Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
1
1 UNITED STATES OF AMERICA
2 NUCLEAR REGULATORY COMMISSION
3 OFFICE OF THE SECRETARY
4 ***
5 BRIEFING ON THE D.C. COOK PLANT
6 ***
7 PUBLIC MEETING
8
9 Nuclear Regulatory Commission
10 Commissioners' Conference Room
11 Building 1
12 One White Flint North
13 11555 Rockville Pike
14 Rockville, Maryland
15 Monday, January 10, 2000
16 The Commission met in open session, pursuant to
17 notice, at 10:05 a.m., the Honorable RICHARD MESERVE,
18 Chairman of the Commission, presiding.
19 COMMISSIONERS PRESENT:
20 RICHARD A. MESERVE, Chairman
21 GRETA J. DICUS, Commissioner
22 NILS J. DIAZ, Commissioner
23 EDWARD McGAFFIGAN, JR., Commissioner
24 JEFFREY S. MERRIFIELD, Commissioner
25
2
1 STAFF AND PRESENTERS SEATED AT THE COMMISSIONER'S TABLE:
2 WILLIAM TRAVERS, Executive Director for Operations
3 E. LINN DRAPER, Chairman & CEO, AEP
4 JOE POLLOCK, Plant Manager, D.C. Cook
5 ROBERT P. POWERS, Sr. Vice President, Nuclear
6 Generation and Chief Nuclear Office, AEP
7 CHRIS BAKKEN, Site Vice President, AEP
8 MIKE RENCHECK, Vice President, Nuclear
9 Engineering, AEP
10 DAVID LOCHBAUM, Nuclear Safety Engineer, Union of
11 Concerned Scientists
12 JIM DYER, Administrator, Region III
13 JOHN GROBE, Director, Division of Reactor Safety,
14 Region III
15 SAMUEL COLLINS, Director, NRR
16 JOHN ZWOLINSKI, Director, Division of Licensing
17 and Project Management, NRC
18 SCOTT GREENLEE
19 ROBERT GODLEE
20 DON NAUGHTON
21 BILL SCHALK
22 WAYNE KROPP
23 MIKE FINISSI
24 SAM BARTON
25 DAVID KUNSEMILLER
3
1 P R O C E E D I N G S
2 [10:05 a.m.]
3 CHAIRMAN MESERVE: Good morning. On behalf of the
4 Commission I would like to welcome you to today's briefing
5 on the D.C. Cook plant.
6 The Commission will hear from representatives of
7 American Electric Power, the licensee for D.C. Cook, the
8 NRC's Region III office, and Mr. David Lochbaum of the Union
9 of Concerned Scientists.
10 The D.C. Cook plant was shut down in September,
11 1997, following an Architect and Engineering inspection that
12 identified significant problems with safety systems.
13 Subsequent inspections identified additional safety system
14 deficiencies, most notably with the ice condensers. The NRC
15 issued a confirmatory action letter in September, 1997,
16 requiring the licensee to address issues discovered during
17 the AE inspection and to perform further assessments and
18 take appropriate corrective actions prior to restarting the
19 plant.
20 After a slow start AEP has made substantial
21 progress in discovering, evaluating and correcting a large
22 number of issues, and after more than two years of effort is
23 within sight of achieving restart.
24 I visited the D.C. Cook plant in December, 1999,
25 and was impressed with the frank discussion by AEP of past
4
1 problems and deficiencies and of the steps that it had been
2 taking to ensure that these problems and deficiencies are
3 corrected and do not recur.
4 I was also impressed by the magnitude and quality
5 of the NRC Staff's oversight activities.
6 I understand that copies of the handouts are
7 available at the entrances. Unless my colleagues have any
8 comments they would like to make, you may proceed.
9 COMMISSIONER MERRIFIELD: Well, actually, Mr.
10 Chairman, just to make a note, since our last meeting I,
11 too, have had the opportunity to travel to Michigan and
12 visit at the D.C. Cook facility and meet with the
13 individuals at this table as well as the staff of the
14 facility and our Staff up there, and I would share the
15 Chairman's comments about the work being done by the
16 licensee and equally as well the hard work being done by our
17 Staff to resolve these issues and move forward, and so thank
18 you very much for your additional consideration.
19 CHAIRMAN MESERVE: Any other opening statements?
20 [No response.]
21 CHAIRMAN MESERVE: If not, Dr. Draper, you may
22 proceed.
23 DR. DRAPER: Thank you, Chairman Meserve, and
24 thank you, Commissioners, for taking the time to be with us
25 today.
5
1 I am Linn Draper, Chairman and Chief Executive of
2 American Electric Power. With me today are Bob Powers,
3 Senior Vice President, Nuclear Generation, who is
4 responsible for all aspects of our D.C. Cook operations;
5 Chris Bakken, D.C. Cook Site Vice President; Mike Rencheck,
6 Vice President of Nuclear Engineering; and Joe Pollock, the
7 D.C. Cook Plant Manager.
8 Bob is our Chief Nuclear Officer. He will lead
9 the presentation today to review the progress made towards
10 the restart of the Cook plant.
11 Chris Bakken joined AEP from Public Service
12 Electric & Gas Company, where he was Plant Manager for the
13 two Salem units. Chris was a key manager responsible for
14 returning those units for operation, and instilling the high
15 standards of safety, reliability and accountability that
16 enabled that organization to continue to perform well.
17 Mike Rencheck joined AEP from Florida Power
18 Corporation, where he was Director of Engineering. He was
19 part of the successful Crystal River 3 restart as well as
20 the Salem restarts at PSE&G;.
21 Joe Pollock also joined us from Public Service
22 Electric & Gas Company, where he was the Maintenance Manager
23 and previously the Quality Assurance Manager.
24 This has been a long and costly outage to AEP. It
25 has been necessary to make improvements to our systems, our
6
1 components, material condition, processes, personnel
2 training and our organizational culture. It has also been
3 an important outage because it marks a renewed commitment by
4 AEP to safety returning the D.C. Cook units to full power
5 operation.
6 As the Chairman mentioned, the outage began in
7 September of 1997. We shut down both units to address
8 concerns raised by the NRC regarding the ability of the
9 emergency core cooling system and the containment system to
10 function properly in the unlikely event of a loss of coolant
11 accident.
12 In early 1998, after we clearly saw the magnitude
13 and the nature of the ice condensers issues, we decided to
14 melt the ice and rebuild the ice condensers to a superior
15 condition. This was the first of many similar and tough
16 decisions to do the right thing when confronted with a
17 problem involving the capability of a safety system or a
18 component to perform its intended function. In fact, doing
19 the right thing every step of the way has become the major
20 theme for all of the work done at the Cook plant.
21 It was clearly demonstrated in our decision a year
22 ago to stop the outage work and take the extra time to
23 complete the expanded system's readiness reviews that both
24 Mike and Bob will discuss. It was reinforced as we
25 authorized the resources to begin the necessary repairs and
7
1 modifications to the plant and to revamp engineering
2 programs, surveillance programs, and the Corrective Action
3 Program and other areas in need of improvement that you will
4 more about in just a few minutes.
5 Under the direction of Bob Powers, we have made
6 significant changes to the D.C. Cook management team. We
7 have a number of the members of the Cook team here today.
8 Bob, Chris and Mike will discuss some of the cultural
9 changes we have made to strengthen our management team and
10 prepare for the restart of the Cook units.
11 Many of the Cook team men and women have assisted
12 in the restart of other nuclear plants across the country.
13 They further demonstrate AEP's commitment to provide the
14 resources necessary to restart this important generation
15 resource for our system.
16 When we met last with the Commission in November,
17 1998, I said it was clear to me that one factor that led to
18 our present situation was an insular and complacent attitude
19 that had developed over many years within the Nuclear
20 Generation Department. We were not identifying our own
21 problems. We were not aggressive in correcting the problems
22 that we did identify. We did not question conditions that
23 had existed for many years and our oversight of the Cook
24 operations was not adequate.
25 AEP has made a commitment to provide the resources
8
1 necessary to correct these conditions to restart the Cook
2 units and to return our Nuclear Generation Division to an
3 industry leadership position.
4 As I mentioned in the beginning, this outage has
5 been very expensive to AEP. We have lost the entire output
6 of one of our largest generation plants for over two years.
7 We have spent considerable additional resources rebuilding
8 the ice condensers and making other necessary modifications
9 and repairs to the plant.
10 With the progress we will report today, we can now
11 see the end to this outage, basically on the schedule that
12 we announced in the middle of last year. We are confident
13 that the investment in D.C. Cook will result in a safer,
14 more reliable and more efficient operating plant. We
15 clearly understand that excellence in nuclear plant
16 performance will return economic dividends to AEP by
17 enabling Cook to achieve higher capacity factors, lower
18 operating and maintenance costs, and shortened refuelling
19 and maintenance outages.
20 We are also preparing Cook for license renewal.
21 We think that extension of its useful life beyond the
22 current limits of the NRC operating licenses will be
23 valuable to us. In fact, it will be a key to our economic
24 recovery.
25 We look forward to the D.C. Cook's plant's
9
1 resumption of its critical role in meeting the electricity
2 supply needs in Michigan and Indiana. AEP's commitment to
3 nuclear power also extends beyond the Cook plant to the
4 acquisition of a 25 percent interest in the South Texas
5 Project through our merger with the Central and Southwest
6 Corporation. The approval process is moving forward on a
7 definitive timeline and we expect to complete the merger in
8 the spring.
9 Nuclear power will be a long-term and significant
10 component of the AEP generation mix. In order to ensure the
11 success of Cook and the nuclear generation business sector
12 in both the near and long-term futures, AEP has taken steps
13 to improve its oversight. I am personally continuing my
14 active oversight of Cook through periodic meetings with Bob
15 Powers and the independent safety review group. This group
16 is made up of six well-respected nuclear consultants who
17 report to Bob as Chief Nuclear Officer and to me as CEO.
18 In our reorganization following the merger with
19 CSW, nuclear generation will continue to report directly to
20 me. I will continue to devote a significant segment of my
21 time to ensure nuclear safety and the effectiveness of our
22 nuclear power operations.
23 Bob and I meet essentially monthly with the AEP
24 Board of Directors or with our Nuclear Oversight Committee
25 of that Board that was formed in April of 1999. The Nuclear
10
1 Oversight Committee is made up of five outside Directors of
2 our corporation. Its purpose is to provide long-term,
3 focused oversight of this important sector of the company.
4 It has met four times -- once at the Cook plant -- to review
5 Cook restart work and plans. The committee will continue to
6 meet periodically to review the Cook status.
7 In sum, as you will hear from Bob and his team, we
8 have made significant progress this past year, and have the
9 end of this long outage in sight. We have assembled a
10 talented and experienced management team which is instilling
11 the right kind of safety consciousness and standards for
12 excellence. AEP has given its full support and commitment
13 of resources to Bob and the Cook team to do the job right,
14 and they are doing just that.
15 If there are not questions, we will commence with
16 the formal presentation. There is an agenda slide which I
17 believe has come up. Bob will begin with an overview or
18 perspective of what we found needed to be changed, the
19 process we are using to make those changes, and a snapshot
20 of where we currently stand, then Mike will discuss the
21 extensive discovery effort completed by the Cook team, its
22 results and some of our more important accomplishments.
23 Chris will cover the implementation phase of our
24 restart plan, discussing the preparations being made to
25 ensure a safe restart of the Cook units, and finally Bob
11
1 will provide some closing remarks, and we would be delighted
2 to entertain questions either now or along the way, however
3 you prefer.
4 CHAIRMAN MESERVE: Why don't we proceed, and we'll
5 come back to questions at the end of the presentation.
6 DR. DRAPER: Bob?
7 MR. POWERS: Thank you, Linn.
8 When I came to Cook in August of 1998, restart
9 efforts had been underway for about a year. I arrived with
10 a background of what a well-run plant looked like, and based
11 on my understanding of the situation at Cook I knew that a
12 substantial challenge lay ahead for the employees and for
13 me.
14 To help define that challenge and determine the
15 best course of action in response, I had to access what the
16 differences were between performance at Cook and the
17 performance we would need to successfully restart and for
18 long-term operations.
19 As a starting point for this comparison I compared
20 what I saw at Cook with four essential cultural attributes
21 found at successful nuclear plants. I believe the
22 fundamentals of a healthy nuclear safety culture include the
23 characteristic that people must be first and foremost
24 focused on safety. There must be capable leadership within
25 the organizations and at the senior management level. The
12
1 organizations must also be self-critical, and the Corrective
2 Action Program must operate effectively. Finally, people
3 must be adequately trained and prepared for their jobs.
4 As you might imagine, I used a number of sources
5 to gather data for my assessment and how the culture at D.C.
6 Cook compared with these fundamentals. I received numerous
7 briefings from my direct reports and their staffs and I
8 talked with many of our employees. I physically observed
9 ongoing work, toured critical plant areas, and reviewed key
10 documentation related to the work and problems that had been
11 identified up to that point.
12 I also sponsored assessments by our Quality
13 Assurance Department and chartered other independent
14 assessments.
15 The principal findings of my assessments are
16 listed on the right hand side of the slide. Basically I
17 determined that the people at Cook had become insular in
18 their focus and approach to managing the power plant. This
19 led to gaps between how Cook did business and how many in
20 the industry were doing business, particularly in the
21 engineering disciplines.
22 While the organization at Cook had been dedicated
23 over the years to ensuring that the plant ran well, I
24 believe Cook's good operating history had a substantial
25 influence on how people viewed problems when they arose.
13
1 For example, even when technical issues were identified by
2 the NRC's Architect-Engineering Inspection Team, I believe
3 many people at Cook didn't fully appreciate what these and
4 other identified problems meant in terms of breakdowns and
5 design control and compliance with the licensing basis.
6 I found that change management was not effective.
7 This was probably best seen in the move of the Engineering
8 organization in two stages from New York City to Columbus,
9 Ohio, and then to our near-site offices. Large numbers of
10 experienced engineers were lost because of the moves and the
11 impact on the organization led to a lack of understanding
12 and focus on certain areas such as design and licensing
13 bases
14 I also confirmed that there were deficient
15 processes and programs. This was particularly notable in
16 the areas of design control, safety evaluations, corrective
17 actions, and training.
18 In the area of corrective actions, problems were
19 not being found or documented in some cases, but in
20 addition, when they were identified there too often was
21 little or no follow-up. This left a backlog of unresolved
22 issues. Besides the problems with the ice condenser these
23 technical issues reduced assurance that certain systems were
24 capable of meeting their safety and accident mitigation
25 functions.
14
1 My assessment also revealed that our training
2 programs were in poor shape. This situation enabled the
3 insular perspective found at the site, rather than serving
4 as a platform to enhance human performance and help assure
5 that industry standards were being met.
6 In retrospect, and having had the benefit now of
7 our expanded discovery efforts, I can understand why we
8 couldn't answer a number of fundamental design and licensing
9 basis questions raised by the Architect-Engineering Team and
10 other NRC inspectors. Simply stated, as an organization
11 Cook had lost focus on maintaining the design basis and in
12 providing strong configuration management, which are both
13 vital to preserving safety margins.
14 Overall, it was clear to me that the fundamentals
15 were missing.
16 Faced with the gaps I mentioned, and the missing
17 fundamentals, I had re-establish a foundation for successful
18 restart and beyond. This required setting the overall
19 direction for the organization. It also required putting
20 some stakes in the ground to help guide our people along the
21 way.
22 I came to Cook with high standards, as did my
23 management team. We all recognized that to achieve
24 successful cultural change we must communicate our standards
25 effectively and provide continual reinforcement.
15
1 This next slide summarizes my standards as key
2 management expectations. It is through the implementation
3 of these expectations that we are changing the culture at
4 Cook.
5 These management expectations are placed
6 throughout the plant and our engineering offices. When I
7 rolled them out, I met with my managers and supervisors to
8 discuss the expectations. I indicated that it was my goal
9 for each manager to internalize the expectations, pass them
10 on to the staffs, and begin to use them in the conduct of
11 work.
12 I don't intend to go over each of these with you
13 this morning. However, I would like to make a few points
14 about them.
15 First, I would like you to note that the
16 expectations are behavior-based. I believe that to sustain
17 change people must learn repeatable behaviors that support
18 the nuclear safety fundamentals I previously mentioned.
19 The second point I want to make is that the end
20 results of these expectations are the same ones demonstrated
21 by personnel at well-performing plants. For example,
22 promptly identifying and correcting problems leads to a
23 questioning attitude. Doing what we say we will do leads to
24 ownership. Accepting accountability for yourself and your
25 coworkers builds teamwork and an entire organization
16
1 grounded on the principle of accountability.
2 Each of these expectations focuses on people.
3 Although the plant and our processes are very, very
4 important, ultimately people make all the difference. When
5 the units and the processes are completely fixed, the
6 strength of our people will be the way we reach our ultimate
7 goal of world class performance.
8 In the end, what we are doing at Cook is nothing
9 fancy. We are concentrating on the fundamentals like clear
10 management expectations, and I believe if we do the
11 fundamentals right, we will be successful in restarting the
12 plants and long-term safe and efficient operation.
13 At this point in our change efforts my management
14 team and I are still providing strong top-down direction for
15 the organization. However, we are seeing signs that our
16 management expectations are taking hold. In fact, some of
17 the performance improvements that Mike and Chris will
18 discuss later are a direct result of this.
19 I fully expect that as our staff matures and
20 becomes more self-sustaining they will be able to take on
21 more responsibility for determining the successful direction
22 of our efforts. This will allow my senior management staff
23 and me to concentrate our attention on other long-term
24 issues such as business process redesign and license
25 renewal.
17
1 However, setting expectations and getting our
2 people moving in the right direction was just part of what
3 was needed to restart the plants. This next slide provides
4 an overview of our restart plan.
5 This slide gives you an overview of the major
6 steps in our restart process. The process involves four
7 basic phases.
8 First, discovery of issues; then implementation of
9 corrective actions; third, verification our corrective
10 actions were effective, ultimately leading to restart by the
11 units. This is the process we have been following since
12 early of last year.
13 However, as I alluded to earlier, the initial
14 discovery efforts at Cook were limited in focus. When I
15 first arrived at Cook, the information I was receiving from
16 my staff indicated that in their minds the recovery effort
17 was nearing completion. As much as I hoped the Cook staff
18 was correct, I pulled the string on this information and the
19 more I pulled the more the message was mixed.
20 As I looked harder, it became clear that the
21 initial discovery efforts had not been conducted using
22 effective procedures, nor had effective training been given
23 to the engineers performing the reviews. Consequently, the
24 results were inconsistent and only a limited number of
25 issues were identified.
18
1 Because of this limited focus, we didn't have a
2 full understanding of the causes and thus we didn't really
3 know where else to look. In addition, it seemed like every
4 time the NRC looked at an area more issues were uncovered.
5 It was obvious that we needed to broaden our
6 review. To start us down this path in September of 1998 I
7 helped assure that we did a thorough and comprehensive job
8 while conducting a safety system functional inspection of
9 the auxiliary feedwater system at the Cook plants.
10 Now since this system had supposedly been scrubbed
11 by our -- cleaned by our previous reviews, it would serve as
12 a bellwether of the accuracy of our previous efforts. Later
13 in the fall of 1998 I also initiated a Blue Ribbon expert
14 panel review of our engineering programs. Both of these
15 efforts turned up substantive issues requiring further
16 evaluation and by late 1998 it was clear to me that
17 something bold needed to be done if the facility was to
18 restart.
19 It was in this same timeframe that I hired Mike
20 Rencheck and subsequently directed a more thorough discovery
21 effort take place. Under Mike's leadership, our initial
22 discovery process was expanded to include a more
23 comprehensive review of our plant systems and also the
24 performance of our departments and of our key processes.
25 Mike will give you more detail about the discovery process
19
1 in his presentation.
2 During the initial period of our expanded
3 discovery early last year, it became clear that I would need
4 to further rebuild the management team as well. Chris and
5 Joe and Mike represent important elements of that rebuilding
6 process. It also became clear that we would have to re-
7 establish the Engineering organization, improve our
8 oversight capability and work to restore our credibility
9 with the NRC.
10 We believe we have made substantial progress in
11 each of these areas. Chris and Mike will give you more
12 detail about our implementation efforts later on.
13 So where does this leave us today? As the icon
14 illustrates, we are currently putting all the pieces
15 together that are necessary for the Cook organization to not
16 only safety restart the units but support our longer term
17 goal of excellence. We have not completed all the
18 remediation work yet, but we do know what else needs to be
19 done. We have a schedule to perform the remaining work and
20 we are committed to safety and quality along the way as we
21 have been throughout our restart efforts.
22 We have accomplished a great deal over the last
23 year. For example, we have submitted the items in our
24 confirmatory action letter to you for closure. We have
25 submitted all of our license amendment requests for Unit 2
20
1 restart. We have undergone numerous NRC inspections,
2 including several major inspections such as the recent
3 Engineering Corrective Action Team Inspection, ECATI, and
4 these inspections support our belief that the Engineering
5 organization has improved and that our Corrective Action
6 Program, our self-evaluation process, and our training at
7 the Cook facility are effective.
8 From an organizational standpoint, we are turning
9 our attention to human performance, and Chris will discuss
10 that later.
11 In addition, I have personally devoted time to
12 ensuring that there is a strong management team for restart
13 and beyond. On this latter point, we have assembled a
14 strong leadership team here at Cook, and I expect it to
15 provide a guiding and stabilizing force for our future
16 efforts.
17 The individuals seated behind me are a few of the
18 people -- introduce yourself, guys.
19 MR. FINISSI: Mike Finissi, Director of Plant
20 Engineering.
21 MR. GODLEE: Robert Godlee, Director of Regulatory
22 Affairs.
23 MR. KROPP: Wayne Kropp, Director of Performance
24 Assurance.
25 MR. GREENLEE: Scott Greenlee, Design Engineering
21
1 Director.
2 MR. BARTON: Sam Barton, Site Senior License.
3 MR. NAUGHTON: Don Naughton, Senior Systems
4 Engineer.
5 MR. SCHALK: Bill Schalk, Communications.
6 MR. KUNSEMILLER: Dave Kunsemiller, Technical
7 Assistance.
8 MR. POWERS: Thanks, guys.
9 These and other individuals represent the
10 management and technical depth of our current team.
11 Although we may experience some turnovers in moves toward
12 normal staffing levels, we intend to keep high-performing
13 people by providing them with a challenging and rewarding
14 environment.
15 Now with regards to the physical work of fixing
16 the plant we also have accomplished a great deal but by far
17 the singlemost man-hour intensive effort we have underway is
18 the repair and reload of our ice condensers. I would like
19 to give you a brief description of this work and provide an
20 update of where we are today with their refurbishment.
21 Next slide, please.
22 MR. POWERS: Approximately 3,800 bags of ice, like
23 the one shown here, were filled using the Cook Plant ice-
24 making machine in 1998. Each bag contains approximately
25 1,200 pounds of ice and it has been stored in an off-site
22
1 cold storage facility since that time. We have periodically
2 sampled the ice while it has been in storage to ensure its
3 quality.
4 As the first step in reloading, the ice is
5 transported by refrigerated tractor-trailers to the station.
6 After removal, it is brought to an ice crusher, which is
7 shown in the next slide. Each bag is brought in and a
8 crusher forklift is used to perform an initial breakup of
9 the ice. The workers on the platform that you see in the
10 slide then begin the process of breaking the ice into
11 smaller chunks to feed into a pulverizer-crusher.
12 The ice then travels by auger and by blowers to
13 the ice condensers, during which time it is conditioned with
14 refrigerated air. This conditioning minimizes moisture
15 intrusion into the ice condenser, limiting frost
16 accumulation and sublimation of the ice.
17 The next slide shows the actual loading of the ice
18 into the ice condenser baskets.
19 The ice piping from the blowers is connected to a
20 cyclone separator in the ice condenser. The cyclone
21 separates the forced refrigerated air from the ice itself
22 and then the ice then falls into the baskets. The green air
23 flow passage bags that you see in the slide are installed
24 prior to the ice being loaded in order to limit the amount
25 of ice which falls out of the baskets.
23
1 Reviewing some of the numbers. There are 1,944
2 ice baskets in the condenser, and each basket is
3 approximately 12 inches in diameter and 48 feet long.
4 Technical specifications require a total ice weight of
5 2,590,000 pounds and we expect to loan about 3 million
6 pounds in the Unit 2 ice condenser. At the present time we
7 have loaded half of the Unit 2 ice condenser and are just
8 initiating the process of weighing the first baskets.
9 Reloading ice is a major milestone for the people
10 at D.C. Cook. I hope the short overview I just provided
11 with you of the ice load helps you appreciate that we have
12 not only accomplished a great deal in discovering and
13 resolving issues, but we have made significant progress in
14 restoring the physical plant since I last spoke to the
15 Commission in November of 1998. True to our key management
16 expectations, we are doing what we said we would do.
17 Let me quickly summarize the key points of my
18 opening remarks. The picture that best describes where we
19 are today is that we know what our problems are. We have
20 identified the necessary corrective actions and we are
21 nearing completion of our restart efforts. Frankly, where
22 we are now feels more and more like a refueling outage.
23 What faces us in the near term is simply to complete the
24 remaining work with quality and with safety.
25 For the longer term, we intend to continue to
24
1 focus on the fundamentals. As we improve there, our
2 leadership team will turn more attention to the challenges
3 of deregulation, license renewal and more efficient
4 operating cycles.
5 With this overview, let me turn the presentation
6 over to Mike Rencheck.
7 MR. RENCHECK: Thank you, Bob. As Bob indicated,
8 you can categorize areas, our areas of focus into plant,
9 processes and people. Today I am going to concentrate on
10 how we set about identifying our issues and some of the
11 results that we have achieved.
12 One of the first things that I did when I came to
13 Cook was to establish a solid processing -- process for
14 discovering our problems, and I did that by utilizing
15 processes that I had found effective in the past.
16 The next slide shows the key elements of this
17 process. Discovery was the first of four phases in our
18 restart process. Discovery was designed to identify
19 problems that could adversely affect the safe and reliable
20 operation of the Cook units. It contained the following
21 attributes to ensure that problems were thoroughly evaluated
22 consistent with their safety importance.
23 As the first bullet on the slide indicates,
24 discovery was an industry-proven process used in the
25 recovery and restart of other nuclear plants. It is
25
1 described in our restart plan and has been implemented
2 through formal procedures.
3 Second, discovery utilized personnel with the
4 broad-based experience in the recovery and restart of
5 nuclear units, combined with Cook experienced personnel. We
6 also used industry peer reviews and visited other nuclear
7 utilities to ensure that lessons learned were incorporated
8 into our process.
9 Third, discovery applied comprehensive and
10 intrusive methods, and we did this through three principal
11 efforts. One of these was our expanded system readiness
12 reviews. These reviews provided a detailed and disciplined
13 assessment of essentially all safety and risk-significant
14 systems. Non-risk-significant systems were also reviewed
15 but to a lesser degree. We also conducted programmatic
16 assessments that were designed to evaluate whether processes
17 critical to restart were in place and functioning properly.
18 125 per REM baseline assessments were performed. This
19 resulted in 94 detailed self-assessments of the programs
20 being conducted.
21 The last effort involved our functional area
22 assessments, which included 18 departmental reviews. These
23 reviews were conducted to determine whether department
24 practices, as well as personnel and management capabilities
25 were adequate to support start-up and safe plant operation.
26
1 The fourth bullet on the slide focuses on our
2 corrective action program. Early in our discovery process,
3 we completely revamped our corrective action program to make
4 it consistent with other well-designed industry processes.
5 We utilized our new program to document, understand the
6 extent of condition, and then to promptly fix the identified
7 problems that came out of discovery.
8 Finally, we subjected our discovery effort, scope,
9 approach, results and proposed corrective actions to a
10 demanding oversight by our various oversight groups such as
11 our System Readiness Review Board and our Plant Operations
12 Review Committee. These efforts were also audited and
13 assessed in detail by our performance assurance department.
14 We believe that our discovery process utilized
15 industry best practices, techniques, and experienced people
16 to assure rigorous and comprehensive evaluation of the
17 problems at D.C. Cook.
18 Let me now discuss what we found. As the left
19 side of this slide indicates, our discovery efforts
20 identified issues in three areas -- people issues, process
21 issues and plant issues. In the area of people issues, the
22 problems generally included an organization that had become
23 insular in its approach to change. This resulted in the
24 inability to raise standards and keep pace with industry
25 changes, to consistently identify conditions adverse to
27
1 quality, determine root causes and implement corrective
2 actions in a timely manner, to adequately train and qualify
3 personnel in important areas such as our design and
4 licensing basis, and, finally, to effectively establish,
5 communicate and implement standards and management
6 expectations.
7 Regarding process issues, a number of our
8 processes had become deficient and ineffective, resulting in
9 problems such as inconsistent design control, inadequate
10 safety evaluations, inadequate operability determinations,
11 deficient post-maintenance and post-modification testing,
12 and insufficient work management programs and associated
13 processes.
14 Many of the plant or technical issues arose from
15 the process issues I just mentioned. This generally
16 resulted in eroded safety margins, missing documentation and
17 inoperable plant equipment. Some specific examples include
18 missing or deficient design documentation, deficiencies in
19 the areas of material condition, for example, our ice
20 condensers, deficiencies in the design of some systems or
21 components, examples are motor-operated valves.
22 Throughout the discovery effort, issues were
23 documented in our corrective action program. The issues
24 were categorized as restart or post-restart required using
25 an industry-proven screen criteria. Management then
28
1 analyzed the restart issues and developed a list of
2 approximately 40 items that required additional management
3 attention due to their potential safety significance. To
4 date, we have been resolving these issues and have found
5 that several have had some safety significance, namely, our
6 ice condensers, our high energy line break program, and our
7 motor-operated valves. Although we have determined how to
8 solve these issues, we are continuing in our efforts to do
9 so.
10 In summary, these issues generally represent the
11 fundamental reasons for our shutdown. Our processes and
12 people skills, fundamental to sound engineering practices,
13 were ineffective. Alignment among our license, our design
14 basis documentation and the plant's hardware in some
15 instances was at best unknown, and, at worst, varied
16 substantially.
17 Clearly, we faced a significant challenge at Cook.
18 However, let me give you some perspective on this challenge.
19 Cook represents the third recovery effort that I have been
20 associated with. In general, the problems at Cook are not
21 unique. With the possible exception of the ice condenser
22 and the extent of our documentation deficiencies, the
23 problems at Cook have been seen throughout the industry in
24 one form or another.
25 We have been utilizing industry-proven corrective
29
1 actions to address many of our identified problems. I have
2 personal experience with many of these such as our expanded
3 system readiness review, resolution of our high energy line
4 break issues and other industry operating experience, and,
5 therefore, I have confidence in their effectiveness.
6 The right side of the slide identifies the
7 corrective action focus areas we used to reestablish and
8 strengthen our engineering capabilities. In the engineering
9 department, we specifically focused on the capabilities of
10 our people, that is, their skills and knowledge, and the
11 processes we use to do our work.
12 First, we had to assure that our management and
13 oversight were sound. To accomplish this, we hired several
14 new management individuals that understood the need for
15 setting high expectations and following through with
16 coaching and direction of both our AEP employees and the
17 contractors that we were utilizing.
18 We understand that the level of engineering
19 performance is directly proportional to the knowledge and
20 skills possessed by our personnel, as well as the quality of
21 the supporting training program. In this regard, we
22 conducted an assessment of personnel competence. Two areas
23 were considered, engineering judgment and problem-solving
24 knowledge. The assessment indicated that engineering
25 judgment was adequate, but problem-solving skills needed
30
1 enhancement.
2 Our assessment also found that many engineers
3 lacked the full understanding of configuration control,
4 design and licensing basis, safety evaluations and
5 operability. Consequently, we initiated a comprehensive
6 remedial training program. In some cases all engineering
7 personnel, including contractors received the training. In
8 other cases, we targeted training to a specific engineering
9 group.
10 I will give you an example. The population of AEP
11 and contractor personnel received training in management
12 expectations, responsibilities, safety focus, conservative
13 decision-making, design and licensing basis, operability
14 determination, 10 CFR 50.59 safety evaluation fundamentals,
15 configuration management, design control, calculations and
16 the development of solutions. And some of the specific
17 targeted training was applied to AEP engineering personnel
18 in areas such as effective problem-solving and human error
19 reduction techniques.
20 An 80 percent passing score was required on tests,
21 and when personnel did not achieve this grade, remediation
22 training was performed. Academic review boards were also
23 conducted for those personnel not meeting standards.
24 We have since performed several follow-up
25 assessments to evaluate the effectiveness of our efforts.
31
1 Based on the quality of work products and root cause
2 analyses, engineering personnel are showing an overall
3 improvement such as an increased understanding of the design
4 and licensing basis, and they are demonstrating a greater
5 questioning attitude toward their work.
6 For the longer term, to ensure that improvements
7 seen to date are maintained and increased, we have revamped
8 our engineering support personnel training program. The
9 program includes establishing position-specific guides for
10 engineering personnel to achieve and then maintain their
11 qualifications.
12 In summary, we are challenging our people to meet
13 higher standards. We believe this focus will help us reach
14 our goal of excellence in the future.
15 Now, in addition to the skills and knowledge
16 training, we have also been improving our practices and
17 procedures used by our people. As part of the programmatic
18 assessment effort that I mentioned earlier, engineering
19 processes and programs were thoroughly evaluated.
20 For example, we performed detailed reviews
21 involving safety evaluations, design control, engineering
22 calculations, the design change process and configuration
23 management. And not only the programs, we also took a look
24 at the documentation associated with these programs such as
25 our updated Final Safety Analysis Report, our calculations
32
1 and our safety evaluations.
2 Issues identified for corrective action during
3 these reviews were documented as condition reports in our
4 corrective action program for disposition. Some of the
5 corrective actions we took in response to these reviews
6 included incorporating best industry practices into our
7 programs, establishing the design engineering organization
8 as the design authority, developing a station-wide
9 configuration management policy and associated procedures,
10 and completing a comprehensive revision of our design
11 control processes, and, last, establishing oversight of our
12 engineering products through our engineering effectiveness
13 department and formal review committees such as our Design
14 Review Board.
15 In summary, we have improved our skills, practices
16 and procedures, and I am seeing the results from our
17 efforts. The documentation for our design and licensing
18 basis is being rebaselined were appropriate. Approximately
19 190 modifications are being installed at D.C. Cook to
20 improve the safety and reliability of our plant.
21 Our performance indicators such as root cause
22 quality, safety evaluation quality and calculation quality
23 also show me that we are on an improving trend and meeting
24 management expectations for restart.
25 These next two slides illustrate our performance
33
1 in these two areas. This slide shows the percentage of
2 acceptance by the Plant Operations Review Committee for
3 50.59 safety screenings and evaluations going back to
4 February of last year. This team set high standards and, as
5 you can see, back in February of last year, 50.59 screens
6 were being rejected and sent back for further analysis.
7 This ultimately resulted in higher quality evaluations that
8 are consistently meeting our expectations today.
9 Another key indicator that directly relates to our
10 corrective action program and the ability of the
11 organization to find problems and develop effective
12 corrective actions is the quality of our root causes. This
13 next slide shows our most recent performance. The quality
14 of our root cause evaluations is measured by the corrective
15 actions department and is scored using a variety of factors
16 such as safety significance, did we achieve the root cause,
17 and extent of condition. These factors are weighted into a
18 composite score that is applied against a management
19 standard or a goal. Although we expect the quality to
20 continue to increase in the future, root cause evaluations
21 are meeting management's higher expectations and are on a
22 generally improving trend.
23 The improvements in these and other fundamental
24 areas, along with the new processes, and the development of
25 design changes, the control of documentation, and
34
1 configuration management, among others, have resulted in
2 rebaselining our design and license basis documentation and
3 plant modifications, where appropriate. This provides us
4 with reasonable assurance and gives us a sound foundation
5 for safe and reliable plant operation.
6 These improvements also indicate the beginning of
7 a longer term cultural change in the engineering department.
8 With our continued leadership and oversight with the safety
9 first focus, we will not repeat past mistakes.
10 I am encouraged with our progress, however, our
11 work in the engineering department is not complete. We
12 still have challenges ahead and I would like to highlight
13 these for you in the next slide.
14 Although the current quality of our engineering
15 products, such as design change packages and safety
16 evaluations are at an acceptable level for restart, we must
17 continue to improve. Our improvements must reduce our
18 reliance on multiple review processes and increase our
19 engineers' knowledge and skills. Our goal is for the
20 engineers to produce products that continually meet our
21 higher standards. This will be achieved in part by
22 enhancing our organizational capabilities, and we will do
23 this through our training programs, and through the use of
24 personnel performance techniques such as human error
25 reduction and performance assessments.
35
1 Another focus area is on contractor reliance.
2 During this restart period, we have relied heavily on
3 outside help. These contracts have been under the
4 management and direction of AEP employees doing this effort
5 and we appreciate their contributions. Quite frankly, we
6 could not have tackled this restart effort without them.
7 Having said that, however, we must now continue reducing our
8 reliance on them to ensure that we have the internal
9 knowledge and capabilities for the longer term journey to
10 excellence.
11 Finally, we recognize that to be successful, the
12 D.C. Cook Station must be an operations-led organization.
13 Engineering, of course, plays a critical part in supporting
14 the safe and reliable operation of the units. We have
15 substantially improved, but we must continue to improve the
16 quality and timeliness of our products delivered to
17 operations.
18 These are the challenges ahead for the engineering
19 department. I would now like to turn the presentation over
20 to Chris Bakken.
21 MR. BAKKEN: Thank you, Mike. To pick up on Bob's
22 earlier discussion of desired behaviors, we believe that
23 being self-critical and developing sound corrective actions
24 requires that we focus on effective oversight. At Cook, we
25 believe that oversight is fundamental to the success of our
36
1 restart work, as well as to our long-term goals.
2 Oversight is a broad concept and involves
3 activities such as monitoring, assessing, coaching and
4 providing feedback. It is demonstrated by individual
5 behavior, as well as through structured processes and
6 programs.
7 On an individual basis, Joe, Mike and I all
8 incorporate oversight into our everyday activities. For
9 example, during daily team meetings, we carefully evaluate
10 the information provided by our staffs. We provide feedback
11 and we encourage people to take a broader view of problems,
12 and to voice their opinions. We believe that this approach
13 promotes openness and better teamwork, and it also results
14 in more comprehensive solutions.
15 This example shows you how we provide oversight on
16 a personal level. But oversight is also built into our
17 restart plan as a structured process. As the next slide
18 shows, our restart effort was designed to provide several
19 layers of oversight. This slide was first shown to the NRC
20 staff during an 0350 meeting last fall. This slide breaks
21 our restart process down into three basis parts, discovery,
22 implementation, and verification, which then lead to restart
23 of the units through the final phase, start-up and power
24 ascension, which is not shown on this slide.
25 The boxes are color-coded with blue representing
37
1 work activities, yellow representing assessment and
2 oversight activities, and green representing approval or
3 concurrence of successfully completed activities. The slide
4 highlights the yellow boxes. As you can see, oversight, in
5 one form or another, occurs in each major step of our
6 restart process.
7 We did not move from discovery without an
8 evaluation of the effectiveness of our efforts to identify
9 problems. A third party panel of experts, the System
10 Readiness Review Board, or SRRB, principally performed this
11 evaluation. As we move towards the completion of our
12 implementation efforts, you can see that, once again, we are
13 using oversight as an important element of our process.
14 Again, SRRB, along with our Plant Operations Review
15 Committee, is providing oversight.
16 In our final phase of the restart, we again will
17 be utilizing several oversight reviews. This consists
18 mainly of department self-assessments and final affirmation
19 reviews by senior management and the Plant Operations Review
20 Committee.
21 Throughout the entire restart process, oversight
22 is also provided by quality assurance. As your staff has
23 noted during several inspections, quality assurance has
24 provided intrusive and insightful review of our restart
25 activities. Line management now sees the benefit of these
38
1 insights and is actively seeking quality assurance's
2 feedback.
3 We believe the structured use of oversight, along
4 with our personal efforts to oversee activities at the site,
5 has ensured that we are doing a quality job. It is a major
6 reason why we have confidence in the effectiveness of our
7 efforts to date.
8 Two other major reasons why we have this
9 confidence is that our discovery effort was thorough and
10 comprehensive, and we are being successful in our transition
11 from an engineering-led organization to an operations-led
12 organization. This next slide illustrates this transition.
13 As mentioned earlier, our restart plan began with
14 the discovery phase. This intensive and time-consuming
15 effort was headed up by engineering for several reasons.
16 First, many of the problems at Cook were centered on design
17 and license basis issues, as well as technical issues.
18 Second, Mike Rencheck had extensive personal experience in
19 leading such an effort.
20 The left side of this slide identifies the key
21 activities performed under Mike's direction. In addition to
22 discovering our problems, Mike and his organization were
23 responsible for developing the solutions to our problems, as
24 well as reestablishing the safety margins and the design
25 bases of our plant and processes.
39
1 Through these efforts, we also began the process
2 of changing the culture of all of our people. Together,
3 these activities have helped ready us for the transition to
4 power operations. In particular, they have given us
5 confidence that when our plant modifications are complete,
6 the operators will have safe and reliable plant equipment,
7 as well as effective procedures. These activities have also
8 provided momentum for our longer term journey to excellence.
9 As we move through this transition period, I can
10 tell you as an operator myself, that the operations
11 organization is anxious to resume control of the plant.
12 Since my arrival in the spring of 1999, I have been hard at
13 work with my organization to reshape the culture among our
14 staff.
15 As the right side of the slide indicates, I
16 believe there are four fundamentals that define an
17 operations-led organization. First and foremost, the
18 operations organization is responsible for operating the
19 plant in a safe and reliable manner. In order to do this,
20 the operators must be trained, maintain their qualifications
21 and be knowledgeable of their license responsibilities.
22 Second, an operations-led organization must be a
23 competent and demanding customer. The proper maintenance of
24 the plant and the processes are critical to an operator's
25 job. This means that operators must work well with
40
1 engineering, maintenance and other support organizations to
2 assure that plant and processes are well maintained.
3 However, the operators must also hold those responsible for
4 maintenance accountable, both in terms of their product and
5 their services. Without quality services and products, the
6 operators are more likely to be unnecessarily challenged in
7 the form of equipment failures or malfunctions.
8 Third, an operations-led organization must be
9 constantly assessing itself and those supporting it. Unless
10 an organization is self-critical, it cannot be assured of
11 growth or continuous improvement.
12 Finally, as the leader of plant operations, the
13 operations department must be among the first to demonstrate
14 the behaviors embodied in the management expectations that
15 Bob discussed earlier.
16 We are well into our transition to an operations-
17 led organization. This has involved instilling higher
18 standards, reshaping the leadership within my various
19 organizations and improving our work processes. To help us
20 complete our transition, we in operations have been
21 concentrating on improving our skills and capabilities. We
22 also have been focusing on enhancing the processes we rely
23 upon to do our jobs.
24 MR. BAKKEN: We have accomplished a great deal
25 over the past year. However, since our time is limited, I
41
1 will only highlight some of the activities that are
2 preparing us to return the power operation.
3 First, let me talk about operator training. We
4 believe that a strong training program is key to our long-
5 term success.
6 In October of 1998, our training programs for
7 operations were placed on probation by NPO. We gave this
8 training program top priority, and in April of 1999, we
9 achieved accreditation renewal of the operations training
10 programs.
11 Subsequent NRC inspections have also noted our
12 training improvements. Concerning operational skills, one
13 area we've been focusing on is human error reduction.
14 We have established human performance goals, and
15 we trimmed the performance of each crew. We utilized this
16 information in our training program and during periodic crew
17 briefings.
18 We have provided our operators with a variety of
19 training opportunities on this subject. For example,
20 operators have attended a human errors reduction training
21 course, they have attended the NPO Team-building Workshop.
22 They have participated in our shift manager mentoring
23 program, and they have participated in our Hop Hallet Crew
24 Training.
25 For those of you not familiar with Mr. Hallet,
42
1 he's the author of the Industrial Operators Handbook, and is
2 a recognized authority on individual and crew human
3 performance.
4 Because human error reduction is such an important
5 element of our long-term success, we recently hired a site
6 human performance manager. Although her efforts are
7 directed to all of our organizations, I have specifically
8 asked her to focus her near-term efforts on error reduction
9 within operations and maintenance departments.
10 We have also focused on the ability of our staff
11 to perform effect root-cause analysis. Training courses
12 have been provided, and this has increased the number of
13 operations staff members who are now qualified root-cause
14 investigators.
15 In-field operations by operations management have
16 been increased. The expectation is to provide oversight of
17 the actual work at the job site, providing support and/or
18 coaching where necessary.
19 Peer checking has been incorporated into the day-
20 to-day conduct of the operations staff, and more time is
21 being devoted to interfaces between managers and their
22 crews, as well as between the Operations and the Quality
23 Assurance Departments.
24 An operations-led organization cannot stand on its
25 own. It is supported by Engineering, which Mike has spoken
43
1 of earlier, as well as other organizations such as
2 Maintenance.
3 I want to briefly mention what we have
4 accomplished in our Maintenance Department: We continue to
5 focus on augmenting our staffing ranks. Over the past
6 several months, we have nearly doubled the permanent AEP
7 staffing levels in supervision and craft available for plant
8 maintenance.
9 At the same time, we continue to reduce our
10 reliance on contractors. While we need contractor support
11 to help us complete the work on Unit II, and for the restart
12 of Unit I, it is my intent to carefully eliminate the
13 majority of our contractors by the end of this year.
14 Another area of continuing focus in maintenance is
15 training. The plans we are currently developing will
16 achieve sufficient skills and qualifications in mechanical,
17 electrical, and instrumentation and controls, to support the
18 contractor reductions at the conclusion of the Unit I
19 restart.
20 I'd like to also mention that the health of our
21 maintenance training programs and instructional staff were
22 reviewed in November of last year by an NPO accreditation
23 team. I believe these programs will receive accreditation
24 renewal in March of this year.
25 The last area I will talk about concerns a few of
44
1 the processes that we have upgraded that are key to safe
2 operations. One of these involves operability
3 determinations under Generic Letter 91-18.
4 We revised the governing procedure to provide
5 better guidance to personnel when performing these
6 determinations. We provided training on those procedural
7 changes.
8 We established the Operations Department as the
9 clear owner of the program. We also implemented, on a
10 temporary basis, a shift operating review team, and on a
11 long-term basis, a cross functional event screening
12 committee, both of which are designed to reduce the burden
13 on the control of operators for reviewing Condition Reports
14 and performing prompt operability determinations.
15 These were some of the measures we put in place to
16 handle the large volume of issues encountered during our
17 discovery efforts.
18 In addition, as part of our new electronic
19 corrective action reporting system, we enhanced the data
20 available to the operators. The data screens now include
21 information on operability, reportability, and mode
22 constraint requirements.
23 The other process I would like to briefly discuss
24 is our emergency operating procedures or EOPs. Early in our
25 restart effort, we recognized that our EOPs needed to be
45
1 substantially revised.
2 We have largely completed this effort, bringing
3 them up to current industry standards. At this time, the
4 procedures themselves have been fully revised. Review and
5 approval by our Plant Operating Review Committee is
6 complete.
7 Now, operators are currently being trained on the
8 new procedures in the simulator. As you can see on this
9 slide, on this important area, we've made steady progress,
10 and, in general, adhered to our schedule, and completed this
11 effort last Friday, not in time to update the slides.
12 I have only highlighted some of the many
13 initiatives that we have implemented to help us transition
14 to an operations-led organization.
15 We have made tremendous progress, and overall, I
16 believe we are demonstrating an improving trend. Of course,
17 as in any restart situation, the startup and testing phase
18 is where everything comes together, and where the quality of
19 our efforts can be measured.
20 If you will turn to the next slide, I would like
21 to discuss our restart and power ascension testing program.
22 As we complete the implementation phase of our
23 restart efforts, the Operations Department is resuming
24 control of the plant systems through the system turnover
25 process.
46
1 To date, 17 of 86 systems have been turned over to
2 Operations. This means that the systems have been tested,
3 as allowed by current plant conditions, and Operations has
4 found that they meet their standards for safety and
5 reliability. This turnover process is an initial step in
6 the startup and power ascension program.
7 I would like to point out that from the beginning
8 of this discussion, that the modifications that are being
9 performed on the Cook Units are limited in scope and, in
10 general, are not significantly changing any of the
11 operational capabilities of the plant.
12 This is unlike other restart efforts. As an
13 example of what I'm referring to, during the Salem restart,
14 we installed a digital feedwater control system, and rebuilt
15 the entire process control system to improve the plant's
16 capabilities.
17 This required extensive testing such as several
18 load rejection tests to confirm its effectiveness. In
19 general, the modifications at Cook involve equipment
20 compliance upgrades, such as the motor-operated valve and
21 high-energy line break work.
22 We are not installing modifications that will
23 cause the plant to respond significantly differently from
24 when it was shut down, and, therefore, the testing programs
25 are much more modest in scope.
47
1 With the turnover of systems complete, and
2 concurrence of AEP management and the NRC, we will take the
3 reactor critical and ultimately proceed to 100-percent
4 power. This chain of events will be under the control of
5 the Operations Department, utilizing what we call a Startup
6 and Power Ascension Program.
7 Before I describe the program itself, I would like
8 to discuss its basis priorities. mplementing these
9 priorities is essential to achieving an event-free restart
10 of the plant.
11 Safety is our top priority during this critical
12 phase of restarting the units. We are committed to
13 proceeding only in a controlled and deliberate manner. By
14 control, I mean that the startup is conducted by a strong,
15 operations-led organization with full responsibility to
16 direct actions and events safely at all times.
17 By deliberate, I mean that we will have a high
18 degree of certainty, that is, the outcome of next actions
19 are well known, are safe, and are in accordance with our
20 overall plans.
21 If we have a problem, we will stop, assess, and
22 implement appropriate corrective actions before proceeding.
23 As to the program itself, we have a plan document
24 that is the Startup and Power Ascension Testing Program
25 Procedure. This procedure describes the key steps in our
48
1 program, and has been reviewed by the System Readiness
2 Review Board.
3 The program is divided into four phases:
4 Component testing, system testing, integral functional
5 testing, and power ascension testing. This building-block
6 approach assures that the plant equipment, both
7 independently and as an integrated system, can be relied
8 upon to perform its intended function.
9 The program itself is nearly identical to the one
10 used during the Salem restart. System test plans have been
11 developed in accordance with the scope of the work performed
12 during this outage.
13 The plans are owned by the system manager, and are
14 thoroughly reviewed by a system engineering supervisor, an
15 operations senior reactor operator, and a test review board.
16 Plans are updated as necessary on a continuing basis.
17 As we execute our plan and perform the various
18 tests, there will be oversight on-shift to assure that
19 proper expertise and management attention is available to
20 address both routine and emergent situations.
21 The around-the-clock oversight includes a shift
22 plant manager, a shift engineering manager, and a shift test
23 engineer.
24 As startup proceeds, the test results will be
25 reviewed by the Test Review Board to ensure that the test
49
1 achieved its intended function, and that the results meet
2 the defined acceptance criteria.
3 We anticipate that we will face some emerging
4 issues as we proceed with the startup and testing. But as I
5 have previously stated, we have skilled individuals and
6 processes to resolve problems as they emerge.
7 Once again, the Cook organization is committed to
8 restarting the plant in a safe, controlled, and deliberate
9 manner. It is only by doing so that we can have an adequate
10 level of assurance that the restart will meet our goal of
11 being even-free.
12 There are two final topics I would like to cover
13 briefly: First, if you will turn to the next slide, I want
14 to go over where we are from a schedule standpoint.
15 This slides shows the total person-hours that we
16 have expended, and, more importantly, the black line shows
17 the person-hours remaining to be completed.
18 As you can see, the lines have crossed, which
19 means that we are well past the halfway point of the outage
20 work. Additionally, little emergent work is being added,
21 which means that if we do what is scheduled and do it on
22 time, we should be close to our scheduled completion date of
23 April 1st for Unit II.
24 I want to again point out that challenges
25 occasionally do arise, and we will take the time to do the
50
1 job right. If called for, we will not hesitate to stop
2 work, reassess, and assure safety and quality are met before
3 resuming our work.
4 The final topic I would like to discuss concerns
5 the focus areas that I see ahead for my organization, which
6 I have listed on the next slide.
7 The first focus area is to ensure that the restart
8 and operation of Unit II is not affected by the continuing
9 outage efforts on Unit I. To accomplish this, we are
10 dedicating portions of our staff to these separate
11 activities.
12 Specifically, the Unit II staff will focus on the
13 critical functions of reactor restart, testing, and power
14 ascension activities.
15 The Unit I staff will focus on the ongoing steam
16 generator replacement and completion of the Unit I outage.
17 The shift plant manager and operations shift
18 manager have overall responsibility for both plants, and
19 they have both the resources and guidance from senior
20 management to assure both the event-free restart and
21 operation of Unit II and the adequate control of work at
22 Unit I.
23 I can assure you that I fully understand the
24 demands that will be placed on these crews. The situation
25 is very similar to when I was at Salem, including the steam
51
1 generator replacement.
2 We were successful at Salem, and are employing the
3 same techniques here to ensure success at Cook.
4 In the area of human performance, I spoke about
5 this previously, and as I indicated, our long-term success
6 will greatly depend on the efforts in this area. It is my
7 intention to initiate a sitewide human performance strategy
8 consistent with the best-performing plants in the industry
9 to continue our improvements in this area.
10 In addition, we continue to be committed to an
11 open environment for personnel to raise concerns. As with
12 other restart situations, we have and will continue to face
13 some issues in this area.
14 To date, however, I believe that we have been
15 successful in addressing these matters. We significantly
16 upgraded our Employee Concerns Program last year, and we
17 have conducted training for supervisors and employees on how
18 to maintain an effective, safety-conscious work environment.
19 These efforts, combined with our upgraded
20 corrective action program, provide a multifaceted approach
21 to assure a healthy work environment at Cook.
22 The third focus area is control of work. During
23 an outage such as this one, our goal is to control work in a
24 systematic and deliberate manner. This is critical to our
25 safety-first fundamental, and is the ultimate responsibility
52
1 of the Operations Department.
2 Operators and management are taking control of the
3 day-to-day activities, and ensuring that they do not let
4 situations control them, minimizing challenges to the
5 control room. This is consistent with our top priority of
6 safety first.
7 The fourth focus area is our backlogs. These are
8 being monitored and evaluated to assure minimal impact on
9 plant operations. This effort is from both an individual,
10 as well as an aggregate effect point of view.
11 Only those items that management believes can be
12 safely deferred to online maintenance or the next outage
13 will be moved past restart.
14 Obviously there is still work ahead of us, and as
15 we proceed, there will be emerging issues that the
16 organization must address. However, we are ready for them.
17 As the site Vice President, I'm committed to
18 stopping and assessing when necessary, and proceeding only
19 when we have the confidence that we can do so safely.
20 We will use our new skills effectively, exhibit a
21 questioning attitude, and demand quality from ourselves and
22 others to assure safe and reliable operations.
23 This concludes my part of the presentation. Bob?
24 MR. POWERS: Thanks, Chris. I'll take just a few
25 minutes to wrap up what we presented today, and give you a
53
1 brief sense of where I see us heading for the future.
2 Could I have the next slide, please? This slide
3 captures the key points that we'd like to leave you with
4 today.
5 During the restart process, we have learned some
6 key lessons: First, we understand the aspects of our past
7 performance that contributed to the shutdown of the Units.
8 The discovery process and the associated results
9 have caused all of us at Cook to reflect on where we were
10 two years ago, and we've made a commitment not to repeat the
11 past.
12 We've learned how to find and how to fix our
13 problems. We now have the disciplined processes and the
14 questioning attitude to assure that root causes are
15 effectively identified, and that corrective actions are
16 effectively implemented.
17 We've learned that it takes a sound plan to
18 achieve our goals. Our restart plan has provided the
19 necessary guidance and flexibility to both address our
20 initial problems and to make the necessary adjustments as
21 emerging issues reveal themselves.
22 As most of you recall, I spoke to the Commission
23 in November of 1998. I described my vision for world class
24 performance and how we would go about achieving it.
25 We developed a comprehensive restart plan, and we
54
1 are doing what we said we would do; we are nearing
2 completion. We believe the restart of Unit II is in sight,
3 and should occur in the Spring of this year.
4 Unit I should follow in the Fall, with its steam
5 generators replaced as well.
6 We have learned that even with good planning,
7 we'll have challenges ahead. Not everything is going to go
8 smoothly, but we have developed the skills to effectively
9 address emergent problems.
10 Thee is more work to be done with our people and
11 processes to reach our goals. However, we do know how to
12 evaluate these challenges and plan for their resolution.
13 Most of all, we've learned not to rush the work of
14 restart. We have and will stop work when necessary to
15 reinforce our higher expectations and achieve the results of
16 doing the job right the first time.
17 Our efforts in terms of time and resources,
18 especially over the past 12 months, have been both difficult
19 and enlightening, but there are definite rewards.
20 They are manifested in a more robust plant that
21 will respond properly when called upon by our operators.
22 They also show up in changes to our culture and processes
23 which are grounded in our higher management expectations.
24 Through our restart efforts, we've built a
25 foundation based on four fundamentals: A safety-first
55
1 culture, capable leadership, self-critical organizations
2 supported by an effective corrective action program, and
3 trained, well-prepared people.
4 These foundational elements are allowing us to
5 build the infrastructure that will support world class
6 performance. They are also helping us as an organization to
7 modify behaviors and make a fundamental change in our
8 culture.
9 Those changes include improvement in our
10 questioning attitude, accountability, teamwork, and
11 ownership.
12 As I mentioned, we are seeing signs of changes in
13 these areas, but we still have a ways to go. With continued
14 attention to our management expectations, we will achieve
15 our goal of safe, reliable, and event-free operation and
16 ultimately world class performance.
17 On behalf of all of us at Cook, I want to thank
18 you for the opportunity to address the Commission today, and
19 this concludes our formal presentation.
20 CHAIRMAN MESERVE: Good. Thank you very much.
21 I'd like to express my appreciation to all of you for what
22 was really a remarkably candid appraisal of the situation
23 that you have confronted. It's clear that you made very
24 aggressive efforts to deal with the situation.
25 Could you say something about the work that
56
1 remains to be completed? You indicated that the ice
2 condenser was about half filled, and so what other things of
3 major significance are before you, before you're ready to
4 commence the restart?
5 MR. POWERS: There are about 200,000 hours of
6 physical work remaining in the outage. Half the ice
7 condenser remains to be filled.
8 That work involves refurbishment of approximately
9 80 or 90 of our motor-operated valves. It includes the
10 physical work to implement the 190 some odd design changes,
11 although some are complete and underway.
12 There are some of the design changes that remain
13 to be resolved. And it involves the work associated with
14 our system turnover windows, where we've gone through and
15 taken a comprehensive scrub of the corrective action
16 documents that have been identified on each system, and any
17 physical work that needs to be done in terms of maintenance,
18 repair, it includes that as well.
19 There is attendant work that is not showing up in
20 that 200,00 man-hours, and that would be some paperwork
21 issues, analytical work, closure work that's associated
22 principally in the engineering and supporting organization.
23 I think that gives you a pretty good assessment on
24 what remains to be done.
25 COMMISSIONER MERRIFIELD: Mr. Chairman, I have
57
1 just a clarifying question, if I can?
2 What's the split between Unit II and Unit I in
3 that 200,000 hours?
4 MR. BAKKEN: That doesn't account for Unit I.
5 COMMISSIONER MERRIFIELD: That's only for Unit II?
6 MR. BAKKEN: Yes, we're treating Unit I as a
7 separate entity, and really the only substantive work that's
8 going on now in Unit I is steam generator placement, because
9 we don't want to distract the organization on Unit II.
10 That project will go through the end of March, and
11 that point then we'll make an assessment, depending on the
12 condition of Unit II, on what work we then pick up and do on
13 Unit I. And we'll look at that very carefully to make sure
14 they don't adversely impact each other. Clearly, Unit II
15 will take precedence.
16 MR. POWERS: The 200 man-hours of work represents
17 about eight weeks worth of work at the rate we are working
18 it down. I think this outage is going to be time-dependent,
19 both on our continued ability to work that 200,000 man-
20 hours down, but it's also become like a refueling outage, a
21 process of appropriately managing the critical path
22 activities where certain key lead items, whether it be
23 associated with the design or the procurement of parts,
24 really will determine the ultimate length of the outage.
25 COMMISSIONER DICUS: Okay, I have a couple of
58
1 quick questions, if I could. One of them is on what you
2 just said, the critical path issues.
3 To what extent is the NRC -- I mean, where are we
4 in the critical path? Is there something that you need from
5 us?
6 MR. POWERS: No, Commissioner. The support from
7 the staff has included critical questioning; it's included a
8 thorough review. But the from the standpoint of support of
9 the project, that questioning and review has been timely.
10 It's been scheduled to support our restart activities.
11 The licensing support, again, has involved
12 critical questioning, tough standards, high standards, but
13 the license products for the Cook Unit II restart are coming
14 at a pace that will support the schedule, and I don't -- in
15 any of my internal documents, I don't see the words, NRC in
16 terms of critical path between us and getting the Units
17 restarted.
18 COMMISSIONER DICUS: And then my second question
19 is going to go to the issue of the new reactor oversight
20 program that we're going to implement later on this year.
21 The first part of this question is probably
22 somewhat philosophical, and you can get into it if you like,
23 or if you want to defer, that's okay, too.
24 But if we had had the new oversight process in
25 place a year or two or three or four ago, would it have
59
1 given you a greater signal early on that you had problems at
2 D.C. Cook, and that those problems needed to be addressed?
3 Would it have given you a heads-up on that? That's the
4 philosophical part of that question.
5 But the second part of it, in light of the fact
6 that we are going to a new oversight process program, in the
7 activities that you have ongoing, which you have so
8 carefully and thoroughly reviewed for us, have you
9 incorporated this new oversight process in your thinking, in
10 your going forward, as you said on some of your slides, to
11 look at and to operate the plant under a new oversight
12 process, such as it is.
13 And I guess the third part of the question is, are
14 you ready to go under a new oversight process?
15 MR. POWERS: Okay, there are three parts to the
16 question.
17 COMMISSIONER DICUS: Yes. It's a three-part
18 question.
19 MR. POWERS: Let me philosophize first. Going
20 forward, I think the NRC has developed a good oversight
21 process for the nuclear industry. I do believe, if I can
22 answer the question by way of looking forward first, then
23 I'll go back in time, we will have a sound corrective action
24 program.
25 In the conduct of that corrective action program,
60
1 we will identify issues, and they will be scrubbed for their
2 safety significance. This will be a key element and a key
3 input into the oversight process, and you will have a
4 dataset that indicates what types of issues are being
5 identified at the Cook plant.
6 In addition, you have engineered as part of your
7 oversight process, some cross-cutting inspection activities
8 that will take a look at the corrective action program for
9 its health, and continue to take a look at the engineering
10 organization in terms of doing some cross -- some vertical
11 reviews to take a look at the health of the engineering
12 organization.
13 With all of those elements in place, I think the
14 new assessment program will find problems like we've talked
15 about, earlier.
16 Now, looking back in retrospect, the Cook plant
17 did not have a healthy corrective action program, nor was it
18 doing a particularly in-depth review and look at its
19 engineering activities.
20 So I'm not sure the feeding, the initial process
21 of getting issues out on the table would have fed the
22 oversight process. So, from my own personal philosophical
23 standpoint, looking at it now as a senior member of industry
24 management, a healthy corrective action process is very,
25 very critical to ensuring that the oversight process will
61
1 work.
2 And second question, related to whether our
3 thoughts about the new oversight process and staring up,
4 with Unit II having been shut down now for getting close to
5 two and a half years, a lot of critical data that goes into
6 the performance metrics is either old or not available.
7 Several of the performance indicators require
8 7,000 critical hours of the reactor to effectively establish
9 the denominator on some of the indicators.
10 As a result, we have talked with your staff and
11 suggested that a transition program from the old oversight
12 effort would be most appropriate for the startup of Cook.
13 So we have a meeting scheduled in February to talk
14 to the staff about what that transitional plan would look
15 like. It certainly would include the continued utilization
16 of the restart metrics that we have established, and they
17 are numerous ones, and they cover a broad gambit of safety-
18 related issues at the plant.
19 The 03.50 panel, in some form or fashion, will
20 probably stay in place to oversee this transition, and we
21 would move aggressively to move and transition to the new
22 oversight program within about a year of restarting the
23 first unit.
24 COMMISSIONER DICUS: All right, thank you.
25 MR. POWERS: Did I answer the third part?
62
1 COMMISSIONER DICUS: You just answered the third
2 one, yes. You just go into the third one. You're not quite
3 ready to do it yet, the transition?
4 MR. POWERS: Yes, that's our perspective.
5 COMMISSIONER DICUS: Right.
6 CHAIRMAN MESERVE: Commissioner Diaz?
7 COMMISSIONER DIAZ: Yes, I want to echo the
8 Chairman's comments regarding the ability to self-criticize
9 yourselves and go forward. There obviously has been a major
10 effort, and your discovery efforts, I guess, have all been
11 major steps.
12 I've got a couple of questions, both of them
13 really related, and I will state them first.
14 When you looked through your present to the
15 supporting material, there's some programmatic items, you
16 know, in the case of the specific list that have high
17 priority, which I will tend to qualify them, but you can see
18 them safety-significant or risk-significant.
19 And then when you get to the restart issues or
20 probability questions, those same items take place with low
21 priority. A case in question is the ice condenser which
22 most -- leads me to my second part of the question.
23 There is some discrepancy, at least to me, at
24 first sight, in the way you prioritize these issues for
25 whether they are case-specific or whether they are
63
1 operational issues.
2 And the second part of the question is, as you
3 know, we went through -- I wouldn't call it traumatic, but a
4 very, very stressful period with Millstone in trying to
5 determine what were the Millstone issues. You know,
6 Millstones has had thousands of issues, and we keep being
7 hammered with how you're going to resolve thousands of
8 issues.
9 And it happens that really practically any power
10 plant or any industry has thousands of issues to resolve.
11 However, the Commission is always concerned with those
12 issues that are safety issues, or lately, we might be even
13 calling them risk-significant, ambivalent, or use them both
14 ways. We don't ever know which way to use them. But we use
15 them in a way that confuses everybody, including ourselves.
16 [Laughter.]
17 COMMISSIONER DIAZ: So, you mentioned, when you -
18 - and Mike Rencheck was the only one to talk about
19 specifically what were some of the safety issues. You talk
20 about the ice condenser and the high-energy lines and the
21 motor-operated valves.
22 Are those the only real safety and risk-
23 significant issues that your discovery showed up, or are
24 those are the only ones you highlighted?
25 If so, okay; if not, what other safety and risk-
64
1 significant issues had to be not only analyzed, but
2 resolved? And what is the status of both?
3 So, first, the discrepancy, and second, what are
4 they?
5 MR. RENCHECK: Let me back up. I think I might
6 provide you with some insight on how we went about
7 establishing the items we have been paying increased
8 attention to, to give you some background, and then I'll
9 answer the question specifically.
10 We used an industry-proven process that we had
11 used at Salem for screening issues as they came up and we
12 entered them into our Corrective Action Program, so we would
13 call restart issues issues that were safety issues,
14 operability issues, design and licensing basis issues,
15 configuration management issues, a gamut of regulatory
16 compliance as well.
17 When we took a look at those issues that we were
18 calling "restart required" we had a very experienced
19 management team and we went through all of those items,
20 identifying what issues and general issues could result in
21 something that was safety significant. That is the list of
22 40 that I had talked about.
23 After we scrubbed through all of the issues we
24 found, we had about 40 on our list that we knew that we had
25 to pay increased attention to because they could have some
65
1 safety significance to them.
2 Now as we have been resolving them to date we have
3 only identified those three that truly had safety
4 significance to them, although we are continuing to work
5 through the issues and we continue to look through the
6 issues --
7 COMMISSIONER DIAZ: Excuse me -- have high safety
8 significance? Obviously the other 40 have some safety
9 significance. You want to prioritize them in a level of
10 requiring major attention from you and also have regulatory
11 significance. Is that --
12 MR. RENCHECK: That is correct.
13 COMMISSIONER DIAZ: That is correct, okay.
14 MR. RENCHECK: That is how we came up with the
15 list. We are still working on them. We have three to date:
16 the ice condenser, motor-operated valves, and high energy
17 line break.
18 Now I believe you asked about the inconsistency.
19 I believe if you look at those issues they are each in
20 themselves have -- play a different role in the plant, so we
21 do not intend to communicate an inconsistency with the
22 priority on them. They all are being looked at at the same
23 level.
24 COMMISSIONER DIAZ: Okay, but it clearly says it
25 is high priority in here, it's low priority in there, and,
66
1 you know, if I am a layman, which I, you know, tend to be,
2 some of the time I look at it and say wait a minute, you
3 know, you are placing different priorities at different
4 times.
5 On issues of safety significance, I just really
6 focusing on safety significant issue, shouldn't the clear
7 priority on safety significant issues be maintained
8 throughout or is the process you are establishing, you know,
9 culls them some time and say they are no longer high
10 priority? I don't understand.
11 MR. RENCHECK: I guess to answer that question we
12 have placed again increased management attention on those 40
13 issues, placing them in a higher realm of management
14 attention and a higher priority than the other issues that
15 we have had for restart. We have periodically reviewed them
16 internally as well as with the Staff.
17 COMMISSIONER DIAZ: The question is should some of
18 those that are very important like the ice containment or
19 the high energy lines or the motor operated valves, should
20 they carry that same priority into the operation?
21 MR. RENCHECK: We are correcting those issues for
22 restart so as we restart our facility, we will be restoring
23 our plant back to its design licensing basis or having new
24 licensing actions that we have already worked with your
25 Staff on.
67
1 CHAIRMAN MESERVE: Commissioner McGaffigan?
2 COMMISSIONER McGAFFIGAN: Thank you. I want to
3 join the Chairman in commending this group of folks for
4 their straightforwardness, not only today but over the last
5 year or so in tackling the problems of restart.
6 One issue that comes to mind, since the plant has
7 been down for so long, how are you stocked for licenced
8 reactor operators, senior reactor operators and I assume you
9 probably have some classes ready to do their manipulations
10 and whatever once you have a plant to manipulate -- where do
11 you stand in trained people?
12 MR. POLLOCK: We are in a little different
13 position with the restart at Cook than some of the other
14 plants. We are actually going to be restarting Cook
15 primarily with operators that had operated the plant prior
16 to the shutdown.
17 In fact, it is pretty well -- I believe it's
18 actually 95 percent SROs and 80 percent ROs and of that 95
19 percent SROs some of those are ROs who have been upgraded
20 through the licensing process to SROs, so basically we are
21 restarting Cook plant with operators who had operated Cook
22 prior to the shutdown.
23 COMMISSIONER McGAFFIGAN: You didn't lose people?
24 MR. POLLOCK: We didn't lose people from that
25 standpoint, although there's some changes, some people who
68
1 were in different positions and were relicensed. We haven't
2 lost people.
3 Additionally, we have 24 SROs slated for training
4 classes that we have brought in that were previously
5 licensed from other plants to augment this and go into a
6 training program starting this spring -- actually, two
7 training programs we will have going this spring.
8 That is on the licensed side, and then we have
9 brought in nearly 40 equipment operators to augment our
10 staff also going through the training program.
11 COMMISSIONER McGAFFIGAN: This is a philosophical
12 question that Commissioner Dicus asked. You have one set of
13 standards for restart, and we have heard that from other
14 plants that some of these folks have worked at, and I know
15 they are going forward to achieve excellence, first
16 quartile, whatever. How do you see -- how long do you see
17 that period taking to achieve the higher standards that you
18 hope to achieve?
19 MR. POWERS: Well, we would love to be able to
20 tell you that it could happen over a short period of time,
21 but realistically the cultural change and making sure that
22 it is embedded in the fabric of our culture in our
23 estimation will take from three to five years to see its
24 full fruition demonstrate itself.
25 In the short-term, let's say over the first year
69
1 or so following restart we still see us in a mode of
2 providing a lot of directive top-down management as the
3 cultural attributes get further and further developed
4 throughout the organization.
5 We have a business plan that is being put together
6 to carry our efforts of continuing that change past restart.
7 There will be 10 strategic initiatives that we'll go to work
8 on some of the human performance issues that Chris alluded
9 to, some of the strategic performance initiative that we
10 need to tackle in terms of enhanced reliability for the
11 units, improved refueling outage performance and the like,
12 and we have included resources to support that business plan
13 as part of our going forward effort but overall I would say
14 you are looking at a couple refueling cycles to really see
15 the results of that cultural change.
16 COMMISSIONER McGAFFIGAN: And then one final
17 question. This may be for Dr. Draper. The Corbin MacNeills
18 of the world and Don Hinzes say you are either a shark or
19 you are going to be eaten.
20 [Laughter.]
21 COMMISSIONER McGAFFIGAN: And one of the issues is
22 insularity. I mean the reason I bring it up -- there is a
23 safety nexus. You know, some of the plants -- once Mike
24 worked at Crystal River and it's now been purchased by
25 Carolina Power & Light, I believe, or merged -- there is a
70
1 trend in the industry towards in that case it was a single
2 unit. You have a two-unit plant so you have more personnel,
3 but the notion that, the philosophical notion that some
4 people in the industry put forward is that you need a group
5 of plants to help provide people with career path
6 opportunities to retain them and that sort of thing, so do
7 you see -- how will you deal with the insularity issue on a
8 more global scale?
9 DR. DRAPER: Well, we think restarting the units
10 gives us a variety of options. The options are relatively
11 obvious, I suppose.
12 One has been suggested -- that you could either
13 sell or buy and become either larger or nonexistent. There
14 are intermediate possibilities, we think. The fact that we
15 will have the relationship with the South Texas Project
16 means that there are really four units that have some
17 relationship one to another.
18 There is also the possibility that we would form
19 some sort of an operational alliance of the type that has
20 been formed by the Wisconsin companies. Those companies are
21 nearby. Some of the units at least have similarities to our
22 own plant, so it is a bridge we have not yet crossed. We
23 recognize that it is something that is certainly worthy of
24 attention, but I wouldn't say it is as obvious as perhaps
25 Corbin thinks it is, that a two-unit, substantial sized
71
1 plant couldn't be successful. I think it probably could be,
2 but that is not necessarily the optimum situation.
3 We will just as we go forward evaluate what those
4 options are.
5 COMMISSIONER McGAFFIGAN: Thank you.
6 CHAIRMAN MESERVE: Commissioner Merrifield.
7 COMMISSIONER MERRIFIELD: Obviously, you know, a
8 lot of the success here is due to the fact that you brought
9 in the strong management team. In fact, you have so many of
10 them here it makes me wonder who is left at the plant today
11 but --
12 [Laughter.]
13 COMMISSIONER MERRIFIELD: I guess my question is
14 institutionalization of changes so that when this group of
15 folks leaves down the line you will still have the right
16 kind of results, that this is not a person-driven process,
17 that it has become institutionalized within the system, and
18 I wonder if you could just touch a little bit on how you are
19 going about doing that.
20 DR. DRAPER: Let me make a comment and then ask
21 Bob to comment as well. I think you are absolutely right.
22 One of the things that we believe we had done is
23 to put together an absolutely top notch team of people who
24 have had experiences at a variety of successful operating
25 plants as well as the restart plants, and so we think we
72
1 have a top layer organization that is second to none.
2 The trick is to, as you suggest, institutionalize
3 that, be sure that the people who are in the succession plan
4 have equally good skills and we'll be working very hard to
5 be sure that we don't have a team that is the All Star team
6 leading off, with nobody else sitting on the bench, and that
7 is a challenge for us. We believe that we have capabilities
8 within our own organization for developing people who have
9 been there, and we will doubtless continue to look around as
10 needed to fill in behind these guys.
11 MR. POWERS: Let me answer the question on a
12 personal level. I came to help this plant achieve world
13 class performance and my job is not done, so I plan to stick
14 it out and make sure that happens.
15 Now having said that, the plan that I am
16 implementing is twofold for about the next year or so. It
17 will be a top-down effort to ensure that the cultural
18 attributes that I mentioned are in fact demonstrated on a
19 day to day basis, and I plan to make sure that the
20 management team that is in place is motivated and
21 appropriately compensated to stick it through as well.
22 In the longer term, the pre-eminent, the first
23 strategic initiative in our business plan will be the human
24 performance initiative. It includes a vision that says to
25 achieve the operating focus that Chris Bakken described we
73
1 will license people throughout the facility to get an
2 operational perspective or certify them. Those will be
3 engineers and maintenance people and radiation protection
4 and chemistry people who will get a sense of what it is like
5 to operate the facility so that they can carry that spirit
6 of what it takes to truly have operational focus forward.
7 Those will be the types of actionable items we
8 will have to accomplish over the next three, four, five
9 years to really make sure that this is self-sustaining, and
10 be less susceptible to the senior management team deciding
11 to go off and pursue other adventures, and that is what we
12 are committed to do.
13 CHAIRMAN MESERVE: Thank you very much.
14 COMMISSIONER MERRIFIELD: Mr. Chairman -- I'm
15 sorry, that wasn't my only question.
16 CHAIRMAN MESERVE: Could you make it brief now,
17 Jeff?
18 COMMISSIONER MERRIFIELD: Can you estimate the
19 size of the backlogs you expect at restart and how you are
20 going to deal with that given the fact that you may have
21 emerging issues under power?
22 MR. BAKKEN: Yes. The specific size of the
23 backlog, Commissioner, is a little bit too early to tell.
24 We do have a meeting planned with the Staff to discuss the
25 backlogs in detail and our plans for addressing them in
74
1 March. In general, the backlog are scrubbed carefully using
2 the restart criteria that we have with the same process that
3 has been used elsewhere.
4 We will be very careful going through it to look
5 to make sure that the individual component as well as
6 potentially aggregate impact is adequately reviewed to make
7 sure that there is no safety issue and that we don't miss a
8 design or license basis issue or a reliability issue.
9 All of that review is being done by the system
10 manager as well as the senior reactor operator and
11 ultimately comes to our plant operating review committee for
12 review and approval. It is a pretty rigorous review process
13 to make sure it is okay.
14 COMMISSIONER MERRIFIELD: One final brief
15 question. Commissioner Dicus asked about readiness renewal
16 oversight process, but I am interested in whether you have
17 any insights at this point on how we might integrate the
18 03.50 process into that new program as well?
19 MR. POWERS: The 03.50 process, Commissioner?
20 I think that deserves some thought. There is a
21 big difference -- the 03.50 process is really a process to
22 drive discovery. The oversight process is one that really
23 needs to have programs in a healthy status to work as I
24 mentioned. Beyond that, we really haven't thought through
25 any --
75
1 COMMISSIONER MERRIFIELD: Okay, perhaps it's for
2 another day. You brought us some insight on that. Thank
3 you.
4 CHAIRMAN MESERVE: Good. I would like to thank
5 you all very much. It's been a very helpful presentation.
6 I would like to turn now to Mr. David Lochbaum,
7 who, as most of you know, is a Nuclear Safety Engineer with
8 the Union of Concerned Scientists. He has been following
9 the situation at this plant carefully over the years.
10 Welcome.
11 MR. LOCHBAUM: Good morning. Thank you for
12 soliciting our views on this matter.
13 Nineteen months ago I sat at this table to discuss
14 the proposed restart of Millstone Unit 3. My presentation
15 at that time ended with these two conclusions, quote, "NU's
16 future performance cannot be predicted, but it is known that
17 the NRC Staff lacks the ability to reliably shut down plants
18 with regulatory performance problems. Millstone Unit 3
19 should not start without that adequate protection standard
20 being met."
21 There are many similarities between D.C. Cook Unit
22 2 today and the Millstone Unit 3 facility in June of 1998.
23 Both had been closed for more than two years while their
24 owners made numerous corrections to both the physical plant
25 and to its procedures.
76
1 We believe that the extent of these changes
2 strongly suggests failure by the plant owners and also by
3 the NRC to have properly focused on safety. D.C. Cook's
4 owners have provided today a lengthy listing of plant
5 modifications, equipment upgrades, and procedure changes
6 that they have made to support their assertion that the
7 facility is preparing to restart.
8 Millstone's owners provided a comparable listing
9 in June of 1998 and similar time and effort has gone into
10 examining these lists in an attempt to ensure that the
11 necessary safety margins have been restored.
12 The compilation and scrutiny of D.C. Cook's list
13 is as important now as it was for Millstone in 1998. The
14 long length of these lists demonstrates that substantial
15 erosion of safety margins occurred. I will try to avoid my
16 usual exchange with Commissioner Diaz over this subject by
17 not stating that this meant that the plants crossed the line
18 between safe and unsafe. Instead, I will say that this
19 meant the plants crossed the line from acceptable
20 performance into unacceptable performance.
21 The key difference between Millstone in 1998 and
22 D.C. Cook today has nothing to do with their respective
23 laundry lists. The key difference is that the NRC Staff now
24 has a list of what it has corrected. At the top of that
25 list is the revised reactor oversight process. In 1998 the
77
1 NRC Staff did not have such a list. At best it had an IOU
2 slip.
3 In effectively implemented reactor oversight
4 process is vital for D.C. Cook, for Millstone, and for all
5 operating nuclear plants. If performance declines an
6 effectively implemented oversight program wills step in and
7 prevent safety margins from being eroded to the point where
8 the line between acceptable and unacceptable performance is
9 crossed.
10 In 1998 we lacked confidence that the NRC Staff
11 had the means to detect and correct declining performance at
12 Millstone should that occur following restart. After all,
13 the Staff was using the same policies and procedures that
14 had been used unsuccessfully prior to Millstone's extended
15 outage.
16 Today we have confidence that the revised reactor
17 oversight process, if implemented effectively, can provide
18 the Staff with the means to detect unacceptable operation at
19 D.C. Cook if its performance declines following restart.
20 The qualifier in that statement, "if implemented
21 effectively," should not be discounted. The old reactor
22 oversight process could have been successful if it had been
23 implemented effectively.
24 We are encouraged that the Staff's plans for
25 implementing the new process include monitoring and follow-
78
1 up checks to increase the chances of successful
2 implementation.
3 We recommend that the revised reactor oversight
4 process be applied to all operating nuclear plants as soon
5 as practical. It is the adequate protection standard that
6 we felt was lacking in June of 1998.
7 Thank you for listening to our views.
8 CHAIRMAN MESERVE: Thank you very much, Mr.
9 Lochbaum.
10 You would agree, would you not, that there has to
11 be some sort of a transition in the case of D.C. Cook
12 because they don't have the critical data available to go
13 full-fledged into the new oversight program.
14 MR. LOCHBAUM: Right. An earlier draft of my
15 written statement suggested that we apply it to D.C. Cook at
16 restart, after discussions with Mr. Grobe and others that,
17 your point is well taken, the plant is not ready to allow
18 that to happen. It is going to take some time for something
19 to happen, so that I agree that that needs to happen.
20 CHAIRMAN MESERVE: Thank you. Any questions from
21 my colleagues?
22 COMMISSIONER MERRIFIELD: Yes.
23 COMMISSIONER McGAFFIGAN: Yes.
24 CHAIRMAN MESERVE: Others?
25 COMMISSIONER DICUS: Go ahead.
79
1 COMMISSIONER McGAFFIGAN: On the oversight
2 process, you heard earlier that -- what was broken at D.C.
3 Cook.
4 Are you confident -- I mean you have sat on this
5 Board -- that if implemented effectively that we would have
6 found the corrective action program problems and the design
7 problems at D.C. Cook with the revised inspection program?
8 COMMISSIONER DICUS: And if I could, also the
9 people problems as well, if I could tag that on.
10 MR. LOCHBAUM: I think it would have been, and the
11 evidence that I used to base that guess is the -- and I
12 don't have it today, I wish I did -- we plotted the NRC
13 inspection findings for a two year period before September
14 of 1997 and a nine-month period afterwards, and they
15 averaged roughly eight or nine findings, which included
16 Level 1, 2, 3 and 4 noncited violations.
17 They averaged eight or nine of those before
18 September, 1997, and they jumped to like 75 in a peak month
19 afterwards. They went up. There was a dramatic sea change.
20 We felt that D.C. Cook's performance didn't change
21 overnight. The perception changed overnight.
22 I don't know that the director of the oversight
23 process would have found it at the exact earliest
24 opportunity but I think it would have found it earlier than
25 September of '97.
80
1 COMMISSIONER McGAFFIGAN: Would the PIs have found
2 it or would it have been in inspection findings?
3 MR. LOCHBAUM: I think it was a race, because most
4 of the data comes through the PI format. My guess would be
5 PIs would have found it first. I think some of the back-
6 testing that is done in SECY 99.07 or 7(a), I forget which
7 one, indicates that some of the findings PIs did go other
8 than green at D.C. Cook so I think that would have been an
9 indication. Whether the NRC's supplemental inspections then
10 fully explain what the problems were and pointed out the
11 people problems Commissioner Dicus pointed out, I suspect
12 that would have happened or that there was an opportunity
13 for that to have happened.
14 COMMISSIONER McGAFFIGAN: I would like to
15 continue. I don't want to turn this into a new inspection
16 program. We will have another opportunity on that, but the
17 significance determination process for inspection findings,
18 do you think some of the inspection findings that were there
19 to be found would have triggered a white or yellow, they
20 wouldn't have all been green inspection findings if you had
21 a properly implemented new oversight process?
22 I mean these are all theoretical questions.
23 MR. LOCHBAUM: Right. I hope they would have. If
24 not, at least it would have prompted a debate, which would
25 have given groups like ours an opportunity to have a voice
81
1 in the debate, but I think it would have -- absent --
2 absent -- I really do --
3 COMMISSIONER McGAFFIGAN: Okay.
4 MR. LOCHBAUM: I have no data to prove that, but I
5 do believe it would have.
6 COMMISSIONER McGAFFIGAN: Thank you.
7 COMMISSIONER DIAZ: Well, I'm sorry we are not
8 disagreeing a lot today. That makes me wonder whether I am
9 getting old.
10 [Laughter.]
11 COMMISSIONER DIAZ: David, but I just wanted to
12 say that I personally, I believe the Commission appreciates,
13 you know, your comments early in the process with this, how
14 you brought things out, and I am glad we pay attention, and
15 you have been very valuable to us in this process, and we --
16 I just want to say thank you.
17 MR. LOCHBAUM: I appreciate that. Thank you.
18 COMMISSIONER MERRIFIELD: Commissioner Diaz,
19 beating me to the punch, I agree. I think your assistance
20 in the D.C. Cook oversight, the new oversight process and
21 the 2.06 process have all been valuable and I hope our
22 positive comments don't take away from your constituency's
23 respect for what you do, because certainly I have respect
24 for it.
25 COMMISSIONER DIAZ: He will disagree soon. Don't
82
1 worry about it.
2 [Laughter.]
3 MR. LOCHBAUM: Not yet though.
4 COMMISSIONER MERRIFIELD: I want to say we have
5 been dealing with the issues relative to Millstone and D.C.
6 Cook within the time that I have been a Commissioner, and
7 even dissatisfaction with the way in which we were doing
8 some things at D.C. Cook and at Millstone and have not had
9 quite the same level of concern about what we have been
10 doing at D.C. Cook.
11 At both we used the 03.50 process, and so my
12 question for you is do we have an issue here in terms of a
13 different way of implementing the 03.50 process? Is it a
14 different way that the regions have acted in their oversight
15 efforts? Is there some inconsistency within how we were
16 acting here at Headquarters? Do we have some other
17 programmatic weaknesses?
18 Where is it that is the source of a difference, in
19 your opinion, in terms of how we acted relative to Millstone
20 and how we have been acting relative to D.C. Cook?
21 MR. LOCHBAUM: Well, I think the 03.50 process is
22 intentionally broad-based and they can cover a number of
23 applications. Therefore, that allows a lot of flexibility
24 on level of detail, what is within the scope, what is out of
25 the scope.
83
1 Even with that issue, I think it was more in how
2 it was implemented at Millstone versus how it was
3 implemented at D.C. Cook, so I don't think it is a specific
4 problem with the procedure. It seemed to me to be the way
5 it was implemented.
6 When I attended or monitored Millstone meetings,
7 there were -- the Staff asked questions, but there was no
8 follow-up. There were no strings pulled. It seemed to be
9 accepted on faith what Millstone was doing. I am not saying
10 Millstone was doing a bad job, just when I look at how
11 Region III has handled D.C. Cook, there have been probing
12 questions. It is not adversarial so it is not a different
13 approach, but there is a greater public confidence. At
14 Millstone it didn't look like -- when I came away from a
15 Millstone meeting I usually had questions that I would have
16 asked had I been allowed to speak.
17 At the D.C. Cook meetings it was very seldom that
18 the region didn't ask the questions first. That led me to
19 greater confidence that they were doing a thorough job
20 asking the questions that I would ask if I could speak, so I
21 think that is the difference that I observed.
22 COMMISSIONER MERRIFIELD: Thank you.
23 CHAIRMAN MESERVE: Thank you. We very much
24 appreciate --
25 MR. LOCHBAUM: Thank you.
84
1 CHAIRMAN MESERVE: -- your participation this
2 morning.
3 Our final panel will consist of various members of
4 the Staff. Good morning.
5 DR. TRAVERS: Well, I think we're settled, Mr.
6 Chairman.
7 CHAIRMAN MESERVE: Why don't you proceed?
8 DR. TRAVERS: Thank you very much. Good morning.
9 As you pointed out earlier, Chairman, in your comments, the
10 Agency has certainly been significantly involved in
11 evaluating the corrective actions at D.C. Cook.
12 Today we plan to provide you with our perspective
13 on a number of issues, including the status of the
14 licensee's corrective actions, and our own Manual Chapter
15 0350 restart assessment process.
16 Joining me at the table this morning are Jim Dyer,
17 the Regional Administrator, Region III, Jack Grobe, who is
18 Jim's Director of the Division of Reactor Safety; Sam
19 Collins, the Director of the Office of Nuclear Reactor
20 Regulation; John Zwolinski, who is Sam's Director of the
21 Division of Licensing and Project Management.
22 Other members of the NRC staff who have been key
23 to our activities at D.C. Cook will be identified in a few
24 moments by both Jim Dyer and John Zwolinski.
25 This is the fourth time in the past two years that
85
1 we've had the opportunity to discuss the performance at D.C.
2 Cook with the Commission. In July of 1998, we discussed
3 D.C. Cook performance at the annual briefing on operating
4 reactors.
5 As a result of that meeting, we concluded that the
6 performance at D.C. Cook was declining. In November of
7 1998, we met with the Commission to discuss D.C. Cook
8 performance in detail, with the particular focus on
9 engineering performance issues.
10 In May of 199, we discussed D.C. Cook performance
11 again at the annual briefing, and we informed the Commission
12 that D.C. Cook had been categorized as an Agency-focus
13 plant. This was done in recognition that the issues at D.C.
14 Cook had for some time been the focus of senior NRC
15 management attention.
16 D.C. Cook remains an Agency-focus plant, and the
17 staff intends to utilize the senior management meeting
18 schedule for this Spring as the vehicle for making the
19 determination of whether the Agency-focus classification
20 should be retained or changed.
21 This determination would include our assessment of
22 the power operations subsequent to any restart
23 authorization. Restart authorization will occur after the
24 Manual Chapter 0350 restart panel has determined that
25 actions have been satisfactorily completed for safe restart
86
1 at Unit II.
2 Jim Dyer, in coordination with Sam Collins and
3 myself, will make a final determination regarding the
4 restart of the D.C. Cook plant.
5 Importantly, the 035 panel will continue to
6 evaluate Unit II performance following restart to ensure
7 that American Electric Power actions to improve performance
8 are sustained.
9 I would like to now to turn it over to Jim Dyer
10 who is going to begin our formal presentation.
11 MR. DYER: Thank you, Bill. May I have Slide 1,
12 please.
13 Mr. Chairman, Commissioners, here with me today is
14 Jack Grobe, who in addition to being the Director of the
15 Division of Reactor Safety in Region III, is also the 0350
16 panel chairman. John Zwolinski is the Vice Chairman for the
17 0350 panel for D.C. Cook restart.
18 Additionally, Region III staff who are also here
19 involved with the D.C. Cook project are Tony Vagel, the DRP
20 Branch Chief, Bruce Bartlett, his Senior Resident Inspector
21 for D.C. Cook, Gary Shear, the DRS Branch Chief, lead Branch
22 Chief for D.C. Cook, and Mel Holmberg, the lead engineer for
23 the D.C. Cook restart activities.
24 Can I have the second slide, please? For today's
25 presentation, our plan is that I will first summarize NRC
87
1 oversight activities since the shutdown of the D.C. Cook
2 Units, and focusing on those activities since our last
3 briefing in May, 1999.
4 And then John Zwolinski will present the status of
5 licensing activities that are in progress or have been
6 completed to support the D.C. Cook restart. And then,
7 finally, we will address the staff oversight activities
8 planned for the restart and the operation.
9 Overall, the NRC has expended approximately 20,000
10 hours of direct inspection effort at the D.C. Cook plant
11 since 1997, in the past three years.
12 COMMISSIONER DIAZ: Excuse me, how many?
13 MR. DYER: About 20,000 hours since 1997, 1998 and
14 1999. And of those, about half of them, or 10,000 hours of
15 direct inspection effort, have been focused on what I will
16 call the recovery and discovery efforts of the licensee.
17 Slide 3, please. For a little history, in
18 September, 1997, in followup to the architect engineering
19 inspections and subsequent plant shutdown, dual-unit
20 shutdown of both D.C. Cook Units, Region III issued a
21 confirmatory action letter documenting the actions that
22 American Electric Power would take prior to their restart.
23 Those actions included resolution of nine specific
24 issues identified during the NRC inspection, as well as our
25 understanding that American Electric Power would determine
88
1 whether similar engineering problems existed in other safety
2 systems.
3 Subsequently, additional problems were discovered,
4 and as a result, the NRC issued a Severity Level II problem
5 violation -- issued violations that constituted a Severity
6 Level II problem, and issued a $500,000 civil penalty in the
7 latter part of 1998.
8 And in March, 1998, American Electric Power
9 developed a restart plan that expanded and included system
10 readiness reviews of those risk-significant systems to bound
11 the problems found by the inspection.
12 At that same time, the NRC commenced its 0350
13 restart panel, formed its 0350 restart panel, and issued its
14 initial case-specific checklist for D.C. Cook restart.
15 Later in 1998, American Electric Power completed
16 their plant system readiness reviews that were intended to
17 bound the significant issues, and in September, the NRC
18 observed American Electric Power's contracted safety system
19 functional inspection of the auxiliary feedwater system.
20 That inspection identified significant operability
21 issues that had been missed by these system readiness
22 reviews. Also in September, NRC inspectors identified
23 operability concerns with motor-operated valves that further
24 questioned the effectiveness of their system readiness
25 reviews.
89
1 At the November 30th, 1998 Commission meeting,
2 briefing on D.C. Cook, American Electric Power was bringing
3 in their outside engineering and management talent,
4 performing self-assessments, and revising their approach to
5 restart, and in March, 1999, they revised their restart plan
6 to include the expanded system readiness reviews and
7 assessment of programs and functional areas.
8 Overall, up until March of 1999, from the
9 September 1997 date until March 1999, the NRC expended
10 approximately 4,000 hours of direct inspection effort to
11 identify the scope of their problems to the licensee, and
12 have them initiate their expanded system readiness reviews.
13 Next Slide 4, please. The expanded system
14 readiness reviews, programmatic assessments, and the
15 functional reviews conducted by American Electric Power
16 staff, augmented by experienced contractors, the process
17 identified numerous deficiencies, some of which required
18 repair, system modifications, and license amendments, as we
19 heard earlier from the licensee.
20 This was the status of the activities at the time
21 we last briefed the Commission in May of 1999. This past
22 Summer, the Manual Chapter 0350 restart panel focused
23 several inspections on the American Electric Power problem
24 discovery efforts, using our own experienced inspectors and
25 contractor personnel.
90
1 Our inspections evaluated the conduct of
2 licensee's problem discovery efforts, reviewed the resultant
3 input to their corrective action process, and assessed the
4 adequacy of the licensee's oversight of this discovery
5 process.
6 We also conducted a safety system functional
7 inspection of two safety systems as an independent
8 validation of their efforts. We found the expanded system
9 readiness reviews to be effective in identifying the
10 deficiencies impacting safety system functions that
11 confirmed that American Electric Power had conducted
12 sufficiently self-critical reviews of their programs and
13 functional areas, and that the performance assessment
14 organization of D.C. Cook provided critical oversight of
15 plant activities.
16 This effort ended up and was completed in
17 September of 1999, and the NRC expended approximately 3,000
18 hours of direct inspection effort to review their discovery
19 efforts.
20 Following this validation of the discovery
21 efforts, the case-specific checklist was expanded to capture
22 the necessary licensee corrective actions to support the
23 safe restart.
24 Slide 5, please. This past Fall, inspections have
25 been conducted to review the effectiveness of American
91
1 Electric Power's efforts to correct the deficiencies
2 identified during their discovery efforts.
3 To date, we have spent approximately 2500 hours of
4 direct inspection effort, reviewing such areas as operator
5 training, corrective actions program, safety evaluations,
6 preventive maintenance, operability determinations, ice
7 condenser corrections, and incorporating instrument
8 uncertainties into equipment design testing and plant
9 procedures, as well as some of the engineering corrective
10 actions activities that were discussed earlier by Mr.
11 Rencheck.
12 The inspections confirm progress in resolving many
13 of the restart issues. Our inspections and NRR staff
14 reviews have confirmed adequate resolutions of the issues
15 identified in the confirmatory action letter and the nine
16 issues in the bounding concern.
17 We are currently considering the staff's
18 recommendation to close out this confirmatory action letter.
19 The remaining restart activities would then be managed
20 through a case-specific checklist in the 0350 process.
21 Slide 6, please. At this point, I'd like to turn
22 the discussion of the licensing activities over to John
23 Zwolinski.
24 MR. ZWOLINSKI: Good morning. I would like to
25 recognize members of the NRR staff, our Project Manager,
92
1 sitting behind me, is John Stang, who has had the
2 responsibility for Cook for the last couple of years. His
3 Section Chief is Claudia Craig, who has also been deeply
4 involved with the facility.
5 I'd also like to note that there are others on the
6 NRR staff that have been deeply involved with technical
7 reviews under the Division of Engineering and Division of
8 System Safety and who supported the work.
9 As compared to other extended shutdown plants,
10 D.C. Cook did not require the processing of a large number
11 of license amendments as Cook has undertaken an effort to
12 restore the original design basis of the plant.
13 The licensee chose to make modifications at the
14 plant, in lieu of trying to use analysis to justify the
15 conditions found during the enhanced system readiness
16 review.
17 Examples include the repair and restoration of the
18 ice condenser to its original design and licensing basis,
19 removal of foreign material, and repair of ice baskets, for
20 example; removal of fibrous material.
21 They also cut holes in the containment crane wall
22 to allow reactor coolant to flow back to the recirculation
23 sump to maintain levels in the sump.
24 Thus, our technical staff focused on questions and
25 concerns raised regarding licensing basis of the plant, and
93
1 trying to maintain a schedule to support licensee
2 submittals.
3 This has been especially true over the past year.
4 Two major issues resolved by the technical staff were
5 unreviewed safety questions concerning sump pump
6 performance, ice rates, also credit for control rod
7 insertion following a large break loca.
8 We have monitored licensee design and licensee
9 initiatives that were identified as a result of the
10 licensee's enhanced system readiness review process and our
11 own inspection process.
12 In order to facilitate the licensing process, we
13 not only interact with the licensee on a daily basis; we
14 conduct a senior management-level phone call on a weekly
15 basis. Typically, NRR, the Region, residents, and the
16 licensee, participate on this important call.
17 We've taken steps to ensure surprises have been
18 minimized, and use the concept of over-communication to
19 ensure any and all issues are raised promptly, thus trying
20 to attain or maintain our ability to stay out in front of
21 any critical licensing issues.
22 Remaining issues before the staff that require our
23 approval prior to restart: Changes to containment spray
24 pump surveillance, deletion of a reference to reactor
25 coolant pump volume as referenced in the technical
94
1 specification, and issuance of an order against NUREG 0737
2 to modify hydrogen monitoring. These are all scheduled to
3 be completed before the end of January.
4 To put in context, the staff's efforts, we've
5 compared our efforts to a few plants that have been in
6 extended outages, specifically Salem and Crystal River. For
7 Cook, in 1999, our staff has spent approximately 1600 hours
8 resolving 13 issues. For Salem, the staff spent
9 considerable time in the early stages of that plant
10 shutdown, but in the following year, resources spent were
11 considerably less than Cook.
12 Whereas, with Crystal River in the last year, we
13 spent about 3500 hours on 34 issues, so Crystal River was
14 very heavily into the licensing side of the house, Cook
15 being far less.
16 That concludes my remarks.
17 MR. DYER: Slide 7, please. As we heard earlier,
18 American Electric Power plans to restart D.C. Cook Unit II
19 in March of this year, and Unit I later this Summer, after
20 steam generator replacement.
21 The NRC Manual Chapter 0350 restart panel has
22 effectively focused NRC activities to accomplish the
23 necessary regulatory actions to meet this schedule. As John
24 said, licensing activities have been well coordinated, as
25 well as the inspection activities in working with the AEP
95
1 staff.
2 We've held frequent meetings onsite, in the
3 Region, and here at headquarters to solicit stakeholder
4 input, and to give them the opportunity to observe the
5 regulatory process.
6 The restart panel continues to review plant
7 issues, emerging issues within the station, and to
8 coordinate our inspection schedules, and review and assess
9 the overall work environment for individuals to raise safety
10 concerns.
11 Currently, we have some remaining inspections to
12 complete prior to restart. As part of our continued
13 validation of the corrective action program, we will inspect
14 the motor-operated valve program, electrical protection
15 coordination, return to service of safety systems, and the
16 surveillance testing program.
17 Just prior to restart, we will also conduct an
18 operational readiness inspection with continuous control
19 room observation, and our senior reactor analysts will also
20 assess the risk impact of any deferred work after restart.
21 Overall, we expect to expend approximately 1200
22 hours of direct inspection effort in this restart effort,
23 going forward from today.
24 Restart approval will follow the existing 0350
25 manual process. The 0350 panel will continue to evaluate
96
1 the Unit II performance, following restart, to ensure that
2 improved performance is sustained.
3 We'll also provide oversight for the Unit I
4 restart, after steam generator replacement, and we'll
5 support transition of D.C. Cook to the new oversight panel.
6 The implementation of the risk-informed baseline
7 inspection program and the revised assessment process will
8 be delayed beyond April 1st. To minimize the impact during
9 the restart of the units and until D.C. Cook has been
10 operated in sufficient time to develop the valid performance
11 indicators, the NRC, as we heard earlier, the NRC and D.C.
12 Cook will meet in February to discuss the transition plan.
13 We'll have a plan put together before April 1st to handle
14 the transition.
15 That concludes my prepared remarks.
16 CHAIRMAN MESERVE: Thank you very much. I think
17 the staff should be commended for their efforts, and we
18 appear to be headed towards a successful conclusion with
19 what is a very obviously major effort. That reflects very
20 well on all of you.
21 I don't really have any questions for you about
22 the specifics of the restart process, but I wonder if having
23 been in the middle of this, there are some observations you
24 make or lessons we should learn about when we confront this
25 situation again.
97
1 Hopefully we won't, but the possibility exists.
2 Are there things that we should learn from this whole
3 process that you've been under that have to do with our own
4 way of dealing with these situations, things we should
5 undertake that would improve the way we approach the kinds
6 of problems that you've been dealing with for the last few
7 years?
8 MR. DYER: Mr. Chairman, I think that the biggest
9 lesson that I have learned -- and we talked about this, and
10 I think Commissioner Dicus and the other Commissioners have
11 raised the issue -- about looking with 20/20 hindsight, what
12 would we have done with the new assessment process and Cook?
13 Sam Collins and I have had several discussions
14 about this. It's the importance of, we have to make the new
15 process discover the D.C. Cook's before they get this bad.
16 And I don't know whether the performance indicators would
17 have discovered it, but focusing on the inspection program,
18 it is -- we need to make sure that the tools are there.
19 I look at it now -- I believe that the new
20 assessment program with the inspection that's currently
21 provided, could find, can find. The challenge that is on me
22 as a Regional Administrator, and Jack as the DRS Director
23 and our team, is to make sure that we put the right kinds of
24 people and have the right kind of inspection effort and
25 talent to identify some of the design basis issues that
98
1 wouldn't lend themselves to performance indicators.
2 And that we ensure that the performance indicators
3 that do come forward are properly categorized so that we get
4 the true picture of performance at the site.
5 CHAIRMAN MESERVE: Thank you. Commissioner Dicus,
6 do you have any questions?
7 COMMISSIONER DICUS: Just a quick one. I'll ask
8 Commissioner Merrifield's question for him.
9 On the 350 process, he's brought this up with the
10 other presenters, and to what extent the 350 process might
11 have to change under the new oversight -- new reactor
12 oversight program that we're going to. I'm just asking it
13 to you, what you think, because it is going to require some
14 modification, but it has also been a very successful
15 program, particularly with D.C. Cook.
16 Do you want to jump on that one?
17 MR. DYER: I'm not sure how the new -- what we're
18 looking at to go -- to tie it to the 350 process to go
19 forward. I anticipate that it will be somewhat like we have
20 right now.
21 There are some critical parts of the 0350 process
22 that I think have to be there. I think the communications
23 channels that it opens up at the point where we make the
24 decision to dedicate the resources, and to manage and to a
25 structured approach, to manage the resources that we're
99
1 focusing on a problem plant, are critical. That still has
2 to be there.
3 Jack is much more familiar with it, so I'll let
4 him talk, if he has anything he wants to add.
5 MR. GROBE: I've studied the new draft procedure
6 for the new 0350 process, and Sam Collins's staff and I
7 considered whether we should implement the new process, once
8 April 1 comes around. We concluded that we should not,
9 because it is predicated upon valid performance indicators
10 and other things that we didn't do under the old process.
11 But there are a couple of things that I have
12 learned through this process. I believe this outage could
13 have been shorter, had we been more intrusive earlier in the
14 0350 process.
15 Behaviors that we've learned in the Regions over
16 the years have shown we have to provide findings. If a
17 licensee doesn't listen to those findings, we make new
18 inspections and provide more findings.
19 But we weren't very -- I don't want to say
20 directive, but severely intrusive early in the discovery
21 efforts that occurred in 1998. Consequently, it wasn't
22 until later in '98 when we were going to do an aux feedwater
23 SSFI and the licensee requested that they be permitted to do
24 that with our oversight, that it truly came to the surface,
25 that the early system reviews were not being effective.
100
1 We had indications of that earlier, and I believe
2 we should have become more intrusive earlier, and done a
3 more thorough engineering inspection earlier in that
4 process.
5 With respect to the new, risk-informed baseline
6 inspection program, for that program to be effective, the
7 licensee has to have a robust corrective action program. So
8 it's somewhat of a guess, whether or not the new program
9 could have been effective with Cook in its, as Bob Powers
10 described, insular, nonfunctional from the standpoint of
11 corrective action, mode that it was in.
12 The new inspection program has corrective action
13 program inspection modules; the old program had those. As
14 Jim indicated, our challenge is to be more effective in
15 implementing those new inspection modules.
16 In addition, the new program includes a much more
17 intense design focus, once every other year, which was not
18 included in the old program.
19 So, from that standpoint, those are the lessons
20 learned from Cook and Millstone.
21 COMMISSIONER DICUS: Okay, thank you.
22 MR. COLLINS: I think we're going to go forward
23 since -- speaking for the Program Office -- we track the
24 oversight process improvements through the tasking
25 memorandum, and as you know, they go to level of detail.
101
1 We have moved improvement initiatives in both the
2 old 350 process, the oversight process, obviously, and also
3 the confirmatory action letter process, into our operating
4 plan as an organization for NRR.
5 Our regulatory effectiveness matrix includes an
6 initiatives area that includes all of these areas.
7 The application of the program, specifically the
8 CAL and the 0350 process at Cook was more of a hybrid than
9 we might have seen at a Salem or a South Texas, for that
10 matter.
11 The hybrid aspect of it was that we had a tendency
12 to be more in-process than confirmatory, once a licensee has
13 come to a conclusion or has completed a program.
14 That's a credit to Jim and Jack and the resources
15 in Region III, in that in the area of changed management,
16 the staff was able to move for a back-end review, once all
17 the answers were there, to an in-process review wherein they
18 look at the process by which the licensee comes to
19 conclusions, take a sample of the application of those
20 processes, and then move on and only sample the subsequent
21 applications.
22 The 0350 process is the same way. The discipline
23 having to do with the restart items is very focused towards
24 those specific regulatory risk-significant issues which need
25 to be confirmed by the Region, rather than go back and
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1 recouping all of the items on the outstanding list and
2 ensuring that they're complete before plant restart.
3 So these initiatives are in process as a result of
4 lessons learned, not only from Cook, but as a learning
5 organization from the past three cases. We have already
6 revised the confirmatory action letter procedure; that's
7 been done.
8 The 0350 process procedure is in draft, so we're
9 moving down the road as a result of these.
10 CHAIRMAN MESERVE: Commissioner Diaz?
11 COMMISSIONER DIAZ: Yes, obviously practice makes
12 perfect, and you guys have so much practice in Millstone and
13 Crystal River and so forth, that, you know, you were able to
14 use better processing.
15 I have a two-part question, one directed to John
16 and one to Jim. It's the same question.
17 We all realize, you know, what happened when you
18 got into the discovery of the auxiliary feedwater and the
19 MOVs and the significance of those issues, and how, you
20 know, you it was -- by the licensee, and you -- and now
21 almost at the end of the process, John, what is the
22 confidence level that you have that all major safety-
23 significant issues have been discovered or have been
24 discovered and already remedied?
25 MR. ZWOLINSKI: I'll go ahead and start.
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1 COMMISSIONER DIAZ: I'm talking about your part,
2 the licensee design, and then I'm going to turn to Jim and
3 ask him the same question on the rest of the issues.
4 MR. ZWOLINSKI: The licensee did the expanded
5 system readiness reviews and identified a myriad of issues.
6 It was then incumbent on us to run it through a process in
7 which the staff was satisfied that the licensee had
8 identified significant issues, risk-significant issues,
9 unresolved safety questions, or were they issues that were
10 less significant that could be deferred?
11 So there restart checklist became a very important
12 vehicle for the licensee to use and for us to look at also.
13 So that went in parallel.
14 The licensee -- and, by the way, this was all done
15 through our 0350 panel. The licensee presented the results
16 of many of these reviews. We independently checked that,
17 verified the licensee was making proper use of 91.18, the
18 degraded nonconforming conditions, and ultimately was
19 satisfied that the restart checklist that they were using
20 was defensible and critical safety concerns had been
21 resolved.
22 The licensee did mention that they are still
23 addressing high-energy line break issues, and they have a
24 process in place that we have been looking at. And they're
25 also looking at their motor-operated valve program, and
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1 making changes there.
2 Should a USQ arise, then perhaps there would be
3 the need for an amendment, but we are monitoring those two
4 areas very closely. And right now, we don't see the need to
5 perform an independent technical review.
6 COMMISSIONER DIAZ: Okay, so you're pretty
7 confident that process worked sufficiently, so that there
8 will be no surprise. You know we got a surprise with
9 Millstone at almost the very end.
10 MR. ZWOLINSKI: Commissioner, I had the
11 opportunity to work on Salem, to work on Crystal River.
12 COMMISSIONER DIAZ: That's right.
13 MR. ZWOLINSKI: And now Cook, and I see the same
14 process being implemented three times, so I'm becoming
15 fairly familiar with it.
16 I want to retain that arm's-length, and
17 questioning the attitude, but it appears that this facility
18 has quite a bit of design margin. They share this with ius,
19 and we verify that.
20 Our analysis during licensing reviews shows
21 margin. So, yes, I feel that we're certainly on the right
22 track and have handled the licensing amendments
23 appropriately.
24 As far as the licensee's activities, their
25 discovery programs seem to be very extensive, and our
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1 inspectors were ultimately able to conclude that the program
2 was, indeed, aggressive.
3 So the summary of the headquarters look, as well
4 as the inspection look, appears to have given this licensee
5 the marks that they've requested as far as mimicking the
6 other licensees.
7 COMMISSIONER DIAZ: Okay, and now the same
8 question on the rest of the issues, Jim?
9 MR. DYER: Well, from the inspection standpoint,
10 Commissioner, I think --
11 COMMISSIONER DIAZ: Including human performance,
12 if you please.
13 MR. DYER: I think from the inspection standpoint
14 certainly in the discovery phase when we invested 3000 hours
15 of direct inspection, that is five FTE that we delivered
16 when observing their inspection -- excuse me, observing
17 their discovery phase, independently validating it, and then
18 watching their process for making sure that those actions
19 got into the corrective action process.
20 That is a phenomenal amount of inspection and we
21 used again, and I'll echo the presentation, we used our very
22 best inspectors. We went through and identified ahead of
23 time our best senior resident inspectors. I worked with the
24 other regions to get talent from the other regions as well
25 as from Headquarters. We paid top dollar to get the top
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1 contractors to come out and support our inspection effort,
2 and so that 3000 hours of inspection effort really wrung out
3 their overall processes and did our own independent
4 validation to identify it.
5 Jack can correct me if I'm wrong, but there was
6 essentially no surprises during our inspections. There was
7 a couple of more minor issues and that, but there was
8 nothing that was a show-stopper or anything that would jump
9 up on our radar screen through the discovery phase.
10 The human performance was part of that. We had
11 done an operator training inspection. Earlier some of the
12 EOPs and the procedure issues or concerns we found that the
13 licensee has essentially set standards higher than ours and
14 is out trying to implement them, and we haven't -- we have
15 gone in in very much a confirmatory role.
16 MR. GROBE: Just to echo and expand on a couple
17 things that Sam and Jim have said, we took a different
18 approach at Cook, and that was to be more in process to
19 avoid, as Jim said, shooting any air balls at the last
20 minute. We didn't want to have a repeat where they finish
21 their discovery phase and we came in and did some
22 inspections and concluded it was inadequate. That would
23 have been a failure obviously on Cook's part but also on our
24 part, so we performed oversight in process, first as they
25 developed their programs, as soon as they had a program
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1 developed we provided immediate comment on that, and we did
2 provide comments that enhanced the quality of the program.
3 It was a good program. The program included as a
4 starting point identifying the key functions that each
5 safety system served, so it started from that as a
6 foundation, then going to identify what design documents
7 existed, and in approximately 40 percent of the cases they
8 couldn't find the documents, and then they had to
9 reconstitute those.
10 I had three Staff that were onsite supplementing
11 the resident team essentially full time for about three
12 months. As each step was taken by the licensee, we would
13 provide critical oversight and feedback.
14 As Jim indicated there were no show-stoppers in
15 our inspection findings. We made findings, had good folks
16 out there looking, and then at the end confirmed with two
17 independent SSFIs of two safety systems to ensure that we
18 had thorough oversight.
19 COMMISSIONER DIAZ: Okay, Mr. Chairman, one tiny
20 question with a very short answer, and it is directed to the
21 licensee.
22 We sometimes, you know, the Staff gets between a
23 rock and a hard place. They are too intrusive or they are
24 not intrusive enough and it appears by getting in process
25 that some improvements were made to the process.
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1 Do you agree or disagree with the Staff assessment
2 that being in process was helpful?
3 DR. DRAPER: Oh, we absolutely agree that that was
4 a helpful move.
5 COMMISSIONER DIAZ: Thank you.
6 CHAIRMAN MESERVE: Commissioner McGaffigan.
7 COMMISSIONER McGAFFIGAN: One quick question, and
8 then perhaps one slightly longer.
9 Mr. Dyer, you said that you have a Staff
10 recommendation to lift the CAL under consideration. How
11 long is that review going to take, or is that imminent, your
12 decision on that?
13 MR. DYER: I believe it will happen -- we get back
14 this week --
15 [Laughter.]
16 COMMISSIONER McGAFFIGAN: If we let you guys do
17 your work --
18 MR. DYER: Well, yes. The Staff's recommendation
19 is the inspectors that were inspecting all the individual
20 items have agreed that the nine items and we closed out the
21 bounding issue as part of the discovery inspections, then we
22 had the nine specific issues.
23 There was one for NRR evaluation, which I believe
24 was the last one in NRR inspections that exited last week,
25 closed out all the issues.
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1 COMMISSIONER McGAFFIGAN: The more philosophical
2 issue, just to go back to this oversight issue, all the
3 hypotheticals we are asking about oversight which may be
4 more appropriate to our March Commission meeting than today,
5 but since D.C. Cook is in front of us, the new oversight
6 process, would the PIs have caught D.C. Cook?
7 If you have a broken Corrective Action Program,
8 will our Corrective Action Program inspections catch D.C.
9 Cook, would they have, or is it the design inspections?
10 By having the PIs, we are freeing up resources to
11 do modules that we didn't do before. Is it the design
12 inspection that would have caught D.C. Cook? Just
13 hypothetically, you know, David says, Mr. Lochbaum says if
14 properly implemented we will catch the D.C. Cooks next time.
15 I am not as sure, because I am not sure how the significance
16 determination process gets you white and yellow findings on
17 things like broken Corrective Action Programs and broken
18 design bases, and so that is my question.
19 MR. DYER: From my perspective, it can, and we
20 need to make it. That's my mindset.
21 COMMISSIONER McGAFFIGAN: My mindset too, but you
22 have to be able to analytically be able to show that at some
23 point.
24 MR. DYER: And I think the question we are still
25 wrestling with too, and Sam probably could speak to this, is
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1 the cross-cutting issues, and how we find those things.
2 I don't know whether or not the PIs would have led
3 the Corrective Action Program or the design inspection. We
4 have all three of those tools. When we get to our PPR
5 process, we need to be able to put it together and come up
6 with the conclusions much sooner.
7 MR. GROBE: If I could just correct some
8 information that was alluded to earlier.
9 The benchmarking that was done earlier this
10 year -- excuse me, last year -- of the new safety
11 determination process, significance determination process,
12 utilized the findings that came from Cook following
13 shutdown, looked at all of those findings and concluded
14 there would have been actually several red findings had
15 those issues been identified.
16 Cook was a well operating plant prior to the
17 shutdown. It operated reliably and they were a middle-of-
18 the-road performer as far as our inspection findings were
19 concerned.
20 DR. TRAVERS: But I think the sorts of findings
21 you are talking about are not performance indicators as much
22 as they are design basis issues that have subsequently --
23 COMMISSIONER McGAFFIGAN: So it's really design
24 basis --
25 DR. TRAVERS: So I think corrective actions and
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1 design basis issues are the ones that I think of the Cook
2 experience as the ones embodied in the oversight program in
3 addition to the PIs.
4 COMMISSIONER McGAFFIGAN: And the SDP did pump out
5 even red findings?
6 DR. TRAVERS: Yes.
7 COMMISSIONER McGAFFIGAN: Once you got them?
8 Okay.
9 MR. COLLINS: I am very careful with absolutes,
10 and I am perhaps not quite as optimistic as maybe some of
11 our other stakeholders who have been at the table, because I
12 think some of this has yet to play out, as well as the
13 licensee's involvement.
14 We have to realize that the licensee plays a major
15 role it --
16 COMMISSIONER DICUS: It's critical.
17 MR. COLLINS: -- in ensuring that their internal
18 Corrective Action Program, which I believe NEI would
19 acknowledge has to be sharpened up in order for the
20 oversight process to work appropriately, the self-
21 assessments, the peer reviews, there is a dual burden here.
22 Our process needs to drive it. We need to
23 understand licensees' capability and their processes, but
24 there are also obligations on the licensees' end.
25 The same for those remaining issues before plant
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1 restart. This is a status briefing. The plant is not ready
2 to restart. The process has to play out. We do have an ASP
3 finding, high energy line break, that the Office of Research
4 is providing support as they have throughout the restart
5 process, and discovery will continue in some important areas
6 by licensees -- not in new areas, but as far as the extent
7 of condition.
8 What we have to be comfortable with is that the
9 NRC processes in place, 03.50 oversight process and
10 inspection and licensing, will be able to respond to those
11 licensees' findings through the remainder of the restart
12 process and come to appropriate regulatory decision. I am
13 confident in that.
14 CHAIRMAN MESERVE: Commissioner Merrifield.
15 COMMISSIONER MERRIFIELD: Yes, I have three quick
16 questions, I think. They probably all can be answered with
17 a yes or no.
18 During your presentation you discussed a variety
19 of the problems that were identified at D.C. Cook and the
20 efforts underway by the licensee to resolve those as part of
21 its corrective action.
22 Are you confident the licensee has taken the steps
23 necessary to address the root causes of the problems
24 identified in the plant so that they do not, these problems
25 of this nature don't reoccur in the future?
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1 MR. DYER: Yes, sir.
2 COMMISSIONER MERRIFIELD: We at this point have
3 had a lot of focus on Unit 1. My sense is at least from
4 what I have heard so far is many of the performance and
5 programmatic problems at the plant were common to both
6 units.
7 Are we taking steps necessary to review our
8 inspection efforts relative to Unit 2 so we can reduce our
9 inspection efforts as it results to Unit 1 going forward?
10 MR. DYER: Jack, I'll let you --
11 MR. GROBE: Yes. The first unit is actually Unit
12 2. It is backwards this time, but the programmatic issues
13 that are corrected for Unit 2 restart are also going to be
14 valid for Unit 1 restart.
15 We have already started mapping out the inspection
16 that we believe is necessary for Unit 1 restart. It will be
17 substantially less than what we have done in Unit 2 and we
18 will primarily focus on the more significant engineering
19 modifications and verification that those were performed
20 correctly and then the similar inspections to what we are
21 doing now going forward on system return to service and
22 preparation of the operators for operating two units
23 simultaneously safely.
24 COMMISSIONER MERRIFIELD: My final one is do we
25 have any NRR or Region III resources dedicated to restart or
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1 on the licensing efforts so that these efforts can be
2 carried out in a timely manner?
3 MR. DYER: The answer to that is no, but we do
4 have sufficient resources within the agency, and that is the
5 way -- I view as the agency focus effort for D.C. Cook to
6 get resources from the other regions as well as NRR, so
7 collectively as an agency we do have the resources for
8 restart but we are beyond the regional level.
9 MR. COLLINS: I think this is a good example of
10 the teaming aspect where Region II I think in particular, as
11 a result of the performance of their plants in that region,
12 has provided a significant amount of resources, the other
13 regions also, but Region II particularly.
14 MR. DYER: Yes, sir.
15 COMMISSIONER MERRIFIELD: Thank you.
16 CHAIRMAN MESERVE: Thank you very much.
17 On behalf of the Commission, I would like to thank
18 American Electric Power, Mr. Lochbaum, and the NRC Staff for
19 providing a very thoughtful and helpful briefing.
20 It is clear that AEP faced a daunting challenge at
21 D.C. Cook and hopefully they are well on their path to its
22 resolution. It is also clear that the NRC Staff, and I am
23 referring here to resident, regional and Headquarters staff,
24 have played an integral part in reaching a solution here,
25 and I would like to thank you all.
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1 [Whereupon, at 12:33 p.m., the briefing was
2 concluded.]
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