05000458/FIN-2013005-03
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Finding | |
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| Title | Operations Prohibited by Technical Specifications for Operations with a Potential to Drain the Reactor Vessel |
| Description | On March 2, 2013, with the plant in a refueling outage, the licensee performed maintenance to replace the pump seals and the flow control valve packing in the A loop of the reactor recirculation system. The maintenance constituted an operation with a potential to drain the reactor vessel (OPDRV). Technical Specification 3.6.1.10 requires an operable primary containment during an OPDRV. The licensee did not take the actions to establish an operable primary containment during the maintenance window for the reactor recirculation system. Instead the licensee met the alternative requirements as described in NRC Enforcement Guidance Memorandum (EGM) 11-003, Dispositioning Boiling Water Reactor License Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel, Revision 1. The alternative requirements that the licensee complied with include the following: 1) The inspectors verified that the licensee declared, in the control room logs, that the plant was in an OPDRV activity. In addition, the licensee took actions to ensure water inventory was maintained and that a defense-in-depth criteria, was in place prior to entering the OPDRV activity. 2) During the OPDRV activities, the reactor vessel water level was maintained at or above 23 feet over the top of the reactor pressure vessel flange. 3) The OPDRV was not conducted in Mode 4 and the licensee did not move recently irradiated fuel during the OPDRV. 4) The licensee evaluated that during the OPDRV activity, the time to drain down the water inventory from 23 feet over the top of the reactor pressure vessel flange, to the reactor pressure vessel flange was greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This was based on the calculated maximum leak rate of OPDRV activities. 5) The capability to isolate the potential leakage path during OPDRV activities before the inventory reached the reactor pressure vessel flange was maintained. 6) During OPDRV activities, more than one safety-related pump was available that was aligned to a makeup water source with the capability to inject water at greater than the maximum potential leakage rate from the reactor pressure vessel, for a minimum time period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. 7) The inspectors verified that the licensee maintained two independent means of monitoring the reactor pressure vessel water level in an effort to identify the onset of a loss of inventory event during the OPDRV activity. These monitoring methods were in accordance with the requirements stipulated in EGM 11-003 Technical Specification 3.6.1.10 is applicable during movement of recently irradiated fuel assemblies in the primary containment and/or during an OPDRV. This technical specification requires that primary containment shall be maintained operable during the applicable conditions. If containment operability is not maintained, then immediate actions should be taken to suspend either of the applicable conditions (fuel movement/OPDRVs). Contrary to the above, between 2:48 p.m. CST on March 2, 2013, and 8:30 a.m. CST on March 7, 2013, the licensee did not maintain primary containment in an operable status while conducting an OPDRV. This is a violation of NRC requirements. Because the violation was identified during the discretion period described in EGM 11-003, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation. The inspectors reviewed this licensee event report and the actions taken by the licensee. No problems were noted. This licensee event report is closed. |
| Site: | River Bend  |
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| Report | IR 05000458/2013005 Section 4OA3 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | A Barrett C Alldredge D Allen E Uribe G Larkin J Laughlin J O'Donnell L Carson P Hernandez R Kopriva S Garchow T Skaggs Ryan W Sifre |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - River Bend - IR 05000458/2013005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (River Bend) @ 2013Q4
Self-Identified List (River Bend)
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