05000387/FIN-2013003-04
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 1 |
| Description | From April 17 through May 17, PPL performed OPDRVs without establishing secondary containment integrity. An OPDRV is an activity that could result in the draining or siphoning of the RPV water level below the top of fuel, without crediting the use of mitigating measures to terminate the uncovering of fuel. TS 3.6.4.1, Secondary Containment requires that secondary containment be operable and is applicable during OPDRVs. The required action for this specification if secondary containment is inoperable in this condition of applicability is to initiate actions to suspend OPDRVs immediately. Therefore, failing to maintain secondary containment operability during OPDRVs without initiating actions to suspend the operation was considered a condition prohibited by TSs as defined by 10 CFR 50.73(a)(2)(i)(B). As reported in LER 05000388/2013-001, PPL conducted the following OPDRVs during the period of secondary containment inoperability: Recirculation system drain and maintenance; RWCU system removal from service, maintenance, testing and restoration; RHR system LLRT, drain, maintenance and testing; Hydraulic Control Unit (HCU) replacement; Local Power Range Monitor (LPRM) replacement; Scram Discharge Volume (SDV) maintenance and testing; CRD mechanism replacements; Scram Pilot Solenoid Valve testing; Reset of Reactor Scram; and Dynamic vent of CRD headers. NRC EGM 11-03, Enforcement Guidance Memorandum On Dispositioning BWR Licensee Noncompliance With TS Containment Requirements During Operations With A Potential For Draining The Reactor Vessel, provides, in part, for the exercise of enforcement discretion only if the licensee demonstrates that it has met four specific criteria during an OPDRV activity. The inspectors assessments of PPLs implementation of these four criteria during the LPRM replacement activity are described below: 1) The inspectors observed that, as required by the EGM, the OPDRV activities were logged in the control room narrative logs and that the log entries appropriately documented actions being taken to ensure water inventory was maintained and defense-in-depth criteria were in place. 2) The inspectors noted that the reactor vessel water level was maintained above the RHR high water level setpoint of 22 feet. 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 evolutions. PPL logged that the worst case estimated time to drain the reactor cavity to the RPV flange was greater than the EGM criteria of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 3) The inspectors verified that the OPDRVs were not conducted in Mode 4 and that PPL maintained secondary containment operability for the refueling floor while moving irradiated fuel during OPDRVs. The inspectors noted that PPL had contingency plans in place for isolating the potential leakage paths, should difficulty arise during the LPRM replacement activities. Additionally, 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. 4) Inspectors verified that, for the periods of April 17 through May 7 and May 10 through May 17, all other TSs were met during OPDRVs with secondary containment inoperable. For the period of May 7 through May 10, inspectors identified that the requirements of TS 3.8.2, AC Sources- Shutdown was not met when operators failed to adequately assess the operability of the EDGs and offsite power. Enforcement associated with performance deficiency is discussed in Section 1R15 of this report. TS 3.6.4.1 is applicable during OPDRVs and requires that secondary containment be operable. TS 3.6.4.1, action C.3, requires operators to initiate actions to suspend OPDRVs immediately upon discovery that secondary containment is inoperable. Contrary to the above, between 12:02 a.m. on April 17, 2013, and 12:53 a.m. on May 7, 2013, and between 3:32 a.m. on May 10, 2013, and 10:00 p.m. on May 17, 2013, PPL did not maintain secondary containment operable while performing OPDRVs. Because the violation was identified during the discretion period described in EGM 11-003, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation. In accordance with EGM 11-003, 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 Standard TSs to provide more clarity to the term OPDRV. The inspectors observed that PPL is tracking the need to submit a license amendment request in its CAP as CR 1707662. This LER is closed. |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2013003 Section 4OA3 |
| Date counted | Jun 30, 2013 (2013Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | J Greives A Bolger M Gray F Arner J Laughlin P Finney D Orr S Barber R Rolph D Dodson |
| Violation of: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73 Technical Specification |
| INPO aspect | |
| ' | |
Finding - Susquehanna - IR 05000387/2013003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Susquehanna) @ 2013Q2
Self-Identified List (Susquehanna)
| |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||