ML20197A890
| ML20197A890 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/16/1997 |
| From: | Leach M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9712230234 | |
| Download: ML20197A890 (51) | |
Text
Pusdc December 16, 1997 MEMORANDUM TO:
A. B. Beach, Regional Administrator Orig. signed by FROM:
M. N. Leach, Chief, Operator Licensing Branch John M. Jacobson for
SUBJECT:
LASALLE STATION RESTART ACTION PLAN The NRC Performance improvement Review Panel for LaSalle Station is using NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," for oversight activities for LaSalle Station. The LaSalle Plant Performance Review Panel has initiated the implementation of the MC and, as a result, has developed the attached Restart Action Plan and submits it for your review and approval. Several dates for NRC verification described in the plan are given as
" targets." These dates are dependent upon the licensee's restatt schedule and will be updated as the licensee is able to provide more accurate startup scheduling information. The Restart Action Plan status will be updated on an as required basis. Minor revisions will be made by the Panel, as appropriate, without seeking additional formal approval from you.
The Restart Action Plan consists of three sections. The first section, " General," provides the purpose of the Plan and background information. The second section," Case Specific Checklist -
Part 1," includes the MC 0350 checklist of items to consider during the overall review process for coordination of the NRC authorization for restart of LaSalle. The third section," Case-Specific Checklist - Part II," includes the MC 0350 checklist for assessment of the issues that the Panel considers Integral to the shutdown and which require NRC assessment prior to restart.
Your concurrence is consiaered approval for implementation and distribution.
/6l/f.6,beacb
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A.B. Beach Date Regional Administrator, Region lli Docket Nos:
50-373;50-374
Attachment:
LaSalle Station Restart Action Plan i
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CONTACT: David Hills, DEH l;
63'1829-9733 See Attached Distribution DOCUMENT NAME: G:/ lass /0350 plan.las SEE PREVIOUS CONCURRENCES To receive a copy of this document, Indicate in the box "C" = Copy w/o attach /enct "E" = Copy w/ attach /enci"N" = No copy OFFICE Rill l
Rill l
Rlli l
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NAME Vogel Leach Grobe Grant (d(j' DATE 12/
/97 12/
/97 12/
/97 12/ 174 ) ($7 OFFICE NRR l
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NAME Capra Zimmerman BeettM l
DATE 12/
/97 12/
/97 12/ l(,
/97 l
OFFICIAL RECORD COPY
..n 9712230234 971216 PDR ADOCK 05000373 P
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December 16 1997 0
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MEMORANDUM To:
A. S. Beach, Regional Administrator FROM:
M. N. Leach, Chief, Operating Lloonsing Branch ho M
b n for
SUBJECT:
LASALLE STATION RESTART ACTION PLAN i
The NRC Performance improvement Review Panel for LaSalle Station is using NRC inspection Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," for oversight activities for LaSalle Station. The LaSalle Plant Posformance Review Panel has initiated the implementation i
of the MC and, as a result, has developed the attached Restart Action Plan and submits it for your review and approval. Several dates for NRC vertnostion described in the plan are given as
" targets." These dates are dependent upon the licensee's restart schedule and will be upda'1 l
as the licensee is able to provide more accurate startup scheduling information. The Restart i
Action Plan status will be updated on an as required basis. Minor revisions will be made by the Panel, as appropriate, without seeking additional formal approval
- rom you.
The Restart Action Plan consists of three sections. The first section, " General," provides the purpose of the Plan and background information. The second section, " Case-Specific Checklist -
Part I," includes the MC 0350 checklist of items to consider during the overall review process for coordination of the NRC authorization for restart of LaSalle. The third section, " Case-Specific Checklist - Part 11," includes the MC 0350 checklist for assessment of the issues that the Panel considers integral to the shutdown and which require NRC assessment prior to restart, j
Your concurrence is considered approval for implementation and distribution.
A.B. Beach Date
)
Regional Administrator, Region lli Docket Nos: 50 373; 50-374
Attachment:
LaSalle Station Restart Action Plan CONTACT: David Hills, DEH l
630/829-9733 See Attached Distribution DOCUMENT NAME: G:/lasa/0350 plan.las To reoelve a oopy of this document, indicate in the box "C" = Copy w/o attach /enci "E" = Copy w/ attach /enci"fr = No copy OFFICE Rlli lG Rill I&
Rlli nrh lA Rlli l
NAME Vegei &
Leach Mn W GrobeLP Grant DATE 12/ I l /97 12/ I 2.
/97 12/ 6 \\ /97 12/
/97 OFFICE NRR l
NRR l
Rlll l
l NAME Capra Zimmerman Beach OATE 12/
i97 12/
/97 12/
/97 OFFICIAL RECORD COPY E
- - ~
l December 16, 1997 MEMORANDUM To:
A. B. Beach, Regional Administrator FROM:
M. N. Leach, Ch iconsing Branch M*MNMNn for
SUBJECT:
LASALLE STATION RESTART ACTION PLAN The NRC Performance Improvement Review Panel'or LaSalle Station is using NRC inspection
- Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," for oversight activities for LaSalle Station. The LaSaue Plant Performance Review Panel has initiated the implementation i
. of the MC and, as a result, has developed the attached Restart Action Plan and submits it for your review and approval. Several dates for NRC verification described in the plan are given as
" targets." These dates are dependent upon the licensee's restart schedule and will be updated as the licensee is able to provide more accurate startup scheduling information. The Rc9ast Action Plan status will be updated on an as-required basis. Minor revisions will be made v, the Panel, as appropriate, without seeking additional formal approval from you.
The Restert Action Plan consists of three sections. The first section, " General," provides the purpose of the Plan and background information. The second section, " Case-Specific Checklist Part 1," includes the MC 0350 checklist of items to consider dunng the overall review process for coordination of the NRC authorization for restart of LaSalle. The third section," Case-4 Specific Checklist Part il," includes the MC 0350 checklist for assessment of the issues that the Panel considers integral to the shutdown and which require NRC assessment prior to restart.
P Your concurrence is considered approval for implementation and distribution.
A.B. Beach Date Regional Administrator, Region lli Docket Nos: 50-373;50-374
Attachment:
LaSalle Station Restart Action Plan CONTACT: David Hills, DEH 830/829-9733 See Attached Distnbution DOCUMENT NAME: G:/lasa/0350 plan.las To receive a copy of this document, Indicate in the box "C" = Copy w/o attach /end "E" =
Copy w/ attach /enci"N" = No copy OFFICE -
Rill -
Rill Rill Rlli NAME Vogel Leach Grobe Grant DATE 12/
7
- 12/
/97 12/
- /97 12/
/97 um m mm-unmium m musu-muni OFFICE NR e.
NRR arg-Rill NAME_
04M 6e ZimmerMan Beach DATE T12co le7 12/i;;t /s7 12/
/97
. Ear 20*d CO:9I 466T-2T-330
7 4
A. Beach 2
Distritmuon:
- 8. Collms, NRR B. Sheron, NRR E. Adonsam, NRR R. Capra, NRR F. Miraglia, NRR R. Zimmerman, NRR Project Manager, NRR G. Tracy, OEDO Deputy RA, Rlli D. Hills, Rill Docket File PUBLIC -
SRI LaSalle m
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MSALLE STATION RESTART ACTION PLAN 2
A.
G E NE RA L _.......................................................... 1 A.1 P UR POS E.................................................... 1 A.2
' 08J ECTIVES................................................. 1 A.3 BACKGROUND................................................ 1 A.4
' ACT IVITI ES.................................................. 2 A.5 OVERALL NRC VERIFICATION STRATEGY.......................... 2 8.
CASE-8PECIFIC CHECKLIST PART I (PROCE88).......................... 3 8.1
. INITIAL NRC REGPONSE....................................... 3 8.2 NOTIFICATIONS............................................... 4 8.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS............. 4 8.4 REVIEW IMPLEMENTATION...................................... 6 8.4.1 Root Causes and Corrective Actions........................... 6 8.4.2 Assessment of Equipment Osmage........................... 7 8.4.3 Determine Restati Issues and Resolution....................... 7 W.4.4 - Obtain Comments......................,.................. 8 8.4.5 Closeout Actions.......................................... 8 8.5 RE8 TART AUTHORIZATION....................................... g
- B.6 RESTART AUTHORIZATION NOTIFICATION........................ 10 C.
- CASE SPECIFIC CHECKLIST - PART 11 (ISSUES).......................... 11 C.1
' ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION,.. 11 C.1.1 Event Analysis and Root Cause Assessment.,,................ 11 C.1.2 Corrective Action Development.............................. 11 C.1.3 Corrective Action Plan implementation and Effectiveness.......... 13 C.2 LICENSEE SELF ASSESSMENT AND MANAGEMENT EFFECTIVENESS. 16
- C.2.1 Self Assessment Capability.....,,......................... 16 C.2.2 Management Oversight and Effectiveness,.....,.............. 17 C.2.3. Management Support..................................... 20 C.3 ASSESSMENT OF PLANT AND CORPORATE STAFF EFFECTIVENESS,.. 21 C.3.1 Assessment of Staff...................................... 21 C.3.2 Assessment of " Corporate" Support........,,................ 23.
C.3.3 Operator issues......................................... 2 3 C.3.4 Engineering Support to Operations........................... 26 C4 ASSESSMENT OF PHYSICAL READINESS OF THE PMNT............ 27 C.5 ASSESSMFNT OF COMPLIANCE WITH REGUMTORY REQUIREMENTS. 32 C.6 COORDINATION WITH INTERESTED ACENCIES AND PARTIES....,.. 33 C.7 ADDITIONAL PLANT SPECIFIC ISSUES AND INSPECTION ITEMS....... 34 i
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1 A.
GENERAL A.1 PURPOSE To provide a basis to plan and coordinate NRC review activities for restart of LaSalle Station, Unit 1. While many of the activities in the licensee's Restart Plan apply to Unit 2, this Action Plan describes those actions that will be taken to address the restart of Unit 1.
A.2 OBJECTIVES To ensure that NRC review efforts are consistently developed, communicated, and implemented and specific guidance is provided to support:
a.
Determining restart issues for review, b.
Identifying the basic tasks needed to review and approve plant restart, and c.
Coordinating and tracking restart review activities.
A.3 BAQKGROUND l
LaSalle Station was on the NRC's watch list from April 1986 until October 1986. Due to declining perfomiance the NRC issued trending letters to LaSalle Station in January and June of 1994. In May 1996, a risk significant service water event occurred involving the injection of large quantities of expandable foam sealant into the safety-related service water tunnel, rendering the essential service water system inoperable for both units. The NRC issued a Confirmatory Action Letter (CAL), No. Rlll 96-008 and Supplement No. Rlll-96-008A to address the issues at LaSalle involving the sealant injection event. The event provided the NRC with insights into LaSalle Station performance which indicated that significant performance weaknesses continued to exist in a number of areas. This event coupled with other design, hardware, and personnel performance issues, indicated that previous efforts to improve performance were not successful.
On October 17,1996, the NRC issued a SALP report for LaSalle with ratings of 3 in all areas except plant support which represents a decline from the previous evaluation period.
To address continuing performance deficiencies, Commonwealth Edison management contracted to have an Independent Safety Assessment (ISA) conducted at LaSalle Station in the fall of 1996. The ISA was conducted by a team of industry peers and Institute of Nuclear Power Operations representatives. The team's charter was to determine why previous improvement initiatives at LaSalle Station had not been successful and the ISA confirmed many of the performance deficiencies identified by the NRC. In September 1996, the NRC conducted a Safety System Operational Performance inspection (SSOPI) of the service water system. The team identified a number of deficiencies in the areas of design basis understanding, maintenance practices, and testing.
In September 1996, both units were shutdown; Unit 1 to repair a turbine control valve and Unit 2 for a refueling outage in December, a decision was made to further extend the outages for both units to address performance issues identified by the NRC, the licensee, and the ISA. The licensee developed a Restart Plan to implement improvements in operations, engineering, plant material condition, human performance, and the corrective action process. Included in the Restart Plan is the performance of system functional reviews. These reviews have been completed by the licensee and have revealed deficiencies which affected the ability of some systems operability to perform their function under certain circumstances.
i.
Based on continuing performance problems, the NRC placed LaSalle Station on the NRC's watch list in January 1997. Following the Senior Management Meeting (SMM) and Commission briefing, the NRC decided to implement an oversight panel for LaSalle. On April 14,1997, a Plant Performance Review Panel, consisting of regional and headquarters personnel, was established, in addition, a CAL Supplement, No. Rlll 96-0088, was issued following the ISA to formalize the licensee's commitments to address deficiencies in material condition, human performance, corrective action process, and engineering support and design deficiencies prior to restart.
A.4 ACTMTIES A comprehensive NRC review of the restart process is required. This Restart Action Plan is intended to include expected NRC sctions that will be required to be taken before restart of LaSalle Station. The Plan defines: the actions which must be accomplished by the NRC, as a minimum, to approve restart; the orgardzation that has the lead responsibility for each action; the case specific issues which must be resolved before restart; and the individuals with the actual responsibility for restart approval. The Panel retains responsibility for assessment of the restart issues and determining whether each issue has been satisfactorily addressed. The Panel will make updates and minor revisions to the Restart Action Plan. Restart Panel meetings will be documented on minutes to include restart issues reviewed.
Section B," Case Specific Checklist - Part 1," of this plan provides generic tasks that support the Restart Action Plan. This section outlines the overall review process needed for the NRC to authorize restart of the facility. Section C, " Case Specific Checklist Part II," contains issues requiring assessment during the restart review. Within the scope of each issue are numerous elements or examples supporting the broader issues which were the causos for the shutdown. It will not be necessary for each element or example on the checklist to be assessed, but enough items must be reviewed to make an assessment that the issue has been sufficiently resolved to support plant restart. Each of the checklists in Section B and C includes columns to record the NRC organization with lead responsibility for the Item and the date and mochanism by which the item was or will be closed The Panelis responsible for implementation of the LaSalle Restart Action Plan. The Panel will maintain and periodically review the Restart Action Plan. These actions should: (1) determine review status, (2) verify necessary tasks and items are complete for each phase of the review, and (3) er,sure that review tasks and issues for assessment remain consistent with the known facts and status of the rectart effort. The lists in Sections B and C should be reviewed when significant milestones are completed and prior to restart authorization to ensure any emerging items are considered.
A.5 OVERALL NRC VERIFICATION STRATEGY The Panelis responsible for reviewint, status and rationale for closure of all Case Specific Checklist issues. Verifications performed by the Panelitself (such as review of the LaSalle Rectart Plan) will be documented in the Case Specific checklist and supplemented as needed in the Panel meeting minutes.
Several of the verification items in the Case Specific Checklist will be completed in the routine inspection program by the resident and regional staff. In addition, the NRC will conduct inspections in the areas of engineering and technical support, self assessment and corrective 2
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4 o
actions, operator licensing, and inservice testing of pumps and valves. These verifications will be documented in the inspection reports.
A Restart Readiness Assessment Team inspection will be conducted by a Region lil inspection team near or after the licensee has informed the NRC (in accordance with the CAL) that the plant is ready to restart. This inspection will be a modified Operational Readiness Assessment Team / Operational Safety Team inspection and will evaluate areas delineated in the Case-Specific Checklist, as well as other perfomiance concems designated by the Panel. The inspection may encompass some performance areas not addressed in the LaSalle Restart Plan or NRC case-specific checklist, es determined by the Panel, to ensure that the current scope and significance of previously identified performance problems should not preclude safe plant startup and operation. The Restart Readiness Assessment Team will be organized and led by Region ill Division of Reactor Safety personnel. These efforts will be documented in an inspection report.
B.
CASE SPECIFIC CHECKLIST - PART I fPROCESS)
B.1 INITIAL NRC RESPONSE Establishment of the facts, the causes, and their apparent impacts should be accomplished early in the process. This information will assist the NRC in characterizing the problems, the safety significance, and the regulatory issues. Early management appraisal of the situation is also important to ensure the proper immediate actions are taken. Many of these items may already be complete when the initial checklist review is perfonned.
TASKS a.
Initial notification and NRC management discussion of known facts and issues (Region).
STATUS:
COMPLETE LaSalle Performance Review Panel established and Charter issued 4/15/97.
c.
Determine need for formal regulatory response (i.e. order or CAL).
STATUS:
COMPLETE Supplemental CAL Rill 96-008B issued 4/14/97. CAL requires licensee to docket its Restart Plan to address performance deficiencies; keep the NRC informed of proposed startup dates; and meet with the NRC monthly, after completing the licensee initiated High Intensity Training (HIT) of operators, and when ready to restart the first unit.
d.
Identify other parties involved (i.e., NRC Organizations, other Federal agencies, industry organizations).
STATUS:
COMPLETE lilinois Department of Nuclear Safety involved.
3 1
4 1
B.2 NOTIFICATIONS Initial notification of the event quicMy communicates NRC's understanding of the event and its immadiate response to the parties having an interest in the event. Notification to Regional and headquarters offices of cognizant Federal agencies may be appropriate. As the review process continues, additional and continuing notifications may be required.
TASKS a.
Issue Daily and Directors Highlight (NRR).
STATUS:
COMPLETE Directors Highlights issued 10/2/96 and 11/20/96.
b.
Issue preliminary notification (Region).
STATUS:
COMPLETE Preliminary Notifications (PNs) PNO 111063, PNO-Rill g6-063A, PNO-Rill 96 074 issued.
f.
State and local officials notified (Region).
STATUS:
COMPLETE PNs PNO-111063, PNO-Rill 063A, anct PNO-Rill 96-074 issued. Press releases issued by public affairs.
g.
Congressional notification (NRR)
STATUS:
COMPLETE The House Commerce Subcommittee on Oversight and Investigations was notified of plant status during briefings by NRR and Region lil management on 8/25/g7.
B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS It will be necessary to establish and organize the NRC restart review to ensure the effective coordination of resources in evaluating the restart process. Effective interfaces within and outside the NRC are critical to properly identify and resolve the pertinent issues, Consider both Regional and headquarters offices of cognizant Federal agencies.
TASKS a.
Establish the Restart Panel.
STATUS:
COMPLETE t
4
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I l
A Restari Oversight Panel was established on 3/7/97 by a memo from J. Caldwell and G. Grant to Reactor inspection Staff / Supervisors. The licensee was notified by letter dated 3/12/97 of the NRC oversight efforts regarding LaSalle Station.
l l
The panel charter was issued on 4/15/97 by a memo from M. Leach to M. Dars.
j l
b.
Assess available information (i.e. Inspection results, licensee self assessments, industry reviews).
STATUS:
COMPLETE Information roviewed:
880Plinspection report (96011)
Independent Self Assessment Team report (2/18/97)
Commonwealth Edison (Comed) response to 50.54f letter (3/28/97) c.-
Obtain input from involved parties both within NRC ano other Federal agencies such as FEMA, EPA, DOJ.
STATUS:
COMPLETE input received from EDO, NRR, and Region Ill.
i d.
Conduct Regional Administrator briefing (Region).
STATUS:
COMPLETE Briefing conducted December 1996, s.
Conduct NRR Executive Team briefing (NRR).
STATUS:
COMPLETE Briefing conducted dudng January 1997 Senior Management Meeting (SMM).
- f. -
Develop the case-specific checklist (CSC).
STATUS:
COMPLETE 1
Panel approval on 11/20/97.
g.
Develop the Restart Action Plan.
STATUS:
COMPLETE Panel approval on 11/20/97. -
5
0 0
s' h.
Regional Administrator approves Restart Action Plan.
STATUS:
Open Prior to 12/17/97 Restart Panel Meeting.
J.
Implement Restart Action Plan.
STATUS:
Continuous k.
Supplement CAL necessary.
STATUS:
As necessary BA REVIEW IMPLEMENTATION The review will be accomplished by a variety of methods including inspections, testing, evaluation of licensee self assessments, evaluation of licensee action plans, and regulatory actions. Once the licensee has developed its corrective action plan, the NRC shall review that plan to verify its completeness and adequacy, The NRC will also determine which corrective actions will be required to be implemented before restart, and thus become restart issues, and those that can be deferred to some later date as long-term corrective actions. The discussions and isse as provided in Section C of this appendix provide additionalinformation to support the review activities described below.
B A.1 t_Causes and Corrective Actions TASKS a.
Evaluate findings of AIT, llT, or special team inspection.
STATUS:
COMPLETE No AIT was performed for this shutdown. However, the AIT in July 1996 identified several problems that are part of the licensee's Restart Plan, in addition, the Panel has evaluated findings from the SSOPl and !1\\.
b.
Licensee performs root cause analysis and davelops corrective action plan for root causes.
STATUS:
COMPLETE Licensee contracted a team for an Independent Self Assessment (ISA). The ISA team's report was issued to the NRC on 2/18/97.
Licensee's Restart Plan was submitted to the NRC on 5/22/97. Revision 1 A of the licensee's Restart Plan was submitted to the NRC on 8/27/97 and supplemented with more supporting details on 9/16/97.
6
c.
NRC evaluates licensee's root cause determination and corrective action plan.
RESPONSIBILITY:
Panel STATUS:
COMPLETE Panel review of the licensee's Restart Plan completed 11/20/97.
B.4.2 Assessment of Eaulomont Domsoe This section is not applicable to the situation at LaSalle Station. No equipment damage existed as the result of an event at the plant.
B.4.3 Determl01Restari Isse and Resolution TASKS a.
Review / evaluate licensee generated restart issues.
RESPONSIBILITY:
Panel STATUS:
COMPLETE Licensee letter dated 12/30/96 i rovided restart 't sues. CAL No. Rill 96-008B Issued after NRC review of the liansee's restart issues, b.
Independe.,t NRC Identification of restart issues (consider sources extemal to NRC and licensee).
STATUS:
COMPLETE As discussed in CAL No. Rlll 96-0088, NRC identified that the plant material conditior,, human performance problems, corrective action process, and engineering support and design deficiencian are issues that must be addrersed by the licensee prior to restarting the units, c.
NRC/ licensee agreement on restart issues.
STATUS:
COMPLETE As indicated in its Restart Plan dated September 16,1997, the licensee ames that the deficiencies identified by the NRC in its CAL must be addressed prior to restart.
d.
Evaluate licensee's restart issues implementation process.
STATUS:
COMPLETE Evaluation completed by the Par al on 11/20/97.
7
i e.
Evaluate licensee's implementation verification process.
STATUS:
COMPLETE Evaluation completed by the Panel on 11/20/g7.
B.4.4 Obtain Comments TASKS a.
Obtain public comments (Panel)
STATUS:
Ongoing NRC staff will be available to answer questions and receive comments from the public at all Restart Panel meetings.
b.
Obtain comments from state and local officials (Region),
STATUS:
Ongoing Illinois Department of Nuclear Safety (IDNS) Of'icials routinely interface with the NRC resident staff. In addition,IDNS officials attend the Restart Panel meetings open to the public and have the opportunity to interface with NRC management following the meetings.
B.4.5 ggitqui Actions TASKS a.
Evaluate licensee's restart readiness self assessment (Region).
STATUS:
Open Target date for completion is following notification by the licensee of its readiness for restart and prior to NRC/ licensee restart meeting, b.
NRC evaluation of applicable items from Section C "lSSUES" complete. (Panel)
STATUS:
Open Target date for completion 16 following notification by the licensee of its readiness for restart and prior to NRC/ licensee restart meeting, c.
Restart issues closed, STATUS:
Open 8
e Target date for completion is following notification by the licensee of its readiness for restart and prior to NRC/ licensee restart rneeting.
d.
Conduct NRC Restart Readiness Assessment Team inspection (Region).
STATUS:
Open Target date for completion is following notification by the licensee of its readiness for restart and prior to NRC/ licensee restart meeting.
e.
Issue augmented restart coverage inspection p!sn (Region).
STATUS:
Open Target date for cornpletion is following notification by the licensee of its readiness for restart and immediately following the NRC' licensee restart meeting, f.
Comments from other parties considered.
STATUS:
Ongoing NRC staff will romain available to answer questions and receive comments from the public and IDNS at all Restart Panel meetings. Target date for completion is following notification by the licensee of its readiness for restart and immediately following the NRC/ licensee restart meeting.
g.
Determine that all conditions of the Order / CAL are satisfied.
STATUS:
Open Target date for completion is following NRC/ licensee restart meeting.
h.
Re-review of Generic Restart Checklist complete.
STATUS:
Open A re-review is targeted for completion prior to the NRC/ licensee restart meeting.
B.5 RESTART AUTHORIZATION When the restart review process has reached the point that the issues have been identified, correc'ed, and reviewed, a restart authorization process is begun.
TASKS a.
Prepare restart authorization document and basis for restart.
STATUS:
Open 9
l l
r b.
NRC Restart Panel recommends Restart Authodzation (Panol).
l t
- STATUS:
Open 4
c.
No restart objections from applicable HQ offices (NRR).
STATUS:
Open j
i d.
No restart objections from applicable Federal apenoies (NRR).
j STATUS:
Open e.
Regional Administrator concurs in Restart Authorization (Region).
STATUS:
Open i
k.
Regional Administrator authorizes restart.
i STATUS:
Open j
All above tasks are targeted for completion following the NRC/ licensee restart meeting.
8.6 RESTART AUTHORIZATION NOTIFICATION
- Notify the applicable parties of the restart authorization.
TASKS i
a.
Commission (if the Commission did not concur in the Restart Authorization or as requested)(NRR).
i STATUS:
Open b.
EDO (if the EDO did not concur in the Restart Authorization or as requested)
(NRR).
STATUS:
Open j
!~
Congressional Affairs (i l t).
c.
?
STATUS:
Open d.
ACRS (a briefing may be substituted for the written notification if the ACRS requests a briefing)(NRR).
STATUS:
Open i
- f.
Public Affairs (Region).
i STATUS:
Open 10
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State and local offlolais (Region).
STATUS:
Open l
All above tasks are awgoted for completion following the NRC/ licensee restart meeting.
I C.
CASE 8PECIFIC CHECKLIST - PART ll flS8UES) r C.1 ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION The listing of applicable assessment ortteria provides the basis for NRC assessment of the effectiveness of the licensee's entrective action plan, i
C.1.1 Event Anahrsis and Root Cause Assessment a.
Conditions leading up to and eventually requiring the shutdown, including -
performance and process concems related to the shutdown, are understood.
STATUS:
COMPLETE On 8/14/97, the Panel verified that the licensee understood the conditions leading to the shutdown.
b.
Potential root causes of the conditions requiring the shutdown and any associated i
problems were thoroughly evalue"Al.
l STATUS:
COMPLETE i
Root causes for the problems were identified by the licensee in its evaluation of the service water event and were confirmed by the ISA team's evaluation. The licensee evaluated the conditions requiring shutdown while establishing its restart plan. The Panel concluded that the licensee evaluated root causes during panel meeting on 8/14/g7.
C.1.2 Corrective Action Development a.
The proposed corrective actions are clearty cross referenced to all of the i
asscciated root causes and causal factors they are intended to correct as appropriate, STATUS:
COMPLETE Although the Restart Plan does not directly reference the root causes identifed in the ISA report, the action plans address the root causes. Panel review completed on 11/20/97.
b.
Each of the corrective actions is assigned an appropriate priority based on safety significance to ensure the proper resources and attention are devoted.
STATUS:
COMPLETE i t i
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The licensee presented its criteda for determining those corrective actions that will be addressed pdor to restart in a meeting with the Panel on August 28,1997. The actions in the Restert Plan are not assigned a pdority as all of the actions are to be completed pdor to restart. Actions to be accomplished following restart will be addressed in the 1998 Operational Plan. Panel review completed on 11/20/97.
c.
Proposed corrective actions identify the desired conditions to be achieved and are adequate to preclude recurrence.
STATUS:
COMPLETE The action plans identify desired results under the strategy description. Panel review completed on 11/20/97.
d.
Corrective actions are sufficiently detailed to ensure that cil activities related to completion of the corrective action have been identified (i.e. procedure or drawing changes, Technical Specification changes, etc.)
STATUS:
COMPLETE At the request of the Panel, the licenses submitted detailed action plans in a letter dated September 16,1997. Panel review completed on 11/20/97.
e.
Corrective actions include restoring systems and equipment to service and verifying they can perform their intended safety functions through post maintenance or post modification testing.
Restari Plan Cross Reference Action Plin 1.1C, Step 4 - Fast Cruise System Checkout Action Plan 4.2, Step 1.9 Identify Functbnal testing requirements including overallintegrated testing and selected ECCS response demonstration testing.
This testing will be directed toward investigation of known problems and confirmation of problem resolution. This testing will also constitute additional discovery for problems which cannot be identified via review of past documentation.
STATUS:
COMPLETE Panel review completed 11/20/97. Implementation of the licensee's corrective actions and actual post maintenance and post modification testing will be reviewed during other inspections conducted to address other aspects of the licensee's restart plan.
- h.
The licensee expanded the scope of the corrective actions to consider all of the causal factor that contributed to the deficiency or problem, including potential generic concems.
STATUS:
COMPLETE 12
o e
I The scope of the Restart Plan addressed the root causes that were identified by
~
the service water system SSOPl, by the ISA, and following the service water event. - Panel verified during meeting on 11/20/g7.
l i
1.
Development of the corrective actions included insights from the organizations or individuals that may have contributed to the event, those responsible for developing the corrective actions, and those responsible for implementing the corrective actions.
STATUS:
COMPLETE i
Inputs for the licensee's action plans included department self-assessments and Action Plan Development Teams. Individualwork items were evaluated for inclusion in the Restart Plan by the line organization. Panel verified during meeting on 11/20/g7.
J.
Interim corrective actions have beer developed and documented when permanent corrective action will take an excessive amount of time to implement or cannot be completed before the licensee plans to restart the facility.
STATUS:
COMPLETE The licensee's Restart Plan, Revision 1s, dated 8/27/g7, addresses the actions to be carried over into Phase 11 and Phase lli (short term and long term actions to be completed following restart) and a discussion of the associated tracking mechanisms. The licensee's plans for restart issue closeout includes 1
documentation for any followup action, which includes a list of actions that will be 1
carried over from Phase I to Phases ll or Ill Panel review completed on 11/20/g7.
k.
All corrective actions have been incorporated into a comprehensive corrective action plan, which has been approved by the licensee's Independent oversight committee.
STATUS:
COMPLETE The licensee docketed a restart plan which defines the actions to be taken to address performance deficiencies. Performance standards and measures are established in the licensea's restart plan. The licensee's quality oversight organization completed its review of the restart plan on 4/15/g7. The licensee discussed the results of the Quality and Cafety Assessment (Q&SA) assessment findings with the NRC during the Restart Panel meeting on 5/2g/g7.
C.1.3 Corrective Action Plan implementation end Effectiveness a.
Each of the corrective actions is assigned a required start and completion date commensurate with the complexity and safety significance of the action.
STATUS.
COMPLETE 13
0 4
Tne Restart P'an does not include dates although all actions will be ceir-;2d prior to restart. The licensee presented its proposed restart schedule during a i
Restart Panel meeting on 11/21/97.
An organlaation and individual have been designated w6th lead responsibility for b.
each of the corrective actions.
l
~ STATUS:
COMPLETE
[
A sponsor, team leader, and team members are assigned to each of the I
-licensee's action plans. Panel review >mpleted on 11/20/g7.
c.
The responsible individual has sufficient awMty, resources, and management support to ensure that the action vnil be adequately completed, j
STATUS:
COMPLETE 1
Each corrective action strategy in the licensee's restart plan has a sponsor The sponsors are upper level management that report either directly to the site vlce-l president or plant general manager. Panel review completed on 11/20/g7, d.
The licensee has defined objectives to tm achieved from implementing the corrective action plan, including interim o' joclives to assess the progress of the plan. The objectives are fonused on ensuring a insting improvement in the operation and maintenance of the plant, j
STATUS:
COMPLETE i
The licensee has defined objectives for each action plan. Progress is assessed by the performance measures and performance standard provided for each plan.
Panel review completed on 11/20/97.
e.
Whenever possible, the licensee's objectives are based on a measurable set of criteria that the licensee can readily track and trend, as appropriate, to provide continuous monitoring of the implementation and effectiveness of the corrective action plan. These measures should form the acceptance criteria for closure and provide procursor indication of declining performance.-
1 STATUS:
COMPLETE Action plans contain performance measures (where applicable) that are being -
trended by the licensee. Penel review completed on 11/20/97.
f.
The licensee has anticipated and addressed potential conflicts of implementing the corrective action plan with existing facility operational (maintenance, engineering, etc.) practices, regulatory requirements, or personnel activities.
STATUS:
COMPLETE k
14 3
4
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y,;
,A
- The limnsee's plan includes processes for addressing potential conflicts._ Panel review completed on 11/20/97..
g._
1 The corrective action plan contains guidance for the licensee to assess changing information or conditions to determine whether the licensse must modify the corrective action plan.
STATUS:
COMPLETE Additions to or removals from the Restart pisa must be presented to the Restatt -
' lasue Review Committee for approval. Panel review completed 11/20/97. -
h.
The licensee has developed training on both the lessons loamed from the event Lanalysis and root cause determination and the technical and administrative changes made to the facilities or practices that includes a discussion regarding why the changes are necessary.
STATUS:
COMPLETE The licensee discussed its plan for communicating objectives to plant staff during the Restart Panel meeting on 5/29/97.
I.
The corrective action plan includes requirements to have self-assessments, and as necessary, independent assessments, of the implementation and effectiveness of the plan.
STATUS:
COMPLETE The Restart Plan requires that each department perform a self-assessment of its performance. The licensee stated in a letter dated 10/8/97 that the Chief Nuclear Officer will commission an independent assessment of the units readiness for restart after the site vice-president concludes that the plant is ready for restart.
J.
In cases where long term actions remain to be secomplished, the licensee has clearty documented when the action will be complete, the basis for the delay in completing the action, and how the action will be tracked and trended to ensure completion.
STATUS:
COMPLETE -
The licensee's Restart Plan, Revision ia, dated 8/27197, addresses the actions to be carried over into Phase 11 and Phase ill (short term and long term actions to be completed following restart) and a discussion of the associated tracking -
mechanisms. The licensee a plans for restart issue closeout includes =
documeritation for any followup action, which includes a list of actions that will be carried over from Phase I to Phases 11 or I!l. Panel review completed on 11/20/97.
k.
The licensee has established a predefined time frame following completion of the corrective actions durin'g which they will continue to monitor the effectiveness of the cormctive actions.
15
7 c
?
-- RESPONSIBILITY:
Panel STATUS:
COMPLETE During the public meeting on 11/21/g7, the licensee indicated that the processes 1
described in the licensee's restart plan to address the performance problems which led to the extended shutdown will be implemented on an ongoing basis.
. C.2 LICEN4E2 SELF-ASSESSMENT AND MANAGEMENT EFFECTIVENESS C.2.1 Self-Asset mont Capability a.
' Effectiveness of Quality Assurance Program.
s Restart Plan Cross-Reference Action Plan 5.2 Improve SQV's [ Site Quality Verification) ability to diagnose Nuclear Safety and Quality concems and effectively communicate those issues to line management for resolution prior to extemal identification or self revealing events.
Action Plan 5.3 - Improve Departmental self assessments and effectiveness.
l NRC Vertfication Plans l
Review plan imp;ementation and effectiveness when performing inspection of the offectivene=S of licensee controls in identifying, resolving, and preventing recurring reoblems (40500 inspection). Tentatively scheduled for March 1998.
n RESPONSIBILITY:
DRS, Lead Engineers Branch STATUS:
Open d.
Effectiveness of deficiency reporting system.
i Restart Plan Cross-Reference Action Plan 5.1, Step 6 - Issue clear guidance / communication on the Problem Identification Form (PlF) process.
Action Plan 5.1, Step 12.0 - Implement a formal CARB [ Corrective Action Review Board) Procedure.
- Action Plan 5.1, Step 13.2 - Establish indicators for measuring CARB effectiveness.
i-NRC Verification Plans -
Review plan implementation and effectiveness during the 40500 inspection tentatively scheduled for March 1998.
i
- RESPONSIBILITY:
D'1S, Lead Engineers Branch
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STATUS:
Open g.
Effectiveness of commitment tracking program.-
Restart PlanCross-Reference Action Plan 8.1, Stop 7 - Implement a formal NTS (Nuclear Tracking System)
Procedure.-
NRC Verification Plans Review plan implementation. h nativer ss during the 40500 inspection tentatively scheduled for March M
RESPONSIBILITY:
DRS, Lea. aAv( Branch STATUS:
Open C.2.2 Manacement Oy_gn.laht and Effectiveness a.
Goals and expectations communicated to and understood by the staff.
Restart Plan Cross-Reference Action Plan 2.1, Step 1 - Expectations Establish clear expectations for human performance and interaction.
NRC Verification Plans Review human performance improvement plan implementation during routine resident inspections.
RESPONSIBILITY:
ORP STATUS:
Open b.
Demonstrated expectation of n terence to procedures.
Restart Plan Cross Reference Action Plan 2.1, Step 2 - Follow-up - Follow-up to ensure expectations are understood and are being applied in daily work activities, NRC Verification Plans Review management oversight of procedure adherence during routine resident inspections.
RESPONSIBILITY:
DRP 17 l.
STATUS:
Open c.
Management involvement in self assessment and independent self-assessment capability.
Restari Plan Cross Reference Action Plan 4.1, Step 7 - Perform self assessment of above effectiveness.
Action Plan 5.2 Improve SQV eifectiveness.
Action Plan 5.3 Improve departmental self assessments and effectiveness.
NRC Verification Pignt Review plan implementation and effectiveness during the 40500 inspection tentatively scheduled for March 1998.
RESPONSIBILITY:
DRS, Lead Engineer? Branch STATUS:
Open d.
Effectiveness of management review committees.
Restart Plan Cross-Referenca None NRC Verification Plans Resident inspectors will verify adequacy during routine observations.
RESPONSIBILITY:
DRP STATUS:
Open e.
Management's demonstrated awareness of day-to-day operational concems.
B.gstart Plan Cross-Reference Action Plan 1.2A, Step 16 - Plan of the Day - Weekly discussion of operator work-around impacts.
Action Plan 1.28, Step 9 - Implement a monthly review of Temporary Alteration status (Operations, Maintenance, Work Control and Engineering) to establish a mutual agreement on open Temporary Alteration resolution priorities and schedule. Identify and resolve any issues that will prevent achieving performance standards to the Station Manager, including Temporary Alterations older than 1 cycle.
Action Plan 1.2C, Step 6 - Plan of the Day - Daily discussion on Dark Board impacts, open Work Requests, alarms present, etc.
18
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. I NRCNortfloation Plan.
4 Resident inspectors w!Il verify adequacy during routine observations; RESPONSIBILITY:
DRP STATUS:
Open f.
Management's ability to identify and prioritize significant issues.
Restart Plan Cross-Reference
{
Action Plan 1.2A, Step 13 - Establish objective critoria for emergent and existing OWA [ operator work-around) inclusion.
Action Plan 1.2C, Step 3 - Establish objective criteria for emergent and existing MCR [ main control room) WR (work request) inclusion.
AcGon Plan 3.1, Step 2.5 - Complete documentation _ reviews prior to restart.
Action Plan 5.1, Step 8.0 - Implomsnt the new Nuclear Division Corrective Action Nuclear Station Work Procedures (NSWPs).
NRC Verification Piar.4 Resident inspectors will verify adequacy during routine observations.
I-RESPONSIBILITY:
CRP STATUS:
Open g.
- Management's ability to coordinate resolution of significant issues.
Restart Action Plan Cross-Reference Action Plan 1.2A, Step 12 - Establish a resolution plan to eliminate OWAs_with Safety Significance, implement a monthly review of open OWAs to establish a mutual agreement on open OWA resolution priorities and schedule. Identify any 0_
OWAs that will create an operator distraction at 100% power following unit restart.
Unit Plant Manager or Operations Manager must approve any long-term OWAs, including OWAs greater than 1 cycle.
Action Plan 1.2A, Step 15 - Provide written justification for the OWA that have
- been deferred to L1R08 or beyond, define the safety impact and the impact on the operators in the plant. Unit Plant Manager an Operations Manager approval is i
required.
Action Plan 1.2B, Step 10 - Each TALT [ temporary alteration) will have a closure plan that will be evaluatedc Action Plan 1.28, Step 11 - Provide written justification for Temp Alts that have been deferred from L1F35, define the safety impact and the impact on the operators in the plant and MCR Unit Plant Manager and operations approval is required.
j-
. Action Plan 1.2C, Step 5 - Provide written justification for the MCR distractions that have been deferred to L1R08, define the safety impact and the impact on the 1g 4
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Action Plan 5.1, Step 8.0 Implement the new Nuclear Division Corrective Action
- NSWP's NRC Verification Plans 1
Resident inspectors will verify adequacy during routine observations.
RESPONSIBILITY:
DRP STATUS:
Open h.
Management's ability to implement effective corrective actions.
Restart Plan Cros?-Reference Action Plan 1.1 A, Step 15 - Establish " baseline" data points for Action Steps #2 through 14. Initiate corrective actions.
Action Plan 5.1, Step 8 - Implement the new Nuclear Division Cor octive Action NSWP's.
NRC Verifiestion Plans Review plan implementation and effectiveness during the 40500 inspection tentative'y scheduled for March 1998.
RESPONSIBILITY:
DRS, Lead Engineers Brr.nch STATUS:
Open C.2.3 Manaaement Support a.
Impact of any management reorganization, with new responsibilities clearly defined and understood.
NRC Verification Plans Resident inspectors will review significant reorganizations which may affect plant operations.
STATUS:
Ongoing c.
Adequate engineering support as demonstrated by timely resolution of issues.
Restart Plan Cross-Reference Strategy 4 addresses upgrading en0 neering to support restart and power i
operation.
20
i NRC Venfication Plans i
Engineering support will be evaluated during Engineering and Technical Support (E&TS) inspection tentativeh scheduled for March 1998.
RESPONSIBILITY: - DRS, Lead Engineers Branch STATUS:
Open d.
Adequate plant administrative procedures.
Restart Plan Cross-Reference Action Plan 1.3B, Step 5 - Revise LAP-900 4 to address streamlining procedure, and incorporating the Global OOS process.
NRC Verification Plans Resident inspectors will verify completion of Action Plan 1.38, step 5, and verify adaquacy of a sample of administrative procedures during routine observations.
RESPONSIBILITY:
DRP STATUS:
Open C.3 ASSESSMENT OF PLANT AND CORPORATE STAFF EFFECTIVENESS C.3.1 Assessment of Staff a.
Demonstrated commitment to achieving improved performance.
Restart Plan Cross-Reference Strategy 2 addresses human performance to support safe plant operation.
NRC Verification Plans The Panel will evaluate performance through a review of inspection findings and discussions during routine management meetings with the licensee.
RESPONSIBILITY:
Panel STATUS:
Open b.
Demonstrated safety consciousness.
Restart Plan Cross-Reference None 21 F
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NRC Verification Plans The Panel will evaluate safety consciousness through a review of inspection findmgs and discussions during routine restart panel meetings with the licensee.
RESPONSIBluTY:. Panel-
' STATUS:
Open c.
Understanding of management's expectations and goals.
Restart Plan Cross-Referer:ce
- Action Plan 2.1, Step 1 - Human performance and interaction.
1 1
NRC Verification Plant Resident inspectors evaluate plant staffs understanding of management's expectations during routine observations.
- RESPONSIBluTY:
DRP STATUS:
Open d.-
Understanding of plant issues and corrective actions.
Restart Plan Cross-Reference Action Plan 2.1, Step 5.4 - Regularly communicate status of the restart plan and system functional reviews.
NRC Verification Plans
~
Resident inspectors will evaluate the plant staffs understanding of the licensee's -
restart plan, emergent plant issues, issues related to the restart plan, and corrective actions during routine observations, i
RESPONSIBILITY; DRP STATUS:
Open
- k. -
Procedure usage / adherence.
Restert Plan Cross-Reference -
Action Plan 2.1, Step 1 - Expectations - Establish clear expectations for human performance and interaction.
Action Plan 2.1, Step 2 - Follow-up - Follow-up to ensure expectations are understood and being applied in daily work activities.
22
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NRC Verification Plans Resident inspectors will verify completion of Action Plan 2.1, Step 1 and 2, and evaluate procedure usage and adherence during routine observations.
RESPONSIBILITY:
DRP STATUS:
Open C.3.2 Assessment of " Corporate" Suco_oA The panel concluded that an assessment uf the corporate support to LaSalle was not ne~.sssary for restart since NRC efforts (the Comed Performance Oversight Panel (CPOP)) are ade,ssing the effectiveness of Comed corporate support to all Comed nuclear generating stations.
C.3.3 Operator issues a.
Licensed operator staffing meets requirements and licensee goats.
Restart Plan Cross-Reference None NRC Verification Plans Ensure that operators granted licenses contingent on reactivity manipulations have completed the required manipulations prior to performing licensed duties.
RESPONSIBILITY:
DRS, Operator Licensing Branch S1 ATUS:
Open b.
Level of formality in the control room.
Restart Plan Cross-Reference Action Plan 1.1 A, Step 7 - Monitor communication for direct, 3-way communication in the Main Control Room and the plant. Document findings, determine causes for inaccurate or incomplete communication and initiate corrective action.
Action Plan 1.1 A, Step 8 - Monitor NSO [ Nuclear Station Operator) Alarm Response, prompt response, informed supervisor retums appropriate alarm response procedure.
Action Plan 1.1 A, Step 9 - Monitor pre-shift briefings. Provide immediate feedback to person conducting briefing areas fro improvement. Input to trend database for follow-up.
Action Plan 1.1 A, Step 10 - Monitor pre-job briefs /HLA [ heightened level-of awareness) briefs. Input to trend database for follow-up.
23
o NRC Verification Plans Restart Readiness Assessment Team will review the license 3 implementation of Action Plan 1.1 A steps listed above and verify its completion.
STATUS:
Open.
c.
Effectiveness of control room simulator training.
Restart Plan Cross-Reference Action Plan 6.1, Steps 1.1 - 1.3 - Define Crew needs and wants; Complete reviews of training materials, feedback, observations, etc.; Complete Reviews of d
Observations, PlFs [ problem identification forms), Events, etc.
Action Plan 8.1, Step 3 - Develop the program.
Action Plan 6.1, Steps 3.2 - 3.3 ' reining (Lesson plans, course materials, labs, other operator input); Evaluation / assessment (exams, evaluations,- observations,-
Shift Manager mentors, etc.).
Action Plan 8.1, Step 4 - Implement the training: -sufficient number of crews trained to support Unit startup.
Action Plan 6.1, Step 5 - Implement operator evaluations - Operators Klentified as pass, short or long term remediation.
Action Plan 8.1, Step 6 - Complete HIT following incorporation of feedback and lessons leamed.
Action Plan 6.1, Step 9 - Complete training identified in action steps 7 & 8 -
sufficient number of crews trained to support unit startup.
Action Plan 6.1, Step 10.2 - Evaluate training effectiveness - Review of Exam Results.
NRC Vcrification Plans DRS evaluated HIT program effectiveness. Documented in inspection Report No. 50-373/97014(DRS); 50-374/97014(DRS).
STATUS:
COMPLETE d,
Control room / plant operator awareness of equipment status.
Restart Plan Cross-Reference Action Plan 1.1 A, Step 3 - Monitor operator rounds for accuracy and completeness, identification of trends and effectiveness of corrective actions.
Document findings, determine causes for inaccurate or incomplete rounds and
- initiate corrective action.
Action Plan 1.1 A, Step 5 - Monitor out of-service problems including type and number. Trend results and implement corrective action.
Action Plan 1.1 A, Step 11 - Monitor US/NSO tumover for completeness, board walkdown. Identify deficiencies per" scorecard'* debrief with individual. Input to trend database.
24
Action Plan 1.1 A, Step 12 - Monitor NLO [non-licensed operator) tumovers for
. completeness, accuracy, professionalism. Identify deficiencies per" scorecard, debrief with individual. Input to trend database.
NRC Verification Plans Restart Readiness Assessment Team will review selected portions of the -
licensee's implementation of Action Plan 1.1A.
RESPONSIBILITY:
DRS STATUS:
Open e.
Adequacy of plant operating procedures.
Restart Plan Cross-Reference Action Plan 1.3C, Step 1.1 - 1.3 - Additional Scope Discovery - Review surveillances and identify those to be performed prior to start up which need revision from initial review (Unit 1); Review all procedures used to perform a start up and. identify those needing revision from initial review (Unit 1); Review all L1F35 DCPs [ design change packages) and tabulate required procedure revisions. Unit i Only.
Action Plan 1.3C, Step 9 - Complete revision of Startup Procedures identified in Stop 1.2.
NRC Verification Plans Restart Readiness Assessment Team will review licensee's plan implementation and effectiveness. The engineering inspector will review implementation of Step 1.3 and verify ccmpletion.
RESPONSIBILITY:
DRS STATUS:
Open f.
Procedure usage / adherence.
Restart Plan Cross-Reference Action Plan 1.1 A, Step 2 - Monitor completed surveillances for accuracy and completeness. Document findings, determine causes for inaccurate or
- incomplete surveillance and bitiate corrective action.
Action Plan 1.1 A, Step 6 - Monitor procedure use and compliance.
NRC Verification Plans Restart Readiness Assessment Team will review licensee's plan implementation and effectiveness of Action Plan 1.1 A, Step 2 and 6.-
25
7 7,- -
RESPONSIBILITY:
.DRS STATUS:
.Open g.
Log keeping practices.
Restart Plan Cross-Reference Action Plan 1.1 A, Step 4 - Monitor operator logs for completeness, legibility and -
conformar ce with expectations.
}fC Verification Plans Restart Readiness Assessment Team will review licensee's plan implementation and effectiveness.
RESPONSIBILITY:
DRS STATUS:
Open C.3.4 Enaineerina Supoort to Operations a.
Engineering personnel qualifications.
Restart Plan Cross-Reference Action Plan 4.1, Step 1.0 - Complete system qualifications for all System Engineering personnel for assigned systems. All systems will have System Engineers assigned. This will include both incumbent and contractor personnel.
Contractor personnel qualification will be determined on a case-by case basis considering previous experience and obserted capab'eity. Assess personnel 4-capability as required to develop fully capable Op.iem Engineering organization.
Revise training syllabus to resolve known deficiencies.
4 Action Plan 4.1, Step 1.1 - Determin system qualification requirements and methods for achieving; the System Functional Performance Review program and System Readiness Review process will be used as an important part of the qualification process. An oral review board will be used to assist in determining
- the qualification status of individual System Engineers. ' This board will be composed of the System Engineer supervisor and selected Group Leaders.
Action Plan 4.1, Step 1.4 - Perform self-assessment of effectiveness of qualification process.
i 4
- Action Plan 4.1, Step 3 - Use System Functional Performance Review program and Engineering Assurance Group rev:aws as part of the fundamental tutoring C
processes for assessing and improving the technical capabilities of Engineering.
NRC Verification Plans E&TS Inspection tentatively scheduled for March 1998, will review the -
- Implemeniation.
- 26 1
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DRS STATUS:
_Open-
- b.
- Engineering Assurance Group Restart Plan Cross-Reference Action Plan 4.1, Step 2.0 - Fully implement Engineering Assurance Group
- fucctions. Reviews by Engineering Assurance will be in-line for the fUlowing engineering products: Safety Evaluations, Operability Evaluations, Technical
- Specifications Clarifications, Root Cause Reports, selected design packages, selected material evaluations, LERs, regulatory submittals.
NRC Verification Plans Engineering inspector will review the implementation and effectiveness of the licensee's plans during routine inspections and E&TS inspection tentatively scheduled for March 1998.
RESPONSIBILITY:
DRS STATUS:
Open C.4
- ASSESSMENT OF PHYSICAL READINESS OF THE PLANT a.
Operability of technical specification systems.
Restart Plan Cross-Reference Action Plan 1.1C, Step 3.1 - 3.3 - Complete Pre-start up reviews - Complete LAP-1200-15, as required to support mode switch to riartup; Complete Start up OSR; Complete Start up PORC.
Action Plan 4.2, Step 2 - Design Reviews - As the complement to the System Functional Performanct Reviews, certain systems or portions of systems will require a detailed design review to identify and resolve problems. Four systems have been identified to date for this raview (VE/VC, CSCS,125 VDC).
Action Plan 4.2, Step 5 - Vendor Information and Operating Experience Reviews.
Action Plan 4.2, Step 5.1 - Review selected vendor information and operating experience files to establish the adequacy of review process in consideration of repeated failure to identify potential design problems with SBM control switches.
Determine scope of Operating historical vendor information and industry experience that should be reviewed to determine confidence in past practices.
Action Plan 4.2, Step 9.2 -System Readiness Review - For all systems imp rtant to safe and reliable operation, perform system readiness review; present results to Senior Management Review. Compete Unit i reviews.
27 1
1
- c..
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NRC Verification Plans
- Restaat Readmess Assessment Team will evaluate a sample of licensee reviews
. to verify acceptability.
RESPONSIBILITY: -- DRS STATUS:
Open b.
Operability of required secondary and support systems.
Restart Plan Cross Reference Action Plan 1.2A, Step 11 - Schedule or complete an action plan for each Operator Work-Around (OWA) that is listed on the L1F35 OWA list defining the -
resolution plan, schedule dato and responsible individust/ organization. Update on 1
an ongoing basis.
Action Plan 4.2, Step 2 - Design Reviews - As the complement to the System Functional Performance Reviews, certain systems or pertions of systems will require a detailed design review to identify and resolve problems. Four systems have been identified to date for this review (VENC, CSCS,125 VDC).
Action Plan 4.2, Step 9.2 - System Readiness Raview - For all systems important to safe and reliable operation, perform system readiness review; present results to Senior Management Review, Complete Unit i reviews.
NRC Vertfication Plans Restart Readiness Assessment Team will evaluate a sample of licensee reviews to verify acceptability.
RESPONSIBILITY:
' STA'.~ud:
Open c.
Results of pre-startup testing.
Restart Plan Cross-Reference Action Plan 1.1C, Step 4 - Fast Cruise system checkout.
Action Plan 4.2, Step 1.1 - System Functional Performance Reviews and.
Functional Testing.
Action Plan 4.2, Step 1.2 - Proceed with System Functional Performance Reviews on all systems selected as important to safe and reliable operation; complete functional reviews on a minimum of 15 to 20 of these systems prior to restart. Apply evaluation criteria to ongoing results of review to determine -
- possible expansion to full scope of functional review prior to restart.
Action Plan 4.2, Step 1.tl - Formalize review organization.
Action Plan 4.2, Step 1.7 - Formalize review, problem reporting and resolution process, _ reporting requirements, and closure process.
28
- -. ~. -. -... _... - - -. - -. --
- w a
Action Plan 4.2, Step 1.8 - Complete review portion for 42 systems in System )
Fundional Performance Reviews including recommended functional testing i requirements.
Action Plan 4.2, stop 1.g - Identify functional testing requirements including overallintegrated testing and selected ECCS response demonstration testing.
- This testing will be directed toward investigation of known problems and confirmation of problem resolution. This testing will also constitute additional '
discovery for problems which cannot be identified via rey!ew of past -
documentation.-
Action Plan 4.2, Step 1.10 - Implement' Joint Test Group process to facilitate test procedure preparation, review, implementation and results.
Action Plan 4.2, Step 1.11 _ Review startup related procedures for adequacy and
. literal compliance capability..
NRC Venfication Plans Observe testing activities during routine inspection activities.
RESPONSIBILITY:
STATUS:
Open i
d.
Adequacy of system lineups, Restart Plan Cross-Reference j
Action Plan 1.1C, Step 2 - Plant equipment lineup verification.
i I
NRC Verification Plans
- Restart Readiness Assessment Team will review the licensee's plan implementation and its effectiveness.-
' RESPONSIBILITY:-
DRS l-STATUS:
_ Open_
e.
Adequacy of surveillance tests / test program.
Restart Plan Cross-Reference p
_ Action Plan 1.3C, Steps 1.1 - 1.3 and step 9 - Review and revise operating procedures.
Action Plan 4.2, Step 1.g - identify Functional testing requirements including overall integrated testing and selected ECCS response demonstration testing.
This testing will be directed toward investigation of known problems and
- confirmation of problem resolution.- This testing will also constitute additional discovery for problems which cannot be identified via review of past
- documentation.
l 29 L
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4 Action Plan 4.2, Stop 2 - Design Reviews - As the complement to the System Functional Performance Reviews, certain systems or portions of systems will require a detailed design review to identify and resolve problems. Four systems have been identified to date for this review (VE/VC, CSCS,125 VDC).
Action Plan 3.1, Steps 2.3.1,2.3.1.1, and 2.3.1.2 - Validate required surveillance /PM scope.
NRC Verification Plans Restert Readiness Assessment Team and E&TS inspection will evaluate a sample of licensee reviews to verify acceptability.
RESPONSIRILITY:
ORS
-J STATUS:
Open f.
Significant hardware issues resolved (i.e., damaged equipment, equipment ageing, modifications).
Restart Plan Cross-Reference Action Plan 1.1C, Step 4 Fast Cruise System Checkout Action Plan 3.1, Steps 2.1 - 2.3 Identify and approve final work necessary for unit restart.
Action Plan 3.1, Step 2.4.1 - Document dinovery results on system basis.
Action Plan 3.1, Step 2.4.2 - Perform Confirmatory sycem Readiness review for all systems in original scope (Step 2.3 above).
1 Action Plan 3.1, Step 2.4.3 - Present a consolidated status of Unit One System Readiness to Management prior to restart.
Action Plan 4.2, Step 1.9 - Identify functional testing requiremer is including overallIntegrated testing and selected ECCS response demonstration testing.
This testing will be directed toward investigation of known problems and confirmation of problem resolution. This testing will also constitute additional discovery for problems which cannot be identified via review of past documentation.
Action Plan 4.2, Step 2 Design Reviews - As the complement to the System Functional Performance Reviews, certain systems or portions of systems will require a detailed design review to identify and resolve problems. Four systems have been identified to date for this review (VE/VC, CSCS,125 VDC).
Action Plan 4.2, Stop 9.2 - System Readiness Review - For all systems important to safe sind reliable operation, perform system readiness review; present results to Senior Management Review. Complete Unit i reviews NRC Verification Plans Restart Readiness Assessment Team and Resid:,nts inspectors will verify that significant hardware issues have been resolved and review implementation and effectiveness of above action plan steps.
RESPONSIBILITY:
.o f
. 8TATUS:
Open g.
Adequacy of the power ascension testing program.
Restart Plan Cross-Reference Action Plan 1.1C, Step 4 Fast Cruise system checkout.
i NRC Venfication Plans Restart Readiness Assessment Team will evaluate adequacy of licensee's restart and power ascension plan.
RESPONSIBILITY:
DRS STATUS:
Open h.
Effectiveness of the plant maintenance program including scheduling and work -
control.
' Restart Plan Omss Reference Action Plan 7.1, Step 8.1 - Implement NSWP A-04.
NRC Verification Plans Resident staff wiU evaluate effectiveness of the work control and scheduling peocesses during routine observations.
l RESPu 3lBILITY:
DRP STATUS:
Open 1.
Maintenance backlog managed and impact on operations assessed.
Restart Plan Cross-Reference Action Plan 3.3, C'ieps 2.1 and 2.2 - Determine which Corrective Tasks must be completed prior to Startup - Unit 1.
Action Plan 3.3, Step 5.1 - Audit completion of Corrective NWR [ Nuclear Work Request) Tasks prior to unit startup - Unit 1.
NRC Verification Plans The Resident inspectors will evaluate the impact of the maintenance backlog and its impact on operat!ons.
RESPONSIBILITY:
DRP STATUS:
Open 31 l
.-... - - ~. -
k.
Engineering backlog managed end' impact on operations assessed.
Restati Plan Cross-Reference Action' Plan 4.2, Steps 8 - 9.4.1 - Backlog Review - Review all backlog items and -
assess importance for resolution prior to restart (e.g., ERs, PlFs/ root cause determinations / corrective actions, Operator Work-Arounds, Control Room Deficiencies, outstanding ARs and Work Requests) against all systems considered important to safe and reliable operation. Use " Restart Review Criteria."
NRC Verification Plans j
1 Review programs during E&TS inspection tentatively scheduled for March 1998.
RESPONSIBILITY:
DRS STATUS:
Open.
l.
Technical issu',s which would preclude restart (Restart issues) are managed by the licensee.
Restart Plan Cross-Reference None NRC Verification Plans Review the licensee's list of restart issues and discuss the status during restart meetings.
Inspect the licensee's action during reviews for C.4.a, C.4.b and C.4.f. Restart-Readiness Assessment Team will evaluate a sample of licensee reviews to verify acceptability.
RESPONSIBILITY:
Open 4
C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS a.
Applicable license amendments have been issued.
RESPONSIBILITY:
NRR c STATUS:
Open Applications for license amendments are being reviewed.
32.
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b.
Applicable exemptiot is have been granted.
RESPONSIBILITY:
NRR i
J STATUS:
As na cessary c.
Applicable rolls fs have been granted.
RESPONSIBILITY:
NRR i
STATUS:
As necessary e.
Confirmatory Action Letter conditions have been satisfied.
RESPONSIBILITY:
Panel STATUS:
Open The Panel will verify that the licensee has completed the CAL items upon notifi-ilon by the licensee that all CAL items have been completed.
- f.
. Significant enforcement issues have been resolved.
STATUS:
Ongoing Enforcement discretion in accordance with section Vll.B.6 of the Enforcement Policy was authorized for several violations related to actions prior to the shutdown. The discretion was issued to the lice.nsee on 9/27/97. No significant enforcement issues are pending.
4 g.
Allegations have been appropriately addressed.
NRC Verification Plans The Panel will be briefed by Region 111 Office Allegation Coordinator prior to restart.
RESPOUSIBiLITY:
PANEL STATUS:
Open C.8 COORDINATION WITH INTERESTED AGENCIES AND PARTIES Coordination with other interested agencies and parties is important to ensure that concems and requirements of these organizations are factored into the restart authorization.
a.
Federal Emergency Management Agency.
RESPONSIBILITY:
NRR 33 i.
.,a
< p; STATUS:
_Open e.
Appropriate State and local officials.
STATUS:
Ongoing '
PNs issued.- Routine interface between NRC Resident inspectors and IDNS Resident Engineer. Periodic management meetings open to the public are being conducted. CAL Rill-g6-008B requires a public meeting be held during which the licensee will describe why it believes the plant is ready for restart, f.
Appropriate public interest groups.
STATUS:
Ongoing Periodic management meetings open to the public are being conducted.
g.
Local news media.
RESPONSIBILITY: - Regional Public Affairs staff 4
STATUS:
Ongoing Routine interface, including interviews with regional management, with media.
- C.7 ADDITIONAL PLANT SPECIFIC ISSUES AND INSPECTION ITEMS a.
Review Inservice Testing (IST) program based on number of significant deficiencies identified.
Restari Plan Cross-Reference d
Action Plan 4.2, Step 3.8 - Review Completed IST assessment to determine items needing correction prior to startup.
NRC Verification Plans
- Conduct IST program inspection prior to restart.
RESPONSIBILITY:
DRS STATUS:
Open-b.
Review setpoint and calibration control programs.
. Restart Plan Cross Reference -
I Action Plan 4.2, Step 6 - Design Evaluations - Examine outstanding design evaluations and analysis work and determine which work required to be completed before restart (e.g., setpoint calculations).
a-
- - - _. ~. -. -....
, -..,o NRC Vertfication Plans P
Review programs during E&TS inspection tentativey scheduled for March 1998.
RESPONSIBILITY:
DRS-STATUS:
Open y
t 4
35
1 L
LASALLE RESTART PLAN: CASE 4PECFIC CIECMUST MATMDC C.1 ASSESSMENT OF ROOT CAUSE DENTFICATION AND CORRECTION ITEM DESCRIPTION RESTART PLAN LICENSEE RESPONSmLE DATE CLOSEDr NUMBER REFERENCES ACTION ORGANIZATION MECHANISM STATUS 1.
Evert analyms and Root Cause Assasement a.
Condihons imedtng to to and eventumsy requiring the shutdown, Pim dened Gr27M Corghete Panel COMPLETE;
>duding performanos and pr-concems rotated to the shutdown, affetFT are N RESTART MEETING p.
Petereed root = m of the canditions requiring the shutdown and any Plan deled 8/27M Cormlete Pened COMPLETE W problems were thorougNy evesueled.
Seneg7 RESTART MEETING 2.
Corredive Acnon Casw G
~
a.
The prgeoed cemdn accens are cesarty crom to as of the Vertous Composen Panel COMPLETE.
eseadmeed rod -- and causal sectors they are ineanded to coneet Penal meseg es appropriate 11/20 57 tt Each of the corrective adions is mesegned an approprtete priarty beoed Vertous Composes Panet COMPLETE; on safety signmcance to ensure the proper resources and enannon are Penef meets davated.
11f20TT c.
Proposed correcewe oceans leerefy We deelred condalons to be various Corgente Panel COMPLETE; achieved and are We to pr=+=== recurrence Penal meseg 1tr2Wp7 d.
Corrective acnons are sumeteney detaned to ensure that as actMuse Vertous Corgeste Penal COMPLETE.
related to compleGon of the corrective action have been lderstried (l.a.
Panel meetg procedure et enwino changes. Tectriiest Specifiestion changes, etc.).
11/205T e.
Correcove acconu lnclude restoring systems and equipmert to servios 1.1C, step 4 Open Panel COMPLETE and verirdng thsy can perform then Hended eefety functions trrough c, step 12 Panelmeets post rneintenance or poet modtficanon testing.
11r2Ws7 h.
The Econeee expanded the scope of the correcthe acnons to consider Vertous Cornplate Panet COMPLETE; et of the causal factor that cort 2uted to the deficiency or problem.
Penet meetg ineduding peeennes generte cone me 1tr20er L
C;.4-; of the correcSwe acnons inesuded ktsights from the Vertous Complete Penal COfWPLETE, orgentresons or hsMduate that may have cone 1btAed to the event, those Punei meneg responalble for developing the cormctive ecSons, enr! tems responsble 11rJOST l
br @w O w the corrective acticce J.
Interim corrective acnone turve been developed and documented whern Vertous Corglete Panel CoerLETE permanord correceve action we take en ocesehe amoint of sme to hpiement or cannot be completed before the !benose plans to restart j
m,
O rrE u NUMBER DESCRIPTON RESTARTPLAN UCENSEE RESPONSIBLE DATE CLOSEDr REFERENCES ACTION ORGANIZATOM MECHANISM STATUS m
m M
k.
At correctrve amans have been kicorporated kto a -W ma Vanous Corgeste Panoi
- COMPLETE, corredhe acean plan, wNdt has been approved by the Scansee's Reeturt Panel hdependert oversiert comr,ittee Moseng strztm7 3.
Corraceve Acnon Plan Impeementanon and Ef'ectrveness a.
Each of the correcthe acbons b assigned a required start and Vertous Complete Pensi rewt COhrLETE.
comptrean date commeneurme weh the cor@iedy and asfaty Penalow saanencance cf the ecson.
11,20 s7 b.
Art u, Aa,,, and MdMdued have been designated nitri teed Various Corgente Penei COMPLETE; responsibuty for each of the corredtve oceans Pened twvloer 11/20s7 c.
The responsible indMduni has suf'letert sumorty, resources, and Vertous Carpelo Panel COMPLETE; rnensgemert awport to ensure that the adion wW be edequmery Panelmoedhe ecr9 pie *ed 11/20s7 d.
The scensee has defined objecttves to be acNet : J from kwiemennng Vartous Campiate Panei
- COMPLETE, the correcttve adlon plan, heduding irterim objedtves to eseess the Panelmoedrg progrees of the pien. The abgeettves are focused on ensurbg a leseng 11/20 s7 knprovement h the openr6cn and mahtenance of the piert.
e.
Whenever poestle, the bcensee's otgectives are based on a Vertous Complete Penet COMPLETE; meneurable set of c seria that the Bcensee can reecmy track and trend, Penal meets as oppropriate, to provide cortinuous monitering of the kgiemertsson 11/2007 and enecthenese of the conective edian pien. These meneures showd form the sweptance craeria for closus and provide precursor hdiesson of decaning performance f.
The scensee has anudpoted and addressed potennel corects of Vertous Composes Panel COMPLETE; hviemereng the conective action pian wah - + ang fedney operanonal Pensimeseg Onentenance, engineering, etc.) graceems, reguiskry requirements, or 11/20S7 personnet setMttes g.
The corrective adion pian contains guidance for the scensee to assoas Vertoue Comoisie Perus COMPLETE; changing informaban or conditions to dctormine whether the scanese Panelmoelhg enuet rnodify the coneettve accon pier:.
11/20S7 h.
The Bcensee has devcicped trasieng on both the lessons teamed frorn Vertous Complete Panel COMPLETE;
{
the event ane'ysis and root cause determinanon and the tectriical and Restart Panel ed ninistrattve changrs made to the facmties or pnnceces that ird=4== a Moseng discussion regarding why the changes a o necessary 5/2997 L
The corredtve action plan indudes requrements to have self-Ucensee letter deesd Compiele Panel COMPLETE;
}
l esseeemerts, and as necessary, independent seeeeemerts, of the 1oes7 uannese leaar j
knpiementanon and enecevenese of tne pie 1 dated toes 7
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in cases where long ter;n accons remain to be scampeshed, the Vertous Complete Panel
- COMPLETE, seensee has cseerty docsonerted when the octhn we be compioen, the Pensi momeng basis for the deisy h compienna the ocean, and how the ocean wW be 11/20e7 l
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I attaf f F RESTART PLAft: IS$1ES C.3 ASSESSMENT OF PUWT Afe CORPORATE STAFF EFFECTWDESS ITEM DESCRIPTION RESTART PLAN UCENSEE RESPONSIBLE DATE CLOS W NUMBER REFERENCES ACTION ORGANEZATFW MECHANISM q 1.
Asseeemert of Stai e.
Cm n-^.d commirmert to actueving improved 4..-e_
Strategy 2 Open Penaf D.
Demonstrated safety consciousness None DRP c.
Uia e=As of managemerfs 6,-
L.6 and geele.
AcDon Plan 2.1 Open DRP d.
Understandin0 of pimrt h-and correcere adtons.
Acton Plan 2.1, Open DRP seep $ 4 IL Pr=we re umege/seerence Achon PInn 2.1, Open DRP step 1 Acdon Plan 2.1, Open step 2 2.
Assessment of" Corporate
- St.gmort NA NA NA NA 3.
Operator issues s.
Ucensed operator staffing meets requrrements and k:ensee goets.
None DRS b.
Level of formeIRyin the cerealroom.
Acton Plan 1.1A, Open DRS soeve 7. s. o. and 10 c.
Effecthenoes of control room simuistor truning.
Accon Plan 6.1, Open DRS
- COMPLETE, steps 1.1 - 13,3, e
3.2 - 3.3, 4,5,6, 9 Report SM14 and 102 d.
Control is..W; operator awareness of equipmert =*=h =
Acean rien 1.1 A, Open DRS l
stepe 3. 5,11 and 12 e.
Adequacy of peart operstmg pr=we =es.
Acton Plan 12C, Open DRS step 1.1 -13 and 9 f.
Pr==*== useguedherence AcSon Plan 1.1 A, Open DRS l
stepe 2 and 6 g.
Log heeping procuces.
Accon PInn 1.1 A, Open DRS step 4 4.
Engineerin2 support to Operations
(
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Engineering personnel quallnenbons.
Acson Plan 4.1, Open DRS steps 1,1.1,1.4, and 3
b.
Engineering Assurance Grup.
Adlon PInn 4.1, Open DRS seep 2 l
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