ML20147H148
| ML20147H148 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/27/1997 |
| From: | NORTHEAST NUCLEAR ENERGY CO. |
| To: | |
| Shared Package | |
| ML20147H129 | List: |
| References | |
| PROC-970327, NUDOCS 9704020159 | |
| Download: ML20147H148 (69) | |
Text
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Attachment 1 Millstone Nuclear Power Station, Unit No. 2 l Operational Readiness Plan, Revision 1 ;
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Table of Contents I. Purpose and Process 1 A. Purpose 2 B. Background 2 C. How Did We Get to Where We Are? 3 l
D. How Do We Get to Where We Are Going? 3 E. NRC Restart Process 6 j
F. ORP Methodology 10 G. Recovery Organization 12 II. Management Standards 14 l
A. Nuclear Safety Culture 14 B. Employee Concerns 15 C. Commitments & Commitment Management 16 D. Department-Specific Excellence Plans 16 E. Management Development and Leadership 17 F. Employee Communications 18 G. Corrective Action Program 18 H. Procedure and Technical Specification Upgrades 21 i Rev.I
l Table of Contents III. Self Assessment (Organizational Readiness) 24 A. Discussion 24 ;
B. Self-Assessment Program 24 C. Independent Oversight Program 26 IV. Regulatory Readiness 27 A. Regulatory Compliance 27 l
B. Regulatory Communications 28 V. Configuration Management and Design Control 29 (System Readiness)
VI. Physical Readiness of Plant (System Readiness) 34 A. Methodology for Workscope Development 34 B. Work Process Improvements 35 C. Housekeeping 35 D. Materiel Condition and Operability 36 VII. Operational Readiness 37 VIII. Assessment of Millstone Unit No. 2 38 Restart Readiness (Operational Readiness)
A. Restart Assessment Process 38 B. Closecut of ORP Deliverables 40 ii Rev.I
. Table of Contents IX. Communications 43 l
X. Readiness For Restart Schedule & Resources 48 A. Development, Approval and Revision 48 B. Schedule Adherence and Review 49 C. Schedule Distribution, Records and Close-out 50 l D. Operational Strategy 50 J
E. Special Testingand Inspection 51 F. Major Modifications 52 j G. Projected Readiness for Restart Schedule Milestones 52 H. Resources 52 I. Contingencies 53 XI. Startup and Power Ascension Plan 54 I
XII. Performance Improvement Plan 55 A. Introduction 55 B. Performance Improvement Initiatives 55 C. Plant Improvement Projects 56 Attachments 57 - 64 iii Rev.1
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I. Purpose and Process '
Rev.1 g -
A. Purpose The purpose of this plan is to raise Millstone Unit No. 2's (Unit 2) operating standards. This will require a top to bottom organizational commitment to embrace conservative decision making, forthrightness and integrity, self -
assessment, and the highest standards for the conduct of operation. Unit 2 can noi restart until sufficiently high standards are demonstrated in the following key areas:
- HThe relationship between employees and' management?
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eXCompliance with regulatory requirements 1 e3Effehti%cdNestive sction orograms A e ' , P ,l1 , i
- $0 nit %onfijurition and operstion consistent with the licensing bases - 1
- GhNiitpltd maintain the design and licensing bases ? #'m The fundamental goal is to be recognized by our employees, the public and the ,
regulator as a trusted, safe and efficient nuclear power plant operator. A significant milestone toward achieving this goal is the removal of Unit 2 from the NRC Watch List. To accomplish this, the intermediate goal of restarting the )
plant must be achieved. This will allow demonstration of the new standards, management effectiveness during power operations and the completion of i activities that can only be accomplished during operations. l 1
l B. Background 1
Unit 2 was placed on the NRC Watch List on January 31,1996. The Unit entered a mid-cycle outage on February 20,1996, to modify the Containment Sump Screen. In letters dated March 7,1996, and May 21,1996, the NRC requested that additional information be submitted, prior to restart, which !
describes actions taken to ensure future operation will be conducted in l accordance with Unit 2's operating license and UFSAR and the Commission's regulations, and the disposition of deficiencies identified after the issuance of the ACR 7007 report, respectively. In letters dated August 14,1996 and October 24, 1996, the NRC issued confirmatory orders directing the establishment of an Independent Corrective Action Verification Program (ICAVP) and the establishment of a comprehensive plan to address the handling of employee concerns with the retention of a third party to oversee NU efforts.
2 Rev.1
C. How Did We Get to Where We Are?
1 The basic causes for our problems have been assessed and documented in ACR -
7007, the Nuclear Committee Advisory Team (NCAT) report, the Fundamental Cause Assessment Team (FCAT) report, the Joint Utility Management l Association (JUMA) report and several NRC Inspection Reports. The findings and lessons learned from those reports can be summarized in one fundamental 1 cause:
Management tolerating low operating standards, resulting in: :
- Non-conservative decision making
- Loss of trust and credibility
. Loss of configuration management
. Regulatory non-compliance
- Ineffective corrective actions
- Ineffective self assessment and oversight D. How Do We Get to Where We Are Going?
To restart Unit 2, we must raise operational standards significantly. This is necessary for Unit 2 management to regain trust and credibility with its employees and regulators. The raising of standards must first take place in management and supervision and then, by their leadership, be infused in all employees. The vision going fonvard is:
bTo:be recognised by!eimployeesfregulatbrstshdithel -
lpublic as:a trusndsafefandsflicientinuslear; operator. >
To achieve this vision, the following key issues must be addressed by Unit 2 management:
- 1. Regain the trust of employees
- 2. Regain the trust of the regulators To regain the trust of employees, Unit 2 management must stop tolerating low operating standards and immediately begin to raise those standards. This will require enlightened leadership that results in proper resolution of employee 3 Rev.1
I concerns and a non-punitive management style that rewards innovation and initiative while not tolerating low standards.
To regain the trust of the regulators, the Unit 2 organization must demonstrate its i commitment to high operating standards. To raise operating standards, management must champion self-assessment and independent oversight, to ensure that issues are identified and resolved at the earliest opportunity and prior j to becoming a more significant issue. The regulator must have total confidence i and trust that Unit 2 will proactively identify and correct--in a timely manner-- l issues in the future. Without this confidence and trust, restart is not likely to !
occur even if the physical plant and programs are restored to compliance with !
the regulations and licensing basis. l Seven key success objectives have been identified, that when accomplished, will i demonstrate the required high standards and reflect a fundamental change in how Unit 2 operates. These key success objectives are:
Millstone Station Success Obiectives e High standards and clear accountabilities
- Incorporated many best practices from other utilities
- Regularly benchmark with other nuclear utilities
- Indicators show strong improvement toward excellence
- Commitments are met
- Strong nuclear safety policy
- Careful adherence to high nuclear safety standards
- Conservative decision making
- Effective self-assessment
- Significant issues are identified by NU rather than the regulator e Effective Corrective Action process
- Corrective actions and commitments are prioritized and resolved in a timely manner, thereby maintaining a low backlog
- Improved regulatory performance as demonstrated by decreases in NRC violations and LERs 4 Rev.1
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. Restored licensing and design bases with process to ensure that they are :
properly maintained j
- - ICAVP contractor confirms that the design and licensing bases have been l
, restored l - Implemented configuration control processes to ensure design and ;
3 licensing bases are maintained !
j e An environment that supports the identification and effective resolution of !
! employee concerns ,
j - An improved Employee Concerns Program actively supported by I j- management and employees l
- Independent review of employee safety concerns confirms effectiveness
- e Commitment to resolve long-standing issues and to maintain safe and reliable
- operations
. - Resource commitment meet or exceed those of similar well run units 5
- Problems are prioritized and resolved in a timely manner
- - Commitment to resolve longer term issues is captured by continuous j improvenient 1
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l E. Nuclear Regulatory Commission (NRC)
Restart Process The position of the Millstone site with respect to its nuclear regulator is unprecedented due to the nature and pervasiveness oflong-standing performance ,
issues. As a result, the actions which must be taken by Unit 2 to resolve these issues, regain the NRC's trust and confidence, and resume operations are complex and interrelated, and demand the absolute attention of all Unit 2 employees and support groups.
The Issues Millstone has accepted declining operating standards for a number of years and, j as a result, long-standing performance issues have languished. The operating standards for Unit 2 must be raised in the following key arees:
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, IDscision$makihg)r Process Overview Many comprehensive reviews will be required to demonstrate that Unit 2, as a team, has successfully addressed the above issues. The reviews include:
. NRC Inspection Manual Chapter 0350, " Staff Guidelines for Restart Approval,"
. 10CFR50.54(f) requests for information, an Independent Corrective Action Verification Program (ICAVP),
e an Employee Concerns Program upgrade with independent oversight verification, o various NRC staff approvals, and e a Commission Vote.
6 Rev.I
- 1. Manual Chapter 350 Process The first NRC prerequisite to restart Unit 2 will be NRC Staff approval. NRC Inspection Manual Chapter 0350," Staff Guidelines for Restart Approval,"is the NRC's road map for the restart of a nuclear power plant that was voluntarily or involuntarily shutdown. MC 350 requires that the NRC staff designate a Restart Panel to oversee the process.
By procedure, the panel must develop a Restart Action Plan which incorporates a plant-specific " restart checklist." From a process standpoint, the Restart Action Plan specifically acknowledges the 10CFR50.54(f) process initiated earlier this year on configuration management / licensing basis documentation issues. The Restart Action Plan also acknowledges the Confirmatory Order requiring the ICAVP. (Note: 10CFR50.54(f) and ICAVP are discussed below)
Restart Checklist The restart checklist explicitly addresses regulatory compliance and licensing matters. It establishes the following as steps needed to be completed prior to restart:
- Necessary license amendments are issued
. Necessary exemptions or relief requests are granted e "Significant" enforcement issues have been resolved
. " Allegations have been appropriately addressed"
. Pending 10CFR 2.206 petitions "have been appropriately addressed" Operational Safety Team Inspection A key component of the MC 350 process is an Operational Safety Team Inspection (OSTI). The framework for an OSTI is established in Manual Chapter 93802, " Operational Safety Team Inspection." For Millstone, the Restart Assessment Plan states that the " inspection will cover self-assessments by the licensee, the licensee's implementation ofits startup plan, control room observation during the approach to criticality and power ascension, selected systems readiness inspections and observation of management oversight."
Recommendation Process Ultimately, when the NRC's restart review process "has reached the point that the issues have been identified, corrected and reviewed," a " restart authorization process" will be initiated. At the NRC Stafflevel, the process of preparing a recommendation includes the following steps (as stated in the restart checklist):
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- A restart recommendation is made by the Restart Assessment Panel.
- The Regional Administrator concurs with the restart recommendation.
- The Office of Nuclear Reactor Regulation (NRR) Associate Director and/or NRR Director concur with the restart recommendation.
- There are no restart objections from other applicable [ Headquarters]
offices. The applicable offices are not identified in the checklist, but given -
the pending investigation and enforcement matters for Millstone, and the l checklist line items related to enforcement, allegations, and Section 2.206 petitions, the Office ofInvestigations (OI) and Office of Enforcement (OE) will be on this list.
- There are no restart objections from applicable Federal agencies. This ;
may include the Department of Justice.
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After these steps are completed, and the Section 50.54(f) and ICAVP processes )
are complete, the NRC Staff will submit a restart recommendation for !
Commission vote. The vote process is addressed below. !
- 2. Section 50.54(f) Activities Each of the Millstone units presently is subject to a series of requests for information pursuant to 10CFR50.54(f). The information, under the terms of the NRC requests, is due no later than seven (7) days prior to restart. The letters )
address the broad issue of discrepancies between the plant / procedures and the licensing / design basis documentation (the "CR 7007" or " configuration management" issue). In addition, the letters raise the issue of the effectiveness of the Millstone problem identification and corrective action programs, and the design control process. The company, in responding to these pending requests, will need to provide a basis upon which the NRC can conclude that the plant will be operated in the future in conformance with the license and the underlying regulatory documents. - As was stated previously, Section 50.54(f) activities will be an input to the MC350 assessment. i 8 Rev.1
- 3. Independent Corrective Action Verification Program The Independent Corrective Action Verification Program (ICAVP) will review the modification of selected systems since initial licensing including:
(a) Review of engineering design and configuration control processes (b) Verification of current, as-modified plant conditions against design basis )
and licensing basis documentation; )
(c) Verification that design and licensing basis requirements are translated l into operating procedures, and maintenance and test procedures; l (d) Verification of system performance through review of specific test records and observation of selected testing of particular systems;
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I (e) Review of proposed and implemented corrective action ofidentified design deficiencies.
Completion of the ICAVP review is necessary prior to NRC restart approval.
The staff will incorporate the ICAVP results into the MC350 assessment.
- 4. Employee Concerns Due to "past failures in management processes and procedures for handling i safety issues raised by employees," and to ensure that employees who raise safety concerns are not discriminated against, on October 24,1996 the NRC ordered NU, prior to restart, to: submit a comprehensive plan within 60 days of ;
issuance of the order to address the root cause of past performance failures, and I propose within 30 days for NRC approval an independent third-party organization to oversee implementation of the plan. Independent oversight will continue until NU demonstrates that the conditions which led to the order have been corrected to the satisfaction of the NRC.
1
- 5. Commission Vote The Millstone units have been designated a Category 3 on the NRC Watch List, which requires a formal Commission vote authorizing restart. prior to the vote, the Commission will be provided with a formal NRC staff restart recommendation in the form of a "SECY paper," giving assurances that the concerns have been addressed. The paper will also indicate that the NRC Executive Director of Operations concurs with the restart recommendation.
The Commission approval process ordinarily will involve at least one public session (at NRC Headquarters), with presentations by the NRC Staff and NNECO.
9 Rev.I
F. ORP Methodology l l
The Unit 2 Operational Readiness Plan (ORP) has been developed to describe a i long-term program to raise operating standards. The process will be continuous, l long-term, and rigorous. The ORP is divided into two distinct phases: The Readiness for Restart Phase, which includes all actions necessary before i requesting authorization for restart, and the Long-Term Performance Improvement Phase, which includes long-term actions necessary to achieve excellence. The Long-Term Performance Improvement Phase will be a natural extension of the Readiness for Restart Phase and will be more fully developed as the Readiness for Restart Phase is completed. All assignments and deliverables contained in the text of this ORP have been tabulated in Attachment I and are delinested in the text by a number in brackets. The tracking number will !
designate the section and item number, e.g., I-3, IV-5 etc. Assignments and deliverables may be treated as stand alone tasks or incorporated into the Readiness for Restart Schedule. Assignments in Attachment I will be managed through the Level 1 System. The documentation and close-out of these l
documents are discussed in Section X of this plan.
\
s Of course, any plan is only as good as its actual implementation, and will only be l
effective with commitment from management and the entire organization. The !
Unit 2 team is committed to this plan and the tenets on which it is based.
Demonstration of that commitment will come through adherence to scheduler commitments with a quality product.
Readiness For Restart Phase l Readiness for Restart is generally defined as completing those activities necessary to ensure safe operations. This includes the necessary actions needed to restore compliance with regulations, including the design and licensing bases, and raising the standards to support long-term safe, reliable operations.
The Readiness for Restart Phase is composed of several elements (see Table I-1) designed to ensure the plant is ready to restart--not only from a physical and technical standpoint, but from a cultural standpoint as well.
Schedule, Startup and Power Ascension, and Performance Improvement The Readiness for Restart Schedule is described in Section X.
10 Rev.1
i The Startup and Power Ascension Plan discusses the transition from current state to full power operation. It is described in Section XI. ).
4 The Performance Improvement Plan describes longer-term actions designed to l return Unit 2 to excellence and sustain that performance level. It is described in .
Section XII. I 1
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G. Recovery Organization The purpose of the Unit 2 Recovery Organization is to establish a higher priority on safety and to focus the organization on raising standards and completing '
effective corrective actions. To accomplish this, the example Recovery Organization shown in Figure I-l will be used as a model to facilitate the recovery of Unit 2. Key " coaching and integrating" positions will be established to evaluate and focus on nuclear safety, corrective actions and regulatory compliance, as well as work control. Adjustments to the model organization will be made as required to support recovery and longer-term normal power operations.
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Millstone Ucit 2 Model Recovery Orgecizatica - ,
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l II. Management Standards (Organizational Readiness)
High operating standards are absolutely essential to the success of Unit 2 because they are directly linked to the safety and reliability of our operations. The following section describes the process for establishing and raising Unit 2 standards. The key to success in each area discussed is clear communication of management expectations, followed by clear accountability for follow-through.
A. Nuclear Safety Culture Conservative decision-making is the standard which must be demonstrated on a continuous basis. Specific actions in this area include:
- T An Unit;2 Nuclear Safety: Policy:will.be developedtimplemented, and;
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embraced to. enhance and guide ' conservative. decision making. ;[II-1];
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- LOrgani;zational changes will be'made to emphasize an4 Safety ((lF2]T; ' , s ,
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. JAti dperations'DepartmerfstanhArd for reactivity l management willpe!
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Ed SOER 96-01, "C6ntr61 Room / Supervision, OperationN Decision- I xM'aking, and Teamwork,"lwill be addressed l{ [II-4]4 ' .
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g e4 -10CFR50.59l training will befprovidedi;[II-6] : y o, r.
a " P6iiodic Human Performance Enhancement:standidoWns will be c conducted;[II-7];
i l The role of the Plant Operations Review Committee (PORC)is critical to providing line management independent review of actions taken and changes 14 Rev.1
made to unit operations. To increase the effectiveness of the PORC, the following activities will be taken:
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- 3 Perform a benchmarking assessment of.PORC!nt good performing' plants
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$PORC administistive (nonasafetyfrel'athd)ieviews [II-9]X ,.
The Safety Evaluation (10CFR 50.59) Program needs to be enhanced by:
eqEstablishing; appropriate linka ge between Operabil.ity Determinstions; .
Land'. Bypass'Jumperstwith the 50."59 process [1I-;10]? f" ' N ' ,
I WEnsuring tlst}0.5heviewers"hnd approvers have complsted training,3 '
- and;e'stablishing~ ~ a peer reviep group to ensure ponsistent standards are :
' imet forl50;59haluationse,:[II-llli .
4
^
B. Employee Concerns Effective resolution of Employee Concerns will be toe highest priority of Unit 2 management. Employee concerns will be addressed in a prompt, efficient, and respectful manner. They will be addressed by supervision listening to employees, understanding their issues and resolving them. Specific expectations are as follows:
- JThel Unit -2 Recovery Officer will provide the expectations and standards -
for how management will resolve. employee concerns.; [11-12]; .
m ,. -
- ]Unitl2 managementlwill fully support
the NU. Nuclear EmplopeeJ
.' Con ,s ,
J'
. W , cerns & Progmm.~
8 < ..
oh All employees will bE familiarized with the Employee Concerns / , ~
+
Progranib[II413]; g.y ' [ '
f (
U' nit 2 management will receive training and/or, coaching on theb l
- )Nxpectati6ns and standArdsifor resolving employee concerns l ithe EhiployeEConcerns Progfam. :[11-14]; '
t 15 Rev.I
C. Commitments & Commitment Management l i
l The standard for meeting and managing commitments must be raised. Our past l resolve to meet our commitments and our ability to manage them has been poor at best. Simply put, we must do what we say we will do! Our standards in this area will be elevated as follows:
l l
- The AITTS system will be adopted as the Unit 2 method of commitment' ;
tracking. !
l e I An AITTS data management guideline will be established to manage data and commitments. [II-15]
- The AITTS backlog of" notify" items will be eliminated. [II-16]' !
D. Department-Specific Excellence Plans !
Each Unit 2 department will develop an Excellence Plan to raise standards and incorporate actions required by this Plan, including necessary personnel training and development. [II-17] Specific areas to be included in all Excellence Plans l include:
l 4--Self Assessment; , 7--Self, Assessment' Training 3 ,
7 m. . .
--%artment Performance Indicafors; L- Observation Tfaihing4 -
- m E--Root Cause Training L m '
--Fint Line Supervisor Training 4
%,Hinnan Error Reducti6nTrainingiT 450.59 Training? s , .f ,
o , $wQualification Traininge *
.e Y a--Staffmg and Resource Assessment?
n .
7 4 Customer FeedbackJ , ,
ji-Clarification of Roles and Expectations ABenclimarking 7 ? .
d-Nuclear Safety Policys M 16 Rev.1
E. Management Development and Leadership Management standards will be raised through the implementation of a program of management development and leadership. Key behavior characteristics for the Unit 2 leadership team to embrace and demonstrate include:
. Promote Teamwork e Place " priority" on priority issues e Follow through and meet commitments e Coach and reinforce positive behavior and provide leadership
- Endorse continuous improvement and raising of standards
- Make conservative decisions Inputs for the development of this program are:
- AThe Virginia Power Recovery Team wil1 provide the leadership standard and:-
l (coaching required to devslop;an effective long-term Unit 2 mansgementi j J te6mf .,
?, . . _ _ , .
l2Y e'6 Train and assignL" coaches" to facilitateias appropriate! the raising ofi 4 l Jstandards. [Ill18]? ,
, s I et Perform obseivation training [Il-19] AY_, .
e U A 1.evel 1 management _ accountability l system _ will be'establishedb [Il-20]; .
EJ Meaningfulfuhit performance' indicators and' stretch goals will be established;
' '~
7 4 [Il-21]! ' ,
n;
. L The expectation ofc"no missed commitments," includind N'RC s;nd '
c commitmentstwill .be' established.([ll.-22]1 ^.
_. l' .
l
.M"Enlighteriod Lsadershii;l Getting to the Heart of Change," byLOaldey'sndi ;
MJ Krug, will be utilised to makel positive changes;within the Unitt 2 organization.; !
- Facilitated working' session (s) with Unit 2" management' personnel will be' held i t'o introdu'ce aijd reinforbe she' key bshavior characteristics discusssd above.
([Ili23]; ? . y , _.
~ ._ .
n m .
.: : A' Best Practice's Coordinator will be assigned to dev5lop a_ benchmarking i plan land scheduleg Bsnshmarking trip ls.will be made to INPO and 'to wSil L 1 performing power stations to. understand and raiso stsndardsflNPO assistl
' ; visits wil.1 be;used to facilitate lanld ~ evaluate standardsr [Il-24]:( .
e: A special' assessment.of supervisors,(and above) by their subordinates will:
.be used 'to evaluate'minagement leadership capabilitp and to identifyf
~'
' development needsi[Il-25] '
o i
17 Rev.1
F. Employee Communications An Unit 2-specific Communications Plan has been developed. The overall objectives of this plan are to:
- Convey high standards and expectations.
- Build confidence of employees in themselves and their leadership.
- Reestablish employee beliefin, and trust of management.
. Develop teamwork and organizational buy-in.
- Convey sense of progress.
Specific Actions:
ebThe Recovery Officer:will provide key standards and expectations for!
icoinmunidAtions.- ' ,
^
e EThe Recovery' Officer l Directors! and !Managers wil'1 convey thesej i >
0!standardiand expectations in accordance With th6UniE2 ( ' "
. ; z, JChmmunicstion Plah provided in Atia$hment'4..[II-l26']E 'i
- G. Corrective Action Program An effective corrective action program is comprised of two principal phases --
identification and the implementation ofidentified action (s) to correct the deficiency.
In the identification phase a low threshold must be maintained to get all potential discrepancies into the corrective action program. Based on screening criteria for the items identified, proper immediate corrective actions must be implemented and reportability must be determined in a timely manner. Additional screening will determine the need for an immediate in-depth review (root cause) or self assessment. Further reviews will then be conducted to determine proper classification and categorization of the issues identified. Identified items will be placed in the data base for tracking and trending. Periodic management reports and trends generated from the data will determine the need for additional in-depth reviews. Action items that are generated from the various reviews will be 18 Rev.1
. I implemented to turn trends in the improving direction or to prevent the recurrence ofevents.
The implementation phase of the corrective actions program is equally important.
This phase utilizes many in-place processes to make certain that the corrective actions identified get proper prioritization and tracking until the item is complete.
Examples of these processes include but are not limited to the automated work orders (AWO), drawing updates (GRITS), and procedure revisions. In order to close an item after work is complete, evidence must be verified that the original concern has been addressed properly. For significant items such as commitments to the Nuclear Regulatory Commission, closure packages will be developed to provide an auditable product.
In order to maintain a strong corrective action process, a clear and concise program has been developed and documented with an approved procedure. Line management has taken ownership of the program by understanding the process and providing the resources and priorities necessary to respond to identified items in a timely manor. Self-assessments will be conducted to assure that no j weaknesses are appearing in any area of the process. Oversight will also provide periodic assessments and audits of the program.
The following has been undertaken to ensure that the Corrective Action Program is effective:
- 1. Organization:
A Corrective Actions Manager has been assigned with a staff dedicated to the program to provide the support required for program development and processing.
The staffincludes root cause specialists who have been trained on industry proven j practices to determine the appropriate causes and corrective actions. The staff l also includes trained personnel to properly classify events and to trend the data to ;
identify areas where additional attention is needed. Reports and trends allow l management to focus on specific weaknesses identified. Coordinators have been provided by the line organizations to make certain that day to day work is l incorporating the actions in their department work plans that was identified l through the corrective action process.
l 19 Rev.I
i
- 2. Process: .
+
' A new corrective action procedure was approved which clearly delineates the =
responsibilities and processes required to conduct an effective corrective action j process.
.- . 3. Prioritization:
a i Efforts are underway to review the many actions that are outstanding to properly !
, . prioritize and group them. As the multiple phases of this plan are executed, the
- . outstanding corrective actions associated with each system and program will be-
! reviewed and closed as the corrective actions are completed. In some cases the
- actions may not be required prior to restarting the unit. For these activities, a ,
management review will be conducted to assure that these items, either as stand I alone items or in aggregate, will not affect safe operation of the unit. I i
s
- 4. Assessments:
Self assessments and independent assessments of the corrective action program -
will be conducted periodically. An independent assessment will be used to -
determine the health of the program and to make adjustments as needed. Key Performance Indicators have been identified to provide the needed trends as the !
program matures. Benchmarking will continue with other utilities to provide the !
new ideas that are needed to keep the program at the highest standard. !
l 20 Rev 1
H. Procedure and Technical Specifications Upgrades Standards must be raised in the area of procedure and technical specification quality. Specific actions are as follows:
A; single technical;and administrative ~ Unit 2 procedures group will bei <
estabilshedelH-34] m Mlw s Technical Procedures revised (including EOPs andAOPs);requir' e d for:
~
4,,
rSsturi feadiness will tie' revindi lH-35] L * , .
4 The Emergency Operating Procedure (EOP) Upgrade Program will be completed following the return to power operations. [II-36] Specific activities are as follows:
. Development of all EOP Upgrade Program administrative control procedures (Writer's Guide, User's Guide, EOP Administration and Maintenance Procedure, EOP Verification Procedure and EOP Validation Procedure)
- Mark-up, and Simulator Verification of CEN-152 on Unit 2 Simulator EOP re-write
. EOP Standard Appendix Development
. Basis Document Development
. Deviation Document Development
. Implementation Guidance Document Development
. Operators Classroom and Simulator Training
. EOP Upgrade Label Program Design and Implementation, SPDS upgrade
. SPDS Upgrade
- Upgraded EOP Setpoint Document Development and Implementation accounting for instrument uncertainties (based on CENPSD-1009)
- Pre-staging of all required tools and equipment 21 Rev.I
i l
The Abnormal. Operating Proced. ore l(AOP);UpgradesProgram.will bel , /
completed"fstlowinidae r$tuin to pswerlopepailens ?l1I-37kSpecifie? L ,j L
activities are as follows:l ? , " ' MS se i ' L" - f " T 'W ,
e Upgrade existing AOPs
- Develop and Implement AOP Writer's Guide, User's Guide, Program Administration Procedure, Verification Procedure and Validation Procedure
. Develop new AOPs as identified
. Upgrade Appendix "R" AOPs including technical revision to meet l Appendix "R" Compliance Report !
- Unit 2 is nearing the end of the multi-year PUP, scheduled to be completed prior to unit startup )
e Benchmarking has been completed for each department's procedures i against the PUP Standardized Writer's Guide e The remaining Unit 2 procedures are being upgraded to the PUP standards to ensure technical quality and usability (human factors)
- The PUP goal has been to assure that procedures are effective, efficient, l and supports safe and reliable plant operation Unit 2pperating prossdures will be reviewed land revised as: appropriate prior to_ Mode 4 sperations, to ensure water _hainmer' events lanprecluded/,
lnE39)fkh?'x : M N : ' , m lh h > ' M '% ' %
22 Rev.1
d Severe Accidsat. Management Guidelines.(SAMG) will be. developed,from..the; o
gensrielDomhbastion Enginderhig OwneriGr~
dif.dto' lie cons'pleted by DecemberT1998dSpscific actl r np'(CEOG[Yiti 8
- Develop and implement SAMG Writer's Guide
- Draft Phase I, II, III guidelines and Restorative AMGs
- Develop Calculation Aids
.
- Review IPEs for discrepancies
- Perform JTA for operators and STAS
- Develop training materials for operators and STAS
- Develop / revise SAMG support procedures
- Revise EPOPs and EPUGs
- Conduct EP organization training
- Revise station radiological emergency plan The' Unit;2 Technical.SpeelGcations will be upgraded to;the InsprovedW Standsid(TecliniEal
$f $EtionitA restN5 U Sp$ltIto AonthliankdMth Ns Design nuts.hnMl f '" y ,
w'l lll'9 2'-) h.
4 i
23 Rev,1
III. Self Assessment (Organizational Readiness) l 1
A. Discussion To better understand the magnitude of problems that must be corrected, candid and objective assessments have been, and will continue to be conducted.
Building from past evaluations and internal assessments, NU management has determined the key weaknesses and performance gaps. These assessments provided management the opportunity to review problems and commit the necessary resources to effect significant change. To ensure that problems of this ;
severity do not occur in the future, an effective self-assessment program, and >
culture, are required.
B. Self Assessment Program Establishment and implementation of effective self-assessment are vital to the long-term success of Unit 2. Unit 2 must become a leaming organization utilizing both internal and external assessment and the industry operating experience programs.
The key attribute to critical and effective self assessment is line management ownership and support. Extensive information already exists that, when evaluated appropriately, provides insight as to unit programs and operating performance. This information will be used by managers as the basis for self-assessment of unit performance. The self assessments will be performed by line managers and will include input from the line, intemal oversight and extemal independent auditors and assessors. Self assessment is to be an integral part of each manager's Department Excellence Plan.
Unit Performance Indicators (UPI) will be selected and used to communicate goals and standards. Managers will review progress toward meeting the goals and will use this progress as an input to self-assessment. These indicators will be updated and reported on a monthly basis. Oversight and quality assurance personnel will report their findings and concerns to station managers. The results from these activities will also be used in the self-assessment process.
24 Rev.1
.- - .- - - - . . - . - - _. .= - .- . - - _ -
l l
j Inspection Findings--resulting from internal Nuclear Oversight audits, NRC inspections and external evaluation--will be reviewed by unit management to assess the effectiveness of the self-assessment program.
s
~
The ORP itself has been assessed by Nuclear Oversight to ensure it appropriately addresses Unit 2 standards and issues.
1 4
I The following specific activities will be undertaken to provide an effective !
i self-assessment program:
, eMThe(Uni (2 Recovery lOffiEeriwill pro, vide;ths etsudard apdl expectation?
' J W, M > Mm S n u~'
Mfor,ssif~assesiment4M11]y>%sg
- w. ~. ..
+ am s m ->,,w ink 4 Annun E ,developedto.1in,tegnsereleva An: Unit _T2: ~
Unit Perfannance, ,ciator)Windon~,
sis Pregnna 9 wiBe &an !
, elfas 4
( Performance lcriteriaduidellence[will;bejdevelopedjuoithstE
- w ~ .
goals;for4xd,sess.a,ienfin,fo,n n ,
n aMmanagement baskshiR'assammad prognun1 win b e ygapencofed![ Rip]F g g i 7 $[g$cy +
QKegindicasarsMufJetinithis planfrabl%0Wessoing , ;
~
6_operationi.a,%:e_tum_nservise. mm will beidevelopedlan. dm. o,nitobedd!H_4 .-
m 64 . ie M]Id Hinneui ~Enconuninnentlil-17)M%AWW~*.wM i
PedsnMEEninace$nt Aknus$il1M dim edPeriodic
~pimnant
?d,lN){[n$n@hM @ f f,4 % sMOlbI. x Self' d.
.~ -
~ .,c n .
Assessments will be co,nductedfin~th,ke e areep:sfi7
'fM a m L-ConictkMI[III4]3 -
n.m : ~
MQ@y@#
- xc
.,?3+ W M '
w" g g%e-Safety;Evaluationsp0CFRl50f9);[M4]! J +y -
'
- 2 ' w!w-PORC Effectiv,esiiss;[1H- 4M 'f
.; .agw%Technisal Procedure Adec1
. ~. 1 0 acdIHy]j O, 7gj i,#b L 96gurifion!ManagementJHIyl0]p:73%i j$ ? *%
x,a;u
% # Conduct'ofOperations [III;12]> , f 2 JW*nbd x# HSudeillance;T,esting![m-11,]?. w R Wi EiP N 4, ~
.x w. . . ~ + + -
eM 5 elf Assessthendraining[will sprovidsdllofapplihable; personnel! [ Illy e % ~o .x >
4' - -
us A3]w; .
y m
,o s
- g. %' & %' w NA. n. . I.M. ,u MAaniReadin.ess
_ ~m._. For_'ResbiitNises. smeritic.odest,en_t wiGik [
n INPO'Eva.lu,ation Ofiteria d wa an_ NRC;0350is, y e idance);will- ;. be condu,cted;E . <
- Y[III-l4]h3M * '; ,d[ Ndi /
,D Y 4 +
[- L' c
25 Rev.1
C. Independent Oversight Program
- 1. Nuclear Oversight The conduct of quality work and the responsibility for quality work resides with line management. The Nuclear Oversight organization's role is to provide independent and critical feedback to line management in the key areas of regulatory compliance, work and management performance and standards. Unit 2 will value and champion the oversight function. Specific standards for Unit 2 management and employees are as follows:
enTh6 oversigh.t; function will;be utilized to provide periodic [ meaningful::'
, yassessments;ofdailyfactivitiegprocesses'and[pfogramsip[IIIy15]!
=> The Ndelear OversightJDep'.dtmentis need to staff with qualified andi
- experienced personnel wipbe supported ([Iliplf][ j ' . 'fy 4Jssues bnd'firidings fron3the audit and'surveillapce pro' gramsLwill beM bresolvsd in a proactiveflid timely niannerts [III-17]) 'i 1
1
- 2. INPO Assistance i l
l INPO will be utilized in an assistance role. Specific actions are as follows: I l
eM Coordination:with INPO.to' review action' plans and area'stof support will!
,t be conductsdl([III-18]L ' YJ (. ~ gf1%_' l
- 1;;Use ofINPO revers 6 loanees,or[ direct utility loanees will be evaluated.'
. [III-20]i
-l' ' 'L ,m ,
- A
,; 3
- [Use ofINPO" assist #isits;will be(evaluated &(AsEid visits idhe areas of
[Uperations[WorkiPlsnning[ Management Development [d$rrectiveJ Mctions[ System EhgineeringtandIPro~cedurs Upgradesiwill$ requested; 2as approfria'te#[III-2_l]L iT * " '
- 3. External Assessment Independent external assessments (including utility peers) will be used as appropriate to verify program effectiveness and quality.
26 Rev.1
4 IV. Regulatory Readiness A. Regulatory Compliance Unit 2 will be in compliance with regulatory requirements prior to restart. Specific activities to be undertaken are as follows:
- 'Implenient requiredLactions to respond to violations identified in'N'RC..
! Inspection Reports will belcompletedq [IV-1]; ' , <
m
- ; x eUshmflete actions necessary to ensure compliance lto[10CFR5dippeNdix" WB ss' indicated byLNdclear Oversight audits and open/overdde addits;
';[IV12]; e- <
?
g "
uR
.x
~
. - . . . , . , . . i ...n(. . , ,_
_ , . . . ~ . . . . . ;
- MOpen NRC Unresolved Items an d. ,LERcomnytmerits . not schedule'd to be
- resolved pridr to restart will beissesseTfdr impaction restsrtf[IV-3]> -
.. i s 3 c . ..
w ,.
- ?Oplen Bypass %mpers[ Operability Determina, tions; and NCRs'not; "
addressed before restart will,be screene'd and addressed undeh '
'Y
~
E ' '
l CFR5.0.5hh[IV4]' ' + o
- e. nf w.p. . ; .
+ <
w n,.
.+; ,
e (.Ophn safetp related AWOs notLaddressed priorto_ restart will be assessed;
.by an Opsrations SRO and PORCJ[IV-5]? , ' ' ' <- #<
w
'# 5
!. .. . ,,. ,t of Complete nscessary reviews, rephirsland/or/compensstory actions toi ehsure[co;mpliance pith!10CFR50[ Appendix RLfofuse;off'Diermo-lag.P
, [IV-6][
m y J '
w , ;
E Nrovide' status ofNRdcommitmenfrespopse'dueldates,in'tliS;ddily. un
/ status' report![IV-7f ' -
M -
l 27 Rev.1
B. Regulatory Communications The following are examples of products and submittals that will be made available to the NRC: [IV-8]
- Li(Unit 2 ORPl Readiness for' Restart worklistl Performance Improvementi '
LWoEklistl
/ ' .' -
9' _
^
eiREsponse. to l'0CFR5034(f) istter?
s -
- 3 p ;& y . .. . .
i ,
,y c '
e ICAVP Plan'and R'equestj- ;
2:. . .
ei Violation. responses as'specified by NRC Inspec' tion:Repoits . ,
,la
'O i_.
l > . , l' [_ 'f ,' p Ia 7
e'u Clossre'pdckages for LERA and Violationsi -
m , , i:t
' ^
ea Closdre packages fdr selected CRss '
, v-28 Rev.I
V. Configuration Management '
and Design Control (System Readiness)
The Configuration Management Plan (CMP) has been developed to respond to the NRC's request pursuant to 10CFR50.54(f) and the associated Confirmatory Order.
The CMP will identify and resolve significant discrepancies and also provide a j basis for future operation in accordance with operating license, the Commission's l regulations and the Final Safety Analysis Report (FSAR). l l
To accomplish these objectives many important tasks must be performed. The 1 first step in the process is to define the CMP scope, process, controls, and deliverables. With this completed, the CMP team will proceed to assemble system Design Basis (D.B) summaries and Licensing Basis (LB) commitments. The next step is to verify that Unit 2 design, operation, testing and maintenance are consistent with the DB and LB commitments and requirements. In addition, the CMP is responsible to ensure that station-wide programs and processes that implement and maintain DB and LB requirements are reviewed for compliance, revised as necessary, and are effectively implemented. Unit 2 technical programs
- and processes which impact system design, testing and maintenance will be reviewed by the CMP for compliance.
An important milestone is the Independent Corrective Action Verification !
Program (ICAVP), which is required by NRC Confirmatory Order. This special I inspection will independently evaluate the effectiveness of the CMP efforts. The ICAVP will look at selected Maintenance Rule group 1 and 2 systems following the discovery phase of the CMP. Results of the inspection will be independently reported to both the NRC and Northeast Utilities (NU). To make sure we are prepared for this verification, a pre-ICAVP Readiness Assessment will be conducted to assure a successful inspection. The preparation and support for the ICAVP team inspection is an important element of the CMP. When we are i confident that we are well prepared, the NRC will be notified of our readiness to proceed with ICAVP.
29 Rev.I i
i Periodic self-assessment will be performed to assure quality is achieved by verifying the effectiveness of project processes and products throughout the CMP effort. In addition, Nuclear Oversight will continue to closely monitor the CMP activities and to provide critical feedback.
Prior to Unit 2 restart, the response to the NRC 10CFR50.54(f) letter must be prepared and submitted to the NRC. This response must describe the actions .
- taken to ensure that future operation of Unit 2 will be conducted in accordance
- with its license, the Commission's regulations and the Unit 2 FSAR. Also, the i
! response must describe the actions taken to ensure that identified deficiencies have
- been appropriately evaluated and resolved. The CMP will provide a basis for l developing this response by documenting the results of the DB and LB compliance verification and providing the rationale for concluding that the Unit 2 ,
l design basis requirements are translated into operating, maintenance and test j procedures. The CMP effort will also result in the identification of significant ;
problems, establishment of root causes and corrective actions necessary to ensure l
- future safe operation. J l
4 The FSAR, selected Technical Specifications, and other documents will be revised prior to Unit 2 restart to ensure that the re-established configuration is accurately described. In addition, the CMP provides for a long-term configuration
i plant, ensuring that all documents are updated and requirements are maintained. !
l j 10CFR50.54(f) Letter Summary The March 7,1996,10CFR50.54(f) letter from the NRC requires submission of !
additional written information, under oath and affirmation, to determine whether i or not the license for Unit 2 should be suspended, modified or revoked. The i information is to describe actions taken to ensure that the future operation of Unit 2 will be conducted in accordance with the terms and conditions of the operating license, the Commission's regulations, including 10CFR50.59, and the FSAR. '
The submittal should describe actions taken to assure that deficiencies identified, based on the ongoing review, have been evaluated for operability, the existence of unreviewed safety questions and reportability.
ICAVP Confirmatory Order Summary The NRC issued a Confirmatory Order to NNECO on August 14,1996, requiring an Independent Corrective Action Verification Program (ICAVP) at each 30 Rev i
Millstone unit. The ICAVP is to be conducted by a technically qualified )
company, independent of NU and it's design contractor. The purpose of the ICAVP is to verify the adequacy of Unit 2's efforts to establish adequate design
- bases and design controls, including the translation of the design bases into ;
operating procedures and maintenance and testing practices, verification of system j
- performance, and implementation of modifications since issuance of the initial facility operating license. ;
J Licensee Basis (LB) Definition t
The Licensing Basis (LB) is that set of requirements that includes the applicable NRC regulations and licensee commitments that ensure the unit's operation is in '
conformance with the operating license, the unit's design basis as specified in 10CFR50.2, NRC regulations, including 10CFR50.59 and the unit's FSAR. l Design Basis (DB) Definition !
Design Basis means that information which identifies the specific functions to be )
performed by a structure, system or component of a facility and the specific values i or ranges of values chosen for controlling parameters as reference bounds for the l design. These values may be (1) restraints derived from generally accepted state-of-the-art practices for achieving functional goals or (2) requirements derived ;
from analysis (based on calculations and/or experiments) of the effects of a i postulated accident for which a structure, system or component must meet functional goals. l Maintenance Rule System List Group 1 1 Auxiliary Feedwater 125v DC Emer. Diesel Generator Service Water 4160v Emer. Buses ESF Room Cooling
.RBCCW 120v Vital AC Reactor Coolant LPSI Boric Acid Shutdown Cooling RWST Control Element Drive CVCS (Volume Portion)
CTMT Structure EBFS & Fuel Hand. Vent 480v Load Centers 480v MCCs Reactor Protection Main Feedwater Safety Injection Tanks HPSI Main Steam ;
Containment Spray ESAS CTMT Air Recir. & Cool. l N1 Linear Range CTMT Isolation l l
31 Rev.1 i
Group 2 RSST NSST Switchyard CTMT & Enc. Bldg. Diesel Room Ventilation Diesel Generator Fuel Oil Purge Instrument Air SFP Cooling & Purif. Sampling CTMT Post Inc. H2 Cont. Main Exhaust Radwaste Vent (Aux.
bldg.)
Control Room A/C Cond. Storage & Transfer EHC Control Chilled Water Plant Heat & Cond. Revy. Fire Protect. & Deluge Auxiliary Bldg. Intake Structure Turbine Bldg.
NI Wide Rng. Log Incore Nuclear Monitor Reactor Regulating Channel Control Bldg. Process & Area Rad Monitors Enclosure Building DC Vital Switchgear Ventilation Configuration Management Program List 10 CFR 50.59 Program Design Change Program EQ Program HELB Program Setpoint Program MEPL Program Appx. "R" Program MOV Program SBO Program IST Program ERDS Program Thermo-lag Program Fuse Program Fire Protection Program Section XI Program Check Valve Program R.G.197 Program Seismic Program M-Rule Program Appx. "J" Program Heavy Loads Program E/C Program PMMS Program To; maintain" adequate and effective control of the Design Bases, ths follo~ wing) activities will be conducted:' j ,
'/'
v.s
- EEstablish a CMP plin .which meets th' e relquireinents of the Marck7,3996 NRC (letter pursuant to 50.54(f)>[V-I]t 'V i 32 Rev.I
s F. Implement the CMP plan to validate and/or restore. plant configuration with th.e l l Design 1 Basis and Licensing (Basis land successfully somplete the Independent : 4
! Corrective lAstion Verification required lif.the NRC Order dated August.14l
- 1996 [V,-II]/ " " '
x
', .. .~ a. . ~ ~ .. ,m of Establish ownership for system Design; Basis and technical programs." [V-3]s '
eij EstaNEli an Engmeenng Assurance Program.J[V-4] , ;
- 1 Reduce 'the $ngineeringl Drawing:sacklog.i [V-5];; % <
l e . .. ,.
5; -L Ensure ths Desig$; .tontrol procsss adequatsly[ considers'shanges tb required ;
' L adminisd ative' and technical programs (e.g.J Piocedbres[ Vendor Manuals,;
e
' f App R, EQ, .Siinulator, Emergency Preparednsss?etc.).1[V-6]L X >
I i
l b
4 d
l 33 Rev.I
. Figure V-1 Main:enance Rule Systems Total Plant System Population eeup2 Maintenance Rule Scope h Group 3 Goup 1 Safety Related Non Risk and 88I'tY ' Risk i
Risk Related Significant Significant Significant
Figure V-2
- Engineering, Design, Licensing l Basis Relational Diagram i
Engineering l Design Licensing i
Basis Basis Basis 4
4 j
1 4
f 1
i
Figure V-3 RELATIONSHIP OF CURRENT REGULATIONS Design Infermation Current Licensing Basis Physical Plant and Procedums 50 2 50.M f 50.7I(e) 50 59 50.2* * ,
m, Design .
Dases Design Input, Output, and Tcchnical Specifications ess NRC Reguladons !
Documents Plant Specific NRC Requirements Orders License Conditions Exemptions Licensee Commhments' in:
NOV Responses
. Bulletin Responses
. Generic Letter Responses Licensee Event Reports
. Safety Evaluation Reports
- Those commitments that are necessary to comply with. egulatory requirements
" Some design bases informailon, developed in respor te to new regulations, may exist outside the FSAR. but is sti!I considered part ofI e cunent licensing basis.
4 i
VI. Physical Readiness l of the Plant l (System Readiness)
)
A. Methodology for Workscope Development i The workscope considered by the Operational Readiness Plan will be continuously i evolving. In order to identify and correctly address necessary work items, lists of deficiencies that will be screened include: AWO backlog, Condition Reprots (CRs), Control Room Deficiencies, Operator burdens, Unresolved Item Reports (UIRs), Operability Determinations (ODs), Non-Conformance Reports (NCRs),
Bypass Jumpers, and Engineering Modifications. All known deficiencies will be screened and logged into three (3) categories: [VI-1]
y)>Mork[pri6r.to restart; - E t(2) Scheduled work lhfter restart l > ', ,
$ (3)j Fhtur$ unscheduled'levdI-dfA ctiop wNfkh The Unit 2 Readiness For Restart worklist will be contained in separate documents and is expected to be dynamic. The worklist for response to the 10CFR50.54(f) letter and the NRC Confirmatory Order may also be kept separate from the Unit 2 Ready For Restart work list. Controls for maintaining the 10CFR 50.54(f) worklist will be maintained by the Unit 2 Configuration Management Project (CMP). Controls for maintaining the Unit 2 Readiness For Restart worklist will be developed by the Unit 2 Restart Director and will be consistent with NUC-PI-20 which is currently specific to MP3.
(
34 Rev.1
1 t
Q B. Work Process Improvements Unit 2's ability to resolve work items in a timely manner will be improved. I i Specific improvements are as follows: I
- $An impmvad pmoss##sik hwGIV*mWalia%Worki
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ykiaMW**peemeeneaginsinsnaarhgg tn man,ansibilismMeasar==m=MteW n 3,;4y,
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l Wapportphysicalisantmodisestiunwenietvw14N%g n, S, ,,
', L .. l 3'...
,'l gl:t i ,(.
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,,'$:N& ,<'l['
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^ ann lf.:yn~ %s vV sj.. Q: ' ';In b$ k 8
'.y s
J
]
. so; W semyne L, f ' g.g' ,
.nrhw' nig2 survetaance metingereeram,.I'].l.T:.. M a W *' ve C. Housekeeping .
l Housekeeping standards will be raised on Unit 2 by:
ob~S_tandards m.. and:a, c
, . gram..forlthe m - unit:will
- , .. .be, . ~established m ~ 4 _. ;6)m:> .. .
. E Peri 6dic emhloyee;h6usekeeping standd6was willLbe conducted 4 [VI-7]?
Mg l
l Wremoved DnauthorizedMMin$cristoredM"j from the; unit.1Vij8]$Nf . tf #P g@ % natorialiwill
~
j eMAUnit, Painting Pr6 gram;will be initisted.{Vist20 " , , a' -
35 Rev.1
D. Materiel Condition and Operability To restore plant systems.tola high state of materiel readines's;and/or topp operable -
.v, " '
~
conditiont. L , ,
"I 3.-t. ,
- e ..
.n. . . ..
m
- V Complete reqsirdd design change' modifications..L [VI4];. ." ~i s .e 4
- LComplete'reqsired preventive maintenance 6[VI-10] .. ; ,
o ,
, * ;Comple'te required corrective maintenance.L [VI-11]' , ,
I l
I i
36 Rev.1 l I
VII. OperationalReadiness !
l Operations must be conducted at the highest standards to ensure safe and reliable plant operations. The Operations Department Excellence Plan will ensure that the following key elements are met:
- Operations personnel are cognizant of the status of plant systems and equipment under their control and ensure that systems and equipment are controlled in a manner that supports safe and reliable plant operation.
- Procedures are technically accurate, provide appropriate directions, and are effectively used to support safe and reliable operation of the plant.
.
- Operator knowledge and performance supports safe and reliable plant operations. ,
e Operator training activities, including Simulator Training, are conducted l in a manner that supports safe and reliable plant operation.
- Operation of the plant is in compliance with Technical Specifications and Technical Requirements Manual.
The following specific actions will be completed:
. - ? Operations.Depaitment Excellence Plan is to ensure that the above key elements aret imetk[VII;1]h ' c ' ' ,
- , ?...
et iDdveloka set of Oph' tions St$6dards whihh will includh Proac0ve Man Shift Manager and.SRO Roler; and Responsibilities,' and C6mmunications Paths andt
^
W (Espestations{[VII-2]( . .. , _,
'C e jTrain on Operations Standards.i[VII-3]; N , f...,. - m4 o ob Review all Technical Specificatiossi to ensutr understanding l therebp enhancing ; ,
ability for'coinpliance.t [VII-4]M
'. 'W '
~
j e Conduct unikwalkdowns to verify no uncon'trollSd temporary plant laherations orf. j l Fl uncontrolled postings and Operator Aids exist..l[VII-5], , )
e londusiunit'walkdownsitd ensste in; plant storage meets administrative c l grequirenients.l[VII-6]I
', . : . _ , . j e ) CompleteLOperations and System Engineering walkdowns' for' materiel condition ' l
/ issues.1[VII-7]W 4 % , :
e i iCompl$te anindependent (external) assessmesi of the' conduet of operations ( [VII-8] !
- ~ Relevant industry l operating experience.will be reviewed. [VII-9]( '
Tb i e fUnit 2 depsrtnients will conduct an operational readiness self-assessment prior to r !
I eash inodFchange or key plant configuration change (ej., fuel movement)? [VII-10] )
l l
l I
37 Rev.I
~
VIIL Assessment of 1 Restart Readiness (Operational Readiness) .
A. Restart Assessment Process ;
Restart Assessment ensures that the collective system operability and plant materiel condition supports safe and reliable plant operation. It also ensures that j operating crews and other plant personnel are fully prepared to support safe and ;
reliable startup and power operation.
l' The elements to be assessed will collectively encompass the following Key Success Objectives be to confirm readiness of Unit 2 for restart:
Millstone Station Success Obiectives j i
l
. High standards and clear accountabilities ;
- Incorporated many best practices from other utilities !
- Regularly benchmark with other nuclear utilities
- Indicators show strong improvement toward excellence l
- Commitments are met
- Strong nuclear safety policy
- Careful adherence to high nuclear safety standards
- Conservative decision making
. Effective self-assessment
- Significant issues are identified by NU rather than the regulator '
- Effective Corrective Action process
. Corrective actions and commitments are prioritized and resolved in a i timely manner, thereby maintaining a low backlog )
- Improved regulatory perfctmance as demonstrated by decreases in NRC l violations and LERs 38 Rev.1 L--__-.-.-__
. Restored licensing and design bases with process to ensure that they are properly maintained
- ICAVP contractor confirms that the design and licensing bases have been restored
- Implemented configuration control processes to ensure design and licensing bases are maintained
. An environment that supports the identification and effective resolution of employee concerns
- An improved Employee Concerns Program actively supported by management and employees
- Independent review of employee safety concerns confirms effectiveness
. Commitment to resolve long-standing issues and to maintain safe and reliable operations
- Resource commitment meet or exceed those of similar well run units
- Problems are prioritized and resolved in a timely manner
- Commitment to resolve longer term issues is captured by continuous improvement Unit PerformanceIndiesEfs
/[yd411][ ' 3 f
(]lfE,Is) for rsstart readin identified ,
I o The following specific assessments to evaluate the above elements will be made prior to restart of Unit 2:
- The approved Operational Readiness Plan will be independently reviewed by Nuclear Oversight for completeness. [VII-12]
. Specific departmental operational readiness assessments will be performed prior to mode changes. [VII-13]
- Nuclear Oversight will perform an independent assessment of restart readiness. [VII-14]
39 Rev.1
Each system identified as either Maintenance Rule Group 1 or 2 will be affirmed ready for restart by the responsible System Engineer prior to request for authorization to restart. [VIII-6] Examples of activities that will be considered include:
- Open items necessary for restart have beca completed or satisfactorily dispositioned
- Materiel condition of the system and its ability to support safe and reliable operation has been affirmed e Proper prioritization of all open items, including schedule for completion, has been completed B. Closeout of Operational Readiness Plan Deliverables The following criteria will be used as a guideline in preparing, reviewing and approving the closure of Operational Readiness Plan deliverables. Preparation and review of these deliverable packages should verify that: the deliverable statement has been met, the deliverable completion quality supports safe restart and operation of Unit 2, and the documentation is sufficient to provide an auditable record of actions taken.
The following criteria are guidelines. Some of the criteria may not be applicable to all deliverable packages. Reviewers and management may also want to add additional criteria based on theirjudgment and expertise of the specific deliverable:
- The deliverable package is approved and signed by the responsible lead e The package contains a cover memo outlining the description of the deliverable, the process used to satisfy it, and a summary of the results e The package contains memos, forms, printouts and any other paperwork evidence necessary to judge that the deliverable statement has been met
- Corrective actions are implemented to prevent recurrence and address root cause findings (as applicable) of the problems that created the deliverable
- Any potential licensing basis or safety issues raised by the deliverable ,
or its process have been resolved l
40 Rev.1 i
. . _ _ - _ . - - - --. _=- _ - _
4 i
. Any operability or restart issues raised by the deliverable or its process t have been resolved
- e Unit Performance Indicators are developed (or updated) to track deliverable items or processes j e If the deliverable is tied to a formal root cause analysis finding, include .
applicable sections of the root cause analysis e If the deliverable statement cannot be met, discuss with the Director of i Restart ,
- Self-Assessment plans include monitoring deliverable items or processes ;
j e The deliverable package is a stand-alone document ;
i i I Deliverable close-out process l l Attachments on pages 57-64 describe ORP deliverables. The following describes the general steps that should occur to close out a deliverable package:
l
. The responsible lead will schedule the package to be reviewed by the Unit 2 management team at the weekly Level 1 meeting, and distribute copies of the package to the management team members prior to the review meeting so they will have an opportunity to loci at the information before the meeting
- . The responsible lead will present the package for review / approval at the
- designated committee meeting
- The designated committee should formally review the package and, if satisfactory, indicate its approval. If the package is not satisfactory, the committee should indicate to the responsible lead what additional action is required
. After receipt of concurrence by the approval body the original, approved deliverable packages must be forwarded to the Director of Restart for inclusion in the Operational Readiness Library I
i i
41 Rev,1 l
Table VIII-1 UPIs for Readiness-for-Restart Corrective Actions Configuration Management Restart List Unresolved Items Report NCR Backlog Drawing Update Backlog AITTS Assignments Required for Startup Restart Modification Implementation Status NRC Open Items CMP - System Assessments Licensee Event Report Commitments CMP - Program Assessments
, Notice of Violation Response Commitments
, License Amendments Required for Restart AITTS Assignmenta in NOTIFY Status Assignments Against CRs Open >120 days Overdue Assignments CR Aging / Overdue Report :
Open/ Overdue Assignments- Audits /Surveilisaces Physical Plant Organizational Performance and Safety Maintenance Rule AWO Backlog Maintenance Rule (a)(1) Systems Status Restart Required Technical Procedure Revisions MEPL Systems Validated
, Condition Report Status Open Operability Determinations Reportable Events Operator Burden Reduction Ratio of Cited /Non-Cited Notices of Violations Control Room Panel Deficiencies Work Planning / Scheduling Effectiveness Temporary Modifications Industrial Safety Accident Rate Personnel Contamination Events Collective Radiation Exposure i
l i
l 42 Rev.1
i
. 1 IX. Communications i i
i A comprehensive Communications Plan has been developed for Unit 2. The Plan i places heavy emphasis on face-to-face communication as the most effective way to disseminate information and accomplish the following objectives: .
i lEBuild confidence ~of employees:in themselves and:their leadeishipp 3
- 2. is-establisti employee cEdibil'ity;and trust lof'managenienti 3$ Develop teamworNand orgsniz'a tionail! buy (-inh 4.IConvefprogresA.l " , ,- +
T Following are additional elements of the plan. A communications matrix, which describes cornmunications, their audiences, and suggested frequency, are also part of the plan.
What Should Be Communicated The information communicated falls into many different categories:
- Management philosophies and messages e Progress and Celebration of successes by individuals and/or groups e Challenges that lie ahead
. Industry and Unit-specific experience that should be communicated to all unit personnel, such as lessons learned e Management feedback on its plans and commitments j
= Other information that is useful, ofinterest, or of value from the standpoint of employee morale j e Communication cross working groups should be stressed and the )
emphasis should be continuous. Also, employees need to know that their comments / suggestions / constructive criticism will be presented to i higher management in the form it was intended when given to line management so they feel upper management is gettmg an accurate input 43 Rev.I
1 Three specific short-term communication strategies involve techniques used to boost employee morale and confidence, and provide progress: ,
. Celebration of successes at all levels. These can consist ofletters of commendation, recognition in management meetings, celebration events, spot recognition awards, a written newsletter, and photo stories, described below e Setting of several (3-5) short-term objectives that support longer-term i goals j 1
e Recovery Officer meeting with all supervisors, managers and directors together to review status, goals and future initiatives j Unit-Wide Communications Approach ,
l Consistent messages must be sent from top to bottom. It is important that I communication with employees is consistent and well coordinated. j Communication with various levels of management is beneficial to employees. l However, if meetings and messages are not carefully coordinated, employees can become frustrated by meetings that are either too frequent or not frequent enough, and can become confused if the messages are inconsistent or in conflict with one j another. i Thus it is in the organization's interest to have a plan that is well thought out and executed. Toward that end, a communications matrix has been created, which lays ;
out the plan for communications--both interpersonal and written. The plan has 1 been developed to ensure enough contact between upper management and other )
management levels, to provide management's philosophies and expectations from top to bottom.
Communications Vehicles A number of communications vehicles are available. Some are system-wide and can be used to disseminate unit-specific information to the rest of the units, as appropriate. The unit communications liaison will be responsible for coordinating unit input into the system-wide communications vehicles. These are outlined in l the Nuclear Communications plan. I I
44 Rev.1
Other vehicles are unit-specific. They are:
D sJFace-to-Face l Meetings:isistsp.after survey;demonsfrates that employeesJ .
generallyMant to re'c eive most of their infdrmation abouithe organintion from-
, theirsupervisdr.MimportancejthesscommunidationsiisusitO)eiinfoiced q ibfmanagement,;andjindividuald60uld bs held accountableMOhould b2? i made$olearlth 't) written communications!doinot repthee fasekNsse.1
- jdshouk herefttbs facenE8[kincIndesi teractionL
" dstwanmanioW_.tsem.imn=dia employees _:and;um-c ,
ermanagementL:n1 ,
mm.w 4
...o
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p 'r , g. d e3 All-handsLmeeiings,:, Mmany casss,$fastsface(comrsunienti6n;is niore&
s approprisitej~inv jarse 'groupsht,. here hee been pappropriate .
o to h,ld 'a unit lall-hands This could.berun~by!thsLunit4 lm,eetinge,isid W precoverylofHcersthelunit:
m ~a e s +, -
cdirector,j; die .
, . , -unit engineeringA,pocas
% ap
.: Dep,arimaen..fmeetlap:;W_heneverappi6priatel x ,,
inform $tionSE_dhM m
- 4. ,
Q_mbrningisnitimeetingsh6uld b6" discus _ sed iii" department n=+ine=#KsM
" ? discussed a,bove, employees,
~
.x wsnt to sstmost'of thek informatil,is ww from'the,iri timmedihte W , y*n managemeny%gahd ng. . [p brief ygmeetings gng are 4an impor~
.SUnthn.anagement letterssmeisostandispeechess Ininany;casespn .
Mtimely infonnation is best communicated by managementMThise c' ome outiony fa regular /asyneeded:bdussIts objectik is"foLpioject the fadthal manage
' iis keeping (ths[ work ~forceLinformed' and recognizing t.; - ind p
< >t
.x _ m s j;~ ,. y.
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- g pg ,
1 ,
,w iP.
.J Units" ,epartment delsbration/Modynti$nal sveiissbThere,will lEn
.n =
v .. n -
,4times when .an eventQ hucas a r: ally,;or p.~; ..icme,;will be, ; app;op. na. te.7Th,ese canM a .. . ~ . - .
Mbe;use, .d to: celebrate success,irally..fsupport for. s,yand.a xconvey;a' sense of teamworki
- Q;upcommpchallenge.', oc;L e~
4
.. e .
[ . . , /N . .. m ,;M.\..' ,
, .' 3 , ) p i, . , p( . i#( , . . , , . . , g Cyntt-specific print"commhaicationsRExamples include unit [dailieb weeklp reports,iissde-specific pitreistoriesiofficer letters /memosfeteswob
.o_.. - 4
..ms .m -
e .m dual and; our w mumcations;ar.
Limpurmnt messages that are crucia. l sii'%c. mdivi
- v. ,m o .
o . m_ ,
group recogmtion, and pmgressRThese. .messa%gew w<ere better commum.cated3 4withjhbto stofiEst and; weekly nydhs thhtnisteTI$t'p eard
~
m 1 .
45 Rev.1
TEMPLATE FOR RECOVERY OFFICER / DIRECTORS FACE-TO-FACE COMMUNICATIONS PLAN ACTIVITY EMPLOYEE RESPONSIBLE SUGGESTED AUDIENCE INDIVIDUAL FREOUENCY p
Management Staff Meeting Directors / Managers Unit Officer Daily Unit Walkdown with Managers Unit Officer Monthly Department Managers Employees Unit Director Weekly 4
Department All-Hands 1st Line Supervisors & Unit Officer Monthly Meetings (Note: May Non-Supervisory Unit Director Weekly include the entire Personnel Unit Engineering Director Weekly department orjust a major group in the department)
Unit 2 Strategy Meeting Unit Director Unit Officer Weekly Engineering Director Employee Communications Simulator O! servations Licensed Operators Recovery Officer Monthly Unit Director Monthly System Engineer Plant System Engineers Unit Engineering Director Periodically Walkdowris ,
Operating Shift Tumover Operating Shift Unit Officer Monthly Unit Director Monthly Meetings with First Line First Line Supervisors and Unit Officer Quarterly Supervisors and above (The above Bi-weekly Management Team)*
- Bi-weekly l Meeting with Operations Shift Managers Unit Director Weekly Shift Managers ***
- A quarterly meeting of the Unit Officer with o'. supervisors. With Unit progress, the frequency may be extended. Unit and Engineering Directors will meet with all of the first-lim: supervisors in one department (e.g., Maintenance) on a bi-weekly basis.
- The Unit Director will meet with at least one Operations shift manager on a weekly basis, except when the unit conditions or being away from the unit preclude it.
46 Rev.I
4 FACE-TO-FACE COMMUNICATIONS PLAN (Cont.)
ACTIVITY EMPLOYEE RESPONSlHLE SUGGESTED AUDIENCE INDIVIDUAL FREOUENCY NRC NRC Resident Inspector Unit Officer Weekly Engineering Director NRC Region /IlQ Unit Officer Monthly Managemet.t TEMPLATE FACE-TO-FACE COMMUNICATIONS PLAN For Department Managers ACTIVITY EMPI OYEE AUDIENCE SUGGESTED FREOUENCY 4
Status Meetings Management Team Daily 4
Department All-IIands All Department Employees Bi-Weekly Management Observation of Employee Groups Monthly /
Training Weekly for Licensed Ops Requal Ops Manager Meeting Ops Shift Managers Weekly Meetings with First Line First Line Supervisors Bi-weekly Supervisors Customer / Corporate Support / Periodic Vendor Invite NU Nuclear senior All Department Members Periodic management (above Director level) to speak to department 47 Rev.1 i
4 X. Readiness For Restart Schedule and Resources 4
A. Development, Approval, and Revision The Readiness-for-Restart Schedrde is developed, reviewed, approved, and revised by the individuals accountable for the completion of the contained activities and their line management. Ownership and buy-in to the schedule by those accountable for its completion is critical for success. Each department, group, or team responsible for contained activities prepares an action plan for achievement of the desired results. These actions are reviewed by the accountable department management, affected departments, and the Unit Director, or designee.
Once reviewed and approved, the activities are included in the schedule.
As we progress through the schedule, emergent activities will be identified for inclusion within the schedule. These emergent activities will be reviewed by the ;
accountable and impacted departments, and the Unit Director or designee prior to l inclusion into the schedule.
Criteria for Restart Required Actions Activities meeting the criteria below are designated " required for restart" and are included within the Readiness-for-Restart Schedule. Activities identified as necessary for longer-term success but not specifically required prior to authorization for restart will be included within the Performance Improvement Plan - discussed in Section XI of this plan.
Activities meeting the following criteria are deemed required for restart and are included within the Readiness-for-Restart Schedule and Readiness For Restart Worklist:
e an event, component failure, deficiency, or condition that could result in operation in an LCO action statement
- failure to perform a required surveillance test or other license requirement or meet a commitment to an outside agency 48 Rev.1
l !
- .
- conditions that have resulted in repetitive safety system equipment i
- failures -
i e potential licensing basis deficiencies requiring maintenance to restore j the plant to conforming conditions (i.e. deficiencies in safety-related or :
3 other qualified equipment, e.g. EQ, Appendix R or seismic) l
. e items that impact plant operability, raise an unreviewed safety question, l
- ' or indicate a discrepancy between the FSAR and as-built plant or an !
j operating procedure e deficiencies in configuration management programs processes, j
4 engineering analysis codes, or documentation that have or could have a j reasonable likelihood of Equipment not meeting its license or design
, basis
!~ e - conditions that may create an unacceptable potential for an unplanned i radioactive release to the environment or discharge effluent to the l l environment which is in excess oflimits l j' e items with work priorities 1 & 2, and specifically identified priority 3 items, in accordance with the work priorities defined in plant procedures
{
F '
i l B. Schedule Adherence and Review :
I l Once approved, the Readiness-for-Restart Schedule serves to communicate the !
l plan of activities required for authorization to restart. Each accountable group, i j I department, and individual is expected to ensure that the schedule accurately
[ reflects the necessary actions to accomplish the desired result. Line management
[ is expected to hold their personnel accountable for the accuracy and to the j completion of activities within the schedule.
4 i l A regularly scheduled progress meeting will be held to monitor and progress the schedule. The attendees will include the accountable individuals, groups, or departments associated with the scheduled activities and line management. Each j action due is expected to be completed and updated as such prior to or during this i meeting. Upcoming actions in jeopardy are expected to also be updated dunng or !
prior to this meeting. !
Remedial actions required to address jeopardized activities are expected to be submitted by the accountable department, group, or individual prior to failing to meet the schedule in accordance with the aforementioned revision process. Line management will hold accountable the schedule accuracy and as-scheduled ,
completion of required activities.
49 Rev.1 i
C. Schedule Distribution, Records, and Close-out The Readiness-for-Restart Schedule will be periodically updated. Updated schedules will be distributed as needed to accountable departments, groups, line management, oversight, and the NRC. Distribution of the updated schedule will be completed by the ORP Manager in accordance with a distribution plan approved by the Unit Director or designee.
Archive files will be established each update such that progress is readily retrievable. Perfonnance measures will be established by the Director of Restart i to accurately reflect schedule accuracy and adherence. Specific quality records for ;
activities requiring such will be maintained in accordance with the procedures governing the activity. The updates to the Readiness-for-Restart Schedule will be available for review but will not serve as a quality record for completion of !
contained activities.
l Following authorization for restart, the Readiness-for-Restart Schedule will be completed, and the Startup and Power Ascension Plan will be used to direct unit activities. A transition plan will be developed and approved by the Unit Director or designee to facilitate this transition.
Specific administrative details for development, review, approval, revision, progress monitoring, and record keeping for the Readiness-for-Restart Schedule are contained within approved plant procedures.
D. Operational Strategy In the early stages of the current shutdown, a problem developed with 2-SI-645, a LPSI injection valve. The specific problem with this valve is that it cannot be shut completely due to apparent internal binding. In order to work on this valve and inspect other LPSI injection valves, the reactor core must be offloaded to the Spent Fuel Pool (SFP). As a result, Unit 2 went to Mode 6 and completed a full core offload. While the core is removed from the vessel, and the refueling pool is full, major maintenance (including safety-related Train A/ Train B components),
and major modifications will be performed (planned major modifications are discussed below).
50 Rev.1
e Upon completion of the off-load workscope, a comprehensive testing program commenced. Virtually all 18 month, refuel frequency surveillances will be performed to verify the operability of systems and safety functions. Also, required post-modification and maintenance testing, as well as any required pre-operational system testing, will be performed to provide assurance of system functionality in compliance with licensing basis documentation.
Once all off-load system testing has been completed, the core will be reloaded, the reactor head will be reinstalled, and Mode 5 will be entered. Preparations will be made to fill and vent the RCS, draw a bubble and enter Mode 4 (commence a heat-up). Although a standard startup sequence will be followed, clearly the startup of
) Unit 2 will not be routine. As mentioned in Section III, Self Assessment, and l Section VII, Assessment of Restart Readiness, many management, third-party, and oversight assessments will be made at each step in the start-up sequence. In addition, the return of equipment and systems to service will be systematic, deliberate and controlled.
E. Special Testing and Inspection
-During performance of the above operational plan, testing will be performed on a variety of components. )
l Examples of planned testing include:
1
! l
- CEDM housing nozzle crack inspections
- RBCCW system full flow testing l
- RBCCW system flow balancing
- Radioactive waste ventilation flow balancing
- VOTES testing of 52 MOVs
- Spec 200 response time testmg
- NI noise testing j e 'B' HPSI pump curve verification 1
. EDG ventilation receive flow testing
- Service water heat exchanger performance testing 51 Rev.1
F. Major Modifications Examples of modifications that will be performed:
- Control Room Air Conditioning (CRAC) Modifications e Switchgear Cooling Modification
- Pressurizer Level Reg. Guide 1.97 Modifications for QA Power
. EDG 'A' & 'B' QA Ventilation System Damper Replacements e Containment Radiation Monitor Isolation Modification
. Hydrogen Sampling / PASS Design Modifications
- S/G Blowdown Radiation Monitor Replacement
- Re-power H2 Containment Isolation Valves G. Projected Readiness For Restart Schedule Milestones Mode 6 December 96 Core Offload January 97 CMP and System Outages Start February 97 Performance Improvement Plan Prepared May 97 Ready For ICAVP Start June 97 Core Reload July 97 Startup and Power Ascension Plan Prepared July 97 System Readiness Assessment Start August 97 - September 97 l Readiness For Restart Assessment August 97 l Readiness For Restart September 15,1997 i
H. Resources !
l The 1997 Unit 2 budget has been developed to support the ORP, Increased temporary staffing needs have been identified. This includes both on-site and off-site activities. Permanent resource requirements will be addressed as part of the 52 Rev.1 4
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j ORP requirement for Department Excellence Plans. The criteria for permanent I staffing is to have sufficient and well qualified resources necessary to operate and
- maintain the unit safety and in complacence with regulatory requirements.
i I. Contingencies l Neither the 1997 budget, nor the Readiness For Restart Schedule will have
- contingencies included even though it is recognized that emergent work is likely, i and that past work efficiency, quality and schedules adherence was low.
i Schedules will be revised as necessary. However, it is not likely that additional 4 resources over the 1997 approved budget can be made available. The Unit Officer will maintain the options to adjust priorities and reassign resources.
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XL Startup and Power Ascension Plan l
Purpose:
To ensure a safe and deliberate return to safe and reliablepower operationfollowing the extended shutdown period.
The Startup and Power Ascension Plan will be a detailed schedule of actions taken following restart authorization to ensure careful and deliberate startup and power ascension. This Plan is in the form of a detailed schedule of activities that begin at restart authorization and conclude at stable full-power operations. This plan is necessary to ensure a careful and deliberate return to power operations following the extended shutdown period. Activities within this schedule include: 1 1
I euGeneralf0perating Procedures; er . ,v .
- TCorrec'ive'and t PrefentivsMsintenancebe ,7 1 .- . < <
- WLind Management [OS$ervaiio@Self-Assessmenti ,
,,, [. . *Tbc *
- M, Assessment: Hold-Points?
a 3.. . --..s- .
ofSurveillance Testing ' Procedures J -
@- , , n, , g % pu , , l
- EP6st Maintenanhe'and N$$Modificati$niTesting?
1 l
i The development, review, and approval of the Startup and Power Ascension Plan will be completed prior to the completion of the Readiness-for-Restart Schedule. i
[XI-1] l 1
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XII. Performance Improvement Plan
Purpose:
To provide the long-term improvement plan and schedule to meet the j highest standardsfor the conduct ofsafe and reliable operations.
A. Introduction The Performance Improvement Plan will be developed, reviewed, and approved prior to restart..
The plan will contain the details and action steps to complete both programmatic improvements and plant projects to meet the longer term goals of safe, reliable, economic, and environmentally sound nuclear power operation. Progress on this plan will be closely monitored and reported frequently.
B. Performance Improvement Initiatives Performance Improvement Initiatives will include those programmatic improvements necessary to support the longer-term goals (beyond restart). Each Performance Improvement Initiative will have an associated schedule of action steps necessary for success. Examples ofinitiatives will cover programmatic areas ofimprovement including Nuclear Oversight effectiveness, improvements in Maintenance Programs, Backlog Reductions, and Steffing Development.
Initiatives will be reviewed and approved by station management to ensure that appropriate resources and support are provided to effect completion. Progress on the schedule of these activities will be frequently communicated to the employees, senior management, the community, and the regulator.
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C. Plant Improvement Projects Plant Improvement Projects will include those physical changes resulting in improvements to plant systems, equipment, and facilities necessary to support the longer-term goals (beyond restart). Projects will have an associated schedule of action steps necessary for success. Examples of Plant Improvement Projects include the continuation of plant coatings, upgrades of material conditions, plant efficiency modifications, and facility upgrades. Plant Improvement Projects will be reviewed and approved by station management to ensure that appropriate resources and support are provided to effect completion. Progress on the schedule of these activities will be similarly communicated to the employees, senior management, the community, and the regulator.
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Attachment ORP Assignments and Deliverables Commit Owner Description Number
] II-la Assistant Unit Director - Develop and implement Unit 2 Nuclear Safety j Nuclear Safety Policy (Work with Mario Bonaca) i Il-lb Corrective Actions Conduct self-assessment to ensure Unit 2 Nuclear
- Manager Safety Policy expectations are embraced by Unit 2 organization 11-2 Unit Officer Recovery Organizational changes 11-3 Operations Manager Develop and rollout Operations Department standard for reactivity management I 11-4 Manager of Operations / Complete response for SOER 96-01 Unit Dir. Staff Assistant 11-5 Operations Complete response and implement actions for )
Managerfrech Support SOER 96-02 ,
Manager l II-6 StaffAssistant Coordinate 10CFR50.59 training schedule for aii- I applicable Unit 2 staff ;
l 11-7 Assistant Unit Dir. - Develop schedule and agenda for Human Nuclear Safety Performance Stand-downs 11- 8 I&C Manager Perfonn benchmarking assessment at well-performing plants 1 II-9 Procedure Group Implement Station Qualified Review (SQR)
Manager Program 11-1 0 Engineering Director Establish appropriate linkage between operability determinations and bypass jumpers with the 50.59 process 11-1 1 Engineering Director Designate peer review group for 50.59 ;
Unit Director I 11-1 2 Unit Officer Set and communicate expectations and standards ;
for resolution of employee concerns 11-1 3 Unit Director Complete employee familiarization with 57 Rev.1 1
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i Engineering Director Employee Concerns Program 11-1 4 Unit Director Complete management training on expectations Engineering Director and standards for resolving employee concerns, as well as, the Employee Concems Program i 1
1
- Il-15a Restart Director Establish an AITTS data management j guideline. Hold Unit 2 AITTS workshop.
- II-15b Corrective Actions Perform self-assessment of AITTS effectiveness Manager j 11-1 6 Corrective Actions Eliminate AITTS backlog of" notify" items l Manager Licensing Director 11-1 7 Operations Manager Develop Level 1 for excellence plan Maintenance Manager implementation WP&OM Manager I&C Manager 2
HP Supervisor j Engineering Director i Corrective Actions )
Manager I l
11-1 8 Assistant Unit Director - Train Department Coaches Nuclear Safety 11-1 9 Assistant Unit Director - Implement Observation Training Nuclear Safety 11-2 0 Assistant Unit Director - Establish a Level 1 Management Accountability i Nuclear Safety System !
l 11-2 1 Assistant Unit Director - Establish stretch goals for UPI and "Workoff" Nuclear Safety curves (also see II-3) i II-22 Unit Director Establish expectation of"no missed Engineering Director commitments." ;
11-23 Unit Director Establish schedule for facilitated working Engineering Director sessions to introduce and reinforce behavioral ;
characteristics for first line and above supervisors.
11-24 Assistant Unit Director - Develop schedule and methodology for Nuclear Safety benchmarking trips 11-2 5 HRG Representative Provide feedback to management team (group and individual) from supervisory assessments 58 Rev.I
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11-2 6 Unit Officer Communicate standards and expectations to Unit Director employces in accordance with the Unit 2 Engineering Director Communications Plan CMP Manager Tech Supp;rt Manager Maintenance Manager I&C Manager WP&OM Manager HP Supervisor Operations Manager Assistant Unit Director -
Nuclear Safety 50.54(f) Acting Supervisor II-27 Corrective Actions Establish ownership of corrective action program Manager within line organization through revision of Corrective Action Program procedure II-28a Unit Director Establish expectations for timely completion of Engineering Director investigations and corrective actions II-28b Corrective Actions Establish goals and trends for corrective actions Manager II-29 Corrective Actions Establish a core group of root cause evaluators Manager 11-3 0 Assistant Unit Director - Establish the organization, reporting structure, Nuclear Safety procedural requirements and facility support ;
needed to implement the corrective action program !
II-31 Corrective Actions Establish indicators and goals for determining Manager effectiveness of the Corrective Action Program 1
11-3 2 Restart Director Establish a backlog review team, perform backlog j reviews 1 11-3 3 Corrective Actions Review a sample of previously closed CRs for Manager / adequacy Perf. Evaluation Mgr.
l II-34 Assistant Unit Director - Establish Single Technical Procedures Group l Nuclear Safety 11-3 5 Procedure Group Identify and track Technical Procedure revisions Manager required for restart readiness 11-3 6 Procedure Group Complete EOP upgrade l Manager 59 Rev.1
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l 1I-37 Procedure Group Complete AOP upgrade Manager II-38a Procedure Group Establish plan to review technical procedures Manager Il-38b Procedure Group Implement plan for technical procedure review l Manager l 11-3 9 Procedure Group Review and revise Operating procedures to
- Manager ensure water hammer events are precluded l
! 11-4 0 Procedure Group Complete Severe Accident Management Manager Guideline development 11-4 1 Licensing Director Develop schedule for Improved Standard Technical Specifications Ill-1 Assistant Unit Director - Provide / set standards and expectations for self-Nuclear Safety assessment Ill-2 Assistant Unit Director - Develop Unit Annunciator Window Program Nuclear Safety III-3 Assistant Unit Director - Develop and Implement a Management BackshiR Nuclear Safety Assessment Program Ill-4a Assistant Unit Director - Complete development of UPIs for ORP (see Nuclear Safety Also I1-23)
III-4b Assistant Unit Director - Publish and review on a monthly frequency UPIs Nuclear Safety for ORP 111-5 Assistant Unit Director - Development and Implement Human Nuclear Safety Performance Enhancement Program Ill-6 Corrective Actions Conduct periodic self assessments for Corrective Manager Actions III-7 I&C Manager Conduct periodic self assessments of Safety Evaluations (10CFR 50.59) Program and Process III-8 I&C Manager Conduct periodic self assessments for PORC effectiveness III-9 Procedure Group Conduct periodic self assessments for technical Manager procedure adequacy 111-1 0 CMP Manager Conduct periodic self assessments for Configuration Management 60 Rev.I
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I III-l1 Corrective Actions Conduct periodic self assessments for adherence l 4
Manager to Surveillance Testing schedule and :
requirements l
- III-12 Operations Manager Conduct periodic self assessments for conduct of !
operations 111-1 3 Assistant Unit Director- Provide self assessment training to applicable i Nuclear Safety / personnel :
- Nuclear Training !
- Contact !
j III-14 Assistant Unit Director - Conduct independent Organizational Readiness [
Nuclear Safety Assessment (Use INPO and NRC 0350 criteria) i f
i i 111-1 5 Unit Director Develop a plan for effective use of Nuclear !
Perf. Evaluation Mgr. Oversight for periodic assessment of daily j Eval. & Analysis, activities, processes, and programs !
!! Group !
a III-16 Unit Director Work with Nuclear Oversight to ensure proper i Engineering Director staffing III-17 Unit Director Develop a plan to ensure proactive, timely ;
Engineering Director resolution ofissues and findings from audits and j
! surveillances j j III-18 Assistant Unit Director - Review progress of actions to meet INPO 1996 j
! Nuclear Safety findings. Prepare INPO six-month status report i
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- III-19 Unit Officer Request and set-up an INPO lead operational l i readiness assessment prior to restart j l
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- 111-2 0 Unit Director Compile evaluation for use ofINPO reverse l .
Engineering Director loanees or direct utility loanees.
III-21 Unit Director Determine scope and schedule for INPO assistance visits.
l
. IV-1 Licensing Director Implement required actions to ensure timely
, response to NRC violations. Develop schedule to achieve timely compliance i
IV-2 Unit Director Identify actions necessary to ensure full Engineering Director compliance with 10CFR50 Appendix B for 4
Oversight Audits 61 Rev.1
IV-3 Assistant Unit Director - Open unresolved items (UIRs) and LER 1 Nuclear Safety commitments have been addressed prior to restart 1 IV-4 Assistant Unit Director - Open Bypass Jumpers, Operability Nuclear Safety Determinations, and NCRs not resolved prior to startup are screened against 10CFR50.59 l IV-5 Operations Manager Opdn safety related AWOs not addressed prior to l restart have been assessed by an Operations SRO and PORC IV-6 Engineering Director Complete actions to ensure compliance with Licensing Director 10CFR50, Appendix R for Thermo-Lag i l
IV-7 Licensing Director Provide status of commitment responses due dates in daily unit status report IV-8 Licensing Director Develop plan and intemal structure to ensure submittals made on time V-1 CMP Manager Develop CMP Plan and Schedule V-2 CMP Manager Perform periodic independent technical review of CMP V-3 Engineering Director Establish ownership for system design and technical programs V-4 Engineering Director Establish Engineering Assurance Program V-5 Engineering Director Provide plans for Engineering Drawing Backlog V-6 Engineering Director Ensure design control process adequately l considers changes to required administrative and tech programs VI-l Restart Director Complete initial categorization process VI-2a WP&OM Manager Complete work flow process changes i
VI-2b WP&OM Manager Complete self-assessment of work flow process VI-3 Maintenance Manager Establish WIN Team ;
VI-4 Maintenance Manager Staff Maintenance / Component Engineer positions i and communicate roles, responsibilities, and expectations 62 Rev.1 l
VI-5 Project Engineering Establish a Project Management / Engineering Manager / group to support modification work Project Manager VI-6 Work Planning & Establish housekeeping standards and Program Maintenance Manager VI-7 Work Planning & Develop schedule for periodic housekeeping Maintenance Manager stand-down VI-8 Lead - Work Planning Remove all unauthorized / improperly stored !
& Maintenance equipment and materials from unit Manager Operations Manager I&C Manager Maintenance Manager HP Supervisor VI-9 Unit Director Complete required design change modifications Engineering Director VI-10 WP&OM Manager Complete required Preventive Maintenance
~ l VI-l 1 WP&OM Manager Complete required Corrective Maintenance l VI-12 Maintenance Manager Develop Unit Painting Program VII-l Operations Manager Ensure Operations Department Excellence Plan incorporates elements from ORP VII-2 Operations Manager Develop set of Operations Standards
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VII-3 Operations Manager / Train on Operations Standards j Nuclear Training Contact l
VII-4 Operations Manager Review Tech Spec Surveillance Procedures to l Tech Support Manager ensure compliance with Tech Specs Vll-5 Operations Manager Conduct unit walkdowns to verify no HP Supervisor uncontrolled temp alterations or postings and i l
Tech Support Manager Operator Aids exist VII-6 Operations Manager Conduct unit walkdowns to ensure in-plant Maintenance Manager storage meets requirements j HP Supervisor I&C Manager i
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Vll-7 Operations Manager Conduct Ops and System Engineering walkdowns Tech Support Manager for materiel condition issues HP Supervisor i
VII-8 Operations Manager Complete independent (extemal) assessment of conduct of Operations VII-9 Corrective Actions Develop plan for effective self assessment of Manager relevant industry operating experience !
- Nuclear Safety Engineering VII-10a Assistant Unit Director - Develop and implement an operational readiness Nuclear Safety self-assessment process (pre-INPO/ pre-IPAP ,
methodology) l VII-10b Unit Director Conduct operational readiness self-assessment i Assistant Unit Director - prior to each mode change and significant plant Nuclear Safety (lead) configuration change Operations Manager Maintenance Manager . )
I&C Manager WP&OM Manager HP Supervisor !
50.54(f) Acting Supv.
Tech Support Manager VIII-l Assistant Unit Director - Identify UPIs for restart readiness Nuclear Safety VIII-2 Perf. Evaluation Mgr. Complete independent review of ORP
- VllI-3 Same as VII-10B Specific departmental operational readiness i assessments will be performed prior to mode '
changes Vill-4 Perf. Evaluation Mgr. Perform independent assessment of restart readiness VIII-5 Same as III-19 Request independent (external) restart readiness 1 assessment VIII-6 Tech Support Manager Affirm that Maintenance Rule Group 1 and 2 CMP Manager systems are ready for restart XI-1 Restart Director Prepare Startup and Power Ascension Plan 4
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