© 2014 Institute of Nuclear Power Operations

I n s t i t u t e o f N u c l e a r P o w e r O p e r a t i o n sI n s t i t u t e o f N u c l e a r P o w e r O p e r a t i o n s

INPO PerspectiveGroundwater Protection and RETS/REMP MeetingJune 2014

INPO PerspectiveGroundwater Protection and RETS/REMP MeetingJune 2014

Joe SearsManager, Nuclear Asset ProtectionJoe SearsManager, Nuclear Asset Protection

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Key TopicsKey Topics

• Groundwater protection

• Underground piping and Tanks

• Process Radiation MonitoringFailures

• Groundwater protection

• Underground piping and Tanks

• Process Radiation MonitoringFailures

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Groundwater ProtectionGroundwater Protection

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NRC File Image

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• Monitored pathway releases expected; includes tritium

• EPA– Safe drinking water standard: 20,000 pCi/l tritum-4 mrem/yr

• NRC– Drinking water reporting level: 20,000 pCi/l

• NEI 07-07 Groundwater Protection

– Reporting– Objective 2.2 Voluntary Communication

• Monitored pathway releases expected; includes tritium

• EPA– Safe drinking water standard: 20,000 pCi/l tritum-4 mrem/yr

• NRC– Drinking water reporting level: 20,000 pCi/l

• NEI 07-07 Groundwater Protection

– Reporting– Objective 2.2 Voluntary Communication

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NEI 07-07, Industry Ground WaterProtection InitiativeNEI 07-07, Industry Ground WaterProtection Initiative

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NEI 07-07, Industry Ground WaterProtection InitiativeNEI 07-07, Industry Ground WaterProtection Initiative• Precursor for underground piping and tank

integrity review – NEI 09-14• Initiative Effectiveness

– Assessment process defined in NEI 07-07

• Perform every 5 years• 11 objectives and 43 acceptance criteria• Shortfalls resolved through site corrective action

program

• Precursor for underground piping and tankintegrity review – NEI 09-14

• Initiative Effectiveness– Assessment process defined in NEI 07-07

• Perform every 5 years• 11 objectives and 43 acceptance criteria• Shortfalls resolved through site corrective action

program

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• Zero tolerance: nuclear plants should not leakradioactive fluids

• Collaboration between stakeholders• Leak source identified and remediated• NEI 07-07 requirements adhered to

Ex. self-assessments; risk ranking performed• Document leaks in CAP• Effective oversight

Department manager/Nuclear oversight/Corporate

• Zero tolerance: nuclear plants should not leakradioactive fluids

• Collaboration between stakeholders• Leak source identified and remediated• NEI 07-07 requirements adhered to

Ex. self-assessments; risk ranking performed• Document leaks in CAP• Effective oversight

Department manager/Nuclear oversight/Corporate

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Groundwater Tritium-Industry ExpectationsGroundwater Tritium-Industry Expectations

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Tritium in Groundwater WellsTritium in Groundwater Wells

• Consolidated Data Entry• Data Element Manual• Data entry required since January 2013• This is NOT a performance indicator but

can be used for site to site comparison

• Consolidated Data Entry• Data Element Manual• Data entry required since January 2013• This is NOT a performance indicator but

can be used for site to site comparison

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Groundwater CDE ReportingGroundwater CDE Reporting

• Common Errors– Entering “0” for tritium

• This should be your detection limit

– Do not need to enter for multiple Units• Enter the data in one unit• Data is a site indicator not unit

– Someone knowledgeable validating data

• Common Errors– Entering “0” for tritium

• This should be your detection limit

– Do not need to enter for multiple Units• Enter the data in one unit• Data is a site indicator not unit

– Someone knowledgeable validating data

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NEI 09-14 Underground Piping and TankIntegrity InitiativeNEI 09-14 Underground Piping and TankIntegrity Initiative

• Licensed (radioactive) material/safety-related/environmentally hazardous

• INPO’s Role– Evaluate program effectiveness– Communicate issues to the industry– Compile and report operating experience

• Licensed (radioactive) material/safety-related/environmentally hazardous

• INPO’s Role– Evaluate program effectiveness– Communicate issues to the industry– Compile and report operating experience

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Plant Responsibilities ICES/NEI 09-14Plant Responsibilities ICES/NEI 09-14

Utilities will enter operating experience related to the itemsbelow into INPO’s (EPIX now ICES) database wheninstances occur. Entries shall be made in a timeframeconsistent with ICES timing requirements.

• Leaks from buried piping• Significant leaks from buried piping: defined as those

which meet either of the following criteria• Reportable under NRC, EPA, or state regulation or the Ground

Water Protection Initiative, or• Result in the system or component being out of service

• Adverse inspection findings: defined as indications frominspections that require a major repair within one cycle

Source: NEI 09-14 Appendix A

Utilities will enter operating experience related to the itemsbelow into INPO’s (EPIX now ICES) database wheninstances occur. Entries shall be made in a timeframeconsistent with ICES timing requirements.

• Leaks from buried piping• Significant leaks from buried piping: defined as those

which meet either of the following criteria• Reportable under NRC, EPA, or state regulation or the Ground

Water Protection Initiative, or• Result in the system or component being out of service

• Adverse inspection findings: defined as indications frominspections that require a major repair within one cycle

Source: NEI 09-14 Appendix A

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Areas for ImprovementAreas for Improvement

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0

2

4

6

8

10

12

2007 2008 2009 2010 2011 2012 2013 2014

Leaks Program U/G & CP CP TOTAL AFIs

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2012 AFI Summary2012 AFI Summary

• Nine AFIs; Four Performance Deficiencies– Five – underground piping– Four - cathodic protection

• Improvement needed– Leak extent of condition addressed– Risk ranking review thoroughness– Leaks occurring and the source is unknown

– Input results in ICES (small number unacceptable)

– Cathodic protection health or none installed

• Nine AFIs; Four Performance Deficiencies– Five – underground piping– Four - cathodic protection

• Improvement needed– Leak extent of condition addressed– Risk ranking review thoroughness– Leaks occurring and the source is unknown

– Input results in ICES (small number unacceptable)

– Cathodic protection health or none installed

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2014 Summary2014 Summary• Two AFIs; Four Performance Deficiencies

– Two – underground piping– Four – cathodic protection

• Improvement needed– Degraded coatings and cathodic protection not

properly maintained– Cathodic protection equipment work

prioritization and completion– Cathodic protection site knowledge weaknesses– Leaks occurring and the source is not

determined

• Two AFIs; Four Performance Deficiencies– Two – underground piping– Four – cathodic protection

• Improvement needed– Degraded coatings and cathodic protection not

properly maintained– Cathodic protection equipment work

prioritization and completion– Cathodic protection site knowledge weaknesses– Leaks occurring and the source is not

determined

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NSIAC – industry oversightNSIAC – industry oversight

• Chief Nuclear Officers• Approved NEI 07-07 and 09-14• Status implementation progress• Discuss Trends• Discuss Gaps

• Chief Nuclear Officers• Approved NEI 07-07 and 09-14• Status implementation progress• Discuss Trends• Discuss Gaps

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• Expected outcome: Improved analytical capabilities result in anaccurate and reliable picture of plant and industry performanceand emerging trends

• Merges EPIX, Plant Events Database, LERs and NPRDS eventreports into an integrated system

• Improves user access

– INPO members and authorized participants

– rapid access to information

– eliminates current manual processing needed before data isusable

• Each station has an OE coordinator who is trained to enter yourdata

• Expected outcome: Improved analytical capabilities result in anaccurate and reliable picture of plant and industry performanceand emerging trends

• Merges EPIX, Plant Events Database, LERs and NPRDS eventreports into an integrated system

• Improves user access

– INPO members and authorized participants

– rapid access to information

– eliminates current manual processing needed before data isusable

• Each station has an OE coordinator who is trained to enter yourdata

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Most Commonly Affected SystemsRelative to NEI 09-14Most Commonly Affected SystemsRelative to NEI 09-14

0

10

20

30

40

50

60

Essential ServiceWater System

Sanitary WasteProcessing System

Liquid WasteManagement System

CVC/Makeup andPurification Sys.

(PWR)

Condensate Storageand Transfer System

Wastewater Disposalsystem

Source: ICES 2008 -2014

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Radiation Monitors (RMS)Radiation Monitors (RMS)

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Radiation Monitors (RMS)Radiation Monitors (RMS)• RMS equipment reliability is a focus area for

many utilities

o Radiation Monitor downtime could result in delay inS/G tube rupture detection and response

• NRC issued IN 2013 – 13, July 2013 - EffluentRMS Deficiencies

• 8 years since last NMAC-related product

o 2003 System Guide – 1007909

o 2005 Calibration Guide – 1011965

• RMS equipment reliability is a focus area formany utilities

o Radiation Monitor downtime could result in delay inS/G tube rupture detection and response

• NRC issued IN 2013 – 13, July 2013 - EffluentRMS Deficiencies

• 8 years since last NMAC-related product

o 2003 System Guide – 1007909

o 2005 Calibration Guide – 1011965

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Industry guidance for RMSIndustry guidance for RMS

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2003 System Guide – 1007909

• Regulatory requirements summary

• Industry Operating Experience

• Troubleshooting guidance

• Equipment obsolescence

2005 Calibration Guide - 1011965•Troubleshooting guidance

• Reference for calibration requirements

and procedures

2003 System Guide – 1007909

• Regulatory requirements summary

• Industry Operating Experience

• Troubleshooting guidance

• Equipment obsolescence

2005 Calibration Guide - 1011965•Troubleshooting guidance

• Reference for calibration requirements

and procedures

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Radiation Monitors (RMS)Radiation Monitors (RMS)• ICES Reports 2009 through 2013• ICES Reports 2009 through 2013

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Radiation Monitors (RMS)Radiation Monitors (RMS)

• Maintenance issues:– Not included in Maintenance Rule– Lack of PM templates

• Sample line cleaning, filters, circuit boards

• Replacements and Obsolescence– Long lead times– Cost for upgrades

• Maintenance issues:– Not included in Maintenance Rule– Lack of PM templates

• Sample line cleaning, filters, circuit boards

• Replacements and Obsolescence– Long lead times– Cost for upgrades

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Radiation Monitors (RMS)Radiation Monitors (RMS)

• Next steps– Work with EPRI and the industry on

• INPO Event Report– Includes recommendations to improve reliability

• Knowledge of currently available guidance• Possible NMAC PM template development

• Next steps– Work with EPRI and the industry on

• INPO Event Report– Includes recommendations to improve reliability

• Knowledge of currently available guidance• Possible NMAC PM template development

© 2014 Institute of Nuclear Power Operations

I n s t i t u t e o f N u c l e a r P o w e r O p e r a t i o n sI n s t i t u t e o f N u c l e a r P o w e r O p e r a t i o n s

Questions?

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I n s t i t u t e o f N u c l e a r P o w e r O p e r a t i o n sI n s t i t u t e o f N u c l e a r P o w e r O p e r a t i o n s

To promote excellence in the operationof commercial nuclear power plants.

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