ML051890400

U1R28 Reduced Inventory Orange Path Contingency Plan

ML051890400
Person / Time
Site:	Point Beach
Issue date:	04/02/2004
From:	Debauche S, Schoon D, Shaw J Nuclear Management Co
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2004-0282
Download: ML051890400 (11)

Text

2-7 U1R28 Reduced Inventory Contingency Plan Rev 1, April 2, 2004 Nuclear Power Business Unit U1R28 REDUCED-INVENTORY ORANGE PATH CONTINGENCY PLAN Revision: I Prepared by Steve DeBauche , 4 9 Date: 412104 Name (Print) Signature Shift Outage Manager fly Date/

\) Sc(hiaV/ Date: - r Name (Print) Signati Plant Manager (or designee)

Approval: (Pr-nt) Date:

Name (Print) Signature Revision I Added 5 SW pumps and SW piping to and from the CC HXs on El 46' to the protected equipment list. Changed "UI CCW A Train" to "UI CCW A Train including required CC Es". Reason:

Comments from NRC Weekly Meeting 04/01/2004. Ref item 20040401-03 B SCOPE SUINDARY:

In accordance with NP 10.3.6, "Outage Safety Review and Safety Assessment', PORC approval is required for Rev. 0 of this plan for the entry into an Orange Path.

JUSTIFICATION:

Orange path entry for nozzle dam installation and removal will increase the efficiency of outage activities by allowing SIG eddy current testing during fuel motion.

Orange path entry is permitted in accordance with NP 103.6 provided contingency plans are in place to 4 L H4 lnfimatlon Inthis record Was deleted inaccordance with th9 Freedom of Information Page I of 11 5 Act,exmtos

• U12 eue netoyCnignyPa

. U1R28 Reduced Inventory Contingency Plan

• Rev I, April 2,2004 CONTINGENCY PLAN DESCRIPTION

1. Maintaining Defense-in-Depth Protected equipment is listed in daily plantloutage status reports and is posted on the Shutdown Safety Status Boards located throughout the plant to inform personnel of equipment needed for defense-in-depth. The areas where protected equipment is located will also be posted to heighten awareness of personnel working in the areas as to the importance of the equipment for shutdown safety. Work on protected equipment shall be prohibited, unless the work is required to maintain equipment operability (i.e., checking oil levels, adjusting packing, etc.).

Review of scheduled outage activities for impact on defense-in-depth / key safety functions is performed by Programs Engineering (EPP). EPP' shall review the entire outage schedule, added outage activities, and FIN team work activities for impact on defense-in-depth to ensure defense-in-depth is maintained and to verify that appropriate logic ties are in the schedule to'preclude Inappropriate work during the reduced inventory condition. Certain activities are not allowed to be conducted in the reduced inventory condition, unless a safety assessment is performed as identified in NP 103.6, Revision 11. This requirement is based on an NRC commitment transmitted via letter VPNPD-93-003 dated January 7, 1993. The following text is quoted from NP 10.3.6:

Tle physical listing of allowed work, eg., exceptions to the requirements described above, will be provided by Outage Planning2 and will be attached to the copies of this document that are in the possession of the Shift Manager, Outage Control Center, and Control Room.

' Contact is Dave Black 2 Contact is Mike Bull Page 2 of 11

U1R28 Reduced Inventory Contingency Plan Rev 1 , April 2,2004 The Shift Technical Advisers (STAs) or Engineering personnel assigned, monitor Key Safety Functions once for each 12-hour shift and document this via form PBF-1562, PBNP Shutdown Safety Assessment and Fire Condition Checklist. The Key Safety Function monitor also conducts a walkdown of sensitive fire protection and equipment areas to ensure no fire risks exist In areas where RHR and CCW cabling is routed, to verify no work is being conducted on protected equipment and to verify credited equipment is available.

2. Restoring Defense-in-Depth

3. Minimizing the Likelihood of a Loss of a Key Safety Function Minimizing the likelihood of a loss of a key safety function is accomplished as follows:

(1) Engineering Programs performs continuing assessment of the outage schedule and emergent activities for impact on maintaining defense-in-depth and key safety functions.

(2) The PPG Outage Planning group shall ensure activities proposed to be added to the schedule and which might be scheduled while in a reduced inventory condition are reviewed by Engineering Programs. EPP will consult with Operations/SROs as needed. The PPG Manager or his designee will then approve the activity for inclusion in the outage schedule.

(3) Protected equipment and / or areas containing protected equipipent shall be Identified prominently in the field per the requirements of NP 103.6, 'Outage Safety Review and Safety Assessment".

(4) The STAs or engineering designee monitor Key Safety Functions once for each 12-hour shift and document this via form PBF-15 62, PBNP Shutdown Safety Assessment and Fire Condition Checklist.

(5) Critical evolutions for entering a reduced inventory condition are controlled by Operations via existing plant procedures as follows: OP 4D Part 1, "Draining the Reactor Coolant System" (IPTE); OP 4F,

'Reactor Coolant System Reduced Inventory Requirements"; and OP 5A (IPTE for Section B), "Reactor Coolant Volume Control".

(6) The "Contingency Steps for Reduced Inventory" will be reviewed by Operations during each shift briefing while the RCS Is In reduced Inventory.

(7) The OCC will evaluate the impact of shift change on critical activities during reduced inventory. For example, raising RCS level to exit fill and vent, S/G manway Installation or removal, or nozzle dam activities. The OCC will, in a timely manner, recommend actions to minimize or manage the impact of turnover on reduced inventory activities. Recommendations could include moving craft resources from other work, holding personnel over (subject to labor agreement), calling personnel in early or allowing the turnover to take place normally.

Page 3 of 11

UIRA Reduced Irventory Contingency Plan Rev 1 , April 2,2004 Page 4 of II

U1R28 Reduced Inventory Contingency Plan Rev 1 April 2, 2004 L.esponsiboi Date It Signature Place Controls in place to ensure activities added to the outage schedule, and FIN activities during reduced inventory are reviewed by EPP prior to approval.

EPPIPPG Safety assessment review of current schedule complete.

EPP The physical listing of allowed work, e.g., exceptions to the work activities that are restricted during mid loop(as defined byNP 103.6), will be provided by Outage Planning3 and will be attached to the copies of this document that are in the possession of the Shift Manager, Outage Control Center, and Control Room.

Outage Manager

£X.

OP 4D IPTE Scheduled; Operations review of Contingency Plan during Shift Briefings scheduled; Containment Closure Checklist CL-1E in place, and maintained. Ensure a copy of this plan is available in the control room during mid loop.

Operations Manager Maintenance personnel working S/G manways and/or nozzle dam installation or removal are briefed that the plant is in an orange path each shift while in reduced inventory.

Maintenance Manager In the interest of efficient inter-group communications, an OCC representative will attend the Ops Shift Brief and Maint Mechanical Shift Brief while the plant is in reduced inventory.

Outage Manager 3 Contact is Mike Bull Pare 5 of 11

UlR2B Reduced Inventory Contingency Plan Rev I April 2,2004 DESCRIPTION lwsponsIDIe I aote in

_ _7__ ___ Signature Place Plant personnel will be notified when the plant is in the reduced inventory orange path. Examples of communication methods that could be used are: South gate electronic display, shutdown safety status boards, postings, PBTV messages, etc.

0CC The OCC will evaluate the impact of shift change on critical activities during reduced Inventory. For example, raising RCS level to exit reduced inventory, S/G manway installation or removal, or nozzle dam activities. The OCC will, in a timely manner, recommend actions to minimize or manage the Impact of turnover on reduced inventory activities.

Recommendations could include moving craft resources from other work, holding personnel over (subject to labor agreement), calling personnel in early or allowing the turnover to take place normally.

0CC _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Handouts will be developed and distributed to plant employees at south gate. The handouts will inform personnel that the plant is in a vulnerable condition in mid loop.

Sara Cassidy Page6ofll

U1R28 Reduced Inventory Contingency Plan Rev I, April 2, 2004 Responsibli In DESCRIPTION Signature I I Controls in place to ensure activities added to the outage schedule, and FIN activities during reduced inventory are reviewed by EPP prior to approval.

EPP/PPG Safety assessment review of current schedule complete.

EPP The physical listing of allowed work, e.g., exceptions to the work activities that are restricted during mid loop(as defined by NP 10.3.6), will be provided by Outage Planning 4 and will be attached to the copies of this document that are in the possession of the Shift Manager, Outage Control Center, and Control Room.

Outage Manager OP 4D IPTE Scheduled; Operations review of Contingency Plan during Shift Briefings scheduled; Containment Closure Checklist CL-1E in place, and maintained. Ensure a copy of this plan is available in the control room during mid loop.

Operations Manager Maintenance personnel working SIG manways and/or nozzle dam installation or removal are briefed that the plant is in an orange path each shift while in reduced inventory.

Maintenance Manager In the interest of efficient inter-group communications, an OCC representative will attend the Ops Shift Brief and Maint Mechanical Shift Brief while the plant is in reduced inventory.

Outage Manager 4Contact is Mike Bull Page 7 of II

U1R28 Reduced Inventory Contingency Plan Rev I, April 2, 2004 iS II DESCRIPTIONSintrPac Responsible SiinaturePlace Date In Plant personnel will be notified when the plant is in the reduced inventory orange path. Examples of communication methods that could be used are: South gate electronic display, shutdown safety status boards, postings, PBTV messages, etc.

0CC The OCC will evaluate the impact of shift change on critical activities during reduced inventory. For example, raising RCS level to exit reduced Inventory, SIG manway installation or removal, or nozzle dam activities. The 0CC will, in a timely manner, recommend actions to minimize or manage the impact of turnover on reduced inventory activities.

Recommendations could include moving craft resources from other work, holding personnel over (subject to labor agreement), calling personnel in early or allowing the turnover to take place normally.

Handouts will be developed and distributed to plant employees at south gate. The handouts will inform personnel that the plant is in a vulnerable condition in mid loop.

Sara Cassidy Page 8 of 11

UIR28 Reduced Inventory Contingency Plan Rev I ,April 2, 2004 Page 9 of 11

UIR28 Reduced Inventory Contingency Plan Rev I, April 2, 2004 I

1t Page lOofli

If UIR28 Reduced Inventory Contingency Plan Rev I , April 2, 2004 CONTACTS (OWNERS)

Dave Dyzak (Outage Manager) PPG 6812 5088

.Brian Dungan OPS 6826 6503 Mike Bull PPG 6597 5780 Duane Schoon PPG 6680 3127 Jim Brander (acting Maintenance Manager) MTN 6432 4459 Rick Wood EPP 7434 3124 Dave Black PE/PRA 6204 6076 Sara Cassidy Comm 6748 6398 Page 11 of 11