05000397/LER-1917-002, Re Implementation of Enforcement Guidance Memorandum 11-003, Revision 3
| ML17191B138 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/10/2017 |
| From: | Hettel W Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-17-123 LER 17-002-00 | |
| Download: ML17191B138 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) |
| 3971917002R00 - NRC Website | |
text
ENERGY NORTHWEST G02-17-123 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 William G. Hettel Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509-377-8311IF. 509-377-4150 wghettel@energy-northwest.com 10 CFR 50.73
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSEE EVENT REPORT NO. 2017-002-00
Dear Sir or Madam:
Transmitted herewith is Licensee Event Report No. 2017-002-00 for Columbia Generating Station. This report is submitted pursuant to 1 O CFR 50.73(a)(2)(i)(B).
There are no commitments being made to the Nuclear Regulatory Commission herein. If you have any questions, or require additional information, please contact Ms. D. M.
Wolfgramm, Regulatory Compliance Supervisor, at (509) 377-4792.
Executed on this tO day of July, 2017 Respectfully, W. G. Hettel Vice President, Operations : Licensee Event Report 2017-002-00 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident lnspector/988C CD Sonoda - BPA/1399 WA Horin - Winston & Strawn July 10, 2017
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (06-2016)
Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
,~iO"<.t Reported lessons learned are incorporated into the licensing process and fed back to industry.
~¥.\\
LICENSEE EVENT REPORT (LER)
Send 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 e-mail
'~
I (See Page 2 for required number of digits/characters for each block) to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104 ), Office of Management and Budget, Washington, DC 20503. If a (See NUREG-1022, R.3 for instruction and guidance for completing this form means used to impose an infonmation collection does not display a currently valid OMB control http://www.nrc.gov/reading-rm/doc-collections/nuregs[staff/sr1022Lr3/)
number, the NRC may not conduct or sponsor, and a person is not required to respond to, the infonmation collection.
- 3. PAGE Columbia Generating Station 05000 397 1 OF 3
- 4. TITLE Implementation of Enforcement Guidance Memorandum 11-003, Revision 3
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED I
SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR MONTH DAY YEAR NUMBER NO.
05000 FACILITY NAME DOCKET NUMBER 05 16 2017 2017 -
002 - 00 7
10 2017 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
D 20.2201(b)
D 20.2203(a)(3)(i)
D 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A) 5 D 20.2201 (d)
D 20.2203(a)(3)(ii)
D 50.73(a)(2)(ii)(B)
D 50.73(a)(2)(viii)(B)
D 20.2203(a)(1>
D 20.2203(a)(4)
D so.73(a)(2)(iii)
D 50.73(a)(2)(ix)(A)
D 20.2203(a)(2)(i)
D 50.36(c)(1)(i)(A)
D 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x)
- 10. POWER LEVEL D 20.2203(a)(2)(ii)
D 50.36(c)(1 )(ii)(A)
D 50.73(a)(2)(v)(A)
D 13.11(a)(4)
D 20.2203(a)(2)(iii)
D so.36(c)(2)
D 50.73(a)(2)(v)(B)
D 13.11(a)(s)
D 20.2203(a)(2)(iv)
D so.46(a)(3)(ii)
D 50.73(a)(2)(v)(C)
D 73.77(a)(1) 000 D 20.2203(a)(2)(v)
D 50.73(a)(2)(i)(A)
D 50.73(a)(2)(v)(D)
D 13.77(a)(2)(i)
D 20.2203(a)(2)(vi)
({] 50.73(a)(2)(i)(B)
D 50.73(a)(2)(vii)
D 13.77(a)(2)(ii)
D 50.73(a)(2)(i)(C)
D OTHER Specify in Abstract below or in EVENT DESCRIPTION continued 6/12/17 0435 PDT - Commenced OPDRV window to support the Reactor Pressure Vessel leakage test.
6/15/17 1017 PDT - Exited OPDRV window.
REPORTABILITY AND SAFETY ASSESSMENT
This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by TS 3.6.4.1, which prohibits performing 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 EGM 11-003, Revision 3. In accordance with station procedures, Energy Northwest adhered to the Nuclear Regulatory Commission plain language definition of OPDRV activities that could potentially result in draining or siphoning the reactor pressure vessel water below the top of the fuel. During all OPDRV activities, the following prerequisites were met:
- 1. The plant was in Mode 5 with the reactor cavity water level was maintained greater than or equal to 22 feet above the Reactor Pressure Vessel (RPV) flange.
- 2. Two independent means of monitoring RPV water level were available.
- 3. At least one Emergency Core Cooling System pump was available and capable of injecting water equal to or greater than the maximum potential leakage rate from the RPV for a minimum of four hours.
- 4. The size of the allowable draining path was minimized to maintain drain down time to greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- 5. Movement of recently irradiated fuel was prohibited.
- 6. OPDRV activities were prohibited during Mode 4 with secondary containment inoperable.
- 7. The capability to isolate a potential leakage path during OPDRV activities before the water inventory could reach the RPV flange was maintained.
The required compensatory measures were properly implemented and adequate levels of safety were provided during the performance of the OPDRV activities described in this report. Based on this information, the performance of these OPDRV activities was determined to have very low safety significance.
CAUSE OF EVENT
Implementation of EGM 11-003, Revision 3, interim actions during Columbia's Refueling Outage R23 was a planned activity. As such, no cause determination was performed on this condition.
SIMILAR EVENTS
On July 7, 2015, Energy Northwest submitted LER 2015-003-00 to report a similar occurrence. During Columbia's Refueling Outage R22, EGM 11-003, Revision 2, was utilized for OPDRV activities while secondary containment was inoperable.
FURTHER CORRECTIVE ACTIONS Consistent with the guidance provided in EGM 11-003, Revision 3, Energy Northwest will submit a license amendment request to adopt Technical Specification Task Force Traveler 542, Reactor Pressure Vessel Water Inventory Control, associated with generic resolution of this issue. Page 3
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