ML15105A571

LER 15-002-00 for Edwin I. Hatch Nuclear Plant, Unit 2, Regarding Performance of Operations with the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment

ML15105A571
Person / Time
Site:	Hatch
Issue date:	04/15/2015
From:	Pierce C R Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-15-0684 LER 15-002-00
Download: ML15105A571 (6)

Text

Charles R. Pierce Regulatory AHairs Director April 15, 2015 Docket Nos.: 50-366 Southern Nuclear Operating Company, Inc. 40 Inverness Center Parkway Post OHice Box 1295 Birmingham, AL 35201 Tel 205.992.7872 Fax 205.992.7601 U. S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Licensee Event Report 2015-002-00 SOUTHERN A COMPANY NL-15-0684 Performance of Operations With the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment Ladies and Gentlemen: In accordance with the requirements of 10 CFR 50.73(a)(2)(i)(B), Southern Nuclear Operating Company hereby submits the enclosed Licensee Event Report. This letter contains no NRC commitments. If you have any questions, please contact Greg Johnson at (912) 537-5874. ReC1!iJ:/' C. R. Pierce Regulatory Affairs Director CRP/jcm

Enclosure:

LER 2015-002-00

Edwin I. Hatch Nuclear Plant Licensee Event Report 2015-002-00 Performance of Operations With the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment Enclosure LER 2015-002-00 X NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150*0104 EXPIRES: 01/31/2017 (02-2014) 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 />. ,,..-..., 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 lnfonmation Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-000t, or by internet e*mailto lnlocollects.Resource@nrc.gov, and to the Desk Officer, Office ollnlonmation and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. II 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 inlonmation collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. PAGE Edwin I. Hatch Nuclear Plant Unit 2 05000 366 1 OF 3 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 NUMBER NO. MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 02 16 2015 2015 -002 -00 04 15 2015 9. OPERATING MODE 11. THIS REPORT IS SUBMITIED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: {Check all that apply) D 20.2201 (bl 0 20.2203(a)(3)(i) 0 50.73(a)(2)(i)(C) D 50.73(a)(2)(vii) D 20.2201 (dl 0 20.2203(a)(3)(ii) D 50.73(a)(2)(ii)(A) D 50.73(a)(2)(viii)(A) 5 0 20.2203(a)(1) 0 20.2203(a)(4) 0 50.73(a)(2)(ii)(B) D 50.73(a)(2)(viii)(B) 0 20.2203(a)(2)(i) 0 50.36(c)(1 )(i)(A) D 50.73(a)(2)(iii) D 50.73(a)(2)(ix)(A) 10. POWER LEVEL 0 20.2203(a)(2)(ii) D 50.36(c)(1 )(ii)(A) 0 50.73(a)(2)(iv)(A) D 50.73(a)(2)(x) 0 20.2203(a)(2)(iii) D 50.36(c)(2) D 50.73(a)(2)(v)(A) D 73.71(a)(4) 0 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(B) D 73.71 (a)(S) 0 0 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) D 50.73(a)(2)(v)(C) D OTHER 0 20.2203(a)(2)(vi) IZI 50. 73(a)(2)(i)(B) 0 50.73(a)(2)(v)(D) Specify In Abstract below or in NRC Form 366A 12. LICENSEE CONTACT FOR THIS LEA LICENSEE CONTACT NUMBER (Include Area Code} Edwin I. Hatch I Steven Tipps -Licensing Supervisor 912-537-5880 13. COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT CAUSE SYSTEM COMPONENT MANU* REPORTABLE CAUSE SYSTEM COMPONENT MANU-REPORTABLE FACTURER TO EPIX FACTURER TO EPIX 14. SUPPLEMENTAL REPORT EXPECTED 15.EXPECTED MONTH DAY YEAR 0 YES (If yes, complete 15. EXPECTED SUBMISSION DATE) IZI NO SUBMISSION DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) 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. !he 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, no cause determination was necessary. A licensee amendment request (LAR) will be submitted following NRC approval of the Technical Specification Task Force (TSTF) Traveler associated with generic resolution of this issue (TSTF-542). NRC FORM 366 (02*2014) jNRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150.0104 EXPIRES: 01131/2017 02*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 teamed are incorporated into the process and led back to industry. 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. 1. FACILITY NAME 2. DOCKET 6. LEA NUMBER 3. PAGE YEAR l SEQUENTIAL l REV NUMBER NO. Edwin I. Hatch Nuclear Plant Unit 2 05000 366 2 OF 3 2015 -002 -00 NARRATIVE 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 NRC FORM 366A (02-2014)

NRC FORM 366A (02-2014) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) CONTINUATION SHEET 1. FACILITY NAME 2. DOCKET 6. LER NUMBER 3. PAGE OF YEAR I SEQUENTIAL I REV NUMBER NO. Edwin I. Hatch Nuclear Plant Unit 2 05000 366 3 2015 -002 -00 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: LER 2013-002-00 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. NRC FORM 366A (02-2014)