Technical Specification Section 5.4.1.a, Administrative Control (Procedures), states, in part, that written procedures shall be established, implemented, and maintained, covering applicable procedures recommended in
Regulatory Guide 1.33, Appendix A, November 1972 (Safety Guide 33, November 1972). Section l.1 of
Regulatory Guide 1.33, Appendix A, November 1972, (Safety Guide 33, November 1972) states, in part, that maintenance that can affect the performance of safety-related equipment should be properly planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, from March 11, 2014, to April 3, 2014, the licensee failed to follow procedure OMA-NGGC-0201, Contingency Planning and Discovery Management, to properly plan for the replacement of the
reactor water cleanup (
RWCU) inlet line isolation valve 1-G31-F001. Specifically, a written contingency plan was not developed. As a result, significant items were missed in the planning and preparation. This contributed to the licensee exceeding the As Low as Reasonably Achievable (
ALARA) dose goal for this job by 11
rem. This finding was more than minor because it was associated with the Program and Process
ALARA planning attribute of the
Occupational Radiation Safety Cornerstone and adversely affected the objective to ensure the adequate protection of worker health and safety from exposure of radiation from radioactive material during routine civilian nuclear reactor operations. The inspectors determined the finding to be of very low safety significance (Green) because Brunswicks three-year rolling average (2011-2013) is 185 person-rem, which is below the
SDP criteria of 240 person-rem for boiling water reactors. The licensee entered this issue into the
CAP as NCR 678510.
