ML20138J033
| ML20138J033 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/17/1997 |
| From: | Shadis R AFFILIATION NOT ASSIGNED |
| To: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20138J032 | List: |
| References | |
| NUDOCS 9705070371 | |
| Download: ML20138J033 (4) | |
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FEg-19,-97 WED 10:55 AM SHADIS 6 ROSEf 4DO CS FRIENDS of the COAST OPPOSIN(i .NI:CLL1R l'OLL I: TION LYJSil)FFl(F 1;0X 9A. E(GCUl111. ,1LAINE II1M4 ltli . 5y2. Mtut) 1-?1X 107 343 6M)2 February 17,1997 I
US Nuclear Regulatory Commission ChairmanShirley A. Jackson Mail Stop O-16 GIS '
OneWhite FlintNorth
< 11555 Rockville Pike Rockville,MD 20852-2738
Dear Chairman Jackson,
We thank the Commission for permitting Friends of the Coast to participate 4,1997 Commission Meeting on the Maine Yankee Atomic h Power h Compan to the 1996 Independent Safety Assessment. We are regret to inform the Comm whole, we did not find it to lie a positive or efficiently productive experience.
Although, as participants, we were not extended the courtesy of noticej internet posting that the. Commission will be m )
and hope that you will include them in your deliberations:
L The Commission appeared to stray from nuclear safety irelated purpose substantive, political speeches from Peter Wiley of Govemor King'si office and addition, Dana Connors of the Maine Chamber of Commerce. No f where in t recotds of correspondence, or in transcripts ofISAT related meetings is the meaningful contribution or critique by Govemor King or Govemor Kin k
team. Mr. Connors gave not one shred of ld evide phrases circulated by the MYAPC public affairs department. Noth be interpreted to be directed toward the enhancement of public safety or At the same time, the Commission refused participation d ld to Mr.
and widely experienced nuclear engineer who had thoroughly reviewed l provide substantive comment from an indu Mr. Bianch was dropped from the list of potential participants becau ,
for time constraints and the possibility that Mr. Blanch i htmight cover l
l redundant of comments from other participants. Frorn a safety perspe Commission's substitution was an absolute waste of time and tax money.
i 9705070371 970430 hDR ADOCK 05000309 PDR
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ROSENDO CS 207.563 6302 P.03 S ' ph -.19 - 9 7 WED 10:36 AM SHADIS C.
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-FRIENDS of the COAST / USNRC L.In theNRC / OPA transcript of the February 4 meeting, a list of" STAFF AND PRE SEATED AT THE COMMISSION TABLE" includes members of the public, who were Chairman Jackson's opening comments, " approved...to express their views." The fact is four public presenters were never accorded a place at the table. They were relega ;
podium placed well off to one side. The Commissioners shared the intimacy ol with the licensee, MYAPC and their proposed surrogate operators, Entergy Incorporated ,
turn, with senior NRC staff and State of Maine ISAT members Wiley and Vanags, but N
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l citizen presenters. i The leisurely, conversational presentation by MYAPC/Entergy ran 43 minutes beyon allotted 60 minutes. NRC staff took 62 minutes, twice their allotted agenda time. By contrast, citizen presenters were held to their allotted time. From the beginning of the mee Commission's choice of the manner in which time and space were dispensed sent Frien :
Coast members, and the Maine public-at large, a rude, clear, and unmistakable signall l
! they and their presenter had to offer would be held in little esteem. '
I L We were witness to a very disturbing set-piece between the Commissioners and th l i
and NRC staff regarding the significance of a November 1996 MYAPS off-site powe made in the meeting of the maximum permissible time redundancy on the two in-comin l l
L lines may be compromised and attendant technical specification changes.
l i Chairman Jackson inquires of NRR Director Frank Miraglia, " ..These issues l site power specifically were issues out of the ISAT and now my understanding is restart issues today. Does that put us in the position of being criticized for not havi Jown with respect to those issues or, put another way, how did we arrive at the sa of these issues relative to their now becoming restart issues?"
l Mrc Miraglia: "' Die issues at the time the decisions were made at the ISA questions regarding that issue. There was not a definitive finding. Th discrepancies within the FSAR...this deserves further review...so i i that wa I
the staff for follow-up and further review and was not seen as an operability issue time."
And later. Mr. Jordan: "No,I think the process that we went through in iden issue, leaving it as a loose end, we were unable to come to closure o unacceptable so we left it as a loose end."
id in lengthy exchanges with staff and licensee
.We found it very strange that what was not sa l was that the off-site power issue was inextricable from questions surround j
defense, the emergency diesel generators ( EDGs. The loading t the on E l
l the ISAT to be non-conservatively calculated. On p
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2/17/97 (Q
. ERIENDS of the COAST / USNRC '
i the loading on EDG 1B ( worst case) increased from 2,629 kW to 2,842 kW (a 21 still below the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> / year rating of 2,850 kW." i l
' We understand this to mean that the capacity-load margin on this EDO to be 8k '
rating, a margin easily lost in small thermal loads or inefficiencies.
It was reported that one of two incoming lines, the Surowiec line, would not su demand of a main motor driven feedwaterpump automatic star. The overload wou start and loading of the EGDs. MYAPS solution was to devise a scheme for an o six hour, main transformer backfeed adaptation. One finds on page 23 of the rep i
team considered the situation, to be of," low safety significance" considering am the historical stability of the grid." We were dismayed to see this glossed over in the 4 As we attempted to point out in our oral presentation to the Commission, many brought forward in the ISA, or collateral to it, aren't new issues. As early as 19 i Hanauer of the AEC cited potential defects at MYAPS including shared circuits and control and plant safety systems. We have put before the commission NRC Inspe I Atherton's 1978 inspection report specifically citing cable separation problems at MY Although the ISAT reviewed and examined cables and found routing, sizing, and ;
I good (p.24), the licensee is presently engaged in extensive rerouting to est A 1983 study on environmental qualificatien of MYAPS components, contra from the Franklin Institute was referred to in our presentation. It raises issue' l
Among them are submergence of electrical components and cables in a vulnerability of switchgear room components to a high energy line break. And there Although much of the above was contained in previous citizen i submitta ;
with staff in the meeting, nor have any individual commissioners expressed the lea !
details. If we do not learn from history, it is said, we will repeat it.
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5, What is in a name? What peculiar conditions at issue, then why was the exercise not an Independent Diagnostic Evalua public, who are concemed and informed about NRC, safety at MYAPS a recently this evaluation was motivated in large part by concerns for the credibility of the ,
damaged at Millstone. The origin of Maine's involvement is clear in L concem that Maine people be," reassured about the safety of MYAPS.
safety bias of the ISAT's conclusions, and the Conunission's defensi and inquiry, sugges that political considerations have once again com 1 L
j process. In our vicw, the assessment was cle l l
l be the unstated mission of the ISAT predetermined the announced co
" safe "
l d l ti, It is our perception that the ISAT, and the NRC'siif handlingti of post-IS and l to bulldoze past unaddressed citizen safety concerns. Certainly, forums o l
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(41 2/17/97 FR'IENDS of the CO AST/ USNRC discourse, such as the news media and the legislature, have been lulled by the Commis d " for safe operation. Any hopes that we '
. uncritical acceptance of the IS AT findings of," a equate, once may have entertained that this Conunission would diligently enforce its own been thoroughly chilled by the NRC's behavior, both staff and Commission, in the ISAT p When representatives of Region I and NRR were less than forthcoming and defe i f
' MYAPS operations in public meetings in our area and before the Maine legislature, m i members took it to mean that the message of a new order had not yet been passed downi safety-minded, and impartial commission. Now, it is sad to report, we are confront !
that suggests the new policy is business as usual .
We are compelled to ask, if excellence is as excellence does,just when does it begin 1
Sincerely,
%8kaL' Raymond Shadis Information Coordinator I
l cc:
Commissioners Dicus, Rogers, Diaz, McGaffigan Govemor Angus King Office of the Inspector General,NRC Legislative List Media List l
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a MaineYankee RELIABLE ELECT AICITY SINCE 1972 329 BATH ROAD + BRUNSWICK. MAINE 04011 + (207) 7984100 March 7,1997 MN-97-43 MBS-97-07 UNITED STATES NUCLEAR REGULATORY COMMISSION
' Attention: Document ControlDesk )
Washington,DC 20555
Reference:
(a) License No. DPR-36 (Docket No. 50-309)
Subject:
Maine Yankee Restart Readiness Plan I Gentlemen: .
i I
Consistent with the intent of NRC Inspection Manual Chapter 0350, Staff Guidelines For Restart '
i Approval, we are enclosing a Restart Readiness Plan (RRP) for the startup of Maine plan contains the ' activities we feel ec==y to complete in order to restart Maine Ya contains provisions for short-term and long-term actions following restart which will ad]
l resolve other outstandmg issues r.ssociated with the plant.
Although we are intent on restoring Maine Yankee to an operating condition, the RRP a substantial amount of work which must be satisfactorily completed in the next several mont l
Progress in completing this w'ork, which consists of both hardware changes and pro evaluations, will form the basis for submittal of a separate Restart Plan Closure Repon approximately 30-60 days prior to our estimated restart date. Based on fuel receip defined activities in the RRP we believe restart on or around July 15 is achievable. However, l l
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ongoing RRP evaluations may identify additional work activities which could affect Therefore, we will defer a firm estimate of the restart schedule until submittal of the Restart ;
Closure Report.
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We would like to take this opportunity to affirm our understanding of Region I's application of t Marmal ChapterG350 process and scheduling. Upon submittal of the RRP, we underst NRC will schedule a public meetmg to discuss the plan and will then issue the Restart Ac Similarly, shortly aner submittal by Maine Yankee of the Restart Plan Closure Repor j again schedule a public meeting to discuss the report and, subsequent to the mee
' necessary steps to verify Restart Action Plan completion.
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MN-97-43 UNITED STATES NUCLEAR REGULATORY COMMISSION Page Two Attention: Document Control Desk Maine Yankee stands ready to facilitate whatever review and inspection is needed for restart. In between the two scheduled meetings discussed above, we would be happy to provide progress updates on implementation of the RRP in meedngs either at Region I facilities or the plan regard, we also expect to submit one or more progress reports addressing some ofthe m l
contained in the RRP appendices. l j
We believe the Restart Readmess Plan is a quality approach to restart and look forward to your review.
Sincerely, i l.,0 C-MichaelB. Sellman President JRH/mwf i Enclosure c: Mr. Hubert Miller :
Mr. J. T. Yerokun !
Mr. Daniel H. Dorman Mr. Richard Conte
. Mr. John Zwolinski Mr. Patrick J. Dostie Mr.Uldis Vanags h
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i MAINE YANKEE ATOMIC POWER COMPANY l '
l I RESTART READINESS PLAN l
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1 Approved by:
President, MYAPC Date l
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Maine Yankee Restart Readiness Plan INDEX
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- l. P u rpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 i
- 11. Ba ckground . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 111. Organization and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l IV Restart Readiness Process Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 l i
V. Extent of Condition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 !
VI. Outage Work Scope identification and Screening . . . . . . . . . . . . . . . . . . . . . . . .'. 11 Vll. Work Completion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 i
Vlli. Restart Readiness Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 IX. Startup and Power Ascension . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 X. Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 l
Attachments
- 1. Definitions
- 2. NRC 0350 Cross Reference
- 3. Restart Work Criteria ,
4, Work Orhr Review Corrective Action Progrem Review J
- 5. l
- 6. Plant System Readiness Assessment
- 7. Plant Program Readiness Assessment
- 8. Department Readiness Assessments
- 9. Licensing / Regulatory Closure AffirmEtion
- 10. Quality Programs Closure Affirmation
- 11. Management Effectiveness Assessment
- 12. Integrated Site Readiness Assessment
- 13. Preliminary Listing of Short-term Focus Areas Appendix - Action Plans for Significant Rastart issues A. Logic Circuit Testing 1 B. Cable Separaten I C. 115KV Offsite Power D. Steam Generator inspection E. Fuel Failures F. Corrective Action Program / Leaming Process
- Surveillance Testing G.
H. EQ lssues i
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Maine Yankee Restart Readiness Plan
- 1. Purpose I
l 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 6,199# forced outage. The Restart Readiness Plan (RRP) provides for the initial implementation of the Maine Yankee Business Plan and is responsive to restart issues contained in the following key inputs: :
- NRC Confirmatory Action Letter (CAL), dated December 18,1996 and Supplement No.1, ;
dated January 30,1997, J
- NRC Independent Safety Assessment (ISA) as documented in NRC letter, dated October 7, it96 and the Maine Yankee Response to ISA dated December'10,1997, l
- other NRC Inspection Reports including integrated Inspection Report 96-13, dated January 15,1997 and 96-16, dated February 11,1997, a MYAPC response pursuant to USNRC 10CFR50.54(f) request " Adequacy and Availability of Design Bases Information,"
= self identified improvement actions, l
= equipment and System Assessments (focused on plant hardware performance issues), and
. program and organizational assessments (focused on non-hardware performance issues).
i 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 '
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' achieve this objective, RRP actions will focus on achieving performance improvement in MYAPC personnel, key work processes and plant equipment and systems. Although the RRP for MY is l
based on restart programs previously approved by the NRC for use at other nuclear plants as well '
as the applicable sections of the NRC 16epeck,6 Manual Chapter 0350 " Staff Guidelines For Restart Approval,"(see Attachment 2 for a comparison mz trix), it addresses the specific issues applicab to MY.
To assure that performance issues are identified, prioritized and addressed in a timely manner, a three phase planning framework is being used to guide performance improvement at MY, This 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 Phase 1 willidentify and resolve all issues that must be completed prior to MY restart to assure a safe, controlled startup and sustained periods of safe and reliable operation. This RRP summarizes the approach and key actiot .s that will be taken to complete Phase 1 and retum MY to power operation.
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J J Maine Yankee Restart Readiness Plan l
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- 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 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 in 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 cverall performance of MY to simultaneously meet long-term objectives for safety, production and economics. This phase is anticipated to include activities ir"plemented 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 will 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 tn.s RRP will be used i to assign new issues to Phases 1,2 or 3. In addition to the many detailed Phase 1 actions that i 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 stattup using specified criteria (discussed in Section VI and included in Attacnment 3). The criteria based approach and broad participation by tt e line organization in evaluaung potential restart i issues is a key. aspect of the RRP and is designed to raise standards across the entire organization.
i 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 j
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 i the complete RRP.
Businnas Plan (Phase 3)
Restart Plan Short Term (Phase 1) % (Phase 2)
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e o Maine Yankee Restart Readiness Plan
- 11. 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
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the restrictions imposed by the order. !
i MY retumed to power operation after a one year shutdown to repair steam l
! January 16, W6 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 an assessment of plcnt conformance to design and licensing basis; provide an assessment of l t
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 . l l 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 plant as a result of operating concems identified by plant engineers reviewing control logic testing concems identified in Genene Letter 96-01 and cable separation issues identified coincident to the 96-01 review.
I December 10,1996 MY responded to the issues ia,tified 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 suberitical l t.ntil 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 concems 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. ;
i February 11,1997 NRC issued Inspection Report 96-16 which tabulated 16 apparent violations derived from the ISA report of October 7,1996 and licensee identified issue in August 1996.
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February 28,1997 MY responded to the apparent violations cited in Inspection Report 9616 l
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Maine Yankee Restart Raadinsss Plzn I
111. Organization and Responsibilities 1 j
Figure 1 Restart Readiness Organization l President MYAPC Nuclear Safety Mgr. Quality Audit Review Programs i Committee (NSARC)
VP Operations Restart Steering Oversight Committee Oversight
.Mgr Nuc Safety
- .VP Licensing VP Engineering Restart Manager YNSD Sr Mgr Plant Manager
.Mgr Quality Prog
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I I l I I l l
Department Hardware Programs g Restart Manager Restart Manager Managers I I I i
Outage Planning {
Hardware Non. Hardware Mgr operations inteorati n Team -
Subcommittee Subcommittee Mgr Maintenance "' 'P
.HW Restart Mgr . Prog. Restart Mgr Mgr Tech Support E eet tsint ep
. Engineering Rep .Engineenng Rep Mgr Outage ,y, n y,,n, p,,
. Operations Rep -Operations Rep Mgr Proj.& Constr
. Maintenance Rep
. Maintenance Rep Mgr Plant Engr ". rot Rep
. Quality Prog Rep s ng Rep Mgr Corp Engr
- Lic g9, p,,g g,, .Purenasing Rep Page 4 P
- VtESTART wpd Revision 0
Maine Yankee Restart Readiness Plan The RRP organization shown in Figure 1 l. s the following responsibilities:
- 1. President MYAPC - Overall responsibility for restart and operation of the MY plant. He has i 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 RRP and is Chairman of the Restart Steering Committee.
l 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 I
hardware and non-hardware sub-committees.
- 4. Restart Manager - Is responsible for the coordination and control of the restart program l including the RRP (does not include the routine physical outage work). Reports to the Vice 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 l manager responsible for approval and implementation of the process to restart the plant and l proceed through power ascension. Reports to the Vice President Operations.
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- 6. Hardware Restart Manager-is responsible for management and resolution of all hardware issues Chairman of the Hardware Restart Subcommittee. Reports to the Restait 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 ar.d oversight of subcommittee work.
- 8. Programs Restart Manager - is responsible for management and resolution of all non-hardware issues. Chairman of the Non-Hardware Restart Subcommittee. Reports to the Restar: Manager.
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- 9. Non-Hardware Subcommittee - coordinate the site evaluation and screening of non-hardware issues against the criteria and review and approve the non-hardware corrective schons. QPD representative is for independent review and oversight of subcommittee work.
- 10. Manager Quality Programs - provides independent review and oversight of RRP ,
implementation and the effectiveness of corrective actions. Reports to the President i MYAPC. j
- 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. !
Reports to the President MYAPC.
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! 12. Responsible Manager - manager accountable for ensuring that the assigned items have been properly evaluated, corrective actions implemented, documentation completed and l-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) es I 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 l
! sustained periods of safe and reliable operation.
The RRP implements the first phase of the three phase Maine Yankee Business Plan and will result l
in the safe, controlled restart of the plant. Figure 2 pmvides an overview of the relationship between the three phase business plan and the major RRP actrvibes. The restart readiness process consists of the following five major elements:
- 1. Complebon of an extent of condsbon review to ensure that identified performance deficiencies do not extend into other programs or processes in a manner that may impact the startup or l
safe operation.
- 2. Idenbficabon and screening of the scope of activities required to be completed prior to unit restart to assure resolubon of safety significant issues and assure a safe, controlled startup.
Where 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. ,
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- 3. Completion of required work using appropnate procedural controls and following appropriate documentation requirements for work package closeout See Section Vil for additional discussion on work completion.
- 4. Implementabon of a comprehensive restart readiness assessment that provides confidence that all required work has been effectively idsntified 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 d;scussion 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 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 l
l successful completion of restart issues.
. Communicate implementation status to the organization.
l Establish an integrated schedule to compide the actions necessary for restart.
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Maina Yankee Raet:rt Readiness Plan Figure 2 Maine Yankee Business Plan I
l Maine Yankee Business Plan
! + ir U"'"*
U"' # Phase 1 Phase 2
! Phase 3 Restart Readiness Plan ~ ~~ Y
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Long Term Plan Short Term Plan I
- ir ilr Ill Manaaement Systems V Ertant of Condition X Overnicht
) Restart Manager CAL Line Management Restart Committee - g -) ISA & Inspections ( r-- PORC QA/QC
-Steering I 50.54(f)
-Hardware 1 Other Self Identified Prob i NSARC
-Non-Hardware l I Outage Organization 1 y I I
lasus Managers 1 i I
I VI Outage Work Scope I I I
identification & Screen I) g- Major Action Plans (
- System Reviews l l Program Reviews !
I I l ir l I Vil Work Comnf atlerj ,,_ I I
I) Hardware ice . s I Non Hardware items 4i I (People /PlantsProcess) !
l 4 -
l i Vlli Readiness Assessm. l 1 Systems i i Programs i I Departments b I
I Quality / Licensing Integrated Site l l
l l I I ir I i i IX Restart & Power i i Ascension Plan !
l Plant Hestup I '
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Reactor Startup 4"
! 30% Power l 90% Power r
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Maine Yankee Restart Readiness Plan 1
Figure 3 1 Maine Yankee Restart Readiness )
f 3 F 3 ( 3 f 3 ;
! Independent Adequacy )
Confirmatory Safety & Availability Self Identified Action Letter Assessment of Design I**"**
Inspections 50.54(f)
L L J L J J h i f Restart Committee
- Restart Steering Committee
- Restart Hardware Committe* Prog./ People Equipment Assessments A - Restart Non Hardware Committee M Assessments Restart Criteria 1 - Safety / Operability 2 - Regulatory Requirement II
< r ,. r ,
Restart Plan - Phase 1 Short Term - Major Action Plans (Appendix) long Term Phase 2 - Hardware Restart List Phase 3
- Non-Hardware Restart List k ) ) L J v
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'- Schedule & Perform Work l
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( Jk N Jk N i
Y Restart t*
Committee Approval Y
2 Restart Readiness Review & A'pproval Startup & Power
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Maine Yankee Restart Readiness Plan V. Extent of Condition in response to the NRC Confirmatory Action Letter (CAL) dated of condition and the root cause(s) for these issues. Figure 4 summarizes the process that will b used to assess the extent of condition. In addition to known issues as identified in the CAL, IS report, MYAPC 50.54(f) response on design basis information and through internal pro identification methods, the RRP outlines a comprehensive process to determine if there other significant issues requiring resolution prior to restart. Later sections of the RRP and Atta I
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 resultr of the reviews will be assessed from an extent of condition perspective by deter the following:
Are there commonalities across root cause evaluations that may lead to more fundamenta root causes?
- Are narrow problems really generic?
Have we identified all safety significant issues important to restart and long-term operation?
Can our corrective a. tion process (Leaming Process) effectively monitor and, when necessary, heal our safety culture? ,
Are our design and licensing basis compliance controls sufficient to avert future safety an regulatory problems?
The assessment of these questions using the results of the plant system and program review the evaluation and screening and plant backlogs will be performed under the leadership of the hardware Subcommittee. A cross discip(ined team will be assembled Based ontotheperform this evalua present results and recommendations to the Non-hardware Subcomm to plant startup or during Phases 2 and/or 3 of the MY Business Plan implementation.
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Figure 4 Extent of Condition Assessment CAL Identified Prob IS A & Insnect. Prob 50.54f fl Resnonse Self Identified Prob
-Cable Separation -Appairent Violations Design Basis Prob -Fuel lasues
! -Logic Testing -URis FSAR Prob -S/G Inspection
-Cont. Flood Level -Other Problems -Tech Spec Prob -Entergy Evolutation
. Isolation Device -lST Basis Prob -Culture Asses'sment Cont. Free Volume 50.59 Process Prob -lNPO Evaluations 115Kv Power Eupply -Other Prob -Other Evaluations l
I I I I If Root Cause
'* 8 " * '
Equipment & Swstem s s E **
7 Evaluations '
Assessn.ents g,,,,,m nts l
l
. If l
Causal Factors ABCDEFGHIJKLMNOPORSTUV x x x x x 1
l2 33 xx x x
x x
x x
j4 x x x x x x x x 55 xx x 76 *
- x I
I; 73 X X X 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. Ider. tined All important Safety lesues?
- 4. Does CAP Monitor & improve Culture?
- 5. Design & Lic Basis Controls Adequate?
l l 3 f . If I I l
Short Term Restart Plan Long Term l
l (Phase 2) (Phase 1) (Phase 3)
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Maine Yankee Restart rteadiness Plan VI. Outage Work Scope identification and Screening The outage work scope is being validated through a rigorous review of open work against defined criteria. The review of open work, including both hardware items and non-hardware issues, is intended to ensure resolution of the specific issue and, where appropriate, the underlying root cause(s). The achievement of this objective requires that, in addition to the review and evaluation of known work items, additsonal assessments must be performed to determine the extent of condition of these performance issues. New work items identified from these assessments will also be j
reviewed against the restart criteria to determine if they require resolution prior to restart.
Some work leoms wlN be intentionally evaluated from different perspectives to ensure that poteritici l safety significant issues are identified and resolved. For example, open work orders not already l included in the scope of the outage are initially reviewed against the restart criteria as part of the
! mantenance work order backlog review (see Attachment 4). These open work orders will also be reviewed on a svstem basis as part of the system review to ensure that any work items deferred l beyond this outage will not impact safety system performance or reliability (see Attachment 6).
- 1. Identification of Potential Restart Work items ,
Potential restart work items are identifiec through review of key intamal and extemal inputs, planrung associated with majorissues and through additional assessment and evaluation to determine the extent of condition.
l A. Key inputs to Work Scope identification i
The seven major areas described below are evaluated to identify restart required actions. This input includes extemal assessment from NRC inspections as well as i
extensive intomal assessment. This scope of review will ensure that both the l specific issue and the underlying . cot 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 Let'er (C/.L) and Supplement
' . Testing of safety-rosated logic circuits
. Cable separation problem resolution
. Root cause of logic testing and eeble separation issues
. Il5KV offsite power supplyissues
. Extent of condition of design and configuration control issues
. . Margin improvement
. Backlog reduchon
. Licensing and design basis issues
. Operatorwesk around issues
. Maintenance and testing improvement
. Engineering improvement
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. Operations improvement i . Self assessment and Corrective Action Program implementation
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5 Maine Yankee Restart Readiness Plan
-Management and organizationalimprovements ;
- 3. NRC Inspection Reports & Violations including:
NRC Integrated Inspection Report 50-309/96-13, January 15,1997
. NRC Integrated Inspection Report 50-309/96-16, February 11,19g7 ;
MYAPC Response pursuant to NRC 10CFR50.54(f) request " Adequacy and l 4.
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- Availability of Design Basis information" including:
. Develop Design Basis Summary Documents (DBSD)
. Review of Technical Specifications and FSAR
. IST design basis'dr.itTerd
. Assessment of design basis
. 50.59 program improvements l
. Design process improvements
- l . Other miscellaneous actions
- 5. Self identified improvements including:
. Maine Yankee Business Plan
. Fuel reliability
! . Steam Generatorinspechon
- Cultural assessment (s)
- Entergy due diligence assessment
. INPO evaluations
. Staffing study
)
- 6. Plant Equipment and System Assessments (focused on plant hardware performance issues) including:
- System walkdowns
. Verification of Desin Basis Summary Documents
. Action plans for systems classified as A.1 per the Maintenance Rule
. Work order backlog review
. Temporary Modifications review l
. 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 i implementing a program to control the design basis i
l I B. Significant Restart issues i
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 l potential for generic implications. The action plans for these issues are contained 1 Page 12 PNtEsTART.wpd Revision 0 l . _ ._ _ _, __ -
. i Maine Yankee Restart Readiness Plan in the Appendix to this RRP. . ,dditional appendixes will be added if new issues are ,
j identified as part of the restart readiness process and these issues are large in l
magnitude or contain potential generic implications. The current set of issues being managed in this way include:
- 1. Logic Circuit Testing
- 2. Cable Separation ' '
- 3. 115KV Offsite Power
- 4. Steam Generatorinspections
- 5. Fuel Repair / Replacement ,
- 6. Corrective Action Program (Lesming Process) ;
- 7. Surveillance Testing l
- 8. EQ lssues '
C. Bacidog Reviews and Additionsi Assessment l
Work order, ccmrctive action program (Leaming Bank) and other significant backlogs i
will be identified and evalunted using the screening criteria discussed below to determine if there are work items required to be completed prior to unit restart. In l
addition, safety significant plant systems and critical plant programs will be assessed l
for extent of condition issues and to identify work required to be completed on these l
systems and programs prior to unit restart. Each key organization will also conduct an initial assessment to define activities that must be completed prior to restart to correct performance deficiencies within their respective organizations. ,
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 Reariness Assessment Attachmar3 8 Department Readinet.s Assessments
- 2. Screening of Potential Restart Work Items Each potential res' tart work item will be evaluated to determine if it requires resolution prior L to plant restart (Phase 1) or should be carried forward into the short-term or long-planr.!ng l
phases (Phases 2 and 3). The issue screening evaluation process provides a structured i
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 ensares priority on all issues with a potential impact on plant operational safety. The screening of issues against this I 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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Restart Work Criteria ;
Restart work is based on two fundamental and related concepts: safety and compliance with regulatory requirements.
Condibons, issues and deficiencies which,if uncorrected, coud reasonably result in the plant being in an unsafe, inoperable or non-complisct condibon must be corrected prior to restart. Conditions, issues and deAciencies for which suGolent compensatory measures are implemented such that the plant is in a safe, operable and complient conditon may be corrected post-restart on a schedule commensurate with their i safety significance. 1 Criterion 1 Safety Screening Can the condWon, issue or deAciency . - - =-My result in the plant being in an unsafe condition, or a safety l
! significant system or component being inoperable? For example:
1.1 Has the condition resulted in repetWve safety system or equipment failures?
i 1.2 Would the condibon result in a plant transient, power reduccon or plant shutdown?
l 1.3 Does the condeon represent a deficiency in design basis, analysis or documentation that l renders a system or component inoperable?
1.4 Does the condibon result in non-technical specificaton equipment that is important to safety (per Operations Procedure 1-264) being inoperable?
l l 1.5 Does the condition create the high pctential for personnelinjury or overexposure?
Criterion 2 Reaulatory Reausrements Screeninc :
l l Can the condition, issue or deficiency reasonably resultin the plant being in a non-compliance condition with regulatory requirements (10CFR50, etc.), the MY operating license or technical specifications? For j example: i l 2.1 is the condition in non-compliance with the requirements of regulations (e.g., EQ, 1 Appendix R, etc.)?
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! 2.2 is the condition in non-compliance with the operating license?
l 2.3 Does the condition result in failure to satisfy a technical specification surveillance ;
l I requirement or place the plant in a condition outside of the technical specificatons?
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- 2.4 Does the condibon result in an emuent release to the environment in excess of regulatory l limits?
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- 3. Oversight of Work identification and Screening ,
Oversight of the work identification and screening process will performed by the Restart Steering Committee and the Hardware and Non-hardware subcommittees. This oversight j l
- 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.
l A. Restart Steering Committee l The Restart Steenng Committee will evaluate the scope of corrective actions for the j major issues contained in the Appendix, screen the actions for prionty assignment (Phase 1,2 or 3) and, when work is wr+LU, evaluate the effechveness of actions ;
in resolving the issue. Phase 1 werk will be completed prior to unit restart. The j l
Restart Steering Committee will perform a similar initial and final review of the I following specific items: i
. Confirmatory Action letter response
. Effectiveness of management and organizational changes .
. Cultural Assessment l
- Entergy Due Diligence Assessment
- Staffing Study B. Hardware Restart Subcommittee f The Hardware Restart Subcommittee will evaluate, screen and close out the
! equipment and system issues, including emergent issues. Specific areas for review include:
. Work order backlog
( . System walkdowns and readiness reviews l
. Actions for systems classified A.1 per the Maintenance Rule.
. Operator work arounds
. Housekeeping issues C. Non-hardware Subcommittee The Non-hardware Subcommittee will evaluate, screen and close out the program i 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 i . Program assessments
. Department self assessments
. 50.54(f) Response
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Maine Yankee Restart Readiness Plan Vll. Work Completion 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 closecut. 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 listi7g of non-hardware issues requiring completion in this outage will be maintained.
This listing includes a subset of the Leaming Process data base and other databases that track non-hardware work items. This listing will be controlled by the Nordhardware Subcommittee.
Emergent i: sues will be evaluated to determine whether they should be added to the restart lists. Deletions to the restart lists will be reviewad and approved by the applicable restart sutemmittee.
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 nonnally be required (e.g., technical specificstion testing, previous commitments to the NRC not specifically related to restart) and other normal outage or refueling activities. Also, the rest "t 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. Issuc Implementation A. Hardware Actions Completion of the hardware actions is the responsibility of the Hardware 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 ccniains 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.
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 Cornmittee periodically.
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l B. Non-Hardware Actions l Completion of the non-hardware actions is the responsibility of the Programs Restart i
Manager. The normal plant processes should be utilized (e.g., the Leaming Process). ,
Scheduled action items should be reviewed and summarize to the Restart Steering Committee periodically. ,
I i
- 3. Issue Clnse Out :
i Restars required issues will be closed out in a consistent manner using the following
- apyoach.
f A. Major Restart issues (RRP Appendix Action Plans) i l
The following close out document 'ormat applies to major restart issues (RRP 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 documentatior, for issue cioseout and have this information in a form that can be l audited by intamal and extemal reviewers.
Sunkmary ,
. Overview of the issue and issue closure Closeout actions
. Summary of actions taken l
= Reference to documentation of completed actions (include as an attachment if not readily available in plant information systems)
Results l
. Performance improvements achieved l . Measures / indicators / tests used to judge effectiveness l Follow-up actions
. Post restart actions (short-te m/long term) required to ensure effectiveness l
!- of corrective actions and to prevent recurrence i . Actions to ensure continued improvement Attachments
! . Supporting documentation l
l Each closeout document will be approved by the responsible manager and the RSC.
B. Restart List items All other restart list issues, both hardware and non-hardware will be closed using !
l normal plant processes (e.g., maintenance work requests, Leaming Process, etc.). )
The responsible manager for cact, 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 l easily available for review by intemal and extemal reviewers.
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The responsible manager is the final approval for completion and does not need to j bring the item back to the restart sub-committee unless the completed action was i significantly different than the action approvod by the committee or there is a concem regarding the effectiveness of completed actions. Department Managers will, as part i
of the final restart readiness review, validate to the RSC that their departments are I
ready for unit restart and power operation and that all restart list items have been completed.
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Maine Yankee Restart Readiness Plan .
Vill. Restart Readiness Assessment 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 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 Quality Programs and Ucensing 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.
- 1. Readiness Assessment Objectives Readiness assessments will be performed to achieve the following objectives:
A. Er'sure 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.
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.
- 2. Conduct of Readiness Assessments 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 responsibia 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 suppo.t 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.
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.
(See Attachments 9 arid 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 team in resolving performance issues, the ability of the management team to sustain the P:VtESTART.wpd Revision 0 Page 19 4
4 Maine Yankee Restart Readiness Plan .
peormance improvements and the overall site readiness to support restart. (See Attachment 11 and 12)
- 3. Readiness Assessment Review Scope Readiness assessments willinclude the following items as a minimum scope. Additional ;
guidance and documentation formats are provided in the attachments.
A. Plant System Readiness Assessments 1
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 suppoti safe and reliable restart and full power operation. !
Implementation of this reviev: sill include close interface and coordination with Operations. )i l
This affirmation is the closure of th? system review process initiated in il;e ufork j scope venfication phase. Incomplete activities at the time of the presentation of the j final system readiness assessment will be identified as contingent 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.
System engineers (or designee) should:
. confirm resolution of any open regulatory issues, e confirm that the material condition of the system supports safe unit startup and power operation, e completion of walkdowns to identify any remaining materiel condition concems, a 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.
I B. Program Readiness Assessment For those programs requiring improvement actions p;ior to restart, as determined through the initial program screening, program owners will affirm the readiness of PMESTART.wpd Revision 0 Pgge 20
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their programs to support ,.. ant startup and power operation. The assessment performed to provide this affirmation will include:
e confirm resolution of any open regulatory issues,
. evaluation of the actions taken to resolve performance issues, f l
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. description of the methods that will be used to maintain program compliance l l with regulatory requirements and industry standards, and !
l . rnplementation of compensatory measures (as appropriate) for post-restart 1 items / issues. l l
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 overrll 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, l
.- resolution of cultural issues or barriers to safe plant operation, i
. ensure that post-restart work and improvement efforts are sufficiently defined, i prioritized, scheduled, and controlled, and l
. ensure that appropriate post- sstart assessments and monitoring processes are in place to prevent recumance 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,
. mainter'ance, engineering and other backlogs are adequately reviewed, screened and restart issues resolved with appropriate completion t.chedules 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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I l The RSC will complete an integrated assessment of overall site readiness including the effectiveness of management in rese: ;g performance issues and establishing methods to prevent recurrence). The mu.egement assessment will include the following key areas (see Attachment 11):
. Oversight and Commitment
. Organization and Support
. Operations and Maintenance
. Corporate Support In addition to the management assessment, the overall site readiness assessment l
I will consist of a " roll up" of several interfacing and overlapping inputs including: j
. Action Plans for significant restart issues,
. resolution of extent of condition issues,
.- outage work order completion (Hardware Restart Ust),
. cer@cn of Leaming Bank tasks required for restart (Non-hardware Restart List) e system readiness affirmation, e program readiness affirmation, .
. department readiness affirmation, l
. Licensing and QPD affirmations, 1 l
- . closeout and disposition of all restart list items, and
. status of short term improvement plans.
The integrated readiness assessment of MY to restart will be documented in l I
Attachment 12.
! [
E. Restart Recommendation The RSC will review and evaluate both the individualinputs 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 l reactor startup. Preliminary or intermediate assessments will be conducted as ]
deterinined appropriate by the RSC, the Vice President Operations, or the President l i l 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 IX. Startup and Power Ascension 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 responsibilities and pre defined hold points for physical plant inspection. A detailed plan for ini'.iating the startup and power ascension will be prepared under.the leadership of the Plant Manager and l
approved by the RSC prior to initiating the integrated site readiness assessment. ,
l The follo..:ng items will be considered in the development of the plan for startup and power ,
ascension:
e activities necessary to demonstrate cperability of technical specification systems,
- activities necessary to demonstrate operability of secondary and support systems, .
- results of pre startup testing, ;
l e adequacy of system lineups,
- adequacy of surveillance tests and surveillanca test program, j e verification of the resolution of significant hardware issues, l
- testing requirements during startup and power ascension, _
- maintenance requirements during startup and power ascension, and a shift staffing requirements during startup and power ascension including ope,ations, 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 drect on shift presence to assess the ongoing activities. They will maintain
- - a cognizance of these activities and assist the Plant Shift Superintendent as ,
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necessary to resolve issues. The major focus of the on shift maager is SAFETY.
l The manager will insure that hold points are not exceeded until the appropriate-reviews are provided as per the startup and power ascension plan.
l B. Restart IJst 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.
l C. System Lineups The Operations Department personnel will perform system lineups in accordence with the appropriate system procedure. Documentation of these lineups will be
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l maintained by the department and a report will be made to the Hardware l l
Subcommittee that alllineups are completed as appropriate. j D. Chemistry Conditions ,
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The Chemistry Section Head will provide a report to the Hardware Subcommittee concerning the status of plant systems and any conditions that warrant special l attention during the plant startup and power ascension. j i
E. Plant Modifications i The Engineering Division will provide a report to the Hardware Subcommittee indicating the closeout statu:. of all plant modifications instituted during this j shutdown. The report will include, but not be limited to, testing, training and i
document updates. l j
l l F. OPIT Review of Outage Status l t i The Outage Planmng and Integration Team will review the outage work list to insure that the plant is saady to proceed to the bestup evolution and report the results to the l Hardware Subcommittee. The report will indicate at what point open issues will be ,
1 resolved and will provide a summary of items that are to be included in Phases 2 and l l 3. .
- 2. Prior to Reactor Startup j
! A. Plant System Readiness Assessment '
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A report will be provided to the Hardware Subcommittee covering those items provided in Sechon Vill of the RRP. The report will indicate at what point open issues l will be. resolved and will provide a summary of items that are to be included in l
- Phases 2 and 3.
l l B. Program Readiness Assessment Program status report to the Non-hardware Subcommittee covering those programs as detailed 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.
C. Department Neadiness Assessment Department status will be reported to the Non-hardware Subcommittee covering those items provided in Section Vill of this 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. 1 Revision 0 Page 24 P
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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 l perform a system walkdown while the plant is at normal operating temperature and i 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 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 1 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.
- 3. 30% power 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 Performance The Operatens Manager will review operations activities during the hestup, reactor startup evolutions and ascensen 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 i
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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- 4. 90% power A. System Walkdowns l
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 Performance The Operations Manager will review operations activities during the heatup, reactor )
l startup evolutions and ascension to 90% power to determine if any additional actions
! relative to organizational support, trair;ing, 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 repoit willindicate at what point open issues will be i resolved and will provde a summary of items that are to be included in Phases 2 and l 3-l l 1
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- i, Maine Yankee Restart Readiness Plan X. Oversight Oversight of restart related activities to ensure that potential safety significant issues or areas of non-l
!- compliance with regulatory requirements are identified and effectively resolved will be achieved through a combination of line management involvement and independent review. I l
- 1. Line Management ,
Line management is responsible forthe 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 tnese evaluations to the Hardware and Non-
! hardware Subcommittees,
! . review and follow up on schons assigned to their organzabon from the Hardware and Non-hardware Subcommittees or the RSC, e rauc 6f rlompleted work products and closecut documentation prior to submittal to the Hat:fware and Non-hardware Subcommittees for closure,
. use of effective performance indicators to monitor department activities, and a reviews and approvals required by work implementing procedures.
j 2. Plant Operations Review Committee (PORC)
The PORC will provide oversight for restart activities through the following activities:
l
. approval of plant startup and power ascension actions, e 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 (QPD)
~
QPD v.ill provide independent oversight of tl.e RRP in order to independenty 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,
< . hardware restart issues, e non-hardware restart issues, and e significant emerging issues.
A separate plan wi'l 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 l provided to prevent recurrence and ensure that improvements are sustained, adequacy of closeout including documentation and appropriate field verifications, adequacy of root cause
( determinations and adequacy of extent of condition determinations.
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The Manager, OPD will be a member of the RSC and CPD representatives will be on the Hardware and Non-hardware Subcommittees. An organization chart of the QPD l
implementation of independent oversight is provided below.
Figure 5 Restart Quality Program Organization J
Mgr. Quality
- Programs i
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Quality Rep Quality Prog Quality Rep Hardware Organization Non-Hardware l
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! Hardware Restart Action Non-Hardware Restart issues Plans (Appendix) Restart issues Oversight Oversight Oversight l 4. Nuclear Safety Audit Review Committee (NSARC)
The NSARC will fulfill their responsibility to advise the President, MYAPC on the RRP and i j
readiness of the plant to restart through oversight and assessment of the RRP l l implementation. ;
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Maine Yankee Restart Readiness Plan i
l Attachment 1 Definitions !
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- 1. Department Readiness Assessment The process whereby department managers ensure the readiness of their area of responsibility by reviewing items such as performance indicators, organizat, ion staffing, personnel training, and se'f-assessment of performance results. (See Attachment 8) l
- 2. Emergent Work ,
All new work items that occur after applicable restart list issuance. l l
- 3. Focus Programs List l Dose MY programs with speedic structure and purpose that have been selected by the non- l hardware subcommittee as being appropriate for initial performance review and final ;
l assessment. (See Attachment 7) j
- 4. Hardware Restart List All work orders planned for Queri in the 1997 refueling outage (designated 97 REFUEL) including those that meet the restart criteria.
- 5. Integrated Site Readiness Assessment l An integrated review by the Restart Steering Committee (RSC) for restart readiness which includes assessments of system, program and department readiness reviews, restart list l closure, content of Phase 2 and Phase 3 plans and other ongoing self-assessment. (See l Attachment 12) 1
- 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) i
! 7. Non-Hardware Restart List A list of program, process and organizatiSnal tasks that must be completed prior to restart of MY (a subset of the Leaming Process data base).
l 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 AfGrmation Verification by Quality Programs that there are no quality issues or concems that would j prevent the initiation of MY restart and power operation. (See Attachment 10)
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Maine Yankee Restart Readiness Plan
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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.
- 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 MY as 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 by reviewing appropriate documents, restart criteria,. field walkdowns and other outstanding engineering / hardware issues. (See Attachment 6) l 1
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Attachment 2 NRC 0350 Cross Reference i
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Atta hment 2 "*9
NRC 0350 Cross Rofarancs ISSUE Appiacable Restart Short-term Long-term Notes / Comments _ _ j Phase 1 Phase 2 Phase 3 C.1.1 Root Cause Assessmsnt:
Cond bons requinng the shutdown are ad of CA
$ YES App A&B N/A N/A
_gigafy,yndetstggd. _ _ _ _ . _ _ . , . , _ .
Root causes of the Conditions requmng ad of CR 2 YES App A&B N/A N/A the shutdowrybre clearly understogd.
Root causes of other significant Part of CAL - Extent of Conditions l 3 YES V N/A N/A prpblemg are clearly,ynderstood. . _
Evaluate adequacy of the roct cause Implement. Evaluate & Improve New 4 YES App F A E3.4.E3.5 Leamma process i
annivsis orocram !
! C.1.2 Damano Assessment:
! Damage assessment was thorough and No Damaged Equipment l
$ NO N/A N/A N/A w.. .snsive. l Correct accons restored system & No Damaged Equipment 2 NO N/A N/A N/A souloment or verMed nerformance as I
- C.1.3 Corrective Actions
Evaluate adequacy of me Mmssed magh me & 2 1 YES RRP Ph. 2 Plan N/A 1
-,,,-...%.O s i.ci;vs ="-_=, plan. Plans I Evaluate adequacy of the Addressed through the RRP & Ph. 2 ,
2 YES RRP Ph. 2 Plan N/A comorehensiv a wocrsms for sc+#- Plans l Aches am Pan oReammg Bad - l Assess contml of mnochw acum M YES RS List LeamBank LeamBank 3
trackina. Eayio.Ac6ons are Part of WO Process )
Effeceve correenve actinns in place for Addressed in Appendix A&B of me RRP 4 YES App A&B N/A N/A GeML. that reouired the shutdown.
Appendix C-H of RRP & Action Plans in 5
Carmet actes 'or omer s@macant YES App C-H Ph. 2 Plan N/A u,vi.J.ms have been imolemented. Ph. 2 Plan Adequam conoceve accon whAcate Addressed through Restart Assessments 6 YES Vil &X QA Assm QA Assm and QA Amenemments C.154Te'If-Assessment CeeeNiity:
Effeceveness of me Quauty Assurance va sie By Enug Assessment &
l $ YES -
A -
Procram Place Rec'd imorovements in Ph. 2 Plan Adequacy of Industry Exponence valuam y nug Assessment & {
2 YES -
A -
Review Procram Place Rea'd imorovements in Ph. 2 Plan i Adequacy of ucensee's independent valush By Enem Assessment &
3 YES -
A -
Review Groups Place Rec'd imorovements In Ph. 2 Plan Adequacy of donciecy mporang sysum Covered By New Leammg Process i 4 YES App F A E3.4 E3.5 Eval.uJted Bv NRC Week of 2/17 SW withngness to mise mncem. Embate By Cummi Assessant &
5 YES Vill-3.C A A1.1 Place Imorovements In Ph. 2 P'an Memeness d M N usage No Signincant Problems Indicated in This 6 NO N/A N/A N/A AJBa Address improvements in Business Plan Adequacy of Commitment Tracking YES - -
F2.4 7
Proaram.
Extemal audit (i.e. INPO) capabihty valuate By Emeg Assessmet &
g YES -
A -
Place Rea'd Imorovements in Ph. 2 Plan Address 1 npr vements in Business Plan Quahty of 10 CFR 50.72 and 50.73 YES - -
F2.6 9 mart; C.t.1 Manacement Oversicht & Eflectiveness: EnWate By Entes Assessant &
Management commitment to achieving YES Vlli- 3.D C D2.7 D2.8 Place Reo'd Improvements in Ph. 2 Plan 3
improved performance Performance goals / expectations SumrnanzeeG15 m Business Ran:
YES Vill 3.0 - App G 2 introdygton, Sp_etio_rLQ1_1&_ App _G devolgped for staff Goais/expectabons communicated t Commmcated in Business Plan YES Vill- 3.0 -
D1.4 3 Employee Bnenngs mesm# Evaluated By Dm Manin Study &
Resources available to management t YES Vill- 3.0 E E4.1 4 incoroorated_Lntglusiness Plan qghJgv3_ goals Develop a Succession Plan and Mgmt Quah canons and tminmg of YES Vill- 3.0 C D2.3 D2.7
! 5 Assm for Officers & ManafLers j manaoement valuate in Dept. Rea@ ness Assm.
j anagean s mmmenM YES Vill 3.D -- -
6
( orocedure a@erence Address in Ph. 2 Plan Mgmt. involvement in self-assessment & YES Vlli- 3.0 A E3.6 7
indepeglent golf-algg31.gapability Effectveness af management review Hze Restad Commmee & Then i 8 YES Vill 3.D A -
! _gommittees Address in Ph. 2 Plan Effecoveness of intamal management valuam y num Assessant &
l 9 YES Vill 3.0 C -
Place Req]Ll_mprovements in Ph. 2 Plan meebnqs valuam y Emeg Assessant &
10 M*"*9'**"I I""P'*"I D** YES Vill- 3.D C -
Place Rea'd imorovements in Ph 2 Pian l - .
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. 1 Attachm2nt 2 "*S'2 NRC 0350 Cross ReferanCa Applicable Restart Short4erm Long-term Notes / Comments
- - . . . . - ISSUE __ _ Phase 2 Phase 3 Phase 1 l Evaluate By Entergy Aueument & l g Management's awareness of day-to-cay YES Vill- 3.0 C -
P_ tace Reg'd imorovements in Ph. 2 Plan
__..pperaton1Leoncems Ability to identfy and pnontze significant an of New Leanng Pseu 12 YES App F A E3 4 E3.5
_gsues Ability t coordinate resolution of at e v Leanng Puen j 13 YES App F A E3.4 E3.5 '
_I!qnicanlissues Ability to implement effective correctve ad of u Samng Paess
$4 YES App F A E3 4 E3.5 actons C.2.2 Manaaement Organization & Support:
Structure of tne organizaton Evaluate By Emergy Aneurnent &
YES Vill-3.D D E4.2 3 Place Rea'd improvemen_ts in Ph. 2 Plan 1 Ability to adequately staff the Evaluated By Tim Martn Study &
2 YES Vill-3.0 E E4.1 incorpqrated into Business Plan
_2rgangation Effect of any management Evaluate As Part Of Restart Readiness 3 YES Vill-3.0 C&D E4.2 reorcanizaton Assessm_ent Establishment of proper work Evaluate By Cuhral Auessnwnt &
4 YES Vill-3.0 o D1.4 D1.5
_pnvironment Place imoroves in Ph. 2 Plan Evaluate By Entegy Assessment &
Ability to foster teamwork among the - YES Vill-3.D F D2.1 3 Place Reg'd imorovements in Ph. 2 Plan staff Ability to resolve employee concems.
Evaluate By Cuhral Aneument &
6 YES Vill-3.D B D1.4 D1.5 Place Imorovements In Ph. 2 Plan Review Engr Programs For Restart Ability to provMe engins*9g support YES Vill 3.D H E4.5 7
Program Review is Part of Restart Plan Adequacy of plant adr in~tratve YES VI & Att.7 G F3.2 8 Proo/ Process improvement is On-ooint Drocedures.
information exchange with other utilites Enhancing industry Awareness is in The g ygg _ _ p3 Business Plan. Section F-3 Parte paton in industry groups Enhancing industry Awareness is in The YES - -
F3 10 Business Plan. Secton F-3 No Significant Problems Indicated in This g Ability to function in the Emergency NO N/A N/A N/A Area Response Oraanization aton we Msne emamency No Significant Problems Indicated in This NO N/A N/A N/A 12 Area clannino eNats C.3.1 Assessment of Staff: Evaluate By CuNral Assessment &
Staff commitment to achieving improved Vill-3.C B Di.4 Di.5 3 YES Place Imorovements in Ph. 2 Plan D+iformance Evaluate By CUNral Assessment &
Staffs safety consciousness YES Vill-3.C B D1.4 D1.6 2 Place Imorovements in Short Term Plan _
Understanding of management's Commune Businen Ran Before YES See Note -
D.3 E.6 3 Restart
_gxpectatgnslooals Understanding of plantissues and Commumcate Business Ran Before
, YES See Note -
D.3 E.6 Restart corrective actions Evaluate By Cubal Auenment &
Morale YES -
B&F G.1 5 Place Imprcygments in Ph. 2 Plan No Signi nt Proderns Indicated in This Stan (umonymanagenem relatonship NO N/A N/A N/A 6 Area EvaWate By Entegy Assenmem &
Structure of the organizaton YES -
D E4.2 7 Place Rea'd imorovements in Ph. 2 Plan Evaluate By Restart Readiness EMect on the stan of any roomanizaton YES Vill D E4.2 8 Assessment Evaluated By Em Martn Study mze Resources available to the staff YES -
E E4.1 9 Contractors For Restart Weakness m Maint haccrectaton g Quahfications and training of the staff YES See Note -
F1.3 Eval. By INPO & Restart rieadiness Evaluate By Cultural Assessment &
t g Staffs work environment YES - B D1.4 D1.5 Place improvements in Ph. 2 Plan No Significant Problems indicated in This Staffs fitness for duty NO N/A N/A N/A 12 Area l No Significant Problems indicated in This Atteneveness to duty NO N/A N/A N/A
$3 Area No Significant Problems indicated in This y Level of attenton to detail NO N/A N/A N/A Area EvaMated By M Mamn Study &
AdeQucy of staffing YES -
E E4.1 15 incorporateJ;Lin_tplusiness Plan Ofthour plant staffing NO N/A N/A N/A 16
A enmw 2 NRC 0350 Crono Rafarsnca "*'*
_ ISS U_E . Applicable Restart St ort-term Long-term _ _ _ Notes / Comments Pnase1 Phase 2 Phase 3 g7 Rotation schedule for shift workers No Significant Problems indicated in This NO M M M Area _
Staff overtime usage valuate By Enteg Auenment &
18 YES -
E E4.1 Place Req'djmprovements In Ph. 2 Plan Amount of contractor usage Evaluate By Enteg Auenment &
19 YES -
E Ed.1 Placdeg'd_Jmpg_vements in Ph. 2 Plan Staff / contractor relabonship Evaluate By Entergy Assessment &
20 YES -
D&E N Place Reg 11 Imorovements in Ph. 2 Plan Allegation process understood. valuate By Enteg Aneumnt &
21 YES -
B D1.4 D1.5 Worker /NRC communicabon orotected Place Reg 31Jmprgvements in Ph. 2 Plan _
22 Procedure usage / adherence Evaluate in Des Readnen Assentnent YES Vill-3.C - -
Awareness of plant secunty No Significant Problems indicated in This 23 NO N/A N/A N/A Understanding of offsite emergeng 9" '
- 24 NO N/A N/A N/A olannino issues C.3.2 Assessment of Corporate Support:
Relationship between corporate and the va ate By Entag Assessment &
9 YES -
D ti4.2 i
Rant staff Place Rea'd tmorovements in Pn. 2 Plan _
Adequacy of the request for corporate Evaluate By Entergy Assessment &
2 YES -
D E4.2 serv 6ces process Place Rea'd improvements in Ph. 2 Plan Corporate understanding of plantissues Evaluate By Entergy Assessment &
3 YES -
D E4.2 Place Rea'11morovements in Ph. 2 Plan Corporate staff in plaat rme Evaluate By Entergy Assessment &
4 YES -
D E4.2 Place Reg'd imorovements in Ph. 2 Plan Effecoveness of the corporate / plant valuate By Entag Assesstnant &
5 YES -
D E4.2 Interface meetnas Place Rea'd Improvements In Ph. 2 Plan Adequacy of corporate representabon at Evaluate By Enteg Assessment &
6 YES -
D E4.2 olant activities Plaj;;e Rec'd lmotovements in Ph. 2 Plan Adequacy of corporate engineenng Evaluate By Enteg Assessment &
7 YES -
H E4.5 suooort Place Rea'd Improvements in Ph. 2 Plan Adequacy of corporate design changes Evaluate By Enteg Assentnent &
5 YES -
G&H E4.5 Place Rea'd Imorovements in Ph. 2 Pian Adequacy of licensing support Evaluate By Enteg Assenment &
9 YES -
D E4.3 Place Rea'd Imorovements in Ph. 2 Plan Coordination with offsite emergency No Gignificant Problems indicated in This 10 NO N/A N/A N/A niannino owia's Area C.3.3 Operator issues:
ucensed operator staffing meets Part of Final Restart Readiness Review 9
reauirements and ItcenseJoals YES lVMD - -
Level f farmality in tne control room Part of Final Restart Readiness Review 2 YES Vill-3.D - -
Adequacy of c ntrol room simulator No Significant Problems Indicated in This 3 NO N/A N/A N/A trainira Area Control room / plant operator awaraness Part of Final Restart Readiness Review 4 YES Vill 3.D - -
gf_eauipment status Adequacy f plant peratng pr cedures Part of Final Restart Readiness Review 5 YES VitMD - -
Procedure usage / adherence Part of Final Restart Readiness Review 6 YES Vill-3.D - -
Log keeping pracaces ad of Mal Restad Rea@nen Remw 7 YES Vill-3.0 - -
C.4 Assessment of Physical Readiness of the Plant:
Operability of technical specificatons System Rea$ ness Assessment and 1 YES Att G IX N/A N/A
_fyptems Restart & Power Ascension Plan Operacihty of required secondary and an of estan & Power Ascense Ran 2 YES IX N/A N/A i LuppgrLinta!Its j Results of pre-startup testing Part of Restart & Power Ascension Plan 3 YES IX N/A N/A Adequacy of system lineups an of Restan & Power Ascense Ran 4 YES IX N/A N/A Adequaq of sminance wsmst Restart Plan Appendix G Evaluates the 5 YES AppG & IX -
B.3
_prpgram T_1stina Prog Signif cant hardware issues resolved Tracked By Restart Plan Appendix A-H &
6 YES App A-H I B.2 (i. eJamaged/agen_q_ equip _menLm_pds) Resta_rt Lists Adequacy of the power ascension Part of Restart & Power Ascension Plan 7 YES IX N/A N/A testino o,Ocam f
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^'tachmsnt 2 "'"
NRC 0350 Cross Rafaranco ISSUE Applicable Restart Short. term Long-term Notes / Comments Phase 1 Phase 2 Phase 3 g Adequacy of plant maintenance program YES Vill-3.D G&H E1.1
_f_ffgetiveness i g Maintenance backlog managed and YES Vill-3.D J B4 4 i imlagt on operation aspessed
/.dequacy of p' nt housekeeping and 10 YES Vilh3.D oguipment storage qq Adequacy of onsite and offsite o gm cant %blems indicated in hs NO N/A N/A N/A l emeraeriev orecaredness ,
Area C.5 Assessment of Compliance with Regulatory Recuirements:
Applicable hcense amendments have N/A q YES AppC Att 9 N/A beentatyed Apphcable exempbons have been N/A N/A 2 7 Att 9 l Granted i Applicable reliefs have been granted N/A N/A 3 7 Att 9 Imposed Orders have been N/A 4 No N/A N/A rn~8Mrescinded 5
Conhery Acton Leuer condibons YES Att 9 N/A N/A have been saMA=d nt enforcement issues have 6 S$n YES Att 9 N/A N/A been resolved A#egations have been appropriatey Att9 N/A 4//.
7 7 addr e 10 CFR 2.206 Ponbons have been 7 Att 9 N/A N/A 8
soorooriately addressed AW SaW and UcensM Board ASLB Hearing Not Planned 9 NO N/A N/A N/A hearinan have been comoleted ,
C.6 Coordination with Interested Aaencies/F arties:
Federal Emergency Management N/A N/A
$ NO N/A Agency Environn. ental Protecton Agency N/A N/A 2 NO N/A Department of Jusace N/A N/A 3 NO N/A Depanmentof Law NO N/A N/A N/A 4
Appr pnam Se and Local Omm sg pahnt WW Coo @ ate 5 YES See Note N/A N/A With NRC Appr pnate Public Interest Groups Wng DepanmentWW Mnate 6 YES See Note N/A N/A With NRC Ucensing Department Will Nrdinate Local News Media YES bm m N 'A l7 With NRC l
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Maine Yankee Restart Readiness Plan Atwchment 3 Restart Work Criteria
' Resturt work is based on two fundamental and related concepts: safety and compliance with regu! story requirements. .
Condbons, issues and deficiencies which, if uncorrected, could reasonably result in the plant being in an ensafe, inoperable or non-compliant condition must be corrected prior to restart. Conditions, issui.zi, and deficiencies for which 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 Gereenino can th condition, issue or deficency reasonably result in the plant being in an unsafe condition, or a safety significant system or component being inoperable? For example:
1.1 Has th'e 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 Gncy 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 conditior create the high potentiel for personnel injury or overexposure?
l Criterion 2 Raoulatorv Reauirements Screenina 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 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?
2.3 Does the condition result in failure to satisfy a technical specification surveillance 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 Attachment 4 Work Order Review The flow chart on the following page summarizes the process that will be used to identify work orders requiring completion prior to restart. The following key actions will occur. l
- 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 l l efficiently. l
- Wor'kscreened as non-refuel will be reviewed by the Hardware Subcommittee to provide i l oversight of the screening result. l l
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- Work activities will be followed by the system owner as an integral element of the system J l readiness review process. ,
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- Emergent work or wo* removed from the outage scope will be reviewed against the restart '
l i work criteria and, as appropriate, by the Hardware Subcommittee similar to the initial bulk l revie N. ,
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- The system owner wisi integrate the open work order status into the final system assessment l to ensure that the system is resdy to support safe plant startup and power operation. ;
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I L Attachment 4 Work Order Review Review Flow Chart l l
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Work Order Listing l
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I F 7 OPIT Non-Refuel 97 i
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i I Review Non- ---> Work List i I Outage Work (97 REFUEL) t i I -
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Non-Refuel Work Final System I.) List ---> Conduct Final ---> Review Form (Sort by System) System Assm j
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Attachment 5 Corrective Action Program Review i
The flow chart on the following page summarizes the process that will be used to identify corrective acdon program /leaming process tasks requiring completion prior to restart. The following key actions will occur::
The Leaming Process Team performs the initial review of corrective action program (old i programs) and teaming process (new program) issues against the restart work criteria.
- The results of the screening evaluaten will be reviewed by the Non-hardware Subcommittee !
to provide oversight of the screening result.
. Work activities wm be followed by the issue owner and will be incorporated into tha 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 Departmeni Manager will integrate the resuits of the completed corrective action program /Leaming Process tasks with the status of open issues and tasks into the ,
Department Readiness assessment to ensure readiness of the department to support safe l plant startup and power operation. .
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Corrective Action Program Review ;
Review Flow Chart r , r , , ,
Old Corrective i New Learning Existing Learning '
Action -> rocess issue Bankissues -
Programs (CAP) i w a w a w a I
if if 1 Depart. Mgr. LP Team Review for LP - Review for Restart < '
input & Restart Criteria l
l if 1 Non Hardware RC I '
Restart Tasks l l Review & Approve ---) !
~-------> (Restart List)
I i Restart issues g J l I 1 I
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to Non Restart (--- Complete Restart Tasks 4-------$ I i ( ; I I
I a i I if I l l issue Owner l I
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'--------- Review Completed - - - - - - - ~ ~~i l -
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9 LP issues / Tasks ---) Conduct Depart ---> Assessment Form (Sort by Depart) Readiness Assm.
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Readiness Assm.
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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 if the item requires resolution prior to restart-
- The results of the screening evaluation will be reviewed by the Hardware Subcommittee to provide 7varsight 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.
. 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.
. The system owner will monitor the system during startup and power ascension.
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Plant System Readiness Assessment Assessment Flow Chart FSys. Prob / Issues c ,
ystem Owner Work Orders Learning Bank ---> Review System ---> ~1 Proposed Mods R wF m Problems / issues I (Engr Actions j t- a i 1r I System Owner F ' I; System l Conduct System ---> Walkdown Form i Walkdown i L J l g_ _ ._ _ _ _ _ _ _ _ _ _ _ 4_ _ _ _ _ _Y ,
Hardware RC F '
Restart Actions
,--------> Initial Restart ---> (Restart List) i Committee Review I
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Schedule &
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Procedures Review Completec Final System Testing Require - - - > Tasks. Documents _ _.) Assessment Form Vendor Info. & Emergent issuss t s I
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System List ---> Conduct Final ---> Walkdown Form i
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Plant System Headiness Assessment Listing of Significant Systems l
- 1. Auxiliary Feedwater/ Emergency Feedwater
- 2. High Pressure Safety injection
- 3. Switchgear Room Ventilation '
! , 4. AC and DC Electrical Distribution l 5. Containment Spray l 6. Emergency Diesel Generators l 7. Low Pressure Safety injection
- 8. 115 KV Offsite Power i I
- 9. Residual Heat Removal l 10. Safety Actuation Systems
- 11. Attemate Shutdown / EFCV Air l
- 12. Service Water and Component Cooling Water 1
- 13. Reactor Protection
- 14. Condensate / Feedwater
- 15. Instrument Air'
- 16. Fire Protection l
- 17. Containment Isolation
- 18. Reactor Coolant
- 19. Control 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 systema from this list as a result of review activities. ;
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L . Attachment 7 j Plant Program Readiness Assessment l
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! The flow chart on the following page. summarizes the process that will be used to perform the L
program readiness assessment ensuring identification and completion of all tasks regnMqg 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 I criteria on the flow chart and input from other personnel in the organization will be used to I make these decisions.
. The program cwner will perform an initial review of program issues, problems and open work )
items against the restart work criteria. ,
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. The results of the screening evalustxm 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. ;
e Work activities will be followed by the program owner and tracked as input to the final program readiness assessment. l
. 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.
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. 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.
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I Msin'J Yankee Rastart Readinsss Plan Attachment 7 Plant Program Readiness Assessment Assessment Flow Chart 1
Priority Matrix Programs List -
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.) Non Hardware RC Restart Review & ---> Programs List
"*"' 8*Y Prioritization (Phase 1) i Safety g t
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M F 7 Program Owner Ownership
- Procedures List Conduct initial ---) *
- Learning Bank
~~Y Program Review Backlogs & Pts L s l
Qnspections/Assm. j j_____________' ;
Non Hardware RC r 7 l Final Prog. Assm.
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_) Review for Restart ---> Not Required l 3 Criteria & Need --
For Restart l ;
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Actions Changed (g- Complete Restart 4--- R tar List i
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Final Program Procedures Review __y Review Actions & __y Assessment Form l
Industry Experstice Conduct Final NRC Information Program Assm. ( j j (Flow Chart j '
if i Non Hardware RC . l Review Program 4 ,
Readiness Assm.
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Attachment 8 Department Restart Readiness Assessment The flow chart on the following page summarizes the process thet will be used to perform the l
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.
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- The results of the screening evaluation w'l be reviewed by the Non-hardware Subcommittee J to provide oversight of the screening result. 1 I
- Work activities will be completed by the task owner and tracked by the department Manager as input to the final Department readiness assessment.
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- Employee communication meetings will be held to discuss any department issues requiring resolution and to identify barriers to performance improvements.
- Emergent issu'es 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.
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- 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 i startup and power operation.
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Maine Yankee Restart Readiness Plan Attachment 8 Department Restart Readiness Assessment Assessment Flow Chart I Problem/ Issues ) Department Mgr. F '
Learning Bank '
. Acti ns
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R w om Depart. Re e Inspections / Audits L >
(Self Assessments y _ ___________J Non Hardware RC F '
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Presentations ---> Conduct Depart. --------# l l Employee Meetings I l l Ieonle/Pronrams P \ If Department Mgr.
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i Non Restart LP Final Department U (Sort by Depart')
Verify Restart - _ -) Assessment Form Actions Complete t ~J k J i
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Maine Yankee Restart Readiness Plan Attachment 9 l 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.
. Confirmate'y Action Letter conditions have teen satisfied.
. Significant enforcement issues, if any, have been resolved.
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. Allegations, if any, have been appropriately addressed.
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. 10CFR2.206 petitions, if any, have been appropriately addressed.
. Alllicensing actions have been closed. !
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. Open license commitments have been reviewed.
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l Attachment 10 Quality Programs Closure Affirmation l The Quality Programs Department Manager shall review the following elements in providing affirmation that there are no additional issues preventing unit restart:
. The results of all quality verification activities performed to insure adequacy of response !
and closure of Phase 1 activities such as: i
. Action Plans for significant restart issues, I
. hardware restart issues, !
. non-hardware restart issues, and )
. significant emergent issues. !
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. In reviewing these elements, the Manager shall consider the following enteria:
. completeness of planning, e adequacy of root cause determinations, including determination- of extent of condition,
. appropriateness of actions taken to resolve performance issc s, i e methods to prevent recurrence, a methods to ensure that improvements are sustained, and
. adequacy of close-out, including documentation and field verifications.
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IGlaine Yankee Restart Readiness Plan Attachment 11 Management Effectiveness Assessment Page 1 of 2 The RSC shall consider the following in providing affirmation that management is ready to support safe startup and power operation:
! Oversight and Commitment
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. management commitment to achieving improved performance )
. goals / expectations communicated to the staff I
. resources available to management to achieve goals l . qualifications and training of management support safe operation
! = management commitment to procedure adherence e management involvement in self-assessment and independent assessment l
. effectiveness of management review committees -
I . effectiveness of intemal management meetings e management in-plant time
. management awareness of day-toA operational concems e ability to identify and prioritize significant issues
! e ability to implement effective corrective actions .
1 Organization and Support
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- structure of the organization
. ability to adequately staff the organization e effect of any reorganization
. establishment of the proper work environment
. ability to foster teamwork among the staff
. ability to resolve employee concems
= ability to provide engineering support
. adequacy of administrative procedures .
Operations and Maintenance
. licensed operator staffing meets requirements
= level of formality in the control room
. adequacy of control room simulator training e control room / plant operator awareness of equipment status
= adequacy of operating procedures e procedure usage / adherence e log keeping practices e maintenance program effectiveness
. maintenance backlog managed and impact on operation assessed
. adequacy of plant housekeeping and equipment storage i
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Coroorate Sucoort l
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. relationship between corporate and the plant staff
. adequacy of the request for corporate services process j
- corporate understanding of plant issues
- . corporate staffin-plant time i + effectiveness of the corporate / plant interface meetings .
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. adequacy of corporate representation at plant activities !
- . adequacy of corporate engineering support
. adequacy of corporate design changes l
. adequacy oflicensing support ,
a coordination with effsita emergency planning officials l
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Attachment 12 Integrated Site Readiness Assessment 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- :
! 1. Action Plans for significant restart issues (Appendix to RRP)
- 2. Final check against NRC Inspection Manual Chapter 0350, " Staff Guidelines for Restart Approva!"(Attachment 2) l
- 3. Extent of Condition conclusions (Section V)
- 4. Outage Work Order completien (Attachment 4)
- 5. Restart Leaming Bank task completion (Attachment 5)
- 6. Safety system assessments (Attachment 6)
- 7. Program reviews and assessments (Attachment 7)
Department assessments (Attachment 8) ;
- 8.
- 9. Licensing / Regulatory Closure Affirmation (Attachment 9) l
- 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)
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l Attachment 13 1
Short Term (Phase 2)
Preliminary Listing of Focus Areas 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
- 1. Material Condition improvements J. Backlog Reduction K. Margin improvement P:VtESTART.wpd Revision 0 Attachment 13-1
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1 APPENDIX Action Plans for Significant Restart issues i I
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APPENDIX A GENERIC LETTER 96-01: LOGIC CIRCUlT TESTING 1
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- 1. INTRODUCTION Generic Letter 96-01, " Testing of Safety Related Logic Circuits" requested that licensees review their surveillance procedures for the reactor protection system, EDG load shedding and sequencing, and ,
actuatxm 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 l evaluations, it was determined that numerous logic circuits were not adequately tested in surveillance procedures per the criteria described in the generic letter. -
I II. ROOT CAUSE
SUMMARY
Plant Root Cause Evaluation (PRCE) No. 215 was chartered, in part, to perform a root cause
! evaluation for the identified surveillance procedure inadequacies. PRCE No. 215 identified the following causa' fc: tors elated to this issue:
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- The des,gn basis functions of system components to be demonstratsf by surveillance testing j l are not clearly defined. i l l
- Surveillance test procedure technical requirements regarding methods, acceptance criteria j and scope are not defined. l I
- The correct resources (personnel, methods and equipment) are not used to develop and I revise surveillance procedures.
l - No program ownership has been established to oversee surveillarxa test implementation and
- j. development and communicate surveillance test expectations.
l - Management policy was to limit surveillance testing of logic circuits to the scope explicit in i
the Technical Specifications.
- The Self Assessment process was ineffectual in identifying quality improvements in the surveillance testing program.
Ill. CORRECTION PLAN
SUMMARY
Immediate Actions Taken:
- 1. An initial evaluation of logic testing adequacy was completed in December 1996.
I l 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.
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' 3. An independent review was completed in February 1997. New issues are screened by i Operations for the current plant condition.
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Maine Yankee Restart Readiness Plan
- 4. Temporary test procedures, temporary procedure changes and surveillance procedure modifications were developed to verify required logic circuits were tested prior to st' art-up.
l 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 l independent review.
- 3. Incorporate the resolution of logic testing discrepancies into permanent surveillance l procedures. (See Appendix G " Surveillance Testing") j
- 4. Evaluate the recommendations identified in PRCE 215 and place in Leaming Process.
Identify and complete those activities identificd 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.
IV. SCHEDULE Activity Scheduled Comolation Date Complete indepei. dent review Complete Complete Generic Letter 96-01 Commitments (surveillance 06-01-97 procedures re~ vised)
Issue Review Report ' 04-01-97 ,
Perform independent issue resolution review 07-01-97 !
Perform the surveillance procedures revised / developed 07-15-97 I for GL 96-01 logic testing-V. ' ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS
- Long-term continual assessment 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 approach used in the past.
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APPENDIX B CABLE SEPARATION 1
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- 1. INTRODUCTION l
! 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 venfy that the cables important to safety were installed in a manner consistent with the established design bases.
l l The objective of this program is to provide reasonable assurance, as required by 10 CFR 50 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 l physical accident consequences documented in the design basis and to reduce the likelihood of l interactions between channels during Maintenance operations or in the event of channel malfunction (reference IEEE standard 279-1968).
The general scope of the program consists of rev' awing plant modifications to determine which
.;afety class cables and non-nucl car safety related 460V or la ger and high current DC power cable
- routings may have been affected. This scope is cased on a review of past "as found" installations that led Maine Yankee to conclude that the original plant construction is not in question. This assumption to the program scope is in the process of being validated by review of a large sample of the plant's original construction cable routings. Field walkdowns are being performed for any modified raceways that contain the above cables. These walkdowns are intended to identify cables, including many original construction and non-nuclear safety class cables, and evaluate their respective cable separation adherence to the FSAR criteria intent.
II. ROOT CAUSE
SUMMARY
The four cable saiparation issue causal factors were determined and documented in the Plant Root Cause Evaluation No. 214 as:
- 1. Ambiguous and conflicting cable separaan criteria contributed to the cable separation deficiencies which have been identified.
- 2. Plant electrical drawings contain inaccurate information.
- 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 i
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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.
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- 1. Re-articulation of the Ucensing Bases, Design Bases, Engineering Bases and Implementing Criteria for Cable Separation at Maine Yankee The licensing bases and design bases requirements are captured in the FSAR and in correspondence on the Maine Yankee docket.
l A compendium of licensing bases, design bases, engineering bases, and implementing criteria are contained in Maine Yankee Technical Evaluation TE-226-96, Cane and Wire i
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
, requirement.
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This task separates the licensing bases and the design bases as defined in NUREG-1397, the engineering bases from TE-226-96 and the implementir>g criteria from MY-STAND ELEC-1 and compares individual " issues" on a subject specific basis. This will allow engineers to
- clearty see and understand the technical differences, if any, in the different levels of specified l
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 Pmject 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.
l 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 o' the effort has been divided into distinct phases which are described in the following section.
Given that neady 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 desiga basis. Any original construction discrepancies discovered during the effort will be investigated and the scope of the project will be redefined as needed.
I 2.1 Verification Activities
! Phase I involves a verificaticn of cable separation adequacy within sleeves, ducts and l imbedded and scheduled-exposed conduits which have been impacted by plant I
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Maine Yankee Restart Readiness Plan l modifications. It is accomplished by implementation of Maine Yankee Procedure 17-52, Cab l& Separation Assessment and Walk-down Procedure.
l Phase 11 involves a verification of cable, tray separation and tray to sleeve / duct and tray j to conduit transition separation. It is also accomplished in accordance with Maine Yankee procedure 17-52, Cable Separation Assessment and Walk-down Procedure.
t Phase 111 involves an extent of condition assessment of the separation of the Main l Control Board. A visual inspection and a photographic mapping is being performed to ,
l support a better understanding of the original esign and the current state of condition. !
l- This review will be accomplished in accordance with Maine Yankee procedure 17-53, !
Main Control Board and Control Room Panel Seperation Assessment Procedure.
l l 2.2 Evaluation of Inspection Results
! Any disuepancy er potential discrepancy related to cable routing separation identified is documented on a discrepancy tracking form. Minor degradation in physical barriers are immediately repaired. The discrepancy tracking form is reviewed by the issue Evaluation Group and if the discrepancy is valid, the group will resolve the concem.
2.3 Resolution and Correction of Discrepancies One or more of the following actions will be used to resolve discrepancies.
l A. Correct "as found" to "as designed" The configuration of cables which are found to be in conflict with the appropriate design documuts or criteria may be reconfigured to complywith the approved design. This may include, but is not limited to re-pu':ing, rerouting, installation of barriers or other appropriate altemate methods of achieving independence.
B. Engineering Evaluation to accept "as is" j 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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- Maine Yankee Restart Readiness Plan l
l IV. SCHEDULE 1
Activity ScheduledComoletion Date item 1 Complete item 2.1 PhaseI Complete Phase 11 03/30/97 Phase lli 05/31/97 Item 2.2 06/01/97 Item 2.3 ltem A 06/01/97 ltem B 06/01/97 Item C Plan Development 06/01/97 V. ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS l A self-assessment of performance within the cable separation project organization is conducted in i structured, scheduled fashion bi-weekly meeting focusing on the group effectiveness associated with activities of the preceding period. The meetings are also a principle vehicle for communication of management expectations and goals, issues discussed include:
- Industry Experience Review
- Interface with Maine Yankee's Independent Review Groups
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- Deficiency Reporting -
- Staff willingness to raise concems i
- Original design ~ commitment tracking
- Quality decisions rnede in the period of review a Conformance to licensing bases issues
- Ope,. Safety issues .
- Radiation Control Open issues i
- Qua!ity and TechnicalIssues i e Scheduling, Manpower, and logistical Issues
- Corre::tive Action Reporting
- Regulatory issues The above areas will, on a selective basis, be subjected to a more formal self-assessment prior to l
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- 1. INTRODUCTION When supplied only from 115KV Section 69, the 115KV off-site power voltage will not recover quickly enough after a plant trip and Safety injection (SIAS) to prevent a load shed and emergency diesel auto-start. This condition occurs because the motor-driven-feed-pumps P-2A or 2B will auto-start on low feedwater header pressure after a plant trip and P-2C (steam-driven-feed-pump) trip. The starting load of the motor, coupled with the other plant auxiliary loads, will keep the bus voltage low 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 rest.rt 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 poweris exceeded.
II. ROOT CAUSE
SUMMARY
A Leaming Bank entry has been made. The earlier versions of the Maine Yankee Voltage Study were performed with n ) interdisciplinary review. Maine Yankee now has an Electrical Calculation Design Review Committee that reviews all new de*:trical calculations and revisions to existing cales.
This committee, which has representativet tim Engineering, Operations, Maintenance and Licensing, provides a comprehensive review 'or any impact on Maine Yankee from our electrical calculations.
Ill. CORRECTION PLAN
SUMMARY
In. mediate action taken:
i Until recently only one (1) off-site power 115KV line was required to be operable for nomust plant
! operation, with the 345KV system backfeed us the backup cif-site supply. Meine Yankee submitted _a Technical Specification change to require that both 115KV lines be operable at power. This Technical Specification change is pending.
Actions to be taken prior to restart:
- 1. A modification will be completed to block the auto-start and trip tne motor driven feed pumps on a safety injechon 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.
l 3. The preposed Technical Specification char'ge 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 o" site power margin.
IV. SCHEDULE Activity beneduled Como'letion 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 llNPLEMENTATION EFFECTIVENESS Prior to restart: -
The Maine Yankee Voltage Study, Calculation MYC-430, will be revised to verify that these circuit modifications resV 115KV Section 69 to an operable line.
After restart:
MYC-4?O will' continue to be updated once per operatirig cycle to verify that both off-site power sources rema';a acceptable.
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l l. INTRODUCTION l We will be performing an inspection of the primary and secondary side of the steam generators.
! Primary inspections will oe 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 combination of regulatory issues and plant / industry needs and objectives.
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- 11. ROOT CAUSE
SUMMARY
l l 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 pnmary side inspechons of the steam generator originates with the requirements of Techrncal Specification 4.10. These requirements have been augmented and modified by NRC Jeneric communications, commitments made in response to these communications, as a result of l coa is'uvients made during the previous tube sleeving repair program, and as a result of inspection achvities at other plants. All primary side inspections and repair activities are aimed at preserving tube integrity.
i The activities associated with the secondary side of the steam generator are less structured from '
i a regulatory point of view and tend to result more from industry accepted practices but none the less han as their primary objechve, that of preserving tube integrity. An additional reason to perform the insWMs 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 mandshng a program to inspect the steam generator intemals. Maine Yankee will formally inspect t
S/G #2 secondary side prior to startup.
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SUMMARY
Immediate Actions As a condition a c.istart, 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 idenbfied in Table 1. Inspections will be expanded as required if defective tubes are
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identified in the base inspection.
The only regulatory issue for the secondary side concems the conduct of intemals inspection, which will be completed prior to restart.
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l l- With regard to long term actions, Maine Yankee is obligated to conduct a steam generator
- primary side inspection no later than each refueling. Maine Yankee will have to evaluate the ;
l- incorporation of additionalinspections based on the results of the inspection.
i l IV. SCHEDULE i ,
! All primary and secondary activities are currently being scheduled. l
' We plan to begin inspection on 4/1/g7. Complete by 6/15/97. See Table 1 for planned dates.
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1 V. ASSESSMENTS OF IMPLEMENTATION EFFECTIVENESS .
l Assessments of effectiveness will be conducted regularty through a Self Assessment process. This includes monitoring: ;
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- Personnel Safety - No lost time accidents; no OSHA Reportables
- Radiation Exposure - Meet ALARA Cornmittee approved budget l = Foreign Material- No program violations l
- Technical / Quality - No more than i GPD primary to secondary leakage between planned ;
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. Schedule - All inspections and repairs complete by 6/15/97 l
- Cost - Base inspections completed for authorized amount l
= Regulatory / Customer- No open regulatory issues. Complete S/G condition assessment to .
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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 Eggerate Intersections 04/01/97 (Bobbin Indications, Smart Sample)-(-200/SG)
- 4. Plus Point Free Span Indications and Eggerate Ambiguous 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
- 8. 20% of Dented Drilled Support Plate Intersections (~ 400/SG) 04/01/97
- 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
- 11. 20% Plus Point of Freespan Vulne.2bla Sample (highest 04/01/97 analytically predicted deposit M::'Jing area) (~ 400/SG)
- Will be revised as necessary based on inspection results and the nece?sity for additional diagnostics (i.e. tube pulls).
MYAPC will present this inspechon plan to the NRC at a meeting tentatively scheduled for 03/20/97.
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- 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 dmicro-curies / milliliter range to the 10 -3 micro-curies / milliliter range indicating fuel leakage. During the ensuing months the RCS iodine activity trends and response to changes in plant power level indicated 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 identded. Just prior to the shutdown, RCS iodine activity was in the low 102 micro-curies /miinister range. On January 2,1997, Maine Yankee management decided to perform a concunent inspection of the fuel. Although an inspection was not necessary based on RCS activity levels, the anticipated duration of the cable separation outage provided al opportunity for an earty cause determination and disposition of the fuel leakage. In particular, Maine Yankee wanted to establish if the cause of the leakage was grid to roc fretting which had occurred in Westinghouse fuel of a similar design in another facility.
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 resutts 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 rods to determine the cause of the Icakage. The visualinspection established grio to rod fretting as the cause of the leakage.
- 11. ROOT CAUSE
SUMMARY
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
Immediate Actions Taken ,
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- A samplir.g 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 i rods at random from assemblies representative of different core locations for inspection. The l
' i inspecuon consisted of screening rods forwear using eddy current testing (ECT) and performing
- visual inspections to estimate wear depth at selected locations. Visual inspections were j performed at the highest wear location on each rod and other locations that could exceed 50%
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wear based on ECT. Assemblies were classified as having light, moderate, and heavy wear if i they contamed sample rods with wear between 0 and 25%, greater than 25% to 50%, or greater j than 50% respectively.
. The sampling program involved 325 rods in 17 s:::mblics. Seven assemblies were sampled '
. In the subset of 24 core periphery Westmghouse assemblies, and each was classified as having
- j. heavy wear. Ten assembiies were sampled in the subset of 44 interior Westinghouse ,
assemblies which were found to have less extensive wear and classified predominately in the I
light to moderate range. The conclusions readied from this effort indicated that the wear problem was 'videspread and generally heaviest in the periphery assemblies and light to ]
moderate in the interior assemblies. In addition, examination of the wear scars showed evidence thr i ine diagonal grid springs were wearing completely through the fuel rod cladding in some fuel rods.
Actions To Be Taken Prior to R'estart j 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 fretting. 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 fue! 06/29/97 Revision 0 Appendix E-3 I
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Complete core analysis 06/30/97 Complete core analysis documentation 07/09/97 initial Criticality 07/15/97 V. ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS A complete assessment of the effechveness of the replacement fuel in 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 Combustien Engineering manufactured fuel for grid to rod fretting.
This was done bet.ause of grid to rod fretting experienced at another facility with similar fuel. No 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 the problem to grids with other features does not occur. These observations support the conclusion that Maine Yankee is not susceptible to grit to rod fretting from proven grid designs.
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l l 1. INTRODUCTION / PROBLEM STATEMF.NT
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l Starting in late 1994, multiple reports from our Nuclear Oversight Committee, Quality Programs i Department, and a Management Review Board identified a trend of repeated problem events. These ,
i reports also revealed that-Maine Yankea's Corrective Action Processes failed to prevent the l recurrence of these events. Subsequent evaluation identified the following Corrective Action l
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j e Problem repetition . e i e Multiple task tracking systems 4 . Inconsistent evaluation quality :
- e inconsistent threshold for discrepancy reporting
- System cluttered with low risk / low value items i j- . . - No or multiple sub-process owners j . Untimely response to and closure of issues
- e Limited access to process use and information
. Uncoordinated response to issues -
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- Duplicate issues and tasks ;
a Lack ofintegrated priority system '
. Trends not easily recognized
. Corporate and department managers unable to determine total work load / resource impact
- 11. 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 en cost and competitive standing fostered an '
attitude of cnmplacency in the sense of tolerince for non-urgent conditions. These economic pressures limited the resources available to respnnd effectively to issues raised from corrective action activities. As a result, managers and eveluators were predisposed to limit the scope of evaluations and corrective actions to fit the avaiirble resources. ,
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. Evaluation consistency and quality was inhibited due to multiple evaluation guidance and the )
absence of evaluator qualification standards. i
. 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. l
'11. CORRECTION PLAN
SUMMARY
Actions Taken in response to these Corrective Action Program deficiencies, the President of Maine Yankee on August 8,1995 chartered a cross-functional team to re-engineer Maine Yankee's root cause analysis
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j Maine Yankee Restart Readiness Plan and corrective action program. The seven member Team, referred to as the Leaming Process Re-
- Engineering Team, consisted ofindividuals from our Manager's Council, Computer Services Section, and Maintenance, Operations, Technical Support, Plant Engineering, and Quality Programs Departments. _ This was a substantial commitment of resources covering a 10 month span for process redesign and development. The Team included a department manager, two section heads, two supervisors, and two principle t#ngineers in addition to training and support personnel. l The Team was chartered to consolidate the many existing Maine Yankee corrective action processes into an integrated process for problem identification, prioritization, root cause evaluation, task tracking, and closure, in addition to consolidating processes, the Leaming Process provides a readdy avadable antry point for all issues through an on-line open-access coraputer system, common screening and coding criteria, an expert screening panel, improved evaluator qualification, a single responsible issue owner, a single consolidated task tracking system, and a common task and issue prioritization method. As a result, Maine Yankee personnel are able to focus resources on higher '
prionty items, conduct more consistent searching and trending, reduce task duplication, reduce the f number of corrective actions to a few more productive actions, and streamline the processing of issues with a minimum of paperwork. In addition, the Lesming Process has lowered the threshold for reporting problems through simplified issue ently at multiple readily available locations which offer unfettered access for all workers, including contractors. Furthermore, workers are allowed to enter issues anonymously if they desire.
The Leaming Process also includes provisions to avoid problem recurrence and addresses occasional ineffective corrective actions. These include quelification requirements for root cause evalustors, 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 extemal 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. N Leaming Process began operating company wide on January 6,1937. We believe the new process will enhance problem identification given its availability to all workers and ease of use, as well as improve the overal! quality of corrective actions.
Actions to be taken Prior to Restart '
- 1. Complete Third Party Evaluation of Leaming Process implementation design against the '
expectations of NRC inspection Procedure (IP) 40500.
- 2. Complete the staffing of the Leaming 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 applicaole legacy da'a from existing tracking systems into the Leaming 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 implement Leaming Prc ass monitoring plan to measure the continuing effectiveness of the Leaming Process. Plan to include monthly monitoring of process performance measures and trend data.
- 2. Input the results from the four Leaming Process reviews and evaluate them for action within the Leaming Bank.
- 3. Conduct ano'.her follow up Third Party Evaluation against the expectations of NRC Inspection Procedure (IP) 40500 within one year of Leaming Process startup focusing on implementation effectiveness.
- 4. Upgr ade Leaming Bank development software to currently available version.
$. Modify Leaming Bank software to collect human resource project management data in support of business planning and plant work scheduling.
i IV. SCHEDULE l Activity Planned Comoletion Date Leaming Process Team Staffing Complete Third Party Leaming Process design Evaluation Complete l
teaming Process Restart Modifications 3-31-97 Leaming Process Monitoring Plan Implemented 4-3')-97 Response to Leaming Process Reviews Planned 4-30-97 Legacy Data Transfer to Leaming Bank 6-30-97 Current and Legacy issues Restart Review 6-30-97 Third Party implementation Review Complete 9-30-97 Upgrade Leaming Bank Software 9-30-97 Incorporate Human Resource Project Data Collection 6-30-98 l-L V. ASSESSMENT OF IMPLEM'dNTATION EFFECTIVENESS Since January 6,1997, the Leaming Process underwent the following reviews:
- A Third Party Evaluation against the expectations of NRC Inspection Procedure (IP) 40500 by 4 William Corcoran.
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- Cable Separation Root Cause Evaluation conducted by Conger and Elsea to determine any i Corrective Action Process changes to prevent recurrence. l
- A Quality Program Surveillance of the Leaming Process implementation.
- A modified NRC Team Corrective Action Inspection based on inspection Procedure (IP) 40500.
In generci, all four reviews found that the Leaming 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 earlyin the implementation per:od to make any definitive conclusion on the overall i 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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- l. INTRODUCTION i
!~ As a result of the logic circuit testing issues identified in responding to Generic Letter 96-01 and the <
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 logic testing (See Appendix A), Technical Specification Surveillance, IST Surveillance Testing, and Post Maintenance Functional Testing.
Technical Specification 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 correspondinc surveillance test was prepared for each of the Umiting Conditions for Operation (section 3 of the Technical Specification), I l
- 2. Each of the existing surveillance tests adequately addresses the Technical Specification requirements, and
- 3. The surveillance are being performed adequately.
I 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 non4nclusion '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 review for compliance with the Third Interval IST Program and app;icable Codes. It will also include the review and development of component basis documentation for all safety class components. ]
This document will provide a basis for inclusion or exclusion of components in/from the IST Program l as well as provide testing reference value basis and applicable Code, FSAR and TS references.
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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SUMMARY
Technical Soecification Testino ,
t 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 Testino 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
l Technical Specification Testing l
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 J has not identified immediate corrective actions. Additionally, this review has not found l 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 suNeillance testing completeness issues, required for completion prior to plant startup are identified as follows:
. The independent review and assessment must be completed, j
= All comments or issues relating to the adequacy of surveillance testing in ensuring l compliance with the Technical Specification Limiting Conditions of Operation must be I resolved, i
. Additional testing to demonstrate Technical Specification compliance, if required, will be l complete Long Term Actions:
l No long term actions have been identified at this time.
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Intermediate Actions Taken:
Maine . Yankee has completed extent of condition reviews for all specific discrepancies identified 1 l with scoping issues and surveillance procedure methods. The process of creating an IST t
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 '
the basis for the development of program component justification.
Actions to be Taken Prior to Start Up:
( Completion of the preliminary program review as well as resolution of identified discrepancies.
l A comprehensive understanding of the IST component basis will be achieved by the document l writer, current IST Coordinator and appropriate supervision to ensure no outstanding scoping
- issues exist. l l Long Term Actions
- l l Long terms action items include completion of the IST Component Basis Document, complete l 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.
l IV. SCHEDULE j The following schedule is provided based on current knowledge of the work scope.
! Activity Nanned Comolction Date ,
Technical Specification Testing initial reviews and assessments Complete f
) 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 Test;ng l
Complete initial program review 03/31/97 l Cornprehensive understanding of component basis Start-up and program scoping IST Basis Document Completion 12/31/97 OM-10 Progrem and procedure complete 06/01/98 Revision 0 Appendix G-4 l i l E
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Maine Yankee Restart Readiness Plan Full OM-10 program implementation Cycle 16 Refuel V. ASSESSMENT OF IMPLEMENTATION EFFECTIVENESS Technical Soecification Testina The effectiveness of the above actions are assessed through the results and conclusions of the scheduled 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 rr. view process will be implemented following the comaletion of the basis documentation and will be conducted by outside industry experts as well as intsrral Maine Yankee personnel. This comprehensive review process will also be used prior to the roll out 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.
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. Maine Yankee Restart Readiness Plan
- 1. INTRODUCTION Several Environmental Qualification (EQ) components, within the Reactor Containment, are below ?
the maximum flood level and are not qualified for submergence.
II. ROOT CAUSE
SUMMARY
Failure to mamtam a continuous EQ Coordmator on site lead to failure in maintaining and upgrading t 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 the EQ criteria, requirements, process and control. .l More details are provided in PRCE #213.
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111. CORRECTION PLAN
SUMMARY
Actions to be taken prior to restart:
- 2. Relocate components required for post accident monitoring. *
- 3. Forthe 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 tiood analysis. -
- 6. Perform an EQ Program Assessment utilidng recognized industry experts.
- 7. Updated Turbine Building High Energy Line Break (HELB) analysis.
Long Term Actions:
- 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 .
include EQ awareness.
- 3. Provide training to Engineering and Maintenance staff en the EQ program criteria, requirements, process and control.
IV. SCHEDULE Activity Planned Comoletion Date Short Term Actions:
( Establish and fill EQ program manager position Completed i
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Maine Yankee Restart Readiness Plan l Relocate components required for post accident monitoring 03/31/97 i
Qualify, replace, or relocate equipment prior to restart. 07/01/97 i
, 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 l
l 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 a Periodic Prcgram Assessment and Walkdown.
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