ML17349A516

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Forwards Corrective Action Plan Outline for Plant Lessons Learned
ML17349A516
Person / Time
Site: Turkey Point  
Issue date: 11/23/1992
From: Taylor J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Curtiss, Rogers, The Chairman
NRC COMMISSION (OCM)
Shared Package
ML17349A517 List:
References
NUDOCS 9212040109
Download: ML17349A516 (12)


Text

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.UNITED STATES NUCLEAR REGULATORY COMMISSION WA8HINQTON, D.C. 20666 November 23, 1992 HEHORANDUM FOR:

The Chairman Commissioner Rogers Commissioner Curtiss Commissioner Remick Commissioner de Planque FROM:

SUBJECT:

James M. Taylor Executive Director for Operations CORRECTIVE ACTION PLAN OUTLINE FOR TURKEY POINT LESSONS LEARNED BACKGROUND In a memorandum to the Commission of October 20, 1992, I summarized and evaluated the restart process of,the Turkey Point nuclear plant following the

.onsite and offsite damage to Turkey Point Units 3 and 4 as a result of "Hurricane Andrew; I indicated that the restart process was flawed and premat'ure in that the 'status of offsite emergency preparedness

{EP) was not acknowledged ahd sufficient coordinati,on with the Federal Emergency Management Agency {FEHA)'had not taken place.

I also listed several factors that contributed t'o the flawed restart process.

These factors included poor internal and external communications and coordination, the lack of a formal restart process. with attendant procedures and checklists, the lack of management and staff focus on,the'offsite EP issues, and inadequate training

,and knowledge of the role of and relationship with FEMA.

I also described needed corrective actions and;committed the staff to developing and implementing such actions.

This corrective action plan

{CAP) is a followup to the commitment in my October 20,

1992, memorandum.

METHODOLOGY NRR will manage and coordinate. the CAP implementation, monitor progress, and prepare periodic status reports,

',as a'ppropriate.

Lead re'sponsibility for each area of the CAP has been assigned to the cognizant staff organization, and target completion, dates, have been established.

Each responsible group will prepare a work plan listing the necessary

steps, required coordination, i'nterim milestones, and end products.

After the work plan is approved, the staff will take each action'in accordance with that plan.

Contact:

L. Raghavan, NRR 504-2019

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CORRECTIVE ACTIONS 1.

REVISE PROCEDURES 1.1 REVISE NRC INSPECTION MANUAL CHAPTER 0350 A licensed commercial nuclear power plant may be shut down for a variety of reasons, including a significant event, complex hardware

problems, or serious management deficiencies.

The subsequent restart of the plant may involve complex corrective actions and significant amounts of licensee and NRC resources.

In these cases, it is necessary to ensure that NRC review and approval of the plant restart is comprehensive,

complete, and consistent with the Commission's safety mission.

NRC Inspection Hanual Chapter 0350 contains guidelines for approving restart of a nuclear power plant after a shutdown as a result of a significant event.

The staff will review the manual chapter and revise it as appropriate to incorporate lessons. learned from the Turkey Point restart process.

Specifically, the following will be considered for inclusion in the manual chapter:

(a) a decision tree to arrive at a required restart process with differentiation between significant event restarts and problem plant restarts.

(b) a master generic checklist for the restart review process, from which a master plant-specific checklist can be generated to address individual circumstances, including consideration of offsite emergency preparedness issues.

Proper management mechanisms would be identified to keep the master checklist current based on feedback of experience.

(c) requirements for developing a regulatory footprint for restart and issuance of a Confirmatory Action Letter (CAL) such that both the licensee and the staff understand the necessary actions to be completed before restart.

Lead Responsibility:

NRR-PHAS Target Completion:

January 31, 1993 1.2 REVISE INSPECTION PROCEDURES.

The staff will review and revise inspection procedures as necessary (1) to be consistent with the revised Inspection Manual Chapter 0350 and (2) to clearly reflect the proper responsibilities of NRC and FEHA.

The emergency preparedness inspecti'on procedures will be revised to clearly reflect the respective responsibilities and roles of FEMA and the NRC for inspecting offsite emergency preparedness activities.

Specifically, the procedures will be made consistent with the modified FEHA/NRC Memorandum of Understanding (HOU) and other Commission guidance.

Lead Responsibility:

NRR-DRSS Target Completion:

February 28, 1993

2.

REVISE FEMA/NRC MEMORANDUM OF UNDERSTANDING The FEHA/NRC MOU will be expanded to address FEHA and NRC actions following a disaster, such as Hurricane Andrew, affecting the 10-mile plume emergency planning zone,and associated onsite emergency preparedness (EP).

The MOU revisions will clarify FEMA's responsibility after a disaster for assessing offsite EP and NRC's responsibility for considering such an assessment in its post-disaster decisions about the restart or continued operation of an affected operating power reactor.

The MOU revisions will also outl,ine FEMA and NRC commitments to inform each other of related plans, schedules, and actions.

Lead Responsibility:

NRR-DRSS Target Completion:

April 30, 1993 3.

IMPROVE STAFF TRAINING The staff will prepare training plans and conduct appropriate training in each region and NRR division.

The training will address revisions to NRC Inspection Manual Chapter 0350 and the revised inspection and restart procedures, and communications between regional offices and headquarters and between the technical organizations within the regional and headquarters offices.

The training will stress the need for aggressive internal and external communications and coordination.

In addition, the training will emphasize the st'aff's understanding of the roles and

'responsibilities of FEHA and the relationship of NRC to FEMA.

This training will be included in the Fundamentals of Inspection training program.

Lead Responsibility:

NRR-DRSS (with assistance from PHAS), Target Completion (for current employees):

Hay 30, 1993 cc:

SECY OGC mes H. T or xecutive Director for Operations

ovember 23, 1992 2.

REVISE FEHA/NRC MEMORANDUM OF UNDERSTANDING The FEMA/NRC HOU will be expanded to address FEHA and NRC actions following a disaster, such as Hurricane Andrew, affecting the 10-mile plume emergency planning zone and associated onsite emergency preparedness (EP).

The HOU revisions will clarify FEHA's responsibility after a disaster for assessing offsite EP and NRC's responsibility for considering such an assessment in its post-disaster decisions about the restart or continued operation of an affected operating power reactor.

The HOU,revisions will also outline FEHA and NRC commitments to inform each other of related plans, schedules, and actions.

3.

Lead Responsibility:

NRR-DRSS Target Completion:

April 30, 1993 IMPROVE STAFF TRAINING Lead (for The staff will prepare training plans and conduct appropriate training in each region and NRR division.

The training will address revisions to NRC Inspection Manual Chapter 0350 and the revised inspection and 'restart procedures, and communications between regional offices and headquarters and between the technical organizations within the regional and headquarters offices.

The training will stress the need for aggressive internal and external co'mmunications and coordination.

In addition, the training will emphasize the staff's understanding of the roles and responsibilities of FEHA and'the relationship of NRC to FEMA.

This training will be included in the Fundamentals of Inspection training program.

Responsibility:

NRR-DRSS (with assistance from PHAS), Target Completion current employees):

May 30, 1993 Original Signed Bye James H. Taylor lames M>. Taylor Executive Director for Operations cc:

SECY OGC Distribution See next page2

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The FEHA/NRC MOU will be expanded to address FEHA and NRC actions following a disaster, such as Hurricane Andrew, affecting the 10-mile plume emergency planning zone and associated onsite emergency preparedness (EP).

The HOU revisions will clarify FEHA's responsibility after a disaster for assessing offsite EP and NRC's responsibility for considering such an assessment in its post-disaster decisions about'the restart or continued operation of an affected operating power reactor.

The MOU revisions will also outline FEHA and NRC commitments to inform each other of related plans, schedules, and actions.

Lead Responsibility:

NRR-DRSS Target Completion:

April 30, 1993 IMPROVE STAFF TRAINING The staff will prepare training plans and conduct appropriate training in each region and NRR division.

The training will address revisions to NRC Inspection Manual Chapter 0350 and the revised inspection and restart procedures, and communications between regional offices and headquarters and between the technical organizations within the regional and headquarters offices.

The training will stress the need for aggressive internal and external communications and coordination.

In addition, the training will emphasize the staff's understanding of the roles and responsibilities of FEHA and the relationship of NRC to FEMA.

This training will be included in the Fundamentals of Inspection training program.

Lead Responsibility:

NRR-DRSS (with assistance from PMAS), Target Completion (for current employees):

Hay 30, 1993 Original Signed Byz James H. Taylor James ilkTaylor Executive Director for Operations cc:

SECY OGC Distribution See next page

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Memorandum Dated November 23, 1992 l

Distribution Docket File NRC 8 Local PDRs EDO¹ 8219

'EDO RF J. Taylor

J.

Sniezek J:

Blaha H. Thompson F. Gillespie T; Murley/F. Miraglia J.

Partlow M. Russell F.

Congel PDI I-2 RF S.

Varga G. Lainas H. Berkow L. Raghavan OPA NRR Mail Room (EDO¹ 8219 w/incoming) (12-G-18)

C. Norsworthy S. Little E.

Tana M. Sinkule, RII B. Clayton D. Crutchfield

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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 II EDO Principal Correspondence Control FROM:

JIM SNIEZEK

DEDR, OEDO TO TOM MURLEY FOR SIGNATURE OF:

EXECUTIVE DIRECTOR DESC:

DUE: 11/20/92 PRI EDO CONTROL I 00082 1 9 DOC DT: 10/23/92 FINAL REPLY:

CRC-NO:

ROUTING:

DATE'0/24/92 ASSIGNED TO:

CONTACT:

DEVELOP DETAILED CORRECTIVE ACTION PLANS RE OFFSITE EMERGENCY PREPAREDNESS AT TURKEY POINT FOR SUBMITTAL TO THE COMMISSION TAYLOR SNIEZEK THOMPSON BLAHA EBNETER NRR MURLEY SPECIAL INSTRUCTIONS OR REMARKS

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ACTfofd DUE TO NRR DlRZCTOR'S OFFlCE BY

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