05000440/LER-2017-001

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LER-2017-001, Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 3
Perry Nuclear Power Plant
Event date: 03-17-2017
Report date: 05-01-2017
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4402017001R00 - NRC Website

Infocollects Resource@nrc gov, and to the Desk Officer, Office of Information and Regulatory Affairs, 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 440 - 001 - 00 Perry Nuclear Power Plant 05000 - 2017 Energy Industry Identification System (ENS) codes are identified in the text as [XX]

INTRODUCTION

From March 17, at

0508 hours
0.00588 days
0.141 hours
8.399471e-4 weeks
1.93294e-4 months

, to March 24, 2017, at

0956 hours
0.0111 days
0.266 hours
0.00158 weeks
3.63758e-4 months

, Perry Nuclear Power Plant (PNPP) conducted Operations with the Potential for Draining the Reactor Vessel (OPDRV) while in Mode 5 at zero percent power, without an operable Primary and Secondary Containment [NH] as required by Technical Specifications 3 6 1 10 and 3 6 4 1 These activities were performed in accordance with the Enforcement Guidance Memorandum (EGM) 11-003, Revision 3, which allows the implementation of interim actions as an alternative to full compliance with Technical Specifications provided several conditions are met This event is being reported in accordance with 10 CFR 50 73(a)(2)(1)(B) as a condition prohibited by Technical Specifications

DESCRIPTION OF EVENT

During Refueling Outage 1R16 from March 17, at

0508 hours
0.00588 days
0.141 hours
8.399471e-4 weeks
1.93294e-4 months

, to March 24, 2017, at

0956 hours
0.0111 days
0.266 hours
0.00158 weeks
3.63758e-4 months

, PNPP conducted OPDRVs while in Mode 5 at zero percent power, without an operable Primary and Secondary Containment as required by Technical Specifications 3 6 1 10 and 3 6 4 1 The following OPDRV activities were completed during this period

  • Draining of Reactor Recirculation [AD] Loop B
  • Replacement of 18 control rod [AA] drive mechanisms (unbolt and install)
  • Replacement of six instrument dry tubes [IG]
  • Replacement of Reactor Recirculation Pump B seal [SEAL]
  • Replacement of Reactor Recirculation Loop B flow control valve [FCV] actuator
  • Plugging of drain line appendages (3 total) on Reactor Recirculation Pump B
  • Local leak rate testing of the Reactor Water Cleanup [CE] suction line containment isolation valves OPDRV activities were controlled by a plant operating procedure, 101-020, " Operations with the Potential to Drain the Reactor Vessel", developed to ensure the proper implementation of EGM 11-003, Revision 3 interim actions

CAUSE OF EVENT

Implementation of EGM 11-003, Revision 3 interim actions during Refueling Outage 1R16 was a preplanned activity conducted in accordance with plant operating procedures As such, no cause determination was performed for this event

ANALYSIS OF EVENT

The OPDRV activities described in this report were accomplished using the interim actions provided in EGM 11- 003, Revision 3 PNPP adhered to the plain language meaning of OPDRV activities that could potentially result in draining or siphoning the Reactor Pressure Vessel (RPV) water level below the top of the fuel This included evolutions involving aligning and realigning plant systems prior to achieving steady-state water level control, without taking credit for mitigating measures PNPP also met the requirements which specify the minimum makeup flow rate and water inventory Further, an adequate defense in depth was maintained to minimize the potential for the release of fission products with Primary and Secondary Containment inoperable Since these measures were implemented, an adequate level of safety was provided during the performance of the OPDRV activities described in this report Infocollects Resource@nrc gov, and to the Desk Officer, Office of Information and Regulatory Affairs, 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

PNPP will submit a license amendment request to incorporate Technical Specification Task Force (TSTF) Traveler - 542, "Reactor Pressure Vessel Water Inventory Control" associated with generic resolution of this issue by December 20, 2017

PREVIOUS SIMILAR EVENTS

A review of LERs and the corrective action database for the past three years showed no similar events