05000324/FIN-2014003-04
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Licensee Procedure OPS-NGGC-1305, Operability Determinations, states, in part, a structure, system, or component is Operable if the TS definition of OPERABLE is satisfied. Technical Specification 3.6.4.1, Secondary Containment, and TS 3.6.4.2, Secondary Containment Isolation Dampers, require secondary containment and SCIDs to be operable. Contrary to the above, on March 9, 2014, Procedure 0MMM-054, Temporary Power Feed Documentation, was not appropriate to the circumstances and did not require an operability determination when SCIDs was powered from a nonsafety-related power supply. The licensee failed to declare the SCIDs inoperable while powered from temporary nonsafety-related electrical power and OPDRVs were in progress. The SCIDs system was inoperable because the normal or emergency electrical power was not capable of performing its related support function. The finding is more than minor because it is associated with the configuration control attribute of the Barrier Integrity Cornerstone and adversely affects the cornerstone objective to provide reasonable assurance that physical design barriers (standby gas treatment) protect the public from radionuclide releases caused by accidents or events. Specifically, the finding is more than minor since the SCIDs system was inoperable. Using IMC 0609, Appendix A, issued June 9, 2012, The SDP for Findings At-Power, the inspectors determined the finding screened to very low safety significance (Green) since the finding only represented a degradation in the radiological barrier function of secondary containment standby gas treatment. The licensee entered this issue into the CAP as NCR 673858. The NRC issued EGM 11-003, Revision 2, to exercise enforcement discretion and not cite licensees for TS violations related to the conduct of OPDRVs with secondary containment inoperable provided that certain criteria were met. One of the criteria was that the licensee must follow all other TS applicability and action requirements. Since the licensee was conducting OPDRVs during the time of the inoperability, the licensee did not meet the criteria in EGM 11-003 for the staff to consider exercising discretion on March 9, 2014. For the inoperability, TS 3.6.4.2 required initiation of action to suspend OPDRVs immediately, as did TS 3.6.4.1, Secondary Containment, for inoperable secondary containment. Therefore, Unit 1 was in a condition prohibited by TS 3.6.4.1, and TS 3.6.4.2. |
| Site: | Brunswick  |
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| Report | IR 05000324/2014003 Section 4OA7 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | D Jackson G Hopper J Dodson M Catts M Schwieg |
| Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
| INPO aspect | |
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Finding - Brunswick - IR 05000324/2014003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Brunswick) @ 2014Q2
Self-Identified List (Brunswick)
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