05000388/LER-2015-005, Regarding Condition Prohibited by Technical Specifications Due to Implementation of Enforcement Guidance Memorandum (EGM) 11-003

Regarding Condition Prohibited by Technical Specifications Due to Implementation of Enforcement Guidance Memorandum (EGM) 11-003

ML15161A007
Person / Time
Site:	Susquehanna
Issue date:	06/10/2015
From:	Franke J Susquehanna, Talen Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-7340 LER 15-005-00
Download: ML15161A007 (4)

LER-2015-005, Regarding Condition Prohibited by Technical Specifications Due to Implementation of Enforcement Guidance Memorandum (EGM) 11-003

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 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)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function
3882015005R00 - NRC Website

text

• JUN 1 0 2015

.Jon A. Franke Site Vice President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick, P A 18603 Tel. 570.542.2904 Fax 570.542.1504 jon.franke@talenenergy.com SUSQUEHANNA STEAM ELECTRIC STATION LICENSEE EVENT REPORT 50-388/2015-005-00 UNIT 2 LICENSE NO. NPF -22 PLA-7340 TALEN--6' ENERGY 10 CFR 50.73 Docket No. 50-388 Attached is Licensee Event Report (LER) 50-388/2015-005-00. 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 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). 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 this event.

This letter contains no new regulatory commitments.

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J. A. Franke Attachment: LER 388/2015-005-00 Copy:

NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. B. R. Fuller, PA DEP/BRP

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 (02-2014)

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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 />.

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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

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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 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.

r* PAGE Susquehanna Steam Electric Station, Unit 2 05000388 1 of 3

4. TITLE Condition Prohibited by Technical Specifications Due to Implementation of Enforcement Guidance Memorandum (EGM) 11-003

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 NO.

MONTH DAY YEAR 05000 NUMBER Olo \\0 FACILITY NAME DOCKET NUMBER 04 14 2015 2015

- 005 00 2015 05000

9. OEPRATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 5 D 2o.2201(b)

D 20.2203(a)(3)(i)

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

D 50.73(a)(2)(vii)

D 2o.22o1 (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) 000 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 50.46(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) 1:8] 50.73(a)(2)(i)(B)

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

Specify in Abstract below or in 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, 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 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_

COMPONENT FAILURE INFORMATION

None

PREVIOUS SIMILAR EVENTS

LER 50-387/2014-006-00 (PLA-7185): Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 LER 50-388/2013-001-00 (PLA 7018): Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 1