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 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 4/14/2015 and 5/16/2015, Susquehanna Steam Electric Station ( SSES) performed Operations with the Potential for Draining the Reactor Vessel ( OPDRV) activities on Unit 2 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 2 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. 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. A license amendment request will be submitted following NRC approval of the Technical Specifications Task Force ( TSTF) traveler associated with generic resolution of this issue. |
CONDITIONS PRIOR TO EVENT
Unit 2 — Mode 5, 0 percent Rated Thermal Power
EVENT DESCRIPTION
While in Mode 5, Refueling, OPDRVs were performed as part of the Unit 2 17th Refueling and Inspection Outage (U2 17 RIO) without an operable secondary containment. This event timeline is as follows:
04/14/2015 - Commenced OPDRV activity under the provisions of EGM 11-003, Revision 2.
4/14/2015 to 5/16/2015 - Performed OPDRV activities in support of U2 17th RIO.
5/17/2015 — Cleared Unit 2 LCO 3.6.4.1 The station used the provisions of EGM 11-003, Revision 2 to perform the following outage activities:
- Recirculation system maintenance
- Reactor Water Clean Up (RWCU) system maintenance
- Hydraulic Control Unit (HCU) maintenance
- Local Power Range Monitor (LPRM) replacement
CAUSE OF EVENT
Implementation of EGM 11-003, Revision 2 interim actions during the U2 17th RIO was a planned activity. As such, no cause determination was performed on the events.
ANALYSIS/SAFETY SIGNIFICANCE
This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by SSES Unit 2 Technical Specification 3.6.4.1, which prohibits activities identified as OPDRVs in Mode 5 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 2. 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 traveler associated with generic resolution of this issue within the time constraints given in EGM 11-003, Revision 2.
No regulatory commitments are associated with this report.
COMPONENT FAILURE INFORMATION
None
PREVIOUS SIMILAR EVENTS
Revision 2 Revision 1
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05000387/LER-2015-001 | Inoperability of the 'B' Emergency Diesel Generator due to Fuel Oil Leakage LER 15-001-01 for Susquehanna, Unit 1, Regarding Condition Prohibited by Technical Specifications Due to Drift of Reactor Pressure Steam Dome - Low Switches | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | 05000388/LER-2015-001 | Condition Prohibited by Technical Specifications Due to Drift of Reactor Pressure Steam Dome - Low Switches | 10 CFR 50.73(a)(2)(v)(D), Loss of Safety Function - Mitigate the Consequences of an Accident 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System | 05000387/LER-2015-002 | Secondary Containment Inoperability Due to Failure to Meet Technical Specification Surveillance Requirement 3.6.4.1.1 | 10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material | 05000388/LER-2015-002 | Secondary Containment Inoperability Due To Failure to Meet Technical Specification Surveillance Requirement 3.6.4.1.1 | 10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material | 05000387/LER-2015-003 | Secondary Containment Inoperability Due to Failure to Meet Technical Specification Surveillance Requirement 3.6.4.1.1 LER 15-003-01 for Susquehanna, Unit 1, Regarding Secondary Containment Inoperability Due to Failure to Meet Technical Specification Surveillance Requirement 3.6.4.1.1 | 10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material | 05000388/LER-2015-003 | Unit 2 Automatic Reactor Scram Caused by Main Turbine Trip Due to Loss of Main Condenser Vacuum | 10 CFR 50.73(a)(2)(iv)(A), System Actuation | 05000387/LER-2015-004 | Secondary Containment Inoperable due to Secondary Containment Boundary Door Found Ajar | 10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material | 05000388/LER-2015-004 | Degraded Condition Due to Reactor Coolant Pressure Boundary Leakage Caused by Vibration and Stiff Pipe Connection | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded | 05000388/LER-2015-005 | Condition Prohibited by Technical Specifications Due to Implementation of Enforcement Guidance Memorandum (EGM) 11-003 | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | 05000387/LER-2015-006 | Loss of Safety Function due to Inoperability of Both Trains of the Standby Gas Treatment System and a Loss of Safety Function of the Control Room Emergency Outside Air Supply System due to Air Flow Controller found in Manual LER 15-006-01 for Susquehanna, Unit 1, Regarding Loss of Safety Function due to Inoperability of Both Trains of the Standby Gas Treatment System and a Loss of Safety Function of the Control Room Emergency Outside Air Supply System due to Air Flow... | 10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material | 05000388/LER-2015-006 | Secondary Containment Declared Inoperable Due to Secondary Containment Boundary Door 104-R Breached. | 10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material | 05000387/LER-2015-007 | Unit 1 'B' Inboard Main Steam Isolation Valve, HV141F022B closed during surveillance test which caused a SCRAM on Unit 1 LER 15-007-00 for Susquehanna, Unit 1, Regarding 'B' Inboard Main Steam Isolation Valve, HV141 F022B Closed During Surveillance Test Which Caused a SCRAM | 10 CFR 50.73(a)(2)(iv)(A), System Actuation | 05000388/LER-2015-007 | 1 of 3 | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | 05000387/LER-2015-008 | 1 of 4 | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | 05000387/LER-2015-009 | Pressure Boundary Leakage From an Inadequate Weld Repair in Small Bore Pump Seal Vent Piping LER 15-009-00 for Susquehanna, Unit 1, Regarding Pressure Boundary Leakage From an Inadequate Weld Repair in Small Bore Pump Seal Vent Piping | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded |
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