3F0397-19, Forwards Sys Readiness Review Plan & Schedule for Completion of Plan,Per Request
| ML20137G532 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/27/1997 |
| From: | Holden J FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 3F0397-19, 3F397-19, NUDOCS 9704010420 | |
| Download: ML20137G532 (5) | |
Text
.
9 Florida Power CORPOVDON EsE' March 27, 1997 3F0397-19 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
System Readiness Review Plan
References:
A. NRC to FPC letter, 3N1096-05, dated October 9, 1996 B. FPC to NRC letter, 3F0297-01, dated February 8, 1997
Dear Sir:
In Reference A, the NRC requested information on the adequacy and availability of design bases information for Crystal River Unit 3 (CR-3), pursuant to 10 CFR 50.54(f).
Florida Power Corporation (FPC) provided the requested information in Reference B, and committed to provide the NRC with additional information on our System Readiness Review Plan (SRRP) by the end of March,1997 with a schedule for completion of the plan.
An Executive Summary (Attachment 1) discusses the SRRP as a comprehensive effort to assure the conformance of the plant design, testing, maintenance, operation, and configuration with licensing and design requirements.
A more detailed discussion of the System Readiness Review Plan is included as Attachment 2, i
System Readiness Revfew Plan, Rev.1, to provide additional information related g
j to this comprehensive effort. The SRRP review will be completed prior to start-up from the current outage.
FPC is in the process of incorporating the review plan into the integrated start-up schedule.
Enclosed, as Attachment 3, is an overview schedule for Phase I of the SRRP.
9704010420 970327 PDR ADOCK 05000302 P
PDR CRYSTAL RIVER ENERGY COMPLEX: 15700 W Power Une St. Crystal River, Fkmda 3442S6708
- C35a 7E6486 A Floride Progrene Company IIll2lEElllllI,0lllllEE
r U. S. Nuclear Regulatory Ccmmission 3F0397 ;
.Page 2 of 2 Since the System Readiness Review Plan is a major activity within the FPC Restart i
Plan, FPC suggests a separate presentation to the NRC to review the programmatic and administrative aspects of the SRRP prior to our next NRC Restart Panel Meeting. Upon completicn of Phase I activities for the Level 1 systems, FPC is recommending a second meeting at the plant site in May,1997 to review and present the plant physical condition aspects of the SRRP and to discuss Level I system review results with the NRC.
i Should you have any questions or require additional information, please contact Brian Gutherman at (352) 563-4566.
Sincerely, J. J. Holden, Director Nuclear Engineering and Projects JJH/BG Attachment xc:
Regional Administrator, Region II Senior Resident Inspector NRR Project Manager
.Pago 1 of 3 l
SYSTEM READINESS REVIEW PLAN EXECUTIVE
SUMMARY
1 The System Readiness Review Plan (SRRP) is a comprehensive effort to assess the conformance of the plant design,
- testing, maintenance, operation, and configuration with licensing and design requirements.
It utilized i
sampling / vertical slice methodology with a graded approach for more risk significant systems. In conjunction with other ongoing program enhancements and initiatives at CR-3, the SRRP will provide reasonable assurance that the system operation is:
Capable of Meeting its Functional Requirement Within Regulatory Design Basis Within Licensing Basis 4
The SRRP consists of a four phase process:
Phase I:
Initial System Readiness Review Phase II:
Restart Activities Monitoring Phase III:
Final System Readiness Review Phase IV: Start-up and Power Ascension Phase I of the SRRP is the " discovery" process which is described as system j
assessments. These assessments encapsulate a review of the system's functional requirements, design / licensing basis documentation, and outstanding work activities. The final input to the Phase I activities is a system walkdown for configuration verification and material condition evaluation.
The assessment 4
reviews and walkdown results determine system restart work scope.
)
During Phase II, work in progress is monitored to assure complete resolution of restart issues.
Periodic system walkdowns will be performed to trend work progress.
Upon completion of each work activity and acceptance by the system manager, the tracks
. base will be updated to document closure of the restart work activity.
Emeeg.. issues that arise will be screened for inclusion as a restart work activity.
When the cumulative system restart work activities are about 80% complete, Phase III of the SRRP will commence. This phase will include a review of work not to l
be completed prior to restart for aggregate impact on system readiness. A final system walkdown will be conducted for evaluation of the system capability to support start-up and safe operation of CR-3.
A Final System Readiness Report will be presented to management for approval.
At Phase IV, the system manager will monitor the system during plant start-up.
Testing activities performed at a system level will be reviewed to assess the individual and aggregate results of system performance to support plant operation.
The system manager will continue to monitor system start-up activities and focus on areas which require corrective maintenance and/or enhancements.
1 I
i 4
d w
. ~.._ _ _ _.._ _ _. _ _
.Page 2 of 3 j
- The System Readiness Review Plan will be implemented for 105 plant systems using a graded approach methodology. Each of the systems were classified into one of three levels. The level classification was determined by a safety significance process relying on three aspects. The first aspect utilized a fission product barrier approach (examples: fuel clad, reactor coolant system, or containment integrity) to comply with 10 CFR 50, Appendix A II. The second aspect relied on an analytical approach which took into consideration several system specific factors such as:
PSA Model Importance i
Maintenance Rule Risk Significance Improved Technical Specification Safety Significance Safety Classification The third aspect considered previous assessment results and findings, number of 4
modifications performed on the system, and other opportunities for configuration changes. Based on these aspects, the systems are classified as Level 1, Level l
2, and Level 3.
Level 1 systems will receive the most comprehensive review and will involve l
extensive research of design and licensing basis documentation to identify the parameters and attributes for inclusion in the System Readiness Review Matrix.
This level receives a review that uses Safety System Function Inspection (SSFI) j methodology applied to 30 topic areas that address the categories of:
Design Basis Licensing Basis Operations i
Maintenance Surveillance Physical plant configuration, and L
Programs, processes, and procedures i
Systems receiving a level I review are:
j Makeup and Purification (MU) 1 Decay Heat Removal (DH) i-Emergency Feedwater (EF) and Emergency Feedwater Initiation and 3
Control (EFIC)
Emergency Diesel Generators (EG) and the EG support systems t
Engineered Safeguards-(ES) j' Core Flood (CF)
Reactor Coolant (RC)
Level 2 systems will receive a system readiness assessment that also uses SSFI 4
methodology but applied to a more limited review of topic areas.
This review will also focus on design and licensing basis compliance as well as modifications, open work activities, and previous assessment results.
In l
addition to the standard Level 2 topic reviews, generic issues identified in Level I system reviews and evaluated as having potential safety significant impact within other systems will be added in Level 2 system reviews.
.Page 3 of 3-i Systems receiving a Level 2 review are:
i Auxiliary Electrical Power (MT) j DC Electrical Distribution (DP) 3 Reactor Building Spray-(BS)
Air Handling Systems for the Control Complex (AH-XK), Reactor Building Recirculation-(AH-XA), and Auxiliary Building Exhaust (AH-XJ)
Nuclear Services Closed Cycle Cooling (SW)~
Nuclear Services and Decay Heat Seawater (RW)
Decay Heat Closed Cycle Cooling (DC) i Control Rod Drive (DR)
Main Steam (MS)
Waste Disposal-(WD)
Radiation Monitoring-(RM)
Annunciator System (AN)
Chemical Addition (CA)
Spent Fuel Cooling (SF)
Nuclear Instrumentation (NI)
Reactor Protection. System (RP)
Containment Access (RA)
The balance of systems will receive a Level 3 system reviews.
These systems receive an "open item" assessment of outstanding work activities for inclusion as a restart work activity. Open items cons _ist of outstanding work activities i
such as: Request for Engineering Assistance (REA), Nuclear Operations Tracking l
and Expediting System (NOTES) work activities, Corrective Action Process open items (Precursor Cards) - and open Work Requests.
Design and licensing basis documents are assessed to ensure these identified open items do not compromise CR-3's design basis or licensing basis complhnce.
All deficiencies identified 'within the SRRP will be entered into our Corrective
- Action Program and will be evaluated against FPC Restart Panel screening criteria for inclusion as a restart work activity.
The System Readiness Review Plan in conjunction with other program enhancements 1
will provide reasonable assurance that.CR-3 will be able to operate within its design and licensing basis. It will assess the conformance of the plant design, testing, maintenance, operation, and plant configuration with design and licensing basis requirements.
.--