ML20211E954
| ML20211E954 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/12/1994 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hehl C, Hodges M, Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20211D362 | List: |
| References | |
| FOIA-97-252 NUDOCS 9709300318 | |
| Download: ML20211E954 (3) | |
Text
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- 8 og' '
) + g UNITED STATES NUCt. EAR REQUt.ATORY C3MMISSION f g REGION I D
KING OF PR S NNS LVAN A 19406-1416 MEMORANDUM FOR: Wayne INihitector Division of Reactor Projects M. Wayne Hodges, Director Division of Reactor Safety Charles W. Hehl, Director Division of Radiation Safety and Safeguards FROM: Curtis J. Cowgill, Chief .
Projects Branch No.1 -
Division of Reactor Projects SUBIECT: INDIAN POINT 3 RESTART ACTION PLAN - ISSUE CIASURE The purpose of this memorandum is to request your approval of the process by which Indian Point 3 Restart Issues, as listed in the Restart Action Plan, will be closed. The restart issue closure process is outlined in the enclosure to this memorandum. 'Ihe NRC's NYPA Assessment Panel (NAP) is responsible for the implementation of the approved Indian Point 3 Restart Action Plan. As such, the NAP will review and officially close all Restart Issues that are considered by inspectors to be satisfactorily resolved and ready for closure.
Your approval sign-off is requested in the space provided below. Questions regarding Indian Point 3 Restart Issue resolution and closure may be directed to Peter Eselgroth at X5234, s
9 .
s J. wpil, Chief ,
Projects B 1 No.1 Division of Reactor Projects
Enclosure:
As r,tated .
Approved: J h, 8 /F Wa'y e 11 Lannin ting Director ' Dat6 /
) / '
r Date M. pyne Hod l4, Directo Y W J PI's 4
' Date les W. HQiredtor kh93g a 97o923 '
O'MEALI97-252 PDR l U "l 3 " ~ \ U i
~
f
MAY l 21994 '
?
2 cc:
R. Capra, NRR B. McCabe, NRR N. Conicella, NRR M. Davis, NRR .
G. Meyer, DRS J. Joyner, DRSS C. Cowgill, DRP P. Eselgroth, DRP W. Cook, SRI-FitzPatrick G. Tracy, SRI-Indian Point 3 , . ..
J. Wiggins, DRS . - -
R. Urban, DRP 6
?
(. ENCIASURE l- Indian Point 3 Restart Action Plan - Issue Closurt Piscess Restart Issues will be managed as follows:
- 1. The DRP Section Chief will notify the appropriate DRS/DRSS Section Chief when the licensee has declared that a Restart issue is ready for NRC inspection. The DRS/DRSS Section Chief will s:hedule an inspection of the issue so as to avoid negative impact on restart.
The1tssigned inspector will coordinate with the DRP SC/ SRI for review of the;
- 2. -
licensee-provided Restart Issue package and appilcable NRC open items. . c.
- 3. When the assigned iam~ is satisfied with the resolution of the issue, the inspection report should include a statament as follows: ...The inspector had no further questions.' (or words to that effect) and "This issue will be reviewed by the NYPA Atemment Panel (NAP) for closure." All numerical references to the Restart Issue must use the appropriate Restart Action Plan section and number.
- 4. Prior to issuance, DRS/DRSS inspection reports pertaining to IP-3 will be provided to the DRP Branch Chief for IP-3 to review and/or identify restart inues. These reports will receive prompt (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) turn-around by DRP. This includes, but is not limited to, reports where current restart issues are discussed, potential additional restart issues are identified, and those closing out current restart issues. An example would be an issue in a report where the iaWor states that an issue must or will be resolved prior to restart.
- 5. DRS/DRSS Section Chiefs should notify the divisional NAP iqiwitative when an inspection report contains a restart inue iaW. that requires NAP review, to '
ensure prompt consideration and closure of the Restart Issue.
_ . . . . _ . ,_-i.4 ~_....,._m. __,._..m-- _ _ _.._~~..u- .._.- . . - . _ . _ _ . - _ . . , ,.---_m....
f;'~
- UNITED STATES
[ NUCLEAR REEULATCRY CSMMISSICN
- r. REGION l !
jS 475 ALLENOALE ROAD )
KING OF PRUSSIA. PENNSYLVANIA 19406 1415
%'***** MAY I 21994 Docket No. 50-286 j MEMORANDUM FOR: Wayne D. Imaing, Acting Director
' Division of Reactor Projects, Region I Jose A. Calvo, Asdstant Director for Region I Reactors l
Division of Reactor Projects -I/II l
Office of Nuclear Reactor Regulation FROM: Curtis J. Cowgill, Chief l
s,ojects Branch No. I
' Division of Reactor Projects, Region I l
SUBJECT:
REVISION AND STATUS UPDATE NO. 2: INDIAN POINT 3 RESTART ACTION PLAN l
The NRC's NYPA Assessment Panel (NAP) is responsible for the implementation of the l
- approved Indian Point 3 Restart Action Plan. The NAP has developed the attached revision
- to the Restart Action Plan based upon on-going inspection activities at Indian Point 3 and NAP oversight. This revision modifies one item in the Restart Readiness Assessment Checklist and adds 25 restart issues. All new restart issues were determined by the NAP to l meet the restart issues criteria in the Plan. The changes include the following:
Addition of 22 Technical Restart Issues in the Restart Issues Checklist (items 16-37) J
- Addition of 3 Programmatic Restart Issues in the Restart Issues Checklist (items 10-12)
- Modification of the Reshrt Readiness Assessment Checklist, Assessment of Root l
- Cause Identification and Correction, Part 3, to include timeliness of 10 CFR 50.72 and 10 CFR 50.73 Reports.
'Ihis revision also provides a status update of the Restart Issues Checklist based on NRC review and inspection of restart issues.
i w
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j @@, %~ uuut MAO AR& _
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4 Memorandum for Wayne D. Lanning 2 ,
& Jose A. Calvo Your approval is requested prior to presentation to the licensee. As progress is made in the restart process, further updates of the Restart Action Plan will be issued.
,5 Cu J. Cow t , ei Projects Bran' o.1 Division of Reactor Projects
Enclosure:
As stated l
Approval /2 [F
'V$yn'e D. LanninQ ' Ddie
/
& ' $. [ah Jose Calvo d~
c)
Date 9C.
i d
6 o
4 4
^
J l
) ' Memorandum for Wayne D. Ianning 3 j
& Jose A. Calvo i
1 oc w/ encl:
Region I Docket Room (with concurrences)
T. Martin, RA '
> C. Cowgill, DRP
- P. Eselgroth, DRP R. Urban, DRP B. Welling, DRP G. Tracy, SRI - Indian Point 3 W. Cook, SRI - FitzPatrick J. Wiggins, DRS R. Blough, DRS G. Meyer, DRS W. Hehl, DRSS l
S. Shankman, DRSS J. Joyner, DRSS V. McCree, OEDO R. Capra, NRR N. Conicella, NRR J. Calvo, NRR F. Miraglia, NRR W. Russell, NRR l
S. Varga, NRR i A. Thadani, NRR L. Reyes, NRR B. Boger, NRR B. Grimes, NRR C. Rossi, NRR F. Congel, NRR
M. Davis, NRR O. Zech, NRR B. McCabe, NRR J. Roe, NRR r
f INDIAN POINT 3 - RESTART ACTION PLAN
- TABLE OF CONTENTS AND RECORD OF REVISIONS AND UPDATES .
! Restart Process Checklist i
Revisloa pgg I. Initial NRC Response 1 2/94 II. Notifications 1 2/94 III. Establish an Organize the NRC Review Process 1 2/94 IV. Review Implementation
, IV.1 Root Causes and CorTective Actions 1 2/94 IV.2 Determine Restart Issues and Resolution 2 5/94 IV.3 Obtain Comments 1 2/94 IV.4 Closeout Actions 1 2/94 V. Restart Authorization 1 2/94 j VI. Restart Authorization Notification 1 2/94 Reetart Issues Checklist Revision Datg I. Confirmatory Action Letter Restart Issues 1 2/94 i II. Technical Restart Issues (3 pages) .
2 5/94
- III. Programmatic Restart Issues (2 pages) 2 5/94
~
IV. Management Oversight Restart Issues 2 5/94 Rectnrt Readiness Assessment Checklist Revision Data I. Assessment of Root Cause Identification and Correction 2 5/94 II. Assessment of Licensee Management ,0 7/93 III. Assessment of Plant and Corporate Staff (2 pages) ,0 7/93 IV. Assessment of Physical Readiness of the Plant 0 7/93-V. Assessment of Compliance with Regulatory Requirements 0 7/93 VI. Coordination with Interested Agencies / Parties 0 7/93
- I RESTART PROCESS CliECKLIST Revision
- 1 Date: 2/94 I. INITIAL NRC RESPONSE TASK / RESPONSIBLE ORGANIZATION STATUS
- a. Initial notification and NRC management discussion of known facts Complete and issues [NRR & Region Il
- b. Conduct a Special Team Inspection [ Region I] Complete
- c. Issue Confirmatory Action Letter [ Region I] Complete
- d. Determhe the need for senior management involvement (NRR & Complete Region I]
- c. Identify other parties involved (i.e. NRC organizations, other Fedeml Complete agencies, industry organizations, etc.) [NRR & Region I]
Detailed Status I.a 10 CFR 50.72 Notification (event no. 25152) dated 02/26/93 NRC Operations Center Plant Status Report dated 02/27/93 10 CFR 50.72 Notification (event no. 25193) dated 03/05/93 SMM Screening Meeting on 04/15/93 1.b Special Inspection Team formed an independent assessment of the root causes that led to the decline in performance at IP3. He inspection was conducted from 04/26/93 to 04/30/93 and 05/10/93 to 05/28/93. The exit meeting was conducted 06/01/93. Report 50-286/93-80 was issued 7/17/93.
I.c Issued 6/17/93 ,,
I.d The EDO, NRR I:iirector, and Regional Administrator toured IP3 on 05/19/93 and met with the NYPA Board of Trustees on 05/25/93.
De Chairman toured IP3 on 06/07/93.
June 1993 SMM I.e FEMA NRC Congressional Affairs NRC Public Affairs Region I State Liaison Officer
4s RESTART PROCESS CHECKLIST i .
I Revision: 1
- Date
- 2/94 i
l H. NOTIFICATIONS i
TASK STATUS
! a. Issue Daily and Directors Highlight [NRR] Complete
- b. Issue Morning Report [ Region Il Complete 3
i c. Conduct Commissioner Assistant's Briefing [NRR] N/A i
- d. Issue Cw=l=l= Paper (NRR] . N/A l
- e. Celmat Federal agencies notified (i.e. FEMA) [NRR] Complete l
- f. Congressional notification [NRR] Complete
! g* State and local Officials notified [ Region I] Complete
! Detailed Status I
f II.a NRR Daily Highlight's dated 03/01/93; 03/08/93; 04/02/93; 06/07/93; and 06/18/93 II.b Region I Morning Report's dated 03/01/93; 03/08/93; and 04/08/93 l II.c Project Manager discussion with Emergency Preparedness Branch on 06/10/93 l
NRC/ FEMA Steering Committee meeting on 6/22/93 II.f Project Manager discussion with Congressional Affairs on 04/29/93 Briefing by Deputy Regional Administrator for Congressman '
Fish from New York on 05/13/93 Congressrusn Fish site visit on 06/07/93 II.g NYS Annembly Hearings on 05/06/93 ,
NYS Assemblywoman Galef and State Senator George Pataki site visit on 06/07/93 .
Briefing of the Four County Nuclear Safety Committee on 7/6/93 by DD of DRP NYS Assembly Joint Hearings 10/25/93.
- Initial notifications complete. Officials are briefed as requested, i
5 9
I RESTART PROCESS CHECKLIST Revision: 1 Date: 2/94
! IH. ESTABLISH AND ORGANIZE THE NRC RE7IEW PROCESS TASK STATUS Establish the Restart Panel [ NAP] Complete a.
1 Assess available informatim (i.e, lnWon results, licensee self- Continuing b.
- assessments, industry reviews) [ NAP]
Cmduct Regional Administrator Briefing [ Region I] Complete
- c.
Conduct Nr.R Executive Team Briefing [NRR] Complete d.
Develop the Restart Action Plan [ NAP] Complete l c.
Regianni Administrator approves Restart Action Plan [ Region I] Complete f.
NRR Associate Director approves Restart Action Plan [NRR] Complete l g.
Continuing
- h. Implement Restart Action Plan [ NAP]
Open
- 1. Modify CAL as ewy [ Region I]
Detailed Status m.a Revised NAP Charter dated 05/13/93
- E.b Continuing NAP activity i m.c SMM screening meeting on 04/15/93 m.d SMM screening meeting on 04/15/93 l E.e Issued in 7/20/93 m.f Approved on 07/20/93 m.g Approved on 07/19/93 E.h Continuing NAP activity i
I i
a
RESTART PROCESS CHECKLIST Revision: 1
- Date: 2/94 i
IV. REVIEW IMPLEMENTATION IV.1 Root (%=ec and Correctivi Actions j
TASK STATUS i a. Evaluate Special Team Inspection findings [NAPJ Complete
- h. Licensee performs root cause analysis and develops corrective action Continuing plan for root causes (PIP) [ NAP]
l c. NRC evaluates licensee's root cause determination and corrective Continuing action plan [NAFJ Detailed Status l
i IV.1.a The Special Team Inspection exit meeting was held on 06/01/93 ,
- Special Team InWon Report issued on 07/21/93 Findings incorporated in Restart Action Plan (07/93)
( IV.l.b Performance Improvement Plan (PIP) submitted 01/12/93 l PIP management meeting on 04/06/93 (Region I) - Summary dated 04/27/93
- PIP / Restart Issues management meeting on 04/20/93 (IP3) - Summary dated l
05/03/93 Licensee restart commitment letter dated 03/26/93 Restart Issues Meeting (08/18/93) l i PIP Management Meeting (12/17/93) l Work Control and Restart Management Meedng (01/24/94)
IV.1.c NRC issued Questions and Comments regarding the PIP on'04/12/93. NYPA response received 06/11/93 Restart Issues Meeting (08/18/93)
NAP Meeting 93-13 Minutes dated 11/23/93 PIP Management Meeting (12/17/93)
PIP Management Meeting letter dated 12/23/93 Work Control and Restart Management Meeting (01/24/94) ,
l l
4- . .
RESTART PROCESS CHECKLIST Revision:._1_
- Date
- 5/94 i
i IV,2 Daearmine paetart Iamme and Ramalution i
TASK STATUS
- a. Review / evaluate licensee generated restart issues [ NAP] Continuing f Continuing j b. Indapandmt NRC identification of restart issues [NAPI
- c. NRC/H- agreement on restart issues [ NAP] Continuing f l
- d. Evaluate hcensee's restart issues implementation process [ NAP] Cnadandag q
- c. Evaluate licensee's implementation verification process [ NAP] Continuing i
- f. Schedule inspections for closure of restart issues [NAPI Continuing i
i i
- g. Evaluate the Restart Readiness Team Inspection (RATI) findings Open
- [ NAP]
i
{ Detailed Status e
l W.2.a NAP Action Item 9345-02 (NAP Meeting 93 06 Minutes dated 04/19/93)
! Continuing NAP Activity W.2.b NAP Action Item 93-05 02 (NAP Meeting 93-06 Minutes dated 04/19/93) l l NAP Action Item 93-07 02
! Special Team Inspection (04/26/93 to 05/28/93)
! Restart Action Plan issued on 07/20/93 Restart Action Plan Revision 2 l- l i
j IV.2.c NAP Action Item 93-07-03
? Restart Issues Meeung (08/18/93) i
- IV.2.d Continuing NAP activity IV.2.e Continuing NAP activity s
- IV.2.f Continuing NAP activity i
1 I
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RESTART PROCESS CHECKLIST Revision: 1 Date: 2/94 IV.3 Obtain Comments TASK STATUS
- a. Conduct public meetings [NAPJ Continuing
- b. Obtain comments from State and Imal Officials (Reglen Il Continuing
, c. Obtain comments from appucable Federal agencies [NRR) Open Detailed Status IV.3.a PIP public management =**ing 04/06/93 PIP / Restart Issue public management meeting 04/20/93 Special Team law. public exit =**ing 06/01/93 Restart Issues public meeting (08/18/93)
PIP public management Mag (12/17/93)
Work Control ud Restart public management meeting (01/24/94)
IV.3.b CorreW and meetings with offich ts (ongoing)
NAP AcSon Item 93-10-06
RESk' ART PROCESS CHECKLIST Revision: 1 Date: 2/94 IV.4 Clacenut Actions TASK STATUS
- a. Evaluate licensee's restart readiness self-assessment [ NAP] Open
- b. Conduct NRC Readiness Assessment Team Inspection (RATI) Open
[ Region Il
- c. NRC evaluate applicable items fmm the Restart Readiness Assessment Open Checklist [NAPJ
- d. Comments fmm oda parties considered [NAPJ Open
- e. Verify all restart issues closed [NAPJ Open
- f. Determine that all conditions of the CAL are satisfied [NAPJ Open
- g. Issue Augmented Restart Coverage InWon Plan [ Region I] Open Detailed Status 9 a,
s
t RESTART PROCESS CHECKLIST Revision: 1 Date: 2/94 V. RESTART AUTHOPEATION TASK STATUS
- a. Prepare restart authorization document and basis for restart [ NAP] Open
- b. NRC Restart Panel recommends restart [ NAP) Open
- c. No restart objections from other applicable HQ offices [NRR) Open
- d. No restart objections fmm applicable Federal agencies [NRR] Open
- e. Regional Administrator concurs in Restart Authorization [ Region 1] Open
- f. Director NRR concurs in Restart Authorization [NRR] Open
- g. Conduct ACRS briefing / notification [NRR] Open
- 12. Conduct Commission briefing / notification [NRR] Open
- i. EDO concurs in Restart Authorization [NRR] Open
- j. Commission notified of Restart Authorization [NRR] N/A
- k. CAL closeout to allow restart [ Region I] Open
- 1. Regional Administrator authorizes restart [ Region 1] Open Detailed Status
. i 3
. RESTART PROCESS CHECKLIST Revision: 1 e
i Date: 2/94 i VI. RESTART AUTHORIZATION NOTIFICATION 1 TASK STATUS I
- a. Commission [NRR) Open Open l b. EDO [NRR] ,
4
- c. Congressional Affairs [NRR] Open i ,
- d. Applicable Federal agencies [NER] Open
! e. Public Affairs [ Region I] Open State and local Officials [ Region I] Open a
f.
t Detailed Status 4
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i RESTART ISSUES CHECKLIST 1 '
l NAP Action Item 93-05-02 required the NAP Restart Issues Subcommittee to review the list of startup concerns, which had been originally developed by the Indian Point 3 resident inspector
- staff, and develop a proposed Indian Point 3 Restart Issues List using newly established restart l issues criteria. 'Ihe criteria used to develop the restart issues list are as follows
l i (1) Resolution of the issue is required to ensure safe operation of the facility.
(2) Resolution of the issue is required to comply with technical specifications.
{ (3) Resolution of the issue is required to comply with other regulatory requiremec (i.e.
(4) Resolution of the issue is required to meet the design /lWia: basis.
1 (5) Resolution of the issue is required to ensure effective management oversight.
l (6) Resolution of the issue is requand to ensure an effective corrective action process.
- 'Ib following checklist contains the Indian Point 3 Restart Issues. 'Ihe restart issues checklist is l divided into four sections
- (1) Confirmatory Action IAtter Issues; (2) Technical Issues; (3)
Programmatic Issues; and (4) Management Oversight Issues. Each section has four columns.
l The first column lists the ==44 restart issue 'Ihe column entitled " Resp. Org." indicates the
! l NRC organization responsible to close the issue, as appropriate. 'Ihe " Reference" column
- l indics'es the inspecti<m report or other docketed reference which documents NRC review and j - ] inspection of the issue. 'Ihe "Date Closed" column lists the date on which the NAP considers l l the issue closed and indicates the NAP Mng number, as applicable.
i All of the restart issues other than the Confirmatory Action letter issues, involve correcting, at a
! minimum, the presently known deficiencies associated with that system or program. Prior to
! restart, NYPA will resolve, or present a plan for the resolution of, each restart issues. In order
! to fully resolve each restart issue, NYPA must address the deficiencies !n that system or program and present the basis for wacluding that sufficient improvements have been made to justify safe operation of the facility.
i l
i
RESTART ISSUES CHECKLIST Revision: 1 Date: 2/94
- 1. CONFIRMA'IORY ACTION LETTER RESTART ISSUES RESTART ISSUE Resp. Reference Date (IJoensee) Org. Closed
- 1. Participate in a managemet Wag with the NRC NAP IP3 Insp Rep i staff, opa for pubuc observation, to discun an initial 93-22 dated 08/18/93 l
list of mutually agreed upon restart issues. 11/26/93
- 2. Once NYPA has determined that sufficient progress NAP has been made with corrective actions, complete a startup readiness evaluation, including an assessment of whether the plant and plant support organizations have the &7 nowledge, k skills, and abilities to prevent, or detect and correct future problems in a timely manner.
- 3. Provide the Regional Administrator with the results of NAP the NYPA n= ment and progress toward readiness for restart of the facility, including those items that remain to be completed prior to plant startup.
- 4. Participate in a management meeting with the NRC NAP staff, open for public observation, to present the results of the Indian Point 3 startup readiness evaluation.
- 5. When NYPA is ready in all respects for restart of the NAP facility, they are to provide a letter to the Regional Administrator certifying that fact. ,
- 6. Obtain the agreement of the Regional Administrator NAP prior to restart ofIndian Point 3.
RESTART ISSUES CHECKLIST Revision:_2_
Date: 5/94 __
II. TECIINICAL RESTART ISSUES RESTART ISSUE Resp. Reference Date (Licensee) Org. Closed l 1. Ensure the AMSAC system meets the requirements of DRS 50 286/94-04 the ATWS Rule ad is reliable.
l 2. Resolve emergency diesel generator deficiencies. DRS Review pkg.
l rec'd
- 3. Resolve fire protection and Appendix R deficiencies. DRS
, 4. Resolve cabic separation deficiencies. DRS
- 5. Resolv^ the reactor missile block bolt / fastener DRP deficier.cies.
5 Resolve orifice plate orientation deficiencies. DRP
- 7. Resolve fuse control deficiencies. DRS
- 8. Ensure the weld channel and containment penetration NRR system nitrog:n backup supply satisfies the design basis.
- 9. Resolve the backup service water biofouling issue. DRS
- 10. Resolve the valve landwheel issue so that, at a DRP minimum, the EOPs and AOPs can be adequately DRS implemented.
I1. Implement the applicable requested actions of NRC NRR ,
Bulletin 93-02 (Debris Plugging of ECCS Strainers).
- 12. Ensure the control room ventilation system (alt NRR conditioning) satisfies the design basis.
l 13. Resolve the PORV issue. DRS Review pkg.
l rec'd
- 14. Resolve the instrument bus voltage fluctuation issue. DRS
- 15. Resolve the main turbine potential overspeed issue. DRP l 16. Resolve instrument air deficiencies. DRS i
i
_. ___.m...___.__ _ _ _ _ _ . _ _ _ _ _ . . . _ - _ _ _ . _ . _ . _ _ _ _ _ . _ _ _ _ . . . . _ _
lL, RESTART ISSUES CHECKLIST Revision:_2_
I
- Date: 5/94 t
H. TECHNICAL RESTART ISSUES
- continued -
i t-RESTART ISSUE Resp. Reference Date l Org. Closed
- j. (Ucensee)
- l. 18. Resolve AFWS deficiencies. DRS l
i
- 19. Resolve cverdue and outdanding EDSFI issues. DRS l- l j 20. Fesolve submerged cahle issue. DRS l
- 21. Resolve instrument loop calibration issue (containment DRS
, l l l sump, CST alarm, RWST).
i 22. Resolve BAHT deficiencies; placement of BAHT DRP l
- - l- controllers, recorders, panels into surveillance l- program.
l DRP l- 23. Resolve service water heat trace deficiencies. _
t l 24. Resolve core exit thermocouple requirements. DRS l
- 25. Resolve post-accident sampling system deficiencies / DRP
[ '
missing commitments.
- 26. Resolve control rod system issues (GL 93-04). DRS l
{ 27. Resolve minimum temperature for criticality issue. DRP
.l. .
- 28. Completion of vendor recommendations for main DRS l
steam non-return check valves.
- 29. Resolve CCR AIC service water valve weights. DRS i l
\
- 30. Resolve gas stripper ramaval. DRP
!- -l-
- 31. InWon and r-tr to extraction steam piping. DRS l
j l keys.-
- 33. Resolve radiation monitor deficiencies. DRS
!- l.
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RESTART ISSUES CHECKLIST Revision:1,,
Date:_ 5/94 H. TECHNICAL RESTART ISSUES
- continued -
RESTART ISSUE Resp. Reference Date (Ucensee) Org. Closed
- 34. Resolve control bulloing exhaust fan inadequate DRS l
l design.
l 35. Resolve construction strainer issue. DRP
l l 37. Resolve inadequate support of fire main in 480V DRS l switchgear room.
, RESTART ISSUES CHECKLIST Revision: 2_
Date: 5/94 III. PROGRAMMATIC RESTART ISSUES RESTART ISSUE Resp. Reference Date GW) Org. Closed
- 1. Resolve plant-wide cot.ective action tracking and DRP implementadon process deSciencies.
- 2. Resolve plant-wide commitment tracidag and DRP 9 implementation process deSciencies.
- 3. Resolve surveillance test program deficiencies. Certify DRP that all surveillance tests are current and the results of each test properly demonstrate equipment operability.
l_ 4. Resolve maintenance /=p=:-:44 retest program DRS 50 286/94-08 deficiencies.
l 5. Resolve calibration deficiencies forinstruments used to DRS 50 286/94-08 conduct surmillance tesdng.
- 6. Evaluate the need for a plant-wide procedure upgrade DRP program. Identify and upgrade critical procedures needed to support restart and safe operations.
- 7. Resolve deficiencies neweintad with the temporary DRP procedure change (TPC) process and the biennial review process.
- 8. Review preventative maintenance (PM) accomalih DRS to ensure vendor recommendations have been included ,,
and develop a process to ensure vendor recommendations att reflected in PM procedures as appropriate
- 9. Enhance the reasonable assurance of safety (RAS) and DRP justification for continued operation GCO) processes.
l 10. . Resolve work control and operations clearance DRP l weaknesses for startup.
RESTART ISSUES CHECKLIST Revision:._2_
Date: 5/94 HI. PROGRAMMATIC RESTART ISSUES
- continued -
RESTART ISSUB Resp. Reference Date (Licensee) Org. Closed l 11. Resolve recurring maintenance inadequacies (parts, DRP l procedures).
l 12. Review Category I (safety-related) equipment DRP l procurement process.
Y
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e V
', RESTART ISSUES CHECKLIST Revision: _2__.
- Date
- 5/94 f
IV MANAGEMENT OVEPSIGHT RESTART ISSUES RESTART ISSUE Resp. Reference Date (Licensee) Org. Closed
- 1. 'Nvelop a icasonable assurance that all NRC DRP
. commitments have been met or are on a schedule for closure by reviewing an app:opriately sized sample of commitments.
! 2. Resolve startup control and mode changc deficiencies. DRP
- 3. Resolve vendor / contractor oversight and control DRS 50-286/94-08 l
deficiencies.
- 4. Ensure management's expectations with regad to DRP procedure adherrnce and attention to detail are clearly understood.
- 5. Provide operability determination guidance and DRP trahting to all applicable station personnel.
- oversight group.
- 7. Review all backlogs to assess the safety impact of the DRP l items contained in these backlogs. Backlogs irclude the work request, RES, CAR, REC, PORC open item, RIND, and RIP lists.
- 8. Assess NYPA staff attitude with respect to NAP ,,
4 performance improvement.
4 4
d i
i f
n RESTART READINESS ASSESSMENT CHECKLIST ,
Revision:._2__
Date: 5/94 I. ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION i .-- .
AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. ROOT CAUSE ASSESSMENT NAP Amlishle Items
- Conditions requiring the shutdown are clearly understood
- Root causes of the conditions requiring the shutdown are clearly understood
- Root causes of other significant problems are clearly understood
- Evaluate adequacy of the root cause analysis program
- 7. CORRbCTIVE ACTIONS NAP Anolicable Items
- Evaluate adequacy of the comprehensive corrective action plan
- Evaluate adequacy of the corTective action programs for, specific root causes
- Assess control of conective action item tracking
- Effective corrective actions for the conditions requiring the shutdown have been implemented
- Effective corrective actions for other significant problems have been implemented
- Adequacy of the corrective action verification process
- 3. SELF-ASSESSMENT CAPABILITY NAP Apolicable Items
- Adequacy oflicensee's startup self-assessment
- Effectiveness of Quality Assurance Program
- Adequacy of Industry Experience Review Prcgram
- Adequacy of licensee's Independent Review Groups
- Adequacy of deficiency reporting system Staff willintmas to' raise concerns Adequacy of Commlucent Tracking Program Utilization of external audits (i.e. INPO) l
- Quality and timeline,s of 10 CFR 50.72 and 50.73 Reports
. - - - . - . ~ . _ . _ - - - - - - . - - - - - - - - - - . - _ - . . . . . - . - . -
4
't i , RESTART READINESS ASSESSMENT CHECKUST I Revision:._0__
I Date: 7/93 i
H. ASSESSMENT OF UCENSEE MANAGEMENT s
i t
AREA POR ASSESSMENT RESPONSIBLE STATUS l
i ORGANIZATION l
' NAP !
- 1. MANAGEMENT OVERSIGHT AND EFFECTIVENESS l l
! Applicable Items a
3' ,
- Management commitment to achieving improved performance l
- Performance goals / expectations developed for the staff j - Goals / expectations communicated to the staff
- - Resources available to management to achieve goals
- - Managem'.at's commitment to procedure adherence I -
Manamt involvement in self-assessment and i%t self-assessment I capability l - Effectiveness of management review committees
! - Management in-plant time
- Management's awareness of day-to-day operational concerns l
- Ability to identify and prioritize significant issues
' - Ability to coordinate resolution of significant issues
- Ability to imalamant effective currective actions
- 2. MANAGEMENT ORGANIZATION AND NAP i
- SUPPORT '
s
) Annlienhle Itame 4
j - Structure of the oreal=h
- - Ability to adequately staff the organization
- Effect of any management reorBanization Establishment of proper work environment
[ -
- Ability to resolve @n concerns j
- Ability to provide engineering support Adequacy of plant administrative procedures
[
- Amount of contractor usage l Adequacy of contractor oversight j -
2
- Information exchange with other utilities
- Participation in industry groups j
i i
i
]
E i
4 i
RESTART READINESS ASSESSMENT CIIECF8JST 4
Revision:_ Q_
Date: 7/93 III. ASSESSMENT OF PLANT AND CORPORATE STAFF AREA FOR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. ASSESSMENT OF STAFF NAP Anolinable hma
- Staff commitment to achieving improved performance l - - Staff's safety conu:lousness
- Understanding of mangemmt's expectations / goals
- Understanding of plant issues and conective actions
- Effect on the staff of any reorganization
- Resourtes available to the staff
. Qualifications and training of the staff
. Staff's work environment
- Level of attention to detail
- Adequacy of staffing
- Off hour plant staffing
- Staff overtime usage
- Amount of contmetor usage
- Staff / contractor relationship
- Procedure usage / adherence
- 2. ASSESSMFNI' OF CORPORATE SUPPORT NAP Apolicable Itagg
- Relationship between corporate and the plant staff '-
- Adequacy of the request for corporate services process
- Corporate undentanding of plant issues
- Corporate staff in plant time
- Effectiveness of the corporate / plant interface meetings
+
- Adequacy of corporate igestation at plant activities
- Adequacy of corporate engineering support
- Adequacy of corporate design changes
- Adequacy of licensing support
1 RESTART READINESS ASSESSMENT CIIECKLIST
- 10. ASSESSMENT OF PLANT AND CORPORATE STAFF
- continued -
AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 3. OPERA'IDR ISSUES NAP Armlienkle Itemt
- IJoensed operator stafung meets requirements and licensee gmis
- Level of formality in the control room
- Adequacy of requalification training
- Adequacy of equipment operabilig determination training
- Adequacy of SRO command and control
- Control room / plant operator awareness of equipment status
- Adequacy of plant operating piecedures
- Procedure usage / adherence
- les keeping practices s
, o" RESTART READINESS ASSESSMENT CIIECKLIST -
Revision:._0__
Date: 7/93 l
IV. ASSESSMENT OF PIIYSICAL READINESS OF THE PIANT m
AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. ASSESSMENT OF PHYSICAL READINESS NAP OF THE PLANT Anolleshle Items
- Operability of technical specifications systems
- Operability of required secondaiy and support systems
- Results of pre-startup testing
- Adequacy of system lineups
- Adequacy of surveillance tests / test program
- Significant hardware issues resolved
- Adequacy of the power ascension testing program
- Adequacy of plant maintenance program effectiveness
- Maintenance backlog managed and impact on operation assessed
- Adequacy of plant housekeeping and equi e.nent t storage
o RESTART READINESS ASSESSMENT CHECKLIST Revision: 0_
Date: 7/93 V. ASSESSMENT OF COMPLIANCE WITH REGULA'IDRY REQUIREMEN13 AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. ASSESSMENT OF COMPLIANCB WITH NAP REGULATORY REQUIREMENTS Anollable item
~
- Applicable license amendments have been issued
- Applicable exemptions have been granted
- Applicable reliefs have been granted
- Confirmatory Action Letter conditions have been satisfied
- Significant enforcement issues have been resolvoi
- Allegations have been appropriately addressed e
RESTART READINESS ASSESSMENT CHECKLIST ,
4 Revision: Q_,
Date: 7/93 VI. COORDINATION WITII INTERESTED AGENCIES / PARTIES !
AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. COORDINATION WITH INTERESTED NAP AGENCIES / PARTIES Armlicable Ite.mn
- Federal Emergency Management %gency
- Appropriate State and I.ocal Officials
- Appropriate Public Interest Groups
- local News Media Y
- o. w '
NUCt. PAR RE T Y CEMMISSION
),
, M*"** )' aan=_s MAY I 31994 Docket No. 50-286 Mr. William A. Josiger .
Aedng Eaecutive Vice President - Nuclear Generadon New York Power Authority 125 Main Street White Plains, New York 106vi
Dear Mr. Josiger:
nis letter forwards a copy of Revision and Status Update No. 2 of the Indian Point 3 Restart Action Plan. De NRC's NYPA Assessment Panel (NAP) MW this revision based upon on going inspeedon activities at Indian Point 3 and condnued NAP oversight, his revision adds 25 new restart issues in the Restart Issues Checklist and modifles one item in the Restart Readineas Aanaamment Checklist. All new restart issues were determined by the NAP to meet the restart issues criteria listed in the Plan. De changes include:
. Addition of 22 Technical Restant lasues in the Restart Issues Checklist (Items 16 37)
. Addidon of 3 Programmade Restart lasues in the Restart lasues Checklist (Items 1012)
. Modification of the Restart Readiness Assessment Checklist, Assessment of Root Cause Identification and Correction, Part 3, to include timeliness of 10 CPR 50.72 and 10 CFR 50.73 Reports.
His revision also provides a status update of the Restart Issues Checklist based on NRC review and inspeedon of restart issues. De additional restart items were discussed with Mr.
Les Hill, Resident Manager at Indian Point 3. If there are any addidonal questions regarding the enclosed docunent, please contact Mr. Curtis Cowgill of my staff at (610) 337-5233.
In accordance with 10 CFR 2.790 of the NRC's ' Rules of Practice," a copy of this letter and its enclosure will be place 8 in the NRC Public Document Room. No'veply to this letter is requested.
Sincerely, Wa 1 =alag, Acting tor Divistor, of Reactor Projects
Enclosure:
Revision and Status Update No. 2: Indian Point 3 Restart Action Plan
,,/11 frvenKr nl/}
q MVQGtY ^ 0 / fl$
_=
o.
Mr. William A. Jealser 2 oc w/ encl:
S. Freeman, President R. Schoenberger, First Executive Vice President & COO, NYPA J. Kelly, Acting Vice Prealdent - Nuclear Operations L. Hill, Resident Manager G. Wilverding, Manager, Nuclear Safety Evaluation G. Goldstein, Assistant General Counsel P. Kokolakis, Director, Nuclear uoansing PWR, NYPA A. Donahue, Mayor, Village of Buchanan C. Jackson, Nuclear Safety and lasing Manager (Con Ed)
C. Donaldson, Esquire, Assistant i.ttorney General, New York Depannant of law l Chairman, Standing Committee on Energy, NYS Assembly. i Chairman, Standing Committee on Environmental Conservation, NYS Assembly
. Executive Chair, Pour County Nuclear Safety Committee ,
Chairman, Committee on Corporations, Authorities, and Commissions Robert D. Pollard, Union of Concerned Scientists
'Ihe Honorable Sandra Galef, NYS Assembly Director, Energy & Water Division, Department of Public Service, State of New York ,
K. Abraham, PAO (2)
Public Document Room (PDR)
Iscal Public Document Room (LPDR)
Nuclear Safety Information' Center (NSIC)
NRC Resident Ir@-
State of New York, SLO Designee 6
e
.r..-,- ,.,,_y.. ,. ,.,, r..., m..,._,. ., . . . . _ _ , ___ ,, , , _ - _ _ , , . . . . _ _
MA1 1 J 1982 Mr. William A. Jostger 3 bec w/ encl:
Region 1 Docket Room (with concurrences)
C. Cowgill, DRP P. Esclgroth, DRP R. Urban, DRP -
D. Welling DRP G. Tracy - Indian Point 3 R. Capra, NRR N. Conicella, NRR bec w/ encl: (VIA E MAIL)
M. Shannon, NRR (MXS1)
V. McCree, OEDO (VMM) e
[g.ug\,
uNitro sTAtts
[
" M AL E D ts ROAD KING OF PRUSSLA. PENNSYLVANIA 16406 1416 -
- ++ MAY l 21994 Docket No. 50 286 MEMORANDUM FOR:
Wayne D. unning, Acting Director Division of Reactor Projects, Region 1 Jose A. Calvo, Assistant Director for Region 1 Reactors Division of Reactor 1%jects 1/II Office of Nuclear Reactor Regulation Curds J. Cowgill, Chief FROM:
Projects Branch No. I Division of Reactor Projects, Region 1
SUBJECT:
REVISION AND STATUS UPDATE NO. 2: EiDIAN POINT 3 RESTART ACTION PLAN The NRC's NYPA Assessment Panel (NAP) is responsible for the implementation of the -
approved Indian Point 3 Restart Action Plan. De NAP has developed the attached revisio to the Restart Acdon Plan based upon on going inspection activities at Indian Point 3 and NAP oversight. ' Itis revision modifies one item in the Restart Readiness Assessment Checklist and adds 25 restart issues. All new restart issues were determined by the NAP to meet the restart issues criteria in the Plan. De changes include the following:
- Addition of 22 Technical Restart issues in the Restart issues Checklist (items
- Addition of 3 Programmatic Restart Issues in the Restart Issues Checklist (items 10-12)
- Modification of the Restart Readiness Assessment Mklist, Assessment of Root Cause Idendfication and Correcdon, Part 3, to include dmeliness of 10 CFR 50.72 and 10 CFR 50.73 Reports.
His revision also provides a status update of the Restart Issues Checklist based on NRC review and inspeedon of resta'rt issues.
h D ,
Memorandum for Wayne D. Lanning 2
& Jose A. Calvo Your approval is requested prior to presentation to the licensee, As progress is made in the restart process, further updates of the Restart Action Plan will be issued.
S Cu sJ.Cowt , D Projects Bmnl o.1
' Division of Reactor Projects
Enclosure:
As stated , ,
Approval j j&h C' Ditek/[b Dys D. LanninQ fp ' $. [c<bv 6 0 f
/ Jose Calvo Date d
.i INDIAN POINT 3 - RESTART ACTION PLAN TABLE OF CONTEN'IS AND RECORD OF REVISIONS AND UPDATES ,
na .,t Pme*== char Ml=#
Revislou Qgg I. Initial NRC Response 1 2/94 II. Nodficadons 1 2/94 III. Establish an Organize the NRC Review Process 1 2/94 IV. Review Implementadon IV.1 Root Causes and Conective Actions 1
- - 2/94 - -
IV.2 Determine Restart Issues and Resolution 2 5/94 IV.3 Obtain Comments 1 2/94 2/94
. IV.4 Closeout Actions 1 V. Restart Authorization 1 2/94 VI. - Restart Authorization Notification 1 2/94 Restart Issues Checklist Enrision Dain I. Confirmatory Action latter Restart Issues 1 2/94 II. Technical Restart Issues (3 pages) 2 5/94 III. Programmatic Restart Issues (2 pages) 2 5/94 IV. Management Oversight R2 start Issues 2 5/94 pa rt Randina== A=aa== ment cwMint Revision Daic I. Assessment of Root Cause Identification and Correction 2 5/94 II. Assessment of Licensee Enagement ,,0 7/93 HI. Assessment of Plant and Corporate Staff (2 pages) 0 7/93 IV. Annaanment of Physical Randinaan of the Plant 0- 7/93 V. Assessment of CWla- with Regulatory Requirements 0 7/93 VI. Coordination with Interested Agencies / Parties 0 7/93
-. -- . . _ . _ _ . ~ _ -__
- _-- __ . _ _ _ _ . _ _ _ _ - ~ . . - _ _ _ _ _ _ __. _
RESTART PROCESS CIIECKLIST Revision:,_L, i
Date: 2/94
- I. INITIAL NRC RESPONSE i
TASK / RESPONSIBLE ORGANIZATION STATUS
- a. Initial notification and NRC management discussion of known facts Complete
~ ~
and issues [NRR & Region I]
- b. Conduct a Special-Team Inspection [ Region Il Complete
- c. Issue Confirmatory Action Letter [ Region I] . Complete
- d. Determine the need for senior management involvement [NRR & Complete i
RW I]
Identify other parties involved (i.e. NRC organizations, other Federal Complete c.
agencies, industry organizations, etc.) [NRR & Region I]
Detailed Status ,
1.a 10 CFR 50.72 Notification (event no. 25152) dated 02/26/93 MRC Operations Center Plant Status Report dated 02/27/93 10 CFR 50.72 Notifiution (event no. 25193) dated 03/05/93 SMM Screening Meeting on 04/15/93
- 1.b Special Inspection Team formM an independent assessment of the root causes that led to the decline in performance at IP3, De inspetion was conducted from 04/26/93 to 04/30/93 and 05/10/93 to 05/28/93, ne exit meeting was conducted 1
- 06/01/93. Report 50-286/93-80 was issued 7/17/93.
+
I.c Issued 6/17/93
- I.d De EDO, NRR birector, and Regional Administrator touted IP3 on 05/19/93 and met with the NYPA Board of Trustees on 05/25/93.
The Chainnan toured IP3 on 06/07/93.
June 1993 SMM
- I.e FEMA NRC Congressional Affairs NRC Public Affain Region I State Liaison Officer
RESTART PROCESS CIIECKLIST Revision: 1 Date: 2/94 H. NOTIFICATIONS TASK STATUS
- a. Issue Daily and Directon Highlight [NRR] Complete
- b. Issue Morning Report [ Region I] Complete
~
- c. Conduct Commissioner Assistant's Briefing [NRR]' . 3/A'
- d. Issue Commission Paper (NRR] N/A
- e. Cognizant Federal agencies notified 0.e. FEMA) [NRR] Complete
- f. Congresslocal notilication [NRR] __
Complete
- g.* State and Local Officials notified [ Region I] Complete Detailed Status II.a NRR Daily High11ght's dated 03/01/93; 03/08/93; 04/02/93; 06/07/93; and 06/18/93 II,b Region I Morning Report's dated 03/01/93; 03/08/93; and 04/08/93 II.e Project Manager discussion with Emergency Proparedness Branch on 06/10/93 NRC/ FEMA Steering Committee meeting on 6/22/93 II.f Proj6ct Manager discussion with Congra 61 Affairs on 04/29/93 Briefing by Deputy Regional Administrator for Congressman Fish from New York on 05/13/93 ,
- Congressman Fish site visit on 06/07/93 II.g NYS Assembly Hearings on 05/06/93 NYS Assemblywoman Galef and State Senator George Pataki site visit on 06/07/93 Briefing of the Four County Nuclear Safety Committee on 7/6/93 by DD of DRP NYS Assembly Joint Hearings 10/25/93.
' Initial notifications complete. Officials are briefed as requested.
RESTART PROCESS CIIECKLIST Revision: 1 Date: 2/94 III. ESTABLISH AND ORGANIZE THE NRC REVIEW PROCESS TASK STATUS 4
- a. Establish the Restart Panel [ NAP] Complete
- b. Assess available information (i.e. inspeedon results, licensee self- Condnuing assessments, industry reviews) [ NAP] -- - - -- . -- --
- c. Conduct Regional Administrator Briefing [ Region Il " Complete
- d. Conduct NRR Executive Team Briefing [NRR] Complete Develop the Restart Action Plan [ NAP] Complete
- c. ,
Regional Administrator approves Restart Acdon Plan [ Region Il Complete f.
- g. NRR Associate Director approves Restart Action Plan [NRR) Complete
- h. Implement Restart Action Plan [ NAP] Continuing _
Modify CAL as necessary [ Region.I] Open l.
Detailed Status III.a Revised NAP Charter dated 05/13/93 III.b Continuing NAP activity 51.c SMM icreening Mng on 04/15/93 l
- III.d SMM screening reeeting on 04/15/93 III.e Issued in 7/20/93 III.f Approved on 07/20/93 III.g Approved on 07/lors IIIh Continuing NAP t.
- tivity i
I
- RESTART PROCESS CHECKLIST
! Revision: 1 Date: 2/94
! IV. REVIEW IMPLEMENTATION IV.! F w c - - and e M ve W e TASK STATUS l _ _ _ _ .
l .. a. Evaluate Special Team laspection nndings [NAPJ Complete I b. Ih performs root cause analysis and develops conective action Continuing i plan for root causes (hP)(NAP) c.. NRC evaluates licensee's root cause deterrninadon and'conective Continuing action plan (NAP)
Detailed Status IV.1.a 'Ihe Special Team inspection exit Ma= was held on 06/01/93 Special Team Inspection Report issued on 07/21/93 Pindings incorporated in Restart Acdon Plan (07/93) 1 IV.I.b Performance improvement Plan (PIP) submitted 01/12/93 PIP management meeting on 04/06/93 (Region I) - Summary dated 04/27/93 PIP / Restart lasues management moedng on 04/20/93 (IP3) - Summary dated 05/03/93 1.Jcen=e restart commitment letter dated 03/26/93 Restant Issues Meedng (08/18/93)
, PIP Management Meeting (12/17/93)
Work Control and Restart Management Meeting (01/24/94)
IV.1.c NRC issued Questions and Comments regarding the PIP on.04/12/93. NYPA response vocalved 06/11/93 Restart Issues Meeting (08/18/93)
NAP Meedag 93-13 Minutes dated 11/23/93 PIP Manageret Meedag (12/17/93)
PIP Management Meeting letter dated 12/23/93 Work Control and Restart M- yt Meedng (01/24/94)
--- ~ ~ ~ ,_. - ,. ,_ _ _._ ,, _ _ ______
RESTART PROCESS CIIECKLIST Revision: 1 Date: 5/94 IV.2 Determine Restart Issues and Reelution TASK STATUS
- n. Review / evaluate licensee generated restart issues [ NAP] Continuing
- b. Independent NRC identification of restart issues [ NAP] Continuing l c. NRC/ licensee agreement on restart issues [ NAP] Condnuing
- d. Evaluate licensee's restart issues implementation process [ NAP] Continuing -
- e. Evaluate licensee's implementation verification process [ NAP] Continuing
- f. Schedule inspections for closure of restart issues [ NAP] Continuing
- g. Evaluate the Restart Readiness Team Inspection (RATI) findings Open
[ NAP]
Detailed Status IV.2.a NAP Action Item 93 05-02 (NAP Meeting 93 06 Minutes dated 04/19/93)
Continuing NAP Activity IV.2.b NAP Action Item 93 05-02 (NAP Meeting 93 06 Minutes dated 04/19/93)
NAP Action Item 93 07-02 Special Team inspection (04/26/93 to 05/28/93)
Restart Action Plan issued on 07/20/93 l
- Restart Action Plan Revision 2 IV.2.c
- NAP Action item 93 07-03 ,,
Restart issues Meedng (08/18/93)
IV.2.d Continuing NAP activity IV.2.e Continuing NAP activity IV.2.f Continuing NAP activity
4 RESTART PROCESS CilECKLIST ;
Revision: 1_
Date: 2/94 IV.3 Obtain Comments TASK STATUS
' a. Conduct public meetings [ NAP] Continuing
- b. Obtain comments from State and Iscal Otim:sals (Region 1] Continuing
' Open
- c. ~ Obtain comments from applicable Federal agencies [NRR]
I Detailed Status IV.3.a a PIP public management meeting 04/06/93 l
- PIP / Restart Issue public management meedng 04/20/93 Special Team Inspection public exit meeting 06/01/93
- Restut Issues public meeting (08/18/93)
PIP public management meedng (12/17/93)
Work Control and Restart public management moedng (01/24/94)
IV.3.b Coe and dags with officials (ongoing)
NAP Action Item 93-10-06 I
' a, i
l
1 4 RII' TART PROCESS CIIECKLIST Revision:._1_
1 Date: 2/94 4
IV.4 Cinaanut Actions i
TASK STATUS
- a. Evaluate licensee's restart readiness self-assessment [NA?J Open
- b. Conduct NRC Readiness Assessment Team Inspection (RATI) Open
[ Region I] ..
~ *
- c. NRC evaluate appilcable items from the Restart Readiness Assessnat Open 4
Checklist [NAPJ
- d. Comments froin other parties malM [NAPJ Open Verify all restart issues closed [NAPJ Open c.
Determine that all conditions of the CAL are satisfied [NAPJ Open f.
Issue Augmented Restart Coverage Inspection Plan [ Region I] Open g.
Ddalled Status ,
4 J
f 8 j #
a 4
4 4
f
-y., , . . _ . _ , . . _ - . .. ,
RESTART PROCESS CHECKLIST Revision:._L_
Date: 2/94 V. RESTART AUTilORIZATION TASK STATl!S Pn: pare restart authorization document and basis for restart [ NAP] Open a.
NRC Restart Panel recommends testart [ NAP] Open b.
[No restart objections from other applicable HQ offices [NRR] Open c.
No restart objections from appilcable Federal agencies [NRR] Open d.
Regional Administrator concurs in Restart Authorization [ Region I] Open e.
Dir*or NRR concurs in Restart Authorization [NRR] Open f.
Conduct ACRS briefing / notification [NRR] Open g.
Conduct Commission briefing / notification [NRR] Open h.
Open
- 1. EDO concurs in Restart Authorization [NRR]
Commission notified of Restart Authorization [NRR] N/A J.
CAL closcout to allow restart [ Region I] Open k.
Regional Administrator authorizes restait [ Region I] Open 1.
Detailed Status 0
RESTART PROCESS CIIECKLIST Revision: L_
Date: 2/94 VI. RESTART AUTHORIZATION NOTIFICATION TASK STATUS
- a. Commission [NRR] Open
- b. EDO [NRR] Open
- c. Congr*=%f Affaln [NRR) ' _~ 1 " ' ' " Open *
- d. Applicable Fedeml agencies [NRR] Open
- e. Public Affairs [ Region Il Cpen
- f. State and Iscal Officids [ Region I] Open ,
petailed Status 9 e O
i
)j ' '
RESTART ISSUES CIIECKLIST NAP Action Item 93 05 02 required the NAP Restart issues Subcommittee to review the list of startup concerns, which had been originally developed by the Indian Point 3 resident inspector staff, and develop a proposed Indian Point 3 Restart issues List using newly-established restart issues criteria. The criteria used to develop the restart issues list are as follows:
(1) Resolution of the issue is required to ensure safe operation of the fac.lity.
(2) Resolution of the issue is required to comply with tecimical specifications.
(3) Resoludon of the issue is required to comply with other regulatory requiremeatt (i.e.
10 CFR, ASM_B, etc.) .
(4) Resolution of the issue is required to meet die design /liccasing basis.
-, (5) Resolution of the issue is required to ensure effective management ove: sight.
(6) Resolution of the issue is required to ensure an effective corrective action process.
The following checklist contains the Indian Point 3 Restart Issues. '!he restart issues checklist is divided into four sections: (1) Confirmatory Action Letter Issues; (2) Technical Issues; (3)
Programmatic Issues; and (4) Management Oversight Issues. Each section has four columns.
'Ihe first coh.mn lists the specific restart issue. The column entitled ' Resp. Org.' indicates the l NRC organization responsible to close the issue, as appropriate. 'Ihe ' Reference' column indicates the inspection report or other docketed reference which documents NRC review and inspection of the issue. 'Ihe "Date Closed' column lists the date on widch the NAP considers i the issue closed and indicates the NAP meeting number, as applicable.
All of the restart issues other than (Se ConfirmEory Action Letter issues, involve correcting, at a minimum, the presently known deficiencies associated with that system or program. Prior to restart, NYPA will resolve, or present a plan for the resolution of, each restart issues. In order to fully resolve each restart issue, NYPA must address the deficiencies in that system or program and present the basis for concluding that sufficient improvements have been nude to justify safe operation of the facility.
I
RESTART ISSUES CHECKLIST Revision: 1 Date: 2/94 4
I. CONFIRMA'IURY ACTION Ix Tex RESTART ISSUES RESTART ISSUE Resp. Reference Date (Lloensee) Org. Closed Participate in a management Wng with the NRC NAP IP3 Insp Rep l 1.
staff, open for public observation, ,to discuss an initial 93-22 dated 08/18/93
~ '
list of mutually agreed. upon restart hsues. 11/26/93
- 2. Once NYPA has determined that sufficient progress NAP i
has been made with conective actiore, complete a
- startup readiness evaluation, including an assessment of whether the plant and plant support organizations have the neury knowledge, skills, and abilities to prevent, or detect and correct future problems in a
- timely manner.
- 3. Provide the Regional Administrator with the results of NAP the NYPA assessment and progress toward readiness i for restart of the facility, including those items that remmin to be complM prior to plant startup.
- 4. Participate in a management meeting with the NRC NAP l
! staff, open for public observation, to present the results of the Indian Point 3 startup readiness i evaluation.
l 5., When NYP,A.is ready in all respects for restart of tho NAP
- faellity, they are to provide a letter to the Regional Administrator certifying that fact. .
- 6. Obtain the agreement of the Regional Administrator NAP prior to restart of Indian Point 3. .
i l
i i
RESTART ISSUES CIIECKLIST Revision: 2 Date: 5/94 l
LI. TECIINICAL RESTART ISSUES l RESTART ISSUB Resp. Reference Date l
, (IJcensee) Org. Closed l
l the ATWS Rule and is reliable. _
- 2. Resolve emergency diesel generator deficiencies. DRS Review pkg.
rec'd
- 3. Resolve fire protection and Appendix R deficiencies. DRS i
- 4. Resolve caole separation deficiencies. DRS l
- 5. Resolve the reactor missile block bolt / fastener DRP deficiencies. __
- 6. Resolve orifice plate orientation deficiencies. DRP
'7. Resolve fuse control deficiencies. DRS
- 8. Ensure the weld channel and containment penetration NRR
, system nitrogen backup supply satisfies the design basis.
, 9. Resolve the backup service water biofouling issue. DRS
- 10. Resolve the valve handwheel issue so that, at a DRP minimum, the EOPs and AOPs can be adequately DRS i implemented.
- 11. Implement the applicable requested actions of NRC NRR ,
Bulletin 93-02 (Debris Plugging of ECCS Strainers).
- 12. Ensure the control soon ventilation system (air NRR conditioning) satisfies tt e design basis.
ree'd
- 14. Resolve the instrument bus voltage fluctuation issue. DRS
- 15. Resolve the main turbine potential overspeed issue. DRP l 16. Resolve instrument air deficiencies. DRS i
l l
R$ START ISSUES CHECKLIST I Revision:_2_,
Date:-. 5/94 II. TECHNICAL RESTART ISSUES
- continued -
RESTART ISSUB Resp. Reference Date (Licensee) Org. Closed
,l_ 17. Resolve fan cooler unit damper deficiencies. ~ ~" ~ ~ "bRP
- 18. Resolve AFWS deficiencies. DRS l
- 19. Resolve overdue and outstanding EDSFI issues. DRS l
- 20. Resolve submerged cable issue. DRS l
l 21. Resolve instmment loop calibration issue (containment DRS sump, CST alarm, RWST).
- 22. Resolve BAHT deficiencies; placement of BAHT DRP controllers, recorders, panels into surveillance Program.
- 23. Resolve service water heat trace deficiencies. DRP l
l 24. Resolve core exit thermocouple requirements. DRS
- 25. Resolve post accident sampling system deficiencies / DRP missing commitments.
26., Resolve control rod system issues (GL 93 04). DRS l
- 27. Resolve minimum temperature for criticality issue. DRP l
- 28. Completion of vendor recommendations for main DRS steam non return check valves.
l
- 29. Resolve CCR A/C service water valve weights. DRS
- 30. Resolve gas stripper removal. DRP l
- 31. Inspection and repair to extraction steam piping. DRS l
l 32. Resolve MOV issues: weak link analysis, anti-rotation DRS keys.
- 33. Resolve radiation monitor deficiencies. DRS l
l RESTART ISSUES CtIECKLIST Revision:_2_
Date: 5/94
- 11. TECIINICAL RESTART ISSUES
- continued -
RESTART ISSUE Resp. Reference Date (I h =) 0.3
~'
Closed
~ ~ ~ ' - ~ ~
- 34. Resolve control building exhaust fan inadequate DRS ~
design.
l 35. Resolve construction strainer issue. DRP
l 37. Resolve inadequate support of fire main in 480V DRS switchgear room.
+
l
RESTART ISSUES CIIECKLIST 1
Revision:_2_.
Date:_ 5/94 III. IMOGRAMMATIC RESTART ISSUES RESTART ISSUE Resp. Reference Date Ojoensee) Org. Closed
. 1. Resolve plant wide corrective action tracking and DRP implementation process deficiencies.
- 2. Resolve plant wide commitmert tacking and DRP implementation process deficiencies.
- 3. Resolve surveillance test program deficiencies. Certify DRP that all surveillance tests are current and the results of
- each test properly demonstrate equipment operability.
- 4. Resolve maintenance / engineering retest program DRS 50-286/94-08 l
deficiencies.
- 5. Resolve calibration defidado for instruments used to DRS 50-286/94-08 l
i conduct surveillance testbig_
- 6. Evaluate the need for a plant-wide procedure upgrade DRP program. Identify and upgrade critical procedures needed to support restart and safe operations.
- 7. Resolve deficiencies associated with the temporary DRP procedure change (TPC) process and the biennial review process.
- 8. ' Review preventative maintenance (PM) accomplished DRS to ensure vendor recommendations have been included
and develop a process to ensure vendor
- recommendations are reflected in PM procedures as I appropriate
- 9. Enhance the reasonable assurance of safety (RAS) and DRP justification for continued operation OCO) pr .
- 10. Resolve work control and operations clearance DRP l
l we*Wsm for startup.
W I
RESTART ISSUES CHECKLIST Revisin:1 Date: 5/94 IH. PROGRAMMATIC RESTART ISSUES
- I
. continued -
RESTART ISSUE Resp. Reference Date (IJoensee) Org. Closed I 11. Resolve 1. curring maintenance inadequacies (parts, DRP procedures).
- 12. Review Category I (safety-related) equip:ncet DRP procurement process.
0 r
-_____m__ _ _ _ _ - _ - . _ . - - _ _ - - . . _, o
RESTART ISSUES CIIECKLIST Revision: 2_.
Date:- 5/94 l
l IV. MANAGEMENT OVERSIGHT RESTART ISSUES RESTART ISSUE Resp. Reference Date (Licensee) Org. Closed
- 1. Develop a reasonable assurance that all NRC DRP commitments have been met or are on a schedule for
closure by reviewing an appropriately sized sample of commitments.
- 2. Resolve startup control and mode change defic!cacies. DRP ,
- 3. Resolve vendor / contractor oversight and control DRS 50-286/94-08 l
deficiencies.
- 4. Ensure management's expectations with regard to DRP procedure adherence and sttention to detail are clearly understood.
- 5. Provide operability determination guidance and DRP training to all applicabic station personnel.
- 7. Review all backlogs to assess the safety impact of the DRP items contained in these backlogs. Backlogs include the work request, RES, CAR, REC, PORC open item,
- RIND, and RIP lists.
- 8. Assess NYPA staff attitude with respect to NAP performance improvement.
RESTART READINESS ASSESSMENT CHFIKLIST Revision: _2_
Date: 5/94
- 1. ASSESSMENT OF ROOT CAUSE IDENTIFICATION AND CORRECTION AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. ROOT CAUSE ASSESSMENT NAP
-- "" ' ~ ~ - - ~ "~ ~-- - -
x,7,i;;'ihle liims
- Conditions requiring the shutdown are clearly understood
- Root causes of the condidons requiring the shutdown are clearly understood
- Root causes of other significant problems are clearly understood
- Evaluate adequacy of the root cause analysis progren
- 2. CGRR13CTIVE ACTIONS NAP 8 Anolicable Ittglg
?
! - Evaluate adequacy of the comprehensive corrective action plan
- Evaluate adequacy of the corrective action programs for specific root causes
- Assess control of corrective action item tracking
- Effective corrective actions for the conditions requiring the shutdown have been implemented
- Effeedve corrective actions for other significant problems have been implemented
- Adequacy of the corrective aedon veriScation process
- 3. SELF-ASSESSMFNT CAPABIllTY ,
NAP Atmlic2hleIbmt
- Adequacy of licensee's startup self-assessment
- Effectiveness of Quality Assurance Program
- Adequacy of Industry Experience Review Program
- Adequacy of licensee's Inkpendent Review Groups
- Adequacy of deficiency reporting sygem
- Staff willingness to raise concerns
- Adequacy of Commitment Tracking Program Utilization of external audits (i.e. INPO) ,
l
- Quality and timeliness of 10 CFR 50.72 and 50.73 Reports
RESTART READINESS ASSESSMENT CHECKLIST 4
Revision:._Q_
Date:_ 7/93 H. ASSESSMENT OF LICENSEE MANAGEMENT AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. MANAGEMENT OVERSIGHT AND NAP EFFECTIVENESS Applicable Items
- - Management coinmitment to achieving improved performance
- Performance goals /ex=*ahs h@ for the staff
- Goals / expectations commimleatari to the staff
- Resources available to management to achieve goals
- Management's commitment to procedure adherence
- Management involvement in self-assessment and 1%t self-=====it capability I. - Effectiveness of management review committees
- Management in-plant time
- Management's awareness of day-to.< lay operational concerns
- Ability to identify and prioritize significant issues
- Ability to coordinate resolution of significant issues
- Ability to implamaat effective corrective actions
- 2. MANAGEMENT ORGANIZATION AND NAP SUPPORT
'Applicableltams
- Structure of the organization ,,
- . Ability to adequately staff the organization
- Effect of any management reorganization
- Establishment of proper work environment
-- Ability to resolve @j= concerns
- Ability to provide engineering support
- Adequacy of plant 'ariministrative procedures
- Amount of cotractor usage
-- Adequacy of contractor oversight
- Information exchange with other utilities
- Participadan in industry groups I
4 RESTART READINESS ASSESSMENT CHECKLIST Revision: 0 Date: 7/93 l
III. ASSESSMENT OF PLANT AND CORPORATE STAFF AREA POR ASSESSMENT RB iPONSIBLE STATUS ORfIANIZATION
- 1. ASSESSMENT OF STAFF NAP Anolicable Items -- - .
- Staff commitment to achieving improved performance
- Staff's safety consciousness
- Understanding of management's expectations / goals
- Understanding of plant issues and conective actions
- Effect on the staff of any reorganization
- Resources available to the staff
- Qualifications and training of the staff
- Staff's work environment
- Level of attention to detail
- Adequacy of staffing
- Off-hour plant staffing
- Staff overtime usage
- Amount of contractor usage
- Staff / contractor relationship
- Procedure usage / adherence
- 2. ASSESSMENT OF CORPORATE SUPPORT NAP -
' Apolicable Items
- Relationship between corporate and the plant staff ,
- Adequacy of the request for corporate services process
- Corporate underetanding of plant issues Corporate staff in plant time
- Effectiveness of the corporate / plant interface meetings Adequacy of corporate representation at plant activities
- Adequacy of corporate engin=ing support
- Adequacy of corporate design changes
- Adequacy oflicensing support 4
4
9 RESTART READINESS ASSESSMENT CHECKLIST l*
l III. ASSESSMENT OF PLANT AND CORPORATE STAFF
- continued -
AREA FOR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 3. OPER5TUiUSS' DES
~
~ ' SF~ - - - '
Applicable Items
- Licensed operator staffmg meets requirements and licensee goals
- Level of formality in the control room
- Adequacy of requalification training
- Adequacy of equipment operability determination training "
- Adequacy of SRO command and control
- Control room / plant operator awareness of equipment status
- Adequacy of plant operathig ptooedures
- Procedure usage / adherence
- log keeping practices 9
e 4
m
4 l RESTART READINESS ASSGSMENT CIIECKLIST Revision: 0 Date: 7/93 IV. ASSESSMENT OF PHYSICAL READINESS OF 11IE PLANT AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. ASSESSMENT OF PHYSICAL READINESS NAP OF THE PLANT . _. _ _ _ _
Anoticable Items
- Operability of technical specifications systems
- Operability of required secondary and support systems
- Results of pre-startup testing
- Adequacy of system lineups
- Adequacy of surveillance tests / test program
- Significant hardware issues resolved
- Adequacy of the power ascension testing program
- Adequacy of plant maintenance program effectiveness
- Maintenance backlog managed and impact on operation umwt
- Adequacy of plant housekeeping and equipment storage 4
o RESTART READINESS ASSESSMENT CHECKLIST C
Revision: 0 Date: 7/93 V. ASSESSMENT OF COMPLIANCE WITH REGULATORY REQUIREMENTS AREA POR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION
- 1. ASSESSMENT OF COMPLIANCE WITH NAP
. . ._ _ REGULATORY REQUIREMENTS Applicable Items
- - Applicable license amendments have been issued
- Applicable exemptions have been granted
- Appilcable reliefs have been granted
- Confirmatory Action I.etter conditions have been satis 6ed
- Significant enforcement issues have been resolved
- Allegations have been appropriawly addressed d
RESTART READINESS ASSESSMENT CHECKLIST .
Rcvision: 0 Date: 7/93 VI. COORDINATION WITH INTERESTED AGENCIES / PARTIES AREA FOR ASSESSMENT RESPONSIBLE STATUS ORGANIZATION COORDINATION WITH INTERESTED NAP 1.
AGENCIES / PARTIES Anolicable Items
- Federal Emergency Management Agency
- Appropriate State and Local Officials
- Appropriate Public Interest Groups
- L' .".1 News Media 88
t* *8cg
- '%, UNITED ST ATES
- l. E\ n NUCLEAR REGULATORY COMMISSION I *4 N REGION t
% o, 8 476 ALLENDALE ROAD g KING OF PRUSSIA. PENNSYLVANIA 19406 1415 JM i T MB Docket No. 50-286
' License No. DPR-64 CAL No.1-93-009 Mr. Ralph E. Beedle Executive Via President - Nuclear Generation New York Power Authority 123 Main St.
White Plains, New York 10601
Dear Mr. Beedle:
4
SUBJECT:
CONFIRMATORY ACTION LUITEK 1-936, RESTART COMMITMENTS The NRC and NYPA have identified numerous pmblems related to the performance oflicensed activities at your Indian Point Unit 3 Nuclear Power Plant. Recent questions associated with the operability of the Anticipated Transient Without Scram (ATWS) Miti ation F System Actuation Circuitry (AMSAC) resulted_ in your placing Indian Point Unit 3 in hot shutdown in late February 1993 to evaluate the problem. Subsequently, you placed the plant in cold shutdown in early March 1993 to correct problems with AMSAC and.make other programmatic-improvements. By letter dated March 26,1993, you stated that certain actions would be taken prior to restart of the facility.
The NRC acknowledges your formulation of a Performance Improvement Plan to addmss certain identified pmblem areas and the additional actions you stated in your March 26,1993 letter.
Pursuant to a telephone conversation Ih. yourself and Mr. Curtis J. Cowgill of my staff on
- June 17,1993, we understand that you will take the following actions prior to the restart of the -
Indian Point Unit 3 Nuclear Power Plant from the current performance impmvement outage:
.1. Participate in a management meeting with the NRC staff, open*for public observation, to establish an initial list of mutually agreed upon restart issues.
- 2. Once you have determined that sufficient progress has been made with your corrective actions, complete a startup readiness evaluation, including an assessment of whether the plant and plant support or-indons have the -ry knowledge, skills and abilities to prevent, or detect and correct, future problems in a timely manner.
- 3. Provide the Regional Administrator with the results of your assessment and progress towards readiness for restart of the facility, including those items that remain to be <
completed prior to plant startup, f) % f b& AQ \
qJNW!"! ut {} &
i, 2 7 Mr. Ralph E. Beedle
- 4. Panicipate in a management meeting with the NRC staff, open for public observation, to present the results of the Indian Point Unit 3 startup readiness evaluation.
- 5. When , au are ready in all respects for restart of the facility, provide a letter to the Regional Administrator certifying that fact.
- 6. As committed in your letter of March 26,1993, obtain the agreement of the Regional Administrator, Region 1, prior to the restart of Indian Point Unit 3.
We note that following the management meeting discussed in item 4 above, the NRC will conduct a Readiness Assessment Team Inspection.
Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C. 2232, and 10 CFR 2.204, you are required to:
- 1. Notify me immediately if your understanding differs from that set forth above.
- 2. Please notify me in writing if for any reason you cannot complete the actions.
Issuance of this Confirmatory Action Letter does not preclude issuance of an Order formalizing Nor does it the above commitments or requiring other actions on the part of the licensee.
preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enfortement action.
De response directed by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.L.96-511 In accordance with 10 CPR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Sincerely,
/k" Thomas T. Martin Regional Administrator i
Mr. Ralph E. Beedle 3 :
cc:
' R. Schoenberger, President -
R. Beedle, Executive Vice President - Nuclear W. Josiger, Vice President - Nuclear Operations G. Goldstein, Assistant General Counsel-P. Kokolakis, Director, Nuclaar Licensing - PWR G. Begany, Mayor, Village of Buchanan C. Jackson; Nuclear Safety and Licensing Manager (Con Ed)
C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law Chairman, Standing Committee on Energy, NYS Assembly
- Chairman,- Standing Committee on Environmental Conservation, NYS Assembly Executive Chair, Four County Nuclear Safety Committee Director, Energy & Water Division, Departmen, of Public Service, State of New York K. Abraham, PAO (2)
- Public Document Room (PDR) local Public Document Room (ISDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York, SLO Designee -
Y
i
- UNITED STATES
'go E E NUCLEAR REGULATORY COMMISSION b 5 E REGION I 8, 475 ALLENDALE ROAD
,o*[- KING OF PRUSSIA. PENNSYLVANIA 194061415 a...+ '
AUG - 81994 Docket No. 50-286 Mr. William A. Josiger Acting Executive Vice President - Nuclear Generation New York Power Authority 123 Main Street
- White Plains, New York 10601
Dear Mr. Josiger:
SUMECT:- COMMENTS REGARDING THE INDIAN POINT 3 RESTART AND CONTINUOUS IMPROVEMENT PLAN By letter dated May 27,1994, you formally submitted the Indian Point 3 Restart and Continuous Improvement Plan (RCIP) to the NRC. The RCIP contains objectives, strategies, and action plans designed, in their totality, to address the root and contributing causes of the performance decline at Indian Point 3 and provides success paths for restart as well as 4 continuous performance improvement. We understand that the RCIP replaces the Performance Improvement Plan (PIP) that had been developed in January 1993. The RCIP was initially discussed with the NRC at a public meeting on May 26,1994. '
As you am aware, in January 1993 the NRC formed the NYPA Assessment Panel (NAP).
'Ihe principal purpose of the NAP is to assist Region I and the Office of Nuclear Reactor Regulation (NRR) in the coordination of NRC resources for the performance monitoring and assessment of both the FitzPatrick and Indian Point 3 plants as well as the NYPA corporate office. The NAP charter included, in part, the specific responsibility to assess the adequacy
- of and monitor the implementation of Indian Point 3 improvement plans. As such, the NAP reviewed the PIP and forwarded an initial assessment by letter dated April 12,1993. 'Ihe NAP continued to assess your implementation of the PIP throughout 1993, and at a public meeting on December 17,1993, concluded that your implementation of the PIP did not appear to be effective at achieving performance improvement. You reached the same conclusion as the. NRC and embarked on developing another improvement plan in January 1994. The RCIP was completed in May 1994 and was presented to the NAP at a public meeting on May 26,1994.
The NAP has completed its initial review of the RCIP and concludes that, if properly implemented, the RCIP should correct the fundamental issues responsible for the performance decline at Indian Point 3. It appears that the PIP short comings were n<msed by NYPA and have been corrected in the RCIP. Our initial num= ment was based on the following:
,, N7'/ h fl( - .
L{UC5iUUU W ~ [
a g 2
k, Mr. William A. Josiger l
~
- 'Ihe RCIP development team included experienced consultants to incorporate success paths used at other " troubled" facilities. The team used input from FitzPatrick and the NYPA corporate office as well as Indian Point 3.
- 'the toot cause analysis performed for the RCIP appears thorough and valid.
-- The RCIP contains objectives, strategies, and action plans with specific managers assigned responsibility for their implementation. The action plans have specific results-oriented tasks and have been integrated into the Indian Point 3 work scheduling system.
- The RCIP contains a multi-level review and assessment process to ensure each action plan has been properly completed prior to closure. In addition, the RCIP contains a detailed restart readiness assessment; thus, the mechanisms are in place to enable successful implementation of the plan.
- The RCIP contains a process for changing the plan if needed and for adding emerging issues as required.
- A senior NYPA manager has been assigned as the RCIP prcject manager to ensure proper implementation of the plan.
Your staff explained the RCIP'to the NRC at the May 26,1994, mating and it appeared that your staff was enthusiastic and committed to properly implemerdng the RCIP. It was also evident that NYPA management is committed to achieving performance improvement at Indian Point 3 since, ulike the PIP, the RCIP was reviewed ar.d approved by the highest levels of NYPA management.
We have concluded that the RCIP is comprehensive. 'Iherefore, the NRC has no specific questions or comments regarding the RCIP at this time. Nonetheless, ye believe that the RCIP, by itself, cannot ensure the smitful restart and continuous improvement eury at Indian Point 3. Proper day-to-day execution of operating, maintenance, engineering and y support activities is wary to achieve successful implementation of the RCIP. 'Ihe NAP will continue to assess and monitor these activities.
--.- _ _ _ i __.-._________._
g.
'A 2
! Mr. William A. Jostger 3 If you have any questions regarding this matter, please contact Mr. Curtis J. Cowgill at (610) 337-5233..
Sincerely, Richard W. Cooper, II, Director Division of Reactor Projects cc:
S. Freeman, President & CEO R. Schoenberger, First Executive Vice President & COO J. Kelly, Acting Vice President - Nuclear Operations R. Patch, Director, Quality Assurance L. Hill, Resident Manager G. Goldstein, Assistant General Counsel P. Kokolakis, Director, Nuclear Licensing - PWR A. Donahue, Mayor, Village of Buchanan C. Jackson, Nuclear Safety and Licensing Manager (Con Ed)
C. Donaldson, Esquire, Assistant Attorney General, New York Department of law Chairman, Standing Committee on Energy, NYS Assembly Chairman, Standing Committee on Environmental Conservation, NYS Assembly Executive Chair, Four County Nuclear Safety Committee Chairman, Committee on Corporations, Authorities, and Commissions Robert D. Pollard, Union of Concerned Scientists The Honorable Sandra Galef, NYS Assembly Director, Energy & Water Division, Department of Public Service, State of New York K. Abraham, PAO (2 copies)
Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector State of New York, SLO Designee w -
)
1 g.
Mr. William A. Jostger 4 bec:
Region I Docket Room (with concurrences)
C. Cowgill, DRP P. Eselgroth, DRP R. Urban, DRP G. Tracy, Indian Point 3 W. Dean, OELO P. Kuo, NRR N. Conicella, NRR
( s ** "8 %y
+ ?, UNITED ST ATES 8 ' ,n NUCLEAR REGULATORY COMMISSION d.$ I REGION I
%,***** ,e** KING OF PRUSS A NN LVAN A 19406141b December 13, 1994 Mr. Leslie Hill, Jr.
Resident Manager New York Power Authority (NYPA)
, Indian Point 3 Nuclear Power Plant l Post Office Box 215 Buchanan, NY 10511
SUBJECT:
DOCUMENT REQUEST FOR RESTART ASSESSMENT TEAM INSPECTION-
Dear Mr. Hill:
As discussed with you.during the November 17, 1994 public meeting on the Indian Point Unit 3 restart, we will conduct a Restart Assessment Team Inspection (RATI) at Indian Point Unit 3 in early 1995 when you have concluded you are ready. The purpose of this inspection is to assess your readiness to safely restart Indian Point Unit 3.
In order to conduct this type of comprehensive inspection, we will need to review, in advance, certain documents. We request that you send one copy of the documents identified in the enclosure to the NRC, Region I office, c/o Mr. James Trapp, 475 Allendale Road, King of Prussia PA 19406, by January 9, 1995.
Your cooperation with us during this inspection will be appreciated. Should you have any questions regarding this request or the inspection, you may contact Mr. Jim Trapp at (215) 337-5186.
Sincerely,
~
. It Cur is J. C jill, III, Chief Projects B th No. 1 ~
Division of Reactor Projects Docket No. 50-286
Enclosure:
RATI Document Request List n iTT b -
.I Mr. Leslie Hill, Jr. 2 ,
cc w/ enc 1:
S. Freeman, President and Chief Executive Of 71cer R. Schoenberger, Chief Operating Officer W. Cahill, Executive Vice President - Nuclear Generation W. Josiger, Vice President - Operations J. Kelly, Vice President - Special Projects and Regulatory Affairs T. Dougherty, Vice President - Nuclear Engineering R. Patch, Director - Quality Assurance G. Wilverding, Manager, Nuclear Safety E 31uation G. Goldstein, Assistant General Counsel C. Faison, Director, Nuclear Licensing - PvR, NYPA A. Donahue, Mayor, Village of Buchanan C. Jackson, Nuclear Safety and Licensing Manager (Con Ed)
C. Donaldson, Esquire, Assistant Attorney General New York Department of Law Chairman, Standing Committee on Energy, NYS Assembly Chairman, Standing Committee on Environmental Conservation, NYS Assembly E. Nullet, Executive Chstr, Four County Nuclear Safety Committee Chairman, Committee on Corporations, Authorities, and Commissions Robert D. Pollard, Union of Concerned Scientists The Honorable Sandra Galef, NYS Assembly Director, Energy & Water Division, Department of Public Service, State of New York State of New York, SLO Designee i
I e
4 1
Mr. Leslie Hill, Jr. 3 i Distribution w/ enc 1:-
K. Abraham, PA0 PUBLIC Nuclear Safety Infomation Center (NSIC)
NRC Resident Inspector
. Region I Docket Room (w/ concurrences) a i
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.I ENCLOSURI ,
RATI DOCUMENT REQUEST LIST Onerations e Operations Directives (00s).
e Plant Operating Procedures (POPS).
e Operator Training matrix verifying both licensed and non-licensed operator participation in re-qualification training. Also provide records for fire brigade member training.
e Records of ' approvals for operations personnel exceeding administrative' overtime guidelines for the past 6-months (if any).
e Provide a list of outstanding control room deficiencias. Indicate which of these deficiencies are planned to be corrected prior to plant start-up, o Provide a copy of the completed plant log sheets for the last week.
Also provide a copy of the plant log sheets that will be used following mode changes, o Provide a copy of the Shift Supervisor, Control Room, and Nuclear Plant Operator log book entries for the past week.
o Provide a copy of the plant turnover sheets for the last week, o Provide the valve check-off log sheets and associated procedures for the alignment of the safety injection (SI), residual heat removal (RHR), and component cooling systems (CCW).
e Provide the System Certification documentation for the SI, RHR, CCW, and the blackout diesel generator, e Provide the system descriptions and design basis docudents for the SI, RHR,'and.CCW systems, e Provide training material and training records for operator training on system modifications installed during the current performance improvement outage, e Summaries =of Deficiency / Event Reports (DERs) written against operations for the last two years, e A copy of Shift Orders for the past week all Standing Orders, and currently existing Night Orders.
e Technical Specification Interpretations.
1 .
2 e Schedule of planned Operations activities for January and February (ie fire drills, etc.).
- List of operator work arounds.
- Shift Schedule and breakdown of crew assignments.
Maintenance / Surveillance e A list of outstanding maintenance deficiencies. Provide an indication as to which of these deficier:.les are planned for resolution prior to plant restart. ,
o Provide a list of preventive maintenance which is beyond the scheduled due dates and is not planned to be conducted prior to plant restart.
Provide evaluations / justifications for deferrals, o Maintenance and I&C Administrative procedures which describe your corrective, preventative and predictive maintenance programs.
e- Procedures, charts and other documents which describe your work planning process, e Documents which describe the Maintenance and Operations interface during planning, scheduling, work start, work closcout-and post maintenance testing, e Documents, including training records, which describes training and retraining of plant and contractor maintenance personnel, o Provide documents which describe how maintenance performance is measured. Also provide the results of the last two maintenance performance: indicator reports.
- Provide a list of post maintenance test failures in the past 6-months.
- Also provide evaluations for failures, including failures identified in the-scope-of-work.
- Provide a schedule on surveillance test planned for the week of January 23, 1995. Also provide the test procedures for any surveillance to be conducted during that week on safety-related equipment.
- Provide a schedule of maintenance and I&C activities planned for the week of January 23, 1995. Also provide the procedures and work packages for any activities to be conducted on safety-related equipment.
Management Proarams/ Independent Oversight
, e Provide a copy of the plan and report for your restart assessment.
I
,f i
3 e Organization charts for all NYPA personnel involved in Indian Point 3 activities.
- Provide administrative procedures for the corrective action program. In addition, provide a copy of the last ten completed root cause evaluations. Provide a listing of outstanding corrective actions items.
- Provide the plant start-up plan.
e Provide open action commitment tracking (ACTS) items.
- Provide the last two perfomance measures reports.
- Provide administrative procedures and the last two self-assessments conducted in the areas of operations, maintenance, surveillance, and engineering / technical support. Also provide the open action items from se f-assessments in these three areas, o Provide the last two Quality Assurance (QA) audits / surveillance ,
conducted in operations, maintenance / surveillance and engineering.
- Provide a list of open QA audit findings.
- Provide administrative controls and the minutes from the last two Safety Review Committee (SRC) meetings.
- Provide a list of open Plant Operations Review Committee (PORC) items.
Also provide a copy of the PORC meeting minutes for the last two PORC meetings.
Enaineerina e Provide Justification for Continued Operation (JCOs), Reasonable Assurance of Safety (RAS), Basis for Maintaining Operability (BMO) or other operability evaluations performed in the past two years.
-e Provide a list of outstanding temporary modifications't Also provide the administrative procedures for controlling temporary modifications.'
o Provide a list of open engineering service requests. Provide the administrative procedures for controlling engineering service requests.
- Administrative procedures for the modification and safety evaluation process.
e Provide a list and brief description for all modifications (Major, Minor, and 1-for-1 replacements) installed during the current outage.
- Provide a list of plant drawings, procedures, and vendor manuals that require updating due to plant modifications.
1
,' 4 o Provide a list of open action items from the Operative Review Group.
Also provide administrative procedures from this program.
0 System Engineering Administrative procedures, l
o Provide documents which describe how engineering / technical support performance is measured. Also provide the results of the last two engineering / technical support perfomance indicator reports.
O Provide documents which describe the prioritization process for
-modifications. Provide a list of design changes packages which are currently in the process which are waiting for prioritization and those that have previously been prioritized.
Y