Brunswick Steam Electric Plant Integrated Inspection Report ...

November 6, 2020

Mr. John Krakuszeski Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 470 River Road, SE (M/C BNP001) Southport, NC 28461 SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT – INTEGRATED INSPECTION

REPORT 05000324/2020003 AND 05000325/2020003 Dear Mr. Krakuszeski: On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brunswick Steam Electric Plant. On November 2, 2020, 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. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Brunswick Steam Electric Plant.

J. Krakuszeski 2

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 cc w/ encl: Distribution via LISTSERV®

J. Krakuszeski 3

SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT – INTEGRATED INSPECTION REPORT 05000324/2020003 AND 05000325/2020003

DATED: November 6, 2020 DISTRIBUTION: M. Kowal, RII S. Price, RII L. Gibson, RII RidsNrrPMBrunswick Resource RidsNrrDro Resource

ADAMS ACCESSION NUMBER: ML20311A210

OFFICE RII: DRP RII: DRP RII: DRP

NAME P. Niebaum J. Steward G. Smith

DATE 11/05/2020 11/05/2020 11/05/2020

OFFICIAL RECORD COPY

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Numbers: 05000324 and 05000325 License Numbers: DPR-62 and DPR-71 Report Numbers: 05000324/2020003 and 05000325/2020003 Enterprise Identifier: I-2020-003-0059 Licensee: Duke Energy Progress, LLC Facility: Brunswick Steam Electric Plant Location: Southport, NC Inspection Dates: July 01, 2020 to September 30, 2020 Inspectors: D. Bacon, Senior Operations Engineer J. Bundy, Operations Engineer P. Niebaum, Senior Project Engineer M. Schwieg, Reactor Inspector G. Smith, Senior Resident Inspector J. Steward, Resident Inspector Approved By: Stewart N. Bailey, Chief

Reactor Projects Branch 4 Division of Reactor Projects

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SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee’s performance by conducting an integrated inspection at Brunswick Steam Electric Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC’s program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Provide Adequate HPCI Preventive Maintenance Procedures Cornerstone Significance Cross-Cutting

Aspect Report Section

Mitigating Systems

Green NCV 05000324/2020003-01 Open/Closed

None (NPP) 71153

A green self-revealed NCV of TS 5.4.1, “Procedures” was identified for the failure to provide an adequate maintenance procedure associated with the High Pressure Coolant Injection (HPCI) system. Specifically, electric governor – remote (EGR) hydraulic actuator tubing was not cleaned in accordance with the vendor technical manual and the Electric Power Research Institute (EPRI) Terry Turbine User’s Manual. As a result, internally generated debris likely caused the U2 HPCI EGR to bind intermittently, resulting in a failure of the EGR to control turbine speed during the initial turbine roll, which led to an overspeed trip of the HPCI turbine during a surveillance test on June 12, 2019.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000324/2019-003-00 LER 2019-003-00 for

Brunswick, Unit 2, High Pressure Coolant Injection (HPCI) Inoperable

71153 Closed

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PLANT STATUS Unit 1 began the inspection period at 95 percent rated thermal power (RTP) due to an exhausted condensate demineralizer. Following replacement of the resin bed, the unit was restored to 100 percent RTP on July 3, 2020 where it continued to operate until the onset of Hurricane Isaias on August 3, 2020. Just prior to the hurricane, Unit 1 was reduced in power to approximately 20 percent RTP and the main generator was taken offline due to a pre-existing ground. On August 4, Unit 1 experienced a loss of off-site power (LOOP) and an automatic reactor scram caused by storm-related debris interacting with the Unit 1 station auxiliary transformer. The operators stabilized the unit in Mode 3 until the storm passed. The licensee then made the decision to shut the plant down to Mode 4. The licensee then entered a forced outage to execute repairs to the main generator to eliminate the ground in the rotating element of the generator. Following completion of the forced outage, Unit 1 was taken critical on August 20. Plant startup continued and the main generator output breaker was closed on August 22, followed by a power ascension. On August 26, the unit reached 100 percent RTP and continued to operate there for the remainder of the inspection period Unit 2 began the period at 100 percent RTP and operated there until August 26, 2020, when power was reduced to 85 percent RTP due to a failure of the heater drain deaerator tank level controller. Following repairs to the controller, the unit was restored to 100 percent RTP where it continued to operate until September 7, 2020, when the 4B feedwater heater level controller failed resulting in the operators lowering power to 70 percent RTP. Following repairs to the 4B feedwater heater level control and a control rod sequence exchange a power ascension was commenced. 100 percent RTP was reached on September 13 where the unit continued to operate until September 19 when power was reduced to 20 percent RTP and the turbine taken off line in order to perform repairs to the 'A' phase generator no-load disconnect links. On September 20, the disconnect links were repaired , the generator output breaker was closed and a power ascension was commenced. 100 percent RTP was reached on September 23 where the unit continued to operate for the remainder of the inspection 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 portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted

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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 71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-

significant systems from impending Hurricane Isaias on August 3 and August 4, 2020. External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures,

and equipment are consistent with the licensee’s design requirements and risk analysis assumptions for coping with external flooding. Specific areas inspected included:

• Units 1 and 2 Reactor Buildings • Emergency Diesel Generator Building • Service Water Building

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: (1) Unit 2 nuclear service water (NSW) and conventional service water (CSW) while the

Unit 2 'A' CSW pump was out-of-service (OOS) for planned replacement on July 6, 2020

(2) Unit 2 Division 1 and Division 2 Backup Nitrogen System on September 22, 2020 (3) Unit 1 Division 1 and Division 2 Backup Nitrogen System on September 24, 2020

71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 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) Control Building (49’ EL) and Central Alarm Station (52’ EL) on July 9, 2020 (2) Technical Support Center (TSC) Simulator Building on July 16, 2020 (3) Unit 2 Reactor Building (20' EL) on July 20, 2020 (4) Unit 2 Reactor Building (50' EL) on July 20, 2020 (5) Supplemental Diesel Generator Platform on August 4, 2020 (6) Modular Chiller Plant (MCP) on August 4, 2020 (7) Emergency Diesel Building (2' EL) on August 26, 2020

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(8) Radwaste Building (35’ EL and 47’ EL) on September 2, 2020 Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an

unannounced fire drill on September 21, 2020. The fire was simulated in the Unit 1 'B' battery room.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on September 3, 2019. Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensee’s annual requalification operating test. Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives. Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised. Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination. Operator License Conditions The inspectors evaluated the licensee’s program for ensuring that licensed operators meet the conditions of their licenses. Control Room Simulator The inspectors evaluated the adequacy of the facility licensee’s control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

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Problem Identification and Resolution The inspectors evaluated the licensee’s ability to identify and resolve problems associated with licensed operator performance.

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 the Unit 1 reactor start-up following the main generator forced outage on August 20, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the following two scenarios associated with the 2020

annual operator requalification exam: • Simulator exam consisting of a scenario that incorporated a reactor feed pump

speed demand failure, inadvertent HPCI initiation, manually isolable main steam leak, stuck open safety relief valve (SRV) with a failed tailpipe leading to emergency depressurization. Exam was conducted on September 22, 2020

• Simulator exam consisting of a scenario that incorporated a reactor building ventilation rad monitor failed low, steam line break in the drywell, loss of electrical buses 2C and E-4, loss of condensate booster pumps, drywell to suppression chamber downcomer rupture, and pressure suppression pressure limit exceeded leading to an emergency depressurization. Exam was conducted on September 29, 2020.

71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01) (2 Samples)

On September 30, 2020, the inspectors completed an evaluation of the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function: (1) Performance Criteria Exceeded for Station Batteries (NCR 2340789) (2) Variable Frequency Drive (VFD) System Component Failures (NCR 2312417)

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) Engineering Change (EC) 417774 Commercial Grade Dedication package

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

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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 elevated risk due to reactor core isolation and cooling (RCIC) outage on July

16, 2020 (2) Unit 1 elevated risk due to 'B' train residual heat removal (RHR) outage on July 30,

2020 (3) Unit 1 elevated risk due to the EDG No. 1 maintenance outage on August 26, 2020 (4) Emergent failure of Battery 1A2 Cell No. 58 during quarterly surveillance on

September 28, 2020

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments: (1) Excessive temps in Main Steam Tunnel (NCR 2340045 and 2340046) (2) Unit 1 main generator ground (NCR 2338925) (3) 1A2 Battery Cell 58 low voltage (NCR 2349867) (4) Unit 1 Drywell to torus vacuum breaker (1-CAC-X18D) failure (NCR 2349338) (5) Unit 1 safety relief valve (SRV) lift pressures found outside of TS requirements (NCR

2343883) (6) Buried fire protection water leak outside of Service Water Pump House results in Unit

2 SW Sprinkler System removal from service (NCR 2348007)

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) BNP Security Owner Controlled Area (SOCA) Modification EC 415047

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the following post maintenance test (PMT) activities to verify system operability and functionality: (1) PMT on RCIC Barometric Condenser Pump following DC contactor replacement in

accordance with (IAW) work order (WO) 20321006 (2) PMT on 1-E51-F008, Steam Supply Outboard Isolation Valve, IAW WO 20379330 (3) PMT on Unit 2 HCU 30-23 Directional Control Valve Leaks IAW WO 20182046 (4) PMT on Unit 2 HCU 42-47, Replace Directional Control Valve IAW WO 20319619

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71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the Unit 1 forced outage activities following Hurricane Isaias

from August 4 to August 20, 2020. This outage mainly focused on repairs to the main generator rotor which developed a ground approximately two weeks prior to the hurricane making landfall

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) Unit 1 Drywell pump out rate IAW 0OI-02.3, Drywell Leakage Control (RCS)

Inservice Testing (IP Section 03.01) (2 Samples)

(1) Unit 2 Service Water Pump and Discharge Valve Operability Test for 2C CSW Pump

(IST) (2) Unit 1 RHR Service Water System Operability Test for 'C' RHR service water booster

pump (IST)

71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated: (1) Annual Licensed Operator Requalification Exam with Emergency Plan classification

on September 22 and September 29, 2020

OTHER ACTIVITIES – BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) Unit 1 (July 1, 2019 - June 30, 2020) (2) Unit 2 (July 1, 2019 - June 30, 2020)

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1 (July 1, 2019 - June 30, 2020) (2) Unit 2 (July 1, 2019 - June 30, 2020)

71152 - Problem Identification and Resolution

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Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample) The inspectors reviewed the licensee’s implementation of its corrective action program related to the following issues: (1) Feedwater heater level control system equipment performance (NCR 2284485)

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated a Notice of Unusual Event (NOUE) and licensee’s response

on August 4, 2020. The NOUE was declared due to a loss of offsite power on Unit 1 due to Hurricane Isaias.

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event report (LER): (1) LER 05000324/2091-003-00, High Pressure Coolant Injection (HPCI) Inoperable

(ADAMS Accession No. ML19213A159). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153.

INSPECTION RESULTS

Observation: Feedwater Heater Level Control System Equipment Performance 71152 Erratic feedwater heater level control issues at Brunswick continue to challenge operators during full power operations. The inspectors reviewed NCR 2337735 as a sample of a selected issue to follow-up to ensure the licensee has initiated corrective actions commensurate with safety significance of the issue. For Unit 1, these issues date back to July of 2018 and for Unit 2 back to April 2019 and includes affected feedwater heaters 3A, 3B, 4A, 4B, 5A and 5B. High-High Level in a feedwater heater results in a loss of feedwater heating and causes power to increase and entry into an abnormal operating procedure. The NCR provides an aggregate work order history for both units in the time frames as noted previously that were initiated to address erratic level control of the associated controllers. The connections that are problematic were isolated to the small junction boxes at the linear variable differential transformer (LVDT) and at the level transmitter. Engineering Change Packages were written to address the issues in both Units. For Unit 1, EC 418231 installed improved LVDT and displacers assembly performance. On Unit 2, EC 418259 addressed the overall feedwater heater level control instrumentation reliability and will be implemented during the next refueling outage.

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Failure to Provide Adequate HPCI Preventive Maintenance Procedures Cornerstone Significance Cross-Cutting

Aspect Report Section

Mitigating Systems

Green NCV 05000324/2020003-01 Open/Closed

None (NPP) 71153

A green self-revealed NCV of TS 5.4.1, “Procedures” was identified for the failure to provide an adequate maintenance procedure associated with the High Pressure Coolant Injection (HPCI) system. Specifically, electric governor – remote (EGR) hydraulic actuator tubing was not cleaned in accordance with the vendor technical manual and the Electric Power Research Institute (EPRI) Terry Turbine User’s Manual. As a result, internally generated debris likely caused the U2 HPCI EGR to bind intermittently, resulting in a failure of the EGR to control turbine speed during the initial turbine roll, which led to an overspeed trip of the HPCI turbine during a surveillance test on June 12, 2019. Description: On June 12, 2019, during performance of quarterly surveillance testing in accordance with 0PT-09.2, “HPCI System Operability Test” on Unit 2, the HPCI turbine experienced an overspeed trip. Following the overspeed trip, the turbine coasted down and reset, then restarted and rolled to rated conditions as designed. The response time of the system was 83 seconds, exceeding the 60-second acceptance criteria, and the licensee determined the HPCI system was inoperable. This was initially reported to the NRC on June 13, 2019 (Event Number 54116). The last Unit 2 HPCI system outage where the EGR was inspected occurred in 2017. This would have been an opportunity to implement EGR tube cleaning as discussed in the EPRI guidance. According to the licensee, EGR tubing inspections and cleanings were added to the EPRI guidance in 2013. The licensee failed to update their site-specific procedures to implement this guidance to clean and inspect the EGR tubing that connects the EGR to the remote servo. The EPRI guidance also discussed examining the drained oil from the tubing to look for evidence of moisture and particulate. Following the event on June 12, 2019, the licensee determined the cause of the HPCI turbine overspeed trip was the result of intermittent binding of the EGR which impacted the operation of the HPCI governor valve used to control HPCI turbine speed. The licensee’s equipment reliability checklist (AR 2277159) determined the intermittent binding of the EGR was most likely the result of internally generated debris due to not cleaning the associated EGR tubing during previous EGR inspections in accordance with the EPRI Terry Turbine User’s Manual. The EGR was sent to an off-site facility for inspection and to determine the cause of the intermittent binding. Upon disassembly, minor nicks and abrasive wear were observed on the leading edge of the pilot valve control land. Also, minor wear was noted around the pilot valve bushing control port, in the same relative location where the pilot valve control land operates. According to the licensee, debris lodged in this area of the EGR would prevent axial movement of the pilot valve, preventing it from porting oil to control turbine speed via the remote (servo) actuator. Corrective Actions: The licensee replaced the EGR on the Unit 2 HPCI skid, revised plant procedures to implement EGR tube cleaning and inspections during future HPCI maintenance outages and conducted a satisfactory post maintenance test on June 15, 2019. The Unit 2 HPCI system was declared operable on June 16, 2019.

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Corrective Action References: AR 2277159 Performance Assessment: Performance Deficiency: Failure to provide an adequate maintenance procedure to clean and inspect the HPCI EGR tubing was a performance deficiency. This resulted in internally generated debris which caused intermittent binding of the U2 HPCI EGR and impacted the ability to control HPCI turbine speed during a surveillance test on June 12, 2019. Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the intermittent binding of the EGR adversely impacted the reliability of the U2 HPCI system as evidenced by the turbine overspeed trip on the initial HPCI system start during quarterly surveillance testing. Significance: The inspectors assessed the significance of the finding using Appendix A, “The Significance Determination Process (SDP) for Findings At-Power.” The inspectors assessed the significance of the finding using Appendix A, “The Significance Determination Process (SDP) for Findings At-Power.” The finding was screened by Exhibit 2, “Mitigating Systems Screening Questions,” under Section A, “Mitigating SSCs and PRA Functionality,” and it was determined the performance deficiency required a detailed risk evaluation because the degraded condition represented a loss of the PRA function of a single train TS system (such as HPCI/HPCS) for greater than its TS allowed outage time. A regional senior reactor analyst (SRA) conducted a detailed risk evaluation using NRC IMC 0609 Appendix A, “The Significance Determination Process (SDP) for Findings At-Power.” The exposure period was assumed to be from the last successful HPCI Surveillance run on 4/13/19 until the unsatisfactory surveillance run on 6/12/19 (60 days) plus the repair time of 2 days. Since the auxiliary oil pump was run on a weekly basis during the period and the governor valve cycles during this activity, it is not certain when the debris was introduced to the pilot valve so a T/2 approach for exposure time was used. This would be 31 days. Since the failure was self-recoverable and only resulted in a delay of HPCI flow being established (approximately 20 seconds outside of technical specification acceptance criteria), only the sequences where HPCI flow is time critical were considered. These were Medium Break (MLOCA) and Small Break Loss of Coolant Accidents (SLOCA). For all other sequences, the safety function would still be achieved even if HPCI flow is delayed. The SRA used SAPHIRE 8 version 8.2.1 and the Brunswick Unit 2 SPAR Model Revision 8.57 dated March 2019. The SRA conducted a conditional risk assessment for MLOCA and SLOCA sequences setting event HCI-TDP-FS-C001, HPCI Fail to Start, to True for 31 days. The dominant accident sequence was a MLOCA with a failure of HPCI and Failure for operators to manually depressurize. The change in core damage frequency was 6.76 E-8 corresponding to a finding of very low safety significance (Green). Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. According to the licensee, changes to the EPRI guidance that included inspections and cleaning of the EGR tubing occurred in 2013. Enforcement:

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Violation: Technical Specifications 5.4.1.a, “Procedures” required in part, written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972. Section I.1 of Appendix A of Regulatory Guide 1.33 required in part, maintenance which can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, licensee procedures used to perform 2017 U2 HPCI maintenance (EGR inspections) were not appropriate to the circumstances. Specifically, the maintenance procedures used did not include guidance to clean and inspect the tubing that connects the EGR with the remote servo. Debris was left in the tubing which resulted in binding and degradation of the EGR pilot valve. As a result, the U2 HPCI system was declared inoperable following a turbine overspeed trip during surveillance testing on June 12, 2019. Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

• On November 2, 2020, the inspectors presented the integrated inspection results to John Krakuszeski and other members of the licensee staff.

• On September 17, 2020, the inspectors presented the Licensed Operator Requalification Program and Licensed Operator Performance Inspection (IP 71111.11B) inspection results to John Krakuszeski, Site Vice President and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Procedure

Type Designation Description or Title Revision or Date

71111.01 Procedures 0AI-68 Brunswick Nuclear Plant Response to Severe Weather Warnings

59

0AOP-13.0 Operation During Hurricane, Flood Conditions, Tornado, or Earthquake

70

0BNP-TR-019 External Event Protection Features 9 AD-EG-BNP-1619

External Events Protection Program 2

DBD-144 External and Internal Flooding Topical Design Basis Document

1

71111.04 Drawings D-07368 Reactor Building Instrument Air Supply Nitrogen Backup Piping Diagram

21

D-73068 Reactor Building Instrument Air Supply Nitrogen Backup Piping Diagram

16

Miscellaneous SD-46 Pneumatic Systems 17 UFSAR, Section 9.3.1

Compressed Air System 27

Procedures 0OP-46 Instrument and Service Air System Operating Procedure 194 2OP-43 Service Water System Operating Procedure 168 SD-43 Service Water System 27

71111.05 Fire Plans CSD-BNP-PFP-0CB

Control Building Pre-fire Plans 5

CSD-BNP-PFP-0DG

Diesel Generator Pre-Fire Plans 1

CSD-BNP-PFP-0MBOCA

Miscellaneous Buildings - Owner Controlled Area 1

CSD-BNP-PFP-0PBAA

Power Block Auxiliary Areas Pre-Fire Plans (SW, RW, AOG, TY, EY, PDC, DGS, MCP)

2

CSD-BNP-PFP-2RB

Reactor Building Pre-Fire Plans 0

Procedures AD-EG-ALL-1520 Transient Combustible Control 13 71111.11Q Procedures 0GP-02 Approach to Criticality and Pressurization of the Reactor 122

AD-OP-ALL-1000 Conduct of Operations 17

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Inspection Procedure

Type Designation Description or Title Revision or Date

LORX-002 Licensed Operator Requalification Simulator Evaluation Guide

17

LORX-014 Licensed Operator Requalification Simulator Evaluation Guide

18

71111.12 Corrective Action Documents

NCR 2312417 VFD System Component Failures 01/23/2020

Miscellaneous Electronic Database

MRule Manager 09/30/2020

NUMARC 93-01 Industry Guidelines for monitoring the effectiveness of maintenance at Nuclear Power Plants

4A

Procedures AD-EG-ALL-1210 Maintenance Rule Program 2 AD-PI-ALL-0106 Cause Investigation Checklists 4

71111.13 Corrective Action Documents

NCR 2349867 Battery 1A-2 Cell 58 Low Voltage 09/23/2020

Procedures 0AP-025 BNP Integrated Scheduling 59 AD-OP-ALL-0201 Protected Equipment 6 AD-WC-ALL-0200

On-Line Work Management 17

AD-WC-ALL-0250

Work Implementation and Completion 12

AD-WC-ALL-0410

Work Activity Integrated Risk Management 10

Work Orders 20184467 Batt 1A-2 Cell 58 Low Voltage 09/23/2020 71111.15 Corrective Action

Documents NCR 2343883 Three Unit 1 SRV lift pressures found outside of TS

requirements 08/13/2020

Drawings D-02043, sh 1 Plant Fire Protection System Piping Diagram 20 D-02304 Service Water Radwaste and Treatment Buildings Fire

Protection Sprinkler System Piping Diagram 15

Miscellaneous 0FP-0092 Risk Informed Compensatory Actions for Fire Protection System Impairements

2

Procedures 0PLP-01.2 Fire Protection System Functionality, Action, and Surveillance Requirements

53

AD-EG-ALL-1106 Configuration Management and Margin Management 6 AD-EG-ALL-1522 Duties of a Compensatory Fire Watch 12

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Inspection Procedure

Type Designation Description or Title Revision or Date

AD-OP-ALL-0105 Operability Determinations 6 71111.18 Engineering

Changes 415047 BNP SOCA Modification 05/13/2020

71111.19 Procedures 0PT-10.1.8 RCIC System Valve Operability Test 42 0PT-10.15.L RCIC Barometric Condenser Vacuum Pump and

Condensate Pump Local Operability Test 12

2OP-07 Reactor Manual Control System Operating Procedure 107 71111.20 Procedures 0GP-02 Approach to Criticality and Pressurization of the Reactor 122

0GP-03 Unit Startup and Synchronization 95 0GP-04 Increasing Turbine Load to Rated Power 128 0GP-05 Unit Shutdown 199

71111.22 Miscellaneous Reactor Operator Logs

Drywell pump out rate September 30, 2020

Procedures 0OI-02.3 Drywell Leakage Control 9 0PT-08.1.1.4A RHR Service Water System Operability Test - Loop A 88 2PT-24.1-2 Service Water Pump and Discharge Valve Operability Test 86

71151 Procedures AD-PI-ALL-0700 Performance Indicators 4 71152 Corrective Action

Documents NCR 2337735 Feedwater Level Control WO aggregate review 07/01/2020

Engineering Changes

418231 Unit 1 Feedwater Level Control Instrumentation Reliability Issues with 3A, 3B, 4A, 4B, 5A, and 5B Feedwater Heaters

08/31/2020

418259 Unit 2 Feedwater Heater Level Control Instrumentation Reliability Issues with 3A, 3B, 4A, 4B, 5A, and 5B Feedwater Heaters

09/30/2020

Procedures AD-PI-ALL-0100 Corrective Action Program 24