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During the Unit 1 spring 2018 refueling outage, the OPDRVs activities are listed below: March 7, 2018: 148 gallons per minute (gpm) leakage associated with local leak rate testing (LLRT) of valves 1-G31-F001 and -F004.March 8, 2018: 82 gpm leakage for A RHR loop draining to support maintenance.March 12, 2018: 81.2 gpm leakage to replace the local power range monitors and intermediate power range dry tubes.March 14, 2018: 71.2 gpm leakage to replace the local power range monitors.March 15, 2018: 25 gpm leakage to replace A recirculation pump seal package.March 22, 2018: 25 gpm leakage to replace A recirculation pump seal package.March 27, 2018: 164 gpm leakage to facilitate control rod drive system venting.March 28, 2018: 288 gpm leakage to account for leakage past scram discharge and vent valves during testing.These activities took place without secondary containment being operable. Corrective Actions: EGM 11-003 allows enforcement discretion regarding secondary containment operability during Mode 5 OPDRV activities provided the licensee meets certain requirements. The licensee met the stipulations of the EGM by executing their procedure 1SP-16-100, EGM 11-003 OPDRV Activities, Rev 001, for each OPDRV activity during the Unit 1 Spring 2018 refueling outage. Additionally, as required by the EGM, the licensee submitted a license amendment request (BSEP 17-0060) on June 29, 2017. The amendment was approved on April 13, 2018, and will be implemented prior to the 2019 Unit 2 spring refueling outage. Corrective Action Reference: The issue was entered into the licensees corrective action program as NCR 2189536. Violation: TS 3.6.4.1, Secondary Containment, requires that secondary containment be operable and is applicable during OPDRVs. The required action if secondary containment is inoperable in this condition is to initiate actions to suspend OPDRVs immediately. Contrary to the above, on activities listed above, the licensee failed to maintain secondary containment operable while performing OPDRVs on Unit 1. Severity/Significance: According to EGM 11-003, the NRC considers enforcement discretion related to secondary containment operability during Mode 5 OPDRV activities provided the licensee meets certain requirements such as monitoring vessel level, maintaining capability to isolate leakage paths, providing minimum makeup flow rate, etc. These requirements provide a reasonable assurance of public health and safety during draining activities in Mode 5 while the secondary containment is inoperable

13 Enclosure Discretion Basis: The NRC exercised 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. These violations were identified during the discretion period described in EGM 11-003, Revision 3, and the licensee met the criteria established in the EGM prior to and during these activities.