05000325/LER-2016-003, Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3
| ML16132A074 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/02/2016 |
| From: | William Gideon Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BSEP 16-0029 LER 16-003-00 | |
| Download: ML16132A074 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 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)(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)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) |
| 3252016003R00 - NRC Website | |
text
MAY 0 2 2016 Serial: BSEP 16-0029 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Brunswick Steam Electric Plant, Unit No. 1 Renewed Facility Operating License No. DPR-71 Docket No. 50-325 Licensee Event Report 1-2016-003 William A. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 10 CFR 50.73 In accordance with the Code of Federal Regulations, Title 1 O, 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 (91 O) 457-2487.
Sincerely, f:2~~~
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: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRG 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: 10/31/2018 (11-2015)
... ~'REou<,o>~
, the NRG 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 1 05000325 1 OF 3
- 4. TITLE Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3
- 5. EVENT DATE
- 6. LEA NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO.
MONTH DAY YEAR 05000 FACILITY NAME DOCKET NUMBER 03 09 2016 2016 - 003 -
00 05 02 2016 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMIITED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
D 20.2201 (b)
D 20.22os(a)(s)(i)
D 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A) 5 D 20.2201 (ct>
D 20.22os(a)(s)(ii)
D 50.73(a)(2)(ii)(B)
D 50.73(a)(2)(viii)(B)
D 20.22os(a)(1 >
D 20.22os(a)(4)
D so.1s(a)(2)(m>
D 50.73(a)(2)(ix)(A)
D 20.22os(a)(2>0>
D 50.36(c)(1)(i)(A)
D 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x)
- 10. POWER LEVEL D 20.22os(a)(2)(ii)
D 50.36(c)(1)(ii)(A)
D 50.73(a)(2)(v)(A)
D 1s.11 (a)(4)
D 20.22os(a)(2)(m>
D so.ss(c)(2>
D 50.73(a)(2)(v)(B)
D 1s.11(a)(s)
D 20.2203(a)(2)(iv)
D so.4s(a)(s)(iil D 50.73(a)(2)(v)(C)
D 1s.11(a)(1) 000 D 20.2203(a)(2)(v)
D 50.73(a)(2)(i)(A)
D 50.73(a)(2)(v)(D)
D 1s.11(a)(2)(il D 20.2203(a)(2)(vi)
[8] 50.73(a)(2)(i)(B)
D 50.73(a)(2)(vii)
D 1s.11(a)(2)(ii)
- J;*.y. ' z£(',(;.[**1
&.~:J'\\
'j D 50.73(a)(2)(i)(C)
D OTHER Specify in Abstract below or in Event Causes 05000-325 YEAR 2016 SEQUENTIAL NUMBER 003 REV NO.
000 Implementation of EGM 11-003, Revision 3, during the Unit 1 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 3, 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 1SP-16-100. 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 2-2015-001, dated April 24, 2015, reported implementation of EGM 11-003 during the 2015 Unit 2 refueling outage. The corrective action for LER 2-2015-001 was to submit a license amendment request to adopt a TSTF travel.er 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 2-2015-001 could not be implemented and could not have prevented the condition reported in LER 1-2016-003.
LER 1-2014-001, dated May 1, 2014, reported implementation of EGM 1 l-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 1-2016-003.
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 1-2016-003.
Commitments
No regulatory commitments are contained in this report.
- 2. DOCKET NUMBER 05000-325 Energy Industry Identification System (EllS) codes are identified in the text as [XX].
Background
Initial conditions YEAR 2016
- 3. LEA NUMBER SEQUENTIAL NUMBER 003 REV NO.
000 At the time of the event, Unit 1 was_ in Mode 5 (i.e., Refuel), at zero percent of rated thermal power (RTP).
Reportability Criteria On March 9, 2016, Unit 1 implemented the guidance of EGM 11-003, Revision 3, "Enforcement Guidance Memorandum 11-003, Revision 3, Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel," dated January 15, 2016. Consistent with EGM 11-003, Revision 3, 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 3, was implemented four additional times during the 2016, Unit 1 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 January 15, 2016, the NRG issued EGM 11-003, Revision 3. EGM 11-003, Revision 3, provides generic enforcement discretion to allow implementation of specific interim actions as an alternative to full compliance with plant TSs 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 1 SP-16-100, "Unit 1 EGM 11-003 OPDRV Activities." This procedure, which implements compensatory actions that meet or exceed those specified in EGM 11-003, Revision 3, was implemented on five occasions during the 2016, Unit 1 refueling outage. The following list provides the durations of each period during which EGM 11-003, Revision 3, was implemented (i.e., OPDRV activities were in progress with secondary containment inoperable). Unit 1 was in Mode 5 during these periods.
EGM 11-003, Revision 3 Implementation Duration Start End 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 19 minutes March 9, 2016, at 1257 March 9, 2016, at 1416 EST Eastern Standard Time (EST) 2 days, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 56 minutes March 9, 2016, at 1419 EST March 11, 2016, at 1715 EST 2 days, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, 20 minutes March 11, 2016, at 1915 EST March 14, 2016, at 0345 Eastern Daylight Time (EDT) 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, 40 minutes March 14, 2016, at 2035 EDT March 15, 2016, at 1515 EDT 3 days, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 20 minutes March 15, 2016, at 2010 EDT March 18, 2016, at 2130 EDT Event Causes 05000-325 YEAR 2016 SEQUENTIAL NUMBER 003 REV NO.
000 Implementation of EGM 11-003, Revision 3, during the Unit 1 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 3, 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 1SP-16-100. 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 2-2015-001, dated April 24, 2015, reported implementation of EGM 11-003 during the 2015 Unit 2 refueling outage. The corrective action for LER 2-2015-001 was to submit a license amendment request to adopt a TSTF travel.er 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 2-2015-001 could not be implemented and could not have prevented the condition reported in LER 1-2016-003.
LER 1-2014-001, dated May 1, 2014, reported implementation of EGM 1 l-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 1-2016-003.
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 1-2016-003.
Commitments
No regulatory commitments are contained in this report.