ML20206M822

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Restart Assessment Plan Millstone Station
ML20206M822
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 05/10/1999
From: Lanning W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206M814 List:
References
PROC-990510, NUDOCS 9905170059
Download: ML20206M822 (42)


Text

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RESTART ASSESSMENT PLAN MILLSTONE STATION I / / j14 hW APPROVED BY: WAYNE D. LANNING, DIRECYO MILLSTONE INSPECTION DIRECTORATE, REGION I hlatA 10, l999 DATE: 9905170059 990510 PDR ADOCK 0500024S P FDR u .------------- w-----u--- -

l MILLSTONE RESTART ASSESSMENT PLAN

1.0 BACKGROUND

Unit 1 shut down to begin its cycle 15 refueling outage (RFO 15) on November'4, 1995. - Unit 2 shut down on February 20,1996, when both trains of the high' - pressure safety injection system were declared inoperable because of excessive suction strainer hole sizes in the containment sump screens. Unit 3 was shut down - on March 30,1996, because of inoperable containment isolation valves in the auxiliary feedwater system. All three Millstone units remained shut down to formulate responses to a series of 10 CFR 50.54(f) letters requiring them to affirm - their compliance with the conditions of each unit's license and the regulations. Following the June 1996 Senior Management Meeting (SMM), the Executive Director for Operations (EDO) issued a letter to the licensee on June 28,1996. The letter stated that the Commission had decided to make each of the three Millstone units a Category 3 plant on the Watch List, which would require a Commission vote prior to restarting each unit. When it became apparent that the units would remain shutdown for an extended ( period, the NRC determined that a coordinated approach to restart approval would - l be required. Hence, the NRC imposed the restart controls of Manual Chapter 0350 (MC 0350), " Staff Guidelines for Restart Approval," which included developing a i Restart Assessment Plan (RAP) to consolidate all of the NRC restart issues, including the salient aspects of MC 0350. The licensee initially focused on Unit 3 as the lead plant for restart. However, as a result of a licensee reorganization which occurred on October 1,1996, each unit .) was assigned a recovery manager who was an executive on temporary loan from another nuclear utility. Resources originally assigned to Unit 3 from the other units were returned to their respective units. Each unit was tasked with establishing their own restart plan, and whichever unit was ready, would apply for restart first. -q The NRC has dealt with the licensee on broader performance issues that went beyond the 10 CFR 50.54(f) concerns. These broader concerns were considered contributory causes for the poor performance, of which the 10 CFR 50.54(f) issues were a subset. These issues were formalized by the licensee in a program titled " Improving Station Performance" (ISP) and were topics that were addressed by the licensee and reviswed by the NRC. The salient concerns embodied in the ISP-included leadership, communications (employee concerns), the corrective action program, procedural adherence and procedure upgrades, work planning and control, and operational enhancements. -The RAP was written to focus on the broader issues of the ISP, licensee self-assessments and management oversight, recognizing the necessity to ensure adequate closure of the 10 CFR 50.54(f) process. J e o

On November 3,- 1996, the NRC created a new organization, the Special Projects Office (SPO) within the Office of Nuclear Reactor Regulation (NRR), to provide a specific management focus on licensing and inspection activities required to support ' an NRC decision on restart of the Millstone units. The Director of SPO assumed the authority and responsibilities of the Regional Administrator for Millstone and the Associate Director of Projects, and reported to the Director of NRR. Over the next year and a half, the licensee's recovery efforts focused on instilling higher standards for operations, developing effective corrective action programs, revitalizing quality assurance practices, regaining employee confidence in; management, and completing 10 CFR 50.54(f) efforts. This recovery effort was a major undertaking by the licensee. On June 15,1998, the Commission provided its restart authorization for Unit 3. Accordingly, the Watch List status of Unit 3 was changed from Category 3 to. Category 2, and the EDO was designated as the senior manager responsible for approving commencement of actions to restart Unit 3. By letter dated June 29, 1998, the EDO authorized the licensee to commence activities to restart Unit 3, and it started up on June 30,1998. Following the NRC's approval to allow restart of Millstone Unit 3, a staff requirements memorandum dated July 15,1998, eliminated SPO, and assigned Millstone oversight responsibilities to NRR and Region 1. Inspection activities were assigned to the Millstone Inspection Directorate reporting to the Region I Administrator, while licensing activities were returned to the NRR projects ~ organization. On July 21,1998, the licensee submitted a letter stating their decision to cease operations at Millstone Unit 1. The Commission subsequently directed the staff to no longer list Millstone Unit 1 as a Category 3 facility. During a Commission meeting on April 14,1999, the staff provided its assessment that the licensee had taken appropriate corrective actions to support restart of Millstone Unit 2. On April 28,1999, the Commission provided its restart authorization and the EDO was designated as the senior manager responsible for approving commencement of Unit 2 restart activities. By letter dated April 29, 1999, the EDO authorized the licensee to commence activities to restart Unit 2. 2.0 10 CFR 50.54(f) ACTIVITIES Each Millstone unit was requested to submit information describing _ actions taken to ensure that future operations would 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 the licensee to provide its plan for completing the licensing bases reviews for each unit. To. aid the NRC in understanding how deficiencies were identified and dispositioned, the-NRC's May.21,1996,. letter also requested the licensee to provide for each .A

r l 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 requiring the licensee to - 4 obtain the services of a third party to conduct an Independent Corrective Action Verification Program (ICAVP) for each unit. Section IV.1 of the Order required the ICAVP to be completed for each unit, to'the satisfaction of the NRC, prior to each unit's restart. Prior to commencing the ICAVP, the licensee _ completed its own review, the Configuration Management Plan (CMP), to reestablish the design and licensing bases for all of the Unit 3 and Unit 2 Maintenance Rule (10 CFR 50.65): Group 1 and Group 2 systems. The subsequent development and implementation of the ICAVP, designed to verify the CMP results, involved an extensive level of effort.- Sargent & Lundy was selected by the licensee and approved by the NRC to conduct the ICAVP at Unit 3. In a June 17,1998, letter to the licensee, the NRC indicated that Sargent & Lundy had conducted the ICAVP at Unit 3 to the satisfaction of the NRC. Parsons was selected by the licensee and approved by the NRC to conduct the ICAVP at Unit 2. During an April 14,1999, Commission meeting, Parsons indicated that it had completed all of the reviews required by the NRC-approved ICAVP Audit Plan and implementing procedures, and the NRC indicated that the ICAVP had been performed satisfactorily at Unit 2. A summary of the NRC staff's ICAVP oversight efforts is provided in SECY-99-109, " Recovery of Millstone Nuclear Power Station, Unit 2," dated April 9,1999. With the completion of the ICAVP at Unit 3 and Unit 2 to the satisfaction of the NRC, and the staff's determination that an ICAVP was no longer necessary at Unit 1 due to its permanent shutdown, the staff has determined in a letter dated April 27, 1999 that all of the conditions required by the ICAVP Order have been satisfied. 3.0 INSPECTION MANUAL CHAPTER 0350 PROCESS As part of its execution of MC 0350, the NRC developed a Restart Assessment Plan (RAP). The RAP was developed to include all expected NRC actions required before the NRC would approve plant restart. The staff developed the RAP to incorporate i the appropriate aspects of MC 0350, and to address site-specific and unit-specific issues. Revision 5 to the RAP, sent to the licensee in a letter dated September 4, 1998, closed out the restart assessment process for. Units 1 and 3. With the issuance of Revision 7 to the RAP, the Unit 2 restart assessment process is now complete, as detailed below.

3.1 Background

The Unit 2 RAP contained several major elements that required resolution before Unit 2 restart. These elements included corrective' action program improvements,

p 4 work planning and control improvements, procedure upgrade programs,' and oversight and quality assurance improvements. The RAP also included staff a activities to evaluate the completion of the licensee's ICAVP, and the licensee's i response to the NRC's 10 CFR 50.54(f) letter.regarding Unit 2. The actions listed in the MC 0350 restart checklist that were applicable to Unit 2, such as those - regarding management effectiveness and self-assessment capability, were also included in the RAP. The RAP also provided for the conduct of an Operational Safety Team inspection (OSTI), and a 40500 Team inspection. These inspections were normally carried out to assess the overall readiness of a plant for restart after-a prolonged shutdown, and were performed at Unit 3. y 3.1 Millstone Restart Assessment Panel The purpose of a restart assessment panelis to focus NRC resources within one group to assess a licensee's overall performance and progress in completing designated restart activities. The specific duties of a restart assessment panel are described in MC 0350. When it was decided that the Millstone station would be subject to the MC 0350 restart process, the Millstone Oversight Team (MOT) was formed to serve as the - restart assessment panel. The MOT was comprised of the Deputy Director, Division of Reactor Safety (Chairman); the NRR Project Directorate; three Project Managers for the Millstone units; the Region i Division of Reactor. Projects Branch Chief, three. Senior Resident inspectors for the Millstone units, and an appointed Division of Reactor Safety representative. Whan the SPO was created on November 3,1996, the MOT was superceded by the Millstone Restart Assessment Panel (Panel). The Panel was composed of the Director, SPO (Chairman); three Deputy Directors of Licensing, inspections, and independent Corrective Actions Verification Program Oversight; three Project Managers for the Millstone units; the Region i inspection Branch Chief, three Senior - Resident inspectors for the Millstone units, and an appointed Division of Reactor Safety representative. When the SPO was eliminated on July 15,1998, and when the licensee submitted a letter stating their decision to cease operations at Millstone Unit 1 on July 28, 1998, the composition of the Panel was altered. The Penel is currently comprised of the Director, Millstone inspection Directorate (Chairman); the NRR Project Directorate; two Project Managers for Millstone Units 2 and 3; the Region I Branch Chief, and two Senior Resident inspectors for Millstone Units 2 and 3.- The Panel will remain in effect for some period of time following the restart of _ Millstone Unit 2, in order to maintain heightened awareness of the Millstone Station. i-.

~ 5 3.2 Millstone Operational Readiness Plan On July 2,1996, the licensee submitted the Unit 3 Operational Readiness Plan. The Plan provided the process the licensee would use to return Unit 3 to operation. However, when the licensee reorganized on October 1,1996, the submitted Plan for Unit 3 needed to be changed substantially. A revision to the Unit 3 Plan was subrnitted to the NRC, inc,luding subsequent revisions. These revisions were reviewed by the Panel, after which meetings would be held with the licensee, open to the public, to discuss the schedule for implementation and coordination of NRC restart activities. The NRC also held periodic meetings directly with the public to obtain their comments concerning the Plan and to answer questions. An important aspect of the Plan was the deficiency list, which included restart and deferred items. These deferred items were audited by the NRC to verify the acceptability of the criteria used to defer items from the restart list. Prior to restart - of Unit 3, the Panel held conference calls with the licensee at least twice a week to discuss readiness for restart, deferred items, and the resolution of emerging technical issues. Since restart of Unit 3, meetings have mainly focused on Unit 2 restart activities. Additionally, the frequency of public meetings were reduced to one per quarter or j when milestone updates were appropriate. In a letter dated January 8,1998, the licensee provided their criteria used to decide whether an item needed to be completed prior to restart; these criteria were used to develop the t' nit 2 deferred items list that was submitted to the NRC on December 1,1998. subsequent letter dated December 22,1998, the licensee modified i their critenu aased in part on lessons learned from Unit 3, and findings from their corrective action program; these new criteria were used to develop the Unit 2 deferred items list submitted to the NRC on March 5,1999. On December 22,1998, the licensee provided the NRC with a Unit 2 Restart Backlog Management Plan, which was an integrated, structured approach to successfully manage and disposition the backlog of identified open items at the time of Unit 2 restart. in this plan, the licensee described its methodology, process, goals, commitments, and key performance indicators to effectively manage and trend performance. As part of this plan, the licensee also committed to provide the NRC with quarterly backlog management updates. The licensee submitted a letter dated February 5,1999, which described their processes and programs to ensure future operations at Unit 2 will be conducted in accordance with its license and FSAR, and the NRC's regulations. 1 The NRC reviewed the December 1,1998, deferred items list. The staff concluded that the licensee's decision-making process for the identification of items to be j completed after Unit 2 restart was accurate and thorough. In addition, the NRC did not identify any items thatiif not corrected prior to plant restart, would have resulted in a significant safety concern during plant operations. The NRC also noted

7 t; e that the licensee's process for developing the deferred items list had been revised to correct completeness and accuracy problems that were identified during an earlier r NRC review of the Unit 2 and Unit 3 deferred items lists in late 1997. The OSTI reviewed the March 5,1999, deferred items list and the Unit 2 Restart Backlog Management Plan. The OSTI concluded that the licensee's process for deferral contai'ned appropriate methodology for the identification of items acceptable for deferral and completion after the restart of Unit 2. Moreover, the OSTl did not identify any items that if not completed prior to restart, would have an adverse impact on the safe restart of Unit 2. The OSTI also concluded that the. licensee's Backlog Management Plan was adequate. In a letter dated March 30,1999, NNECO submitted a change to their commitments previously provided to the NRC concerning backlog management at Units 2 and 3. The licensee's revised commitment is to complete disposition of ICAVP discrepancy - report (DR) corrective actions by March 31,2000 for Unit 3 and December 31, 2001 for Unit 2. The remaining recovery backlog items would continue to be prioritized and tracked within the appropriate controlling program. The licensee stated their adjustment was appropriate in that it will allow a continued focus on safe, event free operation of the unit rather than focus on those backlog items that-are not safety significant. The basis for this change appears to be appropriate; given the licensee's efforts in the assessment of both the safety significance of the - items that have been deferred, as well as the overallimpact the backlog management plan would have on the continued safe, event-free operation after restart. The licensee's management of the Unit 2 and Unit 3 backlog will be assessed as part of the routine inspection program during quarterly backlog management updates provided by the licensee, and during enhanced corrective action team inspections. 3.3 Corrective Action Program Previous licensee self assessments and NRC inspections had found that the licensee'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 relation also existed between the ineffectiveness of the corrective action program and the issues related to the handling of employee safety concerns at Millstone. An important element in an ) effective corrective action program is encouraging workers to raise issues willingly without fear of retribution or retaliation. 1 "The licensee initiated efforts in early 1997 to improve the corrective action program by adopting industry standards and processes and formalizing them in procedure RP-4, " Corrective Action Program." The improvements included a lower threshold for' . reportable problems, more management emphasis on the need for employees to 3 ......w.. ............-. i.. m&

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. To verify the effectiveness of the licensee's actions, supplementing the day-to-day. observations and interactions of the resident inspectors, the staff performed a number of multipurpose inspections to assess the effectiveness of the process. The staff looked at the effectiveness and the appropriateness of the licensee's corrective actions for design concerns raised by the NRC in its ICAVP-related inspections, by the licensee in its CMP, and by' Parsons in its ICAVP. The NRC performed a 40500 Team inspection at Unit 2 in late January and early February 1999, which looked at the overall effectiveness of the corrective action program. The 40500 Team Inspection also gained insights into the effectiveness of the implementation of the corrective action program by assessing a sample of employee concerns case files and documentation packages to determine the level of use of the process and whether it was effective in responding to potential nuclear safety issues or potential employee protection issues. The NRC also performed an OSTI at Unit 2 in March 1999, which in part, inspected the implementation of the corrective action program to determine if it was adequate to support plant restart. Resident inspection reports provided an assessment of corrective actions taken to-resolve inspcctor concerns that were identified as part of the NRC core inspection program. In addition, the resident inspection reports documented NRC assessments of corrective actions to address many of the safety significant restart issues contained in the Unit 2 Significant items List (SIL). The fact that each Unit 2 SIL item was inspected and found to be acceptably addressed, provided examples that indicated line management demonstrated the ability to correct significant technical concerns. During ICAVP inspections, the NRC concluded that the licensee had an acceptable corrective action program that adequately resolved not only specific ICAVP-related issues, but adequately addressed the extent of condition. The NRC further concluded that the licensee's corrective action program was being adequately implemented and that they were taking adequate and timely. corrective action to resolve ICAVP issues necessary to restore the licensing bases and support Unit 2 restart. The 40500 Team and OSTI concluded that the Unit 2 corrective action program is an effective process for addressing significant plant issues. The problem identification threshold was observed to be low, with a high volume of items being generated and processed on a daily basis. A review'of the root cause evaluations for more significant problems found them to be generally thorough and the { corrective actions appropriate and timely. Corrective action assignments and ] + prioritizations were observed to be proper and well tracked.- ECP cases involving { technical and nuclear safety issues requiring corrective actions were appropriately recognized and processed by ECP, and the eventual corrective actions were { responsive to the concerns raised. The Condition Reports and Action Requests that ] .I o

1 l 8 were required to be addressed prior to restart have been identified and are being tracked for completion. 3.4 Work Planning and Controls 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 element in achieving timely and effective corrective actions. Additionally, effective work planning and controls are prerequisites for reducing and managing work backlogs. The NRC 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 is instrumental in establishing the scope of the work, providing the appropriate procedures, and establishing the tagging boundaries. This process has resulted in a noticeable improvement over previous processes at Millstone. The 40500 Team concluded that implementation of a new work control process (12 week rolling schedule), when considered together with the work associated with the Unit 2 restart and upcoming Unit 3 refueling outage, represented a significant continuing challenge. The OSTI included an in-depth assessment of the adequacy of the licensee's work planning and controls. The principal focus of this assessment was to evaluate the adequacy of the licensee's program as it relates to ensuring the safety performance of personnel and plant equipment. The OSTI found that work planning package quality was acceptable. However, emergent work was preventing accurate scheduling and planning such that plant schedule goals were not being met during this inspection. As a result, the licensee was in the process of improving the work planning process. 3.5 Procedure Upgrade Program The quality of and adherence to procedures had been a chronic problem for all three Millstone units. The need to improve procedure quality was an element in the Improving Station Performance program (circa 1995) and the earlier Performance Enhancement Program (circa 1992). In response to NRC concerns, 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 included in a letter to the NRC dated June 4,1992, in which the licensee described its overall Performance Enhancement Program. Because of the licensee's longstanding commitment to complete the PUP and address past procedure adherence and quality problems, the satisfactory performance of the licensee's PUP was identified as a separate issue in the Unit 2 RAP. Although various procedure improvement programs had been ongoing since the late 1980s, the licensee committed to improve procedures to reflect industry standards

9 for format and to standardize procedures at all three units in the PUP.. As a result of this process, the station docurnent control administrative procedures were developed to apply to the three units. 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 their 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. The licensee has met their remaining commitments and has completed the PUP for Unit 2. I Additional insights regarding procedure quality have been obtained through several NRC ICAVP inspections of the licensee's CMP. Only several minor problems were identified. In addition, the OSTl found operating procedure quality to be good, and in general, operating procedures reviewed were technically sound, with only minor problems identified. In addition, the OSTI found that operators conducted observed evolutions in Mode 4 and Mode 3 (plant non-critical heatup) in compliance with operating procedures. The OSTl also found maintenance and surveillance testing procedure quality and adherence to be acceptable. These NRC inspections and the licensee's own evaluations indicate that Unit 2 procedures are acceptablo for restart. As previously noted, the NRC's inclusion of the PUP as a separate issue in the Unit 2 RAP was to assess the licensee's implementation of this longstanding program, in addition, the staff has also had many opportunities to assess the technical adequacy and quality of the procedures, as well as the licensee's adherence to procedures. There has been a substantial improvement over the past 2 years in this area. 3.6 Oversight Oversight and quality assurance is a restart issue due to past ineffective leadership, program implementation, management support, corrective actions and self-assessments, as identified by internal and external audits, including NRC inspections. The licensee developed a broad-based corrective action program for the deficiencies identified through internal and external assessments of Nuclear Oversight (NOS). Among these actions were: (1) promulgating corporate expectations for NOS; (2) reorganizing and restaffing; (3) developing new hold-point inspection procedures; (4) improving communications between line organizations and NOS,'(5) improving the skills of NOS staff in performance-based assessment; 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. After Unit 3 restarted in June 1998, NOS changed its NORVP assessment process to a Nuclear Oversight Verification Plan (NOVP). This new format incorporated a 1

I f 'o review of common site programs (e.g., security, emergency planning, and training) < along with separate assessments of Unit 3 operations, Unit 2 restart readiness, and Unit 1 maintenance. The full scope of NOS activities, including the NOVP, appeared l ' directed toward focusing Millstone station management attention on the areas impacting Unit 2 restart readiness and the achievement of operational excellence for overall station performance. The NRC evaluated NOS effectiveness through the routine inspection program as well as the specialinspections associated with the closure of SIL items in the Unit 2 RAP. The 40500 Team and OSTI examined the area of nuclear oversight and quality assurance. Some of the specific items reviewed included self-assessment programs, various department self-assessments, implementation of the licensee's Quality Assurance program required by 10 CFR 50, Appendix B, and independent oversight organizations such as the Plant Operations Review Committee (PORC), Station Operations Review Committee (SORC), and Nuclear Safety Assessment - Board (NSAB). During rontine and special NRC inspections, the staff confirmed that the licensee has established an effective self-assessment process that contains definitive management expectations regarding the need for performance improvement, an emphasis on self-assessment training, and enhanced procedural controls. The NRC staff found self-assessment programs have been strengthened, and departmental self-assessments were generally self-critical and constructive.,The NOS organization has provided meaningful performance assessments and has effectively identified areas for improvement. The NOS organization was found to be actively involved with the day-to-day operations of Unit 2. The PORC, SORC and NSAB comply with the Unit 2 Technical Specification requirements and were effective in providing plant safety oversight. 3.7 Enforcement During NRC inspections conducted between January 1996 and December 1998,38 potential escalated enforcement issues (Eels) were identified at Unit 2 as a result of NRC inspection activities. Out of 28 Eels identified in 1996, 22 were included in the December 10,1997, $2,100,000 civil penalty package,4 were granted enforcement discretion,1 was cited as a severity level IV violation, and 1 was not a violation. Out of nine Eels identified in 1997, two were aggregated to a severity level lil violation with a civil penalty of $55,000, one was granted enforcement discretion, and five were cited as severity level IV violations. One eel is still under evaluation; however, NNECO has implemented corrective action for this issue. Only one eel was issued in 1998 and was issued as a severity level lli violation, but received enforcement discretion. Thus far for reports issued in 1999, no Eels have 1 been identified at Unit 2. Also in September 1997, the licensee informed the NRC that separate investigations determined that two contractor employees in the Motor Operated Valve Department i

11 at Millstone had been retaliated against in August 1997 for engaging in protected activities. 'Although senior management was slow in recognizing and responding to early indications of retaliation, subsequent to the licensee's investigations, they took significant actions to reverse the terminations, as well as improve the climate at the Millstone station to ensure that a work environment exists such that employees feel free to raise safety concerns. Nevertheless, the NRC Office of Investigations confirmed the finding, and NNECO was issued a Severity Level ll Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $88,000 on March 9, 1999. The corrective actions implemented by the licensee for the enforcement items issued between 1996 and 1999 have been evaluated by the staff and have been determined to be adequate. 3.8 Employee Concerns On October 24,1996, the Director of NRR issued an Order to the licensee requiring the development of a comprehensive plan for handling the Millstone Station employees' safety concerns, and obtaining the services of an independent third-party oversight organization who would develop a plan for overseeing the licensee's implementation of the comprehensive plan. 1 The NRC staff reviewed and commented on the licensee's comprehensive plan, i d approved the third-party organization selected by the licensee to oversee the implementation of the comprehensive plan, and approved the third-party's oversight plan. In accordance with the Order, the third-party organization, Little Harbor Consultants (LHC), provided oversight of the effectiveness of Millstone's Employee Concerns Program (ECP) and safety-conscious work environment (SCV'E) until the licensee demonstrated by its performance that the conditions that led to the Order had been corrected to the satisfaction of the NRC. The NRC staff has monitored the licensee's programs, and through the end of 1998, visited the Millstone site about every 3 weeks to conduct onsite reviews of ongoing activities. The NRC participated in periodic meetings with the licensee and LHC that were open to the public and during which the results of LHC's ongoing assessment and the status of the Millstone SCWE program and the ECP were addressed. Also, the NRC periodically reviewed the licensee's programs, procedures, and j performance data and evaluated the licensee's established program success criteria, performance measures, and quantitative performance metrics. The NRC has also conducted three, week-long evaluations. The staff evaluations are documented in Evaluation Report Nos. 97-212, 98-215, and 98-217. In SECY-98-090, " Selected Issues Related to Recovery of Millstone Nuclear Power Station Unit 3," dated April 24,1998, and in a Commission meeting on May 1, 1998, the staff concluded that the licensee had improved its ECP and SCWE sufficiently to support restart of Unit 3. However, the staff also felt that continuation of the third-party oversight by LHC must be continued for 6 months t J

a 12' 1 l beyond restart to allow for evaluation of the license'e's performance in the ECP and SCWE areas; Over the next six months, the NRC continued to evaluate the licensee's performance in the ECP and SCWE areas. In SECY-99-010,." Closure of Order Requiring Independent, Third-Party Oversight of Northeast Nuclear Energy Company's implementation of Resolution of the Millstone Station Employees Safety Concerns, " dated January 12,1999, the NRC discussed its recommendation to close the ECP Order. ' In a January 19,1999; meeting with the Commission, the NRC, along with LHC and the licensee, discussed the basis for this recommendation. In a March 11,1999, letter to the licensee, the NRC noted, based on a Commission vote, that the NRC is satisfied that the licensee has demonstrated, by its sustained performance in executing its ECP and in establishing a SCWE, that the conditions that led to the requirement of third-party oversight have been adequately corrected. Therefore, no further actions needed to be done with respect to the Order. The NRC also noted that the licensee reconfirmed its intent to conduct quarterly, independent, third-party assessments of the SCWE at Millstone to ensure that progress continues in addressing SCWE issues as the Millstone organization transitions from the Order. The licensee will use LHC to perform these independent reviews. With the closing of the Order, Region I assumed oversight responsibili5ies of monitoring Millstone's ECP and SCWE. The NRC is currently in the process of developing an oversight plan, which will be based on the following activities. A Team inspection is planned in the next several months using inspection Procedure 40500, " Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems." The staff will use this opportunity to monitor the licensee's progress in the SCWE/ECP area using IP 40001, " Resolution of Employee Concerns." Region I will also participate in periodic meetings between the licensee and LHC, which will be open for public observation. During these meetings, the results of LHC's quarterly assessments, and the status of the ECP and SCWE areas will be discussed. 3.9 Significant items List One element of the Unit 2 RAP is the significant items list (SIL), The Sll (Enclosure

1) contains items that the NRC used to audit and evaluate licensee programs and other significant safety and regulatory issues. In order for an item to be included on the NRC's SIL, it had to meet at least one of.the following criteria:

1. Resolution of the issue was required to ensure safe operation of the facility to include satisfaction of the technical specifications or licensing basis. 2. Inspection of the issue would provide insight to an identified programmatic deficiency.such as the corrective action system. a 3

O 13 j i 3.' Inspection of the issue would provide assessment of manag'ement ) effectiveness or personnel performance. l The Panel identified 55 items for inclusion in the Unit 2 SIL. -The NRC has completed its efforts to review and close all 55 SIL items. The SIL items constitute the majority of the programmatic, technical, and regulatory issues included in the Unit 2 RAP. 3.10 Power Ascension inspection The NRC will conduct an assessment of licensee performance through sustained observations of the Unit 2 control room and other plant observations. The assessment will begin during the startup from Mode 3, through initial criticality, up to 30% power. Staffing will be provided by the resident inspector staff, including regional, headquarters or contractor support as necessary. Although around-the-clock coverage is not required, augmented coverage will entail a minimum of 16-hours per day, covering major evolutions and major maintenance and surveillance activities. After this process is suspended at the 30% power plateau, the resident inspector staff will resume normal coverage activities. 3.11 Plant Performance Review On February 24,1999, the NRC completed a Plant Performance Review (PPR) of Millstone. The primary focus of this PPR was on Unit 3 activities. Oversight of Unit 2 continued to be conducted by the Panel under MC 0350, with frequent assessments of performance provided to the Commission and at public meetings. The results of the NRC's assessment was provided to the licensee in a letter dated April 9,1999. Since Unit 2 has been granted permission to restart by the NRC, Unit 2 will be subject to future PPRs. 3.12 Licensing issues The NRC granted the licensee permission to restart Unit 2 as stated in a letter dated - April 29,1999. Therefore, there are no restart licensing issues to be discussed.

Enclosures:

1. Millstone Unit 2 Significant items List
2. Millstone Unit 2 MC 0350 Restart Approval Checklist
3. Millstone Unit 2 Licensing issues Required for Restart

a 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. REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 1 MC 0350 SECTION C.1.3, MANAGEMENT OVERSIGHT AND EFFECTIVENESS; INSP CLOSED C.2.1, C.2.2.a,d,e, LICENSEE STAFF SAFETY CULTURE 40500 IR 99-01 C.3.1,a,b,c,d OST) lR 99-04 2 MC 0350 SECTION C.1.1, 50.54(f)/lCAVP (PHASE I and ll) ICAVP CLOSED C.1.3, C.1.4.g, C.3.2, C.4.f; FSAR UPDATES INSP IR 98-201 CONFIRMATORY ORDER 10 CFR 50.59 PROCESS PROJ IR 98-202 DATED 08/14/96 CONFIGURATION MANAGEMENT / DESIGN CONTROL IR 98-208 PROCESS (PART OF ICAVP PHASE 1) IR 98-213 NRC LETTER DATED 04/27/99 IR 98-219# IR 99-05# 3 MC 0350 SECTION C.1.1 AND DESIGN CONTROL PROCESS CHANGES TO ADDRESS ICAVP CLOSED C.1.3; C.2.2.d; UNIT 1 ACR 7007 INSP IR 98-201 UNIT 1 ACR 7007; IR 98 202 UNIT 2 ACR 8781 NUMEROUS EXAMPLES OF DRAWINGS NOT 1R 98-208 IR REFLECTING ACTUAL PLANT CONFIGURATION IR 98 213 NRC LETTER DATED 04/27/99 IR 98-219 IR 99-05# 4 MC 0350 ITEM C.1.4.e, LICENSEE HANDLING OF CONCERNS RAISED BY PROJ CLOSED C.2.2.b,e; EMPLOYEE 3 INSP IR 97-212 ORDER DATED OCTOBER 24,

  • EMPLOYEE CONCERNS PROGRAM IMPROVEMENTS IR 98-210 1996
  • SCWE IMPROVEMENTS IR 98-215 IR 98-217 IR 99-01 NRC LETTER DATED 03/11/99

e 1 2 i REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS i 5 MC 0350 SECTION C.1.1, CORRECTIVE ACTION PROGRAM EFFECTIVENESS INSP CLOSED C.1.3, C.1.4.d-l, C.2.1, 40500 IR 99-01 C.2.2.c.e, C 3.1.d,m; C.4.f; SELF-ASSESSMENT PROGRAM IMPLEMENTATION AND ICAVP IR 98-219# IR 336/96-04 & 08 EFFECTIVENESS; eel 336/96-201-30 COMMITMENT TRACKING 6 MC 0350 ITEMS C.2.2.d, WORK PLANNING AND CONTROL: INSP CLOSED C.4.e,f,h,1,j OSTI IR 97 207 PLANT MAINTENANCE PROGRAM EFFECTIVENESS; IR 99-04 SIGNIFICANT HARDWARE ISSUES RESOLVED; MAINTENANCE BACKLOG MANAGED AND IMPACT ON OPERATION ASSESSFD; SURVEILLANCE TESTING; PLANT HOUSEKEEPING 7 MC 0350 ITEMS C.1.3.1, BYPASS JUMPERS, OPERATOR WORK AROUNDS & INSP CLOSED C.2.1.e, C 3.2.e, C.4.f,i; CONTROL BOARD DEFICIENCIES OSTI IR 99-04 8 MC 0350 ITEMS C.2.1.b, PROCEDURE ADEQUACY / PROCEDURE UPGRADE OSTl CLOSED C.2.2.d, C.3.1.k, C.3.3.e,f; PROGRAM ICAVP IR 97-202 INSP IR 97-203 ) IFl 336/95 201-03; PROCEDURE CLASSIFICATION - GENERAL USE VERSUS DRS IR 97 207 i d CONTINUOUS USE IR 98-206 IR IR 98-207 URI 336/96-01-04; LOSS OF DC BUS EVENT - ESTABLISH PROCEDURES IR 98-212 REQUIRED BY TECHNICAL SPECIFICATION 6.8.1 IR 98-213 j IR 98-216 l URI 336/96-06-08 SHUTDOWN COOLING SYSTEM WATER HAMMER; IR 98-05 NU LETTER B16257 REVIEW OPERATING PROCEDURES TO PRECLUDE IR 98.06 j WATER HAMMER EVENTS IR 98-219# I 1R 99-02 ) eel 336/97-02-12 SURVEILLANCE PROCEDURE ADEQUACY IR 99-04 1R 99-05# 9 MC 0350 ITEMS C.1.4 0, OPERATING PROCEDURES CONSISTENT WITH FSAR ICAVP CLOSED C.2.2.g, C.3.3.e,f; DESCRIPTION OF SYSTEM OPERATION INSP IR 97-02 eel 336/96 08-13, DRS 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 98-2081R 1R 98-216 IR 98-219# IR 99-05# 1 i i \\ ..m .b

3 REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 10 MC 0350 ITEMS C.2.1.g, PROGRESS OF EMERGENCY OPERATING PROCEDURE DRS(OL) CLOSED C.3.3.e,f; UPGRADES; INSP IR 97-203 IR 336/95-21 IR 98-05 ACCEPTABILITY OF DEFERRING ABNORMAL OPERATING PROCEDURE UPGRADES 11 MC 0350 ITEMS C.1.4.a,b,c, QUALITY ASSURANCE AND OVERSIGHT PROGRAM 40500 CLOSED C.2.1.c INSP IR 99-01 OSTI IR 99-04 IR 99 05# 12 MC 0350 SECTION C.1.1 LICENSEE RESTART PUNCH LIST - REVIEW OF ITEMS INSP CLOSED C.1.3, C.1.4.e, C.2.1.f-g, DEFERRED UNTIL AFTER RESTART OST) IR 97-207 ) C.4.f,I IR 98-06 IR 99-04 ) 13 MC 0350 ITEMS C.3.1.g,h,1,j,1, LICENSED OPERATOR STAFFING: CONTROL ROOM INSP CLOSED C.3.3.a,b,d,g FORMALITY; ATTENTIVENESS TO DUTY; ATTENTION OSTI IR 99-04 TO DETAIL; OFF-HOUR PLANT STAFFING: OVERTIME USAGE: AWARENESS TO PLANT SECURITY; AWARENESS OF EQUIPMENT STATUS; LOG KEEPING PRACTICES; 14 MC 0350 ITEMS C.3.1.e, OPERATOR LICENSING AND TRAINING DRS(OL) CLOSED 1 C.3.3.c; IR 98-05 CONFIRMATORY ACTION IR 98-216 i LETTER DATED MARCH 7, IR 99-02 1997; 15 MC 0350 ITEMS AUGMENTED INSPECTION COVERAGE DURING INSP CLOSED j C.4.a,b,c,d,e,g RESTART INSPECTION: OPERABILITY OF TECHNICAL OSTl IR 99-05# SPECIFICATION SYSTEMS; OPERABILITY OF SECONDARY AND SUPPORT SYSTEMS; SYSTEM LINEUPS; RESULTS OF PRE-STARTUP TESTING; POWER I ASCENSION TESTING 16 MC 0350 ITEMS C.2.2.g-h, EMERGENCY PREPAREDNESS PROGRAM (INCLUDING DRS(EFl,C8 WD C.3.1.m, C.3.2.h; ORGANIZATION / STAFFING / DOSE ASSESSMENT ra r. '12 NU LETTER (B16195) DATED CAPABILITY) 1 IR 98-208 FEBRUARY 10,1997 I lh 98-80 1 i

a 4 REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 17 MC 0350 SECTION C.5 AND DISPOSITION OF REGULATORY ISSUES: LICENSE NRR CLOSED .j C.6 AMENDMENTS; EXEMPTIONS; RELIEFS; ORDERS; PROJ IR 99-05# j SIGNIFICANT ENFORCEMENT ISSUES; ALLEGATIONS; OE AND 10 CFR 2.200 PETITIONS. COORDINATION WITH 01 SEE ENCL. 2 INTERESTED AGENCIES AND PARTIES. DRS AND 3 OPA J INSP 18 ACRs 02621, M2 96-0239 MATERIAL, EQUIPMENT AND PARTS LIST (MEPL) INSP CLOSED eel 336/96-201-42 & 43 PROGRAM IR 97-202 IR 97-203 1R 97-208 IR 98-207 IR 98-212 18 09-02 19 ACRs M2 96-0515 & 07958; EQUIPMENT ENVIRONMENTAL QUALIFICATION (EEO) INSP CLOSED eel 330/96-06-12, PROGRAM ICAVP IR 97-203 eel 336/96-201 20, IR 98-212 l URI 336/93-19-02 HIGH ENERGY LINE BREAK PROGRAM IR 98-219# LER 336/97 31 IR 99-05# 30 IFl 336/95-01-01 MOTOR OPERATED VALVES (GENERIC LETTFR 89-10) DRS CLOSED (SEB) IR 97-203 eel 336/96-05-11 INACCURATE INFORMATION PROVIDED TO THE NRC IR 98-04 REGARDING GENERIC LETTER 89-10; IR 99-04 IR 99-05# eel 336/96-05-09 DYNAMIC TESTING OF AFW TERRY TURBINE STEAM ADMISSION MOV; eel 336/95-08-01,03 & 04 PRESSURE LOCKING OF CONTAINMENT SUMP LER 336/97-34 RECIRCULATION VALVES 21 MC 0350 ITEM C.3.3.e; FIRE PROTECTION / APPENDIX R PROGRAMS DRS CLOSED IR 336/96-08; (EEB) 1R 99-03# 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; CONTAINMENT SUMP SCREEN MESH SIZE & ECCS DRS CLOSED eel 336/96-06-11 PUMP THROTTLE VALVE CLOGGING (SEB) IR 97 203 URI 336/96-06-10 IR 98-207

r 5 REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 23 ACRs 01991, M2-96-0449, HYDROGEN MONITORS AND POST-ACCIDENT 'INSP CLOSED 0467, 0654, 0655, & 0656; SAMPLING SYSTEM (PASS) INOPERABLE AND FAILURE DRS IR 99-02 eel 336/96-0811,12 & 13, TO MEET DESIGN BASIS AND LICENSING BASIS IR 99-05# eel 336/96-20103 & 41, URI 336/96-01-05 CORRECTIVE ACTIONS TO DEVELOP A URI 336/90-18-05 REPRESENTATIVE TOTAL GAS SAMPLE USING PASS 24 ACRs 08174,04047,06372 & EXCESSIVE REACTOR COOLANT SYSTEM HEATUP AND INSP CLOSED 09739; COOLDOWN RATES; EVALUATION OF SIMULTANEOUS IR 98-216 URI 336/95-42-03 REACTOR COOLANT PUMP AND SHUTDOWN COOLING IR 98-06 SYSTEM OPERATION 25 NUMEROUS ACRs; ECCS PUMPS SUCTION LINE FROM RWST HAS DRS CLOSED URI 336/96-06-08 NUMEROUS DEGRADED OR INOPERABLE PIPE IR 97-203 SUPPORTS, MANY CAUSED BY WATER HAMMER 1R 99-02 26 ACR 11252; "B" EMERGENCY DIESEL GENERATOR FAILURE - INSP CLOSED eel 33d/96-09-10 INADEQUATE CORRECTIVE ACTIONS IR 97-02 IR 97-203 IR 98-207 27 eel 336/96-20109 INADEQUATE DESIGN CONTROL MEASURES FOR ICAVP CLOSED VERIFYING ACCURACY OF INFORMATION CONTA:NED IR 98-219# IN DESIGN BASIS DOCUMENT PACKAGES 28 eel 336/96-201-11, FAILURE TO ADEQUATELY CONTROL INSTALLATION OF INSP CLOSED eel 336/96-201-31 TEMPORARY MODIFICATION TO THE RBCCW SURGE IR 97-203 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 CLOSED CONCERNING " DUAL-FUNCTION" ISOLATION VALVES IR 97-202 IR 98-05 IR 98-06 31 eel 336/96-201-28 FAILURE TO ADDRESS STATION BLACKOUT ISSUES DRS-CLOSED IDENTIFIED IN THE VECTRA ASSESSMENT IR 97-203 1R 99-05#

e o 6 RCRTWNCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 32 eel 336/96-201-29 FAILURE TO IMPLEMENT CORRECTIVE ACTIONS FOR INSP CLOSED AUDIT ISSUES INVOLVING TRENDING AND. IR 97-02 PRIORITIZATION OF NON-CONFORMANCE REPORTS IR 97-207 IR 98-207 33 eel 336/96 20136 INADEQUATE CORRECTIVE ACTION CONCERNING A DRS CLOSED SEISMIC DESIGN DEFICIENCY OF A VITAL (CMME) lR 97-202 SWITCHGEAR RGOM COOLER IR 97-203 IR 98-207 34 eel 336/96-08-06 IMPLEMENTATION OF CORRECTIVE ACTION OF INSP CLOSED CHANGING OPERATING PROCEDURE TO LOCK OPEN IR 97-02 REFUELING POOL DRAIN VALVES, AS SPECIFIED IN THE IR 97 203 FSAR, WAS INADEQUATE IR 98-207 35 eel 336/96-08-08 INADEQUATE CORRECTIVE ACTION IN LER 336/96-24 INSP CLOSED IR 97-203 IR 98-207 ~ 36 eel 336/96-08-10 INADEQUATE CORRECTIVE ACTIONS TO ADDRESS - INSP CLOSED UNIT 1 HEAVY LOADS LIFTED OVER THE UNIT 2 VITAL IR 97-02 SWITCHGEAR ROOM IR 97-203 IR 98-207 37 eel 336/95 44-05 ICE BLOCKAGE OF SERVICE WATER STRAINER INSP CLOSED BACKWASH LINE IR 99-02 38 URI 336/96-05-11 (IFS NO. URI SPENT FUEL POOL FSAR UPDATES INSP CLOSED 336/96-05-17) lR 97 02 39 eel 336/96-04-10 ERRONEOUS RBCCW FLOW VALUES IN CONTAINMENT INSP CLOSED TEMPERATURE PROFILE ANALYSIS IR 98-05 URI 336/96-201-38 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 PlPING IR 98-212 41 ACR M2 97-0023 SEIMANS COMPUTER MODEL OF REACTOR CORE. NRR CLOSED FOLLOWING LARGE AND SMALL BREAK LOSS OF NRC LETTER COOLANT ACCIDENTS DATED' 07/23/97 K ._a... mm-... ..an._

s o .- 7 ' REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP' STATUS 42 IR 336/94-201 (IFS NO. IFl EMERGENCY DIESEL GENERATOR FUEL DAY TANK PROJ CLOSED-336/94-201 90) DOES NOT SATISFY 7-DAY DESIGN BASIS CAPACITY INSP-IR 98-207. DRS lR 98 05. IR 98-08 43 URI 336/96-0814 INAPPROPRIATE REMOVAL OF STARTUP RATE TRIP INSP. CLOSED LER 336/96-29 PROJ-IR 96-08 IR 97-207 ' 04 ACR 02797, ACR 09563, POTENTIAL TO EXCEED CONTAINMENT DESIGN INSP CLOSED ACR M2 96-0153; PRESSURE FOLLOWING A MAIN STEAM LINE BREAK IR 99-05# LER 336/97-06 45 ACR M2-96-0296 FAILURE OF MAIN STEAM CHECK VALVE FOLLOWING INSP CLOSED =- A MAIN STEAM LINE BREAK (MSLB) COULD CAUSE 1R 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 CLOSED DAMPER COULD BECOME STUCK CLOSED, DISABLING IR 98-216 BOTH FACILITIES. DAMPER HAS NO MANUAL OPERATOR AS STATED IN FSAR. 47 URI 336/96-08-09, REACTOR PROTECTION SYSTEM AND ENGINEERED INSP CLOSED LER 336/96-24 SAFETY FEATURE RESPONSE TIME TESTING DRS IR 99-05# 48 ACR M2 96-0542 TECHNICAL SPECIFICATION LIMITS FOR INOPERABLE INSP CLOSED-MAIN STEAM SAFETY VALVES NON-CONSERVATIVE IR 98-212 INSERVICE 'NSPECTION/ INSERVICE TESTING DRS-CLOSED-49 LER 336/96-30, LER 336/97-05 I CR M2-97-0491 & 1229 PROGRAMS (CMME) IR 96-06 INSP IR 96-08 IR 98 IR 98-08 IR 99-02 50 CONTROL /USE OF VENDOR INFORMATION INSP CLOSED. ICAVP IR 97-203 IR 98-208 IR 99-02 s F t i

b

r. ? 8 1 1 a REFERENCE MILLSTONE UNIT 2 INSPECTION ITEM RESP STATUS 51 IR 336/95-29 SERVICE WATER SYSTEM OPERATIONAL-DRS(SEB CLOSED PERFORMANCE INSPECTION (SWSOPI) FOLLOWUP ) IR 99-05# 52 LER 336/97-33 ENGINEERED SAFEGUARDS ACTUATION SYSTEM INSP CLOSED INOPERABLE DUE TO IMPROPERLY SlZED POWER 1R 98-05 SUPPLY FUSES 53 LER 336/98-02 THE EMERGENCY CORE COOUNG SYSTEM (ECCS) OSTI CLOSED DESIGN DID NOT ADEQUATELY ADDRESS A LOSS OF IR 99-04 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 CLOSED INDICATES PEAK CLAD TEMPERATURE COULD EXCEED IR 99-02 2200 DEGREES F. 55 LER 336/98-12 RISK SIGNIFICANT ISSUES DESCRIBED IN LICENSEE INSP CLOSED LER 336/9714 EVENT REPORTS. 2/4/99 RAP MEETING MINUTES TITLE DRS IR 98 216 LER 336/97-15 OF SIL ITEM " REVIEW LL LER'S TO DETERMINE THOSE IR 99-02 LER 336/97 23 WITH SAFETY SIGNIFICANCE AND INSPECT BEFORE IR 99-05# LER 336/97-34 RESTART" LER 336/97-37

  1. SIL items are closed based on completed inspections for which inspection reports have yet to be issued.

1 l 1 .l

z K ENCLOSURE 2 MILLSTONE UNIT 2 MC 0350 RESTART APPROVAL CHECKLIST The following items are considered applicable to the restart of Millstone Units 2 4 RESPONSIBILITIES AND AUTHORITIES NEED STATUS RESP 4.01 Regional Administrator, Region 1, notifies the Executive X C RA Director for Operations (EDO) and the Commission, as appropriate, of the NRC actions taken concerning shutdown plants and the proposed followup plan. 4.02 Regional Administrator, Region 1. a. Discusses with the Deputy Executive Director for X C RA Nuclear Reactor Regulation, Regional Operations and Research, the Office of Enforcement (OE), and NRR, as appropriate, the need for an order or confirmatory action letter (CAL) specifying the actions required of the licensee to receive NRC approval to restart the plant and the proposed followup plan. b. Decides, in consultation with the NRR Associate X C RA 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 Panel. d. Develops a written Restart Assessment Plan, X C RAP including a case-specific checklist, to assign responsibilities and schedules for restart actions and interactions with the licensee and outside organizations, e. Coordinates and implements those actions prescribed X C RAP. in the Restart Assessment Plan that have been determined to be the Office of Special Project's - responsibility. These include, when appropriate, interactions with State and local agencies and with regional offices of Federal agencies.

I 2. 4 RESPONSIBILITIES AND AUTHORITIES - NEED STATUS -RESP l f.- In conjunction with NRR, reviews and determines the' X-C RAP .l acceptability of licensee's action program. SRI OSTl NRR (L) 3 1 g. Approves restart of the shutdown plant,'following X 'C .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 with NRR to X C RA establish the appropriate followup actions for a plant that has been shut down. 4.04 Director, Licensing .i a. Coordinates participation in followup conference calls X C NRR (L) and management discussions to ensure that the Regional Administrator is directly involved, when appropriate, in followup action. b. Coordinates and implements actions prescribed in the X C NRR Restart Assessment Plan that have been determined to be Licensing's responsibility. These include,. where applicable, appropriate NRC Office or NRR Division interaction with other Federal agencies (e.g., Federal Emergency Management Agency (FEMA), Department of Justice (DOJ)] pursuant to any. applicable Memoranda of Understanding.

3 4 i I l lNEED STATUS RESP B. PROCESS I B.1 INITIAL NRC RESPONSE 1 The facts, the causes, and their apparent impacts should be established early in the process. This information will assist the NRC in characterizing the problems, the safety j significance, and the regulatory issues. Early management appraisal of the situation is also important to ensure the proper immediate actions are taken. The following items should have been completed or should be incorporated into the CSC as appropriate. Refer to Section 5.02 of this manual chapter for additionalinformation D a. Initial notification and NRC management discussion NA of known facts and issues b. Identify / implement additionalinspections (i.e. AIT, NA IIT, or Special) (Region). c. Determine need for formal regulatory response (i.e. NA order or CAL). d. Identify other parties involved (i.e., NRC NA Organizations, other Federal agencies, industry organizations). 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 headquarters offices of cognizant Federal agencies may be appropriate. As the review process continues, additional and continuing notifications may be required. a. issue Daily and Directors Highlight (NRR). NA b. Issue preliminary notification (Region). NA c. Conduct Commissioner assistants' briefing. NA

.? B. PROCESS NEED.. STATUS RESP; -d. Issue Commission paper (NRR). NA' e. Cognizant Federal agencies notified (i.e., FEMA, EPA, .NA DOJ). f. State and local officiala notified (Region).. .NA g. Congressional notification (NRR) .NA B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS

a. Establish the Restart Panel.

.X C' RAP

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

C RAP licensee self-assessments, industry reviews).

c. Obtain input from involved parties both within NRC X

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

d. Conduct RA briefing.

X C RAP

e. Conduct NRR Executive Team briefing (NRR).

X C RAP f. If required, develop the case-specific checklist (CSC). X C RAP. j ]

g. Develop the Restart Assessment Plan.

X C RAP

h. Director, inspections approves Restart Assessment X

C RI Plan. ~ i. NRR Director approves Restart Assessment Plan. X-C DNRR-J. Implement Restart Assessme'nt Plan. X C RAP J ,l

k. Modify order as necessary X

C. NRR .c ~ )

1 / r 1 8. . PROCESS NEED. ~ STATUS-RESP j B.4 REVIEW IMPLEMENTATION ' _B.4.1 Root Causes and Corrective Actions

a. Evaluate findings of the special team inspection.

X C. ' OSTI ~ -RAP-

b. Licensee performs root cause analysis and develops

-X C 'NU corrective action plan for root causes. OSTl 40500

c. NRC evaluates licensee's root cause determination X

C ' RAP and corrective action plan. OSTI 40500 B.4.2 Assessment of Equipment Damage For events where equipment damage occurs, a thorough assessment of the extent of damage is necessary. A root cause determination will be necessary if the damage was the result of an internal event. The need for independent NRC assessment should be considered. The licensee will need to determine corrective actions to repair, test,' inspect, and/or analyze affected systems and equipment. These actions are required to restore or verify that the equipment will perform to design requirements. Equipment modifications may also be required to ensure performance to design requirements. Potential offsite emergency response impact for external events such as natural disasters, explosions, or riots should be considered. NRR should obtain information from FEMA headquarters reaffirming the adequacy of State and local offsite emergency plans and preparedness if an event raises reasonable doubts about emergency response - capability.i a. Licensee assesses damage to systems and. NA = components. b. NRC evaluates licensee damage assessment. NA ~ L_

i i 7 6 B. PROCESS NEED STATUS RESP j c. Licensee determines corrective actions. NA d. NRC evaluates corrective actions. NA B.4.3 Determine Restart issues and Resolution The establishment of the restart issues that require resolution before restart demands a clear understanding of the issues and the actions required to address those issues by both the NRC and the licensee. This section outlines steps to determine the restart issues and NRC's evaluation of their resolution. a. Review / evaluate licensee generated restart issues. X C RAP (. - b. Independent NRC identification of restart issues. X C RAP c. NRC/ licensee agreement on restart issues. X C RAP d. Evaluate licensee's restart issues implementation X C RAP process. e. Evaluate licensee's implementation verification X C SRI - SIL process. 40500 OSTI I B.4.4 Obtain Comments Since some shutdowns involve a broad number of issues, solicitation of comments from diverse sources may be appropriate. The decision to solicit comments from a group and the level of participation should be made on a case-by-case basis. Input from these groups should be factored into the restart process when they contribute positively to the review. Note: If needed, comments concerning the adequacy of state and local emergency planning and preparedness must be obtained from FEMA headquarters through NRR.

a. Obtain public comments.

X C RAP

1 i -l 7 B. PROCESS NEED STATUS RESP'-

b. Obtain comments from State and Local Officials X

C SLO (Region).. RAP 1

c. Obtain comments from applicable Federal agencies.

X C RAP-B.4.5 Closeout Actions When the actions to resolve the restart issues and significant concerns are substantially complete, closecut-actions are needed to verify that planned inspections and verifications are complete. The licensee should certify that corrective actions required before restart are complete and i that the plant is physically ready for restart. This section - prcvides actions associated with completion of significant NRC reviews and preparations for restart. a. Evaluate licensee's restart readiness self-assessment. X C RAP OSTI b. NRC evaluation of applicable items from Section C X C RAP "lSSUES" complete. c. Restart issues closed. X C RAP SRI OSTI d. Conduct NRC restart readiness team inspection. X C OSTI e. Issue augmented restart coverage inspection plan. X C OSTI RAP' f. Comments from other parties considered. X C RAP g. Determine that all conditions of the Order / CAL are X C RAP satisfied. ICAVP - h.' Re-review of Generic Restart Checklist complete. X C RAP SRI 4 I r w a

Q 8 B. PROCESS NEED STATUS RESP. B.5 RESTART AUTHORIZATION When the restart review process has reached the point that the issues have been identified, corrected, and reviewed, a restart authorization process is begun. At this point the Restart Panel should think broadly and ask: "Are all actions substantially complete? Have we overlooked any items?" Prepare restart recommendation document and basis X C RAP a. for restart. b. NRC Restart Panel recommends restart X C RAP No restart objections from other applicable HQ X C NRR (L) c. offices. d. No restart objections from applicable Federal X C RAP agencies. e. RA concurs in restart recommendation X C RA ~ f. NRR Director concurs in restart recommendation. X C NRR (L) EDO concurs in restart recommendation when X C EDO~ g. required. h. Conduct ACRS briefing when requested (NRR). NA .i i. Conduct Commission briefing when requested. X C RA X C COMM-j. Commission approves restart. X C EDO k. EDO authorizes restart. i B.6 RESTART AUTHORIZATION NOTIFICATION Notify the applicable parties of the restart authorization. Notifications should genera!!y.be made using a memorandum or other format consistent with the level of . formality required. Commun; cation of planned actions is important at this stage to ensure that NRC intentions are clearly understood._ c

9 l B. - PROCESS-a. Commission (if the Commission did not concur in the ' NA Restart Authorization or as requested) (NRR). b. EDO (if the EDO did not concur in the restart NA recommendation or as requested) (NRR). c. Congressional Affairs (RAP). X C RAP d. ACRS (a briefing may be substituted for the written X C NRR notification if the ACRS requests a briefing) (NRR).. e. Applicable Federal agencies. X C RAP f. Public Affairs. X C RAP g. State and local officials, X C SLO h. Citizens or groups that expressed interest during the X C RAP. restart approval process. 1. Issue staff concerns memorandum. X C RAP 5 .,-...g r- -l r srg --. - -.. - -..... -.i.. ,i, ei 3r r - i.-- -- - - - i.- -

4,. + 10 C. ISSUES NEED STATUS-RESP 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' shutdown X -- C . RAP.- are clearly understood. c. Root causes of other significant problems are clearly ~ X - C RAP.. understood, d. Effectiveness of the root cause analysis program. X C-40500-RAP. OSTI C.1.2 Damage Assessment a. Damage assessment was thorough and NA comprehensive. j b. Corrective actions clearly restored systems and NA equipment or verified they can perform as designed. Ll C.1.3 Corrective Actions j a. Thoroughness of the corrective action plan X C RAP 40500 i b. Completeness of corrective action programs for X C SRI specific root causes. 40500 I OSTI c. Control of corrective action item tracking. X C SRI - OSTI-40500 1 d. Effective corrective actions for the conditions-X C . SRI requiring the shutdown have been implemented. OSTI' i i I a. I 9'. l

11~ l C. ISSUES l e. Effective corrective actions for other significant X C SRI ) problems have been implementeo. OSTI ICAVP ' 40500 f. Control of long term corrective actions. X C LSRI (Backlog Management Plan) OSTI - 40500 .l l g. Effectiveness of the corrective action verification X C SRI - process. .OSTI 40500 C.1.4 Self-Assessment Capability The occurrence of an event may be indicative of potential I weaknesses in the licensee's self-assessment capability. A strong self assessment capability creates an environment where problems are readily identified, prioritized, and tracked. Effective corrective actions require problem root cause identification, solutions to correct the cause, and 4 verification methods that ensure the issue is resolved. l Senior licensee management effectiveness in ensuring effective self-assessment is treated separately. l I a. Effectiveness of Quality Assurance Program. X C RAP 40500 b. Effectiveness of Industry Experience Review X C OSTl Program. 40500 c. Effectiveness of licensee's Independent Review X C SRI. Groups. OSTI 40500~ i d. Effectiveness of deficiency reporting system. X C-SRI 3 OSTl -] 40500 t e. Staff. willingness to raise concerns. . X-C NRR (L) RAP ___.m__._._m_mi_a-___m_---

12 C. ISSUES NEED . STATUS. ' RESP f. Effectiveness of PRA usage. X-C' . OSTI 40500 g. Effectiveness of commitment tracking' program. -X C. SRI : RAP. 40500 h. Review applicable external audits X C OSTl-40500. 1. Quality of 10 CFR 50.72 and 50.73 reports. X C - SRI - 1 C.2.1_ Management Oversight and Effectiveness a. Goals / expectations communicated to the staff. X C OSTI 40500 b. Demonstrated expectation of adherence to X C SRI . procedures. OSTI c. Management involvement in self-assessment and X C RAP independent self-assessment capab!!ity .40500 d. Effectiveness of management review committees. X C SRI OSTI 40500 e. Management's demonstrated awareness of X C SRI day-to-day operational concerns. OSTl f. Management's ability to identify and prioritize X C SRI. significant issues. OSTI '40500 g. Management's ability to coordinate resolution of X C SRI - significant issues. OSTl 40500 h. - Management's ability to implement effective ' X C SRI corrective actions. . OSTI 40500-J

13 C. ISSUES C.2.2 Management Support ' mpact of any management reorganization. X C OSTl. i a. RAP 40500 b. Effective and timely resolution of employee concerns. X .C RAP'- ' NRR (L) - 1 SCWE c. Adequate engineering support as demonstrated by X .C' DRS timely resolution of issues. OSTI' ICAVP 4 d. Adequate plant administrative procedures. X C SRI 40500 OSTI e. Effective information exchange with other utilities. X C SRI OSTI 40500 f. Participation in industry groups. NA g. Effectiveness of Emergency Response Organization. X C DRS h. Coordination with offsite emergency planning X C DRS officials. l l C.3.1 Assessment of Staff i a. Demonstrated commitment to achieving improved X C. . RAP performance. SRI ~ . OSTl [ b. Demonstrated safety consciousness. X -C OSTI SRI . NRR (L) - SWCE '1 __.___=________:___-______-__

9 14 C. ISSUES NEED STATUS RESP c. Understanding of management's expectations and X C OSTI goals. 40500 d. Understanding of plant issues and corrective actions. X C OSTl-SRI 40500' e. Qualifications and training of the staff. X 'C OSTI f. Staff's fitness for duty. NA ] g. Attentiveness to duty. X C' OSTI h. Level of attention'to detail. X C OSTI i. Off-hour plant staffing. X C SRI OSTI J. Staff overtime usage. X C SRI 40500 ' OSTI - k. Procedure usage / adherence. X C SRI OSTI 40500 'i 1. Awareness of plant security. X C. DRS

{

m. Understanding of offsite emergency planning issues. X C DRS t C.3.2 Assessment of Corporate Support and Site Engineering l-Support l-l a. Corporate staff understanding of plant issues. X C OSTI L-b. Corporate staff site specific knowledge. X C OSTI 1 c. Effectiveness of the corporate / plant interface X C OSTI meetings. 'I d. Corporate involvement with plant activities. X C OSTI l D I 4 ........)

15 C. ISSUES NEED - STATUS. RESP. e. Effectiveness of site engineering support. X C DRS OSTI ICAVP f. Effectiveness of the site design modification process. X C ICAVP OSTI I ] g. Effectiveness of licensing support. X C RAP 1 h. Coordination with offsite emergency planning X-C DRS officials. C.3.3 Operator issues a. Licensed operator staffing meets requirements and X C DRS licensee goals. I b. Level of formality in the control room. X C OSTI SRI c. Effectiveness of control room simulator training. X C DRS I d. Control room / plant operator awareness of equipment X C OSTI status. SRI e. Adequacy of plant operating procedures. X C SRI ICAVP OSTI i f. Procedure usage / adherence. X C SRI OSTI l g. Log keeping practices. X C OSTI i C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT a. Operability of technical specification systems. X C. OSTI b. Operability of required secondary and support ,X: C Ob l~l systems. I e _______._.._m ______A-____-

1 e 16 C. .lSSUES NEED STATUS RESP c. Results of pre-startup testing. X' .C SRI' OSTl a d. Adequacy of system lineups. X -C OSTI l e. Adequacy of surveillance tests / test program. X C OSTl f. Significant hardware issues resolved (i.e. damaged X C OSTl equipment, equipment ageing, modifications). g. Adequacy of the power ascension testing program. X C OSTI SRI - h. Effectiveness of the plant maintenance program. X C OSTI' DRS l 1 1) i. Maintenance backlog managed and impact on X C OSTI operation assessed. l -] J. Adequacy of plant housekeeping and equipment X C OSTI storage. j l C.5 ASSESSMENT OF COMPLlANCE WITH REGULATORY I REQUIREMENTS l a. Applicable license amendments have been issued. X C RAP l b. Applicable exemptions have been granted. X C RAP c. Applicable reliefs have been granted. X C RAP

d..

Imposed Orders have been modified or rescinded. X C RAP I J e. Significant enforcement issues have been' resolved. X C RAP k OE

f..

Allegations have been appropriately addressed. X C' ' RAP ~ SRI-PE -{ l .A

17 ) C. ISSUES NEED STATUS RESP 1 g. 10 CFR 2.206 Petitions have been appropriately X C NRR (L) addressed. h. Atomic Safety and Licensing Board hearings have NA been completed. { C.6 COORDINATION WITH INTERESTED AGENCIES AND PARTIES a. Federal Emergency Management Agency X C DRS NRR (L) b. Environmental Protection Agency NA c. Department of Justice X C OE 01 RA d. Department of Labor X C OE e. Appropriate State and local officials X C SLO f. Appropriate public interest groups X C RAP g. Local news media X C OPA 1 ..b

.4 y 0 ENCLOSURE 3 MILLSTONE UNIT 2 LICENSING ISSUES REQUIRED FOR RESTART TS Technical Specification CW Complete - Withdrawn CA Complete - Approved TAC No./ Mode issue / Type Status 1 M97746 Meteorological Tower Instrumentation 12/16/97 CW N/A (TS) 2 M98277 Ultimate Heat Sink Temperature 02/06/98 CA l Mode 4 (TS) j 3 M98347 Enclosure Building 09/30/97 CA Mode 4 (TS) j 4 M94623 Containment isolation Valve List Removal from TS 11/19/97 CA Mode 4 (TS) 4 5 M92879 Control Room Emergency Ventilation System 08/16/98 CW Mode 4 (TS) 6 M99543 EDG Fuel Oil Supply Adequacy License Amendment 01/23/98 CA Mode 4 (USQ) 7 MA2340 ESFAS and RPS - Setpoints & Allowable Values 02/08/99 CA. Mode 4 (TS) 8 MA0121 RCS Pressurefremperature Curves 07/01/98 CA j Mode 4 (TS) l 9 M99503 Maximum Containment Pressure Limit 10/27/97 CA Mode 4 (TS) 1 10 M99504 Technical Specification - Verbatim Compliance 05/26/98 CA Mode 4 (TS) 11 M94105 Steam Generator Blowdown Monitors 08/26/97 CA Mode 4 (TS) 12-M99609 Reactor Trip Setpoints - S/G Safety Valves 11/19/97 CA Modes 13 (TS) 13 M97680-Slemans LOCA Analysis - Evaluation 07/23/97 CA ~j Mode 4 (Non TS) j l 14 M99266 Startup Rate Trip 08/19/97 CA .j Mode 4 (Non TS) j 4 15.'. M99296 Hydrogen Monitors - NUREG-0737 10/28/97 CA I Mode 4 (Non TS) .) .- 1 16 M99613 - RG 1.97 - Core Exit Thermocouples Power Supply Mods 01/12/98 CA Mode 4 ' (Non TS) ' i i L22-__--__L_-__-_---___-_a__=__ ___:____=___.__.__-_.- A

j. '0 2 17 MA2416 Exemption request - Appendix R (Four needed)- 03/16/99 CA Mode 4 '(EX) 18 MA0251 Compliance for CEA Rod Drop Testing & Design Section-06/16/98 CA Mode 2 Updates (TS) 19-M99614 ATWS - Commitment Withdrawal . 10/29/98 CA Mode 4 (Non TS) l l 20 MA2441 Condensate Storage Tank Volume 12/31/98 CA ] Mode 4 (TS) { i 21 MA1554 Trisodium Phosphate (TSP) Volume 06/22/98 CA - 1 Mode 3 (TS) '22 MA1649 Low Range Press Transmitters Diversity 12/9/98 CW Mode 4 (USQ) 23 MA2255 Service Water System Protective Coating 12/18/98 CA Mode 4 (USO) .j 24 MA1771 Continuous Bypass Inoperable Channel RPS/ESFAS 11/10/98 CW -. Mode 4 (TS) 25 MA3553 RCS Head Vent Surveillance Compliance issues # 4 03/11/99 CA Mode 4 (TS) 26 MA1462 MSIV & Pressurizer Surveillance 08/21/98 CA Mode 4 (TS) 27 MA1137 RG 1.97 Deviation Variable D23 CAR Fans 04/30/98 CA Mode 4 (Non TS) 28 MA 1066 ATWS Pressure instruments 04/30/98 CA Mode 4 (Non TS) 29 MA1070 Leak-Before-Break Reanalysis-Cold Leg 10/06/98 CA Mode 4 (Non TS) .R l 30. MA2367 Leak Before-Break (Si & SDC sys) 10/06/98 CA l Mode 4 (Non TS) 31 MA0838 Emergency Preparedness Plan, Rev 24 06/04/98 CA Mode 4, (Non TS) 32-M83642 IPEEE - Fire Protection issues (Turbine Building) Not a restart issue N/A (Non TS) 33 MA3410 Siemens MSLB - Reanalysis Methodology Change 03/10/99 CA Mode 4 (TS) 34 MA2311 EDG Surveillance Requirements & GDC-17 TS 03/12/99 CA Mode 4 Clarification (TS) - 35, MA3955 ' ' Shutdown Cooling Sys Relief Valve 02/10/99 CA Mode 4 (TS) 1 l i J ~ -_.---a ___..-_._.--_.__i_______--____.__.

m s O 3 36 MA4361 Boron Precipitation - Hot Leg injection Single Failure 03/10/99 CA Mode 4 (USO) 37 N/A Long Term CST Makeup via FW System No submittal req. (USO) (No USQ involved) 38 MA3672 Control Room Ventilation DBA Calculations 03/10/99 CA l Mode 4 (TS & USQ) 39 N/A Passive Failure - ECCS Piping Post LOCA No submittal req. N/A (USQ) (No USQ involved) 40 MA4126 Leak Before Break - Pressure Surge Line 05/04/99 CA 1 Mode 2 (Non TS) 41 N/A Separation - Raceways No submittal req. N/A (USO) (No USQ involved) 1 42 MA3671 Separation - Control Panel 12' to 6" 01/20/99 CA l Mode 5 (USO) 43 MA3392 Ampacity Derating (GL92-01) Not a restart issue N/A (Non TS) 44 MA4175 S/G Tube Rupture - Reanalysis Not a restart issue N/A (USQ) 45 MA4431 Loss of Feedwater - Reanalysis 04/18/99 CA Mode 2 (TS & USO) 46 MA4150 Continuous Bypass inoperable Channel RPS/ESFAS 01/27/99 CA Mode 4 (TS) 47 MA4580 Hydrogen Purge (Backup to Recombiners) 04/12/99 CA Mode 2 (TS) 48 MA4460 TS Change - ECCS Pump Flow Requirements Not a restart issue N/A (TS) 49 MA4578 EBFS Bypass Leakage Not a restart issue N/A (TS) j 50 MA4555 RG 1.97 Deviation, CST Level Indication 03/17/99 CA-Mode 2 (Non TS) 51 MA4612 RG 1.97 Deviation, Containment Area Rad Variables 03/17/99 CA Mode 2 (Non TS) I J _}}