ML031830791
| ML031830791 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/03/2003 |
| From: | NRC/RGN-III |
| To: | |
| References | |
| Download: ML031830791 (129) | |
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1 1
2 PUBLIC MEETING Between U. S. Nuclear Regulatory Commission O350 Panel 3 and FirstEnergy Nuclear Operating Company 4
Meeting held on Tuesday, June 3, 2003, at 5 2:00 p.m. at the Camp Perry Clubhouse, Oak Harbor, Ohio, taken by me, Marie B. Fresch, Registered Merit Reporter, 6 and Notary Public in and for the State of Ohio.
7 ---
8 PANEL MEMBERS PRESENT:
9 U. S. NUCLEAR REGULATORY COMMISSION 10 John "Jack" Grobe, Chairman, MC 0350 Panel William Ruland, 11 Vice Chairman, MC 0350 Panel Christine Lipa, Projects Branch Chief 12 Christopher Scott Thomas, Senior Resident Inspector 13 U.S. NRC Office - Davis-Besse Jon Hopkins, Project Manager Davis-Besse 14 Jack Rutkowski, NRC Resident Inspector 15 FIRST ENERGY NUCLEAR OPERATING COMPANY 16 Lew Myers, FENOC Chief Operating Officer Michael J. Stevens, 17 Director - Nuclear Maintenance Mike Ross, Restart Director 18 Mark Bezilla, Vice President Davis-Besse James J. Powers, III 19 Director- Nuclear Engineering Robert W. Schrauder 20 Director - Support Services Steven Loehlein, 21 Manager - Quality Assessment Clark Price, Owner - Restart Action Plan 22 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
2 1 MS. LIPA: Were ready to 2 begin then. Okay.
3 Good afternoon. Welcome to FirstEnergy and members 4 of the public for accommodating this meeting today. This 5 is a public meeting between the NRCs Davis-Besse Oversight 6 Panel, and thats us over here, and FirstEnergy Nuclear 7 Operating Company.
8 Im Christine Lipa, and Im the Branch Chief in 9 Region III, and Im responsible for the NRCs Inspection 10 Program at Davis-Besse.
11 The next slide covers the purposes of this meeting, 12 which are to allow FirstEnergy to present the status of 13 activities in their Restart Plan; and then also well be 14 discussing some NRC Oversight Panel activities, focusing on 15 those activities since our last public meeting that was 16 held in May.
17 We have the agenda here. These are the items well 18 be covering today. And, before we get going too far, I 19 would like to make some introductions.
20 On the far left is Jon Hopkins, and Jon is the NRR 21 Project Manager for the Davis-Besse facility.
22 Next to John is Bill Ruland, and Bill is the Senior 23 Manager in NRR in Rockville, Maryland and hes also the 24 Vice Chairman of the Oversight Panel. And Bills actual 25 position is Director for Project Directorate Three in the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
3 1 Division of Licensing Project Management.
2 On my left is Jack Grobe. Jack is a Senior Manager 3 in the Region III Office in Lisle, Illinois, and hes the 4 Chairman of the Davis-Besse Oversight Panel.
5 And then to my right is Scott Thomas, the Senior 6 Resident Inspector here at Davis-Besse facility.
7 Also, we have Jack Rutkowski, the Resident 8 Inspector, whos operating the slides for us today.
9 And Nancy Keller was greeting folks on the way in, 10 in the foyer.
11 And Viktoria Mitlyng is our Public Affairs Officer.
12 There is Viktoria.
13 And we also have Rolland Lickus, our State Affairs 14 Officer. Great.
15 And then, Lew, if you would like to introduce the 16 folks on your table.
17 MR. MYERS: Sure. To my left 18 we have Steve Loehlein. Steve is the Manager of our 19 Quality Assurance Group.
20 Mark Bezilla is next to me on my right. Mark is in 21 charge of, hes the site VP at our site. Jim Powers in 22 charge of Design Engineering.
23 Mike Ross, next to him, is our Restart Director at 24 the present time.
25 Bob Schrauder next to him. Bob is Support Manager.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
4 1 Mike Stevens.
2 Down at the end is -- Clark Price is down at the 3 end. Okay. Hes going to give the management performance 4 indicators for us today.
5 MS. LIPA: Okay, great.
6 Thank you.
7 Are there any public officials or representatives of 8 public officials in the audience?
9 MR. KOEBEL: Carl Koebel, 10 Ottawa County Commissioner.
11 MR. PAPCUN: John Papcun, 12 Ottawa County Commissioner.
13 MR. WITT: Jere Witt, Ottawa 14 County Administrator.
15 MS. LIPA: Okay. Thank you.
16 Okay. So, this meeting today is open to public 17 observation. I dont know if Im having trouble with my 18 mike; does it sound like I am?
19 Okay, how does that sound? All right, excuse me.
20 Okay. So, as I was trying to say, this meeting is 21 open to public observation. This is a business meeting 22 between the Nuclear Regulatory Commission and FirstEnergy, 23 but at the conclusion of the business portion of this 24 meeting, but before the meeting is adjourned, we will have 25 opportunity for public questions and comments.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
5 1 In the foyer on your way in today, there were copies 2 of our June edition of our monthly newsletter, and also 3 copies of the slides for the NRC presentation and the 4 Utilitys presentation.
5 One of the good things about the newsletter, it 6 provides good background information and current status 7 information and also has contact reference information for 8 our public affairs folks in the region, email address and 9 phone numbers, if you want to contact them for more 10 information.
11 We also on the Internet have a web page right on the 12 NRC web page, a whole web page dedicated to Davis-Besse.
13 And we also in the foyer had public meeting feedback forms 14 that you can use to provide comments on todays meeting.
15 Today were having this meeting transcribed by Marie 16 Fresch. And that will maintain a record of todays 17 meeting, and those transcripts are also available on our 18 web page several weeks after each meeting.
19 MR. GROBE: Christine, before 20 you go on, just quickly. One of the things thats a little 21 different about the June newsletter is it includes a little 22 bit of background information on our Resident Staff at the 23 site. The reason we did that, Scott has been around a 24 little while, but weve got two new Residents.
25 Jack Rutkowski is new and we introduced him last MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
6 1 month, but also joining us, we just selected an additional 2 Resident Inspector for the Davis-Besse facility. Her name 3 is Monica Salter-Williams, and shell actually be moving 4 out to the site in September.
5 Shes finishing up some work in our Region I Office 6 right now. And, when she gets here, well certainly 7 introduce her to everybody, but there is a little bit of 8 background information on the staff.
9 Normally, we only have two Resident Inspectors at 10 each of the nuclear power plants in the United States.
11 Weve added a third Resident at Davis-Besse to provide 12 additional oversight during the next couple of years.
13 MS. LIPA: Thank you, Jack.
14 Okay, so the next slide is a summary of the May 6 15 public meeting that was held here last month. And during 16 that meeting we provided a status update on the NRCs 17 ongoing inspections. And we also discussed some upcoming 18 activities, and the public meetings, that we held a public 19 meeting in May to discuss engineering issues. And later in 20 todays presentation, well give an update on some recently 21 completed and ongoing NRC activities.
22 Also last month, FirstEnergy provided an update on 23 their efforts towards restart and they discussed some 24 management changes and some other topics that are listed on 25 the slide.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
7 1 So, I would like to go on to the next one, which 2 covers significant NRC activities since that May meeting.
3 We did issue on May 29th, the Final Significance 4 Determination, which is a red finding regarding the vessel 5 head degradation. And we had issued a Preliminary Risk 6 Significance in February. And then last week we finalized 7 it with the final letter.
8 Also in May, we completed most of our program 9 inspection, and closed several Restart Checklist items.
10 Weve now closed 11 of the 29 items on the Restart 11 Checklist. And there were four Restart Checklist items 12 closed through that programs inspection, and those are 13 listed on the next two slides.
14 Go on to the next one.
15 Also, since the May 6 meeting, we did hold a public 16 meeting in the Region III Office on May 7, and that was to 17 discuss a number of engineering and design issues that 18 Davis-Besse management is working to resolve.
19 Continuing NRC activities. These are some 20 inspections that we have that are ongoing. The System 21 Health Readiness Review Inspection includes safety function 22 validation of systems and some topical issues, which are 23 like high energy line break, environmental qualification, 24 seismic issues. And this inspection is being conducted by 25 several inspectors and is nearing completion.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
8 1 The next one is inspection into the area of Safety 2 Culture, Safety Conscious Work Environment. The focus 3 there is to evaluate the Licensees process and the tools 4 for monitoring the improvement in Safety Culture and Safety 5 Conscious Work Environment and the effectiveness of the 6 Employee Concerns Program.
7 Another inspection is the Corrective Action Team 8 Inspection. This is an inspection to review the 9 effectiveness of the corrective action process at 10 Davis-Besse to ensure that its effectively implemented and 11 appropriate corrective actions are being taken to prevent 12 recurrence of problems.
13 And then the Resident Inspection, Jack talked about 14 the Resident Inspectors. There are two full-time Resident 15 Inspectors and theyre permanently stationed and they 16 inspect a broad spectrum of activities, such as Operations, 17 Maintenance and Testing. And the Resident Inspector 18 Reports come out every 6 to 7 weeks.
19 Some other upcoming NRC activities. We do plan to 20 conduct an inspection of the lower reactor vessel head 21 area, and this will be as the Utility is prepared to go 22 into Mode 4. Well be following that test. And the 23 inspection will review the procedures and the related ASA 24 codes, requirements relative to that leak test on the 25 Reactor Coolant System and well also observe parts of the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
9 1 test and verify proper implementation at those procedures.
2 Were also planning to conduct a public meeting to 3 discuss the Licensees assessment of their Safety Culture 4 work. Once they have fully integrated their independent 5 and internal assessments. And right now were looking 6 around July for that meeting.
7 One of the other activities the NRC plans to do is a 8 backlog, an assessment of the backlog of issues. And this 9 will really depend on as Davis-Besse approaches restart, 10 what work items theyve deferred to do after restart. And 11 well be doing an inspection to take a look at those.
12 The NRC is also preparing to conduct a Restart 13 Assessment Team Inspection, when Davis-Besse nears the 14 point where it will seek NRC authorization for restart.
15 That inspection will review the readiness of the plant and 16 the plant staff to resume plant operations safely and in 17 compliance with NRC requirements. The inspection findings 18 will be considered by the NRC Oversight Panel in making its 19 recommendation to the Regional Administrator on possible 20 restart.
21 The next item. There have been several LERs that 22 have been issued. Those are Licensee Event Reports. So, 23 there are specific conditions that were identified by the 24 Utility or by the NRC that need to be corrected. A part of 25 our process, we also review the past significance and past MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
10 1 enforcement and the causes and make sure those issues are 2 properly corrected.
3 Two other upcoming activities that I dont have on 4 the slide; we are planning a meeting on June 19th, in 5 Headquarters. And the purpose of that meeting will be to 6 discuss the high pressure injection pump modification. We 7 will have that video conferenced in Region III, and also 8 bridge lines available for people who want to call in to 9 listen to that meeting.
10 Also I want to mention that next months meeting 11 will be July 9th, and were planning to have it at the Oak 12 Harbor High School.
13 So, that summarizes the NRC activities since our 14 last meeting. And the inspections that I discussed are 15 part of our Restart Checklist Item, which is our listing of 16 issues that need to be resolved prior to restart of the 17 plant.
18 With that, Ill turn it over to FirstEnergy for your 19 portion of the presentation.
20 MR. MYERS: Thank you, 21 Christine.
22 One of the people that I didnt get a chance to 23 introduce is Bob Saunders; he is with us today; the 24 President of the FirstEnergy Nuclear Operating Company, in 25 the audience with his wife, Carol.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
11 1 Weve had a pretty interesting month this month.
2 Made some changes and some decisions that change the flow 3 path of our schedule. Well talk about that today.
4 Our desired outcome today is to update you on the 5 plant performance, some of the tests weve run, where the 6 plant is at now, some of the management human performance 7 progress weve made since the last meeting, to provide you 8 some information, concerns, and decisions on the high head 9 safety injection pump.
10 Weve made decisions on the, which as you remember, 11 were going down two flow paths; one is replacement, one is 12 modification. There were some real advantages to the 13 modification option. We made that decision, moving forward 14 now. So, were down to one path that were focused on.
15 To provide you with an update on the quality 16 oversight, Steve is next to me, and hell do that today.
17 Hell give their independent perspective on some of the 18 issues we have, and provide you a status of several of the 19 engineering issues and how theyre moving along. And we 20 think theyre making good progress at the present time.
21 Then, finally, to status you on our overall 22 schedule. Weve made some changes there when we decided to 23 take the flow path on the modification, high head safety 24 injection pump, fits into the critical path, flow path.
25 So, we made some changes there. Additionally, then MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
12 1 provide some information on the performance indicators that 2 we monitor to focus toward restart.
3 I introduced the members at our table today. Mark 4 Bezilla will status you on the plant. Ill give you some 5 information on the Management and Human Performance 6 update. Specifically, our Electrical Distribution and 7 Safety Injection Relays is Jim Powers. Bob Schrauder is 8 with us. Hell talk to you about that High Pressure Safety 9 Injection Pump and the Corrective Action Program. And 10 Steve Loehlein, Independent Assessment.
11 The remaining issues, we really got a good list of 12 all the issues and the status of those issues and Mike Ross 13 has really been focused on that. He will provide you some 14 of that information. And if time permits, well look at 15 the Schedule Milestones and the Restart Performance 16 Indicators. If it doesnt, we have those back on the 17 board.
18 With that, Ill turn it over to Mark Bezilla, so he 19 can talk about plant status.
20 MR. BEZILLA: Thank you, Lew.
21 I would like to brief you on where we are with 22 regards to our Reactor Coolant System Pressure Testing and 23 our efforts to complete work in Containment.
24 My desired outcomes; demonstrate our increased 25 confidence in Reactor Coolant System and its support MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
13 1 systems and provide an update on containment activities.
2 Next slide.
3 We completed the 50 pound pressure test of the 4 Reactor Coolant System on May 6. We inspected 5 approximately 1100 components, connections, items, 6 including the reactor vessel closure head; its an O-ring 7 area, the CRDM flanges and the reactor vessel bottom head.
8 No leakage was noted from the reactor vessel closure 9 head, the O-ring area, the CRDM flanges, or the reactor 10 vessel bottom head. We did identify 54 items that required 11 additional attention. And, this could range from a repack, 12 to a tighten packing to a clean and continue to observe.
13 We completed the 250 pound test on May 25th. Again, 14 we inspected those 1100, approximately 1100 components, 15 connections, et cetera. And this time we identified 26 16 items that required additional attention. There were six 17 active leaks; three of those were packing leaks, and the 18 other three were reactor coolant pump seal package 19 temperature elements.
20 Two valves of note, are decay heat valve number 11 21 and number 12. These valves are the first two valves off 22 of the Reactor Coolant System to the Decay Heat Removal 23 System. They had very small accumulations of Boron at the 24 body to bonnet gasket, and were currently evaluating the 25 best course of action for those valves and to address that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
14 1 small accumulation of boric acid.
2 There were 8 recurrent indications of Boron and 3 these will also be appropriately dispositioned prior to 4 Mode 4. And those were clean, inspect, and take a look and 5 we saw some recurrence there. So, thats where you get the 6 recurrent items.
7 I believe that these two pressure tests, the 50 8 pound test and the 250 pound test, have set us up well for 9 our first operating pressure, normal operating pressure and 10 near normal operating temperature milestone.
11 MR. GROBE: Mark, do you 12 know on DH 11 and 12, do you know what the cause of the 13 body to bonnet leakage is on those valves?
14 MR. BEZILLA: Jack, we suspect 15 that thats a gasket leakage. It may just be because the 16 valve is cold at this point, and as we heat up, that may 17 help seal that body to bonnet leak. I believe our approach 18 will be to clean. These are the two valves in our decay 19 heat tank -- decay heat tank, decay heat valve tank, and do 20 the first normal operating pressure, normal operating 21 temperature test, then reopen the tank and take a look and 22 see what those valves look like. We may also do some 23 torque checks and/or additional torquing of body to bonnet 24 holes.
25 I have a picture with me, Jack, in case you hadnt MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
15 1 seen it or you were interested, but this is, its tough to 2 see from there. This is a blow-up and you can see, its 3 about a quarter teaspoon of boric acid is what, the volume 4 were talking about, quantity were talking about. Ill 5 share this with you on a break.
6 MR. GROBE: Okay, thank you.
7 MR. BEZILLA: A few more notable 8 items or items of interest. We determined that in the 9 decay heat removal circulation homing mode, that is where 10 we have the decay heat circulating reactor coolant and with 11 the cooling bypass. So, we were cooling the decay heat, if 12 you will, the decay heat reactor coolant circulation, if 13 you will.
14 We can only get up to, close to 140 degrees for exit 15 thermal couple temperatures, and only to about 130 degrees 16 bulk reactor coolant temperature. The only note there is 17 we have no decay heat in the existing core. Okay.
18 We placed the makeup and purification system in 19 service. That was our normal makeup letdown seal 20 injection. We did find a few items there that will need 21 remediation, but all in all thats just a perform well.
22 We exercised and operated the pressurizer heaters 23 and pressurizer spray valve. We drew a bubble, so we 24 heated the pressurizer up to 400 degrees using those tools, 25 if you will, those items. And again, those performed very MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
16 1 well also.
2 And, we ran each reactor coolant pump. Those are 3 the biggest motors we have in the plant. And we ran each 4 one of them separately and then ran them in combination 5 from anywhere from 30 minutes to a couple of hours. Again, 6 that gave us confidence in that big piece of equipment, if 7 you will, or those four big pieces of equipment.
8 So, in summary Ill say, we gained additional 9 confidence in the performance of Reactor Coolant System and 10 its support systems.
11 Any questions?
12 MR. GROBE: Yeah, I want to 13 go back to DH 11 and 12. Have you gone back through the 14 mechanical work packages to identify whether there is 15 anything that sticks out on reassembling those valves?
16 MR. BEZILLA: I did not 17 personally, Jack, but I had my guys take a look, and we 18 didnt do anything with the body to bonnet. We did repack 19 the valves this outage, but we did not do anything with the 20 body to bonnet.
21 MR. GROBE: Okay. Thank you.
22 MR. HOPKINS: Mark, I have a 23 question. You mentioned three temperature elements for the 24 reactor coolant pumps. Were all of those elements on the 25 two reactor coolant pumps that you did work on?
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
17 1 MR. MYERS: We replaced the 2 seals on all four reactor coolant pumps.
3 MR. HOPKINS: I thought you did 4 more work on two than all four.
5 MR. MYERS: We did. We 6 changed the rotating assembly on two. The thermal couple 7 with the leaks on it are on the seal packages. We replaced 8 all four of those.
9 MR. HOPKINS: Okay.
10 MR. BEZILLA: Jon, I believe it 11 was three of the pumps, if Im correct. And as Lew said, 12 we touched all four of the reactor coolant pump seals.
13 What was interesting was, they were leaking prior to the 14 pump runs; and then after the pump, reactor coolant pump 15 runs, I couldnt find any leakage.
16 I went and checked those myself, and I looked at the 17 four pumps and then after we had ran the pumps, and I 18 couldnt see any leakage. So, I dont know if that was 19 because we had staged a seal and there was less pressure 20 available to those sensors. But in any case, we have to 21 disposition those, and I believe there is going to be some 22 rework on those elements.
23 MR. HOPKINS: Okay, thank you.
24 MR. THOMAS: One 25 clarification. It may be of some benefit if you describe MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
18 1 the temperature relationships between pressurizer 2 temperature, RCS temperature, during the 250 pound test.
3 MR. BEZILLA: During the 250 4 pound test, bulk temperature was from, if I remember 5 correctly, was somewhere in the 140, or actually 140 to 160 6 range, and overall reactor coolant system pressure was 7 around 250 to 260 pounds. But the pressurizer, because we 8 wanted a steam bubble was up over 400, I believe 400 9 degrees, to give us the steam bubble to have the 250 pounds 10 in the system. So, that piece of the system was hotter 11 than the bulk cooling temperature in the rest of the 12 system.
13 MR. THOMAS: And the initial 14 conditions for the latest HPI test required you to heat up 15 in excess of 140 degrees and you did that.
16 MR. BEZILLA: We did that. We 17 heated up -- Scotts referring to the high pressure 18 injection pump testing that we just completed. We heated 19 up to about 180 degrees and we did that with the reactor 20 coolant pumps.
21 Reactor coolant pumps are big motors, big pumps, and 22 they cause rotational energy to be imparted into the 23 coolant, and we can heat up the coolant using the reactor 24 coolant pumps.
25 Okay, next slide.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
19 1 Now, I would like to provide you a brief update on 2 our containment activities. First, let me provide an 3 update on our containment health activities. In regard to 4 the discovery action plans; 14 of 24 of those are complete 5 and remaining 10 are in our internal review process.
6 I talked to Tim Chambers just before coming over 7 here and he believes that those will be finished either 8 late this week or early next week. So, we should have all 9 of those completed by next week.
10 In regard to our Implementation Action Plans, there 11 is 16 of those. Four of those are complete. Six are in 12 our internal review process. One is in draft form; that 13 has to do with containment air cooler motor replacement.
14 And five are awaiting field work to complete, so we can 15 complete those packages. So, Ill say progress is being 16 made in those Implementation Action Plans.
17 Now, let me talk a minute about the containment 18 work. I think weve made good progress on containment 19 work. We have a few items to complete to get us to the 20 point where we can put the equipment hatch on, which is 21 effectively, Ill say, containment closure.
22 And those items consist of reconciling 250 pound 23 test deficiencies or issues that we noted. Containment air 24 cooler flow balancing, and there is some final strut and 25 support work that weve got to finish up on the service MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
20 1 water pipe associated with those CACs.
2 Completion of a few containment health items. The 3 seal along the basement wall, and then demobilization of 4 containment, removal of tool, toolboxes, scaffold, things 5 of that nature, and then Ill say final cleaning of the 6 containment in general. Weve been cleaning, but need to 7 get the stuff out and then do the final cleaning and check 8 of containment.
9 Installation of containment equipment hatch is an 10 important activity for us. It signifies that the plant is 11 near ready for that first normal operating pressure, near 12 normal operating temperature evolution.
13 And, additionally, once we finish in containment, 14 our daily exposure number is going to drop. Well have our 15 people in, Ill say, lower radiation areas not in 16 containment, so I think that will help us from a personal 17 dose standpoint also.
18 I believe we can be ready for installation of 19 containment equipment hatch and containment closure within 20 the next few weeks and I think its very doable.
21 Once we install the containment equipment hatch, our 22 Containment Health Project Manager, Tim Chambers, is going 23 to conduct a turnover, Ill say, of ownership of 24 containment to Mike Roder, our Operations Manager, and his 25 staff. And, Ops will again own the containment. I think MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
21 1 thats a good thing.
2 In conclusion, containment activities are 3 proceeding, and we should have the containment in a 4 condition to support closure by putting the equipment hatch 5 on and having ownership turned over from that Containment 6 Health Project Manager to my Operations Manager within the 7 next few weeks.
8 Any questions?
9 MR. THOMAS: Just for 10 clarification, for when you say containment closure, thats 11 the turnover to Operations; its not the final closeout of 12 containment; correct?
13 MR. BEZILLA: Thats correct, 14 Scott. Thats putting the hatch on, and Ill say having 15 Operations take control and minimize the number of people 16 in there, the activities are ongoing in containment.
17 Okay, if there is no more questions, Ill turn it 18 over to Lew.
19 MR. MYERS: Thank you.
20 Lets take a couple moments and reflect back on some 21 of the actions weve taken on Management/Human Performance 22 Plan, and then look forward. Our desired outcomes, 23 discussed those with the actions weve taken to-date, and 24 then some of the, in the next couple months, we have really 25 got a focused effort that well be applying on the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
22 1 Management Human Performance Plan.
2 Then we talk about going forward. Going forward is 3 the plan for the remainder of this year. Then we have a, 4 as part of that, we develop a long term strategy, a long 5 term plan, that well be signing off in the near future for 6 the continuous improvement of the Management/Human 7 Performance issues to assure that everything is sustained.
8 The Management/Human Performance Building Block 9 consists of actions we have taken to ensure that our team 10 is built to last, if you will; and are the result, as you 11 recall, the Management Root Cause Report that we sent you, 12 the Engineering, Operations and Company Nuclear Review 13 Board Function Assessments, the Corporate Oversight 14 Assessment, the Independent Safety Culture Assessment, and 15 the Quality Oversight Assessments that we performed, and 16 the actions out of those.
17 Actions that we have taken to-date consist of the 18 FENOC corporate organization has been strengthened, and we 19 think strengthened significantly with the addition of the 20 Chief Operating Officer position, the Executive VP of 21 Engineering, and the VP of Oversight, which reports 22 directly to our President, and actually reports on the 23 dotted line to our nuclear -- Nuclear Board.
24 Davis-Besse, the Davis-Besse team now we think has 25 been strengthened significantly. There is probably more MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
23 1 actions that well take there in the near future. For 2 example, we have Mark over here. Im pleased to have him 3 here as the Site Vice President. The senior team was 4 strengthened last year, we took prompt actions there.
5 Weve also been working on the management team to ensure we 6 have proven leadership there.
7 Additionally, the Independent Quality Organization 8 now reports, once again through a VP position, to the 9 President of FENOC, the Board.
10 Weve included several barriers, that if you go look 11 at those barriers, I believe that we put these barriers in 12 place, and the term I like to use, weve anchored them into 13 our processes. And, I think that several of these barriers 14 that we have up here may have actually prevented the 15 reactor head event from occurring.
16 For example, the Engineering Review Board and 17 Corrective Action Review Boards are both key barriers that 18 we have in place now, that weve anchored in place, that we 19 think will strengthen our organization in the future.
20 Next slide, please.
21 Additionally, the Company Nuclear Safety Review 22 Board is a high level board of executives thats 23 independent, and theyre designed to provide independent 24 feedback to the FENOC President. Weve strengthened that 25 board, not only from a member standpoint, but from a MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
24 1 process standpoint. So, it is strictly focused now and 2 focused very well on nuclear safety issues.
3 Weve improved the rigor and the classification of 4 our corrective actions. And I think were doing, well 5 demonstrate in a few moments that classifications now we 6 think are very conservative.
7 And also the quality of our root causes, cause 8 analysis that we use in the Corrective Action Program.
9 Terms we use; apparent cause and root cause. Well, root 10 cause is a very thorough analysis.
11 Weve also strengthened our Management Observation 12 Program, and weve discussed some of the things were 13 seeing out of that program now, and its made me proud.
14 Next slide.
15 If you go look at our Employee Concerns Program, I 16 believe in our 4-Cs Meetings and our feedback were 17 getting, were now getting good feedback from our employees 18 on the confidentiality of the program and also the 19 effectiveness.
20 Theyve actually went out of their way a couple 21 times in meetings with me to compliment us on the 22 effectiveness of how were taking on issues.
23 Weve increased the rigor in our calculations. The 24 standardization of our problem-solving approach. Once 25 again, I think the problem-solving approach, which were MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
25 1 using daily, I think Scott sees us using that. It might 2 have been one of those new programs that are in place now, 3 that have a lot of rigor and a good team. Asking tough 4 questions, we may have discovered the reactor vessel head 5 issue more quickly.
6 So, with that program, problem-solving approach, we 7 think is a good program, and similar to what we use at our 8 other plants.
9 Weve initiated the, several employee communications 10 committees; for instance, the 4-Cs we think is here to 11 stay. Mark is going to take that over as we move forward.
12 The Town Hall Meetings and All-Hands Meetings are typical 13 things that we use at our other plants.
14 Section specific improvement initiatives also have 15 taken place in Engineering and Health Physics. And we 16 developed several performance indicators. And group 17 performance indicators, were working on now, if you walk 18 around our plant, have various groups in Maintenance, HP 19 and Chemistry. You see individual department performance 20 indicators. And in some of the main areas, you see the 21 overall performance indicators of the status of the plant.
22 We think getting down to those groups; our mechanics 23 understand what their backlogs are, and the material 24 condition of the plant is going to be very important to us 25 and increasing standards going forward.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
26 1 I would like to take a moment just to look back and 2 think for a moment about the definition of the term that we 3 came up with. And, you know, if youd asked me a year ago 4 to define Safety Culture, I dont think that, that I could 5 have very well. As well as I can now.
6 And, I could have gave you a definition, but often 7 we would describe Safety Conscious Work Environment for 8 Safety Culture. I heard everyone do that.
9 So, if you look, we have definition now as "That 10 assembly of characteristics and attitudes", so its 11 characteristics and attitudes that effect peoples 12 behavior, "in the organization and individuals which 13 establishes an overriding priority towards nuclear safety 14 activities and that these issues receive the attention 15 warranted by their significance."
16 So, what that means is, every day as we do our work 17 in our power plant, are the safety-related activities 18 totally articulated and are they receiving the attention 19 they want by both supervision and management.
20 If you look at the Safety Conscious Work 21 Environment. We define that as "That part of the Safety 22 Culture addressing employee willingness to raise issues and 23 managements response to those issues."
24 You know, the key term back then you use there, no 25 such thing as a bad question. Its important that we take MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
27 1 every concern seriously. And I think were, ROP met 2 yesterday, and were getting pretty good feedback, and 3 weve made substantial progress in that area. I think its 4 an area that you never arrive in, sort of like the tag-out 5 process, that youre always keep trying.
6 If you go look forward on the next slide, we have a 7 pretty -- reason I threw this slide up here, Im not going 8 to go over issue there. Ill talk about some of them, but 9 we have a very intense plan laid out for the remainder of 10 the year. We keep adding things to it.
11 If you go look, in May and June, we have some 12 procedures were changing, our work management procedures, 13 so that each work activity is classified as high, low, 14 medium risk from a safety standpoint.
15 This week, were taking Thursday, Friday, and 16 Saturday and the senior team, myself and Mark are going off 17 and laying out our strategies for the remainder of the 18 year.
19 And, as you see, weve got a lot of activities lined 20 out for between now and start-up, and then for the 21 remainder of this year. So, then well have plans in place 22 for, that well develop through this for next year.
23 So, its not only are we working on the plant, but 24 these three day activities with managers and supervisors 25 and all of our employees, are very time consuming, but its MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
28 1 something we need to do, were taking seriously.
2 Next slide.
3 Let me provide you with some of those ideas. Our 4 work management process requires management involvement 5 based on risk. You know, at our other two plants, we have 6 a procedure in place, and we bring that over here. Where 7 depending on the system youre working on, look at that 8 system, and then we evaluate the, are you being intrusive, 9 are you just looking, what are you doing to the system.
10 And, if youre working on the plant protection system or 11 something like that, may cause a reactor risk; you would 12 rate that as high to moderate risk. We give that more 13 management attention and more, based on the risk 14 significance.
15 And so, were going to anchor that process at our 16 Davis-Besse plant. So, well have that approved in the 17 near future.
18 From an alignment activity, facilitated site 19 alignment; we leadership development, department/section 20 activities, and All-Hands Meetings scheduled for the rest 21 of this year.
22 The Senior Management Team, for example, like I 23 said, Mark and myself, well spend the next three days 24 developing our short term transition plan for plant 25 startup. You know, were getting ready at that point now, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
29 1 that were talking about Mode 4 in the near future, and 2 when we go into Mode 4, thats a pretty significant 3 transition. Well be heating up the plant, putting steam 4 in our steam lines, testing all of our equipment. So, we 5 need to understand how we change our behaviors when we get 6 to Mode 4.
7 MR. THOMAS: Can we go back to 8 risk management just for a second?
9 MR. MYERS: Sure.
10 MR. THOMAS: How long do you 11 think the worker level, individual, what is their 12 understanding of protected trainings; what a yellow risk 13 condition is? Do you think there is a good recognition of 14 what that actually means, or?
15 MR. MYERS: Well, I know there 16 is. I dont think its internalized as well as it should 17 be, but Ive gone to some of the shop meetings. For 18 instance, I was in the services meeting a few weeks ago.
19 They talked about the color of the risk.
20 When you talk to the employees, they understand that 21 its there, but Im not sure, I think its an area we can 22 improve the level of knowledge on the behaviors associated 23 with that risk significance.
24 So, they recognize it, but not to the, they dont, I 25 dont think they internalize it as much as I would like.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
30 1 Does that make sense?
2 MR. THOMAS: And the efforts 3 that you just spoke about, will improve that?
4 MR. MYERS: Yes. Were 5 focused to improve that. One of the things well be doing, 6 Ill talk about that too, we plan on after we get --
7 looking ahead in my presentation. But after we have, were 8 going to have SMT Meetings we talked about. Then we have 9 three days with managers.
10 One of the things we need to focus on, we got 11 feedback from Sonja Habers report and also our independent 12 assessments, is the employees understanding what the 13 remainder of the year looks like and what are those 14 activities that we have after we start the plant up. And, 15 and whats important? What are those values and indicators 16 that are important to us on a group basis.
17 So, these stand-downs, these one-day meetings are 18 designed to develop a vision map of the short term and the 19 long term to make sure we have clear understanding of some 20 of our standards across the site.
21 We plan on having all 800, 900 employees sit down 22 for a whole day in groups of about 20-- 200 at a time, to 23 go over the vision maps and standards and everything with 24 the directors and managers. So, we think that will be a 25 good opportunity for us to go over dialogue, improve that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
31 1 standard.
2 MR. THOMAS: Okay.
3 MR. MYERS: I rambled a little 4 more on that question than I should have, but the answer is 5 yes, you know.
6 MR. THOMAS: Okay.
7 MR. MYERS: If you go lock look at, 8 you know, at the meetings well be having; well be 9 applying the Lessons Learned from the Root Cause Reports 10 and our Assessments. Well develop our Leadership 11 Strategies for Safety Culture going forward and then the 12 critical element, elements and issues on both the short 13 term and the long term that well continue to focus on as 14 we move forward.
15 We revisit our Safety Conscious Work Environment 16 Program with each and every employee and talk about the 17 changes weve made prior to taking the reactor critical, 18 thats what we find here as Mode 2. And well do that at 19 the All Site Meeting with our employees. So, we want to 20 reiterate the importance of Safety Conscious Work 21 Environment at that time.
22 Next slide.
23 Some other actions well have, is well continue on 24 organizational development activities, both in Engineering 25 and Maintenance. Maintenance is an area now that were MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
32 1 very focused on.
2 Well continue with our employee communication.
3 Were going to reinstate, if you will, our Weekly Managers 4 Meeting. About a year ago, we stopped having the weekly, 5 the daily management meeting, because we had the 6:30 6 meeting. So, as we move forward and as we transition to 7 more of an operational mode, as we move to Mode 4 and Mode 8 3, and focus on startup; we need to reestablish these 9 managers meetings, have the organizational structure put in 10 place and understand what that structure looks like.
11 I think its fair to say that we were not completely 12 pleased with the management meetings we had before. So, 13 that structure is going to be very important.
14 Were going to initiate our monthly departmental and 15 section meetings. Well continue that as we move forward, 16 and continue our monthly All Site Meetings for at least the 17 short term to ensure that we maintain good alignment with 18 our employees.
19 Then conduct a weekly Senior Management Team 20 Strategy Meetings. So as we, as the Senior Management 21 Team, I would like to say is, we always are looking for 22 changes or improvements as we sort of guide the ship down 23 the river, and course direction. So, the strategy meetings 24 every week were having now, we look for those course 25 changes; and well continue those.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
33 1 The next slide, if you will.
2 From a Safety Conscious Work Environment standpoint, 3 were going to continue to monitor our effectiveness. In 4 the third quarter, we plan on doing a survey. And then we 5 plan on continuing doing the surveys at least for the next 6 two years, and maybe longer as we see the need.
7 So, that Safety Conscious Work Environment Survey 8 also provided to you at previous meetings, we think it 9 gives us a very good benchmark from where were at; and if 10 we keep that consistent, we can monitor how were doing 11 going forward.
12 From a quality standpoint, quality has a survey that 13 they use also, and they performed their survey in the 14 fourth quarter, and then annually for the next couple of 15 years at least.
16 Then from a FENOC standpoint, we have our Safety 17 Culture Assessments that well be performing as part of 18 startup. I think yall guys have sat in on a couple of 19 those. We think, were sort of the leaders right now in 20 the industry from what Ive seen in our procedure for 21 monitoring safety culture. I think weve made some more 22 improvements there. Its a cursory process.
23 But well perform those activities prior to Mode 4.
24 Well have a Safety Culture Assessment for readiness.
25 Well perform another assessment prior to Mode 2, then for MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
34 1 subsequent outages in the future, at least for the next 2 year or two.
3 Then FENOC is working on a program going forward 4 where we continually monitor our safety assessment. Were 5 looking for, at group performance indicators that well use 6 in our corporate standpoint, well look at Safety Culture 7 as we move forward.
8 MR. RULAND: So, Lew, if I 9 understand, youre not going to come in at this stage to, 10 basically doing these surveys for the life of the plant; 11 youre going to reevaluate it sometime later. Have you 12 thought, maybe this is too far in advance, have you thought 13 about the criteria you would use to decide whether you 14 would continue those surveys or not?
15 MR. MYERS: What we really 16 plan on doing, if you look, we talked about Mode 4, Mode 2, 17 and then typically what I do is Restart Readiness Review 18 Meetings that we continue to do after every major outage.
19 But, what were doing at FENOC levels, were looking 20 for a group of performance indicators, and were working 21 that already where we use a FENOC level at all of our sites 22 to continuously monitor the Safety Culture.
23 MR. RULAND: So, the plan would 24 be to do that for the life of the plant?
25 MR. MYERS: The plan would be MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
35 1 to do that for the long term, yes. Life of the plant, you 2 know, is a long term.
3 MR. RULAND: Thank you.
4 MR. MYERS: I dont know if 5 Ill be alive that long.
6 MR. RULAND: Both of us at 7 least would be retired.
8 MR. MYERS: Yes. So, the 9 intention is to do it for the long term, yes.
10 And, that pretty well concludes everything that I 11 have. Any questions?
12 Next couple of months are going to be very busy from 13 a Management and Human Performance standpoint. Thank you.
14 MR. GROBE: Lew, you brought 15 up some interesting topics. One of the questions 16 identified by the Management/Human Performance Inspection 17 Team during their review of your internal Safety Culture 18 Assessment Tool, which you call Restart Readiness Review 19 Procedure, was the way in which you build up to your 20 colorization on that chart that youve shown us many times; 21 where you could have some poor performance in critical 22 areas that get averaged into some other performance in 23 maybe some less critical areas.
24 Have you analyzed that concern or question that they 25 raised and decided what action, if any, was necessary to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
36 1 address that?
2 MR. MYERS: Actually, Jack, 3 there was two questions. One yall guys raised, and the 4 other one they did.
5 Actually, the doctors that did the external 6 assessment for us, they dont like grading Safety Culture; 7 they just like general assertions. And yall guys tend to 8 like measurable devices.
9 Weve gone back and looked at, we took, I think, 10 with the survey we did, they call them characteristics or 11 behaviors or something. We did a very, very good 12 cross-functional check to make sure that we were covering 13 everything that they were in that assessment.
14 Then we went back and had some questions about, are 15 there some critical type areas, like if operations is red, 16 would you go forward. That term, term be the indicator red 17 in that area. And the answer to that, if you look at our 18 procedure, there is some subjectivity there, and we 19 clarified that procedure.
20 We think, the answer is yes, we think weve 21 addressed it, but you know, there is always management 22 subjectivity. And, you know, if we had operations red, we 23 would definitely consider that at a higher rating when it 24 came to overall rating than we would maybe, maybe some 25 other department, you know, like the procedures group, or MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
37 1 something, you know. Even though both of them are poor.
2 So, I think we have addressed those questions. And 3 we spent a, the Senior Team spent several hours going 4 through and resolving those questions a few weeks ago.
5 Okay?
6 MR. GROBE: So, there has 7 been a revision to the procedure or just how youre going 8 to apply it?
9 MR. MYERS: No, theres been a 10 revision to the procedure, clarified words, clarified some 11 sections, and then the overall objectives we probably tried 12 to clarify that also.
13 So, there is a revision procedure. I think we 14 signed it, do you remember, Jim, a couple weeks ago?
15 MR. POWERS: Last week.
16 MR. MYERS: Last week? That 17 seems like an eternity, maybe not.
18 MR. GROBE: Can you get a 19 copy of that revision to Scott and hell forward that on to 20 the Region?
21 MR. MYERS: I will be glad to 22 do that.
23 MR. GROBE: Just to be clear, 24 we were reviewing your procedure, its not what we want, 25 its the structure that you set up to assess your MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
38 1 organization, and we provided those comments to you, in 2 your procedure.
3 MR. MYERS: Right. We 4 certainly like things that are measurable; we tend to be 5 engineering type. And so, there is, there is things that 6 are objective and things that are subjective. And when you 7 get into these kinds of models, you do have some 8 subjectivity to them.
9 MR. GROBE: Okay. The 10 outcome of this, and the way that NRC approaches measuring 11 the effectiveness of an organization, we do it based on 12 performance. And then look, if there is performance 13 problems identified, look for the root cause of those 14 performance problems.
15 Youre creating a structure here thats going to be 16 approaching the front end of that organizationally to make 17 your organization effective, and of course youre also 18 looking at performance.
19 There is a couple of things that happened recently, 20 which I think may provide a springboard for discussion 21 items at our next meeting. One was a rather significant 22 operational configuration management problem, where you 23 were filling the circulating water system and there were 24 several valves that werent in the position that you 25 expected them to be in and ended up flooding condenser pits MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
39 1 in the facility.
2 Its significant from the standpoint that Operations 3 needs to know the condition of all their equipment at all 4 times; and in this case, they didnt.
5 I would be interested in a broader perspective, if 6 you have any thoughts on that issue today, that would be 7 good, but I would also next meeting be interested in the 8 broader perspective of Operations performance, what youve 9 seen, as more systems, Mark indicated possibly in the next 10 few weeks containment would be turned over to Operations.
11 So, I would be interested in a perspective of 12 Operations, what youve been learning, what youve been 13 seeing, not only the front end of the organizational 14 effectiveness, setting it up right, but the back end of 15 performance.
16 MR. MYERS: Why dont we give 17 you an operational review next meeting.
18 MR. GROBE: Okay. And I 19 think it was two meeting ago you talked about problems you 20 had seen in a Maintenance area, and you indicated again 21 today that you had been working in that area. It might be 22 a good time to, to look at Maintenances performance and 23 how youre grading that, how youre judging that, and what 24 youve learned.
25 MR. MYERS: Weve already MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
40 1 taken time. We reorganized some pretty strong actions that 2 we plat put the organization side; had some stand-downs with 3 employees. There is several jobs, I think just recently 4 done, Mike will discuss that later, but weve actually done 5 a fairly good job on.
6 But youre right, there is actions still to be taken 7 there. We have an improvement plan. Maintenance was not 8 something from a 350 standpoint or shutdown standpoint that 9 we spent a lot of time speaking with Engineering, 10 Operations and HP, and recently started focusing in the 11 Maintenance area.
12 Its not unusual when you start improving 13 performance in one group, you start seeing the other one 14 showing up. So, weve taken that on now, so we know 15 the plan.
16 MR. GROBE: I think there was 17 an interesting issue that just came up a day or two ago, 18 when you were disassembling the HPI pumps, the high 19 pressure injection pumps, and found some bolts, screws that 20 were broken. Had you identified were those overtorqued or 21 what caused that?
22 MR. MYERS: To my knowledge, 23 they were overtorqued.
24 MR. ROSS: Thats right.
25 MR. GROBE: So, that may have MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
41 1 been a Maintenance problem.
2 MR. MYERS: Yes.
3 MR. GROBE: Okay.
4 MR. BEZILLA: Jack, on that 5 issue, and Ive got one of my experts down here. I believe 6 we had overtorqued, it was skill of the craft. There was 7 no specifics in the procedure, and we now have specific 8 torque values for those bolts in the procedures. So, that 9 should not recur. So thats what I believe was the cause 10 of those broken bolts.
11 MR. GROBE: They are somewhat of a 12 unique design bolt. Okay.
13 The other thing, I spent some time with Jim Powers 14 this morning, and we were talking about Engineering. We 15 havent really touched broadly on Engineering quality in 16 awhile. It might be good next meeting to go over 17 Engineering in a broad context of all the things youve 18 learned over the last several months and where you see 19 Engineering.
20 MR. MYERS: We can do that.
21 So, we have Operations, Maintenance and Engineering.
22 MR. GROBE: That pretty much 23 covers it; doesnt it?
24 MR. MYERS: Pretty much covers 25 it.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
42 1 MR. GROBE: Okay.
2 MR. MYERS: With that, Ill 3 turn it over to Jim Powers. He will discuss Engineering 4 issues we have.
5 MR. POWERS: Okay, thank you, 6 Lew.
7 Two issues I would like to cover this afternoon, 8 concern our Electrical Distribution System and our Safety 9 Features Actuation System Relays. Weve touched on these 10 in past meetings and I want to do an update on where we 11 stand.
12 First of all on the electrical area, one of the 13 issues we had been evaluating concerned our emergency 14 diesel generators and their performance under a starting 15 transient and loading the safety electrical busses. We had 16 found during testing at the site that frequency and voltage 17 dips during those transients did not meet statements that 18 we had in our Updated Safety Analysis Report for the site, 19 which is our licensing basis.
20 And, based on that discovery, we instituted a study 21 to determine the significance of that, particularly on the 22 performance, not only the diesel generators, but all the 23 equipment that they supply on the emergency busses.
24 Going through a detailed evaluation, we prepared 25 what we refer to as an operability evaluation that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
43 1 documents the performance and evaluates it and provides to 2 the Operations staff the basis for the, for operability of 3 the emergency diesel generators.
4 We provided that on May 15, and they reviewed that 5 in detail and accepted it. And that allowed them a basis 6 to declare the diesels operable for all modes. It was a 7 successful outcome determination.
8 Some of the things weve got prior to plant startup 9 to do, is to -- yes, Christine, question?
10 MS. LIPA: Maybe youre going 11 to get to it, but based on the operability evaluation for 12 now, but your long term plan to restore it; is that what 13 youre getting to?
14 MR. POWERS: Well, the long 15 term plan is, to go down the bullets here, the first step 16 is to update our USAR to reflect the actual performance of 17 the engines. We have a draft USAR change in the process of 18 review right now to do that.
19 Then, as youll see in the last bullet on the page, 20 evaluating the actions to improve the engine performance.
21 And there is a couple of changes that could be possible to 22 improve that performance, but based on the current overall 23 performance of the engines and the equipment in the system, 24 they perform acceptably and are operable.
25 MR. GROBE: You indicated MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
44 1 that your diesel generators are now operable for all 2 modes. Are there any conditions on it? Have you resolved 3 the room temperature questions?
4 MR. POWERS: Good question, 5 Jack. The room temperature issue is one that weve made 6 big strides in as well. We had a, a technical team looking 7 at that issue. This is one where the, the engines, these 8 are very large diesel generator engines in rooms. And the 9 ventilation system has not been able to provide cooling to 10 maintain during summer outdoor temperatures, maintain the 11 room temperature to acceptable levels.
12 And weve evaluated the components in the room, the 13 electrical components largely that are sensitive to high 14 temperatures to determine that they were satisfactory up to 15 outdoor ambient temperatures of 95 degrees and have 16 submitted an operability evaluation for that particular 17 issue to Operations as well.
18 So, were continuing work in that area. Although, 19 weve completed that assessment, which provided operability 20 to 95 degree outdoor temperature, which positions us well 21 for this coming summer. There are three modifications 22 were pursuing in the rooms, and were continuing forward 23 to add margin to the plant.
24 And that, that is insulating the exhaust manifold 25 for the engines, providing ventilation to the electrical MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
45 1 cabinets that are in the room, and were also providing 2 large fans that we have retrieved from our Perry unit that 3 were originally intended for the unit two over there and 4 they were not utilized.
5 And we retrieved those, provided refurbishment of 6 them, and are planning a modification to install them at 7 Davis-Besse now. So, putting that equipment to good use to 8 improve margin in those.
9 MR. THOMAS: So, the 10 temperature issue is not going to require a USAR change; is 11 that correct?
12 MR. POWERS: The temperature 13 issue may require a USAR change as well, Scott, in terms of 14 the temperature in the room. The current temperature I 15 believe in the license basis is 120 degrees. And, 16 currently is 134 degrees, is what we evaluated for the 17 capability of the equipment in the room, so.
18 MR. THOMAS: Now, its my 19 understanding that the fans, once you installed the fans 20 that you would regain that margin; is that correct?
21 MR. POWERS: Thats correct, 22 the fans will provide a significant increase in cooling.
23 MR. THOMAS: But still may not 24 get you back down to 120?
25 MR. POWERS: Im not sure on MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
46 1 the detail, that will get us all the way back to 120 or 2 not. We dont have a complete analysis done on that yet, 3 but if they dont, then well have to change our license 4 basis to be consistent, Scott, with that.
5 MR. THOMAS: I understand. The 6 latest on installing the fans; is that post restart, 7 prerestart?
8 MR. MYERS: Post.
9 MR. THOMAS: Post restart 10 issue?
11 MR. POWERS: Right. Were 12 working to position ourselves to do it promptly, continuing 13 with engineering and procurement and planning for that, but 14 seems post restart.
15 MR. THOMAS: Cabinet 16 modifications and the exhaust insulation are prerestart?
17 MR. POWERS: Yes, they are.
18 Those design packages should be issued this week and work 19 commencing shortly thereafter.
20 MR. THOMAS: All right. Thank 21 you.
22 MR. GROBE: Jim, are there 23 any other limitations on this operability evaluation, 24 similar to this temperature limitation? It appears by this 25 spring that were never going to get to 95 degrees, but MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
47 1 its always possible. Are there any other limitations?
2 MR. POWERS: None that comes to 3 mind.
4 MR. GROBE: Okay, thank you.
5 Oh, one other question. You have "prepare and 6 issue USAR change". Whats the specific focus of that USAR 7 change and will that require NRR approval?
8 MR. POWERS: We do not believe 9 its going to require a license amendment and NRR approval 10 at this time, Jack, based on our review of the draft. The 11 specifics are, the USAR said that on the starting of the 12 diesel generators, the voltage would dip below 75 percent 13 of nominal voltage for several cycles. In fact, we found 14 from our testing analysis it would be longer than several 15 cycles, so were changing it to be specific to the results 16 of our analysis.
17 MR. GROBE: Okay.
18 MR. POWERS: Then Ill go 19 through our 5059 Process for changes to our license basis.
20 Okay, Ill move on to, with the Electrical 21 Distribution System, our AC Distribution System. Weve 22 been doing a very comprehensive analysis, or reanalysis, 23 using Electrical Transient Analysis Program, ETAP 24 calculation. And our electrical engineering team has been 25 preparing the model of all the electrical system running MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
48 1 through the plant.
2 As you can imagine, this is a very complex model.
3 It takes the large transmission lines that you see outside 4 the plant with offsite power in the plant through large 5 transformers, progressively smaller transformers. The 6 voltage is reduced and distributed to the various equipment 7 at various voltage levels down to 120 volts AC, which is 8 your common power for small items.
9 The analysis is intended to demonstrate under all 10 conditions the electrical system can provide adequate 11 voltage.
12 Weve gotten our initial analysis results last week.
13 And, this involved a number of different plant alignments 14 and cases of equipment loadings, whether its on or off and 15 given plant mode as weve gone through that analysis. And, 16 were currently evaluating the results of that now, so some 17 impacts on plant equipment.
18 What were finding is that there is a certain mode, 19 unusual lineup of plant transformers that can result in low 20 voltage under a certain set of conditions, which is high 21 summer temperatures with all the equipment running to its 22 duty capability, off-site power coming in through one 23 startup transformer. And, running under that condition and 24 having an accident, with all the accident equipment loads 25 sequencing on the bus quickly, the voltage appears that it MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
49 1 is low in that condition, relative to our acceptance 2 criteria, based on our initial runs of the analysis.
3 What were doing this week to look at that in 4 detail, weve got an independent industry team here. Weve 5 got some individuals from the Institute of Nuclear Power 6 Operations, as well as peer electrical analysts from other 7 utility sites who have gone through similar analysis 8 projects here to critique what we are doing, and look at it 9 and give us any imput, critical input in terms of what 10 were doing, what we may be able to do better.
11 The bottom line on it, were evaluating the 12 conditions that were seeing from that initial runs of the 13 analysis with the, with those initial lineups to determine 14 actions necessary going forward, and that could be adding 15 some relays into some of the equipment in the plant to 16 assure that its not on the electrical system under this 17 set of conditions, and improve voltage on the distribution 18 system in that manner.
19 MS. LIPA: Jim, is there any 20 chance that this could result in a tech spec change, or, 21 because I know you have a definition of off-site, on and 22 off-site circuits.
23 MR. POWERS: Right.
24 MS. LIPA: Is that under 25 question here?
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
50 1 MR. POWERS: Thus far, we 2 havent been looking at a tech spec change, but we have 3 been looking at the alignments that the tech spec could 4 allow. Thats part of the modeling and the different 5 system alignments, that we could be in this type 6 of alignment submitted by the tech specs, but thus far, we 7 havent considered a tech spec change.
8 We have considered administrative restrictions that 9 we must have above and beyond the tech spec requirement, 10 for example, two startup transformers must be in service in 11 order to satisfy, satisfy the operability. But were in 12 the very early stages of evaluating this, and have the team 13 actively doing that now.
14 MS. LIPA: Thank you.
15 MR. GROBE: Just so I 16 understand, the only thing youve identified to-date is 17 possibly that a tech spec could be nonconservative, in 18 which case you would need Administrative Letter 98-01 to 19 apply some administrative controls and assume a tech spec 20 change order?
21 MR. POWERS: Thats right.
22 Thats essentially where we are. We havent gone to that 23 level of detail, but thats the type of --
24 MR. GROBE: Youre not there 25 yet?
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
51 1 MR. POWERS: No.
2 MR. GROBE: Okay.
3 MR. MYERS: No, not at all.
4 MR. POWERS: Okay. Next topic 5 I wanted to brief on is the Safety Features Actuation 6 System Relays. These are relays in a system that were 7 changed out very early in the refueling outage last year.
8 They were part of the planned projects for the refueling.
9 We changed to a different type of relay. It was 10 intended to be installed to replace the original relays 11 that were supplied with the plant. Over time as weve been 12 replacing those relays, we ran into a problem with 13 obsolescence; that is, the supplier stopped manufacturing 14 the replacements for us. So, we needed to come up with an 15 alternative replacement.
16 The replacement that was developed, we found from 17 our testing, is not really suitable for the application.
18 So, weve taken those out. And, were in the process of 19 evaluating and returning the original relays to service, 20 while we regroup and review and develop a replacement for 21 them.
22 Some of the things weve done in this technical 23 evaluation, weve looked at the predominant reasons for 24 replacement of the relays and we found out there is --
25 replacements are usually due to coil problems. And, we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
52 1 found out with perspective coils and replacements, theyre 2 random with respect to age.
3 Weve tested the original relays. Weve developed a 4 bench test criteria looking at coil resistance and contact 5 resistance and insulation performance of them, and gone 6 through and screened out a small population that did not 7 meet our acceptance criteria and we took those out of the 8 population.
9 We believe that the remaining relays that, of this 10 original group, will have improved reliability as a 11 result. And weve developed an action plan to go through, 12 based on our problem-solving decision-making process, to go 13 through this testing and evaluation process. MPR 14 Associates is our lead technical support team as we go 15 through this evaluation.
16 Because we screened out a number of outlayers outliers that 17 didnt meet our acceptance criteria, we obtained 18 replacements from another utility for the ones we could not 19 reinstall in our plant. And we have those on site now and 20 were going to run those through our bench test as well to 21 be sure that those are demonstrating appropriate 22 performance before we install them in our plant.
23 On the next slide, we see our Technical Evaluation 24 is in process. Talked a little about the industry experts, 25 MPR assisting us with this.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
53 1 Our average replacement, we found from a historical 2 review, has been about two percent per year for the past 3 twenty years. We have had a low level of replacement 4 activity ongoing.
5 We looked at temperature effects relative to aging.
6 Does not appear to be an issue, but were going to take 7 several relays apart to confirm it, and look at their 8 material condition to confirm that and to confirm their 9 functionality for another fuel cycle. And were also going 10 to perform an independent review of this technical work 11 that weve done.
12 Were going to prepare an Operability Evaluation to 13 confirm operability in this case. The original relays that 14 we had installed were operable. We had an obsolescence 15 issue with them. Were reinstalling them. Well document 16 the technical basis for that for Operations to review. And 17 expect to confirm that those relays were acceptable for 18 operation through the next operating cycle.
19 And I should point out, one of the major other 20 activities thats included in this effort is procurement of 21 a new generation of relay thats specifically engineered 22 for the application of panels, and thats ongoing now with 23 the initial specification stages as well.
24 MR. THOMAS: Whats been done 25 to strengthen your procurement process, specifically in the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
54 1 area of equivalency evaluations, to ensure youre getting 2 the components that you need to go into your safety related 3 equipment?
4 MR. POWERS: We have a 5 Significant Root Cause Condition Report that was written on 6 this issue, and that was assigned to our Procurement 7 Engineering Group to investigate, evaluate this issue, and 8 how those replacement relays at the beginning of the refuel 9 outage were specified, and what problems led to the issue 10 of their application.
11 So, they own that Condition Report. We have an 12 individual thats investigating it, feeding back what he 13 sees as potential causes. I have met with the Supervisor 14 of Procurement Engineering personally, and with the CR 15 Investigator, to go over some of the considerations when we 16 seek to get replacement parts for the plant, the level of 17 detail that we go into in scrutinizing the application of 18 the parts, and the application that theyre in.
19 So, weve had that dialogue, Scott, to assure that 20 thats well understood, the issue here, its relationship to 21 procurement process.
22 MR. GROBE: Just one more 23 relay question. If the failure rate has been fairly 24 consistent, two percent per year, does that indicate that 25 there hasnt been -- it was my understanding that the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
55 1 initiating action here was a perceived higher failure rate 2 combined with a difficulty getting replacement parts, which 3 caused you to replace these relays.
4 MR. POWERS: Right. What were 5 finding when we say perceived high failure rate. We find 6 from historical records that there was a relatively steady 7 low level failure rate. When you have a failure in IC, 8 Maintenance needs to do a change-out. That activity was 9 ongoing.
10 But, where it really became a critical issue is when 11 the manufacturer stopped providing that style relay. It 12 became an obsolescence issue that needed to have changed.
13 MR. MYERS: Were working with 14 three other utilities.
15 MR. GROBE: Sorry?
16 MR. MYERS: Were working 17 with three other utilities that also have this same relay 18 in their systems. In fact, we went out and got them to 19 give us their relays, so we would have enough for this 20 cycle. I think it was like 256 relays.
21 But support knows this is a reliability issue.
22 These relays, when they do fail, they fail in a safe 23 state. They fail on trip mode. So, what you wind up with 24 is a reliability issue.
25 MR. GROBE: So, these relays MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
56 1 wont be treated any differently under the maintenance rule 2 then? Theyre in fine condition from a maintenance 3 reliability perspective?
4 MR. MYERS: I think thats 5 correct, yes.
6 MS. LIPA: Okay. Anybody 7 else, questions for Jim?
8 This would be a good time for a 10 minute break.
9 Your next session is about to start, right?
10 Okay, so 10 minutes.
11 (Off the record.)
12 MS. LIPA: Okay, Bob, you 13 can go ahead.
14 MR. SCHRAUDER: Thank you.
15 Im going to talk about two issues today; the high 16 pressure injection pump modification were pursuing, and 17 also give you an update where were at with the Corrective 18 Action Program. Ill start with the high pressure 19 injection pump.
20 Before I get started on that, I would like to 21 recognize John ONeill, who is in the audience. He is our 22 Site Project Manager and coordinates all the activities 23 involved with the high pressure injection pump. And, hes 24 going a really good job for us on the site. I appreciate 25 the support we have with him.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
57 1 High pressure injection pump modification. The last 2 time we got together, we talked about the potential for 3 modifying the existing pumps in lieu of replacing with the 4 pumps that we had purchased. Since that time, we have 5 looked at this option in more detail, and have decided that 6 this will be our primary success path.
7 We have confirmed for ourselves that this 8 modification will work. With the modification installed, 9 the pumps will perform all of their required activities.
10 And we continue to work very closely with MPR Associates on 11 this activity.
12 And the issue with the high pressure injection pumps 13 is, we found even with the new screens that we put on our 14 sump, that very fine debris that can get through the sump 15 screen could impact the existing internal pump clearances 16 and had the potential to cause the pump not to be able to 17 perform appropriately.
18 Again, we had looked at replacing or modifying these 19 pumps. Since our last meeting, we have not abandoned the 20 replacement activity, but we put that on hold right now and 21 are not proceeding with that option. We have very high 22 confidence levels in the modification approach, as its far 23 less complex, touches fewer of the plant systems, and that 24 type of piping modification and support modifications that 25 would have been involved in the replacement option.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
58 1 What we will do is modify our existing pumps with an 2 internal strainer that will strain the water that goes to 3 the hydrostatic bearing.
4 Im going to talk a little about the project 5 milestones, the strainer design and its testing, what were 6 doing to validate the pump performance for potential 7 clearance opening as a result of pumping the debris water; 8 and then talk a little bit about what its going to take to 9 implement this modification in the field. I would say that 10 that field implementation represents the biggest challenge 11 certainly from the perspective of the schedule.
12 So, on the next slide, Ill talk about the strainer 13 design and the testing. The strainer will allow water to 14 pass through and supply the hydrostatic bearing and the 15 seal. Its what I call a self-flushing strainer. That 16 would determine analytically that the transiental flow and 17 the velocity of the water will maintain the screen clear of 18 debris and allow water to get through, but will not allow 19 the debris to get through there.
20 If you go to the next slide for a second, well talk 21 about a little bit different design approach than we talked 22 about last time. Right in here are the screens that we 23 talk about. And right here is the take-off that feeds the 24 hydrostatic bearing. This represents the volute in the 25 fourth stage of the pump.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
59 1 The last time we had talked, this screen, the port 2 that goes over the bearing was located, is currently 3 located right there. And the screen would have gone, cant 4 see it real well, but this is a curved surface in here.
5 And we have changed that location to the one thats shown 6 in this configuration.
7 And we did that, because we found that by relocating 8 those ports, the water that supplies the hydrostatic 9 bearing has a higher flow velocity achieved to the screen 10 itself over a wider range of the pump flows, which will 11 assure that the screen stays clean, particularly at the, 12 near the shut-off head of this pump or in the minimum 13 recirculation mode, the velocity we would have gotten 14 pretty low at the screen, and would have increased the 15 probability of plugging the screen.
16 So, this new location also allows the pressure to be 17 higher and to be more constant. That in turn maintains a 18 more constant flow to the bearing, which will make the 19 bearing stiffness more constant over a wider range of the 20 pump operation. Thats one design change that we had since 21 the last meeting.
22 We have also discovered since the last meeting in 23 this design, that the French actually have this type of 24 pump, not the exact same model, but a similar pump in 25 service in some of the French plants. And they have MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
60 1 actually done this modification; not the screen 2 modification, but theyve moved that port, we found, for 3 very much the same reasons, which we kind of discovered 4 after we come up with this design, that another group of 5 engineers had actually found this also, that they get 6 better performance out of the pump by just moving that port 7 to the hydrostatic bearing to a different location there.
8 MPR Associates again is performing the design work 9 for us. Theyre going to mockup and test this strainer 10 design at Wyle Labs.
11 One of the things we discussed last time, we 12 depicted a picture of what the mockup would look like.
13 Since that time, weve obtained a pump, again similar to 14 our pump design, not the same design, its a single stage 15 pump, but it has the same type of approach that this 16 volute, that we can test more accurately, lets say, than 17 we did the mockup. Well actually be doing the strainer 18 testing in a pump in the environment we need to have it 19 with the debris in the water.
20 MR. GROBE: Bob.
21 MR. SCHRAUDER: Yes?
22 MR. GROBE: Just quickly, did 23 you indicate that these pumps, this same design problem 24 exists on pumps that are used in nuclear plants in France?
25 MR. SCHRAUDER: That is my MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
61 1 understanding right now. I checked yesterday to see if the 2 French had these in their nuclear facilities, and was told 3 that they do.
4 We are attempting to get the reports on this, 5 modifications that theyve made, from the French, and were 6 expecting to get those in the next couple of days, so we 7 can look in detail at that.
8 MR. GROBE: I have the other 9 interest; you indicated that they dont have these types of 10 screens installed in the other pumps?
11 MR. SCHRAUDER: No, they dont.
12 They found by simply moving the port, it was acceptable.
13 We looked at that and decided that the added assurance of 14 the screen provides us a level of protection that we want; 15 and were going to continue with the screen modification.
16 MR. GROBE: Okay, thanks.
17 MR. THOMAS: Bob, did you say 18 you were doing both; you are going to move the -- is that 19 the location?
20 MR. SCHRAUDER: Currently, right 21 here is where the existing pumps take-off would be, okay.
22 MR. THOMAS: Okay. I see.
23 Thank you.
24 MR. SCHRAUDER: They were over 25 here. And its a down, and then into the port. So, it MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
62 1 changes, its not a direct take-off of that anymore.
2 Okay. The next subject Ill talk about is the 3 validation pump performance, validation. We actually did 4 perform the first test on this with the pump clearances as 5 they actually exist in the pump. Our rotodynamics analysis 6 has predicted satisfactory pump operations.
7 What well do, is were going to do two periods of 8 this. The first one is called the baseline test. It 9 helped us confirm the model that we created and took some 10 baseline readings on vibrations for the pump, found where 11 the critical speed of the pump was. We were able to find 12 that. We did find in this test that the vibration was very 13 steady on the pump throughout its flow regime that we 14 exercised it through.
15 The next test that well do is, we have opened up 16 the clearances, and well performed what we call the 2X 17 Test, where the clearance are twice what they are normally 18 in the pump. And well run the test again, and validate it 19 with that isolated opening of the clearances due to debris 20 impacting on the clearance, that the pump would continue to 21 perform in a satisfactory manner.
22 The 2X was chosen, its a maximum estimate that we 23 currently have of what the tolerances and clearances would 24 open up to. Were going to do a mockup test also on 25 similar material to our pump to identify how much clearance MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
63 1 you would actually get, but we expect that the 2X clearance 2 or twice the clearance will easily encompass the maximum 3 amount of degradation we would see for the commission time 4 of this pump.
5 Then after the, after the modifications are made and 6 the pumps are resembled, well of course have post 7 modification testing on the pumps before returning them to 8 service.
9 Field implementation. Again, the biggest challenge, 10 particularly in Pump Room Number 2. Pump Room Number 1, 11 which is the pump that were using to perform the tests on, 12 is relatively easy; as easy goes to disassemble a 6,000 13 pound pump; but its a fairly straightforward, pull the 14 internals out of the pump, plenty of clearance there, then 15 we move the pump to a plug in the floor where it can be 16 lifted out and transported to the facility thats going to 17 do the modifications on it.
18 The number two pump, on the other hand, has a lot 19 more interferences by way of other pumps, other motors in 20 the area, and it presents the biggest challenge to us to 21 getting this pump out and maneuvered out of the building 22 into the facility to modify and then to reinstall it.
23 So, there is about a months work of activity 24 between disassembly and reassembly of that pump in the 25 schedule. And we have not had this pump apart in this MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
64 1 manner to take it out like this before, so we really dont 2 know exactly how long its going to take us to get it in 3 and out.
4 There is a fair amount of rigging thats involved in 5 there, and verification that our rigging points will take 6 the six thousand pound load. There are conduit clearance 7 that have to be made, taken out and reput in when we get 8 back. So, there is a lot of field implementation challenge 9 in pump number two.
10 We have a team resolving all those issues, laying 11 out the travel path for the pump, and how it will come out 12 and be maneuvered up and through the room; and theyre 13 progressing with that.
14 Weve actually gone and, the next picture shows a 15 mockup, a full-size mockup of the internals of that pump 16 that we built, so we can actually take it through the 17 travel path and know exactly all the way through the plant 18 that it will clear all the areas that we need to clear it 19 to get it out of the Plant and then back in again.
20 The next picture just shows what I was talking 21 about, some of the congestion in the pump room itself. In 22 the wall back here, relatively close, the pump will come 23 out the back. It has to go out 32 inches this way and then 24 tilt up and level this way and then brought forward and 25 maneuvered around the corner. So, it is, you can kind of MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
65 1 sense the congestion within that room. So, its a delicate 2 piece of rigging and a lot of attention is being paid to 3 that.
4 So, thats where were at with the high pressure 5 injection pump modification. In summary, implementation of 6 this mod will resolve in our mind a debris issue. Well 7 demonstrate by combination of testing in laboratory and in 8 the plant, that the pump will perform under all of its 9 required conditions. And that the schedule for doing this 10 modification supports being able to do the normal operating 11 pressure and normal operating test in mid to late July.
12 I gave Christine a schedule of the activities down 13 at the lab where theyre going to do the mockup, so that 14 the inspectors can come down and see that in progress, as 15 well as well be down there observing that also.
16 Any questions on the pump?
17 MR. GROBE: Yeah, I 18 apologize. We have a conference call I think were trying 19 to schedule for next week to do some preliminary 20 discussions with the technical staff on this modification; 21 then a meeting on the 19th.
22 MR. SCHRAUDER: Right.
23 MR. GROBE: You mentioned 24 earlier today or yesterday that there might be some testing 25 that will be going on before that 19th meeting?
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
66 1 MR. SCHRAUDER: Right, thats the 2 schedule that I gave to Christine. It actually starts I 3 believe on, around the 15th or 17th of June. I wanted to 4 make sure that we had that schedule so you could get down.
5 MR. GROBE: Well have to 6 make sure we discuss that during conference call.
7 MS. LIPA: Right.
8 MR. GROBE: Okay, thanks.
9 MR. SCHRAUDER: Then, the next 10 topic that I want to talk about is the Corrective Action 11 Program. And kind of where were at there, what were 12 seeing in the Corrective Action Program, what youre 13 seeing, and some of the inspections that youre doing.
14 And, Steve is going to talk a little bit too what the 15 Quality Assurance Organization is doing.
16 This is an important topic for us. As we recall, 17 the Corrective Action Program effectiveness was found to be 18 a significant contributor to the events surrounding the 19 reactor vessel head degradation; and its vitality and its 20 viability are key for our future success, that we avoid any 21 such problems in the future.
22 We strengthened both the procedure and the 23 implementation of this program. I would not say its 24 perfect. We still have work to do in anchoring the program 25 to the standards for all of the people involved in this MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
67 1 program.
2 We have seen some problems or shortcomings in some 3 of the new implementation and the new procedure we put in.
4 And Ill address some of those as we go forward.
5 In the meantime, we have I believe implemented some 6 compensatory actions and oversight in the program to ensure 7 ourselves that were getting the adequacy out of the 8 program we need to move forward.
9 At the same time that were trying to anchor this 10 program, due to, you know, the extensive reviews were 11 doing in the plant, design world, and across the site, 12 really, weve generated over 12,000 Condition Reports last 13 year and so far this year. So, were trying to rebuild the 14 program. At the same time were moving a lot of Condition 15 Reports, more than you would typically see in a given 16 period for this amount of time to the process. So, that 17 itself presents some challenges on oversight and assurance 18 of quality of that program.
19 The first thing, I picked three topics that involve 20 really the, the strength of the program. And the last one 21 is one thats come up several times, is the rollover issue 22 of Condition Reports, and Ill talk about that.
23 When you talk about the strength of a Corrective 24 Action Program, you want to make sure that the Condition 25 Reports that youre writing and evaluating, A and, that you MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
68 1 have the proper level of threshold that people will write a 2 Condition Report. But once its written, you want to make 3 sure its appropriately categorized so it gets the 4 appropriate amount of investigation into the condition and 5 the corrective actions associated with it.
6 So, we look at categorization. We look at the 7 quality of the Corrective Actions and the investigation 8 thats going in; and then you also look at the timeliness 9 of responding to the Condition Reports, once theyre 10 initiated. So, those are the three topics that Ill talk 11 about, and then discuss a little bit the rollover process.
12 First one in categorization. Again, the new process 13 became effective for us in March of this year. And it was 14 issued as a FENOC Nuclear Operating Procedure. The major 15 difference I would say, big change in that process is, it 16 went from several different types of cause analysis. We 17 have an apparent cause analysis, we had a basic cause 18 analysis, and we had a significant root cause analysis.
19 The new process has eliminated the basic cause out 20 of it. That is more consistent with industry standards.
21 Now, in addition to eliminating the basic cause, 22 what we did, we upgraded the requirements for doing an 23 apparent cause. So, the requirements there are stricter.
24 There has to be a specified simple analysis method 25 performed. And, we also required on apparent cause MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
69 1 analysis now, generic implications and extent of condition 2 statements within the Condition Report Evaluation.
3 Some of the ones that in the previous system were 4 called apparent causes would now be fixes. And some of 5 them would remain just upgraded apparent causes. We did 6 benchmark the process and believe that it is very 7 consistent with some of the better corrective action 8 programs within the industry.
9 Categorization is one of the things that we would 10 measure, is how well the supervisor that does the initial 11 review on the Condition Report when its being initiated, 12 how well they meet the categorization as specified in the 13 procedure. And that is done by the Management Review 14 Board, which is a collection of managers and senior 15 managers at the site.
16 We have seen actually fairly good categorization.
17 Weve made what might be considered a number of changes, 18 category changes, for instance; and we had a Condition 19 Report written by an individual at the site that said, it 20 seems like you are getting an awful lot of changes that the 21 Management Review Board hasnt changed. They lumped 22 together in that the significance level and the cause 23 evaluation level. And were looking at that.
24 What we found is, in the category changes, what we 25 track very closely is where the Management Review Board has MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
70 1 felt they needed to upgrade from what the supervisor 2 identified; no, this evaluation needs to be of a higher 3 level than what you identified.
4 So, category upgrades, we would consider 5 identification of a condition thats not a condition 6 adverse to quality, where the Management Review Board says, 7 well, yeah, for these reasons it is a condition adverse to 8 quality. And then also a Condition Report thats 9 identified as a condition adverse to quality, but the 10 Management Review Board believes that it is a significant 11 condition adverse to quality.
12 So, in the, not a condition adverse to quality 13 upgraded by the Management Review Board to a condition 14 adverse to quality, weve seen 125 upgrades since the March 15 revision went in place. And since we put the revision in 16 place, weve had about 2,500 Condition Reports initiated.
17 So, 125 of them, we upgraded from what we call an NCAQ to a 18 condition adverse to quality, and eight of them from a 19 condition adverse to quality to a significant condition 20 adverse to quality.
21 Where weve seen the biggest, what Ill call, delta 22 between the management review and the supervisors review 23 is in the type of analysis thats required for the 24 Condition Report. And the biggest one of that is, 25 where the apparent cause versus the fix; where the old MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
71 1 process, they would all have been apparent causes, now some 2 of them would be upgraded to apparent and some of them are 3 saying, these are fixed and trend.
4 What we found is that the supervisors are more apt 5 to put it into the apparent cause evaluation, then the 6 procedure specifies it would be a fix and trend. Weve had 7 in the order of 250 of those, where the supervisor had said 8 its an apparent cause, and Management Review Board says, 9 no, its a fix and trend.
10 Weve had some others. The next biggest one is 57, 11 where the supervisor said, weve taking taken the action 12 sufficient, well close this Condition Report. And 13 Management Review Board said, no, you have a couple other 14 actions, therefore, its a fixed. So, that would be a 15 category process change there.
16 Then, the rest of them are all, a lot fewer, and 17 those are by far the two biggest hitters that weve seen in 18 the recategorization.
19 So, we have not completed yet our review on the 20 Condition Report that was written. We have looked closely 21 at the datum and those are the kinds of things we found.
22 One of the other things Ill say we did find in that 23 Condition Report was an expression by several people, I 24 guess, this person was taking input from. What Ill -- the 25 frustration over the feedback mechanism. That is, the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
72 1 Management Review Board is changing these categories, and 2 theyre sending back information to us that says theyve 3 changed it, but you havent given us enough details to why 4 you changed it or what is the category, so we can learn 5 from that process, rather than have you continue to 6 feedback that we changed the category.
7 So, were looking at better feedback mechanism to 8 explain more completely why we changed the category or 9 evaluation process.
10 What we have found is several of those that we sent 11 back and said, no, we think its this, theyve come back to 12 the Management Review Board and said, heres where I 13 categorized it that way, this was my perspective of why it 14 should be in this category. And in several of those cases, 15 we have agreed with the initiator or the supervisor and 16 said, yeah, we can see that, and it may well be more 17 appropriate to be in that categorization. So, weve 18 changed some of them back to the original identified one.
19 The next, the graph just shows what Ive been 20 discussing. This measures what, again what we watch very 21 carefully is those Condition Report categories, significant 22 or condition adverse to quality, that weve had to change 23 and upgrade the performance of it.
24 We would like to get this into the 90 percent range, 25 and were doing reasonably well on meeting that goal right MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
73 1 now. Its, fewer than ten percent of the Condition Reports 2 are upgraded as a result of management review.
3 MS. LIPA: Bob, how long have 4 you been tracking this indicator, have you been tracking it 5 for years?
6 MR. SCHRAUDER: No, were tracking 7 this -- well, I think they did track before, before the new 8 process went into place also. The statistics that Ive 9 been looking at are since weve changed the process 10 specifically, and that trend has also been improving on 11 which ones we had to change also. And initially, it was 12 like 29 percent the first month, and then 23 percent the 13 next month, and 14 percent. This is all changes, not just 14 the upgrades, but the evaluation process ones too.
15 So, we are seeing an improvement, as people become 16 more acclimated to the new process. Were also looking at 17 additional training, site-wide training, and we provided 18 training to the Condition Reporting analysts, but were 19 looking at more training across the site on that process 20 also.
21 Any questions on categorization?
22 The next thing I want to talk about is quality of 23 the Condition Reports.
24 What we really, right now the measure that we have 25 for quality is at the Corrective Action Review Board; and, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
74 1 how often we have to reject an evaluation that comes to the 2 Corrective Action Review Board.
3 One of the things Ill say is, this first slide 4 shows the Corrective Action Review Board, by charter, by 5 procedure right now, is not charted to look at apparent 6 causes, but as an interim measure weve decided that they 7 probably will look at the apparent cause analysis too, 8 because of this change in the procedure, to make sure that 9 people understand that.
10 Thats where weve seen the biggest, I guess, delta 11 between the procedure and whats actually coming to the 12 Corrective Action Review Board. You can see right now 13 were running at about a 60 percent acceptance rate on 14 those, and rejecting them for one reason or another.
15 Were looking at a hundred percent of them right 16 now. Our intention is to look at all of them until we have 17 confidence that theyre being evaluated and dispositioned 18 appropriately.
19 Recent changes weve made to help enhance the 20 feedback is that the responsible manager of the section 21 thats presenting the Condition Report to us, is present at 22 the meetings, so that he can sense firsthand why, the kind 23 of discussions we have and why we are rejecting some of 24 these, and then well have communication back into the 25 group. And when necessary, we see a specific area thats MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
75 1 struggling, well give one-on-one communication with that 2 manager.
3 MR. GROBE: It took me 4 awhile, but I think I understood the chart.
5 MR. SCHRAUDER: Yeah, well -- Im 6 sorry.
7 MR. GROBE: If I could, the 8 height of the bar there is the indicator of the number of 9 items processed, but you dont have a trend line indicating 10 acceptance rate.
11 MR. SCHRAUDER: Thats right.
12 Actually, the legend is, yeah, the total height is the ones 13 weve looked at, and the red are the numbers that weve 14 rejected. Its going to have a trend line. It is a twelve 15 month rolling average that will trend. We just now got the 16 twelfth week for a couple days, so we havent done it, 17 twelve month rolling average on it right now.
18 MR. GROBE: Got it.
19 MR. SCHRAUDER: But the current 20 rejection rate is right around 62 percent on here.
21 Scott, do you have something?
22 MR. THOMAS: Yeah, you said 23 that items were rejected for one reason or another. Have 24 you identified any specific reasons why some of these 25 things have been rejected?
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
76 1 MR. SCHRAUDER: Thats the next 2 thing Im going to get to.
3 MR. THOMAS: Im sorry. Ill 4 wait then.
5 MR. SCHRAUDER: Some of the 6 reasons why weve rejected it. Some of the reasons are, 7 the evaluations just have not been in the CARBs mind 8 thorough enough, we would reject it.
9 If it doesnt meet the new format. The new process 10 has a specific format that apparent cause needs to follow.
11 If its not in that format, well just reject it, have them 12 get it into the format and bring it back to us.
13 The thing to keep in mind is, many of these apparent 14 causes were actually, because we had this large number, 15 they were generated prior to the change in the procedure.
16 Some of them still have to go through the new procedure 17 process.
18 If, for instance, they had been generated as a 19 basic, or went through a process when we put the new 20 process in place, some of the basics became apparents and 21 some of them may have gone to root cause. So, they still 22 have to meet the new format, even though they were 23 generated early in the process, and some of them were not 24 meeting that new format. So, that would be a reason for 25 rejection.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
77 1 The Corrective Action identified was either not 2 specific enough, in our mind, or measurable enough or 3 clearly written or was not timely enough in the Corrective 4 Action Review Boards mind; or the experience review 5 required or the generic implications and extent of 6 conditions may not have been performed, that would be 7 reason for rejection.
8 And a lot of them, I sit in on a lot of CARBs and a 9 lot of them have been rejected because they simply did not 10 specify the analysis method that they used. May have been 11 apparent in reading it what type of analysis they went 12 through, but they didnt specify, and the procedure 13 requires that you specify the simple analysis that youre 14 using.
15 Again the interim compensatory measure for this is 16 the CARB itself. Again, were continuing to review the 17 apparent causes, all of them right now, until such time as 18 we see, well start relaxing on that when we see particular 19 sections meeting the standards.
20 Some of them are doing very well. For instance, we 21 have noted that the Design Engineering Section, which does 22 a very good job at meeting all of the requirements on the 23 apparent causes. And apparent causes come in pretty well.
24 And weve had only one rejection I believe out of design, 25 and that was as a result of just not specifying an analysis MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
78 1 technique.
2 So, we havent yet, but we will move toward design 3 in the direction of doing a sampling of their reviews, 4 rather than a hundred percent of their analysis.
5 And we are looking at, well develop additional 6 training for the -- weve trained the analysts, if the 7 sections use them effectively, the analyst can help them 8 make sure their Condition Reports are in, in the proper 9 format and the like.
10 Weve seen the organizations that effectively use 11 their analysts do a much better job at getting these things 12 in, but well provide additional training there.
13 We did generate a Condition Report on this issue 14 itself, that we had a high rejection rate from the CARB, so 15 that Condition Report is in the process now.
16 Scott, do you have a question?
17 MR. THOMAS: Do you have 18 specific training for the folks that do the cause analysis, 19 or apparent cause?
20 MR. SCHRAUDER: We have a specific 21 training module, as you know, for root cause analysis. We 22 are developing the training module for the, specifically, 23 the apparent cause analysis.
24 The techniques, you can either use a root cause 25 technique, or simple analysis techniques can be things like MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
79 1 brain storming, interviewing, methods of collecting the 2 data and assessing the data. So, we have not had the 3 training module put together on that yet, but thats one of 4 the things weve discovered in this that we probably need 5 to do some additional training on some of these simple 6 analysis methods; where you think it might be reasonably 7 clear and in some cases its not. So, thats under 8 development.
9 MR. THOMAS: How many of your 10 folks have actual root cause training? Im not asking for 11 a specific number, just --
12 MR. SCHRAUDER: Hundreds, I would 13 say. I dont know the exact number, but we did a lot of 14 training in root cause analysis techniques.
15 MR. THOMAS: Okay.
16 MR. SCHRAUDER: I can get the 17 number for you.
18 MR. THOMAS: Thats not 19 important.
20 MR. SCHRAUDER: Its a large 21 number of people, its not just one or two.
22 When these Condition Reports come to the CARB, we 23 have a check-off sheet that we go through. Its not just, 24 you know, our collective wisdom that judges the 25 acceptability of them. There is a check-off sheet that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
80 1 asks specific questions. You know, does the information 2 present any significant doubt as to the cause of the 3 events? Is the evaluation package, does it lack clarity or 4 conciseness or relevance?
5 And we answer these questions yes or no, and then 6 make a judgment as to whether we ought to accept the 7 Condition Report and making comments back to the 8 evaluators, or whether it ought to be rejected and redone 9 and resubmitted to the CARB. So, its a formal kind of 10 check-off process that we go through.
11 One of the things that were learning as we go 12 forward in quality measurements of the Condition Reports is 13 that some facilities actually have a specific grade that 14 theyll assign to the Condition Report.
15 We have a new program owner for the, FENOC program 16 owner for this program. And hes in the process of 17 benchmarking and developing some FENOC-wide performance 18 indicators, and quality is one of the ones we want some 19 additional ability to measure some of the quality.
20 The next slide shows these root cause evaluations 21 that come in. These are typically the more significant 22 issues. What we have found, this is probably a measure of 23 the degree of training that youre given in root cause 24 analysis, but we found a much higher acceptance rate and a 25 much higher quality in the root cause analysis. Our goal MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
81 1 there is a 90 percent acceptance rate. We are currently 2 meeting, meeting that; and the root cause has continued to 3 be pretty good for the most part.
4 Things that we would reject a root cause for are 5 really the same kinds of things. We dont see as many 6 format-type problems with root causes, because they pretty 7 much have a cookbook that they can fit their analysis and 8 their evaluation into.
9 But sometimes if the root cause, maybe in the minds 10 of the CARB they present the process, doesnt look like 11 they maybe got to the root cause by way of not 12 appropriately considering some pieces of data. So, if we 13 felt that they may have missed some ingredient factor, we 14 would reject it.
15 Again, if the Corrective Action is not clear enough, 16 or we didnt believe it would have the potential to fix the 17 problem, we would reject it. And a significant condition 18 adverse to quality is different than apparent, in that the 19 corrective action is expected that it would, would not 20 occur again.
21 An apparent cause, you look at the apparent reason, 22 and you do your best attempt at getting it, but you expect 23 some percentage of those may recur. A root cause analysis 24 is different in that you expect that you will get to the 25 root cause and you will not have that condition repeat MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
82 1 itself. So, Corrective Actions need to be more stringent, 2 more clear, more specific, and very clearly expected to 3 prevent the action from occurring.
4 We would also reject a root cause if we believe that 5 the extent of condition was too shallow, didnt, you know, 6 look too narrowly for your extent of condition. So, that 7 would be a cause for rejection for a root cause analysis 8 also.
9 So, thats kind of where we stand in our look at the 10 quality of whats coming in.
11 The next issue is timeliness. And this is another 12 issue that Ill say is exacerbated by the volume of 13 Condition Reports that were getting in.
14 What we found, frankly, was that we had a lot of 15 Condition Reports. The procedure requires a specific 16 period of time, a default time, if you will, that an 17 Evaluation and Corrective Actions are expected to be 18 implemented within. And sometimes you extend those, 19 depending on the circumstances and when the, you know, 20 schedule in an outage, for instance, to get it done. But 21 there is nothing in the procedure that allows for a 22 Condition Report to just go overdue. So, we had a large 23 number of, based on our volume of ones that were just 24 overdue, were not being extended, and not getting done.
25 In response to that, we put together a high level MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
83 1 management review team that meets daily on the status of 2 evaluations and corrective actions looking at whats coming 3 up in the next three days, whats currently overdue, whats 4 the reason for it overdue.
5 We can extend due dates in that meeting, but we 6 have found that to be very effective. And that the overdue 7 rate now is, is substantially lower, and is meeting a goal 8 of less than five percent. For the last several weeks, 9 its been down hovering near zero of overdue. So, people 10 are appropriately extending or getting their evaluations in 11 and their corrective actions done.
12 MR. THOMAS: So, this chart 13 doesnt take into account a corrective action thats been 14 extended four or five times?
15 MR. SCHRAUDER: Does not measure 16 extensions. We believe that extensions are granted at the 17 varying levels of the organization, and extensions are 18 approved with management oversight of them.
19 So that, now, that was the thing I was going to 20 mention at the end of this, is that timeliness is another 21 issue. Im used to seeing more performance indicators. It 22 wouldnt be as meaningful for us right now, based on, you 23 know, several of these have been extended outs of post 24 restart. So, the average age is one thing that you would 25 typically look like, the average age of your Condition MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
84 1 Reports, Corrective Actions that havent been completed 2 yet. The average age to close a Condition Report is 3 another one that you track.
4 Were not, we dont have those in place right now, 5 because they wouldnt, wouldnt tell us much. As we move 6 forward, well put together more timeliness of things too.
7 Go ahead, Jack.
8 MR. GROBE: What, what 9 percentage in rough terms do you find -- youre involved in 10 this group that meets daily, right?
11 MR. SCHRAUDER: No, Im not. Mark 12 is the chair of that meeting.
13 MR. GROBE: What percentage 14 do you find that get extended?
15 MR. SCHRAUDER: Id have to look 16 at that.
17 MR. GROBE: Not precisely.
18 MR. SCHRAUDER: A lot right now.
19 MR. BEZILLA: Its stacks about 20 this thick, and Ill say, its probably about like five 21 percent or less of that.
22 What we did was, about a month ago, we told the 23 folks to lay out their work, match to their resource, and 24 give us their due dates, and then they had to meet their 25 due dates or hold them accountable to that; and if they had MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
85 1 trouble meeting their due dates, they need to come in and 2 tell us ahead of time that theyre having trouble, and 3 well either help them meet their due date or well give 4 them some relief on their due date.
5 And since weve done that in the last few weeks, 6 weve had a lot less overdue items. In fact, we had a 7 couple day days in row with like no overdue items. Thats been 8 very positive, I think.
9 MR. SCHRAUDER: In that though, if 10 you look at the database, lets say, a lot of them would 11 have had an extension somewhere along the line. Thats 12 what I was referring to. A lot of them in this process 13 have been extended through the outage period. A lot of 14 them are tied to plant conditions, where youre going to 15 get. So, if the schedule moves, the due date moves out.
16 The process actually allows us to move those types, 17 you know, where theyre outage related and theyre 18 schedule, schedule driven, that an extension is not 19 required to go through the same process, to move it with 20 the schedule, so long as that, at the outage end date they 21 are completed.
22 And thats part of our Restart Readiness Review, is 23 that all the Corrective Actions, Condition Reports that 24 were required to be completed for the outage are 25 completed.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
86 1 MR. GROBE: I think I agree 2 with you, that this timeliness information doesnt tell the 3 whole story. It seems like three items. Sorry.
4 This item is good, which is open corrective actions 5 which are overdue, but you have two other indicators, one 6 is number of extensions granted and the other is average 7 age.
8 MR. SCHRAUDER: Right.
9 MR. GROBE: Extensions or 10 indicator at a different level of organization management 11 level.
12 MR. SCHRAUDER: Thats correct, 13 and we typically do in the processes that Ive been 14 involved with over at our other facility, we do track a 15 number of extensions. And we do, we have a number of 16 extensions on the Condition Reports, but its a measure 17 right now in the process that were kind of in, thats not 18 as meaningful, that once we get through this, this 19 outage --
20 MR. GROBE: I understand.
21 MR. SCHRAUDER: -- and get them 22 going. So, we will be adding those into our portfolio of 23 Condition Reports that we use to look at the health of this 24 program.
25 The next one is the same type of graph, and it MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
87 1 deals with the evaluations. Its the evaluations that 2 weve done by its due date, the same type of information.
3 The first one was the corrective actions that come out of 4 it. This one is actually hitting the situation, evaluate 5 it to determine what you need to do to fix it.
6 The other timeliness measures that we look at, shown 7 on the next one, is the supervisor review. Its expected 8 that the supervisor, once an individual has initiated a 9 Condition Report, it goes to supervisor review that 10 categorizes it, makes sure its appropriately categorized 11 and clearly identifies the problem.
12 We expect that to be done within one day. And 13 again, we expect that at least 90 percent of them to get 14 done within one day or less. And were hovering right 15 around 90 percent right now on that. So, I think thats 89 16 the last time we printed that out.
17 Again, that can be a condition of volume also, but 18 the supervisors are doing a pretty good job right now 19 getting through the Condition Reports on the day that 20 theyre initiated.
21 Then, the next review we looked at, is once the 22 supervisor reviews it and moves it along, its important 23 that the shift supervisor and the SRO review it.
24 Now, its not to say, if its a significant 25 condition impacting plant equipment, its initiated, its MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
88 1 typically walked to the control room, and control room is 2 notified of, you know, potential immediate impact on the 3 systems. But the process is, its expected that the SRO 4 would review the Condition Report within one day also of 5 the supervisors concurrence with, or not concurrence, but 6 forwarding of the review.
7 We expect that to be 95 percent of the time, the SRO 8 would get their review done within one day. Right now, 9 were seeing that its right around 86 percent completed 10 within one day. An overwhelming percentage of them are 11 done within two days, so between 86 and 100 percent, nearly 12 all of those are done within two days.
13 MR. GROBE: Im not sure I 14 understand this. Maybe I dont understand your process.
15 What review are you talking about here for the SRO 16 review?
17 MR. SCHRAUDER: Well, every 18 Condition Report that impacts plant equipment, that has any 19 asset number in it thats a piece of plant equipment, goes 20 to the control room for their review. They look at it for 21 operability. They look at it for reportability. They look 22 at it to understand what, you know, where the plant is at.
23 Thats why, I mean, a lot of these Condition Reports 24 are walked up to the control room when theyre written for 25 those very reasons. That if its an immediate impact on MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
89 1 the equipment, the control room needs to know that right 2 away.
3 Thats what the SROs review. Every Condition 4 Report that is addressed to a piece of plant equipment or a 5 configuration of the plant is reviewed by the SRO.
6 MR. GROBE: Does the CR first 7 have to go through a supervisory review?
8 MR. SCHRAUDER: Yes, it does.
9 Well, by the CREST software, before it progresses to the 10 SRO, it needs to be progressed through the supervisor 11 review.
12 MR. GROBE: And the SRO 13 review timeliness, that does not include the amount of time 14 that the supervisor took it?
15 MR. SCHRAUDER: Thats correct.
16 This is within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the time that they get it, they 17 have to have it reviewed in CREST.
18 MS. LIPA: Is this actually 19 tracked in hours or days?
20 MR. GROBE: Days.
21 MR. SCHRAUDER: Days.
22 MS. LIPA: One day or two 23 days or three days?
24 MR. SCHRAUDER: 24 increment is 25 what is expected to occur in.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
90 1 MR. GROBE: Are these 2 calendar days or business days?
3 MR. SCHRAUDER: Doesnt matter.
4 MS. LIPA: Calendar days?
5 MR. SCHRAUDER: Right, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
6 MR. GROBE: So, my statistics 7 are a bit rough, but if youre 89 percent of the time the 8 supervisors are taking more than a day, and 86 percent of 9 the SROs are taking more than a day, sounds like less than 10 75 percent of your CRs arent getting an operability review 11 in two days.
12 MR. SCHRAUDER: That could be, but 13 again, Id say, when it impacts operability, its walked to 14 the control room quickly.
15 MR. GROBE: Who is making that 16 decision, an operator?
17 MR. SCHRAUDER: The initiator and 18 reviewer are tasked with the responsibility of recognizing 19 whether something can impact operability or not.
20 And those statistics, Jack, if you recall, thats 21 the entire population of Condition Reports. I would say 22 probably, and this is a guess, 50 percent or less of them 23 involve plant equipment that needs to get to the control 24 room.
25 MR. GROBE: All right.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
91 1 MR. SCHRAUDER: So, its not quite 2 what you say. But youre right; I mean, with a delay by 3 the supervisor and the delay by the control room, you could 4 have issues there.
5 We think were doing reasonably well in getting 6 operability issues to the control room rapidly, even if it 7 hasnt progressed through the software system.
8 MR. GROBE: Well, I cant 9 tell that from these indicators. And, I think I need to 10 look a little bit more into this.
11 MR. SCHRAUDER: I understand your, 12 your insight on that.
13 MR. GROBE: Okay.
14 MR. SCHRAUDER: Any other 15 questions on the timeliness review?
16 The next issue is a, is the rollover process. And 17 the rollover has been identified both by our Performance 18 Improvement Unit, some of the inspectors that have come in, 19 Ill say confusing and a cumbersome process.
20 What a rollover is, its a method of transferring 21 the evaluation, whether the complete evaluation or partial 22 evaluation of one issue identified in a Condition Report to 23 be addressed in the another Condition Report thats looking 24 at essentially the same thing.
25 We have found, and your inspectors have found, that MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
92 1 it is a difficult trail to follow sometimes. There have 2 been cases where there have been multiple rolls; where it 3 rolls from one Condition Report to another, and then that 4 rolls up to another and you wind up doing about sometimes 5 seven or eight of these all in one Condition Report.
6 Again, is exacerbated by the large number of these 7 being processed. One area we have particularly seen this 8 in is Containment Health, you know, where we had a lot of 9 the walkdown type of CRs being documented and the like.
10 So, thats why I say, its generally been concentrated in a 11 few specific areas.
12 Weve actually found very few cases where we believe 13 that the case, that the issue has not actually been 14 effectively resolved. Its just a very cumbersome process 15 at times to track them from, to which CR, to which CR did 16 it go to and which one finally answered it. But we have 17 typically found that if you persevere through that process, 18 you will find the answer.
19 Now, Steve Loehlein is heading up a review team, 20 because we got enough comments and saw enough concerns Ill 21 say in this area that we wanted to really take a look at.
22 So, I believe Steve is looking at all the restart or the 23 0350 Condition Reports that had rollovers or rollintos in 24 them; given us some more insight on that. Out of his --
25 thats the independent assessment.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
93 1 One of the other things I wanted to mention is that 2 many of these rollovers occurred before we revised the 3 procedure. And the new procedure has more clarity on the 4 process for rolling over and what youre allowed to roll to 5 another Condition Report; and more specifics on the process 6 and documentation of a rollover.
7 So, to enhance that, we dont believe its a bad 8 idea necessarily to roll, roll over Condition Reports when 9 the receiving one is evaluating virtually the same kind of 10 circumstance. It has to be well documented and an easy 11 trail. But it does appropriately align resources. I think 12 if you just try to evaluate each one individually, you wind 13 up using resources over and over again to look at the same 14 thing. So, if properly administered, Ill say, and 15 documented, its not a bad process, but it needs to be 16 rigorously applied.
17 Weve seen problems with, the procedure right now 18 requires that if youre rolling to another one, the 19 receiving Condition Report has a corrective action in it 20 that says, hey, I got this one, so that the reviewer knows 21 that hes got to evaluate this other condition in it also.
22 Weve seen some problems in that area.
23 So, like I said, we have revised the procedure, 24 tried to provide more clear guidance. Steve is going to 25 give us some more insight into it and well further MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
94 1 strengthen the rollover criteria or, you know, if his 2 evaluation and assessment so indicates, we will consider 3 whether we want to continue the rollover process or not; 4 and well strengthen that process if we keep it and feed it 5 into the FENOC procedure.
6 Questions on the rollovers?
7 MS. LIPA: Thanks for that 8 discussion, Bob. I know our Corrective Action Team 9 Inspection will continue to look at corrective actions, and 10 through that, Im sure well look at some of these 11 rollover.
12 MR. SCHRAUDER: Right.
13 MS. LIPA: Any other 14 questions for Bob?
15 MR. SCHRAUDER: With that, Ill 16 turn it over to Steve.
17 MR. GROBE: Steve, before you 18 get started.
19 (Microphone adjustments.)
20 MR. GROBE: When youre 21 thinking about this rollover situation, think about it also 22 in the context of your performance indicators, and how you 23 treat rollovers in the performance indicators. I dont 24 think you want to discuss it here, because Im not sure 25 Ive given you a chance to think about it.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
95 1 MR. SCHRAUDER: It is addressed in 2 the procedure, Jack. If you roll it, it maintains its 3 current due date. You cant roll it and get an automatic 4 extension on it. So, it has to meet the original CRs due 5 date or it has to be appropriately extended for that.
6 MR. GROBE: Okay.
7 MR. MYERS: Jack, one of the 8 things, you know, we have a lot of experience at other 9 plants. There has been a large number of CRs here. We 10 dont roll, you know, at Beaver Valley we dont roll but a 11 couple a week. Its not like the rollover process causes a 12 lot of grief because were not rolling over that many. It 13 might be different at Perry, but at Beaver Valley I dont 14 remember rolling over. Do you?
15 MR. BEZILLA: Thats correct.
16 Just a handful a week at the most, is what I remember.
17 MR. GROBE: Okay.
18 MR. LOEHLEIN: Okay. Thanks, 19 Bob.
20 I have two things to talk about today. One has been 21 mentioned several times, and that is the status of the 22 Independent Review of Condition Reports; and the other is 23 an update on Quality Assessments of recent oversight 24 activities.
25 In the Independent Review of Condition Reports, we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
96 1 talked about this, or Bob mentioned the rollover issue, but 2 we also decided, and Lew Myers and I talked about this; we 3 heard enough reports about people having some difficulty 4 tracking through all the volumes of Condition Reports and 5 issues. And based on what Quality Assessment had been 6 seeing in its oversight, we agreed that doing an 7 independent review of the Condition Reports for the 350 8 Restart would be a good thing to do.
9 So, Mark Pavlik, who is an auditor in the QA 10 section, is the team lead for us on this. We have team 11 members from other departments on site and from other 12 plants.
13 Now, who we really targeted most often is people on 14 this team, is either people from the Quality Organization 15 or these Condition Reports analysts that in the process are 16 advisors to the managers, are the people that were trying 17 to put on this team on a rotational basis, so they will 18 carry back with them to their organizations the Lessons 19 Learned from how to improve on the work thats done on the 20 Condition Report.
21 So, the scope does include all of these 350 Restart 22 Condition Reports and Corrective Actions.
23 Next slide, please.
24 The objectives are simple in this review. Its to 25 confirm that the initially identified condition has been MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
97 1 evaluated.
2 The other objective is to track and confirm the 3 issues that were rolled to another Condition Report were 4 not lost. In any cases that we find problems in that area, 5 then we use the Corrective Action Program to document the 6 problems that we would find.
7 Next slide, please.
8 Now, as of last Tuesday, I think thats what May 27 9 was. In the system, there are identified 1,783 0350 10 Restart Condition Reports. They have associated with them 11 about 7,700 Corrective Actions. Not all of those are 12 restart related; about half of them are. But were looking 13 at quite a few nonrestart corrective actions, as long as 14 they were associated with the 350 Restart Condition 15 Reports. And the population of Associated Rollovers was 16 identified in our system as 510. As we go through the 17 reviews, these numbers can move around a little bit.
18 Next slide, please.
19 As of last Tuesday, we had reviewed 5,057 of the 20 Corrective Actions of those 7,700; and that includes the 21 Rollover Corrective Actions. In 87 percent of those cases, 22 we were able to track the, how the Corrective Action 23 relates back to the initially identified condition.
24 Approximately 13 percent of those cases were still 25 in review, because that trail is not clear to us yet. So, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
98 1 were having to do additional reviews. And this is, we 2 believe this percentage represents the difficulty that 3 people are experiencing. When I get to some of the causes 4 or some of the problems weve identified so far, were 5 starting to hone in on why that is.
6 MR. GROBE: Steve, just a quick 7 question. Are the 510 on the prior slide, the 510 8 rollovers, those are Rollover Corrective Actions, not CRs?
9 MR. LOEHLEIN: Well, actually, 10 they can be either one. When a rollover occurs, it can 11 either be a Corrective Action thats rolled over and then 12 becomes a Corrective Action in the Condition Report that 13 its now in, which is the process that Bob Schrauder 14 described. The receiving Condition Report gets a 15 Corrective Action to identify it has received that issue.
16 So, it can be a CR, it can be a Condition Report 17 thats rolled, or it can be a Corrective Action thats 18 rolled. We treated everything from the Corrective Action 19 standpoint from the back end of the process and count them 20 all there. That way we have them all, whether they were a 21 Corrective Action that was rolled or a Condition Report 22 that was rolled.
23 MR. GROBE: Okay.
24 MR. LOEHLEIN: Of that 510, 25 youll notice here, as may have been suspected, the number MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
99 1 of percentage were having difficulty tracking from front 2 to back, is higher in those that involve rollover than the 3 general population of the ones weve looked at.
4 On the next slide, what weve got so far is 5 identified concerns, is overall, whats being seen as a 6 general weakness in some cases, documenting the resolution 7 and the identified concern.
8 There are cases, for example, where the closure 9 statement says that appropriate actions were taken to 10 correct the condition, as an example. You cant tell from 11 a statement like that whether or not an appropriate action 12 actually was taken. You cant confirm it. So, for anybody 13 trying to review that on the back end, thats difficult.
14 In the cases that were examining, were finding 15 that there is evidence that correct actions were taken, but 16 theyre not taken credit for in the process. That clearly 17 is a lessons learned for people using this process, that to 18 document accurately what actually settled the issue is the 19 practice and the standard you want to have for the 20 Condition Reports.
21 So, thats been identified on the Condition Report 22 as a generic concern with a number of these.
23 Another identified concern has been, with cases 24 where the evaluation did not address the full scope of the 25 identified issue. Now, here, the most common type we found MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
100 1 here is in the Condition Reports involving valves. Most 2 commonly, if there was a valve that was expected to require 3 a repack of the stuffing blocks box. In a number of these 4 cases, the condition -- initial Condition Report had 5 additional recommended actions on it. It might be to 6 verify fasteners or to replace them.
7 In the resolution of the Condition Report, the 8 packing issue is either addressed as repacking or may 9 provide a basis for why repacking wasnt necessary, but the 10 issue about the fasteners doesnt appear in the explanation 11 as to whether it was or was not addressed. So that, we 12 have written up on a Condition Report as a generic issue to 13 make sure that has not been missed.
14 And in these cases, were finding when we spend the 15 time to track down the people that did them, in most cases, 16 were finding there is an explanation, but once again, the 17 documentation of the actions taken being sufficient is 18 what, is what people are having difficulty with in 19 reviewing the Condition Reports.
20 In these ones weve reviewed so far, we have two 21 examples so far of incorrect actions. One example in which 22 there had been an error made closing a Corrective Action to 23 a work order number. That was an incorrect work order 24 number. The work order number associated with, did exist, 25 but it was not complete yet. So, that was a mistake. We MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
101 1 identified that on a Condition Report.
2 And, we had another one we found in which a 3 procedure improvement had been recommended and was not 4 picked up in a Corrective Action. Those are two specific 5 examples we found so far.
6 MR. GROBE: Before you go 7 on, the definition of acceptable. If this Condition Report 8 involved a design engineering issue, does that acceptable 9 include a review of the adequacy of the design work, or 10 does the acceptable mean that you can track through and 11 identify the specific actions that were taken and they 12 appear to be relevant to the question?
13 MR. LOEHLEIN: I think if I 14 understand your question, Jack, youre asking about whether 15 were looking at or this team was looking at, say, the 16 adequacy of the cause evaluation associated with the 17 Condition Report; is that what youre asking?
18 MR. GROBE: Right, or the 19 acceptability of the corrective actions to address that 20 cause evaluation.
21 MR. LOEHLEIN: Right. I would 22 say, what you just described there is what were going to 23 be taking on and are doing right now in Quality Assessment 24 as part of a focused assessment. Ill talk about that in a 25 couple minutes here.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
102 1 This is strictly a review here. Im not doing it as 2 an audit-type function. So, it is a bit more superficial 3 in the sense that its really looking, when you can track 4 the end result from the initial condition; and so I would 5 say that the level of intrusiveness is not there. Its 6 really a review, and thats why we termed it that.
7 But what youre talking about is questions that we 8 are looking at in the Quality Assessment area under a 9 focused assessment. Ill talk about that in a minute.
10 MR. GROBE: Okay, thank you.
11 MR. LOEHLEIN: So, thats a good 12 lead in to the next slide, which talks about some of the 13 recent key activities that weve been observing in Quality 14 Assessment.
15 First thing I would like to comment on is the, are 16 the two tests that the other members have spoken about 17 recently; the 50 pound per square inch and the 250 pound 18 per square inch Reactor Coolant System Leakage Walkdowns.
19 In both of these cases, Quality Assessment Assessors 20 accompanied walkdown teams in Containment to directly 21 observe how this was being conducted.
22 The 50 pound test in particular was, we thought, an 23 excellent decision made by the organization, because it is 24 not required by the process in place to demonstrate return 25 to service, but it really was used by the line organization MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
103 1 to do a couple things that are going to pay off. That is, 2 that set a baseline, and also everybody involved in these 3 walkdowns had an opportunity, while the system was at a 4 very low challenge, to locate the components and make sure 5 they knew where they were. So, that was a very positive 6 thing we in QA thought.
7 The next bullet I have up there is Emergency 8 Preparedness. This is an area thats always important, the 9 emergency preparedness be in good shape. And certainly 10 with the plant focused the way it is right now, its an 11 opportunity for QA to evaluate whether the organization is 12 properly focused on this important area as well.
13 We watched and observed the activities in the last 14 few drills and exercise, and did note that the weaknesses 15 that were identified in the April drills and so forth, in 16 large part were corrected in the May exercise. So, we 17 continue to observe the activities in there, but the 18 weaknesses that did come up were being addressed by the 19 organization.
20 In the area of Observations of Technical Issues 21 Resolution, there were seeing some good decision-making 22 being made, especially in the area of the plant support 23 center and in senior management involvement. We saw a real 24 turnaround.
25 This is something I get to see firsthand, because I MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
104 1 watch a lot of management decision-making. And the 2 priorities are being established and emphasis on the 3 effective resolution of the technical issues. And this 4 focusing within this plant support center of these issues 5 seems to have had a real strong influence on getting the 6 issues focused on for resolution and clarity of the plans 7 and the challenges to success are discussed well there.
8 On the other side of the technical issues resolution 9 thing, we have continued to look at the contractor 10 oversight part of this. Right now, a lot of the action in 11 terms of contractor oversight is now in the technical 12 resolution area.
13 Some months back we talked about what QA was 14 observing in Maintenance. And early on, the contractor 15 oversight activity is really more in the engineering end.
16 And we have identified some concerns on the owners 17 acceptance process thats been used, and identified that on 18 a Condition Report. We felt too heavy reliance on using 19 contractors as part of the owners acceptance process, and 20 thats been shared with Engineering.
21 Weve identified some issues in the control of 22 purchase orders revisions, and discussed that, we briefed 23 that with the Engineering organization as well.
24 And we continue in the System Health Condition 25 Reports area also. Were watching those real carefully, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
105 1 because of the same issues that Bob Schrauder mentioned 2 about the Corrective Action Program. This is an area, 3 Jack, where were watching real carefully that the 4 Condition Reports have in them a cause analysis that 5 clearly substantiates the basis for the conclusions in the 6 cause analysis.
7 And this is an area where if the evaluator is too 8 cryptic or too brief in his description of how the solution 9 is properly resolved, it will make it unclear for posterity 10 as to why it was the right solution. So, that is an area 11 we continue to watch and we think there is still room for 12 improvement there.
13 MR. HOPKINS: Let me ask a 14 question here, Steve. The last bullet about oversight 15 vendor activities.
16 MR. LOEHLEIN: Right.
17 MR. HOPKINS: Are you just 18 referring to on-site vendor activities or also off-site 19 vendor activities?
20 MR. LOEHLEIN: The reason I added 21 that bullet and hadnt spoken to it yet is we are 22 reabsorbing quality control function back into the quality 23 assessment, quality assurance umbrella. So, I thought I 24 would add a bullet here on the type of off-site vendor 25 activities we recently been involved in; like going to, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
106 1 going out to Oklahoma to take a look at the radiographs 2 that were done on the cyclone separator for decay heat 3 pumps is one example.
4 Recently, just this past week, have been involved at 5 a vendor shop in Utah to take a look at the troubleshooting 6 thats being done on the service water valves for the 7 containment air coolers.
8 We also were recently involved down in Cincinnati 9 with Makeup Valve 3 looking at the certification of the AOP 10 parts associated with that.
11 And so, were looking now that theyre part of the 12 Quality Assurance Organization as to how we can be more 13 effective in some of the vendor oversight, some of the 14 off-site vendor oversight activities, because throughout 15 the industry there have been some issues and weve had some 16 issues with vendor supplied equipment.
17 MR. HOPKINS: Okay.
18 MR. LOEHLEIN: So, were getting 19 more active there. But I put that there, because theyre a 20 recent addition to Quality Assurance.
21 MS. LIPA: Steve, before you 22 go on, you mentioned emergency preparedness, and thats an 23 important area to us too. I neglected to mention earlier, 24 we have a baseline inspection next week that is looking at 25 your evaluated emergency preparedness exercise. They will MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
107 1 be here the full week, but theyll be focusing on that 2 exercise the one day.
3 MR. LOEHLEIN: Right. Thank 4 you.
5 MR. GROBE: I apologize for 6 going backwards.
7 MR. LOEHLEIN: Thats okay.
8 MR. GROBE: But youve keyed 9 me into a thought. At the end of every outage, youre 10 required to do an American Society Mechanical Engineer 11 Leakage Test on the Reactor Coolant System, a pressurized 12 test to look for pressure leakage. Is that normally done 13 hot?
14 MR. LOEHLEIN: I believe thats 15 done in Mode 3.
16 MR. GROBE: Im still 17 pondering the DH 11 and 12 valves and why they were 18 leaking. So, normally, those are tested hot. So, you may 19 have not seen leakage if in fact its a temperature driven 20 issue. Okay. Thanks.
21 MR. MYERS: If its very 22 minor --
23 MR. GROBE: Its minor at 50 24 pounds, but 250 pounds...
25 MR. MYERS: Let me finish. If MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
108 1 its minor and it stays dry, which you find more on that, 2 and it stays that way on up, then those valves that were in 3 it, was close.
4 MR. GROBE: Right. So, you 5 may not have seen it.
6 MR. MYERS: Thats correct.
7 MR. GROBE: All right.
8 MR. LOEHLEIN: Okay, next slide, 9 please.
10 Under some of the current activities, an important 11 one is this Focused Assessment, Jack, that we talked about, 12 or I mentioned just a few minutes ago, a Focused Assessment 13 on Corrective Action Program. Thats because we know that 14 the organization made some stiff changes to the process on 15 March 1st.
16 The early data we had did not show improvement in a 17 couple key areas on implementation; specifically in the, we 18 didnt see improvements yet in the numbers on the quality 19 of the cause analyses and some other important parts of the 20 process.
21 And the CARB data that you saw, Corrective Action 22 Review Board data, showing their rejection rate also, we 23 have a lot of indicators that this was an area deserving of 24 a Focused Assessment.
25 What we do in a case like this, its more like the, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
109 1 the older common, done commonly years ago, used to call an 2 audit, a checklist type, where we have a number of things 3 well be looking at. Well be interviewing people that are 4 involved in the process, that includes both managers and 5 lower level interviews. Well continue to review the 6 Corrective Action Review Boards, what theyre doing.
7 Were going to also do a lot of random selection of 8 Condition Reports from various categories, and well sample 9 rollovers as well, to see that they have actually been 10 completed through the process and all the steps the way 11 they should have been, and take a look at what that data 12 tells us. And well also verify compliance with the 13 program itself. So, that is something were doing right 14 now in this quarter.
15 Well continue in the next few months over the next, 16 during the summer, continuing to do drills in the emergency 17 preparedness area, well continue to observe those.
18 Then I put the last bullet down. Its just sort of 19 a general kind of things that we do all the time and 20 incorporate into our daily oversight activities, as the 21 oversight of Management Decision-Making, Safety Culture, 22 Radiation Protection and there is a lot of activity right 23 now on the regulation changes for our Security Program.
24 MR. HOPKINS: Just mentioning a 25 Security Plan, I would think a lot of those changes would MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
110 1 be generic to the other FENOC plants also.
2 MR. LOEHLEIN: Thats correct.
3 MR. HOPKINS: So, youre in 4 contact then with the other FENOC QA Organizations?
5 MR. MYERS: Absolutely.
6 MR. LOEHLEIN: Well, I know that, 7 we talk every day, but I cant, you know, security being 8 safeguard, we dont talk openly about a lot of things, but 9 yeah, we do communicate with our, we communicate daily with 10 QA from the other two sites, and one of the topics that is 11 appropriate is the security part of that.
12 MR. MYERS: We also have a 13 lead person, our corporate office for security issues.
14 MR. HOPKINS: I was just 15 concerned that, you know, that I figured a lot of the 16 changes would be the same from plant to plant; and I wanted 17 to make sure the QA Organizationss are --
18 MR. LOEHLEIN: That is true, and 19 that kind of conversation goes on, Jon, every time there is 20 a projected change in security level as well.
21 MR. HOPKINS: Okay.
22 MS. LIPA: Just to give a 23 time check, we have about 15 minutes for the next two 24 sections.
25 MR. MYERS: Okay.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
111 1 MR. LOEHLEIN: Mike Ross is going 2 to take over.
3 MR. ROSS: Thank you, Steve.
4 Good afternoon. Our Davis-Besse Plant Support 5 Center is in full operation. The following items have been 6 completed. We developed an issues list and it currently 7 has about 84 items on it. These issues are being reviewed 8 in detail against the standard checklist to identify 9 restart issues and obtain our agreement that the resolution 10 is a quality and lasting type fix.
11 An Action Item Database has been created with owners 12 and due dates. And the issues identified as needing 13 decisions or extra assistance are being brought to the 14 management team in a timely manner.
15 As clarity is brought to new issues, fragnets and 16 part needs are developed and owners assigned, they are 17 transferred to the Outage Control Organization for field 18 implementation.
19 To ensure quick resolution to supply issues, the 20 Corporate Director Supply Chain has been stationed on site 21 and is part of the support center.
22 Listing of modifications has been developed with 23 field implementation dates and is being tracked and 24 prepared for field execution.
25 The Condition Report Database has been reviewed to MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
112 1 identify those issues not yet through with the evaluation 2 process that may be restart. This will assure no hidden 3 restart issue resides in that Corrective Action Database.
4 We do believe we know the issues that need to be 5 resolved.
6 Next slide.
7 Our focus is on early identification of new issues 8 and proper resolution of existing issues. This includes 9 delivery of a quality resolution to the field 10 organization.
11 Several issues are receiving extra focus. These are 12 High Pressure Injection Pump Modification, thats already 13 been discussed by Bob Schrauder. The Electrical Transient 14 Analysis and the Safety Feature Actuation System Relays.
15 Both have been addressed by Jim Powers.
16 Other issues that are receiving extra focus; the 17 Air-Operated Valve Program. We have identified some 18 emergent work in this area, with identification of three 19 new work items. This is the addition of air reservoirs for 20 service water valves 1428, 1429, and 1434. It appears this 21 will revolve without significant impact.
22 The Plant Block Walls Seismic and Tornado Loading 23 issues. As a minimum, we will need a procedure change to 24 resolve one issue dealing with the tornado differential 25 pressure, and additionally a modification to the boric acid MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
113 1 tank room door to address the seismic ability of a wall 2 during a postulated line break in the area.
3 The Thermal Overload Bypass for Safety-Related 4 Motors issues. It appears we will have some field work for 5 that item and a full understanding of and resolution for 6 its being developed.
7 Additionally, we identified two modifications. They 8 are designated, that are designated for restart. The 9 Containment Spray Pump Cyclone Separator addition. This is 10 the addition of a separator to ensure postulated sump 11 debris does not affect the containment spray pump seals. A 12 Boron Precipitation modification has been identified. This 13 is an enhanced method of ensuring the backup capability to 14 provide Boron precipitation flow after a postulated 15 accident.
16 It should be noted, both of these items add 17 significant safety margin to our plant. These items do not 18 impact our overall schedule.
19 In conclusion, we believe we have scrubbed through 20 the present issues and have a good understanding of what 21 needs to be done. We continue to believe all issues are in 22 fact resolvable.
23 MR. HOPKINS: Let me ask, Mike, 24 the Boron Precipitation Modification, is that considered a 25 restart issue?
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
114 1 MR. ROSS: Its a Mode 2 2 issue.
3 MR. HOPKINS: Okay, thank you.
4 MR. GROBE: Just one quick 5 question. Ive heard these two issues discussed; the 6 Cyclone Separator Containment Spray and Boron 7 Precipitation. For quite awhile now theyve been on the 8 engineering issues list. What causes something to get 9 added to the modification list?
10 MR. ROSS: We go through our 11 checklist to verify that it has an issue. We bring it to 12 senior management. We get a firm decision early. And we 13 put it through the process and get it started. Thats the 14 value we bring to the organization.
15 MR. GROBE: Okay, and you 16 indicated that you also reviewed other CRs, and I assume 17 that covers everything thats on Jims Engineering Issues 18 list?
19 MR. POWERS: Thats correct.
20 MR. GROBE: And identified 21 other key issues that could be risk items.
22 MR. ROSS: Thats correct.
23 We probably started with Jims Engineering Issues.
24 MR. GROBE: Okay, good.
25 MR. ROSS: If there is no MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
115 1 more questions, I would like to turn it over to Mike 2 Stevens for Schedule Milestones.
3 MR. MYERS: Why dont we skip 4 over that one. Lets go to the Performance Indicators. I 5 think were running out of time, correct?
6 MR. GROBE: Okay. I mean, 7 Clarks gotten skipped on multiple other occasions.
8 MR. PRICE: Okay, thank you, 9 Mike.
10 Good afternoon. Can you hear me?
11 I would like to conclude our presentation today with 12 an overview of our progress on the O350 Restart Checklist 13 that Christine presented at the beginning of the meeting.
14 Then take a quick look at a couple of our charts to show 15 our overall restart progress on our restart required 16 actions.
17 The next three charts provide a summary of our 18 status on the 0350 Panels Restart Checklist Items. These 19 charts are colored to show where we are in the discovery 20 and implementation actions.
21 Youll see, and also if you have trouble reading, I 22 apologize on your handout, I know black and white is very 23 difficult to discern between the colors. There is a chart 24 over on your righthand side on the wall that also lays this 25 out.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
116 1 Youll see on each chart that we are complete with 2 our discovery plans for each of the Checklist Items. So, 3 Ill mainly focus my discussions on progress on our 4 implementation plans.
5 On Checklist Item 1A and 1B. They both address our 6 technical and nontechnical root causes and other root 7 causes weve done in the Management/Human Performance 8 area. We completed all our 0350 Restart Actions under 9 these two items.
10 Checklist Item Number 2, A and B, address the 11 reactor vessel head replacement and our restoration of the 12 containment vessel. 2A is colored in light blue.
13 Basically, its on hold waiting for our Mode 3 full 14 pressure test. And 2B is essentially complete, waiting on 15 plant conditions to allow completion of a few local leak 16 rate tests that we have remaining.
17 In the 2C area, that deals with restoration of our 18 containment systems, structures, and components. And as 19 Mark Bezilla discussed at the beginning of our 20 presentation, were closing in on final containment closure 21 and turnover of the building and systems to Operations.
22 Mark addressed some closure packages that we still 23 have that are being worked on in the discovery area; and 24 well have those done hopefully by the end of this week.
25 On Checklist Item 2C-1, thats in our Containment MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
117 1 Emergency Sump, which weve completed. We discussed that 2 project several times, and in the meetings. And all work 3 on that, and the inspection activity is complete. We have 4 a couple follow-up items that were working on as a result 5 of the inspection, and should have those to the inspector 6 this week.
7 Our corrective actions for Checklist Item 2D, which 8 looks at systems containing boric acid outside of 9 containment building are also nearing completion.
10 If there is no questions on that slide, Ill move to 11 the next one.
12 The next slide lists ten of our safety significant 13 programs that are on the O350 Checklist. As you can see, 14 we have completed and identified, the identified corrective 15 actions in each of the implementation plans for the first 16 eight programs. Those are either inspection complete or 17 continuing with ongoing NRC inspection activity.
18 The Radiation Protection Program actions are 97 19 percent complete, and which is the 3H line item. They will 20 be totally complete the first of July, which will support 21 an NRC inspection that will be starting on July 14.
22 Then, our final and most recent Checklist Item, 23 which is 3I, which is underway, is the Corrective Action 24 Plan to address Checklist Item that deals with completeness 25 and accuracy of NRC records and submittals. And we are MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
118 1 currently working on that action plan, which essentially 2 includes procedures for the validation of NRC 3 correspondence.
4 Training for our site employees; we have our 5 training program developed for that and now we need to 6 deliver that to our employees.
7 And extent of condition review to determine what we 8 may have submitted on any previous correspondence in the 9 past that may not have been totally complete and accurate.
10 That is just a starting and were putting that plan 11 together.
12 Next slide, please.
13 Okay. In Item 4A-B, those contain Corrective 14 Actions that were identified through Management/Human 15 Performance Improvement Plan. We continue to make good 16 progress in this area, and as Lew discussed earlier we have 17 more work do to, but we have that plan scheduled and should 18 be getting through that in the next month or so.
19 Our Checklist Item 5 covers our Readiness For 20 Restart in both Systems and Operations Readiness. Weve 21 completed 91 percent of the Condition Report Evaluations 22 and Corrective Actions that have been identified through 23 our System Health and our Design Calculation Resolution 24 Plan.
25 We also continue to enhance our Restart Readiness MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
119 1 Review Practice that we discussed earlier to ensure that we 2 have comprehensive review of our readiness to make mode 3 changes and ultimately for plant restart.
4 Then we have Checklist Item 5D, which is the test 5 program which is 72 percent complete, which Mark Bezilla 6 also addressed earlier, where we have completed so far our 7 50 pound and 250 pound test of the Reactor Coolant System.
8 Checklist Item 6 covers the licensing issues 9 associated with the new reactor vessel head, and is 10 complete, including the inspection activity, and closed 11 out.
12 Then Item Number 7 contains our Confirmatory Action 13 Letter; our responses, which are all progressing, and also 14 in that area we cover our final Integrated Restart Report 15 that we are currently working on.
16 If there are no further questions on that, Ill 17 move on to the next final two slides.
18 Okay, these final two slides show at a high level 19 our overall progress on our actions weve identified as 20 required for restart. Many of these actions go well beyond 21 the requirements of the O350 Checklist. As a matter of 22 fact, approximately 60, we have approximately 60 percent of 23 our total restart required Condition Reports and Corrective 24 Actions, are actually over and above the 0350 identified 25 Checklist Items.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
120 1 The first slide shows the work-off of our Condition 2 Report Evaluations for the Condition Reports that we have 3 classified as restart during our entire restart effort. As 4 you can see, were closing in on nearing completion of 5 those evaluations. They leveled off a little bit, but 6 theyre leveled off at a manageable level.
7 We continue our daily review classification of 8 Condition Reports for restart by the Restart Station Review 9 Board, which we discussed in previous meetings. Some of 10 the recent additions that show up in the, these evaluations 11 or Condition Reports are the results that were discussed 12 earlier from our 50 pound and 250 pound test, and our 13 walkdowns of the Reactor Coolant System that Mark Bezilla 14 discussed at the beginning of the presentation.
15 And approximately 100 of the Condition Report 16 Evaluations identified here out of roughly the 300 17 remaining to go, are to support the first mode change to 18 Modes 4 and 3. As Mark Bezilla discussed earlier, those 19 are all scheduled out now with due dates that support the 20 milestones.
21 The final slide shows our work-off in our Corrective 22 Actions that have been classified as restart from our, from 23 the previous Condition Reports that I just talked about.
24 Again, all the Corrective Actions have scheduled due 25 dates.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
121 1 We currently have, as you can see here, around 800 2 that are open. Out of those, 397 of those open Corrective 3 Actions are scheduled to complete to support our first Mode 4 4, and changes to Mode 4 and 3. And so, were working 5 well, and have that, have that all laid out.
6 In conclusion, I would like to say that we are 7 making good progress, and we have confidence that we will 8 complete both our 0350 and the non0350 Restart Actions in 9 support of our Restart Milestones.
10 Are there any questions?
11 MS. LIPA: Thank you. No.
12 MR. PRICE: Okay. If you 13 dont have any, Ill turn it back over to Lew for closing 14 comments.
15 MR. MYERS: The past month has 16 been pretty significant. Weve had, we started out last 17 meeting with several organizational changes. We think 18 those organizational changes have been very effective for 19 us.
20 We changed our direction, which had a significant 21 impact on our schedule. We focused on modification. Weve 22 already test ran the pump. Pulled the impeller on the one 23 A pump. Were planning to pull the Number 2 pump now.
24 We continue to look forward to the, lots of 25 activities in the Management/Human Performance area, MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
122 1 especially in the Safety Culture area in the next couple of 2 months.
3 We were very pleased with the performance of our 4 operators in the 250 pound test; and the overall, with the 5 performance of the plant, even though there is some work 6 for us to do there.
7 The modification of the HPI Test, we believe will be 8 successful. And well be through that in July, early July, 9 allowing us to, to be ready for Mode 4, and Mode 4 and Mode 10 3 pressure tests in the middle of July. And shortly after 11 that, well be, from a plant standpoint, be ready to, look 12 at restart of the unit, which right now we talk about the 13 first part of August, from our perspective.
14 We demonstrated consistently that were able to work 15 off the corrective actions at about 140 a week. And 16 consistently now, if you look at our back logs and all, it 17 looks like the middle of July is easily done for Mode 4.
18 Checklists; Item Number 5 indicates were about 91 19 percent complete with activities for Restart.
20 Once again, you know, I think we demonstrated today, 21 we made good progress. We ran all four Reactor Coolant 22 Pumps for a couple of hours. We drew a vacuum -- put a 23 bubble in our pressurizer. Didnt draw a vacuum. And went 24 through a 250 pound test that performed well.
25 We got, we really bounded the work. Now, I think MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
123 1 Mike Rosss group is going, did an excellent job of 2 bounding the work, and laying the work out on the diesel 3 air dryers. He got that lined out, assuring the parts are 4 here. We know what the work is.
5 So, we really feel very solid right now about our 6 ability to reach the schedule of activities at the first 7 part of August.
8 So, with that being said, we continue to make 9 progress, and we look forward to our next meeting. Thank 10 you.
11 MS. LIPA: Thank you, Lew.
12 Well, that ends the business portion of our meeting 13 today then. What were going to do is take a ten minute 14 break, and well go to public comments and questions.
15 MR. GROBE: Lew, I need to 16 excuse myself. I have a meeting tomorrow morning which 17 requires me to fly out tonight. Bill will continue 18 chairing the meetings tomorrow afternoon and this evening.
19 (Off the record.)
20 MS. LIPA: Okay, were ready 21 to begin with the public comment/questioning period. We 22 would like to open up the microphone for anybody who has a 23 question for us or a comment to address for the NRC folks 24 here.
25 Jack Grobe did have to leave, but Bill Ruland, the MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
124 1 Vice Chair, and the rest of us are still here.
2 What we would like to do is start with local members 3 of the public first, and then we would like each person to 4 limit their time to five minutes. And, at the podium we 5 have a sign-in sheet. And, if you want us to follow-up 6 with you, feel free to put your phone number, that way if 7 there is anything that we didnt fully address, we can 8 contact you later.
9 So, is there anybody who would like to come up and 10 ask a question or give us a comment today?
11 Are there any members of the public that are not 12 local that would like to come up?
13 MS. RYDER: Hi. My name is Amy 14 Ryder. Im with Ohio Citizen Action. I just have a few 15 questions.
16 One is that, I might have missed this earlier in the 17 meeting, because I was late, but if the Reactor Pressure 18 Test does not identify conclusively where the additional 19 rust is coming from, what happens next?
20 MS. LIPA: You talking about 21 on the lower part of the vessel?
22 MS. RYDER: Right.
23 MS. LIPA: Well, right now, 24 the NRC is evaluating Licensees plans on how theyre going 25 to test that and how theyre going to determine it. So, we MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
125 1 should know more before that test. And then once we get 2 the results of that test, well be able to figure out what 3 the information means. But I really cant tell you yet how 4 were going to process that information.
5 MS. RYDER: Will the source of 6 that rust have to be identified before restart is completed 7 conclusively?
8 MS. LIPA: The source of the 9 rust. Well, I think what well be doing is making sure we 10 understand the Licensee evaluation of it and what it means 11 and whether that makes sense and whether there is an 12 indication of a leak. Thats my understanding right now 13 where were headed with that.
14 MS. RYDER: So, there is a 15 possibility that it could restart not knowing where that 16 rust came from?
17 MS. LIPA: Well, I dont 18 really want to say that right now, but I think as we get 19 closer to that test and after that test, we will be able to 20 answer more fully your questions on that.
21 Do you have any comments on that, Bill?
22 MR. RULAND: The key criterion 23 is that the reactor itself has no unidentified leakage, not 24 that the rust stains have or have not been identified.
25 MS. RYDER: Okay.
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126 1 MR. RULAND: So, theoretically, 2 there could be some possibility they would not identify the 3 rust stains, or excuse me, the Licensee will identify the 4 rust stains. But if we were satisfied that the Licensee 5 did a sufficient test to make sure there was no 6 unidentified leakage --
7 MS. RYDER: Leakage.
8 MR. RULAND: -- we wouldnt 9 have any problem with that.
10 MS. RYDER: Okay.
11 MS. LIPA: No, actually its 12 pressure volume leakage.
13 MR. RULAND: Right.
14 MS. LIPA: Pressure volume 15 leakage is the criteria.
16 MS. RYDER: Okay. My second 17 question is, whether or not the OI Investigation Report 18 will be issued before restart is permitted.
19 MS. LIPA: I cant address 20 that. Thats all I can say.
21 MR. RULAND: The OI Report will 22 be issued when the OI Report is ready.
23 MS. RYDER: Will you allow the 24 plant to restart if that OI Report is not completed; I 25 guess maybe is the more accurate?
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127 1 MR. RULAND: Thats all I can 2 say; the OI Report is issued when its issued.
3 MS. RYDER: Right. I 4 understand you dont have control over when thats issued, 5 but will the panel want to know what the report says before 6 you allow FirstEnergy to restart Davis-Besse?
7 MS. LIPA: I think thats a 8 question well have to address at a later time too, Amy.
9 MS. RYDER: Okay. Thanks.
10 MS. LIPA: Does anybody else 11 have any questions for us?
12 Okay. Well, just a few things, then Ill check one 13 more time if there is anybody else.
14 We will be returning tonight at 7 p.m. to give a 15 summary to anybody who wasnt here; and if anybody wants to 16 come back and ask questions, thats fine.
17 And then next month, July 9th, our public meeting 18 will be at the Oak Harbor High School. And were going to 19 go for the same times with an afternoon meeting and evening 20 meeting.
21 Then, were also holding a meeting on June 19th in 22 headquarters, but well have bridge lines for folks that 23 want to call in and listen to that meeting. And the June 24 19th meeting well focus on the high pressure injection 25 pump.
MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
128 1 Was there anyone else that came up with a question 2 while I was talking?
3 Okay. Well, then thank you for coming. Good day.
4 (Off the record.)
5 ---
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MARIE B. FRESCH & ASSOCIATES 1-800-669-DEPO
129 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 13th 10 day of June, 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