Tuesday, July 21, 2015

Why Are Nuclear Plants Having So Many Safety Related HVAC Problem?

July 23

Is excessive HVAC NRC reporting a symptom of too large plant work back log???

July 22:

Bet you most of the HVAC systems were rushed add on systems during troublesome construction and post TMI...

I think the NRC and industry would come back and say...this is where prescriptive regulations got it wrong. There is a insignificant chance these HVAC problems would lead to core damage and a offsite release.
I would say this is where this perspective incentivizes broadly setting up and tolerating safety component degradation and obsolesces.

If we broadly tolerate component degradations in these amazingly complex machines and organizations...then we become much closer to the day when one of these plants runs away from us.
Is there such a thing as boiling frog with priorities metaphor...normalization of deviance?

Is risk perspective numbing us to threats and real risk...

 

The truth is, if the NRC demanded just a few of this plants to shut down over HVAC problems, the industry would update all their problematic HVAC systems. It is common for these guys to fix these problems in a isolated way…instead of thinking holistic it is more efficient with our resources just to buy a new car or buy a new HAVC system.   
The question is if this is an essential safety system, then why is there only one and doing maintenance on it makes it inop.
If this is essential for accident mitigation, why is it taken off line at 100% full power operation, unless the plant has carefully schedule a DBA not to occur while the essential HVAC system is down for repair?"
 July 21:

All 2015 events.
Is it my VY leaking roofs deal…didn’t realize the system had come to end-of-life.
I bet you HVAC problems would be at the bottom of the barrel of maintenance and budgets priority systems.
What do you make big picture and why this is happening...are the issues trending up?
Would having four HVAC systems powered from two independent buses fix it...

Not a complete list: 
###Power Reactor    Event Number: 51103
Facility: CATAWBA
Region: 2 State: SC
Unit: [1] [2] [ ]
RX Type: [1] W-4-LP,[2] W-4-LP
NRC Notified By: THOMAS GARRISON
HQ OPS Officer: JOHN SHOEMAKER    Notification Date: 05/29/2015
Notification Time: 20:17 [ET]
Event Date: 05/29/2015
Event Time: 12:30 [EDT]
Last Update Date: 06/12/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(xiii) - LOSS COMM/ASMT/RESPONSE
Person (Organization):
KATHLEEN O'DONOHUE (R2DO)

Unit    SCRAM Code    RX CRIT    Initial PWR    Initial RX Mode    Current PWR    Current RX Mode
1    N    Y    100    Power Operation    100    Power Operation
2    N    Y    100    Power Operation    100    Power Operation
Event Text
TECHNICAL SUPPORT CENTER VENTILATION SYSTEM OUT OF SERVICE DUE TO DISCOVERED CONDITION

"This is non-emergency eight hour notification for a loss of Emergency Assessment Capability.

"This event is reportable in accordance with 10 CFR 50.72(b)(3)(xiii) as the discovered condition affects the functionality of an emergency response facility.

"A condition impacting functionality of the TSC [Technical Support Center] Ventilation system was discovered on 05/29/2015 at 1230 [EDT]. The issue involves a loss of cooling capability of the TSC ventilation system due to a failed relay. Maintenance will begin repairs at 0700 [EDT] on 05/30/2015. Estimated time to repair is unknown at this time.

"If an emergency is declared requiring TSC activation during this period, the TSC will be staffed and activated using existing emergency planning procedures unless the TSC becomes uninhabitable due to ambient temperature, radiological, or other conditions. If relocation of the TSC becomes necessary, the Emergency Coordinator will relocate the TSC staff to an alternate location in accordance with applicable site procedures. The Emergency Response Organization team will be notified of the condition and the possible need to relocate during an emergency. This condition does not affect the health and safety of the public or station employees. An update will be provided once the TSC ventilation has been restored to normal operation. The NRC Resident Inspector will be notified."

* * * UPDATE FROM AARON MICHALSKI TO DANIEL MILLS AT 1557 EDT ON 6/12/15 * *

The TSC ventilation system has been returned to service. The licensee will notify the NRC Resident Inspector.

Notified R2DO (Guthrie).




###Power Reactor    Event Number: 51154
Facility: BRAIDWOOD
Region: 3 State: IL
Unit: [1] [2] [ ]
RX Type: [1] W-4-LP,[2] W-4-LP
NRC Notified By: BLAKE BAXTER
HQ OPS Officer: DANIEL MILLS    Notification Date: 06/15/2015
Notification Time: 17:42 [ET]
Event Date: 06/16/2015
Event Time: 07:00 [CDT]
Last Update Date: 06/15/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(xiii) - LOSS COMM/ASMT/RESPONSE
Person (Organization):
PATTY PELKE (R3DO)

Unit    SCRAM Code    RX CRIT    Initial PWR    Initial RX Mode    Current PWR    Current RX Mode
1    N    Y    100    Power Operation    100    Power Operation
2    N    Y    100    Power Operation    100    Power Operation
Event Text
TSC VENTILATION TO BE REMOVED FROM SERVICE FOR PLANNED MAINTENANCE

"On 6/16/2015, planned preventive maintenance activities [will be] performed on the Braidwood Generating Station Technical Support Center (TSC), Ventilation System. The work will be completed within approximately 48 hours. This activity includes preventative maintenance that requires the TSC ventilation system to be out of service which will render the TSC ventilation system non-functional.

"If an emergency is declared requiring TSC activation during this period, the TSC will be staffed and activated using existing emergency planning procedures unless the TSC becomes uninhabitable due to ambient temperature or other conditions. If relocation of the TSC becomes necessary, the Emergency Director will relocate the TSC staff as necessary.

"This event is reportable per 10 CFR 50.72(b)(3)(xiii) for 'any event that results in a major loss of emergency assessment capability.' The planned maintenance will not be able to restore the TSC condensing unit or ventilation system to service within the facility activation time specified in the emergency plan (1 hour) in the event of an accident. The Emergency Response Organization team has been notified of the maintenance and the possible need to relocate during an emergency.

"The licensee has notified the NRC Resident Inspector."




###Power Reactor    Event Number: 51164
Facility: LASALLE
Region: 3 State: IL
Unit: [1] [2] [ ]
RX Type: [1] GE-5,[2] GE-5
NRC Notified By: TODD CASAGRANDE
HQ OPS Officer: JEFF HERRERA    Notification Date: 06/17/2015
Notification Time: 23:39 [ET]
Event Date: 06/17/2015
Event Time: 18:41 [CDT]
Last Update Date: 06/18/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(xiii) - LOSS COMM/ASMT/RESPONSE
Person (Organization):
PATTY PELKE (R3DO)

Unit    SCRAM Code    RX CRIT    Initial PWR    Initial RX Mode    Current PWR    Current RX Mode
1    N    Y    100    Power Operation    100    Power Operation
2    N    Y    100    Power Operation    100    Power Operation
Event Text
TECHNICAL SUPPORT CENTER VENTILATION SYSTEM RETURN DAMPER FAILED CLOSED

"On June 17th, 2015 at 1841 CDT, it was determined that the onsite Technical Support Center (TSC) Ventilation System return damper 0VS119Y was failed closed, the failed closed damper affects the TSC Emergency Makeup Train filtration efficiency. There is currently no emergency event in progress requiring TSC staffing. If an emergency is declared and the TSC ERO [Emergency Response Organization] activation is required, the TSC will be staffed and activated unless the TSC becomes uninhabitable due to ambient temperatures, radiological, or other conditions. If relocation of the TSC staff becomes necessary, the Station Emergency Director will relocate the staff to an alternate TSC location in accordance with applicable site procedures.

"The licensee has notified the [NRC] Senior Resident Inspector of the issue."

* * * UPDATE AT 1700 EDT ON 06/18/15 FROM TODD CASAGRANDE TO S. SANDIN * * *

"After repairs were completed, the TSC Ventilation was restored to service at 1650 EDT on 06/18/2015.

"The licensee has notified the NRC Resident Inspector."

Notified R3DO (Pelke).




###Power Reactor    Event Number: 51154
Facility: BRAIDWOOD
Region: 3 State: IL
Unit: [1] [2] [ ]
RX Type: [1] W-4-LP,[2] W-4-LP
NRC Notified By: BLAKE BAXTER
HQ OPS Officer: DANIEL MILLS    Notification Date: 06/15/2015
Notification Time: 17:42 [ET]
Event Date: 06/15/2015
Event Time: 07:00 [CDT]
Last Update Date: 06/18/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(xiii) - LOSS COMM/ASMT/RESPONSE
Person (Organization):
PATTY PELKE (R3DO)

Unit    SCRAM Code    RX CRIT    Initial PWR    Initial RX Mode    Current PWR    Current RX Mode
1    N    Y    100    Power Operation    100    Power Operation
2    N    Y    100    Power Operation    100    Power Operation
Event Text
TSC VENTILATION TO BE REMOVED FROM SERVICE FOR PLANNED MAINTENANCE

"On 6/16/2015, planned preventive maintenance activities [will be] performed on the Braidwood Generating Station Technical Support Center (TSC), Ventilation System. The work will be completed within approximately 48 hours. This activity includes preventative maintenance that requires the TSC ventilation system to be out of service which will render the TSC ventilation system non-functional.

"If an emergency is declared requiring TSC activation during this period, the TSC will be staffed and activated using existing emergency planning procedures unless the TSC becomes uninhabitable due to ambient temperature or other conditions. If relocation of the TSC becomes necessary, the Emergency Director will relocate the TSC staff as necessary.

"This event is reportable per 10 CFR 50.72(b)(3)(xiii) for 'any event that results in a major loss of emergency assessment capability.' The planned maintenance will not be able to restore the TSC condensing unit or ventilation system to service within the facility activation time specified in the emergency plan (1 hour) in the event of an accident. The Emergency Response Organization team has been notified of the maintenance and the possible need to relocate during an emergency.

"The licensee has notified the NRC Resident Inspector."

* * * UPDATE AT 1102 EDT ON 6/18/15 FROM DAVID KORTGE TO JEFF HERRERA * * *

"Braidwood Generating Station TSC ventilation was restored to available status at 0700 CDT on June 18, 2015.

"The previously reported system preventative maintenance has been completed."

The licensee notified the NRC Resident Inspector.

Notified the R3DO (Pelke).




###Power Reactor    Event Number: 51212
Facility: HARRIS
Region: 2 State: NC
Unit: [1] [ ] [ ]
RX Type: [1] W-3-LP
NRC Notified By: RAYMOND MOORE
HQ OPS Officer: MARK ABRAMOVITZ    Notification Date: 07/08/2015
Notification Time: 17:43 [ET]
Event Date: 07/07/2015
Event Time: 11:05 [EDT]
Last Update Date: 07/08/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(xiii) - LOSS COMM/ASMT/RESPONSE
Person (Organization):
GERALD MCCOY (R2DO)

Unit    SCRAM Code    RX CRIT    Initial PWR    Initial RX Mode    Current PWR    Current RX Mode
1    N    Y    100    Power Operation    100    Power Operation
Event Text
TECHNICAL SUPPORT CENTER VENTILATION OUT OF SERVICE

"This is a non-emergency eight hour notification for a loss of Emergency Assessment Capability. This event is reportable in accordance with 10 CFR 50.72(b)(3)(xiii) as the discovered condition affects the functionality of an emergency response facility.

"A condition impacting functionality of the TSC Ventilation system was discovered on July 7, 2015 at 11:05 EDT. The issue involved a loss of cooling capability of the TSC Ventilation system due to failed ventilation system components. Maintenance started repairs immediately following the discovery of the component failures and completed repairs to restore functionality of the TSC Ventilation system on July 8, 2015 at 17:07 EDT. On July 8, 2015, at approximately 15:30 EDT, further review of the impact of this equipment failure determined that this condition was reportable as a loss of emergency assessment capability.

"If an emergency were declared requiring TSC activation during the non-functional period, the TSC would have been staffed and activated using existing emergency planning procedures unless the TSC became uninhabitable due to ambient temperature, radiological, or other conditions. If relocation of the TSC became necessary, the Emergency Director would have relocated the TSC staff to an alternate location in accordance with applicable site procedures. The Emergency Response Organization team was notified of the maintenance and the possible need to relocate during an emergency. This condition did not affect the health and safety of the public or station employees. The NRC Resident Inspector has been notified."



###Power Reactor    Event Number: 51213
Facility: LASALLE
Region: 3 State: IL
Unit: [1] [2] [ ]
RX Type: [1] GE-5,[2] GE-5
NRC Notified By: BRADLEY BRUMUND
HQ OPS Officer: VINCE KLCO    Notification Date: 07/08/2015
Notification Time: 21:53 [ET]
Event Date: 07/08/2015
Event Time: 18:37 [CDT]
Last Update Date: 07/08/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(xiii) - LOSS COMM/ASMT/RESPONSE
Person (Organization):
ANN MARIE STONE (R3DO)

Unit    SCRAM Code    RX CRIT    Initial PWR    Initial RX Mode    Current PWR    Current RX Mode
1    N    Y    100    Power Operation    100    Power Operation
2    N    Y    100    Power Operation    100    Power Operation
Event Text
TECHNICAL SUPPORT CENTER VENTILATION OUT OF SERVICE

"This telephone notification is provided in accordance with Exelon Reportability manual SAF 1.10, 'Major Loss of Emergency Preparedness Capabilities', and 10CFR50.72(b)(3)(xiii).

"On July 8th 2015 at 1837 [CDT], it was determined that the onsite Technical Support Center (TSC) Ventilation System Supply Fan belts had failed, resulting in loss of ventilation for the facility. Repairs were not completed within the time required had the TSC needed to be staffed. There is currently no emergency event in progress requiring TSC staffing. If an emergency is declared and the TSC ERO [Emergency Response Organization] activation is required, the TSC will be staffed and activated unless the TSC becomes uninhabitable due to ambient temperatures, radiological, or other conditions. If relocation of the TSC staff becomes necessary, the Station Emergency Director will relocate the staff to an alternate TSC location in accordance with applicable site procedures.

"The licensee has notified the [NRC] Senior Resident Inspector of the issue."




###Power Reactor    Event Number: 51213
Facility: LASALLE
Region: 3 State: IL
Unit: [1] [2] [ ]
RX Type: [1] GE-5,[2] GE-5
NRC Notified By: BRADLEY BRUMUND
HQ OPS Officer: VINCE KLCO    Notification Date: 07/08/2015
Notification Time: 21:53 [ET]
Event Date: 07/08/2015
Event Time: 18:37 [CDT]
Last Update Date: 07/11/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(xiii) - LOSS COMM/ASMT/RESPONSE
Person (Organization):
ANN MARIE STONE (R3DO)

Unit    SCRAM Code    RX CRIT    Initial PWR    Initial RX Mode    Current PWR    Current RX Mode
1    N    Y    100    Power Operation    100    Power Operation
2    N    Y    100    Power Operation    100    Power Operation
Event Text
TECHNICAL SUPPORT CENTER VENTILATION OUT OF SERVICE

"This telephone notification is provided in accordance with Exelon Reportability manual SAF 1.10, 'Major Loss of Emergency Preparedness Capabilities', and 10CFR50.72(b)(3)(xiii).

"On July 8th 2015 at 1837 [CDT], it was determined that the onsite Technical Support Center (TSC) Ventilation System Supply Fan belts had failed, resulting in loss of ventilation for the facility. Repairs were not completed within the time required had the TSC needed to be staffed. There is currently no emergency event in progress requiring TSC staffing. If an emergency is declared and the TSC ERO [Emergency Response Organization] activation is required, the TSC will be staffed and activated unless the TSC becomes uninhabitable due to ambient temperatures, radiological, or other conditions. If relocation of the TSC staff becomes necessary, the Station Emergency Director will relocate the staff to an alternate TSC location in accordance with applicable site procedures.

"The licensee has notified the [NRC] Senior Resident Inspector of the issue."

* * * UPDATE FROM TODD CASAGRANDE TO DANIEL MILLS AT 1510 EDT ON 7/11/15 * * *

"After repairs were completed, the TSC Ventilation was restarted on 7/9/15 at 0625 EDT for a maintenance run, the TSC Ventilation was restored to operable status at 1500 EDT on 07/11/2015.

"The licensee has notified the NRC Resident Inspector."

Notified R3DO (Stone).




###Power Reactor    Event Number: 51232
Facility: DRESDEN
Region: 3 State: IL
Unit: [ ] [2] [3]
RX Type: [1] GE-1,[2] GE-3,[3] GE-3
NRC Notified By: PATRICK HAARHOSS
HQ OPS Officer: VINCE KLCO    Notification Date: 07/15/2015
Notification Time: 01:04 [ET]
Event Date: 07/15/2015
Event Time: 00:04 [CDT]
Last Update Date: 07/17/2015
Emergency Class: NON EMERGENCY
10 CFR Section: 
50.72(b)(3)(xiii) - LOSS COMM/ASMT/RESPONSE
Person (Organization): 
STEVE ORTH (R3DO)

Unit    SCRAM Code    RX CRIT    Initial PWR    Initial RX Mode    Current PWR    Current RX Mode
2    N    Y    100    Power Operation    100    Power Operation
3    N    Y    100    Power Operation    100    Power Operation
Event Text
TECHNICAL SUPPORT CENTER OUT OF SERVICE DUE TO PLANNED MAINTENANCE 

"At 0004 [CDT] on Wednesday, July 15, 2015, the Dresden Nuclear Power Station (DNPS) Technical Support Center (TSC) emergency ventilation system will be removed from service for planned maintenance activities. During the maintenance, the TSC Ventilation will be shut down. The TSC air filtration fan and dampers will be non-functional, rendering the TSC HVAC accident mode non-functional. This maintenance is scheduled to minimize out of service time. The planned TSC ventilation outage is scheduled to be completed in approximately 24 hours. 

"Contingency plans are in place so that if an emergency is declared requiring TSC activation during this period, the TSC will be staffed and activated using existing Emergency Planning (EP) procedures and checklists. If radiological or environmental conditions require TSC facility evacuation during ventilation system restoration; the Station Emergency Director will relocate the TSC staff in accordance with station procedures." 

"The NRC Resident Inspector has been notified." 

* * * UPDATE FROM TRAVIS PRELLWITZ TO DONALD NORWOOD AT 1733 EDT ON 7/17/2015 * * * 

"At 1347 CDT on July 17, 2015, Dresden TSC Ventilation was restored. The Dresden TSC Ventilation is Functional at this time. 

"The NRC Resident Inspector has been notified." 

Notified R3DO (Orth).

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