NL-13-0742, LER 13-002-00 for Edwin I. Hatch Regarding Performance of Operations with Potential for Draining the Reactor Vessel (OPDRV) Without Operable Secondary Containment: Difference between revisions

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{{Adams
#REDIRECT [[05000366/LER-2013-002]]
| number = ML13109A421
| issue date = 04/19/2013
| title = LER 13-002-00 for Edwin I. Hatch Regarding Performance of Operations with Potential for Draining the Reactor Vessel (OPDRV) Without Operable Secondary Containment
| author name = Madison D R
| author affiliation = Southern Nuclear Operating Co, Inc, Southern Co
| addressee name =
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000366
| license number =
| contact person =
| case reference number = NL-13-0742
| document report number = LER 13-002-00
| document type = Letter, Licensee Event Report (LER)
| page count = 9
}}
 
=Text=
{{#Wiki_filter:Dennis R. Madison Southern Nuclear Vice President
* Hatch Operating Company , Inc. Plant Edv i n i. Harctl 1 1028 Hatch Park','Vay North Baxley. Georgia 3 1 513 T ei 91 2.53 7 5859 Fax 912.3662077 SOUTHERN-.
COMPANY April 19, 2013 Docket Nos.: 50-366 NL-13-0742 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Licensee Event Report Performance of Operations With Potential For Draining the Reactor (OPDRV) Under Specific NRC Interim Ladies and Gentlemen:
In accordance with the requirements of 1 OCFR50.73(a)(2)(i)(B), Southern Nuclear Operating Company hereby submits the enclosed Licensee Event Report (LER) concerning performance of operations with the potential for draining the reactor vessel (OPDRVs)while in Mode 5 without secondary containment being operable, which is a condition prohibited by the Technical SpeCifications.
The provisions contained in NRC enforcement guidance memorandum (EGM) 11-003, Revision 1, "Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements During Operations with a Potential for Draining the Reactor Vessel", were satisfied during performance of the OPDRVs reported in the enclosed LER. This letter contains no NRC commitments.
If you have any questions, please contact Doug McKinney at (205) 992-5982.
Respectfully submitted, D. R. Madison Vice President
-Hatch DRM/sb/sb
 
==Enclosures:==
 
LER 2-2013-02 cc: Kuczynski, Chairman, President
&CEO Mr. D. Executive Vice President
& Nuclear Officer Mr. L. Ivey, Vice President Regulatory Affairs Mr. J. Adams, Vice President -
Fleet Operations M. A. Dowd -Operating Experience Mr. V. M. McCree, Regional Administrator Mr. Martin, NRR Senior Project Manager -Hatch Mr. Morris, Senior Inspector
-Hatch 
 
Licensee Event Report Performance of Operations With Potential For Draining the Reactor (OPDRV) Under Specific NRC Interim NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 1(}2010) l="tilm"I,,";
burden per response to comply with this mandatory collection request: hours. Reported lessons learned are incorporated into the licensing process and fed back to industry.
Send comments regarding burden estimate to the Records and FOIAlPrivacy Service Branch (T-5 F53). U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet LICENSEE EVENT REPORT (LER) e-mail to inlocollects,resources@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs. NEOB-l0202.
(3150-0104).
Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currently valid OMS control number, the NRC may not conduct or sponsor, and a person is nol required to rescond to. the information collection.
: 2. DOCKET NUMBER 3, PAGE Unit 2 05000366 1 OF 3 of Operations With Potential For Draining the Reactor Vessel (OPDRV) Without Operable eccmd;arv Containment
: 5. EVENT DATE S.LER NUMBER 7. REPORT DATE 8. OTHER FACILITIES INVOLVED FACILITY NAME DOCKET NUMBER MONTH, DAY YEAR YEAR SEQUENTIAL NUMBER REV NO. MONTH DAY YEAR 05000 FACILITY NAME ,DOCKET NUMBER 19 2013 2013 -002 -00 04 19 2013 05000 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply) o 20.2201(b) 0 20,2203(a)(3)(i) 0 50.73(a)(2)(i)(C) 0 50.73(a)(2)(vii)
Mode 5 20.2201 (d) 20.2203(a)(3}(ii}
50.73(a}(2}(ii)(A) 50.73(a)(2}(viii}(A}
20.2203(a)(1) 0 20,2203(a}(4) 50.73(a)(2)(ii){B) 0 50.73(a)(2)(viii)(B) 20,2203(a)(2)(i) 50.36(c)(1
)(i)(A) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A)
...1-0.-P-O--W--E--R-l-E-V 20.2203(a)(2)(ii) 50.36(c)(1
)(ii)(A) 50.73(a)(2)(iv)(A)
.... 50.73(a}(2)(x) o 20.2203(a)(2)(iii) 0 50,36(c)(2) 0 5O.73(a}(2)(v)(A) 0 73,71(a}(4) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a}(2)(v)(B) 73.71 (a){5) 000 20.2203(a){2)(v) 0 50.73(a)(2)(i)(A) 50.73(a){2)(v)(C) 0 OTHER o 20,2203(a)(2)(vi) 5O.73(a)(2)(i)(B) 50.73(a)(2)(v)(D)
Specify in Abstract below or in NRC Form 366A 12. LICENSEE CONTACT FOR THIS LER win 1. Hatch I Steven -Principal
: 13. COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT REPORTABLE
; MANU-REPORTABLE CAUSE SYSTEM COMPONENT FACTUREA CAUSE SYSTEM COMPONENT FACTUREA TO EPIX TO EPIX 14. SUPPLEMENTAL REPORT EXPECTED 15. EXPECTED SUBMISSION o YES (If yes, complete 15. EXPECTED SUBMISSION NO DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 typewritten lines) On February 19,2013, February 20, 2013 and February 2013, OPDRV activities were performed while HNP-2 in Mode 5 without an operable secondary
.... VLH...
activities are prohibited by Technical (TS) 1, however recent NRC provided in Regulatory (RIS) 2012-11 and in Enforcement Guidance Memorandum (EGM) 11-003, Revision 1 allowed the implementation of actions as an alternative to full compliance.
were compiled in an procedure the OPDRVactivities at during the 2R22 Refueling in February.
The OPDRV were planned that were completed under the of plant procedures and confinned 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 .r"",,"',pr associated with eneric resolution of this issue. NRC FORM 366 (9-2007) PRINTED ON RECYCLED PAPER NRC FORM 366A u.s. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) (10*2010)
CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET 6. LER NUMBER 3. PAGE I SEQUENTIAL I REVISION YEAR NUMBER NUMBER Edwin I. Hatch Nuclear Plant Unit I 05000-366 2 OF 2013 -002 -NARRATIVE PLANT AND SYSTEM IDENTIFICATION General Electric -Boiling Water Reactor Energy Industry Identification System codes appear in the text as (EllS Code XX). DESCRIPTION OF EVENT The OPDRVs in Table 1 were performed while in Mode 5 without an operable secondary containment, contrary to Technical Specifications (TS) 3.6.4.1. The NRC recognized that such activities may need to be performed during refueling outages while activities were underway with the BWROG to formulate acceptable generic changes to BWR Technical Specifications.
NRC Regulatory Issue Summary (RIS) 2012-11 communicated this guidance to the industry along with Enforcement Guidance Memorandum (EGM) 11-003, Revision 1 that allowed implementation of specific interim actions as an alternative to full compliance with the Technical Specifications while the improvements in the Technical Specifications are under development with the BWROG. Required interim actions specified in the EGM were incorporated into plant procedure GO-OPS-025-0:
OPERATIONS WITH THE POTENTIAL TO DRAIN THE REACTOR VESSEL (OPDRV). This procedure was then utilized on three occasions during the 2013 HNP-2 Refueling Outage. Table 1: HNP-2 OPDRVs Performed February OPDRV Activity Start LPRM Removal and Replacement 0211912013,0908 EST 0211912013, 1848 CRD Drive Removal and 0212012013, 1130 EST 0212112013, 1115 HCU Venting and Recoupling 02/25/2013, 1505 EST 0212612013, 1048 CAUSE OF Implementation of RIS 2012-11 and EGM 11-003, Revision 1 interim actions during the Refueling Outage was a planned activity.
As such, no cause determination was performed for the REPORTABILITY ANALYSIS And SAFETY ASSESSMENT This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operations prohibited by the HNP-2 Technical Specification 3.6.4.1.C.3, which prohibits performing activities identified as OPDRVs in Mode 5 while secondary containment is inoperable.
OPDRVs discussed in this report were performed during the 2R22 Refueling Outage and were accomplished using interim actions provided by the NRC in EGM 11-003, Revision 1. HNP-2 adhered to the NRC plain language meaning of OPDRV activities that could potentially result in draining or siphoning the 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.
HNP 2 also met the requirements which specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain down times. Further, an adequate defense in depth was maintained to minimize the potential for the release of fission products with secondary containment not operable by (a) monitoring RPV level to identify the onset of a loss of inventory event, (b) maintaining the capability to isolate the potential leakage paths, (c) prohibiting Mode 4 (cold shutdown)
OPDRV activities, and (d) prohibiting movement of irradiated fuel with the spent fuel storage pool gates removed in Mode 5. All other Mode 5 Technical NRC FORM 366A (10-201 O)
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION EVENT REPORT (LER) (1 ()'201 0) CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET 6. LER NUMBER 3. PAGE Edwin I. 05000-366 YEAR SEQUENTIAL NUMBER REVISION NUMBER 3 OF 3 2013 002 00 Specifications requirements for activities were foHowed. these compensatory measures were properly implemented, an adequate level of safety was provided during the of the OPDRV activities described in this report. Based on this information the performance of these OPDRV activities were to have a low safety significance.
HNP 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 1. Other Affected:
None Failed Components Information:
None Commitment Information:
This repOlt not create any new permanent licensing commitments.
Previous Similar Events: A review of and Corrective Action Program documents did not reveal any events similar to those discussed in this report within the last years. NRC FORM 366A (1 ()'201 0)
Southern Nuclear 0 Nuclear Ucenslng Form Licensing Action and Concurrence NL-()()6.F03 Version 1.0 Pa 1 of 6 NL Letter Number: NL-13-0742 Due Date (if appli
 
==Subject:==
Performance of Operations With Potential for Draining Specific NRC Interim Actions RLE I Extension:
Sharon Beverly 692-2804 SECTION I -CORRESPONDENCE SCREENING (to be completed by RLE) YES NO 1.1. Does this letter affect the FSAR or any other Ucense Basis Documents?
If YES. complete 1. 1.a. If unsure, obtain peer review from 10 CFR 50.59 qualified individual.
1 .... .-. '..... :....*dOcIINnrl YE$.f'1' NCJ* r 1.2. Does this letter require posting per 10 CFR 19? If YES. ensure posting after submittal.
r P' 1.3. Does this letter contain Safeguards Information?
If YES, do NOT scan to SNC Intranet.
Enter Special Handling Instructions below and review with the AA. r 1.4. Does this letter contain information to be withheld from public disclosure (e.g., Proprietary or Non-Safeguards Security-Related Information)?
If YES. do NOT scan to SNC Intranet.
If Proprietary, include appropriate affidavit.
Enter Special Handling r Instructions below and review with the AA. 1.5. Does this letter contain sensitive, limited access or distribution items? Special Handling Instructions below and rewew with the AA. If YES, enter r  Handling Instructions Click here to enter text. 1.6. Oath or Affirmation Required?
If YES, verify proper letter template is used. r 1.7. Verification Required?
If YES. use the guidance of NL*OO6-GL04.
r 1.8. Office of External Affairs and General Counsel Consultation Required?
If YES, obtain r concurrence Signature in Section II. 1.9. Engineering Independent Technical Review (ITR) Required?
concurrence signature in Section II. 1.10. Challenge Board Required?
If YES, complete 1.10.a. Ift--... I
.......;':..--... '" ,... 1.11 RLE Signature:
Sharon Beverty iUllu..'Q. ()V.4 1.12 Licensing Peer Review Signature:
Steve -in, If YES, obtain r r Date:
Date:
Southern Nucfear Operating Company Nuclear NL-006-F03 SOUI'IaNA Ucenslng Ucensing Action and Concurrence Version 1.0 COMMNY Form Page 2 of 6 1.13 Signature:
NlA Office of External Affairs and General 1.14 "'Signature:
NlA Independent Technical SECTION IV -FINAL REVIEW AND (Mark "NA" for signatures that are not required, including individual Signing t('IIt)NL Manager or Supervisor:
Date:_________NL Director:
___________
_ _____ Date: FNP Vice President:
NJA Date: HNP Vice President:
NJA Date: VEGP Vice President NlA Date: Vice President NlA Date: Engineering Vice President:
NlA Date: Aeet Operations Executive Vice President:
NlA Date: IV.1. Does this letter contain Commitments?
If YES, complete l.a and l.b. , . /r Irv/ IV.1.a Has the Nl PrtncipeI Ucensing Engineer been nottrIed?
r! YES n NO IV_1.b Has Sec:tion lit bean COITlJ)IeI8d for each Commttrnent1 n VESr l NO ..'"" RLE Final Review: Date: 4-/ I" /13 Admin (date and Date: 4-/t l.,i Nuclear NL-006-F04 Licensing LICENSING RECORD FILE CHECKLIST Version 1.0 COMPANY Pa of 1 This checklist completed by the RLE and retained per Step 6.2.7 of NL-006-001, "Administrative Processing of NRC Correspondence." Check all applicable boxes and assemble related documents into the record package. NL LETIER/CORRESPONDENCE NUMBER: l3* 0"14 Z. i Gf' Verification and Validation copy of letter, if required (NL-006-003, "Outgoing NRC Correspondence." Steps 6.3.3,6.3.4,6.4.4 and 6.4.7). Pre-job briefing notes (NL-006-003, "Outgoing NRC Correspondence," Section 6.2.2). Copies/references of regulatory precedent, previous submittals, etc. List of documents reviewed. (See NL-006-GL03 "Guidelines for Preparing Submittals").
Completed Licensing Action Concurrence Form (NL-006-F03, "Licensing Action and Concurrence").
Copies of relevant CRs and Als. Relevant e-mail correspondence.
Relevant telephone conversation records. Correspondence with NRC, such as RAls. Licensing Project Plan, if required. (NL-006-GL06, "Guidelines for Preparation of Licensing Project Plans") Supporting documentation and/or a verification package, in accordance with NL-006-GL04, "Guidelines for Verification of Submittals," if required.
Challenge Board notes, if performed.
PRS/SRB Meeting Minutes, if required.
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