ML20154C460
| ML20154C460 | |
| Person / Time | |
|---|---|
| Issue date: | 05/09/1988 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Davis A, Grace J, Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2.206, NUDOCS 8805180181 | |
| Download: ML20154C460 (5) | |
Text
I
- !F[ j j ",7 MEMORANDUM FOR:
William T. Russell, Regional Administrator Region I J. Nelson Grace, Pegional Administrator Region II A. Bert Davis, Regional Administrator Region III Robert D. Martin, Regional Administrator Region IV John B. Martin, Regional Administrator Region V FROM:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation i
SUBJECT:
CRITERIA FOR PERMITTING RESTART A recurring Question in our recent operations has been "What are the Comission's
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criteria for permitting restart of a nuclear power plant after it has been shut down for safety related reasons?" We have dealt with this issue again recently and as a result of that exercise we have developed a generic statement of our criteria. To arrive at the detailed criteria for a specific case one would augment these generic criteria with the specifics of the case.
This subject warrants further discussion in our forthcoming management meeting in June and, accordingly, I am providing these generic criteria for your information.
i
.as Thomas E. Murley, Director Office of Nuclear Reactor Regulation
Enclosure:
Draft Generic Statement j
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MAY 9 1928 MEMORANDUM FOR:
William T. Russell, Regional Administrator Region I J. Nelson Grace, Regional Administrator Region II A. Bert Davis, Regional Administrater Region III Robert D. Martin, Regional Administrator Region IV John B. Martin, Regional Administrator Region V FROM:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation
)
SUBJECT:
CRITERIA FOR PERMITTING RESTART A recurring question in our recent operations has been "What are the Comission's criteria for permitting restart of a nuclear power plant after it has been shut down for safety related reasons?" We have dealt with this issue again recently and as a result of that exercise we have developed a generic statement of our criteria.
To arrive at the detailed criteria for a specific case one would augrrent these generic criteria with the specifics of the case.
This subject warrants further discussion in our forthcoming managerrent meeting in June and, accordingly, I am providing these generic criteria for your j
information.
l l
Thomas E. Murley, irect Office of Nuclear Reac o gulation
Enclosure:
Draft Generic Statement cc:
V. Stello J. Taylor J. Sniezek F. Miraglia J. 1.ieberman
S RESTART CRITERIA Question What are the Commission's standards for Permitting restart of a power plant after it has been shutdown for safety reasons?
Answer Nuclear power plants are shutdown, voluntarily or not, for a variety of reasons. When a plant is shutdown for reasons stemming from technical specific 6tions or license conditions, the licensee can normally implement a clearly defined corrective action plan. When the criteria of this plan are met, the plant may restart without special authorization from NRC.
- However, plants occasionally are in a shutdown condition as a result of a significant event or significant management deficiencies.
These are the types of cases at which this statement is directed.
Examples of this type of shutdown include plants that were shutdown because of performance problems during the past few years; e.g. Sequoyah, Browns Ferry, Rancho Seco, Pilgrim and Peach Pottom.
NRC has reccted to these types of facility shutdowns in a variety of ways depending on the event that led to the shutdown. The NRC has approached each event individually, and an individual plan of action has evolved.
However, in ensuring that the NRC reaches its fundamental goal in each case, namely to ensure that a restart and operation of the plant will carry with it adequate assurance of protection of the public health and safety, the following criteria are applied.
I.
Licensee Restart Plan:
Root Cause Identified and Corrected First, the root cause of the event or conditions requiring the shutdown must be properly identified. Then the root cause and the event or conditions requiring the shutdown must be addressed by a comprehensive corrective action plan which addresses all applicable issues. The plan must carry the issues through their corrective action, implementation and verification phases.
The above actions are taken by the facility licensee.
The NRC reviews and determines the acceptability of these actions to support safe operations using any or all of the tools available to it in the regulatory program. These could include any or all of the following:
a Headquarters staff review, SALP, the inspection program including regular inspections, specialist inspections or team inspections and enforcement conferences.
Resulting actions are set forth in safety evaluations, license amendments, orders, confirmatory action letters, inspection reports, enforcement packages etc. The staff's review includes the applicable areas outlined below.
2-II.
Licensee Management Organization The licensee's management organization is reviewed to ensure that the overall climate and resources are provided to ensure that the problem and its root cause have been rectified. The organization must demonstrate that it can coordinate, integrate and communicate regarding its objectives so that they are appropriately prioritized for safety significance and are achieved in a timely manner.
This requires an appreciation on the part of that management of what the safety issues are coupled with a positive attitude toward ensuring that they are resolved. This in turn requires that personnel with adequate qualifications and experience be provided for all key management positions.
The resulting(organization (a) should exhibit good teamwork among its subelements, b) should provide strong engineering support for plant activities, (c) should have the internal ability to recognize safety problems and to develop adequate corrective actions and to verify their implementation and effectiveness, (d) should have independent self-assessment features which identify situations not sufficiently dealt with by the regular functioning of the principal organization.
III. Operations Staff The operations staff must recognize and carry out their responsibilities in ensuring public health and safety as required of them by their individual licenses as well as by the facility license to operate the plant.
These responsibilities must be met while working within the environment established by the licensee's maragement as discussed above.
This, in turn, requires that an adequate number of formally qualified licensed operators be provided. A positive proactive attitude tnwards safety issues should be demonstrated across the board in all aspects of operations.
In this regard operators should display attentiveness to duty, fitness for duty, a disciplined approach to activities, a sensitivity for trends on what is happening in the plant, security awareness, and an openness of communications and desire for team work which supports effective relations between different groups (e.g., management, operations, health physics, maintenance, security, contractors).
IV.
Physical State of Readiness of the Plant This is of principal importance for those cases where the reason for the shutdown was based on a physical event or deficiency but it is also important for other types of events as well.
For equipment problems the cause should be identified and appropriate corrective actions taken in the manner discussed in (I) above.
These issues will warrant a strong focus on the pre-operational or initial operational testing which verifies that the problem is resolved.
For complex issues this testing program nay also be complex and of an extended duration.
% For other types of problems as well as equipment problems the complete spectrun of pre-operational and startup testing programs may need to be expanded to consider the more complex types of problems or to consider the effects on plants which have been shutdown for extended periods.
The licensee should be able to demonstrate that all needed safety equipment is operational prior to the restart without excessive reliance on the minimum levels of equipment availability permitted by technical specification Limiting Conditions for Operation.
Surveillance tests should also be up to date without excessive reliance on the ninimum level of testing permitted by TS.
The maintenance backlog should be reduced to nominal levels which do not reflect chronic problems with eouipment readiness nor postponement of long unmet needs.
Procedures should be updated and plant staff trained to reflect resolution of the issue at hand as well as any extensive 1cng unmet needs.
For example, these procedures should include those which conflict with other procedures or with the as built plant, procedures which have not undergone their periodic review, or procedures which do not reflect "the way it is really done."
The as built design of the plant should be known to agree with the safety design basis including analyses, drawings, etc.
V.
Other Agencies, Governrent Organizations, the Public The decision to restart should consider the need for formal action prior to restart as well as the value of good relations with other Federal agencies such as FEMA, DOJ, state and local government representatives and interested members of the public.
This would include the need for action such as on the Emergency Plan by FEMA, responses to correspondence to state Governors or members of Congress and responses to 2.206 Petitions.
VI. ' Legal" Requirements Notwithstanding all of the above, the plant and its prospective operation is not known to be in conflict with any regulations (GDC, etc.) and all requirements of any document authorizing restart (license amendments, orders, etc) are expected to be met.
Restart would not conflict with any matter before a Hearing Board.