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| {{#Wiki_filter:Prairie Island Nuclear Generating Plant NRC Region III Regulatory Conference Emergency Action Level Scheme Issue May 11, 2010 2 Agenda*Opening Remarks -Mark Schimmel*Sequence of Events -Tim Blake *Causes and Corrective Actions -Tim Blake*Regulatory Significance -Jon Anderson*Barriers and Operator Actions -Terry Bacon*Summary -Mark Schimmel*Closing Remarks -Dennis Koehl 3 Opening Remarks*Prairie Island (PINGP) takes its obligation to protect the health and safety of the public very seriously*Performance Deficiency-Failure to follow and maintain in effect emergency plans which use a standard emergency classification and action level scheme-We agree with the performance deficiency *Causes and Corrective Actions*Regulatory Significance 4 Sequence of Events, Causes, and Corrective Actions Tim Blake, Fleet Emergency Preparedness Manager 5 EAL Description*Initiating Condition RA1 -Any UNPLANNED Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the Offsite Dose Calculation Manual (ODCM) Specification for 15 Minutes or Longer -RA1.1 -Applicable to routine release pathways, for which a discharge permit is normally prepared-RA1.2 -Applicable to non-routine release pathways, for which a discharge permit would not normally be prepared-RA1.3 -Confirmed sample analysis Sequence of Events Timeline 6 2009Decision to submit by end of 3 rd QTREAL Rol lback 2004Rev 3 of EALs Implemented 2008 2006Rev 1 of EALs implemented Wrong PictureEvaluating Industry OE Wrong PictureKewaunee OEPoint Beach withdraws submittal"No Deviations"StandardRev 0 of EALs implementedEvaluating Operator Feedback Wrong Picture 2005 2007New EALs SubmittedNo Justification forRA1.3 use submitted to NRCUsed Ambiguous Thresholds Blue comments are missed opportunities Revision 3 to EALs*Completed in June 2009*Note related to use of RA1.3 for offscale radiation monitors removed from Table R-1 *ALERT threshold changed to an unambiguous value for R-18*Offsite Dose Calculation Manual alarm setpoints for R-25 and R-31 were reduced so these radiation monitors would read on scale at 200 X the alarm setpoint 7 | | {{#Wiki_filter:Prairie Island Nuclear Generating Plant NRC Region III Regulatory Conference Emergency Action Level Scheme Issue May 11, 2010 |
| 8 Missed Opportunities*Writers failed to use specific numbers for thresholds, instead used "200 X ODCM limits"*Literal application of fleet expectation for deviations*Did not document and justify the use of EAL RA1.3 as an alternative entry into an ALERT for off scale radiation monitor readings *Inadequate assessment of feedback and industry operating experience Root Cause Evaluation*Root Cause -Existing procedure did not provide adequate guidance for changing EALs or EAL schemes*Contributing Cause-Change in standard and subsequent scope without sufficient resources *Extent of Condition-All extent of condition actions completed -No other examples of the condition found*Extent of Cause 9
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| 10 Interim Actions Taken*EAL scheme change to NEI 99-01, Rev 5 will not be made until procedure revisions are implemented*Reviewed past 10 CFR 50.54(q) evaluations *New 10 CFR 50.54(q) evaluations associated with risk significant planning standard changes require independent external reviews until the fleet procedure is revised 11*Create a fleet procedure for changing EALsand EAL schemes with detailed guidance for:-Proposed staffing levels and time allowances to develop and validate major changes-Acceptable methods for meeting or changing EAL entry condition thresholds when the setpoint is beyond indication range -Engineering reviews for changes requiring process indication or environmental monitoring-Additional validation reviews-Justification of changes in preparation for NRC submittals*Revise EALsto include unambiguous threshold values Corrective Actions 12 Regulatory SignificanceJon Anderson -Regulatory Affairs Manager Regulatory Significance EALsThresholds Bases Radiation Monitors RA1.1 VALID reading on any effluent monitor that exceeds 200 times the alarm setpoint established by a current radioactivity discharge permit for 15 minutes or longer Monitoring on routine release pathways for which a discharge permit is normally prepared Addresses monitoring on non-routine release pathways for which
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| a discharge permit is not normally prepared R-18 RA1.2 VALID reading on one or more radiation monitors that exceeds 200 times the alarm setpoint for 15
| | Agenda |
| | * Opening Remarks - Mark Schimmel |
| | * Sequence of Events - Tim Blake |
| | * Causes and Corrective Actions - Tim Blake |
| | * Regulatory Significance - Jon Anderson |
| | * Barriers and Operator Actions - Terry Bacon |
| | * Summary - Mark Schimmel |
| | * Closing Remarks - Dennis Koehl 2 |
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| minutes or longer R-25 R-31 13 14*R-25/31 Spent Fuel Pool Ventilation Radiation Monitors Regulatory Significance Flow Filter Regulatory Significance 15EALThreshold Basis Radiation MonitorsRA2.1A VALID alarm on one or more of the following radiation monitors:
| | Opening Remarks |
| R-25 or R-31 Spent
| | * Prairie Island (PINGP) takes its obligation to protect the health and safety of the public very seriously |
| | * Performance Deficiency |
| | - Failure to follow and maintain in effect emergency plans which use a standard emergency classification and action level scheme |
| | - We agree with the performance deficiency |
| | * Causes and Corrective Actions |
| | * Regulatory Significance 3 |
|
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| Fuel Pool Air Monitor (HI Alarm)
| | Sequence of Events, Causes, and Corrective Actions Tim Blake, Fleet Emergency Preparedness Manager 4 |
| Addresses indication of fuel uncoveryor damage R-25 R-31*Initiating Condition RA2 -Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel Regulatory Significance EALs RA 2.1 RA 1.2 Radiation Monitors R-25 R-31 R-25 R-31 HI-Alarm Setpoint (6,000 CPM)
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| Instrument Scaling:10 -1,000,000 CPM10 -1,000,000 CPM 200 x Alarm Setpoint (1,200,000 CPM)
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| ALERT Thresholds:
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| 16 R-25/R-31 Thresholds for Entering EAL RA2.1 or RA1.2 0 200000 400000 600000 800000 1000000 1200000 1400000HI Alarm 6000CPM200 x AlarmSetpointCPM Regulatory Significance Indication of Lowering Spent Fuel Pool Level Or Damage to Irradiated Fuel R-25/R-31 HI Alarm 6000 CPM Dec l are an ALERT per RA2.1 RA2.1 RA1.2 17 18 Barriers and Operator ActionsTerry Bacon -Operations Support Manager 19 Barriers and Operator Actions*R-18 Waste Effluent Liquid Monitor Auto Closes at 30,000 CPM R-18 From Tanks CV-31256 NC FC Keylock CV-31841 NC FC Manual Valves NC To River NC = normally closed; FC =
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| fails in the closed position 20*Multiple process and design barriers are in place such that the potential to enter RA 1.1 is
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| extremely low Barriers and Operator Actions No ALERT Yes No No Yes No R-18 Permitted Liquid Discharge Va lve Locked Closed Expected le vel exceeded?Alarm se tpoint Reached CV-31256 Auto Closed Alarm Response Procedure Actions Yes Yes Yes No Manual stop discharge Yes No No ALERT No ALERT No ALERT No ALERT No ALERT 21 Barriers and Operator Actions*Tabletop Scenario-5 of 5 operators declared an ALERT 22 Summary Mark Schimmel, Site Vice President 23 Dennis Koehl, Chief Nuclear Officer Closing Remarks}}
| | EAL Description |
| | * Initiating Condition RA1 - Any UNPLANNED Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the Offsite Dose Calculation Manual (ODCM) Specification for 15 Minutes or Longer |
| | - RA1.1 - Applicable to routine release pathways, for which a discharge permit is normally prepared |
| | - RA1.2 - Applicable to non-routine release pathways, for which a discharge permit would not normally be prepared |
| | - RA1.3 - Confirmed sample analysis 5 |
| | |
| | Sequence of Events Timeline Decision to Rev 0 of EALs Rev 1 of Rev 3 of EALs submit by end implemented EALs Implemented of 3rd QTR implemented Wrong New EALs Submitted Picture No Justification for RA1.3 use submitted to NRC Used Ambiguous Thresholds 2004 2005 2006 2007 2008 2009 L Rollback Evaluating Evaluating Industry OE Kewaunee Point Beach withdraws Operator Wrong Picture OE submittal Feedback No Deviations Standard Wrong Picture Blue comments are missed opportunities 6 |
| | |
| | Revision 3 to EALs |
| | * Completed in June 2009 |
| | * Note related to use of RA1.3 for offscale radiation monitors removed from Table R-1 |
| | * ALERT threshold changed to an unambiguous value for R-18 |
| | * Offsite Dose Calculation Manual alarm setpoints for R-25 and R-31 were reduced so these radiation monitors would read on scale at 200 X the alarm setpoint 7 |
| | |
| | Missed Opportunities |
| | * Writers failed to use specific numbers for thresholds, instead used 200 X ODCM limits |
| | * Literal application of fleet expectation for deviations |
| | * Did not document and justify the use of EAL RA1.3 as an alternative entry into an ALERT for off scale radiation monitor readings |
| | * Inadequate assessment of feedback and industry operating experience 8 |
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| | Root Cause Evaluation |
| | * Root Cause |
| | - Existing procedure did not provide adequate guidance for changing EALs or EAL schemes |
| | * Contributing Cause |
| | - Change in standard and subsequent scope without sufficient resources |
| | * Extent of Condition |
| | - All extent of condition actions completed |
| | - No other examples of the condition found |
| | * Extent of Cause 9 |
| | |
| | Interim Actions Taken EAL scheme change to NEI 99-01, Rev 5 will not be made until procedure revisions are implemented Reviewed past 10 CFR 50.54(q) evaluations New 10 CFR 50.54(q) evaluations associated with risk significant planning standard changes require independent external reviews until the fleet procedure is revised 10 |
| | |
| | Corrective Actions Create a fleet procedure for changing EALs and EAL schemes with detailed guidance for: |
| | - Proposed staffing levels and time allowances to develop and validate major changes |
| | - Acceptable methods for meeting or changing EAL entry condition thresholds when the setpoint is beyond indication range |
| | - Engineering reviews for changes requiring process indication or environmental monitoring |
| | - Additional validation reviews |
| | - Justification of changes in preparation for NRC submittals Revise EALs to include unambiguous threshold values 11 |
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| | Regulatory Significance Jon Anderson - Regulatory Affairs Manager 12 |
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| | Regulatory Significance EALs Thresholds Bases Radiation Monitors RA1.1 VALID reading on any Monitoring on R-18 effluent monitor that routine release exceeds 200 times the pathways for which alarm setpoint established a discharge permit by a current radioactivity is normally prepared discharge permit for 15 minutes or longer RA1.2 VALID reading on one or Addresses R-25 more radiation monitors monitoring on non- R-31 that exceeds 200 times routine release the alarm setpoint for 15 pathways for which minutes or longer a discharge permit is not normally prepared 13 |
| | |
| | Regulatory Significance |
| | * R-25/31 Spent Fuel Pool Ventilation Radiation Monitors Flow Filter 14 |
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| | Regulatory Significance Initiating Condition RA2 - Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel EAL Threshold Basis Radiation Monitors RA2.1 A VALID alarm on one or Addresses R-25 more of the following indication of fuel R-31 radiation monitors: uncovery or damage R-25 or R-31 Spent Fuel Pool Air Monitor (HI Alarm) 15 |
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| | Regulatory Significance EALs RA 2.1 RA 1.2 Radiation R-25 R-25 Monitors R-31 R-31 ALERT HI-Alarm Setpoint 200 x Alarm Setpoint Thresholds: (6,000 CPM) (1,200,000 CPM) |
| | Instrument 10 - 1,000,000 CPM 10 - 1,000,000 CPM Scaling: |
| | 16 |
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| | Regulatory Significance Indication of Lowering R-25/R-31 Thresholds for Entering Spent Fuel Pool Level EAL RA2.1 or RA1.2 Or Damage to Irradiated 1400000 Fuel 1200000 1000000 R-25/R-31 800000 HI Alarm CPM 600000 6000 CPM 400000 RA2.1 RA1.2 200000 Declare an ALERT per RA2.1 0 HI Alarm 6000 200 x Alarm CPM Setpoint 17 |
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| | Barriers and Operator Actions Terry Bacon - Operations Support Manager 18 |
| | |
| | Barriers and Operator Actions |
| | * R-18 Waste Effluent Liquid Monitor Auto Closes at 30,000 CPM From Tanks To River R-18 CV-31256 Keylock NC CV-31841 FC NC FC Manual Valves NC C = normally closed; FC = fails in the closed position 19 |
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| | Barriers and Operator Actions R-18 Permitted Liquid Valve No Discharge No Locked Closed ALERT |
| | * Multiple process Yes and design Expected level No exceeded? No ALERT barriers are in Yes place such that Manual stop discharge No Yes ALERT the potential to No enter RA 1.1 is No Alarm setpoint Reached No ALERT extremely low Yes CV-31256 Auto Closed No ALERT Yes No Alarm Response No Procedure Actions ALERT Yes 20 |
| | |
| | Barriers and Operator Actions Tabletop Scenario |
| | - 5 of 5 operators declared an ALERT 21 |
| | |
| | Summary Mark Schimmel, Site Vice President 22 |
| | |
| | Closing Remarks Dennis Koehl, Chief Nuclear Officer 23}} |
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Category:Meeting Briefing Package/Handouts
MONTHYEARML24029A0382024-01-31031 January 2024 January 31, 2024, Pre-application Meeting Presentation - Prairie Island ISFSI License Amendment Request to Add Grace to License Conditions ML23168A0032023-06-20020 June 2023 Handout for 6/23/2023 Pre-Application Public Meeting with Prairie Island Nuclear Generating Plant to Revise ISFSI TS 4.4 for TN-40HT Casks ML23156A2602023-06-0505 June 2023 2022 Prairie Island End-of-Cycle Meeting Presentation ML23102A1752023-04-14014 April 2023 April 14, 2023 TS 3.7.8 LAR Pre-Submittal Meeting Slides ML22130A5852022-05-10010 May 2022 2021 Monticello and Prairie Island Nuclear Generating Plant End-of-Cycle Meeting Presentation ML22048B1812022-02-18018 February 2022 Pre-Application Meeting for Prairie Island TS 5.6.6, PTLR, LAR ML21221A0202021-08-11011 August 2021 Nis Pr Bypass Test Panel License Amendment Request ML21166A3792021-06-15015 June 2021 Units 1 and 2 2020 End-of-Cycle Meeting Presentation ML21032A2632021-02-0303 February 2021 Slides for Public Meeting with Xcel Energy to Discuss a Planned Amendment to Combine the Emergency Plans and Create a Common Emergency Offsite Facility for Monticello and Prairie Island ML19347B0722019-12-12012 December 2019 TVA and Xcel Energy Slides for Joint Presubmittal Meeting to License Amendment Requests to Adopt WCAP-17661, Revision 1 ML19268A0422019-09-26026 September 2019 Pre-Application Meeting License Amendment Request Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML19210D4512019-07-22022 July 2019 Abeyance Seal Preapplication Meeting Slides ML18051A1752018-02-20020 February 2018 Pre-Application Meeting License Amendment for TSTF-425 Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program Xcel Energy 2/20/2018 ML17240A3382017-08-30030 August 2017 Non-Safety Related Digital Feedwater and Amsac/Dss Control Systems Replacement Project Presentation ML17198A2632017-07-17017 July 2017 Pre-Application Meeting ML17066A3732017-03-0909 March 2017 Spent Fuel Pool Criticality Technical Specification Changes Round 2 Request for Additional Information Public Meeting: March 9, 2017 ML17037D1172017-02-0707 February 2017 License Amendment Requests for Change in Emergency Plan Staff Augmentation Response Times Pre-Submittal Meeting for Prairie Island Nuclear Generating Plant Monticello Nuclear Generating Plant: February 7, 2017 ML17023A0652017-01-24024 January 2017 Pre-Submittal Call Regarding License Amendment Requests for Prairie Island Nuclear Generating Plant, Units 1 and 2 and Monticello Nuclear Generating Plant Emergency Action Level Scheme Changes ML15140A3342015-05-13013 May 2015 Public Meeting 05132015 Licensee Slides Only ML15105A0372015-04-14014 April 2015 Xcel Energy Slide Presentation to Support Pre-Application Meeting on April 14, 2015, to Discuss Nuclear Fuel Design Transition to Include Integral Fuel Burnable Absorber (Ifba) at the Prairie Island Nuclear Generating Plant ML14323B0222014-11-19019 November 2014 Regcon, November 19-20, 2014: 03-Info-Session-2 Ronald Johnson - Tribal Perspective on Continued Storage ML14153A0242014-05-16016 May 2014 Xcel Energy'S Presentation Slides Supporting a May 16, 2014, Public Meeting to Discuss the Flood Hazard Reevaluation Schedule for the Monticello and Prairie Island Nuclear Generating Plants ML14058A1732014-02-19019 February 2014 Diesel Generator Steady State Voltage and Frequency Limits - Prairie Island Nuclear Generating Plant Meeting February 19, 2014 ML13210A2012013-07-29029 July 2013 2012 End-of-Cycle Slides - Licensee ML13210A2002013-07-11011 July 2013 2012 End-of-Cycle Slides ML13056A0262013-02-25025 February 2013 Regulatory Conference Slide Presentation ML12340A5402012-12-0606 December 2012 Reactor Core Cooling & Heat Removal FLEX Strategy - Phase 1 ML12326A9712012-11-21021 November 2012 Encl 3 (Handouts - Public) to Summary of October 24, 2012, Meeting with the Northern States Power Company, D/B/A Excel Energy Regarding Security Requirements and Changes Pertaining to Prairie Island TAC L24689 ML12277A1762012-10-0404 October 2012 Steam Generator Replacement Presentation ML12275A4652012-09-27027 September 2012 Meeting September 27, 2012 - Handouts ML12275A3782012-09-27027 September 2012 Xcel Energy Prairie Island Nuclear Generating Plant Meeting Presentation, Diesel Generator Voltage and Frequency Limits. ML12205A2172012-07-23023 July 2012 NRC 2011 End-of-Cycle Slides ML12205A2202012-07-17017 July 2012 Licensee 2012 End-of-Cycle Slides ML12115A3112012-04-24024 April 2012 Meeting Slides: 04/24/2012 Meeting with Xcel Energy NFPA 805 Presubmittal - Prairie Island Nuclear Generating Plant ML1207904792012-03-14014 March 2012 March 14, 2012 Telecon Slides ML1122803892011-08-18018 August 2011 Pre-Application Meeting for Prairie Island Nuclear Generating Plant (Ping) Extended Power Uprate (EPU) ML1119903462011-07-28028 July 2011 Meeting Presentation, Prairie Island Nuclear Generating Plant - Failure to Maintain the Train a and B Direct Current Electrical Power Subsystems Operable ML1117804242011-06-22022 June 2011 June 22, 2011, Meeting Handout #1 - NRC Meeting Diesel Fuel Oil LAR for Prairie Island Ngp ML1120701572011-06-22022 June 2011 June 22, 2011, Meeting Handout #2 - Proposed Technical Specification Changes for Prairie Island Ngp Diesel Fuel Oil LAR ML1106600792011-03-0303 March 2011 March 3, 2011 Meeting Handouts - Revise Footnote in TS 3.8.1, Prairie Island Nuclear Generating Plant ML1034701142010-12-14014 December 2010 Excel Energy Slides for Public Meeting 12/14/2010 to Discuss Human Performance Issues ML1027802642010-10-0404 October 2010 Session 4 - Heather Westra Presentation at October 4, 2010, Public Meeting on Groundwater Protection ML1023805712010-08-25025 August 2010 Meeting Presentation Alternative Source Term Steam Generator Tube Rupture Margin to Overfill Evaluation - Prairie Island Nuclear Generating Plant ML1014502432010-05-26026 May 2010 Responses to Questions from the Prairie Island Indian Community Concerning Issues Related to Prairie Island Nuclear Generating Plant ML1012604192010-05-20020 May 2010 Meeting Presentation Prairie Island Annual Assessment Meeting - Reactor Oversight Program - 2009 ML1012503422010-05-0505 May 2010 Regulatory Conference Slides ML1015801072010-04-28028 April 2010 2R26 Outage, SG Tube Inspection Telecon Slides ML1010604782010-04-15015 April 2010 April 15, 2010, Meeting Slides - Pre-Application Meeting for Prairie Island Ngp Extended Power Uprate ML0932901282009-12-0101 December 2009 Licensee Slides for Public Meeting ML0931003422009-11-0303 November 2009 HAB Drill Conference Call 2024-01-31
[Table view] Category:Slides and Viewgraphs
MONTHYEARML24029A0382024-01-31031 January 2024 January 31, 2024, Pre-application Meeting Presentation - Prairie Island ISFSI License Amendment Request to Add Grace to License Conditions ML23168A0032023-06-20020 June 2023 Handout for 6/23/2023 Pre-Application Public Meeting with Prairie Island Nuclear Generating Plant to Revise ISFSI TS 4.4 for TN-40HT Casks ML23156A2602023-06-0505 June 2023 2022 Prairie Island End-of-Cycle Meeting Presentation ML23102A1752023-04-14014 April 2023 April 14, 2023 TS 3.7.8 LAR Pre-Submittal Meeting Slides ML22130A5852022-05-10010 May 2022 2021 Monticello and Prairie Island Nuclear Generating Plant End-of-Cycle Meeting Presentation ML22048B1812022-02-18018 February 2022 Pre-Application Meeting for Prairie Island TS 5.6.6, PTLR, LAR ML21166A3792021-06-15015 June 2021 Units 1 and 2 2020 End-of-Cycle Meeting Presentation ML21124A0652021-05-0606 May 2021 Xcel Energy Presentation for May 6, 2021 Public Meeting to Discuss 24-Month Cycles at Prairie Island Nuclear Generating Plant, Units 1 and 2 ML21032A2632021-02-0303 February 2021 Slides for Public Meeting with Xcel Energy to Discuss a Planned Amendment to Combine the Emergency Plans and Create a Common Emergency Offsite Facility for Monticello and Prairie Island ML20266F1052020-09-23023 September 2020 (PINGP) COVID-19 Exemption Request for the 2020 Biennial Emergency Preparedness Exercise ML20212L8622020-07-29029 July 2020 2019 Monticello and Prairie Island EOC Presentation from Webinar ML20098F0682020-04-0909 April 2020 Preapplication Teleconference Presentation: License Amendment Request to Adopt TSTF-569 ML20057D3082020-02-18018 February 2020 Slides Potential License Amendment to Remove Note from LCO 3.4.12 and LCO 3.4.13 ML19268A0422019-09-26026 September 2019 Pre-Application Meeting License Amendment Request Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML19210D4512019-07-22022 July 2019 Abeyance Seal Preapplication Meeting Slides ML19071A2782019-03-0707 March 2019 Enclosure 3: Meeting Slides (Summary of February 28, 2019, Public Meeting with Xcel Energy to Discuss Increasing the Amount of Special Nuclear Material Authorized for Storage at the Prairie Island ISFSI (W/Enclosures 1 and 2)) ML18162A0262018-06-12012 June 2018 License Amendment Request to Reclassify Certain Fuel Handling Equipment ML18051A1752018-02-20020 February 2018 Pre-Application Meeting License Amendment for TSTF-425 Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program Xcel Energy 2/20/2018 ML17240A3382017-08-30030 August 2017 Non-Safety Related Digital Feedwater and Amsac/Dss Control Systems Replacement Project Presentation ML17198A2632017-07-17017 July 2017 Pre-Application Meeting ML17209A1192017-07-17017 July 2017 Summary of July 17, 2017, Meeting with Northern States Power Company, Doing Business as Xcel Energy, on Potential License Amendment Request Related to Heavy Lifting Devices ML17066A3732017-03-0909 March 2017 Spent Fuel Pool Criticality Technical Specification Changes Round 2 Request for Additional Information Public Meeting: March 9, 2017 ML17037D1172017-02-0707 February 2017 License Amendment Requests for Change in Emergency Plan Staff Augmentation Response Times Pre-Submittal Meeting for Prairie Island Nuclear Generating Plant Monticello Nuclear Generating Plant: February 7, 2017 ML17023A0652017-01-24024 January 2017 Pre-Submittal Call Regarding License Amendment Requests for Prairie Island Nuclear Generating Plant, Units 1 and 2 and Monticello Nuclear Generating Plant Emergency Action Level Scheme Changes ML16280A0352016-09-29029 September 2016 Flood Hazard Reevaluation Report - Response to Requested Information (CAC Nos. MF7710 and MF7711) - Figure 1 of 3 ML16280A0372016-09-29029 September 2016 Flood Hazard Reevaluation Report - Response to Requested Information (CAC Nos. MF7710 and MF7711) - Figure 2 of 3 ML16280A0422016-09-29029 September 2016 Flood Hazard Reevaluation Report - Response to Requested Information (CAC Nos. MF7710 and MF7711) - Figure 3 of 3 ML15140A3342015-05-13013 May 2015 Public Meeting 05132015 Licensee Slides Only ML15127A6562015-05-0707 May 2015 PI EOC Mtg NRC Slides ML15105A0372015-04-14014 April 2015 Xcel Energy Slide Presentation to Support Pre-Application Meeting on April 14, 2015, to Discuss Nuclear Fuel Design Transition to Include Integral Fuel Burnable Absorber (Ifba) at the Prairie Island Nuclear Generating Plant ML14323B0222014-11-19019 November 2014 Regcon, November 19-20, 2014: 03-Info-Session-2 Ronald Johnson - Tribal Perspective on Continued Storage ML14162A5202014-06-11011 June 2014 Slides: Prairie Island Independent Spent Fuel Storage Installation - License Renewal Application - Discussion of Requests for Additional Information, for June 16, 2014, Public Meeting ML14153A0242014-05-16016 May 2014 Xcel Energy'S Presentation Slides Supporting a May 16, 2014, Public Meeting to Discuss the Flood Hazard Reevaluation Schedule for the Monticello and Prairie Island Nuclear Generating Plants ML14084A3242014-03-21021 March 2014 M140321: Slides - Presented by Multiple Participants at Commission Briefing on Waste Confidence Rulemaking ML13210A2012013-07-29029 July 2013 2012 End-of-Cycle Slides - Licensee ML13210A2002013-07-11011 July 2013 2012 End-of-Cycle Slides ML13056A0262013-02-25025 February 2013 Regulatory Conference Slide Presentation ML12340A5402012-12-0606 December 2012 Reactor Core Cooling & Heat Removal FLEX Strategy - Phase 1 ML12326A9712012-11-21021 November 2012 Encl 3 (Handouts - Public) to Summary of October 24, 2012, Meeting with the Northern States Power Company, D/B/A Excel Energy Regarding Security Requirements and Changes Pertaining to Prairie Island TAC L24689 ML12277A1762012-10-0404 October 2012 Steam Generator Replacement Presentation ML12275A3782012-09-27027 September 2012 Xcel Energy Prairie Island Nuclear Generating Plant Meeting Presentation, Diesel Generator Voltage and Frequency Limits. ML12205A2172012-07-23023 July 2012 NRC 2011 End-of-Cycle Slides ML12205A2202012-07-17017 July 2012 Licensee 2012 End-of-Cycle Slides ML12115A3112012-04-24024 April 2012 Meeting Slides: 04/24/2012 Meeting with Xcel Energy NFPA 805 Presubmittal - Prairie Island Nuclear Generating Plant ML1207904792012-03-14014 March 2012 March 14, 2012 Telecon Slides ML1122803892011-08-18018 August 2011 Pre-Application Meeting for Prairie Island Nuclear Generating Plant (Ping) Extended Power Uprate (EPU) ML1119903462011-07-28028 July 2011 Meeting Presentation, Prairie Island Nuclear Generating Plant - Failure to Maintain the Train a and B Direct Current Electrical Power Subsystems Operable ML1117804242011-06-22022 June 2011 June 22, 2011, Meeting Handout #1 - NRC Meeting Diesel Fuel Oil LAR for Prairie Island Ngp ML1110200652011-04-14014 April 2011 NRC Slides for EOC Meeting ML1106600792011-03-0303 March 2011 March 3, 2011 Meeting Handouts - Revise Footnote in TS 3.8.1, Prairie Island Nuclear Generating Plant 2024-01-31
[Table view] |
Text
Prairie Island Nuclear Generating Plant NRC Region III Regulatory Conference Emergency Action Level Scheme Issue May 11, 2010
Agenda
- Opening Remarks - Mark Schimmel
- Sequence of Events - Tim Blake
- Causes and Corrective Actions - Tim Blake
- Regulatory Significance - Jon Anderson
- Barriers and Operator Actions - Terry Bacon
- Closing Remarks - Dennis Koehl 2
Opening Remarks
- Prairie Island (PINGP) takes its obligation to protect the health and safety of the public very seriously
- Failure to follow and maintain in effect emergency plans which use a standard emergency classification and action level scheme
- We agree with the performance deficiency
- Causes and Corrective Actions
- Regulatory Significance 3
Sequence of Events, Causes, and Corrective Actions Tim Blake, Fleet Emergency Preparedness Manager 4
EAL Description
- Initiating Condition RA1 - Any UNPLANNED Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the Offsite Dose Calculation Manual (ODCM) Specification for 15 Minutes or Longer
- RA1.1 - Applicable to routine release pathways, for which a discharge permit is normally prepared
- RA1.2 - Applicable to non-routine release pathways, for which a discharge permit would not normally be prepared
- RA1.3 - Confirmed sample analysis 5
Sequence of Events Timeline Decision to Rev 0 of EALs Rev 1 of Rev 3 of EALs submit by end implemented EALs Implemented of 3rd QTR implemented Wrong New EALs Submitted Picture No Justification for RA1.3 use submitted to NRC Used Ambiguous Thresholds 2004 2005 2006 2007 2008 2009 L Rollback Evaluating Evaluating Industry OE Kewaunee Point Beach withdraws Operator Wrong Picture OE submittal Feedback No Deviations Standard Wrong Picture Blue comments are missed opportunities 6
Revision 3 to EALs
- Note related to use of RA1.3 for offscale radiation monitors removed from Table R-1
- ALERT threshold changed to an unambiguous value for R-18
- Offsite Dose Calculation Manual alarm setpoints for R-25 and R-31 were reduced so these radiation monitors would read on scale at 200 X the alarm setpoint 7
Missed Opportunities
- Writers failed to use specific numbers for thresholds, instead used 200 X ODCM limits
- Literal application of fleet expectation for deviations
- Did not document and justify the use of EAL RA1.3 as an alternative entry into an ALERT for off scale radiation monitor readings
- Inadequate assessment of feedback and industry operating experience 8
Root Cause Evaluation
- Existing procedure did not provide adequate guidance for changing EALs or EAL schemes
- Change in standard and subsequent scope without sufficient resources
- All extent of condition actions completed
- No other examples of the condition found
Interim Actions Taken EAL scheme change to NEI 99-01, Rev 5 will not be made until procedure revisions are implemented Reviewed past 10 CFR 50.54(q) evaluations New 10 CFR 50.54(q) evaluations associated with risk significant planning standard changes require independent external reviews until the fleet procedure is revised 10
Corrective Actions Create a fleet procedure for changing EALs and EAL schemes with detailed guidance for:
- Proposed staffing levels and time allowances to develop and validate major changes
- Acceptable methods for meeting or changing EAL entry condition thresholds when the setpoint is beyond indication range
- Engineering reviews for changes requiring process indication or environmental monitoring
- Additional validation reviews
- Justification of changes in preparation for NRC submittals Revise EALs to include unambiguous threshold values 11
Regulatory Significance Jon Anderson - Regulatory Affairs Manager 12
Regulatory Significance EALs Thresholds Bases Radiation Monitors RA1.1 VALID reading on any Monitoring on R-18 effluent monitor that routine release exceeds 200 times the pathways for which alarm setpoint established a discharge permit by a current radioactivity is normally prepared discharge permit for 15 minutes or longer RA1.2 VALID reading on one or Addresses R-25 more radiation monitors monitoring on non- R-31 that exceeds 200 times routine release the alarm setpoint for 15 pathways for which minutes or longer a discharge permit is not normally prepared 13
Regulatory Significance
- R-25/31 Spent Fuel Pool Ventilation Radiation Monitors Flow Filter 14
Regulatory Significance Initiating Condition RA2 - Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel EAL Threshold Basis Radiation Monitors RA2.1 A VALID alarm on one or Addresses R-25 more of the following indication of fuel R-31 radiation monitors: uncovery or damage R-25 or R-31 Spent Fuel Pool Air Monitor (HI Alarm) 15
Regulatory Significance EALs RA 2.1 RA 1.2 Radiation R-25 R-25 Monitors R-31 R-31 ALERT HI-Alarm Setpoint 200 x Alarm Setpoint Thresholds: (6,000 CPM) (1,200,000 CPM)
Instrument 10 - 1,000,000 CPM 10 - 1,000,000 CPM Scaling:
16
Regulatory Significance Indication of Lowering R-25/R-31 Thresholds for Entering Spent Fuel Pool Level EAL RA2.1 or RA1.2 Or Damage to Irradiated 1400000 Fuel 1200000 1000000 R-25/R-31 800000 HI Alarm CPM 600000 6000 CPM 400000 RA2.1 RA1.2 200000 Declare an ALERT per RA2.1 0 HI Alarm 6000 200 x Alarm CPM Setpoint 17
Barriers and Operator Actions Terry Bacon - Operations Support Manager 18
Barriers and Operator Actions
- R-18 Waste Effluent Liquid Monitor Auto Closes at 30,000 CPM From Tanks To River R-18 CV-31256 Keylock NC CV-31841 FC NC FC Manual Valves NC C = normally closed; FC = fails in the closed position 19
Barriers and Operator Actions R-18 Permitted Liquid Valve No Discharge No Locked Closed ALERT
- Multiple process Yes and design Expected level No exceeded? No ALERT barriers are in Yes place such that Manual stop discharge No Yes ALERT the potential to No enter RA 1.1 is No Alarm setpoint Reached No ALERT extremely low Yes CV-31256 Auto Closed No ALERT Yes No Alarm Response No Procedure Actions ALERT Yes 20
Barriers and Operator Actions Tabletop Scenario
- 5 of 5 operators declared an ALERT 21
Summary Mark Schimmel, Site Vice President 22
Closing Remarks Dennis Koehl, Chief Nuclear Officer 23