ML12052A115

Standby Shutdown Facility Design Review Project Plan and Schedule

ML12052A115
Person / Time
Site:	Oconee
Issue date:	02/17/2012
From:	Gillespie T Duke Energy Carolinas
To:	Mccree V NRC/RGN-II/DCI
References
Download: ML12052A115 (28)

Text

-a.

t Duke T. PRESTON GILLESPIE, JR Vice President 0 Energy Oconec Nuclear Station Duke Energy ONOI VP! 7800 Rochester Hwy.

Seneca, SC 29672 864-873-4478 864-873-4208 fax T. Gillespie( )duke-enPrgy. cool February 17, 2012 Mr. Victor McCree, Regional Administrator U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, Georgia 30303-1257

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station (ONS), Units 1, 2 and 3 Renewed Facility Operating License Numbers DPR-38, -47, -55; Docket Numbers 50-269, 50-270 and 50-287; Standby Shutdown Facility Design Review Project Plan and Schedule

Reference:

Duke Energy letter from T. Preston Gillespie to Victor McCree (Nuclear Regulatory Commission), ONS Standby Shutdown Facility and Bus Duct Studies, dated January 26, 2012

Dear Mr. McCree:

Per the referenced letter, Duke Energy Carolinas, LLC (Duke Energy) is submitting as the enclosure to this letter the Standby Shutdown Facility Design Review Project Plan and Schedule.

It should be noted that the project plan and the accompanying schedule, as submitted, represent Duke Energys current plan of the performance of the SSF Design Review Project and a best estimate projection of its chronology. As project activities are undertaken, circumstances may dictate modifications to the project plan and schedule. As such, the project plan and the schedule are living documents that are subject to change.

submittal document cor----- reguIatbrcorhhitrnrts.

If there are any questions regarding this submittal, please contact Kent R. Alter of the ONS Regulatory Compliance Group at (864) 873-3255, or Lenny Azzarello of Duke Energy Nuclear Plant Development at (704) 382-8168.

Sincerely, T. Preston Gillespie, Jr., Vice President Oconee Nuclear Station

Enclosure:

Standby Shutdown Facility Design Review Project Plan and Schedule U. S. Nuclear Regulatory Commission www. duke-energy. corn

U. S. Nuclear Regulatory Commission February 17, 2012 Page 2 cc w/

Enclosure:

Mr. John Stang, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, D. C. 20555 Mr. Jonathan Bartley U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, Georgia 30303-1257 Mr. Andy Sabisch Senior Resident Inspector Oconee Nuclear Site Ms. Susan E. Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201 1

U. S. Nuclear Regulatory Commission February 17, 2012 Page 3 bcc w/Enclosure S. L. Batson T. D. Ray R. H. Guy E. L. Anderson L. S. Nichols J. E. Burchfield J. A. Kammner L. J. Azzarello T. L. Patterson K. R. Alter C. J. Thomas GO -

R. D. Hart CNS K. L. Ashe MNS NSRB, ECOSN ELL, ECO5O File T.S. Working ONS Document Management 2

ENCLOSURE Standby Shutdown Facility Design Review Project Plan and Schedule PROJECT PLAN COMPREHENSIVE DESIGN, LICENSING AND OPERATIONAL REVIEW OF THE OCONEE STANDBY SHUTDOWN FACILITY FEBRUARY 15, 2012 3

TABLE OF CONTENTS EXECUTIVE

SUMMARY

1. PURPOSE

2. OBJECTIVES

3. SCOPE

4. PROJECT APPROACH 4.1. General 4.2. Review of Licensing Basis 4.3. Review of Engineering Design Basis 4.4. Review of Operational Implementation 4.5. Review of Corrective Action Program and Operating Experience 4.6. Field Verification of Systems, Structures and Components 4.7. Documentation of Issues Raised During the Project 4.8. Independent Review Team 4.9. Oconee Site Review and Interface

5. COMMUNICATION INTERFACE WITH KEY STAKEHOLDERS

6. PROJECT TEAM ORGANIZATION AND STAFFING

7. PROJECT SCHEDULE

8. PROJECT TEAM LOGISTICS

9. PROJECT REPORT APPENDIX A Project Schedule APPENDIX B Simplified Project Organization Chart APPENDIX C Project Team Members APPENDIX D Critical Safety Function versus Event Matrix APPENDIX E Industry Configuration Management Model I

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1.0 PURPOSE This document is the project plan for the Comprehensive Design, Licensing and Operational Review of the Oconee Standby Shutdown Facility (SSF). It describes the purpose and scope of the review; the bases and guidance for performing the review; the project team composition and responsibilities; the schedule for the review; Oconee interfaces and responsibilities for supporting the review; anticipated field verification effort; review attributes; and reporting requirements.

2.0 OBJECTIVES The objectives of the Comprehensive Design, Licensing and Operational Review are to:

• Determine if the SSF is currently designed, constructed, operated, maintained and tested to meet the requirements of the design and licensing bases

• Document any identified discrepancies in the corrective action program 3.0 SCOPE The Standby Shutdown Facility (SSF) review is intended to be a comprehensive review, encompassing the licensing and design basis of the SSF through to implementing documents (e.g., calculations, specifications, procedures) starting from the initial licensing efforts. Thus, the project is similar to a design reconstitution effort.

This review is intended to go beyond the sampling process used during NRC inspections and licensee self assessments. This effort includes a review the design and licensing basis, maintenance and operational implementation, and appropriate implementation of corrective actions for internal and external operating experience (OE). Review emphasis is focused on ensuring that the SSF can perform its intended safety functions, i.e., determining if there are deficiencies that could defeat or encumber the ability of the SSF to perform its intended safety function under design basis conditions. To determine what functions need to be performed and when, a matrix will be constructed of SSF functions versus licensing and design basis events.

This matrix will outline the systems and components needed to perform the intended functions and the assumptions and conditions under which the intended functions must be performed.

Field verification walkdowns are included for accessible SSCs to confirm that the actual plant configuration is consistent with the licensing and design basis.

The comprehensive design, licensing and operational review is intended to accomplish the following outcomes:

• Review and confirmation of the licensing basis;

• Review and confirmation of the existence and adequacy of the design basis documentation, including the safety classifications of SSCs;

• Review and confirmation that the actual plant configuration is in conformance with the licensing and design basis;

• Review and confirmation of test and maintenance records to confirm the adequacy of testing in determining performance capability under the applicable design basis conditions; 5

• Review and confirmation of emergency, abnormal, and normal operating procedures, specifically with respect to manual actions required for design basis scenarios;

• Review and confirmation of the adequacy and completeness of training packages related to the SSF;

• Review of Oconee and relevant industry operating experience records to ensure that applicable SSF issues were properly captured and dispositioned in Duke Energys corrective action programs.

A project approach is being used to structure the review effort. Independence and objectivity of the review project is planned by having a team comprised primarily of non-Duke Energy, independent industry experts to perform the work. To ensure an independent regulatory perspective is applied to the project, primarily during the licensing basis review and interpretation, several industry experts with NRC work experience are being utilized.

As part of the creation of a project plan, a resource-loaded schedule is being developed for the Comprehensive Design, Licensing and Operational Review of the SSF. This project plan and schedule includes milestones and deliverables. A phased approach is planned to perform the review. This approach allows for scope evolution as initial project activities are performed. A completion date for the project will be determined when the detailed planning is complete.

Based on the present scope, it is currently estimated that the project could take up to 15 months. As the project progresses, interim milestone deliverables will be made available for NRC review.

4O PROJECT APPROACH 4.1 General The review is intended to be comprehensive, starting with an independent verification of the licensing and design basis, flowing through to the confirmation that facility configuration documents (e.g., design documents such as calculations and drawings, operating procedures, test and maintenance procedures) correctly implement the design and licensing basis, and confirming that the actual plant configuration is in accordance with the licensing and design basis, as well as the facility configuration documents. This approach is consistent with the industry configuration management model (see Appendix E), which illustrates how these three aspects of configuration management must remain aligned. Identified gaps and inconsistencies within and in-between these three aspects will be entered into the stations corrective action program. These tasks are sufficient by themselves for a reconstitution effort. However, the review is intended to continue beyond these activities; separately, operating experience and corrective action program documents will be reviewed to ensure issues related to the SSF have been appropriately dispositioned.

The project approach will include major steps as follows:

1. Review and confirmation of the licensing basis,

2. Review and confirmation of the design basis,

3. Review and confirmation that the facility configuration documents correctly implement the licensing and design basis,

4. Field verification walkdowns to confirm that the actual plant configuration is in accordance with the licensing and design basis, as well as the facility configuration documents, 6

5. Review of operating experience to ensure it is appropriately dispositioned, and

6. Review of issues identified in the corrective action program.

To guide the overall re-constitution effort and provide reasonable assurance that all aspects of the SSF are being thoroughly reviewed, a matrix approach is being used to map critical safety functions against the events for which the SSF is required to respond, per its licensing basis.

Events identified by the licensing basis review, such as turbine building flood, fire and station blackout, will be reviewed for transient progression and the critical safety functions needed for mitigation by the SSF, within the requirements of the licensing basis (such as a requirement to maintain the plant at hot shutdown for a particular event). Critical safety functions needed for mitigation of a particular event, such as Reactor Coolant System inventory control and secondary side heat removal, will then be broken down into sub-functions, such as makeup, letdown and boundary control. Structures, systems and components (SSCs) necessary to perform the identified sub-functions (for example, a pump, a water source, flow isolation capability, a structural barrier) and the required attributes will then be identified and, ultimately, compared against actual plant design and documentation. In this manner, the design basis can be re-constituted, and any gaps between what the requirements say should be there, what the paperwork says is there and what is actually in the field can be captured and entered into the stations corrective action program.

At various stages of the project (e.g., following development of the initial project plan and schedule), the project plan includes challenges from an Independent Review Team, as well as from Oconee site personnel. Such reviews are intended to improve or clarify aspects of the project such as the purpose, scope, and approach, as well as perform a review of the teams findings, conclusions and products.

4.2 Review of Licensing Basis The current licensing basis (CLB) for the Standby Shutdown Facility (SSF) is intended to be re constituted from licensing basis documents such as the FSAR, Technical Specifications (TSs),

NRC correspondence, and other licensing documentation. The intent of this review is to confirm and clarify the CLB and identify any gaps or clarifications in the CLB that need to be addressed.

Initially, a manual search will be performed of all licensing documentation leading up to the April 1983 SER on the SSF. This manual search will serve as a self-study of a portion of the SSF licensing basis, providing an understanding of the early licensing history of the SSF. In addition, the manual search will serve to inform the creation of search criteria (such as key words and phrases, system and component designations, and SSF functions and events) for a more exhaustive, electronic search of post-SER licensing documentation.

As referred to in the initial phase of the licensing basis review, search tools will be developed to perform a more exhaustive, electronic search of licensing documentation. The effectiveness of the search criteria will be checked against focused manual searches to provide greater confidence that all licensing documentation is being accessed and considered. While the focus is primarily on Duke sources of documentation, searches will also be performed on external sources such as ADAMS and public document rooms. Once checked, the search criteria will be applied to post-SER licensing correspondence.

Licensing documents identified during various searches will be reviewed by licensing sub-team personnel and categorized to ultimately draw conclusions on, and re-constitute, the CLB.

Additional tools will be developed to record and document potential licensing basis items, and provide traceability from the re-constituted CLB back to the supporting documentation. Any gaps identified will be entered into the stations corrective action program.

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Products from this licensing review will provide input to the other project activities, such as the engineering sub-teams creation of a critical safety functions versus licensing and design events matrix.

4.3 Review of Engineering Design Basis This portion of the project is intended to ensure that design documentation (e.g., calculations, drawings, specifications) comprehensively and accurately encompasses the licensing basis, as well as provide reasonable assurance that the SSF is able to perform its intended safety functions, as required by the licensing basis. To accomplish this objective, the design basis of the SSF will be re-constituted. Input from the licensing basis review will be utilized to establish the licensing requirements to be incorporated into the design basis. Ultimately, the review is intended to confirm that the design capability of the SSF systems, structures and components (SSCs) can accommodate the licensing basis requirements. A systematic approach to re constituting the SSF design basis will be employed to ensure that this effort is independent and not influenced by any potential pre-existing design errors. Identified gaps in, or issues with, the design basis documentation will be entered into the stations corrective action program.

The first phase of this approach is the creation of a matrix of generic critical safety functions versus initiating events for pressurized water reactors (PWR). This generic PWR matrix will subsequently be reduced to an SSF-specific matrix. This reduction process will initially be based on the current licensing basis. Input from the licensing basis review portion of the project, as well as a critical review of Oconee design documents such as event mitigation calculations and SSF-related design basis documents, will be used to confirm the current licensing basis. Critical safety functions that are to be performed or supported by the SSF are the intended deliverable for this phase of the project.

Subsequent to the identification of SSF-specific critical safety functions, a set of sub-functions will be developed for each of these critical safety functions. These sub-functions further describe what is actually necessary to accomplish the SSF-specific critical safety functions. For example, the set of sub-functions necessary to accomplish the critical safety function of Reactor Coolant System Inventory Control might include reactor coolant system makeup, reactor coolant system letdown and reactor coolant system boundary control. The identification and development of the required sub-functions will be based on the knowledge and experience of the expert team members performing the review. The adequacy of the identified sub-functions for each critical safety function is intended to be confirmed by a critical review of Oconee design documents.

The next step in the process is to identify the SSCs necessary to perform the sub-functions, including the identification of the required design attributes. For example, the previous phase may have identified reactor coolant system makeup as a sub-function for the critical safety function Reactor Coolant System Inventory Control. To perform the makeup sub-function, the following SSCs would typically be necessary: a water source (such as a tank or pool), flow control capability (such as a control valve), motive force (such as a pump and electric motor),

indication for the operator (such as flow and pressure instrumentation), etc. The design attributes for these SSCs might include seismic qualification or the specific temperature, pressure and steam and other environmental exposure conditions under which the SSC must perform its design function(s). The identification and development of the necessary SSCs, and 8

their required design attributes, will be based on the knowledge and experience of the expert team members performing the review.

Once the required critical safety functions, required sub-functions and necessary SSCs, with required design attributes are indentified and developed, the actual design documentation will be critically reviewed to determine if it meets the aforementioned requirements. The design documents will be reviewed for adequacy using tools (such as predefined checklists) for each document type. These tools (e.g., checklists) will be developed early in the project to ensure that the reviews are consistent and sufficient to confirm the adequacy of the design documents.

As previously mentioned, any identified gaps in, or issues with, the design documentation will be entered into the stations corrective action program.

4.4 Review of Operational Implementation The intent of this portion of the project is to ensure that the operational (e.g.,, operations, maintenance, testing) implementation and support of SSF required functions accurately and completely implement the design and licensing basis. Additionally, training documentation will be reviewed to ensure that it provides an appropriate level of knowledge, skills, and abilities to operate and maintain the SSF for all licensing basis identified conditions. Reviews of the operational and training documents will be conducted using a pre-defined checklist for each document type. These tools (checklists) will be developed early in the project to ensure that the reviews are consistent and sufficient to confirm the adequacy of the documents.

The process for reviewing operational implementation begins with the identification of required systems, structures, components (SSCs) and operator actions that require operational support for implementation. Required SSCs include components such as pumps, motors, instrumentation, and flood barriers. Required operator actions include activities such as diesel generator starts, electrical breaker manipulation and pump flow throttling. These required SSCs and operator actions would typically be identified by the engineering design review and provided as input to the operational implementation review. However, input from the entire project team (including the licensing review team and the corrective action program and operating experience review team) will also be utilized to provide reasonable assurance of completeness.

When the required SSCs and operator actions are identified, the next step is to identify the activities necessary to adequately support operational implementation. These operational support activities include, but are not limited to, operator training and direction (to support required operator actions), surveillance testing and inspection, preventative maintenance and routine plant monitoring (to support SSC availability and reliability). Tools will be developed to support the consistent identification of operational implementation activities.

When operational implementation activities have been identified for required SSCs and operator actions, the next step is to identify operational implementation documents needed to support the aforementioned activities. These implementation documents include, but are not limited to, lesson plans and emergency operating procedures (to support operator training and direction),

testing and surveillance procedures (to support surveillance testing and inspection),

maintenance procedures, vendor manuals and operator rounds procedures (to support preventative maintenance and routine plant monitoring), Identified gaps in documentation will be entered into the stations corrective action program. Existing documentation to support 9

operational implementation (the need for such having been identified in the previous process step) will then be reviewed to determine their adequacy to support the required operational implementation activities. This step includes, but is not limited to, the review of existing lesson plans, operations procedures, testing and surveillance procedures and maintenance procedures. Tools will be developed to support the consistent determination of documentation adequacy. Identified gaps will be entered into the stations corrective action program.

4.5 Review of Corrective Action Program and Operating Experience This portion of the project will focus on a review of Corrective Action Program documents and operating experience related to the Standby Shutdown Facility (SSF).

The process will consist of the identification and gathering of the population of specific CAP documents (PIPs) that need to be reviewed to address potential SSF issues. This will consist of the project team members developing criteria for discriminating between SSF-related PlPs and non-SSF-related PIPs.

The PIPs identified in the previous phase of the process will be reviewed and, as appropriate, passed on to other project sub-teams to inform their sub-team activities, used to identify trends or gaps that will require further station resolution, or closed with no concern for the safe and compliant operation of the SSF. Tools (e.g., checklists) will be developed to perform the review of each PIP. Identified problems requiring station resolution will be entered into the stations corrective action program.

The operating experience review will begin with an identification of the various sources of operating experience that are available for station review and disposition. This effort will consist of project team members reviewing industry documentation (e.g., INPO, NEI, NUMARC, EPRI, Vendor, and NRC-generated information).

The next step in the operating experience review will be the identification and gathering of the population of operating experience documents that could result in potential SSF issues. This will consist of the project team member developing criteria for discriminating between SSF related operating experience and non-SSF-related operating experience. Once the various operating experience documents have been identified, the team will retrieve the specific documents for review in preparation for the next phase of the operating experience review efforts.

The operating experience identified in the previous phase of this process will be reviewed and, as appropriate, passed on to other project sub-teams to inform their sub-team activities, document identified gaps in the application of the operating experience, or closed with no concern for the safe and compliant operation of the SSF. Tools (e.g., checklists) will be developed to perform the review of each operating experience document. Identified problems requiring station resolution will be entered into the station corrective action program.

4.6 Field Verification of Systems, Structures and Components The intent of this portion of the project is to perform walkdowns of all accessible systems, structures and components (SSCs) to confirm that the actual plant configuration conforms to the facility configuration documentation, as well as the licensing and design basis. Expectations for 10

the field verifications will be documented in tools (e.g., checklists) to ensure consistency and adequacy of the walkdowns.

Engineering-focused walkdowns will be performed to compare actual plant configuration against the engineering design basis documentation. For example, drawings will be used during walkdowns to verify the existence of various components in the field, their sequence in the flowpath, the existence of any temporary modifications and any physical anomalies from the intended design that could interfere with the performance of the design function. Engineering walkdowns will also take note of material condition issues and any other deviations from the expected configuration.

Operational-focused walkdowns will be performed to compare actual plant configuration against operations documentation, such as procedures, to confirm that the required operator actions can be performed within any required time frame (if applicable). Additional examples of walkdown objectives include the determination that the field configuration supports the ability of station personnel to adequately test, perform surveillance, maintain and monitor plant equipment per the operational implementation documentation. Operational walkdowns will also take note of any potential material condition issues, physical interferences or impediments, and operations or maintenance workarounds.

Any identified deviations or anomalies will be entered into the stations corrective action program.

4.7 Documentation of Issues Raised During the Project As the project team performs its activities, numerous questions are expected to arise. These questions will be researched by gathering data pertaining to the particular question and interfacing with station personnel, as well as vetting the question through the project team. This effort is focused on determining if an answer to the question already exists. If an answer to a particular question is not readily identified, then an issue (or gap) should be entered into the stations corrective action program. The operability process will also be utilized, when and if appropriate. This approach is consistent with the criteria for entering issues into the Duke Energy Nuclear Generation Corrective Action Program (PIP) and the Operability Process. It is important to note that the speed at which resolution of a question is pursued will be a function of its risk importance and potential impact on plant safety. The project team has members who are well versed in Probabilistic Risk Assessment, as well as the appropriate regulatory perspective, to help ensure that the right focus is placed on any particular question or issue.

The project team will maintain an action tracking database for logging and tracking questions, and the activities underway to answer the question, with the ultimate resolution being a documented answer or an entry into the stations PIP Program.

4.8 Independent Review Team An Independent Review Team will be formed to review various aspects of the project throughout the review. Such reviews are intended to improve or clarify aspects of the project such as the purpose, scope, and approach, as well as perform a review of the teams findings and products.

4.9 Oconee Site Review and Interface The Oconee site review will be performed in several different ways at several different levels in the organization. Periodic communications on project status will be covered under the Communications Plan for Key Stakeholders. Site review of key project deliverables (such as licensing basis interpretations and positions) will be scheduled and presented as the schedule 11

milestones for those deliverables are achieved. Daily Oconee site review of all Oconee related corrective action program entries will provide another method for reviewing SSF-related entries made by the project team.

The primary interface between the project team and station personnel will be through the Oconee Risk System Engineering Team. Members of this site team will be integrated into project team activities on a daily to weekly basis and have access to all project team in-progress documents. Members of this site team will also assist with obtaining input from other station personnel on project team activities (such as interviews) and coordinating any preparatory activities in anticipation of potential corrective actions.

5.0 COMMUNICATION INTERFACE WITH KEY STAKEHOLDERS The project team will develop a communication plan for interfaces with key stakeholders (e.g.,

Oconee management, NGD senior leadership, and NRC).

The key stakeholders for the project are:

• Oconee Nuclear Station: Site Vice President, Organizational Effectiveness Manager, Station Manager (including Operations, Maintenance and Work Control direct reports),

Engineering Manager (including Design Engineering, Systems Engineering and components and programs team members), Safety Assurance and Regulatory Compliance,

• Duke Energy Corporate: Chief Nuclear Officer, Senior Vice President Nuclear Operations, Vice President Nuclear Support, Nuclear Compliance Manager

• Duke Energy Nuclear Safety Review Board,

• NRC: Residents, Region II (including Engineering Branch and Division of Reactor Projects and Reactor Safety), NRR (including Projects and Engineering), Security and Incident Response Office,

• INPO,

• Oconee Major Projects: including the special project teams for Protected Service Water, HELB I Tornado, NFPA 805, external flooding, main steam isolation valves.

The communication plan will include desired protocols such as periodic interfaces (e.g., periodic phone calls, meeting updates, and/or written updates), as well as presentations as required.

The plan will be finalized with the specific communication protocols to be used with specific stakeholders following discussions with the stakeholders to ensure expectations are clearly defined.

6.0 PROJECT TEAM ORGANIZATION AND STAFFING The responsibilities for key project team members are discussed below. A simplified project organization chart is presented in Appendix B. This organization chart displays the primary focus areas of the project effort and is subject to change as the needs of the project team evolve over time. A list of team members is included in Appendix C. The team is comprised of both full-time and part-time members. The list of team members is also subject to change as the needs of the project team evolve over time.

Duke Management Leader The overall Duke Energy Management team leader will be responsible for ensuring the scope and objectives of the project are consistent with Duke Energy senior leadership expectations and 12

follow Duke Energys processes for projects. This individual will be responsible for ensuring the project plan is clear and that resources are available to complete the plan. This individual will also set overall expectations for team interactions and communication of project progress and issues with key project stakeholders. This individual will also be the primary communicator with key project stakeholders.

Technical Team Leader The Technical Team Leader will lead the day-to-day activities of the team to complete the project in accordance with the project plan. The Technical Team Leader will also be responsible for overseeing the preparation of the final report.

Team Members Each team member is responsible for completing project activities within the assigned technical area. The team members perform the project activities (e.g., document reviews, personnel interviews, onsite observations of activities, and system walkdowns). Team members will work with Duke employees to ensure that issues and concerns are entered into Dukes corrective action program as appropriate. Team members will provide input to the project report.

Oconee Support Oconee personnel will support the project team by providing access to requested documents and answering questions. Issues entered into the corrective action program will be assigned to and dispositioned by the Oconee team, not the project team.

7.0 PROJECT SCHEDULE The project schedule will be developed during the first phase of the project, the detailed planning phase. The project schedule will be refined and revised as the project progresses. A copy of the project schedule is included in Appendix A.

8.0 PROJECT TEAM LOGISTICS The project team will be based in the Nuclear General Office in Charlotte, with trips to Oconee as needed for walkdowns to verify actual plant configuration, interviews with plant personnel and communications with site and various external stakeholders.

Weekly project team meetings are planned. The primary objectives of the project team meeting are to provide a brief status of progress; identify and discuss potential or actual issues and their significance; identify plans for the coming week; and identify problems or needs impeding progress. Additional objectives are to provide technical and administrative information to team members.

Sub-team meetings (engineering design team, licensing team, operational team, etc.) will be held as needed. The technical details of issues under investigation are intended to be discussed in greater detail during these meetings.

Each sub-team will produce a weekly report of activities performed, issues being investigated and planned activities for submittal to the project manager at the end of each week. The project manager will compile the sub-team reports into a weekly project team report for review during the project team meeting. Each team member will provide brief report feeders covering their project activities. The purpose of the report feeders is to provide a means of efficiently communicating results (look back) and plans (look ahead).

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9.0 PROJECT REPORT The project team will produce a final report (with any supporting databases that may have been created) as a deliverable. The report is anticipated to consist primarily of an executive summary, a report body, appendices, and attachments.

The report body is anticipated to contain the project purpose, objectives, scope, the processes (or approach) used to perform the project, and any general findings and conclusions. Elements of the project plan will ultimately be incorporated into the body of the report.

It is currently envisioned that an appendix will be created for each event identified by the licensing basis is required to respond to. Examples of information anticipated to be included within each appendix are documents reviewed, licensing and design requirements applicable to the particular event, applicable operating experience and corrective actions, the aspects of the current licensing and design basis that can be confirmed, any gaps identified and the PIPs written to enter the gaps into the stations corrective action program, and any conclusions specific to the particular event.

Attachments will be created for important information that is not specific to a particular event.

Examples of information to be included as attachments are tools created to review specific types of documents and tools created to assist with field walkdowns.

Once the final report is completed, an executive summary will be included. The final report, including the executive summary, will then be given a unique identifier (similar to the handling of design studies) and placed into the nuclear electronic document library for retrievability.

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Appendix A Project Schedute 15

ID Task Name start IFinlsh louratlon nQ.4 Dec F Jars I FebI Mar Apr May Jun iulAag SRpj Oyt 0

)tvv PecL Jun. lIck I Marl Apr COMPREHENSIVE DESIGN, LICENSING AND OPERATIONAL REVIEW OF 328 days Mon 1/2/12 Fri 3/29/13 FT H B 6SF - I 1 - 1 LicensIng Basis Reuiw 240 days Mon 1/23/12 Fri 12/21/12 2 1.1 identify and Review Licensing Base documents prior to 1983 60 days Mon 1/23/12 Fri4/13/12

- 3 1.2 White Paper on Licensing Basis Prior to 1983 O days Fri 4/13/12 Fri 4/13/12 4 1.3 List of Licensing Basis documents prior to 1983 0 days Fri 4/13/12 Fri 4/13/12 S 1.4 Criteria for searching licensing documents after 1983 that may have 0 days Fri 4/13/12 Fri 4/13/12 on the SSF Licensing Basis 6 1.5 Identify and Review Licensing Base documents post to 1983 90 days Mon 4/lB/il Fri 8/17/12 7j 1.6 White Paper on Licensing Basis Post 1983 0 days Fri 8/17/12 Fri 8/17/12 8j 1.7 List of Licensing Basis documents post to 1983 0 days Fri 3/17/12 Fri 8117/12 9 1.8 Independently determine 6SF Licensing Basis 90 days Mon 8/20/12 12/21/22 Fri 1.9 Documented Licensing Basis for 5SF 0 days Fri 12/21/12 Fri 12/21/12 11 2 Design Basis (08) Reuiews 270 days MOn 1/30/il Fri 2/B/lI 12 2.1 Identify and Document Generic Set of functions and Events-End 20 days Mon 1/30/12 Fri 2/24/12 Product Generic Islatrix 2.2 Malriu Available identifying Generic Set of functions vs. Events 0 days Fri 2/24/12 Fri 2/24/12 j2/24 14 1

2.3 Identify and Document Events for 5SF Response 30 days Mon 2/27/12 Fri 4/6/12 15 2.4 identify and Document Critical Safety Functions Required by 5SF 30 days Mon 2/27/12 Fri 4/6/12 16 -

2.5 Motrin Available identifying High Level Functions vs. Events Needed 0 days Fri 4/6/12 Fri 4/6/12 for 5SF 17 2.6 For each Critical Safety Function identify and document Sub-Functions 30 days Mon 4/9/12 Fri 5/18/12 to ensure performance of 1SF lB 2.7 Identify and Document Structures, Systems, and Components (SSC5) 30 days Mon 5/21/12 Fri 6/29/12 and Attributes necessary to perform the Sub-Functions identified in previous task.

19 2.8 Documented list of SSC5 and attributes to perform functions and 0 days Fri 6/29/12 Fri 6/29/12 6/lu a uhfun Ct lx ns 20 2.9 Compare Expected Design against actual design, Identify Gaps, and 160 days Mon 7/2/12 Fri 2/8/13 Document Results.

Task e. - -

Project Summary .o Ivaxtive Milestone Mavual Summary Rollup --- Deadline Project: COMFREHENSIVR DESIGN Split ,,...,,,,,,,,,,,,,. Evternal Tasks .--- Inactive Summary V V Manual Summary Prngress Date: Wed 2/14/12 Milestnne External Milestone 3 Mavual Task __ Start-nnly C Summary V

• InactiveTusk _.J Duration-only I Finisk-nsly Page 1 Draft Project Plan for SW Project R12b.rnpp

rank Name Duration Start Finish list Quarter lZndQu an - ) rn.LMnL_L LMvv_Ltun .AgL..

3 Operational Support 270 days Mon 2/6112 Fri 2/15/13 3.1 Initial identification of SSCs requiring operational support based on 30 days Mon 2/6/12 Fri 3/16/12 Operational Team Review of SSF Related Documents 23 3.2 identify activities necessary to support operational implementation. 45 days Mon 3/19/12 Fri 5/18/12 24 3.3 Initial documented list of activities to support operational 0 days Fri 6/18/12 Fri 5/18/12 5/18 implementation of SSF 25 3.4 Determine if operational implementation documents exist to perform 35 days Mon 5/21/12 Fri 7/5/12 required activities as determined by Operational Team Review.

26 3.5 Preliminory White paper discussing operational implementation 0 days Fri 7/5/12 Fri 7/6/12 7/6 document gaps based on initial review by OperationalTeam 27 3.6 Identify activitieS necessary to support operational implementation 20 days Mon 7/2/12 Fri 7/27/12 based on new insights from Engineering Team.

28 3.7 Final documented lint o activities to support operational 0 days Fri 7/27/12 Fri 7/27/12 implementation of 5SF 29 3.8 Determine if additional operational implementation documents eoist 15 days Mon 7/30/t2 Fri 3/17/12 based on results from Engineering Team 30 3.9 Final White paper discussing operational implementation gaps based 0 days Fri 8/17)12 Fri 8/17/12 8/17 on Engineering and Operational Team Reviews 31 3.10 Determine if operational implementation documents are adequate to 160 days Mon 7/9/12 Fri 2/15/13 perform required activities.

32 3.11 White paper/input to Final Team Report results of operational reniewsD days Fri 2115/13 Fri 2/15/13 33 4 CorrectIve Action Program (CAP) and Operating Experience (OE) 205 days Mon zjzo/ii FrI 11/30/12 34 3.1 Identify the population of 5SF relevant PIPs. 15 days Mon 2/20/12 Fri 3/9/12 35 4.2 perform and document review of PIP5 (CAP documents) 170 days Mon 3/12/12 Fri 11/2/t2 36 4.3 Identity types of OE that need to be reviewed for applicability to 5SF. 10 days Mon 2/20/12 Fri 3/2/12 37 4.4 Identify the population of SSF relevant OF 25 days Mon 2/20/12 Fri 3/23)12 38 4.5 Perform and document review of OR documents. 180 days Mon 3/26/12 Fri 11/30/12 5

39 Field Verification and Walkdowns 180 days Mon 4/9/12 FrI 12/14/12 40 5.1 Perform and document Engineering Focused Walkdowns 150 days Mon 4/9/12 Fri 11/2/12 41 5.2 Perform and document Operational Focused Walkdowns 150 days Mon 5/21/12 Fri 12/14/12 Task Project Summary .e Inactive Milestone Manual Summary Rellup Deadline 4.

Frojert COMPREHENSIVE D6SIGN Split External Tasks ------ Inactive Summary V V Manual Summary Progress --

Date Wed 2/16/12 Milestone Enternal Milestone Manual Tank Start-only I aumrnxry

• lnactiueTask IEEZZZZE ..... -- -

Duratien-only Finish-only Page 2 Draft Project Plan for 3SF Project R12b,mpp 1

NJ 0 Task Name DuratIon 5tart Iisiuaflg ,aQmr_. j13a rinlsh Dec tart j Feb Mar Apr May Jun , Jul ,t I Aug.!, 5p NpL0ecLJ4 Fgb,,,..Mr I Am 42 6 Independent Review of products, processes and overall project 285 clays Mon 2/27/12 Fri 3/29/13 management 43 6.1 Develop process(es) for performing the independent review efforts. 60 days Mon 2/27/12 Fri 5/18/12 44 6.2 Process documents eoist for independent reviews 0 duys Fri 5/18/12 Fri 5/18/12 /18 45] 6.3 Schedule und conduct independent review process. 225 days Mon 5/21/12 Fri 3/29/13 46 7 CommunicatIon Protocols 295 days Mop 2/6/12 FrI 3/22/13

- 47 7.1. ldetstify key stakeholders and interfaces 20 days Mon 2/6/12 Fri 3/2/12 48 7.2 Develop communication protocols and expectalions lobe implemented4l days Mon 2/27/12 Fri 4/27/12 with key stakeholdert and interfaces 49 7.3 Develop communication plan 45 days Mon 3/5/12 Fri 5/4/12 SO 7.4 Implement communication plan for the project efforts. 230 days Mon 5/7/12 Fri 3/22/13 51 8 Team Organization and Staffing 45 days Mon 1/2/12 FrI 3/2/12 52 8.1 Determine Organiration Structure Needed for Project 25 days Mon 1/2/12 Fri 2/3/12 53 8,2 Obtain Initial Project Resources 25 days Moo 1/2/12 Fri 2/3/12 94 8.3 Train Project Organization 30 days Moo 1/23/12 Fri 3/2/12 55 9 Project Team LogistIcs 70 days Mon 1/2/12 Fri 4/6/12 56 9.1 SharePoint Setup and Population 60 days Mon 1/16/12 Fri 4/6/12 57 9.2 Develop Initial Meeting Protocols 28 days Mon 1/2/12 Fri 2/3/12 58 9.3 Develop Project Metrics 30 days Mon 2/27/12 Fri 4/6/12

° -

Task Project Summary a -n Inactive Milestone Manual Summary Rollup Deadline 8 Projecl COMPREHENSIVE DESIGN Selit External Tasks Inactive Summary V ) Manual Summary Progress Date Wed 2/15/12 Milestone Eoteraal Milestone a Manual Task Start-only C Summary IvactiveTask r Duration-only .--_ Finislsnnly 2 Page 3 Draft Project Plan for 5SF Project R12b.mpp 3

0 lyask Name Duration Start Finish I 1st Quarter ndQlMrier_r4Qt9cter 1AQ34rsoL11LQvertec, ZsdO.n Pea. Ian [Pph I Mar Spr : May . Lay I Jiyi Feb i Mar Apr 59 10 SecurIty Reviews 230 days Mon 3/5/12 FrI 1/18/13 10.1 Identify and develop list of security activities related to 5SF 30 days Mon 3/5/12 Fri 4/13/12 10.2 Determine security implementation documents that should be in 30 days Mon 3/19/12 Fri 4/27/12 place to support security activities for SSF 10.3 Determine if implementation documents needed to support security 30 days Mon 4/2/12 Fri 5/11/12 activities eyist and document any gaps.

10.4 Gaps with Security implementation documents are documented 0 days Fri 5/11/12 Fri 5/11/12 /iD____

10.5 work with Engineering and Operational Teams to ensure security 180 days Mon 5/14/12 Fri 1/18/13 activities are adequate.

10.6 Gaps in Security implementation activities are documented 0 days Fri 1/18/13 Fri 1/18/13 .1/18

11. Final Team Report 280 days Mon 315/12 FrI 3/29/13 11.1 Develop Team Report Outline and assign Team Report sections to 30 days Mon 3/S/12 Fri 4/13/12 individual team members 68 11,2 Sturt inputting draft information into the sections that will be requirvdlgo days Mon 4/16/12 Fri 1/4/13 j for the final team report.

69 11.3 Consolidate the team sections into one report. 30 days Mon 1/7/13 Fri 2/is/IS 70 11.4 Draft Team Report Available for Review 0 days Fri 2/is/is Fri 2/15/13 71 11.5 Review and revise Soul report as required. 30 days Mon 2/18/13 Fri 3/29/13 72 11.6 Final Team Report is in place 0 days Fri 3/29/13 Fri 3/29/13 8/29 Tush Prujert Summary i  %. Inactive MIlestone Manual Summary Rullup Deadline 4 Frojecl COMPREHENSISE DESIGN Spilt ...,..........,. External Tasks ----------- --

InactIve Summary V V Manual turrimary

• Progress Date: Wed 2/15/12 Milestone Eetersal Milestone 1 Manual Task Start-only Summary Inactive Task czZZ.:E.Z Duration-only ----.

Finish-only Page 4 Draft Project Plan For SSF Project RiZb.mpp 4

Appendix B Simplified Project Organization Chart Management Sponsor Bill Pitesa Communication w/

Management

- Management Lead site, input to

• Consultant I.enny A2zarello budgeting process

• Bryan Dolan I Special Consultant i Teclinical Team Project Manager Leader KenBrockman T Kerry Landis L____*1 I

Corrective Action, Operational Team Design Team Licensing Team Operating Marty Cooper Mike Shtyamberg Jack Crlenjak Experience Rob Sandstrom

Appendix C Project Team Members Assessors Name Functional Responsibility Company Mr. Lenny Azzarello Management Lead Duke Energy Mr. Kerry D. Landis Team Leader Landis Consulting, LLC Mr. Bryan Dolan Management Consultant Synergoi, LLC Mr. Kenneth E. Independent Review Team Landis Consulting, LLC Brockman and Security Mr. Harold Security SME Landis Consulting, LLC Eichenholz Mr. Mike Stinson Security SME Landis Consulting, LLC Independent Review Team Mr. Bill Subalusky Landis Consulting, LLC Member, Operations Dr. Omar S. Mazzoni Independent Review Team Nuenergy, Inc.

(OSM) Member, Electrical Dr. Hugh, D. Independent Review Team Nuenergy, Inc.

Campbell (HDC) Member, Mechanical Mr. Robert Pl&R SME Lead Landis Consulting, LLC Sandstrom Mrs. Nance Henry PI&R Team Support Landis Consulting, LLC Mr. Robert (Bob)

PI&R Team Support Landis Consulting, LLC Schin Mr. William(Bill)

PI&R Team Support Landis Consulting, LLC Johnson TBD PI&R Team Support Landis Consulting, LLC TBD Pl&R Team Support Landis Consulting, LLC

Assessors Name Functional Responsibility Company Operations Lead Assessor Mr. Marty Cooper Landis Consulting, LLC (Ex-Ops Manager)

Mr. Ron Aiello Operations Support Landis Consulting, LLC Mr. Larry Mellen Operations Support Landis Consulting, LLC Mr. Robert (Bob)

Maintenance SME Landis Consulting, LLC McPherson Mr. Walt Rogers PRA SME Landis Consulting, LLC Mr. Richard (Jack) V.

Lead Licensing Assessor Nuenergy, Inc.

Crlenjak (JC)

Mr. Gus Alberthal Licensing Assessor Nuenergy, Inc.

(GA)

Mr. Gabor (Gabe)

Licensing Assessor Nuenergy, Inc.

Salamon (GS)

Mr. James (Jim)

Licensing Assessor Landis Consulting, LLC Raleigh Mr. Robert (Rob)

Licensing Assessor Nuenergy, Inc.

Berryman Mr. Michael Design & Licensing Team Nuenergy, Inc.

Shlyamberg (MS) Lead TBD Mechanical Assessor Nuenergy, Inc.

TBD Mechanical Assessor Nuenergy, Inc.

Mr. Harold (Harry) Electrical Assessor, EDG, Nuenergy, Inc.

Epstein (HE) General Electrical & EQ Mr. Ladislau (Larry) Electrical Assessor, General Nuenergy, Inc.

Hajos (LH) Electrical, & EQ Mr. James (Jim)

I&C Nuenergy, Inc.

Leivo (JL)

Mr. Viktor lvanov (VI) I&C Nuenergy, Inc.

2

Assessors Name Functional Responsibility Company Mr. Victor (Vic) P.

Civil Structural Nuenergy, Inc.

Ferrarini (VPF)

Ms. Fleurdeliza (Fleur) A. dePeralta Fire Protection Nuenergy, Inc.

(FdP)

Mr. Thomas (Tom) J.

Fire Protection Nuenergy, Inc.

Casey (TJC)

Mr. Thomas D. Curtis SSF Subject Matter Expert Nuenergy, Inc.

(TDC)

Mr. Gregg Thermal Hydraulic Analysis G.S. Nuclear Swindlehurst SME Consulting, LLC ERIN Engineering and Mr. Steve Nader PRA & Mechanical SSF SME Research, Inc.

3

Appendix D Critical Safety Function versus Event Matrix Event A Event B Event C Event D Event N

Appendix E Industry Configuration Management Model Licensing, Design Actual Plant Facility Configuration Configuratio Documentation