05000354/LER-2016-004

LER-2016-004, 1 OF 3

Hope Creek Generating Station
Event date:	10-23-2016
Report date:	12-20-2016
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3542016004R00 - NRC Website

LER 16-004-00 for Hope Creek Regarding Operations With a Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment

ML16355A191
Person / Time
Site:	Hope Creek
Issue date:	12/20/2016
From:	Casulli E T Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N16-0229 LER 16-004-00
Download: ML16355A191 (6)

Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a (See NUREG-1022, R.3 for instruction and guidance for completing this form means used to Impose an information collection does not display a currently valid OMB control http://www.nrc.govireadino-rm/doc-collections/nureos/staff/sr1022/r31) number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

Hope Creek Generating Station 05000-354 YEAR

PLANT AND SYSTEM IDENTIFICATION

General Electric - Boiling Water Reactor (BWR/4)* Reactor Pressure Vessel (AC) - EIIS Identifier {AC/RPV} Secondary Containment (NG) - EllS Identifier {NG} *Energy Industry Identification System {EIIS} codes and component function identifier codes appear as {SS/CCC}

IDENTIFICATION OF OCCURRENCE

Event Dates: October 23, October 24, and October 31, 2016 Discovery Dates: October 23, October 24, and October 31, 2016

CONDITIONS PRIOR TO OCCURRENCE

Hope Creek was shut down for Refueling Outage H1R20 in Operational Condition (OPCON) 5 - Refueling Operations.

DESCRIPTION OF OCCURRENCE

On October 23, October 24, and October 31, 2016, with Hope Creek Generating Station (HCGS) in a planned refueling outage and the reactor cavity flooded in OPCON 5, HCGS performed operations with a potential to drain the reactor vessel (OPDRV) without an operable secondary containment {NG}. These operations are prohibited by Technical Specification (TS) 3.6.5.1, "Secondary Containment Integrity." The NRC recognized that such activities may need to be performed during refueling outages while activities were underway with the Boiling Water Reactor Owners (BWROG) to formulate acceptable generic changes to the BWSR Technical Specifications (TS). NRC guidance provided in Enforcement Guidance Memorandum (EGM) 11-003, Revision 3, "Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements During Operations With a Potential for Draining the Reactor Vessel," dated January 15, 2016, allowed the implementation of specific interim actions, as an alternative to full compliance with TS, while the improvements in the TS are under development with the BWROG. The required interim actions specified in the EGM were incorporated into plant procedure OP-HC-108-102, "Management of Operations with the Potential to Drain the Reactor Vessel.

This procedure was then utilized on these occasions as listed in Table 1, during Refueling Outage (H1R20).

Table 1 - HCGS OPDRVs Performed October 2016 Activity / Duration Start End Replacement of Control Rod Drive mechanisms/ 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, 10 minutes October 23, 2016 at 08:40

EDT

October 23, 2016 at 22:50

EDT

Replacement of Local Power Range October 23, 2016 at 22:50 October 24, 2016 at 08:07 Monitors/ 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, 17 minutes EDT EDT Replacement of Control Rod Drive mechanisms and LPRMs/ 1 day, 16 minutes October 24, 2016 at 08:07

EDT

October 25, 2016 at 08:23

EDT

Fill and Vent of the A and B Reactor Recirculation Pump seal / 1 Day, 41 minutes October 31, 2016 at 11:21

EDT

November 1, 2016 at 12:02

CAUSE OF EVENT

Implementation of EGM 11-003, Revision 3, interim actions during the HCGS refueling outage (H1R20) was a planned activity. As such, no cause determination was performed for the event.

Reported lessons learned are incorporated Into the licensing process and fed back to industry, Send comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mall to Infocollects.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 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, Hope Creek Generating Station 05000-354 2016 - 004 - 00

SAFETY CONSEQUENCES AND IMPLICATIONS

The OPDRVs discussed in this report were performed during the HCGS refueling outage (H1R20) and were accomplished using the interim actions provided by the NRC in EGM 11-003, Revision 3. 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 concurrences:

• LER 2012-003-00, dated May 5, 2012, reported an OPDRV activity during the 2012 refueling outage (H1 R17). 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.

• LER 2015-002-11, dated June 10, 2015, reported OPDRV activities during the 2015 refueling outage (H1R19). Interim actions in accordance with Revision 2 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 (TTF) traveler associated with generic resolution of this issue, within twelve months after the issuance of the Notice of Availability of the TSTF traveler as required by EGM 11-003. This action is being tracked in HCGS Corrective Action Program.

COMMITMENTS

This LER contains no regulatory commitments