05000324/LER-2015-001, Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2

Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2

ML15127A167
Person / Time
Site:	Brunswick
Issue date:	04/24/2015
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 15-0021 LER 15-001-00
Download: ML15127A167 (6)

LER-2015-001, Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3242015001R00 - NRC Website

text

• ~ENERGY, William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 APR 2 4 2015 10 CFR 50.73 Serial: BSEP 15-0021 U.S, Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Brunswick Steam Electric Plant, Unit No. 2 Renewed Facility Operating License No. DPR-62 Docket No. 50-324 Licensee Event Report 2-2015-001 In accordance with the Code of Federal Regulations, Title 10, Part 50.73, Duke Energy Progress, Inc., submits the enclosed Licensee Event Report (LER). This report fulfills the requirement for a written report within sixty (60) days of a reportable occurrence.

This document contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

William R. Gideon WRG/mkb

Enclosure:

Licensee Event Report

U.S. Nuclear Regulatory Commission Page 2 of 2 cc (with enclosure):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 (02-2014)

Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.

Reported lessons learned are incorporated into the licensing process and fed back to industry.

Send comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by LICENSEE EVENT REPORT (LER) internet e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and (See Page 2 for required number of Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currently valid OMB digits/characters for each block) control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

3. PAGE Brunswick Steam Electric Plant (BSEP), Unit 2 05000324 1 OF 4

4. TITLE Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED M

I FACILITY NAME DOCKET NUMBER MOYA ER SEQUENTIAL REV MONTH DAY YEAR05 0

NUMBER NO.

05000 FACILITY NAME DOCKET NUMBER 02 26 2015 2015 001

- 00 04 24 2015 05000

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)

El 20.2201(b)

El 20.2203(a)(3)(i)

El 50.73(a)(2)(i)(C)

[1 50.73(a)(2)(vii)

[]

20.2201(d)

El 20.2203(a)(3)(ii)

El 50.73(a)(2)(ii)(A)

[: 50.73(a)(2)(viii)(A) 5E 20.2203(a)(1)

E] 20.2203(a)(4)

El 50.73(a)(2)(ii)(B)

El 50.73(a)(2)(viii)(B)

[]

20.2203(a)(2)(i)

[E 50.36(c)(1)(i)(A)

El 50.73(a)(2)(iii)

El 50.73(a)(2)(ix)(A)

10. POWER LEVEL El 20.2203(a)(2)(ii)

[1 50.36(0)(1)(ii)(A)

[1 50.73(a)(2)(iv)(A)

Ej 50.73(a)(2)(x)

El 20.2203(a)(2)(iii)

[1 50.36(c)(2)

El 50.73(a)(2)(v)(A)

El 73.71(a)(4)

El 20.2203(a)(2)(iv)

[:1 50.46(a)(3)(ii)

El 50.73(a)(2)(v)(B)

El 73.71 (a)(5) 000 20.2203(a)(2)(v)

[E 50.73(a)(2)(i)(A)

El 50.73(a)(2)(v)(C)

El OTHER r-'l nSpecify in Abstract below or in 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B) 50.73(a)(2)(v)(D)

Spc in A v_________,_________

Energy Industry Identification System (EIIS) codes are identified in the text as [XX].

Background

Initial Conditions At the time of the event, Unit 2 was in Mode 5, at zero percent of rated thermal power (RTP).

Reportability Criteria On February 26, 2015, Unit 2 implemented the guidance of EGM 11-003, Revision 2, "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 13, 2013. Consistent with EGM 11-003, Revision 2, secondary containment [NG] operability was not maintained during Operations with a Potential for Draining the Reactor Vessel (OPDRV) activities, and Required Actions C.1 and C.2 of Technical Specification (TS) 3.6.4.1, "Secondary Containment," were not completed.

EGM1 1-003, Revision 2, was implemented four additional times during the 2015, 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 13, 2013, the NRC issued EGM 11-003, Revision 2. EGM 11-003, Revision 2, 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 2SP-15-101, "Unit 2 EGM 11-003 OPDRV Activities." This procedure, which implements compensatory actions that meet or exceed those specified in EGM 11-003, Revision 2, was implemented on five occasions during the 2015, Unit 2 refueling outage. The following list provides the durations of each period during which EGM 11-003, Revision 2, 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 2 Implementation Duration 5 days, 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, 20 minutes 1 day, 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, 7 minutes 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, 29 minutes 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />, 57 minutes 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 39 minutes Start End February 26, 2015, at 0830 Eastern Standard Time (EST)

March 14, 2015, at 2100 Eastern Daylight Time (EDT)

March 17, 2015, at 0345 EDT March 17, 2015, at 1300 EDT March 18, 2015, at 1005 EDT March 4, 2015, at 0250 EST March 16, 2015, at 1107 EDT March 17, 2015, at 0714 EDT March 18, 2015, at 0457 EDT March 18, 2015, at 1244 EDT

Event Cause

Implementation of EGM 11-003, Revision 2, 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 2, 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 2SP-1 5-101. 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 Specification Task Force (TSTF) traveler associated with generic resolution of this issue within 12 months after the issuance of the Notice of Availability of the TSTF traveler.

Previous Similar Events

A review of LERs for the past three years identified the following previous similar occurrences.

LER 1-2014-001, dated May 1, 2014, reported implementation of EGM 11-003 during the 2014 Unit 1 refueling outage. The corrective action for LER 1-2014-001 was to submit a license amendment request to adopt a TSTF traveler associated with generic resolution of this issue within 12 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 1-2014-001 could not be implemented and could not have prevented the condition reported in LER 2-2015-001.

LER 2-2013-001, dated May 6, 2013, reported implementation of EGM 11-003 during the 2013 Unit 2 refueling outage. The corrective action for LER 2-2013-001 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 2-2013-001 could not be implemented and could not have prevented the condition reported in LER 2-2015-001.

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 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 2, during the 2015, 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 LER 2-2015-001.

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 2-2015-001.

Commitments

No regulatory commitments are contIined in this report.