05000324/LER-2015-001
| Brunswick Steam Electric Plant (Bsep), Unit 2 | |
| Event date: | 02-26-2015 |
|---|---|
| Report date: | 04-24-2015 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3242015001R00 - NRC Website | |
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.
EGM11-003, 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 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 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 End 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-15-101. 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.
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.
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.
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 contEined in this report.