ML20196A218

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Restart Assessment Plan Millstone Station
ML20196A218
Person / Time
Site: Millstone Dominion icon.png
Issue date: 11/20/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20196A212 List:
References
PROC-981120, NUDOCS 9811270086
Download: ML20196A218 (40)


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RESTART ASSESSMENT PLAN MILLSTONE STATION APPROVED BY:

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r WAYNE D 'LAflNG,'61 RECTOR, MILLSTC INSPECTION DIRECTORATE, REGION 1 lll7,0lff Date:

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MILLSTONE RESTART ASSESSMENT PLAN

1.0 BACKGROUND

1.1 HISTORICAL The three Millstone units shut down to formulate responses to a series of 10 CFR 50.54 (f) letters requiring them to affirm their compliance with the conditions of each unit's license and the regulations. During May-June,1996, the I

NRC performed a series of inspections at Units 2 and 3 with a 20-person Special Inspection Team (SIT) to ascertain the extent of their compliance. The licensee initially focussed on Unit 3 as the lead plant for restart. However, as a result of a l

licensee reorganization which occurred on October 1,1996, each Millstone unit was

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assigned a recovery manager who was an executive on temporary loan from another nuclear utility. Resources originally assigned to Unit 3 from the other units were returned to their respective units. Each unit has been tasked with establishing their own restart plan and whichever unit is ready will apply to restart first. Hence this restart assessment plan has been expanded to include Manual Chapter (MC)-0350 evaluations (see paragraph 3.0) for all three units.

' On June 28,1996, the Executive Director for Operations (EDO) issued a letter to the licensee that stated the Commission had decided to make the three Millstone units a Category 3 on the Watch List and would vote on the restart of the Millstone units. It is the intent to implement the appropriate aspects of NRC Manual Chapter 0350," Staff Guidelines for Restart Approval" for the restart of all three units. The NRC will schedule and implement its inspection program after the licensee has indicated that the individual activities necessary for restart are complete and ready for inspection.

The NRC has been dealing with Northeast Utilities on broader performance issues which go b9 yond the 10 CFR 50.54(f) concerns. These broader concerns are considered contributory causes for the current poor performance, which the 10 CFR 50.54(f) issues are a subset. These issues have been formalized by the licensee in a program titled improving Station Performance" (ISP) and are topics that will be addressed by the licensee and reviewed by the NRC Millstone Restart Assessment Panel. A meeting was conducted on April 30,1996, and disclosed that the licensee was not adequately managing the program or tracking progress.

The salient concerns embodied in the ISP include leadership, communications (employee concerns), the corrective action program, procedural adherence and procedure upgrades, work planning and control, and operational enhancements.

The NRC Restart Assessment Plan will focus on the broader issues of the ISP and licensee self-assessments and management oversight, recognizing the necessity to ensure adequate closure of the 10 CFR 50.54(f) process. The NRC plan for inspection of the improving Station Performance issues is discussed in more detail in Section 3 of this plan.

REVISION 6 u

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3 On November 3,1996, the agency established the Special Projects Office (SPO) to consolidate NRC efforts under a single Senior Executive Service (SES) manager,

.who reports to the Director of the Office of Nuclear Reactor Regulation (NRR). The Director, SPO assumed the authority and responsibilities of the Regional

' Administrator and the Associate Director of Projects.

4 1.2 CURRENT STATUS Millstone Unit 2 is currently preparing for restart estimated to be sometime during 1999; Unit 1 is to be permanently shutdown; and, Unit 3 restarted June 29,1998 and is currently operating at 100% power. Units 2 and 3 still remain on the NRC watchlist. The NRC's Special Projects Office has been eliminated and inspection activities, except for ICAVP inspections and Employee Concerns / Safety Conscious Work Environment oversight, have been returned to NRC Region 1.

NRCICAVP activities for Unit 2 will remain a separate NRR function until completion of Unit 2 restart. The Region 1 Regional Administrator has overall responsibility for the Millstone 2 restart oversight process.

2.0 10 CFR 50.54(f) Activities 2.1 HISTORICAL Each Millstone unit was requested to submit information describing actions taken to ensure that future operations will be conducted in accordance with the terms and conditions of the operating license, the Commission's regulations, and the Final Safety Analysis Report. In a May 21,1996, letter, the NRC requested Northeast Utilities (NU) to provide for each unit its plan for completing the licensing bases 1

reviews.

To aid in NRC understanding of how deficiencies were identified and dispositioned, the NRC's May 21,1996, letter also requested that NU provide for each Millstone unit a comprehensive list of design and configuration deficiencies and information related to how each deficiency was identified and would be dispositioned.

On August 14,1996, the NRC issued a Confirmatory Order establishing an Independent Corrective Action Verification Program (ICAVP). The independent effort will verify the adequacy of NU's efforts to establish adequate design bases and design controls, including translation of the design bases into operating procedures and maintenance and testing practices, verification of system performance, and implementation of modifications since issuance of the initial facility operating licenses. The NRC oversight of the ICAVP and activities will be in addition to the activities described in this Restart Assessment Plan. The results from this program will be' incorporated into this restart plan and considered a significant part of the decision regarding recommended restart.

REVISION 6 w,

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2.2 CURRENT STATdS i

L The Unit 2 ICAVP is in progress and NRC ICAVP inspections are ongoing. The following inspections concerning configuration management have been performed at Unit 2:

50-336/97-211(ICAVP) performed August 25-29, September 2-5, and December 1-5,1997 50-336/98-202,(SSFI) performed March 2-April 3,1998 50-336/98-201,(ICAVP) performed April 13-May 8,1998 Future ICAVP inspections will be performed to evaluate the adequacy of the Unit 2 configuration management.

3.0 Insoection Manual Chaoter 0350 Process 3.0.1 HISTORICAL l

Millstone Unit 1 entered a routine refueling outage on November 3,1995. On December 13,1995, the NRC sent a " Demand for Information Letter" (10 CFR 50.54(f)) requiring the licensee to certify compliance with the regulatory requirements before restarting the unit. At the January 1996 Senior Management h

Meeting, the site was placed on the " Watch List" for various reasons, including a i

concern for regulatory compliance.

Subsequently, Millstone Units 2 and 3 were l

sent similar letters which required responses before restart.

The NRC Inspection Manual Chapter (MC)-0350," Staff Guidelines For Restart Approval", provides guidelines and a list of tasks and activities that must be considered before a plant that has been shutdown for cause can restart. Because of NRC concerns relating to the licensee's management effectiveness, the appropriate aspects of MC 0350 will be applied to the restart of Units 1,2, and 3 to ensure applicable requirements have been met.

3.02 CURRENT STATUS l

The MC 0350 checklist has been completed for Unit 3; is no longer applicable to l

Unit 1; and is in its early stages for Unit 2 because of current plant status (core still L

fully off-loaded). Most check!ist items concerning Unit 2 readiness are still open.

Some responsibilities on the checklist have been changed due to the elimination of l

the Special Projects Office and the involvement of the Region 1 Regional Administrator. Unit 2 Core reload has been rescheduled several times due to emergent work. Closure of many MC 0350 items will depend on plant readiness, and the results of future NRC inspections including completion of ICAVP inspections, the Unit 2 OSTI and the 40500, Corrective Actions, inspection. The REVISION 6 l

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OSTI and the 40500 inspections for Unit 2 have been tentatively scheduled for the first quarter of 1999. Both Units 2 and 3 remain on the NRC watchlist.

3.1 SPECIAL PROJECTS OFFICE 3.1.1 HISTORICAL The SPO was created on November 3,1996, to oversee the restart of the Millstone units. The plan was to consolidate the NRC resources devoted to the restart efforts under one SES manager. The office is organized into three primary elements, licensing, inspection, and independent corrective action oversight. The Licensing Branch will administer the typical licensing actions performed in NRR; the Inspection Branch will implement the inspection programs, normally managed from the region, and the Independent Corrective Action Verification Program Oversight Branch will oversee the licensee's licensing and design bases review process.

Within the SPO, the Restart Assessment Panel (RAP) will meet to assess the licensee's performance and their progress in completing the designated restart activities. The RAP is composed of the Director, SPO (chairman); the Deputy Directors of Licensing, inspections, and Independent Corrective Actions Verification i

Program Oversight; the Project Managers for the three Millstone units; the inspection Branch Chief, the Senior Resident inspectors for the three Millstone units, and the appointed Division of Reactor Safety representative. The function of the Millstone RAP is described in MC-0350.

3.1.9 CURRENT STATUJ in a staff requirements memorandum dated July 15,1998, the Special Projects Office was eliminated. Responsibilities originally residing within SPO were reassigned various groups within NRR and Region 1. Inspection activities, with the exception of ICAVP inspections, have been assigned to Millstone Inspection Staff under the Region i Office of the Regional Administrator. The ICAVP Project and Millstone Project Directorate are assigned to the Director of NRR. The three groups i

will still meet on a regular basis as the Restart Assessment Panel for Unit 2.

3.2 MILLSTONE OPERATIONAL READINESS PLAN 3.2.1 HISTORICAL On July 2,1996, NU submitted the Unit 3 Operational Readiness Plan, which was discussed at the July 24,1996, meeting and updated at the August 19,1996, meeting. However, the licensee has replaced all of the senior managers (President, Vice Presidents, and two of the three unit directors) in the recent past. With these

. replacements, tha submitted plans for Unit 3 and the proposed plans for Units 1 and 2 are being chariged substantially. The RAP will review these plans and hold periodic meet!ags with NU, open to the public, to discuss the schedule for implementation and coordination of NRC restart activities.

l REVISION 6

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6 The deficiency lists associated with the restart plans for each unit, which will be updated periodically by the licensee, includes restart and deferred items, and will be I

4 audited by the NRC to verify the acceptability of the criteria used to defer items i

from the restart list.

3.2.2 CURRENT STATUS The NRC continues to hold meetings with the licensee which are open to the public to discuss restart activities. Since Unit 3 has been restarted, current maetings will

. emphasize the status of Unit 2. The NRC also holds periodic meetings directly with l

i the public to obtain comments concerning the Millstone Restart Plan and to answer j

questions. The frequency of the public meetings has been reduced to quarterly or when milestone updates are appropriate.

In a letter dated October 21,1997, Unit 2 provided to the NRC a second a pdate to L

the post restart deferred items list. This list was reviewed by the NRC during an inspection performed between October 2 and November 30,1997. The inspection concluded that Unit 2 had improved the review and approval process to provide i

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assurance that the list would be complete and accurate. The improved process resulted in the list containing items that were appropriate for deferral and that the contents of the list had reflected a conservative decision making process. No deferred issues were identified, that if not corrected prior to plant restart, would result in a safety significant concern to plant operations. An inspection of the recent update submittats will be performed on or about early December.

Since the October 21,1997, update of the deferred items list for Unit 2, two 1

l updates have been received by the NRC. These updates have not yet been reviewed by the NRC, but will be reviewed prior to any authorization for the Unit 2 i

restart.

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3.3 CORRECTIVE ACTION PROGRAM 3.3.1 HISTORICAL The NU corrective action program has been weak in ensuring comprehensive and effective corr:.,ie actions. There are many instances of narrowly focused corrective actions that failed to embrace all aspscts of the underlying problem.

Additionally, the licensee has failed to follow up on corrective actions to ensure they were effective. Consequently, the RAP has determined that any restart effort should examine the current state of the licensees corrective action program.

Because of the large number of Condition Reports (CR) [ Note: CRs were previously called Adverse Condition Reports) being identified by the licensee's staff, the resident and regionalinspection staff will concentrate on ist ies for each unit Identified by the CR process and audit the licensees corrective actions for completeness. The staff is periodically selecting CRs for review, based on the l

licensee's assigned level of importance, or their risk significance, as perceived by REVISION 6 I

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the resident staff. Additionally, other CR's will be examined to provide a spectrum of safety significant and lessor risk issues. These selected CR's will be added to the SIL for each unit, which are Enclosures 1,2, and 3 to this plan. The intent is to primarily assess the corrective action program while dealing with the safety significant technicalissues. Examination of the corrective action program needs to I

review the Action Requests (AR) from the Action item Tracking and Trending i

System (AITTS) program, which is an extension of the CR process, and commitments regarding violations and inspection items. Further, a significant input

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to assessing the licensee's corrective action program is denad f.om the normal inspection program where valuable insights regarding the effectiveness of corrective i

actions are routinely collected from the technical safety inspections.

j Additionally, the NRC Independent Corrective Action Verification Oversight Branch will assess the licensee's corrective actions for degraded and non-conforming 1

conditions. Finally, the Operational Safety Team inspection (OSTI) will audit l

portions of the corrective action process during the course of its activities.

Demonstration of improvements in the process will be judged by the completeness l

of the licensee's corrective actions for each of the inspected CRs. There must be a i

high ratio of successfully completed CR's to the total population inspected. There l

should only be minor comments regarding the processing, evaluation, directed corrective actions and closure of an issue.

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l 3.3.2 CURRENT STATUS l

Th licensee's corrective action processes were significantly reviewed by the Unit 3 40500 and OSTI inspections. Although the emphasis in these inspections was for Unit 3, much of the licensee's corrective action system applies to Millstone Station l

in general. Based on these and other NRC inspections, SECY 98-090 concluded that the licensee's corrective action program was adequate to support the restart of t

Unit 3. 40500 and OSTIinspections will be performed for Unit 2 prior to restart to determine the effectiveness of the corrective action program specifically as it i

applies to Unit 2.

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- 3.4 WORK PLANNING AND CONTROLS (C.4.P l

3.4.1 HISTORICAL Work planning and controls are other areas that the licensee has shown a weakness. The ability to plan, control, and complete work is fundamental to j

achieving adequate corrective actions. Effective work planning and controls are prerequisites for reducing and managing backlogs. Weak work planning and control i

' Reference to applicable MC-0350 section 2

REVISION 6 I

were evident during the 1995 Unit 2 outage, wherein, tagging boundary violations resulted in an extensive effort by the licensee to correct. Work control and planning

-were also issues at Unit 1,.which resulted in a managemer.t meeting..

There will be a complete review of the Automated Work Order (AWO) process by the resident or regional staffs. The automated work order process is an integral part of the work planning and control system and is instrumentalin establishing the scope of the work, providing the appropriate procedures, and establishing the tagging boundaries. The OSTI will assess the engineering and maintenance backlogs during its operational readiness inspection and will determine if there are safety significant issues that must be resolved before restart.

L 3.4.2 CURRENT STATUS l

The work control process at Unit 2 is the subject of ongoing routine inspections.

An OSTI will be performed at Unit 2 as the unit nears restart. The OSTl,in part, will perform an in depth review of the Unit 2 work control process.

3.5 PROCEDURE UPGRADE PROGRAM (C.3.3.e) 3.5.1 HISTORICAL The quality and adherence to procedures has been a chronic problem at the Millstone site. The issue was an element in " improving Station Performance" and was one of the subjects of discussion at the periodic meetings between NU and the NRC. In response to NRC concerns, the licensee developed the Procedure Upgrade l

Program (PUP) in the early 1990's to improve station procedures.

l The resident inspectors will relate procedural inspection findings back to the l

procedural upgrade program (PUP), identifying whether the procedures reviewed during the course of an inspection have been upgraded and characterize the quality of the document. This will provide an input for assessing the effectiveness of the licensee's PUP. The NRC staff will develop an inspection plan for examining selected portions of each unit's individual efforts.

3.5.2 CURRENT STATUS I

The licensee has essentially completed the PUP for Unit 2.- The NRC performed a series of inspections of the PUP starting in August,1996, and ending in August, 1997. These inspections determined that the licensee had met most of it's commitments made to the NRC in a June 4,1992, letter, particularly in standardizing the format of station procedures and reducing the number of higher l

tiered procedures.

Programmatic inspections of the PUP apply to all Millstone units. NRC inspections of the technical adequacy of Millstone Unit 2 procedures as a result of the ICAVP i

REVISION 6

9 process are ongoing. There is a backlog of procedure changes at Unit 2 identified externally to the PUP which are being driven by other processes in place such as

.the CMP process, procedure performance, biennial reviews, design changes and technical specification changes. Because of problems identified in the adequacy of i

surveillance tests during 1996 and early 1997, during the past year Unit 2 has performed a 100% review of Section 4 of their Technical specification to determine that all surveillance tests will validate conformance to the TS. This process has j

been completed and surveillance tests are being revised to correct identified l

deficiencies. This process also reviewed conformance to the Unit 2 Technical -

Requirements Manual and to testing required by ASME Code Section XI, Pumps and Valves.

Procedures will be reviewed for adequacy by the ongoing NRC ICAVP inspection Process and routine NRC inspections. The Unit 2 OSTI will provide the final determination as to the adequacy of Unit 2 procedures for restart.

i 3.6 OVERSIGHT (C.1 A 1 3.6.1 HISTORICAL r

The licensee has identified its oversight function as deficient through self-1 assessments and external and internal audits and as a contributing factor in the licensee's declining performance. The report of Assessment of Past Ineffectiveness of Indeoendent Oversiaht by the Yankee Atomic Electric Company (YAEC),

examined the failure of Quality Assessment Services, the Independent Safety Evaluation Group, and the Nuclear Review Board (NRB) to identify the deficient FSAR control process and the radioactive waste conditions. They found that management did not support these functions adequately.

Late in the restart process for each unit, there will be an inspection to evaluate the effectiveness of the oversight groups and management's utilization of the oversight process. There should be positive indications that the oversight function has been i

made an integral part of the licensee's management team assessment process. The oversight function should result in meaningful findings, have access to line i

management, and provide assessments of process and program effectiveness through periodic reports. There should be evidence that the reports are forwarded to the responsible manager and that they have dealt with the contents appropriately. Oversight should be adequately staffed with qualified and experienced personnel. The audit and surveillance programs need to be clearly defined, proceduralized, and implemented with established schedules.

3.6.2 CURRENT STATUS Both the 40500 and OSTIinspections performed extensive reviews of the current function of the Nuclear Oversight organization. Both inspections determined that Nuclear Oversight is more effective than in the past and was more involved in day REVISION 6

10 to day plant activities. Significant improvement has been made in this area since serious deficiencies were noted in an assessment performed in 1996 by a Joint

... Utilities Management Assessment. SECY 98-090, stated,.in part, "...The NRC staff concludes that oversight is adequate to support the restart of Millstone Unit 3 based on (1) the reorganization and replacement of key mangers within NNECO and specifically NOS; (2) the promulgation of improved management expectations; (3) the establishment of open communications between the line and NOS and within l

NOS; (4) the completion of staffing and improved quality and training of the NOS staff; (5) development of a viable inspection and audit program; (6) demonstrated j

improvements in NOS problem identification and assurance that corrective actions

- are implemented; (7) improved performance of quality control inspectors; (8) 4 credible performance by the safety committees; and (9) an effective self-assessment program." Although the recent 40500 and OSTIinspections focused j

on Unit 3, many of the conclusions are applicable to Unit 2.

In addition, the Joint Utilities Management Assessment (JUMA) issued a critical report in its 1996 review, which concluded that the Quality Assurance (QA) program had not been effective in resolving identified problems, including those j

documented in previous OA internal and external assessments. The following and most recent JUMA, completing its on-site assessment in June 1998, determined that the Nuclear Oversight organization had improved in every area evaluated.

However, the team noted that the transition from unit restart goals to station operational excellence required additional efforts to reinforce the gains made since l

1996, particularly in the area of issue ownership, the emphasis on the overall site o

responsibility for quality, and the need for improvement in the response to numerous Condition Reports (CRs). These recent JUMA findings resulted in the i

issuance of four new CRs, covering such broad issues as " expectations, communication, teamwork and trust, and corrective action program implementation", where continued improvements are expected.

Since the startup of Unit 3 in June 1998, the NOS has changed its NORVP assessment process to a Nuclear Oversight Verification Plan (NOVP) format, which incorporates a review of common site programs (e.g., security, EP, training) along with separate assessments of Unit 3 operations, Unit 2 restart, and Unit 1 maintenance. Recent NOVP reports have identified the need for improvements for some of the key issues affecting all three units, as well as the common site programs. The full scope of NOS activities, including the NOVP, appears directed toward focusing Millstone Station management attention to the areas impacting Unit 2 restart readiness and the achievement of operational excellence for overall station performance.

Recent routine inspection activities have observed that Nuclear Oversight has been very active in the monitoring of activities being performed at Unit 2. They have

provided significant oversight through audits and surveillances of plant activities l

particularly in the area of readiness for fuelload. There is also a special oversight group which is monitoring the licensees overall readiness for plant restart.

REVISION 6

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11 Oversight has been very active in its review and involvement in plant activities. As

> with Unit 3,40500 and OSTIinspections will be performed at Unit 2 prior to restart.

3.7 ENFORCEMENT 3.7.1 HISTORICAL Outstanding enforcement items will be reviewed by the resident inspectors to determine if any issues require closure before plant restart. The Agency is currently accumulating escalated enforcement items concerning design bases issues which may require licensee response before recommending restart of each unit. There are also potential enforcement items that will result from the efforts of the Office of l

Investigations, the allegation process review group, the Office of the inspector General, the Specialinspection Team, routine resident and regionalinspection efforts, and the 10 CFR 2.026 petition process.

A Pre-decisional Enforcement Conference was held with the licensee on December 5,1996, to discuss 64 individual apparent violations. The licensee did i

not contest any of the violations at the conference, and the staff is in the process of finalizing the enforcement package. Once enforcement actions have been taken, the NRC will evaluate the licensee's corrective action to those enforcement actions which are determined to impact restart of each unit. Subsequently, a $2.1 million civil penalty was issued to NNECo on December 10,1997, which included violations applicable to all three units.

3.7.2 CURRENT STATUS No significant violations for Unit 2 have been identified in 1998 that would have been considered for escalated enforcement action. Twenty one Severity Level IV

' violations were identified and issued beginning in -January through September 30, 1998. In the December 10,1997, civil penalty, 24 violations were identified l

against Unit 2. As of October,1998,9 of the 24 civil penalty violations have been j

closed.

3.8 EMPLOYEE CONCERNS 3.8.1 HISTORICAL The Millstone site has had a chronic problem in dealing effectively with employee concerns. These problems have been documented in severallicensee assessments, audits, and internal task group studies. The NRC continues to receive an inordinate quantity of allegations from the staff at the Millstone site. The current series of 10 CFR 50.54(f) letters were initiated due to NRC concerns regarding design basis issues at Millstone, as well as an allegation, and a subsequent Millstone 10 CFR REVISION 6

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2.206 petition, dealing with the Unit 1 spent fue; pool. The NRC has issued two enforcement actions for harassment and intimi<htion to NU in the past three years.

l In a September 1996 report, "Millstoae Independent Review Group Regarding Millstone Station and NRC Handling af Employee Concerns and Allegations," the l

NRC staff determined that, in generas an unhealthy work environment, which did not tolerate dissenting views and did not welcome nor promote a questioning l

attitude, has existed at the Millstone plants for the past several years. This poor environment resulted in repeated instances of discrimination and ineffective handling of employee concerns.

The NRC initiated two task groups to examine the Northeast Utilities handling of employee concerns, and the recent layoffs that affected several previous allegers.

The task group examined NU's handling of employee concerns and identified a number of root causes for the licensee's problems in this area. The task group also concluded that past problems and their root causes still remain. The output from these two task groups and the licensee's response to the order will be reviewed for restart issues.

On October 24,1996, the director, Office of Nuclear Reactor Regulation (NRR),

issued an Order to Northeast Nuclear Energy Company (NNECO) requiring specific actions to resolve problems in the process for handling employee safety concerns at the Millstone station. The Order required NNECO to develop, submit for NRC

-review, and implement a comprehensive plan for (a) reviewing and dispositioning t-safety issues raised by its employees, and (b) ensuring that employees who raise safety concerns can do so without fear of retaliation. On January 31,1997, NNECO submitted the plan to the NRC and began implementation of elements of the Plan.

The Order further required NNECO to submit, for NRC approval, a proposed independent, third-party oversight program (ITPOP) organization, to oversee implementation of NNECO's Plan. On December 23,1996, NNECO submitted the proposed third-party organization, Little Harbor Consultants, Inc. (LHC), to the NRC. On April 7,1997, the NRC approved LHC as the third-party organization.

The Order specified that once approved, the third-party organization develops and submits for NRC approval an oversight plan for conduct of their activities. On May 2,1997, LHC submitted the third-party oversight plan to the NRC for approval. On July 15,1997, the NRC reviewed and approved the ITPOP oversight plan. As specified in the Order, independent, third-party oversight will continue to be l

implemented until NNECO demonstrates, by its performance, that the conditions l

which led to the requirements of the oversight have been corrected.

The effectiveness of NNECO programs and program implementation associated with L

-fostering and maintaining a SCWE and for handling employee safety. concerns will be assessed by NRC staff relying substantially on the findings of ITPOP's oversight i

activities. Staff will direct its limited resources to evaluation of a sample of NNECO REVISION 6 7

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13 programs and activities and on review of ITPOP oversight activities. This approach will provide the staff with independent assessment of the effectiveness of NNECO

. programs as well as establishing confidence in ITPOP's findings.

4 3.8.2 CURRENT STATUS The NRC has made an interim ovaluation of Millstone's current program of evaluating employee concerns and maintaining a safety conscious work environment (SCWE). SECY 98-090 documents the final NRC conclusions in this area and applies to all three units. Unless emerging issues arise, this area is closed for all three units. SECY 98-090 states, in part, the following: "... Based on review of documentation, monitoring of NNECO actMties, NRC team (inspection]

evaluations, and consideration of LHC findings, the NRC concludes that the NNECO's ECP and SCWE are established and functioning effectively at Millstone.

j Employee concerns are prioritized based on safety significance, identities are protected, case resolution is timely and there is appropriate follow-up on corrective l

action adequacy. Further, significant improvements have been made in the training provided the employees and contractors regarding SCWE and ECP...The staff also considers that NNECO has developed adequate plans, following restart of a unit, for monitoring the sites safety environment...The staff notes that in accordance with the October 24,1996, Order, the independent third party oversight organization will continue at Millstone until the licensee demonstrates by its performance that the conditions, which led to the requirement of the oversight, have been corrected to the satisfaction of the NRC..."

The NRC has performed an evaluation, 50-245/98-215,for ECP and SWCE during August 1998. Another evaluaton was completed during October 1998. The results of this evaluation are under NRC management review to determine if the " Order Requiring Third Party Order Oversight of Northeast Nuclear Energy Company's 2.

Implementation of the Millstone Station Employee's Safety Concerns issues" dated October 24,1996, can be lifted.

3.9 SIGNIFICANT ITEMS LIST 3.9.1 HISTORICAL The technique to be used for the restart will be to reach agreement with the licensee on its restart issues list, have it impose controls on adding or deferring items from the list, have the resident inspectors review the list to ensure it includes issues of interest to the NRC, and have the residents review the deferred list to ensure appropriate rationales for deferral have been documented (see item B.4.3. of MC 0350). As a result of the'10 CFR 50.54(f) activities, the licensee initially determined that, for all three Millstone units, hundreds of items did not meet criteria for inclusion as a restart item. The resident inspectors, augmented by headquarters staff, are reviewing these lists periodically and confirming that the licensee is performing an adequate assessment of the discrepancies. This process will be used REVISION 6

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in the restart assessment of each unit. The RAP will determine that licensee's l.

< restart issues list includes appropriate restart items from the licensee's programs such as ACR, AR (AITTS), engineering work requests, and commitments.

i The enclosed NRC Significant items Lists for all Millstone units (Enclosures 1,2 and

' 3) contain some of the items that are being used to audit and evaluate licensee

. programs (e.g., the corrective action process) and significant safety / regulatory l

technical issues.

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l1 Restart issues on the NRC's Significant items List will meet at least one of the following criteria:

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Resolution of the issue is required to ensure safe operation of the facility to include satisfaction of the technical specifications or licensing basis.

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Inspection of the issue will provide an insight to an identified programmatic

- deficiency such as the corrective action system.

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Inspection of the issue will provide assessment of management effectiveness or personnel performance.

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3.9.2 CURRENT STATUS Because of licensee attention to the restart of Unit 3, only limited licensee and NRC resources were applied to Unit 2. Major emphasis was placed on the Configuration Management Program process but lesser emphasis was placed on Unit 2 plant readiness..The Unit 2 Sll consists of 54 items which incorporate 75 separate issue closure packages and 8 issues which require no closure packages. The most recent SIL update is enclosed as Attachment (1) to the RAP.

' 3.10. POWER ASCENSION INSPECTIQN

-3.10.1 HISTORICAL Selected portions of NRC MC-93802, " Operational Safety Team Inspection," will provide the framework for a team inspection of each unit during the restart process.

The procedure scope will be modified to address the pertinent issues at Millstone.

The inspection will cover self-assessments by the licensee, the licensee's implementation of its startup plan, control room observations during the approach to j

criticality and power ascension, selected systems readiness inspection and l

observation of management oversight.

l The resident inspectors will provide close monitoring of each unit during mode l'

_.. changes to ensure compliance with each unit's technical specifications and FSAR design bases.

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REVISION 6

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'15 3.10.2 CURRENT STATUS Unit 2 has not reloaded fuel. Heat up and restart has not yet been scheduled by the

-licensee. The NRC has not yet drafted an inspection plan for Unit 2, but the inspection plan will be similar to the inspection used for the startup of Unit 3. In j

addition, the OSTl will be used evaluate Unit 2 readiness for restart.

3.11 PLANT PERFORMANCE REVIEW

\\

The Restart Assessment Panel performs Plant Performances Reviews (PPRs) semi-annually. Two reviews were conducted, on March 19 and November 18,1997.

These PPRs were used to identify issues that need to be inspected at Millstone Station based on licensee performance. These reviews identified several issues that I

l warrant NRC inspection before plant restart of Unit 3. Unit specific issues as well as station wide issues identified by the March 19,1997, PPR, are contained in the SIL for each Unit as inspection items.

i l

PPRs for Millstone were suspended for all units starting in October,1997. The j

reason was the continuous NRC management oversight by the Special Projects i

Office. The PPR remains suspended for Unit 2 until after restart. Although the SPO has been eliminated, special oversight is still in place as required by the July 27, 1998, SRM. The joint NRR and Region i Millstone oversight group still meets frequently as the Restart Assessment Panel (RAP). The RAP management will continue to frequently brief NRC senior management and the Commission on Millstone Unit 2 status obviating the need for a redundant PPR.

3.12 LICENSING ISSUES Millstone Unit 2 has periodically submitted licensing issues (amendments, unresolved safety questions, relief requests, etc.) which will impact the restart process. The status of NRR actions concerning each issue is documented in Enclosure (3) of this plan. Licensing actions required for Unit 2 must be resolved prior to the restart to Unit 2.

Enclosures:

(1).

Significant items List - Millstone Unit 2 (2)

MC-0350- Restart Approval Checklist - Millstone Unit 2 (3)

Licensing issues Required for Restart of Millstone Unit 2 l

I l

l i-REVISION 6 l

1 MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (1)

Millstone Unit 2 Sianificant items List The following is a list of the Millstone issues that, as a minimum, require an NRC inspection and evaluation prior to restart.

I REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 1

MC 0350 SECTION C.1.3, MANAGEMENT OVERSIGHT AND EFFECTIVENESS;

INSP, C.2.1,C.2.2.a,d,e, LICENSEE STAFF SAFETY CULTURE
40500, C.3.1,a,b,c,d OSTI 2

MC 0350 SECTION C.1.1, 50.54(f)/lCAVP (PHASE I and 11)

ICAVP, UPDATED C.1.3, C.1.4.g, C.3.2, C.4.f; FSAR UPDATES
INSP, IR 98-201 CONFIRMATORY ORDER 10 CFR 50.59 PROCESS PROJ IR 98-202 DATED 08/14/96 CONFIGURATION MANAGEMENT / DESIGN CONTROL IR 98 208 PROCESS (PART OF ICAVP PHASE l) 3 MC 0350 SECTION C.1.1 AND DESIGN CONTROL PROCESS CHANGES TO ADDRESS ICAVP UPDATED C.1.3; C.2.2.d; UNIT 1 ACR 7007 IR 98 201 UNIT 1 ACR 7007; IR 98 202 UNIT 2 ACR 8761 NUMEROUS EXAMPLES OF DRAWINGS NOT IR 98-208 REFLECTING ACTUAL PLANT CONFIGURATION 4

MC 0350 lTEM C.1.4.e, LICENSEE HANDLING OF CONCERNS RAISED BY PROJ UPDATED C.2.2.b,e; EMPLOYEES IR 98-210 CONFIRMATORY ORDER

  • EMPLOYEE CONCERNS PROGRAM IMPROVEMENTS DATED OCTO8ER 24,1996

MC 0350 SECTION C.1.1, CORRECTIVE ACTION PROGRAM EFFECTIVENESS IN SP, C.1.3, C.1.4.d-1, C.2.1, 40500 C.2.2.c e C.3.1.d.m; C.4.f; SELF-ASSESSMENT PROGRAM IMPLEMENTATION AND IR 336/96-04 & 08 EFFECTIVENESS; eel 336/96-20130 COMMITMENT TRACKING 6

MC 0350 lTEMS C.2.1.d, WORK PLANNING AND CONTROL:

INSP, UPDATED C.4.e,f,h,i,j OSTl IR 97-207 PLANT MAINTENANCE PROGRAM EFFECTIVENESS; SIGNIFICANT HARDWARE ISSUES RESOLVED; MAINTENANCE BACKLOG MANAGED AND IMPACT ON OPERATION ASSESSED: SURVEILLANCE TESTING; PLANT HOUSEKEEPING REVISION 6 November 18,1998

l i

l REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS l

7 MC 0350 lTEMS C.1.3.f, BYPASS JUMPERS, OPERATOR WORK-AROUNDS &

INSP, j

C.2.1.e, C.3.2.e, C.4.f,i; CONTROL BOARD DEFICIENCIES OSTI l

8 MC 0350 ITEMS C.2.1.b, PROCEDURE ADEQUACY / PROCEDURE UPGRADE

INSP, UPDATED C.2.2.d, C.3.1.k, C 3.3.e,f; PROGRAM OSTI 1R 97 202 ICAVP IR 97 203 IFl 336/95 201-03; PROCEDURE CLASSIFICATION - GENERAL USE VERSUS IR 97 207 CONTINUOUS USE IR 98 207 IR 98 212 URI 336/96-0104; LOSS OF DC BUS EVENT - ESTABLISH PROCEDURES REQUIRED BY TECHNICAL SPECIFICATION 6.8.1 URI 336/96 06-08 SHUTDOWN COOLING SYSTEM WATER HAMMER; NU LETTER B16257 REVIEW OPERATING PROCEDURES TO PRECLUDE WATER HAMMER EVENTS eel 336/97-02-12 SURVEILLANCE PROCEDURE ADEQUACY l

1 9

MC 0350 lTEMS C.1.4.g, OPERATING PROCEDURES CONSISTENT WITH FSAR

INSP, UPDATED i

C.2.2.g, C.3.3.e,f; DESCRIPTION OF SYSTEM OPERATION ICAVP IR 97-02 eel 336/96-0813, IR 98 201 eel 336/96 06-05, ADEQUACY OF PROCEDURE CHANGE PROCESS TO IR 98-202 eel 336/96 08-06, ENSURE OPERATION IN ACCORDANCE WITH LICENSE IR 98 206 LER 336/97-02; IR 98 207 ACR 11104 IR 98-208 10 MC 0350 lTEMS C.2.1.g, PROGRESS OF EMERGENCY OPERATING PROCEDURE DRS(OL)

UPDATED C.3.3.e,f; UPGRADES; 1R 97-203 IR 336/95 21 ACCEPTABILITY OF DEFERRING ABNORMAL i

OPERATING PROCEDURE UPGRADES j

l 11 MC 0350 lTEMS C.1.4.a,b,c, QUALITY ASSURANCE AND OVERSIGHT PROGRAM

INSP, i

C.2.1.c 40500 l

12 MC 0350 SECTION C.1.1 LICENSEE RESTART PUNCH LIST REVIEW OF ITEMS INSP UPDATED C.1.3, C.1.4.e, C.2.1.f-g, DEFERRED UNTIL AFTER RESTART IR 97 207 C.4.f,i 13 MC 0350 lTEMS C.3.1.g,h,1,J,1, LICENSED OPERATOR STAFFING: CONTROL ROOM IN SP, C.3.3.a.b,d.g FORMALITY; ATTENTIVENESS TO DUTY; ATTENTION OSTI TO DETAIL; OFF-HOUR PLANT STAFFING; OVERTIME USAGE; AWARENESS TO PLANT SECURITY; AWARENESS OF EQUIPMENT STATUS; LOG KEEPING PRACTICES:

l r

REVISION 6 November 18,1998 2

i

1 l

REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS i

14 MC 0350 lTEMS C.3.1.e, OPERATOR LICENSING AND TRAINING DRS(OL) l C.3.3.c; CONFIRMATORY ACTION LETTER DATED MARCH 7,-

1997; URI 336/97-01-03 15 MC 0350 ITEMS AUGMENTED INSPECTION COVERAGE DURING

INSP, C.4.a,b,c,d,e,g RESTART INSPECTION:. OPERABILITY OF TECHNICAL OSTI.

SPECIFICATION SYSTEMS; OPERABILITY OF

(

SECONDARY AND SUPPORT SYSTEMS; SYSTEM l

LINEUPS; RESULTS OF PRE-STARTUP TESTING: POWER ASCENSION TESTING 16 MC 0350 ITEMS C.2.2.g-h, EMERGENCY PREPAREDNESS PROGRAM (INCLUDING.

DRS(EP)

CLOSED C 3.1.m, C.3.2.h; ORGANIZATION / STAFFING / DOSE ASSESSMENT IR 96-06 NU LETTER (B16195) DATED CAPABILITY) lR 97 202 FEBRUARY 10,1997 IR 98-208 l

l 17 MC 0350 SECTION C.5 AND DISPOSITION OF REGULATORY ISSUES: LICENSE

NRR, C.6 AMENDMENTS; EXEMPTIONS; RELIEFS; ORDERS;
PROJ, l

SIGNIFIC/sNT ENFORCEMENT ISSUES: ALLEGATIONS; OE, 01, AND 10 CFR 2.206 PETITIONS. COORDINATION WITH

DRS, INTERESTED AGErCES AND PARTIES.

OPA 1

18 ACRs 02621,M2 96-0239 MATERIAL, EQUIPMENT AND M.RTS LIST (MEPL)

NSP UPDATED l

eel 336/96 20142& 43 PROGRAM IR 97 202 IR 97-203 l

lR 97-208 l

lR 98 207 IR 98-212 19 ACRs M2-96-0515 & 07958; EQUIPMENT ENVIRONMENTAL CUAllFICATION (EEO)

ICAVP UPDATED eel 336/96-06-12, PROGRAM DRS(EEB)

IR 97-203 eel 336/96 201-20, INSP IR 98-212 URI 336/9319-02 HIGH ENERGY LINE BREAK PROGRAM LER 336/97-31 REVISION 6 November 18,1998 3

_=.-

REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 20 IFl 336/95 01-01 MOTOR OPERATED VALVES (GENERIC LETTER 8910)

DRS{SEB)

UPDATED IR 97-203 eel 336/96-0511 INACCURATE INFORMATION PROVIDED TO THE NRC I

REGARDING GENERIC LETTER 8910; eel 336/96-05-09 DYNAMIC TESTING OF AFW TERRY TURBINE STEAM ADMISSION MOV; eel 336/95-08-01,03 & 04 PRESSURE LOCKING OF CONTAINMENT SUMP LER 336/97-34 RECIRCULATION VALVES 21 MC 0350 lTEM C.3.3.e FIRE PROTECTION / APPENDIX R PROGRAMS DRS(EEB)

IR 336/96-08; LICENSEE SELF ASSESSMENTS APPENDIX R RELATED ABNORMAL OPERATING AND OA AUDITS; PROCEDURES; ACR M2 96-0460 APPENDIX R COMPLIANCE ASSOCIATED WITH THERMO-LAG 22 ACRs M2-96-0513; CONTAINMENT SUMP SCREEN MESH SIZE & ECCS DRS(SEB)

CLOSED eel 336/96 06-11 PUMP THROTTLE VALVE CLOGGING IR 97-203 URI 336/96-06-10 IR 98 207 23 ACRs 01991,M2 96-0449, HYDROGEN MONITORS AND POST ACCIDENT INSP 0467,0654,0655,& 0656; SAMPLING SYSTEM (PASS) INOPERABLE AND FAILURE eel 336/96-0811,12 & 13, TO MEET DESIGN BASIS AND LICENSING BASIS eel 336/96 20103& 41, URI 336/96 01-05 CORRECTIVE ACTIONS TO DEVELOP A DRS(EP)

URI 336/9018-05 REPRESENTATIVE TOTAL GAS SAMPLE USING PASS 24 ACRs 08174,04047,06372 &

EXCESSIVE REACTOR COOLANT SYSTEM HEATUP AND INSP 09739; COOLDOWN RATES: EVALUATION OF SIMULTANEOUS URI 336/95-42-03 REACTOR COOLANT PUMP AND SHUTDOWN COOLING SYSTEM OPERATION 25 NUMEROUS ACRs; ECCS PUMPS SUCTION LINE FROM RWST HAS INSP UPDATED URI 336/96 06-08 NUMEROUS DEGRADED OR INOPERABLE PIPE IR 97-203 SUPPORTS, MANY CAUSED BY WATER HAMMER 26 ACR 11252; "B" EMERGENCY DIESEL GENERATOR FAILURE -

INSP CLOSED eel 336/96-0910 INADEQUATE CORRECTIVE ACTIONS IR 97-02 IR 97 203 IR 98 207 REVISION 6 November 18,1998 4

..__.__.,__......_.m_

i l

REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 27 eel 336/96 201-09 INADEQUATE DESIGN CONTROL MEASURES FOR ICAVP i'

VERIFYING ACCURACY OF INFORMATION CONTAINED IN DESIGN BASIS DOCUMENT PACKAGES 28 eel 336/96-201 11, FAILURE TO ADEQUATELY CONTROL INSTALLATION INSP CLOSED eel 336/96-20131 OF TEMPORARY MODIFICATION TO THE RBCCW IR 97 203 SURGE TANK IR 98-212 29 eel 336/96 201 12 SEPARATION AND SINGLE FAILURE CONCERNS FOR INSP CLOSED WIDE RANGE NUCLEAR INSTRUMENTS IR 97-203 1R 98-207 30 eel 336/96 20125 FAILURE TO IMPLEMENT CORRECTIVE ACTIONS INSP UPDATED CONCERNING " DUAL FUNCTION" ISOLATION VALVES 1R 97 202 31 eel 336/96-201-28 FAILURE TO ADDRESS STATION BLACKOUT ISSUES INSP UPDATED IDENTIFIED IN THE VECTRA ASSESSMENT 1R 97-203 32 eel 336/96-201-29 FAILURE TO IMPLEMENT CORRECTIVE ACTIONS FOR INSP CLOSED AUDIT ISSUES INVOLVING TRENDING AND IR 97-02

-i PRIORITIZATION OF NON CONFORMANCE REPORTS 1R 97 207 I

1R 98 207 33 eel 336/96-20136 INADEQUATE CORRECTIVE ACTION CONCERNING A DRS CLOSE0 SEISMIC DESIGN DEFICIENCY OF A VITAL (CMME)

IR 97 202 SWITCHGEAR ROOM COOLER 1R 97-203 IR 98 207 34 El1336/96 08 06 IMPLEMENTATION OF CORRECTIVE ACTION OF INSP CLOSED CHANGING OPERATING PROCEDURE TO LOCK OPEN IR 97-02 REFUELING POOL DRAIN VALVES, AS SPECIFIED IN THE IR 97-203 FSAR, WAS INADEQUATE IR 98 207 35 eel 336/96-08-08 INADEQUATE CORRECTIVE ACTION IN 1.ER 336/96-24 INSP CLOSED IR 97 203 IR 98-207 36 eel 336/96 0810 INADEQUATE CORRECTIVE ACTIONS TO ADDRESS INSP CLOSED UNIT 1 HEAVY LOADS LIFTED OVER THE UNIT 2 VITAL IR 97-02 SWITCHGEAR ROOM IR 97-203 IR 98-207 1

REVISION 6 November 18,1998 5

l l

REFERENCE MIL' STONE UNIT 2 INSPECTION ITEM RESP STATUS 1

37 eel 336/95 44-05 ICE BLOCKAGE OF SERVICE WATER STRAINER INSP BACKWASH LINE l

38 URI 336/96-05-11(IFS NO. URI SPENT FUEL POOL FSAR UPDATES INSP CLOSED 336/96-05 17)

II'. 97 02 i

39 eel 336/96-04-10 ERRONEOUS RBCCW FLOW VALUES IN CONTAINMENT INSP TEMPERATURE PROFILE ANALYSIS

)

URI 336/96-201-38 FAILURE TO CONSIDER POST-ACCIDENT FLUID TEMPERATURE IN HPSI FLOW EVALUATION l

40 LER 336/96-31 POTENTIAL STEAM GENERATOR OVERPRESSURE CUE INSP CLCSED l

TO RESTRICTIVE MAIN STEAM SAFETY PIPING IR 93-212 41 ACR M2-97-0023 SEIMANS COMPUTER MODEL OF REACTOR CORE NRR CLOSED FOLLOWING LARGE AND SMALL BREAK LOSS OF NRC LETTER COOLANT ACCIDENTS DATED 07/23/97 42 IR 336/94-201(IFS NO. IFl EMERGENCY DIESEL GENERATOR FUEL DAY TANK

PROJ, UPDATED 336/94 201-90)

DOES NOT SATISFY 7-DAY DESIGN BASIS CAPACITY INSP IR 98-207 1

43 URI 336/96-0814 INAPPROPRIATE REMOVAL OF STARTUP RATE TRIP INSP CLOSED l

LER 336/96-29 IR 96-08 1

IR 97-207 1

l 44 ACR 02797, ACR 09563, POTENTIAL TO EXCEED CONTAINMENT DESIGN INSP ACR M2 96 0153; PRESSURE FOLI.OWING A MAIN STEAM LINE BREAK LER 336/97-06 I

45 ACR M2 96 0296 FAILURE OF MAIN STEAM CHECK VALVE FOLLOWING INSP CLOSED A MAIN STEAM LINE BREAK (MSLB) COULD CAUSE IR 97 202 BOTH STEAM GENERATORS TO BLOW DOWN RESULTING IN EXCEEDING CONTAINMENT DESIGN PRESSURE. THE LICENSEE'S MEPL PROGRAM l

DESIGNATES THE MS CHECK VALVES AS NON QA WHICH THE LICENSEE HAS EVALUATED AS ACCEPTABLE.

46 LER 336/97-02 CONTROL ROOM AIR CONDITIONING COMMON INLET INSP DAMPER COULD BECOME STUCK CLOSED, DISABLING BOTH FACILITIES. DAMPER HAS NO MANUAL OPERATOR AS STATED IN FSAR.

REVISION 6 November 18,1998 6

l

(

REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 47 URI 336/96-08-09, REACTOR PROTECTION SYSTEM AND ENGINEERED INSP LER 336/96-24 SAFETY FEATURE RESPONSE TIME TESTING 48 ACR M2 96-0542 TECHNICAL SPECIFICATION LIMITS FOR INOPERABLE INSP CLOSED MAIN STEAM SAFETY VALVES NON-CONSCRVATIVE IR 98 212 49 LER 336/96-30,LER 336/97-05 INSERVICE INSPECTION / INSERVICE TESTING DRS UPDATED CR M2-97-0491 & 1229 PROGRAMS (CMME)

IR 96-06 IR 96-08 50 CONTROL /USE OF VENDOR INFORMATION INSP UPDATED IR 97-203 IR 98-208 51 IR 336/95-29 SERVICE WATER SYSTEM OPERATIONAL DRS(SEB)

PERFORMANCE INSPECTION (SWSOPI) FOLLOWUP 52 LER 336/97-33 ENGINEERED SAFEGUARDS ACTUATION SYSTEM INSP INOPERABLE DUE TO IMPROPERLY SIZED POWER SUPPLY FUSES 4.

53 LER 336/98-02 THE EMERGENCY CORE COOLING SYSTEM (ECCS)

INSP DESIGN DID NOT ADEQUATELY ADDRESS A LOSS OF COOLANT ACCIDENT (LOCA) COINCIDENT WITH THE LOSS OF EITHER Dl RECT CURRENT (DC) BUS OR ALTERNATING CURRENT (AC) BUS.

54 LER 336/98-09 LARGE BREAK LOSS OF COOLANT ANALYSIS PROJ INDICATES PEAK CLAD TEMPERATURE COULD EXCEED 2200 DEGREES F.

REVISION 6 November 18,1998 7

MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (2)

MILLSTONE UNIT 2 - MC 0350 RESTART APPROVAL CHECKLIST The following items are considered applicable to the restart of Millstone Units 2:

RESPONSIBILITIES AND AUTHORITIES l

lNEED l STATUS l RESP 4.01 Reaional Administrator, Realon 1. Notifies the Executive X

C RA Director for Operations (EDO) and the Commission, as appropriate, of the NRC actions taken concerning shutdown plants and the proposed followup plan.

4.02 Reaional Administrator, Reaion 1.

X C

RA a.

Discusses with the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, the Office of Enforcement (OE), and NRR, as appropriate, the need for an order or confirmatory action letter (CAL) specifying the actions required of the licensee to receive NRC i

approval to restart the plant and the proposed

- followup plan.

j b.

Decides, in consultation with the NRR Associate X

C RA Director for Projects, whethat this manual chapter j

applies to a specific reactor restart, c.

In coordination with the NRR Associate Director for X

C RA Projects, decides whether to establish a Restart Panel.

d.

Develops a written Restart Assessment Plan, X

C RAP including a case-specific checklist, to assign responsibilities and schedules for restart actions and j

interactions with the licensee and outside i

organizations, l

)

REVISION 6 November 18,1998

.,,. +

a

NEED STATUS RESP e.

Coordinates and implements those actions X

RAP prescribed in the Restart Assessment Plan that have been determined to be the Office of Special Project's responsibility. These include, when appropriate, interactions with State and local agencies and with regional offices of Federal agencies.

f.

In conjunction with NRR, reviews and determines X

RAP the acceptability of licensee's action program.

SRI g

NRR (L) g.

Approves restart of the shutdown plant, following X

RA consultation with the EDO and the Director of NRR, and approval / vote by the Commission.

4.03 Regional Administrator, Region 1 a.

Acts as the focal point for discussions within NRR X

RA to establish the appropriate followup actions for a plant that has been shut down.

4.04 Director, Licensing NRR (L) a.

Coordinates participation in followup conference X

calls and management discussions to ensure that the Regional Administrator is directly involved, when appropriate, in followup action.

b.

Coordinates and implements actions prescribed in X

NRR the Restart Assessment Plan that have been determined to be Licensing's responsibility. These include, where applicable, appropriate NRC Office or NRR Division interaction with other Federal agencies (e.g., Federal Emergency Management Agency 4

(FEMA), Department of Justice (DOJ)) pursuant to any applicable Memoranda of L.inderstandlng.

REVISION 6 November 18,1998 i

2

i lNEED-l STATUS RESP B.1 INITIAL NRC RESPONSE NA

)

The facts, the causes, and their apparent impacts should -

be established early in ihe 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. The following items j

should have been completed or should be incorporated into the CSC as appropriate. Refer to Section 5.02 of this manual chapter for additional information.

)

a.

~lnitial notification and NRC management discussion NA i

of known facts and issues l

b.

Identify / implement additionalinspections (i.'e. AIT, NA IIT, or Special) (Region).

l c.

Determine need for formal regulatory response (i.e.

NA i

order or CAL).

i d.

Identify other parties involved (i.e., NRC NA Organizations, other Federal agencies, industry organizations).

l I

REVISION 6 November 18,1998 3

l

)

I

lNEED fSTATUS l RESP

-l B.2 NOTIFICATIONS NA Initial notification of the event quickly communicates i>

NRC's understanding of the event and its immediate i

response to the parties having an interest in the event.

Notification to regional and headquarters offices of j

cognizant Federal agencies may be' appropriate. As the review process continues, additional and continuing notifications may be required.

'l 1

a.

Issue Daily and Directors Highlight (NRR).

NA b.

Issue preliminary notification (Region).

NA

)

c.

Conduct Commissioner assistants' b.-lefing.

NA d.

Issue Commission paper (NRR).

NA e.

Cognizant Federal agencies notified (i.e., FEMA, NA EPA, DOJ).

f.

State and local officials notified (Region).

NA g.

Congressional notification (NRR)

NA B.3~

ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS a.

Establish the Restart Panel.

X C

b.

Assess available information (i.e. inspection results, X

C RAP licensee self-assessments, industry reviews).

c.

Obtain input from involved parties both within NRC X

RAP and other Federal agencies such as FEMA, EPA, RA DOJ.

d.

Conduct RA briefing.

X C

RAP e.

Conduct NRR Executive Team briefing (NRR).

X C

RAP f.

If required, develop the case-specific checklist X

C RAP (CSC).

g.

Develop the Restart Assessment Plan.

X C

RAP REVISION 6 November 18,1998 1

4

NEED STATUS RESP h.

Director, inspections approves Restart X

C R1 Assessment Plan.

l.

NRR Director approves Restart Assessment Plan.

X C

DNRR J.

Implement Restart Assessment Plan.

X RAP k.

Modify order as necessary X

NRR B.4 -

l REVIEW IMPLEMENTATION l

l l

B.4.1 Root Causes and Corrective Actions osTi RAP a.

Evaluate findings of the special team ir6spection.

X b.

Licensee performs root cause analysis and develops X

NU corrective action plan for root causes.

0sTi 49, 9 c.

NRC evaluates licensee's root cause determination X

RAP and corrective action plan.

osT

,gg 4

J 4

c-REVISION 6 November 18,1998 5

s

l lNEED fSTATUS RESP l

B.4.2 -

B.4.2 Assessment of Eauioment Damaae NA 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 l

the result of an internal event. The need for independent NRC assessment 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 ensure performance to design requirernents.

Potential offsite emergency response impact for external events such as natural disasters, explosions, or riots should be considered. NRR should obtain information from FEMA headquarters reaffirming the adequacy of State and local offsite emergency plans and preparedness if an event raises reasonab!: doubts about emergency response capability.

a.

Licensee assesses damage to systems and NA components.

b.

NRC evaluates licensee damage assessment.

NA c.

Licensee determines corrective actions.

NA d.

NRC evaluates corrective actions.

NA B.4.3 Determine Restart issues and Resolution X

RAP l

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 section outlines l

steps to determine the restart issues and NRC's evaluation l

of their resolution.

REVISION 6 November 18,1998 6

l

l NEED STATUS RESP a.

Review / evaluate licensee generated restart issues.

X RAP b.

Independent NRC identification of restart issues X

C RAP c.

NRC/ licensee agreement on restart issues.

X C

RAP d.

Evaluate licensee's resort issues implementation X

C RAP process.

e.

Evaluate licensee's implementation verification X

SRI-SIL process.

40500 OSTI

.- g._;_=_.... __._.__._;_;. _. _. - _., ;.:.. _. ; _

; _. _ _ ; = ;_;.=_ ;.;_ ;; - - _ _;..;. ;.. _.=

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 1

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.

a.

Obtain public comments.

X C

RAP i

b.

Obtain comments from State and Local Officials X

C Regional (Region).

SLO / RAP c.

Obtain comments from applicable Federal agencies.

X C

RAP l

REVISION 6 November 18,1998 7

NEED GTATUs RESP B.4.5.

Closeout Actions L

F

-When the actions to resolve the restart issues and -

significant concerns are substantially complete, closecut actions are needed to verify that planned inspections and verifications are complete. The licensee should certify that corrective actions required before restart are complete and that the plant is physically ready for restart. This section l

provides actions associated with completion of significant NRC reviews and preparations for restart.

RAP a.

Evaluate licensee's restart readiness osTI self assessment.

X b.

NRC evaluation of applicable items from Section C X

RAP

'"lSSUES" complete.

c.

Restart issues closed.

X RAP SRI oSTI d.

Conduct NRC restart readiness team inspection.

X osTI e.

Issue augmented restart coverage inspection plan.

X osTI RAP f.

Comments from other porties considered.

X RAP l.

g.

Determine that all conditions of the Order / CAL are X

RAP satisfied.

ICAVP Re-review of Generic Restart Checib complete.

h.

X RAP SRINU L

B.5 RESTART AUTHORIZATION (B.5)

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?"

l l

a.

Prepare restart recommendation document and basis for restart.

X RAP 1

1

' REVISION 6 November 18,1998 8

i j

NEED STATUS RESP b.

NRC Restart Panel recommends restart X-RAP H

c.

No restart objections from other applicable HQ X

NRR (L)

. offices.

d.

No restart objections from appliceble Federal X

RAP agencies.

e.

RA concurs in restart recommendation X

RA f.

NRR Director concurs in restart recommendation.

X NRR (L) g.

EDO concurs in restart recommendation when NA

required, h.

Conduct ACRS briefing when requested (NRR).

NA 1.

Conduct Commission briefing when requested.

X DSPO J. -

Commission approves restart.

X couM k.

EDO authorizes restart.

X EDO B.6 RESTART AUTHORIZATION NOTIFICATION (B.8)

Notify the applicable parties of the restart authorization.

i Notifications should generally be made using a memorandum or other format consistent with the level of formality required. Communication of planned actions is important at this stage to ensure that NRC intentions are clearly understood.

a.

Commission (if the Commission did not concur in

= the Restart Authorization or as requested) (NRR).

NA 2

b.

EDO (if the EDO did not concur in the restart NA recommendation or as requested) (NRR).

c.

Congressional Affairs (RAP).

X ocA d.

ACRS (a brieilng may be substituted for the written notification if the ALRS requests a briefing) (NRR).

e.

Applicable Federal agencies.

X RAP f.

Public Affairs.

X OPA g.

State and local officials.

X sto REVISION 6 November 10 1998 9

-\\

L' _. __. _

_. = _ _ _..

u L-l L,

NEED STATUS RESP w

h.

Citizens or groups that expressed interest during the-X RAP restart approval process.

i l.

Issue staff concerns memorandum.

X RAP I

1 C.1.1:

Root Cause Assessment a.-

Conditions requiring the shutdown are clearly X

C RAP l

un' erstood.

d i

b.

Root causes of the conditions requiring the X

.C RAP shutdown are clearly understood, c.-

Root causes of other significant problems are clearly X

C RAP understood.

I i

d.

Effectiveness of the root cause analysis program..

X 40500 i

RAP-l OSTI C.1.2 Damaae Assessment a.

' Damage assessment was thorough and NA l

comprehensive.

b.

Corrective actions clearly restored systems and NA equipment or verified they can perform as designed.

L C.1.3 -

Corrective Actions L

a.

Thoroughness of the corrective' action plan X

RAP 40500

b. -Completeness of corrective action programs for X

SRI o

specific root causes.

40500 i' '

i l-L Control of corrective action item tracking.

X SRI c.

OSTI 40500 d.

Effective corrective actions for the conditions X

SRI l

requiring the shutdown have beer: implemented.

oSTI l

e.

Effective corrective actions for other significant X

SRI problems have been implemented.

OSn ICAVP 40500 j

u 6-

[

REVISION 6 November 18,1998 10 I

i i

l' NEED STATUS RESP f.

Control of long-term corrective actions.

X SRI (Backlog Management Plan)-

OST 40500 g.

Effectiveness of the corrective action verification X

SRI process.

OSTI 40500 C.1.4 Self Assessment Canability 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 effectiveness in ensuring effective self-assessment is treated separately.

s.

Effectiveness of Quality Assurance Program.

X RAP 40500 b.

Effectivn s of industry Experience R. view X

OST Program.

40500 c.

Effectiveness of licensee's Independent Review X

SRI Groups.

OSTI 40500 d.

Effectiveness of deficiency reporting system.

X SRI oSTI 40500 1

e.

Staff willingness to raise concerns.

X NRR (L)

)

RAP f.

Effectiveness of PRA usage.

X OST 40500 g.

Effectiveness of commitment tracking program.

X SRI RAP 40500 l

h.

Review applicable external audits X

OSTI 40500 1.'

Ouality of 10 CFR 50.72 and 50.73 reports.

X SRI p.

i

)

REVISION 6 November 18,1998 l

11 1

i l

l

... -.,. - -. ~

L l

.i l NEF.D l STATUS' h RESP

)

C.2.1 =

, Manaamment Oversiaht and Effectiveness- -

-l l-1

-i<

'a.-

" Goals / expectations communicated to the staff.

-X OST: -

-l 40500 I

b.

Demonstrated expectation of adherence to -

X SRI l;

procedures, oSTI c.

Management involvement in self-assessment and X

RAP l

independent self-assessment capability 40500 d.-

Fffectiveness of management review committees, i

X SRI OSTI 40500 l:

e.

Management's demonstred awareness of X

SRI day-to-day operational conce;ns.

OSTI L

f.

2 Management's ability to identify and prioritize X

SRI l

significant issues.

OSTI 40500

}-

g.

Management's ability to coordinate resolution of X

SRI significant issues.

OSTI 40500 h.

. Management's ability to implement effective

-X SRI L

corrective actions.

oST 40500 C.2.2.

Manaaement Sunoort a.

impact of any management reorganization.

X RAP 40500 f

b.

. Effective and timely resolution of employee X

RAP concerns.

NRR (L)

SCWE c.

Adequate engineering support as demonstrated by X

DRS timely resolution of issues.

OSTI I

ICAVP d.

Adequate plant administrative procedures.

X SRI i

40500 l

j.!

OSTI e.

Effective information exchange with other utilities.

X SRI l _., -

OSTI J

40500 f.'

Participation in industry groups.

NA

. Effectiveness of Emergency Response Organization.

X DRS j

g.

REVISION 6 November 18,1998 r

12 i

L i

v. -

I Y

r,

=

r

~

~ - = "

~ ' - '

' " " ~

i 1

NEED STATUS RESP 4

=h.

cCoordination with offsite emergency planning X

DRS l

officials.

C.3.1 Assessment of Staff RAP a.

' Demonstrated commitment to achieving improved X

SRI performance.

oSTI b.

Demonstrated safety consciousness.

X OSTI SRI NRR (L)

SWCE c.

Understanding of management's expectations and X

OST goals.

40500 d.

Understanding of pl' ant issues and corrective X

oSTI actions.

SRI 40500 e.

Qualifications and training of the staff.

X OSTI f.

Staff's fitness for duty.

14A

g. -

Attentiveness to duty.

X oST h.

Level of attention to detail.

X OST 1.

Off-hour plant staffing.

X SRI J.'

Staff overtime usage.

X SRI 40500 k.

Procedure usage / adherence.

X' SRI OSTI 40500 1.

' Awareness of plant security.

X DRS m.

Understanding of offsite emergency planning issues.

X DRS 3

C.3.2 Assessment of Coroorate Suncort and Site Enaineerina Suonort X

OSTI a.

Corporate staff understanding of plant issues.

b.

Corporate staff site specific knowledge.

X o:T' L

c.

Effectiveness of the corporate / plant interface X

OSTI l-meetings.

l';

r d.

Corporate involvement with plant activities.

X OSTI L

REVISION 6 November 18,1998 t

l 13 I

NEED STATUS RESP e.

Effectiveness of site engineering support.

X DRS OSTI ICAVP f.

Effectiveness of the site design modification X

ICAVP process.

oSTI g.

Effectiveness of licensing support.

X RAP h.

Coordination with offsite emergency planning X

DRS officials.

C 3.3 Operator issues a.-

Licensed operator staffing meets requirements and licensee goals.

X DRS

b..

Level of formality in the control room.

X oSTI SRI c.

Effectiveness of control room simulator training.

X DRS d.

Control room / plant operator awareness of X

oSTI equipment status.

SRI e.

Adequacy of plant operating procedures.

X SRI ICAVP oSTI f.

Procedure usage / adherence.

X SRI oST:

g.

Log keeping practices.

X OST C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT a.

Operability of technical specification systems.

X OSTI b.

Operability of required secondary and support X

OSTI

systems, c.

Results of pre-startup testing.

X SRI OSTI d.

Adequacy of system lineups.

X OST e.

4dequacy of surveillance tests / test program.

X oST f.

eiignificant hardware issues resolved (i.e. damaged X

oSTI n quipment, equipment ageing, modifications),

g.

v.dequacy of the power ascension testing program.

X oSTI SRI REVISION 6 November 18,1998 14

NEED STATUS RESP h.

Effectiveness of the plant maintenance program.

X OSTI DRS i

l l

1.

Maintenance backlog managed and impact on X

OSTI operation assessed.

l

[:

J.

'" Adequacy of plant housekeeping and equipment.

.X OSTI I

storage.

C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY I

REQUIREMENTS l

l-a.

Applicable license amendments have been issued.

X RAP b.

Applicable exemptions have been granted.

X RAP c.

Applicable reliefs have been granted.

X RAP l

d.

Imposed Orders have been modified or rescinded.

X RAP l

e.

Significant enforcement issues have been resolved.

X RAP OE f.

. Allegations have been appropriately addressed.

X

. RAP SRI PE l-g.

10 CFR 2.206 Petitions have been appropriately X

NRR (L) addressed.

h.

Atomic Safety and Licensing Board hearings have NA No ASLB i

been completed.

hearing required before restart L

C.6 COORDINATION WITH INTERESTED AGENCIES AND l

PARTIES l

a.-

-Federal Emergency Management Agency X

DRS NRR (L) b.

' Environmental Protection Agency NA f

c.

Department of Justice X

OE 01 RA d.

Department of Labor X

OE e.

Appropriate State and local officials X

SLO f.

Appropriate ;;uldic interest groups X

RAP l

g.

Local news media X

OPA l

l l

J

\\

4 REVISION 6 November 18,1998 15 i

(

MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (3)

LICENSING ISSUES REQUIRED FOR RESTART OF UNIT 2 l

i l

l TAC No.

Issue Status 1

M97746 Meteorological Tower Instrumentation (TSs) 12/16/97 CW I

Mode-N/A (Withdrawn) 2 M98277 Ultimate Heat Sink Temperature (TSs) 02/06/98 CA Mode 4 3

M98347 Enclosure Building (TSs) 09/30/97 CA Mode 4 4

M94623 Containment iso Valve List Removal from TSs 11/19/97 CA Mode 4 (TSs) 5 M92879 Control Rm Emergency Ventilation Sys (TSs) 08/16/98 CW Mode 4 (Withdrawn) 6 M99543 EDG Fuel Oil Supply Adequacy License Amendment 01/23/98 CA Mode 4 (USQ) 7 MA2340 ESFAS and RPS - Setpoints & Allowable Values Under Review Mode 4 (TSs)

TS (01/15/99T) 8 MA0121 RCS P-T Curves (TSs) 07/01/98 CA Mode 4 9

M99503 Max. Containment Pressure Limit (TSs) 10/27/97 CA Mode 4 10 M99504 Technical Specification - Verbatim Compliance 05/26/98 CA Mode 4 (TSs) 11 M94105 Steam Generator Blowdown Monitors (TSs) 08/26/97 CA Mode 4 12 M99609 Rx Trip Setpoints - SG Safety Valves (TSs) 11/19/97 CA Modes 1-3 l

13 M97680 Siemans LOCA Analysis-Evaluation (non TS) 07/23/97 CA l

Mode 4 l

l 14 M99266 Startup Rate Trip (non TS) 08/19/97 CA Mode 4 l

15 M99296 Hydrogen Monitors - NUREG-0737 (non TS) 10/28/97 CA Mode 4 16 M99613 RG 1.97 - Core Exit Thermocouples (CETs) Power 01/12/98 CA Mode 4 Supply Modifications (non TS)

REVISION 6 November 18,1998 l

l l

17 MA2416 Extmption rsqu2st - App ndix R Undsr Revisw Mode 4 (4 - Exemption requests needed)

(EX)

TS (12/31/98T) 18 MA0251 Compliance for CEA Rod Drop Testing & Design 06/16/98 CA Mode 2 Section Updates (TSs) 19 M99614 ATWS - Commitment Withdrawal 10/29/98 CA Mode 4 RAI issued (01/23/98)

(non TS) 20 MA2441 Condensate Storage Tank Volume (TSs)

Under Review - PM Mode 4 (12/31/98T) 21 MA1554 Trisodium Phosphate (TSP) Volume (TSs) 06/22/98 CA Mode 3 22 MA1649 Low Range Press Xmitters Diversity (USQ)

Will be withdrawn Mode 4 (12/30/98T) 23 MA2255 Service Water Sys Protective Coating (USQ)

Under Review TS Mode 4 (12/30/98T) 24 MA1771 Continuous Bypass inop Ch RPS/ESFAS (TSs) 11/10/98 CW Mode 4 25 MA3553 RCS Head Vent Surveillance Compliance issues # 4 Under Review - PM Mode 4 (TSs)

(01/15/99T) 26 MA1462 MSIV & Pressurizer Surveillance (TSs) 08/21/98 CA Mode 4 27 MA1137 RG 1.97 Deviation Variable D23 CAR Fans 04/30/98 CA Mode 4 (non TS) 28 MA 1066 ATWS Pressure Instruments (non TS) 04/30/98 CA Mode 4 29 MA1070 Leak-Before-Break Reanalysis-Cold Leg (non TS) 10/06/98CA Mode 4 30 MA2367 Leak-Before-Break (Si & SDC sys)

(non TS) 10/06/98CA Mode 4 31 MA0838 Emerg. Prepareoness Pirn, Rev 24 (non TS) 06/04/98 CA Mode 4 32 M83642 IPEEE - Fire Protection issues (Turbine Building)

Under Review TS Mode 4 (non TS)

(12/30/98) 33 MA3410 Siemens MSLB - Reanalysis Methodology Change Under Review - TS Mode 4 (TSs)

(12/30/98T) 34 MA2311 EDG Surveillance Requirements & GGC-17 TS Under Review TS Mode 4 Clarification (TSs)

(01/30/99T) 35 MA3955 Shutdown Cooling Sys Relief Valve (TSs)

Under Review Mode 4 TS ( 12/31/98T)

REVISION 6 November 18,1998 2

_._m_

36 Boron Precipitation Hot irg inj Singla Failure -

12/15/98T Mode 4 (USO) 37.

Long Term CST Makeup via FW Sys.

(USO)

Not required to be L

Mode 4 submitted (no USO.

involved).

U 38.

MA3672.-. Cont. Rm. Ventilation DBA Calcus.

-. (TS & USO)-

Under Review - TS Mode 4 (12/30/98T) 39 Passive Failure - ECCS Piping Post LOCA Not required to be Mode 4 (USG) submitted (no USQ involved).'

40 MA4126 Leak Before Break - Press Surge Line (non TS)

Under Review Mode 4 TS (02/26/99T) 41 Mode 4 Separation - Raceways (USO) 1/5/99T 42 MA3671 Separation - Control Panel 12' to 6" (USQ)

Under Review TS Mode 4 (12/30/98T) l 43 MA3392 Ampacity Derating (GL92-01)

(non TS)

Under Review TS Mode 4 (02/15/99T) 44.

MA4175 SG Tube Rupture - Reanalysis (USO)

Under Review

.i Mode 4 45 Mode 4 Loss of Feedwater - Reanalysis (USO)

Submittal date TBD.

46' MA4150 Continuous Bypass inop Ch RPS/ESFAS Under Review Mode 4 (TSs)

TS (12/31/98T) 47 Mode 4 USQ - Hydrogen Purge (Backup to Recombiners) 12/15/98T

)

48' Mode 4 TS Change - ECCS Pump Flow Requirements (will refer 12/15/98T to IST program instead of having values in TS) l

SUMMARY

e 48 licensing issues - 23 TS amendments,13 other licensing actions,1 Exemp. and 11 USQs e

22 are complete - 11 TS amendments,1 USQ, and 10 other licensing actions e

3 withdrawn - 3 TS Amendments e

2 were determined, upon further review, to not be USQs and will not need NRC

_ approval, e

21 remaining - 16 are under review and 5 have not been submitted.

I REVISION 6 November 18,1998 3

c