05000324/FIN-2017002-01
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Finding | |
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| Title | Implementation of EGM 11- 003, Revision 3, Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements During Operations with a Potential for Draining the Reactor Vessel |
| Description | Implementation of EGM 11- 003, Revision 3, Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements During Operations with a Potential for Draining the Reactor Vessel a. Inspection Scope The inspectors reviewed the plants implementation of NRC EGM 11 -003, Revision 3, during Unit 2 maintenance activities for operations with a potential for draining the reactor vessel (OPDRVs) , during the Unit 2 refueling outage. Inspectors verified that for all dates, all other TS requirements were met during OPDRVs with secondary containment inoperable. Documents reviewed are listed in the Attachment. b. Findings Description . During the Unit 2 refueling outage, the OPDRVs activities are listed below: March 21, 2017: 6 gallons per minute leakage for maintenance associated with the 2B recirculation pump seal rebuild March 23, 2017: 48 gallons per minute leakage for hydraulic control unit draining to support rod maintenance March 24, 2017: 65 gallons per minute leakage to close the excess flow check valve and cap the drain line March 27, 2017: 71.2 gallons per minute leakage to replace the low power range monitors and intermediate power range monitors These activities took place without secondary containment being operable. Enforcement . TS 3.6.4.1, Secondary Containment, requires that secondary containment be operable and is applicable during OPDRVs. The required action if secondary containment is inoperable in this condition i s to initiate actions to suspend OPDRVs immediately. Contrary to the above, on March 21, 2017, March 23, 2017, March 24, 2017 , and March 27, 2017 , the licensee failed to maintain secondary containment operable while performing OPDRVs. However, because the violations were identified during the discretion period described in EGM 11 -003, Revision 3, and the licensee met the criteria established in the EGM prior to and during these activities, the NRC exercised enforcement discretion (Enforcement Action -17- 123 ) for the dates of March 21, 2017, March 23, 2017, March 24, 2017, and March 27, 2017, in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforc ement action for this v iolation. The inspectors observed that Brunswick has already submitted a license amendment request (BSEP 17- 0060) on June 29, 2017 which was accepted for review by the NRC on July 18, 2017. The licensee entered this issue into the CAP as NCR 2110409. |
| Site: | Brunswick  |
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| Report | IR 05000324/2017002 Section 4OA5 |
| Date counted | Jun 30, 2017 (2017Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | M Catts M Schwieg D Jackson S Rose |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - Brunswick - IR 05000324/2017002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Brunswick) @ 2017Q2
Self-Identified List (Brunswick)
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