ML20064N456

South Tx Project Electric Generating Station Operational Readiness Plan Unit 2

ML20064N456
Person / Time
Site:	South Texas
Issue date:	03/21/1994
From:	HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20064N454	List: ML20064N456 ST-HL-AE-4741, Forwards South Tx Project Electric Generating Station Operational Readiness Plan Unit 2. Plan Is Refinement of Process Utilized for Unit 1
References
PROC-940321, NUDOCS 9403290325
Download: ML20064N456 (19)

Text

- _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - . _ _ - - _

s SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION HL&P OPERATIONAL READINESS PLAN UNIT 2 A&BL OY bf s-

{

t

-t \.

I$$

l?ll 's "'i g

\ s

[M fl '% .

Excellence Through I

SERV!CE,IEAMWORK, PRIDE M 1112 PRE hh kohhkOh0098 PDR p  ;,

l

\

South Texas Project Electric Generating Station OPERATIONAL READINESS PLAN Unit 2 Table of Contents

1. Introduction and Purpose . . . . . . . . . 1

11. Material Conditio'n and Workload Management . . . ... 2 A. Maintenance Workload Management . .. . . . . . . 2 General . .. . ... . . . ... . . . 2 Performance Measures Used to Monitor Maintenance Effectiveness . . 3 - - - .

B. Equipment Status and Material Condition . . 3 Turbine-Driven Auxiliary Feedwater Pump . . .. . 3 Essential Chillers . . . . . 4 l l

Standby Diesel Generators . . ... ... 5 i Tornado Dampers . . . . .. 5 l l Feedwater Isolation Bypass Valves . . . . . 5 l Surveillance Flow Instruments . . . . . 6

Components on Increased Test Frequency . . . .. . 6 Fire Protection Computers and Hardware . . . . . . 7 111. System Certification Program . . 7 IV. Operations Staffing . . ... 8 A. Staffing Initiatives . . . . 8 B. Reduction in Administrative Burden . . , ... 8 C. Operator Training . . . . . . 9 V. Specific Program Enhancements . . . 9 A. Station Problem Reporting . .. . .. ... 10 B. Configuration Management . . . 11 VI. Self-Assessment . . . . . . . . .. 11 Vil. Integrated Schedule for Resumption of Power Operation .. ... ... . 13 VIII. Summary . . . .. . 14 Figures Figure 1 - Unit 2 Power Ascension Schedule Figure 2 - Unit 2 Power Ascension Organization Figure 3 - Confirmatory Action Letter Issues Appendix Operational Readiness Plan Action Summary n ,. a. m , .

1 i l -.

South Texas Project Electric Generating Station OPERATIONAL READINESS PLAN Unit 2 1

L Introduction and Purpose t

South Texas Project (STP) Units 1 & 2 were removed from . service by llouston Lighting & Power (11L&P) in February 1993, because of continuing problems with the Turbine-Driven Auxiliary Feedwater Pumps. IIL&P committed not to resume power operation until the problems had been corrected. On February 5,1993, the Nuclear Regulatory Commission (NRC) acknowledged this commitment by issuing a CoaGrmatory Action Letter. Subsequently in April 1993, STP was the subject of a NRC Diagnostic Evaluation, and supplements to the ConHrmatory Action Letter added a number of other items to be addressed prior to startup. To support resumption of power operation and to fully address issues identined by station personnel and the NRC, STP developed an Operational Readiness Plan (Revision 0) describing the actions llL&P would take to improve STP hardware, programs, and personnel performance prior to the resumption of safe and reliable power operation. These actions addressed issues described in the NRC's Confirmatory Action Letter of February 5,1993; the ConGrmatory Action Letter Supplement, dated Afay 7,1993; the second supplement to the ConGrmatory Action Letter dated October 15,1993; selected items from the NRC Diagnostic Evaluation Report of June 10, 1993; and assessments and reviews conducted by STP management. The actions included significant reductions in maintenance and engineering backlogs, major improvements in maintenance training and work processes, increased operations staffing, and reduction of burdens on plant operators. These actions were completed prior to the resumption of power operation of Unit 1.

As part ofits preparation for resumption of power operation of Unit 1, IIL&P conducted an extensive set of management evaluations, independent assessments, and augmented tests to ensure that personnel, hardware, and processes were well prepared. As provided in Revision 0 to the Operational Readiness Plan, these evaluations, tests and assessments addressed the specific items included in the ConGrmatory Action Letter and its supplements, as well as the overall readiness of STP for startup and sustained successful operation. During these assessments and evaluations, areas where performance could be further improved were noted and follow-up action taken. Additionally, action has been taken to address issues identined by the NRC during their extensive series of inspections and reviews.

The results of these evaluations and follow-up actions substantiated that STP was ready to commence the approach to full power operation of Unit 1. Subsequently, the NRC authorized the resumption of power operation for Unit 1 on February 15,1994.

! k 'k b f4 %

This Operational Readiness Plan provides for a systematic and conservative approach to support the resumption of power operation of Unit 2. This plan addresses the specific issues for Unit 2 and any aspects of remaining programmatic issues which need to be resolved to support returning Unit 2 to service. SpeciGeally, this Plan describes:

1) the processes by which readiness for resumption of power operation of Unit 2 will be assessed;

2) the methods that will be used during startup and power ascension to return Unit 2 to service safely and reliably;

3) the initiatives underway to continue improvement of facility material condition, workload management, system certification, operations stafGng and readiness assessment.

The experience gained from the activities, management evaluations, independent assessments and augmented tests which supported the return of Unit I to power operation have been factored into this plan for Unit 2. An assessment for Unit I will be conducted after 10 days of full power operation.

Results and recommendations from the critiques of both the Line Management Assessment Plan and the Independent Assessment Plan described in Revision 0 to the Operational Readiness Plan will be factored into the startup plan for Unit 2.

The activities covered by the Unit 2 Operational Readiness Plan have been developed and will be implemented in conjunction with the STP Ilusiness Plan, which is the overall plan for long-term safe, reliable, and efGeient operation of the Station. A number of improvement initiatives that will continue beyond time of the resumption of Unit 2 power operations are being addressed through the Ilusiness Plan.

STP management will be deliberate and conservative in implementing this Operational Readiness Plan and will not return Unit 2 to service until it is satisGed that the unit can be returned to power and operated safely and reliably over the long-term and without adverse effect on the operation of Unit 1.

A number oflessons will likely be learned as Unit I conducts power operation. These lessons will be used to develop further speciGc criteria and procedures for returning Unit 2 to service. The NRC will be kept informed of progress in the development of any other procedures and the implementation of this revised plan through regularly scheduled status meetings and, as appropriate, through the Senior Resident Inspector's OfGce.

II. Material Condition and Workload Management A. Maintenance Workload Management

1. General The work process is focused through the Operations Work Control Group (OWCG) to provide an effective allocation of resources and focus to optimize safe and reliable unit operations. Work progress is reported to management through Unit 2 Outage Weekly Status Reports and the Unit 2 Plan of the Day Report.

mv nmamam ,

x..

The service request backlog for Unit 2 has steadily improved since October 1993 as resources were transferred from Unit 1 to._ Unit 2. This was accomplished while-encouraging identification of equipment problems to ensure continuous plant material condition improvements. Emphasis on workload management is being stressed for both units while Unit I resumes power operation.

2. Performance Measures Used to Monitor Maintenance Effectiveness for Unit 2.

Performance statistics for Maintenance are reviewed weekly by the Vice President, Nuclear Generation and his staff. Performance indicators have been designed to enable the assessment of Maintenance effectiveness and overall' plant material condition.

Indicators used to monitor station material condition are:

Inoperable automatic fimctions. (Goal: none that adversely affect Operi.tions abihty to perform quality rounds and handle normal work load) .

Main Control Board deficiencies. (Goal: No outstanding deficiencies that adversely effect Operations ability to effectively monitor plant conditions at cach mode; with a goal of < 10 at the full power assessment plateau.)

Preventive Maintenance (PM) deferral rate. (Goal: achieve and maintain an on-line PM deferral rate of < 5%)

Total open Service Requests (SR). (Goal: No SRs that affect unit ' safety or reliability. Open SRs will be reviewed for operability and long-term affect on material condition. Trend will be analyzed to demonstrate ability to manage maintenance workload. A desired target is to reduce and maintain each unit total open SRs to <1000 power production system preventive and corrective SRs)

Service Request generation rate. (Changes in SR generation rate are evaluated and understood to ensure threshold for deficiency identification is acceptable and the generation rate is consistent with plant condition) '

B. Equipmen: Status and Material Condition The following equipment ano material condition issues will be addressed for Unit 2 to resolve Unit 2 specific Confirmatory Action Letter restart issues.

q

1. Turbine-Driven Auxiliary Feedwater Pump

. The. material deficiencies that caused the overspeed trip condition 'of the turbine-driven auxiliary feedwater pumps have been corrected. Actions taken to prevent recurrence of the root causes include improvements in maintenance and the work control process, the corrective action process, and the post-

!- maintenance testing program.

l-HWFuMoudroRP lil '3 1

The preventive maintenance work instructions for both Units have been revised to provide specific steps for disassembly, inspection, and reassembly of the governor valves. A complete turbine-driven auxiliary feedwater pump has been procured and refurbished for use at the maintenance training laboratory to provide more effective training of maintenance personnel.

Measures to correct the overspeed trip condition included the refurbishment and modification of the trip throttle valves, refurbishment of the governor valves, optimization of governor setup and operation, enhancement of the system's drainage capability, and removal of defective steam traps from the drain systems. These actions were initially demonstrated to be effective during previous testing in Unit 2 and confirmed during recent Unit I testing.

Upon resumption of power operation, the turbine-driven auxiliary feedwater .

pumps will be subjected to an augmented surveillance program that will confirm the reliability of the equipment. This program includes a normal surveillance run every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the first three weeks after initial operability, weekly for the next four weeks, bi-weekly for the next six weeks, then monthly in accordance with Technical Specification requirements thereafter.

Furthermore, the turbine-driven auxiliary feedwater pump surveillance test -

procedure has been revised to include a new requirement to perform the test with the pump in an extended standby (cold start) condition. If the pump is tested in any other condition, the test must be repeated in an extended standby condition.

l This issue is considered resolved for Unit 2.

2. Essential Chillers Modifications will be made to correct the specific matcrial deficiencies of the essential chillers in Unit 2 similar to the modifications taken in Unit 1.

In order to assure the ability of the chilled water system to function for extended periods of time during a design basis accident under low heat load (cold weather) conditions, manual bypass valves were installed around the essential cooling water outlet valves for precise control of essential cooling water flow through the chiller condensers. A single prepositioned bypacs valve setting will accommodate various load and temperature conditions and climinate the need for additional operator action down to a 42 F essential cooling water supply temperature. Below 42 F, which occurs infrequently, the bypass valves will be monitored to assure chiller condenser pressure is appropriately maintained.

The chiller vendor is currently conducting a chiller training program for appropriate personnel and a dedicated chiller maintenance group has been established.

ll N rnudh nucWORP RI 4

The post modification test in Unit I validated the analysis and the assumptions in the calculation for cold weather operation for both units. This issue is considered resolved for Unit 2 pending completion of' modiGcations to the essential chiller in Train-13 for Unit 2.

3. Standby Diesel Generators The standby diesel generators in Unit 2 will be subject to the same improvements and enhancernents as the standby diesel generators in Unit 1. Testing similar to the augmented testing in Unit I will be conducted in Unit 2. Additionally, the standby diesel generators are undergoing a System Certification program similar to the one utilized in Unit 1. The results of that program as well as the results of other on-going reliability improvement efforts will be made available to Region IV through the Senior Resident Inspector's office.

4. Tornado Dampers The records of damper testing were reviewed. All of the tests required by the tornado damper purchase specification were conducted. Periodic preventive maintenance procedures have been revised to include manually stroking the dampers and are currently being revised to require recording values for damper spring tension for trending analysis of tornado damper performance. This revision will be completed prior to the next performance of the preventive maintenance requirement. The Severe Weather Guidelines were revised to require that following a tornado strike in the Protected Area, speciSc heating, ventilating and air conditioning system fans be secured to ensure that all tornado dampers can return to their normally open position, and that all tornado dampers be inspected and stroked in accordance with the preventive maintenance procedures. The tornado dampers will function as designed.

This issue is considered resolved.

5. Feedwater Isolation 13ypass Valves The same modification utilized in Unit I will be utilized in Unit 2 to prevent reverse flow through the valves. The valve plug will be modified to accommodate the '

decreased stroke requirement and the unbalanced valve trim will be replaced with a '

pressure-balanced trim. Vendor testing and experience in Unit I confirmed that the new valve design would prevent reverse flow when subjected to design pressure differentials.

The concerns regarding the qualification of the feedwater isolation bypass valve positioners and solenoids have been resolved. The positioner piping has been rerouted so the positioner no longer performs a safety function.

u wnm+ on n 5

9 Stroke testing and reverse differential pressure testing were completed on all four Unit I feedwater isolation bypass valves prior to ascension to Mode 2. The feedwater isolation bypass valves for Unit 2 will be similarly tested.

This issue is considered resolved pending the successful completion of the testing a l

noted above.

6. Surveillance Flow Instruments A contributing factor to the burden of surveillance testing on Plant Operations was the classification ofinstrumentation for certain systems to support ASME Section XI testing. To help address this situation, a plant modification for permanent Row instrumentation in the Unit 2 Auxiliary Feedwater system has been installed and will be tested in Mode 3. In addition, permanent differential pressure gages on the Residual IIcat Removal Pumps have been installed and will be tested in Mode 4.

Similar modifications were successfully installed and tested in Unit 1. In addition, precision calibrations will be performed on the installed Row instruments in the Component Cooling Water lleat Exchanger outlet to the Essential Cooling Water system to preclude the use of temporary flow instruments.

Design changes have been initiated to climinate the use of temporary flow instruments or temporary pressure gages in the surveillance tests for the following systems:

Essential Chilled Water, liigh licad Safety injection, Spent Fuel Pool Cooling, and Screen Wash Booster Pumps. These changes will reduce the surveiiiance burden previously experienced by Plant Operations.

7. Components on increased Test Frequency Efforts have been made to reduce the burden of surveillance testing on Operations and Maintenance and the wear and tear on components caused by the number of components included in the ASME Section XI test program that are on increased testing frequency. Many of these components were on an increased test frequency because they either exceeded the trending limits due to stroke times or because the ability to achieve repeatable test results was hampered by the available system design and instrumentation. No apparent physical deficiency existed with these components.

Actions have been taken to reduce the number of components on increased test frequency by revising procedures to improve test consistency, by establishing guidelines for removing components from increased test frequency, and by installing pennanent instrumentation in various systems used for Inservice Tests. Since June 1993, the total number of components has been reduced by approximately 23 items.

The total station items that are on an increased test frequency has been reduced to less than 15 items. The number of components on increased testing frequency is tracked and reported to management on a weekly basis. Prior to resumption of Unit 2 power operation, management will review the number of components on increased testing frequency to ensure that the burden on Operations and Maintenance relating to the testing of these components will not adversely affect the safe operation of the plant.

n *rmaeme $u 6

8. Fire Protection Computers and Hardware The fire protection data acquisition computer alarm descriptions for Unit 2 will be -

upgraded so that the CRT display includes the alann type, Dre preplan number, the -  !

instrument / zone identincation, and a brief description. - Additional information on the printed hard copy will include the Gre preplan title and/or the alarming device l location. There are three corrective action Service Requests for the Fire Detection -

System remaining to be worked off. All fire protection alarms are trended in order to identify' repetitious alarms that indicate other components contributing to nuisance '

alarms. The number of nuisance alarms has subsequently been reduced.

Fire protection Service Requests have received significant attention and the backlog i L has been reduced to normal emergent work rates. The Business Plan addresses long- l term improvements to the Gre protection computers and fire detection systems.

1 Ill. System Certification Program l The System Certification Program for Unit 2 is based on the experience gained from the Unit 1 l l System CertiGeation Program. i System certification is _a program designed to provide additional assurance to management that performance of critical systems will be enhanced. The selection methodology for including systems or portions of systems in the certification process is based on criteria established by plant staff and engineering personnel. The important elements of the criteria included the use of probabilistic risk assessment tools, the use of a failure modes analysis on systems that could cause plant transients, and defining those systems with known past performance deDelencies.

The System Certi0 cation Program is contrelled and documented by two procedures. :One requires a comprehensive package that demonstrates.that each selected system or subsystem has been '

adequately reviewed and that any outstanding items have been appropriately evaluated and dispositioned. A second procedure requires a comprehensive walkdown followed by the acceptance.

of the system by the Plant Manager. Deferred work items will be reviewed and approved by the Plant Manager.

Feedback from system operating experience gained during startup and power ascension testing for -

Unit I will be used to redirect any necessary Engineering or Maintenance actions to resolve system performance deGeiencies or execute other corrective measures for ensuring Unit 2 system readiness! o Augmented testing of equipment in Unit 2 will be based on the results of reviews of testing equipment in Unit 1.

l

)

l n %. mum in 7 u., , - , , , , , , ,, . .

.. .. . . . .. .. . . . . .......)

9 IV. Operations Staffing STp is committed to providing an environment that supports the safe and efGeient operation of its nuclear units and to this end has taken several actions to reduce the burden placed on the Operations staff. The more signincant are:

A. StafGng initiatives i One of the keys to successful operation of STP is to have alert, responsive, well supported,

and well trained personnel. This means that there should be sufGeient personnel to maintain l individual workloads at a reasonable level while on shift without the need of routine overtime, and to allow for continued, uninterrupted training of Operations personnel.

To achieve this initiative, a six crew operating schedule has been implemented for Unit 2.

Each crew consists of Gye licensed and five non-licensed operators. This is an addition of one non-licensed operator per crew. To support this goal, License Class #6 was completed in October 1993 and yielded four new reactor operators and seven new senior reactor operators.

License Class #7 is in progress with 19 senior reactor operator candidates and nine reactor operator candidates. The NRC examination for License Class #7 will occur in October 1994.

Other stafGng increases include an additional twenty experienced non-licensed operators (ten per Unit) who have been trained and qualiGed. Seventeen more have entered the non-licensed operator training course. in addition, experienced operations support contract personnel are being retained to provide support. To assure continued strong operations stafGng, the Business Plan includes initiatives that address optimum stafGng levels, deGne and establish an " operator pipeline," and establish interdepartmental rotation opportunities for Operations personnel.

IL Reduction in Administrative Burden STP is committed to assure that administrative duties on the shift crews do not dilute their .

ability to monitor the operation of the reactor and power generation system and support systems, Of particular concern is distraction of the Shift Supervisors from their primary duty of maintaining an overview to allow proper coordination of activities. To alleviate these burdens the following actions have been taken:

1. The Operations Work Control Group has been established and has signiGeantly reduced the burden on the control room staff by assuming the majority of work process functions assigned to Operations.

2. A Management Senior Reactor Operator Certincation course has been developed to provide personnel from other departments with a better understanding of the operation of the plant and the challenges faced by Operations personnel so they are better able to support Operations personnel. The first class is scheduled for completion during April 1994 and the second class is scheduled to start in May 1994.

n %% mnn g

3. To enhance operational emphasis on safety-related and power block systems and to further reduce the burden on the operators, the responsibility for non safety-related support systems outside the protected area has been transferred to the Technical Services Department. Also, personnel from the Technical Services Department have been quali0ed as Fire Brigade Leaders to reduce the dependence on plant operators to fill this responsibility.

( In addition, prior to the resumption of power operation of Unit 2, a review will be i made of the temporary modifications installed in Unit 2 systems to ensure that the existing temporary modifications do not degrade operator effectiveness.

C. Operator Training To assure operator proGeiency after an extended outage, each crew of Unit 2 operators will receive specine training which, as a minimum, will consist of:

1. Practice the transition from Mode 5 to hlode 3, including abnormal and emergency procedures.

2. Simulator performance of a reactor startup and a plant startup from Mode 3 to turbine roll.

3. Training on modification and design changes to Unit 2 made during the outage.

4. Specific training on steam generator tube leaks and tube ruptures.

5. Training on lessons learned during Unit l's ascension to power operation.

V. SpeciGe Program Enhancements Many of the programmatic improvements which were made to support Unit 1, were implemented generically, and therefore were resolved on a Station Basis. Programmatic issues that are considered to be resolved in this manner include: Post-Maintenance Testing Program, Management of the Engineering Backlog, Fire Brigade Team Leader Training, and Emergency Preparedness.

The STP Management Team is dedicated to continuing to provide the proper environment for the raisine ad addressing of employee concerns. The Employee Concerns Program has been established to asp inat all spes of employee concerns are effectively addressed. An action plan has been implemented to enhance the program. Internal and external assessments have been scheduled to verify the effectiveness of the actions that have been taken.

Programmatic issues that continue to require close management attention are the Station Problem Reporting process and Con 0guration Management process. Enhancements to these processes are discussed below.

o y,m., u m m m e n 9

A. Station Problem iteporting The corrective action procedure has been revised to more clearly establish line management ownership of station problem report investigations and individual responsibility for the subsequent corrective actions. All Station Problem fleports are required to be hand-carried to the shift supervisor for an initial operability, reportability and mode restraint review after initiation. An operability review process has been incorporated into the Station Problem lleport procedure. This process, based on guidance provided in Generic Letter 91-18, will help assure a uniform, consistent approach to resolving emergent operability issues. A multi-discipline, peer-level screening group reviews Station Problem Reports on a daily basis to reconunend event significance category and identify any operability, reportability, or operational holds.

A Problem lleview Group has been developed, consisting of the Plant Managers and line managers from Operations, Engineering, Maintenance, Work Control, Nuclear Assurance, Licensing, and the Corrective Action Group. The Problem Review Group typically meets four times a week to assign the significance category and responsibility for each problem report, and to ensure that appropriate resources are applied to the investigation. This process increases problem report visibility, management's awareness of plant problems, and facilitates problem resolution by increasing departmental accountability and ownership.

The Station Problem lleport database has been modified to include a " plant mode restraint" field to ensure that actions affecting operability and subsequent corrective actions are performed prior to the appropriate mode entry.

i A Corrective Action Initiative Team developed a plan of action for continued enhancement of the corrective action process to ensure adequate and effective problem identification, trending, and root cause analysis, as well as corrective action identification, selection, implementation, and monitoring for timeliness and effectiveness.

Two 13usiness Plan Initiatives have also been established for problem identification training and to foster a culture that promotes continual self-assessment and problem correction by the line organizations. A desired result is that Station personnel will routinely identify and solve problems and participate in self-assessments.

n , mau.. n,u " 10

As a result of mternal reviews and the NRC Operational Readiness Assessment Team observations, othc r improvement initiatives have been initiated:

l .

The categorization of SPRs is being closely monitored by Quality Assurance to ensure l that root cause evaluations are performed for all significant events.

Selected SPRs will be provided to the Problem Review Group for closure review to increase management confidci..e that investigations and corrective actions are focused on the substantive issues and ensure that programmatic weaknesses do not recur.

l The problem report process will be periodically reviewed for effectiveness as part of the routine line management assessments, departmental self-assessments, and performance-based l cvaluations by independent assessment organizations. Specific performance indicators have been established to monitor the corrective action process and graphs of the performance indicators are provided weekly to senior management.

B. Configuration hianagement Independent assessments noted weaknesses in programs for ensuring conGguration management which resulted in unexpected equipment actuations and clearance order deficiencies. In order to address this issue, STP has implemented a Configuration Management Action Plan to identify and implement corrective actions to prevent configuration management deviations during Unit 1 operation 9nd during the startup and power ascension of Unit 2 and subsequent operation.

The Configuration Management Action Plan establishes a standard that unanticipated actuations or other unexpected occurrences are unacceptable. Station expectations on individual procedure usage and adherence will be reinforced through peranal supervisory contact in the workplace. An independent review will be conducted for the effectiveness of recent changes in the Equipment Clearance Order process. Initiatives to improve the Corrective Action process are described in the preceding section of this Operational Readiness Plan. In addition, performance standards for work practices are being reinforced for both workers and supervisors.

VI. Self-Assessment The self-assessment process for Unit 2 will evaluate and determine the acceptability of continued operation at specific milestones including: prior to Mode 4; prior to criticality; power ascension above 50 percent power; completion of ten days of full power operation, and as determined necessary thereafter. The process will include involvement of line and senior management, independent assessment groups { Nuclear Assurance (NA), Independent Safety Engineering Group (ISEG), Plant Operation Review Committee (PORC), Nuclear Safety Resiew Board (NSRB), Planning, Assessment & Controls, Operational Readiness Review Panel (01RP)], outside consultants, and industry gmups such as INPO, as determined by STP managemen: Management effectiveness in identifying. pursuing and correcting plant prob! cms will be a part of the self-assessment progress.

n u. mummmi jj

In order to assure a consistent and integrated approach to the internal assessment process, a Line Management Assessment Plan will be prepared by line management and approved by the Group Vice President, Nuclear prior to core reload. Conceptually, the plan will consist of the following elements:

Line managers with assessment responsibilities associated with resumption of powet operation deUned.

Assessment poin(s or plateaus from Mode 4 to full reactor power.

l Line managers will prepare self-assessment checklists / plans for their functional area for each of the assessment milestones. These checklist / plans will address the hardware, program and performance issues described in this revision to the Operational Readiness Plan, including issues developed based on the lessons learned from Unit l's ascension to power operation.

The checklists will both review performance to date and readiness to proceed to the next plateau.

Prior to advancing beyond any assessment milestone, the checklists for that plateau will be completed and reviewed. The PORC will review the checklists for those functions that directly report to the Plant Manager's organization. The ORRP will review the results of the PORC review and checklists from functions that are outside the Plant Manager's organization.

Collectively, the Plant Manager and ORRP will report to the Vice President, Nuclear Generation on performance to-date and readiness to proceed to the next plateau.

The Vice President, Nuclear Generation will recommend and the Group Vice President, Nuclear will approve proceeding to the next plateau.

After reaching full power, an overall critique of the process will be conducted by the Vice President, Nuclear Generation. Lessons learned and recommendations from that critique will be factored into the STP Business Planning process, as appropriate, in order to assure sustained focus on long-term improvements.

In addition to the Line Management Assessment Plan, an Independent Assessment Plan will also be '

prepared and approved prior to core reload. This Independent Assessment Plan will be developed based on the lessons learned from Unit l's ascension to power operation. Conceptually, this plan will address the following:

An integrated surveillance / observation plan for internal assessment groups. This process will be managed and coordinated by the General Manager, Nuclear Assurance.

A review of the Line Management Assessment Process at each assessment plateau. The plan will contain speciGe criteria for the assessment of the process. The General Manager, Nuclear Assurance will give the Group Vice President, Nuclear an independent opinion on readiness to proceed to the next plateau as an input on each plateau decision.

n w - % m w ai 12

p

- Prior to criticality, the independent members of the NSRIl will conduct a review of the decision / assessment process to date and provide that input to the General Manager, Nuclear Assurance.

After reaching full power, the General Manager, Nuclear Assurance will conduct a critique of the lessons learned from the independent assessment process and recommendations on long-term improvements will be factored into the STP Ilusiness Planning process.

g Finally, a Third-Party Review to assess STP's readiness to resume power operation of Unit 2 'will be 1 conducted. The Third-Party Review will be an independent team that will consist of senior consultants with extensive nuclear and managerial experience.

VII. Integrated Schedule for Resumption of Power Operation A critical path schedule is being used to manage the activities to resume power operation of Unit 2.

This schedule addresses current outage activities, core reload, and the ascension from Mode 4 to full power operation. This schedule displays signi0 cant outage activities, surveillances, applicable test l activities and major equipment manipulations, appropriate readiness assessments, management

!' evaluation periods and decision points. A Unit 2 Power Ascension milestone schedule is provided as Figure 1. Specific detailed schedules to support these milestones are developed. Periodic updates of these schedules will be made available to the NRC.

Maintenance activities are focused through the Operations Work Control Group (OWCG) and are included in the Integrated Schedule. This group is headed by a Senior Reactor Opemtor (SRO) and -

is staffed with quali0ed personnel from other functional areas. Outage Support provides 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage to support outage activities and schedule changes. OWCG and Outage Support work closely to resolve work, schedule and resource issues. As a lesson learned froni Udt 1, a line management position of Outage Director, responsible for overall management of outage ectivities and reporting directly to the Plant Manager, has been established. The two incumbents in these positions are the Unit 2 Assistant Operations Manager (SRO) and the Unit 2 Assistant Maintenance Manager (SRO certified).

A Unit 2 Startup and Power Ascension Plan will be developed to establish the administrative guidelines necessary to ensure that tests and evolutions having the potential to impact the plant's margin of safety are conducted with the controls necessary to meet the requirements of the operating ;

license, applicable regulatory requirements and commitments, accepted industry practices, and approved procedures. This plan will provide guidance for tests, inspection activities, and hold points required during the STP Unit 2 startup and power ascension from entry into Mode 4 to full power.

The Unit 2 Power Ascension Plan and management controls will be based on the lessons learned during the implementation of the Unit 1 Power Ascension Test Program.-

Power ascension testing will be coordinated by.a Power Ascension Test Manager. Additionally, a Startup Duty Manager (a Senior STP Manager) will provide continuous management representation and presence during selected evolutions throughout the power ascension program. The Startup Duty Manager's primary function will be to ensure that the exercise of command and control authority of licensed operators is not diluted by the increased level of activities. The Startup Duty Manager will; also be responsible for assessing the conduct of Operations, Maintenance and other support groups, and for assessing the implementation of the Power Ascension Plan.

n w,mmue m 13 l

.l

- _ __ __________-__-___ ____________________-_ _ ___ - - _ _ w

The Shift Supervisor retains responsibility for the safe operation of the plant, including testing. A Shift Test Coordinator will coordinate the testing sequence and will directly report to the Shift Supervisor.

The basic structure of the operating organization during power ascension is shown in Figure 2.

Changes to this organization structure based on lessons learned from Unit I will be communicated to the Senior Resident inspector.

Vill. Summary The programmatic issues identified in the NRC's February 5,1993 Confirmatory Action Letter and its supplements and the Diagnostic Evaluation were addressed prior to the restart of Unit 1. Each issue identified in the Confirmatory Action Letter and its supplements is discussed in the Unit 2 Operational Readiness Plan. Figure 3 provides a reference guide for finding each issue in this plan.

The specific goals for the Unit 2 ascension to power operation are established in this Operational Readiness Plan. The experience gained during Unit l's ascension to power operation are being utilized in preparing Unit 2 for return to service.

This Unit 2 Operational Readiness Plan details specific plans related to (1) material condition and workload management, (2) system certification, (3) operations staffing, and (4) self-assessment. The Power Ascension Plan for Unit 2 will be based on lessons learned from Unit l's ascension to power operation. STP management will utilize a systematic and conservative approach to return Unit 2 to operation and will not return Unit 2 to service until it is satisfied that the unit can be returned to power and operated safely and rehably over the long-term. Further actions to address long-term performance improvement are being pursued through the STP Business Plan.

(

n mpw % nua,coarni ]4 .

t .

+

9 Figures i

UNIT 2 POWER ASCENSION SCHEDULE .

Management Assessment of 100 % - - - -- -- - - -. .

.10 Days of Eull. Power. Operation 90% - - - -- - - ---

60% - - - - - - -- - - - -- -- - -- --- ---- -- ---- - --

Xenon Stabilization 70% -- - --- - - - - --- -

-& Flux-Testing - - - -

60% - - - --- ----- - --- ---- --

l Management Readiness Review 50g -

l 49% - . .. -- ...-. ... . . -. ... . . ... .. ......... ....

Stabilize Power at 30S' 30% - - - - - ----- -- -- -

20% -- - - -- ---- -- - - - '

~ ~~~ ~~

Tu'6'i6d idstin' ~

Breaker Closure 10% - - - --- - -- ----- - - - -- -

-Q --- -------- --

Mode 1 - --- ---- -- - - - - ~ ~ ~ ~~~~ ~~~~'~~ ~

'Ze'ro P~ok/er ~

Mode 2 - - - ------ ---- -- - - -- - - ... ysics. Testing .. ... ..... .. ...... j Mode 3 -- -

--- - ------------ -- - --- -- ---- M W 3?'*I]"* - - -- ---------------

Mode 4 -- - -

Preps for Mode 4 Mode 5 .- - - ------.

Mode 6 -- --- ---Core Reload l----- - ----- ----- -- --- ------ --------------- -

Defueled _.

1- t i  ; i i i  ! i 1 1 mm 3-14 3-21 3-28 . 4-4. . 4-11' 4-18 4 5-2 5-9 5-16 5-23 5-30 6-6 Figure 1

. . _ - - _ -_=__-__--_______--_ _.

UNIT 2 POWER ASCENSION ORGANIZATION -

WCE PRESOENT NUCLEAR CENERATICN U N:T2 PLANT M ANAGER

.1. . ..l.. .l

--* I 2 STARTUP OUTY OUTAGE FOWER ASCCS5;CN wAMENANCE u AN ACED M AN AGER O! RECTOR TEST uANAGER UNIT 2 -

CDEPATIONS MANAGER TEST TEAMS I I M AiNTEN ANCE SHiri OPERATIONS WORK SU"E A viSO R SUPERV150R CONTROL GROUP MAWTENANCE UNIT CREW SUPERvtSOR I

REACTOR '

OPERATORS -

PEACTOR PLANT OPERATORS PEPuANENT PCSlT!ONS START-UP AUCMENTATION FICURE 2 C - II-l'i PV G RE V 0 03/94

.,y

CONFIRMATORY ACTION LETTER ISSUES 1

I ISSUE PAGE I 1 Turbine-driven auxiliary feedwater pump 3&4 I

2 Station problem report process 10 & 11 3 Service request backlog 3 4 Post-maintenance test program 9 5 Engineering backlog 9 6 Operations staffing 8&9 7 Fire brigade leader training 9 l

l 8 Fire protection computers 7 9 Monogement ef fectiveness 11 10 Employee concerns program 9 11 Standby diesel generator reliability 5 12 Essential chiller reliability 4&5 13 System certification program 7 14 feedwater isolation bypass volves 5&6 15 Tornado dampers 5 16 Emergency preparedness 9 l

1 ricunt 3 l

l C -06 7 7 DVG FEV O '

03/94

~ , 1 k

Operational Readiness Plan Action Summary n

_.___.__1__.___ _ _

(

i OPERATIONAL READINESS PLAN ACTION

SUMMARY

I. INTRODUCTION AND PURPOSE l

1. l Resutts and recommendations from the critques of both the Line Management Assessment Plan and the independent Assessment P!an descr1>ed in Revision 0 to March 1994 the ORP wil! be factored into the startup plan for Und 2. {

I 2 The activtes covered by the Operabonal Readcness Pian will be implemented in conjunction with the Business Plan Ongoing 3.

STP managemer't will be deliberate and conservative in implemenhng this revision to the Operational Readiness Plan and will not retum Unit 2 to service unti it is Ongoing  !

satisfied that the unit can be retumed to power and cperated safely and reliably over the long-term and without adverse aNect en the operation of Unit 1.

4.

Lessons feamed as Und 1 conducts power operation will be used to develop further specific cnteria and procedures for retuming Unit 2 to service. Ongoing The NRC wdl be kept informed of progress in the development of any other procedures and the implementation of this revised plan through regt larly scheduled Ongoing status meetings and, as appropriate, through the Senior Resident inspectors off.ce.

II. MATERIAL CONDITION AND WORKLOAD MANAGEMENT A. MAINTENANCE WORKLOAD MANAGEMENT

6. Performance indicators have been designed to enable the assessment of Maintenance effectiveness and overalt plant material condition. Indicators used to momter Pncr to resumption station matenal condition are:

of power operations Inoperable automatic functions. (Goat none that adversely a'ffect Operations ability to perform quality rounds and hand-e normal work load)

Main Control Board defciencies. (Goat No outstanding deficiencies that adversely ef'ect Operations ability to effecbvely monitor plant condibons at each mode with a goal of < 10 at the fall power assessment plateau )

l .

Preventive Maintenance (PM) deferral rate. (Goat achieve and maintain an on-line PM deferral rate of < 5%)

Total open Service Requests (SR). (Goat No SRs that a5ect unit safety or reliabi!ity. Open SRs will be reviewed for cperibility and long-term a'fect or: material condibon. Trend will be analyzed to demonstrate abaity to manage maintenance workload A desired target is to reduce and maintain each unit tctat open SRs to <1000 power produchon system preventive and corrective SRs)

Service Request generation rate (Changes in SR generabon rate are eva'uated and understood to ensure threshold for def:ciency identifcation is acceptable and the generation rate is consistent with plant condition) 1

___ _ = _ - . -

' \:

i B. EQUIPMENT STATUS AND MATERIAL CONDITION

7. We TOAFW pumps w:!! be subjec*ed to an augmented survedtance program that wd! ccr: firm the rehabi!ty of the equipment.

Resumpt.cn of power operaten

8. Mod >icatsens to correct the spec 6c material deficences of the essentrai chdiers in Un t 2 wd be mada sMar to the modifications taken in Umt 1. Prior resumpton of power CDerat3CM 9 The standDy desel generators in Unit 2 will be subject to the same improvements and enhancements as tne SDGs in Und 1. Pncr to resumpt:en cf power operaten a

Testing similar to the augmented testing in Unit 1 will be conducted n Unit 2.

- SDGs are undergoing a System Certfication process similar to the one utilized in Unit 1. Results of the process wi'l be made available through the Sr.

Resdent's of' ice.

l

10. Penode preventive matntenance procedures are currentty being revised to require the recording of damper spring tension values for trending tomado camper Prior to next pedonnance. pedonnance.

11. The same moddicat:en utdized in Und 1 feedwater iso!ation bypass vanes win be utilized in Unrt 2 to prevent reveise flow through the vanes. The vafve plug wi!! be Pnor resumpton of modified to acccmodate the decreased stroke requirement and the unbalanced vane trim will be replaced wth a p essure ba anced trim. Strcke testing and reverse power operation d,"erential pressure testing wi!! be completed on a!! four Unit 2 FWIBVs.

i

12. The permanent ficw instrumentation in the AFW system wdi be tested in Mode 3. Prior resumption of pcwer operation

13. The permanent d#erentia! pressure gages on the RHR pumps wi!! be tested in Mode 4. During Mode 4 14 Precision ca:tbrations will be performed on the installed flow instnaments in the component cooling water heat exchanger cutlet to the essential cooling water system Prior restmpton of j to prec!ude having to use temporary flow instruments. power cpeation 15~ Management will revew the number of components on increased survei: lance testing frequency to ensure that the burden on Operations and Main ^enance relating Pnor resumption of to the testing of these components will not adversely a"ect the safe operation of the plant. power cperation

16. The f're protecton data acqursition computer alarm desenptions for Unit 2 will be upgraded so that the CRT display includes the alarm type, fire preplan number, Prior resumption of the instrument / zone identification, and a brief description. Additional informaton on the pnnted hard copy will include the fire preplan titie and/or the alarming power operat on devsce location.

2

x Ill. SYSTEM CERTIFICATION PROGRAM 17 Feedback frem system operat:ng expenence gain *d dunng the startup and power ascension testag for Und 1 wih be used to redirect any necessary Engineering er Ongerng Ma ntenance achons to rese!ve system performance de5cencies or execute other correchve measures for ensuring Unit 2 system readiness 18 Augmented test:ng cf equipment in Und 2 wdl be based on the resu!:s of reviews of testing equipment in Urdt 1. Ongoing IV. OPERATIONS STAFFING 19 The second Management Senor Reactor Operator Certificaban Course is scheduled to start in May 1994. M'Y

• 20 A revew wdl be made of the temporary med6 cations instaMed in Unit 2 systems to ensure that the existmg temporary mod:fications do not degrade operatar Prior to resumption e*ectveness of power cperabon

21. To assure operator proficiency a^er an extended outage, each crew of Unit 2 Operators will receive specdic training which, as a minimum, wig consist of. Prict to power ascension Practice the transition from Mode 5 to Mode 3, including abnormal and emergency procedures.

Simulator performance of a reactor startup and a plant star +.up from Mode 3 to turbine roll.

Training on mod 6 cation and design changes to Unit 2 made during the outage.

SpecMc training on steam generator tube leaks and tube ruptures.

Training on lessons leamed during Unit 1's ascension to power operat;on.

g

t.

V. SPECIFIC PROGRAM ENHANCEMENTS

22. Ongo;ng Se'ected SPRs wii! be provided to the Problem Review Grcup for closure review to increase management confidence that investigations and correct:ve actions are focused on the substantave rssues of the Trend SPR so programmatic weaknesses do not recur.

23 The problem repcrt process wiH be periodicaffy reviewed for efectrveness as part of the routine hne management assessments, departmental self-assessments, and Ongoing performance-based evaluations by independent assessment organizahons.

24 An independent revew ws!! be conducted for the efect:veness of recent changes in the Equipment Clearance Order process. April 1994 VI. SELF ASSESSMENT 25.

The assessment process wd! evaluate and determine the acceptability of continued operation at specific milestones including: prior to Mode 4; prior to cr6ca!ity; Ongoing power ascension above 50% power; completion of 10 days of fu!! power operation; as determined thereafter. The process will include involvement of line and senior management, station assessment groups as determined by STP executive management. Management effectiveness in ident/ying, pursuing, and correcting piant problems wilt be a part of the self-assessement process.

26 in order to assure a consistent and integrated approach to *he intemal assessment process, a Line Management Assessment P!an will be prepared by line Recuired prior to rnanagement and approved by the Group Vce President, Nuclear prior to core re! cad. Conceptually, the plan will consist of the following elements' core reload ,

Une managers wah assessment responsibihtes associated wi*h resumption of operations defined.

Assessment points or ptateaus from Mode 4 to fun reactor power Line managers designated above wdl prepare self-assessment checklists /pfans for their funct2onal area for each of the assessment milestones. These checkhst'ptans will address the hardware, program and performance issues described in this Operations Readiness Plan, including issues developed based on the lessons teamed from Unit 1's ascension to power operation. The checklists will both review performance to date and readiness to proceed to the next '

plateau.

Pnor to advancing beyond any assessment milestone, the checklists for that plateau will be completed and reviewed. The PORC wiil review the checklists for those functions that direct!y report to the Plant Manager's organization. The ORRP wi!! review the results of the PORC review and checklists from functions that are outside the Plant Manager's organization.

Conective'y. the Plant Manager and ORRP witi report to the Vice President, Nuclear Generation on performance to date and readiness to proceed to the next plateau.

- The %ce President, Nuclear Generation will recommend and the Group Mce President. Nuclear will approve proceeding to the next plateau.

After reaching full power an overal critique of the process will be conducted by the Vice President, Nuclear Generation. Lessons learned and recommendations from that crcque wdl be factored into the STP Business PIanning process in order to assure sustained focus on long-term improvements.

4

t

'V

=

27. In aMMn to the bne Management Assessmen! P!an. an Independert Assessment Plan ws! a!so be prepared and approved prior to core reload. Thrs independent Prcr to core reload Assessment Pian wd be developed based cn the lessons teamed from 1)n t Ts ascension to power operatton. Conceptua!!y, thrs p'an wd address the faticweng:

- An miegrated survemance/ observation plan for intemal assessment gmups. This peccess wJt be managed and coordinated by the General Manager, Nuciear Assurance A revew cf the une Management Assessment Process at each assessment plateau. The pian wi!! contain spec 6c critena for it'e assessment of the process.

The General Manager. Nuclear Assurance wm give the Group Vice President, Nuclear an independent epinion on readiness to pmceed to the next p.lateau as an cput on each p!ateau decision.

Prcr to crdicahty, the independent members of the NSRB wd! conduct a revew of the decision / assessment process to date and provide that input to the General Manager. Nuclear Assurance.

Aher reaching full power, the General Manager, Nuclear Assurance will conduct a cntque of the lessons teamed from the independent assessment process and recommendat ons on long-term improvements wdl be factored into the STP Business Planning process.

28. A Third-Par *y Review to assess STP's readiness to resume power operation of Unit 2 w,It be conducted. The Th:rd- Party Revew wd be an independent team that Pnct to Mode 4 weil consist of senior consultants with extensise nuclear and manageriat expenence.

Vll. INTEGRATED SCHEDULE FOR RESUMPTION OF POWER OPERATIONS 29 A moestone schedule and spec 6c detai!ed schedules to support these miles!cnes will periodica!!y be updated and made available to the NRC. Ongerg

30. A Und 2 Startup and Power Ascension Plan will be developed to establish the adminstrative guidelines necessary to ensure that tests and evolutions having the Pnor to Mode 4 potential to impact the plant's margin of safety are conducted with the controts necessary to meet the recuirements of the operating license, applicable regulatory requvements and commiments, accepted industry practces, and approved procedures. The plan wig provide guidance for tests, inspecten activites, and hold points required during the STP Unit 2 startup and power ascension from entry into Mode 4 to fu?! power. The Unit 2 Power Ascension P;an and management contro!s we be based on the lessons teamed during the implementation of the Unit 1 Power Ascension Test Program.

31. Power ascension testing wd be coordinated by Power Ascension Test Manager. Prcr to power ascension

32. A Startup Duty Manager will provide continuous management representation and presence dunng selected evo!utions throughout the power ascension program. Pnct to power The Startup Duty Manager's primary function wi!! be to ensure that the exercise of command and control authon'y of licensed operators is not d!!uted by the ascensien increased level cf actrvities. The Startup Duty Manager wm also be responsible for assessing the conduct of Operations, Maintenance and other support groups, and for assessing the implementat:on of the Power Ascension Plan.

33 A Sh:'t Test Coordinatcr wi:1 coordinate the testing sequence and we report direct!y to the Sh;ft Supervisor As required

34. Changes to the basic structure of the operahng organizaten during power ascension of Unit 2 wm be based on lessons learned from Und 1 and will be communicated to the Senior Resident inspector.

5

.