ML17325B467

Rev 5 to Cook Nuclear Plant Restart Plan.

ML17325B467
Person / Time
Site:	Cook
Issue date:	03/03/1999
From:	Powers R AMERICAN ELECTRIC POWER CO., INC.
To:
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ML17325B466	List: ML17325B465 ML17325B467
References
PROC-990303, NUDOCS 9903250070
Download: ML17325B467 (53)

Text

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L Robert Powers Senior Vice President March 3, 1999 9903250070 9903i2 PDR ADQCK 050008i5 P PDR

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EI.EC7RIC POWER CNP Restart Plan Concurrence:

P/i/udk'ice r ident, Nuclear Engineering Site'Vice President P ant Manager Director, Regulatory Affairs Director, Performance Assurance

~~~ JA~M Restart Director CNP Restart Plan Control:

The Restart Director is the administrative owner of this Document. Any Revision, at a minimum, will be reviewed and approved by SMRT. The Licensing Manager shall docket the CNP Restart Plan and any subsequent revisions with the NRC in accordance with AEPNG Procedures.

The procedures required to support the implementation of CNP Restart Plan are listed in the reference section, page 7-1, of the CNP Restart Plan Attachments. Those identified with an asterisk (*) still need to be developed and approved. The Restart Director will ensure the implementing procedures are developed prior to performance of the actions identified in the Plan.

CNP Restart Plan March 3, 1999 Revision 5 Page 2 of 23

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ELECTRIC POWER Table of Contents CNP Restart Plan Control:

CNP Restart Plan Attachments

1. Plan Overview.

1.1. Introduction.

1.2. Objectives 1.3. Program Management.

1.4. Program Scope 1.5. Program Structure .........................'.....................

2. Expanded Discovery Identifying, Understanding and Classifying Problems 9

2.1. Objective ........... 9 2.2. Sources of Potential Restart Issues .9 2.3. Expanded System Readiness Reviews (ESRR). 10 2.4. Programmatic Readiness Assessments 12 2.5. Functional Area Readiness Assessments 12 2.6. Corrective Action Program 12 2.7. Classification of Identified Items Required for Restart. 13 2.8. Criteria and Process for Designation of Restart Items 13 2.9. System Indexed Database System. 14 2.10. Commitments 14

3. Implementation, Fixing the Problems 15 3.1. Objective ~ 15 3.2. Restart Action Plans 15 3.3. Work Control and Integrated Restart Schedule. 15 3A. Documentation Requirements 16

4. Verification Confirming that Objectives are Achieved. 17 4.1. Final Readiness Reviews 17 4.2. Affirmation Requirements 18 4.3. Startup and Power Ascension. 19

5. Internal Oversight Ongoing Assessment 20 5.1. CNP Oversight Organizations 20 5.2. Third Party Assessments 20 5.3. Restart Readiness Measures 20

6. Regulatory Oversight 21 6.1. NRC MC 0350 Restart Panel 21 6.2. CNP Role in Regulatory Oversight 21

7. Authorization to Restart. 22 7.1. Senior Vice President Approval 22

8. Startup and Power Ascension. 23 CNP Resfarf Plan March 3, 1999 Revision 5 Page 3 of 23

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'MERICAN ELECTRIC POWER CPIP Restart Plan Attachments CNP Outage History Restart Organization Plant Programs/Processes Required by Restart Plan Required Programmatic Readiness Reviews Required Functional Area Reviews Criteria for Work Included in the Restart Scope References CNP Restart Plan March 3, 1999 Revision 5 Page 4 of 23

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1. Plan Overview I 1.1. Introduction Both Cook Nuclear Plant (CNP) units have been shut down since September 1997. This extended shutdown, as summarized in Attachment 1, was initially prompted by concerns raised by the Nuclear Regulatory Commission (NRC) architect-engineer (A/E) inspection. Subsequent assessments have uncovered a wide range of plant, people and process issues that must be resolved.

In response, senior management is undertaking comprehensive, aggressive action to fully confront the issues at CNP, beginning with an expanded discovery effort. Building on this discovery, a methodical and comprehensive series of actions are being implemented. This document, the CNP Restart Plan, provides top-tier management direction regarding the structure, content and methods for these restart actions.

1.2. Objectives The CNP Restart Plan provides information to a wide range of users, including plant personnel, NRC, and other interested parties. The objectives of the plan are to:

~ Set the overall strategy, logic, content, oversight, accountabilities and relationships of restart activities, with sufficient clarity to serve as a basis for the implementing processes and procedures.

~ Establish a broad basis for continuing improvement in CNP performance, up to and beyond plant restart.

~ Convey to the NRC how the CNP restart activities will meet regulatory requirements and commitments.

~ Communicate to the entire CNP staff, and to others, the overall path forward to a successful return to service of both CNP units.

1.3. Program Management The CNP restart effort involves work that is different, and in some respects more demanding, than normal plant outages. For that reason, permanent plant organizational units and processes are supplemented with additional organizational units and personnel, oversight committees, and special processes as described in Attachment 2.

CNP Restart Plan March 3, 1999 Revision 5 Page 5 of 23

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" jLNKRlCAN KMCYRIC POWER N tw thstanding the need for special measures, the permanent CNP.

organization retains its accountabilities for plant safety and management, and normal plant processes will be employed to the extent practical.

Senior management expects the entire CNP organization to put this plan into full effect as a common direction toward a successful restart.

1.4. Program Scope The CNP Restart Plan is intended to address the full spectrum of factors that will contribute to safe, efficient and reliable plant operation. Specific issues to be addressed have been identified, and are continuing to emerge, as part of the discovery effort, from NRC and restart requirements as well as AEP assessments.

1.5. Program Structure The CNP Restart Plan is based on fundamentals. Four steps c'oupled with continuous oversight, which lead to plant restart. This methodology is well understood and has been implemented successfully, under similar circumstances, at several other U.S. nuclear plants. Each step of the restart path is depicted as a block on the diagram shown in Figure 1 and defined below.

I. Discovery Discovery is the process of identifying and understanding plant, people and process problems that could jeopardize safe operation of CNP, and the determination of which of those problems must be corrected - and how

- prior to restart.

II. Implementation This term applies to the work done to implement the corrective actions in plant, people and processes needed for a successful restart.

III. Yerification Verification is the use of objective, defensible and properly documented methods to demonstrate that plant, people and process problems have been resolved. This is essential to meet both AEP and NRC requirements.

IV. Startup and Power Ascension Upon authorization from AEP management and with concurrence from NRC, the plant will be restarted in an orderly, deliberate manner.

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El.EC7RIC POWER V. Oversight AEP oversight will assess restart activities to provide further assurance that the work is done in accordance with requirements and procedures, and to confirm that the needed results have been achieved.

Figure 1 is a simplified process chart of the CNP Restart Plan. In principle, the restart program comprises these steps and the steps outlined.

The balance of this plan expands on the basic logic depicted in Figure 1. The processes and methods to be used are explained in this plan. Each of the steps shown in Figure 1 is sequentially outlined in the remaining sections of this plan. Where appropriate, the interrelationship of organizational units and processes particularly the "cross cutting" ones that affect multiple steps are highlighted. Further detail on important topics is provided as attachments. In addition, references to implementing procedures and other pertinent documents are provided.

V Finally, a summary of the programs and processes required by the CNP Restart Plan is provided in Attachment 3.

CNP Restart Plan March 3, 1999 Revision 5 Page 7 of 23

NRG Regulatory Oversight

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Oisaway Restart Identify, Repair. Confirm Corrective Effectiveness; Successful Current Plant Understand and Systems; Actions; Startup/Power Condition Operations Classify Programs; Perform System Ascension; Processes Tests and Heatup Testing Fig 1 (CNP) Restart Plan: The Path Forward GI t

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2. Expanded Discovery Identifying, Understanding and Classifying Problems Discovery Identify, Current Plant Understand and Condition Classify 2.1. Objective The objective of Discovery is to examine, comprehensively and rigorously, plant systems, programs, and functional areas in order to identify, assess and classify the problems that must be addressed in the Restart Program.

Effective discovery is fundamental to a successful Restart Program.

~Ex ended discovery, beyond the discovery work already accomplished, is .

necessary to provide sufficient confidence that the follow-on Restart Program work will result in a safe, successful return to service.

P 2.2. Sources of Potential Restart Issues The following are sources of potential restart issues to be examined during discovery efforts:

~ NRC 0350 Issues NRC has identified issues as requiring resolution prior to restart, per the NRC Manual 0350. These "NRC 0350 issues" are listed in NRC's Case S ecific Checklist for Donald C. Cook Plant.

~ Re'gulatory Commitments lt is essential that AEP commitments to the NRC and others be effectively implemented. Commitments are identified and managed through the tracking system described in PMP 7100.CMP.001, NRC Commitment Mana ement Pro ram. (See also Section 2.10)

~ Readiness Reviews An extensive process of assessments has been prescribed for systems, programs, and functional areas, in order to determine the station's readiness for restart and to identify corrective actions needed to achieve CNP Restart Plan March 3, 1999 Revision 5 I

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ELEClRIC POWER readiness. Readiness reviews, and particularly the Expanded System Readiness Reviews (ESRRs), are a primary source of discovery input.

The three separate but related processes for readiness review (i.e.,

systems, programs and functional areas) provide overlapping and multi-dimensional perspectives on factors which could affect plant performance.

Management may direct other internal or third party assessments to supplement these established methods as necessary.

~ Corrective Action Program The CNP Corrective Action Program is the normal and permanent process for identifying, evaluating and correcting problems.

Condition Reports and Action Requests are the, approved Corrective Action Program methods for reporting problems and discrepancies at CNP. Therefore, problems and discrepancies identified through the discovery process shall be reported using these methods, in accordance with PMP 7030.INT.001, Corrective Action Initiation.

~ Leadership Plans:

A Leadership Plan is a management tool designed to capture those actions considered necessary for the tong-term improvement of a department. Although Leadership Plans are not specifically part of the Restart Program, it is clear that some action items, or portions thereof, in Leadership Plans will be considered prerequisite to startup and with management's direction be managed utilizing Restart Action Plans.

Leadership Plan requirements are established in PMP 2090.001, Leadershi Plans.

2.3. Expanded System Readiness Reviews (ESRR)

The plant system and containment readiness assessment process is controlled by PMP 7200.RST.004, Ex anded S stem Readiness Review

~Pro ram. its purpose is to provide reasonable assurance that systems are capable of performing their safety and accident mitigation functions by assessing conformance with the design basis and licensing basis. The ESRR establishes a disciplined approach to system assessment, ownership, and accountability thereby promoting continued safe, efficient and reliable plant operation.

The ESRR process is comprehensive and rigorous in its methods. The process integrates the results of discovery efforts through the use of CNP Restart Plan March 3, 1999 Revision 5 Page 10 of 23

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EI.EC7RIC POWER information technology. This enables a collective review of potential adverse conditions and their impact on plant systems, programs and processes.

The ESRR Process begins with discovery and continues through implementation, verification, and startup and power ascension. It comprises four distinct phases, as summarized in Table 1.

Table 1: Expanded System Readiness Review Program Phases ESSR Phase 1: Initial System Readiness Review

~ Assessment of system design and licensing basis

~ Performance of a comprehensive multi-disciplined and/or System Manager walkdown of the system materiel condition and operability issues

~ Evaluation of open action items against the restart screening criteria

~ Determination of restart and post-restart work scope

~ Presentation of system readiness reviews to SRRB and PNSRC ESSR Phase 2: Restart Activities Monitoring

~ Evaluation of emergent action items against restart screening criteria

~ Intrusive examination of field work

~ Further review of open corrective action items

~ Monitoring of work completion in preparation for final system readiness reviews

~ System Walkdowns by the System Manager ESSR Phase 3: Final System Readiness Review

~ Review of completed restart scope work

~ Performance of system readiness walkdowns by the System Manager and an operations representative

~ Presentation of the Final System Readiness review to SRRB and PNSRC ESSR Phase 4: Start and Power Ascension"

~ System Manager monitoring of restart activities and continuous monitoring of system readiness

~ System Manager establishing system performance monitoring baselines for tracking and trending

~ Monitoring of new corrective maintenance activities or condition reports The Expanded System Readiness Review Program activities are suppiemented by the Restart Readiness Review and Startup and Power Ascension sections of the CNP Restart Plan.

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ELECTRIC POWER 2.4. Programmatic Readiness Assessments Programmatic readiness assessments confirm that programs are in place and functioning. Programmatic issues identified during discovery are evaluated, and necessary corrective and preventive actions are completed. Programs in place at the time of startup must be adequate to provide reasonable assurance of safe operation of the plant and provide reasonable assurance of conformance with the design and licensing basis.

The programs to be assessed, as of the issue of this plan (revision 5), are listed in Attachment 4. Programmatic readiness assessments are governed by PMP 7200.RST.009, Pro rammatic Restart Readiness. Management may elect to perform additional assessments pending review of results and trends.

2.5. Functional Area Readiness Assessments Functional Area Assessments are conducted to determine that a department is in an appropriate state of readiness to support startup and safe operation.

Elements of the Functional Area Assessments include staffing levels, training and qualifications, experience, performance deficiencies, reduction of backlog, and the establishment of continuing improvement goals.

The functional areas to be assessed, as of the issue of this plan (revision 5),

are listed in Attachment 5. The Functional Area Readiness Assessment process is governed by PMP 7200.RST.010, Functional Area Restart Readiness.

2.6. Corrective Action Program The Corrective Action Program is a comprehensive process of identifying, evaluating and correcting problems. It affects all areas of CNP work, both restart and non-restart. Also, the effectiveness of the Corrective Action Program is itself an NRC 0350 Issue, and actions are in progress to monitor and improve its effectiveness.

In light of the unique circumstances of the extended shutdown, other processes are being employed at CNP to supplement the Corrective Action process. Special restart readiness processes, as described in Sections 2.2 through 2.5, provide extensive discovery capability. The ESRR Process, utilizing Restart Criteria, is being used to ensure that identified problems are appropriately prioritized for completion prior to restart.

The Corrective Action Program is integral to these efforts at CNP, and it is to be used as directed by applicable station procedures. Personnel recognize the importance of vigilance and a questioning attitude, and identify, report and correct problems via the Corrective Action process on a continuing basis.

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'NERICAIVe ELECTRIC POWER At an appropriate point in the restart effort, when it is determined that the Corrective Action Program is working effectively and that there is no further need for supplementary processes, senior management will direct that the Restart Criteria process (see Section 2.8) be discontinued. At that point, the Corrective Action Program will be used, along with other work control processes, for prioritization and classification of identified problems.

2.7.Classification of Identified Items Required for Restart For every item identified and evaluated in the discovery process, a determination must be made as to whether it must be resolved prior to restart.

This determination shall be made in accordance with logical screening criteria and a methodical process. This step of classifying identified items as 'restart required's a key part of the discovery process.

2.8. Criteria and Process for Designation of Restart Items The determination of which items identified through the discovery process must be resolved prior to restart is made by means of consistent application of restart criteria established for this purpose. These criteria address nine attributes:

~ Nuclear Safety

~ Operability

~ Design Basis

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License and Licensing Basis Licensing Commitments

~ Configuration Management

~ Reliability

~ Post Restart Issues

~ Industrial Safety The criteria are discussed more fully in Attachment 6.

The process for classification is prescribed in PMP 7200.RST.004, ~Ex ended S stem Readiness Review Pro ram. Each System Manager is accountable to perform initial classifications for all items entered into SIDS, using the criteria in Attachment 6. Potential restart items are then presented to the System Readiness Review Board (SRRB) for classification as "restart required." Upon classiTication of an item, the information is reviewed by the Restart Team for incorporation in the Integrated Restart Schedule update.

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These potential restart items, once loaded into SIDS, are accessed by users, via networked PCs, as the work proceeds through the steps of classiTication, implementation, verification and startup and power ascension.

2.10. Commitments Adherence to commitments is a cornerstone of CNP's operating philosophy.

From an organizational perspective, this objective will be reinforced through daily practice and accountability. It is essential that all CNP management and staff adhere to commitments made to the NRC, to other external groups, and to each other.

NRC commitments may be rooted in regulatory guides and standards, generic letters, NRC Inspection Reports, in minutes of meetings with the NRC, and in other correspondence, and may be enumerated and documented in responses to the NRC. CNP's discovery processes are intended to identify external commitments. Once identified and documented in accordance with plant procedures, the commitments may be checked for plant conformance.

The process for identifying and tracking commitments (including those made in the future during the restart process and after during normal operations) is found in PMP 7100.CMP.001, NRC Commitment Mana ement Pro ram. All commitments to the NRC must be documented and tracked in accordance with this program.

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3. Implementation Fixing the Problems osoov err tm ptementatcn Identify, Repair:

Understand and Systems; Classify Programs; Processes

.3.1. Objective The objective of implementation is the completion of designated work to a standard that provides reasonable assurance of successful restart.

3.2. Restart Action Plans The Restart Action Ptan process is the primary vehicle for managing significant restart items. It is a simple and flexible project management tool.

It is a "cross-cutting" process, affecting multiple steps in the restart path forward.

Restart Action Plans are required for all NRC 0350 issues, along with other signiTicant actions as selected by management. This process is being established to supplant the "Restart Strategies" process described in previous revisions of the CNP Restart Plan. The objective and philosophy are-similar to the earlier process, but it is intended to be a simpler in implementation and to support integration of discovery with issue resolution, in keeping with the wide diversity of restart issues and actions.

The Restart Action Plan process is described in procedure PMP 7200.RST.001, Restart Action Plans.

3.3.Work Control and Integrated Restart Schedule Integrated scheduling is needed to prioritize and allocate resources for corrective action implementation. The Restart Team is accountable to develop, implement and maintain the Integrated Restart Schedule. The Integrated Restart Schedule is the vehicle to monitor accountabilities for assigned work. The Restart Director will provide the guidance on schedule control and plant personnel responsibilities.

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ELECTRIC POWER 3.4. Documentation Requirements Documentation demonstrating resolution of restart issues, program deficiencies and functional area weaknesses are required to support AEP oversight and NRC inspection. Documentation of implementation actions will fall within one of the following three categories:

~ Restart Action Plans These may require additional closure package documentation beyond existing practice, as defined by procedure PMP 7200.RST.001, Restart Action Plans.

~ Non-0350 restart items (including those deficiencies identified in the ESRR):

These are documented using existing permanent plant processes.

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Leadership Plan actions:

PMP 2090.001, Leadershi Plans, prescribes closure requirements.

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4. Verification Confirming that Objectives are Achieved Implementston verpicatron Identify, Repair: Confirm Corrective Understand and Systems; Actions; Classify Programs; Perform Sy'tem Processes Tests and Heatup 4.1. Final Readiness Reviews Final readiness reviews are intended to confirm that restart activities have been completed. The reviews shall be conducted to confirm system and containment readiness, functional area readiness (including programs),

regulatory readiness and operational readiness. Self-assessments, third party evaluations, peer reviews, and other verification methods will be used as directed by departmental and senior management.

~ Systems and Containment:

System Managers will assess assigned systems for affirming system readiness per PMP 7200.RST.004, Ex anded S stem Readiness Review Procrram. Readiness assessments by the System Manager and an operations representative will provide reasonable assurance that restart actions have been completed to facilitate a safe and reliable startup and continued operations.

The assessment of system readiness is a prerequisite to the turnover of systems to Operations. Any outstanding items remaining at final turnover to Operations will be scheduled for resolution in accordance with the Corrective Action Program commensurate with their significance. The System Readiness Review will not be considered closed until final Dp 2 i p 2 dp PMP 2200.002.002,~Rrt d Power Ascension.

~ Functional Areas and Programs:

PR Managers affirming the readiness of their functional and programmatic areas will perform assessments per PMP 7200.RST.010, Functional Area Restart Readiness. Readiness assessments for functional and programmatic areas will provide reasonable assurance that restart actions have been completed to facilitate a safe and reliable startup and continued operations. The readiness assessment is intended to ensure that potential restart issues have been identified, and assigned actions have CNP Restart Plan March 3, 1999 Revision 5 Page 17 of 23

'NERlCAN'l.ECTRlC POWER been completed and that departmental programs, processes, organizations, personnel, and management capabilities are adequate to support safe and reliable oper'ation.

~ Operations:

Each Shift Supervisor will perform an assessment of shift readiness.

These assessments are intended to ensure completion of required training, appropriate staffing, experience and qualification levels; acceptance of plant materiel condition, system readiness, operator 0

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workarounds (if any), and the control room environment. Additional 2 d t PMPT200.03T003 d~tT <<

~ Regulatory:

The Director of Regulatory Affairs shall perform an assessment of CNP's compliance with regulatory requirements and commitments. This assessment will include a determination of whether:

~ License amendments required for restart have been issued

~ Exemptions required for restart have been granted

~ Code applicable reliefs required for restart have been granted

~ Confirmatory Action Letter conditions required for restart have been addressed to the satisfaction of the NRC

~ Regulatory commitments required for restart have been satisfied

~ Compliance with license conditions has been verified

~ Ongoing programmatic commitments are being met or commitments have been revised

~ Inspection findings and open items required for restart are resolved 4.2. Affirmation Requirements The restart readiness process requires an affirmation that attests that there is reasonable assurance that restart actions have been completed to facilitate safe and reliable startup and continued operations. The affirmation is also intended to be the foundation for continuous improvement philosophy.

The Plant Nuclear Safety Review Committee (PNSRC) shall conduct readiness affirmation sessions and recommend restart to the Senior Vice President when appropriate. Following'acceptance by the PNSRC, the Senior Vice President shall authorize startup based on this review with input CNP Restart Plan March 3, 1999 Revision 5 Page 18 of 23

~ 'NERICAIII ELECTRIC POWER from the Nuclear Safety Design Review Committee, the Independent Safety Review Group and Performance. Assurance.

P Plant system and containment affirmation attributes are contained in PMP 7200.RST.004, Ex anded S stem Readiness Review Pro ram. The affirmation attributes for Functional and Programmatic Areas are contained in PMP 7200.RST.010, Functional Area Restart Readiness.

System turnover to Operations shall be performed to assure plant systems are acceptable to Operations per procedure PMP 7200.RST.003, ~Sstem Turnover to 0 erations.

4.3.Startup and Power Ascension As part of ESRR phase 4, system testing and related activities conducted during plant heat up (see Section 8) is to provide an additional level of assurance of effective corrective action and readiness for restart. Emphasis will be placed on assuring that personnel, programs and equipment are performing as expected and as required.

While permanent plant procedures shall be used to perform these activities, augmented staffing for test performance and operations shall be provided.

PMP 7200.RST.002, Startu and Power Ascension and PMP 7200.RST.005, Restart and Power Ascension Testin Pro ram describes these activities in detail.

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5. internal Oversight Ongoing Assessment 4

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Restert Auth.

Identify, Repair: Conflnn Corrective Effecttveness; Understand end Systems: Actions: Stsrtup/Power Classify Programs; Perform System Ascension; Processes Tests end Hostup Testing 5.1. CNP Oversight Organizations Several oversight organizations have been established with responsibilities unique to CNP restart, to supplement the Performance Assurance responsibilities under 10 CFR 50, Appendix B. The System Readiness Review Board (SRRB) applies direct oversight to the ESRR program, functional assessments, programmatic assessments and Restart Action Plans. Performance Assurance, the Plant Nuclear Safety Review Committee (PNSRC), Senior Management Review Team (SMRT), the Nuclear Safety Design Review Committee (NSDRC), and the Independent Safety Review Group (ISRG) will provide indirect oversight of the readiness reviews and Restart Action Plans.

Oversight organizations are discussed in more detail in Attachment 2.

5.2. Third Party Assessments Directors and managers may initiate independent third party assessments, as necessary, to supplement restart activities, particularly in the discovery and verification. phases of restart. Third party assessments are not required and do not replace or diminish the assigned responsibilities of CNP permanent plant or restart organizations.

5.3. Restart Readiness Measures Restart readiness measures provide the capability for management and staff to gauge progress in accomplishing goals and achieving readiness for restart.

Such measures include workdown curves, performance indicators, and tabulations of adherence to the Integrated Restart Schedule.

The Restart Team will be responsible for developing appropriate measures, compiling the necessary data, and disseminating and providing access to this information.

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6. Regulatory Oversight NRC Regulatory Oversight 1nternaiwOVeys~l't~

Restart Auth.

Identify. Repair. Confirm Corrective Effectiveness; Understand and Systdrlls Actions: Stanuprpower Classify Programs: Perform System Ascension:

Procdsses Tests and Heatup Testing 6.1. NRC MC 0350 Restart-Panel The NRC has implemented a Restart panel in accordance with Inspection Manual Chapter (MC) 0350 Staff Guidelines for Restart A royal to provide guidance for CNP's restart. The guidelines in MC 0350 ensure that:

~ Nuclear Reactor Regulation (NRR) and Region III Office are appropriately involved in restart decision for significant cases.

~ The NRC responds in a clear and appropriate manner with a uniTied position to the licensee.

~ Restart activities are comprehensive and appropriate for the specific reason for the shutdown.

The Restart Panel has developed a Case-Specific Checklist that provides a detailed list of actions and issues to be addressed prior to CNP restart. The items on the list were derived from NRC's review of inspection activities, the Confirmatory Action Letter (CAL), and, CNP Restart Plan (previous revisions).

6.2.CNP Role in Regulatory Oversight The Regulatory Affairs Department will coordinate support for inspections and assessments performed by or for the NRC and communicate with the NRC where opportunities may exist for assessments of CNP's restart program.

Establishing the confidence of the NRC is vital to a restart effort. This is attainable through a full awareness and compliance with regulatory requirements and commitments along with effective communications with the NRC via the NRC Communication Plan. It is important for the personnel working at CNP to be aware of their individual and collective roles in establishing NRC confidence that restart can be achieved.

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7. Authorization to Restart Restart Auth.

Dtaccvery Implementaten Verdicatatn Identify, Repair. Confirm Corrective Understand and Systems; Actions; Classify Programs; Perform System Processes Tests and Heatup 7.1. Senior Vice President Approval The Senior Vice President, with input from oversight organizations and senior management, will provide authorization for restart. This restart authorization will be based on confirmation of the following:

~ System, Functional Area, and Programmatic Readiness has been verified and affirmed by SRRB and PNSRC.

~ Operations has completed acceptance of plant systems and declared readiness for restart and power ascension.

~ Regulatory Affairs has obtained NRC concurrence for restart and satisfied other regulatory prerequisites, including:

Applicable licensing amendments have been issued Exemptions and/or relief has been granted where applicable Imposed Orders have been modified or rescinded CAL conditions have been satisfied Significant enforcement issues have been resolved Impact of allegations has been appropriately assessed 10 CFR 2.206 Petitions have been appropriately addressed.

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8. Startup and Power Ascension Q'

• o rag Restart Auth.

Deoovefy Implemeniaion Vericaiion Reaian Identify, Repair: Confirm Corrective Effectiveness; Successful Understand and Systems; Actions; Startup/Power Operations Classify Programs; Perform System Ascension; Processes Tests and Heatup Testing As part of ESRR phase 4, Startup and Power Ascension is the process of defining and conducting a well-planned, methodical and conservative CNP return'o power operation. The objective is safe, reliable startup and operation of the plant.

The program includes the following key elements:

~ Startup and power ascension management/support organization

~ .Specific hold points, acceptance tests and criteria for continuing restart

~ Contingency plans management observation program for the startup evolutions

'omprehensive

~ Performance Requirements

~ Plant Communications

~ Post startup reviews and critique.

PMP 7200.RST.002, Startu and Power Ascension, and PMP 7200.RST.005, Restart and Power Ascension Testin Pro ram, provides requirements for these activities.

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ELECTRIC POWER CNP Restart Plan Revision S Attachments And References CNP Restart Plan March 3, 1999 Revision 5

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~z AMERICAN ELECTRIC POWER Attachment]: CNP Outage History The following is a chronological synopsis of the major events leading up to and comprising the extended CNP shutdown. Taken as a whole, the outage history is one of gradually emerging problems and constantly evolving restart plans to deal with them. The changes to senior management in mid-1998, and the aggressive and comprehensive assessments initiated by the new team, made clear the full extent of corrective action needed to achieve readiness for restart.

This'revision 5 to the CNP Restart Plan provides a comprehensive, methodical and proven process to achieve that goal.

I

• Between July and September of 1997, the NRC conducted an architect engineering (AE) inspection at CNP. The inspection focused primarily on two safety systems, ECCS and CCW, and it raised issues regarding the sustainability of long-term core cooling during a design basis accident. As a conservative measure, AEP shut both units down on September 9, 1997.

At the conclusion of the AE inspection, CNP committed to address and resolve, prior to restart, the seven (7) specific issues that were identified during the inspection. Shortly thereafter, NRC issued a confirmatory action letter (CAL) identifying additional actions that must be taken by AEP prior restarting the units and advising that NRC approval would be required for restart. A January 1998 restart of both units was planned.

By the early part of 1998, steady progress had been made in resolving the initial CAL issues. At the same time, however, several new issues arose, relating primarily to plant containment systems. In light of these new, emerging concerns, AEP management chose to implement a more rigorous assessment of plant readiness. Three factors led to this decision:

~ Additional assessments would be required to determine whether the type of inspection findings discovered during the AE inspection existed in other safety related systems and whether they effected system operability.

~ It would be necessary to confirm that procedure inadequacies or equipment deficiencies that could challenge operators had been adequately identified and addressed.

~ Lessons learned from other licensees through the integrated assessment of readiness to restart following an extended shutdown period needed to be adopted and applied as appropriate.

CNP Restart Plan March 3, 1999 Revision 5 1-1

0' ANERlCAN ELEC TRlC POWER Also, in July 1998 the NRC established a CNP Restart Panel pursuant to NRC Inspection Manual Chapter (MC) 0350 to assure that its review efforts were appropriate and provided objective measures of restart readiness.

The CNP Restart Plan was incrementally revised several times over the next six months to reflect the expansion of issues uncovered by system, programmatic and functional area reviews as well as the need to address them in an adequate manner.

To test the effectiveness of the System Readiness reviews, CNP conducted a Safety System Functional Inspection (SSFI) of the Auxiliary Feedwater System.

The SSFI identified further design and licensing basis issues not detected by the previous work. The Senior Vice President-Nuclear Generation responded by commissioning an assessment of engineering programs by a panel of industry experts. The resulting Engineering Issues Review Group's final report identified additional system design bases and licensing basis issues, potential weaknesses in engineering programs and processes, and potential vulnerabilities with respect to the scope of systems reviewed during the prior System Readiness Reviews.

Additional assessments were performed at the direction of the new Vice President of Nuclear Engineering in the areas of Engineering Skills, Design Engineering, UFSAR, Corrective Aetio'n, and Engineering Training. It was clear that to achieve restart,'NP must expand its discovery efforts further and employ a more rigorous industry proven process to accomplish the original objectives of the restart plan.

Accordingly, in January 1999, senior management undertook additional actions to confront the scope of,the problems at CNP, beginning with an expanded discovery effort for systems, programs and functional areas. Building on this discovery, a methodical and comprehensive series of actions is now being implemented.

This revision 5 of the CNP Restart Plan represents a continuum with the restart efforts to date. It is intended to capture the full intent of previous revisions, and at the same time adopts proven and comprehensive processes used successfully at other facilities in achieving safe restart from extended outages.

,CNP Restart Plan March 3, '1999 Revision 5 1-2

" AMERICAN EI.ECTRIC POWER : Restart Organization The following are the key CNP organizational positions and the primary restart role(s) of each:

Senior Vice President Nuclear Generation Provides senior management oversight of the restart process and is responsible for; the management of the Restart Plan and; authorizing startup and power ascension.

~ Site Vice President Serves as chairman of the Senior Management Review Team (SMRT) and is responsible for the Restart Plan implementation Plant Manager Manages plant operations and is responsible for the Operations Department's acceptance of system readiness and power ascension.

Restart. Director Manages and controls the restart schedule and its implementation.

~ Vice President, Nuclear Engineering Oversees engineering related activities that include providing reasonable assurance that systems can be operated, maintained, modified, and tested in accordance with the design and licensing basis. Responsibilities also include the expanded system readiness review program and System Readiness Review Board.'ystem Managers Responsible for completion of the system readiness review program to provide reasonable assurance exists that the systems are operable, maintained, modified, and tested in accordance with the design'and licensing basis. System Managers are also responsible for the conduct of ESRR for their assigned systems'.

CNP Restart Plan March 3, 1999 Revision 5 2-1

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~ Director, Performance Assurance Oversees the Performance Assurance activities that provide for verification that CNP personnel, programs and facilities are meeting management expectations and quality standards.

~ Director, Regulatory Affairs Establishes expectations and requirements for plant communications with NRC personnel. Responsibilities also include MC 0350 issue closure, interfacing with the MC 0350 Restart Panel, communicating with the NRC and providing assistance to other plant departments on regulatory issues

~ Directors, Section Managers, and Department Superintendents Accountable for the rigorous and comprehensive performance of readiness assessments, identification of discrepancies, resolution of issues, implementation of corrective actions, completion of restart work, and providing affirmation of readiness to the PNSRC. Responsibilities also

.include the implementation of continuous improvement activities throughout the organization.

Restart Action Plan Owner Responsible for the successful implementation and completion of a Restart Action Plan as detailed in PMP 7200.RST.001, Restart Action Plans.

CNP Restart Plan March 3, 1999 Revision 5 2-2

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'MERlCAN~

El.ECTRlC

'OWER In addition, the following CNP Oversi ht Or anizations provide restart support:

~ Performance Assurance (PA)

Responsible for the Restart Readiness verification effort and providing appropriate resources to support the effort. PA verifies that D. C. Cook personnel, programs, and facilities are meeting management expectations and quality standards.

Senior Management Review Team (SMRT)

The SMRT is responsible for the generation and approval of the restart criteria, for approval of 0350 Restart Action Plans, and for the monitoring and oversight of the Restart Plan and associated processes.

Members: Site Vice President (Chairman)

Vice President Nuclear Engineering (Co-Chairman)

Plant Manager Director Performance Assurance Director Regulatory Affairs

• Independent Safety Review Group Member,

• • Restart Director

• • Restart Program Manager

• • AEPNG Legal Counsel

• This member will actively participate as available and will perform a continuous oversight role.

• • This member will actively participate on a regular basis in an advisory capacity.

~ System Readiness Review Board (SRRB)

Approves the scope of restart work utilizing restart criteria provided in Attachment 6. The SRRB also assesses the readiness of plant systems and containment, Engineering programs, and Engineering functional areas for restart. The SRRB charter is contained in PMP 7200.RST.004, Ex anded S stem Readiness Review Pro ram.

CNP Restart Plan March 3, 1999 Revision 5

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~

~~'MERICAN~

KMCrRlC POWER Plant Nuclear Safety Review Committee (PNSRC)

The PNSRC conducts readiness assessment sessions and recommends plant restart to the Senior Vice President when appropriate.

~ Nuclear Safety Design and Review Committee (NSDRC)

The NSDRC may be requested or choose to review Restart Action Plans, leadership plans, closure packages or other related restart documents that are not directly required by their charter.

~ Independent Safety Review Group (ISRG)

Identifies and reviews key information and issues associated with restart and provides feedback regarding restart program effectiveness to the Senior Vice President, Nuclear Generation, Nuclear Safety Design Review Committee, and other management personnel.

CNP Restart Plan March 3, 1999 Revision 5

Attachment 3: Plant Programs/Processes Required by Restart Plan The following is a matrix of restart processes and programs and their respective procedures, owners, applicability under the Restart Plan, etc.:

Process or Restart Plan Reference Restart Plan Key Individuals, Program Steps~ Attachment Departments, and/or Committees 0350 Issues Discovery PMP 7200.RST.001 Affairs

'egulatory Restart Action Plan Owners, SRRB, PNSRC Regulatory Discovery PMP 7100.CMP.001 Regulatory Affairs, PNSRC Commitments Leadership Discovery PMP 2090.001 Managers, Senior Plans Management Corrective Discovery PMP 7030. INT.001 All CNP Personnel Action Program SIDS Discovery PMP 7200. RST.004 SRRB ESRR Discovery P MP 7200. RST.004 Engineering, Operations, Verification SRRB, PNSRC Startup 8 Power Ascension Programmatic Discovery PMP 7200.RST.009 Managers, SRRB, PNSRC Readiness Assessments Functional Area Discovery PMP 7200.RST.010 Managers, SRRB, PNSRC Readiness Verification Assessments Gl Restart Item Discovery PMP 7200.RST.004 SMRT, Restart Manager P

+ O e ~4 Criteria c

Vl

~g Restart Action Implementation PMP 7200.RST.001 Restart Action Plan Owner, Restart Team o'~

D b Plans mco5

Process or Restart Plan Reference Restart Plan Key Individuals, Program Steps>> Attachment'" Departments, and/or Committeesi Integrated Implementation Team 'estart Restart Schedule Operations Verification Operations Manager, Readiness PNSRC'egulatory Regulatory Verification Affairs, PNSRC Readiness Affirmations Verification PMP 7200.RST.004 SRRB, PNSRC PMP 7200.RST.010 System Verification PMP 7200.RST.003 Engineering Turnover and Operations Department, Operations PNSRC Acceptance Internal Discovery, PA, SRRB, PNSRC, SMRT, Oversight Implementation, NSDRC, ISRG and Verification Startup and Verification, PMP 7200.RST.002 Operations, Maintenance, Power Restart- Engineenng, Appropnate Line Ascension Management NOTES:

(1) Identifies the restart step (as shown in Figure 1) where the process or program is presented in this plan.

Ql i

(2) Refers to the attachments in the CNP Restart Plan that either directly or indirectly provides guidance regarding Q O restart process or programs.

8 (3) Other individuals. departments, or committees may be involved.

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~~~ AMERlCAN~

El.ECTRIC POWER : Required Programmatic Readiness Reviews The following 'programs, at a minimum, will be assessed per PMP 7200.RST.009, Pro rammatic Restart Readiness:

~ 10 CFR 50.59 program

~

Operating Experience

~ Instrument Uncertainty

~ Corrective Action Program

~ Design Change Process

~ Calculations

~ Design and Licensing Basis

~ Procedures

~ Quality Assurance (QA) Audits and Quality Control (QC) Surveillances

~ Surveillances

~ Operator Training

~ FSAR Revalidation/Publication/Update Process

~ MOV

~ Human Performance

~ Failure Modes CNP Restart Plan March 3, 1999 Revision 5 4-1

~ 'NERICAIV~

ELECTRIC POWER : Required Functional Area Readiness Reviews The following functional areas, at a minimum, will be assessed per PMP 7200.RST.010, Functional Area Restart Readiness:

~ Operations

~ Maintenance Plant engineering

~ Design engineering

~ Nuclear Fuels and Safety Analysis

~ Chemistry

~ Radiation protection

~ Outage management

~ Licensing, including licensing support

~ Plant protection

~ Information management

~ Plant performance assurance Document Control'and Records Management including procedure development

~ Emergency Planning

~ Corrective Actions Group

~ Work Control

~ Training CNP Restart Plari March 3, 1999 Revision 5 5-1

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~ AMERlCAN~

DECI IC POWER . : Criteria for Work Included in Restart Scope The following are the criteria to be employed in determining whether an identified issue (or item) must be resolved prior to restart. Each will be evaluated against criteria 1 through 7. If any=of these criteria apply, the issue (or item) will be designated as 'required for restart'. If criteria 1 through 7 do not apply, then criteria 8 or 9 will dictate the classiTication.

Issues shall be resolved prior to restart if they are:

1) Nuclear Safety Required to address a nuclear safety issue.

Issues may be classiTied as follows:

a) Items that could result in significant personnel radiation exposure, radioactivity release or effluent discharge, in excess of limits.

b) Reduces cumulative deficiencies, backlogs or conditions that, in the aggregate, are evaluated to have significant negative impact on nuclear safety. (Not applicable to individual work issues).

2) Operability Required to address an operability issue.

Issues may be classified as follows:

a) Eliminates an existing component failure, deficiency, or condition that could result in operation in, or entry to, an LCO action statement if left uncorrected.

b) Would result in failure or inability to perform a required surveillance test during the current outage or the following operating cycle in accordance with the plant technical specifications.

c) Would increase the risk to operation or safety associated with performing a surveillance.

d) Testing or retesting that must be performed to certify system or component operability, including testing on systems or components during power ascension that result in breaching a system regardless of the work being classified as a restart issue or not.

CNP Restart Plan March 3, 1999 Revision 5 6-1

'NERlCAN~

ELECTRlC POMfER e) Reduces cumulative deficiencies, backlogs or conditions that, in the aggregate, are evaluated to have significant negative impact on operability. (Not applicable to'individual work issues).

3) Design Basis Required to restore acceptable design margin or conformance with the design basis.

Issues may be classified as follows:

a) Corrects design basis deficiencies; i.e, deficiencies in safety-related or technical specification equipment not in conformance with design basis documents.

4) License and Licensing Basis Required to resolve unreviewed safety questions (USQs) or to restore conformance with the license, license conditions or licensing basis.

Issues may be classified as follows:

a) Restores licensing basis deficiencies to conforming conditions.

b) Technical Specification changes to support safe plant operation.

5) Licensing Commitments Required to meet restart licensing commitments such as AIE inspection and related programmatic issues, and confirmatory action letter issues.

Issues may be classified as follows:

a) Resolves existing deficiencies or conditions that would result in the failure to meet a license requirement or a restart commitment to an outside

'gency.

6) Configuration Management Required to address an organizational, programmatic, or process deficiency that could prevent maintenance of adequate design margins or conformance, with the design or licensing basis.

Issues may be classified as follows:

a) Corrects deficiencies in configuration management programs, processes, engineering analysis codes, or operating, maintenance, or test procedures that have a reasonable probability of affecting equipment OPERABILITY.

CNP Restart Plan March 3, 1999 Revision 5 6-2

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EL,ECTR/C POWER

7) Reliability Required to address significant equipment material condition deficiencies singly or in aggregate, or repetitive failures that could affect safety system availability, impact plant reliability, or reduce the ability of operators to operate the plant safely..

Issues may be classified as follows:

a) Reduces cumulative deficiencies, backlogs or conditions that, in the aggregate, are evaluated to have significant negative impact on safety system availability or reliable plant operation. (Not applicable to individual work issues).

b) Restores degraded critical components or conditions that could result in a plant transient, power reduction or shutdown.

c) Resolves conditions that have resulted in repetitive safety system or equipment failures.

Issues that are not classified as restart should be classified as follows:

8) Post Restart Issues a) Issue can be scheduled for a subsequent outage.

b) Issue can be readily worked on line, does not affect safe and reliable operation, does not represent a significant challenge to Maintenance Rule Goals or LCO allowed outage time, and does not impair operations necessary to perform surveillance or monitoring.

c) Issue is classified as minor maintenance, or housekeeping, and does not affect plant operation.

d) Issue is an administrative issue.

e) Issue is a documentation deficiency that has no safety impact.

9) Industrial Safety Concern Note: Industrial safety concerns will not be classified as "restart" because the priority and resolution of these concerns will be addressed under the established work control process priorities and scheduling. Although an industrial safety issue is not classified as restart, it will be worked promptly, commensurate with the safety risk.

CNP Restarf Plan March 3, 1999 Revision 5 6-3

~ 'NKRlCAN~

ua'crwc POWER REFERENCES I

The documents referenced below support the implementation of the CNP Restart Plan. At the time of approval of revision 5 of the CNP Restart Plan, the asterisked (*) references have not been issued. The Restart Director shall assure that the asterisked references are developed and issued to support implementation of the CNP Restart Plan.

PMP 7200.RST.001 Restart Action Plans*

PMP 7200.RST.002 Startup and Power Ascension*

PMP 7200.RST.003 System Turnover to Operations*

PMP 7200.RST.004 Expanded System Readiness Review Program PMP 7200. RST.005 Restart and Power Ascension Testing Program PMP 7200.RST.006 Expanded System Readiness Review Program for Level 2 Systems*

PMP 7200.RST.009 Programmatic Restart Readiness*

PMP 7200.RST.010 Functional Area Restart Readiness",

PMP 2090.001 . Leadership Plans*

PMP 7100.CMP.001 NRC Commitment Management Program PMP 7030.INT.001 Corrective Action Initiation NRC MC 0350 Case Specific Checklist for the Donald C. Cook Plant NRC Inspection Manual Chapter (MC) 0350 Staff Guidelines for Restart A royal NRC Communication Plan Plant Communication Plan CNP Restart P/an March 3, 1999 Revision 5 7-1

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