ML20198E688
| ML20198E688 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/29/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-166, SECY-97-166-R, NUDOCS 9708070203 | |
| Download: ML20198E688 (84) | |
Text
v RELEASED TO THE PDR l
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POLICY ISSUE (Information)
July 29.1997 SECY-97-166 EE:
The Comissioners l
[!E:
L. Joseph Callan Executive Director for Operations
SUBJECT:
RECOVERY OF MILLSTONE NUCLEAR POWER STATION PURPOSE:
To provide the Comission with a quarterly sumary status of the ongoing activities in the Restart Assessment Plan for the Millstone Nuclear Power Station, in response to a Staff Requirements Memorandum dated May 7. 1997.
The sumary status includes the status of the NRC oversight of the Independent Corrective Action Verification Program, an assessment of licensing issues for restart, a sumary of significant inspection activities and results, and an updated project planning schedule.
BACKGROUND:
On November 4. 1995, the licensee (Northeast Utilities) shut down Millstone Unit 1 for a planned refueling outage.
During an NRC investigation of licensed activities at Millstone Unit 1. in the fall of 1995, the NRC staff identified potential violations regarding refueling practices and operattori of
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the spent fuel 001 cooling systems that were inconsistent with the Updated h Final Safety An 1 sis Report (UFSAR).
The NRC issued a letter to the licensee j
on December 13,195, requiring that, before the restart of Millstone Unit 1.
it inform the NRC. pursuant to Section 182a of the Atomic Energy Act of 1954 as amended, and Section 50.54(f) of Title 10 of the Code of Federal Reaulations (10 CFR 50.54(f)). of the actions taken to ensure that in the future it would operate that facility accordin the )lant's operating license, the Comission'g to the terms and conditions of s regulations, and the plant's UFSAR.
Contact:
NOTE:
To BE MADE PUBLICLY AVAILABLE AT William D. Travers. NRR THE CoMMISSloN MEETING oN AUGUST 6. 1997 301-415 1200
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2 In January 1996. the NRC designated the units at Millstone as Category 2 plants on the NRC's watch list.
Plants in this category have weaknesses that warrant increased NRC attention until the licensee demonstrates a period of l
improved performance.
On February 20, 1996, the licensee shut down Millstone I
Unit 2 when it declared both trains of the high pressure safety injection (HPSI) system inoperable because of a design issue (there was a potential that the HPSI throttle valves could become plugged with debris when in the sump recirculation mode). On March 30, 1996, the licensee shut down Millstone Unit 3 after it found that containment isolation valves for the auxiliary feedwater turbine driven pump were inoperable because the valves did not meet NRC requirements.
In response to (1) a licensee root cause analysis of Millstone Unit 1 UFSAR inaccuracies that identified the potential for similar I
configuration management conditions at Millstone Units 2 and 3. and (2) design configuration issues identified at these units, the NRC issued 10 CFR 50.54(f) letters to the licensee on March 7 and April 4,1996.
These letters required that the licensee inform the NRC of the corrective actions taken regarding design configuration issues at Millstone Units 2 and 3 before the restart of each unit.
In June 1996, the NRC designated the units at Millstone as Category 3 alants on the NRC's watch list.
Plants in this category have significant wea(nesses that warrant maintaining them in a shutdown condition until the licensee can demonstrate to the NRC that it has both established and implemented adequate i
arograms to ensure substantial improvement.
Plants in this category require Commission authorization to resume operations.
On August 14, 1996, the NRC issued a Confirmatory Order directing the licensee to contract with a third party to implement an Independent Corrective Action Verification Program (ICAVP) to verify the adequar.v of its efforts to establish adequate design bases and design contro'a.
The ICAVP is intended to provide additional assurance, before unit restart, that the licensee has identified and corrected existing problems in the design and configuration control processes.
On October 24, 1996, the NRC issued an Order directing that, before the restart of any Millstone unit, the licensee develop and submit to the NRC a comprehensive plan for reviewing and dispositioning safety issues raised by its employees and ensuring that employees who raise safety concerns can do so without fear of retaliation.
The Order also directs the licensee to. retain an independent third party to oversee implementation of its comprehensive plan.
-On November 3. 1996, the NRC created a ncw organization, the Special Projects Office (SPD), within the Office of Nuclear Reactor Regulation (NRR), to provide a specific management focus on future NRC activities associated with the Hillstone units.
The SP0's responsibility for activities at Millstone includes all licensing and inspection activities required to support an NRC decision on restart of the Millstone units.
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3-In SECY 97 003. *Hillstone Restart Review Process." dated January 3. 1997, the staff provided to the Comission the NRC staff's processes and approaches that will be used to oversee the corrective action programs at Hillstone Nuclear Power Station. Units 1, 2. and 3.
The staff is applying the guidelines of NRC Manual Chapter (MC) 0350. " Staff Guidelines for Restart Approval." to the restart approvals of Millstone Units 1, 2, and 3.
l On January 30. 1997, the staff, along with the licensee, briefed the Comission concerning the oversight activities in regard to the recovery of the three Millstone units.
Subsequently, on A)ril 23, 1997, the staff, along with the licensee, provided the Commission wit 1 a quarterly u)date regarding these same oversight activities.
The staff is continuing to 3rief the Commission on Millstone activities on a quarterly basis.
DISCUSSION:
1 in a Staff Requirements Memorandum (SRM) dated May 7. 1997, the Commission directed the staff to provide the Comission, prior to each quarterly meeting with the Commission, a summarized written status of the ongoing activities in the Restart Assessment Plan, including but not limited to, the status of NRC oversight of the ICAVP an assessment of licensing issues required for restart, a summary of significant inspection activities and results, and an updated project planning schedule.
The staff has identified in the Restart Assessment Plan several major elements that require resolution before 31 ant restart.
These elements include the corrective action programs, wort planning and control improvements, procedure upgrade. programs, employee concerns.'and quality assurance and management oversight improvements.
The plan also includes staff activities to evaluate the licensee's res Units 1. 2. and 3.ponse to NRC's 10 CFR 50.54(f) letters regarding Millstone and the completion of the ICAVP.
The actions listed in the generic MC 0350 restart checklist that are applicable to Millstone, such as those regarding management effectiveness and self-assessment capability, are also included in the plan.
The plan provides for the conduct of an operational safety team inspection (OSTI), which is normally carried out to assess the overall readiness of the plant for restart after a prolonged shutdown.
Other issues that require NRC review before restart are pending 10 CFR 2.206 petitions, enforcement actions, and allegations. is a summary status of the Restart Assessment Plan major elements.
is the current Restart Assessment Plan for Millstone Units 1, 2. and 3.
A copy of the project planning schedules for Units 3 and 2 is provided as.
The licensee has focused its recovery / restart efforts on Units 3 and 2 and has delayed activities at Unit 1.
The OSTl for Unit 3 is scheduled to begin on or about October 13, 1997, provided the licensee has implemented all necessary corrective actions to have the plant and personnel ready for power operations.
Based on the current schedule, a Commission briefing for a Unit 3 restart decision could occur in December 1997.
The OSTI for Unit 2 is scheduled to begin on or about January 5. 1998, provided the
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licensee has implemented all necessary corrective actions to have the plant and personnel ready for power operations. Based on the current e.chedule, a Commission briefing for a Unit 2 restart decision could occur in March 1998, j
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acph Callan Exe tive Director for Operations Attachments:
1.
Restart Assessment Plan Major Elements 2.
Millstone Restart Assessment Plan 3.
Project Planning Schedule i
DISTRIBUT1oN Commissioners oGc ocAA olG oPA oCA ACRS Clo CFO EDo REGloNS SECY
Restart Assessment Plan Maior Elements I
1.
Manual Chapter 0350 and Restart Assessment Plan 2.
Independent Corrective Action Verification Program 3.
Handling of Safety Concerns Raised by Licensee Employees 4.
Licensing issues 5.
10 CFR 50.54(f) Activities 6.
Corrective Action Program 7.
Oversight 8.
Enforcement Status 9.
Work Planning and Controls 10.
Procedure Upgrade Program 11.
Inspection Activities and Results 12, Operational Safety Team Inspection
-o l
ISSUE:
NRC Manual Chapter 0350 and Restart Assessment Plan DISCUSSION:
NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval." establishes the guidelines for a> proving the restart of a nuclear power plant after a l
slutdown resulting from a significant event, complex I
hardware problem. or for which serious cianagement deficiencies have been identified.
The 3rimary objective of the guidelines in MC 0350 is to ensure tlat NRC's restart review efforts are appropriate for the individual circumstances, are reviewed and approved by the appropriate NRC management levels, and provide objective measures of restart readiness.
As a result of NRC concerns regarding the overall effectiveness of the licensee's management, the staff is applying the guidelines of MC 0350 to the restart a>provals of Millstone Units 1. 2 and 3.
MC 0350 states tlat the staff should develop a plant-specific restart assessment plan for NRC oversight of each plant startup.
1 The restart assessment plan is to include all expected NRC actions required to be taken before the NRC approves a plant for restart.
i NRC ACTION:
The staff has developed a Restart Assessment Plan (RAP) for each of the Millstone units to incorporate the appropriate aspects of MC 0350 and to address site-specific and unit-s)ecific issues.
The RAP consists of several major elements t1at require resolution before plant restart and are related to the root causes for the decline in licensee performance.
These elements include the corrective action programs, work planning and control improvements, procedure upgrade programs, employee concerns, and quality assurance and mar,agement oversight improvements.
The plan also includes -
staff activities to evaluate the licensee's responses to NRC's 10 CFR 50.54(f) letters regarding Millstone Units 1.
- 2. and 3. and completion of the Inde)endent Corrective-Action Verification Program.
The RA) also contains a unit-specific Significant Items List (SIL), which contains specific items that are being used by the NRC to audit and evaluate licensee programs and significant safety / regulatory issues. Additionally, the actions listed in the MC 0350 generic restart checklist that are applicable to Millstone, such as those regarding management effectiveness and self-assessment capability, are also included in the plan.
STATUS:
The RAP is periodically updated. The inspection and closure of RAP items is in the initial stages for all three units, As a result of the licensee's decision-to focus its recovery / restart efforts on Units 3 and 2. the NRC RAP activities are also being directed to these units.
The
licensee is providing Sll closure packages for NRC review and has scheduled the SIL closure package submittals for Units 2 and 3.
There has been some slippage in the schedule for these closure package submittals.
As of July 16. 1997, the NRC staff has closed 23 of the 86 items for Unit 3 and four of the 51 items for Unit 2.
1
- ISSUE:
Independent Corrective Action Verification Program DISCUSSION:
On August 14, 1996, the NRC issued a Confirmatory Order establishing an Independent Corrective Action Verification Program (ICAVP).
The independent effort, carried out by a contractor approved by the NRC. will verify the adecuacy of Northeast Utilities
- efforts to establish adequate cesign 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 ICAVP is intended to provide additional assurance, before unit restart, that the licensee has identified and corrected existing problems in the design and configuration control processes.
It includes a three-tiered approach, as described in SECY-97-003, " Millstone Restart Review Process." dated January 3,1997, for a sample evaluation of the licensee's activities.
The NRC oversight of the ICAVP is one of many dCtiVities that make up the Restart Assessment Plan (RAP).
The results from this program will be considered as a significant part of the decision regarding recommended restart.
The licensee is implementing its Configuration Management Plan (CMP), which is intended to confirm that the future operation of Millstone Units 1, 2, and 3 will be conducted in accordance with the terms and conditions of their a)plicable operating licenses UFSAFz, and NRC regulations.
l T1e CMP includes efforts to understand the licensing and design bases issues, which led to issuance of the 10 CFR 50.54(f) letters and actions to prevent recurrence of those issues. The Unit 3 CMP includes a review of the licensing basis requirements for the 88 systems that the licensee has categorized through the implementation of the maintenance rule as either Group 1 (safety-related and risk-significant) or Group 2 (safety-related or risk-significant). Following completion of problem identification of one-half of the Group 1 systems, the ICAVP contractor can begin its review.
The licensee is scheduled to complete the problem identification phase of the CMP for Unit 3 on July 14, 1997, and on September 5, 1997, for Unit 2.
NRC^ ACTION:
The staff's oversight objectives are to ensure that the review by the ICAVP contractor is independent of the licensee and its design contractors, is performed by qualified individuals, and is comprehensive, incorporating appropriate engineering discipline and operational reviews.
In accordance with the Confirmatory Order, the NRC will review and approve the proposed ICAVP contractor for each
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unit and-the contractor's audit plan-for each review.
The-staff will select the specific systems to be evaluated in
-the ICAVP. With in?ut=from the Connecticut Nuclear Energy i
Advisory Council (1EAC).
The NEAC is expected to select some of the systems.to be reviewed by the ICAVP contractor.
While key design aspects of many of the systems being
-evaluated by the licensee will be assessed in the ICAVP.
four systems will be examined in detail by the contractor.
.The scope of the ICAVP will be increased if issues are identified in the assessment of the licensee's corrective actions.
4 l
In addition to overseeing the' activities of the ICAVP--
contractor, the staff will perform its own independent inspections.
The staff plans to conduct independent vertical-slice inspections of at least two systems: one within the scope of the ICAVP and one outside the sco)e.
1 l
The staff will evaluate the final results of the ICAV) contractor's audit and assess the licensee's corrective actions. The details about the staff oversight plans are
' contained-in SECY-97-003.
l STATUS:
The staff bpproved Sargent & Lundy for the conduct of the Millstone Units 1 and 3 ICAVP on April 7,1997.
The licensee completed problem identification on one-half of the Group 1 systems for Unit 3 on May 27. 1997. The staff approved the Sargent & Lundy audit plan on June 3. 1997, and selected the first two systems for ICAVP review (Service Water pystem and the Quench Spray / Recirculation Spray
' System ).
The staff approved Parsons-Power Group Inc.. for the conduct of the Millstone Unit 2 ICAVP on May 28, 1997.
The audit plan remains under review.- The licensee completed problem identification on one-half of the Group 1 systems June 30-.
1997. The staff selected the first two systems-for review (High Pressure Safety-Injection System and the Refueling Water Storage Tank as one system and Auxiliary Feedwater and the Condensate Storage Tank as the other system).
2The Quench Spray System and the Recirculation Spray System are identified as two separate systems bv the licensee but they are being-considered as one system for review by ICAVP.
. ISSVE:
Handling of Safety Concerns Raised by Licensee Employees DISCUSSION:
In its September 1996 report, " Millstone Independent Review Group Regarding Millstone Station and NRC Handling of Employee Concerns and Allegations " the NRC staff determined that. in general, an unhealthy work environment, which did not tolerate dissenting views and did not welcome nor promote a questioning attitude, has existed at Millstone
)lants for the past several years.
This poor environment 1as resulted in repeated instances of discrimination and ineffective handling of employee concerns.
On October 24.-1996, the Director. Office of Nuclear Reactor-Regulation, issued an Order to Northeast Utilities (NU) requiring the licensee to take specific actions to resolve problems in the process for handling employee safety concerns at the Millstone station.
The October 24, 1996, Order required the licensee to develop, submit-for NRC-review, and begin implementation of a comprehensive plan for (a) reviewing and dispositioning. safety issues raised by its employees, and-(b) ensuring that employees who raise safety concerns are not subject to discrimination. -The licensee submitted the plan to the NRC on January 31, 1997, - and has begun implementation of completed plan sub-elements.
The Order further required the-licensee to submit, for NRC approval.-a proposed independent, third-party organization-to oversee implementation of the above comprehensive plan.
The licensee submitted the proposed third-party organizaticn, Little Harbor Consultants. Inc. (LHC). to the NRC on December 23, 1996. On April 7, 1997 the NRC approved LHC as the third-party organization. The Order specified that once approved. the third-party organization develop and submit for NRC approval an oversight plan for conduct of their activities,- The-third party oversight plan -
was submitted by LHC to the NRC for approval on May 2, 1997.
The plan for independent, third-party oversight will continue to be implemented until the licensee demonstrates, by its erformance, that the conditions, which led to the requireents of that oversight, have been corrected to the satisQ ction of the NRC.
NRC ACTION:
The NRC staff will perform the following functions regarding employee concerns: (1) review and comment on the licensee's comprehensive plan, (2) review and approve the third-party organization for oversight of the comprehensive plan, (3) review and approve the third-party organization oversight plan, and (4) assess effectiveness of licensee implementation of its programs for handling employee safety concerns.
6-STATUSi-
.The staff has reviewed and provided comments to tha licensee on the comprehensive )lan. At a May 13, 1997, meeting-between the NRC and t1e licensee, the licensee gave a--
detailed presentation on the-content and-implementation of-its comprehensive plan._ The presentation included res1onses
-to staff comments-on the plan. Written responses to NRC comments on the plan were provided by the licensee at a May 21. 1997, meeting with the NRC.
By-letter dated April 7. 1997, the staff approved Little Harbor Consultants,. Inc. (LHC), as the third-party organization to provide oversight of the licensee's implementation of its plans. The staff is reviewing the-acceptability of the oversight plan.-which was submitted by LHC on May 2, 1997.
The NRC staff is developing a -)lan for monitoring the licensee's implementation of tie comprehensiva plan and LHC oversight of that implementation.
- Further, e staff will conduct a team inspection of the licensee's 1mplementation of its programs for handling employee concerns prior to the restart of any of the Hillstone units.
7-ISSUE:
Licensing issues DISCUSSION:
Each unit plans to or has submitted-licensing issues (amendments, unresolved safety questions, relief requests, etc.) that will need to be reviewed and approved prior to restart.
NRC ACTION:
The staff will process and review licensing actions as they are identified and submitted by the licensee.
The staff will follow the normal processes for these actions.
STATUS:
Unit 3:
As of July 2.- 1997, the licensee has identified 23 licensing actions that need to be completed prior to restart. Twenty-one have been submitted to the NRC with the other two licensing actions scheduled to be submitted by the 1
end of July 1997. Of the 21 submitted to the NRC. six have been issued and the other 15 are under NRC review.
Unit 2: As of July 2.1997, the licensee has identified 16 licensing actions that need to be completed prior to restart.
Eight have been submitted to the NRC.
One licensing action has been completed by the NRC staff and the other seven are under staff review.
Unit 1: As of July 2.1997, the licensee has identified six licensing actions-that need to be completed prior to restart.
Five have t'een submitted to the NRC with the remaining licensing action scheduled to be submitted by the end of July 1997.
Of the five submitted to the NRC one license amendment has been issued and the other four license amendments are currently under NRC review.
The majority of the license amendments' deal with verbatim compliance issues or clarifications. However, the licensee is currently reviewing three additional issues that may require license amendments prior to startup.
Theamendmentssubmitted-todateandthestaff'sprojected review schedule do not appear to impact the licensee s ability to restart on its current schedule. However, the staff has requested additional or clarifying information on several license amendment requests, which has lengthened the review process.
Future submittals or new emerging _ issues, which require extensive staff review, may impact the
-licensee's projected schedule.
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8 t
ISSUE:
10 CFR 50.54(f) Activities DISCUSSION:
On December 13. 1995, the NRC issued a letter to Northeast Utilities (NU) requesting Nd,-pursuant-to 10 CFR 50.54(f).
to provide information describing actions taken to ensurc that future operations of Millstone Unit I will be conducted in accordance with the terms and conditions of the Millstone Unit 1 operating license, the Commission's regulations, including 10 CFR 50.59, and the Millstone Unit 1 Updated Final Safety Analysis Report (UFSAR).
Similar letters were issued to NU for Millstone Unit 2 on March 7.-1996, and Unit 3 on A)ril 4.1996.- -In those letters, the NRC recuested tlat the information be submitted no later than 7 cays before restart of the respective Millstone units.
By letter dated May 21, 1996. the NRC further requested, pursuant to 10 CFR 50.54(f), a comprehensive list of design and configuration deficiencies identified after the December 13, 1995. letter for Millstone Unit 1 and after the ACR 7007 - Event Response Team Report was issued for Millstone Units 2 and 3.
Due to the increased level of NRC oversight, the units-at Millstone being classified as Category 3 plants, the two oreviously mentioned Orders, and the creation of the Special projects Office, the information needed by the NRC before plant restart has changed.
Therefore, by letter dated A)ril 16, 1997, the NRC superseded the requests contained in tie previously mentioned 10 CFR 50.54(f) letters and requested the following items: (1) the significant items that are needed to be accomplished before restart, (2) the list of items to be deferred until after restart, (3) the-process and rationale NU is using to defer items until after restart, and (4) a description of the actions taken to ensure that future operation of the unit (s) will be conducted in accordance with the license, regulations, and UFSAR.
Items 1. 2 and 3 were-requested to be submitted.
within 45 days of the-letter and items 1 and 2 were to be updated approximately 45 days thereafter.
Item 4 was requested to be submitted 14 days prior to the Commission meeting for each individual unit.
By letter dated May 29, 1997, the licensee submitted the requested information (Items 1. 2, and 3) for Millstone Units 2 and 3.
The licensee did not submit the information for Millstone Unit 1 due to a recent decision to scale back work and minimize resource expenditures during 1997. The licensee committed to include the information for Millstone Unit 1, as well as an update for Millstone Units 2 and 3 in its next submittal (approximately July 13, 1997).
e 9
NRC ACTION:
The NRC staff will review the licensee's submittal-and will conduct an inspection, for each unit. of the licensee's process for deferring items until after restart.
The inspection will include a review of the list of deferred items and an audit of a representative sample.
STATUS:
The NRC staff is reviewing the licensee's submittal and plans to conduct an inspection of the licensee's process for deferring items until after restart.
The inspection is scheduled for the July August 1997 timeframe for Millstone been scheduled. pection for Millstone Unit 2 has not yet Unit 3.
The ins i
1
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ISSUE:
Corrective Action Program DISCUSSION:
The NU corrective action program has been weak in ensuring comprehensive and effective corrective actions. There have been many instances of narrowly focused corrective actions that failed to resolve all aspects of the underlying problem.
Additionally, the licensee has failed to follow up on corrective actions to ensure effectiveness.
NRC ACTION:
The NRC inspection staff will concentrate on issues for each unit idenafied by the licensee's Condition Reports (CRs) process and audit the licensees corrective actions for completeness.
The staff is periodically selecting CRs for review, based on the licensee's assigned level of importance, or their risk significance, as perceived by the NRC staff.
Additionally, other CRs will be examined by the staff to provide a broader spectrum of corrective action issues.
The primary intent is to assess the corrective action program while evaluating safety significant technical issues. Additional insights will be gained from the MC 40500 inspection, closure of the significant items list issues, closure of licensee event reports, and the normal inspection program where valuable insights regarding the effectiveness of corrective actions are routinely collected.
Additionally, the NRC staff, through oversight of the Independent Corrective Action Verification Program, will assess the licensee's corrective actions for degraded and nonconforming conditions.
A team inspection, using NRC Inspection Manual Chapter 40500. " Effectiveness of Licensee Controls in Identifying.
Resolving, and Preventing Problems," is planned for early October.
It will look primarily at the corrective action program, licensee resolution of problems, operating experience feedback, self assessment activities, and on-site and off-site safety review committees.
Finally, the Operational Safety Team Inspection (OSTI) will audit portions of the corrective action process during the course of its activities.
STATUS:
The inspections performed to date indicate increased management focus on the corrective action program problem at Units 2 and 3.
The staff has noted improvements in the quality of the Significant Items List closure packages
-provided by the licensee.
I
. Theinspectionresultsof16openitems{LicenseeEvent Reports (LERs). Escalated Enforcement items (Eels).
Violations, and Unresolved items (URis)} at Unit 2. reviewed in NRC Inspection Report 96-08. were compared to inspection results of 15 open items in NRC Inspection Report 97-02.
The results of this comparison indicate that the licensee has made some )rogress regarding the quality of corrective
- actions, in tie recent report the corrective actions for 12 of 15 open items were acceptable to the NRC while only four of 16 were acceptable in Inspection Report 96 08.
In the recent report, a violation was issued for one of 15 open items, while in the earlier re) ort seven Eels and two violations were associated wit 1 16 open items.
The most recent Millstone site inspection report. 97-02 (June 24, 1997), examined the correttive action program at Unit 1. and indicated that overall, the implementation of procedure RP-4 " Corrective Action Program " Revision 4. has resulted in only limited improvements in the corrective action process.
The revision of the condition report (CR) process was poorly implemented in that specific guidelines were not put in place to ensure the initiation and appropriate processing of CRs for conditions adverse to quality.
ISSUE:
-Oversight
-. DISCUSSION:
The licensee has identified its oversight function as-deficient through self-assessments and-external and internal audits, and has identified its oversight function as a contributing factor in its declining performance.
The Yankee Atomic Electric Company (YAEC), as described in the report " Assessment of Past Ineffectiveness of Independent-Oversight." examined the failure of Quality Assessment
' Services (0AS), the Independent Safety Evaluation Group, and the Nuclear Review Board (NRB) to identify specific program deficiencies.
YAEC found that management did not support these oversight functions adequately.
The licensee recently had an independent review of the nuclear oversight function performed by an outside i
consulting firm. The results have not yet been released, NRC ACTION:
The NRC assessment of the nuclear oversight function is addressed through insights gained from the normal inspection program.
In addition. the NRC will perform a special inspection of the oversight function using NRC Inspection-Manual Chapter 40500.- Additionally, the OSTI will inspect how effectively the oversight' function has been integrated into the operation of the plants.
STATUS:
With the implementation of the program revisions, recovery activities, and organizational initiatives still ongoing.
the-impact and effectiveness of the changes-in the nuclear-oversight function have not yet provided measurable results.
The staff has observed increased Nuclear Safety and Oversight-(NS&O) involvement in performance monitoring.
interfacing analysis, and support of the Unit 3 management and line staffs.
Such involvement has included "real time" evaluation and feedback on routine operational activities and nonroutine events.
The NRC's assessment of NS&O-effectiveness (including an' expectation of demonstrable results of the corrective action program improvements) and specific 0AS activities will continue over the course of the next several inspection periods, covering the ongoing recovery, open item closure. and work associated with the startup planning for the unit.
i
' 4 13 -
- ISSUE:
- Enforcement Status DISCUSSION:.
A Predecisional Enforcement Conference was held with the
-licensee.on December 5, 1996, to discuss 64 individual-apparent violations Subsequent inspections have-identified-.
additional.. examples of.similarLviolations that have been incorporated into the-enforcement package,~ increasing the number of violations to approximately 80 individual items, The licensee did not contest any of the violations at the conference, and the staff is in the. process of finalizing the enforcement package.
NRC ACTION:
Once enforcement actions have been taken, the NRC will evaluate-the licensee's corrective action to those enforcement actions that are determined to impact.the restart of each unit, STATUS:
The rate of new enforcement item identification remains fairly constant for Units 1, 2, and 3, On February 3-7, 1997, an inspection identified several violations in the security area. The violations involved the failure to properly. control vehicles in the protected area, the failure to control safeguards information, and the failure to properly perform personnel searches prior to granting protected area access, :The first two of_these violations were cited in the past, and it appears that corrective actions were not effective, A civil penalty-of
- $55,000 was issued on June 11, 1997, to Northeast Nuclear Energy Company.
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- -ISSUE:
Work Planning and Controls DISCUSSION:
Work planning and controls are other areas in which the licensee has shown a weakness.
The ability to
)lan, control, and complete work is fundamental to ac11eving adequate corrective actions.
Effective work planning and controls are prerequisites for reducing and managing backlogs.
Weak work planning and controls were demonstrated during the Unit 2 outage, wherein. tagging boundary violations resulted in an extensive effort by the licensee to correct the identified weaknesses.
Work planning and controls were also 1ssues at Unit 1.
NRC ACTION:
There will be a complete review of the licensee's site wide Automated Work Order (AWO) process by the NRC staff.
The AWO process is an integral part of the work planning and control system and is instrumental in establishing the scope of the work, praviding the appropriate procedures, and establishing the tagging boundaries.
The Operational Safety Team Ins-)ection (OSTI) will assess engineering and maintenance bacdogs during its operational readiness inspection. The OSTI will determine if there are safety significant issues that must be resolved before restart.
STATUS:
An NRC inspection of the AWO process was performed during the inspection period ending in October 1996.
In that inspection, which focused on Unit 1. the inspectors found that a new work control process was instituted in June 1996 in an effort to im) rove the overall process.
The inspectors observed that a su)stantial number of work orders were being returned for an assortment of reasons, all of which impacted the ability of the work force to efficiently conduct maintenance. Current licensee data for the corrective maintenance work orders required for restart of Units 1 and
- 2. indicate little or no progress on reducing the backlogs.
Recent licensee data indicate a modest reduction in the AWO backlog to support startup for Unit 3.
15 -
- 1SSUE
Procedure Upgrade Program DISCUSSION:
The quality of and adherence to procedures have been a chronic problem at the Millstone site, This-issue was an l
element in " Improving Station Performance" and the earlier j
" Performance Enhancement Program." and was one of the i
subjects of discussion at the aeriodic meetings between NU and the NRC.
In response to NRC concerns, the licensee developed the Procedure Upgrade Program (PUP) in the early 1990s to improve station procedures.
Before the reorganization in October 1996, there was a station-wide Procedure Upgrade Group that provided overall control of the PUP This group developed and maintained the station document control (DC) procedures for control of the program, the overall status of upgraded procedures, coordinators for each Millstone unit, and the hiring of contractors, as necessary, to write the procedures.
Since the licensee's reorganization in October 1996, the PUP group has been decentralized.
The station-wide group now only controls the station administrative procedures including the PUP DC procedures.
The implementation and quality of procedure upgrades are now the responsibility of the individual technical departments within each unit, NRC ACTION:
The staff, in its inspection of selected plant procedures, will identify whether the procedures have been upgraded and will evaluate the effectiveness of the PUP, NRC inspections will include an assessment of the PUP for each Millstone.
unit.
i STATUS:
The Procedure Upgrade Program has been effective in standardizing procedure formats. The document control procedures are lengthy and somewhat difficult to use, but are comprehensive. The PUP is scheduled to be completed before the startup of.each unit, and in the case of Unit 3, should be ready for inspection by the OSTI in October 1997.
ISSUE:
Inspection Activities and Results STATUS:
The most recent inspection report (June 24, 1997), for the Millstone Station identified, at Unit 1, a violation involving failure to translate correctly the plant design basis into drawings and to implement appropriate administrative controls on the positions of certain containment isolation valves in the main feedwater system.
Additionally, it was identified that corrective actions were inadequate to address a Unit 2 single failure vulnerability associated with an enclosure building dam)er.
Finally, five examples of unauthorized radiciogical worcers or workers lacking proper dosimetry entering or working in the radiologically controlled areas, one each in Units 1 and 3 and three in Unit 2, were identified.
The first two items are historical in nature: they are similar to issues which have previously been identified by the licensee and the NRC, and they are the focus of ongoing corrective actions.
The radiological issue is a current finding.
This report also discusses several apparent violations of NRC requirements at Unit 1 pertaining to the conduct of containment leakage rate testing, failure to aerform safety evaluations required by 10 CFR 50.59, inoperaaility of the low pressure coolant injection (LPCI) system, failure to trend condition reports as required by plant procedures, and failure to identify and correct significant conditions adverse to quality associated with containment leak rate testing and fouling of LPCI system heat exchanger tubes.
These items represent a mixture of current and historical -
issues.
On June 26, 1997, the operators for Unit 3 identified increasing temperature in the spent fuel pool (Ref:
Preliminary Notification dated June 27, 1997).
The spent fuel 2001 cooling configuration was altered the previous day and tie operators failed to identify the fact that when they made the changes they, in fact, removed all cooling to the spent fuel pool. The actual safety significance of the event is very low: however, the issue raises concerns about licensee management of plant configuration.
In December 1996, the NRC administered initial senior reactor operator examinations.
Six of the seven applicants failed the examinations.
Subsequently, the licensee performed an independent review of the training program and identified additional problems with the licensed operator training program.
In a March 3, 1997 letter, the licensee committed to implement a series of corrective actions.
On March 7,1997, the NRC issued a Confirmatory Action Letter regarding the identified deficiencies and corrective actions.
' As a result of the known deficiencies within the licensed o>erator training program, the NRC performed a Manual Clapter 41500 inspection of the nonlicensed training program..This was done in parallel with a licensee Nuclear Oversight audit of the srca area.
Based on the results of the audit and inspection, the licensee stopped all training on the site. As of July 10. 1997. only limited training such as the licensed operator training for Unit 3 has been resumed.
The audit identified that the feedback process to improve the training program vas not being implemented.
The licensee is planning to oegin reloading the reactor core on August 2. 1997, at Unit 2.
The NRC staff is planning inspections of the licensee's regulatory compliance during mode change, management oversight and involvement, operator i
performance, and Nuclear Oversight involvement.
I f
ISSUE:
Operational Safety Team' Inspection DISCUSSION:
As a final check before the staff would be in a position to recommend restart of each individual unit, the staff will conduct an inspection to verify that the pl6nt operations are being conducted safely and in conformance with regulatory requirements.
The staff will verify that the organizations that control and support plant operations are functioning effectively to ensure operational safety.
Elements of the inspection include operations, maintenance, surveillence, management oversight, technical support, safety review,- quality assurance, and corrective action.
l Additionally. the staff will verify that the licensee has properly prepared the staff and the )lant for resumption of l
power operations after an extended slutdown.
I NRC ACTION:
NRC management will designate a team leader and arrange for the approariate technical inspectors.
The team-leader will-develop tie scope of the inspection and determine the necessary technical disciplines to adequately inspect the
- plan, The inspection team typically is given 1 to 2 weeks to prepare for the inspection, 2 weeks (or more, if needed) onsite to perform the-inspection and 2 weeks-to write the report inputs.
A formal exit interview with the licensee is held-1 to 2 weeks after the last day of inspection to present the findings and receive any completed corrective actions from the' licensee.
STATUS:
The team leader for Unit 3 has been tentatively identified and preliminary planning has begun.
The insSection for Unit 3 is scheduled to start October 13, 1997, T1e inspection for Unit 2 is scheduled to start January 5.-1998.
4
I
,p>" ""%,,,
4 d
RESTART ASSESSMENT PLAN l
HILLSTONE STATION
'//
APPROVED:--
- 0 t* -
DATE: JULY 22,1997 WILLIAM D TRAVERS DIRECTOR, S ECIAL PROJECTS
i 4
MILLSTONE RESTART ASSESSMENT PLAN
~
11.0 BACKGROUND
The three Millstone units are 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. The 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. Currently, the results of those inspections are under assessment by the team and NRC management. The licensee initially focussed on Unit 3 as the lead plant for restart. However, as a result of a licensee L
reorganization which occurred on October 1,1996, each Millstone unit was 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 t
l returned to their respective units Cach unit has been tasked with establishing their i
own restart plan and whichever unit is ready will apply to restart first. Hence this
-l restart assessment plan has been expanded to include Manual Chapter (MC)-0350 evaluations (see paragraph 3.0) for all three units.
I On June 28i 1996, the Executive Director for Operations (EDO) issued a letter to i
the licensee that stated the Commission had decided to make the three Millstone l
- units a Category 3 on the Watch List and would vote on the restart of the Millstone 1
l-units, it is the intent to implement the appropriate aspects of NRC Manual Chapter l
0350, " Staff Guidelines for Restart Approval". for the restart of all three units. The l
NRC will schedule and implement its inspection program after the licensee has -
l indicated that the individual activities necessary for restart are complete and ready l.
for inspection.
l The NRC has been dealing with Northeast Utilities on broader performance issues-i!
which go beyond the 10 CFR 50,54(f) concerns. These broader concerns are considered contributory causes for the current poor performancei which the 10 CFR
- 50.54(f) issues are a subset. These issues have been formalized by the licensee in i'
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.
o The salient concerns embodied in the ISP include leadership, communications -
I (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 4
inspection of the improving Station Performance issues is discussed in more detailin Section 3 of this plan.
?
Revision 3/24/97 e
1
2 On Novernber 3,1096, the agency established the Special Projects Office (SPO) to consolidate NRC efforts, under e 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.
2.0 10 CFR 50.54ff) Activities Each Millstone unit has been 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 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 deficier.cy was identified and will 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 cversight 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. The deficiencies found by the licensee as a result of the BO.54(f) letters will be evaluated by the Millstone Restart Assessment Panel to identify restart issues.
3.0 MC 0350 Process Millstone Unit 1 entered a routine refueling outage on November 3,1995. On December 13,1995, the NRC sent a 10 CFR 50.54tf) letter requiring the licensee to certify compliance with the regulatory requirements before restarting the unit. At the January 1996 Sanior Management Meeting, the site was placed on the " Watch List" for various reasons, including a concern for regulatory compliance.
Subsequently, Millstone Units 2 and 3 were sent similar letters which required responses before restart.
Revision 3/24/97 i
3 The NRC Inspection Manual, 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 l
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 I
applicable requirements have been met (Enclosure (4).
The Director, SPO, in coordination with the Deputy Executive Director fors Regulatory Programs, and the Director of NRR, will make a recommendation regarding restart. NRR and the SPO willinform the Commission of the staff's and licensee's restart activities through Commission papers, or communications to the EDO. - The Commission will then vote on whether to approve the restart of each
' Millstone unit.
3.1 SPECIAL PROJECTS OFFICE 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 Program Oversight; the Project Managers for the three Millstone units; the Inspection Branch Chief, the Senior Resident inspectors for the three Millstona units, and the appointed Division of Reactor Safety representative. The function of the Millstone RAP is described in MC-0350, 3.2 MILLSTONE OPERATIONAL READINESS PLAN
.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 line managers (President, Vice Presidents, and two of the three unit directors) in the recent past. With this replacement, the submitted plans for Unit 3 and the proposed plans for Units 1 and 2 are being changed substantially. The RAP will review these plans and hold periodic meetings with NU, open to the public, to discuss the schedule for implementation and coordination of NRC restart activities.
Revision 3/24/97
4
- 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 audited by the NRC to verify the acceptability of the criteria used to defer items -
- from the restart list.
3.3 CORRECTIVE ACTION PROGRAM The NU corrective action program has been weak in ensuring comprehensive and effective corrective actions. There are many instances of narrowly focused corrective actions that f ailed to embrace all aspects 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 Adverse Condition Reports (ACR) being identified by the licensee's staff, the resident and togional inspection staff will concentrate on issues for each unit identified by the ACR process and audit the licensees corrective actions for completeness. The staff is periodically selecting ACRs for review, based on the licensee's assigned level of importance, or their risk significance, as perceived by the resident staff. Additionally, other ACR's will be examined to provide a spectrum of safety significant and lessor risk issues. These selected ACRs 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 review the Action Requests (AR) from the Action item Tracking and Trending System (AITTS) program, which is an extension of the ACR process, and commitments regarding violations and inspection items. - Further, a significant input to assessing the licensee's corrective action program is derived from the normal inspection program where valuable insights regarding the effectiveness of corrective actions are routinely collected from the technical safety inspections.
Additionally, the NRC Independent Corrective Action Verification Oversight Branch will assess the licensee's corrective actions for degraded and non-conforming conditions. Finally, the Operational Safety Team inspection (OSTil'will audit portions of the corrective action process during the course of its activities, i
Demonstration of improvements in the process will be judged by the completeness of the licensee's correcth'e actions for each of the inspected ACR's. Tnere must be a high ratio of successfuity completed ACR's to the total population inspected.
There should only be minor comments regarding the processing, evaluation, directed corrective actions and closure of an issue.
Revision 3/24/97
5 3,4 WORK PLANNING AND CONTROLS (C.4.)'
Work planning and controls are other areas that the licensee has shown a i
weakness. The ability to plan, control, and complete work is fundamental to achieving adequate corrective actions. Effective work planning and controls are prerequisites for reducing and managing backlogs. Weak work planning and control was demonstrated during the Unit 2 outoge, 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 management 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 instrumental in establishing the scope of the work, providing the appros,riate procedures, and establishing the tagging boundaries. Consequently, the Unit 1 resident staff has been directed to use the available initiative inspection hours to do a comprehensive inspection of the AWO process, which is a site-wide process.
The OSTI will assess the engineering and maintenance backlogs during its l
operational readiness inspection. The OSTI will determine if there are safety significant issues that must be resolved before restart.
3.5 PROCEDURE UPGRADE PROGRAM (C.3.3.el 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 tlie NRC. In response to NRC concerns, the licensee developed the Procedure Upgrade Program in the early 1990's to improve station procedures.
The resident inspectors will relate procedural inspection findings back to the 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 establish a basis for assessing the effectiveness of the licensee's PUP. The NRC staff will develop an inspection plan for examining selected portions of eich unit's individual efforts.
3.6 OVERSIGHT (C.1.41 The licensee has identified its oversight function as deficient through self-assessments and external and internal audits and as a contributing factor in the licensee's declining performance. The report of Assessment of Past Ineffectiveness 1 Reference to applicable MC-0350 section Revision 3/24/97
6 of Indanandant Overslaht by the Yankee Atomic Electric Company (YAEC),
examined the f ailure 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, in additioni the Joint Utilities Management Association (JUMA) issued its report on July 17,1996. One conclusion was that the quality ascurance (QA) program audits, surveillances, and inspections were not effective in the implementation of their mission and resolution of identified problems, in addition, the JUMA audit found that recommendations for improving QA effectiveness identified in previous OA-internal and external assessments have not been addressed.
The NRC assessment of the nuclear oversight function is addressed as part of the RAP's review of the ISP program and through insights gained from the normal inspection program, in addition, the NRC will perform a special inspection of the.
l oversight function using the services of its Human Factors Assessment group. 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 made an integral part of the licensee's management team assessment process. The oversight function should result in meaningful findingsi have access _to line 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.
3.7 ENFORCEMENT 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 the spent fuel pool and 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 Investigations, the allegation process review group, the Office of the Inspector General, the Special inspection Team, routine resident and regional inspection 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 not contest any of the violations at the conference, and the staff is in the process of Revision 3/24/g7
7 finalizing the enforcement package. Once enforcement actions have been taken, 4
the NRC will evaluate the licensee's corrective action to those enforcement actions which are determined to impact restart of each unit.
3,8 EMPLOYEE CONCERNS The Millstone site has had a chronic problem in dealing effectively with employee concerns. 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 Millstene, as well as an allegation, and_a subsequent Millstone 10 CFR 2.206 petition, dealing with the 1
Unit 1 spent fuel pool. The NRC has issued two enforcement actions for harassment and intimidation to NU in the past three years and has a current escalated enforcement action pending.
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. Subsequently, the NRC issued an order, dated October 24,1996, requiring NU to establish a comprehensive program to address employee concerns, and hire an independent party to oversee the implementation of the program. The output from these two task groups and the licensee's response to the order will be reviewed for restart issues.
3.9-SIGNIFICANT ISSUES LIST 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 criterie for inclusion as a restart item. The resident inspectors, augmented by headquarters staff, are reviewing these liste periodically and confirming that the licensee is performing an adequate assessment'of the discrepancies. This process will be used-in the restart assessment of each unit. The RAP will determine that licensee's restart issues list includes appropriate restart items from the licensee's programs such as ACR, AR (AITTS), engineering work requests, and commitments.
The enclosed NRC Significant issues Lists for all Millstone units (Enclosure 1, 2 and
- 3) contain some of the items that are being used to audit and evaluate licensee Revision 3/24/97 m
i t
8 programs such as the corrective action process and significant safety / regulatory technical issues.
Restart issues wiil meet at least one of the following criteria:
1.
Resolution of the issue is required to ensure safe operation of the facility to include satisf action of the technical specifications or licensing basis.
Inspection of the issue will provide an insight to an identified programmatic 2.
deficiency such as the corrective action system.-
t 3.
Inspection of the issue will provide assessment of management effectiveness or g
personnel performance.
3.10- RESTART INSPECTION Selected portions of NRC MC-93802, " Operational Safety Team inspection," will-provide the framework for a team inspection of each ur.it during the restart process.
The procedure scope will be modified to address the pertina issues at Millstone.
The inspection will cover soli assessments by the licensee, the licensee's implementation of its startup plan, control room observations during the approach to criticality and power ascension, selected systems readiness inspection and observation of management oversight.
The resident inspectors will provide close monitoring of each unit during mode changes to ensure compliance with each unit's technical specifications and FSAR i
design bases.
3.11 PLANT PERFORMANCE REVIEW On March 19,1997, the Millstone Oversight Team conducted a Plant Performance 4
Review (PPR). The PPR was used to identify the issues that_needed to be inspected for the Millstone station. The review identified severalissues that warrant NRC inspection before plant restart of the unit. The unit specific issues, as well as station wide issues identified by the PPR, are contained in the SIL for each unit as iinspection items.
3.12 LICENSING ISSUES Each Millstone unit plans to submit or has submitted licensing issues (amendments, unresolved safety questions, relief requests, etc.) which will impact the restart process. The SPO Licensing Branch will disposition each applicable issue prior to restart. The status of NRR actions concerning nach issue is documented in Enclosure (5) of this plan.
Revision 3/24/97
______.___.___m__-
9
Enclosures:
-(1)-
- Significant items List - Millstone Unit 1 (2)
Significant items List - Millstone Unit 2
.(3)
- Significant Items List - Millstone Unit 3 ~-
(4)-
MC 0350 Restart Approval Checklist - All Millstone Units-
_ 5)
Licensing Amendment Requests
(
i
'l l
Revision 3/24/97
-,-----r--,.---
t 0
i i
ENCLOSURE 1 SIGNIFICANT ITEMS LIST - MILLSTONE UNIT 1
6 MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (1)
Millstone Unit 1 Significantitems Lita R6FERENCE MILLSTONE UNIT 1 INSPECTION ITEM RESP STATUS 1
ACR.01148 FSAR Adequacy for Restart SPO (L) 2 ACR:01535 While de watering spent resin, the waste tempereture DRS in the liner raised from 90 to 310'F l
l 3
ORDER Employee Concerns Program SPO Hannon R,, "
eSenior management has created difficult working (L) e 0921 environment l
EA: 96 59 l
MC 0350 l
C,1.4.e, C.S.d. C.2.2.b l
4 MC 0350 Review enforcement and unresolved iterr,.or restart SPO (1)
C.S.e issues 5
MC 0350 C.5.f Review allegations for restart issues SPO(l)
SPO(L) 6 Review all operability determinations and by pass SPO (l)
Jumpers before restart 7
LER: 96 22 Fatigue cycle open items DRS URl: 92 30 2
\\"
e_
MC 350 Security issues Corrective Action DRS C.3.1.13 EEt: 96 0515, 97 03 01 (02){03);
VIO: 90 09 20 9
Review licensee event reports fv ',estart issues SPO (l) 10 ACR: 05373, Material Equipment and Parts SPO(L)
M197 0358 List (MEPL) Program DRS 11 ACR: 961068, RPS System SPO (1) 7245 eScram solenoid pilot valve replacement 12 LER: 96 48 Overlap testing of RPS/ESF DRS GL 96 01 13 97 ACR:
1 o45 1
Revised 7/16/97
REFERENCE MILLSTONE UNIT 1 INSPECT 60N ITEM RESP STATUS 13 Tl 2515/109 Motor Operated Valves (GL 8910)
DRS URI:94 005-02.94 005-04,95 001 01,96 005 05 LER:96 52 ACR: 03689, M197 0397, 0384,6988 14 ACR:M196-Surveillances Program Review SPO (1) 0992 LER: 9616 V10:95 007 02 LER: 96 42 15 ACR:10790 Control /Use of Vendor Information DRS (U 3) 16 ACR:M196-Redwaste recovery / configuration.
DRS 0915,M1 97 E 95 003 01 einsufficient management support for maintenance of LER: 97 001 radwaste MC 0350
- RW effluent isolation valve OA classification C.2.2.c 17 eel: 96 09 05 Corrective Action Program Effectiveness SDO (1)
Update 97 02 01; lR:97 02
,5,'i$0f0##
- Review licensee corrective action programs for SPO 3
IR: 96 04 effectiveness to include ACR's.
(0) gCR M196-
- Corrective actions have been ineffective in resolving probl6ms
- 1331c, M196 081J,
- M1961035, M197 0342, 0343 MC 0350 C.1.1, C.).3, C.1.4.d, C.2.1 h.
C 3.1 d 18 Review 0737 action items for completion and SPO (1) adequacy 19 Review engineering backlogs SPO (1) for restart issues 20 ORDER Implementation of CMP /ICAVP corrective actions.
SPO MC0350 C.5.d (O) 2 Ravised 7/16/97 J
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REFERENCE MILLSTONE UNIT 1 INSPECTION ITEM RESP STATUS 21 ACR: 03117 eSingle f ailure can disable both trains of emergency DRS
{$'[,81',03[
power source LNP lockout ielay 77 n
- Review LNP integrated procedure and results ACR: M197 0323,0417
$8j3,'j07 e setpoint drift resolution 0
M196 e accelerated testing l
0622,1120 e electric lift modification adequacy l
e electric lift setpoints rjot fully evaluated j
23 ACR: 6264 Configuration Management / Design Control Process SPO 06239,M1' (l)/SPO I$$!'$
(Part of ICAVP Phase 1)
(0) 96 0345, M1 80 100'i
- Review 50.54 issues for restart issues
' 7201 03
- Unit 1 design deficiencies and issues trends 9
Ett.96 04 os
- Review open DBDP items for startup issues MC osso eReview station blackout self assessment items for C.2.1.g.1 startup issues
$',vio, 97, eSignificant differences between design bases and as-02 07 built
- Field changes to plant modifications not reviewed for cause 24 Review FME SPO (1)
$e.3' ,
o FME deficiencies trend for SFP and RX cavity 028o M196 0728, o Debris identified in spent fuel pool ye e Adverse trend identified in Unit 1 FME program o Fuel Pool foreign material and storage controls e LP 24D 4 tuck open due to foreign material 25 ACR: 07478 j dnadequate design modifications DRS os48 e installed wrcrsg material (pressure rating) for LLRT g
connections 26 ACR: 03822 Cui. ant CWDs do not show modifications to equipment SPO (l) 3 Revised 7/16/97
MEFEMENCE MILLSTONE UNIT 1 INSPECTION ITEM MESP STATUS DRS 27 ACR: 06483 Fuse control program inadequate LtR:96 31,96-17 URt:96 004 06 28 ACR:12663 LOCA analysis does not account for instrument DRS uncertainty during surveillance testing 29 PPR E.1 Operator acceptance of degraded conditions, lack of SPO (l) y,C [,50 ownership, O.D.'s accept degraded conditions, temporary mods, etc.
30 ACR:M196-Work Planning and Control SPO (l) 0343,M196-
- Audit the AWO process l
PPR E.2 eSignificant long standing work management EEL 96 08 01 Weaknesses MC 6
- Fallure to completely implement and document C 2.
recommendations of AWO task force report of-1/1995 eTroubleshooting 31 FPR E.2 Post maintenance testing / maintenance F/U inspection SPO VIO:96 001 (1)/DRS 02,94 031 01:
MC 0350 C,4.h 32 URI:96 005 04 Rework SPO (1) 33 LER:96 40,96-Seismic issues DRS Update 49,96 51 gg 97,
'Inf,'[o8 03 oSeismic review seismic modifications (FWCl, A 46, 01 g
URI:96 08 04, 79 02/79 14, NUSOER) 96 08 05.97-eSeismic ll/l eVerify resolution of A 46 outliers CR 07454, M196 0696, oCRD operability M197 0345, eSEP Topic 1116 Close out 0412, M196-0843 4
Revised 7/t6/97
p MEFERENCE MILLSTONE UNIT 1 INSPECTION ITEM MESP STATUS 34 in: 95 82 Spent Fuel Pool DRS IFl:96 oo4 o2 LER: 96 013 ACR:M196
- SFP Cleanup 64 6,M1 97-eReview resolution of Spent Fuel Poolissues W0Q16 ssess and disposition numerous open items in IR95 g,
00e2,0035, eUnanalyzed condition due to indeterminate boraflex 1
M197 0355, degradation 08 0',0456.
- Load drop analysis (Fuel) l
, p 7, 01 01 l
35 Review Reg Guide 1.97 modifications
-DRS 36 ACR:M196-NRC Information Notices LENS have incomplete or SPO (l) 0106 inaccurate responses 37 ACR:M196 Control rod blades in spent fuel pool lif ted inadvertently SPD (l)
Update 024 with tri nue filter IR:97 02 n :96 006 o2 38 ACR:M196-Ineffective program to nionitor and control f asteners DRS 0545 LER: 96 27 eel:96 04 oS 39 ACR:M196-Adverse trend identified in the control of contracted DRS 0584 services 40 ACR:M196-M&TE program is ineffective SPO (1)
Update 0614 lg;97,gj 41 ACR M196-Process for controlling distribution and use of SPO (1) y Mi'87*
documents (procedures) is inef factive FN 42 ACR:M196-Potential deviation from tech specs when changes SPO (l) osio made to Unit 1 organizational structure 43 ACR:M196-Emergency Preparedness Program DRS 0848,M1 97-u n iter (including Organization / Staffing / Dose Assessment
- 916195, Capability).
2/10/97 MC 0350 C.3,1.m C.2.2.g C.2.2.h 44 ACR:M196-Equipment Environmental Qualification (EEO) Program DRS 0876 5
Revised 7/16/97
REFERENCE MILLSTONE UNIT 1 INSPECTION ITEM RESP STATUS t
46 ACR:M196 Components in control rod drive system (suction filters DRS 063s and associated piping, valves and fittings) may not meet the original design requirements 46 ACR:M196 Insufficient personnel for key leadership programs SPO (l) 0924 47 ACR:M196 PM tasks on plant equipment not performed SPO (l) 0926 MC 0360 C.4.1 48 ACR:M196-Management direction insufficient for system DRS je
,,9 engineering 26 C.2.1.e 49 ACR:M106 System and design engineering work management SPO 2
je 360 weaknesses (0)
C.2.1 60 ACR:M196 Training for engineering personnel not effectively SPO implemented C 360 C.3.1.e 61 ACR;M196-Improvements needed in TLD process and program DRS 0933 52 ACR.M196 Chemistry issues DRS y34.M196 e Adverse chemistry conditions increase potential for corrosion 1r1:96 00416 eWeaknesses in chemistry monitoring, trending and evaluation 63 URh 9612 o1 Procedure Adequacy / Procedure Upgrade Program SPO (l)
^CR 1 6
- Operating procedure deficiencies hinder operators p6-0910
- Deviation from operations procedures during MC 0360:
simulator transients C.3.1.k.
- Verify off normal and general operating procedures C
e.
revisions / adequacy C.2.2.d.
- EOP's C.2.1.b URI:97o1 o2 64 ACR:M196*
Component and systcra degradation during plant SPO (1) 0811 shutdown 66 ACR:M196 Degraded instrument air system quality SPO (I) 0912 6
Revised 7/16/97
_.. ~ _
REFERENCE MILLSTONE UNIT 1 INSPECTION ITEM RESP STATUS 56 Vio:95 007 04 Appendix J resolution DRS Update
[n,7 02*
olnadequate testing IR:97 02 8
almplementation of Appendix J modifications ACR:9536, M1 96-eVerify the basis for not Appendix "J" testing the 0155.M197*
ECCS suction Valves eAdequacy of the basis for the shutdown cooling
't 96-46 system classification as a closed loop system 57 LER: 96 026, LLRT Program Review DRS Update
$4yg p2 95,,
- Feedwater system configuration not allow complete IR: 97 drain, accept LLRT 02 96 1104; URl:97 01
- Containment isolation check valve f alls inform LLRT 05; eel:97 02-eHistorical LLRT reeults/ repeat failures of MSIVs, MSIV drains, FWlVs Se
- Review ILRT (required due to the replacement of DRS inboard containment isolation valvet LP 14A & LP 140) 59 ACR:M196-SBGT lasues resolution DRS 0995,97
$N' '#'
elmplementation of a low flow isolation modification DEV:94 023-
- Resolution of all outstanding issues that could affect os operability (ACR 03735,08248, 03403,03402)
$'s ' 77 2
- Technical Specification restriction to prevent the use 1
Vio:95 44 02 of both standby gas trains when venting the drywell eel:96 08 02, eUse of a dedicated operator while venting the drywell 95 e2 03 via SGTS eDraw down time criteria / testing during a LNP 62 60 URl:95 3101 Verify resolution of ATWS issues, lack of LCO and SPO (1)
^CR 7001, turning off the ATWS system to perform battery 7,
voltage adjustments 61 LER: 96 58 Verify resolution of IPEEE walkdown issues DRS/S eDetermine the need for ths licensee to complete the PO (L)
IPEEE 62 ACR;M197-verify implementation of setpoint changes identified by DRS 0219 M197 the setpoint verification program etncorrect RPS setpoints eYarways 7" Error Low Low Water Level Calculation 63 Verify HELB program completion DRS 7
Revised 7/16/97
_ _. =. - _ - _ _. -
_ _ _ ~
REFERENCE MILLSTONE UNIT 1 INSPECTION ITEM RESP STATUS 64 Verify drywell temperature profile, DRS PDCR completion and closeout necessary to update the plant design basis 66 URh93 24-o4 Fire Protection / Appendix R Programs DRS IFh96 00103
- Review fire detection and suppression system code compliance issues resolution
- Appendix R equipment, test, maintenance program, and surveillance program 66 Review commitment modification program for startup SPO (!)
lssues 67 ACR:M196 Core reload DRS Q' 8B
- Error In LOCA modelinput data for GE11 fuel eSIL 581
- The LOCA results are expected to reduce the operating margin for MAPLHGR below the normal value (10%)
e3D monicore heat balance error correction eReview reload 15/ core design for cycle 16 including the PDCR, safety evaluation and reload report.
68 Core spray suction valves receives a sealin accident SPO (l) signal and can not be shut for leak isolation during an accident 69 SD valves (1,2A,2B) may not close under HELB SPO (1) conditions if open with greater than 300 degrees Rx water temperature 70 Review relief valve reliability DRS ACR trend 71 10 CFR 50.59 Process SPO Modifications installed prior to NRC approval and (L) sometimes before the TSAR submitted. (shutdown cooling, SRVs) 72 ACR: 8254 Isolation condenser thermal shock operability / service DRS life issue 73 Leaker fuel bundle root cause S P O (1) 74 IN: 96 07 CRD scram solenoid pilot valve elastomer degradation S P O (I) 8 Revised 7/16/97
REFERENCE MILLSTONE UNIT 1 INSPECTION ITEM RESP STATUS 75 EEt:96 09-08, Service water inspection (GL8913)
DRS Updata
$.04jd[34'.
7
- Arcor issue resolution IR:97 02 ACR.M196
- SW and ESW system operability I
- 0981,
- LPCI system operability 02372,M 1 96-
- 1058, 76 ACR 8250,M1 Electrical separation DRS/S
$#[g3.'34 02
- Rx high level trip powered from the same source PO (L) 33 n
LER: 96 25
- Cable Separation in Switchgear PIR:95 048 ACR.M196 0859,M1 97 0144 LER: 96 30 77 ACR:M196 Seismic concern With 4KV breaker racked out SPO (1) 0845 LER: 96 57 78 ACR: 07454 IGSCC Program weaknesses DRS LER: 9614,95-29,96 35 eel: 96-09 06 URI:96 005-03.96 005 02 79 ACR:7304 Review f ailure to meet technical specifications root SPO (l) 7 cause and corrective actions tER 95 31
(
Numerous LERs 80 ACR:M1 96-Review TRM for technical specification interpretations SPO (l) 1011
- Method to track conditional LCO's 81 URl:90-00102 Seismic qualification of FWCl valve air supply SPO (1) 82 URI:DO 00101 FWCl test results SPO (1) 83 URI:9108104 Availability of short circult/ voltage drop cales DRS 84 VIO:95 007 01 Controf rcom habitability SPO
- Use of SCBAs (I)/SPO (L) 85 URI:95 028 02 Refueling evolutions contrary to design basis SPO (1) 86 V10:95 03102 Cross connecting 480V safety related buses SPO (1) 9 Revised 7/16/97
REFERENCE MILLSTONE UNIT 1 INSPECTION ITEM RESP STATUS 87 URl:96 006 01 DryWell firefIechnical Specifications violation SPO (l)
LER: 96 041, 96 043 88 LER: 96 006 Nonconservative ATWS low low water level setpoint SPO (1) 89 LER: 96 015 Recirc pump flow mismatch surv not perf in SPO (1) accordance with TS 90 LER: 96 024 Temporary Modification to the scram air header SPO(I) pressure switch instrument not removed 91 LER: 96 032 Unqualified components in drywell preclude long term S P O (1) operability 92 LER: 96 036 Potential to bypass turbine stop valve when required to SPO (1) be operable 93 LER: 96 037 Automatic depressurization system may not be single SPO (I)
I f ailure proof 94 LER: 96 029, inservice Inspection / Inservice Testing Programs DRS 96 039 ACR: M t.97 0276,0400 95 LER: 96 045 LPCI sys inop due to stuck open injection check valve SPO (1)
ACR: M196-0088,0087 96 LER: 96-061, LOCA concurrent with LNP loss OC power prevents S P O (1) 96 05 97 4 closure of LPCI torus cooling valve p
96-o941, M196
- RWCU Valves 0550 97 URI:95 81 01 NCR Program ineffective S P O (1) eel:96 006 04 SPO ACR:M196-(0) 0454 98 IR:9612 Operator Licensing and Training DRS URI:96 $'CR:M !
- LOIT/ LOUT program requirement discrepancies 96 1024,1025 M197 0117.0148, 0168.0223, 0259,0398, 0437 MC 0350 C.3.1.e C.3.3.c 10 Revised 7/16/97
REFERENCE MILLSTONE UNIT 1 INSPECTION ITEM RESP STATUS 99 eel:96 0101 Inoperable Gas Turbine Fuel Pump SPO (l)
LER:9610 100 IF096 08 21 Material Condition Program SPO (l)
MC 0350 C.4.f l
101 (Eges,63 Radiation Effluents Monitoring Program Review DRS 97 05 i
ACR: M196 l
1042,1060, 1069,M197 l
l 0242,0424 102 ACn:M197 EDG Air Start System Review SPO (1) 0424 eel: 96 09 07 LER: 96 56, 96 66,96 60 103 ACR: M197 Use of *Non.0" parts in "O" applications SPO (1) 0292,0207, 0026; ACR:
M196.lo97 104 ACR: M197 GT Air Start System Review SPO (I) 0260 105 ACR: M197 Single failure vulnerability of FWCl/APR historical SPO (1) 0277,0794 failure to meet ECCS acceptance criteria 106 ACR: M197*
Containment isolation valves exceed allowable stroke SPO (1) 0200 time 107 Review deferred restart items list (50.54 (f) Response)
SPO (l) 10s Quality Assurance and Oversight Program SPO (I)
NRR 11 Revised 7/16/97
i e
ENCLOSURE 2 SIGNIFICANT ITEMS LIST - MILLSTONE UNIT 2
MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (2)
Millstone Unit 2 Significant items List The following is a list of the Millstone issues that, as a minimum, require an NRC inspection and I
evaluation prior to restart.
REFERENCE MILLSTONE UNIT 2 PNSPECTION ITEM RESP STATUS 1
MC 03E0 SECTION C.1.3, MANAGEMENT OVCRSIGHT AND EFFECTIVENESS; SPO(l) l C.2.1, C.2.2.s,d,e, LICENSEE STAFF SAFETY CULTURE l
C.3.1,a,b,c,d 2
MC 0350 SECTION C.1.1, 50.%4(fi/lCAVP (PHASE I and 11)
SPO C.1.3, C.1.4.g, C.3.2. C 4 f; FSAR ADEOUACY FOR RESTART (0/1/L)
CONFIRMATORY ORDER 10 CFR 50.59 PROCESS DATED 08/14/96 CONFIGURATION MANAGEMENT / DESIGN CONTROL PROCESS (PART OF ICAVP PHASE 1) 3 MC 0350 SECTION C.1.1 AND DESIGN CONTROL PROCESS CHANGES TO ADDRESS SPO(O)
C.1.3; C.2.2.d; UNIT 1 ACR 7007 UNIT 1 ACR 7007; UNIT 2 ACR 8761 NUMEROUS EXAMPLES OF DRAWINGS NOT REFLECTING ACTUAL PLANT CONFIGURATION 4
MC 0350 ITEM C.1.4.e, EMPLOYEE CONCERNS PROGRAM SPO(L)
C.2.2.b.o; CONFIRMATORY ORDER DATED OCTOBER 24,1996 5
MC 0350 SECTION C.1.1, CORRECTIVE ACTION PROGRAM EFFECTIVENESS SPO(ll C.1.3, C.1.4.d l. C.2.1, C.2.2.c.e. C.3.1.d.m; C.4.f; SELF. ASSESSMENT PDOGRAM IMPLEMENTATION AND IR 96 04 & 08 EFFECTIVENESS:
eel 3' 6/96 20130 J
COMMITMENT TRACKING 6
MC 0350 ITEMS C.2.2.d, WORK PLANNING AND CONTROL:
DRS C 4.e.f.h,l.)
(OL)
PLANT MAINTENANCE PROGRAM EFFECTIVENESS; SIGNIFICANT HARDWARE ISSUES RESOLVED; MAINTENANCE BACKLOG MANAGED AND IMPACT ON OPERATION ASSESSED; SURVEILLANCE TESTING; PLANT HOUSEKEEPING 7
MC 0350 ITEMS C.1.3.f, BYPASS JUMPERS, OPERATOR WORK.AROUNDS &
SPO(ll, C.2.1.e, C.3.2.e, C.4.f,1; CONTROL BOARD DEFICIENCIES OSTI RevlSed 7/16/97
REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 8 MC 0350 ITEMS C.2.1.b, PROCEDURE ADEOUACY/ PROCEDURE UPGRADE SPO(l)
C.2.2.d, C 3.1.k. C.3.3.e,f; PROGRAM OSTl IFl 336/95 20103; PROCEDURE CLASSIFICATION. GENERAL USE VERSUS CONTINUOUS USE 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 IR 336/97 02; eel 97 0212 SURVEILLANCE PROCEDURE ADEOUACY SPO(O) 9 MC 0350 ITEMS C.1.4.g, OPERATING PROCEDURES CONSISTENT WITH FSAR SPO(O) eel 96 08 C.2.2.g, C.3.3.e f; DESCRIPTION OF SYSTEM OPERATION 06 UPDATED eel 336/96 0813, eel 336/96 06 05, ADEOUACY OF PROCEDURE CHANGE PROCESS TO 1R 97 02 eel 336/96 08 06.
ENSURE OPERATION IN ACCORDANCE WITH LICENSE LER 336/97 02; ACP 11104 10 MC 0350 ITEMS C.2.1.g.
PROGRESS OF EMERGENCY OPERATING PROCEDURE DRS C.3.3.e.f; UPGRADES; (OL)
IR 336/95 21 ACCEPTABILITY OF DEFERRING ABNORMAL OPERATING i
PROCEDURE UPGRADES 11 MC 0350 ITEMS C.1.4.a,b c, OUALITY ASSURANCE AND OVERSIGHT PROGRAM SPO(l)
NRR C.2.1.c 12 MC 0350 SECTION C.1.1 LICENSEE RESTART PUNCH LIST. REVIEW OF ITEMS SPO(l)
C.1.3, C.1.4.e, C.2.1.f g, DEFERRED UNTIL AFTER RESTART C.4 f,I 13 MC 0350 ITEMS C.3.1.g.h.l.).l, LICENSED OPERATOR STAFFING; CONTROL ROOM SPO(l)
C 3.3.e,b,d,g FORMALITY; ATTENTIVENESS TO DUTY; ATTENTION TO OSTI DETAIL OFF HOUR PLANT STAFFING: OVERTIME USAGE; AWARENESS TO PLANT SECURITY; AWARENESS OF EQUIPMENT STATUS; LOG KEEPING PRACTICES; 14 MC 0350 ITEMS C.3.1.e, OPERATOR LICENSING AND TRAINING DRS (OL)
C.3.3.c; CONFIRMATORY ACTION ADEQUACY OF LICENSED OPERATOR TRAINING LETTER DATED MARCH 7, PROGRAM 1997; URI 336/97 0103 2
Revised 7/16/97
REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 15 MC 0360 ITEMS AUGMENTED INSPECTION COVERAGE DURING RESTART SPO(l)
NOTE 1 C.4.s,b,c d.e.g INSPECTION: OPERABILITY OF TECHNICAL OSTI SPECIFICATION SYSTEMS; OPERABILITY OF SECONDARY AND SUPPORT SYSTEMS; SYSTEM LINEUPS; RESULTS OF PRE STARTUP TESTING; POWER ASCENSION TESTING 16 MC 0350 ITEMS C.2.2.g h, EMERGENCY PREPAREDNESS PROGRAM (INCLUDING DRS(EP)
C.3.1.m. C.3.2.h; ORGANIZATION / STAFFING / DOSE ASSESSMENT NU LETTER (B16195) DATED CAPABILITY)
FEBRUARY 10,1997 17 MC 0350 SECTION C.5 AND DISPOSITION OF REGULATORY ISSUES: LICENSE
- NRR, C.6 AMENDMENTS; EXEMPTIONS; RELIEFS; ORDERS; SPO(L),
SIGNIFICANT ENFORCEMENT ISSUES; ALLEGATIONS; O E, 01, AND 10 CFR 2.206 PETITIONS. COORDINATION WITH
- DRS, INTERESTED AGENCIES AND PARTIES.
OPA 18 ACRs 02621, M2 96-0239 MATERIAL, EQUIPMENT AND PARTS LIST (MEPL)
- NRR, eel 336/96 20142 & 43 PROGRAM DRS (SEB) 19 ACRs M2 96 0515 & 07958; EQUIPMENT ENVIRONMENTAL QUAllFICATION (EEO)
DRS eel 336/96 0612, PROGRAM (EEB) eel 336/96 20120, URI 336/9319 02 HIGH ENERGY LINE BREAK PROGRAM 20 IFl 336/95 0101 MOTOR OPERATED VALVES (GL 8910)
DRS (SEB) eel 336/96 0511 INACCURATE INFORMATION PROVIDED TO THE NRC 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 REClHCULATION VALVES 21 MC 0350 ITEM C.3.3.o; FIRE PROTECTION / APPENDIX R PROGRAMS DRS IR 336/96 08; (EEB)
LICENSEE SELF ASSESSMENTS APPENDIX R RELATED ABNORMAL OPERATING AND OA AUDITS; PROCEDURES:
ACR M2 96 0460 APPENDlX R COMPLIANCE ASSOCIATED WITH THERMO-LAG 22 ACRs M2 96 0513; CONTAINMENT SUMP SCREEN MESH SIZE & ECCS PUMP DRS eel 336/96 0610 & 11 THROTTLE VALVE CLOGGING (SEB) 3 Revised 7/16/97
a REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 23 ACRs 01991. M2 96 0449, HYDROGEN MONITORS AND POST. ACCIDENT SAMPLING SPO(l) 0467, 0654, 0655, & 0656; SYSTEM INOPERABLE AND FAILURE TO MEET DESIGN eel 336/96 0611,12 & 13, BASIS AND LICENSING BASIS eel 336/96 20103 & 41, URI 336/96 0105 24 ACR4 08174,04047,06372 &
EXCESSIVE REACTOR COOLANT SYSTEM HEA1UP AND SPO(l) 09739; COOLDOWN RATES; EVAL UATION OF SIMULTANEOUS URI 336/95 42 03 REACTOR COOLANT PUMP AND SHUTOOWN COOLING SYSTEM OPERATION 25 NUMEROUS ACRs; ECCS PUMPS SUCTION LINE FROM RWST HAS DRS URI 336/96-06 08 NUMEROUS DEGRADED OR INOPERABLE PIPE SUPPORTS, (CMME)
MANY CAUSED BY WATER HAMMER l
26 ACR 11252:
- B' EMERGENCY DIESEL GENERATOR FAILURE.
SPO(l)
OPDATED eel 336/96 0910 (NADEQUA1E CORRECTIVE ACTIONS IR 97 02 27 eel 336/96 20109 INADEQUATE DESIGN CONTROL MEASURES FOR SPO(O)
VERIFYING ACCURACY OF INFORMATION CONTAINED IN DESIGN BASIS DOCUMENT PACKAGES 28 eel 336/96 201 11, FAILURE TO ADEQUATELY CONTROL INSTALLATION OF SPoll) eel 336/96 20131 TEMPORARY MODIFICATION TO THE RBCCW SURGE TANK 29 eel 336/96-201 12 OEPARATION AND SINGLE FAILURE CONCERNS FOR WIDE SPO(l)
RANGE NUCLEAR INSTRUMENTS 30 eel 336/96 20125 FAILURE TO IMPLEMENT CORRECTIVE ACTIONS SPoll)
CONCERNING ' DUAL FUNCTION' ISOLATION VALVES 31 eel 336/P6 20128 FAILURE TO ADDRESS STATION BLACKOUT ISSUES SPO(l)
IDENTIFIED IN THE VECTRA ASSESSMENT 32 eel 536/96 20129 FAILURE TO IMPLEMENT CORRECTIVE ACTIONS FOR SPO(l)
UPDATED AUDIT ISSUttiINVOLVING TRENDINQ AND IR 97 02 PRIORITIZATION OF NON CONFORMANCE REPORTS 33 eel 336/96 20136 INADEQUATE CORRECTIVE ACTION CONCERNihG A DRS SEISMIC DESIGN DEFICIENCY OF A VITAL SWITCHGEAR (CMME)
ROOM COOLER 4
Revised 7/16/97
REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 34 eel 336/96 08 06 IMPLEMENTATION OF CORRECTIVE ACTION OF SPO(l)
UPDATED CHANGING OPERATING PROCEDURE TO LOCK OPEN IR 97 02 REFUILING POOL DHAIN VALVES, AS SPECIFIED IN THE FSAR, WAS INADEQUATE 35 eel 336/96 08 08 INADEQUATE CORRECTIVE ACTION IN LER J36/96 24 SPO(l) 36 Ett 336/96 0810 INADEOUATE CORRECTIVE ACTIONS TO ADDRESS UNIT SPO(l)
UPDATED l
1 HEAVY LOADS LIFTED OVER THE UNIT 2 VITAL IR 97 02 l
SWITCHOEAR ROOM l
l 37 eel 336/95 44 05 ICE BLOCKAGE OF $[RVICE WATER STRAINER SPO(l) l BACKWASH LINE l
3B URI 336/96 0511 (IFS NO. URI SPENT FUEL POOL FSAR UPDATES SPO(l)
CLOSED 336/96 05 17)
IR 97 02 39 eel 336/96 0410 ERRONEOUS RBCCW FLOW VALUES IN CONTAINMENT DRS TEMPERATURE PROFILE ANALYSIS (SEB)
I URI 336/96 20138 FAILURE TO CONSIDER POST. ACCIDENT FLUID TEMPERATURE IN HPSI FLOW EVALUATION 40 LER 336/96 31 POTENTIAL STEAM GENERATOR OVERPRESSURE DUE TO ORS RESTRICTIVE MAIN STEAM SAFETY PIPING (SEB) 41 ACR M2 97 0023 SEIMANS COMPUTER MODEL OF REACTOR CORE LARGE NRR AND SMALL BREAK LOSS OF COOLANT ACCIDENTS 42 IR 336/94 201 (IFS NO. IFl EMERGENCY DIESEL GENERATOR FUEL DAY TANK DOES SPO(L) 336/94 201 90)
NOT SATISFY 7-DAY DESIGN BASIS CAPACITY 43 URI 336/96 0814 INAPPROPRIATE REMOVAL OF STARTUP RATE TRIP SPO(l)
LCR 336/96 29 44 ACR 02797, ACR 09563, POTENTIAL TO EXCEED CONTAINMENT DESIGN SPO(l)
ACR M2 96 0153; PRESSURE FOLLOWING A MAIN STEAM LINE BREAK LER 336/97 06 45 ACR M2 96 0296 FAILURE OF MAIN STEAM CHECK VALVE FOLLOWING A SPO(
MAIN STEAM LINE BREAK (MSLB) COULD CAUSE BOTH STEAM GENERATORS TO BLOW DOWN RESULTING IN EXCEEDING CONTAINMENT DESIGN PRESSURE. THE LICENSEE'S MEPL PROGRAM DESIGNATES THE MS CHECK VALVES AS NON-QA WHICH THE LICENSEE HAS EYALUATED AS ACCEPTABLE.
5 Revised 7/16/97
I REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 46 LER 336/97 02 CONTROL ROOM AIR CONDITIONING COMMON INLET SPO(l)
DAMPER COULD BECOME STUCK CLOSED, DISABLING I
BOTH FACILITIES, DAMPER HAS (40 MANUAL OPERATOR AS STATED IN FSAR.
47 URI 336/96 08 09, REACTOR PROTECTION SYSTEM AND ENQlNEERED SPO(ll LER 336/96 24 SAFETY FEATURE RESPONSE TIME TESTING 48 ACR M2+96 0542 TECHNICAL SPECIFICATION LIMITS FOR INOPERABLE SPO(l)
MAIN STEAM SAFETY VALVES NON CONSERVATIVE 49 LER 336/96 30, LER 336/97 05 INSERVICE INSPECTION / INSERVICE TESTING PROGRAMS DRS (SEB)
CR M2 97 0491 & 1229 r
~
50 CONTROL /USE OF VENDOR INFORMATION SPO(l) 61 IR 336/95 29 SERVICE WATER SYSTEM OPERATIONAL PERFORMANCE DRS INSPECTION (SWSOPI) FOLLOWUP (SE8)
Note 11 Since this inspection will occur following restert approvel, the closure of this item will not be reflected on this list.-
l 6
6 Revised 7/16/97
9 0
l ENCLOSURE 3 l
SIGNIFICANT ITEMS LIST - MILLSTONE UNIT 3 l
i
MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (3)
Millstone Unit 3 Significant items List REFERENCE MILLSTONE UNIT 3 INSPECTION ITEM RESP STATUS 1
ACR: 10773 RSS AND QSS PIPING TEMPERATURE NRR Update eel: 96 0613 MAYBE HIGHER THAN ANALYZED (NRR REYlEW ENG.
DRS IR96 06 LER: 96 007 ANALYSIS, DRS INSPECT INST ALLATION)
SPO (0) 01 & O2 2
eel: b6 201 FSAR ADEQUACY FOR RESTART SPO(L) 01 3
ACR: 0$715 REACTOR POWER INCREASE WHEN UNBORATED CATION DRP CLOSED DEMIN PLACED INTO SERVICE 3CHS DEMIN2 IR96-05 4
ACR: 01895 EDG SEQUENCER CDA SIGNAL OUTPUT "A" TRAIN DRS CLOSED COMPONENTS STARTED IR9649 6
ACR: 01844 FAILURE TO ENTER AN ACTION STATEMENT WHEN MSIVS SPO(l)
Update IR VIO: 94 24 WERE CLOSED.(TECH SPEC AMEND) 97 02 01; LER:97 08 8
ACR: 04199 RCP SEAL INJECTION FILTER *B" GASKET FAILED RESULTING DRP CLOSED IN SPILL OF COOLANT TO FLOOR DRAINS 1R9648 7
ACR: 06092 RCS CHECK VALVE BODY TO BONNET LEAK; 3 RCS*V146 DRP CLOSED IR96 06 8
ACR: 01535 WHILE DEWATERING SPENT RESIN THE WASTE DRP CLOSED TEMPERATURE IN THE LINER RAISED FROM 90 TO 310'F IR9646 9
ACR: 10543 NEED FOR ADDITIONAL REVIEW OF RESPONSE TIME TESTING SPO(l)
FOR PROCEDURES 10 ACR:11322 CLOSURE OF PIR WITHOUT ADDRESSING DESIGN FEATURE DRP CLOSED OF AFFECTED COMPONENTS IR9649 11 NU LTR TURBINE DRIVEN AUX FEEDWATER DESIGN CONCERNS.
SPO(l)
(B15397).
(TECH SPEC AMEND.)
1111/95, ACR: 10774
& 10780 eel: 96 201 04,05; URl:
96-201 40 Revised 7/16/97
REFERENCE MILLSTONE UNIT 3 INSPECTION IT EM RESP STATUS 12 ACR;974317 CONTAINMENT FOUNDATION EROSION NRR SPO (L) 6323 URl:M 44
- 13. M4414 M4416 IFl: 941149 IN: 9711 13 ACR: 96 326, CCP SYSTEM OPERATION ABOVE DESIGN TEMPERATURE,3 SPO(l)
Update 13427,96 RHS*HCV 604/607 FAILING OPEN; AND OTHER FAILURE MODES IR$448 0887 URI: M48-20:lR: 96 201 LER: 96 28 &
M 40 14 ACR: 7748 SGCS OPERATIONAL CONFIGURATION CONTROL (TECH SPEC SPO(l)
Update IR 9742 URl: 964147 AMEND.)
16 ACR: M4169 LETDOWN HEAT EXCHANGER LEAKAGE AND DESIGN SPO(l)
Update IR9646 eel: M4616 DISCREPANCILS 16 Unit 2 DUAL FUNCTION VALVII CONTROL AND TESTING SPO (l)
Update IR 9742 ACR: 01936 17 ACR: 7266 RCP SEAL HOUSING LEAKAGE AND SOLT CORROSION DRS it ACR: 10H2, CONTROUUSE OF VENDOR INFORMATION DRS Update SPO(l)
IR 9742 PPR G.2 eel: 96 201 16,M 201 it, M 20119 URI: 94 201 17 19 URl: M 201 RESOLUTION OF AFW VALVES HELS CONCERN SPO(l) 16 20 VIO: H 6913 EMPLOYEE CONCERNS PROGRAM SPO(L)
MC 0360 ITEMS C.1.4.e &
C.2.2.b i
21 FATIGUE CYCLE OPEN ITEMS IP 37760 DRS CLOSED l
IRH41 l
(UNIT 2 ISSUE)
I 22 PART 70 STORAGE AND INVENTORY IP 84780 (UN!T 1 ISSUE)
DRS CLOSED IR9646 23 FORMALITY OF NON ROUTINE SECURITY ACTIVITIES AND NEW DRS CLOSED IR9646 FUEL SECURITY IP 81064 2
Revised 7/16/97
1 REFERENCE MILLSTONE UNIT 3 INSPECTION ITEM RESP STATUS 1
24 URI: H4148 OVERLAP TESTING OF RPS/ESF SPO(l)
Update
)
LER: 9717 IR9741 1
26 ACR: 912 MATERIAL, EQUIPMENT AND PARTS LIST (MEPL) PROGRAM DRS Update URl: 964710 SPO(l) lR96 201, eel: 94 201 97 202 43 1
26 ACR: H.277, MOTOR OPERATED VALVES (GL 8910)
DRS 0278,$27, 12462 LER: 96 19,20,96 36; URl: 9617 09 IFl: 96 0101, 961741,02, 03,04,06; IN:
9747 27 PPR G.1.C.
MISSED SURVEILLANCESffEST CONTROL SPO(l)
CLOSED G.2 MC 0360 IR9648 ITEMS C.4.e 28 PPRG1.C DILUTION EVENTS SPO(l)
CLOSED 1R9648 29 PPRG1.C FEEDWATER HAMMER DRS CLOSED IR9641 30 IR: 96 31, NU AFW CHECK VALVE LEAKAGE SPO(l)
CLOSED LTR (B16397)
IR:9742 11/1/96 PPR G 1.C.
ACR 964866 31 PPR G.1.C, WORK AROUNDS AND ABUSE OF USE AS IS DEFICIENCIES SPO(l)
G.2 MC 0360 ITEMS C.1.3.f.
C.2.1.e C.3.2.e, C.4.f.& I 32 NOV: 9416 WORK PLANNING AND CONTROL DRS 06 PPR O.2 MC 0360 ITEMS C.2.2.e C.4.f,h,I 3
Revised 7/16/97
REFERENCE MILLSTONE UNIT 3 INSPECTION ITEM RESP STATUS 33 IR: H.201 SEISMIC M DRS PPRG.2 LER: H403; ACR: M.
0643; CR: 97 0060 34 IP:54760; EFFLUENT / ENVIRONMENTAL SAMPLING AND ANALYTICAL DRS Update VIO: H49 PROFICIENCY
~
36 ACR:M3 97 HEAT EXCHANCER PERFORMANCE (GL $913)
DRS 0214 37 1R: 9644 CORRECTIVE ACTION PROGRAM EFFECTIVENESS (TECH SPEC SPO(l)
Update eel: 96 201 AMf;ND.)
lR:97 13,21,22,23, 02,97 202 24,26,27,28, 29 MC 0360 ITEMS C.1.1, C.1.3, C.1.4.d.e.g.
C.2.1, C.2.2.c.e.
C.3.1.d. C.4.f 35 REVIEW 0737 ACTION ITEMS FOR COMPLETlON SPO(l) 39 MC 0360 REVIEW ENGINEERING BACKLOGS DRS ITEMS OSTI C.3.2.a,c 40 MC 0360 REVIEW $0.64F ISSUES FOR RESTART / REVIEW DEFFERED SPO (L)
Update ITEMS C.1.1, RESTART ITEMS LIST SPO (l)
- IRH46, C.1.3, C.1.f,&
97 202 9,
C.4.f,1 41 ACR: 7007 REVIEW SELF ASSESSMENT ROOT CAUSES AND VERIFY SPO(l)
Update URI: 964141 CORRECTIVE ACTIONS (IP40600)
IR: 9742 VIO: H4944 MC 0360 C.1.4.1 42 1R: M48 FIRE PROTECTION / APPENDIX R PROGRAMS DRS Update IR:97 202 43 ORDER 60.64(f)llCAVP (PHASE I and ll)
SPO(O) 4 Revised 7/16/97
i REFERENCE MILLSTONE UNIT 3 INSPECTION ITEM RESP STATUS i
44 ACR: 12116, CYCLE 6 BORON DILUTION ANALYSIS POTENTIALLY NON.
DRS M4326 CONSERVATIVE AND POS FLOW RATE TO CHAR 0lNO PUMPS LER: M 26 MAY BE IN ERROR t
46 ACR: M.
INITIAL SETTINGS FOR ECCS THROTTLE VALVES INADEQUATE SP0(l)
Update 0624,08997 AND POTENTIAL CLOGGING. (TECH SPEC AMEND.)
IR9646 URI M4614 i
LER M 29 &
M 39 44 ACR: M4183 LOW PRESSURE SAPETY INJECTION PENETRATIONS SP0(l) 47 ACR: M4391 RHR HEAT EXCHANGER BOLTING SUSCEPTIBLE TO BORIC DRS CLOSED ACID 1R:97 202 44 ACR: 10397 LLRT "AS FOUND" TOTAL LEAKAGE EXCEEDED MAX SPO (1)
CLOSED ALLOWABLE 1RM48 49 ACR: M4324 FUEL TRANSFER TUSE BELLOWS SEAL CONNECTION NOT SPO (1)
CLOSED i
TESTED IRM 48 SO ACR: M4444 DOCUMENTATION OF CONTAINMENT SYSTEMS DRS DISCREPANCIES 51 ACR: M.
WALWORTH VALVE YOKE GENERIC ISSUE DRS 0339,M 4399 St ACR 10795 SWP TEMPERATURE SWITCHES DEFEATED BY SYPASS SP0(I) eel: M 201 JUMPER FOR SWP'PSAit (800 STER PUMPS) 02,23 LER: M405 01
. 63 ACR: M.
PIECES OF ARCOR FOUND IN 3RSS*E1A AND 3RCC'E1C SPO (1)
Update 8449;CR:97 SPO (0) 1R:M49, 1007,97 97 202 1729 URI:
M49111 LER: M 26 54 ACR: M4191 NUMEROUS BOLTS ON BACK DOOR ON 4160V SWITCHGEAR DRP t OLOSED MISSING IRM46 M
ACR: M4447 FAST TRANSFER TEST FAILURES DRS CLOSED IRM49 l
M ACR: 12495 SHUTDOWN MARolN MONITOR ALARM SETPolNT DRS CLOSED IRM48 i
4 i.
5 Revised 7/16/97 i
L
.s
i REFERENCE MILLSTONE UNIT 3 INSPECTION ITEM RF,SP STATUS 67 ACR: 96 POTENTIAL ELECTRICAL SEPARATION VIOLATIONS DRS Update 0080,96 4081 SPO (l)
IR:97 202 LER 9616, 46,49 LER 96 016 02 68 ACR: 96 THERMAL RELIEF VALVE SETPOINTS SPO(l)
Update 0667,96 4686 IR:97 02 eel 96 20133 69 ACR: 96 USE OF BORAFLEX IN SFP RACKS (TECH SPEC AMEND.)
SPO(l)
UPDATE 0776,9124, NRR 1R: 97 202 0644 LER 96 33 60 ACR: 96 ANALYSl3 OF SOV FAILURE MODES DUE TO MOPD SPO(l)
Update 0718,0021 1R9649 eel:96-0916 41 UNIT 2 EQUIPMENT ENVIRONMENTAL QUALIFICATlON (EEQ)
DRS ACR: 7923 PROGRAM 62 ACR: 13788 TSP BASKET SAFETY EVALUATION POSSIBLY NOT VALID SPO(l)
CLOSED IR: 9742 63 ACR:964396 3 MSS *MOV17D MISSED IST SURVEILLANCE REQUIREMENT DRP CLOSED IR9648 64 ACR: 08814 REACTOR PROTECTION LEAD LAG CIRCUITS MAY BE SET DRS CLOSED NONCONSERVATIVELY IR9646 66 ACR: 96 SIU$lH VALVES POWERED FROM NONSAFETY TRAIN SPO 0746, C R.97 NRR 742 LER: 96 36 St ACR: 904483 CCP AND CCE NON-Q COMPONENTS CAUSE Q COMPONENTS SPO(l)
NOT TO FAIL SAFE 67 ACR: bW21 880 POSSIBLE OVERLOAD IN EVENT OF AN SIS ACTUATION &
SPO(l)
Update TAC Nc.
DESIGN ISSUES NRR 1R: 97 01 M96064 URI: 96 201 141IN 97 21 68 REVIEW ALLEGATIONS FOR RESTART ISSUES SPO (L)
SPO (l) 49 REVIEW ALL OPERABILITY DETERMlHATIONS AND BY. PASS SPO (1)
JUMPERS BEFORE RESTART l
6 Revised 7/16/97
. _ ~
D
I REFERENCE MILLSTONE UNIT 31NSPECTION ITEM RESP STATUS 70 U RI: M 4 8 16 REVIEW TRM FOR TECH, SPEC. INTERPRETATIONS; EVALUATE DRS Update LER: 96402 TS AND OPER. LICENSE ISSUES 1R:9742 01, M 37, M.
38,M42,M.
- 43. M 44, M.
51,97 44,97 07,97 10,97 19 71 MC 0360 REVIEW LICENSEE EVENT REPORTS FOR RESTART ISSUES SPO(f)
C 1.4.1 72 REVIEW ENFORCEMENT AND UNRESOLVED ITEMS FOR ITEMS SPO(l)
FOR RESTART ISSUES 73 NOV 9445 QUALITY ASSURANCE AND OVECSIGHT PROGRAM OSTI 12;IFl: M44 40600 17 MC 0350 C.1.4.a,b,c, C.2.1.c 74 URl: M48 INSERVICE It;SPECTION/ INSERVICE TESTING PROGRAMS DRS Update it; LER: 96 IR:97 til CR 97 02,97 202 901-75 IFl: M 4 8 15 TlA ISSUES (EDO EXHAUST & REQUIRED # OF SW PUMPS)
NRR M4917 SPO(L) 76 IFl: M4817 CRACKING OF FUSE FERRULES DRG CLOSED IR:97 202 77 lFl: 96 4444 POTENTIAL FREEZlNG OF SW BACKWASH LINES SPO(1)
Update IR:M49 78 URI: 9347 10 CFR 60.59 PROCESS SPO(L) 07 eel: H 201 02,04,05,04, 07,08 79 eel: M 201 CONFIGURATION MANAGEMENT / DESIGN CONTROL PROCESS SPO(l)
Update 09,15,35,37, SPO(O) 1R: 9742 39 (PART OF ICAVP PHASE 1)
MC 0350 C.3.2.f -
7 Revised 7/16/97
~
1 REFERENCE MILLSTONE UNIT 3 INSPECTION ITEM RESP STATUS 60 ACR: 97 344 PROCEDURE ADEQUACY / PROCEDURE UPGRADE PROGRAM SPO(l)
Update eel: H 201 08Tl IR9741 it.19 MC 0360 C.2.1.b.
C.2.2.d.
C.3.1.k.
C.3.3.e,f 81 eel: H 201 TESTING OF SAFETY SYSTEMS DRS Update 1R:9742 32,33,34; LER: H.32 42 eel: H 201 QUALITY ASSURANCE RECORDS SPO(l) 10 83 NU LETTER EMERGENCY PREPAREDNESS PROGRAM DRS Update (814195),
IR:9649, 2/10/97 (INCLUDING ORGANIZATION /STAFFINGIDOSE ASSESSMENT 97 202 MC 0360 CAPASILITY)
ITEMS C.2.2.g, h.
C.3.1.m.
C.3.2.h: IFl:
96 3641 84 MC 0360 SECURITY ISSUES. CORRECTIVE ACTION DRS ITEM C.3.1.1 eel: 964615, 9741.XX U1 VIO: H49 20 86 ACR: H 4H, OTHER RSS AND RELATED DESIGN BA818 CONCERNS SPO (0) l 497,$20, NRR 1078,97 4 39, 128,409 l
LER: 9743, 97 15,97 211 CR:971029 86 CAL:197 OPERATOR LICENSING AND TRAINING SPO(l)
Update 010; DRS IR: 97 CR:97 202,97 0927 04 l
l l
8 Revised 7/16/97 l
l
W 9
4 ENCLOSURE 4 MC-0350 - RESTART APPROVAL CHECKLIST ALL MILLSTONE UNITS I
l
4 MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (4)
MILLSTONE UNIT ALL UNITS REST, ART APPROVAL (MCO350)
The following items are considered applicable to the restart of all Millstone Units:
1 l
RESPONSIBILITIES AND AUTHORITIES lNEED fSTATUS l RESP 4.01 Director. Soecial Projects Office (SPO). Notifies the X
C NRR Executive Director for Operations (EDO) and the Commission, as appropriate, of the NRC actions taken concerning shutdown plants and the proposed 1
followup plan.
4.02 Director. Soecial Projects Office X
C DSeo i
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 Ir~ar iML) specifying the actions required of tia H w.a to receive NRC approval to restart the piant and the proposed followup plari.
b.
Decides, in consultation with the NRR X
C DSPO Associate Director for Projects, whether this manual chapter applies to a specific reactor
- restart, c.
In cc. rdination with the NRR Associate X
C DSPO Director for 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 interactions with the licensee and outside organizations.
I Revised 7/16/97
' N;ED l STATUS l 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 X
RAP SRI determines the acceptability of licensee's corrective action program ggg g.
Approves restart of the shutdown plant, X
DSPO following consultation with the EDO and the Director of NRR, and approval / vote by the Commission.
k 4.03 Director SPO Y
t a.
Acts as the focal point for discussions within X
DSPO NRR to establish the appropriate followup actions for a plant that has been shut down.
4.04 Deputy Director, Licensing Sm a.
Coordinates participation in followup X
conference calls and management discussions to ensure that the Director SPO are directly involved, when appropriate, in fu!owup action, b.
Coordinates and implements actions prescribed X
DSPOL in the Restart Assessment Plan that have been determined to be Licens;ng's responsibility.
These include, where applicable, appropriate NRC Office or NRR Division interaction with other Federal agencies (e.g., Federal Emergency Management Agency (FEMA),
Department of Justice (DOJ)) pursuant to any epplicable Memoranda of Understanding.
l 2
Revised 7/16/97
l I NEED l STATUS ! RESP B.1 INITIAL NRC RESPONSE NA The facts, the causes, and their apparent impacts should be established 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. The following items should have been completed or should be incorporated into the CSC as appropriate. Refer to Section 5.02 of this manual chapter for additionalinformation.
a.
Initial notification and NRC management NA discussion of known facts and issues b.
Identify / implement additionalinspections (i.e.
NA AIT, llT, or Special) (Region).
l c.
Determine need for formal regulatory response NA (i.e. order or CAL).
i d.
Identify other parties involved (i.e., NRC NA Organizations, other Federal agencies, industry organizations).
B.2 NOTIFICATIONS NA initial notification of the event quickly communicates NRC's understanding of the event and its immediate response to the parties having an interest in the event. Notification to regional and headquarters offices of cognizant Federal agencies may be appropriate. As the review process continues, additional and continuing notifications may be
- required, a.
Issue Daily and Directors Highlight (NRR).
NA I
I b.
Issue preliminery no ification (Region).
NA l
3 Revised 7/16/97
I l
!NEED { STATUS RESP c.
Conduct Commissioner assistants' briefing.
NA d.
Issue Commission paper (NRR).
NA e.
Cognizant Federal agencies notified (i.e.,
f.
State and local officials notified (Region).
NA g.
Congressional notification (NRR)
NA B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS C
RAP a.
Establish the Restart Panel.
X b.
Assess available information (i.e.
X RAP inspection results, licensee self-assessments, industry reviews).
c.
Obtain input from involved parties both X
RAP within NRC and other Federal agencies such as FEMA, EPA, DOJ.
d.
Conduct Director SPO briefing.
X C
l RAP e.
Conduct NRR Executive Tearn briefing X
f.
Develop the case specific checklist X
C RAP (C SC). --
i g.
Develop the Restart Assessment Plan.
X C
l RAP i
h.
Director SPO approves Restart X
l C
DSPO 2
Assessment Plan.
l.
NRR Director approves Restart X
C DNRR Assessment Plan.
l j.
Implement Restart Assessment Plan.
X RAP k.
Modify order as necessary X
l NRR B.4
! REVIEW IMPLEMENTATION I
l 4
Revised 7/16/97
4 l
lNEED l STATUS l RESP B.4.1 Root Causes and Corrective Actions oSTI
^"
a.
Evaluate findings of the special team X
inspection.
b.
Licensee performs root cause analysis X
NU oST and develops corrective action plan for root causes.
c.
NRC evaluates licensee's root cause X
RAP OSTI determination and corrective action plan.
B.4.2 B.4.2 Assecsment of Eauioment Damage 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 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, j 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 requirements.
Potential offsite emergency response impact for external events such as natural riisasters, 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 reasonable doubts about emergency response capability.
a.
Licensee assesses damage to systems and NA components.
5 Revised 7/16/97
(NEED l STATUS l RESP 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 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 steps to determine the restart issues and NRC's evaluation of their resolution, s.
Review / evaluate licensee generated restart X
- issues, b.
Independent NRC identification of restart X
C RAP issues c.
NRC/ licensee agreement on restart issues.
X l RAP d.
Evaluate licensee's restart issues X
RAP implementation process, e.
Evaluate licensee's implementation verification X
SRI process.
1 l
)
i 6
Revised 7/16/97
l lNEED fSTATUS l RESP B.4.4 Obtain Comments Since some shutdowns involve a broad number of issues, solicitation of comments from diverse sources may be appropriate. The decision to solicit comments from a group and the level of participation should be made on a case by case basis. Input from these groups should be factored into the restart process when they contribute positively to the review. Note:
If needed, comments concerning the adequacy of state and local emergency planning and preparedness must be obtained from FEMA headquarters through NRR.
a.
Obtain public comments.
X If this item will not be reflected on this list.
b.
Obtain comments from State and Local X
SLO Officials (Region).
c.
Obtain comments from applicable X
RAP Federal agencies.
B.4.5 l Closecut Actions When the actions to resolve the restart issues and significant concerns are substantially complete, closeout 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 provides actions associated with completion of significant NRC ggp reviews and preparations for restart.
oSTI a.
Evaluate licensee's restart readiness self-assessment.
X b.
NRC evaluation of applicable items from X
RAP I
Section C "lSSUES" complete.
7 Revised 7/16/97
t d
lNEED l STATUS l RESP c.
Restart issues closed.
Conduct NRC restart readiness team X
OSTI inspection, e.
Issue augmented restart coverage inspection X
oSTI plan.
f.
Comments from other parties considered.
X RAP g.
Determine that all conditions of the Order / CAL X
RAP are satisfied.
h.
Re review of Generic Restart Checklist X
B.5 RESTART AUTHORIZATION (B.51 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?"
a.
Prepare restart recommendation document and basis for restart.
NRC Restart Panel recommends restart X
c.
No restart objections from other applicable HQ X
McKee offices.
d.
No restart objections from applicable Federal X
- agencies, e.
DSPO concurs in restart recommendation X
DSPO f.
NRR Director concurs in restart X
DSPOL recommendation.
g.
EDO concurs in restart recommendation when X
EDO required.
X l SPO h.
Conduct ACRS briefing when requested (NRR). l l1.
Conduct Commission briefing when requested. l X
lDSPO 8
Revised 7/16/97
l-NEED STATUS l RESP j.
Commission approves In restart authorization.
X COMM j
k.
DSPO authorizes restart.
X EDO B.6 RESTART AUTHORIZATION NOTIFICATION (B.8)
Notify the applicable parties of the restart authorization. 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 RAP b.
EDO (it the EDO did not concur in the restart NA EDO recommendation or as requested) (NRR).
c.
Congressional Affairs (RAP).
X OCA d.
ACRS (a briefing may be substituted for the X
SPO written notification if the ACRS requests a briefing) (NRR).
e.
Applicable Federal agencies.
X RAP f.
Public Affairs.
X lOPA
! g.
State and local officials.
X SLO l
h.
Citizens or groups that expressed interest X
RAP during the restart approval process.
4 Root Cause Assessment C.1.1 a.
Conditions requiring the shutdown are clearly X
RAP understood.
b.
Root causes of the conditions requiring the X
RAP shutdown are clearly unde. stood.
c.
Root causes of other significant problems are X
RAP clearly understood.
d.
Effectiveness of the root cause analysis X
RAP program.
9 Revised 7/16/97
l lNEED l STATUS l RESP l
C.1.2 Damage Assessment a.
Damage assessment was thorough and NA comprehensive, b.
Corrective actions clearly restored systems and NA equipment or verified they can perform as designed.
C.1.3 Corrective Actions a.
Thoroughness of the corrective action plan X
RAP b.
Completeness of corrective action programs X
SRI for specific root causes, c.
Control of corrective action item tracking.
X sri OSTI d.
Effective corrective actions for the conditions X
SRI oST:
requiring the shutdown have been implemented, e.
Effective corrective actions for other significant X
SRI OSTI problems have been implemented.
I f.
Control of long term corrective actions.
X SRI OSTI 40500 g.
Effectiveness of the corrective action X
SRI OSTI verification process.
40500 10 Revised 7/16/97
l lNEED l STATUS l RESP
~
I C.1.4 Self Assessment Canabilltv 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 i
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, a.
Effectiveness of Quality Assurance Program.
X RAP 40500 b.
Effectiveness of industry Experience Review X
osTl 40500 Program.
c.
Effectiveness of licensee's Independent Review X
SRI OsT1 Groups.
g5 9 4
d.
Effectiveness of deficiency reporting system.
X SRI osTI 40500 e.
Staff willingness to raise concerns.
! f.
Effectiveness of PRA usage.
X l
osTi g.
Effectiveness of commitment tracking X
h.
Review applicable external audits X
osTi 1.
Quality of 10 CFR 50.72 and 50.73 reports.
X l
SRI C.2.1 Management Oversicht and Effectiveness a.
Goals / expectations communicated to the staff.
X osTi 40500 b.
Demonstrated expectation of adherence to X
SRI osTi procedures, c.
Management involvement in self-assessment X
RAP 40500 and independent self-assessment capability 11 Revised 7/16/97
(NEED l STATUS l-RESP loSTl d.
Effectiveness of management review X
SRI committees.
lg 9
e.
Management's demonstrated awareness of X
SRI oST:
day to-day operational concerns.
f.
Managemen+'s ability to identify and prioritize X
SRI oSTI significant issues.
,g, g.
Management's ability to coordinate resolution X
SRI oSTl of significant issues,
,,9 h.
Management's ability to implement effective X
SRI corrective actions.
oST'
,g5 o C.2.2 Management Sunoort a.
Impact of any management reorganization.
X RAP 40500 b.
Effective and timely resolution of employee X
RAP Concerns.
I.
Adequate engineering support as demonstrated X
!DRS lc by timely resolution of issues.
l oSTI d.
Adequate plant administrative procedures.
Effective information exchange with other X
SRI oST utilities..
lf.
Participation in industry groups.
l NA 40500 lDRS g.
Effectiveness of Emergency Response X
Organization.
l h.
Coordination with offsite emergency X
DRS planning officials.
.C.3.1 Assessment of Staff RAP SRI a.
Demonstrated commitment to achieving X
improved performance.
b.
Demonstrated safety consciousness.
X oSTi SRI 12 Revised 7/16/97
4 l STATUS f RESP f
NEED c.
Understanding of management's expectations X
losTi l 40500 and goals.
d.
Understanding of plant issues and corrective X
osTi SRI actions.
9 99 e.
Qualifications and training of the staff.
X osTi 41500_
f.
Staff's fitness for duty.
NA g.
Attentiveness to duty.
X osT h.
Level of attention to detail.
X osTI 1.
Off hour plant staffing.
X SRI j.
Staff overtime usage.
X l SRI k.
Procedure usage / adherence.
Awareness of plant security.
X l
DRs m.
Understanding of offsite emergency planning X
DRs issues.
I
! Assessment of Corocrate Suonort and Site C.3.2
! ngineering Suonort E
X osTi
< a.
Corporate staff understanding of plant issues.
I b.
Corporate staff site specific knowledge.
X osTi c.
Effectiveness of the corporate / plant interface X
osTi meetings.
l d.
Corporate involvement with plant activities.
X osT e.
Effectiveness of site engineering support.
X DRs osTi f.
Effectiveness of the site design modification X
DRs osTi process.
g.
Effectiveness of licensing support.
X RAP h.
Coordination with offsite emergency planning X
RAP officials.
13 Revised 7/16/97
l lNEED { STATUS l RESP C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS a.
Applicable license amendments have been X
RAP issued.
b.
Applicable exemptions have been granted.
X RAP c.
Applicable reliefs have been granted.
X RAP d.
Imposed Orders have been modified or X
RAP rescinded.
e.
Significant enforcement issues have been X
f.
Allegations have been appropriately addressed.
10 CFR 2.206 Petitions have been X
NRR appropriately addressed, b.
Atomic Safety and Licensing Board hearings NA have been completed.
C.6 COORDINATION WITH INTERESTED AGENCIES AND PARTIES DRS a.
Federal Emergency Management Agency X
b.
Environmental Protection Agency X
l RAP I.
Department of Justice X
OE lc 01 d.
Department of Labor X
l OE e.
Appropriate State and local officials X
SLO f.
Appropriate public interest groups X
RAP 4
g.
Local news media X
l lOPA 15 Revisad 7/16/97
i ENCLOSURE 5 i
LICENSING AMENDMENT REQUESTS t
LICENSING ISSUES REQUIRED FOR RESTART MILLSTONE UNIT 1 i
No.
TAC No.
Issue Status 1
M94258 Standby Gas Treatment System Waiting for RAI response.
Licensee may revise significantly.
2 M96062 Safety / Relief Valve Electrical Design Waiting for RAI response.
Modification 3
M97934 Response Time Testing Under staff review.
Clarification / Modification 4
M98833 Neutron Monitoring Under staff review.
Note: The licensee indicated that at least one additional licensing action will be needed prior to restart.
l l
l l
l Revised 7/16/97
4 LICENSING ISSUES REQUIRED FOR RESTART **
MILLSTONE UNIT 2 No.
TAC No.
Issue Status 1
M97746 Met. Tower inst.
Under Review 2
M98277 Ultimate Heat Sink Under Review
_3 M98374-Enclosure Building Under Review 4
M94623 Cont. Isolation Valves Need Additionalinfo.
5 M92879 Cont. Rm. Emer. Vent System Under Review 8
M97680 EDG Fuel Oil, TS Basis Change Submit 08/15/97 7
ESFAS - Hersh Environment Submit 08/31/97 8
RCS P-T Curves Submit 08/15/97 9-Max. Containment Pressure Limit -
Submit 08/15/97 -
10 Tech. Spec. Verbatim Compliance Submit 08/15/97 11*
M94106 Steam Gen. Blowdown Mont.
Under Review 12' Rx Trip Setpoints SG Safety Valves Submit TBD 13' Tech. Spec. Safety Limit Curves Submit TBD 14 M97680 Siemens LOCA Anal. Evaluation (non TS)
Under Review 15 Startup Rate Trip (non TS)
Under Review
- These items are awaiting vendor analysis to determine if they are restart items.
- 13 amendment requests (6 under review & 7 to be submitted),2 licensing activities requirin9 review and approval.
2 Revised 7/16/97 1
i L
i LICENSING ISSUES REQUIRED FOR RESTART U
L MILLSTONE UNIT 3 l-p L
- i i-No.
TAC No.
Issue Status 1
M92708 Modified MSIV surveillance and action statements.
Amendment No.136 losued 4/10/97 l
i l
2 M95469 Modified the description of the time constants Amendment No.134 associated with the OT and OP Delta T calculations.
Issued 3/10/97 3
M98288-Changed AFW motor and turbine driven pump Amendment No.139 surveillances.
Issued 5/29/97 4-M98289 Separated the required testing of MOV thermal Amendment No.140 overload protection into 2 new surveillances issued 5/29/97 L
5 M98415 Changed the RHR suction relief valve setpoint.
Amendment No.143 l
Issued 7/10/97 L
i 6
M98455 Clarified the actions to be taken when an area Amendment No.141 temperature exceeds the limit.
Issued 6/24/97 7
M98456 Changed the surveillance requirements for the Amendment No.142 i
hydrogen monitors.
Issued 6/24/97 8'
M98525 Changes Charging and Si pump surveillances.
Urider staff review.-
i i-9 M98630 Adds valves that must be closed to provide flood Under staff review.
protection.
p i
10 M98678 Overcurrent protection devises. Relocates the Under staff review.
?-
300% and 150% circuit breaker test currents to l
the Bases.
I
-11
. M98679 losue clarifies the number of battery banks required Under staff review.
In Modes 5 & 6.
4 i
12 M98680 issue addresses seismic qualification of the spent Under staff review.
i-fuel rocks.
i 1
13 M98681 issue corrects the wording associated with venting Under staff review.
the charging pumps.
[
14 M98699 -
Will allow the SMM to be operable at a lower count Under staff review.
, ate.
I j
15 M98724 Revises the battery changer test requirements to Under staff review.-
equal to or greater than 132V.
16 M98866 issue addresses the testing of the RSS pumps.
Under staff review.
i 17 M99016 Creates a surveillance for the situation when the Under staff review.
reactor trip breakers are closed.
L 3
Revised 7/16/97 j
No.
TAC No.
Issue Status 18 M99041 Table 2.21 Notes. Defines the terms.
Under staff review.
19 M99042 Revises the required volume in the DWST and CST.
Under staff review.
20 M99131 Issue involves partial and full stroking MSIVs.
Under staff review.
21 M99132 isses involves manual containment isolation valves Under staff review, that require intermittent operation in Modes 1-4.
22 M99261 Issue involves adding a new TS and Bases for the Under staff review.
SGARBVs.
Note: The licensee has indicated that it plans to submit 4 additional licensing issues which will be needed prior to restart.
D 4
Revised 7/16/97
O PROJECT PLANNING SCHEDULE MILLSTONE UNIT 3 7/23/97 Qtt1,1997 Qtr 2,1HT Otr 3,1M7 QIt 4,1M7 Qtr1,1998 m
Tasar Name Start Finisti Jan l Feb l Mar Apr l May l Jun Jul l Aug l Sep Oct l Nov l Dec Jan l Feb l Mar 1
CMP UNIT 3 IMPLEMENTATION
- 6/196 7/14/97
{
i i
l 2
ICAVP UNIT 3 IMPLEMENTATION "
5/27s 7 10/2/97 3
NRC ICAVP INSPECTIONS 7/1497 11/28/97 i
4 NRC ICAVP IN-OFFICE REVIEW / DOCUMENT 11/17/97 12/24/97 i
e INSPECTION PROGRAM 2/14/97 10f12/97 s
rEMA NOTIFICATION 9/30/97 10/12/97 g
7 EMPLOYEE CONCERNS PROGRAM INSPEC 9/2997 10/10/97 g
8 UCENSE AMENDMENTS 3S9,'
10f12/97 f
9 OFERATIONAL SAFETY TEAM INSPECTION 10f13/97 11/17/97 10 RESTART ASSESSMENT PANEL REVIEW 11/25/97 12/5/97 E
f g
11 EDO/DtR NRR ERIEF 12/12/97 12/12/97 12 COMMISSION BRIEFING 12/1997 12/1997 g
M C
Configuration Management Program (CMP) carried out by the licensee.
e ICAVP carried out by Sargent & Lundy contractor.
c+
(d
PROJECT PLANNING SCHEDULE MILLSTONE UNIT 2 7/*4S7 Otr1,1997 Qtr2,1997 Otr3,1997 Otr4,1997 Qtr 1,1999 r3 Task Name Start Firdsh Jan l Feb l Mar Agr l May l Jun JJ l Aug l Sep Od l Nov l Dec Jan { Feb l Mar 1
CMP UNIT 2 IMPLEMENTATION
- 60S6 9/5/97 2
ICAVP UNIT 2 IMPLEMENTATION "
7/1S7 11/21/97 l
3 NRC ICAVP INSPECTIONS 8/25/97 113 0 S 8 4
NRC ICAVP IN-OFFICE REVIEWI DOCUMENT 1/20S8 2f27/98 5
INSPECTION PROGRAM 3r3S7 12/24S7 f
8 FEMA NOTIFICATION 11/17/97 11/2W97 7
EMPLOYEE CONCERNS PROGRAM INSPEC
&~29f97 10f1097 g
8 UCENSE AMENDMENTS 5/21/97 11/25/97 I
l 9
OPERATIONAL SAFETY TEAM INSPECTION 1/5/98 2698 i
it RESTART ASSESSMENT PANEL REVIEW 2/1896 2/27/98 i
g 11 EDOIDIR NRR BRIEF 3696 3@96 g
12 COMMISSION BRIEFING 3/1398 3f13/98 l
Configuration Management Program (CMP) carried out by the licensee.
ICAVP carried out by Parsons Power Group, Inc. contractor.
@