ML20098B006
| ML20098B006 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/29/1994 |
| From: | Reis T NRC |
| To: | NRC |
| Shared Package | |
| ML20094C015 | List: |
| References | |
| FOIA-95-262 NUDOCS 9510020034 | |
| Download: ML20098B006 (43) | |
Text
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' s: -
November 29. 1994
'FOR:
Cooper. Restart Panel Members A.iB. Bead)/
P. H,-Harrel THROUGH:
/
FROM:
-T. Rein j
SUBJECT:
COOPER RESTART PANEL-MEETING - DECEMBER 5,.1994 A draf t. Restart Action Plan for CNS is attached.
The Restart Action-
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Plan is required by MC 0350.
The Action Plan consists of 3 sections -
GENERAL, PROCESS, & ISSUES.
The PROCESS and ISSUES sections' constitute
-the-Case Specific Checklist - Parts I and.II, respectively.
A meeting of the Cooper Restart Panel is scheduled 'for Monday, December 5, 1994 in the DRP conference room on the 400_ bridge.
The agenda for the meeting is as follows:
REVIEW / DISCUSS & APPROVE THE ELEMENTS OF THE CASE SPECIFIC e
CHECKLIST - PART I (PROCESS)
REVIEW / DISCUSS & APPROVE THE CASE SPECIFIC CHECKLIST - PART II e
(ISSUES) e DISCUSS AND SCHEDULE RESTART INSPECTIONS e
BASED ON AliOVE. PROVIDF APPROVAL FOR THE RESTART ACTION PLAN Many of the elements of the Lase Specific Checklist - Part I (PROCESS) have been completed as indicated in the attachment.
Please review and be prepared to make recommendations for additions,~ deletions and changes in assignment for Part I items.
The Case Specific Checklist - Part II (ISSUES) was first presented to you on November 4, 1994.
It has since been revised (current revision 2) to remove all-items that can be reviewed under the normal inspection program.
Those items removed have been added to other lists for tracking for routine review.
You should review these lists and be prepared to concur with the proposed approach.
The lists are attached and labeled as follows and a brief description is provided.
e SET PROPOSED RESTART ISSUES - items that the SET recommended be resolved e
SET ISSUES - items other than the above extracted from the SET report e
ISSUES TO BE REVIEWED UNDER THE NORMAL INSPECTION PROGRAM -
items identified through routine inspection, SET inspection, or licensee identified that do not impact facility restart
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9510020034 950905 PDR FOIA a PATTERS 95--262_ PDR _. _
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ITEMS NOT ~0 EE '1SPECTED - items identified thecugn normal inspection. SE~ nsoection, or licensee identifiea for whicn further reviea..ot recommended Review tne attached inforna. :n prior to the canel meeting and be preparea ta discuss ana rec:mmena changes in the current approach.
Attachments:
- 1) 1 raft Ce 'ar* Action Pl ar:
- 2) Non Aes'ar*
. s u e s L i '. t ;
- a. SET Lecoosed Restar*
. e; b.
SET Issues c.
- 3:ues.o Be Reviewea. ;er '40rmal Inspec. ion Program 1.
Ite95 Not to Be inspect-:
ic:
deacn n.
'. Howell 3
Gavnn
- 5. Collins
- 3. Beckner R. Hall J. harreil
.!1lCoX
- 3. NorKin E. :lerscnoff J. Freeman C Hackney J. Gillilano E. Collins
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i
'.;, y ENFORCEMENT CONFERENCE WITH [ LICENSEE]
September 16, 1994 NRC REGION IV, ARLINGTON, TEXAS 1.
OPENING REMARKS & INTRODUCTIONS - RA OR DIVISION DIRECTOR 2.
LICENSEE INTRODUCTIONS -
3.
ENFORCEMENT PROCESS - GARY SANB0RN OR RANDY HUEY 4.
APPARENT VIOLATIONS & REGULATORY CONCERNS - DIV DIRECTOR OR BRANCH CHIEF 5.
LICENSEE PRESENTATION -
6.
BREAK (10-MINUTE NRC CAUCUS IF NECESSARY) 7.
RESUMPTION OF DISCUSSION 8.
CLOSING REMARKS - LICENSEE 9.
CLOSING REMARKS - RA OR DIVISION DIRECTOR I
OPENING REMARKS (REGIONAL ADMINISTRATOR)
Good morning / afternoon.
I am J0E CALLAN, Regional Administrator for the Nuclear Regulatory Commission's Region IV office.
This morning we will conduct an enforcement conference between the NRC and Nebraska Public Power District.
This meeting is open to public observation.
I request members of the public to hold any questions that they may have about the conduct of the meeting until the conclusion of the meeting.
The NRC staff members will stay at the conclusion of the meeting to answer questions concerning the conduct of the enforcement conference.
The agenda for the enforcement conference is shown in the viewgraph.
Following my brief opening remarks, Mr. GARY SANB0RN, the Region IV Enforcement Officer, will discuss the Agency's enforcement policy.
Mr. Bill Beach, Director of Region IV's Division of Reactor Projects, and Mr. Pat Gwynn, Director of RIV's Division of Reactor Safety, will then discuss the apparent violations.
Mr. Guy Horn will then be given an opportunity to respond to the apparent violations.
In this regard, I wish to point out to Nebraska Public Power District and members of the public that the decision to hold this enforcement conference does not mean that the NRC has determined that violations have occurred or that enforcement action will be taken.
This conference is an important step in arriving at that decision.
Following Mr. Horn's presentation, I plan to take about a 10-minute recess so that the NRC can briefly review what it has heard and determine if we have
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g follow-up questions.
Lastly, Mr. Horn will be given an opportunity to provide closing comments and I will provide concluding remarks.
Prior to asking the Enforcement Officer to discuss the Enforcement Policy, I would like to introduce members of the NRC staff and then ask Nebraska Public Power District to introduce its participants.
Thank You, Mr. SANBORN will now discuss the agency's Enforcement Policy.
ENFORCEMENT POLICY (ENFORCEMENT OFFICER)
ENFORCEMENT POLICY AND PROCESS I'm going to provide a brief description of the NRC's enforcement program and, in particular, the role of enforcement conferences such as this.
The NRC's enforcement program is governed by the Commission's Enforcement Policy, which is published in Title 10 of the Code of Federal Regulations as Appendix C to 10 CFR Part 2.
Copies of the latest version of the policy are on the table for those who are interested in more information.
Although enforcement conferences are normally closed meetings between the NRC staff and licensee representatives, this conference is open to public observation in accordance with the terms of a trial program begun in July 1992.
While this trial program was originally scheduled to last two years, it has been extended while the NRC reviews the results and determines future policy.
Copies of the federal register notice announcing the extension of this program also are on the table as well as forms that can be used to offer comments on the pilot program.
[0ptional, depending on whether taping is planned] As you may have observed, we are recording this conference.
This is being done for the sole purpose of having a reference should there be any disagreement about what was said.
We do not-plan to transcribe the tapes, but will send copies of the tapes to the Public Document Room from which copies may be obtained by the licensee or members of the public.
NRC's Enforcement Policy establishes a system for classifying violations of NRC requirements according to their safety and regulatory significance, and describes a variety of enforcement sanctions that may be employed. The sanctions include notices of violation, monetary civil penalties, and orders requiring licensees to take certain actions or, in some cases, to suspend licensed activities. Willful violations of requirements can result in actions against individuals and may be referred to the U.S. Department of Justice for i
possible prosecution.
An enforcement conference is held when inspection or investigative findings 4
indicate that violations may have occurred which NRC considers significant from a safety or regulatory perspective.
.s G
The purpose of an enforcement conference is not to negotiate an enforcement
. sanction but to provide a forum for discussing apparent violations, their significance, the reasons for their occurrence, particularly the root cause or causes, and the corrective actions that a licensee has taken or plans to take.
As Mr. Callan stated, the apparent violations discussed at this conference are subject to review and may be revised prior to any resulting enforcement action.
It is important to note that a decision to conduct an enforcement conference does not mean that NRC has made a final determination that violations have occurred or that enforcement action will be taken.
The NRC will be seeking information to ensure that it has a complete understanding of the facts and circumstances surrounding any apparent violations. This includes. seeking the licensee's perspective on the information contained in NRC's inspection report, which was provided to the licensee and made publicly available in advance of the conference.
NRC is particularly interested in whether a licensee is challenging any of the factual information in the report or the apparent violations and, if so, the bases for such challenges.
Licensee representatives are encouraged to present any information that they consider relevant to the NRC's enforcement decision.
Following the enforcement conference, NRC representatives will review the information obtained during the inspection as well as the information gained from this enforcement conference to reach decisions on: 1) whether violations of requirements occurred;
- 2) whether enforcement sanctions should be employed; and 3) what those sanctions should be.
' At the conclusion of this process, which can take from a week to a few weeks, the NRC will inform licensee officials by telephone and in writing of its enforcement decision.
In addition, if the enforcement action involves a monetary civil penalty or an order, the NRC will issue a public announcement at the same time the action is taken.
That concludes the summary of the policy and the enforcement process.
At this time, I will answer any questions licensee representatives have about the NRC's Enforcement Policy or the process that the NRC follows in taking enforcement action.
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s.
REGULATORY CONCERNS (DIVISION DIRECTOR / BRANCH CHIEF)
The apparent violations were are discussing were discovered during an NRC inspection conducted June 13 through August 12, 1994, at the Cooper Nuclear Station and documented in 94-14.
The violations involve an apparently inoperable-primary containment for an undetermined period of time as. demonstrated by the significant leakage
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. identified during local: leak rate testing of penetrations'that you had never tested. The leakage you measured significantly exceeded'the Technical
-Specification limits.
The failure to identify the penetrations as safety-related resulted in the penetrations not receiving appropriate testing in accordance with regulatory requirements and Technical Specifications. Also included is the apparent breakdown.in your design control program, which contributed to the problems associated with the primary containment.
As you well know, an inoperable containment is a very significant safety concern.
In the event of an accident, the health and safety of the public could be seriously jeopardized by a loss of containment. integrity since at least two of the three principle safety barriers would be breached, and possibly all three.
Any breakdown of the design control program has the potential ~ to affect all activities at the station.
Without accurate design information, appropriate decisions.cannot be made to ensure public health and l
. safety. Without an accurate understanding of the design basis,-you cannot
~ identify and correct problems that affect the safe operation of the plant.
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's You have had numerous opportunities to identify the primary containment J
issues. These opportunities included, but were not limited to, Design Change 76-17, Revision 2, which installed thermocouple wires through an open valve; Design Change 90-0226, which identified concerns with your integrated i
leak rate test, as discussed in NRC Inspection Report 50-298/93-18; NRC Information Notice 83-53, " Primary Containment Isolation Valve Discrepancies;"
Generic Letter 87-06, " Periodic Verification of Leak Tight Integrity of Pressure Isolation Valves;" Information Notice 88-70, " Check Valve Inservice Testing Program Deficiencies;" and NRC Inspection Reports 50-298/93-13, and 94-03.
We would like for you address how so many penetrations and welds were improperly classified and remained undetected by you and your staff for such a long time; why your system engineers did not identify or question single isolation devices; how your engineering organization developed the integrated leak rate test with components isolated.
We would like to know the status of your design basis reconstitution program: where are you; what are your plans for the rest of the plant; what is your schedule for completion. We would also like to hear what steps you have taken, or plan to take, to correct
- I problems in your engineering organization so that you will not find yourself in a similar situation again.
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1, CLOSING REMARKS (REGIONAL ADMINISTRATOR)
In closing this enforcement conference, I remind Nebraska Public Power District and members of the public that the apparent violations discussed at this' enforcement conference are subject to further review and may be revised prior to any resulting enforcement action, and that the statements or expressions of opinion made by NRC employees at this enforcement conference, or the lack thereof, are not intended to represent final determinations or beliefs.
I would also like to remind you that the NRC is interested in your comments on its pilot program for opening enforcement conferences to public observation.
Forms for providing comments are on the table in the front of the room.
You do not have to identify yourself on the form; we welcome all comments.
If you don't want to use the forms, simply mail your comments to the Director, Office of Enforcement, U.S. NRC, Washington, D.C. 20555.
BRIEF THANKS TO PUBLIC AND LICENSEE 1
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CNS RESTART PANEL MEETING NOTES - OCTOBER 27. 1994 ATTENDEES
- A. Beach, Panel Chairman and Director, Division of Reactor Projects (DRP)
- S. Collins, Director, Division of Radiation Safety and Safeguards
- T. Gwynn, Director, Division of Reactor Safety (DRS)
- W. Beckner, Panel Vice Chairman and Director, PDIV-1, Office of Nuclear Reactor Regulation (NRR)
- R. Hall, Project Manager, NRR
- P. Harrell, Chief, Project Branch C, DRP
- R. Kopriva, Senior Resident Inspector, DRP
- T. Reis, Project Engineer, Project Branch C, DRP R. Wise, Allegations Coordinator
-E. Collins, Team Leader, DRS
- D. Freeman, Recorder, DRP
DISCUSSION OF CASE-SPECIFIC CHECKLIST Mr. Beach stated that it will not be necessary for all hardware and regulatory issues to be addressed before plant restart. Many can be handled through normal inspection procedures. Check on status of unresolved items before the last panel meeting.
There will probably be no Commission Paper issued.
The CAL may need to be amended to include the restart issues the panel decides upon.
Mr. Collins reminded members to keep in mind what section of the checklist they are working on so as to close out sections as they go along.
Mr. Collins stated that the licensee needs to define the programmatic issues, explain their approach and resolution, and have the resolutions independently verified.
Terry Reis was tasked to formulate a chart of blocks nf time needed for the various milestones toward the approval of restart, which is estimated to total 3 months.
There will be one inspection of 1-2 weeks, a public exit meeting, and a briefing of Mr. Taylor in HQ.
Terry Reis and Randy Hall were tasked to complete a review of Section C of MC 035 and integrate it with the proposed restart issues.
A3
CflS RESTART PANEL MEETING NOTES - NOVEMBER 4 1994 ATTENDEES A. Beach Panel Chairman and Director, Division of Reactor Projects (DRP)
S. Collins. Director. Division of Radiation Safety and Safeguards T. Gwynn. Director, Division of Reactor Safety (DRS)
W. Beckner, Panel Vice Chairman and Director, PDIV-1, Office of Nuclear Reactor Regulation (NRR)
R. Hall. Project Manager, NRR P. Harrell, Chief, Project Branch C, DRP T. Reis. Project Engineer, Project Branch C, DRP D. Freeman, Recorder, DRP All of the attendees at today's meeting are Restart Panel members.
DISCUSSION OF CASE-SPECIFIC CHECKLIST Old Business Mr. Reis explained the organization of the proposed case-specific checklist of restart issues.
The status column will list the appropriate inspection report and whether closed or open.
Mr. Reis has prepared a partial timeline chart.
New Business The title of the overall checklist will be added to the document.
All CAL items have to be addressed and should be noted in the reference column.
in Mr Beach's discussion with Mr. Mueller, the issues of the original list (1 - XI) (predecisional information) agreed with the licensee's list.
We need to ask Mr. Mueller to address only the management approach, not specific items, at the 11/8 meeting.
Issue XI (MANAGEMENT EFFECTIVENESS) is addressed in the SET.
Also, resolution of Issues I - X will partially address management effectiveness.
The Panel decided to leave issue XII (EXCEEDING C00LDOWN RATE) on the list instead of making it an item under issue X (HARDWARE).
Mr. Hall suggested adding the MOV operability item back to the list.
The Panel agreed.
Mr. Reis will have a dated slide to present at the 11/8 meeting showing only the checklist issues, not the items.
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j COOPER NUCLEAR STATION RESTART PANEL CHARTER MEMBERSHIP The Panel will be convened on an as-needed basis and the members will be:
Chairman Bill Beach, Director, DRP Vice Chairman Bill Beckner, Director, Project Directorate IV-1 Members Phil Harrell, Chief, Project Branch C Randy Hall, Project Manager, CNS Ron Kopriva, Senior Resident Inspector Deputy Director, DRS Sam Collins, Director, DRSS Art Howell, Technical Assistant to the RA Terry Reis, Project Engineer Denise Freeman, Recorder NOTE:
Panel members may designate appropriate substitutes.
NRR attendance may be via telecon.
In addition to the members, the following individuals will regularly attend each meeting:
Attendees Joe Gilliland, Public Affairs Officer Charles Hackney, State laision Officer Russ Wise, Allegation Coordinator RESPONSIBILITIES Review all available information related to the plant shutdown.
Develop the Restart Action Plan.
Review the licensee's corrective action or improvement program and ensure that it addresses identified problems and weaknesses.
Maintair ongoing overview of licensee performance throughout the corrective action prncess to include periodic meetings among members of the Panel.
Conduct periodic meetings with the licensee to discuss progress toward satisfactory completion of the program. Meetings with the licensee may be held near the facility and be open to the public.
Provide oversight of the NRC's followup activities.
Review NRC inspection and assessment plans and findings and licensee performance.
j Identify areas where NRC inspection and technical review are needed.
.. Periodically provide assessment of licensee performance and corrective
+
actions to NRC management.
Based on the satisfactory completion of the licensee's restart program and a favorable assessment of the. readiness of the plant to restart, provide a recommendation to the Regional Administrator and Director of NRR for approval to restart.
Minutes for_each meeting will be the vehicle for communicating Panel decisions,-concerns, and recommendations.
It will be the responsibility of' the Chief, Project Branch C, Division of Reactor Projects, to prepare the meeting minutes for approval by the Panel chairman.
DURATION The Panel will continue until all items are completed or until the Regional Administrator, with the concurrence of the Associate Director for Projects, NRR, determines'its purpose has been served.
6 pe AEG UNITED ST ATES NUCLEAR REGULATORY COMMISSION L'; f j
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' f 611 RY AN PL AZA DRIVE, SUITE 400 M
ARLINGTON, TEXAS 76011-8064
- j j NRC INSPECTION MANUAL ILPB MANUAL CHAPTER 0350 STAFF GUIDELINES FOR RESTART APPROVAL 0350-01 PURPOSE 01.01 To establish guidelines for approving restart of a nuclear power plant after a voluntary or involuntary shutdown as a result of a significant event, complex hardware problem, or serious management deficiency.
01.02 To provide a generic checklist (see Appendix A) of actions from which a plant-specific Restart Action Plan can be developed.
01.03 To provide for a record of major regulatory actions leading to approval j
for restart.
0350-02 OBJECTIVES 02.01 To ensure that NRC's restart review efforts are appropriate to the individual circumstances, are reviewed and approved by the appropriate NRC management levels, and provide objective measures of restart readiness.
02.02 To provide for effective coordination of NRC resources in determining restart readiness.
02.03 To clarify responsibilities for the actions necessary to approve restart.
02.04 To ensure that the Office of Nuclear Reactor Regulation (NRR) and regional management agree on the actions to be taken and provide a unified NRC position, 0350-03 APPLICABILITY This manual chapter shall be followed for those cases in which a power reactor licensee plans to restart the reactor after the reactor has been shut down for one or more of the following reasons:
Serious NRC questions about licensee management effectiveness.
Identification of a complex hardware problem or a degradation of a structure, system, or component to the extent that it may not perform its intended safety function and requires comprehensive NRC evaluation prior to restart.
Issue Date:
09/30/93 0350
A significant event, such as one that fits the characteristics described o
in Inspection Manual Chapter 0325, " Augmented Inspection Team," Section 1
05.02_or a significant operational event that meets the description _in NRC Management Directive 8.3, "NRC Incident Investigation Program."
N o
Possible damage to offsite support syster s such cs offsite power or
. emergency response capability as a result of a natural disaster, explosion, r'iot, or event with similar consequences.
2 This manual chapter applies only when a when a licensee plans to restart a reactor after a plant has been shut down.
The events described above are not f
criteria for directing or requesting that a reactor be shut down.
4 0350-04 RESPONSIBILITIES AND AUTHORITIES 04.01 Director. Office of Nuclear Reactor Regulation. NRR.
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.
7 04.02 R,_eoional Administrator a.
Discusses with the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, the Office of Enforcement j
(0E), and NRR, as appropriate, the need for an order or confirmatory action letter (CAL) specifying the actions required by the licensee to 4
receive NRC approval to restart the plant and the proposed followup plan.
i i
l b.
Decides, in consultation with the NRR Associate Director for Projects, whether this manual chapter applies to a specific reactor restart.
c.
In coordination with the NRR Associate Director for Projects, decides j
whether to establish a Restart Panel consisting of a chairman and other representatives from the regional office, and representatives from NRR and 4
other offices, as appropriate.
d.
In coordination with the cognizant NRR Reactor Projects Assistant Director, develops a written Restart Action Pl an, including a case-specific checklist, to assign responsibilities and schedules for restart actions and interface with the licensee and outside organizations.
Coordinates and implements those actions prescribed in the Restart Action e.
l Plan that have been determined to be the regional office's responsibility.
These include, when appropriate, interactions with State and local agencies and with regional officss of Federal agencies.
i f.
In conjunction with NRR, reviews and determines the acceptability of l
licensee's corrective action program.
i g.
Approves restart of the shutdown plant, following consultation with the E00 and the Director of NRR.
l 04.03 NRR Associate Director for Prpiects 1-I Acts as the focal point for discussions within NRR to establish the appropriate I
followup actions for a plant that has been shut down.
0350 Issue Date:
09/30/93
04.04 NRR Reactor Projects Assistant Director a.
Coordinates participation in followup conference calls and management -
discussions to ensure that the Regional Administrator and the Director of.
NRR, are directly involved, where appropriate, in followup action.
b.
Coordinates and implements actions prescribed in the Restart Action Plan that have been determined to be NRR's responsibility. These include, when applicable, appropriate NRC Office or NRR Division interaction with other Federal agencies (e.g., FEMA, Department of Justice) pursuant to any applicable Memoranda of Understanding.
'0350-05 BACKGROUND AND INITIAL ACTIONS 05.01 Background. A licensed commercial nuclear power plant may be shut down, voluntarily or involuntarily, for a variety of reasons.
When a plant is shut down for reasons stemming from license conditions-or technical specifications, the licensee normally can develop and implement a clearly defined corrective action plan and the plant restarts without special approval from the NRC.
- However, plants occasionally are shut down as a result of safety concerns resulting from a significant event, complex hardware problem, or serious management deficiency.
This manual chapter addresses these latter cases.
The guidelines presented in this chapter ensure that (1) NRR and the regional offices are appropriately involved in restart decisions for significant cases,
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(2) the NRC responds in an appropriate manner with a unified position to the licensees, and (3) restart activities are comprehensive and appropriate to the specific reason for the shutdown.
Restart actions for specific situations may address additional issues or may omit issues discussed below if such issues are determined not to be applicable to the situation.
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05.02 initial Actions.
When NRC staff members believe that a particular j
situation at a shut-down plant involves a significant event, complex hardware problem, or serious management deficiency warranting increased regulatory attention, the situation should be discussed promptly between NRR and the applicable regional office.
The initial discussion is normally between the i
regional office Director of Reactor Projects and the cognizant NRR Director of l
Reactor Projects.
For significant operating events, the Director, Division of i
Operational Support (DORS) also should be included in the discussions.
The j
discussion should include a description of the event or circumstances as well as the actions already taken by the regional office and those proposed for the i
future. The Regional Administrator and the NRR Associate Director for Projects should be informed of the circumstances and significance of the situation to plant safety and operation.
NRC action may include the establishment of an incident investigation team (IIT),
an. augmented inspection team (AIT), or a special inspection team.
Such action could further include, as appropriate, a confirmatory action letter or an order.
All of these specific actions should be conducted in acc~ordance with appropriate j
office policies, procedures, and manual chapters.
l Special circumstances involving a significant, rapidly occurring event may require discussions to be initiated directly at the level of the Regional
. Administrator,-the Director of NRR, or the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research.
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Issue Date:
09/30/93 0350 4
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0350-06 RESTART REVIEW ACTIVITIES 06.01 Restart Panel a.
Membership. For each reactor restart subject to oversight consistent with this manual chapter, the regional administrator, in coordination with the j
t NRR Associate Director for Projects, decides whether to establish a l
Restart Panel.
The regional administrator normally establishes the composition of the panel and its responsibilities in writing. The panel will typically consist of the following individuals or those in similar positions:
j 4
e Director or Deputy Director, Regional Office Division of Reactor Projects (Chairman)
{
e Director, Responsible NRR Project Directorate (Vice Chairman) i e
Responsible Regional Office DRP Branch Chief e
Regional Office DRS and DRSS Branch (or Section) Chief e
Responsible Project Manager, NRR l
e Responsible Senior Resident Inspector i
Members can be added to or removed from the panel, as appropriate, based i
on the specifics of the shutdown and the matters to be evaluated prior to authorization for restart. For long-term plant shutdowns, the panel may vary in composition and size over time depending on the corrective actions i
l being performed.
For short-term or less complex cases, a panel can i
consist of as few as two individuals - one from the regional office and one from NRR.
i l
b.
Responsibilities of the Restart Panel.
Typical responsibilities of the i
Restart Panel are:
i j
1.
Review all available information related to the plant shutdown.
2 l
2.
Develop the Restart Action Plan.
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3.
Review the licensee's corrective action or 1mprovement program and ensure that it addresses identified problems and weaknesses.
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4.
Maintain an ongoing overview of licensee performance throughout the corrective action process to include periodic meetings among members of the panel.
5.
Conduct periodic meetings with the licensee to discuss progress toward satisfactory completion of the program.
Depending upon the reason for the reactor shutdown, meetings with the licensee may be held near the facility and be open to the public.
(See Section 07.04.)
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6.
Provide oversight of the NRC's followup activities.
Review NRC j
inspection and assessment plans and findings, and licensee perfor-mance. Identify areas where NRC inspection and technical review are needed.
1 0350 Issue Date:
09/30/93
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7.
Periodically provide assessment of licensee performance and corrective actions to NRC management.
8.
Based on the satisfactory completion of the licensee's restart program, provide a recommendation to the regional administrator and Director of NRR for approval to restart.
06.02 Restart Action Plan. Appendix A contains guidelines for the development of a case-specific restart checklist. The appendix should be used as a starting point to develop the detailed list of actions and issues that should be considered prior to approving restart of the reactor.
The case-specific checklist should be incorporated into the restart action plan.
The restart action plan should include all expected NRC actions that will be I
required to be taken before a plant is approved to restart, including those ac-tions not directly related to the initiating event. The plan also should define:
(a) what must be accomplished by the NRC, as a minimum, to approve plant restart, (b) what issues are to be resolved before restart (i.e. restart issues), (c) who has lead responsibility for each action, and (d) who has responsibility for actual plant restart approval. The plan should establish a process for tracking the status of restart issues and for referencing documentation associated with the resolution of the restart issues.
The Regional Administrator, in coordination with the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, and Director of NRR, normally has the authority to approve restart.
In some instances, Commission approval may be required for restart of the plant. Lead responsibili-ty for interactions with the Commission, ACRS, media, Federal agencies and other public officials also should be established. Typically, NRR will take the lead i
in interactions with the Commission, ACRS, headquarters offices of Federal agencies, and Congress and the regional office will typically deal with the local media and State and local of ficials and regional offices of Federal agencies.
0350-07 GUIDANCE 07.01 Coordination of Followup Actions.
The focal point for working level discussions within the NRC for followup actions will be the appropriate projects division director in the regional office and the NRR Reactor Projects Assistant Director.
They will coordinate participation in conference calls, the Restart Panel, and other management discussions to ensure that the Regional Administrator and the Director of NRR are directly involved, where appropriate, in important decisions.
The project divisions will coordinate and implement the actions prescribed in the restart action plan.
07.02 Commission Involvement. The Commission must be kept adequately informed of the staff's restart actions on a continuing basis.
NRR will inform the Commission of the staff's and licensee's restart actions through Commission papers, EDO highlights, or communications to the EDO.
Based on these interac-tions between the staff and the Commission, the need for Commission briefings will be determined by the circumstances and the Commission's wishes.
For those plants requiring Commission approval for restart, the staff should anticipate Commission briefings with licensee participation (1) after a correctivo plan is agreed to and (2) about a month before plant resta"t is anticipated. At the final briefing, the NRC staff should provide its basis for recommending or not recommending restart. The Commission may express its views Issue Date:
09/30/93 0350
concerning restart at.any time during the process.
A formal _ vote after the restart briefing may. or may not be required.
07.03 Independent Review. The Advisory Committee on Reactor Safeguards (ACRS) may review the restart of plants to independently review the NRC's and the utility's actions.
ACRS will normally review the restart of plants that have been shut down for more than a year because of substantive deficiencies in equipment, systems, or management.
If a plant has been shut down for less than a year, ACRS will consider whether or not to review restart issues of the plant on a case-by-case basis.
The NRR staff will keep ACRS informed of the NRC's actions involving plants shut down for more than a year and will coordinate briefings of the ACRS.
t
_07.04 Public Participation. The need for public participation varies greatly from situation to situation and depends on the cause of the shutdown of the facility, local citizen interest, elected official interest, and other government i
agency concerns.. Public meetings have proven to be a valuable vehicle for public participation in the restart process.
These meetings, which are often transcribed, are held to receive comments on licensee plans and to describe the results of the NRC review of licensee activities.
The need for and level of i
public participation will be determined by NRC management on a case-by-case basis j
and will be incorporated into the actions necessary for restart. Public meetings
'in the local area should be considered to hear concerns and comments on the licensee's restart activities and to factor these concerns and comments into the 1
restart review when these concerns and comments will contribute positively to the review.
07.05 Other Agencies and Government Organizations.
The decision to restart should consider tile need for involvement of staff from other Federal agencies such as the Federal Emergency Management Agency (FEMA), and the Department of t
{
Justice, and State and local government representatives. Briefings with elected officials and observations of NRC inspections by State representatives have been an effective way of enhancing NRC communication regarding problem plants.
i 0350-08 RECORDS 1
I It is important that the restart process be documented. The licensee and the NRC staff must understand the reasons for plant shutdown and the necessary actions to be completed before restart.
In addition, information related to NRC and licensee actions, as well as acceptance criteria and confirmatory actions by other agencies and government organizations, must be made available to the 4
public. As a minimum, the record developed for the shutdown and restart process consists of the following:
a a.
Preliminary Notifications, Commission Information Papers, and other i
documents describing the nature of the problem.
l b.
Confirmatory Action Letter (CAL) or Order issued to the licensee j
specifying the actions to be taken, c.
Establishment of the Restart Panel and tt specific Restart Action Plan.
d.
Interim progress reports (e.g., Commission Paper).
j e.
Minutes _ of meetings of the Restart Panel and of meetings of NRC and L
licensee representatives to discuss the licensee's progress :n taking necessary actions.
t 0350 Issue Date:
09/30/93 4
r
f.
Inspection reports and related correspondence.
g.
Safety evaluations.
h.
Other agency and government actions communicated to NRC.
i.
Documentation that describes the resolution of restart issues.
J.
Written determination that restart is approved.
All documents relating to the restart process are to be included in the docket file and, to the extent permitted by 10 CFR 2.790, made public in accordance with NRC policy.
0350-09 REFERENCES Memorandum of November 23, 1988, from V. Stello, Jr., to office directors and regional administrators entitled " Staff Guidelines Concerning Plant Restart Approval" (DCS microfiche 47707/220).
Memorandum of August 17, 1989, from R. Fraley to J. Taylor, entitled, " Proposed Plant Restart:
Nine Mile Point Unit 1"'(DCS microfiche 70006/326)
END Appendix A.
Generic Restart Checklist 1
Issue Date:
09/30/93 0350 i
'4 APPENDIX A GENERIC RESTART CHECKLIST A.
GENERAL,...............................
1 I
A.1 PURPOSE A.2 OBJECTIVES............................
1 A.3 BACKGROUND............................
1 A.4 ACTIVITIES............................
1 B.
PROCESS................................
3 3
B.1 INITIAL NRC RESPONSE:
4 B.2 NOTIFICATIONS:..........................
B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS:
5 5
B.4 REVIEW IMPLEMENTATION:......................
8 B.5 RESTART AUTHORIZATION:......................
B.6 RESTART AUTHORIZATION NOTIFICATION:
9 10 C.
ISSUES C.1 ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION:
10 C.2 ASSESSMENT OF LICENSEE MANAGEMENT:
12 C.3 ASSESSMENT OF PLANT AND CORPORATE STAFF:
14 C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT:
17 2
C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS:
18 C.6 COORDINATION WITH INTERESTED AGENCIES / PARTIES:
19 i
4 4
Issue Date:
09/30/93 i
0350, Appendix A
s A.~
GENERAL A.1 PURPOSE To provide a basis to plan and coordinate NRC review activities for nuclear power plant restart following.a shutdown _for one or more of the reasons provided in
.Section 0350-03 of this manual chapter.
A.2 OBJECTIVES
.To ensure that NRC review efforts are consistently developed and implemented, j
specific guidance is provided to support:
a.
Determining restart issues for review, b.
Identification of the basic tasks needed to review and approve a plant restart,-
c.
Coordination and tracking of restart review activities.
A.3 BACKGROUND The implementation of this appendix assumes that there has been a nuclear power plant shutdown that merits a comprehensive NRC review of the restart process.
The plant is assumed to be in a safe shutdown condition and measures are in place to physically maintain the plant in a safe shutdown condition.
Section B, " PROCESS," of this appendix provides generic tasks that support the Restart Action Plan described in paragraph 6.02 of this manual chapter.
Section C, " ISSUES, of this appendix contains potential issues for consideration during the Restart Review Activities described in this manual chapter.
A4 ACTIVITIES 3
a.
Develop Case-Specific Checklist. The generic checklists in this appendix should be used as a basis to develop a Case-Specific Checklist (CSC) that
~
outlines the NRC review of a comme'rcial nuclear power plant restart. This i
CSC should be developed as soon as practicable after a comprehensive restart review is deemed necessary.
The CSC should become part of the Restart Action Plan and be used by a Restart Panel to coordinate actions.
CSC development should contain the following elements:
(1)
Review section B " PROCESS," and select the applicable tasks needed to support the restart review. The applicable tasks should be selected based on the known facts specific.to the situation.
If needed, add tasks not
. included in section B.
From this review, develop a specific task list.
(2). Review section C " ISSUES," and select the issues that need inspection or verification.
The applicable items should be selected based on the i
specific situation.
Add items not included in section C if required.
From this review, develop a specific issue list.
g issue Date: 09/30/93 A-1 0350, Appendix A
i (3)
Items (1) and (2) above form the CSC.
The Restart Panel should assign l
responsibility and a schedule for CSC item completion. Previously planned I
inspections included on the Maste'r Inspection Plan (MIP) may satisfy the required verificctions and inspections and should be factored into the process.
Note: Inspection time required to assess or verify licensee activities should be charged against the respective inspection procedure.
CSC planning and maintenance time should be charged against a TAC Number for the Restart Action Plan.
(4)
The CSC should be incorporated into the Restart Action Plan.
b.
CSC Maintenance.
The Restart Panel should maintain and periodically review the CSC at a frequency consistent with the needs of Restart Panel and the anticipated restart schedule. 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 of this appendix should be reviewed when significant milestones are completed and prior to restart authorization to ensure any emerging items are considered.
c.
Issue Tracking.
The CSC may be used, as shown in the example below, to track the status of NRC actions, track the resolution of restart issues, and provide a central point to reference documentation associated with the resolution of restart issues.
EXAMPLE:
ISSUE RESP.0RG.
DATE CLOSED 1.
CAL items 2 and 6 complete Restart 9/30/XX Pnl, NRR 2.
Service Water bio-fouling problems resolved Region 11/1/XX 3.
FEMA issues finding that offsite Emergency NRR 9/29/XX Preparedness is satisfactory R ference/Information Item No.
J 1.
CAL items 2 and 6 - Letter from XYZ Co. to NRC 9/15/XX; letter from NRC to XYZ Co. 9/30/XX 2.
Report No. 50-888-XX-23 3.
Letter from FEMA to NRC 9/29/XX d.
Following the completion of the restart process, the CSC should be closed out in accordance with the restart action plan.
0350, Appendix A A-2 Issue Date:
09/30/93
1 c
B.
PROCESS 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' menu format. Only applicable tasks should be selected for incorporation into the CSC.
The short discussion before each major process step provides insight into the intended 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.
Where possible within the tables, the lead responsible organization is given in parenthesis next to the task.
Where an NRC action responsibility is not indicated, the Restart Panel will determine responsibility. The tables provide a column to mark applicability for the CSC.
B.1 INITIAL NRC RESPONSE:
i Establishment of the facts, the causes, and.their apparent impacts should be accomplished 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. Many of these items may already be complete when the initial checklist review is performed.
Refer to section 5.02 of this manual chapter for additional information.
TASK APPLICABLE a.
Initial notification and NRC management discussion of known facts and issues (Region) b.
Identify / implement additional inspections (i.e. AIT, IIT, or Special) (Region) c.
Determine need for formal regulatory response (i.e.
Order or CAL) d.
Determine need for senior management involvement e.
Identify other parties involved i.e. NRC Organizations, other Federal agencies, industry organizations
[
t Issue Date:
09/30/93 A-3 0350, Appendix A i
l
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 APPLICABLE a.
Issue D=.ily and Directors Highlight (NRR) b.
Issue PN (Region) c.
Conduct Commissioner Assistants' Briefing d.
Issue Commission Paper (NRR) e.
Cognizant Federal agencies notified (i.e. FEMA, EPA, D0J, DOL) f.
State and Local Officials notified (Region) 9 Congressional notification (NRR) d 0350, Appendix A A-4 Issue Date:
09/30/93
4 B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS:
I I
It will 'be.necessary.to establish and organize the NRC restart review to ensure j
the effective coordination of resources in evaluating the restart process.
Effective interfaces within and outside the NRC are critical to properly identify
.and resolve the pertinent issues.
Consider both regional and headquarters offices of cognizant Federal agencies. Refer to sections 6 and 7 of this manual l
chapter for additional information.
TASK APPLICABLE i
a.
Establish the Restart Panel i
b.
Assess available information (i.e. inspection results, licensee self-assessments, industry reviews)
Obtain input from involved parties both within NRC and l
c.
other Federal agencies such as FEMA, EPA, D0J, D0L l
d.
Conduct Regional Administrator Briefing (Region)
Conduct NRR Executive Team Briefing (NRR) e.
f.
Develop the Case Specific Checklist (CSC) j L
g.
Develop the Restart Action Plan l
h.
Regional Administrator approves Restart Action Plan J
i i.
NRR Associate Director and/or NRR Director approves Re-start Action Plan J.
Implement Restart Action Plan n
\\
k.
Modify CAL / Order as necessary i
B.4 REVIEW IMPLEMENTATION:
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 and which can be deferred to some later date as long-term corrective actions. The discussions and issues provided in section C of this appendix provide additional information to support the review activities described below.
1 1ssue Date:
09/30/93 A-5 0350, Appendix A
i B.4.1 Root Causes and Corrective Actions:
TASK APPLICABLE a.
Evaluate findings of AIT, IIT, or Special Team Inspection b.
Licensee performs root cause analysis and develops correc-tive action plan for root causes c.
NRC evaluates licensee's root cause determination and corrective action plan i
B.4.2 Assessment of Equipment Damage:
1 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 internal event.
The need for independent NRC assessment i
should be considered. The licensee will need to determine corrective actions to repair, test, inspect, and/or analyze affected systems and equipment.
These actions are required to restore or verify that the equipment will perform to design requirements.
Equipment modifications may also be required to assure performance to design requirements.
Consider potential offsite emergency response impact for external events such as natural disasters, explosions, cr riots. NRR should obtain information from FEMA headquarters reaffirming the adequacy of state and local offsite emergency plans and preparedness if an event raises reasonable doubts about emergency response capability.
TASK APPLICABLE a.
Licensee assesses damage to systems and components b.
NRC evaluates licensee damage assessment i
c.
Licensee determines corrective actions d.
NRC evaluates corrective actions I
0350, Appendix A A-6 Issue Date:
09/30/93
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 steps to determine the restart ~ issues and NRC's evaluation of their resolution.
TASK' APPLICABLE a.
Review / evaluate licensee generated restart issues b.
Independent NRC identification of restart issues-(consider sources external to NRC and licensee) c.
NRC/ licensee agreement on restart issues d.
Evaluate licensee's restart issues implementation process e.
Evaluate' licensee's implementation verification process 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.
l TASK APPLICABLE a.
Obtain public comments b.
Obtain comments from State and Local Officials (Region) c.
Obtain comments from applicable Federal agencies
)
1 i
Issue Date:
09/30/93 A-7 0350, Appendix A
i 1
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 i
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 APPLICABLE a.
Evaluate licensee's restart readiness self-assessment (Region) b.
NRC evaluation of applicable items from section C " ISSUES" complete c.
Restart issues closed d.
Conduct NRC Restart Readiness Team Inspection (Region) j e.
Issue Augmented Restart Coverage Inspection Plan (Region)
]
f.
Comments from other parties considered 9
Determine that all conditions of_the Order / CAL are satis-j fied i
h.
Re-review of Generic Restart Checklist complete 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 think broadly and ask: "Are all actions substantially complete? Have we overlooked any items?"
TASK APPLICABLE a.
Prepare restart authorization document and basis for restart (Region) b.
NRC Restart Panel approves Restart Authorization 0350, Appendix A A-8 Issue Date:
09/30/93
B.5 RESTART AUTHORIZATION: (Continued)
TASK APPLICABLE c.
No restart objections from other applicable HQ offices d.
No restart objections from applicable Federal agencies e.
Regional Administrator concurs in Restart Authorization f.
NRR Associate Director and/or NRR Director Concurs in Restart Authorization (NRR) g.
EDO concurs in Restart Authorization h.
Conduct ACRS briefing / notification (NRR) i i.
Conduct Commission briefing / notification (NRR) j.
Commission concurs in Restart Authorization k.
Regional Administrator authorizes restart 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 APPLICABLE a.
Commission (NRR) b.
ED0 (NRR) c.
Congressional Affairs (NRR) d.
Applicable Federal agencies (NRR) f.
Public Affairs (Region) 9 State and Local Officials (Region)
)
l Issue Date:
09/30/93 A-9 0350, Appendix A
s C.
ISSUES Restart review actions for specific situations may address additional issues or may omit issues discussed below if such issues - are determined not to be applicable to the situation.
The following tables contain menus of items for consideration by the restart panel'during the restart review.
These items are based on issues found during other restart reviews. The experience is primarily based on plant shutdowns due to management deficiencies, hardware issues, or a combination. External events such as natural disasters, explosions, or riots may require development of a unique set of specific issues. A column is provided to mark whether or not an item is applicable.
C.1
-ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION:
The root cause(s) of the event or the conditions requiring the shutdown should 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 problems. The NRC shall review the licensee's corrective action plan to verify its completeness and adequacy and to determine which corrective actions will be required to be implemented before restart and which can be deferred to some later date as long-term corrective actions.
The NRC staff will review the licensee's corrective action activities and use the tools available in the regulatory program to determine the acceptability of these
' actions with respect to safe operations.
These tools 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 enforcement documents.
0350, Appendix A A-10 Issue Date:
09/30/93
C.l.1 ROOT CAUSE ASSESSMENT:
ISSUES APPLICABLE 1.
Conditions requiring the shutdown are clearly undersEod 2.
Root causes of the conditions requiring the shutdown are clearly understood
- cu T-c 3.
Root causes of other significant problems are clearly understood Nk z - c.:.
4.
Evaluate adequacy of the root caus* analysis programxx_a C. l.2 DAMAGE ASSESSMENT:
ISSUES APPLICABLE 1.
Damage assessment was thorough and comprehensive Nk 2.
Corrective actions clearly restored systems and equipment or verified they can perform as designed Nk C.l.3 CORRECTIVE ACTIONS:
1 ISSUES APPLICABLE 1.
Evaluate adequacy of the comprehensive corrective action plan w4 1_. g 2.
Evaluate adequacy of the corrective action programs for specific root causes 5,--ref t3 I - y. t 3.
Assess control of corrective action item tracking ntN tv:
4.
Effective corrective actions for the conditions requiring the shutdown have been implemented t~ %
r-g 5.
Effective corrective actions for other significant prob-lems have been implemented Nk 6.
Adequacy of the corrective action verification processzv.m
.-4 Issue Date:
09/30/93 A-ll 0350, Appendix A
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 ensure the issue is resolved.
Senior -licensee management involvement in self-assessment is treated-separately.
ISSUES APPLICABLE 1.
Effectiveness of Quality Assurance Program 13l, x.
2.
Adequacy of Industry Experience Review Program
- IE 3.
Adequacy of licensee's Independent Review Groups 'T0f 4.
Adequacy of deficiency reporting system i \\/][, ki 5.
Staff willingness to' raise concerns 52T. }
6.
Effectiveness of PRA usage hdek 7.
Adequacy of Commitment Tracking Program
-Im> t9 1-C 8.
External audit (i.e. INP0) capability bd f(
9.
Quality of 10 CFR 50.72 and 50.73 Reports
-nom. D 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 veri fy their effectiveness; (4) possess an independent 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.
i 8
0350, Appendix A A-12 Issue Date:
09/30/93
+,
C.2.1 Management Oversight and Effectiveness:
ISSUES APPLICABLE 1.
Management commitment to achieving improved performance 2.
Performance goals / expectations developed for the staff 3.
Goals / expectations communicated to the staff 4.
Resources available to management to achieve goals 5.
Qualification and training of management 6.
Management's commitment to procedure adherence 7.
Management involvement in self-assessment and independent self-assessment capability 8.
Effectiveness of management review committees 9.
Effectiveness of internal management meetings
- 10. Management in-plant time
- 11. Management's awareness of day-to-day operational concerns
- 12. Ability to identify and prioritize significant issues
- 13. Ability to coordinate resolution 6f significant issues
- 14. Ability to implement effective corrective actions i
1 5
l 1
l Issue Date: 09/30/93.
A-13 0350, Appendix A i
l
s e
C.2.2 Management Organization and Support:
ISSUES APPLICABLE 1.
Structure of the organization 2.
Ability to adequately staff the organization 3.
Effect of any management reorganization 4.
Establishment of proper work environment 5.
Ability to foster teamwork among the staff 6.
Ability to resolve employee concerns 7.
Ability to provide engineering support 8.
Adequacy of plant administrative procedures 9.
Information exchange with other utilities
- 10. Participation in industry groups
- 11. Ability to function in the Emergency Response Organization
- 12. Coordination with offsite emergency planning officials C.3 ASSESSMENT OF PLANT AND CORPORATE STAFF:
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).
0350, Appendix A A-14 Issue Date:
09/30/93
\\
C.3.1 Assessment of Staff:
j ISSUES APPLICABLE 1.
Staff commitment to achieving improved performance 2.
Staff's safety consciousness 3.
Understanding of management's expectations / goals 4.
Understanding of plant issues and corrective actions 5.
Morale
_6.
Staff (union)/ management relationship l.
Structure of the organization 8.
Effect on the staff of any reorganization 9.
Resources available to the staff
- 10. Qualifications and training of the staff
- 11. Staff's work environment
- 12. Staff's fitness for duty
- 13. Attentiveness to duty
- 14. Level of attention to detail
- 15. Adequacy of staffing
]
- 16. Off-hour plant staf fing
- 17. Rotation schedule for shift workers
- 18. Staff overtime usage 1
4
- 19. Amount of contractor usage i
- 20. Staff / contractor relationship i
- 21. Understanding of the allegation process and protection of workers who communicate with the NRC J
- 22. Procedure usage / adherence
- 23. Awareness of plant security
- 24. Understanding of offsite emergency planning issues i
Issue Date:
09/30/93 A-15 0350, Appendix A
4 L*.
},#
1 C.3.2 Assessment of Corporate Support:
i ISSUES APPLICABLE 1
2 1.
Relationship between corporate and the plant staff 2.
Adequacy of the request for corporate services process i
3.
Corporate understanding of plant issues 4.
Corporate staff in plant time 5.
Effectiveness of the corporate / plant interface meetings i
6.
Adequacy of' corporate representation at plant activities a
7.
Adequacy of corporate engineering support 5
8.
Adequacy of corporate design changes 9.
Adequacy of licensing support
- 10. Coordination with offsite emergency planning officials i,
C.3.3 Operator Issues:
i-ISSUES APPLICABLE j
1.
Licensed operator staffing meets requirements and licensee goals i:
2.
Level of formality in the control room i
3.
Adequacy of control room simulator training i
i 4.
Control room / plant operator awareness of equipment status l
5.
Adequacy of plant operating procedures
{
6.
Procedure usage / adherence l
7.
Log keeping practices i
{
a i
i 0350, Appendix A A-16 Issue Date:
09/30/93 j
l
)
s-
^
L
. v
_4 4-C.4 ASSESSMENT OF PHYSICALLREADINESS 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 readine.ss.
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.
ISSUES APPLICABLE 1.
Operability of technical specifications systems 4
2.
Operability of required secondary and support systems j
l 3.
Results of pre-startup testing j
4.
Adequacy of system lineups 5.
Adequacy of surveillance tests / test program Issue Date:
09/30/93 A-17 0350, Appendix A
s a 4
o C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT:
(Continued)
ISSUES APPLICABLE 6.
Significant hardware issues resolved (i.e. damaged equip-ment, equipment ageing, modifications) 7.
Adequacy of the power ascension testing program 8.
Adequacy of plant maintenance program effectiveness 9.
Maintenance backlog managed and impact on operation as-sessed
- 10. Adequacy of plant housekeeping and equipment storage
- 11. Adequacy of onsite and offsite emergency preparedness C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS:
The plant and its prospective operation must not be in conflict with any applicable regulations or requirements of any document authorizing restart (such as license amendments, orders, or a CAL).
Restart should not conflict with any ongoing matter such as an Atomic Safety and Licensing Board hearing.
ISSUES APPLICABLE i
1.
Applicable license amendments have been issued 2.
Applicable exemptions have been granted 3.
Applicable reliefs have been granted 4.
Imposed Orders have been modified / rescinded 5.
Confirmatory Action Letter conditions have been satisfied 6.
Significant enforcement issues have been resolved 7.
Allegations have been appropriately addressed 8.
10 CFR 2.206 Petitions have been appropriately addressed 9.
Atomic Safety and Licensing Board hearings have been com-h pleted i
i l
0350, Appendix A A-18 Issue Date:
09/30/93 l
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C.6 COORDINATION WITH INTERESTED AGENCIES / PARTIES:
Coordination with other interested parties and agencies is 4 oortant to ensure that concerns and requirements of these organizations are factored into the restart authorization.
ORGANIZATION APPLICABLE 1.
Federal Emergency Management Agency 2.
Environmental Protection Agency 3
Department of Justice 4.
Department of Labor 5.
Appropriate State and Local Officials 6.
Appropriate Public Interest Groups 7.
Local News Media END
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Issue Date:
09/30/93 A-19 0350, Appendix A 1
el-a-1ses e3:4% ~ ~rrJ67 ' us e x e ie i a is To 1-817-860-82?8 P,01 4
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r o son ese Nebraska Public Power District caMan'Ma
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evva.neep NW Nwker j
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Mr. Ralph 13cette 1
Ino6tute of Nuclear Power Operations 700 Galleria Parkway j
Attente, Coorgia 30330-5057 Deer Mr. Beetle:
4 Enclosed is Revision 3 of the Phase 1 Plan (issued on November 9,1994) and Revision 0 of the Reetart Readiness Program (issued on November 8,1994.) The Restart Readiness i
Program providen the transition from the Ph*8e 1 Plan to the Power Ascension Plan. As you will note, this plan includes those items identified as requiring resolution prior to restart and was provided to the NRC during our November 8,1994 Public Meeting to discuss restart leeues 1 am happy to say that the NRC's restart list and the District's startup list compare envorable.
N District is also in the process of developing our Phase 11 (items requiring resolution ismenediately after startup) and Phase Ill Plan (long term) and expect to issue them soon.
You will siso be provided a copy of these plans as soon as they are available.
Ralph, as you can see, we are being very conservative in ensuring that we are addressing iseuce in the order of their importanca. In addition, we are adding issues as they are identified during our investigation of the root causes of DSAT, DET and NPG management Andings. We believe the District has taken the initiative and are currently finding and Asdag, for the hmg term, our own problems. Yuur support in helping us get to this point was e(great value and is greatly apprecia ted.
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R. W. Watkins i
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Richard L.
Sama, Assistant Oirector 1'
' State Civil Defense Agency 1300 Military Road Lincoln, Nebraska 68508-1090 1
j Deer Mr. Samm:
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SUBJECT:
Deficiency observed at the Novanner 16,
- 1994, i
Cooper Nuclear Stat on Exercise
Response
Due:
ecember 5, 1994 i
l The purpose of this lettar :. s to officially inform you of the i
Deficiency identified during -he emergency phase of the Novanner i
16, 1994, exercise of the state and local radiological emergency response plans for the Cooper Nuclear Station.
This Deficiency is being assessed against the Nebraska Field Command Post /
j Information Authentication Center.
Field C_
==d Post /Information Auth==tiention center 1.
1.
obiective nemmar 11, the capability to coordinate the for=ulation and disseminat:.on of accurate information and instructions to the pumlic, was or ne4 -
atelv d.;.z a n - E i a t e d resulting in a Deficiency.
Specifically, the following concerns i
were identified with the issuance of Emergency Broadcast System j
(EBS) messages:
(NUREG-0654, E.7) l-The EBS messages prepared by the state following the i
protective action decision to evacuate were not provided to the public in a timely manner.
The protective action decision to evacuate areas 1, 2,
3, and 4 was made at 0921.
This information vos pruvided 4
to the state ECC at 0925.
However, the EBS station I
was not contacted until 0950 and the complete informa-
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tion to the public required t-' effect this evacuation i
was not broadcast until 1007.
This was a delay of 46 minutes before the commlete instructions were provided to the public regarding the evacuation process.
i The state ECC did not combine critical information, concerning the evacuation of subareas 1, 2,
3, and 4, into one message in accordance with the Annex G of the state plan.
Instead of one EBS message, the state ECC generated fcur secarate cessages to provide this inf or=ation to th e public.
Message number 1, broad-i Attachment
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remeoial act:,.ons', incluaing' remeci~al exercises, driTls, anc other
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act'onS.
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cast at 0954, provided the protective action decision to evacuate and the appropriate landmark dascriptions of the affected areas.
Messages number 2 and 3,
broadcast at 1000, indicated the locations of the reception centers for evacuees and provided specific evacuation instructions to assist the evacuees.
Message nummer 4,
broadcast at 1007, provided the evacuation routes to the reception conte.rs.
Issuing this information as four separate messages, instead of one, would be confusing to the public.
Providing a protective action dec:.sion to evacuate and the de-scription of ne affected areas, without immediately providing the evacuation rcutes to utilize or the location of the reception centers, could result in evacuees using reacs that might lead them into the J
path of the plu=e and ceuld also result in evacuees not reporting :: the reception centers Oc be =eni-tored.
i Remedr.a1 action will recu:.re su =:.ssien et a plan a=endment Oc clearly incicate that cr:.::.cai :.nf cr=ation concerning protective actions (areas affecrec.
'anc:arxs, evacuation
- routes, anc i
reception contars) vill re providec concurrently to the public.
: :.s recc== ended that the as messages be mocified in the manner that was accomplishec f er the For Calhoun Nuclear Station plans.
- n addit:,on := the plan amenc=ent, a remecial exercise must be c=nducted to demonstra:2 =c;ect:.ve nummer 1
- .n accordance wi n the modified plan.
- n accordance with 44 CFR 250.9(d; and the TEMA Radio 1cgical E=crgency Prepareaness Ixere:.se Manual (FEMA-REP-14), Septancer 1991, a Defic 10ncy :. s det.ned as a demonstrated and observec inadecuacy of organisat:.onal performance in an exercise that sculd cause a fincing that Of f site emergency preparedness is not accouate provide reasonacle assurance that appropriate protective measures can
=e taxen ;.n the event of a radiological e=ergenc'/ te pr:tect the nea.:n anc safety of the public living in the vicinit*/ of a nuclear power plant.
Because of the octential impact of Cer:. :. enc:.es on emergency preparedness, they a' r e recuirec to be premptly
- rrectec through appropriate remoclai act:.ons, including remecial exercises, drills, and other actionG.
Based on the above, remecial act:.:n =ust be completed by Maren 1G. 1995.
Please provice Onis Office with a projected date for the completion of the reneolai acti:n. :: include the remedial exercise. by Cecomter 5, 1994 I
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If you have any questions, please contact Robert Bissell at (816) 283-7004.
sincerely,
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Ak. A :f,'.In >//
John A. Miller Regional Director i
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KatAryn Cole, FEMA HQ Charles Hackney NRC IV i
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i CNS RESTART PANEL MEETING NOTES - DECEMBER 5. 1994 ATTENDEES
- A. Beach, Panel Chairman and Director, Division of Reactor Projects (DRP)
- T. Gwynn, Director, Division of Reactor Safety (DRS)
A. Howell, Technical Assistant to the Regional Administrator
- W. Beckner, Panel Vice Chairman and Director, PDIV-1, Office of Nuclear Reactor Regulation (NRR)
- R. Hall, Project Manager, NRR
- P. Harrell, Chief, Project Branch C, DRP
- R. Kopriva, Senior Resident Inspector, DRP
- T. Reis, Project Engineer, Project Branch C, DRP E. Collins, Team Leader, DRS P. Narbut, NRR C. Hackney, Regional State Liaison Officer G. Sanborn, Enforcement Officer R, Wise, Allegations Coordinator L. Ricketson, Inspector, facilities Inspection Program Branch, Division of Radiation Safety and Safeguards
- D. Freeman, Recorder, DRP
- Panel Members ALLEGATIONS Four open allegations for the CNS were discussed.
None were identified as startup issues.
SET FINDINGS The SET identified five possible escalated enforcement issues. An enforcement panel will be held (likely later this week) to address these and determination will be made as to whether they will be included on the Case-Specific Checklist.
Terry Reis was tasked with scheduling this meeting.
After the panel meeting, any items identified for escalated enforcement will become restart issues.
PROCESS The team inspection is to begin on January 9,1995, will be known as the Cooper Restart Team or CRT.
Elmo Collins will lead the team.
Paul Narbut will be a member of the team.
Other members have not been selected.
There will be four licensee meetings open to the public on December 15 and 29 and January 12 and 26.
A major factor of the first meeting will be Mr. Mueller of NPPD giving the licensee's status with resolving restart items.
There will'be no Restart Panel meeting before December 15.
January 26, 1995, is.the goal date for giving restart approval.
a.
' DISCUSSION OF THE RESTART ACTION PLAN
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There will beino Commission Paper issued.
Parts I and-II;of the Restart Action Plan Case-Specific Checklists (process and issues) were reviewed and changes adopted.
Panel' members ' acknowledged that the proposed Case-Specific Checklist - Part II does not reflect all of theLelements available from MC 0350 for review..
Specifically, as assessment of the; licensee staff-per Section C of MC 0350 is not included. The checklist was determined to be appropriate to the CNS case.
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