05000458/LER-2013-001, Regarding Operations Prohibited by Technical Specifications for Operations with a Potential to Drain the Reactor Vessel
| ML13116A009 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/18/2013 |
| From: | Olson E Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LER 13-001-00 | |
| Download: ML13116A009 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 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)(iii) 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)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 4582013001R00 - NRC Website | |
text
E EnteWgy Entergy Operations, Inc.
River Bend Station 5485 U. S. Highway 61 N St. Francisville, LA 70775 Tel 225 381 4374 Fax 225 381 4872 eolson@entergy.com Eric W. Olson Site Vice President RBG-47357 April 18, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Licensee Event Report 50-458 / 2013-001-00 River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47 RBF1-13-0045
Dear Sir or Madam:
In accordance with 10 CFR 50.73, enclosed is the subject Licensee Event Report.
This document contains no commitments. If you have any questions, please contact Mr. Joseph Clark at 225-381-4177.
Sincerely, EWO/dhw Enclosure
Licensee Event Report 50-458 / 2013-001-00 April 18, 2013 RBG-47357 RBF1-13-0045 Page 2 of 2 cc:
U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Blvd.
Arlington, TX 76011-4511 NRC Sr. Resident Inspector P. O. Box 1050 St. Francisville, LA 70775 INPO Records Center E-Mail (MS Word format)
Central Records Clerk Public Utility Commission of Texas 1701 N. Congress Ave.
Austin, TX 78711-3326 Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section JiYoung Wiley P.O. Box 4312 Baton Rouge, LA 70821-4312
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010) digits/characters for each block) the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE River Bend Station - Unit 1 05000-458 1 OF 3
- 4. TITLE Operations Prohibited by Technical Specifications for Operations With a Potential to Drain the Reactor Vessel
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED F~I AU I ACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FA 05000 NUMBER NO.
n/a 05000 FACILITY NAME DOCKET NUMBER 03 02 2013 2013-001-00 04 18 2013 n/a 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
El 20.2201(b)
El 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
El 50.73(a)(2)(vii) 5 El 20.2201(d)
[E 20.2203(a)(3)(ii)
E 50.73(a)(2)(ii)(A)
E 50.73(a)(2)(viii)(A)
[] 20.2203(a)(1)
E 20.2203(a)(4)
E 50.73(a)(2)(ii)(B)
E 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
[
50.36(c)(1)(i)(A)
El 50.73(a)(2)(iii)
[: 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20,2203(a)(2)(ii)
LI 50.36(c)(1)(ii)(A)
[L 50.73(a)(2)(iv)(A)
El 50.73(a)(2)(x)
[] 20,2203(a)(2)(iii)
LI 50.36(c)(2)
LI 50.73(a)(2)(v)(A)
E] 73.71(a)(4) 0 EL 20.2203(a)(2)(iv)
LI 50.46(a)(3)(ii)
LI 50.73(a)(2)(v)(B)
E] 73.71(a)(5)
[I 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A)
LI 50.73(a)(2)(v)(C)
LI OTHER El 20.2203(a)(2)(vi) 2 50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
Specify in Abstract below or in NRC Form 366A
- 12. LICENSEE CONTACT FOR THIS LER FACILITY NAME TELEPHONE NUMBER (Include Area Code)
Joseph A. Clark, Manager - Licensing 225-381-4177CAUSE SYSTEM COMPONENT MANU-
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE FACTURER TO EPIX FACTURER TO EPIX n/a
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR SUBMISSION
[: YES (If yes, complete 15. EXPECTED SUBMISSION DATE) E NO DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On March 2, 2013, at approximately 1448 CST, with the plant in a refueling outage, maintenance on the reactor recirculation system was commenced without taking the required actions to comply with the applicable Technical Specifications. This maintenance constituted operations with a potential to drain the reactor vessel, and the required action for such an activity is restoration of the integrity of primary containment. This action was not taken, and the provisions of NRC Enforcement Guidance Memorandum 11-003 (Rev. 1) were instead invoked. The maintenance was completed and compliance with Technical Specifications was restored at 0830 CST on March 7. This event is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by Technical Specifications, as additionally specified by the Enforcement Guidance Memorandum.
NRC FORM 366 (10-2010)
I.LICENSEE EVENT REPORT (LER)
U.S. NUCLEAR REGULATORY COMMISSION (10-2010)
CONTINUATION SHEET
- 1. FACILITY NAME
- 2. DOCKET
- 6. LER NUMBER
- 3. PAGE YEAR I SEQUENTIALI REV.
River Bend Station - Unit 1 05000 -458 NUMBER NO.OF 2
3 2013 -- 001 -- 00 REPORTED CONDITION On March 2, 2013, at approximately 1448 CST, with the plant in a refueling outage, maintenance on the reactor recirculation system was commenced without taking the required actions to comply with the applicable Technical Specifications (TS). This maintenance constituted operations with a potential to drain the reactor vessel (OPDRV), and the required action for such an activity is restoration of the integrity of primary containment. This action was not taken, and the provisions of NRC Enforcement Guidance Memorandum 11-003 (Rev.
- 1) (EGM) were instead invoked. The maintenance was completed and TS compliance was restored at 0830 CST on March 7. This event is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by Technical Specifications, as additionally specified by the EGM.
EVENT DESCRIPTION
An OPDRV is an activity that could result in the draining or siphoning of the reactor pressure vessel (RPV) water level below the top of fuel without crediting the use of mitigating measures to terminate the draining prior to uncovering fuel. Based on Technical Specification applicability, an OPDRV is a change to the applicability as related to the Limiting Condition for Operation (LCO), and therefore treated much like a mode change.
The NRC issued Revision 1 of the EGM on December 20, 2012, to provide guidance on how to disposition boiling water reactor licensee noncompliance with TS containment requirements during OPDRV operations. Certain safety systems must be operable during OPDRV activities to mitigate drain-down events and to provide protection against untreated fission product release in the event that the RPV water level drops below irradiated fuel. The TS does not define the term OPDRV or identify specific plant actions that constitute OPDRV activities.
Because a definition is not provided, the NRC staff expects licensees to use the plain language meaning of the OPDRV wording for determining applicability. This means that any activity that could potentially result in draining or siphoning the RPV water level below the top of the fuel without taking credit for mitigating measures would be an OPDRV activity.
In order to utilize the EGM and be eligible for enforcement discretion, the licensee is required to:
(1) adhere to the NRC plain language meaning of OPDRV activities, (2) meet the requirements which specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain-down times, I
ILICENSEE EVENT REPORT (LER)
U.s. NUCLEAR REGULATORY COMMISSION (10-2010)
CONTINUATION SHEET
- 1. FACILITY NAME
- 2. DOCKET
- 6. LER NUMBER
- 3. PAGE YEAR SEQUENTIAL I REV.
NUMBERI NO.
River Bend Station - Unit 1 05000 -458 3 OF 3 2013 -- 001 -- 00 (3) ensure that adequate defense-in-depth is maintained to minimize the potential for the release of fission products by monitoring RPV level to identify the onset of a loss of inventory event by maintaining the capability to isolate the potential leakage paths, by prohibiting Mode 4 (cold shutdown) OPDRV activities, by prohibiting movement of irradiated fuel, and, (4) follow all other Mode 5 TS requirements for OPDRV activities.
The station used the provisions of the EGM in order to replace the pump seals and the flow control valve packing in the "A" loop of the reactor recirculation system. When the loop was isolated to set the required conditions for the maintenance, the technicians determined that the baseline leakage through the loop isolation valves was approximately seven gallons per minute, which was well within the prerequisites of the EGM.
The OPDRV was completed at 0830 CST on March 7, with no complications regarding pool water level control.
PREVIOUS OCCURRENCE EVALUATION No similar events have been reported by River Bend Station in the last five years.
SAFETY SIGNIFICANCE
The prerequisites of the EGM and applicable station procedures were met prior to the start of the maintenance. The high pressure core spray, low pressure core spray, and "A" residual heat removal systems were designated for emergency water level control. The reactor cavity water level was greater than 23 feet above the RPV flange, and all pool gates were open.
Contingency plans for potential leakage paths were in place, and two independent channels of pool water level were in service. No transients in pool water level occurred during the maintenance. Thus, this event was of minimal significance with respect to the health and safety of the public.