u1r28 outage risk plan ppg outage management.defense in depth during those conditions that will...

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R128 Outage Schedule Safety Review results i-ct U1R28 Outage Risk Plan PPG Outage Management Introduction The philosophy of the Outage Planning Group with respect to risk assessment is to plan and schedule the shortest possible outage with the least total exposure to risk and provide reliable documentation from the schedule database of meeting this intent. The outage plan, (and outage schedule), will therefore: * Never provide direction to enter a "Red" condition, (See NP 10.3.6), * Limit to the greatest possible extent the quantity and duration of "Orange" condition(s), * Implement comprehensive contingency plans for any "Orange" condition and protect all operating and backup equipment when more than one KSF is at "Orange" condition at any one time, and * Actively seek to reduce duration of "Yellow" conditions when such reductions will not both significantly and adversely affect the overall cost or duration of an outage. The risk profile of the unit 1, 286 refueling outage contains no periods of "Red" risk condition and 2 periods of "Orange" risk condition. This is due to primary S/G and other work on equipment that is un-isolable from the reactor. This work necessitates the lowering of RCS level to reduced inventory. Specific risk reduction contingency plans are required for the 2 periods of "Orange" risk condition. Those contingency plans will be drafted and issued separately from this document. The containment equipment hatch will not be removed during UIR28, eliminating a significant contributor to the risk profile. Significant scope exists for CVCS and RH, causing an increase in risk for inventory, core cooling, and reactivity Key Safety Functions (KSFs) to "Yellow" condition. This work will occur during the fuel and inisert shuffle in the refueling pool. This condition has not occurred in over 7 years at PBNP and will result in plant operating conditions that are not familiar to many workers. With effective planning, training and preparation, the cumulative risk profile ofUlR28 is acceptable. It should be noted thatNP 10.36 and Technical Specifications occasionally utilize similar terminology to describe differing conditions. This is of particular note when discussing the "cavity filled" condition. Further detail will be provided below. The U1R28 Risk Plan This risk plan describes the risk conditions and the actions and tasks necessary to achieve adequate defense in depth during those conditions that will exist during the U1R28 outage. This plan acts as a primer for risk related information contained within the outage schedule. This plan does not replace the outage schedule, which is time based and updated regularly throughout the execution of the outage. The plan will be presented in a structured format A general knowledge of Technical Specifications, Shutdown RiskPrincipals, Administrative Procedures, plant layout and function is assumed. The methods used to retain adequate "defense in depth" will be described in detail for each plant condition. The risk plan is divided into several sections. Each section will relate to an NMC outage phase. Individual activities will be marked in the work group bar chart and detailed schedule documents to identify when human performance risk analysis has shown a high level ofpotential for error, (see NP 1.1.7). Work that is acceptable for performance during reduced inventory periods and during ESF loss of AC power testing, O-RT-003A & B, will be marked in the work group bar chart and detailed schedule documents. This will document pre-review and authorization activities so that execution may proceed wiih assurance. This is of particular value in the WCC at the interfaces with shift management and 'across the counter' with maintenance and engineering. InfolastJiO in this record was deleted in accordance withe Freedom of .SiI?~o Act, exem p 6s1 n 1 nf 19

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Page 1: U1R28 Outage Risk Plan PPG Outage Management.defense in depth during those conditions that will exist during the U1R28 outage. This plan acts as a primer for risk related information

R128 Outage Schedule Safety Review results i-ct

U1R28 Outage Risk PlanPPG Outage Management

IntroductionThe philosophy of the Outage Planning Group with respect to risk assessment is to plan and schedule the

shortest possible outage with the least total exposure to risk and provide reliable documentation from theschedule database of meeting this intent. The outage plan, (and outage schedule), will therefore:

* Never provide direction to enter a "Red" condition, (See NP 10.3.6),* Limit to the greatest possible extent the quantity and duration of "Orange" condition(s),* Implement comprehensive contingency plans for any "Orange" condition and protect all operating and

backup equipment when more than one KSF is at "Orange" condition at any one time, and* Actively seek to reduce duration of "Yellow" conditions when such reductions will not both

significantly and adversely affect the overall cost or duration of an outage.

The risk profile of the unit 1, 286 refueling outage contains no periods of "Red" risk condition and 2periods of "Orange" risk condition. This is due to primary S/G and other work on equipment that is un-isolablefrom the reactor. This work necessitates the lowering of RCS level to reduced inventory. Specific riskreduction contingency plans are required for the 2 periods of "Orange" risk condition. Those contingency planswill be drafted and issued separately from this document.

The containment equipment hatch will not be removed during UIR28, eliminating a significantcontributor to the risk profile.

Significant scope exists for CVCS and RH, causing an increase in risk for inventory, core cooling, andreactivity Key Safety Functions (KSFs) to "Yellow" condition. This work will occur during the fuel and inisertshuffle in the refueling pool. This condition has not occurred in over 7 years at PBNP and will result in plantoperating conditions that are not familiar to many workers. With effective planning, training and preparation,the cumulative risk profile ofUlR28 is acceptable. It should be noted thatNP 10.36 and TechnicalSpecifications occasionally utilize similar terminology to describe differing conditions. This is of particular notewhen discussing the "cavity filled" condition. Further detail will be provided below.

The U1R28 Risk PlanThis risk plan describes the risk conditions and the actions and tasks necessary to achieve adequate

defense in depth during those conditions that will exist during the U1R28 outage. This plan acts as a primer forrisk related information contained within the outage schedule. This plan does not replace the outage schedule,which is time based and updated regularly throughout the execution of the outage.

The plan will be presented in a structured format A general knowledge of Technical Specifications,Shutdown RiskPrincipals, Administrative Procedures, plant layout and function is assumed. The methods usedto retain adequate "defense in depth" will be described in detail for each plant condition. The risk plan isdivided into several sections. Each section will relate to an NMC outage phase.

Individual activities will be marked in the work group bar chart and detailed schedule documents toidentify when human performance risk analysis has shown a high level ofpotential for error, (see NP 1.1.7).

Work that is acceptable for performance during reduced inventory periods and during ESF loss of ACpower testing, O-RT-003A & B, will be marked in the work group bar chart and detailed schedule documents.This will document pre-review and authorization activities so that execution may proceed wiih assurance. Thisis of particular value in the WCC at the interfaces with shift management and 'across the counter' withmaintenance and engineering.

InfolastJiO in this record was deletedin accordance withe Freedom of .SiI?~oAct, exem p 6s1 n

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R128 Outage Schedule Safety Review results

1 Offline to Enter Mode5During the pre-outage period and through Modes 2, (Startup), & 3, (Hot Standby) risk is

evaluated using the On Line Safety Monitor. NP 10.3.6 is not in effect until the plant achieves Mode 4.Upon entry into Mode 4, all KSFs remain "GREEN"' and all safety equipment remains available oroperable for raxinmum defense-in-depth. Fire Protection remains Condition I until entry into Mode 5

2) Enter Mode5 to Enter Mode6

Start Non-ESF related work and Prepare for ORT-3AJB

Integrated "'ESF with Loss of AC Power" Testing

Pre-Approved Concurrent Work:Only work that has beenpre-approved for execution during ORT-003 may be

performed. The following is a list of general work that has been pre-approved to occur duringperformance of ORT-003. It should be noted that further evaluation might result in additionalpre-approvals. Any such pre-approvals will be so noted in the outage schedule.

* CWAI 1 - P-030A and related components.* CWB II - P-030B and related components.* TUX01 - Turbine Generator & Main Transformer.* MSXOI - Main Steam.

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* CSXO1 - non-pump-related Condensate.• CVXOI - High Pressure Letdown, (after RHR letdown in service).* RCAI I - Reactor Coolant Pump motor determination and preparation for lift to the

66' stand.* CONTXO1 - Setup in the reactor head lay-down area, equipment load-in to

containment and temporary power service for under-head inspection.o During Preparation and recovery phases of each train of the ORT3 test, I&C will

continue to perform a normal distribution of work, all of which will be stoppedduring the actual performance of the ORT3 test.

o During the actual performance of the ORT3 test, I&C will be performing secondarytemperature calibrations, containment H2 calibrations, a very small amount ofsecondary valve diagnostics, and EH fluid system components. None of which willimpact operations in the control room.

o Line 121 will be OOS and Appleton work on Line 121 will continue throughoutORT3 testing. Line 121 will not be returned to service until after ORT3 is complete.

Start "B" train only ESF related work:A small amount of primary work may start immediately after the 'B" train integrated

engineered safeguards test is complete. The following is a listing of functional equipmentgroups that can be cleared for work immediately after ORT-003B recovery is complete:

* VNCCB51 - Containment Fan Cooler C

The KSF status for ORT-003A is listed below:

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Reactor over-head disassembly

Start remaining ESF related work.lA significant amount of both primary and secondary work may not start until the

integrated engineered safeguards test is complete. The following is a listing of functionalequipment groups that can be cleared for work immediately after ORT-003 recovery iscomplete:

* CSA1 1 - P-025A and related components* CSB1 1 - P-025B and related components* CSA12 - P-028A and related components* CSB12 - P-028B and related components* CVX05 - Excess Letdown and Seal Return* SIAOI-HHSIA Loop* SIA02 - Containment Spray A Loop* SIB02 - Containment spray B Loop* VNCCA5 1- Containment Fan Cooler A* VNCCA52 - Containment Fan Cooler B

RCS Draln-Down Sequence (part 1)Following O-RT-003, The RCS is drained 60% to 70% Reactor vessel level and the

SIG tubes are burped, (reactor coolant is displaced with Nitrogen gas), per OP-4). The RCSwill then be vented to allow removal of a majority of the S/G primry manway bolts. Actualbreach of the RCS boundary is still not allowed

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RI1u uurage .scneaule Sarety Hevtew results

Reduced Inventory and Mid-Loop

RCS Drain-Down Sequence (part 2)Following SIG tube burp and initial RCS vent, the RCS will be drained to Mid-loop.

During this period NO work will be allowed that could distract watch standers in any way.When the RCS is at mid-loop and stable work will be allowed to resume as expresslyauthorized by the approved Orange Condition Contingency Plan.

Work That May Start While The RCS Is AT Reduced Inventory (after Drainingcomplete and stable conditions are established)

Additional FEGs and components may be removed from service for maintenanceduring the reduced inventory period. The following is a list of FEGs and components thatmay be removed from service.

* RCX00 - RCS Boundary - During this time the pressurizer mnanway will be removedto establish a large hot leg vent. This is required to be complete prior to installingany hot leg nozzle dam.

* RCX02 - Mid-loop Work - Remove S/G primary manways, survey channel-heads,and install nozzle dams. Also the work on SI-00845A will be performed during thistimeframe. This work must proceed expeditiously to allow rapid exit of ORANGErisk condition.

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R128 OutafAe schedunlp Safety Review results

3) Enter Mode 6 to Start of Fuel Movement

Disassemble Reactor and Prepare to Move Fuel

Work That May Start When The RCS Is No Longer at Reduced InventoryAdditional FEGs and components may be removed from service for maintenance

immediately following the reduced inventory period. The following is a list of FEGs andcomponents that may be removed from service.

* MSA21- Steam GeneratorA Feed Check Testing* MSB2 1 - Steam Generator B Feed Check Testing* SIBO - Safety Injection B-train.VNCC52B - Containment Fan Cooler D.

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When the Refueling Cavity is filled to Rod Unlatch Height, the Inventory KSFchanges state as follows:

When the Upper Internals are removed, the Core Cooling KSF changes state, (thischange of state may have occurred earlier based upon TTB but is not credited until this pointfor purposes of the plan). Additionally, the Containment KSF changes reliance on DHEcapability from fan coolers to the refueling cavity with internals removed AND Inventorymargin is increased by removal of the flow restriction caused by the upper internals. Changesoccur as follows:

* l.

Work That Must finish to support fuel motionThe approaching MCC B42 outage and the significant quantity of RWST and CVCS

work will require that the SI "A" boration flow path be restored to service to support fuelmotion during the next phase. SI-00826A will be opened and de-energized to support this

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R128 Outage Schedule Safety Review results

4) Start Fuel Movement to Reload Complete

The Refueling Pool Is Filled

Work That May Start When the Refueling Pool is FullAdditional FEGs and components may be removed from service for maintenance

after the refueling cavity is full. The following is a list of FEGs and components that may beremoved from service.

* CVX02 - Low Pressure Letdown* CVX03 - Normal Charging Header* CVX04 - Seal Injection* CVX06 - Auxiliary Charging Header* CVX07 - Blender and RWST injection flow paths• CVX08 -Emergency Borate flow path* SIX31-Refueling Water Storage Tank, in particular, the ivork on SI-00742.* RHBO 1 - Residual Heat Removal B train, in particular, the bus bar bracing work on

MCC B-42 and the replacement of the P-01OB Rotating Assembly.* Y-04 breaker replacements.* AFBII -P-038B will be lostto Unit 2 fora period oftime to perform some of the

MR 00-037, control room MOB replacement modification, work packages. This willresult in a 3.7.5.C Auxiliary Feed "B" TSAC of 28 hours duration.It is imperative that these 1WPs be worked as scheduled so as to limit the adverseimpact to risk significant components on either unit or protected components on therefueling unit.

• 4KVXOI - X04 Transformer work. THEN when X04 is RTS,* 13KVXOI - X03 Transformer work will be performed.

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Re-Fuel the Reactor

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(5) Reload Complete to Head Set

Please note that although not required, tits expectedthatfuel motion will be complete prior to DHR train swap.

Work That May Start When the Reactor is Re-FueledAdditional FEGs and components may be removed from service for maintenance

after the Reactor is refueled. The following is a list of FEGs and components that may beremoved from service.

SIAOI - Safety Injection "" train.

Steam Generator Secondary Side Work

Steam Generator secondary side internal work will be performed during this period of time ashoses may now be placed through the personnel hatch. This includes tasks that although notcritical, are significant to the completion of outage and to the Containment KSF:

* Tube-sheet Cleaning* Internal inspection of AF-100, Aux Feed check valve* Feed-water flow transmitter root valve replacements* Repack if CS-146, FRV outlet bypass valve.

During the work on the Feed water flow root valves and the repack of CS-I 46, thecontainment boundary will be maintained by CS476AA, the main feed check valve. Thisvalve will have been tested leak tight earlier in the outage per IT-305.

Work That Must Finish to Swap DIR Loops

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±uze uurage bcneauie barecy Keview resuits

Some FEGs and components must be returned to service for operations use beforework may commence on the 2Ud train of RHRIDHR. The following is a list of FEGs andcomponents that must be returned to service.

* RHB0I - "B" train RER loop. Specificallyreplacement of the P-OIOB RotatingAssembly and completion of the bus bracing modification to MCC B42.SIDC31 - Refueling Water Storage Tank, in particular, the work on SI-00742. Returnof the RWST is required to refill RHR ¶B"-train.

• AFB 1 - P-03 8B related work packages for MR 00-037, control room MOBreplacement modification. This will exit the 3.7.5.C Auxiliary Feed "B" TSAC.

It is imperative that these IWPs be worked as scheduled so as to limit the adverseimpact to risk significant components on either unit or protected components on therefueling unit.

Work That May Start After DHR Train SwapAdditional FEGs and components may be removed from service for maintenance

afier "B" train of DHR has been returned to service. The following is a list of FEGs afidcomponents that may be removed from service.

* RHAO1 -Residual Heat Removal "A" train.* AFAI 1 - P-038A will be lost to Unit 2 to perform some of the MR 00-037, control

room MOB replacement modification, work packages. This will result in a 3.7.5.CAuxiliary Feed "A" TSAC of 50 hours duration.

It is imperative that these IWPs be worked as scheduled so as to limit the adverseimpact to risk significant components on either unit or protected components on therefueling unit. v

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R128 Outage Schedule Safety Review results

Work That Must Finish before the ECCS LRPM TestingSome FEGs and components must be returned to service prior to proceeding with

testing that requires fuel motion to be complete and the refueling pool to be fall. Thefollowing is a list of FEGs and components that must be returned to service to perform ECCSLRPM testing.

* SIA01 -High Head SafetyInjection A-Train* SIB01 - High Head Safety Injection B-Train.* SIA02 - Containment Spray A-Train.* SIB02 - Containment Spray B-Traii.* RHAOI - Residual Heat Removal A-Train.

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_Risk associated with A-Train ECCS LRPM testing

Perfomnance of 0-4T-530C changes KSF status as follows:

4

Risk associated with B-Traln ECCS LRPM testingPerformnance of 0-IT-530D changes KSF status as follows:

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R128 Outage Schedule Safety Review results

Work That Must Finish Before Lowering Refueling Pool LevelSome FEGs and components must be returned to service prior to lowering refueling

pool level. The following is a list of FEGs and components that must be returned to service tolower RFP level.

• CVX02 - Low Pressure Letdown.X CVX03 -Normal Charging Header.* CVX05 -RCP Seal Injection.* CVX06 -Auxiliary Charging Header.* CVX07 - Blender.* CVX08 - Emergency Boration Line.* The Sump B debris screen must be installed.* 4KVX1l - X04 Transformer work

Reactor Reassembly

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R128 Outage Schedule Safety Review results

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Risk

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6) Head Set to Enter Mode 5

Reduced Inventory and Mld-Loop

Work That Must be Complete to Enter Reduced Inventory

Some FEGs and components should be returned to service prior to entering into reducedinventory to achieve the greatest possible defense in depth.

* 4KVXOI - X04 Low Voltage Station Auxiliary Transformer.* 13KVXOI - X03 High Voltage Station Auxiliary Transformer.* VNCCX52 - D Containment Fan Cooler Unit* The work associated with B-41 must be complete.

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R128 Outage Schedule Safety Review results

A'

7) 5 to RCS Filled and Vented

Fill & Vent

Work That Will be Performed While The RCS Is In Mode 5

a SIAXI - High Head Safety Injection A-Train Filled and Intact, but not available.This is required to perform the MOV testing of SI-00858A and D. THEN:

* SIBXI - High Head Safety Injection B-Train Filled and Intact, but not available.This is required to perform the MOV testing of SI-00858B and C.

Risks

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CS Filled and Vented to Enter Mode4

Containment Recovery

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R128 Outage Schedule Safety Review results

9) Enter Mode4 to Enter Mode3Risk

During the plant recovery through Modes 3, (Hot Standby), 2, (Startup), and 1,(Power Operation), risk is evaluated using the On Line Safety Monitor. NP 10.3.6 is Dot ineffect after the plant achieves Mode 3.

10) Enter Mode 3 to Enter Mode2Risk

During the plant recovery through Modes 3, (Hot Standby), & 2, (Startup), and 1,(Power Operation), risk is evaluated using the On Line Safety Monitor. NP 10.3.6 is not ineffect after the plant achieves Mode 3.

11) Enter Mode2 to On-LineRisk

During the plant recovery through Modes 3, (Hot Standby), & 2, (Startup), and 1,(Power Operation), risk is evaluated using the On Line Safety Monitor. NP 10.3.6 is not ineffect after the plant achieves Mode 3.

Final On-Line to Full PowerRisk

During the plant recovery through Modes 3, (Hot Standby), & 2, (Startup), and 1,(Power Operation), risk is evaluated using the On Line Safety Monitor. NP 10.3.6 is not ineffect after the plant achieves Mode 3.

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