ML20012C867

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Rev 2 to Transient Reduction Program for Nov 1989.
ML20012C867
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 01/05/1990
From:
ARKANSAS POWER & LIGHT CO.
To:
Shared Package
ML20012C866 List:
References
PROC-900105, NUDOCS 9003260024
Download: ML20012C867 (61)


Text

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ATTACHMENT TO 1CANO39007 e

iz TRANSIENT REDUCTION PROGRAM NOVEMBER-1, 1989 g.

( baw/ l-3-TD -

SITpYrintendent, Tperations Assessment

] W (~' 3 f Director,Quclear Operations 9003260024 900313 P,DR ADOCK0500g3 {jj. b)

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REVISION Revision Date Description  ;

Draft 2/26/87 Issued for interim use and s

comment t

0 1/11/88 This issue incorporates '

comments to the preliminary document and reassigns' duties due to the Nuclear Operations Department reorganization.

1- 7/1/88 This issue reassigns. duties due to transfer of the program to ANO.

2 11/01/89 This issue clarifies responsibilities, updates jobs titles, and increases

! due date accountability.

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1CANO39007 TABLE Of CONTENTS PAGE i

. INTRODUCTION 4 BACKGROUND 6 i

AP&L EFFORTS TO DATE 9 THE TRANSIENT REDUCTION PROGRAM 22 CONCLUSION 27

. SUPPLEMENT A - TRANSIENT REDUCTION PROGRAM GUIDELINES 28 ATTACHMENT A -' RECOMMENDATION CLOSE-0VT MEMORANDUM FORMAT 57 SUPPLEMENT B - MANAGEMENT REVIEW GROUP CHARTER 62 u

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.1CANO39007 INTRODUCTION AP&L has implemented a formal Transient Reduction Program in response to Nuclear Operations Goals and Objectives for 1987 through 1990. The Program was. originally conceived'as a Scram Reduction Program. However, the Program was expanded to include other transients in recognition that transients without scram may also challenge safety systems, t

This Program provides a coordinated, systematic, processing and tracking method for transient reduction recommendations. The Program was initially ,

comprised of items-identified, for the most part, by AP&L. This established Program was chosen as the means to address the B&W Owner's Group Safety and Performance Improvement Program (SPIP) recommendations. It also is the mechanism for processing recommendations generated by internal organizations (e.g., through Operations Assessment evaluations) or other external organi-zations (e.g., CEOG).

The Program consists of two components. The first component, the Policy Statement, was issued in early December,1987. The Policy Statement formally directed that a program be established. The second component, the Program Document, provides the guidelines for Program implementation.

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ATTACNMENT TO 1CANO39007 This Program Document is divided into four areas. First, historical data is presented to show why such a Progri.m is desirable. Second, a description of AP&L' efforts to'date is provided to show how the Program fits with existing efforts,_ The third section provides. specific guidelines to establish the duties, responsibilities, and interfaces which are used to process transient reduction related material. The final section establishes the charter for operation of the Management Review Group.

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ATTACHMENT TO 1CANO39007 BACKGROUND The ability to produce electricity safely and economically is the primary goal of AP&L. Unplanned reactor trips inhibit accomplishing this goal.

Unplanned trips cost many thousands of dollars for replacement power and for increased repair costs associated with expeditious procurement and mai ntenance.- From a safety standpoint, each unplanned trip represents a challenge to safety systems and an increase in thermal, mechanical and hydraulic stresses on plant equipment. Although most reactor trips produce relatively benign consequences, the perceived safety issues associated with trips, by both regulatory agencies and the public, can cause adverse attention.

In 1984, the NRC published an analysis of the 1983 reactor trip statistics which concluded that a reduction in frequency of trips (and the potential-challenges to safety systems) should be a prime goal of each licensee. The Nuclear Utility Management and Resource Committee (NUMARC) responded to this concern by committing industry efforts to a 1985 average goal of no more than three unplanned automatic trips while critical for Units in commercial operation for three years or more. To accomplish this goal, NUMARC committed each utility to adopt practices and policies designed to reduce the number of automatic trips by taking actions including:

  • In-depth and thorough follow-up on all trips;
  • Development of action plans to correct those root causes and thereby to reduce the probability of future automatic trips.

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1CAf4039007 AP&L data indicate that both Units needed improvement. Table I shows the unplanned, automatic trip frequency for both Units from 1980 through 1987 ,

demonstrating that ANO performance has improved. The combination of AP&L's desire to improve performance further, and the HUMARC commitment, led AP&L to set specific trip related performance goals for 1986 through 1990. The 1986 NUHARC goal set a target of three trips per Unit. Unit 1 experienced two trips,'hus t meeting the goal. Unit 2, however, had five trips. The 1987 ANO goal called for two or less trips on ANO-1 and three or less on ANO-2.

Both Units met the goal. The AP&L goals for 1988 and 1989 were set to gradually approach the 1990 NUMARC goal. For 1990, the NUMARC and AP&L Goal is one or less trips on ANO-1 and ANO-2. AP&L believes the only way to meet these goals is to implement a program that provides corrective actions that address the root causes of reacter trips.

As stated in the Introduction, the Program has been expanded from its original' focus on trips to also address transients which may not necessarily result in-a trip since such transients can potentially have the same political and economical impacts as trips. Throughout the re-mainder of this Document, the word transient will be used, rather than

" trips and significant transients", etc. Only those transients for which a Unit Transient Report is generated by the Operations Assessment Group are addressed. These transients are defined in detail later, i-i i

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TABLE 1 4

AND TRIP HISTORY ANO-1 ANO-2 1983. 8 9 1984 3 15 1985 8 9 'l I

1986 2 5 1987 2 2 1988 1 1 1989 (to date) 2 1 I i

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'AP&L' EFFORTS TO DATE The following discussion is provided to document activity that has occurred or is occurring which= contributes to the transient reduction effort.

INPD invesiigations, as documented in INPO 85-011, Scram Reduction' Practices,. break.down scram contributors into five areas: ,

  • 1 Administration r
  • Maintenance
  • ' Surveillance / Testing
  • Operations
  • Design / Hardware There are two general areas in which the AP&L efforts have been focused.
  • The first is the implementation of programs .that are preventive in nature.

This involves aggressively reviewing data from a myriad of sources, understanding the synergistic relationship of this data to the five identified scram reduction areas, and implementing programs that address

.these concerns. This area attempts to address problems before they become *

. trip contributors.

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.The second general area is the event specific analysis. This involves the performance of thorough root cause determinations following each trip and certain transients and implementation of corrective actions to eliminate contributions to trips. The effectiveness of this effort can be measured by the improvements in-trip frequency to date.

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ATTACHMENT TO 1CAJ4039007 Preventive Efforts As may be expected, ' prevention' represents a very broad approach to transient reduction improvements and reacheri into every facet of nuclear plant operation. The following provides examples of the transient. reduction-measures taken at AP&L which are prevention oriented. These measures are divided into the five INP0 identified areas.

1. Administration
  • The ANO Operations Assessment Group (OAG) provides a means for assessment of operating experiences which include system, equipment, procedural, and human factors considerations.

Information is obtained at ANO from outside sources in order to properly assess the possible impact on safe and economic operation of the plant. The OAG also provides the means of channeling appropriate information of immediate importance to the affected groups and into the training program (e.g., maintenance technician, operator, STA, and requalification).

In addition to 0AG, other groups receive and process information pertinent to the Transient Reduction Program, as part of their routine business (e.g., AN0 In-House Event Analysis, Human Perfor-mance Evaluation System, Licensing, Planning and Scheduling, etc.).

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- ATTACHMENT TO 1CANO39007 Examples of external information sources reviewed are NRC Bulletins and Notices, Vendor Information Bulletins, INPO Significant Operating Experience Reports, INPO Significant Experience Reports, and Operations and Maintenance Reminders.

Internal information sources include Transient Report .

Condition Reports, NPRDS, SIMS Reports, Licensee Event Reports, and Control Room Logs.

  • Training is provided to not only meet the appropriate regulatory requirements, but also to ensure that personnel have an adequate understanding of job responsibilities and quality requirements, and have an up-to-date understanding of current operating experiences / requirements.

Training is an area of great interest to NUMARC and INPO, and, as such, has received considerable attention to ensure utilities have developed and accredited necessary programs. AP&L currently has

. ten (10) programs accredited including Operations, I&C Maintenance, Electrical Maintenance; Mechanical Maintenance; HP Chemistry, Radiological Protection, Tech Support and STA.

  • At present, the predominant information source reviewed for improvement is the B&W Safety and Performance Improvement Program (SPIP) and its Recommendation Tracking System (RTS). With the completion of the SPIP effort in September 1987, this Owner's Group sponsored program approved approximately 250 recommendations for evaluation by the B&W utilities. These recommendations are WP900001 Page 11 of 61

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l published in the RTS, a living document, which will be updated based on future BWOG activities. Some important modifications identified through this program were made to the ICS and MFW pump controls during the '1R7 refueling outage.

The CEOG is also formulating a scram reduction policy. Several tasks have been initiated to identify prevalent system contributors and provide a focus for joint CE-utility root cause information and data sharing. Items from the CEOG Program will be entered into this Program. Nuclear Design Services and 0AG also provide a common link between prevention analysis and event analysis. This helps to minimize the possibility of irconsistent actions by other departments and provides additional depth to the review process which is ultimately responsible 4 r selecting transient reduction activities for implementation.

2. Maintenance The following maintenance related activities were established to minimize the potential for inadvertent transients during maintenance activities.

-* Normal processing of job orders requires a Shift Operations Supervisor review to determine the acceptability of plant conditions for work to be performed.

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  • Operations-and Maintenance personnel perform, as necessary, pre-and post-maintenance and operability testing. Operations personnel and/or Scheduling personnel determine technical specification time limits for work, and identify and perform required surveillance testing after maintenance activities which correct equipment failures or which might change equipment r characteristics.
  • AP&L has participated in B&W's Transient Assessment Program (TAP) since 1981. Several tasks related to preventive maintenance programs are being implemented, with special emphasis upon feedwater control and turbine generator initiated events.
  • AP&L has a Planning and Scheduling Section (formerly the Work Control Center) which is responsible for scheduling maintenance activities and for detailed planning of significant or safety-related maintenance activities, and also for maintaining a detailed maintenance history for plant components. The Planning Section scopes the job to establish appropriate boundaries and to specify the technical requirements (EQ, Q, F, applicable procedures,

.etc.). The Scheduling Section determines if coordination with Operations is necessary, and maintains regular contact with Maintenance and Operations (as applicable) through the completion of the job.

  • A Preventive Maintenance Improvement Program has been established to identify necessary PM checks and their frequencies.

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3. Surveillance Testing i
  • A master testing schedule has been developed and maintained. This activity will be computerized and integrated into the Planning and Scheduling activities. *
  • Maintenance personnel are highly qualified and attend a wide variety of training (e.g. , vendor, systems training, skills center training,etc.).

These two activities minimize the potential for inadvertent trips ,

during surveillance tests.

4. Operations 1
  • Operations involvement is of key importance to maintenance activities and is specifically coordinated through the Planning and Scheduling.
  • - The installed Unit-specific simulators for ANO-1 and ANO-2, greatly enhance operator training. As plant modifications occur, 4 they are included in the simulator physical layout and response modeling. As an example, specific training in low power feedwater control techniques can be provided prior to startup if a significant amount of time has elapsed since the previous startup.

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5. Desian and Hardware
  • There are several mechanisms in place to identify transient related equipment failures and performance problems. Some of these are:

- Condition Reports

- Plant Engineering Action Requests

- Engineering Action Requests

- Licensee Event Reports

- Operations Assessment Group (OAG) Review of INP0 documents

- Nuclear Network Information

- NPRDS

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  • The Station Priority Review Committee is chartered to ensure repetitive equipment problems are resolved.
  • Nuclear Services (now Nuclear Operations - Design Engineering) reviewed the B&W SPIP recommendations, and with the assistance of the OAG, identified potential design modifications to the Station Priority Review Committee.

Event-Related Efforts By way of definition, event analysis is a more direct and measurable response- to transient occurrences than is prevention analysis. Specifically, this effort has as its primary goal to analyze transient data and to take corrective actions to reduce the probability of future transients and/or to improve plant performance during a similar transient. The fundamental steps required to accomplish this are: (1) comparison of actual plant performance to expected performance, (2) identification of root causes of deviations from expectations, and (3) development and implementation of action plans to address these root causes.

The OAG has the responsibility to evaluate all ANO trips and transients of greater than 100 MW to address the adequacy of operator actions and equipment performance, to prepare Unit Transient Reports, and to determine if events' or conditions at other facilities will have an impact on the safe and economic operation of ANO. (Additional definition of the scope and criteria can be found in AND Procedure 1000.38.)

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ATTACHMENT TO 1CAN039007 These evaluations are accomplished procedurally by four documents: Plant Impact' Reviews (PIR) Plant Impact Evaluations (PIE), Unit Transient Reports (UTR), and Condition Reports (CRs). These are defined as follows:

Plant Impact Review (PIR)

Plant Impact Reviews are performed by the Operations Assessment Group (OAG) to determine if events or conditions that have occurred or are existing at other facilities will have any impact on the safe operation of ANO.

Examples of external information sources reviewed are NRC Notices and Bulletins, Vendor Information Bulletins, INPO Significant Experience Reports (SER), and INP0 Significant Operating Experience Reports (SOER). The review is to ascertain the applicability of these conditions and the possibility of similar events at ANO and whether they are a direct (corrective acticn will be necessary) or potential (corrective action not necessary to protect ANO from an unsafe or undesirable condition) impact. The PIR is reviewed by the OAG Superintendent.

Plant Impact Evaluation (PIE)

A Plant Impact Evaluation presents the results of a review of an initiating document (e.g. , PIR or 10A) and lists recommended corrective action to

-correct undesirable conditions discovered in the review. The PIE is performed by the OAG and reviewed by the OAG Superintendent and the General Manager, Plant Technical Support and Assessment . Corrective actions are issued through the Station Action Tracking System via the General Manager, Plant Technical Support and Assessment.

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1CANO39007 This evaluation attempts to bring together the conclusions of the initial 1 review, and documents the root causes of the event stated along with ANO ,

deficiencies which could allow a similar situation.

Unit Transient Report (UTR)

This report is prepared by 0AG to explain the causes and responses of a significant reactor or secondary system transient. A reactor transient is defined as a power change greater than 10% full power in less than one minute, any unplanned reactor trip, or t. heatup or cooldown transient in excess of 100 F in one hour. A secondary system transient is defined as a power change in excess of 100 MWe in less than one minute or any unplanned turbine or feedwater pump. trip. A typical Unit Transient Report requires the collection'of a defined set of available information in order to assure reasonable assessment of the event and recommendations. Each of these i transients is reviewed by the Unit Significant Event Review Committee (SERC).

Action recommended by the SERC is included in the UTR and is issued to responsible parties via a Condition Report (CR).

The OAG also provides quarterly-(as a minimum) status reports of INP0 SOERs

-and SERs, and, on an as-needed basis, requests trend reports from the computerized scram event database. Other reports may be generated as deemed I: necessary to provide useful information to the appropriate management level.

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ATTACHMENT TO 1CANO39007 There are several procedures applicable to the collection and analysis of transient data. $ome of these are:

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  • " Condition Reporting and Corrective Actions" (1000.104) i i
  • "NRC Reporting" (106?.01)
  • " Shift Technical Advisor Duties and Responsibilities" (1010.03)  !
  • " Operations Assessment Program" (1030.29) which is the governing procedure for the conduct of business by the OAG.
  • "Significant Event Review Program" (1000.38) which provides guidance for transient review and reporting .

In addition to ANO, several General Office Sections have a roic in reducing transients, and have specific program responsibilities. Primary among these responsibilities is the function of reviewing transient-related materials received from external sources not specifically assigned to tha 0AG, and participating in industry activities.

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Specific examples of external information which may be handled by the i General 075 fee Sections are:

i INP0: evaluations NUMARC materials information queries  !

utility reports i

Owners Group: topical reports information bulletins owners group reports  ;

information requests scram program materials r

Special Interest state reports, queries Group: PSC requests intervenor actions t

EPRI: technical studies NSAC studies Commercial Sources: industry publicationr.

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ATTACHMENT TO 1CANggANSIENT REDUCTION PROGRAM As previously discussed, AP&L currently has a large set of activitiet.

ongoing to assist in the transient reduction effort. This Program is  !

intended to coordinate these efforts. The Program is limited in scope to the processing, evaluation and tracking of improvement recommendations. The Program formalizes these efforts and provides a systematic process. This ,

portion of the Program Document provides the upper-tier guidelines for the coordinated effort. Specific duties, responsibilities, and interfaces are assigned by this document. The Transient Reduction Guideline , .

Supplement A, describes the detailed process required at ANO and the General l Office to address transient related recommendations. The Management Review Group Charter, Supplement B, describes the rules for operation of that group.

Duties and Responsibilities

1. The Director, Nuclear Operations has overall responsibility for the Transient Reduction Program as part of his function to operate the nuclear plants in a safe and reliable manner.
2. The Superintendent, Operations Arsessment nas responsibility for the implementation of the Transient Reduction Program. He shall perform the following functions:
a. Designate a Transient Reduction Program Coordinator to assist him.

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b. Establish and Chair a Management Review Group whose members represent a diversity in experience (e.g. maintenance, operations, l engineering, etc.). (The responsibilities and description of this Group are discussed in Supplement B).
3. The Transient Reduction Program Coordinator is responsible for the ,

following functions:

a. Maintain the Transient Reduction Program Document. *
b. Develop and implement a guideline to provide the details of processing transient reduction related materials in conjunction with the Little Rock Coordinator.
c. Provide periodic written reports to management of the status of the Transient Reduction Program.
d. Provide written reports as necessary to provide the Program status to outside entities, such as B&W, CE, INPO, etc.
e. Document all transient related activities requiring a coordinated effort.

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f. Maintain contact with other AP&L sections from which transient reduction related materials might generate. The follow-up actions or corrective actions may require modifications or evaluations requiring coordinated efforts.
g. Establish a preliminary priority for action based on historical or political importance for review. i L
h. Review each recommendation prior to closing to ensure that the recommendation has been adequately addressed.
i. Establish and maintain the Transient Data Base.
4. The Little Rock Coordinator for the Transient Reduction Program shall perform the following functions:
a. Provide input to the Transient Reduction Program Coordinator for developing and implementing a guideline to provide the details of processing Transient Reduction related materials.
b. Ensure that Little Rock generated Transient Reduction recommendations are transmitted to the Transient Reduction Program Coordinator for processing.

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c. Assign evaluation or implementation responsibility to the applicable GO section. '
d. Track those items assigned to any GO section until complete.
e. Provide the Transient Reduction Program Coordinator with periodic ,

updates of the status of those items assigned to the GO.

6. The General Manager, Nuclear Quality has responsibility for monitoring the Transient Reduction Program periodically to ensure all recommended actions are documented in accordance with the Transient Reduction Guidelines.
7. The Operations Assessment Superintendent is responsible for ensuring that any transient reduction related recommendations generated as a result of evaluations or root cause determinations (e.g. , Unit Transient Reports, SOER's, etc.) are communicated to the Transient Reduction Program Coordinator for inclusion in the Program.
8. The Management Review Group shall:
a. Review each recommendation prior to the closeout to ensure that the disposition is technically correct, fully addresses the recommendation, and is adequately documented.

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b. Periodically review the status of the Program and any open items to ensure sufficient resources are being utilized to meet commitments.
c. Assist the Transient Reduction Program Coordinator in resolving problems with defining the scope of AF&L's response to a recommendation. -i
9. All Nuclear Operations personnel have the responsibility to ensure that, if they have a recommendation or concern which would provide a benefit to the company in transient reduction related matters, actions are taken to submit these recommendations to either the Transient Reduction Program Coordinator or the Little Rock Coordinator. This shall include concerns raised in Owners Groups or other industry groups. I As much as possible, this Program will use existing mechanisms, such as the EAR process and review by the SPRC to assign and prioritize Engineering actions. For those recommendations which require ANO action, memoranda and the action tracking system should be used to coordinate and track activities. .

Communications between ANO and the GO will be through single contacts to ensure effective coordination.

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ATTACHMENT TO 1CANO39007 CONCLUSION AP&L's Transient Reduction Program is intended to provide a formal, standardized approach for dealing with trip and transient reductior, activities. It provides a common method of processing recommendations related to transient reduction and a means of documenting each item from its input until final resolution. By standardizing the process for evaluating transient reduction related recommendations, AP&L will be able to efficiently utilize available resources and meet the corporate trip reduction goals.

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ATTACHMENT TO 1CANO39007 1.0 PURPOSE The objective of these guidelines is to provide for the detailed operation of the Transient Reduction Program. The Transient Reduction Program Document provides a more general program overview and directs this Transient Reduction Program Guideline be established to clearly delineate the detailed program operation and process. These guidelines control detailed Transient Reduction Program activity (receipt of recommendations, evaluations, tracking actions / reviews, close-outs, etc.) at both the G.O. and ANO.

2. 0 REFERENCES 2.0.1 Transient Reduction Program Policy Statement, Directive A4.601.

2.0.2 Transient Reduction Program Document, NP-40 2.0.3 INPO 85-011, Scram Reduction Practices, 5/85 2.0.4 BWOG - Recommendation Tracking System (RTS) Reports 2.0.5 Nuclear Operations Priority System NS-86-0488.

2.0.6 Design Change Initiation and Control Procedure, LRNP-201.

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c' go ATTACHMENT TO i 1CANO39007 3.0 RESPONSIBILITIES l 3.0.1 Per Transient Reduction Program Document. l 4.0 DEFINITIONS / ABBREVIATIONS 1

4.0.1 TRPC Transient Reduction Program Coordinator.

'1 4.0.2 MRG Management Review Group 4.0.3 EAR .,

Engineering Action Request 4.0.4 PSR -

1 Project Scoping Report 4.0.5 DCP Design Change Package .

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4.0.6 BgDG/CEOG l

Babcock and Wilcox Owners Group / Combustion Engineering Owners l Group 1

4.0.7 SPIP  ;

1 Safety and Performance Improvement Program - The BWOG program established to evaluate the performance improvement of the B&W designed NSSS plant. Recommendations developed by SPIP l are included under the Trip Reduction Category-in the RTS.

4.0.8 G.O.

General Office - Little Rock (MCS, EIC, NDS) 4.0.9 VPN Vict President, Nuclear 4.0.10 LRC Little Rock Coordinator 4.0.11 SPRC Station Priority Review Committee WP900001 Page 31 of 61 Rev. #2

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4.0.12 RTS r

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Recommendation Tracking System - The BWOG Tracking System 4

used to identify, document and track the status of technical  ;

i recommendations made by BWOG Committees and Task Forces to i the utilities of the BWOG.

4.0.13 OAS Operations Assessment Superintendent.

5.0 GUIDELINE The following outline identifies the processing of a recommendation 4

from receipt to final close-out.

5.1 Receipt of Recommendation 3

5.1.1 Assion Initial Status Category The TRPC will assign the initial status of " Evaluating  ;

for Applicability" to allInewly received recommendations. (The status categories have been adopted from the BWOG-SPIP RTS, see reference 2.0.4).

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E ATTACHMENT TO YV 1CANO39007 1 5.1.2 Transient Reduction Program Trackino System ana Reports l

l This computerized Tracking System has been established to achieve the following objectives: I

a. To provide various custom reports for internal and external company use.

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b. To track due dates for action items.
c. To provide a focal point for immediate status -l update of each recommendation as it progresses l through the process.

5.1.3 Transient Reduction Program Files The program files have been established to provide permanent documentation of the work activities required to resolve recommendations. These files are designed to  !

provide a chronological record of events from receipt of the recommendation to final close-out. Each file is intended to provide a stand alone, independent support of the current status of each recommendation in an  :

auditable form. Applicable memoranda, EAR's, -

correspondences, close-out memoranda, etc., are a permanent part of these files.

When the TRPC receives a new recommendation a Transient Reduction File is opened and a copy of the recommendation is placed in the file.

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5.1.4 Due Dates Due dates will be assigned for the completion of each activity associated with a transient reduction recom-mendation. These due dates will be based on discussions  !

with the cognizant department. In some cases, the l recommendation will need to be factored into existing workloads via a forms 1 scheduling process (e.g. the

Master Engineering Schedule) and therefore may not be ,

assigned a due date immediately. The assignment of a  ;

due date should be made as quickly as possible. Once these dates are set, any extensions will be justified 4 in writing to the TRPC. This will ensure that the extension is documented and is based on conscientious decision rather than oversight.

  • If action on an item is complete and the recommendation is awatin0 MRG review, the date of the next MRG meeting wiil be the new due date. The TRPC will provide docu-  :

mentation of this due date.

5.2 Initial Recommendation Evaluation for Applicability The TRPC will review and analyze new recommendations. This analysis will include review of items such as SAR, Technical Specifications, system descriptions, etc., as well as conduct l conversations with cognizant groups (i.e., Mechanical Engineering, I- I&C, Operations, Maintenance, etc.) and others as necessary.

i Based on the results of this analysis the TRPC will make a ,

determination as to which of the following categories (Sections 5.2.1, 5.2.2 or 5.2.3 as applicable) the recommendation will apply: '

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!' 5.2.1 Applicable Based on the above analysis (Step 5.2) the TRPC determines that the recommendation is applicable (i.e., the situation i'

or equipment recommended to improve exists at either or both Units).

5.2.1.1 Prioritization The primary objective of prioritization is to utilize the expenditure of resources in the areas which will yield the greatest return on the reduction of Transients. The TRPC will generate a priority (by utilizing various inputs such as AP&L's computerized Transient Data Base, etc.) to determine the most prudent order in which recommendations will be reviewed. The TRPC will proceed as described by step 5.3.

5.2.2 Not Applicable / Superseded / Rejected Based on the above analysis (Step 5.2) the TRPC determines that the recommendation is Not Applicable (i.e. the situation or equipment recommended to improve does not exist at either Unit, etc.), Superseded (one recommendation intent is fully encompassed by another recommendation, etc.) or Rejected (benefits gained do not justify effort, etc.).

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5.2.2.1 TRPC Preparts Justification l

The TRPC will prepare a formal written ,

justification supporting his conclusion. This justification will be submitted to the MRG for review and acceptance. j i

5.2.2.2 MRG Review / Acceptance The MRG reviews the TRPC's written l justification for acceptance. The MRG will accept or not accept this justification.

5.2.2.2.1 Accept The MRG has performed a thorough review of the TRPC's written justification and accepts the .

analysis as is. The Chairman, Management Review Group will sign and date the concurrence statement indicating the MRG's acceptance.

Proceed to step 5.7.

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1CANO39007 S.2.2.2.2 Not Accept The MRG has performed a review of

, the TRPC's written justification )

and does not accept the analysis.  ;

The MRG must justify their conclusion as support to generate further actions l<

to provide a more thorough resolution.

The Chairman, MRG will transmit its conclusion to the TRPC for action .

(return to step 5.2).

5.2.3 Requires Clarificati,on If af ter a detailed review the TRPC cannot determine conclusively the intent or full meaning of the '

recommendation he should request additional clarification. This category is reserved for those recommendations that are ambiguous, unclear, lack continuity, contradictory, etc.

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5.2.3.1 TRPC Evaluates and Submits Recommendation )

to MRG The TRPC does a review and analysis to determine the recommendation intent as best he can. He will review the recc=endation source document if applicable, discuss with other  !

L utilities, B&W/CE, Operations, Engineering, ,

BWOG/CEOG subcommittee members, etc. as necessary.

Based on this analysis the TRPC will prepare a documented justification and submit to the MRG his interpretation as to the meaning and intent of the recommendation.  ;

5.2.3.2 MRG reviews / accepts /clarifiet.

The MRG will review the TRPC's interpretation and either accept it as is or clarify via their own interpretation. The conclusions of the MRG will be documented and returned to the TRPC for action. The TRPC will proceed as ,

described by step 5.2.

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'! 5.3 TRPC Identifies Appropriate Oroanization for Action Once the TRPC has determined that a recommendation is applicable it is ready to be actioned for resolution. The TRPC will conduct discussions with various cognizant groups to determine which department would be most appropriate for action. A discussion of the recommendation concerns, how it will be dispositioned, etc.

will take place with the responsible Plant Manager, prior to issuing I any formal action requesting resolution. Based on the results of these discussions the TRPC will make a determination as to which of the following categories (steps 5.3.1, 5.3.2 or 5.3.3 as applicable) will apply:

5.3.1 TRPC Will Provide Analysis to Resolve Recommendation The TRPC will perform the necessary analysis and provide a resolution which will satisfy the recommendation. The TRPC's review and analysis may involve discussions with the BWOG/CEOG subcommittee member, Operations, B&W/CE, Engineering, etc., or review of applicable procedures, FSAR, Technical Specifications, System Descriptions, etc. as necessary. The TRPC will enter a new change of status into the Transient Reduction Program Tracking System. The TRPC will formalize his analysis and proceed l as described in step 5.5.

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ATTACHMENT TO 1CANO39007 5.3.2 TRPC Actions the ANO Staff to Provide Resolution The TRPC will action the appropriate ANO group to provide a resolution to satisfy the recommendation.

This will be done under the authority of the responsible Plant Manager via the Plant Action Tracking System.

A discussion of the recommendation concerns and how it will be dispositioned will take place prior to issuing any formal request for resolution.

Due dates for this action will be established via these discussions. The TRPC will proceed as des-cribed in step 5.4.

5.3.3 TRPC Issues Action To Little Rock Coordinator The TRPC will action the Little Rock Coordinator typically by a memorandum to provide a resolution to satisfy the recommendation. A discussion of the recommendation concerns and how it will be dispositioned will take place prior to issuing any formal request for resolution. Due dates for this action will be established via the Master Engineering Schedule. The Little Rock Coordinator will action the technically cognizant department at the G.O. (Engineering, etc.)

via an EAR to generate a PSR.

NOTE: EAR's and PSR's are discussed throughout this document. However, memorandums may be used to generate studies or evaluations.

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o . ATTACHMENT TO ICAf4039007 The PSR is a study, typically resulting in several possible resolutions. The PSR should conclude by recommending one of these resolutions for implementation.

A priority of 05 (See Reference 2.0.5) will te established on all EAR's requesting PSR's. The TRPC will assign a new status of " Evaluating for Implementation" to the Transient Reduction Program Tracking System. When the PSR has been completed it will be transmitted to the TRPC for review and acceptance.

5.3.3.1 Little Rock Coordinator Identifies Appropriate G.O. Organization For Action The Little Rock Coordinator will perform a thorough review and determine if he will provide the analysis, or action the recommendation to a technically cognizant group. When the Little Rock Coordinator has determined who will be actioned he will initiate an EAR to track the work progress.

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- ATTACHMENT TO 1 cat 4039007 5.3.3.2 G.O. Organization Provides Requested Action The assigned G.O. organization provides the implementation evaluation.

5.3.3.3 Little Rock Coordinator Reviews Resolution The Little Rock Coordinator will perform a thorough review of the resolution prepared by the technical group. The Little Rock Coordinator will accept (proceed to 5.3.3.3.1) or not accept (proceed to 5.3.3.3.2) the resolution.

5.3.3.3.1 Little Rock Coordinator Accepts the Resolution The Little Rock Coordinator has reviewed the evaluation and accepts it as is. The Little Rock Coordinator has approved the evaluation as satis-factorily meeting the recommendation.

The Little Rock Cordinator transmits it to the TRPC for review. The TRPC proceeds as described in step 5.4.

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ATTACHMENT TO 1CANO39007 5.3.3.3.2 Little Rock Coordinator Does Not Accept Resolution The Little Rock Coordinator has thoroughly reviewed the resolution and does not accept it. The manage-ment involvement is now increased by the Little Rock Coordinator generating an action via the TRPC and the MRG chairman to the appropriate Technical Cognizant Manager. This action will request that further work be performed to ensure that the resolution will satisfy the recommendation. A due date will be established to complete this action. The Little Rock Coordinator will proceed as described by step 5.3.3.1.

5.4 TRPC Reviews Resolution For Acceptance The TRPC will thoroughly review all resolutions (PSR's, site technical resolutions, etc.) to determine if the scope will satisfy the recommendation. The TRPC will accept (proceed to

( 5.4.1) or not accept (proceed to 5.4.2) the resolution as being satisfactory. ,

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( ICANO39007 i 5.4.1 Accept r The TRPC has performed a thorough review and concludes that the resolution is satisfactory (even though it may not resolve the full recommendation intent). The TRPC will determine if the resolution fully or partially satisfies the recommendation intent and then proceed to  ;

the next applicable step (5.4.1.1 or 5.4.1.2) l i

5.4.1.1 Resolution Fully Satisfies the Recommendation Intent The TRPC concludes that the resolution fully satisfies the recommendation intent.

5.4.1,1.1 Resolution is Actioned to be Implemented The TRPC will direct the G.O. or the site as applicable to implement the >

resolution.

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ATTACHMENT TO 1CA,NO39007 5.4.1.1.2 G 0 is Actioned to Implement the The TRPC issues action to the LRC to implement the accepted resolution  ;

i- action. If the implementing action i involves a design change, the approved  ;

EAR which generated the PSR will n .

generate another EAR to develop a DCP.

The Station Priority Review Committee (SPRC) will establish the priority I

for implementation. The G.O. will issue the EAR /DCP as delineated by Design Change Initiation and Control Procedure, GTEP-201.

5.4.1.1.3 Little Rock Coordinator Monitors Action The LRC issues actions to the G.O. for ,

other than DCP items and monitors the implementation actions of the G.O.

whether these be DCP or non-DCP related, e r

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1CANO39007 5.4.1.1.4 LRC Transmits Implementation Results  ;

to the TRPC Once G.0, implementation actions are complete, these actions are forwarded by the LRC to the TRPC for closeout.

If site implementation is required for a DCP, action progresses according to l step 5.4.1.1.6, otherwise action progresses with step 5.4.1.1.9.

I 5.4.1.1.5 TRPC Issues Implementation Action at ANO The TRPC will issue the necessary action to implement the approved recommendation P under the authority of the responsible Plant Manager by using the Plant Action Tracking System. The TRPC will assign a .

new status of " Implementing" in the Transient Reduction Program Tracking System.

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ATTACHMENT TO I 1CANO39007-5.4.1.1.6 Site Implements Action and TRPC Monitors Implementation

.The assigned plant organization implements e,_ the recommendation. The TRPC monitors that the recommendation is. implemented fully and on a timely basis.

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5.4.1.1.7 _ Recommendation is Implemented  !

Once the recommendation is fully implemented, the TRPC proceeds-to step 5.4.1.8. The assigned organization transmits the resolution to the TRPC.

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@ 5.4.1.1.8 The Responsible Plant Manager i

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For non-DCP implementation of recom-mendations, the responsible Plant Manager will review the site implementa-tion actions for adequacy prior to preparation of the close-out memos.

If the actions are satisfactory, the TRPC will proceed according to step 5.4.1.1.9, otherwise he will return  :

to step 5.4.1.1.6.

5.4.1.1.9 TRPC Reviews Implementation Documentation The TRPC will perform a review to ensure that the modification was implemented as originally planned. Also any changes WP900001 Page 48 of 61 Rev. #2

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which may have occurred during the implementation process'must be reviewed by the-TRPC. The TRPC's review will ensure that any change during implementation j will not have had sufficient impact on-the resolution such that the recommendation intent is no longer satisfied. The TRPC will discuss the results of the review.

and accept (proceed per 5.4.1.1.10)'or not accept (proceed per 5.4.1.1.11) the' installation documentation.

5.4.1.1.10 Accepts Based on the thorough review by the TRPC, the implementation documentation has been accepted. l The TRPC will proceed as described by.

step 5.5.

5.4.1.1.11 Not Accepted-Based on the review by the TRPC, the j implementation documentation has not -!

been accepted. The TRPC will proceed as described in step 5.4.2.1.

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-1'C AJ4039007 5.4.1.2 Resolution Partially Satisfies the Recommendation Intent The TRPC has concluded that the resolution partially satisfies the recommendation intent and agrees with_this approach. The TRPC will transmit i this resolution to the MRG for review and concurrence.

5.4.1.2.1 MRG Reviews Resolution The MRG will review the resolution and accept (proceed to 5.4.1.2.2) or not accept (proceed to 5.4.1.2.4) the re-solution as satisfactory to resolve the recommendation.

5.4.1.2.2 MRG Accepts the Resolution s

The MRG reviews the resolution and accepts it l

, as is or approves a resolution for imple-mentation which does not satisfy the full recommendation intent.

The Chairman,'MRG notifies the VPN that'a L resolution which does not satisfy the full l recommendation intent will be implemented.

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b. ' 1CANO39007- t The TRPC will proceed'as described in '

step 5.4.1.1.1.- ,.

i 5.4.1.2.3 MRG Does Not Accept the Resolution s

The MRG reviews the resolution and does not of, accept it as satisfactorily resolving the recommendation.

The MRG must justify their conclusion as'-

support to generate actions to provide a more thorough resolution. The Chairman, MRG will transmit their justification to the TRPC for action. ,

The TRPC will proceed as described in step 5.4.2.1.

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' 5 .~ 4 . 2 . Not Accept The TRPC performs a review of the resolution (PSR, site resolution, etc) and concludes that the resolution does not satisfy'the recommendation concern. The TRPC identifies this~ concern to the Superintendent, Operations Assessment.

5.4.2.1 Superintendent, Operations Assessment Takes Action Upon notification by the TRPC that a satisfactory resolution for a recommendation cannot be reached, the Superintendent, Operations Assessment will I =, take appropriate management action to resolve l- this issue.  !

l Resolution and/or direction should be provided to the TRPC. The TRPC proceeds as described in step 5.3.

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'1CAf4039007-5.5 CLOSE-0VT MEMORANDUM For each recommendation which has an accepted resolution, the TRPC shall generate a formal close-out memorandum. This close-out memo-randum format is shown in Attachment B and is issued on yellow paper for ease of differentiation'from other file documentation. This for-mat is implemented for the purpose of providing a " stand-alone" document supporting that the recommendation has'been satisfied. Sufficient documentation, references, quotations, etc. , should be included throughout each close-out memorandum. .This will provide a clear, concise, orderly, and logical path of events which have been utilized

  • to support the resolution. In addition, a very rapid interpretation of the recommendations history of events and the justification for the resolution can easily be acquired. The close-out memorandum has two sign-off concurrences. One for the Transient Reduction Program Coordinator and another for the Chairman, Management Review Group.

The MRG will proceed as described in step 5.6.

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u c ATTACNMENT TO 1CANO39007 5.6 MRG Review / Acceptance of Close-out Memorandum All close-out memoranda that have the TRPC concurrence are to be submitted to the Management Review Group for review and acceptance. The Management Review Group will review all close-out memoranda for adequacy of the resolution to satisfy the recommendation and determine if the close-out' memorandum is acceptable (proceed to 5.6.1) or unacceptable (proceed to 5.6.2).

5.6.1 Accept The MRG has thoroughly reviewed the close-out memorandum and has accepted it as is. The Chairman, Management

-Review Group will sign the concurrence statement in the close-out memorandum indicating the MRG acceptance. The MRG will proceed with step 5.7.

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5.6.2 Not Accept If-after review the Management Review Group does not concur that the close-out memorandum satisfies the recommendation it w G1 be returned to the TRPC for appropriate disposition. The MRG must provide to the TRPC justification for not-accepting the close-out memorandum. This justification will become a permanent record in the Transient Reduction Program Files and is required to support any additional work necessary to satisfy the recommendation intent. The TRPC will proceed as described by step 5.4.2.1.

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j. 5.7 MRG Transmits the Close-out Memorandum The MRG shall transmit the accepted recommendation close-out  !

memorandum to the TRPC with all concurrences signed and dated.

5.7.1 The TRPC will administratively control the memorandum  !

p distribution and include the original close-out .,

memorandum as a permanent record in the Transient l l Reduction Program Files. The completed memorandum shall be sent to the document analyst for DMS entry. I i

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ATTACHMENT TO 1CANO39007-To provide feedback, notification of the close-out will be sent to the recommendation originator. The TRPC will assign the final appropriate status (Closed / Operable, Closed /Not Applicable, Closed / Superseded, etc.) to the Transient Reduction Program Tracking System.

5.7.2 For any item where final disposition is Closed / Rejected,

< , dC% . regardless of reason, a memorandum shall be sent to the Vice President, Nuclear, informing him of the MRG's decision.

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m j.y sATTACHMENT TO M 1CANO39007-ATTACHMENT A-

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MEMORANDUM TO:- Chairman, Management Review Group FROM: -Transient' Reduction Program Coordirator

SUBJECT:

Close-out of Recommendation

REFERENCES:

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SUMMARY

II. CLOSE-0VT OF RECOMMENDATION A. RECOMMENDATION B. RESOLUTION TO RECOMMENDATION C, EVALUATION!0F RESOLUTION TO RECOMMENDATION D. CONCLUSION E. CONCURRENCE After review of the above outline I concur that this recommendation has been satisfied. I recommend that this close-out memorandum be forwarded to the Management Review Group for review and approval.

TRANSIENT REOUCTION PROGRAM COORDINATOR DATE After review of the above outline the Management Review Group concurs that this recommendation'has been satisfied.

CHAIRMAN, MANAGEMENT REVIEW GROUP DATE i

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ATTACHMENT TO L 1CANO39007 SUPPLEMENT B MANAGEMENT REVIEW GROUP CHARTER 1

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H ATTACHMENT TO 4 1CANO39007

= Arkansas Power and Light Company has a stated objective to significantly reduce the number of transients and plant trips which occur at Arkansas Nuclear One. This objective has been established to further improve the safe and economic performance of that facility. To achieve this objective AP&L has undertaken a major program, called the Transient Reduction Program, which will identify, evaluate and implement a number of administrative, operational and design changes to reduce the likelihood of a plant transient. The core of actions to be considered will come from the B&W Owners Group Safety and Performance Improvement Program (BWOG SPIP). The initial objectives were to evaluate these actions for applicability to Unit 1- by June 1988, and to implement those actions that were applicable by the end of 1R9. All of the issued recommendations were evaluated by June 1.

Implementation of the applicable recommendations, however, will be governed by the available resources. i The Transient Reduction Program Directive A4.601 establishes why AP&L has the Program, and makes known senior management's commitment to the Program.

It further calls for the development of a Program Document, NP-40, to describe the background for the Program and provide for the upper tier guidelines including specific duties, responsibilities and interfaces. This supplement to the Program Document establishes the Management Review Group. Membership l .in this group shall be approved by the Vice President, Nuclear and should I

represent a cross-section of the major Nuclear Departments. This approval I

shall be documented.

The Charter of the Transient R.? duction Program Management Review Group is to:

1. Provide review and concurrence of decisions made concerning the applicability of Transient Reduction Program Recommendations to Arkansas Nuclear One. When necessary, this may include clarifying the intent of a recommendation or resolving problems in defining the scope of AP&L's response to a recommendation.

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2. Provide review and concurrence that transient reduction closeout actions are technically correct, fully address the recommendation, and are adequately documented for later audit and referral.
3. Periodically review the status of the program to' ensure that resources are being dedicated properly to meet AP&L's commitments.

~This also includes providing input to the SPRC on the program's -

schedules and goals to aid in setting appropriate priorities.

In order to implement t'eh above charter, the Management Review Group will review documents provided to-it by the Transient Reduction Program Coordinator. The MRG will review recomiendations considered by the TRPC

- prior to their closeout regardless of the closeout category (i.e. ,

closed / operable, closed /not applicable, closed / rejected, closed / superseded or closed /not evaluated).

The MRG will meet periodically to approve or reject the closeout actions.

The meetings will require participation of at least four members. The decisions of the MRG shall reflect the views of at least 2/3 of the group l present. The Superintendent, Operations Assessment Group shall serve as the 1

l Chairman and the TRPC shall serve as the Secretary for the group. The l following standard meeting agenda will be used:

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1. Program status - Review of overall status.

' 2. Review of new items - Delineation of any items added to the program since the last meeting.

3. Review of changed items - Review of items which changed reporting.

status since the last meeting.

4. Follow-up on items generated at previous meetings - (self explanatory)

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5. Problem areas - Open session 1)r the TRPC to present any problems

'to the group for resolution. This includes obtaining clarification of the intent of a recommendation or defining the -

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limits of AP&L's efforts to resolve an issue.

6. Closeout - Review and concurrence that an item has been resolved and that the TRPC has adequately documented the effort.

Members of the MRG who are also members of the SPRC are responsible for assisting the Transient Reduction Program Coordinator in providing input '

for priority setting to the SPRC.

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