05000321/LER-2016-002

LER-2016-002, Performance of Operations With the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment

Edwin I. Hatch Nuclear Plant Unit 1
Event date:	02-13-2016
Report date:	04-11-2016
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3212016002R00 - NRC Website

LER 16-002-00 for E.I Hatch, Unit 1, Regarding Performance of Operations With the Potential to Drain the Reactor Vessel (OPDRV) Without Secondary Containment

ML16103A138
Person / Time
Site:	Hatch
Issue date:	04/11/2016
From:	Pierce C R Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-16-0315 LER 16-002-00
Download: ML16103A138 (6)

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Edwin I. Hatch Nuclear Plant Unit 1 05000 321

PLANT AND SYSTEM IDENTIFICATION

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

DESCRIPTION OF EVENT

In February 2016, with Unit 1 at 0 percent rated thermal power due to a scheduled refueling outage, operations with the potential to drain the reactor vessel (OPDRV) activities were performed while 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 Technical Specifications. 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 while the NRC staff and Boiling Water Reactor Owner's Group finalize a generic solution for TS changes. The required interim actions specified in the EGM were incorporated into plant procedure 31GO-OPS-025-0 "Operations With The Potential To Drain The Reactor Vessel".

This procedure was utilized during the following three occasions during the 2016 Unit 1 Refueling Outage:

Table 1: Hatch Unit 1 OPDRVs Performed February 2016 OPDRV Activity Start End LPRM replacement activity 02/13/2016, 2130 EST 02/15/2016, 0149 EST CRD push-pull activity 02/15/2016, 1213 EST 02/16/2016, 0740 EST CRD insert / re-couple activity 02/17/2016, 1547 EST 02/18/2016, 1038 EST

CAUSE OF EVENT

Implementation of the required EGM 11-003, Revision 3 interim actions during the 2016 Unit 1 Refueling Outage was a planned activity. As such, no cause determination was performed for the events.

REPORT ABILITY 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 or siphoning the reactor pressure vessel (RPV) water level below the top of the fuel. Hatch also met the requirements which specify the minimum makeup flow rate and water inventory based on OPDRV activities with long drain down times.

Furthermore, 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 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 OPDVR activities described in this report Based on this information, the performance of these OPDRV activities were determined to have a very low safety significance.

CORRECTIVE ACTIONS

Consistent with the guidance given in EGM 11-003 Revision 3, Hatch will submit a licensee amendment request (LAR) following NRC approval of the Technical Specifications Task Force (TSTF) Traveler associated with generic resolution of this issue within the time restraints given in the EGM.

ADDITIONAL INFORMATION

Other Systems Affected: None.

Failed Components Information: None.

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

Previous Similar Events:

On February 16, 2015, February 20, February 18 through 19, 2015, and February 23 through 24, 2015, OPDRV activities were performed while Unit 2 was in Refueling Mode (Mode 5) without an operable secondary containment These activities are prohibited by Technical Specifications (TS) 3.6.4.1. However, NRC guidance provided in Regulatory Issue Summary (RIS) 2012-11 and in Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 allowed the implementation of interim actions as an alternative to full compliance. An adequate defensed 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 the movement of irradiated fuel with the spent fuel storage pool gates removed in Mode 5. The associated Technical Specification Task Force (TSTF) Traveler is not yet available as a Technical Specification consolidated line item improvement process (CLIIP) for use by licensees. For that reason, the corrective actions from this event would not be expected to have prevented the condition reported in this LER.