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Carolina Power and Light Company | Carolina Power and Light Company | ||
ATTN: Mr. Benjamin Waldrep | ATTN: Mr. Benjamin Waldrep | ||
Vice President | |||
Brunswick Steam Electric Plant | Brunswick Steam Electric Plant | ||
P. O. Box 10429 | P. O. Box 10429 | ||
Southport, NC 28461 | Southport, NC 28461 | ||
SUBJECT: | SUBJECT: | ||
BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION | |||
REPORT NOS. 05000324/2007005 AND 05000325/2007005 | |||
Dear Mr. Waldrep: | Dear Mr. Waldrep: | ||
On December 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an | On December 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an | ||
inspection at your Brunswick Units 1 and 2 facilities. The enclosed integrated inspection report | inspection at your Brunswick Units 1 and 2 facilities. The enclosed integrated inspection report | ||
documents the inspection findings, which were discussed on January 22, 2008, with you and | documents the inspection findings, which were discussed on January 22, 2008, with you and | ||
other members of your staff. | other members of your staff. | ||
The inspection examined activities conducted under your license as they relate to safety and | The inspection examined activities conducted under your license as they relate to safety and | ||
compliance with the Commissions rules and regulations and with the conditions of your license. | compliance with the Commissions rules and regulations and with the conditions of your license. | ||
The inspectors reviewed selected procedures and records, observed activities, and interviewed | The inspectors reviewed selected procedures and records, observed activities, and interviewed | ||
personnel. | personnel. | ||
| Line 39: | Line 40: | ||
and its enclosure will be available electronically for public inspection in the NRC Public | and its enclosure will be available electronically for public inspection in the NRC Public | ||
Document Room or from the Publicly Available Records (PARS) component of NRC's | Document Room or from the Publicly Available Records (PARS) component of NRC's | ||
document system (ADAMS). ADAMS is accessible from the NRC Web site at | document system (ADAMS). ADAMS is accessible from the NRC Web site at | ||
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | ||
Sincerely, | |||
/RA/ | |||
Randall A. Musser, Chief | |||
Reactor Projects Branch 4 | |||
Division of Reactor Projects | |||
Docket Nos.: | Docket Nos.: | ||
License Nos: | 50-325, 50-324 | ||
Enclosure: | License Nos: | ||
DPR-71, DPR-62 | |||
cc w/encl: (See page 2) | Enclosure: | ||
Inspection Report 05000325, 324/2007005 | |||
w/Attachment: Supplemental Information | |||
cc w/encl: (See page 2) | |||
OFFICE | |||
RII:DRP | |||
RII:DRP | |||
RII:DRP | |||
RII:DRS | |||
RII:DRS | |||
RII:DRS | |||
RII:DRS | |||
SIGNATURE | |||
/RA/ | |||
/RA By e-mail/ | |||
/RA by e-mail/ | |||
/RA/ | |||
NAME | |||
R Musser | |||
J Austin | |||
S Rutledge | |||
G Wilson | |||
DATE | |||
1/29/08 | |||
1/30/08 | |||
1/30/08 | |||
1/29/08 | |||
E-MAIL COPY? | |||
YES | |||
NO YES | |||
NO YES | |||
NO YES | |||
NO YES | |||
NO YES | |||
NO YES | |||
NO | |||
CP&L | 2 | ||
CP&L | |||
cc w/encl: | cc w/encl: | ||
Director, Site Operations | Director, Site Operations | ||
Brunswick Steam Electric Plant | Brunswick Steam Electric Plant | ||
Carolina Power & Light Company | Carolina Power & Light Company | ||
Electronic Mail Distribution | Electronic Mail Distribution | ||
J. Paul Fulford, Manager | J. Paul Fulford, Manager | ||
Performance Evaluation and | Performance Evaluation and | ||
Regulatory Affairs PEB 5 | |||
Carolina Power & Light Company | Carolina Power & Light Company | ||
Electronic Mail Distribution | |||
Terry D. Hobbs, Plant General Manager | Terry D. Hobbs, Plant General Manager | ||
Brunswick Steam Electric Plant | Brunswick Steam Electric Plant | ||
Carolina Power & Light Company | Carolina Power & Light Company | ||
P. O. Box 10429 | P. O. Box 10429 | ||
Southport, NC 28461 | Southport, NC 28461 | ||
Donald L. Griffith | |||
Donald L. Griffith | Manager - Training | ||
Manager - Training | Progress Energy Carolinas, Inc. | ||
Progress Energy Carolinas, Inc. | |||
Brunswick Steam Electric Plant | Brunswick Steam Electric Plant | ||
Electronic Mail Distribution | Electronic Mail Distribution | ||
Randy C. Ivey | |||
Randy C. Ivey | Manager - Support Services | ||
Manager - Support Services | Progress Energy Carolinas, Inc. | ||
Progress Energy Carolinas, Inc. | |||
Brunswick Steam Electric Plant | Brunswick Steam Electric Plant | ||
Electric Mail Distribution | Electric Mail Distribution | ||
Garry D. Miller, Manager | |||
Garry D. Miller, Manager | License Renewal | ||
License Renewal | |||
Progress Energy | Progress Energy | ||
Electronic Mail Distribution | Electronic Mail Distribution | ||
Annette H. Pope, Supervisor | |||
David T. Conley | Licensing/Regulatory Programs | ||
Associate General Counsel - Legal Dept. | Carolina Power and Light Company | ||
Progress Energy Service Company, LLC | Electronic Mail Distribution | ||
Electronic Mail Distribution | David T. Conley | ||
Associate General Counsel - Legal Dept. | |||
James Ross | Progress Energy Service Company, LLC | ||
Electronic Mail Distribution | |||
James Ross | |||
Nuclear Energy Institute | Nuclear Energy Institute | ||
Electronic Mail Distribution | Electronic Mail Distribution | ||
John H. O'Neill, Jr. | |||
Shaw, Pittman, Potts & Trowbridge | |||
2300 N. Street, NW | |||
Washington, DC 20037-1128 | |||
Beverly Hall, Chief, Radiation | |||
Protection Section | |||
N. C. Department of Environment | |||
and Natural Resources | |||
Electronic Mail Distribution | |||
Peggy Force | |||
Assistant Attorney General | |||
State of North Carolina | |||
Electronic Mail Distribution | |||
Chairman of the North Carolina | |||
Utilities Commission | |||
c/o Sam Watson, Staff Attorney | |||
Electronic Mail Distribution | |||
Robert P. Gruber | |||
Executive Director | |||
Public Staff NCUC | |||
4326 Mail Service Center | |||
Raleigh, NC 27699-4326 | |||
Public Service Commission | |||
State of South Carolina | |||
P. O. Box 11649 | |||
Columbia, SC 29211 | |||
David R. Sandifer | |||
Brunswick County Board of | |||
Commissioners | |||
P. O. Box 249 | |||
Bolivia, NC 28422 | |||
Warren Lee | |||
Emergency Management Director | |||
New Hanover County Department of | |||
Emergency Management | |||
230 Government Center Drive | |||
Suite 115 | |||
Wilmington, NC 28403 | |||
CP&L | 3 | ||
CP&L | |||
Report to Ben Waldrep from Randall A. Musser dated January 29, 2008 | Report to Ben Waldrep from Randall A. Musser dated January 29, 2008 | ||
SUBJECT: | SUBJECT: | ||
BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION | |||
REPORT NOS. 05000324/2007005 AND 05000325/2007005 | |||
Distribution w/encl: | Distribution w/encl: | ||
S. Bailey, NRR | S. Bailey, NRR | ||
R. Pascarelli, NRR | R. Pascarelli, NRR | ||
C. Evans, RII | C. Evans, RII | ||
L. Slack, RII | L. Slack, RII | ||
RIDSNRRDIRS | RIDSNRRDIRS | ||
OE Mail | OE Mail | ||
| Line 123: | Line 189: | ||
U.S. Nuclear Regulatory Commission | U.S. Nuclear Regulatory Commission | ||
8470 River Road, SE | 8470 River Road, SE | ||
Southport, NC 28461 | Southport, NC 28461 | ||
Enclosure | |||
U. S. NUCLEAR REGULATORY COMMISSION | |||
Docket Nos: | REGION II | ||
License Nos: | Docket Nos: | ||
Report Nos: | 50-325, 50-324 | ||
Licensee: | License Nos: | ||
Facility: | DPR-71, DPR-62 | ||
Location: | Report Nos: | ||
05000325/2007005 and 05000324/2007005 | |||
Dates: | Licensee: | ||
Inspectors: | Carolina Power and Light (CP&L) | ||
Facility: | |||
Approved by: | Brunswick Steam Electric Plant, Units 1 & 2 | ||
Location: | |||
8470 River Road SE | |||
Southport, NC 28461 | |||
Dates: | |||
October 1, 2007 through December 31, 2007 | |||
Inspectors: | |||
J. Austin, Senior Resident Inspector | |||
S. Rutledge, Resident Inspector | |||
Approved by: | |||
Randall A. Musser, Chief | |||
Reactor Projects Branch 4 | |||
Division of Reactor Projects | |||
Enclosure | |||
SUMMARY OF FINDINGS | |||
IR 05000325/2007005, 05000324/2007005; 10/01/07- 12/31/07; Brunswick Steam | |||
Electric Plant, Units 1 and 2. | |||
The report covered a 3-month period of inspection by resident inspectors and one senior | |||
reactor inspector. One Green non-cited violation (NCV) was identified. The significance | |||
of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection | |||
Manual Chapter (IAC) 0609, Significance Determination Process (SDP). The NRC's | |||
program for overseeing the safe operation of commercial nuclear power reactors is | |||
described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December | |||
A. NRC-Identified and Self-Revealing Findings | 2006. | ||
A. | |||
B. Licensee-Identified Findings | NRC-Identified and Self-Revealing Findings | ||
NONE | |||
B. | |||
Licensee-Identified Findings | |||
NONE | |||
Enclosure | |||
REPORT DETAILS | |||
Summary of Plant Status | Summary of Plant Status | ||
Unit 1 | Unit 1 | ||
Unit 1 began the inspection period operating at full power. On October 6, power was | Unit 1 began the inspection period operating at full power. On October 6, power was | ||
reduced to 93 percent to perform a control rod improvement. The unit was restored to | reduced to 93 percent to perform a control rod improvement. The unit was restored to | ||
full power the same day. On October 13, power was reduced to 93 percent to perform a | full power the same day. On October 13, power was reduced to 93 percent to perform a | ||
control rod improvement. The unit was returned to full power the same day. On | control rod improvement. The unit was returned to full power the same day. On | ||
October 20, power was reduced to 93 percent to perform a control rod improvement. | October 20, power was reduced to 93 percent to perform a control rod improvement. | ||
Full power was restored the same day. On October 27, power was reduced to 93 | Full power was restored the same day. On October 27, power was reduced to 93 | ||
percent to perform a control rod improvement. Full power was achieved later that day. | percent to perform a control rod improvement. Full power was achieved later that day. | ||
On November 3, power was reduced to 67 percent to facilitate valve testing. The unit | On November 3, power was reduced to 67 percent to facilitate valve testing. The unit | ||
was returned to full power later that day. On November 4, power was reduced to 95 | was returned to full power later that day. On November 4, power was reduced to 95 | ||
percent to perform a control rod improvement. Full power was restored on November 5. | percent to perform a control rod improvement. Full power was restored on November 5. | ||
On November 11, power was reduced to 90 percent to perform a control rod | On November 11, power was reduced to 90 percent to perform a control rod | ||
improvement. Full power was achieved later that day. On November 16, power was | improvement. Full power was achieved later that day. On November 16, power was | ||
reduced to 91 percent to perform a control rod improvement. The unit was returned to | reduced to 91 percent to perform a control rod improvement. The unit was returned to | ||
full power November 17. On November 24, power was reduced to 90 percent for control | full power November 17. On November 24, power was reduced to 90 percent for control | ||
rod testing. Full power was restored later that day. The unit remained at full power for | rod testing. Full power was restored later that day. The unit remained at full power for | ||
the remainder of the inspection period. | the remainder of the inspection period. | ||
Unit 2 | Unit 2 | ||
Unit 2 began the inspection period operating at full power. On October 1, a power | Unit 2 began the inspection period operating at full power. On October 1, a power | ||
ascension occurred from main turbine valve testing. Full power was restored later that | ascension occurred from main turbine valve testing. Full power was restored later that | ||
day. On October 1, power was reduced to 95 percent to perform a control rod | day. On October 1, power was reduced to 95 percent to perform a control rod | ||
improvement. Full power was restored later that day. On October 1, power was | improvement. Full power was restored later that day. On October 1, power was | ||
reduced to 96 percent to perform a control rod improvement. The unit was returned to | reduced to 96 percent to perform a control rod improvement. The unit was returned to | ||
full power later that day. On October 2, power was reduced to 98 percent to perform a | full power later that day. On October 2, power was reduced to 98 percent to perform a | ||
control rod improvement. Full power was restored later that day. On November 8, | control rod improvement. Full power was restored later that day. On November 8, | ||
power was reduced to 71 percent for a Whiteville line outage. Power was returned to | power was reduced to 71 percent for a Whiteville line outage. Power was returned to | ||
full later that day. On November 9, power was reduced to 98 percent for a control rod | full later that day. On November 9, power was reduced to 98 percent for a control rod | ||
improvement. Full power was restored later that day. On November 17, power was | improvement. Full power was restored later that day. On November 17, power was | ||
reduced to 68 percent for main turbine valve, reactor feed pump and scram time testing. | reduced to 68 percent for main turbine valve, reactor feed pump and scram time testing. | ||
The unit was returned to full power on November 18. On November 18, power was | The unit was returned to full power on November 18. On November 18, power was | ||
reduced to 94 percent for xenon build-up following main turbine valve testing and control | reduced to 94 percent for xenon build-up following main turbine valve testing and control | ||
rod sequence exchange. Full power was returned on November 19. On November 19, | rod sequence exchange. Full power was returned on November 19. On November 19, | ||
power was reduced to 85 percent to perform a control rod improvement. Full power was | power was reduced to 85 percent to perform a control rod improvement. Full power was | ||
restored November 20. On November 20, power was reduced to 95 percent to perform | restored November 20. On November 20, power was reduced to 95 percent to perform | ||
a control rod improvement. Full power was achieved November 21, 2007. The unit | a control rod improvement. Full power was achieved November 21, 2007. The unit | ||
remained at full power for the remainder of the inspection period. | remained at full power for the remainder of the inspection period. | ||
3 | |||
1. | Enclosure | ||
1. | |||
1R01 Adverse Weather Protection | REACTOR SAFETY | ||
a. Inspection Scope | Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity | ||
1R01 | |||
Adverse Weather Protection | |||
a. | |||
Inspection Scope | |||
The inspectors assessed the effectiveness of the licensees cold weather protection | |||
program as it related to ensuring that the facilitys service water pumps, emergency | |||
diesel generators, and condensate storage tank low level switches would remain | |||
functional and available in cold weather conditions. In addition to reviewing the | |||
licensees program-related documents and procedures, walkdowns were conducted of | |||
the freeze protection equipment (e.g., heat tracing, area space heaters, etc.) associated | |||
with the above systems/components. Licensee problem identification and resolution | |||
b. Findings | associated with cold weather protections was also assessed. | ||
* | |||
1R04 Equipment Alignment | AR 246713, Unit 2 condensate storage tank heat trace inoperable | ||
.1 | * | ||
a. Inspection Scope | AR 253047, Emergency diesel generator #1 jacket water heater temperature | ||
switch | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
1R04 | |||
Equipment Alignment | |||
.1 | |||
Partial System Walkdowns | |||
a. | |||
Inspection Scope | |||
The inspectors performed three partial walkdowns of the below-listed systems to verify | |||
that the systems were correctly aligned while the redundant train or system was | |||
inoperable or out-of-service (OOS) or, for single train risk significant systems, while the | |||
system was available in a standby condition. The inspectors assessed conditions such | |||
as equipment alignment (i.e., valve positions, damper positions, and breaker alignment) | |||
and system operational readiness (i.e., control power and permissive status) that could | |||
affect operability. The inspectors verified that the licensee identified and resolved | |||
equipment alignment problems that could cause initiating events or impact mitigating | |||
system availability. The inspectors reviewed Administrative Procedure | |||
ADM-NGGC-0106, Configuration Management Program Implementation, to verify that | |||
available structures, systems or components (SSCs) met the requirements of the | |||
configuration control program. Documents reviewed are listed in the Attachment. | |||
* | |||
2A Nuclear service water pump when the 2B nuclear service water pump was | |||
OOS for scheduled maintenance on October 3, 2007 | |||
4 | |||
Enclosure | |||
* | |||
Unit 2 RCIC when the Unit 2 HPCI was OOS for seal repair on October 15, 2007 | |||
* | |||
EDG #2, #3, and #4 while EDG #1 was OOS for scheduled maintenance on | |||
November 19, 2007 | |||
To assess the licensees ability to identify and correct problems, the inspectors reviewed | |||
the following Action Requests (ARs): | |||
* | |||
AR 251684, RCIC extent of condition evaluation using Panametrics | |||
* | |||
AR 252203, U2 RCIC seal purge line orifice missing | |||
* | |||
.2 | AR 259682, U1 RCIC steam supply drain pot steam leak | ||
* | |||
AR 254033, EDG starting air pilot air lines support discrepancies | |||
* | |||
AR 254280, EDG #3 brush inspection meg readings | |||
* | |||
AR 259504, EDG #1 generator vibration alarm | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
.2 | |||
Complete System Walkdown | |||
a. | |||
Inspection Scope | |||
The inspectors conducted a detailed review of the alignment and condition of the Unit 2 | |||
high pressure coolant injection system. The inspector reviewed the Updated Final | |||
Safety Analysis Report, associated attachments of Operating Procedure 2OP-19, High | |||
Pressure Coolant Injection System Operating Procedure, 0PT-09.2, HPCI System | |||
Operability Test and the systems diagrams (drawing numbers D-02523 and LL-09272) | |||
in determining correct system lineup. The inspectors also reviewed maintenance history | |||
of the system. | |||
To assess the licensees identification and resolutions of problems, the inspectors | |||
reviewed the following: | |||
* | |||
AR 250203, HPCI inoperable due to pump seal leakage | |||
* | |||
AR 225856, HPCI lube oil coolers debris | |||
* | |||
AR 229349, HPCI condensate pump trip | |||
* | |||
AR 251647, U2 HPCI vacuum tank level issues | |||
* | |||
AR 251490, Water in U2 HPCI lube oil | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
5 | |||
1R05 Fire Protection | Enclosure | ||
.1 | 1R05 | ||
a. Inspection Scope | Fire Protection | ||
.1 | |||
Fire Area Walkdowns | |||
a. | |||
Inspection Scope | |||
The inspectors reviewed ARs and work orders (WOs) associated with the fire | |||
suppression system to confirm that their disposition was in accordance with Procedure | |||
0AP-033, Fire Protection Program Manual. The inspectors reviewed the status of | |||
ongoing surveillance activities to verify that they were current to support the operability | |||
of the fire protection system. In addition, the inspectors observed the fire suppression | |||
and detection equipment to determine whether any conditions or deficiencies existed | |||
which would impair the operability of that equipment. The inspectors toured the | |||
following six areas important to reactor safety and reviewed the associated prefire plans | |||
to verify that the requirements for fire protection design features, fire area boundaries, | |||
b. Findings | and combustible loading were met. Documents reviewed are listed in the Attachment. | ||
* | |||
.2 | Units 1 and 2 Control Building, - 49' elevation (2 areas) | ||
a. Inspection Scope | * | ||
Units 1 and 2 Control Building, - 23' elevation (2 areas) | |||
* | |||
Units 1 and 2 Reactor Building - 17' elevation (2 areas) | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
.2 | |||
Fire Drill | |||
a. | |||
Inspection Scope | |||
b. Findings | On October 6, 2007, the inspectors observed a plant fire drill at the auxiliary boiler unit | ||
located outside near the Emergency Diesel Generator Building, to assess the fire | |||
brigade performance and to verify that proper firefighting techniques for the type of fire | |||
encountered were utilized. The inspectors monitored the fire brigades use of protective | |||
equipment and firefighting equipment to verify that preplanned firefighting procedures | |||
and appropriate firefighting techniques were used, and to verify that the directions of the | |||
fire brigade leader were thorough, clear, and effective. The inspectors attended the | |||
critique to confirm that appropriate feedback on performance was provided to brigade | |||
members and to ensure that areas for improvement were properly identified for licensee | |||
follow-up. In preparing for the drill, the inspectors reviewed the preplanned drill | |||
scenario, Brunswick Nuclear Plant Drill Scenario Guide, 99-F-0S, Revision 1. | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
6 | |||
1R06 Flood Protection Measures | Enclosure | ||
.1 | 1R06 | ||
a. Inspection Scope | Flood Protection Measures | ||
.1 | |||
Internal Flooding | |||
a. | |||
Inspection Scope | |||
The inspectors reviewed the licensees internal flooding analysis as described in | |||
Updated Final Safety Analysis Report (UFSAR) Section 3.4.2, Protection From Internal | |||
Flooding. Due to the risk significance of equipment in the Service Water and | |||
Emergency Diesel Generator Buildings, the inspectors reviewed UFSAR Section 3.4.2 | |||
analysis of the effects of postulated piping failures for these two areas to determine if | |||
the analysis assumptions and conclusions were based on the current plant | |||
configuration. The internal flooding design features and equipment for coping with | |||
b. Findings | internal flooding was inspected for the equipment located in these buildings. The | ||
walkdown included sources of flooding and drainage, sump pumps, level switches, | |||
.2 | watertight doors, curbs, pedestals and equipment mounting. Documents reviewed are | ||
a. Inspection Scope | listed in the Attachment. | ||
b. Findings | |||
No findings of significance were identified. | |||
.2 | |||
External Flooding | |||
a. | |||
Inspection Scope | |||
The inspectors reviewed the licensees external flooding analysis as described in | |||
UFSAR Section 3.4.1, Protection from External Flooding, to determine the external flood | |||
control design features. Walkdowns were conducted to inspect the external flood | |||
protection barriers including watertight doors, curbs, sealing of external building | |||
b. Findings | penetrations below flood line, and the sump pumps and level alarm circuits. Areas | ||
reviewed included the Emergency Diesel Generator Building, and the Service Water | |||
Building. The inspector reviewed the procedures for coping with external flooding | |||
contained in Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During | |||
Hurricane, Flood Conditions, Tornado, or Earthquake. Other documents reviewed are | |||
listed in the Attachment. | |||
b. Findings | |||
No findings of significance were identified. | |||
7 | |||
1R11 Licensed Operator Requalification | Enclosure | ||
.1 | 1R11 | ||
a. Inspection Scope | Licensed Operator Requalification | ||
.1 | |||
Quarterly Review | |||
a. | |||
Inspection Scope | |||
The inspectors observed licensed operator performance and reviewed the associated | |||
training documents during annual dynamic simulator examination sessions for training | |||
cycle 2007-05. The simulator observations and review included evaluations of | |||
emergency operating procedure and abnormal operating procedure utilization. The | |||
inspectors reviewed Procedure 0TPP-200, Licensed Operator Continuing Training | |||
Program, to verify that the program ensures safe power plant operation. Simulator | |||
sessions were observed on November 20, 2007. The scenarios tested the operators | |||
ability to respond to secondary plant failures, loss of emergency power, and an | |||
automatic trip without a scram followed by a rupture of the scram discharge volume. | |||
The inspectors reviewed operator activities to verify consistent clarity and formality of | |||
communication, conservative decision-making by the crew, appropriate use of | |||
procedures, and proper alarm response. Group dynamics and supervisory oversight, | |||
including the ability to properly identify and implement appropriate Technical | |||
b. Findings | Specification (TS) actions, regulatory reports, and notifications, were observed. The | ||
inspectors observed instructor critiques and preliminary grading of the operating crews | |||
1R12 Maintenance Effectiveness | and assessed whether appropriate feedback was planned to be provided to the licensed | ||
a. Inspection Scope | operators. | ||
b. | |||
Findings | |||
No findings of significance were identified. | |||
1R12 | |||
Maintenance Effectiveness | |||
a. | |||
Inspection Scope | |||
For the two equipment issues described in the ARs listed below, the inspectors reviewed | |||
the licensees implementation of the Maintenance Rule (10 CFR 50.65) with respect to | |||
the characterization of failures, the appropriateness of the associated Maintenance Rule | |||
a(1) or a(2) classification, and the appropriateness of the associated a(1) goals and | |||
corrective actions. The inspectors reviewed the work controls and work practices | |||
associated with the degraded performance or condition to verify that they were | |||
appropriate and did not contribute to the issue. The inspectors also reviewed operations | |||
logs and licensee event reports to verify unavailability times of components and | |||
systems, if applicable. Licensee performance was evaluated against the requirements | |||
of Procedure ADM-NGGC-0101, Maintenance Rule Program. | |||
* | |||
AR 242066, BNP response to operating experience 2007-08 degradation of | |||
buried piping | |||
* | |||
AR 256103, Loss of full out indications on the full core display | |||
8 | |||
Enclosure | |||
b. | |||
1R13 Maintenance Risk Assessments and Emergent Work Evaluation | Findings | ||
No findings of significance were identified. | |||
1R13 | |||
Maintenance Risk Assessments and Emergent Work Evaluation | |||
a. | |||
Inspection Scope | |||
The inspectors reviewed the licensees implementation of 10 CFR 50.65 (a)(4) | |||
requirements during scheduled and emergent maintenance activities, using Procedure | |||
0AP-025, BNP Integrated Scheduling and Technical Requirements Manual 5.5.13, | |||
Configuration Risk Management Program. The inspectors reviewed the effectiveness of | |||
risk assessments performed due to changes in plant configuration for maintenance | |||
activities (planned and emergent). The review was conducted to verify that, upon | |||
unforseen situations, the licensee had taken the necessary steps to plan and control the | |||
resultant emergent work activities. The inspectors reviewed the applicable plant risk | |||
profiles, work week schedules, and maintenance WOs for the following five conditions: | |||
* | |||
AR 250203, HPCI inoperable due to pump seal leakage | |||
* | |||
AR 255545, Unexpected annunciators during performance test (PT-12.2a) for | |||
EDG #1 | |||
* | |||
1R15 Operability Evaluations | AR 257721, Unit 1 condensate storage tank instrumental vent line excessive | ||
sloping | |||
* | |||
AR 257744, EDG #3 jacket water leakage from flexmaster jumpers | |||
* | |||
AR 256079, 1-E11-F017B inoperable due to high energy line break issues at the | |||
motor control cubicle compartment | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
1R15 | |||
Operability Evaluations | |||
a. | |||
Inspection Scope | |||
The inspectors reviewed the operability evaluations associated with the six issues | |||
documented in the ARs listed below, which affected risk significant systems or | |||
components, to assess, as appropriate: 1) the technical adequacy of the evaluations; 2) | |||
the justification of continued system operability; 3) any existing degraded conditions | |||
used as compensatory measures; 4) the adequacy of any compensatory measures in | |||
place, including their intended use and control; and 5) where continued operability was | |||
considered unjustified, the impact on any TS limiting condition for operation and the risk | |||
significance. In addition to the reviews, discussions were conducted with the applicable | |||
system engineer regarding the ability of the system to perform its intended safety | |||
function. | |||
9 | |||
Enclosure | |||
* | |||
AR 249130, 1A Residual heat removal heat exchanger degradation during | |||
testing (OPF08.1.4A) | |||
* | |||
AR 245864, E-4 Loss of coolant accident logic relay 27E2 de-energized | |||
b. Findings | * | ||
AR 250793, Unit 2 RCIC operability concern | |||
1R19 Post-Maintenance Testing | * | ||
a. Inspection Scope | AR 252203, Unit 2 RCIC seal purge line orifice missing | ||
* | |||
AR 251885, Unit 2 HPCI main pump seal leak exceeds posting | |||
* | |||
AR 251490, Water in Unit 2 HPCI lube oil | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
1R19 | |||
Post-Maintenance Testing | |||
a. | |||
Inspection Scope | |||
For the five maintenance activities listed below, the inspectors reviewed the post- | |||
b. Findings | maintenance test procedure and witnessed the testing and/or reviewed test records to | ||
confirm that the scope of testing adequately verified that the work performed was | |||
1R22 Surveillance Testing | correctly completed. The inspectors verified that the test demonstrated that the affected | ||
.1 | equipment was capable of performing its intended function and was operable in | ||
a. Inspection Scope | accordance with TS requirements. The inspectors reviewed the licensees actions | ||
against the requirements in Procedure 0PLP-20, Post Maintenance Testing Program. | |||
* | |||
PT 9.2 HPCI Operability Test following inboard seal failure | |||
* | |||
WO 114145 RCIC system fill and vent after pump maintenance | |||
* | |||
WO 1137349 Inspection of HPCI sump after drain down | |||
* | |||
AR 250499, Basis for changing piping test plan not understood | |||
* | |||
AR 247456, Balance of plant under-voltage relays not tested as required | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
1R22 | |||
Surveillance Testing | |||
.1 | |||
Routine Surveillance Testing | |||
a. | |||
Inspection Scope | |||
The inspectors either observed surveillance tests or reviewed test data for the three risk | |||
significant SSC surveillances, listed below, to verify the tests met TS surveillance | |||
requirements, UFSAR commitments, in-service testing (IST) requirements, and licensee | |||
procedural requirements. The inspectors assessed the effectiveness of the tests in | |||
demonstrating that the SSCs were operationally capable of performing their intended | |||
safety functions. | |||
10 | |||
Enclosure | |||
* | |||
0PT-09.2mst-HPCI 23Q, High Pressure Coolant Injection System operability test, | |||
performed on Unit 2 on October 22, 2007 | |||
* | |||
2O1-03.2, Control Operator Daily Surveillance Report (including drywell leakage | |||
b. Findings | rate determination), performed the week of November 12, 2007. | ||
C | |||
.2 | 0PT-9.3a, High Pressure Coolant Injection System Component Test, performed | ||
a. Inspection Scope | on Unit 1 on December 7, 2007. | ||
b. | |||
Findings | |||
No findings of significance were identified. | |||
.2 | |||
In-service Surveillance Testing | |||
a. | |||
Inspection Scope | |||
The inspectors reviewed the performance of Periodic Test 0PT-9.7, High Pressure | |||
Coolant Injection System Valve Operability Test, performed on Unit 1 on December 7, | |||
2007. The inspectors evaluated the effectiveness of the licensees American Society of | |||
Mechanical Engineers (ASME) Section XI testing program to determine equipment | |||
availability and reliability. The inspectors evaluated selected portions of the following | |||
b. Findings | areas: 1) testing procedures; 2) acceptance criteria; 3) testing methods; 4) compliance | ||
with the licensees IST program, TS, selected licensee commitments, and code | |||
1EP6 Drill Evaluation | requirements; 5) range and accuracy of test instruments; and 6) required corrective | ||
a. Inspection Scope | actions. The inspectors also assessed any applicable corrective actions taken. | ||
To assess the licensees ability to identify and correct problems, the inspector reviewed | |||
AR 214876 which documented that the Unit 1 A conventional service water pump was | |||
discovered to be in the Alert range following testing on November 30, 2006. | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
1EP6 | |||
Drill Evaluation | |||
a. | |||
Inspection Scope | |||
The inspectors observed site emergency preparedness training drill/simulator scenarios | |||
conducted on October 30, 2007 and November 8, 2007. The inspectors reviewed the | |||
drill scenario narrative to identify the timing and location of classifications, notifications, | |||
and protective action recommendations development activities. The inspectors | |||
evaluated the drill conduct from the control room simulator, technical support center, | |||
and the emergency operations facility. During the drill, the inspectors assessed the | |||
adequacy of event classification and notification activities. The inspectors observed | |||
portions of the licensees post-drill critiques at the technical support center and | |||
emergency operating facility. | |||
11 | |||
Enclosure | |||
The inspectors verified that the licensee properly evaluated the drills performance with | |||
respect to performance indicators and assessed drill performance with respect to drill | |||
objectives. To assess the ability of the licensee to identify and correct problems, the | |||
inspectors reviewed the following corrective action documents that were generated as a | |||
result of the drill: | |||
* | |||
AR 252936, knowledge gap in the required actions associated with the Reactor | |||
Building positive pressure as defined in AST documentation | |||
* | |||
AR 252937, rewording of SPDS indication to prevent human error | |||
1R23 Temporary Plant Modifications | * | ||
AR 254108, JIC positions not filled during ERO drill | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
1R23 | |||
Temporary Plant Modifications | |||
a. | |||
Inspection Scope | |||
4. | The inspectors reviewed Operating Manual 0PLP-22, Temporary Changes, to assess | ||
the implementation of Engineering Change (EC) 67830, Reactor Core Isolation Cooling | |||
System Low Suction Pressure Trip Delay which was implemented on October 21, 2007. | |||
The inspectors reviewed the EC to verify that the modification did not affect the | |||
functional capability of the EDG, that the modification was properly installed, and | |||
appropriate post-installation testing was performed. | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
4. | |||
OTHER ACTIVITIES | |||
4OA1 Performance Indicator (PI) Verification | 4OA1 Performance Indicator (PI) Verification | ||
a. Inspection Scope | |||
The inspectors sampled licensee data for the performance indicators (PIs) listed below. | |||
To verify the accuracy of the PI data reported during the period reviewed, PI definitions | |||
and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. | |||
5 were used to verify the basis for each data element. | |||
Reactor Safety Cornerstone | |||
The inspectors sampled licensee submittals for the Units 1 and 2 PIs listed below for the | |||
period January 2007 through November 2007. | |||
12 | |||
Enclosure | |||
* | |||
High Pressure Coolant Injection System | |||
* | |||
Reactor Core Isolation Cooling System | |||
A sample of plant records and data was reviewed and compared to the reported data to | |||
b. Findings | verify the accuracy of the PIs. The licensees corrective action program records were | ||
also reviewed to determine if any problems with the collection of PI data had occurred. | |||
Documents reviewed are listed in the Attachment. | |||
b. | |||
Findings | |||
No findings of significance were identified. | |||
4OA2 Identification and Resolution of Problems | 4OA2 Identification and Resolution of Problems | ||
.1 | .1 | ||
Routine Review of ARs | |||
To aid in the identification of repetitive equipment failures or specific human | |||
performance issues for followup, the inspectors performed frequent screenings of items | |||
.2 | entered into the licensees CAP. The review was accomplished by reviewing daily ARs. | ||
a. Inspection Scope | .2 | ||
Annual Sample Review | |||
a. | |||
Inspection Scope | |||
The inspectors performed an in-depth annual sample review of plant operator | |||
workarounds as documented in licensees operator workaround program and corrective | |||
action documents. This review was performed to verify that the licensee identified | |||
operator workarounds at an appropriate threshold, entered the issues into the CAP, and | |||
planned or implemented appropriate corrective actions. The inspectors reviewed the | |||
actions taken to verify that the licensee had adequately addressed the following | |||
attributes: | |||
* | |||
Complete, accurate, and timely identification of the problem | |||
* | |||
Evaluation and disposition of operability and reportability issues | |||
* | |||
Consideration of previous failures, extent of condition, generic or common cause | |||
implications | |||
* | |||
Prioritization and resolution of the issue commensurate with the safety | |||
significance | |||
* | |||
Identification of the root cause and contributing causes of the problem | |||
* | |||
Identification and implementation of corrective actions commensurate with the | |||
safety significance of the issue | |||
The inspectors reviewed the associated corrective action for AR 250203, Unit 2 high | |||
pressure coolant injection pump seal failure that occurred on October 10, 2007. | |||
13 | |||
b. Findings and Observations | Enclosure | ||
b. | |||
.3 | Findings and Observations | ||
a. Inspection Scope | No findings of significance were identified. | ||
.3 | |||
Semi-Annual Trend Review | |||
a. | |||
Inspection Scope | |||
The inspectors performed a review of the licensees CAP and associated documents to | |||
identify trends that could indicate the existence of a more significant safety issue. The | |||
review was focused on repetitive equipment issues but also considered the results of | |||
frequent inspector CAP item screening (discussed above), licensee trending efforts, and | |||
licensee human performance results. The review considered the period of July through | |||
December 2007. The review further included issues documented outside the normal | |||
CAP in major equipment lists, repetitive and/or rework maintenance lists, operational | |||
focus list, control room deficiency list, outstanding work order list, quality assurance | |||
audit/surveillance reports, key performance indicators, and self-assessment reports. | |||
The inspectors compared and contrasted their results with the results contained in | |||
multiple root cause evaluations the licensee has performed over the last 2 quarters. | |||
Corrective actions associated with a sample of the issues identified in the licensees | |||
b. Assessment and Observations | trend reports were reviewed for adequacy. The inspectors also evaluated the reports | ||
against the requirements of the licensees CAP as specified in Nuclear Generation | |||
Group Standard Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR | |||
50, Appendix B. | |||
b. | |||
Assessment and Observations | |||
No findings of significance were identified. The inspectors noted a trend in the control | |||
and retrieval of foreign material in systems and the adverse effects this has had on | |||
system performance; this was exemplified by the following identified issues: | |||
1) Foreign material found in the 1B Residual Heat Removal (RHR) Room cooler | |||
(AR243465); 2) Metallic foreign material found in the 1B RHR Heat Exchanger | |||
(AR246790); 3) 1D RHRSW Booster pump failed to start was bound by valve pin (AR | |||
243867); 4) Unit 2 HPCI main pump inboard seal failure due to blockage of seal cooling | |||
line (AR250203). The inspectors have determined that the licensee has addressed all | |||
immediate operability concerns, and is currently developing long-term improvements. | |||
4OA6 Meetings, Including Exit | 4OA6 Meetings, Including Exit | ||
Exit Meeting Summary | |||
On January 24, 2008, the resident inspectors presented the inspection results to | |||
Mr. Waldrep and other members of his staff. The inspectors confirmed that proprietary | |||
information was not provided or examined during the inspection. | |||
ATTACHMENT: SUPPLEMENTAL INFORMATION | ATTACHMENT: SUPPLEMENTAL INFORMATION | ||
Attachment | |||
SUPPLEMENTAL INFORMATION | |||
KEY POINTS OF CONTACT | |||
Licensee Personnel | Licensee Personnel | ||
G. Atkinson, Supervisor - Emergency Preparedness | G. Atkinson, Supervisor - Emergency Preparedness | ||
L. Beller, Superintendent Operations Training | L. Beller, Superintendent Operations Training | ||
A. Brittain, Manager - Security | A. Brittain, Manager - Security | ||
D. Griffith, Manager - Training Manager | D. Griffith, Manager - Training Manager | ||
L. Grzeck, Lead Engineer - Technical Support | L. Grzeck, Lead Engineer - Technical Support | ||
S. Howard, Manager - Operations | S. Howard, Manager - Operations | ||
R. Ivey, Manager - Site Support Services | R. Ivey, Manager - Site Support Services | ||
T. Pearson, Supervisor - Operations Training | T. Pearson, Supervisor - Operations Training | ||
A. Pope, Supervisor - Licensing/Regulatory Programs | A. Pope, Supervisor - Licensing/Regulatory Programs | ||
S. Rogers, Manager - Maintenance | S. Rogers, Manager - Maintenance | ||
| Line 622: | Line 818: | ||
NRC Personnel | NRC Personnel | ||
Randall Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects Region II | Randall Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects Region II | ||
Attachment | |||
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED | |||
Opened and Closed | Opened and Closed | ||
None | None | ||
Discussed | Discussed | ||
None | None | ||
LIST OF DOCUMENTS REVIEWED | |||
Section 1R01: Adverse Weather Protection | Section 1R01: Adverse Weather Protection | ||
Plant Operating Manual (POM), Volume VII, Operating Instruction 0OI-01.03, Non-Routine | Plant Operating Manual (POM), Volume VII, Operating Instruction 0OI-01.03, Non-Routine | ||
| Line 639: | Line 835: | ||
Operating Procedure | Operating Procedure | ||
POM, Volume III, 0OP-39, Diesel Generator Operating Procedure | POM, Volume III, 0OP-39, Diesel Generator Operating Procedure | ||
System Description SD-39, Emergency Diesel Generators | System Description SD-39, Emergency Diesel Generators | ||
Section 1R05: Fire Protection | Section 1R05: Fire Protection | ||
POM, Volume XIX, Prefire Plan 0PFP-DG, Diesel Generator Building Prefire Plans | POM, Volume XIX, Prefire Plan 0PFP-DG, Diesel Generator Building Prefire Plans | ||
POM, Volume XIX, Prefire Plan 0PFP-PBAA, Power Block Auxiliary Areas Prefire Plans | POM, Volume XIX, Prefire Plan 0PFP-PBAA, Power Block Auxiliary Areas Prefire Plans | ||
POM, Volume XIX, Prefire Plan 1PFP-RB, Unit 1 Reactor Building Prefire Plans | POM, Volume XIX, Prefire Plan 1PFP-RB, Unit 1 Reactor Building Prefire Plans | ||
Section 1R06: Flood Protection Measures | Section 1R06: Flood Protection Measures | ||
POM, Volume XXI, Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During | POM, Volume XXI, Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During | ||
Hurricane, Flood Conditions, Tornado, or Earthquake | Hurricane, Flood Conditions, Tornado, or Earthquake | ||
POM, Volume X, Periodic Test (PT) 0PT-34.2.2.1, Fire Door, ASSD Access/Egress Door, | POM, Volume X, Periodic Test (PT) 0PT-34.2.2.1, Fire Door, ASSD Access/Egress Door, | ||
Severe Weather Door Inspections | Severe Weather Door Inspections | ||
Updated Final Safety Analysis Report Chapters 2 and 3 | Updated Final Safety Analysis Report Chapters 2 and 3 | ||
}} | }} | ||
Latest revision as of 18:21, 14 January 2025
| ML080350426 | |
| Person / Time | |
|---|---|
| Site: | Brunswick |
| Issue date: | 01/29/2008 |
| From: | Randy Musser Division Reactor Projects II |
| To: | Waldrep B Carolina Power & Light Co |
| References | |
| IR-07-005 | |
| Download: ML080350426 (23) | |
See also: IR 05000324/2007005
Text
January 29, 2008
Carolina Power and Light Company
ATTN: Mr. Benjamin Waldrep
Vice President
Brunswick Steam Electric Plant
P. O. Box 10429
Southport, NC 28461
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION
REPORT NOS. 05000324/2007005 AND 05000325/2007005
Dear Mr. Waldrep:
On December 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Brunswick Units 1 and 2 facilities. The enclosed integrated inspection report
documents the inspection findings, which were discussed on January 22, 2008, with you and
other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
On the basis of the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRC's
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Randall A. Musser, Chief
Reactor Projects Branch 4
Division of Reactor Projects
Docket Nos.:
50-325, 50-324
License Nos:
Enclosure:
Inspection Report 05000325, 324/2007005
w/Attachment: Supplemental Information
cc w/encl: (See page 2)
OFFICE
RII:DRP
RII:DRP
RII:DRP
RII:DRS
RII:DRS
RII:DRS
RII:DRS
SIGNATURE
/RA/
/RA By e-mail/
/RA by e-mail/
/RA/
NAME
R Musser
J Austin
S Rutledge
G Wilson
DATE
1/29/08
1/30/08
1/30/08
1/29/08
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO
2
cc w/encl:
Director, Site Operations
Brunswick Steam Electric Plant
Carolina Power & Light Company
Electronic Mail Distribution
J. Paul Fulford, Manager
Performance Evaluation and
Regulatory Affairs PEB 5
Carolina Power & Light Company
Electronic Mail Distribution
Terry D. Hobbs, Plant General Manager
Brunswick Steam Electric Plant
Carolina Power & Light Company
P. O. Box 10429
Southport, NC 28461
Donald L. Griffith
Manager - Training
Progress Energy Carolinas, Inc.
Brunswick Steam Electric Plant
Electronic Mail Distribution
Randy C. Ivey
Manager - Support Services
Progress Energy Carolinas, Inc.
Brunswick Steam Electric Plant
Electric Mail Distribution
Garry D. Miller, Manager
Progress Energy
Electronic Mail Distribution
Annette H. Pope, Supervisor
Licensing/Regulatory Programs
Carolina Power and Light Company
Electronic Mail Distribution
David T. Conley
Associate General Counsel - Legal Dept.
Progress Energy Service Company, LLC
Electronic Mail Distribution
James Ross
Nuclear Energy Institute
Electronic Mail Distribution
John H. O'Neill, Jr.
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, NW
Washington, DC 20037-1128
Beverly Hall, Chief, Radiation
Protection Section
N. C. Department of Environment
and Natural Resources
Electronic Mail Distribution
Peggy Force
Assistant Attorney General
State of North Carolina
Electronic Mail Distribution
Chairman of the North Carolina
Utilities Commission
c/o Sam Watson, Staff Attorney
Electronic Mail Distribution
Robert P. Gruber
Executive Director
Public Staff NCUC
4326 Mail Service Center
Raleigh, NC 27699-4326
Public Service Commission
State of South Carolina
P. O. Box 11649
Columbia, SC 29211
David R. Sandifer
Brunswick County Board of
Commissioners
P. O. Box 249
Bolivia, NC 28422
Warren Lee
Emergency Management Director
New Hanover County Department of
Emergency Management
230 Government Center Drive
Suite 115
Wilmington, NC 28403
3
Report to Ben Waldrep from Randall A. Musser dated January 29, 2008
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION
REPORT NOS. 05000324/2007005 AND 05000325/2007005
Distribution w/encl:
S. Bailey, NRR
R. Pascarelli, NRR
C. Evans, RII
L. Slack, RII
RIDSNRRDIRS
OE Mail
PUBLIC
NRC Resident Inspector
U.S. Nuclear Regulatory Commission
8470 River Road, SE
Southport, NC 28461
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos:
50-325, 50-324
License Nos:
Report Nos:
05000325/2007005 and 05000324/2007005
Licensee:
Carolina Power and Light (CP&L)
Facility:
Brunswick Steam Electric Plant, Units 1 & 2
Location:
8470 River Road SE
Southport, NC 28461
Dates:
October 1, 2007 through December 31, 2007
Inspectors:
J. Austin, Senior Resident Inspector
S. Rutledge, Resident Inspector
Approved by:
Randall A. Musser, Chief
Reactor Projects Branch 4
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000325/2007005, 05000324/2007005; 10/01/07- 12/31/07; Brunswick Steam
Electric Plant, Units 1 and 2.
The report covered a 3-month period of inspection by resident inspectors and one senior
reactor inspector. One Green non-cited violation (NCV) was identified. The significance
of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection
Manual Chapter (IAC) 0609, Significance Determination Process (SDP). The NRC's
program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December
2006.
A.
NRC-Identified and Self-Revealing Findings
NONE
B.
Licensee-Identified Findings
NONE
Enclosure
REPORT DETAILS
Summary of Plant Status
Unit 1
Unit 1 began the inspection period operating at full power. On October 6, power was
reduced to 93 percent to perform a control rod improvement. The unit was restored to
full power the same day. On October 13, power was reduced to 93 percent to perform a
control rod improvement. The unit was returned to full power the same day. On
October 20, power was reduced to 93 percent to perform a control rod improvement.
Full power was restored the same day. On October 27, power was reduced to 93
percent to perform a control rod improvement. Full power was achieved later that day.
On November 3, power was reduced to 67 percent to facilitate valve testing. The unit
was returned to full power later that day. On November 4, power was reduced to 95
percent to perform a control rod improvement. Full power was restored on November 5.
On November 11, power was reduced to 90 percent to perform a control rod
improvement. Full power was achieved later that day. On November 16, power was
reduced to 91 percent to perform a control rod improvement. The unit was returned to
full power November 17. On November 24, power was reduced to 90 percent for control
rod testing. Full power was restored later that day. The unit remained at full power for
the remainder of the inspection period.
Unit 2
Unit 2 began the inspection period operating at full power. On October 1, a power
ascension occurred from main turbine valve testing. Full power was restored later that
day. On October 1, power was reduced to 95 percent to perform a control rod
improvement. Full power was restored later that day. On October 1, power was
reduced to 96 percent to perform a control rod improvement. The unit was returned to
full power later that day. On October 2, power was reduced to 98 percent to perform a
control rod improvement. Full power was restored later that day. On November 8,
power was reduced to 71 percent for a Whiteville line outage. Power was returned to
full later that day. On November 9, power was reduced to 98 percent for a control rod
improvement. Full power was restored later that day. On November 17, power was
reduced to 68 percent for main turbine valve, reactor feed pump and scram time testing.
The unit was returned to full power on November 18. On November 18, power was
reduced to 94 percent for xenon build-up following main turbine valve testing and control
rod sequence exchange. Full power was returned on November 19. On November 19,
power was reduced to 85 percent to perform a control rod improvement. Full power was
restored November 20. On November 20, power was reduced to 95 percent to perform
a control rod improvement. Full power was achieved November 21, 2007. The unit
remained at full power for the remainder of the inspection period.
3
Enclosure
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01
Adverse Weather Protection
a.
Inspection Scope
The inspectors assessed the effectiveness of the licensees cold weather protection
program as it related to ensuring that the facilitys service water pumps, emergency
diesel generators, and condensate storage tank low level switches would remain
functional and available in cold weather conditions. In addition to reviewing the
licensees program-related documents and procedures, walkdowns were conducted of
the freeze protection equipment (e.g., heat tracing, area space heaters, etc.) associated
with the above systems/components. Licensee problem identification and resolution
associated with cold weather protections was also assessed.
AR 246713246713 Unit 2 condensate storage tank heat trace inoperable
AR 253047253047 Emergency diesel generator #1 jacket water heater temperature
switch
b.
Findings
No findings of significance were identified.
1R04
Equipment Alignment
.1
Partial System Walkdowns
a.
Inspection Scope
The inspectors performed three partial walkdowns of the below-listed systems to verify
that the systems were correctly aligned while the redundant train or system was
inoperable or out-of-service (OOS) or, for single train risk significant systems, while the
system was available in a standby condition. The inspectors assessed conditions such
as equipment alignment (i.e., valve positions, damper positions, and breaker alignment)
and system operational readiness (i.e., control power and permissive status) that could
affect operability. The inspectors verified that the licensee identified and resolved
equipment alignment problems that could cause initiating events or impact mitigating
system availability. The inspectors reviewed Administrative Procedure
ADM-NGGC-0106, Configuration Management Program Implementation, to verify that
available structures, systems or components (SSCs) met the requirements of the
configuration control program. Documents reviewed are listed in the Attachment.
2A Nuclear service water pump when the 2B nuclear service water pump was
OOS for scheduled maintenance on October 3, 2007
4
Enclosure
Unit 2 RCIC when the Unit 2 HPCI was OOS for seal repair on October 15, 2007
EDG #2, #3, and #4 while EDG #1 was OOS for scheduled maintenance on
November 19, 2007
To assess the licensees ability to identify and correct problems, the inspectors reviewed
the following Action Requests (ARs):
AR 251684251684 RCIC extent of condition evaluation using Panametrics
AR 252203252203 U2 RCIC seal purge line orifice missing
AR 259682259682 U1 RCIC steam supply drain pot steam leak
AR 254033254033 EDG starting air pilot air lines support discrepancies
AR 254280254280 EDG #3 brush inspection meg readings
AR 259504259504 EDG #1 generator vibration alarm
b.
Findings
No findings of significance were identified.
.2
Complete System Walkdown
a.
Inspection Scope
The inspectors conducted a detailed review of the alignment and condition of the Unit 2
high pressure coolant injection system. The inspector reviewed the Updated Final
Safety Analysis Report, associated attachments of Operating Procedure 2OP-19, High
Pressure Coolant Injection System Operating Procedure, 0PT-09.2, HPCI System
Operability Test and the systems diagrams (drawing numbers D-02523 and LL-09272)
in determining correct system lineup. The inspectors also reviewed maintenance history
of the system.
To assess the licensees identification and resolutions of problems, the inspectors
reviewed the following:
AR 250203250203 HPCI inoperable due to pump seal leakage
AR 225856225856 HPCI lube oil coolers debris
AR 229349229349 HPCI condensate pump trip
AR 251647251647 U2 HPCI vacuum tank level issues
AR 251490251490 Water in U2 HPCI lube oil
b.
Findings
No findings of significance were identified.
5
Enclosure
1R05
Fire Protection
.1
Fire Area Walkdowns
a.
Inspection Scope
The inspectors reviewed ARs and work orders (WOs) associated with the fire
suppression system to confirm that their disposition was in accordance with Procedure
0AP-033, Fire Protection Program Manual. The inspectors reviewed the status of
ongoing surveillance activities to verify that they were current to support the operability
of the fire protection system. In addition, the inspectors observed the fire suppression
and detection equipment to determine whether any conditions or deficiencies existed
which would impair the operability of that equipment. The inspectors toured the
following six areas important to reactor safety and reviewed the associated prefire plans
to verify that the requirements for fire protection design features, fire area boundaries,
and combustible loading were met. Documents reviewed are listed in the Attachment.
Units 1 and 2 Control Building, - 49' elevation (2 areas)
Units 1 and 2 Control Building, - 23' elevation (2 areas)
Units 1 and 2 Reactor Building - 17' elevation (2 areas)
b.
Findings
No findings of significance were identified.
.2
Fire Drill
a.
Inspection Scope
On October 6, 2007, the inspectors observed a plant fire drill at the auxiliary boiler unit
located outside near the Emergency Diesel Generator Building, to assess the fire
brigade performance and to verify that proper firefighting techniques for the type of fire
encountered were utilized. The inspectors monitored the fire brigades use of protective
equipment and firefighting equipment to verify that preplanned firefighting procedures
and appropriate firefighting techniques were used, and to verify that the directions of the
fire brigade leader were thorough, clear, and effective. The inspectors attended the
critique to confirm that appropriate feedback on performance was provided to brigade
members and to ensure that areas for improvement were properly identified for licensee
follow-up. In preparing for the drill, the inspectors reviewed the preplanned drill
scenario, Brunswick Nuclear Plant Drill Scenario Guide, 99-F-0S, Revision 1.
b.
Findings
No findings of significance were identified.
6
Enclosure
1R06
Flood Protection Measures
.1
a.
Inspection Scope
The inspectors reviewed the licensees internal flooding analysis as described in
Updated Final Safety Analysis Report (UFSAR) Section 3.4.2, Protection From Internal
Flooding. Due to the risk significance of equipment in the Service Water and
Emergency Diesel Generator Buildings, the inspectors reviewed UFSAR Section 3.4.2
analysis of the effects of postulated piping failures for these two areas to determine if
the analysis assumptions and conclusions were based on the current plant
configuration. The internal flooding design features and equipment for coping with
internal flooding was inspected for the equipment located in these buildings. The
walkdown included sources of flooding and drainage, sump pumps, level switches,
watertight doors, curbs, pedestals and equipment mounting. Documents reviewed are
listed in the Attachment.
b. Findings
No findings of significance were identified.
.2
External Flooding
a.
Inspection Scope
The inspectors reviewed the licensees external flooding analysis as described in
UFSAR Section 3.4.1, Protection from External Flooding, to determine the external flood
control design features. Walkdowns were conducted to inspect the external flood
protection barriers including watertight doors, curbs, sealing of external building
penetrations below flood line, and the sump pumps and level alarm circuits. Areas
reviewed included the Emergency Diesel Generator Building, and the Service Water
Building. The inspector reviewed the procedures for coping with external flooding
contained in Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During
Hurricane, Flood Conditions, Tornado, or Earthquake. Other documents reviewed are
listed in the Attachment.
b. Findings
No findings of significance were identified.
7
Enclosure
1R11
Licensed Operator Requalification
.1
Quarterly Review
a.
Inspection Scope
The inspectors observed licensed operator performance and reviewed the associated
training documents during annual dynamic simulator examination sessions for training
cycle 2007-05. The simulator observations and review included evaluations of
emergency operating procedure and abnormal operating procedure utilization. The
inspectors reviewed Procedure 0TPP-200, Licensed Operator Continuing Training
Program, to verify that the program ensures safe power plant operation. Simulator
sessions were observed on November 20, 2007. The scenarios tested the operators
ability to respond to secondary plant failures, loss of emergency power, and an
automatic trip without a scram followed by a rupture of the scram discharge volume.
The inspectors reviewed operator activities to verify consistent clarity and formality of
communication, conservative decision-making by the crew, appropriate use of
procedures, and proper alarm response. Group dynamics and supervisory oversight,
including the ability to properly identify and implement appropriate Technical
Specification (TS) actions, regulatory reports, and notifications, were observed. The
inspectors observed instructor critiques and preliminary grading of the operating crews
and assessed whether appropriate feedback was planned to be provided to the licensed
operators.
b.
Findings
No findings of significance were identified.
1R12
Maintenance Effectiveness
a.
Inspection Scope
For the two equipment issues described in the ARs listed below, the inspectors reviewed
the licensees implementation of the Maintenance Rule (10 CFR 50.65) with respect to
the characterization of failures, the appropriateness of the associated Maintenance Rule
a(1) or a(2) classification, and the appropriateness of the associated a(1) goals and
corrective actions. The inspectors reviewed the work controls and work practices
associated with the degraded performance or condition to verify that they were
appropriate and did not contribute to the issue. The inspectors also reviewed operations
logs and licensee event reports to verify unavailability times of components and
systems, if applicable. Licensee performance was evaluated against the requirements
of Procedure ADM-NGGC-0101, Maintenance Rule Program.
AR 242066242066 BNP response to operating experience 2007-08 degradation of
buried piping
AR 256103256103 Loss of full out indications on the full core display
8
Enclosure
b.
Findings
No findings of significance were identified.
1R13
Maintenance Risk Assessments and Emergent Work Evaluation
a.
Inspection Scope
The inspectors reviewed the licensees implementation of 10 CFR 50.65 (a)(4)
requirements during scheduled and emergent maintenance activities, using Procedure
0AP-025, BNP Integrated Scheduling and Technical Requirements Manual 5.5.13,
Configuration Risk Management Program. The inspectors reviewed the effectiveness of
risk assessments performed due to changes in plant configuration for maintenance
activities (planned and emergent). The review was conducted to verify that, upon
unforseen situations, the licensee had taken the necessary steps to plan and control the
resultant emergent work activities. The inspectors reviewed the applicable plant risk
profiles, work week schedules, and maintenance WOs for the following five conditions:
AR 250203250203 HPCI inoperable due to pump seal leakage
AR 255545255545 Unexpected annunciators during performance test (PT-12.2a) for
EDG #1
AR 257721257721 Unit 1 condensate storage tank instrumental vent line excessive
sloping
AR 257744257744 EDG #3 jacket water leakage from flexmaster jumpers
AR 256079256079 1-E11-F017B inoperable due to high energy line break issues at the
motor control cubicle compartment
b.
Findings
No findings of significance were identified.
1R15
Operability Evaluations
a.
Inspection Scope
The inspectors reviewed the operability evaluations associated with the six issues
documented in the ARs listed below, which affected risk significant systems or
components, to assess, as appropriate: 1) the technical adequacy of the evaluations; 2)
the justification of continued system operability; 3) any existing degraded conditions
used as compensatory measures; 4) the adequacy of any compensatory measures in
place, including their intended use and control; and 5) where continued operability was
considered unjustified, the impact on any TS limiting condition for operation and the risk
significance. In addition to the reviews, discussions were conducted with the applicable
system engineer regarding the ability of the system to perform its intended safety
function.
9
Enclosure
AR 249130249130 1A Residual heat removal heat exchanger degradation during
testing (OPF08.1.4A)
AR 245864245864 E-4 Loss of coolant accident logic relay 27E2 de-energized
AR 250793250793 Unit 2 RCIC operability concern
AR 252203252203 Unit 2 RCIC seal purge line orifice missing
AR 251885251885 Unit 2 HPCI main pump seal leak exceeds posting
AR 251490251490 Water in Unit 2 HPCI lube oil
b.
Findings
No findings of significance were identified.
1R19
Post-Maintenance Testing
a.
Inspection Scope
For the five maintenance activities listed below, the inspectors reviewed the post-
maintenance test procedure and witnessed the testing and/or reviewed test records to
confirm that the scope of testing adequately verified that the work performed was
correctly completed. The inspectors verified that the test demonstrated that the affected
equipment was capable of performing its intended function and was operable in
accordance with TS requirements. The inspectors reviewed the licensees actions
against the requirements in Procedure 0PLP-20, Post Maintenance Testing Program.
PT 9.2 HPCI Operability Test following inboard seal failure
WO 114145 RCIC system fill and vent after pump maintenance
WO 1137349 Inspection of HPCI sump after drain down
AR 250499250499 Basis for changing piping test plan not understood
AR 247456247456 Balance of plant under-voltage relays not tested as required
b.
Findings
No findings of significance were identified.
1R22
Surveillance Testing
.1
Routine Surveillance Testing
a.
Inspection Scope
The inspectors either observed surveillance tests or reviewed test data for the three risk
significant SSC surveillances, listed below, to verify the tests met TS surveillance
requirements, UFSAR commitments, in-service testing (IST) requirements, and licensee
procedural requirements. The inspectors assessed the effectiveness of the tests in
demonstrating that the SSCs were operationally capable of performing their intended
safety functions.
10
Enclosure
0PT-09.2mst-HPCI 23Q, High Pressure Coolant Injection System operability test,
performed on Unit 2 on October 22, 2007
2O1-03.2, Control Operator Daily Surveillance Report (including drywell leakage
rate determination), performed the week of November 12, 2007.
C
0PT-9.3a, High Pressure Coolant Injection System Component Test, performed
on Unit 1 on December 7, 2007.
b.
Findings
No findings of significance were identified.
.2
In-service Surveillance Testing
a.
Inspection Scope
The inspectors reviewed the performance of Periodic Test 0PT-9.7, High Pressure
Coolant Injection System Valve Operability Test, performed on Unit 1 on December 7,
2007. The inspectors evaluated the effectiveness of the licensees American Society of
Mechanical Engineers (ASME)Section XI testing program to determine equipment
availability and reliability. The inspectors evaluated selected portions of the following
areas: 1) testing procedures; 2) acceptance criteria; 3) testing methods; 4) compliance
with the licensees IST program, TS, selected licensee commitments, and code
requirements; 5) range and accuracy of test instruments; and 6) required corrective
actions. The inspectors also assessed any applicable corrective actions taken.
To assess the licensees ability to identify and correct problems, the inspector reviewed
AR 214876214876which documented that the Unit 1 A conventional service water pump was
discovered to be in the Alert range following testing on November 30, 2006.
b.
Findings
No findings of significance were identified.
1EP6
Drill Evaluation
a.
Inspection Scope
The inspectors observed site emergency preparedness training drill/simulator scenarios
conducted on October 30, 2007 and November 8, 2007. The inspectors reviewed the
drill scenario narrative to identify the timing and location of classifications, notifications,
and protective action recommendations development activities. The inspectors
evaluated the drill conduct from the control room simulator, technical support center,
and the emergency operations facility. During the drill, the inspectors assessed the
adequacy of event classification and notification activities. The inspectors observed
portions of the licensees post-drill critiques at the technical support center and
emergency operating facility.
11
Enclosure
The inspectors verified that the licensee properly evaluated the drills performance with
respect to performance indicators and assessed drill performance with respect to drill
objectives. To assess the ability of the licensee to identify and correct problems, the
inspectors reviewed the following corrective action documents that were generated as a
result of the drill:
AR 252936252936 knowledge gap in the required actions associated with the Reactor
Building positive pressure as defined in AST documentation
AR 252937252937 rewording of SPDS indication to prevent human error
AR 254108254108 JIC positions not filled during ERO drill
b.
Findings
No findings of significance were identified.
1R23
Temporary Plant Modifications
a.
Inspection Scope
The inspectors reviewed Operating Manual 0PLP-22, Temporary Changes, to assess
the implementation of Engineering Change (EC) 67830, Reactor Core Isolation Cooling
System Low Suction Pressure Trip Delay which was implemented on October 21, 2007.
The inspectors reviewed the EC to verify that the modification did not affect the
functional capability of the EDG, that the modification was properly installed, and
appropriate post-installation testing was performed.
b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee data for the performance indicators (PIs) listed below.
To verify the accuracy of the PI data reported during the period reviewed, PI definitions
and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev.
5 were used to verify the basis for each data element.
Reactor Safety Cornerstone
The inspectors sampled licensee submittals for the Units 1 and 2 PIs listed below for the
period January 2007 through November 2007.
12
Enclosure
High Pressure Coolant Injection System
Reactor Core Isolation Cooling System
A sample of plant records and data was reviewed and compared to the reported data to
verify the accuracy of the PIs. The licensees corrective action program records were
also reviewed to determine if any problems with the collection of PI data had occurred.
Documents reviewed are listed in the Attachment.
b.
Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1
Routine Review of ARs
To aid in the identification of repetitive equipment failures or specific human
performance issues for followup, the inspectors performed frequent screenings of items
entered into the licensees CAP. The review was accomplished by reviewing daily ARs.
.2
Annual Sample Review
a.
Inspection Scope
The inspectors performed an in-depth annual sample review of plant operator
workarounds as documented in licensees operator workaround program and corrective
action documents. This review was performed to verify that the licensee identified
operator workarounds at an appropriate threshold, entered the issues into the CAP, and
planned or implemented appropriate corrective actions. The inspectors reviewed the
actions taken to verify that the licensee had adequately addressed the following
attributes:
Complete, accurate, and timely identification of the problem
Evaluation and disposition of operability and reportability issues
Consideration of previous failures, extent of condition, generic or common cause
implications
Prioritization and resolution of the issue commensurate with the safety
significance
Identification of the root cause and contributing causes of the problem
Identification and implementation of corrective actions commensurate with the
safety significance of the issue
The inspectors reviewed the associated corrective action for AR 250203250203 Unit 2 high
pressure coolant injection pump seal failure that occurred on October 10, 2007.
13
Enclosure
b.
Findings and Observations
No findings of significance were identified.
.3
Semi-Annual Trend Review
a.
Inspection Scope
The inspectors performed a review of the licensees CAP and associated documents to
identify trends that could indicate the existence of a more significant safety issue. The
review was focused on repetitive equipment issues but also considered the results of
frequent inspector CAP item screening (discussed above), licensee trending efforts, and
licensee human performance results. The review considered the period of July through
December 2007. The review further included issues documented outside the normal
CAP in major equipment lists, repetitive and/or rework maintenance lists, operational
focus list, control room deficiency list, outstanding work order list, quality assurance
audit/surveillance reports, key performance indicators, and self-assessment reports.
The inspectors compared and contrasted their results with the results contained in
multiple root cause evaluations the licensee has performed over the last 2 quarters.
Corrective actions associated with a sample of the issues identified in the licensees
trend reports were reviewed for adequacy. The inspectors also evaluated the reports
against the requirements of the licensees CAP as specified in Nuclear Generation
Group Standard Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50, Appendix B.
b.
Assessment and Observations
No findings of significance were identified. The inspectors noted a trend in the control
and retrieval of foreign material in systems and the adverse effects this has had on
system performance; this was exemplified by the following identified issues:
1) Foreign material found in the 1B Residual Heat Removal (RHR) Room cooler
(AR243465243465; 2) Metallic foreign material found in the 1B RHR Heat Exchanger
(AR246790246790; 3) 1D RHRSW Booster pump failed to start was bound by valve pin (AR
243867); 4) Unit 2 HPCI main pump inboard seal failure due to blockage of seal cooling
line (AR250203250203. The inspectors have determined that the licensee has addressed all
immediate operability concerns, and is currently developing long-term improvements.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On January 24, 2008, the resident inspectors presented the inspection results to
Mr. Waldrep and other members of his staff. The inspectors confirmed that proprietary
information was not provided or examined during the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
G. Atkinson, Supervisor - Emergency Preparedness
L. Beller, Superintendent Operations Training
A. Brittain, Manager - Security
D. Griffith, Manager - Training Manager
L. Grzeck, Lead Engineer - Technical Support
S. Howard, Manager - Operations
R. Ivey, Manager - Site Support Services
T. Pearson, Supervisor - Operations Training
A. Pope, Supervisor - Licensing/Regulatory Programs
S. Rogers, Manager - Maintenance
B. Waldrep, Site Vice President
T. Sherrill, Engineer - Technical Support
T. Trask, Manager - Engineering
J. Titrington, Manger - Nuclear Assessment Services
M. Turkal, Lead Engineer - Technical Support
M. Williams, Manager - Operations Support
E. Wills, Plant General Manager
NRC Personnel
Randall Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects Region II
Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None
Discussed
None
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Plant Operating Manual (POM), Volume VII, Operating Instruction 0OI-01.03, Non-Routine
Activities
POM, Volume XII, Preventive Maintenance 0PM-HT001, Preventive Maintenance on Plant
Freeze Protection and Heat Tracing System
Section 1R04: Equipment Alignment
POM, Volume III, Operating Procedure 2OP-39, High Pressure Coolant Injection System
Operating Procedure
POM, Volume III, 0OP-39, Diesel Generator Operating Procedure
System Description SD-39, Emergency Diesel Generators
Section 1R05: Fire Protection
POM, Volume XIX, Prefire Plan 0PFP-DG, Diesel Generator Building Prefire Plans
POM, Volume XIX, Prefire Plan 0PFP-PBAA, Power Block Auxiliary Areas Prefire Plans
POM, Volume XIX, Prefire Plan 1PFP-RB, Unit 1 Reactor Building Prefire Plans
Section 1R06: Flood Protection Measures
POM, Volume XXI, Abnormal Operating Procedure (AOP) 0AOP-13.0, Operation During
Hurricane, Flood Conditions, Tornado, or Earthquake
POM, Volume X, Periodic Test (PT) 0PT-34.2.2.1, Fire Door, ASSD Access/Egress Door,
Severe Weather Door Inspections
Updated Final Safety Analysis Report Chapters 2 and 3