ML20083M032
| ML20083M032 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/08/1994 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20083L862 | List: |
| References | |
| PROC-941108, NUDOCS 9505190087 | |
| Download: ML20083M032 (74) | |
Text
-- .- . - _ _ - - - -_- - - - - -
.. l l
Nebraska Pub ic Power Distr'ct
.f Nuclear Power Group k
^
M***!qdf? **' ' ' A .....o.......
~.......~,.~
. . . . .. . . . .t T. i . . ; . . . . . i . . 6s i4E;
- - . :i.i. .; . . ; .. ; ;~: . ::; ;;; ;;; ;;;i. ;.;. i!. !. !!. !!. !. !. ;
j ,,,.o*um* , . . .. ;
'i!. E..!.
- m: - 'iiidy ;
i
'm
..! i::: . *." * .
- .
- tiiiiiiii!!i!!!h
- 55
- i;;Z;;i;;.
. . ". . . ~ ! .h .
iiilliijjiijii;
~:: .. i::::. ..--" ;;siiiii; s
3 ;; .g ... .. ! : -
i ' ' " $ ' ' ' ". 'a ;ifNi .
~
i . . .
- 'ii
~~
- .5.4... !.! ;#....!.O
. . . . . . . . .. . ... ... u. .;;1:il. 3 ;;;;;, . .. . .. . . . .
.. .' 5 ~;;;;2i . ... . . .. ;;i.
! . . . . . . ....u.
.::;;;;;.;;;. .iiii ... .;;;;;;iiiii: .. ... .a .. .;.i;;.
. . . ; ; : .. ... ... ... .. i:lsi fi" .. ... . .. ... . . ;;;;;! ..
j
- I * * .::i i:.
. NESTAI T RILAl)I IUS PRO 1R 1
' ( {)
9505190087 950512 PDR ADOCK 05000298 P PDR i
COOPER NUCLEAR STATION RESTART READINESS PROGRAM November 8,1994 (Revision 0) J l l l APPROVED BY: x he // / P- / 9k
~PL MANAGER DATE u ma c?
,.,,/,
SIT $MANMER DATE
INDEX
- l. PURPOSE / DESCRIPTION
- 11. HISTORY 111. DEFINITIONS A. EMERGENT WORK B. INTEGRATED RESTART LIST C.
SUMMARY
RESTART LIST D. OPEN ITEMS E. STARTUPISSUE F. FINAL SYSTEM READINESS REVIEW - G. DEPARTMENT READINESS REVIEW H. LICENSING REGULATORY CLOSURE I. PROGRAM READINESS REVIEW J. SITE READINESS REVIEW K. PERFORMANCE IMPROVEMENT PLAN L. RESPONSIBLE MANAGER M. CRITICAL SYSTEMS LIST N. FOCUS PROGRAM LIST IV. RESPONSIBILITIES A. SITE MANAGER ' B .. PLANT MANAGER C. MANAGEMENT REVIEW COMMITTEE D. RESPONSIBLE MANAGER V. RESTART READINESS PROCESS VI. PHASE I CLOSEOUT Vll. RESTART LIST A. DEVELOPMENT OF RESTART ITEMS LIST
- 1. IDENTIFICATION OF RESTART ITEMS B. DEVELOPMENT OF THE OUTAGE MAINTENANCE SCHEDULE C. CLOSEOUT OF RESTART ITEMS
- 1. .
CLOSEOUT DOCUMENTATION
'M . SELF-ASSESSMENT A. OBJECTIVES
- 1. CONDUCT OF SELF-ASSESSMENTS
- 2. READINESS REVIE'NS IX. QA OVERSIGHT m9
n ..A. >a.-w4- 4 & wn; , _ h
' me INDEX (CONT) ,
i APPENDICES A. PHASE 1 CLOSEOUT B. RESTART READINESS PROCESS FLOW CHART C.
SUMMARY
RESTART LIST D. POTENTIAL RESTART ITEM EVALUATION FORM E. SYSTEM READINESS ASSESSMENT F. DEPARTMENT READINESS ASSESSMENT G. LICENSING READINESS H. PROGRAM READINESS ASSESSMENT
- l. SITE READINESS ASSESSMENT J CROSS REFERENCE OF DSAT FIELD NOTES AND PHASE 1 PLAN f
- K. EMERGENT ISSUES FLOWCHART L. MAINTENANCE WORK REQUEST SCREENING (OUTAGE WDRK ITEMS)
- m. 2
- j i
t-i EERFORMANCE IMPROVEMENT PLAN l _. RESTART READINESS PROGRAM
- l. PURPOSE / DESCRIPTION The purpose of the Restart Readiness Program (RRP) is to document the methodology being used by the Nebraska Public Power District (NPPD) to complete activities necessary to return Cooper Nuclear Station (CNS) to operation following the May 25,1994, forced outage. The Restart Readiness Program addresses how CNS will utilize Restart Lists, Performance lmprovement Plan (PIP) Phase 1 Action items, Diagnostic Self Assessment Team (DSAT) findings, NRC Special Evaluation Team (SET) Inspection findings, NRC Confirmatory Action Letter (CAL) closeouts, and NRC Restart Panel conclusions regarding activities that will provide an_ objective basis for_
restart readiness,. The results of each of fnese efforts are incorporated into final restart readiness determinations, in addition, issues such as plant material condition, miscellaneous hardware deficiencies, and organizational readiness will be assessed and appropriately resolved prior to restart. The Restart Readiness Program provides a transition from Phase 1 PIP activities to implementation of the Power Ascension Plan. Phase 1 involves a planning process for significant issues that must be addressed prir olant startup. Many of these significant issues have been identified in document., such as the Diagnostic Self-Assessment Team inspection, NRC Confirmatory Action Letters, open inspection report items, and management self-identified issues. Phase 1 actions were assigned to individual managers who are responsible for ensuring adequate closeout. NPPD considers all Phase l PIP Action item objectives to be restart issues (see discussions in Section Vil of this document and Appendix C). Some Phase 1 PIP Action items, however, may result in long-term corrective actions that may not be completed prior to restart. These actions will be screened and bases documented for why they do not need to be included on the restart list.
~
Subsequent to restart, Phases 2 and 3 PIPS will be completed. These activities will ensure continued high quality performance. Phase 2 will address ess'ential management actions that wili be completed in the 2-3 month period following plant restart. Phase 3 will address long-term strategic planning, it will provide the framework for managing performance improvement actions that are essential for meeting long-term objectives for safety, production and economics. This phase will involve activities with planning cycles from one to several years. Phase 3 activities are focused on fundamental improvement strategies, and long-term deficiency recurrence control. W 3
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM m
~
ll. HISTORY l The following provides a brief chronology of significant events that are relevant 1 to current restart readinoss activities. These events have contributed to the basis for why certain resiart actions and processes have been deemed necessary and _. appropriate. 5/25/94 Cooper Nuclear Station (CNS) enters a forced outage as a result of - concerns regarding relay operability. 5/26/94 Public meeting at CNS between NPPD and the NRC to discuss integrated Enhancement Plan. 5/27/94 NRC issues Confirmatory Action Letter (Rev. 0) 6/16/94 NRC issues Confirmatory Action Letter (Rev.1) -
~
7/1/94 NRC issues Confirmatory Action Letter (Rev. 2) 7/26/94 Power Ascension Plan, Rev. O issued ~. " 7/25 - 8/19/94 Diagnostic Self-Assessment Team (DSAT) inspection ~ 7/28/94 NPPD Responds to Confirmato,ry Action Letter (Revs. O,1, and 2) ~ 7/29/94 Management Meeting at NRC Headquarters 8/2/94 NRC addendum to Confirmatory Action Letter (Rev. 2) 8/2/94 Power Ascension Plan, Rev.1 issued. 8/12/94 NPPD responds to Confirmatory Action Letter (Rev. 2 addendum) 8/15/94 NRC Special Evaluation Team inspection begins 8/26/94 Performance improvement briefing for NRC 9/1/94 DSAT Report issued 9/15/94 Nuclear Group Startup Plan (Rev.1) 9/16/94 Enforcement Conference on CAL-related issues __ 10/6/94 Phase 1 Plan (Rev. 2) 4
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS _ PROGRAM Ill. DEFINITIONS A. Emeroent Wotk . All new work items that occur after Integrated Restart List issuance; and therefore, have yet to be restart screened and scheduled for completion. i B. Intearated Restart List A detailed list of activities that must be completed prior to restart of CNS. C. Summary Restart list ; A list of restart issues based on Phase 1 Performance improvement Plan objectives. D. Open items items that have the potential to affect components, subsystems, or system operations that must be screened, evaluated, and dispositioned. This dispositioning will result in a determination of whether or not the item is required to be resolved prior to restart. E. Elartuo issue An item assigned to a responsible manager for closecut (prior to plant restart). These issues are maintained on the Summary or Integrated Restart List. F. Final System Readiness Review The process whereby System En ;ineers ensure the readiness of their assigned system by reviewing appropriate docu nents, restart criteria, field walkdowns, and other outstanding engineering / hardware issues. G. Department Readiness Review ' The process whereby Department Managers ensure the readiness of their area of responsibility by reviewing of items such as performance indicators, organization changes, personnel, and self-assessment of performance results. w M S
EERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM H. Licensina Reaulatory Closure Verification by Licensing that all restart actions required by NPPD and the NRC have reasonable documentation and bases. I. Proaram Readiness Review An assessment by department program owners to determine the health and effectiveness of programs owned by that department. The results of this assessment will be incorporated into department readiness affirmations. J. Site Readiness Review A final-stage review by the Management Review Committee (MRC) and other senior District managers for restart readiness which involves integrated assessments of system and department readiness reviews, in addition to restart list closure, Phase 2 and 3 plans, and other ongoing self-assessments. - K. Performance Imorovement Plan A three phase document that summarizes processes, methodologies and bases for ensuring that performance at CNS improves. L. Responsible Manaaer The manager who is accountable for ensuring that a restart issue is satisfactorily completed. ~ M. Critical Systems List Comprised of those systems that could contribute the greatest to safe and reliable operation of CNS, N. Focus Proarams List CNS programs that have specific structure and purpose, and have been selected by management as being appropriate for performance monitoring. _ IV. RESPONSIBILITIES A. Site Manaaer Principle manager responsible for review, approval, and implementation of the Restart Readiness Program and all revisions thereto. 6 __E
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM B. Plant Manaaer Pririciple manager responsible for review, approval, and implementation of the Power Ascension Plan and ensuring prompt revision as necessary. C. Manaaement Review Committee - A management team composed of the Plant Manager, Senior Manager of Safety Assessment, and Corporate Division Manager of Nuclear Engineering & Construction. The Plant Manager is the Chairman of the MRC. All MRC members are expected to be present during all MRC meetings where restart determinations are made. Exceptions to this expectation may only be granted by the MRC Chairman. The MRC has the primary responsibility for determining that items are appropriate for addition to the restart list, that self-assessments are satisfactory, and that organization performance has been improved to the point that restart of CNS is appropriate. D. Responsible Manaaer Manager accountable for ensuring that the item has been properly assigned and , closed-out. The Responsible Manager (or designate) typically will present restart item screening conclusions and the restart item closecut presentation to the MRC. , V. RESTART READINESS PROCESS The restart readiness process involves the collective review and assessment of events and activities, and associated resolutions to determine if CNS is ready to
- resume operation. The primary contributor to restart conclusions will be the satisfactory closecut of Phase I Action items. As discussed herein, Phase 1 Action Item objectives provide the basis for the CNS Summary Restart List. More detailed restart issues are included in the Integrated Restart List. The addition or deletion of a restart item from these lists may occur only with the approval of the MRC. This process is similar to approaches recently used by other nuclear plants with similar deficiencies.
Also providing input into restart readiness decisions is the closeout of several self-assessment initiatives. Restart readiness self-assessments will be performed for critical systems, significant programs, and CNS departments. These self-assessments will utilize the results of Phase i Action item closecuts as appropriate. The MRC will determine the acceptability of self-assessments and make a site readiness determination. Once it is concluded that the site is ready for restart, implementation of the Power Ascension Plan begins. The Power Ascension Plan provides direction regarding additional restart actions. en.m 7
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM w 1 l l
- Engineering Support: roles, responsibilities, and support to operations I and maintenance. t e Plant Testing: IST, surveillance, post-maintenance testing, and ,
preconditioning. ' o Operational Experience Review (OER). j e Procedural Control: technical quality, procedure changes, and procedure adherence. e Additional Management issues: issues that are not specifically addressed in individual program and process categories. A. Development of Restart items List
- 1. Identification of Restart items -
Restart items generally evolve from material condition issues, ongoing NRC
~
inspections, and NPPD assessment activities. Potential restart items also may evolve from employee input to supervisors, through CNS management's review of Performance improvement Plan activities, or from other self-assessment or improvement processes. In this light, CNS has developed a Potential Restart item Form which may be submitted by any NPPD employee (to the MRC) who believes that an item should be evaluated by the MRC for restart implications. Restart items may be addressed by the MRC individually or as a group. Inclusion or exclusion of a group of items is appropriate only if the activities are similar based on the following factors:
- Safety significance, and e extent of condition, and e source (e.g., hardware issues, process issues, maintenance work requests, etc.).
A more detailed discussion of the process used for submittal of this form is provided in App 6ndix D. Specific restart item identification builds upon the same screening criteria utilized in the Phase 1 Plan. The screening criteria are repeated below for convenience. Level l Screenino Evaluation: Issues were evaluated to identify potential safety or operability concerns. These issues were automatically categorized as restart items. 9
O PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM VI. PHASE I CLOSEOUT Closeout of all Phase 1 activities was viewed by CNS management as necessary to demonstrate clearly that sufficient changes have occurred at CNS to address and to prevent recurrence of declining performance. The method of Phase 1 closecut, disposition of Phase 1 findings, and implementation of resultant corrective
- actions are discussed in Appendix A of this document.
Vll. RESTART LIST As discussed in the Phase 1 Performance improvement Plan, the process used to identify restart action categories included a review of CAL items (and responses), open items, DSAT issues, SET issues, and NPPD-identified issues. Two levels of restart items exist at CNS. The Phase 1 Plan provides action items that broadly define restart item categories and documents responsible NPPD managers. The list of Phase 1 Action Item objectives is the Summary Restart List. The Summary Restart List is-provided as Appendix C to this document. This list has been approved by senior management as the scope of actions that must be completed prior to restart. The second level of restart items, the Integrated Restart List, contains more detailed itemized descriptions of the specific activities that must be completed prior to restart. The Integrated Restart List also must be approved by the Management Review Committee. Approval of additions to these lists is addressed in Section Vll.A below and Appendix D. Emergent restart issues will have a focused evaluation to determine whether they should be added to, or deleted from, the Integrated or Summary Lists.
- These lists are not intended to address routine issues that would normally be required by, for example, technical specifications, previous commitments to the NRC not specifically related to restart, and other activities designated by the Site or Plant ~
Manager. Also, these lists do not include all issues that could be scheduled for completion during the outage. Many outage items may reasonably be rescheduled until post-restart if circumstances do not allow their completion prior to plant startup. See Appendices B and L for a flowchart on how NPPD will address outage work items. The restart categories addressed in the Phase 1 PlP are: e Independent Oversight and Self-Assessment: roles and responsibility of SRAB, SORC, QA and QC and organizational self-assessment. e Corrective Action Program, Planning and Performance Monitoring:
- problem identification, root cause analysis, planning and issue resolution,
!_ performance monitoring and follow-up.
- Work Control: identification, tracking, planning and scheduling.
l_
- Design Control and Configuration Management: plant design change control, clearance program, valve lineups, and drawing control.
l 8 l
.(
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
" Level 11 Screenina Evaluation:
Issues that were not categorized as restart items during the Level I screening evaluation were reassessed to determine if they still should be considered restart items. Satisfying a'ny of the following criteria qualifies the item as a restart item. ' An event or finding must be categorized as a restart item if the event or finding involves or could reasonably lead to: ~ ' ~ e an event, component failure, deficiency, or condition that could result in '
- operation in an LCO Action Statement, or
- e. f ailing to perform a required surveillance test or other license requirement cr meet a commitment to an outside agency, or e failure of power production equipment that could result in a plant-transient, derating, or plant shutdown, or
~
e conditions that have resulted in repetitive safety system equipment failures, or e potential licensing basis deficiencies requiring maintenance to restore to - x conforming : conditions (i.e., deficiencies in safety-related or other qualified equipment, e.g., EQ, Appendix R, or seismic), or
~
e potential design basis deficiencies, i.e., deficiencies in safety-related equipment or other technical specification equipment not in conformance with the USAR, or e deficiencies in configuration management programs, processes, engineering analysis codes, or documentation that have, or could have, , a reasonable likelihood of affecting equipment operability, or e conditions that may create an unacceptable potential for an unplanned radioactivity release to the environment or discharge affluent to the ;
~
environment which is in excess of limits. l
\
h
/
M i I Y me. 10
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM B. Development of the Outaoe Maintenance Schedule Maintenance work for the current outage is controlled in accordance with an outage schedule that contains maintenance work that must be completed prior to plant restart. In addition to meeting the technical specification requirements for equipment operability, the schedule will contain other maintenance activities that - satisfy at least one of the eight Level ll startup criteria stated above. Decisions to add hardware items to the approved startup schedule are controlled as described in the flowchart provided in Appendices B and D. These flowcharts describe how potential restart issues are screened and closed-out. C. Closeout of Restart items The following provides a standardized format for addressing Integrated Restart List items.
- 1. Closecut Documentation -
The Responsible Manager for each Summary Restart List item must maintain the master set of documentation for issue closeout. The following closeout process applies to Phase 1 Action Plan items and other significant issues as directed by the MRC. All other issues, e.g., Maintenance Work Requests, Condition Reports, Nuclear Action item Tracking issues, etc., will be closed using normal station processes. The documentation will be maintained in a binder containing information in the following ! format: l A. Summarv:
- Explain why issue is closed / objectives satisfied.
B. Closecut Actions: !
- i
~
- Actions taken to closeout each Action Plan step.
- Why actions envelope the " extent of condition."
C. Results
- Performance improvements in general.
- Any measurable indications / examples of improvement.
ame 11 l l
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM i - D. Follow-uo Actions e Actions to ensure continuation of improvements. Attachments: Supporting documentation verifying closure of each Action Plan step.
- 1. Index
- 2. Action Plan
- 3. Gantt chart with status pages (if appropriate)
- 4. Support documentation; e.g., QA inspections, procedure changes, cover pages of documents and applicable pages.
Approvals: (signatures) Vill. SELF-ASSESSMENT ', A key to ensuring restart readiness is an effective self-assessment program. ~ 1, j Self-assessments will determine the readiness for start-up and therefore, better ensure successful subsequent operations. Structured self-assessments will be performed for
. Department Readiness, Program Readiness, and System Readiness. This is
~ accomplished through the conduct of pre-milestone and periodic management , assessments of performance and readiness effectiveness reviews. The collective perspective of the Management Review Committee will provide the necessary focus : ~ on critical work activities, synergistic effects, and issues that need to be resolved to support the objectives of the readiness review. A. OBJECTIVES l Structured self-assessments will be conducted which will achieve the following ) objectives: e Ens 6re that there are effective communications between station management and staff to assure that important issues are well-understood, facilitate teamwork, and instill a continued sense of ownership of the issues and results, I o Ensure that significant performance or other emergent issues identified - during the outage are resolved satisfactorily, i
% l 12 ,
I
, _ .- .. - _ . . . - - . .= - --. - . . --
%. ~ l PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM e Define a path for continued performance improvement through linkage of assessment results that are appropriate for longer-term resolution in the Phase 2/3 Performance improvement Plans.
- 1. Conduct of Self Assessments s
- Self-assessment at CNS will provide the cornerstone for determining readiness for restart and evaluating the effectiveness of long-term improvement results it also -
provides mechanisms for ensuring that momentum gained from processes, management, and culture changes continues. To be effective, self-assessments must be part of an environment that reinforces performance improvement as a way of doing business and must create the change mechanisms that will improve performance and sustain it at a high level. The MRC will review self-assessments to ensure that the following issues are
~
addressed: A vision of required organizational performance, clearly stated and e shared by the organization.
- Ownership and accountability by organizational members to achieve the '
objectives through managed improvement. For example, the Phase 1 Plan assigns responsibility and accountability to action plan managers for . completion of necessary improvement activities.
- e A value system that promotes the proactive identification and correction of problems by empowered individuals. The management team provides management expectations and guidance necessary to ensure that '
managers can succeed. e A focus on operational readiness by using performance criteria ; established to measure assessment results. This is provided by the restart performance measures developed in the Phase 1 Plan and , readiness review criteria.
- 2. - Readiness Reviews In addition to completing Sumrrary Restart List issues, and Integrated Restart List item-specific restart items, there are five broad areas that will have a readiness review prior to restart. These areas were selected to complement other assessment mechanisms, e.g., performance reports, Phase 1 Plan assessments, and QA oversight.
Tha following provides a discussion of specific areas and the intended scope of
- assessments: -GS 13
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
~,
I ,_ a. Manaaement Effectiveness e Evaluate the adequacy of surveillance test scheduling to ensure there are adequate checks, responsibility l assignments, and control. 1- e Ensure that a startup schedule is available which reasonably sequences activities necessary to support plant startup. e Determine the status and acceptability of operating experience review for any unresolved SOER and OER I issues. l l- e Review the outstanding commitment assessment results to determine that all appropriate items have been resolved. l 1 l.. b. Operations Effectiveness - Review the effectiveness of the operability verification
~
e process to track, communicate and resolve operability issues.
~
e Evaluate the nature and extent of operations issues,
- l. including a backlog review of maintenance, engineering, l and temporary modifications. Evaluate the potential for these to impact the objective of an error-free start-up.
e Assess outstanding equipment clearances to ensure that
~
any operability issues are identified and resolved. 4 e Evaluate simulator training results for operating crews for startup.
~
- Evaluate post-maintenance tests, plans and schedules to ensure that tests are completed successfully.
- c.
- Maintenance Effectiveness e Ensure that staffing is adequate to support startup shift work requirements.
14
3
)
S' PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM ;
-e Evaluate key plant system performance issues and determine risk associated with remaining open maintenance or modification activities.
4
- d. Suncort Effectiveness l
- 1 e Ensure that adequate engineering support is provided to j support shift work requirements and operability j determinations.
I e Ensure that adequate shift staffing is provided for RP, ' chemistry and QA/QC to support start-up.
- e. Engineering Effectiveness e Ensure that engineering analyses are prompt,' accurate and
-, address the issue, and support shift work requirements, reactor engineering and operability determinations.
- f. Power Ascension Plan o Ensure that the Power Ascension Plan assigns designated x personnel to manage plant startup activities through ;
completion of power ascension. Several Power Ascension = i Plan activities also support restart readiness action ! closeout. This activity may be accomplished through other self-assessments.
- g. System Restart. Readiness ai e Prior to restart, each responsible system engineer will review the status of each system as indicated in Appendix E and will affirm restart readiness of the system to support
~
safe and reliable restart and full power operation. The objective is to assess collectively and document system , readiness from a hardware standpoint, to support management restart decisions, to reinforce ownership for system performance and improvement with system engineers, and to lay the foundation for post-restart work / improvement prioritization. Appendix E provides a list , of systems that must go through the System Restart Readiness process, summarizes applicable criteria, and
- provides the form that will be used.
v 15
.. - ~~ . . .- - - . - . .-. . .
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM _ As discussed in the Phase 1 Plan, the process requires both - an initial multi-disciplined assessment of system status and a final assassment and affirmation (signature) by the j System Engineer prior to restart. ' See Appendix E. , Incomplete activities .at the time .of the final system readiness assessment will be identified to.the MRC and
- their impact on restart determined. The System Engineer-must prioritize those remaining' items and determine whether inclusion into the Phase 2 or Phase 3 Plan is appropriate. Technical specification systems will be verified operable before entry into a mode where they are required to be operable.
e Walkdowns will be conducted to assces material condition. Specific emphasis will be placed on systems that are safety significant and important to plant reliability. Walkdowns at a - system operating temperature and pressure 'will be
~
conducted as appropriate to confirm appropriate system restoration, e System engineers will confirm that the material condition of
- the system; the completion of walkdowns; the completion of the review of information related to significant recurring or repetitive equipment problems; development, implementation, and completeness of actions to address
" them; and the establishment of compensatory measures (as
,, appropriate) for post restart items / issues.
~
o System readiness assessments will be reviewed by the
; system engineer's supervisor, SORC, at d the MRC as
~'
indicated in Appendix E. System readiness affirmations also will provide input into department readiness
- affirmations discussed in Section Vill. A.2.h below, and into the overall Management Review Committee's assessment of site readiness. >
_. h. ' Department Restart Readiness e Prior to restart, managers responsible for each major _. functional department indicated in Appendix F will affirm restart readiness of that department's ability to support an error-free startup and safe and reliable operations. This will
- ensure department completion of assigned restart actions; ensure that programs, processes, organization, and v personnel / management capability are sufficient to support 16
, ,c, -
PERFORMANCE IMPROVEMENT PLAN RESTART READINESS PROGRAM ., ,3' safe and reliable operation; ensure that post-restart work and improvement efforts are sufficiently defined, prioritized, scheduled, and controlled; and ensure'.that appropriate a . post-restart assessments and monitoring processes are in - place. o- Final department readiness affirmations will be reviewed by : the MRC. Reviews by SORC and other cognizant managers will be input into the overall Management. Review
- Committee site readiness assessment. <
- 1. Proaram Readiness Assessments e Program owners will assess the health and effectiveness of programs owned by that department. The results of this ;
assessment will -be incorporated into the department
.2 readiness affirmations. -
Past problems with programs at.CNS resulted in part from l unclear ownership, process control weaknesses, and
~
technical program inadequacies. This program assessment is an important element of CNS performance improvement 3
- in that each program . owner must. establish clear 1
~
accountability and responsibility for his/her programs. To ensure a consistent, thorough method of assessing site-2
- programs, specific assessment guidance has been )
developed (see Appendix H). This guidance and the list of d programs that will be assessed are provided in Appendix H.
-]
- o Program owners are expected ' to provide periodic d summaries of identified program' weaknesses from internal and/or external evaluations, trending, and corrective action ,
- documents. Results of these assessments should be documented and recommended actions will be evaluated by the MRC for restart implications and/or appropriate long-
~
l term enhancements. J. Site Readiness Assessment e The overall site readiness assessment will consist of a
" program rollup" of several interfacing and overlapping inputs. These include the system and department readiness affirmations described above, the closeout / disposition of all v restart list items, the review of organization and personnel 17 - )
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM ~ adequacy and other input from personnel and management. See Appendix 1. e The MRC will review a . J evaluate both the individualinputs and the rollup of these inputs and provide,in consultation with the Site Manager, a recommendation to the Vice-President Nuclear for restart authorization. The MRC readiness assessment will be completed before initial mode _. change. Preliminary or intermediate assessments will be conducted as determined appropriate by the MRC, SORC, the Site Manager, or the Vice-President Nuclear. The SRAB also may review site readiness for initial mode change as it deems appropriate.
- e A Power Ascension Plan has been prepared and approved by senior CNS management. This document provides -
specific requirements for startup management, preparing plant hardware, and methodologies that will be used during the actual startup process.
- 3. Review of Self-Assessment Results The review of the results of the management self-assessments to assure that
~
organizational performance meets expectations for plant restart will be performed by - the MRC. This review provides the v,ehicle for establishing and reinforcing expectations with assigned managers, receiving feedback on organizational performance results, and obtaining early feedback on corrective action for performance deficiencies or emergent issues that may impact performance results. o The schedule for the completion of assessments and presentations to the MRC will be controlled by the Phase 1 Project Manager or designate. This individual will ensure that review briefings are scheduled, assist in clarifying assessment processes and requirements, and track and assign further assessments (or other ace m) which ~ may evolve from management review of the results. IX. QA OVERSIGHT Independent oversi0ht of the Restart Readiness Program will be conducted by ~ the Quality Assurance Division through assessments of selected Phase 1 Action Plans, scheduled audits, and specific evaluations of significant emerging issues. Audits in progress and scheduled will emphasize evaluation of identified and potential areas of weakness within the scope of the respective audit. Assessments and surveillance activities will be planned and implemented to focus on evaluation of field performance and operational activities executed to correct identified deficiencies and prepare the plant for return to safe power operation. 18
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
=
W o**
-. i sy s .
ewe bed 4H T r
~
APPENDIX A - PHASE 1 CLOSEOUT SAS reek I l
*e W
9 M l V em om
. PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM P
NF0' 9 est
.1
?
M9
. ee NUCLEAR POWER GROUP PHASE 1 PLAN
.) CLOSEOUT REPORT .
.. PURPOSE AND SCOPE 9 ..
I w' , 1
\
-4 ,
em M if l 4 j N b' 1
. PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
_. NUCLEAR POWER GROUP PHASE 1 PLAN CLOSEOUT REPORT PURPOSE AND SCOPE The purpose of the Nuclear Power Group Phase 1 Plan Closecut Report _ - ("Closcout Report") is to identify and summarize the actions that have been taken at Cooper Nuclear Station (CNS) to resolve the issues identified in the Phase 1 Plan. The Phase 1 planning process involved a comprehensive evaluation of issues identified in ' ;
- numerous sources including NRC enforcement actions, the Diagnostic Self ,
Assessment Team (DSAT) Report, the Confirmatory Action Letter (CAL), and issues self-identified by CNS management. Based on a comprehensive evaluation and screening of the issues identified in these various documents, the Startup Plan Team responsible for development of the Phase 1 Plan identified the subset of management, program / process, and material condition issues that required resolution prior to startup. The Phase 1 issues are addressed in the Plan's three constituent parts: (1) the Phase 1 Action Plans; (2) Material Condition items; and (3) the Phase l Action item List. Lists of the three sets of issues are included in Enclosures 1, 2, and 3,
~
below. The Closeout Report will assess the effectiveness of the actions undertaken at CNS to closecut each of the issues addressed in the Phase 1 Plan. In sum, the purpose of the assessment is to determine whether the issues set forth in the Phase
~'
1 Action Plans, list of material condition items, and Phase 1 Action item List have been effectively addressed -- or remain barriers to safe plant restart. In addition, the
- assessment will gauge whether actions have been taken to clearly communicate management's expectations regarding the Phase 1 improvement initiatives.
6 h The Closecut Report will be structured first, to describe the purpose, development, and scope of the Phase 1 Plan. An assessment of the actions taken at CNS to closeout the issues set forth in each part of the Phase 1 Plan will be summarized in the Closecut Report. A more detailed, issue-by-issue explanation of the actions taken to close out the Phase 1 issues included in the Action Plans, List of Material Condition items, and Action item List will be available in matrices found in Appendices A, B, and C of the Closecut Report. In addition, closure packages for each of the Phase 1 Action Plans -- containing documentation verifying closure of
~
each action plan step -- will be available for review at CNS. v 2
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
~~
ENCLOSURE 1
~
PHASE 1 ACTION PLAN-
. Action Plan
. ID'# issue 1.1 Revise the SRAB Charter; Address Member Indepenkfence and Revise Membership 1.2 Improve SORC Effectiveness 1.3 Independent Assessment of Startup Action Plan, Confirmatory Action Letter, and Condition Reports 1.4 Quality Control
~
2.1 Corrective Action 2.2 Departmental Performance Indicator Goals / Monitoring
@ 3.1 Establish and implement a Plan for Integrated Work control, planning, and Scheduling 3.2 Implement Effective LCO Tracking and Work Coordination Interface System 4.1 Plant Configuration Verification (1 of 2)
- 4.1 Plant Configuration Verification (2 of 2) e 4.2 Identify and Review Priority Vendor Manuals t
3
e .
..- PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
.m.
4.3 NED Review of Procedures and DCNs to Ensure Configuration Control 4.4 Efficient Resolution of Design Basis Questions 4.5 Surveillance Procedure Adequacy 4.6 SORC Approved MWRs and Subsequent Design Changes
..p 4.7 Inadequate Calculation Control Prior to implementation 4.8 Multi-discipline Team System Reviews 5.1 Improve NED Site Support during Startup and Power Ascension (S/PA) 5.2 OD/OE Review 6.1 Pre-Conditioning 6.2 IST and Surveillance Testing a
7.1 Startup Experience Following Extended Outages 7.2 Open OERs 7.3 Reactor Vessel Thermal Transient l j , 8.1 Develop Procedure Hierarchy to identify Controlling Procedures I 1 8.2 Special Instructions a 4 1 1
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM m
~
8.3 Screen 8acklog of Procedure Changes for Significant items for Startup
~
8.4 ADAM Changes 8.5 Method for Handling Surveillance Test LCOs Without Allowed Outage Times - 9.1 Resolve the Lack of Program Ownership in the NPG 9.2 Nuclear Safety Awareness 9.3 Management Observations - Field Coaching Team Plus Management Observations 7 9.4 Industrial Safety 9.5 Licensing Submittals
~
e M GMat owd Y eue 5
~ PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM ~ ENCLOSURE 2 MATERIAL CONDITION ISSUES The following list of material coridition issues can be found in Appendix B of the Phase 1 Action Plan:
- Service Water switches plugging with silt.
- Low pegging of RHR HX divider plate indicators due to plugging.
- 111 Type 2 and 827 Type 4 open items; 2400 discrepancies unresolved (tagging, labeling, physical repairs, procedure revisions).
- Tygon tube " gutter" to address leak around flanged connection on "A" RHR HX.
- RHR pump 18 failure to achieve reference value for number of test
. (e.a., dP @ 10 psi short of reference value).
- Cause of shutdown cooling isolations was leakage past pump
. minimum flow valve that indicated closed but was not fully seated.
4
- Caution tag informing operators that operation of DGSA-V-37 or -38 with failing PCV could overpressurize DG H&V air piping.
- Unexpected opening of HPCI pump minimum flow valve during surveillance testing at full power (1/19/94).
- Leakage past seat in Vessellevelinjection valve NBI-SOV-738/739; isolation of NBI-V-577A/B.
-
- Control switch for main turbine bearing lift pump is in manual to prevent operation while the speed input to its control circuit is erratic.
-
- 200 gpm leakage by the seat of the B RFP minimum flow valve, which is kept isolated as a result.
- Due to leakage by the seat of the domin water LCV, it is isolated. This requires operators to manually open DW-34 prior to starting the Mechanical Vacuum Pump from the MCR.
eme= ene 6
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM n.
- Caution tag guidance not to bias RFC-MA-84A/B positive due to causing RFPs not to go into track and hold following a scram (93-02).
- Monitoring of potential erosion of portion of RHR system not
> established as required by modifications made to flow trim on valves MO-27A/B and 34A/B. -
- Leakage in REC piping not~ adequately monitored.
- Installation of SCRAM discharge level transmitters with improper bolting.
- During B Loop shutdown cooling, flow turbulence caused " chugging" sounds in vicinity of HX bypass valve, RHR-MO 668.
- Failure to test or maintain essential relays on a regular basis, including 18 ground detection relays (50G) on 4160V buses 1F and 1G and
-- Emergency Transformer overvoltage relays.
- Two overhead troughs outside MVP room have drain hoses that end outside sump barriers, creating potential for pooling in corridor.
/
- Possible cavitation noise at water box south of downstream of RF-
~
28MV. a
- Excessive failures of LLRTs on one valve without apparent root cause or detailed evaluation.
- Approximately 250 terminations require repair.
w e Work to replace exhaust manifold on #2 DG was not in accordance with vendor specifications.
-
- Contrary to vendor specifications, bolts on "A" SWP coupling were not tightened with a torque wrench, bolting was not cleaned and lubricated prior to assembly, and tightening pattern was not used by work crew.
- Work performed on MWR 94-4203 and MWR 94-2923 (8/2/94) to set impeller clearance on A service water pump not in accordance with vendor specifications.
- Fuel pump (5L, #2 D/G) replaced using specialinstruction that did not include torquing of bolts.
m.e 7
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM - ' ~
- Degraded condition of MO398 RHR MOV is not identified in the MWR system. Operability Determination No. 94-50 identifies installation of
'_ 250V cor. trol relay in place of 125V control relay for Auxiliary oil pump on HPCi pump.
- Operability Determination No. 94-58 identifies installation of an undersized relief valve on the EDG starting air system (DGSA-RV-
' 15RV).
- Operability Determination No. 94-63 identifies that various check valves installed in the NBI, RCIC, RR, MS, and HPCI were not supplied
, safety-related.
- Operability Determination No. 94-77 identifies lockwashers used on RHR pump motors A,B,C, and D were supplied commercial grade on an essential purchase order and may not be qualified for use.
-
- The plant's corrective action did not include checking other motor boltings on the three remaining RHR pump motors.
M 4
,ee. $P49 t
es== 9em b 9
" M euss 8
~
, PEJFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM m
ENCLOSURE 3 I PfiASE 1 PLAN ACTION ITEM LIST The following items are delineated in Appendix A of the Phase 1 Plan: 1
.
- Determine whether control of spare parts for safety classification is a ,
startup issue.
- Submit letter to NRC to clarify MOV testing schedule.
- Resolve CS-5A maintenance and testing commitments.
- Complete OER review and determine generic implications.
"
- Resolve recommendations from MWR Maintenance Work Practices Review.
- Determine whether ar. tion is necessary prior to startup for the " design
, change correcting the problem" issue.
.-
- Evaluate the power ascension plan for integration with Phase 1 Plan,
, - including establishing management expectations (e.g., for error-free startup). --
- Determine whether action is n'ecessary to ensure technical adequacy of design changes, 4
- Ensure that specific issues are addressed in revised clearance order i program: (1) non-operators operating equipment; (2) pull-to-lock protection use; (3) overriding danger tags; and, (4) independent verification.
8ense s t W V w
- 9
'g .
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM g o. w h M d M L
- 4 ene chur4 s i e %
- APPENDIX B - RESTART READINESS PROCESS FLOW CHART M ?)
W - 9 4 anse ==er M O esas w e- +
I I I I I I .L i 2 1. ! . i ; 1 i I 4- I : i I ,i_ - ( i ; )
^PP*"#" 8 CNS READINESS REVIEW PROGRAM t ;
issue Pool
- System Phase 1 PIP Readiness CAL Assessment
- MRC Review =
^ "
NRC-IRS Lis Clo ut 7 Program CAP 1 m Readiness Self Assessment Assessment CNS Management " Employees Second Level Department Screening -. Readiness Assessment include in Phase 2 or 3 7 o Quality P er Assurance Site . _ _ _ _ _ Site Readiness Site Manager Readiness Review (MRC) Approval implementation Ae=aannent a NRC Restart NRC Oversight Panel Review
1 iii . l j f. PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM i 1 4
-4 l
i 1 APPENDIX C -
SUMMARY
RESTART LIST 9 e+ 4 M w T4 v
m COOPER NUCLEAR STATION
SUMMARY
RESTART LIST The following provides the CNS Summary Restart List. This list addresses broad actions that must be completed prior to restart. They are the framework for the Phase 1 Performance Improvement Plan. A more detailed list, the integrated Restart List, provides a detailed listing of specific activities that must be completed prior to CNS
. restart. ;
~
- 1. Revise the SRAB charter; address member independence and revise membership - ) .1 Ensure SRAB procedures and membership provide effective independent review,
~
audit and oversight of NPG activities to ensure Cooper Nuclear Station is safely . operated and maintained. Changes must ensure SRAB is self-critical and challenges line management. .
-. 2. Improve SORC effectiveness - t R Improve independent oversight ability of SORC to ensure that an appropriate 7 review is performed for all proposed additions, deletions, and changes to safety-related activities.
~' Enhance the process utilized by SORC to ensure sufficient independent oversight J is maintained.
~
- 3. Independent Assessment of Startup Action Plan, Confirmatory Action Letter, Condition Reports - L3
- To conduct the independent assessments as described above and provide timely reporting of results as appropriate. To ensure a quality startup plan and that significant issues are appropriately addressed prior to startup.
~
- 4. Quality Control - \ A
_ 1. Provide increased consistency in the application of QC requirements.
- 2. Provide increased QC inspection for additional activities. l i
- 3. Impose limitations on the amount of persons reviewing and specifying QC requirements.
v
SUMMARY
RESTART LIST - November 3,1994 Page1
e t
- 4. Coach / counsel QC personnel on new program requirements.
- 5. Corrective Action 9.1 Use the dedicated Corrective Action Program group to provide clear management of the program and establish a self-critical root cause culture at CNS which ensures rigorous investigation and effective correction of all conditions adverse to quality.
- 6. Departmental Performance Indicator Goals / Mon:toring - 2.2 To develop management tools to obtain and monitor challenging goals for key
_ station performance indicators. Establish and implement a plan for integrated work control, planning, and
~
7.
-- scheduling - 3,1 ~ '
Correct existing deficiencies in work package content, work coo,dination, and
- ~
daily scheduling through implementation of a work process improvement plan.
~
- 8. Implement effective LCO tracking and work coordination interface system -3.Q, 3
Improve tracking of technical specifications-related equipment that is out of
~
service to limit challenges to safety systems caused by work coordination problems. _., 9. Plant Configuration Verification (1 of 2) - 4.1 Determine if the standby alignment of the plant safety systems is properly specified such that, if called upon to automatically initiate, the systems will meet 4 their design objectives.
- 10. Plant Configuration Verification (2 of 2) - 41.
Perform valve, switch, breaker, and damper lineup walkdown and initiate corrective action for discrepancies.
- 11. Identify and Review Priority Vendor Manuals - 4.Q Determine if the backlogged safety-related vendor manuals / vendor manual j
~ changes and certain non-safety related vendor manuals / vendor manual changes j have recommended PMs that should be addressed prior to startup.
SUMMARY
RESTART UST - November 3,1994 Page 2
~
- 12. NED review of procedures and DCNs to ensure Configuration Control - 4.3 Provide mechanisms for assuring that changes to configurations reflect station design. This includes strengthening review of drawing changes and specific !
procedures. l
- 13. Efficient Resolution of Design. Basis Questions - 4.4 Provide a more efficient method of responding to design basis questions and identifying design basis information and upgrade the quality, detail and accuracy ,
of 10CFR50.59 evaluations before they are submitted to SORC for review and approval. -
- 14. Surveillance Procedure Adequacy 4 5 Complete surveillance procedure validation for CSCS and RPS.
~
- 15. SORC Approved MWRs and Subsequent Design Changes - 4,5 Provide added assurance that SORC approved MWRs used to implement modifications receive a higher level technical review to guard against design deficiencies or violation of design basis.
- 16. Inadequate Calculation Control Prior to implementation - 4 7 .
Ensure calculations that are approved prior to the associated field modification / implementation are appropriately identified.
- 17. Multi-discipline Team System Reviews - 4.6 Complete multi-discipline review of all open items and conduct walkdowns for the RHR and SBGT systems. Revise system checklist for walkdowns and conduct multi-discipline reviews of all critical systems prior to startup.
~~
- 18. Improve NED Site Support during Startup and Power Ascension - 5 1 Provide a coordinated review of the NED/CNS Engineering functions and interfaces related to startup and power ascension, and develop an upgraded interface agreement better defining work function, and responsibilities l Provide augmented NED on-site support for CNS startup and power ascension
~ activities.
SUMMARY
RESTART LIST November 3,1994 Page 3
- 19. OD/OE Review - 6.d Review ODs and OEs for degraded and nonconforming conditions that currently exist and assess startup significance.
- 20. Pre-Conditioning - 6 1 Complete resolution of the CAL pre-conditioning issues.
- 21. . lST and Survell'ance Testing - 6.R
- 1. Verify IST program scope and testing adequacy by constructing the basis for component IST requirements and identifying discrepancies.
- 2. Conduct an evaluation of (types and numbers of] surveillance tests performed to determine program adequacy.
- 22. Startup Experience Following Extended Outages - 71 Conduct special operating experience search for startup issues following long -
shutdown. -
- 23. Open OERs - 7.Q Evaluate current open OERs for startup significance.
- 24. Reactor Vessel Thermal Transient '7 3 Review the reactor vessel and attached piping thermal transients and determine that the thermal fatigue limits have not been exceeded and assure margin adequate for further operation exists.
- 25. Develop procedure hierarchy to identify controlling proceduree - 8.1 Identify all procedures which control and take precedence over other procedures.
Screen lower level procedures for compliance with controlling procedures.
- 26. Special Instructions -81 Develop procedural controls and methods that ensure work performed using Special Instructions is performed at a quality and safety level consistent with that of existing SORC approved procedures.
SUMMARY
RESTART LIST - November 3,1994 Page 4 0
l 1
~
. l x 27. Screen backlog of procedure changes for significant items for start-up - 8,3 Identify all in-process procedure changes requiring approval prior to start-up or - l early in start-up sequence and ensure entry into tracking system.
- 28. ADAM Changes a 6.4 :
~
Purge ADAM (class "B" model, as defined in NUREG 0654) of all reference to . dose, dose rate and any use there of for determination of PARS. )
~
- 29. Method for handling surveillance test LCOs without allowed outage times -8. 5
- , Provide administrative controls for allowed out-of-service times for Technical Specification surveillances.
- 30. Resolve the lack of program ownerchip in the NPG 91 '
Establish effective' ownership for programs which affect reactor safety. I
- 31. Nuclear Safety Awareness - 9.Q T Strengthen the NPG nuclear safety culture and establish high standards of safe, reliable nuclear plant operation.
- 32. Management Observations - Field Coaching Team Plus Management -S3 Observations Increase Management and Supervisory involvement in the field in order to:
- 1. Assess station material conditions
~
- 2. Assess compliance with established radiological and industrial safety work practices
- 3. Assess compliance with station work documents
- 4. Coach and mentor personnel in the field
- 5. Re-enforce management's expectations and standards in the field
- 6. Improve organization communication channels
SUMMARY
RESTART UST November 3,1994 Page 5
~.
- 33. Industrial Safety 9A One of the major objectives of the District is to protect its employees and the public from accidents. Whenever economically possible, the District will eliminate
"~
hazards from employee work areas. However, where hazards cannot be economically removed, it becomes the responsibility of each supervisor and employee to recognize these hazards and deal with them in a manner that will '~ prevent accidents.
- 34. Licensing Submittals 9.5 Development of intemal procedures and practices that assure that all licensing
-. submittals contain accurate information and that all commitment made to extemal agencies are completed on time.
~
SUMMARY
RESTART LIST . November 3,1994 Page 6 i 1
_ PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
-M 5
W 4 h APPENDIX D - POTENTIAL RESTART ITEM EVALUATION FORM
~
4 m6 Ed W m
**9*
d W 3 W f sue e
I 1 RESTART WORK ITEM ADDITION BASIS CHECKLIST l m i l 1ESTART ITEM IDENTIFIER:
-Check the basis for adding the item to the Restart List. The absence of a mark indicates that the item should not be added to the Restart List. If no criterion is satisfied, this form still must be completed and signed by the Responsible Manager.
1.eveli Screenino Evaluation: Issues were evaluated to identify potential safety or ooerability concerns. These issues were automatically categorized as restart items. Level 11 Screenina Evaluation: Issues that were not categorized as restart items during the Levell screening evaluation must be reassessed to determine if there are other reasons for considering them restart items. Satisfying any of the following criteria qualifies the item as a restart item. If an 3 vent or finding involves or could reasonably lead to: - an event, component failure, deficiency or condition that could result in operation in a LCO Action Statement, or failing to perform a required surveillance test or other license requirement or meet a commitment to an outside agency, or - failure of power production equipment that cou!d result in a plant transient, derating, or plant shutdown, or conditions that have resulted in repetitive safety system equipment failures, or potential licensing basis deficiencies requiring maintenance to restore conforming conditions (i.e., deficiencies in safety-related or other qualified equipment, e.g., EQ, Appendix R, or seismic), or potential design basis deficiencies, i.e., deficiencies in safety-related equipment or other technical specification equipment not in conformance with the CNS USAR, or
~
deficiencies in configuration management programs, processes, engineering analysis codes, or documentation that have, or could have, a reasonable likelihood of affecting equipment operability, or , conditions that may create an unacceptable potential for an unplanned radioactivity release to the environment or discharge effluent to the environment which is in excess of limits. Based on the above, the issue should /should not be added to the Restart List. _ Screened By. Date Responsible Manager Signature Date vv+w - w w - re--- T w ei--- = , --*w1-P
'~! RESTART WORK ITEM ADDITION / DELETION FORM
~
Retain Add Delete RESTART ITEM IDENTIFICATION RESTART ITEM OWNER (RESTART LIST #, WORK DOC.#, SYS, ETC.) ADDITION / DELETION INITIATOR ITEM / WORK DESCRIPTION REASON FOR ADDITION / DELETION EVALUATION
~
Cognizant System ,_ Engineer / Supervisor Signature Date
-or-Cognizant Manager Signature Date MANAGEMENTREVIEW COMMITTEE (MRC) APPROVAL MRC Approval Signature Date For Group items, list all applicable documents.
~
~
11/4'94
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM -i 4 ee' We
.4 9
APPENDIX E - SYSTEM READINESS ASSESSMENT
~
W ,w w M
%WuP" 4e8 '
PJRFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
~
SYSTEM READINESS ASSESSMENT ! The following activities will occur as part of the final stage system readiness reviews. Final System Readiness review (See attached form)
- 1. The System Engineer will review and affirm that for the subject focus system:
- a. The system readiness review is complete with any concerns resolved.
- b. System Engineer material condition walkdowns on focus systems are complete.
- c. Emergent items since completion of Rev. O of the Restart List have been properly dispositioned as restart or non-restart.
- d. Reviews of information related to recurring equipment / system problems (adverse trends) have been completed and a plan to address open items is in place -- compensatory measures have been established, as appropriate.
- 2. Engineering Manager, Plant Manager and Site Manager approval have been obtained.
=
ww M
~
i
~
SYSTEM READINESS REVIEW CHECKLIST SYSTEM NAME SYSTEM ENGINEER PIVIEW
SUMMARY
(The System Enrineer shall initial each item below to confirm reviews are comolete)
~
System open Maintenance Work Requests Plant Temporary Modifications Preventative Maintenance
~
ACT items System Walkdown performed Nuclear Action Item Tracking REMARKS (The System Engineer can provide any additional relevant information deemed necessary to orovide a complete summary of system readiness) System Engineer Signature Date ENGINEERING MANAGEMENT REVIEW & APPROVAIE Supervisor Signature Date j Engineering Mgr Signature Date COMMENTS: i l 1 l I PLANT MANAGER APPROVAL ! Plant Manager Date SITE MANAGER APPROVAL *
~
Site Manager Date
- Required if comments noted GuS m
.,iv,- - r 4 - . ... 4e-
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
~
1 I Critical System List M s M 4 teme 9 emus
=
M
=
amase
EERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
~
Critical Svstems List
- 1. Service Water
~
2.. Control Rod Drive '
- 3. Core Spray
- 4. Electrical Equipment
_ 5. Residual Heat Removal
- 6. Reactor Core Isolation Cooling
- 7. Primary Containment
_. 8. Main Steam
- 9. Diesel Generator
- 10. High Pressure Coolant injection
.- 11. Nuclear Boiler Instrumentation
~
- 12. Instrument Air .
- 13. Standby Gas Treatment
- 14. Reactor Equipment Cooling
- 15. Primary Containment Isolation System
- 16. Reactor Protection System
- 17. . Heating & Ventilation (Essential)
~
- 8. Standby Liquid Control -
- i 9. Neutron Monitoring
~
- 20. Automatic Depressurization
_ 21. Radiation Monitoring "
- 22. Turbine Generator Controls
- 23. Switchyard
+4 64 eum
[. M M ene eum
i PERFORMANCE IMPROVEMENT PLAN o RESTART READINESS PROGRAM
- l m
we l l l y m.- e6 A P4 APPENDIX F - DEPARTMENT READINESS ASSESSMENT e ee i .~ w P W n,.. wem eene
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM m Department Restart Readiness Assessment Departments in the General Office and at CNS will conduct an assessment of actions needed to support department readiness for restart, addressing areas indicated below. Readiness will
- address both 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 CNS forward with effective operations beyond restart.
Apolicability .
- Site Manager direct reports and their direct reports.
- Corporate Division Manager of Nuclear Engineering and Construction
. Denartment Manaaer Readiness Assessment and Affirmation -
- Organization responsibilities and functions defined.
- Programs and processes sufficient to support restan.
- Restart Items verified to be complete.
.
- Personnel / management evaluation complete and short term personnel / organization actions complete. -
- Necessary department training complete.
- Standdowns and communication plan complete; effectiveness assessed, i --
- Post-restart items identified and understood; workoff plan established; performance indicators in place, and periodic monitoring / assessment established.
- Phase 2 and 3 Plans on schedule for development / implementation
- Assessment and performance monitoring processes in place -- preliminary positive feedback.
Department Manaaer Review of Above items With Site Manaaer 1
~
- Feedback, expectations, and coaching.
- Status and process assessed.
- Restart readiness affirmed.
- Post-restart efforts defined and controlled.
Affirmation of department restart readiness is provided by the attached form. V* eue enes l l
m MANAGEMENT VERIFICATION FOR STARTUP DEPARTMENT DEPARTMENT MANAGER In addition to G.O.P. 2.1.1.1 requirements, the following items
- have been reviewed to ensure no open items will impact safety on plant startup:
Signature
. 1. All department open items reviewed including:
. Maintenance Work Requests
~
+ condition Reports
~
'~
+ Commitment /Open Item Tracking
- Procedure Changes
. Training e Open OER Documents -
.s
- 2. Any other items considered important
_, to safety. - o I verify readiness to Startup and have completed an extensive walkdown of plant systems. The plant is ready to return to power operation. Any
~~
comments are noted below: COMMENTS: l l DEPARTMENT MANAGER DATE I REVIEVED: SENIOR MANAGER DATE s,s
- SITE MANAGER DATE t _.
- Required if comments noted
i PERFORMANCE IMPROVEMENT PLAN RESTART READINESS PROGRAM ; M3K 4 M S 4 4 APPENDIX G - LICEN, SING READINESS p w
+.
M em e- - w
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
,.O, ~
LICENSING REGULATORY CLOSURE AFFIRMATION
- 1. The Licensing Manager shall ensure that reasonable documentation exists to verify
'_. completion of all restart actions agreed upon between the NRC and NPPD.
- 2. The open license tracking items have been reviewed and determined acceptable for
_ startup.
- 3. All open commitments to outside regulatory agencies have been reviewed and determined
, to be acceptable for startup.
9 ' ~ Exceptions: E
,Y
. 4 Licensing Manager MRC Approval M
M ene m
- 4
' PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM '
meme 6 ephe 4 m
-W
-WG ed 9
=
0 W*
~
APPENDIX H - PROGRAM READINESS ASSESSMENT N W 9 1 1 ~ < l gase l M V' ene e
O
- PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM n
~
Proaram Readiness Assessment Page 1 of 3 d:- PROGRAM: PROGRAM OWNER:
- l. Program Ownership and Definition
. . A. Is ownership clearly defined: If so, where?
B. Do any portions of the program involve split ownership? If so, explain: C. List procedures that define and/or implement the program. . D. Are organizationalinterfaces clearly defined in implementing procedures? If not,
- explain: .c E. Based on the above, describe any necessary procedure changes or actions which need to be taken.
mue a== N m ens
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
~
- Page 2 of 3 II. Potential Consecuences of Plant Restart With Undetected Weaknesses in This Program.
.,, A. Does the program impact nuclear safety, plant reliability, regulatory compliance, or plant operation? (lf no impact, no further evaluation may be necessary for restart.)
_ If there is an impact, provide reference to Restart List screen.
~
Ill. Program Health and Effectiveness A. What performance indicators exist for the program? 4 i ~ B. Do backlogs exist? If so, are they being adequately managed? How?
~
C. Describe the health of the program and bases for this determination. Consider
, external and internal evaluations within the past 18 months and overall performance indicators. .W w
N b
.=
_ee w --v - e . ,
PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
~
Page 3 of 3 IV. List of Actions Recommended For Restart or Post Restart / Bases for This Recommendation: 4 V. Restart
Conclusion:
Program is adequate for restart. a
-. Program is adequate for restart, but requires long-term improvements, a.
Program is not adequate for restart. a
.: ; j ~
Evaluator Date
~
/ /.
, . - - Department Manager Date
.e
~
%w OaW
- 4 l
l
m 1
- N
_, EERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM n
~
FOCUS PROGRAM LIST Coooer Nuclear Station _ 1. Operability Determinations
- 2. Surveillance Testing /LCO Tracking
- 3. Plant Labeling
- 4. Calibration Program
- 5. Operating Experience Reviews
- 6. Corrective Action Program .
~
- 7. Oversight Programs (SRAB/SORC)
- 8. Assessment (Quality Assurance) n-3 .
',. Industrial Safety . ~
- 10. Records Management
- 11. Radwaste Storage and Disposal
- 12. In service Inspection 41 13. In service Testing
- 14. Appendix J Testing
~
- 15. Check Valves
- 16. Welding -
- 17. Erosion / Corrosion
~
- 18. Snubbers 19, Commercial Grade Dedication ennus
_ PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
-._.. t ~
FOCUS PROGRAM LIST (CONT) Coooer Nuclear Station (cont) - ,_ 20. Shelf Life
- 21. Reliability and Performance Monitoring
- 22. Shift Technical Advisor Program ;
- 23. Ver.dct Manuals !
- 24. Systems Engineering 25.. MIC Monitoring and Mitigation -
- 26. Operability Evaluations i
- 27. Equipment Data File
- 28. Predictive Maintenance .
- 29. Preventative Maintenance
~
- 30. GA Audit / Surveillance Program
-- 31. QA Supplier Audit Prog.am
, 32. Quality Control
- 33. Work Control l O *
,4a M
J
=
aree
i.. _ PERFORMANCE IMPROVEMENT PLAN '- RESTART READINESS PROGRAM
'~
FOCUS PROGRAM LIST
,ttuclear Enaineerina and Construction Division (NECD) ._, 1. Instrument Setpoints
- 2. Equipment Qualification
- 3. Equipment Classification
' 4. Fire Protection - Appendix A/R
- 5. Meter Banding l
.. 6. .
Relief Valve Setpoints -
- 7. Temporary Shielding
- 8. Seismic Qualification
. Design Change Program -
- 10. Relay Setpoints a
- 11. Fuse and Breaker Coordination J 12. Load Studies (AC/DC/DG) 1 13. Pipe Hangers
- 14. MOV Program
- 15. I rm s'istic Risk Assessment
-16. Design Basis .
- 17. Configuration Management M
emme
._ PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
~
FOCUS PROGRAM LIST Trainirla
- 1. Instrument & Control
~
- 2. Mechanical Maintenance
- 3. Electrical Maintenance
- 4. Chemistry
- 5. Health Physics / Radiological Support
- 6. Engineering Support .
~
- 7. Simulator Certification
- 8. Shift Supervisor
'. Licensed Operator Requalification -
- 10. Shift Technical Advisor
- 11. Reactor Operator
- 12. Senior Reactor Operator
. 13. Station Operator W
m* M ene N I
w-, a +- a
-- PERFORMANCE IMPROVEPJENT PLAN '- RESTART READINESS PROGRAM e ,w f
M Y asee
'M4 es.s f'
e,* I tw-- O4 , APPENDIX l- SITE READINESS ASSESSMENT Smee 9 7 90er meses
+
W 'i 1 i
PERFOBMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM Site Readiness Assessment The Management Review Committee shall consider the following in providing its affirmation to the Site Manager. 0 -Organization and Personnel Readiness
- - o Systems Readiness o Department Fwadiness o Outage Closure o Restart List Closure O Post-restart Plans Established
. o Assessments Complete o Other
+,.
9=
~9 n ?'"
H w asem W V ene mes
SITE READINESS ' ASSESSMENT FORM I 1
,, RZLL UP AND REVIEW OF SITE READINESS ASSESSMENTS (Principal Areas to b's Reviewed)-
- Organization and Personnel
- System Readiness
- Department Readiness
- Program Readiness
- Outage Closure
- Restart List Closures
- Post Restart Plans
- Assessments
- Other (Specify)
_ REVIEW AND APPROVAL FOR INITIAL MODE CHANGE MRC REMARKS
~
(MRC can provide any additional relevant information deemed necessary to complete this site readiness review for mode change.) SORC REMARKS (SORC can provide any additional relevant information deemed necessary to complete this site readiness review for mode change.)
~
(MRC Chairman and SORC by their signature will affirm that the above and any other relevant areas have been reviewed and that each supports mode change) -
. MRC Chairman Approval Date SORC Approval Date REVIEW AND APPROVAL FOR SITE CRITICALITY MRC REMARKS (MRC can provide any additional relevant information deemed necessary to complete this site readiness review for mode change.)
SORC REMARKS * (SORC can provide any additional information deemed necessary to complete this site readiness review for mode change.) (MRC Chairman and SORC 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 mode change.) MRC Chairman Approval Date SORC Approval Date i14 94
..wyv
- EERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
. O
-W
+0 0 4-G sq M
d l W m e APPENDIX J - CROSS REFERENCE OF DS,AT FIELD NOTES AND PHASE 1 PLAN eod
- hh 5
M w M M men i l
I
~
DSAT FIELD NOTES NOT INCORPORATED INTO THE PHASE 1 i
, PERFORMANCE IMPROVEMENT PROGRAM FIELD' NOTE
? SUPPLEM' ENTAL INFORMATION b '
de ' WW-27 All WW-25 All ~ WW-21 All WW-20 All WW-15 Guidance on when system lineups should be conducted WW-13 All WW-06 All
._ WW-02 All Phase 2/3 Plans on AOT RB-11 Phase I only covers instrumentation RB-09 Guidance on when periodic valve lineups are required , RB-05 All . DM-09 Phase 2/3 Plans - - RB-02 Phase 2/3 Plans DM 08 Example 5 ,
DM 07 All All
~~
DM 01 DM 11 Example 7 DM-10 Examples 2, 6, Causes 1,3 WW-26 Phase 2/3 Plans SV-23 Examples 1,2,3 Phase 2/3 Plans SV-22 Example 1 and Overall Description SV-21 Example 3 _. SV-18 All SV-16 Examples 2,3,5, Phase 2/3 Plans SV-15 All SV-12 All ! l Phase 2/3 Plans to address rework, work arounds, and increased < SV-07 out-of-service times SV-04 Phase 2/3 Plans I I
'4 DSAT Fleid Nates N11incorporitId..
' Te - Fege t
. FIELD NOTE - SUPPLEMENTAL INFORMATION3 ' ; - $$$f SV-06 All SV-01 Description - Phase 2/3 Plans RC-13 All ~
RC-14 All RC-12 All
~
RC 05 All RC 04 Threshold for what constitutes a DC, and MWR 94-G06 Item RC-02 All WW-18 All WW-03 All except dose assessment model items _
. SE-16 All SE-15 All SE-14 All but QC item SE-13 All SE-12 All '~
SE-09 All
- SE 08 All SE 05 All SE-07 All SE-04 All SE-03 All SE-02 All
- SE-01 All RC-15 TPCN, PCN items RC 10 All RC96 All ~
RC-01 All
- JD-12 All JD-10 All _
JD-09 All
- DSAT Field Nsus Nst incorporttid...
Page3
"' ?J FIELD' NOTE" SUPPLEMENTAL INFORM ATION m .
JD-08 : All JD-01 Examples 1,4,6,8,9,10 Causes 1, 2, 3, 4 DK-06 All DK-05 Exs.mples 2,3 j DK-01.1 Examples 2, 3, 4, 6, 7 DB-01 Phase 2/3 Plans WW-17 Verify captured by DM 09 WW-14 All except for work control /specialinstructions RA-10 Review examples to verify drawing corrections OK ; l RA-09 Examples 1, 2, 3 - RA-08 All RA-05 Phase 2/3 Plans JC-02 All JC 01 All GW-19 Description, Programmatic and Management Phase 2/3 Plans , GW-18 Example 4 - GW-17 Examples 2,3 GW-16 All GW-15 Examples 1,3,5,6,7,8,9,10,11,12,13,14,15 GW-14 All GW-13 All GW-12 All GW-11 All GW-10 Phase 2/3 Monitoring Examples 1, 2, 3, 4. Phase 2/3 Drawing Change Program plans, GW-09 correction of previous deficiencies, etc.
= - GW-05 All e GW 04 All
~
GW-03 All GW-02 All h - * - e-eaw-> -* . - - __ - - - - - + 7 '-- 9 1
4 . DSAT Fleid Notes Not inoerperited...
- page 4
~
d b '- ,'
'c i 1:
- FIELD NOTE i s $ _ JSUPPLEMEATAUINFORM flON)? <
DK-04 System Engineering Monitoring Program CB-21 All CB-19 All EWR Process CB-18 Phase 2/3 Monitoring of Root Cause Analysis process and Implementation of corrective actions CB-17 All
-- CB-16 Narrow focus /complianced based evaluation of genericissues CB-15 All but SIL 564 item ~
CB-14 All
~
Phase 2/3 Action on OER Program
-- CB-13 Ensure specific items listed as examples have been reviewed during recent OER review project Phase 2/3 monitoring of Root Cause Analysis adequacy, and
CB-12 Corrective Acticns correlate with root cause analysis
- CB-11 All i . . ,
Phase 2/3 Plans for OER Program, Post-trip review procedure _ CB-10 adequacy 4 .. CB 09 All ;
~
CB-08 All
+ CB-07 All l Failed or absent barriers, Phase 2/3 assessment and monitoring of l MCB-01 CAP performance, OER Phase 2/3 Plan and assessment of OER
- Program performance :.
-i MGW-01 All of Description MGW-02 All of Description, RHR-MO-27A/B and 34A/B example
! MGW-06 Phase 24.' Plans regarding configuration control
"~
Phase 2/3 Plans regarding design control and example regarding MGW 07 testing of modification to see if it works _ Phase 2/3 monitoring and assessment of issues listed MCB-02 MJD-01 All ,
~
MJD-02 All MJD 03 All except example 4 l
- i' MJD 05 Phase 2/3 assessment of NPG's ability to execute plans
._ - . . .___._..m._ ._.
- __ - _ .~. -. - . _ _ ~ . . _ _ _ _ .
-s x
ESAT Fleid Notes Not incorpor:ted... ; Page5
^'
1FiELDiNdTEN ' ISUPPLEMENfdl/iNFORist TidNibdis Ehdh5N N-MJD-06 All MJD-07 Phase 2/3 Plans of independent oversight MJD 08 All ~~ MJD-09 All MSV-05 Phase 2/3 assessment of description MRB-01 Phase 2/3 Plans and assessment of work control program Phase 2/3 assessment of the quality of Maintenance work MSV-01 activities Phase 2/3 Plans to resolve inadequacies in station procedures and MSV-02 instructions : MSV-03 Phase 2/3 Plans to resolve long standing equipment problems' Phase 2/3 assessment regarding compliance with established MRB-02 programs and procedures 3 MWW-03 All i WW-17 Examples 1, 2, 3 - RC-04 All
~~
DM-10 Examples 2,6 . ] SV-01 l All Examples RA-09 Examples 2,3
-' GW-17 Example 2 DK-04 Example CB-07 Example l CB-13 All 7
l-- GW-14 Examples 1, 2,3 GW-15 Examples 1,3,5,7,9,10,11,13,14,15 MGW-02 MO-27A/B, MO-34A/B Example j MCB-02 Example 4, item d WW-16 Closed out by DSAT Team v WW-10 Closed out by DSAT Team WW-11 Closed out by DSAT Team i WW-09 Closed out by DSAT Team
N DSAT Field Nitee Nit incorpit:ted... ~, Page 6 _. - FIELD NOTE: SUPPLE'ME'NTAdlNFORM'ATION " liS@fD #'M WW-08 Closed out by DSAT Team WW-12 Closed out by DSAT Team RB-07 Closed out by DSAT Team ~ WW-01 Closed out by DSAT Team esse se r 64
'4 am S
-em.#
~
j 1 l
^ .1 M
m-k w h M# ese l
F.',- 4 g? _ : PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM n. no W [*.- m
?
em i 9' 94' ames
%M m
*W gg
_. APPENDIX K - EMERGENT ISSUES FLOWCHART was
?'
I W G eMe l l 1 m l
m i I I I i I e i ; I ; ' _d 1 f i i 1 :
~1 - .l . .c :
( ! .' r , EMERGENT ISSUES t ; YES Item Owner Ops Review YES YES Emergent item s item MWR Submit For for MWRs - CRG Identified by - JCO or CR? Restart Reviews Restart Call Dept. Manager Evaluation for CR & JCOs NO NO p
, DEPT. MGR. ,,
NO Evaluator Provide Dept. Mgr Determine Priority . Restart Work. Bring Restart to MRC Recommendation for Review. If Post-Restart, include in Post-Restart Backlog Eval and Schedule. ,,
,, MRC Concurrence YES Post Restart Input to input To Dept Restart System . .
Readiness Schedule Readiness ___.____________._.________m _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ _ w
C ., e PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM
.- ~?
..O e==
e L
-em W
W
$*e e n
een h
-yr 4
- APPENDIX L - MAINTENANCE WORK REQUEST SCREENING N
p-M w h M
==
mad m - -- - - - - - - _-- - - -
t I. ; I I t i J A.i i .1 1 1 i 11 . 't I l J I . i : ? 'I h eo
-( '
.' ')
WPMC SCREEN - r , EWRs & DCPs > STARTUP PLAN CNS RESTART OUTAGE MODS WORK t SCHEDULING ; NEW ~ EQUIPMENT RELATED CRs RE-REVIEW ALL NON A/B/C MWRs ADD CATEGORY SCREENING ,r . A WORK TO PERFORM WORK (OPERATIONS) ' MEETING - > TRACK TO MM STARTUP SCHEDULE COMPLETION a REVIEWALL NON A/B/C CRs NON-MWRs ,
,r .
+
ASSIGN DUE CATEGORY B/C EXISTING CRs DATE TO NON AVAILABLE TO NOT LEVEL 4 OR MWR CRs WORK 5 SCHEDULED OUTAGE ACTIVITIES NOT - PRIORITIZED A/B/C _ _ _ _ _ _ _ _ _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - -}}