05000354/FIN-2015002-04
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Finding | |
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| Title | Operations with a Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment |
| Description | On April 14, 15, 17, 20, 27 and 29, 2015, during a planned refueling outage and the reactor cavity flooded up in Mode 5, Hope Creek conducted multiple OPDRVs without an operable secondary containment. The conduct of an OPDRV without establishing secondary containment integrity is a condition prohibited by TS as defined by 10 CFR 50.73(a)(2)(i)(B). Secondary containment is required by TS 3/4.6.5.1 in Operational Condition *, which is a condition during an OPDRV. The required action for this specification is to suspend OPDRV operations. In this case, the specific OPDRVs were the removal of the scram air header from service (2:00 to 5:15 p.m. on April 14, 2015), B RRP seal replacement (4:36 a.m. on April 15, 2015, through 2:55 a.m. on April 24, 2015), control rod drive replacements (2:17 p.m. on April 17, 2015, through 1:02 p.m. on April 20, 2015), Local power range monitor replacements (3:13 a.m. on April 20, 2015, through 6:40 a.m. on April 23, 2015), scram discharge volume tagging (1:14 to 1:26 p.m. on April 27, 2015), and the fill and vent for the B RRP seal (8:41 p.m. on April 29, 2015, through 6:45 a.m. on April 30, 2015). The OPDRVs were completed in accordance with PSEG procedure OP-HC-108-102, "Management of Operations with the Potential to Drain the Reactor Vessel." These OPDRVs were completed and exited at 6:45 a.m. on April 30, 2015. The NRC issued EGM 11-003, Revision 2, Enforcement Guidance Memorandum On Dispositioning Boiling Water Reactor Licensee Noncompliance With Technical Specification Containment Requirements During Operations With A Potential For Draining The Reactor Vessel, on December 13, 2013, which provides, in part, for the exercise of enforcement discretion only if the licensee demonstrates that it has implemented specific interim actions during any OPDRV activity. The inspectors determined that PSEGs implementation of these specific interim actions during these OPDRV activities were adequate and met the intent of EGM 11-003, Revision 2. The inspectors assessments of PSEGs implementation of these criteria during each of the multiple OPDRV activities are described below: The inspectors observed that, as required by the EGM, the OPDRV activity was logged in the control room narrative logs and that the log entry appropriately recorded the safety-related pump (A RHR) that was the standby source of makeup designated for the evolution. The inspectors noted that the reactor vessel water level was maintained at least 22 feet and 2 inches over the top of the RPV flange in compliance with the minimum water level allowed by Hope Creek TS LCO 3.9.8 applicability. The inspectors also noted that at least one safety-related pump was the standby source of makeup designated in the control room narrative logs for the evolution with the capability to inject water equal to, or greater than, the maximum potential leakage rate from the RPV for a minimum time period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. PSEG reported that the worst case estimated time to drain the reactor cavity to the RPV flange was 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />, which met the EGM criteria of greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors verified that the OPDRV was not conducted in Mode 4 and that PSEG did not move recently irradiated fuel during the OPDRV. The inspectors noted that PSEG had in place a contingency plan for isolating the potential leakage path. The inspectors verified that two independent means of measuring RPV water level (one alarming) were available for identifying the onset of loss of inventory events with sufficient time to close secondary containment before reactor water level reached the top of the RPV flange. TS 3.6.5.1 is applicable in Operational Conditions 1, 2, 3 and * requires that secondary containment integrity shall be maintained. Operational Condition * is defined, in part, as being during OPDRV. TS 3.6.5.1, action b, states, in part, in operational condition, * suspend operations with a potential for draining the reactor vessel. Contrary to the above, between 2:00 p.m. on April 14, 2015, and 6:45 a.m. on April 30, 2015, Hope Creek Generating Station did not maintain secondary containment integrity while conducting OPDRV activities. Because the violation was identified during the discretion period described in EGM 11-003 Revision 2, the NRC is exercising enforcement discretion in accordance with NRC Enforcement Policy Section 2.2.4, Exceptions to Using Only the Operating Reactor Assessment Program, and Section 3.5, Violations Involving Special Circumstances, and, therefore, will not issue enforcement action for this violation. In accordance with EGM 11-003 Revision 2, each licensee that receives discretion must submit a license amendment request within 4 months of the NRC staffs publication in the Federal Register of the notice of availability for a generic change to the STS to provide more clarity to the term OPDRV. The inspectors observed that PSEG is tracking the need to submit a license amendment request in its corrective action program as notification 20559547. This LER is closed. |
| Site: | Hope Creek  |
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| Report | IR 05000354/2015002 Section 4OA3 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | B Fuller C Bixler G Dentel H Gray J Hawkins M Draxton R Nimitz S Haney T Burns T O'Hara R Vadella |
| Violation of: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications Technical Specification - Procedures 10 CFR 50.73 Technical Specification |
| INPO aspect | |
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Finding - Hope Creek - IR 05000354/2015002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Hope Creek) @ 2015Q2
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