ML20056G184
| ML20056G184 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/10/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20056G182 | List: |
| References | |
| PROC-930810, NUDOCS 9309020210 | |
| Download: ML20056G184 (150) | |
Text
- - - - - - - - - - - - - - - - - - - -
TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT w
l RESTART PLAN REV.2 F
ESP E88s !!88882, -
P pyg u,
TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT l
RESTART PLAN REV.2 APPROVED BY: MII A //ols Site Vice President /Date
SEQUOYAH RESTART PLAN REVISION LOG DESCRIPTION OF REVISION REV. LEVEL /DATE
- 1. Initial issuance 0 /May 20,1993
- 2. Incorporate additional process detail and enht.ncement 1/ July 27,1993
- Emergent item reviews
- System readiness forms and walkdowns
- Department program reviews
- Depanment readiness details
- Restart Item Closure process Reflect additional BRC tasks / assignments
- Review of emergent WRs from 5/1 to 7/1
- Review of Department Evaluated backlogs
- Revicw of Post Restan backlogs
- Review of restart WR deletions Incorporate Senior Management Oversight Group comments
- Add Maintenance Manager to MRRC
- More detail on Secondary Reliability Study results
- Additional NSRB review for restart
- Power ascension plan scope and holdpoints Clarification and Miscellaneous Revisions
- Configuration control for BOP process systems
- Less than five delinquent PMs at restan
- PM Revisions added to backlog listing
- Remove MILS from emergent item process
- Update Post Restart improvement plan description
- Reflect transition to normal processes
- Update references
- Minor edits
- 3. Addition of Appendix 11, Startup and Power Ascension 2/ August 10,1993 Plan Revision to section V.G to reflect Appendix 11 A
SEQUOYAH RESTART PLAN TABLE OF CONTENTS I. BACKGROUND II. RESTART PLAN OBJECTIVES III. APPROACH IV. RESTART FOCUS AREAS A. BALANCE OF PLANT B. OPERATIONS C. PROGRA51S D. BACKLOGS - WORK PRIORITIZATION E. PERSONNEL, ORGANIZATION AND CULTURE F. CORPORATFJSITE INTERFACE V. PROCESSES A. RESTART ITDI IDENTIFICATION B. MANAGDIENT RESTART REVIEW CONI 51FITEE C. RESTART LIST D. BACKLOG REVIEW COhihirITEE E. SYSTDI READIhTSS F. DEPARTA1ENT READISTSS G. SITE READINESS VI. ASSESShfENTS/ OVERSIGHT A. RESTART PLAN ADEQUACY B. RESTART PLAN IMPLDIENTATION & EFFECTIVENESS C. ASSESSMENT CAPABILITY VII. CLOSURE & DOCUMENTATION VIU. POSTRESTART - SITE Ih1PROVDIENT PLAN l
IX. REFERENCES X. FIGURES XI. APPENDICES
I. 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 Confirmation of Action Letter (Reference 1) wa.s is2 tied by NRC that documented agreements between TVA 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 noncompliances, 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 time of this event, actions were underway to carry out a comprehensive Site Improvement Plan (SIP), which includes broad initiatives both to address specific weaknesses (identified both internally and externally) and to target those areas 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 over the past several years, 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 backlogs, improving work prioritization, clarifying the interface between the site and corporate organizations, and continuing efforts to elevate overall site workforce effectiveness (people / culture / organization). In sum, restart initiatives were identified to correct not only the specific causes for the shutdown, but also to reduce impediments to effective plant operations following restart.
A
- restart list" containing specific detailed restart actions was developed utilizing input from a variety of sources. These included E/C associated corrective actions including technical 1
program reviews, management review of the SIP areas (which included BOP and Operations improvement action plans), soliciting feedback on signincant 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 specinc potential restart actions were identified, a Management Restart Review Committee (MRRC), chaired by the SQN Site Vice President, was established to review and approve (or disapprove) potential restart item / issues. Restart criteria were developed for use in screening potentialitems and evaluating the merit of those specific items. The criteria focused on nuclear safety, plant reliability, and operational impacts.
A large number of assessment / review efforts were identified to assist in identifying problems, evaluating the adequacy of the restart initiatives, assessing the effectiveness of initiatives, and assessing readiness for restart. These assessments / reviews included a review of recent events and trends by SQN management and the Institute of Nuclear Power Operations (1h70); team reviews of selected technical program areas, reviews by the Nuclear Safety Review Board (NSRB); a high-level, Senior Management Oversight Group using experienced nuclear industry managers; a Restart Readiness Team review of the Operations department's readiness; and a variety of site and corporate reviews in targeted areas by Nuclear Assurance.
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 postrestart improvement.
The overall objectives of the SQN Restart Plan are to ensure the comprehensiveness of the restart efforts; to provide an integrated framework for consistent, effective implementation of those efforts; and to assist in the management and communication of those efforts. This document summarnes key initiatives; extensive supporting detail is referenced as indicated, e.g., detailed implementation schedules, workoff curves, and summary reports.
This plan, including revisions, is issued and approved by the SQN Site Vice President.
III. APPROACH The overall approach to the achievement of the Restart Plan objectives is to integrate and 2
build on the multiple ongoing efforts described above. This includes: identification of key focus areas for improvement based upon the analysis of performance problems and underlying causes, identification of restart actions and scope utilizing documented restart evaluation criteria consistent with Restart Plan objectives, development of processes to facilitate and ensure the comprehensive and effective implementation of restart effons consistent with Restart Plan objectives, utilization of assessments to verify effectiveness and readmess for restart, and integration of the restart efforts with the postrestart overall Site Improvement Plan.
The SQN Restart Plan methodology and integration of efforts are depicted in Figure 1.
Detailed descriptions of each facet of this plan are provided in Sections IV - VI. In general overview, potential restart 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 l software items are assigned to responsible depanment owners. Restart readiness will be
[ principally comprised of integration of system readiness affirmations (hardware) and department readiness affirmations (e.g., software, programs, processes, and people). Restan 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 postrestan plans as well. Multiple assessments are being used to assess restan plan adequacy, restan plan implementation, and restart readiness.
IV. RESTART FOCUS AREAS 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 restan readiness.
IV.A BALANCE OF PLANT (BOP)
Over the past several years, an increasing number of plant transients and reactor trips have resulted from secondary plant problems. Causes have included unexpected hardware 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.
Multiple reviews have been conducted to ensure accurate identification of problem areas.
These included INPO assistance (Reference 3), a comprehensive Secondary Plant Reliability Study (Section IV.A.1), an independent Secondary Plant Design Review (Section IV. A.2),
3
reviews of technical program areas as applied to the BOP (Section IV. A.5), and performance 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.
Implementing initiatives to address these objectives include the following areas:
IV.A.1 Secondary Plant Reliability Study In January 1993, a Secondary Plant Reliability Study tReference 4) was initiated to provide a _ _ _ _
structured, prioritized approach to effecting secondary plant performance improvements.
Specific objectives included understanding the causes of increased 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 l evaluation process involved collecting SQN and industry data; conducting specific department reviews; reviewing management controls and processes; and analyzir.g data.
Recommendations / resolutions were evaluated for cost effectiveness and priority, and categorized by action type, i.e., modification, corrective or preventive maintenance, procedure change or training.
Modifications were further classified as high, medium or low priority and results were reviewed against the restart criteria. Of the twenty-eight identified high priority modifications, twenty-two are being implemented befoxe restart. Key restart modifications include modifications to heater drains and s ents (piping and valves), feedwater system (controller relays and solenoid valves), control air (receiver drain and copper unloader lines),
switchyard (generator breakers and Buckholtz relays), turbine / generator (turbine runback pressure switches and volts / hertz relay), condensate demineralizer (replace and upgrade valves), and the electrical system (vital invertor transfer switch and vital battery test breaker).
- Additional deficiencies were categorized as preventive or corrective maintenance items.
l These items are to be evaluated by the Reliability Centered Maintenance (RCM) program to determine the optimum resolution. These items were screened to identify items of immediate concern due to existing or potential plant conditions. Items considered to pose higher near term risk were addressed by work requests for component replacement. These items included such things as selected turbine building junction box cleaning, inspecting and repairing (those exposed to ground water in-leakage); turbine trip test valves which were 4
difficult to open/close; rigid control air line tubing to stator cooling water temperature control valves subject to vibration (replaced with flex tubing); continuously energized relays in the #3 and #7 heater drain tank level control circuits; and fuses in the transformer cooling circuitry. Nine additional actions were also identified for restart including evaluation of corrosion in raw cooling water piping; furmanite replacement; preventive maintenance on electrical boards; resolving work requests on turbine building sightglasses; resolving work requests on the Amertap system; replacement of thin-wall piping; replacement of Moisture Separator Reheater manway spiral flexitallic gaskets; evaluating impact of corrosion on structural integrity of hydrogen piping; and replacement of oil coolers on selected BOP pumps.
Of sixteen identified procedure / training issues, one procedure issue was identified for restart involving draining water from the Main Turbine Oil Tank. The remaining procedure / training issues typically involve engineering enhancements or work efficiency items.
The modifications, preventive maintenance, procedures and training not recommended for implementation prior to restart are being prioritized for longer term implementation post restart as pan of the ongoing Site Improvement Plan.
In addition to the evaluation of existing deficient conditions, a single point failure analysis was performed. This review identified multiple points of single point failure vulnerability in control and electrical circuitry. The results, along with results from an industry trip review evaluation, will be integrated into the RCM program for analysis and development of preventive maintenance procedures as part of the post restart SIP.
Additional actions were identified for improvement regarding control of work on the secondary plant. These actions are addressed in sections IV. A.6 and IV. A.7.
IV.A.2 Secondary Plant Design Study As a further extension of the inhouse reliability study, a BOP system design review was conducted by Stone and Webster Engineering Corporation (Reference 5). The review was performed by an experienced light water reactor (LWR) BOP systems and heat balance engineer who had not previously been exposed to TVA practices or impler ;ntation. This effort was initiated to identify additional problems or vulnerabilities. Obsenations were 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 l
personnel. A general review of calculations was performed, which focused primarily on methodology and results.
It was concluded that while there are a number of design features not con'monly observed, none, specifically or in combination, should preclude safe, reliable unit operation. Specific 5
nndings 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 made to reduce turbine water induction risk, provide assurance on turbine speed control after 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 stan transients, and feedwater heater level stability during unit transients. The review also noted the unavailability of certain BOP as-built documentation and calculations.
Study results have been evaluated for corrective actions and to identify items for restart implementation. Restan items included addressing the above noted specific fmdings regarding feedwater heater relief valve vent piping orientation and points of highly suspected erosion induced wall thinning. Remaining longer term actions will be factored into long-term BOP system reliability improvements as pan of the SIP.
IV. A.3 Performance of Corrective and Preventive Maintenance During the curTent 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 tne use of the Secondary Plant Reliability Study results. Activities include outstanding corrective maintenance items, conduct of preventive maintenance, temporary repair restcrations and inspection and refurbishment of secondary plant piping as pan of the E/C program review effons (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 -
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-cay 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 fer current outage
- performance. Approximately 5300 WRs for primary and secondary p! ant are currently planned for completion prior to restart.
The permanent correction of temporary repairs to existing 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 restan. Other temporary fittings will be totally repaired for Unit 1 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 restart that describes the temporary repair process including the control, tracking, and 6
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 their due date without technical evaluation) will be reduced to less than five (for both units) 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.
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 / generator improvements.
IV.A.5 BOP Technical Programs Application IV.A.5.a E/C and Confirmatory Action I2tter (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 piping condition were initiated. Significant programmatic weaknesses were 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 small-bore piping are being conducted by TVA, with contracted expertise 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.
7
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 expertise. Organizational responsibility has been reassigned to the new Technical Performance and Program organization described in Section IV.B. A third- party (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 Letter 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 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 temporary 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 l
l IV.A.6.1 Maintenance Processes and Standards A number of actions are being taken to elevate the standards of maintenance conduct on the 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 detailin 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.
8
In addition, clearly defined management expectations concerning higher standards for BOP are being communicated and enforced at all levels 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 (Reference 19) that includes communication of heightened expectations for the quality of 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 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 configuration control and single-failure activities that could result in unit trips.
IV. A.6.3 Control of Configuration Operations' management has determined that BOP process systems will be placed under the controls of Site Standard Practice (SSP) 12.2, " System and Equipment Status Control." The application of this level of control will ensure that BOP systems are properly aligned and maintained during restart and subsequent plant operation through use of system alignment checklists and status files. To further ensure adequate configuration control is established 9
e and maintained on BOP, process equipment will receive a verification of status prior to restart. In addition, an increased awareness of BOP configuration control has been instituted into the OCC work authorization process.
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 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 prioritization processes to increase weighing 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 ured to upgrade the weighing 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 Cperations 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-term recommendations to further enhance switchyard activities will be addressed through the SIP.
10
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 comprehnsive 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 Operations 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 effons 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 methods for configuring various component types (e.g. setting throttle valves), 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 by adding secondary plant process systems to the scope of the site configuration control process.
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 and drawings are ongoing. Incorrect procedures and primary drawings will be corrected before restart of respective units. Following specialized training and upgrading of verification processes, a 100 percent field verification effort was initiated for Unit I 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).
l 11
IV.B.3 Strengthening of Operations' Management and Personnel The capability and effectiveness of Operations' personnel are being evaluated, and necessary 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 Generating Station) are being recruited and hited to infuse additional talent and perspective into the Operations department
~
over tne long term. This effort will be supplemented by recruiting and hiring of former U.S.
Navy officers and petty officers as SRO and AUO trainee candidates, respectively.
IV.B.4 Conduct of Operations Expecutions and standards of performance in key areas - procedural adherence, command and control, plant ownership, formality 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 support 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 ongoing Operations department's standdowns (see Section IV.E). 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 Operatiors' Performance Assessment Nuclear Assurance is evaluating performance relative to conduct of operations through the ongoing Operations Performance Evaluation Program followup. Results of that evaluation l
effort are being discussed with Operations' management and factored into ongoing l communications. A Restart Readiness Team headed by the Vice President, Nuclear l 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).
12
IV.C PROGRAMS Weaknesses were identified in several program areas over the past several years, including the programmatic 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 objectiver of the restart activities in this area are to assess the adequacy of site programs 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 interfa.:es; and provide a foundation to continue longer-term program enhancements.
Three key actions are being taken to address this area: team reviews of selected, "high 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 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 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 13
i t
1 l
composed of the Chairman, NSRB; the Vice President, Technical Support; the General j Manager, Nuclear Assumnce; the Vice President, Nuclear Readiness; the SQN Site Quality j Manager; and the SQN Site Licensing Manager. This panel will also review the actions i being taken to resolve the review findings. l t
t 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 I 1
IV.C.2 Program Owner Reviews j l
- l. As part of department readiness assessments (Section V.F), department program owners will l assss the health and effectiveness of programs owned by that department. This assessment l l wili consider program assessments and performar.ce indicators / trends and the potential impact j of hjentified program weaknesses on near-term, safe, reliable plant operation. The scope and ;
methodology for conducting these reviews is defined in Appendix 9 (also see Reference 27). l i
IV.C.3 Technical Performance and Programs Orp6.ation )
~!
Prior to the :hutdown of the units, early in 1993, weaknesses were observed in the l organizational saucture for several technical programs. The observed weaknesses included l the inadequate definition of program ownership, fragmented implementation, and split l 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 l 1993 to develop a single site organization of technical programs to provide a better structure j for delineating program responsibility and atthority and facilitating implementation through !
well-focused control, e.g., minimizing andkr better controlling " hand-offs" and interfaces. l Program ownership is being clearly established at the site; program definition or j implementation functions previously performed by corporate organizations are being -!
transferred to the site. (See Section IV.F for additional discussion of corporate / site !
l interface.) '
l The overall objective of the organization is to achieve and maintain total program defmition, j 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 j for weaknesses identified by recent events, and consequences of ineffective implementation, j i
The new organization has been approved and key positions permanently filled, induding th-organization manager and several supervisory positions; temporary assignments are being j used in some areas (Reference 21). The transfer of responsibilities and personnel from )
14
._ _ _a
i previous organizations is ongoing. Responsibilities and interfaces are being documented and ;
responsibility transfer agreements established and communicated. Program baselining !
udlizing 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 support continuing reviews and program upgrade efforts.
Before restart, the organization will be in place; resporuibilitiec and interfaces will be defined and documented; restart actions from program reviews wih a c omplete; and programs will ',
be reviewed for adequacy to support restart 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 part of department readiness affirmations.
i
?
I l
I l
r I
i I
15 1
l I
IV.D BACKLOGS /OPEN ITEMS - WORK PRIORITIZATION A number of site processes generate work items of various types that until implemented constitute open or backlogged items. Schedules for working these items are dictated by 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 on assessing the individual and aggregate impact of backlog items on safe, reliable plant operation; reducing existing backlogs that can adversely impact the effective management of site activities; improving work prioritization and scheduling processes to optimize priority 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 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 personnel / management impact perspectives, and to lay the foundation for the effective control and management of backlogs following restart.
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 postrestart backlogs; establishing detailed workoff plans for postrestart backlogs; and 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 3 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 providi ,
by Reference 15. System readiness assessments will consider the aggregate impact of any :
remaining postrestart backlogs /open items on system functionality. Department readiness 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 and 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. .
16 l
IV.E PERSONNEL, ORGANIZATION AND CL1TURE As discussed in Section I, the analysis of the underlying causes for observed weaknesses in l i
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 effon, specific restart initiatives were identified in ;
personnel / management capability, organization structure and definition of responsibilities, !
and personnel culture in terms of ownership and standards of performance. [
F IV.E.1 Personnel Evaluation / Management Development I An evaluation of site personnel / management capability and performance is being conducted ,
to identify weaknesses and associated action / development needs (see Reference 20). This ;
l effon 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 i personnel will be evaluated through the continuation of this process following restart. This t evaluation is being conducted by first identifying key behaviors for success and then l evaluating managers / supervisors / personnel against these behaviors. j The restart evaluation has been completed. Immediate restart actions or development needs are being identified as well as postrestan actions. Evaluations are being compared against i
previous performance appraisals for management feedback and appraisal updating. Targeted development taining will be conducted. Detailed action plans are being developed for l
" action required" managers. Actions needed before restart are being identified and implemented. l The results of this effon will be integrated into the depanment readiness affirmations, the :
overall site restart readiness assessment, and continuing postrestart management performance i
reviews and individual development plan processes. It is acknowledged that this initiative is i
primarily one of enforcing an existing system that has broken down. Ieng-term success will depend on management cominitment.
IV.E.2 Organization, Roles and Responsibilities $
i To improve the effectiveness and ownership of site personnel, an effort was initiated to evaluate the effectiveness of and revise as appropriate the organizational structure, and to clearly define roles, responsibilities, and interfaces. Organizational weaknesses are being j ,
identified, and necessary restan and postrestart actions are being defined. The results of this i effon will be documented and communicated to site personnel; impacted procedures will be revised as appropriate. This effort will interface with effons addressing the corporate / site n
17 f
I interface in Section IV.F, and provides an input to both the depanment readiness assessments and integration into the overall site readiness assessment.
It is expected that full implementation of results of these efforts will continue beyond restart. j i
IV.E.3 Culture and Ownership ,
1 Restart and postrestan continuing effons are being implemented to build an effective site j culture, instill ownership, and foster teamwork among management and site personnel. i A long-term action plan has been developed, and efforts are being integrated into ongoing i restan efforts. These effons are focused at communicating and reinforcing a common site !
vision among all personnel, including overall site objectives and standards of performance i and expectations forjob function execution. [
A series of department standdowns in key depanments are being conducted before restart to j devote special focus to this area. Department-specific performance, processes, procedures, i 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 postrestan improvement. j i
i I
t I
t i
I I
t i
b l
18 l i
.I
i IV.F CORPORATE / SITE INTERFACE ,
i f
s Separate from (but in parallel with) the SQN restart efforts, the TVA corporate organization in Nuclear Power has been recently restructured (see Reference 22 for organization charts).
This effort included the assignment of a new Vice President of Nuclear Operations l (R. M. Eytchison) who has responsibility over the nuclear sites. A corporate group under the newly created Vice President cf 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 S:'pport (M. O. Medford) to consolidate technical and -
programmatic oversight and site support functions into a single organization for a more i
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 References 23 and 33). 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 and the overall site readiness assessment. l a
0 t
i i
l J
1 19
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 refinement 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.
V.A RESTART ITEM IDENTIFICATION ,
The following three sections identify key aspects of the restan item identification process. It is expected that application of the specific processes described in sections V.A.2 and V.A.3 (e.g., criteria, forms) will continue until a time close to unit restart where transition to normal operational processes will occur. Appropriate implementation of normal processes .
will be established.
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 f principal sources:
A. Management Review The Site Vice President, his direct reports, and their direct repons 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 identified additional actions that should be taken before the restan of :
the units, considering major weaknesses such as identified in the SIP, to further improve postrestan operational effectiveness. This team identified a base initial "52 item restan list" .
from which the current restart list developed.
i B. Employee Feedback In mid-March, utilizing the SIP and initial "52 item restan 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.) Appendix 2 provides the documentation package utilized in that process. Additional potential restart items resulting from that process were presented
- to the MRRC for approval / disapproval for adding to the restan list.
20 P
t
i C. Site Improvement Plan (SIP) Review i
The SIP was reviewed on a line-by-line (SIP matrix line entries) basis by MRRC members for identification of potential restan items. [
D. Program Reviews As discussed in Section IV.C, team reviews of a number of program areas were conducted that identified both restan and postrestart recommendations.
E. Assessment Reviews l Trend reports and intemal 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 depr.nment mangers for potential restart items.
i F. Backlog Reviews ;
Prior to establishing the BRC and the associated comprehensive backlog review effon, a number of site backlogs were reviewed by department backlog owners for the identification ,
of potential restan items. The ongoing comprehensive backlog review effort through the l BRC will ensure that all backlogs are identified and reviewed as appropriate against the ;
current restart evaluation criteria. Additional potential restart items may be identified as part of this effort.
G. Restan Plan / Activity Implementation !
Ongoing reviews, assessments, and Restart Plan process / activity implementation, e.g.,
backlog reviews, may identify additional restan items.
21 !
?
l l
l l
V.A.2 RESTART EVALUATION CRITERIA l l
Criteria or considerations communicated by the Site Vice President for use in identifying i 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 conditions for operation (LCOs) and items that could result in plant transients. The following restart evaluation criteria reflect a consolidation and reformatting of these criteria / considerations, along with the explanation / guidance in the application of the criteria.
Actions needed to ensure technical specification (TS) operability will be completed before ,
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 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 the restart of the units from the current 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 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.
o Adverse impact on safety system availability or performance 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 o Significant challenge to plant / personnel performance because of Individual or aggregate hnpact For example, high numbers of compensatory actions, disabled annunciators, high backlog numbers, and degraded or unreliable equipment performance o High potential to hnpact 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 .
hardware failure before the end of the next operating cycle o 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 22 [
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, ;
i and/or resource optimization.
4 1
I V.A.3 POTENTIAL RESTART ITEM DOCUMENTATION AND EVALUATION 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 work orders / work requests, or other normal emergent catage scope addition items handled i I
through the outage addition process in SSP-7.2, " Outage Management." It is recognized that the forced Unit 2 and Unit 1 outage schedules a.:d the Unit 1 Cycle 6 refueling outage schedule contam activities not added through this process. ;
e Potential restart items from any source may be documented on form Att. 3-1, " Potential i Restart Evaluation for Sequoyah", contained in 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 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. Outage hardware related additions / deletions are documented on form Att. 3-2, " Restart Work Item Addition / Deletion Form" as described in Appendix 3. This process is in addition to the normal outage activity addition process provided under SSP 7.2. Items resulting from and documented through the Restart Plan implementing processes, e.g., BRC reviews, will also be provided to the Manager, Project Management and Controls, for scheduling MRRC ,
review and approval as defined in this plan. The restart form provided in Appendix 3 need !
j not be used for items documented through these processes. ;
9 l j The deletion of restart items from the restart scope requires technical evaluation by the i system engineer and MRRC approval. MRRC may delegate day-to-day review authority for WR deletions to BRC with followup overview presentation to MRRC. This process is in :
addition to the normal outage activity deletion process provided under SSP-7.2. This process ;
1 is also implemented through Appendix 3, Attachment 3-2.
i f Completion of restart items will be documented on a Restart Item Closure form as indicated
! in Appendix 10. f i
i l
I, 1
1 i l l 23 l
l
. . _a
1 V.B MANAGEMENT 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 members:
SQN Site Vice President (Chairman) j Plant Manager Engineering and Modifications Manager +
Site Licensing Manager Maintenance Manager ,
Operations Superintendent Site Quality Manager V.B.2 RESPONSIBILITIES AND FUNCTIONS The MRRC oversees and directs th overall management and implementation of the restart 1 activities and processes addressed under this Restart Han. The MRRC approves or disapproves potential restart items / issues, reviews summary results of restart eva'uations, ,
i 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, l execution, and completion.
J V.B.3 MRRC MEETINGS I
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 information presented or may direct that j an additional evaluation or information be obtained before making the final restart j determinaiion. MRRC assigns an " owner" for each restart list item. For items determined j to not be restart ite.ms, MRRC considers if the item should be placed in the SIP, handled by [
existing processes, or worked in an expedited manner. j f
b MRRC meeting decisions, including the addition of items to the SQN restart (evaluation) list, !
are documented, controlled, and tracked by the Manager, Project Management and Controls, {
or his representative.
4 24 1
I 1
l t
V.C RESTM.T EVALUATION LIST The restart evaluation list (i.e., restart list) is maintained and updated by the Manager, j Project Management and Controls (Reference 14). MRRC approves additions or deletions of l restart list activities as described in this plan.
V.D BACKLOG REVIEW C05D1ITTEE (BRC) l The BRC was established to effect a comprehensive and consistent review of key site backlogs for restart con;ideration. Prior to establishment, a number of backlogs oc portions of backlogs had already been evaluated by depanment managers as restart item assignments or independent assessment efforts; additionally, the employee feedback process had identified i a number of restart items from various backlogs. A multidiscipline composition was I
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 efforts, appropriate operational impact assessments using a current SRO 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 effon with other restan processes, e.g., system readiness and l depanment readiness affirmations. The detailed process is described in and controlled under Appendix 4 (References 12 and 24). 1 V.D.1 BRC COMPOSITION ,
i 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 Support Program Manager (lead) ;
M. J. Lorek, Nuclear Engineering (current SRO)
I. Dibiase, Maintenance C. R. Brimer, Nuclear Engineering V.D.2 BRC RESPONSIBILITIES AND FUNCTIONS l
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 depanment backlog owner and/or affected system engineer (s), makes 25
i
?
restart decisions on those backlogs. The BRC uses the collective experience and judgement !
of members with supporting input and conducts reviews against the restart evaluation criteria. f The system engineer (as the system owner) participates in backlog reviews and through i his/her system-specific expertise and judgement has significant impact on the BRC decision-making process for system related backlogs. The BRC process provides significant input to the system readiness evaluation described in Appendix 5. The BRC presents to the MRRC, j!
with department head and/or system engineer suppon as appropriate, the summary results of their determinations. Items / issues that are recommended for restart and items / issues for _ i which a restart recommendation is not clear are discussed in detail with the MRRC. j t
For items for which the evaluation criteria are generally satisfied but it is determined that f 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 addition / deletion l process is described in and controlled under Appendix 3. l Backlogs can present an adverse impact to effective plant operation because of the effect of l i
individual or aggregate items and because of the demands that backlogs place on managing line organizations. Collateral to the BRC's primary restart responsibility, the BRC may document observations and formulate recommendations for improvement of how the site l accumulates and manages backlogs for senior site management consideration. l l
Emergent items identified after the backlog review process cutoff date (May 1,1993) are I reviewed for restart scope inclusion as described in Appendix 4. In general, the interim l process for review of emergent items begins the transition from use of special restart review [
processes back to use of normal operational review processes. This process still employs use of the restart evaluation criteria and additional management oversight. The BRC reviewed .j restart determinations for emergent WRs initiated between May 1 and July 1,1993 to i validate appropriate application of criteria through use of normal processes. The system engineers review restart determinations for emergent items against their systems for ongoing i input into system readiness assessment. Unresolved differences in opini.ns are presented to j MRRC for final determination.
l l
u o
4 26 l
i i
V.E SYSTEM READINESS j
Prior to restart, the responsible system engineer will review the status of each system as j indicated in Appendix 5 and will affirm restart readiness of the system to support i 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 support the management restart decisions, to reinforce ownership for system performance and l improvement with the system engineers, and to lay the foundation for postrestart l work / improvement prioritization. l 1
The process requires both a preliminary assessment of projected system status at restart !
(assuming completion of identified outstanding restart work) and a final assessment and [
affirmation prior to restart. Outstanding restart activities at the time of the final system readiness will be identified. Technical Specification systems will be verified operable before i entry into a mode where they are required operable. System work items identified l subsequent to the final system readiness affirmations will be handled by the normal post j restart work processes.
4 Walkdowns will be conducted on focus systems to assess material condition as indicated in Appendix 5. Focus systems include key safety significant and plant reliability significant '
systems. Walkdowns at system operating temperature and pressure will be conducted as appropriate to identify leaks following system restoration. The Technical Support manager i will coordinate the overall completion of these efforts with other outage and startup activities. l Considerations that will be addressed by the system engineers in support of the readiness )
affirmation will include the status of the material condition of the system including the j
?
review of outstanding backlogs or open items / issues on their system; the completion of walkdowns on focus systems listed in Appendix 5; the completion of the review of i information related to significant recurring or repetitive equipment problems and a plan to :
address them; the establishment of compensatory measures (if appropriate) for postrestart !
items / issues; and the establishment of priorities for the continued improvement of system performance and system material condition. l l
System readiness reviews will be reviewed by the system engineer supervisor, the BRC, the Technical Support manager, and the MRRC as indicated in Appendix 5. System readiness l 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.
d l
)
1
~
27
e L
V.F DEPARTMENT READINESS AFFIRMATION Prior to restart, the managers responsible for each major functional department as indicated ~
in Appendix 6 will affirm restan 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, i
organization, and personnel / management capability are sufficient to support safe and reliable operation; to ensure that postrestart work and improvement efforts (including backlogs) are sufficiently defined, prioriti7.ed, scheduled, and controlled; and to ensure that appropriate postrestart assessment and monitoring processes are in place (See References 13 and 25).
The process leading to this affirmation will include a series of meetings with the department '
manager and the Site Vice President to discuss needed actions leading to department restart readiness, to review progress in attaining organization / functional readiness, and to assist in :
department manager development via the process for establishing depanment readiness for both short- and long-term considerations. Final department readiness affirmations will be ;
reviewed by the MRRC and will be input into the overall MRRC site readiness assessment. :
The depanment readiness affirmation process is detailed in Appendix 6. l v
2 I
f I
t i
I I
l I
r 28 j i
a h
~
~
l l
)
V.G SITE READINESS ASSESSMENT The overall site readiness assessment will consist of a "rollup" of a number of interfacing l and overlapping inputs. These include the system and department readiness affirmations l i
described in Sections V.E and V.F, the closecut by the outage managensent team of outage activities, the closeout / disposition of all restart list items, the review of organization and i personnel adequacy (Section IV.E) including the corporate / site interface (Section IV.F), and the review / assessment of restart 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 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 appropria'te 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.
Appendix 11, Startup and Power Ascension Plan, describes the management plan for ;
1 ensuring the safe, controlled, and deliberate return to service of Sequoyah Nuclear Plant (SQN). This plan defines and describes assessment hold points where reviews, affirmations, and approvals will be conducted. Control / assessment hold points will occur at Mode 5 prior to entry into Mode 4; Mode 3, prior to pulling control rods to achieve criticality; 30%
reactor power, +/- 10%; 65% reactor power, +/- 10%; 90% reactor power, +/- 5 %; and ;
100% reactor power. This plan also describes additional oversight and checks during the !
startup and power ascension to review plant equipment and personnel performance. This l l
plan integrates portions of other Restart Plan processes, outage closeout processes, and site startup processes and procedures with additional requirements set forth by the startup and j power ascension plan. l i
l i
?
L a
f 29 1
i
l VI. ASSESSMENT /OVERSIGIIT !
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 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 of the restart plan; (3) a high-level, Senior Management Oversight Group review of the restart plan and overall restart readiness; (4) internal and external reviews of the BOP; (5) a Restan Readiness Team review of the Operations depanment's restart readiness; (6) an NSRB/QA special review of backlogs; (7) a comprehensive program of Nuclear Assurance -
assessments and audits; and (8) restart readiness oversight, assessment, and affirmation processes described in Section V of this document. A listing of these activities is provided in Appendix 1.
l The application of these efforts in the restart plan development and implementation is i described below.
l
- VI.A IMPROVEMENT AREA IDENTIFICATION - RESTART PLAN ADEQUACY -
l ;
As discussed in Section I, an effon was underway prior to the shutdown of the units to .
identify the root cause(s) or prinupal barriers to the successful accomplishment of TVA l
l Generating Group objectives and to establish detailed action plans through an integrated Site Improvement Plan to address targeted areas for improvement. The identification of specific and common causes/ barriers was accomplished through a management team review of recent events, trend analyses, and internal and external assessments. In more broadly analyzing the ;
underlying causes of overall performance weaknesses over the past several years, two general causes were identified: ineffective resource management and ineffective 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 long-term improvement.
l Three additional independent reviews are being employed to evaluate the accuracy of the above assessment and associated adequacy of the overall restan plan initiatives described in >
l l this document. They include an INPO problem / event analysis to determine if additional i underlying / common weaknesses exist (Reference 29); a special NSRB evaluation of the l restart plan scope and approach (References 10 and 31); and a review of the SQN history and the restart plan by an independent industry Senior Management Oversight Group (References 8 and 28). The results of additional restart readiness assessments, reviews, and oversight activities described below will be evaluated for the need for additional focus or scope within ,
l the restart plan on an ongoing basis.
l 1
l 30
VI.B RESTART PLAN IMPLEMENTATION / EFFECTIVENESS - RESTART !
READINESS !
A combination of varied restart readiness processes and assessments / review: will be I 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 readiness j assessments / affirmations, BRC and MRRC review / oversight, and final closure and f documentation processes, provides a structured approach to line readiness assessment. The extensive use of multiple non-line assessments, reviews, and oversight activities is being additionally employed 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, l personnel, hardware, and technical program issues. The comprehensive Nuclear Assurance l restart assessment program (Reference 11) was developed by the consideration of l programmatic, hardware, and personnel performance weaknesses. The TVA Nuclear Safety !
Review Board will meet for a fmal assessment of restart readiness just prior to restart of :
unit 2 (Reference 34). Restart readiness assessments will be presented to and reviewed by !
the MRRC for the determination of additional needed actions and/or integration into the overall site readiness assessment rollup. ;
l
+
VI.C ASSESSMENT CAPABILITY AND EFFECTIVENESS - POSTRESTART I ASSESSMENT i
A number of activities are ongoing to strengthen the assessment / root cause capability and effectiveness. Department readiness assessments and affirmations will ensure that meaningful !
performance indicators are established and monitored and that these measures are being integrated into the postrestart Site Improvement Plan. A key element of the restructuring of the corporate organization described in Section IV.F is to clearly derme and enhance the ;
corporate oversight functions and effectiveness. A comprehensive audit of the corrective l action program has been conducted to assess implementation effectiveness and identify i actions for funher strengthening from both programmatic and implementation perspectives.
!r 31
1 l
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.
I VIII. POSTRESTART l l
As stated in the objective to the Restart Plan (section II), the overall objectives of the SQN }
restan efforts are to remove or reduce barriers to effective plant operations and lay the j foundation for continuing postrestart improvement. Prior to the current forced outage, the !
SQN Site Improvement Plan (SIP) was undergoing development and refinement to provide a .!
living document for chaning ongoing site improvement efforts; at the time of the shutdown, the SIP provided a starting framework for development of the restart activities described under this Restart Plan. As a result of implementation of the many restan activities ;
associated with the Restart Plan, the scope, priority and schedule for SIP implementation j require extensive updating and reevaluation. Following such updating, which is underway, ,
the SIP will be integrated into the SQN business plan. This business plan will !
target improvement effons correlated to overall station and generating group objectives. y l
A Post Restart Plan is being developed and will be submitted to NRC before restart which j will describe how SQN will identify, prioritize, fund, implement and manage postrestart i 4 improvement activities. The management systems described in this plan will provide the i basis for ensuring effective completion of post restart improvement activities and ensuring effective management of resources to maintain safe and reliable operations into the future. ,
- The Post Restart Plan will describe the SQN business planning process; work prioritization l
]
processes; the composition and significance of post restart backlogs; management controls l and oversight to ensure effective implementation of post restart improvements; and l identification of key post restart improvement efforts.
The above described processes and controls will be established before restart. Identification ,
of improvement priorities and schedules will be accomplished through "living" ,
j implementation of these processes. l l
3 l
. i
.I
~
i 5
32
-+ -- - e.c
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
- 3. INPO Assist on Secondary Plant Equipment dated February 16, 1993 !
- 4. Secondary Plant Reliability Study - SQN dated June 9,1993 !
- 5. Balance of Plant System Review by Stone & Webster Engineering Corporation dated l May 15,1993 l
- 6. SQN - Technical Programs Review dated March 31,1993 ,
- 7. SQN Technical Programs Revicw, memorandum dated May 11, 1993 ;
- 8. Senior Management Oversight Group Chaner, letter dated May 5,1993 l
- 10. Minutes of April 22,1993, NSRB Meeting No.142 dated May 4,1993
- 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 Restart Readiness, Memorandum dated May 11,1993
- 15. SQN Restart 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 Ixvel Indicating 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) -
ADMINISTRATIVELY CONFIDENTIAL
- 21. SQN Technical Programs and Performance Organization Chart
- 22. TVA Generating Group Organization Charts
- 23. Division of Responsibilities - Technical Support and SQN, Memorandum and attached Repon from Mark O. Medford to Robert A. Fenech dated May 14,1993
- 24. SQN - Backleg Reviews and Handling of Emergent Items, memorandum dated May 24,1993
- 25. SQN - Schedule and Additional Direction for Depanment Restart Readiness Assessment, memorandum from Roben A. Fenech to Those Listed dated June 3,1993
- 26. SQN - Establishment of SQN Programs Baseline, memorandum from J.L. Hamilton to M. A. Cooper dated June 16,1993
- 27. SQN - Backlog Review Committee (BRC) Oversight of Department Evaluated Backlogs, memorandum from H.R. Rogers to Those listed dated June 22,1993 33
1
- 28. Sequoyah Senior Management Oversight Group, letter from G. Carl Andognini to Mr. R. Eytchison and Mr. M. Medford dated June 17,1993
- 29. Letter from A.C.Tollison (INPO, Vice President & Director Plant Evaluation Division) -
to Mr. Roben A. Fenech dated June 4,1993 ,
- 30. Backlog Review Committee (BRC) Report, memorandum from H.R. Rogers to Management Restart Review Committee (MRRC) dated June 11,1993
- 31. Restart Plan Review Comments, letter from Gerald H. Neils, SQN NSRB Advisor, to Tom McGrath, SQN NSRB Chairman dated June 28,1993
- 32. SQN Restart Readiness Team Review of Operations, memorandum from T.J. McGrath, i G.L. Rogers, E. Preston, Jr., A.B. Scott to R.M. Eytchison and R.A. Fenech ,
dated July 2,1993 t
- 33. Division of Responsibilities - Technical Support and Nuclear Plants, memorandum ;
from Mark O. Medford to Those listed dated July 1,1993 .
- 34. SQN Nuclear Safety Review Board (NSRB) Meeting Announcement - Meeting No.143 - August 9-10,1993, memorandum from T.J. McGrath to Those listed ;
dated July 15. 1993
- 35. Technical Program Review Oversight Panel Presentation, memorandum from John L. Hamilton to Those listed dated July 21,1993 ;
- 36. Backlog Review Committee (BRC) Supplement to the Report Dated 6-11-93, i memorandum from H.R. Rogers to Management Restart Review Committee (MRRC) dated July 24,1993 ,
- 37. SQN - Restart Item Closure, memorandum from Robert A. Fenech to Those Listed dated June 23,1993 ;
X. FIGURES
- 1. SQN Restart Plan Flowchart i
XI. APPENDICES
- 1. Assessment / Review / Oversight Activity Listing
- 2. Employee Feedback Process
- 3. Process for Evaluating, Adding or Deleting Potential Restart Items .
- 4. Backlog Review Process
- . 5. System Readiness Assessment and Affirmation Process
- 6. Department Readiness Assessment and Affirmation Process i
- 7. Site Readiness Assessment Process
- 8. Site Licensing Regulatory Closure Affirmation .
- 9. Department Program Owner Reviews !
- 10. Restart Item Closure
- 11. Startup and Power Ascension Plan 1
l t
i i
r 1
i
'1 l
\
a l
l 6
I l
X. FIGURES 1
l i
1 1
l l
l t
1 1
1 1
1 i
l.
l t
l l
35 4
l l
1
SQN RESTART PLAN E/C IC6 RF MGT REVIEW .
SCOPE SIP REVIEW
PROGRAMS REV ASSESSMENTS MRRC > RESTART OUTAGE , FIELD EMPLOYEE FEEDBACK LIST y MANAGEMENT IM PLEMENTATION SACKLOGS n NRC NRC QA NsRs DEIT MGR BACKLOG REVIEW ^ m SYSTEM SYS ENGR / COMMITTEE (BRC) READINESS BALANCE OF 4 MRRC PLANT (BOP)
T RT OPERATIONS y DEPARTM EN ,, DEP PERFORMANCE READINESS >
NRC ASSESSMENTS /
4^
- SR MGT TEAM 4 MRRC ID MAINT
N RC.O R AT SYS ENGG (j ORGANIZATION SITE NRC NRC & PERSONNEL READINESS >
, 3,c Ors OVERSIGitT ; 4 r MRRC &
PORC l T.McG R AW PROGRAMS l OA NRC > MODE 4
- I NRC ,
r, (MRRC & D l ,
q 0RC j MODE 2 t userple ch3 37
1 l
i L
i k
e XI. APPENDICES 1
i l
I 1
s l
37 i
i I
1 i
l' 7
APPENDIX 1 1
l 1
r l
i 1
38 1 1
1
APPENDIX 1 l ASSESSMENT / REVIEW /OVERSIGIIT ACTIVITY LISTING f The following assessments, reviews, and oversight activities are being performed to (1) ensure that areas nee' ding improvements are identified, including the under'ying cause(s) for 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 l restart plan; and (4) to assess the effectiveness of restart actions, i.e., restart readiness. ;
I. Identification of Restart Focus Areas for Improvement f I
o 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 i kilowatt-hour. 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' l performance, and backlogs. ,
o 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 aedons, e g., an action to review corrective action (C/A) items or justifications for continued operation >
(JCOs).
i o Following the development of the 52 item list, site management solicited employee feedback from designated departments to determine whether additional significant i problems impacting nuclear safety, plant reliability, or operational performance existed j 4
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 risk not ;
recognized and therefore scheduled in SIP postrestart; and to identify any specific 1 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).
^
O 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.
I o INPO conducted a problem / event analysis using C/A documents for 1992 and 1993 to determine if additional problem areas existed that had not been identified by the above efforts. (Reference 29) 39 ,
1
l l
APPENDIX 1 l t
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). ,
e Completion of the Secondary Plant Reliability Study (Reference 4). ,
i
-
- Conduct of an independent (Stone and Webster) design review of the secondary plant :
i (Reference 5).
- Ongoing Nuclear Assurance performance evaluation for Operations and Maintenance departments (References 11 and 18). ,
- NSRB subcommittee review of engineering backlogs (Reference 8). ;
- EPRI review of the erosion / corrosion program. .
i
- Personnel / management evaluations (Reference 20).
III. Reviews / Assessments of Restart Plan Adequacy l l
I
- NSRB special session review to determine whether the restart plans are suf6ciently i
comprehensive to ensure identification of problems requiring correction prior to restart and those necessary for long-term improvements (Reference 10); NSRB review of Restart Plan (Reference 31). l
- A review of the SQN Restart Plan (References 8 and 28) by a high-level Semor Management Oversight Group using experienced industry managers and reporting to ;
the Vice President, Nuclear Operations, and Vice President, Technical Support. l i
i 40
l APPENDIX 1 l
IV. Reviews /Assessinents of Restart Plan Implementation and Effectiveness - Restart l Readiness (in addition to the review and readiness processes described in Section V ,
l of this document)
- EPRI and Altran review of the E/C recovery program and long-term program l J
upgrades.
- Multiple Nuclear Assurance and Independent Safety Engineering assessments, audits, and followups of department, backlog, and program areas (Reference 11).
1 e 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 taken to address the team review Endings (Reference 35).
- 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 (Reference 32).
- The Senior Management Oversight Group will conduct a week-long assessment of overall site readiness for restart, addressing management, organization, personnel, .
hardware, and program issues (Reference 8).
- A special session for NSRB review of Enal SQN restart readiness following the NRC Operational Readiness Assessment Team (ORAT) inspection and before mode 2 (Reference 34).
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 approximately one week in advance of Mode 4 and continuing through achievement of 100 percent power.
- An integrated startup and power ascension plan addressing site readiness reviews, ,
augmented management oversight, material condition and housekeeping, regulatory I closure, power ascension activities, and speci5ed control / assessment holdpoints is '
being prepared.
i 41 l
l
i i
l f
l l
l \
I I
i i
I I
APPENDIX 2 i
f I
42
?
l i
Appendix .
Page 1 of 6 l MANAGEMENT REVIEW OF ACTIONS FOR RESTART l t
OBJECTIVE:
Evaluate what actions should be completed before restart of units. This includes establishing basis for what actions are NOT i needed before restart.
- TEAM: ;
l R.A. Fenech l R.J. Beecken 4 5
l J.N. Ward M.A. Cooper ,
T.A. Flippo - ,
N.A. Welch '
i APPROACH: l t
i MARCH 12-15
- 1. Review NRC Inspection Manual checklist issues.
- 2. Reevaluated SIP and 52 issues.
MARCH 15 - 19 )
- 3. Review results of:
I A. Program reviews (MARCH 19)
B. Employee feedback (MARCH 15 - 16) i MARCH 15 - 16
- 4. Document assessment methodology including basis for j decisions on NRC checklist j MARCH 26
- 5. Document logic and basis for results of 1, 2 and 3 43 l
}
Appendix 2 Page 2 of 6 EMPLOYEE FEEDBACK I
i 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 1
i e**************************************************************** j i
1 i
APPROACH: ;
- i. MARCH 12 - 15 t
- 1. Site VP direct reports and Plant Manager direct reports hold i communication / brainstorming meetings with personnel down to j levels-identified on Attachment.
. -2. Provide copies of SIP and 52 issues list and; explain how they l were developed and content.
j 3. Sollicit feedback on comprehensiveness and significance (risk and priority) of identified issues.
! l
- 4. Sollicit identification of other problems with emphasis on !
hardware concerns; document through development of list.
- }
2
- 5. Direct reports review feedback, and evaluate on issue }
evaluation form (Attachment) for subsequent management team 2
review. .
I i
MARCH 15
- 6. Site management team review. l i
i s
t I
i P
~
44 .
L Appendix 2 ._ f Page 3 of 6
]
ATTACHMENT DIRECT REPORTS:
P.G..Trudel R.V. Drake
- T.A. Flippo '!
C.E. Kent I H.R. Rogers L.S. Bryant J.S. Baumstark i PERSONNEL LEVELS: I NE: direct reports and their direct reports !
PROJECTS: project managers and above j QA: direct reports and their direct reports ,
?
CHEM /HP: shift supervisors and above i TECH SUPP: engineers and above !
MAINT: general foreman and above --
OPS: cross-section of crews WCG system evaluators and above j i
I F
'l
?
i I
1 i l
45
l Appendix 2 Page 4 of 6 PROBLEM EVALUATION FORM DATE:
IDENTIFYING ORG:
KHOWLEDGEABLE CONTACT:
ISSUE / CONCERN:
i t
TRACKING DOCUMENT / SYSTEM IF ANY:
INTERIM t ACTIONS:
SIGNIFICANCE / RISK: ,
i-t i
- e***************************************************************
EVALUATION:
- j RECOMMENDATION:
i EVALUATOR: DATE:
45
Appendix 2 j Page 5 of 6 TALKING POINTS NOTE: PROVIDE COPY OF SIP AND LIST OF 52 ISSUES i
- Explain what SIP ie 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, j 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, prioritia.s 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 ongcing. (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 47
Appendix 2 Page 6 of 6 i
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 / l problems'in general; below are suggested questions to >
prompt discussion) ;
are there other key issues not included in SIP scope ?
are there hardware problems that are either not ,
t identified or are not being appropriately addressed i.e.
waiting to " bite us" !
are there problems where risk /conseguances are not fully ;
understood ? !
are there processes or ways of doing business whi'ch are ,
not well controlled ?
are there programs or requirements that are ill-defined 1 or not well understood ? ;
I NOTE: sollicit feedback in a brainstorming fashion; obtain sufficient detail to allow further evaluation; avoid introduction of restart considerations at this point i 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
- 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 i
i 48 I
I
i t
i a
APPENDIX 3 ,
}
6 f
f f
49
i i
APPENDIX 3 l PROCESS FOR EVALUATING, ADDING OR DELETING POTENTIAL RESTART ITEA!S I. Objective l Provide a documented mechanism for evaluating, reviewing and approving potential restart items for addition or deletion to the current forced outage scope. l II. Applicability As described in Section V.A of the Restart Plan.
III. Implementation r
The attached memorandum from Robert A. Fenech provides overall direction for evaluating restan items. Attachment Forms 3-1 and 3-2 provide the documented mechanism to obtain ;
appropriate evaluation, review and approval of potential items for either addition or deletion.
Form Att.3-1 was developed early in the shutdown period for identification of any potential '
restart item. At the time of issuance of Revision 1 to this plan, Att.3-1 is generally used to document iorntification of (adding) potential restart non-WR items / issues or the basis for deleting or changing the scope of an existing non-hardware restart item. System related hardware items are generally added or deleted / changed by use of form Att.3-2 as described 1 below to provide system engineer involvement in the decision-making process for outage hardware scope deletions and a mechanism for presenting system engineer disagreement with a non-restart determination to MRRC for final determination.
Form Att.3-2 was initially developed under Revision 0 to this plan to document restart work :
item deletions. Form Att.3-2 issued under Revision 1 to this plan can be used to document :
both restart item additions or deletions. While emergent (post 5/1/93) WR's are evaluated ,
by the WCG SRO's against the restart criteria and do not require an Att.3-2 for outage addition, an Att.3-2 may be used to document basis for addition for presentation to MRRC to resolve any disagreement between the system engineer and outage management or the WCG regarding the restart determination. This application is also acceptable for similarly documenting / resolving system engineer disagreement for any item type, e.g., PER, DCN, etc. Att.3-2 is used in addition to the normal outage activity addition /Jeletion process l 3
provided in SSP 7.2.
As indicated in Appendix 4, MRRC approval of emergent (post 5/1/93) WR restart additions ;
is not required and MRRC may delegate approval of emergent corrective action document restart additions to the daily corrective action Management Review 50 i
. = . - _ _ -- . - .
-i
. Committee Deletion of previously defined restart items from the restart scope must be ;
. approved by MRRC; however MRRC may delegate authority to BRC for day-to-day j implementation of WR deletions with followup MRRC briefing. Responsibility for MRRC briefing rests with the BRC. :
- )
i i
-t
?
s i
i E
t r
I b
-t F
I l
?
l l
i t
r t
i l
i l
51 s
I
i S63 930319 800 :
?
- v. arch 19, '993 ,
h i
~ hose lis:ed en page 2 7
PROCESS yCR E7AI,UATING A O SCEITI.ING SEQUOyAH NUCIIAR PLAN ~ (SGN) RESIART
!*IMS 4
2.e purpose of this =emerandum is to (1) describe the prec3ss for identifying l and evaluating potential items for restart, (2) dccument the schedules !
previcusly discussed f or completing these evaluations and for presenting them to the Manage =ent Restart Review Cem=ittee (MRRC), and (3) transmit the latest restart list f or your review and ec==ent.
Attach =ent 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 [
MRRC f or review and concurrence and how issues identified as restart are scheduled for work. Please let either Gary S.. Soles (pager 40404) Tom D. }
j Knight (pager 90699), or =e knew if you have questicus or coments en this i procedure.
I Restart issues have been and will centinue to be identified from employee i
?
input, the program evaluatica teams currently in place, and by SQN The l management's review cf Sequoyah !=provement Plan items and other issues.
items which are the result of e=ployee input should be screened by department f l
managers. Input items to be- further censidered for restart shall be presented to MREC by the responsible departme=t manager. Please contact Mr. Soles to ;
schedule a meeting with the comittee. The schedule previously identified by ~
l
=e for evaluating and presenting ' to MERC these employee feedback and other 1
potential restart issues is shown below: i March 24, 1993 l Employee input items 1 March I.3, 1993 ;
E:tisting items en the current l
potential restart list (Attach =ent 2) 1 i
March 24, 1993 1 Program evaluatien team ite=s i
t t
t 4
m e t
S2 t
- I 1
l i
st
- l. These listed
? age 2 March 19. 1993 The MRRC meetings are currently occurring daily, and potential restart issues seculd be presented to MRRC as seen as the evaluaticus are ce=pleted. The items reviewed by MRRC will be added to the restart list (Attachment 2) with their restar: determina:icn documented. This list will be centrolled by Mr. 3cles.
, k{4{c;l5 '
'.Ys-~<-s'l~ ) ;
I Robert A. Fenech Site Vice ?residen: ,
I CPS LA-SCN J. S . Bac=s tark, ?03 13-SGN R. J. 3eecken, FCS 13-SQN /
L . S . 3 ryan t , PCB 13-SQN !
M. A. Ceeper, CPS LC-SQN /
!. A. Flipco, 53 1C-SQN I
0 4 E. K. Fogl'e=an, DS? LA-SQN j J. K. Gates, PC3 2C-SQN J. L. Hamil:en, 53 1C-SCN l C . E . Ken t , ?03 2C-SQN R. W. Martin, 0?S 63-SQN R. R. Rausch, S3 2D-SQN H. R. Rogers, POS 2C-SQN M. D. Shepherd. STC 15-SQN .
?. G. Trudel, DSE LA-SQN
?. R. Wallace, CPS 4A-SQN J. N. Ward, OPS AE-SQN N. A. Welch, PCB 2A-SQN L. J. 'w* heeler, OPS LA-SCN K. W. Whittenbu=g, CPS 2A-SQN
- K:GS3:LI?
A::ach=ents c: (A::ach=ents):
R MS , MR 17-C
.u.u. 4. .- w.
. n , / . ., - 4.
=
6 53
w * ? age 3 ef 3 ,
1 I
I
]
I 1
l 4
l r*
J' ,
+ C m e 6 5 4 o e e
C
-&6 Do db C
3
- -C L3e a O*
s a w Oa- ee C**
-C9 3 ,
w e -* e e e- - *=
C * *
- e- t 3 #94 e
0 3 t.
)
Q QCw h ea d
f/1 D
U e w
- u e w C -a C a e 3 s'* a:
sm 3 e C men ak d"n"e o .
er a S O
%ur
- 2
- g - C -L M
0
- f.w
- w 3
- C* 8. A &
em ew 3w
- u 6**D E o*-w sour g 9e>C
'W eeeO O 2
f.1 2 CEEW e
2 9 e
w as.e u -
E 3 E o e v y ,,
2
% > e e
- ee a w e e S 4 W 2 M
y m'
- h a w
,s e w e w ee O
w w o a. Q e. 3 04C w <> 0 *P w 0 m.m .e. w 2 b eO-2 - E
- 3 art e e
. .m w
- Oew
-ee
- e C =
& E O We*
e 3 W Q en a #
W 4> e e 3 A 5 4 e
9e - .C.
- e >
- a 3 =. e
- s. w C 3 .e. e e 9 w e
- m. 3 p e $
e
$e e
- e e h C g O w O
-w e .e. e e S -& G C
.O. == b. 4 % e
.W 4W b 2
+ e a e
e."
54 l l
l I
e
{
$ ~+-. m.w .. ,* 4 .
PROCECRE FCR FIS~AR* E7AI.UATICNS I:e=s identified that are potential restart ite=s for the mits will be subjected :c a f:=al restart evaluatien as f c11cws . This does not apply to ite=s recuired by the technical specificaticns, high-priority outage work Order /werk requests, or ite=s directed to be perfor=ed by the plant =anager.
_Identificatien of Itars Restart ite=s =ay c =e f re= e=ployee input to their supervisers, through Sequcyah Nuclear Plant =anage=en 's review cf Sequoyah l=preve=ent evaluation Plan ite=s or through the identification of other issues , or f ro= the progra:
teams ---~ ' y in place .
)
Eva- luatice of It m
- e=s shall be dete=ined to be restart er nonrestart through a technical evalua:icn which : nsiders the f ollow_ng i= pacts and risks:
- Nuclear safety
- Plant reliability Regulatory b - Other reascus as deter =ined by the evaluator
?sst events or pr:blems which could have been avoided or mini =ized had the i:e= been properly addressed or i=ple=ented should be ecasidered.
I e=s suculd be escalated through the nor=al manage =ent chain and docu=ented en : e a:: ached f c: n (page 1 of Attach =ent 1) fcr submittal to the department
=anager. ::e=s that have been prev-icusly identified and evaluated on a ~he dif f erent but si=ilar f or:n do not have to be placed en the attached fer=.
i:e= will then be presented to the *.'anage=ent Restart Review C :=:ittee (?. REC) by the appropria:e depart =ent sanager and, if approv'ed, will be returned to an evner for sun =ittal to the restart schedule.
An owner will be determined by MRRC. '"his persen will be respensibleaf::
- crdinating vi:h the appropriate organizaticus to develop and sub=i:
sctedule and f or performing the f ollewing analyses:
- C:st based cc a ccs -benefit a=alysis
- Duratien and := pact en the curr-nt schedule I
?.an-hours i 1
- := pact en rescurces based en the current schedule l
1 55 l
l l
1 1
a 1 v3 Z hO 4
a 0h o
- 4.
5 4 L L' ?
E gh a < M 1 ta n z J o
( ;
O
- ~
24 % b .!
' ~ .
d ve e'
< 4 ni
~
4 J P s
% ~
b I
~
~
s O Q t l*M t e.
g $
e h '
2 ni
- 2 D gm'
" '7 ;
5 3 - g e H ~~~
C
~d d %
g
= cc < % s o M eEdI w -
e
- h, C
=
(
r O -
i
> h -
IW P-2 Cm
% s .--
C -7 C l E '9"
= 1.
~
56
- h 5
g 3 5h b. t
=
r 3
i 1
e q C
-r -2
- -E m ,a I
=_
.= , = 2 -.* -
- e
=
g g
- w . . -w 3-
- w .- * . = 1 , . .
=
i
- .s 6 - L : . - :
}- 2 3 7 *t' .25 35 *
- di% : E.! 2
- }- -20
- - e; 5 :. 2 -
=Ex r3 x <3
.i .s .i < s .
tq. E- --
- m. .s
- ;. 3 :: -
= -, : : *- -s -
=5 o 5 -
,ve ., A2, .
. >. .5 :
-e 503 e I
YT: -
=. x . ET *d. .
-..i dst -. .-
-G 3 f. .f i. ;$ -:-s z : -
Ei, w%-2 53 5 4 ., *-*
"*= -z. *. .us- .3* - .e
- . :g- . .-:.- - *- :
u- . :- .a
.e .n .- . 4-F =: Ox*
- s-w a g :s a t !
. = ;r . -
c} _w . .-
- x- };-- . .
a .g.
1
- ?v . .
=a . =+ ,4 4 g-u I :;r *j 20:
, 2_ :. y=
.. .I 2v ; ;4 : 4 1 -.- .*
=: wr: - -
e %.
1 27 : Ts f 2::5 k T. , -
r 3. O.-< -
1 u_ _f ! ;!. v:3 . !. =. TrL w..
t
'g a g- 0...= *.5 :* s w c c
- f ses :s
,s .
w .- -
j 5t<-
- x C# *h., s t -- .> a- -2s u, 8a, g: 5,** * ,=.
- . w
-R 7 I. v: .< - z : = =n ::: . =, s ,
.*3-_=.- s w 3
W:: . c.* .ow: .," u. ; m -
- u. o 2, - -. ,c .-
_.m.- _e .2e
- 2 .; - *g-n
<< -s
- wr, gw<
www :-
. .- .} .r- a.- 8
= ,,
+
, ,w-, . , syeg . :- .,v r. -
..,=g .-. _- : . -., =. g s.1 y.2 .. -. e - -
., .-os, = . ..
. E..-
. .- . .- -. - -_= 6
, --ou 10 Ir;d. -
. . . .e
- x.m
- su. - . .
3- - .
g . .- a. . --
.- . _ . .=
~
~
- . wc 6 1 3
- *.- wc 22=
- 2 c;; 3sa =
- >s -
=.
- J: -
-a s l o .e d .m .
.-:C. I w,. .. ._
- ci . . .
C*M- . , , - .
. .o . .
g . .i .o ~
~ . .
= w ... . .
y 'u Od' . .
- y. - t
. 9- . 7 e- . . . .
F . . . . - - -
- =f . .
- w*
s
'c o
- t:
2h .
i- ::t -
g .
m 2 .- * .
< < . - . - . O. -
H. g .c, . . . 2 m - -
o .c. s x -
y s.
I E [. k<
4 2 2- - -
3 3
77 t
- e e -
- t
- * =
a
- .
- 2 E I ;
a ,s e.. ;A 3
- =. w
- a d : I
- 5 E g -
- 7 5 . E
% *
- s 2 i a a a m y a.* N
- 3 g e 3 5 e -
. o .
on 3 J 1 E
- a s . .
3 s - - _
- 2 s a
- s. Is: e 2 : $
2 m. .a 2 . .
o o :
2 : .s s.
. o o
= c o... .. .< s. . . : : : o a e c : - .
- .i.
u a o - - . - -
- u. s . . . . . ._
. . . 5
_a.
e y . - x l
- r. . .-
. e . t -n x -e ._-
E y 3
-x.
t . s. <- : C .
=-= . a . 2 =s I 5 e e
- e. :.
= 3 #
o . . . . - - -i 5 O. E w
- s < w wj 2
=! E.I E !; f I-: N..
3 3.5 5 s= - =
J 5 $ $ 2 -
3 e ;
a 3 ..
5 hk 5 iI wg3=
5 2 : ,I
- * $ $ =g :v t. 3
~.
- i. :l =
$3 ei o.
5
!:;;l-4
=
- < I .,
6 ,r ...
=2 55-
.go
=
i: *s y
.= ..
=
x
,. 2, 3
- 3 e,g-
-a w
g, c
5
=
w =.
.ai, .- s 3 at g t 6 .
- e .t -
I: 3* * ** f "'a
.,- . -2. 9
- ! -, x -s 5 3 *rs
- s. .*!.,.
2
- 5 4- n e..2 u. -s , .
4 3
,i e.> > - s.
a-x c a:. - .J -2 3: -
w- -
9 E-w .'
- ,* c'=*{ .li
. - . . w*
.vv 77 =2 :
- h. . e v. W wg:
.a: ,, T-
< a
, .s 4 s 5- E- B5 .:
ga
=
l 3g.z .*
m.:
n-* ..J
-f. 3 r -s 1g 3
- s
,g IE w: I .sa n .y g ,<
-'S5
.i .
a Wg -i w. -=-
7 1 2 * >. *Es 2, .f g TV-3 - < - -
- 1 >3 * >
.= w e- W
- ==>-O .=
2 2
>w 7 v. -
g4_ e. .- 4 ;
6 I ?
_ .t ._g _
> ._a 2
'I Y.
s _p
_ , t.u c. . -
. g : : 2
- 2 :
a .
- 3. - .
.. * * * =
- f 1 E N
3 3 . 6 m
. 2 i .
.= -
57
I !
I i i L
l i
i l
I
- 1
. : : 1
! : 1 l
- : t I i I' 5 3 E 1 2 I I
1 . .-
2 . W
- I >
3 .z ,
.a l
J .
= . .
= = 5 ;
i I : < -
a 6
- < x. = W< <- 0= ,
- . : : sa < i
( .%, -
- 2 5 5 - -. x. x
. = x 2- - - -
- = r. - -
s
- *2 : - *
- 3~ :
i3r ;t 1 2
- n .1 &- :
t r
y:G
. . :. a :. -=
- i. * ; :- a s s .9 4 v3
_2 -
z := * ;
=
I - - :.
.x -f. . .
.- e I
. =-
.- z
- =r
.T* y .*. v c
.s 4 g
- r. r w. -* .,
3- . -4
. : -=
35
- =
- 75
- j= *#
l %. -o 2:
.i* .c
.f i.- 3! :
i t.
- x $- =# W 5 b.
yo 3 5.
i
= = g ** 5 -
I* - *5 *
- -, z I E - 2 - .5. -
c EJ . -
-= g *
- ~. 5- -
.z ww
-m c- -
< .x
- a. x. v. < -.. u 2 :.
- 5 :;- 2 g
- - b. s . -
I :=s -.*3 ~* e T A
- o
- 23- = ,, - j 6; 2-
-* M-" -: - ; 5 C. .e . .
i i
-y f
. z - w
.J -c s
e 6
.s -w
- s <T -
a w-
,-s .g z.
y m
. c3 ;
o d.
. ' .f *f
- . E. x -a . -
.- T. C. . 3.' 5 .. ** . * <.
- . **.. .
- 1 *. . .
z . . a. -.s .
_n b. . . .
Q < M C ;f -t z; e Si?
.E
.* Si o
- = o
. g
. . o =-. e.
. 2 . .o .
.a 3 . u . . . .o a. .
.s .o .
. * *. .~
.1 R Y, .:
- *. s, d
. 4' *5 n
- - .2 : m s,- . :
w w
=
. W
- 3 o 2g. *
- Tz es
- aG
.,3 2 o o .. o . .e
- l o .o
- o. . .- .R
~
.o .a .e a. $. . .
-.J
<m
- .g C l v
- I .
e- . . . . . e a
- ..-e
- g. . ...... .- . - . a. e e
r e
r -
> e - e >
s, N ~*
E,i, e
T s'i
. w) . * - ~ . .
I a .
f f 3 f f
. di . , s i s s s
.(,. 3
- s a 3 3 i 5
j E 5 2 I 2 *. @ I.
b 5 E .
. ~ =.
w z
=;,-2 . - f, .- -
= ; .
= -=a -=s . .
. 3
) .
E
. } W s
. . ] .
3 -<. 2 <
a
- g. wc - < . -
. . e -. * -
- 5 .
- o as 6-g .e ; =. .I 3- a: - s e- s c : 4 I 1 . s 1
, , a s - 4 a 2-
- . . e . . . . .
s - = . e s l s : : - - :
2 m a. s s s. .
.: .-,. s- : - s : .s s. s. s.
- s. s. s s
o s
e o oa o e c e
. . . . s. . . . . c o e o s a a.
<w c : : a : . . . . . . . - . . . -
4 .
I. . . . . . . . .
!, v ge :
i :
- s. .
s .
c I t<. W.
> Y
. , 1 .s -
-E r =
g 2x 1 - t, .
. a -
= 5 1 c g w . . . .- sw g e
. s:
g .
a a. s. . I -
g 5 <
. . . , . . 5 ;t2 x* .
.- ,e
.
- s.- . > e
- 5 d< w =s s
, <- r
- I w
a.
.a I
v ,$
T
- E 4
s
-m :
5 . =
.s g
5 -3
- . 3I
,I
,: x .s *. *- -a E. *.
.. *e
.o... = . * . .- -
! -3 =, g wg !e . :- .: ,
= -. ..
. . E a c, .:3 <4. . 1 -.<
< . s,
- s , <
,.a s, =* s .w
-5 I :* .e s a
- m. < 8
.g .v- .a5* f
< p 6
= s 5
- I
{ ,,. 3: -e, .4- <
.y
.e 2
2
- 1 2 Ig 7 7*5 -
5
- a. m I(
$" >.- e-
- sg - g
. ; ; 3. - t . - - -
- 3 8* d.. - I -* sw .,
- 2 3 - = og - r. *g aW
,i =t .I = r. .I ru -a -
a.
1 r
r w; s
- t r
{:
.r 2 3* - :2 Eg s * .
cv a >s. ;. I ., - : u. g 2 r
!m
. .> :: u a
< ;e .so m
- =< .
g a
y : =,= -gst. yg = _<=! -. 3 :< gv [osyg
~
a 3:
e-g 9 - c .s .: 5 e? 3 !* .c r. vs 5, i a re r
- s :s : r e es r3 r.
. .. x a .
. e .
.s. , .
= -
=
g s . .
-. E . . . g . .
5 5 ! 5 3 5 4: g . .
1 5 . 1 as I %. Ig,g. . a. w .. a.
=
5 6 5 s. -
58 .
I i ;
1 I
?
- S p !
- = e I e g . 5 .* .
t
!' 3 l g a 7
,5
- ze l
- - . e
- .
I. 5 a t
- 2 h. c l .
c* .- :-
=
3 g ?
M i i 8 @ " e m
3 , *
- 1 . g. *5 -*
'l a 2 .: . . 5 g u . -
zu , .a . - - = 5 a,l
- =.
= .
0 0
8 i : 5I
-- ~-
e I <
c' r U u a g 5 * [ .2
!. 3 : = c
{ 3 I. -
% s s ' f a 7 a
- 7 23
- 1 f s s s 3 : ; 3 ;
2 y c. . s.
=
- e. c.
=
- 2, , 2, 3 3.< } -
. *s
. : e. 5- ,
p ::-
x: a a a c
- : } 2 .
u 3. o.
w ,
c . * .
.I, g g3 .
. w =, s u a o C >
w?- * *
- 3 P . +
5, E. . . !. !. ". t E 1 b
t g o ..~-
., e5.:s 2 1 3 b
m 38 2 1 2 3 3 2 8 .: .: 3 S. :. 2 B 1 2 3 3 PN1 3 -
c 2 8 .*3 4A . . * * ;
~
tog e *! ' -
33 35 p ,
3 3 2 8 a 2 . O. t
, F. .[
.e .s .i
- f C gll :
1 3 1 2 2 8 .
t3 . .i. 3 2$ .
- .2 .
h E .31 eet 5
& i
. n . .. .
E $} .. . .
E e a r r y
> -* * . W. .g p -W..m.
M . w - p e a y a e >
p i
f
.4 a ,
e a p
. . . . . . . . m ik ,>,.
. . .P .
.t,l > >. >. >. . .> P P
- C . . . . . -. ,
%[ . . ., ., .
- (,s
.I i
. m- .
- kN5 m.
I 5 %
4
. 5 5, s .,,
E
.[ a s ; =- -g -
e, ,e , = .
e . 3. .. .: .= ,. . ,
=a . , , ; , .
I5 5 E. e e* . , 2 a a g . . g I,.( 7 2
(s . e. .
- 2 '* 3 .
3 aJJJJJ}N .2 g .< g
. .e .t .
e e e e e es; c e - a e c g = ; = , .; c ;
. gia = =
.i e. .
- 1 w
- Y, s. s 1 =a .
- a. .
s -
}3: e e e . . .
3 2 2 3 4 6 & t & t<& <6 < . 2 2 ..
2 2 t. t. . . . .
o u o u 3 <a o u o o .
.d.e.1, o a L. .
- a a o o e o . . .
., 5 . . . . . . . . . . . . . . . .
. . . . . .g. . a ,;
- g. .
- c
. e
- 3
_ . a. u. s e
. 3-
- < = = . -
.i [E !i* a 2
. e E. E jI i i.
w 0
=
- E:
s 3 -.fa. ,
I 2 : 5 * ' e IY- - 3 -
=
2
.e : . o
< r :< 2 r ;; ec g =* 38 j
d s- {- 3 : ' :. ,- g C
. ! v .e -s g :.='. s u - .
- 5 3 e. ~-
- kg 3 I
a - -
i:2I . I .
i3.g 3{i ~gI.
i I I.j g 5 ,j-r'!
!~: e5 : r j g3 ;3g i :a 1 :*3, . I v. =g g *gc< 2 s, g .* -[ :E *. s.ix es
- * =
- ! i
- 3i8a -- 23 !
l *r2 ::r e <
- r. a. :4 .
- !
- 3 3* ,E 2 a ,, .
I8 i 1
- e. fu 2
c.
.:2 .o,a- - .<g - E, Bg... e 3e. g < . 5 . .
2 . e
- i. s cI :. {." :3 [3. 3,5. - a ra. . : . . . .
'I, ,::~a<3e Y < < . n .,,.Iy g
-g g ,
g . .g4 sr g; .g- g{, ,< , . u< wa .a u g
- 3 :.;ggK ai
- 4 w
5* e 5 <g
- t. 2 3,
- g. C C- E >.
y
- 3. 5 < R e . .
T 8I 3 0'I 5 a
. . e' b5
- 3 E.
? E* I 83 13 E g > : .-3
- : : : : m: : : : : : : : : : : :
= ,
i 3 1 3 5 7 ,
- : : : .: 2:
3 .. . : :
ssS e.e +
- t
- : : t t:$: i. : : ,
3l .
i a n5
. . s eia ! %s } P i
59 ,
W f 1 i l
1 n4 l, T
.w u
=
r! =
0 4.c' {. E 2
a e a o 5
. a t
. E f: .
R.
E= *=<ti *
=!
)
.K . 3 E E 2
3 3 3 a :
- 3. .! 333 yde~
-s.
kS SC _
ev..
Wm1
~
- Co J; i
- 8 6 .
c .
uma ,... *
- m ci 2 l
. . . 9 I.;. E!
. , , - - .S.a t-U-
6
-9. . .
g . . .
~
2 * * > e r * =
d
. . . . }
T,e CI., ..,. .,
, s, .
- ]
. ;,3 .
4 4
% .1 :
. c)l <
. l ci = . . .$
a' . =, * .= d
.c ,c 2.: : .
w . .c
- s. & - . e ea o 3
.. Ei
- g g
. -E M s e g
- 2 2 g15 5 : E e
L e e a 1 = 7 s
& L 3*.; a a
?J -
v.
uc o.,
. - . - g- . . -
g
.i . -
R. .
9-
- wb Tg : y .
s ,E, 4
s ** -, =. 5 1. . x . g 9
4 - g5 Og.. 2- g ,
So -
- ,3 ~ .
- E 2 .
55 ta -m . . - -
- 5 = a
- s w=
m-2 .=,. w I g. -
3 .
-4 i
.s G ,.
d
- I -9 9
.d 2
I JO et .* *C a r {3 gd 9
n "g f.
5 K 5 s J. J g I en). g .o
=
t.y 2 R,, :-g
.t. .J b: m ,
i N .I
- 4 2- 2- - * < * -
I E
- m3 8 ; # g w ;~ *:3 3-j !, * .= *: 9*
- 5 s E
I e
2 *- E s. E = .
- <= 5 C = E *J . l
- cm- ps -a w- .d m* I, ,n gb bu -
- 2 1 .= -s w: 52s ;
k j
- 58 33 Se- % *s af .- og >- .-g as5 I
z- wx * > 3 E.E i !
- m. .d
- g. s.
t- m5 a
w .. 5 5 W "w -
f
. E cc j i 36 3 2 2 1 E l,
u.
% % % %- } } %
- 2e, 60 m =
l- . .a . -
1 1
l 1
l
- l l
I
- ==
- .= 3 r s i
- =. .
2 E
=
,- =.
=
=
o
-4 E y 1,
=
=
" =,-
ll E
3 3 v
g =a
/ ,
q.; e 1
w O
E
~
- v. i, s s . .
y E.
- s. v.
=. o. r . e 5:
.-=
. c. = a *
. s' -. o. c =.
c -W g c. : . = *} .5 x. - g- -
- r-g= . - ** - -- e o. e = ,
e .s -
is' T.t .I 5:
-* : -3 E f 9:
5: f n a 5.
- I'
. X = s s : }
3 3 Y*
02 p:;8 .*
5 E
jy I. ; :y pt3
- 5 ,; y 3 *5 1: . g. .
'E :s -
s : - - . v= w g E vi . -:
e .. -: . . :
- 3 I33 5 : .32.., {3g c.f: ,a t.
,= E
=3 e
smtu ; E *
. = - =-s s .-
1
- 25
- c5FC e -g : s-I *a.5 E. l a. 2 . -
- . r.
- z
. I,: E. : 2 3. ; -
~l E - E.
TEE."
- . *,. .e ,g . :; . I o"ao;.a- =*3 ..
- .- -: - ,c* = :. -
8e 4:sc: :s*. .-1 ." =. w
- e. . . =-
>-.,;,, :.. * . . - * . e. 6 - g-:.
o, .
- s. 5=;>
r s. .- . .
- =. I E .s
- s* : =. .-f .-m
- f. c.
m $ ". .-
- s5 .***
c a
, . *-S *
.: s=
3w*- rc.-
.s.. .
.>. = -
. c:-
-.= v g > =* -.. . = c2 '3 63 *; **:C 2 .- 5 -
-- 2 22; w. ss:
.c e; .-
yp Ec-p e
2
- =.
- 5 *guwg I. - g .e . gg, * .E g --g E. 2 ., g u. 5 .c g-E- :2 5. 2- 3 r,
- 5 ,, . e -.
-f =x- , :
,s, us.-
s- =-
r
.g.- . 3, y.me g ,-
E-6 . c..... 5-
. . ys.o Ew.
-.. a - . W. . 3 - -- .6 g . . . .
ml.
0 i .
7.w;. -
= a *=I ** ' -
2
- 2 :- y:, .
l l 2 5*'
- 2 2
- :. 2 : .
. 2.:- 3 *
.: =.s .i
. - ..: .. .s .* ,! *s * :
. r e. u. 5 a5 .
0 g g ge- *O a -3 3 :
,. 2 I .-
e5 .a .
! g w .l.
$ ; 2
- 1 I.
2
- 'S. 2 :- . . .
3 ll . .
- w :--I' z. .! ,.
=
- m 2'a E Je*$!, . . 2 s . . . . .
. . . > e e a sI--
2* .. . . . .
> > e >
- . . - e >
. .,ti, . .
s-
' d wl 22 C: 3 -
y c'
- I 31 - .
- e
. a. . e < . 2 .
f 8 *
. .I 4 . < . . a f
- 2 f .-
2 a s - E o
u s <Elia
[
5 2
[
I :. .
I ;7 f -
- .
- 9 3 l ,1 et, i I 3
K.
3 g 3 3 g
=
a .
= 1 a
5a a
5 e
l
- - 2: 3* = = = E ; .n e -a e.- f:
- 5 y a w . t a o a I J. c . .
cl 3 g E
s 2 e . - .
2 .
2 s :
. l .- , s. s a .
- - i= : :
- s. a s.
2 s
. . s.
e o c c c
- s. .
o e e o 2u .!*: i.o u. a. s. o o o o . .
a a : . . . .
l .a -ao 4 . . .
l
.,.-. . . . . =
t
. i
- m. = .
t
! G. . o ;
I . = -
- a3 - F. .
C 6, > - g 3 2 at
. .u.
- 5. 5 l a- o 2 e 1 . . g 2 e ..
-: I : ** tj , 3, t
- s, .;
as .z-- ; e
- : t m$ -f.
3 :. E 8 ** a e ;
- h, e*
f 5 $.
5 Y. o. 3. .
3~ #
- !. *= E $- = 3 -
3
. s 2 a
- x : =; .2 -s -
$5 1 '
- 6 2 { ? *
-8 -,
2x 3:; I 53.. ;* =- e [= * *3 3 i
- a ::- : :
=w
} 2 o. .2g 8 4. -
r s: 4 :::- ;- .E e. I,w 25
- so a
- e. o. =- s , g: -
5 g3
{*3 6 a
- r.' 3. =
> 3 -
m . =
- - =- .E - . -. : . !. e75
- e :-g,. ,.
e f. g, s. . -
a l!j y
- . 5 - : -. -
5
,- =-
E. .
e.>
. :; 3
. . -..s. .. o. . g- e . s:
. I. 5 Eg z> ss .- o s=. ... -
US E d 't d. E r: 51 f*
u Z$ 55 W ZR3 ::V E I
!2 ;. i?. g*,J I.G.:, i.s3 i?.
- ! .! 2 3 .d fa i
!.i 1;w i:si !g.!. I EPw t- 2
- isl t.
II E 2
I 6
I 71 53 II e
Sag D ,=
II.
- , tw I? !- !? I : :
- 3 YT I E32 : : : : :
t: !! . . . - . . 3 : ._
2 =. - .
= 6
. . . . % s* s.
. % . 5 1 5
.1 q . o s m ! I i !
m s s W 3 5 g a 3 5
61
.= - -
, .- Y r e i E 7 I a 5
i
' 3 5 :Sy E. *
. - t , c a
a . .
. 3 , .- . .
- i : -: : .
E : .e m * .a - < a x- - x .e .
5 1 5
- =-E :
8 e ' i ?
- E I E
, 5 : o 355 -
= 5 3 E = ; c - ?
- .I g * *- -
q ws- s,21 1
- - .z :2: . ,
-* a : o. { a. 2 .m
-z = : -
f; - ; ,
-z >-- a :
.- - . 3 ,.
= -
s.' = ". S i x ,
- } - 2 s., =- e. ~. w-w 5 -- -yT .=
3 * -I
=
- .=
g
=
-o -!
o.
. 3 **
- x % ;:- SEc* :: -
w~
z.
6
- T-I. .
E 3
5.
~
. . ;E iwW
- 5 c5 g)1 s
5 S. I
=5-
-4 e. - ; -: g
.r,-3 o c c 9 x
- - r- -
=. s. .c.
e h
. -2
= c-5 a
.o
. 26 -
c s E.
6- :.c-t.
y a
- -* I-- .-
s W
- 2 y
- =
- -=
p-
,s.-
t-
< r C9 .
.o9.
- e. e.
g . .r
- 2 x g - =s -a *> h - 6 .E -
> 4 .f.
o.. E.. .
- a, as-- . 8. .. -
a m
- w ,- w- w 2- - - . - - - .
I a- z- -
T 3 -.
I r ?1
- =
sami 3 =>
3
-
- 3 E 3 E E 3
- .:. . . 2 - . . .c
- .S -
.a 3 $ $ 3 3 .c 7.-
. . s. 2 *7 =~
- g r -;
4
.-
- 5- 3- 3 *i-
-v 5 3 5 22 f.l 5 1 3
. 3
- e . *
- ey; e q r . ..
E 5 3EIt e : :
. .: s.
2 : : : : : . . .
- : e. .s c -e....,i:
a,
-x3 ll' = . .
- c . . ... . .
m 13 -z .- * -x ., .
-* 1, ... 2
- 9-
- -z ., ., ., u.
- . g. .
. l w .s* *- C, 9<
2 - .
1 2 . . .
3 I 3 3 2 3 E
,j;1 :-
. .
- 3 3
- * *
- z 5 i g E -
=.* -
5 : 5 ,. E. 5 5 2 I. : -
l5: e . e
.-=
.5 w 5 c E 5 3 s-- ,i a.. ..
. -. 4 w
- ~.; e =! ,,, - =. U
- a. - . . -
5 3 !*
3
-.g: 3 r ~ -
g o
. I. . 5 o . :
-3 O
i .-
Is
- -e a r e 3 a 3}
o
- = 3 e 3 : o . = . c 3 . . s c 5 I5 3 . .
r
- e .
- c. 6 c
3 3
3 3 e -
L 3
3 3 3 3 3 3 3. 3 3 3 3. .3 . . .
G G O e.
3 3 . . 3 s C C- C C
.3 4 C 0 0 C O 4
J. .e G
0 3 03CW3OCCCCC . . . . . . . . . . .
- . . . . . . . c, . . . . . . .
r n ..
. 2:
I hy
- g:e 2 1 *
- a 3 . r. --
5 . t
- t-
. t .z .
. 3 u*
s_~3 n > x ,
K. - .w a. u ! - s j * . 5 t
l -
W a i g - : a o
5 E.- gr
' I, - : ; , e- , r E. , r 6
- x 5 ne *- -
i --
1,-5
= .
. w w e .*
3 5-y
-5 I = - o
= !a= g4=-
i 5 c a A g . T - -
.a C I.I5i *: Q' -
) a=
- I .* qc-
~ z 2 f r e 7.5-
,6 = .
I o g. =Q1 E 3 ,.
=
@,;3 :-5{ ,:, a- . f
-e . a . 52 >:a
- .a . 5
=. 3
-- ~s*o
. 2 - o - *e*2:w ..
= 9 :-* -
- oQ s
- 3 3 6 . :.
. E w - 4 1 I -* - .
c=.
2-g - w- ra ><
L., s
. = E9 ;q -~
E4
.e. g- 2; e. :
e.
g.
. E. 2 ., I .,;
. gd. e-
.u =
a- 3 : 3- g 4 ,=
- 5 *- 5 5
g
.g
-I- - -A, $UrE 3 *I-3 [$
) * -
s3 .Il3 3 a l' m gE.: !. Ik d fs "uI $-33g 1! ,E
- t. -
i; 3.
l
. V = " *2 w
- . i. ; .a3 =3= i.g : ;! . ;
yt V2 99 {52
.; g .5 a- r- [ ; 2. g=! ss
- I ei t. '
= :
- 0 . ; i 3 2 -f , . -
IO I I I
- II 3' r* ! *s:s j k?c55 Y 2 g? E7 Y5 *5 3EI
. I i 39 r g I? $ -
2 2 2 : : : :
- - : 2 =
3.. e 2 - : : : : : : : 2: :
W - .
- l g n . . . .k g 5
~ g-
- I ,
.. I si I
I I lir...S n 5 2 5 5 a 5 5 5 3 3 3 5 1
l 62
a l
4 f . = -
. =
.I _
/* j - 6 ; 3 G i r i
= r -
{ ' g
- 3 -- ., =
~.
t le, -
x =- . a a t' 3 ]-
i ..
i , .
-<[ = - - e- ' ". . 2
-= a w. = ! 3 '= : * . . $ 6 y -
. 5
- j r ,
e :
- 25 :
.r. 3 . . x t ; ;
= , *
=.
== ps : -:- a .
u, = =x- .- - .. .. . - 8 -3
- . - 5- s :, *. - y u v -
. = = .
. . t a- 6- s c .
-[ 3- * ~5 2 - - r- - s< %. 5 -
T- -
. s ; --
- r* *
- Z,-
- -.l- : - w I ,
z ce*- fa.-l c; -
s -
e g
5
=
.s a.. -
W -
a s. g . . = u e
- .* =. ._x
.t- as e._.
a; .
- t. m.
-R o <-
- g .
=J -. s. .. . - S
- I.
- e- o u- E. . y
. * *a w
., r -- o-w z ,g w
= "a.w- z, aw c
r c, E .
-> 1I . . . = - . s., _-
r ._ -
.. 5 -
- c. e ~. n.
-e. u . . . ,
. c)..
. g .
. 3 8
-)
-s , . . .
g -
y, 3 .
..;a: = ,;.l 1 : :. : .
. : w- .a=!
8 :
> :c..- Ql g
.- . . g .* -
- g
- ~ , , . . -* *
= ; - .e g e _,
=
w ..
. s on
+*M .
s -c . . . .. ... .
s.
G 9 9- I
. .{
a , , -
w .
n - s
% s s . . ., a
~. =%'- - . . *
- 2 .'d
- C e r e an
't.
p . e . .
. .W .
> P P
> . C,I, w;
- -I *
- 2 Y .t * * * *= * *
- a
.t gi *r r > 2 - a .a - - - . .
a y - - -
> - I.
- .m g **
9 E "
- g . :
.i3 I g: - -
a g
-g 3 g 3 -
T, x.I- -* .
w * & .
a d,
= ww .. -
- i . = .
- C. E. - . .
- - :: ;a Oa
,- . - a
= 3 - :
= 5 .
s
!I ai ! yI!!1!Ea2&-
ase asI ! . = = c . L = = -
s s' 5" 'l ,- : i s 3
- 2 e =c . e a e ==
- 2 2 4 & & 2
=
a- 2 -
2 2 2 2 = L. 4 4
& L 2 . WWC 2 2 2 2 2 2 &
4 2 a < .
C C 3 C C 3 W.G C
$s,I.i .
0 3 0
0 0 3 W OWW C
.... . . . . . . s. . . .
s.
o rw ;
e i . . e a * -
. . ,. e- . . c I-
. - t ; 3
- m ,- s* -
-3 -:
3, 3
2 l.
5 -
i.-
i -
, n
- e
.e o
s t.
. i. -
r , a
. i.- -
g .I . t =
I; . : : . 2- > 3, . m . .- s 6 t.
e.
r s- .- 0, - -
u a
a
!* C.. -
I W 7 =
g
. I, c l9 -
" c ; o e .
- m. > w s
I e,
2r !
w
=
= >7
- s = , ,
-i
=;,
.- - , .2 .
t
.e =
. ,= .
3-
- a.- as.
= . :. ..
I. 5 -sa. .-e .
-.a .
..o
-- -a - W- v . . . .
.a= - .
- ,- =
" 2 :
EE =r I = }: i= !, E.
- S i f3 3 E =I. =- 1.
m.
!:f5 $.. ?,= I i ;! h $ I3 s,e 3 E
! I::. . 6,E 5.. .
.s s24. .O;.:e ;. . ,: .,e a, W., - -<
s - a * *
- e: .. =.;,:: . u - : . E t.
= x
'-p.- -
2 y .* n
.- =
- i. ; :5 t x:: Y
.:: s : 3,2 5. , 3-I d [g-
.w - -
- f]
2 2; - :
- s
- 7
- ,s - -
- ,s-. , ** : - -
fg , 55. a.: .
g ( *"
E E* E *f $*5 I 3 2 . . I ~_
.. ? I 1 G. s f ?! 2 f2 *J . . . . ~~ ~ . ,
l Th .~$ h15
- I, ? 3 .: 3 7 ~. 7, o 3
. . ~ ~-~
~
. . R .
, 3 _.---
.z .,. . .
- * *
- s*
.J n . *
- s n * : : : : :
. . s s a 5l .* .
=
=.
- a. =. 3 = - w-
=
- a s
- a 63 e
_ . _ ._ m _ _. _
h
. I i ;
<a
-i
- I 7
> I
. t 1
E. i 3 f
{ T. t r
I .
. i hs' i.
-I
.i ) E $
i 3! I2 I2 I j c
(
s
'o - .
. O g ,
e - . i i
2 3,
.E . 't
- e -;
= ., +
2 1 ys t .- .
.sw b jra ~ .
1 1 2 3 E
!. .] j'-3 jjj$ .1 3 3 3 3 3 ... 3
{ . - .
l3 .
.g.e.
s.
- m
- l 1 a
- - sq I t 2 W . .*
- c. c e. 2 } !
E - I :.
i
- *8Um s C , i O 4 i y g a' . . . .
- gg l,
=
2*.l . . . . .
313 e
j' 3h .2 . 2%% ! *.
- 7 co- ou. ,
- E- .. . . . . . . l t . .* . . . ? Y-
?
?%% ? ? ? ? -I
.1*1 . . t
- . . . . t L g, 35 . . . . .
e a e
. .e o
e a e = r f
. cq . > 5 v' i
. [
8 at
&. i
?
m 4 e,t
-7 5 2* ~.
s y a i.o t, c
?
& E.
. . I w * . +
~- c!.
- g .,,
w . w w 6
. . o 1
.p2 . 3 E .
.. 1 a w .E {
-Q r E =
.f E - .E
- g. . o -
s e i e c .
c 3 ,
& ,e 6 . c s 1 3 ~
a .
!s; , . -- .. ;
.. . . . . . . . . a
- .. -l u . . -
- l c.
!8 3 ;t fi. i 1 l
y
- :
- 1 :*=3 -i as 5 w g . ,
- .5 ; :
!. .- 2 - 5. c w. .. .
1
- ; . =
3w ., '
y .
> Og 2
...* g 5E 5 g ,
l 3 u
0
., E.vsr ..
II 5
e.: -
c..a r: =. - o_. . .
.,,w -
. . . s.. ..
== . . .
a .
4
_g: , - s.g
= _. v. .. e. s. s . 1, is.
s ..
- s. : 2 .
- r 3 x
. .e .
- < ,. e.g
,- es :- sg. - -
- a. :. 3-,2 : =.
c5!!,*
j.i 'l?!
EG- >
.. :, =.? 3.:, 3132liD15!.I. t.v lt:8$ BW j3 i i! :i' i: :, :- == : r=, :.. .... .
m., .o
.. .e s -
s.
g.__ . .. s..v. ,
=. ... ..
a : ; : : : : : 3 -s i
,5. . , 1 i.
t t. t. t. t. t t. t. t. t. ;
a- t. t.
-l 64 8 A.. .1
rv -<..~ n=a<no. ..nn,~,w,,,_..
Att. 3-1
- ?recVe:r
-cwi%%:ene:GtN w m.
m '2n z.
estatement-foc,x~a:.t rier= i
'~mspmr ,
f, ,uarag:rfd_ =.y _
wm"fen%s rpKk W
~
j
, M m ;rg &
!.SMQi?WS195 x.w,w .-mw.ue, s~.: 8 r, n g2 * . -**m%d' .
S
.N<:*.s.hn,nT e
~ *** bmt2,5"k%
I 1
4DWhw
% . d&Mi 4 ;- he ;
M Ta ZFw YTi
'rReccmmendancrw$ i
-_-- i ettn Manaccmer"y ----;;;E, uw _ i I mnclud_ngstecncicair pt - r_
BEN (Eci?[ -_
, p-ccc:causate
- n. -- p
. ~ j leperspec=ve.g ,_., 0
. l
@EiQ4-6
- pepecnve#.. - -
jiMegpiat~~ _ j O pepecoveWg .i
!G,,oth~e:neasorrA%
m_ 2 i
,rceturmicedifEmee.- - -.
l l
fevalG5teC ~4 ~
r -- m -hv..- '
l lh <w-ewai& - __ M dn 3 Restzt:2G r & =
$ bbb <
$~2 Abig %6+MM i
- sx i 1 Date: I
' Ccmcleted By: t Date Sc::erdser Cencurrence: - 1 Date: !
Managemer:t Restart Ccmmit:ee Accroval: i I
i i Cwner-I, I Duraccn recuired:
, l-1 Manncurs recuired:
- I, i
l E: mated cest- I, d
Crganizztiens involvec: t l
I, i Impac cf ;ericrming to ccer ac vices recuinng same resources: i f
i I
i !
- i I !
1 i.
65 1
RESTART WORK ITEM ADDITION / DELETION FORM ATT. 3-2 i
RESTART ITEM IDENTIFICATION RESTART ITEM OWNER (RESTART LIST #, WORK DOC.#, UNIT, SYS, ETC.)
ADDITION / DELETION INITIATOR 1 ITEM / WORK DESCRIPTION:
REASON FOR ADDITION / DELETION (Schedule impact, Mtl Avallability, Other)
SYSTEM ENGINEER TECHNICAL EVALUATION (Address nuclear safety impact, affect on technical specification compliance, and risk to plant operation and reliability if this work is not completed prior to restart. Compensatory measures and/or alternate 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 Addition / Deletion initiator B. Approved form:
- Original to Addition / Deletion initiator to be attached to a comp!eted 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 / add item from restart list
- Copy to Cognizant System Engineer 66
I RESTART WORK ITEM ADDITION / DELETION FORM ATT. 3-2 RESTART ITEM IDENTIFICATION RESTART ITEM OWNER (RESTART LIST #, WORK DOC.#, UNIT, SYS, ETC.)
ADDITION / DELETION INITIATOR ITEM / WORK DESCRIPTION:
REASON FOR ADDITION / DELETION (Schedule impact, Mil Availability, Other) ,
i 4
l l
SYSTEM ENGINEER TECHNICAL EVALUATION t i
t i
t I
i i
l .
Cognizant System Engineer Signature Date MANAGEMENT RESTART REVIEW COMMITTEE (MRRC) APPROVAL ;
t MRRC Approval Signature Date [
t DISTRIBUTION OF APPROVED FORMS: ;
A. Disapproved form to Addition / Deletion initiator B. Approved form: f
- Original to Addition / Deletion initiator to be r,ttached to a completed Figure 1 - Outage Scope Control Form (Appendix 1, SSP-7.2) and submitted to the Outage Manager on the affected unit. l t
- Copy to P M & C to remove / add item from restart list i l
- Copy to Cognizant System Engineer c
i l =
67' [
l 1
i l
i i
I i
P i
e APPENDIX 4 ,
i t
l 1
l l
I i
)
i I
i i
l 68
l l
I APPENTIX 4 BACKLOG REVIEW PROCESS )
OBJECTIVE ;
o Identify all site backlogs as of May 1,1993, and review (verify reviewed) to determine :
' whether either the individual or aggregate impact of backlog items needs to be addressed ;
a before startup.
o Identify emergent backlog items after May 1,1993, and evaluate them for restart. 3 o The backlog review process, which defines the responsibilities of depanment managers l (backlog owners), the Backlog Review Committee (BRC), system engineers, the Management Restan Review Committee (MRRC), and other site organizations, will be used to accomplish this task.
l PROCESS
- 1. Ensure Full Scope of Backlogs Identified - Depanment Manager l A. A backlog item is a pre-May 1,1993, item. ,
i B. Beginning with the Sequoyah Improvement Plant (SIP) list, depanment managers l I
review to affirm that other lists do not exist (e.g., EQ binder update backlog, NER, and licensing commitments) and identify additional lists to Backlog review Committee (BRC) by May 10,1993.
a-Note: A backlog is considered to be any accumulation of unimplemented work beyond active in-process levels. Questions regarding the application of this definition should be discussed with the 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.
i These systems are typically safety, reliability, or balance of plant (BOP) related or common. Systems not included are, in general, non-process systems.
D. The list of site backlogs identified as of May 17,1993, and categorized as requiring either BRC of department manager reviews is shown in Attachment 1-B. BRC evaluated backlogs are further broken down in Attachment 1-B to identify which will receive review by system and which will receive a programmatic review. The basis for backlog categorization is also shown in Attachment 1-B.
II. Department Managed Backlogs Backlogs identified in Attachment 1-B as " Department Managed Backlogs" will be 69
i t
reviewed for restart by the department using Attachment 3 with recommended restart items brought to the MRRC for final restart determination, following the normal process. Each post restart backlog in the Department Managed Backlog category will be r evaluated by the depanment manager using the process in Attachment 4. The BRC will
- review the department managed backlog evaluations and brief the MRRC on the results l of that review (See References 27 and 36).
f III. Backlog Review Committee Evaluated Backlogs - Department Manager Responsibilities l 1 A. Review (or verify reviewed) backlogs as of May 1,1993, against restart evaluation -l 3 criteria (Attachment 2).
Note: Attachment 2 criteria reficct reformatting and explanatior, of application of .
i essentially the same criteria previously distributed for use.
B. Backlog Review Documentation !
. ?
- l. Group backlog items by system. Evaluate backlog items against restan criteria i in Attachment 2 and document the department manager evaluation on the form in l
Attachment 3. A separate form is required for each item for the following backlogs: ,
i !
4 Major Issues Lists (MILS)
> CAQs (II, PER, FIR, CAQR, SCAR)
Items for their backlogs on the same system and with the same restart call my be grouped on one Attachment 3 form.
- 2. Department managers (backlog owners) provide evaluations as discussed in Item I to the BRC.
I C. Evaluation of Postrestart Backlog (department manager only - not BRC) i
- 1. Backlog Composition Evaluation (Attachment 4) l
- 2. Backlog " Number" Evaluation (Attachment 4) !
l B. BRC Process
- 1. The BRC evaluates department manager review documented in Attachment 3 l
?
70 ;
~ .. ..- .-
I, i
i against restart criteria in Attachment 2: I t
- Review "YES" and "NOs" for CAQs and DCN/ MIL backlogs j i - Review only Nos for other bacidogs a e
- 2. Affected systems engineers will participate in the BRC review for system related j backlogs.
- 3. The BRC may schedule department managers to meet with the BRC/ system engineers if discussion or more detail is needed. j i
- 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 j engineer or the BRC to provide comments, basis, etc., resulting from their assessment.
i V. MRRC Review of Backlog Evaluation j A presentation will be made to the MRRC for the 26 "BRC Evaluated Backlogs" l evaluated by the BRC. Each presentation will consist of two parts.
A. Attachment 3 Evaluations for Restart ]
I l
2 Bacidog 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 on Attachment 3 forms. The disposition of Attachment 3 documentation at the end of the MRRC meeting is as follows: l
?
I
- 1. "NO" items to Project Management and Controls (PM&C) for Postrestart 1 Schedule l
- 2. "YES" items to PM&C for Restart Schedule $
)
- 3. All documentation to System Restart Notebooks (For System Related Backlogs) l i
B. Department Manager Characterization of Postrestart Backlog (Attachment 4) l l
i VI. Review of Emergent Items for Restart After May 1,1993 (End Date for Backlog Review Committee) using Restart Evaluation Criteria. ;
71 i l
2
t A. Emergent items after May 1,1993, will be handled as shovm in Attachment 6. i e
B. Maintenance work requests / work orders (WRs/WOs) ;
i The Maintenance department submits WRs/WOs to Operations for restart determination:
- 2. "NO" maintenance WRs/WOs will be evaluated by the Maintenance department I' as part of their postrestart backlog evaluation (refer to Attachment 4) which, in I
tum, is input to Maintenance department readiness (Appendix 6).
I
- 4. Outage management and/or the plant manager may review emergent WRs restart determinations in a management oversight capacity as determined appropriate. {
C. Conditions adverse to quality / justifications for continued operation (CAQs/JCOs) i Corrective Action Management Review Committee (MRC) evaluates CAQs/JCOs for restart:
- 1. "NO" items returned to department manager (owner) to be included in his/her i postrestart backlog evaluation (refer to Attachment 4) which, in turn, feeds that i department's readiness assessment (Appendix 6).
- 2. "YES" items to Project Management and Controls for addition to restart list and !
to outage management for outage schedule addition in accordance with SSP-7.2. ;
D. System Engineer Evaluation Emergent items and their corresponding restart determinations in Paragraphs B and C above will be evaluated by system engineers as part of their System Readiness assessment (refer to Appendix 5)
E. Other Emergent Items i
All other emergent items from the backlog lists in Attachment 1-B or any other ;
i source will evaluated by the department manager (owner) for restart.
- 1. "YES" items will be brought to the MRRC for final restart determination following normal process.
72
s
- 2. "NO" items will be included in the depanment manager's postrestan backlog evaluation (Attachment 4), if applicable. All items in the category will feed the depanment's Department Readiness Evaluation (Appendix 6).
VII. Other Backlog Effons !
i i
The BRC will assess individually and in aggregate the projected composition and significance of post restart backlogs, building on BRC backlog restan evaluations and ,
depanment postrestart backlog evaluations. The BRC will report the results of this e assessment to MRRC. (Reference 36)
I t
)
?
i i
l l
i 73
L j
!4 l
l ATTACIDIENT 1-A SYSTEMS LIST i o 001 Main Steam System o 002 Condensate System l 0 003 Main and Auxiliary Feedwater System o 005 Extraction Steam System ;
o 006 Heater Drains and Vents System j j
o 007 Turbine Extraction Traps and Drains System o 012 Auxiliary Boiler System o 013 Fire Protection (Other than High-Pressure Fire Protection and CO: Fire Protection) l o 014 Condensate Demineralizer System j J t l 0 015 Steam Generator Blowdown System ;
o 018 Fuel Oil System o 020 Central Lubricating Oil System l t
0 024 Raw Cooling Water System 025 Raw Service Water System ];
o 026 High Pressure Fire Protection System !
o 027 Condenser Circulating Water System ,.
029 Potable (Treated) Water Distribution System l o 030 Ventilating System ;
i 031 Air-Conditioning (Cooling - Heating) System t
o 032 Control Air System o 033 Service Air System !
f 034 Vacuum Priming System j
o 035 Generator Hydrogen Cooling Systems 036 Feedwater Secondary Treatment System l 0 037 Gland Seal Water System f 039 CO: Storage, Fire Protection, and Purging System j 040 Station Drainage System j 041 Layup Water Treatment System q
-042 Chemical Cleaning System o 043 Sampling and Water Quality System o 046 Feedwater Control System j o 047 Turbogenerator Control System j
,r 050 Hypochlorite System 052 System Test Facility (Seismic Instrumentation) {
o.054 Injection Water System .l; o 055 Annunciator & Sequential Events Recording System 056 Temperature Monitoring System f o 057 Associated Electrical Systems (Generator) o 058 Generator Bus Cooling System
[
059 Demineralizer Water & Cask Decontamination System j o 061 Ice Condenser System t o 062 Chemical and Volume Control System o 063 Safety Injection System - {
o 065. Emergency Gas Treatment System o 067 Essential Raw CooUng Water System i
h 74
i i
o 068 Reactor Coolant System o 070 Component Cooling System o 072 Containment Spray System o 074 Residual Heat Removal System 077 Waste Disposa! System 078 Spent Fuel Pit Cooling System (Fuel Holding and Cranes) 079 Fuel Handling and Storage System l o 081 Primary Makeup Water System o 082 Standby Diesel Generator System o 083 Hydrogen Recombination System 084 Flood Mode Boration System o 085 Control Rod Drive System o 088 Containment Isolation System o 090 Radiation Monitoring System o 092 Neutron Monitoring System o 094 Incore Monitoring System o 099 Reactor Protection System 200 Status Monitor System o 201 480-V Electrical Boards and Motor Control Center o 202 6900-V Electrical Boards (Logic Panels)' l o 234 Heat Tracing System o 241 Switchyard and Transformers Oncluding 22.5,161, & 500-kV) 244 Communications System 245 Security System 247 Lighting System o 250 AC/DC Low Voltage Power System 263 Condenser Tube Cleaning System o 268 Permanent Hydrogen Mitigation System !
301 P-250 Computer System 302 Penetrations and Sleeves (Mechanical and Electrical) 305 Sewage System o 311 Control Building Heating, Ventilating, Air-Conditioning Onstruments and Valves) (was 31 A) '
o 313 Auxiliary Building Heating, Ventilating, and Air-Conditioning Onstruments and Valves) (was 31C) 317 Miscellaneous 410 Building Doors and Hatches Oncludes Architectural Doors) ,
928 Makeup Water Treatment Plant Electrical Equipment I
959 Demineralizer Water Storage & Distribution System for Makeup Water Treatment Plant
- Focus Systems - System Engineer Walkdowns as a Part of System Readiness ;
i 75 l
3 i
i ATTACILMENT 1-B BRC EVALUATED BACKLOGS o 1. WR/WO (includes orange ball list and defeated annunciators)* i o 2. JCO/EE*
o 3. Comp Measures
- O 4. Open DCNs o 5. Hold Orders *
- 6. Drawing Changes - Cat 2 & Cat 3 ;
o 7. Operator Aids
- o 8. Obsolete Equipment o 9. Issues (DCRs, MILS)**
- 10. Deferral Request PMs ' Appendix L' l
- 11. Procedure Revisions
- 12. Vendor Manual Updates
- 13. DD Backlog
- 14. SSD Backlog o 15. CAQs (II, PER, FIR, PDFIR, CAQR, SCAR)" ;
- 16. Q-List '
o 17. TFARs*
- 18. NER Items" i o 19. TACFs*
- 20. NRC Commitments * ,
o 21. Technical Support Investigation Requests * !
- 22. Old Work Plans
- 23. Weld Maps
- 24. SMIs
- 25. EQ Backlog
- 26. UVAs in Design Inputs l i
0 Areas to be looked on a systems basis. All other areas will be reviewed on a programmatic basis.
i
- BRC reviewed each item.
- BRC reviewed each item ar.d will have individual review paper. [
l l 76
DEPARTMENT EVALUATED BACKLOGS (evaluations subsequently reviewed by BRC)
- 2. Material Requirements
- 3. Instrument Data Packages
- 4. Labels
- 5. NPRDS Data Input
- 6. PRO, TROI Items
- 7. FSAR Changes
- 8. EMS Updates (Fese Tab Updates Included) .
- 9. Tech Spec Changes
- 10. Delinquent PM
- 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 Procedt.ces
- 16. PEG /DCN Procurement
- 17. 56 RIP Item Work Off 6/15
- 18. Calculation Cross Reference Systems (CCRS)
- 19. Non-TS sis (Assume 200 Manhours / Group)
- 20. RCM Study
- 21. SI Reviews
- 22. SPTS 23 FSAR Reviews
- 24. PM R.evisions ,
i i
s 77
3-BACKLOG CATEGORY BASIS Catecorv A - Basis for BRC Backloes Basis for Backlog List:
o Could directly affect plant process equipment from a safety and reliability standpoint. ;
Basis for System vs. Program Review:
o Typically hardware-related or high potential to impact hardware issues ,
o Supports review by system to obtain aggregate impact on system functionality / reliability o Potential to have significant impact for safe and reliable operation i
Category B - Decartment Managed Backlocs o Typically non-hardware administrative / management issues or with ,
minor / indirect hardware impact potential l o Not considered to constitute a significant potential impact to safe and reliable operation o The department manager is to assess restart /non-restart and impact to manage postrestart ,
i 1
1 l
1 78 l l
1 1
^ ~
i.
i ATTACIDIENT 2 RESTART EVALUATION CRITERIA l l
Actions needed to ensure technical specification (TS) operability will be completed before j entering a mode for which associated requirement are applicable. Actions needed to satisfy l NRC docketed commitments or agreements associated with the current outages (e.g., CAL j l
l items) will be completed before restart. The following screening criteria will be used to i
- evaluate other open items / issues to determine what additional actions should be taken before ;
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 consequences of impact.
Potential restart items should be 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 or the restart scope modified. ,
o 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 1; statements, and potential to render a component or system incapable of performing i intended design function. l o Significant challenge to plant / personnel performance because of either individual or !
aggregate impact, e.g., high numbers of compensatory actions, disabled annunciators, j and high maintenance backlog. ;
i o High potential to impact plant operating reliability, e.g., likelihood for causing !
trips / transients, common or single failure point weaknesses, necessitates entry into short- l term TS action statements, and likelihood for hardware failure before the end of the next l operating cycle. l t
o Prudency of or need for working during two-unit outage, e.g., reduced TS action i statement applicability, reduced orr - risk, and reduced operational impact. !
l The above criteria 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. j 1
I l
1 1
79
BACKLOG REVIEW FOR RESTART ATT.3 BACKLOG ITEM DEPARTMENT MANAGER SYS NO.
(Document #)
DESCRIPTION RESTART EVALUATION CRITERIA
[ ] 1. Actons needed for technical specifications operability. [ ] 5. Adverse individual or aggregate impact on safe, reliable operatons including potental for significantfy
[ ] 2. Adverse impact on safety system availability or periormance. challenging plant / personnel performance.
[ ] 3. Potental for causing either entry into short-term [ ] 6. High potential to jeopardize plant reliability.
tech spec. acton statement or frequent entry into [ ] 7. Prudent for working during two-unit ou* age.
tecn spec. acton 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.)
Dept. Mgr.: Restart Recommendation Yes ] No SYSTEM ENGINEER REVIEW No System Engineer Concurrence: Restart [ Yes BACKLOG REVIEW COMMITTEE Restart Yes No Backlog Review Committee Concurrence:
MANAGEMENT RESTART REVIEW COMMITTEE (MRRC) i (MRRC to review for concurrence the "Yes" and
- Grey" restart items identified by BRC) ,
No MRRC Concurrence as Applicable: Restart
] Yes 80
BACKLOG REVIEW FOR RESTART ATT. 3 BACKLOG ITEM DEPARTMENT MANAGER SYS NO.
DESCRIPTION RESTART EVALUATION CRITERIA
[ ] 1. Actons needed for technical specifications operability. [ ] 5. Adverse individual or aggregate impact on safe,
[ ] 2. Adverse impact on safety system evailability or reliable operatons including potential for significantly performance. challenging plant / personnel performance.
[ ] 3. Potental for causing either entry into short-term [ ] 6. High potental to jeopardize plant reliability.
tech. spec. acton statement or frequent entry into [ ] 7. Pruoent for working during two-unit outage.
tech. spec. action stt ament. [ ] 8. No restart criteria are applicable to this item.
[ ] 4. NRC dockete-d com, ,rtments associated with the current outages, i
DEPARTMENT MANAGER JUSTIFICATION l
Dept. Mgr.: Restart Recommendation Yes
] No SYSTEM ENGINEER REVIEW System Engineer Concurrence: Restart ] Yes R No BACKLOG REVIEW COMMITTEE No Backlog Review Committee Concurrence: Restart l lYes MANAGEMENT RESTART REVIEW COMMITTEE (MRRC)
No MRRC Concurrence as Applicable: Restart
] Yes 81
BACKLOG REVIEW FOR RESTART AT .". 5 i (CONTINUATION PAGE) j i
I '
ADDITIONAL COMMENTS
. . , l ITEM IDENTIFICATION SYSTEM NO. ,
1 NAME / DATE:
ORGANIZATION:
)
I l
l NAME / DATE: j ORGANIZATION: ,
J NAME / DATE:
ORGANIZATION:
NAME / DATE:
1 ORGANIZATION- I l
1 82 !
1
ATTACHMENT 4 EVALUATION OF POST RESTART BACKLOGS I
BACKLOG RESPONSIBLE DEPARTMENT MANAGER l
PART A BACKLOG COMPOSITION EVALUATION B ACKLOG ITEMS BACN (Attach post restart backlog by system. Backlog may be further grouped or arranged in a way which facilitates evaluation of its composition.)
u!
PAR SIGMIFICANCE OF POST RESTART BACKLOG TO RESTART CRITERIA (Attach evaluation / basis for v,tiy the post restart backlog. when compared to restart criteria, are l>
acceptable as post restart. Backlog items may be grouped or adressed individually, as appropriate; SU categorized by age, system, significance; or otherwise packaged by the Dept. Mgr to best characterize composition.) f i
DATE DEPARTMENT MANAGER APPROVAL i (This signature signifies that the department manager concurs with the restart determination 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 allocation of resources, incoming items post restart, etc.)
RELATIONSHIP TO INDUSTRY STANDARDS (Is post restart backlog consistent of better than industry averages, !NPO indicators, Brunswick Nuclear Plant startup levels, etc.7)
DATE DEPARTMENT MANAGER APPROVAL (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.)
DATE MRRC APPROVAL 83
ATTACHMENT 4 EVALUATION OF POST RESTART BACKLOGS l 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 criaracterize composition.)
DATE DEPARTMENT MANAGER APPROVAL (This signature signifies that the department manager concurs with the restart determination 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!Iocation of resources, incoming items post restart, etc.)
RELATIONSHIP TO INDUSTRY STANDARDS (Is post restart backlog consistent of better than industry averages, INPO indicators, Brunswick Nuclear Plant startup levels, etc.7)
DATE DEPARTMENT MANAGER APPROVAL (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.)
DATE MRRC APPROVAL 83
ATTACHMENT 4 EVALUATION OF POST RESTART BACKLOGS &
BACKLOG RESPONSIBLE DEPARTMENT MANAGER i PART A BACKLOG COMPOSITION EVALUATION '
BACKLOG ITEMS i T
SIGNIFICANCE OF POST RESTART BACKLOG TO RESTART CRITERIA DEPARTMENT MANAGER APPROVAL DATE i l
PART B BASIS FOR BACKLOG RESTART NUMBER t
POST RESTART " MAINTENANCE" PLAN ,
l RELATIONSHIP TO INDUSTRY STANDARDS l
l I
DEPARTMENT MANAGER APPROVAL DATE MRRC APPROVAL DATE l
84 l
l
i P
ATTACHMENT 5 BACKLOG REVIEW COMMTITEE (BRC) CHARTER ;
The BRC is established by the SQN Vice President as a subcommittee of the Management !
Restart Review Committee (MRRC). The BRC consists of the following members. ,
H. R. Rogers, Lead M. J. Lorek I. Dibiase :
C. R. 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 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 MRRC approval.
B. Implement the process approved:
- 1. Establish schedules for site organization evaluation and for 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 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 identity 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 I program performance risk that could be expected if the issue is not resolved prior to l I
restart and present these issues to the MRRC for final resolution.
D. Backlogs present risk to effective plant operation because of the affect of individual or aggregate items and because of the demands that backlogs place on line organizations to i manage them. Collateral to the BRC's primary responsibility, the BRC will document 85
1 i
observations and formulate 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 j existing backlogs, improved bacidog processes, clarification of ownership, or 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 i prevent this from occurring in the future, j E. Perform additional reviews / evaluations as assigned by the Site VP or MRRC. l l
The backlog review process for which the BRC is responsible is shown in the attached flowchart. ;
l e
I i
i a
k
\
}
a i
i l
- i 1
.I I
.f 86 !
i r
BACKLOG REVIEW PROCESS DM DRC BRC DM DM SE SE PREPARE RESTART PRESENT BACKLOG DY RECOMMENO RESTART IDENTIFY FORM (ATT. 3), SYSTEM TO BRC AND
- a (Y/N) AND DOCUMENT 1 START BACKLOGS BY DESCRIPTION. RESP. SYSTEM BASIS SYSTEM RESTART PROPOSAL ENGINEERS d 6 NEED YES No MORE INFO.
DM BRC PM&C SE MRRC PRESENT TO -> REVIEW EVALUATION - RESTART? YES , RESTART
, SCHEDULE MRRC MAKING RESTART Y/N
$ CALLS FOR ' GREY" AREAS AND OTHER .
CHANGES DETERMINED NECESSARY NO u PM&C u SE POST SYSTEM RESTART #
NOTEBOOK SCHEDULE DM DEPARTMENT MANAGER .
SE SYSTEM ENGINEER BRC BACKLOG REVIEW COMMITTEE PM&C PROJECT MANAGEMENT & CONTROLS MRRC MANAGEMENT RESTART REVIEW COMMITTEE
_ _ . _ . _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ - _ . , _ . .. . . . _ _ _ _ _ _ _ . . . . , . . _ - _ _ . _ - _ _ - ~ _ _ _ _ . _ _ _ . _ _ . . _ _ . _ _ _ _ _ . _ _ ,
ATTACHMENT 6 EMEFIGENT ITEMS DM DEPARTMENT MANAGER OPS OPERATIONS ,
(AFTER 5/1/93 & PRIOR TO SYSTEM READINESS)
OM OUTAGE MANAGERS SE SYSTEM ENGINEER CAMRC CORRECTIVE ACTION MANAGEMENT REVIEW COMMITTEE OPS MRRC MANAGEMENT RESTART REVIEW CA MGT REVIEW TEAM COMMITTEE OM SE
,_ RESTART SYSTEM DM 3S PE SS 2 NOTEBOOK DM OPS RESTARI 4 n CALL FOR MAINT WRMOs YES MAINT.
ITEM MAINT. YES MTFO
- ESTART
- MMO CA MGT. REVIEW COMMITTEE i
IF D D DE T. C'A EVALUATION REVIEWS RESTART Y/N MGR (CATEGORIES IN yp4 CALL FOR "
ATT.1 -0)
CAOs a JCO5 CA MGT REVIEW COMMITTEE y DM gg EVALUATOR PROVIDE a
C y DM 99 W,UESTART
- RECOMMENDATION TO DEPT. MGR. DETERMINE DEPT. MGR. FOR SE PRIORITY FOR WORK. IF PRESENTATION TO MRRC*
INPUT TO RESTART DRING TO MRRC **
FOR REVIEW. IF POST SYSTEM
' READfNESS t
RESTART. ENSURE ITEM is INCLUDED IN POST RESTART MRRC*
BACKLOGEVAL ANOIS SCHEDULED POST RESTART YES MRRC*
CONCURRENCE DM Ym POST RESTART DM BACKLOG INPUT TO NO _ _
COMPOSITION * > DEPT.
NUMBER READINESS EVALUATION p
- (ATT. 4) h POST RESTART h
- This review can be delegated to the daily conective action management review committee
. . _ _ _ _ _ _ _ _ . _ _ _ . _ . _ _ _ . _ . . _ . . . - _ . , _ _ .-... - _ - _ .- _ _-. _ _ ,.. _ . _ . . . . _ . - . ,_ -._..-. _ . _ ._- _ ..~_.... _ ____. _ ._
I 5
t t
APPENDIX 5 t
t I
t t
t
?
e I
89 E
I P
l APPENDIX 5 SYSTEM READINESS ASSESSMENT A. Preliminary System Readiness Review (PSRR) (Attachment 2)
- 1. The list of systems subject to System Readiness evaluation is provided in Attachment 1. Systems not included for System Readiness are, in general,
- non-process systems.
- 2. System engineer review to ensure that:
Open items on the system prior to 5/1/93 have been dispositioned as restan or nonrestan Emergent items since 5/1/93 have been properly dispositioned as restart or nonrestart, or outstanding system engineer concerns have been identified The collective impact of open, nonrestart items on system ability to support safe, reliable startup and operation over the next operating cycle has been evaluated Any outstanding system engineer concerns regarding system ability to support :
safe, reliable startup and operation over the next operating cycle are identified
- 3. Backlog review committee (BRC) review, concurrence with system engineer review ;
- 4. Technical Support Manager approval of system engineer review and BRC review
- 5. Management Restart Review Committee review (via presentation) and approval B. System Walkdowns Walkdowns will be conducted on focus systems identified in Attachment I to assess overall system material condition, allow identification of system hardware deficiencies for evaluation against the restan criteria and provide for correction of those deficiencies ,
which could either individually or in the aggregate prevent safe, reliable startup and {
operation over the next operating' cycle. Focus systems include key safety significant and plant reliability significant systems. Walkdowns will be conducted under the direction of the Technical Support Manager.
Following system restoration and return to service, walkdowns will be conducted at system normal operating temperature and pressure (NOTP) to identify leaks for those I
90 l
m - - _ _
i systems designated by the Technical Support Manager. Consideration will be given to the level of work conducted on the system during the forced outage, significance of -l' potential leakage, system accessibility and ability to identify leakage through other mechanisms, e.g., inventory balances. ,
J C. Final System Readiness Review (Attachment 3) j i
- 1. System engineer review and affirmation that:
- PSRR complete with any system engineers' concerns resolved j System engineer material condition walkdowns on focus systems were complete
- Emergent items since completion of the PSRR have been properly dispositioned as restart or nonrestart
- Restart items for the system have been completed with minor identified l exceptions j l
- Reviews of information related to recurring equipment / system problems (adverse !
trends) were completed and a plan to address is in place; compensatory
- measures have been established if appropriate Priorities for continued improvement of system performance and system material i condition have been established l t
2 System engineer's supervisor review and approval !
- 3. Technical Support Manager review and approval i 3
n 91
ATTACHMENT 1 SYSTEMS LIST f l
o 001 Main Steam System o 002 Condensate System ;
o 003 Main and Auxiliary Feedwater System j o 005 Extraction Steam System ;
o 006 Heater Drains and Vents System j o 007 Turbine Extraction Traps and Drains System o 012 Auxiliary Boiler System !
o 013 Fire Protection (Other than High-Pressure Fire Protection and CO2 Fire Protection) !
o 014 Condensate Demineralizer System !
o 015 Steam Generator Blowdown System ;
o 018 Fuel Oil System ;
o 020 Central Lubricating Oil System l 0 024 Raw Cooling Water System :
025 Raw Service Water System o 026 High Pressure Fire Protection System ;
o 027 Condenser Circulating Water System F 029 Potable (Treated) Water Distribution System ;
o 030 Ventilating System j 031 Air-Conditioning (Cooling - Heating) System j
0 032 Control Air System 0 033 Service Air System 034 Vacuum Priming System o 035 Generator Hydrogen Cooling Systems ,
036 Feedwater Secondary Treatment System j o 037 Gland Seal Water System :
039 CO: Storage, Fire Protection, and Purging System 040 Station Drainage System :
041 Layup Water Treatment System l 042 Chemical Cleaning System o 043 Sampling and Water Quality System 1 o 046 Feedwater Control System ;
o 047 Turbogenerator Control System 050 14ypochlorite System l 052 System Test Facility (Seismic Instrumentation) I o 054 Injection Water System o 055 Annunciator & Sequential Events Recording System 056 Temperature Monitoring System o 057 Associated Electrical Systems (Generator) -
0 058 Generator Bus Cooling System i 059 Demineralizer Water & Cask Decontamination System o 061 Ice Condenser System o 062 Chemical and Volume Control System o 063 Safety Injection System o 065 Emergency Gas Treatment System o 067 Essential Raw Cooling Water System l
92
t o 068 Reactor Coolant System l o 070 Component Cooling System ,
o 072 Containment Spray System o 074 Residual Heat Removal System i 077 Waste Disposal System l 078 Spent Fuel Pit Cooling System (Fuel Holding and Cranes) l 079 Fuel Handling and Storage System [
o 081 Primary Makeup Water System l 0 082 Standby Diesel Generator System o 083 Hydrogen Recombination System ,
084 Flood Mode Boration System .
o 085 Control Rod Drive System o 088 Containment Isolation System o 090 Radiation Monitoring System o 092 Neutron Monitoring System o 094 Incore Monitoring System o 099 Reactor Protection System 200 Status Monitor System o 201 - 480-V Electrical Boards and Motor Control Center o 202 6900-V Electrical Boards (Logic Panels)2 o 234 Heat Tracing System o 241 Switchyard and Transformers (Including 22.5,161, & 500-kV) 244 Communications System 245 Security System 247 Lighting System o 250 AC/DC Iew Voltage Power System 263 Condenser Tube Cleaning System o 268 Permanent Hydrogen Mitigation System 301 P-250 Computer System 302 Penetrations and Sleeves (Mechanical and Electrical) 305 Sewage System o 311 Control Building Heating, Ventilating, Air-Conditioning (Instruments and Valves) (was 31A) o 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
- Focus Systems - System Engineer Walkdowns as a Part of System Readiness 93
_ . _ _ _ _ __J
PRELIMINARY SYSTEM READINESS REVIEW FORM ATT. 2 SYSTEM NO / NAME SYSTEM ENGR.
SYSTEM ENGR. REVIEW
SUMMARY
(The System Engr. shall Initial each item below to indicate that required reviews have been completed)
Open items identified for this system prior to 5/1/93 have been properly dispositioned.
Emergent items since 5/1/93 have been properly dispositioned. Attach any System Engineer concerns for emergent items recommending disposition.
The collective impact of open non-restart backlog items identified to date on this system has been evaluated. Attach any system engineers concerns regarding backlog reviews on the collective impact of open non-restart items on the system REMARKS (The System Engineer can provide any additional relevant information deemed necessary to provide a complete summary of system readiness.)
i System Engineer Signature Date BACKLOG REVIEW COMMITTEE (BRC) EVALUATION (The BRC wil! review the System Engineer PSRR documented above. Changes recommended by BRC will 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) l (The Technical Support Manager will present the results of the Preliminary System Readiness Review l to MRRC. MRRC signature will signify concurrence wth system readiness Mcluding restart /non-restart changes made by the system engineer as documented above or by BRC with l
system engineer concurrence as documented above. Changes made by MRRC during the system readiness presentation sha!! be documented on or attached to this form.)
MRRC Approval Signature Date DISPOSITION OF FORMS Attachment 1 uth attachments (original) - System notebook Changes to Restart Decisions or New Restart items as a result of the Preliminary System Readiness Review-l - New Restart or Changes from Non-Restart to Rt ; tart - Copies to restart schedule process per SSP-7.2 and to item owner.
l I - Changes from Restart to Non-Restart - Copies to Dept. Mgr. to be worked post restart l
and for inclusion in his/her Evaluation of Post Restart Backlogs.
I 94 f
i PRELIMINARY SYSTEM READINESS REVIEW FORM ATT.2 i l
SYSTEM NO / NAME SYSTEM ENGR.
l l
SYSTEM ENGR. REVIEW
SUMMARY
(The System Engr. shall Initial each item below to indicate that required reviews have been completed)
Open items identified for this system prior to 5/1/93 have been properly dispositioned.
Emergent items since 5/1/93 have been property dispositioned. Attach any System Engineer concerns for emergent items recommending disposition. >
The collective impact of open non-restart backlog items identified to date on this 4
system has been evaluated. Attach any system engineers concerns regarding backlog reviews on the collective impact of open non-restart items on the system REMARKS System Engineer Signature Date BACKLOG REVIEW COMMITTEE (BRC) EVALUATION BRC Review & Concurrence Signature Date TECHNICAL SUPPORT MANAGEMENT REVIEW AND APPROVAL Technical Support Manager Signature Date ,
MANAGEMENT RESTART REVIEW COMMITTEE (MRRC)
MRRC Approval Signature Date 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.
- 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.
95
PEgtlMINARY SYSTEM READINESS REVIEW (PSRR)
(PROCESS FOR ATTACHMENT 2)
SE SE SE SE EVALUATE FOR SYSTEM BRC IMPACT, DOCUMENT RESTAPT RESTART CONCERNS & ATTACH BRC PRESENTATION, s ITEMS ON YES TO ATT 2: RESOLUTION OF CALL CHANGto (UACKLOG OR -\ NO
- - BRC 5/i/93 NON- -" h EMERGENT)
( START J- SYSTEM COMPLETE n
RESTART SYSTEM ENG.
CONCERNS FROM URC mig Y/N - EMERGENT NON . yg4 RESTART YES NO y BRC SE o PUNCHLIST ATTACH E E E Ni ITEM TO AR 2 DOC; ATTACH TO ATT 2 N SE TS SYS ENGR DisTainU TE COPtES OF SE DOCUMENTATION FROM MRRC M TG.
O. R ai C D EHRSW 2 PRESENT PRELIM NEW RESTART ISSUES OR p' '
g TS SYSTEM READINESS @ CHANGES FROM NON-RESTART MANAGER REVIEW TO MRRC. ._, TO RESTART FROM DRC OR ->
9 MRRC MTGS. @ TO. DEPT. MGR. TO DE WORKED POST RESTAR T APPROVAL DEPT. MGR. FOR INCLUSION IN His POST-RES TART U^ ' "' ^
CHANGES h CHANGES FROM RESTART TO NON-RESTART FROM BRC OR OC TO. SYSTEM NOTEBOOK MRRC MTGS U
@ PSAR (ORIGINAL) TO SYSTEM NOTEBOOK 3E SYSTEM ENGINEER
! BRC BACKLOG REVIEW COMMITTEE j TS TECHNICAL SUPPORT l MRRC MANAGEMENT RESTART REVIEW COMMITTEE
FINAL SYSTEM READINESS REVIEW FORM ATT. 3 SYSTEM NO / NAME SYSTEM ENGR.
SYSTEM ENGR. REVIEW
SUMMARY
(The System Engr. shall initial each item below to affirm that he/che has completed the Indicated reviews and that they support restart)
Preliminary System Readiness Review (PSRR) complete with items properly mpositioned rand any System Engineer concerns resolved.
Emergent items since PSRR have been properly dispositioned.
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 condition established.
REMARKS (The System Engineer can provide any additional relevant information deemed necessary to provide a complete summary of system readiness.)
AFFIRMATION (The System Engineer shall affirm by his/her signature below that, based on his/her evaluation of the areas listed in the SYSTEM ENGINEER REVIEW
SUMMARY
above and to the best of his/her knowledgefpdgement, 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 Date Supervisor Signature Technical Support Manager Signature Date 97 1
l FINAL SYSTEM READINESS REVIEW FORM ATT. 3 j SYSTEM NO / NAME SYSTEM ENGR. j
(. f SYSTEM ENGR. REVIEW
SUMMARY
(The System Engr. shall initial each item below to affirm that h:/ahe has completed the Indicated reviews and that they support restart) l 1
Preliminary System Readiness Review (PSRR) complete with items properly dispositioned and any System Engineer concems resolved. -l 1
Emergent items since PSRR have been properly dispositioned. ;
System Engr. walkdowns on focus systems (Att. 4) and others as determined by the
- Technical Support Manager are complete.
4 ;
t Reviews of information related to recurring equipment / system problems (trends) completed and a plan developed to address. l Priorities for continued improvament of system performance and system material }
condition established. ;
t REMARKS i l
i b
)
l j-f l ,
i
~ 3 AFFIRMATION i
i
?
i System Engineer Signature Date ;
TECHNICAL SUPPORT MANAGEMENT REVIEW AND APPROVAL
)
j Supervisor Signature Date Technical Support Manager Signature Date 98 l
ATTACHMENT 4 SEQUOYAH NUCLEAR PLANT FOCUS SYSTEMS Desienation 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 CO2 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 26 High Pressure Fire Protection System 27 Condenser Circulating Water System 30 Ventilating System 32 Control Air System 33 Service Air 35 Generator Hydrogen Cooling System 37 Gland Seal Water System 43 Sampling and Water Quality System 46 Feedwater Control System 47 Turbogenerator Control System 54 Injection Water System-55 Annunciator & Sequential Events Recording System 57 Associated Electrical Systems (Generator) 58 Generator Bus Cooling System 61 Ice Condenser 62 Chemical and Volume Control System 63 Safety Injection System 65 Emergency Gas Treatment System 67 Essential Raw Cooling Water System 68 Reactor Coolant System 70 Component Cooling System 72 Containment Spray System 74 Residual Heat Removal System 81 Primary Makeup Water System 82 Standby Diesel Generator System 83 Hydrogen Recombination System 99
/
4 i
85 Control Rod Drive System l 88 Con:ainment Isolation System i 90 Radiation Monitoring System l 92 Neutron Monitoring System l 94 Incore Monitoring System i 99 Reactor Protection System !'
201 40^ V Electrical Boards and Motor Control Center 202 6900-V Electrical Boards (and Logic Panels) '
234 Heat Tracing System (
241 Switchyard and Transformers (Including 22.5,161, & 500-kV) i 250 AC/DC Low Voltage Power System !
268 Permanent Hydrogen Mitigation System i 311 Control Building Heating, Ventilating, and Air-Conditioning l (Instruments and Valves) (was 31 A) i 313 Auxiliary Building Heating, Ventilating, and Air-Conditioning l (Instruments and Valves) (was 31C) }
e t
i i
b e
l i
100 !
4 a,
e APPENDIX 6 S
101
i APPENDIX 6 i
DEPARTMENT RESTART READINESS ASSESSMENT )
- 1. Objective Departments will conduct an assessment of actions needed to support department readiness for restart, addressing the areas indicated in Attachment 1; readiness will address both l hardware and software considerations, for restart and beyond. The overall objective of this effort is not just to ready the plant and site for a moment in time but to lay the foundation to carry SQN forward with effective operations beyond restart.
II. Applicability j Site Vice President direct reports and their direct reports as indicated in Attachment 2. Full department readiness evaluations are required for those departments whose work and actions have the highest potential for impact on plant safety, reliability, and operations. Limited '
evaluations are required for other departments as indicated.
Ill. Department Restart Readiness Affirmation and Concurrence :
Document department manager affirmation of restart readiness and Site Vice President / Management Restart Review Committee review and concurrence with the Attachment 3 form.
i l
I 1
102 ,
']
i i
ATTACHMENT 1 DEPARTMENT RESTART PIADINESS ASSESSMENT Applicability r
- Site Vice President direct reports and their direct reports Department Mana;;er 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 ,
i (including workoff curves), performance / health indicators established, and periodic monitoring / assessment established
- Postrestart improvement areas defined in detail and added to Sequoyah Improvement Plan
- Assessment and performance monitoring processes in place ;
Department Manager Review of Above items With Site Vice President
- Feedback, expectations, and coaching
- Status and process assessed
- Restart readiness affirmed
- Postrestart plan defined and controlled Department Manager Documentation, Affirmation of Final Department Readiness Management Restart Review Committee Review of Department Readiness Roll-up I
103(a)
ATTACHMENT 2 DEPARTMENT READINESS APPLICABluTY MATRIX PERSONNEL ASSESSMENT I" 9 '
AND
" PROGRAMS RESTART NECESSARY
" PERFORMANCE DEPARTMENT k- pg 2 &
AND
,ROCESSEE VERIFIED ITEMS TRAINING MONITORfWa g PROCESSES M
U N g DEFINED READY COMPLETE SHORT-T ERM COMPLETE DOCUMENTED COMPLETE ADDED TO SIP IN PLACE ACTtONS COMPLETE R J Baathen X X X X X X F X X X X X X J S Baurnstak X X X X X F X X X X X X L S Bryant X X X X X X X X X J K Gates F X X X X X X X X X X X C E Kant F X X X X X X X F X X X X X X D L Lunt'y X -X X M O S%%d L X JN Wwd X X X X X X X F X X X X X R V Drake X X X X X X X R R Rausch F X X X X X X X X X X X X X X M A Scartwnhi F X X X X X F X X X X X X e M J Burrynski X X X X X X X
h e
LJvaae F X X X X -X X
X X X X
$ R E Detscolt L X X X M E. maw n X X X M E. Rewifer, R X X X L Ponce R X X X P. A Wallace L X X R X X N S Catron M J. Doyle R X X X X A. J. LaMontagrw R X X X X X J R Sethffe R R.W.Marim J. Mgyanks X X X l L X 1
X X X utensing L X X F - FULL L - LIMITED R - ROLLUP W, DEPT. MGR.
X - REQUIRED BLANK * - NOT REQUIRED 3
4 6*swv. +.wa ,es.---w--rw-*r w'rr- w+e-t- we-w,---r e-e-+ -<w-ee-s=-~www--w---=-oww--- -ee-+w-v rvv ~r-r,% ++**e--'--w-
- w wM - or -
-c- --*-ee'w me -w w=-a .-e< w-e w w-vv---e,-emur---r- s-e -m ='~v-e= --w-- m- - -+ww-e
DEPARTMENT READINESS REVIEW AND AFFIRMATION FORM ATT. 3 DEPARTMENT DEPARTMENT MANAGER DEPp.RTMENT MANAGER READINESS REVIEW AND AFF!RMATION (The Dept. Mgr. shallintilal each item below to affirm department readiness in each area indicated)
Organizaticn responsibilities and functions defined Programs and processes suff cient to support restart Restart items verified complete Personnel! management evaluation complete and short-term actions complete Necessary d% artment training complete Standdowns and communication plan t.omplete; effectiveness assessed Post restart backlog composition cefined 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 monitonng processes in place REMARKS (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 4
l (Site VP can provide any additional relevant information deemed necessary to summarize his review and concurrence with Department Manager saadiness i
Site Vice Presidient Concurrence Date MAN AGMENT RESTA!'.T REVIEW COMMITTEE (MRRC) DEPT. READINESS REVIEW l
MRRC Concurrence .
Date 104
DEPARTMENT READINESS REVIEW AND AFFIRMATION FORM ATT. 3 ;
l DEPARTMENT DEPARTMENT MANAGER I DEPARTMENT MANAGER READINESS REVIEW AND AFFIRMATION (The Dept. Mgr. shall Initial each it;m 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 1 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 ind;cators establisned, 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 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 controCed REMARKS Site Vice Presidient Concurrence Date MANAGMENT RESTART REVIEW COMMITTEE (MRRC) DEPT. READINESS REVIEW MRRC Concurrence Date Ins
I
. l l
r APPENDIX 7 1 106
APPENLIX 7 SITE READINESS ASSESSMENT
+
MRRC Chairman, PORC Site Readiness Assessment 0 Organization and Personnel Readiness o Systems Readiness ,
o Department Readiness o Outage Closure o Restan List Closure o Postrestart Plans Established o Assessments Complete o Other MRRC Chairman, PORC Review and Approval Prior to the Following Activities o Initial Mode Change (Mode 5 to Mode 4) o Site Criticality (Mode 2)
I 1
l l
l 107 l
SITE READINESS ASSESSMENT FCRM ATT.1 ROLL UP AND REVIEW OF SITE READINESS ASSESSMENTS (Principal Areas to be Reviewed)
- Organization and Personnel
- 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 relevaat 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 UNIT CRITICALITY (MODE 2)
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 the Full Site Readiness Assessment completed such that each supports entry into mode 2.) .
MRRC Chairman Approval Date PORC Approval Date 108
SITE READINESS ASSESSMENT FORM ATT.1 ROLL UP AND REVIEW OF SITE READINESS ASSESSMENTS (Principal Areas to be Reviewed)
'
- Organization and Personnel
- 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 PORC REMARKS MRRC Chairman Approval Date PORC Approval Date REVIEW AND APPROVAL FOR UNIT CRITICALITY (MODE 2)
MRRC REMARKS PORC REMARKS MRRC Chairman Approval Date PORC Approval Date 109
.-4 S
e APPENDIX 8 1
I 110
l APPENDIX 8 SITE LICENSING REGULATORY CIASURE AFFIRMATION I
Restart Readiness Affirmation Will Include:
o 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.
Site Licensing Manager i L
I 11'
I 1
l l
)
APPENDIX 9 112
S10 930601 800, ,
- '~
, $s .
k June 2, 1993 l l
Those listed on page 2 SEQUOYAH NUCLEAR PLANT (SQN) - PROGRAM OWNER REVIEWS !
As described in the Restart Plan, department program owners will assess the health and ef f ectiveness of programs owned by that department. The results of ,
this assessment will be incorporated into the department readiness affirmations.
Past problems with programs at SQN were indicated as a result of unclear ownership, excessive backlogs, process control weaknesses, and technical program breakdowns. This program assessment is an important piece of our restart effort, which will require that each department program owner establish clear accountability and responsibility for his/her programs.
In order to ensure a consistent, thorough method of assessing site programs, specific assessment guidance has been developed (see Attachment 1). In addition, a baseline list of site programs and owners has been developed for this assessment (see Attachment 2). This baseline program list was developed by reviewing nuclear pcwer standards and implementing site instructions, technical specifications (Section 6), and controlled manuals. The list of 115 programs developed for the Technical Program Review effort was also incorporated into the site baseline list. Please evaluate the baseline list of programs and determine if the list is accurate and if ownership is correctly assigned. Coordinate additions and/or changes to tde list with the ,
Restart Manager.
In order to facilitate the assessment, the Restart Manager will provide each department program owner a summary of identified program weaknesses from -
internal and/or external evaluations, trending, and corrective action documents. Reruits of the assessment must be documented and recommended actions will be evaluated as restart or long-term enhancements.
)$ & ,
Robert A. Fenech Site Vice President OPS 4A-SQN MAC:JLH:CEG Attachments I
cc (Attachments):
T. D. Knight, ER SA-C RIMS, MR 2F-C r
PLO90214/24 113 !
t i
f I
Those listed i Page 2 '
June 2, 1993 i
TO: R. J. Beecken POB 2B-SQN i J. S. Baumstark, POB 2B-SQN j L. S. Bryant, POB 2B-SQN !
M. J. Burzynski, DSE 1A-SQN i R. V. Drake, OPS 4G-SQN !
R. F. Driscoll, SB IC-SQN J. K. Gates, POB 2C-SQN C. E. Kent, POB 2C-SQN D. L. Lundy, OPS 3C-SQN v J. Migyanka, DSP 1A-SQN R. R. Rausch, SB 2D-SQN [
J. R. Setliffe, SB 13-SQN M. D. Shepherd. STC 2H-SQN M. A. Skarzinski, OPS 4H-SQN <
J. D. Smith, OPS 4C-SQN P. R. Wallace, OPS 4A-SQN J. N. Ward, OPS 4H-SQN -
i i
I 1
114
l l :
AnAc:eer 1 ,
PROGRAM READINESS ASSESSMENT
%;;e 1 of 2 f
R:!CGRAM:
l PROGRAM OWNER- !
l l
l l
l 1. Program Ownership And Definition
, r l
l A. Is ownersnip c!earty defined? If so, where? -
9
(
- 3. Cq any per:icns cf the program involve split cwnership? If so, ex; fain:
i i
C. Lst accer ter and site level procedures that desne andlcr implement the program.
L e ,
t D. Are organizational interfaces clearly de5ned in implementing precedures? If not, explain-
~
r 1 1
?
, . . i E. Based on the above, cese:ibe any necessary procecure changes or actions wnicn neec z ce J.xsn. t l
i 5
- 1. Potential Consequences Of P! ant Restart With Undetected Weaknesses In This Program.
A. Oces the crograr- imcact nucisar safety, plant reliability, regulatory compliance, or plant coeratien? 'If re imcact then no fur:her evaluaton may be necessary for restart.)
115
1 Face 2 :12 ~
\
i 111. Program Health And Effectiveness l A. What pedormance indicators ex:st re!ative to tne program (PERs. FIRS. Ils. NRC, tNRO. ate.)?
i i
l e
i.
E. Do backlogs exist? If so, are they being adequately managed?
t C. What cces trending information indicate for the program?
i i
i D. Cest.noe the heattn of the program and basis for the determination. Consider r:3 : ci and ;.:2. . a evaivatens w: thin the past 18 months and overall performance indicators.
I IV. List Cf Actions Recommended For Restart Or Pest Restart And The Basis For The Recomm-ndat'en.
.? .
t V Restart Ccnclusion c
Program is adeouate for restart. _i Program is acecuate for restart, but recuires long-term improvements. ]_
Program is nct acecuate for restart.
t
/
Evaluator Date
/ ,
Cept. Manager Date i
I 116
c ATTACHMENT 2 SON ADMINISTPdTIVE AND TECHNICAL PROGRAw.S INDEX l
- 1. Employee telations and Development Programs !
- 2. Site Support Programs ;
1
- 3. Site Quality Programs 1
4 Site Licensing Programs t
- 5. Radiological Control Programs >
'P
- 6. Maintenance Programs
- 7. Technical Programs and Performance ,
- 8. Technical Support Programs
-ro
- 9. Site Engineering Programs ,
- 10. Materials and Procurement Programs l
- 11. Security Progra=2 l
- 12. Operations Programs
?
- 13. Chemistry Programs l
- 14. Modifications Programs s
- 15. Plant Manager Programs ;
I
- 16. Training Programs a
- 17. Outage Programs [
i 117 i i
i
- 1. E.mployee Relations and Deveicoment Programs (SSP 1.2) 1. Concerns Resolution (SSP 1.4) 2. Qualification of Personnel (SSP 1.6) 3. Fitness for Duty (SSP 1.7) 4 Overtime (Regulatory)
P 118
t
- 2. Site Support Programs ,
(SSP 2.3) 1. Administration of Site Procedures .
(SSP 2.7) 2. Document Control (SSP 2.8) 3. Drawing Control i
(SSP 2.9) 4. Records Management (SSP 2.12) 5. Computer Software Control (SSP 1.2) 6. Goals and Objectives (SSP 1.5) 7. Saf ety and Health Manual
. r (EPIP) 8. Emergency Preparedness Program f
h r
4
)
F
/
t 9
b 9
119 ;
i i !
l' .i i
i !
1 t
- 3. Site Quality Programs !
i 7
(SSP 3.1) 1. Quality Assurance Program i (SSP 3.4) 2. Corrective Action t
_i t-(SSP 3.5) 3. Stop k'ork :
f i
(SSF 3.7) 4 Finding Identification Report i l (SSP 3.8) 5. Trend Analysis {
i l
i, i
l J
I 120 I i
I i
I 4 Site Licensing Programs 1
(SSP 4.1) 1. Technical Specifications / Licensing Amendments (SSP 4.2) -2. Management of TSAR ;
(SSP 4.3) 3. Management and Tracking of NRC Commitments ,
(SSP 4.4) 4 Management of NER Program (SSP 4.5) 5. Regulatory Reporting Requirements 1
(SSP 4.7) 6. Posting NRC Notices and Information f (SSP 4.8) 7. Nuclear Safety Oversight (SSP 3.6) 8. Problem Evaluation Report i
(SSP 12.5) 9. Technical Specification Interpretation (SSP 12.9) 10. Incident Investigations and Root Cause
?
(SSP 12.13) 11. 50.59 Evaluation Program . ,
(SSP 12.14) 12. JCO/ Waiver of Compliance 1
D I
l 121 l
1.
l
3 l
i
- 5. Radiological Control Program (RCI-1) 1. Radiation Protection Program 2.
(RCI-10) ALARA Program (RCI-17) 3. Controlling By-Product and source Material 'i (SSP 5.5) 4 Reporting of Radiological Incidents .
(SSP 5.51) 5. Radwaste Volume Minimization >
r (PCP Manual) 6. T.S. Process Control Program (ODCM) 7. T.S. Radiological Environmental Monitoring Program ;
(RCI-4) 8. Respiratory Protection Program (RCI-5) 9. Radiation Control Instrument Program ;
I (RCI-11) 10. Bioassay Program ,
6 (RCI-14) 11. Radiation Work Permit Program j (RCI-19) 12. Te=porary Shielding Program (SSP 12.7) 13. Housekeeping / Temp Equip Control / Transient Loads !
.t I
[
f l
t l
'f 122 !
-_ - =_ -
i
- 6. Maintenance Programs l.
(SSP 6.1) 1. Conduct of Maintenance *
(SSP 6.31) 2. Maintenance Management - Pre- or Post-Maintenance Testing )
isSP 6.3) 3. Preventive Maintenance 1
(SSP 6.4) 4 Equipment History and Failure Trend l l
i (SSP 6.6) 5. Operation of Overhead Handling Equipment l (MI-MXX-000-026)
(SSP 6.7) 6. Control of M&TE i (SSP 6.8) 7. Instrumentation Setpoint. Scaling and Calibration Program i
l (SSP 6.11) 8. Equipment Repair / Rework at TVA Service Shops I l
(SSP 6.21-6.30) 9. Cerrective Maintenance Program l (SSP 6.51) 10. Reliability Centered Maintenance 1
(SSP 6.52) 11. Customer Group - Switchyard l l
(SSP 6.56) 12. Labeling and ID Tag Program j (SSP 6.59) 13. Electrical Jumper Control Program 1
(SSP 6.60) 14. Special or Modified Tooling Program (SQM 54) 15. RCP Motor Lube Oil Maintenance Program.
(SQM 57.6) 16. Lubrication Program (Being Devel) 17. Temporary Repair Program i (SSP 7.4) 18. Work Permits (SSP 12.8) 19. Foreign Material Exclusion .
t t
i 123 l
t i
i 4
- 7. Technical Programs and Performance (SSP 8.5) 1. ASME Section XI Pressure Tests (SSP B.6 L) 2. ASME Section XI Pump and Valve Test TI-103) l (SSP 8.7) 3. Containment Leak Rate Test (SQA-185) 4 Piping Vibration Programs (SI 114.1 & 2) 5. ASME In-Service Inspection Program t
(SSP 6.5) 6. Electrical Equipment EQ Program (
(SSP,6.9) 7. ASME Section XI Repair / Replacement Program (SSP 6.10) 8. ASME Section XI and Augmented NOE (Not.e ) 9. Valve Programs (Check /MOV)
(None) 10. Snubber Programs T (SQM 57.5) 11. Predictive Maintenance (SSP 9.54) 12. Erosion / Corrosion Program f (SSP 9.55) 13. Berated Water Corrosion Program i e
(SSP 9.56) 14 Service Water Corrosion Program [
t l
t i.
I t
'[
t 124 r
i
(0-RT-NUC-000-001) 4 Restart Test Program (SSP 5.4) 5. SNM Control (Second Plt. Reliabil/ 6. BOP Program i RCM)
(SSP.9.2) 7. Nuclear Fuel / Core Component Design Ch:nge Control (SSP 12.4) 8. Temporary Alteration Program i
(SSP 12.12) 9. Fuel Receipt. Storage, and Use !
(SSP 12.17) 10. Reactivity Management Program (SSP 12.55) 11. Fuel Integrity Progra=
(TI-111) 12. Condenser Integrity Program (None) 13. T.S. - D.G. Reliability Improvement Program !
h i
5 a
i l
125
i
Configuration Management / Control (SSP 9.5) 3. Design Engineering Practices (SSP 9.1) 4. Controlling Setpoints (SSP 9.52) 5. Equipment Management System :
(Cont. Manuals) 6. Probabilistic Risk Assessment Program (SSP 2.10) 7. Vendor Manual Control (SSP 2.11) 8. Drawing Deviations (SSF 3.2) 9. Augmented Quality Assurance Program !
(SSP 3.3 & 10. Q-List Use and control SQEP 78) -
(SSP 10.5) 11. Technical Evaluation for Procurement of Material and Services (None) 12. Appendix R Program j (NEP 3.1) 13. Calculation Program .
(NEP 3.2) 14 Design Input ,
- (NEP 3.5) 15. Seismic / Structural Qualification ,
(NEP 5.1) 16. Design Output ,
i I
126 I
i i
- 10. Materials and Procurement P r o cra.?.s l (SSP 10.1) 1. Procurement of Material and Services r'
(SSP 10.2) 2. Material Receipt and Inspection
- 3. Handling and Storage of Material (SSP 10.3)
(SSP 10.4) 4 Material Issue Control and Return i
(TI-104) 5. Replacement Items Program. !
(SSP 16.57) 6. Supplemental Material Issue Requirements j i
l
- l l
1 i
i f
i I
I
-i b
n i
f t
L F
l 127 l
i
- 11. Security Programs l I
k (PHYSI-2) 1. Access Clearance for Nuclear Power !
(PHYSI-34) 2. Reporting Safeguards Events j (PHYSI-23) 3. Protection of Safeguards Information (PHYSI-32) 4 Physical Security Plan Train / Qual 5. Training and Qualification Program l Manual ,
i t
6 i
l
?
i h
f r
128 i
- 12. Doerations Programs (SSP 12.1) 1. Conduct of Operations (SSP 12.2) 2. System and Equipment Status (SSP 12.3) 3. Equipment Clearance (SSP 12.6) 4 Equipment Status Verification Program (SSP 12.11) 5. Control and Tracking of Comp. Measures (SSP 12.15) 6. Fire Protection / Transient Fire Load Program (SSP 12.16) 7. E0I Control (SSP 12.18) 8. Switchyard Switching Order Execution (SSP 12.53) 9. Annunciator Disablement (FHI-7) 10. Refueling Operation (SSP 23.51) 11. Radwaste Water Balance and Inleakage Reduction Program (SSP 7.1) 12. Work Control (SSP 8.1) 13. Conduct of Testing (SSP 8.2) 14 Surveillance Test Program ,
t I
1 129 I
i s
- 13. Chemistry Programs i
l (SSP 13.1) 1. Chemistry Program i s
(SSP 13.2) 2. Chemical Traffic Control Program (SSP 13.3) 3. Environmental Compliance (SSP 13.50) 4 Handling and Disposal of Waste Material (0-TI-CEM-260-020) 5. Secondary Water Chemis*ry (0-TI-CEM-260-020) 6. Post Accident Sampling Program (AI-14) 7. Radchem Lab Training -
i (TI*20 & 49) 8. Radchem Lab Test Equipment Calibration Program (Strategic Plan) 9. Steam Generator Reliability Program (TI-49 & 20) 10. T.S. Effluent Monitoring QA Program (SI-137) 11. T.S. Primary Coolant Sources Outside Containment (EPIP) 12. T.S. In-Plant Radiation Monitoring Program ,
(II-12) 13. T.S. Radicactive Effluent Controls Program l
(TI-70) 14 Cleanirg and Decontamination of Plant Equipment l i
(SQM 32) 15. Asiatic Clam Control }
P h
l
)
t f
s i
130 l
3
i i
- 14. Modifications Programs t
t (SSP 7.50, 7.51 1. Welding, Brazing, and Soldering Program ;
& 7.52)
(SSF 7.55) 2. Erection of Scaffolds and Ladders .
(SSP 8.3) 3. Post-Modification Tests .
(SSP 10.51) 4 Control of Contractor Services '
i i
5 I
5 O
t l
e f
u i
l s
131 i
i
(
1 l
l
- 15. Plant Manager Prograr.s r
(SSP B.51) 1. Complex or Infrequently Performed Tests l (SSP 12.52) 2. Personnel Error Reduction /HPES Program ;
(SSP 2.50) 3. Plant Operations Review Cc::nittee ;
?
t l
P e
t t
t 9
o b
r t
I I
T f
h 132 ;
t
t
- 16. SON Training Mrnager 6
(SSP 1.3) 1. Training of Personnel (SSP 4.51) 2. STA Training :
I l
3
. t i
b 9
f s
r O
1 I ,[
i i
1 5
i
.1 1
i I
133
l i
- 17. Outage Programs (SSP 7.2) 1. Outage Management !
I l
t O
O t
b f
B I
i f
P i
i I
i
. i t
i h
9 h
J l
. I i
I I
/. '
PLO90201/3048 134
7 e
r i
j k
i i
I I
i APPENDIX 10 t
i i,
i t
I r
135
- - - -. A + R l
APPENDIX 10 RESTART ITEM CLOSURE l l
l I. Objective ;
This appendix provides the process for documenting completion of Restart Items. This process provides requirements for closure documentation, assignment of responsiblities and j appropriate levels of management review to ensure proper closure. (see Reference 37) j II. Applicability This process applies to closure of all Restan Items listed on the Restart Evaluations for SQN listing maintained by Project Management and Controls (Referer.ce 14). This process is in addition to normal site activity closcout processes, e.g., WR/WO completion, corrective ,
action document completion etc.
B III. Implementation ;
i Closure for each restan item will be accomplished through use of a Restart Pem Closure Form as illustrated in Attachment 1. The attachment I form is an example; closure of restart items using depanment established recreations / renditions of this form is acceptable provided i the department rendition provides for the same information and signatures.
As detailed in Attachment 2, use of the form will provide for brief documentation of the restan item, what actions were taken to resolve / address the item, reference to supporting '
documentation, signature of the evaluator of completion and review signature of the Depanment manager. The department manager will be responsible for maintaining the supponing documentation and ensuring the accuracy of the closure documentation. Upon i completion of the form, the original should be maintained in the department operational readiness notebook with copies forwarded to the SQN Restart Manager (O&PS-4C) and Project Management & Controls (O&PS4G).
i 136
ATIACIFINT 1 RESTART ITEM CLOSURE FORM RESTART ITEM /*
1, ITEM CWNER : !
I I
I. PROBLEM l
l l
I I
I II. ACTION TAKEN:
I I
l I
i .
l I
i i
j i
l l
l III. REFERENCE DOCUMENT (DCN,WP,WR,ETC.) !
J i
Evaluator Date i
/
Department Mgr Date cci M.A. Cooper, CPS 3A-SQN and T.Stanzione CPS 4G-SQhk ,
s a i
1.\
137
ATTACHMENT 2 Page 1 of 2 ITEM 1:
RESTART ITEM #: List restart item nomber from the Restan Evaluations for SQN listing maintained by SQN Project Management & Controls. Ensure accurate unit identification. L ITEM 2:
ITEM OWNER: The name of the restart item owner as listed on the Restan Evaluation list.
ITEM 3:
PROBLEM: Provide a brief statement of the restart item problem / issue. This may be nothing more than the restart item description if sufficient clarity is provided, or may require further explanation of the problem / issue. If there is any question regarding the full scope of the restart item, contact Project Management & Controls to review supporting restart item documentation. If further definitica is still required, MRRC should be consulted.
ITEM 4:
2 . ACTIONS TAKEN: Provide a brief description of what actions were taken to address / resolve the restart item / issue. Wit h the exception for restart WRs described below, ,
Reference to implementing document numbers alone is aql acceptable. Description of actions taken will ensure that the full scope of the restart item is being fully addressed and will provide basis for department manager approval. ,
A restart item which is fully resolved through a restart coded WR may be closed by reference to the restart WR number. It is the responsibility of the department manager to ensure that in fact the full scone is being addressed by the WR and that the WR is coded as restart under the outage management controls before signing closure of a restart item in this manner.
d ITEM 5:
REFERENCE DOCUMENT: List the document or documents that implemented the actions l taken to address / resolve the item, e.g., WR/WOs, PERs, etc. This process does not create a :
stand-alone closure document, but should provide the basis for the full closure " paper trail".
138
1 l
l l
ATTACHMENT 2 l Page 2 of 2 j l
ITEM 6: ,
EVALUATOR: Signature of the person completing the evaluation of closure / completion of the restart item. This person is responsible for submitting restart item closure to the department manager approval following the guidance provided in this Appendix.
ITEM 7:
DEPARTMENT MGR: The department manager shall sign affirming that the restart item has been fully addressed / resolved by the above indicated actions. The department manager is resposible and accountable under signature for the accuracy and appropriateness of the closure. The department manager signature cannot be delecated. excent to a higher manacement level.
a F
l
.)
1 1
l 139
APPENDIX 11 140
APPENDIX 11 STARTUP AND POWER ASCENSION PLAN I. Ut ECTIVE This appendix describes the management plan far ensuring the safe, controlled, and deliberate return to service of Sequoyah Nuclear Plant (SQN). This plan defines and describes assessment hold points where reviews, affirmations, and approvals will be conducted. This plan also describes additional oversight and checks during the startup and power ascension to review plant equipment and personnel performance. This plan integrates portions of other Restart Plan processes, outage closecut processes, and site startup processes and procedures with additional requirements set forth by this appendix.
II. ASSESSMENT IIOLD POINTS This plan establishes the following assessment hold points at which plant conditions are maintained until a prescribed assessment of site readiness for further progression, as defined by this appendix, is completed.
- Mode 5 prior to Mode 4 entry
- Mode 3 prior to Administrative Mode 2 entry (prior to pulling control rods to approach and achieve criticality) e 30 percent reactor power +/- 10 percent e 65 percent reactor power +/- 10 percent
- 90 percent reactor power +/- 5 percent
- 100 percent reactor power (assessment to approve continued operation)
Corresponding holdpoints requiring Plant Manager approval for further increase in plant mode or power level will be established in the applicable general operating instructions. The basis for Plant Manager approval is addressed in this appendix. These holdpoint and associated operational allowances, e.g., +/- 10%, shall not preclude licensed responsibilities l to take the unit, if determined necessary, to a reduced power level or operating mode to ensure safe and stable unit operation.
III. STARTUP AND POWER ASCENSION REVIEW AND APPROVAL MATRIX The Startup and Power Ascension Review and Approval Matrix (attachment 11-1) identifies the review and assessment areas and the types of reviews and approvals for each assessment l hold point. Supporting detail for the matrix requirements and associated assessment hold 141 l
point checklist is contained in Sections IV. - IX.
Approval checklists (Attachment 11-2) and supporting approval checklist continuation forms (Attachment Il-3) will be completed for the associated assessment hold points. The assessment hold point, as defined in Section II above will be entered at the top of Attachment Il-2 and 11-3 forms. The checklists will be completed for the associated assessment hold points and reviewed by the Plant Manager before providing his approval in the General Operating procedure for unit progression beyond that hold point defined condition.
IV. ASSESS 51ENT IIOLD POINT NO.1 - MODE 5 PRIOR TO ENTRY INTO MODE 4 This section describes the reviews, affirmations, and approvals that will be conducted before the initial entry into Mode 4 and subsequent plant heatup to the next holdpoint in Mode 3.
This section also provides the basis for completing the Mode 5 to Mode 4 approval checklist.
Associated comments / remarks, outstanding actions, and/or identified issues / concerns should be listed on the approval checklist continuation form.
IV. A. PLANT EOUIPMENT OUTAGE PHYSICAL WORK COMPLETION tLL Outage Srps - The outage scheduled activities required for Mode 4 or Mode 3 operation will be verified complete by the Outage Planning Manager. Any outstanding activities will be listed on the Approval Checklist Continuation Form. A summary of outage activities to be conducted in Mode 4 and Mode 3 will be attached to the Mode 5 to Mode 4 approval checklist continuation form. When outage activities to support Mode 4 entry are verified complete, the Outage Planning Manager shall affirm completion by signing the approval checklist.
A.2. New WRs - SROs will review new WRs for impact on Mode 4 or Mode 3 operation.
A.n SRO will affirm acceptability of any new unworked WRs on Mode 4 entry by signing the approval checklist.
SYSTEM READINESS d System Readiness Affirmation - The Final System Readiness Review Forms from Appendix 5 of the Restart Plan will be completed for systems required for Mode 4 operation.
The Technical Support Manager will have reviewed the completion status of outstanding 142
system related restart activities at the time of completion of the Final System Readiness Review Forms and will list any outstanding restart activities on the Approval Checklist Continuraion Form. The list and status of any incomplete Final System Readiness Review Forms (for any operating condition or mode) will be listed on the Approval Checklist Continuation Form. When the status of outstanding items is determined acceptable, the Technical Support Manager shall affirm readiness of the systems required for Mode 4 entry by signing the Mode 5 to Mode 4 approval checklist.
M System Performance - Results of any walkdowns conducted to identify leaks and results of any activities to assess / monitor system performance (e.g., normal operator rounds, post maintenance or modi 6 cation testing, operations and system engineer monitoring of plant / equipment performance) will be reviewed for completion of appropriate action to support reliable system performance for Mode 4 or Mode 3 operation. Uncorrected leaks documented on WRs or unresolved issues will be identined on the Mode 5 to Mode 4 approval checklist continuatien form. When the operational status of systems is determined to be acceptable for mode change, the Technical Support Manager and Operations Manager shall afGrm readiness of the systems for Mode 4 or Mode 3 operation by signing the Mode 5 to Mode 4 approval checklist.
OPER ATIONS READINESS M System Alignments - The Operations Superintendent will verify correct plant alignment for Mode 4 entry after reviewing system checklists and system status files, and conducting thorough board walkdowns. Any concerns or issues shall be documented on the Mode 4 Approval Checklist Continuation Form. When the system lineups are determined ready for Mode 4 entry, the Operations Superintendent will afGrm readiness by signing the Mode 5 to Mode 4 approval checklist.
A.6. GOI Reauirements Satisfied - Operations will review the completion status of GOl-1 for Mode 4 entry. Any concerns or issues shall be documented on the approval checklist continuation form. When GOI-l requirements for mode change have been verified complete, the Operations Superintendent shall afGrm that the requirements are satisfied by signing on the Mode 5 to Mode 4 approval checklist. Any exceptions shall be noted on the approval checklist continuation form.
A,7. Housekeepine and Material Condition - Plant management shall conduct a general plant tour to verify that the general plant housekeeping and material condition is ready to support Mode 4 operation. Any identified issues or concerns shall be documented on the Mode 4 approval checklist. The Plant Manager shall afGrm that housekeeping and material condition are acceptable for plant heatup and return to service by signing the Mode 5 to Mode 4 approval checklist.
M Chemistry Parameters - The Radiological and Chemistry manager shall review and 143
verify acceptability of plant chemistry parameters for plant heatup from Mode 5 to Mode 4.
The Radiological and Chemistry manager shall affirm acceptability be signing the Mode 5 to Mode 4 approval checklist.
IV.B. DEPARTMENT AND PERSONNEL B.l. DEPARTMENT READINESS The Site Vice President and MRRC shall review the status of completion of department readiness reviews being conducted in accordance with Appendix 6 of this Restart Plan. The Site Vice President will affirm review and satisfactory progress / status of department readiness to support entry into Mode 4 by signing the Mode 5 to Mode 4 approval checklist.
AUGMENTED OVERSIGHT B1 Plant Management - A management oversight team, under the direction of the Plant Manager, shall be established and in place prior to Mode 4 entry for the purposes of monitoring and evaluating overall plant and personnel performance during the startup and power ascension period. Oversight will be maintained around the clock using rotating management oversight duty assignment and will contin 2e through successful accomplishment of the final 100% power assessment conducted in sectior IX. Coverage will include both SRO level experienced individuals to monitor Operations performance and other management level individuals to monitor control and performance of overall plant activities. Identined issues or concerns will be reported to the Duty Plant Manager. The Plant Manager may suspend coverage if there are prolonged holds at any point or other warranting bases. The Site Vice President will be notified of such suspension. The Plant Manager will affirm that the oversight team coverage has been established by signing the Mode 5 to Mode 4 approval checklist.
ILL Nuclear Assurance (NA) - An NA team shall be established by the Site Quality Manager and in place prior to Mode 4 entry for the purposes of assessing specific and overall conduct and performance of stanup and power ascension activities. Team assessment methodology and coverage will be established under the direction of the Site Quality l
Manager. This oversight activity will continue through successful accomplishment of the final 100% power assessment conducted in section IX. Identified issues or concerns will be i
reported to the Site Quality Manager who will brief the Plant Manager on a periodic basis.
Issues or concerns may be reported directly to the Duty Plant Manager as warranted. The Site Quality Manager shall affirm the NA team is established and in place by signing the Mode 5 to Mode 4 approval checklist.
144 .
IV.C.OVERALL READINESS G MANAGEMENT RESTART REVIEW COMMITTEE (MRRC) - The MRRC shall approve the readiness for entry into Mode 4 based on review of the Site Readiness Assessment conducted in accordance with Appendix 7 of this Restart Plan; review of the Mode 5 to Mode 4 approval checklist completion, including review of the Mode 5 to Mode 4 approval checklist continuation form and any attachments; and review of any current NRC concerns as presented by the Site Licensing Manager. The MRRC Chairman shall affirm completion of the Site Readiness Assessment for initial mode change (Mode 5 to Mode 4),
completion and detailed review of Sections A and B of the Mode 5 to Mode 4 approval checklist including the continuation form and any attachments, and readiness for Mode 4 entry by signing the Site Readiness Assessment Form in accordance with Appendix 7 of the Restart Plan and in Section C of the Mode 5 to Mode 4 approval checklist.
C.2. PLANT OPER ATIONS REVIEW COMMITTEE (PORC)- The PORC shall review the plant's readiness for Mode 4 entry. This review will be conducted concurrent with the MRRC review. The PORC Chairman will affirm PORC approval for the initial mode change from Mode 5 to Mode 4 by signing the Site Readiness Assessment Form in accordance with Appendix 7 of the Restart Plan and Section C of the Mode 5 to Mode 4 approval checklist.
G SENIOR TVA MANAGEMENT - The Site Vice President shall review the plant's readiness with the Vice President, Nuclear Operations and President, Generating Group.
After receiving concurrence from the Vice President, Nuclear Operations and President, Generating Group for entry mio Mode 4, the Site Vice President shall sign the Mode 5 to Mode 4 approval checklist indicating that concurrence.
M NUCLEAR REGULATORY COMMISSION (NRC) - The Site Vice President shall ensure that the NRC Regional Administrator has been notified of TVA approval for the initial mode change from Mode 5 to Mode 4 and that any NRC concerns which could impact this mode change have been resolved by signing the Mode 5 to Mode 4 approval checklist.
M PLANT MAN AGER - The Plant Manager shall verify completion of the Mode 5 to Mode 4 approval checklist before providing approval in GOI-1 for entry into Mode 4. The Plant Manager shall affirm completion and readiness by signing the Mode 5 to Mode 4 approval checklist.
145
V. ASSESSMENT HOLD POINT NO.2 - MODE 3 PRIOR TO ENTRY INTO ADMINISTRATIVE MODE 2 (PRIOR TO PULLING CONTROL RODS TO APPROACH AND ACHIEVE CRITICALITY)
This section describes the reviews, affirmations, and approvals that will be conducted in Mode 3 before beginning to pull control rods to approach and achieve criticality and begin power operation up to the next holdpoint at 30% reactor power +/- 10%. This section also provides the basis for completing the Mode 3 to Mode 2 approval checklist. Associated comments / remarks, outstanding actions, and/or identified issues / concerns should be listed on the Mode 3 to Mode 2 approval checklist continuation form.
V. A. PLANT EOUIPMENT OUTAGE PHYSICAL WORK COMPLETION M Outage Scoce - The outage scheduled activities required for Mode 2 operation up to 30% +/- 10% reactor power will be verified complete by the Outage Planning Manager.
Any outstanding activities will be listed on the Mode 3 to Mode 2 Approval Checklist Continuation Form. A summary of outage activities to be conducted in Mode 2 and up to 40% reactor power will be attached to the approval checklist continuation form. When outage activities to support Mode 2 entry are verined complete, the Outage Planning Manager shall afGrm completion by signing the Mode 3 to Mode 2 approval checklist.
R New WRs - SROs will review new WRs for impact on Mode 2 or power operation up to 40% reactor power. An SRO will afGrm acceptability of any new unworked WRs on Mode 2 entry by signing the Mode 3 to Mode 2 approval checklist.
SYSTEM READINESS d System Readiness Aifirmation - The Final System Readiness Review Forms will be completed for systems in accordance with Appendix 5 of this Restan Plan. The Technical Support Manager will have reviewed the completion status of outstanding system related restart activities at the time of completion of the Final System Readiness Review Forms and will list any outstanding restart activities on the Mode 3 to Mode 2 Approval Checklist Continuation Form. When the status of outstanding items is determined acceptable, the Technical Support Manager shall affirm completion of the Final System Readiness Forms and readiness of plant systems for Mode 2 entry by signing the Mode 3 to Mode 2 approval checklist.
M System Performance - Results of any walkdowns conducted to identify leaks and results of any activities to assess / monitor system performance (e.g., normal operator rounds, post 146
' ------______m__________ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
maintenance or modification testing, operations and system engineer monitoring of plant / equipment performance) will be reviewed for completion of appropriate action to support reliable system performance for Mode 2 and power operation up to 40% reactor power. Uncorrected leaks documented on WRs or unresolved issues will be identified on the Mode 3 to Mode 2 approval checklist continuation form. When the operational status of systems is determined to be acceptable for mode change, the Technical Support Manager and Operations Manager shall affirm readiness of the systems for Mode 2 and power operation up to 40% reactor power by signing the Mode 3 to Mode 2 approval checklist.
OPERATIONS READINESS M System Alienments - The Operations Superintendent will review plant alignment for Mode 2 entry from reviewing the GO status, hold orders and TSCCR logs, and conducting thorough board walkdowns. Any concerns or issues shall be documented on the Mode 3 to Mode 2 approval checklist continuation form. When the system lineups are determined ready for Mode 2 entry, the Operations Superintendent will affirm readiness by signing the Mode 3 to Mode 2 approval checklist.
M GO Requirements Satisfied - Operations will review the completion status of 0-GO-2-1 for Mode 2 entry. Any concerns, issues, deviations or incomplete actions shall be documented on the Mode 3 to Mode 2 Approval Checklist Continuation Form. When 0-GO-2-1 requirements for mode change have been verified complete, the Operations Superintendent shall affirm that the requirements are satisfied by signing on the Mode 3 to Mode 2 approval checklist. Any exceptions shall be noted on the approval checklist continuation form.
A l N/A M Chemistry Parameters - The Radiological and Chemistry manager shall review and verify acceptability of plant chemistry paramaers for taking the unit critical and beginning power increase to 30% reactor power. The Radiological and Chemistry manager shall affirm acceptability be signing the Mode 3 to Mode 2 approval checklist.
V.B. DEPARTMENT AND PERSONNEL DEPARTMENT READINESS B.I. DEPARTMENT READINESS The Site Vice President and MRRC shall review the completion of department readiness reviews being conducted in accordance with Appendix 6 of this Restart Plan. The Site Vice President will affirm review and completion of department readiness review and affirmation forms by signing the Mode 3 to Mode 2 approval checklist.
147
i AUGMENTED OVERSIGHT R1 Plant Manaeement - The management oversight team shall report oversight activity results since Mode 4 entry to the Plant Manager for consideration in assessing readiness for Mode 2 entry using Attachment Il-4. The Plant Manager will attach this report to the Mode 3 to Mode 2 approval checklist continuation form and affirm acceptable disposition of identified concerns / issues by signing the Mode 3 to Mode 2 approval checklist.
LL Nuclear Assurance (NA) - The NA oversight team shall report oversight activity results since Mode 4 entry to the Site Quality Manager. The Site Quality Manager shall summarize (or attach) the results on the Mode 3 to Mode 2 approval checklist continuation form. The Site Quality Manager shall affirm acceptable disposition ofidentified concerns / issues by signing the Mode 3 to Mode 2 approval checklist.
V.C.OVERALL READINESS M MANAGEMENT RESTART REVIEW COMMITTEE (MRRQ - The MRRC shall approve the readiness for entry into Mode 2 based on review of the Site Readiness Assessment conducted in accordance with Appendix 7 of this Restart Plan; review of the Mode 3 to Mode 2 approval checklist completion, including review of the approval checklist continuation form and any attachments; and review of the Regulatory Closure Affirmation (Appendix 8) and any current NRC concerns as presented by the Site Licensing Manager.
The MRRC Chairman shall affirm completion of the Site Readiness Assessment for Mode 2 entry, completion and detailed review of Sections A and B of the Mode 3 to Mode 2 approval checklist including the continuation form and any attachments, and readiness for mode 2 entry by signing the Site Readiness Assessment Form in accordance with Appendix 7 of the Restart Plan and the Mode 3 to Mode 2 approval checklist.
C PLANT OPERATIONS REVIEW COMMITTEE (PORC) - The PORC shall review the plant's readiness for Mode 2 entry. This review will be conducted concurrent with the MRRC review. The PORC Chairman will affirm PORC approval for Mode 2 entry by signing the Site Readiness Asser.sment Form in accordance with Appendix 7 of the Restart Plan and the Mode 3 to Mode 2 approval checklist.
M SENIOR TVA MANAGEMENT - An executive readiness review will be conducted following site readiness review. Readiness presentations will be made by both site and corporate management to the SQN Site Vice President; Vice President, Nuclear Operations; Vice President, Technical Support; and President, Generating Group. After reaching concurrence on readiness for unit restart, the Site Vice President will indicate Senior TVA management approval by signing the Mode 3 to Mode 2 approval checklist.
148
M NUCLEAR REGULATORY COMMISSION (NRC)- The Site Vice President shall ensure that the Confirmation of Action Letter (Reference 1) has been satisfied, that the NRC Regional Administrator has provided approval for entry into Mode 2 and that any hTC concerns which could impact this mode change have been resolved by signing the Mode 3 to Mode 2 approval checklist.
M PLANT MANAGER - The Plant Manager will verify completion of the Mode 3 to Mode 2 approval checklist before providing approval in 0-GO-2-1 to begin pulling control rods for approach to criticality. The Plant Manager will affirm completion and readiness by signing the Mode 3 to Mode 2 approval checklist.
l l
149
VI. ASSESSMENT IIOLD POINT NO.3 - 307c REACTOR POWER +/- 107c This section describes the reviews, afGrmations, and approvals that will be conducted before increasing power beyond 30% +/- 10% up to the next holdpoint at 65% reactor power +/-
10%. This section also provides the basis for completing the 30% approval checklist.
Associated comments / remarks, outstanding actions, and/or identified issues / concerns should be listed on the 30% Approval Checklist Continuation Form.
VI. A. PLANT EOUIPMENT OUTAGE PHYSICAL WORK COMPLETTON AL Outage Scone - The outage scheduled activities required for operation up to 75%
reactor power will be veri 5ed complete by the Outage Planning Manager. Any outstanding activities will be listed on the 30% power approval checklist continuation form. A summary of outage activities to be conducted up to 75% reactor power will be attached to the 30%
power approval checklist continuation form. When outage activities to support power
- increase to 65% +/- 10% are verified complete, the Outage Planning Manager shall affirm completion by signing the 30% approval checklist.
AL New WRs - SROs will review new WRs for impact on continued power operation and up to 75% reactor power. An SRO will affirm acceptability of any new unworked WRs by signing the 30% power approval checklist.
SYSTEM READINESS A.3. N/A M System Performance - Results of any walkdowns conducted to identify leaks and results of any activities to assess / monitor system performance (e.g., normal operator rounds, post maintenance or modification testing, operations and system engineer monitoring of plant / equipment performance) will be reviewed for completion of appropriate action to suppon reliable system performance for power operation up to 75% reactor power.
Uncorrected leaks documented on WRs or unresolved issues will be identified on the 30%
power approval checklist continuation form. When the operational status of systems is determined to be acceptable for power increase, the Technical Support Manager and Operations Manager shall affirm readiness of the systems for power operation up to 75%
reactor power by signing the 30% power approval checklist.
150
OPERATIONS READINESS h System Alignments - The Operations Superintendent will review plant alignment for power increase up 10.75% reactor power. Any concerns or issues shall be documented on the 30% power Approval Checklist Continuation Form. When the system lineups are determined ready for power increase, the Operations Superintendent will afGrm readiness by signing the 30% power approval checklist.
M GO Requirements Satisfied - Operations will review the completion status of 0-GO-2-3 for power increase beyond 30%. Any concerns, issues, deviations or incomplete actions shall be documented on the 30% Power Approval Checklist Continuation Form. When 0-GO-2-3 requirements have been veri 5ed complete for power increase, the Operations Superintendent shall affirm that the requirements are satisned by signing on the 30%
approval checklist.
M N/A d Chemistry Parameten - The Radiological and Chemistry manager shall review and verify acceptability of plant chemistry parameters for power increase up to 75% reactor power. The Radiological and Chemistry manager shall afGrm acceptability be signing the 30% power approval checklist.
VI.B. DEPARTMENT AND PERSONNEL DEPARTMENT READINESS ILL N/A AUGMENTED OVERSIGHT ILL Plant Manacement - The management oversight team shall report oversight activity results since Mode 2 entry to the Plant Manager for consideratica in assessing readiness for funher power increase using Attachment Il-4. This will include assessment of personnel,
! department, and program / process performance. The Plant Manager will attach this oversight report to the 30% power approval checklist continuation form and affirm acceptable disposition of identified concerns / issues by signing the 30% approval checklist.
IL3 Nuclear Assurance (NA) - The NA oversight team shall report oversight activity results since Mode 2 entry to the Site NA Manager. The Site NA Manager shall summarize (or attach) the results on the 30% power approval checklist continuation form. The Site Quality Manager shall affirm acceptable disposition of identined concerns / issues by signing the 30%
power approval checklist.
151
i l
r i
VI.C.OVERALL READINESS j
G MANAGEMENT. RESTART REVIEW COMMITTEE (MRRC) - The MRRC shall approve the readiness c further power increase to 65% +/- 10%. Approval will be based j on review of the 30% power approval checklist, including review of the 30% approval checklist continuation form and attachments. This review addresses completion of outage [
.-elated activities to support readiness for the power increase; scheduling and control of !
nctivities up to the next hold point; system / plant performance since Mode 2; and oversight team results considering personnel, department, and program / process performance since Mode 2. The MRRC Chairman shall affirm completion and detailed review of Sections A [
and B of the 30% power approval checklist including the continuation form and attachments j and readiness for power increase to 65% +/- 10% by signing the 30% power approval checklist.
l t
C PLANT OPERATIONS REVIEW COf fMITTEE (PORC) - The PORC shall review the l plant's readiness for further power increase to 65% +/- 10%. This review will be conducted concurrent with the MRRC review. The PORC Chairman will affirm PORC
, approval by signing the 30% power approval checklist. l G SENIOR TVA MANAGEMENT - The Site Vice President shall review the plant's !
readiness for further power increase with the Vice President, Nuclear Operations and '
President, Generating Group. After receiving concurrence with the decision to increase power to 65% from the Vice President, Nuclear Operations and President, Generating Group, the Site Vice President shall sign the 30% power approval checklist indicating that
~
concurrence. !
i M NUCLEAR REGULATORY COMMISSION (NRC) - The Site Vice President shall !
ensure that the NRC Regional Administrator has been notified of TVA approval for further power increase to 65% power and that any NRC concerns regarding further power increase have been addressed by signing the 30% power approval checklist. :
l M PLANT M ANAGER - The Plant Manager will verify completion of the 30% power !
approval checklist up to this final signature before providing approval in GOI-5 for further i
power increase up to the 65% +/- 10% holdpoint. The Plant Manager will affirm completion and readiness by signing the 30% power approval checklist. i f
4 e
152 ;
F 1
i
I VII. ASSESSMENT IIOLD POINT NO. 4 - 65% REACTOR POWER +/- 10% 4 i
This section describes the reviews, affirmations, and approvals that will be conducted before- :
increasing power beyond 65% +/- 10% up to the next holdpoint at 90% reactor power +/-
10%. This section also provides the basis for completing the 65% approval checklist. ,
. Associated comments / remarks, outstanding actions, and/or identified issues / concerns should be listed on the 65% approval checklist continuation form. ,
i VII. A. PLANT EOUIPMENT r
OUTAGE PHYSICAL WORK COMPLETION i
/L1 Outage Scone - The outage scheduled activities required for 65% ope stion up to 95%
reactor power will be verified complete by the Outage Planning Manager. At . Ttanding L activities will be listed on the 65% power approval checklist continuation form. a summary of outage activities to be conducted up to 95% reactor power will be attached to the 65% !
power approval checklist continuatior. form. When outage activities to support power ,
increase to 95% are verified complete, the Outage Planning Manager shall affirm completion :
by signing the 65% approval checklist. f
/LL New WRs - SROs will review new WRs for impact on continued power operation up to 95% reactor power. An SRO will affirm acceptability of any new unworked WRs by signing the 65% power approval checklist.
SYSTEM READINESS M N/A M System Performance - Results of any walkdowns conducted to identify leaks and results of any activities to assess / monitor system performance (e.g., normal operator rounds, post maintenance or modification testing, operations and system engineer monitoring of plant / equipment performance) will be reviewed for completion of appropriate action to support reliable system performance for power operation up to 95% reactor power.
Uncorrected leaks documented on WRs or unresolved issues will be identified on the 65%
power approval checklist continuation form. When the operational status of systems is derrmined to be acceptable for power increase, the Technical Support Manager and
, 0;mtions Manager shall affirm readiness of the systems for power operation up to 95%
reactor power by signing the 65% power approval checklist.
153
1 DPERATIONS READINESS i
M System Alienments - The Operations Superintendent will review plant alignment for power increase up to 95% reactor power. Any concerns or issues shall be documented on ;
the 65% power Approval Checklist Continuation Form. When the system lineups are determined ready for power increase, the Operations Superintendent will affirm readiness by ;
signing the 65% power approval checklist. ;
M GOI Recuirements Satisfied - Operations will review the completion status of GOI-5 for power increase beyond 65%. Any concerns, issues, deviations or incomplete actions shall be !
documented on the 65% Power Approval Checklist Continuation Form. When GOl-5 requirements for further power increase have been verined complete, (Venfy step number),
the Operations Superintendent shall affirm that the requirements are satisfied by signing on the 65% approval checklist. Any exceptions shall be noted on the approval checklist continuation form. ,
M N/A
> L M Chemistrv Parameters - The Radiological and Chemistry manager shall review and . !
verify acceptability of plant chemistry parameters for power increase up to 95%. The Radiological and Chemistry manager shall affirm acceptability be signing the 65% approval checklist.
VII.B. DEPARTMENT AND PERSONNEL DEPARTMENT READINESS BA N!% ,
AUGMENTED OVERSIGHT i B1 Plant Manacement - The management oversight team shall report oversight activity results since the 30% holdpoint assessment to the Plant Manager for consideration in -
assessing readiness for further power increase using Attachment 11-4. This will include ,
assessment of personnel, depanment, and program / process performance. The Plant Manager will attach this report to the 65% power approval checklist continuation form and affirm ,'
acceptable disposition of identified concerns / issues by signing the 65% approval checklist.
- B1 Nuclear Assurance (NA) - The NA oversight team shall report oversight activity results since the 30% hold point assessment to the Site Quality Manager. The Site Quality Manager shall summarize (or attach) the results on the 65% power approval checlaist continuation .
form. The Plant Manager shall affirm acceptable disposition of identified concerns / issues by signing the 65 % power approval checklist. ;
154 i
t i
i VII.C. OVERALL READINESS Q MANAGEMENT RESTART REVIEW COMM111EE (MRRC) - The MRRC shall approve the readiness for further power increase to 90% +/- 5%. Approval will be based j
~
on review of the 65% power approval checklist,iacluding review of the 65% approval checklist continuation form and attachments. This review addresses completion of outage related activities to support readiness for the power increase; scheduling and control of ;
activities up to the next hold point; system / plant performance to this point; and oversight team results considering personnel, department, and program / process performance. The MRRC Chairman shall affirm completion and detailed review of Sections A and B of the !
65% power approval checklist including the continuation form and attachments and readiness for power increase to 90% +/- 5% by signing the 65% power approval checklist. l
?
Q PLANT OPERATIONS REVIEW COMMITTEE (PORC)- The PORC shall review the plant's readiness for further power increase to 90% +/- 5%. This review will be conducted concurrent with the MRRC review. The PORC Chairman will affirm PORC approval by [
signing the 65% power approval checklist. t Q SENIOR TVA MANAGEMENT - The Site Vice President shall review the plant's !
readiness for further power increase with the Vice President, Nuclear Operations and President, Generating Group. After receiving concurrence with the decision to increase j power to 90% +/- 5% from the Vice President, Nuclear Operations and President, j Generating Group, the Site Vice President shall sign the 65% power approval checklist i indicating that concurrence.
G NUCLEAR REGULATORY COMMISSION (NRC) - The Site Vice President shall ensure that the NRC Regional Administrator has been notified of TVA approval for further j power increase to 90% +/- 5% power and that any NRC concerns regarding further power increase have been addressed by signing the 65% power approval checklist. l i
i G PL ANT M ANAGER - The Plant Manager will verify completion of the 65% power approval checklist up to this final signature before providing approval in GOI-5 for further i power increase up to the 90% +/- 5% holdpoint. The Plant Manager will affirm completion l and readiness by signing the 65% power approval checklist.
I i
~
l l
l 155 I
l
i VIII. ASSESSMENT HOLD POINT NO. 5 - 90% REACTOR POWER +/- 5% ,
i This section describes the reviews, affirmations, and approvals that will be conducted before ,
increasing power beyond 90% +/- 5% up to 100% reactor power. This section also [
provides the basis for completing the 90% approval checklist. Associated (
comments / remarks, outstanding actions, and/or identified issues / concerns should be listed on j the 90% approval checklist continuation form.
i I
VIII. A. PLANT EOUTPMENT OUTAGE PHYSICAL WORK COMPLETION
/L1 Outace Scope - The outage scheduled activities required for operation up to 100%
reactor power will be verified complete by the Outage Planning manager. Any outstanding !
activities will be listed on the 90% power approval checklist continuation form. A summary :
of outage activities to be conducted up to and at 100% reactor power will be attached to the t 90% power approval checklist continuation form. When outage activities to support power increase to 100% are verified complete, the Outage Planning Manager shall affirm completion by signing the 90% approval checklist.
R New WRs - SROs will review new WRs in for impact on continued power operation up ' I to 100%. An SRO will affirm acceptability of any new unworked WRs by signing the 90% j power approval checklist.
SYSTEM READINESS f 4
/L1 E!M ,
/LL System Performance - Results of any walkdowns conducted to identify leaks and results '
of any activities to assess / monitor system performance (e.g., normal operator rounds, post maintenance or modification testing, operations and system engineer monitoring of
- plant / equipment performance) will be reviewed for completion of appropriate action to support reliable system performance for power operation up to 100% reactor power.
Uncorrected leaks documented on WRs or unresolved issues will be identified on the 90%
power approval checklist continuation form. When the operational status of systems is ,
determined to be acceptable for power increase, the Technical Support Manager and Operations Manager shall affirm readiness of the systems for power operation up to 100% ;
reactor power by signing the 90% power approval checklist. i i
i 156 i l
l i
i l
i OPERATIONS READINESS M System Alienments - The Operations Superintendent will review plant alignment for power increase up to 100%. Any concerns or issues shall be documented on the 90% power j Approval Checklist Continuation Form. When the system lineups are determined ready for !
power increase, the Operations Superintendent will affirm readiness by signing the 90% 'l power approval checklist.
M GOI Requirements Satisfied - Operations will review the completion status of GOI-5 for t i
power increase beyond 90%. Any concerns, issues, deviations or incomplete actions shall be documented on the 90% Power Approval Checklist Continuation Form. When GOI-5 requirements for further power increase have been verified complete, the Operations Superintendent shall affirm that the requirements are satisfied by signing on the 90% '
approval checklist. Any exceptions shall be noted on the approval checklist continuation
, form.
' J M E!M i; M Chemistry Parameters - The Radiological and Chemistry manager shall review and i verify acceptability of plant chemistry parameters for power increase to 100%. The Radiological and Chemistry manager shall affirm acceptability be signing the 90% approval checklist. i t
VIII.B. DEPARTMENT AND PERSONNEL DEPARTMENT READINESS i i
ILL N/A AUGMENTED OVERSIGHT s
ILL Plant Management - The management oversight team shall report oversight activity [
results since the 65% holdpoint assessment to the Plant Manager for consideration in ,
assessing readiness for further power increase using Attachment 11-4. This will include assessment of personnel, department, and program / process performance. The Plant Manager ;
will attach this report to the 90% power approval checklist continuation form and affirm -!
acceptable disposition ofidentified concerns / issues by signing the 90% approval checklist. l B1 Nuclear Assurance (NA)- The NA oversight team shall report oversight activity results '
since the 65% hold point assessment to the Site Quality Manager. The Site Quality Manager shall summarize (or attach) the results on the 90% power approval checklist continuation form. The Site Quality Manager shall affirm acceptable disposition of identified ;
concerns / issues by signing the 90% power approval checklist.
157
VIII.C.OVERALL READINESS G MANAGEMENT RESTART REVIEW COMMFITEE (MRRQ - The MRRC shall approve the readiness for further power increase to 100%. Approval will be based on review of the 90% power approval checklist, including review of the 90% approval checklist continuation form and attachments. This review addresses completion of outage related activities to support readiness for the power increase; scheduling and control of activities up to 100% reactor power; system / plant performance to this poir.t; and oversight team results considering personnel, department, and program / process performance. The MRRC Chairman shall affirm completion and detailed review of Sections A and B of the 90% power approval checklist including the continuation form and attachments and readiness for power increase to 100% by signing the 90% power approval checklist.
G PLANT OPERATIONS REVIEW COMMITTEE (PORC) - The PORC shall review the plant's readiness for further power increase to 100%. This review will be conducted concurrent with the MRRC review. The PORC Chairman will affirm PORC approval by signing the 90% power approval checklist.
G SENIOR TVA MANAGEMENT - The Site Vice President shall review the plant's readiness for further power increase with the Vice President, Nuclear Operations and President, Generating Group. After receiving concurrence with the decision to increase power to 100% from the Vice President, Nuclear Operations and President, Generating Group, the Site Vice President shall sign the 90% power approval checklist indicating that concurrence.
G NUCLEAR REGULATORY COMMISSION (NRC) - The Site Vice President shall ensure that the NRC Regional Administrator has been notified of TVA approval for further power increase to 100% power and that any NRC concerns regarding further power increase have been addressed by signing the 90% power approval checklist.
G PLANT MANAGER - The Plant Manager will verify completion of the 90% power approval checklist up to this final signature before providing approval in GOI-5 for further power increase up to the 100% reactor power. The Plant Manager will affirm completion and readiness by signing the 90% power approval checklist.
158
l l
IX. ASSESSMENT IIOLD POINT NO. 6 - 100% REACTOR POWER l This section describes the reviews, affirmations, and approvals that will be conducted upon reaching 100% reactor power. This assessment will be conducted after five days of 1 continuous full power operation and will be documented on a 100% power approval checklist. The assessment will establish the basis for continued full power operation and, based upon favorable results, will mark the transition from this special power ascension 1' monitoring process to the normal plant procedures and processes.
IX. A. PLANT EOUIPMENT ;
OUTAGE PHYSICAL WORK COMPLETION i M Outage Scope - The outage scheduled activities required for full power operation will be verified complete by the Outage Planning Manager. Any outstanding activities will be '
listed on the 100% power approval checklist continuation form. The Outage Planning Manager shall affirm completion by signing the 100% power approval checklist. :
i Al New WRs - SROs will review new WRs for impact on continued power operation. An i SRO will affirm appropriate prioritization and scheduling of any new unworked WRs by signing the 100% power approval checklist. ,
SYSTEM READINESS l A l N!M AA System Performance - Results of any walkdowns conducted to identify leaks and results of any activities to assess / monitor system performance (e.g., normal operator rounds, post maintenance or modification testing, operations and system engineer monitoring of i plant / equipment performance) will be reviewed for completion of appropriate action to support continued ;rliable full power operation. Uncorrected leaks documented on WRs or unresolved issues will be identified on the 100% power approval checklist continuation form.
When the operational status of systems is determined to be acceptable for continued reliable )
full power operation, the Technical Support Manager and Operations Manager shall affirm _,
readiness of the systems by signing the 100% power approval checklist. ;
t 159 .
a
4..
OPERATIONS READINESS i M System Alignments - The Operations Superintendent will review plant alignment for full l
~
power operation. Any concerns or issues shall be documented on the 100% power Approval !
Checklist Continuation Form. When plant alignment is reviewed and determined acceptable, the Operations Superintendent will affirm readiness for continued reliable operation by signing the 100% power approval checklist. :
i M GOI Reauirements Satisfied - Operations will review the completion status of GOI-5 for l
full power operation. Any concerns, issues, deviations or incomplete actions shall be '
documented on the 100% Power Approval Checklist Continuation Form. When G01-5 '
requirements for continued full power operation have been verified complete, the Operations Superintendent shall affirm that the requirements are satisfied by signing on the 100%
approval checklist.
A l N/A l t
Al Chemistrv Parameters - Tl'e Radiological and Chemistry manager shall review and verify acceptability of plant chemistry parameters for continued full power operation. The Radiological and Chemistry manager shall affirm acceptability be signing the 100% approval checklist.
IX.B. DEPARTMENT AND PERSONNEL DEPARTMENT READINESS E.L N LA AUGMENTED OVERSIGHT D1 Plant Management - The management oversight team, using Attachment 11-4, shall prepare a report summarizing oversight activity results since the 90% holdpoint assessment-and the collective results of oversight activity over the entire startup and power ascension evolution. This will include assessment of personnel, department, and program / process performance as well as review of any recent plant events. The Plant Manager shall reviev, and attach this report to the 100% power approval checklist continuation form for overall MRRC and PORC consideration in assessment of acceptability of plant, personnel, and process performance to support safe and reliable continued operation. The Plant Manager shall sign the 100% power approval checklist indicating review and inclusion of this report.
160
i 211 Nuclear Assurance (NA)- The NA oversight team shall prepare a report summarizing oversight activity results since the 90% hold point assessment and the collective mesult of oversight activity during the entire startup and power ascension evolution. The Site Quaiity i Manager shall attach the report to the 100% power approval checklist continuation form for
- overall MRRC and PORC consideration in assessment of acceptability of plant, personnel, and process performance to support safe and reliable continued operation. The Site Quality :
Manager shall sign the 100% power approval checklist indicating review and inclusion of this repert.
IX.C.OVERALL READINESS G MANAGEMENT RESTART REVIEW COMMITTEE (MRRC) - The MRRC shall review and approve the readiness of the plant and site personnel and processes to support continued safe and reliable full power operation. Approval will be based on review of the ,
4 100% power approval checklist, including review of the 100% approval checklist continuation form and attachments. This review addresses completion of outage related '
activities; review of new maintenance WRs; review of system / plant performance; and oversight team results considering overall plant, personnel, department, and program / process performance. The MRRC Chairman shall affirm completion and detailed review of Sections A and B of the 100% power approval checklist including the continuation form and attachments and, based upon acceptable results, shall indicate readiness for continued safe and reliable full power operation by signing the 100% power approval checklist. This !
signature indicates approval to transition from the special processes outlined in the SQN Restart Plan and this power ascension program to the normal site processes for the associated unit. Outstanding or longer term improvements or action items resulting from this review will be identified and tracked through established site processes.
C PLANT OPERATIONS REVIEW COMMITTEE (PORC)- The PORC shall review the.
plant's readiness for continued safe and reliable full power operation. Thi.s review will be conducted concurrent with the MRRC review. The PORC Chairman will affirm PORC i
approval by signing the 100% power approval checklist.
G SENIOR TVA M ANAGEMENT - The Site Vice President shall review with the Vice President,' Nuclear Operations and President, Generating Group the collective results of site performance assessment conducted during the unit startup and power ascension and the basis for continued safe and reliable full power operation of the associated unit within established .
site processes. After receiving concurrence with this assessment from the Vice President, l Nuclear Operations and President, Generating Group, the Site Vice President shall sign the '
100% power approval checklist indicating this concurrence.
i 161 ,
6 b
t 6
i
~ C.4. NUCLEAR REGULATORY COMMISSION (NRC) - The Site Vice President shall i ensure that any NRC concerns regarding continued full power operation have been addressed and that the NRC Regional Administrator has been notified of TVA approval for continued ,
full power operation and transition to normal site processes for the associated unit.
The Site VP shall indicate this notification by signing the 100% power approval checklist. ;
3 fl PLANT MANAGER - The Plant Manager will verify completion of the 100% power i
approval checklist before providing approval in GOI-5 to release the unit for continued full i
power operation within normal site processes. The Plant Manager will affirm completion and readiness by signing the 100% power approval checklist.
- I l
t i
i 8
s f
1 i
I i
1 162
ATT.11-1 STARTUP AND POWER ASCENSION REVIEW AND APPROVAL MATRIX i Modei Mode 2 :30%? 65%L ;90%' 100%'
ASSESSMENT HOLDPOINTS 5 3 Power. Power Power' Pciwer A. PLANT EQUIPMENT ;
OUTAGE PHYSICAL WORK COMPLETION Outage scope (for mode / power level) C C C C C C New WRs R R R R R R SYSTEM READINESS System Readiness Affirmation (for Mode) C C System Performance R R R R R R OPERATIONS READINESS System Alignmeras (for mode / power level) C R R R R R GO Requirements R R R R R R Housekeeping and Material Condition R Chemistry Parameters R R R R R R l
C. DEPARTMENT AND PERSONNEL-DEPARTMENT READINESS Department Readiness Affirmations R C AUGMENTED OVERSIGHT (Personnel / Processes)
Plant Management R R R R R R Nuclear Assurance (NA) R R R R R R C. OVERALL READINESS A A A A A A MRRC/PORC R A R R R R SR. TVA MANAGEMENT R A R R R R NRC A A A A A A PLANT MANAGER
' Mode 5 prior to entering Mode 4.
2 Mode 3 prior to pulhng control rods to achieve criticahty.
C - COMPLETE R - REVIEW A - APPROVAL 163
m ASSESSMENT HOLD POINT APPROVAL CHECKLIST POSITION SIGNATURE DATE ITEM A PLANT EQUIPMENT :
A.1 OUTAGE SCOPE COMPLETE / SCHEDULE ATTACHED OUTAGE MANAGER A.2 NEW WRs REVIEWED WCG SRO A3 SYSTEM READINESS AFFIRMED TECHNICAL SUPPORT MANAGER A.4 SYSTEM PERFORMANCE ACCEPTABLE TECHNICAL SUPPORT / OPS MANAGER A.5 SYSTEM ALIGNMLNTS COMPLETE OPERATIONS SUPERINTENDENT A.6 GO REQUIREMENTS SATISFIED OPERKt IONS SUPERINTENDENT A.7 HOUSEKEEPING & MATERIEL CONDITION ACCEPTABLE PLANT MANAGER A.8 CHEMISTRY PARAMETERS ACCEPTABLE RADCON & CHEMISTRY MANAGER DJ DEPARTMENT BEADINESS B.1 DEPARTMENT READINESS AFFIRMED SITE VICE PRESIDENT B.2 PLANT MANAGEMENT OVERSIGHT REVIEWED 03 PLANT MANAGER B.3 NA OVERSIGHT REVIEWED StTE OUAllTY MANAGER C. OVElW.L HEADINESS; ,
C.1 MRRC APPROVAL MRRC CHAIRMAN C.2 PORC APPROVAL PORC CHAIRMAN C.3 SR. TVA MANAGEMENT REVIEW SITE VICE PRESIDENT C.4 NRC REVIEW & NOTIFICATION SITE VICE PRESIDENT C.5 PLANT MANAGER APPROVAL PLANT MANAGER (1) Review plant management oversight team assessment checklist (Att.11-4).
T N M -
I R
OO PF DN _
HT A TU .
NN EI T MN S Ofo S _
E C -
ST -
C S -
L _
A V .
O _
R .
P P -
A _
4 E
T A
D sL A
m N
M -
E T
I
i ATTACHMENT 11-4 ,
Sheet 1 of 2 ,
l PLANT MANAGEMENT OVERSIGHT TEAM ASSESSMENT CHECKLIST
_ ASSESSMENT HOLD POINT y Satsiactory' aital5 Date veswo .
OPERATIONS
- COMMAND AND CONTROL
- COMMUNICATIONS f i
-FORMALITY
-EFFECTIVENESS
- COGNIZANCE OF PLANT STATUS ,
- RESPONSETO ANNUNCIATORS / ALARMS i
- LOGKEEPING & TURNOVER i
- CONDUCT OF ROUNDS
- PROCEDURAL ADHERENCE
- MONITORING OF EQUIPMENT PERFORMANCE SITE PERSONNEL / PROCESSES
- CONTROL OF WORK
-COORDINATION & COMMUNICATION
-PLANNING AND SCHEDULING
-CONDUCT OF WORK
- PROCEDURE ADHERENCE
- ORGANIZATION COMMUNICATION AND COOPERATION
- PROCEDURE AND WORK DOCUMENT ADEQUACY
- S.T.A.R. UTILIZATION
= OPERATIONS SUPPORT 2 For any *NO", provide additional detail under " issues
- Art.11-4 sheet 2 of 2.
166
ATTACMMENT 11-4 :
Sheet 2 Of 2 ' ;
t PLANT MANAGEMENT OVERSIGHT TEAM ASSESSMENT CHECKLIST ASSESSMENT HOLD POINT .
i
SUMMARY
OF OVERSIGHT ACTMTY CONDUCTED (Support documentation may be attached as needed):
6 i
6 ISSUES: ,
i t
i r
CONCLUSION: _
i 1
l
} TEAM MEMBERS: ,
SIGNATURE DATE l
l 167
)
1
,