Feedwater System Vulnerability Review

Proposed Outline

Phase 1: Complete Prior to Meeting at IPEC in Summer

  1. Compile and Review Industry Operating Experience:

Sources include:

  1. EPRI component / system guides:
  2. 1018699, Feedwater System Maintenance Guide
  3. TR-105663, Feedwater I&C Maintenance Guide
  4. TR-105933, Feedwater Pump Maintenance Guide
  5. TR-111413, Lube Oil System Mitigation
  6. 1003094, Feedwater Pump Turbine Controls and Oil System Maintenance Guide
  7. 1003472, Level Control Guide for Feedwater Heaters, MSRs, and Other Equipment
  8. 1003470, Feedwater Heater Maintenance Guide
  9. NP-7212, Feedwater Isolation Valve Maintenance Guide
  10. 1011828, Severe Duty Valve Maintenance Guide
  11. INPO Topical Reports:
  12. TR 4-41, Review of Main Feedwater System Related Events, November 2004
  13. Addendum 1 to TR 4-41, Review of Main Feedwater System Related Events, September 2006
  14. Addendum 1 to TR4-42, Review of Air-Operated ValveRelated Events (2000 Through September 2006),December 2006
  15. Owners Group Documents
  16. INPO Operating Experience from Plant Events Database using design, vulnerability, aging keywords. Focus on OE that identified “hard to find” issues, detailed problems found within equipment.

Prepare listing of key actions / lessons learned for all Sites to then review and determine status.

(ANO has done this initially. Suggest they complete and another Site perform Peer Check.)

  1. Compile and Review Plant Specific Operating Experience:
  2. Compile and review available open and historical Condition Reports. Focus on aging, passive failures, chronic issues, and repeat maintenance. Review adequacy of corrective actions.
  3. Compile and review open and historical Work Orders. Focus on aging, passive failures, chronic issues, and repeat maintenance.
  4. Compile and Review plant specific INPO Operating Experience from Plant Events Database and applicable EPIX failure data for plant unique components.
  5. Compile and review all historical shutdowns and dowpowers resulting from failures in the Feedwater System. Identify legacy vulnerabilities that may still exist.
  6. Compile and review critical trends for the past several years (get best information available). Are there any unexplained anomalies in the data? Perform detailed review, looking for small anomalies that may not have been caught individually, but could represent an issue collectively.

Prepare listing of key actions / lessons learned for the other Sites to then review and determine status.

  1. Compile and Review Potential Aging Degradation Concerns:
  2. Review the License Renewal Aging Management Review document applicable to the System and Componentswith emphasis on:
  3. Aging Effects Requiring Management (normally Section 3.0)
  4. Time-Limited Aging Analyses, including specific requirements or assumptions (Section 4.0)
  5. Aging Management Programs (Attachment 2)
  6. Review Section 6.1 of the following EPRI LCM Planning Sourcebooks
  7. LCM Planning Sourcebooks—Volume 6: Feedwater Heater Controls, EPRI Report 1007425, March 2003.
  8. LCM Planning Sourcebooks—Volume 10: Feedwater Heaters, EPRI Report 1009073, December 2003.
  9. Life Cycle Management Planning at WolfCreek, EPRI Report 1003060, December 2001. EDG, Main Steam & Feedwater Isolation Valves, and Reactor Protection System.
  10. Life Cycle Management Plans for Feedwater Heater and Moisture Separator Controls at HopeCreek Generating Station, EPRI Report 1009152, September 2003.
  11. Large Motor End of Expected Life and Planning Considerations, EPRI Report 1015076, December 2007
  12. Review the Tables applicable to components in the Feedwater System. Copies of the Tables are located in the System Engineering Peer Group eRoom \ Long Range Plans – MS-S-013 \ LRP Guidance \ EPRI Aging Tables.
  13. Consider passive components within the system, electrical and mechanical. With age, could these passive components have degraded unnoticed? Consider external factors and there impact over time, including heating, water intrusion, vibration, rainwater, animal intrusion. With age, could these external factors have degraded the component to an unacceptable condition? Examples include electrical components subjected to vibration, electrical/electronic components exposed to elevated temperatures, contact pitting over time.
  14. For Plants with Power Uprate: Is more demanded of the equipment? Are there any indications in the system since power uprate to indicate additional stresses on the equipment? Are increased feedwater vibrations affecting equipment? Given the time this equipment has been subjected to feedwater vibrations, are there any new concerns with degradation?

Prepare a listing of walkdown inspection items for use in Step 7 below.

Prepare listing of key actions / lessons learned for the other Sites to then review and determine status.

  1. Review and Identify Low Operating Margins:
  2. Identify existing Low Operating Margin issues in the Site EN-DC-195 Margin Issues Database.
  3. Question Operations and Maintenance personnel to identify new potential Low Operating Margin issues. Example questions to ask are:
  4. Does the component or system experience frequent alarms?
  5. Are the operating parameters close to the maximum or minimum values? Are multiple or continual adjustments required to maintain the parameter within limits?
  6. Have there been any problems in the operation of the component or system under limiting plant / environmental operating conditions? (i.e., hot summer or cold winter operations.)
  7. Have there been problems related to operating parameters near limits in the past?
  8. Have procedural restrictions been placed on the operation of a component or system that result in an Operator or Maintenance burden? (Both normal operations and startup and shutdown.)
  9. Have post SCRAM response been complicated by components or systems operating near limits?
  10. Are surveillance testing results frequently close to the maximum or minimum acceptance values?
  11. Does the surveillance test require complicated adjustments, data analysis or the use of precise M&TE to determine acceptable values?
  12. Are there surveillance tests that we frequently fail or are “afraid to do”?
  13. Are calibration results frequently close to the maximum or minimum acceptance values?
  14. Does the calibration require complicated adjustments, data analysis or the use of precise M&TE to determine acceptable values?
  15. Are there calibrations that we continually fail or are “afraid to do”?

Prepare listing of key actions / lessons learned for the other Sites to then review and determine status.

  1. Review and Identify Single Point Failure Components and Mitigation Strategies:
  2. Review existing Single Point Failure (SPF) Reviews against the current guidance in EN-DC-175 and current knowledge for adequacy.
  3. Perform a review of Critical Cabinets and Panels for embedded subcomponents (relays, power supplies, circuit cards, etc.) that have:
  4. Not been specifically classified for criticality in accordance with EN-DC-153, Revision 3,
  5. Not been specifically identified as Single Point Vulnerable in accordance with EN-DC-175, OR
  6. Not had an appropriate maintenance strategy developed in accordance with EN-DC-335 and EN-DC-324 or equivalent.
  7. Review the Mitigation Strategy for the identified SPF Components, i.e., enhanced PM or modification, for adequacy.
  8. Review the implementation status of the Mitigation Strategies, i.e., enhanced PM or modification. Is it appropriately scheduled? Are there interim strategies in place for those not yet fully implemented?

Prepare listing all identified SPF Components and Mitigation Strategies for the other Sites to then review and determine status.

  1. Review of System Interfaces:
  2. Review interface of critical system / components with non-critical or RTF system / components. Are there any system interactions that could impair or degrade critical components? Example: ANO 1 service air compressor head gasket failure that resulted in a plant shutdown.

Prepare listing of key actions / lessons learned for the other Sites to then review and determine status.

  1. Perform Initial Plant Walkdowns:
  2. Perform initial plant walkdowns of all accessible portions of the system with experienced Operations and Maintenance personnel.
  3. Focus should be placed on:
  4. Key actions and learnings for Review Steps 1 to 6 above.
  5. Equipment condition
  6. Discussions of past concerns known to Team Members
  7. Passive Components, such as cabling, control boxes, structural pieces, etc for signs of degradation. Consider external factors such as heating, water intrusion, vibration, rainwater, animal intrusion, etc.
  1. Update results of Review Steps 1 to 6 as required.
  1. Transmit listings of key actions / lessons learned to the other Sites for them to review and determine status.

Phase 2: Complete at Meeting at IPEC in Summer

  1. Perform Common Review and Gap Analyses:
  2. Perform common review of each plant’s key actions / lessons learned for Fleet wide and/or plant specific gaps for the following:
  3. Industry Operating Experience
  4. Plant Specific Operating Experience
  5. Aging Degradation Concerns and Walkdown Results
  6. Low Operating Margins
  7. Single Point Failure Components and Mitigation Strategies
  8. System Interfaces
  1. Perform common review of each plant’s key actions / lessons learned for Fleet wide and/or plant specific gaps for the following:
  2. Main Feedwater Pump Seals
  3. Main Feedwater Pump Lube Oil Systems
  4. Level Control Valves and Control Systems
  5. Heater Level Control Systems

(Note: BOP AOVs are being reviewed by EP&C under )

  1. Perform Training on EPRI Aging Assessment Field Guide (EPRI Report 1007933, December 2003)
  2. Include In Plant Walkdowns led by ANO License Renewal personnel or other such experienced persons.
  1. Review Performance Monitoring Plans???

Phase 3: Complete after IPEC Reviews and Training in Summer / Fall

  1. Update results of Phase 1 Review Steps 1 to 6 as required based on lessons learned from IPEC Reviews and Training.
  1. Review Operating Procedures and Alarm Response Cards/Procedures:

With Operations personnel:

  1. Review for Limits, Precautions and/or Actions that are considered to be a vulnerability that would put the plant in a trip or transient.
  2. Review for places where a single indication is used as basis for or confirmation of an action. Is that indication properly maintained or is alternate indication available that should be described?
  1. Review Design Changes:
  2. Review the Site Integrated Planning Database (SIPD) records and Engineering Changes (ECs), including ECRs, partially installed modifications, and pending modifications.
  1. Verify Component Criticality and Preventive Maintenance Strategies:
  2. Verify High Critical Components are correctly identified and classified in accordance with EN-DC-153.
  3. Review the current Preventive Maintenance strategies for High Critical Components:
  4. Against the current Fleet PM Templates for effectiveness and completeness.
  5. Revisions necessary to improve performance of identified chronic equipment performance issues.
  1. Perform Second Plant Walkdowns:
  2. Perform second plant walkdowns of all accessible portions of the system with experienced Operations and Maintenance personnel. (BWRs should perform walkdown during the next Refuel Outage.)
  3. Focus should be placed on:
  4. Identified ey actions and learnings.
  5. Use of the EPRI Aging Assessment Field Guide to:
  6. Identify the Condition (such as the environment, loads, maintenance)
  7. Understand the Stressor (such as relative motion, corrosive environment, salt water exposure, thermal stratification)
  8. Identify the Degradation Mechanism (such as galvanic corrosion, wear, pitting, fatigue, thermal embrittlement)
  9. Identify Prevention / Mitigation actions.
  1. Take digital pictures and notes for all identified external surface degradation to support future trending. Capture the pictures and notes in your System Notebook, DVD or other appropriate location
  1. Prioritize Obsolescence Issues in accordance with EN-DC-XXX.
  1. Prepare Report
  1. Present to URT
  1. Update Margin Issues Database in accordance with EN-DC-195.
  1. Update System and Component Health Reports