ML20058C477
| ML20058C477 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/25/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058C437 | List: |
| References | |
| PROC-931025, NUDOCS 9312020466 | |
| Download: ML20058C477 (36) | |
Text
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i Date:. October 25, 1993 Revision: 0 i
SOUTH TEXAS PROJECT RESTART ACTION PLAN 1
A.
GENERAL.............
1 A.1 PURPOSE...........................
1 A.2 OBJECTIVES.........................
I A.3 BACKGROUND.........................
3 ~-
A.4 RESTART ACTION PLAN OVERVIEW 5
l B.
PROCESS..............................
5 B.1 INITIAL NRC RESPONSE....................
6 l
B.2 NOTIFICATIONS.........................
l B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS........
7-9 B.4 REVIEW IMPLEMENTATION....................
13 l
l B.5 RESTART AUTHORIZATION...-.................
14 l
B.6 RESTART AUTHORIZATION NOTIFICATION 15 i
C.
ISSUES................................
C.1 ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION 15 l
C.2 ASSESSMENT OF LICENSEE MANAGEMENT...............
19 i
C.3 ASSESSMENT OF PLANT'AND CORPORATE STAFF...........
-23 i
C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT....
27 C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS....
29
[
C.6 COORDINATION WITH INTERESTED AGENCIES / PARTIES........
30 31 D.
PLANT SPECIFIC STARTUP ISSUES...................
i 35 E.
RESTART INSPECTIONS........................
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A.
GENERAL i
A.1 PURPOSE i
To provide.a basis to plan and coordinate NRC review activities for restart of the South Texas Project units.
A.2 OBJECTIVES To ensure that NRC review efforts are consistently d;veloped and implemented, i
specific guidance is provided to support:
a.
Determining restart issues for review, J
b.
Identification of the basic tasks needed to review and approve plant restart, and j
Coordination and tracking of restart review activities.
c.
1 A.3 BACKGROUND Both units at STP were shut down in early February 1993. They have remained shut down as a result of numerous broad problems identified by the.NRC and the i
licensee.
j On February 3, 1993, following a reactor trip, the Unit 2 turbine-driven i
auxiliary feedwater pump started and immediately tripped on overspeed. On l
February 4,1993, Unit I was required to shut down as.a result of repeated l
failures of the turbine-driven auxiliary feedwater pump to ' start on demand and operate without tripping on overspeed. As a result of these turbine-driven auxiliary feedwater pump problems, NRC 1ssued a Confirmatory Action Letter (CAL) to the Houston Lighting and Power (HL&P) Company on February 5, 1993, and dispatched an augmented inspection team (AIT) to investigate the
]
details surrounding the turbine-driven auxiliary feedwater pump problems. The i
CAL, and its two supplements, identified a number of issues which required' resolution prior to either unit being restarted.
The NRC Region IV Regional Administrator chartered the'STP Review Panel on March 11, 1993. The purpose of the STP Review Panel.is to:
- Assure consistent approach to issues being identified at South Texas Project and attempt to reach an agency consensus and united approach to addressing the problems at South Texas Project.
- Assure that the followup on safety significant issues is being' properly coordinated and scheduled.
- Schedule significant meetings and inspections.
- Assure that the views and concerns of different NRC offices are properly addressed.
- Assure proper coordination for the followup of issues that are identified by the Diagnostic Evaluation Team (DET) inspection.
1
On April 12, 1993, it was determined that NRC Inspection Manual Chapter 0350,
" Staff Guidelines for Restart Approval," was applicable for the South Texas Project Electric Generating Station (STP) because of its extended shutdown and previous indications of serious deficiencies in licensee management effectiveness.
The STP Review Panel assumed the role and responsibilities of the STP Restart Panel.
These responsibilities include:
1.
Reviewing availabl2 information related to the plant shutdown 2.
Developing the Restart Action Plan 3.
Reviewing the licensee's corrective action or improvement program and ensuring that it addresses identified problems and weaknesses 4.
Maintaining an ongoing overview of licensee performance 5.
Conducting periodic meetings with the licensee to discuss progress toward satisfactory completion of the program 6.
Providing oversight and coordination of the NRC's followup activities, reviewing inspection plans and findings, and reviewing licensee performance; identifying areas where NRC inspection and technical review are needed 7.
Providing periodic assessments of licensee performance and corrective actions to NRC management 8.
Providing a recommendation to the Regional Administrator and the i
Director of NRR for approval of restart after satisfactory completion of the licensee's restart program In addition to the AIT activities, several special inspections have been conducted since February 1993, in response to compliance and regulatory issues at STP.
Several of these inspections resulted in enforcement action being taken. Corrective actions have been proposed by the licensee.
Additionally, the NRC Office for Analysis and Evaluation of Operational Data conducted a diagnostic evaluation of the STP during the period March 29 to April 30, 1993. The findings of this effort were forwarded to the licensee on June 10, 1993.
Numerous items were documented in this report, including a number of issues that NRC considered of sufficient scope and safety significance to require resolution prior to either unit being restarted.
In initial response to the Diagnostic Evaluation Team (DET) report, the licensee submitted a letter on August 5,1993, and forwarded their Operational Readiness Plan (ORP) on August 28, 1993.
In addition to responding to the DET short-term problems that the licensee considered necessary to resolve prior to restart, the ORP addressed the planned actions in response to the CAL, special and routine Regional inspections, and other identified concerns and problems.
The ORP addressed initiatives that the licensee considered necessary to be completed prior to the resumption of power operation on either unit.
The licensee's Business Plan was scheduled to be issued on October 15, 1993.
It will describe the initiatives being undertaken to effect sustained performance improvements at the site.
2 i
1 A.4 RESTART ACTION PLAN OVERVIEW A comprehensive NRC review of the restart process is required. The plants are in a safe shutdown condition and measures are in place to physically maintain the plants in a safe shutdown condition. This Restart Action Plan is intended i
to include expected NRC actions that will be required to be taken before restart of the STP units, including those actions not directly related to the i
initiating event. The plan defines: the actions which must be accomplished l
by the NRC, as a minimum, to approve restart; which organization has the lead 1
responsibility for each action; which plant specific issues must be resolved before restart; and who has the actual responsibility for restart approval.
The Panel retains responsibility for assessment of the issue and determining whetbar the issue has been satisfactorily addressed. The STP Restart Panel will make updates and minor revisions to the Restart Action Plan without seeking approval from the Regional Administrator and the Associate Director for Projects. Revisions which are determined by the Panel to be significant will be submitted for approval.
Section B, " PROCESS," of this plan provides generic tasks that support the Restart Action Plan.
This section outlines the overall review process needed for the NRC to authorize restart of the facility.
Section C, " ISSUES," contains issues for consideration and areas requiring l
assessment during the restart review.
The issues in this section are broader than the plant specific restart issues and have been determined to be applicable because of the declining performance of the licensee and the extended length of the shutdown.
It will not be necessary for each item on the checklists to be assessed, but enough items on a checklist must be
)
reviewed to assess the broader areas such as management oversight and effectiveness.
Section D, " PLANT SPECIFIC STARTUP ISSUES," lists plant-specific issues which must be evaluated and resolved prior to plant startup. This list was developed from a review of the Diagnostic Evaluation Team Report, the Executive Director for Operations staff actions memorandum following the Diagnostic Evaluation, the Confirmatory Action Letter and its supplements, the licensee's Operational Readiness Plan, the allegation review process, and routine and special NRC reports, including the Augmented Inspection. Criteria for selection of restart issues ensured inclusion of issues whose resolution is required to: ensure safe facility operation; comply with Technical i
Specification and other regulatory requirements; satisfy the plant's design and licensing basis; ensure effective management oversight; or ensure an effective corrective action process.
Each of the restart issues is, or will be, included on the licensee's restart issue list.
Prior to restarting either STP unit, the licensee will resolve each restart issue to its satisfaction and to the NRC's satisfaction.
The licensee will provide a briefing for the NRC staff on the readiness for plant restart, including the issues included in the I
Confirmatory Action Letter and its supplements prior to restart. This meeting I
will be open to public observation.
Section E, " RESTART INSPECTIONS," lists the inspections to be completed to evaluate the licensee's response to the startup issues.
Issues listed in Sections C and D will be assessed or inspected by resident inspectors, regional inspectors, or an Operations Readiness Assessment Team.
In addition, some areas or items may be assessed by the STP Restart Panel.
3
Each of the checklists in Sections B and C include columns to record the NRC organization with lead responsibility for the item and the date the item was closed.
The list in Section D includes a column to record the date the issue was closed.
The reference /information notes following each checklist table will document the detailed status of each item, including reference to closeout documentation.
The STP Restart Panel is responsible for implementation of the STP Restart Action Plan.
The STP Restart Panel will maintain and periodically review the Restart Action Plan.
These actions should:
(1) determine review status, (2) verify necessary tasks and items are complete for each phase of the review, and (3) ensure that review tasks and issues for assessment remain consistent with the known facts and status of the restart effort.
The generic lists in Sections B and C should be reviewed when significant milestones are completed and prior to restart authorization to ensure any emerging items are considered.
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B.
PROCESS B.1 INITIAL NRC RESPONSE:
This section outlines the general NRC restart review process. The major process steps (i.e., Initial Response, Initial Notifications, etc.) are broken down into potential tasks that are provided in a checklist format. The short discussion before each major process step provides insight into the intended i
activity. An effort was made to place the major steps and tasks in the general order of performance; however, the exact sequence of events cannot be predicted in advance. Thus, many of the major process steps and the specific '
tasks are expected to be performed in parallel.
The tables provide a column to indicate the lead responsible organization and j
closeout date. Tasks which the restart panel has determined to not be applicable to the STP restart process are marked "NA."
TASK RESP ORG DATE CLOSED a.
Initial notification and NRC management RIV 02/04/93 i
discussion of known facts and issues b.
Identify / implement additional inspections RIV 02/04/93 (i.e., AIT, III, or Special) c.
Determine need for formal regulatory RIV 02/05/93 response (i.e., Order or CAL) d.
Determine need for senior management RIV, NRR 03/11/93 involvement e.
Identify other parties involved, i.e.,
RIV, NRR 02/25/93 NRC Organizations, other Federal agencies, and industry organizations f
Reference /Information B.I.a PN 4-93-003 B.I.b PN 4-93-003; AIT dispatched. AIT Inspection Report 9307 issued on 03/24/93.
B.l.c PN 4-93-003; CAL 4-93-04 issued B.I.d STP Review Panel Charter approved B.I.e AE0D was the only other organization involved in the short-term response.
5
B.2 NOTIFICATIONS:
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.
TASK RESP ORG DATE CLOSED a.
Issue Daily and Directors Highlight NRR Ongoing b.
Issue PN RIV 02/04/93 c.
Conduct Commissioner Assistants' RIV 06/25/93 Briefing d.
Issue Commission Paper NA NA e.
Cognizant Federal agencies notified NA NA (i.e., FEMA, EPA 00J, D0L) f.
State and Local Officials notified RIV Ongoing g.
Congressional notification NA NA i
t Reference /Information
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B.2.a Directors Highlight 02/17/93 and approximately weekly thereafter i
B.2.b PN 4-93-003 B.2.c Conducted in conjunction with the Commission briefing on the results of the June 93 senior managers meeting.
B.2.d NA B.2.e NA B.2.f Monthly public meeting announcements.
The Deputy Regional Administrator and the STP Restart Panel Chairman briefed the Texas Public Utility Commission and the Austin City Council on 09/09/93, B.2 9 PN 4-93-003.
NRR discussed with Congressional Affairs.
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B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS:
It will be necessary to establish and organize the NRC restart review to ensure the effective coordination of resources in evaluating the restart Effective interfaces within and outside the NRC are critical to process.
properly identify, coordinate, and resolve the pertinent issues.
Consider both regional and headquarters offices of cognizant State and Federal agencies.
TASK RESP ORG DATE CLOSED l
a.
Establish the Restart Panel RIV 03/11/93 b.
Assess available information (i.e., inspection PANEL Ongoing results, licensee self-assessments, industry reviews) c.
Obtain input from involved parties both within PANEL Ongoing NRC and other Federal agencies, such as FEMA, EPA, D0J, DOL d.
Conduct Regional Administrator Briefing PANEL Ongoing e.
Conduct NRR Executive Team Briefing NRR 06/93 i
Develop the Case Specific Checklist (CSC)
RIV/DRP 10/93 f.
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g.
Develop the Restart Action Plan RIV/DRP 10/93 h.
Regional Administrator approves Restart Action RIV Pending Plan i.
NRR Associate Director and/or NRR Director NRR Pending approves Restart Action Plan j.
Implement Restart Action Plan PANEL Ongoing i
k.
Modify CAL /0rder as necessary RIV/DRP 05/07/93 Reference /Information B.3.a First Panel meeting held on 02/25/93.
Panel charter approved on 03/11/93.
B.3.b Panel meeting notes of 02/25/93 B.3.c No external issues identified.
B.3.d Briefings provided following Panel meetings.
B.3.e full discussion at June 93 Senior Managers Meeting.
NRR will provide 3
l periodic Executive Team briefings.
B.3.f This document includes the CSC.
B.3 9 This document is the Restart Action Plan.
I 7
B.3.h B.3.i B.3.j B.3.k CAL Supplement issued May 7.,1993.
CAL Supplement 2 issued on October 15, 1993.
8
l B.4 REVIEW IMPLEMENTATION:
i The review can be accomplished by a variety of methods including inspections, testing, evaluation of licensee self-assessments, evaluation of licensee action plans, and regulatory actions (i.e., Orders, CAL's).
Early establishment of the review areas will assist in defining the methods to perform the review.
Once the licensee has developed its corrective action plan, the NRC shall review that plan to verify its completeness and adequacy.
The NRC will also need to determine which corrective actions will be required to be implemented before restart and, thus, become restart issues which can be deferred to some later date as long-tenn corrective actions.
The discussions and issues provided in Section C of this appendix provide additional information to support the review activities described below.
B.4.1 Root Causes and Corrective Actions:
TASK RESP ORG DATE CLOSED a.
Evaluate findings of AIT, IIT, or Special RIV 03/24/93 Team inspection b.
Licensee performs root cause analysis and PANEL Pending develops corrective action plan for root causes c.
NRC evaluates licensee's root cause PANEL Pending determination and corrective action plan Reference /Information AIT Inspection Report 9331, AIT Followup Inspection Report 9305 B.4.1.a dated 04/08/93.
B.4.1.b DET response status letter submitted 08/05/93. Operational Readiness Plan submitted 08/28/93. Business Plan to be submitted by 10/15/93.
B.4.1.c NRC letters of 08/26/93 and 09/22/93 acknowledged receipt of licensee submittals of 08/05/93 and 08/28/93.
B.4.2 Assessment of Eauipment Damage:
This section is not applicable for the South Texas Project restart approval.
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i B.4.3 Determine Restart Issues and Resolution:
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 table outlines I
steps to determine the restart issues and NRC's evaluation of their l
resolution.
TASK RESP ORG DATE I
CLOSED a.
Review / evaluate licensee generated restart PANEL 10/05/93 issues b.
Independent NRC identification of restart PANEL 09/27/93 issues (consider sources external to NRC and licensee) c.
NRC/ licensee agreement on restart issues PANEL 10/15/93 l
d.
Evaluate licensee's restart issues PANEL Ongoing i
implementation process e.
Evaluate licensee's implementation PANEL verification process Reference /Information l
B.4.3.a Public meeting and Panel meeting.
B.4.3.b Panel meeting notes.
Inspection Report 9331 B.4.3.c CAL Supplement 2 issued.
B.4.3.d B.4.3.e l
10
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i 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 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 NRR.
i i
l TASK RESP ORG DATE CLOSED a.
Obtain public comments PANEL Ongoing b.
Obtain comments from State and Local PANEL Ongoing Officials c.
Obtain comments from applicable Federal PANEL /NRR agencies Reference /Information B.4.4.a DET public exit meeting at site 06/03/93.
Public meetings at site 07/16/93 and 09/08/93.
Public meeting in the RIV office 10/05/93.
4 B.4.4.b The Deputy Regional Administrator and the STP Restart Panel Chairman briefed the Texas Public Utility Commission and the Austin City Council on 09/09/93.
B.4.4.c l
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B.4.5 Closecut Actions:
When the actions to resolve the restart issues and significant concerns are substantially complete, closecut actions are needed to verify that planned inspections and verifications are complete. The licensee should certify that corrective actions required prior to restart are complete and that the plant is physically ready for restart. This table provides actions associated with completion of significant NRC reviews and preparations for restart.
TASK RESP ORG DATE CLOSED I
' a.
Evaluate licensee's restart readiness PANEL sel f-assessment b.
NRC evaluation of applicable items from PANEL section C " ISSUES" complete c.
Restart issues closed PANEL d.
Conduct NRC Restart Readiness Team NRR Inspection e.
Issue Augmented Restart Coverage RIV/DRP Inspection Plan f.
Comments from other parties considered PANEL g.
Determine that all conditions of the CAL PANEL 3
and its Supplements are satisfied h.
Re-review of Generic Restart Checklist PANEL complete Reference /Information B.4.5.a B.4.5.b B.4.5.c B.4.5.d B.4.5.e B.4.5.f B.4.5.g B.4.5.h i
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B.5 RESTART AUTHORIZATION:
When the restart review process has reached the point that the issues have been identified, corrected, and reviewed, a restart authorization process is begun. At this point the restart panel should confirm that all actions are substantially complete and that the panel has not overlooked any items.
TASK RESP ORG DATE CLOSED Prepare restart authorization document and RIV/DRP a.
basis for restart b.
NRC Restart Panel approves Restart PANEL Authorization c.
No restart objections from other PANEL applicable HQ offices d.
No restart objections from applicable PANEL Federal agencies Regional Administrator concurs 'in Restart RIV e.
Authorization f.
NRR Associate Director and/or NRR Director NRR i
l Concurs in Restart Authorization g.
ED0 concurs in Restart Authorization RIV 1
1 h.
Conduct ACRS briefing / notification NRR i
i.
Conduct Commission briefing / notification NA NA j.
Commission concurs in Restart NA NA Authorization k.
Regional Administrator authorizes restart RIV Reference /Information B.5.a B.S.b l
B.5.c B.S.d B.S.e B.S.f l
B.S.g i
B.5.h B.S.i NA B.5.j NA B.5.k i
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B.6 RESTART AUTHORIZATION NOTIFICATION:
Notify the applicable parties of the restart authorization.
Communication of planned actions is important at this stage to ensure that NRC intentions are clearly understood.
TASK RESP ORG DATE CLOSED a.
Commission NRR i
b.
EDO RIV/NRR l
c.
Congressional Affairs NRR d.
Applicable Federal Ager.cies RIV/NRR f.
Public Affairs RIV g.
State and Local Officials RIV Reference /Information l
B.6.a l
B.6.b B.6.c B.6.d l
B.6.e B.6.f l
B.6 9 l
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i C.
ISSUES C.1 ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION:
I C.l.1 ROOT CAUSE ASSESSMENT:
i The root cause(s) of the event or the conditions requiring the shutdown should i
be identified and corrected. A comprehensive licensee corrective action plan should be developed that addresses the root cause(s) and all applicable issues including corrective action, implementation, and verification.
The corrective action plan should also include sufficient measures to prevent recurrence of i
l problems. The NRC shall review the licensee's corrective action plan to verify its completeness and adequacy and to determine which corrective actions j
will be required to be implemented before restart and which can be deferred to some later date as long-term corrective actions.
I The NRC staff will review the licensee's corrective action activities and use the appropriate tools available in the regulatory program to determine the i
acceptability of these actions with respect to safe operations. The tools which are available include:
staff reviews; the systematic assessment of licensee performance (SALP); inspections, including special team inspections; requests under 10 CFR 50.54(f); senior management meetings; enforcement conferences; and a restart panel. The results of the staff's reviews will be documented by safety evaluations, license amendments, orders, Confirmatory Action Letters, inspection reports, Commission meeting transcripts, and i
i enforcement documents.
ISSUES RESP ORG DATE CLOSED l
1.
Cond.rions requiring the shutdown RIV 02/05/93 are clearly understood 1
2.
Root causes of the conditions PANEL 06/10/93 requiring the shutdown are clearly j
understood l
3.
Root causes of other significant PANEL 06/10/93 problems are clearly understood l
4.
Evaluate adequacy of the root cause RIV analysis program NRR/DRIL l
l Reference /Information 1.
CAL of 02/05/93; CAL Supplements of 05/07/93 and 10/15/93; DET Report of 06/10/93 2.
CAL of 02/05/93; CAL Supplements of 05/07/93 and 10/15/93; DET Report of 06/10/93 l
l 3.
CAL of 02/05/93; CAL Supplements of 05/07/93 and 10/15/93: DET Report j
l of 06/10/93 4.
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C. I.2 DAMAGE ASSESSMENT:
Not applicable for South Texas Project.
5 16
l C. I.3 CORRECTIVE ACTIONS:
ISSUES RESP ORG DATE CLOSED 1.
Evaluate adequacy of the comprehensive PANEL corrective action plan 2.
Evaluate adequacy of the corrective RIV action programs for specific root NRR/DRIL causes 3.
Assess control of corrective action RIV item tracking NRR/DRIL 4.
Effective corrective actions for the RIV conditions requiring the shutdown have NRR/DRIL been implemented 5.
Effective corrective actions for other RIV significant problems have been NRR/DRll implemented 6.
Adequacy of the licensee's corrective RIV action verification process NRR/DRIL Reference /Information 1.
DET response status letter submitted 08/05/93. Operational Readiness Plan submitted 08/28/93. Business Plan to be submitted by 10/15/93.
t l
NRC letters of 08/26/93 and 09/22/93 acknowledged receipt of licensee l
submittals of 08/05/93 and 08/28/93.
2.
t 3.
4.
)
i 5.
i 6.
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C.I.4 SELF-ASSESSMENT CAPABILITY:
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 i
ensure the issue is resolved.
Senior licensee management involvement in self-assessment is treated separately.
j ISSUES RESP ORG DATE CLOSED Ws m, 1.
Effectiveness of Quality Assurance Program PANEL NRR/DRIL 2.
Adequacy of Industry Experience Review PANEL Program NRR/DRll 3.
Adequacy of licensee's Independent Review PANEL Groups NRR/DRIL 4.
Adequacy of deficiency reporting system RIV NRR/DRIL 5.
Staff willingness to raise concerns RIV/DRS 6.
Effectiveness of PRA usage NA NA
{
7.
Adequacy of Commitment Tracking Program NA NA 8.
External audit (i.e., INPO) capability PANEL 9.
Quality of 10 CFR 50.72 and 50.73 Reports NA NA 1
Reference /Information 1.
2.
3.
4.
5.
6.
NA 7.
NA 8.
INP0 review / assistance visit completed 09/24/93.
9.
NA
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C.2 ASSESSMENT OF LICENSEE MANAGEMENT:
The licensee's management organization should be assessed by NRC staff to ensure that qualified personnel, the proper environment, and resources are provided to ensure that the problems and their root causes have been or are being rectified. The organization must demonstrate that it can coordinate, integrate, and communicate its objectives so that they are assigned appropriate priorities regarding safety significance and are completed in a timely manner. NRC reviews will determine if the licensee has effective corporate management oversight and involvement in plant operations and problem resolution.
The licensee's management must appreciate the safety significance of certain issues and ensure that these issues are resolved.
The licensee's organization should:
(1) exhibit good teamwork among its subelements; (2) provide strong engineering and technical support for plant activities; (3) possess the internal ability to recognize safety problems, develop and implement adequate corrective actions and verify their effectiveness; (4) possess an independent j
self-assessment capability that can identify and correct performance problems; and (5) have adequate administrative and technical resources available to accomplish the stated goals and objectives.
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C.2.1 Management Oversicht and Effectiveness ISSUES RESP ORG DATE CLOSED 1.
Management commitment to achieving PANEL improved performance NRR/DRIL 2.
Performance goals / expectations PANEL developed for the staff NRR/DRIL 3.
Goals / expectations communicated to the PANEL staff NRR/DRIL 4.
Resources available to management to PANEL achieve goals NRR/DRIL 5.
Qualification and training of PANEL management NRR/DRIL 6.
Management's commitment to procedure PANEL adherence NRR/DRll 7.
Management involvement in self-PANEL assessment and independent self-NRR/DRIL assessment capability 8.
Effectiveness of management review PANEL committees NRR/DRIL 9.
Effectiveness of internal management PANEL meetings NRR/DRIL
- 10. Management in-plant time PANEL NRR/DRIL
- 11. Management's awareness of day-to-day PANEL operational concerns NRR/DRIL
- 12. Ability to identify and prioritize PANEL significant issues NRR/DRIL
- 13. Ability to coordinate resolution of PANEL significant issues NRR/DRIL
- 14. Ability to implement effective PANEL corrective actions NRR/DRIL 20
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Reference /Inft,rmation 1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
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C.2.2 Management Organization and Support:
ISSUES RESP ORG DATE CLOSED l
1.
Structure of the organization PANEL l
2.
Ability to adequately staff the RIV/DRS organization l
l 3.
Effect of any management reorganization PANEL l
4.
Establishment of proper work environment RIV NRR/DRIL 5.
Ability to foster teamwork among the RIV staff NRR/DRIL 6.
Ability to resolve employee concerns RIV/DRS 7.
Ability to provide engineering support RIV/DRS NRR/DRIL 8.
Adequacy of plant administrative RIV/DRP/DRS procedures 9.
Information exchange with other utilities RIV/DRS
- 10. Participation in industry groups RIV/DRS
- 11. Ability to function in the emergency RIV/DRSS respente organization
- 12. Coordination with offsite emergency NA NA planning officials Reference /Information 1.
2.
3.
4.
5.
l, 6.
7.
8.
9.
10.
11.
12.
NA 22
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l C.3 ASSESSMENT OF PLANT AND CORPORATE STAFF:
i The licensee staff must be capable of recognizing and carrying out their responsibilities to ensure public health and safety. An adequate number of fully qualified licensee staff shall be assigned. A proactive attitude toward safety issues should be demonstrated in all aspects of operations.
In this regard, the licensee staff should display attentiveness to duty, fitness for duty, a disciplined approach to activities, a sensitivity for trends in the plant, security awareness, an openness of communications, and a desire for teamwork that supports effective relations between different groups (e.g.,
management, operations, health physics, maintenance, engineering, security, and contractors).
r j
C.3.1 Assessment of Staff:
i f
l ISSUES RESP ORG DATE CLOSED 1.
Staff commitment to achieving improved PANEL l
performance NRR/DRIL t
2.
Staff's safety consciousness PANEL l
NRR/DRIL f
3.
Understanding of management's PANEL expectations / goals NRR/DRIL 4.
Understanding of plant issues and PANEL corrective actions NRR/DRIL 5.
Morale PANEL NRR/DRIL 6.
Staff (union)/ management relationship PANEL NRR/DRIL 7.
Structure of the organization PANEL NRR/DRIL 8.
Effect on the staff of any PANEL
]
reorganization NRR/DRIL i
9.
Resources available to the staff PANEL
)
NRR/DRIL
- 10. Qualifications and training of the PANEL staff NRR/DRIL
- 11. Staff's work environment PANEL f
NRR/DRIL
- 12. Staff's fitness for duty NA
- 13. Attentiveness to duty PANEL NRR/DRIL
- 14. Level of attention to detail PANEL NRR/DRIL 23 l
l
I
- 15. Adequacy of staffing PANEL NRR/DRIL
- 16. Off-hour plant staffing PANEL NRR/DRIL
- 17. Rotation schedule for shift workers PANEL NRR/DRIL
- 18. Staff overtime usage PANEL NRR/DRIL j
- 19. Amount of contractor usage PANEL NRR/DRIL
- 20. Staff / contractor relationship PANEL NRR/DRIL
- 21. Understanding of the allegation process RIV/DRS and protection of workers who communicate with the NRC
- 22. Procedure usage / adherence RIV/DRP
- 23. Awareness of plant security RIV/DRSS 09/01/93
- 24. Understanding of offsite emergency NA NA planning issues Reference /Information 1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
NA 13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
STP Security force management initiatives and the results of an independent security force management assessment were discussed in a 24
1 i
management meeting with the licensee on September 1, 1993. No restart 1
issues were identified as a result of this meeting or previous security inspection findings.
24.
No restart issues have been identified in this area.
)
i l
l 9
25
,.w-,r
f C.3.2 Assessment of Corporate Support:
Not Applicable for South Texas Project.
C.3.3 Operator issues:
ISSUES RESP ORG DATE CLOSED l.
Licensed operator staffing meets RIV/DRS requirements and licensee goals NRR/DRIL 2.
Level of formality in the control room RIV/DRS NRR/DRIL 3.
Adequacy of control room simulator RIV/DRS training NRR/DRIL 4.
Control room / plant operator awareness RIV/DRS of equipment status NRR/DRIL 5.
Adequacy of plant operating procedures RIV/DRS NRR/DRIL 6.
Procedure usage / adherence RIV/DRS NRR/DRIL 7.
Log keeping practices NA NA Reference /Information 1.
2.
3.
Results of 09/27/93 - 10/01/93 exams (Inspection Report 93-34) 4.
5.
6.
7.
No restart issues have been identified in this area.
l 26
]
C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT:
The physical condition of the plant is of principal importance not only when a shutdown is the result of a physical event or a hardware deficiency but for other reasons as well, especially following prolonged outages.
The causes of significant equipment problems should be identified and appropriate corrective actions taken. Operational testing should verify that each significant equipment problem has been resolved. As appropriate, the complete spectrum of preoperational and startup testing programs may need to be expanded to cover the more complex types of problems or the effects on plants that have been shut down for extended periods.
The licensee must be able to demonstrate that all needed safety equipment is operational before restart.
Systems and equipment need to be available and aligned. Surveillance tests should also be up to date. The maintenance backlog should be managed at controllable levels and should be evaluated for impact on safe operation. Maintenance must also be capable of responding to equipment failures during startup and operation and should not be hindered by unresolved chronic problems with equipment readiness.
Procedures should be adequate and up to date. The emergency preparedness function both onsite and offsite needs to be capable of protecting public health and safety.
9 f
i 27
l i
l ISSUES RESP ORG DATE CLOSED 1.
Operability of technical specifications RIV/DRP systems NRR/DRIL 2.
Operability of required secondary and RIV/DRP support systems NRR/DRIL 3.
Results of prestartup testing RIV/DRP i
4.
Adequacy of system lineups RIV/DRP l
NRR/DRIL 5.
Adequacy of surveillance tests / test RIV/DRP program NRR/DRIL 6.
Significant hardware issues resolved PANEL (i.e., damaged equipment, equipment ageing, modifications) l 7.
Adequacy of the power ascension testing PANEL l
program i
8.
Adequacy of plant maintenance program RIV/DRS effectiveness NRR/DRIL 9.
Maintenance backlog managed and impact RIV/DRS on operation assessed
- 10. Adequacy of plant housekeeping and RIV/DRP equipment storage j
- 11. Adequacy of emergency preparedness RIV/DRSS accountability drills Reference /Information 1.
2.
1 3.
4.
j 5.
6.
7.
8.
9.
10.
11.
28
C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS:
i The plant and its prospective operation must not be in conflict with any applicable regulations or requirements of any document authorizing restart j
(such as license amendments, orders, or a CAL).
Restart should not conflict I
with any ongoing matter such as an Atomic Safety and Licensing Board hearing.
t ISSUES RESP ORG DATE CLOSED 1.
Applicable license amendments have been NRR i
issued 1
2.
Applicable exemptions have been granted NA NA l
3.
Applicable reliefs have been granted NA NA j
4.
Imposed Orders have been NA NA l
modified / rescinded j
5.
Confirmatory Action Letter conditions PANEL l
have been satisfied 6.
Significant enforcement issues have PANEL been resolved 7.
Allegations have been appropriately PANEL addressed 8.
10 CFR 2.206 Petitions have been NRR 07/08/93 appropriately addressed
}
9.
Atomic Safety and Licensing Board NA hearings have been completed Reference /Information 1.
2.
NA 3.
NA 4.
NA 5.
I 6.
7.
8.
Saporito Petition acknowledgement letter of 07/08/93 9.
l i
j 29 l
1 l
C.6 C00RDINA110N WITH INTERESTED AGENCIES / PARTIES:
Coordination with other interested parties and agencies is important to ensure that concerns and requirements of these organizations are factored into the restart authorization.
DATECLOSED_)
ORGANIZATION RESP ORG 1.
Federal Emergency Management Agency RIV/NRR 2.
Environmental Protection Agency NA NA 3
Department of Justice PANEL 4.
Department of Labor PANEL 5.
Appropriate State and Local Officials RIV 6.
Appropriate Public Interest Groups RIV 7.
Lot 11 News Media RIV Reference /Information 1.
2.
NA 3.
4.
5.
6.
7.
h l
l l
l 30
D.
PLANT SPECIFIC STARTUP ISSUES f
The list of plant specific restart issues was developed from a review of the Diagnostic Evaluation Team Report, the Confirmatory Action Letter and supplements, the licensee's Operational Readiness Plan, routine and special NRC reports, the allegation process, and NRC staff actions assigned by the Executive Director for Operations following the Diagnostic Evaluation. NRC Inspection Report 50-498/499-9331 identified and assigned an Inspection followup Item for each item related to issues which require resolution prior j
to the restart of either STP unit. This table will be updated periodically to reflect the status of inspection activities at STP.
The table following this page lists the plant-specific restart issues and their current status.
i 1
l 31
t RESTART ISSUE RELATED ITEMS DATE CLOSED t
1 Turbine-driven Auxiliary Feedwater Pump 9331-07, 08, 09, 10, 43, 50, 71 Reliability and Testing Methodology 9305-04, 05, 07 Unit 1 LER 9307 Unit 2 LER 9304
)
2 Station Problem Report Process, Threshold, 9331-06, 18, 23, 25, 26, 27, 28, 67 Licensee's Review of Existing Reports for 9235-02 Issues Affecting Operability and Safe Plant 9224-01 Operation 9321-01 9322-02 9308-02, 04 1
3 Service Request Backlog, including Reduction 9331-02, 03, 07, 08, 09, 29, 31, 37, 38, Accomplished During the Current Outages and 39, 47, 49, 62, 79, 80 the Licensee's Review of Outstanding SRs for Issues Affecting Equipment Operability, Safe Plant Operation, and Operator Work-arounds 4
The Postmaintenance Test Program, Including-9331-03, 04, 07, 10, 13, 14, 15, 51, 63, Corrective Actions in Response to Violations.
68, 79 and Other-Process improvements-and'the Basis 9226-03 For the Licensee's Confidence That Equipment 9320-02 Removed From Service for Maintenance is 9305-01, 05, 07
-Properly Restored to an Operable Status Unit 1 LER 9204, 9207, 9214, 9216, 9305 5
The Outstending Design Modifications, 9331-02, 04, 08, 12,'16, 18, 19, 20, 21, Temporary Modifications, and Other Engineering 30,'31, 40, 41, 42, 44, 45, 48, 52, 64, Backlog Items,-Including the Licensee's Review' 65, 77, 81 of These For Issues Affecting Equipment 9208-01 Operability,. Safe Plant.0peration, and
.9306-07 Operator Work-arounds 9315-01 Unit 1 LER 9220, Unit 2 LER 9204 I
32
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1 RESTART ISSUE RELATED ITEMS DATE CLOSED 6
Adequacy of Operations Staffing 9331-01, 03, 24, 56, 57, 59, 60, 65, 66, 73 9116-02 9304-03, 04 4
9311-04 9322-01 Unit 2 LERs 9305, 9312 7
Adequacy of Fire Brigade Leader Training and 9331-04, 33, 75 Qualifications 8
Adequacy of Fire Protection Computers and 9331-02, 04,-17, 22, 58, 75 Software, the Licensee's Success in Reducing 9235-06 the Number of Spurious Fire Protection System 9309-01 i
Alarms, and Other Fire Protection Hardware i
i Problems 9
Licensee Management's Effectiveness in 9331-04, 05, 06, 17, 18, 22, 23, 25, 32, identifying, Pursuing, and Correcting Plant 34, 35, 37, 46, 54, 55, 56, 61, 62, 65, 67, 69, 70, 72, 73, 80, 82 Problems 9321-01 9322-02 9224-01 9217-02,-04 9303-01 9308-02, 04 Unit l'LER 9204 10 NRC Review of the' Effectiveness of the 9331-78 Licensee's SPEAK 00T Program 33
_______________._.___..a.11~,,...1_____________
RESTART ISSUE RELATED ITEMS DATE CLOSED 11 Standby Diesel Generator Reliability 9331-08, 09, 11, 12, 13, 16, 19, 28 9214-03 9221-03 9305-01 9315-03 Unit 1 LER 9305 12 Essential Chiller Reliability 9331-10, 13, 20, 21, 44, 45, 74 9224-03 i
Monitoring of the Licensee's System 9331-35, 53 13 Certification Program Adequacy of the Licensee's Resolution of the 9319-01 through 07 14 Reliability and Operability of the Feedwater 9324-01 Isolation Bypass Valves Unit 1 LER 9317 Unit 1 LER 9320 15 Tornado Damper issues 9331-76 16 Emergency Preparednest Accountability issues URI 498:499/9325-02 Reference /Information 1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
34 s
.i u.
E.
RESTART INSPECTIONS I
RESP SCHEDULE INSPECTION ORG LEAD 1
+RI 11/01/93 2
SPR PROCESS, THRESH 0LD, REVIEW DRS TOM 10/12/93 i
RESULTS
+RI 12/13/93 3
SERVICE REQUEST BACKLOG STATUS AND DRP MAS 11/15/93 i
REVIEW, EFFECT ON EQUIPMENT LDG OPERABILITY, SAFE OPERATION, OPERATOR WORK-AROUNDS 4
POSTMAINTENANCE TEST PROGRAM DRS TOM 10/25/93
)
RBV 11/29/93 J
5 ENGINEERING BACKLOGS DRS TFW 11/15/93 j
6 OPERATIONS STAFFING DRS/DRP JLP 11/01/93
+RI 7
FIRE BRIGADE LEADER QUALIFICATIONS DRS GLC 10/18/93 j
8 FIRE PROTECTION COMPUTERS DRS GLC 10/18/93 9
MANAGEMENT EFFECTIVENESS IN DRP/DRS/DRSS EACH l
IDENTIFYING, PURSUING, AND-INSPECTION l
CORRECTING PLANT PROBLEMS l
10 SPEAK 0UT REVIEW DRS/HQ DAP 11/93 l
11 EDG ISSUES DRS/NRR TFW 11/08/93 12 ESSENTIAL CHILLER ISSUES DRP/NRR MAS 10/18/93 i
11/01/93 13 SYSTEM CERTIFICATION DRP/DRIL SRI /0 RAT ONGOING 14 FEEDWATER ISOLATION BYPASS VALVES DRS DAP 10/25/93 15 TORNADO DAMPERS DRP/NRR MAS 10/18/93 l
11/01/93 16 EP ACCOUNTABILITY DRSS BXM 11/18/93 17 LICENSEE'S READINESS ASSESSMENT DRP/NRR WDJ 12/93 18 ORAT DRIL JBJ 11/29/93 01/03/94 35
.-