05000388/LER-2015-005

LER-2015-005, Condition Prohibited by Technical Specifications Due to Implementation of Enforcement Guidance Memorandum (EGM) 11-003

Susquehanna Steam Electric Station, Unit 2
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3882015005R00 - NRC Website

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

• Residual Heat Removal (RHR) system maintenance

• Hydraulic Control Unit (HCU) maintenance

• Local Power Range Monitor (LPRM) replacement

• Control Rod Drive (CRD) mechanism replacements

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