05000366/LER-2015-002
| Edwin I. Hatch Nuclear Plant | |
| Event date: | 02-16-2015 |
|---|---|
| Report date: | 04-15-2015 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3662015002R00 - NRC Website | |
jNRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150.0104 EXPIRES: 01131/2017 02·201 4) Reported lessons teamed are incorporated into the licensin~ process and led back to industry. ~j LICENSEE EVENT REPORT {LER) Send comments regarding burden estimate to the FOIA, rivacy and Information Collections Branch (T-5 F53), U.S. Nudear Regulatory Commission, Washington, DC 20555·0001 , or by internet e-mail to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office ollnformation and Regulatgc Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, CONTINUATION SHEET Washington, 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.
2015 - 002 - 00
PLANT AND SYSTEM IDENTIFICATION
General Electric- Boiling Water Reactor (BWR) Energy Industry Identification System codes appear in the text as (EllS Code XX)
DESCRIPTION OF EVENT
In February 2015, with Unit 2 at 0 percent rated thermal power due to a scheduled refueling outage, operations with the potential to drain the reactor vessel (OPDRV) activities were performed while in Mode 5 (Refueling Mode) contrary to Technical Specification (TS) 3.6.4.1. The NRC recognizes that such activities need to be performed during refueling outages. Activities are underway to formulate acceptable generic changes to BWR Technical Specifications. NRC Regulatory Issue Summary (RIS) 2012-11 communicated this guidance to the industry. Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 currently provides enforcement discretion for licensee noncompliance with TS containment requirements during OPDRV activities until December 31, 2015 while the NRC staff and Boiling Water Reactor Owner's Group finalize a generic solution forTS changes. The required interim actions specified in the EGM were incorporated into plant procedure 31GO-OPS-025-0: OPERATIONS WITH THE POTENTIAL TO DRAIN THE REACTOR VESSEL. This procedure was utilized during the following three occasions during the 2015 Unit 2 Refueling Outage:
Table 1 :Hatch Unit 2 OPDRVs Performed February 2015 OPDRV Activity Start End LPRM Removal and Replacement 02/16/2015, 0945 EST 02/16/2015, 2100 EST HCU Drive Push-Pull 02/1 8/2015, 2238 EST 02/19/2015, 2352 EST HCU High Point Vent 02/23/2015, 1635 EST 02/24/2015, 0325 EST
CAUSE OF EVENT
Implementation of the required EGM 11-003, Revision 2 interim actions during the 2015 Unit 2 Refueling Outage was a planned activity. As such, no cause determination was performed for the events.
REPORT ABILITY AND SAFETY ASSESSMENT
This event is reportable per 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by Technical Specifications (TS) 3.6.4.1.C.3, which prohibits performing activities identified as OPDRVs in Mode 5 while secondary containment is inoperable.
The OPDRVs discussed in this report performed during the Unit 2 Refueling Outage were accomplished using interim actions provided by the NRC in EGM 11-003, Revision 2. Hatch adhered to the NRC plain language meaning of OPDRV activities that could potentially result in draining of siphoning the reactor pressure vessel (RPV) water level below the top of the fuel. Hatch also met the requirements which specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain down times. Furthermore, 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 Specifications requirements for OPDRV activities were followed. Since these compensatory measures were properly implemented, an adequate level of safety was provided during the performance of the OPDVR activities described in this report Based on this information, the performance of these OPDRV activities were determined to have a very low safety significance.
CORRECTIVE ACTIONS
3 Consistent with the guidance given in EGM 11-003 Revision 2, Hatch will submit a licensee amendment request (LAR) following NRC approval of the Technical Specifications Task Force (TSTF) Traveler associated with generic resolution of this issue within the time restraints given in the EGM.
ADDITIONAL INFORMATION
Other Systems Affected: None.
Failed Components Information: None.
Commitment Information: This report does not created any new licensing commitments.
Previous Similar Events:
On February 19, 2013, February 20, 2013, and February 25, 2013, OPDRV activities were performed while Unit 2 was in Refueling Mode (Mode 5) without an operable secondary containment These activities are prohibited by Technical Specifications (TS) 3.6.4.1. However, NRC guidance provided in Regulatory Issue Summary (RIS) 2012-11 and in Enforcement Guidance Memorandum (EGM) 11-003, Revision 1 allowed the implementation of interim actions as an alternative to full compliance. An adequate defensed 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 the movement of irradiated fuel with the spent fuel storage pool gates removed in Mode 5. The associated Technical Specification Task Force (TSTF) Traveler is not yet available as a Technical Specification consolidated line item improvement process (CLIIP) for use by licensees. For that reason, the corrective actions from this event would not be expected to have prevented the condition reported in this LEA.