05000325/LER-2016-003

LER-2016-003, Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

Brunswick Steam Electric Plant (Bsep), Unit 1
Event date:	03-09-2016
Report date:	05-02-2016
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3252016003R00 - NRC Website

LER 16-003-00 for Brunswick Steam Electric Plant, Unit 1 Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

ML16132A074
Person / Time
Site:	Brunswick
Issue date:	05/02/2016
From:	Gideon W R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 16-0029 LER 16-003-00
Download: ML16132A074 (5)

comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by Internet e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

Brunswick Steam Electric Plant (BSEP) 003 05000-325 2016 - 000 Energy Industry Identification System (EllS) codes are identified in the text as [XX].

Background

Initial conditions At the time of the event, Unit 1 was in Mode 5 (i.e., Refuel), at zero percent of rated thermal power (RTP).

Reportability Criteria On March 9, 2016, Unit 1 implemented the guidance of EGM 11-003, Revision 3, "Enforcement Guidance Memorandum 11-003, Revision 3, Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel," dated January 15, 2016. Consistent with EGM 11-003, Revision 3, 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 3, was implemented four additional times during the 2016, 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 January 15, 2016, the NRC issued EGM 11-003, Revision 3. EGM 11-003, Revision 3, provides generic enforcement discretion to allow implementation of specific interim actions as an alternative to full compliance with plant TSs 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-16-100, "Unit 1 EGM 11-003 OPDRV Activities." This procedure, which implements compensatory actions that meet or exceed those specified in EGM 11-003, Revision 3, was implemented on five occasions during the 2016, Unit 1 refueling outage. The following list provides the durations of each period during which EGM 11-003, Revision 3, 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 3 Implementation Duration Start End 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 19 minutes 2 days, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 56 minutes 2 days, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, 20 minutes 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, 40 minutes 3 days, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 20 minutes March 9, 2016, at 1257 Eastern Standard Time (EST) March 9, 2016, at 1419 EST March 11, 2016, at 1915 EST March 14, 2016, at 2035 EDT March 15, 2016, at 2010 EDT March 9, 2016, at 1416 EST March 11, 2016, at 1715 EST March 14, 2016, at 0345 Eastern Daylight Time (EDT) March 15, 2016, at 1515 EDT March 18, 2016, at 2130 EDT comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by Internet e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

Brunswick Steam Electric Plant (BSEP) 003 05000-325 2016 - 000 Event Causes Implementation of EGM 11-003, Revision 3, 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 3, 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-16-100. 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 for the past three years identified the following previous similar occurrences.

refueling outage. The corrective action for LER 2-2015-001 was to submit a license amendment request to adopt a TSTF traveler associated with generic resolution of this issue within 12 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 2-2015-001 could not be implemented and could not have prevented the condition reported in LER 1-2016-003.

refueling outage. The corrective action for LER 1-2014-001 was to submit a license amendment request to adopt a TSTF traveler associated with generic resolution of this issue within 12 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 1-2014-001 could not be implemented and could not have prevented the condition reported in LER 1-2016-003.

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 1-2016-003.

Commitments No regulatory commitments are contained in this report.