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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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04/23/1997
1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
- - -
BRIEFING ON MILLSTONE
- - -
PUBLIC MEETING
Nuclear Regulatory Commission
One White Flint North
Rockville, Maryland
Wednesday, April 23, 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:
MARTIN BOWLING, Recovery Officer, Millstone Unit 2
MIKE BROTHERS, Vice President and Recovery
Officer, Millstone Unit 3
STEPHEN BURNS
JOSEPH CALLAN, EDO
BUZZ CARNS, Sr. Vice President and Chief Nuclear
Officer
SAMUEL COLLINS, Director, NRR
DAVE GOEBEL, Vice President, Nuclear Oversight
EUGENE IMBRO
BRUCE KENYON, President and CEO, Northeast Nuclear
Energy Company
WAYNE LANNING
JACK McELWAIN, Recovery Officer, Millstone Unit 1
JAY THAYER, Recovery Officer, Nuclear Engineering
and Support
WILLIAM TRAVERS, Director, Special Projects
Office, NRR
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P R O C E E D I N G S
[10:00 a.m.]
THE CHAIRMAN: Good morning, ladies and gentlemen.
The purpose of this meeting is for the Commission to be
briefed on the status of activities relating to the three
Millstone nuclear power plants. The Commission will hear
presentations today from both Northeast Utilities and the
NRC staff.
Millstone unit one has been shut down for
approximately 18 months, and units 2 and 3 have been shut
down for a little over one year. All three of the Millstone
units were placed on the NRC's watch list in January 1996.
The units were recategorized as category three plants in
June of 1996.
This action necessitates Commission approval for
the restart of each of the units. The NRC in November of
last year created a new organization, the special Millstone
special projects office, to have responsibility for all
licensing and inspection activities at Millstone to support
a NRC decision on restart of the Millstone units.
This Commission meeting is the second quarterly
meeting to assess the status of activities at the sites.
The Commission is interested in the licensee's
results from its recovery process, how the licensee is
determining that the root cause deficiencies are being
. 4
corrected, a discussion of the role and the effectiveness of
the quality assurance organization at the site, and finally,
an independent assessment from the NRC staff regarding the
threshold and the effectiveness of the licensee's corrective
action programs.
The Commission also is interested in the status of
restart activities and specifically desires comments on the
problems with operator training.
The Commission has recently approved the selection
of the party for the independent oversight of employee
concerns, and so as such, the Commission also is interested
in obtaining feedback beginning with this meeting at each
meeting that we have on gains you're making in making the
Millstone station an environment supportive of the raising
and resolution of safety concerns.
Now, copies of the presentation are available at
the entrance to the meeting, but I'd like to make a
parenthetical remark so that you can address it as you go
along. A member of my staff called your organization
yesterday to inquire as to whether you had any backup slides
for the presentation because the thought was it seemed to a
bit thin, and we were given the understanding that you did
not. And so my first impression is that the message on the
slides, modular, you're fleshing them out as you talk,
appear to be repeating goals as opposed to results. And as
. 5
you may recall, at the meeting we had on January 30th, I
requested that you put more meat on the bones and more
detail, and even though it's not evident in the slides, I
hope that we have a full presentation not only of your plan,
but progress relative to those plans.
And so that we can hear some results, because it's
important whatever your interaction is with the staff that
the Commission hears about where you actually are and
results, because it is the Commission in the end that's
going to have to take the vote.
So with that, Mr. Kenyon, please proceed.
MR. KENYON: Chairman Jackson, Commissioners, I'm
pleased to have this opportunity to update you regarding the
progress being made at Millstone.
Chairman Jackson, with regard to your comment on
the slides, what we have done is identify what we believe
are the most important success objectives and as we talk
about them, we will indicate activities, in other words,
what we have done, we will indicate results achieved, and we
will indicate what concerns or challenges we have going
forward.
So when we complete the presentation, I'd like to
circle back to the comment and get feedback from you as to
whether or not you feel the content was good or we need to
make further adjustments as we do future meetings.
. 6
I'm Bruce Kenyon, president and CEO of Northeast
Nuclear. Seated with me are Buzz Carns, senior vice
president and chief nuclear officer; Jack McElwain, who's
the officer responsible for unit one; Marty Bowling, unit 2;
Mike Brothers, unit 3; Jay Thayer, who is our vice president
of engineering and support; and Dave Goebel, who is the vice
president of oversight. Others in the audience that I wish
to identify are Pat Loftus. She's our new director of
regulatory affairs, formerly with Westinghouse, and George
Davis. George chairs NCAT. NCAT is our advisory team for
end use nuclear committee of the board of trustees.
All of the senior members of the Millstone
leadership team were introduced to you at our previous
meeting on January 30th, although Buzz Carns was just
announced and not available for the meeting, but obviously
here today.
The major purpose of this meeting from my
perspective is to brief you regarding the progress we are
making. At the last meeting, a considerable portion of my
remarks were devoted to giving you an assessment of what
caused the substantial deterioration in performance at
Millstone. And as I indicated then, fundamentally it was
leadership, and I reviewed for you what I considered to have
been the most important leadership failures and what had
been done at that point to place a new leadership team at
. 7
Millstone.
I also, at that time, presented what I considered
to be our most important success objectives, and thus as I
talk about our progress and our significant challenges in
this and future meetings, I will do so in terms of the
success objectives, whose topics are presented on this
slide.
Other topics that I'll address during the course
of this meeting include our current schedules, the company's
financial condition, and very briefly, some comments on
public opinion.
In support of an efficient presentation, Buzz and
I will share the presentation responsibilities but certainly
the other officers here at the table are available to assist
in answering questions.
The first success objective, and again we're going
to do this on the basis of what's the objective, what
activities have we done in relation to that objective, what
results have we achieved, and what do we see as the
challenges going forward.
The first objective is that we are an organization
with high standards and clear accountabilities. The primary
activity in this regard has been the establishment of a new
leadership team, and the recovery organization. And this
includes having established a new officer team; all the
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officers that you see have been newly hired or loaned from
the nuclear industry or in one case promoted. We've
replaced or reassigned about 75 percent of the directors.
Those are the individuals the next level down. We've
obtained recovery teams from PECO and VEPCO who have
responsibilities for units one and 2 respectively, and each
is committed for a minimum of two years.
We also obtained a recovery team from CP&L for
unit 3, but we're nearly completeed in phasing out this
team, mostly with NU personnel and new hires.
This new leadership team has current knowledge of
industry high standards and best practices, has considerable
experience in changing the performance of organizations and
is committed to doing what's necessary to bring these units
back into operations.
Now, in terms of results achieved, I think we have
a leadership team that is functioning very well. We have
largely resolved the leadership issue of a lack of clear
accountabilities. We did this by going to a unitized
organization and by implementing further responsibility
changes and clarifications. We've improved LER timeliness
and quality. But I also think there clearly remains
challenges in the area of high standards.
The general challenge is that the high standards
we are seeking are only partially in place at this point.
. 9
We are still finding and fixing problems. One specific
example is that end use track record in meeting licensing
commitments which historically has not been good at all has
improved, but it still needs to be much better. What is in
progress is an extensive review and compilation of past
commitments, and as we go through that, we are continuing to
find commitments made in the past that were not lived up to,
and to the extent they're reportable, we are making reports
as we go along.
So we're going to continue to have issues in that
area until we finish reviewing all the documentation that we
think is relevant and get in place a good commitment
tracking system.
Another important example, and this goes to your
question, is licensed operator training. This was
identified by the unit 1 licensed operator upgrade failures
and our subsequent reviews, and I think it's important that
I make some comments regarding how I and the rest of the
leadership team view this issue.
I've had nuclear responsibilities for almost all
of my 32-year career, and Buzz's career is somewhat longer.
It's our philosophy that you train your operators and the
rest of your personnel to meet your own high standards.
Satisfying NRC requirements should be a secondary issue, and
in my experience, if you approach it that way, you should
. 10
almost never have an examination failure.
The training program that produced such poor
results began in June, was inappropriately adjusted along
the way, implementation was poor, and that led to licensed
operator upgrade applications being submitted in November.
Now this was a month after the recovery teams had arrived
and at a time when we were heavily involved in assessing a
wide variety of issues, and we frankly had just not picked
up on the fact that there were significant problems in the
-- in operator license training.
Now, this is an explanation, but it's not an
excuse. We were surprised. We were embarrassed.
Particularly considering our philosophy. But we are
determined to and are aggressively addressing the situation,
in part through a very thorough root cause analysis. We've
hired a new director of training and we have docketed a
detailed corrective action plan, so we are working our way
through the plan, but the licensed operator training that we
will achieve is going to be based on the standards that I
described.
THE CHAIRMAN: Let me stop you for a minute.
Given the problems that you found in your initial
operator licensing program, what can you say in the way of
the confidence that the Commission should have in your
requalification, that your requalification program doesn't
. 11
have the same problems?
MR. KENYON: We took a good look at the
requalification program, and we're satisfied that the
requalification and training program is in good shape.
We're satisfied --
THE CHAIRMAN: What satisfies you?
MR. KENYON: Jay, I'm going to ask you to get into
details of what we have done, but obviously when you see
problems, recordkeeping problems, standards problems,
attention line management problems and the whole litany of
things that we saw in the initial licensing or upgrade
training program, then you look for the same problems in the
ongoing retraining programs, and other than some pretty
relatively minor stuff, we did not find these major problems
in the licensed operator requalification program.
Now, Jay, would you --
THE CHAIRMAN: Before he starts, you know, this is
a significant issue, not just for the Northeast Utilities
organization, but the Commission has under consideration the
whole issue of initial operator licensing and having that in
the hands of -- more in the hands of the industry itself,
the individual plants, and so this kind of a problem to show
up at this stage of the game is not particularly helpful.
This is in the broader-based sense, as well as
not, of course, being particularly helpful to you, but let
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me hear from Mr. Thayer.
MR. THAYER: Just to go back to the
requalification training issue, we used the same approach on
the requalification training program review that we did that
was taken by the independent review team in their review of
the unit 1 failures. That resulted, as Mr. Kenyon said, in
several discrepancies to our own accredited training
program.
For two of the four Connecticut units, we shut
down the requalification program for one week each, fixed
those that were mostly administrative issues, procedural
issues, some process discrepancies, fixed those and then
restarted each of the requalification training programs, one
week later on schedule. Those programs are functioning now
and we've had -- our review of those tells us those are
sound training programs.
THE CHAIRMAN: Let me ask you another question.
You talked about your first success objective being that
you're an organization with high standards and
accountabilities. If I go to your restart items, are each
of those accountable to a particular individual or schedule
setup and tracked for each one? Can you give us a few
examples?
MR. KENYON: As a general statement, we know who's
responsible for all of the items. Are there detailed
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schedules on all items? I mean, I would say probably not
but most items are scheduled.
Let me ask -- go ahead, Jack.
MR. McELWAIN: The operational readiness plan for
unit 1, for example, every line item, including the
significant items list, has a person responsible for it, a
due date, and we track those deliverables on a weekly basis,
and I believe it's the same for --
THE CHAIRMAN: Do you have an individual who is
responsible for that?
MR. McELWAIN: Yes. For example, in the operating
licensed training area, the unit director of unit 1 is
responsible for the overall picture and the line items
underneath that that came out of the IRT are responsible for
the next tier down, which is the ops manager, and the
assistant ops manager, and we also are continuing looking at
that.
And if I might clarify a little bit, the license
-- initial license training class that failed was designed,
I would say, inadequately in that it was a six-month program
for initial licensing, which is not something that any of us
were used to seeing anywhere, or were aware that that
specific activity was only taking six months. It was unit
1, and I'm the unit 1 person, so I'm accountable for that
but --
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THE CHAIRMAN: You're saying there was a change in
the length of the training program?
MR. McELWAIN: Yes.
CHAIRMAN JACKSON: And you were not aware of it?
MR. McELWAIN: It started before we got here. It
accelerated. When I got here, I naively thought that that
was the end of a one-year or longer program. In reality, it
was the end of a six-month program, and we put these people
up for tests. That's the clarification. It was
accelerated. It was not our normal licensing program and it
was not done properly, and documentation aside, that program
was not set up to be a success.
THE CHAIRMAN: Let me hear from the unit 2
manager.
MR. BOWLING: On the issue of operator training,
as you know, unit 2 did conduct an initial operating license
class in 1996. There were 12 candidates that took the exam,
of which all 12 successfully passed.
Nonetheless, based on the unit 1 review, we looked
into the adequacy of the program for initial operator
licensing on unit 2. What we found was that a large
percentage of the candidates did not successfully meet all
of the program -- the internal program requirements.
Several have been restricted administratively from
performing licensing duties as a result.
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The -- on the matter of operator requalification
and the adequacy of that program, which Jay Thayer has had
reviewed, from my standpoint, it has to pass my standard as
well, and as a result, I am observing operator requal on a
weekly basis as well as the unit 2 director, and so senior
management has to have the assurance that it's meeting our
standards, which it is at this time.
On the scheduling of the restart items, that's in
-- I'd like to talk about that in two parts.
First, the NRC has recently issued on unit 2 the
significant issues list. We have that scheduled and there
are accountable individuals, not just for each of the items
on the schedule, but for the overall accomplishment, and
that's tracked on a weekly basis and made available to the
resident inspectors.
THE CHAIRMAN: Let me hear from Mr. -- are you
done? Want more?
MR. BOWLING: Well, I just wanted to make one
other point on the restart items. What we consider as
restart items is more extensive than the NRC list, and
that's also tracked similarly.
THE CHAIRMAN: All right. Let me here hear from
Mr. Brothers, and then I think Mr. Rogers has a question.
MR. BROTHERS: With regard to the items if they're
assigned individual responsibility and they're scheduled,
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the answer is yes, for both significant items and all
restart activities.
THE CHAIRMAN: And on the requalification.
MR. BROTHERS: Requalification was looked at by
the same format on independent review, and it continues. We
did find on the last licensed operator initial class, two
individuals with minor discrepancies based upon the IRT from
unit 1, they were removed and one person was removed from
watch, and the deficiency was corrected and he was placed
back on watch.
THE CHAIRMAN: What has changed about it? What
level and who makes the judgment as to what the training
program is as well as its duration, such that we would have
assurance that what you're talking about would not occur --
MR. CARNS: Chairman Jackson, if I may participate
in the discussion.
CHAIRMAN JACKSON: Please. You can participate as
much as you want. I want to just understand, you know, the
answer to the question.
MR. CARNS: There are some very straightforward
simple things that we have to do, and one is to get line
management, ownership of training there. There has been a
disconnect. We have training advisory committees now that
are headed by the unit director and I'm going to chair an
executive training advisory committee to make sure that the
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emphasis is there.
We have done some very simple things, like telling
the training department they do not hold a graded evaluation
of a simulator session without at least the operations
manager there to witness it. In the past, training was done
in a vacuum.
What we have decided is that we're not going to
train the way we operate. We're going to operate the way we
train. It's going to start at the training center and
emanate from there.
CHAIRMAN JACKSON: Okay. Commissioner Rogers?
COMMISSIONER ROGERS: Yes. On the unit 2 initial
exam, you mentioned that everybody passed. Now what was the
duration of the training program that those people
underwent?
MR. BOWLING: That was the -- the issue in
question was the amount of on-shift time, and -- in terms of
actually practicing the requirements of holding a license
and that was the area that was cut short. All other program
requirements, to my knowledge, were met.
COMMISSIONER ROGERS: What I'm trying to get at,
though, was Mr. McElwain's observation that he thought that
these operators that did pass the initial test in unit 1,
had gone through a one-year program, and now you -- what
about the ones that you -- that did pass it?
. 18
MR. BOWLING: My understanding was it was a
one-year program.
COMMISSIONER ROGERS: No, but the ones that passed
for unit 2 were in a one-year program, not a six-month
program?
MR. BOWLING: Yes. Right.
THE CHAIRMAN: So the problem was within the
duration and being able to cover certain material, whatever,
and activities and needing a certain amount of time to get
that done, is that correct?
MR. McELWAIN: I believe in the pursuit of the
timeliness to fill the pipeline that we went on the wrong
path. You couldn't have the breadth and the width of what
you needed in a real operator license program and have
expected these people to be successful, had we looked at it
from the big picture perspective.
COMMISSIONER ROGERS: I take it then that this
six-month training was an accelerated one just for this
group of people?
MR. McELWAIN: Yes.
COMMISSIONER ROGERS: But prior to that, the
custom had been to have a one-year training program?
MR. McELWAIN: Yes. This was the first aberration
of this type.
MR. THAYER: If I could, that is correct. In
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accordance with our accredited program, the requirements are
specified. Any deviations from those requirements need a
thorough documentation. The problem with the unit 1 program
is that there were decisions, as Jack mentioned, to shorten
pieces of that program that were made very low in the
management chain. Those decisions weren't coordinated or
verified by unit management or upper level training
management and this program proceeded with some significant
decisions about shortening being made without the cognizance
of upper management.
THE CHAIRMAN: And so you're saying that what has
changed is in fact both upper management's involvement as
well as having the actual line management engaged in this
process?
MR. CARNS: That's correct, Chairman.
MR. KENYON: And as maybe a final recap, where we
believe we are on this issue is that we have an ongoing
requalification program that's functioning well. We don't
see any serious issues with that. We do have one licensed
operator training class in progress on unit 3 and we are
scrutinizing that very carefully, and based on what we've
seen so far, we think the program is functioning well, but
it obviously has our attention.
THE CHAIRMAN: Okay.
MR. KENYON: Moving on to success objective number
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two, and that is that we demonstrate a strong nuclear safety
philosophy as evidenced by careful adherence to high nuclear
safety standards and conservative decision-making. The
activities here have been that we have published a nuclear
safety document modeled after Virginia Power's. It's based
on four principles, which are the need to maintain a
profound respect for the safety of the reactor core and the
spent fuel, the need to focus attention and resources on
proactively preventing events that compromise nuclear
safety, the need for conservative decision-making, and the
requirement to enforce high standards by doing the right
thing, meaning that the quality and safety are paramount
over schedule and production.
Now those are four principles, but behind that
there's a very detailed document.
The overall result is that I believe on an ongoing
basis, we're demonstrating improved nuclear safety standards
through day-to-day decision-making. Our challenge is that
while this document has been put out fairly recently and is
understood by senior management, we've got a lot of work to
do to educate the work force, drive it down in the
organization so it really becomes a part of their day-to-day
activities, so we have the standard out. We are endeavoring
to live up to that standard, but we're nowhere near where we
need to be in terms of driving and understanding of that
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down into the organization.
Success objective number three --
THE CHAIRMAN: Before you go to the next success
objective, do you track adherence to procedures? And if so,
how is it trending?
MR. KENYON: When we don't comply -- you know,
when we have a problem with procedure compliance, it is
picked up as a CR and the CR is a condition report, and
those are tracked.
Now, I have to ask the unit officers on an
individual basis to tell you how it's trending on their
particular unit.
THE CHAIRMAN: Okay, can each of you briefly tell
me, 1, 2, 3.
MR. McELWAIN: Sure. The procedure compliance
issues of which there were many in '96, unit 1, have
decreased dramatically. We have people with the mind-set
now that if you can't do the procedure as written, you stop.
And we have a lot of information. It doesn't get to be a
corrective action request, or it's self-identified by the
person that's actually doing the job.
We have several I&C people, for example, that have
created their own condition report based on the -- not being
able to proceed with the procedure without stopping and
changing it. We've had shift managers stop operational
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activities because they need a clarification, and that kind
of thing didn't happen in the past, and that kind of led to
some of the procedure adherence issues. We would go down a
path and outthink the procedure in some respects and not
stop and not stop when there was a question, and then fix
the problem and go on. And that's where we're at pretty
much on the OR.
MR. BOWLING: The expectation is that procedure
non-adherence will be documented in a condition report so
that corrective action can be taken. The number of those is
relatively low. I do not draw as much comfort from that as
the number would indicate, based on the need to raise the
standard, and the expectation, and a general weakness in the
procedures set in terms of level of detail which we are
working on.
THE CHAIRMAN: Okay, Mr. Brothers.
MR. BROTHERS: In the case of unit 3, we do track
it. There is condition reports, procedure compliance, that
indicator is low. I think that's primarily due to the
number of procedures we're performing on unit 3 being
relatively low at this time.
One issue that we have that's related that I would
consider related to procedure compliance is a component
manipulation and plant configuration control. That trend is
identified, internally identified as going in the wrong
. 23
direction at Millstone unit 3. While not directly a
procedural compliance issue, there's a personal error
component associated with that. That combined, the
procedure component -- error component is of interest to us
and we're addressing it now.
THE CHAIRMAN: What about the quality of the
procedures themselves?
MR. BROTHERS: The quality of the procedures is
tracked. There is a, within the procedure group under Mr.
Tray Kilpatrick, there is a quality of procedure indicator
he has developed and that is going up.
THE CHAIRMAN: Okay. Thanks.
MR. KENYON: Number three has to do with effective
self-assessment. This is very important in driving to the
goal of improving performance. Self-assessment must be
effectively accomplished by both line management and the
various oversight mechanisms. I think the important test
here is that significant issues are identified by NU rather
than others. So I'm going to talk about each component of
this, beginning with line management self-assessment.
We believe that line management self-assessment
process has been established and results have been achieved.
The activities have been the implementation of a
self-assessment and work observation processes on all units.
We've substantially lowered the threshold for writing
. 24
condition reports.
Now, the challenge is that there's not yet enough
implementation history to demonstrate that our
self-assessment activities are effective. So we just need
to take more time and see how it goes, but the process is in
place and we're using it.
THE CHAIRMAN: What's your metric for
effectiveness?
MR. KENYON: That we are self-identifying problems
as opposed to somebody else identifying them.
THE CHAIRMAN: Do you roughly track a ratio of
self-identified versus externally identified?
MR. KENYON: Yes, we do.
THE CHAIRMAN: And how is that trend going?
MR. KENYON: Again, we've got to do it on the --
MR. CARNS: One of the results is that we're
identifying 25 percent more internally than externally now.
THE CHAIRMAN: So that's one of your metrics?
MR. CARNS: Yes.
CHAIRMAN JACKSON: And how do you measure whether
what's been identified as what's the most safety significant
and/or correctly identify it?
MR. CARNS: Each of the units, when they have a
condition report written, they screen those for significance
level and for discussion at the morning meetings, and the
. 25
significant ones are on a morning report on our Audix phone
system and virtually each of us listen to that in the
morning, and then when I hear something that raises a flag,
I'll go right to the unit officer and discuss it with him.
THE CHAIRMAN: Let me hear from each of you
quickly in turn.
MR. McELWAIN: Yes. We have the morning 8:30
management meeting where all the condition reports generated
in the last 24 hours are gone over, and significance levels
and personnel responsibility is assigned at that meeting.
MR. BOWLING: Okay, Unit 2 is similar. I would
just make one comment about self-assessment in general, and
the effectiveness of the program, what we're looking for.
As you know, to have effective self-assessment,
the organization and the personnel conducting
self-assessment must be at a sufficiently high standard that
they know what they're looking for and whether it's right.
So two indicators of effectiveness would be the raising of
the standard, which would primarily be done for benchmarking
as to what is the correct way to be doing business, and the
second is the number of programmatic issues that are
identified by line management versus the oversight
organization or external agencies such as the NRC.
MR. BROTHERS: From a ratio standpoint of self
identification, in Millstone number 3, the trend is going in
. 26
the right direction. For instance, in March, 248 items were
identified. 26 identified by internal oversight, none by
external oversight, and no events, for a ratio of
approximately 98 percent per unit and two percent for
internal oversight. That is going in the right direction.
The other aspect of this similar to unit 1 and
unit 2 is that we also have conducted review of the
condition reports. A management review team reviews the
proposed corrective action and comes up with a quality
indicator for that corrective action which is trending in
the correct direction, going up.
THE CHAIRMAN: Okay.
MR. KENYON: Shifting to oversight's
effectiveness, we believe that's improved as well. The
activities have been development of an oversight recovery
plan, the implementation of that is about 50 percent
completed. I have communicated my expectations regarding
the role of oversight, the importance of oversight to the
entire organization. We have implemented in a new oversight
organization with expanded resources to better handle the
current challenges and this includes having put line
experienced individuals in both permanent and rotational
positions within oversight, and we've revised and
implemented all oversight procedures.
Now, what have been the results? The results have
. 27
been that I think we have a much better acceptance of the
role of oversight within the broad organization.
Historically that was not there. There's an improved
working relationship with line management. I think what
occurs now is a very healthy and constructive debate on
issues, and I'm also pleased that the quality and usefulness
of audit reports have improved substantially.
The challenges with regard to oversight is to do a
combination of continuing the improvement process, because
it's ramping up, but it's not totally where it needs to be,
but provide very needed review and oversight of our
preparations for ICAVP as a near term milestone.
I also think line management responsiveness to
oversight-identified deficiencies, while improved, needs to
improve further.
I also want to mention the NSAB, our -- its
effectiveness has improved with established separate -- I'm
talking activities now. We've established separate NASB's
for Millstone and CY for increased focus. That's a change.
We've intentionally put senior management on NASB.
That was not how it was done previously, so Buzz is on it,
the unit officers are on it. We've doubled the number of
external numbers from 2 to 4 so that we have some very
independent review, discussion and dialogue taking place.
The result is that its performance has improved.
. 28
I don't -- I'm not here today to tell you I think it's where
it needs to be, but it is improving.
I also want to mention NCAT. NCAT, as you know,
directly advises the nuclear committee of the board. At
least monthly it comes to one of our nuclear sites. I think
they do a very effective job at providing another measure of
independent assessment which is useful both to me and the
nuclear committee. While at least partially on the subject
of ou r board's nuclear committee, I'm pleased to advise the
Commission that Bill Conway, and many of you know Bill, and
he's highly regarded for his nuclear operations expertise,
is joining the board and he participated in his first
meeting yesterday.
Overall challenges with regard to the issue of
self-assessment. I think oversight is clearly adding value
but it needs to continue to improve in order to become a
fully effective organization.
I think the NSAB, although starting to improve,
needs to reach a higher level of performance.
And I think line management needs more time to
demonstrate the effectiveness of its own self-assessment
activities, but the trends are good.
THE CHAIRMAN: Now, at the last Commission
meeting, the Commission requested a more robust presentation
on your site QA organization. Are you prepared to talk
. 29
about that today?
MR. KENYON: We can certainly go into as much
detail as you want. So let me turn to Dave Goebel and ask
him to discuss with you in more detail the functioning of
the oversight organization.
MR. GOEBEL: The oversight organization today is
still in the building process. Not so much numerically, but
in skills. Although we have made, I think, what Bruce has
properly classified as good improvements in the audit area,
the audit reports are having substantive findings, if there
are such things to be found, and there is a good response to
those finds from the line organizations, or whoever owns the
individual item which has been audited.
The oversight organization also has played a very
active role in monitoring the efforts to restore the
configuration control to the units, to the 54(f) effort. We
are actively involved --
THE CHAIRMAN: When you say actively involved, has
the QA organization actually reviewed the scope and the
implementation of the configuration?
MR. GOEBEL: We have reviewed the scope which each
of the individual units are pursuing, have commented back to
the units on the extent of their scope. In some cases that
scope has then been modified. We have commented on each
individual process that the units have prepared in order to
. 30
help them to reestablish the configuration control, and when
it is -- as we go through that process and we come out the
other end, they will have a product to deliver and we will
do vertical slices on that product.
THE CHAIRMAN: On the actual implementation?
MR. GOEBEL: On the actual implementation of the
whole thing, we will do a vertical slice and we will then
comment on what we find or don't find.
THE CHAIRMAN: And what skills building did you --
have you found that you've needed to do in the QA
organization? You said you were still building.
MR. GOEBEL: There's an overall knowledge level
that needs to be improved. There also -- which we are
actively pursuing, some of that by bringing in knowledgeable
people, people who have traditional backgrounds in the area
from other utilities, people who --
THE CHAIRMAN: Permanently?
MR. GOEBEL: Permanent new people.
We have, in some cases, as Bruce has mentioned,
where we've brought some line folks in, the line folks
really don't have a QA background but they have a knowledge
of impact, certain evolutions and things that are done on
the line. The reason for that, why to me that's so vital,
it puts us in a position where then we can anticipate
problems and not go inspect them after they're done.
. 31
I would like to know which evolutions performed at
the plant are high risk evolutions. I want to make sure we
have anticipated those and looked at them far enough in
advance so there's not a -- and in that case serve as a
backup to the line, so there is not a problem which is found
by event which could have been precluded, had a
knowledgeable person looked at it.
THE CHAIRMAN: So in reviewing the scope of the
configuration management plan, then you are in fact
reviewing it from the point of view of risk?
MR. GOEBEL: Yes. We are.
THE CHAIRMAN: Okay.
MR. KENYON: I would like to have Buzz Carns
review the next two success objectives.
MR. CARNS: Success objective number 4 is that we
have an effective corrective action process. The program is
in place. Now we have to prove that we can effectively
implement it. Units are sharing problems, Lessons Learned
and progress made. The director level individual
experienced in implementing a successful corrective action
program at another utility has been hired and will be on
board in the next several weeks. We believe that this
addition to our management team will provide strong and
necessary leadership for the whole process and help develop
some consistency in our corrective action efforts across all
. 32
three units. We believe that corrective action is based on
a simple concept, find and fix your own problems, and follow
up to ensure that they remain fixed. Inherent in this
concept is a responsiveness to others, including the
employees, the industry and the regulators. The
characteristics of the healthy program we probably all could
agree on are self-identification, a questioning attitude and
an effective program that addresses problems and precursors
in an aggressive manner. In the past we've been noted for
precreating problems to solve our problems without effective
follow-up implementation. The real message is that people
solve problems when they work to high standards and are
committed to do what is right. The value of an effective
program is that it provides the lasting institutional
framework for success.
We've improved the mechanics of the corrective
action process to formalize documentation requirements and
establish a dedicated staff to oversee the program. In
addition, we have installed within each of the departments
of the units corrective action coordinators to emphasize
line ownership of the program and the problems. Performance
monitoring and benchmarking are also being utilized to
promote effectiveness.
The results we are seeing include -- and some of
these have been mentioned -- in the last six months,
. 33
approximately 25 percent more identification internally than
externally. A decreasing number of open evaluations and
improvement of evaluations completed within 30 days, which
is the framework. We do have quite a few that fall outside
that guideline right now, but if it needs a further
extension, it has to go to higher levels of management. And
the backlog is being managed and reduced. There is --
THE CHAIRMAN: How is it declining?
MR. CARNS: Let me give you to each of the units.
They can tell you where they are on the declining. It's not
as significant, but it's in the right direction.
MR. McELWAIN: On unit one, the backlog has been
reduced over 200 in the past month and we expect the next
month --
THE CHAIRMAN: You have to reference that to
something.
MR. McELWAIN: From 900 and change to 700 and
change, the backlog, that's the lower significance and the
former program level C and D, created prior to '96, sometime
prior to '96. That's where the big backlog came from;
pretty much in place then.
MR. BOWLING: It's not easy to talk very quickly
about corrective action, but let me try.
THE CHAIRMAN: Well, let me give you a background
question that I'm interested in. What I'm interested in is
. 34
in terms of resolving corrective action issues. Is the time
for resolution appropriate to the safety significance?
MR. BOWLING: That's been our approach on unit 2.
What we have done is taking all of the types of corrective
action -- Jack spoke to the condition reports, but there are
corrective actions in terms of procedures, design
modifications, and the maintenance physical condition of the
plant, through the work order program.
Our approach has been to organize all of the
identified issues, of which there are thousands, into safety
significant, and then we're systematically correcting by
safety significance, and in the areas we're working in, we
have made substantial progress in corrective action.
But for those items that are to be done later in
the schedule, obviously they're still in the backlog.
THE CHAIRMAN: Right. But for those items that
you by your own methodologies have attached the greatest
safety significance to, do you have any significant backlogs
that aren't -- backlogs in the sense of not having a
specified place in the schedule, but just part of a backlog
that you haven't addressed in some way?
MR. BOWLING: No, it's scheduled. And as we move
through the schedule, our goal is to take those backlogs to
industry standards.
MR. CARNS: Some of those obviously have to --
. 35
depending on the significance, have to be solved when found
or within a very short time period. There's others that
we're discovering -- unit 3, maybe Mike can address that,
that's a hardware fix that we have to fix before we go
further.
MR. BROTHERS: Yes. In terms of backlog on unit 3
for the non-significant items, from January, we've gone from
882 to, as of April 12th, 402, so a reduction of 441 on -- a
number greater than 30 days old. In terms of significant
items that have not yet been evaluated, we do have 51 items
that are significance level one that have not yet been
evaluated. Our goal is to have that to zero by July 5th.
THE CHAIRMAN: Okay. So when I talk to you next,
you'll have that resolved?
MR. BROTHERS: That's correct. If it's after July
5th.
THE CHAIRMAN: Well, when I talk to you next is
going to be three months from now, and by definition, that's
after July 5th.
MR. CARNS: I think in the interest of time, let
me just say the challenge for us --
THE CHAIRMAN: The point is, we'll ask -- you
know, you don't just -- we allotted a lot of time to you
today, so --
MR. CARNS: Then let me back up and pick up some
. 36
other items then.
[Laughter.]
MR. CARNS: We talked a little bit about grading
our condition reports and we have these management review
teams that do that, and I think that's significant because
it really looks at the corrective action and assigns a
numerical grade, and that trend is in the right direction,
and trending obviously is very important. With the program
just being established, we don't have a lot of information
on trends, but we've seen some results already. We've seen
the identification of issues in the area of operations
configuration control, and adherence to fire protection
requirements for materials storage. So while the program is
yielding results in the prevention of recurring problems and
the earlier identification of potential problems, we are not
satisfied that any of the results that we have talked about
today are where we want them to be in the long run.
The challenge obviously is to effectively
implement a program to meet very high standards. That
challenge still remains in front of us.
COMMISSIONER ROGERS: You mentioned your grading
of your corrective action reports. What is the average
grade?
MR. CARNS: 2.87 to --
COMMISSIONER ROGERS: Out of what?
. 37
MR. BROTHERS: 2.90 out of 4 on Millstone unit 3.
MR. CARNS: There's a floor of 2 and a ceiling of
4 but it's gone in the right direction.
MR. BROTHERS: There is no floor. It goes from
zero to 4.
MR. CARNS: Well, I was -- 2 has been our minimum,
I think, of what we've had.
MR. McELWAIN: 2.4 on unit 1, and it's increasing.
THE CHAIRMAN: 4 is a good grade?
MR. McELWAIN: 4 is perfect.
CHAIRMAN JACKSON: There is never perfection.
MR. CARNS: I don't think we'll be able to tell
you we are at 4 in three months. but we should be really
closing in on the 3 and slightly over 3.
The next success objective is the restoration of
the design and licensing basis or the 50.54(f) effort if you
will. This is an integral aspect of the corrective action
process at Millstone. We must be able to identify the
discrepancies, capture and track them and effectively
implement the fixes. The 50.54(f) project will accomplish
this for each unit and the work will be validated by an
oversight organization and then confirmed by the independent
corrective action verification program.
The project is significant with nearly 700 people
involved in the effort. We retained 3 different nuclear
. 38
steam supply system firms and each has put an experienced
team in place to assist the units in their licensing and
design basis restoration efforts. The team at unit 1 is
General Electric, partnering with Raytheon and Stone &
Webster. The team at unit unit 2 is Combustion Engineering
partnering with Stone & Webster. And the team at unit 3 is
Westinghouse partnering with the Southern Company.
There is still a great deal of work to be done
before meaningful results are achieved. Our approach is to
identify issues, initiate condition reports as appropriate
and determine which of those condition reports should be
licensee event reports and assess the safety significance
and finally make any necessary physical modifications. To
date, we've identified approximately 6,000 items that
require further review. And out of this total we have
identified about 40 physical modifications that are slated
for units 2 and 3.
Clearly the challenges are to establish the
licensing and design basis.
Another significant challenge is to transfer the
knowledge base that's being created to the Millstone staff.
And finally, we need to develop a program to
ensure that the configuration management is kept current in
the future.
THE CHAIRMAN: Let me ask you this question. Of
. 39
these 40 physical changes on units 2 and 3, have any of them
been implemented?
MR. CARNS: I don't know that we have any complete
right now.
MR. BROTHERS: Yes, we do have a few. There's 30
on Millstone unit 3. Some of them, like, for instance,
installing the target rock controller card, is done. I have
a list and we can go through specifics of which ones are
done. Out of all of them, out of the 30, probably about six
have been done at this time.
THE CHAIRMAN: And have any design basis issues
arisen after a system has been completed?
MR. BROTHERS: No.
MR. CARNS: From a 50.54(f) review completion?
THE CHAIRMAN: I'm talking about after you've
actually done the physical modifications, you don't identify
any further issues and there are no repeat violations with
respect to anything?
MR. BROTHERS: No. Let me amplify on that,
however. When we -- for instance, on one of our more
significant modifications is the RHR flow control valve mod,
associated with the failure mode of the air-operated valves
and the subsequent heat load on the reactor plant component
cooling water system. As we investigated that, we found
other systems like CCE, which is charging pump cooling that
. 40
had the same problem, but nothing additional on RHS.
THE CHAIRMAN: What are some of the oldest issues
that you are wrestling with?
MR. BROTHERS: The oldest -- any of the issues we
found are original design issues. In fact, the majority are
original design issues that date back to original
construction.
THE CHAIRMAN: And can you give me some examples
of those that you would put in the safety significance
category.
MR. BROTHERS: Yes, I could. At this time, the
recirculation spray system, RSS system, has several problems
that have been identified. They're all original
construction and they are vortexing and containment with the
flood-up level being potentially below the vortex preventer.
The water hammer event on external containment that was a
follow on from Generic Letter 9605, and finally the suction
voiding that we have just recently identified as a potential
and issued a prompt report last week with potential for
suction voiding at saturated conditions and atmospheric
pressure inside of containment.
COMMISSIONER DIAZ: For which component?
MR. BROTHERS: The recirculation spray system
pump. Those are the most significant.
COMMISSIONER DIAZ: So you have three major issues
. 41
that definitely have safety significance? On Unit 3?
MR. BROTHERS: Well, in the case of vortexing, the
analysis is not yet complete. There was an analysis done at
one time that showed the flood-up level was correct. In the
case of suction voiding, we did make the prompt report.
Based upon indications we had, the calculations are not yet
complete but it could require a mod. In the case of water
hammer, that's a real event.
There are a couple of other ones that have fallen
into safety significance. The electrical separation issues
that have been found, which were primarily associated with a
main control board supplied by Reliance Electric in the
original construction. We need to go back and quantify what
our actual design basis is for electrical separation. And
finally on the failure modes for air-operated valves that
are the interface, if you will, between architect-engineer
supplied systems and NSSS-supplied systems, in which RHS and
CCE, which is is residual heat removal and the charger pump
cooling, the two I just discussed earlier, will be
indicative of that type.
MR. McELWAIN: You want to know -- you're looking
at me --
CHAIRMAN JACKSON: Expectantly.
MR. McELWAIN: The safety significant issues on
unit 1 have been historical. For example, the intake
. 42
structure ventilation, there are certain design parameters,
the ventilation is inappropriate and we would lose that
system. Obviously we need them for cooling, no matter what
mode you're in. And the 7914 seismic letter, as well as the
USIA 46 and 90.22, all relating to seismic issues,
particularly the significant ones for us are relay
chattering possibility on the diesel generator and gas
turbine, and the 4 kV busses. Those designs are complete,
and we are implementing them in the field so they are
historical in nature but we are, based on their
significance, attacking them very aggressively. We have 23
mods in progress, 6 complete and almost 40 left to go, but
they're in various stages of being designed and planned and
implemented.
MR. BOWLING: On unit 2, our discovery process of
design licensing basis and its comparison with the actual
plant configuration has resulted in the identification of
around 8 modifications. However, through other areas of
investigation, a larger number of modifications have been
identified in order to restore the plant to safety standards
and to regulatory compliance.
A couple that I'll mention, and one of which is a
-- not only a recent discovery, but also had generic
industry implications, aux feedwater under a single failure
was determined to have the potential, when added to the
. 43
containment analysis, to exceed the design limits of the
containment during main steamline break which was a design
basis postulated condition, and that's resulting in a
modification to prevent that.
Also, main steam line under a single failure
assumptions has resulted in overpressurization. That was
determined by Combustion Engineering as a potential generic
industry issue and they did issue a Part 21 on this
particular problem. That also is resulting for unit 2
modification of the steam line.
THE CHAIRMAN: Of the 6,000 items that you said
needed further review, what do you mean when you say further
review? Is it parsing as to what they are, as to whether
they're safety significant or --
MR. CARNS: Exactly. Whether they go into a
condition report or turn into a LER. It turns out that they
result in about 800 condition reports, and it looks like we
have some left of about 5 dozen LER's that are coming out of
that.
COMMISSIONER DIAZ: How much?
MR. CARNS: Somewhere between 4 and 5 dozen.
CHAIRMAN JACKSON: About 60.
MR. CARNS: 50 to 60 is the ballpark.
THE CHAIRMAN: But you haven't finished that
review at this stage of the game?
. 44
MR. CARNS: No.
MR. BOWLING: If I could add, this is the standard
type of questioning that comes out of this type of process.
As the engineers review the design licensing basis in the
plant, they may well have any number of questions as they go
along, or potential concerns, and this large number is that
listing, and then after further investigation, it goes to
whatever actual corrective action may be necessary, and in
all cases it may not be.
THE CHAIRMAN: Okay. I think Commissioner
McGaffigan has a question.
COMMISSIONER McGAFFIGAN: You're going to discuss
later the schedule, but how does all of this -- in listening
to this, it sounds like there's a fair amount of uncertainty
in which you're trying to manage. You know, how does this
affect the scheduling of ICAVPs and the -- you know, how do
you make a schedule given the amount of uncertainty that
you're dealing with here?
MR. KENYON: We have -- let me give you a short
answer and then maybe a longer answer when we talk about
scheduling, but we continue to believe that we can achieve
the May 27th start of the ICAVP. We're watching it closely.
We think the items that are relevant to that are all being
tracked and worked. Clearly as we go through and -- you
know, the challenge of the ICAVP is that you found the
. 45
issues, not that you have necessarily solved all the issues.
So we continue to think that we're on track for
that, but I'll say more about scheduling when I discuss it
more completely.
THE CHAIRMAN: Commissioner Diaz, I think, has a
question.
COMMISSIONER DIAZ: Yes, going back to the 6,000
issues, how far along are you in the review and
prioritization of these issues as regards being important
issues or safety issues or what attempts at, you know,
prioritization of the issues and separation so you can
actually address them? How far along are you?
MR. BROTHERS: Well, let's talk unit-specific. On
unit 3, basically the systems have been looked at.
The systems that are required to be complete prior
to the start-up of ICAVP, that has been done. The schedule
completion date for the unresolved item and open item report
resolution or parsing is scheduled to be complete on May 3rd
for Wave 2 and Wave 3 which accomplishes the prioritization
that you're talking about for the remaining maintenance rule
group one and two systems.
COMMISSIONER DIAZ: All right. That's precisely
the kind of information that we really need.
MR. BOWLING: On unit 2, our ready for the ICAVP
is June 23rd. At that time, we would have completed the
. 46
review of 24 of the 63 maintenance rule systems that we feel
are necessary to validate, and when we're completed, we're
also through corrective action, except for any modifications
that would actually have to be constructed into the plant.
In answer to your question, we -- it would appear
that the discoveries over the past year have been effective
because on a week-to-week basis we're not identifying that
many more items that reach that significance level that they
have to be a condition report or go into a licensee event
report.
MR. CARNS: Not all the corrective action requires
training and procedures, but the discovery will be done by
the 23rd.
MR. BOWLING: Right, and corrective action to the
extent if a procedure change is required, it will be --
well, it will actually be written for implementation.
COMMISSIONER DIAZ: Have they been characterized?
Have they been prioritized into which bin they belong?
MR. BOWLING: They're binned broadly by the
necessity to correct before restart or after, based on their
safety and regulatory significance.
COMMISSIONER DIAZ: That is an important issue,
whether they have to be done before restart occurred. This
is an item the staff needs to be working on.
MR. McELWAIN: Unit 1 is using the same
. 47
identification and prioritization process, and laying it out
either post-restart, pre-restart, when we need the systems
to be operable.
CHAIRMAN JACKSON: Okay.
MR. KENYON: The success objective number 6 is
that we have an environment that supports the identification
and effective resolution of employee concerns. In terms of
activities, we developed and submitted a new employee
concerns program, the basis of which was work by an employee
concerns task force. We have increased the ECP staff to 12
from 3 which is where it was one year ago. We selected
Little Harbor Consultants as the employee concerns
contractor. That contractor was recently conditionally
approved by the NRC and it has begun its site work. We've
retained Paul Blanche, who is a former Millstone
whistleblower, as a consultant primarily on employee
concerns matters.
The results. We perceive that employees are more
comfortable reporting concerns to NU, and this is as
indicated by a significant increase in the number of
concerns reported. We have achieved much greater
involvement by line management in successfully handling
employee concerns with a clear willingness to tackle
difficult issues. We've reduced the average time to resolve
a concern by almost an order of magnitude. It used to be a
. 48
very long time, and we're now down to 29 days.
The challenges are that we still have a lot of
work to do to fully implement the new program.
Another challenge is that we do not at this point
have good statistical information regarding employee
attitudes. We recognize that this is needed. We will
obtain it. We've been waiting for Little Harbor to come on
board so we can agree on an approach that they're
comfortable with.
So I think the climate has improved but we
certainly know that there are individuals and pockets of
distrust out there and we're working to resolve it.
CHAIRMAN JACKSON: What about the significance of
the concerns that are raised?
MR. KENYON: Dave, why don't you address that.
MR. GOEBEL: Madam Chairman, the significance now,
if we break all the issues that come to us and what we would
have to say is that the majority of them are personnel
issues. They're not safety significant. We bin anything
that has even the remotest connection to a plant as a safety
item.
We have no what I would consider significant
technical issues that have come to us out of the work force
into the employee concerns program. The most significant
technical issue that we're working now is being worked with
. 49
in a line organization and that's being worked within
engineering. An individual brought a concern forward and
there's been a task force set up to try and resolve his
concern and work with him to get the issues done, but it's
strictly been done within the line.
CHAIRMAN JACKSON: So your numbers are going up
but you view that as a positive sign?
MR. KENYON: Absolutely. Absolutely.
Success objective number 7, that we're committed
to achieve excellence in nuclear operations.
The principal activities are that prior to
startup, we will have defined excellence -- in other words,
a definition of excellence that we believe in, we will have
developed a plan to achieve it, we will have resolved those
issues which we conclude are important to startup, and we'll
have resource commitments which meet or exceed those of
similar well-run units.
Now I'd like to turn to the subject of schedule.
We had a --
CHAIRMAN JACKSON: Let me ask you a question.
What indicators do you use to measure excellence?
MR. KENYON: The indicators are going to be -- and
we haven't done this yet -- but the indicators are going to
be, we have defined what our standards are for excellence.
In other words, we're not going to be chasing, however we
. 50
perceive a SALP score, we're not going to be chasing however
we perceive an IMPO 1. We're going to define those
standards that we believe in and then clearly we will
measure ourselves against those standards.
CHAIRMAN JACKSON: But you have not identified
those?
MR. KENYON: We have not laid out those standards
as of today. We will do it prior to startup so that we
think we have an obligation -- you know, our management
philosophy, this leadership team believes that our challenge
is not simply to get the restart. It's not simply to get
off the watch list. Our longer-range objective is to be a
top-quartile plant, or series of plants, and thus we will,
prior to startup, define those standards, and we'll let you
know what they are. We will have measures against those.
We'll have a plan to achieve. So we're not simply focused
on what are the thousand things we've got to do simply to
support restart.
MR. CARNS: Some of it can be anecdotal too. Just
a simple example they told me people are getting, that is,
when a shift manager at unit 3 declared both diesels were
inoperable, he could have taken a less conservative route
and said I have 24 hours to catch up on surveillance that
was missed back in 1992. But to take the conservative
route, that's an excellent decision. We need to advertise
. 51
that as being a method of -- acceptable method of behavior.
CHAIRMAN JACKSON: Commissioner Diaz.
COMMISSIONER DIAZ: Yes. I'm getting a feeling in
here that -- it's a little uneasy. When you say that you're
committed to achieve it but you're not ready yet to put the
indicators out there, but, you know, there's a big ground to
cover in between those. Do you have a program that is
trying to establish these indicators, and are you pursuing
it in a manner that they will be able to be known before you
restart?
MR. KENYON: We have lots and lots of indicators
right now that are relevant to what we're doing at this
time. So I didn't want to leave you with the impression we
don't have indicators. We have book of indicators. We will
identify other indicators or the same indicators with
different goals to go toward excellence.
MR. McELWAIN: As part of each of the operational
readiness plans, we have milestones, responsibility for
people to develop individual unit long-term improvement
plans, including indicators to measure that, and they will
all be done before startup as scheduled.
MR. KENYON: On schedule, we had a productive
meeting with the NRC staff on the 17th. I think it was a
good exchange of information.
CHAIRMAN JACKSON: Do you and the NRC staff agree
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on all the restart issues?
MR. KENYON: That's a very encompassing statement.
I'm not aware of any significant disagreement.
CHAIRMAN JACKSON: Okay. I'm going to ask them
the same question. Don't worry.
MR. KENYON: I think the meeting that we had was
helpful in reaching a better understanding of the regulatory
inspection and evaluation requirements and resulting
schedule implications. I will offer the observation that
the NRC staff had its schedule as to how they see the
restarted unit 3 playing out, and frankly that was very
compatible, a high degree of congruence with our current
schedule, but it's obviously very dependent on our
performance.
We agreed to provide the NRC with bi-weekly
updates so that they're fully informed as to how we're doing
against our indicators. They get our indicators more often
than even bi-weekly.
My current overall judgment regarding our
schedules is that it's the same as what I've said
previously. In other words, I continue to expect that we
will have one ready to restart in the third quarter, one
unit ready to restart in the fourth quarter, and one unit
ready to restart in the first quarter. I need to emphasize
that ready to restart means that the -- that we, the
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licensee, have physically completed the important activities
in support of a restart decision.
It does not mean that I think the NRC will have
completed all that it needs to do in evaluating what we have
done. So this is more a definition relevant to our
activities.
Thus I continue to believe that we can restart one
unit near the end of this year, and that's consistent with
the schedule that the staff laid out.
Now, there are schedule issues which are a matter
of ongoing evaluation, and I want to just indicate to you
what some of these are.
We are in the process of developing a site
schedule which will integrate unit site and major regulatory
activities. We need this. We have unit activities that are
very close together and perhaps too close together. This
will become the official schedule, and thus what we have
referred to as unit schedules will continue, but they will
be internal schedules trying to meet or beat the site
schedule.
Work -- so that's one issue.
CHAIRMAN JACKSON: When do you expect to have that
done?
MR. KENYON: Middle of May.
The second issue is that work accomplishment
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rates, although improved, are not yet at levels which will
sustain the current internal schedules. The productivity is
coming up but it's not yet at a level that will support the
scheduling assumptions that we've got, so we clearly have to
improve productivity in order to hold the schedule that we
have.
CHAIRMAN JACKSON: So isn't it somewhat of an
oxymoron then if you say that the work accomplishment rate
won't sustain the schedule on the one hand but the units
will be ready for restart by a certain quarter of the year?
That's somewhat of an oxymoron?
MR. KENYON: No, because there's some contingency
between the internal schedules and the quarter, quarter,
quarter, but because productivity has been lower, coming up,
but lower, the contingency -- the difference between what
the internal schedule will produce and what I've said is a
high-level quarter, quarter, quarter, that difference has
decreased.
CHAIRMAN JACKSON: Have you been meeting your
schedule?
MR. KENYON: Some but not all. The other point
I'd make, and we talked about backlog, and the backlog is
starting to move in the right direction, but it is -- I
think it's also very true that the net backlog of work items
for startup is continuing at levels higher than what had
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been assumed in the schedule, and this is in part a
productivity matter, but it's also in part that we're
continuing to discover a lot of stuff. So as we work off
stuff, we're adding to what needs to be done at the same
time.
I think my overall point is that we are working to
an aggressive game plan. That's what I think we need to do.
We are constantly pushing to improve our performance, but
fundamentally the most important to us is that we meet our
standards first and schedule second.
CHAIRMAN JACKSON: Well, the things I see in the
press seem to suggest that you're really focused on the
schedule and the need to -- in your mind, to have one of the
units started by the end of the year.
MR. KENYON: Well, I'm pleased that you're making
that comment, because it gives me an opportunity to address
it.
We have -- there is a tendency on the part of the
media to focus on schedule, and I am not saying that
schedule isn't important to us. It is. But we have
repeatedly in employee meetings, you know, told -- I mean,
the last thing I want is for employees to feel that the
right thing to do is not raise a concern, the right thing to
do is to take a shortcut. I mean, that is the last thing we
want, because (a) it's wrong, and (b) it will just cause us
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problems down the road.
So we have repeatedly internally in our meetings
with employees emphasized high standards, doing what's
right, but work hard on the schedule, and I can tie this in
with my next point, which is on the financial situation of
the company.
What I want to emphasize to you, to the public,
and I've already emphasized this to employees in a series of
meetings, and this follows the company's decision to suspend
its dividend, that within a reasonable range of assumptions
-- and this is based on the actions that the company has
taken and is taking -- we have the financial support to
bring those units back without compromising our standards,
without taking shortcuts, without ignoring problems, none of
which we would do.
So however the media characterize it, I'm here to
assure you we're going to do what's right.
CHAIRMAN JACKSON: Have you had to supplement your
teams in place to try to adhere to the schedule?
MR. KENYON: Ask that again, Chairman Jackson.
CHAIRMAN JACKSON: Have you found that you've had
to supplement the teams that you have in place?
MR. KENYON: We have done -- any of the -- we
bring in people as needed, and frankly as we continue to
assess our situation, we may make adjustments between the
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units in order to make sure that the lead unit gets to its
startup point. So we're continuing to assess it is what I'm
saying.
CHAIRMAN JACKSON: Let me ask you one last
question which actually goes back around to the operator
issue. You know, a region 3 plant uncovered some problems
with let's call it operator competency, and you have these
units shut down. So how are you keeping your operators
trained for operational conditions and problems?
MR. KENYON: I'm going to give a high-level
answer, and then I'm going to ask the unit to talk. We have
simulators. They are going through the requalification
program. We need to do some intensive things prior to
startup because they will have not actually been at the
controls of an operating plant for a considerable period of
time, but a lot of that we deal with through the simulator.
Jack?
MR. McELWAIN: Yes, we're putting together an
operator refresher course outside the normal requal program
to address not just the modifications that are happening
now, because it is going to change the plant significantly,
but to make sure they're up to speed on the skills that they
need to run a plant on a daily basis, and we're developing
that now, and it will be implemented prior to restart.
MR. BOWLING: I consider this a most significant
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issue in that we are going to have to put together and we're
in the process, as Jack indicated, of working on such a plan
to insure that the qualifications are where we need to be
when we do restart.
MR. BROTHERS: Millstone 3 is consistent with
units 1 and 2.
CHAIRMAN JACKSON: Is there fidelity of the
simulator? I mean, you're making some major changes in the
plant. How are you -- since you have tied a lot of this to
simulator training -- how are you addressing the issue of
the fidelity of the simulator?
MR. BROTHERS: The design control process is very
strong in terms of the link to simulator fidelity. There
was, however, a recent audit that perhaps Dave wants to talk
about concerning simulator facility. It did uncover some
programmatic issues with simulator fidelity.
MR. GOEBEL: The recent audit that was done
possibly a month and a half or so ago uncovered the fact
that although the fidelity of the simulator was being
generally maintained very good, there was no programmatic
system in place to insure this would be maintained good. It
was maintained well by people who knew what had to be done
and the engineers would get hold of the simulator people and
tell them they needed to make changes, and do this, that,
and the next thing. As a result the simulator was kept
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fairly well up to snuff, but had you taken an individual out
of the system someplace who played a key role in it, that
back-door process would fall on its face.
CHAIRMAN JACKSON: So what are you doing about it?
MR. GOEBEL: The folks that own the simulator and
the engineering folks are in the process of formalizing that
arrangement because it also has to include training. So as
the mods are adjusted into the simulator it cycles through
training so the courses in training can be changed so that
not only does the simulator behave like the plant behaves,
but the instructors instruct to the right quality of
operation of the plant.
MR. KENYON: Quickly on public confidence, we also
realize that part of our challenge is to rebuild the
confidence of the public. The best way I know to do that is
to be totally open and candid regarding our activities, what
goes well and what doesn't. Part of rebuilding public
confidence is rebuilding employee confidence, and thus we're
committed to being very honest and forthcoming with our
employees as well.
In the interest of improving public
communications, and I just want to indicate some activities,
we've begun a series of NU-hosted community discussions.
We've conducted two thus far. The topics were employee
concerns and leadership development. The next meeting will
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be held in May. They have been well received. The last one
even ended with applause. We've preceded each of these with
an employee meeting so that we are keeping our employees
well informed. Shortly we'll be announcing the membership
of a Millstone advisory committee. This will be a
cross-section of individuals from the public with varying
backgrounds and expertise, volunteers. It will include some
of our sharp critics, and the intent is that we will
interact with this group and engage in extensive dialogue on
matters of mutual interest.
I've invited Members of the public to witness my
weekly staff meetings. I don't expect everyone to
understand everything that is said but I do expect there to
be a recognition of the sincerity, the candidness and the
commitment to high standards. We're obviously regularly
involved in media activities to discuss the status of our
recovery efforts, and we have greatly increased the number
and quality of management-employee meetings in the units and
across the site. You know, face-to-face communication is
just very important.
Results. We have been taking professionally
conducted surveys for quite a number of months, long before
I got here. The recent survey shows a marked improvement in
the believability and credibility of NU Nuclear. That is
good. We all recognize that opinion polls are just that,
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they're opinions, and what really counts is our performance.
Let me just make some closing comments.
In summary, we have a new and experienced
leadership team in place. They are aggressively addressing
the issues. We are acknowledging the problems as we find
them. We're applying high standards and a commitment to do
what's right. We have promulgated new safety standards, and
education regarding these standards is in progress. The
effectiveness of our oversight has improved, but we have
more to go. I think we have made clear progress in the area
of employee concerns, but we have a lot more to do in terms
of fully implementing the new program. We have put in place
what I think is a good corrective-action program. The issue
now is to execute it, make it work well. We are
aggressively preparing for the start of the first ICAVP on
May 27. We recognize that's a key step toward a restart
decision.
We have the financial resources to do what is
right within I think a reasonable range of scheduling
assumptions, and our belief is that public confidence in
Millstone is improving. So we would be pleased to address
any additional questions.
CHAIRMAN JACKSON: Commissioner Rogers.
COMMISSIONER ROGERS: I have nothing.
CHAIRMAN JACKSON: Commissioner Dicus.
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COMMISSIONER DICUS: I have one question, please.
In the previous briefing I think, Mr. Kenyon, you
indicated making great progress with leadership and upper
management and so forth, but I think that you indicated that
you thought you had problems in leadership in middle
management, and I notice -- I don't think today that you
addressed that particularly. If you did, perhaps I missed
it, or maybe I need a clarification. But do you still
perceive you have problems in middle management -- I think
that's a critical area -- and if so, what is the status of
addressing?
MR. KENYON: Thank you for the question. I did
mention that we had problems in middle management. I think
we have made progress on that. I indicated in my -- early
on in this presentation that the next level down from
officers, only about 25 percent are in their original
positions based on when I came.
But beyond that, we did a leadership assessment,
and I think I mentioned that last time around, but the
purpose of that was for employees -- I mean, it is fine for
us as senior officers to look down and reach some judgment
as to whether an individual is or is not doing a good job
from a leadership perspective, but I think an excellent
measure of whether or not an individual is a leader is what
the employees being led think, and thus we implemented a
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survey technique. We call it a leadership assessment.
There are 26, 28 questions, leadership attributes where the
employee can rate their supervisor on these attributes
ranging from strongly agree to strongly disagree.
Out of that, we got leadership assessment scores.
From those scores, we looked really hard at the bottom 10
percent, and quite a number of the bottom 10 percent are
either no longer at NU or not in a leadership position.
We will be doing another leadership assessment in
the June-July time frame. My expectation is that we ought
to see a very measurable improvement in leadership scores.
We will look at those who scored low and then scored low
again and, you know, was the rate of progress adequate or
not, and thus we'll continue to make changes.
So that's our -- that's a key aspect of what we're
doing on an ongoing basis, have not only our assessment of
how the individual performs, but have the employees'
assessment of how the individual is performing.
COMMISSIONER DICUS: Thank you.
CHAIRMAN JACKSON: Commissioner Diaz.
COMMISSIONER DIAZ: Yes, I'd like to go back to
the beginning, and I think I want to express my strong
support for the initial comments of the Chairman regarding
the specificity and quality of your presentation.
I definitely am not pleased with the amount of
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specific information that was provided. I don't see myself
having been better informed now than I was when you began,
and I think there is a serious issue in here, and that is
that the Commission needs to know specifically where you
stand from your viewpoint.
I think the philosophy is fine. I think you have
stated that clearly, but I think we're beyond that
philosophy at this point, and I really believe that we need
to see from you some specifics. Some of them have been
coming in the discussions, but I like to see charts, I like
to see tables, I like to see bar graphs, I like to see a
real engineering in-progress assessment of where you are.
And we don't have that.
The staff has done a much better job than you have
as far as I know in addressing where you are, and I am
disappointed. I thought that the Chairman of the Commission
was very clear to you in our last meeting that we want
specific details. We want how -- the number the issues has
been characterized. Where have they gone? How many belong
in the good management rules? How many are issues that
implies equipment? I need to see where they belong in a
progress path, and I haven't.
You know, we're going to wait now three more
months to see something. Madam Chairman, I don't know
whether there is a possibility to request in writing a
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specific response from the licensee that addresses these
issues.
CHAIRMAN JACKSON: Well, I think that's a fair
comment. In fact, what I was going to say in my closing
remarks, but I'll say it to you now, and that is that I
would have expected at least a presentation that -- with
respect to each of those objectives that I went through and
asked you questions very specifically, that you would have
told us that without my having to draw it out. That's why
in fact we've used up actually the allotted time for the
meeting and we haven't heard from the staff yet.
But it would have been the kind of information
that would have allowed us to get into the degree of
specificity that Commissioner Diaz is talking about, because
this is very similar to what we heard the last time.
You're talking about having a unit in your minds
ready, quote unquote, for restart, unit 3, and as
Commissioner Diaz says, we're not scheduled to have another
meeting until July, and you said after July 5 or whatever,
and that would be when the meeting would be scheduled.
Three months after that is October, and yet the Commission
is supposed to be in a position to make a decision.
You had also indicated to me at the last meeting
that you didn't want to be judged on what any of your
predecessors had done, but on what you had done. But we
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have to see what that is, and we haven't seen what that is.
So there is a problem there, and so unless we can see, for
whatever it is, positive or negative, in terms of the real
degree of progress, it's very difficult to see ourselves
coming to a decision point, and then to say that you're
tracking to having a unit ready by the third quarter but yet
you yourself say, and this is a quote, "That the work
accomplishment rate won't sustain the schedule," then I
don't know what that means. You tell me it's not an
oxymoron, but I don't know what that means when I don't see
specific things.
I'm not trying to, you know, drag you over the
coals. I'm trying to talk about our responsibly being able
to carry out our role in this, and high-order kind of
statements about goals are not what we're going to need in
the end to reach a decision point, and so you're going to
have to come back with something that has a much, much
greater degree of specificity if there's going to be any
movement at all, and the kinds of categorizations in terms
of the significance of the issues and really how they are
being worked and whether they are real fixes, et cetera, et
cetera, and what are the restart issues that both you and
the staff have agreed on versus a larger universe of restart
issues that you have for yourselves, what kind of scheduling
there is for those that are left over, et cetera, et cetera,
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et cetera.
I mean, we haven't seen anything like that, and
that's why a member of my staff had called to Northeast
Utilities, because when we saw the viewgraphs, then we knew
it was not going to give the Commission that kind of
information that it really needed, but no further viewgraphs
were forthcoming.
But before you speak, let me make sure that
Commissioner McGaffigan -- do you have any --
COMMISSIONER McGAFFIGAN: I have questions, but
why don't you let him --
COMMISSIONER DIAZ: I was just going to say that
we need a coherent, comprehensive, well-identified series of
issues, one by one, their correlation to a startup schedule,
or restart schedule, you know, that we can actually see, not
that you've completed, but where were you, where are you,
and where are you going in a time scale. This will allow us
to do our job, and then we can consult with the staff and
say where are we, where do we need to go? Because this is
an important issue, and we want to give it the proper
attention. I personally don't have the information to
proceed with it, and I would like to see it in black and
white.
CHAIRMAN JACKSON: And there's an issue for me of
allocation of staff resources. We have this special project
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office, but, you know, we have many things to do. Having
this process and have us discharge our responsibilities
relative to it properly requires our having the kinds of
information that Commissioner Diaz is talking about and I've
been talking about.
MR. KENYON: If I might respond, first of all,
I'll accept responsibility for that. Earlier drafts of our
presentation had quite a number of charts in them and we
concluded that -- and again, I'll take responsibility for
it -- but we concluded that given all the issues that we
thought were relevant and the fact that any particular chart
can and typically does require a fair amount of explanation,
that we could not adequately cover the spectrum of issues
that we thought needed to be covered in the kind of detail
that gets down to a lot of charts.
Now, we have the charts, and I want us to be
supportive of what you need, so --
CHAIRMAN JACKSON: Well, you can't get a decision
out of us if you're not.
MR. KENYON: I don't debate that. The question
that I have is, would the appropriate -- and I'm just --
this is off the top of my head -- but would the appropriate
response be that we have one meeting that narrows down to
just one of the Millstone units and that we talk about in
detail to satisfy --
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CHAIRMAN JACKSON: We may need to discuss that
relative to the next meeting we have.
MR. KENYON: My only concern is that -- we made
the judgment, right or wrong, that in 45 minutes, employee
concerns, oversight, you know, all the things --
CHAIRMAN JACKSON: No, that's true. But the point
is, you could have shown us a ratio of self-identified
issues to externally identified issues, how the trending was
going. You could have identified to us for us out the 6,000
issues how have they been parsed down in terms of the number
that have resulted in condition reports and where do they
stand in terms of LER's, how does it affect each unit, and
where are they in working on those units.
MR. KENYON: And those are isolated --
CHAIRMAN JACKSON: You could have had the
information relative to the maintenance rule classification
of systems and how that tracks into the issues and the work
that has to be done on the systems, and how much of them
require physical work or not.
I mean, those kinds of things with some judgment
applied, without inundating us with sheets of paper, are
helpful.
I mean, the Commission -- yes, the staff is going
to work these things in great detail, but the Commission's
going to have to reach a decision that's predicated on what
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you present to us and how the staff says it sees what you're
doing, and for that, it needs more robustness, and if that
requires your working with our SECY or with my office
directly the next time so that we can get the degree of
specificity that each of the Commissioners feel they need to
have, then we'll do that, and whether we'll do it on a
per-unit basis or on an overarching basis, we'll decide, but
clearly, you know, going forward, we have to do it a little
bit different.
COMMISSIONER DIAZ: Could we just get a written
report prior to a meeting, like in the next 30 days? Could
we have a report sent up to us that then we can have time to
look through it and maybe provide some questions that will
be channeled through the Chairman's office to you that would
allow us to get into this issue in depth? Is that possible?
CHAIRMAN JACKSON: Yes, that's possible.
We may submit you some questions that we want you
to address for us.
MR. KENYON: Well, clearly we want to be
responsive to what you need, and our challenge is to present
you the information in a format that allows you to look at
it to the degree that you want, covering a fairly wide range
of issues. I'm happy to do that. We just -- again, I'm
repeating myself.
CHAIRMAN JACKSON: Okay. That's fine.
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MR. KENYON: We made the judgment that for a
45-minute meeting, we backed away from the degree of detail
that we started with.
CHAIRMAN JACKSON: Right. But we don't want to
end up with bones and no meat in the interest of
streamlining, because we've actually already spent an hour
and a half because we didn't have any meat, and we had to
kind of dig through it and pull it out.
Commissioner McGaffigan.
COMMISSIONER McGAFFIGAN: I'd like to associate
myself with both the Chairman and Commissioner Diaz, and one
thought I have from the Congressional process, we will have
hearings on the Hill that are an hour and a half long and
vast amounts of information are provided to us through our
staff -- you know, through the staff, which I once was, a
week or so ahead. We get more and more information, and
then that allows the individual Members of Congress to focus
on issues with well-informed questions, rather than trying
to draw the information out.
So I think there has to be some mechanism --
CHAIRMAN JACKSON: I think that what we need is
more than just the slides. We need some backup
documentation that needs to come to us in an earlier time
frame, and err on the side of more rather than less.
COMMISSIONER McGAFFIGAN: If I could also ask a
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question.
You went through the schedule impacters, as you
saw them. You didn't mention the ICAVP itself. I mean,
once it gets started on May 27, the unit 3, and I guess it's
June 23 you said for unit 2, there's another element of
uncertainty that gets added at that point, namely what are
they going to find and how many issues are you going to --
does your schedule presume that they'll find little, find a
lot, find somewhere in between? How do their findings
affect your post-ICAVP schedule?
MR. KENYON: Our assumption is not that the ICAVP
contractor won't find anything, but our assumption is that
the ICAVP contractor will not find major significant generic
issues. Otherwise we haven't done our job.
COMMISSIONER McGAFFIGAN: And that's at the heart
of predicting what you did with regard to when units will be
ready?
MR. KENYON: Yes.
COMMISSIONER McGAFFIGAN: Is the overlap between
the four-week delay -- the last time we talked, I think you
were still in a horse race between the units and -- its
turned into a little bit of a procession, but with one, you
know, still -- the Kentucky Derby coming up -- one's still
got a shot at coming out ahead of the other. Is that
overlap with only a four-week delay workable? You implied
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that that was an issue. Or how do you -- or is it possible
that unit 2 will end up ahead of unit 3, and that's why
you're keeping them that close? What is in your mind?
MR. KENYON: What's in my mind is that it is
important that we get one unit running as expeditiously as
we can. There's only a modest difference in schedules
between unit 3 and unit 2. We are assessing the
manageability of that. Our understanding from the staff is
that they can, in fact, support two ICAVPs in parallel and
consequently our desire is, since we don't know what --
totally what's going to be found or whether we're going to
find a show stopper, our desire is to keep this unit 2 as
close to unit 3 as we can such that if there is any
stumbling, unit 2 can be moved forward. So that is the
thinking.
COMMISSIONER McGAFFIGAN: So that's the heart of
the philosophy?
MR. KENYON: Yes.
COMMISSIONER McGAFFIGAN: Thank you.
CHAIRMAN JACKSON: Thank you.
I think we'll go on and hear from the NRC staff.
Thank you. Because we do have another Commission meeting.
Mr. Callan.
MR. CALLAN: Good morning chairman, commissioners.
With me at the table are Sam Collins, the director of the
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Office of Nuclear Reactor Regulation, Bill Travers, the
director of Special Projects Office, Wayne Lanning, the
deputy director for inspections for the Special Projects
Office, and Gene Imbro, the deputy director of Independent
Corrective Action Verification Program.
This is the second of our planned quarterly update
briefings. As you recall, the Special Projects Office was
established -- established within NRR in November 1996 to
focus on the inspection and licensing activities required to
support an NRC decision on the readiness for restart on each
of the three Millstone units. Dr. Travers will lead us
through the staff's briefing.
MR. TRAVERS: Good morning. Our principal focus
today to is to provide the Commission with an update
principally focused on our activities and planning for
assessing improvements which the licensee will need to
accomplish before there's any consideration of a restart
authorization.
In particular, and in this overview slide, I point
out that I'd like to touch on our restart assessment plan,
the independent corrective action verification program, a
status report on employee safety concerns program issues,
licensing issues which have been identified as requiring or
needing to be addressed prior to restart, and also a sense
of the staff's own project planning and the steps that we
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see as fundamental and the kinds of NRC activities that need
to be scheduled before we can get to the point where we can
come to the Commission with a recommendation.
Before proceeding to go discuss the topics listed
here, however, I would like to make a brief comment on our
current view of the status of licensee activities at
Millstone. I think you have heard quite a lot from them in
this morning's session, and most of indicates that it's
quite early yet in the process. But since the NU management
restructuring that took place in October, we have seen
positive action in a number of areas.
The licensee, for example, has initiated program
improvements in the area of quality assurance -- and I
emphasize initiated -- program improvements in the area of
quality assurance, procedure upgrades, self assessments and
prioritization, scheduling and completion of work
activities.
At unit 3, they have provided us with schedules
for resolving restart issues which are identified in our
restart assessment plan. These schedules thus far are
generally being met and the licensee submittals have been
determined to be acceptable.
If I can give you a specific in that regard, I
would point out that we have about 87 line items, restart
assessment plan on our significant items list. They have
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completed -- actually, they have submitted and we have
completed a close out on 12 to 14 of those, and they have
generally done it on the schedule that they told us they
would do it.
CHAIRMAN JACKSON: When you say close out, you
mean that if there were any significant physical work to be
done, it's been done and all the documentation is done?
What do you mean when you say close out?
MR. TRAVERS: Close out can range from it actually
being completed to our having addressed the engineering
package that goes along with it. And I'm not sure, I'd have
to look at each individual item.
CHAIRMAN JACKSON: I mean, you have a specific
definition for what close out means?
MR. LANNING: Let me try. The completed packages
must have completed the identified corrective actions for
that issue before we start to inspect it.
CHAIRMAN JACKSON: And when you say that you've
closed out twelve items, that means you've finished your
inspection?
MR. LANNING: We have completed our inspection of
those items.
CHAIRMAN JACKSON: And you have reached a
documented conclusion with respect to it?
MR. LANNING: Those are documented in our
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inspection reports.
CHAIRMAN JACKSON: Okay.
MR. TRAVERS: NU, as you heard this morning, is
also in the process of establishing their employee safety
concerns program and in carrying out their review of the
design licensing basis of safety related or risk significant
systems at all three units. Additionally, they have been
implementing the initial requirements of the NRC orders for
establishing an independent corrective action verification
program and a third-party organization to oversee their
employee concerns program.
As I indicated at the start, though, it's quite
early in the process. In fact, the most significant volume
of the information that we will need to review before coming
to the Commission has yet to be reviewed because principally
their program is not far enough along to allow us to begin
to initiate many of the very significant inspection
activities that we have planned.
CHAIRMAN JACKSON: Now, I note that there are 22
licensing issues required for restart; is that right?
MR. TRAVERS: There are varying numbers of
licensing -- and I was going to cover that in --
CHAIRMAN JACKSON: Okay. Fine.
MR. TRAVERS: Okay. If I can turn now to touching
on the status of the staff activities and give you some
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specifics as to where we think we are relative to our
activities and planning. At the last Commission meeting, we
described our use of manual chapter 0350, and I don't plan
to go through that again, but suffice it to say it's really
a tool that we're using to put ourselves in a position of
having compiled, identified and ultimately document the
issues that we think have a nexus to the restart decision.
The key issues we have identified have been
published in our restart assessment plants for all three
units. In fact, since our last meeting, we revised the
restart assessment plan for unit 3 and have published the
first restart assessment plans for both units 1 and 2.
The reason we had one for unit 3 last time and not
one for unit 1 or 2 is previously, they were in the mode of
identifying a lead unit; that was 3. At the last time you
met with NU and us, they had identified a more or less
parallel track. So we began efforts to expedite our
compilation on these issues.
The restart assessment issues are generally
covered within the topical areas that I've listed on the
slide. Today, I plan to focus updates for the first 3
indicated areas, but I don't mean to underemphasize the
extent of the number of issues that are contained in the
other areas, for example, corrective action programming. We
heard some from them today on that. Our significant items
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list, I may touch on some numerics associated with how many
we have and so forth. But I --
CHAIRMAN JACKSON: I'd also like you to talk about
personnel training and performance.
MR. TRAVERS: We can certainly talk about the
issue. In fact, maybe we should just do that now. You had
a discussion earlier this morning about a number of issues
that were identified by the licensee and reported to us
regarding their operator training and licensing program,
their qualification program.
In the short term, the staff has issued a
confirmatory action letter which really documents the
commitments they've made to reassess root cause and assess
the status of the individuals who are currently licensed at
Millstone, and they've also committed to develop a
corrective action plan as well.
We have been getting some information from them
periodically in conformance with their obligation stated in
the commitments they've sent to us.
In the longer term, though, and I think it's
important to state, we have a specific element of our
restart assessment plan that envisions the use of a special
inspection to assess the status of the operator, In fact,
non-licensed training program at Millstone as well. So we
have a number of issues that speak to that.
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I think another aspect of our program that really
addresses these issues as well, and I'll talk about it a
little more later, is the fact that we expect to carry out
an operational safety team inspection, which is designed to
assess the readiness for NU to operate the plant towards the
end of the process. It's something that we -- typically
uses six to eight inspectors for a couple of weeks on site
to, further along in the process, closer to restart, give
ourselves an assessment of where they stand.
CHAIRMAN JACKSON: Let me ask you one other
question about work planning and control.
MR. TRAVERS: Yes.
CHAIRMAN JACKSON: Is that going to also look at
issues of radiological controls? I mean, there was this
recent confirmatory action letter to Haddam Neck. Are we
going to be taking a look to see that there aren't any
similar issues at any of the Millstone units?
MR. TRAVERS: We are aware of the problems at
Haddam Neck and they are significant ones that are being
addressed outside my organization.
CHAIRMAN JACKSON: No, I'm saying they're being
addressed for Haddam Neck. I'm asking you will you be
making an assessment in the same area for Millstone as part
of your restart?
MR. TRAVERS: The answer is yes, and it's
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currently part of our core program to look at radiological
programs. But I will tell you that we have not evidenced
the kinds of problems that you've seen at Haddam Neck.
There have been a number of incidents, failure to wear
monitoring equipment and small items that keep that issue in
the forefront of our thinking. So it's an item that will
continually be addressed as we go along.
CHAIRMAN JACKSON: Okay.
MR. TRAVERS: Before going forward to talk about
the first three items that I've indicated, I thought I'd
make mention of the fact that we are continuing to meet our
commitment to make our process a very public and open one,
and in that realm, we have been conducting every four to six
weeks a meeting specifically with the public in addition to
the meetings we've been carrying out that are open to
observation between us and the licensee. Typically when we
do those, we go in the evening so that people from attend,
and we present a status report from our perspective to
members of the public. We haven't gotten any applause at
those meetings, but I think it's worked rather well to
continue to give people a sense of the issues as we see them
and some of the success as well, as we see it.
Ultimately, of course, the whole process is
designed to put us in a position to have documented a basis
for coming to the Commission with potentially restart
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authorization.
A significant element in our restart assessment
plan is the conduct of an ICAVP or an independent corrective
action verification program. The ICAVP is required by NRC
order and it's intended to help verify the licensee's
efforts as a starting point to confirm its design licensing
basis. It's really a verification step; it's not viewed as
part of the regulation process.
The principal elements of the NRC activities
related to the conduct of the ICAVP are listed on this
slide. By order, for example, the NRC must approve the
organization proposed by the licensee to carry out the
ICAVP. By NRC order --
CHAIRMAN JACKSON: You have done that.
MR. TRAVERS: And we have recently done that for
units 1 and 3, and the contractor proposed and improved is
Sargent & Lundy. We have under review a proposal to use
Parsons Power or Parsons Engineering at unit 2. The NRC, by
order, must also review the audit plans prepared by those
ICAVP contractor organizations, and we have under review
audit plans from both Sargent & Lundy and Parsons.
CHAIRMAN JACKSON: So audit plan review and
approval doesn't presuppose approval?
MR. TRAVERS: That's right. It does not. In
fact, we expect, based on what we've seen to date, that
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there will be modifications prior to NRC approval of the
audit plan.
Additionally, in the context of our own
responsibilities related to ICAVP, we, the staff, will
select the tier 1 systems, and I can refresh you as to what
tier 1 and tier 2 and tier 3 mean, but let me just state
that staff will select the systems that will be encompassed
within the third party contractor review. It's a sample and
there has been some concern about keeping them close and
who's going to pick them and who makes the judgment, and
it's going to be us.
CHAIRMAN JACKSON: How many?
MR. TRAVERS: And how many, exactly right.
If it's helpful, I could briefly state that the
approach we're using for our expectation of the contractor
in carrying out the ICAVP is that it's going to be a three
tiered approach. The first tier, at least for unit 3, we've
identified that four systems would be evaluated in a deep
vertical slice review of the design, all of the design
aspects of those systems.
In tier 2, we focus on critical design aspects
needed to insure the functionality of systems relied upon to
mitigate the consequences of accidents. So it's less deep,
but it cuts across and captures critical design aspects of
many systems.
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In tier 3, we expect the contractor will review
the implementation of various change processes that are used
at Millstone to modify the facility.
So you can think of it as layered. The licensee
is going to carry out its program; the party contractor
under the auspices of ICAVP order will carry out a
verification step; and our efforts listed further on this
slide, at least the most extensive piece of our efforts will
involve NRC conducted inspections.
CHAIRMAN JACKSON: Now, will we be doing that at
Sargent & Lundy or we're doing that at Millstone?
MR. TRAVERS: Both. And I can explain that. The
NRC-conducted inspections, and there are four of them at
each unit as currently plan, involve team inspections. The
first one involves a focus on the conduct of the ICAVP
contractor, Sargent & Lundy.
Since Sargent & Lundy expects to do much of its
work in Chicago, that's where we'll go. We may complete
some initial walkdowns on the site, but much of what we
expect is going to happen is going to be happening in
Chicago. And I've given you an indication of the
composition at least in terms of size and the duration
period for -- just to give you a sense of the extent of the
effort that we are planning for the ICAVP review.
CHAIRMAN JACKSON: Commissioner McGaffigan has a
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question.
COMMISSIONER McGAFFIGAN: The four weeks
implementation inspection, if the ICAVP for unit 3 starts on
time on May 27th, is that the clock starting for you, or
does it start with some delay? Or how --
MR. TRAVERS: There are linkages and I'll be glad
to explain them. The first linkage is, in the onset of
ICAVP, is that the third party contractor review won't start
until the licensee has completed at least 50 percent of the
group 1 systems as defined by the maintenance rule, and
those, of course, are safety related and risk significant.
So a flag has to go up in terms of what they've been able to
achieve in their readiness for beginning the ICAVP
inspection. So there is some overlap; it's not entirely a
series event.
Our effort is one that -- Gene, you might want to
explain the linkage there.
MR. IMBRO: Well, the implementation inspection as
planned will occur when the ICAVP contractor is about a
third or halfway through their reviews. And the idea of the
implementation inspection is to assess their implementation
of the audit plan that we approved, but I would also point
out that it's going to be not a programmatic look, but a
technical review where we will actually look at products,
design products, calculations that the ICAVP contractor has
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reviewed and assess whether or not we find additional
problems that are there that perhaps they have missed. So
it's an over-check on the thoroughness of their review.
So, again, that's going to be about halfway
through, and we anticipate for unit 3, that would be
sometime in the July time frame.
COMMISSIONER McGAFFIGAN: So in July, this four-
week inspection would occur?
MR. IMBRO: That's right.
COMMISSIONER McGAFFIGAN: What are the dates for
the other three, if -- I know it's hard.
MR. IMBRO: They're all somewhat tentative at this
point, but the out-of-scope system review will be conducted
after the licensee completes their configuration management
plan for the particular unit. So for unit 3, to date,
that's been stated as July 14th. So sometime July 14th or
shortly thereafter, we would actually do an SSFI type
inspection on a system that's part of the -- one of the
systems that's either group 1 or group 2.
CHAIRMAN JACKSON: How are you going to make
decisions? I notice you don't put a S on that. You don't
put an S on out-of-scope systems.
MR. IMBRO: Well, it's really only one system.
CHAIRMAN JACKSON: I know. And I'm saying, so how
do you decide on expanding scope or potentially expanding
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scope?
TRAVERS: We have established a success criteria
and termed it, quote, unquote, a defect for lack of a better
word. And fundamentally, it relates to an expectation that
the licensee's program will be or should be successful in
eliminating issues that might be uncovered in our subsequent
steps that put their unit outside of its licensing basis.
We intend, if we find items of that sort, to look
at the significance of those items. For example, we would
really not expect, and we might consider it a significant
finding if we found an issue that raises to the level of an
unreviewed safety question.
So the success criteria that we have in mind in
our verification phase is one that hopefully documents that
their effort, Northeast's effort, has been successful in
eliminating areas where their plant is outside of its
licensing design basis.
CHAIRMAN JACKSON: So let me understand. When you
say at both, you mean you will go to Sargent & Lundy along
about the period you say, assuming everything tracks
according to schedule, and you review what they've done?
MR. TRAVERS: Yes.
CHAIRMAN JACKSON: But you're going to do your own
SSFI at the station?
MR. TRAVERS: That's right.
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CHAIRMAN JACKSON: And you're going to do it on
the same or different system, or that's to be decided?
MR. TRAVERS: And I can describe that on this
slide.
CHAIRMAN JACKSON: Okay.
MR. TRAVERS: The second inspection that I've
indicated lists an out-of-scope system inspection. That
would be a system review, a deep vertical slice, that would
be a system outside of the scope of what the ICAVP third
party contractor --
CHAIRMAN JACKSON: I understand.
MR. TRAVERS: But certainly within the scope of
what NU has had to do in assessing itself.
CHAIRMAN JACKSON: Okay.
MR. COLLINS: And that's the intent, Chairman, is
to have able to have that view, be able to get NU's work
without that additional --
CHAIRMAN JACKSON: Without that. And then what
the in-scope means, it's what the ICAVP has done, but you'll
do our own independent look at it.
Mr. COLLINS: Exactly.
CHAIRMAN JACKSON: And so there's a cross check.
MR. TRAVERS: On that line, I'll just point out,
because it is a bit hidden, there's a notation about tiers 2
and 3. We expect to do something similar in an evaluation
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independent from what the ICAVP contractor has done in those
areas as well.
COMMISSIONER McGAFFIGAN: Could I get back to the
question about timing on the last --
MR. IMBRO: I offer that because I think for the
in-scope system, timing would be after the ICAVP contractor
has completed its work. So it's necessarily after they've
done their four systems.
COMMISSIONER McGAFFIGAN: I'm using arithmetic
here. Is that September? You said in July, you thought
they'd be a half to a third of the way through, and you go
in for the four weeks. Is the expectation that Sargent &
Lundy would be finished in --
CHAIRMAN JACKSON: See, it really is a linked
system. I think that's what you're trying to tell us.
MR. IMBRO: That's exactly right. As I recollect,
Sargent & Lundy had proposed initially about a 14-week
duration for their reviews, so that would put completion of
ICAVP something like the end of August or early September.
MR. TRAVERS: Perhaps it would be helpful to flip
to the schedule slide and give you evidence of --
MR. IMBRO: Slide 10.
MR. TRAVERs: Slide 10. And it's our project
planning schedule. And basically this slide, you know,
presents our current best effort to project a schedule based
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largely on information that the licensee is projecting about
its ability to accomplish work.
If you look in the context of Commissioner
McGaffigan's question, the most relevant lines are the first
four, the first one being the dates or duration over which
the licensee's effort, termed CMP, will take place.
The next line is the current projected date for
initiation and completion of the ICAVP third-party
contractor effort, and you can see there's overlap based
again on this 50 percent group 1 system completion linkage.
The third line gives you an indication of the
duration and the initiation and expected completion of our
effort to carry out inspections.
The fourth line, just to finish, is a time frame
over which we expect be in a period of in-office review of
some findings and the final documentation.
CHAIRMAN JACKSON: But this is all predicated on
the schedule the licensee has laid out to you and they're
actually stepping their way through that schedule.
MR. TRAVERS: Yes. It's based on that and one
other significant assumption, and that is that what we find,
what the ICAVP contractor finds firstly and what we find in
our own verification effort is largely successful and the
success criteria generally met.
CHAIRMAN JACKSON: Does that answer your question?
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COMMISSIONER McGAFFIGAN: Yes.
MR. TRAVERS: Again, these are significant
activities. They're not 100 percent reviews of what the
licensee is having to go through at Millstone, but we think
the program will give us a high level of confidence that we
will --
CHAIRMAN JACKSON: That, coupled with the 0350.
MR. TRAVERS: Yes. This is just a piece of it.
Just to give you a little bit more detail on the
kinds of resources and sort of the make up of the kinds of
inspections that we expect to complete at Millstone, we have
been carefully planning our effort. There is a potential
for significant NRC resources to brought to bear and used in
connection with these projects.
Currently, our planning base is to field two 13-
person inspection teams essentially in parallel. This would
support ICAVPs at two units, as Mr. Kenyon indicated
earlier.
CHAIRMAN JACKSON: So it's one team per unit, and
so de facto focusing on two.
MR. TRAVERS: That's the current plan, yes.
CHAIRMAN JACKSON: And you would switch over.
MR. TRAVERS: We considered the need to plan for
three, but largely based on uncertainties in the licensee's
own schedule and admittedly impacts to our own program, our
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planning base right now is to field two teams.
CHAIRMAN JACKSON: What regions are supporting
these two?
MR. TRAVERS: Region I is not looked at for
resources in connection with our ICAVP oversight.
CHAIRMAN JACKSON: So this is -- the Region I is
excluded --
MR. TRAVERS: Correct.
CHAIRMAN JACKSON: -- from either -- from any
team.
MR. TRAVERS: Except to the extent that they've
already given up people like Wayne Lanning and Jack Derr and
all of the residents to our temporary spent -- yes -- spent
fuel special projects office.
So Region 1 has already committed resources to our
efforts in that regard and, of course, many activities for
closing out issues will be supported by region-based
inspections. So there's quite a lot of activity that we're
looking to Region I to for continued support.
MR. CALLAN: Chairman, that's an important issue,
and we're keeping a close eye on the impact that this
resource expenditure is going to have on the other regions.
It will have an impact on Regions II, III, and IV.
COMMISSIONER DIAZ: Could I ask what is the
present impact? Right now, you have deployed people from
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the regions to these efforts. Is that actually curtailing
our ability to perform core inspections? What is that issue
now even before going to this?
MR. CALLAN: Commissioner, as part of the
solicitation for resources from the regions, they were asked
to itemize expected impacts, and I'll have to defer to Bill
or Wayne to give you some examples of the types of impact
that they expect.
MR. TRAVERS: Well, we have gotten a -- in terms
of additional support, we're already utilizing some Region I
resources, but in terms of identifying additional support
for ICAVP in particular, we actually asked the regions,
given certain assumptions about the numbers of people who
would be utilized, what their assessment -- the impacts of
their program would be, and they largely fell in the realm
of discretionary inspections, maintenance team inspections,
deferrals, but not core. Not core.
COMMISSIONER DIAZ: Okay. I understood that --
and maybe I misunderstood -- that there was some impact
already going to be felt this quarter on core inspections
because of deployment from the regions.
MR. COLLINS: That has not been expressed to us,
Commissioner. The way the process was envisioned -- and I
also want to be responsive to a complete answer to the
Chairman's question about the other regions. As Bill Callan
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indicated, we went out with a solicitation based on a worst
case man loading, which was three teams, knowing that some
of those resources would be coming from other offices
besides the regions, including NRR, AEOD and Research.
We have had to revise those numbers and we're
further revising those numbers based on the availability of
resources within NRR and AEOD without impacting the region.
Our ultimate goal is to minimize the impact on the regions.
The responses we have received have varied. We
made a decision up front that we would provide for a minimal
impact on Region I. We have since concluded, based on the
inputs from the regions, that we would also have a minimal
impact on Region III. That's because primarily of the plant
situation in Region III.
So the preponderance of resources are coming from
Region II and Region IV. We have about half the amount of
resources that we originally proposed coming from the
regions. We have made up that gap with resources from NRR.
At this time, we have no indication that we are reducing the
core inspections, the core themselves. They are at the
contributing regions.
Now, there was a view if we went with three
inspections at one time and we eliminated Region I and
Region III from consideration, that impacting the core was a
possibility; but at this time, based on the current schedule
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and the loading from the regions, we do not envision that.
COMMISSIONER DIAZ: Well, I'm sure you're very
concerned about not decreasing operational safety
inspections in the other regions with this work. You know,
I think it's a very important issue, and there's a time
problem in here. You know, you can do these things for a
small period of time. If you do them for a large period of
time, you start covering holes and not doing it.
Thank you.
MR. CALLAN: I'd like to add one other perspective
to this issue. As you know, both Sam and I both managed
inspection resources in the region a few months ago, and we
contributed a fair number of inspectors to support several
large team inspections, Maine Yankee, Millstone team
inspections, and a large inspection at Dresden. And it's my
experience that the inspectors that come back from those
efforts are far, far more useful to the regions than before
they went.
Participation on a high level team inspection like
this, in my view, is more beneficial than just about any
kind of training course that we could come up with to
develop them as inspectors. Obviously, if you carry that
too far, it will have negative effects.
CHAIRMAN JACKSON: When you're talking about these
teams in terms -- and you note that -- and you don't have to
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go into, unless someone wants to ask you, great detail about
the team position. But -- and you specify an amount for
contract support. In terms of the team composition, what's
the breakdown in terms of contract support versus NRC staff?
MR. TRAVERS: One other means we're using to
minimize NRC program impacts is to utilize contractors. If
I took a typical team composition -- in fact, I'll use the
first team, the one we're putting together for Unit 3 as an
example of that. Typically, the team leader and the system
leads would be NRC-led employees, and we have contractors
currently identified for team 1 for mechanical systems,
electric power, instrumentation control and piping and
support. Again, NRC staff would be used in the operations
assessment, those last two.
This is really viewed as a value added process.
We're utilizing contractors who have significant experience
in design, and so we're taking advantage of past experience
in identifying some of those people who have supported us in
the past.
CHAIRMAN JACKSON: And so then the 16 FTE staff
effort beyond that, that's for --
MR. TRAVERS: That's a total rack up, if you will,
of the NRC staff resources that would be called into play
sometimes for the --
CHAIRMAN JACKSON: Okay. To support all -- the
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three units?
MR. TRAVERS: That's right.
CHAIRMAN JACKSON: Okay.
COMMISSIONER DIAZ: This is only for the ICAVP?
MR. TRAVERS: That's correct.
COMMISSIONER DIAZ: What is the total effort?
MR. TRAVERS: I don't have a projection.
COMMISSIONER DIAZ: It would be nice to have it
sometime.
MR. CALLAN: We don't count management resources.
COMMISSIONER DIAZ: Maybe you should.
MR. TRAVERS: Moving on, I thought I would give
you just a quick status of some of the things since we had a
list last time that indicated what we hoped or expected we
would achieve. We have been meeting with members of the
public to obtain input, as we said we would, on several
things, on the proposed ICAVP contractor that was submitted
by NU, and on the proposal to utilize Parsons Power at unit
2.
We've actually completed, as the Chairman
indicated earlier, an organizational approval for Sargent &
Lundy for units 1 and 3, and I think significantly I'd like
to point out that we got a number of comments from the
public and we, in our approval, took efforts to address
those in the actual approval.
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Principally they related to questions about
independence, was the organization truly -- could it be
truly viewed as independent from Northeast as opposed to
technical qualifications and that sort of thing.
Lastly, at least on this slide, we carried out
subsequent to our organizational approval an interview of
the Sargent & Lundy team members to get a sense of their
technical confidence --
CHAIRMAN JACKSON: So that was actually part of
the approval process for the organization of their audit
plan?
MR. TRAVERS: It actually followed, but there was
certainly linkage. We looked at organizational approval in
our interviews as related but somewhat separable. So we
traveled to Chicago and met with the proposed team members
subsequent to the overall --
CHAIRMAN JACKSON: If you had found some egregious
problem, you would have --
MR. TRAVERS: I would point it out right now.
CHAIRMAN JACKSON: -- post facto somehow had them
removed?
MR. TRAVERS: Yes.
CHAIRMAN JACKSON: Tell me about the NEACC's
observation. What did they have to say about the
organizational approval process?
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MR. TRAVERS: Again, that's the state's chartered
Nuclear Energy Advisory Council. And we have a memorandum
of understanding with that group to actually participate or
at least observe significant aspects of our process related
to ICAVP and other Millstone oversight.
The co-chair of that group, Terry Kincanen,
represented -- an elected official of the state, traveled
with our team to Chicago and sat in on the interviews and
some discussion of the audit plan and, in fact, we expect
some level of participation as we go forward, perhaps in
inspections and so forth, at the discretion of NEAC.
They have some people who are quite technically
competent, and they may decide that they would like to
observe some of the work we do in carrying out our
inspections.
CHAIRMAN JACKSON: Have they had any initial
observations or comments?
MR. TRAVERS: In fact, I believe I saw a draft
press release that was issued by -- so I hesitate to say. I
don't know if ever was finalized. Maybe Gene knows.
MR. IMBRO: Well, I've only seen the draft also.
I'm not sure if it was finalized. It was my understanding
that Ms. Kincanen was going to present that to a meeting of
the NEAC about a week or so ago. But I think it would be
fair to say, I think it wouldn't be out of line in
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characterizing Ms. Kincanen's at least impression was that
the ICAVP, at least in her estimation, was very thorough and
far-reaching in scope.
CHAIRMAN JACKSON: Okay.
Dr. Travers.
MR. TRAVERS: Another important aspect of NEAC
that we mentioned last time but I'll briefly make note of is
that we have and are working with them to give them an
opportunity to perhaps pick as many as one or two systems.
We aren't just turning over that responsibility 100 percent
to them; we expect to provide them with a list of systems
that we think are appropriate and could be selected. And
this is largely to address a question and a concern that
we've had in some of our public meetings about the secrecy
or how well kept the actual systems will be since they're
only samples, a small number.
What do we expect to do in the next three months
relative to ICAVP? Well, we expect to complete our review
of the Sargent & Lundy audit plan for units 1 and 3. We
expect to complete the staff review of the Parsons
organizational proposal. We also expect to complete the
staff review of the Parsons audit plan for unit 2. We also
expect to carry out our interviews with the Parson team
members similar to what we did with Sargent & Lundy.
Lastly, if the schedule holds, we expect to begin our own
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first inspection at unit 3 of the implementation. You know,
this is one where we would largely go to Chicago to effect a
review of what the contractor --
CHAIRMAN JACKSON: You expect that to be toward
the end of that period?
MR. TRAVERS: That's correct. It right now looks
to be the last week of June, first week of July, according
to the linkages in the current schedule.
CHAIRMAN JACKSON: Okay.
MR. TRAVERS: Next slide.
CHAIRMAN JACKSON: Yes, Commissioner?
COMMISSIONER McGAFFIGAN: Could I ask, on unit 2,
just outside -- if they stay on schedule, on June 23rd, just
outside that three-month window, we're talking July 23rd,
three months from today, would you be -- is the plan at the
moment to be able to give us, at the next meeting, a project
planning schedule for unit 2 as well and will you be ready
if they're ready to start at the start of August?
MR. TRAVERS: Yes. In fact, when we get to the
schedule, I can mention what the dates would be for unit 2.
COMMISSIONER McGAFFIGAN: Okay.
MR. TRAVERS: But that's the objective of our
planning now, is to be prepared to field two teams when they
-- Northeast -- say they'll be ready to begin those
inspections.
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I'd like to turn now to a brief status report on
our activities related to employee safety concerns issues at
Millstone. Of course, as you recall, a separate NRC order
was issued relating to employee safety concerns, and a key
element of that order requires Northeast to hire a third
party organization to oversee Northeast's program to address
employee safety concerns.
Since our last meeting with the Commission, we
have met publicly with the public to obtain input on both
the proposed third party organization which has been
proposed and a submittal to NRC of the licensee's employee
safety concerns program plan. So we've met with the public
and had an opportunity to brief them on these proposals and
documents and soliciting comments.
We've carried out an interview of the third party
organization team members. I should point out that we
approved Little Harbor Consultants as the third party
oversight for employee safety concerns, and we've carried
out an NRC staff review of the Millstone employee safety
concern program plan and provided Northeast recently, just a
day or two ago, with our comments on that plan.
I should point out significantly that we've begun
our planning for a special inspection and our thinking on
what we really need to look at to make a judgment ultimately
prior to coming to the Commission with a recommendation on
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employee safety concerns, and I actually have a backup
slide, if you're interested in seeing it, but if you're not,
I will take advantage of --
CHAIRMAN JACKSON: Sort of take advantage and keep
moving, right.
[Laughter.]
CHAIRMAN JACKSON: Let me just ask you this
question. In terms of your reviewing the Millstone employee
safety concerns program and providing comments, were there
any significant comments that you had to provide?
MR. TRAVERS: Well, I'll point out an important
aspect in sort of an administrative sense, the order
requires NRC review but not approval of that plan. But in
direct response to your question, we did point out a number
of issues that we felt needed to be better fleshed out in
their program plan for employee safety concerns.
Much of what we've received in their initial
submittal includes an outline of specific aspects of their
program that need further development. They have recognized
that they've -- they've included some key attributes that
would be necessarily incorporated into that plan, but we
haven't seen that plan yet. So it is, in some respects, and
I think Mr. Goebel pointed out, it's developing as we speak.
So we need to look further.
CHAIRMAN JACKSON: Can you give your own
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assessment or do you feel comfortable, you know, summarizing
the number and significance of allegations, any trends that
you see to this point?
MR. TRAVERS: In terms of -- and I'll let Wayne
Lanning speak to this in more detail, but in terms of
overall rate of NRC receipt of allegations, it's been
tracking fairly steady, still on the order of four or so a
month.
Maybe, Wayne, you would like to add something to
that.
MR. LANNING: Well, you know, we've placed a great
emphasis on the receipt of technical issues through the
allegation process. We continue to receive allegations
pretty much at the same rate as Bill indicated, about four
per month.
In terms of significance, there have been
technical issues that have -- now appear on our restart
list. There also continues to be an important percentage
that deal with alleged harassment, intimidation. So from
that standpoint, it's pretty much what we've seen in the
past, and that's true for the last six months, also.
CHAIRMAN JACKSON: Okay.
Mr. Travers?
MR. TRAVERS: In terms of what we expect will be
accomplished before the next time we meet with the
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Commission, or at least within the next three months, we
expect to complete our review and approval of the third
party oversight plan -- I'm sorry, audit plan. And that
again --
CHAIRMAN JACKSON: As appropriate.
MR. TRAVERS: That again assumes that we have gone
through the process of commenting and revising if
appropriate, that's right.
We expect -- and again, I'll point out that
there's a public element to this. We fully intend to go and
solicit comments from the public in this process.
We expect to begin monitoring the Millstone
employee safety concerns program and the workings of third
party oversight organization through periodic NRC site
presence. We also plan to have conducted at least a meeting
and perhaps two meetings with the third party oversight
organization to assess the status of their efforts and any
recommendations they are feeding to the licensee.
COMMISSIONER McGAFFIGAN: Is that a public
meeting?
MR. TRAVERS: Yes. All of our meetings of this
sort are at least open for public observation, and typically
we provide on a monthly basis an opportunity to make them
even more directly accessible to public comment.
The next slide touches on another topic that is
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encompassed in our restart assessment plan for Millstone and
it addresses licensing issues that either have been
identified or rather are already in-house and being reviewed
by the NRC staff or have been identified by the licensee as
submissions that will be required prior to restart.
This is really a summary of a number of these
issues that have been identified or are under review, and we
expect it will take some significant NRC effort to work off
some of these.
I think it's important to note and really the
point I wanted to make here was that since they are still
largely in the discovery phase of their efforts, there is a
potential for additional licensing actions which will be
required before restart to be identified.
COMMISSIONER DIAZ: Could you give us a flavor of
what is the largest, you know, licensing issue and the
simplest, just to get an idea of where we are? The most
complex or, you know --
MR. TRAVERS: I don't think we've identified at
least the ones under review as being very complex. And if I
say that, I will give you a time estimate for the typical
time it takes to process. Typically, for a not too complex
licensing amendment, the staff takes between four to six
months. They have been accomplished without exigency in a
shorter time frame, and that's about two months.
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So there is definitely a lag, and it's in part due
to the process, the very formal process, the process that we
use in assuring that there is a public component to our
licensing action consideration.
COMMISSIONER DIAZ: Right. But you haven't seen
any issue of a complexity sufficient to say it's going to
take a year to resolve it?
MR. TRAVERS: I may have to get back to you on
that but I don't think so. Much of what we have identified
in terms of the actions before us are clarifications to
technical specifications and so forth, that kind of detail.
COMMISSIONER DIAZ: Nothing that involves a major
change in a system or would take considerable time for --
MR. TRAVERS: No, but that's what I'm concerned
about in some sense happening -- or not concerned, but I
want to be aware of it in terms of the possibility of it
affecting the --
COMMISSIONER DIAZ: It might be worthwhile to --
CHAIRMAN JACKSON: Yes. I noted there was a press
clipping from Northeast Utilities -- this was kind of a
follow on on April 18th -- stating that there may be show
stoppers and, you know, there was commentary about the
concrete basement erosion.
MR. TRAVERS: Yes.
CHAIRMAN JACKSON: But I had thought that was not
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a restart item but a -- excuse me? It is?
MR. TRAVERS: That particular issue is a restart
issue in the sense that it needs to be addressed and a
resolution identified.
CHAIRMAN JACKSON: A resolution. And similarly
the recirc spray system.
MR. TRAVERS: That is also a restart. It's
specifically contained in our significant items list and,
depending on the outcome of their review, it could require a
major modification of the plant, and I think that's, you
know, first a concern to them.
CHAIRMAN JACKSON: Okay. And then I noted that
the unit with the most additional issues to be submitted is
in fact unit 3, which is the one that's supposedly at the
front of the queue.
MR. TRAVERS: Yes.
CHAIRMAN JACKSON: And have you gotten any
submittal dates and have these been factored into the
schedule?
MR. TRAVERS: In fact, they're late. Much of -- I
think we -- actually, they're not late. I think they told
us in April, either this week, I think by the end of this
week they were due in. I think all of the ones that I have
on here as -- or maybe three short of those, at least 16 are
under development by them and should be submitted shortly.
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CHAIRMAN JACKSON: And you have this all factored
into the schedule and in terms of -- and into the resource
loading?
MR. TRAVERS: We do. We do, although, I'll be
honest with you, there is an element of uncertainty in terms
of the resources that will ultimately be required.
CHAIRMAN JACKSON: Because you don't know.
MR. COLLINS: I think it's important to note too
that the window that we currently have allows us the time to
process these typical amendments. As we get closer towards
the restart date itself, then these will become much more
significant in their progress and status.
CHAIRMAN JACKSON: Okay.
Commissioner McGaffigan I think had his hand up,
and then Commissioner Diaz.
COMMISSIONER McGAFFIGAN: In terms of these
numbers, is it because they're focused on unit 3 that you
have a large number of numbers or is it because unit 3 was
licensed later and, therefore, it has a more complex
licensing basis and more items come up because it's a --
it's just a bigger volume of paper that they needed to
update?
MR. TRAVERS: Since it's initiated by their own
self-identification of what is needed, I honestly don't know
the answer, but each one has a story, and I don't know if
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there is a general heading under which you could make
reference to the different numbers.
MR. LANNING: Probably resulting from the
configuration management program on unit 3, they're having
more findings than they have found at unit 2, for example,
and there are more modifications involved at unit 3.
CHAIRMAN JACKSON: Commissioner Diaz?
COMMISSIONER DIAZ: Yes. But definitely this is
an issue in which the licensee needs to provide us with
information as soon as possible so we can clearly identify
the timetable that is involved.
MR. TRAVERS: And that's exactly what we've been
urging.
MR. BURNS: I might add, just to make sure I
understand the staff, my assumption in hearing them is --
from their description -- is the types of licensing actions
that they have identified would involve a no significant
hazards consideration, which means their timetable is
constructed on a no prior hearing type circumstance, and --
CHAIRMAN JACKSON: Should that change --
MR. BURNS: Should that change, that would be a
different matter because of the hearing requirements under
the regulations and the statute.
COMMISSIONER DIAZ: That was precisely the heart
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of my question.
MR. BURNS: Yes. I want to make sure I address
that.
MR. TRAVERS: Actually, my last slide presents
again our best effort to project --
CHAIRMAN JACKSON: Why don't you speak to
Commissioner McGaffigan's question about the other unit.
MR. TRAVERS: In terms of unit 2 -- well, I'll
just point out that if this holds, this would result, with
many steps, in us briefing the Commission for unit 3 on or
about the 19th of December; and the unit 2 project planning
schedule that we've actually developed but weren't as
confident in would project the same endpoint, the Commission
briefing, on or about early to mid-March.
COMMISSIONER McGAFFIGAN: Why the two-and-a-half
month difference given the four-week difference in the ICAVP
initiation date? How does it end up two-and-a-half months
behind?
MR. TRAVERS: I'd have to look at it and --
MR. IMBRO: I think part of it is due to the fact
that the length of the ICAVP proposed for unit 2 by Parsons
is on the order of perhaps ten weeks longer than what's
going to be done at units 3 and 1.
COMMISSIONER McGAFFIGAN: Okay.
MR. TRAVERS: I'll be honest with you, I think
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that it's largely problematic in terms of, you know, the
unfolding events of their effort, the ICAVP, and our effort
in terms of the schedule.
COMMISSIONER McGAFFIGAN: Madam Chairman?
CHAIRMAN JACKSON: Yes?
COMMISSIONER McGAFFIGAN: My only comment is I
think it's useful to establish baselines at these meetings
so that we can compare them, knowing all of these schedules
are very uncertain.
CHAIRMAN JACKSON: Right.
Let me just say the following to you,
Commissioner. I think it's unfair for us to establish too
definitive baselines for our staff when it's linked to what
the licensee has to come forward with and their actually
being able to step through their work completion process to
support the schedules that they have, in fact, submitted,
because the two are work linked.
COMMISSIONER McGAFFIGAN: Right. I understand.
CHAIRMAN JACKSON: Please.
MR. COLLINS: Excuse me. Just to be complete, we
have a very detailed schedule, including a number of
postulated conditions, that we can certainly share if that
would help be responsive to your question.
CHAIRMAN JACKSON: Yes, that probably would be
useful.
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Commissioner Dicus.
COMMISSIONER DICUS: The comment I want to make,
and this is unusual because I usually very much believe in
schedules and I do in this case as well, but a caution I
think that backs up on what the Chairman said: let's not be
too schedule driven on this at the expense of other issues.
CHAIRMAN JACKSON: Any further comment?
Are you done?
MR. TRAVERS: I think I am.
CHAIRMAN JACKSON: Hold on. Sorry. Commissioner
Dicus has a question.
COMMISSIONER DICUS: One quick question. It
should have an easy answer. I think you previously
indicated that the ACRS will participate at some point in
the Millstone restart. Are they participating yet?
MR. TRAVERS: We've actually been in contact with
ACRS. We had initially gotten word from them that they
would meet in May -- no, in April; but they have since
indicated that they would like to hear from us following
restart as opposed to earlier on in the process. So right
now, we don't have any immediate plans to go forward and
brief the ACRS, largely on their own initiative.
COMMISSIONER DICUS: All right.
CHAIRMAN JACKSON: Well, thank you. I'd like to
thank both Northeast Utilities and the NRC staff for
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briefing the Commission on the progress in assessing
readiness for restart of the Millstone units.
The Commission recognizes that it is difficult to
condense the substance of the reviews performed either by
the licensee or the staff into briefings like this, but
that's the primary reason that the NRC in fact has created
the special projects office, in order to provide direct
oversight of all of the licensing and inspection activities
and to tailor the NRC staff guidelines for restart approval,
the manual chapter 0350 process, to specifically assess the
efficiencies and their resolution at the Millstone units.
As we've clearly indicated through the briefing,
the Commission is not only interested in how the recognized
efficient startup issues are resolved, but equally
importantly in whether the Millstone organization is
functioning in total with the proper perspective on safe
operation, whether that relates to employee concerns,
operability determinations, operator training, competency
and readiness, or any of a myriad of issues.
As I stated at the last meeting and as I think
Commissioner Dicus has just reinforced, the Commission does
not presuppose that any of the three plants will restart by
any certain date; however, the Commission must be prepared
to assure the allocation of adequate staff resources to this
process and to its oversight of the Millstone facility; and
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as such, at subsequent meetings, the Commission will
continue to assess whether adequate progress is being made
in the readiness for restart of the Millstone units and
whether the NRC assessment process is both comprehensive and
timely, but not overly rushed.
I would reemphasize to the licensee what you've
already heard without my going into chapter and verse again
with respect to the degree of specificity the Commission
expects to have in the presentations and in documentation
provided beforehand going forward.
So unless my fellow Commissioners have any further
comments, we're adjourned.
[Whereupon, at 12:33 p.m., the public meeting was
concluded.]
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