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| {{#Wiki_filter:CONTACT: Mark Tonacci, NRR/DIRS 301-415-4045August 9, 2007MEMORANDUM TO:James W. Andersen, ChiefPerformance Assessment Branch Division of Inspection and Regional Support Office of Nuclear Reactor RegulationFROM: Mark E. Tonacci, Reactor Operations Engineer | | {{#Wiki_filter:August 9, 2007 MEMORANDUM TO: James W. Andersen, Chief Performance Assessment Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation FROM: Mark E. Tonacci, Reactor Operations Engineer /RA/ |
| /RA/Performance Assessment BranchDivision of Inspection and Regional Support Office of Nuclear Reactor Regulation
| | Performance Assessment Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation |
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| ==SUBJECT:== | | ==SUBJECT:== |
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| ==SUMMARY== | | ==SUMMARY== |
| ON THE REACTOR OVERSIGHTPROCESS APPEAL OF A FREQUENTLY ASKED QUESTION ON THE MITIGATING SYSTEMS PERFORMANCE INDEX HELD ON AUGUST 2, 2007On August 2, 2007, the staff hosted a public meeting appeal of a frequently asked question onthe mitigating systems performance index. The attendance list for the meeting is contained in . The agenda for the meeting is contained in Enclosure 2.The purpose of the meeting was to allow the staff and the licensee for the Kewaunee PowerStation to present information to the NRC Director of the Division of Inspection and Regional Support on a Frequently Asked Question (FAQ) concerning the Emergency AC Power within the Mitigating Systems Performance Index (MSPI). The Director will make a determination on how the FAQ will be resolved. FAQ 69.2 describes the discovery of a small fuel oil leak on an emergency diesel generator for the Kewaunee Station that was found by an operator on June 28, 2006. The emergency diesel was run for short periods during periodic monthly surveillances several times after the leak was found on the tubing fitting when, during an engine run on August 17, 2006, leakage from the fitting increased to the point where the licensee declared the EDG inoperable. The leak was repaired and the engine was operable the following day. Approximately 51 days lapsed between when the leak was found and when the licensee declared the emergency diesel inoperable.The issue of contention between the licensee and staff centers on the meaning of the term"discovery" as used in the MSPI guidance documentation but which is not explicitly defined. | | ON THE REACTOR OVERSIGHT PROCESS APPEAL OF A FREQUENTLY ASKED QUESTION ON THE MITIGATING SYSTEMS PERFORMANCE INDEX HELD ON AUGUST 2, 2007 On August 2, 2007, the staff hosted a public meeting appeal of a frequently asked question on the mitigating systems performance index. The attendance list for the meeting is contained in . The agenda for the meeting is contained in Enclosure 2. |
| The licensee presented their position that "discovery" means, in essence, after they became aware of a degraded condition that impacted operability, and after they actually recognized the significance of the condition, not when they should have recognized the significance of the condition. The staff presented their position that "discovery," as interpreted from this guidance, means that if a licensee finds a non-conforming or degraded condition that would call into question the potential for impact on operability/unavailability, and has documented this degraded condition with a condition report, or some other similar report (whether or not they enter it into the corrective action program), then this would constitute "discovery" and from that J. Andersenmoment forward, in the absence of an operability assessment that would conclude otherwise,the staff would expect unplanned unavailability to be accrued (if the equipment was actually inoperable) until the equipment is fixed and returned to service. Using the staff position, unplanned unavailability of 51 days, not the one day for repairs as recorded by the licensee, should be included in the performance indicator since the engine was unavailable from the pointthe leak was found until it ultimately failed.The NRC Director of the Division of Inspection and Regional Support will make a decision onthis FAQ in the near term and advise affected parties. According to the NEI 99-02 appeal guidance, the impact of this decision is limited to this Kewaunee FAQ 69.2 and will not change guidance in NEI 99-02. | | The purpose of the meeting was to allow the staff and the licensee for the Kewaunee Power Station to present information to the NRC Director of the Division of Inspection and Regional Support on a Frequently Asked Question (FAQ) concerning the Emergency AC Power within the Mitigating Systems Performance Index (MSPI). The Director will make a determination on how the FAQ will be resolved. FAQ 69.2 describes the discovery of a small fuel oil leak on an emergency diesel generator for the Kewaunee Station that was found by an operator on June 28, 2006. The emergency diesel was run for short periods during periodic monthly surveillances several times after the leak was found on the tubing fitting when, during an engine run on August 17, 2006, leakage from the fitting increased to the point where the licensee declared the EDG inoperable. The leak was repaired and the engine was operable the following day. Approximately 51 days lapsed between when the leak was found and when the licensee declared the emergency diesel inoperable. |
| | The issue of contention between the licensee and staff centers on the meaning of the term discovery as used in the MSPI guidance documentation but which is not explicitly defined. |
| | The licensee presented their position that discovery means, in essence, after they became aware of a degraded condition that impacted operability, and after they actually recognized the significance of the condition, not when they should have recognized the significance of the condition. The staff presented their position that discovery, as interpreted from this guidance, means that if a licensee finds a non-conforming or degraded condition that would call into question the potential for impact on operability/unavailability, and has documented this degraded condition with a condition report, or some other similar report (whether or not they enter it into the corrective action program), then this would constitute "discovery" and from that CONTACT: Mark Tonacci, NRR/DIRS 301-415-4045 |
| | |
| | J. Andersen moment forward, in the absence of an operability assessment that would conclude otherwise, the staff would expect unplanned unavailability to be accrued (if the equipment was actually inoperable) until the equipment is fixed and returned to service. Using the staff position, unplanned unavailability of 51 days, not the one day for repairs as recorded by the licensee, should be included in the performance indicator since the engine was unavailable from the point the leak was found until it ultimately failed. |
| | The NRC Director of the Division of Inspection and Regional Support will make a decision on this FAQ in the near term and advise affected parties. According to the NEI 99-02 appeal guidance, the impact of this decision is limited to this Kewaunee FAQ 69.2 and will not change guidance in NEI 99-02. |
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| ==Enclosures:== | | ==Enclosures:== |
| 1.Attendance List 2.Agenda 3.Kewaunee Power Station Appeal of FAQ 69.2 J. Andersenwould conclude otherwise, the staff would expect unplanned unavailability to be accrued (if theequipment was actually inoperable) until the equipment is fixed and returned to service. Using the staff position, unplanned unavailability of 51 days, not the one day for repairs as recorded by the licensee, should be included in the performance indicator since the engine was unavailable from the point the leak was found until it ultimately failed.The NRC Director of the Division of Inspection and Regional Support will make a decision onthis FAQ in the near term and advise affected parties. According to the NEI 99-02 appeal guidance, the impact of this decision is limited to this Kewaunee FAQ 69.2 and will not change guidance in NEI 99-02. | | : 1. Attendance List |
| | : 2. Agenda |
| | : 3. Kewaunee Power Station Appeal of FAQ 69.2 |
| | |
| | J. Andersen would conclude otherwise, the staff would expect unplanned unavailability to be accrued (if the equipment was actually inoperable) until the equipment is fixed and returned to service. Using the staff position, unplanned unavailability of 51 days, not the one day for repairs as recorded by the licensee, should be included in the performance indicator since the engine was unavailable from the point the leak was found until it ultimately failed. |
| | The NRC Director of the Division of Inspection and Regional Support will make a decision on this FAQ in the near term and advise affected parties. According to the NEI 99-02 appeal guidance, the impact of this decision is limited to this Kewaunee FAQ 69.2 and will not change guidance in NEI 99-02. |
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| ==Enclosures:== | | ==Enclosures:== |
| 1.Attendance List 2.Agenda 3.Kewaunee Power Station Appeal of FAQ 69.2DISTRIBUTION | | : 1. Attendance List |
| :PUBLIC DRoberts ABoland AVegel AHowell BHolianCCasto CPedersonDLew DChamberlainHChristensen ISchoenfeldJShea JCliffordKKennedy THsiaMGamberoni RCanianoSWest VMcCreeDDube JAndersenPAppignani JThompsonSBurgess JAshcraftRGramm RWolfgangSPanier
| | : 2. Agenda |
| | : 3. Kewaunee Power Station Appeal of FAQ 69.2 DISTRIBUTION: |
| | PUBLIC DRoberts ABoland AVegel AHowell BHolian CCasto CPederson DLew DChamberlain HChristensen ISchoenfeld JShea JClifford KKennedy THsia MGamberoni RCaniano SWest VMcCree DDube JAndersen PAppignani JThompson SBurgess JAshcraft RGramm RWolfgang SPanier ECollins Package Accession Number: ML072190038; Memo ML072190015; Enclosures 3 ML072190461 OFFICE DIRS/IPAB DIRS/IPAB NAME MTonacci JAndersen (DHickman for) |
| | DATE 08/09/07 08/09/07 OFFICIAL RECORD COPY |
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| | ATTENDANCE LIST INDUSTRY/STAFF ROP PUBLIC APPEAL MEETING NAME AFFILIATION |
| | : 1. John Butler NEI |
| | : 2. Julie Keys NEI |
| | : 3. Tom Webb Dominion |
| | : 4. Duane Kanitz STARS |
| | : 5. Don Olson Dominion |
| | : 6. Paul Miller Dominion |
| | : 7. Ken Heffner Progress |
| | : 8. Stephen Pannier NRC |
| | : 9. Bob Gramm NRC |
| | : 10. Arthur Salomon NRC |
| | : 11. John Thompson NRC |
| | : 12. Joe Ashcraft NRC |
| | : 13. Elmo Collins NRC |
| | : 14. Mark Tonacci NRC |
| | : 15. Peter Appignani NRC |
| | : 16. Bob Wolfgang NRC |
| | : 17. Sonia Burgess NRC |
| | : 18. Don Dube NRC Enclosure 1 |
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| ECollinsPackage Accession Number: ML072190038; Memo ML072190015;Enclosures 3 ML072190461OFFICEDIRS/IPABDIRS/IPABNAMEMTonacciJAndersen(DHickman for)DATE08/09/0708/09/07 OFFICIAL RECORD COPY ATTENDANCE LISTINDUSTRY/STAFF ROP PUBLIC APPEAL MEETING NAME AFFILIATION1.John ButlerNEI2.Julie KeysNEI 3.Tom Webb Dominion 4.Duane KanitzSTARS 5.Don OlsonDominion 6.Paul MillerDominion 7.Ken HeffnerProgress 8.Stephen PannierNRC 9.Bob Gramm NRC 10.Arthur SalomonNRC 11.John ThompsonNRC 12.Joe AshcraftNRC 13.Elmo CollinsNRC 14.Mark TonacciNRC 15.Peter AppignaniNRC 16.Bob WolfgangNRC 17.Sonia BurgessNRC 18.Don DubeNRC APPEAL MEETING AGENDA FOR FREQUENTLY ASKED QUESTION 69.2,DISCOVERY OF A FUEL OIL LEAK ON AN EMERGENCY DIESEL GENERATOR FOR THE KEWAUNEE STATIONAugust 2, 20071:00 - 2:30 p.m. 1:00 - 1:05 p.m.Introductions and Explanation of FAQ Appeal Process (Appendix E to NEI 99-02) 1:05 - 1:30 p.m.Overview of FAQ 69.2, Kewaunee Licensee Discussion 1:30 - 1:55 p.m.NRC Staff Discussion 1:55 - 2:15 p.m.Questions and Clarifications 2:15 - 2:25 p.m.Public Comments 2:25 - 2:30 p.m.Final Comments 2:30 p.m.Adjourn}}
| | APPEAL MEETING AGENDA FOR FREQUENTLY ASKED QUESTION 69.2, DISCOVERY OF A FUEL OIL LEAK ON AN EMERGENCY DIESEL GENERATOR FOR THE KEWAUNEE STATION August 2, 2007 1:00 - 2:30 p.m. |
| | 1:00 - 1:05 p.m. Introductions and Explanation of FAQ Appeal Process (Appendix E to NEI 99-02) 1:05 - 1:30 p.m. Overview of FAQ 69.2, Kewaunee Licensee Discussion 1:30 - 1:55 p.m. NRC Staff Discussion 1:55 - 2:15 p.m. Questions and Clarifications 2:15 - 2:25 p.m. Public Comments 2:25 - 2:30 p.m. Final Comments 2:30 p.m. Adjourn Enclosure 2}} |
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Text
August 9, 2007 MEMORANDUM TO: James W. Andersen, Chief Performance Assessment Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation FROM: Mark E. Tonacci, Reactor Operations Engineer /RA/
Performance Assessment Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
SUBJECT:
PUBLIC MEETING
SUMMARY
ON THE REACTOR OVERSIGHT PROCESS APPEAL OF A FREQUENTLY ASKED QUESTION ON THE MITIGATING SYSTEMS PERFORMANCE INDEX HELD ON AUGUST 2, 2007 On August 2, 2007, the staff hosted a public meeting appeal of a frequently asked question on the mitigating systems performance index. The attendance list for the meeting is contained in . The agenda for the meeting is contained in Enclosure 2.
The purpose of the meeting was to allow the staff and the licensee for the Kewaunee Power Station to present information to the NRC Director of the Division of Inspection and Regional Support on a Frequently Asked Question (FAQ) concerning the Emergency AC Power within the Mitigating Systems Performance Index (MSPI). The Director will make a determination on how the FAQ will be resolved. FAQ 69.2 describes the discovery of a small fuel oil leak on an emergency diesel generator for the Kewaunee Station that was found by an operator on June 28, 2006. The emergency diesel was run for short periods during periodic monthly surveillances several times after the leak was found on the tubing fitting when, during an engine run on August 17, 2006, leakage from the fitting increased to the point where the licensee declared the EDG inoperable. The leak was repaired and the engine was operable the following day. Approximately 51 days lapsed between when the leak was found and when the licensee declared the emergency diesel inoperable.
The issue of contention between the licensee and staff centers on the meaning of the term discovery as used in the MSPI guidance documentation but which is not explicitly defined.
The licensee presented their position that discovery means, in essence, after they became aware of a degraded condition that impacted operability, and after they actually recognized the significance of the condition, not when they should have recognized the significance of the condition. The staff presented their position that discovery, as interpreted from this guidance, means that if a licensee finds a non-conforming or degraded condition that would call into question the potential for impact on operability/unavailability, and has documented this degraded condition with a condition report, or some other similar report (whether or not they enter it into the corrective action program), then this would constitute "discovery" and from that CONTACT: Mark Tonacci, NRR/DIRS 301-415-4045
J. Andersen moment forward, in the absence of an operability assessment that would conclude otherwise, the staff would expect unplanned unavailability to be accrued (if the equipment was actually inoperable) until the equipment is fixed and returned to service. Using the staff position, unplanned unavailability of 51 days, not the one day for repairs as recorded by the licensee, should be included in the performance indicator since the engine was unavailable from the point the leak was found until it ultimately failed.
The NRC Director of the Division of Inspection and Regional Support will make a decision on this FAQ in the near term and advise affected parties. According to the NEI 99-02 appeal guidance, the impact of this decision is limited to this Kewaunee FAQ 69.2 and will not change guidance in NEI 99-02.
Enclosures:
- 1. Attendance List
- 2. Agenda
- 3. Kewaunee Power Station Appeal of FAQ 69.2
J. Andersen would conclude otherwise, the staff would expect unplanned unavailability to be accrued (if the equipment was actually inoperable) until the equipment is fixed and returned to service. Using the staff position, unplanned unavailability of 51 days, not the one day for repairs as recorded by the licensee, should be included in the performance indicator since the engine was unavailable from the point the leak was found until it ultimately failed.
The NRC Director of the Division of Inspection and Regional Support will make a decision on this FAQ in the near term and advise affected parties. According to the NEI 99-02 appeal guidance, the impact of this decision is limited to this Kewaunee FAQ 69.2 and will not change guidance in NEI 99-02.
Enclosures:
- 1. Attendance List
- 2. Agenda
- 3. Kewaunee Power Station Appeal of FAQ 69.2 DISTRIBUTION:
PUBLIC DRoberts ABoland AVegel AHowell BHolian CCasto CPederson DLew DChamberlain HChristensen ISchoenfeld JShea JClifford KKennedy THsia MGamberoni RCaniano SWest VMcCree DDube JAndersen PAppignani JThompson SBurgess JAshcraft RGramm RWolfgang SPanier ECollins Package Accession Number: ML072190038; Memo ML072190015; Enclosures 3 ML072190461 OFFICE DIRS/IPAB DIRS/IPAB NAME MTonacci JAndersen (DHickman for)
DATE 08/09/07 08/09/07 OFFICIAL RECORD COPY
ATTENDANCE LIST INDUSTRY/STAFF ROP PUBLIC APPEAL MEETING NAME AFFILIATION
- 1. John Butler NEI
- 2. Julie Keys NEI
- 3. Tom Webb Dominion
- 4. Duane Kanitz STARS
- 5. Don Olson Dominion
- 6. Paul Miller Dominion
- 7. Ken Heffner Progress
- 8. Stephen Pannier NRC
- 9. Bob Gramm NRC
- 10. Arthur Salomon NRC
- 11. John Thompson NRC
- 12. Joe Ashcraft NRC
- 13. Elmo Collins NRC
- 14. Mark Tonacci NRC
- 15. Peter Appignani NRC
- 16. Bob Wolfgang NRC
- 17. Sonia Burgess NRC
- 18. Don Dube NRC Enclosure 1
APPEAL MEETING AGENDA FOR FREQUENTLY ASKED QUESTION 69.2, DISCOVERY OF A FUEL OIL LEAK ON AN EMERGENCY DIESEL GENERATOR FOR THE KEWAUNEE STATION August 2, 2007 1:00 - 2:30 p.m.
1:00 - 1:05 p.m. Introductions and Explanation of FAQ Appeal Process (Appendix E to NEI 99-02) 1:05 - 1:30 p.m. Overview of FAQ 69.2, Kewaunee Licensee Discussion 1:30 - 1:55 p.m. NRC Staff Discussion 1:55 - 2:15 p.m. Questions and Clarifications 2:15 - 2:25 p.m. Public Comments 2:25 - 2:30 p.m. Final Comments 2:30 p.m. Adjourn Enclosure 2
