05000324/LER-2013-001
| Brunswick Steam Electric Plant (Bsep), Unit 2 | |
| Event date: | 03-07-2013 |
|---|---|
| Report date: | 05-06-2013 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3242013001R00 - NRC Website | |
Energy Industry Identification System (EIIS) codes are identified in the text as [XX].
Introduction Initial Conditions At the time of the event, Unit 2 was in Mode 5, at 0 percent of rated thermal power (RTP).
Reportability Criteria On March 7, 2013, Unit 2 implemented the guidance of EGM 11-003, Revision 1, "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," dated December 20, 2012. Consistent with EGM 11-003, Revision 1, secondary containment [NG] operability was not maintained during Operations With a Potential for Draining the Reactor Vessel (OPDRV) activities, and Required Action C.1 of Technical Specification (TS) 3.6.4.1, "Secondary Containment," was not completed. EGM 11-003, Revision 1, was implemented four additional times during the 2013 Unit 2 refueling outage. These conditions are being reported in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by the plant's TSs.
Event Description
On December 20, 2012, the NRC issued EGM 11-003, Revision 1. EGM 11-003, Revision 1, provides generic enforcement discretion to allow implementation of specific interim actions as an alternative to full compliance with plant technical specifications related to secondary containment operability during Mode 5 OPDRV activities. To ensure compliance with the interim actions specified in the EGM, BSEP developed plant procedure OSP-12-001, "EGM 11-003 OPDRV Activities." This procedure, which implements compensatory actions that meet or exceed those specified in EGM 11-003, Revision 1, was implemented on five occasions during the 2013, Unit 2 refueling outage. The following list provides the durations of each period during which EGM 11-003, Revision 1, was implemented (i.e., OPDRV activities were in progress with secondary containment inoperable). Unit 2 was in Mode 5 during these periods.
EGM 11-003, Revision 1 Implementation Duration 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, 10 minutes 9 days, 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 2 days, 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />, 5 minutes 36 minutes 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, 18 minutes Start March 7, 2013, at 0130 Eastern Standard Time (EST) March 8, 2013, at 1320 EST March 20, 2013, at 0015 EDT March 24, 2013, at 0458 EDT March 25, 2013, at 0022 EDT End March 7, 2013, at 0940 EST.
March 17, 2013, at 1720 Eastern Daylight Time (E DT).
March 22, 2013, at 2120 EDT March 24, 1013, at 0534 EDT March 25, 2013, at 0540 EDT Event Cause Implementation of EGM 11-003, Revision 1, during the Unit 2 refueling outage was a planned activity. As such, there was no root cause evaluation of the event.
Safety Assessment The safety significance of this event is minimal. As discussed in EGM 11-003, Revision 1, enforcement discretion related to secondary containment operability during Mode 5 OPDRV activities is appropriate because the associated interim actions necessary to receive the discretion ensure an adequate level of safety. To ensure compliance with the interim actions specified in the EGM, BSEP developed plant procedure OSP-12-001. This procedure was implemented for the OPDRV activities during which secondary containment was not operable.
Corrective Actions
BSEP will submit a license amendment request to adopt a Technical Specifications Task Force (TSTF) traveler associated with generic resolution of this issue, within four months after the issuance of the Notice of Availability of the TSTF traveler.
Previous Similar Events
A review of LERs and corrective action program condition reports for the past three years identified the following previous similar occurrences.
- LER 1-2012-002, dated May 2, 2012, reported implementation of EGM 11-003 during the 2012 Unit 1 refueling outage. The corrective action for LER 1-2012-002 was to submit a license amendment request to adopt a TSTF traveler associated with generic resolution of this issue, within four months after the issuance of the Notice of Availability of the TSTF traveler. To date, there is not an approved TSTF traveler. As such, the corrective action from LER 1-2012-002 could not be implemented and could not have prevented the condition reported in LER 2-2013-001.
- LER 1-2012-006, dated November 19, 2012, reported an event where an OPDRV activity was in progress on Unit 1 coincident with secondary containment being inoperable. This constituted operation prohibited by Technical Specification (TS) 3.6.4.1 and was reportable in accordance with 10 CFR 50.73(a)(2)(i)(B). The cause of the event reported in LER 1-2012-006 was inappropriate application of guidance in plant procedure 001-01.01, "BNP Conduct of Operations Supplement.
Implementation of EGM 11-003, Revision 1, during the Unit 2 refueling outage was a planned activity. As such, the action from LER 1-2012-006 is not applicable to the conditions reported in Commitments No regulatory commitments are contained in this report.