | ||
EC 54587 | 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 | Rev. 0 | ||
FP-82508 | |||
Bettis General Operating and Maintenance Instructions for | |||
Pneumatic Rotary Valve Actuators | Pneumatic Rotary Valve Actuators | ||
FP-84867 | 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 | Rev. D | ||
GD-79-3307 | |||
LESSONS LEARNED SHORT TERM REQUIREMENTS | |||
dated | |||
2/31/1979 | 2/31/1979 | ||
GD-79-612 | GD-79-612 | ||
03/06/1979 | ON-SITE EMERGENCY POWER SYSTEMS | ||
Inspection Type | dated | ||
03/06/1979 | |||
JOG-TD-01 | |||
LAP-83-551 | Inspection | ||
ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES | Procedure | ||
NEDC-32973P | 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 | Rev. 0 | ||
NLS-84-363 | |||
ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES | |||
dated | |||
08/30/1984 | 08/30/1984 | ||
NLS-84-515 | NLS-84-515 | ||
INFORMATION: 1) ADEQUACY OF STATION ELECTRIC | 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 | dated | ||
01/18/1985 | |||
NLS-85-321 | |||
AMENDMENT TO FACILITY OPERATING LICENSE | |||
dated | |||
05/23/1985 | 05/23/1985 | ||
NLS89072 | NLS89072 | ||
Letter - SAFER/GESTR-LOCA Analysis | |||
dated | |||
3/29/89 | 3/29/89 | ||
NLU-80-338 | NLU-80-338 | ||
REACTOR REGULATION SUPPORTING AMENDMENT | 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 | dated | ||
II.B.2.2 | 06/11/1980 | ||
NO-80-1093 | NLU-83-70 | ||
SYSTEMS VOLTAGE | PLANT SHIELDING MODIFICATIONS, NUREG-0737 ITEM | ||
NRC89401 | II.B.2.2 | ||
PMCR 2063268 Modify Existing 125VDC Panel PMs to include Breaker | dated | ||
01/27/1983 | |||
SPEC 248-164 Specification for Procurement of Class 2 Buttery Valve and | 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 | Rev. 1 | ||
and Related Technical Specification Operability | TIA 2003-05 | ||
Procedures 0AOP-12.0 | NRC Policy Questions on Technical Specification Adequacy | ||
0AOP-39.0 | and Related Technical Specification Operability | ||
0AP-064 | dated | ||
Inspection Type Designation | 1/16/04 | ||
Procedures | |||
0CM-PVT500 | 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 | Rev. 35 | ||
0EOP-01-EDP | 0ENP-646 | ||
0EOP-01-SBO-15 Primary Containment Isolation | Post Test Evaluation of AOV Diagnostics | ||
0EOP-01-SEP-01 Primary Containment Venting | Rev. 2 | ||
0MST-ADS41BR ADS Loop B Logic Sys Functional and Simulated Auto | 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 | Rev. 3 | ||
0PM-RLY-033 | 0PM-BKR-001 | ||
0PT-10.1.1 | ITE 4KV Breaker and Compartment Checkout | ||
0PT-10.1.3 | Rev. 54 | ||
0PT-20.3 | 0PM-RLY-033 | ||
1MST-BAT11AR | Functional Testing of Thermal Overload Relays | ||
1OP-19 | 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 | Rev. 99 | ||
2EOP-01-RVCP | 1OP-24 | ||
2MST-BAT11DR | Containment Atmosphere Control System | ||
2PT-24.1-2 | Rev. 110 | ||
AD-EG-ALL-1117 Design Analyses and Calculations | 2EOP-01-RVCP | ||
AD-EG-ALL-1431 Air Operated Valve Scope and Categorization | Reactor Vessel Control | ||
AD-EG-ALL-1432 Air Operated Valve Design Basis Review | Rev. 11 | ||
AD-EG-ALL-1433 Air Operated Valve Testing Requirements | 2MST-BAT11DR | ||
AD-EG-ALL-1434 Air Operated Valve Tracking and Trending Requirements | 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- | EGR-NGGC- | ||
0101 | |||
EGR-NGGC- | Electrical Calculation of Motor Output Torque for AC/DC | ||
MOVs | |||
Rev. 12 | |||
EGR-NGGC- | |||
0106 | 0106 | ||
EGR-NGGC- | AC/DC Overcurrent Protection and Coordination | ||
Rev. 5 | |||
EGR-NGGC- | |||
205 | 205 | ||
NGG-PMB-SOV- NGG Equipment Reliability Template SOlenoid Operated | Air Operated Valve Reliability Program | ||
Inspection Type | 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) | Valves (SOV) | ||
SORMC-NUC- | SORMC-NUC- | ||
050 | 050 | ||
Work Orders | 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 | ||
}} | }} | ||
Latest revision as of 21:36, 2 January 2025
| ML19289B887 | |
| Person / Time | |
|---|---|
| Site: | Brunswick |
| 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:
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
- (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,
- 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
4.16kV Emergency Bus Degraded Grid Voltage Relay
Setpoint Calc
Rev. 4
ECCS Analysis Results
Rev. 8
ECCS Analysis Results
Rev. 8
MOV Design Basis Information GL-89-10 & GL-96-05
Rev. 6
High Pressure Coolant Injection System - Condensate
Storage Tank Level Low Uncertainty and Setpoint
Calculation (E41-LSL-N002(3) Loops)
Rev. 3
High Pressure Coolant Injection System - Condensate
Storage Tank Level-Low Uncertainty And Setpoint
Calculation (E41-LSL-N002(3) LOOPS)
Rev. 3
Reactor Core Isolation Cooling System - Condensate
Storage Tank Level - Low Uncertainty And Scaling
Calculation (E51-LSL-4463(4) LOOPS)
Rev. 3
LPCI/RHR Vortex Limit (2 Pumps) Plus HPCI and RCIC
Vortex Determination
Rev. 6
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
dated
08/20/2019
DBAI 2019 - BNP-E-1.012 & 1.013 Not updated for 7.002
Rev 14
dated
08/22/2019
NRC Identified: Typographical Error Found in UFSAR
dated
08/26/2019
MOV Hydraulic Lock Monitoring Program
dated
08/26/2019
DBAI 2019 - BNP-E-8.013 & 8.014, Att. F Errors
dated
08/27/2019
Revise BNP-E-7.002 Assumption 3.2.2.9
dated
08/29/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrections to BNP-E-8.013 & BNP-E-8.014
dated
09/03/2019
2019 DBAI: 0BNP-TR-006 attachment 4 not updated
dated
09/04/2019
Administrative Update to UFSAR Section 6.3.3.3
dated
09/05/2019
2019 NRC DBAI: Conservatism in MOV motor torque
methodology
dated
09/10/2019
HPCI and RCIC Overspeed Evaluation Discrepancies
dated
09/10/2019
2019 DBAI - BNP response to IN 2013-17 did not fully eval
dated
09/10/2019
2019 DBAI: Replacemnt of Program MOV sprng packs not
timely
dated
09/10/2019
2019 NRC DBAI - Procedure Corrections - EGR-NGGC-
0106 & 0101
dated
09/11/2019
2019 DBAI IST Program Document Issue
dated
09/11/2019
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
Unit 1, Phase 1 & 2, Hardened Containment Vent System
Upgrades in Repsonse to EA 12-109 (Mechanical)
Rev. 12
Acceptability of Shaft to Bowl Bearing Clearance and
Impeller Wear Ring Clearance for 2C CSW Pump 2-SW-2C-
Conv-PMP
Rev. 0
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
Licensing Document Change Request
dated
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1/26/04
Licensing Document Change Request
dated
7/14/04
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
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
1-E11-F048B-MO (1B RHR HX BYPASS VLV) with an
Aluminum Rotor Motor
Rev. 0
HPCI Function Update
Rev. 0
Basis for the 1(2)-E41-LSL-N002 and 1(2)-E41-LSL-N003
Setpoints
Rev. 0
Bettis General Operating and Maintenance Instructions for
Pneumatic Rotary Valve Actuators
Rev. D
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
Safety Analysis Evaluations Relative to Measurement
Uncertainties for the BWR/4
Rev. 0
ELECTRICAL DISTRIBUTION SYSTEM VOLTAGES
dated
08/30/1984
RESPONSE TO REQUEST FOR ADDITIONAL
INFORMATION: 1) ADEQUACY OF STATION ELECTRIC
SYSTEM VOLTAGE 2) TECHNICAL SPECIFICATIONS OF
DEGRADED VOLTAGE RELAYS
dated
01/18/1985
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
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
Time Critical Actions/Time Sensitive Actions Supplement
Rev. 5
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Disassembly and Rebuild: Service Water Pump, Johnston
Pump Company
Rev. 35
Post Test Evaluation of AOV Diagnostics
Rev. 2
Emergency Depressurization
Rev. 6
0EOP-01-SBO-15 Primary Containment Isolation
Rev. 1
Primary Containment Venting
Rev. 28
ADS Loop B Logic Sys Functional and Simulated Auto
Actuation Test
Rev. 3
ITE 4KV Breaker and Compartment Checkout
Rev. 54
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
25 VDC Battery 1A-1 Service Capacity Test
Rev. 8
High Pressure Coolant Injection System Operating
Procedure
Rev. 99
Containment Atmosphere Control System
Rev. 110
Reactor Vessel Control
Rev. 11
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
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