05000387/LER-2016-006

LER-2016-006, Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

Susquehanna Steam Electric Station Unit 1
Event date:	03-16-2016
Report date:	05-10-2016
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3872016006R00 - NRC Website

LER 16-006-00 for Susquehanna, Unit 1, Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

ML16131A700
Person / Time
Site:	Susquehanna
Issue date:	05/10/2016
From:	Franke J A Susquehanna, Talen Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EGM 11-003, PLA-7461 LER 16-006-00
Download: ML16131A700 (4)

comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by intemet e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

CONDITIONS PRIOR TO EVENT

Unit 1 — Mode 5, 0 percent Rated Thermal Power

EVENT DESCRIPTION

While in Mode 5, Refueling, OPDRVs were performed as part of the Unit 1 19th Refueling and Inspection Outage (U1 19 RIO) without an operable secondary containment. This event timeline is as follows:

3/15/2016, 0300 — Operations entered Unit 1 Limiting Condition for Operations (LCO) 3.6.4.1 due to Zone I Secondary Containment isolated from the Recirculation Plenum and relaxed in support of outage activities.

3/16/2016, 0340 to 4/11/2016, 1230 — Station performed OPDRV activities under the provisions of EGM 11- 003, Revision 3, in support of U1 19th RIO.

4/12/2016, 1700 — Operations cleared Unit 1 LCO 3.6.4.1 The station used the provisions of EGM 11-003, Revision 3 to perform the following outage activities:

• Recirculation system maintenance

• Reactor Water Cleanup (RWCU) system maintenance

• Residual Heat Removal (RHR) system maintenance

• Hydraulic Control Unit (HCU) and Control Rod Drive (CRD) system maintenance

• Local Power Range Monitor (LPRM) replacements

• Control Rod Drive (CRD) Mechanism replacements

CAUSE OF EVENT

Implementation of EGM 11-003, Revision 3, interim actions during the U1 19th RIO was a planned activity.

As such, no cause determination was performed on the events.

comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

ANALYSIS/SAFETY SIGNIFICANCE

This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by SSES Unit 1 TS 3.6.4.1, which prohibits activities identified as OPDRVs while secondary containment is inoperable.

The OPDRV activities described in this report were accomplished using the interim actions provided by the NRC in EGM 11-003, Revision 3. In accordance with station procedures controlling OPDRVs, SSES adhered to the NRC plain language meaning of OPDRV activities that could potentially result in draining or siphoning the Reactor Pressure Vessel (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. SSES also met the requirements which specify the minimum makeup flow rate and water inventory. Further, an adequate defense in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable. Since these compensatory measures were implemented, an adequate level of safety was provided during the performance of the OPDRV activities described in this report.

CORRECTIVE ACTIONS

SSES will submit a license amendment following NRC approval of the Technical Specifications Task Force (TSTF) traveler associated with generic resolution of this issue within the time constraints given in EGM 11- 003, Revision 3.

No regulatory commitments are associated with this report.

COMPONENT FAILURE INFORMATION

None

PREVIOUS SIMILAR EVENTS

Enforcement Guidance Memorandum (EGM) 11-003," dated June 10, 2015.11-003, Revision 2," dated June 12, 2014.11-003, Revision 1," dated June 14, 2013.