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UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
***
BRIEFING ON OPERATING REACTORS
AND FUEL FACILITIES
***
PUBLIC MEETING
***
U.S. Nuclear Regulatory Commission
One White Flint North
Rockville, Maryland
Tuesday, June 25, 1996
The Commission met in open session, pursuant to
notice, at 10:00 a.m., Shirley A. Jackson, Chairman,
presiding.
COMMISSIONERS PRESENT:
SHIRLEY A. JACKSON, Chairman of the Commission
KENNETH C. ROGERS, Member of the Commission
GRETA J. DICUS, Member of the Commission
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STAFF SEATED AT THE COMMISSION TABLE:
JOHN HOYLE, Secretary of the Commission
KAREN D. CYR, General Counsel
JAMES TAYLOR, EDO
WILLIAM RUSSELL, Director, NRR
DR. CARL PAPERIELLO, Director, NMSS
THOMAS MARTIN, Region I Administrator
HUBERT MILLER, Region III Administrator
STEWART EBNETER, Region II Administrator
JOE CALLAN, Region IV Administrator
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P R O C E E D I N G S
[10:00 a.m.]
CHAIRMAN JACKSON: Good morning, ladies and
gentlemen -- maybe I should say gentlemen here at the table
but we have a few ladies. I am pleased to have the
Headquarters Staff and the Regional Administrators here this
morning to brief the Commission on the results of the recent
NRC Senior Management review of performance at operating
reactors and field facilities.
The senior management meetings are conducted semi-
annually to ensure that the NRC is properly focusing its
resources on facilities that need the most regulatory
attention based on licensee performance and on related
issues of greatest safety significance.
I understand that copies of the slide presentation
are available at the entrances to the meeting room.
Do my fellow Commissioners have any comments at
this time?
[No response.]
CHAIRMAN JACKSON: If not, then Mr. Taylor, please
proceed.
MR. TAYLOR: Good morning. With me at the table
are the four Regional Administrators and the Directors of
the Office of NRR and NMSS.
As the Commission knows, the senior management
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meeting process was initiated in 1986 in response to the
loss of feedwater event at the Davis Besse plant which had
occurred that previous June. This was the 21st such meeting
of NRC senior managers. Although we have refined the
process and the analysis used in support of the meetings,
the discussions have continued to focus on the safety of
operational performance of selected plants across all
regions.
I'll ask Bill Russell to continue with a formal
presentation.
MR. RUSSELL: Thank you, Jim, Commissioners.
Senior management meeting process has two
principal objectives as it relates to nuclear power plant
performance. First is to identify potential problem
performance and adverse trends before they become actual
safety events, and secondly is to effectively utilize agency
resources in overseeing operating reactor safety.
An integrated review of plant safety performance
is conducted using objective information such as plant
specific inspection results, operating experience,
probabilistic risk insights, systematic assessment of
licensee performance reports, performance indicators, and
enforcement history.
Special attention is given to the effectiveness of
licensee self-assessments and the effectiveness of
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corrective actions taken for problems identified by
licensees.
Our objective is to identify facilities early that
have negative performance trends or those that have
performance problems which require agency-wide close
monitoring and oversight.
We also discuss for each of these facilities plant
inspection activities, NRC management oversight, and
allocation of resources for each of the plants discussed.
I'll summarize the overall results of this recent
senior management meeting after which the Regional
Administrators will discuss the facilities in turn that are
in need of agency-wide monitoring and attention.
May I have the first slide, please?
COMMISSIONER ROGERS: Mr. Russell, just before you
go into that, are there any standard criteria that you use
to determine what plants are going to be discussed at the
senior management meeting? You can't discuss every plant,
obviously, or you'd still be there, and so do we have a
fixed set of criteria or is this a choice that is made by
individual Regional Administrators?
MR. RUSSELL: The process that's used is that I
conduct meetings prior to the senior management meeting
approximately six to eight weeks before the senior
management meeting occurs with each Regional Administrator
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at which we discuss each of the plants in the region, such
that all the plants in the U.S. are reviewed and discussed.
At that meeting we have representatives from NRR,
from AEOD, as well as the region, and we go over the
specific information that is collected to support the plant
performance reviews which are conducted by the regions so
that we have the site issues, matrices for each of the
plants. We have the results of the plant performance
reviews. We also have the agency-wide performance
indicators where we look for trends.
We look at enforcement history.
I must mention that Jim Lieberman also
participates in those meetings.
We go through with a discussion for each facility.
We typically identify more facilities for
discussion at the senior management meeting than actually
are identified as potential problem facilities because there
may be some other aspect of that particular plant's
performance which should be shared amongst other Regional
Administrators so that we can collectively reach judgments
on what are the appropriate actions to take.
We don't have numerical or explicit criteria to
use. It's essentially a judgment between the Regional
Administrator and myself as to whether this is an
appropriate facility to bring forward to discuss, so we err
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on the side of having a lower threshold for discussion such
that we can share experiences but it is intended to be a
systematic review of all facilities.
We then go the next step and develop the detailed
information to support the senior management meeting review
following those meetings so we identify candidate facilities
and then the Staff prepares all the information to support
the senior management meeting process --
COMMISSIONER ROGERS: Excuse me --
MR. RUSSELL: I'm sorry --
COMMISSIONER ROGERS: -- what I am trying to get
at is whether you have any sense of the numbers of plants
that should be discussed in everybody's opinion at a senior
management meeting, whether that is kind of stable,
increasing, decreasing. If you don't have a fixed set of
criteria, it may be difficult to, you know, get any numbers.
MR. RUSSELL: We can get you the actual numbers
but I would expect that for -- by sites it's probably on the
order of eight to ten sites that are discussed each time and
probably on the order of 18 to 22 plants, although at the
most recent meeting was a longer meeting than some of the
past ones. We had more facilities to discuss at this last
one.
COMMISSIONER ROGERS: So we really don't have a
feeling that there is a trend in either going up or down in
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the number of plants you feel should be discussed?
MR. RUSSELL: Not in the context of discussing to
exchange information amongst the senior managers as it
relates to plants for which we take action and conclude that
they are problem facilities and warrant agency-wide
monitoring.
We do trend those and that's one of the indicators
that we use each year in our regulatory information
conference.
CHAIRMAN JACKSON: I think Commissioner Dicus has
a comment.
COMMISSIONER DICUS: I get a sense from your
comment that perhaps you don't think there should be set
criteria or the process somewhat formalized. Would that be
a fair statement?
MR. RUSSELL: That is correct. At this point I
believe it is appropriate to err on the side of discussing a
plant, sharing the information about that plant.
The impact is essentially one on the Staff to
develop the information, to go through, collect it,
synthesize it, and put it together so there is some resource
burden but I believe the value of having had the discussion
amongst the other Regional Administrators, sharing that
information, and bringing the senior management perspectives
to bear on a particular facility are worth the additional
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Staff effort, so at this point in time we are leaving it
more as a judgmental and we have generally reached
agreement, although there have been some cases where we have
had some close calls and then we have erred on the side of
going ahead with the discussion rather than not discussing.
COMMISSIONER DICUS: I guess I would have a little
bit of concern, and I think you make a good point -- I would
have a little bit of concern over time, over years of some
consistency on how we're looking at plants without some
values that are set.
CHAIRMAN JACKSON: Well, in fact, I think,
following on the previous meeting on the senior management
meeting process, the Commission specifically asked the Staff
to come back to the Commission with a methodology that
showed more objectivity and that would ensure consistency
among the regions with respect to the criteria for judging
the placement of plants.
That doesn't get to, you know, which plants are
discussed, but once the plants are being discussed how in
fact the determination is made as to which ones should be on
the problem plant list, and in fact I reinforced that
recently relative to the most recent one that by the next
senior management meeting the managers are to come back to
the Commission with these issues in fact addressed.
MR. RUSSELL: If I could have Slide Number 2,
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please?
Category 1 is for plants that are being removed
from the problem plant list where they have shown sustained
performance improvement and no longer warrant agencywide
monitoring and can revert back to the routine monitoring by
the region.
We have one facility in this category and that is
Browns Ferry Unit 3.
CHAIRMAN JACKSON: That means that all the other
plants that we don't give more than the routine monitoring
to are, by definition, in Category 1; is that correct?
MR. RUSSELL: That's correct.
CHAIRMAN JACKSON: Okay.
MR. RUSSELL: The reason we carry it as a Category
1 is we also, as an internal procedure, continue to monitor
the performance of that facility for the next two senior
management meetings to ensure that the performance is in
fact sustained and that the judgments were correct when we
took the action to remove the facility from the list. So
Browns Ferry Unit 3 will be discussed at the next two senior
management meetings with the information developed and it
will be a status plan so that we keep our eye on the
facilities after they have been taken off to continue to
trend their performance.
If I can have Slide Number 3, please?
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Category 2 facilities are those plants whose
operation is closely monitored by the NRC. These facilities
are Indian Point 3, Millstone 1, 2 and 3 and Dresden 2 and
3. Tim Martin will discuss Indian Point 3 and Millstone and
Hub Miller will discuss Dresden when we come to the
discussion of the actual facilities.
Next slide, please.
CHAIRMAN JACKSON: When you do that, and this is
preempting the next slide to some extent, I would appreciate
a discussion about Millstone in terms of its being Category
2 and not Category 3, since all of the Millstone units are
shut down and that we are minimally requiring certain
information in response to the 50.54(f) letter before they
can restart and there would be a list of issues. I think
you are going to be treating them in a particular way, so I
am interested in how that categorization has been done.
MR. RUSSELL: Okay.
Category 3 facilities are plants which are shut
down and require Commission authorization to operate. There
are no plants in this category and the distinction is a
formal Commission vote prior to restart of a facility. Our
intention is to clearly keep the Commission informed of the
Staff's activities associated with monitoring, preparation
for restart and the appropriateness of restart, would expect
that there would be briefings of the Commission. But we did
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not propose to make this a Category 3 facility.
Obviously, if the Commission wishes to formally
vote on restart of these matters, we could certainly change
to reflect that. This was intended to provide both
oversight and some flexibility in the process, depending
upon what the time schedules are for restart. The intent is
not to let any of the facilities restart until such time as
they have adequately responded to the 50.54(f) letters, have
identified the particular issues that need to be addressed
and we have reached agreement on which ones are necessary
for restart and which ones may be deferred. That process is
ongoing and Tim will be talking about some of those elements
in his briefing.
The next slide, please?
This is a new change for our process. Browns
Ferry 1 is the only remaining Category 3 plant before this
last senior management meeting. We chose to remove it from
the Category 3 listing because it is defueled and it is in
long-term lay-up.
The Tennessee Valley Authority currently has no
plan for equipment refurbishment or recovery activities for
Unit 1-specific equipment. They are maintaining equipment
at Unit 1, which supports Unit 2 and 3 operations. Should
TVA decide to restart this unit in the future, Commission
approval would be required prior to plant startup.
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Stu Ebneter will discuss Browns Ferry 1 and Browns
Ferry 3 and I will ask him to start the briefing. Then I
will go to Region One with Tim discussing Indian Point and
Millstone followed by Hub Miller discussing Dresden 2 and 3.
CHAIRMAN JACKSON: Just a point of information for
my edification. How then are you going to be categorizing
Browns Ferry 1? I understand the point here, because it is
basically in long-term lay-up. But how do you carry it on
the books?
MR. TAYLOR: We won't categorize it. We have a
commitment from TVA that, should they change plans, they
will tell us and at that time we would come to the
Commission and say -- we will restore it to that category
and come to the Commission and for formal approval. It is
almost putting it in abeyance rather than just carrying it.
That's the idea.
MR. RUSSELL: Rather than reporting on the status
each month.
We would follow the Agency's Manual Chapter 350
process for restart of a plant that is in an extended
shutdown. We would go through the same approaches, make
sure that the plans and procedures which we have found to be
successful in restart of Units 2 and 3 are, in fact,
implemented so there should not be new licensing or
technical issues. It is more a matter of executing those
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plans and there are significant resource implications for
the company and it is really a financial decision that they
have based their deferral on at this point in time.
CHAIRMAN JACKSON: Right, and that is why I bring
you back to if you are going to be discussing the Region One
plants, the Millstone plants because my understanding is
that the Staff has determined that the restart of all of the
Millstone units should be evaluated under Manual Chapter
350.
MR. RUSSELL: That is correct.
CHAIRMAN JACKSON: And in addition, each unit is
required to respond to a 50.54(f) letter and so it seems to
me that you, de facto, characterized it as Category 3 except
for leaving out the specific Commission approval requirement
which we can discuss.
MR. RUSSELL: That's correct. That's basically
correct. We wanted to provide that flexibility to the
Commission to decide how they wished to handle the specifics
on Millstone.
With that, Stu, if you could proceed.
MR. EBNETER: All right. Good morning.
Browns Ferry. Browns Ferry is a three-unit
boiling water reactor owned and operated by Tennessee Valley
Authority. All three units were placed on the Problem Plant
List as Category 3 units in October of 1986. Unit 2 was
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restarted in May of 1991 and has run well since then. Unit
3 had been in recovery, based on the successful recovery
plan of Unit 2, and it was authorized by the Commission to
restart on November 15, 1995. The restart and power
ascension program was conducted in a deliberate, methodical
manner. No major problems were encountered and it was
successfully concluded in mid-December of 1995.
Unit 3 was reclassified to a watch list Category 2
plant at the January 1996 senior management meeting. Browns
Ferry operations since January has included dual unit
operation with Units 2 and 3 operating simultaneously at
power and a Unit 2 outage concurrent with Unit 3 operations.
TVA has successfully demonstrated the ability to operate the
integrated station with a minimum of unit interactions. The
transition from recovery to operations has been successfully
completed for Unit 3.
Dual unit operations can be characterized as
effective management involvement in all phases of operation
and a proactive self-assessment program which identifies
potential problems early. Corrective actions have been
prompt and extensive in nature. The TVA staff demonstrated
the effectiveness of the training program and exhibited a
good safety attitude.
Procedure adherence was relatively good. Unit-
to-unit communications has minimized interface problems and
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response to transients was good.
Engineering and maintenance support to operations
has been effective and were a major contributor to
operational performance and achieving low backlogs in these
areas. A lower threshold for problems is apparent at the
station. Attention to evaluation reports has increased
sensitivity to problems and ownership of problems is now
apparent in maintenance and engineering.
Browns Ferry operations are good but performance
is not completely free of equipment failures and personnel
errors. For example, the equipment failures include some
wear-related malfunctions of swing check valves and balance
of plant systems. Although TVA's response to the failures
were prompt and effective, the problems should have been
anticipated based on industry operational experience.
The number of personnel errors has not been
excessive and consequences have not been severe but the
causes of these errors indicate the need for additional
focus on configuration control and communication to achieve
further performance improvements.
Our conclusion with regard to Unit 3 is that
station performance is at a level where NRC oversight can be
accomplished at the current regional level. Thus, Browns
Ferry 3 has been classified as Category 1 on the watch list.
Let me briefly discuss Unit 1.
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Unit 1 is shut down and defueled and has been a
Category 3 unit since October of 1986. It is noted in a TVA
letter dated April 16, 1966, TVA does not have a formal
schedule or plan for returning Unit 1 to service. Most of
the Unit 1 systems are in lay-up and are being preserved
adequately. There are a few that support Units 2 and 3
operations as a result of the design flexibility of the
station. TVA stated in their letter that it would maintain
these Unit 1 systems in service commensurate with their
importance to safety, even though there are no current plans
for Unit 1 recovery activities.
The senior managers decided not to identify Unit 1
as a Category 3 because of TVA's uncertainty with regard to
the future of the unit. However, the removal from the watch
list is conditioned on receiving Commission approval prior
to resumption if TVA decides to resume restart activities.
If TVA decides at some future time to restart recovery, they
have committed in the April 16th letter to implement the
same programs used for the recovery and restart of Unit 3.
The Unit 1 would not restart, again, they have a
commitment, without prior Commission approval. They further
committed to follow applicable NRC regulations governing
decommissioning activities should they decide to pursue
decommissioning. And that's the extent of my presentation.
CHAIRMAN JACKSON: The question I have for you,
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Mr. Ebneter, is the following:
We have had circumstances in the past where plants
have been on the watch list, have come off, and have gone
back on, and we have given Browns Ferry 3, you know, very
close scrutiny, obviously, for a long time, and so I guess
the question I -- the only question, really, is I guess it
was given permission to restart in November and this is
June, about 7 seven months later, and so it is your judgment
and the judgment of the senior managers collectively that it
has operated long enough that and you have enough signs for
a longer period of time, long enough period of time, that we
can feel comfortable doing this? That we don't think there
will be a slip-back?
MR. EBNETER: Yes, I believe so. Unit 1 has
operated for several years. I think we needed a little more
assurance and confidence that they could operate two units
simultaneously, but that has been well accomplished.
MR. RUSSELL: You said Unit 1; you mean Unit 2.
MR. EBNETER: Excuse me. Unit 2 and Unit 3.
So I think we have adequate confidence in that
area.
I might add I said good morning to Mr. Kingsley
this morning, and he seemed to be quite happy. He said he
believes that this is his very last meeting at the
Commission.
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[Laughter.]
CHAIRMAN JACKSON: Then I would say that Mr.
Kingsley doesn't plan to come back to see us any more?
MR. EBNETER: That's right. And I have taken that
as a commitment on the record that he will not be back.
Well, he is going to voluntarily come and see us, we are
sure.
[Laughter.]
MR. RUSSELL: Dr. Jackson, also, as I mentioned
earlier, we will continue to monitor at the senior manager
level the performance of the Browns Ferry Station for the
next two senior management meetings so that it will continue
to receive senior management oversight, even though the
resources and the planning activities will be conducted by
the region.
CHAIRMAN JACKSON: Okay. You mentioned that
procedural adherence was relatively good. What did that
qualification mean?
MR. EBNETER: Well, it means relative to --
relatively good. Good is, you know, in the SALP 2 type
category; lots of room for improvement; not especially bad,
but they clearly can do much better at it. We have had
numerous examples of valve line-up switch placement and some
of that is contributed to by inadequate procedures. So they
can work both on the procedural aspect and the human
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performance together. But it's not -- not really bad.
CHAIRMAN JACKSON: Okay. Well, I have gotten used
to seeing Mr. Kingsley, but I would just as soon not see
him.
[Laughter.]
CHAIRMAN JACKSON: Mr. Rogers, any questions?
COMMISSIONER ROGERS: No.
CHAIRMAN JACKSON: Okay.
MR. RUSSELL: I assume then we can proceed with
Indian Point.
MR. MARTIN: Chairman, Commissioners.
The New York Power Authority Indian Point 3
nuclear power plant was first discussed during the June 1992
senior management meeting. Concerns were identified in the
area of procedural adherence and attention to detail,
surveillance testing and corrective action programs,
engineering tech support, information flow, facilities, and
site and corporate management guidance, oversight and
control.
In February '93, the New York Power Authority shut
the plant down in response to concerns of the operability of
their anticipated transient without scram system.
Subsequently, NYPA, the New York Power Authority, took the
plant to cold shutdown and committed to not restart the unit
until the plant had been resolved and NRC agreed to plant
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restart.
Indian Point 3 was placed on the NRC's watch list
in June of '93. After the February '93 shutdown, NYPA
expended significant effort and resources on equipment
maintenance modifications, process improvements and
management changes. NYPA restarted the plant in June '95,
after the NRC agreed that Indian Point 3 was ready to
restart.
In September of '95, in response to an electric
generator cooling system leak, the plant was shut down. The
plant has remained shut down until early April of this year
to repair an evolving list of identified equipment problems
and performance deficiencies, the latter principally
associated with three operational events.
The list of equipment problems reflects in part
NYPA's improved threshold for identifying and resolving
issues, and includes the residual heat removal system check
valves, residual heat removal pump seals, the Appendix R
emergency diesel generator, well channel and containment
pressurization system, and containment fan cooler service
water system.
The three events of concern evidence weakness in
operation, department staff performance, and included the
July operation that reduced pressure, the October heat-up
with inoperable equipment, and the December component
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cooling water leak inside containment.
The underlying performance deficiencies revealed
by these three events demonstrated continuing weaknesses in
the team work and communications, operations staff knowledge
of the licensing basis, procedural adherence, attention to
detail, and a questioning attitude.
These continuing weaknesses illustrate the mixed
effectiveness of past corrective actions.
Finally, the volume of emergent work activities
during the outage appeared to hamper NYPA's ability to focus
on implementing the planned process and procedural
improvements and address the longer term issues that could
enhance equipment reliability and organizational
performance.
In response, I wrote to NYPA in December '95,
requesting that they describe their actions, planned or
taken, to address these concerns. I also requested the
basis that they would use to determine that these actions
were sufficient to arrest the performance weaknesses and
assure the material condition of the facility and staff
performance were sufficient to support safe restart of the
facility.
Since the last senior management meeting, NYPA
implemented extensive equipment maintenance activities and
staff performance enhancements, made several senior
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management changes, and revitalized their operations
procedure upgrade program.
Management also undertook significant additional
effort to better communicate performance expectations,
particularly in the area of procedural adherence, and
enhanced observation and assessment of the shift crew
performance using oversight personnel and outside shift
mentors, as was done during the earlier successful restart
program.
In late January '96, a loss of offsite power event
occurred as a result of the failure of a transformer
lightning arrestor. Operators generally responded well to
the event and pursued a conservative approach to restoring
power to the facility. The event also revealed a diesel
generator breaker that failed to close because of a loose
wire and a ventilation damper that did not operate properly
on a separate diesel.
The licensee responded appropriately to both
material problems.
The NRC has been concerned about the decline of
the material condition of the facility since the restart in
June of '95. There has been a growing maintenance backlog
and a number of material failures that challenged the plant
operators. Some of the more notable equipment failures
include the failures discussed in the January loss of
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offsite power, a steam generator handhold steam leak, and a
charging line leak that required operators to cool down the
facility in March '96.
Additionally, one auxiliary feedwater pump motor
required replacement. It is worthy to note that as material
problems have occurred, the licensee has taken a
comprehensive approach to repairing the specific failure as
well as performing extensive reviews of the extent of
condition to prevent similar problems in other places in the
plant.
Also the licensee has recently made progress in
reducing the backlog of the maintenance of the plant.
In response to the equipment and staff performance
concerns, the NRC conducted a special inspection starting in
late January to verify the implementation of licensee
corrective actions and to assess their effectiveness.
The NRC also reviewed the resolution of recent
equipment problems, including the loss of offsite power
event, as well as observing operator activities over a five-
week period.
The team concluded that operation performance was
improved and satisfactory to support safe restart of the
plant. Improvements were observed in the area of shift
turnover, logkeeping, adherence to plant procedures, and
training. Some self-assessment activities, such as the
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shift mentor program and the integrated assessment of plant
deficiencies, were considered a strength.
However, weaknesses were also identified in
several areas, including adherence to administrative
procedures and the identification and resolution of material
condition deficiencies.
After completing all required maintenance and
training, the licensee restarted the facility in early April
'96. The NRC conducted augmented, around-the-clock
inspection coverage during the restart and power ascension
process.
The inspection activities, coupled with the
resident inspection findings during the power operations in
April and May, noted that overall performance during the
start-up and return to service was good, with generally good
operator rounds, procedural adherence, communications and
conservation decision-making.
However, several examples of failing to adhere to
procedural requirements indicated the need for continued
emphasis in this area.
A manual reactor trip was initiated during the
start-up due to the inadequate venting of a generator
hydrogen cooler. Extensive corrective actions for
preventing a recurrence of this problem were implemented,
and the start-up recommenced several days later.
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Since the restart of the plant in early April,
operations has been characterized as conservative and well
controlled. Engineering support to the plant in response to
several emerging technical issues has been good. The plant
has operated at full power since early April, with the
exception of a rapid plant shutdown on May 20th when a
fitting on an air line to an actuator for one of the main
steam isolation valves broke as it was being tightened to
repair a control air leak.
While NYPA management and NRC question the control
and conduct of maintenance work at power, operator and
maintenance performance during the shutdown was good. The
plant was subsequently returned to power two days later
without any major equipment problems emerging, a sharp
contrast to the long series of equipment problems
experienced during the previous forced outage.
On June 9th, the control panel door for the 32
hydrogen dryer blew off due to a small hydrogen explosion.
No one was injured in the event, which occurred in the non-
nuclear side of the plant in the main turbine building. An
investigation into the cause for the hydrogen leak is
continuing. Plant operations was not impacted by the
explosion, and the licensee intends to replace both hydrogen
dryer units.
In summary, the facility was successfully
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restarted in April '96 and was subsequently operated in a
generally safe and conservative manner. However, continued
strong NYPA senior management involvement, support and
oversight is warranted to sustain the improving trend in
personnel performance and plant material conditions.
Therefore, the NRC will continue to closely
monitor the programs and activities at the facility and
Indian Point 3 will remain on the watch list as a Category 2
facility.
Any questions?
CHAIRMAN JACKSON: Yes. I have recently visited
this particular facility, and what I always say -- I'm
drawing on a popular movie -- you know, excellence is as
excellence does. And so many licensees talk about various
programs for excellence, but you in a sense have given us a
litany of events and problems. And so the question becomes
net, net, are they really getting their hands around the
panoply of issues, particularly as they relate to material
condition and equipment reliability. Are they being
successful in identifying non self-revealing problems; that
is, to what extent are they really identifying problems that
aren't event or incident driven.
You mentioned that when there have been problems,
they've jumped on those problems and thought about the
implications more broadly; but the real question becomes
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getting ahead of the curve.
So perhaps you could make a few comments relative
to that.
MR. MARTIN: Chairman, you've focused on the two
principal questions that are at root to our concerns at
Indian Point.
First of all, you are absolutely correct that when
a problem is identified, they seem to deal with that problem
well and to expand the scope of their investigation to cover
like situations where they have identified some other
problems and have fixed them.
Since the June '95 startup, the amount of emergent
work that has come on their plate has delayed looking at
more longer term items that would focus on equipment
reliability. I'll give you some examples.
The system engineering group, which is largely
responsible for trending performance that would give you
indications it's time to intercede really haven't been able
to focus on those activities; and as a result, we're having
a meeting with them tomorrow on how they intend to move into
the maintenance rule and how they intend to assure the
equipment reliability can support plant operations.
They have some, I think it's ten systems that are
A1 systems that have not met their reliability goals, and
that's, you know, early information. At the same time, we
. 29
do not see a robust predictive maintenance program in place.
So at this point, the frequency of new challenges
is dropping off, but each week seems to reveal something
that a more robust trending program or a predictive
maintenance program might have identified and allowed them
to find it, things like the loose wire on the diesel
generators, the problems we've seen with the dampers, the
hydrogen dryer. I mean, there are things that could have
been done that could have intercepted those earlier.
Now, they have that on their plate, they
understand it's on their plate, they intend to deal with it,
but we're concerned about the challenges to operators, and
this is clearly something that is going to have to be done
before we're ready to take them off the problem plant list.
CHAIRMAN JACKSON: Well, you know, they were shut
down for an extended period, and the question then becomes,
to me, how many of these things are things that could have
or should have been identified at that point, or how many of
them require operation at power to reveal themselves, and
even if it is operation at power, how many of them might you
expect to be identified before there is an incident that
they trigger?
MR. MARTIN: During some background, when they
went into the outage in '93, they regarded it as a human
performance outage. That was the principal thing that they
. 30
needed to do, and they didn't expect the outage to be very
long. As a result, they didn't do any comprehensive lay-up
of equipment to assure that the equipment could survive long
periods of shutdown, and they did not invest in a great deal
of predictive, preventive maintenance. They did a lot of
maintenance items. They significantly raised or
significantly improved the threshold for identification of
problems. And there was a period there where the plant was
just peppered with problem identification tags, that things
that had not been identified in the past were identified and
worked; but these were things that were known to the staff
or just hadn't been dealt with in the past.
The ability to identify things without operating
the equipment was not one of their strengths, and so they
went through that outage, which was much longer than they
anticipated it was going to be, without surfacing a number
of these unrevealed problems. As a result, they expected,
and we did too, with the restart to have a number of
problems surface, and they certainly did.
The licensee now has recognized that problem, they
are devoting additional effort in that area, and tomorrow's
meeting in the regional office will be one of the first cuts
at what their plans are to deal with this on a longer-term
basis.
CHAIRMAN JACKSON: Commissioner Rogers, do you
. 31
have any questions?
COMMISSIONER ROGERS: Yes. A couple of things.
I wondered if you could just say a little bit
about the shift mentor use. Can you tell me just a little
bit about that? What's involved there?
MR. MARTIN: What's involved is taking some
individuals who have had previous quality shift experience
from another utility and they are teamed one on one with the
individual new shift manager. And that's a new role. They
used to have a senior manager, a shift supervisor, but did
not give him the breadth of responsibilities that they now
assign to that position.
To upgrade that individual's safety perspective,
to really manage what goes on at the facility, they provided
the shift managers who coach; also provide reports to senior
management on what they're seeing; and we regard and the
licensee regards this as a positive initiative.
An example: After the restart that occurred last
June, they allowed, unfortunately, the contract to lapse,
and there was a period there where the shift managers did
not have this advice function, and we saw some problems
where they still had not evolved to this higher level of
performance. So they're both counselors, overseers and
advisors to senior managers on how the transition is going.
COMMISSIONER ROGERS: It sounds like a rather good
. 32
idea.
There is a feature of our examination that I have
a little bit of question about, and that is, how do you
measure the effectiveness of corrective action programs for
a plant that's not running?
Now, obviously there are some types of activities
that have been deficient that one might be able to identify
and, through a procedural change or something like that,
correct; but when a plant isn't running, it seems to me
there are certain kinds of problems that will only reveal
themselves when it's running and corrective actions to deal
with those may be in place, but if the question is measuring
the effectiveness of the corrective actions, and that's --
it's like the second derivative that you've got to take
here, and how do you deal with that?
You mentioned that during the time they were down,
that you had some concerns about the effectiveness of their
corrective actions. What did you look at and how do you
look at it?
MR. MARTIN: Okay. First, in response to what you
look at, principal, you've got to be identifying the
problems. So you look at what is the articulation of the
threshold for identifying problems, what is the
encouragement, how easy is it to get those problems into the
system, and then you look at who's identifying them? Is it
. 33
NRC, is it quality assurance, or is it the line organization
who is identifying those?
So you look at the identification process to make
sure that it has been optimized; then you look at, having
identified it, how is it evaluated, how is it prioritized
for corrective action, and then how is it implemented and
what checks do they make sure that the corrective action
implemented really was successful?
So you look at the robustness of the process.
Now, it is true that a lot of things won't reveal
themselves until you run the equipment, but if you know
you're going to be down for a while, there are ways to bring
steam into the plant. For instance, a BWR basically can
heat up the plant using reactor coolant -- that's the way
they normally do heat up before they go critical -- and can
actually draw steam to be able to test out the equipment in
that way. They can also have a house-heating boiler where
they can bring in steam that way.
So it depends on how much you want to ferret out
these problems, and if you put together a robust startup
program, you can actually find most of these before the
plant is ready. That was not done in this case. They
counted on the heat-up. And the heat-up did, by the way,
identify a large number of issues, and they stayed down a
long time after heating up. When they -- as problems were
. 34
found, and they were confident, and we were too, that when
they were ready to restart, that the major issues had been
identified and had been dealt with.
MR. RUSSELL: Let me comment generically, because
this really goes to the root of the whole 350 process.
We clearly want to understand what are the
problems that are the reason for the shutdown and track
those through to ensure that those technical issues are
adequately resolved and retested to the extent they can be
with the plant in the condition it's in.
We also look at conduct of activities and, in
fact, operator control and awareness of plant status. It
turns out that during outages, you have as much concern
about conduct of activities, configuration control, the pace
of activities are actually greater. So you can get quite a
bit of insight into conduct of activities even though it's
not operational activities.
In addition, we have the ability to observe
simulator performance and crews and how they would respond
to emergencies and raise questions about how frequently they
have been trained, and have they, in fact, gone through some
of the evolutions proposed for the power ascension program
on the simulator, et cetera. So you get insights.
But the reality is you still have to operate the
plant in order to see how effectively the balance of plant
. 35
equipment is going to operate. There are some systems that
you just cannot test until you have power: feedwater
systems, feedwater heating, some of the control systems
associated with power conversion.
That's why also we typically have as a part of
that process continued oversight with round-the-clock
observation following a decision to allow restart. In fact,
preceding a decision to allow restart, there is often an
operational readiness team inspection that does a
comprehensive review to look at all the pieces and make sure
that all the pieces add up together to support a decision.
And then you continue to monitor the performance of the
plant and observe how they respond to events which do occur.
So you do the best you can to address the issues.
Most safety equipment, standby equipment, can be
tested because it's normally on standby and you can evaluate
it. The more difficult area is in the balance of plant
power conversion systems, which really cannot be tested
until you're operating.
So challenges from the secondary side typically
reveal themselves in a power ascension, and that's why you
go through a gradual ascension, studying the plant out,
evaluating and proceeding on. That's broadly the process
that's laid out in the Manual Chapter 350, which we execute
for any facility that's in an extended shutdown period where
. 36
you have concerns about control of material equipment,
material condition and preparation for startup.
CHAIRMAN JACKSON: We obviously are not the ones
who do the categorization but that there is some delineation
and that is what the two of you have posited between things
that clearly can be identified and a shutdown condition and
should be and those that perhaps cannot be, but it strikes
me that once a plant has come out of a shutdown, that there
should not be a plethora of issues and particularly related
to equipment that could have and should have been identified
beforehand and that we need to be fairly vigilant and
aggressive with respect to those.
MR. RUSSELL: I agree with the Chairman.
COMMISSIONER ROGERS: Well, I totally support
that. I think it's absolutely right. But it does seem to
me that if one is looking at the effectiveness of a
corrective actions program as a condition for restart, there
is a little bit of a problem there. I mean, there is a gap
that you've got to jump across.
MR. RUSSELL: You are projecting based upon what
you've seen during shutdown to how they are going to perform
during operation.
COMMISSIONER ROGERS: And you won't have it to
hypothesize.
MR. RUSSELL: You won't have total assurance as to
. 37
the effectiveness of that program.
COMMISSIONER ROGERS: No, you won't.
CHAIRMAN JACKSON: What you have to be sure of is
the appropriate delineation has been made and that anything
relative to those things that can be identified in a
shutdown condition or by some way of testing the equipment
in that shutdown has been dealt with. That's a minimal
standard.
The other then is a follow-on standard having to
do with what Commissioner Rogers likes to call the second
derivative which then is a monitoring as the plant is going
through a power ascension. But it seems to me that there
should not be issues that are follow-on issues that can be
identified ahead of time.
MR. RUSSELL: Clearly, there should not be any
repetitive problems that you previously thought you had
resolved and revealed themselves to not have been resolved.
So repetitiveness of problems are very significant. That is
why we are going to continue to monitor this facility
closely because we have not seen a sustained period of
operation free of problems.
CHAIRMAN JACKSON: Okay.
MR. RUSSELL: Millstone Station, Tim?
MR. MARTIN: Millstone. Performance at the
Millstone Nuclear Power Station has been discussed during 10
. 38
senior management meetings since June of '91. Following the
January '95 senior management meeting, NRC senior managers
met with NU's board of trustees in March '95 to communicate
NRC's concerns for the lingering performance problems at the
Millstone facility. Despite a number of initiatives, NU has
had limited success in resolving significant performance
concerns with procedural adherence, work control and
tagging, untimely operability and reportability
determinations, ineffective corrective action processes,
poor operational focus, weak communications and teamwork
between organizations, inadequate handling of employee
safety concerns and poor self-assessment and quality
verification.
Since the January '96 senior management meeting,
Unit 1 has remained shut down in a refueling outage that
began on November 4, '95. Fuel movement and overall
refueling activities were generally well controlled with
good supervision. The quality of maintenance and work
control remains a concern despite the fact that very little
maintenance is occurring.
Engineering support for operations has improved,
particularly in areas of focused management attention.
Efforts to resolve longstanding rad waste facility material
deficiencies have been noteworthy. However, additional
performance concerns were identified with operability and
. 39
reportability determinations, corrective action timeliness
and effectiveness, procedural quality and adherence and
licensing basis understanding and implementation.
Unit 2 operated until February 20, '96, when it
was proactively shut down for a mid-cycle maintenance
surveillance outage to address licensee concerns for
potential plugging of the high-pressure safety injection
flow control valves by containment sump debris able to pass
through suction screening, the potential for which had been
identified at another licensee's facility.
Operator performance and control and ownership of
facility activities have improved however the licensee was
slow in establishing alternative sources of power to
emergency buses following internal damage of one of two
emergency diesel generators during a surveillance test.
Although maintenance procedures and performance have
improved, problems with procedural adherence and weaknesses
in work control remain to be resolved.
Engineering continues to identify significant
deviations from design in facility construction, process
description and surveillance test attributes. Plant support
functions generally remain a strength. Although some
performance improvements have been noted, operability,
reportability determinations and corrective action
timeliness and effectiveness remain a concern.
. 40
Unit 3 operated until March 30, '96, when it
entered a tech spec required shutdown following discovery
that the turbine-driven auxiliary feedwater containment
isolation valves would not seal against design pressure
coming from the containment side. Subsequently, the
licensee reported the discovery that the recirculation spray
system design maximum temperature of 150 degrees Fahrenheit
would be exceeded by containment sump water temperature
following a design basis accident and an assumed single
failure of the service water to the recirc spray system heat
exchanger.
Operator performance has been generally good
including conduct of routine activities, response to
identified problems and sequencing of control room
construction activities counterbalanced by several examples
of inattention to detail and inadequate corrective action
for earlier problems.
Efforts to improve maintenance effectiveness
continue and have met with some success. Engineering
performance has also improved with better responsiveness to
operations, increased scope of problem resolution and
identification of a large volume of historic design
implementation deficiencies.
In January '96, Northeast Utilities initiated a
corporate reengineering effort resulting in the layoff of
. 41
approximately 100 individuals and the assignment of
corporate vice presidents for utility operations,
engineering, work services, technical services and safety
and oversight. Subsequent to the January reengineering
changes, the vice president of operations resigned and this
important position is still vacant. A replacement is being
sought.
In May '96, Northeast Utilities announced the
Nuclear Excellence Plan, which includes the licensee's year-
old Improving Station Performance Program plan and the
individual Unit Configuration Management plans. In a
parallel action, the board of trustees established a nuclear
committee to provide oversight of the management of nuclear
activities. The committee has established a nuclear
committee advisory team to perform assessments and report
results to the committee. The advisory team is currently
engaged in developing a fundamental cause assessment.
The NRC remains concerned about the volume of
allegations received and the continuing evidence of
unresolved employee concerns at Millstone. The licensee has
enhanced training for managers and supervisors, replaced a
number of supervisors and established a new employee
concerns program reporting to the vice president of safety
and oversight. Despite these changes, NRC received 39 new
allegations containing over 80 concerns since January '96.
. 42
In addition to individual inspection or
investigation of each allegation, the NRC is conducting a
broad review of Northeast Utilities' January layoff and an
independent lessons-learned review of the licensee's and
NRC's historic handling of Millstone allegations.
The NRC's level of involvement in assessing the
Millstone activities has been substantially heightened over
the past 9 months. Each of the three units has been
assigned a senior resident inspector and resident inspector
and an SAS manager has been placed in charge of overseeing
Millstone Station activities. Due to the utility's failure
to achieve a sustained level of performance improvements and
continuing concerns for its effectiveness involving safety
concerns, Millstone Station was placed on the watchlist
during the January '96 senior management meeting.
Additionally, a significant level of investigation
and inspection activity was initiated as a result of
concerns associated with the Unit 1 core offloading
practices and an evolving list of concerns with failure to
maintain conformance with their licensing bases. In
December '95, NRC issued the first of a series of demand-
for-information letters to Northeast Utilities, in this case
requiring the licensee to describe what actions the licensee
had taken to ensure future operations of Unit 1 would be in
accordance with the terms and conditions of their license.
. 43
Subsequently, Northeast Utilities initiated an internal
license review that was highly critical of the integrity of
the Unit 1 licensing and design basis and speculated that
similar problems likely existed at the other units.
Following receipt of the licensee's report of
these findings, NRC issued additional demand-for-information
letters for the remaining Millstone units. The latest
demand-for-information letters for each of the three units
requires the licensee to affirm compliance with the terms
and conditions of its operating license, regulations and its
updated final safety analysis report prior to the unit's
restart.
During the month of March and May '96, NRC
conducted a special team inspection of engineering and
licensing activities for Millstone's Units 2 and 3,
concluding the most significant concern was the ineffective
action process for previously identified engineering and
licensing problems.
Examples include but are not limited to, one, a
concern that the turbine-driven auxiliary feedwater pump
discharge piping was not designed to high-energy line break
requirements, so the licensee closed the pump discharge
valves in violation of tech specs.
Two, an Appendix R operability concern for the
service water booster pump discharge valves was resolved by
. 44
installing jumpers that ended up disabling one of the auto-
start features of the pump.
Three, a seismic response concern for the reactor
building closed cooling water surge tank led to the design
and installation of a temporary modification involving
slings, beam clamps, chain falls and come-alongs that not
only appeared inadequate but was not implemented as it was
designed.
CHAIRMAN JACKSON: You mean rubber bands and tape?
MR. MARTIN: I don't want to overstate my case.
Four, a single failure concern for post-accident
hydrogen monitor containment isolation valves was
dispositioned by developing contingency instructions for
operators to install jumpers following a loss-of-coolant
accident. The team also identified multiple examples as
both units of deficient installation of design
modifications, inadequate safety evaluations for
modifications, failure to translate design and licensing
basis information into procedures, practices and drawings,
and errors in the updated final safety analysis report and
description. The report of this inspection is now being
developed.
Recently, NU provided a detailed description of
their plans to complete work to respond to the latest demand
for information for Unit 3. The document describes their
. 45
effort to identify and correct Millstone 3 design and
configuration management deficiencies and provides an
initial list of 881 deficiencies in meeting their design and
licensing basis that have been identified since February
'96, of which about 300 they identified as requiring
resolution prior to restart.
The licensee further indicates their plans to
submit an operational readiness plan in July '96 and to
delay announcing a restart schedule until sufficient
improvement in personnel, culture, processes, programs and
hardware are achieved. Based on my discussion with the
licensee, I understand the licensee will supplement their
response in the near future to include additional identified
deficiencies, possibly some 400 to 500 additional items, and
to detail how and when each deficiency was identified.
The NRC has begun the process of assessing the
licensee's efforts to assure the acceptability of the
licensee's approach. In parallel with these efforts, NRC is
developing an independent restart assessment plan to guide
inspection activities that must be completed prior to any
restart decision.
In summary, previous Millstone performance
concerns remain to be resolved and recent inspection
findings have disclosed significant problems with licensee
compliance with the requirements of their licenses.
. 46
Therefore, the NRC plans to closely monitor the programs and
performance of the Millstone station to assure the
development and implementation of effective corrective
action programs. The NRC has determined that the restart of
all three units will be evaluated and managed under the
requirements of NRC Manual Chapter 350, Staff Guidelines for
Restart Approval. Further, the senior managers concluded
that Millstone station should remain on the watch list as a
Category 2 facility.
Are there any questions?
COMMISSIONER ROGERS: Well, there's a lot you
could ask, but just what is the status of the documentation
of the reports to management that are required,
documentation and reports to management, appropriate levels
of management, that are required under Appendix C of
corrective action programs of -- significant adverse to
corrective actions to conditions -- significant conditions
adverse to quality, those that are to be documented and
reported to management? What is the status of that? Has
that gone on, or is this something that's been another
weakness?
MR. MARTIN: Commissioner, the nonconformance
reports, those things required by Appendix B, the specific
reports that you speak of, have not been generated in all
cases, and in fact, they have recently developed a sitewide
. 47
process they call their adverse condition report which they
are trying to collapse all their adverse condition -- all
their deficiency reporting into this one process.
Unfortunately, this is but another example of
where they have not addressed their previous commitments.
Now on Unit 1, the plant manager sent out a
message to his staff saying that the nonconformance
reporting system, which is the Appendix B system, should be
abandoned in place, and that all things should be put into
the ACR process. Unfortunately, the Appendix B program is
still docketed and has not been changed. So there was not
the type of respect for that system.
They had a reportability evaluation process that
was one set of reports. They had a number of informal
systems that were going on, but these formal systems to
report to senior management the significant issues, we did
not see that being robustly maintained.
MR. RUSSELL: I might comment that this is
explicitly the reason that we asked in the demand for
information that they identify the specific issues. We
understand when they were identified -- for example, if they
had been known for some time but in some other system and
process and had not been acted upon, that might have
implications both technically for the scope of what needs to
be done to ensure all of the problems are identified and it
. 48
may also have implications for failure to report or meet
regulatory requirements in the past. So there are two
elements to it. One is to provide information to allow us
to be confident that the total scope of problems necessary
to be addressed for restart have been identified so that you
can go through and say yes, these need to be addressed
before restart and those do not.
But it is going to be an extensive process --
CHAIRMAN JACKSON: But let me make sure you
clarify a point. But the identification of the when has not
been done?
MR. RUSSELL: That is correct. Well, there are a
few.
MR. MARTIN: Let me correct that. Based upon my
discussion with Ted Feigenbaum, they had intended to -- they
had scheduled a complete response to the DFI in the early
July time frame. When we sent out our letter in May that
asked for their response and identification of issues within
30 days, they made an overt decision not to put something
down that they hadn't yet confirmed. Although they have
some of that information, they did not feel sufficiently
confident and did not want to send forward false
information. They did have this identification of 881
issues. They expect that number to expand to twelve to
1300. They expect ultimately probably 50 percent of them
. 49
--that's their estimate -- will be restart issues, and they
still intend in the early July time frame, according to Mr.
Feigenbaum, to identify the nature, the when, the how, of
identification of these problems in the past, and why they
have not been dealt with.
Mr. Feigenbaum also indicates that they intend to
provide some assessment of how they got themselves into this
situation in that early July document. That was their
intent. He says they were very concerned that they not send
forward information that they would later have to retract
because they determined that it was not correct.
As a result, they only put the bare bones of the
information. They believed this is an interim report, they
intend to supplement it several times over, but the next
major one and the one they had really planned on was the
July report.
MR. RUSSELL: But your observation is correct, we
need to understand how these have been handled in the past
so we can make judgments about the effectiveness of the
corrective actions being taken, and also to ensure the
completeness of identification of the issues that need to be
addressed before restart and then those which may be able to
done longer term.
COMMISSIONER ROGERS: What actions did we take
routinely in the past to look to see whether there was
. 50
documentation and reporting to appropriate levels of
management of conditions adverse to quality?
Is this something that we just assumed was
happening, or did we actually do some spot-checks to see
whether the file was documented, filed and sent to
management?
MR. RUSSELL: We did conduct inspections related
to program requirements for the quality programs in some of
the other areas. There are mechanisms which were used by
the company which resulted in either memoranda or other
informal types of communications between operations and
engineering or licensing which did not get into the formally
required NRC programs, and so unless an inspector were aware
that such documentation existed, if he wanted to do sampling
inspection of the quality program, they'd go in and they'd
look at the quality program reporting, tracking, follow-up.
COMMISSIONER ROGERS: Tom, do you want to --
MR. MARTIN: Yes, I do want to add.
Commissioners, as you are aware, in the late '80s
we shifted to a very performance-based inspection. We
stopped doing the programmatic deep probes where we'd look
at multiple examples of where the program was implemented.
So when problems were identified and we were aware of those
problems, we would then trace those to see that they were
appropriately dealt with, documented, communicated, et
. 51
cetera.
Unfortunately, one of the ills we find is that
there was a lot of very informal communications within the
organization of significant safety issues, and they would
only come to light when they finally had a solution, to be
able to be articulated.
So when we looked at the things that we became
aware of, we found that, yes, the right milestones, the
right reports had been made. But we did not see a generic
problem in this area. What we failed to be aware of was a
number of other issues that were being handled informally
within the system that were not in tracking systems, and so
we were not looking to see -- we didn't have the information
to find that they had not reported those to senior
management.
COMMISSIONER ROGERS: Well, I think it
illustrates, I think, the difficulty of interpreting what we
mean by performance-based regulation because it's got to be
more than just how much electricity goes out on the grid,
and it has to relate how the internal performance of the
organization is working, and if corrective actions are not
adequately documented and passed on to the appropriate
levels of management as required by our rules, that is a
lack of performance in its own right. It's a different kind
of performance from, you know, the numbers that you measure,
. 52
but it's a measure of how internally they are performing,
and when we don't have any way to assess that, I think we
have to be a little bit careful, I think we have to be a
little worried about whether we are too limited in our
interpretation of what we mean by performance-based
regulations.
MR. TAYLOR: That certainly has been demonstrated
here.
MR. MARTIN: Commissioner, don't let me misstate
the situation. When I say performance-based inspection, we
were looking at what occurred, what events came to light.
What we were not tapped into was the informal grapevine and
were not appreciative of how much, what volume and
significance of things was being handled in that informal
grapevine.
Lacking that intelligence, we didn't have a clue
to whether the reports were being made to the right levels,
because we weren't aware of the specific issues.
CHAIRMAN JACKSON: But Commissioner Rogers is
citing a regulatory requirement that is meant -- and
obviously there is a lot in that universe -- but it is meant
to get at safety-significant issues, and that they are being
dealt with appropriately. And there is a performance
relative to those regulatory requirements that I think he is
underscoring here in terms of definition of performance.
. 53
MR. RUSSELL: For example, as I briefed you back
in May, we have pretty explicit reporting requirements for
notifying us of conditions which may be outside the design
of the licensing basis. Some of these examples, which have
been identified, which were in informal systems which were
not reported, may fall into enforcement and there are a
number of investigations going on to determine the
circumstances about why they were not reported.
So it may be that the systems were broken and the
informal processes were such that they would not come to
light, but we need to run those to ground to understand
whether there was some intentional putting it in informal
systems so it would not be exposed to regulatory oversight.
Those questions are still under review and are part of some
of the investigations that are ongoing.
CHAIRMAN JACKSON: All right. Because
performance-based regulation can't be whether we happened --
whether an inspector happens to see whether a pump is
working today or not. It goes well beyond that.
Commissioner Dicus?
COMMISSIONER DICUS: No questions.
CHAIRMAN JACKSON: Any other questions? Okay.
MR. RUSSELL: Dresden.
MR. MILLER: Chairman, Commissioners.
Dresden was placed on the watch list for the first
. 54
time in June 1987. Con Ed responded with the Dresden
Station improvement plan, and following a period of improved
performance, the plant was removed from the watch list in
December 1988.
Performance problems surfaced again and the plant
was returned to the watch list in January 1992. Since that
time efforts have been underway to address problems that
exist with respect to both human performance and plant
material conditions.
Since the last senior management meeting, Unit 3
has operated at power most of the time. Unit 2 restarted
from an extended refueling outage in April. Both units were
shut down about a month ago to address various equipment
failures in the main feedwater system.
Shortly after repairs and restart of Unit 3 on
June 11th, failure of a 4 kV circuit breaker led to another
shutdown of Unit 3.
The station is currently addressing the broad
issue of 4 kV breaker reliability on both Units 2 and 3.
Shifting now to a more broad assessment of
performance over the last six months, management of control
room activities has continued to be good. A conservative
approach to decision-making and plant operations has
generally been taken. A low threshold for identifying
problems has been established.
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Major plant evolutions have been performed in a
deliberate, well-controlled manner. For example, the
numerous startups and shutdowns over the past six months or
so have been virtually error-free and the operators have
reacted well and conservatively to plant transients.
Overall, progress has been made in reducing the
number of personnel errors at the station but problems with
plant equipment lineups and the station's out of service
program reflects some continuing weaknesses in the execution
of field activities.
Some of these problems should have been identified
during Unit 2 pre-startup readiness reviews that were
performed in the March-April timeframe, indicating continued
effort is needed to effectively communicate management's
standards and expectations to station personnel.
Continued slow improvement in plant material
condition has been observed. Efforts to address operator
work-arounds have been positive, for example.
Strong steps were taken to test systems before
restart of Unit 2 from its refueling outage. However, the
potential impact of equipment problem backlogs which remain
large was revealed by the recent Unit 3 scram and safety
system actuation caused by failure of a feedwater control
valve and by current electrical breaker issues.
Steps taken to improve work control processes and
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worker skill levels have begun to show some results but
long-term trends are not yet clear.
In the engineering area, we note the systems
engineers are more consistently identifying and following up
on discrepant conditions. However, engineering backlogs are
large.
Also, some significant weaknesses in design
control are reflected by a failure to resolve known problems
with reactor building structural steel which did not meet
seismic design criteria.
Continued significant management attention is
needed to assure improvement efforts are sustained and
effective at Dresden. Closely monitoring Units 2 and 3 as
they are operated together for a period of time and
monitoring the Unit 3 outage to be conducted in the Fall of
this year will be important in determining if lasting change
is being made.
In addition to continuing Region III inspection
and oversight activities, plans are underway to conduct an
extensive team inspection staffed by personnel outside the
region. This inspection will independently assess progress
in correcting performance problems and sample compliance
with licensing and design basis requirements. This
inspection will be timed to among other things assess
performance during the Fall refueling outage.
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Dresden will remain a Category II plant.
Are there any question? Thank you.
CHAIRMAN JACKSON: Any questions?
COMMISSIONER DICUS: I want to ask a very general
question to kind of help me understand this whole process a
little bit better and it's to the senior managers as a
group.
What process do you use or how do you determine
that a plant is no longer safe to operate? How do you go
about that?
MR. TAYLOR: We have had occasion -- I can start
with Davis Besse. The event was so significant we didn't
issue a shutdown order. One wasn't really necessary. The
plant was actually kept down for something more than two
years.
We had -- it was very clear there were deep
problems at Davis Besse. I just take that example. That
was a -- that became what we call a Category III plant.
There were others where significant operational
events -- Peach Bottom, issues of operator performance;
there were some at Rancho Seco; and indeed I would use those
as examples where our concern about safe performance was so
deep that the licensees themselves knew they had to keep the
plant down and we of course agreed and ultimately to restart
the plant rather extensive programs were executed over
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sometimes a couple of years and then the Commission, having
been briefed both by licensees and Staff, could conclude
that the plant had been reasonably correct and of course was
allowed to restart.
Then we watched them even in a monitoring mode.
They sort of went from a Category III to a Category II.
There were many more of these types of events in
the mid to late '80s than there have been in the last four
or five years.
I could identify other plants but that has been
the methodology
If we had an immediate situation of course the
Agency has the authority to shut a plant down immediately,
to issue immediately an effective order. Correct, counsel?
CHAIRMAN JACKSON: I think, if I may expand a
little on the Commissioner's question, in some sense one
could argue that the response by the NRC has been good if
there's an event that clearly shows that there's a problem.
The issue is one, and I think this relates to what you have
already been asked to do by the Commission following on the
previous meeting, is how do you get to a point that you can
evaluate when there's been a significant enough erosion of
the safety margin that maybe could make you jump out ahead
of the Davis Besse -- or when you can identify that there is
enough of a pervasiveness in terms of how regulatory
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requirements are dealt with that would allow us to get out
ahead of some situations we are dealing with at the moment.
MR. TAYLOR: Of course Category II was established
principally to do that -- I mean to say, wait a minute,
performance isn't good; we don't want to see it deteriorate
therefore we increase their operational oversight.
In fact, that has been the predominant category as
we have been in this now about 10 years or so, where we say
wait a minute, we really want to watch things -- we want to
put extra resources, extra time -- excuse me, Chairman --
CHAIRMAN JACKSON: No, no, no, that's fine.
MR. TAYLOR: That is indeed how plants have become
Category II. Those that weren't really by some judgment, as
I think has to be applied, because no two set of
circumstances are identical, then the Commission several
years ago urged us to point a trending and that became
another wait a minute, we see some adverse movement, it's
not quite at a point where we need to put a great deal of
extra resources but we would like to send a notice of
trending, and I think Cooper is an example of that and there
have been several others.
MR. RUSSELL: Start with Perry.
MR. TAYLOR: Perry -- and so that is how we have
evolved into trying to preclude somebody getting into a case
where there's such a serious safety event that it -- as
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Davis Besse and some of the others were.
CHAIRMAN JACKSON: I think this relates to the
issue of plants that linger on the watch list and then
hopefully Indian Point 3 is not trending in that direction
where one has to ask the question that if a plant is kind of
limping along and one has to interpret it as a limp if it
remains on the watch list for an extended period.
What then do we do? And I think we are taking a
deeper look at Dresden, even though there are some
indications of improvements in certain areas.
I think that in a sense we are asking you a
question that we know you can't totally answer today but is
the nub of the issue in some sense.
But I didn't mean to take off --
MR. TAYLOR: If I could just -- your comment is
correct. In general in the past plants which were shut down
were shut down outside of the senior management review
process. That is, an event occurred or circumstances
occurred. A confirmation of event letter was initiated. In
the Peach Bottom case an order was issued. These were done
in real time and they were based upon conditions that
existed at the time that were so egregious that there was
not a lot of judgment as to whether the plant should or
shouldn't operate.
The chronic marginal performance problem and
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whether a company has sufficient resources to improve
performance at the same time as addressing fundamental
issues with plant material condition, et cetera -- that is a
more difficult issue.
Some facilities have responded to that by shutting
their plants down, addressing the material condition,
getting the material condition taken care of, and then
addressing operation and some of the operational issues.
We have had some cases where plants have continued
to discover problems while operating where they had not
appreciated the full scope of the magnitude of the problem,
and absent some kind of defining event, it becomes a
judgmental process as to how do you use all these indicators
of concern, recognizing that NRC also carries a burden to
articulate clearly why an action is necessary in a formal
regulatory, legalistic sense.
So when you are in this gray area in between, the
approach has been to discuss the issues with the company.
Do they understand the issues? Are they addressing them?
We have had some cases where it has taken a longer time to
address, and I think a clear lesson learned from the
Millstone situation is that we should have been more
forceful in identifying these issues earlier, doing it in a
more visible way and getting management to address these
much earlier than was ultimately the case.
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CHAIRMAN JACKSON: Well, it strikes me that some
of what you are talking about has to do with how do you
develop let us call it a preponderance of evidence?
MR. TAYLOR: Yes.
CHAIRMAN JACKSON: And a regulatory escalation
chain that is hooked to that -- and I think in the end that
is what we want to come out with, and I am going to be
making some remarks at the end along that line.
Let me ask you about two specific things
You now have started using this plant issues list.
Are you finding that that is actually -- and I am
particularly asking the Regional Administrators -- is it a
useful tool and then how do you ensure consistency in the
preparation and use of this list, you know, across the
universe of plants within your regions and across the
regions? What is the feedback mechanism? How does that
fold into the daisy chain of how the plants are assessed?
I am going to come back and ask about IPAPs but I
am interested in your answers to those questions.
MR. RUSSELL: Why don't we start with Joe since he
has not had a chance to address some of these issues.
CHAIRMAN JACKSON: Yes. I was going to give Joe a
chance so he wouldn't feel he'd travelled all the way up
here for nothing.
MR. CALLAN: Chairman, I personally find that the
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plant issues list has been very useful. That opinion may
not be shared by all my staff. I think, as in all new
things, there's a degree of skepticism or resistance.
The big issue is the one that you touched on,
which is consistency, not only amongst the regions, but
within the regions, and we're working on that. The program
office is working with the staffs of all four regions to
come up with criteria to help with that issue.
MR. EBNETER: Well, we in Region II have used that
list for over two years, and I find it very effective. It's
a little bit burdensome on the staff. But there is a danger
of making that list too consistent, and there is a danger of
making that list a little bit too constricted.
What the list does for me in Region II, it gives
me a bigger sample size to look at rather than reportable
events, which are very, very restrictive, and, if used
properly, it can give you some indication of which way the
plant is going. But it has to be maintained current and it
has to be at a fairly low threshold.
We've used it -- we first used it on the St. Lucie
plant two years ago in Region II, and we fined it, and then
we used it on Crystal River to identify some problems, and
we have successfully used it on Cataba station to see things
early.
In each case, we would meet with -- take that
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output from that PIL -- we call it the PIL now; we used to
call it the site integration matrix -- but we would use that
as the output to compare our findings with licensees' self-
assessment and then reach an agreement on where the problems
-- we thought the problems were. It hasn't always worked
100 percent, but it has been very beneficial to us in early
identification.
Bill Russell commented on Millstone. That struck
me as this issue -- he said maybe we should have dealt in a
more visible way. In every case of these plants that I've
mentioned, we have a bi-monthly management meeting open to
the public.
I recently went to one at one of our facilities
where the press came in about five minutes late, and the
press said, can I have a handout, and the licensee says,
well, gee, we don't have any left, they're all gone. And I
told them they could get one of ours, but I would suggest
that this utility give them copies of this handout, and this
is public, and they did. And the press treated them pretty
fair, but this visibility, handling these problems in a
visible manner, certainly has a very big lever in this
business. But we use the --
MR. RUSSELL: That's one of the reasons that we've
required that every item identified on the plant issues list
be referenced to a publicly available document and that we
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not analyze information that is not in the public docket.
So we want to make sure that the written record, whether it
is an inspection report, a licensee event report, it's a
performance indicator from the NRC's performance indicator,
whatever the source of the information is that's being used,
it is on the docket and is publicly available.
I would like to have the other two regional
administrators comment and then I'd like to come back.
MR. MARTIN: Chairman, we just recently shifted to
the plant issues matrix, and I probably have the least
experience with it. I will also say, though, that in
preparation for each senior management meeting, I was going
through the same process of developing such a list, because
you have to extract that information.
I have found that the lists that have been created
do help you very quickly focus on the problems that need to
be addressed and it certainly helped me in my preparation
for meetings with licensees, in preparation for SALP
meetings, and certainly the PPRs seem to much smoother in
the process because we have a common set of events,
discoveries that we're all able to review and we see what
the significance of it is.
Now, you asked about how do we assure uniformity.
Well, obviously within the region, since the same people
participate in the PPRs and process them, we're able to see
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differences and to give on-the-spot counselling. Those same
documents then go with us to the senior management pre-
briefs with the NRR staff, who are able to comment then upon
the differences, and they then also provide the guidance
which then establishes some uniform criteria for them.
So we do have a feedback mechanism, and, to be
quite frank, they're not uniform right now. We're moving
toward that, we're adjusting the thresholds between the
regions so that they do it in the same way.
But I do find them useful. It is consistent with
the way I've had to analyze data in the past. It makes it a
lot easier now that they're culled out as individuals and
then sorted according to function and kinds of problems. So
I find it useful.
CHAIRMAN JACKSON: Mr. Miller.
MR. MILLER: Well, the real struggle in this
business is to get out ahead of issues and to identify the
precursors. And I find this tool very useful in that
regard. I mean, with the low threshold, which is well below
an LER threshold, for example, you can develop a sense by
looking at numerous things reported, both good and bad, a
sense for things that you really can't get any other way
that I know of, frankly. So I look at it as a way to get a
handle on precursors of problems.
As far as consistency, I agree with the others.
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We're still sorting that out, and I think that we're
resolved and we have been working with Bill Russell's people
and comparing notes. I suspect it will take some time to
come to a better level of consistency among regions. And
even within the region, frankly, we're still struggling with
that.
MR. CALLAN: Chairman, since I was the first, I
didn't have a chance to get my thoughts in order. But it's
been my experience one of the greatest dangers of any
assessment activity is a tendency to be anecdotal in the way
we go about it, and the biggest impact that this list has
had on my region, Region IV, has been a tendency to
counteract that proclivity to be anecdotal because you have
all the anecdotes now in a systematic fashion before you,
and it's served as sort of a reality check to our assessment
function.
CHAIRMAN JACKSON: Is it being used in a
consistent way in terms of its use in the PPR as well as in
the preliminary discussions leading up to the senior
management meeting?
MR. RUSSELL: Before I answer that question, let
me give a broad overview of what this is we're talking
about, because while some around the table understand it,
there may be others that don't. And it's really a rather
straightforward process.
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Each document, whether it be a licensee event
report, inspection report, or other, if you were to consider
going through with a yellow highlighter and picking out the
important issues, and if they're important, whether it be
positive or negative with respect to performance, putting
those in a matrix, identifying how the issue was discovered
-- was it self-revealing, was it found by a licensee quality
assessment program, et cetera, was it found by the NRC, does
it relate to maintenance performance, does it relate to
operations, does it relate to engineering, is it related to
plant supports, a remarks column associated with it, and
then included the specific reference that's available in the
public document for that information. It's in a relational
database.
We're using a trade name, but it's a text
relational database; so if you want to pull out the
information associated with operations, you can see what had
been the strengths and the weaknesses and a short
description of what the problem was. If you need more
information about the problem, you can go to the publicly
available document.
That's the concept. Keep that in a reverse
chronological order, focusing on the last six months first
and going through and using that information, along with
other tools we have, such as the master inspection plan and
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some of the other tools to look at what are your inspection
planning activities.
That's then used for the plant performance review
that's conducted and you look at what has been the evidence
in the operations area of performance issues, what has come
out of our inspection findings, et cetera, do we need to
increase inspection, maintain about the same, reduce, in
what areas, and why.
That's the concept. Then use that same raw data
for input to the senior management screening process, where
you may bring other perspectives, such as risk significance,
any case studies done by AEOD, et cetera.
The same background information, we want to get to
the point where we're using it and we'll be attaching it to
senior management meeting background material in the future
so that not only will the few examples that are illustrated
in the senior management meeting documentation be available,
but others will be there so that you would have that hard
data.
The intent is to get consistency between plants
within a region and between regions. One of the approaches
we're considering is that when I conduct the screening
meetings for the next set of senior management meetings,
we'll do it so we do two regions on the same day. That way,
you can have the regional administrator and the senior
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regional staff observe what's being discussed for plants
outside their region, how the process works, and we can get
some cross-communications through that vehicle as well.
CHAIRMAN JACKSON: You say by the next senior
management meeting.
MR. RUSSELL: That's correct.
CHAIRMAN JACKSON: Okay. So that's a commitment.
MR. RUSSELL: That's a commitment. We're looking
at how we're doing. These are some of the issues we're
going to be identifying when we come back to you in the
August timeframe, because this is key, this is our approach
to try and ensure that we are using objective, factual data,
and that when we make statements about performance, we can
illustrate with a number of examples a chain of citation
type.
We intend that these be maintained on site,
current, and then updated by way of management reviews,
either through the plant performance review process, used as
input to the SALP process, used as input to the screening
process, used as input to the senior management meeting
process. That gets to the point where you have digested and
extracted from the record the important information.
Your question about the relation of this to IPAP
and some of the processes -- I recall that the IPAP process
was a direct result of the surprises we had associated with
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South Texas, Quad Cities and some other stations, where we
had information on the record that we had not fully
integrated to understand.
With this process working, I'm hopeful that we
will no longer have a need to conduct an IPAP to understand
what's in the record, analyze the information. It would be
available for others outside of those that are just doing
the inspection to see and analyze. So this is part of the
process to make factual information available on the record
which is public, and this is the tool by which we would use
for our internal analysis for allocation of resources.
CHAIRMAN JACKSON: So, in fact, then, are you
saying that -- so let me make sure we understand, that you
plan to continue with the present program for IPAPs as you
evolve this PIL mechanism, or are you basically migrating to
the use of the plant issues list with the rest of your
process and migrating away from the IPAPs?
MR. RUSSELL: It's a little bit of both. We
discussed this in our meeting with the regional
administrations and we also discussed it at the senior
management meeting. The bottom line, where we're coming out
is that we believe the IPAPs provide a very useful tool for
inspections that are led by headquarters, where you're
looking at program implementation as well as licensee
performance, and we're looking at issues as it relates to
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consistency of inspection reports with various program
requirements.
That would probably mean we'd only be doing one or
two in a region per year, depending upon what needs are; so
it would be less resource-intensive. We're also looking at
modifying those that are done by headquarters to include a
vertical slice inspection to also look into licensing and
design basis kinds of information so that you could exchange
information records. So if you look at licensee events
reports and other information, if it's raising issues about
design, you could go further into design in those areas.
So we are, in fact, looking at modifying it. We
don't believe it's necessary to continue it as a region
based inspection for all facilities, and we'll be coming
back to the Commission and identifying an alternative
approach that will be led by teams essentially managed out
of headquarters with fairly substantial support from people
who have experience in architect engineering types of --
CHAIRMAN JACKSON: Would it include this vertical
slice?
MR. RUSSELL: It would include the vertical slice.
We would expect to have a number of teams that can do that,
on the order of three or four teams to be able to do three
or four facilities per year throughout the United States.
To ensure consistency in quality of licensing basis and
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design basis information.
MR. TAYLOR: We have to come back to --
MR. RUSSELL: We are coming back to --
CHAIRMAN JACKSON: Yes, because the current
question I have was that in view of the ongoing lessons
learned activities with the operating reactors, you believe
it will be necessary to adjust resources presently used to
perform inspections and plan assessments going forward and
that is going to be part of what you --
MR. TAYLOR: We are looking for some outside help,
too.
MR. RUSSELL: That is also why we are balancing to
reduce the IPAP inspections to substitute those resources
for some other types of inspections.
CHAIRMAN JACKSON: Let me ask you a question about
the maintenance rule, since that is becoming effective in a
fairly short period of time. Is the Staff ready to begin
inspection and assessment of the licensee's implementation
of the rule and, you know, is there consistency between the
understanding of licensees and even among our own people
with respect to, you know, the language, the
categorizations, particularly what the performance program
is and where are we with respect to Staff training and
guidance in these areas?
MR. RUSSELL: Broadly, following the issuance of
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the regulatory guide, which was about three years ago, the
Staff started working on developing inspection guidance. We
went through a process of developing draft inspection
guidance, conducted a number of pilot inspections, refined
the guidance and then promulgated that through workshops and
other vehicles. There have recently been some comments on
the inspection guidance. We made some additional changes to
make sure it is consistent with the regulatory guidance.
There were some concerns particularly as related to scope of
monitoring that may be required at a component level if
something were being evaluated from a performance standpoint
at a plant performance level. So if you are evaluating
plant trips, is it necessary to monitor components? And we
agreed with industry in two areas and we made revisions to
the inspection guidance.
As it relates to training, we have conducted
training. We started it first for all the senior residents
and we did that through the senior resident counterpart
meeting that we had here in Washington. Then we have done
specific training in each region. All of that training has
been completed. The first team inspection after July will
have observers from each of the regions and it's made up of
a team using people from each of the regions being led by
headquarters to do the first implementation. Following
that, there will be subsequent implementation in each of the
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regions and we have required that in the initial phases all
of the findings potentially involving enforcement be
coordinated through headquarters so that any enforcement
actions will be reviewed for consistency in headquarters.
So we have done a number of things. We have
completed the training. We believe that we are ready to
implement at this point in time and we don't see a need for
further regulatory guidance.
CHAIRMAN JACKSON: You are saying there is clarity
with respect to the following two things. One is
categorization of the SSCs, the structure, systems and
components, particularly with respect to those that are the
nonsafety-related ones that are included within the scope of
the rule.
MR. RUSSELL: That is correct.
CHAIRMAN JACKSON: There have not been
difficulties in terms of the clear understanding between the
NRC and licensees as to what is meant?
MR. RUSSELL: There has been some dialogue in the
context of the phrase, "could cause a trip" and how that is
being implemented. The approach that the Staff is taking is
if it has cause to trip at that facility or operating
experience from like facilities shows that it has cause to
trip or if your analysis of record such as your submitted
updated final safety analysis report or your IPE indicates
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that that is a potential cause of a trip, that that should
be the scope of what is within coverage.
If, on the other hand, you are monitoring at the
balance of plant level, say reactor trips, and you have a
system that is fault-tolerant, that is you have four trains
of cooling water for your main condenser and you can
tolerate the failure of a cooling water pump for your main
condenser and not have a trip, then that would not
necessarily be within scope.
If, however, you later through operating
experience have one, it certainly would be something you
would have to monitor as a result of it having caused the
plant trip, determine the corrective actions, et cetera.
So there has been some debate which has been along
the lines of the esoteric of how far do you go down --
CHAIRMAN JACKSON: Is there clarity today?
MR. RUSSELL: I believe we are getting there. It
is going to be a challenge to make sure it is consistently
understood throughout the inspection ranks.
CHAIRMAN JACKSON: Will there be clarity on July
10?
MR. RUSSELL: My view is I believe we have
provided clear guidance. Whether it is fully understood in
all cases, when it has come down to the specifics of what
systems or components should be monitored, we have not had
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significant debate.
CHAIRMAN JACKSON: Is it clear to our people?
MR. RUSSELL: Yes.
CHAIRMAN JACKSON: And then I would like to know
from each of the regional -- I have the same questions and I
would like each of the regional administrators to comment.
MR. MILLER: There has been training of several
kinds. There has been training that has been multiple days
of the individuals who will specifically be out doing these
inspections and then there has been the other training which
was the training provided to all of the inspectors who need
to have general knowledge and so I think the training that
has been provided has been very good, very complete.
CHAIRMAN JACKSON: And there is clarity in terms
of what the performance standards are, I mean what we are
monitoring against?
MR. MILLER: I am not an expert but as best as it
has been described to me, I understand.
MR. MARTIN: Madam Chairman, there has been very
good training. But training does not give me the confidence
to say there is clarity in everybody's mind.
As a result, we have been very selective in who
are going to be the first individuals involved in these
inspections, there is going to be a lot of work with the
headquarters organization and the other regions to make sure
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they have a consistent understanding and then, with that
nucleus of individuals who have a consistent understanding,
it will then be brought. We have trained more people than
that, but we have selected the first few teams who are going
to be doing the inspections.
I am confident that we have provided the kinds of
training. We have not tested that and that testing is going
to happen in the field with supervisory oversight and we're
going to get feedback. I am sure there are going to be some
course corrections we need to make to establish that clarity
and consistency across my region and other regions.
CHAIRMAN JACKSON: That supervisory oversight is
going to be provided?
MR. MARTIN: The first teams are going to be led
by headquarters.
MR. EBNETER: Well, I agree there has been good
training. The NRR Staff has done well on it. I think that
Staff needs more training in concepts of reliability-
centered maintenance. I have maintained that for several
years.
With regard to clarity, no, I don't think so. Let
me -- the maintenance rules --
CHAIRMAN JACKSON: You don't think what?
MR. EBNETER: No, there is not much clarity.
The maintenance rule is a performance-based rule.
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That opens the door and gets you out of one size fits all.
That gives each licensee lots of options and when the
inspectors start going out, we'll get some idea how much
clarity there is there.
CHAIRMAN JACKSON: Is there clarity within the
minds of our own people?
MR. EBNETER: I think as Tim and Bill and
everybody has commented, I think we are converging on
clarity but the inspection process is where we are going to
see how much there is and I can tell you, dealing with
licensees, each one has developed his own program around
some umbrella type rule. The inspectors when they start
looking at these differences somebody will have to reconcile
these differences. Part of it will come from what Bill
talked about.
If you have violations, they will go through this
headquarter process of an overview but it's -- I don't think
that full implementation of the maintenance program is going
to be as easy as we may think. That's my view.
MR. CALLAN: I think Stu stole some of my thunder,
Chairman. I think the industry is collectively holding its
breath on this. The feedback I get is there is a lot of
skepticism about whether or not primarily the regions can do
it. I think the Program Office has done a good job. We
just had training last week, three days of it, for our
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regional staff. I sat in on some of it. I thought the
training was quite good, very little to complain about
there.
I think the challenge is going to be in the
implementation. We are going to unleash dozens of
inspectors eventually who serve their apprenticeship under
different rules, different structures and that's going to
be -- I think that is analogous to the challenge the agency
faced a few years ago with the implementation of the Quality
Management Rule in the medical arena and I think --
COMMISSIONER ROGERS: Oh, boy.
[Laughter.]
MR. CALLAN: I think we are learning from that and
I think this decision to run all enforcement issues through
a central clearinghouse that Bill Russell mentioned is a
direct offshoot of that experience. But it is going to be a
challenge for us.
MR. RUSSELL: The aspect is going to be more of a
challenge as it relates to clarity. It is my understanding
that it is the licensee that sets the performance goals and
then monitors against those goals. So issues with respect
to whether they have established appropriate goals --
CHAIRMAN JACKSON: Right.
MR. RUSSELL: -- or not will be an issue that will
be debated. The fact that they have to have a goal and
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monitor against the goals and they have to identify systems
within the scope, those mechanics are straightforward.
That's where the clarity --
CHAIRMAN JACKSON: Where the rubber meets the
road.
MR. RUSSELL: Where the rubber meets the road. Is
it performing consistent with your goal, and if it isn't --
CHAIRMAN JACKSON: And is the goal appropriate.
MR. EBNETER: The devil is in the details.
MR. RUSSELL: We've got several cases where the
performance assumed, for example, in IPE is not consistent
with the actual performance and so the question becomes,
what are you doing to improve equipment performance or are
you just going to go in and recalculate the goal and say
something less is appropriate? That is going to be where we
are going to get into difficulty. That is going to be, in
my view, further down the road.
The first step is going to be to make sure that
they've got appropriate coverage of scope, they've got the
systems in there collecting the information, they have the
hard data to understand what has been the performance. The
harder part is did the performance match the expectation
and, if not, what's being done to fix it.
CHAIRMAN JACKSON: Okay. Let me just ask one
other question.
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Let's go back to the issue of lack of regard for
regulatory compliance that has come out with respect to
certain circumstances we have been dealing with. Do we have
sufficient data to answer the questions of how pervasive a
problem there may be and for how long at this stage?
MR. RUSSELL: That's really back to some similar
questions you asked me at the end of May.
CHAIRMAN JACKSON: Yes, but I'll ask you every
time.
MR. RUSSELL: We believe that we have a few
facilities where we have a pervasive problem and we have a
number of actions under way at other facilities where we
have some concerns but we have not yet done sufficient work
to describe the scope of the problem so there will be a
number of additional team inspections and inspection
activities where we have prioritized not just for the few
that have been discussed at the table today but for other
facilities where we have some concerns to gather
information.
As well, we are continuing our process of
documenting in every inspection report conformance to the
FSER so that database is continuing to grow.
CHAIRMAN JACKSON: So you want me to let you work
your plan?
MR. RUSSELL: Yes, and get back to you in the
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August time frame.
CHAIRMAN JACKSON: I'm willing to do that.
Because we have your commitment.
Commissioner Rogers?
COMMISSIONER ROGERS: Nothing, thank you.
COMMISSIONER DICUS: I have one more question. I
want to shift course a bit and ask a question regarding
materials licensees. Do you have criteria to categorize
licensees much in the same fashion as we are doing them with
the plants?
DR. PAPERIELLO: Actually, yes. I initiated a
program for fuel facilities. I discussed it at this senior
management meeting to systematically review fuel facility
performance along the same line as similarly is done for
reactors and so if we would have a problem facility, we
would be able to bring it to the attention of the senior
managers.
I kind of characterized my program as different.
Reactors are -- you have relatively low probability events,
I mean big events, with very high consequences. Or I have a
program that is characterized by much higher probability of
the events. So you actually have actual events, you have
overexposures, you have medical misadministrations, you have
lost material that winds up in the public domain and exposes
people.
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But the consequences are lower. So now you have
an issue whether or not the risk is comparable on the
material side as the reactor side. My guess is, insofar as
one believes the linear dose model, in fact the consequences
are comparable but it's a different sort of thing. Of
course, public reaction is different. People accept
accidents which have low consequences versus those which
have very high consequences, even though the overall risk in
the low consequence may be higher.
COMMISSIONER DICUS: When you used the term "low
consequence," you're talking about in terms of the number of
people who may be involved or the --
DR. PAPERIELLO: Or the overall dose. In other
words, we are talking about doses of millirems to small
numbers of people or, in some case, rem. But, you know, a
reactor accident is characterized by potentially giving
people hundreds of rem, affecting areas comparable to a
county in size, I mean, versus a materials accident that
just can't create the same kind of a consequence but you
have more of them.
COMMISSIONER DICUS: Okay, so the only type of
licensee that you have done this for are the fuel cycles,
you haven't done this for other types of licensees?
DR. PAPERIELLO: No.
CHAIRMAN JACKSON: Any other questions?
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[No response.]
CHAIRMAN JACKSON: Well, I would like to thank the
Staff, all of you, for a very informative and comprehensive
briefing. And in closing, I would like to make a few
comments on the plant evaluation process.
The Staff had been previously asked by the
Commission to improve first the way you perform integrated
assessments of information obtained from NRC inspections and
licensing activities so that problem plants will be
identified earlier and, secondly, that you improve
consistency in regulation among between headquarters and the
regions and among the regions as well as the objectivity of
the senior management meeting process.
I had requested that you identify what
supplemental actions the NRC should consider when a plant
remains on the watch list for an extended period and since
the last senior management meeting, you have sent to the
Commission draft management directives for the plant
evaluation processes and as well as for the senior
management meeting and in these documents you've done a good
job of describing the senior management meeting process and
the other plant evaluation processes used by the agency.
And when finalized and made publicly available, I believe
this documentation will make the process more transparent to
licensees and the public.
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The new senior management meeting nuclear power
plant performance evaluation template contributes to
providing structure and consistency to the decisionmaking
process at the senior management meeting and the
standardization of the plant performance reviews through the
guidance to the regions contributes to consistency among the
regions in evaluating plants and in inspection planning, as
well as in providing input to the senior management meeting.
As we have discussed, the newly developed plant issues list
will clearly help to identify objective data to be used and
considered.
The Staff has also identified actions for plants
that remain on the watch list for extended periods. Much of
that seems to be pulling into one place and codifying what
already exists and there are two statements to be made about
this. One is that NRC management as one draws together
these various measures in a more objective manner should
exercise its regulatory authority in a timely manner.
Timeliness is the issue here. And I have also requested a
methodology be developed which I know you are working on to
address sustained poor performance but with trigger points
now for NRC action, including special inspections, including
vertical slice ones or reviews if warranted.
The point being that there have to be consequences
for a plant continuing to be on the watch list. Either the
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plant should come off the watch list if it really has
improved or if it does not improve, it must be closely
examined and closely examined to find out what the root of
the problem is and, if it's bad enough, for possible
shutdown after an extended period of poor performance if we
made an assessment that safety margins have been eroded
sufficiently.
An area that I would particularly like the Staff
to continue to evaluate is the development of indicators.
That is a difficult area which will tell us whether a plant
should be discussed or placed on or deleted from the watch
list. Now, the use of the senior management meeting plant
performance evaluation template and the standardization of
the plant performance reviews in conjunction with the
expanded use of the plant issues list should allow the
development of such indicators.
And to further accomplish this and to enhance our
efforts to address problem plants, the starting point should
be focusing on those dominant and recurring characteristics
that have been placed on the problem plant list and these
seem to include three characteristics. That is a high rate
of operational events; second, inadequate engineering and
technical support; and, third, management ineffectiveness.
Each of these have been characterized by some fairly
objective data.
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The last two comments I have are that we have to
work hard to see that the maintenance rule is as effective
as we would like it to be. And that where there -- that
there is real clarity in the minds of our own people as to
what the rule means and what is expected of them relative to
the rule and we also have to work the issue of clarity
between us and licensees in areas where there still are
questions and that as enforcement issues are tracked through
a central clearinghouse that you spoke of, but more broadly
that the enforcement actions and the risk significance of
what the enforcement is being taken with respect to track
with each other.
The only final comment relates to Millstone and
that is that since the Millstone -- because of the
pervasiveness of the issues here and the significance for
the NRC and the fact that the restart at any rate is being
done under NRC Manual Chapter 350, as well as in response to
the 50.54 letter, I believe it is appropriate that you come
back to the Commission before that restart occurs.
So do any of my fellow commissioners have any
closing comments?
COMMISSIONER ROGERS: No, thank you.
CHAIRMAN JACKSON: If not, thank you.
We stand adjourned.
[Whereupon, at 12:02 p.m., the meeting was
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concluded.]
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