ML112590546

Inspection Plan Memo to Fred Brown During Extended Shutdown

ML112590546
Person / Time
Site:	Crystal River
Issue date:	09/16/2011
From:	Croteau R Division Reactor Projects II
To:	Frederick Brown Division of Inspection and Regional Support
References
Download: ML112590546 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 September 16, 2011 MEMORANDRUM TO: Frederick D. Brown, Director Division of Inspection and Regional Support Office of Nuclear Reactor Regulation FROM: Richard P. Croteau, Director /RA/

Division of Reactor Projects

SUBJECT:

NRC OVERSIGHT OF CRYSTAL RIVER UNIT 3 DURING EXTENDED SHUTDOWN Crystal River Unit 3 has been in an extended outage since September 2009 when the Unit was shutdown for steam generator replacement. Completion of outage activities and restart of the plant have been delayed due to the occurrence of internal cracking within the containment walls.

Initial repairs were completed in 2010 but additional cracking occurred during retensioning of the containment building tendons. In June 2011 the licensee announced plans to repair the containment building and estimated the Unit would return to service by 2014.

To implement the Reactor Oversight Process (ROP) at Crystal River Unit 3, Region II intends to implement Manual Chapter (MC) 0351, Implementation of the Reactor Oversight Process at Reactor Facilities in an Extended Shutdown Condition for Reasons Other Than Significant Performance Problems. Region II has prepared the enclosed inspection plan in accordance with MC 0351 which describes the planned inspections during the extended shutdown. MC 0351, Section 04.03 states the Director, Division of Inspection and Regional Support, is required to concur with the regional decision to implement this MC and any associated inspection plan.

Region II hereby requests this concurrence. The inspection plan addresses accomplishment of the Reactor Oversight Process Baseline inspection procedures and includes observations of the planned structural repairs to the containment building. Inspections will verify acceptable performance of major testing activities including tests associated with steam generator replacement, the containment building structural integrity test, and the containment integrated leak rate test. The inspection plan describes the current status of performance indicators and inspections planned to address invalid performance indicators. As plant repairs and testing near completion, the inspection plan will be amended, with NRR concurrence, to focus on readiness for restart, including an Operational Readiness Assessment Inspection.

Enclosure:

As stated CONTACT: Daniel W. Rich, DRP/RII 404-997-4721

______ML112590546________ X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRS RII:DRS SIGNATURE GJW /RA/ DWR /RA/ JER /RA/ HOC /RA/

NAME GWilson DRich JOrtiz-Rivera HChristensen DATE 09/08/2011 09/08/2011 09/12/2011 09/13/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO Crystal River Unit 3 Inspection Plan Background Information:

Crystal River Unit 3 was shutdown on September 26, 2009, for a steam generator replacement refueling outage. During the creation of a temporary opening in the reactor containment building to support steam generator replacement, the licensee discovered an internal crack (also called a delamination) in the wall of Bay 3-4 of the concrete containment. Bay 3-4 was subsequently repaired and retensioning of the containment building tendons began in January 2011. In March 2011 delamination of Bay 5-6 occurred during retensioning. In June 2011 Progress Energy announced the decision to repair the reactor building, including an estimate that repairs should be completed and the Unit returned to service in 2014. The unit is currently in a No-Mode condition with the core fully offloaded to the spent fuel pool.

MC 0351, Implementation of the Reactor Oversight Process at Reactor Facilities in an Extended Shutdown Condition for Reasons other than Significant Performance Problems, will be implemented for Crystal River. This inspection plan is prepared in accordance with MC 0351 and documents how the objectives of the ROP will be met.

This inspection plan is valid for the entire shutdown period, but will be updated as necessary based on the licensees progress in returning the Unit to operation. Within six months of Unit restart, the plan will be updated, with NRR concurrence, to reflect those inspections necessary to ensure operational readiness of the licensee for reactor restart, including an Operational Readiness Assessment inspection.

INSPECTION PLAN

1. BASELINE INSPECTIONS

a. The following Resident Inspector Baseline inspection procedures (IP) are expected to be completed with at least the minimum number of samples as specified in the respective IP. One additional inspection sample will be performed in the area of operator training.

In order to maintain an adequate level of oversight of licensed operator proficiency, the licensed operator requalification quarterly observation by the resident inspectors shall be performed twice per quarter, which is twice the level of effort required by the ROP baseline.

IP Number Title/Section Comments 71111.01 Adverse Weather Protection 71111.04Q Equipment Alignment/Partial 71111.04S Equipment Alignment/Complete 71111.05Q Fire Protection/walkdowns 71111.05S Fire Protection/Fire Drill 71111.06 Flood Protection Measures 71111.07A Heat Sink Performance Enclosure

2 71111.11Q Licensed Operator Twice per quarter Requalification

• 71111.12 Maintenance Effectiveness 71111.19 Post Maintenance Testing 71111.20 Refueling and Outage Activities 71111.22 Surveillance Testing 71114.06 Drill Evaluation 71153 Event Follow-up & Notices of Enforcement Disc.

71130.11 Material Control &

Accountability/Due 2013

b. The available inspection samples for the following Resident Inspector Baseline IPs will be performed, however the number of available samples may be below the minimum specified for the baseline:

IP Number Title/section Comments 71111.13 Maintenance Risk Assessment & IP is not applicable with the Emergent Work Control unit shutdown.

Maintenance Risk assessment is performed under IP 71111.20 71111.15 Operability Determination and Due to the extended Functionality Assessments shutdown period, availability of samples is limited 71111.18 Plant Modifications Due to the extended shutdown period, availability of samples may be limited.

71151 Performance Indicator (PI) Verification Reference PI section 71152 Problem Identification and Resolution The required annual sample (PI&R) for Operator Work Arounds (OWAs) will not be completed during the extended shutdown period since OWAs are not applicable with the core offloaded to the spent fuel pool (SFP).

Enclosure

3

c. DRS BASELINE and OTHER TEAM INSPECTIONS IP Number Title/section Comments 71114.01,-.04 Exercise Eval/Emergency Action Level Complete as specified by IP (EAL) and Emergency Preparedness (EP) changes 71130.0X Security Baseline Inspection Complete as specified by IP 71124.0X Radiation Protection (RP) Inspections Adjust level of effort based on plant conditions 71152B Problem Identification and Resolution, Complete as specified by IP Biennial Inspection 711111.17T Evaluations of Changes, Tests, or Periodicity and scope left to Experiments and Permanent Regional Discretion.

Plant Modifications 71111.21 Component Design Basis Inspection Complete as specified by IP 71111.08 In-Service Inspection Adjust level of effort based on plant conditions

d. ADDITIONAL TARGETED INSPECTIONS TO BE COMPLETED UNDER THE ABOVE ROP PROCEDURES:

SYSTEM/AREA INSPECTION COMMENTS PROCEDURE Foreign Material Exclusion 71111.20 Verify controls are in place (FME) controls of the Spent to ensure containment Fuel Pool (SFP) area during repair activities are not containment repair activities impacting the SFP.

SFP Safety 71111.20 (also using Ensure that containment applicable guidance repair activities have no contained in IP 60801, impact on the SFP and Spent Fuel Pool Safety at SFP cooling support Permanently Shutdown systems.

Reactors)

Operations Training 71111.11 Residents: Additional quarterly inspection during extended shutdown period.

DRS: Inspection to verify operator readiness for restart (within ~3 months of unit startup)

Enclosure

4

e. REACTOR BUILDING REPAIR INSPECTION IP Number Title/section Comments 50001 Steam Generator This IP will continue to be used Replacement Inspection to support inspections associated with the repair of the containment. The lead for this inspection will be the Division of Reactor Safety with assistance from the CR3 Resident Inspectors. DRS should provide an inspection plan that covers containment repair and testing activities (Integrated Leak Rate Test (ILRT)and Structural Integrity (SIT))

46051, 46053, 46055, Structural Concrete These IPs will be implemented 46061, 46071 Procedure/ Work as necessary; structural Observation/Record concrete work is not anticipated Review/Masonry to occur in 2011.

Construction/Expansion Anchors

f. LAYUP INSPECTIONS IP Number Title/section Comments Building Spray, Emergency 71152 These systems are in a Feedwater (EFW), Makeup layup condition. Perform an (MU), Reactor Coolant Annual Sample to verify Systems (RCS) and Once satisfactory implementation Through Steam Generators of layup requirements (OTSG)

2. PERFORMANCE INDICATORS (PIs)

Due to the extended shutdown, several PIs are no longer valid. The table below lists invalid PIs and describes those ROP inspections necessary to compensate for PIs which are no longer valid.

Performance Indicator ROP inspections planned Comments during Extended Shutdown Unplanned Scrams, None PIs are not valid.

Unplanned Power Changes, Unplanned Scrams and and Unplanned Scrams with Unplanned Power Changes Complications PIs will be valid after the unit is critical for 2400 hrs.

Enclosure

5 Performance Indicator ROP inspections planned Comments during Extended Shutdown Unplanned Scrams with Complications PI will become valid after unit startup RCS leakage and Activity None PIs are not valid. RCS Leakage will become valid in Mode 4, RCS activity PI will become valid in Mode 3

(>500F)

Mitigating Systems NONE See Notes 1, 2 Note 3 Performance Indicator (MSPI) Emergency Alternating Current (Emergency Diesel Generator)

MSPI HP Safety Injection NONE See Notes 1, 2 Note 3 (MU System)

MSPI Heat Removal (EFW) NONE See Notes 1, 2 Note 3 MSPI Residual Heat NONE See Notes 1, 2 Note 3 Removal (Decay Heat Removal)

MSPI Cooling Water NONE See Notes 1, 2 Note 3 (Service Water (SW),

Decay Heat Closed Cycle (DC), Raw Water (RW) systems)

PIs associated with EP, RP Routine DRS inspections. PIs remain valid and Safeguards, Note 1: MSPIs consist of the sum of the unavailability of the applicable systems plus the unreliability for the system during the previous twelve quarters. Unavailability is only counted if the reactor is critical. Based on the lack of critical hours since Sept 2009 and the projection that the unit will remain shutdown until CY 2014, the MSPIs are invalid. MSPI inspections specified in IP 71151 will not be performed until after unit startup.

Note 2: The emergency AC system (EDG), DHR system, and the cooling water systems (RW/SW/DC) will continue to be routinely surveillance tested (in-service testing) by the licensee.

For these systems there continues to be an opportunity to identify Mitigating Systems (MS) functional failures and other system problems. To provide confidence the licensee is properly maintaining these systems, the resident inspectors will continue to perform baseline ROP inspections (PMT, Surveillance, Mods, operability etc) for these systems. The MU and EFW systems have NOT been routinely operated or surveillance tested during the extended outage.

If opportunities arise, the residents will perform baseline inspections for the MU and EFW systems. Annually, the resident inspectors will inspect the MU and EFW systems using the Enclosure

6 guidance of IP 71111.04, Equipment Alignment, Section 02.02, Complete Walkdown. The two complete alignment samples for the MU and EFW systems are in addition to the level of effort specified in IP 71111.04 for complete alignments.

Note 3: After unit restart, data submitted by the licensee will be reviewed utilizing IP 71151 on at least an annual basis. Additional inspections will be performed to compensate for invalid PIs until sufficient data has accumulated to provide for each valid PI.

Enclosure