ML20198K716
| ML20198K716 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/11/1998 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-98-286, SECY-98-286-01, SECY-98-286-1, SECY-98-286-R, NUDOCS 9812310136 | |
| Download: ML20198K716 (68) | |
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RELEASED TO THE PDR 4
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s, POLICY ISSUE (Information)
December 11, 1998 SECY-98-286 ER8:
The Commissioners FROM William D. Travers Executive Director for Operations
SUBJECT:
STATUS REPORT ON THE CONTINUING RECOVER ( OF MILLSTONE NUCLEAR POWER STATION PURPOSE:
To provide the Commission with (1) a periodic summary of ongoing activities related to the Restart Assessment Plan (RAP) for the Millstone Nuclear Power Station, Unit 2 and (2) an update of Millstone Unit 3 performance since restart. The summary of ongoing activities provides a status of the major elements that require resolution before plant restart. These include the NRC's oversight of the Independent Corrective Action Verification Program (ICAVP), corrective action program implementation at Millstone Unit 2, an assessment of licensing issues for restart, and work planning and control improvements. The staff's assessment of Northeast Utilities'(the licensee's) progress in establishing a safety-conscious work environment (SCWE) and an effective employee concems program (ECP) will be presented in another Commission paper to
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be issued shortly.
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BACKGROUND:
The staff has been in frequent contact with the Commission through various Commission papers and status reports over the past 2 years since Millstone Station was designated as a " watch list" Category 3 facility in June 1996. The Commission also received briefings from the staff, the licensee, pertinent contract organizations involved in oversight activities, members of the public, h/h and State and local officials on approximately a quarterly basis beginning in January 1997
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through June 1998. Although most of these briefings focused on the status and restart readiness of Millstone Unit 3, information on the Millstone Unit 2 ICAVP and on restart activities at Millstone Unit 2 has usually been provided.
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Contact:
l William M. Dean, NRR 301-415-2240 310110 9812310136 981211 PDR SECV 98-286 R PDR
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! SECY-98-090," Selected issues Related to Recovery of Millstone Nuclear Power Station Unit 3," reported to the Ccmmission on the staff's assessment of the licensee's progress to i
establish an SCWE and an effective ECP, as well as the staff's recommendation that the l
licensee had made appropriate improvements to support restart of Millstone Unit 3. The staff l
made similar recommendations regarding the licensee's efforts to improve its oversight and quality assurance functions, as well as its program for managing ths backlog of work at i
Millstone Unit 3.
l SECY-98-119," Remaining Issues Related to Recovery of Millstone Nuclear Power Station, l
Unit 3," reported to the Commission on (1) the staff's assessment of the remaining issues related to the RAP for Millstone Unit 3 and (2) the staff's recommendation regarding authorization for Millstone Unit 3 restan. In Staff Requirements Memorandum (SRM)98-119 l
dated June 15,1998, the Commission concurred with the NRC staff's conclusion that the licensee had taken appropriate corrective actions to support the restart of Millstone Unit 3. The Commission, therefore, approved the staff's proposal to change the watch list status of Millstone Unit 3 from a Category 3 to a Category 2 plant; authorized the restart of Millstonu Unit 3, subject to satisfactory completion of all remaining issues requiring NRC verification; and designated the Executive Director for Operations (EDO) as the senior manager responsible for verifying that the appropriate aspects of NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelines for Restart Authorization," were completed and for approving commencement of actions to restart Millstone Unit 3. By letter dated June 29,1998, the EDO authorized the i
l licensee to commence activities to restart Millstone Unit 3. Millstone Unit 3 has been operating satisfactorily since its startup in July 1998 and the staff's assessment of its performance is discussed below.
DISCUSSION:
In an SRM dated May 7,1997, the Commission directed the staff to send to the Commission -
before each quarterly meeting with the Commission - a written summary of the ongoing activities in the RAP, 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 Commission has not met since June 2,1998; therefore, the staff found it appropriate to give the Commission a status report at this time.
i The staff has identified several major elements in the RAP that require resolution before l
Millstone Unit 2 restart. These elements include corrective action program improvements (as r
implemented at Mi'! stone Unit 2), work planning and control improvements, procedure upgrade programs, and quality assurance and management oversight improvements. The RAP also covers staff activities to evaluate the completion of the ICAVP and the licensee's response to NRC's 10 CFR 50.54(f) letters regarding Millstone Unit 2. The actions listed in the generic MC 0350 restart checklist that are applicable to Millstone Unit 2, such as those regarding management effectiveness and self-assessment capability, are also covered in the RAP. The RAP provides for the conduct of an Operational Safety Team inspection (OSTI) and an NRC Inspection Manual Inspection Procedure (IP) 40500, " Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems,"inspi ction, which are normally carried out to l
assess the overall readiness of a plant for restart after a prolonged shutdown. Attachment 1
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summarizes the status of the major elements of the RAP. Attachment 2 is the latest version (Revision 6) of the Millstone Unit 2 RAP.
O STATUS OF MILLSTONE UNIT 2 AND 3:
Millstone Unit 2 fuel has been removed from the reactor and is being stored in the spent fuel pool. Core reload, originally scheduled by the licensee for August 1998, has been delayed to January 1999. The delay in loading fuel has been caused by the additional time needed by the licensee to complete certain maintenance activities, such as electrical breaker maintenance, fire sealinspections, and emergent work (e.g., cable separation and ampacity issues, equipment qualification). The licensee's current schedule indicates that it intends to have Millstone Unit 2 enter Mode 4 (Hot Shutdown) on February 18,1999, and enter Mode 2 (Startup) on March 24, 1999. It should be noted that previous experience nas shown that for plants starting up after a prolonged outage, the time between entering Mode 4 and being ready to enter Mode 2 is marked by emerging technical and equipment issues. This time period is also when the NRC conducts its major inspection efforts associated with restart readiness (e.g., OSTI). After completing these inspections, the staff will conduct its final RAP review in preparation for a Commission meeting to consider restart authorization for Millstone Unit 2. The licensee's current overall Millstone Unit 2 schedule, as well as the staff's project planning schedule, is provided in Attachment 3.
Overall, the performance of Millstone Unit 3, since its restart in July 1998, has been acceptable and typical of a plant retuming to service after a shutdown in excess of 2 years. Some equipment problems (largely in the balance of plant) have impacted operations. Licensee self-assessments and the NRC inspection program indicate problems still exist in the areas of work control, engineering backlogs, operator staffing, and control of plant configuration. Several operational events (including a forced outage to repair a leaking auxiliary feedwater valve, two manual reactor trips as a result of secondary water chemistry problems, another manual trip due to reduced condenser vacuum, and a number of power reductions to address secondary system problems and several technical specification compliance issues) have caused licensee management to initiate a collective assessment of the number and severity of operational challenges facing the plant staff. The plant operators have responded well to the challenges with e
evidence of conservative decision-making and deliberate efforts to ensure compliance with procedural requirements. Management has recognized the need to strengthen performance in problem areas and ensure that progress at the station is sustained. Attachment 4 is an overall summary of performance at Millstone Unit 3, including the licensee's efforts at reducing the work backlog.
The licensee has commenced a reorganization that will effectively reduce the total number of managers from the director level to first-line supervisors by 50 percent. This reorganization will create a " station" versus a " unit" organization structure. Additionally, key positions that have been vacant or held for several years by contractors, such as the unit directors, are being staffed with Northeast Utilities employees. This reorganization will require extensive senior management involvement over the next several months. The reorganization, which will be implemented in stages, will be closely followed by the staff.
The transition of the NRC oversight organization from the Special Projects Office to a more normal alignment, with the focal point for restart residing with the Region I Regional Administrabr, is complete. Regional senior management have conducted several site visits to review plant status and assess progress being made. Meetings were held with the licensee and public citizens to announce the transition and introduce the new management team.
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The staff finds that the licensee is progressing in its various activities to effect needed l
improvements at Millstone Unit 2. Although progress has not kept pace with the licensee's initial schedules, improvements in essentially all elements of the NRC's RAP for Millstone Unit 2 are being identified. This progress notwithstanding, the NRC staff's most important assessments of the licensee's readiness for restart have not yet taken place. These assessments are l
necessarily focused on the latter stages of the licensee's improvement program. A number of l
significant inspection activities (e.g., OSTI, IP 40500, and ICAVP-related corrective action effectiveness) will be initiated following the licensee's own readiness determination. These l
inspections and the staff's remaining evaluations of the issues identified in the Millstone Unit 2 RAP will ultimately form the bases for a staff restart recommendation to the Commission.
The staff is continuing to plan and carry out its inspection and licensing activities. This will require extensive coordination with the licensee's s ' ndules and continual assessment of the licensee's progress. Given that the licensee's scht ale for restart currently shows the transition to Mode 4 in February and Mode 2 in March 1999, the staff believes it would be appropriate to conduct a Commission briefing in the near future to discuss Millstone Unit 2 status and progress.
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William D. T avers Executive Director for Operations Attachments:
- 1. Status of Major Elements of the Millstone Unit 2 RAP
- 2. Millstone Unit 2 RAP, Revision 6
- 3. Millstone Unit 2 Ucensee's Restart Milestones and NRC's Project Planning Schedule
- 4. Millstone Unit 3 Post-Restart Performance Assessment DISTRIBUTION:
Commissioners OGC OCAA OIG OPA OCA ACRS l
REGIONS SECY
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Status of Maior Elements of the Millstone Unit 2 Restart Assessment Plan Iltle Page i
Manual Chapter 0350 and Restart Assessment Plan.................................
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Independent' Corrective Action Verification Program.................
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Licensing Issues...............
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- 10 CFR 50.54(f) Activities (Deferred items)............
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Corrective Action Program....................
10 Ove rsig ht...................................................................
12 Work Planning and Controls...............................
15 Procedure Upgrade Program.......
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ISSUE:
Manual Chapter 0350 and Restart Assessment Plan DISCUSSION:
As part of its execution of NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," the staff developed a Restart Assessment Plan (RAP) for Millstone Unit 2. The RAP was developed to cover all the expected NRC actions required before the NRC approves plant restart. The staff 'leveloped an RAP for each Millstone unit to incorporate the appropriate aspects of MC 0350 and to address site-specific and unit-specific issues.
One of the elements of the RAP is the significant items list (SIL). The SIL contains items that the NRC is using to audit and evaluate licensee programs and other significant safety and regulatory issues. When the licensee has j
completed actions associated with a particular item on the SIL, it gives a pacl: age to the staff. The staff then reviews the package and performs any needed inspection activities before closing out the issue.
l Because of the licensee's attention to the restart of Millstone Unit 3, until recently, few licensee and NRC resources have been devoted to Millstone Unit 2. The licensee placed most of its emphasis on executing the Configuration Management Program (CMP) vice Millstone Unit 2 restart readiness. The licensee has been slow in correcting items identified on the Millstone Unit 2 SIL, limiting the number of SIL packages that have been submitted for NRC review.
NRC ACTION:
Closure of the MC 0350 checklist is in its early stages. Most checklist items concerning licensee readiness are still open because of plant status. Closure of many MC 0350 items depends on the licensee achieving physical plant readiness for Mode 4 and Mode 2, and on the results of future NRC inspections. These inspections include the Independent Corrective Action Verification Program (ICAVP) inspections, the Operational Safety Team inspection (OSTI), and the NRC Inspection Manual Inspection Procedure (IP) 40500," Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems." The OSTI and IP 40500 inspections have been tentatively scheduled for early 1999.
STATUS:
The Millstone Unit 2 SIL currently consists of 54 line items, which the licensee has stated will require 75 separate packages for closure. The NRC has received 47 closure packages from the licensee. As of November 13,1998, 30 SIL packages have been closed by the NRC. On the licensee's current schedule, all the SIL packages will be submitted to the NRC by March 18, 1999.
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Independent Corrective Action Verification Program DISCUSSION: On August 14,1996, the NRC issued a confirmatory order establishing an ICAVP. This program, independently carried out by a contractor approved by
- the NRC, is intended to verify the adequacy of Northeast Nuclear Energy Company's (NNECO's) efforts to establish adequate design bases and design controls (i.e., translate the design bases into operaung procedures and maintenance and testing practices, verify system performance, and verify implementation of modifications made 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 corrbt iting problems in the design and configuration control processes. It u a
three-tiered approach, as described in SECY-97-003, " Millstone nestart Review Process," dated January 3,1997, to evaluate a sample of the i
licensee's activities. The NRC's oversight of the ICAVP is one of the many activities that make up the RAP. The results from this program will be a major factor in whether the NRC recommends restart.
NNECO has implemented its CMP, which was developed to confirm that the future operation of Millstone Unit 2 will be con Jucted in accordance with the terms and conditions of its operating license, the Millstone Unit 2 Final Safety Analysis Report (FSAR), and NRC regulations. The CMP included a review of the licensing and design bases requirements for the 63 Millstone Unit 2 systems that the licensee has categorized through implementation of the i
maintenance rule as either Group 1 (safety-related and risk-significant) or Group 2 (safety-related or risk-significant). After NNECO completed its problem identification for half the Millstone Unit 2 Group 1 systems l
(June 30,1997), the ICAVP contractor began the ICAVP review. NNECO completed the problem identification phase of the CMP for Millstone Unit 2 on September 15,1997.
NRC ACTION: The staff's oversight objectives are to ensure that the review by the ICAVP l
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 reviewed and approved the proposed ICAVP contractor for Millstone Unit 2 and approved the contractor's ICAVP audit plan. The staff selected the specific systems to be evaluated in the ICAVP, with input from the Connecticut Nuclear Energy Advisory Council I
(NEAC). The NEAC selected two of the systems to be reviewed by the ICAVP contractor for Millstone Unit 2 from a list of systems identified by the i
NRC. Key design aspects of many of the systems being evaluated by NNECO will be assessed in the ICAVP; four systems were examined in detail by the contractor. The scope of the ICAVP will be broadened if significant issues are identified in the assessment of NNECO's corrective actions.
In overseeing the ICAVP and the ICAVP contractor, the staff performs its own independent inspections. Six separate inspections of licensee and ICAVP contractor activities were planned: an ICAVP implementation inspection, two
. independent vertical-slice inspections of at least two systems at Millstone Unit 2 (one within the scope of the ICAVP and one outside the scope), an inspection of change processes used at the site, a functionalinspection of accident mitigation systems relied on to mitigate the consequences of two accidents analyzed in the FSAR, and an inspectim of the corrective actions implemented as a result of findings made during i INECO's CMP, the ICAVP, and NRC ICAVP oversight inspections. The staff vill also evaluate the final results of the ICAVP contractor's audit and assessreent of the licensee's corrective actions. The staff's oversight plans are di scribed in detailin SECY-97-003.
STATUS:
As previously noted in SECY-97-283, " Recovery of Millstone Nuclear Power Station," dated December 4,1997, the staff approved Parsons Power Group Inc. (Parsons) as the ICAVP contractor for Millstone Unit 2 on May 28,1997.
On July 1,1997, after the problem identification phase had been completed for half the Group 1 maintenance rule systems, the staff selected the high-pressure safety injection system including the refueling water storage tank and the auxiliary feedwater (AFW) system, and the condensate storage tank as the first two systems to be inspected for the Millstone Unit 2 ICAVP.
NNECO declared the problem identification phase of the CMP completed on September 15,1997. On September 18,1997, NEAC selected the emergency diesel generator (EDG) and support systems (comprising five maintenance rule systems) and the radiological release control system (comprising two maintenance rule systems) as the next two system:; to be reviewed during the Millstone Unit 2 ICAVP. With the selection by NEAC of these systems, a total of 11 maintenance rule Group 1 or Group 2 systems were included within the scope of the Millstone Unit 2 ICAVP.
As of November 11,1998, having issue i 811 preliminary discrepancy reports (DRs) (762 valid and 49 invalid), Parson; has essentially completed its discovery phase. Of the valid DRs issued to date,648 DRs have been closed, with 59 as confirmed Level 3 DRs, 451 as confirmed Level 4 DRs,90 as nondiscrepant, and 48 as previously identified. The closure rate of the DRs has improved as NNECO and Parsons have focused more resources on DR review and closure. At the current cate of closure, the staff anticipates that NNECO and Parsons will reach agreement on the issues and the significance levels for the remaining Millstone Unit 2 DRs within the next several weeks.
The staff has completed five of the six-planned ICAVP oversight inspection activities: (1) the ICAVP implementation inspection (Inspection Report (IR) 50-336/97-211), completed on December 12,1997 (early evaluation of Parsons' implementation of the ICAVP audit plan); (2) the Tier 1 out-of-scope safety system functional inspection (SSFI) (IR 50-336/98-202), completed April 4,1998, of the reactor building closed cooling water (RBCCW) system and associated portions of the service water system (SWS) and electrical systems; (3) the Tier 3 design change process inspection (IR 50-336/98-201),
completed May 15,1998; (4) the Tier 2 accident mitigation system inspection (IR 50-336/98-213), completed September 11,1998, of the main steamline
, break (MSLB) and small-break loss-of-coolant accident (SBLOCA) as analyzed in Chapter 14 of the Millstone Unit 2 FSAR; and (5) the Tier 1 inscope SSFl (IR 50-336/98-203), completed October 2,1998, of the AFW.
The only ICAVP oversight inspection activity that remains to be completed is the review of the corrective actions implemented by NNECO in response to issues identified during the CMP, the ICAVP, and NRC ICAVP oversight inspections. The staff currently plans to do the corrective action inspection in two phases: the first phase in early December 1998 and the second phase in early February 1999. This schedule is contingent on the licensee's ability to complete the corrective actions for items identified in the NRC ICAVP inspections and Parsons' confirmed Level 3 DRs.
During the ICAVP implementation inspection, the staff determined that Parsons was adhering to the NRC-approved ICAVP audit plan in its implementation of the ICAVP at Milletone Unit 2. Parsons took appropriate actions to address minor issues that were identified.
During the Tier 1 out-of-scope SSFI, the staff observed that before its selection of RBCCW as the out-of-scope system on September 19,1997, NNECO had already identified and resolved many important RBCCW design vulnerabilities. Although violations were identified during this inspection that l
were considered to be equivalent to ICAVP Significance Level 3 issues I
(conditions outside the design or licensing bases that did not affect the ability of a system to perform its safety-related functions), the inspection team concluded that, overall, NNECO had adequately assessed the RBCCW system's capability to perform its safety functions, its conformance to its design and licensing bases, and its operational compliance with the FSAR and Millstone Unit 2 Technical Specifications (TS).
In assessing NNECO's configuration control and change processes, the staff concluded, on the basis of the results of the Tier 3 design change process inspection, that the implementation of the existing Millstone Unit 2 change l
processes and procedures met the requirements of 10 CFR Part 50, Appendix B, " Quality Assurance," and should be adequate to maintain the Millstone Unit 2 design and licensing bases. Further, the staff concluded that I
the Parsons Tier 3 ICAVP review was conducted in accordance with the l
NRC-approved audit plan and project procedures and that the reviews were thorough and critical. Generally, the NRC team's findings during this I
inspection vere consistent with Parsons' ICAVP findings. An area that both the staff and Parsons determined that required additional attention from NNECO was establishing the threshold for performing safety evaluations in accordance with 10 CFR 50.59.
The NRC Tier 2 team inspection focused on a functional review of the systems involved in the mitigation of two accident scenarios: the MSLB and the SBLOCA. On the basis of the results of the Tier 2 accident mitigation systems inspection, the staff concluded that the accidents analyzed in Chapter 14 of the FSAR appeared consistent with those used in the design of the mitigation systems and that the accident analyses should be adequate to
. maintain the Millstone Unit 2 design and licensing bases. The team found that Parsons' ICAVP Tier 2 reviews were generally conducted in accordance with the NRC-approved ICAVP audit plan and proiect procedures and that the reviews were conducted in a thorough, detailed, and critical manner.
Generally, the team's findings were consistent with Parsons' ICAVP findings.
The team identified several instances in which the licensee failed to translate design-basis requirements into plant procedures. An example was the failure to include a prohibition, assumed in the MSLB accident analysis, for using the feedwater-regulating bypass valves above 25 percent power in the operating procedure for the feedwater system.
The final Tier 1 SSFl was conducted on portions of two systems within the scope of the ICAVP (the AFW system and the EDG sequencer). As a result of this inspection, the staff found that, overall, the breadth and depth of the Parsons review was in accordance with the NRC-approved ICAVP audit plan.
Although the team identified issues not discovered by the CMP or by Parsons, the safety significance of the findings was low. On the basis of the results of i
the team's independent design review and the team's assessment of Parsons' implementation of Tier 1, the staff concluded that NNECO's CMP was generally effective in identifying and correcting nonconformances with the plant's design and licensing bases. The only exception noted during this inspection was the licensee's failure to identify, during its CMP, that it had not properly evaluated a Technical Requirements Manual (TRM) TS clarification that would have allowed isolation of the single flow path for AFW to one of the two steam generators (SGs) for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This was not identified by Parsons during the ICAVP. Both the licensee and Parsons have expanded their rcviews of the TRM. This TRM error and the issues identified during the e
Tier 2 inspection are indicative of a weakness in the configuration control process in the translation of accident analyses inputs to plant procedures.
NNECO recognizes this weakness and is evaluating possible co rective actions. Parsons also identified this process weakness during its ICAVP review. The additional reviews of the TRM have been completed by the licensee and Parsons. Parsons' review was confined to the portions of the TRM that address Tier 1 systems. Parsons did not identify any other issues.
The licensee's review of the TRM identified a similar concern with new fuel handling, which the licensee is addressing.
In addition to the inspection activities, the staff continues to conduct its routine oversight activities: participating in several publicly observable meetings between the licensee and Parsons to discuss the status of the ICAVP, meetings to resolve specific DRs, and daily teleconferences between Parsons and the licensee, and reviewing the licensee's submittal on two preliminary Level 1 DRs for which Parsons and the licensee could not agree.
l One of the DRs involved the possibility of water leakage into the underground i
nonsafety-related EDG fuel oil storage tank, resulting in loss of function of both diesel generators. The other DR identified a lack of redundancy in the ventilation dampers that isolate the enclosure building purge system after a postulated LOCA. In the first case, the staff found that the plant was in l
l conformance with its licensing basis and, therefore, the issue was not a Level 1 DR. However, the licensee voluntarily made procedural changes that prohibit automatic fuel oil transfer to the safety-related day tanks during adverse weather conditions. This procedure change eliminated the concern.
The staff is reviewing the second potential Level 1 DR.
The staff has taken a more active role in facilitating the discussions during the teleconferences between the licensee and Parsons. The staff continues to review and approve changes to Parsons' ICAVP audit olan and implementing procedures and to interview new staff added by Parsons to implement the j
The staff has implemented several changes to the ICAVP process for i
Millstone Unit 2 to take advantage of lessons learned during the Millstone Unit 3 ICAVP. The most significant change made at Millstone Unit 2 was to have Parsons use a sampling approach to review the corrective actions taken l
by NNECO during the ICAVP. Parsons' will review corrective actions to resolve issues identified by NNECO during the CMP and confirmed DRs issued by Parsons. On October 21,1998, the staff informed NNECO and Parsons of the sample of corrective actions ident;fied by NNECO during the CMP to be included within the scope of the ICAVP and the criteria for expanding the scope of Parsons' review in this area.
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l I ISSUE:
Licensing issues DISCUSSION: The licensee plans to submit or has submitted licensing issues (amendments, unreviewed safety questions (USQs), relief requests, etc.) that will need to be reviewed before restart.
NRC ACTION: The staff will process and review licensing actions as the licensee identifies and submits them. The staff will follow the normal processes for these reviews.
STATUS:
On the basis of the licensee's review of existing license amendment requests and an in-depth review of the Millstone Unit 2 TS, the licensee has identified a number of licensing issues that require resolution before restart.
l As of November 13,1998, the licensee had identified 48 licensing issues that require NRC staff review before restart. Of the 48 licensing actions,27 have been completed (11 TS amen 6 nents,3 TS withdrawals,1 license amendment resolving a USO,2 issues the licensee ultimately determined did l
not need to be submitted after discussions with the technical staff, and 10 l
other licensing activities). Of the remaining 21 licensing actions,16 have l
been submitted and are currently under staff review (8 TS amendments,4 USQs,3 other licensing actions, and 1 exemption). The remaining five licensing actions (all of them USQs) are scheduled to be submitted in December 1998, except for a USO associated with cable raceway separation, which is scheduled to be submitted in early January 1999. It is possible that additional licensing issues will emerge as the licensee continues its effort to resolve licensing and design bases issues.
The amendments submitted to date and the staff's projected review schedule do not appear to affect the licensee's ability to restart on its current schedule.
However, the staff has asked for additional information on several license amendment requests, lengthening the review process. Late submittals or newly emerging issues, which require extensive staff review, may slow the licensee's projected schedule.
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. ISSUE:
10 CFR 50.54(f) Activities (Deferred items)
DISCUSSION:
On December 13,1995, the NRC sent a letter to Northeast Utilities (NU),
requesting NU, pursuant to 10 CFR 50.54(f), to provide information describing actions taken to ensure that future operations of Millstone Unit 1 will be conducted in accordance with the terms and conditions of the Millstone Unit 1 L
operating license, the Commission's regulations, including 10 CFR 50.59, and the Millstone Unit 1 Updated Final Safety Analysis Report. Similar letters were sent to NU for Millstone Unit 2 on March 7,1996, and for Millstone Unit 3 on April 4,1996.
On April 16,1997, the NRC sent a letter to NU requesting information pursuant to 10 CFR 50.54(f) (superseding previous letters requesting inform en l_
pursuant to 10 CFR 50.54(f)). The April 16,1997, letter asked the licensee to j
provide information on (1) the significant items that needed to be done before restart, (2) items to be deferred until after restart, (3) NU's process and rationale for deferring items until after restart, and (4) actions taken to ensure i
that future operation of the unit (s) will be conducted in accordance with the license, regulations, and the FSAR.
l In accordance with the requests made in the April 16,1997,10 CFR 50.54(f) letter, the licensee has responded to the first three items, most recently to items 1 and 2, submitted on September 24,1998. The licensee had previously used four criteria (item (3)) for deciding whether an item affected restart: (1) whether it implemented or supported a change to plant TS; (2) whether it corrected a licensing or design-basis deficiency; (3) whether it accomplished a restart license commitment, or (4) whether it resolved an operability concern about a maintenance rule Group 1 or 2 system. The licensee has committed to describe its actions taken to ensure that future operation of Millstone Unit 2 will be conducted in accordance with the license, regulations, and FSAR and send its description to the Commission approximately 30 days before the Commission meeting on restart.
NRC ACTION:
In October 1997, the NRC staff reviewed the licensee's October 21,1997, submittal. The inspectors found that the decision-making process for deferring items was conservative and the items on the deferred issues list would not i
affect safe plant operation. The licensee was generally able to justify the items on the deferred issues list. Only two items were moved to the restart list as a result of the inspections.
I The inspectors also noted that the licensee's process for developing the list j
had been improved to correct the completeness and accuracy problems that were identified during a previous NRC review of the Millstone Unit 3 deferred issues list (NRC IR 50-423/97-202). The Nuclear Oversight Department was more involved and the Plant Operation Review Committee at Millstone Unit 2 did a line-by-line review of the items on the list as part of the review and approval process.
The inspectors concluded that the items on the deffered issues list were appropriate for deferral and, overall, the list reflected a conservative decision-6
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r making process. The inspectors did not identify any issues that, if not s
corrected before plant restart, would have resulted in a significant safety concem during plant operations.
STATUS:
~ The NRC plans to inspect the Millstone Unit 2 deferred issues list again in late l
- 1998, looking at items added to the list since the last inspection of the Millstone Unit 2 list in October 1997. The staff also plans to inspect the Millstone Unit 2 deferred issues list closer to restart.
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. ISSUE:
Corrective Action Program DISCUSSION:
Previous licensee self assessments and NRC inspections had found that NNECO's corrective action program had been historically weak in identifying problems and ineffective in ensuring comprehensive and effective corrective actions. In many instances, narrowly focused corrective actions had failed to encompass all aspects of the underlying problem. Additionally, the licensee often did not follow up on corrective actions to ensure they were effective. A correlation also existed between the ineffectiveness of the corrective action program and the issues related to the handling of employee safety concems and the safety-conscious work environment (SCWE) at Millstone. An impcrtant i
element in an effective corrective action program is encouraging workers to raise issues willingly without fear of retribution or retaliation. Consequently, the RAP made the licensee's corrective action program an important issue.
NNECO initiated efforts in early 1997 to improve the corrective rction program by adopting industry standards and processes and formalizing them in its procedure Reports (RP) 4," Corrective Action Program." The improvements t
included a lower threshold for reportable problems, more management emphasis on the need for employees to identify problems, more management involvement in the process, prompt processing of operability determinations, development of performance indicators, root-cause analysis training, and enhanced tracking and trending programs.
NRC ACTION:
To ve;ify the licensee's actions, supplementing the day-to-day observations i
and interactions of the resident inspectors, the NRC performed a number of multipurpose inspections to assess the effectiveness of the process. The NRC performed a team inspection using IP 40500. The NRC did an inspection of j
the effectiveness and the appropriateness of the licensee's corrective actions for design concems raised by the NRC in its ICAVP-related inspections, the licensee in its CMP, and Sargent and Lundy in its ICAVP. An OSTI was performed at Millstone Unit 3, which audited parts of the corrective action process. In the context of the OSTI, the NRC staff reviewed the licensee's corrective action program and subordinate procedures, audit reports developed l
by NNECO's Nuclear Oversight organization, the licensee's independent l
Review Team Report on the Effectiveness of Corrective Actions, the NRC IP l
40500 inspection team report, and outstanding corrective action items.
l The NRC stco gained insights into the effectiveness of the corrective action program by assessing the licensee's implementation of the employee concems program (ECP) and its efforts to establish an SCWE. Integral to the staff's evaluation of Millstone SCWE activities was its assessment of the licensee's programs for resolving safety issues raised in the line organization. Staff observations and interviews showed that managers and supervisors encouraged employees to identify problems. These observations and findings were consistent with those of Little Harbor Consultants, Inc. (LHC), the third-party organization approved by an NRC order to oversee the licensee's implementation of the SCWE program. LHC also assessed NNECO's corrective action program and found the program and its implementation acceptable.
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i-The foregoing inspections revealed that an appropriately low threshold exists at Millstone Unit 3 foridentifying conditions adverse to quality. NNECO management had effectively communicated new standards to the working staff so that problems would be identified and referred to the corrective action program for resolution. Although the emphasis of these inspections has been on the Millstone Unit 3 implementation of the corrective' action program, much l
of the licensee's program applies to Millstone Unit 2 because it is a site process.
l o the basis of the NRC inspections, SECY-90-090 concluded that the n
licensee's implementation of the corrective action program was adequate for Millstone Unit 3 and would support the restart of Millstone Unit 3. Although the staff found that the licensee's corrective action program was adequate to i
support the restart of Millstone Unit 3, the staff wants to look at the long-term -
performance. Historically, the licensee has had problems in maintaining an effective corrective action program. The staff committed to assess the effectiveness of the corrective action program at Millstone Unit 3 approximately 1 year after plant restart. This inspection may be combined with the staffs inspection of the implementation of the corrective action program at Millstone Unit 2, depending on the pace of the recovery of Millstone Unit 2.
STATUS:
The routine inspections performed to close the SIL issues assess the licensee's corrective action pragram on an ongoing basis and will provide much l
of the staffs overall assessme nt of the corrective action program. Additionally, j
the IP 40500, ICAVP correr4ive action, and OSTI inspections will be performed for Millstone Unit 2 and w4s independently provide insights into the I
effectiveness of the implementation of the corrective action program at Millstone Unit 2. Those inspections will form the basis for the staffs decision on whether the implementation of the corrective action program at Millstone Unit 2 supports restart.
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' lSSUE:
Oversight DISCUSSION:
In 1996, through self-assessments and extemal and internal audits, the licensee identified its oversight function as deficient and as a contributing factor in its declining performance. The root-cause evaluation in Effectiveness of Oversight Organization by the Yankee Atomic Electric Company, dated
. September 10,1996, examined the failure of Quality Assessment Services, the l'
independent Safety Evaluation Group (ISEG) and the Nuclear Review Board l
(NRB) to identify the deficient FSAR control process and the degraded l '
radioactive waste conditions, predominantly in Millstone Unit 1. The licensee found that management did not adequately support the ISEG and the NRB.
j On July 22,1996, the Nuclear Committee Advisory Team sent a report to the Nuclear Committee of the Northeast Utilities Board of Trustees that forwarded
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previous report findings by the Fundamental Cause Assessment Team. As the report noted, " Senior executives at Northeast Utilities, from the CEO [ Chief Executive Officer) to senior nuclear site executives, were ineffective over a number of years in providing vision, direction, and leaders, hip necessary for the management of the NU nuclear power program... Key performance issues, such as an effective corrective action program,... critical self evaluation processes were not fully appreciated by senior management even after they were identified by outside industry and regulatory agencies."
l The Systematic Assessment of Licensee Performance evaluations for the l:
period December 1990 to July 1994 twice judged the Safety Assessment and Quality Verification area to be Category 3. Weak self-assessments and ineffective independent oversight contributed to the low level of performar.ce.
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in addition, the Joint Utilities Management Assessment (JUMA) issued a critical report following its 1996 review, which concluded that the quality assurance (QA) program had not been effective in resolving identified problems, including those documented in previous QA intemal and extemal assessments. A subsequent JUMA, which completed its onsite assessment in June 1998, l
determined that the Nuclear Oversight (NOS) organization had improved in i
every area evaluated. However, the team noted that the transition from unit restart goals to station operational excellence required additional efforts to reinforce the gains made since 1996, particularly in the area of issue ownership, the emphasis on the overall site responsibility for quality, and the need for improvement in the response to numerous Condition Reports (CRs).
These recent JUMA findings resulted in the issuance of four new CRs, covering such broad issues as " expectations, communication, teamwork and trust, and corrective action program implementation," where continued improvements are expected.
NNECO developed a broad-based corrective action program for the deficiencies identified through intemal and extemal assessments of NOS.
Among these actions were (1) promulgating corporate expectations for NOS, (2) reorganizing and staffing, (3) developing new hold-point inspection procedures, (4) improving communications between line organizations, NOS, (5) improving the skills of the NOS staff in performance-based assessment, w
. and (6) developing the NOS Restart Verification Plan (NORVP) to assess key issues in the recovery process. The NORVP contained approximately 20 key issues that were tracked by NOS to gauge the performance improvements being made by the line organization.
Since the startup of Millstone Unit 3 in June 1998, the NOS has changed its NORVP assessment process to a Nuclear Oversight Verification Plan (NOVP) format, which incorporates a review nf common site programs (e.g., security, emergency planning, and training) along with separate assessments of Millstone Unit 3 operations, Millstone Unit 2 restart readiness, and Millstone Unit 1 maintenance. Recent NOVP reports have identified the need for improvements for some of the key issues affecting each of the three units, as well as the common site programs. The full scope of NOS activities, including the NOVP, appears directed toward focusing Millstone station management attention to the areas impacting Millstone Unit 2 restart readiness and the achievement of operational excellence for overall station performance.
NRC ACTION:
In February 1998, an NRC team inspection examined the area of NOS, using NRC IP 40500. The inspection covered several areas, including the review of NOS, which implements the NNECO QA program required by 10 CFR Part 50, Appendix B. An understanding of the effectiveness of the licensee's oversight program was obtained through personnel interviews, program evaluations, procedure reviews, and an assessment of the NORVP. The team also examined the TS-required ISEG and the activities of the Nuclear Safety Assessment Board.
In addition to the IP 40500 team inspection, the resident, regional, and contractor inspectors evaluated NOS effectiveness through the routine inspection program and the special inspections associated with the closure of Milistone Unit 3 RAP SIL items.
In April 1998, an NRC OSTI evaluated the readiness of plant hardware and staff and management programs to support a safe restart and continued operation of Millstone Unit 3. For example, the OSTI verified that management programs, such as self-assessments, communications, independent oversight, management review committees, and safety committees, were adequate to support safe operation.
On the basis of the NRC inspections, the staff concluded that oversight and quality assurance were adequate to support the restart of Millstone Unit 3 for the following reasons: (1) the reorganization and the replacement of key managers within NNECO, especially in Nuclear Oversight; (2) the promulgation of improved management expectations; (3) the establishment of open communications between the line organization and NOS and within NOS; (4) the completion of staffing and improved quality and training of the NOS staff; I
(5) development of a viable inspection and audit program; (6) demonstrated improvements in NOS problem identification and assurance that corrective actions are implemented; (7) improved performance of quality control inspectors; (8) a credible performance by the safety committees; and (9) an effective self-assessment program.
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. STATUS:
NOS has overseen Millstone Unit 2 through audits and surveillances of plant activities, particuiarly in the area of readiness for fuel load. NOS is also monitoring the licensee's overall readiness for plant restart. Millstone station is currently undergoing a reorganization. As a result, the Nuclear Oversight and the Regulatory Affairs groups report to a new vice president. The staff will continue to monitor oversight activities to assess the effect of the new i
organization.
Although the IP 40500 and OSTI inspections focused on Millstone Unit 3, many 4
of the conclusions previously noted apply to Millstone Unit 2 because the oversight program is site-wide. However, the staff will perform both the OSTI and the IP 40500 inspections before Millstone Unit 2 restart to assess the effectiveness of the Nuclear Oversight group at Millstone Unit 2.
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l l - ISSUE:
Work Planning and Controls DISCUSSION:
Work planning and controls are areas in which the licensee has shown weaknesses in the past. The ability to plan, control, and complete work is an important factor in achieving prompt and effective corrective actions.
Additionally, effective work planning and controls are prerequisites for reducing and managing work backlogs.
l The NRC staff reviewed the licensee's revised automated work order (AWO) process, which was implemented site-wide in 1997. The AWO process is an integral part of the work planning and control system. It determines the scope of the work, establishes the appropriate procedures, and sets the tagging boundaries. This process is noticeably better than previous processes at Millstone.
NRC ACTION:
The work control process at Millstone Unit 2 is the subject of ongoing routine inspections. In early November, the first integrated and resource-loaded schedule was issued for Millstone Unit 2. In the future, Millstone Unit 2 plans to use a 12-week rotating schedule for the maintenance of plant equipment.
However, emergent work has kept the unit from fully implementing the new schedule. Progress has been slow in addressing weaknesses in the work control area due to the large residual Millstone Unit 3 backlog and emergent work from the ongoing Millstone Unit 2 outage.
STATUS:
The staff will perform an OSTI, which will include an in-depth review of the l
Millstone Unit 2 work control process. This inspection is tentatively scheduled l
for early 1999.
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. ISSUE:
Procedure Upgrade Program DISCUSSION:
Quality of and adherence to procedures had been chronic problems at the Millstone site for all three units. The need to improve procedure quality was an element in the improving Station Performance Program (circa 1995) and the eart!sr Performance Enhancement Program (circa 1992). In response to NRC concems, the licensee developed the Procedure Upgrade Program (PUP) in 1992 to improve station procedure quality on a site-wide basis. The licensee's PUP commitment was made in a letter to the NRC dated June 4,1992, describing its overall Performance Enhancement Program. Because of the licensee's longstanding commitment to complete the PUP and correct past procedure adherence and quality problems, the satisfactory performance of the licensee's PUP was considered as a separate issue in the NRC RAP.
Although various procedure improvement programs had been ongoing since l-the late 1980s, the licensee committed to improve procedures to reflect industry standards for format and to standardize procedures at all three units in i
the PUP. As a result, the station document control administrative procedures were developed to apply to the three units. Recent inspections by the NRC have verified that most of the commitments made in the letter of June 4,1992, were met.
NRC ACTION:
The licensee has essentially completed the PUP for Millstone Unit 2. The NRC performed a series of inspections of the PUP starting in August 1996, and ending in August 1997. These inspections determined that the licensee had met most of its commitments, particularly in standardizing the format of station procedures and reducing the number of higher tiered procedures.
STATUS:
ICAVP inspections of the technical adequacy of Millstone Unit 2 procedures are ongoing. Millstone Unit 2 has a backlog of procedure changes besides those required by the PUP. These procedure changes were initiated through other processes such as the CMP, procedure performance, biennial reviews, design changes, and TS changes. Because of problems identified in the adequacy of surveillance tests during 1996 and early 1997 NNECO has performed a 100 percent review of Section 4 of the Millstone Unit 2 TS to confirm that all surveillance tests will validate conformance to the TS. This process has been completed and surveillance tests are being revised to correct identified deficiencies. The licensee also reviewed conformance of its surveillances to those required by the Millstone Unit 2 TRM (also discussed in ICAVP section) and the testing required by ASME Code Section XI," Pumps and Valves." The review of the surveillance tests affecting Modes 5 and 6 is complete and the licensee is taking the appropriate corrective actions. The licensee is still reviewing surveillance tests affecting Modes 1-4.
L Procedures will be reviewed for adequacy through the ongoing NRC ICAVP inspection process and routine NRC inspections. The Millstone Unit 2 OSTI L
will make the final decision on whether the procedures are adequate for restart.
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l MILLSTONE UNIT 2 - RESTART ASSESSMENT PMN, REVISION 6 i
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.I RESTART ASSESSMENT PLAN MILLSTONE STATION APPROVED BY:
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REVISION 6 l
l' MILLSTONE RESTART ASSESSMENT PLAN
1.0 BACKGROUND
1.1 HISTORICAL The three Millstone units shut down to formulate responses to a series of 10 CFR 50.54 (f) letters requiring them to affirm their compliance with the l
conditions of each unit's license and the regulations. During May June,1998, 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. The licensee initially focussed on Unit 3 as the lead plant for restart. However, as a result of a licensee reorganization which occurred on October 1,1996, each Millstone unit was i
assigned a recovery manager who was an executive on temporary loan from l
another nuclear utility. Resources originally assigned to Unit 3 from the other units l
were returned to their respective units. Each unit has been tasked with establishing l
their own restart plan and whichever unit is ready will apply to restart first. Hence this restart assessment plan has been expanded to include Manual Chapter (MC)-0350 evaluations (see paragraph 3.0) for all three units.
On June 28,1996, the Executive Director for Operations (EDO) issued a letter to the licensee that stated the Commission had decided to make the three Millstone units a Category 3 on the Watch List and would vote on the restart of the Millstone l
units. It is the intent to implement the appropriate aspects of NRC Manual Chapter 0350," Staff Guidelines for Restart Approval" for the restart of all three units. The i
NRC will schedule and implement its inspection program after the licensee has j
l indicated that the individual activities necessary for restart are complete and ready j
for inspection.
The NRC has been dealing with Northeast Utilities on broader performance issues which go beyond the 10 CFR 50.54(f) concerns. These broader concerns are considered contributory causes for the current poor performance, which the 10 CFR 50.54(f) issues are a subset. These issues have been formalized by the licensee in l
a program titled " improving Station Performance" (ISP) and are topics that will be l
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 l
was not adequately managing the program or tracking progress.
l 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 inspection of the Improving Station Performance issues is discussed in more detail in Section 3 of this plan.
REVISION 6
3 On November 3,1996, the agency established the Special Projects Office (SPO) to consolidate NRC efforts under a single Senior Executive Service (SES) manager, who reports to the Director of the Office of Nuclear Reactor Regulation (NRR). The Director, SPO assumed the authority and responsibilities of the Regional Administrator and the Associate Director of Projects.
1.2 CURRENT STATUS Millstone Unit 2 is currently preparing for restart estimated to be sometime during 1999; Unit 1 is to be permanently shutdown; and, Unit 3 restarted June 29,1998 and is currently operating at 100% power. Units 2 and 3 still remain on the NRC watchlist. The NRC's Special Projects Office has been eliminated and inspection activities, except for ICAVP inspections and Employee Concerns / Safety Conscious Work Environment oversight, have been returned to NRC Region 1.
NRCICAVP activities for Unit 2 will remain a separate NRR function until completion of Unit 2 restart. The Region 1 Regicnal Administrator has overall responsibility for the Millstone 2 restart oversight process.
2.0 10 CFR 50.54(f) Activities 2.1 HISTORICAL Each Millstone unit was requested to submit information describing actions taken to ensure that future operations will be conducted in accordance with the terms and conditions of the operating license, the Commission's regulations, and the Final Safety Analysis Report. In a May 21,1996, letter, the NRC requested Northeast Utilities (NU) to provide for each unit its plan for completing the licensing bases reviews.
To aid in NRC understanding of how deficiencies were identified and dispositioned, the NRC's May 21,1996, letter also requested that NU provide for each Millstone unit a comprehensive list of design and configuration deficiencies and information related to how each deficiency was identified and would be dispositioned.
On August 14,1996, the NRC issued a Confirmatory Order establishing an Independent Corrective Action Verification Program (ICAVP). The independent effort will verify the adequacy of NU's efforts to establish adequate design bases and design controls, including translation of the design bases into operating procedures and maintenance and testing practices, verification of system performance, and implementation of modifications since issuance of the initial f acility operating licenses. The NRC oversight of the ICAVP and activities will be in addition to the activities described in this Restart Assessment Plan. The results from this program will be incorporated into this restart plan and considered a significant part of the decision regarding recommended restart.
REVISION 6
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2.2 CURRENT STATUS i
The Unit 2 ICAVP is in progress and NRC ICAVP inspections are ongoing. The i
following inspections concerning configuration management have been performed at Unit 2:
50-336/97 211(ICAVP) performed August 25-29, September 2 5, and j
December 1-5,1997 50 336/98-202,(SSFI) performed March 2-April 3,1998 l
50-336/98 201,(ICAVP) performed April 13 May 8,1998 Future ICAVP inspections will be performed to evaluate the adequacy of the Unit 2 configuration management.
3.0 Insoection Manual Chaoter 0350 Process 3.0.1 HISTORICAL Millstone Unit 1 entered a routine refueling outage on November 3,1995. On December 13,1995, the NRC sent a " Demand for Information Letter" (10 CFR j
50.54(f)) requiring the licensee to certify compliance with the regulatory j
requirements before restarting the unit. At the January 1996 Senior 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.
The NRC inspection Manual Chapter (MC)-0350," Staff Guidelines For Restart j
Approval", provides guidelines and a list of tasks and activities that must be considered before a plant that has been shutdown for cause can restart. Because of NRC concerns relating to the licensee's management effectiveness, the appropriate aspects of MC 0350 will be applied to the restart of Units 1,2, and 3 to ensure applicable requirements have been met.
3.02 CURRENT STATUS The MC 0350 checklist has been completed for Unit 3; is no longer applicable to Unit 1; and is in its early stages for Unit 2 because of current plant status (core still fully off loaded). Most checklist items concerning Unit 2 readiness are still open.
Some responsibilities on the checklist have been changed due to the elimination of the Special Projects Office and the involvement of the Region 1 Regional Administrator. Unit 2 Core reload has been rescheduled several times due to j
emergent work. Closure of many MC 0350 items will depend on plant readiness, and the results of future NRC inspections including completion of ICAVP inspections, the Unit 2 OSTI and the 40500, Corrective Actions, inspection. The REVISION 6 i
5 OSTI and the 40500 inspections for Unit 2 have been tentatively scheduled for the first quarter of 1999. Both Units 2 and 3 remain on the NRC watchlist.
3.1 SPECI AL PROJECTS OFFICE 3.1.1 HISTORICAL The SPO was created on November 3,1996, to oversee the restart of the Millstone units. The plan was to consolidate the NRC resources devoted to the restart efforts under one SES manager. The office is organized into three primary elements, licensing, inspection, and independent corrective action oversight. The Licensing Branch will administer the typical licensing actions performed in NRR; the inspection Branch willimplement 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 RAF 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 Millstone units, and the appointed Division of Reactor Safety representative. The function of the Millstone RAP is described in MC-0350.
3.1.2 CURRENT STATUS in a staff requirements memorandum dated July 15,1998, the Special Projects Office was eliminated. Responsibilities originally residing within SPO were reassigned various groups within NRR and Region 1. Inspection activities, with the exception of ICAVP inspections, have been assigned to Millstone inspection Staff under the Region i Office of the Regional Administrator. The ICAVP Project and Millstone Project Directorate are assigned to the Director of NRR. The three groups will still meet on a regular basis as the Restart Assessment Panel for Unit 2.
3.2 MILLSTONE OPER ATIONAL READINESS PLAN 3.2.1 HISTORICAL On July 2,1996, NU submitted the Unit 3 Operational Readiness Plan, which was discussed at the July 24,1996, meeting and updated at she August 19,1996, meeting. However, the licensee has replaced all of the se-!m managers (President, Vice Presidents, and two of the three unit directors) in the recent past. With these replacements, the submit'ed 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 6
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i The deficiency lists associated with the restart plans for each unit, which will be j
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.
j 3.2.2 CURRENT STATUS The NRC continues to hold meetings with the licensee which are open to the public a-to discuss restart activities. Since Unit 3 has been restarted, current meetings will i
emphasize the status of Unit 2. The NRC also holds periodic meetings directly with the public to obtain comments concerning the Millstone Restart Plan and to answer questions. The frequency of the public meetings has been reduced to quarterly or j
when milestone updates are appropriate.
l 1.
In a letter dated October 21,1997, Unit 2 provided to the NRC a second update to the post restart deferred items list. This list was reviewed by the NRC during an j
inspection performed between October 2 and November 30,1997. The inspection concluded that Unit 2 had improved the review and approval process to provide i-assurance that the list would be complete and accurate. The improved process resulted in the list containing items that were appropriate for deferral and that the contents of the list had reflected a conservative decision making process. No deferred issues were identified, that if not corrected prior to plant restart, would result in a safety significant concern to plant operations. An inspection of the recent update submittals will be performed on or about early December.
i Since the October 21,1997, update of the deferred items list for Unit 2, two updates have been received by the NRC. These updates have not yet been reviewed by the NRC, but will be reviewed prior to any authorization for the Unit 2 restart.
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3.3 CORRECTIVE ACTION PROGRAM 3.3.1 HISTORICAL l
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 failed to embrace all aspects of the underlying problem.
4 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 licent corrective action program.
Because of the large number of Condition Reports (CR) [ Note: CRs were previously called Adverse Condition Reports] being identified by the licensee's staff, the resident and regionalinspection staff will concentrate on issues for each unit identified by the CR process and audit the licensees corrective actions for completeness. The staff is periodically selecting CRs for review, based on the licensee's assigned level of importance, or their risk significance, as perceived by REVISION 6
7 the resident staff. Additionally, other CR's will be examined to provide a spectrum of safety significant and lessor risk issues. These selected CR's will be added to the SIL for each unit, which are Enclosures 1,2, and 3 to this plan. The intent is to primarily assess the corrective action program while dealing with the safety significant technicalissues. Examination of the corrective action program needs to review the Action Requests (AR) from the Action item Tracking and Trending System (AITTS) program, which is an extension of the CR 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 (OSTI) will audit portions of the corrective action process during the course of its activities.
Demonstration of improvements in the process will be judged by the completeness of the licensee's corrective actions for each of the inspected CRs. There must be a high ratio of successfully completed CR's to the total population inspected. There should only be minor comments regarding the processing, evaluation, directed corrective actions and closure of an issue.
l 3.3.2 CURRENT STATUS Th licensee's corrective action processes were significantly reviewed by the Unit 3 40500 and OSTIinspections. Although the emphasis in these inspections was for Unit 3, much of the licensee's corrective action system applies to Millstone Station in general. Based on these and other NRC inspections, SECY 98 090 concluded that the licensee's corrective action program was adequate to support the restart of Unit 3. 40500 and OSTIinspections will be performed for Unit 2 prior to restart to determine the effectiveness of the corrective action program specifically as it applies to Unit 2.
3.4 WORK PLANNING AND CONTROLS (C.4.)'
3.4.1 HISTORICAL Work planning and controls are other areas that the licensee has shown a weakness. The ability to plan, control, and complete work is fundamental to achieving adequate corrective actions. Effective work planning and controls are prerequisites for reducing and managing backlogs. Weak work planning and control
' Reference to applicable MC-0350 section REVISION 6
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8 were evident during the 1995 Unit 2 outage, wherein, tagging boundary violations resulted in an extensive effort by the licensee to correct. Work control and planning l
were also issues at Unit 1, which resulted in a management meeting.
l There will be a complete review of.the Automated Work Order (AWO) process by the.esident or regional staffs. The automated work order process is an integral part of the work planning and control system and is instrumentalin establishing the l
scope of the work, providing the appropriate procedures, and establishing the l
tagging boundaries. The OSTI will assess the engineering and maintenance backlogs during its operational readiness inspection and will determine if there are i
I safety significant issues that must be resolved before restart.
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3.4.2 CURRENT STES l
The work control process at Unit 2 is the subject of ongoing routine inspections.
An OS?! w.il be performed at Unit 2 as the unit nears restart. The OSTI,in part, will perform an in depth review of the Unit 2 work control process.
l 3.5 PROCEDURE UPGRADE PROGRAM (C.3.3.e)
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3.5.1 HISTORICAL l
The quality and adherence to procedures has been a chronic problem at the l
Millstone site. The issue was an element in " Improving Station Performance" and l
was one of the subjects of discussion at the periodic meetings between NU and the NRC. In response to NRC concerns, the licensee developed the Proceduro Upgrade Program (PUP) 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 l
of the document. This will provide an input for assessing the effectiveness of the licensee's PUP. The NRC staff will develop an inspection plan for examining l
selected portions of each unit's individual efforts.
3.5.2 CURRENT STATUS The licensee has essentially completed the PUP for Unit 2. The NRC performed a series of inspections of the PUP starting in August,1996, and ending in August, 1997. These inspections determined that the licensee had met most of it's commitments made to the NRC in a June 4,1992, letter, particularly in standardizing the format of station procedures and reducing the number of higher tiered procedures.
l Programmatic inspections of the PUP apply to all Millstone units. NRC inspections of the technical adequacy of Millstone Unit 2 procedures as a result of the ICAVP REVISION 6
9 process are ongoing. There is a backlog of procedure changes at Unit 2 identified externally to the PUP which are being driven by other processes in place such as the CMP process, procedure performance, biennial reviews, design changes and technical specification changes. Because of problems identified in the adequacy of surveillance tests during 1996 and early 1997, during the past year Unit 2 has performed a 100% review of Section 4 of their Technical specification to determine that all surveillance tests will validate conformance to the TS. This process has been completed and surveillance tests are being revised to correct identified deficiencies This process also reviewed conformance to the Unit 2 Technical Requirements Manusi and to testing required by ASME Code Section XI, Pumps and Valves.
Procedures will be reviewed for adequacy by the ongoing NRC ICAVP inspection Process and routine NRC inspections. The Unit 2 OSTI will provide the final determination as tc the adequacy of Unit 2 procedures for restart.
3.6 OVERSIGHT (C.1.41 3.6.1 HISTORICAL 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 of Indeoendent Oversicht 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.
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 findings, have access to line managemer.t, and provide assessments of process and program effectiveness through periodic reports. There should be evidence that the reports are forwarded to the responsible manager and that they have dealt with the contents appropriately. Oversight should be adequately staffed with qualified and experienced personnel. The audit and surveillance programs need to be clearly defined, proceduralized, and implemented with established schedules.
3.6.2 CURRENT STATUS Both the 40500 and OSTIinspections performed extensive reviews of the current function of the Nuclear Oversight organization. Both inspections determined that Nuclear Oversight is more effective than in the past and was more involved in day REVISION 6
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4 to day plant activities. Significant improvement has been made in this area since
]
serious deficiencies were noted in an assessment performed in 1996 by a Joint i
Utilities Management Assessment. SECY 98-090, stated, in part, "...The NRC staff
~
concludes that oversight is adequate to support the restart of Millstone Unit 3 based 4
on (1) the reorganization and replacement of key mangers within NNECO and I
specifically NOS; (2) the promulgation of improved management expectations; (3) the establishment of open communications between the line and NOS and within NOS; (4) the completion of staffing and improved quality and training of the NOS i
staff; (5) development of a viable inspection and audit program; (6) demonstrated 1
{
improvemerpts in NOS problem identification and assurance that corrective actions are implemented; (7) imr oved performance of quality control inspectors; (8) 4
)
credible performance by the safety committees; and (9) an effective self-1 assessment program." Although the rer ent 40500 and OSTI inspections focused j
on Unit 3, many of the conclusions are applicable to Unit 2.
In addition, the Joint Utilities Management Assessment (JUMA) issued a critical l
report in its 1996 review, which concluded that the Quality Assurance (QA)
{
program had not been effective in resolving identified problems, including those documented in previous QA internal and sxternal assessments. The following and l
most recent JUMA, completing its on site assessment in June 1998, determined that the Nuclear Oversight organization had improved in every area evaluated.
i l
However, the team noted that the transition from unit restart goals to station j
operational excellence required additional efforts to reinforce the gains made since l
1996, particularly in the area of issue ownership, the emphasis on the overall site i
responsibility for quality, and the need for improvement in the response to l
numerous Condition Reports (CRs). These recent JUMA findings resulted in the issuance of four new CRs, covering such broad issues as " expectations, communication, teamwork and trust, and corrective action program implementation", where continued improvements are expected.
Since the startup of Unit 3 in June 1998, the NOS has changed its NORVP j
assessment process to a Nuclear Oversight Verification Plan (NOVP) format, which incorporates a review of common site programs (e.g., security, EP, training) along with separate assessments of Unit 3 operations, Unit 2 restart, and Unit 1 maintenance. Recent NOVP reports have identified the need for improvements for some of the key issues affecting all three units, as well as the common site programs. The full scope of NOS activities, including the NOVP, appears directed toward focusing Millstone Station management attention to the areas impacting Unit 2 restart readiness and the achievement of operational excellence for overall station performance.
Recent routine inspection activities have observed that Nuclear Oversight has been very active in the monitoring of activities being performed at Unit 2. They have provided significant oversight through audits and surveillances of plant activities particularly in the area of readiness for fuelload. There is also a special oversight group which is monitoring the licensees overall readiness for plant restart.
REVISION 6
11 Oversight has been very active in its review and involvement in plant activities. As with Unit 3,40500 and OSTIinspections will be performed at Unit 2 prior to restart.
3.7 ENFORCEMENT 3.7.1 HISTORICAL Outstanding enforcement items will be reviewed by the resident inspectors to determine if any issues require closure before plant restart. The Agency is currently accumulating escalated enforcement items concerning design bases issues which may require licensee response before recommending restart of each unit. There are also potential enforcement items that will result from the efforts of the Office of 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 finalizing the enforcement package. Once enforcement actions have been taken, the NRC will evaluate the licensee's corrective action to those enforcement actions which are determined to impact restart of each unit. Subsequently, a $2.1 million civil penalty was issued to NNECo on December 10,1997, which included violations applicable to all three units.
3.7.2 CURRENT STATUS i
No significant violations for Unit 2 have been identified in 1998 that would have been considered for escalated enforcement action. Twenty one Severity LevelIV violations were identified and issued beginning in January through September 30, 1998. In the December 10,1997, civil penalty, 24 violations were identified against Unit 2. As of October,1998,9 of the 24 civil penalty violations have been
)
closed.
j 3.8 EMPLOYEE CONCERNS 3.8.1 HISTORICAL The Millstone site has had a chronic problem in dealing effectively with employee concerns. These problems have been documented in severallicensee a::sassments, audits, and internal task group studies. The NRC continues to receive an inordinate quantity of allegations from the staff at the Millstone site. The current series of 10 CFR 50.54(f) letters were initiated due to NRC concerns regarding design basis issues at Millstone, as well as an allegation, and a subsequent Millstone 10 CFR REVISION 6
\\
l
c 4
a
[
12 2.206 petition, dealing with the Unit 1 spent fuel pool. The NRC has issued two enforcement actions for harassment and intimidation to NU in the past three years, t
In a 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 the Millstone plants for the past several years. This poor environment resulted in repeated instances of discrimination and ineffective handling of employee concerns.
The NRC initiated two task groups to examine the Northeast Utilities handling of employee concerns, and the recent layoffs that affected several previous allegers.
The task group examined NU's handling of employee concerns and identified a number of root causes for the licensee's problems in this area. The task group also concluded that past problems and their root causes still remain. The output from these two task groups and the licensee's response to the order will be reviewed for restart issues.
On October 24,1996, the director, Office of Nuclear Reactor Regulation (NRR),
issued an Order to Northeast Nuclear Energy Company (NNECO) requiring specific l
actions to resolve problems in the process for handling employee safety concerns at the Millstone station. The Order required NNECO to develop, submit for NRC review, and implement a comprehensive plan for (a) reviewing and dispositioning safety issues raised by its employees, and (b) ensuring that employees who raise safety concerns can do so without fear of retaliation. On January 31,1997, NNECO submitted the plan to the NRC and began implementation of elements of the Plan.
The Order further required NNECO to submit, for NRC approval, a proposed independent, third-party oversight program (ITPOP) organization, to oversee implementation of NNECO's Plan. On December 23,1996, NNECO submitted the proposed third-party organization, Little Harbor Consultants, Inc. (LHC), to the NRC. On April 7,1997, the NRC approved LHC as the third-party organization.
The Order specified that once approved, the third party organization develops and submits for NRC approval an oversight plan for conduct of their t.ctivities. On May 2,1997, LHC submitted the third-party oversight plan to the NRC for approval. On July 15,1997,the NRC reviewed and approved the iTPOP oversight plan. As specified in the Order, independent, third-party oversight will continue to be implemented until NNECO demonstrates, by its performance, that the conditions which led to the requirements of the oversight have been corrected.
The effectiveness of NNECO programs and program implementation associated with fostering and maintaining r, SCWE and for handling employee safety concerns will be assessed by NRC staff relying substantially on the findings of ITPOP's oversight activities. Staff will direct its limited resources to evaluation of a sample of NNECO REVISION 6
i 13 programs and activities and on review of ITPOP oversight activities. This approach will provide the staff with independent assessment of the effectiveness of NNECO programs as well as establishing confidence in ITPOP's findings.
3.8.2 CURRENT STATUS The NRC has made an interim evaluation of Millstone's current program of evaluating employee concerns and maintaining a safety conscious work environment (SCWE). SECY 98 090 documents the final NRC conclusions in this area and applies to all three units. Unless emerging issues arise, this area is closed for all three units. SECY 98-090 states, in part, the following: "... Based on review of documentation, monitoring of NNECO activities, NRC team [ inspection) evaluations, and consideration of LHC findings, the NRC concludes that the NNECO's ECP and SCWE are established and functioning effectively at Millstone.
Employee concerns are prioritized based on safety significance, identities are protected, case resolution is timely and there is ~ appropriate follow up on corrective action adequacy.' Further, significant improvements have been made in the training provided the employees and contractors regarding SCWE and ECP...The staff also considers that NNECO has developed adequate plans, following restart of a unit, for monitoring the sites safety environment...The staff notes that in accordance with the October 24,1996, Order, the independent third party oversight organization will continue at Millstone until the licensee demonstrates by its performance that the l
conditions, which led to the requirement of the oversight, have been corrected to the satisfaction of the NRC..."
i l
The NRC has performed an evaluation, 50-245/98 215,for ECP and SWCE during August 1998. Another evaluaton was completed during October 1998. The results of this evaluation are under NRC management review to determine if the " Order Requiring Third Party Order Oversight of Northeast Nuclear Energy Company's implementation of the Millstone Station Employee's Safety Concerns issues" dated October 24,1996, can be lifted.
3.9 SIGNIFICANT ITEMS LIST 3.9.1 HISTORICAL The technique to be used for the restart will be to reach agreement with the i
licensee on its restart issues list, have it impose controls on adding or def6rring l
items from the list, have the resident inspectors review the list to ensure it includes issues of interest to the NRC, and have the residents review the deferred list to ensure appropriate rationales for deferral have been documented (see item B.4.3. of MC 0350). As a result of the 10 CFR 50.54(f) activities, the licensee initially determined that, for all three Millstone units, hundreds of items did not meet criteria for inclusion as a restart item. The resident inspectors, augmented by headquarters staff, are reviewing these lists periodically and confirming that the licensee is performing an adequate assessment of the discrepancies. This process will be used l
REVISION 6 l
l
i i
14 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 items Lists for all Millstone units (Enclosures 1,2 and
- 3) contain some of the items that are being used to audit and evaluate licensee programs (e.g., the corrective action process) and significant safety / regulatory technical issues.
Restart issues on the NRC's Significant items List will meet at least one of the following criteria:
1.
Resolution of the issue is required to ensure safe or tration of the facility to -
include satisfaction of the technical specifications t.,r licensing basis.
l 2.
Inspection of the issue will provide an insight to an identified programmatic deficiency such as the corrective action system.
3.
Inspection of the issue will provide assessment of management effectiveness or personnel performance.
l 3.9.2 CURRENT STATUS Because of licensee attention to the restart of Unit 3, only limited licensee and NRC resources were applied to Unit 2. Major emphasis was placed on the Configuration Management Program process but lesser emphasis was placed on Unit 2 plant readiness. The Unit 2 SIL consists of 54 items which incorporate 75 separate issue l
closure packages and 8 issues which require no closure packages. The most recent SIL update is enclosed as Attachment (1) to the RAP.
3.10 POWER ASCENSION INSPECTION 3.10.1 HISTORICAL Selected portions of NRC MC 93802," Operational Safety Team inspection," will provide the framework for a team inspection of each unit during the restart process.
The procedure scope will be modified to address the pertinent issues at Millstone.
The inspection will cover self assessments by the licensee, the licensee's implementation of its startup plan, control room observations during the approach to 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 design bases.
l.
REVISION 6
15 3.10.2 CURRENT STATUS Unit 2 has not reloaded fuel. Heat up and restart has not yet been scheduled by the licensee. The NRC has not yet drafted an inspection plan for Unit 2, but the inspection plan will be similar to the inspection used for the startup of Unit 3. In addition, the OSTI will be used evaluate Unit 2 readiness for restart.
3.11 PLANT PERFORMANCE REVIEW The Restart Assessment Panel performs Plant Performances Reviews (PPRs) semi-annually. Two reviews were conducted, on March 19 and November 18,1997.
These PPRs were used to identify issues that need to be inspected at Millstone Station based on licensee performance. These reviews identified severC issues that warrant NRC inspection before plant restart of Unit 3. Unit specific issues as well as station wide issues identified by the March 19,1997, PPR, are contained in the SIL for each Unit as inspection items.
PPRs for Millstone were suspended for all units starting in October,1997. The reason was the continuous NRC management oversight by the Special Projects Office. The PPR remains suspended for Unit 2 until after restart. Although the SPO has been eliminated, special oversight is still in place as required by the July 27, 1998, SRM. The joint NRR and Region l Millstone oversight group still meets frequently as the Restart Assessment Panel (RAP). The RAP management will continue to frequently brief NRC senior management and the Commission on Millstone Unit 2 status obviating the need for a redundant PPR.
3.12 LICENSING ISSUES Millstone Unit 2 has periodically submitted 1. censing issues (amendments, unresolved safety questions, relief requests, etc.) which will impact the restart process. The status of NRR actions concerning each issue is documented in l
Enclosure (3) of this plan. Licensing actions required for Unit 2 must be resolved pnor to the restart to Unit 2.
Enclosures:
(1)
Significant items List Millstone Unit 2 l-(2)
MC-0350 - Restart Approval Checklist - Millstone Unit 2 (3)
Licensing issues Required for Restart of Millstone Unit 2 l
l t
REVISION 6
l 4
i 1
MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (1)
+
Millstone Unit 2 Sianificant items List The following is a list of the Millstone issues that, as a minimum, require an NRC
{
inspection and evaluation prior to restart.
i REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 1
MC 0350 SECTIOil C.1.3, MANAGEMENT OVERSIGHT AND EFFECTIVENESS;
- INSP, I
C.2.1, C.2.2.a,d,e, LICENSEE STAFF SAFETY CULTURE
- 40500, C.3.1,a,b,c,d OSTI l
e 2
MC 0350 SECTION C.1.1, 50.54(f)/ICAVP (PHASE I and ll)
- ICAVP, UPDATED 4
C.1.3, C.1.4.g, C.3.2, C.4.f; FSAR UPDATES
- INSP, IR 98-201 i
CONFIRMATORY ORDER 10 CFR 50.59 PROCESS PROJ IR 98-202 DATED 08/14/96 CONFIGURATION MANAGEMENT / DESIGN CONTROL IR 98 208 PROCESS (PART OF ICAVP PHASE 1) i i
4 3
MC 0350 SECTION C.1.1 AND DESIGN CONTROL PROCEES CHANGES TO ADDRFSS ICAVP UPDATED i
C.1.3: C.2.2.d; UNIT 1 ACR 7007 IR 98 201
+
UNIT 1 ACR 7007; IR 98-202 UNIT 2 ACR 8761 NUMEROUS EXAMPLES OF DRAWINGS NOT IR 98-208 4
]
REFLECTING ACTUAL PLANT CONFIGURATION l
4 MC 0350 lTEM C.1.4.e, LICENSEE HANDLING OF CONCERNS RAISED BY PROJ UPDATED 4
C.2.2.b,e; EMPLOYEES IR 98-210 l-CONFIRMATORY ORDER e EMPLOYF.E CONCERNS PROGRAM IMPROVEMENTS DATID OCTOBER 24,1996
- SCWE IMPROVEMENTS
]
l 5
MC 0350 SECTION C.1.1, CORRECTIVE ACTION PROGRAM EFFECTIVENESS
- INSP, C.1.3, C.1.4.d-1, C.2.1, 40500 C.2.2.c.e, C.3.1.d,m; C.4.f; SELF-ASSESSMENT PROGRAM IMPLEMENTATION AND i
IR 336/96-04 & 08 EFFECTIVENESS; j
eel 336/96-20130 COMMITMENT TRACKING 6
MC 0350 lTEMS C.2.2.d, WORK PLANNING AND CONTROL:
- INSP, UPDATED C.4.e.f,h,1,)
OSTI 1R 97 207 i
PLANT MAINTENANCE PROGRAM EFFECTIVENESS; i
SIGNIFICANT HARDWARE ISSUES RESOLVED:
MAINTENANCE BACKLOG MANAGED AND IMPACT ON OPERATION ASSESSED; SURVEILLANCE TESTING:
- ^
PLANT HOUSEKEEPING
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REVISION 6 November 18,1998
]
4, i
.m..____
___.._.__.....y.._..___
,_.7_.~_..____
)
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REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 7
MC 0350 lTEMS C.1.3.f, BYPASS JUMPERS, OPERATOR WORK-AROUNDS &
- INSP, C.2.1.e, C.3.2.e, C.4.f,i; CONTROL BOARD DEFICIENCIES OSTI 8
MC 0350 lTEMS C.2.1.b, PROCEDURE ADEQUACY / PROCEDURE UPGRADE
- INSP, UPDATED C.2.2.d C.3.1.k, C.3.3.e.f; PROGRAM
- OSTI, IR 97-202 ICAVP 1R 97 203 tFl 336/95 201-03; PROCEDURE CLASSIFICATION GENERAL USE VERSUS 1R 97-207 CONTINUOUS USE IR 98 207 IR 98 212 URI 336/96-0104; LOSS OF DC BUS EVENT ESTABLISH PROCEDURES REQUIRED BY TECHNICAL SPECIFICATION 6.8.1 URI 336/96-06-08 SHUTDOWN COOLING SYSTEM WATER HAMMER; NU LETTER B16257 REVIEW OPERATING PROCEDURES TO PRECLUDE WATER HAMMER EVENTS eel 336/97-02-12 SURVEILLANCE PROCEDURE ADEQUACY 9
MC 0350 ITEMS C.1.4.g, OPERATING PROCEDURES CONSISTENT WITH FSAR
- INSP, UPDATED C.2.2.g, C.3.3.e.f; DESCRIPTION OF SYSTEM OPERATION ICAVP IR 97 02 eel 336/96-08-13, IR 98 201 eel 336/96-06-05, ADEQUACY OF PROCEDURE CHANGE PROCESS TO IR 98 202 eel 336/96-08-06, ENSURE OPERATION IN ACCORDANCE WITH LICENSE IR 98 206 LER 336/97 02; IR 98 207 ACR 11104 IR 98 208 10 MC 0350 lTEMS C.2.1.g, PROGRESS OF EMERGENCY OPERATING PROCEDURE DRS(OU UPDATED C.3.3.e,f; UPGRADES; IR 97-203 1R 336/95 21 ACCEPTABILITY OF DEFERRING ABNORMAL OPERATING PROCEDURE UPGRADES 11 MC C350 lTEMS C.1.4.a,b,c, QUALIT" ASSURANCE AND OVERSIGHT PROGRAM
- INSP, C.2.1.c 40500 12 MC 0350 SECTIOP, C.1.1 LICENSEE RESTART PUNCH LIST REVIEW OF ITEMS INSP UPDATED C.1.3, C.1.4.e, L 2.1.f-g, DEFERRED UNTIL AFTER RESTART IR 97 207 C.4.1,1 13 MC 0350 ITEMS C.3.1.g.h,1,j,1, UCENSED OPERATOR STAFFING: CONTROL ROOM
- INSP, C.3.3.a,b,d,g FORMALITY; ATTENTIVENESS TO DUTY; ATTENTION OSTI TO DETAIL: OFF-MDUR PLANT STAFFING: OVERTIME USAGE: AWARENESS TO PLANT SECURITY; AWARENESS OF EQUIPMENf STATUS; LOG KEEPING PRACTICES:
REVISION 6 November 18,1998 2
4
REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 14 MC 0350 lTEMS C.3.1.e, OPERATOR LICENSING AND TRAINING DRSIOL)
C.3.3.c; CONFlRMATORY ACTION LETTER DATED MARCH 7, 1997; URI 336/97 01-03 15 MC 0350 ITEMS AUGMENTED INSPECTION COVERAGE DURING
- INSP, C.4.a,b,c,d,e,g RESTART lNSPECTION: 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 lTEMS C.2.2.g-h, EMERGENCY PREPAREDNESS PROGRAM (INCLUDING DRS(EP)
CLOSED l
C.3.1.m. C.3.2.h; ORGANIZATION / STAFFING / DOSE ASSESSMENT IR 96-06 l
NU LETTER (B16195) DATED CAPABILITY) lR 97 202 FEBRUARY 10,1997 IR 98-208 17 MC 0350 SECTION C.5 AND DISPOSITION OF REGULATORY ISSUES: LICENSE
- NRR, C.6 AMENDMENTS; EXEMPTIONS; RELIEFS; ORDERS:
- PROJ, SIGNIFICANT ENFORCEMENT ISSUES: ALLEGATIONS:
OE, 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)
INSP UPDATED eel 336/96 20142& 43 PROGRAM IR 97 202 l
lR 97-203 IR 97 208 IR 98 207 IR 98-212 19 ACRs M2 96-0515 & 07958; EQUIPMENT ENVIRONMENTAL QUALIFICATION (EEO)
ICAVP UPDATED eel 336/96-0612, PROGRAM DRS(EE8) lR 97 203 eel 336/96 20120, INSP IR 98 212 URI 336/9319-02 HIGH ENERGY LINE BREAK PROGRAM j
LER 336/97 31 l
i i
REVISION 6 November 18,1998 4
3 l
i
REFERENCE MILI. STONE UNIT 2 INSPECTION ITEM RESP STATUS 3
i 20 IFl 336/95-01-01 MOTOR OPERATED VALVES (GENERIC LETTER 8910)
DRS(SEB,- UPDATED IR 97 203 eel 336/96-05-11 INACCURATE INFORMATION PROVIDED TO THE NRC REGARDING GENERIC LETTER 8910; 4
eel 336/96-05-09 DYNAMIC TESTING OF AFW TERRY TUR8INE STEAM ADMISSION MOV; eel 336/95-08-01,03 & 04 PRESSURE LOCKING OF CONTAINMENT SUMP LER 336/97 34 RECIRCULATION VALVES i
21 MC 0350lTEM C.3.3.e;
' FIRE PROTECTION / APPENDIX R PROGRAMS DRS(EEB)
IR 336/96-08; LICENSEE SELF-ASSESSMENTS APPENDIX R RELATED ABNORMAL OPERATING AND QA AUDITS; PROCEDURES:
ACR M2 96-0460 APPENDIX R COMPLIANCE ASSOCIATED WITH THERMO-LAG 22 ACRs M2-96-0513; CONT /,1NMENT SUMP SCREEN MESH SIZE & ECCS DRS(SEB)
CLOSED eel 336/96-0611 PUMP THROTTLE VALVE CLOGGING IR 97 203 URI 336/96-06-10 IR 98 207 23 ACRs 01991, M2-96-0449, HYDROGEN MONITORS AND POST ACCIDENT INSP 0467,0654,0655,& 0656; SAMPLING SYSTEM (PASS) INOPERABLE AND FAILURE eel 3F</.3-0811,12 & 13, TO MEET DESIGN BASIS AND LICENSING BASIS eel '.0M. 201-03 & 41, URI 336/96-01-05 CORRECTIVE ACTIONS TO DEVELOP A DRS(EP)
URI 336/90-18-05 REPRESENTATIVE TOTAL GAS SAMPLE USING PASS 24 ACRs 08174,04047,06372 &
EXCESSIVE REACTOR COOLANT SYSTEM HEATUP AND INSP 09739; COOLDOWN RATES: EVALUATION OF SIMULTANEOUS URI 336/9 5-42-03 REACTOR COOLANT PUMP AND SHUTDOWN COOLING SYSTEM OPERATION 25 NUMEROUS ACRs; ECCS PUMPS SUCTION LINE FROM RWST MAS INSP UPDATED URI 336/96 06-08 NUMEROUS DEGRADED OR INOPERABLE PIPE IR 97-203 SUPPORTS, MANY CAUSED BY WATER HAMMER 26 ACR 11252; "B" EMERGENCY DIESEL GENERATOR FAILURE -
INSP CLOSED eel 336/96-0910 INADEQUATE CORRECTIVE ACTIONS IR 97-02 1R 97 203 1R 93-207 REVISION 6 November 18,1998 4
k REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 27 eel 336/96-201-09 IttADEQUATE DESIGN CONTROL MEASURES FOR ICAVP VERIFYING ACCURACY OF INFORMATION CONTAINED IN DESIGN BASIS DOCUMENT PACKAGES 28 eel 336/t 6 201 11, FAILURE TO ADEQUATELY CONTROL INSTALLATION INSP CLOSED eel 336/96-20131 OF TEMPORARY MODIFICATION TO THE R8CCW IR 97 203 SURGE TANK IR 98-212 29 eel 336/96-201 12 SEPARATION AND SINGLE FAILURE CONCERNS FOR INSP CLOSED WIDE RANGE NUCLEAR INSTRUMENTS IR 97 203 IR 98 207 30 eel 336/96 20125 FAILURE TO IMPLEMENT CORRECTIVE ACTIONS INSP UPDATED CONCERNING " DUAL-FUNCTION" ISOLATION VALVES IR 97 202 31 eel 336/96-20128 FAILURE TO ADDRESS STATION BLACKOUT ISSUES INSP UPDATED IDENTIFIED IN THE VECTRA ASSESSMENT IR 97-203 32 eel 336/96-20129 FAILURE TO IMPLEMENT CORRECTIVE ACTIONS FOR INSP CLOSED AUDIT ISSUES INVOLVING TRENDING AND 1R 97-02 PRIORITIZATION OF NON-CONFORMANCE REPORTS IR 97 207 IR 98-207 33 eel 336/96 201-36 INADEQUATE CORRECTIVE ACTION CONCERNING A DRS CLOSED SEISMIC DESIGN DEFICIENCY OF A VITAL (CMME) 1R 97 202 SWITCHGEAR ROOM COOLER 1R 97-203 IR 98 207 34 y11336/96 08 06 IMPLEMENTATION OF CORRECTIVE ACTION OF INSP CLOSED CHANGING OPERATING PROCEDURE TO LOCK OPEN 1R 97 02 REFUELING POOL DRAIN VALVES, AS SPECIFIED IN THE 1R 97 203 FSAR, 'WAS INADEQUATE 1R 98 207 35 eel 336/96 08 08 INADEQUATE CORRECTIVE ACTION IN LER 336/96 24 INSP CLOSED 1R 97-203 IR 98 207 36 F.El 336/96-08-10 INADEQUATE CORRECTIVE ACTIONS TO ADDRESS IN W CLOSED UNIT 1 HEAVY LOADS LIFTED OVER THE UNIT 2 VITAL 1R 97-02 SWITCHGEAR ROOM 1R 97-203 IR 98 207 REVISION 6 November 18,1998 5
i REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 37 eel 336/95-44-05 ICE BLOCKAGE OF SERVICE WATER STRAINER INSP BACKWASH LINE 38 URI 336/96-0511(IFS NO. URI SPENT FUEL POOL FSAR UPDATES INSP CLOSED 336/96-05 17) lR 97-02 l
39 eel 336/96-04-10 ERRONEOUS RBCCW FLOW VALUES IN CONTAINMENT INSP i
TEMPERATURE PROFILE ANALYSIS l-l 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 INSP CLOSED TO RESTRICTIVE MAIN STEAM SAFETY PIPING IR 98-212 i
41 ACR M2 97-0023 SEIMANS COMPUTER MODEL OF REACTOR CORE NRR CLOSED I
FOLLOWING LARGE AND SMALL BREAK LOSS OF NRC LETTER l
COOLANT ACCIDENTS DATED 07/23/97 42 IR 336/94-201(IFS NO. IFl EMERGENCY DIESEL GENERATOR FUEL DAY TANK
- PROJ, UPDATED 336/94-201-90)
DOES NOT SATISFY 7-DAY DESIGN BASIS CAPACITY INSP IR 98-207 43 URI 336/96 0814 INAPPROPRIATE REMOVAL OF STARTUP RATE TRIP INSP CLOSED LER 336/96 29 IR 96-08 IR 97 207 l
44 ACR 02797, ACR 09563, POTENTIAL TO EXCEED CONTAINMENT DESIGN INSP 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 INSP CLOSED l
A MAIN STEAM LINE BREAK IMSLB) COULD CAUSE IR 97-202 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 EVALUATED AS ACCEPTABLE.
46 LER 336/97-02 CONTROL ROOM AIR CONDITIONING COMMON INLET INSP DAMPER COULD BECOME STUCK CLOSED, DISABLING BOTH FACILITIES. DAMPER HAS NO MANUAL OPERATOR AS STATED IN FSAR.
i REVISION 6 November 18,1998 6
. -... ~.. _.-._.
' REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 47 URI 336/96-08-09, REACTOR PROTECTION SYSTEM AND ENGINEERED INSP LER 336/96 24 SAFETY FEATURE RESPONSE TIME TESTING i
1 48 ACR M2 96-0542 TECHNICAL SPECIFICATION LIMITS FOR INOPERABLE INSP CLOSED MAIN STEAM SAFETY VALVES NON-CONSERVATIVE IR 98-212 49 LER 336/96 30.LER 336/97-05 INSERVICE INSPECTION / INSERVICE TESTING DRS UPDATED CR M2-97-0491 & 1229 PROGRAMS (CMME)
IR 96-06 IR 96-08 50 CONTROL /USE OF VENDOR INFORMATION INSP UPDATED IR 97 203 IR 98 208 51 IR 336/95-29 SERVICE WATER SYSTEM OPERATIONAL DRS(SEB)
PERFORMANCE INSPECTION (SWSOPI) FOLLOWUP 52 LER 336/97-33 ENGINEERED SAFEGUARDS ACTUATION SYSTEM INSP INOPERABLE DUE TO IMPROPERLY SIZED POWER SUPPLY FUSES 53 LER 336/98-02 THE EMERGENCY CORE COOLING SYSTEM (ECCS)
INSP DESIGN DID NOT ADEQUATELY ADDRESS A LOSS OF COOLANT ACCIDENT (LOCA) COINCIDENT WITH THE LOSS OF EITHER DIRECT CURRENT (DC) BUS OR ALTERNATING CURRENT (AC) BUS.
54 LER 336/98-09 LARGE BREAK LOSS OF COOLANT ANALYSIS PROJ INDICATES PEAK CLAD TEMPERATURE COULD EXCEED 2200 DEGREES F.
REVISION 6 November 18,1998 7
l i
MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURE (2)
MILLSTONE UNIT 2 MC 0350 RESTART APPROVAL CHECKLIST l
The following items are considered applicable to the restart of Millstone Units 2:
RESPONS!BILITIES AND AUTHORITIES l
lNEED l STATUS l RESP 4.01 Reaional Administrator Reaion 1. Notifies the Executive X
C RA Director for Operations (EDO) and the Commission, as appropriate, of the NRC actions taken concerning shutdown plants and the proposed followup plan.
l 4.02 Reaional Administrator. Reaion 1.
l X
C RA a.
Discusses with the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, the Office of Enforcement (OE), and NRR, !
l as appropriate, the need for an order or confirmatory action letter (CAL) specifying the actions required of the licensee to receive NRC l
i approval to restart the plant and the proposed followup plan.
I
- b.
Decides, in consultation with the NRR Associate X
C RA l
Director for Projects, whether this manual chapter applies to a specific reactor restart.
c.
In coordination with the NRR Associate Director for X
C RA Projects, decides whether to establish a Restart l
Panel.
i
' d.
Develops a written Restart Assessment Plan, iX C
l RAP including a case specific checklist, to assign I
l responsibilities and schedules for restart actions and I l
I interactions with the licensee and outside i
organizations.
l i
REVISION 6 November 18,1998 l
..-.--=_-
l l
4 l
NEED STATUS RESP 4
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 l
agencies.
l f.
In conjunction with NRR, reviews and determines X
RAP SRI the acceptability of licensee's action program.
OSTI I
NRR(U g.
Approves restart of the shutdown plant, following X
RA consultation with the EDO and the Director of NRR, and approval / vote by the Commission.
4.03.
Regional Administrator, Region 1
}
[ a.
Acts as the focal point for discussions within NRR X
. to establish the appropriate followup actions for a i
l plant that has been shut down.
l l
l 4.04 Director, Licensing I
l i
NRR(U a.
Coordinates participation in followup conference
>X I
i calls and management discussions to ensure that l
l the Regional Administrator is directly involved, i
when appropriate, in followup action.
I l
b.
Coordinates and implements actions prescribed in X
i
,NRR I
the Restart Assessment Plan that have been 4
determined to be Licensing's responsibility. These I
include, where applicable, appropriate NRC Office or,
l NRR Division interaction with other Federal agencies j t
(e.g., Federal Emergency Management Agency (FEMA), Department of Justice (DOJ)) pursuant to any applicable Memoranda of Understanding.
l 1
i REVISION 6 November 18,1998 2
4 s
l lNEED 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 safsty 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 i
should have been completed or should be incorporated into i
the CSC as appropriate. Refer to Section 5.02 of this
, manual chapter for additional information.
a.
Initial notification and NRC management discussion NA of known facts and issues I
!b.
Identify / implement additionalinspections (i.e. AIT, fNA ilT, or Special) (Eegion).
i l
c.
Determine need for formal regulatory response (i.e.
! NA l
order or CAL).
l
. d.
Identify other parties involved (i.e., NRC NA l
l Organizations, other Federal agencies, industry
{
I organizations).
REVISION 6 November 18,1998 3
~. _. _.. _ _
d i
I NEED ; STATUS
'l RESP B.2
' NOTIFICATIONS NA Initial notification of the event quickly communicates NRC's understanding of the event and its immediate I response to the parties having an interest in the event.
Notification to regional and headquarters offices of j
cognizant Federal agencies may be appropriate. As the l
review process continues, additional and continuing notifications may be required.
4 a.
Issue Daily and Directors Highlight (NRR).
NA l
i
! b.
Issue preliminary notification (Region),
j NA j c.
Conduct Commissioner assistants' briefing.
NA l
g I
h
, d.
Issue Commission paper (NRR).
! NA l e.
Cognizant Federal agencies notified (i.e., FEMA,
- NA l
f.
State and local officials notified (Region).
fNA f i
g.
Congressional notification (NRR)
NA l
B.3 ESTABLISH AND ORG ANIZE THE NRC REVIEW I
l l
I PROCESS
^
a.
Establish the Restart Panel.
X C
i b.
Assess available information (i.e. inspection results, X
i C
l RAP licensee self assessments, industry reviews).
c.
Obtain input from involved parties both within NRC X
l RAP l
and other Federal agencies such as FEMA, EPA, RA i
DOJ.
i d.
Conduct RA briefing.
X C
lRAP
! ' e.
Conduct NRR Executive Team briefing (NRR).
i X
C l RAP l
f.
If required, develop the case-specific checklist X
C l RAP (CsC).
I l
i Develop the Restart Assessment Plan.
IX l
C RAP g.
REVISION 6 November 18,1998 4
i 1
1 I NEED STATUS RESP h.
Director, inspections approves Restart X
C
! R1
)
l Assessment Plan.
l.
NRR Director approves Restart Assessment Plan.
X C
DNRR J.
Implement Restart Assessment Plan.
X
, RAP k.
Modify order as necessary X
NRR l
l B.4 l REVIEW IMPLEMENTATION l
l l
B.4.1 Root Causes and Corrective Actions OSTI l
a.
Evaluate findings of the special team inspection.
X "A"
b.
Licensee performs root cause analysis and develops X
l
' NU l
corrective action plan for root causes.
j oST I
c.
NRC evaluates licensee's root cause determination i
X
! RAP
! OS7' l
and corrective action plan.
{
g5 o i
t t
l l
1
)
l l
l 2
REVISION 6 November 18,1998 5
i
-. - ~, - - _ ~ -. -. - -
t l STATUS l NEED RESP i
B.4.2, B.4.2 Assessment of Eauioment Damaos NA i
For events where equipment damage occurs, a thorough t
assessment of the extent of damage is necessary. A root cause determination will be necessary if the damage was l
the result of an internal event. The need for independent i
NRC assessment should be considered. The licensee will
)}
need to determine corrective actions to repair, test, inspect, and/or analyze affected systems and equipment.
These actions are required to restore or verify that the equipment will perform to design requirements. Equipment i
modifications may also be required to ensure performance
[
to design requirements.
l 1 Potential offsite emergency response impact for external l
events such as natural disasters, explosions, or riots 4
should be considered. NRR should obtain information from !
{ FEMA headquarters reaffirming the adequacy of State and l
l i local offsite emergency plans and preparedness if an event j
raises reasonable doubts about emergency response l
~
, capability.
i I
j i
I a.
Licensee assesses damage to systems and NA i
components.
i
- b.
NRC evaluates licensee damage assessment.
NA Lic'ensee determines corrective actions.
, NA
! c.
l d.
NRC evaluates corrective actions.
NA B.4.3 ; Determine Restart Issues and Resolution X
j iRAP The establishment of the restart issues that require j
. resolution before restart demands a clear understanding of l 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.
I 1
REVISION 6 November 18,1998 6
s
l l
l NEED
! STATUS l RESP l
a.
Review / evaluate licensee generated restart issues.
X RAP b.
Independent NRC identification of restart issues X
C RAP c.
NRC/ licensee agreement on restart issues.
X C
RAP l
d.
Evaluate licensee's restart issues implementation X
C RAP
- process, e.
Evaluate licensee's implementation verification X
4o500 i
j OSTI
\\
4 B.4.4 Obtain Comments Since some shutdowns involve a broad number of issues, solicitation of comments from diverse sources may be l
l appropriate. The decision to solicit comments from a
. group and the level of participation should be made on a l
t l
' case-by case basis. Input from these groups should be factored into the restart process when they contribute l positively to the review. Note: If needed, comments 1
l concerning the adequacy of state and local emergency l
1
! planning and preparedness must be obtained from FEMA i
headquarters through NRR.
l l
a.
Obtain public comments.
lX I
C i RAP b.
Obtain comments from State and Local Officials X
l C
i Regional (Region).
c.
Obtain comments from applicable Federal agencies.
X C
l RAP l
t l
l l
REVISION 6 November 18,1998 7
4 NEED STATUS RESP t
B.4.5 Closecut Actions When the actions to resolve the restart issues and l significant concerns are substantially complete, closeout i
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 reviews and preparations for restart.
RAP osn a.
Evaluate licensee's restart readiness self assessment.
X b.
NRC evaluation of applicable items from Section C l
X RAP "lSSUES" complete.
! c.
Restart issues closed.
X l
! RAP i
i
' SRI l
l OSTI d.
Conduct NRC restart readiness team inspection.
X I
osTi I
l e.
Issue augmented restart coverage inspection plan.
X i
osTi l
RAP l
i
, RAP X
.f.
Comments from other parties considered.
i i
I
~
t
, g.
Determine that all conditions of the Order / CAL are X
, RAP iICAVP L
satisfied, h.
Re-review of Generic Restart Checklist complete.
X RAP SRlNU B.5
' RESTART AUTHORIZATION (B.5) i l
j When the restart review process has reached the point I
that the issues have been identified, corrected, and
! reviewed, a restart authorization process is begun. At this i j point the Restart Panel should think broadly and ask: "Are l j
l all actions substantially complete? Have we overlooked l
l i any items?"
a.
Prepare restart recommendation document and basis t
for restart.
X RAP q
REVISION 6 November 18,1998 8
1
. ~. -
jNEED ' STATUS RESP b.
NRC Restart Panel recommends restart X
, RAP c.
No restart objections from other applicable HQ X
NRR (L) offices.
d.
No restart objections from applicable Federal X
}
agencies.
e.
.RA concurs in restart recommendation X
RA f.
HRR Director concurs in restart recommendation.
X NRR (L) g.
EDO concurs in restart recommendation when NA re quired.
h.
Ct>nduct ACRS briefing when requested (NRR).
NA 1.
Conduct Commission briefing when requested.
X I DSPO j.
Commission approves restart.
l X
l cOMu lk.
EDO authorizes restart.
X
'EDO B.6 RESTART AUTHORIZATION NOTIFICATION (B.6)
Notify the applicable parties of the restart authorization.
Notifications should generally be made using a l memorandum or other format consistent with the level of I
{
j formality required. Communication of planned actions is
, important at this stage to ensure that NRC intentions are
]
i clearly understood, l
i I
i a.
Commission (if the Commission did not concur in the Restart Authorization or as requested) (NRR).
i l
3 NA i l
b.
EDO (if the EDO did not concur in the restart NA recommendation or as requested) (NRR).
l c.
Congressional Affairs (RAP).
X OCA d.
ACRS (a briefing may be substituted for the written notification if the ACRS requests a briefing) (NRR).
i
' e.
Applicable Federal agencies.
!X
' RAP i f.
Public Affairs.
X l OPA l g.
State and local officials.
IX l
l SLO REVISION 6 November 18,1998 l
8 l
4 NEED STATUS I RESP h.
Citizens or groups that expressed interest during the X
RAP restart approval process.
l RAP
!l.
Issue staff concerns memorandum.
X l
C.1.1 Root Cause Assessment
' a.
Conditions requiring the shutdown are clearly X
C RAP understood, b.
Root causes of the conditions requiring the j
X C
RAP shutdow'n are clearly understood, i
l c.
Root causes of other significant problems are clearly X
C RAP i
understood.
I l d.
Effectiveness of the root cause analysis program.
X 40500 t
MP l
oSTI r
C.1.2 ! Damace Assessment I
l a.
Damage assessment was thorough and l NA !
i comprehensive.
I.
Corrective actions clearly restored systems and lNA l
b equipment or verified they can perform as designed. '
e i
C.1.3 Corrective Actions I
' RAP a.
Thoroughness of the corrective action plan
' 40500 b.
Completeness of corrective action programs for X
l
! SRI specific root causes.
l40500 l
l i SRI c.
Control of corrective ac' tion item tracking.
X cSTI 40500
, d.
Effective corrective actions for the conditions X
l SRI requiring the shutdown have been implemented.
l l
oST e.
Effective corrective actions for other significant
!X l
SRI oSTI problems have been implemented.
l lCAVP 40500 REVISION 6 November 18,1998 10 l
l
l l
7 NEED l STATUS RESP f.
Control of long-term corrective actions.
X SRI (Backlog Management Plan) oSTi 40500 g.
Effectiveness of the corrective action verification X
SRI process.
OSTI l
40500 l
C.1.4 Self-Assessment Canability The occurrence of an event may be indicative of potential weaknesses in the licensee's self assessment capability, j
l A strong self-assessment capability creates an
- environment where problems are readily identified, l prioritized, and tracked. Effective corrective actions
! require prob'em root cause identification, solutions to j correct the cause, and verification methods that ensure the l
I issue is resolved. Senior licensee management l
' effectiveness in ensuring effective self assessment is l
, treated separately.
i i,
a.
Effectiveness of Quality Assurance Program.
i l
l X
- RAP 1
l l40500 b.
Effectiveness of industry Experience Review lX l
! oSTI l
Program.
40500 l
! c.
Effectiveness of licensee's independent Review X
l SRI Groups.
l
- ,oSTi g, 9 i
! d.
Effectiveness of deficiency reporting system.
X l
l SRI l
oSTI I
I40500 l NRR (L)
< e.
Staff willingness to raise concerns.
X lRAP f.
Effectiveness of PRA usage.
X
' oSTI l40500 g.
Effectiveness of commitment tracking program.
X
40500 h.
Review applicable external audits X
oST 40500 l1.
Quality of 10 CFR 50.72 and 50.73 reports.
l X
SRI REVISION 6 November 18,1998 11 1
1E
, NEED ; STATUS l RESP l
l C.2.1 Manaaement Overslaht 'and Effect; D111 a.
Goals / expectations communicated to the staff.
X OSTI 40500 I-X SRI b.
Demonstrated expectation of adherence to oSTI procedures.
RAP lX c.
Management involvement in self-assessment and 40500 independent self assessment capability d.
Effectiveness'of management review committees.
!X SRI OSTI i
l 40600 I
e.
Management's demonstrated awareness of j
X SRI OSTI day to-day operational concerns.
] f.
Management's ability to identify and prioritize j
X SRI oSTI significant issues.
40500 1
X
- SRI g.
Management's ability to coordinate resolution of
- oSTI i
significant issues.
40500 h.
Management's ability to implement effective X
SRI oST corrective actions.
[
C.2.2. j Manaaement Suonort j
i a.
- impact of any management reorganization.
X RAP i
40500
' b.
Effective and timely resolution of employee X
SCWE c.
Adequate engineering support as demonstrated by X
DRS OSTi i
timely resolution of issues.
p SRI d.
Adequate plant administrative procedures.
i X
j i!40500 i
i
!OSTI e.
Effective information exchange with other utilities.
l X
l SRI
!OSTI I40500 f.
Participation in industry groups.
!NA Effectiveness of Emergency Response Organization.
'I X
DRS g.
REVISION 6 November 18,1998 12
l NEED i STATUS !
RESP 3
h.
Coordination with offsite emergency planning l
X DRS officials.
l l
C.3.1 Assessment of Staff RAP a.
Demonstrated commitment to achieving improved X
SRI performance, osTI b.
Demonstrated safety consciousness.
Understanding of management's expectations and X
osTI goals.
40500 Understanding of plant issues and corrective I
d X
osTi actions.
SRI I
40500 e.
Qualifications and training of the staff.
X iosTI
' ! f.
Staff's fitness for duty.
NA i i g.
Attentiveness to duty.
l X
,osTI
) h.
Level of attention to detail.
l X
iosTI i
'l.
Off-hour plant staffing.
I X
! j.
Staff overtime usage.
X l
l SRI I
i 40500 i k.
Procedure usage / adherence.
X i
- SRI l
I I oSTI 40500 i
1.
Awareness of plant security.
X lDRS
, m.
Understanding of offsite emergency planning issues.
X i
l DRs C.3.2, Assessment of Coroorate Suocort and Site Enaineerina
' Sucoort X
'osTI e
I a.
Corporate staff understanding of plant issues.
l l
I b.
Corporate staff site specific knowledge.
X IosTI c.
Effectiveness i f the corporate / plant interface X
osTl
- meetings, d.
Corporate involvement with plant activities.
X osTi i
REVISION 6 November 18,1998 13
..--.n.-
l j
' NEED STATUS RESP
!DRS
! e.
Effectiveness of site engineering support.
X oSTI i
ICAVP f.
Effectiveness of the site design modification X
ICAVP OSTl process.
l.
g.
Effectiveness of licensing support.
X RAP h.
Coordination with offsite emergency planning X
DRS l
officials.
C.3.3 Ooerator lasues i'
a.
Licensed operator staffing meets requirements and licensee goals.
l X
DRS i
Level of formality in the control room.
X oSTI l b.
l SRI I
' c.
Effectiveness of control room simulator training.
X DRS l
! d.
Control room / plant operator awareness of X
oSTI SRI l
equipment status.
! e.
Adequacy of plant operating procedures.
oSTI I.
Procedure usage / adherence.
X i
I f
! OSTI
- g.
Log keen g practices.
X l oSTI
==
C.4
, ASSESSMENT OF PHYSICAL READINESS OF THE PLANT a.
Operability of technical specification systems.
X
, oSTI b.
Operability of required secondary and support X
i
- oSTI
. systems.
i c.
Results of pre-startup testing.
X
. SRI
! oSTI X
i
' OSTI d.
Adequacy of system lineups.
I X
l
! oSTI
! e.
Adequacy of surveillance tests / test program.
l f.
Significant hardware issues resolved (i.e. damaged i
X f
- oSTI equipment, equipment ageing, modifications).
i i
g.
Adequacy of the power ascension testing program.
X oSil l
SRI REVISION 6 November 18,1998 14
l lNEED STATUS RESP h.
Effectiveness of the plant maintenance program.
l X
- OSTI i
DRS 1.-
Maintenance backlog managed and impact on X
OsTi operation assessed.
J.
Adequacy of plant housekeeping and equipment X
OsTi storage.
C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS a.
Applicable license am6ndments have been issued.
X RAP b.
Applicable exemptions have been granted.
X e
RAP c.
Applicable reliefs have been granted.
X RAP d.
Imposed Orders have been modified or rescinded.
X RAP l e.
Significant enforcement issues have been resolved. l X
i l
Allegations have been appropriately addressed.
lX
, PE
' g.
10 CFR 2.206 Petitions have been appropriately X
I NRR (L) addressed.
h.
Atomic Safety and Licensing Board hearings have NA
{ No ASLB
' been completed.
hearing i required e
i j
before 1
restart i
C.6 COORDINATION WITH INTERESTED AGENCIES AND l PARTIES j
l i
! a.
Federal Emergency Management Agency X
'DRS
{
NRR (L) l b.
Environmental Protection Agency NA I
c.
Department of Justice X
' d.
Department of Labor X
l OE
! e.
Appropriate State and local officials l
X SLO if.
Appropriate public interest groups i
X l RAP l g.
Local news media l
X l
l OPA REVISION 6 November 18,1998 15
MILLSTONE RESTART ASSESSMENT PLAN ENCLOSURn (3)
LICENS!NG ISSUES REQUIRED FOR RESTART OF UNIT 2 TAC No.
Issue Status 1
M97746 Meteorological Tower instrumentation (TSs) 12/16/97 CW Mode-N/A (Withdrawn) 2 M98277 Ultimate Heat Sink Temperature (TSs) 02/06/98 CA Mode 4 3.
M98347 Enclosure Building (TSs) 09/30/97 CA Mode 4 1
4 M94623 Containment iso Valve List Removal from TSs 11/19/97 CA i
Mode 4 (TSs) 5 M92879 Control Rm Emergency Ventilation Sys (TSs) 08/16/98 CW Mode 4 (Withdrawn) l 6
M99543 EDG Fuel Oil Supply Adequacy License Amendment 01/25<98 CA Mode 4 (USQ) 7 MA2340 ESFAS and RPS - Setpoints & Allowable Values Under Review Mode 4 (TSs)
TS (01/15/99T) 8 MA0121 RCS P-T Curves (TSs) 07/01/98 CA Mode 4 9
M99503 Max. Containment Pressure Limit (TSs) 10/27/97 CA Mode 4 10 M99504 Technical Specification - Verbatim Compliance 05/26/98 CA i
Mode 4 (TSs) 11 M94105 Steam Generator Blowdown Monitors (TSs) 08/26/97 CA Mode 4 12 M99609 Rx Trip Setpoints - SG Safety Valves (TSs) 11/19/97 CA Modes 1-3 13 M97680 Siemans LOCA Analysis-Evaluation (non TS) 07/23/97 CA Mode 4 14 M99266 Startup Rate Trip (non TS) 08/19/97 CA Mode 4 15 M99296 Hydrogen Monitors - NUREG-0737 (non TS) 10/28/97 CA Mode 4 4
16 M99613 RG 1.97 - Core Exit Thermocouples (CETs) Power 01/12/98 CA Mode 4 Supply Modifications (non TS)
REVISION 6 November 18,1998
I e
?
17 MA2416 Exemption request - Appendix R Under Review Mode 4 (4 - Exemption requests needed)
(EX)
TS (12/31/98T) 18 MA0251 Compliance for CEA Rod Drop Testing & Design 06/16/98 CA Mode 2 Section Updates (TSs) l 19 M99614 ATWS - Commitment Withdrawal 10/29/98 CA Mode 4 RAI issued (01/23/98)
(non TS) 20 MA2441 Condensate Storage Tank Volume (TSs)'
Under Review - PM Mode 4 (12/31/98T) 21 MA1554 Trisodium Phosphate (TSP) Volume (TSs) 06/22/98 CA Mode 3 22 MA1649 Low Range Press Xmitters Diversity (USO)
Will be withdrawn Mode 4 (12/30/98T) 23 MA2255 Service Water Sys Protective Coating (USQ)
Under Review TS Mode 4 -
(12/30/98T) 24 MA1771 Continuous Bypass Inop Ch RPS/ESFAS (TSs) 11/10/98 CW Mode 4 25 MA3553 RCS Head Vent Surveillance Compliance issues # 4 Under Review - PM Mode 4 (TSs)
(01/15/99T) l l
26 MA1462 MSIV & Pressurizer Surveillance (TSs) 08/21/98 CA l
Mode 4 27 MA1137 RG 1.97 Deviation Variable D23 CAR Fans 04/30/98 CA Mode 4 (non TS) 28 MA 1066 ATWS Pressure Instruments (non TS) 04/30/08 CA Mode 4 29 MA1070 Leak-Before-Break Reanalysis Cold Leg (non TS) 10/06/98CA Mode 4 30 MA2367 Leak-Before-Break (Si & SDC sys)
(non TS) 10/06/98CA Mode 4 31 MA0838 Emerg. Preparedness Plan, Rev 24 (non TS) 06/04/98 CA Mode 4 32 M83642 IPEEE - Fire Protection issues (Turbine Building)
Under Review TS Mode 4 (non TS)
(12/30/98) 33 MA3410 Siemens MSLB-Reanalysis Methodology Change Under Review - TS Mode 4 (TSs)
(12/30/98T) 34 MA2311 EDG Surveillance Requirements & GDC-17 TS Under Review TS Mode 4 Clarification (TSs)
(01/30/99T) 35 MA3955 Shutdown Cooling Sys Relief Valve (TSs)
Under Review Mode 4 TS ( 12/31/98T) l REVISION 6 November 18,1998 2
_..m.___-.__
-0 36 Boron Precipitation - Hot leg inj Single Failure 12/15/98T Mode 4 (USQ)
P 37 Long Term CST Makeup via FW Sys.
(USO)
Not required to be Mode 4 submitted (no USQ involved).
38 MA3672 Cont. Rm. Ventilation DBA Calcus.
(TS & USO)
Under Review - TS Mode 4 (12/30/98T) 39 Passive Failure - ECCS Piping Post LOCA Not required to be Mode 4 (USQ) submitted (no USQ involved).
a 40 MA4126 Leak Before Break - Press Surge Line (non TS)
Under Review Mode 4 TS (02/26/99T) 41 Mode 4 Separation - Raceways (USQ) 1/5/99T 42 MA3671 Separation - Control Panel 12' to 6" (USQ)
Under Review TS Mode 4 (12/30/98T) 43 MA3392 Ampacity Derating (GL92-01)
(non TS)
Under Review TS Mode 4 (02/15/99T) 44 MA4175 SG Tube Rupture - Reanalysis (USO)
Under Review Mode 4 45 Mode 4 Loss of Feedwater - Reanalysis (USO)
Submittat date TBD.
46 MA4150 Continuous Bypass Inop Ch RPS/ESFAS Under Review Mode 4 (TSs)
TS (12/31/98T) 47 Mode 4 USQ - Hydrogen Purge (Backup to Recombiners) 12/15/98T 48 Mode 4 TS Change - ECCS Pump Flow Requirements (will refer 12/15/38T to IST program instead of having values in TS)
SUMMARY
e 48 licensing issues - 23 TS amendments,13 other licensing actions,1 Exemp. and 11 USQs e
22 are complete - 11 TS amendments,1 USQ, and 10 other licensing actions e
3 withdrawn - 3 TS Amendmeats e
2 were determined, upon further review, to not be USQw and will r..: need NRC approval.
21 remaining - 16 are under review and 5 have not been submind.
G REVISION 6 November 18,1998 3
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i MILLSTONE UNIT 2 - LICENSEE'S RESTART MILESTONES AND NRC'S PROJECT PLANNING SCHEDULE t
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l MILLSTONE UNIT 2 - LICENSEE'S RESTART MILESTONES Milestone '
Dalg Facility 2 Work Complete 12/22/98 Transition to Mode 6 -
12/31/98 Transition to Mode 5 01/18/99 Facility 1 Work Complete 02/01/99 Engineering Programs Complete 02/05/99 Start to Draw Pressurizer Bubble & Sweep Loops 02/06/99 Non Facility Work Ocmplete 02/16/99 Physically Ready for Restart 02/18/99 Transition to Mode 4 02/18/99 Transition to Mode 3 02/25/99 RCS at 500 'F, P>2000 psi, Start Motor Generator 02/25/99 ICAVP Complete 03/08/99 Sils Complete 03/18/99 Transition to Mode 2 03/24/99 Transition to Mode 1 03/24/99 Synchronize Turbine Generator to Grid 03/24/99
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NRC'S PROJECT PLANNING SCHEDULE Task Name Slad Finish NRC ICAVP Inspections
- Corrective Actions, Part i 12/14/98 12/18/98
- Corrective Actions, Part 2 2/1/99 2/12/99 Commission Meeting TBD TBD-License Amendments 8/14/98 2/18/99 Ready to Restart (Mode 4)- From Licensee's Schedule 2/18/99 2/18/99 OSTI (l' rep /Onsite) 2/8/99 3/5/99 ICAVP Final Report Complete 2/12/99 3/19/99 Inspection Program
- IP 40500 (Prep /Onsite) 1/11/99 2/5/99
- SIL Review 3/26/98 3/19/99 RAP Review TBD TBD EDO/DIR NRR Briefing TBD TBD Commission Briefing TBD TBD l
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i MILLSTONE UNIT 3 - POST-RESTART PERFORMANCE ASSESSMENT i
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t MILLSTONE UNIT 3 POST-RESTART PERFORMANQE ASStdSMENT Overall, the performance of Millstone Unit 3 since its restart in June 1998 has been acceptable; performance is typical of a plant returning to service after a shutdown in excess of 2 years. Several operational events (including a forced outage to repair a leaking valve with maintenance rule impact, two manual reactor trips as a result of secondary water chemistry problems, a manual reactor trip due to reduced condenser vacuum, a number of power reductions to address secondary system equipment problems and several technical specification compliance issues) have caused licensee management to initiate a collective assessment of the number and severity of operational challenges iacing the plant staff. The plant operators have responded well to the challenges with evidence of conservative decision-making and deliberate efforts to ensure compliance with procedural requirements. As power activities were conducted for the first time in more than 2 years, the higher standard for procedure compliance resulted in the identification of several procedural issues that were properly addressed by the operators on shift. Shift managers continue to display a questiccing attitude regarding planned activities and emergent work.
Historically, there has been evidence that the Millstone Unit 3 Operations staff has tolerated equipment problems and process inefficiencies that have affected their ability to operate the plant. This has resulted in a backlog of operator workarounds and temporary modifications that require licensee attention. Also, two recent Operations Department self-assessments have shown the need for additional plant equipment (nonlicensed) operators and improved processes in staff training, qualification, and work control practices, like tagging and valve manipulation accountability. The newly appointed Millstone Chief Nuclear Officer and the current Vice President of Operations have expressed to the NRC a recognition of the need for increased management attention to this area, particularly relating to the reduction of operator workarounds and other related burdens like control board deficiencies, temporary modifications, and staffing issues. An initial training class for nonlicensed operators is currently in progress and both licensed and nonficensed operator classes are planned to cc.nmence next year u alleviate staffing concems; also, other initiatives are being explored to improve efficiency on operations / work control issues.
Other work control disciplines, like mairitenance and engineering, have been similarly burdened by somewhat cumbersome processes, albeit ones that have improved since the plant shut down in 1996. Maintenance activities coming out of the extended outage have been generally well controlled, with " backlogged" items receiving a thorough review to preclude adverse impact on component or system functionality. The emerging work continues to make it difficult to achieve a major reduction in the overall amount of corrective maintenance, but the number of on-line work orders has recently been lowered below 500 and the volume of probabilistic risk assessment (PRA) risk-significant work has been kept below 350 items, meeting management goals in these areas of backlog management. A 12-week rolling schedule used for equipment outages has not yet attained its full efficiency as a planning tool, but PRA input is being effectively used to prioritize work and evaluate the safety impact of the removal of components for preventive maintenance and other operational configuration management questions.
Progress is being made relative to reducing the number of deferred work items; however, the licensee stated during a Restart Assessment Plan meeting on October 27,1998, that it has approximately 60 additional engineering items which should have been included on the deferred issues list. The staff will review these additional items to determine their safety significance and to decide whether enforcement action is warranted.
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~ To address past configuration management program breakdowns at Millstone, significant efforts have been initiated to improva configuration controls at the work performance and I
maintenance level. Although this process is not error-free, as evidenced by the licensee's periodi, discovery of component and system alignment problems, the low threshold for the self-identification of such problems in condition reports (CRs) reflects a healthy and improving program. Additionally, the audit, surveillance, and quality control activities performed by the Nuclear Oversight group, while increasing the CR totals and corrective action requirements, have been recognized as adding value to worker performance and maintenance effectiveness. Overall, the strength of the Nuclear Oversight organization has been noted to be much improved since the unit shut down and, as a result, the resultant quality assurarse activities have been more effective.
In the area of engineering, some problems in the design change control process (e.g.,
choice of improper material for service water /hypochlorite isolation valves) has resulted in recent power ruuctions to effect repairs. This has raised some recurrent NRC concerns regarding the output quality of the plant modification process. Although overall engineering performance has improved, as substantiated by the Independent Corrective Action Verification Program results and resolution of findings, a significant number of existing and emergent engineering issues remain, thus straining the resources for reducing engineering backlog and planning and executing future design modifications.
With the next refueling outage scheduled to begin in May 1999, the planning and timing for schedule development and the scope of modification activities have been compressed, affecting the current engineering workload. An NRC IP 40500 corrective action inspection, scheduled for Millstone Unit 3 in the first half of 1999, will review the deferred issues backlog management program at Millstone Unit 3 (this inspection may be included with the Millstone Unit 2 IP 40500, if the timing allows). Such an inspection will supplement the planned NRC engineering program inspection activities, with likely overlap into the areas of design modification controls, overall engineering adequacy, and sustained performance improvements.
The licensee has commenced a reorganization that will effectively reduce the total number of managers from the director level to first-line supervisors by 50 percent. This reorganization will create a " station" versus a " unit" organization structure. This reorganization (the new directors were appointed in early November 1W8, and the manager and supervisor selection process will extend several months into 1999) will be a challenge that will require extensive senior management involvement by the licensee over the next several months and will be followed closely by the staff.
Recently, Millstone Station's operator training programs were put on probation for 180 days by the National Academy fc. Nuclear Training of the Institute for Nuclear Power Operations. This probationary period was determined to be appropriate while Millstone demonstrates sustainability of corrective actions it implemented earlier this year to address several self-identified weaknesses. The Academy's Accrediting Board makes its judgement based on the record of the past 4 years, during which there were some substantive issues that emerged. Since some of the licensee's initiatives are just beginning to show improvement, the Board decided to place the operator training programs in the 180-day probationary period.
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l NRC'S PROJECT PLANNING SCHEDULE i
Task Name Slad Finish
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NRC ICAVP Inspections
- Corrective Actions, Part 1 12/14/98 12/18/98
- Corrective Actions, Part 2 2/1/99 2/12/99 Commission Meeting
.TBD TBD License Amendments 8/14/98 2/18/99 Ready to Restart (Mode 4) - From Licensee's Schedule 2/18/99 2/18/99 OSTI (Prep /Onsite) 2/8/99 3/5/99 i
ICAVP Final Report Complete 2/12/99 3/19/99 Inspection Program
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- IP 40500 (Prep /Onsite) 1/11/99 2/5/99
- SIL Review 3/26/98 3/19/99 RAP Review TBD TBD EDO/DIR NRR Briefing TBD TBD l
Commission Briefing TBD TBD l
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