ML20217P251

Rev 2 to LaSalle County Station Unit 1/Unit 2 Restart Plan

ML20217P251
Person / Time
Site:	LaSalle
Issue date:	04/28/1998
From:	Dacimo F COMMONWEALTH EDISON CO.
To:
Shared Package
ML20217P248	List: ML20217P243 ML20217P251
References
PROC-980428, NUDOCS 9805060184
Download: ML20217P251 (31)

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LgSilla C:unty Stiti:n

• Unit 1/ Unit 2 R: start Plan REVISION 2 TABLE OF CONTENTS

1. B A C KG RO UN D.............. .................. ............................................. . . . . . . . . . . 1 1.1. PLAN PURPOSE., . .2 1.1.1. Restart Plan (Pimse 1).. . .. .2 1.1.2. Post. Restart (Phase 11).. . .2 1.1.3. Operational Business Plans (Phase 111).. . .3

2. ROLES AND RESPONSIBILITIES......... ....... ...-.................... .... 3 2.1. SITE VICE PRESIDENT., . . .. .. . .3 2.2. STATION MANAGER . .. . . . .4 2.3. STARTUP M ANAGER., .. . . .4 2.4. RESTART PROGRAM MANAGER.. . . . . . .5 2.5. RESTART ACTION PLAN SPONSORS . . . .5 2.6. RESTART ISSUE REVIEW COMMITTEE.. .. . .5

3. RESTART PLAN SCOPE.. .... ............ .. .... . ..... . ................5

4. RESTART PROGRAh1 AND REQU1 RED ACTIONS...... .................................................6 4.1. RESTART PROGRAM OVERVIEW . .6 4.1.1. Restart issue Identification and Screening . .. . . .7 4.2. RESTART ActlON PLANS.. .. . . . . . . .9 Strategy I Safe Plant Operation. . . . . . . . .10 Strateg 2 Human Performance.. . .. . 13 Strategy 3 Plant Material Condition.. . . .. . 13

> Strategy 4 Efective Engineering Support.. . . . .14 l Strategy 5 Corrective Action and Self-Assessment..

. .15 Strategy 6 Training.. .16 Strategy 7 Process improvement.. . . . 16

5. RESTA RT ACTION PLAN 151PLESIENTATION... ..... ........_.................. ............ ..... .. .. 17 5.1 DEPARTMENTAL RESTART READINESS ASSESSMENTS . . .. . .19 5.2. SiSTEM READINESS REVIEWS.. . . . . .. . . 20 5.3. REGULATORY PROGRAM ASSESSMENT.. . . . . . 20 5.4. CON'r1RMATORY ACTION LETTER (CAL) ISSUE CWSEOUT REVIEWS . . . . 21

6. W O R K C O 51 P L ETI O N ............ ...... . . ........... .. .......... ...................... ......... ..... 21

7. RI RC RESTA RT R ECONIN1END ATION...... ...... .. ............. ............ .. ..... .... ..... . .... ....... 21

8. Q UALITY & S A FETY ASS ESS51ENT . .. .... ...... ...... ........ .......... . ...... .. . .... ................. 22

9. CO R PO R A TE ASS ESS N1 ENT ........... ...... ........ .................... ....... .. ...... ...... . 2 2

10. INDEPENDENT RESTART READINESS ASSESSA1ENT....... ........ ..... .. . 22

11. PO W E R AS CENS IO N PLA N ...... ... ........ ........................... . ., ........ . 23

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. LESille County Strtion

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Unit 1/ Unit 2 R:stirt Plin REVISION 2 TABLE OF CONTENTS (continued)

ATTA C H M E NT A : .......................................... ................................................. R ESTA RT PR O C E S S ATTAC H M ENT B : ....................................................... ........................ R ESTART ACTION PLAN S I i

i ATTACH M E NT C : ...... ............................... ..................................... C AL M ATRIX FOR R ESTA RT I i ATTACHMEN T D: ................. ...............................LASALLE READINESS MEASURES ,

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LsS:lle C unty StIti:n Unit 1/ Unit 2 R:st rt PIIn REVISION 2 Page 1

1. BACKGROUND On July 2,1996, the Nuclear Regulatory Commission (NRC) issued a Confirmatory Action Letter (CAL) regarding potential blockage on non-essential service water strainers. On September 20,1996, Commonwealth Edison Company (Comed) shut down LaSalle Station, Unit 2 for planned Refueling Outage L2RO7. On September 22, 1996, Comed shut down LaSalle Unit 1 to repair the Number 4 Turbine Control Valve 4TCV (forced outage L1F35). While these activities were occurring, the NRC was performing a Service Water System Operational Performance Inspection.

The NRC inspection, which was completed on September 24, 1996, identified, among other things, an operability concern with the Unit 1 Residual Heat Removal (RHR) Service Water heat exchanger. Subsequently, Unit 1 was placed in cold shutdown on September 26,1996. Comed placed Unit 1 in cold shutdown pending resolution of the RHR issue.

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

• Comed would develop a Restart Plan for LaSalle County Station to address corrective actions for the performance deficiencies referenced in the NRC's inspection reports and CALs, Comed's Independent Self Assessment Team (ISAT), and LaSalle's own assessments, and transmit that plan to the NRC for formal docketing Comed was to establish quantitative and qualitative criteria for assessing and monitoring the effectiveness of its corrective actions for each area identified in the Restart Plan.

The plan also was to discuss how issues that would not be completed prior to restart would be identified and assessed to demonstrate why restart was acceptable with the action not yet completed.

• Comed would keep the NRC updated on the projected startup date for the lead unit to facilitate advance planning by the NRC for special inspections that it will conduct prior to restart to evaluate operational readiness.

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LESille C:unty Stiti:n

. Unit 1/ Unit 2 R:sttrt PIIn REVISION 2 Page 2 e Comed would meet with the NRC approximately monthly to discuss Restart Plan implementation results and the extent to which evaluation criteria for corrective action effectiveness have been met, e Comed would meet with the NRC once its High Intensity i Training program for licensed operators has been completed and discuss the results of the training initiative and the process / indicators used by LaSalle to evaluate the ability of its licensed operators to start up and operate LaSalle.

LaSalle would meet with the NRC once Comed has concluded that one LaSalle unit is ready for restart. ,

l 1.1. Plan Purpose The above-described Comed activities and agreements with the NRC are an intricate part of LaSalle's Restart Plan and its associated methodology. In that light, the purpose of the LaSalle County Station Unit 1/ Unit 2 Restart Plan is to summarize the actions and controls that will be implemented by Comed to ensure that supplemental LaSalle CAL issues, as well as any issues deemed necessary for restart, are satisfied and auditable.

Comed is dedicated to continuous performance improvement. As such, the  ;

success of the LaSalle restart effort focuses on three primary periods of activity, each providing a different contribution to safe and reliable operation.

1.1.1. Restart Plan The first period involves the development of this Restart Plan. The Restart Plan integrates key site activities associated with the restart of LaSalle County Station Units 1 and 2, and provides a communication and management tool to achieve specific restart goals. Although focused on restart, the Restart Plan also briefly discusses anticipated LaSalle activities to ensure that performance levels reached to support restart do not deteriorate during plant operation.

L;S:lle C:unty St; tion

. Unit 1/ Unit 2 R:stIrt Plan REVISION 2 Page 3 1.1.2. Post-Restart l Activities, deficiencies, and issues identified during the shutdown period, which will not be completed prior to restart, but will be completed within approximately a year subsequent to restart, will be addressed in the Nuclear Tracking System (NTS) and as appropriate, addressed in the Operational Business Plan (discussed below).

1.1.3. Operational Business Plan and Other Long-Term Planning The LaSalle Upgraded 1996 Operational Plan was being implemented and producing significant positive results in several safety performance areas when LaSalle Units 1 and 2 were shut down for L1F35 and L2R07, respectively. Using this plan as a foundation, LaSalle will develop, subsequent to restart, its 1998 Operational Business Plan. The 1998 Operational Plan initiatives will include those activities that are not necessary to facilitate restart but are important to maintaining a continuous performance improvement trend. The Operational Business Plan also wdl address short-term actions (within approximately one year of restart) that are essential for maintaining safe and economically competitive performance at the Station.

In addition to site-specific restart activities, the Nuclear Generation Group also is implementing the Strategic Reform Initiatives (SRIs), which describe Comed's long-term performance vision as a successful participant in a competitive electric utility industry.

2. ROLES AND RESPONSIBILITIES lt is Comed's policy that all LaSalle managers and supervisors ultimately are responsible for ensuring that the station is ready for restart. Nevertheless, there are restart-related i. es and responsibilities that augment routine duties and warrant specific attention in this plan. In that light, the following discussion summarizes primary roles and responsibilities of key management personnel involved in ensuring restart readiness.

LgSille C:unty Station

. Unit 1/ Unit 2 RIst:rt Plin REVISION 2 Page 4 l

2.1. Site Vice President  !

The Site Vice President has overall responsibility for LaSalle Station, and as a l result, is accountable for successful implementation of the Restart Plan. in  !

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

demonstrating restart readiness, the Site Vice President also is responsible {

and accountable for ensuring that LaSalle restart efforts are consistent with Comed Corporate initiatives, i i

The Site Vice President is responsible for recommending restart of the l LaSalle units to the Chief Nuclear Officer. The Site Vice President will make  !

this startup recommendation primarily based on the overall recommendation I of the Restart Issue Review Committee. The Site Vice President will then j certify to the Chief Nuclear Officer that LaSalle is ready for restart. The i CNO considers the Site Vice President's recommendation along with the results of the Q&SA Assessment, the Corporate Assessment, and an  !

Independent Assessment to reach a conclusion regarding restart readiness, i Once a determination has been made that restart is appropriate, the Site j Vice President and CNO will meet with the NRC to provide Comed's basis for determining that restart readiness criteria have been satisfied.

1 2.2. Station Manager 4

The Station Manager is responsible and accountable for day-to-day l management of the LaSalle Restart Plan. His efforts are coordinated with those of the Site Vice President. The Station Manager actively participates in establishing performance expectations and ensuring that those i expectations are satisfied prior to restart. The Station Manager also is responsible and accountable for monitoring plan implementation and recommending to the Site Vice President when adjustments to the Plan are ,

appropriate.  !

2.3. Startup Manager The Startup Manager is retponsible and accountable for ensuring that hardware-related plant restart activities are performed satisfactorily, in this capacity, the Startup Manager is responsible for coordinating plant restart activity performance with the Station Manager ano Restart Program Manager to promptly identify and address necessary mid-course Restart Plan modifications.

LaSalle Ctunty Stiti:n

. Unit 1/ Unit 2 R:stIrt Plin REVISION 2 Page 5 1

2.4. Restart Program Manager l l

The Restart Program Manager is responsible for (1) ensuring that the Restart Plan Strategy Action Plans are implemented, (2) measuring Restart Plan Strategy and related corrective action results through ongoing effectiveness reviews by the appropriate line departments, and (3) coordinating the final Site performance assessments for Restart Plan Closure.

2.5, Restart Plan Strategy Sponsors Restart Plan Strategy Sponsors are responsible and accountable for ensuring that assigned Action Plans satisfy t'.ie underlying strategies. Restart Plan Strategy Sponsors oversee day-to-day implementation of their respective Restart Action Plans and coordinate the efforts of individual Action Plan and item owners. They also are responsible for ensuring that Restart Action Plan documentation packages are auditable and adequately address Restart Action Plan objectives.

2.6. Restart issue Review Committee l

The Restart issue Review Committee (RIRC) is a management team chaired l

by the Station Manager, and compo ed of the Startup, Operations, '

Maintenance and Engineering Managers. This Committee has primary i responsibility for determining whether issues / items / activities satisfy restart issue criteria (see Section 4.1.1). The RIRC also must approve i implementation /closecut of a restart activity if that activity does not satisfy restart performance improvement criteria. In addition, the RIRC is

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responsible for determining whether other broad restart activities (e.g.,

readiness assessments, program revisions, process revisions) have been satisfactorily implemented to support restart. When it is determined by the Restart Program Manager that all Restart Action Plan Strategies have been satisfactorily implemented, along with satisfaction of other performance measures, as deemed appropriate, the RIRC will determine whether the plant is ready for restart and provide its recommendation to the Site Vice ,

President.

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l L S:lle Crunty Stitirn

. Unit 1/ Unit 2 RIstirt Pl:n REVISION 2 Page 6

3. RESTART PLAN SCOPE l

While the Restart Plan applies to Units 1 and 2, the initial restart focus is on LaSalle County Station Unit 1. Because both units share personnel, resources, and processes, improvemento made to support Unit 1 restart, this j Restart Plan also will support the restart of Unit 2. The LaSalle County l Station Unit 2 refueling outage (L2R07) continues, in a limited manner, in parallel with the Unit 1 restart effort. Unit 2 activities are focused on maintaining safe shutdown.

4. RESTART PROGRAM AND REQUIRED ACTIONS 4.1. Restart Program Overview The LaSalle Restart Program consists of the actions set forth in two documents: (1) the Restart Plan and (2) the Restart Project Management Program document. This document -- the Restart Plan -- provides an overall picture of how restart issues are identified, resolved, and approved at LaSalle Station. The Restart Project Management Program document explains in greater detail how these activities are accomplished through complementary programs and activities to provide the highest level of confidence that the units will be returned to reliable full power operation in a safe and controlled manner. The overall restart process is presented as a flow chart in Attachment A, with the major elements described below.

The Restart Program consists of the following key attributes:

• Restart Issue Identification and Screening a Work Completion e Regulatory Program Assessment l

-* Restart and Operational Readiness Evaluation e Restart and Power Ascension. l l

. 1 1.sSalle County Stati:n l

Unit 1/ Unit 2 RIstart Plan j REVISION 2 Page 7 l

l Each activity is described below. l 4.1.1. Restart Issue Identification and Screening 1 Problem Identification Forms (PIFs), Action Requests, Engineering Requests, Procedure Change Requests, Work Requests, self-assessments and programmatic review findings, and routine Corrective Action Program trend PlFs will be screened utilizing restart criteria. The Startup Manager maintains the integrated schedule which reflects a listing of all activities that have to be performed prior to restart.

Restart issue Identification Criteria  ;

e Resolves a nuclear safety or operability issue.

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

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

• Resolves identified procedural deficiencies that:

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

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

c. challenge the ability of a system to perform functions

< important to safe and reliable operation.

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

• Resolves conditions that have resulted in repetitive equipment failures.

l L;Sille C:unty Stiti:n

. Unit 1/ Unit 2 R:st:rt Pl:n REVISION 2  :

Page 8 I e Resolves licensing or design basis discrepancies in safety- l related or other Technical Specification-required equipment  ;

and/or resolves substantive licensing and design basis document discrepancies. (Documentation deficiencies that have no safety impact may be completed as short-term action items with appropriate justification, provided that the actions are formally scheduled and tracked to completion.)

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

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

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

Occasionally, issues may satisfy the above restart criteria that may not be necessary from a safety perspective to be completed prior to restart. Under these circumstances, the Restart Project Management Program document provides a process for removal of an issue from the restart list.

Restart issues primarily have evolved from two sources -- the System l Functional Performance Review (SFPR) Program and LaSalle self-assessments. The SFPR is an action plan developed at the direction of LaSalle Senior Management in November 1996, and completed in July 1997.

The SFPR provides confidence that systems important to safe and reliable operation will perform consistent with the LaSalle design basis. For those areas where a level of confidence was not initially present, an additional objective of the SFPR program is to identify and initiate appropriate corrective actions to restore confidence that the system will perform consistent with the LaSalle design basis. Generally speaking, the SFPR responds to issues raised in LaSalle's March 28,1997,10 C.F.R. 50.54(f) response to the NRC.

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LcSalle C:unty St;ti:n l

. Unit 1/ Unit 2 R: start PI:n i REVISION 2 l Page 9 l

Forty-two systems have been reviewed under the SFPR using the screening '

criteria set forth in the SFPR Program Document. These systems encompass approximately 98% of core damage frequency mitigation.

Once an issue is identified through the SFPR process, applicable corrective actions generally are classified either as an Engineering Request (ER), a Design Change Request (DCR), or a Work Request (WR). Although many of these ERs, DCRs, and WRs already are preliminary classified as " restart,"

LaSalle will be applying the restart criteria set forth in this document -- the Restart Plan -- to identify the final list of restart issues to be presented to the RIRC to determine whether they should be completed prior to restart. As previously noted, issues may be removed from the restart list after implementing processes described in the Restart Project Management Program docurnent.

Other potential restart work items are being identified from several sources including the following:

e internal and external assessments; e review of backlogs (e.g., maintenance, engineering, operations, corrective action program PIFs);

e system readiness reviews, commitments review; and e personnel and plant performance trends.

Issues raised through these programs also will be screened to determine rastart status and will be presented to the RIRC as appropriate. In addition, comprehensive evaluations are being conducted to define any additional work that must be completed prior to unit restart. The resulting work scope includet significant actions relating to personnel processes, and plant equipment to correct identified deficiencies and improve operational safety performance. Many of these actions are defined in the Restart Action Plans and are summarized in Section 4.2. l 4.2. Restart Action Plan Strategies Restart Action Plan Strategies evolved as the key focus areas for demonstrating restart readiness. Several of the plans change or upgrade site-wide programs and processes and, therefore, are applicable to both Units 1 and 2. However, the present focus of Action Plan Strategy implementation is Unit 1.

L,iS:lle Crunty StIti:n Unit 1/ Unit 2 R:stIrt Pl:n REVISION 2 Page 10 The Restart Action Plan Strategies implement the following sevenl improvement strategies:

. Safe Plant Operation e Human Performance

• Plant Material Condition

• Effective Engineering Support

• Corrective Action and Self-Assessment

• Training

• Process Improvement The primary purpose and content of the Restart Action Plan Strategies are summarized below. Copies of the current Restart Action Plan Strategies (which include a list of applicable performance measures / standards, constituent action steps, completion dates, and responsible sponsors / action item owners) are included in Attachment B. A matrix cross-referencing each of the Restart Action Plans to the major issues in set forth in the NRC's Confirmatory Action Letter is provided in Attachment C. A chart listing the targeted restart perfoimance standard in each of the seven areas of restart planning is provided in Attachment D. These performance standards provide l the minimum requirements that must be satisfied prior to restart. Only the  !

Site Vice President with concurrer.ce by the RIRC (and with consultation  ;

from the Manager, Quality & Safety Assessment) may decide that an l Appendix D performance may be modified prior to restart.

Strategy No.1 - Safe Plant Operation l Restart Action Plan Strategy No.1 implements the Safe Plant Operation l strategy. The fundamental objective of this plan strategy is to establish a strong focus on operational safety and to become an Operations-driven organization. It is necessary to achieve this objective both to achieve safe plant restart and ascension to 100 percent power, as well as to sustain coerational safety on an ongoing basis thereafter.

Collectively, the individual action items set forth in . Action Plan No.1 are aimed, more specifically, at: (1) improving operator performance; (2) reducing operator challenges; and (3) correcting processes that challenge safe plant operation. Actions to achieve these goals are identified below and outlined, in their entirety, in the actual Restart Action Plans provided in Attachment B.

I L,1Silb C:unty Stiti:n

. Unit 1/ Unit 2 Rittirt Pl:n REVISION 2 Page 11 Improve Operator Performance (Action Plan No.1.1)

The primary focus here is to ensure that plant operators are fully effective in initiating a unit restart and sustaining power operation with a conservative l focus on operational safety. Restart actions include:

Monitoring Critical Operating Functions (Action Plan No.1.1 A)

To improve Operator and Supervisor professionalism and their ability to sustain safe plant operation, monitoring criteria -- that are consistent with both performance expectations and training activities -- will be anplied to specific oversight actions.

Upgrading the Operator Work Environment (Action Plan No.1.1B)

The operator work environment will be physically improved at LaSalle to support operator professionalism and ownership, and to support safe, reliable plant operation (e.g., through effective communication and p!anning for operational activities).

Developing and Implementing a Restart and Power Ascension Plan (Action Plan No.1.1C)

The normal unit startup and power ascension process will be supplemented to provide effective management oversight during restart and power ascension to ensure conservative decisions are made. A Restart and Power Ascension Plan will be developed and implemented in two phases: prior to unit restart, and during the startup and power ascension to full power.

Reduce Operator Challenges (Action Plan No.1.2)

Plant operators are challenged during normal, abnormal, and emergency plant conditions at LaSalle due to a high number of operator workarounds, temporary asterations to plant systems, and distractions in the Main Control Room. The goal of Action Plan No.1.2. is to reduce these challenges so that Station personnel can effectively operate and maintain the plant under all conditions. Specific restart actions to achieve this goal include the following:

$ L,aSille Crunty Sttti:n Unit 1/ Unit 2 RIst rt Plan REVISION 2 Page 12 Operator Workarounds (Action Plan No.1.2A) I l

i Through the actions specified in this Action Plan, LaSalle will reduce the I number of operator workarounds that require compensatory actions by operators in the normal course of their daily activities.

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Temporary Alterations (Action Plan No.1.28)

Implementation of this Action Plan will ensure a reduction in the number of temporary alterations to plant systems that may unnecessarily challenge plant operators during normal, abnormal, and emergency conditions.

Main Control Room Distractions (Action Plan No.1.2C)

Prior to restart, LaSalle will reduce the number of distractions in the Main Control Room so that plant operators are not unnecessarily challenged during normal, abnormal, and emergency conditions. l Correct Processes that Challenge Safe Plant Operation (Action Plan No.1.3)

Weaknesses in plant labeling impact the ability of Station personnel to effectively operate and maintain the plant, and have contributed to many out-of-service errors at LaSalle. Human performance, process, and procedure problems are the primary root causes of such errors. For example, poor-quality procedures challenge the ability of plant operators to implement expectations regarding procedure use and compliance. In addition, operating procedures require revision to reflect plant configuration and to satisfy testing requirements. In response, this Action Plan implements a series of actions, including:

Upgrading Plant Labeling (Action Plan No.1.3A)

Actions set forth in this Action Plan will upgrade labeling of plant equipment to minimize the potential for out-of-service and personnel errors.

Improving the Equipment Out-of-Service Program (Action Plan No.1.38)

Utilizing self-assessments to identify problems, LaSalle will implement corrective actions that define expectations regarding error reduction in the out-of-service program.

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, 1 L SIlla Ctunty St:ti:n Unit 1/ Unit 2 R:stIrt Pl n REVISION 2 1 Page 13 l Reviewing and Revising Operating Procedures (Action Plan No.1.3C) l Based on the results of procedure reviews specified in the Action Plan, operating procedures will be revkad, as necessary, to implement safe unit restart and power operation.

l Strategy No. 2 - Human Performance l 1

Restart Action Plan Strategy No. 2 implements the Human Performance l strategy. This Action Plan consists of one item -- Action Plan No. 2.1. Its overall objective is to achieve a near-term, step-change improvement in human performance at the Station to support safe plant restart and continued operation. This Action Plan strives to improve human interactions by focusing on improving communications, teamwork, and supervisory follow-up, and engaging the entire workforce in identifying and resolving barriers to good human performance. In general, the course of action set forth in this Action Plan proceeds along the following path: (1) establish clear expectations; (2) communicate them to the workforce; (3) coach and mentor personnel during performance of their job activities; (4) continually monitor site human performance; and (5) overcome barriers to improved human performance on an ongoing basis.

Through this Action Plan, LaSalle seeks to ensure that human performance improvements are realized along with plant material condition and process improvements. Only by doing so will improved operational safety performance be sustained into the future.

Strategy No. 3 - Plant Material Condition l Restart Action Plan Strategy No. 3 is focused on plant material condition. l Its fundamental objective is to implement effective outage management oversight to ensure that planned outage activities are effectively implemented, brought to closure, and result in significant material condition improvement at the Station. This objective will be achieved through implementation of a Unit 1 and Unit 2 Outage Plan, and a Maintenance Backlog Review Plan.

LaStile C:unty Stiti:n

- Unit 1/ Unit 2 Restart Plan REVISION 2 Page 14 i

Unit 1 Outage Plan (Action Plan No. 3.1)

A detailed outage implementation plan ensures that required Unit 1 outage work is defined and that Station resources are properly aligned to support safe completion of work items. Through this Action Plan, LaSalle will develop and implement a Unit 1 Outage Plan that identifies, organizes, and directs the completion of plant work necessary to improve the plant's material condition and thereby provide a high level of confidence in safe unit startup and power operation.

Unt 2 Outage Plan (Action Plan No. 3.2)

Although the initial focus of the Restart Action Plan No. 3 is Unit 1, work activities will also continue on Unit 2 to support L2R07 as resources are available. Thus, LaSalle will develop and implement a Unit 2 Outage Plan to satisfy tP . same objectives addressed by the Unit 1 Outage Plan (i.e.,

improved n~;erial condition, and safe startup and power ascension).

Maintenance Backlog Review Plan (Action Plan No. 3.3)

As part of this Action Plan, LaSalle will complete a review of the Nuclear Work Request (NWR) corrective action backlog to determine what corrective tasks must be completed prior to startup. This provides an additional means of ensuring that the plant's material condition is adequato to support safe ,

startup and power operation.

Strategy No. 4 - Effective Engineering Support l Restart Action Plan Stra.tegy No. 4 implements the Engineering Support l strategy. Its overall objtctive of this plan is to conduct programmatic assessments and upgrade Ei.gineering capabilities at the Station to ensure that plant problems are identified, and those required to be completed prior to restart are effectively resolved to support safe, reliable, and event-free restart and power operation. Two specific Action Plans have been developed to achieve this objective and implement the underlying strategy.

9 1.iSalle C:unty Sttti:n Unit 1/ Unit 2 R:stirt PIIn REVISION 2 Page 15 1 Engineering Capability (Action Plan No. 4.1)

Engineering work products r'ust consistently meet standards and expectations to effectively support plant operation and maintenance activities. They also must consistently include sufficient technical bases to ensure that the plant design basis is maintained on an ongoing basis. To improve the technical capabilities, judgment, and work quality of Engineering, the Action Plan upgrades Engineering capabilities through the addition of experienced personnel, provides for additional training of existing personnel, and implements organizational and programmatic changes to ensure that work products meet applicable quality sMndards.

Plant Operational Readiness (Action Plan No. 4.2)

The operational readiness of plant systems must be confirmed, in part, by addressing configuration discrepancies, open design evaluations, and degraded material conditions. This Action Plan implements a system functional performance review and other focused assessments of plant systems to define the scope of work necessary to be completed prior to unit restart. These actions will provide the necessary level of confidence that systems are capable of operating reliably and in accordance with design bases requirements.

Strategy No. 5 - Corrective Action and Self-Assessment l Restart Action Plan Strategy No. 5 focuses on Corrective Action and Self- l Assessment. Its underlying strategy is to conduct programmatic assessments and implement Corrective Action Program improvements so that plant problems are effectively identified and, those required to be completed prior to restart, resolved to ensure safe, reliable, event-free startup and power operation. Its three constituent Action Plans, identified below, seek to achieve these objectives primarily by improving self-assessrrm J. capabilities and Corrective Action Program implementation.

LtSille County Stiti:n Unit 1/ Unit 2 RIst'rt PI:n REVISION 2 Page 16 Corrective Action Program and Assessment (Action Plan No. 5.1)

Corrective Action Program implementation must ensure that problem identification, potential negative trends, and root cause determinations are consistently effective in identifying the cause(s) of problems. In addition, corrective actions must be consistently assessed to determine whether they effectively resolve Station problems. This Action Plan delineates actions to improve the Corrective Action Program, primarily in the areas of problem identification, root cause determination, corrective action screening, and post-corrective action review.

Quality & Safety Assessment (Q&SA) Effectiveness (Action Plan No. 5.2) l Action items set forth in this plan focus on improving Q&SA's ability to l diagnose Nuclear Safety and Quality concerns and effectively communicate such issues to line management for resolution prior to external identification of self-revealing events.

Departmental Self Assessments and Effectiveness (Action Plan No. 5.3) l Departmental self-assessments must identify potential problems prior to their l actual occurrence. This Action Plan specifies actions to improve departmental self-assessments so that they identify potential problems early in their developmental stages, thus allowing time for implementation of corrective actions.

Strategy No. 6 - Training l Restart Action Plan Strategy No. 6 implements the Restart Training Strategy. l This Action Plan consists of one item--Action Plan No. 6.1. Its primary purpose is to focus on personal development and improve individuals' skills at the Station. Operational safety and correcting equipment maintenance '

issues right the first time are its areas of emphasis. In particular, the Action Plan provides for Operator Startup Training. It recognizes that plant operators must uniformly possess the knowledge and skills necessary to meet and exceed Stations operational excellence standards. As such, the Action Plan implements an operator training program.

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L:Sille County Stiti:n Unit 1/ Unit 2 R:stirt PI:n REVISION 2 Page 17 Strategy No. 7- Process improvement l Reatart Action Plan Strategy No. 7 implements the Process Improvement Strategy. This Action Plan consists of one item--Action Plan No. 7.1. Its oveisil objective is to evaluate current processes and to identify those which prevent work from being accomplished in a safe and efficient manner. For example, a key focus area of this Action Plan will initially be aimed at improving and streamlining the procedure process.

5. RESTART ACTION PLAN IMPLEMENTATION It is acknowledged that Restart Action Plans (the majority developed in early 1997) do not provide the full scope of activities that must be performed to demonstrate that LaSalle Station is ready for restart. However, the activities described in this Restart Plan, when collectively implemented, will provide that restart readiness assurance. Therefore, completion of an action plan (previously described as "closecut") does not indicate that Action Plan issues satisfy restart criteria. Completion of an Action Plan indicates that the performance measures / standards listed in the action plan have been satisfied such that the process described by the plan can be reliably used to achieve restart readiness. Action Plan strategies represent what the name implies.

They are strategies;i.e., processes for ultimately reaching restart goals.

Each Restart Action Plan Owner is responsible for ensuring that adequate, auditable information is maintained for his/her Action Plan item. The following process applies to certifying Action Plan implementation and designated other restart activities as being ready for RIRC review.

Documentation associated with each Action Plan issue typically will contain the following information:  ;

A. Introduction and Summary:

• Describe the nature and scope of the restart issue (s),

summarize why the subsequent actions achieve the desired objective and resolve the associated issue (s), and confirm that such actions satisfy the applicable performance measures / standards.

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,. LcS:lle Ccunty Stiti::n

. Unit 1/ Unit 2 Rzstirt Pirn REVISION 2 Page 18 B. Discussion of Action Steps:

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• Describe actions taken to close out/ implement each Action Plan e Explain why actions envelope the " extent of condition" )

C. Results:

• Discuss demonstrated performance improvements (in general)

. Apply performance measure (s)/ standard ((s) and describe

, measurable indications of performance improvement (use l

performance indicator results, etc.)

D. Follow-up Actions:

• Identify actions to ensure continued improvement e List actions carried-over into post-restart (include discussion of associated tracking mechanism)

E. Post-Implementation Evaluations: q Each Action Plan implementation package shall have a post-implementation evaluation strategy. This strategy will; e Ensure that issues identified after plan implementation, but before unit restart, are satisfactorily addressed consistent with the Restart Action Plans e include a periodic review by Action Plan owners of relevant Corrective Action Program documents, including Problem Identification Forms, Procedure Change Requests, Work Requests, self-assessments and programmatic review findings, and routine Corrective Action Program issues e Permit final review and approval of issues associated with the Action Plans and their resolution, in the aggregate, prior to unit restart F. Attachments:

• Index of documents

• Action Plan e Supporting documentation (e.g., inspections, walkdowns, surveys, procedure changes, cover pages of documents and applicable pages).

• Approval signatures

.. ' 14Silb Csunty Stiti:n Unit 1/ Unit 2 Restart Plan REVISION 2 Page 19 An Action Plan is considered implemented when:

e action plan steps have been completed

• performance measures are being met or it reasonably apears that either the strategy or the strategy along with l other corrective actions will satisfy strategy performance  !

measures prior to restart.

It may be permissible to not complete action plan activities, if those activities can be justified as being not specifically relevant to fulfilling performance measures. These activities will be documented as exceptions in the Action Plan implementation document package. These exceptions must be approved by the Restart Issue Review Committee (RIRC).

The results of Action Plan implementation will be reviewed by the RIRC as j part of its integrated assessment of restart activities (refer to Section 2.6). l Based on the integrated assessment, the RIRC may recommend restart with Action Plan performance measures not being met. The justification for this recommendation will be documented as part of the integrated assessment.

5.1. Departmental Restart Readiness Assessments Department Restart Readiness Assessments by each organization are an element of Action Plan 5.3. These Department Restart Readiness l Assessments will be used to establish organizational capability to support j safe startup and reliable operation of LaSalle Units 1 and 2 and to provide a  !

plan for continued improving performance. Department Heads will lead an organization asssessment which includes:

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• Developing an assessment scope and plan  !

• Completing an initial assessment  !

• Identifying issues that must be resolved prior to startup, and actions necessary to promote performance improvement

• Developing corrective action plans to resolve issues

• Documenting closure of these issues.

The Department Restart Readiness Assessment process will:

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e Ensure effective communications between LaSalle management and staff to assure that important issues are well-understood,  !

that teamwork is facilitated, and that a continued sense of ownership of issues and results is internal: zed;

1,iSIlle County St tion Unit 1/ Unit 2 RIsttrt Plan REVISION 2 Page 20 Ensure that significant performance or other emergent issues l have been identified and formally documented, issue owners l have been assigned responsibility and accountability for tracking l closure to completion; and l

I Define a path for continued performance improvement through l l linkage of self-assessment results to long-term performance i

objectives (post-restart).

l Self-assessment results will be reviewed by the RIRC to ensure satisfaction of the above-discussed expectations.

5.2. System i ?eadiness Reviews System Readinoss Reviews will be performed by relevant System Engineers to ensure that:

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

. Systems that have been placed in lay-up during the current outage have been made operationally ready.

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

• All necessary system components are operable.

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

5.3. Regulatory Program Assessment Programmatic reviews of key regulatory areas will be performed prior to restart and results reported to the Site Vice President. At a minimum, Regulatory Program reviews in the following areas shall be performed:

• Appendix R e Environmental Qualification

• Equipment Aging

• Maintenance Rule

..' LcSalle C:unty Stiti n Unit 1/ Unit 2 R:st:rt PIIn REVISION 2 Page 21 e in Service Testing

• Other Regulatory Generic issues, as appropriate 5.4 Confirmatory Action Letter (CAL) Issue Closeout Reviews CAL issue Closecut Reviews areas have been selected based on previously  !

identified CAL and self-assessment issues. These reviews, which may utilize j the results of self-assessments and other restart readiness activities, shall be provided to the RlRC prior to its consideration of restart readiness for the following areas, at a minimum:

• Material Condition Human Performance e Corrective Action e Engineering Support

• Design Deficiencies CAL review subjects will have an assigned " owner" who is responsible for J either ensuring that activities, when completed, will provide adequate assessment information, and/or initiating, when necessary, additional actions that demonstrate why the programmatic area has been aatisfactorily addressed to facilitate restart. The CAL review reports prepared by the

" owner" will provide, at a minimum, a discussion on:

e definition of the issue; e integrated activities that address the issue; and, e the basis on which it is concluded that the issue has been satisfactorily addressed.  !

6. WORK COMPLETION Work required for unit restart is completed under the direction of line management using existing plant processes and procedures for execution and control of work. Implementation schedules are established and managed i by the Startup Management Organization for plant hardware-oriented activities and major non-hardware activities. Summary level actions to drive successful completion of restart work items is provided in the Plant Material Condition and Outage Completion Action Plan. Work completion is documented consistent with plant process and procedural requirements with oversight for effective job completion provided by line management and oversight organizations.

,,' LtS1!1e C:unty St: tion Unit 1/ Unit 2 Ristirt Plan REVISION 2 Page 22

7. RIRC RESTART RECOMMENDATION I Additional input regarding restart readiness, personnel, and work processes will be obtained from the Plant Operating Review Committee (PORC), l independent oversight organizations such as the Safety Review Board (SRB), 1 Quality & Safety Assessment (Q&SA) , and from other inputs at the discretion of the Site Vice President. The end result of the above activities will be presentations to the RIRC. The RIRC, after being satisfied with restart readiness, will recommend unit restart to the Site Vice-President.

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8. QUALITY & SAFETY ASSESSMENT Quality & Safety Assessment (Q&SA) will perform an independent assessment of restart readiness and certify plant restart readiness to the Manager of Nuclear Oversight. The Manager of Nuclear Oversight then certifies restart readiness to the Chief Nuclear Officer (CNO).

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9. NUCLEAR GENERATION GROUP (NGG) ASSESSMENT i

The CNO will consider the results of a NGG assessment of restart readiness.

To support this effort, a Corporate Nuclear Review Board (CRB) will be formed to gather information from the Site Quality and Safety Assessment (QSA) Reviews, the Nuclear Oversight, and other independent sources.

Nuclear Oversight assessments will be supplemented with external members to obtain an additional level of independent review.

To ensure that a comprehensive readiness review is conducted, the' Corporate assessment will look at a broad set of issues beyond those included in the LaSalle Restart Plan. Based on a review of industry standard assessment criteria, NRC criteria, and recent plant restart experience a set of Comed questions / criteria have been developed. This assessment tool has been compiled consistent with the LaSalle Restart Plan Strategies and also based on the more traditional categories: Operations, Maintenance, Engineering, Plant Support and Management Programs / Oversight.

,. L:Sille C:unty Stitlan

. Unit 1/ Unit 2 Re attrt PIIn REVISION 2 Page 23

10. INDEPENDENT RESTART READINESS ASSESSMENT When the Site Vice President concludes that the plant is ready for restart, he will request authorization for restart from the CNO. The CNO will commission an independent assessment of the units' readiness for restart and, upon satisfactory resolution of independent assessment issues, grant final authorization for restart to the Site Vice President

11. POWER ASCENSION PLAN l Concurrent with the development of final restart readiness actions is the development of a Restart and Power Ascension Plan (developed as part of I the Safe Plant Operation Action Plan). This Plan ensures that plant hardware is operational and personnel are prepared to operate the plant after the current outage. The Restart and Power Ascension Plan (RPAP) transitions the plant (hardware) and personnel from shutdown to operational status.

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.. LESilla County Station Unit 1/ Unit 2 Restart Plan f i

REVISION 2 Page 25 ATTACHMENTB RESTART ACTION PLANS l

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,.' LISille C:unty StItion

• Unit 1/ Unit 2 Restart Plan REVISION 2 Page 26 ATTACHMENT C 1

l CONFIRMATORY ACTION LETTER MATRIX FOR RESTART i

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, 1 Safe Plant Operations 1.1 Improve Operator Performance 1.1 A Monitoring Critical Operations X Functions 1.1 B Operator Work Environment X X 1.1 C Restart and Power Ascension Plan X X X 1.2 Reduce Operator Challenges 1.2 A Operator Workarounds X X l 1.2B Temporary Alterations X 1.2C Main Control Room Distractions X 1.3 Correct Processes that Challenge Safet Plant Operation 1.3 A Plant Labeling Program X X 1.3B Out-of-Service Program X l 1.3C Operating Procedures Readiness X X l

l 2 Human Performance l

l 2.1 Human Interaction and Performance X l

3 Plant Material Condition 3.1 Unit 1 Outage Management Plan X X 3.2 Unit 2 Outage Management Plan X X 3.3 Maintenance Backlog Review Plan X X l 4 Effective Engineering Support 4.1 Engineering Capability X X X 4.2 Plant Operational Readiness X X X L

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,. LISille County Stiti:n l

. Unit 1/ Unit 2 RIstirt Plan l REVISION 2 Page 27 ATTACHMENT C 1 l

CONFIRMATORY ACTION LETTER MATRIX FOR RESTART l Action Flan l Item CAL ISSUE '

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8 .6 1 5 Corrective Action and Self Assessment 5.1 Corrective Action Program X 5.2 Quality Verification Effectiveness X 5.3 Department Self Assessment X X l 6 irsining  !

6.1 Operator Training X X l 7 Process improvement 7.1 Procedures X l

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,. .L Sille Crunty Stiti:n

• Unit 1/ Unit 2 RIstart Plan l REVISION 2 l Page 28 l

l ATTACHMENT D LASALLE READINESS MEASURES

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Restart Target (1) Safe Plant Operation e improve Operator Performance Improving Trend in OPS Event Free Clock

• Operator Work Around <10 And No Significanc Ones e Outstanding Tamp Alts <

__10 Greater Than 1 Refuel Outage e Control Room Distractions <

__10 And No Significant Ones (2) Human Performance e Site Human Performance improving Trend in Station Event Free Clock e Out of Service Errors < 2 Per Month e Safety System Actuations < 2 Per Month e Open Significant Human <4 Performance PlF e Open Significant Procedures <4 Adherence PlF (3) Plant Material Condition e Outage Backlog 100% As Required for Startup (4) Engineering Effectiveness e Engineering Quality improving Trend In Engineering Score Card ~

e SFPR Reviews 100% As Required for Startup e Outstanding Engineering 100% As Required for Startup Requests

• System Readiness Review 100% As Required for Startup e Design Changes 100% As Required for Startup (5) Corrective Action - Self Assessment

. CARB ihjections Rate _< 40%

• Significant Repeat Events < 2/ Month e Significant Corrective Actions < 15/ Quarter Overdue (6) Training HIT Training Complete (7) Process improvement 100% Required for Startup (Procedures)

NOTE: (1) The Restart Targets are determined on a per Unit basis.

(2) "Significant" is defined as a generic breakdown in the process.