IR 05000324/2021002
| ML21223A155 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/11/2021 |
| From: | Stewart Bailey Division Reactor Projects II |
| To: | Krakuszeski J Duke Energy Progress |
| T Francis | |
| References | |
| IR 2021002 | |
| Download: ML21223A155 (25) | |
Text
August 11, 2021
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000324/2021002 AND 05000325/2021002
Dear Mr. Krakuszeski:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On July 29, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000324 and 05000325 License Nos. DPR-62 and DPR-71
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000324 and 05000325 License Numbers: DPR-62 and DPR-71 Report Numbers: 05000324/2021002 and 05000325/2021002 Enterprise Identifier: I-2021-002-0008 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant Location: Southport, NC Inspection Dates: April 1, 2021 to June 30, 2021 Inspectors: G. Smith, Senior Resident Inspector M. Schwieg, Reactor Inspector J. Diaz-Velez, Senior Health Physicist B. Kellner, Senior Health Physicist J. Rivera, Health Physicist Approved By: Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Brunswick Steam Electric Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000325/2020-002-00 LER 2020-002-00 for 71153 Closed Brunswick Steam Electric Plant, Unit 1, Technical Specification Required Shutdown due to Unidentified Leakage
PLANT STATUS
Unit 1 began the period at 100 percent (full) rated thermal power (RTP) and operated there until May 1, 2021, when the unit was shut down mid-cycle to replace a leaking seal package on the 'B' recirculation pump. Following replacement of the seal packages on both the 'A' and 'B' recirculation pumps, the unit was taken critical and the output breaker closed on May 12, 2021.
On May 13, 2021, a power ascension was commenced, and the unit reached full power on May 20, 2021. The unit continued to operate at essentially full power for the remainder of the inspection period.
Unit 2 began the period shut down for a refueling outage. Following completion of the refueling outage, the unit was taken critical on April 4, 2021. On April 5, 2021, the output breaker was closed, and a power ascension was commenced. The unit reached full power on April 9, 2021.
The unit continued to operate there until June 7, 2021, when power was reduced to 75 percent RTP for a control rod improvement. Following completion of the rod improvement, the unit was restored to full power on June 9, 2021, where it continued to operate until the end of the period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 high pressure coolant injection (HPCI) system on April 15, 2021
- (2) Unit 1 residual heat removal (RHR) torus suction system on April 21, 2021
- (3) Diesel generator building instrument air system on June 18, 2021
- (4) Unit 1 'B' train RHR while 'A' train was out-of-service for planned maintenance on
June 23, 2021 Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the safety-related Unit 1 and Unit 2 core spray (CS) systems completed on May 26, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Service water (SW) building elevation (EL) 4' on April 9, 2021
- (2) SW building EL 20' on April 9, 2021
- (3) Diesel generator fuel oil tank cells #1 thru #4 on May 27, 2021
- (4) Control building EL 49' (main control room) on June 1, 2021
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill in the service water building on April 19, 2021
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
On June 30, 2021, the inspectors completed an evaluation of the internal flooding mitigation protections in the:
- (1) SW building
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during initial pressurization of the reactor coolant system following a refueling outage on April 4, 2021
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator continuing training (loss of 2XDB bus, inadvertent core spray initiation, reactor water cleanup (RWCU) system rupture) on June 24, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 1 'B' recirculation pump seal degradation and subsequent replacement (Nuclear
Condition Report (NCR) 2379462) Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Commercial grade dedication package associated with a Watt/Var transducer used in the safety-related emergency diesel generators (EDGs)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1 shutdown risk during maintenance outage to replace the 'B' recirculation pump seal package on May 7, 2021.
- (2) Emergent failure of TE 2-B21-TE-N013A results in half scram during testing on June 15, 2021
- (3) Emergent failure of the Unit 1 'B' control rod drive pump on June 17, 2021
- (4) Unit 1 A RHR Outage on June 23, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1 Drywell Equipment Drain leakage in Action Level 1 (NCR 2379462)
- (2) Unit 2 'B' North Hotwell In-Leakage (NCR 2378093)
- (3) Unit 1 SC Torus Line Plate Inspection Results Exceed Acceptance Criteria (NCR 2374037)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Diesel fuel oil tank room aqueous film forming foam (AFFF) degradation (EC 419628)
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) 0PT-80.1, Reactor Pressure Vessel ASME Section XI Pressure Test
- (2) 0PT-34.5.4.0, Foam Concentrate Performance Evaluation and Level Verification
- (3) 0PM-RLY035, Function Test of E3-E1 Cross-tie Breaker Lockout Relay
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated the Unit 2 refueling outage (B2R25) from March 5, 2021 to April 5, 2021
- (2) The inspectors evaluated the Unit 1 forced outage to repair a failing recirculating pump seal from May 1 to May 12, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) 0PT-12.2C, No. 3 Diesel Generator Monthly Load Test on June 10, 2021
- (2) EDG-4 LOOP/LOCA Loading Test (RS) on June 16, 2021
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
- (1) The inspectors evaluated an emergency drill conducted on April 20, 2021
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated a simulator training session that involved a RWCU system rupture on June 24,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
- (1) The inspectors reviewed the following:
Radiation Work Packages
- RWP # 2503 - CRD Activities- Including Support Activities (locked high radiation area (LHRA)/HCA), Rev: 11
- RWP # 2523 - 117' FLOOD UP ACTIVITIES, Rev: 08
- RWP # 2526 - 117' - REASSEMBLY ACTIVITIES, Rev: 06
- RWP # 2553 - Welding Activities MSIV Drain Lines EC Rev: 02 Electronic Alarming Dosimeter (ED) Alarms
- Reviewed ED dose and dose rate alarm logs from January 2020 through January 2021. No unplanned or unexpected alarms occurred.
Labeling of Containers
- Observed 15 radioactive material containers at various locations inside the protected area and radiologically controlled area (RCA) with appropriate Radioactive Material labeling
- Observed 6 in service HEPA units and vacuums appropriately labeled as Radioactive Material in the RCA
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) The inspectors verified the following sealed sources are accounted for and are intact:
- Category 2 Cs-137 source ID# 10R008 (Hopewell shielded box calibrator/irradiator)
- Category 2 Cs-137 source ID# 84R106 (Shepherd shielded box calibrator/irradiator)
- (2) Observed workers undressing, and monitoring after exiting the drywell and refueling cavity contaminated areas, including RP monitoring for discrete hot particles, as applicable
- (3) Observed licensee surveys of personnel and potentially contaminated material leaving the RCA
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- RWP # 2503, Control Rod Drive (CRD) Activities [removal, replacement, adjustments, etc.]
- (2) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- RWP # 2523, 117' Flood up Activities [Fuel Pool Gate Seal, In-vessel inspection, IER L2 19-6 Inspections, etc.]
- (3) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- (4) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- RWP # 2553, Welding Activities MSIV Drain Lines High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas (VHRA):
- (1) Unit 1 and Unit 2 condenser bays (4 entry points each) LHRA
- (3) Unit 1 and Unit 2 drywell (2 entry points) VHRA Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
Through direct observation, interviews, or discussions with workers and RP technicians, the inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensees radiological work planning.
- (1) The inspectors reviewed the following activities:
- ALARA Plan 2503 - B2R25 Control Rod Drive Exchange And Support Activities, 2/2/2021
- (2) The inspectors reviewed the following activities:
- ALARA Tracking Sheet 2513T - B2R25 Shielding Project, 2/1/2021
- (3) The inspectors reviewed the following activities:
- ALARA Plan 2523 - B2R25 Refuel Floor Maintenance, 2/2/2021
- (4) The inspectors reviewed the following activities:
- ALARA Plan 2526 - B2R25 Reassembly Activities, 2/2/2021
- (5) The inspectors reviewed the following activities:
- ALARA Plan 2553 - Drywell Welding Equipment Drains, 2/2/2021
- (6) The inspectors reviewed the following activities:
- ALARA Tracking Sheet 2552T - Welding 2/1/2021 Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (3 Samples)
The inspectors evaluated dose estimates and exposure tracking.
- (1) The inspectors reviewed the following as low as reasonably achievable planning documents:
- ALARA Plan 1503 - B1R23 Control Rod Drive Exchange and Support Activities, Revisions 0, 1, & 2 (February and March 2020)
Additionally, the inspectors reviewed the following radiological outcome evaluations:
- ALARA Plan 1503 - B1R23 Control Rod Drive Exchange and Support Activities, 50 and 75 % in-progress reviews and Post Job Review
- (2) The inspectors reviewed the following as low as reasonably achievable planning documents:
- ALARA Plan 1504 - B1R23 Refuel Floor Decontamination Support, Revision 0, 2/11/2020 Additionally, the inspectors reviewed the following radiological outcome evaluations:
- ALARA Plan 1504 - B1R23 Refuel Floor Decontamination Support, 50% in-progress review and Post Job Review
- (3) The inspectors reviewed the following as low as reasonably achievable planning documents:
- ALARA Plan 1523 - B1R23 Refuel Floor Maintenance Window Activities, Revision 0 & 1, 2/11/2020 & 3/13/2020 Additionally, the inspectors reviewed the following radiological outcome evaluations:
- ALARA Plan 1523 - B1R23 Refuel Floor Maintenance Window Activities, Post Job Review
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (4 Samples)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls.
- (1) The inspectors reviewed the following activities:
- Temporary Shielding Request (TSR #) 2 -RF21-01 - Reactor Recirculation Piping
- TSR # 2 -RF21-28 - RWCU Heat Exchangers
- TSR # 2 -RF21-08 - RB 117' Shield Racks
- (2) The inspectors reviewed the following activities:
In progress reviews for the following ALARA Plans (APs):
- AP 2523, B2R25 Refueling Maintenance, at 50%
- AP 2522, Unit 2 Refuel Disassembly, at 50%
- (3) The inspectors reviewed the following activities:
Post Job ALARA review of the following ALARA Plan
- (4) The inspectors reviewed the following activities:
TEDE-ALARA evaluations for the following work activities:
- CRD exchange
- refuel disassembly
- cavity decontamination
- refuel assembly
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance:
- (1) by observation via video monitoring of work performed for refueling, CRD exchange preparations, reactor reassembly activities [RWPs 2503 and 2526], and during direct observation while onsite.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
(1)
- Unit 1 standby gas treatment system Trains A and B (2)
- Unit 2 control building emergency filter system Trains A and B
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Temporary Ventilation System Setups
- HEPAs - #6, #9, #19, #1478, #1702
- Air Vacuums - #1614, #1619
- (2) Portable or Installed Monitoring Systems
- iCam (portable continuous air monitor), Enrad # 13220 located in the unit control room stairwell
- iCam, Enrad # 12695 and 11774 located in the hallways on the 20' elevation
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices. Observed in-field applications; verifying the licensee validated the level of protection provided by the devices; inspecting the material condition of devices, reviewing records and certification of devices issued for use; reviewing the qualifications of workers that use the devices; and observing workers donning, doffing and testing devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) Reviewed Brunswick Nuclear Plant - TLD-ED Correlations for the 1st Semi-Annual 2020 Monitoring Period
Internal Dosimetry (IP Section 03.03) (3 Samples)
The inspectors evaluated the internal dosimetry program implementation.
- (1) The inspectors reviewed the following:
In-Vitro Internal Monitoring
- Reviewed results of baseline Tritium bioassay analysis of eight
- (8) divers performing radiological diving during the 2021 Unit 2 outage.
- (2) The inspectors reviewed the following:
Whole Body Counts
- Reviewed positive body count records for eight
- (8) workers installing shielding in the reactor cavity during the 2020 Unit 1 refueling outage
- (3) The inspectors reviewed the following:
Dose Assessments Performed Using Air Sampling and Derived Air Concentration-Hour Monitoring
- Internal dose assessments for eight
- (8) workers installing shielding in the reactor cavity during the 2020 Unit 1 refueling outage (based on whole body counts).
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situation:
- (1) Licensees implementation of requirements to manage radiation protection of declared pregnant workers for three workers.
- (2) Licensees implementation and application of NRC-approved external dosimetry methods (i.e. EDEX) for Control Rod Drive changeouts during 2021 Unit 2 outage.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (6 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Area radiation monitor (ARM) in control room
- (2) Portal monitor (GEM-5) at RCA exit
- (3) Small article monitor (Cronos) at RCA exit
- (4) Personnel contamination monitor (Argos) at RCA exit
- (5) High range portable survey instrument (Telepole) in instrumentation lab
- (6) Continuous air monitors (iCAMs) in various locations in the reactor building
Calibration and Testing Program (IP Section 03.02) (11 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Whole body counter (WBC) no. BNPFS2
- (2) Unit 2 drywell high range area radiation monitor
- (3) Count room gamma detector no. 3
- (4) Count room alpha and beta Tennelec detector no. TH-05
- (5) Electronic dosimeter serial no. 867834
- (6) Count room Tricarb tritium counter serial no. SGLO30201363
- (7) GEM-5 serial no. 11698
- (8) Cronos-4 serial no. 11652
- (9) Argos 5AB serial no. 12309
- (10) Telepole serial no. 02131
- (11) Ludlum model 12-4 Remball serial no. 12141 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Main stack gaseous effluent monitor
- (2) Liquid waste discharge effluent monitor
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
- (1) Unit 1 (April 1, 2020 through March 31, 2021)
- (2) Unit 2 (April 1, 2020 through March 31, 2021)
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1 (April 1, 2020 through March 31, 2021)
- (2) Unit 2 (April 1, 2020 through March 31, 2021)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1 (April 1, 2020 through March 31, 2021)
- (2) Unit 2 (April 1, 2020 through March 31, 2021)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) Unit 1 (January 1, 2020 through January 1, 2021)
Unit 2 (January 1, 2020 through January 1, 2021)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) Unit 1 (May 1, 2020 through January 1, 2021)
Unit 2 (May 1, 2020 through January 1, 2021)
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in equipment performance that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) NCR 2370489: Invalid Unit 2 Group 6 Initiation
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event report (LER):
- (1) LER 05000325/2020-002-00, Technical Specification Required Shutdown Due to Unidentified Leakage (ADAMS Accession No. ML20140A004). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.
Personnel Performance (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees performance regarding an event that occurred on February 17, 2021. The event was an invalid group 6 isolation and was reported to the NRC on April 4, 2021, under event notification 55191. This 60-day notification was in lieu of a written LER as allowed by 10 CFR 50.73(a)(1). The group 6 actuation was considered invalid pursuant to 10 CFR 50.73(a)(2)(iv)(A) and 10 CFR 50.73(a)(2)(iv)(B). The operators responded to the event in accordance with required procedures.
INSPECTION RESULTS
Observation: Semi-Annual Trend Review 71152 The inspectors performed a trend analysis on the licensees corrective action program to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on equipment performance trends, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of January 2021 through June 2021, although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends. Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.
During this review, the inspectors did note that two recent operating cycles on both units were affected by degrading recirculation pump seals. Just prior to the March 2021, Unit 2 refueling outage, Unit 2 experienced a degrading 'B' recirculation pump seal. This was evidenced by a deviation from expected seal pressure parameters and increased drywell leakage. In this case, the licensee was able to continue to operate plant until Unit 2 was shut down for a refueling outage on March 5, 2021. During this refueling outage both the 'A' and 'B' seal packages were replaced. Also, during the latter part of April 2021, the operators noted degrading trends on the Unit 1 'B' recirculation pump seal. In this case, it was determined by the licensee that the best path forward was to remove the unit from service for a mid-cycle outage and replace the seal package, as discussed in Section 71111.20 of this report. Unit 1 was shut down from May 1 to May 12 to replace both the 'A' and 'B recirculation pump seal packages.
The inspectors noted that the typical life cycle for a seal package is six years. In both the cases noted above, the seal package did not last the expected six years. This negative trend was communicated to the licensee that the seal packages may not be operating or installed to their optimal performance.
Observation: Annual Follow-up of Selected Issue: Invalid Unit 2 Group 6 71152 Isolation (NCR 2370489)
The inspectors conducted a detailed review of NCR 2370489, Invalid Unit 2 Secondary Containment and Group 6 Isolation. The inspectors chose this sample because it dealt with the barrier integrity cornerstone. During performance of a Unit 2 Group 6 isolation functional test, the secondary containment isolation signal was received after the reactor building ventilation radiation monitor exceeded the setpoint. The licensee determined the isolation was invalid and realigned the reactor building ventilation. When the ventilation was restored, the radiation monitor output returned to normal.
The licensee performed a detailed root cause analysis and developed several corrective actions to address the deficiencies. The root cause was determined to be moisture intrusion into the electronics within the detector assembly or signal cable connector. The inspectors determined that the licensees plan to address this issue was reasonably commensurate with the safety significance of the equipment that might be affected by this type of equipment failure.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 29, 2021, the inspectors presented the integrated inspection results to John A. Krakuszeski and other members of the licensee staff.
- On April 6, 2021, the inspectors presented the radiation safety inspection results to John A. Krakuszeski and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Drawings D-02526 Reactor Building Residual Heat Removal piping diagram 84
D-25023 Reactor Building High Pressure Coolant Injection System 61
Procedures 1OP-17 Residual Heat Removal System Operating Procedure 139
1OP-18 Core Spray System Operating Procedure 63
2OP-18 Core Spray System Operating Procedure 75
SD-18 Core Spray System 7
71111.05 Fire Plans 0PFP-013 General Fire Plan 54
AD-EG-ALL-1532 NFPA 805 Pre-Fire Plans 2
CSD-BNP-PFP- Control Building Pre-Fire Plans 5
0CB
Procedures AD-OP-ALL-0207 Fire Brigade Administrative Controls 3
CSD-BNP-PFP- Diesel Generator Building Prefire Plans 1
0DG
71111.11Q Procedures 0GP-02 Approach to Criticality and Pressurization of the Reactor 124
AD-OP-ALL-1000 Conduct of Operations 17
71111.12 Engineering EC417774 Commercial Grade (CG) dedication package for a 0
Changes Westinghouse transducer
Procedures AD-EG-ALL-1210 Maintenance Rule Program 2
71111.13 Procedures 0AP-025 BNP Integrated Scheduling 60
AD-OP-ALL-0201 Protected Equipment 8
AD-WC-ALL-0200 On-Line Work Management 19
AD-WC-ALL-0250 Work Implementation and Completion 12
AD-WC-ALL-0410 Work Activity Integrated Risk Management 11
71111.15 Procedures AD-OP-ALL-0105 Operability Determinations and Functionality Assessments 4
71111.18 Engineering EC-41962 DG Fuel Tank Room AFFF degradation 0
Changes
71111.19 Procedures 0PM-RLY035 Functional Test and Lubrication Check of Lockout Relays 20
0PT-80.1 Reactor Pressure Vessel ASME Section XI Pressure Test 79
Work Orders 20437758
71111.20 Procedures 0GP-02 Approach to Criticality and Pressurization of the Reactor 124
0GP-03 Unit Startup and Synchronization 98
Inspection Type Designation Description or Title Revision or
Procedure Date
0GP-04 Increasing Turbine Load to Rated Power 130
0GP-05 Unit Shutdown 202
71111.22 Procedures 0PT-12.1D No. 4 Diesel Generator LOOP/LOCA Test 8
0PT-12.2C No. 3 Diesel Generator Monthly Load Test 120
0PT-34.5.4.0 Foam Concentrate Performance Evaluation and Level 14
Verification
71124.01 Corrective Action NCRs 02282724, Corrective Action Reports
Documents 02320188,
2320798,
2320935,
2321363,
2326606,
2330059,
2333210,
2334856,
2334857,
2339395,
2355138 and
2366896
Miscellaneous 2019 Alpha 2019 Alpha Characterization Report 04/13/2020
Characterization
Report
Procedures 0E&RC-0040 ADMINISTRATIVE CONTROLS FOR HIGH RADIATION 45
AREAS, LOCKED HIGH RADIATION AREAS, AND VERY
AD-PI-ALL-0100 CORRECTIVE ACTION PROGRAM 25
AD-RP-ALL-0002 RADIATION AND CONTAMINATION SURVEYS 2
AD-RP-ALL-0003 RADIOLOGICAL AIR SAMPLING 4
AD-RP-ALL-0004 RADIOLOGICAL POSTING AND LABELING 5
AD-RP-ALL-0005 ACCESS CONTROLS FOR HIGH AND LOCKED HIGH 1
RADIATION AREAS
AD-RP-ALL-0006 PERSONNEL CONTAMINATION MONITORING 1
AD-RP-ALL-0007 CONTROL OF RADIOACTIVE MATERIAL 2
AD-RP-ALL-0009 RADIOGRAPHY 1
Inspection Type Designation Description or Title Revision or
Procedure Date
AD-RP-ALL-0010 RADIOLOGICAL JOB COVERAGE 0
AD-RP-ALL-2002 SRD ALARMS 5
AD-RP-ALL-2004 MANAGEMENT OF LARGE SCALE CONTAMINATION 0
EVENTS
AD-RP-ALL-2008 REMOTE MONITORING 4
AD-RP-ALL-2011 RADIATION PROTECTION BRIEFINGS 5
AD-RP-ALL-2017 ACCESS CONTROLS TO VERIFY HIGH RADIATION AREA 7
AND SUPPLEMENTAL ACCESS CONTROLS FOR HRA
AND LHRA
AD-RP-ALL-2020 RADIOLOGICAL CONTROLS FOR DIVING OPERATIONS 3
Radiation Surveys 511436001 IL Nuclide Distribution Report (DAW) 09/08/2020
BNP-M- ISFSI Survey 12/27/2020
201227-8
BNP-M- Unit 2 Refueling Building - Shield Block removal 03/05/2021
210305-7
BNP-M- Unit 2 Reactor Cavity Initial Entry 03/06/2021
210306-26
BNP-M- Unit 2 Drywell initial Entry 03/6/2021
210306-41
BNP-M- Unit 2 Drywell Initial Entry Survey 03/06/2021
210306-42
BNP-M- Unit 2 Drywell Initial Entry Survey 03/06/2021
210306-5
BNP-M- Unit 2 Reactor Cavity - Rx Head detailed survey 03/07/2021
210307-14
BNP-M- Unit 2 Drywell 67' Elevation - Nozzle Shields open 03/09/2021
210309-24
BNP-M- BNP BRAC DETERMINATION 03/13/2021
21031321-020
BNP-M- U-2 Turbine Building - Valve 2-MVD-S1 Breach 03/23/2021
210323-19
BNP-M- Unit 2 RWCU Heat Exchanger insulation replacement 03/23/2021
210323-9
BNP-M- Unit 2 TIP Drive Boxes [Incore drives] 03/25/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
210325-10
BNP-M- Unit 2 Fuel Pool heat exchanger room Fill and Vent by Ops 03/28/2021
210328-11
BNP-M- Unit 2 Reactor Cavity Post Drain Down/Pre Decon 03/29/2021
210329-1
BNP-M- Unit 2 Reactor Cavity Post Decon and after reactor head set 03/30/2021
210330-1
Radiation Work List of 2021 Unit 2 Including dose and dose rate alarm setpoints by task. 01/25/2021
(B2R25)
List of Active Including dose and dose rate alarm setpoints. 01/25/2021
21 Online
Self-Assessments 02169344-05 Radioactive Material Management 05/24/2018
248333-05 BNP ALARA Self-Assessment 09/12/2019
248336-05 Internal Dosimetry 12/12/2019
2307278-05 RP Field Operations 10/08/2020
2307279-05 BNP Respiratory Protection Program Assessment 09/17/2020
71124.02 ALARA Plans 2021 Site ALARA goals 02/18/2021
2018 - 2022 Brunswick Nuclear Plant ALARA Long Range Plan 2018
UPDATE
20 Brunswick Nuclear Plant ALARA Long Range Plan, including 12/11/2019
source term reduction initiatives
Calculations 2 -RF21-01 Temporary Shielding Request (TSR), U2 DW 5', 17' and 38', 02/04/2021
GA dose rate reduction on RCR piping from 5' to 48'
Elevations
-RF21-08 Unit 2 117' Refuel Floor, RB 117' Shield Racks 02/04/2021
2-RF21-05 Temporary Shielding Request, U2 Rx Cavity Inner & Outer 02/04/2021
Bellows, Reduce GA Dose Rates for Rx disassembly and
reassembly
Miscellaneous Special ALARA Committee Meeting Minutes 01/13/2021
Special ALARA Committee Meeting Minutes 01/20/2021
ALARA Committee Meeting Minutes 01/25/2021
Brunswick Unit 2 BRAC Survey Data - 2005 through 2021 03/21/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
Power BI Brunswick ALARA Dose tracking reports 3/6/2021
through 3/31/2021
Procedures 0AI-90 Cobalt Reduction Program 8
AD-RP-ALL-9000 ALARA PROGRAM 9
AD-RP-ALL-9001 ALARA PLANNING 5
MNT-NGGC-0003 Radiation Shielding Use 17
71124.03 Calculations Air Sample obtained inside the tent during 2B Turbine rotor 3/11/2021
blade sand blasting activity
Gamma Spec # Air sample obtained during MSR Cross-Over Piping breach 3/9/2021
210478
Gamma Spec # Air Sample obtained in the U-2 Drywell under vessel during 3/22/2021
210580 SRM installation
Calibration S/N 2870260 SCBA Annual Flow Tests dated 8/28/2019 and 8/27/2020
Records S/N 4821117 SCBA Annual Flow Tests dated 8/28/2019 and 8/26/2020
S/N 8030114807 PortaCount Pro Model 8030 Calibration Certificate 11/20/2020
S/N 8030114808 PortaCount Pro Model 8030 Calibration Certificate 12/03/2020
Serial Number Self-Contained Breathing Apparatus (SCBA) Annual Flow
(S/N) 1830280 Tests dated 8/28/2019 and 8/27/2020
Corrective Action NCRs 02264578, Corrective Action Documents
Documents 02276211,
278444,
286549,
287736,
2304096 and
2334838
Miscellaneous Scott SCBA Maintenance and Overhaul Technician 2/28/2020
Certification for Vallen Distribution Inc. service personnel
0E&RC-0292 Monthly SCBA and Respirator Inspection and Inventory - 01/19/2021
January 2021
0E&RC-0292 Monthly SCBA and Respirator Inspection and Inventory - 02/09/2021
February 2021
Procedures 0E&RC-0135 SAMPLING OF BREATHING AIR 20
0E&RC-0136 SET UP AND USE OF AIR LINE RESPIRATORY 19
PROTECTION DEVICES
Inspection Type Designation Description or Title Revision or
Procedure Date
0E&RC-0225 TESTING OF HEPA PARTICULATE FILTERS AND SEALS 11
0E&RC-0229 CONTROL AND USE OF HEPA AIR FILTRATION UNITS 11
0E&RC-0311 CALIBRATION OF AIR SAMPLING EQUIPMENT 22
0E&RC-0351 OPERATION OF ECONOAIR L-5P LAPEL AIR SAMPLERS 0
AD-RP-ALL-0008 USE AND CONTROL OF HEPA FILTRATION AND VACUUM 0
EQUIPMENT
AD-RP-ALL-2014 WORK IN ALPHA ENVIRONMENTS 7
AD-RP-ALL-2015 ALPHA RADIATION CHARACTERIZATION 4
AD-RP-ALL-2019 TEDE-ALARA EVALUATIONS AND DAC-HOUR TRACKING 3
AD-RP-ALL-6001 QUANTITATIVE FIT TESTING 3
AD-RP-ALL-6002 INSPECTIONS OF SELF-CONTAINED BREATHING 2
APPARATUS (SCBA) AND ASSOCIATED EQUIPMENT
AD-RP-ALL-6005 POWERED AIR-PURIFYING RESPIRATORS 1
PD-RP-ALL-6000 RESPIRATORY PROTECTIVE EQUIPMENT APPROVAL 3
AND ISSUE
Radiation Surveys Radioactive Air Sample Log and sample results from 3/6/2021
to 3/26/2021.
Work Orders 20101777 01 LR, Perform 1-SGT-1B, 1PT-15.1.2B Filter Test
20192264 01 CB Emergency Filter System Test (A Train)
20192794 01 LR, Perform 1PT-15.1.2A, SBGT 1A Filter Test
272257 02 LR, Perform 1MST-SBGT500B Filter Test
20342806 08 LR, Perform 1MST-SBGT500A, SBGT 1A Filter Test
20348040 01 CB Emergency Filter System Test (A Train)
71124.04 Calculations RWP 2500, Task AD-RP-All-4015, Attachment 3, Multi-Pack Form EDEX
calculations for eight (8) individuals performing CRD exchange
activities - 3/16/2021 to 3/19/2021.
Corrective Action NCRs 02263673,
Documents 02269618,
2319556,
2320487,
2323566, and
2344441
Engineering CSD-RP-ALL- Brunswick Passive Whole Body Sensitivity Study 5/25/2018
Evaluations 4001
Inspection Type Designation Description or Title Revision or
Procedure Date
Dosimetry BNP DSC/ISFSI NEUTRON TLD CORRECTION FACTOR 09/25/2014
Technical Report: VALIDATION
14-02
Miscellaneous Whole Body Counter nuclide libraries for routine analysis and 02/10/2021
screening for medical isotopes.
CFR Part 61 Brunswick Dry Active Waste Characterization [Nuclide 09/08/2020
Distribution Report]
In-Vitro Bioassay GEL Laboratories Tritium Bioassay Sample analysis results -
Work Order #s 536569 and 536647.
Bioassay samples obtained 3/3/and 3/4/2021.
NVLAP LAB Duke Energy Dosimetry Laboratory NVLAP Certificate of
CODE: 100505-0 Accreditation - 2019, 2020, and 2021
Procedures AD-RP-ALL-0006 Personnel Contamination Monitoring 1
AD-RP-ALL-2003 Investigation of Unusual Radiological Occurrences 4
AD-RP-ALL-2010, Skin Dose from Contamination 2
Skin Dose
AD-RP-ALL-4014 Dosimetry Management 10
CSD-RP-ALL- Prospective Determination for Occupational Exposure 0
4016
TE-RP-ALL-2007 Neutron Dose Tracking 3
TE-RP-ALL-4001 Declared Pregnant Worker 3
Self-Assessments Self-Assessment 2020 Dosimetry Lab Internal Audit 8/4/2020
2300425
Self-Assessment Brunswick Internal Dosimetry 12/12/2019
Number:
248336
Self-Assessment Brunswick External Dosimetry 12/3/2020
Number:
2307281-05
Self-Assessment: Duke Energy Dosimetry Laboratory 2020 NVLAP On-Site 9/16/2020
2300428 Assessment
71151 Calculations BNP-MECH-MSPI BNP Mitigating System Performance Index Plant Basis 2
Document
Corrective Action NCRs 02320798,
Inspection Type Designation Description or Title Revision or
Procedure Date
Documents 02332479,
2337906,
2340880,
2359530, and
2360615
Miscellaneous Brunswick 2020 Annual Radioactive Liquid Release Summary 02/18/2021
Report [including MEI total dose and isotopic release totals for
the year]
Brunswick 2020 Annual Radioactive Gaseous Release 02/18/2021
Summary Report [including MEI total dose and isotopic
release totals for the year]
Electronic Dosimeter (ED) Dose and Dose Rate Alarm Logs
from 1/1/2020 through 1/31/2021
Procedures AD-PI-ALL-0700 Performance Indicators 4
AD-PI-ALL-0700 Performance Indicators 4
71152 Corrective Action AR-02370489 Invalid U2 Group 6 0
Documents
23