ML20151Y599

Rev 3 to LaSalle County Station Restart Plan, for Unit 2 Only

ML20151Y599
Person / Time
Site:	LaSalle
Issue date:	09/14/1998
From:	Dacimo F, Dobbs J COMMONWEALTH EDISON CO.
To:
Shared Package
ML20151Y591	List: ML20151Y586 ML20151Y599
References
PROC-980914, NUDOCS 9809180288
Download: ML20151Y599 (14)

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! lisSalle1 County:[Stdtion-

?ResthFtLPihn LRevision'31(Unit 2'Only)-

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Issued:) l'Septernber14fi998L ApproVsdi M c:

' g . Dobbs, Uni (2 Restart Manager J' ~

-:( iMqt

- F; R.:iDacimo, _ Site Vice President

88' 88888 M@h$ga P

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LaS:lle C:unty stati:n Unit 2 R: start Plan REVISION 3 l

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t l TABLE OF CONTENTS

1. B AC K G R O U N D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1. P l a n P u rpo s e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2 1.1.1. Re st a rt P la n . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 l 1.1.2. P o st-Rest a rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1.3. Business Plan and Other Long-Term Planning ......... ... ..........2 )

2. RO LE S AN D R ES PON SIBILITIE S ............................................................... 3 i i

2.1. Site Vice President . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . .........3 2.2. Senior Vice President, N GG. . . . .. . . . . .. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.3. Station Manager ........ . ..... .. . .. ..... . . . . . . . . . . . . . . . . . ......3 2.4. U nit 2 Re sta rt M ana ger .. . . . . . . . . .. .. . . . . . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 ,

2.5. Restart Issue Review Committee (RIRC) ............. . . .. .. . ..... .. .. ...4 j

3. RESTART PROGRAM AND REQUIRED ACTlONS .................................... 4 3.1. Restart Issue identification and Screening... ... . ... . .. .... ..5 3.1.1. Restart issue Identification Criteria............. . ....... . . . . . . . . .5 3.1.2. Re start Action P lan s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.2, Wo rk C om pl e tion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.3. Restart and Operational Readiness Assessment. . .. ........ .............. .... 7 3.3.1. Departmental Restart Readiness Assessments....... . . ..... .. . ..... 7 3.3.2. S ystem Re adines s Reviews. . . . . . ... . . . . .. . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . 7 3.4. Re start Te st Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......8 3.5. RIRC Restart Recommend stion ... . ...................... . . .. .... ................8 3.6. N uclear Oversight. . . . . . .. . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . .. ....8 3.7. Nuclear Generation Group (NGG) Assessment.... . ... . . . .9 3.8. Chief Nuclear Officer (CNO) Restart Authorization.. . . . . . . . . ..9 3.9. Power Ascension Plan...... .. .. .................. ....... ... . .. ...9 ATTACHMENT A RESTART ACTION PLAN CLOSEOUT ASSESSMENT PACKAGE IMPLEMENTATION, FORMAT AND CONTENT

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, Lasille C:unty Stati:n l Unit 2 R: start Plan REVISION 3 Page 1

1. BACKGROUND.

On July 2,1996, the Nuclear Regulatory Commission (NRC) issued a Confirmatory l

Action Letter (CAL) regarding potential blockage on non-essential service water strainers. On September 20,1996, Commonwealth Edison Comoany (Comed) shut down LaSalle Station, Unit 2 for planned Refueling Outage L2R07. On September 22, 1996, Comed shut down LaSalle Unit 1 to repair the Number 4 Turbine Control Valve 4TCV (forced outage L1F35). While these activities were occurring, the NRC was l

performing a Service Water System Operational Performance inspection. The NRC inspection, which was completed on September 24, 1996, identified, among other  ;

things, an operability concern with the Unit 1 Residual Heat Removal (RHR) Service '

Water heat exchanger. Subsequently, Unit 1 was placed in cold shutdown on l

September 26,1996. Comed placed Unit 1 in cold shutdown pending resolution of the l

RHR issue. 1 i

After the shutdown, Comed determined that neither unit should restart prior to resolution of issues identified by Comed and the NRC related to hardware (material condition), human performance, corrective action process, and engineering support and design deficiency. The NRC issued an April 14,1997, supplemental CAL, which  !

included Comed's agreement to:

l Develop a Restart Plan for LaSalle County Station to address corrective actions

for the performance deficiencies referenced in the NRC's inspection reports and CALs, Comed's Independent Self Assessment Team (ISAT), and LaSalle's own

, assessments, and transmit that plan to the NRC for formal docketing. Comed was to establish quantitative and qualitative criteria for assessing and monitoring the effectiveness of its corrective actions for each area identified in the Restart i Plan. The plan also was to discuss how issues that would not be completed prior to restart would be identified and assessed to demonstrate why restart was acceptable with the action not yet completed.

On December 16,1997, the NRC issued a Manual Chapter (MC) 0350 Restart Action Plan to guide NRC inspections for restart readiness. Extensive restart readiness inspections were conducted by the NRC to confirm that MC 0350 issues had been satisfied. On July 24,1998, Comed forwarded to the NRC a letter certifying that all CAL commitments had been satisfied. Also on July 24,1998, the Nuclear Regulatory Commission issued a letter to Comed agreeing with this position. The NRC letter l noted that MC 0350 inspection and evaluation activities were complete and that Comed l had satisfied MC 0350 and CAL requirements for LaSalle, Units 1 and 2. Based on this

NRC conclusion, Revision 3 of the LaSalle Restart Plan has been modified to focus

only on Unit 2 activities that must be performed to demonstrate that:

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, La8:lle C:unty Stati:n Unit 2 Restart Plan REVISION 3 Page 2

1. Material condition activities for Unit 2 have been satisfactorily performed and that Unit 2 systems are ready to support restart; and

2. Departmental readiness is adequate to support dual unit operation.

The LaSalle and Nuclear Generating Group staff has conducted reviews and evaluations of the recovery and restart of Unit 1. A significant number of lessons leamed have been identified that will result in process and performance improvements to both Unit 2 and other i future outages.' These are being factored into the recovery of Unit 2. Based on the above, activities that were in Revision 2 of the LaSalle Restart Plan, but are not necessary for the restart of Unit 2, have been deleted. i I

1.1. Plan Purpose j The above-described Comed activities and agreements with the NRC are an intricate l part of LaSalle's Restart Plan and its associated methodology. In that light, the l purpose of the LaSalle County Station Unit 2 Restart Phm is to summarize the actions and controls that will be implemented by Comed to ensure that Unit 2 material condition is adequate to support restart and reaffirm departmental readiness for dual unit operation.

I 1.1.1. Restart Plan The Unit 2 Restart Plan integrates key site activities associated with the restart of LaSalle County Station Unh .2, and provides a communication and management tool. l Although focused on Unit aestart, tt.o Unit 2 Restart Plan also briefly discusses the j l results of LaSalle Unit 1 restart activities to ensure that performance levels reached to i

support re 'rt of Unit 1 have not deteriorated during plant operation.

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l 1.1.2. Post-Restart L Like Unit 1, activities, deficiencies, and issues identified during the shutdown period, which will not be' completed prior to restart are dispositioned by the Restart issues Review Committee (RIRC) and entered into the appropriate tracking system.

1.1.3. Business Plan and Other Lona-Term Plannina ,

l LaSalle's 1998 Business Plan addresses short-term actions that are essential for maintaining safe and economically competitive performance at LaSalle. The 1999-2001 Business Plan is currently under development. In addition to site-specific restart activities, the Nuclear Generation Group (NGG) also is implementing the Strategic

Reform initiatives (SRis), which describe Comed's long-term performance vision as a j successful participant in a competitive electric utility industry.

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. LaStile County Stati:n

[ Unit 2 R: start Plan

REVISION 3 i Page 3 i

l 2. ROLES AND RESPONSIBILITIES LaSalle managers and supervisors are responsible for ensuring that Unit 2 is ready for

restart. There are restart-related roles and responsibilities that will augment routine i duties and warrant specific attention in this plan. In that light, the following discussion j

summarizes primary roles and responsibilities of key management personnel involved i in ensuring Unit 2 restart readiness.

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! 2.1. Site Vice President ll The Site Vice President has overall responsibility for LaSalle Station, Units 1 and 2, i and as a result, is accountable for successful implementation of the Unit 2 Restart Plan. .

In addition to ensuring that the Restart Plan provides a sound methodology for  !

'4 demonstrating restart readiness, the Site Vice President also is responsible and

! accountable for ensuring that LaSalle restart efforts are consistent with Comed i j Corporate initiatives.

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! The Site Vice President is responsible for recommending restart of LaSalle Unit 2 to the l Chief Nuclear Officer (CNO). The Site Vice President will make this startup j: recommendation primarily based on the overall recommendation of the Unit 2 Restart lssue Review Committee (RIRC). The Site Vice President will then certify to the CNO i that LaSalle Unit 2 is ready for restart.

i- 2.2. Senior Vice President. NGG

!' . Additional oversight will focused on Unit 2 outage activities during Unit i restart, restart testing

' and initial operation for the duration of the Unit 2 outage. The Senior Vice President, Nuclear Generation Group (NGG) is responsible for the day to-day corporate oversight of Unit 2, the

! Unit 2 outage organization, and financing of significant Unit 2 activities. He will direct daily

> onsite activities through the Unit 2 Restart Manager. The Senior Vice President, NGG, is also F responsible for coordinating activities, as needed, with the Site Vice President, LaSalle Station.

2.3. Station Manaaer The Station Manager maintains the Technical Specification responsibilities for overall unit safe operation and shall have control over those onsite activities necessary for ,

safe operation and maintenance of the plant. The Station Manager will interface with Unit 2 activities as the continuing chairman of the Restart issue Review Committee j (RIRC) (now focussed on Unit 2), and through that function, will ensure that: (1) Unit 2 activities do not have an adverse impact on Unit 1; and (2) the level of safety and rigor  ;

implemented during the Unit 1 restart will not be diminished during Unit 2 activities. As j Chairman of the RIRC, the Station Manager also provides a periodic review and final assessment of Unit 2 restart readiness through RIRC activities.

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. LaS:lle C::unty Stati:n Unit 2 R: start Plan l REVISION 3 Page 4 l 2.4. - Unit 2 Restart Manaaer l

The Unit 2 Restart Manager is responsible and accountable for ensuring that LaSalle Unit 2 material condition and process / program readiness attivities are satisfactorily

! completed prior to certification to the Site Vice President that Unit 2 is ready for restart.

In this capacity, the Unit 2 Restart Manager is responsible for coordinating Unit 2 restart activity performance with the RlRC and promptly identifying to the Senior Vice President, NGG, Site Vice President and Station Manager if any change to the restart criteria described in section 3.1.1 is proposed. As described above, to reduce the burden on the LaSalle Station Site Vice President, during the Unit 2 outage the Unit 2 Restart Manager will report primarily to the Senior Vice President, NGG. The Unit 2 Restart Manager is responsible for on-site coordination of Unit 2 restart activities among Comed organizations and reporting the status of these activities to the Site Vice President on a periodic basis. The Restart Manager is accountable for meeting Restart Issue Review Committee (RIRC) requirements for restart of Unit 2.

2.5. Flestart Issue Review Committee (RIRCJ The RIRC is a management team chaired by the Station Manager, and composed of the Operations Manager, Maintenance Manager, Engineering Manager, and Unit 2 Restart Manager. This Committee has primary responsibility for determining whether issues / items / activities satisfy restart issue criteria. When it is determined by the Unit 2 Restart Manager that all required restart activities have been satisfactorily implemented, along with satisfaction of other performance measures, as deemed appropriate, the RiRC will determine whether the plant is ready for restart and provide its recommendation to the Site Vice President. The Plant Operations Review Committee is used for reviews as required by Nuclear Station Procedures.

3. Restart Proaram and Reautred Actions The Restart Program consists of several key attributes including Restart issue Identification and Screening, Work Completion, Restart and Operational Readiness Evaluation, Restart Testing and Restart and Power Ascension. Each of them activities is described below.

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!. LaS:lle C:unty Station Unit 2 R: start Plan REVISION 3 l Page 5 3.1. Restart issue identification and Screening

, Problem identification Forms (PlFs), Action Requests, Engineering Requests, l Procedure Change Requests, Work Requests, self-assessments and programmatic review findings, and routine Corrective Action Program trend PIFs will be screened

, utilizing restart criteria. The Unit 2 Restart Manager maintains the integrated schedule l that includes a comprehensive listing of activities which have to be performed prior to l restart.

l 3.1.1. Restart Issue identifk ation Criteria

. Resolves a nuclear safety or operability issue.

. Eliminates or mitigates a predictable component failure, deficiency, j condition, or operator workaround that could result in an operational failure, entry into an LCO, or could challenge performance of system functions important to safe and reliable operation. ,

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. Resolves a deficiency or condition that could result in a failure, or the i inability to satisfy a required surveillance test during the current outage, or l during the subsequent operating cycle. 4 l

l . Resolves identified procedural deficiencies that:

a. affect the adequacy or validity of required surveillances, or

b. have resulted in repetitive work-around situations, or

c. challenge the ability of a system to perform functions important to safe and reliable operation.

. Restores degraded critical components, or corrects conditions that could result in a plant transient, unscheduled load reduction, or shutdown.

. Resolves conditions that have resulted in repetitive equipment failures.

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. Resolves licensing or design basis discrepancies in safe , ~related or other Technical Specification-required equipment and/or resolves substantive licensing and design basis document discrepancies. (Documentation deficiencies that have no safety impact may be completed as short-term action items with appropriate justification, provided that the actions are s

formally scheduled and tracked to, completion.)

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.. Las lle C:unty Stati n Unit 2 R; start Plan REVISION 3 Page6

. Eliminates conditions that may create a potential excessive personnel radiation exposure, an unplanned radioactivity release to the environment, or a discharge of effluent in excess of regulatory limits. 1 I

e Reduces cumulative deficiencies, backlogs, or conditions that, in the I aggregate, could have a significant negative impact on nuclear or personnel l safety, operability, or reliable plant operation. (Not applicable to individual l work items.)

l e Required to address organizational, training, programmatic, or process i deficiencies that have a reasonable probability of affecting safe and reliable l plant operation. ]

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!. These restart issue identification criteria are incorporated into the LaSalle Station Outage Scope Control Guideline, WC-302. Occasionally, issues may satisfy restart criteria that may not be necessary from a safety perspective to be completed prior to restart. Under these circumstances, WC-302 provides a process for removal of an l

issue from outage scope.

L l Restart issues primarily have evolved from the System Functional Performance Review '

l (SFPR) Program and LaSalle self-assessments. Other potential restart work items are being identified from several sources including the Corrective Action Program, Action i Requests, Work Requests, Engineering Requests, Design Change Roquests review of backlogs, system readiness reviews, internal and external assessments and personnel l and plant performance trends.

Issues raised through these programs are screened to determine restart status and will be presented to the RIRC as appropriate.

3.1.2. Restart Action Plans The Unit 2 Restart Manager or RIRC may direct the development of new Restart Action Plans if it is determined that specific Unit i Restart Strategy objectives are not being satisfied or for any identified significant emerging issues. Should the need arise, Action Plan Sponsors will be designated to address the specific performance issue. It is l not anticipated that Unit 1 Action Plan Strategies will be reopened or appended for Unit 2 activities. Action Plan activities associated with Unit 2 have been transferred to the Nuclear Tracking System (NTS). NTS will track implementation of necessary actions to support Unit 2. The format and method for implementation for Restart Action Plans is f provided in Attachment A. The results of any new Action Plan implementation would be i

reviewed by the RIRC as part of its integrated assessment of restart activities. Based

( on the integrcled assessment, the RlRC may recommend restart with Action Plan i

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. LaSille Ccunty Stati:n ,

Unit 2 R: start Plan REVISION 3 Page 7 performance measures not being met. The justification for this recommendation would be documented as part of the RIRC's integrated assessment.

l 3.2. Work Completion Work required for Unit 2 restart is completed under the direction of line management using current plant processes and approved procedures for execution and control of l

work. Implementation schedules are established and managed by the Unit 2 outage organization for plant hardware-oriented activities and major non-hardware activities.

Work completion is documented consistent with plant process and procedural requirements with oversight for effective job completion provided by line management and oversight organizations.

3.3. Restart and Operational Readiness Assessment Restart and operational readiness is determined through the performance of Departmental Restart Readiness and System Readiness Assessments. Since the departmental readiness assessments already have been performed to support Unit 1 restart, the Unit 2 activity only involves confirmation that readiness-related conclusions reached at that time still apply when Unit 2 restarts and that departments are ready to support dual unit operation. If the Unit 1 readiness conclusions do not remain valid, additional assessments and determinations of appropriate corrective actions will be conducted and presented to the RIRC.

3.3.1. Departmental Restart Readiness Assessments Department Restart Readiness Assessments will be performed to assure that departments are ready to support dual unit operation. These assessments will minimally include a review of:

. Restart issues

. Human performance

. Processes and programs (focused on Unit 2 restart and dual unit operation)

. Backlogs 3.3.2. System Readiness Reviews System Readiness Reviews performed to support Unit 2 restart will be similar to those l performed on Unit 1. These reviews will be performed by relevant System Engineers to l ensure that:

. All safety-significant issues, individually or in the aggregate, have been i adequately addressed by restart activities.

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. La8:lle County Statlin Unit 2 R: start Plan REVISION 3 Page8 e Systems that have been placed in lay-up during the current outage have been made operationally ready.

. Technical Specification surveillances are current and/or appropriately scheduled.

. All necessary system components are operable.

System Readiness Review results will be provided to the RIRC to support its restart 3 readiness review.

3.4. Restart Test Proaram The Unit 2 restart test program will be based on the Unit 1 experience, as modified by 4

lessons learned and unit-specific differences. Post-restart performance of Unit 1 also will be considered to determine if scope expansion is warranted.

The operability of the LaSalle plant systems and their capability to perform required l l

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safety function (s) requires validation due to prolonged plant shutdown and extensive '

modifications. The Unit 2 restart test program will ensure that plant systems are 1 capable of meeting the safe shutdown requirements. The restart test program also will

. test selected non-safety-related systems required for plant operations. The restart l procedures will use existing plant surveillance procedures whenever possible. j 3.5 RIRC Restart Recommendation I

When it is determined by the Unit 2 Restart Manager that all required restart activities I have been satisfactorily implemented, along with satisfaction of other performance

measures, as deemed appropriate, the RIRC will determine whether the plant is ready

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for restart. Additional input regarding restart readiness, personnel, and work processes may be obtained from the Plant Operating Review Committee, independent oversight organizations such as the Nuclear Safety Review Board, Nuclear Oversight, and from other inputs at the discretion of the RIRC. The end result of these activities will be

presentations on restart readiness to the RIRC. The RlRC, after being satisfied with restart readiness, will recommend Unit 2 restart to the Site Vice-President. i Nuclear Overslaht 3.6 Nuclear Oversight will perform an independent assessment of restart readiness and 1 certify plant restart readiness to the Manager of Nuclear Oversight. The Manager of Nuclear Oversight then certifies restart readiness to the Chief Nuclear Officer (CNO).

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l'. Lasslie C:unty Stati:n i Unit 2 R: start Plan l REVISION 3 i Page9 3.7. Nuclear Generation Group (NGG) Assessment i The CNO will consider the results of a NGG assessment of restart readiness. To j support this effort, a Corporate Nuclear Review Board (CNRB) will be formed to ensure that a comprehensive readiness review is conducted. The Corporate assessment will l look at a broad set of issues beyond those included in the LaSalle Restart Plan. Based i f

on this review, the CNRB certifies restart readiness to the CNO.

. 3.8. Chief Nuclear Officer (CNO) Restart Authorization i When the Site Vice President concludes that the plant is ready for restart, he will

, request authorization for restart from the CNO. The CNO considers the Site Vice

} President's recommendation along with the results of the Nuclear Oversight Assessment, the Nuclear Generation Group Assessment, and an independent l Assessme .it (if determined to be necessary) to reach a conclusion regarding restart i readiness. Once a determination has been made that restart is appropriate, the CNO

- and/or Site Vice President will inform the NRC of the intent to restart Unit 2.

! 3.9. Power Ascension Plan i

l Concurrent with the development of final restart readiness actions is the development

of a Restart and Power Ascension Plan. This Plan ensures that plant hardware is 4

operational and personnel are prepared to operate the plant after the current outage.

The Restart and Power Ascension Plan transitions the plant (hardware) and personnel

from shutdown to operational status. The Unit 2 Restart and Power Ascension Plan will be based in part, on lessons learned during Unit 1 power ascension.

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. La8:lle C:unty Station i Unit 2 R: start Plan REVISION 3 j Attachment A, Page 1 l l

ATTACHMENT A RESTART ACTION PLAN CLOSEOUT ASSESSMENT PACKAGE ,

IMPLEMENTATION. FORMAT AND CONTENT l

! Restart Action Plan Implementation A. Restart Action Plan Soonsor Responsibilities:

. 1. If Restart Action Plans are assigned, their approach to issue resolution will l be similar to that used to support Unit 1 restart readiness determinations.

These Sponsors will work with Station management to develop Action Plan Strategy objectives and appropriate performance measures to resolve restart issues identified in the manner described in Unit 2 Restart Plan Section '

3.1.2. Restart Action Plan Sponsors will be responsible and accountable for ensuring that assigned Action Plans are developed and implemented which  !

satisfy the underlying Action Plan objectives.

2. The Restart Action Plan Sponsors also will oversee day-to-day implementation of their respective Action Plans and coordinate the efforts of individual Action Plan and item owners. They also are responsible for ensuring that Restart Action Plan documentation packages are auditable, adequately address Restart Action Plan objectives, and are consistent with the format described below.

B. Restart Action Plan implementationn

1. An Action Plan is considered implemented when:

e action plan steps have been completed, and e performance measures are being met or it reasonably appears that either the strategy or the strategy along with other corrective actions will satisfy strategy performance measures prior to restart j 2. It may be permissible to not complete action plan activities prior to restart, if l those activities can be justified as being not specifically relevant to fulfilling performance measures. These activities will be documented as exceptions in

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the Action Plan implementation document package. These exceptions must l be approved by the Unit 2 RIRC.

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. LaS:lle County Ctati:n Unit 2 R: start Plan REVISION 3 i Attachment A, Page 2 Action Plan Strateov Closeout Assessment Packane Format and Content i

A. Introduction and Summary:

1. Describe the nature and scope of the restart issue (s), summarize why the subsequent actions achieve the desired objective and resolve the associated L issue (s), and confirm that such actions satisfy the applicable performance measures / standards. l l l l B. Discussion of Action Steos: l l

1. Describe actions taken to close out/ implement each Action Plan i

2. Explain why actions envelope the " extent of condition" C. Results: l l 1. Discuss demonstrated performance improvements (in general) i  ;

2. Apply performance measure (s)/ standard ((s) and describe measurable l

indications of performance improvement (use performance indicator results, etc.)

I D. Follow-up Actions:

l 1. Identify actions to ensure continued improvement

2. List actions carried-over into post-restart (include discussion of associated tracking mechanism)

! E. Post-Imolementation Evaluations:

Each Action Plan implementation package shall have a post-implementation L evaluation strategy. This strategy will:

l 1. Ensure that issues identified after plan implementation, but before unit j restart, are satisfactorily addressed consistent with the Restart Action Plans l

L 2. Include a periodic review by Action Plan owners of relevant Corrective Action Program documents, including Problem identification Forms, Procedure Change Requests, Work Requests, self-assessments and programmatic review findings, and routine Corrective Action Program issues I

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!* , LaS_Ile C unty Stati n Unit 2 RItart Plan i REVISION 3 l l Attachment A, Page 3 l

3. Permit final review and approval of issues associated with the Action Plans and their resolution, in the aggregate, prior to unit restart F. Attachments:

1. Index of documents

2. Action Plan l

3. Supporting documentation (e.g., inspections, walkdowns, surveys, procedure changes, ccver peces of documents and applicable pages).

4. Approval signatures 1

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