ML20133G348
| ML20133G348 | |
| Person / Time | |
|---|---|
| Issue date: | 02/17/1995 |
| From: | Rathbun D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Boehlert S HOUSE OF REP. |
| Shared Package | |
| ML20133F757 | List: |
| References | |
| FOIA-96-514 NUDOCS 9701160001 | |
| Download: ML20133G348 (1) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 0001 February 17, 1995 4
4 The Honorable Sherwood Boehlert United States House of Representatives Washington, DC 20515
Dear Congressman Boehlert:
This is to acknowledge receipt of your letter dated February 6, 1995, transmitting correspondence from your constituent, Norman Von Wettberg, regarding the Nuclear Regulatory Commission's General Design Criteria.
Please be assured that we are working on a response and a reply will be forwarded to you as soon as possible.
Sincerely, Dennis K.
Rathbun, Director Office of Congressional Affairs 9701160001 970108 PDR FOIA WEISER96-514 PDR
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. NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666-0001 c
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LIhe.Jionorable Sue W. Kelly United States House of Representatives Washington, DC 20515-3219
Dear Congresswoman Kelly:
I am responding to your letter of June 28, 1995, to former Chairman Selin of the U.S. Nuclear Regulatory Commission, in which you expressed concern that every step be taken to ensure the safe operation of Indian Point Nuclear Generating Unit No. 3 (IP3).
You also requested to be kept informed of the facility's progress during the restart.
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As you know, IP3 was shut down by the New York Power Authority (NYPA)-in February 1993, to correct several hardware issues and to implement plant-wide programmatic improvements.
The plant restarted on June 27, 1995. The NRC has undertaken significant inspection and assessment efforts since the February 1993 shutdown to evaluate NYPA's progress in resolving technical concerns and correcting the underlying root causes of the identified deficiencies.
j During the IP3 restart, the NRC implemented an augmented inspection plan to assess NYPA's activities.
In addition to the three full-time resident inspectors assigned to the site, additional inspectors provided around-the-clock coverage for the first phase of the startup and maintained augmented inspection effort for about three weeks.
Curing this time, among other NRC inspection activities, the inspectors reviewed NYPA's self-assessment of safety performance, quality assurance assessments, and support to operations on emergent issues.
The staff reviewed the results of NYPA's self-assessment and on the basis of our independent augmented inspection effort, we agreed with the findings.
NYPA had committed not to increase reactor power above 40 percent until they performed a self-assessment and notified the NRC staff of the results.
By letter dated July 6, 1995, NYPA notified the NRC staff of the results of this sel f-as ses sment.
I have enclosed a copy of this letter for your information.
The staff reviewed NYPA's self-assessment and, on the basis of our independent augmented inspection effort, we agreed with the results. Although our augmented startup inspection effort has ended, I assure you that until IP3 has operated at an improved performance level for a sustained period of time, the NRC staff will continue to oversee this facility at an enhanced level.
NYPA has also committed that, after achieving full-power operation, they will conduct a self-assessment of the restart process and will present the results to the NRC staff in a public meeting.
The meeting will be held in the i
vicinity of the site and open for public observation, to be followed by a s
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e-The Honorable Kelly
- question-and-answer session, allowing the public an -acortunity to discuss issues with the NRC staff in attendance.
Regarding your request to be kept informed of the facility's progress, we would be glad to meet with you to provide any additional information you may need.
j I trust this information addresses your request.
Sincerely, l
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/ fxecutive irector j
V for Operations
Enclosure:
NYPA letter dated j
July 6, 1995 l
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July 6,1995 IPN-95-073 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Indian Point 3 Nuclear Power Plant Docket No.50-28S Self Assessment During Plant Starhr
REFERENCE:
- 1. NYPA letter IPN-95-065, W. J. Cahill, Jr., to NRC, " Readiness to Restart Indian Point 3," dr'ad June 12,1995,
- 2. NRC letter, T. Martin to W. 'J.ahill, Jr., " Restart of the Indian Point 3 Nuclear Power Plant," dated June 19,1995.
Dear Sir:
The New York Power Authority has completed a self-assessment of reactor restart and power ascension to 30% - 40% power at the Indian Point 3 Nuclear Power Plant. This period in the power ascension program provided an opportunity to assess, under operating conditions, performance of plant systems and the effectiveness of plant staff and administrative processes.
The Power Authority committed to provide the self-assessment results to the NRC staff prior to exceeding 40% reactor power (References 1 and 2).
The assessment consisted of system walkdowns by engineering and operations personnel, self-assessments by Department Managers, an evaluation by the Independent Safety Engineering Group (ISEG), and surveillances by the Quality Assurance group.
Assessment results were presented to the Plant Leadership Team (PLT), consisting of senior plant management, for critical review. A description of the self-assessment method and summary of results is provided in Attachment 1.,
The startup evolution following the replacement of the reactor vessel head 0-ring has proceeded smoothly with few emergent issues requiring resolution. Conservative decision-making is evident at all levels in the organization and there is strong management involvement and control of activities. Results of the self-assessment indicate that actions taken to date by the Power Authority to improve performance at Indian Point 3 are effective.
4 Q 7// M gg; Enclosure
l Docket No. 50-286 IPN-95-073 '
Page 2 of 2
'I The Power Authority concludes that plant equipment, personnel and administrative 5
processes at Indian Point 3 can safely support the remaining power ascension activities and.
sustained operation at full power conditions. Additional assessment activities are planned during the balance of the power ascension program and results will be provided to the NRC in a public meeting after achieving full power operation.
There are no new commitments identified in this letter. If you have any questions, j.
please contact me.
4 Very truly yours, y
W.. Cahill, Jr.
Chief Nuclear Officer l
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Mr. Thomas T. Martin Regional Administrator / Region I
. U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 j
l Mr. Curtis J. Cowgill, Chief Reactor Projects Branch No.1 U.S. Nuclear Regulatory Commission Region i 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Nicola F. Conicella, Project Manager i
Project Directorate 11 Division of Reactor Projects 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 U.S. Nuclear Regulatory Commission Resident inspectors' Office Indian Point 3 Nuclear Power Plant P.O. Box 337 Buchanan, NY 10511
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ATTACHMENT I T@ IPN-95 073 SELF-ASSESSMENT OF REACTER RESTART AND POWER ASCENSION TO APPROXIMATELY 30% POWER AT INDIAN POINT 3 NUCLEAR POWER PLANT INTRODUCTION:
The New York Power Authority has completed a self-assessment of reactor restart and power ascension to approximately 30% to 40% power at the Indian Point 3 Nuclear Power Plant.
The assessment covers the period from approximately June 20 to July 5,1995. Plant heatup to normal operating temperature and pressure (following the reactor vessel 0-ring replacement project) was completed on June 19. Steady state operation at the nominal 30%
to 40% power plateau was achieved on July 3. The purpose of this assessment was to provide a systematic approach to evaluating the performance of plant systems, administrative processes, and personnel during this period.
The Power Authority committed to provide the self-assessment results to the NRC prior to increasing reactor power above 40% (References 1 and 2). The following sections describe the method, results and conclusions of the self-assessment.
i SELF-ASSESSMENT METHOD:
The Power Authority prepared a Startup and Power Ascension Plan (Reference 3) which provides the overall structure and sequence for plant startup following the outage that began in 1993. Written guidance for conducting the self-assessment is included in the Plan. The format of this self-assessment models the assessment (i.e., Start Up Readiness Evaluation) which was performed prior to restart to demonstrate the effectiveness of corrective actions implemented at Indian Point 3 (Reference 4). The four elements of the Start Up Readiness Evaluation were:
- 1. System Certification to assure acceptable material condition.
- 2. The Operational Readiness Review consisting of a self assessment by Department Managers.
- 3. The Startup Evaluation for Readiness Team inspection to independently assess plant and organizational readiness, i
- 4. Quality Assurance independent oversight.
Assessment activities during plant startup and power ascension were developed which correspond to each of these fnur elements of the Start Up Readiness Evaluation. This approach provides assurance that the attributes and conclusions which supported the restart decision remain valid as the plant equipment and personnel make the transition from an outage to an operating facility. The startup and' power ascension self assessment consisted of:
- 1. System walkdowns by system engineers and plant operators.
- 2. Self assessments by specified Department Managers.
- 3. An independent review by the Independent Safety Evaluation Group (ISEG) to ensure the operational and functional capability of the plant to support the continuation of the startup sequence.
- 4. Quality Assurance independent oversight.
Dockit No. 50-286 lPN-95-073 Attachment i Page 2 of 5 The assessment also included a data collection effort to provide additional quantitative evidence of performance. Data was collected for selected plant process parameters and for measures of staff and administrative program effectiveness.
All assessment activities, results and conclusions were subjected to critical review by the Plant Leadership Team (PLT) during assessment hold point meetings. The PLT consists of senior on-site management personnel and has an ongoing responsibility to ensure.
management involvement with plant activities and to implement programs which facilitate safe, operation.
System Walkdowns During the course of plant startup, system walkdowns were conducted by system engineers and operations personnel. Walkdowns were performed to provide assurance that the j
material condition established as part of the pre-startup system certification program was being maintained. Equipment performance was observed as the various plant systems were 1-l placed in service. Written guidance covering material condition, housekeeping, and radiological protection where applicable was provided in the startup plan for personnel performing walkdowns.
Department Manager Self-Assessments i
l Self-assessments by selected Department Managers were performed to verify that their respective departments met applicable performance standards during the startup and power I
ascension evolution. Performance standards were defined for approximately twenty subject areas such as operator knowledge, acceptability of procedures, control of work activities, and implementation of management policies. Written guidance in the startup plan provided the l
Department Managers with evaluation attributes and criteria which could be used to determine if specified performance standards were achieved. Department Managers were required to present the results of their self-assessment to the Plant Leadership Team for critical review.
Independent Safety Engineering Group Review The Independent Safety Engineering Group (ISEG) consists of the ISEG Director and a Senior Assessment Engineer at each of the Power Authority's two nuclear plants. The ISEG conducted mterviews, reviewed documents, and observed work-in-progress to evaluate operations, maintenance, and engineering activities. Equipment operation was also observed and related documents were reviewed to assess the physical plant in areas such as thermal expansion and radiological, chemistry, and ambient environmental conditions. The ISEG also performed a review of low power reactor physics test results.
Quality Assurance Oversight The site Quality Assurance department conducted a surveillance of plant performance during the period following senior management approval to restart the reactor to the holdpoint prior to exceeding 30% power. This surveillance provided a broad assessment of plarit and i
1 J
i DockIt No. 50-286 IPN-95-073 Attachment i Page 3 of 5 I
personnel performance with the purpose of determining if Indian Point 3 is ready to operate at full power. The surveillance included results from ongoing QA activities such as an Operations Audit and recently completed QA surveillances. Quality Assurance provided oversight during startup j
and power ascension in the following areas:
Organization and Administration Material condition and housekeeping Test coordination and execution Operations Maintenance instrumentation and controls Technical support Radiation control Chemistry Quality Assurance oversight focused on field observations, during day shift and back shift periods, and included evaluations of communications, management oversight and control, departmental self-assessments, decision making, and procedure adherence.
SELF-ASSESSMENT RESULTS:
i System Walkdowns System walkdowns were performed at various times during startup so that equipment and system performance under changing plant conditions could be observed and to ensure that plant material condition was being maintained. Several minor items were documented as Plant identified Deficiencies (PlDs). There are no remaining open items which prevent continued power ascension or adversely affect safe plant operation.
Additionally, there are approximately 130 Work Requests (WRs) remaining to be completed during the balance of the power ascension program. Many of these work items involve retests of recently completed corrective maintenance activities or require piant conditions above the current power level. Temporary modifications and operator work arounds are periodically reviewed to ensure they are consistent with established guidelines.
Department Manager Self-Assessments Department Managers presented their self-assessment results to the PLT during meetings held on July 3,4, and 5,1995. The self-assessments identified strengths as well as areas for potentialimprovement. There were no weaknesses identified which would prevent their respective organizations from supporting continued power ascension to full power. Areas of future improvement are primarily in the areas of further streamlining of procedures and administrative processes. Plant staff continue to exhibit a positive and questioning attitude in the self-identi6 cation and reporting of problems.
_ _ _ ~ _ _ _ _. _ _ _. _ _ _ _ _ _ _ _. - - _. _
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Dockit No. 50-286 IPN-95-073 j
Attachment I f
Page 4 of 5 i
i
' Independent Safety Engineering Group Review j
The overall conclusion of the ISEG review is that plant operation during the assessment period was conducted safely and activities were performed conservatively. Work activities l
are well planned particularty when a Limiting Condition for Operation (LCO) is involved. The i
plant is responsive to emergent issues with options and consequences being carefully j
evaluated before actions are taken. The ability of ihe organization to anticipate events before they become emergent issues could be improved. Communication within and between i
i departments has significantly improved and additional progress can be made in the handoff of work activities from one group to the next responsible department.
1 i
Quality Assurance Oversight
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Throughout the period of startup and power ascension significant improvement was noted i
compared to previous outages in the management and control of plant activities and material i
i condition. Startup activities are proceeding cautiously and quality is given priority over schedule. Problems are being property documented, brought to management attention, evaluated conservatively and resolved. Management is maintaining good visibility and control of activities prior to each startup milestone. Personnel in all departments are demonstrating good questioning attitudes, attention to' detail, and adherence to procedures. Operations is controlling plant configuration and ensuring compliance with Technical Specifications and j
Operational Specifications. While some weaknesses were identified, the Quality Assurance surveillance did not identify any generic or specific problem area or concem which would I
prevent Indian Point 3 from safely continuing with the sisrtup to full power operation.
i i
CONCLUSION:
The self assessment demonstrated that the improvement initiatives implemented to date by j
the Power Authority are effective in assuring the safe operation of Indian Point 3. There is evidence of strong management involvement and control of activities. Management expectations regarding the importance of nuclear safety have been well communicated, resulting in conservative decision-making at alllevels in the organization. Only one reactor trip occured to date during the startup evolution. The trip was manually initiated and was the result of a conservative approach by plant operators.
4.
Plant systems have performed well during reactor restart and power ascension. Plant staff have proper skills and exhibit good teamwcit in responding to and resolving emergent issues. Administrative programs such as Deviation and Event Reporting (DER) and the Action and Commitment Tracking System (ACTS) provide tools for plant staff to implement an effective corrective action program.
A continuation of self assessment activities is part of the Power Authority's plan for long term imprevements at Indian Point 3. Self-assessment activities are an ongoing administrative tool which provide benefits both for management to identify areas for improvement and for plant 1
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Dockit No. 50-286 IPN-95-073 Attachment l Page 5 of 5 staff to develop a greater understanding of management expectations, including a commitment to resolving concems.
l The Power Authority r:oncludes that plant equipment, personnel and administrative processes at Indian Point 3 can safely support the remaining power ascension activities and sustained operation at full power conditions.
REFERENCES:
1.
NYPA letter IPN-95-065, W. J. Cahill, Jr., to NRC, " Readiness to Restart Indian Point 3," dated June 12,1995.
2.
NRC letter, T. Martin to W. Cahill, Jr., " Restart of the Indian Point 3 Nuc.aar Power Plant," dated June 19,1995.
3.
NYPA Procedure SUP-95-01, "Startup and Power Ascension Procedure."
4.
NYPA letter IPN-95-036, W. J. Cahill to NRC, " Start Up Readiness Evaluation," dated March 16,1995.
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ASSISTANT MAJORITY WHIP June 28,1995 Mr. Ivan Selin Chairman, Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20352
Dear Mr. Selin:
With the restart of the Indian Point 3 nuclear power plant in Westchester County, New York, h
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- I would like to express in the strongest possible terms my concern t at every step e a e ensure the safety of this facility's continued operation.
As you know, equipment and management problems forced the shutdown of the Indian Po facility in 1993. Since that time, the New York Power Authority has revamped the management team at the facility and implemented operational improvements to correct the deficiencies which prompted the shutdown. Based on these improvements, the Nuclear Regulatory Commi approved the Power Authority's plan to restart the facility.
Nuclear energy can play an important role in satisfying our energy needs, but not at the expense of public safety. I have heard from a number of my constituents expressing concerns ove restart of Indian Point 3. Their concerns underscore the primary view that the operational reforms made at the facility must place the highest priority on safety. Anything less is clearly
- unacceptable.
The N clear Regulatory Commission must carefully oversee and monitor the restart of Indian Point 3, and I would like to be kept informed on the facility's progress.
Thank you for your attention in this matter. If I can provide you with additional information on this matter, please do not hesitate to contact me.
Sincerely, ue W. Kelly Member of Congress SWK/syh. cy e m m l va u 3p+
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