05000324/FIN-2015003-02
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Finding | |
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| Title | Implementation 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 |
| Description | The inspectors reviewed the plants implementation of NRC EGM 11-003, Revision 2, during Unit 2 maintenance activities which had the potential to drain the reactor vessel during the Unit 2 refueling outage. The activities included: February 26, 2015: 398 gallons per minute leakage for establishing a clearance for RWCU vent and drain valve maintenance March 14, 2015: 85 gallons per minute leakage for RWCU maintenance activities and excess flow check valve testing through test valve 2-B32-V85 March 17, 2015, 0411: 1 gallon per minute leakage for RWCU isolation valve leak March 17, 2015, 1300: 1 gallon per minute leakage for RWCU isolation valve leak March 18, 2015: 1 gallon per minute leakage for RWCU isolation valve leak, leak stopped when the 2A RWCU pump was put under clearance These activities took place without secondary containment being operable. Inspectors verified compliance with the guidelines of EGM 11-003 prior to and during these activities. Additionally, inspectors verified that, for all dates, all other TSs were met during OPDRVs with secondary containment inoperable. 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 February 26, 2015, March 14, 2015, twice on March 17, 2015, and March 18, 2015, the licensee failed to maintain secondary containment operable while performing OPDRVs. However, because the violations were identified during the discretion period described in EGM 11-003, Revision 2, the NRC is exercising enforcement discretion for the dates of February 26, 2015, March 14, 2015, twice on March 17, 2015, and March 18, 2015, 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, subject to a timely license amendment request being submitted. |
| Site: | Brunswick  |
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| Report | IR 05000324/2015003 Section 4OA5 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Ruh A Sengupta C Fontana G Hopper J Austin L Pressley M Catts M Orr M Schwieg S Sanchez |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - Brunswick - IR 05000324/2015003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Brunswick) @ 2015Q3
Self-Identified List (Brunswick)
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