ML20083M040

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Rev 1 to Restart Readiness Program
ML20083M040
Person / Time
Site: Cooper Entergy icon.png
Issue date: 01/20/1995
From:
NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20083L862 List:
References
PROC-950120, NUDOCS 9505190091
Download: ML20083M040 (79)


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COOPER NUCLEAR STATION

-. RESTART READINESS PROGRAM

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January 20,1995 (Revision 1)

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q APPROVED BY:

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. INDEX

l. PURPOSE / DESCRIPTION ll. HISTORY lil. 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 Vill. SELF-ASSESSMENT A. OBJECTIVES
1. CONDUCT OF SELF-ASSESSMENTS j
2. READINESS REVIEWS

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IX. OA OVERSIGHT M

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_ INDEX (CONT)

APPENDICES A. PHASE 1 CLOSEOUT

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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

1. SITE READINESS ASSESSMENT

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J CROSS REFERENCE OF DSAT FIELD NOTES AND PHASE 1 PLAN K. EMERGENT ISSUES FLOWCHART L. MAINTENANCE WORK REQUEST SCREENING (OUTAGE WORK ITEMS) ,

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  • PERFORMANCE IMPROVEMENT PLAN RESTART READINESS PROGRAM
1. 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 improvement Plan (PIP) Phase 1 Action items,

- Diagnostic Self Assessment Team (DSAT) findings, NRC Special Evaluation Team (SET) Inspection findings, NRC Confirma'ory Action Letter (CAL) closecuts, and NRC Restart Panel conclusions regarding activities that will provide an objective basis for restart readiness. The results of each of these 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 prior to plant startup. Many of these significant issues have been identified in documents 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 closecut. NPPD considers all Phase i 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 documente'd 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 essential management actions that will 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 l involve activities with planning cycles from one to several years. Phase 3 activities

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are focused on fundamental improvement strategies and long-term deficiency l recurrence control.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM r

11. HISTORY The following provides a brief chronology of significant events that are relevant to current restart readiness activities. These events have contributed to the basis for why certain restart 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 Confirmatory 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

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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 l

PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM 111. DEFINITIONS A. Emeraent Work All new work items that occur after Integrated Restart List issuance; and therefore, have yet to be restart screened and scheduled for completion.

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 J

ltems 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. Startuo issue i 1

l An item assigned to a responsible manager for closecut (prior to plant restart). l These issues are maintained on the Summary or Integrated Restart List. l l

F. Final System Readiness Review

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l The process whereby System Engineers ensure the readiness of their assigned system by reviewing appropriate documents, restart criteria, field walkdowns, and other outstanding engineering / hardware issues.

G. Department Readiness Review I 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.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM

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H. Licensina Reaulatory Closure Verification by Licensing that all restart actions required by NPPD and the NRC have reasonable documentation and bases.

l. Proaram Readiness Review t

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 Managt.nent 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 improvement Plan A three phase document that summarizes processes, methodologies, and bases l for enauring that performance at CNS improves.

L. Responsible Manaaer The manager who is accountable for ensuring that a restart issue is satisfactorily completed. ,

1 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 nanagement 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.

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  • PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM B. Plant Manaaer Principle 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 acco'untable 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 closeout presentation tar the MRC.

V. RESTART READINESS PROCESS s

- 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 closeout 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 closecut 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 close' ., 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. ,

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM VI. PHASE I CLOSEOUT Closecut 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 closeout, 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 PIP are:

e independent Oversight and Self-Assessment: roles and responsibility of SRAB, SORC, QA and QC and organizational self-assessment.

  • 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.
  • Design Control and Configuration Management: plant design change

- control, clearance program, valve lineups, and drawing control.

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rW4 PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM ra e Engineering Support: roles, responsibilities, and support to operations and maintenance.

  • Plant Testing: IST, surveillance, post-maintenance testing, and preconditioning.
  • Operational Experience Review (OER).

e Procedural Control: technical quality, procedure changes, and procedure

- adherence.

  • 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

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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
  • 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 Appendix D. Specific restart item identification builds upon the same _.

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screening criteria utilized in the Phase 1 Plan. The screening criteria are repeated below for convenience.

Level l Screenina Evaluation:

lssues were evaluated to identify potential safety or operability concerns.

These issues were automatically categorized as restart items.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM v

v 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 any of the folinwing 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:

an event, component failure, deficiency, or condition that could result in e

operation in an LCO Action Statement, or e failing to perform a required surveillance test or other license requirement or 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

  • conditions that have resulted in repetitive safety system equipment failures, or
  • potentiallicensing basis deficiencies requiring maintenance to restore to conforming conditions (i.e., deficiencies in safety-related or other

__. - ' qualified equipment, e.g., EO, Appendix R, or seismic), or

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  • potential design basis deficiencies, i.e., deficiencies in safety-related

- equipment or other technical specification equipment not in conformance with the USAR, or

  • deficiencies in configuration management programs, processes, engineering analysis cooes, 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.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM i n B. Development of the Outaae 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 ccntain other maintenance activities that

.. satisfy at least one of the eight Level 11 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. Closeout Documentation The Responsible Manager for each Summary Restart List item must maintain the master set of documentation for issue closecut. The following closecut 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

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format: i A. Summarv:

o Explain why issue is closed / objectives satisfied.

B. Closecut Acti.ons:

e Actions taken to closecut each Action Plan step.

  • Why actions envelope the " extent of condition." ..-

C. Results

  • Performance Improvements in general.
  • Any measurable indications / examples of improvement.

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D. Follow-uo Actions

  • Actions to ensure continuation of improvements.

Attachments: Supporting documentation verifying closure of each Action Plan step.

1. Index

- 2. Action Plan j

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.

.- Self-assessments will determine the readiness for restart and therefore, better ensure l successful subsequent operations. Structured self-assessments will be performed for Department Readiness, Program Readiness, and System iReadiness. This is

- accomplished through the conduct of pre-milestone and periodic management

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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 Se . nelf-assessments will be conducted which will achieve the following objeci .

  • Ensure 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,

  • Ensure that significant performance or other emergent issues identified during the outage are resolved satisfactorily, 5

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1 e Define a path for continued performance improvement through linkage of assessment results that are appropriate for longer-term resolution in I the Phase 2/3 Performance improvement Plans. l i

1. Conduct of Self Assessments i

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 performancc improvement as a way of doing business and must create the change mechanisms that will improve performance and sustain it at a high level.

i The MRC will review self-assessments to ensure that the following issues are addressed:

e A vision of required organizational performance, clearly stated and shared by the organization.

o Ownership and accountability by organizational membra to achieve the objectives through managed improvement. For exan; pie, the Phase 1

.- Plan assigns responsibility and accountability to action plan managers for completion of necessary improvement activities.

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_ 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.

a. System Restart Readiness 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

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safe and reliable restart and full power operation. The objective is to assess collectively and document system readiness from a hardware standpoint, to support

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management restart decisions, to reinforce ownership for v system performance and improvement with system 13

PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM m

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, surnmarizes applicable criteria, and '

provides the form that will be used.

As discussed in the Phase 1 Plan, the process requires both an initial multi-disciplined assessment of system status and

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a final assessment and affirmation (signature) by the

_. 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 assess material condition.

Specific emphasis will be placed on systems that are safety significant and important to plant reliability. Walkdowns at

_v system operating temperature and pressure will be conducted as appropriate to confirm appropriate system

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restoration. i

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  • System engineers will confirm 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.
  • System readiness assessments will be reviewed by the system engineer's supervisor, SORC, and 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

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of site readiness. l l

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'b. Department Restart Readiness

  • Prior to restart, managers responsible for each major l 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 personnel / management capability are sufficient to support

- safe and reliable operation; ensure that post-restart work and improvement efforts are sufficiently defined, prioritized, scheduled, and controlled; and ensure that appropriate post-restart assessments and monitoring processes are in place.

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  • This assessment process is complementary to the individual program assessments described in Section Vill.A.2.i of this program. The process for conducting these departmental assessments incorporates input from program assessments under the department's responsibility and other assessment areas. Other areas include completion of assigned restart

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~ actions, organization, personnel and management capability, post-restart work and improvement efforts, and post-restart assessment and monitoring processes.

a e Final department and program readiness affirmations will be presented by the assigned manager to the Management

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Review Committee. The compilation of these reviews form

- one of the principal bases for determining the station's readiness for restart.

  • The checklist to be used by department managers to l complete the self assessment of their departments prior to restart also is provided in Appendix F. This checklist is open-ended in that the questions for each principal area of 1 assessment are intended to be explored to the extent necessary to determine that the affected area is acceptable

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for supporting the startup objectives and, as appropriate, that additionalimprovement actions are identified for post- l startup implementation. Some of the actions specified and

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areas to be reviewed are not applicable to all departments (e.g., startup shift staffing), and should be disregarded if not applicable.

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c. Proaram Readiness Assessments Specific guidance for program restart assessments was provided in a December 9,1994, memorandum to Program Managers. A general description of this guidance is provided below.
  • 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 readiness affirmations.

Past problems with programs at CNS resulted, in part, from unclear ownership, process contro! . weaknesses, and

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technical program inadequacies. This program assessment is an important element of CNS performance improvement in that each program owner must establish clear accountability and responsibility for his/her programs. To ensure a consistent, thorough method of assessing site

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programs, specific assessment guidance has been developed (see Appendix H). This guidance and the list of programs that will be assessed are provided in Appendix H.

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  • Program owners are expected to provide periodic summaries of identified program weaknesses from internal and/or external evaluations, trending, and corrective action

- documents. Results of these assessments should be

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documented and recommended actions will be evaluated by

, the MRC for restart implications and/or appropriate long-term enhancements.

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d. Site Readiness Assessment
  • 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 closcout/dispositiortof.all.

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restart list items, the review of organization and personnel adequacy and other input from personnel and management.

See Appendix l.

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e The MRC will review and evaluate both the individualinputs

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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 Nuciear. 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 vehicle 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. ]

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 '

l ensure that review briefings are scheduled, assist in clarifying assessment processes and requirements, and track and assign further assessments (or other actions) which ,

may evolve from management review of the results.

IX. QA OVERSIGHT Independent oversight of the Restart Readiness Program will be conducted by the Quality Assurance Division throughassessments of selected Phase 1 Action Plans, scheduled audits, and specific evaluatiens of significant emerging issues. Audits in progress and scheduled will emphasize evaluation of identified and potential areas of l

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weakness within the scope of the respective audit. Assessments and surveillance l activities will be planned and implemented to focus on evaluation of field performance

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and operational activities executed to correct identified deficiencies and prepare the plant for return to safe power operation. )

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NijCLEAR POWER GROUP PHASE 1 PLAN CLOSEOUT REPORT PURPOSE AND SCOPE

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NUCLEAR POWER GROUP PHASE 1 PLAN CLOSEOUT REPORT PURPOSE AND SCOPE The purpose of the Nuclear Power Group Phase 1 Plan Closeout Report

("Closecut 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 numarous 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, 4

p.ogram/ 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 i Action j ltem List. Lists of the three sets of issues are included in Enclosures 1, 2, and 3, below.

. - The Closecut 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

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purpose of the assessment is to determine whether the issuessset 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.

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The Closeout Report will be structured first, to describe the purpose,

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development, and scope of the Phase 1 Plan. An assessment of the actions taken at CNS to closecut 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 Lists will be available in matrices found in i 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 pian step -- will be available for review at CNS.

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4 PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PCOGRAM ENCLOSURE 1 l

l PHASE 1 ACTION PLAN Action Plan

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1.1 Revise the SRAB Charter; Address Member independence and Revise i Membership ,

I 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

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4.1 Plant Configuration Verification (1 of 2)

Plant Configuration Verification (2 of 2)

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4.2 Identify and Review Priority Vendor Manuals 3

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4.3 NED Review of Procedures and DCNs to Ensure Configuration Control l l

l 4.4 Efficient Resolution of Design-Basis Questions 1

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_ 4.5 Surveillance Procedure Adequacy

__ 4.6 SORC Approved MWRs and Subsequent Design Changes 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 Pre-Conditioning 6.1 i 6.2 IGT and Surveillance Testing 7.1 Startup Experience Following Extended Outages 7.2 Open OERs 7.3 Reactor Vessel Thermal Transient 8.1 Develop Procedure Hierarchy to Identify Controlling Procedures 8.2 Special Instructions N

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM 3

8.3 Screen Backlog 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

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Observations 9.4 Industrial Safety

.a 9.5 Licensing Submittals 9

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM g

ENCLOSURE 2 MATERIAL CONDITION ISSUES The following list of material condition issues can be found in Appendix B of the Phase 1 Action Plan:

  • Low pegging of RHR HX divider plate indicators dua to plugging.
  • 111 Type 2 and 827 Type 4 open items; 2400 discrepancies unresolved (tagging, labeling, physical repairs, procedure revisions).

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  • 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).

_- minimum flow valve that indicated closed but was not fully seated.

  • 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 Vessel !evel injection 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

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Mechanical Vacuum Pump from the MCR.

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PERFORMANCE IMPP.OVEMENT PLAN - RESTART READINESS PROGRAM j m l

  • 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).

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  • 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.

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  • Installation of SCRAM discharge level transmitters with improper bolting.
  • During B Loop shutdown cooling, flow turbulence caused "chuggin0" sounds in vicinity of HX bypass valve, RHR-MO-66B.

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  • Failure to test or maintain essential relays on a ;egular 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.

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  • Possible cavitation noise at water box south of downstream of RF-28MV.

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  • Excessive failures of LLRTs on one valve without apparent root cause or detailed evaluation.
  • Approximately 250 terminations require repair.
  • 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

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impeller clearance on "A" service water pump not in accordance with vendor specifications.

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  • Fuel pump (5L, #2 D/G) replaced using special instruction that did not include torquing of bolts.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM

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  • Degraded condition.of MO398 RHR MOV is not identified in the MWR system. Operability Determination No. 94-50 identifies installation of 250V control relay in place of 125V control relay for Auxiliary oil pump on HPCl pump.

- undersized relief valve on the EDG starting air system (DGSA-RV-15RV).

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  • The plant's corrective action did not include checking other motor boltings on the three remaining RHR pump motors.

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EERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM ENCLOSURE 3 PHASE 1 PLAN ACTION ITEM LIST The following items are delineated in Appendix A of the Phase 1 Plan:

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  • 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 action 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).

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  • Determine whether action is necessary to ensure technical adequacy of design changes.
  • Ensure that specific issues are addressed in revised clearance order program: (1) non-operators operating equipment; (2) pull-to-lock protection use; (3) overriding danger tags; and, (4) independent verification.

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, 1 Appendix B CNS READINESS REVIEW PROGRAM t >

Issue Poal

System Phase 1 PIP Readiness CAL Assessment DSAT . Add To Restart Restart issue SET MRC Review = "

List Closecut NRC-IRS Program CAP 8 Readiness Self Assessment Assessment CNS Management "

Employees Second Level Department Screening --. Readiness Assessment I I include in Phase 2 or 3 7 1r Quality Power Assurance Site Site Readiness Site Manager :p Restart

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Ascension Plan Readiness Review (MRC)

Approval implementation Assessment u

NRC Restart .

NRC Oversight Panel Review

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SUMMARY

RESTART LIST 4

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- COOPER NUCLEAR STATION

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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 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 improve independent oversight ability of SORC to ensure that an appropriate review is performed for all proposed additions, deletions, and changes to safety-related activities.

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Enhance the process utilized by SORC to ensure sufficier;t independent oversight is maintained.

3. Independent Assessment of Startup Action Plan, Confirmatory Action Letter, Condition Reports 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

1. Provide increased consistency in the application of QC requirements.
2. Provide increased QC inspection for additional activities.
3. Impose limitations on the amount of persons reviewing and specifying QC requirements.

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SUMMARY

RESTART LIST - November 3,1994 Page 1

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, 4. Coach / counsel QC personnel on new program requirements.

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5. Corrective Action 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 / Monitoring To develop management tools to obtain and monitor challenging goals for key station performance indicators.
7. Establish and implement a plan for integrated work control, planning, and scheduling Correct existing deficiencies in work package content, work coordination, and daily scheduling through implementation of a work process improvement plan.
8. Implement offective LCO tracking and work coordination interface system improve tracking of technical specifications-related equipment that is out of service to limit challenges to safety systems caused by work coordination problems. ,

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9. Plant Configuration Verification (1 of 2)

Determine if the standby alignment of the plant safety systoms is properly specified such that, if called upon to automatically initiate, the systems will meet  ;

their design objectives.  !

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10. Plant Configuration Verification (2 of 2) l l

Perform valve, switch, breaker, and damper lineup walkdown and initiate i corrective action for discrepancies.

11. Identify and Revisw Priority Vendor Manuals j Determine if the backlogged safety-related vendor manuals / vendor manual changes and certain non-safety related vendor manuals / vendor manual changes have recommended PMs that should be addressed prior to startup.

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SUMMARY

RESTART LIST - November 3,1994 Page 2

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%. L12. ~ NEC review of procedures and DCNs to ensure Configuration Control

.. Provide mechanisms for assuring that changes to configurations reflect. station design. This includes strengthening review of drawing changes and specific procedures.

13. Efficient Resolution of Design-Basis Questions Provide a more efficient method of responding to . design basis questions and identifying design basis information and upgrade the quality, detail and accuracy

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of 10CFR50.59 evaluations before they are submitted to SORC for review and approval.

14. Surveillance Procedure Adequacy Complete omveillance procedure validation for CSCS and RPS.
15. SORC Approved MWRs and Subsequent Design Changes >

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,

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16. Inadequate Calculation Control Prior to implementation -

Ensure calculations that are approved prior to the associated field modification / implementation are appropriately identified. i

17. Multi-discipline Team System Reviews 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 critc 1 systems prior to startup.
18. Improve NED Site Support during Startup and Power Ascension l Provide a coordinated review of the NED/CNS Engineering functions and

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4 interfaces related to startup and power ascension, and develop an upgraded l

,. interface agreement better defining work function, and responsibilities

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Provide augmented NED on-site support for CNS startup and power ascension activities.

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RESTART LIST - November 3,1994 Page3 l

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19. .OD/OE Review

~ q Review ODs and OEs for degraded and nonconforming conditions that currently  !

- exist and assess startup significance. i 1

20.  ; Pre-Conditioning  !

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- Complete resolution of the CAL pre-conditioning issues.

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21. IST and Surveillance Testing
1. Verify IST program scope and testing adequacy by constructing the basis for component IST requirements and identifying discrepancies, t
2. Conduct an evaluation of[ types and numbers of] surveillance tests I performed to determine program adequacy.
22. Startup Experience Following Extended Outages Conduct special operating experience search for startup issues following long  !

shutdown. i

23. Open OERs Evaluate current open OERs for startup significance. i

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24. Reacter Vessel Thermal Transient

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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 procedures -

Identify all procedures which control and take precedence over other procedures.

Screen lower level procedures for compliance with controlling procedures.

26. SpecialInstructions

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Develop procedural controls and methods that ensure work performed using l Special Instructions is performed at a quality and safety level consistent with that '

of existing SORC approved procedures.

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SUMMARY

RESTART LIST - November 3,1994 Page 4 g a g-a.m-r- - - S wi *----e-

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._ 27. .

Screen backlog of procedure changes.,for significant items for start-up

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Identify all in-process procedure changes requiring approval prior to start-up or early in start-up sequence and ensure entry into tracking system.

28. ADAM Changes 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 ellowed outage times -

Provide administrative controls for allowed out-of-service times for Technical Specification surveillances.

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30. Resolve the lack of program ownership in the NPG Establish effective ownership for programs which affect reactor safety.
31. Nuclear Safety Awareness Strengthen the NPG nuclear safety culture and establish high standards of safe, reliable nuclear plant operation.
32. Management Observations - Field Coaching Team Plus Management Observations increase Management and Supervisory involvement in the field in order to:
1. Assess station material conditions  !

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Assess compliance with established radiological and industrial safety work practices

3. Assess compliance with station work documents
4. Coach and mentor personnelin the field
5. Re-enforce management's expectations and standards in the field

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6. Improve organization communication channels w'

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SUMMARY

RESTART LIST - November 3,1994 Page 5

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y 33. Industrial Safety ,

One of the major objectives of the District is to hrotect its employees and'the public from accidents. Whenever economically possible, the District will eliminate

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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 Development of internal procedures and practices that assure that all licensing submittals contain accurate information and that all commitment made to external agencies are completed on time. ,

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RESTART LIST - November 3,1994 Page 6

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM

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APPENDIX D - POTENTIAL RESTART ITEM EVALUATION FORM i

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RESTART WORK ITEM ADDITION BASIS CHECKLIST RESTART ITEM IDENTIFIER:

Ch ck the basis for adding the item to the Restart List. The absence of a mark indicates that the item should not j be added to the Restart List. If no criterion is satisfied, this form still must be completed and signed by the Rzsponsible Manager.

1 Level i Screenina Evaluation:

Issues were evaluated to identify potential safety or operability concerns. These issues were automatically categorized as restart items.

Level Il Screenina Evaluation:

Issues that were not categorized as restart items during the Level I screening evaluation must be reassessed to determine if there are other reasons for considering them restart items. Satisfying any of the following criteria i qualifies the item as a restart item.

If an event or finding involves or could reasonably lead to:

an event, comportent 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 s

failure of power production equipment that could 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 i specification equipment not in conformance with the CNS USAR, or

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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 dischargo effluent to the environment which is in excess of regulatory limits.

Based on the above, the issue should /should not be added to the Restart List.

' ~ 9creened By Date Responsible Manager Signature Date

7 RESTART WORK ITEM ADDITION / DELETION FORM

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Retain Add Delete

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RESTART ITEM IDENTIFICATION: RESTART ITEM OWNER (RESTART LIST #, WORK DOC.#, SYS, ETC.)

ADDITION / DELETION INITIATOR

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ITEM / WORK DESCRIPTION:

REASON FOR ADDITION / DELETION:

-- _. EVALUATION:

Cognizant System Engineer / Supervisor Signature Date

-or-Cognizant Manager Signature Date MANAGEMENT REVIEW COMMITTEE (MRC) APPROVAL MRC Approval Signature Date For Group items, list all applicable documents:

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM

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- APPENDIX E - SYSTEM READINESS ASSESSMENT M

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PERFORMANCE 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.

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PERFORMANCE IMPROVEMENT PLAN . RESTART READINESS PROGRAM

_ FINAL SYSTEM READINESS REVIEW CHECKLIST SYSTEM NAME: SYSTEM ENGINEER SYSTEM ENGINEER REVIEW

SUMMARY

(The System Enaineer shall initial each item below to confirm that reviews are complete.)

All multi-discipline review items have been dispositioned.

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Identify and disposition items that have emerged since the most recent multi-disciplined review.

MRC-approved restart items have been completed or appropriately dispositioned.

Identify system MWR and CR backlogs and address / discuss cumulative effects.

Perform final system walkdown to EOl 93-01.

Document results and initiate process to followup on significant findings.

REMARKS (The System Enaineer can provide any additional relevant information deemed scessary to provide a comolete summarv of system readiness -- provide continuation sheets as necessarv.)

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ENGINEERING MANAGEMENT REVIEW & APPROVALS Supervisor Signature Date Engineering Mgr. Signature Date COMMENTS:

MANAGEMENT REVIEW COMMITTEE (MRC) APPROVAL MRC Chairman Date l

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P_ERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM T

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Critical System List i v5

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM Critical Systems List

1. Service Water
2. Control Rod Drive a 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 Gr.s Treatment
14. Reactor Equipment Cooling
15. Primary Containment Isolation System
16. Reactor Protection System
17. Heating & Ventilation (Essential)

-18. Standby Liquid Control

... .9. Neutron Monitoring

20. Automatic Depressurization
21. Radiation Monitoring i

.. 22. Turbine Generator Controls >

23. Switchyard ee.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM T

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.

Acolicability

  • Site Manager direct reports and their direct reports.

Plant Manager

  • Manager, Engineering

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  • Manager, Operations

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  • Manager, Maintenance
  • Manager, Radiological
  • Manager, Scheduling Senior Manager of Safety Assessment
  • Manager, Licensing

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  • Manager, Events Analysis s
  • Manager, Nuclear Safety Support Senior Manager of Site Support
  • Supervisor, Security
  • Manager, Site Services
  • Manager, Nuclear Training
  • Corporate Division Manager of Nuclear Engineering and Construction Division Manager, Nuclear Engineering and Construction
  • Manager, Nuclear Engineering

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RESTART READINESS PROGRAM DEPARTMENT READINESS ASSESSMENT

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Department Manager:

-- IRG Review:

MRC Approved:

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM DEPARTMENT RESTART READINESS ASSESSMENT CHECKLIST Assess the current management and organizational structure. Assure that the organizational responsibilities, functions and interfaces are adequately defined, necessary training is completed, and appropriate communication of startup objectives, Restart Readiness Program and the Startup and Power Ascension Plan has occurred. Determine if there are any changes required to support startup. Describe long-term plans for organizational improvement.

Assess the backlog of outstanding commitments to assure that startup objectives can be met. Assure that all assigned restart items have been verified as completed.

Complete the review and evaluation of the program assessments assigned to your department. In the aggregate, determine if there are any deficiencies or other performance results from the program assessments that would prevent achieving the ,

startup objectives.

Review past performance trends from an assessment of the corrective action program results. Review open and closed condition reports that are associated with the department and assess their generic implications on performance as it might relate to achieving the startup objectives. Determine if the condition report backlog has been correctly characterized and is being managed to closure in a timely manner.

If applicable, assess the adequacy of snift staffing plans to support the Startup and

._ Power Ascension Plan.

Determine the current workload and management capability. Determine if the post-restart workload is adequately characterized, prioritized and scheduled. Determine if appropriate performance monitoring processes are in place and periodic assessment established.

Describe any longer-terrn, departmentalimprovement actions. Describe plans for conducting post-restart assessments.

Who are the " customers" of the department? What mechanisms are in place to assess how effectively the department is meeting its needs. By polling department " customers,"

determine how effective these mechanisms are in providing feedback (i.e., what do customers say versus that the feedback mechanisms are saying). What enhancements are planned to improve inter-departmental communications with customers.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM DEPARTMENT ASSESSMENT READINESS CHECKLIST (cont)

Specific organizations are to include in their self assessments the following activities to support startup as indicated:

Ooerations Evaluate the adequacy of surveillance test scheduling to ensure there are adequate checks, responsibility assignments, and controls such that all required surveillance tests are completed.

Ensure that the startup schedule is available and reasonably sequences activities necessary to support plant startup.

Assess outstanding equipment clearances to ensure that there are no outstanding operability issues.

Evaluate the nature and extent of any operations issues, including a backlog review of maintenance, engineering, and temporary modifications. Evaluate the potential for these to impact the objective of an error-free start-up.

Maintenance Evaluate post-maintenance tests, plans and schedules to ensure that tests are completed successfully during startup.

Events Analysis Determine the status and acceptability of operating experience review for any unresolved SOER and OER issues.

Licensina Review the outstanding external commitment assessment results to determine that all

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appropriate items have been resolved.

Trainina and Operations Evaluate simulator training results for operating crews for startup.

sttach this checklist (completed) to the Department Restart Readiness Management Verification

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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.

Exceptions:

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Program:

Program Owner:

Program Manager:

Program ID Number:

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Independent Review Group Recommendation:

. O Requires Restart Assessment O Requires Post-Restart Assessment

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O Acceptable At This Time IRG Reviewer:

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l PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM INITIAL PROGRAM ASSESSMENT & SCREENING l l

PROGRAM: OWNER:

- When completing the initial program self-assessment screening' or the more detailed self-s:sessment, it is important to provide the appropriate level of information. One word answers

- cro inadequate, and pages of detailed descriptions are unnecessary and not required. The following paragraphs are intended to provide the program owner with sufficient guidance for the program review documentation. Throughout the self-assessment processes, emphasis should bs placed on program impact on CNS restart criteria. Obviously, the expectation is that all CNS 7 prcgrams will eventually achieve and maintain a recognized level of excellence. However, the first step in meeting that objective is to recognize current deficiencies and prioritize actions to cddress the problems uncovered. The program review process will help in identifying the dsficiencies, focusing on the impact to CNS restart will assist in establishing the priorities.

If the conclusion reached by the program owner is that the program status supports CNS restart, substantiated by the logic and rationale associated with the answers to the following qusstions, the program will not need a more in-depth self-assessment process outlined in the

'ollowing discussion. The program will be reviewed by the Management Review Committee to

- alidate the status and assure adequacy to support restart.

Ths program manager should docurrent the conclusions from the assessment in the format of

- ths following individual sections. TFe completed assessments will be retained by CNS as appropriate for review and assessmant by QA and the NRC.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM T

INITIAL PROGRAM ASSESSMENT AND SCREENING A. Describe the Program and Scope.

Why is the program in existence? Is the program mandated by regulation? Is it referenced or found in Technical Specifications, USAR or other licensing base documents? If the program isn't based on

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iegulation, what is the basis for its existence? The important aspect is for the owner to understand the overall purpose of the program and have the ability to articulate that understanding in the terms of describing the primary objective or mission of the program.

Explain the program impact on nuclear safety. Does the program have a regulatory compliance impact?

Explain how the program impacts operations. Those programs with strong ties to plant operation should receive increased attention and scrutiny. In answering this question, the impact on plant reliability should be considered.

Describe the changes in the program, including those resulting from the Phase 1 Performance improvement Plan, DSAT, SET, or other evaluations.

B. Describe the performanca indicators for the program.

How is the success of the program measured? What data and performance indicators are available? Are they consistent with industry standards? Are the indicators complete and comprehensive, i.e., do they provide the true picture of program performance? How are these performance indicators used to determine the status of the program? Consider recent trends. Describe any actions taken based on the information

-- / and analysis associated with performance indicators? What type of feedback loops have been constructed to assure the actions taken are effective? (Questions C through F address perforrnance indicators from

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external organizations), i

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C. Has this program been the subject of any NRC inspection or INPO evaluation during the past 18 months? If so, what were the overall results?

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Has the program been the subject of an NRC inspection, a routine NRC resident report or the subject of a

. . , special inspection? All pertinent external evaluations during the past 18 months should be included. If the NRC or INPO has looked at this program over the past 18 months, what were their conclusions? What was done to the program as a result of these findings? What has changed (positive or negative) regarding the program since the time of the inspection? Do the external results correlate with internal results? If not, can they be explained or the differences justified?

D. Have any NRC Notices of Violations (NOVs) been written on this program over the past 18 months? If the answer is yes, describe the number and their relative significance

_ usin0 the NRC rating system and your own words.

Explain the relative significance of the violations. The response to the NOV is a source of this information along with your understanding of the program status at the time of the violation.

E. Have any industry experience notifications pertaining to this program been received during the past 18 months? Summarize the responses to these notifications.

w Has the program been the subject of an NRC Information Notice, Generic Letter, or Bulletin. Has the program been the subject of INPO SOERs or SERs. Has the operating experience review program provided any adverse performance input applicable to this program? Are there any known industry notifications i

pending on this program?

PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM n

INITIAL PROGRAM ASSESSMENT AND SCREENING (cont)

F. Have any Condition Reports (CRs) been written against the program within the past 18 months? How many remain open? What does the CR process tell about the program?

The number of Crs has a bearing on program performance, but the number alone is insufficient to tell the full story. What are the relative ages of the Crs? What is the breakdown of categories (significance)?

How are Crs being managed? In the aggregate, what does the CR process indicate about program adequacy?

G.. Provide your assessment of the overall status of the program?

Given all of the information compiled above, how would you rate the current program adequacy. This should be done in terms of adequacy to support CNS startup, and in terms of adequacy relative to successfully accomplishing the program's primary objective. The base criteria defining adequacy are

- contained as the restart critoria in the Restart Readiness Program. Would you conclude that this program's status is adequate to support restart of the Cooper Nuclear Struion? Provide sufficient logic and details to support your conclusion. You will be expected to review your position with the MRC.

Ccmments:

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Program Owner /Date: /

"Rasponsible Manager /Date: /

Reviewed by MRC/Date: /

PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM I T  !

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DETAILED PROGRAM SELF-ASSESSMENT PROCESS

- l This process is implemented when the results of the initial self-assessment screening process discussed above, requires additional, detailed self-assessment to confirm restart readiness or

_ d termine necessary compensatory actions. The answers to previous screening questions are  ;

used as a starting point for further self-assessment. The objective is to determine acceptable  :

program standards, current program status, actions required prior to startup, and longer-term l

__ p:rformance improvement issues.

This self-assessment process is expected to result in a short report (5 - 10 pages) that includes e description of the actions that have been taken to bring the program to a level of adequacy l l

that supports CNS restart.

- The department manager should document the conclusions from the assessment in the follow:ng individual section format. The completed assessments will be retained by CNS for future reference.

A. List the current industry standards (or other criteria) against which the program should be measured? l It is important to understand the criteria and standards used by the industry to determine program success.

l Standards may be found in reference material, including material from INPO, EPRI, the NRC and CNS

._ licensing documents. The standards need not be exhaustive, but they should provide the program owner with a high confidence that they are appropriate for the purpose.

B. Describe any current program performance deficiencies, concentrating on how the program is not meeting the above standards or criteria.

Use the initial program screening efforts to determine the set of problems and/or program shortcomings that led to the conclusion that the program was not adequate to support CNS start up. is the list

- complete? Are there other program issues that need to be considered? How can we be sure all significant program deficiencies have been identified? Address people, process and management system deficiencies that relate clearly to shortfalls in performance.

C. What are the causal factors or root causes associated with program deficiencies?

Corrective actions cannot be adequately constructed until there is an understanding of the underlying causal factors or root causes. In this step a root cause determination needs to be performed consistent with the deficiencies and the impact of the program on CNS restart.

D. Considering the deficiencies and the causal factors, what corrective actions have you taken to improve the program to a level of adequacy for CNS restart?

Once the causal factors have been determined, corrective actions can be developed. At this point interest

,_. is only on those actions required to raise program performance to a level adequate to support CNS restart.

The program manager should not wait for MRC review to initiate the required corrective action.

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM

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INITIAL PROGRAM ASSESSMENT AND SCREENING (cont)

E. Describe longer-term (post startup) actions that will enhance program performance to a level that will meet our long term objectives of achieving top-quartile performance in safety, production and cost performance.

The final step in the self-assessment process is to consider other program improvement actions that are not required for startup, but that will raise the program to the desired level of performance.

Department Manager /Date: /

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Rsviewed by MRC/Date: /

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM .

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FOCUS PROGRAM LIST Cooper Nuclear Station 1.. Operability Determinations / Evaluations

2. Surveillance Testing
3. LCO Tracking
4. Plant Labeling
5. Process instrumentation Calibration Program
6. Operating Experience Reviews
7. Corrective Action Program
8. Safety Review and Audit Board L Station Operations Review Committee
10. Assessment (Quality Assurance) ,
11. Industrial Safety

.- 12. Records Management

13. Radwaste Storage and Disposal
14. In-service Inspection
15. In-service Testing
16. Appendix J Testing
17. Check Valves

- _- 18. Welding

' 19. Erosion / Corrosion m.!O. Snubbers

21. Commercial Grade Dedication

PERFORMANCE IMPROVEMENT PLAN . RESTART READINESS PROGRAM

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FOCUS PROGRAM LIST (CONT)

Cooper Nuclear Station (conti

_ 22. Shelf Life

23. Reliability and Performance Monitoring
24. Shift Technical Advisor Program

- 25. Vendor Manuals

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27. MIC Monitoring and Mitigation
28. Equipment Data ihie
29. Predictiv3 Maintenance 9-

_ s o. Preventative Maintenance

31. QA Audit / Surveillance Program ,
32. QA Supplier Audit Program
33. Quality Control
34. Work Control W

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM T

FOCUS PROGRAM LIST Nuclear Enaineerino and Construction Division (NECD)

1. Instrument Setpoints
2. Equipment Qualification
3. Equipment Classification

'4. Fire Protection - Appendix A/R

5. Meter Banding
6. Relief Valve Setpoints
7. Temporary Shielding

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8. Seismic Qualification of Equipment

. . .. Design Chango Program

10. Electrical Protective Relay Setpoints ,
11. Fuse and Breaker Coordination

_ 12. Load Studies (AC/DC/DG)

13. Pipe Hangers
14. MOV Program

- 15. CNS Severe Accident Analysis

16. Design Basis
17. Configuration Management M

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PERFORMANCE IMPROVEMENT PLAN -~ RESTART READINESS PROGRAM

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FOCUS PROGRAM LIST Trainina

1. Instrument & Control Technician
2. Mechanical Maintenance

- 3. Electrical Maintenance

4. Chemistry Technician
5. Health Physics Technician
6. Engineering Support Personnel
7. Simulator Certification
8. Shift Supervisor

_ j. Licensed Operator Requalification

10. Shift Technical Advisor ,
11. Initial Licensed Operator
12. Senior Reactor Operator
13. Station Operator l l

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM ,

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.. l APPENDIX i- SITE READINESS ASSESSMENT i an se

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Site Readiness Assessment

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The Management Review Committee shall consider the following in providing its affirmation to tha Site Manager.

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0 Organization and Personnel Readiness o Systems Readiness o Department Readiness o Outage Closure ,

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_ o Restart List Closure o Post-rcatart Plans Established o Assessments Complete

..o Other

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SITE READINESS ASSESSMENT FORM

-7 ROLL UP AND REVIEW OF SITE READINESS ASSESSMFMTS:

(Principal Areas to be Reviewed)
  • Organization and Personnel
  • System Readiness
  • Department Readiness
  • Program Readiness

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  • Outage Closve
  • Restart List Closures
  • Post Restart Plans
  • Assessments
  • Other (Specify)

REVIEW AND APPROVAL FOR INITIAL MODE CIIANGE MRC REMARKS SORC REMAltKS

. MRC Chairman Approval Date SORC Approval Date

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REVIEW AND APPROVAL FOR SITE CRITICALITY MRC REMARKS

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SORC REMARKS

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I MRC Chairman Approval Date SORC Approval Date

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM e-o euw

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e V ', f APPENDlX J - CROSS REFERENCE OF DSAT FIELD NOTES AND PHASE 1 PLAN i

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DSAT FIELD NOTES NOT INCORPORATED 1 INTO THE PHASE 1

- PERFORMANCE IMPROVEMENT PROGRAM I '(pI5EDY DT5dN * '

' > tl SUPPL 55iENTAl[jN5dik514tI6N$3dNNP# %Q WW-27 All WW-25 All

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WW-21 All WW-20 All WW-15 Guidance on when system lineups should be conducted WW-13 Ali WW-06 All WW-02 All RB-11 Phase 2/3 Plans on AOT 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

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DM-08 Example 5 ,

, DM-07 All DM-01 All 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

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SV-21 Example 3 SV-18 All SV-16 Examples 2, 3, 5, Phase 2/3 Plans SV-15 All SV-12 All s.

SV-07 ase 2/3 fans to address rework, work arounds, and increased out-of-service times SV-04 Phase 2/3 Plans 1

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DSAT Field Not2s Not incorporttid...

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Page 2 c FIELD, NOTE) ~ !%@$hG 'sSUPpdMENT^iflNF RMhTlONN Ulk($4d$h(%$)

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 94-006 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 -

r SE-08 All SE-05 All SE-07 All S E-04 All SE-03 All SE-02 All SE-01 All RC-15 TPCN, PCN ltems RC-10 All RC-06 All RC-01 All

.. JD 12 All JD-10 All JD-09 All .

DSAT Field Nat:e Nrt incorporatid...

, Page 3 IFIELD N'OTEL .

(SOPPI EMENYAllNFORMATIDN! ' % 78Md'l JD-08 All JD-01 Examples 1,4,6,8,9,10 Causes 1, 2, 3, 4 DK-06 All DK-05 Examples 2,3 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 RA-09 Examples 1, 2, 3 RA-08 All RA-05 ,

P' ase 2/3 Plans JC-02 a JC-01 All GW-19 Description, Programmatic and Managernent Phase 2/3 Plans ir -

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 GW-09 Examples 1, 2, 3, 4. Phase 2/3 Drawing Change Program plans, correction of previous deficiencies, etc.

GW-05 All GW-04 All GW-03 All GW-02 All

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DSAT Field Notes N1t incorporated... l T Page 4 I MFi$LdjNOTEih@d2 '

A < + 3h , ESijPPl5MENihtIN!!DRM tidND IMf$he$

l 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 generic issues ,

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 i Phase 2/3 monitoring of Root Cause Analysis adequacy, and CB-12 Corrective Actions correlate with root cause analysis

-" CB-11 All Phase 2/3 Plans for OER Program, Postetrip review procedure CB-10

._, adequacy ..

CB-09 All CB-08 All CB-07 All Falled or absent barriers, Phase 2/3 assessment and monitoring of MCB-01 CAP performance, OER Phase 2/3 Plan and assessment of OER Program performance MGW-01 All of Description MGW-02 All of Description, RHR-MO-27A/B and 34A/B example ~

MGW-06 Phase 2/3 Plans regarding configuration control

~ Phase 2/3 Plans regarding design control and example regarding MGW-07 testing of modification to see if it works MCB-02 Phase 2/3 monitoring and assessment of issues listeil MJD-01 All

_ 'MJD-02 All l MJD-03 All except examolo 4 )

MJD-05 Phase 2/3 assessment of NPG's ability to execute plans

DSAT Field Nites N1t incorporetd...

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yf;$Fl$1d!SOI5Y'a sib S9fsM?TS $50ii P1 5hi5NY ElS565NIAflON@Bdhk@MkIk H'

MJD-06 All MJD-07 Phase 2/3 Plans of independent oversight

- MJD-08 All I

- MJO-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 MWW-03 All WW-17 Examples 1, 2, 3 RC-04 All

_ DM-10 Examples 2,6 ..

.. SV-01 All Examples RA-09 Examples 2,3 GW-17 Example 2 DK-04 Example j l

CB-07 Example

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CB-13 All 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 MCB-02 Example 4, item d WW-16 Closed out by DSAT Team WW-10 Closed out by DSAT Team

_ WW-11 Closed out by DSAT Team WW-09 Closed out by DSAT Team

e DSAT field N:tre Nat inctrptr:ted...

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I"iSOPPl5MESYhfl NONMIYidS$ E '/_l'# fck 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 t

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PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM y.

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APPENDIX K - EMERGENT ISSUES FLOWCHART

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EMERGENT ISSUES L a

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YES Item Owner Ops Review YES .YES Em "t' s Item MWR, Submit For for MWRs - CRG e iEed bY

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JCO or CR? Restart Reviews Restart Call Dept. Manager Evaluation for CR & JCOs NO NO RC

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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 t Restad System Input To Dept. '

Schedule Readiness Readiness

PERFORMANCE IMPROVEMENT PLAN - RESTART READINESS PROGRAM i l

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WPMC SCREEN r ,

EtNRs & DCPs > STARTUP PLAN CNS RESTART OUTAGE MODS WORK SCHEDULING  ;

NEW EQUIPMENT RELATED CRs RE-REVIEW ALL NON A/B/C ADD CATEGORY MWRs SCREENING PERFORM WORK

  • y A WORK TO (OFERATIONS) MEETING STARTUP MWR lON SCHEDULE A

REVIEW ALL NON A/B/C CRs NON-MWRs v

ASSIGN D_UE EXISTING DATE TO NON CATEGORY B/C CATEGORY 1-3 MWR CRs AVAILABLE TO ,

CRs WORK

SCHEDULED OUTAGE ACTIVITIES NOT PRIORITIZED l A/B/C