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Home > Electronic Reading Room > Document Collections > Commission Documents > Commission Meetings, Slides, Transcripts, Meeting SRMs, and Full Written Explanation for Closed Meetings > 1997
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01/29/1997
1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
***
BRIEFING ON OPERATING REACTORS AND FUEL FACILITIES
***
PUBLIC MEETING
***
Nuclear Regulatory Commission
Commission Hearing Room
11555 Rockville Pike
Rockville, Maryland
Wednesday, January 29, 1997
The Commission met in open session, pursuant to
notice, at 10:00 a.m., the Honorable SHIRLEY A. JACKSON,
Chairman of the Commission, presiding.
COMMISSIONERS PRESENT:
SHIRLEY A. JACKSON, Chairman of the Commission
KENNETH C. ROGERS, Member of the Commission
GRETA J. DICUS, Member of the Commission
NILS J. DIAZ, Member of the Commission
EDGAR McGAFFIGAN, JR., Member of the Commission
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STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
JOHN C. HOYLE, Secretary
KAREN D. CYR, General Counsel
HUGH THOMPSON, JR., Acting EDO
CARL PAPERIELLO, Director, NMSS
HUBERT MILLER, Region I Administrator
LUIS REYS, Region II Administrator
BILL BEACH, Region III 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. 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
fuel facilities. The senior management meetings are
conducted semi-annually to ensure that the NRC is properly
focusing its resources on facilities that need -- that most
need regulatory attention based on safety performance and on
issues of greatest safety significance.
The Commission would be interested in hearing
about steps taken to improve the quality of discussions at
the meeting and to enhance the consistency of decisions and
if you were able to make progress in these areas.
I understand that copies of the slide presentation
are available at the entrance to the meeting room and unless
the commissioners have any comments, Mr. Thompson, please
proceed.
MR. THOMPSON: Thank you, Chairman Jackson,
Commissioners.
With me at the table this morning are Carl
Paperiello, who is the director of NMSS; Frank Miraglia, who
is the acting director of NRR; Hub Miller, who is the Region
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I regional administrator; Luis Reyes, who is the regional
administrator for Region II; Bill Beach, who is the regional
administrator for Region III; and Joe Callan who is the
regional administrator for Region IV and will soon be the
EDO, and I know he looks forward to that day. Certainly I
do.
[Laughter.]
MR. THOMPSON: As you know, the senior management
meeting was initiated in 1986 in response to the loss of the
feedwater event at Davis-Bessie, which occurred in June of
1985. This meeting was the twenty-second such senior
management meeting.
Over the past 10 years, the senior management
meeting process and the analysis used in support of the
meetings and our decisions has evolved.
In response to the Commission staff requirement
memorandum following the June 1996 briefing on operating
reactors and fuel cycle facilities, the staff continued to
look at further changes that could be made to improve the
basis for judging whether a plant should be based on the
watch list.
For this meeting, several new initiatives were
adopted to strengthen the scrutability of the senior
management meeting process, to improve the quality of the
discussions and to enhance the consistency and the clarity
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of the decisions. These steps included placing an increase
emphasis on the staff's current assessment of plant safety
performance as opposed to licensee plans and projections,
modifying the format for the discussion of plant background
information focusing on the most significant safety
performance issues. Using information summaries or slides
is what we used to identify the strongest reasons for and
against increased agency attention, particularly for those
plants that were being discussed, not those that were on the
watch list which we used our watch removal format.
Improving the quality and completeness of the
record in the senior management meeting discussions so that
others who look at the meetings and result of the meetings
in the past would be able to understand better what the
basis for our decisions were. And, finally, placing
increased emphasis on obtaining and integrating the views of
each senior manager at the meeting.
We early on recognized the importance that we each
bring to the senior management meeting, our experience from
other regions, our experience from headquarters, and we
encouraged full and open discussion by everyone present to
present what information they had and to also challenge on
the slides the arguments for increased attention as well as
those for not taking increased senior management attention.
I must admit the success in the latter part about
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having open discussions kind of exceeded my expectations
and, in fact, at this particular meeting we only focused on
the operating reactor events and did not have an opportunity
to discuss any of the material on fuel cycle facilities and,
in fact, we continued the meeting one more day in the
afternoon on a Friday after the two-day meeting we had in
Region IV.
CHAIRMAN JACKSON: What are your plans relative to
materials licensing and fuel cycle facilities?
MR. THOMPSON: We have not made any specific
plans. We did ask Carl at the meeting whether or not he had
any unique facilities that needed discussions. He indicated
at that time there were none but Carl and I have discussed
the need to see whether or not we needed a different format.
Obviously, the true focus of these meetings have
been on operating reactor and we have had some fuel cycle
facility -- fuel cycle facilities in the past that we have
discussed and Carl knows that he is able to identify and
bring those up. He is also looking at some other approaches
to look at those.
But I think we will turn to Carl another day, if
we can, to give us some suggestions on what processes that
we need to do, unless you have anything you want to add
today?
DR. PAPERIELLO: Other than the fact we have
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initiated a formal process within NMSS to do plant
performance reviews, just as we do on the reactor side for
fuel cycles, and we are expanding that to include vendors of
dry cast storage systems. So we are -- I think we are
behind the curve with respect to NRR but we are looking at
doing systematic performance reviews.
Frankly, I did it for very selfish reasons, so I
could have a view of a particular facility without, you
know, coming out of the blue. So we have initiated a formal
process for doing that and if a facility looks like the kind
of facilities we discuss here, then it would be brought to
your attention.
CHAIRMAN JACKSON: Okay, when do you expect to
begin to implement that?
DR. PAPERIELLO: Well, the plant performance
reviews for fuel cycle we are already implementing and for
vendors of dry cast, we are reviewing that this year.
CHAIRMAN JACKSON: Okay, Commissioner Dicus?
COMMISSIONER DICUS: Yes, I just wanted to add,
based on the Chairman's comment, to pursue and actively
pursue reviews of these type facilities and plants in a very
timely fashion.
CHAIRMAN JACKSON: And in a consistent fashion.
DR. PAPERIELLO: Yes, and we do that -- you know,
we try to keep the Commission, obviously, informed on
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particular issues. We have the site decommissioning problem
plants and cleanup activity. So we will continue to look at
ways to improve that aspect.
This senior management meeting resulted in the
addition of five stations to the NRC watch list as Category
2 facilities. Also, two facilities received trending
letters.
Before I turn the meeting over to Frank Miraglia
and the regional administrators, I would like to highlight a
few points. First, because a plant is listed on the watch
list does not mean that it is unsafe to operate. If we
conclude that a plant cannot safely operate, we will issue
orders to shut the plant down in order to ensure adequate
protection of the public health and safety. A senior
management meeting is not such a forum that would do that.
Our objective in placing a plant on the watch list
in Category 2 is to identify those plants that have had or
are having weaknesses that warrant increased NRC attention
from both headquarters and the regional offices.
Second, it is apparent that the number of stations
on the watch list has increased. I believe that this is due
in part to the recent refocus of NRC's attention to the
engineering design area. As you know, this area had not
been a major focus of NRC's inspection activities since the
early '90s and weaknesses in this area contribute directly
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to the addition of two stations to the watch list.
Third, I mentioned earlier that we are trying to
enhance the consistency of the decisions made at the senior
management meeting. This led to our decision to place Salem
on the watch list as a Category 2 facility.
Let me be clear. Salem's overall safety
performance has not declined since the June 1996 meeting.
We believe Salem's efforts to improve its performance are
correctly targeted and the NRC is satisfied with their
overall approach.
This action was taken because Salem was not placed
on the watch list at an earlier senior management meeting
when, in hind sight, overall safety performance clearly
warranted such action.
This was the most difficult decision made at this
senior management meeting because delay in our action could
cause an unintended disruption of the ongoing improvement
efforts at both plants. The basis for placing our action
has been articulated in our letters to the Public Service
Electric and Gas and in our press release, both of which
include our support of the current restart efforts at Salem.
Hub Miller will address this station in more
detail in his remarks.
Finally, Bill Beach will discuss in detail the
performance of Commonwealth Edison and its Dresden, Lasalle
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and Zion facilities. Commonwealth Edison is implementing a
number of initiatives ensuring the ability to perform
independent self-assessment to find their own problems,
which is commendable.
However, I would like to mention now that because
the longstanding performance problems at Commonwealth Edison
facilities, which is over the past ten years, four of the
six Commonwealth stations have received trending letters or
have been on the watch list. I have signed a
request-for-information letter, pursuant to 10CFR50.54(f)
that requires Commonwealth Edison to provide information
that will allow the NRC to determine what actions, if any,
should be taken to assure that it can safely operate its six
nuclear stations simultaneously while sustaining
performance.
It is in the best interests of both the NRC and
Commonwealth Edison that history does not repeat itself
anymore and we are committed to work with Commonwealth to
address this issue head on.
I will now ask Frank Miraglia to begin the formal
presentation.
MR. MIRAGLIA: Thank you, Hugh.
Good morning, Madam Chairman, Commissioners.
As has been covered, the senior management meeting
has two principal objectives as it relates to nuclear power
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plant performance. The first is to identify problem
performance and adverse trends before they realize
themselves in actual safety events.
And as noted by the Chairman, we are overseeing
reactor safety. An integrated review is conducted of plant
safety performance at these meetings by considering the
objective information, such as the plant specific inspection
results, operating experience, probabilistic risk insights,
systematic assessment of licensee performance, performance
indicators and enforcement history.
Special attention is given to licensees'
self-assessments and the effectiveness of corrective actions
taken for problems identified by licensees.
Our objective is to identify facilities early that
have negative performance trends or those facilities whose
performance requires agency-wide close monitoring and
oversight.
We also discuss plant inspection activities, NRC
management oversight and resources for individual plants
discussed.
I will summarize the overall results of this
recent senior management meeting, after which the regional
administrators will discuss facilities that have been
categorized as needing agency-wide attention or where we
have taken action as a result of the senior management
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meeting.
May I have Slide 2, please.
Category 1 is a list of those plants that are
removed from the NRC Watch List. No plants were removed
from the list during the January, 1997 senior management
meeting.
Slide 3.
COMMISSIONER ROGERS: Excuse me, just before you
leave that, the Staff sent up to the Commission in May a
SECY 96-093. It described a couple of techniques or tools
that would be used at the senior management meeting.
One of them was the Plant Performance Evaluation
Template. The other one was the Watch List Removal Matrix.
I wonder if you could say anything about how you
used those in any of your decisions.
MR. MIRAGLIA: Yes. With respect to the latter,
the removal matrix, that was used for the plants that had
already been designated as Watch List plants to determine
whether there was sufficient progress to have them removed
from the list and such matrices were used for Dresden,
Indian Point.
COMMISSIONER ROGERS: So it was used?
MR. MIRAGLIA: Yes. We have also used it in a
unique way for Salem in the context of, as Mr. Thompson has
explained, in hindsight Salem perhaps should have been on
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the list earlier and, given that, we said in the decision to
put Salem on the list we should look at those attributes to
determine whether sufficient progress had been made such
that they would have been removed from the list.
The result of that evaluation was we couldn't
conclude that they met that Watch Removal List criteria.
In terms of the former, in terms of the template,
those elements are looked at. In the discussion of the
plants the performance indicators, the events at the
plants --
COMMISSIONER ROGERS: Well, I know the template
does involve a lot of things that you have looked at in the
past.
MR. MIRAGLIA: Yes.
COMMISSIONER ROGERS: Let me ask another question,
whether you used it in a systematic way.
MR. MIRAGLIA: I think what we tried to do in
terms of the Plant Issue Matrix is try to integrate those
kinds of things and bring those higher points from the
screening meeting to be discussed in the meeting.
We are still working on that matrix, need more
time to get that into a more systematic process.
The removal matrix we had been using for a longer
time and it has more discipline and more consistency. We
did attempt to use it but I don't think it had the degree of
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formality where we are.
CHAIRMAN JACKSON: Mr. Thompson, did you have a
follow-on comment?
MR. THOMPSON: No. I think Frank covered that.
MR. MIRAGLIA: With respect to the Category 2
facility, that's Slide 3, the Category 2 facilities are
those whose operation is closely monitored by the NRC.
These facilities include Indian Point, Maine Yankee, Salem I
and II, Crystal River, Dresden II and III, Lasalle I and II,
and Zion I and II.
Indian Point III and Dresden II and III were
previously designated as Category 2 sites.
The four additional sites -- Maine Yankee, Salem I
and II, Crystal River, Lasalle, and Zion, were added, and it
was special circumstances with respect to Salem's addition
as discussed by Mr. Thompson.
Slide 4.
COMMISSIONER DICUS: I have a couple of questions
on the slide before you go forward, and I am trying to
understand why the Category 2 list has essentially more than
doubled, because I think that is a very critical point.
I may have to go back to some opening statements
that Mr. Thompson made in trying to understand this a little
clearer.
I think you indicated in your opening statement
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that in this particular senior management meeting you did
change or modify how you looked at the plants or the format
that you used.
Could you clarify that statement?
MR. THOMPSON: Yes. We had as part of the effort
to improve the senior management process -- we hired an
independent consultant who looked at the process,
interviewed many of the senior management that had
participated in the process, interviewed some of the
industry, and looked -- and identified and made some
suggested changes that we should consider.
The one that we were able to look at in the
timeframe that we had available, the criticism was that the
previous senior management meeting had to some extent been
dominated by the regional administrators, not because of
inappropriate aspects -- because they are the ones
responsible for the plant -- but because they had such a
detailed knowledge and their knowledge was almost
overpowering everybody else's knowledge at the meetings.
So what we elected to do was have that detailed
knowledge to put the arguments both for increased agency
attention as well as not having increased agency attention.
That is, have the individual who knows the most present the
argument on both sides of the issues. I think that was the
key element or the key critical element that we did in
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addition to having all the managers who then had experience,
had similar experience with similar plants, who may have
even had experience with those plants challenge the regional
administrators on those issues, on his articulation, and did
they withstand the scrutiny that the senior managers brought
to those issues, and that in essence led to, as I said
earlier, a much more vigorous discussion on the plants that
we had and in essence was one of the changes.
I think just the information was better. I think
the reasons I articulated here with our new focus of the
design engineering aspects as well as the decision we made
with respect to Salem with respect to consistency and
scrutablity, understandability of the approach contributed
to the addition of three of those new facilities.
Zion and Lasalle, obviously you'll hear the
specifics with those later on.
COMMISSIONER DICUS: Okay. Then the report you're
referring to is the Arthur Andersen consultant?
MR. THOMPSON: That's correct.
COMMISSIONER DICUS: I guess I was under the
impression from a conversation that you and I had had a few
days ago that the Arthur Andersen report really had not been
used, or any part of it. So I'm hearing now that a part of
it, perhaps, was used or was a guidance.
MR. THOMPSON: The Arthur Andersen recommendations
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were not used. We looked at the comments or the conclusion
of the Arthur Andersen study as it relates to the regional
administrators having the predominant knowledge that was
available and the approach outlined by Arthur Andersen was
not used, the information in the Arthur Andersen report was
not used in making any decisions.
What we did elect to do is to have the regional
administrators articulate both sides of the arguments that
we would have to make a decision on, which was not part of
the Arthur Andersen recommendation. That was one that we
looked at the Arther Andersen, noting that we could improve
our decision-making process by providing the broadest amount
of information to the senior managers there and that was the
change that we made. It had a slight nexus, but it was not
using the approach recommended by the Arthur Andersen
approach.
COMMISSIONER DICUS: Right. Just a quick comment
and I'll move on.
I'm in the process still of reading and studying
the Arthur Andersen report which seems to have some value,
but I think if we're going to use this report or we're going
to perhaps change the way plants are evaluated, that
probably is a -- I see that as a policy decision that the
Commission needs to make and then give the directive.
MR. THOMPSON: Absolutely. We still used our
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category criteria for making our decisions and what we tried
to elicit was the best information that we could have
amongst all the senior managers in having a full and frank
dialogue in reaching those decisions.
It was the full and frank dialogue and exchange of
information that we had that was improving the process we
had in place. We've always had the ability to articulate
the views of the directors of NRR, other people there,
Office Enforcement, Office Investigation, whoever was there.
This just was a mechanism which facilitated that
exchange of information that we've had in the past.
COMMISSIONER DIAZ: Madam Chairman?
CHAIRMAN JACKSON: Go ahead.
MR. CALLAN: Let me just make the quick comment.
As a practical matter, Commissioner, we had the Arthur
Andersen report only a few weeks before the senior
management meeting. The regional administrators and
regional staff had pretty much put together the briefing
sheets. We were in a position where we really, as a
practical matter, couldn't implement the Arthur Andersen --
even if we had wanted to, so we elected to make some
adjustments as Hugh Thompson mentioned, that were doable in
a very short period of time, very modest in terms of
structure, modest adjustments.
CHAIRMAN JACKSON: But you did not use the Arthur
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Andersen performance indicators in making your judgments, is
that what you're telling us?
MR. THOMPSON: That is it. We did not use them.
In fairness, the slides were put up there simply as a matter
of observation, but they were not used by any one judgment,
no one used the Arthur Andersen slides because I think we
also said that information, that technology for those slides
was premature, had not been fully evaluated, had not
received peer review and we have had previous experience
with trying to use performance indicators that had not been
ripe and had not been thoroughly evaluated and reviewed. So
we did not use that.
The real benefit from the Arthur Andersen we were
able to implement was to ensure that all participants felt
free to comment, to discuss, to provide their inputs into
the meeting as well as to request the regional
administrators to really present both sides of an argument
that we could then have the ability to reflect on as we made
the decision based on the criteria that we presently had.
CHAIRMAN JACKSON: Commissioner Diaz?
COMMISSIONER DIAZ: Yes. Going back to your
statement that in this senior management meeting, there was
significant discussion and challenge to the regional
administrators and I think that was a wonderful process, if
you look at the position of the regional administrators say
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before the discussion and the challenges, was any of the
decisions changed or the discussion just supported the
decision of the regional administrators?
CHAIRMAN JACKSON: Perhaps there's a way we could
address that question. Are we going to hear from each of
the regional administrators?
MR. THOMPSON: We will hear from them, yes.
CHAIRMAN JACKSON: Well, perhaps each one of them
could speak to that.
COMMISSIONER DIAZ: No, I think this is a generic
process and the question is very clear. The regional
administrators, each one has a position documented because
they know the plants better. You discussed them, challenged
them. Was, in any one case, that position changed by your
discussion?
MR. THOMPSON: The position is not articulated up
front, Commissioner Diaz. What is done, in the cases, we
discussed the plant, discussed performance issues, and we
hear all of the plants as an aggregate set, reflect over the
evening, and then we come back the next day and say, based
on what we've heard, where are we with respect to the
categorization of these facilities.
What was done in this case is exactly what was
done in most of the other senior management -- in fact, all
of the senior management meetings that I've attended where
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the facts are presented and the difference, in this case, is
the regional administrators say, here is issues based upon
the performance in the last six months that would indicate
or warrant increased agency attention or indicate adverse
performance that we need to consider, action within the
content, here's the facts that would argue and so both sides
of the issues were presented in that way.
So if any of the issues changed is a difficult
question to answer because it wasn't presented that way.
Those decisions were made the following day.
COMMISSIONER DIAZ: Then I would defer to Madam
Chairman's comment which seems to be very appropriate that
then the regional administrators might illustrate how
effective the process is, if it's actually helped them,
changed their decision, or the fact that they already are so
much more knowledgeable than anybody else, they were able to
maintain and support the position they have taken prior to
the meeting.
CHAIRMAN JACKSON: I think that's what we can do
as we go through.
MR. THOMPSON: Frank has some more things.
MR. MIRAGLIA: With respect to Category III
facilities, Slide 4, Category III facilities are the last to
shutdown and require Commission authorization to operate,
that the staff monitors closely.
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Millstone I, II and II remain in Category II.
Subsequent to the last meeting, the Commission meeting on
the senior management meeting results, those plants were
categorized as Category III plants.
As the Commission is aware, we have a meeting
tomorrow on Millstone at 10:00 a.m. Northeast Utilities
will be here to give status. Dr. Travers and the SPO staff
will also be giving a staff presentation and we won't be
discussing the Millstone units in any detail with respect to
the rest of the senior management meeting and we'll handle
that tomorrow. Slide 5, please.
The following plants requiring trending letters
were identified at the senior management meeting and that
was Clinton and Point Beach I and II. Slide 6.
Hope Creek was issued a letter. At this recent
meeting the senior managers concluded that the licensee had
reversed the adverse performance trend at Hope Creek. Such a
letter will be sent indicating that.
Slide 7 has already been covered by Mr. Thompson.
There were no priority material issues identified. In
fact, there was no real discussion of material facilities at
that.
Hub Miller will discuss Indian Point III, Maine
Yankee, Salem and Hope Creek, Luis Reyes will discuss
Crystal River and Bill Beach will discuss Dresden, Lasalle,
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Zion, Clinton and Point Beach.
At this point I'll turn the discussion over to Hub
Miller for --
COMMISSIONER ROGERS: Just before we move off, I
have one question, just a general question on our policy
with respect to trending letters.
Once a trending letter is issued and there has not
been a correction of adverse trend letter issued, there
could be some period of time there. Several SM meetings
could take place, so is it clear that that initial trending
letter still is in effect in a certain sense?
In other words, until we issue a correction, an
acknowledgement of a correction of adverse trends, we don't
issue anything each time we have a senior management meeting
if a plant has received a trending letter and hasn't
received a correction of adverse trend letter, is that the
process?
MR. MIRAGLIA: That's what the process is and then
with respect to the results of that, the results of the last
meeting where Hope Creek didn't receive a letter the
regional administrator would indicate that Hope Creek was
discussed and that no action was taken, and that's the
judgment that the trend hasn't been abated, so that is the
process and the policy, and that is articulated within the
context of the draft management directives and some of those
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that are out right now, sir.
COMMISSIONER ROGERS: It does seem to me that
there is a little gap there in a certain sense that when we
issue a trending letter and then the licensee takes some
corrective action but it isn't enough to cause us to issue a
correction of adverse trend letter.
There is nothing on the record that indicates some
acknowledgement at least out of the senior management
meeting. Now maybe it isn't necessary but it does look to
me like there's a sort of disconnect until we reconnect with
the issuance of a correction of adverse trend.
MR. MIRAGLIA: We, in fact I think early on, we
were using the process where we tried to issue something at
the end of each meeting and many times it's -- the period
wasn't soon enough.
COMMISSIONER ROGERS: Yes. I am not questioning
your decision. I am just questioning the process that
simply leaves it unaddressed.
There was a senior management meeting, the letter
came out --
MR. MIRAGLIA: We will be re-examining the senior
management process I think as we all know, and certainly I
think that would be one element that we would --
COMMISSIONER ROGERS: Well, I would suggest you
take a look at that.
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MR. MIRAGLIA: We certainly will.
COMMISSIONER ROGERS: Because it does seem to me
there's a little bit of a gap in the process.
MR. MIRAGLIA: We'll address that and have a
recommendation to the Commission on that.
CHAIRMAN JACKSON: Commissioner?
COMMISSIONER McGAFFIGAN: I am going to ask, are
you going to mention the superior performer letters at any
point, the little bit of good news that comes out of this?
Could you also explain the process to me whereby you decide
who gets a superior performer letter?
MR. MIRAGLIA: Yes. The management directive
indicates what is the criteria for consideration for
superior performance, the management directive paper that
Commissioner Rogers referred to, and it's essentially what's
the performance evaluation in terms of SALP being Category 1
in the major SALP areas not having significant enforcement
actions for a period of time, and if it meets that criteria
the judgment is that it is a candidate for receiving such
recognition.
The policy has been changed over time with the
Commission and the current policy is that plants, since the
last senior management meeting, that meet that criteria are
discussed, saying that it meets the criteria and such a
letter should be sent, and that is sent subsequent to the
. 26
management meeting. It is usually a two-week period.
CHAIRMAN JACKSON: I think the Commission would
like you to say who got such letters this time.
COMMISSIONER McGAFFIGAN: Is it fair to --
MR. MIRAGLIA: Yes. It was Harris facility and
Turkey Point facility that received such recognition -- will
receive. They have not been notified yet -- but the policy
would be such notification would be two weeks subsequent to
this meeting.
The previous guidance from the Commission was to
focus --
COMMISSIONER McGAFFIGAN: I'm sorry --
MR. MIRAGLIA: -- on this, but we can revisit that
issue also.
COMMISSIONER McGAFFIGAN: We'll revisit that too.
CHAIRMAN JACKSON: Please go on.
MR. THOMPSON: Mr. Miller?
MR. MILLER: Let me first of all address the
question -- I went into this meeting with an open mind. I
had no hard held view.
The modifications that were talked about were
characterized as modest and simple, but while they were
modest and simple, I think it was a significant improvement
in terms of having before all of the senior managers those
arguments that are most compelling for taking increased
. 27
action and those arguments that are most compelling for not.
So my job as regional administrator was to,
knowing what I know about the plants, was to feel
responsible for assuring that the facts are known to all of
the senior managers, and also do a good job of presenting
arguments on both sides, and I think it did facilitate
discussion.
As you said, the discussions were longer than
normal, so to answer your question I had no hard view before
the meeting and I honestly looked for the discussion to draw
conclusions and I am happy, very happy, with the process.
I think it did provide what we are all looking
for, which is greater consistency plant to plant, meeting to
meeting, and great scrutability of our results.
With that, let me first talk about Indian Point
III.
Indian Point III was first placed on the Watch
List as a Category 2 plant in June of 1993. At that time
the plant was shut down to deal with a number of technical
and staff performance issues.
Governed by a confirmatory action letter, the New
York Power Authority conducted an outage lasting about two
years.
Following restart in June of 1995, the plant
operated for only a short period of time before equipment
. 28
problems and some significant personnel errors again caused
the Power Authority to shut the unit down for an extended
outage.
The outage lasted about six months.
Over the period from June, 1993 to early 1996,
numerous management changes were made at both corporate and
site levels as the licensee attempted to address performance
problems.
Since starting up in April, 1996, the plant has
operated at power nearly continuously. During this time the
senior management team has been relatively stable and has
provided strong oversight of plant evolutions and major
maintenance activities.
A generally conservative approach to plant
operations has been taken. Improvements noted in the last
senior management meeting, communications and the conduct of
control room activities have continued. Overall, the number
and significance of personnel errors at the station has
declined but some human performance problems remain,
particularly in the area of work control.
Work control errors, for example, led to
inoperability of an auxiliary feedwater pump on one occasion
and a plant transient on another.
Maintenance activities generally have been
performed well and corrective maintenance backlogs reduced
. 29
significantly over the past six months. While overall
improvement in plant material condition has been observed,
equipment problems continue to challenge operations. These
problems, the majority of which originated in the balance of
plant, resulted in a number of plant transient shutdowns and
power reductions.
Emergent work continued to hamper progress in
reducing engineering backlogs which have been large and
making needed improvements in areas such as safety
evaluations, operability determinations, set point control
and updating and validating design basis documents.
Recently, efforts have been made to better
understand and prioritize outstanding engineering work.
Steps have been taken to refocus attention on problem areas
administration resources have been added, but it is too
early to judge results in the engineering area.
Currently, the plant is in a forced outage to
repair feedwater heater tube links. The station is using
this outage to address a number of equipment issues such as
replacement of leaking pressurizer power operated relief
valves that have been longstanding operator work-arounds.
The power authority is developing plans to address
many of the remaining equipment issues in their refueling
outage scheduled to begin in a couple of months.
Determining whether the station has made necessary lasting
. 30
improvements will require an additional period of
monitoring. This includes at least assessment of the outage
scope and its preparations. It also includes the monitoring
of operations and work control during some portion of the
refueling outage. The last time the plant was refueled was
in 1992 with the extended outages.
In conclusion, after considering the evaluation
factors for removal of a plant from the watch list, senior
managers concluded that Indian Point 3 should remain on the
watch list as a Category 2 facility; that is, a plant
warranting increased attention from both headquarters and
regional offices.
CHAIRMAN JACKSON: Did you, in fact, use the watch
list removal factors in helping making your determination?
MR. MILLER: Yes, ma'am. That was developed
before the meeting and that was also the subject of great
discussion in the meeting, very definitely.
CHAIRMAN JACKSON: Any questions?
[No response.]
MR. MILLER: Next, I will talk about Maine Yankee.
This was the first time that Maine Yankee was
discussed at a senior management meeting. Over the past
year, a number of significant deficiencies at the facility
came to light. Agency understanding of these deficiencies
was developed largely by an independent assessment team
. 31
which conduced a review during the latter half of 1996.
Strengths were noted in some aspects of
operations, such as handling of routine and transient
operating conditions and shift turnovers. The independent
team found station staff to be knowledgeable.
As the independent review was initiated in
response to problems which had come to light regarding use
of computer codes, the broad spectrum of analytical codes
used at the facilities were examined and the team found a
mixed picture. Frequently used codes were excellent but
weaknesses were found in others.
More broadly, the independent assessment team
discovered a number of significant design issues. The
capability of several safety systems was called into
question, particularly for operational power levels above
2440 megawatts thermal.
Coupled with requests about design margins on some
systems were significant weaknesses in the testing of plant
equipment and material condition deficiencies. These
problems revealed broader weaknesses in the area of
engineering support, which is provided by the combination of
Maine Yankee and Yankee Atomic Electric Company staffs.
More fundamentally, the independent team
determined that the weaknesses and deficiencies that exist
appeared to relate to two root causes: Economic pressures
. 32
to contain costs and poor problem identification as a result
of complacency and a lack of a questioning attitude.
Since completion of the independent safety
assessment, additional examples of design issues have been
identified by Maine Yankee in following up on the
independent safety team findings. Configuration problems
have been identified. Failure to provide adequate cable
separation on several systems, for example, were found in
December, resulting in a shutdown of the facility. An NRC
confirmatory action letter was issued at that time,
stipulating actions required prior to startup.
Maine Yankee has developed a plan and initiated
steps to correct the problems. These include committing
additional funds and hiring of new staff, principally in
engineering, maintenance and radiological controls. An
agreement is under development with Entergy Corporation to
obtain outside management expertise in operation of the
facility. This plan is the plan that was submitted on
December 10 and the company will be meeting with the
Commission on February 4, which is next week, to review the
plan.
Much remains to be done, however. The senior
managers determined that increased agency attention is
needed to monitor improvement efforts. As a consequence,
Maine Yankee has been designated as a Category 2 watch list
. 33
facility.
CHAIRMAN JACKSON: I have a question for you.
If Maine Yankee had previously been viewed as a
good performer and, in a certain sense, you've essentially
said that the recent focused inspection, and particularly
the independent safety assessment, were the things that
uncovered problems that suggested that this plant warranted
increased agency attention.
What does this say in terms of the ability in the
normal course of things to uncover these problems or, put
another way, what assurances do we have that we are not
missing them somewhere else and is it suggesting any
renormalizations in our regular inspection program that
needs to exist because it seems that most of what you
considered within the context of the factors that would make
you designate it a Category 2 plant were uncovered in a
special way. So if you could speak to that?
MR. MILLER: Two things. It perhaps is
oversimplifying it to say that it was design alone that
caused this categorization. It was really a combination of
things. It was the coupling of a lack of the questioning
attitude and the design issues that caused the senior
managers to make this judgment.
But, as you know, we are looking at -- and others
might speak to this -- at ways to be able to take deeper
. 34
looks at design and in fact we've assembled resources
through a contractor to permit the staff to do more what are
called vertical slice inspections, which get you into the
details of design, design function.
We are limited as to how many of those we can do,
honestly, but we are on a course of performing these
inspections virtually at all plants in a sequence that is
informed by risk and other things that we know about plants,
picking targets that are most vulnerable first, and we are
proceeding to do that.
Frank, do you want to --
MR. MIRAGLIA: Yes, I would like to address it
perhaps in a broader context. In terms of Maine Yankee
specifically, as the Commission is well aware, there was the
concern raised by the allegations that there were concerns
relative to Maine Yankee's performance developing that led
to the audit. In a concurrent time frame, the issues that
were growing from Millstone, Haddam Neck, et cetera,
experience were ongoing and we were looking at and
identified concerns in the design area.
We had been looking at ways of enhancing our
inspection program to do vertical slice and to incorporate
more of the SSFI type, safety system function inspection, to
look into the design area. We have taken steps on that.
As Hub indicated, subsequent to the senior
. 35
management meeting last June, we have engaged architectural
engineering services to do those vertical slice inspections,
to probe in that type of area. In addition, we have issued,
because of the design weaknesses that have been identified
in several of the facilities, we have issued a 50.54(f)
letter to all the utilities other than the Northeast
Utilities, since they were already under a 50.54(f) letter,
to explain and to state the bases why design control and
configuration management of the plant is being maintained,
what programs do they have and how do they have confidence
that they have those kinds of issues.
The special inspection team, the special
inspection team, grew out of concerns from the allegations
and that focus and we've incorporated in that inspection
team that vertical slice element, so I think we are building
off of the experience we have gained not only through Maine
Yankee but at other facilities and the program is being
redirected in that kind of area and we are gaining
information to say how can we use our resources most
effectively and use the 50.54(f) responses on design control
and focus the appropriate level of inspection on facilities
using that kind of information.
So I think the program is being redirected.
CHAIRMAN JACKSON: Mr. Callan?
MR. CALLAN: Chairman, I just did want to mention
. 36
one important insight that came out of the Maine Yankee
experience that is being addressed. I think the Commission
will shortly be getting a Commission paper describing Phase
II of our lessons learned.
But one of the important lessons learned from
Maine Yankee is the need to more closely couple the
inspection process with the licensing process. That is in
addition to the design and the engineering issues that were
previously discussed.
MR. MIRAGLIA: The scope of the issues that were
considering improvements are even broader as Mr. Callan was
articulating. Those that we have actually taken and
implemented to date, there are further improvements that are
being looked at and the Commission will be hearing those in
the future.
CHAIRMAN JACKSON: Are there any questions?
[No response.]
MR. MILLER: Okay, Salem.
Hugh has already mentioned that the action taken
here was not a reflection of current performance but more a
different perspective on previous decisions made on the
facility.
Since Salem was first discussed during senior
management meetings in 1990 and 1991, after a period of some
improvement, performance problems surfaced again leading to
. 37
discussion of the plant at the June 1994 senior management
meeting.
The event that best illustrated these problems
involved a significant plant transient which occurred in
April 1994. The event which was initiated by sea grass
intrusion on cooling systems resulted in a reactor trip,
safety injection and failure of numerous plant components
which significantly complicated operator response. The
transient revealed numerous equipment problems and operator
work-arounds.
The licensee was required to review the event and
actions being taken to address underlying problems directly
with the Commission in a meeting held in July 1994.
Continuing performance problems led senior
managers to conclude in the January 1995 senior management
meeting that agency concerns needed to be brought directly
to the Board of Directors of Public Service Gas and Electric
in a meeting. This occurred in March of 1995.
Subsequently, additional equipment operability
problems led to technical specification required shutdown of
Units 1 and 2 in April and May of 1995 respectively. Given
the breadth of both the human performance and equipment
problems that were coming to light at this time, the
licensee expanded significantly the scope of its improvement
efforts. Extensive senior management changes were made in
. 38
the summer of 1995.
Following decisions by new management to initiate
retraining of station staff and to undertake major
refurbishment of plant equipment in an extended outage, an
NRC confirmatory action letter was issued in June 1995
establishing actions required before restart of the units.
In monitoring activities at the site since that
time, since the shutdown, we have observed the current
management team that the licensee has assembled to be a
strong one. There have been changes but the team has been
relatively stable and in place for most of the outage.
A much lower problem reporting threshold has been
established and management has been aggressive in addressing
root causes. Significant staffing changes have been made.
Operations and maintenance staffs have now completed
extensive training and requalification programs to both
reinforce fundamental skills and establish higher safety
standards. Steps have been taken to strengthen station
self-assessment, corrective action and work control
processes.
As a result, the number and significance of
personnel errors have declined. Operators have demonstrated
improved ownership of the plant and conservative
decisionmaking.
The outage scope has been extensive for both
. 39
plants. Numerous components have been refurbished or
replaced with more reliable equipment in both safety-related
and balance-of-plant systems. More than 400 modifications
have been made.
These include major modifications or upgrades to
diesel generators, servicewater and component cooling water
systems and the control room. A digital feedwater control
system is being installed and approximately 800 Hagen
instrument modules used in various control and protection
functions are being replaced. This effort is significant
because these Hagen modules were the source of numerous
operator work-arounds before the shutdown. Steam generators
are being replaced on Unit 1.
A comprehensive pre-startup test program is under
way on Unit 2 to assure repair work has been effective.
Engineering organizations are providing stronger support on
equipment and design issues as evidenced by completion of a
recent licensing basis conformance review.
The senior managers thoroughly discussed current
activities at Salem and the basis for past senior management
meeting decisions. The conclusion was that the scope and
depth of the problems that existed at Salem prior to the
dual unit outage, prior to management changes made largely
in 1995, warranted categorizing it as a Category 2 facility
indicating need for increased NRC attention. Past decisions
. 40
regarding Salem's status were influenced by current licensee
management's recognition of problems and efforts being made
to address them.
As a practical matter, however, given the extent
of these problems and the scope of activities, the agency
increased its attention to Salem to a level commensurate
with that given a plant in a Category 2 status. As a
consequence, senior managers reviewed Salem performance
using the category 2 evaluation -- the evaluation factors
for removal of a plant from the watch list.
Managers concluded, notwithstanding significant
steps being taken and results achieved to date, Salem would
not be removed from Category 2 status if it had been
previously categorized as such. A key consideration in the
watch list removal evaluation factors is assessment of plant
and integrated station performance at power, which is yet to
occur.
The licensee is nearing the end of its outage on
Unit 2. Startup is now scheduled to occur sometime in the
next couple of months. As explained in the January 2 staff
paper submitted to the Commission on Salem restart
activities, the staff has completed or will complete
extensive inspections in the design, engineering and testing
areas before restart. Consistent with guidelines contained
in NRC Manual Chapter 0350 governing agencywide activities
. 41
and special plant restart situations like Salem, an
independent readiness assessment team will conduct a final
review of operational readiness before restart of the unit
is authorized.
In summary, decision was made to recognize Salem
should have been placed on the watch list previously and
that it would not have been removed at this point. As such,
Salem is being classified as a Category 2 facility.
Again, as we mentioned at the beginning, this is
not intended to suggest that we are dissatisfied with the
approach being taken or to imply that the improvements that
are being taken are incorrectly targeted.
CHAIRMAN JACKSON: Questions?
[No response.]
MR. MILLER: Hope Creek.
The Hope Creek generating station was first
discussed at the January 1996 senior management meeting. At
that meeting, senior managers reviewed a number of events
that revealed declining performance at the station. A
decision was made to send a letter advising Public Service
Electric and Gas of the negative trend and requesting a
meeting of top level officials to discuss NRC concerns.
Steps taken by licensee management since that
meeting to address both human performance and equipment
issues have resulted in overall improvement in plant
. 42
operations. Management has consistently exhibited a
conservative approach to decisionmaking. Progress has been
made in communicating higher performance and lowering
significantly the threshold for identification of problems.
Numerous staffing changes and an extensive
training and requalification initiative have led to improved
control and plant activities by operators and this is
significant because the negative trend discussed in the
January 1996 letter is most notably evidenced by several
significant events that -- where operators failed to
properly control plant evolutions.
Overall personnel error rates have declined
significantly. The station is well along in addressing
previously identified problems with technical specification
and surveillance procedure discrepancies. Overall material
condition of the plant is good as illustrated by improved
plant operating performance.
This improvement stemmed, to a large degree, to
work accomplished during an extended outage completed in
early 1996. Maintenance and engineering backlogs, which are
somewhat large, constitute a continuing challenge to the
station but they are well understood and prioritized.
Continuing attention is also needed to improve
operator staffing levels which were reduced somewhat during
the station's operator requalification initiatives.
. 43
In summary, senior managers determined that Public
Service Electric and Gas has arrested the decline in
performance at Hope Creek station. The company has been so
notified in our letter summarizing senior management meeting
decisions.
CHAIRMAN JACKSON: Questions?
[No response.]
MR. THOMPSON: We will go to Luis Reyes of Region
II.
CHAIRMAN JACKSON: You don't plan to say anything
about Millstone because we're having a separate meeting; is
that the point?
MR. THOMPSON: That's correct, Madam Chairman.
CHAIRMAN JACKSON: All right.
Any questions? If not --
MR. REYES: Madam Chairman, Commissioners, I will
be addressing the senior managers meeting review of Crystal
River.
Crystal is a single BLW unit operated by Florida
Power Corporation. Declining performance at Crystal River
was first discussed during the June 1996 senior management
meeting. Performance concerns at Crystal River discussed at
this senior management meeting involve Florida Power
Corporation mishandling of several design issues, improper
interpretation of NRC regulations and weaknesses in operator
. 44
performance, corrective actions and management oversight.
As a result of the licensee's performance, a
series of bimonthly management meetings were conducted
between the regional administrator and the senior managers
from the region and FPC's chief nuclear officer and key
Crystal River site managers. These meetings were conducted
to review the licensee's progress in implementing corrective
actions.
Overall performance at the facility has continued
to decline from the previous assessment period, as
documented in the most recent SALP issued on November 25,
1996. Several level three violations were issued since the
last senior managers' meeting which included significant
civil penalties.
Modifications made to the plant during the April
1996 refueling outage created on review a safety question
regarding emergency diesel generator loading and introduced
additional failure modes in the emergency feedwater system.
The significant issues, engineering reviews and
modifications required resulted in the licensee's decision
to shut down Crystal River in September of 1996 and to
maintain the unit in shutdown for an extended period of time
to ensure safety system operability and to increase design
margins. This action was taken as a recognition by the
licensee that Crystal River may have operated outside its
. 45
design basis and that other systems could also be impacted
by the recent engineering issues.
The licensee has submitted to the NRC a management
corrective action plan which is being implemented and
contains thorough corrective actions to resolve the issues
that led to the unit's shutdown. The NRC has established a
startup panel, part of the Manual Chapter 0350 review
process.
The issues at Crystal River warrant increased NRC
attention from both headquarters and the region and
therefore the senior managers have classified Crystal River
as a Category 2 plant.
CHAIRMAN JACKSON: Questions about that?
MR. REYES: I still need to address Commissioner
Diaz's question about the senior managers' meeting.
I guess, in terms of the process, I have
participated in previous senior managers' meetings in a
different capacity and the particular enhancements that we
made to this senior managers' meeting, the one in January,
where the regional administrator presented both the negative
and positive, I thought it was very useful. It led to a
better discussion among the senior managers' meeting and
understanding of the facts presented by all the people
around the table.
When I prepared for the meeting, I had a range of
. 46
options that I thought would come out of it. I wasn't sure
exactly. I didn't have a decision made ahead of time.
It was interesting because, on the second day, all
the senior managers were discussing the same range of
options regarding Crystal River and we talk about no action,
which was not an option. We felt that performance required
an action by the agency and we discussed clearly that it was
not a Category 3 plant. So the range was between a
declining performance letter and the Category 2. And we
all, in consensus, agreed it was a Category 2 plant and I
agreed with that decision.
CHAIRMAN JACKSON: Thank you.
Any other questions?
[No response.]
CHAIRMAN JACKSON: Okay, who's next?
MR. THOMPSON: Mr. Beach from Region III.
MR. BEACH: Good morning, Chairman, Commissioners.
Before discussing Lasalle, Zion and Dresden, let
me provide you a brief overview of the Commonwealth Edison
system and the basis for a 50.54(f) letter.
Since the June 1996 senior management meeting,
Commonwealth Edison has reacted to significant performance
issues at all six of its nuclear sites.
The Byron station's performance has been very good
to superior with one exception that involved the discovery
. 47
that inadequate surveillance procedures and corrective
actions to servicewater system degradation resulted in the
ultimate heat sink being inoperable on several occasions.
Braidwood has struggled with material condition
and configuration control problems but now appears to be
getting well after increased management focus in those
areas.
Quad Cities effectively resolved some longstanding
engineering issues and is currently sustaining improvement.
The management team has stayed focused on achieving the
improvement initiatives started in 1994.
Although Dresden has not yet demonstrated the
ability to sustain power operation of both units, the
station, like Quad Cities, has shown improvement over the
past six months and the station's weaknesses are better
defined after the NRC's independent safety inspection.
At Zion, there has been some decline in
performance over the past six months. A trend of personnel
errors, operational events and the poor quality of routine
work and engineering activities continue, despite
management's efforts to improve.
At Lasalle, both units have been shut down since
September due to emergent hardware issues, to address
performance issues manifested in a risk-significant
servicewater event and to address problems highlighted in
. 48
the most recent systematic assessment of licensee
performance.
To meet these challenges, Commonwealth Edison is
taking some noteworthy actions. During this same period,
Commonwealth Edison has significantly increased its
allocation of resources to address its systemwide
performance problems. In addition, more significant changes
were made at senior management levels to provide better and
more focused oversight and guidance to the nuclear sites.
Five of six vice presidents have now come from outside of
the Commonwealth system and five of the six plant managers
or general managers, as the case may be, have also come from
outside the system. More managers at less senior positions
are continuously being recruited and brought into the
system.
In addition, using a team of industry peers and
INPO representatives, Commonwealth performed an independent
safety assessment at Lasalle and Zion. This was a
particularly noteworthy effort aimed at determining why
previous performance initiatives were not successful at
these two facilities.
The licensees' effort found similar performance
problems at each plant. Self-assessment attributed the
principal reasons for the problems to be due to, in essence,
weak management processes and a lack of management
. 49
involvement. Comprehensive plans to address these findings
are being developed and will be presented at public exits at
each of the facilities in February.
In response to the findings of the NRC's
independent safety inspection at Dresden and other recent
NRC inspections, and the self-assessments at Lasalle and
Zion, Commonwealth Edison has directed that each site
initiate actions to improve the quality, maintenance and
accessibility of design information.
A confirmatory action letter was issued in
November outlining the extensive action Commonwealth Edison
is taking or will take to address the engineering
deficiencies. Commonwealth Edison essentially has brought
in a number of new managers with a philosophy to focus on
safety, identify issues, resolve them and fix the plants
while opening communications with the NRC.
Commonwealth Edison appears to be putting a number
of issues on the table and is aggressively seeking change.
Although Commonwealth Edison has made a number of management
changes, has implemented a number of significant initiatives
to improve its performance, most of these initiatives are
not yet implemented at Lasalle and Zion.
The following discussions regarding Dresden,
Lasalle and Zion will show significant challenges remain at
these stations. Improvements at Dresden must continue and
. 50
substantial improvement must be affected at Lasalle and
Zion. These needed safety performance improvements must be
achieved without negative effects at the other nuclear
units. Thus, the senior managers concluded that the acting
executive director for operations send a letter, pursuant to
10CFR50.54(f) to the chief executive officer of Commonwealth
Edison requesting information why the NRC should have
confidence that the licensee can operate its nuclear
stations while sustaining performance at each site.
CHAIRMAN JACKSON: Place this into some context
for me, Mr. Beach. Is this an unprecedented action?
MR. BEACH: I guess being relatively new to the
region, from my perspective, I would say yes, it is, but --
MR. MIRAGLIA: In terms of an action coming from
the seniors, yes, it is, in terms of previous senior
meetings.
CHAIRMAN JACKSON: And have we begun any
discussion with the licensee as to what kind of information
we would expect them to provide to assist us in making the
judgment that's inherent in the 50.54 letter?
MR. MIRAGLIA: The letter is a request for
information and identifies the need for them to do that and
the letter indicates we're prepared to enter into dialogue.
CHAIRMAN JACKSON: And they have to respond within
what, 60 days?
. 51
MR. THOMPSON: That's what the letter is.
Obviously, we have the ability to extend that time if it's
needed, if it's warranted and for just cause.
CHAIRMAN JACKSON: Why don't you continue? Did
you have a question?
COMMISSIONER DIAZ: Yes. I have a question.
Would you comment on how significant is the issue
of poor relationships between the management and the unions
at these plants and how you might think it affects the
performance of the entire plant personnel?
MR. BEACH: That's a difficult question because I
think it varies at each of the sites. I think the extent of
the problems, obviously, for example, Braidwood and Byron
have some problems, but they're able to manage it. I think
Lasalle and Zion probably have the most significant
problems, but whether that has really had an impact on the
ability to manage or not, I really can't comment.
COMMISSIONER DIAZ: But is it a problem? Is the
union-management interaction a problem at the plants?
MR. BEACH: At Lasalle, I think there is evidence
that there is a problem there.
COMMISSIONER DIAZ: Thank you.
CHAIRMAN JACKSON: Do you consider, and perhaps
you can address this in your more detailed comments about
each plant, do you consider that the decline and performance
. 52
at Zion since 1993 is attributable to a corporate shift in
attention away from that facility as it's focused on other
facilities?
MR. BEACH: I don't really think so. I think it
probably plays a part in it but I don't think it's the major
cause.
CHAIRMAN JACKSON: All right. Why don't you go
on?
MR. BEACH: Let me begin with Lasalle. Lasalle
was given a trending letter in January of 1994 due to
concerns about poor radiological work practices, declining
material condition, declining personnel performance, and NRC
staff concerns about the licensee's ability to pursue and
resolve root causes for these issues.
By January 1995, the licensee's initiatives were
found to be effective in arresting these adverse trends and
a letter was sent urging the continuation of improvement
initiatives.
However, the licensee's performance since the last
senior management meeting in June 1996 has declined. In the
first two months following the last senior management
meeting, licensee performance was considered at least
adequate.
While some progress was made in identifying and
correcting material condition deficiencies, improvements in
. 53
plant hardware material condition were slow. Maintenance
and engineering backlogs remained high. Emergent work and
rework limited the licensee's ability in implementing the
station's material condition improvement plan.
In June, holes were bored in the safety-related
service water pump room floors for the purpose of injecting
a sealant material to eliminate water seepage. The service
water system serves, by design, as the ultimate heat sink at
Lasalle.
Since the work control process was circumvented,
the work was performed was a minor maintenance activity on a
service work request. As a result, no engineering
evaluations to determine the impact on operation of the
facility were performed and the work was performed without
sufficient reviews, procedures or oversight.
A large quantity of expandable foam sealant was
injected into the safety-related service water tunnel.
Since the foam sealant expands considerably when it comes in
contact with water, the injections caused two service water
plant transients that significantly challenged the operating
crew.
The event revealed previously unidentified
material condition problems and disclosed significant
engineering weaknesses in support to plant operations.
Escalated enforcement action was issued on January 24th of
. 54
this year that resulted in a proposed $650,000 civil
penalty.
Two months after the service water event, the
NRC's systematic assessment of licensee performance was
conducted. Category III ratings were assigned in all
functional areas with the exception of plant support. The
ratings reflected, to a large extent, the lessons of the
service water event, with the clear finding that the event
confirmed fundamental programmatic weaknesses and management
weaknesses that extended throughout the organization.
To address these issues, a new management team was
put in place at Lasalle. A new site vice president and a
new engineering manager are now in place and 13 of 18 of its
top managers will be from outside the commonwealth system.
Senior corporate management has decided to
maintain both units shutdown indefinitely until the recent
human performance and hardware deficiencies have been
resolved. The new management team appears to understand the
scope and significance of its problems and has developed a
detailed restart action plan and a plan to affect long-term
performance improvements in all organizational areas.
The licensee's management changes in its
commitment to significant improvement initiatives, including
engineering, indicate that actions, when implemented, may
correct many of the longstanding performance issues that
. 55
exist.
Reviews of the results of the recent systematic
assessment of licensee performance, the preliminary results
of the licensee's self-assessment, the Lasalle service water
event, and the instances of the failure to use the
engineering design change process to properly control plant
modifications do, in fact, reveal significant insights into
performance at the Lasalle station.
These insights reflect the licensee's inability to
demonstrate progress in previous improvement initiatives in
the plant's material condition and to improve work planning
and maintenance processes which were not fully effective.
Given the scope and significance of these
problems, the senior managers concluded that the Lasalle
station warrants increased NRC attention and recommended
that Lasalle be placed on the NRC's watch list as a
Category II facility.
CHAIRMAN JACKSON: Any questions?
[No response.]
MR. BEACH: Zion was on the NRC's watch list as a
Category II facility from January 1991 until January 1993
when it was removed from the list based on improved
performance.
Efforts to improve material condition, upgrade
operator performance, and efficiently plan and execute work
. 56
have not been fully successful. Zion has been discussed at
the last two senior management meetings and it appears
performance has declined since the June 1996 senior
management meeting.
During the last senior management meeting cycle,
there was some progress in improving control room standards
and communications. Operator workarounds have significantly
decreased. There has been measured improvement in problem
identification.
However, several operational errors and unplanned
configuration changes occurred. Operators changed equipment
configuration status without following procedures. On
several occasions, these errors resulted in inadvertent
technical specification limiting conditions for operation
entries. Corrective actions were either ineffective or
untimely and as a result, the NRC issued a $50,000 civil
penalty in August 1996.
In response to these errors, there were constant
management campaigns to improve and several brief stand
downs. These stand downs were positive efforts to change
performance. Employees were asked why they should be
allowed to work at the station. However, despite these
efforts, similar problems still occur.
While Zion Station has taken steps to address the
number of significant material condition problems, including
. 57
implementation of a 12-week rolling maintenance schedule,
equipment problems continue to adversely affect plant
operation. The maintenance backlog remains high which has
been compounded by the inability of maintenance personnel to
do work correctly the first time.
Recent inspections in the area of engineering
identified significant deficiencies in the overall execution
of engineering activities. An engineering and technical
support inspection identified examples of an ineffective
50.59 safety evaluation process, weaknesses in the
in-service inspection program, examples of inadequate
modification, closeout and post-modification testing, and
the lack of control and understanding of the technical
specification interpretation process.
These findings, when combined with examples of
inadequate resolution of recurring equipment deficiencies
and poor procedure adherence in quality, reflect an overall
weakness in engineering support to the station. Escalating
enforcement action is pending for the significant
deficiencies in the overall execution of engineering
activities.
Zion Station continues to have one of the highest
source terms among PWRs in this country. Although there has
been some progress in source term reduction and ALARA
planning, these improvements were diminished by inadequate
. 58
procedure in radiation work permit adherence as well as
weaknesses in the control of radioactive material.
To address these issues a new management team is
in place. The licensee is developing a station operations
performance plan and is relying on a new management team to
assure effective implementation of the plan.
These changes and these kind of actions combined
with significant improvement initiatives in operations and
engineering when fully implemented may ultimately change
Zion Station's performance.
To date, however, previous initiatives have not
been fully successful. Although Zion has not experienced a
significant event like Lasalle, reviews of the licensee's
self-assessments and NRC inspection reports show the absence
of significant progress in improving the material condition
of the plant, continued work process problems and the
failure to stem the human error rate.
Given these problems, the senior managers
concluded that Zion warrants increased NRC attention and
recommended that Zion be placed on the NRC watch list as a
Category 2 facility.
CHAIRMAN JACKSON: Questions?
[No response.]
MR. BEACH: Dresden was first placed on the NRC
Watch List in June, 1987, and removed in December, 1988, and
. 59
again placed on the Watch List in January, 1992.
Significant contributors to the decision to place
Dresden on the Watch List a second time included weaknesses
in procedure, quality, and adherence, communications,
execution of management expectations, plant material
condition, supervision and control of work activities, work
performance, and engineering and licensing support.
Since the last senior management meeting the
conduct of operations in the performance of control room
operators continued to be good as a result of management
initiatives that included reinforcing standards and
expectations to the operations staff.
In addition, Unit II has operated well since its
restart in August. Operators have demonstrated a
questioning attitude and will facilitate a prompt
identification of potential problems.
Some conservative decisions included the manual
scram of Unit II last May following a feedwater transient
and the decision to shut down Unit III and maintain Unit II
in a shutdown while performing a complete overhaul of the 4
kV circuit breakers was also conservative.
Outside the control room several operator errors
occurred which indicated that the rigor and attention to
detail seen in the control room has not yet been
consistently implemented in the other areas of the plant.
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During the last six months significant improvement
was made in the material condition of the plan and the
knowledge, skills and abilities of maintenance personnel.
However, emergent work activities continued to
hamper the ability to conduct planned work, thereby
adversely affecting the ability to reduce work backlogs.
Longstanding programmatic problems with the
inservice test program and surveillance testing continued to
result in the failure to detect all degraded systems and
components.
There was improved performance in the area of
engineering support to the station, particularly associated
with system engineering, however emergent issues in the
large engineering backlog has also diverted the focus of the
engineering organization of significant longstanding
problems and was an impediment to quality engineering
products.
Furthermore, significant weaknesses were
identified by the NRC independent safety inspection team in
the area of design control.
The senior managers discussed the safety
performance of Dresden in light of the above discussion and
used the senior management meeting Watch List removal
evaluation factors. The senior managers discussed the
insights from the Dresden independent safety inspection
. 61
which found that while overall safety performance had
improved, the pace of improvement was slow and varied.
Significant improvement was evident in the area of
operator performance, although Dresden has yet to sustain
power operation of both units for an extended period of
time.
The significant reduction in personnel exposure
and contamination events was noted and some improvements
were observed in the maintenance process and in the material
condition of the plant.
However, Dresden continues to be challenged by the
high level of emergent work and the large maintenance
backlog.
Since significant challenges to continued
improvement at Dresden remain, the senior managers concluded
that Dresden Station warrants increased NRC attention and
that Dresden remain on the NRC's Watch List as a Category 2
facility.
CHAIRMAN JACKSON: Any questions?
COMMISSIONER McGAFFIGAN: Could I ask one
question? You're just finished with comment?
CHAIRMAN JACKSON: No, he's not done with comment,
actually. There's a trending letter, right -- I'm sorry.
You are finished with comment, right.
COMMISSIONER McGAFFIGAN: This goes back to our
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question that Commissioner Rogers asked at the very
beginning about the Hope Creek, where we sent a trending
letter and now we are sending a letter saying everything's
okay.
In the case of Quad Cities, they got trending
letters on several occasions in the past and they are
outlined in the 5054(f) letter.
Have we ever sent a letter of the sort that we are
sending at Hope Creed to them? We did that at one of the
meetings last year.
MR. MIRAGLIA: Yes. We can go back and get the
exact date, but there is an exact date where we -- it's
about two years ago.
COMMISSIONER McGAFFIGAN: Are there any plants --
this is maybe one I should have asked at the time -- are
there any plants at the moment that have gotten trending
letters in the past that we haven't closed out?
MR. MIRAGLIA: The answer is no.
COMMISSIONER McGAFFIGAN: Okay.
CHAIRMAN JACKSON: Thank you.
MR. THOMPSON: I understand that is correct.
CHAIRMAN JACKSON: Any other questions?
[No response.]
CHAIRMAN JACKSON: Do you have one more to talk
about?
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MR. BEACH: Two more.
CHAIRMAN JACKSON: I see. Okay.
MR. BEACH: Let me answer your, Commissioner
Diaz's, question about the senior management meeting process
earlier.
I really had no preconceived decisions as to what
would go on the Watch List or what would not go on the Watch
List. I did have very strong feelings that whatever
happened to Lasalle should happen to Zion because of the
measurable performance difference between Zion and Lasalle
and Dresden -- whatever that may be -- because if you visit
the plants there is a significant difference between Zion
and Lasalle and Dresden, although all three would be
considered Watch List plants.
Using the theory that it is harder to get off the
Watch List than it is to get on, and that we have to be
skeptical, I think clearly if you take away the service
water event, the performance of the two facilities is very
close.
COMMISSIONER DIAZ: Thank you.
CHAIRMAN JACKSON: Okay.
MR. BEACH: Point Beach -- Point Beach Nuclear
Plant was discussed for the first time at the senior
management meeting because of the plant's performance
decline since the systematic assessment of licensee
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performance that was issue in April, 1996.
Weaknesses in operation, engineering and
maintenance led to a number of violations involving
inattentiveness to duty by control room operators and
ineffective surveillance testing.
A significant enforcement action was issued in
early December with a proposed civil penalty in the amount
of $325,000.
The primary cause of these issues appears to be a
focus on keeping the units operating in an environment that
did not encourage problem identification or questioning
attitudes.
To address these problems early in the period, the
facility provided NRC with a substantial improvement plan.
However, NRC continued to find significant new issues that
the licensee had not identified.
Little was being done by the licensee in the way
of performing self or independent assessments of plant
activities to fully bound the performance issues that were
being identified.
Because of this, the NRC performed an operational
safety team inspection to better define current performance
and assess the licensee's corrective actions. The OSTI
findings confirmed earlier NRC findings that corrective
action efforts to date were not broad in scope to
. 65
appropriately assess the extent the extent of the problems
identified.
In early December the licensee appointed a new
Chief Nuclear Officer and on December 12, 1996 the licensee
issued a letter containing commitments that will be
completed prior to restart of Unit II from its current
outage.
The NRC issued a confirmatory action letter
confirming these commitments. The commitments provided in
the December 12th letter included reviewing a broad range of
procedure and work activities.
Significant licensee actions included realigning
engineering into a system engineering concept to better
focus on plant system status and performance, committing to
move corporate engineering to the plant site, realigning
senior plant and corporate management and committing to add
additions plant staff, up to 40 FTE, from outside Point
Beach.
The licensee is starting to show encouraging signs
as well in the way of acknowledging its performance
weaknesses. Since the appointment of the new Chief Nuclear
Officer, the licensee has started to demonstrate the ability
to deal with its own problems and take actions needed to
correct its problems.
There has been a positive trend in the licensee's
. 66
identification of issues in the past weeks.
A number of condition reports are being generated
and there's a significant increase in the number of
10CFR50.72 issues being reported to the NRC.
Early intervention by the NRC through its
inspection program and aggressive licensee actions may
arrest this decline. However, since a number of actions are
still needed, the senior managers recommended that the
Acting Executive Director for Operations send a trending
letter to Wisconsin Electric informing the Chief Executive
Officer of the agencies concerned regarding the decline in
operational safety performance at Point Beach Station.
CHAIRMAN JACKSON: Any questions?
[No response.]
MR. BEACH: Clinton Power Station was discussed at
the senior management meeting for the first time since 1991
due to an overall decline in plant performance during the
past year.
The evidence of the decline was clearly
demonstrated in September 1996 when a sequence of events
associated with a reactor recirc pump seal failure revealed
significant deficiencies at the facility. The deficiencies
included problems with procedural adequacy and adherence,
lack of rigor in conducting operations, and weak engineering
support to operations.
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In addition, the deficiencies included lapses in
safety focus where managers and staff were not fully
knowledgeable of their basic responsibilities and where it
appears plant management placed too much emphasis on keeping
the plant on-line.
Many of the issues identified as a result of the
September 5th event appear to violate NRC requirements and
an enforcement conference is planned for early February.
It appears that a practice had developed where
procedures were not always followed at the sight. By
procedure, if the intent of a procedure were satisfied, a
procedure change was not required. This may have
contributed to the procedural adherence problems
demonstrated by the reactor recirculation pump seal failure
event and other examples identified where operators work
around procedure deficiencies rather than fix them.
While initially slow in assessing the September
5th event, the licensee has implemented a number of
management changes including a new plant manager and a new
assistant plant manager of operations. The licensee has
devoted significant resources and management attention to
identifying and addressing problems.
The new managers are encouraging a much lower
threshold for the initiation of condition reports,
encouraging the staff to improve the quality of procedures,
. 68
and to stop work activities when problems are encountered,
and encouraging additional conservatism in the scheduling
and performance of work. Conservative decisions have been
made even though they had a negative impact on the outage
schedule.
Clinton is currently shutdown and confirmatory
action letters were issued to the licensee in September 1996
and January 1997 to document the staff's understanding of
the actions that the licensee would take prior to restart in
response to the September 1996 recirculation pump seal
failure event.
The recent management and operating crew changes
at Clinton, the licensee initiatives aimed at instilling
conservative decisionmaking and the actions to resolve a
number of procedure and material condition issues will
hopefully arrest the decline in performance.
However, because of the concern about the
licensee's reduced emphasis on safe operation during the
reactor recirculation seal failure event and the number of
examples of problems with procedural adequacy and adherence,
senior managers recommended that the acting executive
director for operations send a trending letter to Illinois
Power Company informing the chief executive officer of the
agencies concerned regarding the decline in operational
safety performance at the Clinton power station.
. 69
CHAIRMAN JACKSON: Any questions?
MR. THOMPSON: That concludes are prepared
discussions on the plants and we'd be pleased to respond to
any Commissioner questions.
CHAIRMAN JACKSON: I think Mr. Callan had
something?
MR. CALLAN: I would like an opportunity to
respond to Commissioner Diaz's question.
In my view, one of the more striking aspects of
these changes was to make the assessment or decision-making
process much more difficult, in some cases agonizing, a
reflection of that difficulty that came from arguing both
sides of the equation was that we had budgeted about a hour
on the second day to go through the plants we had discussed
and to come to closure. We ended up taking the full six
hours of the second day which precluded talking about
materials, as we mentioned earlier. So that reflects the
type of discussion that was, I think, prompted by the way
the material was presented.
COMMISSIONER DIAZ: Thank you.
CHAIRMAN JACKSON: Okay. Is there anything else?
MR. THOMPSON: I think we now have completed our
presentation and are pleased to respond to any questions
that you may have.
CHAIRMAN JACKSON: Commissioner Rogers?
. 70
COMMISSIONER ROGERS: I think the most obvious
question that comes out of where we are right now is really
what is the significance of what appears to be an abrupt
change in the status of a plant, either that it was not even
discussed at one meeting and at the next meeting, got a
trending letter, or didn't have a trending letter and
abruptly wound up on the watch list.
It's a question of what are we to make of that?
Does this indicate that there's abrupt deterioration at
these plants over a six-month period that is suggested by
such action, or is this an indication of a different way of
looking at the plants from the way we looked at them before,
or the third one is, of course, inattention on the NRC's
part.
I think it's important that you comment on that,
whether the new way of evaluating plants in a more
systematic way has led to a quicker decision than in the
past or whether it's just a very mixed bag so that some
plants have started to slip rapidly and it's appropriate to
take them from not even being discussed to a watch list
status, which I guess has happened in one case, or not being
discussed at all and then going on getting a trending letter
at the next senior management meeting.
In other words, one would expect some kind of a
continuous process going on rather than an abrupt process at
. 71
most plants but that may not be the case. However, our
judgments seem to be being made here somewhat in a stepwise
fashion.
It could be the new way of reviewing plants and it
might be an indication of something else happening out there
in the world that's taking place more rapidly. I know we've
touched on the question of resources or attempting to keep
plants running, whether we're seeing some evidence of a
shift in safety culture at plants.
In other words, I'd like to just understand
whether we should read anything into these actions or
whether we simply are in a transition period between one way
of looking at plants and another way of looking at plants
and that it will all sort out and stabilize the next time
around.
CHAIRMAN JACKSON: Now let's give you a chance to
answer.
MR. MIRAGLIA: I'll try to respond from the
context of the overall program.
I think it would be a misperception to say it's a
new process. The process has been an evolving process over
time. The Commission has directed, the Chairman has
directed over the last two years that we should look for
more ways of using objective evidence, making the process
more transparent. So the processes have changed. I think
. 72
they are evolutionary-type changes and I don't think the
presentation mechanism was an abrupt change that resulted in
what you have characterized as a perceived perception in the
step change for facilities.
I think it does indicate that we need to closely
look at trending letter versus category issues,
categorization issues. That's an issue that may have to be
looked at to say is there a sharper distinction. I think
each of the regional administrators, in their presentation,
indicated there was some agonizing or some balancing in
terms of those.
In terms of why each plant wound up where they
did, I think they were addressed by each regional
administrator and they could reiterate it. For example, in
the Crystal River case, it was an engineering modification
that was made in the spring, that was subsequently found at
a later date that said that facility operated outside its
design and licensing basis for a period of time.
I think that was a telling kind of thing and that
goes to Mr. Thompson's observation that the issues of design
are getting a little bit more focused and our program hadn't
been focusing on that, and we're trying to redirect this.
We responded to the Chairman earlier.
In terms of the Clinton, there was a significant
shift from the previous assessment period in terms of the
. 73
significance of the recirculation seal.
So I think each of those, there's an answer for
and I think it's a range of the topics that you identified
in your question, but I don't see it as a very stepwise
difference in how we're doing things. I think it was a
modest change that we made to the process and I think the
process has been evolving with time. We'll have to look at
that again in terms of the outcome.
COMMISSIONER ROGERS: But if you look at your
results, sit looks like --
MR. THOMPSON: Yes, the perception could be that
and I think if you look at each of the issues, Salem was a
retrospective look as we've explained. I think Bill
addressed the differences between Zion, Lasalle and Dresden
given the relative performance of those kinds of facilities.
MR. MILLER: Maine Yankee, I don't think it was a
decline. I think that we just got insight that we had not
gotten before, a combination of an important allegation that
panned out and a deep vertical slice, a 22-member team for 3
or 4 months. That's a level of scrutiny that permitted us
to uncover things we previously hadn't done.
We're going back, of course, looking at that,
trying to learn lessons from it, but some of it has to do
with resources. It goes back to the question we had before
from the Chairman about design and how we look at design.
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COMMISSIONER DIAZ: If you look at --
CHAIRMAN JACKSON: Excuse me. Commissioner Dicus?
COMMISSIONER DICUS: We have to take turns.
CHAIRMAN JACKSON: That's right. Otherwise, it
gets out of hand.
COMMISSIONER DICUS: This follows up a little bit,
I think, on Commissioner Rogers' question, together with a
comment the Chairman made earlier about occasionally we
appear to miss something.
When plants go on the watch list, and these
plants, I was prone to go back and look at the most recent
SALP ratings for the plants. For the most part -- some
exceptions -- but for the most part, there seems to be
little correlation.
I recognize that a SALP evaluation looks at
certain things, is done a certain way. It may be a very
subjective sort of evaluation and this senior management
meeting evaluation is done differently.
Given that, and given the apparent, for the most
part, lack of correlation between them -- I guess I'm
directing this question to anyone that wants to answer it
but probably to Mr. Thompson. Feel free to jump in anyway.
Do you think we still need these two separate
kinds of evaluations?
MR. THOMPSON: I certainly think this is a process
. 75
we need to look at. My specific responsibilities for the
reactor area are fairly new although I was involved in a
previous life.
My understanding, and I think Frank will probably
be able to articulate it better, there is more linkage than
is kind of apparent as the way we do the processing in
preparations for the senior management meeting as well as
the SALP process itself. So I want to ask Frank to address
the linkage and how that should be -- it may not be obvious
to the public how we do our communications both internally
and with the licensee on that.
MR. MIRAGLIA: In terms of the perception relative
to the SALP, and one of the management directives that we've
made public is we've tried to articulate how those pieces
fit together, the SALP is nominally a backward or a
retrospective look.
Some of those span a long period of time and
within the context of the process, it is to look at the last
six months. Some of the SALPs that you see that are
information or input are dated in terms of the period of
performance that we are looking at.
For one of Bill's plants, he talked -- I believe
it was Point Beach, the SALP looked relatively good and it
was from backwards and it was the performance in the next
period that we wouldn't see in terms of an evaluation of
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SALP to the conclusion in that SALP period.
We have a continuum of inspection processes and
evaluation and we have a number of performance assessment
type tools and this was raised, I believe, in one of the
SRMs in a broad sense that came out of our briefing on SALP,
which is how do these pieces go together and we make them
more effective and more efficient.
They all have a role and a use and I think we are
in an evolving kind of process with respect to the
performance assessments. We have a plant performance review
that looks at the inspection results between region and
headquarters and says, what are we doing for the next six
months? And so we have various performance assessment tools
that covered various periods of time.
At the screening meetings, prior to the senior
management meeting, one of the goals is to say where were we
with respect to the last SALP and the last performance
review, what has occurred in that period of time and the
focus is on the six months preceding the meeting. So there
is some time lag and some time differences and it does
raise -- give rise to the questions and perceptions as to
what is the SALP telling you? You have to look at what was
the SALP and what was the period of the SALP and what
performance period are we talking about and they are a
little bit different.
. 77
We have tried to integrate and show how they are
interrelated and integrated and that's something that we
will be looking at in response to some of the SRMs for the
Commission's response.
CHAIRMAN JACKSON: Mr. Callan?
MR. CALLAN: I was just going to make two points.
One was whispered to me by Luis. I'll give him credit.
[Laughter.]
MR. REYES: Which one?
[Laughter.]
MR. CALLAN: The SALP process as Hugh, as several
people mentioned earlier, actually the inspection process
has not in the past -- in recent years anyway, focused on
engineering and licensee basis issues. Hence, SALPs
conducted during that same time period would also not
reflect a focus in those areas and, as we've said earlier,
problems in those areas were major themes in some of the
plants we discussed. So one would expect, therefore, some
degree of disconnect between SALP and the discussion plants
today in that arena.
The second point I make is just to reinforce
something that Frank Miraglia had just said and that is to
really put a SALP report today in its proper context, you
have to look at the SALP report and every six months after
that, and the timing is intended to be coincident with the
. 78
senior management meeting process, so they are integrated,
the region does a six-month update of that SALP and it's a
fairly rigorous process involving, in some cases,
significant shifts of inspection resources as a result. And
then each licensee is sent a letter after that six-month
review.
What we don't do is revise the SALP scores but a
discerning reader can certainly detect a change,
evolutionary change or even an abrupt change in perspective.
So you would have to look at -- if you think of those
six-month assessments as supplements to the SALP, you would
have to look at the SALP and its subsequent supplements to
capture where the agency is on a given licensee. The output
of that product.
MR. MIRAGLIA: The output of that product, as Mr.
Callan is indicating, is where the inspection effort is
going to be in the next six months or more and that's a
signal to where we think we have concerns or perhaps not
enough information to make a judgment and that's a signal to
the utility and the public. It's done in a public kind of
way, as to where our focus is shifting.
But with respect to engineering, I think SALP does
cover engineering. However, the focus in the past has been
on operational support to engineering and this design aspect
is a new element that, as I indicated to the Chairman, we
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are looking at ways of enhancing that, so the design
aspect --
CHAIRMAN JACKSON: With the right balance, so you
don't lose the focus.
MR. MIRAGLIA: We have to have operational safety
focus as well, so this is an issue that we are looking at,
we've taken modest steps and we are looking for further
improvements in that area as well.
MR. CALLAN: And I would just say, finally, your
point, Commissioner, is fundamentally valid. There are
frequently, maybe one could say too frequently there is a
disconnect between the SALP assessment, even when updated,
and the results of the senior management meeting and I think
Hub Miller did a good job of describing how that can come
about and there are several examples of the staff developing
insights based upon events, transients.
CHAIRMAN JACKSON: Commissioner Diaz?
COMMISSIONER DIAZ: Thank you.
I have some thoughts I want to bounce around a
little bit.
First I would like to commend the staff for the
efforts in organizing, documenting and orchestrating the
senior management meeting. Obviously, a tremendous amount
of work has gone into it. The decisions that were made have
significant impact on the licensees and should be some
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indicators of both how the industry and how the NRC
discharge their responsibilities.
And yet the Commission is ultimately responsible
for the decisions that the staff makes. In reviewing all
this latest information I still have the opinion that the
sequence of correlative processes leading to the decisions
made by the senior management meeting are not transparent to
the Commission and much less to the public.
In particular, it appears that licensee events
drive the process and drive the decisionmaking rather than a
more balance, holistic approach. Obviously, the staff must
have, and I am sure they did have, weigh the safety
significance and risk implications of every major component
of the evaluation and consider the enforcement actions and
other truths that are available to them from the regulatory
process.
I am pleased to hear that this effort, having
improved the quality of the meeting and having resulted in
significant improvement, that I am sure will be apparent to
us shortly. Yet it is not apparent to me how these are all
integrated in the decisionmaking process and how they
correlate with a few decisions, maybe three, made at these
meetings, especially those plants that have never been on a
watch list or received a trending letter.
Specifically, I have concerns how Maine Yankee,
. 81
Zion and Crystal River were placed directly on the watch
list when, a short time ago, they were considered good
performers and, when one looks beyond an event, we find
aggressive correction and remedial reaction programs that
the staff have praised. A trending letter might be more
consistent with the way we have acted in comparable
situations.
I am also concerned with the large number of
plants placed on the watch list. Again, echoing my fellow
commissioners, it appears that both the licensee and the NRC
are not doing enough to discern early and in a
programmatically correct manner the trends that lead to
questionable performance. It is our duty to provide early
trending. It is our duty to provide guidance to the
licensees, to avoid the situations that have led to this
what I call massive placing of plants on the watch list.
I would encourage my fellow commissioners to
expeditiously establish additional guidance for the staff on
the issue of our processes for evaluations of licensee
performance leading to the senior management meeting
decisions and the Commission input after those decisions are
made.
I urge the staff to assist us in transforming this
entire program to a fully accountable, fully transparent
process, clear to the public and the licensee.
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Thank you, Madam Chairman.
CHAIRMAN JACKSON: Any comments?
Commissioner McGaffigan.
COMMISSIONER McGAFFIGAN: I didn't have a prepared
speech but --
COMMISSIONER DIAZ: Good.
[Laughter.]
COMMISSIONER McGAFFIGAN: One of the questions on
the senior management -- we have all been referring to this
Arthur Andersen study. Is that going to be released or has
it been released to the public?
MR. THOMPSON: It will be placed in the public
document room today.
COMMISSIONER McGAFFIGAN: Because I think that is
very important.
My question goes to something that Commissioner
Dicus asked at the very outset. You all read that report.
The heart of the report, I'll tell the public and you can
read it, is that the process hasn't worked well in the past,
that there were problems with it and the solution is
suggested. The solution has to do with using our own
performance indicators and a decision matrix, which -- the
performance indicators aren't perfect, the decision matrix
isn't perfect but it might be a major improvement if we can
perfect it and I know the staff is going to come back and
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tell us in February some initial thoughts, in March some
further thoughts on that.
But it strikes me that you are all human and the
thrust of this report is that we probably have missed things
in the past, that there are plants that we probably should
have taken action on earlier, we let people off lists
quicker than they should have been. In one of the examples,
we indicate the performance got even worse and we never
discussed them again.
Did that -- maybe I shouldn't ask the question but
it has to have affected you as you sit there knowing that
this is going to be a public document, knowing that you are
going to have to deal with is this model the correct model
or something close to it better and more objective than what
we've done in the past?
So if I had a prepared statement, it would be
something along the lines of that I -- there may have been a
renormalization at this point, it may have nothing to do
with whether the industry has been performing better or
worse in the last several months, although I think in each
case the staff has good reasons, but it may well reflect the
general criticism and then I commend the staff and the
Commission that was here for asking for this report. It
reflects that we may not have been perfect in the past, we
have to renormalize and move forward. Like Commissioner
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Diaz, I think I won't ask for answers, I just want to make
that comment.
CHAIRMAN JACKSON: What I would like to do is
thank the staff for an informative briefing and for honesty.
The Commission is interested in the results from
the 10CFR50.54(f) letter to Commonwealth Edison. I
understand that the licensee's response is due in 60 days,
so I'm going to be scheduling or asking that there be a
Commission briefing scheduled soon after you've had time to
evaluate the information and to determine what actions, if
any, need to be taken as a consequence.
We'll also be asking Commonwealth Edison to also
participate in that briefing, to speak to their response,
and so we'll schedule that meeting as appropriate relative
to being able to have that kind of information on the table.
In general, I found the results of this senior
management meeting to be encouraging. With regard to
improving decisionmaking by basing them on performance,
demonstrated safety performance.
I believe that the processes used and the results,
while not perfect, as everyone has indicated, are credible.
You have laid out your reasons in each case. But as has
been identified, room for improvement does remain in
finalizing and using objective, meaningful performance
indicators, recognizing the leading indicators that identify
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where cost-cutting measures, for instance, may impact safe
operation, and in monitoring our licensee actions to ensure
that safety performance problems have actually been
corrected.
I think with the transitions which are rapidly
occurring in the electric utility industry, it is imperative
that NRC be timely, be fair, be objective and as accurate as
we can be, it's still an imperfect process, in evaluating
plant performance to ensure the continued safety of
operating commercial reactors.
I think that a challenge has been laid before you
relative to helping not only the Commission, but the public
understand the linkages between the various evaluative
mechanisms that we use and how one plays into the other.
I think you also have a challenge to explain that
the senior management meeting results are meant to focus
attention as opposed to being a regulatory decision. The
50.54(f) letter is a regulatory action.
To this end, then, the Commission plans to closely
monitor the staff's progress in this area and Commission
meetings have been scheduled in the near future to discuss
the status of improvements in the Operating Reactor
Oversight Program as well as the status of the analysis of
the plant watch list indicators. I think that will be a
robust discussion and I think that those meetings are the
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appropriate places to take up the broader-based policy
implications as opposed to here.
Unless there are any further closing comments or
speeches, we are adjourned.
[Whereupon, at 12:00 p.m., the briefing was
concluded.]
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