ML13066A331

Regulatory Conference Presentation 3-12-2013

ML13066A331
Person / Time
Site:	Kewaunee
Issue date:	03/07/2013
From:	Dominion Energy Kewaunee
To:	NRC/RGN-III/DRMA
References
EA-12-272
Download: ML13066A331 (20)

Text

Kewaunee Power Kewaunee Power Station NRC Region III NRC Region III Regulatory Conference Loss of PPCS Indication For SPING RMs

© 2007 Dominion

Agenda g

• Opening remarks p

g

• Event description R

l t i

ifi

• Regulatory significance

• Conclusion

• Closing remarks 2

© 2007 Dominion

Opening Remarks p

g Dominion is committed to preserving the health and f t f th bli safety of the public 3

© 2007 Dominion

Opening Remarks p

g

• Preliminary Violation y

• 10 CFR 50.54 (q)(2) & 10 CFR 50.47 (b)(4)

- Kewaunee Power Stations unidentified loss of SPING indication on the PPCS and RADSERV stations precluded action to restore the capability to classify EALs RG1.1 p

y y

and RS1.1

• Agree performance deficiency existed

• Differ with significance of finding

• Differ with significance of finding 4

© 2007 Dominion

Event Description p

• Hardware failure

• RADSERV

• Interface between SPING units and PPCS

• Additional Data Acquisition Modules lost

• Local SPING indication remained available

• Upon discovery of RADSERV failure, restoration completed same day 5

© 2007 Dominion

Regulatory Significance g

y g

RADSERV failure-Hardware issue P

i h

d f il h

b Previous hardware failures have been evaluated under 10 CR 50 47(b)(8) 10 CR 50.47(b)(8) 6

© 2007 Dominion

Regulatory Significance g

y g

5.8 10 CFR 50.47(b)(8), Emergency Facilities and Equipment PLANNING STANDARD:

Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

PS FUNCTIONS:

1.

Adequate facilities are maintained to support emergency response.

2.

Adequate equipment is maintained to support 2.

Adequate equipment is maintained to support emergency response.

7

Regulatory Significance g

y g

• NUREG 0654

• H. Emergency Facilities and Equipment

• 5.b. radiological monitors, (e.g., process, area, emergency, effluent, wound and portable monitors and sampling equipment);

8

© 2007 Dominion

Regulatory Significance g

y g

10 CFR 50.47 (b)(8)

( )( )

• White threshold

- Equipment necessary to implement the E-plan is not available or not functional

• Period of longer than 7 days from time of discovery

• Without Compensatory Measures 9

© 2007 Dominion

Regulatory Significance g

y g

10 CFR 50.47 (b)(8)

( )( )

• Green threshold

- A significant amount of equipment necessary to implement the E-plan is not available or functional to the extent that any key ERO member could not perform his/her assigned p

g functions, in the absence of compensatory measures.

10

© 2007 Dominion

Regulatory Significance g

y g

IMC 0609 Basis IMC 0609 Basis Not all hardware failures under control of licensee Assessed by scope of outage from discovery

• RADSERV failure

• Hardware failure y

• Restored same day of discovery 11

© 2007 Dominion

Regulatory Significance g

y g

• Industry OE y

• Columbia Generating Station (05000397/2012502)

Fi di St d

d Si ifi Finding Standard Significance Effluent Monitor Classification Thresholds 10 CFR 50.47(b)(4)

White Inaccurate methods for assessing the offsite consequences of a radiological release were inaccurate 10 CFR 50.47(b)(9)

White Reactor Building High Range Exhaust monitor was unavailable 38 of 149 months and corrective actions were ineffective in restoring the availability and reliability of the 10 CFR 50.47(b)(8)

Green - Licensee Identified 12

© 2007 Dominion availability and reliability of the monitor

Regulatory Significance g

y g

• Columbia Green Finding

• 10 CFR 50.47 (b)(8)

• Failed to provide and maintain RX Building Failed to provide and maintain RX Building High Range Exhaust RM

• Unavailable 38 out of 149 months

• Planning Standard determined to be degraded C

i t

ti l d l

• Causing potential delays

• Classification and radiological assessments 13

© 2007 Dominion

Regulatory Significance g

y g

• Columbia White Finding

• Finding

• 10 CFR 50.54(q) and 10 CFR 50.47(b)(4)

• Failure to maintain a standard EAL scheme

• Inappropriately calculated and changed RM thresholds for Site Area Emergency and thresholds for Site Area Emergency and General Emergency 14

© 2007 Dominion

Additional Information

• Actual duration of vulnerability

• Fast breaking LOCA

• RCS > 350°F on 3/24/11 at 0300 RCS 350 F on 3/24/11 at 0300

• Six days

• Classification Methodology

• Classification Methodology

• Shift Manager perspective 15

© 2007 Dominion

Additional Information

• EAL scheme diversification

• NEI 99-01 Rev. 4

- Fission product barrier challenges

- Effluent ICs do not stand alone

- EOPs and CSF reduce ambiguity and time

• NRC Regulatory Analysis of NEI 99-01

- Plant conditions more timely than radiological measurements radiological measurements 16

© 2007 Dominion

Root Cause Evaluation RC-1 Absence of a programmatic requirement to periodically monitor RADSERV and to pe od ca y o

to S

V a d PPCS RC-2 RC 2 System platform is obsolete and difficult to maintain to maintain 17

© 2007 Dominion

Conclusions

• RADSERV failure was a hardware issue

• Restored same day as discovery

• 10 CFR 50 47 (b)(8) Green Finding

• 10 CFR 50.47 (b)(8) Green Finding

• Precedence of the Columbia finding 18

© 2007 Dominion

Closing Remarks g

• Dominion Acknowledges g

• Degraded planning standard

• Importance of equipment associated with EP Importance of equipment associated with EP

• Violation has occurred

• Corrective actions Corrective actions 19

© 2007 Dominion

Closing Remarks g

Dominion is committed to preserving the health and safety of the public safety of the public 20

© 2007 Dominion