05000387/LER-2018-001, Implementation of Enforcement Guidance Memorandum (Egm) 11-003, Revision 3, During Unit 1 Refueling
| ML18144A818 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/24/2018 |
| From: | Berryman B Susquehanna, Talen Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-7705 LER 2018-001-00 | |
| Download: ML18144A818 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3872018001R00 - NRC Website | |
text
MAt2 4 2018 Brad Berryman Site Vice President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.2904 Fax 570.542.1504 Brad.Berryman@TalenEnergy.com SUSQUEHANNA STEAM ELECTRIC STATION LICENSEE EVENT REPORT 50-387/2018-001-00 UNIT 1 LICENSE NO. NPF-14 PLA-7705 TALEN~
ENERGY 10 CFR 50.73 Docket No. 50-387 Attached is Licensee Event Report (LER) 50-387/2018-001-00. The condition reported by this LER was expected as a result of planned activities in support of a routine refueling outage. As described in the LER, the United States (U.S.) Nuclear Regulatory Commission (NRC) provided enforcement discretion guidance, applicable to Boiling Water Reactor licensees, that allows the reported condition. Although this allowance is provided by the NRC's enforcement guidance, the activities are still considered reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications (TS). Specifically, operations with the potential for draining the reactor vessel (OPDRVs) were performed while in Mode 5 without secondary containment being operable, as expected and allowed by the enforcement guidance. The provisions contained in the NRC enforcement guidance memorandum (EGM)11-003, Revision 3, "Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel," were used during performance of the specified OPDRV activities.
There were no actual consequences to the health and safety of the public as a result of this event.
This letter contains no new regulatory commitments.
Should you have any questions regarding this submittal, please contact Mr. Jason Jennings, Manager-Nuclear Regulatory Affairs at (570) 542-3155.
Attachment: LER 50-387/2018-001-00 Copy:
NRC Region I Ms. T. E. Hood, NRC Project Manager Ms. L. H. Micewski, NRC Sr. Resident Inspector Mr. M. Shields, PA DEP/BRP Document Control Desk PLA-7705
NRC FORM366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 03/31/2020 (04-2018)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 13. Page Susquehanna Stear11 Electric Station Unit 1 05000387 1 OF3
- 4. Title: Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3, during Unit 1 Refueling
- 5. Event Date
- 6. LER Number
- 7. Report Date
- 8. Other Facilities Involved Sequential Rev Facility Name Docket Number Month Day Year Year Month Day Year N/A Number No.
05000 04 02 2018 2018
- - 001
- - 00 05 2018 Facility Name Docket Number
- 24 N/A 05000
- 9. Operating Mode Abstract (Limit to 1400 spaces, i.e., approximately 14 single-spaced typewritten lines)
The condition reported by this Licensee Event Report (LER) was an expected condition, which was the result of planned activities in support of a routine refueling outage. As described in the LER, the United States (U.S.)
Nuclear Regulatory Commission (NRC) provided enforcement guidance, applicable to boiling water reactor licensees, that allows the reported condition. Although this allowance is provided by the NRC's enforcement guidance, the planned activities are still considered reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications (TS).
Between 04/02/2018 and 04/24/2018, Susquehanna Steam Electric Station (SSES) performed Operations with the Potential for Draining the Reactor Vessel (OPDRV) activities on Unit 1 while in Mode 5 without an operable secondary containment, as expected and allowed by the enforcement guidance. Although NRC Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 allows the implementation of interim actions as an alternative to full compliance, this condition is still considered a condition prohibited by TS 3.6.4.1, Secondary Containment. The OPDRV activities were planned activities that were completed under the guidance of plant procedures and are considered to have low safety significance based on interim actions taken. Since these actions were deliberate, no cause determination was necessary.
There were no actual consequences to the health and safety of the public as a result of this event.
NRC FORM 366 (04-2018)
CONDITIONS PRIOR TO EVENT
Unit 1 - Mode 5, 0 percent Rated Thermal Power
EVENT DESCRIPTION
YEAR 2018 SEQUENTIAL NUMBER 001 REV NO.
00 While in Mode 5, Refueling, Operations with the Potential for Draining the Reactor Vessel (OPDRV) activities were performed as part of the Unit 1 20th Refueling and Inspection Outage (U1 20 RIO) without an operable secondary containment [EllS Code: NG]. The event timeline for these activities is as follows:
04/02/2018, 14:15 - Operations entered Unit 1 Limiting Condition for Operations (LCO) 3.6.4.1 due to Zone I Secondary Containment being isolated from the Recirculation Plenum and relaxed in support of outage activities.
04/02/2018, 19:20 to 04/24/2018, 19:50- Station performed OPDRV activities under the provisions of EGM 11-003, Revision 3, in support of U1 20 RIO.
04/25/2018, 22:23 - Operations cleared Unit 1 LCO 3.6.4.1 as Zone I was re-established and un-isolated from the recirculation plenum.
The station used the provisions of EGM 11-003, Revision 3 to perform the following outage activities:
- Recirculation system [EllS Code: AD] maintenance and pump replacement
- Reactor Water Cleanup (RWCU) [EllS Code: CE] system flushes and maintenance
- Residual Heat Removal (RHR) system [EllS Code: BO] maintenance
- Hydraulic Control Unit (HCU) and Control Rod Drive (CRD) system [EllS Code: AA] maintenance
- Local Power Range Monitor (LPRM) [EllS Code: IG] replacements, including Intermediate Range Monitor 1 E Dry Tube replacement
- Control Rod Drive (CRD) Mechanism [EllS Code: AA] replacements
- Core Spray [EllS Code: BM] instrument line flush
CAUSE OF EVENT
Implementation of EGM 11-003, Revision 3, interim actions during the U1 20 RIO was a planned activity. As such, no cause determination was performed on the events. Page 2 of 3 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 3/31/2020 (04-2018)
LICENSEE EVENT REPORT {LER}
CONTINUATION SHEET (See NUREG-1 022, R.3 for instruction and guidance for completing this form http://wvvw. nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1 022/r3D
, the NRC may not conduct or sponsor, and a person is not required to respond to, the informalion colleclion.
- 3. LER NUMBER YEAR Susquehanna Steam Electric Station Unit 1 05000-387 2018
ANALYSIS/SAFETY SIGNIFICANCE
SEQUENTIAL NUMBER 001 REV NO.
00 This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition 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 available. This ensures 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. There were no actual consequences to the health and safety of the public as a result of the OPDRV activities.
CORRECTIVE ACTIONS
SSES submitted a license amendment request to adopt Technical Specifications Task Force Traveler 542 (TSTF-542), Reactor Pressure Vessel Water Inventory Control on September 20, 2017 (ML17265A434).
The NRC completed acceptance review of the license amendment request on October 16, 2017 (ML17290A024). No regulatory commitments are associated with this report.
PREVIOUS SIMILAR EVENTS
LER 50-388/2017-002-00 (PLA-7589): "Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 during Unit 2 Refueling," dated May 05, 2017.
LER 50-387/2016-006-00 (PLA-7461): "Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3," dated May 10, 2016.
LER 50-388/2015-005-00 (PLA-7340): "Condition Prohibited by Technical Specification Due to Implementation of Enforcement Guidance Memorandum (EGM) 11 -003," dated June 10, 2015.
LER 50-387/2014-006-00 (PLA-7185): "Implementation of Enforcement Guidance Memorandum (EGM) 11 -003, Revision 2," dated June 12, 2014.
LER 50-388/2013-001 -00 (PLA-7018): "Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 1," dated June 14, 2013. Page 3 of 3