ML20202B119
| ML20202B119 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/31/1998 |
| From: | Langan J, Laplante J, Mcelwain J NORTHEAST NUCLEAR ENERGY CO. |
| To: | |
| Shared Package | |
| ML20202B110 | List: |
| References | |
| PROC-980131, NUDOCS 9802110120 | |
| Download: ML20202B119 (32) | |
Text
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MILLSTONE UNIT 3 r
OPERATIONAL READINESS PLAN f
Prepared Ev: ((. AWM Date: i/t?[f/ '
(([f h. A. Langati(
Reviewed Dy: # N Date: / 7 '/
- 9 4
[/ J. Z. LaPlante V NA _5f - Dre: / do-X Approved By: (/ ' [P. Mc'Elwain Approved By: /4ffI N Date: 4%
M. ll.Mrothers
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Unit 3 Operatonal Reediness Plan Revision 5
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7 TAHLE OF CONTENTS 1.0 letraluction :
1.1 Purpose :
- 1.2 flackground [
1.3 Nuclear Regulatory Commission Restart Process IA Roles and Responsibilities 2.0 Perforniance Assessment 2.1 13ackground 2.2 Recovery Strategy 3.0 Restart Issues Management ;
i 4.0 Restart Elements 4.1 Ornanization Readiness 4.1.1 Management Oversight and Effectiveness 4.1.2 iluman Performance 4.1.3 Corrective Action /Self Assessment Program implementation 4.1.4 Work Management Program 4.1.5 Procedures Program 4.1.6 Training 4.1.7 Environmental 4.2 System Readiness 4.2.1 Configuration Management 4.2.2 Design Control -
4.2.3 10 CFR 50.59 Process i 4.2.4 Engineering Skills Enhancements 4.2.5 Physical Plant Work i
4.2.6 System Operability 4.2.7 Testing Program 4.2.8 Plant Materiel Conditions 4.3. Otwrational Readiness i
Unit 3 Operational Readiness Man i Revisica 5
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4.0 itestart Elements (con't) 4.4, Regulatory Readiness 4.5 Communications Strateny 4.5.1 What Should be Communicated 4.5.2 Unit Wide Communications Approach
- 5.0 Operational Meediness Assessment 5.1 Line Assessments 5.2 Nuclear Oversight Assessment 5.3 - Employee Review Committee Assessment 6.0 ' - Startup and Power Ascension Program 6.1 Objective 6.2 Testing Program 6.3 Startup and Power Ascension Administration 7,0 Long Term Operational Objectives
- Attachments I, Regulatory Process t
E Unit 3 Operational Readiness Plan il Revision 6
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1.0 INTRODUCTION
l',1 Purpose A clear understanding of the causes leading to the decline of Millstone's performance has been achieved through the use of various investigation and mot cause techniques, improved perfonnance must be demonstrated to the public, regulatory agencies, and the employees to ensure Unit 3 can be safely returned to power operation. Mill"one management has developed the Unit 3 Operational Readiness Plan (ORP) to identify and control the actions necessary to achieve and maintain improved performance, incorporated into the ORP are the topics previously contained in the Millstone improving Station Performance (ISP) Plan and selected elements of the Nuclear Excellence Plan (NEP). Once Millstone management determines plant readiness for restart has been achieved, a request will be submitted to the NRC for approval to return to power operation.
1,2 Itackground l Millstone Nuclear Power Station was designated as a Watchlist Category 2 facility by the NRC on 1
January 29,1996. On Mareb 7,1996, Unit 3 received a letter from the NRC requestirg the unit provide, within 30 days, the actions taken, or plar ed to be taken, to address the conclusions of ACR 7007 as they pertain to Unit 3.
During the month of March, Unit 3 was the focus of a special NRC inspection of engineering and licensing activities. On March 31,1996, Unit 3 shutdown when a deficiency that would have prevented the Auxiliary Feedwater containment isolation valves from performing their safety function was identified. On April 4th,1996, as a result of the findings of the Special Inspection, the NRC forwarded Unit 3 a 10 CFR 50.54(f) request for information, requiring Northeast Utilities describe those actions taken to ensure that future operations at Millstone Unit 3 will be conducted in accordance with terms and conditions of the Millstone Unit 3 operating license. This letter wo , subsequently superseded by the NRC 10 CFR 50.54(f) request for infonnation dated April 16,1997.
On June 21,1996, the NRC forwarded a letter confirming Millstone's continued status as a Watchlist Categg 2 facility. On June 28,1996, Millstone was designated by the NRC as a Watchlist Category 3 facility, in a letter dated Augu.,t 14, 1996, the NRC issued an order requiring the establishment of an Independent Corrective Action Verification Program (ICAVP). A suond confinnatory order was issued by the NRC in a letter dated October 24,1996, which required the establishment of a corsprehensive plan to address the handling of employee concerns by an independent third party. A Condrmatory Action Letter was issued by the NRC in a letter dated March 7,1997, confirming our ongoing efforts and commitments to evaluate and correct problems found within the licensed operator training programs at Millstone.
1.3 Nuclear Regulatory Con, mission (NRC) Restart Process Prior to NRC approval to restart, the following regulatory items must be addressed and satisfactorily completed (Unit 3 actions required by these regulatory items are included in the ORP):
)
Manual Chapter 0350 Process / Operational Safety Team inspection (OSTI) 1
- - Section 50.54(f) Activities '
- NRC Significant items List Unit 3 Operato..I Rea$ ness Plan 1 Revision 5
.e .
. e Independent Corrective Action Verification Program Order
- Employee Concerns Third Pany Oversight Order
- Confirmatory Action Letter Operator Training
- Commission Vote Additional detail is provided in Attachment i 1.4 Roles and Responsibilities The successful implementation of the Unit 3 ORP requires a consolidated team effon. The following is a list of roles and responsibilities of the key team members Vlec President - Operat!ons/ Unit 3 Recovery Offleer - Responsible for providing the overall strategy for restut and estab!!shing performance expectations Vice President Nuclear Oversight Responsible for advising the Unit 3 Vice President as to the readiness of Use 3 for restart.
Unit 3 Management Implement action plans and corrective actions to support restart readiness.
Unit 3 Employees - Support the implementation of the ORP by focusing on plant safety end continuous improvement Key to this responsibility is the obligation to raise any and all identified quality and safety concerns to management's attention for resolution Management Review Committee (MRC) The MRC is an ad hoc management oversight board charged with reviewing organizational readiness ofline and selected suppon organizations. The MRC shall be made up of nembers cf the Unit 3 management team as assigned by the Unit Vice President. Challenge meetings will be scheduled as required to review department's readiness to suppon saft operation, and review action plans for areas determined to need improvement. The commt: tee performs a management oversight function, and, therefore, does not fall u . der the purview of 10 CFR $0, Appendix B.
2.0 PERFORMANCE ASSESSMENT & RECOVERY 2.1 Hackground The causes for the performance declinc at Millstone have been assessed and documented in various Millstone root cause analyses, such as ACR 7007 CR M3 971839, the Fundamental Cause Assessment Team report, the Joint Utility Management Association report and several NRC Inspection Repons. The issues can be summarized as follows:
- Senior executives at Nonheast Utilities (NU), from the CEO to senior nuclear site executives, were ineffective over a number of years in providing vision, direction, and leadership necessary for the management of the NU nuclear power program.
Unit 3 Operational Readiness Plan 2 Revision 5
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t Senior management failed to provide the nuclear organization with clear direction and oversight in several key areas including, performance standards, station priorities, and management expec.ations. The message that safety wr's a higher priority than cost effectiveness was not consistently understood by the workforce.
Many of the more important initiatives and activities intended to address identined issues, such as employee concerns, design bases, con 0guration control, and correction of backlog, did not receive consistent and clear management direction and support, nor did they have adequate owner accountability.
e Key performance weaknesses, such as an effective corrective action program, licensed operator quali0 cation standards, and critical self evaluation processes, were not addressed in a prompt comprehensive and lasting fashion.
- Senior management did not ensure effective communication throughout the nuclear organization. They did not recognize the existence of the horizontal and vertical barriers to two way exchange of infonnation and the resulting loss of trust and con 0dence in management at the Millstone sites. Further, top management discouraged information that con'.radicted their understanding of the nuclear organization.
Top management did not establish a cooperative and supportive team atmosphere among l groups competing for resources and recognition. This was particularly true of the Operations
( and Engineering organizations where an appreciation of each others role and importance to l plant safety was lacking.
l Collectively, this resulted in a loss of trust and cr dibility of manageruent with employees, regulators, and the general public. To restore trust, standards must be raised and a strong and healthy nuclear safety environment must be maintained, llowever, ineffective leadership led to a breakdown in areas that are critical to maintaining high performance standards. These issues were identined from the principal recurring causat factors contained in several critical assessments of Millstone performance and NRC inspection reports it is the weaknese in these key areas that has resulted in the numerous technical and process deficiencies that have been identified to date. It is understood that until these key areas are functioning effectively, reasonable assurance cannot be given that signincant technical and process denciencies will not recur in the future.
The key .ssues which must be satisfactorily addressed prior to restart include:
- Leadership e Safety-Conscious Work Environment
- Self Assessment
- Corrective Action
- Nuclear Safety Assessmer" Board (NSAD)' Oversight
- Configuration Managemt
- Regulatory Compliance
- Conduct of Safe Operations Training
- Conduct of Safe Operations - Operator Readiness
. Work Control and Planning
- Procedure Qual' .nd Adherence e Programs W1 Protect IIcalth and Safety (including Emergency Preparedness, Fire Protection. Radiological Protection, Security, and Environmental).
Unn 3 Operstonal Readiness Plan 3 Revision 5 m___
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l 2.2 Recovery Strategy To address the root cause of inefTective leadership, new lcadership has been appointed. This leadership team includes highly experienced managers with proven records of good perfonnance at other nuclear utilities. In addition, supervisor and above leadership development has been undertaken in order to raise standards and promote teamwork.
j Executive Sponsors and issue Managers have been named for each of the key issues. Under the Executive Sponsor's guidance and continuing support, the issue Manager has complete authority to address the issue from a site wide perspective. Specifically, the Executive Sponsors and issue ;
Managers have the responsibility to:
- Establish ownership and accountability
- Set clear standards and expectations e implement effective Corrective Actions e Monitor performance progress The current ste.tus of each of these issues i. provided in the NRC Commissioner's Briefing Book.
The purpose of this Operational Read; ness Plan is to provide a plan for assessing restart readiness from a Unit perspective. This will include assessing department and Unit performance in those key issues which lend themselves to measurement on a Unit basis. This ORP is also based heavily on the performance attributes called out in Manual Chapter 0350, the Operational Safety Team inspection (OSTI) Inspection procedure, and INPO 96-006, " Performance Objectives and Criteria for Operating Nuclear Electric Generating Stations."
3.0 Restart Isshe Management Millstone 3 is controlling its work items to ensure that all items are completed which:
- Support Nuclear Safety, e Establish and maintain the Licensing and Design Basis, e implement an efTective Employee Concerns Program, and
- Maintain safe and reliable operations.
The unit's specific process h, in general, represented by the generic discussion which follows.
Work items originate from various documents, depending on v,hich program the work item came from. The major documents that generate work or represent work items are the Unresolved item Report (UIR), Open item Report (OIR), the Condition Report (CR), the Non Conformance Report (NCR), the Automated Work Order (AWO), the Engineering Work Request (EWR),
Operator Work Arounds (OWA), Control Room Deficiency (CRD), and Temporary Modifications (TM). Other documents exist, however, they are generally daughter documents generated to resolve an issue identihed by one of the higher level documents previously mentioned. In addition, these documents can be linked to each other. For example, a CR may generate an EWR.
Unit 3 Operational Readiness Plan 4 Revision 5
As items are identined through UIRs. OIRs, CRs, NCRs, AWOs, EWRs, OWAs, CRDs, and ,
, TMs, the associated activities are screened to determine if they should be completed prior to startup. Figure I depicts the general process. If an item is an AWO, it is reviewed to distingolsh between work that should be considered fe, the current outage and work that is scheduled for the future. An example would be preventive maintenance. There are many AWOs that exist for future scheduled preventive maintenance that do not represent deferred work.
All other AWOs and all UIRs, OIRs, CRs, NCRs, EWRs, OWAs, CRDs, and TMs are then reviewed for priority. Work identined for completion prior to restait includes:
- 1. Any item that supports or implements a Technical Speci0 cation change that is required for startup,
- 2. Any item that corrects or resolves a Licensing 11 asis or Design Ilasis denciency. This includes FSAR discrepancies (not including enhancements and editorial clarifications) identided prior to the end of discovery on 8/13/97, and any FSAR change approved prior to i1/lS/97,
- 3. Any item that involves a commitment to the NRC for completion of specified activities prior to restart, and
- 4. Any item that is required for a Mainte iance Rule (10 CFR 50.65) group 1 or 2 system to be operable or to perform its design basis function, it is recognized that certain discrepancies may exist on Maintenance Rule group 1 or 2 systems that do not impact operability and may be considered for Jeferral, subject to available materials and resources, if an item is selected for deferral, it is reviewed by management to ensure the deferral is appropriate.
Management may either concur with the deferral, or direct the item to the restart worklist.
- UnR 3 Operational Readiness Ptan 5 Revision 5
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4.0 RESTART ELEMENTS There are five major elements of restart readiness. Org.mization, System. Operational, Regulatory and Communications. This section describes the initiatives necessary for each element to demonstrate I
restart readiness and establish a foundation for long tenn sustained improvement.
ORP Sections 4.1 through 4.4 identify the specific performance indicators designed to measure restart readiness. The performance indicators are taken from the Millstone Unit 3 Performance Assessment Windows. The Unit 3 Performance Assessment Windows is a management tool which includes i indicators relevant to both restart and operational performance. As a management tool, the performance windows will be revised as necessary to achieve current management goals and objectives.
j lt is not intended to revise the ORP if the perfor nance windows are adjusted.
Each indicator in the performance windows can assume one of five different states, as follows:
, Red: Falls short of expectations, acceptance criteria or goals are impacted.
I Yellow: Falls short of expectations, acceptance criteria or goals are not impacted.
l White: Meets expectations.
Green: Exceeds expectations.
Blue: Currently unassessed or under development.
The specific success criteria for each relevant indicator is described in sections 4.1 through 4.4. 'the performance windows are periodically assessed and updated.
4.1 Orraniration Readiness 4.1.1 Management Oversight and Effectiveness Objectivet The objective of management is to establish organizational culture and values. At the heart of Unit 3 culture is a consideration for Nuclear Safety and a profound respect for the nuclear core. Supporting nuclear safety is an organizational focus on raising standards, completing effective corrective actions, establishing accountability, and fostering a spirit of continuous improvement.
Success Criteria:
The following Management Oversight and Effectiveness performance windows must be evamated as either green, or yellow with a Corrective Action plan in place and sustained improvement being made:
- Standards and Expectations Communicated tc the Staff
- Commitment to Achieving improved Performance
- Nuclear Safety
- Understanding of Plant Issues and Corrective Actions
- Effectiveness of Management Review Committees
-ALARA
- Procedure Compliance Unit 3 Operational Readiness Plan 7 Revision 5
4.1.2 . Iluman Performance 4
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 stafiqualincation and training l Success Criteria:
The following performance windows t,st he evaluate ' as either green, or yellow with a Corrective Action plan in place and sustaineu improvement being made:
- Training /Qaali0 cation (Operations, Mechanical Maintenance, I&E, Maintenance Planning, and Engineering)
Staff Levels Adequate (Operations) lluman Performance (Operations, Mechanical Maintenance, I&E, Maintenance f
Planning, and Management Oversight and Effectheness)
- Industrial Safety (Management Oversight aad EITectiveness)
- Events (Operations) 4.1.3 Corrective Action /Self Assessment Program implementation Objective:
An efTective corrective action program is necessary to identify, correct, and prevent recurrence ofidentified pr/olems, in the identincation 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 detennined in a timely manner, if necessary, root cause assessment 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 perfonnance wmdows must be evaluated as either green, or yellow with a Corrective Action plan in place and sustained improvenient being made:
- Initial CR Screening
- alTTS CAD Management
- Overdue Assignnients
- OE Effectiveness
- Conduct of CAD CRs/ACRs
- Conduet of CAD Self Assessment
- Root Cause vaality
- Effectiveness of MRT
- Trending Effectiveness
- CR Close Out Timeliness Unit 3 Operational Readiness Plan 8 Revision 5
4 t 4.1.4 Vork 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, emcient scheduling, and an awareness of the safety impacts associated with equipment outages.
Success Criteria:
The following performance windows must be evaluated as either green, or yellow with a Corrective Action plan in place and sustained improvement being made:
Work Centrol & Outage Management
- Surveillances
-Schedule Adherence Conduct of Work Planning Maintenance:
Conduct of Maintenance (Mechanical and 1&E)
- Work Package Quality Overall difectiveness of Plant Maintenance Program (Mechanical and I AE)
Maintenance Backlog Management l
Average Age of Backlog AWOs Post Maintenan;e Testing Preventive Maintenance Program 4.1.5 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.
Success Criteria:
The following performance windows must be evaluated as either green, or yellow with a Corrective Action plan in place and sustained improvement being made:
Procedure Compliance (Management Oversight & Effectiveness, Maintenance, and Operations)
- Procedure Quality (Operations)
- Technical Adequacy of Procedures (Mechanical Maintenance and 1&E)
- Document Control / Availability (Operations)
- Procedures / Document Control (Maintenance)
Unit 3 Operatonal Readiness Plan 9 Revision 5 l
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i 4.1.6 Training Objective:
Training pcograms utilizing the systematic approach to Training must be in place and functioning to ensure adequately trained Operations, Maintenance and Engineering staff is available to support restan.
Success Criteria.
The following Training performance windows must be evaluated as either i,rcen, or yellow with a Corrective Action plan in place and sustained improvement being made:
Simulator Fidelity i
Management Support of fraining Licensed Operatur Continuing Training
- Non Licensed Operator Training STA 4.1.7 Entlennmental Objective: . .
An c%ctive cavironmental management program is necessary to ensure that discharges from the plant are performed in compliance with environmental regulations.
l Success Criteria:
The following Chemistry performance window shall be evaluated as either green, or yellow with !
a Corrective Action plan in place and sustained improvement beir.g made:
NPDES Perfonnance 4.2 System Bendiness 4.2.1 Configuration Management Objective:
One of the key underpinnings supponing nuclear safety is the assumption that the plant design basis and licensing basis are accurately re0ceted -in the physical plant construction and associated operating, maintenance, and test procedures. Unit 3 has undertaken a Configuration Management Plan to verify the integrity of the design and licensing basis and verify it is properly translated into the physical plant.
Success Criteria:
The following Engineering pedormance window must be evaluated as either green, or yellow with a Corrective Action plan in place and sustained improvement being made:
Configuration Management UnR 3 Operstional Readiness Plan 10 Revision 5
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1 4.2.2 , Design Control ;
Objective: 1 Once the design and licensing basis has been verified, they must be maintainea. Thus, controls I are required to ensure proper con 0geration management on a going forward basis.
Success Criteria i The following Engineering performance windows must be evaluated as el;her green, or yellow with a Corrective Action plan in place and sustained improveme it being made:
- Design Quality NCRs Temporary Modincations Effectiveness of PRA Usage J
4.2.3 10 CFR 50.59 Process Obyctive:
10 CFR 50.59 safety evaluations must be compete and comprehensive to support safe operation and appropriate operability determinations.
Success Criteria:
The following Engineering performance window must be evaluated as either green, or yellow with a Corrective Action plan in place and sustained improvement being made:
- 10CFR50.59 Safety Evaluations i
4.2.4 Engineering 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 proucient to suppon the safe and eflicient operation and maintenance of the plant. .
Success Criteria:
The following Engineering performance window must be evaluated as either green, or yellow with a Corrective Action plan in place and sustained improvement being made:
Conduct of Engineering 4.2.5 Physical Pl nl Work Objectivet Required modifications, corrective maintenance, preventive maintenance, and asrociated testing is complete or scheduled for required plant mode.
Success Criteria:
--- The Maintenance and WC&OM departments report restart requ. , work is complete.
Unit 3 Operauonal Readiness Plan 11 Revision 5
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4.2.6 System Operability Objecthet All systems required for restart and plant operation are operable or awalting scheduled testing at required plant mode. llalance of plant systems and necessary supp- 1 systems are also operable.
Success Crlierlat 1he following performance windows must be evaluated as either green, or yellow wita a Corrective Action plan in place and sustained improvement being made:
Engineering:
. System Readiness Resuhs of System Testing Operations:
Operability of Tech Spec Systems Operability of Required Secondary and Suppon Systems
. Operator livniens
. Adequacy of System Line ups Post Maintenance Testing Illack Doard (Alarms) 4,2,7 Testing Pavgram Objectives
- Suncillance testing must be technically accurate and complete to support operability of as ociated systems. Additionally, a power ascentbn test program, including required stanup testing, must be developed and approved.
Success Criteria:
The following performance windows must be evaluated as either green, or yellow with a Corrective Action plan in place and sustained improvement being made:
Engineering:
- Adequacy of Power Ascension Testing
- Sun cillance Testing -
Operations:
Surveillance Tests Adequacy of Power Ascension Procedures
. Procedure Quality. Surveillancesi IAE and Mechanical Maintenanse:
. M&TE:
. Technical Adequacy off Procedures
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Una 3 Operstonal Read 6 ness Plan 12 Revision 5 l
4.1J . Plant Materiel Condition Objettiver Prooer 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 labeling, appropriate leak collection, and control of contaminated wrface areas.
Success Criterlat - _
i The following performance windows must be evaluated as either green. or yellow with a j Corrective Action plan in place and sustained improvement being made: l llousekeeping (Maangement Oversight & Effectiveness and Mechanical Maintenance)
Control of Consumable Chemicals (Chemistry) 4.3 Operational Headiness Objective:
Operational activities must be cot ducted in a marner that ensures safe, conservative, and reliable operations. Nuclear Safety and profound respect for the core must be foremost in operational decisions. Operations pers'.,nel are to be cognizant of the status of plant systems and comply with all applicable regulations and the Technical Specifications.
7 Success Criterlat L The following Operations performance windows must be evaluated as either green,'or yellow with a Corrective Action plan in place and sustained improvement being made:
. Staff Levels Adequate Worker Practices
. Required Reading Awareness of Plant Security
. Work Observations' Awareness of Plant Status Una 3 Operatonal Readiness Plan 13 Revision 5 q _
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I 4.4 Regulatory Readiness - t
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Objectives i An effective organization to address regulatory issues must exist. This includes adequate Technical Speel0 cations that ax both understandable and acceptable for plant operation, in ,
addition, regulator commitments must be tracked and fulfilled. !
Success Criteria: i
- 1. : The following performance windows must be evaluated as either green, or yellow with a i Corrective Action plan in place and sustained improvement being made:
- Tech Spec improvement Plan (Licensing)
- Commitment Management (Licensing) :
Tech Specs (Operations)
- 2. 'llie final 10CFR50.54(f) response for Unit 3 must be complete and submitted to the NRC. !
2
- 3. The NRC Significant items List (SIL) must be complete.
- A summary root cause has been performed to umbrella ACR 7007, CR M3 971839, QAS failure evaluation, FCAT fundamental cause evaluation, and JUMA. Corrective actions have i
been verified to be in place, and the results of this evaluation included in the Gnal 10 CFR 50.54(f) response.
- 5. The Confirmatory Order for an independent Corrective Action Verification Program is rescinded or modified.
- 6. The Confirmatory Order for an independent Third Pany Oversight Panel is rescinded or .
modified.
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- 7. The Confirmatory Action Letter on Operator Training is complete.
- 8. 10 CFR 50.54(f) Significant items for Restart are complete. i
. 4.5 Communications Strateny Face to-face communication is tbc most effective way to disseminate information and accomplish the following objectives:
e' - Establish an atmosphere of trust and credibility among employees and management
.- Keep employees fully informed ofissues, developments, and management expectations in an 4
honest and timely manner.
-e Build enduring knowledge, support, and ownership responsibility for the readiness plan and its vision.
Following are additional elements of the communication strategy. A communications matrix which describes communications activities, their audiences, and suggested frequency, is also pan of the plan.
Una 3 Operational Readiness Plan 34 Revisen $
_ - . , _ _ . _ . _ . . _ , _ .~ - , _ _ . _ . _ - - - _
e o 4.5.1 What Should lie Communleated hhe information communicated falls into many different categories:
- Management philosophies and messages.
- Progress and Celebration of successes by individuals and/or groups.
- Challenges that lie ahead.
- Industry and Unit specinc experience that should be communicated to all unit personnel, such as lessons learned.
- Management feedhack on its plans and commitments.
- Other information that is useful, of interest, or of value from the standpoint of employee mornle.
1 e
Communication across working groups should be stressed and the emphasis should be continuous. Also, employees need to know that their comments / suggestions / constructive critielsm 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 ccmmunication 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.
- Unit Vice-President meeting with supervisors, managers, and directors to review status, goals, and future initiatives.
4.5.2 Unit Wide Communleations Approach A communications matrix has been created which lays out the plan for communications, both interpersonal and written. The plan has been developed to ensure enough contact between upper management and other management levels and to provide management's philosophies and expectations from top to bottom.
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.
Und 3 Operatonal Readiness Plan 13 F<evision 5
4 0 Other vehicles are unit specific. T hey are:
- Face to Face Meetings:
Face-to face meetings are the preferred method for communicating information on the unit, face to face includes not only interaction between employees and immediate management, but -
also interactions between employees and unit senior management it should be made clear that u written communications do not replace face to-face communications.
- All bands meetings:
In many cases, faceno face communication is more appropriate in large groups. There have l
been, and will be, cecasions 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 snecting should be discussed in department meetings. As discusseo above, employees want to get most of their information from their immediate manay rment, and brief meetings are an imponant element.
- Unit management letters and memos:
In many cases, timely infonnation is best communicated by management. These come out on a regular, as-needed basis. The objective is to project the fact that management is keeping the work force informed and recognizing individual achievement, e Unit / Department Celebration / Motivational Events: There will be times when an event, such as a rally or picnic, will be appropriate. These can be used to celebrate succe s, rally support for upcoming challenges, and convey a sense of teamwork.
Unit speelfic print communications: Examples include unit dailies, weekly _
reports, issue specific picture stories, officer letters / memos, etc. Two important messages that are crucial in our cominunications are individual and group
- recognition and progress, Unit 3 Operatonal Readiness Plan 16 Revision S
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. . TEMPLATE FOR MECOVERY OFFICER / DIRECTORS
, FACE-TO FACE COMMUNICATIONS PLAN ACTIVITY EMPLOYEE AUDIESCE RESPONSlHI E SUGGESTF1
- INDIVIDUAL FRF0Qi~ icy, i
- j. Management Staff Meeting Directors / Managers Unit Oflicer Daily Unit Walkdown with Department . Managers Unit Officer Monthly 1
Manager Employees Unit Director Weekly Depanment AIMiands Meetings ist Line Supervisor & Non- Unit Officer Monthly s
, (Note: May include the enilre Gupervisory Personnel Unit Director Weekly department orjust a major group in Unit Engineering Director Weekly the department)
Unit 3 Strategy Meeting Unit Director Unit Omcer Weekly Engineering Director 4 Employee Communications Simulator Observations Licensed Operators Unit Vice President Monthly ,
Unit Director Monthly
- System Engineer Plant Walkdowns System Engineers Unit Engineering Periodically ;
Director Operating Shin l'urnover Operating Shin Unit Officer Monthly Unit Diructor Monthly i
- Meetings with First Line Supervisor First Line Supervisors and above Unit Officer Quarterly and above (1he Management Team) -
Meeting with Operations Shin Shin Managers Unit Ollicer Weekly Managers "
- NRC NRC Resident inspector Unit Officer Weekly Engineering Director NRC NRC Region /IlQ Unit Officer Monthly Management
" A quarterly meeting of the Unit Omcer with all supervisors, With Unit progress, the frequency may be extended. Unit and Engineering Directors will meet with all of the first-line supervisors in one department (e.g., Mainto ance) on a bi-weekly basis.
"' The Unit Director will meet with at least one Operations shift manager on a weekly basis, except w hen the unit conditions or being away from the unit preclude it.
FACE TO FACE COMMUNICATIONS PLAN (Cont.)
e Unit 3 Operatenal Readiness Plan 17 Revision 5
o . .
TEMPLATE FACE-TO FACE COMMUNICATIONS, LAN For Department Managers ACTIVITY EMPLOYEE AUDIENCE SUGG ES'I ED FREOUENCY Status Meetings Management Team Daily Department All llands All Department Employees ill Weekly Mangrent Observation of Iraining Employee Groups Monthly /
l Weekly for Licensed Ops Requal Ops Manager Meeting Ops Shill Managers Weekly l Meeting with First Line Supervisors First Line Supervisors til weekly Customer /Corwrate Support / Vendor Periodic Invite NU Nuc car senior management All Department Members Periodie (above Director level)to speak to department I
Una 3 Operatonal Readiness Plan 18 Revisen $
5.0 OPEllATIONALllEADINESS ASSESSMENT kJnit readiness asressment is the process by which Unit 3 will determine its readiness to support safe an reliable startup and power operation. Satisfaction of the success criteria described in Section 4 ensures the Millstone Station success objectives, embodied below, are met:
Millitone Station Succens Ohlectives liigh standards and clear accountabilities e incorporate many best practices from other utilities e Regularly benchmark with other nuclear utilities e Indicator show strong improvement toward excellence e Commitments are met Strong nuclear safety policy
- Careful adherence to high nuclear safety standards e Conservative decision making Effective self assessment
- Significant issues are identified by NU rather than the regulator Effective Correctise Action process e
Corrective actions and commitments are prioritized and resolved in a timely manner e improved regula'ory performance as demonstrated by decreases in NRC violations and LERs i
Restored licensing and design bases with process to ensure that they are properly maintained e ICAVP contractor confirms that the design and licensing bases have been restored e implemented effective configuration control processes An environment that supports the identification and effective resolution of employee concems
- Open and candid communications e Timely resolution of employee safety concerns
- Independent review of employee safety concerns coalirms effectiveness Commitment to achieve excellence in nuclear operations Excellence has been defined, a plan to achieve has been developed and there is good demonstrated progress e issues important to startup have been resolved e
Resource commitments meet or exceed thor of similar well run units Restart readiness asse;! ment shall consist of the following elements:
Und 3 Opershonal Rea$ ness Plan 19 Revision 5
5.1 1.ine Assessments Line and support department assessments of restan readiness, L described in Section 4 shall be performed periodically. Each Depanment Manager is responsible for determining their depanments overall " Readiness for Restart", based on a comparison of the results of their asseument with the success criteria contained in Section 4. This qualitative assessment should consider the aggregate impact of restart items requiring improvement.
Completed department assessments shall be reviewed by the Manag ment Review Committee. The MRC shall revicw:
(1) Criteria, to verify an adequate standard has been sstablished for restart.
(ii) Assessment nr.ethod, to verify the method used to assess performance against criteria is valid.
(iii) Assessment result, to verify the conclusion isjustiGed in light of the .riteria.
(iv) Corrective Actions plans to verify they are adequate to improve performance.
(v) The overall departments readiness for restart to verify the aggregate department performance is sumclent to support restart The MRC shall provide a recommendation to the Unit Recovery OfHeer as to the readiness of the Unit to restart.
5.2 - Nuclear Oversight -
Nuclear Oversight shall perform an independent assessment of restart readiness through their Nuclear Oversight restan verincation plan (*lORVP).
5.3 Employee Review Committee The Unit 3 Employee Review Committee shall provide a recommendation to the Unit 3 Recovery OfGeer on the units readiness for restart. -
6.0 STARTUP AND POWER ASCENSION PROGRAM 6.1 - Objective The objective of the Startup and Power Ascension program is to ensure a safe, event. free restart of the unit. Startup from this extended shutdown will be complicated by the following factors:
(i) - Systems have been out of service for an extended period of time (ii) A large number of maintenance activities and modi 0 cations have been made (iii) Plant operating crews have not operated at power for an extended period of time The objectives of the'Startup and Pcwer Ascension program will be considered to be met when the unit has been restarted, and is running:
~ '
(i) Without signincant events or challenges to safety systems (ii) With a minimum of reportable events (iii) Without lost time accidents und Opersuonal Readiness Plan 20 Revision 5
6.2 Testing Program
'hhc Startup and Power Ascension program involves an integrated and systematic approach to establish the readiness of equipment in areas where corrective maintenance and modi 0 cations have been made during the shutdown. The test program is based on attributes of other successful stanup and restart programs tised in the nuclear industry.
Startup and power ascension testing consists of:
(i) component level testing (ii) system level testing (iii) integrated functional testing (iv) power ascension testing Where possible, existing surveillance procedures will be used to verify component and system operability following completion of maintenance and modi 0 cation activities. Where existing procedures are not sufucient to verify component functionality, a Special Procedure (SPROC) and/or Inservice Test i (IST) will be written. Tetts and procedures will be written in accordance with applicab!c station l administrative procedures. As required, SpROCs and ISTs are subject to a documented safety evaluation pursuant to 10 CFR 50.59.
With the plant in Cold Shutdown (htode 5) a series of component and system level tests will be perfonned to verify the readiness of the plant to proceed to startup. As work is completed on components and systems, post maintenance and post modi 0 cation testing will be performed to verify components and systems are capable of perfonning their safety function. As noted earlier, these tests may either be existing surveillance procedures, or unique procedures specifically geared to verifying system functionality following modification. Where the Configuration Management Program has raised questions as to a system's capability, special procedures may be run to verify the as-built system is capable of performing its safety function. Test results will be independently reviewed, as well as being l
reviewed by either the hianagement Review Committee or the Plant Operations Review Committee prior to proceeding with testing.
Following completion of this testing, a series of tests will be run to verify integrated system operations.
These tests will primarily be existing integrated surveillance tests, including a Loss of Power Test on each safety related train, an integrated ESF with LOP Test, and a drawdown test of the Supplemental Leak Collection and Release System. These tests are intended to supplement post maintenance and post-modi 0 cation testing and verify that system interactions have not been unintentionally changed by modifications that have occurred during the outage. These test will also verify that the secondary containment boundary has been properly restored.
In addition to the biode 5 testing described above, the turbine plant will be started up and operated to allow for system flush and cleanup, as well as an assessment of its readiness to suppon unit restart.
Scaling steam will be put on the turbine, a cendenser vacuum drawn, and the condensate system placed in operation. Condensate will be run in both short recycle and long recycle to allow for system Chemistry to be adjusted, as well as for the system to be cleaned up. Any materiel problems, such as leaks, will be identifie) for later repair. Following completion of these activities, the turbine plant will be shutdown for cleaning and inspection of the condenser, and for repair of deficiencies identified during the startup.
Following completion of hiode 5 testing, and verification that all items required for mode change have been completed, the unit will begin a slow and deliberate heatup of the primary plant. Retest and surveillance activities requiring specific plant conditions will be performed as thosc conditions are established. Once Normal Operating Temperature and Normal Operating Pressure (NOP/NOT) have Unit 3 Operatonal Reatness Plan 21 Revision $
been reached, and testing completed, the plant will be cooled back down to Mode S. Denciencies uncovered during this startup will be repaired. Iloth the reactor plant and turbine plant will then be brought to NOP/NOT to await the Commission presentation and vote. Once Commission approval to restar1 has been obtained, the reactor will be brought critical and a controlled, deliberate power ascension started. The power ascension testing schedule will closely resemble a normal post refueling power ascension, with the notable exception of thw Power Physics Testing. Since the reactor has not been refueled during this outage, core physics characteristics will he veri 0ed as the plant ascends in Mode 1, but not at zero power.
6,3 Startup and Power Ascension Administration Startup and Power Ascension activities will be governed by two procedures. One procedure will denne the administrative requirements and guidelines under which the startup and power ascension will proceed. This procedure will define, among other things, an organization to provide management oversight of startup and power ascension activities, as well as define how emergent issues are prioritized and dispositioned. This procedure will also define a process by which the organization wi'l assess the performance ofits people, processes, and equipment. In addition, there is a Startup and Pow,r Ascension Sequencing Procedure tha' defines the sequence of startup and power ascension activities from Mode 5 through 100% power. Iloid pointa in this sequencing procedure are provided to allow systematic review and assessment of plant and personnel performance and to assure that both the plant equipment and the organization are ready to proceed with the startup. These assessment criteria incorporate important attributes and parameters, including plant materici condition, completion of necessary corrective actions, personnel performance, and responsiveness of the support activities.
7,0 LONG TERM OPERATIONAL OILIECTIVES The Unit 3 Performance Assessment Windows described in Section 4 is the management tool being used to prepare for restart. As such, we have established performance criteria at a level appropriate to support safe, event-free operation. This level, +. : going forward basis, would not be appropriate or consistent with our goals of achieving excellence in operations and industry leadership. Accordingly, the standards supporting the performance windows will be continaously raised, establishing a progren of continuous improvement. The cycle of self assessment, improvement, and higher standards will tie continuously repeated.
Prior to restart, a plan for addressing deferred items, as described in Section 3, will be developed.
Unit 3 Operatonal Readiness Plan 22 Hevision 5
ATTACllMENT 1 - REGULATORY PROCESS
- 1. Manual Chapter 350 Process NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelires for Restar1 Approval," .he NRC established process for approving restart of a nuclear power plant afler a shutdown resulting from a =
significant event, complex hardware problem, or serious deficiency. Restart review activities are coordinated by a Restart Panel in accordance with the Restart Assessment Plan. The Restart Assessment Plan includes a case specific restart checklist which evaluates: --
Assessment of Root Cause identification and Correction e Licensee Self Assessment and Management Effectiveness
. Assessment of Plant and Corporate Staff Effectiveness e Assessment of Physical Readiness of the Plant B Assessment of Compliance with Regulatc,ry Requirements 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) e Operational Safety Team inspection (OSTI)(IP 93802), and Operational Readiness Assessment Team inspection (RATI)(IP 93806)
The results of the above inspections, as well as other NRC assessments, will be considered by the Restart Panel, culminating in a restart recommendation by the NRC staff and restart approval by the Nuclear _
Regulatory Commission.
- 2. Section 50.54(f) Activities Each of the Millstone Units is presently subject to a request for information pursuant to 10 CFR 50.54(f),
dated April 16,1997. The April 16,1997 request supersedes all previous NRC requests and requires the following information be provided for each unit:
- l. The significant items that are needed to be accomplished prior to restart,
- 2. The list ofitems to be deferred until aller restart, -
- 3. The process and rationale used to defer items (identified in 2, above), and
- 4. The actions that have been taken to ensure that future operation of the unit will be conducted in accordance with the license, regulations, and UFSAR.
Unit 3 Operatonal Readiness Plan 1 Revision 5
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- 3. Independent Corrective Action Verification Program khe Independent Corrective Action Verification Program (ICAVP) completion is required prior to NRC restart approval. The ICAVP will review modifications of selected systems since initial licensing including:
(a) Review of engineer!.ig design and con 0guration control processes, (b) Veri 0 cation of die current as modified plant conditions against design basis and licensing basis documentation, (c) Verification that design and licensing basis requirements are translated into operating, maintenance, and test procedures.
(d) Verification of system performance through review of specific test records and observation of selected testing of particular systems, (c) Review of proposed and implemented corrective action of identified design deficis..cies.
- 4. Employee Concerns Due to "past faimres in management processes and procedures for handling issues raised by employees,"
and to ensure that the employees who raise concerns are not discriminated against, the NRC ordered Millstone prior to restart to: submit a comprehensive plan within 60 deys of issuance of the order to address the root cause of past performance failurer and propose within 30 days for NRC cpproval an independent third. party organization to oversee implementation of the plan, independent oversight will continue until Millstone demonstrates that the conditions which led to the order have been corrected to the satisfaction of the NRC,
- 5. Commission Vote l
Once the NRC Staffis satisfied that restart is appropriate it will prcpare a restart recommerdation for the Commission. The Commission approval process ordinarily will involve at least one public session (at NRC lleadquarters), with presentations by the NRC Staff and NU.
Unit 3 Operational Readiness Plan 2 Revision 5
- Docket No. 50-423 B16978 m
O Attachment 2 Millstone Station Unit No. 3 7 Operational Readiness Plan 3
e Performance Windows Status as of December 1997 Jantary 1998 l
U.S. Nucl:ar Reguletory Commission B16978\ Attachment 2\Page 1 ORGANIZATION READINESS Management Oversight and Effectiveness
'.] Standards and Expectations Communicated to the Staff Sat for Restart Commitment to Achieving Improved Performance Unsat Nuclear Safety Trending to Sat Understanding of Plant Issues and Corrective Actions Sat for Restart Effectiveness of Management Review Committees Sat for Restart ALARA Sat for Restart g Procedure Compliance Unsat O Human Performance Training /Qualifica0an Operations Sat for Restart Mechanical Maintenance Trending to Sat Instrumentation and Electrical Trending to Sat Maintenance Planning Unsat Engineering Trending to Sat Staff Levels Adequate Operations Sat for Restart Human Performance Operations Trending to Sat Maintenance Mechanical Maintenance Not Evaluated Instrumentation and Electrical Not Evaluated Maintenance Planning Not Evaluated Management Oversight and Effectiveness Trending to Sat Industrial Safety Management Oversight and Effectiveness Trending to Sat Events Operations Trending to Sat Corrective Actions /Seit Assessment Programimplementation Initial CR Screening Sat for Restart AITTS CAD Management Sat for Restart Overdue Assignments Sat for Restart OE Effectiveness Trending to Sat Conduct of CAD CRs/ACRs Sat for Restart Conduct of CAD - Self-Assessment Sat for Restatt Root Cause Quality Trending to Sat Effectiveness of MRT Sat for Restart Trending Effectiveness Sat for Restart CR Close-Out Timeliness Unsat
_ _a
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U.S. Nucber Reguintory Commission B16978\ Attachment 2\Page 2 Work Management Program Work Control & Outage Management Surveillances Sat for Restart
] Schedule Adherence Conduct of Work Planning Trending to Sat Trending to Sat Maintenance Conduct of Maintenance Mechanical Trending to Sat Instrumentation and Electrical Sat for Restart g Work Package Quality Sat for Restart Overall Effectiveness of Plant Maintenance Program O Mechanical Sat for Restart Instrumentation and Electrical Sat for Restart Maintenance Backlog Management Treading te Sat Average Age of Backlog AWOs Sat for Restart Post Maintenance Testing Sat for Restart Preventive Maintenance Program Trending to Sat Procedures Program Procedure Compliance h' nagement Oversight and Effectiveness Unsat M .intenance Mechanical Maintenance Not Evaluated instrumentation and Electrical Not Evaluated Operations Sat for Restart Procedure Quality Operations Trending to Sat Technical Adequacy of Procedures Mechanical Maintenance Sat for Restart Instrumentation and Electrical Unsat Document Control / Availability Operations Sat for Restart Procedures / Document Control Maintenance Mechanical Maintenance Trending to Sat Instrumentation and Electrical Sat for Restart Training Simulator Fidelity Sat for Restart Management Support of Training Trending to Sat Licensed Operator Continuing Training Trending to Sat Non-Licensed Operator Training Trending to Sat STA Trending to Sat j
_ _ _ _ _ . . . . . ... l
U.S. Nuclear Regul: tory Commission B16978\ Attachment 2\Page 3 4
Environmental NPDES Performance Trending to Sat SYSTEM READINESS Configuration Management Configuration Management Sat for Restart Design Control Design Quality - Trending to Sat NCRs Unsat Temporary Modifications Unsat Effe diveness of PRA Usage Sat for Restart 10 CFR 50.59 Process 10 CFR 50.59 Safety Evaluations Sat for Restart Engineering Skills Enhancement Conduct of Engineering Sat for Restart Physical Plant Work No applicable window The Maintenance and Work Control and Outage Management departments report restart required work is complete.
System Operability Engineering System Readiness Sat for Restart Results of System Testing Trending to Sat
. Operations Operability of Tech Spec Systems Sat for Restart Operability of Required Secondary and Support Systems Not Evaluated Operator Burdens Trending to Sat Adequacy of System Line-ups- Sat for Restart Post Maintenance Testing Sat for Restart Black Board (Alarms)- Not Evaluated Testing Program Engineering Adequacy of Power Ascension Testing Sat for Restart Surveillance Testing Sat for Restart Operations Surveillance Tests
{ Sat for Restart 1
<s .
U.S. Nucl:ar Reguletory Commission B16978\ Attachment 2\Page 4 Adequacy of Power Ascension Procedures Not Evaluated Procedure Quality - Surveillances Trending to Sat insi.umentation and Electrical M&TE Sat for Restar:
Technical Adequacy of Procedures Unsat Mechanical Maintenance M&TE Sat for Restan Technical Adequacy of Procedures Sat for Restart Plant Material Condition g Housekeeping Management Oversight and Effectiveness Trending to Sat b Mechanical Maintenance Control of Consumable Chemicals Trending to Sat Chemistry Sat for Restart OPERATIONAL READINESS Operations Staff Levels Adequate Sat for Restart Worker Practices Sat for Restart Required Reading Sat for Restart Awareness of Plant Security Sat for Restart Work Observations Sat for Restart
' Awareness of Plant Status Trending to Sat REGULATORY READINESS Tech Spec Improvement Plan Licensing Sat for Restart Commitment Management Licensing Trending to Sat Tech Specs Operations Unsat Final 10 CFR 50.54(f) response Trending to Sat NRC Significant items List Trending to Sat Summary Root Cause included in final 10 CFR 50.54(f) response Trending to Sat Confirmatory Order - lCAVP Trending to Sat Confirmatory Order -ITPOP Trending to Sat Confirmatory Action Letter - Operator Training Trending to Sat 10 CFR 50.54(f) Significant items for Restart complete Not Evaluated
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