05000321/LER-2016-002, E.I Hatch, Unit 1, Regarding Performance of Operations with the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment
| ML16103A138 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/11/2016 |
| From: | Pierce C Southern Co, Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-16-0315 LER 16-002-00 | |
| Download: ML16103A138 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 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)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3212016002R00 - NRC Website | |
text
Charles R. Pierce Regulatory Affairs Director APR 11 2016 Docket Nos.: 50-321 Southern Nuclear Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Binningham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Licensee Event Report 2016-002-00 SOUTHERN <<\\
NUCLEAR A SOUTHERN COMPANY NL-16-0315 Performance of Operations with the Potential to Drain the Reactor Vessel (OPDRVl Without Secondary Containment Ladies and Gentlemen:
In accordance with the requirements of 10 CFR 50.73{a)(2)(i)(B) Southern Nuclear Operating Company hereby submits the enclosed Licensee Event Report.
This letter contains no NRC commitments. If you have any questions, please contact Greg Johnson at (912) 537-5874.
R;.-;~tted, C. R. Pierce Regulatory Affairs Director CRP/cdp Enclosure: LER 2016-002-00
U.S. Nuclear Regulatory Commission NL-16-0315 Page2 cc:
Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President-Hatch Mr. M. D. Meier, Vice President-Regulatory Affairs Mr. D. R. Madison, Vice President-Fleet Operations Mr. B. J. Adams, Vice President-Engineering Mr. G. L. Johnson, Regulatory Affairs Manager-Hatch RTYPE: CHA02.004 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Project Manager-Hatch Mr. D. H. Hardage, Senior Resident Inspector-Hatch
Edwin I. Hatch Nuclear Plant Unit 1 Licensee Event Report 2016-002-00 Performance of Operations with the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment
~ NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150~104 EXPIRES: 0113112017 (02-2014)
Estimated burden per response to comply with this mandatory coUection request 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
3~/
Reported lessons learned are incorporated iniD the licensing process and fed back to lndusb"y.
Send comrnenls reganfing burden estimate ID the FOIA, Privacy and Information Collections
\\.. J() LICENSEE EVENT REPORT (LER)
Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to lnfocollecls.Resoun:e@nrc.gov, and to the Desk Officer, Oflice of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budge~ Washington, DC 20503. H a means used to impose an information collection does not o!Splay a currently valid OMB control number, the NRC may not conduct or sponsor, and a person Is nol required to respond ID, the Information collection.
- 3. PAGE Edwin I. Hatch Nuclear Plant Unit 1 05000 321 1 OF 3
~-TITLE Performance of Operations With the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 02 13 2016 2016 - 002 -
00 04 11 2016
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 0 20.2201(b) 0 20.2203(a)(3)(1) 0 50.73(a)(2)(i)(C) 0 50.73(a)(2)(vii) 5 0 20.2201 (d) 0 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(A) 0 50.73(a)(2)(viii)(A) 0 20.2203(a)(1) 0 20.2203(a)(4) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) 0 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A) 0 50.73(a)(2)(iii) 0 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL 0 20.2203(a)(2)(ii) 0 50.36(c)(1)(ii)(A) 0 50.73(a)(2)(iv)(A) 0 50.73(a)(2)(x) 0 20.2203(a)(2)(iii) 0 50.36(c)(2) 0 50.73(a)(2)(v)(A) 0 73.71(a)(4) 0 0 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(B) 0 73.71(8)(5) 0 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(C) 0 OTHER 0 20.2203(a)(2)(vi) 1:8] 50. 73(a)(2)(i)(B) 0 50.73(a)(2)(v)(D)
Specify In Abstract below or In
PLANT AND SYSTEM IDENTIFICATION
General Electric-Boiling Water Reactor (BWR)
Energy Industry Identification System codes appear in the text as (EllS Code XX)
DESCRIPTION OF EVENT
In February 2016, with Unit 1 at 0 percent rated thermal power due to a scheduled refueling outage, operations with the potential to drain the reactor vessel (OPDRV) activities were performed while in Mode 5 (Refueling Mode) contrary to Technical Specification (TS) 3.6.4.1. The NRC recognizes that such activities need to be performed during refueling outages. Activities are underway to formulate acceptable generic changes to BWR Technical Specifications. NRC Regulatory Issue Summary (RIS) 2012-11 communicated this guidance to the industry. Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 currently provides enforcement discretion for licensee noncompliance with TS containment requirements during OPDRV activities until December 31, 2017 while the NRC staff and Boiling Water Reactor Owner's Group finalize a generic solution forTS changes. The required interim actions specified in the EGM were incorporated into plant procedure 31GO-OPS-025-0 "Operations With The Potential To Drain The Reactor Vessel".
This procedure was utilized during the following three occasions during the 2016 Unit 1 Refueling Outage:
Table 1: Hatch Unit 1 OPDRVs Performed February 2016 OPDRV Activity Start End LPRM replacement activity 02/13/2016, 2130 EST 02/15/2016, 0149 EST CRD push-pull activity 02/15/2016, 1213 EST 02/16/2016, 0740 EST CRD insert I re-couple activity 02/17/2016, 1547 EST 02/18/2016, 1038 EST
CAUSE OF EVENT
Implementation of the required EGM 11-003, Revision 3 interim actions during the 2016 Unit 1 Refueling Outage was a planned activity. As such, no cause determination was performed for the events.
REPORT ABILITY AND SAFETY ASSESSMENT This event is reportable per 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by Technical Specifications (TS) 3.6.4.1.C.3, which prohibits performing activities identified as OPDRVs in Mode 5 while secondary containment is inoperable.
The OPDRVs discussed in this report performed during the Unit 2 Refueling Outage were accomplished using interim actions provided by the NRC in EGM 11-003, Revision 3. Hatch adhered to the NRC plain language meaning of OPDRV activities that could potentially result in draining or siphoning the reactor pressure vessel (RPV) water level below the top of the fuel. Hatch also met the requirements which specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain down times.
- 6. LER NUMBER YEAR I SEQUENTIAL I NUMBER 2016 -- 002 -- 00 REV.
NO.
- 3. PAGE 30F 3 Furthermore, an adequate defense in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable by (a) monitoring RPV level to identify the onset of a loss of inventory event, (b) maintaining the capability to isolate the potential leakage paths, (c) prohibiting Mode 4 (cold shutdown) OPDRV activities, and (d) prohibiting movement of irradiated fuel with the spent fuel storage pool gates removed in Mode 5.
All other Mode 5 Technical Specifications requirements for OPDRV activities were followed. Since these compensatory measures were properly implemented, an adequate level of safety was provided during the performance of the OPDVR activities described in this report Based on this information, the performance of these OPDRV activities were determined to have a very low safety significance.
CORRECTIVE ACTIONS
Consistent with the guidance given in EGM 11-003 Revision 3, Hatch will submit a licensee amendment request (LAR) following NRC approval of the Technical Specifications Task Force (TSTF) Traveler associated with generic resolution of this issue within the time restraints given in the EGM.
ADDITIONAL INFORMATION
Other Systems Affected: None.
Failed Components Information
None.
Commitment Information: This report does not created any new licensing commitments.
Previous Similar Events
LER 2015-002-00 On February 16, 2015, February 20, February 18 through 19, 2015, and February 23 through 24, 2015, OPDRV activities were performed while Unit 2 was in Refueling Mode (Mode 5) without an operable secondary containment These activities are prohibited by Technical Specifications (TS) 3.6.4.1. However, NRC guidance provided in Regulatory Issue Summary (RIS) 2012-11 and in Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 allowed the implementation of interim actions as an alternative to full compliance. An adequate defensed in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable by (a) monitoring RPV level to identify the onset of a loss of inventory event, (b) maintaining the capability to isolate the potential leakage paths, (c) prohibiting Mode 4 (cold shutdown) OPDRV activities, and (d) prohibiting the movement of irradiated fuel with the spent fuel storage pool gates removed in Mode 5. The associated Technical Specification Task Force (TSTF) Traveler is not yet available as a Technical Specification consolidated line item improvement process (CLIIP) for use by licensees. For that reason, the corrective actions from this event would not be expected to have prevented the condition reported in this LER.
PLANT AND SYSTEM IDENTIFICATION
General Electric-Boiling Water Reactor (BWR)
Energy Industry Identification System codes appear in the text as (EllS Code XX)
DESCRIPTION OF EVENT
In February 2016, with Unit 1 at 0 percent rated thermal power due to a scheduled refueling outage, operations with the potential to drain the reactor vessel (OPDRV) activities were performed while in Mode 5 (Refueling Mode) contrary to Technical Specification (TS) 3.6.4.1. The NRC recognizes that such activities need to be performed during refueling outages. Activities are underway to formulate acceptable generic changes to BWR Technical Specifications. NRC Regulatory Issue Summary (RIS) 2012-11 communicated this guidance to the industry. Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 currently provides enforcement discretion for licensee noncompliance with TS containment requirements during OPDRV activities until December 31, 2017 while the NRC staff and Boiling Water Reactor Owner's Group finalize a generic solution forTS changes. The required interim actions specified in the EGM were incorporated into plant procedure 31GO-OPS-025-0 "Operations With The Potential To Drain The Reactor Vessel".
This procedure was utilized during the following three occasions during the 2016 Unit 1 Refueling Outage:
Table 1: Hatch Unit 1 OPDRVs Performed February 2016 OPDRV Activity Start End LPRM replacement activity 02/13/2016, 2130 EST 02/15/2016, 0149 EST CRD push-pull activity 02/15/2016, 1213 EST 02/16/2016, 0740 EST CRD insert I re-couple activity 02/17/2016, 1547 EST 02/18/2016, 1038 EST
CAUSE OF EVENT
Implementation of the required EGM 11-003, Revision 3 interim actions during the 2016 Unit 1 Refueling Outage was a planned activity. As such, no cause determination was performed for the events.
REPORT ABILITY AND SAFETY ASSESSMENT This event is reportable per 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by Technical Specifications (TS) 3.6.4.1.C.3, which prohibits performing activities identified as OPDRVs in Mode 5 while secondary containment is inoperable.
The OPDRVs discussed in this report performed during the Unit 2 Refueling Outage were accomplished using interim actions provided by the NRC in EGM 11-003, Revision 3. Hatch adhered to the NRC plain language meaning of OPDRV activities that could potentially result in draining or siphoning the reactor pressure vessel (RPV) water level below the top of the fuel. Hatch also met the requirements which specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain down times.
- 6. LER NUMBER YEAR I SEQUENTIAL I NUMBER 2016 -- 002 -- 00 REV.
NO.
- 3. PAGE 30F 3 Furthermore, an adequate defense in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable by (a) monitoring RPV level to identify the onset of a loss of inventory event, (b) maintaining the capability to isolate the potential leakage paths, (c) prohibiting Mode 4 (cold shutdown) OPDRV activities, and (d) prohibiting movement of irradiated fuel with the spent fuel storage pool gates removed in Mode 5.
All other Mode 5 Technical Specifications requirements for OPDRV activities were followed. Since these compensatory measures were properly implemented, an adequate level of safety was provided during the performance of the OPDVR activities described in this report Based on this information, the performance of these OPDRV activities were determined to have a very low safety significance.
CORRECTIVE ACTIONS
Consistent with the guidance given in EGM 11-003 Revision 3, Hatch will submit a licensee amendment request (LAR) following NRC approval of the Technical Specifications Task Force (TSTF) Traveler associated with generic resolution of this issue within the time restraints given in the EGM.
ADDITIONAL INFORMATION
Other Systems Affected: None.
Failed Components Information
None.
Commitment Information: This report does not created any new licensing commitments.
Previous Similar Events
LER 2015-002-00 On February 16, 2015, February 20, February 18 through 19, 2015, and February 23 through 24, 2015, OPDRV activities were performed while Unit 2 was in Refueling Mode (Mode 5) without an operable secondary containment These activities are prohibited by Technical Specifications (TS) 3.6.4.1. However, NRC guidance provided in Regulatory Issue Summary (RIS) 2012-11 and in Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 allowed the implementation of interim actions as an alternative to full compliance. An adequate defensed in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable by (a) monitoring RPV level to identify the onset of a loss of inventory event, (b) maintaining the capability to isolate the potential leakage paths, (c) prohibiting Mode 4 (cold shutdown) OPDRV activities, and (d) prohibiting the movement of irradiated fuel with the spent fuel storage pool gates removed in Mode 5. The associated Technical Specification Task Force (TSTF) Traveler is not yet available as a Technical Specification consolidated line item improvement process (CLIIP) for use by licensees. For that reason, the corrective actions from this event would not be expected to have prevented the condition reported in this LER.