05000387/FIN-2018002-04
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | |
| Description | From April 2 through April 24, 2018, Susquehanna performed OPDRVs without establishing secondary containment integrity. An OPDRV is an activity that could result in the draining or siphoning of the reactor pressure vessel 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. As reported in LER 05000387/2018-001, Susquehanna conducted the following OPDRVs during the period of secondary containment inoperability: Recirculation system maintenance and pump replacement; Reactor water cleanup system flushes and maintenance; RHR system maintenance; Hydraulic control unit and control rod drive system maintenance; Local power range monitor replacements, including Intermediate Range Monitor 1E Dry Tube replacement; Control rod drive mechanism replacements; and Core spray instrument line flush. NRC EGM 11-03, EGM on Dispositioning BWR Licensee Noncompliance With TS Containment Requirements During Operations With A Potential For Draining The Reactor Vessel, Revision 3, provides, in part, for the exercise of enforcement discretion only if the licensee demonstrates that it has met specific criteria during an OPDRV activity. The inspectors assessed that Susquehanna adequately implemented these criteria. In accordance with EGM 11-003, in order to continue to receive enforcement discretion, a license amendment request (LAR) must be submitted and accepted for review within 12 months of the NRC staffs publication of the generic change, which occurred on December 20, 2016. The inspectors verified that Susquehanna submitted the required LAR on September 20, 2017 (ADAMS Accession No. ML17265A434), and that it was subsequently accepted by the NRC for review by a letter dated October 16, 2017 (ADAMS Accession No. ML17290A024).Corrective Action: Susquehanna submitted an LAR to adopt TS Task Force Traveler 542, Reactor Pressure Vessel Water Inventory Control, on September 20, 2017.Corrective Action Reference: AR-2015-01733 Enforcement: Violation: 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). Contrary to the above,from April 2 through April 24, 2018, Susquehanna performed OPDRVs without establishing secondary containment integrity. Basis for Discretion: The NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy because all criteria described in EGM 11-003 were met, enforcement discretion was previously authorized by EA-2017-089, and the licensee submitted an LAR on September 20, 2017 which was subsequently accepted by the NRC for review on October 16, 2017, and, therefore, will not issue enforcement action for this violation. The disposition of this violation closes LER 05000387/2018-001-00. |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2018002 Section 4OA3 |
| Date counted | Jun 30, 2018 (2018Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | No Cornerstone |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | L Micewski T Daun E Burket J Furia A Turilin J Greives |
| Violation of: | Technical Specification |
| INPO aspect | |
| ' | |
Finding - Susquehanna - IR 05000387/2018002 | ||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Susquehanna) @ 2018Q2
Self-Identified List (Susquehanna)
| ||||||||||||||||||||||||||||||||||||||||||||||||||