ML20210H753

Informs That Licensee Restart & Performance Review Panel Has Determined That Plant Has Satisfactorily Completed Items & Corrective Actions Identified as Restraints to Restarting of Cps,W/Exception as Listed

ML20210H753
Person / Time
Site:	Clinton
Issue date:	08/05/1997
From:	Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9708140177
Download: ML20210H753 (40)

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3 j 801 WARRENVILLE ROAD 'I g USLE. ILUNotS 80532-4351 August 5, 1997 VMEMORANDUM TO: A. Bill Beach, Regional Administrator VMM

• FROM: James L. Caldwell, Deputy Regional Ad inistrato

SUBJECT:

. CLINTON POWER STATION RESTART (PARTIAL APPROVAL)

I am writing to inform you that the Clinton Restart and Performance Review Panel

-(the Panel), following a modified Manual Chapter (MC)-0350 format developed in November 1996 (Attachment B), has determined that Illinois Power (IP) has satisfactorily completed those items and corrective actions identified as restraints to restarting the Clinton Power Station (CPS) with an exceptinn described below. Further, the Panel has determined that CPS personnel performance and equipment status are capable of supporting facility restart. I Following the September 5,1996, reacter recirculation pump seal failure event, the NRC lasued Confirmatory Action Letter (CAL) Alll 96-013 to confirm actions IP would take to - 4 identify issues associated with the event. Following completion of IP's investigation into the' event and the NRC special inspection and Operational Safety Team inspection (OSTI),

IP committed to implement a Startup Readiness Action Plan (SRAP) prior to restarting CPS.

The SRAP items were documented in CAL No. Rill 97-001 and were designed.to improve-

. procedure adherence and quality, safety and operability evaluations, address a number of long-standing equipment problems, bnd improve IP's corrective action program. A third CAL, Rlli-97-OO6, was issued in June 1997, addressing degraded coatings in the containment. ~ In addition to the CALs, specific equipment issues were identified as restart issues including degraded voltage, breaker maintenance, and control room neon bulb =

sockets.

IP's corrective action implementation and effectiveness were inspected by the resident staff, resident inspectors from other Region lit sites, and non-resident inspection activities.

. The Panel monitored IP's activities through direct observations and feedback from inspectors. The Panel met weekly and held public meetings with IP on April 18, May 1, 1

'15,28, June-13, and July 3,1997, to discuss the status and effectiveness of the specific items and emergent technical issues.

The Panel reviewed the actions IP took to address programmatic and equipment I deficiencies identified at the CPS. The review included assessments of IP's actions and responses to commitments in the three CALs, actions to address equipment deficiencies at {

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,- - CPS, actions to address discrepancies between the as-built facility and the Updated Safety j' Analysis Report, actions to address degraded but operable equipment,'and current

allegations for trends or startup issues. A summary of the Par'el's review of the issues is

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. In Attachment A. _While recognizing that IP's improvement program is not completed, the Panel, with the exception of the electricalissue discussed below, concluded there is -

l' reasonable assurance that the facility can start up and operate safely. -

LThe final restart issues deal with offsite electrical power source capability, electrical circuit

- breaker reliability, and equipment qualification in the Emergency Diesel Generator (EDG) rooms.. To address offsite power source capability, IP has requested a Technical Specification amendment and an exemption from General Design Criterion 17. To address l

safety related breaker reliability, IP performed extensive inspections, tests, and overhauls i of safety related breakers to demonstrate reasonable assurance that these breakers were -

capable of performing their safety function. - Despite these efforts, a safety related breaker failed in service on July 22,1997.- IP is performing additional tests, reviewing their maintenance procedures, and developing and implementing corrective actions to re- - ,

establish reasonable assurance that safety related breakers will function when called upon.

1 To addioss high EDG room temperatures, IP is performing extensive reviews and analysis -

.to demonstrate that the EDGs and their supporting equipment will remain operable under i j foreseeable conditions of high temperature. These issues will be discussed and the f licensee's determinations and corrective actions will be evaluated prior to restart of the ,

L facility. A separate memo to you will document the Panel's review and agreement that +

these electricalissues have been resolved sufficiently to allow restart. .

i To ensure appropriate monitoring of IP's activities during startup, a special startup _ i l ' monitoring program consists of 24-hour coverag1 by six inspectors during startup and power ascension was developed (Attachment C). . The Panel reviewed the program and

! found it acceptable.

0 l Restant Review Panet Results'and Recommendation an Appinved:

q A. BIG Beacth Regional Administrator Region HI- ,

I Attachments: -A. Issue Assessment 4

B. Modified MC-0350 Restart Action Plan for Clinton Power Station (CPS) j C. Startup Inspection Plan Docket No. 50-461 Inspection Report 97016 -

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A. Bill Beach '- Distribution -

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-J. Roe, NRR

- G.' Marcus, NRR D. Pickett, NRR .

J.'Caldwell, Rlli G. Grant, Rlli J. Grobe, Rlli G. Wright, Rill K. Perkins, WCFO, RIV SRI, Clinton Docket File PUBLIC IE-01 4

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i Attachment A h ISSUE ASSESSMENT CAL No; RIII-96-013:

F Confirmatory Action Letter (CAL) No. RIII-96-013 was issued shortly after the

September 5,1996 event. The CAL addressed actions Illinois Power (IP) committed

to perform to assess the event. IP addressed the actions in a number of letters to the

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_NRC, the last being on December 9,1996, where IP's Startup Readiness Action Plan 4-(SRAP) was ad&essed. All' actions associated with the C AL were completed, carried

over to the SRAP, or addressed in IP's long-term Strategic Impr6vemem Program.

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CAL No. RIII-97-001; e-

, Procedure Adhennee:

Improvements in procedure adherence have been noticed site-wide, with significant

! improvements noted in the Operations Department. The most effective actions taken- l by IP management occurred in April 1997 when fundamental changes were made to

. the administrative procedures governing procedute adherence and temporary

{ procedure changes. Special training was provided to plant staff on the new procedures and management used the training to re-enforce its expectations in the area. IP also brought in outside contractors to assist in evaluating and correcting problems in human performance regarding procedure adherence.

P" rocedum Improvement:-

IP implemented a procedure enhancement program for important operating procedures

- and selected surveillance procedures. This activity improved the procedures' technical content and usability. The program initially reviewed the procedures for technical accuracy. Following the April changes to the procedure adherence guidance, procedures were reviewed to ensure they could be accomplished as written.

The combination of the two reviews has resulted in much improved procedures.

- Safety Evaluations & Operability Determinations:-

IP revised its programs for safety evaluations and operability determinations.

Training was also provided to engineering and operations staffs on both topics with emphasis placed on the purpose of 10 CFR 50.59 mafety evaluations.- One of the

. notable changes was in the operability determination program where the Operations Department now has the responsibility for initial equipment operability determinations

- rather than engineering. While the licensee experiences growing pains in the -

program's implementation, the essential elements of a successful program exist.

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1 Coritctive Action Program:

IP addressed short and long term improvements to its corrective action program.

Short term activities involved increased staff sensitivity towards cor.dition reports, improved critique process, and improved assessment timeliness. Iong term actions, addressed in IP's July 3,1997 letter, include items such as a separate group responsible for the corrective action program and improvod corrective action determinations. IP's short term actions have resulted in a considerable improvement in the process.

57 Individual CAL No. RIII-97-001 Items:

The Panel reviewed IP's actions associated with 57 items in CAL No. RIII-97-001.

The review included review of IP's documentation, meetings with IP to discuss actions taken and their effectiveness, and independent inspection activities. The inspection activities involved routine observations and discussion with Clinton Power Station (CPS) staff, inspection effort directed at individual issues, and observations of IP's training and seminars addressing spec.fic issues. The results from these activities 2

formed the bases for the Panel's closure of the 57 items documented in Inspection Report 50-461/97012. As noted in the report, three items require additional activities during startup and power ascension: control room startup monitoring, feedwater check valve performance, and reactor recirculation pump seal performance. Based on the aforementioned activities, the Clinton Restart and Performance Review Panel (the Panel) determined that IP has ta. ken the actions they committed to take prior to unit startup and that those actions have improved CPS staff performance.

LONG STANDING TECIINICAL ISSUES _t Feedwater Check Valves:

Significant modifications were made to the two outboard feedwater check valves.

Modifications to the valves' operators were made to improve seat alignment during closure and closing forces. Post modification leak rate testing indicated a very low leakage rate. IP committed to perform a mid-cycle local leak rate test on the feedwater check valves to validate the effectiveness of the design changes.

Degraded Voltage:

Significant modifications were made to address degraded voltage condition.

Modifications were made to the electrical distribution system to improve the facility's response to an electrical distribution safety function inspection identified degraded voltage condition. This item was the critical path item for the outage from Jenuary to the end of the outage. Resolution of the onsite problem of degraded voltage led to the identification of the need for a Technical Specification amendment and an exemption A-2

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from General Design Criteria 17. Dese were still pending and required the Panel review and approval prior to restart. l Safety Related Breaker Maintenances

, In response to NRC identified deficiencies in its maintenance program for safety  ;

i related breakers, IP completed an extensive testing and inspection progmm on 480 V, 4160 V, and 6900 V safety related circuit breakers. The Panel concluded that

! additional information is required to ensure reasonable assurance that the breakers will i perform satisfactorily during the next refueling cycle.

Control Room Neon Bulb Replacement:

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[ IP replaced, for the second time, all main control room neon bulb holders due to

inadequate initial installation. The kensee identified the root cause of this problem to be a programmatic breakdown in'the control of consumable material on plant

j. components and poor workmanship. Actions were taken to address both issues.

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4 Main Control Room Deficiencies:

IP also identified and repaired in excess of 400 main control room deficiencies, i

significantly improving the material condition of the main control room. The Panel found IP's actions to be neceptable.

1 Excessive Backlogs of Non Safety and Safety Related Preventive

} Maintenance (PM) Tasks Following an NRC inspector question on the timeliness of the calibration'of radiation l monitors, the licensee found an error in a computer program used to schedule PMs

[ had caused 1,464 PM for safety and non-safety components to be late. The licensee

is prioritizing necessary tasks, performing critical PMs or performing engineering-evaluations to justify not performing the PMs prior to restart.

( CAL No. RHI-97-006 DEGRADED CONTAINMENT COATINGS: -

' CAL No. RIII-97-006 was issued to document actions IP agreed to take in response to i._ the NRC identified issue of degraded containment coatings and their impact on I suppression pool emergency core cooling system suction strainer operability. IP i addressed the CAL by removing known and suspected degraded coatings and by sampling non-suspect coatings to demonstrate conformance to the applicable standards. The program was reviewed by the Panel and Nuclear Reactor Regulation coating experts and found to be acceptable.

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4 ALLEGATIONS. UPDATED SAFETY ANALYSIS (USAR) DISCREPANCIES. AND

! DEGRADED BUT OPERABLE EOUIPMEN"r:

The Panel's review of existing allegations did not identify any specific trends or issues which would impede unit startup, Likewise, a review of USAR discrepancies and degraded but operable equipment evaluations did not identify any items affecting unit restart. Equipment that had been identified as degraded but operable had been identified by IP as mode change restraints indicating the degraded condition would be corrected prior to changing modes. The Panel found no restart items in this area.

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1 .l Attachment B  !

Modified Manual Chanter (MC) 0350 Restart Action Man for Clinton Power Station (CPS)

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A. GENERAL.

A.1- PURPOSE i

The CPS Restart Action Plan (Action Pl6n) is to plan and coordinate NRC review '

activities for the Clinton Station restart following the shutdown from the September 5,1996 event.

A.2 - OBJECTIVES The' Action Plan has been developed to ensure NRC review efforts are consistently developed and implemented, with specific guidance to support the following .

activities.

a .-- Determine issues requiring NRC review prior to facility restart,

b. Identify the basic tasks needed to be reviewed and approved prior to facility restart. -

c. Restart review activity coordination and tracking.

A.3 BACKGROUND Following the plant startup from the April 9,1996 reactor scram, one of two reactor recirculation pump shaft seals began to degrade.: Pump seal pressure was initially observed to be decreasing and drywell unidentified leakage was observed to be increasingi both indicative of seal degradation.. On September 5,1996, due to

' increasing trends in drywell unidentified leakage, isolation of the reactor recirculation loop believed to be the leakage source was initiated. While isolating the loop, unidentified drywell leakage increased above the five gallons per minute technical specification limit. An Unusual Event was declared and a number of actions were taken by the plant staff, including actions to decrease unidentified leakage. During these actions the pump sesi failed, causing a large and rapid

-.-- - increase in the drywell leakage rate'. The plant was shut down, leakage terminated,

- and actions were started to replace the pump seals.

The NRC was concerned with the decisions and ' actions taken in response'to plant conditions during the event. Based on these concerns, a special NRC team

. inspection was initiated on September 6,1996, to evaluate the actions taken in

- response to the event. In addition, the NRC was concerned with the slow response by senior-r B-1

l' management to thoroughly assess the actions of the operating crew under the direction of the Shift Supervisor and the Assistant Director for Operations.

Further, the licensee's initial actions to assess the event and the actions taken during the event were not sufficient to identify the numerous errors and problems associated with the event. This required the licensee, aftei discussions with the NRC, to reassess the event and submit a second corrective action plan for NRC review.

B. PROCESS B.1 INITIAL NRC RESPONSE -

a. Initial notification and NRC management discussion of the known facts and 4

issues were conducted on September 5,1996, upon notification of the event.-

b. Region lliidentified the need for an NRC specialinspection to specifically address the event and licensee actions pertaining thereto. The special

inspection was started on Septernber 5,1996, and concluded on October 4, 1996. Based on the event and the preliminary findings from the special inspection a second inspection was initiated. The second inspection, an

Operational Safety Team inspection (OSTI) commenced on September 16, 1996, and concluded on October 4,1996,

c. Based on the event and the slow and limited management response to the event, the NRC issued a CAL No. Rill 96-013 on September 11,1996.

4 Based on the information identified through the Special and OSTI inspections, further discussions are being held to determine whether additional actions in this area are needed to ensure the licensee is fully 4

aware of NRC concerns.

B.2 NOTIFICATIONS

a. Issue Daily and Directors Highlight: Unknown

b. Issue Preliminary Notification (PN): - PN 96-058 issued

. 9/6/96

c. Conduct Commissioner Assistants' Briefing: None conducted

d. Issue Commission Paper: None issued B-2

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B.3 ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS a.- edter reviewing the preliminary finding fra the two inspections, a Restart Panel was established on October 29,1996.

Senior Executive Service Oversight: James Caldwell, Director, Division of Reactor Projects (DRP),

Region lli Assistant: Gail Marcus, Project Director, PD 3 3 Team Leader: Geoffrey Wright, Restart Manager, Division of Reactor Safety, Region lli Team Members: Fred Brown, Acting Senior Resident inspector Doug Pickett, Pro}ect Manager, Nuclear Reactor Regulation (NRR)

Karla Stoedter, Resident inspector (RI), CPS Ron Langstaff, Acting RI

- Dave Zemel, Illinois Department of Nuclear Safety (IDNS)

b. Information Available for Review:-

Inspection Reports: 50-461/96-009,10,11,12,13,14,15,16 50-461/97-001 (Systematic Assessment of Licensee Performance (SALP) Report) 50-461/97-002, 3, 5, 6 Confirmatory Action Letter (Rlli 96-013)

Confirmatory Action Letter (Rill 97-OO1)

Confirmatory Action Letter (Rlli 97-OO6)

Licensee Action Plan dated September 24,1996 Licensee Event Assessment dated September 22,1996 i Licensee Startup Readiness Action Plan (SRAP) dated December 9,1996 Licensee Response to CAL Rlli-97-OO1. dated July 2,1997 Licensee Corrective Action /Self Assessment Program Improvements letter dated July 3,1997,

c. Conduct Regional Administrator Briefing STATUS: COMPLETE

d. Develop Case Specific Checklist STATUS: COMPLETE

. e. Develop CPS Restart Action Plan STATUS: COMPLETE B-3

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f. Obtain NRR Projects input for Action Plan i

STATUS:-- COMPLETE j

g. - Division Director's Approval of Restart Action Plan STATUS: COMPLETE h.- Implement Action Plan STATUS: . COMPLETE i . Modify Confirmatory Action Letter (CAL) as Necessary STATUS: No modifications ' wore necessary. -

l' = B.4 REVIEW IMPLEMENTATION p

! B.4.1 ' Root Causes and Corrective Actions <

[, -a. Team has evaluated findings from the special and OSTI team inspections.

E STATUS; COMPLETE: Escalated enforcement actions against lilinois ,

i Power (IP) and individuals proposed. Enforcement for

. September 5,1996 event, radiation protection issues, High 4 Pressure Core Sprey (HPCS), Emergency Diesel Generator l - (EDG) inoperabi!ity, and feedwater check valve failures has been issued. Actions ~against individuals from the 4- September 5,1996 event were limited to a letter to the twt.

,. senior individuals. An additional escalated enforcement action against IP was issued for safety related breaker reliability 4

Issues.-

i Several apparent violations associated with the administrative procedure on procedure adherence have not been dispositioned ~  ;

i by the NRC, but licensee corrective actions for this problem-~

j~ have been implemented anti were effective. This problem -

does not represent a startup issue.

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L b. Licensee Assessments Performed:

1.- Initial event assessment

2. - Revised event essessment dated September 22,1996 3.- Initial Corrective Action Plan dated September 17,1996-

.4. Revised Corrective Action Plan dated September 24,1996 c - 5. SRAP submitted December 9,1996 a

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I~ c. NRC reviewed the_ licensee's initial event assessment and Correet3ve Action Plan and found them lacking in content and detail. After discussions with the NRC, the licensee revised both documents and resubmitted them. -

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d. Review of Revised Corrective Action Plan and SRAP found them responsive to NRC concems and generally acceptable. CAL Rlll 97-001 was issued to

{' confirm IP commitment to the plans. Two items IP had agreed to were

- added:' emphasis on safety vs. production training and qualitative / qualitative i

' evaluation criteria for IP to assess effectiveness of their programs.

h 8.4.2' Equipment Damage Assessment i

- Licensee assessment of equipment damage caused or contributed to the event.

3 Damage appeared to be limited to the failed reactor recirculation seal package.

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a. Preliminary Assessment on Cause of Seal Damage and Failure i-STATUS: COMPLETE: Dirt and flashing of water to steam, was caused by securing cooling water, which forced the second stage seal faces apart appeared to be the primary cause.

b. NRC Evaluation of Licensee's Damage Assessment

- STATUS

COMPLETE: NRC observed seal disassembly and inspection, j

Licensee's assessment was consistent with seal condition.

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. c. Licensee Determined Corrective Actions STATUS: COMPLETE:

1. _ Old seal package removed, new package installed.

Questionable discussions on installing the new seal package with the primary system hot and knowre -

isolation valve leakage. Plant was cooled down prior to work being performed.-

2. Disassembly of failed seal package reve'aled that dirt was the most probable initial failure mechanism.

3. Licensee has sent seal components out for more extensive analysis.

4. - Licensee has assembled an engineering team to resolve long standing reactor recirculation pump seal e degradation problems at CPS.

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d. NRC Evaluates Corrective' Actions STATUS:- COMPLETE: Immediate corrective action for failed seal was comprehensive and'wellimplemented.

B.4.3 Determine Restart issues and Resolution

a. Review / Evaluate Licensee Generated Restart issues STATUS: COMPLETE: Initial review against special and OSTI inspections identified deficiencies in IP's restart issue list.

NRC discussions with IP subsequently resolved issues. IP submitted restart issues list on December 9,1996. - ,

b. Independent NRC Identification of Restart lasues STATUk COMPLETE:l Augmented resident team developed restart issues list. The list was used to assess IP's restart issues in B.4.3.a. Issues were included in IP's SRAP, which was confirmed through a CAL,

c. NRC/ Licensee Agreement on Restart issues SIATUS: COMPLETE: NRC and IP agreed on issues list and IP submitted its SRAP on December 9,1996,

d. Evaluate Licensee's Restart lasues implementation Process STATUS. COi4?LETG: An interim readiness inspection was performed during the _ week of January 6,- 1997.L Augmented resident inspection activities continued to monitor implementation of the licensee's corrective actions.- This inspection was -

documented in inspection Report 50-461/97012.

e. Evaluate Licensee's Implementation Verification Process STATUS: COMPLETE: Same as B.4.3.d. Program is having a positive impact on designated activities.. ,

' B.4.4 Obtain Comments STATUS: COMPLETE: Obtained comments and agreement on restart

. issues from NRR - Doug Pickett, Gail Marcus, and Cynthia Carpenter.

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h. B.4.5 - Closeout Actions I

i-When the actions to resolve the restart issues and significant concerns are  ;

substantially complete, closeout actions are needed to verify that planned l inspect!ons and verification are complete. The licenses should certify that corrective actions required before restart are complete and that the plant is physically ready for restan.

F 4 a. Evaluate Licensee's SRAP (Region)

STATUS: COMPLETE: Bi weekly meetings with final meeting conducted -

on July 3,1997, indicated appropriate understanding of past i issues and remaining issues effecting restart.

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~ b. NRC Evaluation of Applicable items from Section C " Issues" Complete 1

[ STATUS: COMPLETE: See Section C.

i c. Restart issues Closed STATUS: - COMPLETE: Allidentified restart issues have been resolved.

i Major issues were associated with the three CALs, safety related breaker operability / reliability, containment coatings, j and degraded voltage.

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d. Conduct'NRC Restart Readiness Team Inspection (Region) l STATUS

NOT APPLICABLC Due to the human performance issues and the protracted nature of the outage, resident and regional based inspections conducted throughout the outage were i focused on assessing licensee readiness to restart.

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c. Issue Augmented Restart Coverage inspection Plan STATQS; COMPLETE: - Plan development hour coverage is to be provided by residents and supplemented by other site residents and regional personnel. Coverage will continue ~ over a 2-week period.

- f. - Comments from Other Parties Considered ,

STATUS:' COMPLETE: Comments solicited from NRR Projects and resident office. Input obtained from NRR indicated no restart issues associated with human factors, safety related breaker, or containment coatings issues.

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g. Determine That all Conditions of the Order / CAL are Satisfied STATUS: - COMPLETE: Letter from A. Bill Beach, Rill Regional Administrator to John Cook of IP.

h. Re review of Generic Restart Checklist Complete STATUS: COMPLETE: See Section C.

B.5 RESTART ACCEPTANCE

. a. Prepare Restart Readiness Review and Basis Document STATUli COMPLETE: Contained herein,

b. NRC Restart Panel Approves Restart Readiness Review STATUS: COMPLETE: Contained herein,

c. No Restart Objections from Other App!! cable HQ offices.(NRR, Analysis of Events and Operational Data)

STATUS: COMPLETE: No objections from NRR on containment coatings or human factors issues.

d. NRR Concurs with Restart Readiness Review STATUS: COMPLETE: Contained herein.

e. Regional Administrator Approves Restart Readiness Review .

STATUS: COMPLETE: Contained on cover memorandum to this document.

B.6 RESTART AUTHORIZATION NOTIFICATION Notify the applicable parties of the restart readiness review approval. Notifications should generally be made using a memorandum or other format consistent with the level of formality required. Communication of planned actions is important at this stage to ensure that NRC intentions are clearly understood, a, .Public Affairs (Region)

STATUS: COMPLETE: Notification made by DRP.

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b. IDNS (Region)

STATUS: COMPLETE: Notification made by DRP.

c. Additional notification to be considered: Executive Director of Operations (EDO), NRR STATUS: EDO consultation indicated by Regional Administrator approval of the cover memorandum for this document.

C. ISSUES The following sections contain items for consideration by the Panel during the restart review. These items are based on issues found during other restart reviews.

The experience is primarily based on plant shutdowns due to inanagement deficiencies, hardware issues, or a combination.

C.1 ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION The root cause(s) of the event or the conditions requiring the shutdown should be identified and corrected. A comprehensive licensee corrective action plan should be developed that addresses the root cause(s) and all applicable issues including corrective actions, implementation, and verification. The licensee should revise its corrective cction plan as necessary to on?ure emergent issues are addressed and resolved. The Panel should ensure that emergent issues identified by the NRC are

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promptly conveyed to the licensee for incorporation Mtc the licensee's corrective action plan. The corrective action dan should also include sufficient measures to prevent recurrence of problems. ,1

'C shall review the licensee's corrective action plan to verify its completr.m: ' adequacy and to determine which corrective actions will be require . - olemented before restart and which can be deferred to some later date as <

orrective actions.

The NRC will review the licensee's cot. action activities and use the tools available in the regulatory program to determine the acceptability of these actions with respect to safe operations. These tools include staff reviews the SALP report; inspections, including special team inspections; requests under 10 CFR 50.54(f); senior management meetings: enforcement conferences; and a Restart Panel. The results of the NRC staff's reviews will be documented as appropriate by safety evaluations, licensee amendments, orders, CALs, in.spection reports, Commission meeting transcripts, and enforcement documents.

C.1.1 Root Cause Aesessment

a. Conditions Requiring the Shutdown are Clearly Understood STATUS: COMPLETE: Reactor recirculation pump seal package failures are a continuing problem at the CPS. Initialinspection of the failed seal package revealed dirt as a prime contributor to the B-9

initial seal package leakage. Operational decisions during loop isolation activities may have contributed to ultimate seal package f.milure.

The causes for poor operational and management decisions can be generically attributed to a lack of conservative decision making and possibly economic pressures.

b. Root Causes of the Conditions Requiring the Shutdown are Clearly Understood STATUS: COMPLETE: Root cause for failure of the specific sealis believed to be dirt. Cause(s) for continued seal package failure for Pump B is not yet fully understood. Special IP engineering team planned to assess all Pump B failures.

Excessive leakage during event attributed to the flashing of water to steam and forcing seal stage faces apart,

c. Root Causes of Other Significant Problems are Clearly Understood STATUS 1 COMPLETE: Causes for out of service equipment, poor decision making, poor engineering support, poor understanding of design basis and 10 CFR 50.59 safety evaluation process traced to a number of issues: Shift in focus over time to increase the importance of production, lack of knowledge, lack of management expectations, lack of attention to detail, etc.

Major cause of issues are addressed in IP's SRAP of December 9,1996,

d. Effectiveness of the root cause analysis program STATUS: COMPLETE: Initial event assessment by the licensee was not comprehensive. Subsequent assessment was improved.

Subsequent assessments were adequate - some issues well addressed others required NRC input. Overall program is adequate with improvements planned long term.

C.1.2 Damage Assessment ,

a. Damage Assessment was Thorough and Comprehensive SJATUS: COMPLETE: Licensee's assessment of seal package failure has, to date, been both thorough and comprehensive, f

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A performance, especially in the procedural adherence and

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quality areas. Long term corrective actions, including a modified Diagnostic Evaluation Team (DET) inspection are -

--scheduled following restart of the ur*,

f. Control of Long Term Corrective Actions STATUS: . COMPLETE: IP,in addition to the SRAP and the Strbt::gic Performance improvement Plan, has developed a long term 4

action plan to address those issues which are not of immediate j significance to safe plant startup. Refer to IP's July 3,1997 letter on corrective actions and self assessments.

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g. Effectiveness of the Corrective Action Verification Process 4

STATUS: COMPLETE: Corrective action verification process for actions

[ associated with the September 5,1996 event and associated issues have'been handled adequately. Initial actions treated

actions as a check list without sufficient emphasis on

!: effectiveness. Recent activities on closure of CAL items have

[ included discussions on action effectiveness, t .. l C.1.4 Self-Assessment Capability  !

,.The occurrence of an event may be indicative of potential weaknesses in the licensee's self-assessment capability. - A strong self-assessment capability creates an environment where problems are readily identified, prioritized, and tracked.

4 Effective corrective actions require problem root cause identification, solutions to correct the cause,' and verification methods _that ensure the issue is resolved. The effectiveness of senior licensee management in ensuring effective self-asassament is treated separately,

y a.-. . Effectiveness of Quality Assurance (QA) Program 1 STATUS

COMPLETE: IP recognizes OA program was not effective in identifying the problem and trends associated with the

-September 5,1996 event Plans are in place,'along with a new Nuclear Assessment Director, to review the program and .

identify c. orrective actions. Ownershi,p of the Corrective Action process vested in a newly created middle level management position. _Intcaration of the assessment and corrective action functions was emphasized by creation of a ,

. new senior level management position.  !

b. Effectiveness'of Licensee's ' independent Review Groups STATUS: COMPLETE: As with other OA programs, independent Safety Engineering Group (ISEG) reviews did not identify the B-12

significant performance issues at CPS. Subsequent reviews of ISEG activities indicates improved assessment of information for example, reviews of surveillance tests for adequacy identified a number of deficiencies,

c. Effectiveness of Deficiency Reporting System STATUS: COMPLETE: The program, prior to September 1996, had a very high threshold for reporting issues on condition reports.

Subsequent changes in management expectations has significantly lowered the threshold. Since August 1996, there has been a substantial increase in the number of issues being reported via condition reports. Recent changes have included i

application of the system to the radiologically protected area.

Long term monitoring required to assess effectiveness.

d. Licensee Staff Willingness to Raise Concerns STATUS; COMPLETE: Discussions with individuals from the line and QA organizations indicates staff is willing to raise concems, increased number of condition reports issued also indicates people are raising and documenting concems,

e. Effectiveness of Probabilistic Risk Assessment (PRA) Usage STATUS: COMPLETE: It did not appear that PRA was used in the past to assess collective impact of control room deficiencies.

- However, recent observations have indicated that PRA is being used to evaluate plant conditions and being used to input into decisions on equipment outages.

C.2 ASSESSMENT OF LICENSEE MANAGEMENT EFFECTIVENESS Evaluate the effectiveness of the licensee's management in assessing, evaluating, and resolving the problems and the associated root causes that resulted in the plant shutdown and contributing problems. Licensee management effectiveness should be measured against the results achieved by the licensee. The results should j demonstrate a coordinated and integrated approach to resolving the problems and developing corrective actions, the problems and corrective actions should be assigned priority consistent with their safety significance. Licensee's management must demonstrate an ability to recognize safety problems, develop and implement adequate corrective actions, and verify the effectiveness of the corrective actions in

- a timely manner.

4 B-13 g e , ,- -

I C.2.1 Management Oversight and Effectiveness  !

a. {

Goals and Expectations Communicated to the Staff SIAT13; COMPLETE:

Action has Human performance hasimbeen taken to address this area.

term vigilance is necessary, proved; however continued long b.

Demonstrated Expectation of Adherence to Procedures STATUS; COMPLETE:

After extensive NRC involvement and subsequent enforcement action, the licensee developed regulatory compliant procedure adherence program and procedure change program. Licensee management has expressed its expectations on procedural adherence. All plant staff received extensive training on the new requirements, improved performance in this area has been documented in routine NRC r'sident inspection reports.

c.

Management involvement in Self Assessment and independent Self-Assessment Capability STATUS: COMPLETE: Third party (Institute of Nuclear Power Operations, contractors) assessments have been good.

Internal management assessment in one case was not well documented regarding findings and recommendations, d.

Effectiveness of Management Review Committees

' STATUS; COMPLETE:

In general, improvements in critical assessment of CPS activities improvements have been were necessary, noted in areas where continued e.

Management's Demor'strated Awareness of Day-to-Day Operational Concerns STATUSl COMPLETE:

Acceptable communication, in general, between plant managers and directors. Through observation of the engineering and 8:15 a.m. licensee m,eetings, individuals appear knowledgeable of current operationalissues.

f.

Management's Ability to identify and Prioritize Significant issues STATUS; COMPLETE:

Performance in this area is adequate. The licensee has had success in this area where improvements were needed. For example, a supervisor's involvement with an employee's failure to follow procedures while exiting the site through a radiation monitor on March 9,1997, was B-14

_ ~ __ _ _. _

l handled effectively; on the other hand, the significance of the March 9,1997 situation was not appreciated until NRC was

~

involved. The February plant wide " stand downs" are another example where appropriate actions were taken in response to continuing performance errors,

g. Management's Ability to Coordinate Resolution of Significant issues STATUS: COMPLETE: Licensee implemented the Recovery Team to monitor and assess effectiveness of corrective actions required

for plant restart.

h. Management's Ability to implement Effective Corrective Actions STATUji COMPLETE: There are indications that corrective ections have improved.

C.2.2 Managament support

a. impact of Any Management Reorganization STATUS: COMPLETE: Management changes immediately after the September 5,1996 event and additional changes based on performance in various areas were taken by IP. Most recently, 4

a new senior level management position was created to ensure appropriate focur en.300ce mant and to maintain corrective actions in the long term. Human perfctmance has improved in the last three months, b Adequate Engineering Support as Demonstrated by Timuy Resolution of issues STATUS: COMPLETE: A significant issue had been identified in the September 5,1996 event with additional findings by the OSTI.

More recent observations indicate improved support.

Engineering identification of surveillance acceptance criteria deficier.cios and additional voltage issues indicate improved ergineering support.- Current issues associated with Strategic Performance improvement Plan for system assessments has produced positive results. ,

c. Adequate Plant Administrative Procedures STATUS: COMPLETE: The revised Operab!!ity Assessment document was considered good. The new 10 CFR 50.59 implementation document was considered adequate. Further, the revised upper tier procedure adherence document and procedure B 15

change document removed policy disconnect between expectations and written guidance and were considered to be -

adequate.

C.3- ASSESSMENT OF PLANT AND CORPORATE STAFF EFFECTIVENESS The licensee's staff must be capable of recognizing and carrying out their

! . responsibilities to ensure public health and safety, Plant and corporate staff effectiveness should be assessed on the basis of the results achieved by the licensee.: A proactive attitude toward safety issues should be demonstrated in all aspects of operations. In this regard, the iicensee's staff should display attentiveness to duty, fitness for duty, a disciplined approach to activities, a j- sensitivity for trends in the plant, security awareness, and openness of communications, and a desire for teamwork that supports effective relations between different groups (e.g., management, operatiods, health physics, maintenance, engineering, security, and contractors).

C.3.1 Assessment of the Licensee's Staff .

a. Demonstrated Commitment to Achieving improved Performance STATUS: COMPLETE: Improved performance indicates the licensee's staff is more attuned to performance issues. There is still skepticism about long term management commitment on the part of licensee staff. DET scheduled for shortly after unit l restart.

- b .- Demonstrated Safety Consciousness STATUS: COMPLETE: Examples indicate improvement in this area; however, there are events continuing which indicates not i everyone in the staff is thinking along these lines. DET scheduled for shortly after unit restart.

c. Understanding of Management's Expectations and Goals-STATUS: - COMPLETE: Generally, personnel seem to understand expectations and goals. February " stand downs" provided another opportunity for management ,to present its expectations. The licensee's staff participate in the discussions. Indications are that staff willimplement management expectations and goals when the expectations are clearly and consistently defined.-

d. Ot:derstanding of Plant issues and Corrective Actions -

STATUS: COMPLETE: The licensee's staff understand the issues and corrective actions for the September 5,1996 event.

B-16

, __. - ~ _ . _ _ . _ . _ _ _ . _ _ _ _ _ .. _ _ _- - . .. _ . _ . - _ _

4 -s Indications are that staff understands the need for additional corrective actions as well, but some examples of resistance to change have been observed by inspectors,

e. - Qualifications and Training of the Licensee's Staff STATUS: COMPLETE: Training observed by the NRC team was '

appropriate. No significant qualification or training issues were i identified in the Operations Department. Examples of inadequate training of the Maintenance Department staff were

. noted and cited, immediate corrective actions were

implemented in each case. DET scheduled for shortly after unit restart.

f. Level of Attention to Detail-STATUS: COMPLETE: Improvements were observed in procedure

content and usage. However, some errors were still being made, but not at a level or frequency which created a clear p safety concern.

g. Licensee Staff's Overtime Usage e

4 STATUS: COMPLETE: Overtime usage, wnile high, is within NRC guidelines.

h. Procedure Usage / Adherence STATUS: COMPLETE: While there are notable examples of continued problems in this area, there was significant improvement following implementation of new procedural .use guidance and c rew temporary change procedure at the beginning of April 1997. Current performance is considered adequate.

C.3.2 Assessment of " Corporate' Support (THIS ITEM WAS REMOVED BECAUSE THERE IS NO " CORPORA TE' SUPPORT ORGANIZA TION. AlL SUPPORT FUNCTIONS ARE ON SITE.)

a. Corporate Staff Understanding of Plant Issues ,

b. Corporate' Staff Site Specific Knowledge.

c. Effectiveness of the Corporate / Plant Interface Meetings d.. Corporate involvement with Plant Activities Effectiveness of Licensing Support e.

B-17

-- - . _ + .- , . , - - - , - -,-

._.___._._,.__7._

. i l

C.3.3 Operator issues

a. Level of Formality in the Control Room - Crew Consistency -

l STATUS; COMPLETE: Substantialimprovement observed by the NRC '

team While problems of consistency continue to be noted, overall performance is adequate.- Performance will be '

i- monitored during startup as documented in attachment C of the cover memorandum for this document.

4 j b. Effectiveness of Control Room Simulator Training STATUS: COMPLETE: Observed training is effective and addressed NRC concems.

c. Control Room / Plant Operator Awareness of Equipment Status STATUS: COMPLETE: Observations and discussions with operating crews indicates improved awareness of equipment status and ,

examples indicate a more questioning attitude by the operators. A few examples continue to exist where individuals ,

are not fully aware of equipment conditions. Follow-up will be '

- performed as described in Attachment C.

d. Adequacy of Plant Operating Procedures STATUS: COMPLETE: Recent reviews by operators have identified a number of procedural corrections and enhancements. Changes are being prioritized based on significance to unit startup.

Additional raview were conducted to ensure procedures could be processed under the new guidance on procedure adherence, CPS Procedure 1005.15.

e. Procedure Usage / Adherence STATUS: COMPLETE: General procedure adherence in operations has improved. Operators indicate that the old phil6 sophy that procedures provided guidance and could be interpreted loosely has been replaced with a philosophy that procedures are to be performed as written or changed.

f. Log Keeping Practices STATUS: COMPLETE: Licensee control room log keeping practices are consistent ,with the licensee's expectations.

B 18

i l

C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT The licensee should identify the causes of significant equipment prob %rr s and take approorlate corrective actions. Operation?! testing should verify that each signi! leant equipment problem has ' een resolved. Testing may need to be expanded to cover complex type problems.

The licensee must be able to demonstrate that all needed safety equipment is operational before restart. Systems and equipment need to be available and aligned. Surveillance tests should be up to date. Maintenance backlogs should be t managed at controllable levels and should be evaluated for impact on safe operat6n. Maintenance personnel must also be capable of responding to equipment failures during startup and operation and should t'ot be hindered by unresolved chronic problems with equipment. Procedures should be adequate and current,

a. Operability of Technical Specification Systems STATUS: COMPLETE: Verified through augmented resident staff inspection activities. See also Attachment C.

b. Operability of Required Secondary and Support Systems

'61MS1 COMPLETE: Verified through augmented resident staff inspection activities. See also Attachment C.

c. Results of Startup Testing STATUS: COMPLETE: Verified through augmented resident staff inspection activities. See also Attachment C.

d. Adequacy of System Lineups STATUS: COMPLETE: Verified through augmented resident staff inspection activities. See also Attachment C.

v. Aduquacy of Suiveillance Testarrest Program STATU3: COM9LETE: Being verified through augmented resident staff inspection activities. See also Attachment C.

f. Significant Hardware lasues Resolved (i.e., damaged equipment, equipment ageing, modifications)

STATUSi COMPLETE: 1. Reactor Rasulation Pump Seal has been replaced; 2. Safety related breakers have been inspected, tested, and/or refurbished: 3. Degraded containment coatings have been removed, re-coated, and pull tested: 4. Main B 19

?-

f

.n control room neon bulb sockets have baan replaced; D.

Licensee requested a TS exemption from NMR for degraded 345 kV line; 6. Licensee was in the process of verifying components in the EDG toom qualified to 140'F, equivalent to 112*F outside temp. Licensee raswered questions to sequests for additional information from NRC.

g. Effectiveness of the Plant Maintenance Program STATUSl COMPLETE: Licensee is continuing to asms work practices .

and control. Initial NRC essessment dLi net identify any restart issues. However, a recent issue was luontified by the NRC on exceeding deadlines for completing safety and non-safety related equipment PMs. A computer progra error -

caused 1,464 PMs deadlines to be exceeded.

h.- Maintenance Backlogs Managed and impact on Operationt Assessed STATUS: COMPLETE: Initial review of ma'.ntenance work requests to remain open after plant restart did not Identify any significant safetu issues. The licensee will address the 1,464 PM bccklogs 'oy perforrning the necessary PMs and/or conducting an engineering evaluation to justify not completing the PMs

- before plart restart.

l. Discrepancies Between As Built Facility and Updated USAR Evaluated STATUS: COMPLETE: IP compiled list of known USAR discrepancies.

Actions have been taken to change USAR, change facility, or evaluated to ensure no unreviewed safety quastion exists.

NRC reviewed a sample and did not identify any start up lasues.

J. Degraded But Operable Equipment Evaluated STATUS: COMPLETE:--IP identified degraded but operable equipment and developed safety evaluations for each cas4. Mode =

restraints were applied for the appropriate equipment. NRC did review a sample of these items, SWre the eleciU05:!ssues reose, and did not identify any stsrt up issues.

C.5- - ASSESSMENT OF COMPLIANCE WITH REGULATORY REOUIREMENTS ,

a.: . Applicable License Amendments Have Been lasued STATUSI COMPLETE: licensee requested a License amendment for availability of 345 kV offsite power source and exemption for General Design Criteria 17.

B 20 -

Y

. \

b. Imposed Orders Have Been Modified or Roscinded S.IAT.LLSI COMPLETE: No Orders were written.

c. CAL Conditions Have Boon Satisfied STATUS: COMPLETE: Cats No. Alll 96 013,97 001, and 97 006 will be closed via a letter from A. Bill Beach, Rlil Regional Administrator to John Cook of IP.

d. Significant Enforcement lasues Have Been P.esolved STATUS: COMPLETE: Enforcemer% actions associated with September 5,1990 event, radiation protection, feedwater check valves, HPCS, EDG operability, and safety related breaker rollability were issuod. Additional examples of apparent violations associated with the administrative procedure on procedure usage have not been dispositioned; however, corrective actions have been taken and have been verified to be offective.

e. Allogations Have Been Appropriately Addressed STATUSj COMPLETE: Special review of outstanding allegations did not identify any startup !asues.

C.6 COORDINATION WITH INTERESTED AGENCIES AND PARTIES

a. Department of Justice: Investigation into Wrongdoing During Unit Shutdown by Office of Investigation (01)

STATUEt- COMPLETE: Two 01 investigations were complete. Letters issued to two individuals for September 5,1996 event, and a deteimination of no violation due to procedural issues in another event. No further 01 involvement anticipated, and no open actions left,

b. Appropriate State and Local Officiata STATUS: COMPLETE: IDNS onsite inspector participated in evaluating the completion of the licensee's SRAP ltem.

B 21 l

litM DESCRIPTQw LICENSEE NRC ACTION CLOSCOUT NUMDER ACTION STATUS LETTER STATUS B.1 initial NRC Reeponse N/A Comsdete N/A B.2 Notificatione N/A Complete N/A B.3 Establieb and Orgenlas NRC toview procese N/A Complete N/A B.4.1 Root Causes and Corrective Actione N/A Complete N/A B.4.2 Equipment Demese Aseeeement N/A Complete N/A B.4.3 Determine Reetort leaves and Resolution

e. Review /evoluete licensee generated testert ineues N/A Complete N/A

b. Independent NRC identification of testert issuee N/A Complete N/A

c. NRC/ lice sees agreement on testert leeues N/A Complete N/A

d. Evaluate licensee's teetort leaves implementation N/A Cornplete N'A procese

e. Evoluete liconese's irre:ementation ver6fication process N/A Complete N/A

f. Otitein NRR Projects input for Action Plan N/A Complete N/A

g. Division Director's approval of Restert Act6on Plan N/A Complete N/A

h. Implement Action Plan N/A Complete N/A

1. Modify CAL es necessary N/A Complete N/A B.4.4 Obtain commente on Plan N/A Complete N/A -

B.4.5 CLOSEOUT ACTIONS

e. Evelvete liconeee's testert tendinees self eenessment N/A Complete N/A

b. NRC evaluation of appliceblo items from Section C N/A Complete N/A ,

'lSSUES"

c. Restert issues closed N/A Complete N/A

d. Conduct NRC teatert readiness teem inspection N/A N/A N/A

e. leeue augmented restert coverage inspection plan N/A Complete N/A

f. Comment from other parties considered N/A Complete N/A

g. Determine that all conditions of the CAL have been N/A Complete N/A estisfied

h. Re review Genetic Restea 4 Checklist N/A Complete N/A B.5 RESTART ACCEPTANCE

e. Prepare Restart Rooiness Review and beeis document N/A Complete N/A

b. NRC Restert Penei approves restert feediness review N/A Complete N/A B 22

---___._._.__-.__.m._..-.-_._.- ~. ,

9

(

3 i ITEM .li-!*'*!!04 LICENSEE NRC ACTION CLOSEOUT NUMBER ACTION STATUS LETTER STATUS

c. No testert objections from other applicable HQ offices N/A Complete N/A (NRR, AE00, etc.)

d. Regional Administrator Approves Restert Reedmose N/A Cornplete N/A Redew 8.6 RESTART AUTHORIZATKW NOTFICAtl0N e, Public Affaire (Region) N!!, Cv4Gtt N/A

b. IDNS (Region) N/A N/A Comtdete 1

c. Additional Notification to be considered -

1. CormWooion (NRR) N/A NOT REQUIRED N/A

2. EDO(NRR) N/A Complete N/A

3. Congresolonel Affaire (NRR) N/A NOT REQUIRED N/A 4 ACR$ (NRR) N/A NOT REQUIRED N/A l

i

)

J B-23

i 4

ITEM DESCRIPTION LICENSEE NRC ACTION CLOSEOUT NUMBER ACTION GTATUS LETTER STATUS C 164UES C.1 ASSES 4 MENT OF ROOT CAUSE IDENTIFICATION AND CORRECT 60N C.1.1 Root Cause Aeoesoment

e. Condition requiring the e%tdown are clearly N/A Complete N/A urderstood e-,_

b. Root Causes of corvhtione requiring shutdown are N/A Complete N/A cleerfy understood

c. Root causes of ether significant prot,lems oleerfy N/A Complete N/A underetood

d. Effectivenese of toot cause snelysis program N/A Complete N/A C.I.2 Damage Aeoseen.ont

a. Damage essessmeril wee thorough and comprehensive N/A Complete N/A

b. Corrective actione clearly testored system and N/A Complete N/A equiptnent C.1.3 Corrective Actione

e. Thoroughness of the corrective action plan N/A Complete N/A

b. Completeness of corrective action programe for e ooitio N/A Complete N/A toot causes

c. Control of corrective action item tracking N/A Compiele N/A

d. Effective corrective actions for the conditione requiring N/A Complete N/A the shutdown implemented

e. Effective corrective actions for other probleme N/A Complete N/A implemented

=

f. Control of long-term corrective actione NIA Complete N/A

g. Effectiveness of the corrective action verification N/A Complete N/A process C.I.4 Self-Aseecament Capability

e. Effectiveness of Quelty Assurance Progtsn N/A Complete N/A

b. Eff ectivenees of licensee's independent Review Groupe N/A Complete NIA

c. Effectivenese of deficiency reporting system N/A - Complete N/A

d. Staff willingnese to reise concerne N/A Complete N/A

. e. Effectivenose of PRA usage N/A Complete N/A C.2 ASSEA& MENT OF LICENSEE MANAGEMENT EFFECTIVENESS B 24 4

A,- , .-mr.-.c -. e , - m- , + , , . , . - . . . - _ . -,.-,e. ~, % ,,.,. ,,.m.-- , - . , , ,-r, - ,-. ---r

ITEM DESCRIPil0N LICEN$tt NRC ACTION CLOSE0VT NUMBER ACTION STATUS LETTER STATUS au-C.2,1 Management Overolght & Effectiverwee

a. Goals and expectatiorw communionted to the staff N/A Complete N/A

b. Demonstreted expectations of adherence to procedures N/A Complete N/A

c. Management involvement in self eesessment & indep. N/A Complete N/A self essessment capeWisties

d. Effectiveness of management review committee N/A Complete N/A

e. Management owerenese of day to-day operational N/A Complete N/A concerne

f. Managemente atsihty to identify arxi prioritire significant N/A Complete N/A issues

g. Management's abihty to coordmate teeolution of N/A Complete N/A significant leeues

h. Management's atWhty to implement effective corrective N/A Complete N/A actione C.2.2 Manecement support

a. impact of any management teorganization N/A Complete N/A

b. Adequate engineering support; demonstrated by timely N/A Cornplete N/A issue resolution

c. Adequate plant admit 9strative procedures N/A Complete N/A C.3 ASSESSMENT OF PLANT AND CORPORATE STAFF LFFECTIVENESS C.3.1 Assosoment of Staff

e. Demonstrated commitment to schieving improved N/A Complete N/A performance

b. Demonstrated safety consciousnese letA Complete N/A

c. Understanding of management's expectatione and N/A Complete N/A goals

d. Understanding of plant leeues and cosrective actions N/A Complete N/A

o. Qualification and training of the staff N/A Complete N/A

f. Level of attention to detail N/A Complete N/A

g. Ctaff overtime usage N/A Complete N/A

h. Proced are usage / adherence N/A Complete N/A C.3.2 Assessment of *Corporete* support N/A NOT N/A APPLICABLE

a. corporate staff understanding of plant issues N/A NOT N/A APPLICABLE

, B 25

. - . _ . . - . . - _ - - - . . ~ _ . - - . . . - . - - - . - --- -

=

fitM DESCRIPTION LICENSEE NRC ACTION CLCtt0UT NUMBER ACTION STATUS LETitR STATUS j b. Corpotete steff de specific knowledge N/A NOT N/A APPLICABLE I c. Effectiveness of corporate / plant interface ~aetmge N/A NOT N/A APPLICABLE

d. Corporate involvement with plant activities N/A NOT N/A APPLICABLE l e. Effectiveriese of beeneing support N/A NOT N/A APPLICABLE .

C.3.3 Operator leeues

e. Level of formality in the control room + orew N/A Complete N/A consistency

b. Effectiveneet of control foom simulator training N/A Complete N/A

c. Control room / plant opetetot awarenees of equipment N/A Complete N/A

etetus 1

d. Adequacy of plant operating procedures N/A Complete N/A

e. Procedure usageledherence N/A. Complete N/A

, f. Log kooping ptocthee N/A Complete N/A C.4 ASSESSMENT OF PHYSICAL READINESS OF THE PLANT

$ e. Operability of technical specification systeme N/A Complete N/A

b. Operabihty of required escondary and support systema N/A Complete N/A

c. Roeults of pre-startup testing N/A Complete N/A

] d. Adequacy of system ieneupe N/A Complete N/A

e. Adequacy of eurveillance teste/ test progtem N/A Complete N/A

f. Significent hardwere leeuse resolved N/A Complete N/A

g. Effectivenese of the plant maintenance program N/A Complete N/A

h. Maintenance backlog managed and impact on N/A Complete N/A operatione essessed

1. ' US AR discrepancies evaluated N/A Complete N/A j, Degraded but operable equipment evaluated N/A Complete N/A C.5 ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS e, Applicable licones amendments have been leeues N/A Complete N/A (Offelte powet availability & GDC 17 partial exemption)

b. Imposed Orders have been modified or teocinded N/A Not Applicable N/A B 26 s

i e, - - ,-- --=e

_ -_- . ~ . . , _ _ _ _ _ _ . . _ . _ _ _m-__

__-_m.,- -

f litM DESCRIPTION UCENSEE NRC ACTION CLC$t0UT NUM9(R ACTION STATUS LETTER  !

STATUS

o. Confirmatory Action Letter (s) conditions have been N/A Complete N/A eatiefied

[

d. Significent enfoteement leaves have been tesolved N/A Complete N/A  ;

e. Allegations have been appropriately oddressed N/A Complete N/A C.6 COORDINATION WITilINTERESTED AGENCIES AND PARTIES

e. Department of Justice . 01investigsteons into wrong N/A Complete N/A  ;

doing during urut shutdown

b. Appropriate State end Local officiele: IDNS N/A Complete N/A i

i i I i

I i

4 P

I 1

1 6 27 i

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lit M DE SCetiPTION LICENstt NRC ACTION CLOSEOUT NUMDE R ACTION ftTATUS LETTER STATUS l.1 Adequacy of polecy statemente and generet procedures Venfied Closed by panel IR 50-tegarding conduct of operations and procedure complete. 5/8 461/97012 conpliance considered effective 1.2 Som. net on procedure compliance Ve1fied Closed by panel IR 50-complete, 5/8 461/97012 considered offective l

La special procedure review for selected topice g Verified Closed by penet IR 50- l Complete 4/28 461/97012 1.4 S6mulator proctice for operating crews Verified Closed by panel IR fA Complete 4/28 461/97012 )

1.5 Revised Critique process Verified Closed by panel IR 50-Conviete 6/3 461/97012 1.6 Procedure con *liance, seninaro Venfied Closed by panel IR 50-complete, 6/3 461/97012 considered effective 1.7 Now fuel procedures Ventied Closed by panel IR 50-Complete 4/28 461/97012 1.8 Monitor Procedure compliance verified Closed by panel IR 50-complete. 5/22 461/97012 considered effective 4.9 Evoluete procedure process Venfied Closed by panel IR 50-complete. 5/14 461/97012 considered effective 1.10 Rosew sys opo procedures Verified Cloend by panel IR 50-Complete 5/14 461/97012 1.11 Review Sury, procedures Verified Closed by panel IR 50-complete. 5/14 461/97012 considered effective 1.12 Review tendom semple Verified Closed by panel IR 50-Complete 4/28 461/97012 1.13 Review comment control fme Venfied Closed by panel IR 50-Complete 4/28 461/97012 1.14 Assess personnel qualifications Verified Closed by panel IR 50-Complete 5/14 461/97012 1.15 Review temp proc. changes Verified Closed by panel IR 50-Complete 4/28 461/97012 1.16 Observe surv. proc. usoge Verified Closed by panel IR 50-Complete 4/?8 461/97012 8 28 f

t ITEM DESCRIPTION LICENSEE NRC ACTION ClostOUT NUMBE R ACTION STATUS LETTER STATUS 1.17 10 CFR 60.69 training Actsons Clo**d by panel IR 60-verified, 6/22 461/97012 considered complete 1.18 Rev6ew ell Standmg Oedere ogninst the 10 CFR 60,69 Verified Closed by panel IR 60-ecreening process, (new item added by licensee Complete 6/22 461/97012 l

1.19 Review Surveillance Procedures for fidelity with Verified Closed by panel IR 00-Technical Specificatione end US AR, Complete 6/3 461/97012

11. 1 Define & doc. conservative deciolon orpoctatione Venfied Closed by panel IR 60-Complete 4/28 461/97012

11. 2 Conservative decision making seminar Verified Closed by panel IR 60-Complete 4/28 461/97012 11, 3 Plant & equip condition limite Verified Closed by panel IR 60-Comp'ete 4/28 461/97012

11. 4 Recognition & Acceptance of errote by 9,6,96 crew Verified Closed by panel IR 60-Complete 6/3 461/37012 11, 6 Plant Manager will rnest with each crew Verified Closed by panel IR 60-Complete 6/3 461/97012

11. 6 Additional plant / equipment condition limite Verified Closed by panel IR 60-Complete 6/8 461/97012

11. 7 Review April 1996 incident Venfied Closed by panel IR 60-complete, 6/22 461/97012 considered offestive

11. 8 Review 60ER 9210 Reducing event through H.P Actions Closed by panel IR 60-verified 6/22 461/97012 complete, but not ready 11, 9 Simulator Reetert Training Verification Closed by panel IR 60-Cornplete 4/28 461/97012 til.1 Review of oversight personnel roles, duties, & Verification Closed by panel IR 60-expectations Complete 4/28 461/97012 111. 2 Oversight personnel roles, duties, & expectatione Verification Closed by panel IR 60-briefmg Complete 4/28 461/97012 til.3 Control room monitoring during startup Verification Partial Closure IR 60-in progress 6/22, review 461/97012 through during startup startyp 111. 4 Startup hold pointe Venficat6on Closed by panel IR 60-Conviete 6/22 461/97012 111. 5 Monitor opere4ond deealon mekk g Venfication Closed by panel IR 60-Complete 6/22 461/97012 B-29

litM DESCRIPil0N UCEN5tt NRC ACTION CLOSEOUT NUMBLR ACTION STATUS LETTER STATUS til.6 Oversight responsibility briefings Verification Closed by panel IR 50-Corrviste 4/28 461/97012 lit.7 Sersor Managemeset Team self critique Verification Closed by panel IR 50-Cornplete 4/28 481/97012 til.8 Lower threshold to irWtiete seeesomente Venfication C(oecJ by panel IR 50 Complete 5/22 461/97012 til.9 Morvtor Lifectivenese of Corrective Actions Venfication Closed by panel IR 50-Convieto 6/3 461/97012 111. 1 0 Corrective Actions for the Work Control Program Verification Closed by panel IR 50-Cormlete 6/3 461/97012 IV.1 Rooire. D. eeni replacement Considered Partial Closure IR b%

complete, 5/14, pending 461/91012 but will . PMT during remain open Startup pending PMT dunng startup IV.2 Drywell floor dram morwtor Venfication Closed by panel IR 50-Complete 4/28 461/97012 IV.3 Drywell equipment dram monitor Verification Closed by panel IR 50-Complete 4/28 461/97012 IV,4 Review outstanding MWRe Verification Closed by panel IR 54 complete. 5/22 461/97012 considered effective IV.5 RF leakage detection systeme Venfication Closed by panel IR 50-Cornplete 6/3 461/97012 IV,6 Leak detection added to process computer Verification Closed by panel IR 50-In Progress 5/22 461/97012 IV.7 Quarterly morwtoring of meterial deficiencies by senior Verified Closed by panel IR 50-more, complete, b/0 461/97012 considered effective IV.8 Review 95 & 96 NRC reporte on material condition Actions Closed by panel IR 50-verified 5/22 461/97012 complete, but not ready IV.9 Operability / Generic Letter 91 18 Verification Closed by panel IR 50-Complete 5/22 461/97012 IV.10 Action plan reviews Venfication Closed by panel IR 50-Complete 4/28 4E1/97012 IV,11 Butterfly valve seismic concerne Verification Closed by panel !R 50-Complete 5/8 461/97012 B 30

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i ITEM DESCRIPTION LICENS(E NRC ACTION l CLOSEOUT NUMDER ACTION STATUS LET1tR STATUS mamousammmmme l IV.12 Redew MWRe oldet then 6 toonthe Venfication Closed by panel IR 60-(

' Conylote, 6/22 461/97012 considered effective IV.13 Feedwater check vehec Will temmin Partial Closure IR 60-open until 6/14, pending 461/97012 eftet startup Post Startup Rev6e w IV,14 GL. 96.06 Verifecation Closed by panel IR 60-In Progrese B/22 461/97012 IV.16 AR/PR eystem os en effective tool Verification Cloeod by panel IR 60-Conclete 6/22 461/97012 IV 16 Operetst workaround eeview Verification Closed by panel IR 60-Cormlete 6/3 461/97012 IV,17 Mein control room deficiencies Verification Closed by panel IR 60 Conelete 6/2 461/97012 l

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Attachment C Startun Inspection Plan Docket No. 50 461 Inanection Report 97018 A. Pangle of Insoection Provide 24 hout coverage of start up activities in order to evaluate the effectiveness of licensee correc.tive actions involving procedure adherence, communications, compliance with Technical Specifications, maintenance work practices, operability determinations, temporary modifications, and radiological .

work practices.

B. Insoection Team Membershlo The lead inspector is Troy Pruett. There will be 2 inspectors per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift.

7AM 3:45 Pruett and Collins /C. Brown 3PM 11:45 Stasek and Ray /F. Brown 11PM-7:45 AM Campbell and Stoedter Team members should understand that anticipated coverage is seven days a week for up to t to weeks. Replacement inspectors will need to be identified for any individual breaks in coverage C. General Information ,

inspectors are expected to provide written comments, at least once per shift, in a common log regarding the activities observed and areas where additional inspection effort should be directed. (he shift lead is expected to assess the activities in progress and adjust plant observations to best utilize inspection resources (e.g.,

continuous control room observations need not be performed if it is more beneficial to observe maintenance / surveillance activities). Daily input of inspection observations to Region 8:1 management is expected.

Report input in Manual Chapter (MC) 0610 forma;is due within 1 week following '

the end of start up observations. Round the-clock startup, coverage will be provided generally in the period from prior to rod pull to full power, inspection MCs 71715,71707,71750,61726,62707, and 37551 will be used to perform inspection activities. Inspection hours are to be charged to regional initletive.

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D. Euncilonal Area insocction Activities i l

The following elements within each functional area represent the minimum activities that should be ovaluated. Additional items described in the inspection Manual Chaptors should be performed at the discretion of the shift load.

1. Operations

a. Assess ability of personnel to imptomont procedural requirements,

b. Evaluate the offectiveness of communications and control room formality,

c. Verify compliance with Technical Specifications,

d. Assess imp!cmontation of operability datormination program,

c. Verify modo restraints are completed prior to changing operational modos,

f. Evaluato the ability of personnel to ovaluate the condition of plant equipment on operability.

g. Independently verify the adequacy of selected valve and breaker linopps,

b. Assess log kooping practicos of TJactor, Operator, Senior Reactor Operator, and Non Licensed Operator,

l. Observo recirculation pump shif ts, and pump seal performance in general.

J. Observo perform.anco of drywellleakage detection systems,

k. Assess operator knowledge of system modifications installed during Refueling Outage 6.

l. Assess proceduro adequacy for routino operating ovolutions.

m. Dotormino Operations' ability to make appropriato proceduro changos in a timely manner when procedures cannot be performed as written.

2. Maintenance ,

a. Evaluate the offectiveness of maintenance work practicos.

b. Determine if equipment is procond.tioned prior to the performance of testing. "+, ,

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c. Assess ability of personnel to implement procedural requirements.

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d. Monitor the extent of on line maintenance.

e. Verify surveillance testing fulfills the Technical Specification requirements and is in accordance with design basis information from the Updated Safety Analysis Report.

3. - Enaineerina

a. Assess the impact of temputary modifications on the licensing and design $

basis of the facility.

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b.  !

Evaluate engineering input provided to operations (especially operability determinations) and maintenance (especially root cause and tiending of degraded equipment) departments.

c, '!

. Observe interaction between nuclear engineering and operations during start-  !'

up.

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4. Plant Sunoort

a. Determine effectiveness of postings as radiological conditions change,

b. En:,se radiction work permit requirements are understood and followed by radiation workers and enforced by health physics technicians and first line supervisors.

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