05000325/LER-2014-001
| Brunswick Steam Electric Plant (Bsep), Unit 1 | |
| Event date: | 03-07-2014 |
|---|---|
| Report date: | 05-01-2014 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3252014001R00 - NRC Website | |
Energy Industry Identification System (EDS) codes are identified in the text as [XX].
Background
Initial Conditions At the time of the event, Unit 1 was in Mode 5, at zero percent of rated thermal power (RTP).
Reportability Criteria On March 7, 2014, Unit 1 implemented the guidance 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," dated December 13, 2013. Consistent with EGM 11-003, Revision 2, 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 2, was implemented four additional times during the 2014, 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 December 13, 2013, the NRC issued EGM 11-003, Revision 2. EGM 11-003, Revision 2, provides generic enforcement discretion to allow implementation of specific interim actions as an alternative to full compliance with plant technical specifications 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 1SP-14-100, "EGM 11-003 OPDRV Activities." This procedure, which implements compensatory actions that meet or exceed those specified in EGM 11-003, Revision 2, was implemented on five occasions during the 2014, Unit 1 refueling outage. The following list provides the durations of each period during which EGM 11-003, Revision 2, 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 2 Implementation Duration Start End 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, 1 minute 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 21 hours, 22 minutes 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />, 34 minutes 9 days, 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, 9 minutes March 7, 2014, at 0944 Eastem Standard Time (EST) March 9, 2014, at 1253 Eastern Daylight Time (EDT) March 14, 2014, at 0519 EDT March 17, 2014, at 1126 EDT March 18, 2014, at 2346 EDT March 8, 2014, at 0345 EST March 10, 2014, at 0453 EDT March 15, 2014, at 0241 EDT March 18, 2014, at 0500 EDT March 28, 2014, at 1755 EDT Event Cause Implementation of EGM 11-003, Revision 2, 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 2, 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-14-100. 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 and corrective action program condition reports for the past three years identified the following previous similar occurrences.
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 1-2014-001.
refueling outage. The corrective action for LER 1-2012-002 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 1-2012-002 could not be implemented and could not have prevented the condition reported in LER 1-2014-001.
Commitments No regulatory commitments are contained in this report.