Text

Restart Plan
	ML18101B122
Person / Time
Site:	Salem
Issue date:	10/13/1995
From:	; Public Service Enterprise Group
To:	;
Shared Package
ML18101B123	List: ML18101B122;
References
	PROC-951013, NUDOCS 9512040296
	Download: ML18101B122 (100)
	v • d • e

RESTART PLAN APPROVAL THIS RESTART PLAN WAS PRESENTED TO AND APPROVED BY THE MANAGEMENT REVIEW COMMITTEE MEETING NUMBER:

95 - 063 - 1 OCTOBER 13, 1995 C.C. WARREN L.F. STORZ E.C. SIMFSON DIRECTOR - NU AR HR & ADN!INISTRA TION

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SALEM RESTART PLAN ATTACHMENT 1 SALEM RESTART PLAN TABLE OF CONTENTS Page

1.0 INTRODUCTION

& OVERVIEW..................................................................... 1 2.0 PLANT, PEOPLE & PROCESS IMPROVEMENT............................................ 4 3.0 RESTART READINESS ASSESSlY.IENT........................................................... 8 4.0 RESTART DECISION...................................................................................... 11 5.0 STARTUP AND POWER ASCENSION PROGRAM....................................... 11

APPENDIX A RESTART REVIEW AND SCREENING PROCESS........................... 15 APPENDIX B CAUSE DETERMINATIONS............................................................. 17 APPENDIX C RESTART ACTION PLANS................................................................ 20 APPENDIX D SYSTEMS REVIEWED FOR RESTART............................................ 29 APPENDIX E OTHER RESTART CONSIDERATIONS............................................ 30

SALEM RESTART PLAN ATTACHMENT 1 SALEM RESTART PLAN

1.0 INTRODUCTION

& OVERVIEW 1.1 PURPOSE The Salem Restart Plan (SRP) describes and controls the activities needed to fundamentally change the performance of the Salem Generating Station (SGS). The plan outlines the work to be done to ensure the plant (equipment), people and processes are ready to support the controlled restart and continued reliable operation of SGS.

1.2 BACKGROUND

Salem Units 1 and 2 were removed from service by Public Service Electric & Gas Co.

(PSE&G) on May 16, 1995 and June 7, 1995 respectively. Although the plants were shutdown as a result of specific plant conditions and events, the decision was made to maintain the units in a shutdown status until recurring plant equipment, process and people issues could be resolved. On June 9, 1995 the NRC acknowledged this decision by issuing a Confirmatory Action Letter (CAL).

Prior to the unit shutdowns, a comprehensive assessment and improvement effort by PSE&G had been initiated. PSE&G had developed a tool for the overall management of improvement actions in the Nuclear Business Unit (NBU) called the IMP ACT (Issue Management and Prioritized Action) Plan. This plan was based on an extensive analysis of recent internal and external performance reviews, audits, assessments and inspections of both SGS Units specifically and the NBU in general. The IMPACT Plan included Intervention Actions, Near-Term Action Plans and Long Term Actions.

Following. the unit shutdowns, the IMP ACT Plan was reassessed to validate its applicability to the shutdown status of the units, and was then incorporated into the SRP. The SRP consists of a comprehensive and systematic approach for the identification, review, approval, assessment and affirmation of activities needed to support the restart and reliable operation of the Salem Units.

PSE&G has a new NBU management team in place that is providing fresh leadership and clear direction. These senior managers have proven expertise in turning around poor performing plants and are now driving the efforts for the NBU to achieve improved performance. This new management team is committed to producing sweeping changes in the conduct of operations within the NBU. Roles, responsibilities and goals have been established and communicated; personal accountability will be required. The focus is on: safety; conservative decision making; well planned, deliberate actions; support of the Operations Department; and long term reliability.

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SALEM RESTART PLAN ATTACHMENT 1 1.3 ROLES AND RESPONSIBILITIES The successful implementation of the SRP requires a consolidated team effort from all members of the NBU. The following is a list of roles and responsibilities of the key team members:

Senior Management - The Senior Vice President-Nuclear Operations (SVP-NO) is responsible for providing the overall strategy for the restart, establishing performance improvement strategies and expectations, and recommending to the Chief Nuclear Officer (CNO) that each unit be restarted. The Senior Vice President-Nuclear Engineering (SVP-NE) supports the SVP-NO and collaborates on the recommendation. The Director - Quality Assurance/Nuclear Safety Review (QA/NSR) independently advises the CNO as to the readiness of the Salem units for restart.

General Manager - Salem Operations (GM-SO) - Has overall responsibility for the management and implementation of the SRP. He is also responsible to ensure the necessary resources are available and properly employed.

Management Review Committee (MRC) - Utilizing consistent standards, applies a collegial assessment to the review and approval of the issues necessary for restart. The l\\1RC is a multi-disciplined team of managers, chaired by the GM-SO, with the attitude and experience necessary to thoroughly question and review potential plant, people and process restart issues.

System Readiness Review Board (SRRB) - Using established criteria, performs a technical assessment of each system readiness review package for consistency and completeness. The SRRB is a multi-disciplined team of Engineering Supervisors with the experience needed to assess the quality of system readiness reviews.

System Managers - Determine system readiness for restart, lead multi-discipline system review teams and continually monitor system health.

Restart Action Plan Managers - Develop and manage each individual Action Plan, monitor restart performance indicators/criteria and periodically assess plan progress/execution.

Department Managers - Perform self assessments of their individual departments, establish and implement corrective actions, and justify the restart readiness of their department to the l\\1RC.

All NBU Employees - Support the implementation of the SRP by focusing on plant safety and continuous improvement. Key to this responsibility is the obligation to raise any and all identified quality and safety concerns to management's attention for resolution.

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SALEM RESTART PLAN ATTACHMENT 1 1.4 OVERVIEW OF SALEM RESTART PLAN STRUCTURE The SRP consists of the following three major sections:

Plant, People & Process Improvement Restart Readiness Review & Affirmation Startup & Power Ascension An overview of each of these areas is discussed below. The process to control the review and screening of restart issues and restart approval is outlined in Appendix A.

1.4.1 PLANT, PEOPLE AND PROCESS IMPROVEMENT The Plant, People and Process Improvement effort is a comprehensive and systematic approach to identify and correct concerns as follows:

Analyze data & identify problems Determine needed corrective actions Establish corrective action plans Establish implementation effectiveness criteria Document and present findings and recommendations to the MRC Implement the approved action plans and corrective actions Monitor the effectiveness of the implementation Continue assessment of emergent issues for inclusion into the action plans Review revisions to action plans with MRC if necessary 1.4.2 RESTART READINESS REVIEW & AFFIRMATION The Restart Readiness Review assesses the readiness of the plant, people and processes for restart and continued operation. It consists of an initial verification of corrective action effectiveness followed by a detailed restart readiness assessment. Key elements include:

Final assessment/verification of plant, people & process readiness for restart System readiness affirmation to MRC Action Plan readiness affirmation to MRC Department readiness affirmation to MRC Operational readiness affirmation to MRC Integrated assessment of overall readiness QA/NSR independent verification Senior Management assessment of overall readiness Page 3 of30

SALEM RESTART PLAN ATTACHMENT 1 1.4.3 STARTUP & POWER ASCENSION The Startup and Power Ascension Program establishes a controlled and conservative process consisting of the following elements:

Establishing an augmented startup & power ascension management/support organization Defining specific hold points, acceptance tests and criteria for continuing restart Establishing contingency plans Implementing a comprehensive management observation program for the startup evolutions Completing a post startup review and critique 2.0 PLANT, PEOPLE & PROCESS IMPROVEMENT 2.1 This section of the SRP addresses improvement at Salem (specifically) and NBU (in general).

Plant, People and Process issues will be addressed through the following major aspects of the SRP:

System Readiness Review Program - Plant Equipment Issues Restart Action Plans - People & Process Issues Common Programmatic and Generic Issues Performance Improvement Monitoring SYSTEM READINESS REVIEW PROGRAM 2.1.1 PURPOSE The System Readiness Review Program establishes a process for system managers to systematically assess selected critical systems and affirm the readiness of the plant systems to support a controlled restart and safe reliable full power operation.

2.

1.2 DESCRIPTION

Procedure SC. TE-TD.ZZ-0023(Z), "System Readiness Review Program," provides guidance in researching, assessing and documenting system readiness of critical systems. Other supporting systems are reviewed using a thorough, but slightly less rigorous, process described in SC. TE-TD.ZZ-0025(Z), "System Readiness Review Program: Support Systems." Each system review was presented to the MRC for review and approval.

Both System Readiness Review procedures require:

Identification of Problems & Corrective Actions Monitoring of Corrective Action Implementation Verification of Completion of Corrective Actions Monitoring of Corrective Action Effectiveness Page 4 of30

SALEM RESTART PLAN ATTACHMENT 1 The System Readiness Review process consists of the following phafoes:

Initial System Readiness Review Restart Activities Monitoring Final System Readiness Review

Systems Restart Phase *

Although included in these procedures, these activities are primarily performed as part of the Restart Readiness Review & Startup Power Ascension sections of the SRP.

The Initial System Readiness Review phase includes the following key elements:

Review of system design and licensing basis Evaluation of open action items against the restart screening criteria Performance of a comprehensive multi-disciplined and/or System Manager walkdown of the system materiel condition and operability issues Determination of a restart work scope, power ascension work scope and post-restart work scope Presentation of system readiness reviews to the SRRB and MRC The Restart Activities Monitoring phase includes the following key elements:

Evaluation of emergent action items against restart screening criteria Extensive and intrusive examination of field work Further review of open corrective action items Monitoring of work completion in preparation for final system readiness reviews Completion of regularly scheduled walkdowns by the System Manager The Final System Readiness Review phase will include the following key elements:

Review of completed Restart Scope work against design and licensing basis requirements Performance of system readiness walkdowns by the System Manager and a licensed SRO Presentation-of the final System Readiness Review to the SRRB and MRC The Systems Restart phase will include the following key elements:

System Manager monitoring of restart activities System Manager establishing system performance monitoring baselines for tracking and

trending System Manager monitoring of new corrective maintenance activities or condition reports System Manager continuous monitoring of system readiness Page 5 of 30

SALEM RESTART PLAN ATTACHMENT 1 2.1.3

SUMMARY

This comprehensive and systematic process ensures that plant systems have been thoroughly evaluated, modified, tested and maintained to support restart. In addition, the process establishes a disciplined approach to system assessment, ownership and accountability thereby promoting the continued safe and reliable operation of plant systems.

2.2 RESTART ACTION PLANS 2.2.1 PURPOSE The Restart Action Plans form a systematic and strategic based process focused on correcting the root causes and contributing causes that have lead to the decline in performance at SGS and theNBU.

2.

2.2 DESCRIPTION

After the root and contributing causes for the decline in performance of SGS were identified, planning sessions were conducted to develop a strategic-based approach to performance improvement. Plans were developed by analyzing station performance issues, defining performance problem statements, and developing strategies and plans to address those problems. Sources of issues included the following:

Organizational Effectiveness Assessment NRC inspection reports INPO evaluations and training accreditation reports Business competitiveness issues Licensee Event Reports (LERs) and Incident Reports (IRs)

QA/NSR issues Comprehensive Performance Assessment Team (CP AT) issues Top-ten equipment priority lists A causal analysis was performed to determine the underlying causes for the problems associated with the SGS performance decline (see Appendix B). Action plans that incorporated the results ofthis analysis were developed prior to shutdown of the Salem units.

These plans were then reviewed and revised by management to ensure that essential startup issues, such as those documented in the CAL or the NRC Special Inspection Team report, were addressed and to reflect any changes required as a result of the shutdown and plans for restart. Action plan schedules will be maintained separately, updated periodically to show progress and managed to completion.

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SALEM RESTART PLAN ATTACHMENT 1 These SRP Action Plans address programmatic deficiencies in the following areas (Details provided in Appendix C):

Conduct of Operations Human Performance Management Engineering Performance Reliable Maintenance Work Control Process Improvement Organizational Self-Assessment Corrective Action Salem System Engineering Function And Equipment Reliability Accredited Training 2.3 COMMON, PROGRAMMATIC & GENERIC ISSUES 2.4 Plant, people and process issues that cross plant system and organizational boundaries will be assigned to an individual or group with appropriate resources to thoroughly investigate and recommend enhancements. A detailed list of the systems reviewed is included in Appendix D.

Other topics and programs were also presented to the MRC for review and approval. The more significant areas reviewed are shown in Appendix E.

PERFORMANCE IMPROVEMENT MONITORING Key performance indicators will be established to track the performance improvement effort.

These indicators are intended to provide a clear picture of the progress that has been made and indicate trends that are developing.

Materiel condition and equipment readiness will be evaluated against backlogs in key areas and specific equipment issues. Backlogs will be screened to ensure that there are no outstanding potential safety issues and that the aggregate effect of the backlog does not create a potential safety issue. Recurring materiel condition and equipment performance deficiencies will be addressed.

Additionally, people and process issues that hinder improvement will be addressed. Indicators will be used by management to monitor the effectiveness of the restart actions and to determine if organizational performance levels have improved sufficiently to restart the plant. The following are examples of indicators that will be monitored:

Corrective and preventive maintenance work orders Operator work arounds Control Room instruments out-of-service Temporary modifications Condition reports, incident reports and common cause trending Action Tracking System backlog Engineering work backlogs Page 7 of JO

SALEM RESTART PLAN ATTACHMENT 1 3.0 3.1 3.2 3.3 Drawing revisions Procedure revisions Problem self-identification Tagging Issues Training/Qualifications Adherence to standards Communications feedback Staffing levels Configuration Control Design Change Package quality Maintenance rework Human Performance Errors Quality of work package planning Action Request backlog Senior NBU Management will review performance indicators and compare them to expectations for an indication of readiness to restart.

RESTART READINESS ASSESSMENT PURPOSE Prior to implementing the Startup and Power Ascension Program, the NBU will conduct a series of assessments to affirm the readiness of the plant, people and processes to support a successful restart and safe and reliable full power operation.

DESCRIPTION The restart readiness assessment program involves the review and assessment of the results achieved by the collective plant, people and process improvement effort. Assessments will be performed in the following areas:

Routine Self-Assessments System Readiness Department Readiness Operational Readiness Integrated Readiness MRC Readiness ROUTINE SELF-ASSESSMENTS Routine self-assessments will be performed for Salem and NBU Support Departments, in accordance with SC.SA-AP.ZZ-0034(Q), "Self Assessment Program," as applicable. The focus of these self assessments will be on restart readiness in accordance with procedure SC.SA-AP.ZZ-0035(Q), "Operational Readiness Self-Assessment Program".

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SALEM RESTART PLAN ATTACHMENT 1 3.4 This procedure establishes an integrated line-management assessment and affirmation of system, departmental and operational readiness for restart. The program also provides a consistent management review and assessment of SGS materiel condition, plant operations, personnel performance, corrective action effectiveness, organizational responsiveness and functionality of the work control process.

SYSTEM READINESS ASSESSMENT Prior to restart, responsible system managers will affirm the readiness of the critical

. systems to support a controlled restart and safe and reliable power operation.

The objective is to thoroughly assess and document system readiness collectively to support management restart decisions, to reinforce ownership for system performance with system managers, and to lay the foundation for post-restart system health monitoring.

The program will include a formal method for release of completed systems for testing prior to startup. All testing performed will be controlled by appropriate station procedures following establishment of required prerequisites.

The startup-related operating procedures 'and significant test procedures will be prepared, verified and validated prior to the startup of the plant. Procedures for special tests and other off-normal evaluations will be reviewed carefully against appropriate regulatory requirements and industry standards.

Walk-throughs will be performed prior to significant evolutions. The plant simulator may be used to validate complex test procedures.

3.5 DEPARTMENT READINESS ASSESSMENT Departments will affirm restart readiness in accordance with the Operational Readiness Self-Assessment Program.

The assessment will ensure assigned restart actions are completed and that programs, processes and organizational capabilities are sufficient to support safe and reliable operation. It also ensures that post-restart work and improvement efforts are sufficiently defined, prioritized, scheduled, and controlled, and that appropriate post-restart assessment and monitoring processes are in place.

Final department readiness affirmations and checklists will be completed and signed by the respective Department Managers. The affirmations will then be reviewed by the MRC based on established criteria.

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SALEM RESTART PLAN ATTACHMENT 1 3.6 OPERATIONAL READINESS ASSESSMENT The Operations Manager, with input from each Senior Nuclear Shift Supervisor will assess and affirm each operating shift' s readiness to support a controlled, conservative and deliberate startup and subsequent safe and reliable operation. The assessment will confirm completion of required training, appropriate staffing levels, experience and qualification levels and acceptance of the plant materiel condition, system readiness and the control room working environment.

Indoctrination on the Startup and Power Ascension Plan will be completed and standards for conduct of operation established and communicated. This review will address the responses of the broad range of events that could occur during startup. Reviews specific to the startup will be conducted with the follow-up pre-shift or pre-job briefings to emphasize key items covered in the startup training.

3. 7 INTEGRATED READINESS ASSESSMENT An independent team will perform an assessment of the overall operation of SGS and the appropriate support organizations.

Experienced personnel from outside PSE&G will supplement the SGS team performing this independent readiness assessment. The team will be composed of individuals with diverse backgrounds in management, operations, engineering, oversight, quality assurance and other skills.

The team qualifications will ensure that issues are examined thoroughly; that actions in response to the SRP requirements successfully resolved the issues; and that performance improved.

3.8 MRC READINESS ASSESSMENT The overall station readiness assessment will consist of several interfacing and overlapping inputs. These include the system, operational and department readiness affirmations described above, the disposition or close out of restart items, the review of organization and personnel adequacy, and other input from personnel and management.

The MRC will review and evaluate the individual inputs and the roll-up of these inputs and then provide a recommendation to the SVP-NO relative to restart.

3.9 QA/NSR RESTART VERIFICATION QNNSR will independently review the results of the action plans and advise the CNO as to the readiness of the Salem units for restart.

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SALEM RESTART PLAN ATTACHMENT 1 4.0 RESTART DECISION Considering the MRC evaluation and recommendation, the results of the integrated readiness assessments and the QA/NSR verification, the SVP-NO will recommend restart to the CNO.

When the CNO is satisfied, based on line management input and independent verification, that the station is ready for restart and that the NRC is satisfied with the response to issues identified in the CAL, the Startup and Power Ascension Program will be implemented.

5.0 STARTUP AND POWER ASCENSION PROGRAM 5.1 The Startup and Power Ascension Program establishes a well defined and deliberate approach for the restart of Salem. 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 Comprehensive management observation program for the startup evolutions Post startup review and critique STARTUP & POWER ASCENSION MANAGEMENT/SUPPORT ORGANIZATION A management/support organization will be established to provide the experience, safety focus, and added resources to enhance the operating shift and line organization's ability to conduct a safe and conservative startup. This organization will provide a continuous presence of management oversight/support and maintenance/engineering expertise to analyze and resolve emergent issues during startup.

5.1.1 OUTAGE MANAGEMENT TEAM The normal Outage Management organization consists of two outage managers, one for each unit. A Shift Outage Manager supports both Outage Managers and provides around the clock control of the Outage Control Center. The Outage Control Center is staffed by shift representatives from the Maintenance, Engineering and Procurement Departments. The Shift Outage Manager is also supported by a number of shift Outage Coordinators, who oversee and coordinate activities throughout the plant.

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SALEM RESTART PLAN ATTACHMENT 1 5.1.2 STARTUP SUPPORT TEAM The Outage Management Team will be supported by a Shift Plant Manager, Shift Engineering Support Manager and Startup Testing Manager. The Startup Testing Manager will be supported by Shift Startup Testing Engineers. Descriptions and responsibilities of these positions are as follows:

Shift Plant Manager - An assigned manager that will provide an on-shift (24-hour) presence as a direct representative of the GM-SO and is responsible for maintaining an overall perspective of the startup process. If necessary, the Shift Plant Manager is authorized to request Operations to delay the startup, reduce power or shutdown to make necessary repairs, keeping the GM-SO informed of these decisions. The Shift Plant Manager, with the concurrence of the GM-SO can authorize ascension to the next power level.

Shift Engineering Support Manager - An assigned manager that will provide an on-shift (24-hour) presence as a direct representative of the Director - System Engineering and be responsible for maintaining an overall perspective on engineering support for the startup process. This Manager will control on-shift engineering resources as necessary to support scheduled startup testing activities, resolve emergent operability issues, support maintenance, and manage necessary reactor engineering tests and control room activities.

Startup Testing Manager - A designated engineer/manager, who provides the necessary focus and single point of contact needed to coordinate the overall startup and power ascension test program. The Startup Testing Manager is also responsible for the development of the Startup and Power Ascension Testing Plan.

Shift Startup Testing Engineer - A designated engineer/manager, who provides an on-shift (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) presence to implement the startup and power ascension test program at the direction of the Startup Testing Manager.

5.2 SEQUENCE OF ASSESSMENT HOLD POINTS The Startup and Power Ascension Program covers activities and hold points from cold shutdown to full power operations. The Startup Testing Manager and Outage Managers will develop the schedule and hold points. The hold points will be derived from procedural requirements, surveillance tests and post-maintenance testing requirements. The hold points permit time to confirm satisfactory plant performance, ensure effective resolution of open and emergent issues, and review and evaluate test and assessment results. The Shift Plant Manager will review and approve proceeding beyond established hold points.

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SALEM RESTART PLAN ATTACHMENT 1 5.2.1 HOLD POINTS Specific hold points will be established in the startup plan to support testing. The following are typical of hold points that will be in the plan:

Cold Shutdown (MODE 5)

Reason: Complete Containment Close-out; evaluate completed checklists Hot Shutdown (MODE 4) Tave< 350 F Reason: Perform plant safety system testing, system and area walkdowns, evaluate walk-down reports and materiel condition, implement corrective actions, complete minor maintenance Hot Standby (MODE 3) Sub-critical, Tave> 350 F Reason: Testing, provide assurance ofreadiness to request NRC concurrence to progress toMODE2 Startup (MODE 2) Critical, < 5% power Reason: Readiness assessment post criticality, prior to proceeding above 5% power and synchronize main turbine to grid Power Operation (MODE 1) > 5% power 30 to 40% Power Reason: To perform assessment after the main turbine is synchronized to the grid Overall assessment of plant, process and people performance 5.2.2 TESTING Critical systems selected for pre-operational functional testing will be integrated into the start-up schedule. Test results will be reviewed to ensure operational readiness of plant equipment and technical specification compliance.

5.3 CONTINGENCY PLANNING The Startup Testing Manager will ensure that contingency plans are in place to provide sufficient assistance as may be necessary to support the startup schedule.

A review of past Salem startup/OEF startup issues will be performed to anticipate potential problems.

The power ascension schedule includes a specific extended review to be conducted at a hold point between 30 to 40% power (or other appropriate hold point as delineated in the plan) to evaluate overall plant, process and people performance prior to continued power mcreases.

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SALEM RESTART PLAN ATTACHMENT 1 5.4 MANAGEMENT OVERSIGHT During the startup and power ascension, the Salem management team will increase management oversight on startup evolutions, principally testing, maintenance and plant configuration changes. The Startup Testing Manager is responsible for preparation and coordination of schedules for management observations in support of the SRP. The observations will be activity driven, i.e., they will be scheduled around specific activities that the Startup Testing Manager and the GM-SO consider appropriate for increased observation and follow-up. Observations results will be reported directly to the GM-SO and Startup Testing Manager.

5.5 POST STARTUP REVIEW At an appropriate time following the startup of Unit 1, the Startup Testing Manager will lead a critique of the startup. Input will be solicited from all participating organizations. The review will identify, communicate and address any lessons-learned, considering both problems and positive experiences. These experiences will be incorporated into the Unit 2 and future start-ups.

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SALEM RESTART PLAN ATTACHMENT 1 APPENDIX A RESTART REVIEW AND SCREENING PROCESS ISSUE IDENTIFICATION A comprehensive review of plant, people and process performance issues was conducted (System Readiness Reviews and Action Plans). Emerging issues will be screened to identify modifications to the SRP Action Plans needed to meet restart objectives. The SRP provides the process to identify other reliability issues that need to be addressed prior to restart (e.g., station work arounds, control room indicators, operability determinations, corrective and preventive maintenance backlogs, engineering issues and spare parts issues.

ISSUE SCREENING Issues will be evaluated by the appropriate person or line organization to determine if they should be resolved prior to station startup or carried forward. The issue screening process will provide a structured method to ensure each issue is addressed appropriately. The issue screening evaluation will be performed in two levels using pre-established criteria described in Table 1. Recommendations from the screening will be presented to the 1\\1RC for approval. Restart issues, along with the results of the screening (start-up or non-start-up) and status (open/closed) will be entered into a controlled data base to ensure the appropriate outage work scope is identified and completed. Evaluations will be documented and retained.

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SALEM RESTART PLAN ATTACHMENT 1 Table 1 Restart Scope Screening Criteria Level 1 Screening - The proposed action resolves a safety or operability issue. (These automatically require resolution prior to plant startup.)

Level 2 Screening - Although not a safety or operability issue, the proposed action:

1. Eliminates a component failure, deficiency or condition that could result in operation in or entry into an LCO action statement.

2. Resolves deficiencies or conditions that

a. 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,

b. would increase the risk to operation or safety associated with performing a surveillance, or

c. would result in the failure to meet a license requirement or a commitment to an outside agency.

3. Restores degraded critical components or conditions that could result in a plant transient, derate or shutdown.

4. Resolves conditions that have resulted in repetitive safety system or power block equipment failures.

5. Restores licensing-basis deficiencies to conforming conditions (e.g., EQ, Appendix R, seismic

& environmental).

6. Corrects design basis deficiencies, i.e., deficiencies in safety related equipment or other Technical Specification* equipment not in conformance with design basis documents such as the UFSAR.

7. Corrects deficiencies in configuration management programs, processes, engineering analysis codes or documentation that have a reasonable probability of affecting equipment operability.

8. Eliminates conditions that may create an unacceptable potential for personnel radiation exposure, an unplanned radioactivity release to the environment or discharge of eflluent in excess of limits.

9. Reduces cumulative deficiencies, backlogs or conditions that, in aggregate, could have significant negative impact on safety, operability or reliable plant operation. (Not applicable to individual work items.)

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SALEM RESTART PLAN ATTACHMENT 1 APPENDIXB CAUSE DETERMINATIONS

1. The Twelve Common Cause Issues The following documents contain self-generated and independent information about performance issues at Salem:

Focused Self Assessments including CPAT QA Assessment Findings SALP Report NRC Special Inspection Team (SIT) Report NRC Augmented Inspection Team (AIT) Report 4/7 /94 INPO 1994 Report INPO 1995 Report Licensee Event Reports Incident Reports Organizational Effectiveness Assessment Report As part of the Salem restart program, the :findings in these documents have been reviewed by multiple organizations to identify the fundamental issues behind the recent poor performance of people and processes at the plant (Figure 1 ). These reviews included:

The original screening of :findings by the responsible department manager and staff.

Review of findings performed by PSE&G and an outside consulting organization to establish Near Term Action Plans.

Review of LERs and IRs performed by FPI International.

Validation and restructuring of restart plans performed by PSE&G and an outside organization.

Twelve common causes were identified that capture the fundamental issues behind the :findings..

The methodology used for the analysis is depicted in figure 1.

Performance Issues NRC INPO Others Analysis PSE&G Outside Org.

Figure 1: Common cause development sequence Page 17 of 30 Common Causes

SALEM RESTART PLAN ATTACHMENT 1 The consensus of the teams that conducted these reviews is that all people and process problems related to the findings can be mapped to these twelve causes. The overall list of common cause issues has been segmented for implementation purposes as shown in the following table:

Focus Site Wide Common Cause Issue I

People Roles, responsibilities and accountability require better definition across theNBU.

2 People Standards of performance and work expectations must be enhanced.

3 People Performance expectations must be more effectively monitored and enforced by managers and supervisors.

4 People Communications and coordination must be improved across.functional lines and vertically within departments.

5 People Staffing adjustments must be made to ensure that all personnel have sufficient time to carry out core responsibilities.

6 People Implementation of training and qualification to meet accreditation standards must be improved.

7 Process/

Higher standards for equipment performance and maintenance must be Program built into the operations culture.

8 Process/

Conservative decision making and safety perspective must be enhanced.

Program 9

Process/

The NBU must become more operations focused.

i----**

Program IO Process/

The ability to determine root causes for problems and establish lasting Program corrective actions must be improved.

11 Process/

The work control process must be redesigned to improve availability of Program resources and hardware to resolve equipment deficiencies.

12 Process/

Self assessment processes must be enhanced to ensure better Program identification and resolution of process/program problems.

2. Evaluation Methods Similar evaluation methods were used by the NBD and outside teams to identify common causes.

In these evaluations, the departmental performance issues and cause determinations identified by the restart action plan owners were examined and screened. Original NRC, INPO and Self Assessment documents were also sampled to validate the restart plan data. Using this information, the following criteria were used to identify site wide common cause issues:

The issue is a pervasive attribute of the NBU culture that negatively impacts performance.

The issue is a common process, activity, or resource that is performed or used by most functional units and is contributing to poor performance in multiple units (e.g., self assessment).

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SALEM RESTART PLAN ATTACHMENT 1 The issue is a key process owned by one functional unit that impacts the performance of multiple units (e.g., work control).

The independent evaluation performed by FPI was directed specifically at the causes of 100 IR.s and 200 LERs from 1992-1995. An outside organization used "Common Cause Stream Analysis" to identify the following common causes:

Poor internal communications within the Operations Department.

Poor accountability system for improving work practices of poor performers.

Poor supervision for human error prevention, reinforcing management expectations and accountability.

Poor professional standards, and in some cases, low n;ianagement expectations.

PSE&G is confident that sufficient evaluation has been performed to isolate these twelve common causes, and that significant improvement in these twelve areas will, in fact, resolve the people and process performance issues identified by all sources. PSE&G also recognizes that there may be opportunities to combine issues for implementation purposes without sacrificing the quality of the results. PSE&G will consider combining issues if appropriate as the restart plans are implemented.

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SALEM RESTART PLAN ATTACHMENT 1 APPENDIXC RESTART ACTION PLANS 1.0 CONDUCT OF OPERATIONS I. I Objective Provide an operating philosophy and environment that breeds sustainable operational excellence.

1.2 1.3 Action Statements Establish shift resources for adequate long-term plant oversight.

Develop leadership skills and expectations for crew management.

Establish and implement Operations Standards Document.

Establish Operation System Managers and ownership of systems.

Establish and implement quality operability determinations.

Establish Operation's involvement in sche?uling of appropri~te work activities.

Improve communications and teamwork.

Establish streamlined Safety Tagging Program.

Reduce the operations procedure backlog and establish threshold for backlog.

Verify procedure readiness to support a safe and controlled startup.

Establish Operation's ownership of training program.

Assess operator readiness for restart.

Expected Results Clear expectations established that Operation's first responsibility is reactor safety. This responsibility will be met with safe and controlled operation of the plant.

Appropriate standards for the conduct of Operations established and effectively implemented.

Operation's leadership role in plant activities and ownership of plant equipment are established. This is evidenced by Operation's identification and prompt pursuit of plant problems and workarounds that interfere with or threaten safe and controlled operation of the plant.

Programs, procedures and policies are adequate to support plant startup.

SNSS and NSS assume ownership of their crew's knowledge, skill level and training.

Operator training program enhancement and departmental involvement result in the removal of the INPO probationary status from the program. Existing Operator proficiency is independently verified prior to plant startup.

A long-term plan for maintaining adequate department staffing levels and qualifications is in place. Adequate short-term measures in place to support plant startup.

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SALEM RESTART PLAN ATTACHMENT 1

2.

HUMAN PERFORMANCE 2.1.

Objectives The right people in supervisory positions.

Develop and communicate clear departmental goals and responsibilities.

Set realistic expectations and hold individuals accountable.

Learn and use new leadership skills and behaviors (i.e., meeting effectiveness, identification and communication of safety issues, conservative decision making, teamwork, etc.).

2.2.

Action Statements Staff and maintain a Salem Supervisory team that has the leadership qualities necessary to improve Salem Station performance.

Identify and communicate Salem's Vision, Mission, Goals, department roles and responsibilities and align goals to hold station personnel accountable for results.

Develop, implement and support learning experiences for those in supervisory positions to enhance/change their leadership skills and behaviors in order to get the performance results necessary in the NBU.

Implement recognition/communication efforts to keep station personnel informed and improve morale.

2.3.

Expected Results A strong, stable Salem management team having a clear mission and goals with demonstrated teamwork and/or ownership, high skills and knowledge, and a self-improvement culture is in place.

The Salem management and supervisor positions are filled with the right people who demonstrate competencies in organizational leadership, business focus, conservative decision making and performance results.

High standards and expectations are established, communicated, understood and demonstrated by employees who do the 'right thing the first time' and there is an upward trend in the safety culture index survey.

There is increased number of people on Performance Improvement Plans, turnover of employees and new hires.

Incident reports due to human error show a consistent decreasing trend.

Leaders in all levels throughout the NBU are working together as evidenced in productive meetings and improved plant performance.

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SALEM RESTART PLAN ATTACHMENT 1

3.

ENGINEERING PERFORMANCE 3.1.

Objectives Improve engineering organization management, leadership and safety focus.

Upgrade engineering programs and procedures.

Improve the quality of engineering activities.

Identify and reduce engineering backlog.

Implement and anchor a continuous improvement process that includes self assessments, performance indicators and other means of identifying needed improvements in engineering products and services.

3.2.

Action Statements Define and communicate expectations, roles, responsibility and goals for Nuclear Engineering.

Prepare a root cause analysis (RCA) procedure and train root cause analysis group in RCA techniques and methodology.

Characterize engineering backlog and initiate and complete restart backlog reduction.

Initiate third party assessment of Engineering Support Personnel training program.

Train Engineering staff to ensure high quality work.

Improve Engineering organization safety culture.

Improve management leadership.

3.3.

Expected Results The engineering organization is restructured and staffed to provide a more effective and proactive support to Salem Operations and Maintenance.

The engineering backlog reduced and maintained within the established goals.

Critical engineering programs and processes are upgraded to provide more effective Operations and Maintenance support with improved baseline, tracking and trending information.

The Engineering interface with station organizations is improved.

Engineering involvement is fully integrated with day-to-day Operations and Maintenance.

Quality and timeliness of engineering products and services in support of station operations.

Improved engineering quality.

Root cause analysis performed as a normal part of engineering.

Self assessments performed.

Improvements verified.

Performance indicators used to continuously assess performance.

Programs, processes and a safety culture that is effective and anchored in the engineering organization.

Page 22 of JO

SALEM RESTART PLAN ATTACHMENT 1

4.

RELIABLE MAINTENANCE 4.1.

Objective Identify, correct and assess those deficiencies in maintenance programs that when successfully corrected will support improved equipment reliability and materiel condition at the station.

4.2.

Action Statements Establish and communicate standards. and expectations for equipment and personnel performance.

Implement new work management program.

Benchmark Maintenance organization and programs against industry leaders.

Establish ownership and overall responsibility of the PM program in maintenance.

Review and revise as appropriate, Maintenance department program and procedures for control of contractors and non-station personnel.

Ensure communication of clear expectations for the conduct of training and qualification activities.

4.3.

Expected Results Maintenance effectively supports reliable equipment performance, improved materiel condition and safe operations.

Maintenance self-assessment and corrective action initiatives, and management oversight and follow-through effectively support the continual improvement culture of the station.

Maintenance department ownership of the training program results in a highly qualified work force to promote safe and reliable operations.

5.

WORK CONTROL PROCESS IMPROVEMENT 5.1.

Objectives Develop and implement an improved work control process that effectively supports operations and reliable maintenance.

Identify and reduce work control process backlogs.

Identify and correct work control interface areas inhibiting effective schedule implementation and productivity.

Identify weaknesses and upgrade the utility of work control support systems.

Improve process performance indicators for monitoring routine functions, backlogs and process effectiveness.

Utilize an effective self-assessment process as an input for sustaining and enhancing the work control process.

Page 23 of JO

SALEM RESTART PLAN ATTACHMENT 1

6.

5.2.

Action Statements Better define the structure and discipline of the existing work control process.

Eliminate or reduce the existing backlogs which have contributed to materiel and performance deficiencies to levels that permit the application of available resources to the resolution of real-time conditions.

Improve the organizational interface functions that support the work control process.

Enhance the Managed Maintenance Information System (MMIS) to support a comprehensive work control process.

Develop performance indicators to monitor and track work control process functions that provide sufficient visibility of process weaknesses.

5.3.

Expected Results A functioning work control process which establishes ownership, responsibility and accountability for all process functions, and emphasizes the strong role of the Operations Department in driving the process. The program implements a minor maintenance process which provides an effective and controlled method of promptly accomplishing minor work outside the normal planning and scheduling process.

Work control process backlogs are minimized and process flows are monitored and controlled to preclude accumulation of future backlogs. The corrective maintenance backlog is validated, prioritized, updated and scheduled to reflect Operations, Engineering, and Maintenance inputs.

Work control process interfaces between Planning and Scheduling, Maintenance, Operations, Engineering, Procurement and Material Management, Radiation Protection and other groups are controlled and functioning to support efficient schedule implementation.

Work control process functions and management controls are enhanced by effective support systems including the MMIS and scheduling hardware and software support.

A set of hierarchical performance indicators in place to monitor work control process functions and information flows providing for timely identification of functions needing management attention or process enhancement.

An effective process control function in place which includes periodic self-assessments of the work management program and the Planning and Scheduling Department as inputs for identifying and implementing process enhancements.

SELF ASSESSMENT 6.1.

Objective Develop the capability and acceptance of the Salem organization such that self assessment is used effectively and routinely to continually improve performance.

6.2.

Action Statements Page 24 of30

SALEM RESTART PLAN ATTACHMENT 1

7.

Revise self assessment program for Salem Station.

Establish a Salem Station self assessment coordinator.

Implement Departmental self assessment program.

Implement management and peer observer program.

6. 3.

Expected Results A new culture is established at Salem whereby self assessment is an automatic and explicit action by each employee.

Procedures are established to improve the use and effectiveness of self-assessments at Salem.

They address day-to-day management and the peer observation program. Organizational self assessments support restart and annual self assessment plans for all Salem departments are performed.

Salem has comprehensive organizational self assessments that document its major performance weaknesses and the completed actions that address these weaknesses. The assessment documents support the goals of a safe startup and reliable power operation.

The trends in Level 1 and 2 Condition Reports demonstrate an increased percentage of self-identified issues and an increase in issues being identified due to raising standards and expectations.

CORRECTIVE ACTION PROGRAM 7.1.

Objectives

*Establish a consolidated corrective action program with low threshold for entry.

Establish organizational point of accountability for corrective action program oversight with strong lirie management support.

Stabilize total number of corrective action documents.

Sustain performance of timely evaluations and corrective action implementation.

Sustain performance of high quality 'apparent cause' and 'root cause' evaluations and selection of corrective actions.

Establish an effective trending program.

Improve organizational performance.

7.2.

Action Statements Consolidate the corrective action programs that are currently distributed among several separate processes and develop key programmatic controls.

Establish single point of accountability with respect to management ownership and oversight.

Clearly define roles, authorities and responsibilities for administering the program.

Reduce the backlog of significant corrective action program documents.

Page 25 of30

SALEM RESTART PLAN ATTACHMENT 1 Complete evaluations and corrective actions in a timely manner. Reduce the frequency of missed or extended due dates.

Improve root cause analysis skills and procedures and increase the effectiveness of corrective actions.

Trend the corrective action program to support NBU needs.

7. 3.

Expected Results Process Performance Issues are entered into the corrective action program as appropriate.

Consistent timely completion of evaluations.

Complete corrective actions with minimal extensions and overdue items in a timely manner.

The number of corrective action program documents is manageable.

Quality apparent cause and root cause evaluations.

Implementation of effective corrective actions.

Negative trends identified and reversed in a timely manner.

Lessons learned are distributed to PSE&G and the industry in a timely manner.

Organizational Performance Reduced repeat events.

Reduced significant events.

Reduced personnel error rate.

Negative trends are arrested.

8.

SALEM SYSTEM ENGINEERING FUNCTION AND EQUIPMENT RELIABILITY 8.1.

Objectives Provide management expectations and system manager roles and responsibilities.

Achieve system manager accountability and ownership for system performance.

Improve system manager assessment ofsystem performance.

Identify and address equipment performance issues.

Assess and document system readiness.

Improve system manager monitoring of corrective action implementation and effectiveness.

8.2.

Action Statements Re-engineer System Engineering functions and processes.

Develop system readiness review program (evaluations & walkdowns).

Develop and implement the project to prioritize backlog of hardware issues.

Address high priority recurring equipment problems.

Page 26 of30

SALEM RESTART PLAN ATTACHMENT 1 8.3.

Expected Results As a minimum, system managers proactively monitor and trend system performance and ensure plant systems are in a state of readiness. As a result, plant systems are operated, maintained, tested, and modified in accordance with their design basis.

System Engineering processes and methods are revised and improved to facilitate:

Understanding the licensing/design basis Implementing system performance standards and monitoring Documenting system attributes in system notebooks Performing scheduled system walkdowns Processing data into information for trending and analysis The System Engineering culture and environment are changed to establish a proactive work environment which ensures:

Assertive identification of unacceptable or degrading equipment performance Consistent use of industry experience in problem solving Routine management of corrective actions Consistent application of root cause techniques to solve problems System managers are equal team members with Operations and Maintenance in decision making concerning system schedules and system performance.

System readiness review methods are adopted and become a permanent way of life for system managers.

9.

ACCREDITED TRAINING PROGRAM 9.1.

Objectives Establish clear expectations and accountabilities for training programs.

Ensure that the Training Department's resources and capabilities are adequate to meet expected performance levels.

Ensure that training materials and facilities support required training and are of high quality.

Ensure that training instructors are effective and meet performance standards.

Verify that all work activities are performed by appropriately qualified and trained personnel.

Upgrade the self-assessment process for training to emphasize line management participation.

9.2.

Action Statements Promulgate expectations regarding ownership of training and qualification to line and training management.

Set standards for training observations in all training settings.

Perform Training Department root cause analysis of issues associated with the Salem Operations Accreditation Renewal.

Page 27 of30

SALEM RESTART PLAN ATTACHMENT 1 Perform Assessments of key managers and supervisors and identify positions to be filled or replaced.

Ensure simulator configuration management supports required training.

Upgrade qualification instruments to industry standards.

Ensure that all operating shifts meet full qualification standards.

Evaluate the need to adjust the observation process by comparison with industry peers.

Assign PSE&G Recovery Team to objectively identify training weaknesses.

Prepare for Accreditation Board review.

9.3.

Expected Results Line managers consistently demonstrate ownership of their respective training programs and use their training programs to improve plant and personnel performance through:

Critical observations of training and/or qualification activities in all settings Leadership as chairmen of their respective Training Review Groups (TR Gs)

Participation in Comprehensive Self-Evaluations (CSEs) of their respective accredited training programs Participation in lesson plan and training development Instructor performance is consistently rated as effective and training materials are consistently rated as clear and accurate. Exceptions are addressed promptly.

The CSE process demonstrates a critical, in-depth proficiency that identifies training weaknesses, root causes and effective corrective actions. The CSE process also contains means to. verify corrective action effectiveness following implementation.

The Nuclear Training Department is adequately staffed to conduct effective training.

The simulator is maintained current, as evidenced by trainee and/or management feedback and completion of software and hardware changes in accordance with established standards.

Applicable actions within the plans are incorporated into the training programs and reinforced in training sessions for sustained improvements.

Full accreditation of the Salem Operations Training Programs is renewed.

Page 28 of30

SALEM RESTART PLAN ATTACHMENT 1 APPENDIXD SYSTEMS REVIEWED FOR RESTART

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SALEM RESTART PLAN ATTACHMENT 1 APPENDIXE OTHER RESTART CONSIDERATIONS Alternate Shutdown Methodology Appendix "R" - Fire Protection Systems Bill ofMaterial Validation Check Valve Program Commercial Grade Dedication Commitment Management Configuration Control Contractor Control Design Change Implementation Environmental Qualification Program Erosion/Corrosion Program Excessive Cooldown Fuse Control Hagan Module Refurbishment/Replacement In-Service Inspection In-Service Testing Leak Repair Maintenance & Test Equipment Calibration Maintenance Rule Motor Operated Valves Operator Work Arounds Reactor Vessel Embrittlement Security Snubbers Station Oversight & Review Committee Effectiveness Vendor Technical Documents Page 30 of 30

ATTAC.ENT2 ACTION PLANS ACTION PLAN Page OPERATIONS................................................................................................................ 1 HUMAN PERFORMANCE............................................................................................ 8 ENGINEERJNG............................................................................................................. 12 MAINTENANCE........................................................................................................... 19 WORK CONTROL........................................................................................................ 25 SELF ASSESSMENT.................................................................................................... 31 CORRECTIVE ACTIONS............................................................................................. 34 SYSTEM ENGINEERJNG & EQUIPMENT RELIABILITY........................................ 42 TRAINING.................................................................................................................... 48

c Op.ns Restart Action Plan ATTACHMEN

Management Sponsor: Manager - Salem Operations Introduction The Salem Operations Department has not been effective in providing adequate oversight of plant activities to ensure minimization of events and controlled plant operation. Operation's standards for equipment condition, communication and training are not adequate.

. This is evidenced by the current materiel condition of the plant and the status of the operator training program accreditation. The fundamental conduct of operations must be restored through a comprehensive restructuring of our people and business processes to - ensure safe and controlled operation of the Salem units. Reactor safety must be clearly established as our number one priority. Objective The objective of this action plan is to provide an operating philosophy and environment that breeds sustainable operational excellence. Expected Results Upon the completion of the Operations Restart Action Plan, the following results are anticipated: Clear expectation established that Operation's first responsibility is reactor safety. This responsibility will be met with safe and controlled operation of the plant. Appropriate Standards for the Conduct of Operations established and effectively implemented: Operation's leadership role in plant activities and ownership of plant equipment established. This will be evidenced by Operation's identification and prompt pursuit of plant problems and work arounds that interfere with or threaten safe and controlled operation of the plant. Programs, Procedures and Policies are adequate to support plant startup. SNSS and NSS assume ownership of their crew's knowledge, skill level and training. Operator training program enhancements and departmental involvement result in the removal of the INPO probationary status from the program. Existing operator proficiency independently verified prior to plant startup. A long term plan for maintaining adequate department staffing levels and qualifications is in place. Adequate short term measures in place to support plant startup. Revision 1 Page 1

Op.ns Restart Action Plan ATTACHMEN

Problem Statement 1 The Salem Operations Department's leadership in plant activities is deficient. Direct supervision of plant operations both in the Control Room and in the plant is weak.

Actions Restart 1.1 Establish shift resources for adequate long-term plant oversight.

a. Identify number oflicensed and non.:.licensed operators needed per shift.

YES

b. Develop interim shift organization for restart.

YES

c. Implement final shift organization for restart.

YES

d. Develop a long-term shift organization plan.

YES

e. Provide staffing for an interim shift STA position.

YES

f. Implement accelerated operator training classes to support staffing needs.

YES

g. Obtain sufficient personnel to meet organizational plan.

YES

h. Assess crew composition and compatibility.

YES

i. Ensure adequate crew balance for plant operation.

YES 1.2 Develop leadership skills and expectations for crew management.

a. Senior Vice President's initial expectations communicated to shift management YES

b. Peer visits at INPO 1 and SALP 1 plants for selected shift members.

YES

c. Provide shift mentors to assist in leadership development.

YES

d. Establish clear roles and responsibilities for operating crews.

YES

e. Provide routine self-assessment of crew's leadership performance YES 1.3 Re-establish control of plant activities and Control Room.

a. Shift crews review their duties and line management then transfer appropriate duties to operations staff and YES Work Control Center or other departments.

b. Review and streamline work control center processes.

YES

c. Restructure initial review of Action Requests (CR/CM) to a support staff function.

YES

d. Provide operations support and direction of Outage Control Center 24 hr. a day.

YES

e. Provide event investigation and root cause evaluation organization.

YES

f. Establish clear expectations of Control Room priorities and communicate these expectations to shifts.

YES

g. Establish supervisory presence in the field.

YES

h. Perform independent assessment of NEO/RO/SRO Control Room and plant activities.

YES

i. Revise Control Room assessors program with QA.

YES

j. Revise turnover process.

YES Revision 1 Page 2

Op.~s Restart Action Plan ATTACHMEN

Problem Statement 2 Operations Management's standards for plant and personnel pe~ormance are deficient.

Actions Restart 2.1 Establish and implement Operations Standards Document

a. Develop initial Operations Standards Document.

YES'

b. Communicate management's expectations for adherence to standards.

YES

c. Put standards into effect.

YES

d. Independently measure adherence to standards. Revise as required.

YES

e. MARC training performed and implemented.

YES

f. Implement method for bench marking Salem to current and future Industry leaders.

YES

g. Provide periodic audits to monitor and verify adherence to standard.

YES

h. Evaluate effectiveness of line management.

YES

i. Post restart continue to monitor and improve standards.

NO Problem Statement 3 Operation's ownership of plant equipment, communication of priorities and leadership in problem resolution needs improvement. Teamwork between Operations, Maintenance, Engineering and Planning is in need of enhancements. Identification of plant equipment issues that impact safety, reliability or requiring work arounds needs improvement. The Operations Department involvement with DCP conception, implementation and close-out needs improvement. Operation's process for making timely operability determinations needs to demonstrate stronger internal ownership and less reliance on engmeenng. Operations Management's involvement in schedule development and adherence needs improvement. Actions Restart 3.1 Establish Operation System Managers and ownership of systems.

a. Establish Operations System Managers, align with Technical Department and Maintenance System Managers, YES identify operators and publish joint list.

b. Communicate Management expectations for ownership of systems.

YES

c. Implement Operation's System Manager program.

YES

d. Provide line item signature by Operations System Manager indicating their system is ready for station startup.

YES Revision 1 Page 3

Op.ns Restart Action Plan ATTACHMEN

Actions Restart

e. Independently measure Operator ownership of program.

YES

f. Verify planned DCP training meets line management's expectations.

YES g_ Evaluate outcome ofDCP training. YES 3.2 Establish and implement quality operability determinations

a. Revise procedure to address GL 91-18 issues.

YES

b. Conduct training on operability determinations.

YES

c. Implement revised operability determination procedure.

YES

d. Independent review of shifts ability to make operability determinations.

YES

e. Incorporate review feedback into program.

NO 3.3 Enhance Operation's involvement in scheduling of appropriate work activities.

a. Develop Work Control Center roles and responsibilities.

YES

b. Develop Desk Top Guides to implement new program.

YES

c. Communicate management's expectations for adherence to schedule.

YES

d. Implement new work control process.

YES

e. Measure each shift' s adherence to schedule.

YES

f. Communicate management's expectations for tolerance of work arounds and appropriate use of schedule to YES resolve plant challenges.

g. Revise Retest program and work document process.

YES 3.4 Establish mechanisms to improve communications and teamwork.

a. Develop a plan to redesign the Control Room into a common controls area.

YES

b. Establish SNSS and NSS group meeting schedule.

YES

c. Furnish voice mail for operators.

NO

d. Develop program to enhance teamwork and communications between operating crews, maintenance and YES technical personnel.

e. Establish clear guidelines for communication of plant problems and priorities.

YES

f. Communicate expectations for operation's role in resolving plant problems.

YES

g. Provide enhanced means for operator identification of problems with a prompt feedback mechanism.

YES

h. Provide full crew simulator and classroom training sessions.

YES

i. Measure communications through follow-up assessments.

YES Revision 1 Page 4

Op.ns Restart Action Plan ATTACHMEN. Problem Statement 4 Operations procedures and policies need to be strengthened to support long-term operational excellence and plant startup. Crew ownership of procedures is lacking. Actions Restart 4.1 Establish streamlined Safety Tagging Program.

a. Evaluate Safety Tagging Program and implement short term corre<;;tive actions to reduce the number of YES tagging problems.

b. Revise Safety Tagging Program procedure.

NO

c. Revise Safety Tagging training.

NO

d. Implement Safety Tagging training.

NO

e. Implement Safety Tagging Program.

NO f Independent measure of program implementation and adherence to procedure. NO

g. Implement enhancements to Tris Plus.

NO

h. Measure Safety Tagging events through condition reports.

NO

i. Revise Operations Directive on Tris Plus.

YES 4.2 Review and revise as appropriate the self assessment program.

a. Identify assessment coordinator.

YES

b. Coordinator trained on NBU assessment program.

YES

c. Identify individuals to perform assessments.

YES

d. Identify areas in Operations to be assessed.

YES

e. Perform identified assessments.

YES f Incorporate assessment findings into action plan. YES

g. Perform final assessment for operator restart readiness.

YES

h. Report findings to Operation's Management, recommendation on ready to restart.

YES 4.3 Review and revise as appropriate the Condition Reporting, Root Cause and Corrective Action Programs.

a. Establish and staff a group to process Condition Reports, root cause and corrective actions.

YES

b. Perform coordinator training on root cause and corrective action.

YES

c. Provide event investigation and critique training to appropriate personnel.

YES

d. Identify additional resources required to reduce backlogs.

YES

e. Reduce root cause evaluations backlog and maintain a 7 day turn around.

NO Revision 1 Page 5

Op.ns Restart Action Plan ATTACHMEN

Actions Restart f Measure effectiveness of the program, recommended corrective action implementation.

YES 4.4 Reduce the operation procedure backlog and establish threshold for backlog.

a. Establish SCOPE of backlog, identify revisions required for restart.

YES

b. Implement plan to reduce backlog with contractor support.

YES

c. Establish plan to control backlog to allow technical revision incorporated prior to schedule use.

YES

d. Provide specific shift operator owners for each operating procedure.

YES

e. Implement plan to maintain backlog.

YES 4.5 Review and revise as appropriate Operation's Department Directives and develop policy for procedure implementation.

a. Identify Operation's Directives requiring revision I deletion.

YES

b. Establish schedule for revision completion and incorporate items into action plan.

YES

c. Complete identified revisions.

YES 4.6 Establish actions to delete Technical Specification Interpretations and reduce Technical Specification reportable occurrences.

a. Determine low value Technical Specification Interpretations and delete.

YES

b. Incorporate Technical Specification Interpretation's into appropriate documents.

YES

c. Identify Technical Specification LCOs which result in routine reportable events.

YES

d. Ensure appropriate corrective maintenance activities are planned for equipment identified in item c.

YES

e. Initiate License Change Requests to correct Tech Spec deficiencies resulting from item c as required.

YES f Establish operator assessment for the effectiveness of corrective actions associated with repeat equipment NO failures that resulted in unplanned technical specification entries.

g. Eliminate the use of Engineering Memos used to control plant operations.

YES

h. Review Tech Spec surveillances and ensure adequate surveillances are being scheduled and performed.

YES (LERJ l l/95-006) commitment 5/1/96

i. Develop Tech Spec matrix for surveillances.

YES

j. Establish shift ownership of surveillances.

YES 4.7 Establish actions for verification of procedure readiness to support a safe and controlled startup.

a. Review and validate station startup procedures on simulator.

YES

b. Validate and correct AOP discrepancies.

YES

c. Validate and correct EOPs to WOG guidelines. Provide basis for deviations.

YES

d. Review and revise operator tour logs.

YES

e. Validate and correct all Control Room alarm response procedures.

YES Revision 1 Page 6

Op.ns Restart Action Plan ATTACHMEN

Actions Restart f

Validate and correct safe shutdown procedure. YES

g. Perform simulator and classroom training on procedure revisions.

YES

h. Identify the scope of procedures required for the Auxiliary Alarm Summary, and identify which procedures YES are needed prior to restart.

1.

Develop Auxiliary Alarm Summary Procedures identified as required for restart YES J. Develop Auxiliarv Alarm Summary Procedures identified as not required for restart NO

k. Verify Operator aides are current, necessary, and properly controlled YES Problem Statement 5 Operation's ownership for skills, knowledge, attitude and training of operators needs significant improvement.

Actions Restart 5.1 Establish Operation's ownership of training program.

a. Establish SNSS and NSS as accountable for knowledge, skill and attitude of their crew members.

YES

b. Identify Operation's representative for daily interface with training for resolution of probation related YES findings.

c. Establish a single responsible SRO for each operator in training.

YES

d. Establish crew review of lesson plan quality prior to instruction.

YES

e. Implement Operations Management's feedback for crew simulator performance.

YES f Perform self assessment by line management of training. YES

g. Review qualification cards and ensure appropriate tasks are included and selected for actual performance.

YES

h. Establish peer review board program for final qualification of operators.

YES

i. Establish Training Review Group to oversee training activities.

YES

i. ReviewNEO training program to ensure adequacy of program.

YES

k. Select Training Review Group members to ensure consistent representation of operating crews.

YES

1. "The Industrial Operators Handbook" training completed by each shift YES 5.2 Assess Operator readiness for restart.

a. Conduct Licensed Operator audit exam.

YES

b. Conduct Nuclear Equipment Operator readiness evaluation.

YES

c. Perform management assessment of crew shift management capabilities.

YES Revision 1 Page 7

Performance Management Restart Action Plan Management Sponsors: Human Resources Planning and Development - Manager General Manager - Salem Operations Introduction ATTACHMEN Personnel performance at Salem Station has not been effective in achieving event free operations because management has not held Station personnel accountable for performance_ results. This has resulted in reduced capacity factors due to extended forced and refueling outages and significant NRC enforcement actions. Objective To assure that Salem has the required leadership to achieve the NBU's goals for a top performing nuclear plant by: Having the right people in supervisory positions Developing and communicating clear departmental goals and responsibilities Setting realistic expectations and holding individuals accountable Learning and using new leadership skills and behaviors (i.e. meeting effectiveness, identification and communication of safety issues, conservative decision making, teamwork) Expected Results Upon the completion of the Human Performance Management Restart Plan, the following results are anticipated: A strong, stable, Salem Management Team having clear mission and goals with demonstrated teamwork/ownership, high skills and knowledge, and a self improvement culture. The Salem Management and Supervisor positions are filled with the right people who have demonstrated competencies in Organizational Leadership, Business Focus, Conservative Decision Making and Performance Results. High Standards and expectations are established, communicated, understood and demonstrated by employees who do the right thing the first time and there is an upward trend in the Safety Culture Index Survey. Leaders of all levels throughout the NBU are working together as evidenced in meetings and plant performance. There is increased number of people on Performance Improvement Plans, turnover of employees and new hires. Incident reports due to. human error show a consistent decreasing trend. Revision 1 Page8

Performance Management Restart Action Plan ATTACHMEN Problem Statement 1 Those in supervisory position at Salem (first line to general manager) are ineffective thus failing to achieve performance improvement goals. Action 1.1 Staff and maintain a Salem supervisory team that has the leadership qualities necessary to improve Salem Station performance

a. Add temporary "industry mentors" for key Salem managers

b. Assess key station line management (Tate Assessment)

c. Provide feedback from Tate assessment

d. Salem GM select Management Team

e. Salem Management Team construct development plans based on Tate assessment /BLD/ etc.

f Salem Management Team begins team building

g. Assess those in first line supervisor positions who have previous not been assessed through SAS

h. Salem Management Team uses performances ranking on their direct reports and other supervisory staff

1.

All in supervisor positions construct development plans based on ranking feedback /BLD/etc.

j. RCs and./ or smaller units begin team building sessions

k. Develop "bench strength" within the NBU and Salem by identifying Critical P_ositions, identifying,.

assessing, developing potential successors for CPs as well as high potential females and minorities.

1.

Develop implement a rotation plan for Salem Problem Statement 2 Restart NO YES YES YES YES YES YES YES YES NO NO NO Salem department roles and responsibilities are not clearly defined leading to confused work processes and inconsistent human performance measures. Action Restart 2.1 Identify and communicate Salem's Vision, Mission, Goals, departmental roles and responsibilities and align goals to hold station personnel accountable for results

a. Begin discussion of2.1 (above) at team building YES

b. Finalize discussion of2. l (above), develop and communicate clear, concise departmental goals (vision, YES mission, practices, condu.cts)

Revision 1 Page9

Perlormance Management Restart Action Plan ATTACHMEN Action Restart

c. Check within departments regarding: clarity, understanding of various roles and responsibilities (self assess YES success of r&r definition)

d. Set clear, realistic performance expectation with employees YES

e. Roll out performance feedback review worksheet (for quarterly reviews and soliciting input from others)

YES

f.

Evaluate performance against expectations using quarterly reviews and annual appraisals YES

g. Alignment of results oriented performance standards YES

h. Evaluate quality of annual appraisal on monthly basis using Salem Standards of Quality Appraisals YES

1.

Evaluate quality/quantity of data collected for pre-Performance Improvement Plans to ensure bottom 10%

YES of Salem population is identified

i.

Implement the first Culture Safety Index Survey to identify leading indicators re: performance YES

k. Use data analysis from 2i to redefine and/or validate key areas of focus in human performance YES I.

Department /Station continual self assessments to reinforce a self assessment culture (see Salem Self YES Assessment Restart Action Plan) Problem Statement 3 Those in supervisory positions (first line to general manager) at Salem I NBU (all) do not have or use consistent and effective leadership skills and behaviors. Action Restart 3.1 Develop, implement, support learning experiences for those in supervisory positions to enhance I change their leadership skills and behaviors in order to get the performance results necessarv in the NBU

a. Create "Leadership Qual Card" for those in all supervisory positions (enhancement of TP 900 for all) to NO include required and desired learning experiences for success in the NBU (i.e. BLD, MARC, Dale Carnegie Training, Human Error Reduction)

b. Plan and schedule BLD, MARC, Dale Carnegie before restart with the least amount of impact on station YES resource and align with other training requirements (such as Employee Concerns, Standards of Integrity)

c. Support station attendance (increase participation of Operations, Maintenance), communicate expectation YES of new skills and behaviors learned at BLD, MARC, Dale Carnegie, Human Error Reduction and hold participants accountable for their learning

d. Observe I Coach I Provide feedback to BLD graduates I participants to support application of new skills NO and behaviors; provide evaluation of key BLD skills to both the graduate and his I her supervisor Revision 1 Page 10

Performance Management Restart Action Plan ATTACHMEN Action Restart

e. Self Assessment skills will be imported to those in supervision and employees through doing self YES assessments (see Self Assessment Action Plan), and learning Performance monitoring/trending and Common Cause Analysis (see Corrective Action Plan) f Salem Management to identify short term station training needs to provide tools to use for improved results NO oriented performances

g. Design focused training to meet short term station needs (key areas identifies in 3e. were conflict NO Resolution, Listening, Feedback, Performance Planning and Appraisal Time Management) available to be given to all NBU employees (except PP A), 2-4 hrs, in the work place Problem Statement 4 Inconsistent messages and lack of communications within the NBU (and Salem) adversely impact morale and cause rumors.

Action Restart 4.1 Implement recognition I communication efforts to keep station personnel informed and improve morale

a. Publish results (even small successes), key progress of restart, and other important messages in Weekly YES Update, on bulletin boards throughout station, Nuclear Today

b. Conduct monthly meetings with union representatives YES

c. Conduct meeting for employees on a regular basis to provide input into department I station issues, YES communicate key messages and acknowledge results to date

d. Increase department manager I supervisory file presence to observe, coach, communicate, "catch people YES doing things right" Revision 1 Page 11

En.ring Restart Action Plan ATTACHMEN

Management Sponsors: Manager - Salem Restart Engineering Introduction Engineering performance must be improved to support reliable station operations and maintenance. Engineering management, processes and programs must be more effective and proactive in identifying and resolving long standing equipment problems.

Objective The objective ofthis restart action plan is to improve engineering support to Salem by: Improving engineering organization management, leadership and safety focus Upgrading engineering programs and procedures Improving the quality of engineering activities Identifying and reducing engineering backlogs Implementing and anchoring a continuous improvement process that includes self assessments, performance indicators and other means of identifying needed improvements in engineering products and services Expected Results Upon the completion of the Engineering Restart Action Plan, the following results are anticipated: The engineering organization will be restructured and staffed to provide more effective and proactive support to Salem Operations and Maintenance. The work processes will be improved and the engineering backlog reduced and maintained within the established goals. Critical engineering programs and processes will be upgraded to provide more effective Operations and Maintenance support with improved baseline, tracking and trending information. The Engineering interface with station organizations will be improved. Engineering involvement fully integrated with day-to-day Operations and Maintenance Quality and timeliness of engineering products and services to support safe and controlled station operations. Revision 1 Page 12

En.ring Restart Action Plan The engineering organization will be utilizing a continuous improvement process to: Improve engineering quality Perform root cause analysis as a normal part of engineering Self assess performance Verify improvements Use performance indicators to continuously assess performance ATTACHMEN. Validate that the actions to upgrade the engineering organization, programs, processes and safety culture are effective and anchored in the engineering organization. Problem Statement 1 Performance expectations, roles and responsibilities are not clearly defined or understood by the engineering staff and interfacing organizations. Actions Restart 1.1 Establish goals of the engineering organizations. YES 1.2 Define and communicate expectations, roles and responsibilities for Nuclear Engineering Design.

a.

Establish organizational goals. YES

b.

Establish and communicate expectations, roles and responsibilities. YES C. Provide documented evidence that the engineers understand their roles, responsibilities and YES accountabilities.

d.

Evaluate effectiveness of communication of the department roles and responsibilities internally and YES externally through documented self assessments.

e.

Monitor that performance expectations are met by soliciting customer feedback, personnel appraisals, YES performance indicator's, and organizational assessments by third party. 1.3 Define and communicate expectations, roles and responsibilities for System Engineering.

a.

Establish organizational goals. YES

b.

Establish and communicate expectations, roles and responsibilities. YES

c.

Provide documented evidence that the engineers understand their roles, responsibilities and YES accountabilities.

d.

Evaluate effectiveness of communication of the department roles and responsibilities internally and YES externally through documented self assessments.

e.

Monitor that performance expectations are met by conducting customer survey, personnel appraisals, YES performance indicator's trends, and organizational assessments by third party. Revision 1 Page 13

En.ring Restart Action Plan ATTACHMEN

Actions Restart 1.4 Define and communicate expectations, roles and responsibilities for Plant Engineering and Projects.

a.

Establish organizational goals. YES

b.

Establish and communicate expectations, roles and responsibilities. YES

c.

Provide documented evidence that the engineers understand their roles, responsibilities and YES accountabilities.

d.

Evaluate effectiveness of communication of the department roles* and responsibilities internally and YES externally through documented self assessments.

e.

Monitor that performance expectations are met, by conducting customer survey, personnel appraisals, YES performance indicator's trends, and organizational assessments by third party. 1.5 Define and communicate expectations, roles and responsibilities for Nuclear Fuel Group.

a.

Establish organizational goals. YES

b.

Establish and communicate expectations, roles and responsibilities. YES

c.

Provide documented evidence that the engineers understand their roles, responsibilities and YES accountabilities.

d.

Evaluate effectiveness of communication of the department roles and responsibilities internally and YES externally through documented self assessments.

e.

Monitor that performance expectations are met by conducting customer survey, personnel appraisals, YES performance indicator's trends, and organizational assessments by third party. Problem Statement 2 Engineering is not proactively identifying, determining root causes or solving technical issues in a timely manner. Actions Restart 2.1 Improve root cause analysis procedure. (see Salem Corrective Action Restart Action Plan) YES 2.2 Establish a Root Cause Analysis (RCA) group. YES 2.3 Train root cause analysis group in RCA techniques and methodology. YES 2.4 Nuclear Engineering Design issues identification, analysis and solutions implementation.

a.

Conduct system configuration control walkdowns and initiate resolution of identified issues. YES

b.

Strengthen Engineering Assurance Group staffing levels. YES

c.

Establish and implement a process for identification of emergent technical issues and incipient equipment YES failures. Revision 1 Page 14

En-~ng Restart Action Plan ATTACHMEN
Actions Restart

d.

Perform self assessment of implementation of technical issues solutions. YES

e.

Perform independent third party verification of technical issues identification, analysis and solutions. YES f Train a significant percentage of engineering staff in the basic root cause analysis philosophy and YES techniques. 2.5 Plant engineering technical issues identification, analysis and solutions implementation.

a.

Prioritize and schedule DCPs required for Restart. YES

b.

Develop and implement an action plan to assure the quality ofDCPs. YES

c.

Prepare management tools to proactively manage Design Change Package (DCP) production and quality. YES

d.

Perform self assessment of implementation of technical issues solutions. YES

e.

Perform independent third party verification of progress in technical issues solution. YES f Train a significant percentage of engineering staff in the basic root cause philosophy and techniques. YES 2.6 Salem System Engineering issues identification, analysis and solutions implementation.

a.

Establish an interim operability assessment group and supplement operability assessments. YES

b.

Assemble system readiness review teams and conduct system walkdown. YES C. Identify issues, analyze and implement solutions. YES

d.

Perform self assessment of implementation of technical issues solutions. YES

e.

Perform independent third party verification of progress in technical issues solution. YES f Train a significant percentage of engineering staff in the basic root cause philosophy and techniques. YES 2.7 Nuclear Fuel issues identification, analysis and solutions implementation.

a.

Identify issues, analyze and initiate implementation of solutions. YES

b.

Perform self assessment of implementation of technical issues solutions. YES

c.

Perform independent third party verification of progress in technical issues solution. YES

d.

Train a significant percentage of engineering staff in the basic root cause philosophy and techniques. YES Revision 1 Page 15

En.ring Restart Action Plan ATTACHMEN. Problem Statement 3 Several engineering programs and procedures do not meet some regulatory requirements and/or are not effective. Engineering backlogs are not maintained at acceptable levels. Actions Restart 3.1 Characterize engineering backlog and initiate restart backlog reduction. YES 3.2 Perform baseline Self Assessment of selected Engineering programs, processes and procedures and identify YES corrective actions required. 3.3 Develop and implement new engineering programs, processes, procedures and/or upgrade as required. (check YES valves, MOY [89-10], IST, Maintenance Rule, etc.) 3.4 Complete restart backlog reduction effort. YES 3.5 Communicate new and ungraded programs and/or procedures to Epruneering/Operations/Maintenance. YES 3.6 Perform organizational (Department Level) Restart Readiness Assessments. YES 3.7 Perform third party validation of selected engineering programs effectiveness and of corrective actions. YES 3.8 Implement corrective actions identified in self assessments and/or validations. YES Problem Statement 4 The engineering staff is not adequately trained to assure high quality of work. Engineering staff qualification requirements are not clearly established or maintained. Actions Restart 4.1 YES 4.2 YES 4.3 Qualit Surve. YES 4.4 YES 4.5 YES 4.6 YES 4.7 ort Personnel* YES 4.8 NO 4.9 NO Note: Revision 1 Page 16

En.ring Restart Action Plan ATTACHMEN. Problem Statement 5 The engineering organization safety culture needs to be improved and anchored in the organization. Engineering management has not provided the leadership to implement a continuous engineering improvement and effective self assessment process. Actions Restart 5.1 Improve management leadership.

a.

Perform assessment, develop organizational strategy. YES

b.

Implement organizational changes. (Directors, Managers and Supervisory Level) YES 5.2 Implement an organizational structure to support safety culture.

a.

Reorganize engineering and better define work scope and division oflabor i.e. system manager, YES component specialties technical programs, root cause analysis group, etc.

b.

Establish and implement training program to sensitize engineering to: YES (1) Safety concern focus (2) Root cause analysis application (3) Error free design and installation

c.

Implement elements of the Salem Human Performance Management Restart Action Plan to anchor safety YES and excellence culture in engineering organization.

d.

Shift reactive engineering work load to an interim engineering group to allow system managers to ensure YES system readiness.

e.

Train personnel in Action Request procedure NAP-06 to allow for ease in identifying problems and YES tracking the corrective actions. 5.3 Improve proactive engineering.

a.

Upgrade system managers capability to support proactive engineering. YES

b.

Implement system walkdowns and system problem database to capture past, current and future problems YES (SIDS). (see System Engineering and Equipment Reliability Action Plan) 5.4 Implement continuous Engineering Improvement..

a.

Implement restart performance indicators to measure status and effectiveness of engineering corrective YES actions.

b.

Evaluate 1995 INPO Assessment of Hope Creek, identify areas for improvement at Salem, and develop YES plan to address them.

c.

Assess whether engineering products and services meet requirements/expectations. YES

d.

Develop and implement a continuous engineering improvement program. NO

e.

Develop post restart performance indicators. NO Revision 1 Page 17

En.ring Restart Action Plan ATTACHMEN. Actions Restart 5.5 Benchmark Engineering Performance to raise standard of performance

a.

Benchmark engineering staff, organization, functions against industry and develop recommendations plan NO for solutions.

b.

Review programs, processes of highly successful industry counterparts and develop a plan to incorporate NO the best practices.

c.

Implement changes required to bring station within industry norms. NO 5.6 Perform self assessment to lower thresholds for failure rate.

a.

Performs self assessments of engineering organization, management, leadership and safety culture. NO

b.

Utilize results of self assessments to gauge performance of engineering against established levels of NO performance.

c.

Adjust acceptable failure rate as required. NO 5.7 Balance Engineering Work Loads.

a.

Distribute work load to allow for proactive engineering. NO

b.

Assess organization changes and staffing to determine if work loads are properly distributed. NO

c.

Adjust organization and engineering staff work load based on assessment results. NO Revision 1 Page 18

M.nance Restart Action Plan ATTACHMEN. Management Sponsor: Manager - Salem Maintenance Introduction Salem maintenance has not been effective in achieving reliable equipment performance and materiel condition attributes of the station. Degraded performance in this area is resultant from weaknesses in other maintenance areas such as corrective action programs, management oversight and controls, work management system and the preventive maintenance program. These weaknesses have been developed into six problem statements within this action plan. These weaknesses were identified through a comprehensive review of plant documentation and reports including: NRC SALP Reports (1989 - 1994), NRC Special Investigation Team Report, INPO Evaluation Findings (1983 - 1995), INPO Assist Report (1995), QA Maintenance Audit Report (1995), Regulatory Issue Matrix, Comprehensive Self-Evaluation of Maintenance Training Report (1995) and other internal problem reports. The NRC and INPO documents provided the basis for the review, with the INPO Performance Objectives providing a :framework to categorize problem areas. Recurrent themes or problems became evident in several areas. These themes were compared to the context of the other documentation to ensure all major problem areas were identified. This examination revealed six major themes, that if addressed, would yield desired improvements in the execution of maintenance at the station. The Maintenance leadership team reviewed on-going corrective actions in current action plans to determine whether those actions would be sufficient to resolve the problems and preclude their recurrence. The leadership team then determined what additional actions would b~ required to resolve the problems noted. Corrective actions were developed and validated against the problem statements. The actions found herein are the result of several iterations of"what if' analysis and validation of corrective actions against the problem statements. Objective The objective of this action plan is to identify, correct and assess those deficiencies in maintenance to improve equipment reliability and materiel condition at the station. Expected Results Upon the completion of the Maintenance Restart Action Plan, the following results are anticipated: The conduct of maintenance effectively supports reliable equipment performance, improved materiel condition and safe event-

free operations.

Revision 1 Page 19

M.nance Restart Action Plan ATTACHMEN. Maintenance self-assessment and corrective action initiatives, and management oversight and follow-through effectively supports the continual improvement culture of the station. Maintenance department ownership of the training program results in a highly qualified work force to promote safe and reliable operations. Problem Statement 1 Maintenance corrective actions and management follow-through have been less than sufficient to identify problems, to determine root causes of equipment and personnel deficiencies, to implement appropriate corrective actions, and to assess and monitor these actions for effectiveness. Actions Restart 1.1 Establish and communicate standards and expectations for equipment and personnel performance.

a. Review and incorporate INPO Performance Objectives and Criteria YES

b. Perform benchmarking against industry leaders YES

c. Solicit employee input for standards and expectations YES

d. Continue assessment and upgrading of standards and expectations.

YES 1.2 Establish accountability for behavior changes within the Maintenance process.

a. Reinforce questioning attitudes among employees YES

b. Establish performance indicators YES

c. Routine self-assessment and follow-through per station guidance YES

d. Continue reinforcement of standards and expectations YES 1.3 Improve in-depth evaluation and analysis of identified problems and develop corrective actions

a. Perform root cause analysis in accordance with NAP-6 YES

b. Review problems for generic impact YES

c. Establish a performance review process to review and evaluate human performance issues YES

d. Establish department review committee for review of Maintenance corrective action process YES 1.4 Establish expectations for implementation of effective corrective actions

a. Plan and implement corrective actions per schedule YES

b. Develop actions to preclude recurrence (i.e. training, lessons learned, coaching/counseling, YES procedure/process changes),

Revision 1 Page 20

M.nance Restart Action Plan ATTACHMEN. Actions Restart

c. Develop measures for follow-through assessment of corrective actions YES

d. Develop and monitor performance indicators for ensuring effectiveness of corrective actions YES 1.5 Establish objectives for continuing Maintenance self-assessment in accordance with station assessment programs

a. Utilize department review committee YES

b. Develop, monitor and trend performance indicators YES

c. Reinforcement of standards and expectations YES Problem Statement 2 The work management system and processes have been less than sufficient to effectively identify, prioritize, schedule, plan, execute, return to service, and close-out equipment deficiencies.

Actions Restart 2.1 Implement new work management program. YES 2.2

a. Provide initial training to Maintenance personnel on the roles, responsibilities and accountabilities as defined YES in the "new" work management process.

b. Follow-through with feedback and additional training during implementation phase as necessary. Validate YES that this training is consistent with the other work management system partners.

2.3 Develop and implement team building sessions for the partners in the work management system (i.e. YES Operations, Maintenance, Work Control, Engineering) to strengthen department relationships. 2.4 Review and revise the rework/repetitive maintenance program to identify and monitor rework and repetitive YES problems. Use NAP-6 process to evaluate and correct noted problems. 2.5 Establish standards and expectations for the conduct ofmaintenance and establish accountability for adherence YES to those standards and expectations. 2.6 Reorganize the Maintenance department to establish clear lines of autho_rity and accountability to assist with the YES development of Maintenance personnel and communication internal and external to the department. 2.7 Review the implementation of the WIN Team and develop a plan to enhance this application of resources. YES 2.8 Establish objectives for continuing Maintenance self-assessment in accordance with station assessment programs

a. Utilize department review committee YES

b. Develop, monitor and trend performance indicators YES

c. Reinforcement of standards and expectations YES Revision 1 Page 21

M.nance Restart Action Plan ATTACHMEN

Problem Statement 3 Maintenance management has been less than sufficient in establishing and enforcing standards and expectations for the conduct of maintenance and in developing and adhering to maintenance programs.

Actions Restart 3.1 Establish standards and expectations for the conduct of maintenance and establish accountability for adherence YES to those standards and expectations. 3.2 Reorganize the Maintenance department to establish clear lines of authority and accountability to assist with the YES development of Maintenance personnel and communication internal and external to the department. 3.3 Benchmark Maintenance organization and programs against industry leaders. Revise organization and YES programs as required based on performance monitoring, benchmarking and continuous Maintenance self-assessment. 3.4 Evaluate current supervisory and management training and professional development programs to ensure NO personnel are prepared to perform their functions. Problem Statement 4 The preventive maintenance (PM) program has not been completely effective in ensuring appropriate scope definition and completion of PM activities to support reliable plant operation. Actions Restart 4.1 Establish ownership and overall responsibility of PM program in Maintenance. YES 4.2 Revise program and procedures to clearly define roles and responsibilities. Train personnel on roles and YES responsibilities of revised PM program 4.3 Evaluate results of Engineering PM program self-assessment YES

a. Develop and implement corrective actions to address programmatic weaknesses YES

b. Develop performance indicators YES

c. Monitor and assess effectiveness of corrective actions YES 4.4 Identify plant components not evaluated for inclusion or exclusion from the PM program. Prioritize analysis YES review of these components to support restart.

4.5 Evaluate PM program status and define required PMs in conjunction with system readiness reviews to support YES safe reliable operation post-restart. Revision 1 Page 22

M.nance Restart Action Plan ATTACHMEN. Problem Statement 5 Maintenance management has not been effective in oversight of non-station personnel performing maintenance on plant equipment. Actions Restart 5.1 Review and revise (as appropriate) Maintenance department program and procedures for control of contractors YES and non-station personnel.

5.2 Establish point-of-accountability to ensure non-station personnel are qualified to perform maintenance tasks on YES Salem plant equipment.

5.3 Establish accountable Maintenance oversight and coverage of non-station personnel performing maintenance YES activities. 5.4 Review contractual terms and conditions and develop improvements in work methods to optimize flexibility and NO productivity. 5.5 Establish objectives for continuing Maintenance self-assessment in accordance with station assessment programs

a. Utilize department review committee YES

b. Develop, monitor and trend performance indicators YES

c. Follow-through reinforcement of standards and expectations YES Problem Statement 6 Maintenance management ownership of the Maintenance Training Program has been less than sufficient to ensure communication of clear expectations for the conduct of training and qualification activities, and job performance standards.

Actions Restart 6.1 Review and evaluate reports for areas of weakness. YES 6.2 Establish standards and expectations for the conduct of maintenance training and establish accountability for YES adherence to those standards and expectations, Reinforce use of continuing training as a forum for these standards and expectations. 6.3 Develop and implement corrective actions YES Revision 1 Page 23

M.nance Restart Action Plan ATTACHMEN. Actions Restart 6.4 Establish objectives for continuing Maintenance self-assessment in accordance with station assessment programs

a. Utilize department review committee YES

b. Develop, monitor and trend performance indicators YES C. Reinforce standards and expectations YES Other Issues The following action items are considered important to resolve and monitor through the Restart Process.

Actions Restart 7.1 Perform the following assessments:

a. Maintenance department self-assessment, YES

b. Maintenance Rule Effectiveness Assessment.

Develop Assessment Plan NO Perform Assessment NO 7.2 Address and support completion of system walkdown identified Restart items YES 7.3 Reduce and monitor backlogs of the following

a. PRs andDRs YES

b. ATS items YES

c. Corrective actions YES

d. Control room indicators out-of-service YES

e. Maintenance department procedure backlog YES 7.4 Develop and implement plan to address ICD card issue.

NO 7.5 Evaluate existing operator work-arounds to determine required maintenance actions. Ensure a method is in YES place to regularly assess the maintenance implications of operator work-arounds. 7.6 Review engineering plans for program development and implementation (i.e. AOV, MOV, predictive NO maintenance) and establish interface and responsibilities 7.7 Establish objectives for continuing Maintenance self-assessment in accordance with station procedures

a. Utilize department review committee YES

b. Develop, monitor and trend performance indicators YES

c. Follow-through reinforcement of standards and expectations YES Revision 1 Page 24

Wo.ontrol Restart Action Plan

ATTACHMEN
Management Sponsor: Station Planning Manager Introduction Emergent work, work package content, and process inefficiencies have limited work control effectiveness.

Objectives Develop and implement an improved Work Control Program which effectively supports operations and reliable maintenance. Identify and eliminate work control process backlogs. Identify and correct work control interface areas inhibiting effective schedule implementation and productivity. Identify weaknesses and upgrade the utility of work control support systems. Improve process performance indicators for monitoring routine functions, backlogs, and process effectiveness. Utilize an effective self-assessment process as an input for sustaining and enhancing the Work Control Program. Expected Results Upon the completion of the Work Control Restart Action Plan, the following results are anticipated: A functioning work control prqgram in place which establishes ownership, responsibility and accountability for all process functions, and emphasizes the strong role of the Operations Department in driving the process. The program should implement a Minor Maintenance process which provides an effective and controlled method of promptly accomplishing minor work outside the normal planning and scheduling process. Work control process backlogs eliminated and process flows monitored and controlled to preclude accumulation of future backlogs. The corrective maintenance backlog validated, prioritized, updated to reflect Operations, Engineering, Maintenance and MRC screening for restart, and scheduled. Work Control program interfaces between Planning and Scheduling, Maintenance, Operations, Engineering, Procurement and Material Management, Radiation Protection, and other groups controlled and functioning to support efficient schedule implementation. Work Control process functions and management controls enhanced by effective support systems including the Management Maintenance Information System (MMIS) and scheduling hardware and software support. A set of hierarchical Performance Indicators in place to monitor Work Control process functions and information flows providing for timely identification of functions needing management attention or process enhancement. An effective process control function in place which includes periodic self-assessments of the Work Management Program and the Planning and Scheduling Department as inputs for identifying and implementing process enhancements. Revision 1 Page 25

Wo.ontrol Restart Action Plan ATTACHMEN. Problem Statement 1 The existing work control process requires better definition, structure and discipline. Delays in equipment repair and return to service result from a lack of schedule adherence and work control process deficiencies such as insufficient work planning, inappropriate scheduling.and coordination, and ineffective problem identification and resolution. Lack of schedule adherence has been attributed, in part, to poor quality work packages. A large percentage (in the 30% range) of work packages received by Maintenance are either correctedin the field or returned to Planning. Work packages are not issued to first line supervisors with adequate lead time to ensure planning is correct and packages are ready to work as scheduled. Package changes suggested by craft and supervisors are not effectively incorporated into future work packages. Action Restart 1.1 Establish ownership, responsibility and accountability for the Work Control Program. YES 1.2 Develop a Work Control Process Model identifving functional area interfaces. YES 1.3 Establish organizational requirements to support the Work Control Program. YES

a. Approve and issue Work Control Program Manual and revision to NA-AP-09.

YES

b. Complete training on the Work Control Program Manual.

YES 1.4 Redefine functions of reporting, screening and validating corrective maintenance. YES 1.5 Establish an effective Minor Maintenance Program. YES

a. Complete training of Maintenance, Operations, and Operations Support Department personnel.

YES 1.6 Revise the process for reporting and resolving work-in-progress problems. YES

a. Complete training on the revised work-in-progress problem reporting process.

YES 1.7 Establish a process for planning and scheduling on-line LCO maintenance. YES

a. Complete training on on-line LCO maintenance pla.Ilning and scheduling process.

YES 1.8 Redefine the integrated scheduling process and implement the Work Week Manager concept. YES

a. Develop materials and complete training to implement Work Week Manager concept.

YES 1.9 Upgrade the planning and work package development process to improve work package quality. YES

a. Complete training and fully implement "task ready" planning.

YES

b. Incorporate an effective work package feedback process from the Implementor to Planning.

YES 1.10 Establish a controlled process for work package, review, approval and release. YES

a. Complete training and fully implement the work package approval and release process.

YES Revision 1 Page 26

Wo.ontrol Restart Action Plan ATTACHMEN

Action Restart 1.11 Establish a controlled process for work package completion, retest, review and closure.

YES

a. Draft and obtain working level concurrence of an improved work completion and closure process.

YES

b. Incorporate the revised completion and closure process in the Work ControlProcess Manual. (Rev 01)

YES

c. Complete training and fully implement the work package completion and closure process.

YES

d. Implement lead shop concept which will reduce qty of work activity pkgs. and improve retest process.

YES 1.12 Develop an improved POD which promotes understanding of plant conditions and work-in-progress. YES

a. Obtain sample POD's from other plants with two PWR units.

NO

b. Develop "user friendly" formats for displaying current Work Week schedule and other information.

YES

c. Identify sources and assign responsibility and timing for input of POD information to Scheduling.

YES

d. Accomplish programming required to produce the POD and present information in the desired format.

YES

e. Develop materials and train managers and supervisors utilizing the POD in the revised process.

YES f Implement the improved Plan of the Day. YES Problem Statement 2 Low staffing levels and process inefficiencies have contributed to an accumulation of.functional area backlogs which contribute to material and performance deficiencies. The existing backlogs will be eliminated or reduced to levels which permits the application of available resources to the resolution of real time conditions. The material deficiency identification and resolution function has receded from real time. A backlog of corrective maintenance exists which is not clearly defined, evaluated, planned and scheduled. It includes a large number of minor and questionable deficiencies which inhibit effective review and identification of important equipment problems. Recurring equipment performance and material deficiencies exist, some of which have caused or complicated plant transients. The backlog includes Work Orders on hold for parts and Engineering. Operations does not have an integrated process to prioritize technical issues, plant modifications, and corrective maintenance. Action Restart 2.1 Review process data and support activities and identify process backlogs. YES 2.2 Validate the backlog of about 6,500 Corrective Maintenance AR/WO's. YES 2.3 Reduce the backlog of 6,500 Completed Work Orders not entered into history to normal throughput. NO 2.4 Eliminate the backlog of300 unplanned mechanical work packages for 1Rl2. YES 2.5 Eliminate the backlog of 2,400 pending Preventive Maintenance changes (upgrades). NO Revision 1 Page 27

Wo.ontrol Restart Action Plan ATTACHMEN. Action Restart

a. Reduce the backlog bv 75% to 600 changes.

NO

b. Maintain the backlog of changes less than one month old NO 2.6 Eliminate the backlog of 12,000 planned PM's in need ofuograding.

NO

a. Identify and assign resources to review low frequency PM's perform necessary upgrade action.

NO

b. Complete upgrade of low frequency PM's.

NO C. Establish requirement for Planners to upgrade high frequency PM's before T-4 schedule date. NO

d. Implement method to code ungraded PM's so that the upgrading review is performed only once.

NO 2.7 Initiate action with the responsible organizations and eliminate backlogs of Work Orders on hold. YES

a. Implement process to monitor Planner performance in meeting early ordering oolicv.

YES

b. Clarify organizational responsibilities for identifying and resolving restrained Work Orders.

YES

c. Review restrained WO's, identify issues and reschedule and/or resolve WO's on hold for parts.

YES

d. Evaluate interface between the schedule and completion of Engineering work to support schedule.

YES

e. Identify Engineering schedule support issues and initiate action to reschedule and/or resolve issues.

YES f Evaluate WO's on administrative hold, identify causes, and determine need for corrective action. YES

g. Initiate action with the responsible organization to resolve administrative hold issues.

YES

h. Establish process to monitor rescheduling actions and to identify the reasons for reschedules.

YES

1.

Establish goals for each major reschedule reason and maintain reschedules within these goals. YES Problem Statement 3 Organizational functions interfacing with and supporting the Work Control Process need improvement. Support of the Work Control Center is often insufficient to support the work control process. Changes to the station's configuration have been made without changes in design documents or requirements. Problems exist with implementation of the station tagging program, some of which have contributed to station events. There has been inadequate focus or enforcement of the schedule by support organizations. Engineering has not resolved a number of equipment problems, some of which are long standing. Work is delayed, rescheduled or postponed due to non-availability of parts. Action Restart 3.1 Assist Operations in upgrading the tagging process to more effectively support the work schedule. YES

a. Assist in reviewing tagging process and interface with schedule and work package structure.

YES

b. Review proposed changes to the tagging process to ensure work control issues are resolved.

YES Revision 1 Page 28

Wo.ontrol Restart Action Plan ATTACHMEN

Action Restart 3.2 Coordinate action with Operations to upgrade facilities and consolidate Operations WC functions.

NO

a. Determine optimum staffing of a Work Control Center which consolidates Operations WC functions.

NO

b. Identify space near the Control Rooms which could accommodate the upgraded WCC.

NO

c. Identify space for relocating incumbents in the identified space and develop a relocation plan.

NO

d. Complete relocation of personnel and preparation of new Work Control Center.

NO e.. Realign organizational responsibilities and establish new Work Control Center. NO f Revise procedures and desk guides to reflect new Work Control Center. NO 3.3 Coordinate action with Maintenance to expand the use of Composite Teams. NO

a. Establish a process for identifying Composite Team work before work is planned.

NO

b. Identifv and implement requirements for planning work packages for Composite Teams.

NO 3.4 Coordinate action with Engineering to improve the process of replacing obsolete plant components. NO 3.5 Coordinate action with Procurement to eliminate material holds due to low stock levels. NO

a. Establish process to identify if parts causing reschedules are non-stock or inventorv items.

NO

b. Determine and correct causes of stocking levels being too low to support scheduled requirements.

NO

c. Identify number of Priority 1 Work Orders (PM's and ST's) rescheduled due to parts restraints.

NO Problem Statement 4 The Managed Maintenance Information System (MMIS) needs to be enhanced to support a comprehensive work control process. Action Restart 4.1 Implement priority MMIS software enhancements needed to support process functional changes. YES 4.2 Implement MMIS software enhancements needed to support process and performance indicators. YES

a. Identify changes needed for SRO and shop approvals of work packages.

YES

b. Develop and test Phase II program changes.

YES

c. Prepare materials and train Ops, Maintenance and Planning personnel in use of new MMIS fields.

YES

d. Implement Phase II program changes.

YES

e. Revise Work Control Program Manual and Desk Guides affected by the changes.

YES 4.3 Implement long term enhancements to MMIS to improve user interface and simolifv WC functions. NO

a. Develop proposed reformatting of AR/WO screens to put high usage (common) data on Screen 1.

NO

b. Identify complete set of data fields needed to support all Work Control process functions.

NO Revision 1 Page 29

Wo.ontrol Restart Action Pl~ ATTACHMEN

Action Restart C. Identify new data fields needed to support performance indicators and to manage backlogs.

NO

d. Review proposed* changes with Methods and Systems and develop implementation schedule.

NO

e. Develop and test Phase III program changes.

NO f Prepare materials and train station personnel in use of new MMIS screens and data fields. NO

g. Revise Work Control Program Manual and Desk Guides affected by the changes.

NO

h. Implement Phase III MMIS changes.

NO

1.

Evaluate proposed Phase III changes for cost effectiveness based on plans to upgrade system. NO Problem Statement 5 The performance indicators used to monitor and track work control process functions do not provide sufficient visibility of process weaknesses. Action Restart 5.1 Establish a set of performance indicators to track backlog reduction to meet plan dates. YES 5.2 Establish a set of performance indicators to track current status of Unit 1 Refueling Outage planning. YES 5.3 Establish a set of performance indicators to track current status ofUnit 2 Forced Outage planning. YES 5.4 Establish a set of performance indicators to track schedule stability and adherence. (On-Line Schedule) YES 5.5 Establish a set of performance indicators to track the routine flow of work through the process. YES Problem Statement 6 A systematic, structured Self-Assessment process is needed as part of the Work Management Program process control function. Action Restart 6.1 Incorporate requirements for periodic self-assessment of the Work Management Program into a Desk Guide for NO the Work Management Program Advisory Committee. 6.2 Conduct a self-assessment of the Work Management Program after implementation and prior to startup. YES 6.3 Conduct a self-assessment of the Planning Department prior to startup. YES 6.4 Incorporate appropriate actions resulting from the self-assessments into short term and long term action plans. YES Revision 1 Page 30

Sel.essment Restart Action Plan

ATTACHMEN
Management Sponsor: Manager - Salem Projects Introduction Salem has not been effective in establishing self assessment as part of normal business practice and culture. When self assessments have been performed, they have not been consistently effective in identifying problems, processes or programs that need to be improved.

This is measured by the number of weaknesses found by outside groups and by plant performance. Objective The objective of this action plan is to develop the capability and acceptance of the Salem organization such that self assessment is used effectively and routinely to improve performance continually. Expected Results Upon the completion of the Self-Assessment Restart Action Plan, the following results are anticipated: A new culture is established at Salem whereby 'self assessment' is an automatic and explicit step of every action by each employee. Procedures are established to improve the usage and effectiveness of self assessments at Salem. They address day-to-day management and the peer observation program, organizational self assessments to support restart and annual self assessment plans for all Salem departments. The Salem Station has comprehensive organizational self assessments that document its major performance weaknesses and the completed actions that address these weaknesses. The assessment documents will support the goals of a safe startup and reliable power operation. The trends in Level 1 and 2 Condition Reports demonstrate an increased percentage of self identified issues and an increase in issues being identified due to raising standards and expectations. Revision 2 Page 31

Sel.essment Restart Action Plan ATTACHMEN

Problem Statement 1 The existing self assessment program is limited in scope and the results do not accurately identify the root causes of Salem performance weaknesses.

Actions Restart 1.1 Revise Self Assessment Program for Salem Station

a.

Develop Self Assessment Procedure for routine operations (Present to Station Operations Review YES Committee)

b.

Develop Self Assessment procedure for restart following outages (Present to SORC) YES

c.

Identify departmental assessors and conduct training YES

d.

Conduct Self Assessment Program training YES

e.

Communicate self assessment expectations to all hands YES f Implement Procedures YES 1.2 Establish a Salem Station Self Assessment Coordinator

a.

Develop job scope for the self assessment coordinator YES

b.

Staff the position with temporary support to establish program YES

c.

Select a permanent individual for the position YES Problem Statement 2 Gep.erally~ the Salem work force at all levels rarely perform Self Assessments. When Self Assessments are performed, they are done so mcons1stently. Actions Restart 2.1 Implement Departmental Self Assessments Program

a.

Develop departmental assessment scope and objectives (Planning, Maint, Rad Pro, & Chemistry) YES

b.

Develop departmental assessment scope and objectives (Ops). YES

c.

Conduct Initial Departmental Self Assessment (Planning, Maint, Rad Pro, & Chemistry) YES

d.

Conduct Initial Departmental Self Assessment (Ops) YES

e.

Present initial self assessment results to MRC (Planning, Maint, RadPro, & Chemistry) YES f Present initial self assessment results to MRC (Ops) YES

g.

Present status of self assessment identified actions to MRC YES

h.

Present*status of self assessment identified actions to MRC YES Revision 2 Page 32

Sel.essment Restart Action Plan ATTACHMEN. Actions

Restart

1.

Incorporate lessons learned into Self Assessment procedure YES J. Develop final departmental self assessment plans for restart YES

k.

Perform final departmental restart self assessment YES

1.

Present self assessment results to :MRC YES

m.

Correct restart concerns identified in self assessments YES 2.2 Implement Management and Peer Observer Program

a. Identify and schedule manager observations YES

b. Identify and schedule peer observations YES

c. Schedule observation training for designated observers YES

d. Commence implementation of management observations YES_

e. Commence implementation of peer observation YES

f.

Present initial management observation results to :MRC YES

g. Present initial Peer Observation results to :MRC YES

h. Incorporate lessons learned into self assessment procedure YES Revision 2 Page 33

Co.ive Action Restart Action Plan ATTACHMEN

Management Sponsor: Manager - Corrective Action & Quality Services Introduction The Corrective Action Program (CAP) Implementation has been ineffective in providing lasting problem resolution and precluding recurrence of similar or related problems. Specific problems include lack of timeliness, no program manager, lack of performance indicators, lack of or poor operability determinations, multiple processes, corrective actions not tracked to completion, threshold for entry is too high, inadequate use of trend data, poor quality of root cause analysis, inconsistent SNSS/NSS involvement in processes, lack of ownership and inadequate management oversight.

THE CORRECTIVE ACTION PROGRAM IS COMMON TO SALEM AND HOPE CREEK STATIONS. IMPROVEMENTS. DESCRIBED IN THE SALEM RESTART PLAN ARE BEING IMPLEMENTED THROUGHOUT THE NUCLEAR BUSINESS UNIT. Objectives Establish a consolidated corrective action program with low threshold for entry. Establish organizational point of accountability for CAP oversight, with strong line management support. Stabilize total number of corrective action documents. Sustained performance of timely evaluations and corrective action implementation. Sustained performance of.high quality 'apparent cause' and 'root cause' evaluations and selection of corrective actions. Establish effective trending program. Improve organizational performance. Expected Results Upon the completion of the Corrective Action Restart Plan, the following results are anticipated: Process Performance Conditions Adverse to Quality (CAQ) entered into CAP, as appropriate. Evaluations consistently completed in prescribed time. Timely completion of corrective actions with minimal extensions and overdue items. Manageable number of CAP documents. Revision 1 Page 34

Co.ive Action Restart Action Plan ATTACHMEN. Acceptable quality of Apparent Cause and Root Cause Evaluations. Selection of effective Corrective Actions. Timely identification and reversal of negative trends. Timely dissemination oflessons learned to PSE&G & the industry. Organizational Performance Reduction in repeat events Reduction in LERs Elimination of significant events Reduction in Personnel Error Rate Aggressive reversal of negative trends CAQs are self-identified before becoming self-evident (events, failed components, etc.) or identified by others Problem Statement 1 Various elements of the Corrective Action Program are distributed among several separate processes. The individual processes lacked important controls. Actions Restart 1.1 Initial process consolidation/improvement

a. Lower the threshold for entry into CAP, implement improved Operability Determination controls, and YES consolidate IR, QA AR, and DEF processes. Issue Revision to NAP-6.

[Rev 9, 7/2/95]

b. Make SERT the single root cause analysis/corrective action activity when convened YES 1.2 Improve understanding and implementation of CAP *

a. Develop guidelines for CA Group implementation of NAP-6 YES

b. Conduct training on MMIS system and data input requirements YES 1.3 Incorporate Deficiency Report process into CAP (NAP-6) [deleted, see item 1.4]

1.4 Further consolidation/improvement of CAP and CAP procedures. (Note - Phased to allow for Hope Creek refueling outage) NOTE: THIS ITEM REQUIRES INTERFACE WITH OTHER EFFORTS TO CONSOLIDATE WORK MANAGEMENT SYSTEMS

a. Identify Salem, Hope Creek, Nuc. Engr., & Meth/Sys team members each to work with CA Group YES developing and implementing changes Revision 1 Page 35

Co.ive Action Restart Action Plan ATTACHMEN. Actions Restart

b. Perform a self-assessment of CAP implementation. Evaluate and identify changes to be made, including:

YES Incorporate SERT into NAP-6 and NBP-2 (delete NAP-61) Incorporate other problem reporting systems into NAP-6 (Ml\\1IS discrepancies, TRIS changes, EWRs, MCRs,... ) Evaluate/clarify significance level guidelines. -

Revise NAP-6 to be more "user friendly". Develop lower tiered procedures or guidelines as appropriate.

Strengthen operability determination interface

c. Draft NAP-6 revision and other procedures distributed to appropriate managers for review YES

d. Comments due YES

e. Present NAP-6 Rev. and other procedures (ifreqd) to SORC YES f

Modify MMIS as required to support changes. (Avail for training) YES g, Communicate changes and expectations via training and manager roll down YES

h. Implement changes YES 1.5 Develop and implement CAP communications tools

a. Begin publishing monthly CAP newsletter YES

b. Develop Feedback Program (Internal OEF) [Coard w/ OEP imp. - Problem Statement 7]

YES 1.6 Modify MMIS to improve efficiency of CAP administration

a. Develop scope and schedule for initial system improvements YES

b. Implement changes YES

c. Evaluate and revise MMIS/CAP database management, controls, and structure to make user friendly and NO provide for easier generation of management reports NOTE: TIIlS ITEM REQUIRES INTERFACE WITH OTHER EFFORTS TO CONSOLIDATE WORK MANAGEMENT SYSTEMS 1.7 Perform an independent assessment of CAP performance YES Revision 1 Page 36

Co.ive Action Restart Action Plan ATTACHMEN

Problem Statement 2 Corrective Action Program has no single point of accountability with respect to management ownership and oversight. Roles, authorities and responsibilities for administration of the program are not clearly defined.

Actions Restart 2.1 Establish a single point of accountability for CAP program development and implementation YES 2.2 Staff the QA/NSR CA Group and assume responsibility for program administration YES 2.3 Review, clarify, and communicate roles, responsibilities, and authorities of CA Group, Dept. Managers, Root Cause specialists, and Station QA in CA Program. Aspects to be considered include, but are not limited to: SIG. level determination, assignment of evaluation manager, assignment of corrective actions, monitoring quality/effectiveness of problem reporting/ individual RCA & ACA evaluations/corrective action, data entry, monitoring closure, trending, SERT, Root Cause Analysis procedures and training

a. Review existing procedures/documents and identify required changes and/or clarifications YES

b. Develop/revise written definition of roles, responsibilities and authorities. Incorporate into NAP-6, if YES required. (coincident w/ Rev for DRs)

c. Managers review roles, responsibilities, authorities, and expectations with their organizations YES

d. Managers address staffing levels and/ or i ob assignments, if necessarv YES 2.4 Implement program to monitor departmental performance

a. Develop program to assist department managers monitor performance of their departments YES b.. Implement departmental monitoring program YES

c. Develop and implement independent review of departmental performance YES

d. Develop and implement feedback to NBU senior management YES 2.5 Perform a self-assessment of Corrective Action Group performance YES Problem Statement 3 Salem has a significant backlog of Corrective Action Program documents.

A Actions Restart 3.1 Corrective Action Team (CAT) provide interim support to station depts. YES 3.2 INCIDENT REPORTS

a. Identify backlog of open IRs YES

b. Develop and initiate reporting of IR status YES Revision 1 Page 37

Co.ive Action Restart Action Plan ATTACHMEN

Actions Restart

c. Develop schedules to complete the evaluation of backlogged Incident Reports YES

d. Complete evaluation of all Incident Reports YES

e. Review all open IRs for identification of corrective action tracking. Establish tracking items where YES necessarv f

Complete all IR corrective actions (See note) NO 3.3 QA ACTION REQUESTS and DOCUMENT EVALUATION FORMS (DEF)

a. Implement monthly reports to track status YES

b. Close documents (See note)

NO 3.4 DEFICIENCY REPORTS

a. Implement monthly reports to track status YES

b. Close Documents (See note)

NO 3.5 Other document types which are incorporated into NAP by action 1.4

a. Develop methodology to close YES

b. Implement monthly reports to track status YES C. Close Documents (See note)

NO NOTE: Open items are to be reviewed by Department Managers to determine ifthe particular item is required to be completed prior to restart. Problem Statement 4 Completion of evaluations and corrective actions has not been timely.. Due dates are frequently missed or extended. Actions Restart 4.1 Publish expectation that evaluations be completed in 3 0 days and that CR/IR extensions be eliminated YES 4.2 Develop performance indicators for timeliness of evaluations and corrective actions YES 4.3 Establish controls over due date extensions

a. Condition Reports (Short Term)

YES

b. Incident Reports (Short Term)

YES

c. Address software security issue for selected fields, i.e., due date restricted to CAP personnel only.

NO (Long Term) 4.4 Publish daily list of upcoming and overdue evaluations YES 4.5 Publish weekly lists of upcoming and overdue corrective actions YES 4.6 Publish monthly list of upcoming and overdue effectiveness reviews YES Revision 1 Page 38

Co.ive Action Restart Action Plan ATTACHMEN

Problem Statement 5 Root cause analysis skills and procedures are weak. Corrective actions are often not effective at preventing recurrence.

Actions Restart 5.1 Conduct initial training on Organizational and Programmatic Root Cause Analysis and Human Error YES Analysis (FPI) 5.2 Implement process to measure quality of Level 1 CR/IR evaluations

a. Develop and publish interim guidance YES

b. Sample completed evaluations and report results YES 5.3 Develop and publish expectations for content and format ofLevel-1 (root cause) and Level-2 (apparent YES cause) evaluations 5.4 Implement monitoring program for quality ofLevel-1 evaluations

a. Begin review of evaluations by Corrective Action Review Board YES

b. Develop Performance Indicator of CARB review results YES 5.5 Implement monitoring program for quality of Level - 2 evaluations

a. Develop criteria YES

b. Communicate to organization YES

c. Develop performance indicator YES 5.6 QA perform independent assessment ofLevel-2, 3 & 4 evaluations YES 5.7 Implement Dept. Manager evaluation of effectiveness of corrective actions

a. Establish and communicate expectation YES

b. Develop performance indicators /reports on effectiveness reviews YES 5.8 Develop department root cause specialists

a. Identify candidates YES

b. Review/revise job assignments as appropriate YES

c. Evaluate and address impact on department resources YES

d. Schedule and conduct root cause engineer training YES 5.9 CA Group provide mentors for Root Cause Specialists YES 5.10 Improve Root Cause Procedure YES

a. Identify Sys. Engr. Dept. member to work with CA Group developing and implementing revision to Root Cause Procedure

- Develop and issue revision to Root Cause Procedure YES - Review/train on revision with Root Cause Specialists YES Revision 1 Page 39

Co.ive Action Restart Action Plan ATTACHMEN. Actions Restart* 5.11 Improve existing and develop new training programs. Transfer FPI technology to PSE&G. Courses to NO include:

a. Root Cause Analysis and Decision Making (Root Camp)

b. Root Cause Analysis Refresher

c. Organizational & Programmatic Analysis

d. Human Error Analysis

e. Component Failure Analysis for Engineers f

Advanced Component Failure Analysis for Engineers

g. Component Failure Analysis for Technicians and Supervisors

h. Root Cause Team Leader Problem Statement 6 Corrective Action Program trending does not effectively support NBU needs.

Actions Restart 6.1 Review and Improve Trending Program for Corrective Action Process

a. Identify Maint Rule and Sys Engr team members (1 each) to work with CA Group improving the YES trending programs

b. Assess current trending capabilities YES

c. Assess other utility (model) programs YES

d. Determine data to be trended (establish interface with M-Rule, NPRDS)

YES

e. Establish who will be identifying trend data (inputting codes) and who will be performing trend analysis YES f

Define CAP trending process (Develop written guidance) YES

g. Publish trend data on a quarterly basis YES 6.2 Conduct common cause analysis of Salem (and Hope Creek) performance

a. Initial Analysis by FPI YES*

b. Initiate periodic analysis by PSE&G Root Cause Specialists (Initially supported by FPI)

YES Revision 1 Page 40

Co.ive Action Restart Action Plan ATTACHMEN

Problem Statement 7 The Operating Experience (OE) Program has been ineffective at preventing events which have occurred in the industry from occurring at NBU nuclear facilities.

Actions Restart 7.1 Clarify Roles and Responsibilities

a. Clearly define scope and expectations of the OE YES

b. Identify optimized organization and reporting structure for the OE program YES

c. Eliminate redundant screening efforts YES

d. Establish issue ownership and accountability concept for each OE issue YES

e. Modifv tracking methods to align with ownership roles YES 7.2 Enhance Standards of Performance and Work Standards

a. Upgrade the effectiveness of the system for prioritizing OE YES

b. Upgrade the criteria for assigning due dates YES 7.3 Improve Monitoring and Trending of Performance and Expectations

a. OE will monitor the quality of responses and escalate as necessary YES

b. Develop trend parameters to effectively monitor and assess the program YES 7.4 Improve Communications, Coordination and Management Commitment Across Functional Areas

a. Develop and implement a senior management monthly status report YES

b. Upgrade the weekly OE station meetings YES Include the Training and Engineering Departments Develop a charter and expectations for the meetings Initiate periodic presentation of program status and trend data 7.5 Strengthen Self Assessments

a. Complete a baseline assessment utilizing industry support YES

b. Develop guidelines for performing self assessments NO

c. Schedule and perform periodic assessments NO

d. Complete an assessment of the upgraded program YES Revision 1 Page41

L__ ___ Sy.Engineering and Equipment Reliability Restart Action Plan Management Sponsor: Manager - System Engineering - Salem Manager - Salem Restart Engineering Introduction ATTACHMEN

System Engineering has not functioned pro actively to _assure that systems are established and maintained in a reliable state of readiness where they can be operated, maintained, tested, and modified in accordance with their design basis. Equipment problems have not been prioritized nor appropriate engineering attention applied to resolve long standing issues.

Objectives Improve system engineering and equipment reliability by: Providing management expectations and System Manager roles and responsibilities Achieving System Manager accountability and ownership for system performance Improving System Manager assessment of system performance Identifying and addressing equipment performance issues Assessing and documenting system readiness Improving System Manager monitoring of corrective action implementation and effectiveness Expected Results Upon the completion of the System Engineering and Equipment Reliability Restart Action Plan, the following results are anticipated: As a minimum, System Managers are proactively monitoring and trending system performance and assuring plant systems are in a state of readiness whereby they are operated, maintained, tested, and modified in accordance with their design basis.

_ System Engineering Department processes and methods are revised and improved to facilitate:

understanding the licensing/ design basis implementing system performance standards and monitoring documenting system attributes in system notebooks performing scheduled system walkdowns processing data into information for trending and analysis Revision 1 42

Sys.Engineering and Equipment Reliability Restart Action Plan

ATTACHMEN
The System Engineering culture and environment are changed to establish a proactive work environment which ensures:

the assertive identification of unacceptable or degrading equipment performance the consistent use of industry experience in problem solving the routine management of corrective actions the consistent application of root cause techniques to solve problems The System Managers are equal team members with Operations and Maintenance in decision making concerning system schedules and system performance. The System Readiness Review methods are adopted and become a permanent "Way of Life" for the System Managers. Problem Statement 1 System Engineering roles and responsibilities are not clearly defined or understood by system managers and interfacing organizations. NOTE: Related causal statements, actions and Performance Indicators are addressed in Engineering Restart Action Plan Problem Statement I. Problem Statement 2 System Engineering processes do not facilitate intrusive performance monitoring and analysis to support the identification of system and component reliability problems and improve Salem's performance. Actions Restart 2.1 Re-engineer System Engineering Functions/Processes

a. Benchmark System Engineering methods and practices being performed within the industry YES

b. Establish and benchmark system standards of performance NO

c. Develop system performance monitoring methods and problem identification NO

d. Assess and develop troubleshooting and root cause analysis methods YES

e. Assess and develop corrective action implementation and following methods YES f

Assess and develop system notebook methods and maintenance NO

g. Assess and schedule periodic, integrated system walkdowns YES Revision 1 43

Sys&ngineering and Equipment Reliability Restart Action Plan

ATTACHMEN
Actions Restart

h. Assess and develop methods for measuring and communicating System Readiness YES

1.

Assess and implement methods for utilization for operating experience feedback to enhance system YES readiness

j.

Perform Department Self-Assessments and integrate results into daily operations YES

k. Define and establish interaction with system maintainability programs (e.g. spare parts, PM).

YES

1.

Assess and optimize methods for coordination and review ofDCPs NO

m. Establish a plan for process upgrade to support System Encineering roles and responsibilities NO Problem Statement 3 A lack of system "ownership" by system managers and recognition of system managers by site departments results in long standing system and component reliability issues not being addressed in a timely manner.

Actions Restart 3.1 System Readiness Review Program <Evaluations & W alkdowns)

a. Develop System Readiness Review Plan YES

b. Develop guidelines for implementing System Readiness Reviews YES

c. Develop the restart review criteria for system readiness YES

d. Determine the systems that should be included in the System Readiness Review Program (SRRP)

YES

e. Develop a System Index Database System to retrieve & manage system corrective action requirements &

YES performance data in support of system readiness reviews required for restart f Obtain computer aided system readiness reports that are available in the near term & provide to System YES Mgrs.

g. Determine & implement the best method for prioritizing, implementing & tracking system deficiencies YES that should be resolved prior to restart

h. Assemble System Readiness Review Teams and secure resource requirements YES

1.

Assess currently compiled System Engineer Notebooks YES J. Supplement System Engineer Notebooks through System Readiness Review Program YES

k. Qefine & establish criteria for conducting system walkdowns YES Revision 1 44

Sys.Engineering and Equipment Reliability Restart Action Plan

ATTACHMEN
Actions Restart

1.

Conduct walkdown of Safe Shutdown (Mode 5) components YES

m. Conductwalkdowns of systems in SRRP - Unit I YES

n. Conduct walkdowns of systems in SRRP - Unit 2 YES

0. Retrieve & review relevant documentation for system deficiencies that should be corrected prior to YES restart-Ul

p. Retrieve & review relevant documentation for system deficiencies that should be corrected prior to YES restart-U2

q. Integrate the Top I 0 Critical Equipment List action items into the system readiness reviews & prioritize YES resolution accordingly

r.

Initiate corrective action to identified system deficiencies in accordance with restart review criteria - Ul YES

s. Initiate corrective action to identified system deficiendes in accordance with restart review criteria - U2 YES

t. Establish & implement a management level System Readiness Review Board for engineering assessment YES of all systems included

u. Self Assessment: Establish a Third Party Assessment of Selected SRR Systems for Unit I and 2 YES

v. Phase I - Present Initial System Readiness Reviews to l\\1RC for Unit I YES

w. Phase I -Present Initial System Readiness Reviews to l\\1RC for Unit 2 YES

x. Designate System Teams with Operations and System Engineering YES

y. Establish System Teams YES

z. Phase II - Assess l\\1RC approved/in-process/Completed work activities and perform system walkdowns YES for Unit I aa. Phase II - Assess l\\1RC approved/in-process/Completed work activities and perform system walkdowns YES for Unit 2 bb. Phase II - Assess new work and perform incremental l\\1RC presentations for necessary scope additions*

YES forUI cc. Phase II - Assess new work and perform incremental l\\1RC presentations for necessary scope additions YES forU2 dd. Develop the Startup Test Plan for Unit I YES ee. Develop the Startup Test Plan for Unit 2 YES ff Review the non-46 systems for Unit I YES gg. Review the non-46 systems for Unit 2 YES Revision 1 45

Sys.Engineering and Equipment Reliability Restart Action Plan

ATTACHMEN
Actions Restart hh. Phase III - Present final system readiness reviews to l\\1RC for Unit 1 YES

11. Phase III - Present final system readiness reviews to l\\1RC for Unit 2 YES ij. Phase IV - Startup and power ascension reviews/walkdowns for Unit 1 YES kk. Phase IV - Startup and power ascension reviews/walkdowns for Unit 2 YES Problem Statement 4 Hardware issues are not accurately identified or properly prioritized thereby impacting event-free operations.

Actions Restart 4.1 Develop & Implement Project to Prioritize Backlog of Hardware Issues

a. Identify existing backlog of significant hardware issues that challenge Operations YES

b. Develop method & prioritize significant hardware issues for resolution YES

c. Issue results & develop a reliability report YES

d. Ensure that all recommended actions and open issues identified in the Hardware Intervention Action Plan YES Report have been addressed and/or are being tracked to closure.

Problem Statement 5 A lack of engineering rigor in root cause analysis has resulted in long standing recurring equipment problems not being addressed and corrected in a timely manner. Actions Restart 5.1 Address High Priority Long Standing Equipment Performance Problems

a. Identify Targeted Equipment

1) Assemble team for evaluation NO

2) Interview operators, mechanics, technicians and gather published data NO

3) Identify specific components experiencing recurring failures or long standing degradation -

YES

4) Present the selected equipment list to the l\\1RC YES Revision 1 46

Sy.Engineering and Equipment Reliability Restart Action Plan

ATTACHMEN
Actions Restart

5) Department managers assign lead personnel in their areas as points of contact for each "select" YES component

b. Review and Analyze Relevant Documentation

1) Retrieve relevant site documentation for "select" components such as work history records, YES operability determinations, root cause analyses, T-Mods, DCPs, DEFs, etc.

2) Assemble team to review documentation.

YES

3) Summarize current status and results of previous attempts to achieve performance improvements YES

4) Identify historical activities and characterize why attempts to correct problems were not successful.

YES

5) Determine corrective actions that, if taken, will likely lead to improved root cause analyses for each YES "select" component; carry out new root cause analysis.

6) Identify action plans to address individual "select" component problems YES

7) Present action plans for each "select" component to MRC YES

c. Implement and Monitor Corrective Actions for "select" components for Ul NO

d. Implement and Monitor Corrective Actions for "select" components for U2 NO

e. Correct generic weaknesses NO

1) Identify generic historical weaknesses and establish action plans to correct NO

2) Overall complies and categorizes generic weaknesses NO

3) Long term actions are identified NO

4) Monitoring and future assessment methodologv established and implemented NO Revision 1 47

Ac.ted Training Restart Action Plan ATTACHMEN

Management Sponsors: Director - Nuclear Training Center Introduction In seeking accreditation renewal for the Operations Training Programs, several weaknesses were identified that resulted in the programs being placed on probation. Improvements in line and training management of training and qualification activities are required to assure that personnel are adequately trained and qualified and that all training programs meet accreditation standards.

Objective The objective of this action plan is to recover the Operations Training Programs from a probationary to a fully accredited status by: Establishing clear expectations and accountabilities for training programs. Ensuring that the Training Department's resources and capabilities are adequate to meet expected performance levels. Ensuring that training materials and facilities support required training and are of high quality. Ensuring that training instructors are effective and meet performance standards. Verifying that all work activities are performed by appropriately qualified and trained personnel. Upgrading the self-assessment process for training to emphasize line management participation. Expected Results Upon completion of the Accredited Training Action Plan, the below listed results are anticipated. Specific performance standards exist to measure progress toward the end goals. Line managers consistently demonstrate ownership of.their respective training programs and use their training programs to improve plant and personnel performance through: - providing critical observations of training/qualification activities in all settings - leadership as chairmen of their respective Training Review Groups (TR Gs) - participation in Comprehensive Self-Evaluations (CSEs) of their respective accredited training programs - participation in lesson plan and training development Instructor performance is consistently rated as effective and training materials are consistently rated as clear and accurate. Exceptions are addressed promptly. Revision 4 Page 48

Ac.ted Training Rest~ Action Plan ATTACHMEN

The CSE process demonstrates a critical, in-depth proficiency that identifies training weaknesses, root causes and effective corrective actions. The CSE process also contains means to verify corrective action effectiveness following implementation.

The Nuclear Training Department is adequately staffed to conduct effective training. The simulator is maintained current, as evidenced by trainee/management feedback and completion of software and hardware changes in accordance with established standards. Applicable actions within the Restart Action Plan are incorporated into the training programs and reinforced in training sessions for sustained improvements. Full accreditation of the Salem Operations training programs has been renewed. Problem Statement 1 Senior management has not established and reinforced clear expectations for line and Training Department ownership and accountability for the training programs and processes. This has led to a degradation of the operator training programs. Actions Restart 1.1 Promulgate expectations regarding ownership of training and qualification to line and training management.

a. Issue written expectations for (1) line management ownership of their respective training programs; (2) line YES management responsibility for ensuring work activities are performed by qualified personnel; and (3) training management responsibility for maintaining training and qualification processes that meet industry standards.

b. Conduct sessions to convey expectations to Operations staff Reinforce expectations for ownership, YES observation and participation in training activities and qualifications of staff.

c. Training manager meet with training staff to define his expectations for the conduct of training programs.

YES Conduct rolldown meetings with staff to reaffirm expectations at monthly staff meetings. NO Conduct TSD seminars for NTD staff YES

d. Conduct initial TSD seminar for line and training management to improve understanding roles and NO responsibilities for training programs.

e. Conduct two additional TSD seminars for line/training management with INPO.

YES f Conduct overview of accredited programs and expectations for continuing training for all personnel. YES

g. Revise training for new supervisors to include overview of accredited training programs and reinforce YES expectations.

h. Meet with Training Manager, GM-Salem, and Operations Manager to reinforce expectations and resolve YES any issues.

Revision 4 Page 49

Ac.ted Training Restart Action Plan ATTACHMEN

Actions Restart

1.

Conduct sessions to convey expectations to Engineering Staff Reinforce expectations for ownership, YES observation and participation in training activities and qualifications of staff J. Establish a line manager/supervisor check-in procedure requiring review of training responsibilities with YES their immediate supervisor.. 1.2 Set standards for training observations in all trailing settings (classroom, simulator, lab and in-plant).

a. Issue written expectations to line managers for observations of training activities including instructor skills YES and training materials quality. Implement modified observation forms.

b. Specify recommended minimum frequencies of observations to GM - Salem.

YES

c. Provide monthly summary of observation results to line managers and GM - Salem.

YES

d. Provide weekly schedules of in-plant training activities and observation targets to assist line managers to YES schedule their observations.

e. Develop training for line managers and supervisors on how to conduct training observations.

YES f Provide training to line managers and supervisors on how to conduct training observations. YES

g. Incorporate into supervisory training a topic on how to conduct training observations.

NO 1.3 Set standards for the conduct of simulator training.

a. Meet with simulator instructors to detail expectations.

YES

b. Revise SSP-201 to provide guidance to instructors on briefing the crew on simulator discrepancies and use YES of simulator freeze function.

c. Revise SSP-208 to provide guidance for scenario guide validation.

YES

d. Conduct special training session for simulator instructors on procedure revisions.

YES 1.4 Develop training performance indicators and monitor performance against defined indicators.

a. Review and finalize performance indicators (Action Plan).

YES

b. Review and finalize performance indicators (NTOC). (Responsibility assigned to TRGs by NTOC.)

YES

c. Review and finalize performance indicators (TRGs).

YES

d. Submit Nuclear Network item for performance indicators, review input for incorporation into d.2.

YES 1.5 C~nduct bi-monthly training performance reviews with Training Manager and Salem line managers through YES 12/31/95. 1.6 Review and implement changes to training oversight function.

a. Revise the membership and charter of the Nuclear Training Oversight Committee based on review of YES industry practice

b. NTOC to review performance indicator results, the status and effectiveness of corrective actions for YES licensed/non-licensed operator training and lesson learned for other Salem programs Revision 4 Page 50

Ac.ted Training Restart Action Plan ATTACHMEN

Actions Restart C. Revise Training Review Group (TRG) charters to put focus on assessment of training effectiveness and YES management oversight of training. NTOC member attend first TRG meeting under new charter

d. All TRGs to meet monthly through 12/31/95.

YES

e. TRGs meet quarterly following 12/31/95 in accordance with NAP-14.

NO 1.7 Evaluate change in operator requal schedule from current two weeks per requal segment to one week. NO

a. Operations management to meet with class each requal session.

NO

b. Implement schedule changes.

NO 1.8 Evaluate changes in requal schedules for balance of accredited training programs. NO

a. Maintenance NO

b. Rad Pro/Chemistry NO C. Engineering Support NO 1.9 Rework Nuclear Training Department processes and procedures.

NO Problem Statement 2 Line and Training Department management may have not identified all of the root causes of the training program deficiencies associated with the Salem Operations Accreditation renewal issues. Actions Restart 2.1 Perform Training Department root cause analysis of issues associated with the Salem Operations Accreditation YES Renewal 2.2 Conduct independent root cause analysis by combined NBD/industry team. YES

a. Develop team charter YES

b. Kick-off team review YES

c. Complete review YES 2.3 Modify action plan as necessarv based on root cause results.

YES 2.4 Forward independent root cause response to INPO. YES Revision 4 Page 51

Ac.ited Training Restart Action Plan ATTACHMEN

Problem Statement 3 Open management, supervisory, and instructional positions have adversely impacted the quality of training. Performance problems with selected incumbents has compounded the impact.

Actions Restart 3.l Perform assessments of key managers and supervisors. YES 3.2 Identify positions to be filled or replaced.

a. Fill NLO Training Supervisor position.

YES

b. Fill Simulator Supervisor position.

NO

c. Fill Manager - Nuclear Training position by external recruit.

YES

d. Fill Salem Licensed Operator instructor position.

YES

e. INPO Reverse Loanee.

NO f Fill Salem NEO Instructor positions.. YES 3.3 Implement performance improvement programs for individuals, reevaluate performance, take. additional YES actions as necessary. 3.4 Evaluate resources needed to conduct required training and revise instructional materials through end of 1995. YES 3.5 Bring in contract assistance as necessary.

a. Supplement an instructor work force to compensate for unfilled vacancies and recently filled positions YES being certified (3 people).

b. Resources needed to revise training materials (6 people).

YES

c. Additional instructor for initial NEO class (due to size of class).

YES

d. Designate evaluators for NEO task qualification.

YES

e. Clerical Resources required to support training material revision.

YES 3.6 Assess trainee feedback from the current initial NEO and licensed operator classes to assess need for additional YES actions. 3.7 Delay start of initial NEO training program to allow for training material revision and instructional skills YES improvement Problem Statement 4 Quality of training materials has had an adverse impact on classroom instruction. Failure to properly prioritize simulator deficiencies and configuration issues may adversely affect simulator training. Revision 4 Page 52

Ac.ited Training Restart Action Plan ATTACHMEN

Actions Restart 4.1 Ensure simulator configuration management supports required training.

a. Revise SP-203 to address documentation and prioritization of problems and communicate to simulator YES staff.

b. Separate hardware and software deficiencies and categorize for resolution.

YES

c. Establish simulator inoperable instrument log.

YES

d. Re-prioritize all open simulator deficiencies.

YES

e. Monitor close-out of deficiencies in accordance with prioritization categories; monitor via performance NO indicators.

4.2 Upgrade training materials.

a. Identify materials requiring revision and prioritize.

YES

b. Combine lesson materials so there is common set for licensed and non-licensed training.

NO

c. Evaluate training material quality utilizing trainee, line management and training management observations.

NO

d. Review and revise, as necessary, the training materials revision process.

NO 4.3 Provide additional method of identifying new or significantly revised tasks by revising the purchasing process NO to require notifying Training Department of new equipment or test equipment and including vendor training in the bid specification. 4.4 Create Simulator Review Panel as part of Operations TRGs. YES

a. Salem Panel in place

b. Hope Creek Panel in place Problem Statement 5 Instructor performance weaknesses reduce the effectiveness of classroom and simulator training. Task performance evaluations conducted by evaluators do not sufficiently evaluate student mastery of the task prior to independent performance.

Actions Restart 5.1 Upgrade qualification instruments to industry standards.

a. Provide interim guidance to incumbent evaluators to ensure all trainees complete system knowledge YES checkouts before they are allowed to obtain a task evaluation.

b. Evaluate existing instruments against industry standards for the use of follow-up questions and revise as YES necessary.

c. Train designated evaluators prior to performing additional evaluations.

YES Revision 4 Page 53

Ac.ted Training Restart Action Plan ATTACHMEN

Actions Restart

d. Use observation results to identify topics for evaluator refresher training and as a basis for coaching NO individual evaluators (first quarterly review).

1) Letter to Operations Manager detailing trends in training and qualification activities performed in-YES plant.

e. Review remaining accredited programs for OJE/OJT process.

NO

1) Identify current process/practice.

2) Evaluate against ACAD 91-006.

3) Modify as required.

f Standing item for TRGs to verify evaluator training and revised QCE Program is effective via NO observation of qualification activities. 5.2 Upgrade current performance levels of instructors as necessary.

a. Revise instructor observation process including immediate feedback of observation results.

YES

b. Observe instructor performance by industry peers.

YES

c. Obtain current feedback from INPO review visit on instructor performance.

YES

d. Perform quarterly performance reviews of instructor personnel and hold accountable for meeting NO expectations.

e. Use observation results to identify topics for instructor continuing training and as a basis to coach NO individual instructors (first quarterly review).

Instructor continuing training scheduled for third quarter 1995 based on observation deficiencies. YES

1) Questioning Techniques

2) Preparation of Transparencies

3) Classroom Management

4) Reinforcement ofWork Standards

f.

Conduct instructor initial training program utilizing lessons learned to complete program modifications. YES

g. Implement Instructor TRG.

YES

h. Create individual instructor development plans.

NO 5.3 Uograde Qualification Card Evaluator Program

a. Revise TP-101 ( aualification procedure).

YES

b. Letter of changes to TP-101 and expectations to each line manager and evaluator YES

c. Deleted from Plan

d. Revise initial and refresher generic QCE programs into separate courses.

YES

e. Generic QCE made specific for each discipline YES Revision 4 Page 54

Ac.ted Training Restart Action Plan ATTACHMEN

Actions Restart f

PTS sessions with instructor on specific QCE YES

g. PTS present specific program at respective TRG meeting YES

h. Deleted from Plan

1.

Implement new QCE program YES 5.4 Upgrade Initial Instructor Training Program

a. *Evaluate T and Q level of instructional staff and match new to old tasks.

YES

b. Update Instructor Task-to-Training matrix - input new job analysis.

YES

c. Update Qualification Tracking System.

YES

d. Complete Instructor Job-Task Analysis.

NO

e. Revise Instructor Training Procedure (TP-2911 ).

YES f Revise Exemption Process Procedure (TP-0102). YES

g. Develop instructor specific exemption process.

YES

h. Identify topics and implement training sessions.

YES

1.

Develop instructor training program materials. YES J. Conduct instructor training as necessary. YES 5.5 Operations OJT Action Plan

a. Propose to Operations Managers.

NO

b. Finalize OJT plan with stations.

NO

c. Revise Training Procedures NO

d. Revise Qualification Guides.

NO

e. Finalize procedures and qualification guides with stations.

NO f Implement new process. NO 5.6 Develop an orientation program for new principal ti-aining supervisors NO 5.7 Establish qualification cards for NTD supervisors/managers.

a. Develop qual cards.

NO

b. Complete incumbent reviews.

NO 5.8 Revise ESP training program description. YES 5.9 Develop Job Qualification Guides (JQGs) for each accredited ESP discipline. NO 5.10 Revise/develop initial and continuing ESP Training.

a. Select tasks/topics for training.

YES

b. Develop self-study guides/lesson plans for selected topics.

1) Plant Operations Orientation NO Revision 4 Page 55

Ac.ted Training Restart Action Plan ATTACHMEN. Actions Restart

2) Other Orientation NO

3) Position Specific Orientation NO

c. Develop fourth quarter OEF Training.

YES

d. Schedule 1996 training for selected courses.

NO 5.11 Conduct fourth quarter OEF Training. YES 5.12 Evaluate training effectiveness for ESP Program. NO 5.13 Conduct Qualification Guide Evaluator Training for ESP. NO Problem Statement 6 Personnel have performed work activities for which they are not appropriately trained and qualified. Actions Restart 6.1 Conduct sessions for operating shifts to reinforce expectation that all personnel are trained and qualified to YES perform work activities. 6.2 Assure that SNSSs meet full qualification standards. YES Develop SNS S succession plan encompassing both temporary replacements and promotions. YES

a.

b. Revise VPN-12 to prohibit temporary upgrades to SNSS prior to completion of full qualification YES program, except in defined, extreme circumstances.

c. Revise NAP-14 to prohibit temporary upgrades to SNSS prior to completion of full qualification YES program, except in defined, extreme circumstances.

d. Operations Manager will verify that all personnel who fill the SNSS position temporarily are qualified.

YES 6.3 Assure that non-licensed operators are qualified.

a. Interview incumbent NLOs trained since the last accreditation renewal to identify any knowledge or skill YES deficiencies and remediate as necessary.

Boric Acid Evaporator operation evaluation/remediation NO

b. Repeat selected task qualifications for a sampling of recently qualified personnel. (One individual failed YES and was successfully remediated.)

c. Perform verification of qualification for all non-licensed operators.

YES

1) Audit training records for Salem NLOs.

YES

2) Audit training records for Hope Creek NLOs.

YES

3) Resolve discrepancies identified for item 6.3.C.1.

YES

4) Perform qualification activities for NLO classes 0301. 094. 01 and 0301. 001. 01.

YES Revision 4

Page 56

Ac.ited Training Restart Action Plan ATTACHMEN

Actions Restart

5) Resolve discrepancies identified for item 6.3.C.2.

YES

d. Deleted - duplicate activity to item 6.3.c.

YES

e. Perform verification of qualification for all licensed operators.

YES

f. Perform qualification activities associated with discrepancies identified. for item 6.3.e.

YES

g. Assessment of operator performance associated with discrepancies identified for item 6.3.e.

YES

h. Systematically review the NLO qualification cards to identify those tasks that must be actually performed NO prior to qualification. Revise the qualification cards based on the review results prior to use.

1) Primary

2) Secondarv

3) Outside 6.4 Identify any other situations where non-qualified personnel may be performing work and take appropriate YES action.

6.5 Assure that Engineering Support Personnel are qualified.

a. Identifv population in program.

YES

b. Complete iob analysis.

YES

c. Supervisors/managers complete incumbent review forms.

YES

d. Complete incumbent review board.

YES

e. Report incumbent training and qualification status to managers/supervisors.

YES 6.6 Assure that shift technical advisors (STAs) are qualified.

a. Develop additional evaluation material for qualifying STAs during initial training and evaluating during YES continuing training.

b. Revise STA training procedures, task lists, qual cards; and identify core of "must perform tasks.

YES

c. Review "present state" evaluation methods for incumbents:

1) Performance appraisal items/exPectations relative to STA duties.

YES

2) Evaluation of STAs on the simulator.

YES

d. Conduct root cause evaluation/recommend corrective actions for STA Program weaknesses YES

e. Evaluate incumbent STAs.

YES 6.7 Add Operations qualifications to "Qual Tracking" system.

a. Input/verify qualifications.

YES

b. Train Operations supervision/management on use of system.

YES 6.8 Conduct Salem licensed operator readiness exam. YES Revision 4 Page 57

Ac.ited Training Restart Action Plan ATTACHMEN

Problem Statement 7 The current self-evaluation process has not provided critical assessment of the training programs. This has contributed to the probationary status of the Salem Operations programs.

Actions Restart 7.1 Compare results ofindustry peer observations of training activities to observations conducted by Salem line YES and training personnel; evaluate the need for any adiustments in the observation process. 7.2 Evaluate current trainee feedback process.

a. Compare against industry practices. Implement any needed changes.

YES

b. Determine method to ensure feedback to trainees on the disposition of their course evaluations.

YES

c. Revise Training Feedback process.

YES

d. Deleted from plan.

7.3 Review and revise comprehensive self-evaluation process.

a. Include line management participation.

YES

b. INPO visit, semi-assist YES

c. Incorporate INPO comments from semi-assist visit.

YES

d. Pilot revised process on RP/Chemistry training programs.

YES

e. Make revision to Self-Evaluation procedure based on pilot (TP-0105).

YES f RP/Chem Self-Evaluation results presented to NTOC by line managers (Program Owners). YES g, Develop plan to retain Operations accredited training program to support Salem Restart YES

h. Conduct comprehensive self-evaluations.

YES HC Ops. Programs Engineering Support Programs

1.

Conduct comprehensive self-evaluations. YES Controls Programs Mechanical Programs J. INPO Self-Evaluation Review Visit YES

k. RP/Chem Self-Evaluation follow-up review YES

1.

Make final revision to self-evaluation procedure based on completion of CSEs, including ongoing self-NO assessment to conduct follow-~p assessment on completed corrective actions. Revision 4 Page 58

Ac.ited Training Restart Action Plan ATTACHMEN. Actions Restart 7.4 Present completed CSEs to NTOC.

a. ESP CSE results presented to NTOC by program owners.

YES

b. Hope Creek Operations CSE results presented to NTOC by program owners.

NO

c. Maintenance CSE results presented to NTOC by program owners.

YES

d. Deleted from plan.

e. Revised RP/Chem CSE to NTOC by program owners.

YES Problem Statement 8 Nuclear Training Department personnel may not be identifying training weaknesses objectively. Use of other internal oversight personnel and industry peers must be utilized to ensure the recovery actions are completed and effectively implemented. Actions Restart 8.1 Assign PSE&G Recovery Team.

a. Designate project management team members.

YES

b. Project management team in place and functional.

YES

c. Maintain project plans for each problem and accrediting board concern.

YES

d. Develop utility comments for each problem and board concern.

YES

e. Develop and maintain document "notebooks" current with weekly status and update INPO Probation YES Manager.

f Develop and maintain documentation for NTOC/TRG and INPO recovery/review team. YES

g. Maintain weekly status of updates to actions, completed and overdue, and results.

YES

h. Report to TRGs and NTOC monthly, and Training Manager weekly.

YES

1.

Educate line and training personnel on how to go through a probation period and interact with INPO YES teams. 8.2 Request Peer Review Team involvement.

a. Obtain commitments from utilities.

YES

b. Peer review team periodically observe, assess and comment on effectiveness of corrective actions and training staff performance.

Peer team visit - second quarter YES Peer team visit - fourth quarter YES Revision 4 Page 59

A.ited Training Restart Action Plan ATTACHMEN' Problem Statement 9 The NBU management team must concur with readiness for accreditation renewal and be prepared for the Accrediting Board. Actions Restart 9.1

Accreditation Review Team Manager visit YES 9.2 Accreditation Review Team First visit YES 9.3 Accreditation Review Team Second - Fifth visit YES 9.4 Prepare management team for return visit to Accrediting Board

a. Educate team on TSD, accreditation, etc.

NO

b. Assure intimate knowledge of problems, corrective actions and results NO C. Develop strategy for board meeting NO

d. Practice board NO

e. Salem Accreditation Board YES 9.5 Deleted - not applicable to Salem.

9.6 Provide monthly status to CNO and CEO on accreditation recovery activities. NO Revision 4 Page 60

1 ATTACHMENT 3 ACTIONS TO ADDRESS RECURRING EQUIPMENT RELIABILITY & OPERABILITY ISSUES

1.0 INTRODUCTION

In response to recurring equipment reliability and operability problems at Salem Generating Station, PSE&G is implementing an aggressive and comprehensive effort to review and address identified significant equipment concerns prior to the restart of each unit. As described in the Salem Restart Plan, the center piece of this effort is the System Readiness Review Program (SRRP). An overview of the SRRP is discussed in the Salem Restart Plan. The following is a more detailed description of the SRRP as well as other aspects of the Salem Restart Plan which focus on recurring equipment reliability and operability issues. This discussion focuses primarily on the identification, screening, and approval activities necessary to establish the restart work scope for equipment related issues.

2.0 BACKGROUND

ON EQUIPMENT INTERVENTION ACTIVITIES Initially, a special team review oflong-standing equipment issues was initiated in late March 1995. The objective ofthis effort was to develop and implement a management prioritization process to focus on performing the right work at the right time. This process was known as the Hardware Intervention Action Plan (HIAP). The team evaluated the most critical systems with respect to overall plant safety and reliability. This approach identified 29 focus systems. The criteria used in this screening were: System contribution to core melt risk as determined by the Salem PRA Power production losses attributed to each system (in the past 18 months) Corrective maintenance man-hours applied to the system (in the past 18 months) Following the decision to keep Units 1 and 2 off line for an extended outage, the scope of the equipment intervention effort was significantly expanded. This expanded effort became the System Readiness Review Program (SRRP). The SRRP identified 46 critical systems for the highest tier of review. These 46 systems include all 29 systems identified by HIAP as well as other systems considered to be critical systems based on additional reviews with respect to: (I) safe shut down, (2) risk significance, (3) historical power loss or (4) historically high corrective maintenance work load. Starting in July 1995, the SRRP was initiated using a detailed procedure to prescribe the method to implement the System Readiness Reviews (SRR) of the 46 critical systems. (Other supporting systems are also being reviewed using a thorough but less rigorous process.) The approach applied to the critical systems, contains the following four phases (as is discussed in the Salem Restart Plan): Page 1 of7

ATTACHMENT 3 Initial System Readiness Reviews - the identification of problems & corrective actions Restart Activities Monitoring - the scheduling and monitoring of corrective action implementation Final System Readiness Review - verification of completion of corrective actions Startup and Power Ascension - the plant startup testing & continuous monitoring of plant performance and corrective action effectiveness. 3.0 INITIAL SYSTEM READINESS REVIEWS The following is a discussion of the major activities of the Initial System Readiness-Reviews (ISRR) that established the scope of the equipment related restart activities. 3.1 SYSTEM MANAGERS AND SYSTEM READINESS REVIEW TEAM Each System Manager has "ownership" for their system, not only during the SRR, but also during startup, power ascension and full power operations. Prior to restart, each System Manager will affirm that their system is prepared for safe and reliable plant operation. Each ISRR (on critical systems) was conducted by a multi-discipline team. System Managers led and organized each SRR team. The teams typically consisted of representatives from Maintenance, Operations, Design Engineering and Planning. As needed, outside consulting resources were utilized to provide the appropriate expertise to supplement in-house resources. 3.2 DESIGN BASIS REVIEW The SRR team reviewed each critical system's design basis documentation. This review enabled the SRR team to gain an understanding of the overall system functional requirements and provided a basis for the SRR team to reference during the entire initial SRR effort. Additionally, any discrepancies identified during this review were incorporated into the Corrective Action Program. 3.3 DATA COLLECTION A comprehensive inform,ation management system, System Index Database System (SIDS), was developed to collect open corrective actions from various site sources and sort this information by system. SIDS contains the following types of SRR data sources: Open Corrective Maintenance Work Orders Open Preventative Maintenance Work Orders Open Identified Operator Work-Arounds Open Action Requests Open Configuration Control Deficiencies Open Action Tracking System Tasks Scheduled and Unscheduled Design Change Packages Open Discrepancy Evaluations (DEF) Page 2 of7

ATTACHMENT 3 SIDS types of SRR data sources (continued): Open Engineering Work Requests Equipment I System Operability Determinations Temporary Modifications (T-Mods) Open Incident Reports Open Quality Assurance Action Items 3.4 EVALUATION & SCREENING OF OPEN CORRECTIVE ACTION ITEMS The identified open corrective action items (as discussed above) were reviewed and evaluated for restart readiness scope in accordance with the System Readiness Review Program. This means that each item has been screened into one of four categories as listed below: Restart - To be completed prior to power ascension Power Ascension - To be completed prior to full power operation Post Restart - To be completed after power ascension Not Applicable - Redundant or invalid item Items categorized as Restart undergo an additional classification as either Restart Required or Restart Recommended. 3.5 SYSTEM W ALKDOWNS The SRR team conducted a formal walkdown of individual system components and specific system areas. The walkdowns focused on equipment reliability and operability issues. Detailed walkdown guidelines were used as a reference to plan and conduct the walkdowns. W alkdown findings were reviewed, entered into the appropriate administrative corrective action process, screened to Restart Criteria, and recorded electronically in the System Index Database System. 3.6 INITIAL SYSTEM READINESS REVIEW (ISRR) REPORT Following the design basis review, corrective action item review/screening and system walkdown, an ISRR report was generated for presentation to the System Readiness Review Board (SRRB) and Management Review Committee (MRC) (defined in the Salem Restart Plan). The report included as a minimum the following information: Documentation of any identified Design Basis concerns Evaluation of work scope determination and recommen~ed screening categories System walkdown results Aggregate evaluation of deferred work Identification of generic programs, process and procedural concerns New actions determined Page 3 of7

ATTACHMENT 3 3.7 PRESENTATION OF THE ISRR REPORTS TO THE SRRB & MRC The System Managers presented the ISRR reports to the SRRB prior to the MRC. The SRRB performed a technical assessment of each SRR report for consistency and completeness. The SRRB is a multi-discipline team of Engineering supervisors/managers with the experience needed to assess the quality of the SRR. If the SRRB disapproved the report, the System Manager resolved the SRRB concerns and r.e-present the report to the SRRB until approval is obtained.* Once all SRRB comments were satisfactorily resolved and the ISRR report was approved, the report was presented to' the MRC. System Manager presented the ISRR report to the MRC for review and approval. The MRC review focused on the restart screening criteria in order to affirm proper categorization. 3.8 RESTART ACTIVITIES MONITORING & FINAL SYSTEM READINESS REVIEWS The System Managers will perform monitoring of the restart activities including walkdowns, intrusive examinations of selected field work and evaluation of emergent activities for inclusion into the restart work scope. A final SRR will be completed for each critical system an_d presented to the SRRB and MRC for review and approval. These reviews will be completed as part of the overall Restart Readiness Assessment as discussed in the SRP. Written affirmation of system readiness will be required from the System Manager and the licensed Senior Reactor Operator assigned to each system. -Further descriptions of these activities are included in the Salem Restart Plan. 4.0 OTHER EQUIPMENT RELIABILITY & OPERABILITY IMPROVEMENT ACTIVITIES In addition to the System Readiness Review Program, other parallel and complementary activities are being conducted to ~.ssure effective corrective actions for recurring equipment problems now and in the future. _These activities include the following: Investigation into recurring equipment problems including an overall root cause assessment

Actions to address Operator Work Arounds Configuration Control Inspections Common/Equipment Related Programmatic Reviews 4.1 INVESTIGATION INTO RECURRING EQUIPMENT PROBLEMS A separate initiative to specifically identify and analyze recurring equipment problems was initiated as part of the System Engineering and Equipment Reliability Action Plan of the SRP.

The first phase focused on establishing an overall list of identified recurring equipment concerns. The second phase involves an in-depth data analysis of "select"* components (a subset of the overall list of identified recurring equipment concerns). The goal of this analysis is not to fix the individual equipment problems (that will be addressed through SRRP); the goal is to establish the generic root causes for the failure to identify and correct the problems the first time. Page4 of7

ATTACHMENT 3 4.2 OPERATOR WORKAROUNDS (OWA) An OW A exists where it is necessary for an Operator to take manual action to compensate for a degraded condition or a design deficiency of a system or component and this action increases the risk of inducing a transient or impedes the operator's ability to respond to a transient.

To ensure that all existing OW As were captured, the existing list of OW As was reviewed by the Operations Department Staff In addition, a survey used to identify OW As was completed by two full shifts of operators. Following this effort, select Operations personnel reviewed the backlog of maintenance work orders to identify any additional items that should be included on the OW A list.

This thorough data collection and review effort was conducted to ensure that all identified OW As were' identified for possible inclusion in the restart scope. All identified OW As were reviewed against the restart screening criteria (refer to Attachment A of the Salem Restart Plan). The results of this review were presented to the MRC for approval. In qrder to address past problems with identification, tracking and elimination of OW As, the Operations Department is developing a new procedure for the handling of OW As. The new procedure includes a specific definition of OW As, as well as direction on the categorization, tracking and close-out of OW As. 4.3 CONFIGURATION CONTROL INSPECTIONS

As a result of a large number of identified configuration control discrepancies, a self assessment was conducted by Nuclear Engineering into the cause of the configuration control discrepancies at Salem.

The findings of the self assessment, as well as a list of identified corrective actions were issued in a report which recommended performing configuration control walkdowns of Salem systems. The walkdowns will address the same 46 systems as those undergoing system readiness reviews under the SRRP. W alkdowns focus on comparing the phY,sical installation with selected design drawings and include labeling checks, electrical fuse and breaker information gathering and bolting material sampling.* 4.4 COMMON EQUIPMENT RELATED PROGRAMMATIC REVIEWS The Management Review Committee has tasked the organization to perform reviews into key common/equipment related programs. Examples of the programs under review are provided below. The results of these reviews have been or will be presented to the MRC for review and approval of those corrective actions required to be made prior to restart. Check Valve Program Commercial Grade Dedication Design Change Implementation Environmental Qualification Program Erosion/Corrosion Program Fuse Control In-Service Inspection Page 5 of7

ATTACHMENT 3 In-Service Testing Leak Repair Maintenance & Test Equipment Calibration Maintenance Rule Motor Operated Valves Operating Experience Feedback 5.0 ACTIVITIES TO BE COMPLETED PRIOR TO RESTART The activities that will be completed prior to restart can be categorized into the following groups: Design Change Packages Inspections, Component Repair or Replacement Preventive Maintenance, Testing* and Surveillances The. majority of these activities are to be completed to address one or more of the following concerns: Removal of a Temporary Modification Correction of an Operator Work Around Correction of a Configuration Deficiency Correction of a Design Deficiency Correction of a Component Deficiency The following is a list which exemplifies those activities scheduled to be completed prior to restart. This is by no means a comprehensive list of the activities which will be completed prior to restart. The outage work list includes in excess of30,000 items. These include: Over 6600 work orders Over 1100 procedure changes Over 500 design change packages Over 600 DEFs (Deficiency Evaluations) The following list provides examples of the work (in the areas Design Change Packages; Inspections, Component Repair or Replacement) which are scheduled to be completed as part of the Salem Restart effort. Page 6 of7

ATTACHMENT 3 Design Change Packages Installation of Digital Feedwater Control System Upgrade of Service Water Piping (both large bore & small bore) Overhaul of Circulating Water System RMS R41 Replacement Spent Fuel Rerack Project HEBA/MEBA Project Auxiliary Building HV AC Upgrades Pressurizer Upgrades Fuel Transfer System/Manipulator Crane Upgrades SIG Feedwater Nozzle Thermal Sleeve Replacement Switchgear Penetration Work Secondary Piping and Valve Upgrades Replace MST Low Pressure Tube 125V DC Battery Charger Upgrades Feedwater Flow Measurement System Emergency Diesel Generator Air System Feedwater Heater Tube Bundle Replacement Main Turbine Lube Oil Separator Replacement Control Area Ventilation System Upgrades Screen Wash Piping Upgrades Hagan Module Upgrades RCP Motor Oil Collection System Modifications Diesel Generator Vibration Modifications Turbine Generator Limit Switches Main Steam Reheat Drain Line Modifications Reg. Guide 1.97 Work Inspections, Component Repairs/Replacements Expanded Scope Steam Generator Tube Inspections Steam Generator Tube Plug Replacement RCP Motor Refurbishment Main Generator Lead Box Refurbishment Generic Letter 89-13 Inspections Emergency Diesel Generator Disassembly and Inspection Page 7 of7}}

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