05000461/LER-2017-003

LER-2017-003, Implementation of Enforcement Guidance Memorandum (EGM) 11 - 003, Revision 3

Clinton Power Station, Unit 1
Event date:	05-09-2017
Report date:	07-03-2017
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4612017003R00 - NRC Website

LER 17-003-00 for Clinton Power Station, Unit 1 Regarding Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3

ML17188A380
Person / Time
Site:	Clinton
Issue date:	07/03/2017
From:	Stoner T R Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
U-604355 LER 17-003-00
Download: ML17188A380 (5)

comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects Resource@nrc gov, and to the Desk Officer, Office of Information and Regulatory Affairs, used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection

3. LER NUMBER

- 00 2017 003

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 Mode: 5 Event Date: May 9, 2017 Event Time: 2320 Mode Name: Refueling Reactor Power: 00 percent

B. DESCRIPTION OF EVENT

While in Mode 5, Refueling, Operations with the Potential for Draining the Reactor Vessel (OPDRV) activities were performed as part of the Unit 1 C1R17 Refueling Outage without an operable Secondary Containment (SC). The event timeline is presented as follows:

May 9, 2017 at 2320 - Commenced OPDRV activities under the provisions of EGM 11-003, Revision 3.

May 9, 2017 to May 28, 2017 - Performed OPDRV activities in support of Refueling Outage C1R17.

The station used the provisions of EGM 11-003, Revision 3 to perform the following outage activities:

• Shifting Residual Heat Removal (RHR) B in shutdown cooling to the upper pools. [BO]

• Isolating, draining and filling Reactor Recirculation Loops A and B [AD]

• Intermediate Range Monitor dry tube replacement [IG]

• Repairing jet pump flow transmitter

• Reactor Water Cleanup System (RT) pump startup and RT system letdown [CE]

• Starting and aligning RHR A for shutdown cooling to the Feedwater (FW) -'A' line and 'A' upper pool return line [SJ] comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc gov, and to the Desk Officer, Office of Information and Regulatory Affairs, used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

3. LER NUMBER

2017 - 00 003

• Perform maintenance on Control Rod Drive Hydraulic Control Units

• Shift from RHR A to RHR B shutdown cooling

C. CAUSE OF EVENT

Implementation of EGM 11-003, Revision 3 interim actions during the C1R17 Refueling Outage was a preplanned activity. As such, no cause determination was performed for these 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 (TS) 3.6.4.1, Secondary Containment , 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

On May 1, 2017, CPS submitted a license amendment request following the NRC approved guidance in Technical Specification Task Force traveler (TSTF)-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. The proposed change replaces existing TS requirements related to OPDRVs with new requirements on RPV inventory control to protect TS Safety Limit 2.1.1.3.

Infocollects Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection

3. LER NUMBER

2017 - 00 003

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 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 5without an operable SC, as expected and allowed by NRC EGM 11-003, Revision 2.

This was 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.

Revision 3.

Between May 18, 2016, and May 23, 2016, CPS performed OPDRV activities while in Mode 5 without an operable SC, as expected and allowed by NRC EGM 11-003, Revision 3. This was 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 C1R16.

a COMPONENT FAILURE DATA There were no CPS component failures associated with this event.