IR 05000336/1996201
| ML20135F450 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/30/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20135F429 | List: |
| References | |
| 50-336-96-201, 50-423-96-201, NUDOCS 9612130066 | |
| Download: ML20135F450 (105) | |
Text
March 30, 1996
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 beir.g 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 i
staff.
j Sinerely, Original Signed By Jacque Durr for:
Wayne Utnning, Director
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Millstone Oversight Team Docket No. 50-423 Enclosure:
NRC Millstone Unit 3 Restart Assessment Plan
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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 l
V. Juliano, Waterford Library
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J. Buckingham, Department of Public Utility Control State of Connecticut SLO
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a fi A I M M C ENCLOSURE 3
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September 12,1996
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MEMORANDUM TO:
Hubert J. Miller,
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Regional Administrator, R1
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Roy Zimmerman I
Associate Director for Projects Ofhe of Nuclear Reactor Regulation l
FROM:
Wayne D. Lanning, Director Millstone Oversight Team, RI Phillip F. McKee, Director Northeast Utilities Project Directorate i
Office of Nuclear Reactor Regulation l
SUBJECT:
MILLSTONE RESTART ASSESSMENT PLAN Attached for your review and approval is the Millstone Station Restart Assessment Plan which encompasses the NRC Manual Chapter MC 0350, Staff Guidelines for Restart Approval. The Millstone Oversight Team (MOT) will fulfill the role of Restart Panel for the purposes of MC 0350. This assessment plan is applicable to Millstone Unit 3, and, once approved, will be maintained and updated as necessary by the Millstone Oversight Team.
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The MOT intends to make minor revisions without seeking additional approval; however, if a significant revision is made to the plan, you will be notified and requested to approve the change. The restart plans for Units 1 and 2 will generally contain the same generic issues
supplemented with plant specific technicalissues.
The restart assesement plan consists of several major elements requiring close j
coordination 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 i
performance. The second area is the licensee's responses to the 10 CFR 50.54 (f) letters
for each of the units and the associatod NRC Confirmatory Order. Lastly, the MC 0350 overview process and the Operational Safety Team inspection will be tailored to the restart l
Of the specific unit.
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The MOT will continue to meet with the licensee and the public regarding this plan.
Accordingly, this plan will be a living document and updated periodically.
Original Signed By:
Original Signed By:
Phillip F. McKee, Director Wayne D. Lanning, Director Northeast Utilities Project Directorate Millstone Oversight Team l
Office of Nuclear Reactor Regulation Region I
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Original Signed By:
Original Signed By:
Approved:
Roy Zimmerman Date Hubert J. Miller Date l
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REV 9/12/96 MILLSTONE RESTART ASSESSMENT PLAN l
1.0 BACKGROUND The three Millstone Units are shut down to formulate responses to a series of
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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 are 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
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units. It is the intent to implement the appropriate aspects of NRC Manual Chapter
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0350, " Staff Guidelines for Restart Approval" for the restart of all three units. The NRC 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 contributory causes for the current poor performance, which the 10 CFR 50.54(f) issues are a subset. These issues have been formalized by the licensee in a program titled " Improving Station Performance" (ISP) and are topics that will be addressed by the licensee and reviewed by the NRC Millstone Oversight Team (MOT). A meeting was conducted on April 30,1996,and disclosed that the licensee was not adequately managing the program nor tracking progress.
The salient concerns embodied in the ISP include leadership, communications (employee concerns), the corrective action program, procedural adherence and procedure upgrades, work planning and control, and operational enhancements.
The NRC restart assessment program will focus on the broader issues of the ISP and licensee self assessments and management oversight, 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 detailin Section 3 of this plan.
2.0 10 CFR 50.54(f) Activities Each Millstone unit has beer > 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 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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l 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 j
related to how each deficiency was identified and will be dispositioned.
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
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design controls, including translation of the design bases into operating psocedures and maintenance and testing practices, verification of system performance, and implementation of modifications since issuance of the initial facility operating
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l licenses. The NRC oversight of the ICAV program and activities will be separate from, and in addition to the activities described in this restart essessment plan. The
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results from this program will be incorporated into this restart plan and considered a
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significant part of the decision regarding recommended restart. The deficiencies 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.
3.0 MC 0350 Process 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 concem for regulatory compliance.
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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 Administrator,in coordination with the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, and the Director of Nuclear Reactor Regulation (NRR), will make a recommendation regarding restart.
NRR and the Region willinform the Commission of the staff's and licensee's restart
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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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3.1 MILLSTONE OVERSIGHT TEAM
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The Millstone Oversight Team (MOT) is composed of the Director, Millstone Oversight Team, the Director, Northeast Utilities Project Directorate, the Project Managers for the three Millstone units, the DRP Project Branch Chief, the Senior
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Resident inspectors for the three Millstone units and the appointed Division of Reactor Safety representative. The function of'the Millstone Restart Panelis described in Manual Chapter 0350 and will be fulfilled by the MOT.
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3.2 MILLSTONE OPERATIONAL READINESS PLAN
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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
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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 defen items from the restart list.
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3.3 CORRECTIVE ACTION PROGRAM The NU corrective action program has been weak in ensuring comprehensive and effective corrective actions. There are many instances of narrowly focused 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.
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Because of the large nu~mber of Adverse Condition Reports (ACR) being identified
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by the licensee's staff, the resident and regional inspection staff will concentrate on issues for each 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 technicalissues. Examination of the corrective action program needs to review the Action Requests (AR) from the Action item Tracking and Trending System (AITTS) program, which is an extension of the ACR process, and commitments regarding violations and inspection items. Further, a significant input to assessing the licensee's corrective action program is derived from the normal inspection program where valuable insi hts regarding the effectiveness of
corrective actions are routinely collected from the technical safety inspections.
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Additionally, the NRC Independent Corrective Action Verification team will assess l
the licensee's corrective actions for degraded and non-conforming conditions, Finally, the Operational Safety Team inspection (OSTI) will audit portions of the
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corrective action process during the course of its activities.
I 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 j
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a high ratio of successfully completed ACR's to the total population inspected.
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.)'
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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
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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 regi'onal 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
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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 i
i Reference to applicable MC 0350 section j
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licensee's PUP. The NRC staff will develop an inspection plan for examining selected portions of each unit's individual efforts.
3.6 OVERSIGHT (C.1.4 )
The licensee has identified its oversight function as deficient through self assessments and external and internal audits and a contributing factor in the licensee's declining performance. The report of Assessment of Past ineffectiveness of Indeoendent Oversicht 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 adequately.
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 OA effectiveness identified in previous QA internal and external assessments have not beer 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 reports are forwarded
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to the responsible manager and that they have dealt with the contents appropriately. Oversight should be adequately staffed with qualified 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
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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 the efforts of the Office of Investigations, the allegation process review group, the Office of the inspector Ger.eral, the Special Inspection Team, routine resident and regionalinspection efforts and the 10 CFR 2.026 petition process. The
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culmination 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
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l 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
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the staff at the Millstone site. The current series of 10 CFR 50.54(f) letters were I
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
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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 Utilities handling of employee concerns and the recent layoffs that affected several previous allegers.
The task group examined Northeast Utilities handling of employee concerns and identified a number of root causes for the licensee's problems 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 reviewed 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 lice.nsee on its restart issues list, have it impose controls on adding or deferring items from the list, have the resident inspectors review the list to ensure it included 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.
j The enclosed NRC Significant issues Lists will contain items that are being used to audit and evaluete licensee programs such as the corrective action process and significant safet)/ regulatory. technical issues.
Restart issues will meet at least one of the following criteria:
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Resolution of the issue is required to ensure safe operation of the j
facility to include satisfaction of the technical specifications or l
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licensing basis.
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Inspection of the issue will provide an insight to an identified programmatic deficiency such as the corrective action system.
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Inspection of the issue will provide assessment of management effectiveness or personnel performance.
3.10 RESTART INSPECTION
i Selected portions of NRC Manual Chapter 93802, " Operational Safety Team
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Inspection," will provide the framework for a team inspection of each unit during restart. The inspection will cover self-assessments by the licensee, the licensee's
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irnplementation of its startup plan, control room observations during the approach to 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 I
i 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
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for the Millstone Station. The review identified severalissues that warrant NRC inspection before plant restart of the unit. The unit specific issues as well as station wide issues identified by the PPR are contained in the Significant issues List for each unit as inspection items.
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3.12 LICENSE AMENDMENTS
l 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 l
steam line pressure negative rate high steam line isolation time constant: and 2)
change operational modes with both shutdown margin monitors inoperable and to
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revise the locked valve list.
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Enclosure 1 MILLSTONE UNIT 3 l
SIGNIFICANT ITEMS LIST
REF.
ITEM RESP.
STATUS
ACR RSS AND OSS 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
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01148 BEFORE RESTART
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ACR REACTOR POWER INCREASE WHEN DRP
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05715 UNBORATED CATION DEMIN PLACED i
INTO SERVICE 3CHS-DEMIN2 ACR EDG SEQUENCER CDA SIGNAL OUTPUT DRS 01895
"A" TRAIN COMPONENTS STARTED
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ACR FAILURE TO ENTER AN ACTION DRP 01844 STATEMENT WHEN MSIVS WERE CLOSED
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i ACR RCP SEAL INJECTION FILTER "B" DRP
04199 GASKET FAILED RESULTING IN SPILL OF COOLANT TO FLOOR DRAINS
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ACR RCS CHECK VALVE BODY TO BONNET DRP
06092 LEAK 3 RCS*V146 ACR WHILE DEWATERING SPENT RESIN, THE DRP l
01535 WASTE TEMPERATURE IN THE LINER
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RAISED FROM 90 TO 310oF j
ACR NEED FOR ADDITIONAL REVIEW OF DRS 10543 RESPONSE TIME TESTING FOR i
PROCEDURES
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ACR CLOSURE OF PIR WITHOUT DRP
11322 ADDRESSING DESIGN FEATURE OF AFFECTED COMPONENTS e
ACR TURBINE DRIVEN AUX FEEDWATER DRP
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10774 DESIGN CONCERN
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i ACR CONTAINMENT FOUNDATION EROSION NRR j
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ACR CCP SYSTEM OPERATION ABOVE DRP 10800 DESIGN TEMPERATURE a
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MILLSTONE UNIL3 Continued REF.
ISSUE RESP.
STATUS ACR SGCS OPERATIONAL CONFIGURATION DRS 7745 CONTROL ACR LETDOWN HEAT EXCHANGER LEAKAGE DRP M3-9 6-AND DESIGN DISCREPANCIES 0159
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ACR DUAL FUNCTION VALVE CONTROL AND DRP/NRR 01935 TESTING ACR RCP SEAL HOUSING LEAKAGE AND DRS l
7266 BOLT CORROSION 10790 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 RESTART ISSUES 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 37750 DRS COMPL.
PART 70 STORAGE AND INVENTORY IP DRS COMPL.
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MILLSTONE UNIT 3
REF.
ISSUE RESP.
STATUS i
FORMALITY OF NON-ROUTINE DRS
SECURITY ACTIVITIES AND NEW FUEL 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 l
MOTOR OPERATED VALVE PROGRAM DRS i
GL89-10 PORV/SG DUMP VALVES PPR RESIDENT EMPHASIS: MISSED SRI
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G.1.C SURVEILLANCES
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PPR RESIDENT EMPHASIS: DILUTION SRI I
G.1.C EVENTS PPR RESIDENT EMPHASIS: FEEDWATER SRI G.1.C HAMMER i
PPR RESIDENT EMPHASIS: CHECK VALVE SRI G.1.C LEAKAGE PPR RESIDENT EMPHASIS: WORK-SRI G.1.C AROUNDS PPR RESIDENT EMPHASIS: SURVEILLANCE SRI G.2 CONTROL,MAINT. CONFLICT PPR RESIDENT EMPHASIS: USE OF SRI 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 PPR RESIDENT EMPHASIS: SEISMIC 11/1 SRI G.2 i
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MILLSTONE UNIT 3 CONTINUED i
REF.
ISSUE RESP.
STATUS EFFLUENT / ENVIRONMENTAL DRS SAMPLING AND ANALYTICAL 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 I
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
ORDER PHASE ll OF THE ICAVP NRR
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ENCLOSURE 2 MILLSTONE UNITS 3 RESTART APPROVAL
The following items are considered applicable to the restart of Millstone Units 3:
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UNIT 3
RESPONSIBILITIES AND AUTHORITIES
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i NEED STATUS RES P
4.0 Director. Office of Nuclear Reactor Reaulation (NRR).
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Notifies the Executive Director for Operations (EDO)
and the Commission, as appropriate, of the NRC actions taken concerning shutdown plants and the proposed followup plan.
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4.0 Reaional Administrator X
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Discusses with the Deputy Executive Director for Nuclear Reactor Regulation, Regional
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Operations and Research, the Office of
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Enforcement (OE), and NRR, as appropriate, the need for an order or confirmatory action letter (CAL) specifying the actions required of the
licensee to receive NRC approval to restart the plant and the proposed followup plan.
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Decides,in consultation with the NRR X
C RA Associate Director for Projects, whether this i
manual chapter applies to a specific reactor restart.
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In coordination with the NRR Associate Director X
C RA for Projects, decides whether to establish a Restart Panel.
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In coordination with the cognizant NRR X
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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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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, when appropriate, interactions with State and local
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agencies and with regional offices of Federal
agencies.
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In conjunction with NRR, reviews and X
MOT determines the acceptability of licensee's SRI corrective action program.
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Approves restart of the shutdown plant, X
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following consultation with the EDO and the
Director of NRR, and approval / vote by the Commission.
4.03 NRR Associate Director for Projects i
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Acts as the focal point for discussions within X
zimme NRR to establish the appropriate followup rmen actions for a plant that has been shut down.
4.04 NRR Reactor Projects Division Director M Kee 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.
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b.
Coordinates and implements actions prescribed x
McKee i1 the Restart Assessment Plan that have been determined to be NRR's responsibility. These
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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.
e
'
.
.
l NEED sTATU RESP.
I s
B.1 INITIAL NRC RESPONSE NA 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 j
into the CSC as appropriate. Refer to
'
Section 5.02 of this manual chapter for additional information.
.
a.
Initial notification and NRC NA management discussion of known facts and issues 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).
.
I
-
\\
.
.
NEED STATU RESP.
S B.2 NOTIFICATIONS NA 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 e.
Cognizant Federal agencies notified NA (i.e., FEMA, EPA, DOJ).
f.
State and local officials notified NA (Region).
g.
Congressional notification (NRR)
NA
.
.
PROCESS B.3 NEED STATU RESP.
S B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS 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
mot (Region).
e.
Conduct NRR Executive Team briefing X
C mot (NRR).
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.
i.
NRR Associate Director and/or NRR X
C AD Director approves Restart Assessment Plan.
J.
Implement Restart Assessment Plan.
X mot k.
Modify order as necessary X
NRR I
I
.
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.
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!
. _ - - - __
_ _ _ _.. _ - _
.__ -_.
-
_
NEE sTATU RESP D
s B.4 REVIEW IMPLEMENTATION B.4.1 Root Causes and Corrective Actions osTI MOI a.
Evaluate findings of the special team X
inspection.
b.
Licensee performs root cause analysis X
NU osTI and develops corrective action plan for root causes.
c.
NRC evaluates licensee's root cause X
mot determination and corrective action osTi plan.
.
. - -
..
..
__.. _. -
_._~.__. _
. - _. _ _ _ -
__._______._m
-. _ _ _ _ _ _. - _ _.
.
i.
.
!
.
<
.
NEED STATU RESP j
s B.4.2 B.4.2 Assessment of Eauioment Damaae NA
For events where equipment damage occurs, a thorough assessment of the extent of damage is necessary. A root cause determination will be
necessary if the damage was the result of an I
internal event. The need for independent NRC
.
l assessment should be considered. The licensee
will need to determine corrective actions to repair, I
test, inspect, and/or analyze affected systems and
)
equipment. These actions are required to restore i
or verify that the equipment will perform to design
!
requirements. Equipment modifications may also i
be required to ensure performance to design i
requirements.
i
!.
l Potential offsite emergency response impact for j
external events such as natural disasters, j
explosion;, or riots should be considered. NRR should obtain information from FEMA
'
l headquarters reaffirming the adequacy of State j
and local offsite emergency plans and
!
preparedness if an event raises reasonable doubts j
about emergency response capability.
{
a.
Licensee assesses damage to systems and NA
!
components.
,
I I
b.
NRC evaluates licensee damage NA
!
assessment.
i
c.
Licensee determines corrective actions.
NA i
j d.
NRC evaluates corrective actions.
NA i
!
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i NEED STATU RESP.
S
'
'
i B.4.3 Determine Restart Issues and Resolution X
MOT
.
i j
The establishment of the restart issues that j
require resolution before restart demands a clear j
understanding of the issues and the actions
required to address those issues by both the NRC l
and the licensee. This section outlines steps to
,
i determine the restart issues and NRC's evaluation j
of their resolution.
i l
a.
Review / evaluate licensee generated restart X
MOT issues.
.
i b.
Independent NRC identification of restart X
MOT
.
issues c.
NRC/ licensee agreement on restart issues.
X MOT d.
Evaluate licensee's restart issues X
MOT
,
i implementation process.
?
i a
e.
Evaluate licensee's implementation X
SRI j
verification process.
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.
.
.
.
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-
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.
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NEED STATUS RESP
.
B.4.4 Obtain Comments Since some shutdowns involve a broad number of issues, solicitation of comments from diverse sources may be appropriate. The decision to solicit comments J
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 and local emergency planning and preparedness must be obtained from FEMA headquarters through mot NRR.
x a.
Obtain public comments.
b.
Obtain comments from State and Local X
slo Officials (Region).
c.
Obtain comments from applicable X
NRR 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 reviews and preparations for restart.
mot osTI 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 cidsed.
X mot SRI OSTI d.
Conduct NRC restart readiness team inspection X
osTi (Region),
e.
Issue augmented restart coverage inspection X
osTI plan (Region).
___
.
_ _ -
- _.
_
__
_
_
_ _.... _ _.
. __
_ _ _ _ _
_
_ _ _ _
_
.
.
-
.
,
NEED STATUS RESP.
f.
Comments from other parties considered.
X MOT i
g.
Determine that all conditions of the Order / CAL X
,
are satisfied.
h.
Re-review of Generic Restart Checklist X
MOT
complete.
B.5 RESTART AUTHORIZATION (B.5)
'
1
When the restart review process has reached the point that the issues have been identified, corrected, and
'
l reviewed, a restart authorization process is begun. At l
this point the Restart Panel should think broadly and j
ask: "Are all actions substantially complete? Have we overlooked any items?"
i 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 d
offices.
.
j d.
No restart objections from applicable Federal X
mot agencies.
e.
Regional Administrator concurs in restart X
RA recommendation
'
f.
NRR Associate Director and/or NRR Director X
McKee concurs in restart recommendation.
g.
EDO concurs in restart recommendation when X
EDO required.
h.
Conduct ACRS briefing when requested (NRR).
NA
.
\\
.
.
NEED sTATU RESP.
s i.
Conduct Commission briefing when requested X
RA j.
Commission concurs in Restart Authorization.
X coMM i
k.
Regional Administrator authorizes restart.
X RA B.6 RESTART AUTHORIZATION 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 the Restart Authorization or as requested) (NRR).
X mot b.
EDO (if the EDO did not concur in the restart X
EDO recommendation or as requested) (NRR).
c.
Congressional Affairs (NRR).
X oCA
'
d.
ACRS (a briefing may be substituted for the NA written notification if the ACRS requests a briefing) (NRR).
e.
Applicable Federal agencies (NRR).
X NRR f.
Public Affairs (Region).
X OPA
,
g.
State and local officials (Region).
X SLO h.
Citizens or groups that expressed interest during X
mot
the restart approval process (Region).
,
.
_.. -.
..
.-.- _
.
.
.- - --.___
= - - _-----_ -.-..
... - -.-
.
ISSUES
.
NEED sTATU RESP.
s C.1.1 Root Cause Assessment
,
a.
Conditions requiring the shutdown are X
mot
!
clearly understood.
i 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
j a.
Damage. assessment was thorough and NA comprehensive.
b.
Corrective actions clearly restored systems NA and equipment or verified they can perform as designed.
C.1.3 Corrective Actions j
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 i
osTI
!
d.
Effective corrective actions for the X
SRI conditions requiring the shutdown have osTi been implemented.
'
e.
Effective corrective actions for other X
SRI significant problems have been osTI
'
implemented.
f.
Control of long-term corrective actions.
X SRI osTi
.
._,
___ _
_.. _
_ _ _ __
_
.
_ _ _.
_
_
- _ _ ___...____ _ _
__
_ _ _ _ _ _
__
.
.
g.
Effectiveness of the corrective action X
- i
'
verification process.
osTI
i NEED sTATU RESP.
s C.1.4 Self-Assessment Caoability The occurrence of an event may be indicative of potential weaknesses in the licensee's
self assessment capability. A strong 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 i
management effectiveness in ensuring effective self-assessment is treated separately.
a.
Effectiveness of Quality Assurance Program.
X NRR b.
Effectiveness of Industry Experience Review X
osTi Program.
c.
Effectiveness of licensee's Independent X
SRI Review Groups.
osTi
_
d.
Effectiveness of deficiency reporting system.
X SRI osT1 e.
Staff willingness to raise concerns.
Effectiveness of PRA usage.
X IcAV TEAM g.
Effectiveness of co.
.itment tracking X
h.
Review applicable external audits X
osTi i.
Quality of 10 CFR 50.72 and 50.73 reports.
X SRI
.
.
.
NEED STATU RESP.
s C.2.1 Manaaement Oversicht and Effectiveness a.
Goals / expectations communicated to the staff.
X osTI b.
Demonstrated expectation of adherence to X
SRI procedures.
osTi c.
Management involvement in self-assessment X
Moi and independent self-assessment capability NRR 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 corrective actions.
osTI C.2.2 Manaaement suooort 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 d.
Adequate plant administrative procedures.
J e.
Effective information exchange with other X
sri utilities.
OSTI f.
Participation in industry groups.
NA g.
Effectiveness of Emergency Response X
DRs Organization.
h.
Coordination with offsite emergency X
DRs
planning officials.
. - __..
..
_-
_.
..
-
- - _
.
-.
-
- --
.
.
.
li NEED sTATU RESP.
s l
C.3.1 Assessment of Staff mot j
!
a.
Demonstrated commitrnent to achieving X
SRI osis improved performance.
f b.
Demonstrated safety consciousness.
X osTi SRI
,
.
!
c.
Understanding of management's expectations X
osT l
and goals.
-
j d.
Understanding of piant issues and corrective X
osTI
'
actions.
e.
Qualifications and training of the staff.
X osTI i
f.
Staff's fitness for duty.
NA i
g.
Attentiveness to duty.
X osTI
'
h.
Level of attention to detail.
X osTI a
j i.
Off-hour plant staffing.
X SRI
j j.
Staff overtime usage.
X SRI SRI k.
Procedure usage / adherence.
{X SRI
,
PE j
-
i 1.
Awareness of plant security.
X DRS
!
,
m.
Understanding of offsite emergency planning X
DRs i
,
issues.
g,
_. ___..
,_
_
_ _ _ _ _ _
_
.
.- -
--
l C.3.2 essessment of Coroorate Suooort and Site i
Enaineerina Suncort
'
]
X osTI J
a.
Corporate staff understanding of plant issues.
]
b.
Corporate staff site specific knowledge.
X osTI j
c.
Effectiveness of the corporate / plant interface X
osTi i
meetings.
I d.
Corporate involvement ith plant activities.
X osTi
_
e.
Effectiveness of site engineering support.
X DRs f.
Effectiveness of the site desiga modification X
DRs process.
. _
_
_
__
o e
g.
Effectiveness of licensing support.
X NRR NEED STATUS RESP.
h.
Coordination with offsite emergency planning X
NRR officials.
C.3.3 Operator issues a.
Licensed operator staffing meets requirements and licensee goals.
X osTi b.
Level of formality in the cont.
.,o m.
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.
l f.
Procedure usage / adherence.
X SRI j
osTi g.
Log keeping practices.
X osTl
,
.
og
....
.
.
.
. -_ - __ __
_ - - -. -
_
. _ - _ -.
.--
C.4 ASSESSMENT OF PHYSICAL READINESS OF THE l
PLANT a.
Operability of technical specification systems.
X osT1 b.
Operability of required secondary and support X
osTi systems, i
c.
Results of pre-startup testing.
NA l
d.
Adequacy of system lineu'Js.
X osT l
e.
Adequacy of surveillance tists/ test program.
X osTI l
l f.
Significant hardware issues resolved (i.e.
X osit
!
damaged equipment, ecupment ageing, modifications).
g.
Adequacy of the power ascension testing X
osTi SRI program, h.
Effectiveness of the plant maintenance program.
X osTI DRs i.
Maintenance backlog managed and impact X
osTI on operation assessed.
l
i
!
.
.
d
..
.
_
_
._
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Effectiveness of licensing support.
X NRR
.
NEED STATUS RESP.
a h.
Coordination with offsite emergency planning X
NRR officials.
C.3.3 Ooerator issues
!
a.
Licensed operator staffing meets requirements l
and licensee goals.
X osTi
)
b.
Level of formality in the control room.
X osTI l
SRI l
c.
Effectiveness of control room simulator X
DRs training.
!
d.
Control room / plant operator awareness of X
osTi equipment status, SRI l
i e.
Adequacy of plant operating procedures.
X sri i
PE f.
Procedure usage / adherence.
X sri osT j
g.
Log keeping practices.
X osTi C.4 ASSESSMENT OF PHYSICAL READINESS OF THE
!
PLANT
!'
Operability of technical specification systems.
X osTi
,
a.
b.
Operability of required secondary and support X
osTi
_
systems.
c.
Results of pre-startup testing.
NA l
d.
Adecuacy of system lineups.
X osT Adequacy of surveillance tests / test program.
X osT e.
[
l f.
Significant hardware issues resolved (i.e.
X osTi i
damaged equipment, equipment ageing, modifications).
I g.
Adequacy of the power ascension testing X
osti l
program.
'
h.
Effectiveness of the plant maintenance program.
X osTi DRs i.
Maintenance backlog managed and impact X
osTI
'
on operation assessed.
.
i 1