05000397/FIN-2015003-06
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Finding | |
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| Title | Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 |
| Description | During Refueling Outage 22 in May June 2015, Columbia Generating Station implemented the guidance of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2, 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 operability was not maintained during operations with a potential for draining the reactor vessel activities, and required action C.2 of Technical Specification 3.6.4.1 was not completed. The inspectors reviewed this licensee event report for potential performance deficiencies and violations of regulatory requirements. The inspectors reviewed the stations implementation of the EGM 11-003, Revision 2, during operations with a potential for draining the reactor vessel. Specific observations included: 1. The inspectors observed that the operations logged all potential for draining the reactor vessel activities in the control room narrative logs, and that the log entry appropriately recorded the standby source of makeup designated for the evolutions. 2. The inspectors noted that the licensee maintained reactor vessel water level at least greater than 21 feet above the top of the reactor pressure vessel flange as required by Technical Specification 3.9.6. The inspectors also verified that at least one safety-related pump was the standby source of makeup designed in the control room narrative logs for the evolutions. The inspectors confirmed that the worst case estimated time to drain the reactor cavity to the reactor pressure vessel flange was greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 3. The inspectors verified that the operations with a potential for draining the reactor vessels were not conducted in Mode 4 and that the licensee did not move irradiated fuel during the operations with a potential for draining the reactor vessels. The inspectors verified that two independent means of measuring reactor pressure vessel water level were available for identifying the onset of loss of inventory events. Technical Specification 3.6.4.1, Secondary Containment requires, in part, that secondary containment shall be operable during operations with a potential for draining the reactor vessel. Technical Specification 3.6.4.1, Condition C, requires the licensee to initiate actions to suspend operations with a potential for draining the reactor vessel immediately when secondary containment is inoperable. Contrary to the above, from May 13 - June 13, 2015, Columbia Generating Station performed a total of five operations with a potential for draining the reactor vessel activities while in Mode 5 without an operable secondary containment. These conditions were reported as conditions prohibited by Technical Specifications. The licensee entered this issue into its corrective action program as Action Request 329328. Since this violation occurred during the discretion period described in EGM 11-003, Revision 2, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy, and, therefore, will not issue enforcement action for this violation. In accordance with EGM 11-003, Revision 2, each licensee that receives discretion must submit a license amendment request (LAR) to resolve the issue for its plant which the NRC staff LAR acceptance review finds acceptable in accordance with LIC-109, Acceptance Review Procedures. The generic solution will be a generic change to the Standard Technical Specifications, and the NRC will publish a notice of availability (NOA) for the TS solution in the Federal Register. Each licensee that receives discretion must submit its amendment request within 12 months of the NRC staffs issuance of the NOA. Licensees may submit LARs to adopt the NRC-approved approach or to propose an alternative approach for their plants. This licensee event report is closed. |
| Site: | Columbia  |
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| Report | IR 05000397/2015003 Section 4OA3 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | C Stott D Bradley J Groom J O'Donnell L Carson M Phalen N Greene R Smith |
| Violation of: | Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Columbia - IR 05000397/2015003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Columbia) @ 2015Q3
Self-Identified List (Columbia)
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