ML20199J560
| ML20199J560 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/13/1997 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20199J485 | List: |
| References | |
| 0AP-022, AP-22, NUDOCS 9802050342 | |
| Download: ML20199J560 (36) | |
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l CP&L CAROLINA POWER & LIGHT COMPANY Information BRUNSWICK NUCLEAR PLANT Use PLANT OPERATING MANUAL VOLUME I ADMINISTRATIVE PROCEDURE
'B N P RECIPIEEID UNIT col $"bLLED
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OCT 101997 NUCLEAR DOCUMENTCONTROL ll llil l!ll Ill ll l IIIIIlI!!IllilIlIl ll 0/iP-022 BNP OUTAGE RISK MANAGEMENT REVISION 2 EFFEC IVE DATE
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Vice President - Brunswick Nuclear Plant Date Director - Site Operations 1882 288M M 8sa 6 P
PDR OAP-022 Rev.2 Page 1 of 36
REVISION
SUMMARY
l Clerical Revision due to conversion of procedure from Wordperfect 5.1 DOS to Microsoft Word 7.0.
LIST OF EFFECTIVE PAGES 0AP-22 l-Paoe(s)
Revision 1 36 2
0AP-022 Rev.2 Page 2 of 36
TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE....................................................................................................5
2.0 REFERENCES
.................................................................................................5 3.0 DEF1NITIONS............................................................................................6 3.1 Ava ila b le (Ava ila bility)............................................................................. 6 3.2 C o n t i n g e n cy P l a n.................................................................................... 6 3.3 De ca y H e at R em oval Ca pa bility.............................................................. 6 3.4 D e fe n s e I n D e p t h...................................................................................... 7 3.5 F u n c ti o n a 1....................................................................................
3.0 H ig he r Ris k Evolutio n s............................................................................ 7 3.7 I n v e n to ry C o n t rol.................................................................................... 7 3.8 K e y S a fe ty F u n etio n s............................................................................... 7 3.9 Operable............................................................................................7 3.10 R e a ctivity C o n t rol....................................................................... 8 4.0 R E S P O N SI B I LiTI E S..................................,...
............ 8 4.1 Pla nt G e n e ra 1 M a n a g e r...............................................
.8 4.2 Manager-Site Support Services................
................. 9 4.3 Ma na ger - Reg ulatory Affairs......................................................... 9 4.4 Manager-Brunswick Engineering Support....................................... 9 4.5 Manager - Outage and Scheduling.................................................. 10 5.0 MANAGEMENT OUTAGE SAFETY PHILOSOPHY............................
10 5.1 Integ rated Ma na geme nt...........................................
..............10 5.2 Level of Activities............................
11 5.3 Dense in Depth.....
....................................................12 5.4 Contingency Plans.
13 5.5 T ra i n i n g..................................................
... 13 5.6 Outage Risk Assessment Review.......
14 6.0 DEFENSE IN DEPTH OUTAGE PLANNING AND SCHEDULING GUIDELINES /REVIEWCHECKLIST...
14 6.1 Decay Heat Removal....
14 6.2 Fuel Pool Cooling...
17 6.3 Makeup Capability.
18 6.4 Reactor Water Level Control....
19 6.5 Secondary Containment.
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0AP-022 Rev.2 Page 3 of 33 e
TABLE OF CONTENTS SECTION
'PAGE 6.6. -
Reactivity Control...
.............................................................................23 6.7 Electrical Powe r Ditmr.,- an.................................................................. 24 6.8 Hyd ra ulic a nd Mech & rucal S n u.n>ers.......................................................... 24 6.9 Miscellaneous G uidelines/ Reviews............................................................. 24 7.0 INDEPENDENT OUTAGE RISK ASSESSMENT PROCESS...........................,.. 26 7.1 '
Initial Review of the Outage Plan and Schedule......................................... 26 t
8.0 RISK ASSESSMENTOF EMERGENTWORK OR ACTIVITY SCHEDULE CHANGES.........................................................................................................,27 ATTACHMENT 1 S a fety Sig n ifica n ce Dete rmin ation........................................................................ 3 0 FORMS 1 -Safety Sig nifica nce Determination Log............................................................... 34 2 Sche J ule C h a n g e a p p roval..,..............,..............,.............................................. 3 5 -
3: U nit Key S a fety F u n etio n Sta t u s........................................................................... - 36 I
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Rev.2 Page 4 of 36
1.0 PURPOSE This procedure communicates the Plant Management Outage Safety Philosophy and provides guidance to be used in meeting the objectives and goals of that Philosophy, it is applicable to all planned outages and outage activities until the Reactor is placed in Operational MODE 2 for the purposes of taking the reactor critical for startup. The safety philosophy of integrated management, level of activities, Defense in Depth, and contingency planning is applied to planned and emergent activities for forced outages. The Plant General Manager and/or the Manager Outages and Scheduling may extend the implementation of this procedure to include a formal risk assessment should the duration or complexity of a forced outage require it. This planning guide is not intended to supersede Technical Specifications or Plant Operating Procedures. If conflicts arise, the Plant Operating Procedures and Technical Specifications will take precedence.
l The Outage Goalis to perform high priority work while minimizing risk and meeting or exceeding regulatory, radiolocical, and safety goals established for the outage.
The BNP policy with respect to outage safety is to utilize the DEFENSE IN DEPTH concept to conduct outages which minimize risk to the public, to employees, to the non-outage unit, and to the financial investment in the plant.
2.0 REFERENCES
2.1 NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Safety l
Management.
2.2 Supplemental BWR Guidance for NUMARC 91-06 2.3 NUREG 1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States 2.4 OAP-23, Outage Planning 2.5 PLP-24, Work Management Process 2.6 0AP-018, Safety Rules 2.7
'PLP-17, ldentification, Development, Review, and Conduct of infrequently Performed Tests or Evolutions 2.8 01-01, Conduct of Operations Manual 2.9 OAP-001, Overtime Scheduling OAP-022 Rev.2 Page 5 of 36
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2.0 REFERENCES
2.10 PLP 28, Startup and Power Ascension Management Plan following an Outage 2.11 PLP 29, Self-Assessment for Readiness to Startup Following an Outage 4
1 2.12 ADM NGGC-0101, Maintenance Rule Program lR13l 2.13 BNP Unit 1 and Unit 2 Operating Licenses as indicated in Amendment Nos.
183 and 214. Source / Reference Documents BSEP 96-0340/BSEP 96-0123.
3.0 DEFINITIONS The following list of definitions are terms related to shutdown conditions and are defined specifically for their use in discussions of shutdown risk management.
3.1 Available (AvailabillW)
The status of a system, structure or component that is in service or can be placed in service in a FUNCTIONAL or OPERABLE state by either manual or automatic means.
3.2 Contingency Plan-An approved plan of compensatory actions:
3.2.1 To maintain DEFENSE IN DEPTH by alternate means when pre-outage planning reveals that specified systems, structures or compcnents will not be AVAILABLE; 3.2.2 To restore DEFENSE IN DEPTH when system AVAILABILITY drops below the planned DEFENSE IN DEPTH during the outage; 3.2.3 To minimiza the likelihood of a loss of KEY SAFETY FUNCTIONS during HIGHER RISK EVOLUTIONS.
3.3 Decay Heat Removal Capability The ability to maintain reactor coolant temperature within the limits required by NDT considerations to ensure the structural integrity of ASME Code Class 1,2, and 3 components and to maintain the Fuel Pool temperature less than 150 F with the fuel pool gates removed or with core off-loaded and fuel pool gates installed.
0AP-022 Rev. 2 Page 6 of 36
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3.0 DEFINITIONS 3.4 Defense In Depth For the purpose of managing risk during shutdown, DEFENSE IN DEPTH is the concept of:
3.4.1 Providing systems, structures and components to provide backup of KEY SAFETY FUNCTIONS using redundant, alternate or diverse methods; 3.4.2 Planning and scheduling outage activities in a manner that will optimize safety system AVAILABILITY; 3.4.3 Providing administrative controls to support and/or supplement the above elements.
3.5 Functional The ability of a system or compone't to perform its intended service. The applicable Technical Specifications requirements or licensing / design basis assumptions may not be maintained.
3.6 Higher Risk Evolutions Outage activities, plart configurations or conditions during shutdown where the plant is more susceptible to an event causing the loss of a KEY SAFETY FUNCTION.
J.7 inventory Control Measures established to ensure that irradiated fuel remains covered with coolant to maintain heat transfer and shielding requirements.
3.8 Key Safety Functions During shutdown, the KEY SAFETY FUNCTIONS are: Decay Heat Removal, Water Inventory Control, Power Availability, Reactivity Control, and Secondary Containment Control.
3.9 Operable The ability of a system to perform its specified function with all applicable Technical Specification requirements satisfied. (See Technical Specifications for more detail.)
0AP-022 Rev.2 Page 7 of 36
3.0 DEFINITIONS 3.10 Reactivity Control Measures established to preclude inadvertent criticality, power excursions or losses of shutdown margin and to maintain the ability to monitor and predict core behavior, 4.0 RESPONSIBILITIES This section delineates the responsibi!ities of managers for implementation of this procedure.
4.1 Plant General Manager The Plant General Manager is responsible for:
4.1.1-Ensuring that an outage schedule is developed in accordance with Sections 5.1, 5.2, 5.3, and 5.4.
l 4.1.2 Ensuring that Contingency Plans are available in accordance with Section 5.4.
4.1.3 Ensuring that scheduled work for both the outage and non outage unit is accomplished in a manner which maintains the Outage Safety Philosophy of Section 5.0.
4.1.4 Ensuring that personnel are trained in Outage Philosophy as required by Section 5.5.
4.1.5
- Ensuring that an Outage Risk Assessment Review is conducted prior to approval of the Schedule as required by Section 5.6.
4.1.6 Ensuring that emergent work or activity schedule changes are processed in accordance with Section 8.0.
-4.1.7 Ensuring that the required support to develop the outage schedule in accordance with Section 5.0 is available from his organization.
4.1.8 Ensuring that a post-outage review is conducted as required by Section 5.1.5.
0AP-022 Rev.2 Page 8 of 36
4.2 Manager - Site Support Services i
The Manager - Site Support Services is responsible for:
4.2.1 Ensuring that his scheduled work is accomplished in a manner which maintains the Outage Philosophy of Section 5.0.
4.2.2 Ensuring that his personnel are trained in Outage Philosophy as required by Section 5.5.
4.2.3 Ensuring that the required s-
- ort to develop the outage schedule in accordance with Section 5.0 is available from his organization.
4.3 Manager-Regulatory Affairs The Manager - F. alatory Affairs is responsible for:
4.3.1 Ensuring that his scheduled work is accomplished in a manner which maintains the Outage Philosophy of Section 5.0.
4.3.2 Ensuring that his personnel are trained in Outage Philosophy as required by Section 5.5.
4.3.3 Ensuring that the required support to develop the outage schedule in accordance with Section 5.0 is available from his organization.
4.4 Manager - Brunswick Engineering Support The Manager - Brunswick Engineering Support is responsible for:
4.4.1 Ensuring that his scheduled work is accomplished in a manner which maintains the Outage Philosophy of Section 5.0.
4.4.2 Ensuring that his personnel are trained in Outage Philosophy as required by Section 5.5.
4.4.3 Ensuring that the required support to develop the outage schedu.. in accordr. ace with Section 5.0 is available from his organization.
0AP-022 Rev. 2 Page 9 of 36 m
4.5 Manager - Outage and Scheduling The Aanager - Outage and Scheduling is responsible for:
4.5.1 Organizing an independent outage risk assessment of each BNP planned outagts and designating the Risk Assessment Team Leader (see Section 7.0).
4.5.2 Producing the outage schedule at the direction of the Plant General Manager (see Section 4.1.1).
5.0 MANAGEMENT OUTAGE SAFETY PHILOSGPHY Senior Management Outage Safety Philosophy consists of the following elements:
- 1. Integrated Management
- 2. Levelof Activities
- 3. Defense in Depth
- 4. Contingency Plaris
- 5. Training
- 6. Outage Risk Assessment Review Each Manager will ensure that this philosophy is communicated to their personnelinvolved in planning and executing the outage.
5.1 Integrated Management 5.1.1 Senior Management philosophy regarding outage nuclear safety will be communicated to all personnelinvolved in planning and executing the outage as described in Section 5.5, Training.
5.1.2 Outage schedules will be developed through interaction with involved organizations and disciplines to assure that the planning provides DEFENSE IN DEPTH throughout the outage. Outage activities will be controlled and implemented in accordance with the approved schedule.
f Page 10 of 36 0AP-022 Rev.2
I 5.1 Integrated Management 5.1,3 The logic and basis used to develop the laitial schedule will also be applied to any safety significant schedule changes that might occur before or during the outage. For any schedule change, the level of review and approval authority necessary to implement the change will i
be defined.-
j 5.1.4 The current plant status, including the AVAILABILITY of key safety systems or equipment, will be communicated on a regular basis to plant / site personnel who perform or affect work within the plant (Form 3). HIGHER RISK EVOLUTIONS will also be conveyed including any appropriate precautions or compensatory actions necessary during _
these periods.
5.1.5 A post outage critique will be cor ducted that assesses outage performance from a safety perspective. The results of the critique will be used as a basis for improvements to planning and control of future outages. This may be accomplished through the management of a common " Lessons Learned" data base.
5.2 Level of Activities 5.2.1 The outage work scope and schedule will endeavor to match resources to activities and time constraints. Additional resources will be available to meet anticipated emergent scope. The work scope will be prioritized to allow appropriate decisions when scope change is required.
5,2.2 Activities in the outage schedule will be sufficiently detailed and organized to accurately convey the impact on complex evolutions, plant conditions, and equipment AVAILABILITY, 5.2.3 During HIGHER RISK EVOLUTIONS of infrequently performed -
evolutions, any activity that may negatively impact a KEY SAFETY FUNCTION must be limited and strictly controlled.
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5.2.4 Outage planning and execution shall consider the potential introduction of hazards (e.g., fire, flooding, etc.) posed by the level and scope of activities in a given area of the plant and establish compensatory measures as appropriate.
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0AP-022 Rev.2 Page 11 of 36 y
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5.2 Level of Activities 5.2.5 Overtime during outages will be controlled in accordance with established plant procedures. Administrative Procedure OAP-001, establisher limits and approval authority for overtime.
These limits are important since excess overtime can result in an increase in safe shutdown risk.
5.3 Defense in Depth 5.3.1 The outage schedule shall establish systems, structures and components (SSCs) to provide backup for KEY SAFETY FUNCTIONS. The SSCs tracked on the key Safety Function Status Sheet (Form 3) is consistent with the maintenance rule SSCs. The backup capabilities provided v.'ill be commensurate with plant conditions.
5.3.2 Outage planning shall optimize safety system availability. Systems shall be returned to service; either OPERABLE when required l
Technical Specifications, or FUNCTIONAL, as soon as practietta following completion of scheduled work per PLP-29.
5.3.3 The functionality of systems and components shall be assured. This will be accomplished through post maintenance testing, plant modification acceptance testing, monitoring of the key parameters with the system in service, verification of system alignment and administrative control by operations personnel, etc. This requirement is especially important for systems, components, or structures being returned to service following repair or modification.
5.3.4 Systems, structures and components identified to provide DEFENSE IN DEPTH during periods of the outage shall be controlled such that they remain AVAILABLE during these periods.
5.3.5 Plant procedures shall ensure that they minimize the probability of loss of a KEY SAFETY FUNCTION, and that the consequences of a loss of a KEY SAFETY FUNCTION is minimized to the extent practicable.
0AP-022 Rev. 2 Page 12 of 36
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5.4 Contingency Plana 5.4.1 CONTINGENCY PLANS shall be available when entering a HIGHER RISK EVOLUTION.
5.4.2 CONTINGENCY PLANS shall be developed when system availabili y drops below the planntsd DEFENSE IN DEPTH.
5.4.3 CONTINGENCY PLANS should consider the use of alternate equipment to respond to the loss of dedicated safety and monitoring equipment, and should consider additional monitoring or controls to minimize the potential for unplanned equipment unavailability.
Contingency Plans may be documented in any normal work control process such as ESRs, WR/JOs, or as a ceparately approved procedure.
5.4.4 Personnel who may be required to implement a CONTINGENCY PLAN shall be identified and be familiar with the plan.
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5.5 Training 5.5.1 Operator training e iall provide knowledge of the applicable shutdown safety issues incitding loss of DECAY HEAT REMOVAL, INVENTORY CONTROL, POWER AVAILABILITY, REACTIVITY CONTROL and CONTAINMENT. To the extent practicable, simulatoi training for shutdown conditions shall also be included.
5.5.2 Plant personnel, including contractors and others temporarily assigned to support the outage, shall be trained on the Outage Safety Philosophy of Section 5.0 as it applies to their job. This will be accomplished by General Employee Training, skill qualification training, license training, pre-job briefings, mock-up training, coaching, etc. The t(aining needs to ensure that the employee knows how his specific work activity could cause a reduction of the DEFENSE IN DEPTH element of the safety philosophy. The training should also emphasize considering possible contingencies if a work activity does not proceed as expected. The extent and manner of the training will be determined by the manager in charge of the work.
0AP-022 Rev.2 Page 13 of 36
5.6 Outage Risk Assessment Review 5.6.1 Prior to the catage, the schedule shall be reviewed by a multi-disciplined group knowledgeable in senior management philosophy for outage nuclear safety and plant operat;ons. The review group should include individuals knowledgeable in areas of Management, Engineering, Maintenance, Outage Planning and Scheduling and Operations. At least one member must have held a Senior Reactor Operator License at Brunswick. The review shall not be conducted solely by those directly involved in the developmcat and preparation of the outage schedule.
5.6.2 The review shall assess the adequacy of the DEFENSE IN DEPTH provided for the duration of the outage and for consistency with the outage safety policy. This review, following the Defense in Depth Outage Planning ar.d Scheduling Guidelines / Review Checklist, shall also include a det*Jed examination of the outage schedule, including system interactions, support system availability, and the impact of l
temporarily installed equipment.
5.6.3 The review shall ensure that HIGHER RISK EVOLUTIONS are clearly identified in the schedule and that CONTINGENCY PLANS and mitigating procedures have been developed and are adequate.
5.6.4 The review shall include a review of industry experience relative to shutdown events.
5.6.5 Safety significant schedule or scope changes wh;ch occur after the outage schedule is approved shall receive a review to assess the impact on the planned DEFENSE IN DEPTH. The Plant Nuclear Safety Committee shall review any changes which would result in not meeting the DEFENSE IN DEPTH criteria or creates a HIGHER RISK EVOLUTION.
6.0 DEFENSE IN DEPTH OUTAGE PLANNING AND SCHEDULING GUIDELINES / REVIEW CHECKLIST 6.1 Decay Heat Removal Any combination of core cooling and fuel pool cooling methods may be utilized when the fuel pool gates are removed as long as the requirements of Sections 6.1.1 through 6.1.7 are fulfilled.
0AP-022 Rev.2 Page 14 of 36
1 6.1..
l 6.1.1 Due to high heat loads when the reactor is first shutdown, the Nuclear Service Water header with a minimum of one (1) N'; clear Service Water Pump, the Conventional SeGe Water Header with a minimum of two (2) Conventional Service Water Pumps and both "A" l
and "B" RHR Service Water Loops and RHR Loops will be maintained AVAILABLE for DE^t Y HEAT REMOVAL for twenty-four i
(24) hours after reaching the pressure at which RHR System can be placed in shutdown cooling.-
6.1.2 Core Cooling System interlocks will be evaluated for applicability to shutdown conditions. Consideration will be given to disabling logic or interlocks that are evaluated as' detrimental or ineffective for a give_n condition. Examples are: ECCS initiation logic and shutdown cooling isolation logic for high reactor pressure or low reactor vessel level
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once the reactor cavity has been flooded to normal refueling level.
6.1.3 Outage activities on components within or that directly interface with the core cooling system will be evaluated for risk / impact before being i
performed. An example is maintenance on Reactor Recirculation System valves which could divert (bypass) flow from the Reactor Core.
6.1.4 Activities which may negatively impact the Core Cooling System / Components should be scheduled during periods of low decay heat or during defueled conditions. If such activities must be scheduled during periods of high decay heat, then CONTINGENCY PLANS must be established.
6.1.5 A primary and backup means of core cooling will be maintained.
Either the primary or the backup system must have its emergency power supplies available.= Any combination of RHR Pumps may be used including redundant pumps in the same loop. Redundancy within the RHR SW Loops must be provided consistent with the RHR i
loops. This level of DEFENSE IN DEPTH is an objective of the outage plan. PNSC review is required prior to reducing the level of safety to less than that level defined by the DEFENSE IN DEPTH concept. The systems available to meet this objective are:
1.
A Loop RHR (A or C RHR pump, A RHR Heat Exchanger, A or C RHR Booster Pump along with a source of service water and the i
required piping and support components,is defined as A Loop RHR j-SDC for the intent of this procedure.
0AP-022 Rev.2 Page 15 of 36
6.1.
Dacay Haat R!movci 2.
B Loop RHR (B or D RHR pump, B RHR Heat Exch' anger, B or D RHR SW Booster Pump along with a source of service water and the required piping and support components, is defined as B Loop RHR SDC for the intent of this procedure.
3.
For items 1 and 2 above, the other RHR and RHR Service Water Pump in the same loop may provide the necessary redundancy as required by the NUMARC guidelines and this procedure.
4.
Due to its energy absorption capability and losses to ambient, the reactor cavity when flooded to normal refueling level may be considered an appropriate DECAY HEAT REMOVAL backup.
5.
Condenser Cooling mode (a flow path from the Reactor to the condenser then returned to the reactor through filters and/or demineralizers via the Condensate and Feedwater Systems) operation.
The ability to circulate the Reactor Vessel to prevent stratification and accurate bulk temperature determination is also required. The condenser cooling mode is not a normally relied upon (scheduled)
DECAY HEAT REMOVAL method. Condenser cooling requires:
a.
Two main steam lines b.
One feedwater line c.
Recirculation Loop A c. Recirculation Loop B or RHR Loop A with one pump cr RHR Loop B with one pump for forced recirculation to provide accurate temperature indication d.
Circulating Water System with two intake pumps e.
One condensate pump f
EHC System with one pump g.
Conventional Service Water System h.
TBCCW System i.
Instrument and Service Air System 0AP-022 Rev.2 Page 16 of 36 I
6.1.
DIcay H2at R:m:: val 6.1.6 The suitability of a system as a DECAY HEAT REMOVAL System does not directly relate to its Technical Specification operability status. Since Decay Heat generation will vary with core power history, the decay heat removal capability required will also vary. A system is considered to be AVAILABLE if it can be used to maintain core temperature below the boiling point and below the temperature limit imposed by Technical Specifications. As decay heat generation diminishes, additional systems, such as Core Spray, ECCS System Keepfill, Control Rod Drive, Fuel Pool Cooling, Supplemental Fuel Pool Cooling, etc., become capable of providing adequate DECAY HEAT REMOVAL capability. The System Engineer will be utilized to provide guidance if questions arise about the ability of a system to remove decay heat in a given situation. DEFENSE IN DEPTH is met for the DECAY HEAT REMOVAL Safety Function when a primary and a backup DECAY HEAT REMOVAL System is AVAILABLE, each being capable of removing decay heat, and the Emergency Core l
Cooling Systems Technical Specifications are met. Either the primary or the backup DECAY HEAT REMOVAL system must have an Emergency power supply AVAILABLE in order to satisfy the DEFENSE IN DEPTH requirements.
6.1.7 A primary and backup means of coolant temperature indication will be l
maintained at all times, unless specific exemption is granted by the Operations Manager.
lR13l 6.1.8 A DECAY HEAT load calmlation for the reactor, reactor cavity, and fuel pool will be completes fore the start of each outage to verify adequacy of Decay Heat h,ioval Systems and facilitate the calculation of time to boil during the outage.
6.2 Fuel Pool Coollag Any combination of core cooling and fuel pool cooling methods may be utilized when the fuel pool gates are removed as long as the requirements of Sections 6.1.1 through 6.1.8 are fulfilled.
6.2.1
-The outage schedule will provide a DEFENSE IN DEPTH commensurate with the risk associated with loss of Fuel Pool cooling.
0AP-022 Rev.2 Page 17 of 36
6.2.
Fuel Pool Cooling 6.2.2 When the core has been off-loaded to the fuel pool, the guidelines that apply to core cooling also apply to the Fuel Pool. A primary and -
a backup means of cooling the fuel pool must be available and at least one of these systems must be capable of being powered from an emergency power supply. Each system must be capable of maintaining fuel pool temperature at 150*F or less. The support systems for Fuel Pool Cooling must be equally redundant, i.e., the RBCCW pumps AVAILABLE must have a source of emergency power, and the Service Water System must have a source of backup emergency power.
i 6.2.3 DEFENSE IN DEPTH is met for Fuel Pool Cooling when a primary means and a backup means of Fuel Pool cooling is AVAILABLE.
Each system must be capable of maintaining fuel pool temperature at 150*F or less under the worst anticipated heat load.
6,3 Makeup Capability 6.3.1 A system capable of flooding the Reactor Coolant System to provide adequate core cooling through submergence shall be AVAILABLE when fuelis in the reactor vessel.
6.3.2 A source of make-up water adequate to reflood the core following the worst credible Loss of_ Coolant Accident for the present plant condition shall always be AVAILABLE to the Reactor Coolant System.
6.3.3 Systems available for core flooding:
1.
"A" Core Spray 2.
"B" Core Spray 3.
"A" RHR LPCI Mode with "A" and/or "C" pump 4.
"B" RHR LPCI Mode with "B" and/or "D" pump 5.
Conuensate/Feedwater System 6.
Control Rod Drive System 0AP-022 Rev.2 Page 18 of 36
6.3 Makeup Capability 7.
Fire main via RHR SW and RHR System 8.
Service Water cross-tie to RHR System 6.3.4 A source of make-up water adequate to provide make-up to the Spent Fuel Pool with a peak heat load from the decay heat of the full core at the end of a fuel cycle plus the remaining decay heat of the spent fuel shall be available when the fuel pool gates are installed.
6.3.5 Systems available for fuel pool make-up:
1.
Osmineralized Water System to the skimmer surge tank.
2.
L.Mi Loop "A" via the RHR A/B Loop cross tie valve.
3.
LPCI Loop "B" to the fuel pool 4.
Demineralized Water and/or "B" RHR Service water cross tie to the "B" RHR System.
5.
Class (Category) l Source of make-up which meets the requirements of Regulatory Guide 1.13, 6.3.6 DEFENSE IN DEPTH is met for the Makeup Capability Safety Function when a primary and a backup core flooding and/or Fuel Pool Makeup system is AVAILABLE and the Technical Specifications for the Emergency Core Cooling Systems are met. A system is considered to be AVAILABLE when it is capable of providing makeup flow commensurate with present plant conditions and activities.
When plant conditions are being controlled such that a potential to drain the vessel does not exist, the required makeup capability can be significantly reducedi The primary or the backup system must have an AVAILABLE source of emergency power.
6.4 Reactor Water Level Control 6.4.1 The E11-F008 and/or E11-F009 isolation function on low RPV water level shoula be FUNCTIONAL when both valves are open and the reactor cavity water level is below normal refueling level.
0AP-022 Rev.2 Page 19 of 36
6,4 R act:r Wat:r Lsv:1 Centr:I 6.4.2 Administrative controls will be used for any valves which can cause rapid inventory loss. Typical examples are the reject to Radwaste, E11-F040 and E11-F049, and the RHR minimum flow valve to the Suppression Pool E11-F007A and E11-F007B, 6.4.3 Maintenance and testing of reactor safety relief valve acoation logic should not be scheduled while the vessel is flooded above 640" unless Main Steam Line plugs are installed, if these activities must be performed, procedures will require that valve actuation be disabled. Operators will monitor vessel water level during the activity and be prepared to take mitigative actions.
6.4.4 Plant configurations where a single active failure or personnel error can result in a rapid loss of reactor water will be identified and minimized to the extent possible.
6.4.5 Restoration guidance for returning systems to service will emphasize the proper sequencing of steps and proper positioning of critical valves and switches.
6.4.6 For activities that may impact the reactor water level, procedures or work instructions will clearly stipulate the initial plant conditions and will also include appropriate warnings and cautions.
6.4.7 Evolutions that deliberately alter Reactor Vessel level control flow paths will be strictly controlled and monitored.
6.4.8 Freeze seals employed in locations that can impact Reactor Vessel coolant inventory will be carefully and continuously monitored, and their use must be reviewed and accepted by PNSC Appropriate CONTINGENCY PLANS will be established and ready for implementation in the event of a freeze seal failure.
6.4.9 Removal of control rod blades and control rod drive mechanisms can be performed simultaneously after establishing administrative controls to preclude inadvertently establishing a flow path from the vessel.
6.4.10 Main Steam Line (MSL) plugs will be used to prevent Reactor cavity or fuel pool drain down through safety relief valves or main steam isolation valves. MSL plugs will have a backup air supply available as part of the CONTINGENCY PLAN for loss of plant instrument air.
0AP-022 Rev.2 Page 20 of 36
6.4 Reactor Water Level Control 6.4.11 When Main Steam Line plugs, Reactor recirculation suction plugs, or jet pump plugs are the sole barrier preventing drain down, a makeup source of sufficient injection capacity will be AVAILABLE to compensate for a failure of a plug. Time spent in this configuration will be minimized. This requirement is not applicable when the fuelis in the fuel pool and the gates are installed.
6.4.12 A FUNCTIONAL flood up system capable of makeup flow to the Reactor Pressure Vessel will be AVAILABLE at all times when the cavity is flooded and the fuel pool gates are removed. These systems are:
1.
"A" Core Spray 2.
"B" Core Spray 3.
"A" RHR LPCI Mode with "A" and/or "C" Pump 4.
"B" RHR LPCI Mode with "B" and/or "D" Pump 9
5.
Condensate /Feedwater System 6.
Demineralized Watea 7.
Condensate Transfer 8.
Control Rod Drive System 9.
Fire Main 10.
Service Water 6.4.13 in addition to makeup capability either a reject capability must be available or level stabilized with no influent or effluent flow. Systems used for reject are:
1.
RWCU System 2.
Fuel Pool Cooling System 0AP-022 Rev.2 Page 21 of 36
.u
6.4 Re:ctar W:t:r Level Control 3.
"B" RHR to Radwaste 4.
Various drains with appropriate controls established (Cavity Drains, Main Ste' m Lines, Bottom head Drain, Recirculation System, etc.)
a 6.4.14 When the cavity is flooded and the fuel pool gates are removed, DEFENSE IN DEPTH is met for the Reactor Water Level Control Safety Function when a primary and backup FUNCTIONAL flood up system is available and capable of providing makeup flow to the Reactor Pressure Vessel. DEFENSE IN DEPTH is also met when plant configurations, activities or evolutions are identified, minimized, strictly controlled and monitored where a single failure or personnel error can result in a rapid loss of Reactor water or alter reactor vessel level control flow paths. Freeze seals, maintenance and testing of relief valve actuation logic, removal of control rods and control rod drives, and use of Main Steam Line plugs are examples of plant configurations, activities or evolutions that are strictly controlled and l
maintained.
6.5 Secondary Containment 6.5.1 Secondary Containment shall be maintained OPERABLE:
1.
During core alterations 2.
When handling irradiated fuel in the secondary containment.
3.
From unit shutdown until Reactor Vessel disassembly is complete and during Reactor Vessel reassembly.
4.
When required by Technical Specifications.
6.5.2 In cases where (1) RHR fuel pool cooling assist is disabled, (2) fuel pool cooling capability is reduced, or (3) the fuel pool gates are installed following a full core off-load (high decay heat load):
At least one SBGT train and secondary containment shall be maintained FUNCTIONAL such that they can be manually initiated if necessary. The FUNCTIONAL SBGT train shall have a backup emergency power source. This requirement can be relaxed when Engineering has determined that the decay heat load has decreased enough to provide a high level of corifidence that fuel pool temperature will be maintained below the temperature at which significant amounts of iodine would be released.
0AP-022 Rev.2 Page 22 of 36 m..
6.5
_ Secondary Containment 6.5.3 A FUNCTIONAL secondary containment is one that can be established in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or within the time to reach boiling in the coolant with at least one SBGT Train that can be manually started.
6.5.4 DEFENSE IN DEPTH is met for the Secondary Containment Safety Function when the Containment Technical Specification Requirements have been met and the secondary containment requirements of Steps 6.5.1 through 6.5.3 have been met.
6.6 Reactivity Control 6.6.1 Fuel movement in the reactor vessel will not occur simultaneously with control rod drive mechanism maintenance unless an engineering analysis has been performed to demonstrate adequate shutdown margin exists and that controls exist to prevent entering an unanalyzed condition.
6.6.2 Fuel cells will be ioaded into the reactor vessel only after positive verification control rods are inserted.
l 6.6.3 Changes to the refueling sequence will be controlled using the same technical bases used to develop the original refueling sequence.
6.6.4 Fuel moves will be verified in accordance with the fuel handling procedures.
6.6.5 Reactor coolant temperature must be maintained above the minimum temperature used for shutdown margin calculation. The Reactor coolant temperature restrictions will be clearly communicated to personnel in control of reactor coolant temperature.
6.6.6 DEFENSE IN DEPTH is met for the REACTIVI'iY CONTROL Safety Function when the REACTIVITY CONTROL, Instrumentation, and Refueling Technical Specifications are met and the guidance given in this procedure has been adhered to. The Reactor Mode switch provides a means of enforcing restrictions on reactivity affecting controls and devices commensurate with the plant conditions.
)
0AP-022 Rev. 2 Page 23 of 36
6.7 Electrical Power Distribution 6.7.1 Activity in the switchyard will be severely limited when a Diesel Generator is out of service.
6.7.2 The Electrical Distribution System should be aligned for UAT backfeed when extended (> 14 days) outages are planned that include scheduled DG unavailability.
6.7.3 Physical work will be limited to one division at a time. When work is occurring in one division, the other division shall receive elevated attention to maintain that division FUNCTIONAL.
6.7.4 Each unit shall have a Primary and a backup source of AC Power at all times. The Primary Source will be from the UAT (backfeed) or the SAT. The UAT and SAT shall have two incoming 230KV lines capable of supplying power. The backup power source shall be a Diesel Generator capable of supplying power to the respective emergency bus.
6.7.5 DEFENSE IN DEPTH is met for the AC Power Safety Function when both emergency buses are being fed from the UAT or SAT and at least one of the emergency buses has a FUNCTIONAL Diesel Generator capable of supplying rated load to the emergency bus.
6.8 Hydraulic and Mechanical Snubbers Hydraulic and mechanical snubbers shall be OPERABLE when located on systems required to be OPERABLE, per Technical Specifications, for the present plant condition.
6.9 Miscellaneous "-ulrielines/ Reviews 6.9.1 Verify that plant procedures / policies address the following issues:
1.
Coolant inventory loss (EOPs) 2.
Fire stop/ penetration seal control (FPP-015) 3.
Confined space work permits (Al-66) 4.
Asbestos control (AP-15) 0AP-022 Rev.2 Page 24 of 36 a
6.9 Miscellaneous Guidelines / Reviews 5.
ALARA and radiation protection (E&RC-40/45) 6.
Control of transient combustibles (FPP-014) 7.
Working hours and overtime (AP-001) 8.
Fitness For Duty restrictions (SEC NGGC-2101) 9.
Control of infrequently performed tests or evolutions (PLP-17) 10.
Post Maintenance Testing (PLP-20) 11.
Temporary power arrangements (ENP-14) 12.
Access control (SI-09)
L l
13.
Loss of Fuel Pool Cooling (AOP-38) 6.9.2 Review the outage schedule for activities or combinations of activities I
that could possibly present a challenge to the shutdown safety functions. A plot of the KEY SAFETY SYSTEM STATUS for the entire outage will be performed during this review.
6.9.3 Review the outage schedule to ensure that work activities scheduled for the Main' Control Room vM; not have a negative impact on plant operations.
6.9.4 Review the outage schedule for activities that could potentially impact the operation of the other unit or affect the available resources required to safely operate the other unit (PLP-28 Attachment 11).
0AP-022 Rev.2 Page 25 of 36
- 7.0 -
INDEPENDENT OUTAGE RISK ASSESSMENT PROCESS 7.1 Initial Review of the Outage Plan and Schedule 7.1.1 The Superintendent Outages is responsibla for organizing an independent outage risk assessment of each BNP planned outage and designating the Risk Assessment Team Leader The Risk Assessment Team will be comprised of multi-disciplined personnel, with the majority of the team not directly involved in the development of the outage plan and schedule which is being reviewed. Some personnel who were directly involved in developing the schedule may be assigned to facilitate the Risk Assessment Team's effons by explaining the scheduling logic, answering BNP specific questions, etc. At least one team member must have held an SRO license at BNP.
7.1.2 The timing of the review will be coordinated so that there is a high i
level of confidence in the accracy of the Outage Schedule yet sufficient time remains prior to the start of the outage to respond to the Risk Assessment Team's recommendations.
I 7.1.3 The Outage Plan and Schedule shall be reviewed and accepted by the PNSC following the Risk Assessment Team's review and resolution of their comments. The Superintendent Outages _ is responsible for briefing the Vice President - BNP and the Director Site Operations on the outage plan.
l 7.1.4 The Risk Assessment Team Leader is responsible for managing the efforts of the team members during the review and conducting an exit meeting with the Superintendent Outages or his designee. The Risk Assessment Team Leader will clearly identify any recommendation resulting from the review and deliver a draft written report at the exit meeting. The Risk Assessment Team Leader is also responsible for delivery of the final written report within one week of completing the review. The Team Leader may request,if desired, a written response to any or all of the Review Team's recommendations.
7.1.5 The Superintendent Outages will ensure that the Risk Assessment Team's recommendations are placed on an appropriate tracking system (if needed), responsible individuals assigned, and completion dates set appropriate to the significance and priority of each recommendation.
0AP-022 Rev. 2 Page 26 of 36
7.1 Initial Review of the Outage Plan and Schedulo 7.1.6 If the Risk Assessment Team Leader has requested a written response, the Superintendent Outages is responsible for negotiating a response date with the Team Leader and preparing and submitting the response as negotiated.
7.1.7 Outage Risk Assessment and Management (ORAM) Computer Based Risk Assessment Program is utilized daily to verify key shutdown safety functions are maintained. Items identified by the Risk Assessment Team are verified by ORAM and any differences reconciled.
8.0 RISK ASSESSMENT OF EMERGENT WORK OR ACTIVITY SCHEDULE 3
CHANGES 8.1 Risk Assessment of outage scope additions / deletions and schedule changes from the start of the Risk Assessment until the Reactor Mode switch is placed in Mode 2 for the purpose of Reactor startup is the responsibility of the Manager Outages and Scheduling and will follow the assessment guidelines prescribed in this section. The Superintendent Outages is responsible for implementing the scope addition / deletion and schedule change review and documentation process. The Outage SRO reviews scope and schedule changes until the Shift Outage Manager (SOM) is put in place. The SOM reviews scope and schedule changes until the Reactor mode switch is placed in Mode 2 for Reactor Startup.
8.2 Outage scope (additions / deletions) changes are initiated and dispositioned in accordance with 0AP-23. Scope additions / deletions Risk Assessment reviews are documented on FORM 1. Schedule changes are reviewed, approved and documented on FORM 2.
NOTE:
The Operations Shift Superintendent has the authority to cause any work activity to occur or to cease the work activity as he deems necessary to maintain the plant in a safe condition.
8.3 For the cases where scope or schedule changes cannot be performed within a scheduled Level I window without:
8.3.1 affecting the other unit, or 8.3.2 moves another Level I window or schedule milestones, or 0AP-022 Rev.2 Page 27 of 36
8.0 RISK ASSESSMENT OF EMERGENT WORK OR ACTIVITY SCHEDULE CHANGES 8.3.3 w;.ich changes a schedule logic constraint or logic ties to a defined safety significant activity, or 8.3.4 moves a major scope of work The Scheduler will initiate a Form 2 and forward to the Outage SRO/SOM. The Outage SRO/ Shift Outage Manager wih perform an assessment of the proposed change. This review will determine if the activity will reduce the planned DEFENSE IN DEPTH or create a HIGHER RISK EVOLUTION. He may initiate an assessment team to review the proposed change. if an assessment team is required it will consist of the following members:
Outage and Scheduling Manager or designee i
Operations Manager or designee l
Engineering Manager or designee l
Maintenance Manager or designee A typical designee for these managers could be the outage on shift managers for each functional area, such as, the Shift Outage Manager for the Outage and Scheduling Manager, i
8.4 Proposed scope changes or schedule changes which are det rmined by the assessment team review to reduce the planned DEFENSE IN DEPTH, or are considered to be HIGHER RISK EVOLUTIONS, will require additional evaluation and approval prior to implementation. A PNSC review is required by Section 5.6.5 prior to including the activity in the schedule.
8.5 The Outage SRO/ Shift Outage Manager is responsible for the day-to-day utilization of Form 1 and Form 2 per Step 8.2 above. The Superintendent Outage Management is responsible for maintaining the historical file of Form is and Form 2s documenting the assessment of proposed work additions or schedule activity changes.
0AP-022 Rev.2 Page 28 of 36 l
8.0-RISK ASSESSMENT OF EMERGENT WORK OR ACTIVITY SCHEDULE CHANGES 8.6 The assessment of the proposed scope change is as follows:
l' 8.6.1 The initial review is performed by the Outage SRO/ Shift Outage Manager or designee, using Form 1. If this evaluation indicates that the activity is not significant to safety, then the activity can be incorporated into the outage scope. If the response to BOTH Criterion 1 and Criterion 2 are NO, then the activity is not significant to safety.
8.6.2 If the activity is significant to safety, then further evaluation is required. The Outage SRO/ Shift Outage Manager assembles a team composed of representatives from Engineering, N,;. 'enance, and Operations. The operations representative must hold a current Senior Reactor Operators License. This team will assess the activity, using Attachment 1, to determine if the planned DEFENSE IN DEPTH will be compromised. If the results of that review indicates that DEFENSE IN DEPTH may be compromised, PNSC review is required by Section 5.6.5 prior to implementing the activity in the schedule. The Superintendent Outage Management is responsible for maintaining a historical file of Attachment 1s.
8.6.3 If the assessment indicates that the DEFENSE IN DEPTH criteria is l
satisfied, the activity is further assessed for the potential to create a HIGHER RISK EVOLUTION and the appropriate compensatory measures are taken.
8.6.4 If it is determined that the evolution creates a breach of the DEFENSE IN DEPTH or creates a HIGHER RISK EVOLUTION, PNSC review is required by Section 5.6.5 prior to including the activity in the schedule.
8.6.5 ORAM analysis of the schedule on a daily basis verifies maintenance of key safety functions during the outage.
Page 29 u) 3G l 0AP-022 Rev. 2
ATTACHMENT 1 Page 1 of 4 Safety Significance Determination l
- 1. Evaluate the Activity (ies)/ Task (s) listed on Form 1 against the following criteria to i
determine if additional risk assessment is required:
A: CRITERIA 1 Can the work be performed within an existing work window without adversely affecting the NON-Outage Unit, and without adverse affect on any other activity window?
If YES, no further assessment is required to perform this
- activity, if NO, continue to Criteria 2.
B: CRITERIA 2 Does (Do) (Could) the activity (les) affect any of the following:
DECAY HEAT REMOVAL Capability Reactor Level Control Capability Reactor Coolant / Fuel Pool Makeup Capability Secondary Containment Integrity Electrical Power Distribution Systems REACTIVITY CONTROL Systems Fuel Pool Cooling Miscellaneous Reviews if YES, additional evaluation is required for the activity / task.
Use Section 3, ASSESSMENT OF SAFETY SIGNIFICANT ACTIVITIES to perform the additional evaluation.
If NO, no further evaluation is required for the activity / task
- 2. Record results of activity assessment on Form 1.
0AP-022 Rev.2 Page 30 of 36
1 I
ATTACHMENT 1 Page 2 of 4 Safety Significance Determination
3.0 ASSESSMENT
OF SAFETY SIGNIFICANT ACTIVITIES ACTIVITY TO BE ASSESSED Preceding Constraints Succeeding Constraints Planned Duration :o Activity (clock hours) c 3.1 Assessment of DEFENSE IN DEPTH 3.1.1 Will the systems required OPERABLE by Technical Specifications remain OPERABLE 7 YES ( ) NO ( )
3.1.2 Will the DEFENSE IN DEPTH Guidelines be met for the following KEY SAFETY FUNCTIONS if the proposed revision is implemented?
YES-NO 3.2.1 DECAY HEAT REMOVAL
()
()
3.2.2 Fuel Pool Cooling
()
()
3.2.3 Reactor Coolant Makeup Capability
()
()
3.2.4 Reactor Water Level Control
()
()
3.2.5 Secondr.ry Containment
()
()
3.2.6 REACTIVITY CONTROL
()
()
3.2.7 Electrical Power Distribution
()
()
3 2.8 Miscellaneous Reviews
()
()
=
OAP-022 Rev. 2 Page 31 of 36
ATTACHMENT 1 Page 3 of 4 Safety Sign!ficance Determination if the DEFENSC IN DEPTH is defeated (a NO answer in any of the above questions) by initiating the prop sed change then further Management review, as determined by the o
Manager, Outage and Scheduling must be completed prior to implementing this activity.
If DEFENSE IN DEPTH is maintained, then complete the assessment in Section 3.2 below to determine if a HIGHER RISK EVOLUTION is createo, if DEFENSE IN DEPTH cannot be maintained att er additio,al evaluation, PNSC review is required prior to impler unting this activity.
32 Assessment For HIGHER RISK EVOLUTION Could implementing the activity in question pose a risk to or increase the probability of locing the DEFENSE IN DEPTH provided for the following KEY SAFETY FUNCTIONS:
YES NO 1.
()
()
2.
Fuel Pool Cooling
()
()
3.
Reactor Coolant Makeup Capability
()
()
4.
Reactor Water Level Contiol
()
()
5.
()
()
6.
REACTIVITY CONTROL
()
()
7.
Electrical Power Distribution
()
()
8.
_ Miscellaneous Reviews
()
()
OAP 022_
Rev,2 Page 32 of 36
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Page 4 of 4 l
Safety Significance Determination if any of the KEY SAFETY FUNCTIONS are potentially affected, contingency measures must be in place to preserve the safety function. The contingency measures may include plans to implement alternate methods, the use of temporary equipment, specla' briefs, or other measures as deemed appropriate i
to maintain the reliability of the safety function. Describe below any compensatory measures taken. This description must indicate what is to be done, why it is being done, and who has responsibility for getting it done.
l F
1 If the activity is determined to be a HIGHER RISK EVOLUTION, then PNSC review is required prior to including the activity in the schedule.
3.3 Activity Approval t
YES NO Assessment team approval?
()
()
SOM Date Team Members:
Date Date.
Date Date Date PNSC Review Completed Date (if required) 0AP 022 Rev.2 Page 33 of 36
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FORM 2 Pac e 1 of 1 Schedule C1ange Approval To:
- Outage SRO/SOM Name From:
Requestor Ext.
Date
Subject:
Schedule changes for i
System Name and Number i
The following schedule changes are required to support Outage Planning and Scheduling. Please verify "
changes can be made and maintain ' DEFENSE IN DEPTH" as verified by the vafe Shutdown Risk Assessment.
WR/JO Activity #
Scheduler Schedule changes approved O
Schedule changes NQI approved OWhy ?
Outage SRO or Designee /SOM Signature Date Concurrence Outage Superintendent or Designee Date Schedule change complete Scheduler Date Comments Outage SRO Designee must hold a current SRO license on the appropriate BNP Unit Outage Superintendent Designee must be in " Outage & Scheduling" Supervision.
0AP-022 Rev.2 Page 35 of 36
FORM 3 r
Pas e 1 of 1 Unit Key Sa fety Function Status Change Since Last Shift Date:
Time:
SHUTDOWN COOLING REACTIVITY CONTROL
[
'A" RHR/RHR SW All Rods Inserted -
- C" RHR/RHR SW
- A" SRM
- B" RHR/RHR SW
- B"SRM
'D" RHR/RHR SW
- A" FPC
- 0" RHR Assist
'A" SSFPC Bus E 1
- D" SSFPC DG1 Bus E 2 INVENTORY CONTROL DG2 Bus E 3 f
'A" Core Spray DG3
[
- B" Core Spray Bus E-4 "A" LPCI DG4
- B"LPCI UAT COND/FW SAT CRD 2 230KV lines RWCU Cat i Fuel Pool M/U per AOP-038 SECONDARY CONTAINMENT Plant Mode Core Alts in Progress
'A" SBGT Fuel Pool Gates Installed "B"SOGT Suppression Pool Avail.
Secondary Cont.
RPV Temp Control Band Reactor Temp Heat Uprate Time to Doil KEY:
A = Functionally available O = Futty operable G = Guarded X = Not Available Shading is used to ind:cate that a key Safety Function does not meet Defense in Depth Cnteria.- When Defense in Depth is not met for a Key Safety Function, the remaining systems that are available to perform that functional shall be GUARDED, Notify Maintenance Rule Program Engineer, 0AP-022 -
Rev.2 Pa0e 36 of 36
. -. ~.
-