Transcript Containment Spray System

Regulatory Experience With
Preconditioning
ISTOG Winter Meeting Orlando Florida
January 24, 2008
Tim Smith
Dominion Energy Kewaunee
920-388-8660
[email protected]
1
What Happened?
• Quarterly Containment Spray pump and Valve
Test was scheduled following corrective
maintenance on a non-IST component.
• NRC Resident Inspector questioned Control Room
staff on preconditioning related to the use of IST
components for tagout boundaries for component
corrective maintenance.
2
Valves in Question
ICS-7A
Containment
ICS-7B
From
Refuel
Canal
ICS-201
Additive
Standpipe
LI
4131103
LI
18009
LI
18010
PI
11415
ICS-202
CI-1001A
To
SI
FI
41341
ICS-200B
ICS-6B
M
PI
11175
PI
4131702
CI-1001B
M
ICS-210B
ICS-5B
ICS-6A
FI
41340
M
ICS-200A
M
ICS-5A
Additive
Pump
Additive
Tank
From
RHR Hx
RHR-400B
M
M
ICS-210A
Filter
RWST
ICS-102
Gasket
Repair
Restricting
Orifice
PI
11429
PI
11174
PI
4131701
ICS Pump
1B
M
ICS
Pump 1A
ICS-2B
From
RHR Hx
RHR-400A
M
ICS-2A3
Initial Response
• IST Owner Contacted and replied that since
the valves were closed they were
preconditioned.
• Condition Report generated.
• IST Owner discussed issue with NRC
Resident.
4
First Discussion
• Provided Inspector Part 9900 and NUREG
1482
• Informed Inspector I couldn’t speak for
work control procedures
• Didn’t Mention Program Definition
5
Part 9900 Technical Guidance
Maintenance - Preconditioning of Structures, Systems, And
Components Before Determining Operability
Preconditioning – The alteration, variation,
manipulation, or adjustment of the physical
condition of an SSC before Technical
Specification surveillance or ASME Code
testing.
6
Part 9900 Technical Guidance
Acceptable Preconditioning – The alteration,
variation, manipulation, or adjustment of
the physical condition of an SSC before
Technical Specification surveillance or
ASME Code testing for the purpose of
protecting personnel or equipment or to
meet the manufacturer’s recommendations.
7
Part 9900 Technical Guidance
Unacceptable Preconditioning - The
alteration, variation, manipulation, or
adjustment of the physical condition of an
SSC before Technical Specification
surveillance or ASME Code testing that will
alter one or more of an SSC’s operational
parameters which results in acceptable test
results.
8
Part 9900 Technical Guidance
Unacceptable Preconditioning –
Could mask the actual as found condition of
the SSC and possibly result in an inability
to verify the operability of the SSC.
Could make it difficult to determine whether
the SSC would perform its intended
function during an event in which the SSC
might be needed.
9
Part 9900 Technical Guidance
• Does the practice performed ensure that
the SSC will meet testing acceptance
criteria?
• Would the SSC have failed the
surveillance without the preconditioning?
10
Part 9900 Technical Guidance
• Does the practice bypass or mask the asfound condition?
• Is preventive maintenance routinely
performed just before the testing?
• Is the preventive maintenance performed
only for scheduling convenience?
11
Operability Determination
• Compared historical stroke times
• Answered five questions from NRC
Inspection Manual Part 9900 to document
preconditioning was acceptable
12
Inspector Feedback
• Any IST Procedural Controls?
• Work Management Procedural Controls?
• How can you justify acceptability of
preconditioning after the fact?
13
NUREG 1482 Para. 3.5.4
• “the staff considers unacceptable
preconditioning of pumps and valves in the
IST program to include such activities as
…(2) Operation of a pump or valve shortly
before a test, if such operation could be
avoided through plant procedures with
personnel and plant safety maintained.”
14
KPS “OLD” Program Definition
• Preconditioning – The act of exercising or
placing a component in service for the
purpose of enhancing the results of an
inservice test. The act of preconditioning
could mask a degrading condition that may
otherwise be detected when testing a
component in the “as found” condition.
15
KPS “Old” Program Definition
(Cont.)
• The exercising of a component when
required by an Operations Procedure for
system reconfiguration shall not constitute
or be considered as preconditioning. It is an
expectation to perform tests in the “as
found” condition but not a Code
requirement except for relief valves.
Activities, which may be considered as
preconditioning, should be justified.
16
Subsequent Discussions
• Plant Manager initially agreed that what
occurred sounded like preconditioning
• Industry Response (ISTOG) provided data
to the contrary. None of the responses
(approximately 20) considered
preconditioning in tagging evolutions
17
Subsequent Discussions
• Senior Resident presented to Plant
Management that IST “Didn’t care about
preconditioning because it isn’t a Code
requirement.”
• Provided Junior Resident information from
2002 Pump and Valve Symposium
• Seabrook Resident “Contacted”
18
Subsequent Discussions
• It became apparent that the KPS response to
the original concern was not done correctly.
• Each piece of the puzzle was presented to
the Resident by one group or individual at a
time. This led to more questions and
misunderstandings.
• A more unified approach including all work
groups may have prevented violation.
19
Subsequent Discussions
• Potential Work Planning Procedure
Violation
Involved Discussion with Work Week
Coordinators and Supervisor/Manager
Resulted in the conclusion that no
procedural violation occurred
20
Inadequate Procedure Violation
“The inspectors determined, following review
of plant procedures, interviews with plant
management, and a review of NRC
guidance on preconditioning, that plant
procedures were not adequate to support
proper consideration of preconditioning.
21
Inadequate Procedure Violation
These procedures did not discuss or
provide a definition for acceptable versus
unacceptable preconditioning, did not
provide guidance on the scope of
components which should be included in
such consideration, and did not identify
which personnel were responsible for the
consideration of potential
preconditioning.
22
Inadequate Procedure Violation
Therefore, the inspectors determined that,
due to inadequate procedures, adequate
consideration of preconditioning of ICS-202
and ICS-2B during maintenance activities
was not given before the surveillance
procedure that tested these valves was
conducted”
23
Corrective Actions
• Revised definition of preconditioning in IST
Program to match Part 9900 Guidance
• “Benchmarked” Seabrook’s Preconditioning
Procedural Guidance
• Revised work management procedures
• Added IST Program Technical Position
24
“As Found”
The physical state of a component after a
period of normal service without repairs or
adjustments that could affect its operation.
Normal service includes component
operation when required by an operating
procedure or non-routine operation of the
component to establish required system
conditions for corrective maintenance
activities.
25
Corrective Actions
• Key is to document potential concerns in
work planning documents and/or
procedures
• Raise Awareness to ensure everyone has a
similar understanding
26
Continuing Evaluation
• Reviewing Scheduling
Typically maintenance items performed
early in work week and surveillances
performed late in work week. This results in
many preconditioning concerns/questions.
Reversing schedule should minimize
preconditioning concerns.
27
Do Over???
• NRC 95002 Inspection Team Questioned
EDG Test Sequence
Fire Protection Trip Test performed prior to
Quarterly “slow” start test that timed an IST
cooling water valve.
28
Do Over???
• 2001 Evaluation of test sequence “Missed
the Mark”
• Requested meeting with Senior Resident to
better understand concern
• Senior Resident Informed 95002 team that
sequence was “Acceptable Preconditioning”
based upon difference in periodicity of tests
29
Do Over???
• NRC Senior Resident Informed KPS that
we may have a “Risk” violation based upon
excessive unavailability time caused by test
sequence
• Recommended evaluating merging of tests
• Will monitor our evaluation/response
30
Questions?
• Does ISTOG want to pursue submittal of
position to EPRI?
• Has anyone has similar experiences?
• Is there value in distributing as INPO OE?
31