05000366/LER-2017-001

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LER-2017-001, 1 OF 3
Edwin I. Hatch Nuclear Plant Unit 2
Event date: 02-10-2017
Report date: 04-03-2017
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3662017001R00 - NRC Website

Reported lessons teamed 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-mail to Infocollects.Resource@nm.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.

PLANT AND SYSTEM INDENTIFICATION

General Electric — Boiling Water Reactor (BWR) Energy Industry Identification System codes appear in the text as (EIIS Code XX)

DESCRIPTION OF EVENT

In February 2017, with Unit 2 at 0 percent rated thermal power due to a scheduled refueling outage, planned operations with the potential to drain the reactor vessel (OPDRV) activities were performed without secondary containment intact 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 TS. NRC Regulatory Issue Summary (RIS) 2012-11 communicated this guidance to the industry. Enforcement Guidance Memorandum (EGM) 11-003, Revision 3 currently provides enforcement discretion for licensee noncompliance with TS containment requirements during OPDRV activities until December 31, 2017. The required interim actions specified in the EGM were incorporated into plant procedure 31GO-OPS-025 "Operations with the Potential To Drain the Reactor Vessel.

This procedure was utilized during the following three occasions during the 2017 Unit 2 Refueling Outage:

Table 1: Hatch Unit 2 OPDRVs Performed February 2017 OPDRV Activity Start End LPRM Removal and Replacement 02/10/2017, 1038 EST 02/10/2017, 2340 EST CRD Push-Pull 02/11/2017, 0526 EST 02/11/2017, 1745 EST HCU Vent 02/12/2017, 2006 EST 02/13/2017, 0544 EST

CAUSE OF EVENT

Implementation of the required EGM 11-003, Revision 3 interim actions during the 2017 Unit 2 Refueling Outage was a planned activity. As such, no cause determination was performed for the events.

REPORTABILITY 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 3. 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 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 followed. Since these compensatory measures were properly implemented, an adequate level of safety was provided during the performance of the OPDRV activities described in this report. Based on the information, the performance of these OPDRV activities was determined to have a very low safety significance.

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-mail 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.

CORRECTIVE ACTIONS

Consistent with the guidance given in EGM 11-003 Revision 3, Hatch will submit a license amendment request for the associated NRC-approved Technical Specifications Task Force (TSTF) Traveler 542, "Reactor Pressure Vessel Water Inventory Control" within the time restraints given in the EGM.

ADDITIONAL INFORMATION

Other Systems Affected: None Failed Components Information: None.

Commitment Information: This report does not create any new licensing commitments.

Previous Similar Events:

On February 13 through 15, 2016, February 15 through 16, 2016, and February 17 through 18, 2016 operations with the potential to drain the reactor vessel (OPDRV) activities were performed while Unit 1 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 3 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 2016 Hatch Unit 1 Refueling Outage in February.

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.