05000298/LER-2014-004
| Cooper Nuclear Station | |
| Event date: | 10-03-2014 |
|---|---|
| Report date: | 11-24-2014 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2982014004R00 - NRC Website | |
Reported lessons learned are incorporated into the licensing process and fed back to industry.
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 Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means 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.
Cooper Nuclear Station 05000298 NO _
PLANT STATUS
Cooper Nuclear Station (CNS) was in Mode 5, Refueling, at 0 percent power, at the time of the event.
BACKGROUND
On December 13, 2013, the Nuclear Regulatory Commission issued Enforcement Guidance Memorandum (EGM) 11-003, Revision 2, "Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements During Operations with a Potential for Draining the Reactor Vessel." 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 Operations with a Potential for Draining the Reactor Vessel (OPDRV) activities. To ensure compliance with interim actions specified in the EGM, CNS added guidance to plant procedure 0.50.5, Outage Shutdown Safety.
EVENT DESCRIPTION
During Refueling Outage 28 (RE-28), CNS implemented the guidance of EGM 11-003, Revision 2, seven times. Consistent with EGM 11-003, Revision 2, secondary containment operability was not maintained during OPDRV activities, and Required Action C.2 of Technical Specification (TS) 3.6.4.1 was not completed.
The following list provides the dates which EGM 11-003 was implemented (Note: All times are Central Daylight Time):
Start End Activity Performed October 3, 2014, at 1602 October 4, 2014, at 1059 Draining Reactor Recirculation Pump [EIIS: P] (RR-P) B without the jet pump plugs fully installed October 3, 2014, at 2215 October 4, 2014, at 0251 Control Rod Drive (CRD) [EIIS: AA] maintenance October 16, 2014, at 0023 October 22, 2014, at 0425 Removal of jet pump plugs associated with RR-P-B maintenance October 16, 2014, at 0437 October 18, 2014, at 0424 Venting the CRDs (table continued) Reported lessons learned are incorporated into the licensing process and fed back to industry.
Send 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 Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means 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.
Cooper Nuclear Station 05000298
NO
Start End Activity Performed October 17, 2014, at 2233 October 18, 2014, at 2115 Defeating the scram function for two CRDs and support IVVI Inspections October 18, 2014, at 0939 October 22, 2014, at 2336 RR-P-A seal maintenance October 19, 2014, at 0435 October 22, 2014, at 2308 CRD freeze seal [EIIS: SEAL]
BASIS FOR REPORT
This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as conditions prohibited by CNS TS 3.6.4.1, which prohibits performing activities identified as OPDRVs in MODE 5 while secondary containment is inoperable.
SAFETY SIGNIFICANCE
As discussed in EGM 11-003, Revision 2, enforcement discretion is appropriate because the issues have low safety significance since licensees must implement compensatory measures to provide an adequate level of safety when using the discretion. To ensure compliance with the interim actions specified in the EGM, CNS added guidance to plant procedure 0.50.5. This procedure was implemented for the OPDRV activities during which secondary containment was not operable.
CAUSE
Implementation of EGM 11-003, Revision 2, during RE-28 was a planned activity. As such, there were no root cause evaluations of the events.
CORRECTIVE ACTION
CNS will submit a license amendment request to adopt the Technical Specifications Task Force (TSTF) traveler associated with generic resolution of this issue, within 12 months after issuance of the Notice of Availability of the TSTF traveler.
PREVIOUS EVENTS
There have been no events reported in the last three years related to EGM 11-003 or OPDRVs.