ML20198J756
| ML20198J756 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/10/1998 |
| From: | Terry J FLORIDA POWER CORP. |
| To: | |
| Shared Package | |
| ML20198J675 | List:
|
| References | |
| PROC-980110-02, PROC-980110-2, NUDOCS 9801140205 | |
| Download: ML20198J756 (13) | |
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Power SFlorida C 0 M P O H A1 ION 1
CRYSTAL RIVER U slT 3 _____
i
' SYSTEM READINESS REVIEW Pl.Ah i I
E ide[
J.I erry /
anager, Nucidar Plant Technical Support N "k N k o!O N302 L. . -So"- _ _ _ . . -- - - .
Key issue How does fPC have reasonable assurance that equipment operability and reliability problems at CR 3 have been identified in a disciplined, systematic, and comprehensive manner, and that corrective actions have bet , taken to ensure safe and dependable startup and operation of the plant.
. - Executive in response to the Nuclear Regulatory Commission's Request for -
Summary Information dated October 9,1996, pursuant to 10CFR50.54(0, Florida Power Corporation (FPC) committed to perform a System Readiness Review (SRR) of Crystal River Unit 3 (CR 3) systems prior to restart. The SRR provided a phased and prioritized approach for the revlew of each of 105 plant systems. These reviews were one part of a comprehensive restart program that provided reasonable assurance that CR 3 systems are operated reliably within their design and licensing basis.
Based on the results of the SRR resws documented in the final reports for each of the plant systems, the evaluations of potential programmatic issues, ar.d the results of several independent self assessments and audits, including a recent NRC SSFl for two plant systems (the Low Pressure injection system and the High Pressure Injection system), it is concluded that the System Readiness Review Program has provided an effective means of:
e Identifying specific system and programmatic deficiencies and corrective actions e Assessing the restart significance of recent and previously identified probierns, and
- Monitoring the successful resolution of those problems, T herefore, There k reasonable assurance that the CR-3 systems are capable of meeting their design and licensing basis requirements.
AND The systems are ready for reliable operailon for the next operating cycle.
m This conclusion is based on the evaluations summarized in the final SRR
. reports, completion of modification and maintenance testing, and the pending completion of the startup surveillance testing.
In ii t atives Issues - associated with system and equipment performance were identified and docketed to the NRC in October 28, 1996 corre3pondence 3F1096-22. In response to these issues and in support
-of the response to 10CFR50.54(0, FPC implemented the System Readiness Review Program (SRRP).
2
The SRRP provided a phased and prioritized approach for the review of l each of the plant systems. The reviews were one part of a compre- l hersive restart program. In conjunction with other ongoing programs at l CR 3, and resolution of outstanding issues identified as required for 1 restart, the SRR provided reasonable assurance that the system operation: i
. Is capable of meeting its functional requirements, e is within its regulatory design basis, and
. Is within its licensing basis.
The SRRP was developed to assess CR 3 systems using Safety System functional Inspection (SSfl) methodology and implemented through a graded approach. This method defined critical inspection characteristics in topic areas of:
- Design Basis e Licensing Documents e Operations
- Maintenance
- Surveillance e Physical Plant Configuration
. Programs, Processes and Procedures which were applied to assess the system health and conformance to requirements. Overall, thirty (30) system topic areas were defined. The matrix used in the assessments is shown on Attachment 1.
Under the SRRP, System Managers have assessed the readiness for restart of each of the 105 systems at CR 3. The systems have been assessed in a prioritized and phased approach. In order to ensure that the systems receive the appropriate level of evaluation and resources, systems were assigned to one of three levels of review.
Level 1 - SSFl inspection Level 2 - Focused SSfl inspection Level 3 - System Open item and Configuration Review f ach system was assigned an appropriate level of review based on factors described in the Preparation section of this report. The graded SRRP assessment methodology was applied for the review of each system based on its assigned level. Level 1 systems were reviewed in all 30 topic areas. Level 2 system reviews focused on critical system attributes relative to design and licensing basis information and plant configuration. Level 3 systems had an open item review. All systems were subjected to walkdowns to ensure r,hysical plant configuration control.
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The assessment of each system is divided into an initial preparation phase and four discrete phases of implementation. The scope of each is described below.
Preparation - This step included establishing and training personnel associated with the SRRP. Training began with a review of design and licensing basis documentation. The training was conducted in accordance with documented qualification requirements that covered plant procedures, processes, and computerized document search tools, as well at 9e vertical slice safety system functional inspection (SSFI) methodology. All training was conducted in accordance with the qualification requirements documented in the SRRP.
The 105 CR 3 systems were prioritized and classified into one of three SRR review levels. The classification process took into account factors such as:
. The importance of the system in maintaining the integrity of the fission product boundaries (fuel clad, reactor coolant system and containment)
. Probabilistic Safety Assessment ranking
. The importance of the system to plant safety as determined by the Maintenance Rule ranking process
. A regulatory factor including consideration of regulatory design basis
. The number of moditications performed on the system, and other opportunities for confi;;uration change
. Results of prior system reviews (EDSFI, SWSOPI, etc.)
The prioritization of the vystems was reviewed by several independent experienced groups. The resulting system classifications are such that, based on a PSA risk reduction worth perspective and excluding contributions due to human error, the Level 1 systems are relied upon in accident sequences which account for 87% of the core damage frequency, in addition, the Level 1 and Level 2 systems are relied upon in accident seq'.ences which account for 100% of the core damage frequency.
The SRR process included and obtained input from personnel with a wide range of experience and expertise.
. The FPC System Manager provided a detailed knowledge of the system, including its functional requirements and its performance history. The system manager also brought ownership of the scstem:
at the conclusion of the SRR the system manager determines whether the system is ready for restart.
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. The System Operator participated in the SRR, in the initial and final system walkdowns and by reviewing and concurring with the initial and final SRR reports. Operations accepted the final SRR Reports for each system.
. The Design Engineer for the system provided support as required and participated in the System Ownership Team review of the appropriate Configuration Document Integration Project documents, including fSAR revisions.
. Maintenance and Licensing personnel provided support as required.
. MPR Associates brought detailed knowledge and experience with the vertical slice and SSfl process, and provided an independent perspective grounded in experience at other plants.
. Framatome Technologies brought the unique knowledge of the design basis for CR 3 and other B&W plants and direct access to previously conducted and ongoing design basis analyses.
Phase 1 Discovery and Assessment. Phase 1 of the SRR employed a vertical slice approach similar to the methodology of a Safety System i enctional Inspection (SSfl). This approach was used to evaluate elected system functional and safety requirements (Attributes) against plant configuration, as well as design, licensing, operations and maintenance documents (Topic Areas) on a sampling basis.
The assessments included a comparison and evaluation of documents as well as observations of plant condition and configuration during system walkdowns. The results were documented in Attribute Assessment forms and Issue Tracking forms in the SRR Database. Discrepancies were entered into the CR 3 corrective action prog, ram. Database manipulation and reporting capabilities assist in reporting, tracking and identification of generic issues and trends.
Document Review, for level 1 and Level 2 systems, each system review team developed a list of specific system attributes for assessment based on review of design and licensing basis information. Licensing requirements and design basis documents included FSAR, Technical Specification, and Design Basis Documents. Generic requirements, such as Station Blackout, Environmental Qualification, Appendix R, etc.
were also selected as system attributes when appropriate. These attributes were selected to cover the functional requirements of the system and its critical components. The system specific bases for selection of system attributes are documented in the Initial SRR Report for each system. The Level 3 system review teams also used the FSAR, the Technical Specifications and Design Basis Documents, if applicable, to establish functional requirements to be addressed in the assessment.
However, specific system attributes were not defined for the Level 3 reviews.
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The requirements associated with each of the selected attributes were evaluated against specific Topic Areas or sources of information. The topic areas cover design and licensing documents, operating, maintenance and testing procedures as well as programmatic issues such as corrective action programs. The focus of these evaluations was to assess consistency and conformance of current plant configuration and operation to current plant design and licensing basis requirements. for Level 1 systems, all 30 Topic Areas are covered.
for Level 2 systems, the review began in 14 Topic Areas. Emphasis was placed on design and licensing documents, plant modifications, plant operating procedures, and plant configuration. The need for expansion of Level 2 topic areas was conducted by an " expert panel". Panel members consisted of manager level personnel from Engineering, Work Controls, Operations, and the Plant Review Committee Chairman. The panel assessed the results of the Level I reviews and assessed the cumulative significance within each topic area to identify programmatic concerns or generic issues that may cross system boundaries, to ensure Level 2 systems were consistent and reviewed as appropriate. This review is formally documented in the Expert Panel Report. Level 2 system reviews were also expanded based on previous assessments performed on the specific system. Issues or discrepancies identified during previous assessments (such as SWSOPl & EDSFI) were analyzed and categorlied within the SRR topic areas. These topics were then factored into the SRR assessments, in summary, Level 2 assessments are termed " focused" reviews because of the expansion based on Level 1 assessments and the reviews of previous system specific assessments.
Ior Level 1 and Level 2 systems, the results of the individual checks of attribute requirements against topic areas were documented in Assessment Forms and entered into the SRR database. Identified ciscrepancies were documented in the issue Tracking part of the SRR database. Coples of the completed Attribute Assessment forms were included in the initial reports for the individual systems. Greater than 16,000 attribute checks were performed during the Level 1 and Level 2 SRR Reviews. Greater than 1500 discrepancies were identified.
Assessment attribute checks reviewed for Level 1 systems exceeded the n iginal goal by a factor of two. This is the result of identifying potential issues and " pulling the thread" to find the source of the issue. Topic areas reviewed and assessment attribute checks for Level 2 systems also exceeded the original goal by a factor of two, again, for the same reason as the level 1 reviews, Attachment 2 shows the final number of topic areas checked for each Level 1 and 2 system.
Level 3 system reviews focused on the system functional and safety requirements as documented in the FSAR, ITS and DBDs. Level 3 system reviews also covered plant work control databases, including such documents as REAs, MARS, Precursor Cards, Work Requests, and Operator Workarounds.
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.Jt_ _ _ - 4 for all system reviews, identified discrepancies were entered into the CR 3 Corrective Action Process or work control process. Resulting Precursor Cards were included in the initial reports for the individual systems.
Initial Walkdowns. The assessment of each system included walkdowns during the initial discovery phase of the process. A plan for the system walkdowns was developed for each system, using the guidance in the SRR Plan. The walkdown team consisted of the system operator, the core members of the SRR team performing the assessments, and when requested by the System Manager, representatives from Maintenance, Licensing, and Design. The walkdowns focused on equipment reliability or operability issues as well as conformance with system design basis configuration.
As with evaluation of documents, results of the walkdowns were documented on Assessment forms and entered mto the SRR database for level 1 and tevel 2 systems. For all three Level systems, discrepancies were entered into the appropriate corrective action program and tracked to satisfactory resolution.
Screening of Open items for Restart Requirements. The SRR Teams reviewed open items generated in the SRR process and existing open items (e.g., Precursor Cards, Requests for Engineering Assistance, Modification Approval Records, Operator Workarounds, etc.) to determined whether the items were required to be resolved prior to restart. Those items that were recommended by the SRR Team for resolution prior to restart were forwarded for further evaluation and were entered into appropriate data bases for tracking as part of Phase 2 and 3 of the SRR Program, included in the review of existing open items were previously identified Restart issues that apply to individual systems. For some systems, the ongoing actions to address these Restart issues include analyses and plant modifications that are fundamental to the compliance of the ;
system with its design and licensing basis and to the system readiness for restart. These issues were identified and summarized in the individual system SRR reports.
Initial Reports. The results of Phase 1 of the SRR were documented in an Initial Report for each system. Each report docurnented the scope of the review and summarlied the results obtained. The reoort provided the foundation for the conclusion that a system is within its licensing and design basis, contingent upon resolution of identified discrepancies.
Discrepancies that were identified were described, entered into the appiopriate FPC work control system and tracked to satisfactory 1 completion in an SRR database. Copies of any Precursor Cards that 7
M i
were generated were included in the report. The l eve! of detail provided for each report was commensurate with the SRR review Level (1,2, or 3) for the system. The initial Reports received several levels of management review and approval as described in the SRR Plan and were transmitted to FPC Records Management.
Phase 2 Outage Activities Monitoring. During Phase 2 of the SRR, the System Ownership Team concept was formed. The System Ownership Team was comprised of the System Manager as the lead, the Design Engineer (optional for Levels 2 and 3), the System Operator (optional for Level 3), a Licensing representative (optional) and the Configuration Document Integration Project Writer / Integrator, for implementing the design basis documentation.
The Ownership Team had the responsibility for keeping abreast of on-going system activities, evaluating new or emergent issues, monitoring progress of Restart Action items, and for providing technical input to help ensure that these activities were completed satisfactorily. New issues were documented, reviewed for restart significance, and entered into the appropriate corrective action program. Closure of restart required open items were reviewed and if the resolution was appropriate, the item was documented as closed in the SRR database.
Revised configuration documentation such as the FSAR, EBDB, and ITS are reviewed by the Ownership Team and comment resolution coordinated with the CDIP.
The Or ai fship Team also reviewed the open Restart items and open itemt m the Work Control documents to confirm that deferred work is no .equired prior to restart. The cumulative impact of deferred work w 3 considered.
Phase 3. Final System Readiness Review. Final walkdowns were performed on work in progress with emphasis on Restart Action items, previously identified problem areas, and system modifications, if any.
SRR open items and the database were reviewed to ensure issues were properly closed. Each System Ownership Team was responsible for preparing and presenting a system specific Final System Readiness Report. The Final SRR Report documents the discrepancy and open item information gathered in Phase 2 and Phase 3, and summarizes the evaluations based on the Maintenance Rule performance criteria.
The Final SRR Report for level 1 and Level 2 systems was prepared by the System Manager, reviewed by the System Operator, and approved by the appropriate NPTS Supervisor and by the NPTS Manager. The report provides a status and summary of the completed and open (if any)
SRR restart items and a final review of any other items that were open against the system. Additionally, a list of remaining open restart items m presented together with a committed completion schedule that is tunsistent with plant restart.
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1 The approved Level 1 reports and those Level 2 reports deemed .;
appropriate by the ADPO/MNPO are presented to the " expert panel" ;
System Readiness Review Board for final review and acceptance. Level ;
2 reports not requiring review by the System Readiness Review Board ,
are accepted by t be ADPO/MNPO. i The Final Report also documents the review by the Ownership Team of the revised configuration documentation, including the FSAR, the CBDB, the ITS, etc. The Ownership Team verified that the revised configuration documents are consistent and reflect the resolution'of Identified discrepancies and system modifications. Any remaining configuration document open items were listed in the Final Report and those items that are required to be resolved prior to restart' were-identified.
For Level 3 systems, the initl'al Report also served as the Final Report, level 3 reports were presented to Operations for review and were accepted by the ADPO/MNPO.
Phase 4 Startup and Power Ascension Phase. During Phase 4, the
- System Manager monitors startup activities, including the results of surveillance tests, post maintenance tests, MAR functional tests, and their effect on system readiness.
Prior to entry to Mode 4, the System Manager confirms the adequate closure of restart required open items and evaluates the status of any items that are not closed, including those in the SRR Open items Database and those on the CDIP Open Item List, and any emergent open items generated since the completion of the Final Report. The status review of these items is documented in a report to the Shift Manager by the System Manager, with the conclusion that the system is ready for plant startup. Concurrence that the system is ready for entry to Mode 4 is provided by the Shift Manager._
At the. conclusion of. Phase 4, the System Manager issues a system readiness certification, affirming that the system has been monitored during plant startup and power ascension, that corrective maintenance activities have been reviewed and that the system is ready for reliable operation 1(or , the next cycle.
Concurrence is lprovided; by the appropriate NPTS_ supervisor' and the readiness certification form -'is forwarded to the NPTS Manager as part of the requirements of Al.256,
" Station ' Readiness for Restart Sequence, Reactor Restart ~and Power Ascension Plan'.
- 9:
Results Achieved Assessments The System Readiness Review Program has provided a systematic and comprehensive assessment of CR-3 systems. The effectiveness has been confirmed by self-assessments and improvements to the process implemented as a result of the assessments. These assessments were conducted by experienced FPC personnel and industry experts (MPR Associates, f ailure Prevention (FPI), INPO, Senior Utility Executives) to ensure systems readiness. FPC Quality Assurance provided independent assessment that concluded the SRRP to be effective. Additionally, the NRC SSFl for our low Pressure injection and High Pressure injection subsystems concluded that the " System Readiness Reviews were judged to be of good quality, well organized, and provided an appropriate barrier for assurance that restart issues were being addressed."
SRRP All Phase 3 Final Reporu have been completed and presented to the Restart Panel. The systems have been accepted by Operations and are progressing under Phase 4 to support plant restart.
The final Reports identified remaining open items that were required to be completed prior to restart. These items have been scheduled and are being tracked by the System Managers to closure.
Conclusion The SRRP has provided a systematic and comprehensive review of CR-3 systems and has ensured that effective corrective actions have been taken to assure the safe and reliable operation of CR-3. This program provided FPC with reasonable assurance that systems can be operated, maintained, and tested in accordance with their design basis.
The SRR reviews also lead to improved knowledge of the design bases and provide the system managers with improved skills for performing subsequent vertical slice and SSFl activities. These improved skills and capabilities will be used by the system managers and plant management to reduce future threats to system licensing and design bases and system functional requirements, in the tong run, these skills will help support reliable plant operation.
10
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