05000298/LER-2016-005, Regarding Implementation of Enforcement Guidance Memorandum 11-003, Revision 3, Causes Conditions Prohibited by Technical Specifications
| ML16350A102 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/22/2016 |
| From: | Limpias O Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2016072 LER 16-005-00 | |
| Download: ML16350A102 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2982016005R00 - NRC Website | |
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H Nebraska Public Power District Always there when you need us NLS2016072 November 22, 2016 U.S. Nucle(,11" Regulatory Commission Attention: D,ocument Control Desk Washington, D~C. 20555-0001
Subject:
Licensee Event Report No. 2016-005-00 Cooper Nuclear Station, Docket No. 50-298, DPR-46
Dear Sir or Madam:
(
\\
Th~purpose of this correspondence is to forward Licensee Event Report 2016-005-00.
There are no n~w commitments contained in this letteL A. Limp' s Vice President uclear-Chief Nuclear. Officer
/jo Attachment: Licensee Event Report 2016-005.:.00 cc:
Regional Administrator w/attachment USNRC - Region IV NPG Distribution w/attachment Cooper Project Manager w/attachme:p.t INPO Records Center w/attachment USNRC - NRR Plant Licensing Branch IV-2 via ICES entry Senior Resident Inspector w/attachment USNRC-CNS SRAB Administrator w/attachment SORC Chairmanw/attachment CNS Records w/attachment COOPER NUCLEAR STATION P.O. Box 98 /Brownville, NE 68321-0098 Telephone: (402) 825-3811 /Fax: (402) 825-5211 www.nppd.com
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES:
(11-2015) 10/31/2018
, the NRG may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Cooper Nuclear Station 05000298 1of3
- 4. TITLE
. Implementation of Enforcement Guidance Memorandum 11-003, Revision 3, Causes Conditions Prohibited by Technical Specifications
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED YEAR ISEQUENTIALI REV FACILITY NAME DOCKET MONTH DAY YEAR NO.
MONTH DAY YEAR
~5000 NUMBER FACILITY NAME DOCKET 10 01 2016 2016 -
005 -
00 11 22 2016 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §:
Check all that apply)
D 20.2201(b)
D 20.2203(a)(3)(i) 0 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A) 5 D 20.2201(d)
D 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(B)
D 50.73(a)(2)(viii)(B)
D 20.2203(a)(1)
D 20.2203(a)(4)
D 50.73(a)(2)(ii) 0 50.73(a)(2)(ix)(A)
D 20.2203(a)(2)(i) 0 50.36(c)(1 )(i)(A) 0 50. 73(a)(2)(iv)(A)
D,50.73(a)(2)(x)
D 20.2203(a)(2)(ii)
D 50.36(c)(1 )(ii)(A) 0 50. 73(a)(2)(v)(A)
D 73.71(a)(4)
- 10. POWER LEVEL D 20.2203(a)(2)(iii)
D 50.36(c)(2)
D 50.73(a)(2)(v)(B)
D 73.71(a)(5)
D 20.2203(a)(2)(iv)
D 50.46(a)(3)(ii)
D 50.73(a)(2)(v)(C)
D 73.77(a)(1) 000 0 20.2203(a)(2)(v) 0 50. 73(a)(2)(i)(A)
D 50. 73(a)(2)(v)(D)
D 73. 77(a)(2)(i) 0 20.2203(a)(2)(vi)
~ 50. 73(a)(2)(i)(B) 0 50.73(a)(2)(vii)
D 73. 77(a)(2)(ii) 0 50.73(a)(2)(i)(C) 0 OTHER Specify in Abstract below or in =
PLANT STATUS SEQUENTIAL NUMBER
- - 005 REV NO.
- - 00 Cooper Nuclear Station (CNS) was in Mode 5, Refueling, at 0 percent power, at the time of the events.
BACKGROUND On January 15, 2016, the Nuclear Regulatory Commission issued Enforcement Guidance Memorandum (EGM) 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." EGM 11-003, Revision 3, 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 29 (RE-29), CNS implemented the guidance of EGM 11-003, Revision 3, four times. Consistent with EGM 11-003, Revision 3, Secondary Containment operability ~as not maintained during OPDRV activities, and Required Action C.2 of Technical Specification (TS) 3.6.4.1 was not completed.
The following provides the dates which EGM 11-003 was implemented:
- 1. On October 1 and 2, 2016, the EGM was utilized to allow work on Reactor Recirculation Pump A (RR-P-A) and RR-P-B without the jet pump plugs installed while performing Surveillance Procedure 6.1 SGT.401, "SGT A Fan Capacity Test, SGT B Cooling Flow Test and Check Valve IST (Div 1 )."
- 2. From October 2-5, 2016, the EGM was utilized to allow work on RR-P-A, RR-P-B, Control Rod Drive (CRD) withdrawal/bypass operations and Hydraulic Control Unit (HCU) 42-31 during repairs to Main Steam Air Operated Valve 86B.
- 3. On October 6, 2016, the EGM was utilized to work on RR-P-A and RR-P-B without the jet pump plugs installed while draining Reactor Core Isolation Cooling 12 Relief Valve and flushing Main Steam Isolation Valves (MSIV).
- 4. From October 19-25, 2016, the EGM was utilized to work on RR-P-A. While using the EGM, work was also performed on CRD-V-113s (freeze seal), CRD Drive Venting, and CRD-V-105 (10-43)
(freeze seal). These OPDRVs were in progress while Secondary Containment was inoperable for MSIV 86A and 86B repair, Reactor Building (RB) personnel airlock seal repair, shift of RB ventilation, Service Water Valve 531 draining and Residual Heat Removal Valve 57/67 draining.
NRC FORM 366 (06-2016) r..
- ~
NRC FORM 366 (11-2015)
. i U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)
{~<lo.
'f.~., **** r:,;
(See Page 2 for required number of digits/characters for each block)
(See NUREG-1022, R 3 for instruction and guidance for completing this form http://www.nrc.gov/reading-rm/doc.collections/nuregs/staff/sr1022/r3/)
Page 3 of 3 APPROVED BYOMB: NO. 3150-0104 EXPIRES: 10/31/2018 Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
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 e-mail to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of lnfonmation 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 infonmation collection.
- 3. LER NUMBER YEAR Cooper Nuclear Station 05000-298 2016 NARRATIVE BASIS FOR REPORT SEQUENTIAL NUMBER
- - 005 REV NO.
- - 00 These events are 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 3, 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 3, during RE-29 was a planned activity. As such, there were no root cause evaluations of the events.
CORRECTIVE ACTIONS
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 During RE-28, CNS implemented EGM 11-003, Revision 2, seven times. These events were reported under one License Event Report, LER 2014-004-00.
NRC FORM 366 (06-2016)