05000321/LER-2018-002, Regarding Operations with the Potential to Drain the Reactor Vessel (Opdrvs) Without Secondary Containment

Regarding Operations with the Potential to Drain the Reactor Vessel (Opdrvs) Without Secondary Containment

ML18080A057
Person / Time
Site:	Hatch
Issue date:	03/21/2018
From:	Vineyard D Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-18-0351 LER 2018-002-00
Download: ML18080A057 (5)

LER-2018-002, Regarding Operations with the Potential to Drain the Reactor Vessel (Opdrvs) Without Secondary Containment

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)
3212018002R00 - NRC Website

text

A Southern Nuclear March 21, 2018 Docket Nos.: 50-321 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Unit 1 Ha1dt Nude2lr P!lan2 11028 ~

Palbay Nllaa BalOey. GA 31513 912 537 5859 tEl 912 sa& '2J1T1 lim NL-18-0351 Operations with the Potential to Drain the Reactor Vessel (OPDRVs) Without Secondary Containment Ladies and Gentlemen:

In accordance with the requirements of 10 CFR 50.73(a)(2)(i)(B), Southern Nuclear Operating Company (SNC) hereby submits the enclosed Licensee Event Report (LEA).

This letter contains no NRC commitments. If you have any questions, please contact Keith Long at {912) 537-5874.

D. R. Vineyard Vice President - Hatch DRV/jcb Enclosure: LEA 2018-002-00

U. S. Nuclear Regulatory Commission NL-18-0351 Page2 Cc:

Regional Administrator, Region II NRR Project Manager-Hatch Senior Resident Inspector-Hatch RTYPE: CHA02.004

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150*0104 EXPIRES: 10/31/2018 (06-2016)

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 />.

~~

LICENSEE EVENT REPORT (LER)

Reported lessons learned are incorporated into the licensing process and fed back to industry.

Send comments regarding burden estimate to the FOIA, Privacy and tntonnation Collections

'= '/

(See Page 2 for required number of digits/characters for each block)

Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to lntocollects.Resource@nrc.gov, and to the Desk Officer, Olfice of lntonnation and Regulatory (See NUREG-1 022, R.3 for instruction and guidance for completing this form Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503.11 a means used to impose an intonnation collection does not display a currently valid OMB control httt>i lwww.l'li'C.oovlreadoo-fm'OO!:-oofedlcos/llll!lremslslafftslrt02Z'l3!)

number, the NRC may not conduct or sponsor, and a person is not required to respond to, the intonnation collection.

1. FACILITY NAME

~ - DOCKET NUMBER

~-PAGE Edwin I. Hatch Unit 1 05000321 1 OF3

4. TITLE Performance of Operations with the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment

5. EVENT DATE

6. LEA NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR MONTH DAY YEAR NUMBER NO.

FACILITY NAME DOCKET NUMBER 02 09 2018 2018

- 002

- 00 03 21 2018

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: Check all that apply) 0 20.2201(b) 0 20.2203(a)(3)(i) 0 50.73(a)(2)(ii)(A) 0 50.73(a)(2)(viii)(A) 5 0 20.2201 (d) 0 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) 0 20.2203(a)(1) 0 20.2203(a)(4) 0 50.73(a)(2)(iii) 0 50.73(a)(2)(ix)(A) 0 20.2203(a)(2)(i) 0 50.36(c)(1 )(i)(A) 0 50.73(a)(2)(iv)(A) 0 50.73(a)(2)(x)

10. POWER LEVEL 0 20.2203(a)(2)(ii) 0 50.36(c)(1 )(ii)(A) 0 50.73(a)(2)(v)(A) 0 73.71(a)(4) 0 20.2203(a)(2)(iii) 0 50.36(c)(2) 0 50.73(a)(2)(v)(B) 0 73.71(a)(5) 0 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(C) 0 73.77(a)(1) 000 0 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(D) 0 73.77(a)(2)(i) 0 20.2203(a)(2)(vi) 181 50. 73(a)(2)(i)(B) 0 50.73(a)(2)(vii) 0 73.77(a)(2)(ii) 0 50.73(a)(2)(i)(C) 00THER Specily in Abstract below or in NRC Fonn 366A

12. LICENSEE CONTACT FOR THIS LEA ICENSEE CONTACT J~LEPHONE NUMBER (Include Area Code)

Edwin I. Hatch I Jimmy Collins - Licensing Supervisor 912-537*2342

13. COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT

CAUSE

SYSTEM COMPONENT MANU-REPORTABLE

CAUSE

SYSTEM COMPONENT MANU-REPORTABLE FACTURER TOEPIX FACTURER TOEPIX

14. SUPPLEMENTAL REPORT EXPECTED

15. EXPECTED MONTH DAY YEAR 0 YES (lfyes, complete 15. EXPECTED SUBMISSION DATE) 181 NO SUBMISSION DATE ABSTRACT (Umff to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On February 9 through February 13, 2018, planned operations with the potential to drain the reactor vessel (OPDRV) activities were performed while Unit 1 remained in Refueling Mode (Mode 5) without an operable secondary containment. These activities are prohibited per Technical Specifications (TS) 3.6.4.1. However, recent NRC guidance provided in Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 and in Regulatory Issue Suf!lmary (RIS) 2012-11 allowed the implementation of int~rim actions as an alternative to full compliance. These actions are contained in the operating procedure for the OPDRV activities performed during the 2018 Hatch Unit 1 Refueling Outage in February.

The performance of OPDRV activities were planned activities that were completed under the guidance of plant procedures and confirmed to have low safety significance based on interim actions taken. Since these actions were deliberate, a cause determination was not necessary. A license amendment request (LAR) has been submitted for the associated NRC-approved Technical Specifications Task Force (TSTF) Traveler 542, "Reactor Pressure Vessel Water Inventory Control."

Event Description

In February 2018, with Unit 1 at 0 percent rated thermal power due to a scheduled refueling outage, planned operations with the potential to drain the reactor vessel (OPDRV) activities were performed without secondary containment intact 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 TS. NRC Regulatory Issue Summary (RIS) 2012-11 communicated this guidance to the industry. Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 currently provides enforcement discretion for licensee noncompliance with TS containment requirements during OPDRV activities. The required interim actions specified in the EGM were incorporated into plant procedure 31 GO-OPS-025 "Operations with the Potential To Drain the Reactor Vessel." This procedure was utilized during the following three occasions during the 2018 Unit 1 Refueling Outage:

Table 1: Hatch Unit 1 OPDRVs Performed February 2018 OPDRV Activity Start End LPRM Removal and Replacement 02109/2018 0211 0/2018 CAD Push-Pull 0211 0/2018 0211212018 HCU Vent 0211212018 02113/2018 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.

Event Cause Analysis

Implementation of the required EGM 11-003, Revision 3 interim actions during the 2018 Unit 1 Refueling Outage was a planned activity. As such, no cause determination was performed for the events.

Safety Assessment

The OPDRVs discussed in this report performed during the Unit 1 Refueling Outage were accomplished using interim actions provided by the NRC in EGM 11-003, Revision 3. 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 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

!Jrovided during the performance of the OPDRV activities described in this report. Based on the information, Page 2 of 3 (Q6.201 6)

U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150*0104 EXPIRES: 10/31/2018 LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET (See NUREG-1 022, A.3 for instruction and guidance for completing this form ht!p;:/t\\w.rwJ!lte.ooy/!l!<rl'OO*rmldiol!:-oof~staft/sr1022Jr3/)

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.

Send comments regarding burden estimate to the FOIA, Privacy and lnfonmation Collections Branch (T*5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by 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.

3. LEA NUMBER Edwin I. Hatch Unit 1 05000-321 YEAR I SEQUENTIAL I REV NUMBER NO.

2018

- 002

- 00 the performance of these OPDRV activities was determined to have a very low safety significance.

Corrective Actions

Consistent with the guidance given in EGM 11-003 Revision 3, Hatch has submitted a license amendment request for the associated NRC-approved Technical Specifications Task Force (TSTF) Traveler 542, "Reactor Pressure Vessel Water Inventory Control."

Previous Similar Events

LER 2017-001-00 On February 10 through February 13, 2017, planned operations with the potential to drain the reactor vessel (OPDRV) activities were performed while Unit 2 remained in Refueling Mode (Mode 5) without an operable secondary containment. These activities are prohibited by Technical Specifications (TS) 3.6.4.1. However, recent NRC guidance provided in Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 and in Regulatory Issue Summary (RIS) 2012-11 allowed the implementation of interim actions as an alternative to full compliance. These actions are contained in the operating procedure for the OPDRV activities performed during the 2017 Hatch Unit 2 Refueling Outage in February.

LER 2016-002-00 On February 13 through 15, 2016, February 15 through 16, 2016, and February 17 through 18,2016 operations with the potential to drain the reactor vessel (OPDRV) activities were performed while Unit 1 remained in Refueling Mode (Mode 5) without an operable secondary containment. These activities are prohibited by Technical Specifications (TS) 3.6.4.1. However, recent NRC guidance provided in Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 and in Regulatory Issue Summary (RIS) 2012-11 allowed the implementation of interim actions as an alternative to full compliance. These actions are compiled in the operating procedure for the OPDRV activities performed during the 2016 Hatch Unit 1 Refueling Outage in February.

LER 2015-002-00 On. February 16,2015, February 18 through 19,2015, and.February 23 through 24,2015 operations with the potential to drain the reactor vessel (OPDRV) activities were performed while Unit 2 remained in Refueling Mode (Mode 5) without an operable secondary containment. These activities are prohibited by Technical Specifications (TS) 3.6.4.1. However, recent NRC guidance provided in Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 and in Regulatory Issue Summary (RIS) 2012-11 allowed the implementation of interim actions as an alternative to full compliance. These actions are compiled in the operating procedure for the OPDRV activities performed during the 2015 Hatch Unit 2 Refueling Outage in February. Page 3 of 3