ML20195H868
ML20195H868 | |
Person / Time | |
---|---|
Site: | Millstone ![]() |
Issue date: | 11/04/1998 |
From: | Laplante J NORTHEAST NUCLEAR ENERGY CO. |
To: | |
Shared Package | |
ML20195H859 | List: |
References | |
PROC-981104, NUDOCS 9811240133 | |
Download: ML20195H868 (33) | |
Text
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e MILLSTONE Unit 2 l
OPERATIONAL i
READINESS PLAN i
I MILLSTONE NUCLEAR POWER STATION i
l Northeast Utilities i
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Prepared By:
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Date:
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Plante Approved By:
As Date:
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L A. Price
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9811240133 981117 1
PDR ADOCK 05000336 P
pg Rev.4 t
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Table of Contents I. Purpose and Process A. Purpose 1
B. Background 1
C. How Did We Get to Where We Are?
2 D. How Do We Get to Where We Are Going?
3 E. Nuclear Regulatory Commission (NRC) Restart Process 6
F. Recovery Organization 8
G. ORP Methodology 8
H. Key Performance Indicators (KPI) 9 I. Integrated Schedule 9
J. Unit 2 NRC Briefing Book 9
II. Restart Readiness A. Organization 11 B. System Readiness 15 C. OperationalReadiness 18 D. Regulatory Readiness 19 E. Communications 19
. III. Operational Readiness Assessment 22 1
IV. Startup and Power Ascension Program 23 V.
Long Term Performance 23 VI. Backlog Management Plan 23
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Purpose and Process A. Purpose The purpose of this plan is to achieve and maintain improved performance at Millstone Unit 2. Improved performance requires organizational commitment to higher operating standards through conservative decision making, forthrightness and integrity, self-assessment, and the highest standards for the conduct of-
.'. operations. Northeast Nuclear Energy Company (NNECO) will not request authorization for Unit 2 to L
enter Mode 2 until sufficiently high standards are demonstrated in the following seven Key Issues:
Safety Conscious Work Environment i
l-Self-Assessment
' * -- Corrective Action Work Control and Planning e
Procedure Quality and Adherence L
- Operational Readiness e
l-Engineering Quality e.
The fundamental goal is to be recognized by our employees, the public, and the. Nuclear Regulatory Commission (NRC) as a trusted, safe, and efficient nuclear power plant operator.
(L B. - Background 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 resolve a High Pressure Safety Injection system operability concern. In letters dated
' March 7,1996, and May 21,1996, the NRC, pursuant to 10 CFR 50.54(f), requested that additional L
information be submitted prior to restart which describes actions taken to ensure future operation will be L
conducted in accordance with: 1) Unit 2's operating license and Updated Final Safety Analysis Report L
(UFSAR); 2) the Commission's regulations; and 3) the disposition of deficiencies identified after the
. issuance of the ACR 7007 report. On April 16,1997, the NRC superseded their previous 10 CFR 50.54(f) i requests and required that the following information be provided: 1) significant items that are needed to L
be accomplished prior to restart; 2) a list ofitems to be deferred until after restart; 3) the process and rationale Northeast Utilities (NU) is using to' defer items identified in request No. 2; and 4) identification
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of actions that have been taken to ensure that future operation of the unit will be conducted in accordance with the license, regulations, and UFSAR.- In addition, NU must provide information confirming that all significant items identified in request No. I have been completed prior to restart, or if not completed,
. provide details on how they were dispositioned. Initial responses to requests No. I through No. 3 were submitted to the NRC on May 29,1997. The information contained in response to requests No. I and No.
2 are updated approximately every 60 days, with the most recent update provided in September,1998.
Request No. 3 was updated on January 9,1998. A response to request No. 4, and the final submittal of information for requests No. I through No. 3 must be submitted to the NRC no later than 14 days prior to
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the Commission meeting on Unit 2 restart.
On August 14,1996, the NRC issued a Confirmatory Order directing the establishment of an Independent Corrective ' Action Verification Program (ICAVP). On March 11,1997, the NRC issued a clarification to U
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On October 24,1996, the NRC issued an Order requiring the establishment of a comprehensive plan to address the handling of employee concerns with the retention of an independent third-party to oversee NU efforts.
On March 7,1997, the NRC issued a Confirmatory Action Letter on Nuclear Training.
NNECO actions taken in response to these letters are the subject of the discussions which follow.
C. How Did We Get to Where We Are?
In April 1996, the Northeast Utilities' Board of Trustees formed the Nuclear Committee of the Board to provide increased oversight of the nuclear program. The Nuclear Committee chartered the Nuclear Committee Advisory Team (NCAT) to provide assistance. At the request of the NCAT, the Fundamental Cause Assessment Team (FCAT) was formed in May 1996, to perform an independent assessment of the factors contributing to the decline in Millstone's performance over the ten-year period between 1987 and 1996. The FCAT Report was issued on July 12,1996, and submitted to the NRC Staffin a July 24,1996, letter.
Regarding the findings of the assessment, the FCAT identified the following fundamental causes of the decline in NU's nuclear program relative to the increasing demands placed on a well-performing nuclear 1
program:
The top levels of NNECO management did not consistently exercise effective leadership or articulate and implement appropriate vision and direction.
The nuclear organization did not establish and maintain high standards and expectations.
The nuclear organization's leadership, management, and interpersonal skills were weak.
These fundamental causes are interrelated. For example, executive management vision and direction affected the standards applied in the nuclear organization. Similarly, leadership and interpersonal skills affected the way in which directions and standards were implemented. NNECO determined the root cause was ineffective leadership which tolerated performance to low standards.
The conclusions of the FCAT review have been used as an " umbrella" for associated findings from other focused reports, including:
Millstone Employee Concerns Assessment Team Report (January 29,1996)
ACR 7007 Event Response Team Report (February 22,1996)
Report of the Management Review of the Adequacy of the NNECO Quality Assurance Program (Joint Utility Management Audit - JUMA)(July 17,1996)
Root Cause Evaluation of the Independent Oversight Organization (September 10,1996) e NRC Inspection Report 96-201 (Special Inspection of Engineering and Licensing Activities at MP2 and 3)(September 20,1996)
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e' Millstone Independent Review Group (MIRG) - Report on Employee Concerns (October 24,1996)
Common Cause Assessment of Apparent Violations at Millstone (December 13,1996) 2 Rev.4
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D. How Do We Get to Where We Are Going?
NNECO management's response was clear and decisive: the attention provided by the NU Board of Trustees on nuclear matters significantly increased and the leadership for the nuclear organization was changed.
l Other changes were made which specifically addressed standards, skills, and programs within the nuclear organization. The leadership team, with the approval and guidance of the Board, has pursued a recovery program which addresses the specific weaknesses identified in the FCAT report and many station assessments.
l Millstone station has also established success objectives that establish the framework for improving l
performance. The success objectives are:
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Millstone Station l
Success Obiectives i
High Standards and Clear Accountabilities
- Incorporate many best practices from other utilities
- Regularly benchmark with other nuclear utilities
- Indicators show strong improvement toward excellence
- Commitments are met j
Strong Nuclear Safety Policy l
- Careful adherence to high nuclear safety standards
- Conservative decision making
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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 timely mamier
- Improved regulatory performance as demonstrated by decreases in NRC violations and Licensee Event Reports (LERs)
Restored Licensing and Design Bases with process to ensure that they are properly maintained l
- ICAVP contractor confirms that the design and licensing bases have been restored l
- Implemented effective configuration control processes An environment that supports the identification and effective resolution of employee concerns
- Open and candid communications
- Timely resolution of employee safety concerns
- Independent review of employee safety concerns confirms effectiveness I
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Commitment to resolve long-standing issues and to maintain safe and reliable operations e
.- Excellence has been defined, a plan to achieve has been developed and there is good l
demonstrated performance
- Issues important to startup have been resolved
- Resource commitments meet or exceed those of similar well-run units 1
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The following paragraphs provide a summary of results achieved to date to correct several of the most significant issues and achieve performance at a level satisfactory to support restart. These are leadership, l
Unit 2 key issues, safety conscious work environment, problem identification and disposition, and l
management oversight and controls.
l Leadershin In the latter part of 1996, new leadership was appointed in response to the root cause on ineffective leadership. This leadership team included experienced management with records of strong safety and l
regulatory performance at other utilities. In addition, supervisor-and-above leadership development has been on-going and continues to be effective in raising standards and promoting teamwork.
l Collectively, the new leadership team embodies the needed abilities, leadership skills, character and experience, and have applied them to transform the culture and improve performance at Millstone.
This leadership team has a profound respect for the regulatory process and is committed to set standards and reinforce expectations for conduct of operations in conformance with the design and licensing bases.
This leadership team is also committed to create and sustain a safety conscious work environment where employees feel free to raise any issue important to them with the confidence that the issue will be addressed with commitment, respect, and in a timely manner. This leadership team is setting high standards and providing sufficient oversight to ensure effective, functioning corrective action and employee concerns programs, within a safety conscious work environment.
NNECO has developed and implemented a recovery program for Millstone Unit 2, centered around applying the lessons learned from Unit 3 and sustaining and improving leadership performance. Efforts continue to be focused on achieving the seven Millstone Station Success Objectives.
Unit 2 Key Issues l
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Based on performance achieved to support the restart of Unit 3, most of the 16 key issues necessary to L
support restart of Unit 2 were also satisfactory. The remaining key issues provided below are all tracking to satisfactory to support restart in the first quarter of 1999.
- Self-Assessment L
Corrective Action Work Control and Planning Procedure Quality and Adherence o
e Operational Readiness e
Engineering Quality '
Key issue executive sponsors and issue managers have been assigned. The effectiveness of corrective i
actions to address these key issues is being monitored on a continuing basis by the leadership team and 4
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i independently assessed by the Nuclear Oversight organization. The status of each of the key issues will be provided in periodic NRC briefings.
Safety Conscious Work Environment The FCAT report clearly identified the necessity of addressing human behaviors or " cultural problems" at Millstone. The leadership team continues to reinforce actions to build a culture revolving around nuclear safety, and one which encourages and welcomes employees to voice observations and concerns. Millstone Station has established and is maintaining a safety conscious work environment.
Problem Identification and Disnosition NNECO has taken action to restore the four major programmatic elements of an effective corrective action process at Millstone Station. These four elements are:
. - Problem Identification, Problem Evaluation, Problem Resolution, and e
e Corrective Action Effectiveness.
The first element focuses on instilling a questioning attitude which encourages critical self-identification and assessment with a low threshold for problem identification. NNECO has established an environment in which problems are self-identified and where self-assessment is an integral part of the way business is conducted. The second element focuses on the quality and timeliness of evaluations, including performance against management expectations for operability and reportability determinations. The third element
- focuses on addressing the key issues, completion of corrective actions, backlog management, and minimizing recurrence ofissues or events. The fourth element focuses on results, including the health of programs, processes and procedures, and management oversight and controls.
Mannecment Oversieht and Control Oversight from the Board of Trustees has been revitalized. The makeup of the Board of Trustees includes individual with nuclear plant operations experience. A strong Nuclear Safety Assessment Board (NSAB)
-was established and demonstrated effective to support safe event free operations. NSAB membership-meets Technical Specification requirements.
The Plant and Site Operations Review Committees (PORC and SORC) are setting high standards and are meeting Technical Specification requirements.
The Nuclear Oversight function is an integral part of the leadership team's assessment process. Nuclear Oversight performance has been demonstrated as satisfactory te support safe, event-free operation. The Nuclear Oversight function includes monitoring the quality of station activities for restart through the Nuclear Oversight Verification Plan (NOVP) and beyond restart through the conduct of effective audits, surveillances, and assessments in accordance with applicable regulatory requirements.
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E. Nuclear Regulatory Commission (NRC) Restart Process Process Overview The results of many comprehensive reviews. of the following regulatory activities will be required to demonstrate that Unit 2 is ready for restart. The reviews include:
NRC Inspection Manual Chapter 0350," Staff Guidelines for Restart Approval" 10 CFR 50.54(f) requests for information e
Independent Corrective Action Verification Program (ICAVP)
Independent Third Party Oversight Program (ITPOP) of the Employee Concerns Program Operator Training Confirmatory Action Letter Manual Chanter 0350 Process NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelines for Res:. art Approval," is the NRC established process for approving restart of a nuclear power plant after a shutdcwn resulting from a significant event, cornplex hardware problem, or serious deficiency. Restart review activities are coordinated by a Restart Panel in accordance with the Restart Assessment Plan. The Restart Assessment l
Plan includes a case-specific restart checklist which evaluates:
e Assessment of Root Cause Identification and Correction l
Licensee Self-Assessment and Management Effectweness l
Assessment of Plant and Corporate Staff Effectiveress Assessment of Physical Readiness of the Plant Assessment of Compliance with Regulatory Requiren.ents e
Coordination with Interested Agencies and Parties Included in the MC 0350 process is the integration of other NRC inspection and assessment processes.
For the Millstone site, other major NRC assessments include:
Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems (IP 40500) l Operational Safety Team Inspection (OSTI) (IP 93802)
The results of the above inspections, as well as other NRC assessments, will be considered by the Restart Panel and the NRC staffin determining when the NRC issues permission for Millstone Unit 2 to enter Mode 2.
l 10 CFR 50.54(f) Reauest for Information l
Millstone Unit 2 is subject to a series of requests for irformation pursuant to 10 CFR 50.54(f). The effective request is dated April 16,1997, and supersedes all previous requests. The April 16,1997 request requires NNECO to provide on the docket:
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- 1. The significant items that need to be accomplished prior to restan. Significant items are defined as issues impacting equipment covered by 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," that raised (1) questions concerning the operability of 1
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equipment, or (2) questions concerning the ability of the equipment to perform its intended design basis function.
- 2. The list ofitems to be deferred until after restart. This list must include, but not be limited to, issues impacting equipment covered by 10 CFR 50.65, which will not be resolved or fully implemented prior to restart.
- 3. The process and rationale NNECO is using to defer items identified per item 2, above, until after restart.
- 4. Those actions that have been taken to ensure that future operation of the unit will be conducted in accordance with the license, regulations, and UFSAR. In addition, NNECO must provide information confirming that all significant items identified in item 1, above, have been completed, or if not completed, provide details to how they have been dispositioned.
Items 1 and 2 are provided to the NRC in periodic updates, due approximately every 60 days, as required
' by NRC letter dated January 8,1998. The most recent update was provided September 24,1998. Item 3 was due to the NRC within 45 days of the April 16, 1997 request and was completed in NNECO's response dated May 29,1997, and amended in a January 9,1998 submittal. Item 4 is due to the NRC no l
later than 14 days prior to the Commission meeting for Unit 2 restart.
Independent Corrective Action Verification Proeram The Independent Corrective Action Verification Program (ICAVP) is being performed, as required by the NRC's August 14,1996 Confirmatory Order, to review selected systems. The review will consist of:
(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 into operating procedures, and maintenance and test procedures (d) Verification of system performance through review of specific test records and observation of selected testing of particular systems (e) - Review of proposed and implemented corrective action ofidentified design deficiencies Completion of the ICAVP review is necessary prior to NRC restart approval.
Emplovec Concerns Due to past failures in management processes and procedures for handling safety issues raised by l
employees and to_ ensure that employees who raise safety concerns are not discriminated against, NU received an NRC confirmatory order on October 24, 1996, to institute an Independent Third Party Oversight Program (ITPOP) for employee concerns. Specifically, the NRC required NU to submit a comprehensive plan within 60 days to address the root cause of past performance failures, and propose i
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. NNECO has established a safety conscious
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work environment as indicated in submittals to the NRC dated March 31,1998 and April 24,1998. The 7
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most recent quarterly performance report, submitted in July 1998, indicates that a safety conscious work environment is being maintained.
Operator Trainine Confirmatory Action Letter Training has completed the action associated with the Confirmatory Action Letter. Designated Unit 2 restart required activities within the training corrective action plan will be complete prior to Unit 2 restart.
F. Unit 2/ Recovery Organization The purpose.of the Unit 2 and Recovery Organization is to establish a management team focused on, and dedicated to safe restart of Millstone Unit 2. Emphasis is on high standards, effective corrective actions, and continued regulatory compliance. To accomplish this, an organization similar to that shown in Figure I-1 is being 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, effective corrective actions, operational excellence, and regulatory compliance. Adjustments to the model organization will be made as required to support recovery and long-term normal power operations.
G. ORP Methodology There are five major elements of restart readiness: Organization, System, Operational, Regulatory, and Communications. The ORP describes the initiatives necessary for each element to demonstrate restart readiness and establishes a foundation for long-term sustained improvement.
ORP Section II identifies the specific performance indicators designed to measure restart readiness. The performance indicators are taken from the Millstone Unit 2 Performance Annunciator Panel Reporting System. The Unit 2 Performance Annunciator Panel Reporting System is a management tool which includes indicators relevant to both restart and operational performance. As a management tool, the l
performance windows will be revised as necessary to achieve current management goals and objectives. It is not intended to revise the ORP if the performance windows are adjusted. The status of the Unit 2 l
Performance Annunciator Panel windows is currently updated quarterly and is available on site.
Each indicator in the performance windows can assume one of five different states, as follows:
Red:
Unsatisfactory for restart Yellow: Tracking to satisfactory for restart White:
Sat for Restart l
Green: Exceeds expectations Blue:
Currently unassessed or under developm:nt The specific success criteria for each relevant indicator is described in Section II. Green or white windows are satisfactory for restart.
Yellow windows are satisfactory for restart if the associated window performance is showing sustained improvement under a corrective action plan. Red windows or yellow windows not showing sustained improvement under a corrective action plan are unsatisfactory for restart.
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e H. Key Performance Indicators (KPI)
A set of Key Performance Indicators (KPI) important to restart readinees has been developed and is l
updated on an approximate weekly basis. These KPIs are available to the NRC and are provided at the NRC Restart Assessment Panel public meetings.
-I. Integrated Schedule An integrated schedule for restart has also been developed and implemented. The schedule is reviewed by Unit 2 management and updated several times a week.
J. Unit 2 NRC Briefing Book Unit 2 progress to restart, which updates readiness for restart and the remaining key issues, is provided to the NRC to provide status update prior to scheduled NRC Commission Meetings.
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Fieure I-I
' -i Millstone Unit 2/ Recovery Oreanization i
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MP2 Unit Director l
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l Assistant Unit Director l l Assistant Unit Director l l Manager Radiation Protection l l
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Manager Manager Manager Manager Manager Manager Manager Supenisor Supeniser Centralized Corrective Nuclear I& C Work Operations Maintenance Radiological Rndistion
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Procedures Actions Safety Planning &
Engineering Protection Group Outage Management
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i l MP2 Engineering Director l j
MP2 f
Engineering Assistant Director t
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l Manager Manager Manager Project Restart Supenisor f'
Design Technical Project Manager Coordinator Cost &
Engineering Support Engineenng CMP Scheduling i
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II. Restart Readiness l
l A. Organization j
Management Oversieht and EfTectiveness Objective:
l The objective of management is to establish an organizational culture with a strong nuclear safety philosophy, a commitment to critical self-assessment, a questioning attitude, and an inherent respect for its governing regulations.
The leadership team is improving performance by establishing high standards, incorporating best practices from other utilities, closely monitoring performance, and actively guiding actions to achieve these standards.
I Success Criteria:
The following Management Oversight and Effectiveness performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made:
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- Standards and Expectations Communicated to the Staff 1
- Commitment to Achieving Improved Performance
- Nuclear Safety
- Corrective Action Program
- Procedure Usage and Adherence
- Effectiveness ofMRT/PORC
-ALARA l
Human Performance Objective:
Adequate performance of individuals within the framework of a functional organization is essential to meeting organizational goals of safe and reliable operation. Essential elements contributing to acceptable human performance include:
Demonstrated safety consciousness An understanding of management expectations Adequate stafTqualification and training l
Success Criteria:
The following performance windows must be evaluated as either green, white, or yellow with a l
corrective action plan in place and sustained improvement being made. For summary windows, none of the supporting windows may be red.
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OPERATIONS
' - Attentiveness to Duty
- Communications
- Level of Attention to Detail
- Shift Turnover / Briefs.
- Log Keeping Practices
- Control Room Demeanor
- Tagging Events Mispositioning Events
--' Training and Qualifications WORK PLANNING and OUTAGE MANAGEMENT Human Performance
- Training and Qualification MAINTENANCE
- Worker Practices
- Training and Qualification INSTRUMENT and CONTROL Worker Practices
- Human Performance
- Training and Qualification ENGINEER.ING
- Human Performance
- Training and Qualification
- CORRECTIVE ACTION PROGRAM
- Human Performance - U2 CAD
- Training and Qualification PROCEDURES
- Human Performance
- Training and Qualification RADIATION PROTECTION
- Human Performance I
- Procedure Compliance i
- Training and Qualification
- CHEMISTRY
- Worker Practices -
- Training and Qualification LICENSING i
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Corrective Action /Self Assessment Program Implementation Objective:
An effective corrective action program is necessary to identify, correct, and prevent recurrence of identified problems. In the identification phase, a low threshold must be maintained to get all potential discrepancies into the corrective action program. Appropriate immediate corrective actions must be implemented and reportability must be determined in a timely manner. If necessary, root cause assessments will be conducted. Additionally, periodic management reports and trends are generated to ensure continuous improvement and prevent recurrence of events.
Success Criteria:
The following corrective action program performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made.
For summary windows, none of the supporting windows may be red.
- Trending EfTectiveness
- AITTS Corrective Action Department (CAD) Management Overdue Assignments OE Effectiveness Root Cause Quality Initial CR Screening
- Conduct of CAD CRs/ACRs Work Management Program Objective:
An effective Work Management Program is necessary to ensure that activities are planned, controlled, and completed in a timely manner. Inherent in this goal is a prioritized and managed backlog, quality work packages, eflicient scheduling, and an awareness of the safety impacts associated with equipment outages.
Success Criteria:
The following performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made. For summary windows, none of the supporting windows may be red.
WORK PLANNING and OUTAGE MANAGEMENT Plan of the Day Effectiveness
- Work Package Quality Post Maintenance Testing Preventive Maintenance Program 13 Rev.4
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MAINTENANCE FME-Conduct ofMaintenance
. Overall Effectiveness of Plant Maintenance Program Procedures Program Objective:
Procedure compliance and quality are fundamental to safe nuclear operations. This includes compliance with controlled procedures that have been properly verified as current and correct.
i Procedures are being reviewed and revised through a Procedure Upgrade Program.
Success Criteria:
The following performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made. For summary windows, none of the supporting windows may be red.
OPERATIONS
- Procedure Use
- Procedure Quality MAINTENANCE
- Procedures / Document Control INSTRUMENT and CONTROL
- Procedures / Document Control PROCEDURES Technical Adequacy ofProcedures i
Trainine Objective:
Training programs utilizing the Systematic Approach to Training must be in place and functioning to ensure adequately trained Operations, Maintenance, and Engineering staff are available to support restart.
Success Criteria.
The following Training performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made. For summary windows, none of the supporting windows may be red.
- Quality of Accredited Programs
- Quality of Non-Accredited Programs
- Simulator Fidelity
- Management Support ofTraining 4
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Environmental Objective:
An effective Environmental Management Program is necessary to ensure that discharges from the plant are performed in compliance with environmental regulations.
Success Criteria:
The following Chemistry performance window shall be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made. For summary windows, none of the supporting windows may be red.
- NPDES Performance B. System Readiness Confieuration Manarement Objective:
One of the key underpinnings supporting nuclear safety is the assumption that the plant design bases and licensing bases are accurately reflected in the physical plant construction and associated operating, maintenance, and test procedures. Unit 2 has a Configuration Management Program to verify the integrity of the design and licensing bases and to verify these are properly translated into
~ the physical plant.
. Success Criteria:
The following performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made. For summary windows, none of the supporting windows may be red.
OPERATIONS
- Tagging Process / Practices
- Document Control / Availability.
ENGINEERING
- Configuration Management Engineering Programs 1
Desien Control l
i Objective:
Once the design and licensing bases have been verified, they must be maintained. Thus, controls g
are required to ensure proper configuration management on a going-forward basis.
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Success Criteria:
The follo' wing Engineering performance windows must be evaluated as either green, white, or l
. yellow with a corrective action plan in place and sustained improvement being made. For I-summary windows, none of the supporting windows may be red.
- Design Quality
- NCRs
- Effectiveness of PRA Usage l
- TemporaryModifications 10 CFR 50.59 Process Objective:
10 CFR 50.59 safety evaluations must be complete and comprehensive to support safe operation and appropriate operability determinations.
E Success Criteria:
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The following Engineering performance window must be evaluated as either green, white, or j
yellow with a corrective action plan in place and sustained improvement being made.
l 10 CFR 50.59 Safety Evaluations I
Enmineerine Skills Enhancement Objective:
Engineering is a key support organization and serves as an essential partner in ensuring that other organizations understand the plant's design basis. Engineering must be technically proficient to l
l-support the safe and efficient operation and maintenance of the plant.
Success Criteria:
The following Engineering performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made.
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- Effectiveness of Engineering Support
. Conduct of Engineering Physical Plant Work Objective:
i Required modifications, corrective maintenance, preventive maintenance, and associated testing are complete or scheduled for required plant mode.-
Success Criteria:
2The Maintenance and Work Planning & Outage Management departments report restart required work is complete.
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i System Operability
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Objective:
l All systems required for re-start and plant operation are operable or awaiting scheduled testing at required plant mode. The balance of plant systems and necessary support systems are also operable.
i Success Criteria:
l The following performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made. For summary windows, l
none of the supporting windows may be red.
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OPERATIONS
- Operator Burdens (Work Arounds)
- TemporaryModifications
- Black Board Alarms
- Operability ofTech Spec Systems
- Secondary, Support Systems Available l
- Tech Specs
- Adequacy of System Lineups l
ENGINEERING
- Maintenance Rule
- System Readiness Testine Program Objective:
l Surveillance and in-service testing must be technically accurate and complete to support l
operability of associated systems. Additionally, a startup and power ascension test program incorporating required startup testing must be developed and approved.
Success Criteria:
The following performance windows must be evaluated as either green, white, or yellow with a j
corrective action plan in place and sustained improvement being made. For summary windows, l
none of the supporting windows may be red.
OPERATIONS
- Surveillance Tests Power Ascension Procedures l
MAINTENANCE I
- Surveillance Testing
' INSTRUMENT and CONTROL M&TE
- Surveillance Testing 17 Rev.4 l
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ENGINEERING
- Surveillance Tests
- Adequacy / Power Ascension Procedures
' CHEMISTRY
- Surveillance Testing Plant Materiel Condition Objective:
Proper plant housekeeping is indicative of the overall staff attitude toward plant operation. This includes not only maintaining work areas neat and clean, but also encompasses proper chemical storage, proper chemical !tbeling, appropriate leak collection, and control of contaminated surface areas.
Success Criteria:
The following performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made. For summary windows, none of the supporting windows may be red.
OPERATIONS Housekeeping MAINTENANCE
- ' Control of Chemicals / Material Storage Housekeeping INSTRUMENT and CONTROL
- Housekeeping CHEMISTRY
- Control of Consumable Chemicals
- Housekeeping C. Operational Readiness Objective:
Operational activities must be conducted in a manner that ensures safe, conservative, and reliable operations. Nuclear Safety and a profound respect for the core must be foremost in operational decisions. Operations personnel are to be cognizant of the status of plant systems and comply with all applicable regulations and the Technical Specifications.
Success Criteria:
The following Operations performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made.
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Awareness of Plant Status Staff Levels Adequate
- Required Reading
- Work Observations Awareness of Plant Security
' D. Regulatory Readiness An effective organization to address regulatory issues must exist. This includes adequate
- Technical Specifications that are both understandable and acceptable for plant operation. In addition, regulator commitments must be tracked and fulfilled.
Success Criteria:
- 1. The following Licensing performance windows must be evaluated as either green, white, or yellow with a corrective action plan in place and sustained improvement being made. For summary windows, none of the supporting windows may be red.
- Technical Specifications l
Reponability Determinations and LERs l ~
- Commitment Management
- 2. The final 10CFR50.54(f) response for Unit 2 must be complete and submitted to the NRC.
- 3. The NRC Significant Items List (SIL) must be complete.
- 4. The Confirmatory Order for an Independent Corrective Action Verification Program is rescinded or modified.
- 5. NNECO safety conscious work environment performance is satisfactory to support restart.
- 6. The Confirmatory Action Letter on Operator Training and the associated Unit 2 actions within the Training corrective action plan are complete.
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7.
10 CFR 50.54(f) Significant Items for Restart are complete or dispositioned.
E. Communications A comprehensive Communications Plan has been developed for Unit 2. The Plan places heavy l
emphasis on face-to-face communication as the most effective way to disseminate information L
and accomplish the following objectives:
j Build confidence of employees in themselves and their leadership i
Re-establish employee credibility and trust of management Develop teamwork and organizational buy-in Convey progress 19 Rev.4 l
A. communications plan, which describes communications, their audiences, and suggested frequency to implement face-to-face communications has been implemented. The following are elements of the Communications 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 e
Industry and unit-specific experience that should be communicated to all unit personnel, such as lessons learned Management feedback on its plans and commitments e
Other information that is useful, of interest, or of value from the standpoint of employee morale Communication across 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 higher management in the form it was intended when given to line management so they feel upper management is getting an accurate input.
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 of letters of commendation, recognition in management meetings, celebration events, spot recognition awards, a written newsletter, and photo stories.
Setting of several (3-5) short-term objectives that support longer-term goals Officer meetings with all supervisors, managers and directors together to review status, goals, e
L and future initiatives Unit-Wide Communications Anoroach j
' Consistent messages must be sent from top to bottom. It is important that communication with employees be. consistent and well coordinated.
Communication with various levels of management is beneficial to employees. Altematively, if meetings and messages are not carefully l
coordinated, employees can become frustrated by meetings that are either too frequent or not l
frequent enough, and can become confused if the messages are inconsistent or in conflict with one another.
r
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It is in the organization's best interest to have a plan that is well thought out and executed.
i Toward that.end, the communications matrix lays out the plan for communications, both interpersonal and written. The Communications Plan has been developed to ensure sufficient 20 Rev,4 I'
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contact between upper management and other reporting levels and to provide management's philosophies and expectations throughout the organization.
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 the Nuclear Communications Plan.
l Other vehicles are unit-specific. They are:
Face-to-Face Meetings: Survey after survey demonstrates that employees generally want to receive most of their information about the organization from their supervisor. The importance of these communications must be reinforced by management, and individuals should be held accountable. It should be made clear that written communications do not I
replace face-to-face interaction, l
It should be emphasized here that face-to-face not only includes interaction between employees and immediate management, but also interactions between employees and unit j
senior management.
All hands meetings: In many cases, face-to-face communication is more appropriate in large groups. There have been, and will be, occasions when it is appropriate to hold a unit all-hands meeting. This could be run by the unit recovery officer, the unit director, the unit engineering director, or others as applicable.
Department meetings: Whenever appropriate, information from the morning unit meeting
]
should be discussed in department meetings. As discussed above, employees want to get most of their information from their immediate management, and brief meetings are an important element in accomplishing this.
Unit management letters, memos and speeches: In many cases, timely information is best communicated by management. These communications are issued on a regular or on an as-needed basis. Their objective is to project management's commitment to keep the work force informed and to recognize individual achievement.
Unit / Department Celebration / Motivational Events: There will be times when an event, e
such as a rally or picnic, will be appropriate. These can be used to celebrate success, rally support for upcoming challenges, and convey a sense of teamwork.
- Print communications: Examples include dailies, weekly reports, issue-specific picture stories, officer letters / memos, etc. Two important messages that are crucial in our communications are individual and group recognition, and progress. These messages are i
now better communicated with photo stories and weekly updates than they were with the previously existing vehicles.
21 Rev.4
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contact between upper management and other reporting levels and to provide management's philosophies and expectations throughout the organization.
1 1
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 coordMating unit input into the system-wide communications vehicles. These are outlined in the Nuclear Communications Plan.
Other vehicles are unit-specific. They are; Face-to-Face Meetings: Survey aller survey demonstrates that employees generally want to e
receive most of their information about the organization from their supervisor. The importance of these communications must be reinforced by management, and individuals should be held accountable. It should be made clear that written communications do not replace face-to-face interaction.
It should be emphasized here that fa e-to-face not only includes interaction between employees and immediate management, but also interactions between employees and unit j
senior management.
All-hands meetings: In many cases, face-to-face communication is more appropriate in large groups. There have been, and will be, occasions when it is appropriate to hold a unit all-hands meeting. This could be mn by the unit recovery officer, the unit director, the unit engineering director, or others as applicable.
l Department meetings: Whenever appropriate, information from the morning unit meeting e
should be discussed in department meetings. As discussed above, employees want to get most of their information from their immediate management, and brief meetings are an important element in accomplishing this.
Unit management letters, memos and speeches: In many cases, timely information is best communicated by management. These communications are issued on a regular or on an as-needed basis. Their objective is to project management's commitment to keep the work force informed and to recognize individual achievement.
Unit / Department Celebration / Motivational Events: There will be times when an event, sucn as a rally or picnic, will be appropriate. These can be used to celebrate success, rally support for upcoming challenges, and convey a sense of teamwork.
- Print communications: Examples include dailies, weekly reports, issue-specific picture l
stories, officer letters / memos, etc. Two important messages that are crucial in our communications are individual and group recognition, and progress. These messages are now better communicated with photo stories and weekly updates than they were with the previously existing vehicles.
21 Rev.4
III. Operational Readiness Assessment Millstone Unit 2 has established and is following a rigorous restart affirmation process based on lessons learned from the Unit 3 process. The process involves the direct panicipation by a number ofinternal and external organizations. Within the affirmation process, there are checks and balances to assure that all issues are resolved and all plant systems and organizations are ready to support operations prior to entry into Mode 2.
The following table shows the organizations which are involved in confirming the restart readiness of Unit 2 and illustrates the comprehensive nature of the checks and balances in the process.
Millstone Unit 2 Readiness Affirmation Summary Criterion Line Nuclear Nuclear Independent NNECO Management Oversight Safety Third Party Senior Assessment Management Board Restoration X
X X
X X
ofDesign and Licensing Bases Safety X
X X
X X
conscious work l
environment l
Programs to X
X X
X X
Identify and Resolve i
Problems l
Unit 2 X
X X
X Readiness Management X
X X
X X
Control and Oversight
)
Rigorous X
X X
X X
Process for Restart I
Aflirmation 1
l 22 Rev.4
IV. Startup and Power Ascension Program The objective of the Unit 2 Startup and Power Ascension Program is to ensure a safe, event-free restart using an integrated, systematic approach incorporating the Unit 3 lessons learned. Startup and power ascension activities are intended to be governed by Special Procedure, SPROC OP 98-2-08," Unit 2 Restart Following 10CFR50.54(f) Outage." The procedure will be PORC approved approximately 45 days prior to Mode 4 entry.
The Startup and Power Ascension Program will include hold-points, at which NNECO will formally assess plant and organizational readiness to proceed through power ascension. These hold-points are presently planned to occur prior to Mode 4 entry, prior to Mode 2 entry, and subsequent to completion of activities at 30% power, 50% power, and 75% power. The assessments will be conducted by the line, PORC and Nuclear Oversight. At each hold-point, Nuclear Oversight concurrence will be required to proceed to the next phase of the Startup and Power Ascension Program. A final assessment to determine readiness to resume continued full power operation will be conducted following completion of activities at the 100% power test plateau. The results of the 100% power assessment will be used as the basis for the Vice President of Operations to declare the Startup and Power Ascension Program complete. The Startup and Power Ascension Program is available on site.
V. Long Term Performance The Millstone organization is completing a long diflicult recovery. With Unit 2 restart, the organization will transition to a period of operation, characterized by conservative decision making, safety consciousness, and continuous improvement.
The strategy for continued improvement and achieving excellence is contained in the 1998 - 2000 Performance Plan for Millstone Station and the Northeast Utilities Nuclear Business Unit 19998 - 2003 Business Plan.
These documents are available on site.
VI. Backlog Management Plan The Millstone Unit 2 Backlog Management Plan provides an integrated, structured approach to successfully manage and disposition the backlog ofidentified open items at the time of Unit 2 restart, while maintaining a focus on the safe, event-free operation of Unit 2.
The Plan supports the following Unit 2 high level performance objectives:
Reduce the challenges to the operators Improve the timeliness and effectiveness of maintenance and work activities, while maintaining high quality standards Maintain a high state of plant materiel condition 23 Rev.4
The Backlog Management Plan goal is to work off the historical backlog while maintaining the current corrective action average age less than 120 days Backlog Management methodology guidance, which reflects the following process functional requirements, will be approved prior to entry into Mode 2:
" Backlog of Deferred Work" will be dispositioned prior to entry into Mode 2 following e
RFOl3 Existing Unit and Station work control and priority processes will be used to disposition backlog items, including an option not to pursue performance enhancement items Continuously improving management standards and expectations for backlog levels to achieve e
industry benchmarks Maintain visibility on work items initiated prior to or during this outage (including ICAVP e
DRs and CMP Discovery Items)
Conduct periodic assessments of results to provide added assurance that management e
standards are being conservatively applied Maintain visibility on the " Backlog of Deferred Work" through appropriate inclusion into the unit schedule Monitor performance and results using existing Unit and Station tools and techniques The Backlog Management Plan is available on site.
4 24 Rev.4 i
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t-i Docket No. 50-336 i.
B17485 l
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Millstone Station Unit No. 2 Operational Readiness Plan p
Performance Windows Status as of Second Quarter 1998 i-i*
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November 1998 i
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6 Docket No. 50-336 l
B17485 a
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l Millstone Station Unit No. 2 Operational Readiness Plan Performance Windows Status as of i
Second Quarter 1998 1
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November 1998 4
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U.S. Nucl:ar R::guictory Commission 3
B17485\\Attechment 2\\Pcge 1 i
i ORGANIZATION READINESS Management Oversight and Effectiveness Standards and Expectations Communicated to the Staff Sat for Restart Commitment to Achieving Improved Performance Sat for Restart Nuclear Safety Sat for Restart Corrective Action Program Tracking to Sat Procedure Usage and Adherence Sat for Restart Effectiveness of MRT/PORC Sat for Restart ALARA Sat for Restart Human Performance OPERATIONS Attentiveness to Duty Sat for Restart Communications Sat for Restart Level of Attention to Detail Sat for Restart Shift Turnover / Briefs Sat for Restart Log Keeping Practices Sat for Restart Control Room Demeanor Sat for Restart Tagging Events Sat for Restart Mispositioning Events Sat for Restart Training and Qualifications Tracking to Sat WORK PLANNING AND OUTAGE MANAGEMENT Human Performance Not Evaluated Training and Qualification Unsat MAINTENANCE Worker Practices Sat for Restart Training and Qualification Tracking to Sat INSTRUMENT AND CONTROL Worker Practices Sat for Restart Human Performance Not Evaluated Training and Qualification Sat for Restart ENGINEERING Human Performance Tracking to Sat
(
Training and Qualification Sat for Restart CORRECTIVE ACTION PROGRAM Human Performance - Unit 2 CAD Sat for Restart Training and Qualification Sat for Restart I
['
' U.S. Nuclecr Regul tory Commission B17485\\ Attachment 2\\Page 2
' PROCEDURES.
Human Performance Sat for Restart
-Training and Qualification Sat for Restart R/4DIATION PROTECTION Human Performance Sat for Restart Procedure Compliance Sat for Restart Training and Qualification Not Evaluated CHEMISTRY Worker Practices Sat for Restart Training and Qualification Sat for Restart LICENSING Training and Qualification Sat for Restart Corrective Actions /Self Assessment Program implementation Trending Effectiveness Sat for Restart AITTS CAD Management Unsat Overdue Assignments Tracking to Sat OE Effectiveness Tracking to Sat Root Cause Quality Tracking to Sat initial CR Screening Sat for Restart Conduct of CAD CRs/ACRs Sat for Restart I
Work Management Program WORK PLANNING AND OUTAGE MANAGEMENT POD. Effectiveness Not Evaluated Work Package Quality Sat for Restart Post Maintenance Testing Sat for Restart
'. Preventive Maintenance Program Unsat MAINTENANCE FME Sat for Restart Conduct of Maintenance Tracking to Sat Overall Effectiveness of Plant Maintenance Program Tracking to Sat Procedures Program OPERATIONS Procedure Use Sat for Restart Procedure Quality Unsat MAINTENANCE Procedures / Document Control Sat for Restart
l U.S. Nucl ar R:gulttory Commission B17485%ttachment 2\\Page 3 q
INSTRUMENT AND CONTROL Procedures / Document Control Sat for Restart PROCEDURES Technical Adequacy of Procedures Tracking to Sat Training Quality of Accredited Programs Sat for Restart Quality of Non-Accredited Programs Sat for Restart Simulator Fidelity Sat for Restart Management Support of Training Unsat Environmental NPDES Performance Sat for Restart SYSTEM READINESS Configuration Management OPERATIONS Tagging Process / Practices Sat for Restart Document Control / Availability Sat for Restart ENGINEERING Configuration Management Sat for Restart Engineering Programs Unsat l
Design Control Design Quality Sat for Restart NCRs Sat for Restart Effectiveness of PRA Usage Sat for Restart
)
Temporary Modifications Sat for Restart l
i 10 CFR 50.59 Process 10 CFR 50.59 Safety Evaluations Sat for Restart Engineering Skills Enhancement Effectiveness of Engineering Support Tracking to Sat Conduct of Engineering Tracking to Sat Physical Plant Work l
No applicable window l
The Maintenance and Work Control and Outage Management l
departments report restart required work is complete.
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' U.S. Nucl:ar Regul tory Commission l
B17485\\ Attachment 2\\Page 4 l-System Operability j-Operator Burdens (Work Arounds)
Tracking to Sat Temporary Modifications Tracking to Sat f
Black Board Alarms Not Evaluated Operability of Tech Spec Systems Sat for Restart Secondary, Support Systems Available Tracking to Sat Tech Specs Unsat Adequacy of System Lineups Tracking to Sat ENGINEERING Maintenance Rule Unsat System Readiness Not Evaluated Testing Program OPERATIONS l
- Surveillance Tests Tracking to Sat i
Power Ascension Procedures Tracking to Sat MAINTENANCE L
M&TE Sat for Restart Surveillance Testing Sat for Restart
- lNSTRUMENT AND CONTROL M&TE Not Evaluated l
Surveillance Testing Sat for Restart ENGINEERING Surveillance Tests Sat for Restart Adequacy / Power Ascension Procedures Sat for Restart CHEMISTRY Surveillance Testing Sat for Restart Plant Material Condition L
OPERATIONS Housekeeping Tracking to Sat l
MAINTENANCE Control of Chemicals / Material Storage Tracking to Sat Housekeeping Tracking to Sat INSTRUMENT AND CONTROL Housekeeping Sat for Restart l
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j I7 U.S. Nuclerr R:gulatory Commission B17485\\ Attachment 2\\Page 5 i
CHEMISTRY Control of Consumable Chemicals -
Sat for Restart Housekeeping Tracking to Sat l-I OPERATIONAL READINESS l
OPERATIONS l-Awareness of Plant Status Sat for Restart i
Staff Levels Adequate -
Sat for Restart Required Reading Not Evaluated l
Work Observations Sat for Restart j
Awareness of Plant Security Sat for Restart REGULATORY READINESS l
LICENSING l
Technical Specifications Tracking to Sat Reportability Determinations and LERs Sat for Restart Commitment Management Tracking to Sat l
Final 10 CFR 50.54(f) response -
Tracking to Sat
_ NRC Significant items List Tracking to Sat
' Confirmatory Order - lCAVP Tracking to Sat
- Confirmatory Order - ITPOP Tracking to Sat Confirmatory Action Letter - Operator Training Sat for Restart
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10 CFR 50.54(f) Significant items for Restart complete Tracking to Sat i
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