1 Regulatory Experience With Preconditioning ISTOG Winter Meeting Orlando Florida January 24, 2008 Tim Smith Dominion Energy Kewaunee

2 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.

3 M RWST PI PI PI ICS Pump 1B ICS Pump 1A M M M M M M M CI-1001A CI-1001B ICS-201 ICS-202 From Refuel Canal To SI From RHR Hx From RHR Hx ICS-2B ICS-2A ICS-5A ICS-6A ICS-6B ICS-5B Restricting Orifice PI Containment RHR-400B RHR-400A Additive Standpipe Additive Pump Additive Tank Filter LI LI LI PI PI Valves in Question FI FI ICS-200B ICS-200A ICS-210B ICS-210A ICS-7A ICS-7B ICS-102 Gasket Repair

4 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.

5 First Discussion Provided Inspector Part 9900 and NUREG 1482 Informed Inspector I couldn’t speak for work control procedures Didn’t Mention Program Definition

6 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.

7 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.

8 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.

9 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.

10 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?

11 Part 9900 Technical Guidance Does the practice bypass or mask the as- found condition? Is preventive maintenance routinely performed just before the testing? Is the preventive maintenance performed only for scheduling convenience?

12 Operability Determination Compared historical stroke times Answered five questions from NRC Inspection Manual Part 9900 to document preconditioning was acceptable

13 Inspector Feedback Any IST Procedural Controls? Work Management Procedural Controls? How can you justify acceptability of preconditioning after the fact?

14 NUREG 1482 Para “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.”

15 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.

16 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.

17 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

18 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”

19 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.

20 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

21 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.

22 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.

23 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”

24 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

25 “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.

26 Corrective Actions Key is to document potential concerns in work planning documents and/or procedures Raise Awareness to ensure everyone has a similar understanding

27 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.

28 Do Over??? NRC Inspection Team Questioned EDG Test Sequence Fire Protection Trip Test performed prior to Quarterly “slow” start test that timed an IST cooling water valve.

29 Do Over??? 2001 Evaluation of test sequence “Missed the Mark” Requested meeting with Senior Resident to better understand concern Senior Resident Informed team that sequence was “Acceptable Preconditioning” based upon difference in periodicity of tests

30 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

31 Questions? Does ISTOG want to pursue submittal of position to EPRI? Has anyone has similar experiences? Is there value in distributing as INPO OE?