05000354/LER-2015-002
| Hope Creek Generating Station | |
| Event date: | 04-14-2015 |
|---|---|
| Report date: | 06-10-2015 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3542015002R00 - NRC Website | |
PLANT
General Reactor Secondary *Energy
IDENTIFICATION
Event
Discovery
CONDITIONS
Hope Operations.
DESCRIPTION
On potential operations recognized with Technical Revision Noncompliance Draining an BWROG.
102, on
AND SYSTEM IDENTIFICATION
Electric - Boiling Water Reactor (BWR/4)* Pressure Vessel (AC) - EIIS Identifier {AC/RPV} Containment (NG) - EIIS Identifier {NG} Industry Identification System {EllS} codes and component function identifier codes appear as {SS/CCC}
OF OCCURRENCE
Dates: April 14, April 15, April 17, April 20, April 27, and April 29, 2015 Dates: April 14, April 15, April 17, April 20, April 27, and April 29, 2015
PRIOR TO OCCURRENCE
Creek was shut down for Refueling Outage H1R19 in Operational Condition (OPCON) 5 - Refueling
OF OCCURRENCE
April 14, April 15, April 17, April 20, April 27, and April 29, 2015, with Hope Creek Generating Station (HCGS) a planned refueling outage and the reactor cavity flooded up in OPCON 5, HCGS performed operations with to drain the reactor vessel (OPDRV) without an operable secondary containment {NG}. These are prohibited by Technical Specification (TS) 3.6.5.1, "Secondary Containment Integrity." The NRC that such activities may need to be performed during refueling outages while activities were underway the Boiling Water Reactor Owners Group (BWROG) to formulate acceptable generic changes to the BWR Specifications (TS). NRC guidance provided in Enforcement Guidance Memorandum (EGM) 11-003, 2, "Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee with Technical Specification Containment Requirements During Operations With a Potential for the Reactor Vessel," dated December 13, 2013, allowed the implementation of specific interim actions, alternative to full compliance with TS, while the improvements in the TS are under development with the The required interim actions specified in the EGM were incorporated into plant procedure OP-HC-108- "Management of Operations with the Potential to Drain the Reactor Vessel." This procedure was then utilized these occasions as listed in Table 1, during Refueling Outage (H1R19) in April 2015.
Table 1 - HCGS OPDRVs Performed April 2015 a as Activity / Duration Start End Removal of Scram Air Header from Service / 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, 15 minutes April 14, 2015 at 14:00 EDT April 14, 2015 at 17:15 EDT Replace the B Reactor Recirculation Pump seal / 8 days, 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />, 19 minutes April 15, 2015 at 04:36 EDT April 24, 2015 at 02:55 EDT Replacement of Control Rod Drive mechanisms / 2 days, 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />, 45 minutes April 17, 2015 at 14:17 EDT April 20, 2015 at 13:02 EDT Replacement of Local Power Range Monitors / 3 days, 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, 27 minutes April 20, 2015 at 03:13 EDT April 23, 2015 at 06:40 EDT Expanding the tagged boundary for the Scram Discharge Volume / 12 minutes April 27, 2015 at 13:14 EDT April 27, 2015 at 13:26 EDT Fill and Vent of the B Reactor Recirculation Pump seal / 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, 4 minutes April 29, 2015 at 20:41 EDT April 30, 2015 at 06:45 EDT the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503.1f a means used to Impose an information collection does not display a currency valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
2. DOCKET 6. LER NUMBER 3. PAGE 1. FACILITY NAME Hope Creek Generating Station 05000354
CAUSE OF EVENT
Implementation of EGM 11-003, Revision 2, interim actions during the HCGS refueling outage (H1R19) was a planned activity. As such, no cause determination was performed for the event.
SAFETY CONSEQUENCES AND IMPLICATIONS
The OPDRVs discussed in this report were performed during the HCGS refueling outage (H1R19) and were accomplished using the interim actions provided by the NRC in EGM 11-003, Revision 2. For these events, HCGS adhered to the NRC plain language meaning of OPDRV activities that could potentially result in draining or siphoning the RPV water level below the top of fuel. This included evolutions involving aligning and realigning plant systems prior to achieving steady-state water level control, without taking credit for mitigating measures. HCGS also met the requirements that specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain down times. Further, 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 TS requirements for activities were followed. Since these compensatory measures were properly implemented, an adequate level of safety was provided during the OPDRV activities described in this report. Based on this information, the performance of these OPDRV activities were determined to have a low safety significance.
PREVIOUS EVENTS
A review of Licensee Event Reports and the corrective action program for the past three years identified the following previous similar occurrences:
- LER 2012-003-00, dated May 5, 2012, reported an OPDRV activity during the 2012 refueling outage (H1R17). Interim actions in accordance with Revision 0 of the EGM were applied. No corrective actions were stated.
- LER 2013-004-00, dated December 10, 2013, reported OPDRV activities during the 2013 refueling outage (H1R18). Interim actions in accordance with Revision 1 of the EGM were applied. No corrective actions were stated.
CORRECTIVE ACTIONS
HCGS will submit a license amendment request to adopt a Technical Specification Task Force (TSTF) traveler associated with generic resolution of this issue, within four months after the issuance of the Notice of Availability of the TSTF traveler.
COMMITMENTS
This LER contains no regulatory commitments.