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Text

Rev 5 to PMP 7200.RST.004, Expanded Sys Readiness Review Program.
	ML17325B589
Person / Time
Site:	Cook
Issue date:	05/07/1999
From:	Finissi M, Larson R; INDIANA MICHIGAN POWER CO.
To:	;
Shared Package
ML17325B588	List: ML17325B587; ML17325B589; ML17325B590;
References
	PMP-7200.RST., PMP-7200.RST.00, NUDOCS 9905170136
	Download: ML17325B589 (140)
	v • d • e

PMP 7200.RST.004 Rev.S Page 1 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Information Effective Date:

Robert E. Larson Michael Finissi NE nter wner ogtuzant rgantzatton TABLE OF CONTENTS 1 PURPOSE AND SCOPE o~ esses ~ esse ~~~~~~ oo ~~~~~~~~~~ ooooooo ~ ~ so 3 2 DEFIMTIONS AND ABBREVIATIONS................ I~ ~ 06 3 RESPONSIBILITIES o~~ oo ~~~~~ oooo ~ oo ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ooooooo. ~o ~

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~~ ~ .10 4 DETAILS- ~~~ oo ~~~~ ooooe ~~ oeooo ~~ ooooooooo ~ ~ ~ ~ ~ ~ ~ ~ oo ~ ~ oooo ~ ~ eooo ~ ~ ooooooo ~~~~ eoo ~~ ~~ ooooooeooo-13 4.1 Scope And Selection Of Systems For Expanded System Readiness Review ...'...... 13 4.2 Use Of The System Assessment Matrix, SIDS, And The Assessment Data Base.... 14 4.3 Phase 1 Initial Expanded System Readiness Review...........~..................... 16 4.4 Phase 2 Restart Activities Monitoring.......... ........................... 27 4.5 Phase 3 Final Expanded System Readiness Review...................... 32 4.6 Phase 4 Startup And Power A.,ensiOn.................'.............................. 37 47

~ Reports......,...,........~..........,... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 41 5 FINAL CONDITIONS e oo soooooeooo~ooooooee oo~eoo~~~~oe ~~ oooo ~~~ooeooooooeoooooooooooooooooooeoooo~ 42 6 REFERENCES ~~oooooooooooooo~oooooo~~~~ooeooooooo~ooooooooeooooooo~~~~oooeoooo~eooooooo~oo~~~oo~ 42 ATTACHMENT1 SYSTEM READINESS REVIEW BOARD (SRRB) CHARTER.. 44 ATTACHMENT2 21 LEVEL 1 SYSTEMS INCLUDED IN THE PREVIOUS SYSTEM RE ADINESS~RE~VIEW esses'oooooeooooooooooooooooooo ~ ~ eoooooooooooooeoooooo ooooooooo 46 ~ ~~

ATTACHMENT3 RATIONALEFOR SELECTION LEVEL 1 SYSTEMS FOR EXPANDED RE ADINESS REVIEW oo ooeooooooeoo so eoo sooooosoooooeooooooooooooooooeo.

~ ~ ~~ ~~~ ~~~ oo ~~~o 48 ATTACHMENT4 EXPANDED SYSTEM READINESS REVIEW LEVEL 1 SYSTEMS

~ ooooooe ~ oooo ~ oooo ~ ~ osooo ~ ooooooooooo ~ ooooooooeooeooosoo ~~~ oooooooe ~~ ooooe ~ ooooo ~~~~~~o 49 ATTACHMENT5 EXPANDED SYSTEM READINESS REVIEW TRAINING RE QUIREMENTS ooo oooooooooooooeoooo ooeoeoooooooo ooooooeeoooooooooooooooooo os oo

~ ~ ~ ~ ~ ~ ooo 51 ATTACHMENT6 SYSTEM'READINESS REVIEW DOCUMENTATIONAND DATA S OURCESoooooo ~ ooooooosoeooooooooooooeeoooooooooeoooooooooooooooooooe ~ eooooooooooooeo ~~ esses 52 9905170136 9q0507 PDR ADOCK 050003i5 f P PDR

Information PMP 7200.RST.004 Rev. 5 Page 2 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM ATTACHMENT7 SYSTEM READINESS REVIEW PROGRAM (SYSTEM WALKDOWN G UIDELINES) o ~ ~ ~ ~ oo ~ ~ oo ~ oeoooooooo ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ oo ~ ~ oo ~ ~ ~ ~ ~ ~~~~~ ~~~~~~~~~~~~~~~~~ o 54 ATTACHMENT8 CRITERIA FOR WORK INCLUDED IN RESTART SCOPE.... 62 ATTACHMENT9 PHASE 2 OUTAGE SCOPE APPROVAL PROCESS............... 69 ATTACHMENT10 RESTART REQUIRED SCOPE DEFERRAL FORM............. 70 ATTACHMENT 11 EXPANDED SYSTEM READINESS REVIEW CLARIFICATION S HEET ~~~~~~~~~~~~~o~~~~~~ oe ~~~~~~~ oo ~ eo ~ oo ~~~o~~~~ ~~ ~~ ~~~~~~~e ~~o~e~~~~~~~~~~~~ ~~ ~~ ~~ ~~ ~~ 71 ATTACHMENT 12 INITIALEXPANDED SYSTEM READINESS REVIEW REPORT

~~ e e~e e~~e ~~~e ~oe e o~e ~o~~e~~~~o~e ~o~e~e ~o~o~e ~e ~~e ~~~~e~~ e ~~~~o~e ~oo~~o~~~~e ~e ~e ~~~~ 72 ATTACHMENT13 FINAL EXPANDED SYSTEM READINESS REVIEW REPORT

~~ oooooo ~ eoooo ~ oooooooo ~~~ oo ~~~ oooooooooooo ~ ~ oo ~ eo ~ ~ ~ ~ ~ ~ ~ ~ ~ ooooooo ~ ooeoo ~~~~ oooooo ~~ 75 ATTACHMENT14 EXPANDED SYSTEM READINESS REVIEWS INTEGRATED RES ULTS oooooooeooooo oo ooooooooooooooooeooooooooooooooooo

~ ~ ~ ~ oo ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ oooooo ~ ~ ~ ooooo oo

~ ~~ 78 ATTACHMENT15 SYSTEM WALKDOWNREPORT ..................................... 83 ATTACHMENT 16 SYSTEM READINESS AFFIRMATIONREPORT ................ 84 FIGURE 1 SYSTEM ASSESSMENT MATRIXMAJOR TOPICS ........................ 85 FIGURE 2 SYSTEM ASSESSMENT MATRIXEXA'MPLE - AUXILIARYFEEDWATER S YSTEM ~ ~ ~ ~ oooooo ~ ~ ~ ~ ~ ~ ~ ~ ~ oooooo ~ ~ oo ~ ~ ooee ~ ~ oooo ~ oooo ~ oo ~ ~ oooooooooo ~ ~ oooo ooo oo

~ ~ ~~~~~~~~ oo 95 FIGURE 3 READINESS REVIEW ATTRIBUTE ASSESSMENT FORM..............100 FIGURE 4 SAMPLE COMPLETED READINESS REVIEW ATTRIBUTE ASSESSMENT

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Information PMP 7200.RST.004 Rev. 5 Page 3 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 1 PURPOSE AND SCOPE [Ref. 6.8]

1.1 The purpose of this document is to define the Expanded System Readiness Review (ESRR) Program and provide guidance in evaluating and determining system restart readiness for the Cook plant. This document also describes the process for scoping work items as either required or not required to support unit restart. These guidelines support startup from the current extended outage in support of Reference 6.1.

1.2 Several independent reviews, including a self assessment of the Auxiliary Feedwater

'ystem and an independent Engineering Issues Review Group report identified vulnerabilities in the preservation of the Design and Licensing Basis that suggested a need for a more rigorous review of overall system readiness, 1.3 The ESRR will provide reasonable assurance that:

~ the plant systems are capable of meeting their safety and accident mitigation functions as defined in their design and licensing bases [Ref. 6.11], and

~ in conjunction with other ongoing improvement programs and resolution of identified issues, that the plant is modified, tested, operated and maintained consistent with the design and licensing bases. [Ref. 6.12]

1.4 The Expanded System Readiness Review consists of four phases Phase 1: Initial Expanded System Readiness Review Phase 2: Restart Activities Monitoring Phase 3: Final Expanded System Readiness Review Phase 4: Startup and Power Ascension 1.4.1 Phase 1 is to include the following:

a. Formation and training of system teams for readiness review using representatives from various station departments.

b. A review of system design and license basis documentation.

c. Review of safety and accident mitigation functions for each system.

d. Verification, in conjunction with other ongoing improvement programs and resolution of identified issues, that the plant is modified, tested, operated and maintained consistent with the design and licensing bases.

Information PMP 7200.RST.004 . Rev. 5 Page 4 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM

e. Evaluation of the extent of condition for identified problems and identification of potential programmatic or generic issues.

Performance of multi-disciplined system walkdowns.

Evaluation of open items in the System Indexed DataBase System (SIDS) (see definitions) against the Restart Screening Criteria.

NOTE: The Plant Nuclear Safety Review Committee (PNSRC) is making a transition to be known as Plant Operations Review Committee (PORC). This document uses the acronym, PORC, but documents such as the UFSAR and Technical Specifications may use PNSRC that represents the same group.

h. Presentation of the Initial Expanded System Readiness Review Report 'o the System Readiness Review Board (SRRB) and the Plant Operations Review Committee (PORC).

/

Begin scheduling restart work in the Restart Schedule.

1.4.2 Phase 2 is to include the following:

ao Continued review of open corrective action items through closure.

b. Continued evaluation of emergent action items for unit restart against the Restart Screening Criteria.

C. Scheduling of restart work into the appropriate System Work Window.

d. Monitoring of field. work, including presence at the job site, when appropriate.

e. Development of System Test Plans.

Preparation for System Window closure and the Final Expanded System Readiness Reviews.

g. Completion of regularly scheduled walkdowns by the System Manager (See definitions).

h. Management of work closure through use of performance indicators and priorities.

Update of the SIDS data base, as the System Manager evaluates emergent and open items.

Information PMP 7200.RST.004 Rev. 5 Page 5 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 1.4.3 Phase 3 is to include the following:

a... Final System Readiness Walkdown completed by the System Manager and an assigned Operations representative.

b. Presentation of the Final System Readiness Report, prior to restart, to the SRRB and PORC by the assigned operations representative and the System Manager.

c. Review work that is not complete prior to restart and review the aggregate impact of deferred work.

d. Finalize the System Test Plans.

e. System Manager will develop performance monitoring baseline for system performance tracking and trending 1.4A Phase 4 is to include the following:

a. Designated test results identified by the Test Review Board (TRB).

b. System Manager will implement performance monitoring baseline for system performance tracking and trending.

c. System Manager will monitor any new corrective maintenance activities or condition reports, and continuously monitor system readiness.

d. Completion of System Readiness Affirmation.

Information PMP 7200.RST.004 Rev. 5 Page 6 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 2 DEFINITIONS AND ABBREVIATIONS Term Meaning System Assessment Matrix The matrix consists of attributes (rows) and topic review areas (columns) that define the scope of the work and when completed provides the summary basis of the conclusions of the Expanded System Readiness Review. Figure 1 provides the Assessment Matrix Form. Figure 2 provides a sample completed assessment matrix.

Attribute Key system parameters, including system safety and accident mitigation functions, that will be evaluated against various topic review areas. The attributes make up the rows of the matrix and are selected by the Expanded System Readiness Review Teams using guidance provided in Section 4.3.4.

Topic Review Area Consists of documents and sources of information in the following areas: Design, Licensing, Operations, Maintenance, Surveillance, Physical Plant, and Programs, Processes and Procedures. The review areas make up the columns of the assessment matrix. The addendum to Figure 1 provides guidance on the evaluation to be performed for each topic area.

Discrepancy A finding generated as a result of an activity performed in accordance with this procedure which indicates a potential need for corrective action or process improvement. Discrepancies identified during the Expanded System Readiness Review are documented via Condition Reports (CRs) in the Cook Plant Corrective Action Program (CAP) or as Action Requests in the Work Control System (NPM). A Condition Report shall be issued for any item that falls within the scope of the Corrective Action Program.

Generic Issue Discrepancies identified in several systems for the same topic

..review area that potentially identify a process or programmatic problem..

Assessment Data Base The data base used to document Expanded System Readiness Review assessments, confirming consistent use of design and licensing information, and identifying discrepancies.

Information PMP 7200.RST.004 Rev. 5 Page 7 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 2 DEFINITIONS AND ABBREVIATIONS (Continued)

Term Meaning System Indexed Data Base The SIDS data base is used to track open items identified as System required for restart. Open items in this data base include open items from existing plant data sources, and discrepancies identified by the Expanded System Readiness Review. Thus, discrepancies identified during the Expanded System Readiness Review generate entries in the SIDS Database.

Current Licensing Basis The set of NRC information applicable to a specific plant and a licensee's written commitments for ensuring compliance with, and operating within applicable NRC requirements and the plant specific design basis, including all modifications and additions to such commitments over the life of the license, that are docketed and in effect. The CLB includes NRC regulations contained in 10CFR Parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 54, 55, 70, 72, 73, 100 and appendices thereto: Orders, License Conditions, Exemptions, and Technical Specifications (TSs). It also includes the plant specific design basis information defined in 10CFR 50.2 as documented in the most recent UFSAR as required by 10CFR 50.71 and NRC commitments remaining in effect that were made in docketed licensing correspondence such as responses to NRC Bulletins, Generic Letters and enforcement actions, as well as licensee commitments documented in the NRC Safety Evaluations or Licensee Event Reports.

Design Basis Information that identifies the specific functions to be (as Defined by 10CFR 50.2) performed by a structure, system or component of a facility and the specific values or range of values chosen for controlling parameters as reference bounds for design. These

.values may be (1) restraints derived from generally accepted state-of-the-art practices for achieving functional goals or (2) requirements derived from analysis (based on calculations and/or experiments) of the effect of a postulated accident for which a structure, system or component must meet functional goals.

Information PMP 7200.RST.004 Rev. 5 Page 8 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 2 DEFINITIONS AND ABBREVIATIONS (Continued)

Term Meaning Engineering Design Basis The Engineering Design Basis is the entire set of design-restraints that are implemented, including (1) those that are part of the current licensing basis, and (2) those that are not part of the current licensing basis, but are implemented to achieve certain. economies of operation, maintenance, procurement, installation, or construction. (See Reference 6.2 for further clarification, including definitions of Design Basis Document, Design Requirements and Design Output Document).

Vertical Slice Review A structured review approach derived from the Safety System Function Inspection (SSFI) methodology that allows an assessment of specific aspects of the plant physical configuration and operation against selected aspects of the plant licensing and design basis. The scope of the ESRR vertical slice review for each system is defined by the System Assessment Matrix.

Horizontal Slice Review A review of a programmatic issue or plant documents across multiple plant systems, such as a review of the UFSAR, evaluation of Appendix R fire protection requirements, review and upgrade of calculations, etc.

System Readiness Review A board of personnel conducting business in accordance with Board (SRRB) the Charter in Attachment 1.

System Manager The leader of the Expanded System Readiness Review Team and engineering owner of assigned systems for purposes of this procedure.

System Manager Indicates the fact that the System Manager has reviewed the "APPROVE" scope (i.e., the screening of the item as required or not required to support unit restart) of an item in SIDS and the associated comments that justify the item's scope. This "APPROVAL" is denoted in the Initial System Manager Approval box in SIDS and is used by the System Manager during all Phases for new items in SIDS, meaning that the System Manager agrees with the scope and justification.

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Information PMP 7200.RST.004 Rev. 5 Page 9 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 2 DEFINITIONS AND ABBREVIATIONS (Continued)

Term Meaning System Manager During Phases 3 and 4, "CONCURRENCE" is denoted in the "CONCUR" Final System Manager Approval box in SIDS and is used by the System Manager to mean that restart items, or post restart items that are not included in the aggregate impact, have been completed to the satisfaction of the System Manager.

System Manager Indicates that this Restart scoped SIDS item is not complete and "EXCEPT" remains an exception to restart (i.e., completion of the item still needed to enter the mode identified in the mode restraint box in SIDS). This "EXCEPTION" is denoted in the Final System Manager Approval box in SIDS and is used by the System Manager during. Phases 3 and 4.

System Manager "Post Denoted on items associated with a component that has (2) or.

Restart Deferred" more post restart deferred items, excluding PM post restart items.

System Manager "Restart Denoted on items with deferred scope that were initially Required Deferred" approved, as restart required. These items must be accompanied by a Restart Required Scope Deferral Form (Attachment 10).

Information PMP 7200.RST.004 Rev. 5 Page 10 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 3 RESPONSIBILITIES 3.1 The Director of Engineering Restart is responsible for overseeing Engineering preparations for restart, for the ESRR Program and, when needed, for chairing the System Readiness Review Board; ensuring that the requisite members are in attendance.

3.2 The System Readiness Review Manager is responsible for:

3.2.1 Expanded System Readiness Review Program content and oversight.

3.2.2 Determination of the scope of the review for ESRR systems.

3.2.3 Ensuring adequate training and logistics support is provided to participating'eam members j 3.2.4 Reviewing the results of the individual system readiness reviews, identifying any generic. concerns and defining progranunatic corrective action (ifany).

3.2.5 Reviewing the attribute selection and the corresponding Assessment Matrix for each system (Figure 1).

3.2.6 Maintaining and revising this procedure on the Expanded System Readiness Review Program, annotating the changes made, and obtaining appropriate approvals.

3.2.7 Owns and manages the SIDS Database 3.3 The System Engineering Manager is responsible for the assignment of System Managers to systemrbeing reviewed, and for providing additional oversight for the ESRR Program.

3A The System Engineering Supervisors are responsible for supervision and effective implementation of the Expanded System Readiness Review Program through active coaching, counseling and oversight of the System Manager. The System Engineering Supervisors jointly own the ESRR results with the System Managers.

3.5 The Expanded System Readiness Review Program Coordinator is responsible for:

3.5.1 Expanded System Readiness Review program development and implementation.

3.5,2 Schedule and coordination

Information PMP 7200.RST.004 Rev. 5 Page 11 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 3.5.3 Reviewing and recommending for approval the attribute selection and the corresponding Assessment Matrix for each system.

3.5.4 Review the Assessment Data Base to identify generic issues and trends.

3.6 The Assessment Data Base Coordinator is responsible for:

3.6.1 Assuring that the Assessment Data Base is operational and available to the ESRR teams.

3.6.2 Maintaining the data in the Assessment Data Base and providing status.and summary reports regarding the ESRR.

3.7 The SIDS Data Base Coordinator is responsible for:

3.7.1 Assuring that the SIDS Data Base is operational and available to the ESRR.

teams, and to program owners and functional area managers (or designees).

3.7.2 Making any required changes or improvements to the SIDS Data Base.

3.7.3 Ensuring that items required to be scoped are entered into the SIDS Data Base.

3.7.4 Providing and maintaining the quality of SIDS reports.

3.8 System Managers are responsible for:

3.8.1 Overall system health and performance.

3.8.2 Organizing and leading each ESRR Team. The Team will be composed of

'he necessary multi-discipline resources to conduct Phase 1 of the Expanded System Rea'diness Reviews. The System Teams will include the following:

a. System Manager

b. Operations Representative

c. Design Engineering Representative

d. Maintenance Representative.

e. Licensing Representative

f. Outside member(s) with varied industry experience

Information PMP 7200.RST.004 Rev. 5 Page 12 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 3.8.3 Coordinating team requests for system design and licensing basis documentation from the appropriate sources.

3.8.4 Performing Phases 1, 2, and 3, and supporting Phase 4 of the ESRR.

3.8.5 Coordinating preparation of the ESRR Initial and Final Reports, and presenting these reports to the SRRB and PORC.

3.8.6 Assembling ESRR review results and restart action items into the SIDS Database for tracking.

3.8.7 Maintaining a status of restart action items and submitting status updates to plant management as required.

3.8.8 Coordinating and conducting system.walkdowns with appropriate team members.

3.8.9 Organizing and leading each work window team (see Section 4.4.2b.1).

3.9 The Expanded System'Readiness Review Teams are responsible for:

3.9.1 Identifying attributes appropriate to their specific system for assessment.

3.9.2 Selecting topic areas appropriate to the identified attributes.

3.9.3 Performing system attribute checks and walkdowns and documenting the results, including any noted discrepancies, in the assessment data base.

3.9.4 Reviewing items in the SIDS data base and scoping the items as discussed in section 4,3.12.

3.9.5 Entering the deficiencies in the Cook Plant Corrective Action Program and/or Work Control System as appropriate.

3.9.6 Providing assistance to the System Manager as required.

3.10 The Operations Manager is responsible for assigning appropriate Operations representatives to support the ESRR Program.

3.11 The Director of Regulatory Affairs is responsible for assigning appropriate Licensing representatives to support the ESRR Program.

3.12 The Maintenance Manager is responsible for assigning appropriate maintenance representatives to support the ESRR Program.

I, ik.$ g Information PMP 7200.RST.004 Rev. 5 Page 13 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 3.13 The Design Engineering Director is responsible for assigning appropriate Design Engineering representatives to support the ESRR Program.

3.14 The SRRB w'ill perform management oversight and assessment of the Expanded

=-

System Readiness Review Program and will be the final approval authority over work item screening. The SRRB will perform activities applicable to this procedure, including approval of the System Assessment Matrices. The SRRB Charter is included in Attachment l. An expected product of the SRRB oversight is improved consistency and technical depth of the ESRR results.

3.15 The PORC is responsible to provide a cross-discipline oversight of the ESRR Program by reviewing ESRR reports for each system and the Integrated Readiness Review Report.

3.16 The Outage Scope Management Team (OSMT) will review emergent work items following Phase 1 to determine whether or not they are required to support Unit restart.

4 DETAILS 4.1 Scope And Selection Of Systems For Expanded System Readiness Review NOTE: The term "TBDL" when used in this document refers to detail To Be Developed Later and incorporated in a subsequent revision to this document or in other documents.

4.1.1 Previously, a plant System Readiness Review was conducted as discussed in Reference 6.3. A graded approach was used in performing the previous system readiness reviews, with high-risk systems receiving more thorough reviews. The previous system readiness reviews were broken down into three levels-with. the following attributes:

a. Level 1 Systems

.1. Risk-significant Maintenance Rule systems

2. Some important non-risk significant standby maintenance rule systems

b. Level 2 Systems

1. Remaining non-risk significant Maintenance Rule systems

c. Level 3 Systems

Information PMP 7200.RST.004 Rev. 5 Page 14 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM

1. Non-Maintenance Rule systems that support power generation

2. Systems that are required for plant operation, are easily monitored in service, and present little or no challenge to safety 4.1.2 The 21 Level 1 systems included in the previous System Readiness Review are listed in Attachment 2.

4.1.3 Subsequent to the completion of the previous System Readiness Review, several independent reviews were conducted, including a Safety System Functional Inspection (SSFI) of the Auxiliary Feedwater System (Reference 6.4) and an Engineering Issues Review Group final report (Reference 6.5).

These reviews identified vulnerabilities with respect to the scope of systems reviewed during the previous System Readiness Review, additional system design basis and licensing basis issues, and weaknesses in engineering programs and processes.

4.1.4 The classification of Level 1, 2, and 3 systems utilized during the previously performed system readiness reviews were based solely on Maintenance Rule input. The Level 1 systems were Maintenance Rule Risk systems. Level 2 systems were non-risk significant systems, but 'ignificant systems that were still included in the scope of the Maintenance Rule.

Level 3 systems were systems that were not included in the scope of the Maintenance Rule.

4.1.5 The classification of Level 1 and 2 systems utilized during the ESRR Program is based on Maintenance Rule input, systems required for safe shutdown, significant attendant/support systems, and systems identified by the System Engineering Manager that have experienced an abnormal amount of corrective maintenance. The basis for the selection of Level 1 systems is found in Attachment 3.

4.1.6 Expanded System Readiness Reviews under this procedure will be conducted on all of the previous Level 1 systems, plus additional systems that were determined to warrant an Expanded System Readiness Review (Refer to Attachment 4). Expanded System Readiness Reviews for the new Level 2 Systems will be addressed in a separate procedure.

4.2 Use Of The System Assessment Matrix, SIDS, And The Assessment Data Base 4.2.1 The ESRR employs a vertical slice approach derived from the methodology of a Safety System Functional Inspection (SSFI). This approach evaluates system safety important to safe operation and accident mitigation functions (Attributes) against plant configuration and design, licensing, operations and maintenance documents (Topic Areas).

Information PMP 7200.RST.004 Rev. 5 Page 15 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 4.2.2 The scope of the vertical slice review performed on a system is shown in a System Assessment Matrix. The system attributes selected for each system's review form the rows of this matrix, as further discussed in section 4.3.4. The sources of information or topic areas that are included in the vertical slice form the columns of the matrix.

4.2.3 The System Manager, accompanied by the cognizant System Engineering Supervisor, presents a description of the system scope and the system specific Assessment Matrix to the SRRB for approval. This helps the SRRB ascertain that attributes are appropriate.

4.2;4 The requirements associated with each of the attributes are evaluated against specific topic areas or sources of information.

4.2.5 The assessments include comparison,and evaluation of documents as well as observations of plant condition and configuration during system walkdowns.

The ESRR will emphasize those attributes, topic areas and activities necessary to satisfy the program purpose.

4.2.6 The results are documented using Attribute Assessment Forms (Figure 3) in the Assessment Data Base. Discrepancies are entered into the Cook Plant Corrective Action Program and/or Work Control System (NPM).

Assessment Data Base manipulation and reporting capabilities assist in reporting, tracking and identification of generic issues and trends.

4.2.7 By assessing the results for all topic areas across all the systems reviewed, the ESRR can assist in determining the extent of condition of vulnerabilities in plant programs and processes already identified by previous inspections and reviews (e.g., References 6.4 and 6.5). The ESRR will also be used to identify other potential vulnerabilities and the potential need for further improvement in plant processes and programs.

4.2.8 In summary, the ESRRs result in a vertical slice evaluation of selected design and licensing bases for the ESRR systems. These evaluations do not guarantee that future external or internal assessments will not uncover additional problem reviews. However, in conjunction with other ongoing horizontal slice restart programs at Cook Plant and resolution of issues that are recommended for restart, the ESRRs provide reasonable assurance that key systems are capable of meeting their safety and accident mitigation functions as defined in their design and licensing basis.

Information PMP 7200.RST.004 Rev. 5 Page 16 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 4.2.9 The SIDS Data Base is being used to track items being evaluated, scoped and justified as either Restart or Post Restart for both Units. This data base is the central repository for such items. SIDS will generate reports listing Restart and Post Restart items for SRRB and PORC approval. This data base will be managed and controlled by the System Manager for his particular system(s).

4.3 Phase 1 Initial Expanded System Readiness Review 4.3.1 Expanded System Readiness Review Team Formation

a. The System Engineering Manager will assign a System Manager to each of the Expanded System Readiness Review teams.

b. The System Manager will lead the Expanded System Readiness Review'eam comprised of a licensed member from Operations and members ..

from Design Engineering, Maintenance, Licensing, and outside members with strong industry experience; 4.3.2 Training

a. Prior to performing the reviews, training will be conducted for the AEP System Managers and the ESRR Team members on Expanded System Readiness Review Program knowledge and skill needs. These needs are defined- in Attachment 5.

b. The training for the AEP System Managers and the ESRR Teams was determined based on an evaluation of the tasks to be performed and lessons learned form the original System Readiness Reviews, the original System Engineering Review Board, and previously performed engineering and programmatic assessments.

A 4.3.3 Review Design and Licensing Basis Documentation

a. The ESRR Team shall become familiar with the design and licensing basis of the system to gain an understanding of the system functional and safety requirements under normal operating and accident conditions. The design and license basis documentation listed in Attachment 6 will be available to the ESRR Team.

b. Access to the following will be provided to the ESRR Teams.

1. EQ information

2. Appendix R information

Information PMP 7200.RST.004 Rev. 5 Page 17 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM

3. Station Blackout information

4. ISI/IST Program Information 5; Seismic qualification information

6. Electrical design criteria (separation, etc.)

7. Maintenance Rule Program Information

8. Individual Plant Examination (IPE) Results

9. High Energy Line Break Program'Information

10. Generic Letters GL89-13, GL83-28, GL96-01, and responses thereto.

11. Generic Letter GL89-10 program information.

12. Generic Letter GL96-06 information (as available)

13. LER 97-021 and associated single failure commitments

14. 1998 AFW SSFI Report

15. 1998 Containment Spray SSFI Report

16. Engineering Issues Review Group Report (Reference 6.5)

c. The expectation is that the System Manager will review the above information to determine its impact on his system.

d. Licensing will provide the results of a review of licensing commitments on a system basis.

4.3.4 Define System Specific Attributes

a. During the review and evaluation of design and licensing information, each ESRR Team will develop a list of attributes to be included in the assessment on the System Assessment Matrix.

Information PMP 7200.RST.004 Rev. 5 Page 18 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM

b. Attributes will be selected by a thorough review of the design and, licensing basis to identify the system safety and accident mitigation functions. Additional functional requirements of the system and critical components may also be selected. Information from the Licensing Review Program will be considered as will PRA insights on risk significant components and functions. Functionality of attendant/support systems and important passive equipment (e.g.,

tanks, bladders, strainers) will also be considered in selection of system attributes. Generic requirements such as Station Blackout, EQ, Appendix R, etc. will also be selected as system attributes when appropriate. A detailed example of and some requirements for attribute selection and their bases are provided in the Figure 2 addendum.

4.3.5 Establish Scope of Review

a. Each ESRR Team will perform a vertical slice review of its assigned system by evaluating the system and common attributes against specific topic review areas as documented in the system Assessment Matrix.

The topic areas to be assessed for each attribute will be defined in an initial System Assessment Matrix at the start of the ESRR, taking into account the results of previous evaluations at Cook Plant. This initial System Assessment Matrix will be reviewed and recommended by the ESRR Program Coordinator or Manager and the Nuclear Licensing Manager or Director of Regulatory Affairs, and approved by the SRRB. Changes made in response to SRRB comments need not be re-reviewed by the other parties who previously reviewed the matrix.

These reviews and approvals will be based on the matrix and other supporting material as dictated by the board. Typically, this information will consist of:

~ A listing of the system safety and accident mitigation functions

~ The matrix itself, showing the attributes chosen and the topics to be reviewed for each

~ A marked-up system flow diagram or schematic depicting system boundaries

<<u ~ 4 Information PNIP 7200.RST.004 Rev. 5 Page 19 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM

~ A separate word description'of system physical boundaries and functional boundaries. Functional boundaries are those interfaces with other systems or the environment that must be proper in order for the system to function as designed. An example would be a circuit breaker in a non-safety related system that must open to protect a connected safety-related system if the aon-safety related system incurs a fault.

~ A description of the attributes chosen and the sub-attributes of each which the team intends to pursue.

b. The System Assessment Matrix will be used by each ESRR team as a "

guideline to ensure adequate coverage of topic areas and all attributes.

c. Based on the additional knowledge and understanding gained in the course of the review, specifically including the results of the review of licensing commitments, actual coverage of specific topic areas for particular attributes may expand and deviate from the initial matrix, provided that coverage of appropriate topic areas and all attributes is maintained. If ongoing licensing or ESRR'reviews identify the need to add,attributes to the assessment matrix, these additions will be approved by the ESRR Manager or the ESRR Program Coordinator.

Such additions will be communicated in a timely manner between Licensing aad the ESRR Manager. Actual coverage will be documented in the final System Assessment Matrix, which will be reviewed by the ESRR Program Manager or Program Coordinator and will be included in the Initial Expanded System Readiness Review report. "

4.3.6 Review System Condition Documeatation

a. Data sources in SIDS will be reviewed by the ESRR Teams to gain a comprehensive understanding of the current system condition, to assess the system functional requirements for readiness, and to evaluate the conformance of the system condition to its design basis. A specific focus of this effort shall be the identification of fundamental vulnerabilities in the system's ability to perform its safety and accident mitigation functions as defined in the Design and Licensing Basis.

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b. During the review and evaluation of these data sources, the ESRR team may develop additional specific requirements to be checked. For

. example, if a previously conducted assessment identified a discrepancy between a component capability and a design requirement, this design requirement would be a candidate for investigation and the satisfactory closure of the previously identified discrepancy would be assessed as part of the ESRR. The same strategy may be applied to assess the satisfactory closure of open items that were identified when the Design Basis Documents were created.

4.3.7 Perform Assessment of System Attributes and Topic Areas

a. The checks of specific attributes against the topic areas will assess the internal consistency of system documents, procedures, and plant configuration and their conformance with design and licensing requirements. The ESRR Team will document conformance with requirements as well as discrepancies on an Attribute Assessment Form. An example of a completed Attribute Assessment Form is provided in Figured (Actual form may vary slightly as it will be computer generated).

b. Each Attribute Assessment Form shall list the documentation reviewed or walkdown observations made to arrive at the assessment conclusions. The list of reviewed documents shall contain revision numbers and/or date if applicable. The assessment forms shall describe the assessment and indicate the number of attribute checks covered by the assessment form and the number of attribute checks which resulted in identification of discrepancies. The ESRR team shall determine the extent of condition for discrepancies identified within their system by conducting additional checks as necessary.

c. A summary of the evaluation for each attribute will be documented in the Initial System Readiness Report. This sumtnary will document the checks made to verify the capability of the system to perform its safety and accident mitigation functions.

4.3.8 Perform Walkdown of System

Information PMP 7200.RST.004 Rev. 5 Page 21 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM ao The System Manager shall develop the walkdown strategy in accordance with the System Walkdown Guidelines and brief the ESRR Team (see Attachment 7). The walkdowns conducted as part of the previous System Readiness Reviews tended to focus on material condition. The ESRR walkdowns will include evaluation of material condition, but will also focus on configuration or environmental issues that could also impact the design and licensing basis. [Ref. 6.13]

System safety and accident mitigation function flow paths should be indicated on system flow diagrams. The marked up drawings will be used to assist the System Manager to verify the system safety and accident mitigation functions during the system walkdowns. Other drawings may be used by teams to check specific configuration or as-built details against drawing requirements.

C. Participants in the walkdowns will include the System Manager, the Operations representative, a Maintenance representative, and outside team member(s). Participation by representatives of design engineering and licensing may also be obtained when required by the System Manager;

d. The assessment performed during the walkdown will be documented, together with discrepancies noted, in the assessment data base.

e. Corrective action items identified during the walkdowns shall be.

entered into the Corrective Action Program and/or Work Control System by initiating a Condition Report or Action Request respectively.

These corrective action items will also be captured in the SIDS data base and the Assessment Data Base.

A Walkdown Report (Attachment 15) is to be assembled by the System Manager-and included in the Initial Expanded System Readiness Report The report will discuss the following:

1. Walkdown purpose and scope

2. Walkdown findings

3. Necessary corrective actions identified

4. Summarization of system concerns and condition

5. Suinmarization and justification for portions of systems that are not walked down.

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g. During the review and evaluation of the walkdowns, the System Team may develop additional checks to make beyond those on the Walkdown

. Guidelines.

4.3.9 Identify Long Standing or Recurring Equipment Performance Issues

a. Each ESRR team will obtain information from previous Reliability Centered Maintenance (RCM) evaluations, the IST program self assessment, and Maintenance Rule evaluations to identify potential long-standing or recurring equipment performance issues. Such issues be identified for follow-up in the Assessment Data Base and the 'hall Corrective Action Program and/or Work Control System and the

results will be documented in the Initial Expanded System Readiness Review Report. A Condition Report shall be issued for any item that falls within the scope of the Corrective Action Program. ~

4.3.10 Evaluate Extent of Condition for Identified Problems

a. Each system team shall assess recurring issues to determine whether further extent of condition determination is required (beyond the planned scope as documented in the initial system Assessment Matrix) and document any such conditions in the Initial Expanded System Readiness Review Report. [Ref. 6.14]

b. The ESRR Program Manager and Program Coordinator shall review the results across all the reviewed systems to identify potential programmatic or generic issues. Ifappropriate, this information will be used to recommend corrective actions of a programmatic nature.

The results will be documented in the Expanded System Readiness Review Integrated Results, described in Attachment 14.

4.3.11 Documen~view.results and enter discrepancies into ESRR Assessment Data Base and the Cook Plant Corrective Action Program and/or Work Control System. A Condition Report shall be issued for any items that fall within the scope of the Corrective Action Program.

a. Attribute checks performed as well as discrepancies found in this review are to be documented in the Assessment Data'ase.

Discrepancies shall also be entered into the Cook Plant Corrective Action Program by Condition Report or the Work Control System by Action Request.

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b. Condition Reports and Action Requests will automatically be loaded into the SIDS data base. This SIDS data base will allow tracking of

.. open items required for restart and will allow evaluation of potential aggregate effects of those items not required to be resolved prior to restart.

NOTE: Program owners or functional area managers (or designee) perform scoping, monitoring, and closure of non system-specific programmatic or functional area discrepancies as discussed further in PMP 7200.RST.009 and PMP 7200.RST.010.

4.3.12 Determine Restart Workscope

a. All system-specific items in the SIDS data base will be reviewed against the Restart Issues Selection/Screening Criteria (see Attachment 8). The System Manager is responsible for adding any known open corrective action items not present in SIDS for his system. These items are to be evaluated for Restart Readiness Scope. PRA risk-based insights may be helpful in deciding marginal cases.

b. Each system-specific item in the SIDS database will be evaluated using the evaluation process outlined in Attachment 8. The ESRR Team will recommend one of the following classifications for each such item in SIDS in order to enable return of the Cook Plant Units to operation in a safe and reliable manner:

1. RESTART1 - Activities required to be completed prior to entering Startup/Power Ascension of Unit 1. This classification includes necessary restart and power ascension testing activities as well as definition of the applicable mode restraint.

2. RESTART2 - Activities required to be completed prior to entering Startup/Power Ascension of Unit 2. This classification includes necessary restart and power ascension testing activities as well as definition of the applicable mode restraint.

3. POST RESTART1 - Activities which should be completed on a schedule consistent with the Unit 1 normal plant work controls process.

4. POST RESTART2 - Activities which should be completed on a schedule consistent with the Unit 2 normal plant work controls process.

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5. NOT APPLICABLE - Activities that are not required to be completed.

c. These classifications will be used to determine and schedule the work within the appropriate restart time frame;

d. Preventive Maintenance activities are unique since they often provide a means of enhancing equipment performance. However, the equipment being serviced may require being removed from operation. As a result, the ESRR must take these activities into consideration when evaluating PM activities. The following expectations are associated with the evaluations of PM activities:

~ All PMs scheduled for completion before August 31, 2001 are to

, be reviewed.

~ PMs scheduled (next required date) prior to March 31, 2000 are to be categorized as RESTART1 or RESTART2.

~ PMs that are scheduled or planned during the operating cycle, and require a unit outage to complete, are to be categorized as RESTART1 or RESTART2's appropriate.

~ PMs scheduled (next required date) prior to August 31, 2001 that are not part of on-line maintenance or a Functional Equipment Group (FEG) outage; and will impact a surveillance test, or initiate an unplanned or unscheduled LCO during the operating cycle, are to be categorized as RESTART1 or RESTART2.

~ PMs that are scheduled as a function of a pre-planned or pre-sehedtQed FEG outage, with or without an ensuing LCO, and do not challenge unit/system operability, are to be categorized as POST RESTART1 or POST RESTART2.

Some re-screening will be necessary ifthe assumed dates above change.

e. All system leaks are to be evaluated. Scope determination guidelines are as follows:

ll

~ Any leak location with no available isolation is to be categorized as RESTART1 or RESTART2, unless reasonable justification for a different categorization is provided.

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~ Any ASME code component/vessel/piping leakage is to be categorized as RESTART1 or RESTART2.

"~ Leakage that can only be isolated by using a "freeze seal" is to be categorized as RESTART1 or RESTART2.

~ Any leakage identified within containment requiring corrective action is to be categorized as RESTART1 or RESTART2.

Leakage identified on systems outside containment, on non-ASME code components/vessels/piping, that is isolable, and would not challenge system operability or reliability if worked non-outage, is to be categorized as POST RESTART1 or POST RESTART2.

Leakage from systems outside containment that would or could contain radioactive fluids that could violate leakage requirements in Section 14.3 of the UFSAR is to be categorized RESTART1 or RESTART2.

4.3.13 Labeling

~ Any labeling issues that have potential impact to work control tagging are to be categorized as RESTART1 or RESTART2 with the mode identified.,

~ Any labeling issues with any potential impact to system operability or reliability are to be categorized as RESTART1 or RESTART2.

~ Only labeling issues that have no impact on components/systems work control tagging are to be categorized as POST RESTART1 or POST RESTART2.

4.3.14 Prepare Initial Expanded System Readiness Report and Present to The System Readiness Review Board.

a. The information gathered throughout the system readiness review and

.walkdown shall be compiled by the ESRR Team into an Initial Expanded System Readiness Review Report. Each member of the review team, including participants in the walkdowns, will be identified in the report.

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EXPANDED SYSTEM READINESS REVIEW PROGRAM 5 Page 26 of 101

b. The System Manager will ensure that each open corrective action item identified during the ESRR and walkdown is initiated either as a Condition Report or Action Request, and, ifsystem-specific, is evaluated and scoped in the SIDS data base prior to the SRRB presentation.

C. The report content is as depicted in Attachment 12 and will be presented to the SRRB for approval. Minor changes in the report format are permitted with the concurrence of the ESSR program manager or coordinator. The System Manager will be accompanied by the Engineering Supervisor cognizant over the system.

d. When the Initial Expanded System Readiness Report is approved by the SRRB, the System Manager will next present the report to the PORC for approval. Ifthe report is approved by the SRRB with comments, the System Manager will resolve all SRRB comments and the original signees of the report will re-review the report and approve comment resolution. If the SRRB disapproves the report, the System Manager must re-present the report to the SRRB until approval is obtained, obtaining re-reviews as necessary.

e. After the report has been presented to the SRRB, the SRRB Secretary will provide the cognizant Engineering Supervisor with a list of all comments the System Manager needs to address. In some instances when the new technical issues are identified during SRRB reviews, the System Manager will be required to write a Condition Report on the issue. In this case, the respective Engineering Supervisor is to debrief the System Manager, and record the debrief in the CR. The debrief will address all comments recorded at the SRRB presentation. When ESRR program implementation problems are identified, the SRRB secretary will write a Condition Report oh the issue.

f. After SRRB approval, the System Manager presents the Initial Expanded System Readiness Review Report to the PORC. The PORC will approve or disapprove the report, from a nuclear safety standpoint, keeping an overview perspective that focuses on ensuring that inter-disciplinary concerns were adequately addressed. PORC should not normally focus on approving SRRB action on each discrepant condition but rather should probe into methods and overall results. If approved, the action items will be included in the restart effort. Any changes to the scope (restart/post restart) of individual items will be recorded in the PORC meeting minutes. Ifdisapproved, the System Manager will take appropriate actions and re-present the report to the PORC.

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- g. The cognizant Engineering Supervisor will ensure incorporation of PORC comments within the report and SIDS data base. PORC comments are to be incorporated in SIDS by the SIDS Data Base

-

Coordinator, and reviewed by the System Manager. PORC comments within the report are to be incorporated by the System Manager.

4.3.15 Functional Areas and Programmatic Issues

a. Open items associated with functional areas and programs will be loaded into the SIDS data base.

b. If the open functional area or programmatic items affect specific systems, these items will be transferred to the appropriate system, within SIDS, where the ESRR Teams will scope the items.

c. The SRRB will review the scoping of programmatic and functional area work items that are not system specific subject to a schedule and protocol established by the Director of Restart.

d. Functional area and programmatic issue items will be reviewed and approved by SRRB.

e. For open functional area and programmatic items that are not system specific, the appropriate functional area or program owners are responsible for ensuring that the functional areas and programs are ready to support restart in accordance with the Restart Plan.

4.4 Phase 2 - Restart Activities Monitoring NOTE'rogram owners or functional area managers (or designee) perform scoping, monitoring, and closure of non system-specific programmatic or functional area discrepancies-as. discussed further in PMP 7200.RST.009 and PMP 7200.RST.OIO 4.4.1 General Description of Phase 2 Activities

a. The System Manager will use SIDS to monitor approved system work scope and identify any new action items. Work activities should be frequently field verified and monitored to insure corrective actions are being taken and no adverse plant conditions develop.

b. The System Manager will perform the following activities:

1. Monitor closure of approved system-specific workscope items using SIDS and available performance indicators.

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2. Identify and evaluate new emergent system-specific action items for restart; consider using risk-based insights where available to enhance decision-making in marginal cases.

3. Perform routine field walkdowns

4. Make presentations to the SRRB as requested

5. Review system work window planning and scheduling to ensure work is being properly scheduled

6. Provide input to and review System Test Plans

7. Update SIDS to reflect proper completion of open system-specific items and to document exceptions to completed work

c. For Restart Required items that are not planned to be completed prior to restart, the system-specific Restart Required Scope Deferral Form (Attachment 10) is to be reviewed through the same level of approval as when the item was originally approved for restart.

d. Applicable Restart Required Scope Deferral Forms are to be completed prior to closure of the applicable System Work Window. For Condition Reports not associated with corrective maintenance, the deferral form is to be completed no later than the Final Expanded System Readiness Review.

4.4.2 Management of Workscope NOTE: Emergent items scoped as restart must be scheduled in the appropriate System Work Windows.

a. Identify and Scope Emerging (New) Open Items

1. Phase 2 work items that are evaluated and scoped for accomplishment prior to restart after the Expanded System Readiness Review Initial Report is prepared will be reviewed using the following process in accordance with Attachment 9.

a) The System Manager will review, evaluate and scope new or emergent system-specific items within SIDS in accordance with Attachment 8, "Criteria for Work Included in Restart Scope,"

Information PMP 7200.RST.004 Rev. 5 Page 29 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM b) The System Manager is also responsible for review and evaluation of any newly initiated Operating Experience items impacting his respective systems. The new Operating Experience items are to be scoped for applicability to the unit restart. The System Manager is to ensure that Operating Experience items that are scoped as restart items are resolved and follow-up actions completed prior to restart.

c) System-specific items that result in newly created corrective maintenance or new design change requests are to be monitored for closure.

2. Phase 2 Outage Scope Approval Process - Additions a) Once new emergent field work items (ARs/JOs/JOAs) are scoped by the System Manager, they will be presented to the OSMT for review and approval by the cognizant Engineering Supervisor or his designee in order to be added to the Restart Schedule; These new emergent work items are subsequently (usually weekly) presented to the SRRB (or subcommittee thereof) for review and approval by the System Manager.

PORC approval of restart items is not required during Phase 2.

b) All other emergent system-specific items that are not field work related (broke/fix) are scoped by the System Manager and presented to the SRRB (or subcommittee thereof) for review and approval. PORC approval of these items is not required during Phase 2.

3. Phase 2 Outage Scope Approval Process - Deletions a~When deferring items that have been previously approved by the SRRB and PORC as restart items, The Restart Required Scope Deferral Form is to be used. The form will be reviewed through the same level of approval that the restart item originally received.

b. System Windows

-1. System Window Scheduling

Information PMP 7200.RST.004 Rev. 5 Page 30 of 101 EXPOUNDED SYSTEM READINESS REVIEW PROGRAM a) The System Manager and Operations personnel should ensure that the applicable restart work is contained within the respective system work window or'ther appropriate work opportunity. Actual system work windows are developed and scheduled using a System Work Window Team that assists the scheduling organization. System window planning and scheduling will be accomplished by the team under the supervision of the System Manager as follows:

~ Interface with the appropriate planner and scheduler and obtain the planned system windows for review.

~ Review the system schedule for completion. The System Manager should record system schedule additions, changes, conflicts, and omissions within an internal memorandum sent to Planning and Scheduling.

~ Through System Work Window Team meetings the System Manager will ensure that the System Work Window Team is aware of restart task requirements to support System Work Window schedules.

2. System Window Work Management a) The following issues are to be monitored on systems with only one work window, or monitored during the final system work window of a system:

~ Ensure Restart Required scope items are completed. The, System Manager will review completed items to ensure the work was completed to his satisfaction.

~ The System Manager is to assure that the final comment field in SIDS is completed.

~ For Restart Required items, the mode field and the test restraints within the issue field are to be completed in SIDS by the System Manager.

<'.

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~ Closed restart scope items are to be reviewed and approved by the System Manager and comments entered into the Final Comments Screen of each item in SIDS.

An approval designates that the responsible department for completing the item has statused the item as closed or complete.

b) The following issues are to be monitored by the system work window team on systems with multiple system work windows.

~ Ensure "Evaluation Type" open items (i.e., CRs, AR Evals etc.) are completed.

~ Corrective maintenance items generated from "Evaluation Type" activities are scoped within SIDS.

~ Ensure emergent work items'scoped as Restart are

'cheduled for completion prior to the end of the last available system work window.

c. System Test Plans

1. The System Managers are responsible for assisting in the development of the Startup Testing Program for their respective systems. The System Manager will support the Start-up and Power Ascension Organization/Operations organizations in this capacity.

2. The System Manager will start developing System Test Plans in accordance with PMP-7200.RST.005 (when approved). Test Plans will be developed for appropriate systems based on the reviews performed in Phase 1.

3. For systems where the System Manager concludes that System Test Plans are not appropriate, justification as to why a System Test Plan is not required will be developed.

d.. System Walkdown

1. System Manager should complete a system walkdown on a routine basis. The purpose of these walkdowns is to monitor satisfactory completion of work and to identify emergent deficient conditions.

e. Interaction with the System Readiness Review Board

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1. Any new technical issues identified in a system by SRRB during Phase 2 will be documented in a Condition Report. The Condition Report will be generated by the SRRB secretary or individual System Managers will write the Condition Reports if the issue was identified during a SRRB meeting or presentation at which they are present.

4.5 Phase 3 - Final Expanded System Readiness Review NOTE: Program owners or functional area managers (or designee) perform scoping, monitoring, and closure of non system-specific programmatic or functional area discrepancies as discussed further in PMP 7200.RST.009 and PMP 7200.RST.010.

4.5.1 General Scope

'.

For Restart Required items that are not planned to be completed prior to restart, the Restart Required Scope Deferral Form (Attachment 10) is to be reviewed through the same level of approval as when the item was originally approved for restart.

b. Applicable Restart Required Scope Deferral Forms are to be completed prior to closure of the applicable System Work Window. For Condition Reports not associated with corrective maintenance, the deferral form is to be completed no later than the Final Expanded System Readiness Review.

c. Restart Activities

1. System Managers will review all items scoped RESTART1 or RESTART2 in SIDS to ascertain their completion prior to "affirming final system readiness for Restart.

2. A final system readiness review walkdown will be completed by the System Manager and a licensed operations representative.

3. A Final Expanded System Readiness Review Report will be developed.

4. The System Test Plan will be revised to include all items applicable to Restart and Power Ascension that were not approved in previous revisions of the Test Plan.

~ mr~,

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5. The Final Expanded System Readiness Review is completed when the System Test Plan has been revised and received Test Review Board (TRB) (reference PMP-7200.RST.005 (when approved))

concurrence and the Final Expanded System Readiness Review Report has been completed, presented to the SRRB and the PORC, and PORC approval has been given for system Restart.

6. Restart Required system-specific items that are not completed are to be coded as an Exception within SIDS. Refer to Attachment 11, "Final Expanded System Readiness Review Clarification Sheet,"

for detailed information.

7, Items that are coded as an Exception do not require comments in the Final Comment field in SIDS.

8. Restart Required system-specific items that are not planned to be .

completed prior to restart are to be coded as Restart Required Deferred in the Final System Manager Approval box within SIDS.

Refer to Attachment 11, "Final Expanded System Readiness Review Clarification Sheet," for detailed information.

d. Post Restart Activities System Managers will review all system-specific items scoped Post Restartl or Post Restart2 as appropriate in SIDS for final approval for applicability to Restart. They then complete the Final Comment field in SIDS for all Post Restart items.

2. For components that have two (2) or more associated Post Restart items, the Post Restart items are to be coded as Post Restart Deferred in the Final System Manager Approval box within SIDS.

Refer-.to Attachment 11, "Final Expanded System Readiness Review Clarification Sheet," for detailed information.

3. Post Restart items related to components with multiple (two or more) deferred issues, excluding post restart PMs, are to have the Final Comment section completed in SIDS providing technical justification for restart by evaluating the aggregate impact of the multiple deferred tasks on the component. These comments are to be referenced in the Final Expanded System Readiness Review Report.

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4. Marked-up drawings identifying the components with multiple deferred issues will be included with the Final Expanded System Readiness Review Report.

5; The aggregate impact of all outstanding items against a given component will be reviewed, assessing the operability of the component. Justification for exclusion of the items for Final System Readiness will be included in the Final Expanded System Readiness Review Report.

6. The aggregate impact of all affected components will be evaluated against the given system assessing the operability of the system, and this evaluation will also be included in the Final Expanded System Readiness Review Report.

4.5.2 Final Restart Work Closure

a. All system-specific Restart Scope items within SIDS are to be reviewed and concurred with by the System Manager. An approval designates that the responsible department for completing an item has statused the item as Work Complete or Closed. Any known exceptions to the items are to be noted as specified in Section 4.5.1c.6 prior to System Manager approval. Items not administratively closed are to be addressed within the final comments as to how these items are to be closed.

b. The System Manager collects the Restart Required Scope Deferral Forms completed on each system and reviews the Deferred Restart Required Work and Post Restart Scoped Work, excluding post restart PMs, for aggregate impact to the system, and prepares technical justification for system operability in accordance with its design basis functions=This review is to be included within the Final Expanded System Readiness Review Report as discussed in Section 4.5.4a.

4.5.3 Final System Walkdown and Walkdown Report

a. The ESRR Team, under the leadership of the System Manager, will conduct a final system walkdown in accordance with the guidance of Attachment 7. The pu'rpose of the walkdown is to ascertain proper accomplishment of identified, work and to identify any previously undocumented system deficiencies.

b. Minimum walkdown attendance will require the System Managel. and a licensed operations representative.

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c. Upon completion of the System Team Walkdown, the System Manager will complete a Walkdown Report. This report will cover the topics identified in Attachment 15 and will form a part of the Final Expanded System Readiness Review Report.

d. Discrepancies identified during this walkdown will be entered into the Corrective Action Program and/or Work Control System.

4.5.4 Final Expanded System Readiness Review Report

a. The Final Expanded System Readiness Review Report will include the following items:

1. Final Expanded System Readiness Review SIDS Report.

2. Final Expanded System Readiness Review System Walkdown Report (Attachment 15).

3. The report will include a cover sheet similar to Attachment 13, titled Final Expanded System Readiness Review Report.

4. Copies of all Restart Required Scope Deferral Forms for the system are to be attached.

I

5. Impact of deferred work assessment (See 4.5.4b below).

6. System Test Plan

b. The impact of deferred work (work scoped as Post-restart) will be

~

assessed, first individually, then in aggregate on individual system components, then on the system overall readiness for restart as discussed'further below.

1. The following items will be evaluated individually regarding the impact on a component basis, aggregate impact on a component basis, and aggregate impact on a system basis:

~ Post Restart Scope, system components with multiple (Two or more) deferred work items, excluding post restart PMs.

~ All Restart required deferred scope Components.

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2. The evaluation will first address system components with multiple deferred work items. At the component level, the deferred work issues, then the aggregate impact of the deferred work for each component will be addressed.

3. This discussion will include the technical justification allowing the component to return to service with the identified deferred work issue(s).

4 System components with multiple (two or more) Post Restart deferred work items, or any component with a deferred Restart Required work item are to be identified on the applicable drawing(s) (Flow Diagrams, Wiring Diagrams, General Arrangement Diagrams), with the deferred work identification number(s) noted next to the affected component. Alternately, the-.

component can be identified'on the drawing and a list of the deferred work identification numbers for each affected component attached.

5. The aggregate impact evaluation will conclude with a discussion on system readiness to return to service. The aggregate impact on the system and its capacity to perform its design basis function is to be discussed, addressing the cumulative impact of system components with deferred work. A statement will be included explaining how the deferred work is to be scheduled.,

c. Final Expanded System Readiness Review Presentations The Final Expanded System Readiness Review Reports are to be reviewed by the respective Operations and Licensing representatives, Engineering Supervisor, then scheduled for presentation 4tL'L Ml I to the SRRB.

2. The Final Expanded System Readiness Review Report is to be ll presented to the SRRB and PORC by the System Manager, the cognizant Engineering Supervisor and a licensed operations representative. SRRB or PORC comments or open items are to be addressed as discussed in Sections 4.3. 14e through 4.3. 14g for the Initial Expanded System Readiness Review Report.

d. System Test Plans

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1. System Test Plans are to be finalized as specified in (PMP-7200.RST.005 (when approved)). The plans will include all items applicable to Restart and Power Ascension which have been finalized subsequent to previous revisions of the Test Plan.

2. System Test Plans or Justifications for not having System Test Plans will be reviewed and approved by the Test Review Board.

3. System Test Plans will be implemented through Phase 3 and Phase 4 of the ESRR Program.

4.5.5 Phase 3 Emergent Work Management

a. Emergent corrective action items are to be continuously scoped for restart applicability throughout Phase 3. Use of PRA risk-based insights may help with marginal cases.

b. After initial comments and scoping on an emergent system-specific work item is incorporated in the SIDS database, the item is coded "APPROVE". The System Manager also reviews the scoping of the item and if Restart required, then annotates it in the SIDS database as "EXCEPT" (to designate the item as a restart exception if not.

completed).

c. For a system-specific item scoped as Post Restart, comments are

, entered in the Final Comments field and the System Manager codes the item as Post Restart Deferred.

d. For emergent system-specific field work items, refer to Section 4.4.2a.2.a) for the approval process.

e. For all other emergent system-specific items that are not field work related (broke/fix), refer to section 4.4.2a.2.b) for the approval process..

f. The system-specific Exception List in SIDS is to be continually managed by the System Manager until the system is turned over to Operations for testing.

g. For those system specific items that are completed and satisfy restart requirements, change the "EXCEPT" to "CONCUR" and complete the Final Comments section in SIDS.

4.6 Phase 4 - Startup And Power Ascension

Information PMP 7200.RST.004 Rev. 5 Page 38 of 101 EXPMDED SYSTEM READINESS REVIEW PROGRAM NOTE'rogram owners-or functional area managers (or designee) perform scoping, monitoring, and closure of non system-specific programmatic or functional area discrepancies as discussed further in PMP 7200.RST.009 and PMP 7200.RST.010.

4.6.1 General Scope

a. Phase 4 activities include the following:

1. Phase 4 commences on each system with the PORC approval of Final Expanded System Readiness Review Report for that system.

2. The System Manager is to monitor through completion those system-specific work items scoped Exception within SIDS.

3. Management of emergent system-specific work items through the normal work control process and Scope Addition/Deletion Cover Sheet (TBDL).

4. The System Manager is to complete System Readiness Affirmation after the retest portion of the system work window and prior to restoration of system operability to support unit Restart.

5. 'ystem Readiness Affirmation and submittal of the System Readiness Affirmation Report (Attachment 16).

6. Each System Manager is to monitor the conduct of the Station Startup and Power Ascension Plan as it relates to his system.

7. The System Manager is to implement the baseline system performance monitoring, tracking and trending.

S. System Work Window Teams are to continue to meet on a regular basis. The System Manager will lead the team in managing future system work windows, as well as monitoring open corrective action items, operability issues, and reliability issues on the system.

9. Phase 4 is complete when all power ascension testing is complete and the respective unit attains 100% rated unit load for - (TBDL)-

days..

4.6.2 Phase 4 Emergent System-Specific Work Management, Prior to System Affirmation

r 0

Information PMP 7200.RST.004 Rev. 5 Page 39 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM

a. Emergent issues are to be reviewed to support the system work window schedule.

b. Emergent corrective action items are to be presented to the OSMT with an attached Scope Addition/Deletion Cover Sheet (TBDL).

c. Emergent items are to have initial comments entered into SIDS and to be scoped as follows:

1, Emergent items that are required for restart will be scoped Restartl or Restart2, in accordance with Attachment 8, "Criteria for Work Included in Restart Scope."

2. Items that are identified to be worked in accordance with the normal Work Control system requirements are to be scoped as WORK CONTROL PROCESS (WCP). Items scoped as WCP will include the technical basis for when the item should be completed.

These conditions shall support work order priorities as defined in PMI-2291 to ensure continued system readiness.

3. An explanation, providing technical justification (Reference item 6 on Attachment 8) is to be entered in the Initial Comments Field in SIDS.

4. The System Manager is to "APPROVE" items in the Initial System Manager Approval box in SIDS once he is satisfied with the scope of the item-.

d. Corrective maintenance work items are to be presented to the OSMT with a Scope Addition/Deletion Cover Sheet (TBDL). Engineering issues that may impact the system affirmation process are to be included and managed via the Restart Schedule.

e. Restart Required items that are not complete are to become "Exceptions," and added to the "Exceptions" list. When an item is completed, the System Manager is to review and denote as "CONCUR" within the Final System Manager Approval box in SIDS.

4.6.3 System Readiness Affirmation

a. The System Manager will complete a System Readiness Affirmation Report which will include the following information:

1. Current system License Change Request(s).

Information PMF 7200.RST.004 Rev. 5 Page 40 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM

2. Current list of operator workarounds.

3. Current corrective actions that involve Control Room equipment.

4. Currently installed Temporary Modifications.

5. Active Operability Determinations (ODs) and Justifications for Continued Operation (JCOs), with the associated 10CFR50.59 screen or evaluation for each OD or JCO.

6. The remaining open system-specific "Exceptions" items and any system-specific "Exceptions" identified during the affirmation process. Exceptions are remaining open restart required items.

7. Any other operations focus list concerns involving the system.

8. Reference to the Initial Expanded System Readiness Review Report

9. Reference to the system tests specified in the System Test Plan.

b. The System Manager and licensed operations representative will conduct a System Readiness Affirmation walkdown and document walkdown on System Walkdown Report (Attachment 15). The results of the walkdown will be included in the System Readiness Affirmation Report.

c. The licensed operations representative will co-sign the System Readiness Affirmation Report with the System Manager.

d. Any corrective actions identified during the System Readiness Affirmation are to be addressed within the work control process and identifiedao the Outage Control Center for resolution, Engineering action items are to be added to the Engineering Priority List with the designated engineer identified as the lead.to resolve the issue.

e. The System Manager and the licensed operations representative will present the System Readiness Affirmation Report to SRRB and PORC.

f." Any comments received from SRRB during the Phase 4 require resolution and response within three weeks from the date of the SRRB meeting.

g. The system is turned over to operations after PORC approval of the System Readiness Affirmation Report.

~ .

Information PMP 7200.RST.004 Rev. 5 Page 41 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 4.6.4 System Test Plans

a. The System Managers are to monitor the results of each respective Test Plan. The System Managers are to follow-through on 'System deficient test plan results the Corrective Action Program and/or Work Control System as appropriate. A Condition Report shall be issued for any items that fall within the scope of the Corrective Action Program.

b. System Test Plan results are to be selectively incorporated within the System Manager Performance Monitoring Program (TBDL).

4.6.5 Emergent System-Specific Work Management After System Affirmation

a. All emergent issues are to be scoped as "WCP" or "Work Control Process" in the SIDS database. Emergent work is to be addressed within the'work control process as described within the Station Administrative Procedures.

b. Emergent corrective maintenance issues are to be presented to the OSMT. Emergent engineering issues that may impact unit start-up are to be addressed within the Engineering, Priority List.

4.7 Reports 4.7.1 Phase 1 - Initial Expanded System Readiness Review Report.

a. The Initial Expanded System Readiness Review Reports are to be completed in accordance with Section 4.3. 14 and Attachment 12.

4.7.2 Phase 3 Final Expanded System Readiness Review Report

a. The Final Expanded System Readiness Review Reports are to be completed in accordance with Section 4.5.4 and Attachment 13.

4.7.3 Phase 4 System Readiness Affirmation Report

a. The System Readiness Affirmation Reports are to be completed IAW Section 4.6.3a.

4.7.4 Integrated System Readiness Report

a. The ESRR Manager or his designee shall prepare a report which integrates the results of the individual system ESRR efforts.

Information PMP 7200.RST.004 Rev. 5 Page 42 of 101 EXUDED SYSTEM READINESS REVIEW PROGRAM

b. The integrated report (see Attachment 14) shall summarize the results of the ESRR activities in Phases 1 and 2, and identify the status of other programs, reviews and upgrades that are supportive of the ESRR

'n providing reasonable assurance of being in conformance with licensing and design basis.

c. The intent of this integrated report and associated backup information is to provide assurance that the plant design, testing, maintenance, operation and configuration conforms to the licensing and design requirements and that the plant is in a condition to support plant operation for the next run cycle.

d. The final integrated System Readiness Report will be presented to the SRRB for review and to the PORC for approval.

5 FINAL CONDITIONS 5.1 None 6 REFERENCES 6.1 Cook Nuclear Plant Restart Plan 6.2 NUREG 1397, An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Power Industry E

6.3 Restart Strategy for Restart Issue 5455, Plant Systems Readiness Assessment 6.4 Auxiliary Feedwater SSFI Report (November 1998) 6.5 Engineering Issues Review Group Final Report (December 19, 1998) 6.6 PMP 7200.RST.006, Expanded System Readiness Review Program For Level 2 Systems 6.7 PMP-7200,RST.005 (when approved), Restart Startup Power Ascension Program

Information PMP 7200.RST.004 Rev. 5 Page 43 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 6.8 CR 98-8122, System Readiness Reviews for 21 Systems May Not be Effective in Verifying System Operability 6.9 PMP-7200.RST.009, Functional Area Restart Readiness 6.10 PMP-7200.RST.010, Programmatic Restart Readiness

, 6.11 Commitment Management System Commitment 7280

6. 12 Commitment Management System Commitment 7197 6.13 Commitment Management System Commitment 7303 6.14 Commitment Management System Commitment 6783 6.1S Commitment Management System Commitment 7319

Information PMP 7200.RST.004 Rev. 5 Page 44 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 1 SYSTEM READINESS REVIEW BOARD Pages:

(SRRB) CHARTER 44-45 SYSTEM READINESS REVIEW BOARD SRRB CHARTER PURPOSE: Perform a system-based, multidisciplinary technical review of potential restart issues associated with risk significant plant equipment. This board is intended to ensure consistent application of the restart criteria contained in the Cook Nuclear Plant Restart Plan among system managers, and 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 that is needed to provide reasonable assurance of a safe and reliable stanup and achieve a safe, reliable, and efficient post startup operating cycle.

MEMBERS: Director of Engineering Restart (Chair)

Director of Plant Engineering (Vice Chair)

System Engineering Manager (Vice Chair)

Vice President of Nuclear Engineering Manager of System Readiness Reviews Director of Design Engineering (Vice Chair)

Director of Nuclear Fuels, Safety and Analysis (Vice Chair)

Operations representative - Bob Heathcote (primary) or Rodney Foster (alternate)

EOP Project representative - Kevin White (primary) or Jim Abshire (alternate)

External consultants: John Durham>>>>

Greg Gibbs>>>>

Phil Hildebrandt>>>>

Larry Demick>>>>

Jeff Bass>>>> (primary) or BiH Bryant' (alternate) Westinghouse representative System engineering supervisors Board Secretary Non-voting members: Additional occasional attendance by members of the Plant Operations Review Committee, the Restart group, and the Engineering Effectiveness organization is expected to reinforce expectations and provide oversight for the restart issue review process=.Additionally, the SRRB Chairman may invite guest, non-voting members to supplement the board when reviewing nonwngineering program or functional area assessment results or SIDS issues.

QUORUM: Chair (or Vice Chair), an Operations and EOP Project representative, and a (ESRR minimum of two of the double asterisked named members, and one engineering Related supervisor, not associated with the system or document/program under review. A Board SRRB Secretary shall also be present but may be one of the SRRB members. No

-Functions) board willconsist of more than six voting members. Other members may participate at their discretion as non-voting members in such cases.

5 5 % QJ Information PMP '7200.RST.004 Rev. 5 Page 45 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM READINESS REVIEW BOARD Pages:

Attachment 1 (SRRB) CHARTER 44-45 QUORUM Chair (or Vice Chair), minimum of two of the double asterisked members and two (Programmatic other members. One of the additional members shall be an engineering and Functional representative for reviews of engineering programs. No board shall consist of more Area Readiness than five voting members. An SRRB Secretary shall also be present but may be one Board of the SRRB members. Other members may participate at their discretion as non-Functions) voting members in such cases.

ACTIONS: The SRRB will:

l. Serve as the primary independent engineering review body for 0350 checklist item restart action plans as required by PMP 7200.RST.001'nd, as delineated further in PMP 7200.RST.004 and PMP 7200.RST.006, expanded system readiness review identified issues and reports. The SRRB will also perform functions related to assuring proper dispositioning of programmatic and function area readiness discrepancies as detailed in PMP 7200.RST.009 and PMP 7200.RST.010. The SRRB affirms and approves the scoping of potential deficient conditions as either restart or post-restart based on criteria defined in the restart plan.

2. In its reviews, enforce technical rigor, consistency of approach, and a thorough assessment of system readiness. The SRRB will also challenge engineers to ensure the issues are fully understood.

3. Ensure a record of decisions and concerns raised by the SRRB review is documented for future review. Programmatic implementation concerns raised by the SRRB willbe documented on condition reports initiated by the SRRB secretary.

4. Ensure that nuclear engineering principles and the attributes of good engineering are demonstrated by the engineering staff.

5. Ensure that the engineers understand their roles and responsibilities.

The Director of Engineering Restart is responsible for management oversight of SRRB activities and for disbanding this board after startup when directed by the Site Vice President. PORC=will'provide oversight of the SRRB and approve Expanded System Readiness Reports as discussed in PMP. 7200.RST.004 and PMP 7200.RST.006 in that oversight role.

This charter becomes effective with the issuance of PMP 7200.RST.004 REVISION 5.

Information PMP 7200.RST.004 Rev. 5 Page 46 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 21 LEVEL 1 SYSTEMS INCLUDED IN THE Pages:

Attachment 2 PREVIOUS SYSTEM READINESS REVIEW 46-47 THE 21 LEVEL 1,SYSTEMS FOR THE PREVIOUS EXPANDED SYSTEM READINESS REVIEW WERE 120 volt AC/CRID Inverters Air Recirculation/Hydrogen Recombiner Auxiliary Feedwater 250 volt DC Station Batteries Component Cooling Water Containment Containment Spray Control Air ECCS Accumulators ECCS Charging/CVCS High Head Injection ECCS Residual Heat Removal ECCS Safety Injection Emergency Diesel Generators Essentiai Service Water Ice Condenser Main Steam Non-essential Service Water Plant Air Compressors

J 0

Information PMP 7200.RST.004 Rev. 5 Page 47 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 21 LEVEL 1 SYSTEMS INCLUDED IN THE Pages:

PREVIOUS SYSTEM READINESS REVIEW 46-47 Reactor Coolant System Reactor Protection System/Solid-state Protection/ESFAS Electrical Safety Buses 4000 volt and 600 volt

Information PMP 7200.RST.004 Rev. 5 Page 48 of 101

"-

EXPANDED SYSTEM READINESS REVIEW PROGRAM RATIONALEFOR SELECTING LEVEL 1 Attachment 3 Pages:

SYSTEMS FOR EXPANDED SYSTEM 48-48 READINESS REVIEW The following rationale was used in selecting the 39 systems to be reviewed in accordance with this procedure. All selected systems are identified in Attachment 4.

Maintenance Rule Risk Si ificant S stems All Cook Plant Maintenance Rule Risk Significant systems were included in the Level 1 ESRR.

S stems Re uired to Su ort Safe Shutdown The Cook Plant specific fire protection/Appendix R reports/documents were reviewed to identify systems required to support safe shutdown. All of these systems were included in t5e scope of the Level 1 ESSR.

Attendant/Su ort S stems Attendant systems were considered during the identification of Level 1 systems being selected for the ESRR. Heating, Ventilation and Air Conditioning systems such as Control Area Ventilation, Switchgear Ventilation and Containment Ventilation were included in the scope of the ESRR. The Screenwash and Fire Protection Systems were also included as attendant/support system.

Historical Performance of Cook Plant S stems The historical performance of Cook Plant systems was considered. Based on input from the System Engineering Manager and the Operations Manager additional systems such as Emergency Lighting, and Post Accident Sampling System (PASS) were included.

Third Pa Review of the Sco The scope of the systems chosen for ESRR was reviewed by a peer group and an independent third party to ensure that successful completion of the ESRR on these systems would provide a reasonable assurance that the Cook Plant can be restarted safely and reliably.

Information PMP 7200.RST.004 Rev. 5 Page 49 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM EXPANDED SYSTEM READINESS REVIEW Pages:

Attachment 4 LEVEL 1 SYSTEMS 49- 50 SYSTEM DESCRIPTION ABB SYSTEM RELATED SYSTEMS RISK SIG SAFE SHUT SIG SUPPORT SIG LEVEL DOWN SYSTEM CORRECTIVE MAINT.

ECCS CHARGING CVCS Includes Cha in Letdown Boron Path and SINJ ECCS SI POST ACCIDENT SAMPLING SYSTEM Ir PASS N AUX BUILDINGVENT ESF Includes ABV GEN & AF/ESW V CONTROL ROOM COMPLEX VENTILATION CRAC SWITCHGEAR VENTILATION SWGR N 250 VDC STATION BATI'ERIES 250 VDC Includes N TRN ICE CONDENSER ICE CONTROL ROD & CONTROL ROD DRIVE CRDM Includes RPI RPS/SSPS/ESFAS LOCAL SHUTDOWN INDICATIONSYSTEM LSI N RADIATIONMONITORING RMS RVLIS RVLIS COMPONENT COOLING WATER CCW CNTMT ISOLATION COMPONENTS CIV SPENT FUEL PIT COOLING 120 VAC VITALBUSES & CRID INVERTER CRID MAINSTEAM MS Includes DUMP & N2 for PORVs AIR RECIRC/H2 SKIMMER ~CE CONTAINMENTVENTILATION CV VENTILATION- DIESEL GENERATOR DG VENT EMERGENCY DIESEL GENERATORS "S" in the "Safe Shutdown Column" indicates a support system for safe shutdown

Information PMP 7200.RST.004 Rev. 5 Page 50 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM EXPANDED SYSTEM READINESS REVIEW Pages:

Attachment 4 LEVEL 1 SYSTEMS 49-50 SYSTEM DESCRIFTION ABB SYSTEM RELATED SYSTEMS RISK SIG SAFE SHUT SIG SUPPORT SIG-LEVEL DOWN SYSTEM CORRECTIVE MAINT.

ELECTRICAL SAFETY BUSES T BUS Includes 4KV & 600 V SCREENWASH SCRN Includes Screcnhouse/Intake FIRE PROTECTION - HALON & CARDOX Includes RCP FP N AUXILIARYBUILDING TURBINE BUILDING CONTROL AIR Includes Com ressed Air Header &

CNTMT Control Air Header PLANT AIR COMPRESSOR PAC Includes BAC CONTAINMENT CNTMT Includes DIS & H2 REC & HDS CONTAINMENTSPRAY AUX FEEDWATER SYSTEM Includes CST Includes MLMS ECCS ACCUMULATORS ACCUM RCS/RCS PRESSURE RELIEF EMERGENCY LIGHTING PACKS E LTG N OFFSITE POWER OFPW Includes SWYD ESSENTIAL SERVICE WATER ESW NON ESSENTIAL SERVICE WATER NESW NUCLEAR INSTRUMENTATION NI Includes T/C N "S" in the "Safe Shutdown Column" indicates a support system for safe shutdown

Information PMP 7200.RST.004 . Rev. 5 Page 51 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM EXPANDED SYSTEM READINESS REVIEW Pages:

Attachment 5 TRAINING REQUIREMENTS 51-51 1.0 TECHNICA'L TRAINING 1.1 Human Error Reduction Techniques for Engineers* (including record review and verification) 1.2 Electronic Corrective Action System

'.3 Folio Database*

1.4 Calculation Matrix 1.5 System Design and Licensing Basis~

1.6 SRO level self taught systems training with test and remediation*

1.7 Causal Analysis and effective problem solving techniques 1.8 Operability Determinations*

1.9 50.59 Screens and Evaluations*

1.10 PRA/Maintenance Rule 1.11 INPO Database/NRC Web Page~

1.12 Environmental*Qualification 1.13 Generic Letter 89-13 1.14 Generic Letter 89-10 1.15 High Energy Line Break Analysis 1.16 Appendix R 1.17 Station Blackout 1.18 Communications-Elevating Issues to Mgnt.

2.0 PROCESS TRAINING 2.1 The Enhanced System Readiness Review Program and Procedure 2.2 Use of the Assessment Database 2.3 Systems Indexed Database System (SIDS), access and data entry 2.4 Use of. computers 2.5 Lessons Learned and Vulnerabilities from previous independent inspections and reviews.

For System Managers only. Senunars to indoctrinate other team members in design and licensing basis fundamentals and key concepts and definitions related to operability determinations and 50.59 screens and evaluations will also be conducted for other team members.

0 Information PMP 7200.RST.004 Rev. 5 Page 52 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 6 SYSTEM READINESS REVIEW Pages:

DOCUMENTATION AND DATA SOURCES 52-53 DESIGN BASIS DOCUMENTATION P&IDs Elementary and One Line Diagrams DBDs & Associated Notebooks Calculations Modifications Open and Closed Safety Evaluations and Screenings TMODS ~

Com nent Evaluations Design Change Determinations LICENSE BASIS DOCUMENTS UFSAR, FSAR & SER including Amendments General Design Criteria & FSAR Q&A Licensing History Books Commitment Database Reg Guides LERs & NOVs Tech S ecs and Bases NRC 0 n Item List DATASOURCES Operating Procedures Abnormal 0 rating Procedures Emergency Operating Procedures Annunciator Response Procedure Preventive Maintenance Procedures/PMCR Surveillance Test Procedures s Training Lesson Plans

-

Condition Reports 0 en and Closed Previously conducted audits, assessments (SSFIs, EDSFIs, QA/PA, 3 a reviews)

Results of relevant NRC & INPO ins tions (Ins tion Re rts, etc.)

Generic Letters and Res nses IENs IEBs and Res onses SOERs SERs Part 21 Notifications Westinghouse Information Vendor Manuals JO/ARs including AR Evals rability Determinations &, TDMs Ops 0 n Item Log DATASOURCES (CONTINUED) 0 rator Workarounds/Concerns Restart Plan Strategies Engineering Evaluations S ifications and Standards PRA Com onents Based and 0 rator Action Based Risk Ranking Engineering Memos

Information .

PMP 7200.RST.004 Rev. 5 Page 53 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM READINESS REVIEW Pages:

Attachment 6 DOCUMENTATIONAND DATA SOURCES 52-53 Receipt Ins ection Procedures Relay Document Technical Data Book PMI 5023 Dedication Plans Long Standing Clearances/Caution Tags Operator Aids

Information 'MP 7200.RST.004 Rev. 5 Page 54 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM

'SYSTEM READINESS REVIEW PROGRAM Pages:

Attachment 7 (SYSTEM WALKDOWNGUIDELINES) 54- 61 1.0 PURPOSE

'his walkdown guideline is to be used as a reference while conducting the Expanded System Readiness Review Team (or individual) walkdowns. The completed walkdowns, during the initial SRR, should be taken into account in setting the scope of the ESRR walkdowns.

2.0 GENERAL METHODS 2.1 Define the purpose of the walkdown,'areas to be visited/observed, roles of the individual team members, and assistance from Health Physics or other departments to access areas.

2.2 Plan the walkdown execution and implementation. Pre-define how the walkdown will assess the conformance of the plant with design and licensing basis requirements (For example, piping and component configuration, electrical separation, etc.). Ensure remote electrical cabinets, tanks, etc. and instrumentation including control Room and Remote Shutdown Panel instruments are included in the walkdown plan. Contact Health Physics supervision to obtain any special ALARAreviews prior to actual system walkdowns.

2.3 Brief the team on the purpose and plan.

2.4 Conduct the walkdown. Focus the team on observation of equipment. Work independently and discuss concerns for clarity. Take concise and accurate notes to quantify and describe findings in sufficient detail to prevent having to walkdown the item twice.

2.5 Conduct a formal post walkdown briefing. Review the notes, discuss issues and document the results on the ESRR Assessment forms, entering the data into the ESRR Assessment database. Identify any impact on equipment or system operation. Immediate concerns are to be identified to the engineering supervisor and the operations Shift Manager.

2.6 Identify the items that need to be completed for the system to meet its intended design function. Assess each item against the restart criteria, Attachment 8. The items are to be documented for disposition and tracking in SIDS.

~

Information PMP 7200.RST.004 EXPANDED SYSTEM READINESS REVIEW PROGRAM Rev. 5, Page 55 of 101 SYSTEM READINESS REVIEW PROGRAM Pages:

Attachment 7 (SYSTEM WALKDOWNGUIDELINES) 54- 61 3.0 GUIDELINES 3.1 The team (lead by the System Manager) is to outline the system walkdown strategy. Key system components and system concerns are to be identified.

3.2 The team is to identify necessary operational or plant configuration drawings to accompany the team during the walkdown.

3.3 Throughout the walkdown, the team is to function as a cohesive unit, maintaining focus on either individual system coinponents or specific system areas.

3.4 The walkdown is to focus on operability issues as well as conformance with-system design configuration and design basis. Other conditions including potential impact on equipment reliability should be noted during the walkdown.

3.S Each Team member is expected to record detailed notes identified during the walkdown. Any areas of the system that could not be walked down shall be noted and justified in the walkdown report.

3.6 Examples of team focus areas include:

Condition of snubbers, pipe supports, hangers and fasteners Condition and placement of coatings and insulation Evidence of corrosion Evidence of boric acid or boric acid buildup especially on carbon steel components, and material wastage Unauthorized modifications, partial modifications or temporary modifications not in accordance with station programs Surface condition of visible structural welds Condition of barrier or penetration seals Use of unauthorized chemicals on components

Information PMP 7200.RST.004 Rev. 5 Page 56 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM READINESS REVIEW PROGRAM Pages:

(SYSTEM WALKDOWNGUIDELINES) 54- 61

~ Evidence of bolt torque relaxation.

Evidence of discoloration on relays, cable insulation or electrical components Condition inside electrical cabinets Unauthorized or expired scaffolding in unauthorized locations or impacting equipment performance Hoses or other connections for vents or drains Presence of abandoned equipment not clearly labeled 3.7 The following is a general list of electrical and mechanical equipment physical plant inspection items:

3.7.1 Electrical Panels Equipment

~ -

Identify missing water plugs or holes/openings in cabinets (water or moisture intrusion can degrade or damage equipment).

~ Identify missing or loose bolts or thumb screws (ifmissing can violate seismic evaluation and it is not good work practice).

~ Identify open doors or back panels (ensure properly closed and latched, otherwise can violate seismic evaluation or allow dirt,

,,water, etc., to enter panel).

~ Identify mis-positioned breaker switches (anything that is different).

Identify improper labeling on key component breakers/switches (ensure that they are accurate and legible per controlled drawings; also includes modules, relays, conduit).

Identify dirt or debris covering cooling gratings or filters (if blocked, can prevent cooling and cause heat buildup and subsequent equipment degradation).

Information PMP 7200.RST.004 Rev. 5,', Page 57 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM READINESS REVIEW PROGRAM Pages:

(SYSTEM WALKDOWNGUIDELINES) 54-61 Feel panels and equipment enclosures where appropriate to check for excessive heat buildup (can be an indication of degraded equipment; initiate request for themography check).

Check cable trays. (Cable should not be hanging outside of cable tray; can overstress cable tray).

Check cables and conduit for degradation (cracked, brittle, chafed, bend radius, etc.).

Check MCCs overall for anything that is different.

Note any deficiency tags, especially old tags not being worked.

These may need increased priority or have had work complete'd but the tags have not been removed.

~ Check for any abnormal sounds or smells coming from the, cabinet (may indicate degraded equipment)

~ Verify equipment-grounding cable is connected and intact.

~ Look at general materiel condition of cabinet (rust, dirt, consider qualitative impact on heat transfer).

~ Inspect seismic supports and trays.

~ s Inspect overall condition of terminal strips and mechanical connections (lug landings).

Inspect conduit and junction boxes for external damage, loose conduit connections and missing parts and fasteners.

~ Inspect solenoid valves and motor covers for evidence of damage or equipment degradation.

3.7.2 Mechanical Components

~ Identify any abnormal sounds or smells coming from pump or motor operation.

Bearing housings and motors and pumps are to be inspected for signs of excessive heat or, vibration.

f Information PMP 7200.RST.004 Rev. 5 Pago 58 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM 7

SYSTEM READINESS REVIEW PROGRAM Pages:

'ttachment (SYSTEM WAI KDOWN GUIDELINES) 54- 61

~ Look at general material condition of pump or motor for steam, oil, water leaks, proper levels in oil reservoirs or sight glasses (and properly marked), missing insulation, proper conduit installation.,

Identify pinned hangers.

Inspect system gauges for proper operation or typical values.

Look for pump rotation or reverse rotation if part of a dual train common header system (could indicate check valve degradation or isolation valves leaking by)

Identify dirt or debris covering cooling gratings or filters (if blocked can prevent cooling and cause heat buildup and subsequent equipment degradation)

Note any deficiency tags, especially old tags not being worked. (These may indicate a need for increased priority or they may be an indication that the work was completed but that the tags have not been removed.)

Check equipment/equipment skid/foundation bolting., (Are all bolts present with proper thread engagement'?)(minimum of flush or better)

~ Review trends of parameters on key system equipment; visually inspect identified equipment'with degraded

.performance.

. ~ Visually inspect for old leak repair fittings, ensure Temporary Modifications exist to restore components with leak repair fittings.

~ Inspect equipment labeling/tags (ensure they are accurate and legible per controlled drawings).

Information PMP 7200.RST.004 Rev. 5 Page 59 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM READINESS REVIEW PROGRAM Pages:

(SYSTEM WALKDOWNGUIDELINES) 54- 61 3.8 The following list contains material conditions indicating equipment operability issues:

3.8.1 Operability Issues Leaks (water, steam, oil, air-packing, flanges, rust on components or floor).

Lubrication (sight glasses, bull's eyes, grease cups, grease fittings, valve stems).

Handwheels/valve operators (missing, key or pin missing, unlocked, not labeled).

H Filters, screen or louvers (clogged, dirty, missing).

Instruments or gauges (out of calibration, inoperable, bent pointers).

Drains or drain holes (clogged, blocked, full, screens or grating missing).

Lines or pipes (loose, unbracketed, vibrating, insulation missing or damaged, not properly sloped).

Fasteners/bolts (loose, stripped, corroded, missing).

Indicating lamps (missing, burned out, missing covers).

Control room annunciators.

Panels (covers missing, bolt missing or not tightened, dirt and debris inside).

Area lighting (bulbs missing or burned out, inadequate to support activities).

Look for consistency between similar parameters.

Packing (bottomed out, out of adjustment, dirty or rusted glands).

Information PMP 7200.RST.004 Rev. 5 Page 60 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM READINESS REVIEW PROGRAM Pages:

(SYSTEM WALKDOWNGUIDELINES) 54- 61

~ - Cables or leads (unsecured, worn or frayed insulation, improper terminations).

Motors or generators (dirty, brush rigging pigtails broken, carbon dust, excessive noise or vibration, ground straps loose or missing).

Preservation (rust, corrosion, missing or damaged insulation or

-

lagging).

Check valves (oscillating lever, banging, stuck open).

MOVs (lubricant leaks, missing T-Drains).

Valves (dried grease caked on stem, packing or stem leaks, bent stem).

3.9 The following is a general list of additional inspection items that apply to both mechanical and electrical equipment:

3.9.1 Mechanical or Electrical Equipment

~ Identify inadequate or degraded structural components.

~ Inspect system piping for evidence of water hammer, severe transients, or improper venting. Damaged supports, base plate grouting, anchors (pulled-out or deformed) are to be identified for further root cause analysis.

~ Inspect for,unauthorized loads supported from cable trays, coiiduits or piping systems,

~ Identify undocumented system modifications.

~ Identify damaged heat trace and damaged or missing insulation.

Note piping exhibiting cyclical vibration for possible high cycle fatigue concerns.

Safety postings, radiological postings (properly positioned, legible and understandable).

4

Information PMP 7200.RST.004 Rev. 5 Page 61 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM READINESS REVIEW PROGRAM Pages:

..Attachment 7 (SYSTEM WALKDOWNGUIDELINES) 54- 61 3.10 The System Manager is to ensure that team members record identified walkdown issues in Walkdown Reports, and during Phase 1 on the Attribute Assessment forms. The System Manager is responsible to ensure that any discrepancies have appropriate follow-up corrective actions initiated to resolve any identified issues.

Information ~ PMP 7200.RST;004 Rev. 5 Page 62 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 8 CRITERIA FOR WORK INCLUDED IN . Pages:

RESTART SCOPE 62-68 NOTE CHANGES TO THE RESTART CRITERIA REQUIRE THE APPROVAL OF THE SENIOR MANAGEMENTREVIEW TEAM (SMRT)

1. Review the open corrective action item against the Restart Screening Criteria. The Restart Screening Criteria is used to identify scope of items reviewed during Phases 1, 2, and 3. If none of the criteria apply, then the action item is not applicable to the restart effort. If the restart screening criteria applies the System Manager should determine when the action item must be completed to support safe and event free restart and reliable power operation. Program owners and functional area managers (or their designees) shall also follow the guidance in this attachment for scoping non system-specific programmatic and functional area SIDS items when directed by the Director of Restart. In this capacity; these owners/managers/designees function, in effect, as the System Manager for these items.

Restartl Activities required to be completed prior to entering Startup/Power Ascension of Unit 1. This classification includes necessary restart and power ascension testing activities Restart2 Activities required to be completed prior to entering Startup/Power Ascension of Unit 2. This classification includes necessary restart and power ascension testing activities.

Post Restartl Activities which should be completed on a schedule consistent with the Unit 1 normal plant work controls process.

Post Restart2 Activities which should be completed on a schedule consistent with the Unit 2 normal plant work controls process.

Not Applicable Activities that are not required to be completed.

2. Enter descriptive text that describes a specific issue in the ISSUES box. This is a searchable text field of up to 255 characters and is designed to assist the System Managers in readily retrieving information on associated issues. Some examples are packing leaks, oil leaks, housekeeping, etc.

Information PMP 7200.RST.004 Rev. 5 Page 63 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM CRITERIA FOR WORK INCLUDED IN Pages:

Attachment 8 RESTART SCOPE 62-68 3 Ifthe issue is system-specific but also is related to an existing station program, consider identifying the PROGRAM by scrolling, then selecting the most appropriate program source and dragging the appropriate program(s) into the RELATED PROGRAM box.

This information may help program owners identify programmatic weaknesses.

Examples of program s'ources include High Energy Line Break, Appendix R, Station Blackout, etc. For new items placed in the "No system entered" bin in SIDS, the ESRR group will review the item and assign it to a system or programmatic and/or functional area. Ifa needed program is not listed, contact the SIDS data base coordinator.

Information PMP 7200.RST.004 Rev. 5 Page 64 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 8 CRITERIA FOR WORK INCLUDED IN Pages:

RESTART SCOPE 62-68

4. Identify the applicable Restart Screening Criteria as outlined in this attachment. Enter this criteria in SIDS by scrolling and selecting the most appropriate criteria (e.g.

RESTART1A, RESTART2A, RESTART2B, etc.).

5. Identify the applicable mode restraint for the item by scrolling, then selecting the appropriate mode (e.g., 1, 2, 3, 4, etc.).

6 Complete the INITIALCOMMENT field in the INITIALREVIEW screen. The comment field should contain specific reasons for the item being included or excluded from the restart effort. Ensure that the information is accurate and concise, technically justifying from a design basis view point, the SCOPE and RESTART CRITERIA selected. The COMMENT field must be comple'ted prior to System Manager approval.

Note: The FINAL COMMENT field on the FINAL REVIEW screen is to be completed prior to the final readiness review presentations. This field is to justify that the work completed will support restart readiness.

7. During Phases 1, 2, and 3, the System Manager will approve SIDS items as Restartl, Restart2, Post Restartl, Post Restart2, or N/A. The System Manager will signify his approval of the scope by "Approving" the scope and justification comments in the Initial System Manager Approval Box in SIDS. Later, during Phase 3, if a restart item is not completed, the System Manager will denote the item as an "Exception" in the Final System Manager Approval Box in SIDS. If an item is satisfactorily completed, the System Manager will denote his "Concurrence" in the Final System Manager Approval Box in SIDS.

8. During Phase 4, items will be scoped as WCP or RESTART1 or RESTART2.

9. Additional information is available in the Systems Indexed Data Base Systems Operator's Manual.

J Information PMP 7200. RST.004 Rev. 5 Page 65 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 8 CRITERIA. FOR WORK INCLUDED IN Pages:

RESTART SCOPE 62-68 RESTART SCREENING CRITERIA Issues will be evaluated against criteria 1 through 9. Ifcriteria 1 through 7 do not apply, then categorize the issue using criteria 8 or 9.

Issues shall be resolved prior to restart if they are:.

1) Nuclear Safety Required to address a nuclear safety issue.

Issues may be classified as follows:

a) Items that could result in significant personnel radiation exposure, radioactivity release or effluent discharge, in excess of limits.

b) Reduces cumulative deficiencies, backlogs or conditions that, in the aggregate, are evaluated to have significant negative impact on nuclear safety. (Not applicable to individual work issues).

2) Operability Required to address an operability issue.

Issues may be classified as follows:

a) Eliminates an existing component failure, deficiency, or condition that could result m operation in, or entry to, an LCO action statement if left uncorrected.

b) 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.

c) Would increase the risk to operation or safety associated with performing a surveillance.

Information 'MP 7200.RST.004 Rev. 5 Page 66 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM CRITERIA FOR WORK INCLUDED IN Pages:

'ESTART SCOPE 62- 68 d) Testing or retesting that must be performed to certify'system or component operability, including testing on systems or components during power ascension that result in breeching a system regardless of the work being classified as a restart issue or not.

e) Reduces cumulative deficiencies, backlogs or conditions that, in the aggregate, are evaluated to have significant negative impact on operability. (Not applicable to individual work issues).

3) Design Basis Required to restore acceptable design margin or conformance. with the design basis.

Issues may be classified as follows:

a) Corrects design basis deficiencies; i.e., deficiencies in safety-related or technical specification equipment not in conformance with design basis documents.

4) License and Licensing Basis Required to resolve unreviewed safety questions (USQs) or to restore conformance with the license, license conditions or licensing basis.

Issues may be classified as follows:

a) Restores licensing basis deficiencies to conforming conditions.

b) TechmcaI Specification changes to support safe plant operation.

5) Licensing Commitments Required to meet restart licensing commitments such as A/E inspection and related programmatic issues, and confirmatory action letter issues.

Issues may be classified as follows:

a) Resolves existing deficiencies or conditions that would result in the failure to meet a license requirement or a restart commitment to an outside agency.

Information PMP 7200.RST.004 Rev. 5 Page 67 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM CRITERIA FOR WORK INCLUDED IN Pages:

RESTART'SCOPE 62-68

6) Configuration Management Required to address an organizational, programmatic, or process deficiency that could prevent maintenance of adequate design margins or conformance with the design or licensing basis.

Issues may be classified as follows:

a) 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.

7) Reliability Required to address significant equipment material condition deficiencies singly or in aggregate; or repetitive failures that could affect safety system availability, impact plant reliability, or reduce the ability of operators to operate the plant safely.

Issues may be classified as follows:

a) Reduces cumulative deficiencies, backlogs or conditions that, in the aggregate, are evaluated to have significant negative impact on safety system availability or reliable plant operation. (Not applicable to individual work issues).

b) Restores degraded critical components or conditions that could result in a plant transient, power reduction or shutdown.

c) Resolves"conditions that have resulted in repetitive safety system or equipment failures.

Information PMP 7200.RST.004 Rev. 5 . Page 68 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM CRITERIA FOR WORK INCLUDED IN Pages:

Attachment 8 RESTART SCOPE 62-68 Issues that are not classified as restart should be classified as follows:

8) Post Restart Issues a) Issue can be scheduled for a subsequent outage.

b) Issue can be readily worked on line, does not affect safe and reliable operation, does not represent a significant challenge to Maintenance Rule Goals or LCO allowed outage time, and does not impair operations necessary to perform surveillance or monitoring.

c) Issue is classified as minor maintenance, or housekeeping, and does not affect plant operation.

d) Issue is an administrative issue.

e) Issue is a documentation deficiency that has no safety impact.

9) Industrial Safety Concern NOTE: Industrial safety concerns will not be classified as "restart" because the priority and resolution of these concerns will be addressed under the established work control process priorities and scheduling. Although an industrial safety issue is not classified as restart, it will be worked promptly, commensurate ~

~td with the safety risk.

Information PMP 7200.RST.004 Rev. 5 Page 69 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM PHASE 2 OUTAGE SCOPE APPROVAL Pages:

Attachment 9 PROCESS 69-69 NEW WORK SYSTEM MANAGER ENGINEERING SUPERVISOR All other new work Field work items-e.g. AR s/JO s System Readiness Outage Scope Review Board Management Team (See Note)

SIDS update to NPM Scheduling NOTE: SRRB (or subcommittee thereof ) reviews the scoping of these items separately.

SIDS is then updated to reflect SRRB comments by the System Manager.

Information PMP 7200.RST.004 Rev. 5 Page 70 of 101

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EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 10 RESTART REQUIRED SCOPE DEFERRAL Pages:

FORM 70- 70 UNIT: DATE:

SYSTEM:

DOCUMENT TYPE:

(e.g., Condition Report, Action Request)

KEY I. D:

(e.g., Condition Report or Action Request Number)

Item

Description:

Initial Technical Justification for Restart Scope Designation (ensure the original basis for scoping the item as required for restart is addressed);

Technical Justification for Restart Deferral:

New Scheduled Completion Date:

(Scope Addition/Deletion form attached if applicable)

Originator Date:

System Manager Date:

Designated Ops. Rep. Date:

Engineering Supervisor Date:

Nuclear Licensing Manager/

Director of Regulatory Affairs Date:

System Engineer Manager Date:

Date:

PORC Mtg. ¹ Date:

Information PMP 7200.RST.004 Rev. 5 Page 71 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM EXPANDED SYSTEM READINESS REVIEW Pages:

. Attachment 11 CLARIFICATIONSHEET 71-71 S stem Mana er A royal Concur Item closed and work completed satisfies restart requirements, or for those post restart items that are not included in the aggregate impact.

Except Open restart items (including those items that are "work complete" but not administratively closed), or items that are closed but do not satisfy restart requirements..

Post Restart Deferred Denoted on items associated with a component that has two (2) or more post restart deferred items, excluding PM post restart items.

Restart Required Deferred Denoted on items with deferred scope that were initially approved, as restart required. These items must be accompanied by a Restart Required Scope Deferral Form (Attachment 10).

Information PMP 7200.RST.004 Rev. 5 Page 72 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 12 INITIALEXPANDED SYSTEM READINESS Pages:

REVIEW REPORT 72-74 INITIALEXPANDED SYSTEM READINESS REPORT COVER SHEET SYSTEM TITLE SYSTEM REVIEWERS System Manager Signature / Date Operations Representative

Signature./ Date Licensing Representative ~

Signature / Date Engineering Supervisor Signature / Date ESRR Manager/Coordinator

. Signature / Date System Readiness Review Board.

Signature / Date Plant Operations Review Committee Chairman, Signature / Date, PORC MTG. ¹

~ These signatures maybe obtained by routing the report to both individuals simultaneously. Retain copies of both signatures with the original of the report in the SRRB meeting minutes.

'

Information PMP 7200.RST.004 Rev. 5 Page 73 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 12 INITIALEXPANDED SYSTEM READINESS Pages:

REVIEW REPORT 72-74 INITIALEXPANDED SYSTEM READINESS REVIEW REPORT FORMAT EXECUTIVE

SUMMARY

1.0 INTRODUCTION

1.1 Purpose 1.2 Scope and Approach (Include specific identification of the system's safety and accident mitigation functions) 2.0 RESULTS AND CONCLUSIONS 2.1 Summary of Attribute Assessments 2.2 Suimnary of Review of SIDS Items 2.3 Summary of Open Items 2.4 Observations and Conclusions (including recurring items judged to need further extent of condition determination) (see step 4.3.10a) 3.0 ATIRIBUTEASSESSMENTS 3.1 Assessment Matrix 3.2 .-

Attribute Assessments and review of system functions.

3.3 Discrepancies

' "

4.0 WALKDOWNRESULTS 4.1 Walkdown Scope 4.2 Observations 5.0 REVIEW OF SIDS ITEMS 5.1 Review of Open Items (Summary Information)

0 Information PMP 7200.RST.004 Rev. 5 Page 74 of 101

~,

EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 12 INITIALEXPANDED SYSTEM READINESS Pages:

REVIEW REPORT 72- 74 5.2 Revie'w of Closed Items (Summary Information)

6.0 REFERENCES

6.1 ENCLOSURES

Enclosure 1: Attribute Assessment Forms Enclosure 2: Restart Items (SIDS)

Enclosure 3: Post-restart Open Items (SIDS)

Enclosure 4: Review of Closed Items From SIDS Enclosure 5: System Boundaries Enclosure 6: Walkdown Plan 6.2 FIGURES AND TABLES Figure 1: System Boundaries Table 1: Final System Readiness Review Assessment Matrix Table 2: Attribute Assessment Summary Table 3: Assessment Discrepancies Recommended for Corrective Action Prior to Restart Table 4: Assessment Discrepancies Recommended for Closure Post Restart

Information PMP 7200. RST.004 Rev. 5 Page 75 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM A~ichment 13 FINAL EXPANDED SYSTEM READINESS Pages:

REVIEW REPORT 75-77 FINALEXPANDED SYSTEM READINESS REPORT COVER SHEET SYSTEM TITLE DATE SYSTEM REVIE%ERS System Manager Date Operations Representative ~ Date Licensing Representative ~ Date Engineering Supervisor Date ESRR Manager/Coordinator Date System Readiness Review Board Date Plant Operations Review Committee Date PORC MTG. ¹

~ These signatures maybe obtained by routing the report to both individuals simultaneously. Retain copies of both signatures with the original of the report in the SRRB meeting minutes.

A< g L Information PMP 7200.RST.004 Rev. 5 Page 76 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 13 FINAL EXPA'NDED SYSTEM READINESS Pages:

REVIEW REPORT 75-77 FINAL EXPANDED SYSTEM READINESS REVIEW REPORT FORMAT 1.0 OVERVIEW 1.1 Summary of items closed since the initial report issuance 91-18 Operability Determinations (list each item)

Engineering Evaluations (list each item)

DCPs (list each item)

I Action Requests (list each item)

Condition Reports (list each item)

NRC Commitment Data Base items (list each item)

Operator Workarounds (list each item)

Outage Required PMs 2.0 OPEN ITEM REVIEW 2.1 Items 91-18 Operability Reviews (list each item)

Engineering Evaluations (list each item)

DCPs (list each item)

Work Requests (list each item)

Condition Reports (list each item)

Commitment Data Base (list each item)

Operator Workarounds (list each item) k

'I Information PMP 7200.RST.004 "

Rev. 5 Page 77 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 13 FINAL EXPANDED SYSTEM READINESS Pages:

75-77

,

REVIEW REPORT 2.1 Items (Continued)

Outage Required PM's that will become overdue prior to next planned outage 2.2 Restart Scoping 2.3 Schedule for Resolution of Open Items 3.0 DESIGN AND LICENSE BASIS ISSUES

SUMMARY

Explain the significance of each issue (one or two sentences on safety, risk, or system operability/reliability impact.

Discuss what plans(s) is in place for resolution of each issue.

Include when the issue is scheduled to be resolved.

4.0 WALEDOWN 4.1 Walkdown purpose and scope 4.2 Walkdown Team 4.3 Walkdown Results 4.4,Conclusions 4.5 Restart Scoping 5.0 AGGREGATE IMPACT OF DEFERRED WORK

Attachment:

Marked up drawings showing components with multiple (two or more) Post-restart or restart deferred work items.

Information PMP 7200.RST.004 Rev. 5 Page 78 of 101

'XPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 14 EXPANDED SYSTEM READINESS Pages:

REVIEWS INTEGRATED RESULTS 78-82 ESRR Program Coordinator Date ESRR Program Manager Date Director, Engineering Restart Date System Readiness Review Board Date Plant Operations Review Committee Date PORC Mtg. ¹

Information PMP 7200.RST.004 Rev. 5 Page 79 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Attachment 14 EXPANDED SYSTEM READINESS Pages:

REVIEWS INTEGRATED RESULTS 78- 82 EXPANDED SYSTEM READINESS REVIEWS INTEGRATED RESULTS FORMAT

1.0 INTRODUCTION

AND PURPOSE 1.1 Introduction 1.2 Purpose 2.0 SCOPE AND STRUCTURE FOR LEVEL 1 ESRRs 2.1 Overall Approach and Scope 2.2 System Prioritization 2.3 Structure of Level 1 ESRR Teams 2.4 Vertical Slice Methodology 2.5 Screening of Open Items for Restart Requirements 2.6 Reviews and Self-Assessments 3.0

SUMMARY

OF PHASE 1 RESULTS 3.1 Vertical Slice Results and Characterization of Findings 3.2 Screening of Open Items 3.3 Walkdown Results 4.0 ASSESSMENT OF RESULTS BY TOPIC AREA 4.1 Lessons learned to be included in Level 2 ESRR 4.2 Identification of Potential Programmatic Issues

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REVIEWS INTEGRATED RESULTS 78-82

5.0 CONCLUSION

S 5.1 System Readiness 5.2 Potential Programmatic Issues

6.0 REFERENCES

APPENDICES A RESTART ISSUES, SELECTION/SCREENING CRITERIA B EVALUATIONOF DISCREPANCIES BY TOPIC AREA Topic Area 1: Electrical Calculations and Analysis Topic Area 2: I&C Calculations and Analysis Topic Area 3: Mechanical & Structural Calculations and Analysis Topic Area 4: Accident Analysis Topic Area 5: Drawings Topic Area 6: Logic Diagrams Topic Area 7: Configuration Management Topic Area 8: Specifications Topic Area 9: DBD Topic Area 10: Change Documentation/50.59 Reviews Topic Area 11: Temporary Modifications/Bypasses Topic Area 12: FSAR Review Topic Area 13: TS and Bases

Information PMP 7200.RST.004 Rev. 5 Page 81 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM EXPANDED SYSTEM READINESS Pages: 4 REVIEWS INTEGRATED RESULTS 78-82 Topic Area 14: Licensing Commitments Topic Area 15: Notices / Bulletins/Generic Letters Topic Area 16: Procedures Topic Area 17: Operator Workarounds Topic Area 18: Industry Operating Experience Reviews Topic Area 19: Maintenance Procedures Topic Area 20: Vendor Technical Information Topic Area 21: Preventive Maintenance Topic Area 22: Surveillance and Periodic Tests and Inspections Topic Area 23: ISVSection XI IST Topic Area 24: As-Built Verification Topic Area 25: Control Room Drawings Topic Area 26: Surveillance Programs Topic Area 27: Corrective Actions

~P Topic Area 28: QA Audits and Self Assessments Topic Area 29: Training Lesson Plans Topic Area 30: Open Items (Backlog)

Topic Area 31: Strategy Documents

Information PMP 7200.RST.004 Rev. 5 Page 82 of 101 EXPA'NDED SYSTEM READINESS REVIEW PROGRAM Attachment 14 EXPANDED SYSTEM READINESS Pages:

REVIEWS INTEGRATED RESULTS 78-82 C GROUPING OF ESRR-IDENTIFIED ITEMS BY TOPIC AREA FIGURES 2.1 Graded Approach for Enh'anced System Readiness Review 2.2 Typical Topic Areas for Enhanced System Readiness Review Vertical Slices 2.3 Enhanced System Readiness Review Plan 2.4 Level 1 Enhanced System Readiness Reviews 2.5 Typical System Assessment Matrix 4.1 Topic Review Sutmnary - Level 1 Systems Checks and Discrepancies 4.2 Topic Revjew Summary - Level 1 Systems Discrepancies as Percent of Checks 4.3 Issues by Topic Areas - Level 1 Systems by severity-4A Issues by Topic Area - Level 1 Systems (Restart Recommended Issues Only)

TABLES 3-1 Summary Statistics for Level 1 System Reviews 3-2 Summary of Areas Covered During the Walkdowns

Information PMP 7200.RST.004 Rev. 5 Page 83 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Pages:

Attachment 15 SYSTEM WALKDOWNREPORT 83-83 Date of Walkdown: .

System Manager/Team Leader:

~Setem:

Pu ose of Walkdown:

Provide a brief description of the purpose of the walkdown.

Walkdown Sco e:

Provide an overall synopsis as to the scope of the walkdown, primary objectives, time spent'n the walkdown, total number of all deficiencies noted as well as noting if any operability concerns were noted.

Walkdown Tea Provide a listing of the walkdown team members as well as their respective organizations.

Walkdown Results:

Provide an overall characterization as to the items identified, and safety or operability concerns, etc.

==

Conclusions:==

Provide an overall assessment of the system condition based on observations. Summarize any specific need for improvements and all follow-up actions being pursued.

Information PMP 7200.RST.004 Rev. 5 Page 84 of 101 EXPA'NDED SYSTEM READINESS REVIEW PROGRAM Attachment 16 SYSTEM READINESS AFFIRMATION Pages:

REPORT 84- 84 1.0 THE READINESS AFFIRMATIONREPORT WILLINCLUDE THE FOLLOWING INFORMATION 1.1 Current system License Change Request(s).

1.2 Current operator workarounds.

1.3 Current corrective actions required of control room equipment.

1.4 Currently installed T-Mods.

1.5 Active operability determinations and JCOs, with the 10CFR50.59 for each OD or JCO.

1.6 The remaining open "Exceptions" items and any "Exceptions" identified during the affirmation process. Exceptions are remaining open restart required items.

1.7 An Operations priorities list compiled from or identical to the Focus List or Operations Priorities Addendum List (but not necessarily limited to these lists) for the system.

1.8 Reference Initial Expanded System Readiness Review Report 1.9 Reference Final Expanded System Readiness Review report.

1.10 Reference the system tests per the System Test Plan.

0 Information PMP 7200.RST.004 Rev. 5 Page 85 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM ASSESSMENT MATRIX Pages:

Figure 1 MAJOR TOPICS 85-94 SYSIKM ASSESShKNT hIATRIX MAJOR TOPICS DESIGN BASIS LICENSING OPERATIONS mi~~~NCP. SURV 'ROGRAMS, PHYSICAL DOCUMENTS PLANT PROCESS 4 PROCEDURES 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 K K ASSESShKNT ATTRIUTES 0 0

Information PMP 7200,RST.004 Rev. 5 Page 86 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM ASSESSMENT MATRIX Pages:

Figure 1 Addendum MAJOR TOPICS 85-94 OVERVIEW The following guidance for each of the 31 major topics in Figure 1 is provided regarding the types of documents and sources of information to be used and to provide a consistent definition of the topic areas for grouping and documenting the results. Individual reviewers will use their experience and that of the ESRR Team to determine the specific documents and sources of information to be assessed. Completed scope of the previous System Readiness Reviews should be taken into account.

DESIGN BASIS Electrical Calcs/Analysis:,Calculations related to motors, electrical devices, circuits, and associated power supplies for system components shall be reviewed. The reviews should assess the appropriateness of design inputs, assumptions, consistency with as-built configuration, and general approach. Also, calculation results should be verified for appropriate use in other design basis documents. The potential effect of modifications on the emergency electrical load calculation, including load sequencing, should be considered. In addition, fuse coordination shall be addressed against the requirements of IEEE 308.

2 I&C Calcs/Analysis: Calculations related to the performance, set points, and stability of I&C components and loops for system components shall be reviewed. The scope of the reviews should be

. similar to the electrical calculations. In addition, reference 6.5 identifies a potential concern with instrument uncertainty calculations, such as due to dynamic fiow effects, and with lack of trending of instrument drift and use of unverified drift values provided by the equipment vendors.

3 Mech and Struct Calcs/Analysis: Calculations related to hydraulics, heat transfer, equipment/support loads, equipment/pipe stresses, and other mechanical performance issues related to system components shall be reviewed. The scope of the reviews should be similar to the electrical calculations.

ot' Information PMP 7200.RST.004 Rev. 5 Page 87 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM ASSESSMENT MATRIX Pages:

Figure 1 Addendum MAJOR TOPICS 85 -94

4. Accident Analysis: Analysis of UFSAR Chapter 14 events shall be reviewed for assumptions regarding system configuration, performance and conditions.

5. Drawings: Controlled drawings documenting system design, configuration, layout, and conformance to programs (e.g.,

Appendix R, testing, and EQ) shall be reviewed for system design basis information and system interaction/dependency information.

Drawings that are excluded from this topic are logic diagrams (covered in Topic 6), Control Room drawings (covered in Topic 25), and vendor drawings (covered in Topic 20).

6. Logic Diagrams: The logic diagrams shall be reviewed for system design basis information and system interaction/dependency information.

7. Configuration Management: Cross-referenced documents shall be verified to be current, applicable, and appropriate. In particular, ESRR teams shall specifically review several input changes looking for a lack of integration between calculations, accident analysis assumptions, design values, design basis documents, system description and normal and emergency operating procedures.

Additionally, the facility data base should be checked for accuracy and consistency with design requirements.

8. Specifications: Equipment design, procurement, and installation

.specifications shall be reviewed for consistency of system design basis information and for adherence to code and safety requirements. General design specifications shall also be reviewed for system design basis information.

9. DBD: Related design basis documents shall be reviewed for system design basis requirements, identification of possible cross-referenced documents, and appropriate applicability. Potential vulnerabilities include identification of and compliance with single failure criteria. Adequate closure of open items identified during preparation of the DBDs should be considered. Based on the results in reference 6.5, this topic area should be a focus area for the ESRR.

Information ', PMP 7200.RST.004 Rev. 5 Page 88 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM ASSESSMENT MATRIX "Pages:

MAJOR TOPICS 85 -94

10. Change Documents/50.59 Reviews: Change documents, including DCPs, Component Evaluations (CEs) and UFSAR changes, shall be assessed for completeness, consistency with the system safety and accident mitigation functions as defined in the design and licensing basis, appropriate consideration of interdisciplinary impact/input, and effective follow through (changes made or posted against the appropriate documents). 50.59 screens and 50.59 safety reviews shall be reviewed to assess whether the change may have resulted in a current plant configuration or operation that is outside the design or licensing basis, Cook Plant has, in the past, not performed some 50.59 screens when required because station personnel did not recognize that they were changing the facility as described in the UFSAR. As part of the ESRR, teams should review past 50.59 screens associated with change documents being reviewed to ensure that an excessively liberal interpretation of the words "system as described in the UFSAR" was not used. See NEI 9647 for additional guidance and current industry standards.

L a el+

Information 'PMP 7200.RST.004 Rev. 5 Page 89 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Addendum SYSTEM ASSESSMENT MATRIX Pages:

Figure 1 MAJOR TOPICS 85-94

11. Temporary Modifications/Bypasses: Temporary modifications and "bypasses" shall be reviewed to verify that they were evaluated against appropriate design basis information and do not result in an unreviewed safety question. Based on the results of reference 6.5, "Bypasses" should be a focus area for the ESRR. Additionally, teams should be alert for engineering evaluations, action requests, partially installed modifications, and other changes to ensure that necessary screenings were done in each case, Cook Plant has identified 23 specific processes with a potential to bypass the 50.59 process as follows:

Engineering Specifications ~ Design Change Addenda Action Request/Job Orders ~ Setpoints Drawing changes ~ DCDIRs Operability determinations ~ Technical data books Technical Direction Memos ~ PMI-5023 addressing plant NPM (Engineering) fabrication and repairs Evaluations ~ Dedication Plans Mechanical Engineering Memo ~ Old clearances/Caution Tags Electrical Engineering Memos ~ Open Items Log Design Change Determination ~ Work Arounds/Watch List Condition Report ~ Temporary Operator Aids Receipt Inspection Practices ~ Permanent Operator Aids Design Standards These items should be reviewed in assessing the health of the 50.59 process for the system. Also, the temporary modification shall be assessed to assure the duration is not excessive. 50.59 applicability evaluations and 50.59 reviews shall be reviewed to assess whether the temporary modifications may have resulted in a current plant configuration or operation that is outside the regulatory design basis or licensing basis.

Abandoned Equipment without a 50.59 should also be considered.

Information PMP 7200.RST.004 Rev. 5 Page 90 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM ASSESSMENT MATRIX Pages:

Figure 1 Addendum MAJOR TOPICS 85-94 LICENSING DOCUMENTS-

12. UFSAR Review: Chapters related to the system, interfacing systems (e.g., power distribution, I&C, and support systems),

accident analysis, and applicable design criteria shall be reviewed for regulatory design basis and licensing basis information. Scope of this review should take into account the ongoing UFSAR validation effort (which was initially restricted to 21 systems of the original SRR). Pending UFSAR changes should be assessed and selected UFSAR questions and requirements should be validated against installed equipment specifications and operational/test procedures as applicable.

13. TS/Bases: LCOs, Surveillance requirements, and their bases for the .

system and its components shall be reviewed for regulatory design basis and licensing requirements Other appropriate sections (e.g.,

for interfacing systems, EQ-related, and containment isolation-related) should also be reviewed for system/component regulatory design requirements.

14. Licensing Commitments: Open items from NRC inspections, commitments in the license (and not in the UFSAR or TS), and other commitments made to the NRC by docketed correspondence shall be reviewed for additional licensing basis requirements. For example, reference 6.5 notes that not all systems may meet the criteria of the response to LER 97-021-01 regarding single failure interpretation. A list of system specific licensing commitments will be provided to the ESRR by the Licensing Basis Review Group.

15. Notices/Bulletins/Generic Letters: NRC generic communications and evaluations and responses to them related to the system shall be reviewed for additional regulatory design basis requirements and information.

~ t ~

Information PMP 7200.RST.004 Rev. 5 Page 91 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM ASSESSMENT MA'i'RIX Pages:

Figure 1 Addendum MAJOR TOPICS 85 -94 OPERATIONS

16. Procedures: Operating and emergency operating procedures related to the system shall be reviewed for conformance with design basis information. Based on the results of reference 6.5, Emergency Operating Procedures should be a focus of the ESRR.

17. Operator Workarounds: Operator workarounds shall be reviewed for impact on system operation or performance. The impact should be assessed for conformance with the design basis information.

18. Industry Operating Experience Reviews: Industry experience reviews related to the system shall be assessed and compared to current design basis information. Specifically, Operating Experience information from the INPO Industry Database and generic NRC information shall be reviewed and effectiveness of application/consideration reviewed. Based on the results of reference 6.5, industry operating experience should be a focus of the ESRR. [Ref. 6.15t MAIN'IKNANCE'aintenance Procedures: Procedures for the overhaul of or general repair of system components shall be reviewed for appropriate use of and conformance with design basis information. Also,

. completed work documentation, including any applicable data sheets, should. be. assessed for adequacy of the use of the procedure. This topic does not cover preventive maintenance activities (covered in item 21) and surveillance type procedures (covered in item 22).

20. Vendor Technical Information: Vendor technical manuals, vendor drawings, and design data forwarded by the vendor related to system components shall be reviewed for conformance with design basis information. Based on the results of reference 6.5, vendor technical information should be a focus area of the ESRR.

Information PMP 7200.RST.004 Rev. 5., Page 92 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Figure 1 Addendum SYSTEM ASSESSMENT MATRIX Pages:

MAJOR TOPICS 85-94

21. Preventive Maintenance: Regularly scheduled maintenance work items to assure proper equipment operation, including calibrations, lubrication, and filter flushing/changing, shall be reviewed for appropriate schedules, timeliness of performing the activity, and appropriate use of materials, Procedures for preventive maintenance scheduling and documentation shall also be reviewed.

SURVEILLANCE

22. Surveillance and Periodic Tests & Inspections: Each ESRR team shall, in the course of its assessment, verify that design basis safety and accident mitigation functions of the system are validated and verified, either by periodic testing or by engineering calculation for those portions of the system that cannot be tested periodically.

Procedures for tests and inspections required to verify compliance with TS Surveillance Requirements for system components shall be reviewed to assess compliance with the TS and its Bases, appropriate methodology, and consistency with other design basis information. Results of the most recent surveillance and periodic performance tests shall also be reviewed for compliance with design basis information and for the presence of adverse trends that have not been addressed.

23. ISI and Section XI IST: Procedures for Inservice Inspection and Inservice testing of system pumps and valves and other performance tests (e.g., heat exchanger performance tests, MOV tests, special pump/system performance tests) shall be reviewed for

. appropriate use of and conformance with design basis information.

Results of. the. most recent tests shall also be reviewed for compliance with design basis information.

~ ~ += I N~

Information PMP 7200.RST.004 Rev. 5 Page 93 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM SYSTEM ASSESSMENT MATRIX Pages:

Figure 1 Addendum MAJOR TOPICS 85-94 PHYSICAL PLANT

24. As-Built Verifications: Walkdowns of the system to verify conformance with design basis information, system layout against the drawings, system condition, component configuration, interactions with other systems, and other characteristics shall be performed based on checklists developed from the documentation reviews. These walkdowns should consider the adequacy of "

system vent provisions and how the provisions are incorporated into system procedures.

25. Control Room Drawings (i.e. the OP-series and the 9800 series drawings) shall be reviewed for conformance with design basis information. Also, the timeliness of the incorporation of changes to the current drawings should be assessed.

26. Surveillance Programs: Surveillances not associated with Items 22 and 23, such as Erosion/Corrosion, Fire Protection, or HELB, shall be reviewed for direct or indirect applicability to the system and its components and conformance with design basis. Results of the most recent surveillances should be assessed against design basis information.

'ev. 5 C

Information PMP 7200.RST.004 Page 94 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Addendum SYSTEM ASSESSMENT MATRIX Pages:

Figure 1 MAJOR TOPICS 85-94 PROGRAMS, PROCESS AND PROCEDURES

27. Corrective Actions: Closed Condition Reports (CRs), Maintenance Action Requests, NPM Engineering Evaluation Requests, and other corrective action type reports related to the system shall be assessed for appropriate evaluation of problem against design basis, generic considerations, appropriate resolution, timeliness of resolution, and adverse trends. Included in this review shall be an assessment to determine ifany existing conditions should be the subject of an operability Determination, 50.59 screen or justification for continued operation. (See Generic Letter 91-18 for further details).

28. PA Audits and other Assessments: PA audits, EDSFIs, SSFIs, and other completed similar system or program assessments related to the system including Maintenance Rule Risk Significance determination shall be reviewed to assess effectiveness of the audit, appropriate resolution, including addressing extent of condition, timeliness of resolution, and adverse trends. Implementation of any generic lessons learned from system - specific SSFIs and the 9/97 IST self assessment should be evaluated.

29. Training Lesson Plans: Operations and engineering training lesson plans for the system shall be reviewed for consistency with design basis information and operating procedures.

30.. Open Items (Backlog): Maintenance, engineering, and operations open itemsxelated to the system shall be evaluated with respect to the current Restart Criteria within the SIDS data base;

31. Strategy Documents: Some Cook Plant systems had specific strategy documents prepared to articulate actions taken in response to NRC Identified Issues., ESRR teams shall review these documents and mark them up to refiect any changes needed to fully address issues of extent of condition, t'ransportability to the other unit, or to ensure a technically accurate and thorough approach to resolving the issue. This markup should be brief but should focus on identifying major unaddressed or unresolved issues in the system that may impact on resolution of the issue addressed by the strategy document.

Information PMP 7200.RST. Rev. 5 Page 95 of 101 EXPANDED SYSTEM READINESS REVIE% PROGRAM Figure 2 SYSTEM ASSESSMENT MATRIX Pages:

EXAMPLE - AUXILIARYFEEDWATER SYSTEM 95 -99 SYSrEM ASSESSMENT MATRIX EXAMPLE - AUXILIARYFEEDWATER SYSTEM MAJOR TOPlCS DESIGN BASIS LICENSING OPERATIONS MAINTENANCE SURV PHYSICAL PROGRAMS, PROCESS DOCUMENTS PLANT Ec PROCEDURES I 2 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Cl 9

E K

ASSESSMENT ATIRIBVIKS 0 AFW01 WATERSUIHY X X X X AFW02 l4JKRDUVEHANDTD.AFWmIS X X X AFW03 X X

'lURHNEANDSIEAM SURD X X X X X X X AFWOS AFWIMWCKNIKLVALVES X X AFWC01 HHNGDBXiN AFWC02 CXÃl'AINMENrKXAlKN HKiHHIERGYIJNEBREAKS BA1KCblBIPALQIALRKhlKN X X X X AHEÃmR X X AFWC07 AFWC08 AFWC09 X X AFWC10 SNGZ FAILURECRIIERIAICMF X X AFWCl1 (%&0 X X X AFWC12 'IEMP. HRCIS CNSYS(XBIAB8LTY AFWC13 HCIHINALHA7AKS

Information . PMP 7200.RST.004 Rev. 5 Page 96 of 101 EXPA'NDED SYSTEM READINESS REVIEW PROGRAM Figure 2 Addendum SYSTEM ASSESSMENT MATRIX Pages:

EXAMPLE - AUXILIARYFEEDWATER SYSTEM 95-99 ATTRIBUTE SELECTION GUIDANCE (typical example only - not a complete treatment of the AFW system critical attributes or design considerations)

Note: System attributes are selected based on a thorough research of the system design basis.

Attributes chosen for detailed review should be those vital to accomplishing the various safety and accident mitigation functions as defined in the design and licensing basis for the specified mission times (where applicable) and in the design plant conditions. Cook Plant has sometimes overlooked the critical functions of passive components (such as tanks, strainers, spray headers) to assure that appropriate performance has been demonstrated by testing, calculatioh.

or analysis. Additionally, such passive components have sometimes not received thorough materiel condition inspections to assure that the component contains the heat tracing, instrumentation, and other necessary features are functional such that the component remains operable in all required modes. ESRR teams shall assess obvious passive components for these types of issues.

SYSTEM FUNCTIONS BEING ASSESSED AFW01 Water Supply: An adequate water supply inventory is required for the AFW system to remove decay heat from the reactor coolant system (RCS) following events resulting in a loss of main feedwater; Issues related to water volume and level'indication, switchover to other sources, and overpressure/vacuum pressure are to be assessed. Included in this assessment should be a review of the capability of backup water supplies to function as designed.

AFW02 ~

Motor-driven and turbine-driven auxiliary feedwater pumps (list component IDs): the AFW-pumps are critical components for delivery of the required AFW flow. Issues related to pump performance, NPSH, mitiitnum flow requirements, motor and power supplies, power supply reliability, and design

'equirements are to be assessed.

AFW03 Initiation and control: The auxiliary feedwater system initiation and control circuitry is required to automatically initiate the system and assure adequate decay heat removal and to allow control of cooldown rates. Issues related to initiation and control setpoints, instrumentation, flow, and level control are to be assessed.

Information PMP /200.RST.004 Rev. 5 Page 97 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Figure 2 Addendum SYSTEM ASSESSMENT MATRIX Pages:

EXAMPLE - AUXILIARYFEEDWATER SYSTEM 95 -99 Turbine and steam supply: The turbine driver for the turbine-driven auxiliary feedwater pumps (component IDs) and its steam supply and exhaust critical components for the operation of the pump. These components

're have a negative industry operating experience history, and at Cook Plant have a seismic classification (in part) that has been questioned in the past. Issues related to steam line warming and draining, trip and governor valve design, operation, and maintenance, speed controls, overspeed protection, and pump alignment are to be assessed.

AFW05 AFW flow control valves (FMO-212, 222,232,242,211,221,231,241). The flow control valves are critical to limit flow to specified limits to achieve adequate decay heat removal and to miiumize overcooling of the RCS. Issues related to valve and actuator design requirements, power supplies, and positioning capability are to be assessed.

Generic Attributes to be a lied where a licable b all ESRR teams

~

Note: The below listed generic or common attributes, including items AFWC01 to AFWC13, are broadly applicable based on Cook Plant operating history, experience, and issues and, as such, each ESRR team shall be aware of potential effects of these attributes on functionality of their system.

AFWC01 Piping design: Changes in piping design criteria since original plant design MAYresult in confusion in piping design, installation, and inspection for existing piping and new piping installation. Other examples include material condition of buried pipe, ASME Code classification boundaries, and design temperature and pressures.

Containment isolation: Example of potential concerns are modification, maintenance, and testing (Appendix J) of containment isolation features.

AFWC03 Station blackout operation: Significant effort has been made by the industry to address rules regarding loss of all AC power. The AFW system is an important mitigator for this event.. Example issues include water supply, flow control and manual actions for the AFW system under station blackout conditions.

Information PMP 7200.RST.004 Rev. 5 Page 98 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Figure 2 Addendum SYSTEM ASSESSMENT MATRIX Pages:

EXAMPLE - AUXILIARYFEEDWATER SYSTEM 95-99 High Energy line breaks: Cook Plant systems should be protected against the effects of high energy line breaks. Line break issues are interdisciplinary, involving piping design, environmental qualification, fiooding, bamer design, and accident analyses. Walkdown of physical barriers intended to ensure protection against such line breaks shall be considered to verify their mitigation capability. Additionally, consider test verification of detection and mitigation schemes.

AFWC05 Environmental qualification: EQ is a highly regulated program to assure system operation during adverse environmental conditions associated with design basis accident conditions. The EQ program is being assessed independently of this review. Potential issues from that review affecting system functions important to safe operation and accident mitigation should be considered.

AFWC06 Appendix R: Appendix R is a highly regulated program that required significant utility effort to address. The Appendix R program is being assessed independently of this review. Potential issues from that review affecting system functions important to safe operation and accident mitigation should be considered. Specific consideration should also be given to fire barriers and equipment required for safe shutdown.

AFWC07 Electrical separation: Redundant electrical trains and instrument channels are required to be separated by Regulatory Guide 1.75. Compliance with these requirements should be considered in the system walkdowns.

AFWC08 Seismic qualification: The AFW system is generally classified as seismic Category'.in. accordance with Regulatory Guide 1.29. Compliance with the requirements and the impact on design basis should be verified to the extent that the seismic classification and calculational basis are consistent.

AFWC09. Year 2000 (Y2K): Considerable industry effort is being expended to ensure the reliable operation of microprocessor-based control and indication systems will not be vulnerable to year 2000 related problems. Identify microprocessor based controls within the system, confirm they are within the Y2K scope, and identify outstanding work remaining.

Information'IMP 7200.RST.004 Rev. 5 Page 99 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM Figure 2 Addendum SYSTEM ASSESSMENT MATRIX Pages:

EXAMPLE - AUXILIARYFEEDWATER SYSTEM 95-99 AFWC10 Single Failure Criteria/Common Mode Failure (CMF): The Cook Plant single failure design basis is not straightforward and misunderstanding or misapplication has led to issues of nonconformance in the past.

Additionally, some events at Cook Plant have been related to a failure to adequately consider possible failure modes of both system and supporting or attendant system components, ESRR teams must clearly understand the design basis in these areas and should evaluate whether possible failure modes of both the system and attending systems have been assessed to ensure the design is robust. (see LER 97-021) Additionally, ESRR teams should be alert for and identify common mode failure mechanisms (if encountered) during their reviews. These mechanisms include inappropriate-operations, maintenance, testing, or procurement priorities or poor material condition..

AFWCII Generic Letter 89-13 (GL 89-13): Cook Plant has had problems

,implementing Generic Letter 89-13 on service water cooling systems. The GL 89-13 program is being assessed independently of this review. Potential.

issues from the review affecting system functions important to safe operation and accident mitigation should be considered. ESRR teams should also be alert for instances where service water system dead legs are not properly or effectively addressed under the program or where Cook operating experience shows that, the existing provisions are insufficient.

AFWC12 Temperature Effects on System Operability: Cook Plant has not yet properly accounted for lake temperature variations in all system design bases. ESRR teams shall specifically assess, where applicable, whether the design basis for the system or system components is at odds with the maximum seasonal lake temperature expected, which could be as high as 87.5 degrees during certain summer months. Where such instances are found, the effect on system operability shall be assessed.

AFWC13 External Hazards: Potential external hazards that may be applicable include flooding from both external and internal sources, missiles from both internal and external potential sources, wind loading, tornado and electric storm effects.

Information PjVIP 7200.RST.004 Rev. 5 Page 100 of 101 EXPANDED SYSTEM READINESS REVIEW PROGRAM READINESS REVIEW ATTRIBUTE Pages:

Figure 3 ASSESSMENT FORM 100 - 100

~

Readiness Review Attribute Assessment Form s

Reviewer: Date: Item Number Reviewer Number: System Attribute Number Attribute Description Major topic Attribute Major Topic Attribute Checks CRs Checks CRs Electrical Calcs/analysis 1 Operating Procedures 16 1&C Calcs/Analysis 2 Operator Work Arounds 17 Mech./struct Calcs/Analysis 3 Industry Op Exp Reviews 18 Accident Analysis 4 Maintenance Procedures 19 Drawings 5 Vendor/Technical Info 20 Logic Diagrams. 6 Preventive Maintenance 21 Config. Management Info. 7 Surveillance and Periodic 22 Specifications DBDs 8

9 ISUSection XI IST'3 Tests & inspections As-Built Verification 24 Change Docs/50.59 Reviews. 10 Control Room Drawings, 25 Temporary Mods/Bypasses 11 Surveillance Programs 26 UFSAR Reviews TS/Bases Licensing Commitments 13 12 14 Correction Action Program PA Audits/Other Assessments Training Lesson Plans 27 28 29 Notices, Bulletins and GLs. 15 Open Items (Backlog) 30 Strategy Documents 31 CR Number:

Documents Reviewed Attribute Assessment

Information, PMP 7200.RST.004 Rev. 5 Page 101 of 101 EXPA'NDED SYSTEM READINESS REVIEW PROGRAM SAMPLE COMPLETED READINESS REVIEW Pages:

Figure 4 ATTRIBUTE ASSESSMENT FORM 101- 101 Readiness Review Attribute Assessment Form Reviewer: Russell Date: 2/5/99 Item Number Reviewer Number: ~ABROi System ~AFW Attribute Number AFWO1 Attribute Description CONDENSATE STORAGE TANK DESIGN BASIS Major topic, Attribute Major Topic Attribute Checks CRs Checks Electrical Calcs/analysis Operating Procedures 16 . 0 1&C Calcs/Analysis Operator Work Arounds "

17 0 Mech/struct Calcs/Analysis Industry Op Exp Reviews 18 0 Accident Analysis Maintenance Procedures 19 0 Drawings Vendor/Technical Info 20 0 0 Logic Diagrams, Preventive Maintenance 21 0 Config. Management info. Surveillance and Periodic 22 0 0 Test & Inspections Specifications 8 0 Section XI IST/Perf. Tests 23 DBDs 9 1 As-Built Verification 24 Change Docs/50.59 Reviews 10 0 Control Room Drawings 25 Temporary Mods/Bypasses 11 0 Surveillance Programs 26 UFSAR Reviews 12 0 Correction Action Program 27 ITS/Bases 13 0 PA Audits/Other Assessments 28 Licensing Commitments 14 0 Training Lesson Plans, 29 Notices, Bulletins and GLs 15 0 Open Items (Backlog) 30 Strategy Documents 31 CR Number:

CR 4 984000 to provide basis for the statement that 174,451 gallons is sufficient to remove decay heat.

Documents Reviewed

1. DBD - DB-12, AFWS, Auxiliary Feedwater System, Rev. 0, Change 6, Section 3.0.

2. UFSAR 10.5.2, Rev.

3. TS 3.7.6 and Bases; Attribute Assessment No Calculation or other documentation or data could be found to establish the basis for this minimum value. The basis for the 9 hour1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> decay heat cooling capacity needs to be established

Attachment 2 Expanded System Readiness Review Procedure For Level 2 Systems PMP 7200.RST.006, Rev. 1

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