05000354/LER-2013-004
| Hope Creek Generating Station | |
| Event date: | 10-15-2013 |
|---|---|
| Report date: | 12-10-2013 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3542013004R00 - NRC Website | |
PLANT AND SYSTEM IDENTIFICATION
General Electric — Boiling Water Reactor (BWR/4)* Reactor Pressure Vessel (AC) — EIIS Identifier {AC/RPV} Secondary Containment (NG) — EIIS Identifier {NG} *Energy Industry Identification System {EIIS} codes and component function identifier codes appear as {SS/CCC}
IDENTIFICATION OF EVENT
Event Dates: October 15, October 20, and October 23, 2013 Discovery Dates: October 15, October 20, and October 23, 2013
CONDITIONS PRIOR TO EVENT
Hope Creek was shutdown for Refueling Outage H1 R18 in Operational Condition (OPCON) 5 - Refueling Operations.
DESCRIPTION OF EVENT
On October 15, October 20, and October 23, 2013, with Hope Creek Generating Station (HCGS) in a planned refueling outage and the reactor cavity flooded up in OPCON 5, HCGS performed operations with a potential to drain the reactor vessel (OPDRV) without an operable secondary containment {NG}. These operations are prohibited by Technical Specification (TS) 3.6.4.1, "Secondary Containment." The NRC recognized that such activities may need to be performed during refueling outages while activities were underway with the Boiling Water Reactor Owners Group (BWROG) to formulate acceptable generic changes to the BWR Technical Specifications (TS). NRC guidance provided in Enforcement Guidance Memorandum (EGM) 11-003, Revision 1, "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," dated December 20, 2012, allowed the implementation of specific interim actions, as an alternative to full compliance with TS, while the improvements in the TS are under development with the BWROG. The required interim actions specified in the EGM were incorporated into plant procedure OP-HC-108-102, "Management of Operations with the Potential to Drain the Reactor Vessel." This procedure was then utilized on three occasions, listed in Table 1, during Refueling Outage (H1R18) in October.
Table 1 — HCGS OPDRVs Performed October 2013 Activityllmplementation Duration Start End 'A' Recirc Pump Seal Replacement 14 days, 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, 43 minutes October 15, 2013 at 17:00 EDT October 30, 2013 at 11:43 EDT CRD Mechanism and LPRM Replacement 4 days, 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, 6 minutes October 20, 2013 at 12:00 EDT October 24, 2013 at 19:06 EDT
RWCU LLRT
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 35 minutes October 23, 2013 at 18:29 EDT October 24, 2013 at 19:06 EDT These conditions are being reported in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by TS.
CAUSE OF EVENT
Implementation of EGM 11-003, Revision 1, interim actions during the HOGS refueling outage (H1R18) was a planned activity. As such, no cause determination was performed for the event.
SAFETY CONSEQUENCES AND IMPLICATIONS
The OPDRVs discussed in this report were performed during the HOGS refueling outage (H1R18) and were accomplished using the interim actions provided by the NRC in EGM 11-003, Revision 1. For these events, HOGS adhered to the NRC plain language meaning of OPDRV activities that could potentially result in draining or siphoning the RPV water level below the top of fuel. This included evolutions involving aligning and realigning plant systems prior to achieving steady-state water level control, without taking credit for mitigating measures. HOGS also met the requirements that specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain down times. Further, 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 TS requirements for activities were followed.
Since these compensatory measures were properly implemented, an adequate level of safety was provided during the OPDRV activities described in this report. Based on this information, the performance of these OPDRV activities were determined to have a low safety significance.
PREVIOUS EVENTS
A review of Licensee Event Reports and the corrective action program for the past three years identified the following previous similar occurrences.
- LER 2012-003-00, dated May 5, 2012, reported an OPDRV activity during the 2012 refueling outage (H1R17). Interim actions in accordance with Revision 0 of the EGM were applied. No corrective actions were stated.
CORRECTIVE ACTIONS
HOGS will submit a license amendment request to adopt a Technical Specification Task Force (TSTF) traveler associated with generic resolution of this issue, within four months after the issuance of the Notice of Availability of the TSTF traveler.
COMMITMENTS
This LER contains no regulatory commitments.