05000298/LER-2016-005
| 11-22-2016 | During Refueling Outage 29 (RE-29), Cooper Nuclear Station implemented the guidance of 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," dated January 15, 2016. Consistent with EGM 11-003, Revision 3, secondary containment operability was not maintained during Operations with a Potential for Draining the Reactor Vessel activities, and Required Action C.2 of Technical Specification (TS) 3.6.4.1 was not completed.
EGM 11-003, Revision 3, was implemented four times during RE-29. These conditions are being reported as conditions prohibited by TS. 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. Consistent with the guidance provided in EGM 11-003, Revision 3, Nebraska Public Power District will submit a license amendment request to adopt a 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. - 005 -00 Cooper Nuclear Station 05000- 298 2016 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 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. ContentsPLANT STATUSCooper Nuclear Station (CNS) was in Mode 5, Refueling, at 0 percent power, at the time of the events. BACKGROUNDOn 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 DESCRIPTIONDuring 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 was 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 6.1SGT.401, "SGT A Fan Capacity Test, SGT B Cooling Flow Test and Check Valve 1ST (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. 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 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. 05000- 298 Cooper Nuclear Station 2016 - 005 - 00 3. LER NUMBERBASIS FOR REPORTThese 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 SIGNIFICANCEAs 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. CAUSEImplementation 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 ACTIONSCNS 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 EVENTSDuring RE-28, CNS implemented EGM 11-003, Revision 2, seven times. These events were reported under one License Event Report, LER 2014-004-00. |
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| Cooper Nuclear Station | |
| Event date: | 10-01-2016 |
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| Report date: | 11-22-2016 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2982016005R00 - NRC Website | |
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