05000263/LER-2015-001, Operations With A Potential To Drain The Reactor Vessel (OPDRV) Without Secondary Containment Operable
| Monticello Nuclear Generating Plant | |
| Event date: | 4-23-2015 |
|---|---|
| Report date: | 6-16-2015 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2632015001R00 - NRC Website | |
On April 23 and 25, 2015, during planned Reactor Recirculation System modifications and maintenance, the provisions of NRC Enforcement Guidance Memorandum (EGM)11-003 (Revision 2) were invoked for Operations With a Potential to Drain the Reactor Vessel (OPDRV) in noncompliance with Technical Specification (TS) 3.6.4.1, "Secondary Containment." These conditions are being reported in accordance with 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by the TS that is under enforcement discretion as specified in EGM 11-003.
The safety significance of these noncompliances is minimal as EGM 11-003 specifies interim actions that provide an adequate level of safety. Implementation of EGM 11-003 for these actions was a planned activity and as such, no cause determination was performed for the events. Following development of a Technical Specification Task Force traveler a license amendment request will be submitted to resolve this issue as required by EGM 11-003.
EVENT DESCRIPTION
During the 2015 Refueling Outage (RFO), Operations With a Potential to Drain the Reactor Vessel (OPDRV) activities were performed. Most OPDRVs did not meet the criteria to invoke the provisions of NRC Enforcement Guidance Memorandum (EGM)11-003 (Revision 2). However, on April 23 and 25, 2015, with the reactor cavity flooded to 21 feet, 11 inches, above the reactor vessel flange (Technical Specification (TS) 3.9.7, "Residual Heat Removal (RHR) — High Water Level" [BO]), the plant in MODE 5, and at 0.0 percent power, OPDRV activities were performed for which the provisions of EGM 11-003 were invoked, in noncompliance with TS 3.6.4.1, "Secondary Containment" [NG]. The plant performed the activities in accordance with the required actions of EGM 11-003, entitled, "Enforcement Guidance Memorandum 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." The specific OPDRV activities involved Reactor Recirculation System [AD] modifications and maintenance.
The NRC recognized that such activities may need to be performed during refueling outages while activities are underway with the Boiling Water Reactor [BWR] Owners Group (BWROG) to jointly formulate acceptable generic changes to the BWR TS. NRC guidance provided in EGM 11-003 provides specific interim actions that could be performed under enforcement discretion, as an alternative to compliance with the TS, while the improvements to the TS are under development by the NRC and BWROG. Plant procedure OWI-03.03, "Operation With Potential to Drain The Reactor," provides guidance to implement the interim actions specified in EGM 11-003. This procedure was utilized on two occasions invoking the guidance of EGM 11-003 during the 2015 RFO.
accordance with TS requirements. Other OPDRV activities occurred during this period which required the use of EGM 11-003 to be suspended.
EVENT ANALYSIS
These occurrences are being reported in accordance with 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by TS, as additionally specified in EGM 11-003. The OPDRVs discussed in this report were performed during the 2015 RFO invoking the guidance of EGM 11-003 instead of full compliance with the TS for these planned activities.
SAFETY SIGNIFICANCE
The safety significance of these occurrences is minimal. As discussed in EGM 11-003, enforcement because the associated interim actions necessary to receive enforcement discretion ensure an adequate level of safety. A plant procedure was developed to implement the interim actions specified in EGM 11-003. This procedure was applied for the OPDRV activities under the scope of EGM 11-003. This procedure was applied for the OPDRV activities under the scope of EGM 11-003 during periods in which secondary containment was not operable.
CAUSE
Implementation of EGM 11-003 interim actions during the 2015 RFO was a planned activity. As such, no cause determination was needed for these events.
CORRECTIVE ACTION
A license amendment request will be submitted to adopt the Technical Specification Task Force (TSTF) traveler associated with the generic resolution for this issue, within twelve months after issuance of the Notice of Availability for the TSTF traveler as required by EGM 11-003. This action is being tracked in the Monticello Nuclear Generating Plant (MNGP) Corrective Action Program.
PREVIOUS SIMILAR EVENTS
A review of MNGP Licensee Event Reports from the last three years found no other instances where EGM 11-003 was invoked. EGM 11-003 was first issued in 2011.
ADDITIONAL INFORMATION
The Institute of Electrical and Electronics Engineer codes for equipment are denoted by [XX].