05000305/LER-2007-008, Inadequate Emergency Diesel Generator Testing When Redundant Emergency Diesel Generator Was Inoperable
| ML072350120 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 08/17/2007 |
| From: | Hartz L Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 07-0544 LER 07-008-00 | |
| Download: ML072350120 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vi) 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(viii) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(B) |
| 3052007008R00 - NRC Website | |
text
Dotminion Dominion Energy Kewaunee, Inc.
N490 Highway 42, Kewaunee, WI 54216-9511 AUG 17 2007 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Serial No.
KPS/LIC/JG:
Docket No.
License No.
07-0544 RO 50-305 DPR-43 DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION LICENSEE EVENT REPORT 2007-008-00
Dear Sirs:
Pursuant to 10 CFR 50.73, Dominion Energy Kewaunee, Inc., hereby submits the following Licensee Event Report applicable to Kewaunee Power Station.
Report No. 50-305/2007-008-00 This report has been reviewed by the Plant Operating Review Committee and will be forwarded to the Management Safety Review Committee for its review.
If you have any further questions, please contact Mr. Jack Gadzala at (920) 388-8604.
Very truly yours, Leslie N. Hartz Site Vice President, Kewaunee Power Station Attachment Commitments made by this letter: NONE
Serial No. 07-0544 Page 2 of 2 cc:
Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. P. D. Milano Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-802 Washington, DC 20555-000 1 NRC Senior Resident Inspector Kewaunee Power Station
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-01 04 EXPIRES 6-30-2007 (6-2004)
Estimated burden per response to comply with this mandatory collection request: 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />.
Reported lessons learned are incorporated into the licensing process and fed back to industry.
LIEN SEE EVENT REPORT (LER)
Send comments regarding burden estimate to the Records and FOlAJPrivacy Service Branch LIC (T-5 F52), U.S. Nuclear Regulatory Commission, Washington. DC 20555-0001, or by internet e-(Servrefor required number of mail to infocollects@nrc.gov, and to the Desk Otticer, Office of Intormation and Regulatory (See rverseAffairs, NEOB-1 0202, (3150-0066), Office ot Management and Budget, Washington, DC 20503.
digits/characters for each block)
It a means used to impose an intormation collection does not display a currently valid 0MB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
FACILITY NAME (1)
DCE UBR()PG 3
Kewaunee Power Station050351o 3
TITLE (4)
Inadequate Emergency Diesel Generator Testing when Redundant Emergency Diesel Generator was Inoperable EVENT DATE (5) ___
LER NUMBER (6)
REPORT DATE (7)
OTHER FACILITIES INVOLVED (8)
SEUNIA IE FACILITY NAME DOCKET NUMBER MO DAY YEAR YEAR NUMBER NO MO DY YEAR 06 19 2007 2007 008 --
00 08 17 2007 FACILITY NAME jDOCKET NUMBER OPERATING N
THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CIFR,:(Check all that apply) (111)
MODE (9)
F20.2201 (b) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(B) 50.73(a)(2)(ix)(A)
POWER 10 20.2201 (d)
__20.2203(a)(4) 50.73(a)(2)(iii) 50.73(a)(2)(x)
LEVEL________
(110)_
20.2203(a)(1) 50.36(c)(1 )(i)(A) 50.73(a)(2)(iv)(A) 73.71 (a)(4) 20.2203(a)(2)(i)
__50.36(c)(1
)(ii)(A)
__50.73(a)(2)(v)(A) 73.71 (a)(5) 20.2203(a)(2)(ii) 50.36(c)(2) 50.73(a)(2)(v)(B)
- - OTE 20.2203(a)(2)(iii) 50.46(a)(3)(ii) 50.73(a)(2)(v)(C)
Specify in Abstract below or in 20.203()(2(iv 5073()(2)i)()
5.73a)()(v(D) __20.2203(a)(2)(iv)
X 50.73(a)(2)(i)(B)
__50.73(a)(2)(vi)(D 20.2203(a)(2)(vi)
X_ 50.73(a)(2)(i)(C) 50.73(a)(2)(viii)(
20.2203(a)(3)(i) 50.73(a)(2)(ii)(A)
I 50.73(a)(2)(viii)(B)
LICENSEE CONTACT FOR THIS LER (12)
NAME TELEPHONE NUMBER (Include Area Code)
Jack Gadzala 1(920) 388-8604 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
MANU-REPORTABLE IMANU-REPORTABLE CAS YTM COMPONENT FACTURER TO EPIX CAU SE SYSTEM ICOMPONENT FA OTURER TO EPIX SUPPLEMENTAL REPORT EXPECTED (14)
EXPECTED MONTH DAY YEAR I
SUBMISSION YES (If yes, complete EXPECTED SUBMISSION DATE).
XN AE(5 ABSTRACT On June 19, 2007, Dominion Energy Kewaunee was verbally informed that NRC staff determined that a load test of the emergency diesel generator (EDG) was needed for demonstrating compliance with Technical Specification (TS) 3.7.b.2. This determination was made in response to a review of past operating practice at Kewaunee Power Station (KPS) regarding performance of a daily test of the redundant (other) EDG required by TS 3.7.b.2 when one EDG is inoperable.
Historically, a start test of the redundant (other) EDG was performed to satisfy the daily test required by TS 3.7.b.2. However, the recent communications with NRC staff indicated that a start test of an EDG was insufficient for demonstrating compliance with TS 3.7.b.2. Rather, a load test in addition to a start test should have been performed.
A record review identified two recent instances where daily surveillance testing of the redundant (other) EDG required by TS 3.7.b.2 had been performed (May 31 and July 26, 2006). This daily testing did not include a load test. However, subsequent monthly start and load testing performed per TS 4.6.a.1 confirmed that the EDGs had been operable.U.S. NUCLEAR REGULATORY COMMISSION (1.2001)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DROCKET NUMBER (2 LER NUMBER (6)
PAGE (3)
YEAR SEQETA NUMBE 21f Kewaunee Power Station 05000305 1UETIA REVISIO 12007 008 0
TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
Event Description
On June 19, 2007, Dominion Energy Kewaunee was verbally informed that NRC staff determined that a load test of the emergency diesel generator (EDG) [DG] was needed for demonstrating compliance with Technical Specification (TS) 3.7.b.2. This determination was made in response to a review of past operating practice at Kewaunee Power Station (KPS) regarding performance of a daily test of the redundant (other) EDG required by TS 3.7.b.2 when one EDG is inoperable.
TS 3.7.b.2 states "One diesel generator may be inoperable for a period not exceeding 7 days provided the other diesel generator is tested daily to ensure OPERABILITY and the engineered safety features associated with this diesel generator are OPERABLE."
Historically, a start test of the redundant (other) EDG was performed to satisfy the daily test required by TS 3.7.b.2. However, recent communications with NRC staff indicated that a start test of an EDG was insufficient for demonstrating compliance with TS 3.7.b.2. Rather, a load test in addition to a start test should have been performed.
A record review identified two recent instances where daily surveillance testing of the redundant (other) EDG required by TS 3.7.b.2 had been performed (May 31 and July 26, 2006). This daily testing did not include a load test. However, subsequent monthly start and load testing performed per TS 4.6.a.1 confirmed that the EDGs had been operable.
A related event, regarding failure to perform the required test within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, was reported on September 11, 2006 (LER 2006-008-00) in accordance with 10 CFR 50.73(a)(2)(i)(B), "Any operation or condition which was prohibited by the plant's Technical Specifications."
Event and Safety Consequence Analysis:
On July 25, 2006, SW [BI] train B was declared inoperable. Each SW train supports its associated EDG by providing cooling water. With one train of SW inoperable, components supported by that train are also considered inoperable. Consequently, EDG B was also declared inoperable (cascading TS).
KPS TS do not contain an allowance analogous to Standard TS LCO 3.0.6 wherein only the support system LCO actions are required to be entered (except where explicitly stated). When one train of SW is inoperable at KPS, components supported by that train are inoperable, which includes the associated EDG. Such a condition requires entry into TS 3.7.b.2 for the inoperable EDG. TS 3.7.b.2 states "One diesel generator may be inoperable for a period not exceeding 7 days provided the other diesel generator is tested daily to ensure OPERABILITY and the engineered safety features associated with this diesel generator are OPERABLE."
With one EDG that has become or was rendered inoperable, KIPS TS require that the other EDG be tested to ensure operability as a condition of the seven day allowance for continued operation. This testing is intended to assure that the other EDG has not become inoperable due to a common cause failure. TS 3.7.b.2 does not specify what test must be performed to fulfill the testing requirement.
N RC FORM 366A (1 -2001)
NRIC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (1 -2001)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET NUMBER (2 LER NUMBER (6)
PAGE (3)
YEAR ISEQUENTIAL REVISION Kewaunee Power Station 05000305 1
NUBE NMER 3 of 3 12007 008 0
TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
Based on the historically understood intent of the TS when the plant was licensed, previous communications with the NRC, and industry experience with EDG operability, the KPS staff considered a start test of the EDGs to be an appropriate daily test to "ensure OPERABILITY."
Existing industry guidance describes that a load test to satisfy TS 3.7.b.2 reduces EDG availability because such a test renders both EDGs inoperable longer than necessary to demonstrate the operability of the DG.
In summary, testing of the operable EDG by starting the engine (without load testing) was considered appropriate for satisfying the requirement of KPS TS 3.7.b.2 and was consistent with industry practice for maintaining EDG reliability and in accordance with NU REG-1 431. Therefore, only a start test of the OPERABLE EDG had been performed in the past.
There were no events or conditions that could have prevented the fulfillment of the safety function of systems (opposite train equipment was operable) associated with this condition. Since EDG A was subsequently proven operable by starting and loading, there was no safety significance associated with this event.
Cause
The cause for only performing a start test rather than a load test was due to longstanding perception and practice that a start test was appropriate for fully satisfying the requirements of TS 3.7.b.2.
Based on the historically understood intent of the TS when the plant was licensed, previous communications with the NRC, and industry experience with EDG operability, the KPS staff considered a start test of the EDGs to be an appropriate daily test to "ensure OPERABILITY."
In addition to the industry guidance discussed previously, KPS staff believed a load test was not required based on previous correspondence. NRC Inspection Report 79-02 issued a Notice of Violation (NOV) to KPS for making the other EDG inoperable during a daily operability test that included a load test. The KPS response to the NOV stated that operating instructions prohibiting load testing of a DG, while the second DG was out of service, had been issued to prevent reoccurrence. The NRC acknowledged this corrective action in their NOV closeout letter dated November 21, 1979, and considered it to be adequate.
Therefore, based on industry guidance and previous correspondence, KPS' procedures did not require a load test of the remaining operable DG.
Corrective Actions
1.
The KPS Technical Requirements Manual (TRM) was revised to require performance of the surveillance requirement specified in TS 4.6.a.1 to satisfy the LCO requirements of TS 3.7.b.2. Performance of this testing would render both EDGs inoperable and require entry into TS LCO 3.0.c, "Standard Shutdown Sequence". However, the time required to perform this test is sufficiently short such that it would normally not require initiation of a TS required plant shutdown.
- 2.
As long term corrective action, a license amendment request is being prepared to propose revising the KPS TS to allow testing of the EDGs consistent with NUREG-1 431, Standard Technical Specifications.
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LER 2006-008-00, Diesel Generator Operability Testing Interval Exceeded