ML030640569
| ML030640569 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/11/2003 |
| From: | NRC/RGN-III |
| To: | |
| References | |
| Download: ML030640569 (135) | |
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2 3 PUBLIC MEETING BETWEEN U.S. NUCLEAR REGULATORY COMMISSION O350 PANEL 4 AND FIRST ENERGY NUCLEAR OPERATING COMPANY OAK HARBOR, OHIO 5
6 Meeting held on Tuesday, February 11, 2003, at 7 2:00 p.m. at the Camp Perry Clubhouse, Oak Harbor, Ohio, taken by me, Marie B. Fresch, Registered Merit Reporter, 8 and Notary Public in and for the State of Ohio.
9 - - -
10 PANEL MEMBERS PRESENT:
11 U. S. NUCLEAR REGULATORY COMMISSION 12 John "Jack" Grobe, Chairman, MC 0350 Oversight Panel Christine Lipa, Projects Branch Chief 13 Douglas Simpkins, NRC Resident Inspector Jon Hopkins, Project Manager Davis-Besse 14 Anthony Mendiola, Section Chief PDIII-2, NRR 15 Dave Passehl, Project Engineer Davis-Besse 16 FIRST ENERGY NUCLEAR OPERATING COMPANY 17 Lew Myers, FENOC Chief Operating Officer Robert W. Schrauder, 18 Director - Support Services J. Randel Fast, Plant Manager 19 James J. Powers, III Director - Nuclear Engineering 20 Michael J. Stevens, Director - Work Management 21 Steve Loehlein, Manager - Quality Assurance 22 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
2 1 MS. LIPA: Okay. Good 2 afternoon. Can you hear me in the back? Good.
3 Okay. Well, welcome to FirstEnergy and to members 4 of the public. Im Christine Lipa and Im in Region III of 5 the NRCs Region III Office, and I have responsibility for 6 the NRCs inspection program at Davis-Besse.
7 And, well go through introductions in a moment 8 here, but let me just go to the next slide.
9 This is one of -- weve been having monthly public 10 0350 Meetings with FirstEnergy since last May. And, the 11 purpose of this meeting is to inform the public of the 12 NRCs Oversight Panel activities; and thats what we are up 13 here, the NRCs Oversight Panel; and, then also allow the 14 Licensee to present their status on their progress in 15 implementing their Return to Service Plan. And then, well 16 be discussing various parts of that plan.
17 Well go through the rest of the -- you can go to 18 the next slide, which has the agenda. Well go through the 19 rest of the introductions in a minute here.
20 Jon Hopkins is on my far left. He is the Project 21 Manager in Headquarters for the Davis-Besse facility.
22 Next to Jon is Tony Mendiola, and he is the Section 23 Chief at NRR.
24 Next to Tony is Jack Grobe. Jack is the Senior 25 Manager in the Region III Office in Lisle, Illinois; and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
3 1 hes the Chairman of the Oversight Panel.
2 Next to me is Dave Passehl, and hes the Project 3 Engineer for the Davis-Besse Project in Region III.
4 And, next to Dave is Doug Simpkins, and Doug is the 5 Resident Inspector at the Davis-Besse facility.
6 Also, in the audience today from NRC we have Ivy 7 Netsell. Shes is Resident Inspector at Cook, and she can 8 also get you a handout if you didnt get one when you came 9 in. Raise your hand, and Ivy will hand you one.
10 Also, we have Viktoria Mitlyng. Shes our Public 11 Affairs Officer in Region III.
12 Nancy Keller is the Office Assistant for the 13 Resident Inspector Office at Davis-Besse, and she was in 14 foyer with the handouts.
15 We have Jay Collins, who is a General Engineer on 16 rotation from Headquarters.
17 I also saw Rolland Lickus. Hes our State Liaison 18 Representative. There he is.
19 And then our transcriber today is Marie Fresch.
20 And Ill turn it over to you, Lew, if you want to 21 introduce your panel, then I have more to say.
22 MR. MYERS: Fine. At the 23 end of table, Steve Loehlein. Steve is our Manager of 24 Quality Assurance. And last time we discussed that we 25 would like to have him here at the next public meeting, so MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
4 1 hes prepared to speak today on what quality assurance is 2 seeing at our plant.
3 Bob Schrauder is our Director of Support Services.
4 As you know, hes working in the Systems Area Building 5 Block now.
6 To my right, is Randy Fast. Randy Fast is our Plant 7 Manager.
8 Jim Powers next to him is the Director of 9 Engineering.
10 And then Mike Stevens at the end is the Director of 11 Maintenance; and as you know, hes also the Outage Director 12 at the present time.
13 MS. LIPA: Okay, thank you 14 Lew.
15 Also, before we get started, are there any public 16 officials or representatives of public officials in the 17 room?
18 MR. ARNDT: Steve Arndt, 19 Ottawa County Commissioner.
20 MS. LIPA: Hi, Steve.
21 MR. PAPCIN: John Papcin, 22 Ottawa County Commissioner.
23 MS. LIPA: Hello.
24 MR. WITT: Jere Witt, County 25 Administrator.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
5 1 MS. LIPA: Okay. Anybody 2 else?
3 Okay, good, thank you.
4 Okay, next on the agenda is a summary of the last 5 monthly public meeting we had here on January 14th. Ill 6 turn it over to Tony Mendiola for that.
7 MR. MENDIOLA: Can you all see 8 that slide back there?
9 Basically, to summarize the meeting on January 14th, 10 that we had here, the discussion centered on two main 11 areas; basically, the restart preparations on both the 12 Licensees part and actions that we have as a panel have 13 performed to date; and, then basically, we broke further 14 down to the bottom of that topics discussed area, Safety 15 Conscious Work Environment.
16 Let me recap for a moment the discussion. The NRC 17 Restart Checklist, which is basically the action matrix 18 that were working from, we provided the update on that, 19 and then discussed the status of various inspections, most 20 of which are ongoing or will be ongoing soon; and, various 21 meetings that we were going to have in the month of January 22 and early part of February associated with the Safety 23 Culture, and other meetings that we had or supported, 24 commission meetings, and congressional briefings and things 25 like that.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
6 1 The FirstEnergy presentation focused primarily on 2 restart. They discussed the status of the physical 3 plant; basically, the construction work and modification 4 work that was ongoing on the site. And the, their working 5 off of their condition reports and corrective actions.
6 Basically, they use very similar to the charts you see 7 there on the, I guess on your righthand side of the room 8 there, discussing the various aspects of, of their programs 9 to complete these corrective actions.
10 There is a discussion of the, the Reactor Coolant 11 System Integrity Management Program, which you can see 12 about halfway down from the top was discussed there; and, 13 basically, a continued discussion on their readiness to 14 reload the fuel and other issues associated with the fuel 15 and fuel reliability.
16 In the interest of time, we did speed up the agenda 17 and moved right into the topic of the day, which was the 18 Safety Culture, Safety Conscious Work Environment topic.
19 At this meeting, the Licensee introduced Doctor Haber, who 20 is their consultant to help them implement the new safety 21 methodology at FirstEnergy -- at Davis-Besse, excuse me.
22 There was a discussion, detailed discussion of the 23 FirstEnergy model for Safety Culture. And, I dont see a 24 version of it here, but the Licensee provided a 25 four-pillared graphic, which discussed basic principles of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
7 1 Safety Conscious Work Environment, and four pillars that 2 they are focusing on to improve the Safety Conscious Work 3 Environment at the site.
4 Upon completion of that conversation, which lasted I 5 would say about half the meeting, we then moved on to 6 closure.
7 For everybodys interest, the transcripts from that 8 meeting are available on the website. And, if there is any 9 other topic areas you would like to, need more information 10 on, you can see me during one of the breaks or at the 11 conclusion of this meeting. Thats all I have.
12 MS. LIPA: Okay, thanks 13 Tony.
14 Then, the next slide was the next meeting we had, 15 which was on January 30th. And we had a pretty lengthy 16 public meeting in the Region III Office, where we discussed 17 with FirstEnergy their plans for assessing the status of 18 Safety Culture and Safety Conscious Work Environment at the 19 facility; and the various methods of surveys, interviews, 20 and attributes that will be evaluated. This included 21 activities that have already taken place at the facility; 22 those that are continuing, and those that are planned over 23 the coming weeks.
24 And the slides for that January 30th meeting are 25 available on our website and the transcript will come out MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
8 1 after we finish processing it.
2 I did want to mention, I skipped over a few of my 3 introduction remarks at the beginning, that this meeting is 4 open to the public, and the public will have an opportunity 5 before the end of the meeting to ask questions of the NRC.
6 And this is what we consider to be a Category One Meeting 7 in accordance with the NRC policy in conducting public 8 meetings.
9 Were also having this meeting transcribed today to 10 maintain a record of the meeting. And the transcription 11 will be available on our web page. We usually have it 12 available in about 3 to 4 weeks.
13 The agenda and the handouts are available in the 14 foyer and on the NRCs Web site. We also have the February 15 edition of the NRC monthly newsletter. This is a summary 16 we put together that has background information as well as 17 current activities.
18 We also have a public meeting feedback form. And, 19 this is a really good tool for us to get feedback from 20 people that are here, to let us know aspects of the meeting 21 that we can improve on. And weve been doing that since 22 these started back in May. And we have actually changed a 23 few things, and I think weve made it a better meeting.
24 And then, also our handouts for today and the 25 Licensees handouts.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
9 1 So, let me go on with the next slide then, which is 2 the Restart Checklist. What I want to do here was give you 3 an update on where we stand on the parts of the Restart 4 Checklist.
5 The first items are the technical and nontechnical 6 aspects of the Root Cause, and those are still under review 7 by the inspectors and technical review of NRR.
8 The next area is the Adequacy of Safety Significant 9 Structures, Systems and Components. And what weve done 10 here is, we had several inspections that have been out, so 11 let me go through a couple of highlights with you.
12 For Item 2A, the main item that is still outstanding 13 for that is the Normal Operating Pressure Test thats 14 scheduled after the first Mode 4. So, well be covering 15 that with a special inspection.
16 For Item 2B, which is Containment Vessel 17 Restoration, the remaining activity there is the ILRT, 18 Integrated Leak Rate Test of containment.
19 For Item 2C, we have several unresolved items that 20 came out of the inspection that was done, and exited in 21 November.
22 For Item 2C-1, which is on the emergency sump, that 23 inspection will be performed once the utility has completed 24 their mod package, and well also be inspecting the actual 25 sump that has been modified.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
10 1 For Item 2D, the item thats remaining here is 2 inspectors to follow the Licensees resolution of problems 3 that theyve identified on boric acid containing systems 4 that are on-site containment.
5 The next area that we have is the Programs area.
6 And these are all programs that the Licensee is reviewing 7 in detail, and coming up with plans to address deficiencies 8 that they discovered. So, right now the inspectors are 9 planning to come out when the Licensees reviews have 10 progressed sufficiently that there is something, a 11 completed product that we can inspect.
12 The next area is Section 4, which is the Adequacy 13 Organizational Effectiveness and Human Performance. And we 14 actually have three phases to this inspection. Phase one 15 has already been completed, and Jack will go through that 16 in a few minutes and then well be continuing inspections 17 to address those checklist items.
18 Section 5, which is Readiness for Restart, these 19 areas are not really ready for inspection yet.
20 And then Section 6, which are several licensing 21 actions. And for all of you, licensing actions, which is 22 the first bullet there, the NRC has received the 23 information that they were waiting for from the Licensee, 24 and its under NRC review, but there is no outstanding 25 questions. We do plan to document closure of these many MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
11 1 systems in Inspection Report 0302.
2 And then the final item on the Restart Checklist is 3 a meeting at the end of Confirmatory Action Letter Items 4 Resolution to discuss restart when the utility is ready for 5 that part of the process.
6 Okay. The next slide is, Ill turn it over to Jack, 7 and hell discuss some recent inspection activity and some 8 upcoming inspection activity.
9 MR. GROBE: Thank you 10 Christine.
11 Can you hear me okay? Excellent.
12 Weve issued one Routine Resident Report and one 13 Special Inspection Report since the last time we met. The 14 Routine Resident Report covered a broad spectrum of areas 15 as is characteristic of all of our Resident Reports. The 16 Residents are on site every day and they inspect ongoing 17 activities at the plant in the areas of maintenance and 18 operations and testing.
19 The Special Report that was issued concerned the 20 checklist items dealing with the adequacy of the Root 21 Causes in the Human Performance area, as well as the 22 adequacy of the Licensees Improvement Initiatives. Thats 23 Checklist Item 1 and Checklist Item 4.
24 The report documented the results of inspections 25 that covered the first two Root Causes. The very MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
12 1 substantive Root Cause that the Licensee submitted last 2 August, that addressed what is commonly referred to as a 3 barrier analysis. It was looking at barriers to failure in 4 all aspects of operation of the plant.
5 And in addition to that, there was an additional 6 analysis that was performed of the Quality Assurance 7 aspects of the plant operations. It was specifically 8 targeted in the QA Program and the implementation of that 9 program.
10 The inspection team found that both those analysis--
11 analyses were comprehensive and the identified corrective 12 actions to address the issues identified in the analysis 13 appeared to be adequate, if theyre properly implemented.
14 In addition, the inspectors identified a number of 15 questions regarding the scope of the two remaining analyses 16 that the company was planning, particularly questions 17 regarding the impact of engineering on the problems that 18 were discovered last February, and the impact of corporate 19 support.
20 So, the Licensee has since that inspection completed 21 its analyses in the area of Plant Operations, as well as 22 the Safety Committees function, and added to that analyses 23 in the area of engineering and corporate support. Those 24 four remaining analyses are now complete and well have 25 inspectors that will be coming back to the facility this MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
13 1 month to continue that inspection.
2 As Christine mentioned, this inspection is being 3 done in three phases. The first is ensuring that the root 4 causes are sufficient. The second is to make sure that the 5 corrective actions that the company has identified appear 6 appropriate to address those problems that FirstEnergy 7 identified. And third, looking at the implementation of 8 those corrective actions and their effectiveness prior to 9 restart.
10 So the, a portion of the first phase has been 11 completed, and well be continuing with the rest of phase 12 one of that inspection and moving into the second phase.
13 In addition on this slide, youll see the second 14 bullet concerns the System Health Reviews. I believe, I 15 looked ahead in FirstEnergys presentation and theyre 16 planning on having Bob Schrauder address some of those 17 engineering areas in the System Health Reviews.
18 We have ongoing inspections, particularly focusing 19 in the engineering areas, and the company has worked 20 continuously in that area, so our inspections are tracking 21 as they complete work activities, we send folks out to 22 inspect those activities.
23 In the Program Effectiveness area, we had two 24 programs that we need to complete our review of on the 25 short run, and those are the Boric Acid Corrosion MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
14 1 Management Program, and the Reactor Coolant System Leakage 2 Program. Then there is a number of other programs that our 3 inspectors are tracking Licensee progress, and well be out 4 to inspect when theyre ready for inspection.
5 There are, as Christine mentioned, a couple of other 6 inspections that are scheduled in the near term. Those 7 include the Integrated Leak Rate Test and the Pressure Test 8 of the Reactor Coolant System.
9 We expect to see those occurring in the next several 10 weeks, as well as, hopefully, a specific targeted 11 inspection in the radiation protection area. As you may 12 recall at the last monthly meeting, we publicly discussed 13 the results of resent inspections in the area with 14 protection of workers on site as well as controlled 15 materials that, radioactive materials that could 16 potentially get off site. Identified a number of findings 17 in those areas. And shortly our inspectors, our radiation 18 safety inspectors will be back out to look at the 19 corrective actions the company has implemented in the 20 Radiation Protection Program.
21 I think that summarizes continuing inspections, 22 Christine.
23 MS. LIPA: Okay. Thank you.
24 Then, if you could go back to slide 3.
25 This is just the agenda. And next on the item is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
15 1 the fourth bullet, which is the Licensees presentation, 2 and then following that, well take a break, and then well 3 have the public comments and questions period.
4 So, Ill turn it over to you, Lew.
5 MR. MYERS: Thank you.
6 We have four Desired Outcomes today. First, we 7 thought we would take some time and update the NRC and the 8 public on our efforts that we made toward restart in the 9 past month. Specifically, Randy Fast will provide you 10 some, a review of where were at from a fuel load 11 standpoint right now.
12 And then, Jim Powers is going to talk to you about 13 the Integrated Containment Leak Test thats coming up, 14 probably before our next meeting. And that test was 15 designed, since we installed the reactor vessel head, were 16 going to go back and pressurize the containment and prove 17 its leak tight, designed pressure. So, Jim will talk to 18 you about that.
19 From a System Health standpoint, Safety Function 20 Validation Project is a project we took on after we did the 21 initial reviews of our systems. We always said, after we 22 did those, that we would increase our scope based on what 23 we found. So, we took on another set of systems that we 24 wanted to go look at. We call that program the Safety 25 Functional Validation Project. Bob Schrauder will talk MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
16 1 about that.
2 Then from a Restart Readiness standpoint and Safety 3 Culture, we had a meeting January the 30th, and spent six 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> there. Im going to try to recap that meeting in 5 about six minutes. And then provide a review of what weve 6 done as a Restart Readiness Review at the plant for fuel 7 load.
8 So, we had Restart Readiness Review meetings, and 9 finally at the end of those meetings graded our own Safety 10 Culture, where we think were at using our model. So, I 11 thought I would spend some time on that today.
12 Then, Quality Assurance, Steve Loehlein, we talked 13 about having him here the next time, this time, to discuss 14 what the Quality Assurance Oversight Group is seeing at our 15 station. They were brought up through Bill Pearce, our VP 16 of Quality Oversight, and provide us an independent 17 assessment.
18 Then, finally, Mike Stevens will spend some time to 19 talk to you about our schedule, where were at. We thought 20 right now that wed have fuel load, at the last meeting at 21 this time. We havent got there yet. Just spend some time 22 on that, where were going in the next few months, and few 23 weeks, okay.
24 Thats it.
25 With that, Ill turn it over to Randy.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
17 1 Next slide.
2 MR. FAST: Thank you, Lew.
3 Good afternoon. Today, I would like to update us on 4 our Restart Readiness. Ill provide discussion and focus 5 in four key areas; those are fuel readiness, our plant 6 status, our processes and finally an update on observations 7 and the observation program.
8 Next slide.
9 First on the fuel. We worked with our fuel supplier 10 in identifying why we had indications on fuel assemblies, 11 damage on grid straps. Ill kind of show you right here is 12 what we call a grid strap.
13 That area provides support for the fuel rods 14 themselves. The fuel rods are the array that you see here, 15 the vertical rods. What we found in the movement of fuel 16 on some new assemblies in the spent fuel pool, we had 17 damage on, specifically on the corners of those grid 18 straps.
19 What we identified were three key areas; one of 20 which was the design and material selection. These are a 21 fairly soft metal, and prior to being irradiated, are 22 actually fairly malleable. And that design is one that the 23 industry is well aware of and there are actions being taken 24 by Framatone to improve that grid strap design.
25 Secondly, we looked at our equipment to see, was it MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
18 1 operating the way we would expect it to. And we did find 2 in the spent fuel pool the equipment had some alignment.
3 We require vertical indexing over each assembly; and as 4 well the indexing, thats the grid location were off a 5 little bit. So, we did take the action to go back and 6 reindex the spent fuel pool.
7 Lastly, we identified some of our handling 8 techniques. We werent using industry experience as well 9 as we could, and we went back and evaluated that; got some 10 help from the industry, and best practices for moving 11 fuel. We believe that those corrective actions are 12 effective and they will ensure that we can reliably move 13 the fuel.
14 One of the things I want to point out is, these grid 15 straps are really a structural mechanism and its not a 16 contributor to fuel failure. Although, we were concerned, 17 and we want to make certain that were handling the fuel 18 properly, it did not result in the root cause analysis in 19 actual fuel failure.
20 This assembly right here is actually an assembly 21 that had grid strap damage and was sent back to the fuel 22 supplier and remanufactured. This is one of our reactor 23 engineers here performing an inspection of that assembly as 24 it was returned to the site.
25 Additionally, as part of this outage, weve taken on MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
19 1 an opportunity to improve our main fuel handling 2 equipment. And we have put in a state of the art fuel 3 bridge modification, which includes improved controls and 4 it will improve our reliability.
5 Now, part of this whole process of moving fuel takes 6 a dedicated team of individuals. And weve partnered with 7 our fuel supplier, Framatone, to move the fuel. And we 8 actually have four senior advisors that are working with 9 our Operations staff as part of that fuel movement. That 10 compares with normally you will have one at a station in 11 that senior advisory capacity. We have four. So, we can 12 ensure that we have round-the-clock coverage and we have 13 the best industry experience to help us in moving that 14 fuel.
15 Lastly, we have completed all the training. So, 16 each position associated with the movement of fuel have 17 gone through an exhaustive training program and weve 18 recertified all of our folks to ensure we can have safe and 19 reliable transfer of fuel.
20 MS. LIPA: Randy, I have a 21 couple of questions for you about the fuel. First of all, 22 did you assess the design issue with the grid straps under 23 part 21; and then second, what was the root cause of the 24 fuel failures?
25 MR. FAST: Okay. Christine, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
20 1 the first question on the part 21, we have not submitted 2 that as a part 21. And, again, what Ill do is take an 3 action to assess that, and see whether or not -- I believe 4 from a reportability standpoint it wouldnt be, but it 5 might be advisable to provide some, a report just to make 6 sure youre on board with what we found.
7 This particular root cause was not in the fuel 8 failures themselves. This was in the grid strap. So, we 9 have another root cause. And I would have to think back, 10 because thats really quite a few months ago that we had 11 completed that review, and actually had a space there --
12 excuse me, grid rod threading, which is high frequency 13 vibration of the fuel rod. And the threading is the actual 14 rubbing of the spacer grid components against the fuel rod 15 and actually wears a hole in the fuel rod.
16 And thats where the root cause was completed 17 earlier. It was not part of this root cause and 18 preparation. And all the corrective actions from that had 19 been completed as well. Some of those are corrective 20 actions where we provided some solid stainless steel rods 21 in place of the actual fuel pelleted rods in locations 22 where we saw that the grid-to-rod threading was more 23 pronounced and that is actually adjacent to LOCA holes 24 inside the core.
25 Those are areas where you have increased flow comes MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
21 1 in contact with the fuel rod, sets up a high frequency 2 vibration, allows the fretting to occur. So, we stabilize 3 that by providing some stainless steel rods in those 4 locations.
5 MS. LIPA: Okay. Thank 6 you.
7 MR. GROBE: Randy, before you 8 go on, I understand one of the activities you need to 9 complete prior to commencing fuel reload has to do with 10 reactor vessel cleanliness, and I heard that some of the 11 materials that were identified in the vessel were grid 12 strap materials. Could you go into a little bit on the 13 issue of reactor cleanliness and what youre doing about 14 that?
15 MR. FAST: Certainly. As 16 part of fuel load preparations, we do a thorough inspection 17 of the reactor vessel and the area underneath the vessel.
18 The fuel sits on a, whats called a core barrel. Its 19 really an assembly in the bottom of the core that provides 20 support for the 177 fuel assemblies.
21 During this period of time where the fuel has been 22 offloaded in the spent fuel pool, we want to do a complete 23 and thorough inspection of the reactor internals and of the 24 core barrel and the lower portion of the vessel to ensure 25 there was no foreign material or any debris.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
22 1 What we found through that was a number of 2 indistinguishable piece parts, Ill call it; some of which 3 are most probably pieces of grid strap. We did, I think 4 today, identified a ball bearing. Dont know exactly, it 5 may have come from one of the tools that is used for fuel, 6 but thats something were going to have to evaluate.
7 As well, saw some foreign material, light debris, 8 some of which was probably some paint, paint chips and the 9 like. And weve gone through and vacuumed that. We 10 redistributed it. We do a video. Thats kind of, Ill use 11 the word, Lew likes this, a cursive process. We actually 12 go in, we clean, we go back inspect. We have to meet Class 13 B Cleanliness Requirements for the Reactor Coolant System 14 for stainless steel systems.
15 So, well continue to clean the vessel until we meet 16 the Class B Requirements.
17 MR. GROBE: Okay, thank you.
18 MR. MENDIOLA: Randy, if I could 19 ask a question. You mentioned there was an alignment 20 problem in your spent fuel pool. Could you tell us a 21 little more about that?
22 MR. FAST: Tony, what you 23 have is a series of what Ill call X Y axes for each fuel 24 location. And we had gone through in 2001, and then into 25 2002, a rerack project. What that is effectively, is we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
23 1 needed to provide more storage location in our spent fuel 2 pool for expended fuel.
3 As part of that rerack project, we had some of the 4 locations off by as much as about a half an inch. When you 5 look at the very close tolerances of the storage locations 6 and the fuel and the mast, we found that we had an 7 opportunity to set up, an opportunity to have grid strap 8 the corners that come in contact with those storage 9 locations.
10 So, we went through and reindexed the pool. And I 11 know now were within about an eighth of an inch,.125 12 inches, thats well within the design requirements for fuel 13 identification.
14 Additionally, we had some compensatory measures 15 where we used a camera to verify that were on index.
16 There was one other issue that is called out in the report, 17 and that was the potential that the fuel mast itself was 18 out of vertical. What we found is that it was in vertical; 19 however, there are some spacer, spacer plates in there that 20 provide very, very close tolerances. What weve asked 21 Framatone to do is review that design and see whether we 22 can open some of those tolerances that will provide a 23 little more flexibility in handling fuel in the spent fuel 24 pool.
25 MR. MENDIOLA: Okay. Basically, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
24 1 it had to do with the position of the rack within the pool; 2 meaning, if you will, in an appropriately indexed 3 position.
4 MR. FAST: Yes, sir.
5 MR. MENDIOLA: Not the fuel in 6 each of the locations, but the rack itself.
7 MR. FAST: Yes, and actually 8 I asked that question. The fuel in the assembly could be 9 at any one of the, it may be pushed over to any one of the 10 north, south, east, west walls, and you should still be on 11 index it at that point. Thats where some of those 12 tolerances, those stackup tolerances come from. Thats 13 well within the design, but the index in itself was off by 14 as much as a half an inch.
15 MR. MENDIOLA: Thank you.
16 MR. FAST: Next slide, 17 please.
18 We talked last time about reactor coolant pumps.
19 Just to refresh, we did complete refurbishment on the 1-1 20 and 1-2 reactor coolant pump and reactor coolant pump 21 motor. This is one of the reactor coolant pump motors 22 thats being lowered down into the D ring inside of 23 containment.
24 A question came up about, we did two out of the four 25 reactor coolant pumps. You would say, why did you do two MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
25 1 and not do the other two. This was what Ill call elective 2 maintenance. We were well within the normal preventative 3 maintenance periodicity. However, we took this as an 4 opportunity to open up and do inspections on the pump and 5 motor.
6 And part of the issue here was, as well, going back 7 to the extended condition, boric acid. We had some legacy 8 issues in boric acid leaking from the flanges for the 9 reactor coolant pumps themselves. That was an industry 10 understood situation.
11 Framatone had come up or Byron Jackson, the supplier 12 of the pump, has a new generation seal that provides better 13 sealing and leak prevention; and its much like a reactor 14 vessel, its a dual O-ring seal design. We went with new 15 generation on these two.
16 The other two are well within their periodicity.
17 The other two pumps that we did not go after, and motors, 18 are well within their design for preventative maintenance.
19 We didnt see any extended condition items from the 20 analyses of these two pumps and motors that would drive us 21 to go after the other two.
22 We will continue to monitor those and well 23 implement corrective actions in accordance with our 24 Preventative Maintenance Program.
25 Next slide, please.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
26 1 This is about the best picture I can provide to-date 2 on the upper portion of the containment emergency sump.
3 And as we talked last meeting, I had one of the top hats 4 here, which is the cylindrical filter assemblage that 5 allows the 3/16 inch holes that are drilled, water during a 6 design basis accident floods the containment and comes up.
7 And these, Im going to use a term here that we kind 8 of affectionately call, trash racks. This is a large 9 filter on the outside. Youll see some of the top portions 10 of those racks, which fit around the top of this. That 11 provides a first barrier for the straining of any foreign 12 material.
13 And then, inside this upper portion, about 400 14 square feet, about 15 square feet each of 27 top 15 hats, provide that top level of the strainer.
16 This is now functional, the upper section. And we, 17 after fuel load and recovery of the reactor coolant system 18 fuel and vent well complete the lower portion of the 19 containment emergency sump.
20 Its a pretty good picture of the area. Its at the 21 565 elevation of containment against the south wall.
22 MR. HOPKINS: I have a couple 23 questions on that. In the Licensee event report that you 24 submitted to us, especially Revision One dealing with the 25 sump, you talked about part of the reason for the new sump MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
27 1 is the old sump had a gap that was too large, and that 2 could potentially affect containment spray systems.
3 You also stated that besides that potential affect 4 on containment spray systems from the too large gap which 5 you had to fix one way or another, and your fix is with the 6 new sump; that the new sump would also provide you extra 7 margin with regards to amount of debris that might get on 8 the screens.
9 Have you made any finding with regard to the amount 10 of debris on the old screens, would have been too much?
11 MR. POWERS: Let me answer that 12 one, Jon. On the old screens, theyre about 50 square feet 13 of screen material on the old sump. And, we have been 14 preparing what we call a transport analysis that takes an 15 assessment of the debris that can be generated during an 16 accident in containment.
17 (Microphone problem) 18 Thank you, Mike. Let me start again.
19 The old sump had about 50 square feet of screen, 20 screenage on it to allow water flow-through, and the new 21 sump has about 12, 13 hundred square feet. So, weve 22 improved that substantially.
23 Now, what we have done since weve been comparing 24 this new design is doing a transport analysis, looking at 25 debris sources within containment, and were following some MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
28 1 of the latest industry guidance on that. The industry has 2 learned quite a bit over the years from the original 3 licensing and design basis of the containment emergency 4 sumps up until today.
5 Originally, the sumps were designed back in the late 6 60s and through the mid 70s, to consider a 50 percent 7 blockage. And that was relatively nonmechanistic, if you 8 will. Assume its 50 percent plugged and determine theres 9 adequate MPSH to the pumps with that blockage.
10 As we gone on with time and incidents have occurred 11 relative to sumps, weve assessed more accurately what 12 kinds of debris can cause problems with the sump, how would 13 debris get down to the sump. And the industry, as well as 14 your organization, has done studies on that, modeling what 15 we call transport debris generation and transport down to 16 the sumps.
17 And we completed that ourselves. We determined that 18 given what we refer to as a design basis condition, we get 19 a large break of a reactor coolant pipe, a lot of steam, 20 and pressure released; there can be, there can be a 21 substantial amount of debris that is transported down to 22 the sump area.
23 Of course, there is smaller type breaks, you would 24 have a condition where not as much debris would get down 25 there, and the sump generally is, is more functional when MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
29 1 you have smaller types of breaks.
2 So, what we said in our Licensee Event Report that 3 you were referencing is related to design basis accidents, 4 how much debris can get down there. What we determined is 5 with our new sump, and new screenage, that we would have 6 margin available, even under that condition, extreme 7 conditions to our pumps.
8 MR. HOPKINS: All right. Ill 9 just mention that the NRC is going to issue a draft generic 10 letter on this issue, I think within the month. So, you 11 want to read that, see what it says.
12 MR. POWERS: Okay, thanks.
13 Well be watching for that.
14 MR. GROBE: Jim, could you go 15 into a little more detail on the transport analysis? Are 16 you analyzing the as-found conditions in February of 2002?
17 MR. POWERS: No, what we really 18 looked at, Jack, was design basis conditions; worst case, 19 large break, LOCA accident conditions. And were looking 20 at it from the perspective of what was found to give a 21 safety significant assessment. And, weve begun preparing 22 that now.
23 Because, what was found in February with the 24 degradation on the head would constitute a relatively 25 smaller type of break in the reactor coolant pressure MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
30 1 boundary, and relatively contained within the service 2 structure on top of the head. So, we wouldnt expect from 3 that type of as-found condition to have a lot of debris 4 generated that would transport down to the sump. Its a 5 very tortuous path to get down to the sump from that 6 location.
7 So, what weve been analyzing for a design basis and 8 reporting in our LER, is large break design basis. We will 9 provide however a safety significant assessment on what was 10 found in February.
11 MR. GROBE: What are the 12 major contributors to the debris that youre talking about?
13 MR. POWERS: Major contributors 14 are insulation, and it can be either metallic, reflective 15 metallic insulation or fibrous insulation thats wrapped 16 around pipes and components; coatings, if theyre not fully 17 qualified, the temperature, pressure and radiation within 18 containment that can exist after an accident.
19 Also, when you consider a large break, design basis 20 break, were talking about very violent discharge of jet, 21 of reactor coolant, that can strip concrete and paint and 22 insulation off adjacent structures; and thats what 23 constitutes the debris. Thats what the industry guidance 24 in recent years has defined what the, whats the 25 constituents of the debris. So, thats the type of thing MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
31 1 that we look for.
2 MR. GROBE: So, the design 3 basis worse case design break is what youre analyzing.
4 Are you looking at the as-found coatings with that 5 analysis?
6 MR. POWERS: We, yes. And, as 7 weve described over the, some of the last meetings, weve 8 been looking very carefully at our coatings within 9 containment; and as we go through some of the progressive 10 slides here in Randys presentation, youll see the 11 recoating project were doing on the top of the containment 12 dome. Where you can stand up on the refueling floor and 13 look upwards. Its quite a height up there that were up 14 working with painters, stripping and recoating to assure we 15 maintain a qualified coating system up there.
16 Weve also recoated our core flood tanks. Were 17 working on recoating service water piping. We found on a 18 very thorough containment walkdown and assessment of 19 coatings, that our conduit that some of our cable and 20 wiring runs through has a coating system on it thats not 21 fully qualified for the post-accident conditions.
22 So, were very carefully looking at that to see to 23 what extent that coating needs to be removed and replaced.
24 And were using our transport analysis to make a 25 determination to what extent that needs to be removed and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
32 1 what extent it can be allowed to stay, and very clearly 2 defining in our inventory of unqualified coatings in 3 containment, you know, what the as-left condition will be.
4 MR. GROBE: In the analysis 5 that you performed, how significant a role did the 6 unqualified coatings play?
7 MR. POWERS: The unqualified 8 coatings is pretty significant overall. If you look at the 9 square feet of coating within the large containment 10 structure, there is quite a bit of coatings. So, to us, 11 that was a significant part of the, the walkdown of 12 containment under Containment Health, looking for coating 13 qualification information, inspecting the condition of the 14 coatings, and looking for repairs on the coatings, because 15 there is a large amount of coatings; a significant 16 contributor to potential debris for the sump.
17 MR. GROBE: Okay. If you 18 could just summarize for me in a few words the conclusions 19 of your analyses to-date with respect to whether or not the 20 sump would have functioned given a design basis accident?
21 MR. POWERS: Given a design 22 basis accident, there is a, there is a concern with the 23 amount of debris that can be generated under design basis 24 conditions, because of what I described as a very large 25 break, a large amount of debris being transported. And, we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
33 1 think the original sump, which was designed in accordance 2 with the design regulation and criteria at that time, could 3 have been blocked to a large extent by debris.
4 When I look though at the conditions that were found 5 in February, with the head degradation, its really, its 6 not in the same regime, I guess you would say, as a design 7 basis large break. Its a smaller potential, potential for 8 a smaller break there. So, we think under that case, the 9 sump likely would remain functional.
10 But, the reason we reported our conditions under the 11 LER, was for design basis condition, we did not feel that, 12 that the original sump would have been satisfactory.
13 MR. GROBE: Thank you.
14 MR. FAST: Next slide, 15 please.
16 I wanted to point out, what we have here, what we 17 call the decay heat pit. Weve actually renamed this.
18 This is a decay heat tank. This is legacy issue that two 19 decay heat valves that are in a vault in containment which 20 are required to operate post accident any time from 21 immediately following the accident up to about a week after 22 the accident. And, those valves have been sealed 23 traditionally with sealing RTV material.
24 We wanted to take a proactive approach at resolving 25 that legacy issue by providing in this case the stainless MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
34 1 steel vault or tank. And this photograph is probably 2 difficult for you to see, but what you see is a curved 3 section right here, which actually is installed to allow 4 for thermal expansion of that tank.
5 So, this design will ensure that integrity is 6 maintained for these two important valves in containment.
7 It will be completely sealed prior to our going to Mode 4, 8 and that work is proceeding well, but I thought of interest 9 would be this design feature that includes for thermal 10 expansion within that tank.
11 Next, please.
12 Here we have the containment air coolers. Weve 13 talked about that quite a bit. There are three in a row.
14 Again, it may be difficult for you to see, but there is the 15 third one back here; the one most pronounced in the middle 16 here; and then there is one in the foreground.
17 What I wanted to be able to point out is were 18 making excellent progress in returning these. These are 19 completely refurbished. New cooling coils; as well, all 20 the structural steel has been blasted and recoated. What 21 you see right here is a foreign material exclusion cover on 22 a service waterline. This is the line, the blue line 23 thats coming in. You have an inlet pipe and an outlet 24 pipe. Those distribute water into and then out of these 25 heat exchangers.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
35 1 What we have is a brand new design that again allows 2 for thermal expansion under design basis accident 3 conditions. Its actually conduit and stainless steel 4 bellows assembly, and that will allow for some thermal 5 growth. So, these are not installed yet. Thats one of 6 the last things that we have yet to do. And those are in 7 fabrication.
8 So, that supply and return header will be attached 9 to, in this case, the, there are three heat exchangers 10 here, and three heat exchangers here. On the opposite 11 corner you have as well the other, so there is a total of 12 twelve heat exchangers, you have the other inlets and 13 outlets. So, you can see that these have been completely 14 refurbished.
15 The fan motors inside are all new and completely 16 refurbished. We have brand new whats called dropdown 17 dampers. The air flow comes from the area here in the 18 general vicinity is pulled through the heat exchanger, 19 comes down through a fan, and is exhausted through a 20 plenum, which is our next picture. But under design basis 21 accident, there is a drop down register. Ill point it out 22 in the next photograph, but those actually open up to short 23 cycle the redistribution of air within containment.
24 Here is, whats really like a boxcar or 25 tractor/trailer. Its about 40 feet wide, and this is just MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
36 1 about completed. The drop down damper, difficult to see, 2 but its a damper thats right in this area here. And that 3 damper would close, and there is an upper portion that 4 opens. Its got fusible lengths that under heated 5 conditions allows the damper to open and short cycle the 6 air under design basis accident.
7 On the far side, on either end of this plenum, this 8 is a common plenum for all three containment air coolers, 9 you have some turning veins. Its a 90 degree turning vein 10 comes exhausted out, has two separate sections of 90 degree 11 turning vein; and then brings the air under normal 12 recirculation back into the D ring.
13 So, thats a stainless steel, half inch stainless 14 steel plate floor; stainless steel walls that have been 15 bolted together; and were working on the overhead in 16 connecting everything together. So, making very good 17 progress on our containment air coolers that will greatly 18 improve environmental conditions and ensure reliability for 19 basis design accident.
20 Next slide.
21 MR. GROBE: Randy, before you 22 go on, could you or Jim or Bob, discuss a little bit of 23 your analysis of the as-found condition of the containment 24 air coolers and the, as far as whether or not they would 25 have functioned as designed?
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
37 1 MR. POWERS: Yeah, weve been 2 analyzing the containment air coolers. And, for those of 3 you who havent attended previous meetings, a description 4 of those air coolers Randy described the air being drawn 5 through them. Well, the air in the containment had boron 6 mist in it, and those cooling coils were fouled somewhat 7 with that boron precipitating out.
8 So, we needed to do an assessment on how that would 9 affect our heat transfer capability. And weve also 10 disassembled the cooling coils as we completely rebuilt 11 them, and inspected them as part of that process; and found 12 when we opened them up, there was some, inside some 13 deposits from the water system that had built up over 14 time. So, we took into consideration all of those factors 15 in the performance of the containment air coolers.
16 Now, we did a thermal performance calculation, and 17 from the design basis, licensing basis conditions of the 18 plant, the containment air coolers work in conjunction with 19 containment spray system to control the containment 20 pressure and temperature conditions in a post accident 21 environment. And, what we found is that working in 22 conjunction with containment spray, the containment air 23 coolers would be operable and perform their function to 24 control containment conditions.
25 What were going through now in the details is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
38 1 assessing the functionality of the sump, which I just 2 described; and on an integrated basis, if we had a, an 3 accident in the containment, the function of containment 4 spray, which takes suction on the sump, and the containment 5 air coolers; and what the likelihood is, that the, you 6 know, the performance and functionality of the sump would 7 be affected.
8 And so what were doing, what I refer to safety 9 significance assessment, thats taking into consideration 10 the total picture. Debris being generated during an 11 accident. Whats the likelihood that it would get down to 12 the sump and block it, you know, from a design basis 13 perspective. We consider by design rules that it might, 14 practicality of it getting down there; functionality is 15 probable.
16 And so, looking at containment spray, and the 17 performance of the containment air coolers on an integrated 18 basis is what were working through now, Jack. I know 19 there is still work to be done to answer your question 20 completely, but our intention is to provide a report of 21 that assessment to you for review.
22 MR. GROBE: Do you have an 23 idea what the schedule will be for completing that?
24 MR. POWERS: Weve just 25 completed the assessment of the containment air coolers, so MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
39 1 now were beginning the process of doing an integrated look 2 at the plant response. And I would expect its going to be 3 in the range of two to four weeks to put that together.
4 MR. GROBE: And again, each 5 of these analysis is looking at -- analyses are looking at 6 a design basis worst case accident; is that right?
7 MR. POWERS: Well, in the case 8 of the -- thats right. Containment air coolers, the 9 answer is yes. Were also looking at it from the 10 perspective of what is the more likely condition, both from 11 a design basis condition, and then from a safety 12 significance perspective.
13 MR. MYERS: I think there is 14 a couple of interesting points. You know, one of the 15 things is we went back, if you look at this thing as a 16 whole. We think well be able to demonstrate 17 functionality. For the first 30 minutes or so of an event, 18 you really dont need the containment sump, because were 19 ejecting water from the boric acid tank, you know.
20 And then, the other thing that I think you mentioned 21 is important, the technology has changed over the years.
22 And weve talked about that in here a lot, in the analysis, 23 like transport analysis. When we originally designed the 24 plant, the design basis of the plant that was approved by 25 the NRC and us, you know, that we assumed, we just MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
40 1 automatically assumed 50 percent of it got plugged up.
2 We met that design basis. We always have. Coming 3 out where it is now, with some of the new models, we can 4 theorize things that we havent in the past, you know. We 5 can keep theorizing, you know. But some of these theories, 6 on the paint being blown off and things like that; well 7 probably see something like that.
8 But we met the design basis of the plant initially.
9 And functionality of the plant, we believe, right now we 10 believe would still be intact based on that design basis.
11 And, and then were going back to this transport analysis, 12 and looking at some other assumptions. Those assumptions 13 werent in the original design.
14 MR. GROBE: Okay, thanks 15 Lew.
16 You brought a question up and I think you answered 17 it already, Jim, but let me make sure I clearly 18 understand. Youre doing both a design basis analysis, but 19 also probabilistic analysis; is that correct?
20 MR. POWERS: Thats right, 21 Jack. The design basis analysis would be reported in a 22 Licensee event report related to the containment air cooler 23 conditions, and capabilities. And then the safety 24 significance assessment will be a separate assessment based 25 on as-found conditions and significance.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
41 1 MR. GROBE: Okay.
2 MR. FAST: Okay. Moving 3 along. What we see here is the containment dome. Just to 4 get a vantage point of where we are, were at the 603 5 elevation looking straight up into the containment dome.
6 And this is the polar crane, which has provided very good 7 reliability after we have gone through our modification 8 there. That rests on an outside ring, support ring here.
9 And Ill point out a couple of things. One is the 10 spray headers. So, you see a circular header here. Thats 11 in the uppermost portion of the containment dome. And then 12 a lower containment spray header, the circle that Im 13 identifying here.
14 What weve done, weve completed, as you can see, a 15 significant amount of the containment dome in the 16 refurbishment. You see the gray areas here where we 17 actually removed the paint.
18 Thats a pretty arduous process. Used whats called 19 a rotopine; we also use needle guns. This is an air 20 operated and vacuum drag the debris back into the 21 containment system. And, thats where the paints been 22 removed. You can see then the line where the old paint --
23 heres the new paint, the white fresh paint. You can see 24 the gray where the paint has been removed. And then on the 25 outer ring, the paint that has yet to be removed here.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
42 1 So, you can see the actual rigs, the spider rigs 2 that the paint crews are working out of. You can see how 3 they will actually rotate around to remove that paint, and 4 then another crew will come back and reapply coatings to 5 that surface area.
6 So, thats quite an effort, and continues to go 7 pretty well. The surface area associated with that dome is 8 about an acre, and all of that paint is hand removed. And 9 so, you want to get an update of where we are, were making 10 good progress. We expect from a coating standpoint -- kind 11 of back to this sump. This paint needs to be recovered in 12 this area. Anyways, we do not have to remove the rest of 13 the paint on the walls.
14 Now you see here below that support. Thats a 15 different style of paint. Thats both a carboline, but a 16 different type of paint and that paint is good. It meets 17 design requirements.
18 MR. GROBE: Randy, there 19 could be folks in the audience that, for those of us that 20 stood there that actually makes sense; could you give 21 dimensions?
22 MR. FAST: The building 23 itself is about 2.8 million cubic feet and overall almost 24 300 feet tall. So, from the 603 elevation, which is the 25 operating deck of containment, as weve talked about some MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
43 1 of these other areas; the sump, the top portion of the sump 2 is at 565 feet. Thats also where the plenum is. I showed 3 the pictures of the containment air coolers. So, thats 4 the lowest elevation of containment, 565 foot elevation.
5 The next is 585 feet. Thats where the containment 6 air coolers with the actual heat exchangers are located.
7 The operating deck is at 603. The top of the D rings is 8 653 feet. Thats 50 feet above that. Its about another 9 30 or so feet until you get to the support ring for the 10 polar crane. And then its about another 50 or 60 feet to 11 get to the crown of the dome. So, overall, 300 feet from 12 top to bottom.
13 MR. GROBE: So, from where 14 that photograph is taken to the top of the dome, it sounds 15 like its about 130 feet up?
16 MR. FAST: Yes, sir. Thats 17 approximate. I would have to figure out the math. Dont 18 hold me to the 130. Its pretty close though.
19 MR. POWERS: Its pretty 20 special people that go up there and do that painting, I can 21 tell you that. Randy, did you go up and experience that?
22 MR. FAST: Its kind of an 23 interesting story. I really wanted to understand what was 24 going on in the containment dome. A lot of hype and I 25 wanted to see it up close and personal. We have a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
44 1 qualification process that qualifies, just like a window 2 washer on a building. These rigs have some specialized 3 safety features for running the rigs up and down. I went 4 through that training program; was qualified as a rig 5 operator. Went up to the dome, and I actually removed 6 paint for about an hour up in the top of the dome. It was 7 quite exciting. Ill tell you.
8 MR. MYERS: Plus, its an 9 area we spend a lot of hours of inspection time, from that 10 standpoint.
11 MR. FAST: So, really, my 12 hats off to the paint crew. It sounds kind of like, well, 13 paint is not a big deal. I can tell you, these are 14 engineered coatings. This is a very dedicated crew that 15 are working this at heights.
16 And in fact, just an item, from an interest 17 standpoint, you can say, well is that safe. Actually 18 brought in a specialist in the industry, a Professional 19 Registered Engineering to look at the design of these rigs 20 and the application, and we got a good bill of health.
21 And, we continue to work safely in this area.
22 MR. MYERS: But to go into 23 the containment, to go up there; whats it take, like 30 24 minutes?
25 MR. FAST: It takes about 30 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
45 1 minutes, by the time you brief, you get in the basket. I 2 went up with three other people. By the time you get up 3 there, you have a series, actually had three tie-off 4 lanyards to ensure that youre safe. Youre tied off by 5 double point at any one time. Then, you transition one 6 lanyard to your next position, and go through a series to 7 go from the basket to -- then we had, while we were doing 8 that uppermost portion, we had two 35-foot sections that 9 were in the very top and they were suspended by a central 10 pivot point at the very top of the containment dome.
11 Interesting project and really quite a tribute to 12 the folks that are doing this work.
13 MR. FAST: Next slide, 14 please.
15 Next area I wanted to talk to you about is some of 16 the processes we went through. Certainly, we looked at the 17 plant and the plants readiness to move fuel. But, one of 18 the things that is very difficult to assess, but we 19 actually use a business practice, this is much like a 20 procedure, was developed at our other stations.
21 We went through and refined it specifically for our 22 recovery here at Davis-Besse; and that involves a collegial 23 review by about 40 key organizational folks, including 24 supervisors, superintendents, managers, directors, and our 25 more senior people. Lew was personally involved with MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
46 1 this. We brought over our Vice President from the Beaver 2 Valley Station, and as well our Executive Vice President of 3 Engineering attended the majority of these discussions.
4 This went through a very detailed review of our 5 readiness. And we got started probably a little early, but 6 we invested between 50 and 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of discussion in going 7 through this very detailed review.
8 It included the seven Building Blocks, and then as 9 well, we went through each organization and looked at 10 things like, do we have the proper staffing; are our folks 11 qualified; have we completed corrective actions associated 12 with problems in their areas; do we understand what their 13 back logs and procedures were.
14 So, that review was a very intrusive review. And it 15 added a significant amount of value, I would say, in our 16 ability to assess our readiness to move forward.
17 One of the specific actions that came from this were 18 the Refuel Director roles and responsibility here. The 19 Refuel Director is a Senior Reactor Operator licensed 20 individual that is overseeing the actual movement of the 21 fuel to ensure that its reliable and done safely.
22 What we found out, as we queried. This is really a 23 tribute to having some new folks, use to maybe doing things 24 a little differently. Being intrusive, asking questions 25 about how do we do that. What we found out is the Senior MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
47 1 Reactor Operator was a little bit different than what we 2 would say the traditional role of the Refuel Director was.
3 We had what was called a tag board which keeps track 4 of the fuel itself, involved with some of the 5 administrative processes. They did not meet our 6 expectations. We subsequently changed that role and 7 responsibility to provide direct oversight, no 8 administrative duties, to ensure that we can safely move 9 fuel. That was a direct output from this Readiness 10 Review.
11 Another one, we put in place the Management 12 Oversight. When I talk about Management Oversight, 13 certainly myself and other senior managers have been 14 involved in looking at our readiness and the support. Ive 15 made tours. I know Lew and myself and others made tours of 16 containment most recently within the last few days in 17 seeing how ready we are.
18 But we did put in place, a seven-day-a-week, 19 24-hour-a-day Oversight Management Team, which includes 20 folks that were previously licensed and have refueling 21 experience. And, theyre sitting there with the sole 22 purpose of overseeing the process of moving fuel.
23 Lastly, I want to talk about and weve had a lot of 24 discussions about our Observation Program. And weve 25 already gotten some good feedback on the observations that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
48 1 have been conducted as part of our fuel readiness. One I 2 would mention is foreign material exclusion. We put in 3 place a housekeeping zone in the containment for the 4 movement of fuel, and we have a single point of access to 5 those areas to establish housekeeping boundaries.
6 We saw that we had some opportunities for 7 improvement there. Those were documented on a Condition 8 Report as well as an observation, so we have corrective 9 actions to ensure that the role and responsibility of that 10 foreign material exclusion monitor is, will meet our 11 expectations.
12 Just a recap, and not to bore you with a lot of 13 facts, but we did our totalization of management 14 observation for the month of January. We did a total of 15 468; 364 included fuel observations, 46 a training. I 16 think its important, because training continues. We still 17 have a lot of training thats going on, particularly in the 18 operations area. And, then 58 that were specific to 19 operations processes. 21 Condition Reports were generated 20 based on those observations.
21 We had 90 percent schedule adherence, Ill call it.
22 You know, Lew has talked to us about, its not just a 23 matter of just run out there when the time is right, we 24 want to preschedule those important evolutions and make 25 sure the people are scheduled to monitor it.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
49 1 I was scheduled this last week to look at personal 2 protective equipment. Part of the reason I was scheduled 3 to do that is that was one of the shortfalls we saw as we 4 pulled together the information from the January 5 observations. We saw that there were opportunities in 6 areas for room for improvement.
7 I made an observation. I actually took some 8 specific action to get some additional safety equipment 9 that was identified from my observation about personal 10 protective equipment.
11 We feel like weve made some pretty good progress.
12 We benchmarked and compared ourselves against our other 13 FirstEnergy Nuclear Operating Company Stations and we are 14 doing more observations. And, although, sometimes our 15 staff say, we dont see our managers enough; we have 16 assembled a pretty impressive amount of observations.
17 About 72 percent of the field observations focused 18 on some element of safety, whether it be radiological, 19 nuclear or industrial safety; and 28 percent of those field 20 observations focused on improvements and standards and 21 being able to coach our folks to new standards of 22 excellence.
23 As part of the observation program, we have specific 24 attributes that we look at. We had a total of 656 checks 25 on procedures. Thats verifications of procedures that are MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
50 1 in use, that theyre being followed, that theyre being 2 place marked; and so we have 650 total checks on 3 procedures. No alarming or no trends that we saw that 4 would require us to take any immediate action in that 5 area.
6 I thought it was interesting, got a couple of facts 7 here. The least observed focused area were observations, 8 field observations of office safety. I think thats, that 9 tells you that were going where the action is. Were 10 going out to the plant and seeing the activities that are 11 actually ongoing. I think thats good, because sometimes 12 in an observation program, well allow observations of 13 something like office safety. While certainly thats 14 important, its not our focus area. And, when you do the 15 rack up of information, it substantiated that.
16 So, thats really all I had to identify. Well, we 17 did have some strengths, I just identified. We saw some 18 good teamwork. Thats good. As were building this team, 19 we want to be able to look at teamwork; we want to look at 20 communications, some of our human performance tools, like a 21 questioning attitude and peer checks were identified as 22 commonly seen strengths as part of observation.
23 But as I mentioned, areas that we need to focus on, 24 personal protective equipment; thats why I was personally 25 scheduled and other managers last week to do those; tool MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
51 1 control, checks for hazards, and as identified foreign 2 material exclusion.
3 MR. MENDIOLA: Can I ask a 4 question about your observations? You said 460 management 5 observation in the month of January. How many managers are 6 involved, or better yet, how often does a specific manager 7 make an observation?
8 MR. FAST: Tony, let me try 9 to answer your question. The total population of folks 10 that are involved in the observation program is somewhere 11 around 125; includes from our First Line Supervisor to our 12 Chief Operating Officer. So, if you kind of figure out, 13 you say 125, that would represent about three per. We have 14 some specific targets on how many people, but as well, as 15 far as managers, were actually scheduled approximately 16 once per month. So, thats a scheduled observation. Our 17 expectation is that we exceed the minimum.
18 So, I think the numbers are pretty defensive. They 19 will illuminate at least the fact that you schedule each 20 person for one, you might end up with 125. We end up with 21 468, pretty much demonstrates that were exceeding the 22 minimum expectations.
23 MR. MENDIOLA: Thats almost 24 three or four a month, I would say.
25 MR. FAST: Thats correct.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
52 1 MR. MENDIOLA: You say most of 2 the observations are in the plant. Are you doing any 3 observations, if you will, of meetings or, you know, 4 engineers get together and discuss system characteristic?
5 MR. FAST: Yes, we do.
6 MR. MENDIOLA: Basically the soft 7 stuff.
8 MR. FAST: Absolutely. When 9 we developed this program, I worked with a team of folks 10 from FirstEnergy Nuclear Operating Company. This is a 11 common process we use at all our stations. We didnt want 12 to put this, didnt want to put any over burdensome 13 contraints on it, so we actually provide some examples. In 14 a meeting, are personally done observations of operations 15 turnover, maybe in observations, but Ive also done 16 observations of where Im not directly involved with a 17 meeting; sit back, walk it, watch the interaction, see what 18 the communications are, and we have some specific 19 attributes to that.
20 So, the answer is, yes we do.
21 MR. MENDIOLA: Okay, thank you.
22 MR. SCHRAUDER: I can tell you 23 when NPR was doing the Safety Function Validation Project 24 for us, I spent two days, two different Fridays, where I 25 went down to Virginia and did some observations of their MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
53 1 process as they were going through it also.
2 MR. MYERS: Same thing 3 closer.
4 MR. FAST: We would maybe 5 provide an observation of a vendor out in the field or at 6 their factory or their support headquarters.
7 Any other questions? With that, Ill turn it over 8 to Jim Powers.
9 MR. POWERS: Okay, what I would 10 like to talk about today is looking forward in Restart 11 Readiness, the committee meeting that Randy described in 12 the past slide was talking about Mode 6 readiness for 13 reloading fuel into the reactor.
14 The next mode that well come upon as a milestone is 15 Mode 5. Well replace the replacement head that we have in 16 containment on the reactor vessel with fuel in it. So, we 17 will again assure that were ready for that mode 5, and be 18 prepared for that.
19 Then following that, were going to do a containment 20 integrated leak rate test. This is a test thats done 21 periodically at nuclear plants, typically every ten years, 22 where the containment building is pressurized up to the 23 post accident pressure in containment, and leak tested to 24 verify that it meets regulation and requirement per leak 25 tight integrity.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
54 1 We last did this test in 2000, and the results of 2 that test were very good. We were very leak tight, two and 3 a half percent of the allowed exceptions criteria. So, the 4 engineers are quite proud of the containment systems 5 performance. And weve got the same group preparing the 6 test again.
7 Because its such a large building, we pressurize it 8 with seven large compressors, and that takes about ten 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> to pressurize the building. We pressurize it a bit 10 higher than 38 pounds to provide a demonstration that there 11 is additional margin in the capability of containment.
12 And, so we pressurize it up. We have a stabilization 13 period that we hold pressure about 6 to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, let 14 conditions stabilize in there.
15 Then, we do a drop test is what we refer to it; 16 watching pressure instrumentation is very accurate, and 17 temperature instrumentation is laid out throughout the 18 containment to see any changes that would indicate that the 19 pressure is dropping and that any leakage exists.
20 Following that first phase of the test, the second 21 phase is to introduce a known leak out of the containment 22 with a flow meter, so we know precisely how much air is 23 coming out. Then, we watch our instruments to see if they 24 would detect that, how accurately they detect that. And 25 that validates phase one of the test, showing that the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
55 1 instruments do pick up and read any small leaks.
2 Were looking at this test schedule now to be tested 3 and complete in the early part of March, and its a major 4 milestone for us. It will demonstrate the robust 5 containment. And the real intent of this is to demonstrate 6 that the access openings that we created in the containment 7 to bring in our replacement reactor head, which we have 8 closed up and we did testing, for example, on the 9 containment metallic vessel itself. We did radiography 10 x-rays of all the welds to verify they met all acceptance 11 criteria, which they did. This will be a substantial test 12 of robustness of the containment for completion of that 13 project.
14 MR. HOPKINS: I have a question, 15 Jim. One of those lines up there says, local leak grade 16 test to repair containment. Why do you have the word local 17 there?
18 MR. POWERS: At the time we did 19 that repair itself, we were looking at locally, the actual 20 weld on the vessel to assure that it itself had high 21 integrity. But, one of the questions is when you do such a 22 large construction project on a structure like this, is to 23 demonstrate overall structural integrity. Thats one of 24 the reasons why were undertaking this integrated test.
25 When you do containment testing, you can do MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
56 1 integrated type tests, which is the whole building; or you 2 can do local tests, which is individual valves or in this 3 case welds, to demonstrate each one, one by one, that it 4 has leak tight integrity. So, there is a couple different 5 ways its done.
6 Typically, every ten years you do an integrated test 7 of the whole building, but each refueling outage, youll do 8 local leak rate tests of individual valves. Particularly 9 if you do maintenance on a valve, you need to demonstrate 10 as a post maintenance test that its leak tight integrity 11 has been maintained.
12 MR. HOPKINS: So, in reality, 13 the word local is an error though on the slide.
14 MR. SCHRAUDER: No, its not an 15 error, Jon, weve done both. When we completed that 16 repair, we did a local test of that repair. We will now do 17 an integrated test of the entire containment. Well do 18 both.
19 MR. HOPKINS: Okay. Thats what 20 I didnt understand.
21 MR. POWERS: Any other 22 questions? Okay, if not, I will turn it over to 23 Mr. Schrauder, and hell talk about --
24 MS. LIPA: Well, actually, I 25 was going to interrupt and suggest a 10 minute break at MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
57 1 this point. Okay? So, its 2:19 by my clock, so 2:29.
2 (Off the record.)
3 MS. LIPA: Lets go ahead 4 and get started. Im sure Tony will join us shortly.
5 Go ahead, Bob.
6 MR. SCHRAUDER: Thank you, 7 Christine.
8 As Lew said, for the last several months, Ive been 9 working with Jim, looking at some of the engineering issues 10 that were trying to resolve. In particular, over the last 11 couple of months, Ive been involved in the Safety Function 12 Validation Project and thats the project Im going to 13 spend most of my time discussing the status of the results 14 of that today.
15 Before I get to that, I want to very briefly build 16 the background up to that and why we have the Safety 17 Function Validation Project. So, by way of background, the 18 System Health Assurance Plan is what this falls under and 19 that plan consisted of the Readiness Operational Reviews 20 that were done early in the outage; then the System Health 21 Readiness Reviews, which were part of the Building Block; 22 and then the Latent Issues Reviews.
23 We did a couple of other reviews that we looked at 24 in this. We had done a couple of self-assessments on a 25 couple of other systems; the High Pressure Injection System MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
58 1 and the 4160 Volt Electric Alternating Current System. And 2 then we also looked at the results of the NRC inspections 3 on several of the systems that we had also looked at.
4 As we went through that, all of the issues, 5 potential issues that were documented, that came out of 6 that were documented in our Corrective Action Program.
7 This next slide is kind of a mini version of an 8 issue that we introduced I believe at the last meeting; 9 then we had a more detailed discussion in Lisle regarding 10 our path for resolution of the issues that Condition 11 Reports that came up.
12 We described a three-path process, where Path A is, 13 is our Corrective Action Program. And each individual CR 14 thats written is evaluated through Path A, where we 15 determine its impact on operability, where the RSRV 16 identifies whether its a restart issue or can be resolved 17 post restart, look at whether we need to do an extent of 18 condition for those. So, those are kind of the individual 19 issue resolutions.
20 Then over on the far right you see Path C, which the 21 topical issues, some of the, what the collective reviews 22 looked at is there were certain issues that came up that we 23 lumped together in topical issues. Those were the High 24 Energy Line Break, Environmental Qualification, Seismic 25 Qualification of Equipment, Plugging, Appendix R Issues.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
59 1 And, Ill talk very briefly about how were resolving those 2 at the end of this.
3 Then Path B is where I want to spend most of my time 4 is the Safety Function Validation Project. Weve completed 5 that project now, and we want to discuss the results of 6 that.
7 Next slide shows how we got to the Safety Function 8 Validation Project. As we worked through the System Health 9 Readiness Reviews, Latent Issues Reviews, obviously, we 10 generated quite a few condition reports out of that.
11 So, we did a Safety Consequence Review. Actually, 12 we had NPR associates do that for us. They looked at the 13 body of Condition Reports that had been identified by our 14 Restart Station Review Board as required for restart.
15 Looked at those, binned them together, tried to draw some 16 conclusions from that, and recommend a plan for looking at 17 the extent of condition from those.
18 You can see, we looked at about 600 Condition 19 Reports in that process. Eight percent of them or about 51 20 Condition Reports identified a, it did have potential 21 impact on the plant design basis. And again, this is on, 22 Im going to say, five systems in detail, and two systems 23 that were not as detailed evaluated.
24 So, we had about 28 individual issues, when you bin 25 them together. And again, had the potential for impact on MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
60 1 plant design bases. And, a lot of those potential issues 2 did relate to our calculations supporting the design 3 basis.
4 So what-- the project that we came up with or the 5 extent of condition process, we named the Safety Function 6 Validation Project.
7 MR. GROBE: Bob, before you 8 get into that project, could you status us with where you 9 are with resolving those 28 issues?
10 MR. SCHRAUDER: Those 28 issues 11 are encompassed in the Safety Function Validation Project.
12 I dont have the exact where each one is resolved, but they 13 are working through those in the Corrective Action 14 Program. And, I can status you the next time exactly where 15 each of those are.
16 Some of them I know have been fundamentally 17 resolved, and some of those are the issues Ill talk about 18 in the results of the Safety Function Validation Project.
19 MR. GROBE: Actually, Lew, 20 you and I had talked about possibly having another separate 21 meeting just focusing on design engineering.
22 MR. MYERS: Thats right.
23 MR. GROBE: I think that 24 would be a good idea. Im not sure when would be the best 25 time for that, but maybe sometime over the next 4 to 6 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
61 1 weeks would be appropriate to have that second type of 2 meeting.
3 MR. SCHRAUDER: That would work 4 out well. Ill be going into detail in all those issues 5 and where we are in resolving them.
6 MR. GROBE: Okay, thank you.
7 MR. SCHRAUDER: Again, NPR worked 8 with us, and we developed the Safety Function Validation 9 Project, whose purpose was to provide assurance given what 10 we seen in the safety functions that provide a significant 11 contribution to the core damage frequency as determined by 12 our plant safety analysis, probabilistic safety analysis 13 could be performed.
14 We looked at all those safety functions that 15 contribute greater than one percent of the core damage 16 frequency. Said another way, all those functions added up 17 to covering 99 percent of the core damage frequency. And 18 approximately 99 percent of whats known as the large early 19 release also.
20 Those safety functions identified were comprised 21 within 15 Safety Related Systems. Five of those, we had 22 already evaluated in great detail in the Latent Issue 23 Reviews. Two of them; the High Pressure Injection, and the 24 4160 Volt AC System, we had done a partial assessment of, 25 but not as deep as the Latent Issues Reviews.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
62 1 So, we took those two systems wed done partially 2 and added 8 additional systems we were going to look at in 3 the Safety Function Validation Project for a total of, all 4 total that would be 15 of our safety systems that again 5 cover 99 percent of the core damage frequency for the 6 plant.
7 The methodology that was used by NPR was to first 8 find the safety functions and what attributes would be 9 validated. So, the group went off, identified what the 10 safety functions were, what attributes there were. They 11 identified the available calculations and testing that 12 demonstrate the systems capability to perform those 13 functions, and then reviewed the calculations and testing 14 to validate, to attempt to validate whether or not in fact 15 that safety function or attribute could be fulfilled.
16 It was a two-step process that NPR employed; that 17 is, they first had their groups go off the, the individual 18 groups go off and identify the safety functions, the 19 boundary of the system that they were going to look at.
20 That then came into the board, and the board looked, an 21 Oversight Panel, looked at and reviewed the level, the 22 depth that they were going into and confirmed that, yes, 23 that would capture all the safety functions that we intend 24 to look at.
25 Then, the review teams went off, did their reviews, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
63 1 did their looks at safety functions, calculations, testing 2 that had been performed, all the design basis information 3 that they could get. They then brought that back to the 4 board, and then the board probed them, dug at the issues, 5 did their review to make sure that they had done a 6 comprehensive review of the safety functions that they were 7 attempting to validate.
8 In line with that process, or as part of that 9 process, there were oversight provided by FirstEnergy. I 10 spent a couple of days down there, sat through several of 11 the board presentations at the beginning -- well, actually 12 toward the middle of the project and then at the end of the 13 project.
14 Steve had his Quality Assurance Oversight people 15 were down there for much of the time. Marty Farber from 16 the NRC observed a large part of that. We also had at 17 least one member of our Engineering Assessment Board 18 present at nearly all of the Oversight Panel Reviews of 19 those. So, we got a lot of review while that was in 20 process.
21 I would tell you that I believe that it was a very 22 thorough and comprehensive review. I think they did a good 23 job. I think Marty and the inspector that he brought down 24 with him felt like it was a pretty high quality review that 25 was done.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
64 1 So, thats all well and good. Whats the results of 2 it? Four of those systems -- Im sorry. The additional 3 thing that NPR was doing for us in that review was for 4 functions that could not be fully validated, they did 5 perform some of the preliminary technical evaluation to see 6 the impact of that; to determine the effect on systems 7 capability, and they helped us in operability 8 determinations if required, if the systems were found to be 9 degraded.
10 Then, of course, all the nonconformances that were 11 identified during the course of that project were also 12 entered into the Corrective Action Program, and they would 13 then go back over to Path A and come down through the 14 Corrective Action Program.
15 MR. GROBE: Bob, let me 16 make sure I understand that. Oftentimes in engineering 17 reviews, you come up with a lot of questions. And, its a 18 period of time until those questions are revolved to the 19 point where you can conclude theyre actually nonconforming 20 conditions.
21 Do you still have a batch of questions that are 22 still being evaluated, or have all of the issues been 23 evaluated and dispositioned as either nonconforming 24 conditions or adequately resolved?
25 MR. SCHRAUDER: All of the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
65 1 evaluations have not been completed yet, Jack, out of the 2 Safety Function Validation Project. In some cases, they 3 were not able to, with the information they had available 4 to them, validate for instance a safety function. That 5 then comes back to us and we have to do further analysis, 6 in some cases, and further research.
7 So, not all of those Condition Reports that came out 8 of this are complete yet; and we have not yet completed the 9 effort of attempting to validate those systems which NPR 10 was not able to validate their safety function.
11 MR. GROBE: Okay. So, 12 all of the questions have been turned into Condition 13 Reports and youre continuing the evaluation under the 14 Condition Reporting Process?
15 MR. SCHRAUDER: Thats 16 correct.
17 MR. GROBE: Thank you.
18 MR. MENDIOLA: Im not sure 19 I understand. This is a one-time project? In other 20 words, you know, now that you finished it, now that you 21 looked at these 15 systems, and youve come up with either 22 being fully validated or those that need additional 23 analysis; thats it, basically, everything gets handed over 24 to the Corrective Action Program?
25 MR. SCHRAUDER: Im not sure MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
66 1 I understand your question, but basically the answer is 2 yes. Its a one-time project that covered 99 percent of 3 the core damage frequency, but those issues that were 4 identified need to be resolved and they are categorized as 5 either needing to be resolved prior to restart, or whether 6 they can be resolved post restart. Because every 7 discrepancy that they found, we identified and put into the 8 Corrective Action Program.
9 The ongoing process is, as weve talked about in the 10 past for assuring continued system health and maintaining 11 design basis, are the latent issue reviews, which we will 12 incorporate into our ongoing processes.
13 MR. MENDIOLA: So, that, if 14 you will, is the long term result of this project, is to 15 institutionalize that kind of material into a constant 16 everyday process that you have at the site?
17 MR. SCHRAUDER: Yes.
18 MR. MENDIOLA: So, it would 19 show itself in a latent issue?
20 MR. SCHRAUDER: The Latent 21 Issue Review Program will be the institutionalization of 22 systematic reviews of systems to assure ourselves that we 23 maintain them in full stead.
24 MR. MENDIOLA: Okay, thank 25 you.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
67 1 MR. SCHRAUDER: Okay, the 2 results of the project. Four of the systems that were 3 looked at, NPR was able to fully validate their safety 4 functions; thats the High Pressure Injection System, the 5 Main Steam System -- Steam Generators and the Safety 6 Features Actuation System.
7 You see there are additional systems that we still 8 require, as Jack asked about before, additional analysis to 9 confirm or identify that the safety system could not be, 10 the safety function could not be validated. Those systems 11 are listed there.
12 We have a fairly high competence level that when 13 were through with all the analysis, that we will be able 14 to demonstrate that each of these systems was capable of 15 performing its safety function. We have just not yet 16 completed all those reviews, and some cases may have to do 17 some recalculation, some reanalysis to show that.
18 Do you have a question, Jack?
19 MR. GROBE: I wanted to make 20 sure I understood the totality of the results. These 21 results on this slide, called Project Results; those are 22 the results of the Validation Project. You had seven 23 additional systems that you looked at under Latent Issue 24 Review and Self-Assessments. How many of the systems from 25 those additional seven fell into the fully validated MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
68 1 category and are requiring additional analysis category?
2 MR. SCHRAUDER: I would tell 3 you from the Latent Issue Reviews, that none of those 4 systems were fully validated when they went through their 5 Latent Issue Reviews, and they would fall into the same 6 category of some of those. Again, they were questions that 7 were asked that the individuals could not either find the 8 documentation, or in some cases there was conflicting 9 information. I will tell you, none of the Latent Issue 10 Reviews would result in what we would say their safety 11 function was validated.
12 Many of those issues we have resolved along the way; 13 have not yet reached the point where we have declared any 14 one of those systems completely validated yet.
15 MR. GROBE: And the two 16 systems that you did Self-Assessments on, those also were 17 not fully validated?
18 MR. SCHRAUDER: Right. The 19 ones that we did Self-Assessments on are included in the 20 Safety Function Validation Project.
21 MR. GROBE: I see. So, 22 the total then is 13 systems.
23 MR. SCHRAUDER: The total is 24 15 systems; 5 Latent Issues, 2 Self-Assessments that were 25 redone in the Safety Function Validation Project, and then MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
69 1 8 additional systems. So, the total amount of systems we 2 looked at in this level of detail was 15.
3 MR. GROBE: I think I 4 understand. Thank you.
5 MR. SCHRAUDER: So, each of 6 those additional analysis required, again are entered into 7 the Corrective Action Program. And in many cases or 8 several of the cases, for instance, Low Pressure Injection 9 System, there is one function of that system that yet has 10 to be validated. Then, were working through those 11 issues.
12 Any other questions on the Safety Function 13 Validation Project?
14 MR. PASSEHL: So, I guess 15 on your slide 22, you dont have all 15 systems listed on 16 here; you have 8. And there is an extra 7?
17 MR. SCHRAUDER: Actually, all 18 of them that were comprised within the Safety Function 19 Validation Project are here. Where its the Electrical 20 Distribution Systems, that includes 125 Volt/250 Volt DC 21 System, the 4160 Volt AC System and 480 Volt AC System.
22 One of the good things, I would say, that came out 23 of it or one of the encouraging things, is we looked at the 24 electrical distribution systems, we were not able to fully 25 validate that, but all but one I believe of the issues that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
70 1 came out of the Safety Function Validation Project had been 2 previously identified in the System Health Readiness 3 Reviews that we had done.
4 The process that NPR did, they didnt look at what 5 had already been identified for those systems. They merely 6 identified the safety function they were trying to 7 validate, find what documentation they could have, created 8 their questions or their issues, and then they looked to 9 see if that issue was already addressed in the Corrective 10 Action System.
11 And, for the Electrical Distribution System, like I 12 said, with the exception of the battery issue that was 13 raised, all of those conditions had been identified under 14 the System Health Readiness Reviews, even though those 15 reviews were not really targeted at a detailed analysis of 16 the calculations and the design basis information for those 17 systems.
18 So, I think it just, in my mind it adds some 19 credibility, I would say, to the System Health Readiness 20 Reviews. And, that was a comment that NPR made to us 21 also.
22 MS. LIPA: The question I 23 have -- excuse me, Jack. Maybe youre going to get to it 24 later. At what point will you be at or where are you in 25 the process of determining if any of these are passed MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
71 1 operability, past reportability, LER-type issues?
2 MR. SCHRAUDER: All of those 3 issues still have to be evaluated and it will depend, 4 obviously, thats what the evaluation is doing. Can we 5 determine or demonstrate operability from a going forward 6 prospective, and also we will have to look back and 7 determine its past operability if, the function is in fact 8 found to be not able to be validated.
9 Thats all part of the normal condition reporting 10 process. And were working through those Condition 11 Reports.
12 MS. LIPA: So, you havent 13 even gotten to the point where youve determined that it 14 would be reportable to start the 60 day clock from any of 15 these issues?
16 MR. SCHRAUDER: Thats correct.
17 The other thing that we did find -- sorry, Jack -- in this 18 process, both in the Safety Function Validation Project and 19 the, what Ill get to in just a minute, as were looking at 20 the topical issues; we did confirm what we suspected; that 21 is, we have a lot of help in looking at these reviews and 22 going through documentation for the plant calculation, with 23 a lot of people that are not familiar with our design or 24 licensing basis; theyre not familiar with the 25 calculational structures and where to find information.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
72 1 And they, as we told them, dont spend a whole lot 2 of time. If you cant find the information, generate the 3 CR, get it into the system, and well turn people loose on 4 going down it.
5 We did in fact, have in fact found numerous examples 6 of where the information was in fact contained in 7 calculations if you knew your way around it, could find 8 it. You know, there are certain aspects of those Condition 9 Reports that are attributed directly to what we are 10 licensed to and what our design basis is. So, a lot of the 11 issues are not issues. Theyre simply questions that were 12 raised and are easily answered once you get the 13 calculations out and can demonstrate it.
14 I have a percentage for you on that, but there are a 15 lot of them in there that-- and that was done by intent.
16 We wanted them to get the reviews done. If they had 17 questions, dont stop the review, get them into the 18 process, and well get to those as we can.
19 MR. GROBE: Just a comment, 20 Bob, so that you and your licensing folks can anticipate 21 our needs. Recognizing the number of design questions 22 youre still in the process of resolving. We discussed 23 this, this morning, and internally in a panel meeting; 24 determined that it might be appropriate now to start weekly 25 calls with your Regulatory Affairs Group to track the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
73 1 resolution of these questions. I anticipate that there is 2 a possibility there may be some licensing questions that 3 come up in the course of resolution of these issues. And, 4 early dialogue will help us be prepared to understand those 5 issues, and help you understand our perspectives on them.
6 So, Ive asked Tony and Jon to set up with your 7 staff, your licensing staff, some weekly dialogues to go 8 through the status of these issues and identify the ones 9 that have the greatest risk of needing licensing work, so 10 that we can be prepared to do that.
11 MR. SCHRAUDER: I think 12 thats a good idea, Jack. I can tell you that there is one 13 that came out of the Safety Function Validation Project 14 that I know of, and thats on the differential pressure 15 trip set point that the steam feedwater control system, 16 where the tech spec value is nonconservative relative to 17 the design basis calculations. In that case, we will have 18 the procedure for that, looks like it was also 19 nonconservative relative to the calculational base behind 20 it.
21 What we have to do now is look at where do we 22 actually have the trip set point set. And, also make sure 23 that the procedure now aligns with the design basis, and 24 then well have you come in with a license amendment 25 request, to change the tech spec, because the tech spec MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
74 1 value is a nonconservative tech spec and follow NRC 2 guidelines on how you handle those issues also.
3 There are some licensing issues that will come out 4 of it.
5 MR. MENDIOLA: Bob, Im going to 6 ask the stupid question here. You started out on slide 20 7 with 15 safety systems. Okay. Slide 22 only has 8 8 listed. I can only assume from your response earlier that 9 all the Electrical Distribution System systems, if you 10 will, the 15, are listed at the bottom there. Theyre all 11 compressed into one bullet?
12 MR. SCHRAUDER: Let me go 13 through the 15 systems for you clearly.
14 MR. MENDIOLA: Basically, 15 the very simple question is, where is the other 7?
16 MR. SCHRAUDER: Let me go 17 walk through it for you. There were 15 total systems.
18 Five of them were completed under the Latent Issue Review.
19 They were not looked at in the Safety Function Validation 20 Project. Okay. That leaves 10 systems.
21 If you look at the slide youre looking at, there 22 are eight bullets there. The last bullet, the Electrical 23 Distribution System is actually three systems; 125 Volt 24 DC-- 125/250 Volt DC, the 4160 Volt AC, and 480 Volt AC.
25 So, that should be ten systems there and the five MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
75 1 from the Latent Issues Review.
2 MR. MENDIOLA: Okay. Thank 3 you.
4 From the systems requiring additional analysis, was 5 there any, for lack of better terminology, red flags or 6 anything to cause, anything that we should, if you will, 7 start focusing on?
8 MR. SCHRAUDER: The one that 9 I dont have a very clear path to how its going to be 10 resolved yet Ill talk about; and thats the Low Pressure 11 Injection System of the Decay Heat System. The safety 12 function there that were trying to validate yet or need to 13 relook at is the, we have two methods of Boron 14 precipitation control post LOCA.
15 Our secondary method for Boron precipitation control 16 post LOCA is through the decay heat drop line, where you 17 have one low pressure injection system taking suction from 18 that for the purposes of precipitation control; you have 19 the other LPI system injecting into the vessel.
20 Early tests for the plant identified that the net, 21 to satisfy the net positive suction head requirements for 22 that pump for Boron precipitation control required eleven 23 inch height in the drop leg.
24 This review identified that the calculational basis 25 identified that if youre injecting an LPI pump, were MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
76 1 running at runout, it could only supply seven inches of 2 head in that drop line.
3 So, the analysis that were going through right now 4 is there is some questions on the validity of the test, 5 because it was not really run, Boron precipitation control 6 wasnt considered at the time the plant was licensed. It 7 was a later addition. So, the test that was done was 8 really not for the purposes of establishing precipitation 9 control. So, once they got to a certain level, eleven 10 inches, ran it there for a certain time; they said, okay, 11 end the test, well draw a curve from that.
12 During the course of that test and looking at the 13 data now, and the reason they stopped at eleven inches, was 14 testers believed that they heard cavitation in the pump at 15 that level. Going back and looking at the test data now, 16 whats believed is what they were hearing was air entrapped 17 in the system from the previous test; and that theyre 18 looking at pressure gauges and discharge pressure from the 19 pump, you know, being able to show the pump couldnt have 20 been cavitating with the kind of pressure indications that 21 you had there.
22 And so, Framatone was working with us in resolving 23 this. When I say I dont have a clear path to solution on 24 this, were either going to have to demonstrate 25 analytically with the data we have available that the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
77 1 required height is much less than eleven inches and you 2 could have met that safety function; or were going to have 3 to take, were going to have to test that under, in a 4 mockup facility and reestablish what the actual height is.
5 So, thats one of them I would say, yeah, we dont 6 have a clear answer on that one yet, but I believe there is 7 two paths to pursue on that one.
8 MR. MENDIOLA: Okay, thank you.
9 Im just curious on the timetable for when this information 10 might be more readily available to us? Will be a while 11 off?
12 MR. SCHRAUDER: Which information, 13 Tony?
14 MR. MENDIOLA: Well, things like 15 you just brought up; your response and your reaction to how 16 youre going to conclude that analysis, and conclude this 17 issue?
18 MR. SCHRAUDER: It will be 19 available to you as soon as we know which way were going 20 with it. Some of these issues just are being evaluated.
21 MR. MENDIOLA: Okay, I 22 understand.
23 MR. SCHRAUDER: Okay, emergency 24 core cooling system, HVAC system, thats another one that 25 relates back to the ultimate heat sink temperature. Thats MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
78 1 really an environmental qualification issue, where the room 2 was originally, max temperatures was expected to be 125 3 degrees in that.
4 When you include two issues in there; the high 5 pressure injection pump running in the room was not 6 considered as a heat addition to the room, and it needed to 7 be; also, when you looked at the impact of raising the 8 temperature to 90 degrees, and the potential for separation 9 from the lake, if you will, and the heatup of the forebay, 10 the bottom line conclusion was that the actual maximum 11 temperature in that room would rise above 125, and would 12 peak somewhere around 133 degrees.
13 So, we had to go relook at all the equipment in the 14 room and see, will it withstand 133 degrees. We have 15 looked at that, and we have one relay that was qualified 16 for 125. We dont have, I dont believe we have right now 17 sufficient information to say it works at 133. So, we 18 still have some more analysis to do with; if there is other 19 facilities that have tested it higher, well probably take 20 that relay out and qualify it to a higher temperature to 21 verify that it would have functioned at 140 degrees. And 22 we may have to go out and buy a replacement relay for 23 that.
24 Thats the type of issues that were dealing with, 25 on those unvalidated systems yet.
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79 1 MR. MENDIOLA: Okay, thank you.
2 MR. PASSEHL: I would have an 3 additional question. You mentioned on slide 18, your 4 Safety Function Validation Project, you stated that youre 5 completed with that. Yet on slide 22, you got all these 6 systems requiring additional analysis. What did you mean 7 by completed with that?
8 MR. SCHRAUDER: The Safety 9 Function Validation Project was a defined scope of work 10 that NPR did for us. They performed that issue for us.
11 They have turned over the results of that and said, here 12 are the things that we could not validate. So we then put 13 them into the Corrective Action Program where we will have 14 to resolve those, but the project itself is completed.
15 MR. PASSEHL: I understand.
16 And, then your five systems you did on the Latent Issue 17 Reviews; Reactor Coolant System, Aux. Feedwater --
18 MR. SCHRAUDER: Service Water.
19 MR. PASSEHL: Are those fully 20 validated?
21 MR. SCHRAUDER: No, thats the 22 question Jack asked before. None of those systems were 23 fully validated in the Latent Issue Reviews either. So, 24 the same process is ongoing for them; further analysis, 25 further research.
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80 1 MR. PASSEHL: Okay, thank you.
2 MR. SCHRAUDER: Okay. The other 3 thing, Path C was the Topical Issues. And the Topical 4 Issue Reviews are not done yet, not completed yet. Those, 5 again, I have identified before is Seismic Qualification, 6 High Energy Line Break, Environmental Qualification, 7 Appendix R Safe Shutdown Analysis and the Station 8 Flooding.
9 Described briefly here, the process were going 10 through to review those. Were doing Collective 11 Significance Reviews on those topical areas. Were 12 looking, were using a Nuclear Operating Business Procedure 13 that, its a relatively new procedure that weve developed, 14 across FENOC. Its specifically aimed at Collective 15 Significance Reviews. It provides us with a consistent 16 process and consistent format for the analysis of those 17 systems.
18 Well use the Condition Report Data Base to pull all 19 the issues that have been identified relative to those. We 20 would bin those Condition Reports, much like we did in the 21 Safety Function Validation Project, into specific topical 22 areas within that topic. And then, well look at those to 23 see whether they have implication, problematic implications 24 to those topical areas, and well also conduct an extended 25 condition evaluation for the area where thats warranted.
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81 1 Then, well determine, schedule again the Corrective 2 Actions that come out of that, go into the system to 3 determine whether they need to be done prior to or post 4 restart and well schedule those Corrective Actions.
5 Then, when the report is written, it will go through 6 our Engineering Assessment Board to review the results of 7 that process also.
8 Those things, Im going to say theyre probably 75 9 to 80 percent complete right now, some in a more of a state 10 of completion than others. I expect that they will be, the 11 reviewers should be completed with their work this week and 12 then they will be scheduled for AP Review within the next 13 week or so.
14 MR. GROBE: Bob, are the 15 reviews completed sufficiently that you can give us some 16 insight on how many of the areas warranted further extended 17 condition review?
18 MR. SCHRAUDER: I can speak to 19 one, Jack, that Ive looked at pretty much. Thats the 20 Seismic Category.
21 Seismic Category had identified several things. Two 22 over one criteria. Much of that was a, restraints of some 23 temporary equipment. We also looked at the impact of the 24 Boron deposits that were in the containment. Did they 25 impact the seismic capability of the systems they were on?
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82 1 We found that they did not.
2 We had one issue that came out of this, was a 3 relatively old issue though. Early in the plants life, we 4 got some of these relays, HFA relays that were identified 5 under GE SIL. I cant recall what SIL stands for.
6 Notification to industry from a vendor.
7 MR. POWERS: Service 8 Information Letter.
9 MR. SCHRAUDER: Service 10 Information Letter. Thanks, Jim.
11 We had bought these relays by way of a third party.
12 We didnt get them directly from GE. We were not on their 13 vendor list for them. So, we did not get the information 14 in when they put it out, that these relays needed to have 15 certain adjustments or checks to see if they needed 16 adjustments periodically.
17 I think we had about five of those. We identified a 18 few of those and we did do an extended condition to find 19 out how many of these HFA relays do we have. Well go out 20 and perform the set point checks on that.
21 And then we did confirm that we plugged that gap in 22 the process, a third party vendor, we would get information 23 on their products. And this was, was found to be isolated 24 in this case, with GE. I think we had gone through 25 Westinghouse that that had been corrected in the past.
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83 1 Another one we did find that we had to do an 2 extended condition on the seismic was, our process a couple 3 of years ago has had some discrepancies in the seismic and 4 safety classification, where you might in the safety, 5 safety/nonsafety boundary at say an open root valve, 6 downstream up there, you might have a transmitter or 7 something that needed to be qualified for seismic 8 purposes.
9 Either was not reflected properly on the PNIDs, or 10 the data base that we use to track that; had it confusing 11 to modification, if youre putting it in.
12 We went back and did an extended condition on that, 13 to see. We looked back to the point that that confusion 14 was introduced into the system and looked back at all the 15 mods done since that time. And I believe that resulted in 16 identification of five transmitters that needed to be 17 looked at. Two of those were original purchases, and they 18 were, did have the proper qualification to them. We had to 19 replace three transmitters. Thats an example of an 20 extended condition that came out.
21 One final one was a, I dont know if you recall this 22 or not, but there was an issue again on the seismic 23 classification in the service water pump bay, if you will.
24 And the cooling tower makeup line went through there. And, 25 it was supposed to be seismic. And it was not seismic. It MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
84 1 was not installed seismically.
2 So, we had to do an analysis to show. We used a 3 methodology to determine the line would have withstood the 4 frequency, the resonance frequency for the earthquake. We 5 used that method to show it would have withstood the 6 earthquake effects, but we are also going back and making 7 that seismic now.
8 That resulted in an extended condition, so we had to 9 go out and look at other systems where there were multiple 10 trains or multiple systems in a single area that could be 11 impacted by that event. And, by that situation, we found 12 four or five other areas that we had to go look at. All of 13 those turned out to be acceptable.
14 Thats the kinds of things were finding in the 15 extended conditions that were doing as a result of.
16 MR. GROBE: Okay, thank 17 you.
18 MR. SCHRAUDER: That 19 concludes my discussion, unless theres -- well, there is a 20 summary slide here that says, as I said before, we did show 21 good correlation with the System Health Readiness Reviews.
22 We do have more analytical work ahead of us to be able to 23 fully validate some of the safety functions. We have yet, 24 we have not identified any major modifications necessary as 25 a result of the Safety Function Validation; or so far, the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
85 1 Topical Area Reviews.
2 And we did confirm, I think what we had already 3 said, that there was some rigor in the calculations, 4 clerical calculations that was lacking.
5 MR. GROBE: Thank you.
6 MR. SCHRAUDER: With that, I turn 7 it over to --
8 MR. MYERS: Me.
9 MR. SCHRAUDER: Lew Myers.
10 MR. MYERS: Thank you.
11 I have to sort of shift gears now, talk about 12 providing you some information in a few areas first, give 13 you a snapshot of the January the 30th meeting that we had 14 with the Nuclear Regulatory Commission in Chicago to 15 discuss Safety Culture and Safety Conscious Work 16 Environment.
17 Second, to status our Restart Readiness Review 18 Meeting that we had, where we looked at -- once again, I 19 want to make this clear, we only looked at fuel, because 20 Restart Readiness Review Meeting was not prepared, designed 21 to look at restart. We do various Restart Readiness Review 22 Meetings as we change operating modes of the plant, so Ill 23 provide you some observations of the one we did for fuel 24 load.
25 And, finally, Ill provide you status of how we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
86 1 addressed the safety, Safety Culture readiness for fuel 2 load. That will be the first time weve done that.
3 First, I would like to give you a little background.
4 The Root Cause Report for the Reactor Vessel Head was 5 presented last August. In that report, there were 6 basically five overall conclusions that we had.
7 First, we found that there was a production focus 8 established by management combined with taking minimum 9 actions to meet regulatory requirements and in some cases 10 we did meet the minimum action, and that resulted in 11 acceptance of degraded conditions. Item number one.
12 Second, we found that Davis-Besse had been operating 13 a long time as basically an isolated plant. As you 14 remember, FirstEnergy is a fairly new company. And then we 15 took over the Beaver Valley Station. So, if you look at 16 our Davis-Besse station, all our performance indicators 17 were running along pretty well. So, from a FirstEnergy 18 standpoint, it was still being operated sort of as a 19 stand-alone plant.
20 Third, a large number of Condition Reports were 21 identified by our employees. There was like over twenty 22 Condition Reports written, but they werent properly 23 classified or evaluated. If they had been, we wouldnt be 24 sitting here today. So, the employees were writing and 25 identifying problems.
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87 1 Fourth, our Quality Organization reported to the 2 site staff for many years, and as a result their 3 effectiveness was limited. In fact, they became part of 4 the same culture, if you will. And when you read back on 5 the reports, some of the conclusions that they drew based 6 on the findings, its hard to correlate those conclusions 7 as being accurate.
8 Fifth, Operations was not actively involved in the 9 role of improving the plant conditions. Somewhere along 10 the line, over a long length of time, sort of have a 11 different role with Randy and I, than others have seen 12 traditionally in other nuclear stations.
13 With that, those are the areas that our Root Cause 14 sort of focused on, and I would like to provide you with 15 now the next slide. The definitions of what weve given 16 our employees, as Safety Culture and Safety Conscious Work 17 Environment.
18 We divide those things into two areas, and 19 basically, two different definitions. Let me tell you 20 why. From a Safety Culture standpoint, we define that as 21 the "assembly of characteristics and attitudes", so both 22 characteristics and attitudes, "in the organization", which 23 is organization, youre looking at the organization; "and 24 individuals", so, what they see from, "which establishes an 25 overriding priority towards nuclear safety activities and MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
88 1 ensures that issues received the attention warranted by 2 their significance."
3 Write a CR, properly classified. If youre out 4 doing a job in the field, you get the right management 5 oversight. Thats what were talking about here.
6 From a Safety Conscious Work Environment standpoint, 7 its "That part of a Safety Culture", if you will, 8 "addressing employee willingness to raise issues and 9 managements response to these issues." So, they have an 10 environment that encourages them to identify problems.
11 Next slide.
12 At that meeting, we provided the NRC a management 13 model. Once again, I want to stress this. This is a 14 management model. Its not an employee model. And this, 15 its not designed to establish the perfect employee.
16 It can and should be used to help management and 17 ensure that the correct standards are present in the 18 organization, and that our standards are properly being 19 understood by our employees, and then be implemented into 20 the field. Are we sending the right message to our 21 employees? Thats the real question.
22 There are three commitment areas that we discussed 23 with the NRC at that meeting, and 14 individual commitments 24 that we also discussed that we monitor effectiveness in.
25 Now, let me go through those.
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89 1 First is the policy level commitment. That policy 2 level commitment has to do with the message that we send 3 from our corporate organization. Are our policies correct 4 from a safety standpoint? The management value structure 5 that we have. Do we understand our value and vision and 6 are they being properly implemented in the field. The 7 resources that we provide; the same thing from time, money 8 to people.
9 And then, finally, the oversight that we provide, 10 from not only a quality oversight point-- standpoint, but 11 from a self-assessment standpoint. Those are the type of 12 things were talking about there.
13 Then you move on into the management commitment 14 area, if you will. The commitments under there are 15 emphasis on safety. Do we send the right messages daily, 16 when we find issues? That we understand the 17 responsibilities of the managers and the organizations and 18 are we cohesive as a team. And that was an area that we 19 really want to start focusing on. I would tell you that we 20 were sort of in isolationism in our group.
21 Then finally, accountability of responsibility. Do 22 we understand who is responsible? That accountability is 23 clear. Qualifications in training is more than just 24 maintenance or operator training; its leadership training, 25 its management training, and supervisor skills training MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
90 1 also. Then, high organizational commitment to safety. Are 2 we really committed to it? Do we send those messages?
3 And then, finally under the individual area, you can 4 focus on the nuclear professionalism. You know, what do 5 people, what do they understand technically when theyre in 6 the field. I mean, do you understand what youre dealing 7 with and do you have the right sensitivity to those issues?
8 Open communications. Thats the vertical 9 communications within our organization. And then rigorous 10 work control. Thats more than just going out working a 11 work package. Are the engineering documents that we 12 prepare quality documents? And one that I know is close to 13 our heart right now are the RWPs that we prepared, 14 radiologic standpoint, thorough and accurate. So, its 15 across the board from a work control standpoint.
16 Questioning attitudes and overall drive for 17 excellence, and maintain our plant, and improving safety 18 margins from cycle to cycle, both from a personnel 19 standpoint, but also from a material standpoint.
20 With that being said, let me go through some of the 21 actions were taking very quickly. These are just, you 22 know, just a snapshot of the actions that we shared with 23 you all guys in the January 30th meeting.
24 First from a policy standpoint, we started taking 25 many of our actions back in the May time frame in 2002, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
91 1 after we finished our Technical Review. The first action 2 we took was create a management structure for oversight, 3 and took the action to sponsor the Management/Human 4 Performance Report that we shared with you in August.
5 And then, after that, our FirstEnergy Board of 6 Directors issued a resolution on nuclear safety. Thats 7 what we think should be the genesis of the standing in our 8 company. From that point on, Bob Saunders provided two new 9 policies; one on Safety Culture and one on Safety Conscious 10 Work Environment.
11 Weve now met with all of our employees and trained 12 all employees at FirstEnergy Nuclear Operating Company on 13 those policies. We strengthened our Incentive Program, 14 which we talked about with the root cause to focus on 15 safety.
16 Weve established and implemented an executive level 17 organization, if you will. We now have the Quality 18 Assurance Manager, the Executive VP of Engineering and 19 Chief Operating Officer position at our corporation -- at 20 our corporate offices. And if you go look at this alone, 21 it would have prevented some of the isolationism and 22 assured standardization of our processes, and it would have 23 probably improved the quality, the quality of the oversight 24 documents that we looked at and may have resulted in us not 25 being here today.
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92 1 We strengthened our Employee Concerns Program. We 2 work hard to make sure thats an anonymous program and 3 people feel free to come forward with that, into that 4 program and address issues. And, were seeing good 5 improvement there.
6 From a management standpoint, you know, I talked at 7 that meeting about our management team. Today up here, you 8 know, I think its our senior team. Were technically 9 involved with things going on at the plant. Before we came 10 here today, we took time looking at the videotape of our 11 reactor vessel, so we could understand the cleanliness 12 requirement, you know.
13 We talked somewhat about that, but the management 14 team we have in place at our station has over 460 years of 15 nuclear experience. Most of them are SRO, most of them are 16 degreed individuals with advanced degrees. And whats more 17 important than that, theyre proven leaders in industry. A 18 lot of us have worked other places, worked at our other 19 plants and were a pretty well known commodity. So, we 20 really believe that we really strengthen the leadership 21 team for the plant.
22 Additionally from a, a standpoint of what failed; 23 Tony, you asked a question awhile ago about the Corrective 24 Action Program. If were going to restart our plant, we 25 have to make sure that our Corrective Action Program is MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
93 1 working properly. I mean, it is the backbone of how we 2 identify problems, where we put things. Once we stick them 3 in there, they cant get lost. They might not get worked 4 on, but they cant get lost.
5 So, its imperative that we properly classify and 6 then evaluate issues. And, what weve done to strengthen 7 that is our Corrective Action Review Board. Now its 8 chaired by Randy Fast. On there we also have engineering 9 managers and the Operations Manager. So, we really, really 10 escalate the duties and responsibilities of that board, 11 their performance indicators, and tried to strengthen the 12 Corrective Action Program.
13 Additionally now, once we solve our problem that our 14 employees had given us, we send each and every employee 15 back an email telling them how we solved their problem.
16 So, we think were improving that program a lot.
17 We improved our leadership conferences. You know, 18 one of the things we now have, we evaluate each and every 19 one of our managers, supervisor yearly; and were in the 20 process of doing that right now. Weve added two new 21 conferences that focus on safety. So, thats new for us.
22 Weve strengthened our problem solving and 23 decision-making nuclear operating procedure. As I think 24 Christine knows, we have a procedure that we used at Perry 25 for decision-making; stop, analyze the problem, get the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
94 1 right people involved, use the right techniques.
2 You know, we did not have that at the Davis-Besse 3 Plant, so weve turned that into a nuclear operating 4 procedure thats now used every day at all of our plants, 5 called morning phone call. We have a morning phone call 6 7:30, just about every day you can hear somebody talking 7 about an action plan they developed for one of the nuclear 8 operating decision-making models. So, we think thats 9 really strengthened the way we -- when we find problems, 10 that we deal with them.
11 Then, Engineering Assessment Board is now in place 12 at this station to look at the engineering products. And 13 probably if they looked at some of the engineering products 14 that were sent out in the past, we wouldnt be here today.
15 So, we think were seeing good improvement there.
16 Now lets move on to the individual. Weve talked 17 about the Reactor Vessel Head Group Training that weve 18 done, if you will, where we sit down each and every group 19 individually, and went through, in depth training on this 20 event and how your particular group was involved with this 21 event; how we should have found it earlier. Then we went 22 through the group standards and we tested each and every 23 person on site. So, thats complete.
24 The Town Hall Meetings are basically weekly. We may 25 miss a week every now and then, but usually weekly. Randy MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
95 1 says we have a hundred people. Jim says we have 40. So, 2 we typically have somewhere between 100, 140 people.
3 I dont know how I came up with that math, but 4 sometimes theyre very large groups and sometimes there are 5 groups where Ive attended meetings of about 40 people.
6 If you go look, I talked about our 4-Cs Meetings.
7 I try to have one of those meetings basically weekly with 8 our employees. Ive now met with over 500 of our 9 employees. And, you know, its really interesting. I 10 think its time for maybe one of you all to come in and sit 11 in on one of those meetings. Our employees are brutally 12 honest. Thats one thing Ill say about them. I think 13 those meetings are good.
14 The one thing that I see coming out of that, is a 15 willingness of the employees. When we do these meetings, 16 we have, we have the team meet together to identify their 17 concerns and their compliments and everything. So, I want 18 to know who wrote the question out. Then, when I come into 19 the meeting and go over all those things, I prepare and try 20 to be able to give them good responsive answers.
21 And what Im finding now more and more at those 22 meetings, as I bring up the questions, the employees will 23 say, well, this was my question, which shows me its the 24 environment Im looking for. So, I think those meetings 25 have been very valuable.
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96 1 There is something that I believe, they tell me in 2 the years that theyve been at Davis-Besse, theyve never 3 had an opportunity to sit down with a VP and be able to 4 talk with him. I dont quite understand that, but thats 5 something we should keep a permanent part of our system in 6 the future; and we intend to.
7 Finally, we created -- we had operability training, 8 as you know. And our Root Cause Report, our Operations 9 Group was lax on, prove to me this is operable; come to me, 10 engineering, show me why its operable. And, we were doing 11 some things by telephone that we shouldnt have. So, we 12 reevaluated the operability process, provided training to 13 all of our engineers, all of our operators. I think youll 14 find that very challenging, operability issues now.
15 And then finally, we went back and we requalified 16 each and every one of our root cause evaluators. Those are 17 just some of the actions we have taken. There may be 18 more.
19 The next area, I want to talk about is --
20 MR. GROBE: Before you go on, 21 I have a question on slide 30. I wanted to hear this slide 22 31 material before I asked it.
23 In the 3 areas; policy, management and individual, 24 you have four to five assessment attributes, I guess.
25 MR. MYERS: Right.
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97 1 MR. GROBE: In each of those 2 assessment attributes, there is a number of data sources 3 that goes into your assessment in that area. Have you 4 developed that sufficiently that its on paper, its 5 something thats ready for us?
6 MR. MYERS: We used it, Jack.
7 MR. GROBE: Pardon me?
8 MR. MYERS: We used it during 9 the Restart Assessment. Now that weve used it, were 10 going back and modifying it some, but its actually been 11 used. Im going to talk about that, as a matter of fact.
12 MR. GROBE: Okay, good.
13 MR. MYERS: In our Restart 14 Readiness Review, let me tell you, the purpose of that 15 meeting is not to justify why we should load fuel, the 16 purpose of that meeting is to determine why we should load 17 fuel. You know, do we have a consensus around the table 18 that loading fuel, were ready to load fuel. And, well do 19 that for Mode 4 and other times.
20 As Randy said, the meetings, this meeting went on 21 for five and a half days over a several week period. If 22 nothing else, it was a good team building session. Start 23 off not doing as well as I would have expected on 24 presenting their areas, but ended up I thought fairly 25 well.
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98 1 What we do there is we bring each and every group in 2 our station in, and the groups come in and explain why 3 their organization is ready to load fuel. Do you have 4 the -- and we have a list of questions that we go through; 5 3 or 4 page list that they need to be able to answer.
6 Do you have the people in place that you need? From 7 a health physics standpoint, do we have all the areas 8 locked that we need to go lock up now to load fuel? Do we 9 have the organization in place? What is different now 10 than it was before, you know? So, they need to be able to 11 answer those questions.
12 We also have a group of questions they have to ask 13 about Safety Culture in those areas. So, each and every 14 group, we grade those groups on their Safety Culture, 15 their readiness to move forward. And they would go through 16 this question list on a group basis.
17 Additionally, we look and make sure that we feel the 18 whole plant staff, at the end of the meeting, we sit around 19 the table and go through those questions again. Thats 20 where we sit down and grade each of the areas as a total.
21 For example, suppose we have a manning problem in 22 one group, which we did. But as a site, do we think we 23 have a manning problem, were working excessive hours or 24 something. So, we analyze that and then grade that 25 particular area based on what all weve heard.
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99 1 The other thing we do is we look at several key 2 programs. For now, weve looked at the groups; what are 3 the key programs? Some of the programs we went through are 4 Corrective Action Program, whats it tell us; the 5 Management Observation Program, the Radiological Control 6 Program, the Reactor Coolant System Leakage Program and the 7 Employee Concerns Program, which is, what does the Employee 8 Concerns Program tell us now? Are our people willing to 9 bring issues forward?
10 Also, from an engineering standpoint, lets talk 11 about the systems we need for, for fuel load. We actually 12 bring the System Engineers in and go through the systems 13 and let them convince us that their system is ready to 14 support fuel load. And out of that we found a lot of 15 interesting things. Also, at the end of the meeting then, 16 were ready to grade the overall assessment of Safety 17 Culture, if you will.
18 Now, as we do that, what weve done, is the way 19 weve done that at this meeting, we took each individual 20 group and we graded either green, white, yellow or red.
21 You can read the definitions, I wont read each one.
22 To be green, all major areas are acceptable with a 23 few minor deviations. From a white standpoint, all the 24 major areas are acceptable with a few indicators requiring 25 management attention. Then, you get down in the red area, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
100 1 and you would say its just not acceptable. We have to 2 take immediate management attention. So, thats sort of 3 the grading process we went through.
4 Next slide.
5 Once again, what I tried to do here is to indicate 6 that we just dont take one, one issue like, all the 7 groups, do they feel like they have the right man. What we 8 try to do is take our performance indicators, went and 9 looked at our backlogs, we looked at our risk indicators, 10 our management observation programs. What are they telling 11 us?
12 For instance, we went through our management 13 observations. We could tell that we had a high number of 14 management observations requiring coaching, more than we 15 typically see at our other plant.
16 We looked at how weve demonstrated our performance 17 during recent plant critical evolutions. For example, one 18 of the things we looked at in this issue was when we filled 19 the reactor cavity for the first time. Then, feedback from 20 our Independent Safety Culture Review Process, which is --
21 and Quality Assessments; they also provide us some input.
22 And, then Doctor Haber will look at that process too. How 23 do we need to use that process to help strengthen the one 24 we have in place.
25 Now, let me go through what we found. You go look MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
101 1 at the way we graded ourselves for fuel load, and it sort 2 of makes sense; from a policy level of commitment that area 3 is graded white. From a management area commitment the 4 grade is white. And then, from an individual commitment, 5 we graded it yellow.
6 Now, whats interesting there is, this is a 7 management model once again. Its used to help us monitor 8 our standards, their implementation, and allow us to take 9 corrective action to assure that we are in line with our 10 employees.
11 Its not to say that our employees are yellow.
12 Okay? So, but we think there is areas that we need to go 13 focus on.
14 Let me go down to the policy level area. In that 15 area, we graded the management value structures as yellow.
16 Why did we do that? Well, when we go around and ask our 17 employees and survey about our, we dont get a consistent 18 reply from our employees when we talk about mission, 19 vision, our values; we dont quite feel like theyre 20 clearly understood, even though we got them out there and 21 everything else; were not where we want to be.
22 We have worked on our business plan to ensure that 23 we really focused our business plan on safety now, but we 24 havent wrote our business plan out to our employees. So, 25 that was a hit that we took there from the policy level.
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102 1 Then, we categorized the management value structure 2 as yellow. And once again, its just we dont get a 3 consistent message. That was the area that we made yellow 4 under policy levels.
5 Now, if you move on up into the management area of 6 commitment, thats where you talk about the management 7 staff at the plant. If you go look at the acceptance of 8 responsibility, responsibilities commitment was classified 9 as yellow in that area.
10 You know, one of the things we looked at there is 11 our appraisal process. We then have these new competencies 12 that weve installed and were going through our appraisal 13 process now. We wont finish it until next month. So, 14 because we havent finished it, we classified ourselves as 15 yellow. Thats only one of about 50 questions. But 16 because we have not finished it, we classified ourselves as 17 yellow.
18 And, there is a large number of management 19 observations, once again, that I mentioned awhile ago, 20 larger than what I want to see, thats requiring coaching.
21 So, those two issues cause us to classify that, that 22 indicator as yellow.
23 If you move up in the individual area, we talked 24 about a drive for excellence. We classified that as 25 yellow. We have a number of systems that still have MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
103 1 performance problems, you know. Theyre classified as A-1 2 systems, if you will. Now, each and every one of those 3 have a plan to get them off the A-1 plan before startup, 4 but we havent had them implemented yet. So, because we 5 havent had them implemented we classified that as yellow.
6 Then, there is a large number of issues thats 7 facing us from a corrective action standpoint. There is 8 about three thousand issues facing us right now. Thats a 9 lot, and we know thats a big battle. So, we classified 10 that as yellow.
11 Then, the number of Condition Reports in the 12 engineering area, we actually classified that as red, 13 because there is just answers, there is questions that you 14 mentioned a while ago, that we just dont have the answer 15 to right now. We made that red.
16 So, the overall area, the overall commitment was 17 classified as yellow.
18 Now, under rigorous work control, we also classified 19 that as yellow. The reason we classified that as yellow 20 is, as we fill the reactor cavity, thats, this is only one 21 example, but we didnt have a contingency plan in place to 22 go look for leakage. You know, and we thought that should 23 have been there. Then, once we got into the reactor cavity 24 issue, we didnt pull the decision-making knob out and use 25 it as effectively as we should have initially. It took us MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
104 1 several hours to do that. So, based on that performance, 2 we classified that area as yellow also.
3 Then under nuclear professionalism, once again, 4 were taking a double hit here, but we havent finished our 5 ownership for excellence evaluations, and weve had several 6 minor radiation protection CRs written, issues that we 7 found recently. I think you all know some of those where 8 the people didnt, they worked in areas maybe they 9 shouldnt have, but those issues that we came up with 10 there, we thought were enough to classify the nuclear 11 professionalism area also as yellow.
12 So, if you look at us overall, we said, were ready 13 to load fuel. There is some actions we want to go take.
14 Weve already taken some of those actions.
15 But in the policy area, the overall area was white.
16 Management area we classified as white. And then the 17 individual commitment area was yellow; individual 18 commitment areas.
19 MS. LIPA: Let me ask you a 20 question before we go on. Im looking at slide 33 with the 21 definitions and trying to make sure I understand. If we 22 use the individuals commitment area, for example, there 23 are five attributes that fit into that. Your definition 24 page, it would say yellow, all major areas are acceptable 25 with several indicators requiring management attention.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
105 1 Whats an area and whats an indicator?
2 MR. MYERS: The area would be 3 the individual commitment area, and then those indicators 4 are the various blocks on the righthand side, which are --
5 so there is a commitment area and then individual 6 commitments.
7 MS. LIPA: So, the page 33 8 then, when it defines yellow, its talking about all three 9 major areas, you only have three major areas.
10 MR. MYERS: Thats correct.
11 MS. LIPA: Okay. Thank you.
12 Oh, let me do a time check too, real quick, because 13 its about 4:36, and we wanted to finish the presentation 14 part by around 5. So, that will help you plan the rest of 15 your discussions.
16 MR. MYERS: Were right on 17 target.
18 In summary, this is a pretty new concept. We think 19 this concept is pretty unique. Weve never seen anybody as 20 a management team spending days trying to evaluate their 21 Safety Culture. I think its pretty state-of-the-art, you 22 know, the process that we went through.
23 The Safety Culture assessment is innovative, in that 24 we think its, once again, its under refinement. You 25 know, we think gave us good messages. Provides a fair MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
106 1 assessment of our status. I think some of your guys said 2 in our meeting, it was fairly, it was very, very 3 objective.
4 It contains areas that are both qualitative and 5 quantitative for us to measure. We can go measure rework.
6 We can go measure performance in the field. We can measure 7 items rejected. But, you know, things that are hard to 8 measure, or a little harder to measure is, do our employees 9 understand and believe in our value system. You have to do 10 that by ad hoc surveys and stuff, and just questioning our 11 abilities. And, we found it to be a useful tool for us to 12 focus on, to go take management actions that we need to, to 13 correct the behaviors.
14 We think the assessment is a fair representation of 15 where were at right now and our results show it. For 16 that, I thank you.
17 Steve.
18 MR. GROBE: Before you go 19 on, Lew.
20 MR. MYERS: I knew I wouldnt 21 get by with that.
22 MR. GROBE: The question I 23 asked earlier, is this assessment process written down in a 24 station procedure policy, so that we can take a look at it 25 at the NRC?
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107 1 MR. MYERS: Were doing that, 2 as we said, were turning it into a business policy, 3 business guideline. It will be, you know how we do 4 readiness restart reviews, were adding to that process, 5 then were adding to our business plan, and it will be an 6 area we assess every month in our business plan.
7 MR. GROBE: When do you think 8 it will be in a final company document?
9 MR. MYERS: I believe before 10 the next meeting.
11 MR. GROBE: Okay, the sooner 12 the better.
13 MR. MYERS: Its going to be 14 very soon.
15 MR. GROBE: Okay.
16 MR. MENDIOLA: I have a simple 17 question. You indicated each group was interviewed for the 18 readiness to load fuel I guess individually. I would 19 assume then that each group has their own Safety Culture 20 Assessment chart, if you would, at a group level.
21 MR. MYERS: What they have is 22 a group of questions that they answered. Then, as they 23 came in, we challenged them on those questions.
24 MR. MENDIOLA: I would assume 25 that the answers, their answers to each of those, I think MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
108 1 you said 50 questions, right?
2 MR. MYERS: I dont know.
3 MR. MENDIOLA: Would be, if you 4 will, pulled into each of these individual elements and 5 then into each of the individual commitments. So, I would 6 assume there would be a culture assessment on a group 7 basis, at a group level, that would then roll up into this 8 final overall culture assessment.
9 MR. MYERS: I think the 10 answer, I dont know if the answer to that is exactly yes 11 or not, but close to it. They came in with their charts 12 filled out. And, to be real on he is with you, there were 13 some people that came in and called things red, but after a 14 lot of discussion, they were made yellow. There were some 15 things people brought in they said were green, and by the 16 time we got through with them, they ended up being yellow.
17 There were a lot of areas -- Ive got the complete 18 list here with me. There is a lot of individual areas that 19 we classified as red, as a matter of fact, and some areas 20 yellow. If you want to look at the overall results of the 21 report, the questions we asked and everything else; what we 22 do is, we took good notes for the entire meeting. We can 23 share that with you.
24 I think the answer to your question is overall yes, 25 but Im not sure that we evaluated each and every area on a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
109 1 Safety Culture standpoint.
2 MR. MENDIOLA: Okay, the interest 3 in feedback obviously, that each individual group, if you 4 will, has their grades, so to speak, their self-assessment 5 policies.
6 MR. MYERS: Yes.
7 MR. MENDIOLA: And they take them 8 back to see, to improve themselves.
9 MR. MYERS: If it requires 10 management attention; for instance, there was one area, one 11 group, that the overtime was in question right now. So, 12 weve already met with that group, and gave some direction 13 on where we want to see them reduce the overtime. So, a 14 lot of things, were already beginning to take action on 15 those things. So, each group, youre right, walked away 16 with feedback and actions.
17 MR. MENDIOLA: Okay, thank you.
18 MR. MYERS: Okay. Steve.
19 MR. LOEHLEIN: Thank you, Lew.
20 Ill try to be brief.
21 As you know, on the NRC Nuclear Quality Assessment, 22 or NQA, its our job to find problems, basically to find 23 the problems that no one else in the organization has, and 24 get them corrected. Its also our job, our value really is 25 measured in the types of things we can find. If we cant MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
110 1 or dont find issues of value, then we cant be effective 2 in improving the safety performance of the plant. So, 3 thats our mission.
4 What Im going to share with you today are some 5 examples of activities that we do that really fall into two 6 simple categories; one is observations. Now, on 7 observations this is where we are trying to ensure that 8 actions and decisions that are being made are appropriate.
9 And if theyre not, then we intervene if necessary to 10 ensure the proper outcome. Examples of this would be 11 participating in meeting settings, review boards, 12 briefings, that sort of thing.
13 We also have the audit and assessment portion of our 14 activities, which deals with measuring against the standard 15 or acceptance criteria for a plant activity. And in those 16 cases, we provide feedback, usually via conditional reports 17 and audit records.
18 So, what Ive done is Ive separated slides into 19 three parts, results from recent activities on the first 20 slide that Ill go through, then the other two deal with 21 ongoing assessments, and the last one for our plans for the 22 future here, near future.
23 So, theres a number of items listed there. Ill 24 try to pick some of the high points. First, fuel spacer 25 grid damage and the associated stop work. Im sure the NRC MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
111 1 is aware of the stop work that NQA imposed on us a few 2 months ago on the movement of fuel.
3 Randy Fast talked to you about different types of 4 grid strap damage that was being found. That had occurred 5 in the past. Corrective actions had been taken, which when 6 found new damage now, NQA was not satisfied that we had in 7 place the necessary controls to make sure we would not have 8 future damage, so thats why we imposed the stop work.
9 There was ultimately a formal Root Cause Evaluation 10 done. And we have, we are satisfied here in the last few 11 days that the compensatory measures and corrective actions 12 necessary to make fuel movement safe was achieved.
13 I think that was a case, one of the cases where NQA 14 didnt have to, thought they needed to impose stop work 15 authority.
16 Restart Station Review Board Decision-making. This 17 is an interesting area. Its a meeting that we observed 18 with quite a bit of regularity, because this team, this 19 review board team is evaluating which activities or which 20 Condition Reports and Corrective Actions need to be 21 performed prior to restart versus post restart.
22 So, naturally NQA, our main vision is to make sure 23 that the decisions made there are made conservative. But, 24 while in the process of observing that, or any activity, 25 sometimes we find issues in related areas. And in one, in MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
112 1 a case that were looking at, one of these review boards, 2 the Restart Station Review Board, came to light that one of 3 the Condition Reports that had been evaluated for post 4 restart was done on the basis that an issue, the only issue 5 that might be restarted was going to be handled on a 6 different Condition Report.
7 Well, under the charter of the Restart Station 8 Review Board, they dont question whether that translation 9 actually happens. Its not part of their scope. In a 10 particular case, we found that that transference of that 11 issue to the other Condition Report had not actually 12 occurred. So, we identified that on a Condition Report and 13 aligned the evaluation to make sure we dont have more 14 cases of that type of situation.
15 In other related type of looks, we found a few cases 16 where Work Orders were deferred to post outage; whereas, 17 the Corrective Actions that were associated were still 18 properly shown as prerestart. So, the organization had not 19 lost track of the item from a Corrective Action standpoint.
20 There was this concern that perhaps something could, would 21 be found in the way a work order had been retargeted post 22 restart. This again, we identified on a Condition Report 23 and underlined as to looking to what that means in terms of 24 scope and we will monitor that.
25 Since we are on a time bind, there is a number of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
113 1 them up there, I think theres a couple of key ones. If 2 you have any questions on any of those in particular, 3 please say so; otherwise, Ill move on to some of the 4 ongoing things were doing.
5 On the next slide, there is a list of the things 6 that I have both past assessment activities and things 7 were doing right now.
8 In the System Health Readiness Review, thats an 9 area thats been discussed at some length here. We know 10 from past meetings with you, with the NRC and others here, 11 that we had done five independent reviews of systems 12 ourselves, and to do a comparison.
13 We had concluded that the System Health Readiness 14 Reviews were successfully done. We did find some 15 differences, and overall in that whole process, I had 16 written about 60 Condition Reports identifying the 17 differences in other enhancements that we at NQA 18 recommended. None of those resulted in us identifying a 19 significant condition or that we felt that the process had 20 not worked properly.
21 Program Reviews is ongoing right now, because we 22 have, in a similar fashion, we performed six independent 23 program reviews, and were right now gathering our delta 24 comparison on these programs, what we found compared to 25 what the line found.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
114 1 The Program areas are the In-service Test Program, 2 The TEP ODP, which is the Test Equipment Procurement 3 Operability Determinations Process, Reliability Program, 4 and Classification Process, which takes a look at how the 5 organization decides whether something is or is not a 6 safety related item, either materials area or in the work 7 function area. And, were compiling our data right now and 8 well be initiating Condition Reports as appropriate for 9 that.
10 We also reviewed six Phase I Reviews, or we observed 11 six Phase I Reviews and looked at five Phase II Reviews 12 that were performed by the line.
13 Another area here thats ongoing is the area thats 14 probably of interest is Safety Culture and Safety Conscious 15 Work Environment and Independent Survey. What we did in QA 16 is we just last week completed a ten percent survey of the 17 plant staff, face-to-face interview style survey.
18 Now, were still digesting what all those results 19 are telling us, but I thought I would share with you some 20 of the initial impressions of the results.
21 First, in all the interviews we conducted, none of 22 the individuals stated that they had personally experienced 23 retaliation in response to identifying a concern. We had 24 all but one individual indicate that they would personally 25 use the Corrective Action Program to identify concerns as MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
115 1 their first, thats the first place they would go.
2 After those two items, the next few bullets I have 3 for you have to do with their perceptions. A lot of these 4 questions we asked them, and we have this in Safety 5 Conscious Work Environment, is really about how do they 6 feel about what they hear, and you know, even if they have 7 not been personally involved in a situation.
8 Over 95 percent of the sampling told us that they 9 believe that management wants employees to report 10 problems. About 90 percent did not feel that the 11 possibility -- Im sorry. Im trying to characterize this 12 right.
13 The way we asked the question was, had they heard of 14 issues with retaliation. They themselves had already told 15 us they didnt experience. We asked them, do you believe 16 retaliation is a possibility or an issue that youve heard 17 of in the last three months, was not properly dealt with.
18 From that perspective, there were 90 percent of those 19 people identified that they felt this concern had been 20 properly addressed. Ten percent of them felt they had 21 heard something somewhere that it had not gone right.
22 And about 80 percent felt that the identified 23 concerns had been completely and effectively resolved.
24 So, these numbers, we think, are improvements over 25 the numbers that Bill Pearce had presented some months MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
116 1 back, but its the kind of thing were continuing to look 2 at. These are just our early, the early data weve got 3 based on what we completed late last week.
4 MS. LIPA: Steve, was that 5 ten percent a random ten percent? I might have missed that 6 part?
7 MR. LOEHLEIN: Yeah, the way we 8 actually did it, Christine, is we took the organization 9 chart of supervisors and below, so no one above supervisor 10 was included in the sampling. Then, we went through the 11 Org. charts and picked up, like every so many we picked a 12 name, whoever that happened to be, and thats how we 13 established the randomness of it.
14 MS. LIPA: Thank you.
15 MR. LOEHLEIN: Are there any more 16 questions on the examples I put up here?
17 In terms of upcoming observations which are on the 18 next slide, probably a good one to mention was the fuel 19 movement activities. Assume that the plant conditions 20 support fuel movement. That will be the next really 21 important thing for QA to observe.
22 And we will be providing coverage on every shift to 23 look at fuel movement activities. And, were real 24 interested in things like the preevolution briefs, command 25 and control in the field, and proper application of the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
117 1 compensatory measures that are being taken to prevent fuel 2 damage.
3 Another important one that is taking place now is 4 radiation protection activities, because now the plant will 5 be moving fuel. Well have changes in RWP Requirements, 6 Radiation Worker Requirements, and that sort of thing.
7 We have already taken a look at the high red areas 8 and having all those, were properly established.
9 MR. PASSEHL: Just a question.
10 How do you, or whats your mechanism for capturing your 11 observations in writing? Do you submit reports or?
12 MR. LOEHLEIN: Yeah, we had a 13 data base known as the QFO, Quality Field Observation.
14 Its a data base thats really not too dissimilar from what 15 the management team uses for management observations to 16 capture what we see in observations there. But, of course, 17 it doesnt mean that we also dont have Condition Reports, 18 quite of number of them actually, in areas that we write as 19 we do observations and assessments. Thats where we 20 capture all our information and we share with line 21 management and they result in the basis for our quarterly 22 audits.
23 MR. PASSEHL: So, I guess, do 24 you roll up your observations, say Program Reviews, System 25 Health Readiness Reviews with a separate assessment report; MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
118 1 or, it sounds like you dont do that?
2 MR. LOEHLEIN: Well, we, in terms 3 of, its probably going to depend on what youre talking 4 about. On System Health Readiness Reviews, we have talked 5 about how we are going to do rollups when that whole 6 process is completed, but in the interim were using our 7 Continuous Assessment Process, the parts of it that fit our 8 Standard Master Assessment Plan, as we call it, get 9 reported as part of the quarterly assessment. But youre 10 right, there are some areas like that, that we are planning 11 to write individual reports on the results at the end.
12 MR. PASSEHL: I see. And have 13 you mapped out your assessment activities beyond fuel 14 movement?
15 MR. LOEHLEIN: Well, what we do 16 most of our, we have a plan we set up, we produce a 17 quarterly assessment plan. And the whole thing is we have 18 a number of things that we see or look at periodically.
19 And what we do is we look ahead to what the stations 20 schedule of activities is planned to be.
21 We look for those areas that, you know, key areas of 22 perhaps vulnerability in terms of safety and that sort of 23 thing, and we ensure that those elements and attributes 24 that apply to those kinds of activities are included in our 25 plans for that quarter. Thats how we do it.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
119 1 MR. PASSEHL: Okay, thank you.
2 MR. LOEHLEIN: I think the 3 Resident receives a copy of our Quarterly Assessment Plan 4 to share them with you. If you need a copy, we can get you 5 one.
6 Overall, I think I would like to make a concluding 7 statement really about how we feel at NQA in what were 8 seeing, and that is overall were observing a lot of good 9 performances in many areas, but we continue to provide the 10 feedback thats necessary to ensure that improvements and 11 corrections are made when appropriate.
12 MR. GROBE: Thanks, Steve. I 13 appreciate that briefing. I actually have a question for 14 Bill Pearce, and I was wondering if you might come up. I 15 saw you back there.
16 One of the changes in the organizational structure, 17 one of the Corrective Actions for the Root Cause was to 18 separate Quality Assessment from the Line Organization at 19 the site. You have a very unique reporting relationship in 20 that new structure. You report both to the President of 21 FirstEnergy as well as to the Nuclear Subcommittee Board of 22 Directors.
23 I was wondering if you could talk a little bit about 24 what sort of interface you have with the President of 25 FirstEnergy, and the Subcommittee of the Board.
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120 1 (Off the record.)
2 MR. MYERS: Can I ask a 3 question real quick? Right now, I think, the charts are on 4 the wall for the schedule part. I feel comfortable 5 deleting that.
6 MR. GROBE: That would be 7 great.
8 MR. MYERS: Okay.
9 MR. PEARCE: First part about 10 meeting with the President, I actually talked with Bob 11 Damon on the telephone, and we talked about whats going on 12 at the three sites, and how I perceive it. And of course, 13 we talked to the line organization also.
14 If I see something, and Ive had several times where 15 I did, where I called Bob about something that I saw going 16 on, to give him what I thought was a different perspective 17 of what were doing, and provide some information or 18 insight into what I think is going on. So, I think that 19 demonstrates some amount of independence.
20 And I pretty well watch, I spent most of my time at 21 Davis-Besse, and the majority of my time; and both working 22 with the Quality Assurance Organization and Employee 23 Concern Program, in trying to assess, get some feel of how 24 things are going, and where the Quality Assurance Program 25 may need some assistance or help.
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121 1 In fact, every day when Im there, which is like I 2 said about 90 percent of the time, I go down in the 3 mornings and get some update on what theyre doing, what 4 theyre seeing, you know, what theyre interaction with the 5 staff is, and how theyre feeling about things.
6 So, I guess thats really what Im doing, Jack.
7 In regard to the Nuclear Committee of the Board, 8 they meet monthly. I meet with them monthly, as does the 9 Line Organization. And, I try to give some independent 10 view as to, from a safety perspective of where were going, 11 not just how were doing it, you know, getting work done, 12 or how were doing in the outage, but from a safety 13 perspective; focus on issues that are relevant to, like 14 fuel integrity, RCS integrity, containment integrity, 15 health of the safety systems and provide some insight from 16 a safety perspective to the board, to the different 17 committees of the board.
18 So, thats some independence I think I provided.
19 Other than the Line Organization, they of course give their 20 reports and I give mine. And they dont always match 21 exactly, but at least the Line, I think they know what the 22 issues that I have are.
23 MR. GROBE: Could you just 24 give one example of a situation where you had a differing 25 perspective than what the Line Organization had on a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
122 1 specific activity?
2 MR. PEARCE: Sure. I just 3 gave, I think the last time I think it was, the Line 4 reported about what was going on at Beaver Valley on the 5 steam generators. And, I had some concern whether, whether 6 the Nuclear Committee of the Board fully appreciated the 7 condition of the steam generators at Beaver Valley. So, I 8 tried to give some definition, technical definition of 9 that, that they could understand, and to make them 10 understand where we were.
11 Its, I think thats something, that level in the 12 organization needs to understand, that they need to support 13 what were doing over there with those generators.
14 MR. GROBE: Okay. Let me 15 just characterize what I think I understood you to say.
16 You provided some additional context from your perspective, 17 so that there would be a complete understanding of the 18 situation in that one example. Is that correct?
19 MR. PEARCE: Thats correct. I 20 can give you some other examples, if you let me think of 21 them.
22 MR. GROBE: No, I just wanted 23 one, just to make sure I understood.
24 MR. PEARCE: Right.
25 MR. GROBE: Okay, thanks.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
123 1 MR. PEARCE: Youre welcome.
2 MR. GROBE: Any other 3 questions?
4 At this point, Lew, do you have any closing remarks 5 that you want to give?
6 MR. MYERS: Yes, I do. I 7 would like to take a moment for that.
8 You know, backing up, before I get started, I can 9 tell you there has been times from a schedule standpoint 10 and all, that Bill give, or cost standpoint, that Bill give 11 the board a different perspective than I did. Im always 12 giving the most aggressive perspective. So, I know theres 13 been some differences there. So, I can assure you, hes 14 brutally honest from his perspective. There is another 15 example.
16 In closing, you know, I want to talk about fuel 17 movement. Were not, were not going to move fuel until 18 were comfortable with the clearance of the vessel. That 19 may take longer than we expect, especially if we wind up 20 having to review internals or something, but well do that 21 if we need to.
22 Were sitting here today. We looked at the tapes 23 before we came here. Were going to work it for the next 24 twelve hours or so, but were looking at other options 25 also. So, fuel movement is eminent and we feel like were MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
124 1 very ready for that when the time comes.
2 Containment testing will be completed in early 3 March. Were looking forward to that. We already have the 4 air compressors lined up, good owner of the program, and we 5 feel of that project, feel like were closing in on being 6 ready to pressurize that containment.
7 System reviews showed good, good progress. We dont 8 have all the questions answered. We know that. But weve 9 got them in our data base, and we have people working on 10 all of them. So, were pleased with the progress we made 11 there so far.
12 The one thing, I think it served us well that we 13 havent, we talked a lot about, is Safety Culture 14 evaluation, that the Readiness Restart Review for fuel load 15 that we did. We identified over a 170 issues that we took 16 on as a management team before fuel load. One of them was 17 to ensure that we wanted to have the other decay heat train 18 functional. And that wasnt a requirement. We thought it 19 gave us added value. So, weve got both decay heat trains 20 available.
21 Additionally, once again, we think that serves us 22 well. We think that Safety Culture did serve us well.
23 Eventually, I have a prepared statement though that I 24 wanted to provide you. And Ill do that now. I prepared 25 this today.
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125 1 At our January 30th meeting with NRC in Lisle, 2 Illinois, we reported that we had recently, it was reported 3 that we had recently been informed that several persons 4 have been subject to retaliation for raising safety 5 concerns at Davis-Besse.
6 The person claimed that within the past two weeks at 7 least two employees who have raised safety concerns to 8 their immediate supervisors or stopped work for safety 9 reasons received letters of reprimand, verbal threats of 10 harm by co-workers and/or experienced damage to their 11 personal property while on site, specifically that tires 12 were slashed.
13 When I got back, I requested our attorney to contact 14 the individual, and obtain a more, obtain more specifically 15 information, so that we could perform a meaningful 16 investigation of these allegations. Our attorney called 17 the individual on two occasions and left detailed messages 18 requesting information. Neither call was returned.
19 We conducted a review of our records and concluded 20 the allegations most likely corresponded to two separate 21 events that we know of. One occurred more than six months 22 ago, and the other within the last month. Our 23 investigation of both events did not substantiate 24 retaliation to raising safety concerns.
25 We are in the progress on actions for the second MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
126 1 event. Management received, management received the 2 discipline for the employee in question and has retracted 3 the issue at the time of the meeting on January the 30th.
4 This issue had to do with the practice at Davis-Besse of 5 employees leaving early without supervisor notification, 6 not a safety issue.
7 Our message is clear. Bring us the allegation.
8 Well address that. We can not solve problems unless we 9 have all the relevant information. We all share the 10 responsibility to maintain a Safety Conscious Work 11 Environment at Davis-Besse. Im firmly committed to that.
12 We encourage interested members of the public to 13 share in that responsibility with us. I thank you very 14 much.
15 MR. GROBE: Okay. Thanks, 16 Lew.
17 I think what well do right now is just move right 18 into the question and answer session without taking a 19 break. That way well get folks to dinner at a reasonable 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, if thats okay. Christine and I will just step down 21 in front.
22 MS. LIPA: What we would 23 like to do is have everybody sign in and state your name 24 clearly. Just make sure we have a sheet up here.
25 Sign in, state your name clearly for the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
127 1 transcriber, and then were really going to keep people to 2 3 to 5 minutes. This is one of the feedbacks that weve 3 gotten in the past is we havent kept people to the time 4 limit. So, were going to be policing that a little bit 5 better this time.
6 MR. GROBE: Before we get 7 started, I just wanted to make two observations. One was 8 we also received a lot of feedback regarding the quality of 9 our sound system. I think this is an improvement. I think 10 that the microphones have been working much better than 11 they have in the past.
12 If you do have feedback though, we are continuing to 13 respond. We have made several revisions to the sound 14 system in the last couple of months, and this one seems to 15 be effective. So, I want to thank the folks here at Camp 16 Perry for this sound system.
17 I also wanted to comment on an action that the 18 Agency took today that some of you may have heard about.
19 In the continuing Agency response with all pressurized 20 water reactors in the United States, the Agency has issued 21 orders to each operating pressurized water reactor in the 22 United States, specifying NRC expectations for future 23 examinations of reactor head penetrations.
24 After the discovery of the situation at Davis-Besse, 25 actually preceded Davis-Besse, the Agency had initiated a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
128 1 number of what we call generic activities; thats 2 activities that affect more than one Licensee. The 3 inspections that Davis-Besse was doing during the outage in 4 February of 2002 was in response to an NRC bulletin 5 requesting certain examinations and inspections of head 6 penetrations.
7 After Davis-Besse, that continued. There were two 8 more bulletins issued. And, just today there were orders 9 issued to every operating PWR in the United States. So, 10 those are activities that really have little to do with 11 what were doing here; that is, assessing Davis-Besses 12 progress toward approaching restart, but I just wanted to 13 make sure everybody was aware of that.
14 So, are there any, I think first local officials 15 that have a question or a comment?
16 Okay, are there any members of the local area around 17 the plant that have a question? Quiet, satisfied group or 18 a very hungry group; one or the other.
19 Okay, are there any other members of the public that 20 have a question or comment?
21 Excellent.
22 MR. RIDZON: Paul Ridzon with 23 McDonald Investors.
24 Jack, at the close of every meeting, you always give 25 an overview of the meeting, and your take on progress MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
129 1 made. Thats what I always thought was the valuable part 2 of the meetings. I wonder if you could provide that to us 3 now.
4 MR. GROBE: I was afraid you 5 were going to say a benediction.
6 I think my perspective and the panels perspective 7 hasnt changed over the last several months; that the plant 8 continues to make progress in running their Return to 9 Service Plan. We continue to have inspections and our 10 inspections have not disclosed any significant issues in 11 their activities.
12 Last month was a busy month. The meeting on January 13 30th was very meaningful. FirstEnergy has clearly 14 articulated their plans for assessing Safety Culture, going 15 forward, and the proof is in the pudding, of course. We 16 need to see those plans fleshed out in paper, so that we 17 can understand them and evaluate them; and then we need to 18 see them implemented. So, progress is being made, and I 19 think its being made on every front.
20 MR. RIDZON: Could you give a 21 sense as to what level of implementation is required for 22 restart? Obviously, you cant get a hundred percent of the 23 way, I guess Sonya at one point said that it takes three 24 years for this to kick in. I expect were not going to --
25 MR. GROBE: Oh, I understand MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
130 1 your question. Let me articulate it to make sure I 2 understand it. Your question has to do with the level of 3 Safety Culture that is necessary for restart.
4 What were waiting for is for FirstEnergys 5 definition, so we can clearly understand the threshold that 6 theyve set. In broad terms, the threshold is that none of 7 their areas of performance will be in the red category.
8 Theyve established colored categories for their 9 performance. We need to see whats behind that. What goes 10 into those assessments.
11 Lew presented in broad terms the assessment they did 12 for fuel loading. Again, we need to see the details thats 13 behind that before we can make a judgment as to whether or 14 not we agree with their assessment scheme; and well do 15 that as soon as they have it for us.
16 MR. RIDZON: Thank you.
17 MR. GROBE: Hello, Amy.
18 MS. RYDER: How are you?
19 My name is Amy Ryder. Im with Ohio Citizen 20 Action.
21 I have a question about this infamous red photo that 22 was taken back in April of 2000. Apparently, this was 23 reported in the Cleveland Plain Dealer, that a Condition 24 Report was written about this photo in April of 2000; was 25 given to a FirstEnergy supervisor, and then was turned over MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
131 1 to an NRC inspector. Now that its clear that both the NRC 2 and FirstEnergy knew that the condition of the reactor 3 was -- or that it was corroding, that there was a 4 significant amount of rust; does the NRC still stand by its 5 decision that they should not have issued the immediate 6 shutdown order?
7 MR. GROBE: Im not sure --
8 MS. RYDER: Your agency --
9 MR. GROBE: Im not sure what 10 your question is, but let me step back and make sure that I 11 understand it.
12 The photograph youre talking about is the one that 13 showed rust materials coming out of the, what are called 14 weep holes on the side of the reactor vessel.
15 First, to the best of my knowledge, the NRC did not 16 see that photograph until the Augmented Inspection Team 17 received that photograph as part of the background 18 information that they reviewed. That was in March and 19 April, early April of 2002.
20 This specific question is under review within the 21 NRC, and I dont know the results of that review, but I 22 think the second question that you asked was whether were 23 revisiting the issue of issuing -- or not issuing an order 24 near the end of 2001. And I think the Chairman fairly 25 clearly articulated the agencys position on that in his MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
132 1 letter to the Inspector General in response to the 2 Inspector Generals investigation of that matter.
3 So, I dont have anything more to add beyond what 4 the Chairman stated.
5 MS. RYDER: My understanding 6 was that Condition Report was turned over to an NRC 7 inspector long before April of 2002.
8 MR. GROBE: That was 9 information that I believe the Union of Concerned 10 Scientists put out and I dont know what the foundation of 11 that is, and its under review. To the best of my 12 knowledge, the first time we saw that photograph was March, 13 middle of March, between the middle of March of 2002 and 14 the first week in April of 2002.
15 MS. RYDER: So, their 16 information is wrong?
17 MR. GROBE: Thats, to my 18 understanding it is. Thats correct, but its under 19 review, and Im not part of that review. So, its being 20 looked at.
21 MS. RYDER: Okay.
22 MR. GROBE: Other questions?
23 Okay, very good. I guess the rest of you are 24 waiting for our meeting at 7:00 this evening, when were 25 going to have a general public meeting and receive MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
133 1 questions and comments from the public at that time.
2 Thank you very much.
3 (Off the record.)
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134 1 CERTIFICATE 2 I, Marie B. Fresch, Registered Merit Reporter and 3 Notary Public in and for the State of Ohio, duly 4 commissioned and qualified therein, do hereby certify that 5 the foregoing is a true and correct transcript of the 6 proceedings as taken by me and that I was present during 7 all of said proceedings.
8 IN WITNESS WHEREOF, I have hereunto set my hand and 9 affixed my seal of office at Norwalk, Ohio, on this 21st 10 day of February, 2003.
11 12 13 14 Marie B. Fresch, RMR 15 NOTARY PUBLIC, STATE OF OHIO 16 My Commission Expires 10-9-03.
17 18 19 20 21 22 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO