ML20206F223

NRC Manual Chapter 0350 Restart Action Plan for Clinton Power Station

ML20206F223
Person / Time
Site:	Clinton
Issue date:	04/27/1999
From:	NRC
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ML20206F217	List: ML20206F214 ML20206F223 ML20206F233 ML20206F236 ML20206F248
References
PROC-990427, NUDOCS 9905060047
Download: ML20206F223 (46)

Text

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ENCLOSURE NRC MANUAL CHAPTER 0350 RESTART ACTION PLAN FOR CLINTON POWER STATION T!!' 188!1 E888?u PDR O

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.y CLINTON POWER STATION RESTART ACTION PLAN A.' G E N E RAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 A.1 P U R POS E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 A.2- OBJECTIVES . . . . . . . . . . . . . . . . .. . . . . . . . . . . ......................~1 A.3 BAC KG ROU N D . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

. A.4 ACTIVITI ES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 A5 OVERALL NRC VERIFICATION STRATEGY . . . . . . . . . . . . . . . . . . . . . . . . . 4 B. CASE-SPECIFIC CHECKLIST - PART I (PROCESS) . . . . . . . . . . . . . . . . . . . . . . . . . 4  ;

B.1 INITIAL NRC RESPONSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 B.2 NOTI FICATION S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS . . . . . . . . . . . . 7 B.4 REVIEW IMPLEMENTATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 :

B.4.1 Root Causes and Corrective Actions . . . . . . . . . . . . . . . . . . . . . . . . . . 10 B.4.2 Assessment of Equipment Damage . . . . . . . . . . . . . . . . . . . . . . . . . . 11 B.4.3 Determine Restart issues and Resolution . . . . . . . . . . . . . . . . . . . . . . 11

' B.4.4 Obtain Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 B.4.5 Closeout Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 l

B.5 - RESTART AUTHORIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 B.6 RESTART AUTHORIZATION NOTIFICATION . . . . . . . . . . . . . . . . . . . . . . 16 j C. CASE-SPECIFIC CHECKLIST - PART ll (ISSUES) . . . . . . . . . . . . . . . . . . . . . . . . . . 17 C.1 ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION . 17  !

C.1.1 Event Analysis and Root Cause Assessment . . . . . . . . . . . . . . . . . . . 18 C.1.2 Corrective Action Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 l C.1.3 Corrective Action Plan implementation and Effectiveness . . . . . . . . . 22 C.2 LICENSEE SELF-ASSESSMENT AND MANAGEMENT EFFECTIVENESS . 24 C.2.1 Self-Assessment Capability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 C.2.2 Management Oversight and Effectiveness . . . . . . . . . . . . . . . . . . . . . 26 C.2.3 Management Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 C.3 ASSESSMENT OF PLANT AND CORPORATE STAFF EFFECTIVENESS . 29 ,

I C.3.1 Assessment of Staff . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . 29 C.3.2 Assessment of " Corporate" Support . . . . . . . . . . . . . . . . . . . . . . . . . . 32 C.3.3 Operator issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . 32 C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT . . . . . . . . . .. , . 33 C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS 35 i C.6 COORDINATION WITH INTERESTED AGENCIES AND PARTIES . . . . . . . 37 I

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1 A. GENERAL A.1 PURPOSE To provide a basis to plan and coordinate NRC review activities for restart of Clinton Power Station.

A.2 OBJECTIVES To ensure that NRC review efforts are consistently developed, communicated, and implemented and specific guidance is provided to support:

a. Determining restart issues for review, b.' identifying the basic tasks needed to review and approve plant restart, and

c. Coordinating and tracking restart review activities.

A.3 BACKGROUND in December 1996, Illinois Power (IP) decided to maintain Clinton Power Station (CPS) in an extended shutdown to address performance issues identified by the NRC during the review of the circumstances associated with the September 5,19%, reactor recirculation pump seal failure. The NRC initially raised concems with Illinois Power (IP) senior management's and CPS staff's inMial investigation into the root causes of the September 1996 event which failed to identify significant procedural adherence issues. The NRC issued Confirmatory Action Letters (CALs) Rlll-96-013 on September 11,1996; Rlli-97-001 on January 9,1997; and Rill-97-006 on June 9,1997. CALs Rill-96-013 and Rill-97-001 addressed specific issues stemming from the September 5,1996, reactor recirculation pump seal leakage event. CAL Rlll-97-006 addressed degraded containment coating conditions.

Following the Senior Management Meeting in January 1997, IP was notified by letter dated January 27,1997, that NRC senior managers had identified the safety performance at CPS as trending adversely. Performance issues included examples of non-conservative safety focus in decision-making, poor procedural adherence and adequacy, weak engineering and maintenance support to operations, and a lack of discipline and rigor during conduct of operations. In March 1997, the NRC Region lli and Office of Nuclear Reactor Regulation staffs formed an NRC Oversight Panel for CPS to ensure appropriate NRC focus was provided and resources were allocated with regard to CPS improvement initiatives. On March 13,1997, the NRC staff issued a Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," Restart Action Plan for CPS to govem the conduct of NRC inspection and evaluation activities for plant restart.

Equipment problems identified subsequent to the trending letter continued to require NRC involvement to ensure proper resolution. This was noted in the June 23,1997, Systematic Assessment of Licensee Performance report, which stated that the inspection findings and NRC effort required to achieve acceptable issue resolution indicates that Illinois Power's management had not provided sufficient oversight to ensure the program for problem identification and corrective action was effective and that management often did not understand the significance 1

k of hardware issues and did not ensure that effective measures were taken to address the issues.

As a result of these continuing NRC concems and following the Senior Management Meeting

_ (SMM) review in June 1997 of CPS improvement initiatives, IP committed to perform an

. integrated Safety Assessment (ISA) similar to an NRC Diagnostic Evaluation in an August 21, 1997, letter to IP, the NRC informed CPS management that the NRC would perform a Special Evaluation Team (SET) assessment to independently evaluate the scrutability and thoroughness of CPS's Integrated Safety Assessment.

Subsequent to the June 1997 SMM and prior to the ISA, one safety-related and one nonsafety-related Westinghouse 4160 volt,1200 amp breaker failed on July 22,1997 and a similar safety-related circuit breaker failed on August 5,1997. These failures indicated that IP's preventive j maintenance program for circuit breakers was inadequate. This performance insight was j particularly significant given that IP had implemented a special breaker inspection program to address previously identified weaknesses in breaker preventive maintenance activities. As a result of growing concems with IP's corrective action program at CPS and the associated impact on maintaining operability of safety-related structures, systems, and components (SSCs), the NRC issued a DFl which required IP to provide the NRC with information addressing why IP '

had: (1) reasonable assurance that actions taken to address the recurring weaknesses in the corrective action program had been effective, and (2) reasonable assurance that the operability of safety-related SSCs had not been adversely affected by the licensee's activities. 1 The ISA was performed between August and October 1997, and significant weaknesses were identifed in the operations, engineering, maintenance, and plant support functional areas.

Identified weaknesses included the overall conduct of operations, management and supervision of operations, performance of system engineers, control and understanding of the design basis, maintenance work scheduling, work processes, and radiation protection performance. In addition, the ISA identified weaknesses in barriers to prevent safety problems that were not typical of facilities with a strong nuclear safety culture. These weak barriers were identified at all levels of management associated with CPS and were dispersed throughout CPS's processes.

On January 2,1998, the NRC documented the results of an NRC Special Evaluation Team (SET) which evaluated activities at CPS and validated the findings of the ISA. The SET determined that the ISA conducted an effective diagnostic assessment of the station's performance and reached substantive conclusions. The SET determined, based on an assessment of CPS performance from June 1995 through October 1997, that the following were the root causes of the licensee's problems concerning management and leadership; programs, processes, and procedures; and human performance: (1) management generally did not establish and implement effective performance standards; (2) CPS programs, processes, and procedures did not consistently provide defense in depth to assure plant activities were conducted in a safe manner; (3) problem identification was inconsistent and evaluation and corrective actions were generally ineffective; and (4) management did not ensure that the infrastructure was suitable to support major changes.

On January 15,1998, a letter was forwarded to Illinois Power which documented that NRC senior managers had placed Clinton on the NRC Watch List as a Category 2 plant and that increased NRC attention was warranted until a period of demonstrated improved performance i 2

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was obtained. NRC letter dated January 21,1998, documented that the NRC Site Performance improvement Oversight Panel activities had been re-initiated.

On February 3,1998, CPS announced several management changes following the January 5, 1998, announcement that PECo Energy Company would provide management services at CPS.

On February 19,1998, CPS docketed a summary of the Plan For Excellence (PFE) including restart commitments. The PFE summary identified actions to achieve broad goals, including strategies for management oversight, personnel development, communications, safety culture, training of personnel, conduct of operations, corrective action program, work management program, procedures, preventive maintenance, plant equipment performance, system engineer effectiveness, backlogs of maintenance and surveillance tests, hardware / design readiness, 1 organization readiness, and program readiness. l Meetings were held between the NRC and CPS on September 26 and November 14,1997, and January 18, February 5, March 17, and May 5, June 23, July 7, September 17 October 23, November 10, and December 17,1998, and January 14, February 5, March 18, March 25, and April 16,1999 to discuss activities involving circuit breakers, the corrective action program, preventive maintenance, work control, quality assurance, design reviews, plant material condition, the conduct of operations, and the development and implementation of the PFE.

-On July 14,1998, the NRC revised its Restart Action Plan. The revision was necessitated by the transpiration of several significant activities at CPS, including IP's development of the PFE.

The PFE included new commitments by IP for completion prior to the restart of CPS. The NRC Restart Oversight Panel established a Case Specific Checklist (CSC) to reflect the specific items that the NRC considered to be necessary to be addressed by IP prior to plant restart. The Restart Oversight Panel verified that the issues identified on the CSC were included in IP's PFE.

The CSC was revised on September 15 and December 2,1998.

A.4 ACTIVITIES A comprehensive NRC review of the restart process is required. This Restart Action Plan is intended to include expected NRC actions that will be required to be taken before restart of Clinton Power Station. The Plan defines: the actions which must be accomplished by the NRC, as a minimum, to approve restart; the organization that has the lead responsibility for each action; the case-specific issues which must be resolved before restart; and the individuals with the actual responsibility for restart approval. The Panel retains responsibility for assessment of the restart issues and determining whether each issue has been satisfactorily addressed. The Panel will make updates and minor revisions to the Restart Action Plan. Restart Panel meetings will be documented on minutes to include restart issues reviewed.

Section B, " Case-Specific Checklist - Part 1," of this plan provides generic tasks that support the Restart Action Plan. This section outlines the overall review process needed for the NRC to authorize restart of the facility. Section C, " Case-Specific Checklist - Part II," contains issues requiring assessment during the restart review. Within the scope of each issue are numerous elements or examples supporting the broader issues which were the causes for the shutdown.

It will not be necessary for each element or example on the checklist to be assessed, but enough items must be reviewed to make an assessment that the issue has been sufficiently resolved to support plant restart. Each of the checklists in Section B and C includes columns to 3

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'r record the NRC organization with lead responsibility for the item and the date and mechanism by which the item was or will be closed.

The Panelis responsible for implementation of the CPS Restart Action Plan. The Panel will maintain and periodically review the Restart Action Plan. These actions should: (1) determine review status, (2) verify necessary tasks and items are complete for each phase of the review, and (3) ensure that review tasks and issues for assessment remain consistent with the known facts and status of the restart effort. The lists in Sections B and C should be reviewed when significant milestones are completed and prior to restart authorization to ensure any emerging items are considered.

A.5 OVERALL NRC VERIFICATION STRATEGY The Panel is responsible for reviewing status and rationale for closure of all Case-Specific Checklist issues. Verifications performed by the Panel itself (such as review of the CPS Restart Plan) will be documented in the Case-Specific Checklist and supplemented as needed in' the Panel meeting minutes.

Several of the verification items in the Case-Specific Checklist will be completed in the routine inspection program by the resident and regional staff. In addition, the NRC will conduct inspections in the areas of engineering and technical support, self-assessment and corrective actions, operator licensing, maintenance rule implementation, and emergency preparedness.

These verifications were documented in the inspection reports.

A Restart Readiness Assessment Team inspection was conducted by a Region 111 inspection team near or after the licensee informed the NRC that the plant was ready to restart. This -

. inspection was a modified Operational Readiness Assessment Team / Operational Safety Team Inspection and evaluated areas delineated in the Case-Specific Checklist, as well as other performance concems designated by the Panel. The Restart Readiness Assessment Team was organized and led by Region lli Division of Reactor Safety personnel. These efforts will be

' documented in inspection reports.

B. CASE-SPECIFIC CHECKLIST - PART I (PROCESS)

B.1 INITIAL NRC RESPONSE Establishment of the facts, the causes, and their apparent impacts should be accomplished early in the process. This information will assist the NRC in characterizing the problems, the safety significance, and the regulatory issues. Early management appraisal of the situation is also important to ensure the proper immediate actions are taken. Many of these items may already be complete when the initial checklist review is performed.

TASKS

a. Initial notification and NRC management discussion of known facts and issues (Region).

STATUS: COMPLETE 4 l

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NRC Management was initially notified of the recirculation pump seal failure on September 5,1996. A specialinspection and an Operational Safety Team inspection were conducted and the results of these inspections were communicated to NRC management via numerous briefings and Special Inspection Report 50-461/96011 issued November 19,1996. NRC management was notified of the circuit breaker failures shortly after they occurred. An AIT was dispatched to the site to review the circumstances surrounding the failures and

. the results of this inspection were communicated to NRC management via numerous briefings and AIT Inspection Report 50-461/97018 issued November 24,1997.

In addition, Clinton Power Station performance was discussed at the January 1997 SMM and each subsequent SMM through the April 1999 meeting.

b. Identify / implement additional inspections (i.e., AIT, llT, or Special):

STATUS: COMPLETE The following additional inspections were conducted and their findings and conclusions were documented in the following inspection reports:

50-461/96011(Special/OSTI) 97018 (AIT) 50-461/ 97022 (DRP) 97025 (DRP) 50-461/98003 (DRP) 98017 (DRP) 50-461/98028 (Maint Rule) 98029 (Requal Exams) 50-461/99001(40500) 99002 (DRP) 50-461/99003 (SSEI) 99004 (OPS Readiness) 50-461/99006 (DRP) 99011 (DRP)

Licensee conducted ISA SET report dated January 2,1998

c. ' Determine need for formal regulatory response (i.e., order or CAL).

STATUS: COMPLETE The NRC issued Confirmatory Action Letters (CALs) Rlll-96-013 on September 11,1996; Rlil-97-001 on January 9,1997; Rlll-97-006 on June 9, 1997; and Rill-97-009 on August 6,1997. CALs Rill-96-013 and Rill-97-001 addressed specific issues stemming from the September 5,1996, reactor recirculation pump sealleakage event. CAL Rill-97-006 addressed degraded containment coating. CAL Rlli-97-009 addressed circuit breaker issues stemming from the August 5,1997, circuit breaker failure. All CALs are closed.

CALS Rlli-96-013,97-001, and 97-006 were closed in a letter from A. Bill Beach, Regional Administrator, Region lll to John G. Cook, Senior Vice President, IP, dated August 4,1997 and CAL Rill-97-009 will be closed in a letter from Jim Dyer, Regional Administrator, Region lli to John McElwain, Chief Nuclear Officer, prior to restart.

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l- The NRC issued a Demand for Information (DFI) on September 26,1997. The l DFl pertained to IP's continued deficiencies in their corrective action program and NRC's concem that these deficiencies affected the ability of safety-related structures, systems, and components to perform their intended functions. The DFl will be closed in a letter from Jim Dyer, Regional Administrator, Region lil to John McElwain, Chief Nuclear Officer, prior to restart.

d. Identify other parties involved (i.e., NRC Organizations, other Federal agencies, l Industry organizations).

STATUS: COMPLETE No other parties were involved.

B.2 NOTIFICATIONS Initial notification of the event quickly communicates NRC's understanding of the event and its immediate response to the parties having an interest in the event. Notification to Regional and I headquarters offices of cognizant Federal agencies may be appropriate. As the review process continues, additional and continuing notifications may be required.

TASKS

a. Issue Daily and Director's Highlight (NRR).  !

STATUS: COMPLETE I

Directors highlights were issued for management changes and significant activities at CPS. l l

b. Issue preliminary notification (Region).  !

I STATUS: COMPLETE  !

l Preliminary notifications were issued on September 6,1996 (Shutdown to Repair l Recirculation Pump Seal Due to Unidentified Leakage above the Technical  !

. Specification Limit); September 17,1996 (Update to Shutdown to Repair Recirculation Pump Seal); October 8,1996 (Second Update to Shutdown to l l Repair Recirculation Pump Seal); August 5,1997 (Augmented Inspection Team l to Review 4160 volt Circuit Breaker Failure); August 15,1997 (Update to Augmented Inspection Team to Review 4160 volt Circuit Breaker Failure); i September 26,1997 (NRC Staff issues Demand For information to lilinois Power Co.); and January 5,1998 (PECo Energy to Provide Management Services at i Clinton).

c. Conduct Commissioner assistants' briefing:

STATUS: COMPLETE.

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- I The NRC addressed Clinton Power Station (CPS) restart activities during Plant Performance Reviews (PPRs), NRC Senior Management Meetings (SMMs), and the Systematic Assessment of Licensee Performance (SALP). PPRs for CPS were conducted on November 6,1996; March 6 and October 21,1997; April 28 1998; and February 2.1999. The NRC issued a SALP addressing CPS's extended outage and . is documented in inspection Report 50-461/97001.

Clinton Power Station ierformance was discussed during January 1997 SMM and each subsequent SMM through the April 1999 SMM.

d. Issue Commission paper:

STATUS: COMPLETE - Not Required

e. Cognizant Federal agencies notified:

STATUS: COMPLETE. l l

f. State and local officials notified (Region). 1 STATUS: COMPLETE State and local officials received NRC issued preliminary notices. The NRC issued preliminary notices on September 6,1996 (Shutdown to Repair j Recirculation Pump Seal Due to Unidentified Leakage above the Technical  !

Specification Limit); September 17,1996 (Update to Shutdown to Repair l Recirculation Pump Seal); October 8,1996 (Second Update to Shutdown to l Repair Recirculation Pump Seal); August 5,1997 (Augmented Inspection Team  !

to Review 4160 volt Circuit Breaker Failure), August 15,1997 (Update to l Augmented Inspection Team to Review 4160 volt Circuit Breaker Failure)-  !

September 26,1997 (NRC Staff issued Demand-for-Information to Illinois Power  !

Co.); and January 5,1998 (PECo Energy to Provide Management Services at Clinton). In addition, the State was notified of the circumstances surrounding i each event by the Illinois Department of Nuclear Safety resident inspector. )

g. Congressional notification (NRR)

STATUS: COMPLETE .

NRR and Region 111 notified the Office of Congressional Affairs via Directors Highlights and preliminary notices.

B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS It will be necessary to establish and organize the NRC restart review to ensure the effective coordination of resources in evaluating the restart process. Effective interfaces within and outside the NRC are critical to properly identify and resolve the pertinent issues,. Consider both Regional and headquarters offices of cognizant Federal agencies.

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TASKS

a. Establish the Restart Panel.

STATUS: COMPLETE On March 13,1997, the NRC Restart Oversight Panel was established and issued a Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval,"

Restart Action Plan for CPS to govern the conduct of NRC inspection and evaluation activities for plant restart. On July 14,1998, the NRC revised its Restart Action Plan. The revision was necessitated by the transpiration of several significant activities at CPS, including IP's development of the Clinton Plan for Excellence (PFE) on February 19,1998. The PFE included new commitments by IP for completion prior to the restart of CPS. The NRC Restart Oversight Panel established a Case Specific Checklist (CSC) to reflect the specific items that the NRC considered to be necessary to be addressed by IP prior to plant restart. The Restart Oversight Panel verified that the issues I identified on the CSC were included in IP's PFE. The CSC was updated on September 15 and December 2,1998.

b. Assess available information (i.e., inspection results, licensee self-assessments, industry reviews).

STATUS: COMPLETE l

information reviewed I

Following inspection reports were used to develop Restart Action Plan and CSC ltems:

50-461/96011(Special/OSTI) 50-461/97001(SALP) 50-461/97012(DRP) 50-461/97018 (AIT) 50-461/97019(DRP) 50-461/97022 (DRP) 50-461/97025 (DRP) 50-461/98003 (DRP)

SET report dated January 2,1998 ISA report dated October 20,1997

c. Obtain input from involved parties both within NRC and other Federal agencies such as FEMA, EPA, DOJ.

STATUS: COMPLETE No interest was expressed by other agencies; therefore, input was not required.

d. Conduct Regional Administrator briefing (Region).

STATUS: COMPLETE Briefing conducted March 1997 8

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!e l e. Conduct NRR Executive Team briefing (NRR).

STATUS: COMPLETE

! f. Develop tne case-specific checklist (CSC).

STATUS: COMPLETE The Restart Plan for CPS was approved on March 13,1997. The plan was revised on July 14,1998 to include the Case Specific Checklist (CSC). The CSC and the restart plan was updated on September 15 and December 2,1998.

g. Develop the Restart Action Plan.

STATUS: COMPLETE Panel approval on March 13,1997.

h. Regional Administrator approves Restart Action Plan:

STATUS: COMPLETE Plan was approved on March 13,1997,

i. ' NRR Office Director approves Restart Action Plan:

j STATUS: COMPLETE Approval was not required.

J. Implement Restart Action Plan:

STATUS: COMPLETE Implemented on March 13,1997 and closed on July 15,1997. A re-opened and revised Restart Action Plan was issued on July 14,1998 and closed on April 20, 1999.

k. Modify CAL or order as necessary:

STATUS: COf.iPLETE Modification to CALs was not necessary. No orders were issued.

B.4 REVIEW IMPLEMENTATION The review will be accomplished by a variety of methods including inspections, testing, evaluation of licensee self-assessments, evaluation of licensee action plans, and regulatory actions. Once the licensee has developed its corrective action plan, the NRC shall review that 9

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. plan to verify its completeness and adequacy. . The NRC will also determine which corrective actions will be required to be implemented before restart, and thus become restart issues, and

. those that can be deferred to some later date as long-term corrective actions. The discussions and issues provided in Section C of this appendix provide additional information to support the review activities described below.

B.4.1 Root Causes and Corrective Actions l- TASKS

a. Evaluate findings of AIT, llT, or special team inspection, STATUS: COMPLETE

The Special inspection and AIT findings were incorporated into the CSC.

! ' b. Licensee performs root cause analysis and develops corrective action plan for l root causes.

STATUS: COMPLETE in responsa to the initial event, the licensee developed a corrective action plan called the Startup Readiness Action Plan (SRAP) to address the root causes of the event. Follow;ng the breaker failures, and the ISA, and SET inspections, the licensee developed a new corrective action plan called the Plan-for-Excellence

- (PFE) to address the root causes of identified issues included in the PFE was a plan to address the issues raised in the Demand-for-information regarding the

! licensee's corrective action program.

l c. NRC evaluates licensee's root cause determination and corrective action plan.

' STATUS: COMPLETE On July 3,1997, the NRC completed an evaluation of the actions taken to address SRAP commitments and documented the results in NRC Inspection Report 50-461/97012(DRP). The NRC performed a number of inspections to -

evaluate the effectiveness of the actions taken to address the commitments in the PFE and documented the results in the following inspection reports:

50-461/98017 (DRP) 50-461/98028 (DRP) 50-461/99002 (DRP) 50-461/99003 (SSEl) 50-461/99006 (DRP) 50-461/99008 (EP)

In addition, two team inspections and a resident inspection were performed for which the results will be documented in inspection Reports 50-461/99001, 50-461/99004 and 50-461/99011. The results for these inspections regarding open CSC items are documented in attached letters to the panel chairman.

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m B.4.2 Assessment of Eauioment Damaae TASKS

a. Licensee assesses damage to systems and components:

STATUS: COMPLETE The licensee presented their corrective action plans for the recirculation pump sealleakage and circuit breaker failures at a public 0350 meeting on October 23, 1998 and December 17,1998, respectively.

b. NRC evaluates licensee damage assessment:

STATUS: COMPLETE.

The NRC staff determined that the licensee adequately captured all potentially inoperable equipment and all damaged equipment in its damage assessment.

l c. Licensee determines corrective actions:

STATUS: COMPLETE l i Corrective actions to address potentially inoperable equipment and damaged equipment were included in the licensee's SRAP and PFE. The licensee documented its corrective actions in response to CALs Rill 96-013, dated December 9,1996; Rlll-97-001, dated July 2,1997; Rill-97-006, dated June 9, 1997, and Rill-97-009, dated December 11,1998, and to the DFI, dated February 8,1999,

d. NRC evaluates corrective actions:

STATUS: COMPLETE j The NRC evaluated the licensee's corrective actions committed to in the PFE and concluded that the licensee's actions were satisfactory to address potentially inoperable equipment and all damaged equipment. The results of the circuit breaker review were included in IR 50-461/99003 and the results of the recirculation seal failure were documented in IR 50-461/99006.

B.4.3 Determine Restart Issues and Resolution TASKS

a. Review / evaluate licensee generated restart issues.

STATUS: COMPLETE 11

k The NRC evaluated the licensee's PFE and concluded that the licensee's restart commitments were comprehensive to address performance deficiencies,

b. Independent NRC identification of restart issues (consider sources external to NRC and licensee).

STATUS: COMPLETE The NRC issued CAL 97-001 to confirm the restart commitments made in the SRAP. Subsequent to the ISA/ SET, the NRC independently reviewed all i available documentation associated with CPS performance deficiencies and generated a new restart list, the Case Specific Checklist (CSC).

c. NRC/ licensee agreement on restart issues.

STATUS: COMPLETE The NRC restart list was subsumed in the licensee's PFE.

d. Evaluate licensee's restart issues implementation process.

STATUS: COMPLETE The resident inspector staff routinely evaluated the licensee's implementation process and documented their conclusions in routine inspection reports.

e. Evaluate licensee's implementation verification process.

STATUS: COMPLETE The resident inspectors identified weaknesses and deficiencies in inspection Reports 50-461/98020,99002, and 99006. This was also documented in the results of the February 1999 Plant Performance Review meeting for CPS.

B.4.4 Obtain Comments TASKS

a. Obtain public comments:

STATUS: COMPLETE NRC staff was available to answer questions and receive comments from the  !

public at all of the following public Restart Oversight Panel meetings:  !

November 14,1997; March 17,1998; May 5,1998; June 23,1998; July 7,1998; j

. September 17,1998; October 23,1998; November 10,1998; December 17, l 1998; January 14,1999; February 5,1999; March 18,1999; March 25,1999; and i April 16,1999. l 12 l l

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b. Obtain comments from State and Local Officials:

STATUS: COMPLETE i

No comments were received from State and Local Officials.

c. Obtain comments from applicable Federal agencies:

STATUS: COMPLETE No comments were received from other Federal agencies.

B.4.5 Closeout Actions TASK'

a. Evaluate licensee's restart readiness self-assessment:

STATUS: COMPLETE The keensee completed an assessment of restart items. The NRC completed its review of all restart items on April 20,1999. See attached Case Specific Checklist. I

b. NRC evaluation of applicable items from Section C "lSSUES" complete.

STATUS: COMPLETE Status of MC 0350 issues and other known potential startup issues was discussed and verified as closed during the April 20,1999, intemal Restart Oversight Panel meeting.

The MC 0350 Restart Action Plan Closeout letter indicates that the licensee remains responsible for ensuring that any other issues which may impact unit restart or safe plant operations are promptly identified and properly addressed.

c. Restart issues closed: l STATUS: COMPLETE '

The NRC has completed its review of all restart issues. Improvements in the work control / operations interface will be tracked outside the MC 0350 process.

See attached CSC. '

d. Conduct NRC restart readiness team inspection STATUS: COMPLETE Restart readiness inspection was conducted in March and April 1999. The team's conclusions will be documented in inspection Report 50-461/99004 The conclusions of the team are also included in an attached memorandum. Other I

13

D l maior team inspections were conducted to verify CPS's readiness for restart.

Th6se included assessment of the licensee's corrective action program, engineering support of plant operations activities, implemeritation of the Maintenance Rule, and effectiveness of IP's emergency preparedness program.

e. Issue augmented restart coverage inspection plan (Region).

STATUS: COMPLETE A coverage inspection plan has been developed based on licensee's restart estimations.

f. Comments from other parties considered.

STATUS: COMPLETE No comments were received from other parties.

g. Determine that all conditions of the Order / CAL are satisfied.

STATUS: COMPLETE The NRC issued Confirmatory Action Letters (CALs) Rlil-96-013 on September 11,1996; Rlll-97-001 on January 9,1997; Rill-97-006 on June 9,1997; and l Rlll-97-009 on August 6,1997. CALs Rill-96-013 and Rill-97-001 addressed specific issues stemming from the Septernber 5,1996, reactor recirculation pump l sealleakage event. CAL Rlil-97-006 addressed degraded containment coating.

l CAL Rlll-97-009 addressed circuit breaker issues stemming from the August 5, j 1997, circuit breaker failure. CALS Rill-96-013,97-001, and 97-006 were closed in a letter from A. Bill Beach, Region Administrator, Region 111 to John G. Cook, Senior Vice President, IP, dated August 4,1997. CAL Rlll-97-009 will be closed in a letter from Jim Dyer, Regional Administrator, Region ill to John McElwain, Chief Nuclear Officer, prior to restart.

The NRC issued a Demand for information (DFl) on September 26,1997. The DFl pertained to IP's continued deficiencies in its corrective action program and NRC's concern that these deficiencies affected the ability of safety-related structures, systems, and components to perform their intended functions. The DFl will be closed in a letter from Jim Dyer, Regional Administrator, Region lil to John McElwain, Chief Nuclear Officer, prior to restart.

h. Re-review of Generic Restart Checklist complete.

STATUS: COMPLETE Restart Oversight Panel re-reviewed the Generic Restart Checklist on April 20, 1999.

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B.5 RESTART AUTHORIZATION l

When the restart review process has reached the point that the issues have been identified, corrected, and reviewed, a restart authorization process is begun.

TASKS

a. Prepare restart authorization document and basis for restart.

STATUS: COMPLETE A restart authorization memorandum was prepared by the panel.

I

b. NRC Restart Panel recommends Restart Authorization (Panel).

STATUS: COMPLETE Restart Oversight Panel reached a consensus to recommend authorization of CPS restart on April 20,1999.

c. No restart objections from applicable HQ offices (NRR).

l STATUS: COMPLETE The Office of Investigations, Enforcement and General Counsel were verbally notified of the Clinton restart. No objections were received.

d. No restart objections from applicable Federal agencies (NRR).

( STATUS: COMPLETE FEMA Headquarters faxed NRR an internal memorandum generated by FEMA Region V personnel to FEMA Headquarters as a basis for indicating FEMA did not have any restart objections for Clinton Power Station.

e. . Regional Administrator concurs in Restart Authorization (Region).

STATUS: COMPLETE This item is considered closed based upon discussion of current status, specific description of actions being taken to complete this item, and Panel agreement to those steps in the 4/20/90 Panel meeting. Final verification is being tracked outside the MC 0350 plan.

f. NRR Office Director concurs in Restart Authorization (NRR).

STATUS: COMPLETE 15 l

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Region Administrator discussed CPS restart authorization with the NRR Office l

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Director and the Executive Director for Operations (EDO) at the SMM on April 21, 1999. The Regional Administrator will consult with the Director, NRR, and the EDO prior to signing out action plan closecut letter. Final verification is being tracked outside the MC 0350 plan.

g. EDO concurs in Restart A Jthorization when required.

STATUS: COMPLETE The Regional Administrator briefed the EDO during the April 20 - 21,1999 Senior >

Management Meeting and will consult with the EDO prior to signing out action plan closeout letter. Final verification is being tracked outside the MC 0350 plan.

h. Conduct ACRS briefing when requested (NRR). I STATUS: COMPLETE l

I ACRS did not express interest in participating in the CPS restart authorization process but will generically address plant restart from an extended outage.

i. Conduct Commission briefing when requested (NRR).

STATUS: COMPLETE - Commission briefing not requested.

J. Commission concurs In Restart Authorization when required.

STATUS: Complete - Commission concurrence not required. l l

k. Regional Administrator authorizes restart, j i

STATUS: COMPLETE l i This item is considered closed based upon discussion of current status, specific description of actions being taken to complete this item, and Panel agreement to  !

those steps in the 4/20/90 Panel meeting. Final verification is being tracked  ;

outside the MC 0350 plan.

B.6 RESTART AUTHORIZATION NOTIFICATION Notify the applicable parties of the restart authorization.

TASKS

a. Commission (if the Commission did not concur in the Restart Authorization or as requested) (NRR).

STATUS: COMPLETE 16 l

L The EDO's Office will coordinate with the Commission Office on an as needed-basis,

b. EDO (if the EDO did not concur in the Restart Authorization or as requested)

(NRR).

STATUS: COMPLETE The EDO will be consulted by the Regional Administrator as part of the restart authorization process.

c. Congressional Affairs (NRR).

STATUS: COMPLETE NRR will notify Congressional Affairs of CPS restart authorization. This item is being tracked outside the MC 0350 process.

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

STATUS: COMPLETE NRR will notify ACRS of CPS restart authorization. This item is being tracked outside the MC 0350 process.

e. Applicable Federal agencies (NRR).

STATUS: COMPLETE NRR will notify FEMA Headquarters when restart authorization is issued. Region 111 Liaison Officer will notify FEMA Region V when restart authorization is issued.

This item is considered closed and will be tracked outside the MC 0350 process.

f. Public Affairs (Region).

STATUS: COMPLETE A PN and press release have been drafted that will be issued following final restart approval. This item is considered closed and will be tracked outside the MC 0350 process.

g. State and local officials (Region).

STATUS: COMPLETE A PN and press release have been drafted that will be issued following final restart appioval. In addition, the State Liaison Officer will contact the State and 17 l _ - - - - - - - - - - - - - - - - _

s a

L i* Local officials once restart has been approved. This item is considered closed l and will be tracked outside the MC 0350 process.

l h. Citizens or groups that expressed interest during the restart approval process (Region). {

l STATUS: COMPLETE No citizens or groups expressed inferest in notification of plant restart.

C. CASE-SPECIFIC CHECKLIST - PART 11 (ISSUES)

C.1 ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION 1

' The listing of applicable assessment criteria provides the basis for NRC assessment of the effectiveness of the licensee's corrective action plan. j l C.1.1 Event Analysis and Root Cause Assessment i

a. Conditions leading up to and eventually requiring the shutdown, including performance and process concems related to the shutdown, are understood.

i STATUS: COMPLETE i The conditions leading up to the shutdown are thoroughly understood. This was mainly accomplished during the performance of the licensee's ISA. The findings of the ISA were confirmed by the SET.

b. Potential root causes of the conditions requiring the shutdown and any l associated problems were thoroughly evaluated.

STATUS: COMPLtiTE Root causes for the conditions requiring shutdown were thoroughly evaluated and actions were developed to address them in the licensee's PFE. Numerous NRC inspections were conducted to verify that the root causes were adequately addressed. All CSC restart issues were adequately addressed; the completed CSC is attached.

c. The scope of the analysis considered the applicability of related events on similar systems, structures, components, procedures, processes, or activities at CPS and other industry facilities in an attempt to identify trends or generic industry l

concerns.

l STATUS: COMPLETE The deficiencies were assessed for their effect on other similar SSCs. The licensee addressed this issue in its PFE. In addition, CSC restart items were adequately addressed concerning: provide reasonable assurance that 18 L

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l deficiencies affecting SSCs are corrected; resolve issues associated with circuit breaker failures; and provide reasonable assurance that safety-related SSCs will perform their intended functions.

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d. Equipment damage assessment was thorough and comprehenfave, including an assessment of related and adjacent structures, systems, and components.

STATUS: COMPLETE The NRC staff determined that the licensee adequately captured all potentially

, inoperable equipment and all damaged equipment in its damage assessment.

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e. Rationale for rejecting potential root causes was clearly defined and documented

for all root causes evaluated.

1 STATUS: COMPLETE I

l The NRC 40500 cc.rective action verification inspection evaluated the licensee rationale for rejecting potential root causes and found that the licensee's process

( '

was clearly defined. The team also verified that condition reports contained documented rationale for evaluation of identified root causes.

f. The licensee's rationale for terminating the root cause and causal factors analyses was based on a documented process that provided a reasonable basis l for all conclusions reached.

, STATUS: COMPLETE l The NRC 40500 corrective action verification inspection evaluated the licensee's .

rationale for terminating root causes and causal factors analyses. The team l found that terminated root causes were based on a documented process that

! provided a reasonable basis and that all conclusions reached were documented in the associated conddion report.

l- g. The population of potential root causes and their respective evaluations have l been independently reviewed by the licensee's oversight committee.

STATUS: COMPLETE l

The NRC 40500 corrective action verification inspection evaluated the licensee's l population of condition reports and associated potential root causes and their respective evaluations. The team determined that the root cause evaluations and associated condition reports were independently reviewed by the licensee's oversight committee.

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C.1.2 Corrective Action Development

a. The proposed corrective actions are clearly cross-referenced to all of the associated root causes and causal factors they are intended to correct as appropriate.

l STATUS: COMPLETE The licensee developed and implemented its Plan-For-Excellence (PFE) on .

February 19,1998. The NRC Restart Oversight Panel verified that the PFE l clearly cross-referenced the appropriate root causes and causal factors to an appropriate corrective action.-

b. Each of the corrective actions is assigned an appropriate priority based on safety significance to ensure the proper resources and attention are devoted.

STATUS: COMPLETE  ;

The licensee developed and implemented its Plan-For-Excellence (PFE) on February 19,1998. In the PFE, the licensee established priorities for the planned corrective actions as those to be resolved prior to restart, those to be performed in the near term, either before or after restart, and those long-term actions to be performed after restart. The Panel verified that each of the licensee's corrective actions was assigned an appropriate priority and appropriate attention devoted j based on safety significance. . However, the licensee's PFE is outdated. Many due dates for near- and long-term actions not required for restart have either been passed or will not be met. The PFE is in need of an update. A i management meeting will be held shortly after restart to discuss the actions the licensee plans to take to sustain the short term improvement in operator performance recently accomplished and other actions planned for continued performance improvements. I

c. Proposed corrective actions identify the desired conditions to be achieved and are adequate to preclude recurrence.

~

i STATUS: COMPLETE The proposed corrective actions were assessed as being adequate to preclude recurrence of the conditions which led to the plant shutdown.

d. Corrective actions are sufficiently detailed to ensure that all activities related to completion of the corrective action have been identified (i.e., procedure or drawing changes, Technical Specification changes, etc.)

STATUS: COMPLETE

. Corrective actions were reviewed to ensure they were sufficiently detailed to ensure all activities related to the actions were identified.

20

e. Corrective actions include restoring systems and equipment to service and verifying they can perform their intended safety functions through post maintenance or post modification testing.

STATUS: COMPLETE Numerous inspections were conducted to review the actions taken by the licensee to ensure SSCs can perform their intended safety functions. These actions were adequate to ensure equipment will perform as designed,

f. The licensee performed safety evaluations to ensure that corrective actions did not result in loss of safety margin.

STATUS: COMPLETE '

The licensee performed a System Design and Functional Validation (SDFV) review which verified necessary safety evaluations were performed and that adequate safety margin existed.

g. The licensee adhered to applicable industry codes and standards during the development and analyses of corrective actions.

STATUS: COMPLETE All applicable codes and standards were adhered to during the development and analyses of corrective actions.

h. The licensee expanded the scope of the corrective actions to consider all of the causal factors that contributed to the deficiency or problem, including potential generic concerns.

STATUS: COMPLETE ' l The licensee performed an Integrated Safety Assessment which identified numerous deficiencies in all functional areas. Subsequent to the ISA, the licensee conducted the SDFV and the corrective actions to address deficiencies were appropriately expanded.

l. Development of the corrective actions included insights from the organizations or individuals that may have contributed to the event, those responsible for developing the corrective actions, and those responsible for implementing the l ' corrective actions.

l STATUS: COMPLETE

^

The d' evelopment of the licensee's PFE addressed the insights from the l organizations or individuals that may have contributed to the event, those responsible for developing the corrective actions, and those responsible for implementing the corrective actions.

21 .

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J. Interim corrective actions have been developed and documented when permanent corrective action will take an excessive amount of time to implement or cannot be completed before the licensee plans to restart the facility.

STATUS: COMPLETE The licensee developed and implemented its Plan-For-Excellence (PFE) on February 19,1998. In the PFE, the licensee established priorities for the planned corrective actions as those to be resolved prior to restart, those to be performed in the near term, either before or after restart, and those long-term actions to be performed after restart. The Panel verified that each of the licensee's corrective actions was assigned an appropriate priority and appropriate attention devoted based on safety significance. However, the licensee's PFE is outdated. Many due dates for near- and long-term actions beyond restart requirements have either been passed or will not be met. The PFE is in need of an update. A management meeting will be held shortly after restart to discuss the actions the licensee plans to take to sustain the short term improvement in operator performance recently accomplished and other actions planned for continued performance improvements.

k. All corrective actior.s have been incorporated into a comprehensive corrective action plan, which has been approved by the licensee's independent oversight committee.

STATUS: COMPLETE The corrective actions have been incorporated into the PFE which was approved by the independent oversight committee.

C.1.3 Corrective Action Plan Imolementation and Effectiveness

a. Each of the corrective actions is assigned a required start and completion date commensurate with the complexity and safety significance of the action.

STATUS: COMPLETE The licensee devehpe i and implemented its Plan-For-Excellence (PFE) on February 19,1998. !:; the PFE, the licensee established priorities for the planned corrective actions as those to be resolved prior to restart, those to be performed in the near term, either before or after restart, and those long-term actions to be performed after restart. The Panel verified that each of the licensee's corrective actions was assigned an appropriate priority and appropriate attention devoted based on safety significance. However, the licensee's PFE is outdated. Many due dates for near- and long-term actions not required for restart have either Fren passed or will not be met. The PFE is in need of an update. A wanagement meeting will be held shortly after restart to discuss the actions the licensee plans to take to sustain the short term improvement in operator performance recently accomplished and other actions planned for continued performance improvements.

22 i

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b. An organization and individual have been designated with lead lesponsibility for each of the corrective actions.

STATUS: COMPLETE The licensee named a recovery manager with overall responsibility for implementation of the PFE. In additional, all actions were assigned to specific organizations and individuals for lead responsibility,

c. The responsible individual has sufficient authority, resources, and management support to ensure that the action will be adequately completed.

STATUS: COMPLETE The responsible individuals were verified to have appropriate authority,

d. The licensee has defined objectives to be achieved from implementing the corrective action plan, including interim objectives to assess the progress of the plan. The objectives are focused on ensuring a lasting improvement in the operation and maintenance of the plant.

STATUS: COMPLETE The licensee tracked the completion of corrective actions and used performance indicators to evaluate the effectiveness of their actions on an ongoing basis. In the PFE, the licensee established priorities for the planned corrective actions as those to be resolved prior to restart, those to be performed in the near term, either before or after restart, and those long-term actions to be performed after restart. The long-term actions were designed to achieve excellence in performance,

e. Whenever possible, the licensee's objectives are based on a measurable set of criteria that the licensee can readily track and trend, as appropriate, to provide continuous monitoring of the implementation and effectiveness of the corrective action plan. These measures should form the acceptance criteria for closure and provide precursor indication of declining performance.

STATUS: COMPLETE The PFE contained performance measures (where applicable) that were trended by the licensee.

f. The licensee has anticipated and addressed potential conflicts of implementing the corrective action plan with existing facility operational (maintenance, engineering, etc.) practices, regulatory requirements, or personnel activities.

STATUS: COMPLETE I

23 l

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l The licensee's plan includes processes for addressing potential conflicts. None i developed.

g. The corrective action plan contains guidance for the licensee to assess changing i information or conditions to determine whether the licensee must modify the corrective action plan.

STATUS: COMPLETE The licensee modified corrective actions associated with restart items as necessary to address changing conditions. However, the PFE has not been '

updated to reflect new issues since it was issued.

h. The licensee has developed training on both the lessons learned from the event analysis and root cause determination and the technical and administrative changes made to the facilities or practices that includes a discussion regarding why the changes are necessary, STATUS: COMPLETE The licensee completed training of both the lessons learned from the event analysis and root cause determination and the technical and administrative changes made to the facilities. The resident inspectors and an operator re-qualification examination team evaluated the licensee's training plans. The Panel discussed this issue at the April 20,1999, Panel meeting and concluded that the licensee's actions were satisfactory.

i. The corrective action plan includes requirements to have self-assessments, and as necessary, independent assessments, of the implementation and effectiveness of the plan.

STATUS: COMPLETE The PFE requires that each department perform a self-assessment of its performance. The NRC 40500 corrective action verification inspection team evaluated the licensee's self-assessment process and determined that the self- ,

assessment program was in its infancy and needed further evaluation at a later j date. j

j. In cases where long-term actions remain to be accomplished, the licensee has clearly documented when the action will be complete, the basis for the delay in completing the action, and how the action wi!I be tracked and trended to ensure completion.

STATUS: CLOSED in the PFE the licensee established priorities for the planned corrective actions as those to be resolved prior to restart, those non-restart items to be performed in i the near term, either before or after restart, and those long-term actions to be l

24 l

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performed after restart. However, the licensee's PFE is outdated. Many due dates for near- and long-term actions have either been passed or will not be met.

The PFE is in need of an update. A management meeting will be held shortly after restart to discuss the actions the licensee plans to take to sustain the short term improvement in operator performance recently accomplished and other actions planned for continued performance improvements,

k. The licensee has established a predefined time frame following completion of the corrective actioris during which they will continue to monitor the effectiveness of the corrective actiore.

STATUS: COMPLETE The licensee uses performance indicators and other assessment tools to evaluate the effectiveness of its actions. Future use of these indicators will be mcnitored outside of the MC 0350 process.

C.2 LICENSEE SELF-ASSESSMENT AND MANAGEMENT EFFECTIVENESS C.2.1 Self-Assessment Capability

a. Effectiveness of Quality Assurance Program.

STATUS: COMPLETE The NRC 40500 corrective action verification inspection team evaluated the Quality Assurance program and determined that the probing, thorough audits were usually performed by this group.

b. Effectiveness of Industry Experience Review Program.

STATUS: COMPLETE  ;

1 The NRC 40500 corrective action verification inspection team determined that the licensee program for use of industry experience was well developed and effective,

c. Effectiveness of licensee's independent review groups.

STATUS: COMPLETE The NRC 40500 corrective action verification inspection team evaluated the effectiveness of the licensee's independent review groups self-assessment process and determined that the licensee's process was adequate.

d. Effectiveness of deficiency reporting system.

STATUS: COMPLETE 25

The NRC 40500 corrective action verification inspection team evaluated the effectiveness of licensee's deficiency reporting system. The team found the licensee's corrective action program to be minimally adequate to support plant restart.

e. Licensee's staff willingness to raise concerns.

STATUS: COMPLETE The NRC 40500 corrective action verification inspection team evaluated the effectiveness of licensee's deficiency reporting system and the willingness of the CPS staff to raise concerns. The team found that the staff was willing to raise concerns and that the condition reporting system was effectively used by the staff.

f. Effectiveness of PRA usage.

STATUS: COMPLETE The NRC residents and regional based inspectors evaluated the licensee's risk

assessment process. The inspectors reviewed the licensee's program for outage l and on-line maintenance activities, training provided to CPS operations personnel l and work management, and the licensee's thresholds for contingency planning.

The inspectors found the licensee's process to be adequate.

l l

g. Effectiveness of commitment tracking program.

i STATUS

COMPLETE  !

l The NRC 40500 corrective action verification inspection team evaluated the l licensee's tracking program and found that it was effective in monitoring progress of corrective actions associated with the PFE, condition reports, industry l

experience reports, and self-assessment findings.  ;

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h. External audit (i.e., INPO) capability.

STATUS: COMPLETE The licensee used peer checks from INPO evaluators regularly during the shutdown. In addition, numerous resources have been provided from the PECo organization to mentor and audit programs. A full INPO audit is scheduled for August 1999.

i. Quality of 10 CFR 50.72 and 50.73 reports.

STATUS: COMPLETE The quality of these reports varied. In one instance, a revision to a 50.73 report was necessary after NRC review determined that inaccurate information was 26

l contained in the initial report. However, in general, the reports provided by the licensee were accurate and adequate to describe the respective events.

C.2.2 Manaaement Oversioht and Effectiveness

a. Goals and expectations communicated to ar$J understood by the staff.

STATUS: COMPLETE The management team has communicated eipectations for individual and organizational performance to all levels in a variety of forums. However, the licensee has not been consistently successful in instilling a nuclear safety work ethic that is understood at alllevels of the organization. Often, when assessing the overall performance of the organization, plant workers tend to compare current performance to their previous performance rather than to the standards of excellence set as a performance goal by plant management.

b. Demonstrated expectation of adherence to procedures.

STATUS: COMPLETE The NRC team inspections (SSEl, Maintenance Rule implementation,40500 corrective actions verification, emergency preparedness, and operational readiness) were chartered by the Restart Oversight Panel to evaluate, among other things, the licensee staffs adherence to procedures. In addition, the resident inspectors routinely observed licensee's activities and evaluated licensee adherence to procedures. Strict procedural compliance has been emphasized by licensee management and plant staff generally understand the expectations. Procedural adherence has significantly improved at the station.

c. Management involvement in self-assessment and independent self-assessment capability.

STATUS: COMPLETE The 40500 team inspection evaluated the licensee's self-assessment processes )

and determined that the processes were adequate.

. d. Effectiveness of management review committees.

STATUS: COMPLETE The 40500 team evaluated the licensee's management review committees and l determined that the committees were effective in ensuring safe routine day-to-day activities'.

e. - Management's demonstrated awareness of day-to-day operational concems.

STATUS: COMPLETE 27 g

Plant management has been closely involved with day-to-day operational concems and, recently, has intervened when necessary to address arising concerns.

f. Management's ability to identify and prioritize significant issues.

STATUS: COMPLETE The management team in place has acknowledged the performance problems and is committed to addressing identified issues. Progress has been made in addressing the issues through the development and implementation of the PFE.

Plant management has taken actions, such as site-wide standdowns, to address performance deficiencies and to implement further improvement initiatives when needed.

g. Management's ability to coordinate resolution of significant issues.

STATUS: COMPLETE Plant management has ensured steady progress has been made towards addressing the restart issues. Some of these issues have been complex technical issues, such as degraded voltage, which have been effectively addressed.

h. Management's ability to implement effective corrective actions.

STATUS: COMPLETE Although many corrective action program deficiencies were identified during

. recent inspections conducted to assess the licensee's readiness to restart the plant, the corrective action program is considered adequate to support plant restart. As a result, the DFl conceming the licensee's corrective action program was closed inspections are neeriod after restart to ensure the existing deficiencies are addressed and do not develop into more significant programmatic concems.

C.2.3 Manaaement Support

a. Impact of any management reorganization, with new responsibilities clearly defined and understood.

STATUS: COMPLETE l

The licensee has effectively incorporated many new management members into its organization and responsibilities of the individuals were generally clearly understood.

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b. Effective and timely resolution of employee concerns.

STATUS: COMPLETE The NRC 40500 team was chartered by the Restart Oversight Panel to evaluate the licensee's effectiveness and timeliness of resolving CPS employee's concerns. The team determined that the licensee's employee concern program was adequate.

c. Adequate engineering support as demonstrated by timely resolution of issues.

STATUS: COMPLETE l l l The NRC SSEl and 40500 teams were chartered by the Restart Oversight Panel l l to evaluate, among other things, the licensee's engineering organization support for issue resolution. The teams determined that the licensee's support was l improved and that significant issues with circuit breakers, recirculation pump seals, degraded voltage issues, and emergency diesel generators were effectively resolved. However, there were many instances where the engineering organization's support to operations was inadequate.

d. Adequate plant administrative procedures.

STATUS: COMPLETE The licensee's procedures are generally adequate; however, the licensee did not assess the large procedure change backlog (about 3,000) until prompted by inspectors. During the review, approximately 170 procedures were required to be revised prior to restart to include needed technical changes.

e. Effective information exchange with other utilities.

STATUS: COMPLETE The licensee contracted PECo to provide management services for implementing the PFE and preparations for CPS restart. This has resulted in effective exchange with other utilities. The licensee has been in contact with other utilities who have had units in an extended shutdown condition and has incorporated lessons learned into its processes.

f. - Effective participation in industry groups.

STATUS: COMPLETE The licensee has been effective in participating in industry groups.

g. Effectiveness of Emergency Response Organization.  ;

STATUS: COMPLETE 29

The Restart Oversight Panel chartered an emergency preparedness inspection to evaluate the effectiveness of the licensee's emergency response organization.

The team evaluated the licensee's March 1999 emergency drill and determined that the emergency response organization was adequate.

C.3 ASSESSMENT OF PLANT AND CORPORATE STAFF EFFECTIVENESS C.3.1 Assessment of Staff

a. Demonstrated commitment to achieving improved performance.

STATUS: COMPLETE The management team in place has acknowledged the performance problems and is committed to addressing identified issues. Progress has been made in addressing the issues through the development and implementation of the PFE.

Plant management has taken actions, such as site-wide standdowns, to address performance deficiencies and to implement further improvement initiatives when needed.

b. Demonstrated safety consciousness.

STATUS: COMPLETE Management has demonstrated safety-consciousness when addressing plant events. Expectations have been reinforced to the plant staff during standdowns and by other means. However, plant operators have used non-conservative decision-making when conducting work on occasions.

l

c. Understanding of management's expectations and goals.

STATUS: COMPLETE l

The management team has communicated expectations for individual and organizational performance to all levels in a variety of forums. However, the licensee has not been consistently successful in instilling a nuclear safety work l ethic that is understood at alllevels of the organization. Often, when assessing

! the overall performance of the organization, plant workers tend to compare current performance to their previous performance rather than to the standards of excellence set as a performance goal by plant management.

d. Understanding of plant issues and corrective actions. j STATUS: COMPLETE Although all issues were eventually satisfactorily addressed by the licensee to support plant restart, a recurring theme for many of the closure packages for the !

restart items presented to the NRC during the review process was that comprehensive plans to address the items were developed but not all aspects of 30

T I

the plans had been sufficiently implemented to warrant closure of the items.

Some items, most notably the development of a program to reduce main control room deficiencies, were been reviewed several times but were not ready to be closed. The result of this was the deferral of severalitems to the last three team inspections prior to restart and the need for further review of some of these items 1 after the team inspections were completed. In some instances, NRC involvement was necessary before the licensee developed and implemented the necessary ,

corrective actions. I

e. Qualification and training of the staff. J STATUS: COMPLETE  !

The Restart Oversight Panel chartered the license re-qualification examination team and the operational readiness inspection team to evaluate the qualification and training of CPS's staff. The teams determined that the licensee's staff was adequately trained and qualified to ensure a safe restait of CPS.

f. Staff's fitness for duty.

STATUS: COMPLETE The Panel determined that fitness for duty or attentiveness to duty were not contributing factors to the circumstances that led to the extended shutdown of CPS; therefore, inspection or verification of these issues was not required.

g. Attentiveness to duty.

STATUS: COMPLETE The Panel determined that fitness for duty or attentiveness to duty were not l contributing factors to the circumstances that led to the extended shutdown of l CPS; therefore, inspection or verification of these issues was not required.

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h. Level of attention-to-detail.

STATUS: COMPLETE Although attention-to-detail was a minor contributing factor to the circumstances that led to the extended shutdown of CPS, the Panel determined that separate inspection of this issue was not required.

l. Off-hour plant staffing.

STATUS: COMPLETE j The Panel determined that off-hours plant staffing and overtime usage were not contributing factors to the circumstances that led to the extended shutdown of CPS; therefore, inspection or verification of these issues was not required.

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j. Staff overtime usage.

STATUS: COMPLETE I i

The licensee has generally complied with overtime usage requirements.

However, it was identified that routine, heavy use of overtime was assigned to all Fix-it-Now team members in an effort to reduce the large maintenance item backlog.

k. Procedure usage / adherence.

STATUS: COMPLETE Strict procedural compliance has been emphasized by licensee management and plant staff generally understand the expectations. Procedural adherence has significantly improved at the station.

l. Awareness of plant security.

STATUS: COMPLETE The Panel determined that awareness of plant security was not a contributing factor to the circumstances that led to the extended shutdown of CPS; therefore, inspection or verification of this issue was not required.

m. Understanding of offsite emergency planning issues.

{

STATUS: COMPLETE No offsite emergency planning issues were identified.

l C.3.2 Assessment of "Coroorate" Sucoort 1

lilinois Power does not have a typical corporate support organization. Therefore, the Panel concluded that an assessment of the corporate support to CPS was not necessary for restart.

C.3.3 Operator issues

a. Licensed operator staffing meets requirements and licensee goals.

STATUS: COMPLETE The Restart Oversight Panel chartered the license re-qualification examination team and the operational readiness inspection team to evaluate the qualification and training of CPS's staff. The teams determined that the licensee's staff was J adequately trained and qualified to ensure a safe restart of CPS.

I 32 I l

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b. Level of formality in the control room.

STATUS: COMPLETE Several violations were recently identified regarding the conduct of operations in the control room. The licensee took immediate corrective actions to address these issues and improvements were subsequently noted. The details of this issue are documented in IR 50-461/99006.

I

c. Effectiveness of control room simulator training. '

STATUS: COMPLETE 4 in the fourth quarter of 1998, a significant number of licensed operators failed their requalification testing. Simulator training problems were a contributing factor. The licensee implemented corrective actions and improvement in this area has been noted.

d. Control room / plant operator awareness of equipment status STATUS: COMPLETE There have been many observatons by NRC inspectors that indicate operators where not aware of equipment etatus. Improvements were noted in this area and a restart item (CSC ltem ll.1) cot:cerning operator awareness of plant conditions was closed. This area will continue to be monitored outside of the MC 0350 process.

e. Adequacy of plant operating procedures.  !

STATUS: COMPLETE Plant operating procedures have been reviewed and the necessary changes  ;

have either been incorporated or will be prior to the respective procedure's next  !

use. The licensee has adequately addressed this issue (CSC item II.3) and it was closed as a restart issue. However, this area will continue to be monitored outside of the MC 0350 process.

f. Procedure usage / adherence.

STATUS: COMPLETE Strict procedural compliance has been emphasized by licensee management and plant staff generally understand the expectations. Procedural adherence has significantly improved at the station 33

p 1 4

l C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT

a. Operability of technical specification systems.

STATUS: COMPLETE l

~ A restart readiness inspection was conducted in March and April,1999. Mode change restraints were still in place. This item will be tracked outside the l MC 0350 process.

b. Operability of required secondary and support systems.

STATUS: COMPLETE A restart readiness team inspection was conducted in March and April,1999.

Mode change restraints were still in place. This item will be tracked outside the MC 0350 process.

c. Results of pre-startup testing.

STATUS: COMPLETE l

The licensee conducted pre-startup testing with no major problems encountered. i

d. Adequacy of system lineups.

STATUS: COMPLETE 1

The Restart Oversight Panel chartered the NRC startup coverage inspection team to verify that the licensee adequately restored systems required for startup.

! This inspection was assigned on April 20,1999, during the Panel's review of the

licensee's readiness for restart. This item will be tracked outside of the MC 0350 i process. j

e. Adequacy of surveillance tests / test program.

STATUS: COMPLETE The resident inspectors verified that the licensee's surveillance testing program

, was satisfactory and documented their findings and conclusions in inspection  ;

Report 50-461/99006.

l f. Significant hardware issues resolved (i.e., damaged equipment, equipment aging, modifications).

STATUS: COMPLETE <

The Restart Oversight Panel determined on April 20,1999, that CPS was ready for restart, including resolution of all significant hardware issues.

34

Restart Plan Case-Specific-Checklist Cross-Reference CSC ltem IV.2 - Resolution of Deficiencier with SSCs CSC ltem IV.3 - Circuit Breakers CSC ltem IV.4 - Degraded Voltage issues CSC ltem IV.5 - Resolution of Fire Protection Safe Shutdown Concerns CSC item IV.6 - Resolution of Recirculation Pump Seal Issues CSC item IV.7 - Resolution of Emergency Diesel Generator issues

g. Adequacy of the power ascension testing program.

STATUS: COMPLETE The program was reviewed during the operational readiness inspection with no major problems identified. Power ascension testing will be observed outside of the MC 0350 process.

h. Effectiveness of the plant maintenance program including scheduling and work control.

STATUS: COMPLETE Recent problems were identified with the work control / operations interface and

, were documented in IR 50-461/99006. The licensee implemented improvement l initiatives which were effective in improving performance in the near term.

However, it is not clear that these improvements can be sustained. This item will continue to be tracked outside the MC 0350 process.

i. Maintenance backlog managed and impact on operations assessed.

i STATUS: COMPLETE r The maintenance backlog was assessed by PRA specialists in the NRC and l determined to be appropriately prioritized. It appeared that there should be

minimal impact from the maintenance backlog on plant operations.

l C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS

a. Applicable license amendments have been issued.

STATUS: COMPLETE All license amendments have been issued. The following License Amendment (LA) changes were issued:

Under Voltage relay set point LA issued on March 26,1999.

Valve 1MC-042 leak test deferral LA issued on March 8,1999.

Emergency Diesel Generator (EDG) starting voltage and frequency LA issued on January 20,1999.

35

Division 3 EDG ready-to-load requirement LA issued on January 20,1999.

Extension of thermo-lag modifications completion date issue on December 23,1998.

EDG reduced load testing LA issued on December 14,1998.

Static-VAR-Compensator installation LA issued on October 9,1998.

New Emergency Reserve Auxiliary Transformer, automatic operation during shutdown LA issued on October 1,1998.

Leak test deferral for 21 valves, ASME relief issued on October 6,1998. j Review of Clinton Management Services Agreement issued on August 7,1998.  !

b. Applicable exemptions have been granted.

STATUS: COMPLETE  !

No exemptions were requested. j

c. Applicable reliefs have been granted.

l STATUS: COMPLETE All applicable reliefs were granted with the appropriate LA. The following relief was granted and issued:

Valve 1MC-042 leak test deferral LA issued on March 8,1999.

Extension of thermo-lag modifications completion date issue on . j December 23,1998.

Leak test deferral for 21 valves, ASME relief issued on October 6,1998.

d. Imposed orders have been modified or rescinded.

STATUS: COMPLETE I No orders were issued.

e. Confirmatory Action Letter conditions have been satisfied.

STATUS: COMPLETE The NRC issued Confirmatory Action Letters (CALs) Rlli-96-013 on September 11,1996; Rlll-97-001 on January 9,1997; Rill-97-006 on June 9, 1997; and Rlli-97-009 on August 6,1997. CALs Rill-96-013 and Rlll-97-001 addressed specific issues stemming from the September 5,1996, reactor recirculation pump sealleakage event. CAL Rlll-97-006 addressed degraded containment coating. CAL Rlll-97-009 addressed circuit breaker issues stemming from the August 5,1997, circuit breaker failure. All CALs are closed.

CALS Rlll-96-013,97-001, and 97-006 were closed in a letter from A. Bill Beach, Region Administrator, Region lll to John G. Cook, Senior Vice President, IP, dated August 4,1997. CAL Rill-97-009 will be closed in a letter from Jim Dyer, Regional Administrator, Region lll to John McElwain, Chief Nuclear Officer, prior to restart.

36 l

l L

The NRC issued a Demand for Information (DFI) on September 26,1997. The DFl pertained to IP's continued deficiencies in its corrective action program and the NRC's concern that these deficiencies affected the ability of safety-related structures, systems, and components to perform their intended functions. The DFl will be closed in a letter from Jim Dyer, Regional Administrator, Region lli to John McElwain, Chief Nuclear Officer, prior to restart.

f. Significant enforcement issues have been resolved.

STATUS: COMPLETE All significant enforcement issues associated with the circumstances that led up to the extended shutdown of CPS were resolved prior to chartering the Restart Oversight Panel and prior to the development of the current NRC Restart Action.

Plan

g. Allegations have been appropriately addressed.

STATUS: COMPLETE All allegations affecting the restart of CPS have been closed.

i

h. 10 CFR 2.206 Petitions have been appropriately addressed.

STATUS: COMPLETE The NRC did not receive 10 CFR 2.206 petitions for CPS restart. I

i. Atomic Safety and Licensing Board hearings have been completed.

STATUS: COMPLETE The Atomic Safety and Licensing Board did not request to participate in the restart authorization approval for CPS.

C.6 COORDINATION WITH INTERESTED AGENCIES AND PARTIES Coordination with other interested agencies and parties is important to ensure that concerns and requirements of these organizations are factored into the restart authorization. Only the Federal Emergency Management Agency was established as an interested federal agency for CPS restart.

l l a. Federal Emergency Management Agency (FEMA).

l STATUS: COMPLETE 37

l FEMA Headquaders faxed NRR an internal memorandum generated by FEMA Region V personnel to FEMA Headquarters as a basis for indicating FEMA did not have any restart objections for Clinton Power Station.

b. Environmental Protection Agency (EPA).

STATUS: COMPLETE The EPA did not establish interest in the restart authorization of CPS. No action is required.

c. Department of Justice.

STATUS: COMPLETE The Department of Justice did not establish interest in the restart authorization of CPS. No action is required,

d. Department of Labor.

STATUS: COMPLETE The Department of Labor did not establish interest in the restart authorization of CPS. No action is required.

e. Appropriate State and local officials.

STATUS: COMPLETE A PN and press release have been drafted that will be issued following final restart approval. This item is considered closed and will be tracked outside the MC 0350 process. The State Liaison Officer will notified the appropriate state and local officials of the restart authorization of CPS.

f. Appropriate public interest groups.

STATUS: COMPLETE The Region 111 office provided a press release notifying the public of the restart authorization of CPS.

g. Local news media, STATUS: COMPLETE A PN and press release have been drafted that will be issued following final restart approval. This item is considered closed and will be tracked outside the MC 0350 process.

1 1

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