ML20135F726

Restart Readiness Plan

ML20135F726
Person / Time
Site:	Maine Yankee
Issue date:	03/07/1997
From:	Sellman M Maine Yankee
To:
Shared Package
ML20135F724	List: ML20135F720 ML20135F726
References
PROC-970307, NUDOCS 9703130368
Download: ML20135F726 (89)

Text

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MAINE YANKEE ATOMIC POWER COMPANY RESTART READINESS PLAN l

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l h 12A & _ 3/7(q y President, MYAPC Date Dk SDohk 050$0309 P PDR

Maine Yankee Restart Readiness Plan i INDEX

l. P u rp o s e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l 11. Ba c k g ro u n d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1 1 l Ill. Organization and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l

IV Restart Readiness Process Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 - I V. Exte nt of Co nd itio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 VI. Outage Work Scope identification and Screening . . . . . . . . . . . . . . . . . . . . . . . . . 11 1

Vll. Wo rk C o m p letio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 i Vill. Restart Readiness Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 ,

l IX. Startup and Power Ascension . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 l i

I X. O ve rs i g h t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 7 1

Attachments

1. Definitions

2. NRC 0350 Cross Reference

3. Restart Work Criteria

4. Work Order Review

5. Corrective Action Program Review

6. Plant System Readiness Assessment

7. Plant Program Readiness Assessment

8. Department Readiness Assessments

9. Licensing / Regulatory Closure Affirmation

10. Quality Programs Closure Affirmation i 11. Management Effectiveness Assessment

12. Integrated Site Readiness Assessment

13. Preliminary Listing of Short-term Focus Areas Appendix - Action Plans for Significant Restart Issues A. Logic Circuit Testing B. Cable Separation C. 115KV Offsite Power D. Steam Generator Inspection E. Fuel Failures F. Corrective Action Program / Learning Process G. Surveillance Testing H. EQ lssues r

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l Maine Yankee Restart Readiness Plan 1

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1. Purpose The purpose of the Restart Readiness Plan is to document the methodology being used by the

Maine Yankee Atomic Power Company (MYAPC) to identify and complete activities necessary to ,

, retum the Maine Yankee (MY) plant to operation following the December 6,19% forced outage. The l

Restart Readiness Plan (RRP) provides for the initial implementation of the Maine Yankee Business -i Plan and is responsive to restart issues contained in the following key inputs

i NRC Confirmatory Action Letter (CAL), dated December 18,1996 and Supplement No.1,

] dated January 30,1997, NRC Independent Safety Assessment (ISA) as documented in NRC letter, dated October 7, 1996 and the Maine Yankee Response to ISA dated December 10,1997, i; e

~other NRC Inspection Reports including integrated Inspection Report 96-13, dated January i- 15,1997 and 96-16, dated February 11,1997, MYAPC response pursuant to U3NRC 10CFR50.54(f) request " Adequacy and Availability of j Design Bases Information,"

a self identified improvement actions, i

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.- equipment and System Assessments (focused on plant hardware performance issues), and j . program and organizational assessments (focused on non-hardware performance issues). .j f MYAPC has developed this RRP to ensure that the issues identified in the inputs listed above are adequately addressed and to identify and resolve any other issues that affect plant safety. To j achieve this objective, RRP actions will focus on achieving perfomlance improvement in MYAPC

personnel, key work processes and plant equipment and systems. Although the RRP for MY is based on restart programs previously approved by the NRC for use at other nuclear plants as well j as the applicable sections of the NRC inspection Manual Chapter 0350 " Staff Guidelines For Restart Approval,"(see Attachment 2 for a comparison matrix), it addresses the specific issues applicable 1

to MY.

j To assure that performance issues are identified, prioritized and addressed in a timely manner, a f three phase planning framework is being used to guide performance improvement at MY. This F framework is driven by the Maine Yankee Business Plan and will ensure that performance improvements achieved prior to unit restart are sustained into the future. The three phases are:

1. Phase 1 - Restart Readiness i

! Phase 1 willidentify and resolve all issues that must be completed prior to MY restart to 1

- assure a safe, controlled startup and sustained periods of safe and reliable operation.~ This

. - RRP summarizes the approach and key actions thai will be taken to complete Phase 1 and j return MY to power operation.

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Maine Yankee Restart Readiness Plan i

2. Phase 2 - Short-Term improvements Phase 2 implements actions that do not directly affect plant safety or regulatory requirements but will be accomplished in an expeditious manner to sustain and reinforce the performance improvements achieved in Phase 1. The Phase 2 Plan will be developed prior to restart and will provide a bridge after MY restart (Phase 1) and before implementing the long term l improvement program (Phase 3) to reinforce the momentum for performance improvement. '

These actions (see Attachment 13) are to be completed within approximately six months following MY restart.

3. Phase 3 - Long-Term improvements This phase implements strategies and actions to sustain the Phase 1 and 2 improvements and to achieve long-term business plan objectives. Phase 3 is strategic in nature and designed to elevate the overall performance of MY to simultaneously meet long-term objectives for safety, production and economics. This phase is anticipated to include activities implemented over a period of one to several years in duration.

Although the primary focus for the MYAPC organization is on Phase 1 activities, some Phase 2 and 3 actions w;ll begin planning and implementation in parallel with Phase 1 to ensure that Phase 1 improvements are sustained and to provide for the rapid initiation of continuing improvements following MY restart. The Maine Yankee Business Plan identifies Phase 1,2 and 3 actions for known issues and the issue screening and prioritization process described in this RRP will be used to assign new issues to Phases 1,2 or 3. In addition to the many detailed Phase 1 actions that address issues raised in the ISA and other key inputs, ISA root causes and issues will continue to be addressed Phases 2 and 3. Phase 2 and 3 plans will be updated using the Maine Yankee Business Plan framework prior to initiating plant restart and power operation.

The RRP is being implemented to provide affirmative decisions as to what issues require resolution prior to startup using specified criteria (discussed in Section VI and included in Attachment 3). The criteria based approach and broad participation by the line organization in evaluating potential restart issues is a key aspect of the RRP and is designed to raise standards across the entire organization.

Individual action plans are provided in the appendix for major outage issues. The use of these appendixes allows for issue-specific review, approval of major activities and implementation of a phased closure as these major issues are resolved. Additionally, if other significant issues are identified during the plant shutdown it will allow documenting the intended actions without revising the complete RRP.

Business Plan (Phase 3)

Restart Pf an short Term (Phase 1) %# (Phase 2)

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Maine Yankee R_estart Readiness Plan ll. Background A brief chronology of significant events relevant to current MY restart readiness activities is summarized below.

January 3,1996 NRC issued a Confirmatory Order suspending authority for and limiting power operation and containment pressure. This Orderwas the result of allegations made to the State of Maine regarding the use of certain computer codes by MY and Yankee Atomic Electric Company. MY continues to operate under the restrictions imposed by the order.

January 16,1996 MY returned to power operation after a one year shutdown to repair steam generators.

June 7,1996 NRC, at the request of the State of Maine, announced the formation of an Independent Safety Assessment (ISA) Team to conduct en assessment of plant conformance to design and licensing basis; provide an assessment of operational safety performance; evaluate the effectiveness of licensee self-assessments, corrective action and improvement plans; and determine the root causes of safety significant findings and conclusions .

October 7,1996 NRC issued the ISA report. The report identified strengths and weaknesses and concluded that the operational safety of the plant was declining but adequate for continued operation.

December 4,1996 MY operators shut down the p! ant as a result of operating concerns identified by plant engineers reviewing control logic testing concerns identified in Generic Letter 96-01 and cable separation issues identified coincident to the 96-01 review.

December 10,1996 MY responded to the issues identified in the October 7,1996 ISA report including corrective actions underway and planned.

December 18,1996 NRC issued a confirmatory action letter requiring MY to remain subcritical until the problems requiring the plant shutdown were resolved.

January 30,1997 NRC issued a supplement to the confirmatory action letter requiring the resolution of certain concerns in the October 7 ISA report, issues raised by MY's response to Generic Letter 96-01, and issues raise by MY's response to the Confirmatory Order of Jan 3,1996.

February 7,1997 MY responded to the generic NRC request (10CFR50.54 (f)) for Information Regarding Adequacy and Availability of Design Bases information.

February 11,1997 NRC issued Inspection Report 96-16 which tabulated 16 apparent violations j derived from the ISA report of October 7,1996 and licensee identified issue J in August 1996. 'l February 28,1997 MY responded to the apparent violations cited in Inspection Report 96-16 P3 RESTART.wpd Revision 0 Page 3  !

l Maine Yankee Restart Readiness Plan l

Ill. Organization and Responsibilities r

i Figure 1 i Restart Readiness Organization l

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. President 1

,; MYAPC I

Mgr. Quality Nuclear Safety

< Programs Auf t Review 4

Committee (NSARC)

VP Operations 1

Restart Steering

, Oversight Committee Oversight ,

4 _ - _ _ _ ______

-Mgr Nuc Safety

-VP Licensing

. -VP Engineering i Restart Manager YNSO Sr Mgr Plant Manager

-Mgr Quality Prog

I I f I I I I Hardware Programs Department Restart Manager Restart Manager Managers Outage Manager I I I I Hardware Non Hardware Mgr Operations Outage Planning Subcommittee Subcommittee Mgr Maintenance Inte rahon Team j

.HW Restart Mgr Prog. Restart Mgr Mgr Tech Support P

. Engineering Rep -Engineering Rep Mgr Outage fE ' ".'n a' ep

-Operations Rep -Operations Rep Mgr Proj.& Constr -Mech M aint Rep

. Maintenance Rep -Maintenance Rep "

-Quality Prog Rep -Licensing Rep Mgr Plant Engr j,P*'frot o Rep

-Quality Prog Rep Mgr Corp Engt . Purchasing Rep PARESTART.wpd Revision 0 Page 4

1 Maine Yankee Restart Readiness Plan l l

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The RRP organization shown in Figure 1 has the following responsibilities:

1. President MYAPC - Overall responsibility for restart and operation of the MY plant. He has final approval of the RRP and plant restart approval.

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2. Vice President Operations -Is responsible for the management and implementation of the 1 RRP and is Chairman of the Restart Steering Committee.

3. Restart Steering Committee (RSC) - Is responsible to support the Vice President Operations in the overall direction and oversight of the restart program. They will evaluate, i screen and closeout major issues. They will also review and approve the activities of the hardware and non-hardware sub-committees. I

4. Restart Manager - Is responsible for the coordination and control of the restart program including the RRP (does not include the routine physical outage work). Reports to the Vice l President Operations.

5. Plant Manager - is responsible for the management and control of the defined physical outage work including scheduling of activities and coordination of resources. Principal manager responsible for approval and implementation of the process to restart the plant and I proceed through power ascension. Reports to the Vice President Operations. l 1

6. Hardware Restart Manager-is responsible for management and resolution of all hardware issues. Chairman of the Hardware Restart Subcommittee. Reports to the Restart Manager.

7. Hardware Subcommittee - coordinate the site evaluation and screening of hardware issues against the criteria and review and approve the hardware corrective actions. QPD representative is for independent review and oversight of subcommittee work.

8. Programs Restart Manager - is responsible for management and resolutim of all non- l hardware issues. Chairman of the Non-Hardware Restart Subcommittee. Reports to the Restart Manager.

9. Non-Hardware Subcommittee - coordinate the site evaluation and screening of non- I hardware issues against the criteria and review and approve the non-hardware corrective j actions. QPD representative is for independent review and oversight of subcommittee work. l

10. Manager Quality Programs - provides independent review and oversight of RRP implementation and the effectiveness of corrective actions. Reports to the President MYAPC. I i

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11. Nuclear Safety Audit Review Committee (NSARC)- Advise the President of MYAPC on  !

the RRP and implementation and provide assessment of the plant readiness to restart. l Repcits to the President MYAPC. j

12. Responsible Manager - manager accountable for ensuring that the assigned items have been properly evaluated, corrective actions implemented, documentation completed and i issue closure. The responsible manager (or designate) typically will present the assigned {

restart item screening conclusion and restart closeout to the applicable restart committee.

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Maine Yankee Restart Readiness Plan IV. Restart Readiness Process Overview MYAPC established a RRP Team with responsibility to develop a comprehensive and effective RRP within the framework of the Maine Yankee Business Plan. The Team's charter was to (1) establish an integrated approach for identifying and completing work activities required for restart and (2) identify management, program, and process initiatives to assure a safe, controlled startup and sustained periods of safe and reliable operation.

The RRP implements the first phase of the three phase Maine Yankee Business Plan and will result in the safe, controlled restart of the plant. Figure 2 provides an overview of the relationship between the three phase business plan and the major RRP activitit s. The restart readiness process consists of the following five major elements:

1. Completion of an extent of condition review to ensure 1 at identified performance deficiencies do not extend into other programs or processes in a manner that may impact the startup or safe operation. l l

2. Identification and screening of the scope of activitbs required to be completed prior to unit )

restart to assure resolution of safety significant issues and assure a safe, controlled startup. '

WMre possible, other known work will be scheduled for completion in Phases 2 or 3. See Section VI for additional discussion on outage work scope verification.

3. Completion of required work using appropriate procedural controls and following appropriate documentation requirements for work package closeout. See Section Vll for additional discussion on work completion.

4. Implementation of a comprehensive restart readiness assessment that provides confidence that all required work has been effectively identified and completed and that plant systems, programs, processes and personnel are ready to support safe unit restart and power operation. See Section Vill for additional discussion on the restart readiness assessment.

5. Initiation of plant startup and power ascension following a safe and controlled approach. See Section IX for additional discussion on the startup and power ascension.

The restart readiness process is shown in flow chart form in Figure 3. The integrated set of activities completed to implement the RRP are comprehensive, provide assurance that potential safety issues have been resolved and demonstrate that MY is positioned to sustain the improvements achieved in this phase and to implement additional performance improvements in Phases 2 and 3.

To achieve successful implementation of this RRP, the Restart Manager will take the following additional actions:

. Communicate the RRP to the organization and assign responsibility and accountability for successful completion of restart issues.

. Communicate implementation status to the organization.

Establish an integrated schedule to complete the actions necessary for restart, PARESTART.wpd Revision 0 Page 6

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I Miina Yanksn Rzstert Raadinuss Pl:n Figure 2 Maine Yankee Business Plan Maine Yankee ,

I Business Plan if l U"'"

Phase 1 U"'"'* ) Phase 2 Phase 3 l Long Term Plan <~~~ Restart Readiness Plan

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Short Term Plan h if h lli Manaaement Systems V Extent of Condition X Overslaht i Restart Manager CAL Line Management T -) ISA & Inspections (-- l-- -- PORC Restart Committee

-Steering g 50.54(f)  : QA/QC Hardware l Other Self Identified Prob i NSARC

.Non Hardware i i Outage Organization 1 3g I issue Managers  ! I I VI Outage Work Scope  !

Identification & Screen I,

) Major Action Plans (-l l

, i System Reviews l Program Reviews i I I l ir l l Vil Work Comotetion I I

I_) Hardware items I Non-Hardware items 4i I

(People / Plant / Process) l l i I if I l l l

Vlli Readiness Assessm. l i Systems l l Programs I l- Departments b i Quality / Licensing I Integrated Site l l

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I if l i l IX Restart & Power I l Ascension Plan i i Plant Heatup I Reactor Startup 4" 30% Power 90% Power PMESTART wpd Revision 0 Page 7

4 Maine Yankee Restart Readiness Plan Figure 3 Maine Yankee Restart Readiness F 3 ( 3 f 3 r 3 Independent Adequacy Confirmatory Safety & Availability Action Letter Assessment of Design Self Identified Basis Info. Issues (CAL) (ISA) & NRC inspections 50.54(f) l

( ( ) ( ) L J if if Restart Committee

- Restart Steering Committee l Equipment - Restart Hardware Committee '

Prog./ People Assessments

- estart N n Hardware Coma.ttee Restart Criteria

@ Assessments

, 1 - Safety / Operability 2 Regulatory Requirement i

( ) ( )

if I r , , , ,

Restart Plan - Phase 1 Short Term - Major Action Plans (Appendix) Long Term Phase 2 - Hardware Restart List Phase 3

- Non-Hardware Restart i.ist k ) N } k )

If Schedule & Perform Work JL N Mk N Y Restart Mgt Aphal Committee Approval Y

I Restart Readiness Review & A'pproval Startup & Power Y Ascension Plan P.\ RESTART wpd Revision 0 Page 8

l Maine Yankee Restart Readiness Plan -

l V. Extent of Condition l

l In response to the NRC Confirmatory Action Letter (CAL) dated December 18,1996 and Supplement 1 to the CAL dated January 30,1997, MYAPC willimplement an assessment to determine the extent of condition and the root cause(s) for these issues. Figure 4 summarizes the process that will be used to assess the extent of condition. In addition to known issues as identified in the CAL, ISA report, MYAPC 50.54(f) response on design basis information and through internal problem identification methods, the RRP outlines a comprehensive process to determine if there other safety significant issues requiring resolution prior to restart Later sections of the RRP and Attachments describe the implementation approach for plant system and program reviews as well as the evaluation and screening of plant work order, corrective action and engineering backlogs.

The results of the reviews will be assessed from an extent of condition perspective by determining the following:

Are there commonalities across root cause evaluations that may lead to more fundamental j root causes? i

. Are narrow problems really generic? l Have we identified all safety significant issues important to restart and long-term operation?

Can our corrective action process (Learning Process) effectively monitor and, when necessary, heal our safety culture?

Are our design and licensing basis compliance contro's sufficient to avert future safety and regulatory problems?

The assessment of these questions using the results of the plant system and program reviews and j the evaluation and screening and plant backlogs wi;l be performed under the leadership of the Non-hardware Subcommittee A cross disciplined team will be assembled to perform this evaluation and present results and recommendations to the Non-hardware Subcommittee. Based on the conclusions of the assessment, additionalinvestigative or corrective actions may be required prior to plant startup or during Phases 2 and/or 3 of the MY Business Plan implementation.

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Maine Yankee Restart Readiness Plan Figure 4 Extent of Condition Assessment CAL fdentified Prob IS A & Inspect. Prob S0.54f f) Resoonse Self Identified Prob Cable Separation Appairent Violations Design Basis Prob -Fuel Issues

-Logic Testing URIs FSAR Prob S/G Inspection

-Cont. Flood Level -Other Problems Tech Spec Prob Entergy Evalutation

-isolation Device -lST Basis Prob -Culture Assessment

-Cont. Free Volume -50.59 Process Prob -lNPO Evaluations

-115Kv Power Supply -Other Prob -Other Evaluations l I I l i

if Equipment & System s Root Cause s I U '* * ' ^

Assessments 7 Evaluations '

Assessm nts A

Jk 3g Jk Causal Factors l ABCDEFGHIJKLMNOPQRSTUV j x X x x x xx x x x E 2

• x x x 3

j 4 x x x x x x x x i 5 I 6 xx x e 7 x x x

• x x x 8 x x g x x 10 x x x x if Extent Of Condition Assessment

1. Are There Common Root Causes?

2. Are Narrow Problems Generic?

3. Identified All important Safety issues?

4. Does CAP Monitor & Improve Culture?

5. Design & Lic Basis Controls Adequate?

if , if if Short Term Restart Plan Long Term (Phase 2) (Phase 1) (Phase 3)

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1 Maine Yankee Restart Readiness Plan 4

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VI. Outage Work Scope Identification and Screening l

} . 1 The outage work scope is being va: dated through a rigorous review of open work against defined i criteria. The review of open work, including both hardware items and non-hardware issucs, is intended to ensure resolution of the specific issue and, where appropriate, the underlyir.g root

, causeb). The achievement of this objective requires that, in addition to the review and evaluation  ;

of knosn work items, additional assessments must be performed to determine the extent of condition )

of these performance issues. New work items identified from these assessments will also be i

reviewed against the restart criteria to determine if they require resolution prior to restart. l I- Some work items will be intentionally evaluated from different perspectives to ensure that potentia;

safety significant issues are identified and resolved. For example, open work orders not already

included in the scope of the outage are initially reviewed against the restart criteria as part of the -

maintenance work order backlog review (see Attachment 4). These open work orders will also be g reviewed on a system basis as part of the system review to ensure that any work items deferred beyond this outage will not impact safety system performance or reliability (see Attachment 6).

I 1. Identification of Potential Restart Work Items

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1- Potential restart work items are identified through review of key intemal and extemal inputs, 4

planning associated with majorissues and through additional assessment and evaluation to determine the extent of condition.

A. Key inputs to Work Scope identification The seven major areas described below are evaluated to identify restart required actions. This input includes external assessment from NRC inspections as well as extensive internal assessment. This scope of review will ensure that both the specific issue and the underlying root cause(s) are identified for resolution. New issues requiring resolution prior to plant restart may be identified as a result of implementing this review. The seven review areas are:

1. NRC Confirmatory Action Letter (CAL) and Supplement:

. Testing of safety-related logic circuits

. Cable separation problem resolution ,

. Root cause of logic testing and cable separation issues  ;

. Il5KV offsite power supply issues

. Extent of condition of design and configuration controlissues 1 2, independent Safety Assessment (ISA) and the MYAPC response (including the Excellence Plan):

. Margin improvement

. Backlog reduction

. Licensing and design bacis issues

. Operator work around issues

. . Maintenance and testing improvement

. Engineering improvement

. Operations improvement

. Self assessment and Corrective Action Program implementation

. Resource adequacy P3 RESTART.wpd - Revision 0 Page 11

Maine Yankee Restart Readiness Plan Management and organizational improvements

3. - NRC Inspection Reports & Violations including:

NRC Integrated Inspection Report 50-309/96-13, January 15,1997 j NRC Integrated Inspection Report 50-309/96-16, February 11,1997

4. MYAPC Response pursuant to NRC 10CFR50.54(f) request " Adequacy and i Availability of Design Basis Information" including:

. Develop Design Basis Summary Documents (DBSD)

Review of Technical Specifications and FSAR

. ' IST design basis development

. Assessment of design basis

. 50.59 program improvements

. Design process improvements Other miscellaneous actions

5. Self Identified improvements including:

. Maine Yankee Business Plan

. Fuel reliability

. Steam Generator inspection Cultural assessment (s)

. Entergy due diligence assessment  !

-. INPO evaluations  !

. Staffing study

6. - Plant Equipment and System Assessments (focused on plant hardware performance issues) including: l System walkdowns

. Verification of Design Basis Summary Documents j

. Action plans for systems classified as A.1 per the Maintenance Rule

. Work order backlog review

. Temporary Modifications review  ;

. Operator Work arounds review

. Housekeeping issues

7. Program and Organization Assessments (focused on non-hardware performance issues) including:

. Corrective Action Program (CAP) backlog - Leaming Process  :

. Engineering backlog

. Department assessments

. Program reviews on a focused set of plant programs

.- Significant Root Cause Evaluations

• Development of Design Basis Summary Documents and implementing a program to control the design basis v

B. Significant Restart issues Several of the large issues identified will be managed as individual restart projects and will be specifically evaluated during the resolution review process to assess the potential for generic implications. The action plans for these issues are contained PARESTART.wpd . Revision 0 Page 12

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Maine Yankee Restart Readiness Plan 1

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in the Appendix to this RRP. Additional appendixes will be added if new issues are

. identified as part of the restart readiness process and these issues are large in

[ magnitude or contain potential generic implications. The current set of issues being i managed in this way include:

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!: . 1. Logic Circuit Testing

2. Cable Separation

' 3. 115KV Offsite Power .

4. Steam Generator Inspections i 5. Fuel Repair / Replacement Corrective Action Program (Leaming Process) 4 6.

7. Surveillance Testing

8. EQ issues C. . Backlog Reviews and Additional Assessment f-Work order, corrective action program (Leaming Bank) and other significant backlogs will be identified and evaluated using the screening criteria discussed below to determine if there are work items required to be completed prior to unit restart. In addition, safety significant plant systems and critical plant programs will be assessed for extent of condition issues and to identify work required to be completed on these systems and programs prior to unit restart. Each key organization will also conduct l an initial assessment to define activities that must be completed prior to restart to .;

correct performance deficiencies within their respective organizations l Additional guidance for the evaluation of key backlogs, plant systems, programs and department self assessments is provided in the following attachments:

~ Attachment 4 - Work Order Review Attachment 5 - Corrective Action Program Review

. Attachment 6 - Plant System Readiness Assessment Attachment 7 - Plant Program Readiness Assessment Attachment 8 - Department Readiness Assessments

2. Screening of Potential Restart Work items Each potential restart work item will be evaluated to determine if it requires resolution prior to plant restart (Phase 1) or should be carried forward into the short-term or long-planning phases (Phases 2 and 3). The issue screening evaluation process provides a structured method, focused on operational safety, to assure that each issue is evaluated in a consistent manner .

The issue screening evaluation uses a two level criteria that ensures priority on all issues

-with a potential impact on plant operational safety. The screening of issues against this criteria will be completed by site personnel as assigned by the Restart Steering Committee or the Hardware and Non-hardware subcommittees. The criteria is provided below. )

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1 Maine Yankee Restart Readiness Plan i

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$ Restart Work Criteria l

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Re' start work is' based on two fundamental and related concepts: safety and comphance with regulatory l requirements.

j Conditions, issues and deficiencies which, if uncorrected, c%Id reasonably result in the plant being in an .

unsafe, inoperable or non-compliant condition must be conected prior to restart. Conditions, issues and deficiencies for which sufficient compensatory measures am implemented such that the plant is in a safe, 1~ operable and compliant condition may be corrected post-mstart on a schedule commensurate with their safety significance, i Criterion 1 Safety Screenina i-j- Can the condition, issue or deficiency reasonably result in the plant being in an unsafe condition, or a safety 4- significant system or component being inoperable? For example

4-1.1 Has the condition resulted in repetitive safety system or equipment failures?

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1.2 Would the condition result in a plant transient, power reduction or plant shutdown?

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! 1.3 Does the condition represent a deficiency in design basis, analysis or documentation that

renders a system or component inoperable?

l i 1,4 Does the condition result in non-technical specification equipment that is important to j safety (per Operations Procedure 1-26-6) being inoperable? -

1.5 Does the condition create the high potential for personna' ujury or overexposure?

Criterion 2 Reaulatory Reauirements Screening j Can the condition, issue or deficiency reasonably result in the plant being in a non-compliance condition i- with regulatory requirements (10CFR50, etc.), the MY operating license or technical specifications? For example:

b 2.1 is the condition in non-compliance with the requirements of regulations (e.g., EQ, Appendix R, etc.)?

.2.2 is the condition in non-compliance with the operating license?

j: 2.3 Does the condition result in failure to satisfy a technical specification surveillance 4

requirement or place the plant in a condition outside of the technical specifications?

2.4 . Does the condition result in an effluent release to the environment in excess of regulatory

, limits?

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Maine Yankee Restart Readiness Plan l

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l 3. Oversight of Work Identification and Screening l

l Oversight of the work identification and screening process will performed by the Restart l Steering Committee and the Hardware and Non-hardware subcommittees. This oversight

! will ensure that the screening criteria is consistently applied to identify the work required to

! be completed during the outage and to ensure that the root cause of key performance issues

is identified with effective corrective actions implemented.

A. Restart Steering Committee The Restart Steering Committee will evaluate the scope of corrective actions for the major issues contained in the Appendix, screen the actions for priority assignment (Phase 1,2 or 3) and, when work is completed, evaluate the effectiveness of actions in resolving the issue. Phase 1 work will be completed prior to unit restart. The Restart Steering Committee will perform a similar initial and final review of the following specific items:

. Confirmatory Action letter response

. Effectiveness of management and organizational changes  ;

e Cultural Assessment l

. Entergy Due Diligence Assessment

. Staffing Study ,

B. Hardware Restart Subcommittee l

The Hardware Restart Subcommittee will evaluate, screen and close out the l equipment and system issues, including emergent issues. Specific areas for review include: j

. Work order backlog

. System walkdowns and readiness reviews

. Actions for systems classified A.1 per the Maintenance Rule.

. Operator work arounds

. Temporary mooifications

. Housekeeping issues C. Non-hardware Subcommittee The Non-hardware Subcommittee will evaluate, screen and close out the program and process issues, including emergent issues. Specific areas for review include:

. Corrective action program backlog

. Engineering backlog

. ISA actions and commitments

. NRC Inspections / Violations

. Business Plan initiatives

. Program assessments

. Department self assessments l . 50.54(f) Response

. Extent of condition evaluation P:\ RESTART.wpd Revision 0 Page 15

l Maine Yankee Restart Readiness Plan l

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l Vll. Work Completion l

l This RRP does not control the conduct of work at MY. Work required to be completed prior to unit restart will follow plant processes and procedures. Responsibility for planning, scheduling and completing outage required work is consistent with normal organizational responsibilities. Specific work items designated as required to be completed prior to restart via the work scope identification and screening process described in Section VI will be tracked through completion and documentation closeout. The tracking process is summarized below.

1. Issue Tracking - Restart Lists Two restart item tracking lists will be used. One listing includes all hardware issues designated as requiring completion in this outage because it is planned work for the outage and/or meets the restart criteria specified above. This listing is a subset of the work control process data base. The hardware list will be controlled by the Hardware Subcommittee. A second listing of non-hardware issues requiring completion in this outage will be maintained.

This listing includes a subset of the Learning Process data base and other databases that track non-hardware work items. This listing will be controlled by the Non-hardware Subcommittee.

Emergent issues will be evaluated to determine whether they should be added to the restart lists. Deletions to the restart lists will be reviewed and approved by the applicable restart sub-committee.

The restart lists are intended for tracking those items meeting the criteria and therefore required for restart. The restart lists are not intended to address routine issues that would normally be required (e.g., technical specification testing, previous commitments to the NRC not specifically related to restart) and other normal outage or refueling activities. Also, the restart lists do not include all actions that are scheduled for completion during the outage (because of logistical considerations or other performance improvement items) but not required by the restart criteria.

2. Issue implementation l l

A. Hardware Actions Completion of the hardware actions is the responsibility of the Hardwan Restart Manager. The normal work control processes will be utilized. Physical work for the current outage is controlled in accordance with an outage schedule that contains maintenance work and design improvements that must be completed prior to plant restart. In addition, the schedule will contain other activities requiring completion because they satisfy the restart criteria for safety and equipment operability or ,

regulatory requirements. l The outage schedule is reviewed on a periodic basis. Adjustments are made to the schedule to address changes in activity duration and as a result of sequencing needs. Updates to the schedule are published periodically to insure all personnel understand upcoming activities and priorities. A summary report will be issued to the Restart Steering Committee periodically.

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Maine Yankee Restart Readiness Plan ]

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B. Non-Hardware Actions j Completion of the non-hardware actions is the responsibility of the Programs Restart Manager. The normal plant processes should be utilized (e.g., the Learning Process). j 1

l Scheduled action items should be reviewed and summarize to the Restart Steenng l Committee periodically.  ;

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3. Issue Close Out Restart required issues will be closed out in a consistent manner using the following approach.

A. Major Restart Issues (RRP Appendix Action Plans)

-1 The following close out document format applies to major restart issues (RRP l Appendix Action Plans) and other significant issues as direct by the RSC. The responsible manager for each major restart issue will maintain the master set of documentation for issue closeout and have this information in a form that can be )

, audited by internal and external reviewers.

Summary

. Overview of the issue and issue closure

! Closeout actions

. Summary of actions taken  !

. Reference to documentation of completed actions (include as an attachment

, if not readily available in plant information systems)

Results

. Performance improvements achieved

. Measures / indicators / tests used to judge effectiveness Follow-up actions

• Post restart actions (short-term /long-term) required to ensure effectiveness of corrective actions and to prevent recurrence

. Actions to ensure continued improvement Attachments

. Supporting documentation Each closeout document will be approved by the responsible manager and the RSC. l i

B. Restart List items l All other restart list issues, both hardware and non-hardware will be closed using normal plant processes (e.g., maintenance work requests, Leaming Process, etc.).

The responsible manager for each restart list item should maintain the documentation for issue closeout. This documentation can be maintained in the  :

normal plant data base or document control systems. This documentation should be easily available for review by internal and external reviewers.

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Maine Yankee Restart Readiness Plan 4

l The responsible manager is the final approval for completion and does not need to bring the item back to the restart sub-committee unless the completed action was significantly different than the action approved by the committee or there is a concern regaroing the effectiveness of completed actions. Department Managers will, as part

' of the final restart readiness review, validate to the RSC that their departments are ready for unit restart and power operation and that all restart list items have been completed.

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l l Maine Yankee Restart Readiness Plan i i l Vill. Restart Readiness Assessment l'

The MYAPC organization will perform a restart readiness assessment to determine the readiness of the plant and the organization to support safe start-up and power operation. Restart readiness l

assessments will result in the affirmation that departments, programs, and plant systems are ready '

to support unit restart and power operation. Affirmation will also be provided by Qua!ity Programs and Licensing that there are no additional issues preventing unit restart. The RSC will evaluate the results of the readiness assessments and integrate these results to determine whether restart of the plant is recommended to the President MYAPC.

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1. Readiness Assessment Objectives Readiness assessments will be performed to achieve the following objectives:

A. Ensure effective communications between station management and staff to assure that important issues relative to to plant restart and power operation are well-understood, facilitate teamwork in the management of these issues, and reinforce  ;

line management ownership of the issues and results. )

l B. Ensure that all restart required issues have been effectively resolved including those )

emergent issues defined during the course of the outage.

C. Define a path for continued performance improvement through linkage of assessment results with the Phase 2 (short-term) and phase 3 (long-term) plans. l

2. Conduct of Readiness Assessments l

The applicable subcommittee (hardware or non-hardware) will define the specific organizations, programs and plant systems for which a readiness assessment will be completed and will assign a responsible manager to complete the readiness assessment in accordance with the guidelines provided in the attachments. The responsible manager will present these results to the subcommittee concluding with their affirmation of readiness to support restart and power operation. As a minimum, readiness reviews will be completed in the following areas A. Safety significant plant systems as defined in Attachment 6. l l

B. Plant programs that were judged to require an initial review or detailed assessment as determined in Attachment 7.

C. Plant departments as defined in Attachment 8.

In addition to these readiness reviews, the RSC will evaluate presentations from Quality Programs and Licensing on their independent affirmation that there are no quality or licensing issues that must be resolved prior to recommending plant restart to the President MYAPC.

l (See Attachments 9 and 10)

The RSC will perform an integrated evaluation of the readiness reviews and independent affirmations to establish a recommendation regarding the effectiveness of the management l

team in resolving performance issues, the ability of the management team to sustain the PARESTART.wpd Revision 0 Page 19 l

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performance improvements and the overall site readiness to support restart. (See l Attachment 11 and 12)

3. Readiness Assessment Review Scope l Readiness assessments will include the following items as a minimum scope. Additional i guidance and documentation formats are provided in the attachments.

A. Plant System Readiness Assessments Prior to restart, each responsible system engineer (or designated person) will review the status of each system as indicated in Attachment 6 and will affirm restart readiness of the system to support safe and reliable restart and full power operation.

Implementation of this review will include close interface and coordination with Operations.

This affirmation is the closure of the system review process initiated in the work i scope verification phase. Incomplete activities at the time of the presentation of the final system readiness assessment will be identified as centingent and tracked to completion. Items that will remain open at unit restart should be prioritized for resolution in either Phase 2 or Phase 3, as appropriate. Technical specification systems will be verified operable before entry into a mode where they are required to be operable.

1 System engineers (or designee) should:

. confirm resolution of any open regulatory issues,

. confirm that the material condition of the system supports safe unit startup and power operation,

. completion of walkdowns to identify any remaining materiel condition concems,

' . completion of the review of information related to significant recurring or repetitive equipment problems and the development, implementation, and

. completeness of actions to address these problems, and

. implementation of compensatory measures (as appropriate) for post-restart items / issues and assessment of their collective safety impact.

Final system walkdowns will be conducted to confirm that there are no significant unidentified material condition issues. Walkdowns at system operating temperature and pressure will be conducted, as appropriate, to confirm system restoration during plant restart and power ascension.

System readiness assessments will be reviewed by the system engineering supervisor, Plant Engineering Manager, Plant Shift Superintendent and the Hardware Subcommittee (see Attachment 6). System readiness affirmations also will provide input into the overall RSC assessment of site readiness.

B. Program Readiness Assessments-For those programs requiring improvement actions prior to restart, as determined through the initial program screening, program owners will affirm the readiness of PMEsTART.wpd Revision 0 Page 20

l l Maine Yankee Restart Readiness Plan l their programs to support plant startup and power operation. The assessment j performed to provide this affirmation will include:

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confirm resolution of any open regulatory issues, e evaluation of the actions taken to resolve performance issues, e

description of the methods that will be used to maintain program compliance with regulatory requirements and industry standards, and implementation of compensatory measures (as appropriate) for post-restart items / issues.

A general review of department programs will also be part of the department readiness assessment.

Final program readiness affirmations will be reviewed by the Non-Hardware Subcommittee. Reviews by the Non-Hardware Subcommittee and other cognizant managers will be input into the overall RSC site readiness assessment.

C. . Department Readiness Assessments Prior to restart, managers responsible for each major functional department indicated in Attachment 8 will affirm the readiness of that department's ability to support an error-free startup and safe and reliable operations. The assessment performed to provide this affirmation will ensure:

. confirm resolution of any open regulatory issues,  !

. department completion of assigned restart actions,

. ensure that programs, processes, organization, and personnel / management capability are sufficient to support safe and reliable operation,

. resolution of culturalissues or barriers to safe plant operation,

. ensure that post-restart work and improvement efforts are sufficiently defined, prioritized, scheduled, and controlled, and ensure that appropriate post-restart assessments and monitoring processes are in place to prevent recurrence of any performance issues.

Final department readiness affirmations will be reviewed by the RSC. Reviews by the Non-Hardware Subcommittee and other cognizant managers will be input into the overall RSC site readiness assessment.

D. Integrated Site Assessment Prior to initiating the integrated assessment, the RSC will establish measures to define when the plant is ready for restart, including:

. root causes are understood with required corrective actions implemented, e maintenance, engineering and other backlogs are adequately reviewed, screened and restart issues resolved with appropriate completion schedules established for non-restart required items, and

. specific activities and initiatives (e.g., action plans and hardware /non-hardware action items) are completed.

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Maine Yankee Restart Readiness Plan The RSC will complete an integrated assessment of overall site readiness including the effectiveness of management in resolving performance issues and establishing methods to prevent recurrence). The management assessment will include the following key areas (see Attachment 11):

. Oversight and Commitment

. Organization and Support

. Operations and Maintenance

. Corporate Cupport in addition to the management assessment, the overall site readiness assessment will consist of a " roll up" of several interfacing and overlapping inputs including:

. Action Plans for significant restart issues,

. resolution of extent of condition issues, e outage work order completion (Hardware Restart List),

. completion of Leaming Bank tasks required for restart (Non-hardware Restart List) e system readiness affirmation, e program readiness affirmation,

. department readiness affirmation,

. Licensing and QPD affirmations, e closecut and disposition of all restart list items, and

. str.tus of short term improvement plans.

The integrated readiness assessment of MY to restart will be documented in Attachment 12.

E. Restart Recommendation The RSC will review and evaluate both the individual inputs and the roll-up of these inputs and provide a recommendation to the President MYAPC for restart authorization. The RSC readiness assessment will be completed before initial reactor startup. Preliminary or intermediate assessments will be conducted as determined appropriate by the RSC, the Vice President Operations, or the President MYAPC. The NSARC also may review site readiness for initial mode change as it deems appropriate. Required review and approval by PORC will be completed prior to initiation of startup activities.

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l Maine Yankee Restart Readiness Plan 4

IX. Startup and Power Ascension t

Startup and power ascension will follow a controlled and deliberate process to restore the plant to power operation including dedicated management, augmented management structure and l responsibilities and pre-defined hold points for physical plant inspection. A detailed plan for initiating ;

the startup and power ascension will be prepared under the leadership of the Plant Manager and 1 approved by the RSC prior to initiating the integrated site readiness assessment.

The following items will be considered in the development of the plan for startup and power ascension:

activities necessary to demonstrate operability of technical specification systems, activities necessary to demonstrate operability of secondary and support systems,

. results of pre-startup testing,

. adequacy of system lineups, e adequacy of surveillance tests and surveillance test program, I

. verification of the resolution of significant hardware issues,

. testing requirements during startup and power ascension,

. maintenance requirements during startup and power ascension, and shift staffing requirements during startup and power ascension including operations, maintenance, engineering and other support requirements (e.g., RP, chemistry).

The following hold points during the startup and power ascension process are defined on a  ;

preliminary basis: '

1. Prior to Heatup (<210F in RCS)

A. Management Readiness

During the startup and power ascension activities, dedicated management will provide a direct on shift presence to assess the ongoing activities. They will maintain a cognizance of these activities and assist the Plant Shift Superintendent as necessary to resolve issues. The major focus of the on shift manager is SAFETY.

The manager will insure that hold points are not exceeded until the appropriate reviews are provided as per the startup and power ascension plan.

B. Restar1 List Assessment Each restart subcommittee will review their restart list and assess if any items not completed are necessary prior to commencing a plant heatup. This will be reported to the RSC and will indicate at what point open issues will be resolved and will provide a summary of items that are to be included in Phases 2 and 3. The Hardware Subcommittee will review the deferral process to insure that all work orders are appropriately deferred.

C. System Lineups The Operations Department personnel will perform system lineups in accordance with the appropriate system procedure. Documentation of these lineups will be P

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maintained by the department and a report will be made to the Hardware

Subcommittee that all lineups are completed as appropriate. j l

L D. ' Chemistry Conditions 1.

The Chemistry Section Head will provide a report to the Hardware Subcommittee concerning the status of plant systems and any conditions that warrant special attention during the plant startup and power ascension.

E. Plant Modifications The Engineering Division will provide a report to the Hardware Subcommittee indicating the closeout status of all. plant modifications instituted during this shutdown. The report will include, but not be limited to, testing, training and document updates.

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F. OPIT Review of Outage Status The Outage Planning and integration Team will review the outage work list to insure that the plant is ready to proceed to the heatup evolution and report the results to the Hardware Subcommittee. The report will indicate at what point open issues will be resolved and will provide a summary of items that are to be included in Phases 2 and 3.

2. Prior to Reactor Startup 1

A. Plant System Readiness Assessment A report will be provided to.the Hardware Subcommittee covering those items ,

provided in Section Vill of the RRP. The report will indicate at what point open issues will be resolved and will provide a summary of items that are to be included in Phases 2 and 3. i B. Program Readiness Assessment

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Program status report to the Non-hardware Subcommittee covering those programs as detailed in Section Vill of the RRP. The report willindicate at what point open issues will be resolved and will provide a summary of items that are to be included in Phases 2 and 3.

C. Department Readiness Assessment Department status will be reported to the Non-hardware Subcommittee covering those items provided in Section Vill of this RRP. The report willindicate at what point open issues will be resolved and will provide a summary of items that are to be included in Phases 2 and 3.

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C Maine Yankee Restart Readiness Plan D. Restart List Assessment Each restart subcommittee will review their restart list and assess if any items not completed prior to commencing the plant heatup are required prior to reactor startup.

This will be reported to the RSC and will indicate at what point open issues will be .;

resolved and any items to be included in Phases 2 and 3.

E. . System Walkdowns For those systems that are lined up and/or operating, each system engineer will perform a system walkdown while the plant is at normal operating temperature and pressure. The results of this walkdown. will be reported to the Hardware -

Subcommittee indicating any open issues that require resolution.

F. OPIT Review of Outage Status i The Outage Planning and Integration Team will review the outage work list to insure that the plant is ready to proceed to the reactor startup evolution and_ report the results to the Hcravare Subcommittee. The report will indicate at what point open issues will be resolved and will provide a summary of items that are to be included ,

in Phases 2 and 3.

3. 30% power j A. . System Walkdowns  ;

Each system engineer will perform a system walkdown while the plant is at normal' operating temperature and pressure. The results of this walkdown will be reported to the Hardware Subcommittee indicating any open issues that require resolution B, Operations 14rformance

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The Operations Manager will review operations activities during the heatup, reactor startup evolutions and ascension to 30% power to determine if any additional actions relative to organizational support, training, or equipment performance are required prior to continuing power ascension.

C. OPIT Review of Outage Status The Outage Planning and Integration Team will review the outage work list to insure that the plant is ready to proceed beyond 30% power and report the results to the Hardware Subcommittee. The report will indicate at what point open issues will be resolved and will provide a summary of items that are to be included in Phases 2 and 3.

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Maine Yankee Restart Readiness Plan i

4; 90% power  ;

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A. System Walkdowns Each system engineer will perform a system walkdown while the plant is at normal j operating temperature and pressure. The results of this walkdown will be reported to the Hardware Subcommittee indicating any open issues that require resolution.

B. Operations Performance The Operations Manager will review operations activities during the heatup, reactor startup evolutions and ascension to 90% power to determine if any additional actions relative to organizational support, training, or equipment performance are required to support continuing power operation.

C. OPIT Review of Outage Status The Outage Planning and Integration Team will review the outage work list to insure that the plant is ready to sustain power operation and report the results to the Hardware Subcommittee. The report will indicate at what point open issues will be l resolved and will provide a summary of items that are to be included in Phases 2 and 3.

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Maine Yankee Restart Readiness Plan X. Oversight Oversight of restart related activities to ensure that potential safety significant issues or areas of non-compliance with regulatory requirements are identified and effectively resolved will be achieved through a combination of line management involvement and independent review.

1. Line Management Line management is responsible for the quality completion of all restart activities. Oversight for high quality work products will be accomplished through the following activities:

. review of screening evaluations performed against the restart work criteria

, (Attachment 3) prior to submitting these evaluations to the Hardware and Non-hardware Subcommittees, e review and follow-up on actions assigned to their organization from the Hardware and i Non-hardware Subcommittees or the RSC,

. review of completed work products and closeout documentation prior to submittal to the Hardware and Non-hardware Subcommittees for closure,

. use of effective performance indicators to monitor department activities, and e reviews and approvals required by work implementing procedures.

2. Plant Operations Review Committee (PORC)

The PORC will provide oversight for restart activities through the following activities:

. approval of plant startup and power ascension actions, 4

. approval of restart activities within the scope of the PORC charter, and

. providing a recommendation to the RSC that the plant is prepared to initiate startup and power ascension.

3. Quality Programs Department (OPD)

QPD will provide independent oversight of the RRP in order to independently affirm to the RSC that there are no unresolved issues preventing startup of the unit. They will provide this oversight in four major areas:

. Action plans for significant restart issues, e hardware restart issues,

. non-hardware restart issues, and

. significant emerging issues.

A separate plan will be developed by QPD to provide oversight of startup and power ascension activities.

The QPD will conduct review and oversight through a combination of audit, surveillance, inspection and assessment activities. These activities will, in aggregate, review selected issues for completeness of plans, actions taken to resolve performance issues, methods provided to prevent recurrence and ensure that improvements are sustained, adequacy of closecut including documentation and appropriate field verifications, adequacy of root cause determinations and adequacy of extent of condition determinations.

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The Manager, QPD will be a member of the RSC and QPD representatives will be on the Hardware and Non-hardware Subcommittees. An organization chart of the QPD implementation of independent oversight is provided below.

Figure 5

! Restart Quality Prograrn Organization Mgr. Quality Programs i I Quality Rep Quality Prog Quality Rep Hardware Organization Non-Hardware i I Hardware Restart Action Non-Hardware Restart issues Plans (Appendix) Restart issues Oversight Oversight Oversight i l

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4. Nuclear Safety Audit Review Committee (NSARC)

The NSARC will fulfill their responsibility to advise the President, MYAPC on the RRP and readiness of the plant to restart through oversight and assessment of the RRP implementation.

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ATTACHMENTS I

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Maine Yankee Restart Readiness Pls.n Attachment 1 Definitions

1. Department Readiness Assessment The process whereby department managers ensure the readiness of their area of ,

responsibility by reviewing items such as performance indicators, organization staffing, personnel training, and self-assessment of performance results. (See Attachment 8)

2. Emergent Work All new work items that occur after applicable restart list issuance. i

3. Focus Programs List i Those MY programs with specific structure and purpose that have been selected by the non- l hardware subcommittee as being appropriate for initial performance review and final assessment. (See Attachment 7)

4. Hardware Restart List i

'; All work orders planned for completion in the 1997 refueling outage (designated 97 REFUEL) I including those that meet the restart criteria.  ;

5. Integrated Site Readiness Assessment An integrated review by the Restart Steering Committee (RSC) for restart readiness which includes assessments of system, program and department readiness reviews, restart list 4

closure, content of Phase 2 and Phase 3 plans and other ongoing self-assessment. (See

! Attachment 12)

6. Licensing / Regulatory Closure Affirmation Verification by Licensing that all restart actions required by MYAPC and the NRC are closed and have reasonable documentation and bases. (See Attachment 9)

7. Non-Hardware Restart List A list of program, process and organizational tasks that must be completed prior to restart of MY (a subset of the Learning Process data base).

8. Open items items that have the potential to affect components, subsystems, or system operations that

, must be screened, evaluated, and dispositioned. This dispositioning will result in a determination of whether or not the item is required to be resolved prior to restart.

9. Program Readiness Assessment An assessment of focus programs by program owners to determine the health and effectiveness of key plant programs.(See Attachment 7)

10. Quality Programs Closure Affirmation Verification by Quality Programs that there are no quality issues or concems that would prevent the initiation of MY restart and power operation. (See Attachment 10)

P:\ RESTART.wpd Revision 0 Attachment 1-1

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Maine Yankee Restart Readiness Plan Definitions (continued)

11. . Responsible Manager The manager who is accountable for ensuring that a restart issue is satisfactorily completed.

12. Restart issue An item assigned to a responsible manager for closeout prior to plant restart. These issues are maintained on the hardware or non-hardware restart lists. l

13. Restart Readiness Plan A document that summarizes process, methodology and basis for identifying and completing all work necessary to ensure the safe restart and power operation of MY.

14. Safety Significant System Those systems that could contribute the greatest to safe and reliable operation of Mi as j defined by the Maintenance Rule. (See Attachment 6)

15. System Readiness Assessment The process whereby an assigned owner ensures the readiness of a safety significant system ~oy reviewing appropriate documents, restart criteria, field walkdowns and other outstanding engineering / hardware issues. (See Attachment 6)

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PnREsTART.wpd Revision 0 Attachment 1-2 ,

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'l l Attachment 2 NRC 0350 Cross Reference ,

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^"achment2 Page 1 NRC 0350 Crocs Referenco ISSUE . Applicable _ Restart _ . Short term .Long term Notes / Comments Phase 1 Phase 2 Phase 3 l C.1.1 Root Cause Assessment: )

Conditions requiring the shutdown are l Part of CAL 9 YES App A&B N/A N/A clearly understood. i Root causes of the conditions requirWg YES App A&B N/A art oNAL 2 N/A the shutdown are clearly.understord. I

! Root causes oMer sigscant Part of CAL - Extent of Conditions i 3 YES V N/A N/A problems are clearly understood._ , _ _ . _ ____ _ _ _ _ __.

Evaluate adequacy of the root cau.e Implement. Evaluate & improve New 4 YES App F A E3.4.E3.5 analysis orooram Leamino orocess C.1.2 Damage Assessment:

Damage assessment was thorough and No Damaged Equipment 1 NO N/A N/A N/A i _

comprehensive, j Correct actions restored system & No Damaged Equipment 2 NO N/A N/A N/A l eauioment or verified oerformance as

C.1.3 Corrective Actions

l Evat ste adequacy of the Addressed through the RRP & Ph. 2 3 YES RRP Ph. 2 Plan N/A comprehensive corrective actiort plan. Plans l Evaluate adequacy of the Addressed through the RRP & Ph. 2 2 YES RRP Ph. 2 Plan N/A l _

comprehensive programs _for specific Plans Assess control of conecWe aedon item Actions are Part of Learning Bank -

3 YES RS List LearnBank LearnBank tracking. Equip. Actions are Part of WO_ Process .__

Effective corrective actions in place for Addressed in Appendix A&B of the RRP 4 YES App A&B N/A N/A conditions that required the shutdown.

Conect acdons fw othw sigscant Appendix C-H of RRP & Action Plans in 5 YES App C-H Ph. 2 Plan N/A problems.have been implemented. Ph. 2 Plan Adequate corrective action verification Addressed through Restart Assessments 6 YES Vil &X OA Assm OA Assm orocess and QA Assessments C.1.4 Self Assessment Capability:

Effectiveness of the Quality Assurance Evaluate By Entergy Assessment &

3 YES -

A -

Program Place Reg'd Jmprovements Jn Ph. 2 Plan Adequacy of Industry Experience Evaluate By Entergy Assessment &

2 YES -

A -

Review Prograrn _ _ _ _ _ _ _

Place Reg'd improvem_ents in. PA 2 Plan.

Adequacy of licensee's Independent EvaWate By Entergy Assessnwnt &

3 YES -

A -

Review Groups ___. Place Req'd improvements In Ph. 2 Plan _

Adequacy of deficiency reporting system Covered By New Learning Process 4 YES App F A E3.4 E3.5 Evaluated By NRC Week of 2/17 StaN wMngness to raise concems. A1,1 EvaNate By Ntwal Assessment &

5 YES Vill-3.C A Place improvemo_nts in Ph._2 Plan _ _. _.  ;

1. echeness of M N usage No Significant Problems Indicated in This 6 NO N/A N/A N/A Area ._

i Adequacy of Commitment Tracking Address improvements in Business Plan 7 YES - -

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rna audit (i.e. INPO) capability valiaieTy~$~ntergy Ass'essment &-

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Place flea'd Jrnprovements IrtPh. 2 Plan i g Quality of 10 CFR 50.72 and 50.73 YES - -

F2.6 Address Improvements In Business Plan Reoorts C.2.1 Manaaement Oversicht & Ef1ectiveness:

Management commitment to achieving valuate By Entergy Assessnwnt &

3 YES Vill- 3.D C D2.7 D2.8 improved performance . . _

Place. Reg'd improvements Jn Ph._2 Plan l Performance goals / expectations Summarized +G15 in Business Plan: l 2 YES Vill- 3.D -

App G developed.for staff.____ __ _ _ _ _ _ _ ._.__ __ _ _ _ _ _ _

introduction Section D1.3 & App G_

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G als/ expectations communicated t Communicated in Business Plan 3 YES Vill- 3.D -

D1.4

_ the staff ____ _ __ _ __ __ _ _ _ . _ _ _ __ _

Employee Briefinas _ _ ____ ____

Resources available to management t Evaluated By Tim Martin Study &

4 YES Vill- 3.D E E4.1 achieve goals _ incorporated _Into Business Plan Qualifications and training of Develop a Succession Plan and Mgmt 5 YES Vill- 3.D C D2.3 D2.7 l management Assm for Officers & Managers anagenwnts cwnment t Evaluate In Dept. Readiness Assm.

6 YES Vill- 3.D - -

procedure adherence Mgmt. Involvement in self-assessment & Address in Ph. 2 Plan 7 YES Vill- 3.D A E3.6

( _

independent self-assess. capability __ __ ___ _ _ _ _ . _

EMecweness ohnanagemed rWew Utilize Restart Committee & Then_ _ _ ___ _ _ _ _ _ _

! 8 YES Vlli- 3.D A _

committees . __ ___.. _ _ _ _ __ _ __ _ _ _ _ _ _ _ ___ Address.In Ph. 2 Plan _

g Effectiveness of internal management Evabate By Entergy Assessment &

YES Vill- 3.D C -

meetings ___ __. __ _ _ _ . _ _ _ ___ _ _ _ _ _ _ _

Place _ Req'd. improvements in Phx 2 Plan Management in-plant time Evaluate By Entergy Assessment &

10 YES Vill- 3.D C -

Place Rea'd Imorovements in Ph. 2 Plan 1

6

Attachm2nt 2 NRC 0350 Cross Refarcnco Page 2 ISSUE Appycable J _ Restart _ Short term _Long-te; ) Notes / Comments Phasei Phase 2 Phase 3 i

g Management's awareness of day-to-day YES Vill. 3.0 C - Evaluate By Entergy Assessment 8 operational concerns Place Reg'd Improvements in P.h 2. Plan _

Ability to identify and prioritize significant ad fNew amhg Rocess 4 12 YES App F A E3.4 E3.5 issues 13 ^.bility to coordinate resolution of YES App F A Part of New Learning Process significant issues E3.4 E3.5 g Ability to implement effective corrective Part of New Leaming Process YES App F A E3.4 E3.5 actions C.2.2 Management Oroanization & Support:

Stmeture of me organizadon EvaluaM By Entergy Assessment &

1 YES Vill-3.D D E4.2 Place. Reg'd Improvements _in Ph. 2 Plan Ability to adequately staff the Evaluated By Tim Martin Study &

2 YES Vill-3.D E E4.1 organization incorporated into Business. Plan E#ect of any nianagement Evaluate As Part Of Restart Readiness 3 YES Vill-3.D C&D E4.2 reorganization _

Establishment of proper work Assessrnent. ____.__ __

4 Evaluate By Cunural Assessrner &

YES Vill-3.D B D1.4 D1.5 environrnent _ __ _ _ _ _ . _ .__ _ _ _ _ _ _ _ . _ P_ lace improves I.n Ph 2 Plan _

5 Asty to foster Mamwo* among me - valuate By Entergy Assessment &

YES Vill-3.D F D2.1 staff ._ _ _ _

Place . Req'd improvements in.Ph. 2 Plan 6

y o msoNe employee comems. valuate By Cunural Assessrnent &

YES Vill-3.D B D1.4 D1.5 Place improvements in Ph. 2 Plan Ability to provide engineering support e w Engr Rograms Fw Restad 7 YES Vill-3.D H E4.5  ;

Adequacy of plant administrative Program Review is Part of Restart Plan 8

procedures.

YES VI & Att.7 G F3.2 Prog / Process improvernent is.On poinq _

g Information exchange with other utilities YES - -

F3 Enhancing industry Awareness is in The l

Business Plan, Section F 3 Participation in industry groups Enhancing industry Awareness is In The 10 YES - -

F3 i Business Plan, Section F-3 g Ability to function in the Emergency _ . _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ No Significant Problems Indicated in This Response Organization NO N/A N/A N/A

_ Area _ l g Coordination with offsite emergency NO N/A N/A N/A No Significant Problems Indicated in This i olannina official Area C.3.1 Assessment of Staff:

Staff commitment to achieving improved Evaluate By Cunural Assessment &

3 YES Vill-3.C B D1.4 D1.5 performance Place Improvements In Ph. 2 Plan Staffs safety consciousness vabate By Cunwal Assessnient &

2 YES Vill-3.C B Di.4 D1.6 j Place Improvements in Short Term .Plart Understanding of management's Communicate Business Plan Before 3 YES See Note -

D.3 E.6 expectations / goals Restart Undtestanding of plant issues and Communicate Business Plan Before 4 YES See Note -

D.3E.6 corrective actions _ _ _ _ _ _ ____ Restart _ _ __

aM valuate By Cuhural Assessrnent &

5 YES -

B8F G.1 j Place improvements In Ph. 2 Plan 1 Staff (union)/ management relationship. _ _ _ _ _ No Significant Problems Indicated in This 6 NO N/A N/A N/A Area Structure of the organization EvaluaM By Entergy Assessnet & I 7 YES -

D E4.2 Place _ Reg'd _lmproyements in Ph 2. Plan.

E#ect on tne sta# of any rewgaNzaton Evaluate By Restart Readiness 8 YES Vill D E4.2 Assessment Resources available to the staff Evaluated By Tim Martin Study Utilize 9 YES -

E E4.1 Contractors For Restart Qualifications and training of the staff Weakness in Maint Re-accreditation 10 YES See Note -

F1.3 Eval..By_INPO & Restart Readiness __

q Staffs work environment. _ _ . . _ _ _ _ _ . _ Evabate By CuRwal Assessment &

YES -

B D1.4 D1.5 Place Improyements in Ph. 2 Plan _. _

Staffs fitness for duty No Significant Problems Indicated in This 12 NO N/A N/A N/A Area Attentiveness to duty No Significant Problems indicated in This 13 NO N/A N/A N/A Area y Level of attention to detail No Significant Problems Indicated in This NO N/A N/A N/A Area Adequacy of sMng Evaluated By Tim Martin Study &

15 YES -

E E4.1 incorporated _Into Business Plan _ _ _

Off-hour plant staffing No Significant Problems Indicated in This 16 NO N/A N/A N/A Area

1 l

Attacnment 2 Paga 3 NRC 0350 Cross Rcfarrnco

_ _ ISSUE _ Applicable _ Restart _ Short-term. l.ong: term. ,

Notes / Comments Phase i Phase 2 Phase 3 Rotation schedule for shift workers No Significant Problems indicated in This 37 NO N/A N/A N/A Area Staff overtime usage Evaluate By Entergy Assessment &

18 YES -

E E4.1 Place Reg'd improvements Jn _PA2 Plan Am unt of contractor usage Evaluate By Entergy Assessment &

19 YES -

E E4.1 Place Reg'd_ improvements in PA 2 Plan.

Staff / contractor relationship Evaluate By Entergy Assessment &

20 YES -

D&E E4.1 Place Req'd improvements in P_h. 2 Plan.

Allegation process understood. Evaluate By Entergy Assessnwnt &

21 YES -

D D1.4 D1.5 Worker /NRC communication protected Place Reg'd trnprovements in Ph. 2 Plan _. ,

Procedure usage / adherence Evaluate In Dept Readiness Assessment 22 YES Vill-3.C - -

l Awareness of plant security No Significant Problems Indicated in This 23 NO N/A N/A N/A Area Understanding of offsite emergency No Significant Problems indicated in This 24 NO N/A N/A N/A clannino issues Area C.3.2 Assessment of Corporate Support:

Relationship between corporate and the Evaluate By Entergy Assessment &

1 YES -

D E4.2 plant. staff Place Reg'd .lmprovements. In Ph._2 Plan Adequacy of the request for corporate Evaluate By Entergy Assessment &

2 YES -

D E4.2 serv!ces process Place Reg'd_ Improvements.In Ph. 2 Plan Corporate understanding of plant issues Evaluate By Entergy Assessnwnt &

3 YES -

D E4.2 Place Reg'd_Jmprovements in Ph. 2 Plan _

Corporate staffin plant time Evaluate By Entergy Assessment &

4 YES -

D E4.2

_ _ Place _R_ eq'd Improvements in Ph 2 Plan.

Effectiveness of the corporate / plant _ _ _ Evaluate By Entergy Assessment &

5 YES -

D E4.2 interface rneetings. Place Reg'd. lmprovements .in P_h. 2 Plan.

Adequacy of corporata representation at Evaluate By Entergy Assessment &

6 YES -

D E4.2 plant activities _ _._ _ ___

Place Reg'd Jmprovernents in Ph. 2. Plan Adequacy of corporate engn. sering EvaMate By Entergy Assessrnent &

7 YES -

H E4.5 l support Place Reg'd improvernents in.Ph. 2 Plari. l Adequacy of corporate design changes EvaNate By Entergy Assessnwnt &

8 YES -

G&H E4.5 Place Req'd Improvements In_Ph. 2 Plan g Adequacy of licensing support YES -

D E4.3 Evabate By Entergy Assessmem &

Place Reg'd improvements In Ph. 2. Plan l

Coordination with offsite emergency No Significant Problems Indicated in This  ;

10 NO N/A N/A N/A olannina officia! Area C.3.3 Operator issues:

ucensed operator staffing meets Part of Final Restart Readiness Review l 1 YES Vlli-3.D - -

requirements and license _ goals __ ,_ ___ . _ __ .

Level of f rmality in the control room Part of Final Restart Readiness Review 2 YES Vill-3.D - -

Adequacy of control room simulator No Significant Problems indicated in This 3 NO N/A N/A N/A training __. _ _ _ _ _ _ ____ _ ___ __ Area Control room / plant operator awareness Part of Final Restart Readiness Review 4 YES Vill 3.D - -

of equipment status Adequacy of plant operating procedures Part of Final Restart Readiness Review

. 5 YES Vill-3.D - -

~ ~

Procedure usage / adherence Part of FEaIIiistafiheadiness Review-6 YES I

~

} Log keeping practices [ES~ Vill 3 D Piri'oIFinaiFEs~tarI~ Readiness Reviei C.4 Assessment of Physical Readiness of the Plant:

Operability of technical specifications System Readiness Assessment and 4 YES Att 6 IX N/A N/A systems Restart.& Power Ascension Plan _ _

Operability of required secondary and Part of Restart & Power Ascension Plan 2 YES IX N/A N/A support systems. _ _ _ _ _ _ _ _ . _ _ _ .

Results of pre-startup testing ._ art of Restart & Power Ascension Ran_ . _ _

3 YES IX N/A N/A

^ ~

} ASAqh[oikstedlI'n~eAps Yh[' IX / I art of Re5 tad & Power A3cension Plan y dequacy of surveillance tests / test Restart Plan Appendix G Evaluates the YES AppG & IX -

B.3 program Testinq Prog _ _ _ _ _ _ _

S gnificant hardware issues resolved Tracked By Restart Plan Appendix A-H &

6 YES App A-H I B.2 (i.e1 damaged /aqing equipment, modsL_ _. Restart Lists Adequacy of the power ascension Part of Restart & Power Ascension Plan 7 YES IX N/A N/A testina oroaram

^* chm 2nt 2 NRC 0350 Cross Ref:renco Page 4

_. _ _lSSUE . Appl.icable_ _ Restart _ Short-term Long-_ term .N_otes/ Comments _.

Phase 1 Phase 2 Phase 3 Adequacy of plant maintenance program 8 YES Vill-3.D G&H E1.1 effectiveness Maintenance backlog managed and 9 YES Vlll-3.D J B4.4 impact or) operation assessed Adequacy of plant housekeeping and 10 YES Vill-3.D equipment._storaQe g Adequacy of onsite and offsite NO N/A N/A N/A No Sigr.ificant Problems Indicated in This emeroency creoaredness Area C.5 Assessment of Compliance with Reaulatory Requirements:

Applicable license amendments have

$ YES AppC Att 9 N/A N/A been issued Applicable exemptions have been 2  ? Att 9 N/A N/A granted _.__

Applicable reliefs have been granted 3 7 Att 9 N/A N/A imposed Orders have been 4 . No N/A N/A N/A

. . , modified / rescinded Confirmatory Action Letter conditions 5 YES Att 9 N/A N/A haye been_ satisfied Significant enforcement issues have 6 YES Att 9 N/A N/A

_ beer 1 resolved Allegations have been appropriately 7  ? Att 9 N/A N/A

_ addressed _ _

10 CFR 2.206 Petitions have been 8  ? Att 9 N/A N/A appropriately addressed g Atomic Safety and Licensing Board NO N/A N/A N/A ASLB Hearing Not Planned hearinos have been comDleted C.6 Coordination with Interested Agencies /F arties:

Federal Emergency Management 1 NO N/A N/A N/A Agency.

Environmental Protection Agency 2 NO N/A N/A N/A Department of Justice 3 NO N/A N/A N/A Department of Labor 4 NO N/A N/A N/A Appropriate State and Local Officials Licensing Department Will Coordinate 5 YES See Note N/A N/A With NRC Appropriate Public Interest Groups Licensing Department Will Coordinate 6 YES See Note N/A N/A With NRC Local News Media Licensing Department Will Coordinate 7 YES See Note N/A N/A With NRC

Maine Yankee Restart Readiness Plan Attachment 3 Restart Work Criteria Restart work is based on two fundamental and related concepts: safety and compliance with regulatory requirements.

Conditions, issues and deficiencies which, if uncorrected, could reasonably result in the plant being in an unsafe, inoperable or non-compliant condition must be corrected prior to restart. Conditions, issues and deficiencies forwhich sufficient compensatory measures are implemented such that the plant is in a safe, operable and compliant condition may be corrected post-restart on a schedule  !

commensurate with their safety significance.

Criterion 1 Safety Screenina Can the condition, issue or deficiency reasonably result in the plant being in an unsafe condition, or a safety significant system or component being inoperable? For example:

- 1.1 Has the condition resulted in repetitive safety system or equipment failures?

1.2 Would the condition result in a plant transient, power reduction or plant shutdown?

1.3 Does the condition represent a deficiency in design basis, analysis or documentation that renders a system or component inoperable?

1.4 Does the condition result in non-technical specification equipment that is important to safety (per Operations Procedure 1-26-6) being inoperable?

1.5 Does the condition create the high potential for personnel injury or overexposure?

Criterion 2 Reaulatorv Reauirements Screenina l

Can the condition, issue or deficiency reasonably result in the plant being in a non-compliance condition with regulatory requirements (10CFR50, etc.), the MY operating license or technical )

specifications? For example:

2.1 ls the condition in non-compliance with the requirements of regulations (e.g., EQ, i Appendix R, etc.)? )

I 2.2 is the condition in non-compliance with the operating license?  !

2.3 Does the condition result in failure to satisfy a technical specification surveillance I requirement or place the plant in a condition outside of the technical specifications?

2.4 Does the condition result in an effluent release to the environment in excess of regulatory limits?

PRESTART.wpd Revision 0 Attachment 3-1 l

Maine Yankee Restart Readiness Plan i

Attachment 4 Work Order Review

, The flow chart on the following page summarizes the process that will be used to identify work orders i requiring completion prior to restart. The following key actions will occur:  !

OPIT performs the initial bulk review of work orders using existing outage planning criteria

, and the restart work criteria. The bulk review will be prioritized based on outage system windows and safety systems so that work can be planned and in-plant work can proceed efficiently.

Work screened as non-refuel will be reviewed by the Hardware Subcommittee to provide oversight of the screening result.

Work activities will be followed by the system owner as an integral element of the system l readiness review process. I l

Emergent work or work removed from the outage scope will be reviewed against the restart work criteria and, as appropriate, by the Hardware Subcommittee similar to the initial bulk review.

l

. The system owner willintegrate the open work order status into the final system assessment i i to ensure that the system is ready to support safe plant startup and power operation.  ;

l i

l l

l l

P3 RESTART.wpd Revision 0 Attachment 4-1

Maine Yankee Restart Readiness Plan l Attachment 5 i Corrective Action Program Review l

The flow chart on the following page summarizes the process that will be used to identify corrective action program /leaming process tasks requiring completion prior to restart. The following key actions

! will occur:

The Learning Process Team performs the initial review of corrective action program (old programs) and learning process (new program) issues against the restart work criteria.

. The results of the screening evaluation will be reviewed by the Non-hardware Subcommittee to provide oversight of the screening result.

Work activities will be followed by the issue owner and will be incorporated into the integrated Department Readiness Assessment.

Emergent issues or issues removed from the outage scope will be reviewed against the restart work criteria and, as appropriate, by the Non-hardware subcommittee similar to the initial review.

. The Department Manager will integrate the results of the complcted corrective action program / Learning Process tasks with the status of open issues and tasks into the Department Readiness assessment to ensure readiness of the department to support safe plant startup and power operation.

P:\ RESTART.wpd Revision 0 Attachment 5-1

Maine Yankee Restart Readiness Plan a

Attachment 4 Work Order Review Review Flow Chart r m Work Order Listing w a v

I 3 OPIT Non-Refuel 97 p__ _________

Outage Need I G .

i J I i

1 3r I OPIT I g

{_ _ _ _ _ _ ._ _ )

l Review for Restart Criteria

---

h i i

l i

I I if V I

Hardware RC r Refuel 97

_______l--------- Review Non. ---> Work List I '

I Outage Work (97 REFUEL) l I q J i

I I

g if i

f ' WO Owner Emergent or l 1 Action Changed (- - - Schedule & 4 i

I to Non-Restart Complete Work I q J I

I

, System Owner I ---------

! Follow Work &

I Emergent issues

.I I

I if I F 3 System Owner # '

I Non-Refuel Work I) List Final System

---> Conduct Final --->

(Sort by System) Review Form System Assm v J L J Hardware RC i Approve Final 4 System Assm.

P:\ RESTART.wpd Revision 0 Attachment 4-2

l l

1 4

M:ina Ycnkr2 Rect rt R:adinun Plin j

. l Attachment 5 Corrective Action Program Review Review Flow Chart  ;

1 r m r m r 3 Action New Learning Existing Learning 4 r cess issue Programs (CAP) Bankissues v 2 w J w 2 a if if l Depart. Mgr. LP Team l

j Review for LP -

Review for Restart 4 l Input & Restart Criteria i

_J 1 d

if Non Hardware RC F 3 l Restart Tasks

[

g Review & Approve --+ (Restart List) i i --------> Restart issues i I L > 1 l ' '

I l ' if I I F 3 Task Owner l

l Tasks Changed to Non-Restart (--- Complete Restart Tasks 4-------f I

'L J l l A i I

l if I l

l Issue Owner l 1

Review Completed --------' ,

I i

Restart Tasks '

1 I

if I r 3 Depart. Mgr. r 3 I

Non Restart

[y LP lssues/ Tasks Final Depart. l

---> Conduct Depart - - - > Assessment Form (Sort by Depart) g Readiness Assm.

j t J i

if Non Hardware RC l

i Review Depart. 4 Readiness Assm.

, if Restart Steer RC Approve Depart.

Readiness Assm.

P? RESTART wpd Revision 0 Attachment 5-2

Maine Yankee Restart Readiness Plan Attachment 6 Plant System Readiness Assessment The flow chart on the following page summarizes the process that will be used to perform the system readiness assessment ensuring identification and completion of all tasks requiring completion prior to restart. The following key actions will occur:

The system owner will perform an initial review of system issues, problems and open work items against the restart work criteria.

. A system walkdown will be performed to identify any other materiel condition issues not already identified and to evaluate these items against the restart work criteria to determine 4

if the item requires resolution prior to restart.

. The results of the screening evaluation will be reviewed by the Hardware Subcommittee to provide oversight of the screening result.

The system owner will also review other key documents relating to system operation, performance and documentation against the restart work criteria to determine if the item requires resolution prior to restart.

. Work activities will be followed by the task owner and tracked by the system owner as input to the final system readiness assessment. i

. Emergent issues or issues removed from the outage scope will be reviewed against the restart work criteria and, as appropriate, by the Hardware Subcommittee similar to the initial review.

. The system owner will complete a final system walkdown review and integrate the results of the completed tasks with the status of open issues and tasks and present a final system readiness assessment of the readiness of the system to support safe plant startup and power operation.

I

. The system owner will monitor the system during startup and power ascension.

PRESTART.wpd Revision 0 Attachment 6-1 1.

1 Maine Yankee Restart Readiness Plan Attachment 6 Plant System Readiness Assessment Assessment Flow Chart Sys. Prob / Issues e Y"** *"*' m Work Orders Learning Bank ---> Review System ---> R wF m ~1 Proposed Mods Problems / issues i Engr Actions j t > I V l System Owner F 3 l

System i Conduct System ---> Walkdown Form i Walkdown i

. L .

J l j _ _ _ _ _ _ _ _ _ _ _ _ _ 4_ _ _ _ _ _Y Hardware RC F 3

> Restart Actions

, Initial Restart --->

Committee Review (Restart List)

' V J g_____________J 2 r 3 Emergent or Task Owner Action Changed to (g- '

Schedule &

Non-Restart Complete Task L J l

DBSD Syste Owner F 3

~~

Procedures Review Completed _ _ _y Final System Testing Require

- - - > Tasks, Documents Assessment Form ,

Vendor Info. & Emergent Issues (  ; I (FSAR j l

r 3 System Owner #

Non Outage Work l List System i

---> Conduct Final --->

(Sort by Sys) Walkdown Form I System Wakdown I q j k J l 8

I v l Hardware RC I l

Approve Final 4------- ~~~-'

System Assm.

V System Owner Monitor System During Startup &

Pwr Assension P.\ RESTART wpd Revision 0 Attachment 6-2

Maine Yankee Restart Readiness Plan Plant System Readiness Assessment Listing of Significant Systems

1. Auxiliary Feedwater/ Emergency Feedwater l 2. High Pressure Safety injection i

3. Switchgear Room Ventilation

4. AC and DC Electrical Distribution

5. Containment Spray

6. Emergency Diesel Generators

7. Low Pressure Safety injection L

8. 115 KV Offsite Power

9. Residual Heat Removal

10. Safety Actuation Systems 11, Altemate Shutdown / EFCV Air

12. Service Water and Component Cooling Water l 13. Reactor Protection

14. Condensate / Feedwater

15. Instrument Air

16. Fire Protection

17. Containment isolation

18. Reactor Coolant

19. Cor trol Room Ventilation

20. Other HVAC

21. Radiation Monitoring Notes: 1. The Reactor Coolant, Control Room Ventilation, Other HVAC and Radiation Monitoring systems have no explicit modeling in the PRA and therefore cannot be assigned a risk ranking. These systems are included for completeness only.

2. The RSC can add or delete systems from this list as a result of review activities.

l l

P.WEsTART.wpd Revision 0 Attachment 6-3

l Maine Yankee Restart Readiness Plan i

Attachment 7 Plant Program Readiness Assessment The flow chart on the following page summarizes the process that will be used to perform the program readiness assessment ensuring identification and completion of all tasks requiring completion prior to restart. The following key actions will occur:

The Non-hardware Subcommittee will perform an initial screening of plant programs to determine which programs require assessment during the Phase 1 (prior to restart). The criteria on the flow chart and input from other personnel in the organization will be used to make these decisions. ,.

The program owner will perform an initial review of program issues, problems and open work items against the restart work criteria.

. The results of the screening evaluation will be reviewed by the Non-hardware Subcommittee to provide oversight of the screening result and to determine if more detailed assessment and evaluation of the program is required prior to plant restart.

Work activities will be follower' / the program owner and tracked as input to the final program readiness assessn.er.>

Emergent issues or issues rem ried from the outage scope will be reviewed against the restart work criteria and, as appr apriate, by the Non-hardware Subcommittee similar to the initial review.

As directed by the Non-hardware Subcommittee, the program owner will complete a final program readiness assessment of the readiness of the program to support safe plant startup and power operation.

?

l P:\ RESTART.wpd Revision 0 Attachment 7-1

1 Miina Yanksa Ruttrt Rndiniss Pirn Attachment 7 Plant Program Readiness Assessment Assessment Flow Chart 1 I

e , j Priority Matrix Programs List Known Short L s Restart Problems Term?

if l

1. ' l No Prob. Long Short _ _ _ .) Non Hardware RC Restart l Indicated Term? Term?

Review & ---> Programs List Non- Safety Prioritization (Phase 1)

Safety e  ;

_____________.]

[Problemllssues ) Program Owner I T Ownership Initial Program Procedures List Conduct Initial ---> Review Form Learning Bank

_ _ _)

Program Review Backlogs & Pls L >

i Qnspections/Assm. j g_____________-

Non-Hardware RC r 3 Final Prog. Assm.

_________y Review for Restart ---> Not Required l Criteria & Need --

For Restart I, For Final Assm. lt

,, <______3 F 3 # '

Task Owner Emergent or Restart Actions Actions Changed (g- Complete Restart 4-- (Restart List) to Non-Restart i Actions t J l k J l

I I Document Review ) I Program Owner F 3 Reg. Requirements I_ -

Procedures Review Review Actions & Final Program

~ _ _ _) Assessment Form industry Experence Conduct Final NRC Information Program Assm. t J (Flow Chart j j 1r i Non Hardware RC l Review Program 4 Readiness Assm.

. if Restart Steer RC Approve Program l Readiness Assm. 3 l

l P:\ RESTART.wpd Revision 0 Attachment 7-2 l i

i l

Maine Yankee Restart Readiness Plan Attachment 8 Department Restart Readiness Assessment The flow chart on the following page summarizes the process that will be used to perform the Department readiness assessment ensuring identification and completion of all tasks requiring completion prior to restart. The following key actions will occur:

. The Department Manager will perform an initial review of department issues, problems and open work items against the restart work criteria.

. The results of the screening evaluation will be reviewed by the Non-hardware Subcommittee to provide oversight of the screening result.

. Work activities will be completed by the task owner and tracked by the department Manager as input to the final Department readiness assessment.

. Employee communication meetings will be held to discuss any department issues requiring resolution and to identify barriers to performance improvements.

. Emergent issues or issues removed from the outage scope will be reviewed against the

. restart work criteria and, as appropriate, by the Non-hardware Subcommittee similar to the initial review.

. The Department Manager will complete a final Department Assessment that integrates the results of the completed tasks with the status of open issues and tasks and present a final Department readiness assessment of the readiness of the department to support safe plant startup and power operation.

P:\ RESTART.wpd Revision 0 Attachment 8-1

Maine Yankee Restart Readiness Plan l

Attachment 8 l Department Restart Readiness Assessment 4

Assessment Flow Chart  ;

IProblem/ Issues ) Department Mgr. # T l

l Learning Bank Backlogs & Pls Conduct Initial --->

Engr. Actions - _ _ _) eWew Fonn Depart. Review Inspections / Audits (  ;

(Self Assessments y _____________j Non Hardware RC F 3 ,

I Restart Actions Review for Restart - - - >

---

--> (Restart List) l l Criteria i I L J 8

1 i

'- I l e if I I l Actions Changed 4- - -

Task Owner Complete Restart I--------l j 1 to Non-Restart Actions ---------l i

i k > l j

i l l l if i I # 7 Department Mgr. I esent t o s Conduct Depart. --------

Employee Meetings I-I (

l

> I l

l [Peoole/Procrams D if I, 1 Org & Responsib. Department Mgr. i i

I I

Programs / Process Procedures Training

---> Conduct Final Department Assm.

---

~f  ;

l i (Employee /Mgt Perf. j l

' 'r v

' I ' Department Mgr. r 3 i

Non-Restart LP Final Department l.) (Sort by Depart) _ _ _) Verify Restart ---)

Actions Complete s s Fm i L J q y if i Non Hardware RC l Review Depart. (-------

Readiness Assm.

s if Restart Steer RC Approve Depart.

Readiness Assm.

P3 RESTART.wpd Revision 0 Attachment 8-2

Maino Yankee Restart Readiness Plan Attachment 9 Licensing Regulatory Closure Affirmation The Licensing Manager shall consider the following in providing affirmation that all restart licensing required items are closed:

Applicable license amendments, if any, have been issued.

Applicable license exemptions, if any, have been granted.

Applicable reliefs, if any, have been granted.

. Imposed orders have been modified / rescinded.

• Confirmatory Action Letter conditions have been satisfied.

. Significant enforcement issues, if any, have been resolved.

Allegations, if any, have been appropriately addressed.

10CFR2.206 petitions, if any, have been appropriately addressed.

. Alllicensing actions have been closed.

. Open license commitments have been reviewed.

P.WEsTART.wpd Revision 0 Attachment 9-1

i l Maine Yankee Restart Readiness Plan I I l

i l l

L Attachment 10 l Quality Programs Closure Affirmation l

l The Quality Programs Department Manager sha'l review the following elements in providing affirmation that there are no additionalissues preventing unit restart:

The results of all quality verification activities performed to insure adequacy of response and closure of Phase 1 activities such as:

. Action Plans for significant restart issues,

. hardware restart issues,

. non-hardware restart issues, and

. significant emergent issues.

In reviewing these elements, the Manager shall consider the following criteria:

. completeness of planning, l

. adequacy of root cause determinations, including determinations of extent of condition,

. appropriateness of actions taken to resolve performance issues, a methods to prevent recurrence,

. methods to ensure that improvements are sustained, and

. adequacy of close-out, including documentation and field verifications.

PAREsTART.wpd Revision 0 Attachment 10-1

Maine Yankee Restart Readiness Plan Attachment 11 Management Effectiveness Assessment 4 Page 1 of 2 The RSC shall consider the following in providing afflrmation that management is ready to support safe startup and power operation:

Oversiaht and Commitment a

management commitment to achieving improved performance

. goals / expectations communicated to the staff a

resources available to management to achieve goals qualifications and training of management support safe operation

. management commitment to proceduns adherence e

management involvement in self-assessment and independent assessment

. effectiveness of management review committees effectiveness of internal management meetings e management in-plant time e management awareness of day-to-day operational concerns e ability to identify and prioritize significant issues e ability to implement effective corrective actions Oraanization and Sucoort

. structure of the organization

. ability to adequately staff the organization

. effect of any reorganization

. establishment of the proper work environment

. ability to foster teamwork among the staff

= ability to resolve employee concerns e ability to provide engineering support

. adequacy of administrative procedures Operations and Maintenance e licensed operator staffing meets requirements e level of formality in the control room

. adequacy of control room simulator training control room / plant operator awareness of equipment status

= adequacy of operating procedures e procedure usage / adherence

. log keeping practices

. maintenance program effectiveness e maintenance backlog managed and impact on operation assessed

. adequacy of plant housekeeping and equipment storage P3 RESTART.wpd Revision 0 Attachment 11-1

Maine Yankee Restart Readiness Plan Attachment 11 Management Effectiveness Assessment Page 2 of 2 Coroorate Sucoort a relationship between corporate and the plant staff

. adequacy of the request for corporate services process

. corporate understanding of plant issues

= corporate staff in-plant time e effectiveness of the corporate / plant interface meetings e adequacy of corporate representation at plant activities e adequacy of corporate engineering support

- adequacy of corporate design changes

. adequacy of licensing support a coordination with offsite emergency planning officials l

l PMEsTART.wpd Revision 0 Attachment 11-2

l l Maine Yankee Restart Readiness Plan l l l l

l Attachment 12 I i Integrated Site Readiness Assessment l The RSC shall consider the following in providing affirmation to the President, MYAPC that the l MY plant is ready to initiate startup and power ascension:  ;

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1. Action Plans for significant restart issues (Appendix to RRP)

2. Final check against NRC Inspection Manual Chapter 0350, " Staff Guidelines for Restart Approval" (Attachment 2)

3. Extent of Condition conclusions (Section V)

4. Outage Work Order completion (Attachment 4)

5. Restart Learning Bank task completion (Attachment 5)

6. Safety system assessments (Attachment 6)

7. Program reviews and assessments (Attachment 7)

8. Department assessments (Attachment 8) i

9. Licensing / Regulatory Closure Affirmation (Attachment 9)

10. Quality Programs Closure Affirmation (Attachment 10)

11. Management Effectiveness Assessment (Attachment 11)

12. Startup and Power Ascension plan implementation (Section IX)

13. Short-term (Phase 2) plan implementation (Attachment 13) l P3 RESTART.wpd Revision 0 Attachment 12-1

I Maine Yankee Restart Readiness Plan l

Attachment 13

' Short Term (Phase 2)

Preliminary Listing of Focus Areas l A. Improve Self Assessment Capability B. Evaluate and improve Culture C, Management Effectiveness D. Organizational Effectiveness and Corporate Support E. Staffing Adequacy F. Teamwork and Communications G. Program Ownership and Process improvement H. Department-specific improvement Plans I. Material Condition Improvements J. Backlog Reduction K. Margin improvement I

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I Maine Yankee Restart Readiness Plan  !

I APPENDIX Action Plans for Significant Restart issues 1

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> Maine Yankee Restart Readiness Plan APPENDIX A

. GENERIC LETTER 96-01: LOGIC CIRCUlT TESTING  :

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l Maine Yankee Restart Readiness Plan

1. INTRODUCTION l Generic Letter 96-01, " Testing of Safety Related Logic Circuits" requested that licensees review their i

surveillance procedures for the reactor protection system, EDG load shedding and sequencing, and actuation logic for the engineered safety features systems to ensure that complete testing is being performed as required by Technical Specifications. During the performance of the required

! evaluations, it was determined that numerous logic circuits were not adequately tested in surveillance procedures per the criteria described in the generic letter.

II. ROOT CAUSE

SUMMARY

Plant Root Cause Evaluation (PRCE) No. 215 was chaitered, in part, to perform a root cause evaluation for the identified surveillance procedure inadequacies. PRCE No. 215 identified the following causal factors related to this issue:

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The design basis functions of system components to be demonstrated by surveillance testing are not clearly defined.

Surveillance test procedure technical requirements regarding methods, acceptance criteria and scope are not defined.

I The correct resources (personnel, methods and equipment) are not used to develop and -

revise surveillance procedures.

• No program ownership has been established to oversee surveillance test implementation and 2 development and communicate surveillance test expectations. j Management policy was to limit surveillance testing of logic circuits to the scope explicit in the Technical Specifications. l

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The Self Assessment process was ineffectual in identifying quality improvements in the surveillance testing program.

i 111. CORRECTION PLAN

SUMMARY

l immediate Actions Taken:

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1. An initial evaluation of logic testing adequacy was completed in December 1996. I

2. Identified surveillance issues were reported to the NRC via LER 96-043. Not all issues were reported at this time. Revision (s) to the LER is required to identify additional issues.

3. An independent review was completed in February 1997. New issues are screened by Operations for the current plant condition.

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Maine Yankee Restart Readiness Plan 4

4. Temporary test procedures, temporary procedure changes and surveillance procedure 1

modifications were developed to verify required logic circuits were tested prior to start-up.

Actions to be taken prior to restart:

1. Complete the evaluation of the Generic Letter 96-01 logic circuits.

2. Complete the evaluation and disposition of all of the identified issues from both the initial and independent review.

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3. Incorporate the resolution of logic testing discrepancies into permanent surveillance procedures. (See Appendix G " Surveillance Testing")

4. Evaluate the recommendations identified in PRCE 215 and place in Learning Process.

Identify and complete those activities identified as restart issues.

5. Assess the causal factors identified in PRCE 215 as part of the " Extent of Condition" evaluation (see Section V).

6. Perform the surveillance testing using revised /new procedures.

Post-Restart Actions: ,

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1. Complete the remainder of the PRCE No. 215 identified activities.

l IV. SCHEDULE Activity Scheduled Comoletion Date Complete independent review Complete ,

Complete Generic Letter 96-01 Commitments (surveillance 06-01-97 procedures revised) )

Issue Review Report 04-01-97 Perform independent issue resolution review 07-01-97 Perform the surveillance procedures revised / developed 07-15-97 for GL 96-01 logic testing V. ASSESSMENT OF lMPLEMENTATION EFFECTIVENESS Long-term continual assessmw of surveillance procedure adequacy will be performed by the newly formed System Engineering Section. They will be performing systematic reviews of the assigned system'which will include testing and testing requirements rather that the component-based j approach used in the past. -

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APPENDIX B CABLE SEPABATION Revision 0 Appendix B-1

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1. INTRODUCTION In December 1996, instances of apparent deviations were discovered in the cable separation configurations between the "as found" installed cables and the original designs. As a result, Maine Yankee established a program to review and verify that the cables important to safety were installed in a manner consistent with the established design bases.

l The objective of this program is to provide reasonable assurance, as required by 10 CFR 50 I

Appendix B, that the cable routing for safety related equipment provides physical separation to accomplish decoupling of the effects of unsafe environmental factors, electric transients, and physical accident consequences documented in the design basis and to reduce the likelihood of i

interactions between channels during Maintenance operations or in the event of channel malfunction l (reference IEEE standard 279-1968).

The general scope of the program consists of reviewing plant modifications to determine which safety class cables and non-nuclear safety related 480V or larger and high current DC power cable i routings may have been affected. This scope is based on a review of past "as found" installations I that led Maine Yankee to conclude that the original plant construction is not in question. This I assumption to the program scope is in the process of being validated by review of a large sample l of the plant's original construction cable routings. Field walkdowns are being performed for any l modified raceways that contain the above cables. These walkdowns are intended to identify cables, l including many original construction and non-nuclear safety class cables, and evaluate their l respective cable separation adherence to the FSAR criteria intent.

11. ROOT CAUSE

SUMMARY

The four cable separation issue causal factors were determined and documented in the Plant Root Cause Evaluation No. 214 as:

1. Ambiguous and conflicting cable separation criteria contributed to the cable separation deficiencies which have been identified.

2. Plant electrical drawings contain inaccurate informstica.

3. Train affiliation labeling for cables and cable trays is less than adequate.

4. Cabling separation training for engineers and craft personnel has been less than adequate.

Ill. CORRECTION PLAN

SUMMARY

The corrective action plan for resolution of the cable separation issue is detailed within the Cable l

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Maine Yankee Restart Readiness Plan Separation Program Plan. The scope of this Plan includes the identification, evaluation and/or resolution of the cable separation discrepancies. A summary of the Plan is presented below.

1. Re-articulation of the Licensing Bases, Design Bases, Engineering Bases and Implementing I

Criteria for Cable Separation at Maine Yankee The licensing bases and design bases requirements are captured in the FSAR and in I correspondence on the Maine Yankee docket.

I A compendium of licensing bases, design bases, engineering bases, and implementing criteria are contained in Maine Yankee Technical Evaluation TE-226-96, Cable and Wire

, Separation Criteria. This document summarizes the original separation criteria for cables and circuits and was compiled from the FSAR, controlled drawing notes, and engineering

and licensing correspondence from the plant construction period with references for each 8

requirement.

i This task separates the licensing bases and the design bases as defined in NUREG-1397, the engineering bases from TE-226-96 and the implementing criteria from MY-STAND-ELEC-1 and compares individual " issues" on a subject specific basis. This will allow engineers to l clearly see and understand the technical differences, if any, in the different levels of specified requirements and to more clearly evaluate the current level of conformance of the questionable installations to the licensing basis.

2. Assessment of Condition The Maine Yankee Cable Separation Assessment and Walk-down Project purpose is to

verify the acceptability or resolve the discrepancies related to the physical separation of cables. This will be accomplished by performing selective walkdowns. The criteria set forth in TE 226-96 has been utilized during these walkdowns.

The scope of these walkdowns includes all safety related cables,480 V AC and larger non-nuclear safety related cables and high current DC cables installed by modifications after initial fuel load. The process verifies that proper safety related train / channel separation exists. The verification / walk-down portion of the effort has been divided into distinct phases which are described in the following section.

Given that nearly all cable separation discrepancies discovered have involved plant modifications and that a review of plant construction records indicates significant QA effort to verify cable installation, the original construction cables and circuits are assumed to be in installed in accordance with the original design basis. Any original construction discrepancies discovered during the effort will be investigated and the scope of the project will be redefined as needed.

2.1 Verification Activities Phase I involves a verification of cable separation adequacy within sleeves, ducts and imbedded and scheduled-exposed conduits which have been impacted by plant Revision 0 Appendix B-3

Maine Yankee Restart Readiness Plan modifications. It is accomplished by implementation of Maine Yankee Procedure 17-52, Cable Separation Assessment and Walk-down Procedure.

Phase ll involves a verification of cable tray separation and tray to sleeve / duct and tray to conduit transition separation. It is also accomplished in accordance with Maine Yankee procedure 17-52, Cable Separation Assessment and Walk-down Procedure.

Phase Ill involves an extent of condition assessment of the separation of the Main Control Board. A visualinspection and a photographic mapping is being performed to ,

support a better understanding of the original design and the current state of condition. I This review will be accomplished in accordance with Maine Yankee procedure 17-53, Main Control Board and Control Room Panel Separation Assessment Procedure.

2.2 Evaluation of Inspection Results l

Any discrepancy or potential discrepancy related to cable routing separation identified is 1 documented on a discrepancy tracking form. Minor degradation in physical barriers are j immediately repaired. The discrepancy tracking form is reviewed by the issue Evaluation i Group and if the discrepancy is valid, the group will resolve the concern. I 2.3 Resolution and Correction of Discrepancies One or more of the following actions will be used to resolve discrepancies.

A. Correct "as found" to "as designed" The configuration of cables which are found to be in conflict with the appropriate design documents or criteria may be reconfigured to comply with the approved design. This may include, but is not limited to re-pulling, rerouting, installation of barriers or other appropriate alternate methods of achieving independence.

B. Engineering Evaluation to accept "as is" An engineering evaluation may be performed with discrepant cables to accept the cables as installed. This may include a safety analysis and/or a functional redundancy analysis.

C. Long Term Corrective Action Maine Yankee intends to correct all deficiencies practicable prior to restart. There may be some deficiencies which could require completion in the post restart time period. In this situation, a safety evaluation will be performed and compensatory action (s) may be established. The long term corrective action (s) will be placed on the post restart list for implementation in the appropriate time period.

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IV. SCHEDULE Activity ScheduledComoletion Date item 1 Complete 1 Item 2.1 '

i PhaseI Complete Phase ll 03/30/97 Phase ill 05/31/97 Item 2.2 06/01/97 Item 2.3 Item A 06/01/97

Ite m B 06/01/97 Item C Plan Development 06/01/97 i V. ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS A self-assessment of performance within the cable separation project organization is conducted in l structured, scheduled fashion bi-weekly meeting focusing on the group effectiveness associated with l 4

activities of the preceding period. The meetings are also a principle vehicle for communication of management expectations and goals, issues discussed include:

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. Industry Experience Review  !

. Interface with Maine Yankee's Independent Review Groups  ;

Deficiency Report'::g

. Staff willingness to raise concems

. Original design commitment tracking I

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. Quality decisions made in the period of review

. Conformance to licensing bases issues

. Open Safety issues

. Radiation Control Open issues

. Quality and Technical Issues I

. Scheduling, Manpower, and logistical Issues I

. Corrective Action Reporting I

. Regulatory issues The above areas will, on a selective basis, be subjected to a more formal self-assessment prior to re-start.

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d APPENDIX C 115 kV OFFSITE POWER 1

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j l. INTRODUCTION l

When supplied only from 115KV Section 69, the 115KV off-site power voltage will not recover quickly i l enough after a plant trip and Safety injection (SlAS) to prevent a load shed and emergency diesel l auto-start This condition occurs because the motor-driven-feed-pumps P-2A or 2B will auto-start l on low feedwater header pressure after a plant trip and P-2C (steam-driven-feed-pump) trip. The l i starting foad of the motor, coupled with the other plant auxiliary loads, will keep the bus voltage low l enough for the five (5) seconds required to start the load shed sequence.

Maine Yankee recently submitted a Technical Specification change to require two (2) operable 115KV lines which will be in effect prior to plant restart. This Technical Specification change will require a natural circulation cooldown of the plant when the Technical Specification remedial action time for loss of off-site power is exceeded.

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11. ROOT CAUSE

SUMMARY

A Learning Bank entry has been made. The earlier versions of the Maine Yankee Voltage dNdy

. were performed with no interdisciplinary review. Maine Yankee now has an Electrical Calculation Design Review Committee that reviews all new electrical calculations and revisions to existing cales.

This committee, which has representatives from Engineering, Operations, Maintenance and Licensing, provides a comprehensive review for any impact on Maine Yankee from our electrical calculations.

Ill. CORRECTION PLAN

SUMMARY

1mmediate action taken:

Until recently only one (1) off-site power 115KV line was required to be operable for normal plant )

operation, with the 345KV system backfeed as the backup off-site supply. Maine Yankee submitted a Technical Specification change to require that both 115KV lines be operable at power. This Technical Specification change is pending, l

Actions to be taken prior to restart: 1

1. A modification will be completed to block the auto-start and trip the motur driven feed pumps on a safetyinjection actuation signal. This modification will also include a trip of the containment recirculation fans FN-17-1,3,5 on SlAS to increase voltage margin for 480V motor-operated valves.

2. The Maine Yankee Voltage Study, Calculation MYC-430, will be revised to verify that 115KV Section 69 is restored to an operable line after the modification is completed.

3. The proposed Technical Specification change must be approved.

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Maine Yankee Restart Readiness Plan Long term actions:

Evaluate the replacement of off-site power transformer X-14 with either a high speed load tap changer or a parallel X-14 to increase off site power margin.

IV. SCHEDULE Activity Scheduled Comoletion Date Complete the modification 07/01/97 Complete Calculation MYC.430 to verify the operability 07/01/97 of 115KV Section 69 Evaluate need for additional long term actions to improve 12/31/98 offsite power availability V. ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS Prior to restart:

The Maine Yankee Voltage Study, Calculation MYC-430, will be revised to verify that these circuit modifications restore 115KV Section 69 to an operable line.

After restart:

MYC-430 will continue to be updated once per operating cycle to verify that both off-site power sources remain acceptable.

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Maine Yankee Restart Readiness Plan APPENDIX D STEAM GENERATO.R INSPECTIONS 4

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1. INTRODUCTION ,

I We will be performing an inspection of the primary and secondary side of the steam generators. i Primary inspections will be conducted on all three steam generators. Secondary inspections will be

performed on at least one (1) steam generator. The need for the inspection stems from a l combination of regulatory issues and plant / industry needs and objectives.

11. ROOT CAUSE

SUMMARY

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Although there is no defined root cause analysis associated with this effort, the implementation of these inspections are founded within regulatory and industry guidance.

The requirement for primary side inspections of the steam generator originates with the requirements  ;

of Technical Specification 4.10. These requirements have been augmented and modified by NRC  !

generic communications, commitments made in response to these communications, as a result of commitments made during the previous tube sleeving repair program, and as a result of inspection  :

activities at other plants. All primary side inspections and repair activities are aimed at preserving tube integrity.

The activities associated with the secondary side of the steam generater are less structured from a regulatory point of view and tend to result more from industry accepted practices but none the less have as their primary objective, that of preserving tube integrity. An additional reason to perform the inspections and work on the secondary side of the steam generators is to recover pressure losses due to tube fouling. From a regulatory viewpoint, the NRC will soon publish a Generic Letter mandating a program to inspect the steam generator intemals. Maine Yankee will formally inspect S/G #2 secondary side prior to startup.

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i 111. CORRECTION PLAN

SUMMARY

Immediate Actions l As a condition of restart, Maine Yankee is required to complete the primary side inspection program and any required expansions as a result of our inspection findings. The inspection program is identified in Table 1. Inspections will be expanded as required if defective tubes are i identified in the base inspection. l i

The only regulatory issue for the secondary side concems the conduct of internals inspection, which will be completed prior to restart.

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Long Term Actions With regard to long term actions, Maine Yankee is obligated to conduct a steam generator i primary side inspection no later than each refueling. Maine Yankee will have to evaluate the I incorporation of additionalinspections based on the results of the inspection.

IV. SCHEDULE .

, All primary and secondary activities are currently being scheduled.

We plan to begin inspection on 4/1/97. Complete by 6/15/97, See Table 1 for planned dates.

V. ASSESSMENTS OF IMPLEMENTATION EFFECTIVENESS Assessments of effectiveness will be conducted regularly through a Self Assessment process. This  !

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Personnel Safety - No lost time accidents; no OSHA Reportables i

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Radiation Exposure - Meet ALARA Committee approved budget Foreign Material- No program violations Technical / Quality- No more than 1 GPD primary to secondary leakage between planned inspections .

Schedule - Allinspections and repairs comphte by 6/15/97 l

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Cost - Base inspections completed for authorized amount ,

Regulatory / Customer- No open regulatory issues. Complete S/G condition assessment to  !

M.Y. Board of Directors  !

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Maine Yankee Restart Readiness Plan TABLE 1 INITIAL 1997 STEAM GENERATOR PRIMARY SIDE INSPECTION PLAN

• Inspections currently planned:

1. Preliminary Condition Assessment (plus point) 04/01/97

2. 100% Bobbin (~ 5500/SG) 05/01/97

3. 20% Plus Point Sample of Vulnerable Eggcrate Intersections 04/01/97 (Bobbin Indications, Smart Sample)- (~200/SG) l

4. Plus Point Free Span Indications and Eggcrate Ambiguous i Bobbin Signals (Bobbin Indications, Near Drilled Supp. *See #7) 04/01/97

5. Small Cold Leg Sample of Sludge Pile Bobbin Indications (~10 tubes) 05/01/97

6. - 20% Plus Point at TC Expansion Transitions (~ 1100/SG) 05/01/97

7. 100% Plus Point Steam Blanket Region (~ 500/SG) 05/01/97 l l

8. 20% of Dented Drilled Support Plate Intersections (~ 400/SG) 04/01/97 l l

9. 100% Plus Point or CECCO of 30" Sleeves (~ 550/SG) 04/01/97

10. 20% Plus Point or CECCO of 20" and 12" Sleeves (~ 1000/SG) 04/01/97 1

11. 20% Plus Point of Freespan Vulnerable Sample (highest 04/01/97 l analytically predicted deposit loading area) (~ 400/SG)

• Will be revised as necessary based on inspection results and the necessity for additional l diagnostics (i.e. tube pulls).

l MYAPC will present this inspection plan to the NRC at a meeting tentatively scheduled for 03/20/97.

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APPENDIX E FUEL FAILURES i I

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Maine Yankee Restart Readineus Plan

1. INTRODUCTION Maine Yankee Cycle 15 was initiated on January 16,1996, with no indication of fuel leakage. The Cycle 15 reload included 68 fresh fuel assemblies which were the first Westinghouse manufactured assemblies to be operated at Maine Yankee. On June 12,1996, reactor coolant system (RCS) iodine activity increased from the high 10 4micro-curies / milliliter range to the 10 ' micro-curies / milliliter range indicating fuelleakage. During the ensuing months the RCS iodine activity trends and response to changes in plant powerlevelindicated a gradual, but progressive trend in fuel leakage.

On December 6,1996, Maine Yankee was taken off line to deal with cable separation deficiencies which had been identified. Just prior to the shutdown, RCS iodine activity was in the low 10-2 micro-curies / milliliter range. On January 2,1997, Maine Yankee management decided to perform a concurrent inspection of the fuel. Although an inspection was not necessary based on RCS activity levels, the anticipated duration of the cable separation outage provided an opportunity for an early cause determination and disposition of the fuelleakage. In particular, Maine Yankee wanted to establish if the cause of the leakage was grid to rod fretting which had occurred in Westinghouse fuel of a similar design in another facility.

a The initial scope of the fuelinspection consisted of using a new in-mast sipping system to identify leaking fuel assemblies and using an ultrasonic (UT) device to identify leaking fuel rods. The results of the inspection identified 9 leaking assemblies containing 76 leaking rods. All of the leaking rods were within the batch of the 68 first cycle fuel assemblies manufactured by Westinghouse. Seventy five of the 76 leaking rods were in a subset of 24 assemblies located near the core periphery. Sixty six of these leaking rods were in a subset of 8 assemblies in " half-baffle" locations. Half-baffle locations are those locations where half of one edge of a fuel assembly is adjacent to the core shroud and the other half is adjacent to another fuel assembly.

. Following the sipping and UT inspections, a visual inspection was performed on individual leaking

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rods to determine the cause of the leakage. The visual inspection established grid to rod fretting as the cause of the leakage.

II. ROOT CAUSE

SUMMARY

a The primary cause for the fuelleakage was determined to be grid to rod fretting at the mid-assembly fuel spacer grids. The cause of this fretting was determined to be related to an inadequate design of Westinghouse C14 fuel with zircaloy mid grids that incorporate a diagonal spring feature. The C14 design is the Westinghouse version of the ABB Combustion Engineering 14X14 fuel design.

Ill. CORRECTION PLAN

SUMMARY

1mmediate Actions Taken Revision 0 Appendix E-2

l Maine Yankee Restart Readiness Plan A sampling program was initiated to characterize the extent of damage from grid to rod fretting in order to disposition the affected fuel The sampling program involved selecting non-leaking rods at random from assemblies representative of different core locations forinspection. The inspection consisted of screening rods for wear using eddy current testing (ECT) and performing ,

visual inspections to estimate wear depth at selected locations. Visual inspections were -

performed at the highest wear location on each rod and other locations that could exceed 50%

wear based on ECT, Assemblies were classified as having light, moderate, and heavy wear if l they contained sample rods with wear between 0 and 25%, greater than 25% to 50%, or greater l than 50% respectively.  ;

The sampling program involved 325 rods in 17 assemblies. Seven assemblies were sampled:

in the subset of 24 core periphery Westinghouse assemblies, and each was classified as having heavy wear. Ten assemblies were sampled in the subset of 44 interior Westinghouse assemblies which were found to have less extensive wear and classified predominately in the light to moderate range, The conclusions reached from this effort indicated that the wear problem was widesprr;ad and generally heaviest in the periphery assemblies and light to moderate in the interior assemblies, in addition, examination of the wear scars showed evidence that the diagonal grid springs were wearing completely through the fuel rod cladding in some fuel rods. i l

Actions To Be Taken Prior to Restart Based on the wear damage to both fuel clad and grid springs, it was decided to replace all 68 Westinghouse fuel assemblies with a fuel design known not to be susceptible to a grid to rod f utting. Additionally, Maine Yankee will redesign a new reload core configuration with greater than 68 replacement assemblies and complete the associated safety analysis and changes to core operating limits prior to restart.

Long Term Actions Institute a policy that any significant design changes to Maine Yankee fuel that have not been proven by operation elsewhere be proven at Maine Yankee through the use of lead qualification assemblies.

IV. SCHEDULE The following is the currently planned schedule for the failed fuel related activities (this schedule may change as circumstances related to the project change).-

Activity Scheduled Comoletion Date Document policy on lead qualification assemblies 03/31/97 Offload Cycle 15 fuel- 05/07/97

- Fabricate replacement fuel 06/16/97 Receive and inspect replacement fuel 06/24/97 Load Cycle 16 fuel 06/29/97 Revision 0 Appendix E-3

l Maine Yankee Restart Readiness Plan Complete core analysis 06/30/97 Complete core analysis documentation 07/09/97 Initial Criticality 07/15/97 V. ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS ,

l A complete assessment of the effectiveness of the replacement fuelin preventing further grid to rod fretting can not be made until substantial operation with the fuel has occurred. However, a reasonable expectation exists that the selection of a proven grid design will not result in grid to rod fretting at Maine Yankee.

Maine Yankee has not experienced leakage from grid to rod fretting in the past with fuel manufactured by either Combustion Engineering and EXXON. Several years ago Maine Yankee performed ECT inspections of Combustion Engineering manufactured fuel for grid to rod fretting. l This was done because of grid to rod fretting experienced at another facility with similar fuel. No I evidence of significant grid to rod fretting was found. Also, no evidence of significant grid to rod fretting was found in the outer row of rods in the Westinghouse fuel assemblies examined in the current campaign. These rods have some different grid features, which implies that propagation of l the problem to grids with other features does not occur. These observations support the conclusion j that Maine Yankee is not susceptible to grit to rod fretting from proven grid designs.

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APPENDIX F CORRECTIVE ACTION PROGRAM / LEARNING PROCESS  :

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Maine Yankee Restart Readiness Plan

l. INTRODUCTION / PROBLEM STATEMENT Starting in late 1994, multiple reports from our Nuclear Oversight Committee, Quality Programs Department, and a Management Review Board identified a trend of repeated problem events These reports also revealed that Maine Yankee's Corrective Action Processes failed to prevent the recurrence of these events. Subsequent evaluation identified the following Corrective Action Process deficiencies

• Problem repetition l'

. Multiple task tracking systems

. Inconsistent evaluation quality

. Inconsistent threshold for discrepancy reporting  ;

1 - System cluttered with low risk / low value items l

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. Untimely response to and closure of issues

. Limited access to process use and information

. Uncoordinated response to issues

. Duplicate issues and tasks

. Lack of integrated priority system

. Trends not easily recognized

. Corporate and department managers unable to determine total work load / resource impact i

ll. ROOT CAUSE

SUMMARY

As reported in the ISA report, Maine Yankee identified complacency and a lack of a questioning attitude as the causes for weaknesses in our problem identification and correction.

• As the ISA report observes, the close focus on cost and competitive standing fostered an attitude of complacency in the sense of tolerance for non-urgent conditions. These economic pressures limited the resources available to respond effectively to issues raised from corrective action activities. As a result, managers and evaluators were predisposed to limit the scope of evaluations and corrective actions to fit the available resources.

3 . Evaluation consistency and quality was inhibited due to multiple evaluation guidance and the absence of evaluator qualification standards.

. Management failed to recognize the scope and aggregate significance of the growing corrective action backlog due to the use of multiple uncoordinated tracking and prioritization systems.

Ill. CORRECTION PLAN

SUMMARY

Actions Taken in response to these Corrective Action Program deficiencies, the President of Mainc Yankee on August 8,1995 chartered a cross-functional team to re-engineer Maine Yankee's root cause analysis Revision 0 Appendix F-2

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Maine Yankee Restart Readiness Plan and corrective action program. The seven member Team, referred to as the Leaming Process Re-Engineering Team, consisted of individuals from our Manager's Council, Computer Services Section, I

! and Maintenance, Operations, Technical Support, Plant Engineering, and Quality Programs I

Departments. This was a substantial commitment of resources covering a 10 month span for 4 process redesign and development. The Team included a department manager, two section heads, l two supervisors, and two principle engineers in addition to training and support personnel.

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, The Team was chartered to consolidate the many existing Maine Yankee corrective action processes l into an integrated process for problem identification, prioritization, root cause evaluation, task l j tracking, and closure, in addition to consolidating processes, the Learning Process provides a '

a- readily available entry point for all issues through an on-line open-access computer system, common j screening and coding criteria, an expert screening panel, improved evaluator qualification, a single p responsible issue owner, a single consolidated task tracking system, and a common task and issue l

prioritization method. As a result, Maine Yankee personnel are able to focus resources on higher I

. priority items, conduct more consistent searching and trending, reduce task duplication, reduce the I number of corrective actions to a few more productive actions, and streamline the processing of L

issues with a minimum of paperwork. In addition, the Learning Process has lowered the threshold for reporting problems through simplified issue entry at multiple readily available locations which offer

[ unfettered access for all workers, including contractors. Furthermore, workers are allowed to enter 7

. issues anonymously if they desire.

The Leaming Process also includes provisions to avoid problem recurrence and addresses occasional ineffective corrective actions. These include qualification requirements for root cause evaluators, single issue owner responsibility for integrated problem solution, risk level and task priorities influenced by prior experience, post implementation effectiveness evaluations for high risk issues, inclusion of external operating experience in prior experience searches, and a searchable -

' leamable lessons database that can be used when preparing for work, procedure modifications, or training. These features help assure that the Leaming Process and root cause procedures align with the guidance provided in NRC Information Notice 96-28, Suggested Guidance Relating to Development and Implementation of Corrective Action.

The Re-Engineering Team completed the initial development phase on July 3,1996. Final design, programming, and Implementation was then tumed over to an implementation team headed by the manager / owner of the new Leaming Process. The Leaming Process began operating company wide l on January 6,1997. We believe the new process will enhance problem identification given its I availability to all workers and ease of use, as well as improve the overall quality of corrective actions. j Actions to be taken Prior to Restart

1. Complete Third Party Evaluation of Learning Process implementation design against the expectations of NRC Inspection Procedure (IP) 40500.

2. Complete the staffing of the Learning Process Team.

3. Develop and implement Leaming Process software and process changes to support startup issue tracking.

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4. Screen and transfer applicable legacy data from existing tracking systems into the Learning Bank.

5. Review current and legacy Leaming Bank issues for inclusion in current outage work scope using restart criteria.

Long Term Actions

1. Develop and imp!ement Learning Process monitoring plan to measure the continuing effectiveness of the Leaming Process. Plan to include monthly monitoring of process performance measures and trend data.

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2. Input the results from the four Leaming Process reviews and evaluate them for action within the Learning Bank.

3. Conduct another follow up Third Party Evaluation against the expectations of NRC inspection Procedure (IP) 40500 within one year of Learning Process startup focusing on implementation effectiveness.

4. Upgrade Learning Bank development software to currently available version.

5. Modify Leaming Bank software to collect human resource project managemer,t data in support of business planning and plant work scheduling.

IV. SCHEDULE Activity Planned Comoletion Date Learning Process Team Staffing Complete Third Party Leaming Process design Evaluation Complete Learning Process Restart Modifications 3-31-97 Leaming Process Monitoring Plan Implemented 4-30-97 Response to Leaming Process Reviews Planned 4-30-97 Legacy Data Transfer to Learning Bank 6-30-97 Current and Legacy issues Restart Review 6-30-97 Third Party implementation Review Complete 9-30-97 Upgrade Learning Bank Software 0-30-97 i incorporate Human Resource Project Data Collection 6-30-98 V. ASSESSMENT OF IMPLEME.4TATION EFFECTIVENESS Since J'anuary 6,1997, the Learning Process underwent the following reviews:

• A Third Party Evaluation against the expectations of NRC Inspection Procedure (IP) 40500 by William Corcoran.

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. Cable Separation Root Cause Evaluation conducted by Conger and Elsea to determine any Corrective Action Process changes to prevent recurrence.  ;

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• A Quality Program Surveillance of the Leaming Process Implementation. l l

• A modiried NRC Team Corrective Action Inspection based on Inspection Procedure (IP) 40500, l

in general, all four reviews found that the Learning Process has the capability of fulfilling the expectations of the NRC Inspection Procedure (IP) 40500 if it is consistently applied to all aspects of the program areas covered by the inspection procedure It has many effective attributes and has the inherent capability for continuous process improvement. However, all four found that their reviews were too early in the implementation period to make any definitive conclusion on the overall effectiveness of the process. - Specific comments from all four reviews will be assessed and viable improvement opportunities will be tracked and documented using the Leaming Process.

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Maine Yankee Restart Readiness Plan APPENDIX G SURVEILLANCE TESTING l

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l. ' INTRODUCTION As a result of the logic circuit testing issues identified in responding to Generic Letter 96-01 and the 1 experiences and insight gained from the USNRC Independent Safety Assessment inspection, Maine Yankee has determined and committed to an extensive review of surveillance testing completeness and effectiveness. There are several areas targeted for review and assessment. The areas are l logic testing (See Appendix A), Technical Specification Surveillance, IST Surveillance Testing, and I Post Maintenance Functional Testing.

Technical Soecification Testina The tasks associated with these reviews are defined as a complete, section by section, review and assessment of the Technical Specifications and associated surveillance tests to ensure:

' 1. A corresponding surveillance test was prepared for each of the Limiting Conditions for Operation l (section 3 of the Technical Specification),

L2i Each of the existing surveillance tests adequately addresses the Technical Specification requirements, and

3. The surveillance are being performed adequately.

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The completion of the reviews and assessments to date have resulted in initial listings of recommended additional surveillance test requirements and modifications to existing procedures.

These recommendations are in the process of receiving independent assessment, review, and confirmation.

Inservice Testina Due to several recently identified issues within the IST Program including the non-inclusion of safety related valves and improper testing methods, Maine Yankee has committed to developing an IST Program Component Basis Document. The scope of this project is to include a current program j review for compliance with the Third Interval IST Program and applicable Codes. It will also include  !

the _ review and development of component basis documentation for all safety class components. i This document will provide a basis for inclusion or exclusion of components in/from the IST Program as well as provide testing reference value basis and applicable Code, FSAR and TS references.

3 Post Maintenance Functional Testina Past events at Maine Yankee have indicated there were weaknesses in the post maintenance functional testing process. Extensive root cause and corrective action plans have been executed.

The sole remaining action item for Maine Yankee to complete is a self assessment of the effectiveness of the previous corrective actions.

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11. ROOT CAUSE

SUMMARY

Technical Soecification Testina The determination of the causal factors leading to the need to perform these reviews and assessments is ongoing. In order for this effort to result in meaningful information, the review, assessment and resolution must be completed prior to being capable of determining the root cause.

inservice Testina The major causal factors identified that have lead to the understanding of the need to develop a defined IST Program component basis include a lack of sufficient Code clarification (ie. NUREG-1482); insufficient Code, system configuration, and design basis training for the program developers; non-participation in industry events;. ineffective review process; and unclear management expectations in reference to appropriate program development.

Ill. CORRECTION PLAN

SUMMARY

Technical Soecification Testina immediate Actions Taken:

The sole immediate corrective action at this time is the continuation of the independent assessment, review, and confirmation of the initial tasks. To date the independent assessment has not identified immediate corrective actions. Additionally, this review has not found deficiencies that are reportable or affect operability of plant equipment. The independent review is continuing.

Actions to be Taken Prior to Start Up:

The actions, related to the surveillance testing completeness issues, required for completion prior to plant startup are identified as follows:

. The independent review and assessment must be completed,

. All comments or issues relating to the adequacy of surveillance testing in ensuring compliance with the Technical Specification Limiting Conditions of Operation must be resolved,

. Additional testing to demonstrate Technical Specification compliance, if required, will be complete Long Term Actions:

No long term actions have been identified at this time.

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Maine Yankee Restart Readiness Plan Inservice Testina Intermediate Actions Taken: )

i Maine Yankee has completed extent of condition reviews for all specific discrepancies identified '

I with scoping issues and surveillance procedure methods. The process of creating an IST Component Basis Document has been started by instituting a preliminary program review for compliance utilizing qualified contracted engineering support. This review will continue and form j the basis for the development of program component justification.

1 Actions to be Taken Prior to Start Up:

Completion of the preliminary program review as well as resolution of identified discrepancies.

A comprehensive understanding of the IST component basis will be achieved by the document writer, current IST Coordinator and appropriate supervision to ensure no outstanding scoping  ;

issues exist.

1 Long Term Actions:

Long terms action items include completion of the IST Component Basis Document, complete review and re-write of IST surveillance procedures, and full IST Program re-write in accordance with ASME/ ANSI OM-10. Maine Yankee also has plans to hire a new IST Coordinator with previous Code and industry experience. Appropriate training will be developed and given to all applicable plant departments.

IV. SCHEDULE The following schedule is provided based on current knowledge of the work scope.

Activity Planned Comoletion Date I

Technical Specification Testing 1 I

Initial reviews and assessments Complete independent review and assessment 04/15/97 Resolution of issues, revision to procedures (if required) 06/01/97 Completion of additional surveillance testing (if required) 07/01/97 Inservice Testing Complete initial program review 03/31/97 Comprehensive understanding of component basis Start-up and program scoping IST Basis Document Completion 12/31/97 OM-10 Program and procedure complete 06/01/98 Revision 0 Appendix G-4 l

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l Maine Yankee Restart Readiness Plan Full OM-10 program implementation Cycle 16 Refuel i

V. ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS l

Technical Soecification Testina The effectiveness of the above actions are assessed through the results and conclusions of the

.ccheduled independent reviews, implementation effectiveness of the surveillance testing procedure changes will be assessed through the use of Quality Programs Department surveillance and audits.

Inservice Testina The effectiveness of the above actions are assessed following the completion of all activities up to and including the re-write of the IST Program and formal roll out. A comprehensive and effective review process will be implemented following the completion of the basis documentation and will be conducted by outside industry experts as well as internal Maine Yankee personnel. This comprehensive review process will also be used prior to the roll oct of the new ASME/ ANSI OM-10 IST Program and procedures.

Post Maintenance Functional Testina Maine Yankee will perform a self assessment of the post maintenance functional testing process to determine the effectiveness of the corrective actions taken. l l

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APPENDIX H  !

ENVIRONMENTAL QUALIFICATION i

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1. INTRODUCTION Several Environmental Qualification (EQ) components, within the Reactor Containment, are below the maximum flood level and are not qualified for submergence. j

11. ROOT CAUSE

SUMMARY

Failure to maintain a continuous EQ Coordinator on site lead to failure in maintaining and upgrading the EQ program and promote Station sensitivity to EQ compliance. Other contributing causes are insufficient formal process to control EQ attributes during the design change review, and lack of training to promote tho EQ criteria, requirements, process and control.

More details are provided in PRCE #213,

, Ill. CORRECTION PLAN

SUMMARY

Actions to be taken prior to restart:

1. Establish and fill the Maine Yankee EQ program manager position.

2. Relocate components required for post accident monitoring.

3. For the remaining potentially affected equipment, evaluate and assess the equipment operability, demonstrating that the equipment safety function will be completed prior to being submerged.

4. Qualify, replace, or relocate equipment whose safety function is needed subsequent to submergence.

5. Complete Root Cause evaluation and Containment flood analysis.

6. Perform an EQ Program Assessment utilizing recognized industry experts.

7. Updated Turbine Building High Energy Line Break (HELB) analysis.

Long Term Actions:

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1. Verification of the Equipment Master List to assure accuracy.  ;

2. Develop a formalized control process for the review of design change documents so as to l include EQ awareness. l

3. Provide training to Engineering and Maintenance staff on the EQ program criteria, requirements, l process and control.

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IV. SCHEDULE Activity Planned Comoletion Date Short Term Actions:

1 Establish and fill EQ program manager position Completed

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l Maine Yankee Restart Readiness Plan Relocate components required for post accident monitoring 03/31/97 l Qualify, replace, or relocate equipment prior to restart. 07/01/97 Perform root cause evaluation Completed Perform EQ Program Assessment Completed Revise and disposition EQ Assessment QDR concems 06/01/97 Complete Turbine Building HELB Analysis 07/01/97 Long Term Actions:

Revision to the Design Change Process and other documents 12/31/97 Established training program and complete training 12/31/97 EQ Masterlist Verification 05/01/98 Evaluate and incorporate, as applicable, EQ Program enhancements 09/01/98 identified by EQ Assessment V. ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS 1 Periodic Program Assessments will be used to monitor / assess the effectiveness of the program changes. One of the responsibilities / expectations of the new EQ Program Manageris to perform l a Periodic Program Assessment and Walkdown. j 1

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