05000461/LER-2016-008

LER-2016-008, Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

Clinton Power Station, Unit 1
Event date:	05-18-2016
Report date:	07-15-2016
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4612016008R00 - NRC Website

LER 16-008-00 for Clinton Power Station, Unit 1, Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

ML16201A233
Person / Time
Site:	Clinton
Issue date:	07/15/2016
From:	Stoner T R Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
U-604298 LER 16-008-00
Download: ML16201A233 (5)

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PLANT AND SYSTEM IDENTIFICATION

General Electric—Boiling Water Reactor, 3473 Megawatts Thermal Rated Core Power Energy Industry Identification System (EIIS) codes are identified in the text as [XX]

EVENT IDENTIFICATION

Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 A. Plant Operating Conditions before the Event Unit: 1 Event Date: May 18, 2016 Mode: 5 Mode Name: Refueling

B. DESCRIPTION OF EVENT

Event Time: 0100 Reactor Power: 00 percent While in Mode 5, Refueling, Operations with the Potential for Draining the Reactor Vessel (OPDRV) were performed as part of the Unit 1 C1R16 Refueling Outage without an operable Secondary Containment (SC). The event timeline is presented as follows:

May 18, 2016 at 0100 - Commenced OPDRV activities under the provisions of EGM 11-003, Rev 3 for shifting residual heat removal (RHR) B to the upper pools.

May 18, 2016 at 0106 - Completed OPDRV activities.

May 23, 2016 at 2010 - Commenced OPDRV activities under the provisions of EGM 11-003, Rev. 3 for shifting RHR B from the upper pools to the feedwater lines.

May 23, 2016 at 2015 - Completed OPDRV activities.

OPDRV activities were completed successfully in support of the completion of Refueling Outage C1R16.

C. CAUSE OF EVENT

Implementation of EGM 11-003, Revision 3 interim actions during C1R16 Refueling Outage was a preplanned activity. As such, no cause determination was performed for the events.

D. SAFETY ANALYSIS

There were no safety consequences associated with the condition described in this report.

This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as an operation prohibited by CPS Technical Specification 3.6.4.1, Secondary Containment (SC), which prohibits performing activities identified as OPDRVs in Mode 5 with SC inoperable.

The OPDRV activities described in this report were accomplished using the interim actions provided by the NRC in EGM 11-003, Revision 3. CPS 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. CPS 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 SC inoperable. Since these measures were implemented, an adequate level of safety was provided during the performance of the OPDRV activities described in this report.

E. CORRECTIVE ACTIONS

CPS will submit a license amendment request following the NRC approval of a Technical Specification Task Force (TSTF) traveler associated with generic resolution of this issue within the time constraints specified in EGM 11-003, Revision 3.

F. PREVIOUS SIMILAR OCCURENCES

Revision 1 Between October 13, 2013 and October 27, 2013, CPS performed OPDRV activities while in Mode 5 without an operable SC, as expected and allowed by NRC EGM 11-003, Revision 1. This was a reportable as a condition prohibited by TS as SC was inoperable during OPDRV activities. These activities were concluded successfully during Refueling Outage C1R14 with no resulting safety consequences.

Revision 2.

Between April 29, 2015, and May 12, 2015, CPS performed OPDRV activities while in Mode 5 without an operable SC, as expected and allowed by NRC EGM 11-003, Revision 2. This a condition prohibited by TS 3.6.4.1 and is reportable under 10 CFR 50.73 (a)(2)(i)(B). These activities were completed successfully during Refueling Outage C1R15.

G. COMPONENT FAILURE DATA

There was no component failure associated with this event.