IA-96-339, Forwards Facility Restart Assessment Plan,For Review & Approval
| ML20128G511 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/12/1996 |
| From: | Lanning W, Mckee P NRC (Affiliation Not Assigned), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miller H, Zimmerman R NRC (Affiliation Not Assigned), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20128G476 | List: |
| References | |
| FOIA-96-339 NUDOCS 9610090053 | |
| Download: ML20128G511 (26) | |
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c, e Septem'oer 12,1996 4
MEMORANDUM TO: Hubert J. Miller, Regional Administrator, RI i
Roy Zimmerman Associate Director for Projects Office of Nuclear Reactor Regulation l
FROM: Wayne D. Lanning, Director Millstone Oversight Team, RI )
Phillip F. McKee, Director Northeast Utilities Project Directorate Office of Nuclear Reactor Regulation l
SUBJECT:
MILLSTONE RESTART ASSESSMENT PLAN 1 l
Attached for your review and approval is the Millstone Station Restart Assessment Plan I which encompasses the NRC Manual Chapter MC 0350, Staff Guidelines for Restart l l Approval. The Millstone Oversight Team (MOT) will fulfill the role of Restart Panel for the l purposes of MC 0350. This assessment plan is applicable to Millstone Unit 3, and, once
! approved, will be maintainsd and updated as necessary by the Millstone Oversight Team. l l The MOT intends to make minor revisions without seeking additional approval; however, if I a significant revision is made to the plan, you will be notified and requested to approve the l change. The restart plans for Units 1 and 2 will generally contain the same generic issues l supplemented with plant specific technical issues.
l The restart assessment plan consists of several major elements requiring close coordination i of NRC resources. First, the MOT is emphasizing the broader programmatic issues being addressed by the licensee in their improving Station Performance Program. These are the underlying issues that have contributed to the decline in the licensee's performance. The second area is the licensee's responses to the 10 CFR 50.54 (f) letters for each of the units and the associated NRC Confirmatory Order. Lastly, the MC 0350 overview process and the Operational Safety Team inspection will be tailored to the restart of the specific unit.
l 9610090053 961001 PDR FOIA WILLIAM 96-339 PDR 7')
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i 2 i The MOT will continue to meet with the licensee and the public regarding this plan. l Accordingly, this plan will be a living document and updated periodically. i l
Original Signed By: Original Signed By: [
Phillip F. McKee, Director Wayne D. Lanning, Director Northeast Utilities Project Directorate Millstone Oversight Team Office of Nuclear Reactor Regulation Region I s
4 Original Signed By: Original Signed By: ,
Approved:
Roy Zimmerman Date Hubert J. Miller Date i
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i DOCUMENT NAME: G:\ BRANCH 6\MSACTION.96 Ts meelve a copy of this document. Indicate in the boa: 'C' = Copy wthout attachment / enclosure 'E' = Copy mth attachment / enclosure 'N' = No copy OFFICE Rl/DRP l Rl/ MOT l / l l l NAME JDurr WLanning DATE 09/13/96 09/ /96 09/ /96 09/ /96 09/ /96 OFFICIAL RECORD COPY I
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REV 9/12/96 MILLSTONE RESTART ASSESSMENT PLAN
1.0 BACKGROUND
The three Millstone Units are shut down to formulate responses to a series of
, 10 CFR 50.54 (f) letters requiring them to affirm their compliance with the conditions of each unit's license and the regulations. The NRC performed a series of inspections at Units 2 and 3 with a 20 person Special inspection Team (SIT) to ascertain the extent of their compliance. Currently, the results of those inspections am under assessment by the team and NRC management. The licensee is focusing on Unit 3 as the lead plant for restart, and is directing resources from the other units to concentrate on completing one unit at a time.
On June 28,1996, the Executive Director for Operations issued a letter to the licensee that stated the Commission had decided to make the three Millstone units a
, Category 3 on the Watch List and would vote on the restart of the Millstone units.
l It is the intent to implement the appropriate aspects of NRC Manual Chapter 0350, j
" Staff Guidelines for Restart Approval" for the restart of all three units. The NRC- j l will schedule and implement its inspection program after the licensee has indicated
! that the activities necessary for restart are complete and ready for inspection. The NRC has been dealing with Northeast Utilities on broader performance issues which go beyond the 10 CFR 50.54(f) concerns. These broader concerns are considered 4 contributory causes for the current poor performance, which the 10 CFR 50.54(f) l issues are a subset. These issues have been formalized by the licensee in a i program titled " improving Station Performance" (ISP) and are topics that will be {
addressed by the licensee and reviewed by the NRC Millstone Oversight Team i i
(MOT). A meeting was conducted on April 30,1996, and disclosed that the l licensee was not adequately managing the program nor tracking progress.
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l The salient concerns embodied in the ISP include leadership, communications ;
l (employee concerns), the corrective action program, procedural adherence and l procedure upgrades, work planning and control, and operational enhancements.
l The NRC restart assessment program will focus on the broader issues of the ISP and licensee self assessments and management ov.ersight, recognizing the necessity to ensure adequate closure of the 10 CFR 50.54(f) process. The NRC plan for inspection of the Improving Station Performance issues is discussed in more detail in Section 3 of this plan.
2.0 10 CFR 50.54(f) Activities Each Millstone unit has been requested to submit information describing actions taken to ensure that future operations will be conducted in accordance with the terms and conditions of the operating license, the Commission's regulations, and j the Final Safety Analysis Report. The NRC requested that the information be submitted no later than 7 days prior to the restart of the respective Millstone units.
In the May 21,1996 letter, the NRC requested NU to provide for each unit its plans for completing the licensing bases reviews.
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To aid in NRC understanding of how deficiencies were identified and dispositioned, the NRC's May 21,1996, letter also requested that NU provide for each Millstone unit a comprehensive list of design and configuration deficiencies and information ,
related to how each deficiency was identified and will be dispositioned. l On August 14,1996, the NRC issued a Confirmatory Order establishing an Independent Corrective Action Verification (ICAV) program. The independent effort will verify the adequacy of NU's efforts to establish adequate design bases and design controls, including translation of the design bases into operating procedures and maintenance and testing practices, verification of system performance, and implementation of modifications since issuance of the initial facility operating licenses. The NRC oversight of the ICAV program and activities will be separate from, and in addition to the activities described in this restart assessment plan. The l results from this program will be incorporated into this restart plan and considered a '
significant part of the decision regarding recommended restart. The deficiencies I found by the licensee as a result of the 50.54(f) letters will be evaluated by the Millstone Oversight Team (MOT) to identify restart issues. I I
3.0 MC 0350 Process l l
Millstone Unit 1 entered a routine refueling outage in October 1995. At the January 1996 Senior Management Meeting, the site was placed on the " Watch List" for ,
various reasons, including a concern for regulatory compliance. Subsequently, the NRC sent a 10 CFR 50.54(f) letter requiring the licensee to certify compliance with the regulatory requirements before restarting the unit. Subsequently, Millstone Units 2 and 3 were sent similar letters which required responses before restart.
The NRC Inspection Manual, Manual Chapter 0350, " Staff Guidelines For Restart Approval", provides guidelines and a list of tasks and activities that must be considered before a plant that has been shutdown for cause can restart. Because of NRC concerns relating to the licensee's management effectiveness, the appropriate aspects of MC 0350 will be applied to the restart of Units 1,2 and 3 to ensure applicable requirements have been met (Enclosure 2).
The regional inspection effort will focus on selected areas of the ISP and completing the routine inspection program requirements. This assessment plan will be maintained and updated by the Millstone Oversight Team (MOT). It is intended that the MOT willidentify new issues to be added to the plan as the Millstone facilities restart plans evolve; there is no intent to have NRC management approve minor changes to this assessment plan.
The Regional Aiministrator, in coordination with the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, and the Director of Nuclear Reactor 3egulation (NRR), will make a recommendation regarding restart.
NRR and the Region willinform the Commission of the staff's and licensee's restart activities through Commission papers, or communications to the EDO. The Commission will then vote on whether to approve the restart of each Millstone unit.
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l 3.1 MILLSTONE OVERSIGHT TEAM ,
l The Millstone Oversight Team (MOT) is composed of the Director, Millstone l Oversight Team, the Director, Northeast Utilities Project Directorate, the Project l Managers for the three Millstone units, the DRP Project Branch Chief, the Senior Resident inspectors for the three Millstone units and the appointed Division of 1 Reactor Safety representative. The function of the Millstone Restart Panelis described in Manual Chapter 0350 and will be fulfilled by the MOT. -
l 3.2 MILLSTONE OPERATIONAL READINESS PLAN On July 2,1996,'NU submitted the Unit 3 Operational Readiness Plan, which was discussed at the July 24,1996 meeting and updated at the August 19,1996 meeting. The MOT will review this plan and hold periodic meetings with Northeast Utilities, open to the public, to discuss the schedule for implementation and coordination of NRC restart activities.
On August 13,1996, NU submitted the Operational Readiness Punchlist items identified for restart. The deficiency list, which will be updated periodically, includes restart and deferred items, and will be audited to verify the acceptability of the criteria used to defer items from the restart list.
3.3 CORRECTIVE ACTION PROGRAM l l
The NU corrective action program has been weak in ensuring comprehensive and i effective corrective actions. There are many instances of narrowly focused I corrective actions that failed to embrace all aspects of the underlying problem.
Additionally, the licensee has failed to follow up on corrective actions to ensure they were effective. Consequently, the MOT has determined that any restart effort should examine the current state of the licensees corrective action program.
Because of the large number of Adverse Condition Reports (ACR) being identified by the licensee's staff, the resident and regional inspection staff will concentrate on issues for esch unit identified by the ACR process and audit the licensees corrective actions for completeness. The staff has selected level"A" and "B" ACR's for review. Additionally, other ACR's will be examined to provide a spectrum of safety significant and lessor risk issues. The initial list of selected items is contained in Enclosure 1.
The intent is to primarily assess the corrective action program while dealing with the safety significant technical issues. Examination of the corrective action program needs to review the Action Requests (AR) from the AcCon item Tracking and Trending System (AITTS) program, which is an extensima of the ACR process, and commitments regarding violations and inspection iteme. Further, a significant input to assessing the licensest's corrective action program is derived from the normal inspection program where valuable insights regarding the effectiveness of corrective actions are routinely collected from the technical safety inspections.
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i Additionally, the NRC Independent Corrective Action Verification team will assess the licensee's corrective actions for degraded and non-conforming conditions.
Finally, the Operational Safety Team inspection (OSTI) will audit portions of the corrective action process during the course of its activities.
Demonstration of improvements in the process will be judged by the completeness
" of the licensee's corrective actions for each of the inspected ACR's. There must be i a high ratio of successfully completed ACR's to the total population inspected. l There should only be minor comments regarding the processing, evaluation, directed corrective actions and closure of an issue.
3.4 WORK PLANNING' AND CONTROLS (C.4.)'
Work planning and controls are other areas that the licensee has shown a weakness. The ability to plan, control and complete work is fundamental to achieving adequate corrective actions. Effective work planning and controls are prerequisites for reducing and managing backlogs. Weak work planning and control was demonstrated during the Unit 2 outage wherein tagging boundary violations resulted in an extensive effort by the licensee to correct. Work control and planning were also issues at Unit 1, which resulted in a management meeting.
There will be a complete review of the Automated Work Order (AWO) process by the resident or regional staffs. The automated work order process is an integral part of the work planning and control system and is instrumental in establishing the scope of the work, providing the appropriate procedures, and establishing the tagging boundaries. Consequently, the Unit 1 resident staff has been directed to use the available initiative inspection hours to do a comprehensive inspection of the AWO process, which is a site wide process.
The OSTI will assess the engineering and maintenance backlogs during its operational readiness inspection. The OSTI will determine if there are safety significant issues that must be resolved before restart.
3.5 PROCEDURE UPGRADE PROGRAM (C.3.3.e)
The quality and adherence to procedures has been a chronic problem at the Millstone site. The issue was an element in " Improving Station Performance" and was one of the subjects of discussion at the periodic meetings between Northeast Utilities and the NRC. In response to NRC concerns, the licensee developed the Procedure Upgrade Program in the early 1990's to improve station procedures.
The resident inspectors will relate procedural inspection findings back to the procedural upgrade program (PUP), identifying whether the procedures reviewed during the course of an inspection have been upgraded and characterize the quality
, of the document. This will establish a basis for assessing the effectiveness of the
' Reference to applicable MC 0350 section 4
licensee's PUP. The NRC staff wil' develop an inspection plan for examining l selected portions of each unit's individ efforts.
3.6 OVERSIGHT (C.1.4 )
l The licensee has identified its oversight function as deficient through self l assessments and external and internal audits and a contributing factor in the licensee's declining performance. The report of Msessment of Past ineffectiveness of Indeoendent Oversiaht by YAEC examined the failure of Quality Assessment Services, the Independent Safety Evaluation Group, and the Nuclear Review Board (NRB) to identify the deficient FSAR control process and the radioactive waste ,
conditions. They'found that management did not support these functions l adequately. l in addition, the Joint Utilities Management Association (JUMA) issued its report on July 17,1996. One conclusion was that the quality assurance program audits, surveillances, and inspections were not effective in the implementation of their mission and resolution of identified problems. In addition, the JUMA audit found that recommendations for improving QA effectiveness identified in previous QA internal and external assessments have not been addressed.
The NRC assessment of the nuclear oversight function is addressed as part of the MOT's review of the ISP program and through insights gained from the normal inspection program. In addition, the NRC will perform a specialinspection of the oversight function using the services of its Human Factors Assessment group. Late in the restart process for each unit, there will be an inspection to evaluate the effectiveness of the oversight groups and management's utilization of the oversight process. There should be positive indications that the oversight function has been made an integral part of the licensee's management team assessment process. The oversight function should result in meaningful findings, have access to line management and provide assessments of process and program effectiveness through periodic reports. There should be evidence that the rerorts are forwarded to the responsible manager and that they have dealt with the intents appropriately. Oversight should be adequately staffed witi: valified and experienced personnel. The audit and surveillance programs need to be clearly defined, proceduralized, and implemented with established schedules.
3.7 ENFORCEMENT Outstanding enforcement items will be reviewed by the resident inspectors to determine if any issues require closure before plant restart. The outstanding restart enforcement items will be added to the NRC Significant issues List. The agency is currently accumulating escalated enforcement items concerning the spent fuel pool and design bases issues which may require licensee response before recommending restart of each unit. There are also potential enforcement items that will result from l the efforts of the Office of Investigations, the allegation process review group, the l Office of the inspector General, the Special Inspection Team, routine resident and l
regional inspection efforts and the 10 CFR 2.026 petition process. The culmination 5
of this process is not fully developed at this time. The Office of Enforcement and the Millstone Enforcement Panel have the lead responsibility for this process. The results from this process will be formalized and incorporated into this assessment plan.
, 3.8 EMPLOYEE CONCERNS The Millstone site has had a chronic problem in dealing effectively with employee concerns. The NRC continues to receive an inordinate quantity of allegations from the staff at the Millstone site. The current series of 10 CFR 50.54(f) letters were initiated as a result of an allegation and subsequent 10 CFR 2.206 petition dealing with the Unit 1 spent fuel pool. The NRC has issued two enforcement actions for harassment and intimidation to Northeast Utilities in the past three years and has a current escalated enforcement action pending.
The NRC has initiated two task groups to examine the Northeast Uti!; ties handling of employee concerns and the recent layoffs that affected several previous allegers.
The task group examined Northeast Utilities han^ of employee concerns and identified a number of root causes for the licensee - roblems in this area. The task group also concluded that past problems and their root causes still remain. The output from these two task groups and the licensee's response to their findings will be raviewed for restart issues as well as potential enforcement actions.
3.9 SIGNIFICANT ISSUES LIST The technique used for the restart will be to reach agreement with the licensee on its restart issues list, have it impose controls on adding or deferrhg items from the list, have the resident inspectors review the list to ensure it incluoed issues of interest to the NRC and have the residents review the deferred list to ensure appropriate rationales for deferral have been documented (See item B.4.3. of MC 0350). As the result of the 10 CFR 50.54(f) activities, the licensee initially determined that about 600 items did not meet criteria for inclusion as a restart item.
The resident inspector, augmented by headquarters staff, reviewed this list and confirmed that the licensee performed an adequate assessment of the discrepancies. This process will be used in the restart assessment of each unit.
The MOT will determine that the licensee's restart issues list includes appropriate restart items from the licensee's programs such as ACR, AR (AITTS), engineering work requests, and commitments.
The enclosed NRC Significant issues Lists will contain items that are being used to audit and evaluate licensee programs such as the corrective action process and significant safety / regulatory technical issues.
Restart issues will meet at least one of the following criteria:
- 1. Resolution of the issue is required to ensure safe operation of the facility to include satisfaction of the technical specifications or licensing basis.
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- 2. Inspection of the issue will provide an insight to an identified j programmatic deficiency such as the corrective action system. !
- 3. Inspection of the issue will provide assessment of management effectiveness or personnel performance.
3.10 RESTART INSPECTION Selected portions of NRC Manual Chapter 93802, " Operational Safety Team 1 Inspection," will provide the framework for a team inspection of each unit dunng i restart. The inspection will cover self-assessments by the licensee, the licensee's I implementation of its startup plan, control room observations during the approach to i criticality and power ascension, selected systems readiness inspection and I observation of management oversight.
The resident inspectors will provide close monitoring of each unit during mode changes to ensure compliance with each unit's technical specifications and FSAR design bases.
3.11 PLANT PERFORMANCE REVIEW On May 16-17,1996, the MOT conducted a Plant Performance Review. The Plant Performance Review was used to identify the issues that needed to be inspected for the Millstone Station. The review identified severalissues that warrant NRC i inspection before plant restart of the unit. The unit specific issues as well as i station wide issues identified by the PPR are contained in the Significant issues List for each unit as inspection items.
3.12 LICENSE AMENDMENTS Millstone Unit 3 currently has two license amendments required for startup in the review process. They are: 1) the over temperature A T time constants and the steam line pressure negative rate high steam line isolation time constant; and 2) change operational modes with both shutdown margin monitors inoperable and to revise the locked valve list.
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Enclosure 1 MILLSTONE UNIT 3 SIGNIFICANT ITEMS LIST REF. ITEM RESP 8 STATUS ACR RSS AND QSS PIPING TEMPERATURE NRR 10733 MAYBE HIGHER THAN ANALYZED (NRR DRS SUPP.
- REVIEW ENG. ANALYSIS, DRS INSPECT INSTALLATION)
ACR DEGREE FSAR NEEDS TO BE UPDATED NRR 01148 BEFORE RESTART ACR REACTOR POWER INCREASE WHEN DRP 05715 UNBORATED CATION DEMIN PLACED INTO SERVICE 3CHS-DEMIN2 ACR EDG SEQUENCER CDA SIGNAL OUTPUT DRS 01895 "A" TRAIN COMPONENTS STARTED ACR FAILURE'TO ENTER AN ACTION DRP 01844 STATEMENT WHEN MSIVS WERE CLOSED ACR RCP SEAL INJECTION FILTER "B" DRP 04199 GASKET FAILED RESULTING IN SPILL OF COOLANT TO FLOOR DRAINS ACR RCS CHECK VALVE BODY TO BONNET DRP 06092 LEAK; 3 RCS*V146 ACR WHILE DEWATERING SPENT RESIN, THE DRP 01535 WASTE TEMPERATURE IN THE LINER RAISED FROM 90 TO 310'F ACR NEED FOR ADDITIONAL REVIEW OF DRS 10543 RESPONSE TIME TESTING FOR PROCEDURES ACR CLOSURE OF PIR WITMOUT DRP 11322 ADDRESSING DESIGN FEATURE OF AFFECTED COMPONENTS ACR TURBINE DRIVEN AUX FEEDWATER DRP 10774 DESIGN CONCERN ACR CONTAINMENT FOUNDATION EROSION NRR 6323 l ACR CCP SYSTEM OPERATION ABOVE DRP 10800 DESIGN TEMPERATURE l 2 Responsibility
MILLSTONE UNIT 3 Continued REF. ISSUE RESP. STATUS ACR SGCS OPERATIONAL CONFIGURATION DRS 7745 CONTROL ACR LETDOWN HEAT EXCHANGER LEAKAGE DRP M3 AND DESIGN DISCREPANCIES 0159 ACR DUAL FUNCTION VALVE CONTROL AND DRP/NRR 01935 TESTING ACR RCP SEAL HOUSING LEAKAGE AND DRS 7266 BOLT CORROSION 10700 CONTROL AND USE OF VENDOR DRS INFORMATION RESOLUTION OF AFW VALVES AND DRS HELB REVIEW OUTPUT FROM J. HANNON PE EMPLOYEE CONCERNS REVIEW ENFORCEMENT AND SRI UNRESOLVED ITEMS FOR ITEMS FOR I
RESTARTISSUES REVIEW NRR SPECIAL TEAM FINDINGS NRR FOR RESTART ISSUES REVIEW ALLEGATIONS FOR RESTART PE/NRR ISSUES REVIEW ALL OPERABILITY SRI DETERMINATIONS AND BY-PASS JUMPERS BEFORE RESTART FATIGUE CYCLE OPEN ITEMS IP 3'7750 DRS COMPL.
PART 70 STORAGE AND INVENTORY IP DRS COMPL.
84750 2
l MILLSTONE UNIT 3 REF. ISSUE RESP. STATUS FORMALITY OF NON-ROUTINE DRS SECURITY ACTIVITIES AND NEW FUEL 4 SECURITY IP 81064 ESSIG LACK OF ON SHIFT DOSE DRS MEMO ASSESSMENT CAPABILITY OVERLAP TESTING OF RPS/ESF DRS REVIEW LICENSEE EVENT REPORTS SRI FOR RESTART ISSUES.
MATERIAL, EQUIP. AND PARTS LIST NRR (MEPL) PROGRAM EVALUATION MOTOR OPERATED VALVE PROGRAM DRS GL89-10 PORV/SG DUMP VALVES PPR RESIDENT EMPHASIS: MISSED SRI G.1.C SURVEILLANCES PPR RESIDENT EMPHASIS: DILUTION SRI G.1.C EVENTS PPR RESIDENT EMPHASIS: FEEDWATER SRI G.1.C HAMMER PPR RESIDENT EMPHASIS: CHECK VALVE SRI G.1.C LEAKAGE PPR RESIDENT EMPHASIS: WORK- SRI G.1.C AROUNDS ~ .
PPR RESIDENT EMPHASIS: SURVEILLANCE SRI j G.2 CONTROL,MAINT. CONFLICT l PPR RESIDENT EMPHASIS: USE OF SRI l G.2 VENDOR INFORMATION PPR RESIDENT EMPHASIS: AWO QUALITY SRI G.2 AND BACKLOG CONTROL PPR RESIDENT EMPHASIS: ABUSE OF USE- SRI G.2 AS-IS FOR DEFICIENCIES PPh RESIDENT EMPHASIS: SEISMIC 11/1 SRI G.2 l 3 i
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1 REF. ISSUE RESP. STATUS EFFLUENT / ENVIRONMENTAL DRS SAMPLING AND ANALYTICAL 4 PROFICIENCY RADWASTE SYSTEMS / CONTROLS DRS HEAT EXCHANGER PERFORMANCE DRS (GL 89-07) ' SRI 1R96-04 REVIEW LICENSEE CORRECTIVE SRI ACTION PROGRAMS FOR EFFECTIVENESS TO INCLUDE ACR's AND NCR's REVIEW 0737 ACTION ITEMS FOR DRP COMPLETION REVIEW ENGINEERING BACKLOGS DRS REVIEW 50.54F ISSUES FOR MOT RESTART NRR ACR REVIEW SELF ASSESSMENT ROOT DRP 7007 CAUSES AND VERIFY CORRECTIVE ISP ACTIONS GL HEAT EXCHANGER PERFORMANCE SRI 89-13 DRS FIRE PROTECTION PROGRAM DRS ORDER PHASE ll OF THE ICAVP NRR 4
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ENCLOSURE 2 l MILLSTONE UNITS 3 l
l RESTART APPROVAL 4
The following items are considered applicable to the restart of Millstone Units 3:
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4 UNIT 3
- BESPONSIBILITIES AND AUTHORITIES NEED STATUS RESP 4.0 Director, Office of Nuclear Reactor Reaulation (NRR). X C NRR i 1 Notifies the Executive Director for Operations (EDO) and the Commission, as appropriate, of the NRC actions taken concerning shutdown plants and the j proposed followup plan.
4.0 Reaional Administrator X C RA 2
l a. Discusses with the Deputy Executive Director j for Nuclear Reactor Regulation, Regional
- need for an order or confirmatory action letter
] (CAL) specifying the actions required of the j licensee to receive NRC approval to restart the 4 plant and the proposed followup plan.
j b. Decides, in consultation with the NRR X C RA j Associate Director for Projects, whether this ,
j manual chapter applies to a specific reactor )
2 restart. j l
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I c. In coordination with the NRR Associate Director X C RA i for Projects, decides whether to establish a
- Restart Panel. j
- d. In coordination with the cognizant NRR X C mot Director, Division of Reactor Projects, develops a written Restart Assessment Plan, including a case-specific checklist, to assign responsibilities and schedules for restart actions and ,
interactions with the licensee and outside organizations.
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- e. Coordinates and implements those actions X mot prescribed in the Restart Assessment Plan that have been determined to be the regional office's responsibility. These include, wher 4 appropriate, interactions with State and locai agencies and with regional offices of Federal agencies.
- f. In conjunction with NRR, reviews and X MOT determines the acceptability of licensee's SRI corrective action program. OSTI 1 I
Director of NRR, and approval / vote by the !
Commission.
4.03 NRA Associate Director for Proiects
- a. Acts as the focal point for discussions within X zimmer man NRR to establish the appropriate foliowup actions for a plant that has been shut down.
4.04 NRR Reactor Projects Division Director
- a. Coordinates participation in followup X conference calls and management discussions to ensure that the Regional Administrator and the Director of NRR are directly involved, when appropriate, in followup action.
Coordinates and implements actions prescribed x McKee b.
in the Restart Assessment Plan that have been determined to be NRR's responsibility. These include, where applicable, appropriate NRC Office or NRR Division interaction with other Federal agencies (e.g., Federal Emergency Management Agency (FEMA), Department of Justice (DOJ)) pursuant to any applicable Memoranda of Understanding.
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NEED STATUS RESP. ,
l B.1 INITIAL NRC RESPONSE NA 4 !
The facts, the causes, and their apparent impacts should be established early in the process. This information will assist the,NRC in characterizing the problems, the safety significance, and the regulatory issues. Early )
management appraisal of the situation is also important to ensure the proper immediate actions are taken. The following items should have been
, completed or should be incorporated ,
into the CSC as appropriate. Refer to l Section 5.02 of this manual chapter for I additional information.
- a. Initial notification and NRC NA ,
management discussion of l known facts and issues l 1
- b. Identify / implement additional NA inspections (i.e. AIT, llT, or Special) (Region).
- c. Determine need for formal NA regulatory response (i.e. order or CAL).
- d. Identify other parties involved NA (i.e., NRC Organizations, other Federal agencies, industry organizations).
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NEED STATUS RESP.
B.2 NOTIFICATIONS NA 4 initial notification of the event quickly communicates NRC's understanding of the event and its immediate response to the parties having an interest in the event.
Notification to regional and headquarters offices of cognizant Federal agencies may be appropriate. As the review process continues, additional and continuing notifications may be required,
- a. Issue Daily and Directors Highlight NA (NRR).
- b. Issue preliminary notification NA (Region).
- c. Conduct Commissioner assistants' NA briefing.
- d. Issue Commission paper (NRR). NA
- f. State and local officials notified NA I (Region).
- g. Congressional notification (NRR) NA 9
PROCESS B.3 NEED STATUS RESP.
B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW -
4- PROCESS c mot
- a. Establish the Restart Panel. X
- b. Assess available information (i.e. X mot inspection results, licensee self-assessments, industry reviews).
- c. Obtain input from involved parties both X mot within NRC and other Federal agencies such as FEMA, EPA, DOJ.
- d. Conduct Regional Administrator briefing X Moi (Region).
- f. Develop the case-specific checklist (CSC). X C mot
- g. Develop the Restart Assessment Plan. X C mot
- h. Regional Administrator approves Restart X C RA Assessment Plan.
- j. Implement Restart Assessment Plan. X mot
- k. Modify order as necessary X NRR 10
NEED STATUS RESP.
B.4 REVIEW IMPLEMENTATION B.4.1 Root Causes and Corrective Actions oSTI MOT
- a. Evaluate findings of the special team X inspection,
- b. I.icensee performs root cause analysis X NU and develops corrective action plan for sTi root causes.
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- c. NRC evaluates licensee's root cause X osTI determination and corrective action plan.
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t NEED STATUS RESP B.4.2 B.4.2 Assessment of Eauioment Damaae NA For events where equipment damage occurs, a l 4 thorough assessment of the extent of damage is ,
necessary. A root cause determination will be '
necessary if the damage was the result of an internal event. The need for independent NRC
, assessment should be considered. The licensee will need to determine corrective actions to repair, test, inspect, and/or analyze affected systems and equipment. These actions are required to restore or verify that the equipment will perform to design requirements. Equipment modifications may also be required to ensure performance to design requirements, i
Potential offsite emergency response impact for ,
external events such as natural disasters, j explosions, or riots should be considered. NRR '
should obtain information from FEMA headquarters reaffirming the adequacy of State and local offsite emergency plans and preparedness if an event raises reasonable doubts about emergency response capability.
- a. Licensee assesses damage to systems and NA components.
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- b. NRC evaluates licensee damage NA j assessment,
- c. Licensee determines corrective actions. NA i
l d. NRC evaluates corrective actions. NA 12
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B.4.3 Determine Restart issues and Resolution X MOT 4- The establishment of the restart issues that require resolution before restart demands a clear understanding of the issues and the actions required to address those issues by both the NRC and the licensee. This section outlines steps to determine the restart issues and NRC's evaluation of their resolution,
- a. Review / evaluate licensee generated restart X MOT issues.
- b. Independent NRC identification of restart X MOT issues
- c. NRC/ licensee agreement on restart issues. X mot .
1
- d. Evaluate licensee's restart issues X MOT implementation process.
- e. Evaluate licensee's implementation X sm verification process.
13
l NEED status RESP. ;
J B.4.4 Obtain Comments Since some shutdowns involve a broad number of l
4 issues, solicitation of comments from diverse sources I may be appropriate. The decision to soticit comments from a group and the level of participation should be made on a case-by-case basis. Input from these ;
groups should'be factored into the restart process )
when they contribute positively to the review. Note: If !
needed, comments concerning the adequacy of state l
! and local emergency planning and preparedness must Mor be obtained from FEMA headquarters through NRR.
- a. Obtain public comments. X
- b. Obtain comments from State and Local X sto Officials (Region).
- c. Obtain comments from applicable X NRR I Federal agencies.
B.4.5 Closeout Actions When the actions to resolve the restart issues and significant concerns are substantially complete, closeout actions are needed to verify that planned inspections and verifications are complete. The licensee should certify that corrective actions required before restart are complete and that the plant is physically ready for restart. This section provides actions associated with completion of significant NRC uoi reviews and preparations for restart. osT
- a. Evaluate licensee's restart readiness self-assessment (Region). X
- b. NRC evaluation of applicable items from X MOT Section C "lSSUES" complete.
- c. Restart issues closed. X mot SRI osTI l
- d. Conduct NRC restart readiness team inspection X osTi (Region),
- e. issue augmented restart coverage inspection X osTi plan (Region).
14
. . I NEED STATUS RESP.
- f. Comments from other parties considered. X mot 4 g. Determine that all conditions of the Order / CAL X NRR are satisfied,
- h. Re-review of Generic Restart Checklist X mot SRI complete.
B.5 HESTART AUTHORIZATION (B.5)
When the restart review process has reached the point that the issues have been identified, corrected, and reviewod, a restart authorization process is begun. At this point the Restart Panel should think broadly and ask: "Are all actions substantially complete? Have we overlooked any items?"
- a. Prepare restart recommendation document and basis for restart (Region). X mot
- b. NRC Restart Panel recommends restart X mot
- c. No restart objections from other applicable HQ X McKee offices.
- d. No restart objections from applicable Federal X MOT agencies. 1 l
- e. Regional Administrator concurs in restart X RA j recommendation
l l
NEED STATUS RESP.
4 j. Commission concurs In Restart Authorization. X couu
- k. Regional Administrator authorizes restart. X RA B.6 RESTART AUTHDRIZATION NOTIFICATION (B.6)
Notify the applicable parties of the restart authorization.
Notifications should generally be made using a memorandum or other format consistent with the level of formality required. Communication of planned actions is important at this stage to ensure that NRC intentions are clearly understood.
- a. Commission (if the Commission did not concur in i
the Restart Authorization or as requested) (NRR).
X mot
- d. ACRS (a briefing may be substituted for the NA written notification if the ACRS requests a briefing) (NRR).
- f. Public Affairs (Region). X oPA l l
- g. State and local officials (Region). X sto 1
- h. Citizens or groups that expressed interest during X MOT the restart approval process (Region). ,
1 s
j !
16 i
ISSUES l
NEED STATUS RESP. l C.1.1 Root Cause Assessment
- a. Conditions requiring the shutdown are X uoT l
+ clearly understood.
- b. Root causes of the conditions requiring the X mot shutdown are clearly understood.
- c. Root causes of other significant problems X mot are clearly understood.
- d. Effectiveness of the root cause analysis X mot program.
C.1.2 Damaae Assessment
- a. Damage assessment was thorcugh and NA comprehensive.
- b. Corrective actions clearly restored systems NA and equipment or verified they can perform as designed. l C.1.3 Corrective Actions I
- a. Thoroughness of the corrective action plan X mot
- b. Completeness of corrective action programs X SRI for specific root causes.
- c. Control of corrective action item tracking. X sri osTi
- d. Effective corrective actions for the X SRI osTi conditions requiring the shutdown have been implemented.
- e. Effective corrective actions for other X sri osT significant problems have been
. implemented.
- f. Control of long-term corrective actions. X SRI osTi
- g. Effectiveness of the corrective action X SRI osTi verification process, 17
NEEo STATUS RESP. l C.1.4 Self-Assessment Capability The occurrence of an event may be indicative of
+ potential weaknesses in the licensee's j self-assessment capability. A strong i self-assessment capability creates an environment where problems are readily identified, prioritized, and tracked. Effective corrective actions require problem root cause identification, solutions to correct the cause, and verification methods that ensure the issue is resolved. Senior licensee rnanagement effectiveness in ensuring effective self-assessment is treated separately.
- a. Effectiveness of Quality Assurance Program. X NRR
- b. Effectiveness of Industry Experience Review X osT Program.
- c. Effectiveness of licensee's Independent X SRI osTi Review Groups.
- d. Effectiveness of deficiency reporting system. X sri osTi
- e. Staff willingness to raise concerns. X oE NRR
- f. Effectiveness of PRA usage. X ICAV TEAM
l
- h. Review applicable external audits X osTi l
- i. Quality of 10 CFR 50.72 and 50.73 s eports. X sri l
18
NEED STATUS RESP.
C.2.1 Manaaement Oversicht and Effectiveness
- a. Goals / expectations communicated to the staff. X osTi
+
- b. Demonstrated expectation of adherence to X sRt
< procedures. osTi
- c. Management involvement in self-assessment X mot and independent self-assessment capability NRR j
- d. Effectiveness of management review X SRI committees. osTi
- e. Management's demonstrated awareness of X sri day-to-day operational concerns. osTi
- f. Management's ability to identify and prioritize X SRI significant issues. osTI
- g. Management's ability to coordinate resolution X SRI of significant issues. osTI
- h. Management's ability to implement effective X SRI osTi corrective actions.
C.2.2 Manaaement Sucoort
- a. Impact of any management reorganization. X mot
- b. Effective and timely resolution of employee X MOT concerns,
- c. Adequate engineering support as demonstrated X DRs by timely resolution of issues. osTi
- e. Effective information exchange with other X SRI sT utilities.
- f. Participation in industry groups.
NA
- g. Effectiveness of Emergency Response X DRs Organization.
- h. Coordination with offsite emergency X DRs planning officials.
19
l
)
l NEED status RESP.
C.3.1 Assessment of Staff mot sRt
- a. Demonstrated commitment to achieving X improved performance.
+
- b. Demonstrated safety consciousness. X osTi SRI
- c. Understanding of management's expectations X osT and goals.
- d. Understanding of plant issues and corrective X osTl SRI actions.
- e. Qualifications and training of the staff. X osTi
- f. Staff's fitness for duty. NA !
- g. Attentiveness to duty. X osTl
- h. Level of attention to detail. X osTi
- i. Off-hour plant staffing. X SRI
- j. Staff overtime usage. X sRl SRI
- m. Understanding of offsite emergency planning X DRs issues.
C.3.2 Assessment of Coroorate Support and Site i Enaineerina Suocort l X osTl '
- a. Corporate staff understanding of plant issues.
- b. Corporate staff site specific knowledge. X osT
- c. Effectiveness of the corporate / plant interface X osTi meetings.
- d. Corporate involvement with plant activities. X osT
- e. Effectiveness of site engineering support. X DRs
- f. Effectiveness of the site design modification X DRs process.
- g. Effectiveness of licensing support. X NRR 20
NEED STATUS RESP.
- h. Coordination with offsite emergency planning X NRR officials.
C.3.3 Operator Issues 4
- a. Licensed operator staffing meets requirements and licensee goals. X osTi
- b. Level of formality in the control room. X osTi
, SRI
- c. Effectiveness of control room simulator X DRs training.
- d. Control room / plant operator awareness of X osTi SRI equipment status.
- e. Adequacy of plant operating procedures. X sR PE
- f. Procedure usage / adherence. X SRI osTi
- g. Log keeping practices. X osti C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT
- a. Operability of technical specification systems. X osTi
- b. Operability of required secondary and support X osTi systems.
- c. Results of pre-startup testing. NA
- d. Adequacy of system lineups. X osTi
- e. Adequacy of surveillance tests / test program. X osTi
- f. Significant hardware issues resolved (i.e. X osT l damaged equipment, equipment ageing, modifications). ,
osTi I
- g. Adequacy of the power ascension testing X ,
sri program.
- h. Effectiveness of the plant maintenance program. X osTi DRs
- i. Maintenance backlog managed and impact X osTi on operation assessed.
- j. Adequacy of plant housekeeping and equipment X osTi storage.
21
NEED STATUS RESP.
C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS
- a. Applicable license amendments have been X NRR 4 issued.
- b. Applicable exemptions have been granted. X NRR
- c. Applicable reliefs have been granted. X NRR
- d. Imposed Orders have been modified or X NRR rescinded.
- e. Significant enforcement issues have been X MOT resolved. OE
- g. 10 CFR 2.206 Petitions have been appropriately X NRR addressed. *
- h. Atomic Safety and Licensing Board hearings NA have been completed.
C.6 COORDINATION WITH INTERESTED AGENCIFS AND PARTIES
- c. Department of Justice X OE 01
- d. Department of Labor X OE
- e. Appropriate State and local officials X SLO
- f. Appropriate public interest groups X MOT
- g. Local news media X OPA t 22
6 s .,
September 12,1996 !
i 4 I Mr. Ted C. Feigenbaum Executive Vice President - Nuclear Northeast Nuclear Energy Company c/o Mr. Terry L. Harpster-P. O. Box 128 Waterford, Connecticut 06385
SUBJECT:
NRC MILLSTONE UNIT 3 RESTART ASSESSMENT PLAN
Dear Mr. Feigenbaum:
The enclosed document is the NRC Millstone Unit 3 Restart Assessment Plan. It is being provided to you to ensure there is a clear understanding of the issues of concern to the NRC and allow maximum coordination of your restart activities. As your restart activities identify new issues, we will modify our plan to incorporate emerging concerns. If you have questions ;
regarding the contents of this document, please contact me or Jacque Durr of my staff. l l
Sinerely, l Original Signed By Jacque Durr for:
Wayne Lanning, Director Millstone Oversight Team Docket No. 50-423
Enclosure:
NRC Millstone Unit 3 Restart Assessment Plan cc w/ encl:
M. H. Brothers, Nuclear Unit 3 Director L. M. Cuoco, Esquire D. B. Miller, Senior Vice President, Nuclear Safety and Oversight S. E. Scace, Vice President, Reengineering E. A. DeBarba, Vice President, Nuclear Technical Services F. C. Rothen, Vice President, Maintenance Services S. B. Comley, We The People V. Juliano, Waterford Library J. Buckingham, Department of Public Utility Control State of Connecticut SLO
J .. .
i
' tr. Ted C. Feigenbaun.
2 Distribution w/ encl:
Region I Docket Room (with concurrences)
C. O'Daniell, DRP NRC Senior Resident Inspector
- Nuclear Safety Information Center (NSIC)
PUBLIC D. Screnci, PAO Distribution w/enci (VI E-MAIL):
W. Dean, OEDO P. McKee, NRR V. Rooney, NRR M. Callahan, OCA Inspection Program Branch (IPAS)
DOCUMENT NAME: G:\ BRANCH 6\MSACTION.912 To receive a copy of this document, indicate in the box: "C' = Copy without attachment / enclosure
'E' = Copy with attachment / enclosure *N* = No copy OFFICE Rl/DRP / /
NAME JDurr DATE 09/13/96 09/ /96 09/ /96 09/ /96 09/ /96 OFFICIAL RECORD MPI
._