05000366/LER-2013-002
| Edwin I. Hatch Nuclear Plant Unit 2 | |
| Event date: | 02-19-2013 |
|---|---|
| Report date: | 04-19-2013 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3662013002R00 - NRC Website | |
PLANT AND SYSTEM IDENTIFICATION
General Electric - Boiling Water Reactor Energy Industry Identification System codes appear in the text as (EIIS Code XX).
DESCRIPTION OF EVENT
The OPDRVs in Table 1 were performed while in Mode 5 without an operable secondary containment, contrary to Technical Specifications (TS) 3.6.4.1. The NRC recognized that such activities may need to be performed during refueling outages while activities were underway with the BWROG to formulate acceptable generic changes to BWR Technical Specifications. NRC Regulatory Issue Summary (RIS) 2012-11 communicated this guidance to the industry along with Enforcement Guidance Memorandum (EGM) 11-003, Revision 1 that allowed implementation of specific interim actions as an alternative to full compliance with the Technical Specifications while the improvements in the Technical Specifications are under development with the BWROG. Required interim actions specified in the EGM were incorporated into plant procedure 31- GO-OPS-025-0: OPERATIONS WITH THE POTENTIAL TO DRAIN THE REACTOR VESSEL (OPDRV). This procedure was then utilized on three occasions during the 2013 HNP-2 Refueling Outage.
Table 1: HNP-2 OPDRVs Performed February 2013 OPDRV Activity Start End LPRM Removal and Replacement 02/19/2013, 0908 EST 02/19/2013, 1848 EST CRD Drive Removal and 02/20/2013, 1130 EST 02/21/2013, 1115 EST Replacement HCU Venting and Recoupling 02/25/2013, 1505 EST 02/26/2013, 1048 EST
CAUSE OF EVENT
Implementation of RIS 2012-11 and EGM 11-003, Revision 1 interim actions during the HNP-2R22 Refueling Outage was a planned activity. As such, no cause determination was performed for the events.
REPORTABTLITY ANALYSIS And SAFETY ASSESSMENT This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by the HNP-2 Technical Specification 3.6.4.1.C.3, which prohibits performing activities identified as OPDRVs in Mode 5 while secondary containment is inoperable..
OPDRVs discussed in this report were performed during the 2R22 Refueling Outage and were accomplished using interim actions provided by the NRC in EGM 11-003, Revision 1. HNP-2 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 the fuel. This included evolutions involving aligning and realigning plant systems prior to achieving steady-state water level control, without taking credit for mitigating measures. HNP 2 also met the requirements which 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 Technical complete 1.1,a, If unsure, obtain peer review from 10 CFR 50.59 qualified individual. 1 — (C
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