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| issue date = 05/06/1998
| issue date = 05/06/1998
| title = Rev 2 of Cook Nuclear Plant Restart Plan.
| title = Rev 2 of Cook Nuclear Plant Restart Plan.
| author name = SAMPSON J R
| author name = Sampson J
| author affiliation = INDIANA MICHIGAN POWER CO.
| author affiliation = INDIANA MICHIGAN POWER CO.
| addressee name =  
| addressee name =  
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{{#Wiki_filter:ATTACHMENT TO AEP:NRC: 1303 RESTART PLAN-REVISION 2 9806f00446 980506 PDR ADOCK 05000315 P PDR  
{{#Wiki_filter:ATTACHMENT TO AEP:NRC: 1303 RESTART PLAN - REVISION 2 9806f00446 980506 PDR ADOCK 05000315 P             PDR
'I Cook Nuclear Plant Restart Plan J.R Sampson Site Vice President Revision 2


Introduction and Overview 1.1 Purpose 1.2 Background 1.3 Roles and Responsibilities 1.4 Cook Nuclear Plant Restart Process Overview 2.Restart Work Scope Determination 2.1 Restart Work Scope Determination Process 2.2 Plant System Reviews 2.3 Redefined Restart Work Scope 3..Restart Work Scope Performance 3.1 Work Scope Performance 4.Restart Readiness Assessment 4.1 4.2 4.3 4.4 System Readiness Functional Area Readiness Prograinmatic Readiness Containment Readiness 5.Restart Authorization 5.1 Restart Oversight Committee (ROC)Review and Approval 5.2 Senior Manager Review Team (SMRT)Review and Approval 5.3 Executive Vice President Restart Authorization 6.Startup and Power Ascension 6.1 Management Oversight and Organizational Support 6.2 Operating Proficiency and Experience Review Attachments:
'I Cook Nuclear Plant Restart Plan Revision 2 J. R Sampson Site Vice President
A system engineer review board (SERB)charter B restart oversight committee (ROC)charter C criteria for work included in restart scope D plant systems to be reviewed by ROC E restart process map F plant performance assurance oversight of restart Revision Block 1.0 Introduction and Overview 1.1 Purpose The Cook Nuclear Plant Restart Plan describes the activities and controls that will be implemented to ensure the facility is ready to safely start up and operate in an event&ee manner.To provide us with the assurance that this can be accomplished we must determine that our people, plant and programs are ready to meet this challenge.
The plan will assess these areas and identify any needed action to ensure we can safely startup and operate reliably in an event&ee manner.The plan will assess the following:
~People Have we adequately prepared our people such that they are trained on the changes in our programs and procedures and understand the issues involved in restarting and operating the plant?Are the functional areas staffed, organized and functioning at a level to support safe startup and reliable operation in an event&ee manner?~'rograms Have our programs and procedures been adjusted to include the lessons learned?Are they adequate to allow us to return to operation and prevent future nonconforming conditions?
o Plant Are our materiel condition, configurations, restart.readiness of systems and ability to meet design function while complying with applicable regulations adequate to allow us to return to service?This plan provides a map to conduct the assessments needed to assure ourselves that we are ready to restart.The actions and activities needed to do this and any corrective actions will be performed in accordance with approved procedures.


===1.2 Background===
Introduction and Overview 1.1      Purpose 1.2     Background 1.3      Roles and Responsibilities 1.4      Cook Nuclear Plant Restart Process Overview
During the July-September, 1997, time&arne, the NRC conducted an architect engineering inspection at Cook Nuclear Plant.The AE inspection focused primarily on two safety systems, ECCS and CCW.Six weeks into the AE inspection, a question surfaced regarding our ability to sustain long-term cooling of the core during a design basis accident.As a conservative measure, both units were shut down on September 9 and cooled to cold shut down until this question could be properly answered.
: 2.     Restart Work Scope Determination 2.1      Restart Work Scope Determination Process 2.2     Plant System Reviews 2.3      Redefined Restart Work Scope 3.. Restart Work Scope Performance 3.1     Work Scope Performance
On September 12, the NRC concluded the AE inspection with a public exit.meeting.Following this meeting, Cook Nuclear Plant committed to addressing and resolving seven (7)specific issues identified during the inspection prior to restart of the units.It was believed that these seven issues could be resolved within a few weeks.Subsequent to our letter to the NRC committing to these actions, the NRC issued a confirmatory action letter (CAL)identifying their approval would be required prior to restarting the units.The NRC CAL also identified two additional actions to be taken as a condition for restarting the units.The unit 2 reactor was scheduled for a refueling to begin in late September, 1997.The unit 2 core was within two weeks of normal burn up window at the time of the unscheduled shut down.Our objective was to resolve the CAL items, and restart unit 2 for the remaining two weeks of fuel burn up, then commence the refueling outage.Over the next several weeks, it became apparent that a restart would not be achievable in the near term, and a decision was made to begin the unit 2 refueling outage and its scheduled work on October 20, 1997.In parallel with the outage work, our organization worked through the many AE inspection/CAL issues.It appeared that a January 1998 restart of both units would be feasible.During the time period of January-February 1998, the Cook Nuclear Plant senior management team had several meetings with the NRC, and the CAL issues were nearing resolution.
: 4.     Restart Readiness Assessment 4.1     System Readiness 4.2      Functional Area Readiness 4.3     Prograinmatic Readiness 4.4      Containment Readiness
It was during this time period that several new issues arose, concerning or relating to our containment systems that would require significant resources and focus to reconcile.
: 5. Restart Authorization 5.1     Restart Oversight Committee (ROC) Review and Approval 5.2      Senior Manager Review Team (SMRT) Review and Approval 5.3      Executive Vice President Restart Authorization
Given the significant period that both units had been shut down up to this point, and the uncertainty for a near-term start up date, it was decided that the scope of both units'utages needed to be re-evaluated, and a more rigorous assessment of plant readiness was required prior to any restart.These steps are necessary in order to achieve the objectives described in Section 1.1.The key factors that led to this decision are: Design basis concerns and equipment performance and testing issues which have come to light in recent months raised the concern that additional hardware and non-hardware activities may need to be completed during this extended shut down.Confirmation is required that procedure inadequacies or equipment deficiencies that may challenge plant operators during normal, abnormal, or emergency conditions have been adequately identified and addressed.
: 6. Startup and Power Ascension 6.1      Management Oversight and Organizational Support 6.2      Operating Proficiency and Experience Review Attachments:
Lessons learned&om other nuclear utilities in the implementation of an integrated assessment of readiness to restart following an extended shutdown period are being adopted and applied to Cook Nuclear Plant on a pilot basis during this outage.1.3 Roles and Responsibilities Roles and responsibilities for the execution of this plan are as follows: 1.3.1 All Nuclear Generation Employees Responsible for supporting the restart activities by focusing on safe operations and continuous improvement.
A system    engineer review board (SERB) charter B restart oversight committee (ROC) charter C criteria for work included in restart scope D plant systems to be reviewed by ROC E restart process map F plant performance assurance oversight of restart Revision Block
All employees are obligated to raise any and all quality concerns to management's action through the corrective action program.1.3.2 System Engineers Responsible for successful completion of restart work on selected systems, performing an assessment of system readiness to support unity restart and , safe, reliable power operations, implementing necessary corrective actions and providing affirmation of readiness.
1.3.3 System Engineering Review Board (SERB)Board internal to the engineering organization responsible for assessing the readiness of plant systems and providing recommendations for additional restart scope to the ROC.The SERB charter is provided in attachment A.1.3.4 Restart Oversight Committee (ROC)Responsible for determining the restart scope of work using consistent standards and criteria approved by the senior management review team (SMRT)and assessing the readiness of Cook Nuclear Plant to restart and resume power operations, using the process approved by the SMRT in this procedure.
The ROC charter is provided in attachment B.1.3.5 Senior Management Review Team (SMRT)Members: Site Vice President (Chairman)
Vice President Nuclear Engineering Director Performance Assurance Director Regulatory Affairs*Independent Safety Review Committee Member-*This member will actively participate as available, and will perform a continuous oversight role.Routine communication with this member may be accomplished through review of meeting minutes, phone conferencing and follow up interviews with the SMRT members.The SMRT is responsible for generation and approvals of: (a)criteria for screening work items required for completion of restart;and, monitoring and oversight of the process for affirmation and approval of plant and staff readiness for restart.1.3.6 Plant Manager, Engineering Managers and Department Superintendents Responsibility for successful completion of the restart work, performing an assessment of functional area readiness to support unit restart and safe, reliable power operations, implementing necessary corrective actions and providing affirmation of readiness to the ROC.1.3.7 Restart Manager Responsibility for the management and control of restart work activities including the scheduling of activities and coordination of resources.
1.3.8 Site Vice President Overall responsibility for the management and implementation of the restart plan to achieve the purpose described in section 1.1.Serves as chairman of the (SMRT).1.3.9 Executive Vice President Nuclear Generation Responsible for authorizing startup and power ascension, and providing senior management oversight of the restart process.1.3.10 Plant Performance Assurance Responsible to discharge performance assurance responsibilities under 10 CFR 50, Appendix B, to provide assurance that activities affecting quality are satisfactorily accomplished.
See Attachment F for further details.1.4 Cook Nuclear Plant Restart Process Overview The restart plan consists of the following major activities:
(1)scope determination (2)work performance (3)readiness assessment


(4)startup authorization (5)startup and power ascension Following is a process map and summary of the activities with more detailed information presented in later sections of this document.
1.0 Introduction and Overview 1.1    Purpose The Cook Nuclear Plant Restart Plan describes the activities and controls that will be implemented to ensure the facility is ready to safely start up and operate in an event &ee manner. To provide us with the assurance that this can be accomplished we must determine that our people, plant and programs are ready to meet this challenge. The plan will assess these areas and identify any needed action to ensure we can safely startup and operate reliably in an event &ee manner.
f Cook Plant Restart Plan Overview L1 srv Bgheen Perform System Readiness Reviews 15 sERS Rexxnmed Restart Work Scope sa Roc Appmve Restart Work Scope 2.1 Reaw Qeneoer Perform Restart Work M Perform Rnat Review Racer rvnend Startup 41 srNT Reconvnend Restart$.1 opearoe Restart And Power Operation 12 Il eager Perform F nctional Area Readeess Reviews Final Review 12 nanoyoo Perform Progranmatic Rearfeess Reviews 1A ovRers~Perform Containment Readiness Review 1.1 Sys Engineers Perform System'eadiness Reviews The'objective of the restart readiness assessment is to ensure that the integrated set of plant equipment, human resources and work programs are capable of supporting safe and reliable power operations.
The plan will assess the following:
The restart readiness assessment will be initiated in parallel with the execution and completion of restart work.The restart readiness assessment will focus on the following 1.2~Managers Perform Functional Area Readiness Reviews~plant system readiness~functional area readiness~programmatic readiness~containment readiness 1.3.Managers Perform Programmatic Readiness Reviews 1.4 Dir Plant Engineering Perform Containment Readiness Reviews 1.5 SERB Recommend Restart Work Scope The restart work scope may be increased as a result of the plant system assessments or other ongoing work.The system engineers will recommend the restart work scope to the System Engineer Review Board (SERB).
            ~       People Have we adequately prepared our people such that they are trained on the changes in our programs and procedures and understand the issues involved in restarting and operating the plant? Are the functional areas staffed, organized and functioning at a level to support safe startup and reliable operation in an event &ee manner?
1.6'OC'pprove Restart Work Scope All restart scope additions will be approved by the Restart Oversight Committee (ROC).2.1 Restart Manager Perform Restart Work Following determination of the restart work scope by the ROC, the restart manager is responsible for coordinating the planning, scheduling and completion of the work.3.1 ROC,PNSRC Perform Final Review Recommend Startup Results of the restart assessment will be presented to the Restart Oversight.
            ~  'rograms Have our programs and procedures been adjusted to include the lessons learned?
Committee (ROC)with an af5rmation by the responsible system engineer or engineering manager, and the functional area superintendent of the readiness of the system'r organization to support plant startup and safe, reliable power operations.
Are they adequate to allow us to return to operation and prevent future nonconforming conditions?
4.1 SMRT Recommend Restart Following presentation and acceptance of the assessment results by the ROC, the Site Vice President will convene the SMRT to perform an integrated review of the affirmations, verify compliance with regulatory commitments and any other special criteria that may impact the initiation of startup activities.
o        Plant Are our materiel condition, configurations, restart. readiness of systems and ability to meet design function while complying with applicable regulations adequate to allow us to return to service?
4.2 Exec Vice Pres Authorize Restart Based on the results of this review, the Executive Vice President Nuclear Generation will authorize startup and power ascension.
This plan provides a map to conduct the assessments needed to assure ourselves that we are ready to restart. The actions and activities needed to do this and any corrective actions willbe performed in accordance with approved procedures.
5.1 OPS Startup and Power Ascension Startup and power ascension following the completion of startup work will follow a deliberate and controlled approach that ensures operational and personnel safety.The normal startup process defined in Cook Nuclear Plant procedures will be supplemented with appropriate management oversight and support&om engineering and maintenance organization such that issues or concerns are promptly addressed and the startup can be accomplished in a safe, controlled manner.
1.2  Background During the July - September, 1997, time&arne, the NRC conducted an architect engineering inspection at Cook Nuclear Plant. The AE inspection focused primarily on two safety systems, ECCS and CCW. Six weeks into the AE inspection, a question surfaced regarding our ability to sustain long-term cooling of the core during a design basis accident. As a conservative measure, both units were shut down on September 9 and cooled to cold shut down until this question could be properly answered.
0 2.0 Restart Work Scope Determination 2.1 Restart Work Scope Determination Process The restart work scope is being defined through a determination process driven by the ROC consistent with their charter.Outstanding work items and selected progranunatic issues are reviewed against defined criteria to determine which items should be included in the restart scope.System engineers have the largest role in this process, but there is also considerable involvement from other organizations including operations, design engineering, and maintenance.
The restart work scope determination process is outlined in attachment E..2.2 Plant System Review Plant systems are reviewed by the system engineer using the plant system review instructions with results and recommendations presented to the ROC.The plant system review process consists of four primly elements as described below.2.2,1 Selection of Plant Systems Plant systems have been selected for a detailed review and affirmation based on the historical performance and risk significance of the system.This review will be performed in accordance with the plant system readiness review instructions.
Results of the assessment of selected systems will be presented first to the SERB and, upon approval, to the ROC with appropriate recommendations for additional actions'o be performed after restart.The systems are listed in attachment D.The remaining systems will be assessed and evaluated as part of the line responsibility of the engineering organization through the use of the SERB.Issues that affect restart scope on these systems will be presented to the ROC on a case basis.2.2.2 Restart Work Scope Additions The restart work scope addition for plant systems is focused on those items not already included in the restart work scope.Items already scheduled for completion prior to restart are not evaluated against the criteria provided in attachment C unless there is a proposal to delete them.The goal of the system review and work scope addition process is to define'the work necessary for completion prior to restart such that the system is capable of supporting safe and reliable power operation.
This review will include the following:
10 (a)(c)the magnitude, significance and risk of items which will be resolved aAer restart should be defined and evaluated; assurance that recurring problems on the system that could affect safe and reliable operations are being fixed;assurance that any design basis and licensing issues on the system are being addressed within a time frame that is appropriate for the issue;and assurance that operators will not be unnecessarily challenged in the operation of the system during normal, abnormal, or emergency conditions.
Based on the review of open work items against the criteria presented in attachment C, the system engineer is to provide recommendations for the restart scope changes for the selected systems in attachment D to the SERB and upon approval to the ROC.Items recommended for addition to the restart scope for remaining plant systems will be handled on an item specific basis by the ROC following an initial review by line management.
It should be noted that.it was not the intent of this program to resolve all design basis issues.We are committed to a long range program to accomplish this resolution.
2.2.3 Monitoring Restart Work, Addressing Emergent Issues and Performing a More Detailed Assessment of System Readiness System engineering is to monitor the progress of work on assigned system and address emergent issues as required.Any major restart scope impacts defined by emergent issues should be brought to the ROC following line management review.All other emergent issues are assessed daily by the engineering managers.Also, the system engineer is to use this period to complete the assessment and evaluation of system readiness in preparation for the final system readiness review and affirmation of readiness for restart.2.2.4 Final System Readiness Review and Affirmation This aspect of the system readiness review process is summarized in section 4.1.Although it is not expected that any significant restart work scope issues will be identified during this final review, if any are identified, they are to be brought to the immediate attention of the ROC (following line management review).11


2.3 Redefined Restart Work Scope The restart work scope may be redefined based on the evaluation process described above.Decisions made by, the ROC regarding the restart work scope are documented in meeting minutes and work item status is tracked.3.0 Restart Work Scope Performance 3.1 Work Scope Performance Following determination of the restart work scope by the ROC, the restart manager is responsible for coordinating the planning, scheduling and completion of the work, including the implementation of prograinmatic changes.The restart work scope performance process is outlined in attachment E.4.0 Restart Readiness Assessment
On September 12, the NRC concluded the AE inspection with a public exit
'he restart ieadiness assessment is an integrated line management assessment that assists station management in determining the readiness to initiate startup and achieve safe, reliable power operation through the next operating cycle.The restart readiness assessment process is outlined in attachment E, This form of assessment is one element of a comprehensive plant assessment program that is the foundation of our continuous improvement philosophy.
. meeting. Following this meeting, Cook Nuclear Plant committed to addressing and resolving seven (7) specific issues identified during the inspection prior to restart of the units. It was believed that these seven issues could be resolved within a few weeks. Subsequent to our letter to the NRC committing to these actions, the NRC issued a confirmatory action letter (CAL) identifying their approval would be required prior to restarting the units. The NRC CAL also identified two additional actions to be taken as a condition for restarting the units.
Implementation of this action is consistent with the experience and lessons learned of other nuclear utilities.
The unit 2 reactor was scheduled for a refueling to begin in late September, 1997.
The restart readiness assessment is being implemented at Cook Nuclear Plant based on lessons learned and will be captured such that this process can be implemented on a routine basis in the future.The restart readiness assessment for restart will verify the completion of all defined restart work and the affirmation of system, department and restart readiness for startup and power operations.
The unit 2 core was within two weeks of normal burn up window at the time of the unscheduled shut down. Our objective was to resolve the CAL items, and restart unit 2 for the remaining two weeks of fuel burn up, then commence the refueling outage.
Results of the assessment and afBrmation of readiness will be presented to the ROC by the responsible system engineer, functional area manager and operations shift supervisor.
Over the next several weeks, it became apparent that a restart would not be achievable in the near term, and a decision was made to begin the unit 2 refueling outage and its scheduled work on October 20, 1997. In parallel with the outage work, our organization worked through the many AE inspection/CAL issues. It appeared that a January 1998 restart of both units would be feasible.
-Following acceptance by the ROC, the site vice president will convene an SMRT meeting to review these affirmations and verify compliance with regulatory commitments and any other applicable criteria.The site vice president will recommend start up of the units based on this review, and assurance regarding the readiness of the station to initiate startup and safely, reliably operate through the next operating cycle.Following is a summary of the key elements of the program.4.1 System Readiness System readiness affirmations by the system engineer are to confirm that plant systems meet functional design requirements, have been suitably tested and are ready to support safe and reliable startup and operation through the next cycle.This afIirmation is based on the work completed as described in section 2.2, and is to 12
During the time period of January - February 1998, the Cook Nuclear Plant senior management team had several meetings with the NRC, and the CAL issues were nearing resolution. It was during this time period that several new issues arose, concerning or relating to our containment systems that would require significant resources and focus to reconcile.
Given the significant period that both units had been shut down up to this point, and the uncertainty for a near-term start up date, it was decided that the scope of both units'utages needed to be re-evaluated, and a more rigorous assessment of plant readiness was required prior to any restart. These steps are necessary in order to achieve the objectives described in Section 1.1. The key factors that led to this decision are:
Design basis concerns and equipment performance and testing issues which have come to light in recent months raised the concern that additional hardware and non-hardware activities may need to be completed during this extended shut down.
Confirmation is required that procedure inadequacies or equipment deficiencies that may challenge plant operators during normal, abnormal, or emergency conditions have been adequately identified and addressed.
Lessons learned &om other nuclear utilities in the implementation of an integrated assessment of readiness to restart following an extended shutdown


include a coordinated system walkdown of the system with operations and maintenance personnel on systems defined by the plant engineering manager.Where necessary, compensatory actions for rescheduled work or other areas of performance risk are to be defined and addressed.
period are being adopted and applied to Cook Nuclear Plant on a pilot basis during this outage.
System readiness affirmations are to be presented by the system engineer to the SERB and upon its approval to the ROC for the systems identified in attachment D.Affirmation of system readiness is documented with the signature of the system engineer and manager.Affirmation of individual system readiness for the remaining plant systems will be addressed as part of the system engineering line management responsibility and will be one element of the functional area readiness evaluation.
1.3 Roles and Responsibilities Roles and responsibilities for the execution      of this plan are as follows:
4.2 Functional Area Readiness r Functional area readiness by selected functional areas is an affirmation that the department is in an appropriate state of readiness to support startup and safe and reliable power operation through the next cycle.Functional area readiness will include items such as: (a)(c)(d)adequacy of staffing levels, personnel experience and qualifications to demonstrate compliance with regulatory requirements and commitments; completion of personnel training on normal startup evaluations, power ascension requirements, industry operating experience including extended shutdown and unusual events at similar plants, emergency preparedness, changes in plant configuration, changes in plant operating and emergency procedures, and changes in key adininistrative procedures and processes; resolution of significant performance deficiencies and reduction of backlogs (corrective action, corrective maintenance etc.)to manageable levels;and establishment of goals and priorities for the continued improvement of the department including use of critical assessment methods.Functional Area readiness will be affirmed to the ROC by the following functional
1.3.1      AllNuclear Generation Employees Responsible for supporting the restart activities by focusing on safe operations and continuous improvement. All employees are obligated to raise any and all quality concerns to management's action through the corrective action program.
~operations outage management
1.3.2       System Engineers Responsible for successful completion of restart work on selected systems, performing an assessment of system readiness to support unity restart and safe, reliable power operations, implementing necessary corrective actions and providing affirmation of readiness.
~maintenance licensing plant engineering fuels design engineering
1.3.3      System Engineering Review Board (SERB)
~plant protection
Board internal to the engineering organization responsible for assessing the readiness ofplant systems and providing recommendations for additional restart scope to the ROC. The SERB charter is provided in attachment A.
~production engineering information management chemistry plant performance assurance radiation protection Affirmation of functional area readiness is documented with the signature of the functional area manager.13
1.3.4      Restart Oversight Committee (ROC)
Responsible for determining the restart scope of work using consistent standards and criteria approved by the senior management review team (SMRT) and assessing the readiness of Cook Nuclear Plant to restart and resume power operations, using the process approved by the SMRT in this procedure. The ROC charter is provided in attachment B.
1.3.5      Senior Management Review Team (SMRT)
Members:        Site Vice President (Chairman)
Vice President Nuclear Engineering Director Performance Assurance Director Regulatory Affairs
                                *Independent Safety Review Committee Member
            -*This member will actively participate as available, and willperform a continuous oversight role. Routine communication with this member may


4.3 Programmatic Readiness Programmatic readiness review will confirm that programs are in place to support identification and correction of problems.Programmatic issues identified during the unit shutdown have been evaluated and necessary corrective or preventive actions have been completed.
be accomplished through review of meeting minutes, phone conferencing and follow up interviews with the SMRT members.
Programs in place at the time of unit start-up will ensure that the plant will be operated in conformance with its design bases and in accordance with the AEP quality assurance program.A/E programmatic issues potential bypass of 50.59 safety evaluations 50.59 safety evaluation quality corrective action program improvements surveillance program assessment 4.4 Containment Readiness The containment readiness review will focus on the ability of the containment system to meet the intended functional design requirements.
The SMRT is responsible for generation and approvals of:
The critical points of the review will focus on the system materiel condition, adequate surveillance testing, and the system configuration control, 5.0 Restart Authorization The restart authorization process is outlined in attachment E.5.1 Restart Oversight Committee (ROC)Review and Approval The ROC will review and accept the assessment affirmations in 4.1, 4.2, 4.3 and 4.4.A restart recommendation will be made to the SMRT based on the results of the functional area assessments.
(a)      criteria for screening work items required for completion of restart; and, monitoring and oversight of the process for affirmation and approval of plant and staff readiness for restart.
5.2 Senior Manager Review Team (SMRT)Review and Approval Upon review and acceptance of the assessment affirmations in 4.1, 4.2, 4.3 and 4.4 by the ROC, the site vice president will convene an SMRT meeting to perform an integrated review and approval.5.3 Executive Vice President Restart Authorization Based on this review the executive vice president nuclear generation will provide-the authorization for restart and power ascension.
1.3.6  Plant Manager, Engineering Managers and Department Superintendents Responsibility for successful completion of the restart work, performing an assessment of functional area readiness to support unit restart and safe, reliable power operations, implementing necessary corrective actions and providing affirmation of readiness to the ROC.
14
1.3.Restart Manager Responsibility for the management and control ofrestart work activities including the scheduling of activities and coordination of resources.
1.3.8  Site Vice President Overall responsibility for the management and implementation of the restart plan to achieve the purpose described in section 1.1. Serves as chairman of the (SMRT).
1.3.9  Executive Vice President Nuclear Generation Responsible for authorizing startup and power ascension, and providing senior management oversight of the restart process.
1.3.10 Plant Performance Assurance Responsible to discharge performance assurance responsibilities under 10 CFR 50, Appendix B, to provide assurance that activities affecting quality are satisfactorily accomplished. See Attachment F for further details.
1.4 Cook Nuclear Plant Restart Process Overview The restart plan consists  of the following major activities:
(1)      scope determination (2)      work performance (3)      readiness assessment


6.0 Startup and Power Ascension Startup and power ascension, following the completion of the restart work will follow a deliberate and controlled approach that ensures operational and personnel safety.The normal startup management team will be augmented with a shift plant manager and shift engineering manager such that issues or concerns are promptly addressed and the status can be accomplished in a safe, controlled manner.The startup and power ascension actions summarized in this section do not change or alter any requirements of the startup procedures defined above.6.1 Management Oversight and Organizational Support The Cook Nuclear Plant management structure will be supplemented with a shift plant manager and shift engineering manager to compliment the shift maintenance manager during the startup and power ascension phase.The responsibilities of these positions are as follows: 6.1.1 Shift Plant Manager The shift plant manager provides on-shift (24-hour)presence as a direct representative of the plant manager and is responsible for maintaining an overall perspective of the startup process.If necessary, the shift plant manager is authorized to request operations to delay the startup, reduce power, or shutdown to make necessary repairs.6.1.2 Shift Engineering Manager The shift engineering manager provides on-shift (24-hour)presence as a direct representative of the plant engineering manager and is responsible for maintaining an overall perspective of engineering support of the startup process.The shift engineering manager will control on-shift engineering resources as necessary to support scheduled startup testing activities, resolve emergent operability issues, support maintenance and manage necessary reactor engineering test activities.
(4)   startup authorization (5)   startup and power ascension Following is a process map and summary of the activities with more detailed information presented in later sections of this document.
6.1.3 Shift Maintenance Manager The shift maintenance manager provides on-shift (24-hour)presence as a direct representative of the maintenance manager and is responsible for maintaining an overall perspective of maintenance support of the startup process.The shift maintenance manager will control on-shift maintenance resources as necessary to support scheduled startup testing activities, resolve emergent equipment issues, and support operations.
15 0
This organization will be implemented as directed by the plant manager at critical evolutions during startup such as change to mode 4, initial criticality, turbine roll, and parallel to grid.The organization will be disbanded as directed by the plant manager but not before mode 4 to 30%power.6.2 Operating Proficiency and Experience Review To minimize the potential for performance errors during the plant startup, the following actions will be taken:~operations personnel will utilize the simulator to practice the startup evolution and ensure understanding and proficiency with applicable startup procedures and special requirements; a review of past Cook Nuclear Plant startup issues relevant industry operating experience will be performed during the functional area reviews to ensure understanding of past experience and lessons learned;department communication meetings will be conducted with each plant department to discuss management expectations regarding the startup and power ascension processes, schedule, and responsibilities.
These~meetings will be completed prior to initiating the startup evolution.
16 ATTACHMENT A PURPOSE: Perform a system-based, multi-disciplinary technical review of potential restart issues associated with risk significant plant equipment.
This board will ensure consistent application of the restart criteria contained in Attachment C of the Cook Nuclear Plant Restart Plan among system engineers, and ensure that restart decisions reflect the shared concerns of Operations, Maintenance and Engineering.
The result of this review will be to define the equipment related work which is needed to ensure a safe and event free startup and achieve a reliable post startup operating cycle.MEMBERS: Director Plant Engineering (Chair)Mechanical Component Manager Electrical System Manager.Safety and Analysis Manager I&C Manager Performance Testing Manager Preventive Maintenance Manager Board Secretary Non-Member:
Additional attendance by members of Restart Oversight Committee is expected to reinforce expectations and provide oversight for the restart Issue review process.Alternate chair: Site Engineering Managers Alternate safety and analysis manager: Engineers in the Safety and Analysis Section, subject to acceptance of the SERB chair or alternate chair.QUORUM: Chair (or alternate), two Onsite Managers, Safety and Analysis Manager (or alternate), and Secretary.
17 0
ACTIONS: 3.5.6.Review all potential restart items identified by System Engineers based on criteria defined in the restart plan;the System Engineer will present the proposed restart items for discussion.
A representative of Operations and Maintenance knowledgeable of the system's restart issues will support the system engineer and ensure the perspective of the other production groups is considered.
The Operations representative will normally be an SS or a US of the Operations crew responsible for the system, but can be an SS assigned to the%ork Control Center.Designate systems that are required to be presented to the SERB by system engineer, Maintenance and Operations.
The SERB will review all items identified as potential restart issues by the system engineer system readiness review.The system engineer, Operations or Maintenance representatives will also identify other issues which are not identified as potential restMt issues but may be questioned.
A complete list of open issues on each system will be available during SERB meetings.The SERB will review and question additional items as desired to determine if they should be restart issues.Ensure a record of all decisions and concerns raised by the SERB review is documented for futtue review.As a iesult of the review, recommend specific potential restart items for approval by the ROC.Review and approve the charter and any revisions needed to support the restart plan.Disband this board after startup when directed by the Site Vice President.
D.R.Hafer Director of Plant Hnginccting 18


ATTACHMENT B PURPOSE: Exercise management oversight and approval of physical and programmatic work scope necessary to ensure a safe and uneventful unit startup, and achieve a reliable operating cycle.Position Plant Manager, Chair Operations Superintendent Vice Chair Production Engineering Director Plant Engineering Director Maintenance Superintendent Licensing Manager Chemistry Superintendent Radiation Protection Superintendent Training Superintendent Restart Manager Restart Plan Project Manager*Secretary*
f Cook Plant Restart Plan Overview L1      srv Bgheen 15      sERS    sa        Roc            2.1    Reaw  Qeneoer M                    41        srNT    $ .1      opearoe Perform System  Rexxnmed Restart Appmve Restart Work                            Perform Rnat Review                     Restart And Power Readiness Reviews                                            Perform Restart Work                      Reconvnend Restart Work Scope          Scope                                    Racer rvnend Startup                        Operation 12        Ileager                                  Final Review Perform F nctional Area Readeess Reviews 12          nanoyoo Perform Progranmatic Rearfeess Reviews 1A    ovRers~
Doug Cooper Bob Gillespie Ken Baker Don Hafer John Boesch Mark Ackerman Dave Morey Doug Noble Dennis Loope John Stubblefield Phil Gora Betty Clark Alternate Bob Gillespie Guy Tollas Alberto Verteramo Mike Finissi Mark Stark Gordon Arent Bob Claes Paul Holland Dennis Willemin Dick Strasser Sandy McClintock
Perform Containment Readiness Review
*Indicates non-voting members QUORUM: Chairperson or vice chairperson, and three (3)additional voting members, two of which must be primary members.Attendance
&om Performance Assurance and Business Performance is strongly encouraged to perform an active oversight role.ACTIONS: 2.Set and communicate expectations for the organization to evaluate work items against the restart scope criteria.Ensure screening criteria are consistently applied via the restart oversight committee review, meeting and approval process.19 4 I Some items that meet one or more of the criteria maybe deferred until after restart if there is special consideration that provides the basis for this decision.Examples may include items that are only a concern during certain seasons, reduced risk of performing the work during a system outage, or implementation ofadequate compensatory actions until a long-term solution is defined.A clear basis for deferral of these items is to be provided.3.Review and approve: A.Restart action items to be completed prior to star{up.B.Station readiness to initiate until startup and power ascension as determined by the results of the assessment of readiness to startup, 4.Maintain arecotd ofpresentations, discussions, deliberations and basis for decisions and recommendations.
5, Review charter as necessary to accommodate changing conditions.
Convene as necessary to accomplish this charter prior to and during starship.Disband after unit startup when directed by the site vice president..
Site Vice dent Date 20 ATTACHMENT C.To be included in the plant restart work scope, items must meet the following criteria: 1.Level 1 Screening Resolves an immediate industrial or nuclear safety, operability or regulatory issue.These issues will be mandatory restart items.1.Necessaiy to address the voluntary shutdown for the A/E inspection and related programmatic issues.I 2.Necessary to address the confirmatory action letter.3.Required to return an INOPERABLE system, subsystem or component to OPERABLE status.4.Required to resolve an immediate industrial or nuclear safety concern.5.Necessary to address regulatory commitments.
2.Level 2 Screening Not an immediate industrial or nuclear safety, operability or regulatory issue.These issues will be considered for addition to the restart item list based on the review and recommendations of plant engineering, operations, and maintenance if the action: 1~Eliminates an existing component failure, deficiency, or condition that could result in operation in, or entry to, an LCO action statement.
'2.Resolves existing deficiencies or conditions that: a.would result in failure or inability to perform a required surveillance test during the current outage or the following operating cycle in accordance with the plant technical specifications; b.would increase the risk to operation for safety associated with performing a surveillance; or c.would result in the failure to meet a license requirement or a restart commitment to an outside agency.21


3.Restores degraded critical components or conditions that could result in a plant transient, power reduction or shutdown.4.Resolves conditions that have resulted in repetitive safety system or equipment failures.5.Restores hcensing basis deficiencies to conforming conditions (extended programmatic reviews and scheduled coirective actions maybe completed post-restart with the proper justification of no safety impact, a satisfactory OPERABILITY determination, and appropriate regulatory communication).
The'objective of the restart readiness assessment is to ensure that the integrated set of plant equipment, human resources and work programs are capable of supporting safe and reliable 1.1        Sys Engineers    power operations.       The restart readiness assessment will be initiated in parallel with the execution and completion of restart Perform System work.
6.Corrects equipment with design basis deficiencies; i.L, deficiencies in safety-related or technical specification equipment not in conformance with design basis documents such as the FSAR(extended programmatic reviews and scheduled comctive actions may be completed post-restart with justification of no safety impact, a satisfactory OPERABILITY determination and appropriate regulatory communication).
'eadiness        Reviews The restart readiness assessment      will focus on the following 1.2        ~
7.Corrects deficiencies in configuration management programs, processes, engineering analysis codes, or operating, maintenance, or test procedures that have a reasonable probability of affecting equipment OPERABILITY (documentation deficiencies, which have no safety impact, may be completed post-restart).
Managers Perform Functional                      ~   plant system readiness Area Readiness                        ~  functional area readiness Reviews                          ~  programmatic readiness
8, Eliminates conditions that create a potential for peieonnel radiation exposure, radioactivity release, or efHuent discharge in excess of limits.9.Reduces aunulative deficiencies, backlogs or conditions that, in the aggri~te, are evaluated to have significant negative impact on safety, operability or reliable plant operation.(Not applicable to individual work items).Ap paved: Site ident 22 23 ATTACHhgNT D.120 Vac/CRID Inverters Air Recirculation/Hydrogen Skimmer Auxiliary Feedwater 250 Vdc Station Batteries Component Cooling Water Containment Containment Spray Control Air ECCS Accumulators ECCS Charging Modes 1, 2, 3/CVCS High-head Injection ECCS RHR ECCS SI Electrical Safety Busses (4000 V/600 V)Emergency Diesel Generators Essential Service Water Ice Condenser Main Steam Non-essential Service Water Plant Air Compressors Reactor Coolant System/RCS Pressure Relief Reactor Protection System/Solid-state Protection/ESFAS 24
                                          ~  containment readiness 1.3    . Managers Perform Programmatic Readiness Reviews 1.4    Dir Plant Engineering Perform Containment Readiness Reviews 1.5          SERB          The restart work scope may be increased as a result of the plant system assessments or other ongoing work. The system Recommend Restart engineers willrecommend the restart work scope to the System Work Scope Engineer Review Board (SERB).


ATTACHMENT E Restart Process Map (1)Restart Work Scope Determination 1.1 Beni Engheenrc Select Plant Systems For Review Approve Plant System For Review 1.3 SYS ENO~OPS, Mr Perform System Reviews Addithnal Work Sco Required?Perform Readiness Assessment
1.6                          All restart scope additions    will be approved by the Restart
)sadness Assessmara 1 1.2 ROC Validate Existing Resta Work Scope YES 1.5 SERB SERB Review And Approval Approve Restart Work Scope Additions Approved Restart Scope Additions 1.7 SYS ENGR Monitor Work, Address Emergent Issues Perform Work Scop Approved Restart Work Scope (2)Restart Work Scope Performance 2.1 Mr, IS Plan Restart Work Schedule Restart Wo 2.3 Al Oqy Conduct Restart Work Perform Readiness Assessment I3I eenness Assessnenl 3.1 25
            'OC'pprove Oversight Committee (ROC).
Restart Work Scope 2.1     Restart Manager    Following determination    of the restart work scope by the ROC, the restart manager is responsible for coordinating the planning, Perform Restart Work       scheduling and completion of the work.
3.1       ROC,PNSRC          Results of the restart assessment will be presented to the Restart Oversight. Committee (ROC) with an af5rmation by the Perform Final Review        responsible system engineer or engineering manager, and the Recommend Startup            functional area superintendent of the readiness of the system'r organization to support plant startup and safe, reliable power operations.
4.1                   SMRT  Following presentation and acceptance of the assessment results by the ROC, the Site Vice President will convene the SMRT to perform an integrated review of the affirmations, verify Recommend Restart compliance with regulatory commitments and any other special criteria that may impact the initiation of startup activities.
4.2     Exec Vice Pres      Based on the results ofthis review, the Executive Vice President Nuclear Generation willauthorize startup and power ascension.
Authorize Restart 5.1                   OPS  Startup and power ascension following the completion of startup work willfollow a deliberate and controlled approach that ensures Startup and Power        operational and personnel safety. The normal startup process Ascension            defined in Cook Nuclear Plant procedures willbe supplemented with appropriate management oversight and support &om engineering and maintenance organization such that issues or concerns are promptly addressed and the startup can be accomplished in a safe, controlled manner.


ATTACHMENT E Restart Process Map (3)Readiness Assessment 3.1 Sye Eny'neer Affirm Plant System Readiness sa SERB SERB Confirms Readiness Plant System Ready?SERB no Restart Work Scope Determination 3A Menegea Affirm Functional Area Readiness Functional Areas Ready 1 oeienlIoeen 1A Yes Yes S.e u ORBS Affirm Programmatic Readiness Programs Ready?no Restart Work Scope Determination 1 oeienneieeen 1A Yes S.la Mender Compliie And Present Results Restart Authorization 4 eeien ALerertzeiion AA no Restart Work Scope Determination 1 oeienTwLteen 1A Yes Affirm Containment Readiness Containment Ready?26 no Restart Work Scope Determination Oe~1A
0 2.0 Restart Work Scope Determination 2.1   Restart Work Scope Determination Process The restart work scope is being defined through a determination process driven by the ROC consistent with their charter. Outstanding work items and selected progranunatic issues are reviewed against defined criteria to determine which items should be included in the restart scope. System engineers have the largest role in this process, but there is also considerable involvement from other organizations including operations, design engineering, and maintenance. The restart work scope determination process is outlined in attachment E..
2.2  Plant System Review Plant systems are reviewed by the system engineer using the plant system review instructions with results and recommendations presented to the ROC.
The plant system review process consists    of four primly elements    as described below.
2.2,1   Selection  of Plant Systems Plant systems have been selected for a detailed review and affirmation based on the historical performance and risk significance of the system.
This review willbe performed in accordance with the plant system readiness review instructions. Results of the assessment of selected systems willbe presented first to the SERB and, upon approval, to the ROC with appropriate recommendations for additional actions'o be performed after restart. The systems are listed in attachment D.
The remaining systems willbe assessed and evaluated as part of the line responsibility of the engineering organization through the use of the SERB.
Issues that affect restart scope on these systems willbe presented to the ROC on a case basis.
2.2.2  Restart Work Scope Additions The restart work scope addition for plant systems is focused on those items not already included in the restart work scope. Items already scheduled for completion prior to restart are not evaluated against the criteria provided in attachment C unless there is a proposal to delete them. The goal of the system review and work scope addition process is to define'the work necessary for completion prior to restart such that the system is capable of supporting safe and reliable power operation. This review will include the following:
10


ATTACHMENT E Restart Process Map ATTACHMENT E Restart Process Map{4)Restart Authorization
(a)   the magnitude, significance and risk of items which willbe resolved aAer restart should be defined and evaluated; assurance that recurring problems on the system that could affect safe and reliable operations are being fixed; (c)    assurance that any design basis and licensing issues on the system are being addressed within a time frame that is appropriate for the issue; and assurance that operators willnot be unnecessarily challenged in the operation of the system during normal, abnormal, or emergency conditions.
{5)Power Operation 4.1 ROC Perform Final Readines Review 42 ROC, PNSRC Perform Final Review Recommend Startup Recommend Restart 4A Exec Vlcc Presa%Authorize Restart 5.1 OexeSNN Start up and Power Ascension 27 V.~
Based on the review of open work items against the criteria presented in attachment C, the system engineer is to provide recommendations for the restart scope changes for the selected systems in attachment D to the SERB and upon approval to the ROC. Items recommended for addition to the restart scope for remaining plant systems willbe handled on an item specific basis by the ROC following an initial review by line management.
ATTACHMENT F Perfo ance Assurance Oversight of Restart Performance Assurance Oversight of Restart The purpose of this oversight effort is to discharge Performance Assurance responsibilities, under 10 CFR 50, Appendix B, to provide assurance that activities afffecting quality are satisfactorily accomplished.
It should be noted that. it was not the intent of this program to resolve all design basis issues. We are committed to a long range program to accomplish this resolution.
This oversight will include providing independent feedback to line management concerning the adequacy of the restart plan and how effective the plan is being implemented.
2.2.3 Monitoring Restart Work, Addressing Emergent Issues and Performing a More Detailed Assessment of System Readiness System engineering is to monitor the progress of work on assigned system and address emergent issues as required. Any major restart scope impacts defined by emergent issues should be brought to the ROC following line management review. Allother emergent issues are assessed daily by the engineering managers.
To enhance independence, personnel conducting this oversight will include those who have not been involved with the evolution of practices and lessons learned as the Restart Plan has been implemented.
Also, the system engineer is to use this period to complete the assessment and evaluation of system readiness in preparation for the final system readiness review and affirmation of readiness for restart.
Critical activities were identified
2.2.4 Final System Readiness Review and Affirmation This aspect of the system readiness review process is summarized in section 4.1. Although it is not expected that any significant restart work scope issues willbe identified during this final review, ifany are identified, they are to be brought to the immediate attention of the ROC (following line management review).
&om the restart plan.Critical attributes of these activities were identified and scheduled for oversight as follows: List of Critical Activities System Readiness Reviews Functional Area Reviews Programmatic Reviews Containment Readiness Reviews Determination of Restart Work Scope Restart Work SERB ROC Integration of Reviews Startup and Power Ascension Critical Attributes of Critical Activities System Readiness Reviews Are the right systems being reviewed?Are the right methods being used to conduct the reviews?Are the reviews effective?
11
Functional Area Reviews Are the right areas being reviewed?Are the right methods being used to conduct the reviews?Are the reviews effectlve2 Programmatic Reviews Are the right programs being reviewed?Are the right methods being used to conduct the reviews?Are the reviews effective2 Containment Readiness Reviews Is the right scope being reviewed2 Are the right methods being used to conduct the reviews?Are the reviews effective2 Determination of Restart Work Scope Is the right criteria being used to determine restart work scope?Are there any hidden inventories of items that are not being considered?
Review work not included in restart?Adherence to Criteria Expert Judgement 28


ATTACHMZYI' Perf ce Assurance Oversight of Restart Restart Work Is restart work being performed to proper standards?
2.3 Redefined Restart      Work Scope The restart work scope may be redefined based on the evaluation process described above. Decisions made by, the ROC regarding the restart work scope are documented in meeting minutes and work item status is tracked.
Engineering Maintenance Operations Other SERB Is the charter adequate?Is the SERB effectively carrying out the charter2 ROC Is the charter adequate?Is the ROC effectively carrying out the charter2 Integration of Reviews Is the method of integrating reviews adequate?Plant Equipment Human Resources Work Programs Startup and Power Ascension Is it adequately Planned2 Is it adequately Scheduled?
3.0    Restart Work Scope Performance 3.1    Work Scope Performance Following determination of the restart work scope by the ROC, the restart manager is responsible for coordinating the planning, scheduling and completion of the work, including the implementation ofprograinmatic changes. The restart work scope performance process is outlined in attachment E.
4.0 Restart Readiness Assessment
                                              'he restart ieadiness assessment is an integrated line management assessment that assists station management in determining the readiness to initiate startup and achieve safe, reliable power operation through the next operating cycle. The restart readiness assessment process is outlined in attachment E, This form of assessment is one element of a comprehensive plant assessment program that is the foundation of our continuous improvement philosophy. Implementation of this action is consistent with the experience and lessons learned of other nuclear utilities. The restart readiness assessment is being implemented at Cook Nuclear Plant based on lessons learned and willbe captured such that this process can be implemented on a routine basis in the future.
The restart readiness assessment for restart willverify the completion of all defined restart work and the affirmation of system, department and restart readiness for startup and power operations. Results of the assessment and afBrmation of readiness willbe presented to the ROC by the responsible system engineer, functional area manager and operations shift supervisor. - Following acceptance by the ROC, the site vice president will convene an SMRT meeting to review these affirmations and verify compliance with regulatory commitments and any other applicable criteria. The site vice president will recommend start up of the units based on this review, and assurance regarding the readiness of the station to initiate startup and safely, reliably operate through the next operating cycle.
Following is a summary of the key elements of the program.
4.1 System Readiness System readiness affirmations by the system engineer are to confirm that plant systems meet functional design requirements, have been suitably tested and are ready to support safe and reliable startup and operation through the next cycle. This afIirmation is based on the work completed as described in section 2.2, and is to 12
 
include a coordinated system walkdown of the system with operations and maintenance personnel on systems defined by the plant engineering manager.
Where necessary, compensatory actions for rescheduled work or other areas of performance risk are to be defined and addressed.
System readiness affirmations are to be presented by the system engineer to the SERB and upon its approval to the ROC for the systems identified in attachment D.
Affirmation of system readiness is documented with the signature of the system engineer and manager. Affirmation of individual system readiness for the remaining plant systems willbe addressed as part of the system engineering line management responsibility and willbe one element of the functional area readiness evaluation.
4.2 Functional Area Readiness r
Functional area readiness by selected functional areas is an affirmation that the department is in an appropriate state of readiness to support startup and safe and reliable power operation through the next cycle. Functional area readiness will include items such as:
(a)    adequacy of staffing levels, personnel experience and qualifications to demonstrate compliance with regulatory requirements and commitments; completion of personnel training on normal startup evaluations, power ascension requirements, industry operating experience including extended shutdown and unusual events at similar plants, emergency preparedness, changes in plant configuration, changes in plant operating and emergency procedures, and changes in key adininistrative procedures and processes; (c)    resolution of significant performance deficiencies and reduction of backlogs (corrective action, corrective maintenance etc. ) to manageable levels; and (d)    establishment of goals and priorities for the continued improvement of the department including use of critical assessment methods.
Functional Area readiness willbe affirmed to the ROC by the following functional
            ~  operations                                    outage management
            ~  maintenance                                    licensing plant engineering                              fuels design engineering                      ~    plant protection
          ~    production engineering                        information management chemistry                                      plant performance assurance radiation protection Affirmation of functional area readiness is documented with the signature of the functional area manager.
13
 
4.3 Programmatic Readiness Programmatic readiness review willconfirm that programs are in place to support identification and correction of problems. Programmatic issues identified during the unit shutdown have been evaluated and necessary corrective or preventive actions have been completed. Programs in place at the time of unit start-up will ensure that the plant willbe operated in conformance with its design bases and in accordance with the AEP quality assurance program.
A/E programmatic issues potential bypass of 50.59 safety evaluations 50.59 safety evaluation quality corrective action program improvements surveillance program assessment 4.4 Containment Readiness The containment readiness review will focus on the ability of the containment system to meet the intended functional design requirements. The critical points  of the review will focus on the system materiel condition, adequate surveillance testing, and the system configuration control, 5.0 Restart Authorization The restart authorization process is outlined in attachment E.
5.1 Restart Oversight Committee (ROC) Review and Approval The ROC willreview and accept the assessment affirmations in 4.1, 4.2, 4.3 and 4.4. A restart recommendation willbe made to the SMRT based on the results of the functional area assessments.
5.2    Senior Manager Review Team (SMRT) Review and Approval Upon review and acceptance of the assessment affirmations in 4.1, 4.2, 4.3 and 4.4 by the ROC, the site vice president willconvene an SMRT meeting to perform an integrated review and approval.
5.3    Executive Vice President Restart Authorization Based on this review the executive vice president nuclear generation  willprovide-the authorization for restart and power ascension.
14
 
6.0 Startup and Power Ascension Startup and power ascension, following the completion of the restart work willfollow a deliberate and controlled approach that ensures operational and personnel safety. The normal startup management team willbe augmented with a shift plant manager and shift engineering manager such that issues or concerns are promptly addressed and the status can be accomplished in a safe, controlled manner. The startup and power ascension actions summarized in this section do not change or alter any requirements of the startup procedures defined above.
6.1 Management Oversight and Organizational          Support The Cook Nuclear Plant management structure willbe supplemented with a shift plant manager and shift engineering manager to compliment the shift maintenance manager during the startup and power ascension phase. The responsibilities of these positions are as follows:
6.1.1  Shift Plant Manager The shift plant manager provides on-shift (24-hour) presence as a direct representative of the plant manager and is responsible for maintaining an overall perspective of the startup process. Ifnecessary, the shift plant manager is authorized to request operations to delay the startup, reduce power, or shutdown to make necessary repairs.
6.1.2  Shift Engineering Manager The shift engineering manager provides on-shift (24-hour) presence as a direct representative of the plant engineering manager and is responsible for maintaining an overall perspective of engineering support of the startup process. The shift engineering manager willcontrol on-shift engineering resources as necessary to support scheduled startup testing activities, resolve emergent operability issues, support maintenance and manage necessary reactor engineering test activities.
6.1.3  Shift Maintenance Manager The shift maintenance manager provides on-shift (24-hour) presence as a direct representative of the maintenance manager and is responsible for maintaining an overall perspective of maintenance support of the startup process. The shift maintenance manager willcontrol on-shift maintenance resources as necessary to support scheduled startup testing activities, resolve emergent equipment issues, and support operations.
15
 
0 This organization willbe implemented as directed by the plant manager at critical evolutions during startup such as change to mode 4, initial criticality, turbine roll, and parallel to grid. The organization willbe disbanded as directed by the plant manager but not before mode 4 to 30% power.
6.2 Operating Proficiency and Experience Review To minimize the potential for performance errors during the plant startup, the following actions willbe taken:
              ~  operations personnel willutilize the simulator to practice the startup evolution and ensure understanding and proficiency with applicable startup procedures and special requirements; a review of past Cook Nuclear Plant startup issues relevant industry operating experience willbe performed during the functional area reviews to ensure understanding of past experience and lessons learned; department communication meetings willbe conducted with each plant department to discuss management expectations regarding the startup and power ascension processes, schedule, and responsibilities. These
                ~
meetings willbe completed prior to initiating the startup evolution.
16
 
ATTACHMENTA PURPOSE:  Perform a system-based, multi-disciplinary technical review of potential restart issues associated with risk significant plant equipment. This board will ensure consistent application of the restart criteria contained in Attachment C of the Cook Nuclear Plant Restart Plan among system engineers, and ensure that restart decisions reflect the shared concerns of Operations, Maintenance and Engineering. The result of this review will be to define the equipment related work which is needed to ensure a safe and event free startup and achieve a reliable post startup operating cycle.
MEMBERS:
Director Plant Engineering (Chair)
Mechanical Component Manager Electrical System Manager.
Safety and Analysis Manager I&C Manager Performance Testing Manager Preventive Maintenance Manager Board Secretary Non-Member: Additional attendance by members of Restart Oversight Committee is expected to reinforce expectations and provide oversight for the restart Issue review process.
Alternate chair:        Site Engineering Managers Alternate safety and analysis manager:      Engineers in the Safety and Analysis Section, subject to acceptance of the SERB chair or alternate chair.
QUORUM:  Chair (or alternate), two Onsite Managers, Safety and Analysis Manager (or alternate), and Secretary.
17
 
0 ACTIONS:
Review all potential restart items identified by System Engineers based on criteria defined in the restart plan; the System Engineer willpresent the proposed restart items for discussion. A representative of Operations and Maintenance knowledgeable of the system's restart issues will support the system engineer and ensure the perspective of the other production groups is considered. The Operations representative will normally be an SS or a US of the Operations crew responsible for the system, but can be an SS assigned to the%ork Control Center.
Designate systems that are required to be presented to the SERB by system engineer, Maintenance and Operations.
: 3.      The SERB willreview all items identified as potential restart issues by the system engineer system readiness review. The system engineer, Operations or Maintenance representatives willalso identify other issues which are not identified as potential restMt issues but may be questioned.
A complete list of open    issues on each system willbe available during SERB meetings. The SERB willreview and question additional items as desired to determine ifthey should be restart issues.
: 5.      Ensure a record of all decisions and concerns raised by the SERB review is documented for futtue review.
: 6.      As a iesult of the review, recommend specific potential restart items for approval by the ROC.
Review and approve the charter and any revisions needed to support the restart plan. Disband this board after startup when directed by the Site Vice President.
D. R. Hafer Director of Plant Hnginccting 18
 
ATTACHMENTB PURPOSE:        Exercise management oversight and approval of physical and programmatic work scope necessary to ensure a safe and uneventful unit startup, and achieve a reliable operating cycle.
Position                                                      Alternate Plant Manager, Chair                                  Doug Cooper          Bob Gillespie Operations Superintendent Vice Chair                  Bob Gillespie        Guy Tollas Production Engineering Director                      Ken Baker            Alberto Verteramo Plant Engineering Director                            Don Hafer            Mike Finissi Maintenance Superintendent                            John Boesch          Mark Stark Licensing Manager                                    Mark Ackerman        Gordon Arent Chemistry Superintendent                              Dave Morey            Bob Claes Radiation Protection Superintendent                  Doug Noble            Paul Holland Training Superintendent                              Dennis Loope          Dennis Willemin Restart Manager                                      John Stubblefield    Dick Strasser Restart Plan Project Manager*                        Phil Gora Secretary*                                            Betty Clark          Sandy McClintock
*Indicates non-voting members QUORUM:        Chairperson or vice chairperson, and three (3) additional voting members, two of which must be primary members. Attendance &om Performance Assurance and Business Performance is strongly encouraged to perform an active oversight role.
ACTIONS:
Set and communicate expectations for the organization to evaluate work items against the restart scope criteria.
: 2.      Ensure screening criteria are consistently applied via the restart oversight committee review, meeting and approval process.
19
 
4 I
 
Some items that meet one or more    of the criteria  maybe  deferred until after restart ifthere is special consideration  that provides the basis for this decision. Examples may include items that are only a concern during certain seasons, reduced risk of performing the work during a system outage, or implementation ofadequate compensatory actions until a long-term solution is defined. A clear basis for deferral of these items is to be provided.
: 3. Review and approve:
A.      Restart action items to be completed prior to star{up.
B.      Station readiness to initiate until startup and power ascension as determined by the results of the assessment of readiness to startup,
: 4. Maintain arecotd ofpresentations, discussions, deliberations and basis for decisions and recommendations.
5,  Review charter as necessary to accommodate changing conditions.
Convene as necessary to accomplish this charter prior to and during starship.
Disband after unit startup when directed by the site vice president..
Site Vice dent                                                                  Date 20
 
ATTACHMENTC          .
To be included in the plant restart work scope, items must meet the following criteria:
: 1. Level  1  Screening Resolves an immediate industrial or nuclear safety, operability or regulatory issue. These issues willbe mandatory restart items.
: 1. Necessaiy to address the voluntary shutdown for the A/E inspection and related programmatic issues.
I
: 2. Necessary to address the confirmatory action letter.
: 3. Required to return an INOPERABLE system, subsystem or component to OPERABLE status.
: 4. Required to resolve an immediate industrial or nuclear safety concern.
: 5. Necessary to address regulatory commitments.
: 2. Level 2 Screening Not an immediate industrial or nuclear safety, operability or regulatory issue. These issues will be considered for addition to the restart item list based on the review and recommendations of plant engineering, operations, and maintenance    ifthe action:
1 ~  Eliminates an existing component failure, deficiency, or condition that could result in operation in, or entry to, an LCO action statement.
      '2. Resolves existing deficiencies or conditions that:
: a. would result in failure or inability to perform a required surveillance test during the current outage or the following operating cycle in accordance with the plant technical specifications;
: b. would increase the risk to operation for safety associated with performing a surveillance; or
: c. would result in the failure to meet a license requirement or a restart commitment to an outside agency.
21
: 3. Restores degraded critical components or conditions that could result in a plant transient, power reduction or shutdown.
: 4. Resolves conditions that have resulted in repetitive safety system or equipment failures.
: 5. Restores hcensing basis deficiencies to conforming conditions (extended programmatic reviews and scheduled coirective actions maybe completed post-restart with the proper justification of no safety impact, a satisfactory OPERABILITY determination, and appropriate regulatory communication).
: 6. Corrects equipment with design basis deficiencies; i.L, deficiencies in safety-related or technical specification equipment not in conformance with design basis documents such as the FSAR(extended programmatic reviews and scheduled comctive actions may be completed post-restart with justification of no safety impact, a satisfactory OPERABILITYdetermination and appropriate regulatory communication).
: 7. Corrects deficiencies in configuration management programs, processes, engineering analysis codes, or operating, maintenance, or test procedures that have a reasonable probability of affecting equipment OPERABILITY (documentation deficiencies, which have no safety impact, may be completed post-restart).
8,  Eliminates conditions that create a potential for peieonnel radiation exposure, radioactivity release, or efHuent discharge in excess of limits.
: 9. Reduces aunulative deficiencies, backlogs or conditions that, in the aggri~te, are evaluated to have significant negative impact on safety, operability or reliable plant operation. (Not applicable to individual work items).
Ap paved:
Site          ident 22
 
23 ATTACHhgNTD .
120 Vac/CRID Inverters AirRecirculation/Hydrogen Skimmer Auxiliary Feedwater 250 Vdc Station Batteries Component Cooling Water Containment Containment Spray Control Air ECCS Accumulators ECCS Charging Modes 1, 2, 3/CVCS High-head Injection ECCS RHR ECCS SI Electrical Safety Busses (4000 V/600 V)
Emergency Diesel Generators Essential Service Water Ice Condenser Main Steam Non-essential Service Water Plant AirCompressors Reactor Coolant System/RCS Pressure Relief Reactor Protection System/Solid-state Protection/ESFAS 24
 
ATTACHMENTE Restart Process Map (1) Restart Work Scope Determination 1.1    Beni Engheenrc                                  1.3    SYS ENO ~ OPS, Mr Select Plant Systems          Approve Plant System        Perform System      Addithnal Work Sco                Perform Readiness For Review                      For Review                Reviews                Required?                      Assessment
                                                                                                                  ) sadness Assessmara    1 YES 1.2          ROC 1.5          SERB Validate Existing Resta                                                            SERB Review And Work Scope                                                                          Approval Approve Restart Work Scope Additions Approved Restart Scope Additions 1.7        SYS ENGR Monitor Work, Address Emergent                                        Perform Work Scop Issues Approved Restart Work Scope (2 )Restart Work Scope Performance 2.1        Mr, IS                                          2.3        Al Oqy Plan Restart Work Perform Readiness Schedule Restart Wo          Conduct Restart Work Assessment I3I eenness Assessnenl  3.1 25
 
ATTACHMENTE Restart Process Map (3) Readiness Assessment 3.1      Sye Eny'neer sa        SERB Affirm Plant System    SERB Confirms Readiness            Readiness Plant System Ready?
SERB no Restart Work Scope Determination 1      oeienlIoeen  1A Yes 3A        Menegea Affirm Functional Area Readiness                Functional Areas Ready                      Yes no          Restart Work Scope Determination          S.la      Mender 1      oeienneieeen 1A      Compliie And Present Results          Restart Authorization S.e        u ORBS 4  eeien ALerertzeiion AA AffirmProgrammatic Readiness                    Programs Ready?                          Yes no                                Yes Restart Work Scope Determination 1      oeienTwLteen 1A AffirmContainment Readiness                  Containment Ready?
no Restart Work Scope Determination 26 Oe~          1A
 
ATTACHMENTE Restart Process Map ATTACHMENTE Restart Process Map
{4) Restart Authorization                                {5) Power Operation 4.1        ROC        42    ROC, PNSRC                        4A  Exec Vlcc Presa%      5.1      OexeSNN Perform Final Readines Perform Final Review Recommend Restart  Authorize Restart          Start up and Power Review          Recommend Startup                                                          Ascension 27
 
V
. ~
 
ATTACHMENTF Perfo                  ance Assurance Oversight      of Restart Performance Assurance Oversight of Restart The purpose of this oversight effort is to discharge Performance Assurance responsibilities, under 10 CFR 50, Appendix B, to provide assurance that activities afffecting quality are satisfactorily accomplished. This oversight will include providing independent feedback to line management concerning the adequacy of the restart plan and how effective the plan is being implemented. To enhance independence, personnel conducting this oversight will include those who have not been involved with the evolution ofpractices and lessons learned as the Restart Plan has been implemented.
Critical activities were identified &om the restart plan. Critical attributes        of these activities were identified and scheduled for oversight as follows:
List of Critical Activities System Readiness Reviews Functional Area Reviews Programmatic Reviews Containment Readiness Reviews Determination of Restart Work Scope Restart Work SERB ROC Integration of Reviews Startup and Power Ascension Critical Attributes of Critical Activities System Readiness Reviews Are the right systems being reviewed?
Are the right methods being used to conduct the reviews?
Are the reviews effective?
Functional Area Reviews Are the right areas being reviewed?
Are the right methods being used to conduct the reviews?
Are the reviews effectlve2 Programmatic Reviews Are the right programs being reviewed?
Are the right methods being used to conduct the reviews?
Are the reviews effective2 Containment Readiness Reviews Is the right scope being reviewed2 Are the right methods being used to conduct the reviews?
Are the reviews effective2 Determination of Restart Work Scope Is the right criteria being used to determine restart work scope?
Are there any hidden inventories of items that are not being considered?
Review work not included in restart?
Adherence to Criteria Expert Judgement 28
 
ATTACHMZYI' Perf               ce Assurance Oversight   of Restart Restart Work Is restart work being performed to proper standards?
Engineering Maintenance Operations Other SERB Is the charter adequate?
Is the SERB effectively carrying out the charter2 ROC Is the charter adequate?
Is the ROC effectively carrying out the charter2 Integration of Reviews Is the method of integrating reviews adequate?
Plant Equipment Human Resources Work Programs Startup and Power Ascension Is it adequately Planned2 Is it adequately Scheduled?
Is is adequately Performed (Onshift Observations)?
Is is adequately Performed (Onshift Observations)?
29 Revision Block Restart Plan Revisions Revision Number Description Page 26: New page.Added Revision Block Page 8"Authorize Restart": Deleted Executive Vice President Nuclear Engineering.
29
Added Executive Vice President Nuclear Generation.
 
Pages 20 and 21: Added reference numbers to restart criteria.Sect 1.3.5: Added Director Regulatory Affairs to SMRT Attachment A: Added Preventive Maintenance Manager to SERB charter Sect 1.3.10: Added Plant Performance Assurance responsibilities Added Attachment F, Performance Assurance Oversight Of Restart Index: Added Attachment F Attachment C: Added"operability or regulatory" to level 1 screening.
Revision Block Restart Plan Revisions Revision                                   Description                          Date Number Page 26: New page. Added Revision Block Page 8 "Authorize Restart": Deleted Executive Vice President Nuclear 4/7/98 Engineering. Added Executive Vice President Nuclear Generation.
Added 5.Necessary to address regulatory commitments.
Pages 20 and 21: Added reference numbers to restart criteria.
Added"regulatory" to level 2 screening.
Sect 1.3.5: Added Director Regulatory Affairs to SMRT Attachment A: Added Preventive Maintenance Manager to SERB charter Sect 1.3.10: Added Plant Performance Assurance responsibilities Added Attachment F, Performance Assurance Oversight Of Restart Index: Added Attachment F Attachment C: Added "operability or regulatory" to level 1 screening.
Date 4/7/98 30 e.}}
Added 5. Necessary to address regulatory commitments. Added "regulatory" to level 2 screening.
30
 
e.}}

Latest revision as of 00:56, 4 February 2020

Rev 2 of Cook Nuclear Plant Restart Plan.
ML17334A730
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 05/06/1998
From: Sampson J
INDIANA MICHIGAN POWER CO.
To:
Shared Package
ML17334A731 List:
References
PROC-980506, NUDOCS 9806100446
Download: ML17334A730 (52)


Text

ATTACHMENT TO AEP:NRC: 1303 RESTART PLAN - REVISION 2 9806f00446 980506 PDR ADOCK 05000315 P PDR

'I Cook Nuclear Plant Restart Plan Revision 2 J. R Sampson Site Vice President

Introduction and Overview 1.1 Purpose 1.2 Background 1.3 Roles and Responsibilities 1.4 Cook Nuclear Plant Restart Process Overview

2. Restart Work Scope Determination 2.1 Restart Work Scope Determination Process 2.2 Plant System Reviews 2.3 Redefined Restart Work Scope 3.. Restart Work Scope Performance 3.1 Work Scope Performance
4. Restart Readiness Assessment 4.1 System Readiness 4.2 Functional Area Readiness 4.3 Prograinmatic Readiness 4.4 Containment Readiness
5. Restart Authorization 5.1 Restart Oversight Committee (ROC) Review and Approval 5.2 Senior Manager Review Team (SMRT) Review and Approval 5.3 Executive Vice President Restart Authorization
6. Startup and Power Ascension 6.1 Management Oversight and Organizational Support 6.2 Operating Proficiency and Experience Review Attachments:

A system engineer review board (SERB) charter B restart oversight committee (ROC) charter C criteria for work included in restart scope D plant systems to be reviewed by ROC E restart process map F plant performance assurance oversight of restart Revision Block

1.0 Introduction and Overview 1.1 Purpose The Cook Nuclear Plant Restart Plan describes the activities and controls that will be implemented to ensure the facility is ready to safely start up and operate in an event &ee manner. To provide us with the assurance that this can be accomplished we must determine that our people, plant and programs are ready to meet this challenge. The plan will assess these areas and identify any needed action to ensure we can safely startup and operate reliably in an event &ee manner.

The plan will assess the following:

~ People Have we adequately prepared our people such that they are trained on the changes in our programs and procedures and understand the issues involved in restarting and operating the plant? Are the functional areas staffed, organized and functioning at a level to support safe startup and reliable operation in an event &ee manner?

~ 'rograms Have our programs and procedures been adjusted to include the lessons learned?

Are they adequate to allow us to return to operation and prevent future nonconforming conditions?

o Plant Are our materiel condition, configurations, restart. readiness of systems and ability to meet design function while complying with applicable regulations adequate to allow us to return to service?

This plan provides a map to conduct the assessments needed to assure ourselves that we are ready to restart. The actions and activities needed to do this and any corrective actions willbe performed in accordance with approved procedures.

1.2 Background During the July - September, 1997, time&arne, the NRC conducted an architect engineering inspection at Cook Nuclear Plant. The AE inspection focused primarily on two safety systems, ECCS and CCW. Six weeks into the AE inspection, a question surfaced regarding our ability to sustain long-term cooling of the core during a design basis accident. As a conservative measure, both units were shut down on September 9 and cooled to cold shut down until this question could be properly answered.

On September 12, the NRC concluded the AE inspection with a public exit

. meeting. Following this meeting, Cook Nuclear Plant committed to addressing and resolving seven (7) specific issues identified during the inspection prior to restart of the units. It was believed that these seven issues could be resolved within a few weeks. Subsequent to our letter to the NRC committing to these actions, the NRC issued a confirmatory action letter (CAL) identifying their approval would be required prior to restarting the units. The NRC CAL also identified two additional actions to be taken as a condition for restarting the units.

The unit 2 reactor was scheduled for a refueling to begin in late September, 1997.

The unit 2 core was within two weeks of normal burn up window at the time of the unscheduled shut down. Our objective was to resolve the CAL items, and restart unit 2 for the remaining two weeks of fuel burn up, then commence the refueling outage.

Over the next several weeks, it became apparent that a restart would not be achievable in the near term, and a decision was made to begin the unit 2 refueling outage and its scheduled work on October 20, 1997. In parallel with the outage work, our organization worked through the many AE inspection/CAL issues. It appeared that a January 1998 restart of both units would be feasible.

During the time period of January - February 1998, the Cook Nuclear Plant senior management team had several meetings with the NRC, and the CAL issues were nearing resolution. It was during this time period that several new issues arose, concerning or relating to our containment systems that would require significant resources and focus to reconcile.

Given the significant period that both units had been shut down up to this point, and the uncertainty for a near-term start up date, it was decided that the scope of both units'utages needed to be re-evaluated, and a more rigorous assessment of plant readiness was required prior to any restart. These steps are necessary in order to achieve the objectives described in Section 1.1. The key factors that led to this decision are:

Design basis concerns and equipment performance and testing issues which have come to light in recent months raised the concern that additional hardware and non-hardware activities may need to be completed during this extended shut down.

Confirmation is required that procedure inadequacies or equipment deficiencies that may challenge plant operators during normal, abnormal, or emergency conditions have been adequately identified and addressed.

Lessons learned &om other nuclear utilities in the implementation of an integrated assessment of readiness to restart following an extended shutdown

period are being adopted and applied to Cook Nuclear Plant on a pilot basis during this outage.

1.3 Roles and Responsibilities Roles and responsibilities for the execution of this plan are as follows:

1.3.1 AllNuclear Generation Employees Responsible for supporting the restart activities by focusing on safe operations and continuous improvement. All employees are obligated to raise any and all quality concerns to management's action through the corrective action program.

1.3.2 System Engineers Responsible for successful completion of restart work on selected systems, performing an assessment of system readiness to support unity restart and safe, reliable power operations, implementing necessary corrective actions and providing affirmation of readiness.

1.3.3 System Engineering Review Board (SERB)

Board internal to the engineering organization responsible for assessing the readiness ofplant systems and providing recommendations for additional restart scope to the ROC. The SERB charter is provided in attachment A.

1.3.4 Restart Oversight Committee (ROC)

Responsible for determining the restart scope of work using consistent standards and criteria approved by the senior management review team (SMRT) and assessing the readiness of Cook Nuclear Plant to restart and resume power operations, using the process approved by the SMRT in this procedure. The ROC charter is provided in attachment B.

1.3.5 Senior Management Review Team (SMRT)

Members: Site Vice President (Chairman)

Vice President Nuclear Engineering Director Performance Assurance Director Regulatory Affairs

  • Independent Safety Review Committee Member

-*This member will actively participate as available, and willperform a continuous oversight role. Routine communication with this member may

be accomplished through review of meeting minutes, phone conferencing and follow up interviews with the SMRT members.

The SMRT is responsible for generation and approvals of:

(a) criteria for screening work items required for completion of restart; and, monitoring and oversight of the process for affirmation and approval of plant and staff readiness for restart.

1.3.6 Plant Manager, Engineering Managers and Department Superintendents Responsibility for successful completion of the restart work, performing an assessment of functional area readiness to support unit restart and safe, reliable power operations, implementing necessary corrective actions and providing affirmation of readiness to the ROC.

1.3.7 Restart Manager Responsibility for the management and control ofrestart work activities including the scheduling of activities and coordination of resources.

1.3.8 Site Vice President Overall responsibility for the management and implementation of the restart plan to achieve the purpose described in section 1.1. Serves as chairman of the (SMRT).

1.3.9 Executive Vice President Nuclear Generation Responsible for authorizing startup and power ascension, and providing senior management oversight of the restart process.

1.3.10 Plant Performance Assurance Responsible to discharge performance assurance responsibilities under 10 CFR 50, Appendix B, to provide assurance that activities affecting quality are satisfactorily accomplished. See Attachment F for further details.

1.4 Cook Nuclear Plant Restart Process Overview The restart plan consists of the following major activities:

(1) scope determination (2) work performance (3) readiness assessment

(4) startup authorization (5) startup and power ascension Following is a process map and summary of the activities with more detailed information presented in later sections of this document.

f Cook Plant Restart Plan Overview L1 srv Bgheen 15 sERS sa Roc 2.1 Reaw Qeneoer M 41 srNT $ .1 opearoe Perform System Rexxnmed Restart Appmve Restart Work Perform Rnat Review Restart And Power Readiness Reviews Perform Restart Work Reconvnend Restart Work Scope Scope Racer rvnend Startup Operation 12 Ileager Final Review Perform F nctional Area Readeess Reviews 12 nanoyoo Perform Progranmatic Rearfeess Reviews 1A ovRers~

Perform Containment Readiness Review

The'objective of the restart readiness assessment is to ensure that the integrated set of plant equipment, human resources and work programs are capable of supporting safe and reliable 1.1 Sys Engineers power operations. The restart readiness assessment will be initiated in parallel with the execution and completion of restart Perform System work.

'eadiness Reviews The restart readiness assessment will focus on the following 1.2 ~

Managers Perform Functional ~ plant system readiness Area Readiness ~ functional area readiness Reviews ~ programmatic readiness

~ containment readiness 1.3 . Managers Perform Programmatic Readiness Reviews 1.4 Dir Plant Engineering Perform Containment Readiness Reviews 1.5 SERB The restart work scope may be increased as a result of the plant system assessments or other ongoing work. The system Recommend Restart engineers willrecommend the restart work scope to the System Work Scope Engineer Review Board (SERB).

1.6 All restart scope additions will be approved by the Restart

'OC'pprove Oversight Committee (ROC).

Restart Work Scope 2.1 Restart Manager Following determination of the restart work scope by the ROC, the restart manager is responsible for coordinating the planning, Perform Restart Work scheduling and completion of the work.

3.1 ROC,PNSRC Results of the restart assessment will be presented to the Restart Oversight. Committee (ROC) with an af5rmation by the Perform Final Review responsible system engineer or engineering manager, and the Recommend Startup functional area superintendent of the readiness of the system'r organization to support plant startup and safe, reliable power operations.

4.1 SMRT Following presentation and acceptance of the assessment results by the ROC, the Site Vice President will convene the SMRT to perform an integrated review of the affirmations, verify Recommend Restart compliance with regulatory commitments and any other special criteria that may impact the initiation of startup activities.

4.2 Exec Vice Pres Based on the results ofthis review, the Executive Vice President Nuclear Generation willauthorize startup and power ascension.

Authorize Restart 5.1 OPS Startup and power ascension following the completion of startup work willfollow a deliberate and controlled approach that ensures Startup and Power operational and personnel safety. The normal startup process Ascension defined in Cook Nuclear Plant procedures willbe supplemented with appropriate management oversight and support &om engineering and maintenance organization such that issues or concerns are promptly addressed and the startup can be accomplished in a safe, controlled manner.

0 2.0 Restart Work Scope Determination 2.1 Restart Work Scope Determination Process The restart work scope is being defined through a determination process driven by the ROC consistent with their charter. Outstanding work items and selected progranunatic issues are reviewed against defined criteria to determine which items should be included in the restart scope. System engineers have the largest role in this process, but there is also considerable involvement from other organizations including operations, design engineering, and maintenance. The restart work scope determination process is outlined in attachment E..

2.2 Plant System Review Plant systems are reviewed by the system engineer using the plant system review instructions with results and recommendations presented to the ROC.

The plant system review process consists of four primly elements as described below.

2.2,1 Selection of Plant Systems Plant systems have been selected for a detailed review and affirmation based on the historical performance and risk significance of the system.

This review willbe performed in accordance with the plant system readiness review instructions. Results of the assessment of selected systems willbe presented first to the SERB and, upon approval, to the ROC with appropriate recommendations for additional actions'o be performed after restart. The systems are listed in attachment D.

The remaining systems willbe assessed and evaluated as part of the line responsibility of the engineering organization through the use of the SERB.

Issues that affect restart scope on these systems willbe presented to the ROC on a case basis.

2.2.2 Restart Work Scope Additions The restart work scope addition for plant systems is focused on those items not already included in the restart work scope. Items already scheduled for completion prior to restart are not evaluated against the criteria provided in attachment C unless there is a proposal to delete them. The goal of the system review and work scope addition process is to define'the work necessary for completion prior to restart such that the system is capable of supporting safe and reliable power operation. This review will include the following:

10

(a) the magnitude, significance and risk of items which willbe resolved aAer restart should be defined and evaluated; assurance that recurring problems on the system that could affect safe and reliable operations are being fixed; (c) assurance that any design basis and licensing issues on the system are being addressed within a time frame that is appropriate for the issue; and assurance that operators willnot be unnecessarily challenged in the operation of the system during normal, abnormal, or emergency conditions.

Based on the review of open work items against the criteria presented in attachment C, the system engineer is to provide recommendations for the restart scope changes for the selected systems in attachment D to the SERB and upon approval to the ROC. Items recommended for addition to the restart scope for remaining plant systems willbe handled on an item specific basis by the ROC following an initial review by line management.

It should be noted that. it was not the intent of this program to resolve all design basis issues. We are committed to a long range program to accomplish this resolution.

2.2.3 Monitoring Restart Work, Addressing Emergent Issues and Performing a More Detailed Assessment of System Readiness System engineering is to monitor the progress of work on assigned system and address emergent issues as required. Any major restart scope impacts defined by emergent issues should be brought to the ROC following line management review. Allother emergent issues are assessed daily by the engineering managers.

Also, the system engineer is to use this period to complete the assessment and evaluation of system readiness in preparation for the final system readiness review and affirmation of readiness for restart.

2.2.4 Final System Readiness Review and Affirmation This aspect of the system readiness review process is summarized in section 4.1. Although it is not expected that any significant restart work scope issues willbe identified during this final review, ifany are identified, they are to be brought to the immediate attention of the ROC (following line management review).

11

2.3 Redefined Restart Work Scope The restart work scope may be redefined based on the evaluation process described above. Decisions made by, the ROC regarding the restart work scope are documented in meeting minutes and work item status is tracked.

3.0 Restart Work Scope Performance 3.1 Work Scope Performance Following determination of the restart work scope by the ROC, the restart manager is responsible for coordinating the planning, scheduling and completion of the work, including the implementation ofprograinmatic changes. The restart work scope performance process is outlined in attachment E.

4.0 Restart Readiness Assessment

'he restart ieadiness assessment is an integrated line management assessment that assists station management in determining the readiness to initiate startup and achieve safe, reliable power operation through the next operating cycle. The restart readiness assessment process is outlined in attachment E, This form of assessment is one element of a comprehensive plant assessment program that is the foundation of our continuous improvement philosophy. Implementation of this action is consistent with the experience and lessons learned of other nuclear utilities. The restart readiness assessment is being implemented at Cook Nuclear Plant based on lessons learned and willbe captured such that this process can be implemented on a routine basis in the future.

The restart readiness assessment for restart willverify the completion of all defined restart work and the affirmation of system, department and restart readiness for startup and power operations. Results of the assessment and afBrmation of readiness willbe presented to the ROC by the responsible system engineer, functional area manager and operations shift supervisor. - Following acceptance by the ROC, the site vice president will convene an SMRT meeting to review these affirmations and verify compliance with regulatory commitments and any other applicable criteria. The site vice president will recommend start up of the units based on this review, and assurance regarding the readiness of the station to initiate startup and safely, reliably operate through the next operating cycle.

Following is a summary of the key elements of the program.

4.1 System Readiness System readiness affirmations by the system engineer are to confirm that plant systems meet functional design requirements, have been suitably tested and are ready to support safe and reliable startup and operation through the next cycle. This afIirmation is based on the work completed as described in section 2.2, and is to 12

include a coordinated system walkdown of the system with operations and maintenance personnel on systems defined by the plant engineering manager.

Where necessary, compensatory actions for rescheduled work or other areas of performance risk are to be defined and addressed.

System readiness affirmations are to be presented by the system engineer to the SERB and upon its approval to the ROC for the systems identified in attachment D.

Affirmation of system readiness is documented with the signature of the system engineer and manager. Affirmation of individual system readiness for the remaining plant systems willbe addressed as part of the system engineering line management responsibility and willbe one element of the functional area readiness evaluation.

4.2 Functional Area Readiness r

Functional area readiness by selected functional areas is an affirmation that the department is in an appropriate state of readiness to support startup and safe and reliable power operation through the next cycle. Functional area readiness will include items such as:

(a) adequacy of staffing levels, personnel experience and qualifications to demonstrate compliance with regulatory requirements and commitments; completion of personnel training on normal startup evaluations, power ascension requirements, industry operating experience including extended shutdown and unusual events at similar plants, emergency preparedness, changes in plant configuration, changes in plant operating and emergency procedures, and changes in key adininistrative procedures and processes; (c) resolution of significant performance deficiencies and reduction of backlogs (corrective action, corrective maintenance etc. ) to manageable levels; and (d) establishment of goals and priorities for the continued improvement of the department including use of critical assessment methods.

Functional Area readiness willbe affirmed to the ROC by the following functional

~ operations outage management

~ maintenance licensing plant engineering fuels design engineering ~ plant protection

~ production engineering information management chemistry plant performance assurance radiation protection Affirmation of functional area readiness is documented with the signature of the functional area manager.

13

4.3 Programmatic Readiness Programmatic readiness review willconfirm that programs are in place to support identification and correction of problems. Programmatic issues identified during the unit shutdown have been evaluated and necessary corrective or preventive actions have been completed. Programs in place at the time of unit start-up will ensure that the plant willbe operated in conformance with its design bases and in accordance with the AEP quality assurance program.

A/E programmatic issues potential bypass of 50.59 safety evaluations 50.59 safety evaluation quality corrective action program improvements surveillance program assessment 4.4 Containment Readiness The containment readiness review will focus on the ability of the containment system to meet the intended functional design requirements. The critical points of the review will focus on the system materiel condition, adequate surveillance testing, and the system configuration control, 5.0 Restart Authorization The restart authorization process is outlined in attachment E.

5.1 Restart Oversight Committee (ROC) Review and Approval The ROC willreview and accept the assessment affirmations in 4.1, 4.2, 4.3 and 4.4. A restart recommendation willbe made to the SMRT based on the results of the functional area assessments.

5.2 Senior Manager Review Team (SMRT) Review and Approval Upon review and acceptance of the assessment affirmations in 4.1, 4.2, 4.3 and 4.4 by the ROC, the site vice president willconvene an SMRT meeting to perform an integrated review and approval.

5.3 Executive Vice President Restart Authorization Based on this review the executive vice president nuclear generation willprovide-the authorization for restart and power ascension.

14

6.0 Startup and Power Ascension Startup and power ascension, following the completion of the restart work willfollow a deliberate and controlled approach that ensures operational and personnel safety. The normal startup management team willbe augmented with a shift plant manager and shift engineering manager such that issues or concerns are promptly addressed and the status can be accomplished in a safe, controlled manner. The startup and power ascension actions summarized in this section do not change or alter any requirements of the startup procedures defined above.

6.1 Management Oversight and Organizational Support The Cook Nuclear Plant management structure willbe supplemented with a shift plant manager and shift engineering manager to compliment the shift maintenance manager during the startup and power ascension phase. The responsibilities of these positions are as follows:

6.1.1 Shift Plant Manager The shift plant manager provides on-shift (24-hour) presence as a direct representative of the plant manager and is responsible for maintaining an overall perspective of the startup process. Ifnecessary, the shift plant manager is authorized to request operations to delay the startup, reduce power, or shutdown to make necessary repairs.

6.1.2 Shift Engineering Manager The shift engineering manager provides on-shift (24-hour) presence as a direct representative of the plant engineering manager and is responsible for maintaining an overall perspective of engineering support of the startup process. The shift engineering manager willcontrol on-shift engineering resources as necessary to support scheduled startup testing activities, resolve emergent operability issues, support maintenance and manage necessary reactor engineering test activities.

6.1.3 Shift Maintenance Manager The shift maintenance manager provides on-shift (24-hour) presence as a direct representative of the maintenance manager and is responsible for maintaining an overall perspective of maintenance support of the startup process. The shift maintenance manager willcontrol on-shift maintenance resources as necessary to support scheduled startup testing activities, resolve emergent equipment issues, and support operations.

15

0 This organization willbe implemented as directed by the plant manager at critical evolutions during startup such as change to mode 4, initial criticality, turbine roll, and parallel to grid. The organization willbe disbanded as directed by the plant manager but not before mode 4 to 30% power.

6.2 Operating Proficiency and Experience Review To minimize the potential for performance errors during the plant startup, the following actions willbe taken:

~ operations personnel willutilize the simulator to practice the startup evolution and ensure understanding and proficiency with applicable startup procedures and special requirements; a review of past Cook Nuclear Plant startup issues relevant industry operating experience willbe performed during the functional area reviews to ensure understanding of past experience and lessons learned; department communication meetings willbe conducted with each plant department to discuss management expectations regarding the startup and power ascension processes, schedule, and responsibilities. These

~

meetings willbe completed prior to initiating the startup evolution.

16

ATTACHMENTA PURPOSE: Perform a system-based, multi-disciplinary technical review of potential restart issues associated with risk significant plant equipment. This board will ensure consistent application of the restart criteria contained in Attachment C of the Cook Nuclear Plant Restart Plan among system engineers, and ensure that restart decisions reflect the shared concerns of Operations, Maintenance and Engineering. The result of this review will be to define the equipment related work which is needed to ensure a safe and event free startup and achieve a reliable post startup operating cycle.

MEMBERS:

Director Plant Engineering (Chair)

Mechanical Component Manager Electrical System Manager.

Safety and Analysis Manager I&C Manager Performance Testing Manager Preventive Maintenance Manager Board Secretary Non-Member: Additional attendance by members of Restart Oversight Committee is expected to reinforce expectations and provide oversight for the restart Issue review process.

Alternate chair: Site Engineering Managers Alternate safety and analysis manager: Engineers in the Safety and Analysis Section, subject to acceptance of the SERB chair or alternate chair.

QUORUM: Chair (or alternate), two Onsite Managers, Safety and Analysis Manager (or alternate), and Secretary.

17

0 ACTIONS:

Review all potential restart items identified by System Engineers based on criteria defined in the restart plan; the System Engineer willpresent the proposed restart items for discussion. A representative of Operations and Maintenance knowledgeable of the system's restart issues will support the system engineer and ensure the perspective of the other production groups is considered. The Operations representative will normally be an SS or a US of the Operations crew responsible for the system, but can be an SS assigned to the%ork Control Center.

Designate systems that are required to be presented to the SERB by system engineer, Maintenance and Operations.

3. The SERB willreview all items identified as potential restart issues by the system engineer system readiness review. The system engineer, Operations or Maintenance representatives willalso identify other issues which are not identified as potential restMt issues but may be questioned.

A complete list of open issues on each system willbe available during SERB meetings. The SERB willreview and question additional items as desired to determine ifthey should be restart issues.

5. Ensure a record of all decisions and concerns raised by the SERB review is documented for futtue review.
6. As a iesult of the review, recommend specific potential restart items for approval by the ROC.

Review and approve the charter and any revisions needed to support the restart plan. Disband this board after startup when directed by the Site Vice President.

D. R. Hafer Director of Plant Hnginccting 18

ATTACHMENTB PURPOSE: Exercise management oversight and approval of physical and programmatic work scope necessary to ensure a safe and uneventful unit startup, and achieve a reliable operating cycle.

Position Alternate Plant Manager, Chair Doug Cooper Bob Gillespie Operations Superintendent Vice Chair Bob Gillespie Guy Tollas Production Engineering Director Ken Baker Alberto Verteramo Plant Engineering Director Don Hafer Mike Finissi Maintenance Superintendent John Boesch Mark Stark Licensing Manager Mark Ackerman Gordon Arent Chemistry Superintendent Dave Morey Bob Claes Radiation Protection Superintendent Doug Noble Paul Holland Training Superintendent Dennis Loope Dennis Willemin Restart Manager John Stubblefield Dick Strasser Restart Plan Project Manager* Phil Gora Secretary* Betty Clark Sandy McClintock

  • Indicates non-voting members QUORUM: Chairperson or vice chairperson, and three (3) additional voting members, two of which must be primary members. Attendance &om Performance Assurance and Business Performance is strongly encouraged to perform an active oversight role.

ACTIONS:

Set and communicate expectations for the organization to evaluate work items against the restart scope criteria.

2. Ensure screening criteria are consistently applied via the restart oversight committee review, meeting and approval process.

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4 I

Some items that meet one or more of the criteria maybe deferred until after restart ifthere is special consideration that provides the basis for this decision. Examples may include items that are only a concern during certain seasons, reduced risk of performing the work during a system outage, or implementation ofadequate compensatory actions until a long-term solution is defined. A clear basis for deferral of these items is to be provided.

3. Review and approve:

A. Restart action items to be completed prior to star{up.

B. Station readiness to initiate until startup and power ascension as determined by the results of the assessment of readiness to startup,

4. Maintain arecotd ofpresentations, discussions, deliberations and basis for decisions and recommendations.

5, Review charter as necessary to accommodate changing conditions.

Convene as necessary to accomplish this charter prior to and during starship.

Disband after unit startup when directed by the site vice president..

Site Vice dent Date 20

ATTACHMENTC .

To be included in the plant restart work scope, items must meet the following criteria:

1. Level 1 Screening Resolves an immediate industrial or nuclear safety, operability or regulatory issue. These issues willbe mandatory restart items.
1. Necessaiy to address the voluntary shutdown for the A/E inspection and related programmatic issues.

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2. Necessary to address the confirmatory action letter.
3. Required to return an INOPERABLE system, subsystem or component to OPERABLE status.
4. Required to resolve an immediate industrial or nuclear safety concern.
5. Necessary to address regulatory commitments.
2. Level 2 Screening Not an immediate industrial or nuclear safety, operability or regulatory issue. These issues will be considered for addition to the restart item list based on the review and recommendations of plant engineering, operations, and maintenance ifthe action:

1 ~ Eliminates an existing component failure, deficiency, or condition that could result in operation in, or entry to, an LCO action statement.

'2. Resolves existing deficiencies or conditions that:

a. would result in failure or inability to perform a required surveillance test during the current outage or the following operating cycle in accordance with the plant technical specifications;
b. would increase the risk to operation for safety associated with performing a surveillance; or
c. would result in the failure to meet a license requirement or a restart commitment to an outside agency.

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3. Restores degraded critical components or conditions that could result in a plant transient, power reduction or shutdown.
4. Resolves conditions that have resulted in repetitive safety system or equipment failures.
5. Restores hcensing basis deficiencies to conforming conditions (extended programmatic reviews and scheduled coirective actions maybe completed post-restart with the proper justification of no safety impact, a satisfactory OPERABILITY determination, and appropriate regulatory communication).
6. Corrects equipment with design basis deficiencies; i.L, deficiencies in safety-related or technical specification equipment not in conformance with design basis documents such as the FSAR(extended programmatic reviews and scheduled comctive actions may be completed post-restart with justification of no safety impact, a satisfactory OPERABILITYdetermination and appropriate regulatory communication).
7. Corrects deficiencies in configuration management programs, processes, engineering analysis codes, or operating, maintenance, or test procedures that have a reasonable probability of affecting equipment OPERABILITY (documentation deficiencies, which have no safety impact, may be completed post-restart).

8, Eliminates conditions that create a potential for peieonnel radiation exposure, radioactivity release, or efHuent discharge in excess of limits.

9. Reduces aunulative deficiencies, backlogs or conditions that, in the aggri~te, are evaluated to have significant negative impact on safety, operability or reliable plant operation. (Not applicable to individual work items).

Ap paved:

Site ident 22

23 ATTACHhgNTD .

120 Vac/CRID Inverters AirRecirculation/Hydrogen Skimmer Auxiliary Feedwater 250 Vdc Station Batteries Component Cooling Water Containment Containment Spray Control Air ECCS Accumulators ECCS Charging Modes 1, 2, 3/CVCS High-head Injection ECCS RHR ECCS SI Electrical Safety Busses (4000 V/600 V)

Emergency Diesel Generators Essential Service Water Ice Condenser Main Steam Non-essential Service Water Plant AirCompressors Reactor Coolant System/RCS Pressure Relief Reactor Protection System/Solid-state Protection/ESFAS 24

ATTACHMENTE Restart Process Map (1) Restart Work Scope Determination 1.1 Beni Engheenrc 1.3 SYS ENO ~ OPS, Mr Select Plant Systems Approve Plant System Perform System Addithnal Work Sco Perform Readiness For Review For Review Reviews Required? Assessment

) sadness Assessmara 1 YES 1.2 ROC 1.5 SERB Validate Existing Resta SERB Review And Work Scope Approval Approve Restart Work Scope Additions Approved Restart Scope Additions 1.7 SYS ENGR Monitor Work, Address Emergent Perform Work Scop Issues Approved Restart Work Scope (2 )Restart Work Scope Performance 2.1 Mr, IS 2.3 Al Oqy Plan Restart Work Perform Readiness Schedule Restart Wo Conduct Restart Work Assessment I3I eenness Assessnenl 3.1 25

ATTACHMENTE Restart Process Map (3) Readiness Assessment 3.1 Sye Eny'neer sa SERB Affirm Plant System SERB Confirms Readiness Readiness Plant System Ready?

SERB no Restart Work Scope Determination 1 oeienlIoeen 1A Yes 3A Menegea Affirm Functional Area Readiness Functional Areas Ready Yes no Restart Work Scope Determination S.la Mender 1 oeienneieeen 1A Compliie And Present Results Restart Authorization S.e u ORBS 4 eeien ALerertzeiion AA AffirmProgrammatic Readiness Programs Ready? Yes no Yes Restart Work Scope Determination 1 oeienTwLteen 1A AffirmContainment Readiness Containment Ready?

no Restart Work Scope Determination 26 Oe~ 1A

ATTACHMENTE Restart Process Map ATTACHMENTE Restart Process Map

{4) Restart Authorization {5) Power Operation 4.1 ROC 42 ROC, PNSRC 4A Exec Vlcc Presa% 5.1 OexeSNN Perform Final Readines Perform Final Review Recommend Restart Authorize Restart Start up and Power Review Recommend Startup Ascension 27

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ATTACHMENTF Perfo ance Assurance Oversight of Restart Performance Assurance Oversight of Restart The purpose of this oversight effort is to discharge Performance Assurance responsibilities, under 10 CFR 50, Appendix B, to provide assurance that activities afffecting quality are satisfactorily accomplished. This oversight will include providing independent feedback to line management concerning the adequacy of the restart plan and how effective the plan is being implemented. To enhance independence, personnel conducting this oversight will include those who have not been involved with the evolution ofpractices and lessons learned as the Restart Plan has been implemented.

Critical activities were identified &om the restart plan. Critical attributes of these activities were identified and scheduled for oversight as follows:

List of Critical Activities System Readiness Reviews Functional Area Reviews Programmatic Reviews Containment Readiness Reviews Determination of Restart Work Scope Restart Work SERB ROC Integration of Reviews Startup and Power Ascension Critical Attributes of Critical Activities System Readiness Reviews Are the right systems being reviewed?

Are the right methods being used to conduct the reviews?

Are the reviews effective?

Functional Area Reviews Are the right areas being reviewed?

Are the right methods being used to conduct the reviews?

Are the reviews effectlve2 Programmatic Reviews Are the right programs being reviewed?

Are the right methods being used to conduct the reviews?

Are the reviews effective2 Containment Readiness Reviews Is the right scope being reviewed2 Are the right methods being used to conduct the reviews?

Are the reviews effective2 Determination of Restart Work Scope Is the right criteria being used to determine restart work scope?

Are there any hidden inventories of items that are not being considered?

Review work not included in restart?

Adherence to Criteria Expert Judgement 28

ATTACHMZYI' Perf ce Assurance Oversight of Restart Restart Work Is restart work being performed to proper standards?

Engineering Maintenance Operations Other SERB Is the charter adequate?

Is the SERB effectively carrying out the charter2 ROC Is the charter adequate?

Is the ROC effectively carrying out the charter2 Integration of Reviews Is the method of integrating reviews adequate?

Plant Equipment Human Resources Work Programs Startup and Power Ascension Is it adequately Planned2 Is it adequately Scheduled?

Is is adequately Performed (Onshift Observations)?

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Revision Block Restart Plan Revisions Revision Description Date Number Page 26: New page. Added Revision Block Page 8 "Authorize Restart": Deleted Executive Vice President Nuclear 4/7/98 Engineering. Added Executive Vice President Nuclear Generation.

Pages 20 and 21: Added reference numbers to restart criteria.

Sect 1.3.5: Added Director Regulatory Affairs to SMRT Attachment A: Added Preventive Maintenance Manager to SERB charter Sect 1.3.10: Added Plant Performance Assurance responsibilities Added Attachment F, Performance Assurance Oversight Of Restart Index: Added Attachment F Attachment C: Added "operability or regulatory" to level 1 screening.

Added 5. Necessary to address regulatory commitments. Added "regulatory" to level 2 screening.

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