05000440/FIN-2017002-02
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Finding | |
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| Title | Implementation of Enforcement Guidance Memorandum 11003, Revision 3 |
| Description | From March 17, 2017, to March 24, 2017, Perry Nuclear Power Plant (PNPP) performed Operations with the Potential to Drain the Reactor Vessel (OPDRV) while in Mode 5 without an operable primary and secondary containment. An OPDRV is an activity that could result in the draining or siphoning of the reactor pressure vessel water level below the top of fuel, without crediting the use of mitigating measures to terminate the uncovering of fuel. Secondary containment was required by TS 3.6.4.1 to be operable during OPDRVs. Primary containment was required by TS 3.6.1.10 to be operable during OPDRVS. The required action for these specifications was to suspend OPDRV operations. Therefore, entering the OPDRV without establishing primary and secondary containment integrity was considered a condition prohibited by TS as defined by 10 CFR 50.73(a)(2)(i)(B).The NRC issued Enforcement Guidance Memorandum (EGM) 11003, Revision 3, on January 15, 2016, to provide guidance on how to disposition boiling water reactor licensee noncompliance with TS containment requirements during OPDRV operations. The NRC considers enforcement discretion related to secondary containment operability during Mode 5 OPDRV activities appropriate because the associated interim actions necessary to receive the discretion ensure an adequate level of safety by requiring licensees immediate actions to (1) adhere to the NRC plain language meaning of OPDRV activities; (2) meet the requirements which specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain down times;
(3) ensure that adequate defense in depth is 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; and (4) ensure that licensees follow all other Mode 5 TS requirements for OPDRV activities.The inspectors reviewed licensee event report (LER) 201700100 for potential performance deficiencies and/or violations of regulatory requirements. The inspectors also reviewed the stations implementation of the EGM during OPDRVs:The inspectors observed that the OPDRV activities were logged in the control room narrative logs, the log entry appropriately recorded the standby source of makeup water designated for the evolutions, and that defense in-depth criteria were in place.The inspectors noted that the reactor vessel water level was maintained at least 22 feet and 9 inches over the top of the reactor pressure vessel flange as required by TS 3.9.6. The inspectors also verified that at least one safety-related pump was the standby source of makeup designated in the control room narrative logs for the evolutions. The inspectors confirmed that the worst case estimated time to drain the reactor cavity to the reactor pressure vessel flange was greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.The inspectors reviewed Engineering Change documents which calculated the time to drain down during these activities and the feasibility of pre-planned actions the station would take to isolate potential leakage paths during these periods of time. The inspectors verified that the OPDRVs were not conducted in Mode 4 and that the licensee did not move irradiated fuel during the OPDRVs. The inspectors noted that PNPP had in place a contingency plan for isolating the potential leakage path and verified that two independent means of measuring reactor pressure vessel water level were available for identifying the onset of loss of inventory events.The inspectors verified that all other TS requirements were met during the March 17, 2017, to March 24 2017, OPDRVs with primary and secondary containment inoperable.Technical Specification 3.6.4.1 required, in part, that secondary containment shall be operable during OPDRV. Technical Specification 3.6.4.1, Condition C, required the licensee to initiate action to suspend OPDRV immediately when secondary containment is inoperable. Technical specification 3.6.1.10 required, in part, that primary containment shall be operable during OPDRV. Technical specification 3.6.1.10, Condition A, required the licensee initiate action to suspend OPDRV immediately when primary containment is inoperable. From March 17, 2017, to March 24, 2017, PNPP performed OPDRV activities while in Mode 5 without an operable primary or secondary containment. Specifically, the station performed the following OPDRV activities without an operable primary or secondary containment:draining of reactor recirculation loop B; replacement of 18 control rod drive mechanisms (unbolt and install);replacement of six instrument dry tubes;replacement of reactor recirculation pump B seal;replacement of reactor recirculation loop B flow control valve actuator;plugging of drain line appendages on reactor recirculation pump B; andlocal leak rate testing of the reactor water cleanup suction line containment isolation valves.The failure to perform OPDRV activities with operable primary and secondary containments is a violation of TS 3.6.1.10 and TS 3.6.4.1. Because the violation occurred during the discretion period described in EGM 11003, Revision 3, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation.In accordance with EGM 11003, Revision 3, each licensee that receives discretion must submit a license amendment request within 12 months of the NRC staffs publication in the Federal Register of the notice of availability for a generic change to the standard TS to provide more clarity to the term OPDRV. The inspectors observed thatPNPP is tracking the need to submit a license amendment request as commitment PYL1712101.This LER is closed. This inspection constituted one event follow-up sample as defined in IP 7115305. |
| Site: | Perry  |
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| Report | IR 05000440/2017002 Section 4OA3 |
| Date counted | Jun 30, 2017 (2017Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | M Young S Graves G Pick P Elkmann N Day M Stafford E Schrader S Hedger |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - Perry - IR 05000440/2017002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2017Q2
Self-Identified List (Perry)
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