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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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01/30/1997
1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
- - -
BRIEFING ON MILLSTONE BY
NORTHEAST UTILITIES AND NRC
- - -
PUBLIC MEETING
Nuclear Regulatory Commission
One White Flint North
Rockville, Maryland
Thursday, January 30, 1997
The Commission met in open session, pursuant to
notice, at 10:00 a.m., Shirley A. Jackson, Chairman,
presiding.
COMMISSIONERS PRESENT:
SHIRLEY A. JACKSON, Chairman of the Commission
KENNETH C. ROGERS, Commissioner
GRETA J. DICUS, Commissioner
NILS J. DIAZ, Commissioner
EDWARD McGAFFIGAN, JR., Commissioner
. 2
STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
JOHN C. HOYLE, Secretary of the Commission
KAREN D. CYR, General Counsel
NORTHEAST UTILITIES:
BRUCE KENYON, President and CEO
DAVE GOEBEL, VP, Nuclear Oversight
JAY THAYER, Recovery Officer, Nuclear Engineering
and Support
JACK McELWAIN, Recovery Officer, Millstone Unit 1
MARTIN BOWLING, Recovery Officer, Millstone Unit 2
MIKE BROTHERS, VP and Recovery Officer, Millstone
Unit 3
NRC STAFF:
HUGH L. THOMPSON, JR., Acting EDO
FRANK MIRAGLIA, Acting Director, NRR
EUGENE IMBRO, Deputy Director for ICAVP, SPO, NRR
WAYNE LANNING, Deputy Director for Inspections,
SPO, NRR
PHILLIP McKEE, Deputy Director for Licensing and
Oversight, SPO, NRR
. 3
P R O C E E D I N G S
[10:00 a.m.]
CHAIRMAN JACKSON: Good morning, ladies and
gentlemen. The purpose of this meeting is for the
Commission to be briefed on the status of activities related
to the three Millstone Nuclear Power Plants. The Commission
will hear presentations today from both Northeast Utilities
and the NRC staff.
Millstone Unit 1 has been shut down for
approximately 15 months and Units 2 and 3 are approaching
being shut down for one year.
All three of the Millstone units were placed on
the NRC's watch list in January 1966, and in fact the NRC
has stated that this action in retrospect was late in
occurring.
The units were recategorized as Category III
plants in June of 1996. This action necessitates Commission
approval for restart of each of the units.
The NRC in November of last year created a new
organization, the Special Projects Office, to have
responsibility for all licensing and inspection activities
at Millstone to support an NRC decision on the restart of
those units.
This Commission meeting is the first of what are
planned to be quarterly meetings to assess the status of
. 4
activities at the sites. The Commission is interested in
the recovery process the licensee is employing, the root
causes of the deficiencies and how these are being
corrected, and indicators and measurement tools the licensee
is using to verify progress.
The Commission has recently reviewed an NRC staff
paper entitled the Millstone Restart Process, which is being
made publicly available today.
The Commission looks forward to the staff's
presentation in addition to the licensee's. We are
particularly interested in hearing from the staff on their
planned oversight process for restart of the Millstone
units.
I understand that copies of the presentation
materials are available at the entrance to the meeting.
Unless the Commissioners have any comments,
Mr. Kenyon, please.
MR. KENYON: Thank you, Chairman Jackson,
Commissioners. For the record, my name is Bruce Kenyon.
I'm President and CEO of Northeast Nuclear. I have been in
that position since September of 1996. Previously I was
President and Chief Operating Officer of South Carolina
Electric and Gas, which included responsibilities for the
V.C. Summer Plant.
Prior to six years at SCE&G, I was 14 years at
. 5
PP&L in various positions, including being Senior Vice
President-Nuclear, and responsible for the Susquehanna
units. I was previously with Northeast Utilities, six years
there, senior license on both Millstone Unit 1 and Unit 2,
and I have navy experience as well.
My current challenge obviously is to fix
Northeast's nuclear program and recover the Millstone units.
Before discussing the status of the recovery
efforts and a review of certain issues that we want to
address today, I would like to make some introductions.
Seated with me is Jack McElwain from PECO. He has
been Director of Outage Management, but he's with us as the
Recovery Officer on Millstone Unit 1.
Marty Bowling. He's Virginia Power Manager of
Nuclear Licensing, but he's here with us heading a team as
Recovery Officer of Unit 2.
Mike Brothers is seated at the table. Mike is
assuming the position of Recovery Officer of Millstone Unit
3. He succeeds John Paul Cowan, who is Vice President of
Operations and Engineering Support. He has been loaned from
CP&L. As I think you are aware, he's taking an officer
position at Crystal River, but he is here in the audience.
Also seated at the table is Jay Thayer. Jay is on
loan from Yankee Atomic, Vice President and Manager of
Operations, and he's filling the position with us of Vice
. 6
President of Engineering and Support.
Also seated at the table is Dave Goebel. He's a
recently retired rear admiral and he is Vice President of
Oversight.
We have a lot of others in the audience from
Northeast Utilities, but I wish to point out that Bernie Fox
is seated behind me; Chairman, President and CEO.
Also, George Davis chairs the advisory team to the
Nuclear Committee of NU's Board of Trustees. George is a
former navy vice admiral and previously CEO of Boston
Edison.
[Slide.]
MR. KENYON: The agenda slide indicates what we
would like to do for the first of what you've already
indicated would be a series of quarterly presentations to
the Commission regarding our efforts to recover the
Millstone units.
For my portion of the agenda, and particularly
since this is the first of several meetings to talk about
where we are in our progress, I thought I would start by
giving you my assessment of the root causes of the Millstone
performance problems. I want to highlight the actions that
have been taken to address root causes and indicate the
progress we're making, and then as part of all that I want
to discuss certain issues that I think are relevant for this
. 7
particular meeting.
Other agenda topics will include Jay Thayer giving
you a status of efforts to reestablish the licensing and
design basis for each unit.
Dave Goebel, status of efforts to resolve employee
concerns issues.
Jack McElwain, status of efforts to establish an
effective corrective action program.
Clearly there are a number of other issues that we
could talk about today, but in the interest of time those
are the issues that we selected that we thought would be
most relevant for this meeting. As we have other meetings,
we will want to discuss other issues as well.
[Slide.]
MR. KENYON: Beginning with root causes, in my
judgment the fundamental problem was leadership. This was
manifested through four principal failures.
A failure to set and maintain high standards. By
that I mean instead of seeking standards of excellence, the
organization along the way defaulted to regulatory minimums.
The organization stopped benchmarking other utilities. As I
think we all understand, if the best you are doing is aiming
for regulatory minimums, then at some point you fall short.
The second was a failure to establish clear
accountabilities. The organization historically pursued a
. 8
highly centralized organization, more recently called the
Power of Five concept. You can organize a lot of different
ways, but this particular approach had the significant
disadvantage of not establishing and enforcing in a good
sense who was accountable for what.
As an example, if you are responsible for one of
the Millstone units as a unit director, in my judgment that
individual did really not have the full accountability that
that individual needed to have, did not have engineering
resources, did not have licensing resources, did not have a
lot of things to really make that person accountable. So
what you wound up with was a situation where
accountabilities did not truly come together until you got
to the top of the organization, and that was just too far
away from where the accountability needed to be.
There was also a failure to develop efficient
processes. The organization sought to solve problems by
developing additional controls as opposed to understanding
what the real problem was and solving the real problem.
They endeavored to prevent problems through controls on top
of controls on top of controls. The effect of this was over
time to make the processes by which you do work increasingly
inefficient and harder to get things done. Over time there
was a huge backlog of items not being accomplished, and this
gave rise to quite a number of employee concerns, as you
. 9
would understand.
Finally, there was a failure to identify true root
causes. The fundamental problem was leadership. The
leadership at that time didn't recognize that the
fundamental problem was them, and thus they endeavored to
pursue a lot of other things without the real problem being
solved.
So the picture that I think characterized the
Northeast Nuclear situation, particularly the Millstone
situation, was one of deteriorating performance, low
standards, falling further and further behind the industry,
a growing backlog of important work not accomplished,
unclear accountabilities as to who should fix what, a lack
of understanding of the true problems, increase in employee
concerns with some high profile cases not well handled,
growing supervisor and manager frustration, and thus, in
spite of many efforts and many programs to try and address
that, the organization, at least at the time I arrived, was
as close to a dysfunctional organization as I have ever
encountered.
Correcting a leadership problem requires new
leadership.
[Slide.]
MR. KENYON: By new leadership, I don't mean one
or two individuals, but a substantial infusion. What we
. 10
have is a new officer team. Every person at this table is
new. We have two new hires, four loaned, shifting a little
bit with one loaned individual leaving and Mike Brothers
picking up that responsibility. As was announced last week,
we have a new chief nuclear officer for Millstone, Buzz
Carnes. He's coming from Wolf Creek. He spent a few days
at the plant this week, but he really reports in halfway
through next week and will be able to do a lot for us.
CHAIRMAN JACKSON: What's your current estimate of
when these various recovery teams will hand off the baton,
as it were, to permanent management teams?
MR. KENYON: It's coincidental, because we have
been working on the agreements, but going out this morning
is a press release indicating the following:
In the case of Unit 1, PECO has agreed to provide
a recovery team to manage the activities on Unit 1 on a
long-term basis, meaning through startup into operation for
a period of time of at least two years with the opportunity
to renew.
CHAIRMAN JACKSON: Two years from now or two years
from startup?
MR. KENYON: Two years from March 1, to be
precise. But again, options to renew. Thus, what I'm
saying is that they've agreed to stay as long as we need
them to stay. In both these cases what we have is a letter
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of intent. We have some contractual details to work out,
but we have a signed letter of intent.
Also, on Unit 2, with Virginia Power to do exactly
the same thing. In other words, at least two years starting
from March 1 provide the recovery team, the leadership team
on Unit 2.
CHAIRMAN JACKSON: Does that involve the
individuals who are sitting at the table?
MR. KENYON: Yes, it does. It will not
necessarily involve every Virginia Power or PECO individual
that is currently. We may shift some.
CHAIRMAN JACKSON: But the team leadership is not
anticipated to change?
MR. KENYON: That's right. The team leadership
that you see here sitting at the table is the team
leadership that is going to take these units through
start up and into operation. We are very pleased with that.
On Unit 3, we are transitioning from a CP&L led
team to an NU led team, and that NU led team will be led by
Mike Brothers. CP&L will be transitioning out. They are
willing to leave a few people on a longer term basis but not
a full team. Thus, we will supplement an NU led
organization on Unit 3 with one or two or three CP&L
individuals.
In addition, as is going on with the other two
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utilities that are supporting us, CP&L is going to continue
the practice of sending a very senior nuclear individual to
the site on a monthly basis to look at what is going on and
be in a sense in an ongoing advisory capacity to us as to
how they see things going.
Also, CP&L is willing to provide support in other
ways, such as access to programs, such as a willingness to
have our people continue the practice of going and visiting
their plants so our folks can see how it's done somewhere
else; access to programs and procedures.
I want to be sure that the impression is not left
that CP&L is just walking away. They're not. I'm
comfortable, but I concluded that the right thing to do was
transition only one unit at this point and then transition
the other two units after startup, well into operation,
transition the units one at a time, not have on a Friday a
whole team there and then on Monday a whole team gone, but
gradually replace people so that both myself and obviously
the NRC can be assured that we are going to make a very
gradual and careful transition in leadership continuity.
CHAIRMAN JACKSON: What impact has this transition
had on Millstone and your restart plans there on Unit 3?
MR. KENYON: On Unit 3, contrary to what some
people have speculated -- they speculated that CP&L
transitioning out will be a major setback. I don't see that
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at all. I think we've got a plan in place.
I need to remind you what the initial commitment
was. It was to come in for six months. It's just John
Cowan that's leaving at this point. The rest of the CP&L
team is there and will be there through the six months and
then phased out after that. So we have a recovery plan in
place that was put together by John and CP&L folks and Mike
Brothers.
Mike is an individual who is highly regarded by
employees, by the public that knows him, by the NRC folks,
as I understand it, who know him, certainly by myself, and I
think we can achieve a very smooth transition here. I don't
see any significant loss of momentum, and thus I think we
fully intend to just keep right on doing what we need to do.
CHAIRMAN JACKSON: Okay.
MR. KENYON: In responding to your question I gave
a sense as to what the recovery teams are doing. What I was
indicating was that what they do is a lot more than simply
have a management team in place. By virtue of the fact that
they are here, they provide access to their home companies'
programs, their procedures, a working model of what
standards should be and how they work.
So there is a lot more going on than simply having
parachuted some folks in who are filling some leadership
positions. There are Northeast Utilities folks, operators,
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shift supervisors, whatever, going back to those utilities
and seeing how things work there. That has been a very
important aspect.
As I mentioned earlier, the company had stopped
benchmarking, but what is going on now is a lot of
interaction. Not solely with these supporting utilities,
but with others to get out and see how the industry really
does things. That has just opened individual's eyes.
COMMISSIONER ROGERS: Roughly how many people from
each of the units have actually gone off site to look?
MR. KENYON: One hundred.
COMMISSIONER ROGERS: All told or from each site?
MR. McELWAIN: A relative number. About 100 from
a site.
COMMISSIONER ROGERS: From a site?
MR. McELWAIN: The whole site.
MR. KENYON: Millstone, yes. It's not a practice
that, well, we did it, and that's the end of it. It's one
that we do as we need to do.
CHAIRMAN JACKSON: You are going to march us
through various things in terms of the higher order look,
but the highest order look involves the board itself.
MR. KENYON: Yes.
CHAIRMAN JACKSON: What confidence do we have that
the board is on board and fully supportive of what you are
. 15
outlining here?
MR. KENYON: First of all, I would not have taken
this position if I did not feel I had the full confidence
and support of not just Bernie as CEO of Northeast
Utilities, but also the board.
CHAIRMAN JACKSON: Can I get Mr. Fox to speak to
that? I think it's important that the Commission hear from
you.
MR. KENYON: Yes. Do you want me to give my
answer?
CHAIRMAN JACKSON: I want both of your answers.
MR. KENYON: I'll answer and then I'll pass it.
I would not have taken the position if I didn't
feel comfortable that I had the full support. I felt very
comfortable. I had it from Bernie Fox. I wanted and did
meet with a large number of the trustees prior to taking the
job, outlining what I thought the problems were, what I
thought I needed to do, and were they supportive of the game
plan. The response to that has been very positive.
As I think you are aware, the trustees formed a
Nuclear Committee. The Nuclear Committee meets twice a
month, which is quite unusual for this kind of thing. Once
by phone, once in person. The Nuclear Committee
periodically comes to the site.
As it happens, this was scheduled before this
. 16
meeting was scheduled. You're smiling, but it's true. The
Nuclear Committee met yesterday at Millstone, spent a full
day, got briefings from all the recovery officers, took the
time as part of their agenda to split up into teams, to go
into each unit, talk to managers, meet with employees, get
reactions, get their own direct impressions as to what is
going on and how well it's going on.
In addition, the Nuclear Committee has input from
George Davis and the Nuclear Committee advisory team.
That's a strong group of consultants. They are critically
looking at all of Northeast's nuclear plants on a regular
basis and they are providing separate, independent reports
to the committee as to what they see are the issues and
whether or not George and his group feel that the
appropriate actions are being taken.
The points I am making are, first of all, they are
fully supportive. I've got a budget to do what needs to be
done that is almost embarrassing in terms of the amount of
money it involves, and they are very engaged in looking at
what is happening, questioning what is going on, and
receiving a lot of input. So I am extremely comfortable
that the trustees as well as Bernie are fully supportive of
doing what is necessary to get these units where they need
to be, ready to operate, and that they can be carried
forward in a safe and reliable fashion.
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I will pass.
CHAIRMAN JACKSON: Let me hear from Mr. Fox on
behalf of himself and the board.
MR. FOX: Dr. Jackson, obviously I'm not going to
repeat many of things that Bruce Kenyon just mentioned, but
our very vigorous effort, both mine as the CEO and the
board's in their role as fiduciaries and as leaders of the
corporation, has been to demonstrated both by word and
presence full engagement and full support of Bruce, full
support demonstrated by the resources being made available.
And you're fully aware and I'm sure everyone in this room is
fully aware that that is a challenge, but it's a challenge
that we are committed to rising to.
In additon to that presence, by not only double
meetings of the board committee twice a month, but full
briefings of the entire board by the committee chair as well
as by Bruce on a monthly basis.
As he mentioned, it happened that our board
committee had been scheduled to be at Millstone for a full
day yesterday. And they were. Right now our plans call for
the committee of the board to spend a full day at Seabrook
next month. So we also recognize that although the high
focus is on the challenges at Millstone that we have other
nuclear facilities and we have to be sure that those nuclear
facilities also have the proper level of attention.
. 18
CHAIRMAN JACKSON: Thank you.
MR. KENYON: In bringing in a new leadership team
-- this is really what is happening to address the
fundamental problems -- what this leadership team needs to
do. I just want to emphasize this. Part of the issue has
been standards. So this team has to bring in what are the
right standards, set those standards, enforce those
standards. We have got to fix the processes that are not
efficient.
With regard to incumbent NU nuclear leadership, we
need to determine who are part of the solution -- in other
words, a keeper -- and who are not, and act aggressively.
We frankly do not have a lot of time for a whole bunch of
folks to have a get-well program. Either they pretty much
know what they need to do and can enforce the right
standards and the right accountabilities and manage this
well, or we've got to get folks who can.
We clearly need to create a proper climate for
employee concerns, but our overall challenge is -- and this
is really what is most important -- we need to fundamentally
change how Northeast Nuclear functions.
I had intended to talk about the issue of
leadership continuity. I think we have covered that on the
basis of your question.
Another issue I wanted to address with you is the
. 19
issue of leadership consistency, a little bit different than
the question of continuity.
In bringing in three teams, they are obviously
coming from different utilities. There are some differences
in how those utilities do business. Those differences have
turned out not to be huge. They are very modest difference
in cultures. I am not insisting on an identical approach
for each unit, but I do want the differences to be
differences that I can rationalize and feel comfortable
with.
It has been a challenge to do that and a lot of
the other things that I'm doing. As I already mentioned,
hiring Buzz Carnes, bringing him in as Chief Nuclear
Officer, having the three recovery officers as well as Jay
Thayer and an officer who is responsible for some other
support functions, really the Millstone leadership team at
an officer level all reporting to Buzz Carnes. Dave Goebel
as the Vice President of Oversight will continue to report
to me because he has responsibilities for more than just
Millstone.
The intention here is to have a strong senior
level person that will assist in leading the recovery of
these units, ensure that we have a reasonable consistency of
standards across the units, and certainly pay very careful
attention to the management transitions.
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I made the statement earlier that our most
important challenge, in my judgment, is not so much the
execution of the particular items in the recovery plan, but
really the most important challenge is fundamentally
changing how NU functions. We, the leadership team, have
spent a fair amount of time talking about what are the most
important objectives that we need to accomplish in order to
make that fundamental change in how NU functions.
[Slide.]
MR. KENYON: We have identified seven success
objectives as being the seven items that we believe are the
most important. We're not saying there aren't others, but
these are our top seven, so to speak.
We must be an organization with high standards and
clear accountabilities. I'm going to elaborate on each of
these. That means that we have incorporated maybe not all
but many of the best practices from other utilities. It
means that we are regularly benchmarking with other nuclear
utilities. It means that we have indicators that show
strong improvement toward excellence. I don't expect us to
be at excellence by the time we are ready to start up, but
we should be well on the way. And certainly we are meeting
our commitments.
Second, we must have a strong nuclear safety
philosophy, which means to me careful adherence to high
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safety standards and conservative decision-making.
We must have an effective self-assessment process.
That is not just oversight. That is also line management
being able to critically look at what is going on, identify
and deal with problems. I think the fundamental measure
there that I would want and I think you would want is to the
extent that there are problems we find them, and you can
have confidence that we know how to find problems and deal
with them.
We must have an effective corrective action
process, which means problems are prioritized and resolved
in a timely manner, and that we have improved regulatory
performance as demonstrated by decreasing violations and
licensee event reports.
CHAIRMAN JACKSON: Let me ask you two questions.
One is, what is your assessment of plant personnel
embracing the need for change?
Number one, so that we are not just talking
philosophically, in the course of your discussion are you
going to speak with any degree of specificity with respect
to what evidence there is of progress with respect to
self-assessment and effective corrective action?
MR. KENYON: Let me deal with the second question
first. One of our additional presentations is corrective
action. So we are going to talk about what we are doing and
. 22
the progress there. We have another presentation on
employee concerns and the progress we are making there. We
flagged talking about the issue of oversight and we just
concluded we didn't have time in the agenda, but certainly
if you would like to talk more about that in deference to
something else, Dave Goebel can address it.
As to your first question on employees and the
extent to which they embrace change, certainly what you have
in any employee population is a continuum of opinion from
those who clearly embrace it and are enthusiastic and let's
get on with it. I find at the worker level the employees
want to get on with it: let's do what we need to do. If
things haven't been right, they accept it. When you're on
the watch list, when the plants are shut down, when you know
you can't start up, when you know you can't be in this
situation forever, I would say the workers are very
enthusiastic.
The layer that I'm more concerned about is what I
would characterize as middle management below this new
leadership team, above the employees who basically want to
get on and get things done. I think in that middle
management layer we have a mixture of folks, some who are
very good, committed to do it, some who need to be told, and
we are telling them what's the standard, here's how we want
you to do business; we are going to hold you accountable to
. 23
it.
I think we have some who are fairly entrenched in
a historic way of doing business which we have to fix.
Well, we'll fix it. The question is, do we fix it by
teaching them how to do it or do we fix it by putting
somebody else in the position?
I think we are making good progress in reaching
the broader population. I don't think we have at this point
as much of a sense of urgency as I think we need to have,
and we are working on that. I don't think we have at this
point all our employees fully understanding the game plan,
and we are working hard at communicating that. But in
general we are not meeting any substantial degree of
resistance to the need to change. Employees know that
Millstone isn't in good shape and it needs to be in good
shape or they're not going to have jobs.
[Slide.]
MR. KENYON: Item five is reconstituted licensing
and design bases with a process to ensure that they are
properly maintained. We'll all know that on the basis of
the ICAVP contractor determining that the bases have been
restored. We also obviously have to demonstrate that we
have implemented effective configuration control processes.
Six is an environment that supports the
identification and effective resolution of employee
. 24
concerns. This will be characterized by very open and
candid communication with employees, timely resolution of
employee safety concerns, and certainly, per your order, an
independent review of the employee concerns program and
whether or not it has reached a state of effectiveness.
Finally, number seven is a commitment to achieve
excellence in nuclear operations. What this means to us is
that we will have to find what excellence means to us. We
will have a plan developed as to how we are going to achieve
excellence. There will be demonstrated good progress,
particularly on longstanding issues, and certainly issues
important to startup have been resolved.
CHAIRMAN JACKSON: That progress is important,
because every nuclear executive talks about commitment to
excellence. Excellence is as excellence does.
MR. KENYON: That's right. I don't disagree at
all.
Finally, we need to be able to show and
demonstrate that we have the resource commitments that meet
or exceed those of similar well run units.
I believe these seven objectives broadly capture
the most important aspects of what needs to be done to
fundamentally change how this organization functions.
[Slide.]
MR. KENYON: To talk briefly about the recovery
. 25
plans, they consist of certain major elements. I want to
link as I go through this the success objectives with the
elements of the recovery plans. The recovery plans were
developed on a unit by unit basis.
Recovery plans are laid out to achieve system
readiness, which means the licensing and design bases are
recovered. That's success objective number five, and that
will be the subject of a presentation.
The necessary design changes have been made;
system drawings are updated; operating, maintenance and test
procedures are where they ought to be and properly reflect
the design basis; the material conditions of systems and
equipment is proper, meaning corrective maintenance has been
accomplished; preventive maintenance is current.
That's system readiness, but we all know there is
a lot more to restart than simply the systems being ready.
The second item, and this captures a lot of these
other objectives, is organizational readiness. This is to
ensure that the broader aspects of the Millstone
organization are ready to support safe and reliable
operation. This means that we have set the appropriate
standards.
We are holding individuals accountable. That's
success objective number one.
We've established a strong nuclear safety
. 26
philosophy and people can see it in the decisions that are
made.
We have effective self-assessment.
We have an effective corrective action program.
We have the proper employee concerns environment, a
long-range commitment to excellence.
A lot of these success objectives go into
establishing that the organization is ready.
There also needs to be operational readiness.
This ensures that the systems and operating personnel are in
a final state of readiness. We'll talk more about this in a
future briefing. At a high level it means systems are
operable; it means the personnel have been trained; their
qualifications have been updated as appropriate; we've done
some special things to compensate for the fact that the
units have been shut down for a long time; we have the right
staffing.
Regulatory readiness means that all the
commitments that we made that are necessary to support
startup have been met. There is a good track record in this
regard, and it's characterized by extensive review and
interaction with the NRC at many levels in order to support
a rebuilding of regulatory confidence.
Finally, communications readiness. Here the
objective is that, first of all, our employees have a good
. 27
collective understanding of what we are doing and why,
particularly our standards. We have clearly communicated in
an open way.
There are a lot of ways you can look at this, but
the fundamental measure is on the basis of face to face
communication. I have the best sense of what is going on by
going out in the organization and talking to people and
looking at their attitudes, listening to their questions,
seeing what they are concerned about. That's how I judge
them.
CHAIRMAN JACKSON: Let me ask you this question,
Mr. Kenyon. Since in many ways communications in that whole
area are at the heart of how you deal with employee
concerns, and we are going to hear about that, you have the
face to face opportunity and you can have some comfort
relative to what your organization's state of readiness is
in that area. How are you going to communicate it to the
public and to us relative to a restart decision?
MR. KENYON: First of all, with regard to the
public, we are commencing a series of public meetings every
four to six weeks. The first one is in February. I'm not
sure I'm remembering off the top of my head the date. In
fact, I think we actually have two in February. A series of
public meetings. They are going to be topic-based.
The first one is going to be employee concerns,
. 28
but we are going to have other topics that we think would be
of interest to the public. We are going to invite the whole
world. We are going to have a leadership team; we are going
to have employees, depending on what the topic is.
For example, we have had this employee concerns
task force working on what is a good employee concerns
program. At this meeting where we go through the employee
concerns issues we are going to have members of the employee
concerns task force participate in the communication of what
we are doing and how we are doing it.
So with regard to the public, it's a series of
meetings, and we'll do this for as long as it's productive.
We just have to communicate, communicate, communicate.
CHAIRMAN JACKSON: Do you have metrics to measure
success?
MR. KENYON: We have public opinion measures that
we take on a monthly basis. I think these measures can be
refined, but we do that.
This is more subjective. The reality is most of
the public believes that there is a new leadership team in
place. My interaction with the public has been very
positive; my interaction with the media has been very
positive; and thus the general public is quite supportive of
"we want the units run well, we want the units run safely,
demonstrate that you can do that, bring these units back."
. 29
There is a smaller group in the public that is
much more vocal, but even my interactions with them have
been good. We are going to make sure to the extent that
group has issues -- I've gone on their talk show. They have
their own TV talk show. I've gone on their talk show. So
we are going to have interactions with them.
Maybe I'm an idealist, but we are committed to do
what is right. We are open and candid about what we are
doing, and that is going to come across; it is coming
across; and I think we sense it a lot in terms of just the
nature of the interactions that are going on in addition to
surveys that we take on a monthly basis.
With regard to the NRC, I think the key here is
that we have regular meetings, formal and informal, where we
just lay out what we are doing and how we are doing it, and
we have good dialogue as to what the issues are.
Certainly I'm looking for input from all quarters,
particularly including the NRC, and I think that if it isn't
clear already, it will be clear that we are very open, we
are very candid, and we're not trying to hide anything.
We're just going to lay it out there and have lots of
interactions. I think a quarterly meeting with the
Commission is excellent, and we welcome this opportunity.
Obviously the fundamental measure is performance,
and we intend to demonstrate that performance and then
. 30
communicate that performance.
To comment on schedules, first, we are committed
to do what's right. Standards are first; schedules are
secondary.
I have indicated that our most important challenge
is not so much the schedules as laid out in the recovery
plan but to fundamentally change how the organization
functions. That is not something that can be readily
scheduled. Thus it's our belief, although subjective, that
we can accomplish these fundamental changes in the
organization within the time frames that are laid out in the
schedule. But that's an assumption.
I have stated that standards are first and
foremost. A companion statement is that I need to convey at
least on our part a sense of urgency. Having three units
down for an extended period of time is a significant
financial drain on the company, and we really do need to
restart at least one unit this year. We just cannot keep
spending like this indefinitely.
My fourth point is that it's much easier to create
a schedule when the scope of the work is fully known, and we
don't know the full scope of the work because we are going
through a lot of reviews to see what needs to be done. We
have made allowances in our schedule for a reasonable number
of identified problems. We've made assumptions. We don't
. 31
know, for example, the sample size that is going to be
required by you of the ICAVP contractor. So whatever you
have determined in that regard obviously can significantly
influence the schedule.
My fifth point goes to the issue --
CHAIRMAN JACKSON: Let me talk to you before you
go off of schedules. By what date do you foresee having a
workable restart issues list for each unit?
MR. KENYON: We have a workable restart issues
list now. It's just that as we find new things we add to
it. As we close things we take items off. So we have a
listing of items required for startup now.
I want to talk a little bit about the strategy of
endeavoring to restart the three units in parallel, which is
a significant change from what was being done before I
arrived.
I think it's obvious to everyone that the most
efficient way to restart three units is to work all three in
parallel rather than one at a time. But I also fully
realize that there are potential interferences both within
NU and externally as to can you really do all three at once.
At the moment what we are trying to do is each unit working
what it needs to do, working those units in parallel, and at
some point there may be some interferences.
What I'm working to do and what the leadership
. 32
team is working to do is, as we see pinch points, we
endeavor to solve those: Can one ICAVP contractor do its
review of three units almost on top of each other? We've
concluded no.
So we've submitted the contractor for Unit 3. We
will be submitting contractors for Unit 1 and 2 and we're
going to be adding one additional contractor so we have a
greater assurance that this workload can be accomplished.
We also know that there are challenges to NRC
inspection resources: Can the NRC do what it needs to do
with three units coming back in parallel?
I want you to know this. I acknowledge that we
may get to a point where it's necessary to select a lead
unit, but my desire is to not do that any sooner than we
have to. I'd like to work three units in parallel as long
as we can work them.
I realize that it is an impractical reality to
have three units arrive on your desk seeking permission to
restart at the same time, and that is not quite what the
schedules show anyway. They are not that far apart, but
things are going to happen. We are going to encounter this
issue that we don't know about today or that issue that we
don't know about today.
I'd like to work these in parallel for as long as
we can work them. What we are asking of ourselves is, if we
. 33
ever get to a point that we've got to make some choices,
we'll make some choices. All things being equal, we'll pick
the largest unit. The reality is all things are probably
not going to be equal, and then we would endeavor to pick
the unit with the greatest state of readiness, the highest
probability of success, and at some point it will be one
unit at a time going across the goal line.
We are sensitive to the challenges that we are
creating for the NRC and its inspection resources. Our
commitment is to work with you and try and figure out ways
that we could be supportive and cooperative of the
regulatory challenges that you and the staff have.
CHAIRMAN JACKSON: Do the schedules that you have
developed for each site include all the important
milestones?
MR. KENYON: Yes.
[Slide.]
MR. KENYON: To wrap up, just quickly indicating
progress, a lot has happened in the last three or four
months.
We have established and communicated the root
causes of our nuclear problems.
We have brought in a new leadership team.
We have reorganized the nuclear organization to a
unitized concept with much clearer responsibilities.
. 34
We have established a recovery team for each
Millstone unit.
We have developed a recovery plan for each unit
and a recovery plan for oversight.
We have begun the process of raising standards and
improving processes.
[Slide.]
MR. KENYON: The ICAVP contractor has been
selected for Unit 3 and we will be communicating shortly the
recommendation for Units 1 and 2.
We've established a virtually new oversight
leadership team, and that includes a new director of
employee concerns.
We have selected the employee concerns oversight
contractor.
We have a new employee concerns program developed
by the team. As I indicated, a lot of employee input on
this, and because we wanted to get the employee input and
because they really wrestled with how this program needed to
be established, it took a little longer than we hoped, but
that submittal will be made tomorrow, and Dave Goebel will
talk more about the employee concerns program.
[Slide.]
MR. KENYON: We have approved a significantly
improved corrective action program. Jack McElwain will talk
. 35
about that in more detail.
We have addressed the issue of leadership
continuity through startup. I've talked about that.
I haven't mentioned this up to now. We have
conducted a leadership assessment. In other words,
employees assessing their leadership on leadership
characteristics, not technical skills. We just have the
results of that being communicated, but that's important
input to us on this question of who is part of the solution.
CHAIRMAN JACKSON: Are you going to talk to us
about the results?
MR. KENYON: No, because I have not personally
been briefed on the results yet. Some of these folks have.
If you'd like, they can. It's just that my briefing hasn't
taken place yet.
CHAIRMAN JACKSON: I think it would be interesting
for us to hear to the extent you are prepared to talk about
it. You don't have to take a lot of time.
MR. KENYON: Marty.
MR. BOWLING: For Millstone Unit 2, as Bruce has
indicated, all employees who were invited, that is,
voluntarily, could rate their immediate supervisor and any
level up in the organization all the way to Bruce.
We have the results back on that. They have just
been received this week and we are just looking at them.
. 36
The rating scale was between one and eight. On Unit 2 the
aggregate score for all supervisors was around a five.
CHAIRMAN JACKSON: What does one mean?
MR. BOWLING: One was the lowest.
MR. KENYON: One means strongly disagree. In
other words, we asked 26 or 28 leadership questions. This
is a variation on what we did at South Carolina Electric and
Gas, a very important tool for us. There are questions on
leadership attributes and each employee basically has boxes
to check that range from strongly agree, because the
leadership characteristic is stated in a positive way, to
strongly disagree, meaning my supervisor doesn't do that.
If you get a score of one, that means you've got strongly
disagree on everything. The other end of the scale is
strongly agree on everything.
MR. BOWLING: So it basically came out on the
average, but you can see for individuals deviations one way
or the other.
Another good feature of this, for each low rating
the employee was asked to provide the major reason for that,
and there were three or four possibilities. The two most
prevailing reasons coming out for a low score is that the
supervisor doesn't have time or the supervisor doesn't
perceive this area that I'm working in as important.
CHAIRMAN JACKSON: What do you intend to do with
. 37
the results?
MR. KENYON: I'm going to sit down with each of
the officers. We've solved the leadership problem at the
top of the organization. The next layer down for us is
directors. We have changed out over half the directors.
The next layer down is managers and supervisors and so
forth.
A critical issue for us is we need to understand
who is clearly part of the solution, who clearly doesn't get
it, in which case they go, and then to the extent that there
is a question mark there and the leadership assessment is
input, then we have to decide how bad is the problem and do
we think we can fix it in a short period of time or not. If
we think it's fixable, there is a decent chance of fixing it
in a short period of time, we'll hang in with the
individual. If we conclude it's not fixable in a short
period of time, then we are not going to hang in with the
individual.
CHAIRMAN JACKSON: How are you defining short
period of time?
MR. KENYON: A couple months. We are going to do
a leadership assessment again in six months. Our objective
is a significant improvement in the leadership scores. For
whatever it is we got this time we want to see a significant
improvement next time.
. 38
COMMISSIONER ROGERS: Before we leave this
progress topic, could you say just a little bit more about
your unitized concept? What activities are unit-specific
and what are shared by the whole site? For example, to what
extent is engineering unit-specific and maintenance
unit-specific?
MR. KENYON: I will give you some examples. I'm
going to ask the other folks on the leadership team to throw
in some more.
For example, on engineering, there is a
centralized organization that sets the engineering
standards, that sets the programs, but the accomplishment of
the engineering is on a unit by unit basis.
Similarly with license. We have a centralized
organization that is going to set overall policy and
strategy, but to the extent a regulatory commitment is made,
it is almost always a unit-specific commitment.
This has been a problem in the past, because a
centralized organization made a commitment that really the
unit had to carry out, but the unit didn't own the
commitment because they didn't make it. So we've had a lot
of problems with this outfit doing this and that outfit not
living up to it. So regulatory commitments are going to be
managed on a unit by unit basis, and thus if a commitment is
not met, it's very clear who is accountable.
. 39
We have a centralized training organization, but
the units have to be satisfied that they are getting what
they need. So training is support.
Jump in with some other examples.
MR. McELWAIN: A further example on the programs,
like the motor operated valve program, the erosion/corrosion
program, those things are managed out of Jay's organization
and implemented at the units. A different program is the
corrective action program that I'll talk about. It's a
site-wide program. So everything that we can now determine
still makes sense to be one program for everybody, like MOVs
and like corrective action, that's the approach we are
taking with that.
Each of the units where the central group will
take a lead in trying to enhance the particular program, for
example, corrective action, was a three-unit operation to
get it where it is today, but I get to talk about it because
I was assigned the sponsorship for that program.
That's how we have taken things that were very
cumbersome to do and were universal, if you will, and
sometimes we have unitized them and sometimes we've not.
The critical aspect is, if it applies to all units, we'll at
least pilot it on one unit and then make it common across
the three. It makes sense from a practical standpoint
rather than have three organizations trying to do the same
. 40
thing to have somebody pilot it, input from the other two
units, make it common, and then manage it from there.
COMMISSIONER ROGERS: The engineering design basis
reconstitution, I'd like to hear about that. Not
necessarily now but at some point.
MR. KENYON: That is a presentation
COMMISSIONER ROGERS: I'd like to hear how
unitized that is and how general it is.
CHAIRMAN JACKSON: Mr. Bowling, you were going to
say something?
MR. BOWLING: Yes. I think the approach is for
the unit to have those organizations in it which it needs to
provide the conduct and support of operations and
maintenance. From the engineering perspective with the unit
are three key areas:
Design engineering for any modifications required
to the plant.
The technical support area, which is basically
system engineering, and also regulatory and technical
programs.
The third is the configuration management
restoration under 50.54(f).
MR. KENYON: At this point I would like to call on
Dave Goebel on employee concerns.
MR. GOEBEL: Thank you, Bruce.
. 41
Just a short introduction of myself. My name is
Dave Goebel and I'm a 34-year navy veteran, having spent 25
years of that in the Naval Nuclear Propulsion Program either
at sea or ashore. Eight of those years were in shipyard
periods doing major reactor plant maintenance, refuelings,
training for restart, and that sort of thing. And I had two
years as a senior member of the Naval Nuclear Propulsion
Board doing examinations on reactor plants.
The remainder of my career was either in school or
working on national policy issues. I was fortunate to have
had the opportunity to work with General Powell in
concluding the START Treaty at the assistant secretary
level, and most recently have worked with DOE and the
national labs and DP on sustainment of the nation's nuclear
weapons stockpile without the benefit of underground nuclear
testing.
I was part of the navy's original retention
program that started back in the early and mid-1960s, and
throughout my navy commands the retention of my
organizations has always improved.
And I've been with Northeast Utilities for four
months now.
[Slide.]
MR. GOEBEL: The subject that I'm going to talk
about today is the employee concerns program.
. 42
The fundamental objective is the number six
objective which Bruce has just given you. We want to
establish an environment that supports the identification
and effective resolution of employee concerns.
[Slide.]
MR. GOEBEL: There are two prongs to that, the
first of which is the preparation of the comprehensive plan.
That plan was written with the assistance of the
employee volunteers. As Bruce has said, we put a call out
for volunteers, for people who would be interested in doing
that. We had 20 people come forward. We made no
selections.
We took those who sincerely wanted to work on it
and set them down for what started out as as month and then
ended up a little over two months with no real bounds on
them. They were free to suggest anything they wanted to
suggest, and it was done with the employee group essentially
with no oversight. They had the opportunity to say what
they felt and to line out a program.
We had two facilitators which we hired to bring in
to try and facilitate the discussion so that they would have
an idea of what good programs were in other utilities, and
they provided a program which has been the foundation for
what, as Bruce has said, we will be submitting tomorrow.
That plan provides for increased training for
. 43
members of the work force as well as members of management.
It works to improve the effectiveness of the ECP,
that is, the employee concerns program, through a series of
process improvements.
We will be increasing the accountability of
individual behaviors of management. As part of that we will
have a system where we will do hot spot analysis. The
leadership survey will certainly help us in that regard, to
identify those managers who harass or intimidate.
Likewise, confidentiality is extremely important
to us, and this program helps set in place the protocols to
ensure we sustain confidentiality for those folks who have
concerns and who want to have confidentiality.
A key part of the program is the establishment of
an employee concerns oversight panel. The function of that
panel will be to oversee the employee concerns program
itself. That panel will consist of members from the work
force. They will additionally monitor for chilling effect;
they will monitor for harassment.
At the end of the day, when an employee has had
his concern dealt with in the best way in which the program
thinks is appropriate and everyone has had their say, if the
employee is still dissatisfied, there will be a provision to
have a third party reviewer to come in, take a look at it,
and give judgment on the employee's issue.
. 44
So we think that this particular employee concerns
oversight panel will go a long way towards helping ensure
that the concerns are properly handled.
COMMISSIONER ROGERS: How many people are on it
and do they stay on there? Or do they rotate?
MR. GOEBEL: We are currently planning seven with
a full time administrator. There will be some sort of a
rotation plan, maybe after a year and a half to two years,
but it's going to be a reasonable period of time.
There is some question as to whether the panel
should have outside members on it similar to a nuclear
safety assessment board. Those are being weighed now to try
and sort out what gives a fair, impartial effective panel to
take on the issue that may or may not come up.
CHAIRMAN JACKSON: Have you done any comparison of
your proposed program to programs in other industries or in
other companies?
MR. GOEBEL: We have in other companies. The team
was encouraged to go out and sample other utilities, and
they have done that. They went out as part of their
preliminary work, found out what other utilities had done,
and our two facilitators for the group had come from a
background of very heavy involvement in employee concerns
programs. So they could provide some of that insight on
what were good programs, what were not good programs, what
. 45
really made sense to do and what didn't.
The team embraced them. They felt very
comfortable with the two folks that came in. As I said, we
stayed out of it. It was their process.
CHAIRMAN JACKSON: You've laid out the
comprehensive plan objectives, but I'm always performance
oriented. What are your metrics for knowing that you've
accomplished it?
MR. GOEBEL: "Show me."
CHAIRMAN JACKSON: But how are you going to know
you've accomplished those objectives and how will more than
Dave Goebel know that you've accomplished those objectives?
[Slide.]
MR. GOEBEL: This slide and the next slide are ten
objectives, and I won't bother reading them.
First off, it might help to understand where the
objectives came from. The objectives came from those
deficiencies that were outlined to us in two fundamental
reports, the FCAT report, fundamental cause assessment team
report, which had been commissioned by the company, and the
Hanan report. Those reports went through and delineated in
some detail where historically we had failed to meet the
mark.
The program sets its objectives, and these were
the objectives that the team set out to satisfy, to look at
. 46
these things and to say, what does it take, what are inputs
that if we did certain fundamental actions would lead to a
correction of that deficiency. So they have devised a
series of 110 or 120 different types of things which should
be looked at in order to go through.
Those have been formulated into concrete packages
to lay out a process in which we will address each one of
those. When the plan is submitted, it will be submitted
with these objectives in it, and next to those objectives
will be elements which we carried out in order to satisfy or
meet those objectives.
Measurements will come in probably three ways.
One is the standard KPIs that will come out of it
and measure a number of concerns, how long they are open.
Just those types of things that show effectiveness of the
program.
A second measurement method will be through the
third-party oversight panel which has been directed by
order, and I'll talk to that in a minute.
The third way is you go around and ask. Bruce has
plainly said this. We have got to establish the rapport
with the work force that management is interested in their
issues. We want to hear them, we want them to bring them
forward, and we will accept them and work with them in order
to solve the issues that they have. Whether they be safety
. 47
issues, personnel issues that affect the performance of
their job, we will help them see that those types of issues
get solved.
Although the fundamental focus of the program may
be safety issues, we recognize there are a lot of other
issues out there that the work force also has, and we will
facilitate getting those to the right section of the
organization.
CHAIRMAN JACKSON: Will the effectiveness of the
line managers in dealing with employee concerns all the way
up the line be part of the performance appraisal for those
individuals?
MR. GOEBEL: It will. One of the taskings that
will go out to the human resources development process is to
go back and modify job descriptions to make it a
consideration when hiring individuals, and it will go into
our internal evaluation system. So when you evaluate an
individual there will be a box there that says how does he
or she do in relation to handling employee issues, employee
concerns, or whatever. So every time your annual review
comes up you will be graded on that assessment to make a
determination as to how you as an individual have done.
CHAIRMAN JACKSON: Relative to the objectives that
you've laid out in this overall comprehensive plan?
MR. GOEBEL: There will be guidance that lays out
. 48
how they should do that process. Yes, ma'am.
[Slide.]
MR. GOEBEL: Unless there is interest, I won't
read those ten items. It's still line management's
responsibility to make this program work. They have got to
demonstrate that they have the willingness to talk to their
employees.
They have got to demonstrate that they have
established an environment where safety questions are
welcomed.
Additionally, the line is responsible for
championing zero tolerance for harassment, intimidation and
discrimination.
COMMISSIONER ROGERS: What does zero mean? What
does that really mean?
MR. GOEBEL: What it means is that, one, it is not
a tolerated management precept that if you harass a fellow
employee that that's an accepted mode of behavior, and they
must work to root those out, have systems that help them
identify that through their own management chain.
Some of it will be feedback from the employee
concerns program, either through this concerns oversight
panel which we have established or through just the handling
of the concerns themselves that will come out of the
process.
. 49
But they have got to champion that and they've got
to make their people understand that in the course of doing
their business they will not tolerate that behavior in their
own organization. So in that sense it's zero tolerance. I
do not allow that here.
MR. KENYON: It means if we find it, we're going
to deal with it severely, up to and including firing the
individual.
[Slide.]
MR. GOEBEL: The ECP program then becomes a safety
net for the line.
The ECP program will assist the line in handling
the concerns, acting fundamentally as a facilitator.
In those cases where that doesn't work, then the
ECP program provides an alternate path. Today that path is
necessary. The trust of some of the employees remains low.
We've got to regain that trust, and this program is one way
to do that.
CHAIRMAN JACKSON: Do you find there are new hot
spots emerging?
MR. GOEBEL: Not right now.
CHAIRMAN JACKSON: Have the old ones been
resolved?
MR. GOEBEL: There has been such a shift in
management that we have not seen new ones develop, and the
. 50
old ones that might have existed have not risen up.
As we go through this process of evaluating
members of the management team at all levels for leadership
characteristics and people are forced to walk the talk, we
are going to find out very quickly those that are on the
team and those that are not on the team, and if we have a
hot spot, it's clearly because we will have found in an
organization an area where there is not someone on the team.
[Slide.]
MR. GOEBEL: In addition to the plan, we have
submitted the name of a third-party oversight team, Little
Harbor Consultants. That's a ten-person team. In so doing
we have received inputs from over 20 different companies or
individuals who wanted to be a part of the process as we
went through this. We asked eight companies for RFPs and
ultimately interviewed six, and the selectee out of that
process became the Little Harbor Consultants.
Their function is clearly outlined in the order:
Provide an independent assessment.
The need to evaluate for improvement.
And they need to determine what the needs are for
additional change.
After reviewing their qualifications, they came in
and briefed us, told us how they intend to conduct business,
how they intend to work to involve all the stakeholders,
. 51
including the public in the process. I think they've got
what it takes to do this job.
COMMISSIONER DIAZ: Excuse me. I have a question
on that. I'm sure when you evaluated Little Harbor you were
very concerned with their experience in handling employee
concerns. Was it clearly established that they had the
capability of correlating safety concerns with safety issues
in a manner that will be clearly and promptly identified?
MR. GOEBEL: Yes. I believe they have five
engineers who are specifically skilled in the areas. If
there is a safety concern and we fail to recognize it, they
certainly should be able to.
COMMISSIONER DIAZ: Thank you.
[Slide.]
MR. GOEBEL: The final thing I wanted to say is we
have had some successes in the recent past. So we are
making progress.
I cite on the slide that on the first of December
we had 44 concerns which were under investigation and the
oldest was up to four years old. In the previous two or
three years or four years our average closure time was over
200 days. Very long. Things just sat; they festered; there
was no satisfaction really given to the employee when he or
she had a concern that anybody cared. It's clear from the
statistics.
. 52
As of the 24th of January, a little less than two
months, we had 22 open concerns that were under
investigation. The oldest was about 22 months old, and that
includes what was a holdover from the previous number. But
those received since the first of December through the 24th
of January the average closure time was about 18 days.
So clearly there has been a prompt change in the
process. That I attribute to two things. One is a very
senior level involvement on the part of the units. The unit
recovery officers and the unit directors are personally
taking an interest in resolving these concerns.
That is filtering down through the organization.
The organization then starts to see at the middle level the
concerns which Bruce has talked about. That is going to go
a long way towards improving the overall handling of these
issues and the restoration of the employee trust in
management.
I will say also that the submission rate of
concerns to the employee concerns program has increased.
Frankly, I don't take that as all bad. I want them to say
the stuff. I don't want them to be out there allowing these
things to fester and not come forward. We are trying to
generate an atmosphere where they truly know that we want
the concerns that they see; we want them to bring them
forward; and we want to get them no matter how we get them;
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we don't want them to sit there and fester.
If there are no other questions, that concludes
the briefing.
COMMISSIONER DIAZ: I just wanted to make a
comment that since this deals with employee concerns and how
they are doing their jobs and you have changed from the
military to the civilian, we will not hold against you your
distinguished military career.
[Laughter.]
MR. GOEBEL: Thank you very much. I appreciate
that. No further comment.
CHAIRMAN JACKSON: Commissioner Rogers.
COMMISSIONER ROGERS: Not on this. Thank you.
CHAIRMAN JACKSON: Okay.
MR. KENYON: Jay.
MR. THAYER: Good morning. I'm Jay Thayer. I'm
an electrical engineer by training. I spent 23 years in
various technical and managerial positions in the commercial
nuclear power industry in both engineering and operations
areas of responsibility. I've been in executive management
for the last six years, most recently serving as the Vice
President of Engineering at Vermont Yankee Nuclear Power
Corporation.
[Slide.]
MR. THAYER: The purpose of my presentation this
. 54
morning is to cover what Bruce outlined as objective number
five, and the measurement of that is we must have by restart
restored licensing and design basis with processes to ensure
that they are properly maintained.
We are currently implementing our configuration
management plan to restore the design and licensing basis
for the three Millstone units, and the effectiveness of our
efforts will be independently confirmed by the ICAVP
contractor.
A little bit about my role. As discussed before,
my organization is a standard setting organization. In
addition to some of the engineering programs that we manage,
we run the 50.59 procedure; the design control program is
under my organization; the configuration management program
and technical programs as mentioned before, such as the MOV
program.
We have moved into a more active role in the
configuration management program. As the three units
developed the programs last summer and last fall, in the
last several weeks, since about the first of the year, we
have moved into a role of overseeing and trying to levelize
that effort.
One of the first accomplishments that we made was
we performed a self-assessment of the three-unit
configuration management plans, looking for consistency. We
. 55
understood going in that they would not be identical, but we
also understood we wanted some level, some standard set so
that when the ICAVP contractor came in or when your
inspection people came in there would be some common
understanding of what had been done to restore both the
licensing and the design processes.
Furthermore, as of about a week ago I've initiated
under the direction of Bruce Kenyon an independent
assessment as to the degree of consistency that will be
needed for the units in implementing the CMP.
My current plan is to bring in some of the outside
senior review people who have been engaged in reviewing the
50.54(f) responses for the industry. I feel that the
knowledge that has been gained by those folks in the last
few months will be vital to us, number one, to benchmark our
efforts against the industry efforts, and also to achieve
this consistency goal that we are looking for on the
Millstone site between our three units.
[Slide.]
MR. THAYER: The stated purpose of our
configuration management plan is very simple. It's to
provide a reasonable assurance that the future operation of
each unit will be conducted as specified in the terms and
conditions of the unit's operating license, NRC regulations,
and the unit's updated FSAR.
. 56
[Slide.]
MR. THAYER: Getting back to the configuration
management plan, this is our guidance document. It's simply
to tie our actions that we take in configuration management
to the requirements of the 50.54(f) letters, the various
letters that have been issued for the three Millstone units.
[Slide.]
MR. THAYER: This configuration management plan is
a high level document.
It applies to all three units.
It is implemented by a series of project
instructions. Over the past month the effort has been to
update the project instructions to more accurately reflect
what is going on on the three sites and to look for
consistency.
CHAIRMAN JACKSON: Could you describe the
availability of the design and licensing basis information
at each site?
MR. THAYER: It varies and it varies primarily, as
you would expect, by the vintage of the plan, the vintage of
the license, the type of the NSSS, and also, quite frankly,
the time that the various configuration management teams
have been in place.
The level of investigation on Unit 3, for example,
is ahead, primarily for two reasons. One, because the team
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has been place longer; two, because the vintage of that unit
is such that a lot more of the design basis is more readily
recoverable.
On Unit 1, for example, the FSAR is simpler. The
backup to that, the calculations, the design, the drawings,
there are fewer in number of them. So even though it is an
older unit, the amount of information to recover is less.
That has held true.
There are other idiosyncracies. We find pockets
of where certain parts of the design and licensing basis
have been particularly well maintained. For example, the
incidence of findings on the Unit 2 FSAR is lower for some
reason than the other two units. We don't understand that
yet; we don't want to attempt to explain it; but it's just a
finding as we have marched through the various design
documents and licensing documents.
CHAIRMAN JACKSON: Are you saying that you will or
you won't have a large reconstitution effort to do?
MR. THAYER: The reconstitution of information
will be taken on a case by case basis and it will be decided
based on the safety significance or on the ability for us to
prove the function of a particular system or the function of
a particular component. If it is deemed necessary to be
able to prove a design basis fact to reconstitute, then we
will reconstitute.
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[Slide.]
MR. THAYER: We also understand that design basis
and licensing basis recovery involves ongoing processes.
These processes have not been done well in the past at
Northeast Utilities, and we understand that the
configuration management plan is not a one-time effort. In
recovering, reconstituting, documenting, collecting the
design basis and licensing basis we also have to put into
place robust programs which will ensure that these processes
continue on or after restart and for the remaining life of
these plants.
[Slide.]
MR. THAYER: To wrap up, the engineering programs
and the documents that are being assessed. We will have by
the start of the ICAVP a significant amount of that
information corrected and updated. We provided the
remaining updates to the information prior to restart, an
update of all the engineering programs and the processes to
support the updating of those that I mentioned a minute ago,
well developed and implemented and validated prior to
restart.
CHAIRMAN JACKSON: Let me ask you this question.
You talked about a review of NRC commitments. What has your
early sampling told you? Where do you stand with respect to
that?
. 59
MR. THAYER: From the standpoint of access to the
commitments, on Unit 1, for example, we have completed a 100
percent review of the commitments. So the first point is
they are easily retrievable.
The second point is we feel that that is the
discovery retrieval. We are going through the validation:
Have those commitments been carried out in the practices and
procedures on site?
CHAIRMAN JACKSON: That's what I'm interested in.
MR. THAYER: I don't have a good feel for that at
this point. That is the validation process that we are
currently going through.
MR. BOWLING: I would add, Jay, that that's the
effort that is about to be undertaken on a large scale. So
over the next three to five months they will be validated
and results will be in.
CHAIRMAN JACKSON: So I should ask you again at
the next meeting?
MR. BOWLING: Yes.
CHAIRMAN JACKSON: With respect to the FSAR review
and update, what is your progress in that area and how would
you categorize the findings to date? If you could give a
few examples and talk about their risk significance.
MR. THAYER: The FSAR was one of the first areas
of review and discovery in the configuration management
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plan. Mike might want to talk about the Unit 3 progress in
that area because it's further along. But we have a
significant number of findings on all three of the FSARs.
Like I said, Unit 2 being less for some reason.
Right now we are going through a process of
prioritizing those findings: What is the impact? I won't
trivialize it by a typographical error. Does it impact the
ability for the system to satisfy the design basis fact in
question? Does it misrepresent a system design basis fact?
Does it not capture a critical licensing commitment?
These are being prioritized and screened right
now, and they will also be prioritized as far as which one
of those will go into our FSAR updates which will be
submitted prior to startup.
CHAIRMAN JACKSON: What improvements are you
looking to make in your 50.59 program?
MR. THAYER: We have made quite a bit of progress
in 50.59 already. In one of the early efforts last fall we
had an initiative by Unit 1 to perhaps adopt one of the PECO
50.59 processes. We put a team together, some of my folks,
the Unit 1 folks.
We looked at the existing Northeast 50.59 process
and came to the conclusion that the process of performing
the safety evaluations was fairly current; it was fairly
rugged; it stood the test against an industry benchmark; but
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what we found was our screening process for when we should
be performing 50.59s was terrible.
In other words, the 50.59s that we were doing,
most of those have been pretty good safety evaluations, but
we weren't performing safety evaluations on changes and
issues that came up on operability determinations as were
others in the industry. So our screening process to tell an
individual when a 50.59 was necessary was broken.
That has been the major focus of the procedure
upgrade. That procedure has been revised, and training is
going on right now with personnel to implement that
procedure.
CHAIRMAN JACKSON: When you speak of meeting the
50.54(f) letters prior to restart, what do you mean by that?
And in order to have time for the NRC staff to review, you
have to resolve what prior needs in that regard?
MR. THAYER: We understand that. It's my
understanding that the formal letters have a seven-day prior
to restart commitment in them or request in them. That
obviously is not enough time to assure compliance with all
the requirements of these letters. We have built in various
time frames in our recovery schedules for inspection
activities which would come after the ICAVP which would
monitor progress prior to restart. I don't have the exact
time frame, but there is a considerable --
. 62
CHAIRMAN JACKSON: You've built in and resolved
those milestones with the NRC staff?
MR. THAYER: I wouldn't go so far as to say
they've been resolved yet. However, we have acknowledged
that it will take a finite amount of time and not seven days
to resolve those kinds of issues.
MR. BROTHERS: Chairman Jackson, Mike Brothers.
In terms of the official schedule that we are putting on the
units, our schedule goes up to the point of when we are in
fact ready for restart. In other words, when we submit that
letter to you. After that there is no formal schedule.
CHAIRMAN JACKSON: Okay.
MR. McELWAIN: Good morning, my name is Jack
McElwain. I'll keep the intro short. I've been with PECO
Energy since 1968 and I've spent since 1984 at Peach Bottom.
I've been here since October.
[Slide.]
MR. McELWAIN: I'd like to talk a little bit this
morning about the corrective action program.
We saw a need and the need has been obvious over
time that the corrective action program did not work.
The first slide tells you the things that were
lacking in the corrective action process, i.e.
accountability, quality and timeliness of the evaluations.
We didn't have an effective issue and commitment tracking,
. 63
and we didn't do very much trending at all.
CHAIRMAN JACKSON: Was the QA involved in that?
What is the QA organization? Have they looked at this area
of issue trending recently, and what definition is there to
effectiveness in this context?
MR. McELWAIN: It's easier to say the opposite,
that they weren't effective because we didn't really do it.
CHAIRMAN JACKSON: That's ineffective.
MR. McELWAIN: That's just the way we were in the
fall. But the oversight organization did do a corrective
action audit in November while we were in the process of
changing it, and they did validate that the things that were
happening in the past were still not fixed.
CHAIRMAN JACKSON: Does this mean your QA
organization needs reconstitution, or is there something
else, some other way?
MR. McELWAIN: I think the QA organization from
the past is being reconstituted, and that is one of the
recovery organizations that is happening in parallel with
us. So I don't think that is something new.
CHAIRMAN JACKSON: The first role is with the
line, but the role of the QA organization is important on a
going-forward basis. You have the corrective action
program. It's important, at least in my mind, that we
understand how that reconstituted QA organization and your
. 64
handling the corrective action program coalesce.
MR. KENYON: We had targeted that as a future
presentation. I think coming into this it's obvious that
oversight, meaning QA and other things, was not right. Dave
has done a lot to fix that. I feel much better about the
audit reports that we have today versus what we had a month
or six weeks ago. We do plan on a future presentation to
give you.
CHAIRMAN JACKSON: So you want to talk to us today
about overall where you are planning to go in corrective
action but this is a commitment that you are going to talk
to us specifically about the QA organization and how it fits
into this.
MR. KENYON: Absolutely.
CHAIRMAN JACKSON: Okay.
MR. McELWAIN: We did revise the corrective action
program to address these issues. But more importantly, we
took a management perspective at each of the units. We had
a management review team that looks at every adverse
condition report that is generated, and it used to be a
different process than it is now.
The process now is the management team looks at it
every day. We determine the significance level of it. We
assign it to a certain individual. We have established
commitments, had people own up to those commitments and own
. 65
that particular ACR and follow through to completion.
Historically you could have an adverse condition
report closed without all the corrective actions being
complete. We stopped that. No adverse condition report
-- in the new model it's going to be condition report --
will be closed without the corrective actions being
complete. It's a lot harder to lose track of things that
you said you were going to do versus did you do them.
That same cross-discipline team looks at all the
corrective actions and root causes on the adverse condition
reports to determine if they really meet the description of
the incident or the adverse condition itself.
We also look at the proposed corrective actions
and the timeliness of them to see if they fit where we think
they should be in the grander scheme of things.
[Slide.]
MR. McELWAIN: We have upgraded root cause
analysis capability. It comes with the change in the
process. For example, Unit 3. A whole lot of people have
been trained. What they are using is a vendor FPI process
on causal analysis trending, how to do those particular
issues. That's captured in the procedure.
Unit 2 has a lot of people trained in that. Unit
1 has less people in that, but we're all going down the same
path. This is one program across the units, and that's how
. 66
we are going to make sure that we really do the right root
cause analysis of the right causal factors.
A key to go hand in hand with a good corrective
action program is two issues.
One is a self-assessment. I don't mean
necessarily formal self-assessment as prescribed on a
bi-yearly basis like most utilities have. It has got to be
a constant way of looking at how you do business, whether
it's how you did the performance that week or it's how an
operator evolution went. It's constantly being critical in
figuring out how to do things. Even if you did them well,
how to do them better. That's what I'm looking at as the
self-assessment piece. It has to become generic to the site
and the way we normally do business on a daily basis.
The other part of that is a worker observation
program. What this implies is that management can't be
sitting in a different building. They have to be out in the
plant. They have to be observing the work activities. If
they see something that is not correct, they have to take
immediate intervention on it, even if it's something as
simple as earplugs required.
You talk to the people about what they're doing,
look at the procedures, see how they are doing the work to
make sure that you do a one on one immediate intervention.
Raising the standards is an easy way to do that. You get
. 67
out there. People become more engaged in the bigger picture
of how the power plant works if they are not stuck in their
particular office looking at paperwork, ACRs or AITTS, which
are the computer systems that track these issues. I think
those two things are going to be important in allowing us to
have a better corrective action program going forward.
[Slide.]
MR. McELWAIN: The corrective action formal
program change is effective the middle of February. We
instituted from a management perspective the things that are
in there back in November, but this formalizes that and
gives us time to train the people that have to do different
evolutionary steps in the process to allow it to be done in
a controlled, efficiency manner.
We also have established strong line management
ownership and accountability for the corrective action
process. It's one of the issues that I am the sponsor for
and the other unit recovery officers as well as Jay have
issues that they are sponsoring.
It shows mainly if people understand that
management has an interest in it, they are the things that
they are going to be interested in. This will also help
with employee concerns. If somebody identifies something,
we can fix it right and don't have it happen again. It
doesn't have to wait and fester and turn into a concern
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sometime down the road. That also will help that program.
We have performance indicators presently for each
unit, by each organization to trend issues coming in at
significance levels, whether they are overdue or not
overdue; corrective action is being developed as well as
completed. It's a whole series of indicators that we go
over in house on a normal basis. Actually on a weekly basis
at Unit 1.
[Slide.]
MR. McELWAIN: The indicator I attached was just
to give you an idea. This is just raw data on the adverse
condition history since September of those that have come
in, which is the dotted line, and those which have been
closed out, which is the solid line.
As you can see there is a screaming up the hill,
which is what we would expect it to do. The threshold is
very, very low. We get some things that could appear to be
nonsensical in a certain environment. We don't treat them
that way. We don't say that can't be an ACR. We make it an
ACR. We go along with it. We give it the significant
level it needs. If it's something we can trend, something
we use in the trending bin, something that requires
immediate action, we try to take that action.
In the solid line rising you see to match the
input there is a real time lag. There is a big backlog of
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ACRs historically. When the recovery teams first got here
we set up with each individual who had responsibility for
these actions: When are you going to be done? We need your
commitment to do it. Tell us what resources you need and
we'll get them for you.
Most of them, as you can see, kind of focused on
the end of the year, because we were asking this question in
early November. That rise in the closeout rate is based on
people starting to meet those commitments that they made to
close those ACRs out. That's really all that graph is
indicative of.
CHAIRMAN JACKSON: Commissioner Rogers.
COMMISSIONER ROGERS: The correction action
program, of course, is very important. But it's sort of
implies that it's corrective, that something didn't go right
and it has to be fixed. In this worker observation program
you focused on management participation. Have you given any
thought to actually using workers to help to identify better
ways of doing things so that you avoid something that has to
be corrected?
MR. McELWAIN: Yes. In the new program there are
three levels. There used to be four. They used to be A, B,
C and D. Now they are 1, 2, 3. One and two are the real
issues that are corrective actions.
Category 3 is enhancements. You want to improve a
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procedure that you don't have control of, that you can't
improve yourself. A work process you want to improve;
something you think could be an enhancement no matter what
it is. That's what the level 3's are going to be for.
That's the formal avenue for doing that. That's
why we have to have everybody understand what that process
is for and why it's necessary to have these issues come out.
Even if they are enhancements and improvements, you capture
them, you assign some actions to them, and you track them to
completion.
The thought going into the change was the first
two are significant, could be plant, could even be people
issues, but the third is really for enhancements and
improvements.
MR. BOWLING: I would add something. The way that
we are getting at this is to bring from our utilities people
up on a temporary basis. For example, licensed operators
that then can observe what shift operations is and make
those type of observations to the right standards.
CHAIRMAN JACKSON: Mr. Kenyon.
MR. KENYON: Chairman Jackson, in the interest of
time I'm going to be very brief in my closing comments.
I think we have indicated that we believe the
fundamental problem that has plagued Northeast and
particularly Millstone for quite a number of years has been
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leadership. We have fundamentally changed out the
leadership at high levels and we are still working down in
the organization.
This team is committed. This team is
enthusiastic. This team clearly understands the standards
that need to be set. There is no doubt in my mind we can do
what needs to be done. The issue is execution and how long
it is going to take.
We are working hard. We know that the key issue
here is demonstration of performance, and that's what we
intend to do. We also know that a key issue is
communication, communication with the public, communication
with you, the regulator.
You asked me an earlier question regarding do we
know what needs to be done. We do think we know what needs
to be done. We have not at this point fully communicated
that to the NRC. There are requests for what are your
action lists and that kind of thing. We will be responding
to those.
We do seek a couple of things that are maybe
obvious. One is an acceptance of this leadership team on
its merits. We know that there is a lot of regulatory
history that represents how NU has behaved historically. NU
has been rather defensive, rather contentious, rather
legalistic, and that behavior produced understandable and
. 72
corresponding reactions by the NRC, and thus I think the
regulatory relationships when I arrived were not good.
That's the company's fault.
I want you to know that that is clearly not what
this leadership wants. We intend to be fully open, fully
candid, not defensive. We will share the information. We
know that there are regulatory challenges that need to be
met, and we intend to fully work with you. So certainly we
want to be judged on the basis of what we do and the
performance we achieve and not be judged on a history that
at least this team did not create.
Second, we are hopeful and believe it's important
that there be a sufficient commitment of resources to
support the inspection and regulatory resources to support
the recovery of these units.
Certainly, based on the actions you took yesterday
in putting quite a number of plants on the watch list, we
know we're not the only ones with problems, and I'm not
suggesting that misery loves company. We have been down for
a while. We need for a lot of reasons to get these units
back and we know that is going to take a commitment of
resources from the Commission. We want to work with you to
be as supportive on that as we can.
We believe that this may constitute the largest
management turnaround in the history of the nuclear
. 73
industry. Maybe that's an arguable point, but that's what
we've got to do and that's what we are committed to do.
This concludes our remarks.
CHAIRMAN JACKSON: Thank you, Mr. Kenyon.
Let me make a couple of comments to you.
Obviously everyone is aware of how long the units have been
down, what it costs for every month they're down. It can't
be more important to anyone than the company itself, its
shareholders, those who work at the company, as well as
those in the community that have a stake. You're the ones
who are going to have to rebuild the trust of that
community. We have our own job with respect to regulatory
confidence, but in the end you're the ones who own and
operate those plants. So the stakes are highest for you.
I don't think there is any question but that the
Commission will accept the team on its merits, but what that
means is that the focus is on what you do, not what you have
been.
We all like to feel that if we come at something
with good reputations that we want people to believe that we
are going to do what we say we are going to do, but in many
ways how we got ourselves to here is taking promissory
notes. One should take what you say at face value, but in
the end, as we work our way along, what we are looking for
is measurable progress in each of the areas, particularly
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the ones that had gotten to points where we felt we had to
issue orders with respect to.
I think if we all understand that and you're
working with the staff and you're working with those in the
State of Connecticut who are involved in good faith and
openness and with measurable progress, then we don't have a
problem. If it doesn't go that way, then you all have
stellar reputations, but in the end when we come to make our
decision it's going to be on the basis of what we see and
what we see has been done.
Unless there are any further comments from the
Commission, I think we will hear from the NRC staff, who
will be given equal opportunity.
MR. KENYON: Thank you, Chairman Jackson. I
couldn't agree more with your closing comments.
CHAIRMAN JACKSON: Mr. Thompson, you can begin.
Would you begin, though, by introducing the members at the
table with you, please.
MR. THOMPSON: I would be delighted to, Chairman
Jackson.
To my left is Wayne Lanning, who is the Deputy
Director for Inspections for the Special Projects Office.
To my immediate right is Phil McKee, who is the
Deputy Director for Licensing, the Special Projects Office.
He will be giving the briefing this morning. Unfortunately,
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Dr. Travers had a death in the family and is not able to be
with us this morning.
To Mr. McKee's right is Frank Miraglia, who is the
Acting Director of the Office of Nuclear Reactor
Regulations.
To his right is Mr. Gene Imbro, who is the Deputy
Director of Independent Corrective Action Programs.
They will be prepared to respond to any questions
that we may have today. Phil McKee will actually lead us
through the staff's briefing.
As you know, in November of 1996 this new
organization, the Special Projects Office, was established
within the Office of NRR with responsibilities to include
all licensing and inspection activities required to support
an NRC decision on the readiness to restart each of the
three Millstone units. I was pleased by Bruce Kenyon's
recognition that their approach to move in parallel will add
a significant and a real workload challenge to the NRC
staff.
I think with that I will just turn it over to
Phil.
MR. McKEE: Thank you.
[Slide.]
MR. McKEE: As mentioned by Hugh Thompson, the
primary reason the Special Projects Office was created is to
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provide a specific management focus on future NRC activities
associated with the Millstone units.
The new organization serves a primary function of
integrated Headquarters and Region I resources for
inspection, licensing and oversight.
As Hugh mentioned, Bill Travers is unfortunately
not able to be here with us today. He's the Director of
Special Projects Office.
Reporting to him are the three deputies here at
the table. We are responsible for the key oversight
activities.
CHAIRMAN JACKSON: So the director assumes the
role of both the regional administrator and the associate
director of the projects?
MR. McKEE: That's correct, the region, and the
projects are integrated and focused to the Special Projects
Office director.
The regional arm of the Special Projects Office
includes a branch chief, resident inspectors, and the region
project engineer.
In January of 1996 each Millstone unit was
allocated a senior resident and resident inspector position.
Since then two new resident inspectors have been assigned
for Units 1 and 3 and we are in the process of selecting the
senior resident for Unit 2.
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I might mention that two of the residents are here
today, and also the branch chief, Jack Durer, and also the
resident for Millstone Unit 3, who is Tony Cerni, and the
resident for Millstone Unit 1, who is Ted Eastly.
CHAIRMAN JACKSON: Are you telling us that each of
the senior residents are new?
MR. McKEE: That's correct, since January. By the
time we select the third senior resident, which should be
shortly, they will all be new senior residents.
Special Projects Office is utilizing a minimum
number of full-time staff. However, the staff will be
supplemented, depending on ongoing activities by regional
inspectors, headquarter technical staff, and contractors.
[Slide.]
CHAIRMAN JACKSON: Let me ask you a question. Go
back to your first slide.
[Slide.]
CHAIRMAN JACKSON: You have there that you will be
using contractor resources. They are going to be used in
what areas?
MR. McKEE: We are kind of bloating, depending on
license activity resources, but contractor resources are
going to be needed for a number of functions.
We are looking at contractor support for our staff
and for the independent corrective action verification
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program activities that the NRC will do on our oversight of
that program.
Also contractor support is needed for inspection
areas and maybe follow-up on some of the allegations that
the NRC receives.
Further, we are looking at some contractor support
even in the employee concerns program area to support some
follow-up activities and monitoring activities we have
planned there.
CHAIRMAN JACKSON: And they are going to be
independent of any organization or contractors that the
licensee uses in those same functions?
MR. McKEE: Definitely. We will be independent of
those organizations.
Back to the second slide, please.
[Slide.]
MR. McKEE: Although my presentation will focus on
staff activities to establish NRC's programs for assessing
the licensee's corrective actions and restart readiness, I
want to first emphasize that our primary responsibility at
Millstone continues to be the day to day assessment of the
licensee's safety performance. Most important, given the
status of the facilities, is our continuing assessment of
the licensee's safe shutdown operations.
As you heard from the licensee's presentation,
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there have been a significant number of recent management
changes at the Millstone station. Staff has not had
sufficient time to assess the effects of all the changes
being implemented by this new organization.
Further, the licensee is still in a period of
discovery related to many issues, and in particular those
related to design and licensing basis.
Although it is premature to comment in any depth
on the recent performance, I would like to mention that our
inspection activities have identified improvements in
control of site work. Most significantly, schedules,
although some may be ambitious in our estimation, and
prioritization for major work activities have been developed
for all three units.
However, one area which continues to be an issue
and which has been identified in recent NRC inspection
reports is the licensee's follow-up in correcting identified
issues. Since corrective action processes is a very
important and critical issue, we plan to closely follow
licensee progress in this area.
[Slide.]
MR. McKEE: The staff is structuring our oversight
program in accordance with Inspection Manual Chapter 0350.
That manual chapter provides a process, including check
lists covering most every contingency, for assessing restart
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readiness of plants which are shut down for complex events,
significant hardware issues, or significant management
weaknesses.
The elements that I have listed on the slide
include some major activities and they are customized for
the Millstone review. I will just discuss a few here
briefly.
Consistent with the manual chapter's guidance, we
have established a restart panel and restart assessment plan
focused on Unit 3.
The restart evaluation process specifically
includes Commission involvement. At Millstone that
involvement is substantial and encompasses periodic status
reports, including a quarterly briefing of the Commission
and restart authorization.
Regarding ACRS review, plants shut down for longer
than one year are typically considered for review by ACRS.
However, ACRS at their option can be involved to the extent
that they think is appropriate.
Public participation is a very important aspect.
In most all of our oversight processes, including employee
concerns area and the ICAVP -- I'll keep using ICAVP.
That's one acronym I'll use, because it shortens it quite a
bit -- multiple means are available for public
participation.
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CHAIRMAN JACKSON: Do you have a long-range time
line formulated as yet that in some sense schedules, at
least in a relative sense, each of the milestones associated
with each of these pieces and that has some logical
methodology for picking locations for public meetings?
MR. McKEE: The processes for ICAVP and employee
concerns identifies specific times. In those processes
public participation is specified. Our goal is every six
weeks or so to have a public meeting if it's not held for
some other reason.
As we mention here and the licensee mentioned,
schedules are fairly open and haven't been well established
yet. So we really try to use those periodic meetings that
we have to pick up the issues of the time. In February we
are having a meeting with the public to discuss the ICAVP
and employee concerns. We are also including another issue
that we are discussing there.
I think our interaction with the public is quite
substantial and fairly well laid out.
MR. IMBRO: Further, on the ICAVP we are also
planning to solicit public comments on the audit plan or get
public input on the audit plan when it's submitted by the
licensee. We will take those public comments into
evaluation in our approval process.
CHAIRMAN JACKSON: Are you doing that through
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public meetings?
MR. IMBRO: Meetings with the public, Dr. Jackson.
We usually meet with the public in the evening and solicit
their input.
Also, we have committed to have periodic status
meetings on the conduct of the ICAVP or progress of the
ICAVP with the public. We want to keep them apprised of the
status.
MR. McKEE: Getting back to the assessment plan,
the plan also provides for coordination with other agencies
as appropriate, and organizations. This may include FEMA,
Department of Justice, and the state as necessary.
Most importantly, the process results in a
documented basis for NRC's restart readiness evaluation.
This basis is to be used by the NRC senior management and
the Commission in making decisions regarding the restart of
any of the Millstone units.
[Slide.]
MR. McKEE: The core of our planning is documented
in the restart assessment plan. In particular, the plan
identifies areas where regulatory emphasis is needed. The
plan is a living document and will be revised periodically
as we go along.
The first two items listed, the ICAVP and employee
concerns, are major elements of the plan, and I will discuss
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these later in a little more detail.
However, it needs to be emphasized that the
employee concerns and ICAVP elements, as important as they
may be, are only elements of a much larger plan. Many of
the other elements, such as corrective action -- and I think
that was discussed by the licensee here -- work planning and
controls and quality assurance and oversight, are equally
important.
The plan also includes a significant issues list
that specifies individual items. These items are typically
identified in inspection reports which the restart
assessment panel has determined require documented
verification prior to restart of any of the units.
Like the plan, we expect this list to evolve as
the discovery process continues.
CHAIRMAN JACKSON: Is that going to be made
publicly available?
MR. McKEE: The significant issues list, the ones
we have identified at least for Unit 3, is publicly
available in our restart. It's an attachment to our restart
assessment plan.
CHAIRMAN JACKSON: That will be true for all of
the --
MR. McKEE: Right, and it will be true for the
other two units.
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CHAIRMAN JACKSON: Let me make sure I understand.
Are all of the significant issues restart issues?
MR. McKEE: All of the significant issues require
certain resolution, our inspection, the NRC follow-up prior
to restart. So they do involve restart issues, yes. Some
are like corrective action plans. You won't be able to
resolve necessarily every aspect that might be included.
MR. MIRAGLIA: It will at least articulate the
scope of the issue for restart and would could remain for
later.
CHAIRMAN JACKSON: I guess all I'm really asking
is relative to a point of clarity. Since I have confusion,
and I think about the public, I think it's very important
that we're clear if we have what we call a significant
issues list what the overlap of that list is relative to
what are the issues that have to be addressed before restart
so that there is no confusion.
MR. LANNING: Let's clarify it to make sure we all
have the same common understanding. The significant issues
list are those issues that the staff has identified as the
minimum required that the licensee must address and complete
to our satisfaction prior to restart.
There is an additional list that the licensee has
which is much larger than that, which is also a source of
confusion. We only have completed this activity for Unit 3
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to date, because that's the only list that we have received
from the licensee concerning restart.
CHAIRMAN JACKSON: Let me make sure I understand.
The licensee has its restart list.
MR. LANNING: That's correct.
CHAIRMAN JACKSON: Is our significant issues list
a subset of that, or it could be but it goes beyond it?
MR. LANNING: Our list is a subset of the
licensee's list.
CHAIRMAN JACKSON: I'm sorry to belabor the point,
but every issue that is on our significant issues list by
definition is on the licensee's restart list?
MR. LANNING: That's correct.
CHAIRMAN JACKSON: Commissioner McGaffigan.
COMMISSIONER McGAFFIGAN: In the inspection
report, how quickly does the licensee get to start working
on coming up with a way to resolve the issues? Do they have
to wait for us to write the report, or is it orally
communicated at the time? How does that work just in
general?
MR. MIRAGLIA: Wayne.
MR. LANNING: The significant issues list is
articulated in the restart assessment plan. That has been
published; it's available to the licensee to start work on
immediately.
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COMMISSIONER McGAFFIGAN: You also said earlier
it's an evolving document; you are going to come up with
additional issues, and as they said, they are going to come
up in discovery. I think that was the word used. How are
additions made?
I'm just trying to understand the process so
that's it's a prompt process, that it doesn't wait for an
every three month Commission meeting or something in order
that they know what they have to fix.
MR. MIRAGLIA: The issues are identified. In the
course of inspections there are usually exits. So the
information in terms of the issue is identified to the
licensee at the conclusion of the inspection.
The licensee will make its evaluation as to is
this a restart item or not, share that with the staff, and
we either agree or say it needs to go even further.
That's the process that is done by the 0350
restart panel. There are periodic meetings of those. They
are done in public meetings. Those lists are shared with
the utility on a fairly frequent basis.
I don't know what your current meeting schedule is
right now.
MR. LANNING: We're averaging about one a month.
As they have made progress we can have more frequent
meetings.
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COMMISSIONER McGAFFIGAN: And it's up to the
licensee to propose how to resolve the issue once it's
identified? Then it's up to the panel to decide whether
that resolution is acceptable?
MR. LANNING: Absolutely. They have to list each
of the issues and provide us a package certifying
essentially that they have completed the actions that they
think are necessary for the NRC to close that issue. They
provide that to us so that we can inspect it.
CHAIRMAN JACKSON: Okay.
MR. McKEE: If we can go back to slide four.
[Slide.]
MR. McKEE: One item listed is the operational
safety team inspection. It's an intensive independent
evaluation to be performed just prior to the restart of each
of the Millstone units. The inspection focuses on
licensee's capability to safely operate the facility. It
involves eight or more inspectors who will be on site two or
three weeks to perform the inspection.
I need to point out that prior to December 1996
the licensee had been focusing on Unit 3 as the lead plant
for restart. For that reason, the NRC restart action plan
is directed at Unit 3 activities. Now it appears, I think
as was discussed and you heard today, that the licensee is
focusing restart activities for all three units on a
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parallel path. This revised approach could have
considerable resource impacts on the NRC, particularly in
considering the scope and depth of NRC activities associated
with the restart assessment for each of the facilities.
Also, there are many actions and milestones
required by the licensee to be completed prior to NRC
conducting its review and assessments. I know the licensee
spoke to this issue a little bit in their presentation,
including the many assumptions that they have made in doing
their things. I think they reflected that they are not
certain on some what NRC may require in certain areas. So
there is a little interchange that needs to go on here.
Given the licensee's ambitious schedules and
parallel effort for the units, the staff questions the
licensee's capability to meet all the necessary milestones
for providing staff with necessary submittal packages and
the information to support NRC activities.
It is very important that the licensee prepare
supportable and integrated schedules with clear intermediate
milestones for the three units. I heard some of that today,
but that needs to be very carefully done so that we can
proceed with our work also.
This is essential for the staff to plan and muster
necessary resources to evaluate licensee programs.
As an aside, I want to mention last October the
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staff did request some information, more details on the
operational readiness plan and schedules of important
milestones for Unit 3. Although we received some
information, we really haven't yet even received docketed
information on that request. So we are still waiting for
certain information for us to proceed.
CHAIRMAN JACKSON: Let me take you back for a
quick minute. You mentioned that the Manual Chapter 0350
process explicitly provides for your interface with other
appropriate agencies and organizations, and you mentioned
FEMA, DOJ, and state agencies. The question I have relative
to the state is, have you in fact articulated what your
interface is going to be with either state agencies or state
organizations or state groups? Have you in fact articulated
that?
MR. IMBRO: I can answer that, Dr. Jackson. For
the ICAVP we have solicited observation of the process by
the NEAC, Nuclear Energy Advisory Council, I believe it is,
and that organization is constituted by the Connecticut
state legislature. We have memorandums of understanding
from four of the individuals, the two chair people plus two
alternates, and they will be involved in keeping abreast of
the ICAVP and our status so they will understand the process
and know what is going on. So to that extent the state has
been involved with the ICAVP.
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MR. MIRAGLIA: In terms of the public meetings, I
believe there has been conversation with Dr. Travers and the
state that they would like to be kept informed of briefings.
If they need more than they would get at public meetings,
we've even arranged for opportunities to be briefed in that
regard as well.
MR. LANNING: That's right. We have committed to
brief the state representatives monthly on the status.
MR. MIRAGLIA: So there has been contact at a
number of levels.
MR. McKEE: If I could have the fifth slide.
[Slide.]
MR. McKEE: The independent corrective action
verification program has been required for each Millstone
unit by order issued in September of 1996.
The ICAVP is intended to provide independent
confirmation that the licensee has identified and addressed
design and licensing basis deficiencies.
The ICAVP will also confirm that the licensee has
processes in place that will ensure continued conformance
with their license basis.
The order requires the licensee to contract for an
independent organization to carry out the ICAVP.
The order specifies that NRC review and approval
is required for several of the elements.
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NRC staff will review and approve the independence
and technical qualifications of the proposed ICAVP
organization.
Individual member's independence and their
technical qualifications.
And the audit plan which must be submitted by the
ICAVP organization.
As part of our review of the ICAVP audit plan, the
staff will determine the scope and depth of the ICAVP audit,
including which systems are to be evaluated.
CHAIRMAN JACKSON: What criteria are you using to
ensure an adequate sampling of systems?
MR. MIRAGLIA: As described in the Commission
paper that was referenced early in your remarks, Chairman
Jackson, which will be made public today, the licensee has
the primary responsibility to look at all systems within the
context of the 0350 process and conduct the problem
identification phase, resolve issues, and then institute
corrective actions. The ICAVP will also then select a
number of systems.
In early meetings with the utility in August
preceding the order relative to this, we talked in terms of
looking at risk-significant systems, those that would be
covered by the maintenance rule, and at a point in the
process where the utility has completed its problem
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identification and instituted corrective actions propose a
number of systems that are ready for ICAVP review. Then,
within the context of the process the ICAVP will decide a
number of systems to be looked at, and then that plan will
be submitted for the staff to review and audit.
CHAIRMAN JACKSON: So the number of systems and
the basis on which they are to be chosen will come to the
NRC for approval?
MR. MIRAGLIA: Yes.
MR. IMBRO: We will specify the number of systems.
I think the next slide really addresses the scope of the
ICAVP in terms of the multi-tiered effect not only to review
four systems as was stated in the Commission paper, but also
the fact that we need to look at the accident analyses to
make sure the other systems that get engaged to mitigate
accidents function the way they are supposed to, and then
also to look at the change processes that have resulted in
plant configuration getting to where it is since OL to make
sure that those have not introduced any modifications.
CHAIRMAN JACKSON: Have you begun your discussion
of the ICAVP? You're up next, right?
MR. IMBRO: No. Mr. McKee was going to handle the
whole presentation. I was trying to respond to your
question.
[Slide.]
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MR. McKEE: On the next slide we are going to talk
about conduct of the ICAVP.
As I mentioned before, the staff is required to
approve it. We have given a lot of consideration to those
elements of what we think should be considered in the ICAVP.
In general, staff has determined that the ICAVP
should include a three-tier review.
Tier 1. This is the plan for Unit 1 as we have
identified in the paper, but likely will apply a similar
process to the other units. The contractor would perform an
extensive vertical slice evaluation of design and operation
aspects of a sample of safety-related and risk-significant
systems. I think the original thought was four, as Gene
mentioned.
In tier 2 other safety-related or risk-significant
systems would be evaluated and the focus would be on
critical active functional attributes necessary to mitigate
postulated accidents analyzed in the FSAR.
In tier 3 design change processes such as those
involving procedural changes, calculation changes, drawing
changes, tech spec changes would be sampled.
CHAIRMAN JACKSON: So when we are looking at tier
1, tier 2 and tier 3, how many systems, at least at this
stage of the game, are you talking about looking at?
MR. IMBRO: It's a little bit hard to answer. For
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tier 1 it clearly is four systems. The four-system review
is a vertical review looking at all design aspects and
making sure that the systems conform to the licensing basis
but also that the design requirements flow through to the
operating, maintenance, surveillance procedures, testing, et
cetera. So there is a complete top to bottom review of four
systems.
Tier 2 I wouldn't necessarily look at on a system
basis but more on an analyzed accident basis. In other
words, we are going to start with the Chapter 15 accidents
and the FSAR and go through each accident and look at what
has been taken credit for in terms of performance of all the
systems and make sure that those functions can be performed
by the systems by going back to look at the design bases for
those particular attributes.
So the tier 2 is not necessarily a system review
but an accident analysis review focusing on the critical
attributes of the systems that need to come into play to
mitigate the consequences of the accident.
And tier 3 is not a system review at all but is a
broad review of processes.
MR. MIRAGLIA: And it's the results of all of
these and the outcomes of these that will say is that
enough. You have to put those together and make the
judgments that those three processes have provided the
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information to say and to make the inference that the ICAVP
is going to have to say that the licensee has done enough
and independently verified corrective action.
MR. McKEE: Finally, on that slide, the ICAVP
would not begin until the licensee has completed the problem
identification phase of the configuration management program
for at least one half of the risk-significant systems.
If I could have slide seven, please.
[Slide.]
MR. McKEE: This provides a little more
information on the tier 1 evaluation. We may have covered
some of this already.
The tier 1 scope as identified by the staff for
Unit 3 includes a multi-discipline vertical slice review for
several systems comparable to an integrated design
inspection. Licensee review includes approximately 80
safety-related or risk-significant systems.
Tier 1 will encompass the adequacy of original
design for the unmodified portions of the selected systems
as well as all the modifications since issuance of the
operating license.
CHAIRMAN JACKSON: Let me ask you a question. I
just want to make sure I'm clear. Did you say the licensee
has identified 80 systems?
MR. McKEE: I think 80 represents the full scope
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of all the systems that the licensee is looking at, not ones
that necessarily will come under the ICAVP.
CHAIRMAN JACKSON: I understood that. I'm asking
you a question. You said 80 systems, right, and you said 80
risk-significant systems?
MR. MIRAGLIA: It's the 80 systems that would fall
under the criteria as they are implementing the maintenance
rule.
CHAIRMAN JACKSON: The ICAVP at this point will
look at four in this tier 1 process?
MR. IMBRO: That's correct.
MR. MIRAGLIA: And the 80 is applicable just to
Unit 3.
CHAIRMAN JACKSON: Is the 80 for one unit or for
all three?
MR. IMBRO: The 80 is for Unit 3.
CHAIRMAN JACKSON: So the four is for Unit 3?
MR. IMBRO: Exactly, yes.
COMMISSIONER ROGERS: What is the thinking here of
your focus on the original design for unmodified systems?
What are you looking for there?
MR. IMBRO: What we are looking for, Commissioner
Rogers, is, starting with the reality of the system as
installed in the plant, making sure that that is in
conformance with its licensing basis. For the unmodified
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portions of the system the supporting documentation is the
original design. For the parts of the system that have been
modified, it's the supporting documentation of the
modification packages. We want to look at the total design
package that supports the system as it exists today to make
sure that's in compliance with its licensing and design
basis.
COMMISSIONER ROGERS: The problem I have here is
just understanding what sort of things you think you might
turn up there. It looks to me as if what you may find or
the purpose of this would be to see whether the original
design complied with the original FSAR. Is that right?
MR. IMBRO: That's right.
COMMISSIONER ROGERS: This would go back to your
one then.
MR. IMBRO: Exactly.
MR. MIRAGLIA: The second thing is that given the
modifications --
COMMISSIONER ROGERS: I understand the
modifications. It's the unmodified portions.
MR. IMBRO: There have been examples where
original design problems have been uncovered. Therefore we
felt like we needed to go back and look at the adequacy of
the original design. That is something that is a little bit
unusual in terms of how we review things, but we felt for
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Millstone this was necessary.
COMMISSIONER ROGERS: But then this is sort of a
sampling process in a certain sense of the original design
conformance with the FSAR for the four systems. That's how
you are taking the sample in a sense. It really doesn't
relate to the modifications; it relates to the original
design and FSAR conformance.
CHAIRMAN JACKSON: Let me make sure I understand,
because now I'm confused. My perspective was that there
were these four systems that you were picking based on some
set of criteria, risk significance included.
MR. IMBRO: That's right.
CHAIRMAN JACKSON: Having picked those, some
portions of the systems may have been unmodified since the
beginning and some portions may have been modified.
MR. IMBRO: That's correct.
CHAIRMAN JACKSON: In taking this vertical slice
you are doing both things. You are not picking the four
systems based on never having been modified or having been
modified. You're picking them on some other criteria, and
in taking this slice you have to do both of these.
MR. IMBRO: That's right. One of our criteria
would be also to look at the number of modifications and the
complexity of modifications that are made to a particular
system.
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CHAIRMAN JACKSON: To make sure that we are
touching base with what his question is and mine, within a
given complicated system there are aspects of both.
MR. IMBRO: Exactly.
MR. MIRAGLIA: You're picking a system and you're
saying did it meet the original design as modified. The
answer is yes.
CHAIRMAN JACKSON: Commissioner McGaffigan.
COMMISSIONER McGAFFIGAN: This is just a language
question and perhaps everybody who went through the
maintenance rule knows. When you use safety-related or
risk-significant, are they the same, or is risk-significant
systems that are not safety-related?
MR. MIRAGLIA: Within the context of the
maintenance rule, it is risk-significant and it would
include safety.
COMMISSIONER McGAFFIGAN: So risk-significant
includes safety systems?
MR. MIRAGLIA: In terms of the maintenance rule,
it would be the broader context.
MR. IMBRO: Some of the safety-related systems are
not really risk-significant. It gets complicated.
CHAIRMAN JACKSON: We don't want to go off the
map, but there are at least four operative phrases that come
up that I think actually need clarification at some point.
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They are safety-related; we say safety-significant; we say
important to safety; and we say risk-significant. And they
don't all mean the same thing. Am I correct?
MR. IMBRO: That's correct.
MR. MIRAGLIA: That's right.
CHAIRMAN JACKSON: For the purposes of
Commissioner McGaffigan's question, what are you saying?
[Laughter.]
COMMISSIONER McGAFFIGAN: They've been very good
about using the terms safety-related or risk-significant all
through the briefing. So I've been very impressed.
MR. IMBRO: From my knowledge of Unit 3, the
licensee has approximately 220 or 230 systems total in the
plant. They have divided those into four categories. I
will focus on the first two because I'm not sure I know the
definitions for the other two. The first two comprises the
80 systems that we just discussed or made reference to.
The group one systems are risk-significant and
safety-related, and I think the total number is something
like 39, more or less.
The group two systems are safety-related or
risk-significant. In that category there are approximately
42 systems, I believe. Some of those are safety-related but
not risk-significant, and others, one or two systems, are
risk-significant but not safety-related. I think the two
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non-safety-related systems that are risk-significant have to
do with availability of offsite power kind of things that
are not typically safety-related.
CHAIRMAN JACKSON: Maybe you could just give a
quick definition of safety-related.
MR. IMBRO: Safety-related would be those systems
that -- I guess as a first cut, those systems that are
necessary to mitigate the consequences of an accident or to
prevent accidents such as the primary pressure boundary.
CHAIRMAN JACKSON: Just for the record.
COMMISSIONER McGAFFIGAN: Sorry.
CHAIRMAN JACKSON: No. That was a good question.
MR. McKEE: To finish on this slide, I was going
to mention something about our selection process, but I
think we've already covered that. It's based on a number of
factors. So let's move to the next slide, please.
[Slide.]
MR. McKEE: As far as NRC oversight of the ICAVP,
staff will provide oversight of that process by reviewing on
a sampling basis the ICAVP processes and findings and
conducting separate design-related inspections of a couple
systems.
CHAIRMAN JACKSON: Those systems are different
than the four the ICAVP will cover?
MR. IMBRO: No, not totally. One will be within
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the scope of the ICAVP. So one of the systems that was used
to do a vertical slice on ourselves will be within the scope
of the ICAVP and would be one of the four systems. The
other would be not be within the scope of the ICAVP but one
of the remaining of the 80 systems that is done by the
licensee but not necessarily addressed by the ICAVP.
CHAIRMAN JACKSON: And that's one of the things
that we are going to end up using contractors for?
MR. IMBRO: Exactly, yes.
MR. McKEE: Staff intends to keep the state and
public well informed on ongoing activities, including
invitation to the state representative to observe NRC
inspections. We are going to have multiple meetings with
the licensee which will be open to the public. And we're
going to have specific meetings with the public on this
topic.
[Slide.]
MR. McKEE: Just to give you a quick status of
where we are on ICAVP.
In brief, the current status of the program is the
staff is reviewing the proposals by the licensee to use
Sargent & Lundy at Units 1 and 3. We have requested some
additional information from the licensee and we plan
separate meetings with the licensee and the public in the
near future. February 5, I think, is when we planned those.
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The meeting with the licensee, which will be open
to the public, will be to discuss their proposal and
selection process.
In our meeting with the public we plan to solicit
the public's comments on the contractor selection.
CHAIRMAN JACKSON: Will the comments that you get
from the meeting be addressed prior to or as part of the
decision-making process?
MR. IMBRO: It will be part of the decision-making
process.
COMMISSIONER McGAFFIGAN: Could I ask one
question?
CHAIRMAN JACKSON: Sure.
COMMISSIONER McGAFFIGAN: Perhaps Mr. Kenyon can
answer. His chart read the same way, that there was a
contractor for Unit 1 and 3, but in his oral presentation he
said that they had chosen an ICAVP contractor for 3 and they
were soon going to do 1 and 2. I guess I should have asked
it at the time. I'm just wondering whether you have chosen
the Unit 1 ICAVP contractor and submitted it yet or whether
your oral remarks were right and you are still working on
that.
MR. KENYON: We have chosen but not submitted.
COMMISSIONER McGAFFIGAN: Chosen but not submitted
the number 1?
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MR. KENYON: That's right.
CHAIRMAN JACKSON: Where does the thing stand for
Unit 2?
MR. KENYON: The same. We have internally chosen
both and we will shortly be submitting them.
CHAIRMAN JACKSON: So the only one that has been
submitted is Unit 3 at this stage?
MR. KENYON: That's correct.
I'm sorry. I'm out of date. Unit 1 has been
submitted also.
MR. IMBRO: There is a difference in date.
Submittal on the Unit 1 was the 15th of January.
MR. McKEE: That completes the ICAVP. I want to
shift over to employee concerns. If I could have slide 10,
please.
[Slide.]
MR. McKEE: As a result of past failures in the
licensee's programs for the handling of safety issues raised
by its employees and NRC concerns about the treatment of
employees who brought safety concerns to management's
attention, NRC issued an order in October of 1996 requiring
the licensee to take a number of actions. The licensee did
discuss some of these and I'll kind of cover those briefly
again.
The principal actions specified by the order
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include licensee submittal for NRC review their own
comprehensive plan for reviewing and disposition of safety
issues raised by their employees.
The order also requires the licensee to propose an
independent organization to oversee the comprehensive plan.
Once the NRC approves an independent organization,
that organization will develop and provide for NRC approval
an oversight plan. All these actions are required prior to
the restart of any of the Millstone units.
Once in place, the independent organization would
provide reports at least quarterly to the NRC. These
reports would be made available to the public. We are still
considering how we might discuss that, and that would be
presented quarterly, including participation by the public.
CHAIRMAN JACKSON: So at this point you don't
necessarily require any progress relative to the plan before
restart. You just said that the plan has to be approved
prior to restart.
MR. McKEE: That's correct. The oversight plan
has to be approved. That's the independent group. That
plan has to be approved prior to restart. As far as
implementation of their comprehensive plan the oversight
group will be doing, that's one purpose of that function,
and then of course the NRC would be doing, also similar to
the ICAVP, some other higher tier level oversight and
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assessment of employee concerns.
CHAIRMAN JACKSON: I'm just trying to clarify
those. Whereas with ICAVP there are certain things that
specifically have to have been done before restart, you are
not putting in any requirement that there are specific
things that have to have been done in the employee concerns
areas.
MR. McKEE: You're correct. The order does not
specify. The order specifies that they have to have the
oversight plan in and we approve it prior to restart.
CHAIRMAN JACKSON: But you have to bring it to us
and convince us.
MR. McKEE: That's correct, yes.
MR. LANNING: But as a practical matter, the
licensee will have to demonstrate that they've made progress
in dealing with employee concerns prior to restart. That is
a startup issue.
CHAIRMAN JACKSON: That's something you should
keep in mind in coming to the Commission.
MR. McKEE: My last point was that the NRC plans
to assess the effectiveness of this plan and bring that to
the Commission and discuss that with the Commission prior to
restart.
Next slide, please.
[Slide.]
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MR. McKEE: The status of the employee concerns
order activities is similar to the status for the ICAVP. Of
course we don't have three separate programs. The employee
concerns is a station program rather than an individual unit
program.
The licensee has submitted a proposed
organization, Little Harbor Consultants, and we are
reviewing the qualifications and independence aspects of the
organization and individuals.
Similar to the ICAVP contractor selection process,
we have requested some additional information from the
licensee. A letter just went out today on that.
CHAIRMAN JACKSON: Are there any particular issues
that are you requesting information about?
MR. McKEE: We're requesting some further
information on Little Harbor Consultants, some further
information on some of the individuals, assurance of their
independence from Millstone, and financial independence from
Northeast Utilities.
We are also curious about some of the construction
of that organization, how the people will be placed at site,
what will be their availability and kind of their dedication
of time, since it looks like a specially formed organization
for this purpose.
Again, we are having a meeting with the licensee
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concurrent with the ICAVP meeting on February 5, and that
meeting will be open to the public for them to discuss the
issues that we have asked them and the additional questions.
Also that evening we are having a meeting with the public to
receive their comments or any input on the proposed
organization.
CHAIRMAN JACKSON: Let me make sure I understand.
This meeting to receive comments on the proposals relative
to the ICAVP, is that a meeting that the NRC is holding on
February 5?
MR. McKEE: On February 5 we actually have two
meetings. We have one meeting that the NRC is holding, and
it's a meeting with the licensee. That meeting will be in
the afternoon of the 5th.
CHAIRMAN JACKSON: Is that going to be open to the
public?
MR. McKEE: That will be open to the public. That
meeting will include discussions of both the ICAVP and the
employee concerns.
CHAIRMAN JACKSON: Then separately the NRC is
having a public meeting on February 5th in the evening?
MR. McKEE: Correct. In the evening we are having
a meeting with the public off the site. I guess in the
Waterford Town Hall. A meeting with the public to discuss
both those programs.
. 109
CHAIRMAN JACKSON: When do you foresee a decision
being made relative to the ICAVP and our acceptance?
MR. McKEE: If I could have the next slide.
[Slide.]
MR. McKEE: But that won't provide a definitive
answer. Actually the next slide we tried to identify some
milestones that we expect or anticipate will be accomplished
prior to our next briefing to the Commission.
We anticipate after this meeting, if we get
additional information that progress will be made and
subject to meeting the criteria that we are looking for,
approval of the ICAVP organizations as well as the employee
concerns organization.
If that's true in the next three months the order,
at least in employee concerns, which I know a little bit
better, after approval of the organization, they have 30
days to submit their oversight plan. If that works out and
we select within the next several weeks the employee concern
contractor, we should be at a point even three months from
now for looking at an approval well in the process of that
oversight plan.
I think the same is true also for the submittal of
the ICAVP plan.
MR. IMBRO: For the ICAVP, we hope that within
several weeks after we have our meeting on the 5th and we
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evaluate the information as presented and consider the
public comments that we receive from the evening meeting,
then we would be in a position to provide feedback back to
the licensee.
MR. LANNING: And to help the public provide
meaningful feedback, we have provided copies of the
correspondence between Northeast Utilities and NRC in the
local public document room, which is the Waterford library,
such that the public can get copies of that documentation
and prepare themselves for the evening meeting.
CHAIRMAN JACKSON: Okay.
MR. McKEE: We've really covered most of the items
that we have on there that I will call the near term, the
next three months.
The last item. Of course we plan to keep the
Commission informed, and we will work our agenda and see
what we need to talk about at the next meeting.
That concludes my remarks.
CHAIRMAN JACKSON: Thank you.
MR. THOMPSON: That concludes the staff's
presentation. We would be prepared to answer any questions.
CHAIRMAN JACKSON: Commissioner Rogers.
COMMISSIONER ROGERS: I have no additional
questions. I thought it was very excellent.
CHAIRMAN JACKSON: Commissioner Dicus.
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COMMISSIONER DICUS: No, thank you.
CHAIRMAN JACKSON: Commissioner Diaz.
COMMISSIONER DIAZ: I do have a couple of little
questions. Again, you're going to have to excuse me,
because they were very simple, but when the discussion on
safety-significant and risk came in they got a little more
complicated. So I had to write something down quickly just
to make sure that my question comes out clearly.
You go through this entire document. I am certain
that in every one of the staff actions safety is behind it.
Paraphrasing Chairman Jackson when she finished her remarks,
we do not manage utilities; we regulate utilities regarding
their safety significance. I think that is an important
issue.
And we know we have this major massive effort on
the design basis reconstitution, which I guess constitutes a
significant portion of the efforts.
However, in going through all of these documents,
and I'm sure I missed not only this but all the others, I
wonder if I could ask the staff.
In all of these vertical, horizontal and diagonal
slices we have taken have you identified an individual,
independent, very safety-significant, risk-significant issue
at Millstone which would have had or could have impaired the
capability of the systems to perform its intended safety
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function?
MR. MIRAGLIA: I think what led up to and prior to
the 50.54(f) letters on each of the units there were special
inspections. In fact, there was a self-assessment by the
licensee relative to concerns that led to technical
specification shutdowns because they could not meet the
licensing basis. I believe Unit 1 was the first unit to be
shut down.
As a result of those concerns, we had a special
inspection team sent to the Millstone station with a focus
on Unit 1. Then we looked at Unit 2 and 3 as concerns were
identified based upon the licensee's own self-assessment.
And also within the context of Haddam Neck. So we had a
20-plus-person team looking at the safety and operation
within the licensing basis for the facility. And other
issues were identified where they couldn't make the
appropriate operability call, so it led to the shutdown of
the other units.
Those reports are on the docket, in the public
document room, and form the basis. It was the licensee's
own judgment based upon their assessments and our inspection
results that led to the shutdown of those units and the need
for a reconfiguration to assure operation.
COMMISSIONER DIAZ: I couldn't agree more with the
need for reconstitution of the design basis. Being
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simpleminded, that really was not my question. My question
was, have we identified an independent issue?
MR. MIRAGLIA: I believe we can identify from the
findings in the special inspection at least two or three
significant safety issues at the units that led to the
shutdown, and we can provide that and highlight those
reports for you.
COMMISSIONER DIAZ: Would you, please. I will ask
the staff to do likewise.
MR. THOMPSON: We will be glad to provide that to
the Commission.
MR. McKEE: We had an enforcement conference with
the licensee in December. That enforcement conference
included a number of the issues that were identified at the
inspection we were talking about plus issues that were
identified by the regional inspection program. So what we
provide will probably include a lot of that. That included
a number of significant issues.
COMMISSIONER DIAZ: I have gone to the significant
issues list. I don't see many of them that I would call
really safety-significant and risk-significant.
MR. MIRAGLIA: Mr. Imbro can give one example.
MR. IMBRO: One issue that comes to mind, I
believe on Unit 2, was the size of the containment sump
screen mesh. That was larger than the orifice size for the
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high pressure injection throttle valves and created a
potential for blockage of high pressure injection because
debris could pass through the sump screens that was larger
than the orifice size. That is one issue that comes off the
top of my head.
MR. LANNING: An additional issue is Unit 2
concerning the turbine driven auxiliary feedwater pump.
They had disabled that pump at certain times contrary to
tech specs, which is a very significant finding by this
team.
COMMISSIONER DIAZ: I remember that one clearly.
But I think it would be important that we identify
those significant issues clearly and separate; all of the
issues dealing with design basis and with everything else is
something that we need to have up front.
MR. MIRAGLIA: It's already documented within the
reports. We could highlight those. I think it's those
issues that indicated that we had to do an extensive fix.
CHAIRMAN JACKSON: Why don't you just take what
you have and highlight it and provide it to Commissioner
Diaz.
MR. MIRAGLIA: Yes. We'll do that.
CHAIRMAN JACKSON: Are there any further questions
or comments?
[No response.]
. 115
CHAIRMAN JACKSON: I would like to thank both
Northeast Utilities and the staff for briefing the
Commission on the processes being used to address readiness
for restart of the Millstone units.
The Commission recognizes that much effort has
been expended by the licensee and the NRC staff in
determining what the deficiencies are, analyzing them for
root cause and categorizing them for safety significance.
Clearly, however, there is a lot of work yet to be done.
To reiterate, from the NRC's perspective the
decision-making process has been formalized by the following
things.
First, issuing orders related to an independent
corrective action verification program and the establishment
of a third-party oversight of the employee concerns program.
Secondly, creating the Special Projects Office to
oversee all licensing and inspection activities.
Third, updating the NRC's staff guidelines for
restart approval, namely, the Manual Chapter 0350 process,
specifically for the Millstone units.
Fourth, formalizing Commission involvement by
necessitating a vote for final restart approval and in the
interim conducting routine meetings to track progress which
at this point are scheduled on a quarterly basis.
However, the plan is dependent also on the
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licensee's schedule, and so I encourage the licensee to work
closely with the staff in establishing a schedule however
draft a schedule that may be and as promptly as possible
finalizing a list of restart issues.
NRC resource allocations, as we have all spoken
to, must be planned accordingly. And although the licensee
has indicated the desire to work all three units in
parallel, I believe the Commission would greatly benefit by
having a draft time line with significant milestones
annotated for each of the three units.
The Commission does not presuppose that any of the
plants will restart by a certain date or not restart by a
certain date. However, the Commission must be prepared to
ensure that adequate resources are employed to ensure
adequate review in a timely manner and to ensure that the
public health and safety concerns are addressed.
The Commission looks forward then to more detail,
more meat on the skeletons of these plans and these
processes at each subsequent Commission meeting.
As an aside, with respect to the regulatory
lessons learned from this process, I note that the NRC
continues to study improvements to be made in its processes
and to have those processes reflect appropriately risk and
safety significance. The Commission is currently scheduled
to be briefed on Millstone and Maine Yankee's lessons
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learned on February 19.
Unless any of the Commissioners have any closing
comments, we stand adjourned.
[Whereupon, at 12:40 p.m., the briefing was
adjourned.]
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