ML20116L021
| ML20116L021 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/26/1996 |
| From: | Brothers M, Rothen F, Vargas J NORTHEAST UTILITIES SERVICE CO. |
| To: | |
| Shared Package | |
| ML20116L019 | List: |
| References | |
| PROC-960726, NUDOCS 9608160052 | |
| Download: ML20116L021 (82) | |
Text
Docket No. 50-423 B15839 1
l Attachment 3 I
Millstone Nuclear Power Station, Unit No. 3 Operational Readiness Plan, Revision 1 i
August 1996 f
l 9608160052 960813 PDR ADOCK 05000423 P PDR
O Millstone Unit 3 Operational Readiness Plan i
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4 44 F 4
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i Rev.1 7/26/96 l
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Approved By: M/h'
~
N 7/2k6 MM. Brotheib. ' Date .
MP-3 Unit Director i P
Approved By: I/ % 7/2/94 1
/ J.M.Vargfs Date !
D'esign Engineering Director Approved By: l EC. Rothen Date .
Vice President, Nuclear Work Services i Approved By: _ _ io js 7!Z kf E.A. DeBarba Date i Vice President, Nuclear Technica ervi s !
I Approved By:
" D.B.' Miller,'JI A Y
[/ Date I Sr., Vice President, Nuclear Safety and Ov6rsight j l
Approved By: # [#
T.C. Feigenb m V _
71 (
'Dat'e Executive Vice President hief Nuclear Officer NOTE: The signatures listed above reflect ORP, Rev. O approval. Revision 1 approval signature is listed at the end of the Summary of Changes.
. Summary of Changes for Revision 1 This section provides at list of effective changes made to Revision 0 of the Operational Readiness Plan during the current revision 1 update. Identified are changes made by adding or deleting sections or steps as well as word modifications resulting in a change ofintent.
- 1.Section I. 2. cla.ifies that the Operational Readiness Plan format is based on the OEOs from the Nuclear Excellence Plan.
- 2. New Section I. 3. was added to define for Roles and Responsibilities of key individuals.
- 3.Section I. 4. was changed to include a short-term Action Plan based upon an integrated evaluation performed on the results of the Horizontal and Vertical Slice Review Team results.
- 4.Section I. 4.2. was modified to provide guidance for failure to meet the Success Criteria of 50.54(f) and a bullet was added for clarification of the remaining portion of the ORP Success Criteria.
- 5. Bullet was added to the end of Section II. 2.1. that assigned the Unit Corrective Action Manager a deliverable to ensure applicable action plans are developed to appropriately address each of the root cause areas.
- 6.Section II. 2.4.was modified to include: "The Joint Utility Management Assessment (JUMA) will be added to the Readiness Plan as information becomes i available. This was a recent assessment of the OAS organization."
- 7.Section III.1. Discussion, was condensed by removing text relating to initiatives not i contained within the plan.
- 8. The deliverable, updated FSAR chapters, has been moved to Section III. and was modified to read:" Review and update of MP-3 Final Safety Analysis Report ;
(FSAR) is complete and docketed with the NRC."
- 9.Section III. 2.1.10.- Aligned Unit Director ORP deliverable expectations with the ORP Attachment A deliverables.
- 10.Section IV., Methodology - deletes requirement for MQC/PORC to determine i acceptability of self-assessment initiatives. These will be reviewed and accepted by I the Unit Director with any recommendations properly dispositioned. The reason for this change is to align requirements with expectations of the CNO, that the Unit ,
Director is the responsible person for identifying and setting the standard of what is I required for our Operational Readiness Letter submittal.
- 11.Section V. was modified to clarify the closecut process for readiness deliverables.
- 12. Changes in deliverable dates have been made to align with preliminary outage schedule milestones.
MP-3 Operational Readiness Plan i Rev.1 7/26/96
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- 13. Upon review, the following deliverables were removed from the ORP l Attachment A, because they have been completed or do not meet Unit 3 start-up
! criteria. .
- OEO #1 1 >
All action plans associated with Maintenance Rule requirements have ,
been completed.
r
- OEO #2 !
MP-3 Operational Readiness Plan has been developed. ;
i
- Review of changes to the MP-3 Operational Readiness Plan is an on-going process.
- OEO #3 :
- Public Communications (old section 1.b.) has been ren.oved (did not meet ;
restart criteria).
- Develop CNO expectations for behavior is complete and has been removed as a deliverable.
- OEO #4 Removed deliverables for best practice coordinators named and top 10 list of process problems (did not meet restart criteria).
l 14. Upon review, additional deliverables were added to the the ORP Attachment A, ;
as follows:
A number of modifications were made throughout the ORP to clarify deliverables, modify deliverables or add detail.
Deliverables were added to OEO #1, Key Backlog and Hardware Initiatives, OEO #2, Configuration Management, and 10CFR50.54(f) Review / Analysis.
This is a result ofinputs from PI-2 assessment recommendations and Integrated Team recommendations.
- OEO #1
- Expectations were added to reflect Nuclear and Unit DCA Charters.
- OEO #2
- Added deliverable for the MP-3 Corrective Action Manager to review all initiatives and deliverables to ensure root causes and recommendations have been adequately dispositioned.
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MP-3 Operational Readiness Plan ii Rev.1 7/26/96
- 14. Continued (deliwrables added)
= OEO #3 Added deliverable to " Develop and communicate CNO expectations for the Independent Oversight Function to the Nuclear Group."
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- Added deliverable to " Implement measures to improve overall effectiveness l ofinternal communications among management and employees of the
! Nuclear Group.
- OEO #5
- Added deliverable to identify a " Barrier Breaker" lead for unit 3.
1 ,
Revision 1 Submitted By: _.
!g((h Mibf i N i
[N N perational Red'diness Manager / Dat'e
! Revision 1 Approved By: N1h' N , de M (,
M.H.' Brothers /
16 ate MP-3 Unit Director t
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I l
MP-3 Operational Readiness Plan iii Rev.1 7/26/96 l
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! TABLE OF CONTENTS l
1
- 1. I NTRO D U CTI O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ,
l
- 1. B ackground . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l 2. Phased Performance Improvement Approach . . . . . . . . . . . . . . . . . . . . . . 1 ;
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- 3. Roles and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 !
l l 4. S u cce ss Cri t e ri a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 ,
i l II. PERFORMANCE ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 ;
- 1. M e t hod ology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
- 2. Root Cause Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l
- 3. Fundamental Cause Identification and Review . . . . . . . . . . . . . . . . . . . . . 12 i III. MILLSTONE 3 RESTART CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 !
- 1. Operational Excellence Objective (OEO) #1 Initiatives for industry leadership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
- 2. Operational Excellence Objective (OEO) #2 l Initiatives for bui: ding regulatory confidence . . . . . . . . . . . . . . . . . . . . . . 21 l 3. Operational Excellence Objective (OEO) #3 l Initiatives for improving communications and morale . . . . . . . . . . . . . . . 30 l l 4. Operational Excellence Objective (OEO) #4 3 l Initiatives to improve teamwork . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
- 5. Operational Er.cellence Objective (OEO) #5 I 1
Initiatives to improve workers ability to conduct work successfully . . . . 35 l.,
l IV. READINESS ASSESSMENT PROCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 l l
- 1. M e t hod ology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 i
- 2. Development of Readiness Deliverables . . . . . . . . . . . . . . . . . . . . . . . . . . 37 )
l 3. Development of The Outage Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 V. CLOSEOUT OF OPERATIONAL READINESS PLAN DELIVERABLES. 40
- 1. G uid elin es . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
- 2. Deliverables close-out process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 l
i A'ITACHMENT 4
Attachment A - ORP Deliverables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 i
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. MP-3 Operational Readiness Plan av Rev.1 7/25/96 i
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l I. INTRODUCTION
- 1. Backeround Millstone Unit 3 (MP-3) was placed on the NRC Watch List on January 31,1996.
The Unit entered an outage on March 31,1996 to repair Auxiliary Feedwater Containment Isolation Valves. In letters dated March 7,1996, April 4,1996, and May 21,1996, the NRC requested that additional information be submitted prior to re-start which describes actions taken to ensure future operation will be conducted in accordance with MP-3's operating license and UFSAR and the Commission's regulations. NU is committed to satisfactorily resolve these issues prior to resumption of power operation.
- 2. Phased Performance Improvement Approach NU Management has developed the MP-3 Operational Readiness Plan (ORP) to ;
implement near-term actions to achieve performance improvement to support a safe return to power operation.
l The ORP utilizes a format based on the Operational Excellence Objectives j (OEO) from the Nuclear Excellence Plan. I Long term actions to achieve nuclear excellence based on Operational Excellence
, Objectives, strategies, initiatives and key performance indicators cre described in l l the Nuclear Excellence Plan. The Nuclear Excellence Plan addresses a broader l range of issues over the longer term, which will help ensure that the root causes of l NU nuclear performance problems are corrected and all the units achieve a ,
sustained level of excellent performance. '
- 3. Roles and Responsibilities The successful implementation of the MP-3 Operational Readiness Plan (ORP) l requires a consolidated team effort from all Millstone employees. The following is l a list of roles and responsibilities of the key team members:
Senior Management - The Executive Vice President and Chief Nuclear Officer is responsible for providing the overall strategy for restart and establishing performance expectations. The Senior Vice President- Nuclear Safety and Oversight independently advises the Chief Nuclear Officer as to the readiness of MP-3 to restart.
Unit Director - The MP-3 Unit Director has overall responsibility for the management and implementation of the ORP which includes the necessay resources are available and properly utilized. The Unit Director will review changes to the ORP and has the approval authority for revisions.
, Employee Review Committee - Conducts an independent assessment of MP-3 l l readiness to restart. Advises the Unit Director of issues impacting MP-3 readiness.
l Plant Operations Review Committee (PORC) - Utilizing consistent standards, the PORC reviews and approves deliverables necessay for restart. PORC performs a technical assessment of each system readiness review package for consistency and !
completeness. The PORC is a multi-disciplined team of managers, chaired by the Unit Director with the experience necessary to assess and review restart issues.
l MP-3 Operational Readiness Plan l Rev.1 7/26/96 Page 1 of 75 l
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Expert Panel - As defined in NUC-PI-14, CMP Process Administration, reviews and prioritizes identified deficiencies to determine startup prerequisites, evaluates deficiencies from an operability, reportability, and safety significance perspective to confirm proper corrective action program disposition, and endorse adequacy of proposed corrective action.
Operational Readiness Manager - Develops the Operational Readiness Plan and integrated outage schedule. 'Itacks deliverables to completion. Communicates to the organization, progress by means of Performance Indicators, Outage Highlights, and All Hands Meetings. Identifies barriers and major risks to senior management.
Work Planning and Outage Manager - Works with centralized scheduling to develop and update the integrated outage schedule. Conducts Daily Schedule Update Meetings to discuss progress and barriers.
Action Plan Managers - Develop action plans to address identified weaknesses and deficiencies at MP-3 addressing specific corrective actions to resolve identified root cause findings. Coordinate with the Unit Director and department managers to implement action plans. :
Corrective Action Manager - Review actions and initiatives to ensure root cause performance findings are properly addressed to support restart of unit 3. ;
Department Managers - Perform self-assessmenk of their individual departments, implement action plans, corrective actions, and demonstrate the restart readiness of their department to the Unit Director.
All Millstone Employees - Support the implementation of the ORP by focusing .
on plant safety and continuous improvement. Key to this responsibility is the obligation to raise any and all identified quality and safety concerns to ;
management's attention for resolution. ;
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MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 2 of 75
- 4. Success Criteria ,
- This Success Criteria refers to the 50.54(f) portion of the Operational Readiness Plan.
The 50.54(f) plan must prove the initial premise that the original MP-3 FSAR was sound. The plan must also show that the problems identified in the MP-1 root cause investigation (ACR-7007) that are applicable to MP-3, do not preclude the safe operation of the unit.
Two criteria must be met: ;
- 1) An assessment of each identified deficiency must be made. No individual l deficiency, if found while the unit was at power, could have resulted in a ;
required shutdown. This criteria addresses the validity of the " slice" method j ofverification. .
- 2) An aggregate assessment of allidentified deficiencies must be made. The !
aggregate assessment must validate that the original FSAR was sound and that the problems identified by ACR 7007 have not resulted in an unsound FSAR. ;
1 i
Based upon the review of the above criteria, both attributes failed to be achieved.
Based upon an integrated evaluation performed on the results of the Horizontal I and Vertical Slice Review Team results, the following short-term Action Plan was i proposed l
- 1) Review and update appropriate sections of the FSAR (including review of past licensing commitments), critical calculations, technical specs, DBDPs, and l upgrade performance of 50.59 analyses. i
- 2) Review and correction of Ops Critical Drawings, address MEPL program and upgrade of vendor technical information control program.
- 3) Initiation ofimproved corrective action program.
- 4) Review and upgrade of operating and surveillance procedures and inspections, address operator burdens and MCB deficiencies, address bypass jumpers and temporary modifications, review and address PMMS program, and correct
! sigmficant materiel condition deficiencies. In addition, complete system readiness reviews on remaining safety related systems.
- 5) Initiation of a configuration control program, including the DCM, to ensure effective communication links between programs, processes, and procedures that is consistent with industry experience for multi-site plants and includes effective records management.
As an additional review expansion, a formal system s::lf assessment on four problem, high significance systems shall be performed: auxiliary feedwater, service water, emergency diesels, and SBO diesel. This effort would use the SSFI process as guidance. These systems were selected for evaluation based on the following: 1.
a safety significance review of group 1 systems,2. a significance review of HSRT and VSRT deficiencies,3. the relatively large number of historical problems
! previously identified, and 4. regulatory interest.
The remaining portion of the ORP Success Criteria is satisfied by the successful comp'etion of Section III Initiatives as documented in the deliverables of 4
Attatnment A and accepted by the Unit Director.
1 MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 3 of 75
- l. - -
II. PERFORMANCE ASSESSMENT
- 1. Methodology To better understand the magnitude of the problems that must be corrected, candid and objective assessments are being conducted. Building from existing evaluation programs, documents (INPO and NRC evaluations and internal assessments) and personal interviews within the organization, NU management is determining the key weaknesses and performance gaps. These assessments provide management the opportunity to review the problems and commit the necessary resources and involvement necessary to effect significant change.
The Operational Readiness Plan (ORP) is based on these assessments and incorporates elements of the Operational Excellence Objectives (OEOs), Nuclear Excellence Plan (NEP), and Improving Station Performance (ISP) initiatives.
These elements have been combined with the MP-3 Management Restart Criteria to identify specific MP-3 ORP initiatives and deliverables. Each deliverable has an associated responsible lead person and due date (Attachment A).
- 2. Root Cause Evaluations The following root cause analyses are associated with the MP-3 ORP. Results of these reviews may be incorporated into ORP deliverables or become longer-term action items, as appropriate.
2.1. ACR 7007 - Event Response Team Report The table listed below shows the conclusions from the ACR 7007 Report and the correlation between the corrective actions and the deliverables of the Operational Readiness Plan.
ACR 7007 to Operational Readiness Plan Conclusion / Comment Corrective Action ORP Deliverables
- 1. UFSAR submitted to Addressed by 50.54(f) Project OEO #2 NRCin 1986/87with Completion Plan 10CFR50.54(f) Review / Analyses errors. (Deliverables on page 62)
- 2. NU knew about these Historical fact: no action OEO #2 errors, required. 10CFR50.54(f) Review / Analyses (Deliverables on page 62)
- 3. Commitments to correct Addressed by50.54(f) Project OEO #2 the errors were Completion Plan. For MP-3,10CFR50.54(f) ineffective. Review / Analyses (Deliverables onpage 62)
Commitment Management (Deliverables on page 52)
- 4. Calculations did not exist Addressed by 50.54(f) Project OEO #2 to support some of the Completion Plan. 10CFR50.54(f) Review / Analyses design bases, and were (Deliverables on page 62) not reconstructed. l MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 4 of 75
ACR 7007 to Operational Readiness Plan Conclusion / Comment Corrective Action ORP Deliverables
- 5. NU did not view UFSAR Corrective action: develop and OEO #1 as a licensing basis implement education program. Management I>evelopment and document. Leadership (Deliverables on page 43)
OEO #2 Configuration Management (Deliverables on page 58)
EngineeringTraining (Deliverables on page 63)
- 6. NU's administrative Addressed by 50.54(f) Project OEO #2 programs did not fully Completion Plan. 10CFR50.54(f) Review / Analyses mcorporate regulatory (Deliverables on page 62) requirements.
- 7. Decade-long pattern of Corrective action: conduct a OEO #2 decisions and actions has verification effort at MP-2, 10CFR50.54(f) Review / Analyses genericimplications. M P-3, C Y.
(Deliverables on page 62)
Corrective Actions (Deliverables on pages 55-57)
Configuration Management (Deliverables on page 58)
- 8. Lack of accountability Corrective action: develop and OEO #2 and teamwork for implement a Corrective Action Corrective Actions UFSAR accuracy. Monitoring Plan.
(Deliverables on pages 55-57)
- 9. Root Cause for 5.7 will be Addressed by 50.54(f) Project OEO #2 identified by 50.54(f) Completion Plan. 10CFR50.54(f) Review / Analyses self-assessment.
(Deliverables on page C2)
Root Cause Assessments (Deliverables on page 61)
- 10. Issues and their causes Addressed by 50.54(f) Project OEO #1 were identified to Completion Plan. Management Development and management; Leadership management should have (Deliverables on page 43) been accountable for the corrective actions. Effective Nuclear Safety &
Oversight (Deliverables on page 44)
- 11. NU Oversight did not Addressed by recent OEO #1 identify administrative reorganization and corrective Effective Nuclear Safety &
programs weaknesses or actions Oversight pattern of design control (Deliverables on page 44) events.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 5 of 75
ACR 7007 to Operational Readiness Plan Conclusion / Comment Corrective Action ORP Deliverables
- 12. Employees do not Corrective action: develop and OEO #1 understand relationship implement education program. Management Development and between 10 CFR, design Leadership bases, industry standards, (Deliverables on page 43) administrative programs.
OEO #2 Configuration Management (Deliverables on page 58)
Engineering Raining (Deliverables on page 63)
- 13. Organization does not Corrective action: develop and OEO #1 appreciate processes implement education program. Management Development and needed to achieve stated Leadership safety objectives. (Deliverables on page 43)
OEO #2 Configuration Management (Deliverables on page 58)
Engineering Raining (Deliverables on page 63)
- 14. Organization focuses Corrective action: develop and OEO #1 narrowlyon problems and imp!cment education prc, gram. Management Development and their resolutions. Leadership (Deliverables on page 43)
OEO #2 Corrective Actions (Deliverables on pages 55-57)
EngineeringTraining (Deliverables on page 63)
- 15. Line managers use a Corrective action: develop OEO #2 limited set of tracking and measurement tools for Corrective Actions trending tools. functional area performance. (Deliverables on pages 55-57)
Self-Assessment (Deliverables on page 49)
Note: Per expectation of Unit 3 Director communicated in status. update meeting of 7/12/96. All Action Plan Managers are requested to ensure resolution of root cause and fundamental cause findings (as applicable) are addressed when developing their initiatives. Identify ORP l changes to the Unit 3 Director and Operational Readiness Manager.
- The Unit Corrective Action Manager has been assigned a deliverable to ensure applicable action plans are developed to appropriately address each of the root cause areas.
Refer to page 61 for deliverable.
4 4
l MP-3 Operational Readiness Plan Rev. I 7/26/96 Page 6 of 75 l
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f 2.2. Root Cause Analysis for the failure of the QA organization to identify MP-3 !
deficiencies. !
The table listed below shows the QAS Failure Root Cause Evaluation and the correlations between the recommendations and the deliverables of the i Operational Readiness Plan. )
i QAS Failure Root Cause Evaluation to Operational Readiness Plan !
QAS Failure Root Cause QAS Failust Root Cause ORP Deliverables !
Evaluation Causal Factor Evaluation Recommendations i
- 1. The Chief Nuclear The Chief Nuclear Officer O.E.O. #3 Officer's expectations must establish and
. Employee Communications were not adequate m that communicate executive 3 expectations for the (Deliverables on Page 72) ;
he expected the ,
independent oversight inde ndent oversight function '
organization tolimitits to al of the Nuclear Group, review of activities to the minimum required by :
regulations. ;
- 2. The QAS audit program Oversight expectations should O.E.O. #1 !
did not meet the be benchmarked a ainst the Effective Nuclear Safety &
minimum required by bestpractices of scensees Oversight ,
regulations because the who are considered to have a r track record for excellent (Deliverables on Pg. 44) ;
program was based on implementing Nuclear Performance. O.E.O. #4 !
Group Procedures rather ContinuousImprovement Team & !
than the base Strategies requirements and (Deliverables on Page 73) t commitments. j
- 3. QAS did not periodically QAS must include O.E.O. #1 I assess its own consideration of the base Effective Nuclear Safety & !
performance against the regulatory requirements, Oversight .
(Deliverables on Pg. 44)
Pr g a UQ ) and m en s uch a,s the l the base regulatory NUQAPinitsoversight , O.E.O. #2 l requirements to which it Self-Assessment l was responsible for hho*rma$c basis.
oIar ular (Deliverables on Pages 49-5f) I verifying compliance. !
l l
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i QAS Failure Root Cause Evaluation to Operational Readiness Plan QAS Failure Root Cause QAS Failure Root Cause ORP Deliverables Evaluation Causal Factor Evaluation Recommendations
- 4. Line management Oversightimplementation plan O.E.O. #1 reinforced the limited shouldinclude requirements Management Model & I scope of the independent for line management Performance Management l oversight process through attendance at meetings.
(Deliverables on Page 42) its limited view of the Oversightimplementationplan .
value of oversight and its should be reviewed by the line Management Development & J lack of effort to organization. Lead ship improve it. (Deliverables on Page 43) 4 Line management's expectations for the Effective Nuclear Safety &
independent oversight function Oversight must be established and (Deliverables on Page 44) communicated to the line organization. O E.O. #2 Training and qualification Corrective Action program for oversight (Deliverables on Pages 55-57) personnelis commensurate Engineering Training with ex ctations for the (Deliverables on Page 63) 1 oversig t orgamzation. I O.E.O. #4 l Successful service in the oversight organization should Continuous Improvement Team &
be made a prerequisite to Strategies i advancement in certainline (Deliverables on Page 73) management positions l
- 5. The Chief Nuclear Nuclear Safety & Oversight O.E.O. #1 Officer and line must monitor implementation Effective Nuclear Safety &
management accepted Ian and of th,e oversght for corre a.ve Oversight known deficiencies in the {; vide g, fe (Deliverables on Page 44) oversight process without order to ensure O.E.O. #2 resolving them in a timely implementation of the CNO's manner. expectations. Self-Assessment
. (Deliverables on Pages 49-51)
Line management must provide feedback to the Corrective Action oversight organization (Deliverables on Pages 55-57) management re,garding O.E.O. #4 correction and improvements in the oversight program. Continuous Improvement Team &
Strategies (Deliverables on Page 73)
Note: Per expectation of Unit 3 Director communicated in status update meeting of 7/12/96. All Action Plan Managers are requested to ensure resolution of root cause and fundamental cause findings (as applicable) are addressed when developing their initiatives. Identify ORP changes to the Unit 3 Director and Operational Readiness Manager.
=
The Unit Corrective Action Manager has been assigned a deliverable to ensure applicable action plans are developed to appropriately address each of the root cause areas.
Refer to page 61 for deliverable.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 8 of 75
2.3. Millstone Unit 3 Specific Root Cause Analyses.
The results of Root Cause investigations," Millstone Unit-3 Loss of Confidence in the MP-3 Configuration and Current Licensing Bases," Revision 1 (ACR 13302) indicate the findiny,s, recommendations and corrective actions of ACR 7007 are applicable and valid for MP-3. For specific information, refer to the ACR 7007 to Operational Readiness Plan correlatton table on pages 4-6.
MF-3 Sp$ific Assessment to Oprational Readiness Plan Identified Issue Recommended Acibn ORP Deliverables
)
- 1. Open Bypass Jumpers may Bypass Jumpers remainingin O.E.O. #1 represent a " work-around" place upon unit startup be Plant Hardware in Good of a design feature described reviewed for FSAR PhysicalCondition in the FSAR. compatibility and hav,e a (Deliverables on pages 45-48) written safety evaluation.
- 2. Early(1983-1991) plant A thorough review of early O.E.O. #1 modifications using the E & vintage (1983 ,1991) PDCEs Plant Hardwarein Good DCR and PDCE processes and E&DCRs is recommended. PhysicalCondition may have been completed by (Deliverables on pages 45-48) staff not fully knowledgeable on design and documentation considerations.
- 3. Assumptions used as the Create a masterlisting of all O.E.O. #2 bases for calculations may calculations generated to date Configuration Management have been too narrow. so that a proper foundation for (Deliverables on pages SB)
Calculation tracking future work is established.
integrity necessary to facilitate system modification was not always 1 present.
l
- 4. During startup, some Operations Department O.E.O. #2 systems were changed in the complete a review of all Group 10CFR50.59 Implementation way they were operated to 11 systems for . (Deliverables on page 60) make them work. Procedure FSAR-to-Operating changes were made without Procedure compatibihty. Corrective Actions regard to the FSAR. 10CFR50.59 evaluations need (Deliverables on pages 55-57)
Inadequate preventive to be completed if the unit 10CFR50.54(f) Review &
maintenance degraded some returns to service with systems Analysis FSAR systems to the point operated at odds with the (Deliverables on page 62) where they were taken out of FSAR-described method of service. Systemswhichwere operation.
abandoned in place were still described in the FSAR.
- 5. Significant work released Review Engineering backlog O.E.O. #1 during the years around per MP-3 Restart Criteria Plant Hardware in Good initial commercial operation item 11.1. PhysicalCondition may contain vulnerabili, ties (Deliverables on pages 45-46) relating to non-comphance with FSAR-described features and functions.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 9 of 75
MP-3 Specific Assessment to Operational Readiness Plan Identified Isrue Recommended Action ORP Deliverables
- 6. Commitment tracking A means be established to O.E.O. #2 process is not optimal. ensure commitments are Commitment Management tracked and traceable. (Deliverables on page 52)
MTFItems (Deliverable on page 68)
- 7. Systems supplied by vendors Vertical Slice reviewers be O.E.O. #2 and installed by the mindful of major AE/ Vendor mterfaces. 10CFR50.54(f) Review &
Architect /Engm, eerhave Analysis experienced problems (Dehverables on page 62) related to the vendor /AE in:erface.
- 8. MP-3 staff close to Raining element of ACR 7007 O.E.O. #2 surveillance test writing and corrective actions is inclusive of ineering Raining test performance processes this employee population. Enfliverables (D ora page 63) hasinsufficient knowledge of the FSARimpact resulting Configuration Management from their work. (Dehverables on pages 58)
- 9. FSAR changes have been All FSAR changes made for O.E.O. #2 made without the benefit of reasons other than plant design changes be reviewed to ensure 10CFR50.54(f) Review &
a 10CFR50.59 evaluation. Analysis that a 10CFR50.59 evaluation (Dehverables on page 62) exists or a clear and acceptable rationale is in placejustifying 10CFR50.59 Implementation the lack of need for an (Deliverables on page 60) evaluation.
- 10. DCNs may have been used Complete a review of Category O.E.O. #2 for drawing updates without 8 Administrative DCNs t Configuration Management having a parent document or ensure drawings have not been (Deliverables on pages 58) 10CFR50.59 evaluation. changed to reflect field conditions without ensuring the field condition is in accordance with intended design. Cease using Category 8 DCNs for purp,oses other than purely admmistrative changes.
- 11. Informationcontainedin An evaluation of need for a O.E.O. #2 answers to NRC questions in more complete incorporation of NU's responses to the NRC 10CFR50.54(f) Review &
FSAR volumes 15 & 16 is Anal is not consistentlyincorporated questions into the body of the (Det etables on page 62) into the descriptions FSAR is recommended.
contained in the body of the Evaluate completed CMP FSAR. reviews to ensure information in FSAR volumes 15 & 16 was included in initial reviews.
i MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 10 of 75 ,
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1 MP-3 Specific Assessment to Operational Readiness Plan l Identified Issue Recommended Action ORP Deliverables
- 12. Significant levels of backlog Place a heavy emphasis on O.E.O. #5 in process areas (PDCRs, backlog reduction, ultimately to Work Control NCRs, AWOs, etc) seems to the pomt of backlog (Deliverables on page 74) be a precursor to degraded climmation together with a unit performance. commitment to prevent new O.E~O #1 growth. Plant IIardware in Good l
PhysicalCondition (Deliverables on pages 45-48)
, Note: Per expectation of Unit 3 Director communicated in status update meeting of 7/12/96. All l Action Plan Managers are requested to ensure resolution of root cause and fundamental l
cause findings (as applicable) are addressed when developing their initiatives. Identify ORP changes to the Unit 3 Director and Operational Readiness Manager.
The Unit Corrective Action Manager has been assigned a deliverable to ensure applicable action plans are developed to appropriately address each of the root cause areas.
Refer to page 61 for deliverable.
2.4. The Joint Utility Management Assessment GUMA) will be added to the Readiness Plan as information becomes available. This was a recent assessment of the OAS organization.
I MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 11 of 75
- 3. Fundamental Cause Identification and Review A fundamental cause analysis is being finalized by the Fundamental Causes Assessment Team (FCAT) for the Nuclear Committee Advisory Team (NCAT).
Results of this assessment will be incorporated into the Operational Readiness Plan or become longer-term Action Initiatives under the Nuclear Excellence Plan, as appropriate.
The findings of the preliminary report have been addressed by the Operational Readiness Plan initiatives. The table listed below shows the correlation between the FCAT categories and the deliverables of the Operational Readiness Plan.
FCAT to Operational Readiness Plan FCAT Category Summary ORP Deliverables
- 1. Vision & Direction Leadership vision and O.E.O. #1 di,rection were not consistent Management Model &
with fundamental needs of a Performance Mariagement
f;7 7
E ""' ' '
(Deliverables on page 42)
Management Development &
Leadership (Deliverables on page 43)
- 2. Defense of the Status Leadership often put emphasis O.E.O. #1 Quo onjustifying the status qu Effective Nuclear Safety &
rather than resolving problems.
Oversight (Deliverables on page 44)
O.E.O. #2 Root Cause Assessment (Deliverables on page 61)
- 3. Response to Serious Leadership did not effectively O.E.O. #2 Problems re ond to mounting Corrective Action proble s (Deliverables on pages 55-57)
Self-Assessment (Deliverables on pages 49-51)
- 4. Tolerance of Deficient Deficient conditions were O.E.O. #1 Conditions often overlooked, not Management Model &
corrected, or corrected slowly Performance Management or with a narrow focus.
(Deliverables on page 42)
O.E.O. #2 Corrective Action (Deliverables on pages 55-57)
O.E.O. #4 ContinuousImprovement Team &
Strategies (Deliverables on page 73)
I MP-3 Operational Readiness Plan i Rev. I 7/26/96 i Page 12 of 75 ;
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l l FCAT to Operational Readiness Plan FCAT Category Summary ORP Deliverables l
- 5. Conservatism Management and personnel O.E.O. #2 standards did not ensure Self-Assessment conservative decisions. ,
(Deliverables on pages 49-51) I i
Conservative Operating Philosophy (Deliverables on page 54) ;
10CFR50.59 Implementation (Deliverables on page 60) t
- 6. Attitude Tbward Regulatory standards were not O.E.O. #2 ,
Regulatory Standards always met because certain '
Regulatory Communications requirements were not t recognized and others were (Deliverables on page 53) :
considered to be unimportant. NRC Inspection Issues (Deliverables onpages 64-66) l Procedure Compliance (Deliverables on page 60)
- 7. Organizational An ineffective organization O.E.O. #1 i Effectiveness existed because of weak Management Model&
management skills in peop,le Perfortrance Management r orifizat o o eIou s,$nd (Deliverables on page 42) definition of organizational Management Development &
roles. Leadership (Deliverables on page 43)
O.E.O. #3 ize Organizational Structure
) ' ivliverables on page 70)
' O.E.O. #5 Align Human Resources (Deliverables on page 74) i
- 8. Employee Conurns Management wasineffective in O.E.O. #3 {
responding to many employee Employee Concerns Task Plan (Deliverables on page 70-71)
Employee Communications i (Deliverables on page 72) l Note: Per expectation of Unit 3 Director communicated in status update meeting of 7/12/96. All i Action Plan Managers are requested to ensure resolution of root cause and fundamental i cause findings (as applicable) are addressed when developing their initiatives. Identify ORP changes to the Unit 3 Director and Operational Readiness Manager.
l l The Unit Corrective Action Manager has been assigned a deliverable to ensure applicable action plans are developed to appropriately address each of the fundamental cause areas.
Refer to page 61 for deliverable.
MP-3 Operational Readines ::an Rev.1 7/26/96 Page 13 of 75 q em" -w-g .m' "-
g.u-,. m ac-- - - , - asms.- - ,- - - - - -m- ,----~ -4 e.m
III. MILLSTONE 3 RESTART CRITERIA This section contains initiatives which are organized within the five (5) Operational Excellence Objective (OEO) categories as identified in the Nuclear Excellence Plan.
Initiatives under each category are divided into the following:
. Management Initiatives
- Key Backlog & Hardware Initiatives
. Key Performance Indicators NOTE: In reference to the 3 categories listed above, please note that only categories with assigned initiatives have been listed.
Each initiative has a responsible lead person and unit director expectations which correspond to deliverables in Attachment A,"ORP Deliverables."
- 1. Operational Excellence Obiective (OEO) #1 STRATEGY: BECOME A RECOGNIZED INDUSTRY LEADER Return Northeast Utilities to a position ofleadership in the US Nuclear Industry.
Establish a five-unit management model that will provide the leadership required to achieve nuclear excellence m operations by creating dramatic and fundamental change in the way we manage the nuclear program at Northeast Utilities.
Executive Sponsors: T. Feigenbaum and W. DiProfio DISCUSSION:
Foremost in this approach will be implementation of a five-Unit management model that assures the Nuclear Group's success by setting the same nuclear excellence goals for each unit and that uses best practices and common business methods. 3e specific strategic focus areas will encompass planning and direction, i ownership and expectations, and appropriate monitoring and follow through, the I major components of a successful management model. These components will. l
- Set high performance expectations and standards )
- Drive mutual accountability and self assessment Improve planning, prioritization and performance monitoring skills
. Implement best practices and common business methods ;
- Communicate directly with employees and line managers
. Assure that poor management performance is identified and resolved by senior management.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 14 of 75
1.1. Management Initiatives l 1.1.1. MANAGEMENT MODEL AND PERFORMANCE MANAGEMENT
! (RFF. NEP LD j Implement Nuclear Level Determine Course of Action (DCA) as the 4 strategic planning focal point for the organization, including i incorporating the Unit DCA into the Nuclear DCA to provide the .
- high-level focus for the Nuclear Excellence Plan. Revise the charter to l e specify the process to be used to develop, revise, conduct performance 4
reviews of and manage the Nuclear Excellence Plan. l G. Winters, Action Plan Manager j Unit Director ORP Deliverable Expectations:
q Nuclear DCA:
i = Nuclear and Unit DCA Charters are approved and DCA Team members are agreed on roles, responsibilities and expectations j associated with the DCA process. 6
=
i A schedule is established to develop and im,plement a fully l operational Nuclear DCA, in accordance with the DCA Charters 4 and the Nuclear Excellence Plan.
- a Restart initiatives not funded under the existing MP-3 budget are ,
evaluated by the Nuclear DCA in accordance with priorities [
- established by the Nuclear Excellence Plan and NU Nuclear Group ;
j key objectives. Approved initiatives receive funding. ,
j Unit DCA: ;
4 ;
A schedule is established for transition of the Unit RAC to the Unit .
j DCA, in accordance with the DCA Charters and the Nuclear !
Excellence Plan. :
j Refer to page 42 for deliverables.
4 i
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.5 1 i 1
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i MP-3 Operational Readiness Plan Rev.1 7/26/96 ;
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l 1.1.2. MANAGEMENT DEVELOPMENT AND I FADERSHIP .
(REE NEP L4)
Implement a program of management development and leadership.
Introduce 360 degree feedback systems to provide employees with a legitimate means to communicate employee perceptions on management i performance, organizational trust levels, and Nuclear Group !
effectiveness in achieving our goals.
1 H. Haynes, Action Plan Manager )
Unit Director ORP Deliverable Expectations: I
. The plan and schedule for the leadership and development training is approved and training has been started for managers and supemsors.
. The Failure Prevention and Investigation survey is complete and the results have been utilized to confirm the needs assessment for the leadership and development training.
. Evaluate the Leadership Development Curriculum against the FPI survey results to verify curriculum elements are responsive.
Refer to page 43 for deliverables.
l MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 16 of 75
1.1.3. EFFECTIVE NUCLEAR SAFETY AND OVERSIGHT -
(REE NEP 1.2) l Strengthen the role of the nuclear oversight functions (NS&O, NSAB, and SORC/PORC) and define line management expectations to assure we achieve our strategic goals for nuclear excellence.
E. Desmamis, Action Plan Manager Unit Director ORP Deliverable Expectations:
. Develo p and communicate CNO expectations for the independent oversight function to the Nuclear Group. ,
I The selection process is complete such that all managers associated directly with MP-3 are in place to carryout NS&O responsibilities.
Develop specific actions to improve effectiveness of NS&O to support review of readiness for MP-3 restart.
The NS&O assessment of the MP-3 Operational Readiness Plan is complete.
NS&O continuously monitors unit actions and provides documentation demonstrating NS&O conclusions regarding MP3s :
readiness for startup to Executive Committee.
Refer to page 44 for deliverables.
I MP-3 Operational Readiness Plan i Rev.1 7/26/96 i Page 17 of 75
1.2. Key Backlog and Hardware Initiatives 1.2.1.THE PLANT HARDWARE IS IN GOOD PHYSICAL CONDITION l AND DEMONSTRATING RELIABIF OPERATION. l Unit Director ORP Deliverable Expectations:
Documentation demonstrating that allinstalled by been reviewed ior: (Responsible Lead:B. Enoch) pass jumpers ha need/ justification compatibility with the FSAR (PI-2 assessment recommendations) l Documentation demonstrating total installed bypass jumpers less than 30. (Responsible Lead: B. Enoch)
Documentation that there are less than 11 installed bypass jumpers which are greater than 2 cycles old. (Responsible Lead: B. Enoch)
Documentation detailing the schedule for planned removal of all bypass jumpers. (Responsible Lead: B. Enoch)
Develop and approve action plans for all Maintenance Rule (a)(1) systems to restore them to (a)(2) status. (Responsible Lead: D.
Gerber)
. Documentation demonstrating that 50% of open NCRs as of 9/6/96 are closed. (Responsible Lead: D. Gerber)
. Documentation demonstrating that there are 0 (zero) NCRs greater than 60 days old without dispositions. (Responsible Lead: D. Gerber)
Documentation demonstrating all in-service tests are closed (except ,
for testing required for power ascension). (Responsible Lead: D. I Gerber)
. Documentation demonstrating all design changes are closed out within 90 days of completion. (Responsible Lead: R. Andren)
Conduct a review of the old Level of Effort (LOE) items and old l engineering work request (EWRs) in the "pending EWR file" for l i
impact on MP3 restart. Disposition them prior to plant start-up per Nuclear Safety Engineering Report recommendation of l
7/15/96, AR No. 96000413. (Responsible Lead: R. Andren)
! . Documentation that no DBDP discrepancies remain open.
! (Responsible Lead:R. Andren)
I . Documentation demonstrating that all component ids vs approved MEPL evaluations have been validated. (Responsible Lead: R.
Andren)
. Documentation demonstrating that all design or administrative l discrepancies associated with the MEPL evaluations have been l dispositioned. (Responsible Lead:R. Andren) i i~
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 18 of 75
1.2.1. Continued 4
Documentation demonstrating all PDCEs and E&DCRs generated from 1983 thru 1991, not already reviewed during the HSRT effort for effect on FSAR, have been reviewed and operability concerns addressed (PI-2 assessment recommendations).
(Responsible Lead: W Stairs)
Documentation demonstrating all PMRs have been reviewed and operability concerns dispositioned. (Responsible Lead: W Stairs)
Documentation demonstrating S & W Project Change Requests have been reviewed and operability concerns dispositioned.
(Responsible Lead: W Stairs)
Documentation that the RSS/QSS/SI hardware modifications are completed. (Responsible Lead: J. Langan)
Documentation that the RHR Pressure Locking /I'hermal Binding hardware modifications are completed.
(Responsible Lead:J. Langan)
Documentation that the "C" MSIV hard vare modifications are completed. (Responsible Lead:J. Langan)
Documentation that the MSS *MOV18 A-D hardware modifications are completed. (Responsible Lead:J. Langan)
Documentation that the CRDM Cooling Fan replacement is complete. (Responsible Lead:J. Langan)
Documentation that the Main Generator Rewedge hardware modifications are completed. (Responsible Lead:J. Langan)
Documentation that the Battery 6 Replacement is complete.
(Responsible Lead:J. Langan)
Documentation that the AOV Air Line replacements are complete ior identifled scope. (Responsible Lead:J. Langan)
Documentation that the FWS Over-pressurization modifications are completed. (Responsible Lead:J. Langan)
Documentation that the Screen Wash hardware modifications are completed. (Responsible Lead:J. Langan)
=
Documentation that the Condenser Steam Dump hardware modifications are completed. (Responsible Lead:J. Langan)
Documentation that the Service Water hardware modifications are completed. (ResponsibleLead:J.Langan) l Documentation demonstrating refurbishment of Intake Screen general area is complete. (Responsible Lead: B. Roy)
=
Documentation demonstrating that refurbishment of ESF building 24' level is complete. (Responsible Lead: B. Roy)
Documentation demonstrating that turbine building storage location project is complete. (Responsible Lead: B. Roy)
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 19 of 75
I 1.2.1. Continued j Documentation demonstrating painting of the East / West Switchgear enclosures is completc. (Responsible Lead: B. Roy)
- Documentation that operator burdens have been identified and submitted for corrective action such that .<_5 operator burdens remain to be dispositioned. (Responsible Lead: B. Pinkowitz) l Identified MCB deficiencies are dispositioned within 14 days. I 1
(Responsible Lead:B. Pinkowitz)
Conduct a review of open replacement item evaluations (RIES) for impact on MP3 restart.(Responsible Lead: D. McCory)
- Documentation demonstrating PTSCR has been initiated for 3RHS* V43. (Responsible Lead: D. McDaniel)
Document demonstrating action plan for 3HVR*FN6A/B has been developed. (Responsible Lead: D. McDaniel)
Refer to pages 45 thru 48 for deliverables.
l 1.3. Key Performance Indicators Status update package from Operational Readiness Manager is maintained separate from this document. ;
l 1.3.1. Management Effectiveness ;
- a. Engineering Backlog j
- MEPL Components Validated l
- Unresolved Operability Determinations Design Basis Data Package discrepancies 1.3.2. Material Condition
- a. Work Control AWO Status and Age AWO Backlog (T tal & Critical)
- Installed Bypass Jumpers
- Hardware Modifications Materiel Condition Upgrades
- Operator Burdens MP-3 Operational Readiness Plan
. Rev.1 7/26/96 Page 20 of 75
- 2. Operational Excellence Obiective (OEO) #2 STRNfEGY: REBUILD REGULATORY CONFIDENCE to rebuild our regulatoy margin and establish an effective working environment with regulators.
Establish a focus on safe operations through Nuclear Group-wide processes that assure safe operation, conservative decision making, conformance with regulatoy requirements, and proactive communications.
Executive Sponsors: E. DeBarba and P. Richardson DISCUSSION:
This strategy encompasses initiatives that will substantially upgrade the processes used to implement key licensing requirements and provide us with a high degree of assurance that the design and licensing bases are maintained correctly. The initiatives will also provide for proactive communications with the NRC.
2.1. Management Initiatives 2.1.1 SELF-ASSESSMENT (REE NEP 2.2)
Establish and implement a self-assessment program that will be based upon prompt identification and effective resolution of problems at all organizational levels. Integrate self-assessment with external and internal operating experience programs, and implement additional changes to transition to a learning organization. Train personnel and instill personal responsibility for problem identification and resolution.
R Stroup, Action Plan Manager Unit Director ORP Deliverable Expectations:
Generic questions prepared by Nuclear officers addressed in a separate report approved by the Executive Committee.
Assessment performed to ensure the organization understands the reasons for the current performance decline.
All MP-3 departments have completed self-assessments as assigned by the Unit Director as part of the Quarterly Self-Assessment Program.
Documentation that a formal method is in place to share results of self-assessments between departments.
Documentation demonstrating that all department self-assessments have been reviewed and recommendations have been dispositioned.
Provid:. results of PRA review for MP-3 identified deficiencies, not corrected prior to restart, documenting the impact on safety to the Unit 3 Director.
Line organizations conduct and submit Operational Readiness self-assessments as assigned.
Refer to pages 49-51 for deliverables.
MP-3 Operational Readiness Plan Rev. I 7/26/96 Page 21 of 75
i I
r 2.1.2. COMMITMENT MANAGEMENT (RFE NEP 2.3) i Upgrade the commitment management program to prioritize, assign, l monitor and manage commitments consistent with industry best !
practices. Provide management follow up to assure that commitments l are fully met.
G. Kann, Action Plan Manager:
i Unit Director ORP Deliverable Expectations:
External commitments a licable to MP-3 are entered into AITTS !
and a list provided to the nit Director for identification of start-up {
items. (Example: Local town & state commitments, public meeting i activities or commitments.) <
1 Documentation that events which occur during the current outage !
are identified and dispositioned by the MQC/PORC. l Refer to page 52 for deliverables.
2.1.3. REGULATORY COMMUNICATIONS (REE NEP 2.6) '
Implement a proactive regulatory communications program.
T Harpster; Action Plan Manager Unit Director ORP Deliverable Expectations: l
- Documentation demonstrating the results of Vertical & Horizontal Slice Reviews are acce ted by MQC for all in-scope systems and docketed with the NR
- The Document Rooms which contain information to support the MP-3 Operational Readiness Plan are established (Millstone site and NRC headquarters).
- The June 20th and July 2nd letters have been submitted to the NRC which document:
All design and configuration deficiencies identified between 2/22/96,6/13/96 and 7/1/96.
How these deficiencies were discovered How long each deficiency existed The corrective actions for each deficiency The MP-3 Operational Readiness Plan is revised as necessary and officially transmitted to the NRC.
Documentation demonstrating the 10CFR50.54f and Operation Readiness response to the NRC is a consensus product of MP3 management.
Refer to page 53 for deliverables.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 22 of 75
2.1.4. CONSERVATIVE OPERATING PHILOSOPHY A conservative operating philosophy is being demonstrated by the MP-3 staff.
M. Brothers, Action Plan Manager Unit Director ORP Deliverable Expectations Documentation that any NOVs against MP-3 are reviewed and !
dispositioned by the MOC/PORC.
]
Refer to page 54 for deliverables.
2.1.5. CORRECTIVE ACTION (REE NEP 2.1 AND ISP)
Establish and implement a common corrective action program that will determine underlying causes of problems and develop hetions that will demonstrate an effective corrective action system and include monitoring and follow up to preclude recurrence.
G. Gram, Action Plan Manager Unit Director ORP Deliverable Expectations:
Documentation demonstrating that the results of the ACR express team have been implemented.
Documentation that externally-identified problems are reviewed by the MOC and utilized to assess the effectiveness of the unit's ,
corrective action program. !
Documentation that all items identified as restart criteria are reviewed and accepted by either the MOC or Expert Panel.
. Unit Director is clearly established as the owner of the corrective i action process for his unit.
Daily chairman of the unit MRT Instructor / coach for unit MRT training Kickoff facilitator at every corrective action organizational training session for MP-3.
Use status of corrective action KPI's and status of A and B priority ACR as an agenda in every weekly staff meeting.
Use status of KPIs, Trends, and Tracking in individual performance reviews.
Group managers conduct Nuclear Organization 'Itaining on new Corrective Action Manual and ACR procedure.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 23 of 75
2.1.5. Continued
- Corrective Action Manual and Common ACR Procedure are approved and adopted by all MP-3.
Corrective Action KPI data entered for tracking purposes.
- Conduct a review oflevel A, D, & C ACRs to ensure they are processed in accordance with RP-4.
l
- Measurements of Performance developed which are used to assess l the effectiveness of the corrective action process.
. Develop core pool of at least 2 senior Root Cause Evaluators for M P-3.
Expectation will be that at least one core pool member is required l for every root cause analysis done on a unit.
- Develop Corrective Action Process trending information and guidelines:
l -
Preliminary Finalized
. Change the ACR Procedure to preclude closure of ACRs before corrective work completed.
. 100% of all open Millstone ACRs and ARs will be reviewed for data quality and MP-3 restart.
Unit specific Events Analysis Group established for MP-3.
- Develo 3 an MRT training module for the new Corrective Action Manua. and ACR Procedure.
Develop a Nuclear Organization 'Itaining Module for the new Corrective Action Manual and ACR procedure.
a Unit Director conducts MRT training on Corrective Action Manual and ACR Procedure.
NS&O will conduct an audit of a sample of closed A, B &C level
- ACRs.
Refer to pages 55-57 for deliverables.
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i MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 24 of 75
-. _. .- - - . - -- -= -. .. - - - - - . -. . - . -
- 2.1.6. CONFIGURATION MANAGEMENT (RFE NEP 2.4) !
Establish configuration management programs and processes that will !
assure conformance to design and licensing bases.
J. Vargas, Action Plan Manager ,
Unit Director ORP Deliverable Expectations: l Policies, procedures and processes have been upgraded as required i by the Configuration Management Plan. I Provide scope and audience for CMP 'Itaining to Nuclear Training
' for Implementation Plan.
Identify scope and audience for FSAR training on its use and expectations per recommendation of PI-2, Rev. 2,"MP-3 Specific Assessment."
Create a master listing of all calculations generated to date so that a proper foundation for future work is established (PI-2 assessment recommendations).
All Category 8 DCNs have been reviewed to ensure that drawings have not been changed to reflect field conditions without first ensuring the field condition is in accordance with the intended design (PI-2 assessment recommendations).
DCM has been revised to ensure the Category 8 DCNs are only used for purely administrative purposes (PI-2 assessment recommendations).
Upgrade procedures to comply with CMP Implementation Phase I.
Documentation demonstrating Phase 1 Configuration Management Plan and Configuration Controls are in place.
Develop CMP Training Implementation Plan.
Documentation demonstrating independent assessment of system slice reviews and walkdowns complete.
Refer to pages 58-59 for deliverables.
2.1.7.10CFR50.59 IMPIFMENTATION (REE NEP 2.5)
Implement an improved 50.59 safety analysis process that supports the I revised configuration management processes.
M. Kai, Action Plan Manager Unit Director ORP Deliverable Expectations:
All Operability Determinations which have identified degraded conditions have been evaluated through the 50.59 process. l Request 10CFR50.59 evaluations for abnormal plant conditions as required by restart activities.
Refer to page 60 for deliverables.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 25 of 75
2.1.8. PROCEDURE COMPLIANCE (REE ISP)
M. Brothers, Action Plan Manager Unit Director ORP Deliverable Expectations:
- Communicate expectations indicating that all programs and procedures will be followed in a verbatim manner. When a procedure problem is encountered, the expectation is that the person will stop (unless an emergency condition exists) and follow the requirements to formally correct the problem.
1 i . Review of vendor information control process complete (to verify current conditions).
l
- Revise (as necessary) and implement the vendor information control l program.
Refer to page 60 for deliverables.
l l 2.1.9. ROOT CAUSE ASSESSMENTS Corrective actions for each of the root causes.
R Blasioli, Action Plan Manager
. MP-3 Corrective Action Manager reviews all initiatives and deliverables to ensure that corrective actions for each of the root causes are in place and recommendations of the following have been adequately dispositioned.
ACR 7007 QAS Failure l
MP-3 Specific FCAT/NCAT Fundamental Causes JUMA (Joint Utility Management Assessment)
Failure of the OAS organization to identify FSAR deficiencies.
J. Warnock, Action Pfar: Manager Unit Director ORP Deliverable Expectations:
. Documentation demonstrating root cause analysis for the failure of the oversight orge:nzation to identify FSAR deficiencies is complete, and generic in.plications are identified.
Root cause analyses will be performed for identified MP-3 deficiencies.
G. Pitman, Action Plan Manager Unit Director ORP Deliverable Expectations:
- MP-3 specific root cause analyses has been completed with l recommendations to Unit 3 Director.
I
! Refer to page 61 for deliverables.
! MP-3 Operational Readiness Plan
! Rev.1 7/26/96 Page 26 of 75 l
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_ _ . _ _ _ _.m . . . . _ _ _ _ _ _ _ . _ .. _ . _ _ _ _ _ _ _ ___ _ _ _ _. ._.
l l -. ;
l .f 2.1.10.10CFR50.54(f) REVIEWLM4ALYSES l The review of analyses of and response to the 10CFR50.54(f) issues on -
l i MP-3 is complete. ;
l J. Vargas, Action Plan Manager Unit Director ORP Deliverable Expectations:
- The following 10CFR50.54f tasks are complete: [
Operational Readiness Reviews :
I -
System slice reviews and walkdowns are complete. !
Independent Assessment l t
volumes 15 & 16 was included in initial reviews. (PI-2 Assessment l'
, Recommendations)
complete. >
P
- PI-17 Review of FSAR Testing Requirements is complete and discrepancies are dispositioned.
l
grade interlocks has been dispositioned.
l Refer to page 62-63 for deliverables. ;
i t l 2.1.11. ENGINFFRING TRAINING i l Train selected staff on the procedures identified as being weaknesses on l M P-3.
H. Haynes, Action Plan Manager ;
Unit Director ORP Deliverable Expectations, j l
Provide training to the identified Engineering staff on the followmg:
Design Control Manual 10CFR50.59 NGP/ Engineering Department Instructions Refer to page 63 for deliverables. l i
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2.2. Key Backlog / hardware Initiatives 2.2.1.NRC INSPECTION ISSUES All outstanding NRC inspection issues are addressed and no operability questions remain.
J. Peschel, Action Plan Manager Unit Director ORP Deliverable Expectations:
- Identified NRC generic and Unit 3 specific communications reviewed and dispositioned.
Refer to pages 64-66 for deliverables.
2.2.2. OPERABILITY DETERMINATIONS 1
Unit Director ORP Deliverable Expectations:
. Operability determinations reviewed and any degraded conditions l evaluated for acceptability.
K. Burton, Action Plan Manager Refer to page 67 for deliverables.
2.2.3. JUSTIFICATION FOR CONTINUED OPERATIONS UCOS) l Unit Director ORP Deliverable Expectations:
. All JCOs reviewed and scheduled for resolution.
K. Burton, Action Plan Manager Refer to page 68 for deliverables.
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2.2.4. ACR REVIEW K. Burton, Action Plan hianager Unit Director ORP Deliverable Expectations: ;
All level A, B & C ACRs reviewed in accordance with RP-4, and I uncompleted corrective actions will be evaluated for significance of the remaining open items. Recommendations forwarded to the Unit Director and Corrective Action Manager.
Refer to page 68 for deliverables.
- 2.2.5. MTF ITEMS !
D. Gerber; Action Plan Afanager Unit Director ORP Deliverable Expectations:
All MTF items (except NCRs) reviewed and incorporated into l
AITTS.
Refer to page 68 for deliverables.
I 2.2.6.OSD ITEMS
- T. Sullivan, Action Plan Afanager Unit Director ORP Deliverable Expectations
l All OSD open items are reviewed and resolved as required.
Refer to page 69 for deliverables.
i 2.2.7.NSAB ITEMS M. Brothers, Action Plan hianager i Unit Director ORP Deliverable Expectations:
l
- All NSAB open items are dispositioned.
Refer to page 69 for deliverables.
2.3. Key Performance Indicators l 2.3.1. Corrective Action Program Effectiveness
- Shutdown Risk Evolutions
- Outage-related LERs
- Outage-related Medical Events Outage Radiation Exposure Start-up Prerequisite Activities Open Operational Readiness Plan Deliverables Completed MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 29 of 75 i
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- 3. Operational Excellence Ob_iective (OEO) #3 STRATEGY: IMPROVE COMMUNICATIONS / MORALE to develop and maintain a high degree of trust between management and the rest of the organization. Rebuild employee confidence that we will go fonvard with nuclear excellence as our measure of succese.
Rebuild employee confidence in management by holding managers accountable for the performance results, by demonstrating integrity to our stated goals and by modeling the required behaviors and values (teamwork, open and honest communications, conservative decision making, and accountability for results).
Executive Sponsors: D. Miller and W. Riffer/R. Kacich DISCUSSION:
Employee trust and confidence will be rebuilt by clearly communicating the elements of the goals, strategies and initiatives for achieving nuclear excellence and how each employee can contribute to these goals. The expectation that managers and supervisors are responsible to remove barriers preventing employees from solving problems and for resolving employee concerns will be communicated. Management is working to create an environment that values employee contributions and actively resolves employee issues at the level in the organization closest to the issue.
3.1. Management Initiatives 3.1.1. OPTIMIZE ORGANIZATIONAL STRUCTURE (REE NEP 3.1)
Evaluate and implement the organizational and process changes from the Nuclear Re-Engineering Team (NRET) study that will stabilize the organization to the maximum extent possible for the one-to-two year time horizon.
R. Kacich, Action Plan Manager Unit Director ORP Deliverable Expectations:
. The recommendations from the NRET to stabilize the organization have been approved by the Nuclear DCA, and any changes affecting MP-3 are on schedule.
Refer to page 70 for deliverables.
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MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 30 of 75
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l 3.1.2. EMPLOYEE CONCERNS TASK PLAN (REE NEP 3.2 AND ISP) !
Evaluate and improve the ability of functional area managers to resolve employee issues and communicate effectively with employees, including satisfactory resolution of concerns and issues. Integrate the Employee Concerns Task Plan with the Nuclear Excellence Plan.
L. Chatfield, Action Plan Manager Unit Director ORP Deliverable Expectations: I
. The Chief Nuclear Officer (CNO) establishes, communicates and reinforces specific performance and behavior expectations for all !
individuals m the Nuclear Group, and especially for management
, personnel. Important here is demonstrated executive and semor !
l management presence in the plants. ;
l An assessment of MP-3 should show that a high percentage of MP-3 ,
personnel feel comfortable bringing safety concerns to their chain of command or the Employee Concerns Program.
l Employee concerns have been reviewed and no operability questions are unresolved.
- Operational Readiness Plan is clearly communicated to unit 3 ;
l personnel, with key milestones identified. l
=
l Conduct Failure Prevention and Investigation Culture Survey. !
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Finalize and enter key Employee Concerns assignment milestones l l
into AITTS.
Develop Employee Concerns Program monitoring strategy.
NRC submittal on KPIs (including Employee Concerns).
l Develop plan for Employee Concerns related programs / procedures l enhancements includmg a dedicated ECP Rep. established for MP-3.
Implement measures to improve overall effectiveness of internal communications among management and employees in the Nuclear l Group, notably in the area of CNO expectations and resolving employee concerns.
Refer to pages 70-71 for deliverables.
1 MP-3 Operational Readiness Plan l Rev.1 7/26/96
! Page 31 of 75 l
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1 3.1.3. EMPLOYEE COMMUNICATIONS (REE NEP 3.3)
. Restructure the vehicles used to communicate within the Nuclear Group.
Establish a communications program to, communicate expectations to the Nuclear Group for the excellence measures, objectives, strategies and initiatives, and communicate performance results.
D. Winn, Action Plan Manager l
l Unit Director ORP Deliverable Expectations:
)
- MP-3 personnel will have attended a presentation of the Nuclear i Excellence Plan and its relation to the MP-3 Operational Readiness '
Plan and the MP-3 restart.
Refer to page 72 for deliverables.
i 3.1.4. EMPLOYEE REVIEW COMMITTEE >
l Employees select committee members to conduct an independent assessment of the unit's readiness for restart.
T Lyons, Action Plan Manager Unit Director ORP Deliverable Exnectations:
i l
Employee Review Committee to conduct an independent assessment i of umt readiness for restart and provide documentation to the ORP j Manager.
Refer to page 72 for deliverables.
- 3.2. Key Performance Indicators l 3.2.1. In development, none available at this time.
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MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 32of 75
. _ = . _ . . -
- 4. Operational Excellence Objective (OEO) #4 STRATEGY: INCREASE TEAMWORK creating a high level of -
cooperation and mutual support among all five units, allowing us to develop a strong, shared sense of ownership and accountability throughout the organization for five-unit success.
Executive Sponsors: E Rothen and M. Brothers DISCUSSION:
Establish ownership and expectations, resolve questions of roles and responsibilities, measure performance, and hold managers accountable for results.
4.1. Management Initiatives ,
4.1.1. CONTINUOUS IMPROVEMENT TEAM AND STRATEGIES (REE NEP 4.1)
Establish a peer group improvement strategy and program focused on process improvements modeled on other rnulti-site utilities, and take advantage oflessons learned from the quick-hit teams and ;
problem-solving approaches used by the Nuclear Re-Engineering Team.
W Nevelos, Ac: ion Plan Manager ,
Unit Director ORP Deliverable Expectations:
- Members identified for Continuous Improvement Team ,
. Initial meeting held for Continuous Improvement Team Refer to page 73 for deliverables.
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MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 33 of 75 l
4.1.2. STANDARDIZE TECHNICAL MAINTENANCE AND I OPERATIONS PROCEDURES (REE NEP 4.2)
This initiative also covers the Procedure Upgrade Project under I
" Improving Station Performance."
T Kirkpatrick, Action Plan Manager i Unit Director ORP Deliverable Expectations:
- Technical procedure issues identified in MP-3 deficiencies have been reviewed and dispositioned by the Department Procedure Coordinators to support MP-3 restart (OPS, I&C, MNT, TS, DE, GTS, HP, & CHM).
Refer to page 73 for deliverables.
4.1.3. RESOURCE SHARING AND STAFF UTILIZATION (REE NEP 4.3)
W Can; Action Plan Manager Unit Director ORP Deliverable Exnectations:
- Communicate to the entire organization that we are reassessing our previously published position of driving to 2,000 employees in NU Nuclear.
Refer to page 73 for deliverables.
4.2. Key Performance Indicators 4.2.1.In development, none available at this time.
I MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 34 of 75
.. =. .. . __ - .. .-
- 5. Operational Excellence Ob_iective (OEO) #5 STRATEGY: IMPROVE EMPLOYEES' ABILITY TO CONDUCT WORK SUCCESSFULLY by enabling the organization at all levels to complete required work successfully by providing lasting solutions to problems, maintaining effective ,
configuration control and operating effectively and efficiently. j Assure that management is provided with the vehicles to receive organizational feedback on barriers to performance and takes appropriate action.
Executive Sponsors: S. Scace and J. LaPlatney DISCUSSION:
The strategy will also identify additional barriers to achievement of the Nuclear Excellence objectives over the next two years, including organizational, personnel, and IT.
5.1. Management Initiatives 5.1.1. ALIGN HUMAN RESOURCES (REE NEP 5.2)
Develop new strategies and approaches for a comprehensive reward and incentive process coupled with the strategic goals and key performance indicators. This initiative will encompass NPIP, PRP and other existing incentive programs.
R. Romer; Action Plan Manager Unit Director ORP Deliverable Expectations:
Approve the 1996 NPIP program revisions and communicate them to the organization. ,
Refer to page 74 for deliverables.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 35 of 75
5.1.2.THE MP3 STAFF DISPLAYS THE ABILITY TO PERFORM WORK ;
SAFELY AND MAINTAIN THE PLANT ;
M. Brothers & J. Langan Responsible Leads ;
I Unit Director ORP Deliverable Expectations:
1 l e Documentation demonstrating review of all priority 1,2, & 3 AWOs :
for restart impact is complete and any issues identified are dispositioned.
l l . Documentation demonstrating that priority 1,2 & 3 AWO backlog is ;
i less than 500. ,
- Documentation that the AWO backlog ofless than 500 contains no i safety significant items. !
. Documentation that an unplanned entry into LCO(s) goal has been established and is being monitored by unit management.
- Identify a " Barrier Breaker" lead for unit 3. ,
l l Refer to page 74 for deliverables.
, 5.1.3. AN ADEOUATE TESTING PROGRAM EXISTS TO DEMONSTRATE EOUIPMENT OPERABILITY j J. Langan, Action Plan Manager Unit Director ORP Deliverable Expectations:
. The centralized surveillance tracking program is in place, functional ,
and being run by WP/OM.
- All surveillances are scheduled within required periodicity based on ;
new RF06 date.
.- LLRT tests are completed and documented.
i
- Documentation that all applicable mode punch lists are complete !
j per outage schedule.
l EDG tests are completed and documented.
= ESF/ LOP tests are completed and documented.
l .
Refer to page 75 for deliverables.
5.2. Key Performance Indicators l 5.2.1. Rework (goal to maintain less than 1%, bases on total work complete).
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 36 of 75
IV. READINESS ASSESSMENT PROCESS i
- 1. Methodolony j The readiness of MP-3 for restart will incorporate 3 levels of internal review.
= Unit Director l l
=
Nuclear Safety and Oversight i .
= NU Executive Committee l The readiness assessment process involves the collective review and assessment of events and activities, and associated resolutions to determine if MP-3 is ready to resume operation. The primary contributor to Millstone management's readiness l conclusions will be the satisfactory closeout of the Operational Readiness Plan deliverables. The addition or deletion of initiatives / deliverables may occur only with l the approval of the MP-3 Unit Director.
Also providing input into readiness decisions is the closeout of several self-assessment initiatives. These will be reviewed and accepted by the Unit Director with any recommendations properly dispositioned. Once approval from the NRC is received to restart, the integrated outage schedule and Operations Department procedures will j provide direction regarding start-up actions.
l 2. Development of Readiness Deliverables l 2.1. Identification - Readiness items generally evolved from materiel condition j issues, NRC inspections, Millstone assessment activities, MP-3 management, Nuclear Excellence Plan, and Nuclear Safety & Oversite. Attachment A
! provides detailed deliverables.
2.2. Addition of Deliverables - Newly identified MP-3 problems may warrant being added as restart items in the form of ORP deliverable (s). The direction and criteria of Section IV.2 serves as guidance for classifying newly identified problems for resolution.
2.3. Deletion of Deliverables - It may be appropriate to delete deliverables from the MP-3 Operational Readiness Plan under certain conditions. If a I deliverable has no direct or indirect impact on the ability to safely operate l MP-3 and is not a corrective action required by ORP bases documents (root cause analyses, NRC inspection findings, etc.) it may be considered for deletion. Deletion of a deliverable will be coordinated and reviewed by the MP-3 Operational Readiness Manager and Corrective Action Manager and be l approved by the Unit Director.
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Page 37of 75
- 3. Development of The Outage Schedule Work activities for the outage are controlled in accordance with an integrated outage schedule that contains activities that must be completed prior to start-up.
In addition to satisfying Technical Specification requirements for equipment operability, the schedule will contain other maintenance activities.
Activities must be categorized as a restart item if the issue involves or could reasonably lead to:
. an event, component failure, deficiency, or condition that could result in operation in an LCO action statement, or failure to perform a required surveillance test or other license requirement or meet a commitment to an outside agency, or conditions that have resulted in repetitive safety system equipment failures, or
. potential licensing basis deficiencies requiring maintenance to restore the plant to conforming conditions (i.e., deficiencies in safety-related or other qualified equipment, e.g., EQ, Appendix R, or seismic), or items that impact plant operability, raise an unreviewed safety question, or indicate a discrepancy between the FSAR and the as-built plant or an operating procedure.
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.
Work priorities 1 & 2 as shown in Figure 1," Work Priorities" are start-up items and priority 3 may be designated as a start-up item as determined by management. Priority 4 is not start-up related.
The ORP (Restart) Punchlist is the responsibility of the ORP Manager. Restart items will be determined by MRT (for all ACRs) and Expert Panel (for other deficiencies). To remove an item from the ORP Punchlist, ORP Manager approval is required.
Close-out of startup prerequis: items shall be the responsibility of the cognizant department manager. Startup purequisite items shall be closed out by normal process (example: action requests, ACRs) and be presented to the Management Review Team (MRT), Unit Project Manager (UPM), or Expert Panel for review as appropriate.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 38 of 75 i I
Figure 1 Work Priorities CATEGORY PRIORITY 1 PRIORITY 2 PRIORITY 3 PRIORITY 4 l
Plant or Equipm:nt Prevents operation at Equipment problem Improves unit Generalplant Reliability expected powerlevel that jeopardizes performance, improvement and or requires contmued operation availabilit ,and equipment repairs immediate action to at expected power operabili . Work which can be done avoid equipment level maybe se eduled when time permits damage and completedin a timely manner j Personnel Safety Significant safety Safety hazard which Personnel safety .
4 >
hazard requiring requires attention to improvements that ,Aw -
immediate actionin avoid personnel are needed but do ' %twW order to avoid injury not present an %o k -
personnelinjury immediate hazard ; _ ,
En Outage Work immediate action Ajob on the critical May become Does not affect required to prevent path schedule critical path work criticalpath adversely affecting or or significantly schedule and may be impeding critical affecting outage deferred tolater path schedule schedule outage without affecting reliability Regulatory Problem that results Jeopardizes Routine work l Requirement in failing to meet a compliance with required by -
regulatory regulatory regulations requirement requirements , >
Preventive e' - <
Overdue PM which Routine PM work Routine PM work l
Maintenance ' ' '
has been determined by Operations or
'L.- Maintenance i
- supervision to l
'} require a higher priority
. ep - ,<.
Security Requires multiple Requires Security High priority CM, Routine CM, PM, or Requirement Security Guard Guard posting and PM, SV, or modification work posting and major excessive overtime modification work system failure is hours will be or imminent or has expended unless or occurred addressed promptly Deterioration to a i Condition is situation where or or expected to postmg is required, deteriorate within but is not expected Major part of There are inadequate I week to a point in the near future security system has personnel to where Security failed creating a compensate for Guard posting will degradation of additional failures be required security which cannot beyond this event be compensated i
MP-3 Operational Readiness Plan Rev. I 7/26/96 Page 39 of 75
V. CLOSEOUT OF OPERATIONAL READINESS PLAN DELIVERABLES.
The following criteria should be used in preparing, reviewing and approving the closure of Operational Readiness Plan deliverables. Preparation and review of these deliverable packages should verify that:
- the deliverable statement has been met
- the deliverable completion quality supports safe restart and operation of MP-3
- the documentation is sufficient to provide an auditable record of actions taken
- 1. Guidelines The following criteria are guidelines. Some of the criteria may not be applicable to all deliverable packages. Reviewers may want to add additional criteria based on theirjudgement and expertise of the specific deliverable.
1.1. The deliverable package is approved and signed by the responsible lead.
1.2. The package contains a cover memo outlining the description of the deliverable, the process used to satisfy it, and a summary of the results.
1.3. The package contains memos, forms, printouts and any other paperwork evidence necessary to judge that the deliverable statement has been met.
1.4. Evidence that corrective actions are implemented to prevent recurrence and address root cause findings (as applicable) of the problems which created the deliverable.
1.5. Any licensing basis or design basis issues raised by the deliverable or its process have been resolved.
1.6. Any operability or restart issues raised by the deliverable or its process have been resolved.
1.7. Key Performance Indicators are developed (or updated) to track deliverable items or processes.
1.8. If the deliverable is tied to a formal root cause analysis finding, include applicable sections of the root cause analysis.
1.9. If the deliverable statement cannot be met, discuss with Operational Readiness Manager.
1.10. Self-Assessment plans include monitoring deliverable items or processes.
1.11. The deliverable package is a stand-alone document.
1.12. The approved deliverable package is returned to the Operational Readiness Manager for inclusion in the Operational Readiness Document Library.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 40 of 75 1
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- 2. Deliverables close-out process f The following describes the general steps which should occur to close out a !
deliverable package:
l 4
l J
2.1. When the responsible lead has assembled a complete deliverable package, ,
forward it to the Operational Readiness Manager who will screen it for completeness and consistency.
~
2.2. The Operational Readiness Manager will determine which committee ;
j (PORC, or Expert Panel) should review and approve closure of the package.
2.3. The responsible lead will schedule the package to be reviewed by the l appropriate committee and distribute copies of the package to the committee ,
members prior to the review meeting so they will have an opportunity to look at the information before the meeting. .
l 2.4. The responsible lead will present the package for review / approval at the designated committee meeting.
2.5. The designated committee should formally review the package and if f satisfactory, indicate its approval. If the package is not satisfactory, the i committee should indicate to the responsible lead what additional action is required.
2.6. Original, approved deliverable packages must be forwarded to the Operational Readiness Manager for inclusion in the Operational Readiness i Library, 2.7. Ifit the final ORP Deliverable for that section, the responsible lead can now !
be signed off as complete. When all signatures for a given section are !
complete the Unit Director Review for acceptance and signature occurs. i Note: Closure of individual action request item guidance documentation is being developed and will also be included in a future revision. For the interim period, contact the Operation Readiness Manager.
Operational Readiness Assessment Assessments will be conducted by a review of the deliverables assigned and completed in Attachment A.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 41 of 75
1 1
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Attachment A l
"ORP Deliverables" t
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1 1
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Attachment A - ORP Dcliver:bles Operational Excellence Objective (OEO) #1 Deliverables Associated with Becoming a Recognized Industry Leader i
1.1.1, Management Model & Performance Management Responsible Lead Date Due Description Date to Date i MQCIPORC Complete ,
l G. Winters 7/12/96 Nuclear DCA establishes MP-3 as the priority N/A 7/12/96 l l restart effort for the NU Nuclear Organization.
l G. Winters 8/16/96 Nuclear and Unit DCA Charters are approved N/A ,
l and DCA Team members are agreed on roles, j l responsibilities and expectations associated with !
I the DCA process. l G. Winters 8/16/96 A schedule is established to develop and N/A implement a fully operational Nuclear DCA, in I accordance with the DCA Charters and the Nuclear Excellence Plan. l l G. Winters 10/4/96 Restart initiatives not funded under the existing N/A MP-3 budget are evaluated by the Nuclear DCA in accordance with priorities established by the l Nuclear Excellence Plan and NU Nuclear 1 i
Group key objectives. Approved initiatives I receive funding.
G. Winters 10/4/96 A schedule is established for transition of the N/A Unit RAC to the Unit DCA,in accordance with the DCA Charters and the Nuclear Excellence Plan.
G. Winters Signature Date Accepted by Unit Director Signature Date i
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MP-3 Operational Readiness Plan Rev.1 7/26/96 l Page 42 of 75 i
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Attrchment A - ORP Deliverr.bles Operational Excellence Objective (OEO) #1 l Deliverables Associated with Becoming a Recognized Industry Leader 1.1.2. Management Development and Leadership l Responsible Lead Date Due Description Date to Date AfQQPORC Complete H.Ilaynes 7/31/96 The plan for MP-3 to begin the leadership &
development training is approved by MP-3 management, and training has been started for managers and supervisors.
M. Brown 8/9/96 The FPI survey is complete and the results have been utilized to confirm the needs assessment for the leadership and development training.
H. Haynes 8/9/96 Evaluate the Leadership Development Curriculum against the FPI survey results to verify curriculum elements are responsive.
M. Brown Signature Date H. Haynes Signature Date Accepted by 2 Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 43 of 75
I Attrchment A - ORP Deliverables Operational Excellence Objective (OEO) #1 Deliverables Associated with Becoming a Recognized Industry Leader 1.1.3. Effective Nuclear Safety and Oversight Responsible Lead Date Due Description Date to Date blQCIPORC Complete :
T. Feigenbaum 8/30/96 Develop and communicate CNO expectations for the independent oversight function to the Nuclear Group.
E. Desmarais 8/16/96 The selection process is complete such that all N/A managers associated directly with MP-3 are in place to carryout NS&O responsibilities.
E. Desmarais 9/27/96 An action plan is in place to ensure the NS&O organization is functional and effectiveness is demonstrated.
D. Miller 7/2/96 The NS&O assessment of the MP-3 N/A 7/2/96 Operational Readiness Plan is complete.
D. Miller 10/9/96 NS&O continuously monitors unit actions and N/A provides documentation demonstrating NS&O conclusions regarding MP3s readiness for startup to Executive Committee.
T. Feigenbaum ;
Signature Date i E. Desmarais Signature Date !
D. Miller Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 44 of 75
?
l Att:chment A - ORP Deliverables \
l Operational Excellence Objective (OEO) #1 Deliverables Associated with Becoming a Recognized Industry Leader l 1.2.1. Plant Hardware in Good Physical Condition l
Responsible Lead Date Due Description Date to Date MQCIPCRC Complete i R. Enoch 9/27/96 Documentation demonstrating that all installed bypass jumpers have been reviewed for need/ justification and compatibility with the FSAR.
l R. Enoch 9/27/96 Documentation demonstrating total installed l bypassjumpers less than 30. I R. Enoch 9/27/96 Documentation that there are less than 11 installed bypass jumpers which are greater than 2 cycies old.
R. Enoch 8/30/96 Documentation detailing the schedule for planned removal of all bypass jumpers.
l R. Enoch Signature Date 1.2.1. Plant Hardware in Good Physical Condition (continued) l i Responsible Lead Date Due Description Date to Date 1
MQCIPORC Complete D. Gerber 8/30/96 Develop and approve action plans for all N/A Maintenance Rule (a)(1) systems to restore them to (a)(2) status.
D. Gerber 10/4/96 Documentation demonstrating that 50% of l open NCRs as of 9/6/96 are closed.
D. Gerber 9/2796 Documentation demonstrating that there are 0 (zero) NCRs greater than 60 days old without j dispositions.
D. Gerber 10/4/96 Documentation demonstrating all in-service l tests are closed (except as required for power l ascension).
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D. Gerber Signature Date l
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1 MP-3 Operational Readiness Plan
! Rev.1 7/26/96 Page 45 of 75
l Attrchment A - ORP Deliverables i Operational Excellence Objective (OEO) #1 Deliverables Associated with Becoming 9 Recognized Industry Leader 1.2.1. Plant Hardware in Good Physical Condhion (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete R. Andren 9/27/96 Documentation demonstrating all design i changes are closed out within 90 days of l completion. j R. Andren 9/27/96 Conduct a review of the old Level o' '
Effort (LOE) items and old engineering work request (EWRs) in the "pending EWR file" for impact on MP3 restart. Disposition them prior to plant start-up per Nuclear Safety Engineering Report recommendation of !
7/15/96, AR No. 96000413.
l R. Andren 9/27/96 Documentation that no DBDP discrepancies !
remam open.
R. Andren 9/27/96 Documentation demonstrating that all component ids vs approved MEPL evaluations ,
l have been validated. I R. Andren 9/27/96 Documentation demonstrating that all design or administrative discrepancies associated with the MEPL evaluations have been dispositioned.
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R. Andren i Signature Date !
l 1.2.1. Plant Hardware in Good Physical Condition (continued) i Responsible Lead Date Due Description Date to Date MQCIPORC Complete l W. Stairs 8/30/96 Documentation demonstrating all PDCEs and N/A
! E&DCRs generated from 1983 thru 1991, not i already reviewed during the HSRT effort for l effect on FSAR, have been reviewed and operability concerns addressed.
W. Stairs 8/30/96 Documentation demonstrating all PMRs have N/A been reviewed and operability concerns dispositioned.
W. Stairs 8/30/96 Documentation demonstrating S & W Project N/A l Change Requests have been reviewed and operability concerns dispositioned. j W. Stairs Signature Date l
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 46 of 75 l
Attachment A - ORP Deliver:bles Operational Excellence Objective (OEO) #1 Deliverables Associated with Becoming a Recognized Industry Leader 1.2.1. Plant Hardware in Good Physical Condition (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete J.Langan 8/30/96 Documentation that the RSS/QSS/SI hardware N/A modifications are completed.
J.Langan 8SO/96 Documentation that the RHR Pressure N/A Locking / Thermal Binding hardware modifications are completed.
J.Langan 8/30/96 Documentation that the "C" MSIV hardware N/A modifications are completed.
J.Langan 8SO/96 Documentation that the MSS *MOV18 A-D N/A hardware modifications are completed.
J.Langan 8SO/96 Documentation that the CRDM Cooling Fan N/A replacement is complete.
J.Langan 8/30/96 Documentation that the Main Generator N/A Rewedge hardware modifications are completed.
J.Langan 850/96 Documentation that the Battery 6 Replacement N/A is complete.
J.Langan 8SO/96 Documentation that the AOV Air Line N/A replacements are complete for identified scope.
J.Langan 8S 0/96 Documentation that the FWS N/A Over-pressurization modifications are completed.
J.Langan 8/30/96 Documentation that the Screen Wash hardware N/A modifications are completed.
J.Langan 8S 0/96 Documentation that the Condenser Steam N/A Dump hardware modifications are completed.
J.Langan 8S 0/96 Documentation that the Service Water N/A hardware modifications are completed.
J.Langan Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 47 of 75
Attachment A - ORP Delivcrebles Operational Excellence Objective (OEO) #1 Deliverables Associated with Becoming a Recognized Industry Leader 1.2.1. Plant Hardware in Good Physical Condition (continued) l Responsible Lead Date Due Description Date to Date MOCIPORC Complete R.B.Roy 8/30/96 Documentation demonstrating refurbishment of N/A Intake Screen general area is complete.
R.B. Roy 8/30/96 Documentation demonstrating that N/A refurbishment of ESF building 24' level is complete.
R.B. Roy 8/30/96 Documentation demonstrating that turbine N/A building storage location project is complete.
R.B. Roy 8/30/96 Documentation demonstrating painting of the N/A East / West Switchgear enclosures is complete.
R.B. Roy Signature Date 1.2.1. Plant Hardware in Good Physical Condition (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete B. Pinkowitz 9/27/96 Documentation that operator burdens have been N/A identified and submitted for corrective action such that <_5 operator burdens remain to be dispositioned.
B. Pinkowitz 9/27/96 Identified MCB deficiencies are dispositioned N/A within 14 days.
D. McCory 9/27/96 Conduct a review of open replacement item
, evaluations (RIES) for impact on MP3 restart.
l D. McDaniel 9/27/96 Documentation demonstrating PTSCR has
- been initiated for 3RHS*V43.
D. McDaniel 9/27/96 Document demonstrating action plan for 3HVR'FN6A/B has been developed.
l l B. Pinkowitz Signature Date D. McCory i Signature Date l D. McDaniel l Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 48 of 75
l Att chment A - ORP Deliver:bles '
Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuildine Reculatory Confidence 2.1.1. Self-Assessment :
Responsible Lead Date Due Description Date to Date MQCIPORC Complete R. Kacich 8/30/96 Generic questions prepared by Nuclear officers addressed in a separate report approved by the i Executive Committee. i
- 1. Do we understand the reasons for our current performance decline? l
- 2. Are you addressing the root causes for our performance decline?
- 3. Have you identified and have plans to ,
address the generic issues that could have l
resulted from the identified root causes?
- 4. How will you prevent the same problems I from occurring in the future?
- 5. How do you know you areimproving? '
- 6. How can you demonstrate current and l continuing conformance with the design l andlicensing basis?
- 7. Do we have the necessary resources to achieveNuclearExcellence? Have management's expectations been communicated on nuclear excellence?
- 8. Are there strong and effective oversight I
functions in effect that will identify negative {
trends? l 1
- 9. Do you understand the root causes of Employee Concerns and have you implemented a plan to address these?
- 10. Are the roles and responsibilities clear in the organization?
R. Kacich Signature Date 1
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MP-3 Operational Readiness Plan l
Rev.1 7/26/96 1 Page 49 of 75
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Attechment A - ORP Delivermbles Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.1. Self-Assessment (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete T. Feigenbaum 8/30/96 Assessment performed to ensure the organization understands the reasons for the current performance decline.
T. Feigenbaum Sigttature Date 2.1.1. Self-Assessment (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete P. Stroup 8/30/96 All MP-3 departments have completed self-assessments as assigned by the Unit Director as part of the Quarterly Self-Assessment Program R. Enoch 8/30/96 Documentation that a formal method is in place N/A to share results of self-assessments between departments.
R. Enoch 9/27/96 Documentation demonstrating that all N/A department self-assessments have been reviewed and recommendations have been dispositioned.
D. Dube 8/16/96 Provide results of PRA review for MP-3 identified deficiencies, not corrected prior to restart, documenting the impact on safety to the Unit 3 Director.
P. Stroup Signature Date R. Enoch Signature Date D. Dube Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 50 of 75
Att:chment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.1. Self-Assessment (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete Line 9/27/96 Line organizations conduct and submit Organizations Operational Readiness self-assessments as assigned.
Tech Support Eng.
Dept. Manager Signature Date Design Engineering Dept. Manager ._.
Signature Date Operations Dept.
Manager Signature Date Maintenance Dept.
Manager Signature Date I & C Dept.
Manager Signature Date WP&OM Dept.
Manager Signature Date Accepted by Unit Director Signature Date l
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l MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 51 of 75
Attahment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuildine Regulatory Confidence 2.1.2. Commitment Management Responsible Lead Date Due Description Date to Date MGCIPORC Complete G. Kann 9/27/96 Externalcommitments applicable to MP-3 are entered in AITTS and a listing provided to the Unit Director for identification of start-up items.
M. Brothers / 9/27/96 Documentation that events which occur during Designee the current outage are identified and dispositioned by the MOC/PORC.
G. Kann Signature Date M. Brothers /
Designee Signature Date Accepted by Unit Director !
Signature Date :
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MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 52of 75
Attachment A - ORP Delivercbles Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.3. Regulatory Communications Responsible Lead Date Due Description Date to Date MQCIPORC Complete M. Brothers / 8/16/96 Documentation demonstrating the results of Designee Vertical & Horizontal Slice Reviews are accepted by MOC for allin-scope systems and docketed with the NRC. l T. Harpster 8/16/96 The Document Rooms which contain N/A information to support the MP-3 Operational Readiness Plan are established.
T Harpster 6/20/96 The deficiency letters have been submitted to N/A 6/20/96 7/2/96 the NRC which document: 7/2/96 Identified design and configuration management deficiencies How these deficiencies were discovered a
Howlong each deficiency existed The corrective actions for each deficiency Note: Dates will be added here to reflect the updates transferred to theNRC.
T. Harpster 7/2/96 The MP-3 Operational Readiness Plan is N/A 7/2/96 revised as necessary and officially transmitted to the NRC.
Note: Dates will be added here to reflect the updates transferred to the NRC.
M. Brothers /
Designee Signature Date T. Harpster Signature Date Accepted by Unit Director Signature Date i MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 53 of 75
Attachment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidencs 2.1.3. Regulatory Communications (continued) l l
Responsible Lead Date Due Description Date to Date ;
MQCIPORC Complete l
T. Harpster 10/10/96 Documentation demonstrating the N/A i 10CFR50.54f and Operation Readiness i response to the NRC is a consensus product of MP3 management.
T. Harpster Signature Date Accepted by Unit Director Signature Date 2.1.4. Conservative Operating Philosophy Responsible Lead Date Due Description Date to Date MQCIPORC Complete l M. Brothers / 9/27/96 Documentation that any NOVs against MP-3 l Designee are reviewed and dispositioned by the !
MOC/PORC.
M. Brothers /
Designee Signature Date Accepted by Unit Director Signature Date l
l MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 54 of 75
Attechment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.5. Corrective Actions ResponsibleLead Date Due Description Date to Date MQCIPORC Complete M. Brothers / 10/4/96 Documentation ddonstrating that the results Designee of the ACR express team have been implemented.
! M. Brothers / 10/4/96 Documentation that externally-identified l Designee problems are reviewed by the MQC and utilized l to assess the effectiveness of the unit's corrective action program.
M. Brothers / 9/27/96 Documentation that all items identified as De.dgnee restart criteria are reviewed and accepted by .
either the MOC or Expert Panel. l M. Brothers / 9/27/96 Unit Director is clearly established as the owner Designee of the corrective action process for their units.
. Daily chairman of the unit MRT Instructor / coach for unit MRT training Kickoff facilitator at every corrective action
, organizational training session for MP-3.
l Use status of corrective action KPI's and i status of A and B priority ACR as an agenda in every weekly staff meeting.
Use status of KPIs, Eends, and Tracking in individualperformance reviews.
l M. Brothers / 9/27/96 Group managers conduct Nuclear Organization Designee Rainmg on new Corrective Action Manual and ACR procedure.
M. Brothers /
Designee Signature Date i
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l Attcchment A - ORP Deliverabl:s l Operational Excellence Objective (OEO) #2 l
. Deliverables Associated with Rebuildine Reenlatory Confidence l
2.1.5. Corrective Actions (continued) l Responsible Lead Date Due Description Date to Date MQCIPORC Complete G. Gram 8/30/96 Corrective Action Manual and Common ACR ;
Procedure are approved and adopted by MP-3.
I G. Gram 10/4/96 Corrective Action KPI data entered for tracking purposes. !
G. Gram 8/30/96 Conduct a review oflevel A, B, & C ACRs to j ensure they are processed in accordance with '
RP-4.
G. Gram 8/30/96 Measurements of Performance devcloped which j are used to assess the effectiveness of the l corrective action process.
G. Gram 10/4/96 Develop core pool of at least 2 senior Root !
Cause Evaluators for MP-3.
G. Gram 9/27/96 Expectation will be that at least one core pool member is required for every root cause analysis done on a unit.
G. Gram Develop Corrective Action Process trending information and guidelines:
8/16/96 + Preliminary 8/30/96
- Finalized G. Gram 10/4/96 Change the ACR Procedure to preclude closure of ACRs before corrective work completed.
G. Gram 9/27/96 100% of all open Millstone ACRs and ARs will be reviewed for data quality and MP-3 restart.
G. Gram 10/4/96 Unit specific Events Analysis Group established l for MP-3.
G. Gram Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 56of 75
Attrchment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.5. Corrective Actions (continued)
Responsible Lead Date Due Dzscription Date to Date MQCIPORC Complete S. Herd 8/16S6 Develop an MRT training module for the new Corrective Action Manual and ACR Procedure.
S. Herd 8/16S6 Develop a Nuclear Organization Training Module for the new Corrective Action Manual and ACR procedure.
K. Gosselin 8/30S 6 Unit Director conducts MRT training on Corrective Action Manual and ACR Procedure.
M. Brown 8/30S 6 NS&O will conduct an audit of a sample of closed A. B &Clevel ACRs.
S. Herd Signature Dcte M. Brown Signature Date K. Gosselin Signature Date Accepted by Unit Director Signature Date I
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l MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 57 of 75 l
Atttchment A - ORP D:liverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.6. Configuration Management Responsible Lead Date Due Description Date to Date MQCIPORC Complete J. Vargas 8/16/96 Policies, procedures and processes have been upgraded as required by the Configuration Management Plan.
J. Vargas 7/26/96 Provide sco and audience for CMP Training N/A 7/12/96 to Nuclear raining for Implementation Plan J. Vargas 9/27/96 Create a master listing of all calculations generated to date so that a proper foundation for future work is established (PI-2 assessment recommendations).
J. Vargas 8/30/96 All Category 8 DCNs have been reviewed to ensure that drawings have not been changed to reflect field conditions without first ensuring the field condition is in accordance with the -
intended design (PI-2 assessment recommendations).
J. Vargas 9/27/96 DCM has been revised to ensure the Categ,ory 8 DCNs are only used for purely administrative purposes (PI-2 assessment recommendations).
J. Vargas Signature Date
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MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 58 of 75
Attachment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.6. Configuration Management (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete P. Blasioli 8/30/96 Identify scope and audience for FSAR training on its use and expections per recommendation of PI-2, Rev. 2,"MP-3 Specific Assessment."
R.Cox 8/16/96 Documentation demonstrating Phase 1 N/A Configuration Management Plan and Configuration Controls are in place.
R.Cox 8/16/96 Upgrade procedures to comply with CMP Implementation Phase 1.
H. liap.es 8/30/96 Develop CMP 'llraining Implementation Plan.
M. Brown 8/30/96 Documentation demonstrating independent assessment of system slice reviews and walkdowns complete.
P. Blasioli Signature Date R. Cox Signature Date H. Haynes Signature Date M. Brown Signature Date Accepted by Unit Director Signature Date 1
1 MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 59 of 75
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Attcchment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.7. 10CFR50.59 Ir .plementation Responsible Lead Date Due Description Date to Date MQCIPORC Complete M. Kai 8/30/96 All Operability Determinations which have identified degraded conditions have been evaluated through the 50.59 process.
B. Pinkowitz 9/27/96 Request 10CFR50.59 evaluations for abnormal plant conditions as required by restart activities.
M. Kai Signature Date B. Pinkowitz Signature Date Accepted by Unit Director Signature Date 2.1.8. Procedure Compliance Responsible Lead Date Due Description Date to Date MQCIPORC Complete M. Brothers / 8/30/96 Communicate expectations indicating that all N/A Designee programs and procedures will be followed in a verbatim manner. When a procedure problem is encountered, the expectation is that the person will stop (unless an emergency condition exists) and follow the requirements to formally correct the problem.
R.Cox 9/27/96 Review of vendor information control process N/A complete (to verify current conditions).
1 Vargas 9/27/96 Revise (as necessary) and implement the vendor N/A information control program.
M. Brothers /
Designee Signature Date R.Cox Signature Date J. Vargas Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 60 of 75
Attachm:nt A - ORP Deliverabl::s Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.1.9. Root Cause Assessments Responsible Lead Date Due Description Date to Date MQCIPORC Complete P. Blasioli 8/30/96 MP-3 Corrective Action Manager reviews all initiatives and deliverables to ensure that corrective actions for each of the root causes are in place and recommendations of the following have been adequately dispositioned.
- ACR 7007 OAS Failure MP-3 Specific FCAT/NCAT FundamentalCauses JUMA (Joint Utility Management Assessment)
J. Warnock 8/16/96 Documentation demonstrating root cause N/A
)
analysis for the failure of the oversight organization to identify FSAR deficiencies is complete, and generic implications are identified.
G. Pitman 7/8/96 MP-3 specific root cause analyses has been 7/1/96 7/1/96 completed with recommendations to Unit 3 Director.
J. Warnock Signature Date G. Pitman Signature Date P. Blasioli Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 61 of 75
l Attcchmsnt A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence l
l 2.1.10. 10CFR50.54(f) Review / Analysis l Responsible Lead Date Due Description Date to Date MQCIPORC Complete ;
T.Lyons 8/16/96 Documentation demonstrating 10CFR50.54f N/A Operational Readiness Reviews are complete.
I Lyons 8/16/96 Documentation demonstrating 10CFR50.54f N/A Operational Readiness Reviews, horizontal slice reviews and walkdowns are complete.
T.Lyons 8/30/96 Evaluate completed CMP reviews to ensure information in FSAR volumes 15 & 16 was I included in initial reviews. (P12 assessment recommendations)
J. Vargas 8/16/96 Documentation demonstrating vertical system N/A slice reviews and walkdowns complete.
T.Lyons _ ,
Signature Date i J. Vargas Signature Date Accepted by l Unit Director l Signature Date l l
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Attechinent A - ORP Deliverrbles Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence l
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2.1.10.10CFR50.54(f) Review / Analysis (continued) 7 Responsible Lead Date Due Description Date to Date l MQCIPORC Complete l l D. McDaniel 800/96 PI-17 review of FSAR testing requirements is complete and discrepancies are dispositioned.
f D. Gerber 8 SOS 6 Documentation that URI 96-01-08 FSAR l requirements to test safety grade interlocks has l been dispositioned.
, J. Vargas 10/4/96 Incorporate information from FSAR volumes l 15 & 16into the body of the FSAR. (PI2 assessment recommendations)
J. Vargas 10/10S 6 Review and update of MP-3 Final Safety Analysis Report (FSAR)is complete.
D. McDaniel Signature Date D. Gerber Signature Date 1 J. Vargas l Signature Date I Accepted by Unit Director Signature Date 2.1.11. Engineering Training Responsible Lead Date Due Description Date to Date MQCIPORC Complete H. Haynes 8/30S 6 Provide training to the identified Engineering I staff on Design Control Manual. (ACR 7007 corrective action)
H. Haynes 8S 0/96 Provide training to the identified Engineering I staff on 10CFR50.59. (ACR 7007 corrective action)
H. Haynes 8S 0/96 Provide trainin to the identified Engineering staff on NG ineering Department Instructions. (A 7007 corrective action)
H. Haynes i Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 63 of 75 l
l Attachment A - ORP Deliverables j Operational Excellence Objective (OEO) #2 l
Deliverables Associated with Rebuilding Regulatory Confidence 2.2.1. NRC Inspection Issues !
Responsible Lead Date Due Description Da'e to Date MQClPORC Complete l l
J. Peschel 8/30/96 Documentation demonstrating all NRC Inspection Issues (Virgilio, URIs, IFIs) have been addressed and there are no operability issues.
J. Peschel 8S 0/96 Documentation demonstrating that NRC Generic Letter 95-04 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8S 0/96 Documentation demonstrating that NRC Generic Letter 93-06 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8SO/96 Documentation demonstrating that NRC Generic Letter 91-15 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8S 0/96 Documentation demonstrating that NRC Generic Letter 89-22 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 800/96 Documentation demonstrating that NRC Generic Letter 89-18 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 88-15 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 86-16 issues have been reviewed i for applicability and there are no operability I issucs.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic I.ctter 86-10 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 86-07 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 85-22 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 85-16 issues have been reviewed for applicability and there are no operability issues.
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 64 of 75
Attechment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuildine Reeulatory Confidence 2.2.1. NRC Inspection Issues (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 85-13 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 85-05 issues have been reviewed for applicability and there at: no operability issues.
J. Peschel 8SO/96 Documentation demonstrating that NRC Generic Letter 84-21 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 83-42 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 83-33 issues have been reviewed for applicabi!ity and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 83-32 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 82-11 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 824)8 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 81-28 issues have been reviewed for applicability and there are no operability issues.
J. Peschel 8/30/96 Documentation demonstrating that NRC Generic Letter 81-22 issues have been reviewed for applicability and there are no operability issues.
J. Peschel Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 65 of 75
Attachment A - ORP Delivcrcbles Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.2.1. NRC Inspection Issues (continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete M. Venable 8/30/96 Documentation demonstrating NRC Information Notice 93-31 "MOV Failure Caused by Stem Protector Pipe Interference" has been resolved by adding cautions to station common procedures for MOV maintenance.
M. Venable 8/30/96 Documentation demonstrating NRC Information Notice 95-35 " Degraded Ability of S/Gs to Remove Decay Heat by Natural Circulation" has been resolved by adding cautions into procedures to ensure sufficient level is maintained in S/Gs and the capability to pressurize the RCS is maintained when S/Gs are credited as a heat sink.
M. Venable 8/30/96 Documentation demonstrating NRC Information Notice 96-06 " Design and Testing Deficiencies of Tornado Dampers at Nuclear Power Plants" has been resolved by identifying testing needed to ensure dampers will operate as designed.
M. Venable 8/30/96 Documentation demonstrating NRC Information Notice 94-57 " Debris in Containment and RHR System"has been resolved by reviewing for applicability and potential corrective actions.
M. Venable Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 66 of 75
Attcchment A - ORP Delivernbles '
Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.2.2. Operability Determinations Responsible Lead trate Due Description Date Date toQMC Complete K. Burton 8S 0/96 Documentation that Operability Determinations for Cold Shutdown Issues (ACR 08315 & ACR 07269) have been evaluated and reviewed with any degraded conditions resolved.
K. Burton 8SO/96 Documentation that Operability Determination for Containment Base Mat Porous Concrete Issue (ACR 06323) has been evaluated.
K. Burton 8/30/96 Documentation that Operability Determination for ECCS Throttle Valve Clogging Issue (ACR 088897) has been evaluated.
K. Burton 8/30/96 Documentation that Operability Determination for Service Water MCC/RC Booster Pump Air Binding Issue (ACR 04964) has been evaluated.
K. Burton 8 S 0/96 Documentation that Operability Determination for PASS Unreliability Issue (ACR 01176) has been evaluated.
K. Burton 8/30/96 Documentation that Operability Determination for S/G UJIbbe N2 Build Up Issue (ACR 12631) has been evaluated.
J.Langan 880/96 Documentation that emergent operability determinations are reviewed for acceptability K. Burton Signature Date J.Langan Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev. I 7/26/96 Page 67 of 75
Att chment A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.2.3. Justification for Continued Operations (JCOs)
Responsible Lead Date Due Description Date Date toQMC Complete K. Burton 8/30/96 Documentation demonstrating JCOs have been reviewed and scheduled for resolution.
K. Burton Signature Date Accepted by Unit Director Signature Date j 2.2.4. ACR Review '
Responsible Lead Date Due Description Date Date toQMC Complete IC Burton 9/27/96 Documentation demonstrating that level A, B & C ACRs have been reviewed in accordance with RP-4, and uncompleted corrective actions will be evaluated for significance of the remaining open items.
Recommendations forwarded to the Unit Director and Corrective Action Manager.
K. Burton !
Signature Date Accepted by I Unit Director Signature Date 2.2.5. MTF Items Responsible Lead Date Due Description Date Date toQMC Complete D. Gerber 9/27/96 Documentation that all MTF items (except NCRs) have been reviewed and incorporated into AITTS.
D. Gerber Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 68 of 75
Attachm:nt A - ORP Deliverables Operational Excellence Objective (OEO) #2 Deliverables Associated with Rebuilding Regulatory Confidence 2.2.6. OSD Items 0
Responsible Lead Date Due Description Date Date to QhfC Complete T. Sullivan 8/30/96 Documentation demonstrating OSD open items l (including CUAT) have been reviewed and i resolved.
T. Sullivan
- Signature Date Accepted by 4
Unit Director Signature Date 4
2.2.7. NSAB Items Responsible Lead Date Due Description Date Date toQAfC Complete M. Brothers / 8/30/96 Documentation that NSAB open items have all Designee been dispositioned.
M. Brothers /
Designee Signature Date J
Accepted by Unit Director 2
Signature Date l
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l MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 69 of 75
Attcchment A - ORP Deliverables Operational Excellence Objective (OEO) #3 Improving Communications / Morale 3.1.1. Optimize Organizational Structure Responsible Lead Date Due Description Date to Date MQCIPORC Complete R. Kacich 9/27/96 The recommendations from the Nuclear N/A Re-Engineering Team (NRET) to stabilize the organization have been approved by the Nuclear DCA, and any changes affecting MP-3 are on the schedule.
I R. Kacich Signature Date Accepted by Unit Director Signature Date 3.1.2. Employee Concerns Task Plan Responsible Lead Date Due Description Date to Date i MQCIPORC Complete M. Brothers / 8/30/96 An assessment of MP-3 should show that a high j Designee percentage of MP-3 personnel feel comfortable 1 bringing safety concerns to their chain of I command or the Employee Concerns Program.
M. Brothers / 9/27/96 Documentation that employee concerns have Designee been reviewed and no MP-3 operability questions are unresolved.
M. Brothers / 8/30/96 Documentation that the Operational Readiness N/A Designee Plan is clearly communicated to MP-3 personnel with key milestone status presented in an easy, understandable manner.
M. Brothers / l Designee Signature Date I I
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 70 of 75
Attachment A - ORP Deliverables Operational Excellence Objective (OEO) #3 Improving Communications / Morale 3.1.2. Employee Concerns 1hsk Plan (Continued)
Responsible Lead Date Due Description Date to Date MQCIPORC Complete T. Feigenbaum 7/2/96 Present CNO expectations to Nuclear Group N/A 6/13/96 personnel.
M. Brown 6/30/96 Conduct FPI Culture Survey N/A E. Fries 8/16/96 Finalize and enter key Employee Concerns assignment milestones into AITTS.
J. DeMella 8/30/96 Develop, Employee Concerns Program monitormg strategy.
J. DeMella 8/30/96 NRC submittal on KPIs (including Employee Concerns).
E Sroka 8/30/96 Develop plan for Employee Concerns related programs / procedures enhancements.
L ChatfielJ 8/16/96 Dedicated ECP Rep, established for MP-3.
L Chatfielo 8/30/96 Implement measures to improve overall effectiveness of internal communications among management and employees in the Nuclear Group, notablyin the area of CNO expectations and resolving employee concerns.
M. Brown Signature Date E. Fries Signature Date T. Feigenbaum Signature Date E Sroka Signature Date J. DeMella Signature Date L. Chatfield Signature Date Accepted by Unit Director Signature Date l
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 71 of 75
Attachment A - ORP Deliver.:bles Operational Excellence Objective (OEO) #3 Improving Communications / Morale 3.1.3. Employee Communications Responsible Lead Date Due Description Date to Date MQCIPORC Complete D. Winn 8/30/96 MP-3 personnel will have attended a N/A presentation of the Excellence Plan and its l
relationship to the MP-3 Operational Readiness Plan and MP-3 restart.
D. Winn Signature Date Accepted by Unit Director Signature Date 3.1.4. Employee Review Committee j Responsible Lead Dat.: Due Description Date to Date MQCIPORC Compkte R. Beckman 7/12/96 Form an Employee Review Committee for the N/A 7/11/96 l MP-3 Operational Readiness Plan.
l T.Lyons 10/4/96 Employee Review Comrnittee to conduct an indepcadent assessment of unit readiness for restart and provide documentation to the ORP Manager.
R. Beckman Signature Date T.Lyons Signature Date Accepted by Unit Director Signature Date MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 72 of 75
i Attechment A - ORP Deliverables -
Operational Excellence Objective (OEO) #4 Increasing Teamwork. All Five Units 4.1.1. Continuous Improvement Team and Strategies Responsible Lead Date Due Description Date to Date MQCIPORC Complete W. Nevelos 8/16/96 Membersidentified for Continuous Improvement Team.
W. Nevelos 8/30/96 Initial meeting held for Continuous Improvement Team.
W. Nevelos Signature Date Accepted by Unit Director Signature Date 4.1.2. Procedure Upgrade Responsible Lead Date Due Description Date to Date MQCIPORC Complete T. Kirkpatrick 9/27/96 Technical procedure isst.es identified in the MP-3 deficiencies have been reviewed and dispositioned by the Department Procedure Coordinators to support MP-3 restart (OPS, ,
I&C, MNT, TS, DE, GTS, HP & CHM) l T. Kirkpatrick Signature Date Accepted by Unit Director Signature Date 4.1.3. Resource Sharing and Staff Utilization Responsible Lead Date Due Description Date to Date MQCIPORC Complete W. Carr 8/30/96 Communicate to the entire organization that we are reassessing our previously published position of driving to 2000 employees in the NU Nuclear Group.
W. Carr Signature Date Accepted by Unit Director Signature Date i
t MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 73 of 75
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Att: chm:nt A - ORP Delivercbles Operational Excellence Objective (OEO) #5 Improve Employees' Ability to Conduct Work Successfully 5.1.1. Align Human Resources Responsible Lead Date Due Description Date to Date MQCIPORC Complete R. Romer 10/4/96 Approve the 1996 NPIP program revisions and communicate them to the organization.
R. Romer Signature Date Accepted by Unit Director Signature Date 5.1.2. Work Control Responsible Lead Date Due Description Date to Date MQCIPORC Complete J.Langan 9/27/96 Documentation demonstrating review of all priority 1,2, & 3 AWOs for restart impact is complete and any issues identified are dispositioned.
J.Langan 10/4/96 Documentation demonstrating that priority 1,2
& 3 AWO backlog is < 500.
J.Langan 10/4/96 Documentation that the AWO backlog of less than 500 contains no safety significant items.
M. Brothers / 8/30/96 Documentation that an unplanned entry into Designee moni(tored by unit management.LCO s) goal has been established M. Brothers / 8/30/96 Identify a " Barrier Breaker" lead for unit 3.
Designee J.Langan Signature Date M. Brothers l Designee Signature Date Accepted by Unit Director Signature Date ,
l MP-3 Operational Readiness Plan Rev. I 7/26/96 i Page 74 of 75 l l
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Attrchment A - ORP Deliverables -
Operational Excellence Objective (OEO) #5 Improve Employees' Ability to Conduct Work Successfully 5.1.3. Plant Testing Responsible Lead Date Due Description Date to Date MQCIPORC Complete J.Langan 8/30/96 Documentation demonstrating a centralized surveillance tracking program is in place, functional and being run by WP/OM.
J.Langan 9/27/96 Documentation demonstrating all surveillances are scheduled within required periodicity based on new RF06 date.
J.Langan 8/16/96 LLRT tests are completed and documented.
J.Langan 9/27/96 Documentation that all applicable mode punch lists are complete per outage schedule.
J.Langan 8/16/96 EDG tests are completed and documented.
J.Langan 8/16/96 ESF/ LOP tests are completed and documented.
J.Langan Signature Date Accepted by Unit Director Signature Date 1
MP-3 Operational Readiness Plan Rev.1 7/26/96 Page 75 of 75