ML030090347
| ML030090347 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/23/2002 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| FOIA/PA-2003-0376 | |
| Download: ML030090347 (120) | |
Text
1 1 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION 2
3 IN RE: THE MATTER )
)
4 OF )
)
5 DAVIS-BESSE )
6 REPORT OF PROCEEDINGS 7 December 23, 2002 9:00 A.M.
8 9 REPORT OF PROCEEDINGS had and testimony 10 taken the hearing of the above-entitled matter, 11 held before Mr. Ted Quay, at the Nuclear Regulatory 12 Commission, 801 Warrenville Road, Lisle, Illinois.
13 14 PRESENT ON BEHALF OF N.R.C.:
15 MR. JACK GROBE, Hearing Officer; 16 MR. MARTIN J. FARBER; 17 MR. MEL HOLMBERG; and 18 MR. ROY CANIANO.
19 PRESENT ON BEHALF OF DAVIS-BESSE:
20 MR. LEW MYER MYERS; 21 MR. JIM POWERS; 22 MR. ROBERT SCHRAUDER; COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
2 1 MR. GARY LEIDICH; 2 MR. MIKE RODER; 3 MR. JOHN GRABNAR; 4 MR. KENDALL BYRD; 5 MR. BOB COWARD; 6 MR. ALEX ZARECHMAK; 7 MR. STEVE FRANTZ; 8 MR. PAT MC CLUSKEY; and 9 MR. KEVIN SPENCER.
10 ALSO PRESENT:
11 MR. DAVID PASSEHL; 12 MR. TOM HENRY; 13 MR. JOE PETRICH; 14 MR. BRIAN RENWICK; 15 MR. CHECK ZOIO ZOIA; 16 MR. TIM STEADHAM; 17 MR. GEOFFREY WRIGHT; 18 MS. DANEIRA MELENDEZ; 19 MR. ROLAND LICKUS; 20 MR. TODD SCHNEIDER; 21 MR. TOM BILIK; and 22 MR. SHAWN PERGANDE.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
3 1 MS. HOUSEMAN: Good morning and welcome to 2 the Nuclear Regulatory Commission conference call.
3 Participants will be able to listen in on the 4 question and answer portion of the conference.
5 Your host for today is Cheryl Houseman. You may 6 begin when ready.
7 MR. GROBE: Thank you very much. My name is 8 Jack Grobe. Id like to welcome First Energy and 9 N.R.C. participants and the public from various 10 locations to this meeting this morning. Im the 11 chairman of the N.R.C. oversight for the 12 Davis-Besse facility. Over the past several 13 months, First Energy has been reviewing three 14 systems to evaluate the design and operating 15 condition of those systems.
16 In addition, the N.R.C. has 17 performed a safety system design and performance 18 capability inspection to independently evaluate 19 three systems, one already reviewed by First 20 Energy, an assessment of the adequacy of the First 21 Energy reviews. The reviews of each of those 22 systems by both the N.R.C. and First Energy COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
4 1 revealed substantive design questions regarding the 2 operation of those systems.
3 We appreciate First Energy providing 4 the N.R.C. with your resolution of system health 5 assurance plan design issues documents allowing the 6 N.R.C. staff to better prepare for this matter.
7 The purpose of todays meeting is to discuss First 8 Energys plan to resolve the design questions and 9 to assure that through the efficiency its well 10 understood.
11 This meeting between N.R.C. and 12 First Energy is open to public observation here in 13 the N.R.C.s Region III office in Lisle, Illinois, 14 and in the N.R.C. headquarters offices in 15 Rockville, Maryland, through video conferencing and 16 through a teleconference bridge line where members 17 of the public can listen in on the bridge.
18 After the N.R.C.s discussions today 19 with First Energy are completed, there will be 20 opportunities for members of the public here and 21 through the telephone conference bridge to ask 22 questions of the N.R.C. or make comments. We are COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
5 1 also having this meeting transcribed today to 2 maintain a record of the meeting. The transcripts 3 will be available on the N.R.C.s web page several 4 weeks after todays meeting. Copies of the First 5 Energy hand-out are available in the back of this 6 conference room and N.R.C. headquarters and on the 7 N.R.C.s web site. You may also see copies of the 8 N.R.C.s December public monthly newsletter. Also 9 in our conference rooms are N.R.C. meeting feedback 10 forms that you can fill out and provide feedback on 11 format, content or any other aspect of these 12 meetings so that we can improve the quality of our 13 public meetings.
14 At this time Id like to introduce 15 the rest of the N.R.C. staff that is here today and 16 also in headquarters, and then have Lew introduce 17 your staff here at the table.
18 MR. FARBER: My name is Martin Farber, 19 division of reactive safety, Region III.
20 MR. HOLMBERG: My name is Mel Holmberg.
21 MR. GROBE: And Im glad -- you didnt have 22 your microphone on, that reminded me to make sure COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
6 1 that everybody has these microphones close to them 2 and turned on. There is a little green LED that 3 would indicate the microphone is on. Most of them 4 should be on.
5 Also here for the N.R.C. in the 6 audience, please go ahead.
7 MR. ZOIO ZOIA: Chuck ZOIO ZOIA, DRS.
8 MR. STEADHAM: Tim Steadham, DRS.
9 MR. PASSEHL: Im David Passehl, DRS.
10 MR. LICKUS: Roland Lickus, state and 11 government affairs.
12 TOM BILIK: Tom Bilik, DRS.
13 MS. MELENDEZ: Daniera Melendez.
14 MR. WRIGHT: Geoff Wright, reactor projects.
15 MR. GROBE: Okay. Could the N.R.C.
16 headquarters please introduce themselves.
17 MR. HOPKINS: Yes, John Hopkins, project 18 manager for NRRI. Im expecting Bill Dean to join 19 us though hes not here right now.
20 MR. GROBE: Very good, thank you. Also 21 behind us who I neglected to introduce is Roy 22 Caniano, Deputy Director of Reactor Safety. And COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
7 1 our stenographer is Ellen Piccony, welcome.
2 Lew, at this time would you like to 3 introduce yourself.
4 MR. MYER MYERS: Thank you, Jack, were glad to be 5 here today. At the table we have Ken Byrd, hes 6 with our nuclear engineer group. John Grabner is 7 our manager of design engineering; Mike Roder, my 8 operations manager, Im glad to have him with us.
9 Im Lew MYER MYERS, chief operating officer of First 10 Energy. To my right is Gary Leidich, executive VP 11 of First Energy. Next to him is Bob Schrauder, our 12 director of support normally, but hes the project 13 engineer on this issue and helped us work through 14 this. And Jim Powers is a director of engineering 15 next to him. We have several people along the back 16 row. Why dont you stand up back here. Kevin 17 Spencer, Steve Frantz, Pat McCluskey, Alex 18 Zarechmak and Bob Coward.
19 MR. GROBE: Okay, very good. I think that 20 completes our introductions. One person I did not 21 hear introduce themselves was Victoria Viktoria Midling Mitlyng.
22 Victoria Viktoria is our public affairs officer here in COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
8 1 Region III, and she is always available to 2 interface with the public.
3 At this time, Lew, Id like to turn 4 the meeting over to you for your presentation.
5 MR. MYER MYERS: Gary is going to start out.
6 MR. LEIDICH: Refer to the slides on Page 4, 7 and just from a corporate perspective, set the 8 appropriate tone for the meeting, as well as this 9 effort going forward. The company, First Energy, 10 set the standard of returning Davis-Besse back to 11 service in a safe and reliable manner and that 12 includes system health assurance, which is what we 13 are here to talk about today. And, again, our 14 overall focus is to do the job right the first time 15 to regain the confidence of all our customers, and 16 we are certainly committed to meet that challenge.
17 So really Im here today to offer support from a 18 corporate perspective and recognize that we are 19 here to do this job appropriately, and certainly 20 welcome your input on our plan for system health 21 assurance and the design issues that have been 22 identified.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
9 1 So with that Im going to turn to it 2 over to our team, starting with Lew who will go 3 through the desired outcomes, and we will go from 4 there.
5 MR. MYER MYERS: We are here today to provide you 6 an update on the Davis-Besse action plan to resolve 7 design questions identified during the system 8 health assurance plan reviews. We told you that we 9 were evaluating issues from our system readiness 10 reviews and create the scope as necessary through 11 these five latent issues reviews and a total of 12 three system reviews. We are here to obtain your 13 feedback on our plan going forward today.
14 The system health -- our objective, 15 the objective to the system health building block, 16 if you will, was to provide system assurance to 17 First Energy, the regulators and the general public 18 that the systems at Davis-Besse would perform these 19 safety and accident mitigation functions. That was 20 the original objective of the building block.
21 Since that time that we started the six building 22 blocks, the seventh one will be the restart action COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
10 1 plan. We in the system health really thought there 2 would be three systems, we picked five latent issue 3 systems to look at, and we picked the systems like 4 service water and component cooling water because 5 of recent experience. And we thought that would 6 provide us significant insight.
7 We found questions concerning design 8 calculations and our ability to go back and look at 9 those calculations, the rigors of the calculations, 10 and we found some questions in those areas. Most 11 of those were primarily questions from the prior to 12 1990 time frame. There werent recent issues. We 13 found that the calcs sometimes were different, but 14 we have been able to find the calcs and they were 15 very much in line with the 54(f) letter that we 16 provided to the regulators some time ago.
17 Today we found nothing in these 18 calculations that we were not able to find or were 19 not bounded easily. And to date we found nothing 20 that would indicate that our systems at our 21 Davis-Besse plant were not either able to perform 22 their design functions or operable to this date for COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
11 1 those questions we looked at in the five systems.
2 So once again, we always told you 3 that we would take a broad-based look. Our plan 4 looks at systems with questions. We are going to 5 go back and look at systems which have a greater 6 than one percent core damage risk frequency. What 7 that does is give us 99 percent confidence we wont 8 find anything later on in latent issues reviews 9 that are significant.
10 Our plan has three paths. The first 11 path is an operability review. We are taking each 12 and every CR and we are talking about that today, 13 and performing what we call operability review on 14 the CRs we have generated as part of the latent 15 issues. And our supervisor will either declare the 16 system operable or inoperable, based on their 17 reviews of the information.
18 We will then validate risk 19 significance of the safety functions. And then 20 finally we are looking at the issues from a 21 programmatic standpoint. We always told you wed 22 take the CRs that we wrote during latent issues and COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
12 1 put them together and look at cross-cutting issues 2 on the other systems.
3 These three paths, we feel that if 4 we take ten additional systems and provide 5 reasonable assurance of the conditions of the 6 Davis-Besse plant and assure that its safe and 7 reliable, if we find additional issues, we will 8 take additional corrective actions before restart.
9 But our intention is to -- we believe that we will 10 find that our reviews were bound, the systems, and 11 we told you that we will continue to move forward 12 with latent issue reviews after our restart of our 13 plan. We think that that will provide us and the 14 public good, reasonable assurance.
15 With that Id like to turn it over 16 to Jim Powers.
17 MR. POWERS: Thank you, Lew. What Id like 18 to do this morning is first give a little 19 historical perspective on the maintenance of the 20 licensing basis at Davis-Besse over the years, and 21 then proceed to talk a little bit about our system 22 health building block and activities we have COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
13 1 undertaken as part of the current recovery of the 2 plant.
3 Behind me on the easel and in your 4 hand-outs there is a design basis assessment 5 timeline that we prepared, and it shows along the 6 top of the timeline the plant operations since the 7 mid 1980s time frame up until today. And along the 8 bottom it shows the number of assessments that have 9 been performed both by the Davis-Besse staff, as 10 well as the N.R.C. staff over the years.
11 We started in the 1985 time frame 12 because this is the time frame when the plant went 13 through a recovery effort from the offspeed water 14 event that occurred in that time frame. And we 15 proceeded from there because we wanted to see from 16 the long-range historical look on what type of 17 activities had transpired since that time because 18 we know that a lot of attention was focused on the 19 plant in the mid 80s, both from the owner 20 perspective as well as the regulator perspective.
21 In fact, a course of action was 22 prepared in that time frame that encompassed many COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
14 1 activities, a lot of them were related to 2 engineering. What Id like to focus on is the 3 bottom of the chart and the activities that 4 transpired over the years and the number of sets 5 that were performed. We list them on the slides --
6 on Slide No. 11 that is shown here. Our 7 independent safety engineering group performed 8 vertical slices of systems, and that starts in 9 1989, we show a station and instrument air system 10 vertical slice assessment; 1991, emergency diesel 11 generators; 1992, steam generators; 1993, service 12 water system. And this is particularly important 13 because service water system is one of the ones we 14 are looking at in detail today. In 1994 instrument 15 and controls, and 1995, offspeed water system.
16 And as you go across the bottom of 17 the timeline you can see that the surveillance and 18 assessment of the design basis has been ongoing and 19 continuous. Then we look at N.R.C. reviews that 20 were performed, and these are typically detailed 21 inspections of systems and their functional 22 capability, and also design basis supporting them.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
15 1 In 1992, electrical distribution system functional 2 inspection, EDSFI was performed. In 1993 a service 3 water inspection that was referred to, this was a 4 very detailed and hard hitting assessment of 5 service water capability and appraisal performance, 6 and in the 1997 high-pressure injection and 7 low-pressure injection systems, and what was 8 referred to as an architect/engineer inspection.
9 This inspection consisted of teams of engineers 10 from architect/engineer corporations that were led 11 by the N.R.C. inspector looking in detail at these 12 systems over a number of weeks to go into the 13 design basis specifically to see how the licensees 14 were maintaining the design basis over the years.
15 And then in 2000 safety system 16 design performance capability inspection was 17 performed at the plant. And so these activities 18 were ongoing over time, and I think if you look at 19 the chart you will see that its a continuum of 20 assessments and inspection.
21 And the chart is available at the 22 front here for those of you who would like to come COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
16 1 take a look at it, and there is also hand-outs that 2 detail it.
3 The results of those assessments, 4 importantly, consistently showed that the systems 5 were operable and capable of performing safety 6 functions. Any time that we have an assessment or 7 an inspection, we typically develop questions, 8 engineers come to the site, they are independent, 9 they havent participated in the engineer 10 activities of the site, and they ask questions. We 11 wrote those down in our corrective action program, 12 and then we evaluate them and answer them. But we 13 found over the past the systems had been determined 14 to be operable and functional.
15 We did also identify some weaknesses 16 in calculations as a part of those inspection 17 assessments, and, in fact, had activities ongoing 18 at the site to improve our calculations and the 19 quality and continuous improvements in those areas 20 over the years. Another thing to point out is as 21 the assessment and inspection activities have gone 22 on over the years at the plant, both the inspectors COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
17 1 and the engineers learn new things, new 2 perspectives on the systems, and we continue to 3 improve our technology and our methodologies 4 improve and the questions get tougher, and part of 5 that contributes to some of the questions we have 6 today.
7 When we look at a plant thats been 8 operating for 25 years and we apply todays 9 understandings, todays technology and 10 methodologies to the original -- in some cases the 11 original calculations for the plant, there are 12 questions and areas for improvement that are 13 identified, and that is consistent with 14 Davis-Besse, as well as other plants in the 15 industry.
16 MR. MYER MYERS: When we went back and 17 looked at all questions on the calc and compared 18 what we were seeing at our plant and throughout the 19 industry, we were very consistent with our 20 operational plants.
21 MR. POWERS: Thats right. I would say that 22 is correct, Lew. When we have an inspection, one COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
18 1 of our internal inspections done and calculations 2 on design basis information, the type of questions 3 we see today are typical of whats been -- we have 4 seen at other plants and at our plants in the 5 industry. You typically have a number of questions 6 that need to be answered, usually takes some time 7 to work through the analysis, and in some cases 8 calculations need to be revised to answer the 9 questions, and thats what we are doing right now, 10 and its consistent with what occurred at other 11 plants.
12 The resulting remedial actions from 13 many of these inspection assessments were a review 14 of our updated safety analysis report that was done 15 in 1996 and design basis validation program, which 16 was performed in 1997 to 1999. The updated safety 17 analysis report is really a compendium of all the 18 license bases for the plant and reflect the 19 important design basis that is related to safety 20 function of our systems. And so its a very 21 extended review that is done when you look at the 22 use.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
19 1 The design basis validation program 2 looked at three systems which comprise some of the 3 most important functions in the plant from a safety 4 perspective, and we looked at all the calculations 5 in support of those functions in the 1997 to 1999 6 time frame. These activities were part of a 7 response to a request for information that was 8 issued pursuant to 10 CFR 1054.F 50.54F by the N.R.C.
9 that all utilities in the time frame in the mid 90s 10 were requested to prepare an assessment and 11 response on the maintenance of their design basis 12 of plants and how it was reflected in the 13 procedures that tested and surveilled the plant.
14 And we have performed that assessment, along with 15 all of the other licensees in the country, and 16 these two activities, the review of the USAR and 17 our design basis validation program were two of the 18 activities that we performed in support of that.
19 And there were commitments from the design basis 20 validation program to work through, corrective 21 actions that we developed, and that improving 22 calculations, weaknesses in calculations, COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
20 1 identified issues, and we were in the process of 2 working through those improvement programs.
3 MR. GROBE: Are you going to get into more 4 detail later, or is Bob, on the scope of those 5 prior activities and what contributions they 6 provide to you on comfort level and the extent of 7 conditions bounded?
8 MR. POWERS: Sure, I can comment on that.
9 Well, particularly in the case of the design basis 10 validation, we were using portions of the design 11 base validation project to provide assurance on 12 extended condition, and with respect to that 13 project did assess areas that have -- where 14 questions currently have been raised, then we will 15 be able to use it and take credit for it, for 16 extended condition assessments. If it did not 17 accept a particular question thats been raised, we 18 will not be able to use it, but Bob will get into 19 some more detail on the safety function validation 20 program that we have prepared, and then we will 21 walk through some detail on that.
22 MR. MYER MYERS: Is it fair to say if you go back COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
21 1 and look at the 50.54 that was submitted and with 2 the plan we laid out, that the type of questions 3 that we found on the five latent issue reviews and 4 what N.R.C. found are similar?
5 MR. POWERS: Yes, the -- what Lew is 6 referring to is our 54(f) letter response, we 7 acknowledged at that time that there were 8 weaknesses in calculations and prepared our design 9 basis validation program, launched into that in 97 10 to improve of the calculations, but we also in that 11 letter of response point out that there was several 12 areas which we did not specifically assess in the 13 response, because it was believed that the 14 assessments and inspections that we had undergone 15 relatively recently to that time frame 16 substantially demonstrated that the programs were 17 healthy.
18 Those were programs of HELB, 19 environmental qualifications, seismic 20 qualification, Appendix R and flooding, for 21 example, and when we have gone through this most 22 recent system health building block and done our COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
22 1 latent issues reviews and systems health 2 maintenance reviews, we have developed some 3 questions in those areas, started out as areas of 4 corrective significance in our assessment of the 5 questions that have been asked, and so it is 6 consistent that we find some areas of question 7 there, because we did not poke into those in a lot 8 of detail as part of the 54(f) letter response.
9 So what we are seeing is fairly 10 consistent to what was submitted in the 54(f) 11 response.
12 MR. MYER MYERS: I guess what Im trying to tell 13 you is I think we did a pretty good job in the 14 50.54(f) letter. Im not sure that we did as good 15 a job of following through after we submitted the 16 letter. But when I read that and I read the issues 17 that I see coming out of our recent reviews, 18 theyre basically the same in my mind 19 MR. POWERS: Thats right. One of the 20 important aspects of the response to the 54(f) 21 letter and also our design base validation program 22 is that we had a number of calculations that needed COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
23 1 to be either revised or prepared, that we found 2 areas that needed continued improvement, and there 3 were 250 calculations that fell under this category 4 that were ongoing, to have those calculations 5 finished up as part of our corrective action.
6 That project was not expedited as 7 aggressively as it appropriately should have been.
8 We determined that when we came on site this year, 9 and reviewed our current numbers in this area.
10 This was back in the April time frame, and we 11 authorized the resources to complete that project 12 by the end of this year, and Sergeant & Lundy has 13 been helping us with that process in issuing over 14 250 calculations. So that is an area where we 15 could have done better from a schedule perspective 16 as a project that didnt get completed as quickly 17 as we would have desired, but it is being expedited 18 now.
19 MR. HOLMBERG: Mel Holmberg, Region III. You 20 mentioned the other issues that were not 21 specifically looked at very in-depth in the 50.54, 22 I think HELB, EQ, seismic qualification, fire COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
24 1 protection. What was your basis for whatever 2 conclusions you had in those areas?
3 MR. POWERS: In the letter of response what 4 we -- the basis for our conclusion was that 5 assessments and inspections had been performed near 6 term to the 54(f) letter response. Those are areas 7 that were relatively active at that time, had been 8 surveilled, and we felt that that was a 9 satisfactory assessment at that time.
10 MR. HOLMBERG: So what types -- can you give 11 me examples of what type of things you say you 12 surveilled, or --
13 MR. POWERS: Inspection, for example N.R.C.
14 inspection in the EQ area for self-assessment by 15 our quality organization in that area.
16 MR. HOLMBERG: Okay.
17 MR. POWERS: There had been documented audits 18 and inspection assessments of those programs that 19 we felt substantially characterized their status at 20 that time.
21 MR. HOLMBERG: Thanks.
22 MR. MYER MYERS: EQ, if you go back and look on the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
25 1 timeline we gave you, it shows us inspections and 2 areas where we all looked at the EQ, so if you go 3 back and say was that program healthy, we would say 4 yes, based on the results of that. So we tried to 5 provide a lot of that history here in that 6 timeline.
7 MR. GROBE: I have got a number questions 8 regarding the historical review, but, Jim, I think 9 Id like you to continue your presentation and we 10 will hold them for the end of your section.
11 MR. POWERS: Okay. So thats a look back on 12 how the design basis has been maintained and 13 surveilled at Davis-Besse over the years.
14 Now, moving into todays time frame, 15 the system health assurance plan that Lew described 16 in 2002 we began the system health assurance plan I 17 referred to as a building block or restart of the 18 plant. And there was three reviews actually that 19 were prepared as part of this building block.
20 The first was an operational 21 readiness review, and this was a review of the 22 system engineer chaired by the plant manager of COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
26 1 issues that related to their systems that they had 2 been carrying over the years that they wanted to 3 get done, and giving them an opportunity to voice 4 their concerns to the plant manager.
5 And there were a number of projects 6 that emerged from that of things that were 7 important to get done in the plant, material 8 condition issues for their systems, and we approved 9 a good deal of work to proceed as a result of those 10 reviews. And I think it also gave the -- from the 11 human, you know, perspective, it gave the 12 responsible system engineers an opportunity to sit 13 down with the plant manager and have a direct voice 14 in the plant management and their desires to 15 improve the health of their systems.
16 The next was a system health 17 readiness review level. We went into this looking 18 at our maintenance rules, risk significant systems.
19 31 of those -- of the 36 systems were included at 20 this level of reviewing. We went and looked at 21 modifications back to the 1990 time frame, because 22 this is the year in which the modification for the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
27 1 service structure inspection port openings was 2 initially submitted and subsequently deferred from 3 that time, and so we wanted to take a look and see 4 if there was any other modifications, either open 5 or closed, that needed to be done or appropriately 6 done, and gave the engineer an opportunity to look 7 at that.
8 We also looked at work orders and 9 corrective actions since the 1995 time frame. That 10 1995 time frame was selected because that was 11 subsequent to a management shift from the 12 Davis-Besse site over to the Perry site, and we 13 wanted to take a look to see if there was any 14 deviation from the programs, from effectiveness 15 from 1995 going forward in those areas.
16 And we also looked at the testing 17 programs for these systems to be sure that the 18 maintenance rules for significant functions were 19 tested appropriately. So they were fairly 20 extensive reviews, each one is in a three-inch 21 binder of working material, and in some cases two 22 binders worth of materials. So its by no means a COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
28 1 shallow review.
2 And lastly, our latent issues 3 reviews. And for those of you who have not 4 participated in the dialogue up to now, the latent 5 issues is a vertical slice process that we 6 initiated at the Beaver Valley plant and was seen 7 as very beneficial there in terms of digging out 8 issues that may be latent, buried in a plant 9 system, either in the hardware or in the software, 10 the paperwork for the system.
11 A team goes through and looks for 12 issues that may have been residing below the 13 surface and brings those out so they can be 14 resolved. Its a very effective process, and we 15 have improved on it actually at Davis-Besse, a 16 little more detail on operational readiness 17 reviews.
18 These were completed, they were done 19 very early on, in fact in the May time frame, 20 identified whether the systems have any known 21 significant deficiencies and corrective actions to 22 bring those out, bring them forward and deal with COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
29 1 them, selected systems relative to the maintenance 2 rule performance criteria material, condition and 3 operator. So this was a fairly broad selection 4 process that went into these systems. Any one of 5 these areas where there was known to be problems, 6 the systems were brought up and brought forward for 7 a committee review. The committee was chaired by 8 the plant manager. And there was also substantial 9 maintenance and operations support for it.
10 In fact, Mike Roder, our operations 11 manager sat in on the planning of these meetings, 12 and there was a number of issues that came up in 13 the area of, for example, operator burdens or 14 material conditions of the systems that were 15 addressed. And Mike is here if -- do you have 16 anything to say on that?
17 MR. RODER: Yeah, thanks, Jim. There was an 18 -- now this early on in the time frame that we sat 19 in on these meetings, and it was good ownership by 20 the system engineers, a lot of activities that were 21 added to the schedule to resolve. I brought a 22 couple of examples we worked and several leads on COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
30 1 transformers and corrected some deficiencies there.
2 Breakers in the switch yard were overhauled. Some 3 of the air compressors, power supplies, I think we 4 changed out 14 enunciator power supplies, all 5 strengthening the operation of the plant. Several 6 work arounds and several operator burden activities 7 were also included, remodified the fuel handling 8 bridge, components to strengthen the operation of 9 the plant, so there was a lot of good ownership, 10 good dialogue from the system engineers and 11 operations plant manager to strengthen our position 12 and increase the reliability and health of the 13 various systems.
14 Another thing, Jim, it wasnt all 15 the systems, there was a couple of cross-cutting 16 issues as we went there. We noticed there was 17 issues with power supplies, we discussed power 18 supplies in that context of air operated valves, 19 motor operated valves, and corrosion was another 20 system, if you will, that was discussed, and 21 instrument root valve, we noticed there was an 22 issue with root valves. There was some vertical COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
31 1 slices through the system, if you will.
2 MR. POWERS: Thanks.
3 MR. RODER: So there were a number of 4 projects that we -- high pressure injection were 5 refurbished.
6 MR. POWERS: There were some major items that 7 the engineers had sought to get done.
8 Next, on Slide 16, the system health 9 readiness reviews. We list out the review scheme 10 that was performed, the test results of 11 functionality, the support functionality 12 modifications since the 1990s, corrective actions, 13 work orders since the middle of the 1990s, and then 14 system walkdowns is one aspect of it that I didnt 15 mention. And that is, we got out on each one of 16 these 31 systems and walked them down to the 17 multidiscipline team, consisting of maintenance, 18 operations, system engineering and design 19 engineering and management.
20 MR. LEIDICH: I participated in those as 21 well, and I can assure you these were a high level 22 of detail in the field, and we were going as far as COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
32 1 identifying rust in electrical cabinets and a 2 variety of those kinds of things, so suffice it to 3 say we got a very comprehensive review of the 4 systems condition from a plant perspective, so the 5 threshold for identification of problems, I think, 6 took a different tone at Davis-Besse. As a result, 7 we have identified a lot of condition reports on 8 these systems at both thresholds, which represents 9 a very substantial amount of work that we have been 10 tangling with in this outage, but I think its 11 another indicator of our philosophy going forward 12 here.
13 MR. POWERS: I agree. I believe there was a 14 significant change in the plant that was achieved.
15 You were asking the engineers and the maintenance 16 staff and operations to work together and walk by 17 equipment in the plant that they have been walking 18 by every day for years and critically look at it 19 and ask them is it safe and is it acceptable, and 20 its a 25-year-old plant, so you will find some 21 corrosion of supports, for example, and Im talking 22 about minor surface corrosion, rust if you will.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
33 1 You were going to find small questions of material 2 condition or cleanliness, housekeeping that perhaps 3 had been passed over before, but now were 4 critically asking questions, and much of that was 5 entered into our corrective action process, and 6 particularly getting off the beaten path and look 7 around behind the equipment, behind cabinets, 8 inside cabinets and poke around. And it was very 9 beneficial in terms of changing culture and 10 standards.
11 MR. MYER MYERS: Let me take this a second. You 12 know, if you are going to look, you know, I think 13 what we have concluded so far, we have looked at 14 our systems every way throughout history, through 15 -- that is what our timeline talks about, and if 16 you look at our 50.54(f) letter response, I think 17 that was done quite well.
18 The reason I spent some time on that 19 a while ago is I dont think our response of that 20 was as good as it should have been. I want to make 21 that clear.
22 Youre going to look at overall COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
34 1 material position of our Davis-Besse plant from an 2 operations standpoint and maintenance rule 3 standpoint, stuff like that, go back and read the 4 report, there was a 25 percent decrease in the last 5 cycle in the number of A-1 systems from a 6 maintenance rule standpoint, which once again 7 indicates that -- and we have said that before --
8 the plant was in fairly good material condition 9 when we brought down -- we know we -- when we walk 10 around the plant, you know, the plant material 11 condition looks pretty good, and additionally we 12 brought in some -- several outside teams of people, 13 executives from our plants, our ROP cabinet members 14 that we have in our restart oversight panel, and we 15 have had them out in the plant, and I know you have 16 been out there, and actually the material condition 17 of the plant appears to be quite good.
18 That is my overall assessment of the 19 plant, and my experience is that if you look at the 20 physical, material condition of the plant, the 21 material condition of it is quite good in our 22 plant, and that is the feedback we have received COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
35 1 from everything we have looked at, and thats what 2 I said going into the building block plans, and 3 that is what we still believe to be true. There 4 are these design type questions that have to do 5 with calcs, mostly latency issues, and I think that 6 is the meat of what were here for. But I think 7 just to summarize, we did go over all material 8 condition of the plant, we addressed that quite 9 good.
10 MR. POWERS: And so the goal for the system 11 health assurance plan was to provide confidence 12 that the systems can perform their function. And 13 on Slide 17 we talk about the latent issue review 14 in a bit more detail. We selected five systems to 15 look at in great detail to assess down through the 16 design basis of the system, the design calculation, 17 what the status of the systems were. That included 18 the reactor coolant system, service water system 19 and off-speed water system, component cooling water 20 and the emergency diesel generators. And those 21 were selected for a variety of reasons, some due to 22 volume of involvement with our reactor degradation COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
36 1 issue, others were due to issues from our quality 2 assurance assessments of the systems, and others 3 were selected because of their contributions to 4 safety function at the plant. And we thought there 5 was a core group of systems that would really tell 6 us a good picture on what the status was of the 7 deep system health.
8 We verified design bases as part of 9 these reviews, going back and looking that the 10 calculations were in place to support the safety 11 functions and the testing program of the safety 12 programs. We assessed in all 31 different system 13 attributes, so we asked a lot of questions going 14 through this in terms of given calculations, 15 quality of the calculations, electrical 16 calculations, mechanical safety analysis, 17 environmental qualifications, there were a lot of 18 checks that were made. And we also reviewed 19 various data sources.
20 There were teams working on these, 21 Id say on average probably eight individuals, 22 engineers, experienced engineers, I might add that COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
37 1 have worked at other plants who have gone through 2 this level of detail system review and spent 3 several months going through the review process and 4 really digging through all the information 5 available, and then performing comprehensive 6 walkdowns of these systems as well in the field, 7 and both were material condition and configuration 8 perspective.
9 In addition to latent issues, we 10 also prepared self-assessments of calculations and 11 high pressure injection system and the 4160 vault 12 distribution system. And this was looking at the 13 calculations. In particular we felt that one of 14 the areas that we had developed of corrective 15 significance was in the calculations as we went 16 through latent issues reviews, and so we prepared 17 an assessment of the high pressure injection and 18 4160 systems. The N.R.C. also came and inspected I 19 would add the service water system in detail and 20 also high pressure injection on 4160 volt systems, 21 and so that their findings were added to our 22 discovery findings as well, and used to help set COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
38 1 direction in terms of what issues were of 2 collective significance to us.
3 On Slide 18, the major 4 accomplishment that we made at the site, we 5 completed discovery in this area for system health 6 assurance plan, and to us that was quite important.
7 We started off on this track back in the early 8 summer time frame, building our plant, doing our 9 training, developing procedures and mobilizing 10 industry expertise, and I feel we have some of the 11 best in the industry in discovery type of 12 activities help us and helping our engineers go 13 through it. It was a very good learning process 14 for our engineers, as well as helping us understand 15 the status of systems in the plant.
16 We issued reports for both the 17 latent issue and system health readiness reviews, 18 and those were all issued to Mr. MYER MYERS. They are in 19 his office taking up a lot of space on his 20 conference table now as he calls in individual 21 engineers and walks them through their report to 22 gain a clearer understanding of what they did and COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
39 1 what their feelings are about their system, and 2 also their feelings about activities that need to 3 be done to support restart of the plant and then 4 other activities that are in the category of 5 improvement that can be made subsequent to restart.
6 They issued condition reports for 7 all of the questions that were identified, and 8 there was a large number of condition reports, and 9 an important point that Id like to make on the 10 number of condition reports issued, when we 11 commissioned the review teams to go off and do the 12 system health reviews and the latent issues 13 reviews, we brought in a number of contractor 14 resources who were highly experienced at doing 15 system reviews, but we told them we didnt want 16 them to spend a lot of time searching for 17 information and trying to answer questions, but 18 rather we wanted to move expeditiously through 19 discovery and sort of write their questions down on 20 a condition report and move on, and we would 21 research and answer that question subsequent to the 22 identification. And they did that.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
40 1 And what we are finding as we go 2 through the evaluation and the research stage now 3 on our condition reports is that in many cases 4 there is an answer to the question, for example, a 5 calculation is missing for an important parameter 6 on a system. Given some time an engineer that is 7 more familiar with the records retrieval process is 8 able to find those calculations, and so there is a 9 significant population of the condition reports 10 which are being answered and being closed out and 11 being determined to be not necessarily a 12 significant issue.
13 We encouraged a questioning attitude 14 going through the process, and we generated over 15 1,200 CRs, and that included both design 16 calculation type questions, as well as operation 17 questions, meaning material condition, hardware 18 questions, procedure questions for operation of the 19 equipment.
20 Our collective significance reviews 21 which we committed to and always planned to do at 22 the end of discovery identified some cross-cutting COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
41 1 issues, and we listed those out in our plan to go 2 forward, and Bob Schrauder will talk to those a 3 bit, and I mentioned those earlier. They are the 4 HELB, environmental qualifications and seismic 5 qualification, floods, Appendix R fire protection.
6 The questions in those areas we felt merited some 7 further review from a significance perspective.
8 The overall discrepancy ratio 9 related to latent issue reviews was determined to 10 be low. That is, for all the attributes that we 11 checked as we went through this collecting 12 calculations, drawings, manuals, procedures and 13 just looking for consistency and looking for any 14 errors that could be found, the number of errors 15 that we found versus the number of checks made was 16 low. And that is an arrangement of about three 17 percent. So we are talking about a -- you know, 18 the vast majority of things that were checked going 19 through all documentation at the plants passed 20 acceptably that level of scrutiny.
21 MR. MYER MYERS: How does that three percent rate, 22 how does that compare to the industry when we do COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
42 1 this kind of cross-checking?
2 MR. POWERS: I would say when you get into 3 this level of detail and the complexities of the 4 business we are in, the engineering, this level of 5 discrepancy not be expected. Every time we do that 6 assessment, whether its our own licensee, quality 7 assurance or engineer assurance, personnel do 8 assessments, questions are raised. Every time the 9 N.R.C. comes in on an inspection, questions are 10 raised. Thats how we, each of us do our job, to 11 raise those issues. And to have questions and 12 discrepancies come up in the three percent range, I 13 would say is probably consistent with what we would 14 see on-line. Let me ask M.P.R., I think M.P.R. &
15 Associates assisted us in assessment of some of 16 these, and I would like Alex to perhaps describe 17 his experience in some other plants that have gone 18 through this type of review.
19 MR. ZARECHMAK: My name is Alex Zarechmak, 20 M.P.R. & Associates. Thank you, Jim. We have been 21 asked to participate from the beginning on this 22 latent issue review process and advise First Energy COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
43 1 in how to structure and how to conduct it, and on 2 the back end to assess some of the results, not 3 unlike the experience at at least five other plants 4 that have gone through similar kinds of system 5 reviews.
6 In each case we tried to track not 7 only the issues that we identified but to put in 8 perspective the issues that we looked at to get a 9 ratio of problems versus checks, and then frankly 10 the three percent is probably in the lower range of 11 the reviews that have been done in other plants.
12 Clearly not something that you can scientifically 13 prove and hang your hat on, but clearly not 14 atypical of other places.
15 If could I comment, I guess the 16 other thing that perhaps is a little bit different 17 here, Id like to point out is we literally --
18 First Energy literally put together an army of 19 folks for these five systems, probably more 20 intrusive and heavier hitting than some of the 21 other places.
22 Each of the five systems, if I COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
44 1 recall right, had at least 10, and probably 12, and 2 sometimes 15 people doing the reviews. Typically 3 other places its been fewer than that, so if you 4 look at the number of plan hours that have gone 5 into these inspections, compare that to the 6 industry experience in other systems, its pretty 7 overwhelming. So in that sense as we look at how 8 successful or with how much difficulty we have had 9 to close out the questions that have been raised, 10 its probably not too surprising. You have this 11 army of folks generating the questions, and frankly 12 you dont have enough people on the other side 13 answering the questions quickly enough or 14 effectively enough.
15 MR. POWERS: Thank you, Alex.
16 Our preliminary evaluation and other 17 questions indicates that there is relatively few 18 that have potential safety consequences, given 19 1,200 -- over 1,200 condition reports issued. We 20 have gone through, looked at potential safety 21 consequence assessment, and M.P.R. Associates is 22 assisting us with that and has done that at several COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
45 1 other sites, and what we are finding is that that 2 large number of questions boils down to in the 3 range of approximately 20, 24 questions. Bob is 4 telling me 26 question areas that we need to do 5 further detailed review on in terms of having 6 potential safety consequences. So the number of 7 potentially significant issues is -- again is 8 relatively small, but those are the issues that we 9 are focusing on and turning our detailed attention 10 and evaluation analysis approaches on to assure 11 that we answer those questions satisfactorily.
12 Now, we are currently performing 13 operability determinations in areas to determine 14 the actual impact of those questions, and that is 15 an ongoing process. As Alex pointed out, we really 16 unleashed an army of engineers and technicians on 17 our systems to ask questions, and these engineers 18 had come from actively doing that at other plants, 19 and for those of you who are engineers, and for 20 that matter most of you who have any sort of a job 21 know that each time you do something, you learn and 22 you move on to your next task and bring that COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
46 1 knowledge with you. So the cumulative knowledge in 2 the industry in todays terms was brought to bear 3 at Davis-Besse, and that did result in a lot of 4 questions, and its taking the technical staff at 5 the station some time to go through those 6 questions.
7 But we have developed a resolution 8 plan, and we provided an advance copy to the staff 9 here in the region last week for review, and Bobs 10 going to walk through that and we will talk about 11 that plan and some of the findings we have had and 12 some of the suggestions we have had in disposition 13 issues and some of the activities that are 14 continuing to go on.
15 In summary from my section of the 16 presentation, what Id like to point out is that 17 the findings that we have at the plant are 18 consistent with the past historical findings that 19 have been generated through system reviews over the 20 years. The plant has not sat idle.
21 The plant has its design basis that 22 is in command of a design base and responsible for COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
47 1 it, and its been aggressively inspected and 2 surveilled both by N.R.C. and the licensee over the 3 years, and so the questions that are resulting are 4 consistent with questions for our plant in the 5 industry, will be consistent for operating plants 6 in the industry right now, and we are going through 7 our operability determinations process, and we 8 assess these questions and we are working through 9 them one by one to make sure we answer them 10 thoroughly and completely, and the answers will be 11 subject and -- available and subject to inspection.
12 And with that Id like to turn it 13 over to Bob Schrauder, whose taken on the project 14 management role for resolution of the design 15 questions.
16 MR. FARBER: Could you go back to the 1,200 17 CRs, just run through the process by which those 18 were evaluated and tell me whether all 1,200 now 19 have been evaluated, what is the status of that 20 whole program? You have 26 open questions. Is 21 that 26 potentially significant issues out of 22 1,200, or what is the percentage?
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
48 1 MR. POWERS: That is 26 potentially 2 significant issues out of 1,200 is the way that I 3 would characterize that, Marty. The process is 4 that the condition reports are written which 5 identified a question, the preparer will write it 6 up. Then a supervisor takes a look at it and 7 annotates it in his block to indicate his knowledge 8 perhaps of the relative significance of the issue.
9 There may be some background from the plant, 10 knowledge that contributes to the identification of 11 the issue and provides some clarity to it. So you 12 have those initial preparation stages, and they 13 issue it.
14 Going to the control room from 15 there, if it affects equipment in the plant in any 16 way, the control room makes an initial 17 determination of operability, and the equipment is 18 either operable or its not. And based on that 19 question, in some cases its not clear. For 20 example, there is a question on a calculation for a 21 heat exchanger for a room cooler lets say, and the 22 question needs to be answered. Right now its just COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
49 1 a question, and so the operator will often times 2 take what is called a mode change restraint against 3 the condition report. He marks it right on the 4 condition report that the plant cannot proceed 5 through a given mode where that equipment must be 6 operable, and the operator, the licensed operator 7 requires that that question be answered to his 8 satisfaction before it goes through the mode 9 change.
10 And so the mode changes are listed 11 and they are controlled, and the plant cannot be 12 taken through a mode change until all of those 13 condition reports tagged against it have been 14 answered. So once the licensed operators have made 15 that determination, then the condition report, the 16 question if you will is out there to be answered.
17 We have got these large numbers, over 1,200 that 18 have been answered, and we have been assisted by 19 contract organizations, Enercom being one of the 20 primary ones we are utilizing to go through 21 research work with our people, licensee people at 22 the site, get that site-specific knowledge, go COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
50 1 through the records, history, answer the questions.
2 That is an ongoing process.
3 And we are dealing with operability 4 determination of each one of these issues as we go 5 through that process, and we are observing it by 6 mode change restraint, so each time we have a mode 7 change in our schedule ahead of us, we are working 8 off those CRs to make sure that we are prepared to 9 make that mode change.
10 Now, the 26 issues out of the 1,200 11 are issues that in the assessment that was 12 performed of all those CRs could potentially effect 13 the -- have an affect on what we call the Chapter 14 15 analysis, which is -- Chapter 15 is a safety 15 analysis chapter of our updated safety analysis 16 report, and so we have gone through the screening 17 process, we have determined that 26 out of over 18 1,200 questions could potentially affect that, and 19 now we are in the process of bearing down on those 20 issues to assess them and answer them, and I think 21 Ken Byrd can provide us some detail on the type of 22 issues that have arisen and a couple of cases where COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
51 1 we have had completion of those issues.
2 Ken, would you like to speak to 3 them?
4 MR. BYRD: Of the 26 issues, some of the more 5 significant ones included a question which was 6 raised about our emergency core cooling system, 7 heated exchangers, in particular the question was 8 raised whether or not the heat transfer coefficient 9 was not conservative enough. There was an initial 10 question it could be off by 60 percent. Obviously 11 this was a significant concern. We have had a 12 review done by a third party, and based on that 13 review, it appears that of the activities, the 14 transfer coefficient was doing closer to our value, 15 and we were able to resolve the issue after further 16 review.
17 Another significant concern was in 18 our ultimate heat sensor. There was the question 19 about our -- the returns if we have a seismic 20 event, if we had a failure of our normal return, 21 all the service water was routed back to our 22 deicing return, would we overheat the service water COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
52 1 system. At the time this question was raised, we 2 didnt have an answer for it.
3 We have done a lot of further 4 digging and determined that actually this was 5 addressed, we had calculations and it had been 6 addressed in our original safety analysis report, 7 and apparently somehow inadvertently dropped from 8 that section of the safety analysis report, but the 9 calculations actually were in place. It was one of 10 the things we had to dig around for a while to find 11 information.
12 Another example which is not 13 necessarily a calculational issue was a question 14 about the current -- we have gone to three-way 15 communications, as have a number of other plants.
16 There was a question of how that would affect the 17 timing of a number of our calculations, in 18 particular the high energy line break calculations, 19 and it was all of those. We have been working with 20 operations, in fact we have gone and observed crews 21 in the simulator to determine if the assumptions we 22 made were credible. It appears that they are. We COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
53 1 will take some additional actions going forward to 2 ensure that first of all we have identified all 3 functions.
4 We have some more procedure guidance 5 on that, and then in my area we are going to try to 6 eliminate some of those if possible, so if we can 7 do away with some of the assumptions, operator 8 actions.
9 Another one of the other questions 10 was actually service water flooding issue involved, 11 this was actually not a design basis issue, it was 12 of some significance because it was an issue where 13 we would have failure, it would result in a loss of 14 all our service water and also cause us to lose the 15 ability to align our back-up service water pump, 16 which is a safety-related pump.
17 After investigation of this 18 question, which had been raised by one of the issue 19 teams, we determined this was an issue of 20 misreading of PNID and that the pipe didnt go 21 there in fact, so that issue was resolved.
22 We had a calculational issue that COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
54 1 again that was one that came out of the latent 2 issue review that had been previously identified in 3 our design basis validation, and we have resolved 4 that issue, and it was -- this appears to be 5 documentation, although there was revision of 6 calculation that was required.
7 Those are the kinds of issues. A 8 couple of other good examples of RECS RCS activity, 9 there was a question raised about the basis for our 10 RECS RCS activity. There was a case of confusing 11 presentation in the -- in our safety analysis, the 12 historical numbers were confusing. We have gone 13 back through the calculations. Its adequate, but 14 we are going to have to revise some of the way the 15 information was presented in our safety analysis 16 report.
17 I think those are typical of some of 18 the ones we have worked. There are 26 issues, we 19 have not worked through all of them yet, some of 20 them are still in the resolution process, some of 21 the resolutions are not completed yet, but that is 22 kind of the examples of what we are finding.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
55 1 MR. SCHRAUDER: Let me take a crack at 2 answering your question, because Im not sure that 3 we have yet.
4 MR. FARBER: You have generated a couple of 5 additional questions, lets put it that way.
6 MR. SCHRAUDER: 1,200 CRs identifying -- as 7 you know, the station review board looks, we 8 categorize some of those as obviously not being 9 required to be completed prior to restart, so some 10 of them come out of that process. The others --
11 and the boiling down to 26 issues, if you will, 12 says that we just take that issue -- the answer is 13 no, they have not all been evaluated yet, some have 14 and some havent.
15 MR. FARBER: So --
16 MR. SCHRAUDER: If you take the issue as 17 written, and accept for the time being for our 18 assessment process that its a fact, and then if 19 you say that its fact, then we went through the 20 process of determining what is the generic issue 21 and what is the potential safety significance and 22 lump them together and come up with 26 potentially COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
56 1 safety-significant issues that need to be addressed 2 if they, in fact, turn out to be true.
3 So that they are not all answered 4 yet, they are not all evaluated yet. We are 5 continuing in the process, but again if taken as 6 true, they would boil down to 26 right now 7 potentially safety-significant issues.
8 And then there is also the 9 programmatic or topical issues that Jim talked 10 about that are not included in the 26, the line 11 break, seismic, Appendix R, flooding and equipment 12 qualification.
13 MR. FARBER: So does that mean there exists a 14 potential that further engineering evaluation of 15 this additional population could reveal other 16 potentially significant issues because it sounds 17 like you have gotten to this point as a result of 18 just your initial screenings subsequent to SRP and 19 that the detailed technical evaluation --
20 MR. SCHRAUDER: No, out of that population 21 you wont -- I dont believe you will find 22 additional issues because again, like I said, the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
57 1 issue is accepted as its written. Now, as you do 2 an extended condition, we are going to talk about 3 that later. And as you look at other systems, you 4 could have more issues that identify themselves, 5 but I dont think we are going to find any 6 additional potentially safety significant issues 7 out of the 1,200 CRs that we are talking about 8 here.
9 MR. FARBER: Okay.
10 MR. HOLMBERG: This topical band group we keep 11 hearing about, and my understanding that is the 12 flooding, EQ, do you have a number that you put on 13 that in terms of CRs that are in the topical vein?
14 MR. SCHRAUDER: I dont have the number off 15 the top of my head.
16 MR. HOLMBERG: Is it comparable with the 17 other conditions or more or less?
18 MR. POWERS: Well --
19 MR. SCHRAUDER: Substantially less.
20 MR. HOLMBERG: In fact, let me ask -- I 21 believe that the -- that group included all 22 condition reports as great as 1,200 that were COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
58 1 generated, and in the system areas there was, I 2 think, somewhat less than that in these topical 3 areas. I think there is typically I want to say in 4 the range of 30 or so.
5 MR. POWERS: Thats right, so there was 6 enough hits in those areas as far as CRs from a 7 significance standpoint that we thought it merited 8 further review.
9 MR. HOLMBERG: But -- okay. I understand if 10 you have a population of -- we will take it as 30 11 or whatever, the real number is -- have these 12 issues gone through some kind of thought process 13 taken as theyre fact, there was a significance to 14 them, has that been done?
15 MR. SCHRAUDER: Not in exactly that same way.
16 The safety significance evaluation that MPV was 17 working on did not include those five topics.
18 Those five topics are being evaluated now on the 19 potential impact of those.
20 MR. HOLMBERG: The reason I bring it up is 21 that another plant that I was involved with was in an 22 extended shutdown, they had some health HELB issues COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
59 1 that turned out to be some more risk-significant 2 issues, and thats why we list those. I want to 3 make sure I understand. If we havent done that, 4 do you intend to do that process?
5 MR. SCHRAUDER: We intend to do this, all of 6 those issues will be addressed prior to restart and 7 their extent of condition 8 MR. HOLMBERG: Thank you.
9 MR. GROBE: Bill and John, in that course do 10 you have any questions?
11 MR. DEAN: I dont have any questions, 12 nothing at this time.
13 MR. GROBE: Okay. Jim, let me just ask a 14 couple of questions. You have given a historical 15 description of design reviews over the years, and 16 Im having a little bit of difficulty putting all 17 of this in context, and I have a couple of 18 questions just to make sure I understand.
19 It sounds like you have done a 20 number of vertical slice reviews, it looks like six 21 of them over the late 80s and early 90s, and then 22 did a rather comprehensive design basis validation COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
60 1 program in the 97 and 99 time frame. Several of 2 the systems that you have reviewed in your latent 3 issues review in 2002 you had prior vertical slice 4 reviews which were fairly comprehensive design 5 reviews and were also covered under the design 6 basis validation program. The findings that you 7 have had from these latent issues review, why are 8 you finding these today and not identified during 9 one of these prior either vertical slice reviews, 10 for example, service water was one of your latent 11 issues you did in 1993, a vertical slice on service 12 water, and then you reviewed all the systems again 13 in the 97 and 99 time frame. Why do you have 14 those, the 26 potential safety significant design 15 concerns today, and were these issues previously 16 identified and not resolved?
17 MR. POWERS: I think there is two reasons for 18 the first part. Any time you bring a different 19 individual into play in terms of coming in and 20 asking questions, that individual, engineer, 21 technician will bring his or her own unique 22 experiences and background to the job to ask COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
61 1 questions. They have gone through and seen 2 problems in their careers and they bring that 3 unique perspective to asking questions, so any time 4 you bring in a new person, a new team, this is the 5 important reason for independent verifications in 6 the industry, you are going to get different 7 questions.
8 So that is one reason why we see 9 additional questions. Every time we inspect a 10 system we will see questions. The other thing is 11 that with time the industry improves and the 12 questions also change and improve as we discover 13 issues with the plants, both your organization as 14 well as our own. The Institute of Nuclear Power 15 Operations will issue an operations bulletin, and 16 we learn, and communications, its the same thing 17 with the engineers and technicians who inspect or 18 assess, they also learn. And so methodologies 19 change, technology changes and the questions 20 change. So from year to year we will seek new 21 questions being asked, but in general the questions 22 that are being asked is -- are consistent with COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
62 1 those that have been asked over time, and 2 subsequent to which the systems were determined to 3 be operable and functional, and thats why we feel 4 we are dealing in the same set of cards, if you 5 will, as we go through the issues that have been 6 raised now.
7 And some issues have been known to 8 exist before. There is quite a large number that 9 are new, but there have been some that were raised 10 in the past and either have been satisfactorily 11 disposed of in the past and are being raised again 12 or were not satisfactorily disposed of, and in the 13 cases I alluded to earlier on the design base 14 validation, we knew there were a number of issues 15 and calculation updates we needed to follow through 16 on, which we have not done aggressively, and so we 17 know there are some areas where questions were 18 known and need to be followed up on more 19 aggressively.
20 MR. GROBE: Id like to focus on the 26 21 potential safety concerns. Had any of those been 22 previously identified and not adequately resolved?
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
63 1 Ken, let me ask you that question.
2 MR. BYRD: Two of the issues were directly 3 identified in the design basis validation program.
4 One of those was a water temperature, minimum 5 temperature, the other one was the flooding one I 6 had mentioned before, the flooding calculations 7 issue.
8 MR. GROBE: And those were CRs that were 9 issued in the 97 to 99 time frame on those two?
10 MR. BYRD: Actually, in the 97 to 99 time 11 frame they had been evaluated, and then there had 12 been a request for assistance initiated concerning 13 the flooding issue which had now been completed.
14 The temperature issue had been evaluated as not 15 being a concern, which was probably an incorrect 16 evaluation, although we have subsequently agreed on 17 the calculations, and there is a concern that there 18 was no subsequent change of the 97 time frame, 19 should have gone back and redone the calculation.
20 MR. GROBE: And so 24 of the issues had not 21 been previously identified?
22 MR. BYRD: Not directly. In other words, the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
64 1 two I mentioned were ones that were directly 2 identified.
3 MR. GROBE: Jim, I understand your comments 4 with respect to the vertical slice reviews, those 5 are normally more of a sampling type review, but 6 the design basis validation program, and in a 7 sampling review oftentimes the individuals bring 8 specific questions to look at, but in the design 9 basis validation program, that should have been a 10 comprehensive look at all critical design 11 parameters, isnt that what it was?
12 MR. POWERS: The intent was to look at the --
13 for the maintenance rule, risk significant rule 14 analysis in support of their functions, and yes, it 15 was intended to be a comprehensive assessment.
16 MR. FARBER: Jim, lets go back to the 17 program itself because Lew made the comment that 18 the 1997 response was -- you know, back to the 19 N.R.C. was well written, but that the actual 20 execution didnt measure up to the level of 21 response. Could you be a little more detailed 22 about how that came about, you know, why didnt the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
65 1 execution match the quality of the response?
2 MR. POWERS: Yeah, I will give you my 3 perspective on that. And if we look at the 4 timeline over here you can see we kicked off the 5 design base validation right subsequent to our 6 50.54(f) letter response, this time frame. And you 7 can see that the -- that that program proceeded on 8 through 2000, working up responses. There was 9 follow-up responses to 50.54(f) process, and as Ken 10 had indicated there was a collection of issues that 11 were out of that review that were considered to be 12 requests for assistance level actions that need to 13 be taken through, improved calculations prepared, 14 calculations that were missing.
15 It was felt that it was work in the 16 configuration management design control area that 17 needed to get done, but it could get done on a 18 project standing aside from the corrective action 19 program, if you will, as a project. Now, projects 20 need to be funded, and this project did not get 21 done as, you know, getting resources applied to it 22 as aggressively as it should have, and you can see COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
66 1 in the 2001 time frame there was a hiatus from 2 completing some of those calculations, and these 3 resulted in the 250 calculations I mentioned 4 earlier. And so what we found was earlier this 5 year when we looked at status on those that we had 6 to get those done promptly, so thats what we have 7 been doing this year.
8 MR. MYER MYERS: We bounded that in April.
9 MR. POWERS: That is correct.
10 MR. MYER MYERS: Since we found out about it, we 11 went after it, we just have not been as responsive as 12 we should have.
13 MR. FARBER: Wasnt there some delay in 14 getting the reviews underway?
15 MR. POWERS: Initial review?
16 MR. FARBER: Yeah.
17 MR. POWERS: Not that Im aware of, not that 18 Im aware of.
19 MR. FARBER: The reason I bring that up, it 20 was my understanding that initially the system 21 reviews of the maintenance rule risk significant 22 systems were going to be done by in-house COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
67 1 engineers, but there was not enough folks to get it 2 done, so ultimately it was contracted out and some 3 of those were -- at least it wasnt issued until 4 2000.
5 MR. POWERS: Yeah, that could be right, that 6 is probably right from a resource applied to it 7 perspective. And the answer is yes, you know, we 8 could have done better, we should have done better, 9 and I think part of the lessons learned from this 10 whole episode at the plant is focus appropriate 11 attention on activities like this, this sort of 12 design base maintenance and responsiveness 13 questions, so yeah, we could have done better in 14 those areas.
15 MR. GROBE: The design base validation 16 program, the 36 system maintenance rule, 17 significant systems so far in the latent issues 18 reviews, which I think are aware of the majority of 19 these 26 significant questions; is that correct?
20 MR. POWERS: (Indicating.)
21 MR. GROBE: You looked at five systems. You 22 have indicated that the design base validation COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
68 1 program, and these are design reviews you did, 2 consistently showed that the systems were operable 3 and capable of performing their safety function.
4 Now, you have looked at five systems and identified 5 26 areas where you cant answer that question yet.
6 What does that tell you regarding 7 the quality and scope of the prior design reviews?
8 MR. POWERS: We feel in the case of the 9 design base validation that it covered a lot of 10 ground. We did a lot of checking of the 11 calculations. We prepared revisions or new 12 calculations.
13 In a number of cases and, you know, 14 also a number of discrepancies that we have 15 disposed of. However, there were areas that we 16 feel that it did not answer questions. There has 17 been specific questions raised as part of our 18 latent issues reviews and the inspection activities 19 that the design base validation program did not ask 20 that question.
21 So in those cases, we were not using 22 it to take credit for its completeness in those COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
69 1 particular areas, and we will be evaluating that.
2 Bob will talk to that in his description of the 3 plan that we have put forth on resolving these 4 design questions, and then again I would say, you 5 know, a couple of the design base validation with 6 systems assessments and inspections, and in some 7 cases those inspections being very deep slice, 8 vertical slice reviews, multiple, week-long 9 reviews, such as architect engineer inspections, 10 and come back and we will ask other questions that 11 require substantial engineering time to evaluate is 12 something that does happen as you change reviewers, 13 as you change technologies and evaluators, I would 14 expect that there will always be questions raised.
15 So do I condemn the activities that have been done 16 in the past? No, not at all. I think they were 17 done with the intent to do a comprehensive and 18 technical quality job.
19 We, a licensee sought out resources, 20 appropriate resources to do that, and in the case 21 of design base validation, we utilized a major 22 architect/engineer in the industry who had done COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
70 1 similar type of calculation programs at our plants, 2 and I think those were good efforts that were 3 performed. I think there is areas where they need 4 to be improved though, Jack.
5 MR. MYER MYERS: Let me answer that, too. We have 6 some industry experience from our contractors that 7 worked at a lot of plants, some very few plants.
8 When Davis-Besse was designed, we all had slide 9 rules, you know, and we have come a ways since 10 then. I have worked at some of those plants too.
11 But some of the modern plants that I have looked at 12 have very detailed, very detailed Id say design 13 bases. I have confidence if you went out and did a 14 latent issue review and brought in engineers from 15 five or six companies and turned them loose and go 16 ask questions, theyd give you a three percent 17 error rate consistently, and if you do it again, 18 they will give you another three percent error 19 rate. If you do it again in five years, it will be 20 three percent.
21 They will ask you five or six 22 questions, and every one of these design engineer COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
71 1 reviews I have ever been through, you are going to 2 have to scratch your head and try to answer, you 3 know, that you just dont know the answer to, but 4 you have to go out and do an engineering calc or 5 some reviews to try to answer those questions.
6 And you heard us go through some of 7 the 26 questions already. You know, I think its 8 fair to say that we know the answer to a bunch of 9 the 26 questions already, and we are finding the 10 calcs, you know, and we are able to -- we can do 11 other engineering reviews. Davis-Besse is a fairly 12 old plant, like many others, but even though the 13 new plants that are plants that have been recently 14 redesigned with new design basis documents that I 15 have worked at, when you go back and do the latent 16 issue reviews, you will get a three percent error 17 rate or three percent questions, and there will be 18 a couple of them that will just make you scratch 19 your head.
20 So I think that the key is that we 21 havent found anything yet thats caused us to go 22 out and say we are going to have to redesign a COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
72 1 system or something like that.
2 MR. GROBE: I think by and large we agree 3 with you, that certainly every time you send a 4 capable, inquisitive group of design engineers into 5 a system, you are going to find good questions.
6 And I think this discussion, Jim, that you have 7 provided is a good foundation for ongoing dialogue 8 on the condition, and maybe its time to move into 9 that. The issue that I struggle with is making a 10 judgment on the adequacy of extended condition 11 without knowing the answer to those 26 questions.
12 Why is it that we dont have those answers yet? We 13 have been talking about this for a month or two.
14 MR. POWERS: Its based on the large number 15 of questions, you know. As Alex indicated, we did 16 have a number of competent question askers working 17 at the plant for several months and generated in 18 fairly short order, and by that I mean over several 19 months, a large number of condition reports, not 20 all of which are in this population of the 1,200 we 21 are talking about today, or there are many other 22 questions that are being asked.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
73 1 There is also a high level of 2 activity at the plant in terms of improvements, 3 modifications to the plant to improve it. Design 4 engineers and system engineers are engaged in many 5 of those activities. The system engineers were 6 engaged in -- focused on getting their reports done 7 for the latent issues report and system health 8 review, and those reports were issued out on the --
9 geez, I want to say on Thanksgiving week or the 10 week after Thanksgiving we got those completed. So 11 relatively recently they have been able to put 12 their pen down and turn their attention to the 13 condition reports.
14 Now, Ken Byrds area is one of the 15 major ones that is dealing with questions, and hes 16 got the task of sorting those questions out, 17 getting them in a logical sequence, because not all 18 independent questions, if you ask a question on the 19 alternate heat sinc sink, the lake temperature, that 20 temperature can affect the heat exchangers that are 21 cooled by service water within the plant, and the 22 question on heat exchangers in the plant, and you COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
74 1 have got two different questions that relate to 2 each other, so Ken has carefully tried to lay out 3 the logic on how he worked through the process of 4 anticipating the questions logically, and it takes 5 time, Jack. They are complex, technical issues 6 that merit some introspection and evaluation, and 7 thats taken us some time.
8 MR. MYER MYERS: Of the 26 issues right now we have 9 most of those bounded, dont we?
10 MR. POWERS: I would -- we have answered --
11 of the 26, we have answered about eight of them.
12 Ken, why dont you give us a picture on that.
13 MR. BYRD: Of the 26 issues, right now I 14 would say that approximately a third of them we 15 have an answer for. We may not have it all the way 16 run through and documented. Probably another third 17 we are still looking at, and then probably other 18 third we know where were going to go, and that 19 would be probably a rough estimation as to where we 20 are right now.
21 MR. GROBE: When are we going to start 22 answers on those 26 issues?
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
75 1 MR. POWERS: We are targeting the end of 2 January to have the bulk of our condition reports 3 worked through, and that is ongoing as to the 4 process that Bob will describe. Kens being 5 engaged now, hes got projects going on each of 6 those questions, and activities, and we are still 7 -- we are still engaging more technical resources, 8 bringing in some of the original designers of the 9 plant, for example, to help us through this 10 process, and we are trying to -- we are trying to 11 balance having the appropriate level of resources 12 at the site to manage effectively and make sure we 13 get a good quality of work versus the timeliness of 14 supporting the -- answering these type of questions 15 and proceeding with our activities for restart of 16 the plant.
17 So that as you know, we did have a 18 reduction in the contractor population around the 19 Thanksgiving time frame for precisely those 20 reasons. We were finishing up discovery, and we 21 felt that we needed to get to a contractor level 22 that we could effectively manage and assure that we COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
76 1 were controlling, and production at the appropriate 2 quality of work, and those are some of the issues 3 that Ken worked through as he answers these 4 questions.
5 MR. MYER MYERS: We believe the end of January, 6 right, we will have all those bounded up?
7 MR. BYRD: Thats what were aiming for, the 8 end of January.
9 MR. MYER MYERS: Was that your question?
10 MR. GROBE: It was. And like I said, I dont 11 understand how we can fully put a full context on 12 what you have done to date and what needs to be 13 done going forward without those answers. Three 14 percent failure rate is very low. If all three 15 percent was operability questions, that is very 16 significant. If none of them result in operability 17 questions, then that is also very significant, and 18 so its -- as far as these decisions, these 19 cross-cutting areas that you have identified, and 20 environmental qualifications, these are areas that 21 you shouldnt be identifying today in 2002 as 22 cross-cutting concerns in your design engineering COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
77 1 programs.
2 However, if none of them have 3 resulted in operability questions, then thats 4 pretty good. If at least some of them have, then 5 thats a horse of a different color, as they say in 6 the Wizard of Oz. So I think we need these answers 7 to be able to make any judgments on questions 8 before us.
9 Why dont I ask for any more 10 questions on Jims presentation, and then we will 11 give our transcribers fingers a rest for a few 12 minutes.
13 Bill Dean, anything at headquarters?
14 MR. DEAN: Nothing here, Jack.
15 MR. GROBE: Why dont we take -- its 10:32, 16 why dont we take a break until 10:40.
17 Thank you.
18 (Whereupon, a recess was 19 had, after which the 20 conference resumed as 21 follows:)
22 MR. GROBE: We just finished the historical COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
78 1 dialogue from Jim Powers, and I think Bob Schrauder 2 is going to describe the resolution process.
3 MR. SCHRAUDER: Okay. Thank you, Jack. Now 4 we have identified questions, reiterated questions.
5 We dont know yet whether they are actually issues.
6 They are potentially safety-significant questions 7 that have been raised. Now you have got to figure 8 out, what does that mean to all the rest of the 9 systems that have resolved that determine your 10 condition and how do you determine whether, in 11 fact, it is safety significant, and thats what the 12 plan that Im going to describe goes through.
13 Its a comprehensive plan that is 14 intended to provide assurance that these 15 potentially safety-significant issues are 16 identified and resolved. We can verify the 17 technical specifications, operability is met, 18 safety systems, structures and components will, in 19 fact, perform their safety functions. And then 20 just as importantly, what is the extent of the 21 conditions of these issues or questions that we had 22 identified. I will tell you that we have looked at COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
79 1 -- some of what we have looked at, some of the 2 issues that we have brought up, the majority of the 3 design-related condition reports, and that I want 4 to keep reiterating, that is fundamentally what we 5 are talking about is the design-related condition 6 reports.
7 92 percent of them that have been 8 identified for restart are not potentially safety 9 significant. We looked at nearly 600 CRs that were 10 flagged for restart, these design-related condition 11 reports, 40 of those condition reports fell into 12 the category of potentially safety significant or 13 having potentially significant impact on the 14 Chapter 15 analysis, and those 40 individual CRs 15 then when you compile them together constitute the 16 26 potential issues that we talked about.
17 Then there is another approximately 18 36, I believe, condition reports that we say have a 19 potential -- if correct as written, they have minor 20 impact on the Chapter 15 analysis. By and large, 21 the calculations related questions are the ones 22 that dominated the potentially safety significant COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
80 1 questions that were raised.
2 So Lew had talked about the three 3 parallel paths that were taken. The primary path, 4 if you will, is each individual CR has a -- what we 5 described as taken through the control room for an 6 operability determination. And if there were 7 operability issues taken to an extended condition, 8 so you look at each condition report individually.
9 Then we go out and do a validation of the risk 10 significant safety functions, and also resolution 11 of our topical issues. So what we have is a CR 12 process for the individuals. We did this potential 13 safety significant impact or potential impact on 14 the Chapter 15 analysis, and then we did a 15 collective significance review as another activity 16 here.
17 The diagram that is shown on 22, 18 and, Jack, this has been just subtlety altered.
19 You had a preliminary one, and there is really not 20 many changes to it, but I will describe those as we 21 walk through it. These are the three flow paths 22 that we will talk through. And those of you that COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
81 1 have the handouts, I might suggest that you keep 2 this one in front of you as we go through these, 3 and the individual paths are reproduced on the 4 slide as we get to them.
5 On Page 23 you see the three paths.
6 Path A is the resolution of each individual 7 condition report and determine extent of condition.
8 Flow Path B provides evaluations or additional 9 assurance of significant safety function 10 capabilities. And Flow Path C resolves those 11 topical issues that we talked about earlier.
12 Lets talk about the -- Path A is on 13 Slide 24. The condition report comes in initially 14 and goes to the control room.
15 You can see that it can be answered one 16 of two ways, its either -- one of three ways.
17 Its operable, its not operable or we dont know, 18 we need to do further evaluation.
19 If its not operable, its -- as you 20 recall, it went over to the restart station review 21 board, and that was one of the changes that I made 22 is that block coming out of the shift managers went COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
82 1 over -- I initially said it would be restart, but 2 there is another screening -- it would be 3 post-restart. There is another screening that 4 needed to go through, and that is restart station 5 review board. And even though it may be operable, 6 there were a lot of those that we said needed to be 7 evaluated prior to restart anyway.
8 If its not operable or required 9 further evaluation, its going into the detailed 10 evaluation triangle there. If we, in fact, find 11 that the condition is not valid, it moves back 12 around to the control room where the shift manager 13 can agree or disagree with that and make his final 14 determinations on operability.
15 If its a valid condition -- Im 16 going to have to pull this out too because I cant 17 read the screen. If its a valid condition, the 18 detailed evaluation can result in several things.
19 Either the system function is not operable, its 20 operable but degraded or its not operable, but it 21 is within the design basis. Those are the three 22 paths that we show there. And if you say its COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
83 1 operable but degraded, you may come up with 2 compensatory actions required under a generic 91-18 3 evaluation. You would then obviously send those 4 compensatory back down to control room to get their 5 concurrence.
6 If its not operable you have to 7 take remedial action, obviously, to restore 8 operability, discuss that issue with the shift 9 manager and also there needs to be a root cause 10 analysis and preventive actions to prevent 11 recurrence.
12 You see that we have identified that 13 as not necessarily a restart required activity in 14 that many of the issues that we have coming out of 15 here, we believe are going to be the same type of 16 root cause issues that we found in our root cause 17 reactor vessel head. We can take the remedial 18 action and restart the system to operable without 19 having the root cause of how did you get there and 20 what preventive actions are you going to take to 21 make sure you dont get there in the future, but we 22 do need to go through that process.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
84 1 The other block down the path is 2 its not operable but its within the design basis.
3 That is, the design calculations may support the 4 condition, but it didnt meet the literal 5 compliance with the tech specs, that maybe there is 6 a specific value that the tech spec would call out 7 that you have to meet, and that in fact would 8 render the system inoperable if it didnt meet 9 those surveillance requirements, for instance. In 10 that case we may, if the design basis supports the 11 new value, you may need to come in with a licensing 12 action to change the specs back to a more correct 13 value.
14 Now, the two paths of not operable 15 or not operable for either reason comes down and it 16 splits there and goes two paths, obviously goes 17 back up to the control room to let them know the 18 condition of their systems, and then it also goes 19 to the extent of conditional path, and that is the 20 path that says weve got to determine your extended 21 condition, and that extended condition report, we 22 say if its in this safety function validation COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
85 1 project, which we are going to talk about a little 2 bit further, if its in the scope of that or if 3 its within the scope of what was looked at in the 4 design basis validation project on the system 5 health reviews, or its one of these topical issues 6 that we have talked about in Path C, then the 7 extended condition we believe is bounded.
8 If its not covered, if those 9 activities that have taken place or are ongoing, 10 then we need to determine the extent of condition 11 and how you might go about determining the extent 12 of the condition if its not covered there. And 13 that is Flow Path A.
14 MR. MYER MYERS: That gets into that question you 15 asked earlier about could you identify the topical 16 areas. The answer is yes, you do.
17 MR. SCHRAUDER: Then we look at what I will 18 call Flow Path B, and that is the safety 19 consequence of potential issues that you look at, 20 as we discussed.
21 MR. GROBE: Before you go on, Im a little 22 concerned. Maybe its just a choice of words, the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
86 1 big diamond at the right-hand corner, is your 2 decision for extended condition within the scope of 3 one of these several programs, then the extended 4 condition is bounded. What you mean I think if I 5 understand correctly is that the extent of 6 condition should be bound once you complete these?
7 MR. SCHRAUDER: That is correct.
8 MR. GROBE: Okay. Got it.
9 MR. SCHRAUDER: Those, in fact, would 10 constitute the extended condition by going through 11 the significance determinations and the like.
12 MR. GROBE: Okay.
13 MR. SCHRAUDER: So Flow Path B, we know that 14 we have a lot of the CR questions that were raised 15 and have potential safety consequence, so we are 16 working with M.P.R. on what is really a two-phased 17 program. Let me talk about Flow Path B and C 18 together for just a minute. In those two paths, we 19 are looking at the collective significance and the 20 potential safety significance for these issues.
21 And they both identified one common theme, and that 22 is a lot of the issues, or a vast majority of the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
87 1 issues are related to those calculation issues that 2 we have talked about.
3 And then the collective significance 4 review also identified the topical issues which we 5 referred to, and those being the high energy line 6 break, EQ, seismic qualification, Appendix R and 7 flooding issues. But two of those paths show the 8 calculational issues or concerns that need to be 9 addressed, and so Phase 2 of that evaluation 10 process is to do the safety function validation 11 project.
12 So Phase 1 said each of the CRs is 13 reviewed to see if it has a potential impact on the 14 safety analysis to determine that if properly 15 screened, horizontal reviews are likely to discover 16 the similar nonconforming conditions and systems 17 not covered by the latent issue reviews or the 18 assessments that were done for the N.R.C.
19 inspections, and then, three, to identify what 20 those further actions are that are necessary to 21 determine whether, in fact, they are safety 22 significant. So Phase 1 had three objectives that COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
88 1 we were trying to meet. In Phase 2, completes the 2 actions necessary to determine the actual safety 3 significance and perform extended condition review 4 on other systems.
5 The -- that piece of the program, 6 the safety function validation project, which is 7 what Im referring to as Phase 2, it will perform 8 evaluations of findings that contribute more than 9 one percent of the core damage frequency, and for 10 our plant those functions that contribute more than 11 one percent of the core damage frequency are 12 comprised of 15 systems, and they relate to, as you 13 see down further, the 99 percent, practically 99 14 percent of the core damage frequency and the large 15 early release frequency.
16 Five of the fifteen systems have 17 already gone through the latent issue review. Two 18 of the systems that still need some further looking 19 at but have gone through the self-assessment in 20 this population also. So if you look at the next 21 page, it lists the 15 plant systems that will be 22 subjected to the safety function validation COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
89 1 project.
2 Do you have a question, Jack?
3 MR. GROBE: Go ahead 4 MR. HOLMBERG: Well, the question I have is 5 on Path C. You get into resolving of topical 6 issues, you have got a line on the far right that 7 talks about EQ -- HELB and EQ, and Im trying to 8 understand what types of examples of things would 9 fall into that? Like for instance, in my mind Im 10 picturing a component, for instance, that lets 11 suppose its either related to the cooling system 12 on safe shutdown of the plant, component needed for 13 one of those functions, and its vulnerable to 14 hydrogen line break, for the sake of argument, if 15 that component, for instance, has not been 16 evaluated before and you are trying to pick out 17 whether you were required to evaluate or not, I 18 mean its true maybe that if it cannot function, 19 you would have an impact, but it may be a licensing 20 question, i.e. was I originally designed or 21 required to have health protection in all areas or 22 not? Is this the path that it would be on on the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
90 1 right side there if you had that kind of question?
2 MR. SCHRAUDER: That would be in Path 3 Charlie, that is correct 4 MR. HOLMBERG: So even though you have a 5 vulnerability protection, if its a licensing 6 issue, it would be on the very far right and would 7 not necessarily fall into a bin that would be a 8 restart type CR?
9 MR. SCHRAUDER: No, no, no. Just because 10 its in the topical issues, in the licensing 11 issues, does not mean that it wouldnt be resolved 12 prior to restart.
13 MR. HOLMBERG: Okay.
14 MR. SCHRAUDER: So those programs, again 15 HELB, EQ, all of those programs will have 16 assessments done programatically on those issues 17 and determinations made of what conditions need to 18 be resolved prior to restart and which ones dont 19 have to be resolved prior to restart?
20 MR. HOLMBERG: And just refresh my memory.
21 If its a licensing issue or question, what would 22 be your threshold for throwing it in one bin or the COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
91 1 other?
2 MR. SCHRAUDER: The threshold would be it was 3 required to be evaluated, environmental 4 qualification, and if it hasnt been, it will be 5 required to be looked at prior to restart.
6 MR. HOLMBERG: Thank you.
7 MR. GROBE: If I understand the logic that 8 you selected 15 systems, if you review these 15 9 systems, I think, if I understand correctly, you 10 will have evaluated 99 percent of -- you will have 11 evaluated the functions, that if they are adequate, 12 will contribute 99 percent of the core damage 13 frequency reduction in the event of an accident, 14 but isnt that evaluation of core damage frequency 15 in large early release frequency contingent upon 16 all other systems and functions performing 17 adequately, that there were no other design issues?
18 For example, one of the systems not 19 on your list is the reactor protection system, and 20 one of your cross-cutting concerns is environmental 21 qualification. If you have an environmental 22 qualification concern with some of the components COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
92 1 that contribute to the reactor protection system 2 and the reactor doesnt shut down, doesnt that 3 affect your core damage frequency calculations and 4 the importance of these 15 systems?
5 MR. SCHRAUDER: First of all, Im going to 6 let Ken -- Ken is our expert in the PSA world, but 7 the issue of if its an environmental qualification 8 issue that impacts RPS, its expected to catch it 9 in Path C and have that resolved prior to restart.
10 MR. GROBE: Okay. Maybe I didnt understand 11 Path C. Are you going to review all safety 12 significant systems, meaning all systems that 13 contribute to the accidents in some successor for 14 these five cross-cutting issues --
15 MR. SCHRAUDER: The --
16 MR. GROBE: -- or are you just going to 17 review these 15 systems in the five cross-cutting 18 areas?
19 MR. SCHRAUDER: The topical issues will be 20 resolved and looked at for their extent of 21 condition individually, independently of the 22 extended condition for calculation issues.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
93 1 MR. GROBE: Why dont we let you go on then 2 and get you -- why dont -- I think we have gotten 3 onto Path C so why dont we do that so we can fully 4 understand this.
5 MR. SCHRAUDER: So Page 28 identifies those 6 15 plant systems that will be included in the 7 safety function validation program. And then on 8 Page 29, we talk about the methodology that we will 9 employ, review associated calculations and/or tests 10 and confirm that they do, in fact, support the 11 function.
12 If its necessary, we prepare 13 evaluations to support operability determinations 14 for condition reports, and these things will 15 provide additional assurance that we need the 16 system structures to perform their safety 17 functions.
18 We will prepare a summary report for 19 all of the 15 systems to reach a conclusion of the 20 ability of the plant to perform its 21 risk-significant functions. We will correct any 22 operability issues obviously required to restart, COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
94 1 if necessary determine whether to expand the scope.
2 You see as we go through this process of the extent 3 of condition, if the extent of condition in going 4 through these other 15 systems identifies another 5 potential operability issue, then that kicks it 6 back into Path A that goes through, and if its in 7 fact determined to be an operability issue and its 8 not operable, that obviously results in a 9 significant condition which a further extent of 10 condition may be warranted. So of course if we 11 find additional operabilities in the review, that 12 its likely to expand the extent of condition that 13 you would need to do.
14 And then on Page 31 we talk about 15 Path C, collective significance review identified, 16 as we said, calculational issues, topical issues 17 that we have discussed several times, and then a 18 few other issues that -- things like material 19 issues I will call them, valve leakage, some 20 incomplete tread engagement procedure, some system 21 distribution, those are the types of things that we 22 are talking about under other issues.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
95 1 Now, these -- each of these topical 2 issues, as I said, it has some developing of a 3 resolution plan on its own. I think Ken can speak 4 specifically and tell us how he is going back 5 looking at the high energy line break, as an 6 example, and the flooding issues.
7 MR. BYRD: The line break we looked at, 8 collected all condition reports together, and all 9 the issues and what we found is the questions we 10 have had regarding high energy line break, there is 11 two major categories, one is postulation and the 12 other is issues involving the turbinability turbine building, 13 which is issues coming from information in 2002. Theres 14 been some other things, those are the large two 15 areas.
16 I think we have a really what to my 17 mind is a very comprehensive plan with high energy 18 line break. What we are doing is we are resolving 19 these issues on postulation, and what we found is 20 we are a pretty standard review plant and there was 21 some confusion trying to apply some of the 22 postulation, we are going back determining what COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
96 1 exactly our design basis is for this, and we are 2 going to update our design criteria manual and that 3 particular section of the safety analysis report to 4 make sure this is clear.
5 We are also going to go back and 6 review all of our analyses to determine if we have 7 any new breaks we need to analyze as a result of 8 that. My understanding in talking to our people is 9 it doesnt look like we are going to have 10 significant changes to the breaks, we are 11 postulating right now, but we want to clean this 12 up.
13 If we have any new breaks, we will 14 analyze those and make a determination. The other 15 our big issue this -- the second big issue, the 16 information in the 2002 turbinability turbine building, HELB, 17 we had been working on this prior to the shutdown and all 18 the flood questions have slowed down our resolution 19 of this because we have got a whole lot of new 20 issues, and we wanted to make sure we understand 21 all the new questions that were coming at us.
22 And the issues -- one of them was COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
97 1 the operator actions that I mentioned before. That 2 was a question that related to our turbinability turbine 3 building to -- we wanted to sort some of those things out, 4 so we slowed down the process of getting the final 5 calc out on that.
6 However, we have achieved analysis 7 -- we are completing analyzing the turbinability turbine 8 building and associated rooms, including our component 9 cooling water room, and auxiliary fuel pump rooms 10 using the most current codes, and at this point 11 that should be -- actually, the calculation was 12 complete, and nothing we have seen is really 13 changing the results significantly, but we will 14 have the final -- after we have completed it there 15 may be some changes. We should be seeing that back 16 within a few weeks, our final calculations.
17 On the EQ part, there may be some EQ 18 issues, the off-speed pump rooms we have been 19 expecting and making plans for. The other part of 20 our HELB analysis, auxiliary HELB analysis, we have 21 two major sides, the turbine side the other 22 auxiliary building side.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
98 1 There have not been a significant 2 number of questions relating that, however, in the 3 effort to make sure we are really looking at this 4 thoroughly, we are going to go back and look at 5 analysis prior to restart.
6 Our concern is potentially there may 7 be some assumptions or it could be that we did find 8 one condition report concerning barriers that were 9 not really qualified to HELB credits analysis, so 10 we do have a project going that will actually go 11 back and take that analysis, which was done in old 12 code, we are going to upgrade it, will rewalk it 13 down and look at our analysis, and that will be 14 done before restart.
15 If we find any problems, we will 16 stick that post-restart. We plan to go back and 17 evaluate all of the breaks. If we do that, 18 essentially this will go through all of our HELB 19 analysis, this plan we have prior to restart, so 20 any issues should come out of all of this, and we 21 are going to be left with a pretty up-to-date HELB 22 analysis for all parts of the plant.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
99 1 The flooding was another issue that 2 I was involved in quite a bit. We had 3 substantially fewer condition reports overall on 4 the flooding issue, and they have tended to run 5 over a variety of different issues, some are 6 procedural, some are involving testing of check 7 valves and things of that nature. The one issue we 8 have not found as many is calculational issues on 9 the flooding side.
10 We did have the one calculation 11 which I found on design validation basis, which is 12 turning out to be a non-issue. The one issue that 13 was particularly concerning to us is we did have a 14 concern over non-seismic piping on our cooling 15 water makeup pump which could affect all of the 16 service water pump room that was evaluated to have 17 been functional, but that was a significant concern 18 from an actual physical perspective on a situation 19 like that.
20 As a consequence, we are going to be 21 looking pretty extensively to see if there is other 22 conditions like that. In order to do that, what we COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
100 1 have essentially done is look at identifying other 2 places where there could be similar flooding 3 concerns, and that is component cooling water pump 4 room, specifically the emergency core cooling 5 system pump rooms, which are other potential areas 6 we could have flooding concerns, and in those rooms 7 we are going to review all the piping analysis to 8 determine if there is any other piping that should 9 have been seismic. If we had a flood concern, that 10 is -- I think that would be a fairly thorough way 11 to resolve the extended condition on that issue.
12 MR. HOLMBERG: Quick question for you. These 13 re-analyses, will this require some kind of review 14 by the N.R.C.?
15 MR. BYRD: Nothing should require review by 16 the N.R.C.
17 MR. GROBE: I guess the complete answer to 18 that question is you dont know yet, as you go 19 through the analyses you could identify something 20 that would require review?
21 MR. BYRD: That is correct. Actually what I 22 meant is we are using a different code and that COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
101 1 sort of thing, but everything we are doing, none of 2 that would require necessarily a resubmittal. We 3 could run into a problem that requires review, 4 thats true, but at this point I dont believe we 5 have any issues like that.
6 MR. GROBE: Okay.
7 MR. SCHRAUDER: On each of the topical areas, 8 there will be a plan for resolution and 9 determination of the extended condition. If in 10 fact, the questions that were raised turn out to be 11 real issues, I can tell you that environmental 12 qualifications, some of the feedback I have already 13 gotten from the guys is some more of this "didnt 14 look far enough" or "didnt understand the current 15 licensing basis of our plant," so we expect that 16 many of those issues will not be valid issues, and 17 those that are will have to be determined for 18 extent of condition, and obviously environmental 19 qualification issues in one sense they are going to 20 trail the high energy line break, so if there is a 21 high energy line break in an area that has to be 22 repostulated, it may change your environmental COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
102 1 qualifications parameters in that area also, or it 2 would.
3 MR. GROBE: There is one of your topical 4 areas that I dont have a good understanding of the 5 types of issues you have identified, and that is 6 the Appendix R safe shutdown, post-fire safe 7 shutdown situation.
8 What are the kinds of issues that 9 you have identified in this area, and what is your 10 re-evaluation scope?
11 MR. SCHRAUDER: I dont have the details on 12 the fire protection yet, Jack. As you probably 13 know, I just got into this this week, Im trying to 14 sort through all of these issues. I dont have a 15 good handle on what is identified in Appendix R 16 yet. I did talk with the system engineer on that 17 last week, he does not believe that hes going to 18 have significant issues that were identified here 19 that are going to turn out to be real issues, so 20 hes not overly concerned with them. I havent dug 21 into the specific details of that to confirm his 22 sense yet.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
103 1 MR. GROBE: It may be beneficial over the 2 next month to have more detailed discussion on 3 working level of each of those topical areas to 4 make sure we understand what the specific issues 5 are, what the extent of your re-evaluation is going 6 to be, and that will help us determine what level 7 of inspection we may want to apply in each of those 8 areas.
9 MR. SCHRAUDER: Right.
10 The next page is already asked and 11 answered, when do we expect to have determination 12 of operability, determination of safety function 13 validation project completed. We expect to have 14 that completed by the end of January. If other 15 issues fall out of that, then to we will have to 16 reassess, you know, further extent, but this 17 activity that we are looking at now, current 18 determinations of operability of questions already 19 raised and safety function validation project, we 20 expect to have done by the end of January 21 MR. FARBER: Bob, what resemblance will the 22 reviews conducted under the safety function COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
104 1 validation project bear to the latent issues 2 reviews on the five systems, if any?
3 MR. SCHRAUDER: They will look at the depth 4 of -- again, it is aimed at the calculational 5 issues, so it will look to that level of depth in 6 the calculational -- MPR you have a -- would you 7 like to ask Alex what is --
8 MR. FARBER: The key is latent issues review 9 evaluated some 31 attributes in detail and now what 10 Im hearing is the safety function validation 11 project will evaluate some additional 10 systems, 12 but only in the calculational area. Im not sure 13 if that is -- if my understanding is correct or 14 not.
15 MR. ZERECHMAK: That is the correct essence 16 of the review. The purpose coming out of it is not 17 to redo the latent issue review for a number of 18 different systems, but is to take advantage of the 19 lessons that we have learned both from the LIR and 20 the safety consequence review, which both pointed 21 to calculations being a key issue for those issues 22 that affect safety functions. And so we are COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
105 1 sitting back and saying, okay, if my goal 2 ultimately is for it to be sure that my plant can 3 satisfy safety functions, what do I have to do?
4 And the answer for these additional 5 systems is identify what the safety functions are 6 and confirm that I can meet those mitigation 7 functions, either by calculations or by test, and 8 if I can -- if I can find a calc and demonstrate 9 either by calc or testing that I can meet those 10 safety functions, then I have done two things, 11 provide assurance that I can meet safety functions, 12 which is probably the most important thing, and in 13 addition, what I have done is an extended condition 14 for the calculations as they support or do not 15 support the safety functions.
16 MR. SCHRAUDER: Part of the Phase 1 also --
17 Alex, correct me if I am wrong on this -- we went 18 through and we looked at all of these issues that 19 were identified, or questions that were identified 20 that did have potential safety significance, and 21 asked the question of whether this detailed look 22 from a calculational perspective would have COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
106 1 uncovered those issues, and in most of those cases, 2 the answer was yes.
3 Things that werent were things like 4 what Ken had asked or said before, that an operator 5 had questioned whether given a current philosophy 6 in three-way communications and some other things, 7 do we have sufficient time to take the operator 8 actions in the time that we are specified. I 9 recall that that is one of the examples, but nearly 10 all of these things, or very many of them would, in 11 fact, have been identified in the calculational 12 review that we intend to do on the additional 13 systems.
14 That was part of the process for 15 Phase 1, to determine whether this process was 16 likely to uncover the remaining issues.
17 MR. GROBE: Mel, Marty, any other questions?
18 (No response.)
19 MR. GROBE: Bill and John in headquarters, do 20 you have any questions?
21 MR. HOPKINS: Is there a plan to update the 22 50.54(f) response to us?
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
107 1 MR. POWERS: We will evaluate that, John, and 2 determine, based on collectively what we find. To 3 the extent that we need to do that and if we do, we 4 will.
5 MR. MYER MYERS: Id like to add that, you know, as 6 we come out of this program we are in, I think we 7 have already made a commitment that we still see 8 the significance of those type of reviews. We need 9 to go back and do them. We didnt do as good a job 10 as we should have. We are going to do some now, 11 and we are going to commit to do some additional 12 latent issues reviews going forward now with all 31 13 attributes, you know, so I think we have already 14 committed to do that, and we need to go back, and 15 based on the letter we sent back to you, the 16 50.54(f) letter, we could do a second letter, but I 17 dont know that we need do that. I think we have 18 already made that commitment. If we do, we will.
19 MR. FARBER: I guess the thing that Im 20 trying to make sure that I appreciate is that you 21 have a good, sound technical basis for only looking 22 at these calculational issues for these ten systems COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
108 1 and not looking at other inspection attributes.
2 Now, I understand that you did a 3 system -- health system readiness review that 4 covered a number of attributes, but there are 5 attributes that the system health readiness review 6 did not cover, and calculations was but one of 7 them. So Im trying to understand why you feel 8 that you have a solid technical basis for not 9 looking at some of those attributes that werent 10 covered under that and why you are limiting it just 11 to the calculations.
12 MR. POWERS: Our collective significance 13 review focused on latent issues, Marty, looked at 14 all the routes from 31 topical areas and went 15 through that process and determined where we needed 16 to focus on, one is calculation quality, and then 17 the five topical areas we discussed before, 18 environmental qualification, high energy line 19 break, etc., those five areas we felt were the ones 20 we needed to focus on pre-restart to nail down 21 status there and provide its position.
22 There were other areas from COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
109 1 collective significance that we intend to pursue 2 following the restart, and that is things like the 3 maintenance and quality of our system design 4 description manuals. There were some -- there is 5 further issues that we need to do that is going to 6 take us through those other systems, so its not as 7 if -- its not as if we are not going to do that 8 further work on those system health review level 9 systems. For example, environmental qualification, 10 high energy line break, they will go to the extent 11 necessary, where the CRs have been held, they will 12 determine what extent of condition they need to be 13 taken through those systems, and areas of 14 collective significance similarly will not just be 15 focusing on five latent issues system, they will 16 have plans that extend them to the other population 17 of systems. So in that sense we think the latent 18 issues review served its purpose. We found areas 19 of weakness, we have characterized whether they are 20 pre-restart or post-restart that need to ensue, and 21 we will be laying forth plans to carry those 22 forward as much as can be limited to five latent COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
110 1 issue systems.
2 MR. FARBER: Thank you.
3 MR. MYER MYERS: Did that answer the question?
4 MR. FARBER: (Indicating.)
5 MR. GROBE: Let me make sure I understand the 6 scope of the safety function validation project.
7 For those systems that have already been through a 8 latent issues review or self-assessments prior to 9 N.R.C. inspection, I think that is a total of seven 10 systems. Are those systems going to receive 11 additional review under the safety function 12 validation project?
13 MR. SCHRAUDER: The five systems that were 14 looked at under latent issue reviews will not. The 15 two systems that were done as self-assessments will 16 be looked at to the extent that they were not 17 looked at for this aspect when self-assessment was 18 done.
19 MR. GROBE: Okay. Any other questions from 20 headquarters?
21 MR. HOPKINS: No, we dont have any other 22 questions.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
111 1 MR. GROBE: Okay.
2 MR. MYER MYERS: You know, one of the things we 3 came in with a latent issue review is -- you know, 4 that is not easy for us to pull up our information, 5 we are still finding it. And you know one of the 6 things we installed over at our other plants is a 7 system called Atlas, and our engineers use it, we 8 got good feedback.
9 That was one of the issues that we 10 are talking about here, and I believe that we will 11 do that as we do the latent issue reviews after 12 restart. It took us several years to get all of 13 our information in Atlas in the other plant, but 14 its our intention to use Atlas in all three of our 15 plants, and we have that in our program, so that is 16 something we would do after restart.
17 But anyway, in closing let me say 18 this: None of our system reviews that we did, and 19 as part of the system building block reviews today 20 have resulted in any systems not supporting 21 functionality or operability. Theres been some 22 tough questions there, but we think we have most of COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
112 1 those questions, at least 66 percent of the 26 2 areas are bounded now. So why should we go 3 further? Why should we go further? Well, the 4 reason we should go further is because we told you 5 we would. We didnt do as good a job responding as 6 quickly as we should to the 50.54(f) letter, and we 7 told you as part of the system health building 8 block that we would identify issues, categorize 9 those issues and increase the scope as necessary.
10 Thats what we are doing.
11 Prior to restart we will resolve the 12 topical areas, we will validate the most 13 risk-significant function capability, we will 14 address the operability issues to the extent of 15 condition.
16 Completion of these items will 17 ensure -- I believe will meet the objectives of 18 ensuring that we are reliable and safe. If we 19 find issues that are significant concerns, then 20 additional actions will be required. We dont 21 believe with the information we have today that 22 that will be the case, but if we do, we will COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
113 1 increase the scope.
2 Thank you.
3 MR. GROBE: Okay. Bill, did you have any 4 final comments or questions that you wanted to 5 make?
6 MR. DEAN: Just that we will wait and see 7 what results out of this, and I think this is a 8 good opportunity for the licensee to demonstrate, 9 you know, some of those things that we have talked 10 about relative to safety focus and showing the 11 persistence to continue to look at these issues and 12 continue the communication. This is a good 13 opportunity for the licensee to do that for us.
14 MR. MYER MYERS: Can I comment on that? You know, 15 the easy thing is if we can take these 26 issues 16 and bound them would be to come back to the 17 regulator and say that -- and say we did what you 18 told us to, increase the scope as we did. I think 19 that says something, and it says that we are 20 interested in validating that we have a safe plant, 21 and that is an additional scope for us, but we are 22 going to do that.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
114 1 MR. GROBE: Okay. Well, I certainly 2 appreciate this, its been very informative. I 3 think we still have some questions outstanding, so 4 that the dialogue needs to continue.
5 I particularly appreciate you coming 6 in on December 23rd. I know that this has an 7 impact on everybody, its a busy time of the year, 8 and I appreciate you coming in on this date.
9 I believe that based on the 10 conversations we have had amongst the panel members 11 that should you not identify in these 26 current 12 issues or any additional issues as you go through 13 your system function validation project for the 14 additional ten systems, if you identify no safety 15 function problems, then I think we would be 16 comfortable that this is a robust review that will 17 support your conclusion that the plan provides 18 reasonable assurance that Davis-Besse is ready to 19 support safe and reliable plant operation.
20 If, in fact, you identify that plans 21 as they are currently -- as they currently exist in 22 the plant would not support safety function, then I COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
115 1 think we need to step back and ask ourselves that 2 question a little bit more thoroughly and look at 3 other systems that you are not evaluating and 4 possibly look at what you are planning after 5 restart to support our thinking on whether or not 6 we can comfortably agree with your conclusion.
7 So I think that the question is 8 open. Its absolutely critical that we have the 9 answer to the 26 issues, and also that you proceed 10 with these cross-cutting areas, the topical issues 11 as you call them and that we understand the safety 12 impact of those. And whether you identify any 13 further operational issues, operability issues as 14 part of your validation project. So I think the 15 dialogue needs to continue.
16 Who is the principle point of 17 contact that we should use for the topical issues, 18 is that you, Bob?
19 MR. MYER MYERS: Bob.
20 MR. GROBE: And we will be getting a hold of 21 you and making sure that we understand who are the 22 leads in each of these areas that we can get more COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
116 1 information from and understand exactly what the 2 issues are and what you are doing with those design 3 areas. And we are also going to be looking at the 4 safety function validation project in detail to 5 make sure we understand that.
6 So I think this has been a highly 7 successful meeting. We understand the landscape.
8 I dont believe we are able to agree with your 9 conclusion today, but we understand what we need to 10 do to go forward.
11 So with that Id like to complete --
12 unless you have any other comments, Id like to 13 complete the business portion of this meeting and 14 go to the public question and comments section of 15 the meeting.
16 The way wed like to address this 17 section of the meeting is to first ask if there is 18 any members of the public here in the Region III 19 office that have any questions or comments for the 20 N.R.C. staff and then move to any folks that were 21 in the headquarters offices and then move to folks 22 that are on the phone.
COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
117 1 So why dont we start here in Region 2 III, is there anybody here that has a question or a 3 comment that they want to make, please step up to 4 the microphone.
5 (No response.)
6 MR. GROBE: Weve got a happy, satisfied 7 bunch here, okay, good.
8 Bill, do you have any folks there at 9 headquarters that have any questions or comments 10 that theyd like to make?
11 MR. DEAN: We have one individual here, and 12 they declined our offer to make a comment or ask a 13 question.
14 MR. GROBE: Okay. At this time Id like to 15 ask the operator on the phone whether or not she 16 has any folks on the phone that have questions or 17 comments?
18 MS. HOUSEMAN: If you would like to make a 19 comment, please press Star 1 on your touch-tone 20 phone.
21 (No response.)
22 MS. HOUSEMAN: Once again, to ask a question, COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
118 1 please press Star 1.
2 (No response.)
3 MS. HOUSEMAN: Im showing no questions at 4 this time.
5 MR. GROBE: Well, thats a first.
6 Without any questions from members 7 of the public, I believe we are ready to adjourn 8 the meeting. Thank you very much.
9 MR. MYER MYERS: Thank you.
10 (Which were all the 11 proceedings had and 12 testimony taken in the 13 above-entitled matter at 14 the time and place 15 aforesaid.)
16 17 18 19 20 21 22 COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622
119 1 STATE OF ILLINOIS )
) SS.
2 COUNTY OF KANE )
3 I, ELLEN E. PICCONY, a Notary Public duly 4 qualified and commissioned for the State of 5 Illinois, County of Kane, do hereby certify that 6 subject to the usual terms and conditions of County 7 Court Reporters, Inc., reported in shorthand the 8 proceedings had and testimony taken at the meeting 9 in the above-entitled cause, and that the foregoing 10 transcript is a true, correct and complete report 11 of the entire testimony so taken at the time and 12 place hereinabove set forth.
13 14 15 16 17 Notary Public 18 My Commission Expires 19 October 15, 2003.
20 21 22 COUNTY COURT REPORTERS, INC.
600 S. County Farm Rd., Wheaton, IL 630-653-1622