ML20044F308

Rev 0 to Sequoyah Nuclear Plant Restart Plan.

ML20044F308
Person / Time
Site:	Sequoyah
Issue date:	05/20/1993
From:	Fenech R TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20044F307	List: ML20044F305 ML20044F308
References
PROC-930520, NUDOCS 9305280005
Download: ML20044F308 (108)

Text

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i TENNESSEE VALL.EY AUTHORITY I i

SEQUOYAH NUCLEAR PLANT l

l RESTART PLAN 1 l

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. i REV.O  ;

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i APPROVED BY: MJ8bA </lo/S.3 Site Vice President /Date b

9305280005 DR 930520  !

p ADDCK 05000327 'I PDR

SEQUOYAH RESTART PLAN REVISION LOG DESCRIPTION OF REVISION REV. LEVEUDATE

1. Initialissuance 0 /May 20,1993 1

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SEQUOYAH RESTART PLAN TABLE OF CONTENTS ,

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I. BACKGROUND '

II. RESTART PLAN OBJECTIVES III. APPROACII IV. RESTART FOCUS AREAS A. BALANCE OF PLAhT B. OPERATIONS C. PROGRAMS D. BACKLOGS - WORK PRIORITIZATION ,

E. PERSONNEL, ORGANIZATION AND CULTURE F. CORPORATE / SITE INTERFACE V. PROCESSES A. RESTART ITD1 IDENTIFICATION B. MANAGDIENT RESTART REVIEW COMMITTEE  :

C. RESTART LIST D. BACKLOG REVIEW COABIFITEE {

E. SYSTDI READINESS F. DEPARTMENT READINESS G. SITE READINESS VI. ASSESSMENTS /OVERSIGIIT  ;

A. RESTART PLAN ADEQUACY B. RESTART PLAN IMPLDIENTATION & EFFECTIVENESS l C. ASSESSMENT CAPABILTIY VII. CLOSURE & DOCUMENTATION i

VIII. POSTRESTART - SITE BfPROVDIENT PLAN l

IX. REFERENCES X. FIGURES I XI. APPENDICES j i

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1. BACKGROUND The Sequoyah Nuclear Plant (SQN) units were shut down in March 1993 following a rupture of a 10-inch, Unit 2, No. 2 extraction steam line to a No. 2 feedwater heater. Significant weaknesses were identified in the SQN erosion / corrosion (E/C) program that ultimately led to unacceptable thinning and the subject rupture at power. A Confirmatioe of Action Letter (Reference 1) was issued by NRC that documented agreements between TJA and NRC (see Reference 2 TVA letter) regarding actions to be taken before the restart of either unit. The actions addressed the evaluation of the specific event, E/C piping evaluation and repairs, E/C program upgrade, and review of other technical programs for similar potential weaknesses.

Prior to this event, a number of weaknesses in SQN's performance had been identified that resulted in regulatory nancompliances, adverse impacts on safety system availability, and plant trips and transients. Targeted improvement efforts had not been effective in achieving the requisite levels of improvement. In evaluating past performance and events, common weaknesses continued to be identified in: control of configuration, control of work, sensitivity to and focus on the balance of plant (BOP), personnel performance relative to expectations, and program ownership.

At the 'ime of this event, actions were underway to carry out a comprehensive Site Imp ament Plan (SIP), which includes broad initiatives both to address specific weaknes::es (identified both internally and externally) and to target those arezs most critical to overall TVA Generating Group objectives. Several specific ongoing initiatives included conducting a comprehensive Secondary Plant Reliability Study, restructuring and reorganizing implementation and ownership for specific site technical programs, and concentrating ,

additional management talent and focus on improvements in the Operations department's performance. Accordingly, these same key focus areas - BOP, Technical Programs, and Operations department's performance - were identified for improvement action implementation before restart of the units. Weaknesses in these areas have been major contributors to past challenges to effective plant operations. .

In analyzing the underlying causes of performance weaknesses byer the past several years, i i

two key areas, both involving management effectiveness, were identified: ineffective resource management and ineffective personnel / management performance. Several  :

improvement areas have been targeted for short-term focus, including reducing backlegs,  !

improving work prioritization, clarifying the interface between the site and corporate ,

organizations, and conti.auing efforts to elevate overall site workforce effectiveness t (people / culture / organization). In sum, restart initiatives were identified to correct not only i the specinc causes for the shutd:wn but also to reduce impediments to effective plant q operations following restart. ,

A " restart list" containing specific de: ailed restart actions was developed utilizing input frca  !

a variety of sources. These included E/C associated corrective actions including technical l I

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f program reviews, management review of the SIP areas (which included BOP and Operations improvement action plans), soliciting feedback on significant problems from key employees [

in targeted departments, review of internal and external reviews, review of backlog or open items / issues, and system design reviews in targeted areas.

As specific potential restan actions were identified, a Management Restan Review l

Committee (MRRC), chaired by the SQN Site Vice President, was established to review and approve (or disapprove) potential restan item / issues. Restan criteria were developed for use  !

in screening potentialitems and evaluating the merit of those specific items. The criteria j focused on nuclear safety, plant reliability, and operational impacts.  ;

t A large number of assessment / review efforts were identified to assist in identifying problems, [

evaluating the adequacy of the restart initiatives, assessing the effectiveness ofinitiatives, and  ;

assessing readiness for restan. These assessments / reviews included a review of recent events and trends by SQN management and the Institute of Nuclear Power Operations (INPO); team I reviews of selected technical program areas, reviews by the Nuclear Safety Review Board l (NSRB); a high-level, Senior Restart Oversight Group using experienced nuclear industry managers; a Restart Readiness Team review of the Operations department's readiness; and a i variety of site and corporate reviews in targeted areas by Nuclear Assurance. f The development of this integrated SQN Restart Plan was initiated to fully develop the above ,

efforts and to provide an integrated framework for consistent, effective implementation. ,

II. RESTART PLAN OBJECTIVES ,

The overall objectives of the SQN restart efforts are to remove or reduce barriers to effective ,

plant operations and lay the foundation for continuing postrestan improvement.  :

The overall objectives of the SQN Restan Plan are to ensure the comprehensiveness of the restart efforts; to provide an integrated framework for consistent, effective implementation of i

those efforts; and to assist in the management and communication of those efforts. This document summarizes key initiatives; extensive supporting detail is referenced as indicated,  !

e.g., detailed implementation schedules, workoff curves, and summary repons. l This plan, including revisions, is issued and approved by the SQN Site Vice President.

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III. APPROACH l The overall approach to the achievement of the Restan Plan objectives is to integrate and l build on the multiple ongoing efforts described above. This includes: identification of key i i

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focus areas for improvement based upon the analysis of performance problems and j underlying causes, identification of restart actions and scope utilizing documented restart evaluation criteria consistent with Restart Plan objectives, development of processes to l facilitate and ensure the comprehensive and effective implementation of restart efforts consistent with Restart Plan objectives, utilization of assessments to verify effectiveness and  ;

readiness for restart, and integration of the restart efforts with the postrestart overall Site i Improvement Plan. [

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The SQN Restart Plan methodology and integration of efforts are depicted in Figure I.

Detailed descriptions of each facet of this plan are provided in Sections IV - VI. In general overview, potential restan issue identification results from a variety of sources, as discussed in Section I, and potential restart items are evaluated against the restart evaluation criteria  !

(see Section V.A) and reviewed by MRRC before being added to the restart list (see Sections V.A and B). Restart list hardware items are forwarded to the outage management team, and software items are assigned to responsible department owners. Restart readiness will be [

principally comprised of integration of system readiness affirmations (hardware) and  !

depanment readiness affirmations (e.g., software, programs, processes, and people). Restart  !

i activities in key focus areas such as the BOP, programs, and the Operations department's  :

performance feed into these two readiness processes. Restart readiness will not only address  !

restart activities but adequacy of postrestart plans as well. Multiple assessments are bemg  ;

used to assess restart plan adequacy, restart plan implementation, and restart readiness.

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IV. RESTART FOCUS AREAS i

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This section will address each restart focus area. Both hardware and software elements are  !

addressed. In many cases improvement plans / initiatives will be continuing past restart.

Processes have been established as described in Section V to establish the basis for restart readiness, f

i IV.A BALANCE OF PLANT (BOP) t Over the past several years, an increasing number of plant transients and reactor zips have {

resulted from secondary plant problems. Causes have included unexpected hardw2re ,

failures, marginally designed or degraded system / component performance, and ineffective application of programs / processes. Insufficient focus / priority has been provided to the ,

secondary plant to achieve effective, reliable operation. l Multiple reviews have been conducted to ensure accurate identification of problem areas.

These included INPO assistance (Reference 3), a comprehensive Secondary Plant Reliability l Study (Section IV.A.1), an independent Secondary Plant Design Review (Section IV.A.2), i reviews of technical program areas as applied to the BOP (Section IV.A.5), and performance j i

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evaluations of BOP' work by the Nuclear Assurance organization (Section IV.A.6).  !

The objectives 'of restart activities associated with the BOP include improving material condition and plant reliability, strengthening control of work for secondary plant activities, and increasing overall site focus on secondary plant performance.

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I l Implementing initiatives to address these objectives include the following areas:

l IV.A.1 Secondary Plant Reliability Study In January 1993, a Secondary Plant Reliability Study was initiated to provide a structured, l prioritized approach to effecting secondary plant performance improvements. Specific objectives included understanding the causes ofincreased contribution of the secondary plant to trips /runbacks/ transients, identifying points of single component failure requiring less than  ;

full power to repair, and providing appropriate recommendations to site management. This  :

study was conducted using a multi-organization Sequoyah team. Review elements included the allocation of technical, maintenance, and budget resources (work prioritization relative to primary plant); trips /runbacks/ power reductions; trip logic review for single failure points; control of work on the BOP; and successful utility experience. The evaluation process involved collecting SQN and industry data; conducting specific department reviews; reviewing management controls and processes; and analyzing data. Recommendations were l ,

l evaluated for cost effectiveness and priority, and categorized by action type, e.g., procedure-  ;

changes or hardware changes.  :

This study has been completed and the final report will be issued prior to restart. Key restart actions resulting from this study included modifications to heater drains and vents (piping and valves), feedwater system (controller relays and solenoid valves), control air (receiver drain and copper unloader lines), switchyard (generator breakers and Buckholtz relays),

i turbine /genemtor (turbine runback pressure switches and volts / hertz relay), condensate demineralizer (replace and upgrade valves), and the electrical system (vitalinverter transfer i

switch and vital battery test breaker). Postrestart items involve lower priority modifications and recommendations for focusing preventive maintenance activities. These items are being. ,

integrated into the overall SIP.

In addition, the results of this study are being integrated into the ongoing improvements in the site work prioritization process and the ongoing Reliability Centered Maintenance (RCM) program.  ;

i IV.A.2 Secondary Plant Design Study As a funher extension of the inhouse reliability study, a BOP system design review was -]

conducted by Stone and Webster Engineering Corporation (Reference 5). The review was

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1 performed by an experienced light water reactor (LWR) BOP systems and heat balance engineer who had not previously been exposed to TVA practices or implementation. This  !

effort was initiated to identify additional problems or vulnerabilities. Observations were j requested regarding features that deviated from industry practice or Stone and Webster's standard practices. The review involved an evaluation of flow and piping drawings, unit _;

walkdowns, TVA design standards and descriptions of systems, and discussions with TVA j personnel. A general review of calculations was performed, which focused primarily on i methodology and results.  ;

It was concluded that while there are a number of design features not commonly observed, none, specifically or in combination, should preclude safe, reliable unit operation. Specific findings addressed the design and orientation of the feedwater heater safety relief valve vent  !

stack and points of highly suspected erosion-induced wall thinning. Recommendations were i made to reduce turbine water induction risk, provide assurance on turbine speed control after l trips, and avoid long-term problems on the reheater drains. Recommendations for actions  !

were also made in the condensate / heater drain /feedwater system hydraulics, pump start _ _ ,

transients, and feedwater heater level stability during unit transients. The review also noted the unavailability of certain BOP as-built documentation and calculations. 7 Study results have been evaluated for corrective actions and to identify items for restart implementation. Postrestart actions will be factored into long-term BOP system reliability  !

improvements as part of the SIP.  ;

i IV.A.3 Performance of Corrective and Preventive Maintenance >

t During the current dual-unit outages, extensive corrective and preventive maintenance activities are being performed, with specific focus on the secondary plant. Maintenance  ;

prioritization and high-benefit work identification processes are being enhanced through the t use of the Secondary Plant Reliability Study results. Activities include outstanding corrective ,

maintenance items, conduct of preventive maintenance, temporary repair restorations and j inspection and refurbishment of secondary plant piping as part of the E/C program review ,

efforts (see Reference 15 for workoff curves).

The existing Maintenance work request (WR) backlog has been reviewed by licensed senior reactor operators using the restart evaluation criteria considerations for assessment of risk -

i individual and aggregate - and identification of degradation levels. The results of the Secondary Plant Reliability Study were utilized as part of this review, as were insights provided by INPO's review of BOP material condition. This methodology is being employed ,

on a continuing basis to address emergent, day-to-day WRs. This WR backlog will be '

reviewed by the individual system engineer who will present these results/ recommendations to the Backlog Review Committee (BRC) described in Section V.D. The results of this effort have been used to identify the restart maintenance population for current outage  !

performance. Approximately 3500 WRs for primary and secondary plant are currently 5  :

planned for completion prior to restart.

The permanent correction of temporary repairs to exirting piping as the result of E/C effects is being conducted before restart. Other temporary repairs are being evaluated and permanently corrected as appropriate. All through wall Furmanite applications for Units 1 and 2 will be repaired before restart. Other temporary fittings will be totally repaired for Unit I before restart and the majority for Unit 2 with a small number to be repaired by the  ;

end of the Unit 2 Cycle 6 refueling outage. In addition, a site procedure will be developed before restan that describes the temporary repair process including the control, tracking, and trending of such repairs.

The existing preventive maintenance (PM) backlog has been reviewed and prioritized using the restart evaluation criteria (Section V.A.2). Delinquent PMs (unimplemented PMs past i their due date without technical evaluation) will be completed before restart. PMs due before the Unit 2 Cycle 6 refueling outage for which conduct at power is considered to constitute an unacceptable level of risk are being performed during the current outages. RCM-driven PM revisions with identified plant reliability benefits are being reviewed and expedited for PM conduct during the current outages. PMs not performed during the current outages will essentially consist of lower benefit PMs that can be effectively performed with the units online. The PM backlog will also be reviewed by the BRC. Approximately 3700 PMs for primary and secondary plant are planned to be completed prior to restart.

O IV.A.4 Implementation of Secondary Plant Modifications  :

A number of modifications are being implemented to improve secondary plant component and system reliability and performance. Several of the modifications were identified and planned prior to the unit shutdown for implementation during subsequent outages. Additional .

modifications were identified through Secondary Plant Reliability Study recommendations, backlog reviews, employee feedback, and selected system reviews. Key modifications involve improvements in feedwater heater level controls, electrical system and control component changeouts and upgrades, reduction in air system design vulnerabilities, switchyard breaker and relay changeouts, and turbine /generatorimprovements.

IV.A.5 BOP Technical Programs Application I

IV.A.5.a E/C and Confirmatory Action Letter (CAL) Issues As a result of the erosion / corrosion induced rupture of the Unit 2 large bore extraction steam line and previous small bore piping failures, an overall E/C programmatic review and reevaluation of pipi ng condition were initiated. Significant programmatic weaknesses were '

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identified and a strategic scoping plan was developed by Electric Power Research Institute (EPRI). A comprehensive piping inspection and reevaluation effort for both large- and l l

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small-bore piping are being conducted by TVA, with contracted expenise and support. For large-bore piping (greater than 2-inch diameter), this includes: a complete rebuild of the CHECMATE large-bore model using verified model inputs, full pass two piping inspection data inputs based on full inspection grids, development and documentation of verified acceptance criteria, and required repairs / replacements. For small-bore piping, efforts include: completion of piping changeouts ongoing and scheduled at the time of the unit shutdowns, development of a detailed inspection plan based on a review of system design and operation and operating experience, and changeouts of indicated thinned piping.

Approximately 3000 feet of small bore piping and 300 feet of large bore piping are being changed out per unit. E/C programs for both small- and large-bore piping are being upgraded consistent with industry standards using contracted expenise. Organizational responsibility has been reassigned to the new Technical Performance and Program organization described in Section IV.B. A third- pany (EPRI) review of the entire piping evaluation and E/C program upgrade will be conducted.

Actions resulting from the extraction steam line rupture event identified in TVA's letter and the NRC Confirmation of Action 12tter dated March 4,1993 (References 1 and 2) will be completed before restart. These include the complete review of the event including the piping failure mechanism and impacts of the event on plant equipment, the review of the E/C program including a third party review, an evaluation of the condition of plant piping subject to E/C effects, the completion of permanent repairs to piping that was under temporary repair because of E/C effects, and the evaluation of other programs relative to weaknesses identified in the E/C program implementation. All CAL actions will be verified and affirmed complete by the Site Licensing manager before restart as provided for in Appendix 8.

IV.A.5.b Other Secondary Plant Programs ,

i Additional technical program reviews (reference Sections IV.C and Reference 6) identified several targeted areas for improvement in program applications to the secondary plant. These areas addressed the E/C program (including MIC) application to secondary systems such as raw water and high pressure fire protection, preventive and predictive maintenance for secondary plant equipment, switchyard (SWYD) controls, and temponry repair controls. Strengthened controls and selected inspections / evaluations are being implemented on the BOP for restart. Additional enhancements will be implemented as part of the SIP following restart.

IV.A.6 Upgrading Work Practices IV.A.6.1 Maintenance Processes and Standards A number of actions are being taken to elevate the standards of maintenance conduct on the 7

secondary plant. The Maintenance / Modifications Managers are conducting communications ,

and coaching sessions during department standdowns (see Section IV.E) with Maintenance, Modifications, and contract personnel to heighten sensitivity and attention to detail in conduct of secondary plant maintenance activities. This includes a discussion of plant operating reliability, risk and consequences using previous events, and maintenance work observations.

Secondary plant work practices and standards in such areas as planning detail for secondary work are being similarly heightened to parallel implementation practices and standards used for the primary plant.

In addition, clearly defined management expectations concerning higher standards for BOP are being communicated and enforced at alllevels of the Maintenance department.

A specific training session is being developed on BOP quality standards that will be presented to Maintenance personnel.

IV.A.6.2 Control of Work Several initiatives have been implemented to improve the control of work on the BOP. As a result of previous plant events, Plant Manager policies were developed for work on or around sensitive equipment and for the types of equipment adjustments (e.g., set point dials) that can be made without a work document. The policy on sensitive equipment has been incorporated into a site standard practice that will involve training and result in enhanced awareness of plant personnel (Reference 16). The policy on BOP equipment / controller adjustments clarified expectations regarding the use of procedures / work documents for BOP adjustments (Reference 17). This policy defines the following: (1) Operations is authorized to make certain adjustments during plant evolutions or when prompt action is necessary; (2)

Operations, with support from the system engineer, can make adjustments for equipment optimization but not to compensate for needed maintenance; and (3) other adjustment actions on BOP equipment can only be performed by utilizing the appropriate work document.

In the area of Maintenance and Modifications work control, a number of BOP performance / planning weaknesses have been identified by the Nuclear Assurance Organization Performance Evaluation Program (Reference 18). As corrective actions for these weaknesses, Maintenance / Modifications management has initiated a strategic plan  :

(Refe:ence 19) that includes communication of heightened expectations for the quality of i BOP work. This plan also includes specific expectations for each level of supervision including the craft. In addition, actions have been taken to increase supervisory presence in t

the plant for coaching and oversight, and increase the level of detail in work order planning.

The authorization of BOP work by Operations will continue to be performed through the Operations Control Center (OCC). Operations' reviews prior to the authorization of work have placed increased emphasis on configu ation control and single failure activities that could result in unit trips.

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I IV.A.6.3 Control of Configuration Operations' management has deter nined that BOP systems will be placed under the controls ,

of Site Standard Practice (SS?) 12.2, " Equipment and Status Control." The application of i

this level of control will ensure that BOP systems are properly aligned and maintained during restart and subsequent plant operadon. To further ensure adequate configuration control is established and maintained on BOP, process equipment will receive a verification of status prior to restart (see Reference 15 workoff curves). In addition, an increased awareness of BOP configuration control has been instituted into the OCC work authorization process. t i

IV.A.6.4 Improved Assessment of and Prioritization of Outstanding Work /Open Items on BOP A number of initiatives are being taken to improve the assessment of impact / risk for f outstanding secondary plant issues / work. These include assignment of risk degradation levels to work orders to aid in proper prioritization of work, adjustment in the site work l prioritization processes to increase weighting of plant reliability issues, and augmented controls and reviews of WRs over 90 days old. Results from the Secondary Plant Reliability Study are also being used to upgrade the weighting of plant reliability considerations in work prioritization and monitoring.

IV.A.7 Switchyard (SWYD) Controls and Interfaces ,

Several initiatives are being taken to further improve SWYD controls and interfaces. Actions  ;

being taken and/or to be completed prior to restart include establishing an onsite Customer Group (CG) owner for switchyard activities, removing outdated signs for access gates and vehicle control, revising the site instruction (SSP 6.52, " Activities of Customer Group at Sequoyah Nuclear Plant") to ensure CG activities are impact reviewed and that Operations is properly notified, formalizing the switching order execution process, ensuring the CG fully implements site instructions for switchyard activities, and strengthening the control of switchyard work during high-risk evolutions. Other long-termTecommendations to further  ;

enhance switchyard activities will be addressed through the SIP.

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IV.B OPERATIONS DEPARTMENT'S PERFORMANCE Weaknesses in the Operations department's performance have resulted in adverse impacts on safety system availability and a large number of plant events. A comprehensive improvement effort was ongoing at the time of unit shutdown. The review of performance history and ongoing performance evaluation efforts by Nuclear Assurance are being used to identify current areas requiring additional improvement to support unit start-up and safe, reliable operations over the next operating cycle. Additionally, senior corporate staff's assisted by industry experienced consultants are verifying the identification of problem areas -

and assessing performance levels to ensure operational readiness (Reference Appendix 1 for activity description).

The overall objectives of restart improvement efforts in the Operctions area include:

ensuring the establishment of an effective configuration control process; " certifying" the configuration of the plant both to support shutdown and restart conditions; providing safe and effective conduct of operations in targeted areas such as procedure adherence, plant ownership, command and control, formality of communications, self-checking, logkeeping, and turnover and status monitoring; strengthening management and personnel; and continuing efforts to upgrade personnel standards and culture.

IV.B.1 Configuration Control Multiple efforts are ongoing to enhance the configuration control process in the short and long term. These include the simplification and strengthening of the verification processes and requirements, additional training in standardized configuration methods for various component types, inclusion of additional systems within the configuration control process scope, ongoing procedure simplifications /matchups to eliminate multiple procedure alignments, trial use of a computerized configuration control system, and strengthened controls over configuration changes in the BOP (see Reference 15 for applicable workoff cunes).

IV.B.2 Configuration Verification Prior to unit shutdown, several configuration verification efforts were ongoing to provide additional assurance that components - valves, handswitches, etc. - were in the correct position to perform their required design function. A main control room handswitch verification effort is in progress including a comprehensive procedure and drawing review, to ensure the accurate assignment of positions. Reviews of associated Operation's procedures 10

and drawings are ongoing. Incorrect procedures and primary drawings will be corrected before restan. Following specialized tmining and upgrading of verification processes, a 100 l- percent field verification effort was initiated for Unit 1 for required systems for Modes 5 and 6 and for Unit 2 and common for all configured systems. The verification of configured systems will be completed before restart. SROs are being used to conduct " spot checking" of alignments (see Reference 15 for applicable workoff curves).

IV.B.3 Strengthening of Operations' Management and Personnel

) The cap' ability and effectiveness of Operations' personnel are being evaluated, and necessary i actions are being identified as part of the overall evaluation of site personnel discussed in Section IV.E. Additionally, an experienced supervisor has been recently hired to provide management oversight and workforce strengthening for auxiliary unit operators (AUOs).

Experienced industry SROs and AUOs (Trojan Nuclear Genenting Station) are being l

recruited and hired to infuse additional talent and perspective into the Operations depanment I over the long term. This effort will be supplemented by recruiting and hiring of former U.S.

Navy officec and petty officers as SRO and AUO trainee candidates, respectively (see References 20 and 21).

IV.B.4 Conduct of Operations Expectations and standards of performance in key areas - procedural adherence, command and control, plant ownership, fonnality of communications, self-checking, logkeeping, turnover, and status monitoring - are being enhanced, communicated, reinforced and monitored on a continuing basis.

Procedure adherence is being stressed with communication of expectations regarding inadequate, incorrect, or unclear procedures. The procedure revision process for Operations' procedures has been improved by supplementing suppon in this area. Turnover meetings and Operations' management briefings during training week, as well as weekly meetings with the Site Vice President, are used to discuss and reinforce expectations and areas for further improvement. Operations' administrative procedures, including the Conduct of Operations procedure, are being discussed, and expectations in execution are being communicated during i ongoing Operations depanment's standdowns (see Section IV.E and Reference 21).

Processes such as logkeeping and turnover are being standardized as much as possible. The utilization of the stop, think, act, review (STAR) process to enhance self-checking is continuing.

IV.B.5 Operations' Performance Assessment Nuc! car Assurance is evaluating performance relative to conduct of operations through the ongoing Operations Performance Evaluation Program followup. Results of that evaluation effort are being discussed with Operations' management and factored into ongoing 11

t communications. A Restart Readiness Team headed by the Vice President, Nuclear .

Readiness, will critically evaluate Operations' performance before restart to ensure adequate performance to support unit restart and operation. Members of that team have initiated an independent assessment of department performance during the ongoing restart efforts to provide feedback to Operations department management on effectiveness and progress.

(Reference Section VI.B and Appendix 1 activity listing description).

IV.C PROGRAMS Weaknesses were identifled in several program areas over the past several years, including the pmgrammatic weaknesses in the site E/C program, which resulted in the Unit 2 extraction line rupture and shutdown of the units for the current outages. Beyond specific program weaknesses, identified common elements or causes included an unclear definition of ,

program ownership, responsibilities and interfaces, and ineffective change management relative to responsibilities, organization, supervision, and resources allocation. A significant weakness was identified regarding split responsibilities between site and corporate organizations.

The objectives of the restart activities in this area are to assess the adequacy of site pmgrarns and implementation; assess the consequences of any identified weaknesses and take actions necessary to provide current implementation consistent with restart plan objectives; ensure clear ownership for site programs is established, including an effective organization structure and organizational interfaces; and provide a foundation to continue longer-term program enhancements.

Three key actions are being taken to address this area: team reviews of selected, "hlgh risk" technical program areas; reviews of program areas by department program owners as part of  ;

the department readiness assessments; and establishment of a Technical Performance and  :

Programs organization to consolidate and better focus definition and implementation of key site technical programs.

IV.C.1 Technical Programs Review A review of technical programs was conducted by a team headed up by the Chairman of TVA's NSRB (see Reference 6). The purpose of the review was to assess program adequacy, identify specific deficiencies or work items that should be addressed before restart, and to provide advice and assistance to implement longer-term program improvements. The review teams were composed of 38 TVA personnel from Nuclear Assurance, corporate technical groups, and SQN site organizations. Eight industry experts external to TVA also ,

participated in the review effort. Programs for review were identified by a team of senior corporate managers consisting of the Chairman, NSRB; the Manager, Nuclear Licensing and 12

Regulatory Affairs (NLRA); the Chief Engineer; the Manager, Technical Programs; the Manager, Nuclear Fuels; and the Manager, Quality Programs. Program selection was based on a review of events, trends, and performance indicators; a review of common elements  :

associated with recent events; the potential to impact plant operations; and programs with split ownership between corporate and site (Reference 7). The programs reviewed included:

open issues (including backlogs); switchyard control; corrosion control programs; American 7 Society of Mechanical Engineers and regulatory programs; valve, predictive maintenance, >

and equipment trending programs; control of temporary repairs; chemistry; and  !

environmental qualification. Oversight of the conduct of the review was provided by a panel  :

composed of the Chairman, NSRB; the Vice President, Technical Support; the General .

Manager, Nuclear Assurance; the Vice President, Nuclear Readiness; the SQN Site Quality l Manager; and the SQN Site Licensing Manager. This panel will also review the actions being taken to resolve the review findings. l f

The results of these reviews (Reference 6) were provided to program owners and both restart  ;

and long-term improvement recommendations were identified. Program owners are utilizing -

these reviews to assist in baselining current program health; additional reviews are being conducted as appropriate. ,

I IV.C.2 Program Owner Reviews t

As part of department readiness assessments (Section V.F), department program owners will assess the health and effectiveness of programs owned by that department. This assessment will consider program assessments and performance indicators / trends and the potential impact i of identified program weaknesses on near-term, safe, reliable plant operation.

IV.C.3 Technical Performance and Programs Organization 1 Prior to the shutdown of the units, early in 1993, weaknesses were observed in the organizational structure for several technical programs. The observed weaknesses included the inadequate definition of program ownership, fragmented implementation, and split responsibilities between multiple organizations, both within the site organizations and between the site and corporate organizations. As a result, an effort was initiated in early_

1993 to develop a single site organization of technical programs to provide a better structure i for delineating program responsibility and authority and facilitating implementation through '

well-focused control, e.g., minimizing and/or better controlling " hand-offs" and interfaces.

Program ownership is being clearly established at the site; program definition or implementation functions previously performed by corporate organizations are being transferred to the site. (See Section IV.F for additional discussion of corporate / site interface.) ,

The overall objective of the organization is to achieve 1.nd maintain total program definition, 13 l

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ownership, and responsibility for effective SQN implementation. As practical, organizational

" hand offs" will be minimized. The scope of the technical programs to be included in this organization was developed from a review of program magnitude and complexities, potential for weaknesses identified by recent events, and consequences of ineffective implementation.

The new organization has been approved and key positions permanently filled, including the organization manager and several supervisory positions; temporary assignments are being used in some areas (Reference 22). The transfer of responsibilities and personnel from-previous organizations is ongoing. Responsibilities and interfaces are being documented and responsibility transfer agreements established and communicated. Program baselining utilizing the program reviews described in Section IV.C.1, along with additional applicable reviews, is being conducted to upgrade individual program areas. Contracted expertise is being utilized in several areas to suppon continuing reviews and program upgrade efforts.

Before restan, the organization will be in place; responsibilities and interfaces will be defined and documented; restan actions from program reviews will be complete; and programs will be myiewed for adequacy to support restan and plant operation. Program owner affirmations of program adequacy to support restart and safe, reliable operation over the next operating cycle will be documented. Longer term program improvement efforts will continue beyond restart and will be identified as pan of depanment readiness affirmations.

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l IV.D BACKLOGS /OPEN ITEMS - WORK PRIORITIZATION i l-1 A number of site processes generate work items of vanous types that untilimplemented i- constitute open or backlogged items. Schedules for working these items are dictated by l

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process requirements, significance / priority and site work prioritization processes. Prior to the current outages, the SIP had identified backlogs as a major improvement area with focus l on assessing the individual and aggregate impact of backlog items on safe, reliable plant i operation; reducing existing backlogs that can adversely impact the effective management of  !

site activities; improving work prioritization and scheduling processes to optimize priority j assignment; and improving work processes to control the development of future backlogs.

It is recognized that open items and backlogs will always exist to some degree. The restart l objectives in this area are to ensure that backlog items individually or in the aggregate do not  !

pose unacceptable risk to effective plant and site operation from hardware and I personnel / management impact perspectives, and to lay the foundation for the effective control  !

and management of backlogs following restart.

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Accordingly, restart activities in the area of backlogs are focused at gaining a good understanding of the individual and aggregate impact of existing backlog items; working open items with significant impact / risk to safety system availability, plant reliability, or effective plant / personnel performance on either an individual or aggregate basis; improving backlog ,

assessment and monitoring processes to ensure effective controls and understanding of l postrestart backlogs; establishing detailed workoff plans for postrestart backlogs; and i initiating improvements to work processes to optimize postrestart priority assignments and control the development of future backlogs. .

The above activities are being implemented and captured through three key restart plan ,

processes, the backlog review process (see Section V.D), the system readiness assessments (see Section V.E), and the department readiness assessments (see Section V.F). In summary, through a designated Backlog Review Committee (BRC) and system engineer evaluation, site backlogs are being identified and backlog items are being evaluated individually and/or in the aggregate against restart evaluation criteria. Applicable restart workoff curves are provided by Reference 15. System readiness assessments will consider the aggregate impact of any remaining postrestart backlogs /open items on system functionality. Department readiness i assessments will ensure a thorough analysis and understanding of the department-owned postrestart backlog compositions, will have established acceptability of those backlog levels to support safe md reliable operations, will have determined what process improvements are necessary to prevent the development of unacceptable postrestart backlogs, and will have established workoff curves and performance indicators to ensure effective management of postrestart work.

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1 IV.E PERSONNEL, ORGANIZATION AND CULTURE l

1 As discussed in Section I, the analysis of the underlying causes for observed weaknesses in l SQN performance identified repeated indications of ineffective personnel and management i performance. While it is recognized that improving personnel performance and effectiveness  ;

is an ongoing, long-term effort, specific restart initiatives were identified in l personnel / management capability, organization structure and definition of responsibilities, and personnel culture in terms of ownership and standards of performance.  ;

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IV.E.1 Personnel Evaluation / Management Development An evaluation of site personnel / management capability and performance is being conducted

- to identify weaknesses and associated action / development needs (see Reference 20). This effort will be completed down through the first-line supervisor in all site organizations and for the entire Operations depanment (down to AUO levels) before restan. Remaining personnel will be evaluated through the continuation of this process following restan. This ,

evaluation is being conducted by first identifying key behaviors for success and then evaluating managers / supervisors / personnel against these behaviors.

The restart evaluation has been completed. Immediate restart actions or development needs are being identified as well as postrestart actions. Evaluations are being compared against previous performance appraisals for management feedback and appraisal updating. Targeted development training will be conducted. Detailed action plans are being developed for ,

" action required" managers. Actions needed before restan are being identified and l implemented. i The results of this effort will be integrated into the department readiness affirmations, the overall site restan readiness assessment, and continuing postrestan management performance reviews and individual development plan processes. It is acknowledged that this initiative is primarily one of enforcing an existing system that has broken down. Long-term success will i depend on management commitment.

IV.E.2 Organization, Roles and Responsibilities ,

l To improve the effectiveness and ownership of site personnel, an effon was initiated to  !

evaluate the effectiveness of and revise as appropriate the organizational structure, and to f clearly define roles, responsibilities, and interfaces (see Reference 21). Organizational weaknesses are being identiEed, and necessary restart and postrestan actions are being ,

defined. The results of this effort will be documented and communicated to site personnel;- l 1

impacted procedures will be revised as appropriate. This effort will interface with efforts 16  !

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l addressing the corporate / site interface in Section IV.F, and provides an input to both the depanment readiness assessments and integration into the overall site readiness assessment.

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.a IV.E.3 . Culture and Ownership Restart and postrestart continuing efforts are being implemented to build an effective site culture, instill ownership, and foster teamwork araong management and site personnel.

A long-term action plan has been developed, and efforts are being integrated into ongoing restart efforts. These efforts are focused at communicating and reinforcing a common site i vision among all personnel, including overall site objectives and standards of performance and expectations forjob function execution.

A series of department standdowns in key departments are being conducted before restart to devote special focus to this area (see Reference 21). Department-specific performance, processes, procedures, and issues are being addressed as well as overall site restart and postrestart plans and objectives. This effort comprises a small subset of a broad, long-term action plan for continuing postrestart improvement.

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IV.F CORPORATE / SITE INTERFACE f Separate from (but in parallel with) the SQN restart efforts, the TVA corporate organization  ;

in Nuclear Power has been recently restructured (see Reference 23 for organization charts).

This effort included the assignment of a new Vice President of Nuclear Operations (R. M.

Eytchison) who has responsibility over the nuclear sites. A corporate group under the newly ,

created Vice President of Nuclear Readiness (D. R. Keuter) is responsible for overseeing site  ;

readiness and reporting the state of operational readiness to the Vice President of Nuclear Operations. The recent reorganization realigns all corporate technical functions under one Vice President of Technical Support (M. O. Medford) to consolidate technical and programmatic oversight and site support functions into a single organization for a more integrated, unified approach.  ;

A key element of the overall restructuring effort is to ensure that all site technical functions are owned by and conducted from the site organizations. Actions are ongoing to clearly .

i define the corporate mission in terms of site oversight, plant support, and TVA program area responsibilities and to coordinate with the site for the effective transfer of responsibilities / functions (see Reference 24). Companion efforts to improve the effectiveness of the corporate organization are also ongoing. A clear definition of the corporate / site ,

interface will be integrated into the site organizational activities discussed in Section IV.E.2 i I

and the overall site readiness assessment.

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s j1 V. PROCESSES  !

This section outlines the processes being utilized to identify potential restart items, conduct or obtain associated reviews / approvals, and assess readiness for restart through the integration of multiple processes / reviews. These processes will be defined, revised, -

implemented, and controlled under appendices to this plan. A revision to or a refmement of ,

these processes, following the issuance of this Restart Plan, will constitute a revision to the  :

Restart Plan and will be approved by the Site Vice President. 1 I

V.A RESTART ITEM IDENTIFICATION ,

Key aspects of the restart item identification process are described below. l V.A.1 SOURCES OF POTENTIAL RESTART ITEMS AND ISSUES Potential restart items have been (and/or may continue to be) identified through the following principal sources-A. Management Review The Site Vice President, his direct reports, and their direct reports met to identify both .

hardware and administrative weaknesses, problems, or areas for improvement that directly'or  !

indirectly contributed to the forced outages and should be addressed / resolved prior to restart.

Additionally, this team identi5ed additional actions that should be taken before the restart of .

the units, considering major weaknesses such as identified in the SIP, to further improve postrestart operational effectiveness. This team identified a base initial "52 item restart list"  :

from which the current restart list developed.

f B. Employee Feedback In mid-March, utilizing the SIP and initial "52 item restart list," designated department managers met with targeted personnel groups to determine if other significant issues / problems existed that were not already identified or whether the current assessment of

• significance (and therefore priority) of problems was appropriate. (The designated departments and personnel populations were those considered most likely to be aware of other significant issues / problems.) Ap 'ix 2 provides the documentation package utilized in that process. Additional potential resti.,1 items resulting from that process were presented to the MRRC for approval / disapproval for adding to the restart list.

C. Site Improvement Plan (SIP) Review l The SIP was reviewed on a line-by-line (SIP matrix line entries) basis by MRRC members .

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-it for identification of potential restart items. l t

i D. Program Reviews j i

As discussed in Section IV.C, team reviews of a number of program areas were conducted  :

that identified both restan and postrestan recommendations.  !

E. Assessment Reviews Trend reports and internal and external assessments, e.g., Nuclear Assurance trend repons -

and Performance Evaluations, and the 1992 SQN Nuclear Plant Self-Assessment ("Keuter ,

report"), were reviewed by department mangers for potential restart items.

F. Backlog Reviews Prior to establishing the BRC and the associated comprehensive backlog review effort, a number of site backlogs were reviewed by depanment backlog owners for the identification of potential restart items. The ongoing comprehensive backlog review effort through the  :

BRC will ensure that all backlogs are identified and reviewed as appropriate against the

, current restan evaluation criteria. Additional potential restan items may be identified as part of this effort. ,

G. Restart Plan / Activity Implementation {

Ongoing reviews, assessments, and Restan Plan process / activity implementation, e.g.,

backlog reviews, may identify additional restart items. . ,

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l V.A.2 RESTART EVALUATION CRITERIA 1

Criteria or considerations communicated by the Site Vice President for use in identifymg j potential restart items have focused on nuclear safety, plant reliability, and operational  !

impacts, with examples provided such as items resulting in frequent entry into limiting l conditions for operation (LCOs) and items that could result in plant transients. The l' following restart evaluation criteria reflect a consolidation and reformatting of these criteria / considerations, along with the explanation / guidance in the application of the criteda. 3 Actions needed to ensure technical specification (TS) operability will be completed before j entering a mode for which associated requirements are applicable (except as allowed under  ;

LCO 3.0.4 exception). Actions needed to satisfy NRC docketed commitments or agreements l associated with the current outages (e.g., CAL items) will be completed before restart. The I following screening criteria will be used to evaluate other open items / issues to determine l what additional actions should be taken before the restart of the units from the current l outages. The criteria establish basic considerations involving nuclear safety, plant reliability, and operational impacts for which assessments and judgements must be applied, e.g., degree j and probability or consequences of impact. Potential restart items should be conservatively assessed and presented to MRRC by the responsible organization / owner as described in .

Sections V.A.3 - V.D of this document. MRRC will either approve the item / issue for restart scope inclusion or will provide the basis for why the item / issue should be addressed ,

following restart or the restart scope modified.  !

• Adverse impact on safety system availability or performance e For example, potential for causing frequent entry into TS action statements, potential _

for entry into short-term TS action statements, and potential to render a component or system incapable of performing intended design function  !

• Significant challenge to plant / personnel performance because of individual or l aggregate impact  ;

For example, high numbers of compensatory actions, disabled annunciators, high backlog numbers, and degraded or unreliable equipment performance l

• High potential to impact plant operating reliability  :

For example, likelihood for causing trips / transients, common or single failure point weaknesses, necessitates entry into short-term TS action statements, and likelihood for j hardware failure before the end of the next operating cycle

• Prudence of or need for working during two unit outage ,

For example, reduced TS action statement applicability, reduced outage risk, and reduced operational impact  ;

The above criteria do not preclude the approval and inclusion of activities that do not meet 21 i i

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the criteria but are determined desirable / prudent in consideration of overall site objectives, j e.g., activities associated with ALARA (as low as reasonably achievable), industrial safety, l and/or resource optimization.

t V.A.3 POTENTIAL RESTART ITEh! DOCUMENTATION AND EVALUATION -

1 Potential restart items have been and are being documented and evaluated as described in this  !

section. This process does not apply to items required to satisfy TSs, high-priority outage j work orders / work requests, or other normal emergent outage scope addition items handled l through the outage addition process in SSP-7.2, " Outage Management." It is recognized that the forced Unit 2 and Unit 1 outage schedules and the Unit 1 Cycle 6 refueling outage  ;

schedule contain activities not added through this process.

1 Potential restart items from any source may be documented on the form contained in j

. Appendix 3, reviewed and concurred with by the responsible supervisor, and provided to the Manager, Project Management and Controls, for scheduling a MRRC review. Items that l have been previously (prior to issuance of this plan) presented to MRRC or previously identified / evaluated utilizing alternative documentation do not have to be placed (retrofitted) {

on the form in Appendix 3. Items resulting from and documented through the Restart Plan implementing processes, e.g., BRC reviews, will also be provided to the Manager, Project i l

Management and Controls, for scheduling MRRC review 1.nd approval. The restart form l l provided in Appendix 3 need not be used for items documented through these processes.

1 Die deletion of restart items from the restart scope requires technical evaluation by the system engineer and MRRC approval. This process is in addition to the normal cutage .

j activity deletion process provided under SSP-7.2. This process is described in Appendix 3.

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V.B MANAGENIENT RESTART REVIEW COMMITTEE (MRRC)

V.B.1 MRRC COMPOSITION The MRRC is chaired by the Site Vice President and is composed of the following site I

members:

SQN Site Vice President (Chairman)

Plant Manager Engineering and Modifications Manager Site Licensing Manager Operations Superintendent Site Quality Manager V.B.2 RESPONSIBILITIES AND FUNCTIONS The MRRC oversees and directs the overall management and implementation of the restart activities and processes addressed under this Restart Plan. The MRRC approves or disapproves potential restart items / issues, reviews summary results of restart evaluations, reviews the adequacy of restart activity completion verification activities, and reviews results of restart readiness assessments and affirmations. MRRC will provide overall management direction and approval of the restart process, including the outage schedule development, execution, and completion.

V.B.3 MRRC MEETINGS .

MRRC meetings to review potential restart items or to review results of restart item evaluations are scheduled through the Manager, Project Management and Controls. Potential restart items are presented to MRRC during scheduled meetings by the appropriate department manager, program owner, system engineer, or other sponsoring individual.

MRRC makes a restart determination based on the informationpresented or may direct that l an additional evaluation or information be obtained before making the final restart determination. MRRC assigns an " owner" for each restart list item. For items determined  !

to not be restart items, MRRC considers if the item should be placed in the SIP, handled by ,

existing processes, or worked in an expedited manner.  ;

MRRC meeting decisions, including the addition of items to the SQN restart (evaluation) list, i are documented, controlled, and tracked by the Manager, Project Management and Controls, (

or his representative. l l

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6 V.C RESTART EVALUATION LIST ,

1 The restart evaluation list (i.e., restan list) is maintained and updated by the Manager, )

Project Management and Controls. MRRC approves all additions or deletions of restan list i

activities (Reference 14).

V.D BACKLOG REVIEW COMMITTEE (BRC) ,

The BRC was established to effect a comprehensive and consistent review of key site backlogs for restart consideration. Prior to establishment, a number of backlogs or portions  :

of backlogs had already been evaluated by department managers as restan item assignments l or independent assessment effons; additionally, the employee feedback process had identified a number of restart items from various backlogs. A multidiscipline composition was j established to ensure appropriate site impact considerations, e.g, Operations' SRO input.

Members were selected based upon broad experience, knowledge, and perspectives. The  :

implementation of the backlog review through the BRC ensures the comprehensiveness of '

backlog review effons, appropriate operational impact assessments using an active SRO l licensed individual, and consistency in backlog review implementation. Reviews are being conducted on a system basis as appropriate to provide the foundation for assessing the ,

aggregate impact of outstanding items / issues on system functionality. Members serve as  !

representatives or liaisons with associated depanments to ensure the effective coordination of ,

the completion of this effort with other restart processes, e.g., system readiness and depanment readiness affirmations. The detailed process is described in and controlled under Appendix 4. .

i V.D.1 BRC COMPOSITION The BRC is composed of multidisciplined members representing the key site organizations owning or affected by the majority of site backlogs. The members include the following:

H. R. Rogers, Technical Suppon Program Manager (ledd)

M. J. Lorek, Nuclear Engineering (active SRO)

I. Dibiase, Maintenance C. R. Brimer, Nuclear Engineering V.D.2 BRC RESPONSIBILITIES AND FUNCTIONS The BRC identifies and evaluates existing site backlogs (as defined in Appendix 4) as of May 1,1993, for their individual and aggregate impact on restart and, with the .

recommendation of the backlog owner and affected system engineer (s), makes restan  !

decisions on those backlogs (see Reference 15 for workoff curve). The BRC uses the  :

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collective experience and judgement of members with supporting input and conducts reviews against the restart evaluation criteria. The system engineer (as the system owner) participates in backlog reviews and through his/her system-specific expertise and judgment has significant impact on the BRC decision-making process. The BRC process makes significant impact to ,

the system readiness evaluation described in Appendix 5. The BRC presents to the MRRC,  ;

with depanment head and/or system engineer support as appropriate, the summary results of their determinations. Items / issues that are recommended for restart and items / issues for which a restart recommendation is not clear are discussed in detail with the MRRC.  ;

For items for which the evaluation criteria are generally satisfied but it is determined that significant schedule / resource impacts would be involved, the BRC, with input from the department head / system engineer, may assess the technical acceptability of not resolving the item (s)/ issue before restart and the level of equipment, personnel, or program performance

" risk" that could be assumed or expected. These items would be presented and discussed in detail with the MRRC for final restart determination. The restart item deletion process is described in and controlled under Appendix 4. i Backlogs can present an adverse impact to effective plant operation because of the effect of individual or aggregate items and because of the demands that backlogs place on managing i line organizations. Collateral to the BRC's primary restart responsibility, the BRC may document observations and formulate recommendations for improvement of how the site  !

accumulates and manages backlogs for senior site management consideration.

Emergent items identified after the backlog review process cutoff date are reviewed for .{

restart scope inclusion as described in Appendix 4. 1 I

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V.E SYSTEM READINESS 1'

Prior to restart, the responsible system engineer will review the status of each system as indicated in Appendix 5 and will affirm restart readiness of the system to support safe and reliable restart and operation during the next operating cycle. The purpose of this ,

l. process is to collectively assess system readiness from a hardware standpoint to suppon the l management restart decisions, to reinforce ownership for system performance and l l

improvement with the system engineers, and to lay the foundation for postrestart work / improvement prioritization.

Considerations that will be addressed by the system engineers in support of that affirmation  ;

will include the status of the material condition of the system including the review of outstanding backlogs or open items / issues on their system; the completion of the review of 7 information related to significant recurring or repetitive equipment failures; the establishment of compensatory measures (if appropriate) for postrestart items / issues; the prioritization of addressing open items / issues that will exist following restart; the completion of walkdowms on focus systems listed in Appendix 5 or as required by the Technical Support manager; and the establishment of priorities for the continued improvement of system performance and .j system material condition.

System readiness reviews will be reviewed by the system engineer supervisor, the BRC, the r Technical Support manager, and the MRRC. System readiness affirmations will be input into the department readiness affirmations discussed in Section V.F, and into the overall  ;

MRRC site readiness assessment.

The system readiness process is detailed in Appendix 5. _

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l L V.F DEPARTMENT READINESS AFFIRMATION l

Prior to restart, the managers responsible for each major functional department as indicated in Appendix 6 will affirm restart readiness of that department to support a safe and reliable  ;

restart and operation during the next operating cycle. The purpose of this process is to ensure depanment completion of assigned restart actions; to ensure that programs, processes, .

organization, and personnel / management capability are sufficient to support safe and reliable  !

operation; to ensure that postrestan work and improvement efforts (including backlogs) are i sufficiently defined, prioritized, scheduled, and controlled; and to ensure that appropriate postrestart assessment and monitoring processes are in place.  ;

The process leading to this affirmation will include a series of meetings with the depanment  !

manager and the Site Vice President to discuss needed actions leading to depanment restan ,

readiness, to review progress in attaining organization / functional readiness, and to assist in department manager development via the process for establishing department readiness for -

both shon- and long-term considerations. Final depanment readiness affirmations will be ,

reviewed by the MRRC and will be input into the overall MRRC site readiness assessment.

The department readiness affirmation process is detailed in Appendix 6.

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V.G SITE READINESS ASSESSNIENT i The overall site readiness assessment will consist of a "rollup" of a number of interfacing i and overlapping inputs. These include the system and depanment readiness affirmations described in Sections V.E and V.F, the closeout by the outage management team of outage activities, the closeout / disposition of all restan list items, the review of organization and personnel adequacy (Section IV.E) including the corporate / site interface (Section IV.F), and ,

the review / assessment of restan readiness assessment activities described in Section VI. The MRRC will review and evaluate both the inputs and rollup of these inputs and provide,  :

through the Chairman, final restart approval and authorization. A MRRC readiness i assessment will be conducted before initial mode change (Mode 5 to 4) and the full site readiness assessment will be completed before unit restart, defined as unit criticality.

Preliminary or intermediate assessments will be conducted as determined appropriate by the MRRC or the Site Vice President. The Plant Operations Review Committee will also review ,

site readiness for initial mode change and unit restart.

The site readiness assessment process is depicted in Appendix 7.

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VI. ASSESSMENT / OVERSIGHT  !

As part of the restart activities, a number of assessments, reviews, and oversight activities  ;

are being employed to ensure that key areas for improvement are identified, that the  :

associated restart plan and activities are appropriate to address those weaknesses, and that the l restart plan is effectively implemented. Key review and assessment activities include: (1) ,

the technical program reviews referenced in Section IV.C; (2) a special SQN NSRB review l of the restart plan; (3) a high-leve!, Senior Management Oversight Group review of the  !

restart plan and overall restart readiness; (4) internal and external reviews of the BOP; (5) a l Restart Readiness Team review of the Operations department's restart readiness; (6) an )

NSRB special review of backlogs; (7) a comprehensive program of Nuclear Assurance assessments and audits; and (8) a restart readiness oversight, assessment, and affirmation  ;

i rocesses described in Section V of this document. A listing of these activities is provided in l ApTndix 1. l The application of these efforts in the restart plan development and implementation is j r

described below.

v VI.A DIPROVEMENT AREA IDENTIFICATION - RESTART PLAN ADEQUACY l As discussed in Section I, an effort was underway prior to the shutdown of the units to i l identify the root cause(s) or principal barriers to the successful accomplishment of TVA . [

j Generating Group objectives and to establish detailed action plans through an integrated Site l

! Improvement Plan to address targeted areas for improvement. The identification of specific  !

l and common causes/ barriers was accomplished through a management team review of recent l events, trend analyses, and internal and external assessments. In more broadly analyzing the .

j underlying causes of overall performance weaknesses over the past several years, two general

causes were identified

ineffective resource management and ineffective l j personnel / management performance. As a result of this recent and current analysis, the six )

focus areas described in Section IV were identified for intensive short-term and continuing  !

l long-term improvement. l t

Three additional independent reviews are being employed to ev'aluate the accuracy of the l above assessment and associated adequacy of the overall restart plan initiatives described in i this document. They include an INPO problem / event analysis to determine if additional  !

underlying / common weaknesses exist; a special NSRB evaluation of the restan plan scope j and approach (Reference 10); and a review of the SQN history and the restart plan by an l independent industry Senior Management Oversight Group (Reference 8). The results of l additional restart readiness assessments, reviews, and oversight activities described below  ;

will be evaluated for the need for additional focus or scope within the restart plan on an  !

ongoing basis.  !

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k VLB RESTART PLAN IMPLEMENTATION /EFFECTIUNESS - RESTART READINESS A combination of varied restart readiness processes and assessments / reviews will be conducted to support a determination of site readiness to safely restart and operate the units  !

over the next operating cycle. The implementation of the Restart Plan, through readmess  :

assessments / affirmations, BRC and MRRC review / oversight, and final closure and documentation processes, provides a structured approach to line readiness assessment. The extensive use of multiple non-line assessments, reviews, and oversight activities is being r additionally em' ployed to address readiness in targeted areas such as the RRT review of the Operations department's readiness, and more general readiness assessments such as the Senior Management Oversight Group review addressing management, organization, personnel, hardware, and technical program issues. The comprehensive Nuclear Assurance restart assessment program (Reference 11) was developed by the consideration of  :

programmatic, hardware, and personnel performance weaknesses. Restart readiness assessments will be presented to and reviewed by the MRRC for the determination of -

addidonal needed actions and/or integration into the overall site readiness assessment rollup.

i T . ASSESSMENT CAPABILITY AND EFFECTIVENESS - POSTRESTART ASSESSMENT t

A number of activities are ongoing to str.:ngthen the assessment / root cause capability and effectiveness. Depanment readiness assessments and affirmations will ensure that meaningful performance indicators are established and monitored and that these measures are being integrated into the postrestan Site Improvement Plan. A key element of the restructuring of -

the corporate organization described in Section IV.F is to clearly define and enhance the  ;

corporate oversight functions and effectiveness. A comprehensive audit of the corrective action program has been conducted to assess implementation effectiveness and identify  ;

actions for further strengthening from both programmatic and implementation perspectives. ,

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VII. CLOSURE AND DOCUMENTATION The MRRC will review the rollup documentation of Restart Plan completion as described in Section V.G. Documentation and closure will be tracked, compiled, and presented to the MRRC.

VIII. POSTRESTART - SITE IMPROVEMENT PLAN The postrestart SIP will be updated, revised, reviewed, and approved by the SQN Site Vice President before restart. The postrestart SIP will provide a detailed, structured document for identification and prioritization of postrestart improvement actions and will include defined -

performance indicators, processes for continuing and periodically monitoring progress and performance, and an update of the SIP as appropriate.

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l IX. REFERENCES

1. NRC Confirmatory Action Letter dated March 4,1993

2. TVA letter from O. D. Kingsley to S. D. Ebneter dated March 4,1993 i

3. INPO Assist on Secondary Plant Equipment dated February 16, 1993 l

4. ( Secondary Plant Reliability Study when issued ) ,

5. Balance of Plant System Review by Stone & Webster Engineering Corporation dated  !

May 15,1993 i

6. SQN - Technical Programs Review dated March 31,1993

7. SQN Technical Programs Review, memorandum dated May 11,1993

8. Senior Management Oversight Group Charter, letter dated May 5,1993 i

9. NSRB - Special Review of Open Engineering Work at SQN, Memorandum dated May 4,1993 ,

10. Minutes of April 22,1993, NSRB Meeting No.142 dated May 4,1993 1

11. Nuclear Assurance Oversight Plan for SQN Restart, Memorandum dated May 20,1993 -

12. SQN - Backlog Review, Memorandum dated May 11,1993 _

13. SQN - Department Restan Readiness, Memorandum dated May 11, 1993 [

14. Restart Evaluations for SQN (current list maintained by SQN Project Management and i

Controls)

15. SQN.Restan Workoff Curves (current curve package maintained by SQN Project Management and Controls)

16. Site Standard Practice (SSP)-12.63, " Sensitive Equipment Control"  ;

17. SQN - Adjustment of LevelIndicating Controllers and Use of Metering Orifice Cleanout  !

Plugs, Memorandum from R. J. Beecken to All Operations, Maintenance, and Technical Support Personnel dated April 26,' 1993

18. Nuclear Assurance Performance Evaluation Program  !

19. SQN Maintenance Performance Evaluation February 10 through March 22,1993, ,

Memorandum from L. S. Bryant to T. A. Flippo dated April 23,1993

- 20. SQN Performance Improvement Plan (including evaluation and results) - l ADMINISTRATIVELY CONFIDENTIAL t

21. SQN Restan Plan - Software Schedules

22. SQN Technical Programs and Performance Organization Chart ji

23. TVA Generating Group Organization Chans

24. Division of Responsibilities - Technical Suppon and SQN, Memorandum and attached l Report from Mark O. Medford to Roben A. Fenech dated May 14,1993 X. FIGURES  ;

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1. SQN Restan Plan Flowchart 32 l

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XI. APPENDICES j

- 1. Assessment / Review / Oversight Activity Listing

2. Employee Feedback Process  ;

3. Process for Evaluating and Scheduling SQN Restart Items  !

4. Backlog Review Process  ;

5. System Readiness Assessment and Affirmation Process [

6. _ Department Readiness Assessment and Affirmation Process

7. Site Readiness Assessment Process .!

8. Site Licensing Regulatory Closure Affirmation }

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FIGURE.1 SQN RESTART PLAN

-E/C UIC6 RFO MGT REVIEW SIP REVIEW SCOPE j PROGRAMS REV -

ASSESSMENTS MRRC > RESTART y OUTAGE FIELD EMPLOYEE FEEDHACK _

LIST MANAGEMENT [p IM PLEMENTATION BACKLOGS ^

NRC NRC QA Y NSRB DEPT MGR HACKLOG REVIEW SYSTEM p

^ '

SYS ENGR / COMMITTEE (HRC) READINESS HALANCE OF 4 MRRC PLANT (HOP) h^R'I.OPERATIONS y DEPARTM ENhy DEPT NRC PERFORMANCE ASSESSMENTS j > READINESS >

^

9 ^-0 PS MRRC hfAINT SYS ENGG SR htGT TEAh!

NRC-O R AT y

4 I(j SI]P '

ORGANIZATION .

SITE NRC NRC & PERSONNEL, READINESS >

NRC OPS OVERSIGIIT >< MRRC &

, " ' ORC T.ht cG R ATII PROGRAMS or NRC > MODE 4 NRC MRRC PORC y MODE 2 seacpin th3 y

- . _ _ . _ __m-_ .- _______.___m.__.__._______.__.e.___m.___m_.__ __tmm_-__m_ *- +-we m m i2~ -3 _ -5 .,- .. -~m_.e-v%...,w--w __e , - - ,.,e_ 4 . ,__ r ce _,.r~-,-,m __...w_--,

XI. APPENDICES 36

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f 37

APPENDIX 1 ASSESSMENT / REVIEW /OVERSIGIIT ACTIVITY LISTING The following assessments, reviews, and oversight activities are being performed to (1) L ensure that areas needing improvements are identified, including the underlying cause(s) for i

overall performance weaknesses; (2) to ensure that the Restart Plan is appropriate to the achievement of overall restart plan objectives; (3) to verify the proper implementation of the restart plan; and (4) to assess the effectiveness of restar, actions, i.e., restart readiness.

I. Identification of Restart Focus Areas for Improvemend l

I

• Prior to unit shutdown, an overall Site Improvement Plan was developed to target key areas for improving the ability to meet overall site and Generating Group objectives, i.e.,

nuclear safety / regulatory performance, plant capacity factor, and generation cost per killowatthour. To develop this plan, the site management team reviewed previous events and trends and internal and external assessments / reviews. The plan included both software and ,

hardware issues and included the following focus areas: BOP, Operations' performance, and backlogs.

• Following the shutdown, the site management team reviewed key areas for improvement during the forced outages, including the review of the SIP areas. An initial restart list of 52 ,

items was developed. This list included both specific items to be implemented as well as actions to evaluate other areas for potential identification of restart actions, e.g., an action to review corrective action (C/A) items or justifications for continued operation (JCOs). ,

• Following the development of the 52 item list, site management solicited employee feedback from designated departments to determine whether additional significant problems impacting nuclear safety, plant reliability, or operational performance existed that had not been identified in either the SIP or the 52 item list and whether the indicated management priority for resolution was considered inappropriate, e.g., true iisk not recognized and therefore scheduled in SIP postrestart; and to identify any specific individual concerns, e.g.,

a specific backlog item such as a hardware upgrade. This effort provided an overlap with some actions being taken as part of the 52 item list (Appendix 2).  ;

• As restart evaluation criteria evolved, additional reviews of the SIP and internal and external assessments / reviews were conducted by site management, and additional items were  :

added to the restart list as appropriate.

• INPO conducted a problem / event analysis using C/A documents for 1992 and 1993 to I determine if additional problem areas existed that had not been identified by the above efforts.

l 38  ;

api .'NDIX 1 II. Specific Ongoing Reviews or Conducted in Specific Focus Areas to Ensure Clearly Defined Scope of Problems ,

• INPO assist plant walkthrough to broadly identify plant weaknesses based on experience and judgement (Reference 3) ,

• Completion of the Secondary Plant Reliability Study (included in references when-issued)

• Conduct of an independent (Stone and Webster) design review of the secondary plant (Reference 5)

• Ongoing Nuclear Assurance performance cvaluation for Operations and Maintenance departments ,

• NSRB subcommittee review of engineering backlogs (Reference 8) t

• EPRI review of the erosion / corrosion program ,

• Team reviews of high-risk SQN technical programs headed by the Chairman, NSRB ,

(Reference 6)

• Personnel / management evaluations (see Section IV.E)

III. Reviews / Assessments of Restart Plan Adequacy

• NSRB special session review to determine whether the restart plans are sufficiently comprehensive to ensure identification of problems requiring correction prior to restart and those necessary for long-term improvements (Reference 10)

• A review of the SQN Restart Plan (Reference 8) by a high-level Senior Management i Oversight Group using experienced industry managers and reporting to the Vice President, Nuclear Operations, and Vice President, Technical Support i

39

APPENDIX 1 IV. Reviews / Assessments cf Restart Plan Implementation and Effectiveness - Restart Readiness (in addition to the review and readiness processes described in Section V of this document) ,

i

• EPRI and Altran review of the E/C recovery program and long-term program upgrades l

• Multiple Nuclear Assurance and Indipendent Safety Engineering assessments, audits, and followups of department, backlog, and program areas (Reference 11)

• Contract expertise using Reedy Associates in the Section XI program areas and -

Impell and Altran in the E/C program areas ,

• The oversight panel for the team technical program reviews will review the actions i taken to address the team review findings ,

• A review by an Operations department Restart Readiness Team to assess and verify .;

the readiness of operations to conduct safe and effective reactor operations. This .

review team will be led by the Vice President, Nuclear Readiness (D. R. Keuter),  ;

and will be composed of senior TVA managers and industry consultants

• The Senior Management Oversight Group will conduct a week-long assessment of overall site readiness for restart, addressing management, organization, personnel, l hardware, and program issues (Reference 8) _

IV. Start-up Oversight

• Observations of the Operations department by Nuclear Assurance will continue )

during stan-up and mode change evolution

• The Operations department will have a team of nonshift SROs conducting 24-hour Operations oversight starting one week in advance of Mode 4 and continuing through achievement of 100 percent power i

40  !

4 1

1 i

APPENDIX 2 t'

=

b i

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4 41 I

Appendbc 2 Page 1 of 6 MANAGEMENT REVIEW OT ACTIONS FOR RESTART OBJECTIVE:

Evaluate what actions should be completed before restart of units. This includes establishing basis for what actions are NOT needed before restart.

TEAM:

R.A. Fenech R.J. Beecken J.N. Ward M.A. Cooper T.A. Flippo N.A. Welch APPROACH:

MARCH 12-15

1. Review NRC Inspection Manual enecklist issues.

2. Reevaluated SIP and 52 issues.

MARCH IS - 19

3. Review results of:

A. Program reviews (MARCH 19)_

B. Employee feedback (MARCH 15 - 16)

MARCH 15 - 16

4. Document assessment methodology including basis for decisions on NRC checklist MARCH 26

5. Document logic and basis for results of 1, 2 and 3 42

1 Appendbc 2 Pege 2 of 6 EMPLOYEE FEEDBACK l

OBJECTIVE:

Determine if other significant issues / problems exist which are ,

not identified or whether current assessment of significance (and .

therefore priority) of problems is appropriate. l i

'I APPROACH:

MARCH 12 - 15  !

1. Site VP direct reports and Plant Manager direct reports hold .

communication / brainstorming meetings with personnel down to levels identified on Attachment.

2. Provide copies of SIP and 52 issues list and explain how they ,

were developed and content.

3. Sollicit feedback on comprehensiveness and significance (risk .

and priority) of identified issues.

4. Sollicit identification of other problems with emphasis on i hardware concerns; document through development of list. -

5. Direct reports review feedback, and evaluate on issue evaluation form (Attachment) for subsequent management team review. '-

i MARCH 15 -

I

6. Site management team review.

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Appendbt 2 Page 3 of 6' ATTACHMENT f

I i

DIRECT REPORTS: .

P.G. Trudel- -

R.V. Drake T.A. Flippo  :

C.E. Kent H.R. Rogers L.S. Bryant  !

J.S. Baumstark f

i i

PERSONNEL LEVELS:  :

NE: direct reports and their direct reports i f

PROJECTS: project managers and above  ;

f-QA: direct reports and their direct reports CHEM /HP: shift supervisors and above  :

TECH SUPP:

~

engineers and above

~I MAINT: general foreman and above ~

OPS: cross-section of crews ,

WCG system evaluators and above  ;

i 4

l i

T 44

-, e m - , - - - ,

l l

1 Appendix 2 Page 4 of 3 PROBLEM EVALUATION FORM DATE:  ;

IDENTIFYING ORG:

KNOWLEDGEABLE CONTACT:

ISSUE / CONCERN:

t t

{

TRACKING DOCUMENT / SYSTEM IF ANY:

INTERIM ACTIONS:

{

SIGNIFICANCE / RISK: .

l EVALUATION:

RECOMMENDATION:

i EVALUATOR: DATE: i 45 1

1 I

Appendix 2 Page 5 of 6 TALKING POINTS NOTE: PROVIDE COPY OF SIP AND LIST OF 52 ISSUES

• Explain what SIP is and how it was developed:

- compilation of key issues affecting SQN performance

- developed through collaborative management team review of site performance and assessments (internal and external) against Corporate and SQN goals / objectives

- focus to identify key problems which are preventing SQN from achieving operational objectives - nuclear safety (including regulatory performance), plant reliability, and efficient operation

- collective team assessment of priorities and schedules based on significance - again significance tied to nuclear safety, plant reliability, and operational impact

- a "living", evolving document as actions are completed, priorities / schedules change, and/or new issues are. identified - intended to be a " road map" for overall site strategic direction to better focus efforts and priorities

• Recently identified secondary pipe leaks, erosion ~ program deficiencies and associated plant shutdown has initiated a reevaluation of SIP in terms of scope, priorities and schedule - is scope comprehensive? are schedules prudent given risks to effective operation? are there actions which should be completed before restart of the units?

• Management team again collectively reviewed SIP areas and through a brainstorming effort developed a list of 52 items for further consideration; that evaluation effort is ongoing. (refer to list of 52 items)

• - Additionally, given the significant program weaknesses identified in the erosion / corrosion area, eight teams have been formed using Corporate, Site, and industry experts to evaluate other key site program areas (e.g. ISI, EQ,Section XI, etc.) to determine if similar weaknesses exist and what actions are needed both in the short and long term.

• While the above efforts are providing a good foundation.for identifying and prioritizing improvement efforts, we want-to take the approach down another level, to receive your 46

Appendix 2 Page 6 of 6 feedback; to verify from another direction that the above scope is appropriately bounding problems and issues which  !

pose threats to safe and efficient operation (Sollicit feedback on SIP, 52 issues and SQN performance /

problems in general; below are suggested questions to i prompt discussion) <

i are there other key issues not included in SIP scope ? >

are there hardware problems that are either not identified or are not being appropriately addressed i.e.

Waiting to " bite us" are there problems where risk / consequences are not fully understood ? ,

are there processes or ways of doing business which are not well controlled ?

are there programs or requirements that are ill-defined  ;

or not well understood ?

NOTE: sollicit feedback in a brainstorming fashion; obtain sufficient detail to allow further evaluation; avoid introduction of restart considerations at this p7 int of discussion - looking for identification of unaddressed or inadequately addressed problems, without screening  !

against some predesignated restart schedule window; feedback to be used for both short_ term and longer term improvement efforts Document feedback by developing list of issues / problems to carry forward for further evaluation -

i

• Results of feedback from each organization will be reviewed and further evaluated as appropriate by the department level manager (e.g. Larry Bryant) for subsequent collective management team review l

r h

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47 [

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48

S63 930319 800 r

(-

4 March 19, 1993 Those listed on page 2 PROCESS FOR EVA1,UATING AND 3CHEDULING SEQUOYAH NUCLEAR ?LANT (SQN) RESTART ITEMS' The purpose of this memorandum is to (1) describe ' the proc 3ss for identifying and evaluating potential items for restart, (2) document the schedules previously discussed f or completing these evaluations and for presenting them to the Management Restart Review Committee (MRRC), and (3) transmit the latest restart list for your review and com=ent.

Attachment 1 is the " desk top" procedure to be used to identify and evaluate issues for restart. It describes how issues evaluated will be presented to MREC for review and concurrence and how issues identified as restart are scheduled for work. Please let either Gary S. Boles (pager 40404), Tom D.

Enight (pager 90699), or me know if you have questions or enm=ents on this procedure.

Restart issues have been and will centinue to be identified from employee input, the program evaluatien teams currently in place, and by SQN '

management's review of Sequoyah improvement Plan items and other issues. The items which are the result of e=ployee input should be screened by depart =ent managers. Input items to be further considered for restart shall be presented to MRRC by the responsible department manager. Please contact Mr. Soles to schedule a meeting with the committee. The schedule previously identified by '

me for evaluating and presenting to MRRC these employee feedback and other potential restart issues is shown below: -

E=ployee input items March 24, 1993-Existing items en the current March 13, 1993 potential restart list (Attach =ent 2) .

March 24, 1993

?rc5:am evaluatien team items 49

- (

i

[

. Those listed ,

Page 2  !

March 19, 1993 i

The MRRC meetings are currently occurring daily, and potential restart issues should be presented to MRRC as soon as the evaluatiens are completed. The items reviewed by MRRC will be added to the restart list (Attachment 2) with their restart determination documented. This list will be controlled by i Mr. Soles, AhW ) .

i Robert A. Fenech Site Vice President ,

OPS 4A-SQN J. S. Baumstark, PCB 23-SQN /

R. J. Seecken, P0B 23-SQN  ;

L. S. 3ryant, POB 23-SQN ,

M. A. Cooper, OPS 4C-SQN R. 7. Drake, OPS 4G-SQN T. A. Flipoo, S3 1C-SQN h

\j H. K. Fogl' man, e DSP 1A-SQN J. K. Gates, PCB 2C-SQN f

J. L. Hamilten. 53 1C-SCN C. E. Kent, ?03 2C-SQN ,

R. W. Martin, OPS 43-SQN R. R. Rausch, S3 2D-SQN ,

t H. R. Rogers, PCB 2C-SQN M. D. Shepherd STC 25-SQN i

?. G. Trudel, DSE 1A-SGN i P. R. Wallace, OPS hA-SQN -

J. N. Ward, OPS LH-SQN l N. A. Welch, P03 2A-SQN i L. J. Wheeler, OPS 1A-SQN i K. W. Whittenburg, OPS 3A-SQN l,

s OK:GS3:LK?  !

Attachments l cc (Attachments):

RIMS, MR 2F-C i

?L316201/1321 i

4 50

r,

' ~- <

8 ..

Restart Evaluation Process l

• 5 4

' Dept. Wgr. MRRC Individual MRRC Cwner Line Org.

' Yes Identify Supervisor Management Yes Assign Develop leptement

, W  ; Restart and loput W

'lstue- Concur F Review Owner schedule Work

!- Concurf

+ SIP Review

no No '

-Employee feedbatit Boles / Knight

-Program reviews Put into

-Management input Dept. Mgr,/WRRC Proj. Mgt. restert'  ;

list

$1P Yes Put into llem 7 US Sir w

No 5

Close or take okher ' As required actlons I

W i i

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1. D (4 .

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A1"IACEMCTI 1 PROCEDURE yCR RESTART E7A N '* TONS F

i i

Items identified that are potential restart items for This the units will be does not apply to .j subjected to a formal restart evaluation as f ollows.

items required by the technical specifications, high-priority outage work ,

order /vork requests, or items directed to be performed by the plant manager. .

Identificatien of Items Restart items may come from employee input to their supervisors, through Sequoyah Nuclear Plant management's review of Sequoyah Improvement flan items or through the identification of other issues, or from the program evaluatien ,

teams currently in place.

5 I

.r Evaluation of Items Items shall be determined to be restart or nonrestart through a technical evaluation which considers the following impacts and risks: {

4

[

Nuclear safety r

Planc reliability i I

t

• Regulatory .

I M Other reasons as determined by the evaluator ,

Past events or problems which could have been avoided or minimized had the item been properly addressed or implemented should be considered.  !

i i Items should be escalated through the nor=al management chain and documented  ;

on the attached form (page 2 of Attachment 1) for submittal to the department I manager. Items that have been previously identified and evaluated on a l

-I different but similar for=r do not have to be placed on the attached form. The  ;

item will then be presented to the Management Restart Review Committee Ud.RRC) I by the appropriate department manager and, if approved, will be returned to an '

cwner f or submittal to the restart schedule. >

I An owner will be deter =ined by FRRC. Sis person will be respcnsible. for coordinating with the appropriate organizations to develop and submit a  ;

schedule and for performing the following analyses: ,

t Cost based on a cost-benefit analysis j Durstion and impact on the current schedule ,

.i Man-hours  !

t Imract on resources based on the current schedule l

52 ,

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Date: l Cemcleted By: .

l Data: l l Sucerviser Cencurrence:

I Date: l Management Restar: Commit:ee Accreval: ~ i l -

' i

! Owner: I i .. I

! Cursticn recuired: l o

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I i

RESTART ITEM DELETION PROCESS t

Deletion of restart items from either the Unit 1 or Unit 2 out'gea schedules will be controlled in accordance with this process. In addition to the technical evaluation and approvals required by this process documented on the Restart Item Deletion Form (Attachment 3-2), restart item deletion requires '

that an Appendix I - Outage Scope Control Form (SSP-7.2) be completed and approved. Attachment 3-2, Restart Item Deletion Form, should be r completed / approved first and attached to the SSP 7.2 Appendix I Outage Scope Control Form for further processing. The individual responsible for initiating the restart item deletion completes Attachment 3-2 and obtains MRRC ,

approval. .

1 5

4

?

i r

I i

63

RESTART WORK TTEM DELETION FORM ATT. 3-2 RESTART ITEM IDENTIFICATION RESTART ITEM OWNER (RESTART LIST #, WORK DOC.#, UNIT, SYS, ETC.)

DELETION INITIATOR ITEM / WORK DESCRIPTION: ,

REASON FOR DELETION (Schedule impact, Mtl Availabl!!ty, Other)

SYSTEM ENGINEER TECHNICAL EVALUATION / BASIS FOR RESTART ITEM DELETION (Address nuclear safety impact, affect on technical specification compliance, and risk to plant operation and re!! ability if this work is not completed prior to restart. Compensatory measures and/or ,

attemate means of addressing the problem / issue if not worked prior to restart needs to be included.)

Cognizant System Engineer Signature ~ Date MANAGEMENT RESTART REVIEW COMMITTEE (MRRC) APPROVAL MRRC Approval Signature Date DISTRIBUTION OF APPROVED FORMS:

A. Disapproved form to Deletion initiator B. Approved form:

- Original to Deletion initiator to be attached to a completed Figure 1 - Outage Scope Control Form (Appendix 1, SSP-7.2) and submitted to the Outage Manager on the affected unit.

- Copy to P M & C to remove item from restart list

- Copy to Cognizant System Engineer 64

RESTART WORK ITEM DELE . l .ORM  ;

ATT. 3-2 RESTART ITEM IDENTIFICATION RESTARTi cM OWNER (RESTART LIST #, WORK DOC.#, UNIT, SYS, ETC.)

DELETION INITIATOR ITEM / WORK DESCRIPTION:

REASON FOR DELETION (Schedule impact, Mt! Availability, Other)

SYSTEM ENGINEER TECHNICAL EVALUATION / BASIS FOR RESTART ITEM DELETION 2

Cognizant System Engineer Signature Date MANAGEMENT RESTART REVIEW COMMITTEE (MRRC) APPROVAL MRRC Approval Signature Date DISTRIBUTION OF A2 PROVED FORMS:

A. Disapproved form to Deletion Initiator B. Approved form:

- Original to Deletion trutiator to be attached to a completed Figure 1 - Outage Scope Control Form (Appendix 1, SSP-7.2) and submitted to the Outage Manager on the affected unit.

- Copy to P M & C to remove item from restart list

- Copy to Cognizant System Engineer I

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APPENDIX 4 66

\.

BACKLOG REVIEW PROCESS l OBJECTIVE }

• Identify all site backlogs as of May 1, 1993, and review (verify  !

reviewed) to determine whether either the individual or aggregate impact l of backlog items needs to be addressed before startup.  ;

l

+ Identify emergent backlog items af ter May 1,1993, and evaluate them tor j restart.  ;

i

- The backlog review process, which defines the responsibilities of I department managers (backlog owners), the BRC, system engineers, the [

Management Restart Review Committee (MRRC), and other site  !

organizations, will be used to accomplish this task. j PROCESS i

I. Ensure Full Scope of Backlogs Identified - Department Manager I A. A backlog item is a pre-May 1, 1993, item. j i

B. Beginning with the Sequoyah Improvement Plan (SIP) list, department  ;

managers review to affirm that other lists do not exist (e.g., EQ ,

binder update backlog, NER, and licensing commitments and identify . l additional lists to Backlog review Committee (BRC) by May 10, 1993. . l; Note: A backlog is considered to be any accumulation of unimplemented -  ;

work beyond active in-process levels. Questions.regarding the j application of this definition should be discussed with the l Management Restart Review Committee (MRRC).  !

C. Backlogs to be reviewed by system will be reviewed against the list of systems (Attachment 1-A) developed by Technical Support and the  ;

BRC as of May 17, 1993. These systems are typically safety,_ '

reliability, or balance of plant (BOP) related or common. Systems ,

not included are, in general, non-process systems. l t

D. The list of site backlogs identified as of May 17, 1993, and i categorized as requiring either BRC or~ department manager reviews is shown in Attachment 1-B. BRC evaluated backlogs are further broken j down in Attachment 1-B to identify which will receive review by i system and which will receive a programmatic review. The basis for ,

backlog categorization is also shown in Attachment 1-B.  !

i II. Department Managed Backlogs Backlogs identified in Attachment 1-B as " Department Managed Backlogs"  !

will be reviewed for restart by the department with recommended restart  !

items brought to the MRRC for final restart determination, following the ,

normal process. Each postrestart backlog in the Department Managed l Backlog category will be evaluated by the department manager using the l

process in Attachment 4.  ;

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III. Backlog Review Committee Evaluated Backlogs - Department Manager ,

Responsibilities  ;

i A. Review (or verify reviewed) backlogs as of May 1, 1993, against  !

restart evaluation criteria (Attachment 2). i Note: Attachment 2 criteria reflect reformatting and explanation of application of essentially the same criteria previously )

distributed for use.

B. Backlog Review Documentation i

1. Group backlog items by system. Evaluate backlog items against l restart criteria in Attachment 2 and document the department  !

manager evaluation on the form in Attachment 3. A separate form is required for each item for the following backlogs:

Major Issues Lists (MILS)

CAQs (II, PER, FIR, CAQR, SCAR)

Items for other backlogs on the same system and with the same restart call may be grouped on one Attachment 3 form.  :

2. Department managers (backlog owners) provide evaluations as '

discussed in Item 1 to the BRC.  ;

C. Evaluation of Postrestart Backlog (department manager only - not 3RC)

1. Backlog Composition Evaluation (Attachment 4) '

2. Backlog 'Humber" Evaluation (Attachment 4)

3. Present completed Attachment 4 to the MRRC as described in Section IV below.

IV. Backlog Review Committee (BRC)

A. The BRC charter, including members, is shown in Attachment 5.  ;

i B. BRC Process

1. The BRC evaluates department manager review documented in Attachment 3 against restart criteria in Attachment 2:

- Review "YESs" and "N0s" for CAQs and DCN/ MIL backlogs

- Review only N0s for other backlogs j

2. Affected system engineers will participate in the BRC review.

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3. The BRC may schedule department managers to meet with the BRC/ system engineers if discussion or more detail is needed.  ;

4. The system engineer and the BRC will concur and/or resolve any differences with the department manager and document concurrence by signing Attachment 3. The continuation page for Attachment 3 ,

is provided for either the system engineer or the ERC to provide comments, basis, etc., resulting from their assessment. l V. MRRC Review of Backlog Evaluation A presentation will be made to the MRRC for each backlog evaluated by the BRC. Each presentation will consist of two parts.

A. Attachment 3 Evaluations for Restart l Backlog items will be grouped and presented in three categories:

restart, nonrestart, and " grey." The presentation will focus on the "YES" and " grey" items with the MRRC making / concurring with restart calls for these items. Backlog presenters to the MRRC will include the backlog owner, the BRC, or system engineers, as appropriate.

The backlog presenter is responsible for documenting restart decisions made in the MRRC meeting en Attachment 3 forms. The disposition of Attachment 3 documentation at the end of the MRRC meeting is as follows:

1. "N0" Ita.ms to Project Management and Controls (PM&C) for Postrestart Schedule

2. "YES" items to PM&C for Restart Schedule

3. All Documentation to System Restart Notebooks ,

B. Department Manager Characterization of Postrestart Backlog (Attachment 4)

VI. Review of Emergent Items for Restart After May.1, 1993 (End Date for Backlog Review Committee)

A. Emergent items after May 1, 1993, will be handled as shown in Attachment 6.

B. Maintenance work requests / work orders (WI J/W0s)

The Maintenance department submits WRs/W0s to Operations for restart i determination:

1. "YES" maintenance WRs/W0s scheduled by Work Control in accordance with Site Standard Practice (SSP) 7.2.

r 69

2. 'HO" maintenance WRs/W0s will be evaluated by the Maintenance department as part of their postrestart backlog evaluation (refer to Attachment 4) which, in turn, is input to Maintenance department readiness (Appendix 6).

C. Conditions adverse to quality / justifications for continued operation (CAQs/JCOs) and major issue list (MIL) items Corrective Action Management Review Team evaluates CAQs/JCOs for restart; Plant Improvement Committee (PIC) evaluates MIL items for restart.

1. 'WO" items returned to department manager (owner) to be included in his/her postrestart backlog evaluation (refer to Attachment 4) which, in turn, feeds that department's readiness assessment (Appendix 6).

2. "YES" items returned to department manager (owner) for submittal  ;

to MRRC for final restart determination j t

"YES" items from MRRC meeting to restart schedule in accordance with SSP-7.2 l v

"NO" items from MRRC meeting to department manager (owner) to be included in his/her postrestart backlog evaluation (Attachment 4) which, in turn, feeds that department's Department Readiness assessment (Appendix 6) i D. System Engineer Evaluations  ;

i' Emergent 1+ams and their corresponding restart determinations in Paragraphs b and C above will be identified and evaluated by system engineers as part of their System Readiness assessment (refer to Appendix 5) i E. Other Emergent Items All other emergent items from the backlog lists in Attachment 1-B and other sources will be evaluated by the department manager (owner) for restart.

1. "YES" items will be brought to the MRRC for final restart determination following normal process.

2. "NO" items will be included in the department manager's postrestart backlog evaluation (Attachment 4), if applicable. ,

All items in this category will feed the department's Department Readiness evaluation (Appendix 6).

I PLO90204/2752 I 70

i

'l ATIACEMENT 1-A i

SYSTEMS LIST I

i

+ 001 Main Steam System j

- 002 Condensate System l

- 003 Main and Auxiliary Feedwater System f

. 005 Extraction Steam System  !

+ 006 Heater Drains and Vents System j

- 007 Turbine Extraction Traps and Drains System

- 012 Auxiliary Boiler System  ;

• 013 Fire Protection (Other than High-Pressure Fire Protection and 002 Fire Protection) l

- 014 Condensate Demineralizer System  ;

- 015 Steam Generator Blowdown System I

- 018 Fuel Oil System

+ 020 Central Lubricating Oil System

• 024 Raw Cooling Water System l 025 Raw Service Water System 026 High Pressure Fire Protection System i

- 027 Condenser Circulating Water System l 029 Potable (Treated) Water Distribution System i 030 Ventilating System 031 Air-Conditioning (Cooling - Heating) System  !

- 032 Control Air System ,

033 Service Air System l 034 Vacuum Priming System 035 Generator Hydrogen Cooling Systems ,

036 Feedwater Secondary Treatment System

• 037 Gland Seal Water System 039 CO, Storage, Fire Protection, and Purging System -

040 Station Drainage System -

041 Layup Water Treatment System ,

042 Chemical Cleaning System 043 Sampling and Water Quality System

- 046 Feedwater Control System

- 047 Turbogenerator Control System  !

050 Hypochlorite System .

052 System Test Facility (Seismic Instrumentation)

= 054 Injection Water System 055 Annunciator & Sequential Events Recording System 056 Temperature Monitoring System

- 057 Associated Electrical Systems (Generator)

+ 058 Generator Bus Cooling System 059 Demineralizer Water & Cask Decontamination System 061 Ice Condenser System

- 062 Chemical and Volume Control System  !

+ 063 Safety Injection System

- 065 Emergency Gas Treatment System  ;

+ 067 Essential Raw Cooling Water System  :

068 Reactor Coolant System l

• Focus Systems - System Engineer Walkdowns as a Part of System Readiness l l

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SYSTEMS LIST 1

4

+ 070 Component Cooling System ,

072 Containment Spray System

+ 074 Residual Heat Removal System I 077 Waste Disposal System 078 Spent Fuel Pit Cooling System (Fuel Holding and Cranes)  !

079 Fuel Handling and Storage System  ;

081 Primary Makeup Water System

+ 082 Standby Diesel Generator System 083 Hydrogen Recombination System .!

084 Flood Mode Boration System '

085 Control Rod Drive System 088 Containment Isolation System 090 Radiation Monitoring System i 092 Neutron Monitoring System  ;

094 Incore Monitoring System i 099 Reactor Protection System

• 200 Status Monitor System >

+ 201 480-VElectricalBoardsandMotorContrglCenter

+ 202 6900-V Electrical Boards (Logic Panels) .i 234 Heat Tracing System

+ 241 Switchyard and Transformers (Including 22.5, 161, & 500-kV) 244 Communication System '

245 Security Systems 247 Lighting Systems

+

250 AD/DC low Voltage Power System 263 Condenser. Tube Cleaning System .

268 Permanent Hydrogen Mitigation System 1 301 P-250 Camputer System  ;

302 Penetrations and Sleeves (Mechanical and Electrical) '

305 Sewage System _

+ 311 Control Building Heating, Ventilating, and Air-Conditioning (Instruments and Valves) (was 31A)

+ 313 Auxiliary Building Heating, Ventilating, and Air-Conditioning  !

(Instruments and Valves) (was 310) 317 Miscellaneous 410 Building Doors and Hatches (Includes Architectural Doors) 928 Makeup Water Treatment Plant Electrical Equipment >

959 Demineralizer Water Storage & Distribution System for i Makeup Water Treatment Plant

+

Focus Systems - System Engineer Walkdowns as a Part of System Readiness 1

l 1

PLO90204/2752 l 1

72 1

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ATIACEMENT 1-B BRC EVALUATED 3ACKLOGS

+ 1. WR/WO (incudes orange ball list and defeated annunciators) *

+ 2. JCO/EE *

• 3. Comp Measures *

+ 4. Open DCNs *

• 5. Hold Orders *

6. Drawing Changes - Cat 2 & Cat 3

+ 7. Operator Aids *

• 8. Obsolete Equipment

+ 9. Issues (DCRs, MILS) **

10. Deferral Request PMs ' Appendix L'

11. Procedure Revisions

12. Vendor Manual Updates

13. DD Backlog

14. SSD Backlog

+ 15. CAQs (II, PER, FIR, PDFIR, CAQR, SCAR) **

16. Q-List

+ 17. TFARs *

18. NER Items *

• 19. TACFs *

20. NRC Commitments *

• 21. Technical Support Investigation Requests *

22. Old Work Plans

23. Weld Maps

24. SMIs

25. EQ Backlog

26. UVAs in Design Inputs

• Areas to be looked on a systems basis. All other areas will be reviewed on a programmatic basis.

• BRC reviewed each item.

• • BRC reviewed each item and will have individual review paper.

PLO90204/2752 73

l l

DEPARIMENT EVALUATED BACKLOGS i

1. QA Level II (No RIP)

2. Material Requirements  ;

3. Instrument Data Packages

4. Labels- t

5. NPRDS Data Input

6. PRO, TROI Items

7. FSAR Changes '

8.. EMS Updates (Fuse Tab Updates Included)

9. Tech Spec Changes

10. Delinquent FM

11. Bid Reviews, Bin Reviews, Inspection Reports (PEG Material Issues)

12. ECN/DCN Backlog Closure

13. DCN Impact Review

14. Maintenance History Updates

15. Administrative Hold Procedures [

16.

PEG /DCN Procurement

17. 56 RIP Item Work Off 6/15 l

18. Calculation Cross Reference Systems (CCRS)

19. Non-TS sis (Assume 200 Manhours / Group) l

20. RCM Study }

21. SI Reviews  ;

22. SPTS t

23. FSAR Reviews i

i PLO90204/2752 s

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1 BACKLOG CATEGORY BASIS j l

Catecory A - Basis for BRC Backlogs i Basis for Backlog List:

+ Could directly affect plant process equipment from a safety and reliability standpoint.

Basis for System vs. Program Review:

. Typically hardware-related or high potential to impact hardware issues  ;

• Supports review by system to obtain aggregate impact on system i functionality / reliability

. Potential to have significant impact for safe and reliable operation i Catecorv B - Decartment Manaced Backlocs

. Typically non-hardware administrative / management issues or with minor / indirect hardware impact potential

+ Not considered to constitute a significant potential impact to safe and reliable operation

• The department manager is to assess restart /non-restart and 13 pact to manage postrestart 75

ATTACHMENT 2 t RESTART EVALUATION CRITERIA r

Actions needed to ensure technical specification (TS) operabil'ity will be completed before entering a mode for which associated requirements ar. I applicable. Actions needed to satisfy NRC docketed commitments or agreements associated with the current outages (e.g., CAL items) will be completed before restart. The following screening criteria will be used to evaluate other open  ;

items / issues to determine what additional actions should be taken before i restart of the units from the current outage. The criteria establish basic considerations involving nuclear safety, plant reliability, and operational impacts for which assessments and judgments must be applied, e.g., degree and .

probability or conservatively assessed and presented to the MRRC by the  !

responsible organization / owner. The MRRC will either approve the item / issue for restart scope inclusion or will provide the basis for why the item / issue should be addressed following restart scope modified.

• Adverse impact on safety system availability or performance, e.g.,

potential for causing frequent entry into TS action statements, potential for entry into short-term TS action statements, and potential to render a component or system incapable of performing intended design function.

• Significant challenge to plant / personnel performance because of either

• individual or aggregate impact, e.g., high numbers of compensatory  ;

actions, disabled annunciators, and high maintenance backlog.

i

• High potential to impact plant operating reliability, e.g., likelihood for causing trips / transients, common or single failure point weaknesses, necessitates entry into short-term TS action statements, and likelihood for hardware failure before the end of the next operating cycle.  ;

• Prudency of or need for working during twolunit outage, e.g., reduced TS action statement applicability, reduced outage risk, and reduced operational impact.

The above cr seria do not preclude approval and inclusion 'of activities that do not meet the criteria but are determined desirable / prudent in consideration .

of overall site objectives, e.g., activities associated with ALARA, resource, and/or efficiency optimization.

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BACKLOG REVIEW FOR RESTART ATT.3 BACKLOG ITEM DEPARTMENT MANAGER SYS NO.

(Document #)

DESCRIPTION RESTART EVALUATION CRITERIA

[ ] 1. Actions needed for technical specifications operability. [ ] 5. Adverse individual or aggregate impact on safe,

[ ] 2. Adverse impact on safety system availability or reliable operations including potental for significant'y performance. challenging plant / personnel performance.

[ ] 3. Potental for causing either entry ir.to short-term [ ] 6. High potentalto jeopardize plantteliability.

tech. spec. acton statement or irequent entry into [ ] 7. Prudent for working dunng two-unit outage.

tech. spec. action statement. [ ] 8. No restart criteria are applicable to this item.

[ ] 4. NRC docketed commitments associated with the current outages.

DEPARTMENT MANAGER JUSTIFICATION (Provide justification for review of item. Dept. Mgr. to determine the appropriate method to document.

Considerations should primarily address restart criteria but can also include age; not critical system or critical issue; restraints (material, plant condition req'd to work); etc. Items on a single system may be justified together provided the basis for restart or non-restart is the same ; eg. instrument data packages on the same system.)

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Dept. Mgr.: Restart Recommendation l W Yes W No l SYSTEM ENGINEER REVIEW System Engineer Concurrence: Restart Yes R No BACKLOG REVIEW COMMITTEE l

l Backlog Review Committee Concurrence:

Restart ] Yes l l No MANAGEMENT RESTART REVIEW COMMITTEE (MRRC) l (MRRC to review for concurrence the "Yes" and

• Grey" restart items identfied by BRC)  !

1 MRRC Concurrence, as Applicable: Restart R Yes ] No 77

BACKLOG REVIEW FOR RESTART ATT.3  :

BACKLOG ITEM DEPARTMENT MANAGER SYS NO.

t DESCRIPTION >

RESTART EVALUATION CRITERIA

[ ] 1. Actons needed for technical specificatons operability. [ ] 5. Adverse individual or aggregate impact on safe.

[ ] 2. Adverse impact on safety system availabi!!'y or reliable operations including potential for signdicantly performance. challenging planthersonnel perforrnance.

[ ] 3. Potental for causing either entry into snort-term [ ] 6. High potental to jeopardize plant reliability. >

tech, spec. action statement or frequent entry into [ ] 7. Prudent for working dunng two-unit outage. ,

tech. spec. acton statement. [ ] 8. No restart criteria are applicable to this item. *

[ ] 4. NRO docketed commitments associated with the current outages.

DEPARTMENT MANAGER JUSTIFICATION t

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Dept. Mgr.: Restart Recommendation Yes No s

SYSTEM ENGINEER REVIEW I

System Engineer Concurrence: Restart Yes W No j 1

BACKLOG REVIEW COMMITTEE >

i I '

i Backlog Review Committee Concurrence: Restart Yes No

• l MANAGEMENT RESTART REVIEW COMMITTEE {MRRC)  ;

t Yes  !

MRRC Concurrence as Applicable: Restart l l No 78

Page 3 of 3 BACKLOG REVIEW FOR RESTART ATT.3 (CONTINUATION PAGE)

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",~ . k, ITEM IDENTIFICATION SYSTEM NO.

NAME / DATE:

l ORGANIZATION: l ,

NAME / DATE:

ORGANCATION:

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l NAME / DATE: {

ORGANIZATION:

i NAME / DATE: i ORGANIZATION: ,

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4 ATTACHMENT 4  :

EVALUATION OF POST RESTART BACKLOGS BACKLOG RESPONSIBLE DEPARTMENT MANAGER PART A  : BACKLOG COMPOSITION EVALUATION)

BACKLOG ITEMS (Attach post restart backlog by system. Backlog may be further grouped or arranged in a way which facilitates evaluation of its composition.)

SIGNIFICANCE OF POST RESTART BACKLOG TO RESTART CRITERIA (Attach evaluation / basis for why the post restart backlog, when compared to restart criteria, are acceptable as post restart. Backlog items may be grouped or adressed individually, as appropriate; categorized by age, system, significance; or otherwise packaged by the Dept. Mgr to best characterize composition.)

DEP/ .IMENT MANAGER APPROVAL DATE (This signature signifies that the department manager concurs with the restart determination t

for backlog items on part A of this form.)

PART B BASIS FOR BACKLOG RESTART NUMBER ! _

POST RESTART " MAINTENANCE" PLAN (Why/how can backlog be effectively managed post restart? Consider a!!ocation of resources, incoming items post restart, etc.)

r RELATIONSHIP TO INDUSTRY STANDARDS ,

(Is post restart backlog consistent of better than industry averages, INPO indicators, Brunswick Nuclear Plant startup levels, etc.7) i DEPARTMENT MANAGER APPROVAL DATE ,

(This signature signifies that the department manager has determined by the evaluation in part B that the post restart backlog number supports restart and subsequent operation.)

MRRC APPROVAL DATE 80

i ATTACHMENT 4 EVALUATION OF POST RESTART BACKLOGS i i

BACKLOG RESPONSIBLE DEPARTMENT MANAGER i

PART-A4 BACKLOG ' COMPOSITION EVALUATIONS ^

BACKLOG ITEMS 1

i i

SIGNIFICANCE OF POST RESTART BACKLOG TO RESTART CRITERIA i

L i

i DEPARTMENT MANAGER APPROVAL DATE j

~

? BASIS FOR BACKLOG RESTART NUMBERi #

2  :

. PdRT B?

POST RESTART " MAINTENANCE" PLAN  ?

i l

l RELATIONSHIP TO INDUSTRY STANDARDS [

DEPARTMENT MANAGER APPROVAL DATE .;

I 3

MRRC APPROVAL DATE +

i 81 I 1

k ATTACHMENT 5 t

BACKLOG REVIEW CCMMITTEE (BRC) CHARTER The BRC is established by the SQN Vice President as a subcommittee of the i Management Restart Review Committee (MRRC). The BRC consists of the following members: ,

H. R. Rogers, Lead  ;

M. J. Lorek  :

I. Dibiase [

C. Brimer The BRC is empowered to identify and evaluate all existing site backlogs as of

• May 1, 1993, for their individual and aggregate impact on restart and, with the recommendation of the backlog owner and affected system engineer (s), to i make restart decisions on all backlog items. specifically, the BRC will:  ;

A. Establish the site backlog review process, defining the relative responsibilities of the site department managers (backlog owners), system engineers, MRRC, and Project Management and Controls (PM&C), and obtain 1 MRRC approval.

B. Implement the process approved:

a

1. Establish schedules for site organization evaluation and for l participation in BRC meetings, maintaining overall status of BRC work, including organization, backlog, and system completion. .

2. Define and maintain records and documentation associated with the process.

3. Provide written and verbal communication of BRC results to affected-organizations (department managers and PM&C and to the MRRC.

C. Use the collective experience and judgement of BRC members to evaluate the individual and collective impact of backlog items against the restart evaluation criteria to identify items that do and do not need to be completed prior to restart. The consideration of the causes of past transients and significant equipment, program, and personnel performance ,

problems will provide a basis for the BRC's application of restart

• criteria to backlog items and issues. For individual or aggregate items that are not " clean cut" restart /postrestart or items for which >

significant schedule / resource impacts would be involved, the BRC will assess and document the level of equipment, personnel, or program performance risk that could be expected if the issue is not resolved prior to restart and present these issues to.the MRRC for final resolution.  ;

k 82  ;

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D. Backlogs present risk to effective plant operation because of the affect t of individual or aggregate items and because of the demands that backlogs place on line organizations to manage them. Collateral to the BRC's 2 primary responsibility, the BRC will document observations and I'ormulate recommendations for improvement of how the site accumulates and manages backlogs for senior site management consideration. Recommendations may  ;

include improvements that could result from a combination of existing backlogs, improved backlog processes, clarification of ownership, or i' utilization of backlog indicators that flag significance as opposed to backlog number. Consideration will be given to how the present condition of backlogs was reached and measures to prevent this from occurring in the E

future.

The backlog review process for which the BRC is responsible is shown in the l attached flowchart.

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BACKLOG REVIEW PROCESS DM BRC BRC DM' DM SE SE PREPARE RESTART PRESENT BACKLOG BY RECOMMEND RESTART IDENDFY I

-> BAC OG BY 4 .

SCR F 0 R SP. SYSTEM BAS RESTART PROPOSAL ENGINEERS d L NEED YES MORE NO INFO,

. i DM BRC SE MRRC PM&C t u

- ca i

• YES RESTART PRESENT TO w REVIEW EVALUATION RESTART 7 SCHEDULE MRRC MAKING RESTART YA4 CALLS FOR

• GREY' AREAS AND OTHER CHANGES DETERMINED NECESSARY NO

-u PM&C p SE POST SYSTEM NOTEBOOK ' NS RESTART. _, y _ Ry

- SCHEDULE DM DEPARTMENT MANAGER -

SE SYSTEM ENGINEER - ISEG NRC BRC BACKLOG REVIEW COMMITTEE REVIEW REVEW PM&C. PROJECT MANAGEMENi'& CONTROLS MRRC MANAGEMENT RESTART REVIEW COMM11 TEE-1SE G - INDEPENDENT SAFETY ENGINEERING GROUP NRC NUCLEAR REGULATOsWCOMMISSION -

NSRS ' NUCt. EAR SAFETY REVIEW BOARD 4

\

rw -s yr w-- v ,evg-w. .ywgw ><- w y=,--yv-y = vt ry e up *--w,c

• y- v'- e v w 3Emev 'gw+ m1wg- + v' -v .,re m + we +'s e -+ewswmvg4- -we--aw +w -r-ww wew ***-Wr+w--o--rwn 'e-u----ee dies----* v---r,*e-*a -w-m

= e r ==< - -_+ -e'+6M

w ATTACHMENT 6 EMERGENT ITEMS DM DEPARTMENT MANAGER (AFTER 5/1/93 & PRIOR TO SYSTEM READINESS) OPS OPERATIONS OM OUTAGE MANAGERS SE SYSTEM ENGINEER PIC PLANT IMPROVEMENT COMMITTEE MRRO MANAGEMENT RESTART REVIEW '

OPS COMMITTEE CA MGT REVIEW TEAM Plc OM SE RESTART SYSTEM OPS RESTART - - .

• SCHEDULE >

DM YES PER SSP-7.2 NOTEDOOK t DM CALL FOR MAINT.

WR/WOs d iL IS ITEM OWNER EMERGENT ITEM YES ITEM MAINT. YES SUDMIT FOR CA MGT. RENEW MAINT.

IDENTIFIED BY DEPT

'MGR (CATEGORIES IN

- NAO+ RESTART ~ TEAM REC' ART witjWO CAO, OR MIL CALL FOR CAQs & yin ATT.1-B) EVALUATION YM JCOs PK RESTART CA MGT CALL FOR MILS REVIEW TEAM, Y

( START ) Plc p DM NO EVALUATOR PROVIDE (D

.u U DM W!TIESTART HO RECOMMENDATION TO DEPT. MGR. OETERMINE PRIORM FOR MK IF DEPT. MGR. FOR SE PRESENTATION TO MARC RESTART BRING TO MARC INPUTTO FOR REVIEW. IF POST -> SYSTEM -

RESTART, ENSURE ITEM IS '

READINESS INCLUDED IN POST RESTART BACKLOG EVAL ANO IS 'MRRC SCHEDULED POST RESTART s CONCURRENCE 4

Y/N DM POST RESTART DM BACKLOG INPUT TO NO COMPOSITIONa DEPT.

NUMBER READINESS EVALUATION I,

(ATT. 4) i h

POST

• RESTART l

t

..____,..._,..-.._.,._.u._-_ _ - _ . . . . ~ ~ . ~ . - . . . ~ , _ . _ _ . _ _ . . . _ . . _ _ _ _ ~ . _ , , - . . _ . - - -

- _ _ _ _ . . _ . _ _ . _ . . - . . . . _ . , . . _ , _ . . ~ . . . . .

APPENDIX 5 h

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SYSTEM READINESS PROCESS A. Preliminary System Readiness Review (PSRR) ( Attachment 2)

1. List of systems for System Readiness evaluation is provided in Attachment 1. Systems are safety, reliability, or BOP related or are common systems. Systems not included for System Readiness are, in general, non-process systems. Focus systems are chosen for BOP plant reliability, common / shared systems, or emergency core cooling systems and require system walkdowns as a part of System Readiness.

Typically, focus systems were selected based on highest potential impact to plant safety and reliability.

2. System engineer review to ensure that:

- Restart items on the system have been closed (punchlist open items)

- Emergent items are properly evaluated for restart

- Backlog items have been properly evaluated for restart and collective impact of open, nonrestart items will not impact the system's ability to support safe, reliable startup and operation

3. Backlog review committee (BRC) review, concurrence with system engineer review. .

4. Technical Support Manager approval of system engineer review and 3RC '

review.

5. Management Restart Review Committee review (via presentation) and approval.

B. Iinal System Readiness Review (Attachment 3)

1. System engineer review and affir=ation that:

- PSRR complete with punchlisted items closed and any system engineers' concerns resolved _

Emergent items since completion of the PSRR have proper restart  :

calls and restart items are closed

- System engineer walkdowns on systems (Attachment 4) are complete as determined by the Technical Support Manager

- Reviews of information related to recurring equipment / system problems (adverse trends) completed and a plan to address in place ,

- Priorities for continued improvement of system perfomance and system material condition established

2. Systems engineer's supervisor review and approval.

3. Technical Support Manager review and approval.

PLO90201/3026

I ATTACEFINT 1

. SYSTEMS LIST I

+ 001 Main Steam System

. 002 Condensate System

- 003 Main and Auxiliary Feedwater Systen

- 005 Extraction Steam System

- 006 Heater Drains and Vents System

= 007 Turbine Extraction Traps and Drains System

- 012 Acriliary Boiler System

+ 013 Fire Protection (Other than High-Pressure Fire Protectien and CO2 Fire Protection) i

+ 014 Condensate Demineralizer System

- 015 Steam Generator Blowdown System

+ 018 Fuel Oil System

+ 020 Central Lubricating Oil System

- 024 Raw Cooling Water System .

0 15 Raw Service WaterSystem 026 High Pressure Fire Protection System 027 Condenser Circulating Water Syste=

029 Potable (Treated) Water Distribution System '

030 Ventilating System --. -

031 Air-Conditioning (Cooling - Heating) System

- 032 Centrol Air System 033 Service Air System 034 Vacuum Priming System

+ 035 Generator Hydrogen Cooling Systems 036 Feedwater Secondary Treatment System

+ 037 Gland Seal Water System 039 CO 2 St rage, Fire Protection, and Purging Systen ,

040 Station Drainage System -

041 Layup Water Treatment System 042 Chemical Cleaning System 043 Sampling and Water Quality System

+ 046 Feedwater Control System

+ 047 Turbogenerator Centrol System i, 050 Hypochlorite System .

052 System Test Facility (Seismic Instrumentation)

= 054 Injectica Water System >

055 Annunciator & Sequential Events Recording System 056 Temperature Monitoring System

. 057 Associated Electrical Systems (Generator) 058 Generator 3us Cooling System -

059 Demineralizer Water & Cask Decontamination System e 061 Ice Condenser System ,

• 062 Chemical and Volume Control System

- 063 Saiety injection System

+ 065 Emergency Gas Treatment System

+ 067 Essential Raw Cooling Water System 068 Reactor Coolant System

+ Focus Systems - System Engineer Walkdowns as a Part of System Readiness 88 i

SYSTEMS LIST

+ 070 Component Cooling System 072 Containment Spray System

. 074 Residual Heat Removal System 077 Waste Disposal System 078 Spent Fuel Pit Cooling System (Fuel Holding and Cranes) 079 Fuel Handling and Storage System 081 Primary Makeup Water System

. 082 Standby Diesel Generator System ,

083 Hydrogen Recombination System 084 Flood Mode Boration System 085 Centrol Rod Drive System 088 Containment Isolation System 090 Radiation Monitoring System 092 Neutron Monitoring System 094 Incore Monitoring System 099 Reactor Protection System 200 Status Monitor System

= 201 480-V Electrical Boards and Motor Contrgl Center

- 202 6900-V Electrical Boards (Logic Panels) 134 Heat Tracing System Switchyard and Transformers (Including 22.5, 161, & 500-kV)

- 241 244 Communicatien System .

245 Security Systems  ?

247 Lighting Systems  ;

• 25 0 AD/DC Low Voltage Power System 263 Condenser Tube Cleaning System 268 Per=anent Hydrogen Mitigation System 301 P-250 Computer System 302 Penetrations and Sleeves (Mechanical and Electrical) 305 Sewage System 311 Control Building Heating, Ventilating, and Air-Conditioning .

(Instruments and Valves) (was 31A) a 313 Auxiliary Building Heating, Ventilating, and Air-Conditioning (Instruments and Valves) (was 31C) 317 Miscellaneous 410 Building Doors and Hatches (Includes Architectural Doors)  :

928 Makeup Water Treatment Plant Electrical Equipment 959 Demineralizer Water Storage & Distribution System for  ;

Makeup Water Treatment Plant

• Tocus Systems - System Engineer Walkdowns as a Part of System Readiness i

PLO90204/2748 89

s PRELIMINARY SYSTEM READINESS REVIEW FORM ATT. 2 SYSTEM NO / NAME SYSTEM ENGR. I SYSTEM ENGR. REVIEW

SUMMARY

(The System Engr. sha!! Initial each item below to Indicate that j required reviews have been completed) ,

Restart items identified for this system have been completed (Attach punchlist of currently open restart items) {

l Emergent items since 5/1/93 have been evaluated for restart. Attach any System Engineer concems for emergent items recommending disposition.

Backlog items prior to 5/1/93 have been evaluated for restart and for the collective impact of open non-restart backlog items on this system. Attach any systera engineers concems regarding backlog reviews on the collective impact of open i non-restart items on the system REMARKS (The System Engirseer can provide any addtional relevant information deemed necessary to provide a complete summary of system readiness.)

System Engineer Signature Date BACKLOG REVIEW COMMITTEE (BRC) EVALUATION (The BRC wi!! review the System Engineer PSRR documented above. Changes recommended by BRC wi!! be documented on applicable BRC forms, concurred with by the System Engineer via his initials /date, and attached to this form.)

BRC Review & Concurrence Signature Date TECHNICAL SUPPORT MANAGEMENT REVIEW AND APPROVAL Technical Support Manager Signature Date MANAGEMENT RESTART REVIEW COMMITTEE (MRRC)

(The Technical Support Manager will present the results of the Prelimina'ry System Readiness Review to MRRC. MRRC signature will signify concurrence with system readiness including restart /non-restart changes made by the system engineer as documented above or by BRC with system engineer concurrence as documented above. Changes made by MRRC during the system <

readiness presentation shall be documented on or attached to this form.) l MRRC Approval Signature Date f I

DISPOSITION OF FORMS Attachment 1 with attachments (original) - System notebook Changes to Restart Decisions or New Restart items as a result of the Preliminary System Readiness  ;

Review:

- New Restart or Changes from Non-Restart to Restart - Copies to restart schedule process  !

per SSP-7.2 and to item owner. l

- Changes from Restart to Non-Restart - Copies to Dept. Mgr. to be worked post restart and for inclusion in his/her Evaluation of Post Restart Backlogs.

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s s PRELIMINARY SYSTEM READINESS REVIEW FORM ATT.2 SYSTEM NO / NAME SYSTEM ENGR. f SYSTEM ENGR. REVIEW

SUMMARY

(The System Engr. shall initial each item below to indicate that required reviews have been completed)

Restart items identified for this system have been completed (Attach punchlist of currently open restartitems)

Emergent items since 5/1/93 have been evaluated for restart. Attach any System Engineer concems for emergent items recommending disposition.

Backlog items prior to 5/1/93 have been evaluated for restart and for the collective irnpact of open non-restart backlog items on this system. Attach any system engineers concems regarding backlog reviews on the collective impact of open non-restart items on the system REMARKS System Engineer Signature Date BACKLOG REVIEW COMMrTTEE (BRC) EVALUATION BRC Review & Concurrence Signature Date TECHNICAL SUPPORT MANAGEMENT REVIEW AND APPROVAL P

Technical Support Manager Signature Date MANAGEMENT RESTART REVIEW COMMITTEE (MRRC)

MRRC Approval Signature Date DISPOSITION CF FORMS Attachment 1 with attachments (origina!) - System notebook ,

Changes to Restart Decisions or New Restart items as a result of the Prefirninary System Readiness Review:

- New Restart or Changes from Non-Restart to Restart - Copies to res' art schedule process per SSP-7.2 and to item owner.  ;

- Changes from Restart to Non-Restart - Copies to Dept. Mgr. to be worked post res' art and for inclusion in his/her Evaluation of Post Restart Backlogs.

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EllE.LIMINARY S_YSTEM READINESS REVIEW (PSRR)

(PROCESS FOR ATTACHMENT 2)

SE SE SE SE EVALUATE FOR SYSTEM DRC lMPACT,' DOCUMENT RESTART RESTART CONCERNS & ATTACH BRC PRESENTATION, CALL CHANGES

• ^ ~* " '

( START )-- fY$1EM BR 1/93 NON. y o E E GE 4 h 1

COMPLETE RESTART FROM BRC MTG.

CONCERNS Y#4 - EMERGENT NON. ygg RESTART NO SE p p BRC PUNCHLIST, ATTACl1 MOOlFY BRC, TO ATE 2 EMERGENT ITEM DOC; ATTACH TO ATT. 2

$ SE TS SYS ENGR DISTRIBUTE COPIES OF SE DOCUMENTATION FROM MRRC MTG. -

PRESENT PREllM @ TO: RESTART SCHEDULE PER SSP-7.2 SYSTEM READINESS (3 NEWRESTARTISSUES OR DEPE MGR. (INFO)

TS CHANGES FROM NON-RESTART MANAGER REVIEW TO MRRC. TO RESTART FROM BRC OR

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APPROVAL

• MRRC MTGS. @ TO: DEPT. MGR.TO BE WORKED POST RESTART DEP T. MGR. FOR INCLUSION IN HIS POST-RESTART BACKLOG COMPOSITION, NUMBER EVALUATION CHANGES l @ CHANGES FROM RESTART TO

-" T FROM BRC OR C T @ TO: SYSTEM NOTEDOOK

@ PSRR (ORIGINAL) TO SYSTEM NOTEBOOK SE SYSTEM ENGINEER BRC BACKLOG REVIEW COMMITTEE TS TECHNICAL SUPPORT MRRC MANAGEMENT RESTART REVIEW COMMITTEE

I FINAL SYSTEM READINESS REVIEW FORM ATT.3 SYSTEM NO / NAME SYSTEM ENGR.

SYSTEM ENGR. REVIEW

SUMMARY

(The System Engr. shall inittai each item below to affirm that he/she has completed the Indicated reviews and that they support restarr) t Preliminary System Readiness Review (PSRR) complete with punchlist items closed and any System Engineer concerns resolved.

Emergent items since PSRR have proper restart determination and restart items are completed System Engr. walkdowns on focus systems (Att. 4) and others as determined by the Technical Support Manager are complete.

Reviews of information related to recurring equipment / system problems (trends) completed and a plan developed to address.

Priorities for continued irnprovement of system performance and system material cond; tion established.

REMARKS (The System Engineer can provide any additional relevant information deemed necessary to provide a complete summary of system readiness.)

AFFIRMATION (The System , wr shall affirm by his/her signature below that, based on his/her evaluation of the arecs listed in the SYSTEM ENGINEER REVIEW

SUMMARY

above and to the best of his/her knowledgefjudgement, the system is in a condition of readiness to support safe and reliable restart ,

and operation.)

System Engineer Signature Date TECHNICAL SUPPORT MANAGEMENT REVIEW AND APPROVAL r

Supervisor Signature Date Technical Support Manager Signature Date 93

FINAL SYSTEM READINESS REVIEW FORM ATT. 3 SYSTEM NO / NAME SYSTEM ENGR.

SYSTEM ENGR. REV!EW

SUMMARY

(The System Engr. shall Initial each item below to affirm that he/she has completed the indicated reviews and that they support restart)

Preliminary System Readiness Review (PSRR) complete with punchlist items closed and any System Engineer concems resolved.

Emergent items since PSRR have proper restart determination ar.J restart items are completed System Engr. walkdowns on focus systems (Att. 4) and others as determined by the Technical Support Manager are complete.

Reviews of information related to recurring equipment / system problems (trends) completed and a plan developed to address.

Priorities for continued improvement of system performance and system material concEtion established.

REMARV3 AFFIRMATION System Engineer Signature Date TECHNICAL SUPPORT MANAGEMENT REVIEW AND APPROVAL Supervisor Signature Date Technical Support Manager Signature Date 94

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ATTACHMENT 4 Sequoyah Nuclear Plant Focus Systems Desirnation System 1 Main Steam System 2 Condensate System 3 Main and Auxiliary Feedwater System 5 Extraction Steam System 6 Heater Drains and Vents System 7 Turbine Extraction Traps and Drains System 12 Auxiliary Boiler System 13 Fire Protection System (Other than High-Pressure Fire Protection and C02 Fire Protection) 14 Condensate Demineralizer System 15 Steam Generator Blowdown System 18 Fuel Oil System 20 Central Lubricating Oil System 24 Raw Cooling Water System 27 Condenser Circulating Water System 30 Ventilating System 32 Control Air System 35 Generator Hydrogen Cooling System '

37 Gland Seal Water System 46 Feedwater Control System 47 Turbogenerator Control System 54 Injection Water System 57 Associated Electrical Systems (Generator) 58 Generator Bus Cooling System 62 Chemical and Volume Control System 63 Safety Injection System 65 Emergency Gas Treatment System 67 Essential Raw Cooling Water System 70 Component Cooling System 74 Residual Heat Removal System ',

82 Standby Diesel Generator System 201 480-V Electrical Boards and Motor Control Center 202 6900-V Electrical Boards (and Logic Panels) 241 Switchyard and Transformers _(Including 22.5, 161, & 500-kV) 250 AC/DC Low Voltage Power System 311 Control Building Heating, Ventilating, and Air-Conditioning (Instruments and Valves) (was 31A) 313 Auxiliary Building Heating, Ventilating, and Air-Conditioning (Instruments and Valves) (was 31C)

PLO90201/3026 95

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DEPARTMENT RESTART READINESS ASSESSMENT l Applicability

• Site Vice President direct reports and their direct reports Department Manager Readiness Assessment and Affirmation

• Organization responsibilities and functions defined

• Programs and processes sufficient to support restart

• . Restart items verified complete

• Personnel / management evaluation complete and short-term actions complete

• Necessary department training complete

• Standdowns and communication plan complete; effectiveness assessed.

• Postrestart backlog composition defined and understood, workoff plan established (including workoff curves), performance / health indicators  ;

established, and periodic monitoring / assessment established

• Postrestart improvement areas defined in detail and added to Sequoyah i Improvement Plan Assessment and performance monitoring processes in place

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Department Manager Review of Above Items With Site Vice President

• Feedback, expectations, and coaching j

• Status and process-assessed

• Restart readiness affirmed  !

• Postrestart plan defined and controlled Department Manager Documentation, Affirmation of Final Department Readiness -

(For n in Attachment 1)

Management Restart Review Committee Review of Department Readiness Roll-up f

PLO90204/2753

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DEPARTMENT READINESS REVIEW AND AFFIRMATION FORM ATT.1 DEPARTMENT DEPARTMENT MANAGER DEPARTMENT MANAGER READINESS REVIEW AND AFFIRMATION (The Dept. Mgr. shall Initial each item below to affirm department readiness in each area indicated)

Organization responsibilities and functions defined Programs and processes sufficient to support restart Restart items verified complete Personnel / management evaluation complete and short-term actions complete Necessary department training complete Standdowns and communication plan complete; effectiveness assessed Post restart backlog composition defined and understood, workoff plan established (including workoff curves), performance / health indicators established, and periodic monitoring / assessment established Post restart improvement areas defined in detail and added to Sequoyah improvement Plan Assessment and performance monitoring processes in place REMARKS l

(Dept. Mgr. can provide any additional relevant information deemed necessary to provide a complete summary of department readiness)

Department Manager Affirmation Date SITE VICE PRESIDENT REVIEW OF DEPARTMENT READINESS (Site VP shall Initial each item below to indicate concurrence with Department Manager assessment and affirmation of readiness)

Feedback, expectations, and coaching complete Status and process assessed ,

Restart readiness affirmed Post restart plan defined and controlled REMARKS (Site VP can provide any additional relevant information deemed necessary to summarize his review and concurrence with Department Manager readiness Site Vice Presidient Concurrence ._. Date MANAGMENT RESTART REVIEW COMMITTEE (MRRC) DEPi. READINESS REVIEW MRRC Concurrence Date 98

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DEPARTMENT READINESS REVIEW AND AFFIRMATION FORM ATT.1 l DEPARTMENT DEPARTMENT MANAGER l

l DEPARTMENT MANAGER READINESS REVIEW AND AFFIRMATION (The Dept. Mgr. shallInitial each item below to affirm department readiness in each area Indicated)

Organization responsibilities and functions defined Programs and processes sufficient to support restart Restart items verified complete Personnet/ management evaluation complete and short-term actions complete Necessary department training complete Standdowns and communication plan complete; effectiveness assessed l

Post restart backlog composition defined and understood, workoff plan established i (including workoff curves), performance / health indicators established, and periodic monitoring / assessment estabfished Post restart improvement areas defined in detail and added to Sequoyah Improvement Plan i i

Assessment and performance monitoring processes in place REMARKS Department Manager Affirmation Date SITE VICE PRESIDENT REVIEW OF DEPARTMENT READINESS (Site VP shallInitial each item below to indicate concurrence with Department Manager assessment and affirmation of readiness) ,

Feedback, expectations, and coaching complete Status and process assessed ,

Restart readiness affirmed Post restart plan defined and controlled REMARKS f i

I Site Vice Presidient Concurrence Date j MANAGMENT RESTART REVIEW COMMITTEE (MRRC) DEPT. READINESS REVIEW MRRC Concurrence Date 99

e APPENDIX 7 100

SITE READINESS ASSESSMD3T l

t MRRC Chairman, PORC Site Readiness Assessment

• Organization and Personnel Readiness l

• Systems Readiness  !

• Department Readiness l

• Outage Closure l

• Restart List Closure  ;

• Postrestart Plans Established  !

• Assessments Complete

• Other MRRC Chairman, PORC Review and Approval Prior to the Following Activities

• Initial Mode Change (Mode 5 to Mode 4) ,

• Site Criticality (Mode 2) ,

PLO90204/2756 i

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SITE READINESS ASSESSMENT FORM ATT.1 ROLL UP AND REVIEW OF SITE READINESS ASSESSMENTS (Principal Areas to be Reviewed)

• Organization and Personne!

• Systems Readiness

• Department Readiness

• Outage Closure

• Restart Ust Closure

• Post Restart Plans

• Assessments

• Other (Specify)

REVIEW AND APPROVAL FOR INITIAL MODE CHANGE (MODE 5 TO MODE 4)

MRRC REMARKS (MRRC can provide any additional relevant information deemed necessary to complete this site readiness review for this mode change.)

PORC REMARKS (PORC can provide any additional relevant information deemed necessary to complete this site readiness review for this mode change.)

(MRRC Chairman and PORC by their signature will affirm that the above and any other relevant areas have been reviewed and that each supports entry into mode 4 from mode 5.)

MRRC Chairman Approval Date PORC Approval Date REVIEW AND APPROVAL FOR SITE CRITICALITY (MODE 2) .

MRRC REMARKS (MRRC can provide any additional relevant information deemed necessary to complete this site readiness review for this mode change.)

i PORC REMARKS (PORC can provide any additional relevant information deemed necessary to complete this site readiness  ;

review for this mode change.)

(MRRC Chairman and PORC by their signature will affirm that the above and any other relevant areas l have been reviewed and the Full Site Readiness Assessment completed such that each supports entry into mode 2.)

MRRC Chairman Approval Date PORC Approval Date 102 >

SITE READINESS ASSESSMENT FORM ATT.1 ROLL UP AND REVIEY/ OF SITE READINESS ASSESSMENTS (Principal Areas to be Reviewed)

• Organization and Personne!

• Systems Readiness

• Department Readiness

• Outage Closure

• Restad Ust Closure ,

• Post Restart Plans

• Assessments

• Other (Specify)

REVIEW AND APPROVAL FOR INITIAL MODE CHANGE (MODE 5 TO MODE 4)

MRRC REMARKS PORC REMARKS MRRC Chairman Approval Date PORC Approval Date REVIEW AND APPROVAL FOR SITE CRITICALITY (MODE 2) .

MRRC REMARKS PORC REMARKS MRRC Chairman Approval Date PORC Approval Date

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APPENDIX 8  :

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APPENDIX 8 SITE LICENSING REGULATORY CLOSURE AFFIRMATION Restart Readiness Affirmation WillInclude: ,

• Affirmation that objective evidence exists verifying completion of all restart actions required by TVA and NRC letters associated with the subject outage for the respective unit. '

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