ML14163A241: Difference between revisions

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{{#Wiki_filter:JUN.l 2 2014 Jon A. Franke Site Vice President U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PPL Susquehanna, LLC 769 Salem Boulevard Berwick, P A 18603 Tel. 570.542.2904 Fax 570.542.1504 jfranke@pplweb.com SUSQUEHANNA STEAM ELECTRIC STATION LICENSEE EVENT REPORT 50-387/2014-006-00 UNIT 1 LICENSE NO. NPF-14 PLA-7185 Docket No. 50-387 Attached is Licensee Event Report (LER) 50-387/2014-006-00.
{{#Wiki_filter:JUN.l 2 20 14 Jon A. Franke Site Vice President U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PPL Susquehanna, LLC 769 Salem Boulevard Berwick , P A 18603 Tel. 570.542.2904 Fax 570.542.1504 jfranke@pplweb.com SUSQUEHANNA STEAM ELECTRIC STATION LICENSEE EVENT REPORT 50-387/2014-006-00 UNIT 1 LICENSE NO. NPF-14 PLA-7185 Docket No. 50-387 Attached is Licensee Event Report (LER) 50-387/2014-006-00.
The condition reported by this LER was an expected condition, which was the result of planned activities in support of a routine refueling outage. As described in the LER, the U.S. Nuclear Regulatory Commission (NRC) provided enfor'?ement  
The condition reported by this LER was an expected condition, which was the result of planned activities in support of a routine refueling outage. As described in the LER, the U.S. Nuclear Regulatory Commission (NRC) provided enfor'?ement guidance, applicable to boiling water reactor licensees, that allows the reported condition.
: guidance, applicable to boiling water reactor licensees, that allows the reported condition.
Although this allowance is provided by the NRC's enforcement guidance, the planned activities are still considered reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications (TS). Specifically, operations with the potential for draining the reactor vessel (OPDRVs) were performed while in Mode 5 without secondary containment being operable, as expected and allowed by the enforcement guidance.
Although this allowance is provided by the NRC's enforcement  
The provisions contained in NRC enforcement guidance memorandum (EGM) 11-003, Revision 2, "Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel," were used during performance of these OPDRVs. There were no actual consequences to the health and safety of the public as a result of these events. This letter contains no new regulatory commitments.  
: guidance, the planned activities are still considered reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications (TS). Specifically, operations with the potential for draining the reactor vessel (OPDRVs) were performed while in Mode 5 without secondary containment being operable, as expected and allowed by the enforcement guidance.
The provisions contained in NRC enforcement guidance memorandum (EGM) 11-003, Revision 2, "Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel,"
were used during performance of these OPDRVs. There were no actual consequences to the health and safety of the public as a result of these events. This letter contains no new regulatory commitments.  


==Attachment:==
==Attachment:==


LER 50-387/2014-006-00 Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES:
LER 50-387/2014-006-00 Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 (01*2014)
01/31/2017 (01*2014)
Estimated burden per response to comply with this mandatory collection request 80 hours.  
Estimated burden per response to comply with this mandatory collection request 80 hours.  
... {¥! 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 (See Page 2 for required number of internet e-mail to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory  
... {¥! 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 FOI A, Privacy and Information Collections ..... / Bran ch (T-5 F5 3), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by (See Page 2 for required number of internet e-mail to lnfocollects.Resource@nrc.gov, and to the Des k Officer , Office of In formatio n and Regulatory Affairs, NEOB-10202, (3150-0 104), Office of Management and Budg et, Washington , DC digits/characters for each block) 20503. If a means 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 resp ond to, the information collection.  
: Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington
, DC digits/characters for each block) 20503. If a means 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.  
: 1. FACILITY NAME DOCKET NUMBER Susquehanna Steam Electric Station Unit 1 05000387 1 OF3 4. TITLE Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 5. EVENT DATE 6. LER NUMBER 7. REPORT DATE 8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO. MONTH DAY YEAR Susquehanna Steam Electric Station Unit1 Ofo FACILITY NAME DOCKET NUMBER 04 16 2014 2014 006 00 ta. 2014 05000 9. OEPRAllNG MODE 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that aoolv! 5 D 20.2201 (b) D 20.2203(a)(3)(i)
: 1. FACILITY NAME DOCKET NUMBER Susquehanna Steam Electric Station Unit 1 05000387 1 OF3 4. TITLE Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 5. EVENT DATE 6. LER NUMBER 7. REPORT DATE 8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO. MONTH DAY YEAR Susquehanna Steam Electric Station Unit1 Ofo FACILITY NAME DOCKET NUMBER 04 16 2014 2014 006 00 ta. 2014 05000 9. OEPRAllNG MODE 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that aoolv! 5 D 20.2201 (b) D 20.2203(a)(3)(i)
D 50.73(a)(2)(i)(C)
D 50.73(a)(2)(i)(C)
Line 50: Line 44:
D 50.73(a)(2)(x)
D 50.73(a)(2)(x)
D 20.2203(a)(2)(iii)
D 20.2203(a)(2)(iii)
D 50.36(c)(2)
D 50.36(c)(2) D 50.73(a)(2)(v)(A)
D 50.73(a)(2)(v)(A)
D 73.71 (a)(4) D 20.2203(a)(2)(iv)
D 73.71 (a)(4) D 20.2203(a)(2)(iv)
D 50.216(a)(3)(ii)
D 50.2 16(a)(3)(ii)
D 50.73(a)(2)(v)(B)
D 50.73(a)(2)(v)(B)
D 73.71(a)(5)
D 73.71(a)(5)
Line 60: Line 53:
D 50.73(a)(2)(v)(C) 0 OTHER D 20.2203(a)(2)(vi) 181 50.73(a)(2)(i)(B)
D 50.73(a)(2)(v)(C) 0 OTHER D 20.2203(a)(2)(vi) 181 50.73(a)(2)(i)(B)
D 50.73(a)(2)(v)(D)
D 50.73(a)(2)(v)(D)
Specify in Abstract below or in NRC Form 366A 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT ' rELEPHONE NUMER (Include Area Code) .* R. W. Mcintosh, Nuclear Regulatory Affairs (570) 542-1695  
Specify in Abstract below or in NRC Form 366A 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT ' r ELEPHO NE NUMER (Include Area Code) .* R. W. Mcintosh , Nuclear Regulatory Affairs (570) 542-1695 13. COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT CAUSE SYSTEM COMPONENT MANU-REPORTABLE
: 13. COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT CAUSE SYSTEM COMPONENT MANU-REPORTABLE
* CAUSE SYSTEM r'OMPONENT MANU-REPORTABLE FACTURER TOEPIX FACTURER TOEPIX .. 14. SUPPLEMENTAL REPORT EXPECTED 15.EXPECTED MONTH DAY YEAR D YES (If yes, complete 15. EXPECTED SUBMISSION DATE) SUBMISSION DATE !ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) The condition reported by this LER was an expected condition, which was the result of planned activities in support of a routine refueling outage. As described in the LER, the U. S. Nuclear Regulatory Commission (NRC) provided enforcement guidance, applicable to boiling water reactor licensees, that allows the reported condition.
* CAUSE SYSTEM r'OMPONENT MANU-REPORTABLE FACTURER TOEPIX FACTURER TOEPIX .. 14. SUPPLEMENTAL REPORT EXPECTED 15.EXPECTED MONTH DAY YEAR D YES (If yes, complete  
Although this allowance is provided by the NRC's enforcement guidance, the planned activities are still considered reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications (TS). Between 4/16/2014 and 5/23/2014, Susquehanna Steam Electric Station (SSES) performed Operations with the Potential for Draining the Reactor Vessel (OPDRV) actiyities on Unit 1 while in Mode 5 without an operable secondary containment, as expected and allowed by the enforcement guidance.
: 15. EXPECTED SUBMISSION DATE) SUBMISSION DATE !ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) The condition reported by this LER was an expected condition, which was the result of planned activities in support of a routine refueling outage. As described in the LER, the U. S. Nuclear Regulatory Commission (NRC) provided enforcement  
Although NRC Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 allows the implementation of interim actions as an alternative to full compliance, this condition is still considered a condition prohibited by TS 3.6.4.1. The OPDRV activities were planned activities that were completed under the guidance of plant procedures and are considered to have low safety significance based on interim actions taken. Since these actions were deliberate, no cause determination was necessary.
: guidance, applicable to boiling water reactor licensees, that allows the reported condition.
Although this allowance is provided by the NRC's enforcement  
: guidance, the planned activities are still considered reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications (TS). Between 4/16/2014 and 5/23/2014, Susquehanna Steam Electric Station (SSES) performed Operations with the Potential for Draining the Reactor Vessel (OPDRV) actiyities on Unit 1 while in Mode 5 without an operable secondary containment, as expected and allowed by the enforcement guidance.
Although NRC Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 allows the implementation of interim actions as an alternative to full compliance, this condition is still considered a condition prohibited by TS 3.6.4.1.
The OPDRV activities were planned activities that were completed under the guidance of plant procedures and are considered to have low safety significance based on interim actions taken. Since these actions were deliberate, no cause determination was necessary.
A license amendment request will be submitted following NRC approval of the Technical Specifications Task Force (TSTF) traveler associated with generic resolution of this issue. NRC FORM 366 (01-2014)
A license amendment request will be submitted following NRC approval of the Technical Specifications Task Force (TSTF) traveler associated with generic resolution of this issue. NRC FORM 366 (01-2014)
NRC FORM 366A (01-2014) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET Susquehanna Steam Electric Station Unit 1 05000387 NARRATIVE EVENT DESCRIPTION APPROVED BY OMB: NO. 3150-0104 EXPIRES:
NRC FORM 366A (0 1-2014) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET Susquehanna Steam Electric Station Unit 1 05000387 NARRATIVE EVENT DESCRIPTION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 Estimated burden per response to comply with this mandatory collection request: 80 hours. Rep o rted lessons learned are incorporated into the licensing process and fed back to industry. Send comments regarding burden estimate to the FOIA , Privacy and l nfonmat i on Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission , Washingto n , DC 20555-0001, or by internet e-mail to l nfocollects.R esou r ce@nrc.gov, and to the Desk Officer , Off i ce of ln fonmatio n and Regulatory Affairs, NEOB-102 02, (3150*0104), Office of Management and Budge t, Washington , DC 20503. If a means used to impose an infonmation collection does not display a currently vali d OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to , the infonma tion collection.  
01/31/2017 Estimated burden per response to comply with this mandatory collection request:
80 hours. Reported lessons learned are incorporated into the licensing process and fed back to industry. Send comments regarding burden estimate to the FOIA, Privacy and lnfonmation Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission
, Washingto n, DC 20555-0001, or by internet e-mail to lnfocollects
.Resource@nrc.gov, and to the Desk Officer, Office of lnfonmation and Regulatory  
: Affairs, NEOB-10202, (3150*0104),
Office of Management and Budget, Washington
, DC 20503. If a means used to impose an infonmation 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 infonmation collection.  
: 6. LER NUMBER 3. PAGE YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 20F3 2014 -006 -00 While in Mode 5, Refueling, OPDRVs were performed as part of the Unit 1 18th Refueling and Inspection Outage (U1 18 RIO) without an operable secondary containment.
: 6. LER NUMBER 3. PAGE YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 20F3 2014 -006 -00 While in Mode 5, Refueling, OPDRVs were performed as part of the Unit 1 18th Refueling and Inspection Outage (U1 18 RIO) without an operable secondary containment.
This event timeline is as follows:
This event timeline is as follows: 04/16/2014-Commenced OPDRV activity under the provisions of EGM 11-003, Revision 2. 4/16/2014 to 5/23/2014-Performed OPDRV activities in support of U1 18 RIO. 5/23/2014-Cleared Unit 1 LCO 3.6.4.1 The station used the provisions of EGM 11-003, Revision 2 to perform the following outage activities:
04/16/2014-Commenced OPDRV activity under the provisions of EGM 11-003, Revision  
: 2. 4/16/2014 to 5/23/2014-Performed OPDRV activities in support of U1 18 RIO. 5/23/2014-Cleared Unit 1 LCO 3.6.4.1 The station used the provisions of EGM 11-003, Revision 2 to perform the following outage activities:
* Recirculation system maintenance
* Recirculation system maintenance
* Reactor Water Clean Up (RWCU) system maintenance
* Reactor Water Clean Up (RWCU) system maintenance
Line 89: Line 68:
* Standby Liquid Control (SBLC) testing
* Standby Liquid Control (SBLC) testing
* Control Rod Drive (CRD) mechanism replacements
* Control Rod Drive (CRD) mechanism replacements
* Full Scram testing CAUSE OF THE EVENT Implementation of EGM 11-003, Revision 2 interim actions during the U1 18 RIO was a planned activity.
* Full Scram testing CAUSE OF THE EVENT Implementation of EGM 11-003 , Revision 2 interim actions during the U1 18 RIO was a planned activity.
As such, no cause determination was performed on the events. ANALYSIS I SAFETY SIGNIFICANCE This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by SSES Unit 1 Technical Specification 3.6.4.1, which prohibits activities identified as OPDRVs in Mode 5 while secondary containment is inoperable.
As such, no cause determination was performed on the events. ANALYSIS I SAFETY SIGNIFICANCE This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by SSES Unit 1 Technical Specification 3.6.4.1, which prohibits 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 the NRC in EGM 11-003, Revision  
The OPDRV activities described in this report were accomplished using the interim actions provided by the NRC in EGM 11-003, Revision 2. In accordance with station procedures controlling OPDRVs, (e.g., NDAP-QA-0326, and OP-AD-325), SSES 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.
: 2. In accordance with station procedures controlling OPDRVs, (e.g., NDAP-QA-0326, and OP-AD-325),
SSES 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.
SSES also met the requirements which specify the minimum makeup flow NRC FORM 366A (01-2014)
SSES also met the requirements which specify the minimum makeup flow NRC FORM 366A (01-2014)
NRC FORM 366A (01-2014) LICENSEE EVENT REPORT (LER) CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET U.S. NUCLEAR REGULATORY COMMISSION  
NRC FORM 366A (01-2014) LICENSEE EVENT REPORT (LER) CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET U.S. NUCLEAR REGULATORY COMMISSION  
: 6. LER NUMBER 3. PAGE Susquehanna Steam Electric Station Unit 1 05000387 YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 30F3 2014 -006 -00 NARRATIVE rate and water inventory.  
: 6. LER NUMBER 3. PAGE Susquehanna Steam Electric Station Unit 1 05000387 YEAR I SEQUENTIAL I REVISION NUMBER NU M BER 30F3 2014 -006 -00 NARRATIVE rate and water inventory.
: Further, an adequate defense in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable.
Further, an adequate defense in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable.
Since these compensatory measures were implemented, an adequate level of safety was provided during the performance of the OPDRV activities described in this report. CORRECTIVE ACTIONS SSES will submit a license amendment following NRC approval of the Technical Specifications Task Force traveler associated with generic resolution of this issue within the time constraints given in EGM 11-003, Revision  
Since these compensatory measures were implemented, an adequate level of safety was provided during the performance of the OPDRV activities described in this report. CORRECTIVE ACTIONS SSES will submit a license amendment following NRC approval of the Technical Specifications Task Force traveler associated with generic resolution of this issue within the time constraints given in EGM 11-003, Revision 2. No regulatory commitments are associated with this report. ADDITIONAL INFORMATION Component Information:
: 2. No regulatory commitments are associated with this report. ADDITIONAL INFORMATION Component Information:
None Previous Similar Events: None PREVIOUS SIMILAR EVENTS LER 50-388/2013-001-00 (PLA 7018): Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 1}}
None Previous Similar Events: None PREVIOUS SIMILAR EVENTS LER 50-388/2013-001-00 (PLA 7018): Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 1}}

Revision as of 15:48, 9 July 2018

LER 14-006-00 for Susquehanna Steam Electric Station Unit 1, Regarding Implementation of Enforcement Guidance Memorandum (Egm)11-003, Revision 2
ML14163A241
Person / Time
Site:  Talen Energy icon.png
Issue date: 06/12/2014
From: Franke J A
Susquehanna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LER 14-006-00
Download: ML14163A241 (4)
v • d • e


Text

JUN.l 2 20 14 Jon A. Franke Site Vice President U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PPL Susquehanna, LLC 769 Salem Boulevard Berwick , P A 18603 Tel. 570.542.2904 Fax 570.542.1504 jfranke@pplweb.com SUSQUEHANNA STEAM ELECTRIC STATION LICENSEE EVENT REPORT 50-387/2014-006-00 UNIT 1 LICENSE NO. NPF-14 PLA-7185 Docket No. 50-387 Attached is Licensee Event Report (LER) 50-387/2014-006-00.

The condition reported by this LER was an expected condition, which was the result of planned activities in support of a routine refueling outage. As described in the LER, the U.S. Nuclear Regulatory Commission (NRC) provided enfor'?ement guidance, applicable to boiling water reactor licensees, that allows the reported condition.

Although this allowance is provided by the NRC's enforcement guidance, the planned activities are still considered reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications (TS). Specifically, operations with the potential for draining the reactor vessel (OPDRVs) were performed while in Mode 5 without secondary containment being operable, as expected and allowed by the enforcement guidance.

The provisions contained in NRC enforcement guidance memorandum (EGM)11-003, Revision 2, "Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel," were used during performance of these OPDRVs. There were no actual consequences to the health and safety of the public as a result of these events. This letter contains no new regulatory commitments.

Attachment:

LER 50-387/2014-006-00 Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 (01*2014)

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 />.

... {¥! 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 FOI A, Privacy and Information Collections ..... / Bran ch (T-5 F5 3), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by (See Page 2 for required number of internet e-mail to lnfocollects.Resource@nrc.gov, and to the Des k Officer , Office of In formatio n and Regulatory Affairs, NEOB-10202, (3150-0 104), Office of Management and Budg et, Washington , DC digits/characters for each block) 20503. If a means 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 resp ond to, the information collection.

1. FACILITY NAME DOCKET NUMBER Susquehanna Steam Electric Station Unit 1 05000387 1 OF3 4. TITLE Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 5. EVENT DATE 6. LER NUMBER 7. REPORT DATE 8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO. MONTH DAY YEAR Susquehanna Steam Electric Station Unit1 Ofo FACILITY NAME DOCKET NUMBER 04 16 2014 2014 006 00 ta. 2014 05000 9. OEPRAllNG MODE 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that aoolv! 5 D 20.2201 (b) D 20.2203(a)(3)(i)

D 50.73(a)(2)(i)(C)

D 50.73(a)(2)(vii)

D 20.2201 (d) D 20.2203(a)(3)(ii)

D 50.73(a)(2)(ii)(A)

D 50.73(a)(2)(viii)(A)

10. POWER LEVEL D 20.2203(a)(1)

D 20.2203(a)(4)

D 50.73(a)(2)(ii)(B)

D 50.73(a)(2)(viii)(B)

D 20.2203(a)(2)(i)

D 50.36(c)(1

)(i)(A) D 50.73(a)(2)(iii)

D 50.73(a)(2)(ix)(A) 0% D 20.2203(a)(2)(ii)

D 50.36(c)(1)(ii)(A)

D 50.73(a)(2)(iv)(A)

D 50.73(a)(2)(x)

D 20.2203(a)(2)(iii)

D 50.36(c)(2) D 50.73(a)(2)(v)(A)

D 73.71 (a)(4) D 20.2203(a)(2)(iv)

D 50.2 16(a)(3)(ii)

D 50.73(a)(2)(v)(B)

D 73.71(a)(5)

D 20.2203(a)(2)(v)

D 50.73(a)(2)(i)(A)

D 50.73(a)(2)(v)(C) 0 OTHER D 20.2203(a)(2)(vi) 181 50.73(a)(2)(i)(B)

D 50.73(a)(2)(v)(D)

Specify in Abstract below or in NRC Form 366A 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT ' r ELEPHO NE NUMER (Include Area Code) .* R. W. Mcintosh , Nuclear Regulatory Affairs (570) 542-1695 13. COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT CAUSE SYSTEM COMPONENT MANU-REPORTABLE

  • CAUSE SYSTEM r'OMPONENT MANU-REPORTABLE FACTURER TOEPIX FACTURER TOEPIX .. 14. SUPPLEMENTAL REPORT EXPECTED 15.EXPECTED MONTH DAY YEAR D YES (If yes, complete 15. EXPECTED SUBMISSION DATE) SUBMISSION DATE !ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) The condition reported by this LER was an expected condition, which was the result of planned activities in support of a routine refueling outage. As described in the LER, the U. S. Nuclear Regulatory Commission (NRC) provided enforcement guidance, applicable to boiling water reactor licensees, that allows the reported condition.

Although this allowance is provided by the NRC's enforcement guidance, the planned activities are still considered reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications (TS). Between 4/16/2014 and 5/23/2014, Susquehanna Steam Electric Station (SSES) performed Operations with the Potential for Draining the Reactor Vessel (OPDRV) actiyities on Unit 1 while in Mode 5 without an operable secondary containment, as expected and allowed by the enforcement guidance.

Although NRC Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 allows the implementation of interim actions as an alternative to full compliance, this condition is still considered a condition prohibited by TS 3.6.4.1. The OPDRV activities were planned activities that were completed under the guidance of plant procedures and are considered to have low safety significance based on interim actions taken. Since these actions were deliberate, no cause determination was necessary.

A license amendment request will be submitted following NRC approval of the Technical Specifications Task Force (TSTF) traveler associated with generic resolution of this issue. NRC FORM 366 (01-2014)

NRC FORM 366A (0 1-2014) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET Susquehanna Steam Electric Station Unit 1 05000387 NARRATIVE EVENT DESCRIPTION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 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 />. Rep o rted lessons learned are incorporated into the licensing process and fed back to industry. Send comments regarding burden estimate to the FOIA , Privacy and l nfonmat i on Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission , Washingto n , DC 20555-0001, or by internet e-mail to l nfocollects.R esou r ce@nrc.gov, and to the Desk Officer , Off i ce of ln fonmatio n and Regulatory Affairs, NEOB-102 02, (3150*0104), Office of Management and Budge t, Washington , DC 20503. If a means used to impose an infonmation collection does not display a currently vali d OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to , the infonma tion collection.

6. LER NUMBER 3. PAGE YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 20F3 2014 -006 -00 While in Mode 5, Refueling, OPDRVs were performed as part of the Unit 1 18th Refueling and Inspection Outage (U1 18 RIO) without an operable secondary containment.

This event timeline is as follows: 04/16/2014-Commenced OPDRV activity under the provisions of EGM 11-003, Revision 2. 4/16/2014 to 5/23/2014-Performed OPDRV activities in support of U1 18 RIO. 5/23/2014-Cleared Unit 1 LCO 3.6.4.1 The station used the provisions of EGM 11-003, Revision 2 to perform the following outage activities:

  • Recirculation system maintenance
  • Reactor Water Clean Up (RWCU) system maintenance
  • Hydraulic Control Unit (HCU) maintenance
  • Local Power Range Monitor (LPRM) replacement
  • Full Scram testing CAUSE OF THE EVENT Implementation of EGM 11-003 , Revision 2 interim actions during the U1 18 RIO was a planned activity.

As such, no cause determination was performed on the events. ANALYSIS I SAFETY SIGNIFICANCE This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by SSES Unit 1 Technical Specification 3.6.4.1, which prohibits 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 the NRC in EGM 11-003, Revision 2. In accordance with station procedures controlling OPDRVs, (e.g., NDAP-QA-0326, and OP-AD-325), SSES 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.

SSES also met the requirements which specify the minimum makeup flow NRC FORM 366A (01-2014)

NRC FORM 366A (01-2014) LICENSEE EVENT REPORT (LER) CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET U.S. NUCLEAR REGULATORY COMMISSION

6. LER NUMBER 3. PAGE Susquehanna Steam Electric Station Unit 1 05000387 YEAR I SEQUENTIAL I REVISION NUMBER NU M BER 30F3 2014 -006 -00 NARRATIVE rate and water inventory.

Further, an adequate defense in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable.

Since these compensatory measures were implemented, an adequate level of safety was provided during the performance of the OPDRV activities described in this report. CORRECTIVE ACTIONS SSES will submit a license amendment following NRC approval of the Technical Specifications Task Force traveler associated with generic resolution of this issue within the time constraints given in EGM 11-003, Revision 2. No regulatory commitments are associated with this report. ADDITIONAL INFORMATION Component Information:

None Previous Similar Events: None PREVIOUS SIMILAR EVENTS LER 50-388/2013-001-00 (PLA 7018): Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 1

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