ML120541135
| ML120541135 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/22/2012 |
| From: | NRC/SECY |
| To: | |
| References | |
| Download: ML120541135 (72) | |
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UNITED STATES OF AMERICA U.S. NUCLEAR REGULATORY COMMISSION BRIEFING ON FORT CALHOUN FEBRUARY 22, 2012 9:00 A.M.
TRANSCRIPT OF PROCEEDINGS Public Meeting Before the U.S. Nuclear Regulatory Commission:
Gregory B. Jaczko, Chairman Kristine L. Svinicki, Commissioner George Apostolakis, Commissioner William D. Magwood, IV, Commissioner William C. Ostendorff, Commissioner
2 APPEARANCES Omaha Public Power District (OPPD):
W. Gary Gates Chief Executive Officer and President David Bannister Vice President, Chief Nuclear Officer Fort Calhoun Station John Herman Division Manager-Nuclear Engineering OPPD NRC Staff:
Bill Borchardt Executive Director for Operations Elmo Collins Regional Administrator Region IV John Lubinski Deputy Director Division of Inspection and Regional Support NRR Troy Pruett Deputy Director, Division of Reactor Projects Region IV
3 1 PROCEEDINGS 2 CHAIRMAN JACZKO: We'll now turn to the regular part of the 3 meeting. Before we begin, though, I would just like to make a note. I believe, 4 you can correct me if Im wrong Steve, I think this is your last public meeting. So 5 I just wanted to say, for those of you who don't know, this will be Steve's last 6 public Commission meeting as General Counsel, so I just wanted to say a few 7 words about Steve. He's been with the federal service for 34 years, and he's 8 accepted, what will be Im sure, a very interesting position as counsel at the 9 OECD in Paris, working at the Nuclear Energy Agency. I've known Steve over 10 seven years, and I have certainly appreciated his expertise, experience, and his 11 steady professionalism. I think he has demonstrated tremendous leadership as 12 the General Counsel in the long line of tremendous General Counsels that we've 13 had at this agency. So I want to thank you for all your service to the agency and 14 to the American people for your many, many decades of public service, and for 15 the work you'll continue to do in between learning French and eating wonderful 16 food.
17 STEPHEN BURNS: Learning French will be the challenge. No, I 18 appreciate that Mr. Chairman, it's been, as I said, I started at the agency in 1978, 19 a few months before the Three Mile Island accident, and I think -- my joke has 20 always been I wanted to be a communications lawyer, but then when I found the 21 Atomic Energy Act was based on the Communications Act in 1934, I became a 22 communications lawyer for all these years, but it's been an interesting thing --
23 one of the interesting things has been working with the Commissions over the 24 years, for the last 25 years, and working with the staff as well as with the lawyers 25 in my own office and others, so I think you for those nice words.
4 1 CHAIRMAN JACZKO: Sure, of course. Comments from --
2 COMMISSIONER SVINICKI: Yes, Mr. Chairman, I just -- Steve, 3 you're moving on to something that I think is very fascinating, there's a lot 4 happening in the international arena, and so I want to wish you well, and Im sure 5 that everyone will continue to benefit from your contributions in that capacity, so 6 good luck.
7 COMMISSIONER MAGWOOD: Well, as a former chairman of the 8 NEA's steering committee, I can tell you you're going to be working with a great 9 organization, and the fringe benefits of excellent restaurants within walking 10 distance of anywhere you go is not to be overlooked. So I look forward to 11 coming to Paris and visiting you once you learn where all the good restaurants 12 are.
13 [laughter]
14 COMMISSIONER APOSTOLAKIS: Good luck in your endeavors, 15 Steve.
16 STEPHEN BURNS: Thank you.
17 COMMISSIONER APOSTOLAKIS: I think you will enjoy it there.
18 STEPHEN BURNS: Thank you.
19 COMMISSIONER OSTENDORFF: Steve, I've enjoyed working with 20 you, and wish you all the best. Thanks for your service.
21 STEPHEN BURNS: Thank you.
22 CHAIRMAN JACZKO: Well, with that, we'll turn to the subject of 23 today's meeting. The staff and I would note that this is the first -- this is another 24 day of firsts or some lasts, and some firsts -- this is a first in a newly renovated 25 Commission hearing room, so that explains the new carpet smell. So -- but it
5 1 looks very nice, I think it came out very nice, so thank you Annette for your work 2 to get that done. Bill, do you want to get started then?
3 BILL BORCHARDT: Sure, thank you Chairman. Yeah, I'd also like 4 to add my thanks to the Office of Administration that got this room completed 5 yesterday, and it's in good shape for today's meeting, so I'd like to congratulate 6 them for a lot of hard work on a very tight time schedule, and on behalf of the 7 staff to add our thanks to Steve for his many years of service; we've had a very 8 long and productive relationship with Steve, as have many of the senior 9 managers, and in fact all of the staff within the agency, so wish him the very best 10 of luck and we'll be seeing him in the next few years in a different capacity.
11 So today we're here to discuss the NRC's oversight of Fort 12 Calhoun. A plant that enters Column IV of the reactor oversight process action 13 matrix, which is the multiple repetitive degraded cornerstone column, receives a 14 degree of increased oversight and attention from the staff, and from the 15 Commission.
16 The annual agency action review meeting and the procedures that 17 govern it was revised in 2009 to ensure that once a plant enters into Column IV, 18 that within six months it receives -- it is the subject of a Commission briefing 19 where the licensee comes in to describe their plans and activities related to 20 improving facility performance. This was done, this timing, in order to make sure 21 that the public and all stakeholders understood that we didn't wait for annual 22 assessments or annual reviews to revise and adapt our inspection and oversight 23 program to changing performance within the licensees, so we have continuously 24 been modifying and adjusting the resources, and you'll hear from Elmo and the 25 rest of the team here shortly about what we've done in that degree.
6 1 Fort Calhoun is located near Omaha, Nebraska, and it entered 2 Column IV of the action matrix on September 1st of 2011. The meeting was 3 scheduled shortly thereafter in order to brief the Commission on the performance 4 issues in accordance with our management directives. Since that time, however, 5 performance challenges continue to emerge at Fort Calhoun, most notably the 6 flooding situation in the Midwest, and the staff, on December 13th of 2011 7 transitioned out of the normal reactor oversight assessment program to Manual 8 Chapter 0350, which is oversight of reactor facilities in a shutdown condition, due 9 to significant performance and operational concerns. This is the first plant to 10 enter into an 0350 process in just short of 10 years, the last one was Davis-11 Besse. Can we go to slide three, shows the agenda for today's meeting, and 12 with that I will turn the presentation over to Elmo.
13 ELMO COLLINS: Slide four please. Mr. Chairman, Commissioners 14 -- Mr. Chairman, Commissioners, good morning. Slide four. This morning I plan 15 to provide a summary of the events and the regulatory actions that preceded us 16 and leading up to this meeting. Slide five.
17 In 2010 the NRC finalized a finding of significance; it was classified 18 as yellow significance in the reactor oversight program. This dealt with an 19 inadequate flood strategy that was identified by NRC inspectors. In 2011 Fort 20 Calhoun station was in the process of preparing for the 95002 inspection which 21 follows a plant that enters the degraded cornerstone of the reactor oversight 22 process. Twice during 2011 the licensee performed self-assessments, and both 23 times the self-assessments determined, and to the licensee's credit they 24 reported, they were not yet ready for us to come on site and perform our 25 supplemental inspection.
7 1 Ultimately, that inspection was scheduled for June of 2012, 2 however, as we all know, in advance of that, in May, we received notification the 3 licensee and the NRC, that the Corps of Engineers planned to increase the 4 release rates from the dams of the Missouri River system to unprecedented 5 levels, and the projected water level at the Fort Calhoun station that they were 6 given by the Corps of Engineers indicated that they were going to have to deal 7 with water on site at the station.
8 On June 6th, the licensee declared an unusual event. The waters 9 were approaching 1,004 feet, which is the grade level at the site, which is also 10 the emergency action level for an unusual event at Fort Calhoun station. On 11 June 7th, the licensee experienced another event that was a fire and safety 12 related 480 volt breakers, which -- for which the licensee declared an alert, and 13 the agency entered the monitoring mode. We'll talk a little bit more about that 14 later, but just to note it here, and later that day the licensee exited the alert.
15 I'll note that in advance of the rising waters at Fort Calhoun station, 16 the licensee took a number of substantial actions to prepare the site to respond 17 to the high water levels. Some of these were strengthened actions and added 18 actions from NRC's finding, yellow finding that the licensee had developed, and 19 they took actions even beyond that, I'll add.
20 The Nuclear Regulatory Commission responded to this. We 21 instituted 24/7 site coverage with the rising water levels at Fort Calhoun. We 22 verified the actions that the licensee put in place and the flood barriers as part of 23 our inspection preparation, and we received, I'll just note, significant assistance 24 from the other Regions, and the inspectors that enabled us to carry out this 24/7 25 monitoring for an extended period of time.
8 1 So we were in the emergency response mode, the licensee was in 2 the emergency response mode, the water had exceeded grade level at the site, 3 and so NRC, at this time, deferred the conduct of the routine supplemental 4 inspection for the yellow finding while the site was in emergency response.
5 The water peaked at about 1,006 feet, 11 inches in July of 2012, 6 and we conducted a public meeting in Omaha with the licensee as the waters 7 started going down to try to understand their plans, their actions post-flood for 8 inspections, tests, verifications of equipment and the site to make sure that the 9 facility was properly prepared for return to power, and this resulted in the 10 substance of our Confirmatory Action Letter that we issued in August of 2012. It 11 had some other actions in there for equipment problems, but it was primarily 12 aimed at what was needed to be accomplished because of the flood.
13 So at the same time period, coincident with the flood and the 14 Confirmatory Action Letter, Region IV was finalizing a finding of significance 15 associated with the reactor protection system. It turned out to be a white 16 significance, and this combined with the yellow flood finding and being in the fifth 17 quarter of degraded cornerstone, NRC's assessment determined that Fort 18 Calhoun Station performance warranted the highest level of oversight provided 19 for by the reactor oversight process, and that's Column IV.
20 Region IV made an organizational change to ensure we provided 21 the specific oversight for the conduct of the inspection programs, and to provide 22 for the ongoing safety assessment that Bill alluded to. We established a 23 separate branch. Fort Calhoun is the only branch in that part of the division of 24 reactor projects.
25 The water levels subsided and licensee exited the emergency
9 1 conditions, so in September we were back on site. We needed to do some 2 reactive inspections, primarily -- most significantly with the fire that had occurred 3 on June 7th, so we conducted a special inspection to review that, to try to 4 understand the significance, and there were several performance deficiencies 5 which were identified in this inspection, but most importantly, I think at this time, 6 we're still developing -- that inspection report is in final draft, and we're finalizing 7 that for issuance, but the event, as we gathered the circumstances and did a risk 8 assessment of that event, it became apparent to us that it's likely -- in all 9 likelihood would be considered a significant operational event. We were coming 10 up with conditional core damage probabilities in excess of 10 to the minus 4.
11 And so as part of our ongoing assessment process, the licensee 12 had been shut down for over six months, the efficacy of the performance 13 indicators starts to come into question when licensee's are shut down for 14 extended periods of time. Our ability to meaningfully complete the baseline 15 inspection program to give us meaningful performance information was called 16 into question, and so we once again considered what is the appropriate level of 17 NRC oversight, what's the proper level for NRC engagement at this facility, and 18 now we know that the June 7th fire was a significant operational event, and 19 Region IV, in conjunction -- in consultation with NRR and with the Executive 20 Director for Operations, decided that Manual Chapter 0350 process was the most 21 appropriate oversight guidance for us to use at Fort Calhoun Station. One of the 22 benefits of this process is it will provide for us additional steps to verify that all the 23 actions are taken for plant safety before the plant returns to power.
24 I believe the number of events and the significance of the events 25 that we've seen at Fort Calhoun Station indicate that there are significant
10 1 performance issues that need to be addressed by the licensee, and while I think 2 to date a comprehensive assessment of everything is not yet finally been 3 completed, we do know some things that are challenges at Fort Calhoun Station 4 performance. The first of which is maintenance and design, and I say this 5 because of the insights we got from the special inspection after the June 7th fire.
6 Licensee review and NRC inspection trace the roots of the causes of that fire 7 back to a design modification which was accomplished almost two years ago.
8 There were installation difficulties; testing was not done to test the 9 resistance of the contacts, and it actually resulted in a configuration where 12 10 safety related 480 volt breakers either had or were susceptible to having a high 11 resistance contacts, and so we -- those issues need to be understood.
12 The corrective action program has weaknesses, and there are 13 organizational effectiveness weaknesses at the site that also need to be 14 addressed, so the licensee has a number of plans in place, I believe you will hear 15 from them, and we will use those plans to inform us for our restart checklist to 16 make sure we address the right items for safety before the plant returns to 17 power, so thank you. I'll turn it over to John; he's going to summarize 0350 18 process.
19 JOHN LUBINSKI: Good morning, Im John Lubinski, Im the vice-20 chair for the Fort Calhoun Station Manual Chapter 0350 oversight panel, and I'll 21 discuss a general overview of the 0350 process. The purpose of Manual 22 Chapter 0350 is to establish and provide enhanced oversight and assessment of 23 licensee performance during the shutdown through restart, and until it is 24 appropriate to return the plant to the routine reactor oversight process. Oversight 25 includes an enhanced inspection plan that follows several aspects of the ROP;
11 1 specifically oversight utilizes the baseline inspection program to the maximum 2 extent possible. In those cases where the baseline does not provide adequate 3 assurance that performance issues are appropriately addressed, enhanced and 4 supplemental inspections are used. Plants are not included in the reactor 5 oversight progress action matrix when under 0350; however, performance 6 deficiencies are evaluated using the appropriate aspects of the significance 7 determination process.
8 For entry conditions, in general, into Manual Chapter 0350 9 Oversight, there are four conditions that must be met. First, plant performance is 10 in Column IV or V of the action matrix or a significant operational event had 11 occurred. Secondly, the plant is in a shutdown -- is shut down, or the licensee is 12 committed to shutdown to address the performance issues. The NRC has a 13 regulatory hold in effect such as an order on the licensee or the licensee is 14 committed to not restart such as under a Confirmatory Action Letter, and finally, 15 once all these three conditions are met, NRC management makes a decision that 16 Manual Chapter 0350 Oversight is appropriate based on the conditions of the 17 plant and the licensee performance.
18 The process followed under Manual Chapter 0350 includes the 19 establishment of an oversight panel to develop criteria for oversight, and to verify 20 licensees corrective actions are adequate; development of a process plan that 21 guides the oversight panel through its activities; development of a restart 22 checklist which identifies all the items and issues that need to be addressed prior 23 to plant restart; and ensures open and transparent communication to external 24 stakeholders throughout the process. Regarding termination of Manual Chapter 25 0350, oversight under Manual Chapter 0350 continues after plant restart for a
12 1 period of time recommended by the oversight panel, and approved by the 2 Regional Administrator. When appropriate, the oversight panel will recommend 3 termination of Manual Chapter 0350 and return to the routine reactor oversight 4 process and inclusion back into the appropriate column of the action matrix.
5 That's a general overview of the 0350 process, I'll now turn to Troy who will talk 6 specifically about Fort Calhoun issues associated with 0350.
7 TROY PRUETT: Thank you John.
8 CHAIRMAN JACZKO: Take your time, whatever you need.
9 Technically, you run out of time, but don't worry --
10 TROY PRUETT: I thought I got to stop talking when it hit zero.
11 [laughter]
12 CHAIRMAN JACZKO: Keep talking until we tell you to stop talking.
13 [laughter]
14 TROY PRUETT: Well, good morning Mr. Chairman and 15 Commissioners. Again, my name is Troy Pruett and Im the chairman of the Fort 16 Calhoun Station oversight panel, and what I wanted to talk about today was 17 where we are in the process, actual process, at Fort Calhoun Station. As 18 mentioned earlier, the first step was to identify the panel members, and we did 19 that on December 29th, I was named as head chairman, John the vice-chairman, 20 and then the other members are comprised of Region IV staff and staff from 21 NRR, so we have a diverse team of headquarters and regional personnel.
22 Next step was to sign out a panel charter, we did that on January 23 12th, and the panel charter, at a real high level, listed the activities that the 24 panel's responsible for: communications with externals, developing an agency 25 record, doing a comprehensive safety assessment and then reaching a
13 1 determination that the facility's safe to restart, making that recommendation for 2 the Regional Administrator and then to be able to provide some level of 3 assurance that the facility, once restarted, if warranted, can operate safely.
4 The next part of the process was to develop a process plan, and we 5 recently completed that activity. It essentially follows all the elements that are in 6 Manual Chapter 0350, highlights all the different activities that are in that Manual 7 Chapter for us to accomplish. It provides a little bit more detail about the types of 8 internal/external stakeholders we need to be communicating with, and how 9 frequently we need to be able to do those things, and more importantly, it will 10 ultimately establish a comprehensive agency record of all the activities that the 11 panel took during this process.
12 The restart checklist, or the plant issues list, that's currently under 13 development, we know with a high level of certainty that the current Confirmatory 14 Action letter that was put in place following the flooding event, most of the items 15 in that Confirmatory Action Letter will transfer over to what we term the restart 16 checklist. In addition, as Fort Calhoun Station completes their comprehensive 17 assessment to determine the depth and breadth of performance issues, there 18 may be certain things that come out of that that will add to the restart checklist.
19 The NRC may choose to add additional items to that checklist, for example, Fort 20 Calhoun Station will embark upon an independent safety culture review that will 21 need to be completed prior to restart of the facility, that's something that we 22 would add to the restart checklist. All the items on the restart checklist will be 23 incorporated into another Confirmatory Action Letter, and we're probably going to 24 issue two more Confirmatory Action Letters through this process. One will 25 specifically address those items that need to be completed prior to restart of the
14 1 facility to ensure safe operation. The second Confirmatory Action Letter would 2 be similar to what we would issue for a plant that enters Column IV after 3 completion of a 95003 inspection, and that'll be those activities that are 4 necessary to sustain performance improvement for the long term, beyond restart 5 of the facility, and that's needed to ensure continued performance improvement, 6 and continued safe operation of the facility. And again, the restart checklist and 7 the Confirmatory Action Letters, those are all under development right now as we 8 learn more about the performance at Fort Calhoun Station.
9 The next thing we have to do is to develop an inspection plan.
10 Again, this is a two phase approach. There's -- the first stage is those 11 inspections that are required to be completed prior to restart. We'll also develop 12 an inspection plan that'll go beyond restart for the transition from safe operation 13 of facility back to the return to the reactor oversight program.
14 As John mentioned earlier, we have gone through and looked at 15 each of the elements that are -- that were in the inspection program prior to 16 entering 0350 and we selected those items that we felt are appropriate to 17 continue in the near-term. That'd be an initial operator examinations, those are 18 important to do, so we decided to keep those inspections. There's a tri-annual 19 fire protection inspection schedule for March, we decided to keep it. Fort 20 Calhoun's transitioning into NFPA 805 so that was an important inspection to 21 maintain. We're looking at the resident inspector modules to see what's 22 appropriate to be accomplished, and each of those baseline procedures will do 23 the things that are appropriate to accomplish, and then the residence, if 24 appropriate, will be used to follow-up on CAL specific items. There's a 25 component design basis inspection that was scheduled for this summer. We've
15 1 opted not to complete that inspection, instead use those resources as part of our 2 independent assessment of the licensees performance review.
3 We recently completed a readiness for the 2012 flooding season 4 inspection. You guys may have seen the event report that came out as a result 5 of that inspection activity, and again, that inspection was to make sure we were 6 ready to deal with the summer of 2012. We'll also have to do another inspection 7 that looks at the 2011 flooding effects, and what were the impacts on the facility, 8 what corrective actions has the facility put in place to deal with some of those 9 issues, namely, soil compaction underneath the facility; that's still an ongoing 10 review right now, and the licensee is completing some level of analysis. We still 11 have a fair amount of analysis left to do to understand the soil compaction under 12 the facility.
13 Once we've completed our inspections, we'll develop a plan to 14 return Fort Calhoun Station back to the normal reactor oversight process. Upon 15 facility restart, we'll stay in Manual Chapter 0350 process for some period of time, 16 likely one to two quarters. That's to allow the performance indicators time to 17 reset, so we have meaningful data, so we can make performance assessments 18 under the reactor oversight process -- and then again this is all intended to make 19 sure that when, if warranted, the facility can safely restart and then we'll be able 20 to maintain safe operation beyond restart, and those are my comments.
21 BILL BORCHARDT: So in conclusion I'd just like to make four quick 22 points. One is that the issues that got Fort Calhoun to Column IV and to the 23 0350 process didn't manifest themselves overnight. It's unlikely they'll be fixed 24 overnight. This is usually a long, deliberate process that is required to address 25 all of the issues.
16 1 The second point is that we're early in on this process, you're still in 2 the discovery phase, so it would not be surprising if there's a redefinition of some 3 of the issues. Also, it wouldn't be all that surprising if some new issues are 4 discovered and emerge that need to be addressed throughout the process. The 5 third is that this requires a significant resource commitment on the part of the 6 NRC, and of the licensee. The NRC is prepared to provide whatever resources 7 we need to the Region IV team. We can draw on resources from the other 8 regional offices, and from headquarters to support whatever inspection activities 9 are required, whenever they're required.
10 And the fourth is what Troy alluded to, is that the objective is not 11 just restart. It has to be much more than that, it has to be sustained, long-term 12 safe operation of the facility, and that's the kind of acceptance criteria the staff 13 will use when it makes regulatory recommendations. That completes the staff's 14 presentation, thank you.
15 CHAIRMAN JACZKO: Great, well thank you. We'll start with 16 Commissioner Svinicki.
17 COMMISSIONER SVINICKI: Well, good morning again, and thank 18 you all for your presentations. My questions are pretty general so I will leave it to 19 Bill and Elmo to decide if you want to respond yourselves or you want to ask the 20 other members of this panel to take some of these questions.
21 I was not serving on the Commission at the time of Davis-Besse so 22 I will confess that when the 0350 process was mentioned for Fort Calhoun I had 23 to go and study up on the entry conditions, the process, and then how -- what's 24 the structured process for exit from this particular process. At a very high level, I 25 don't know Elmo, maybe you would want to take this, could you contrast --
17 1 because of course people, I think, are generally very familiar with the columns of 2 the reactor oversight process, but Column V, if Im defining this correctly, would 3 be for plants that we consider unsafe and the 0350 process, I know we went over 4 the entry conditions, but could you contrast Column V in our system versus the 5 0350 process, from kind of the staff's regulatory toolbox?
6 ELMO COLLINS: Thank you. At least in a general sense, 0350 7 serves two distinct purposes in my mind. One is it allows us to -- for facilities that 8 are shut down, construct a unique oversight process to provide the meaningful 9 performance information that we can use for our assessment. So set that aside, 10 it also talks about being in Column IV and/or having a significant operational 11 event, and we saw both of those at Fort Calhoun Station, so those are the types 12 of things that ask us questions. Do we need to extra work before this facility 13 returns to power? Without -- and that's where 0350 takes you. It provides for 14 that construct, systematically to identify the issues to be addressed for the added 15 verification of safety. We knew enough, in our continuing assessment process, 16 to know we needed to ask those questions. We found that the facility did meet 17 the entry criteria of 0350, and we made that determination. Contrast that to 18 Column V, we didn't do the work, I would offer you, to take the results from the 19 special inspection team and other findings, to finalize to a useable product to 20 meet these multiple significant performance items which is one of the criterion to 21 consider a facility for Column V. We didn't do it, and we haven't done it, so we 22 never actually got to ask ourselves was the facility unsafe or not? Because we 23 want to engage before that, at any rate -- [laughs] --
24 COMMISSIONER SVINICKI: John, did you --
25 ELMO COLLINS: -- and the guidance provided for that.
18 1 COMMISSIONER SVINICKI: Thank you, it looks like John wanted 2 to --
3 JOHN LUBINSKI: If I could just add, as Elmo said, when the 4 decisions were made with respect to the plant being transitioned to Column IV, 5 the plant was in a shutdown condition at that time. The performance issues, 6 somewhat related to the shutdown conditions, but others were related to 7 operating conditions. From the standpoint of the Region's oversight, the plant 8 was in a safe condition during shutdown, continues to be in a safe condition 9 since it is shutdown today, so therefore looking to move to Column V, as Elmo 10 said, was not something that we looked at all the details because we felt we were 11 in the appropriate process. They were in Column IV, the 0350 process allows us 12 to enhance our oversight and customize it to the situation at hand, which they 13 were continued to be in a regulatory hold, having them in a shutdown condition 14 and prior to restart, as Troy said, we will make sure all safety issues are 15 addressed so that we will not authorize restart until they're in a safe condition.
16 So the process itself led us from Column IV to 0350.
17 COMMISSIONER SVINICKI: Can I ask -- maybe since you had 18 your microphone on I'll ask you a follow-up. You had presented the entry 19 conditions for entry into Manual Chapter 0350 and Im not trying to be hyper 20 technical about the process here, but I -- when there was a discussion, I think it's 21 the -- well, they kind of flow from each other, so I won't jump to number two, 22 number one briefly is plant performance is in Column IV/V. Elmo was just talking 23 about that. But item two is the plant is shut down or the licensee has committed 24 to shut down the plant to address performance issues. I had a sense here that 25 maybe you are doing a bit of a stylized interpretation of these entry conditions
19 1 because I know this is a hypothetical, but for the flooding event, were the 2 performance issues and status at Fort Calhoun would -- was that at a level that 3 would have -- that you would have either shut that plant down or requested that 4 the licensee commit to shut the plant down? Was the flooding event an aspect of 5 kind of a stylized application of item two?
6 JOHN LUBINSKI: I wouldn't say it was a stylized application. I'll 7 ask Elmo or Troy to add to this, but when we look at the process we're in the 8 timeline, the plant was coming out of an outage already so they were in a 9 refueling outage. They remained down at that point. Prior to going into the 10 outage, there were not performance issues identified that would have caused us 11 to even put them in a Column IV at that point.
12 COMMISSIONER SVINICKI: Okay.
13 JOHN LUBINSKI: So from a discussion standpoint we weren't 14 doing anything stylized with respect to that. They did have an event occur in 15 June prior to the flooding, so the flooding added to that, and then there were 16 other performance issues that occurred along the line, so to be able to speculate 17 would we have done something different if they were operating, it would be 18 difficult because number one, that was not the situation, and number two, we 19 don't know the performance or reaction of the -- what the licensee would have 20 done if they were in an operating condition at that point, and had any of these 21 issues occurred.
22 ELMO COLLINS: I would like to add to that, Commissioner. In 23 August and September when we issued the Confirmatory Action Letter and 24 moved the plant to Column IV, we consciously kept the flooding issues and 25 actions for plant restart separate from the ROP performance assessment
20 1 process. They were not linked at that time, but once we became to understand 2 the June 7th fire as a significant operational event, we had to -- we actually 3 asked ourselves the same question you asked -- you just asked us, you know, 4 does it meet this, and how does it meet it, and are we being true to criteria, and if 5 the plant had been operating and that event had occurred, then we would have 6 wound up in the same position.
7 COMMISSIONER SVINICKI: Okay.
8 ELMO COLLINS: It would have resulted in a plant shutdown, a 9 significant operational event, and transient, and so it would -- we would -- it would 10 have taken us to the same path, and so -- yes, I hope that helps give you some 11 insight.
12 COMMISSIONER SVINICKI: That is helpful, I appreciate both of 13 the commentary that -- the comments that you both made in response to that 14 question, and Elmo, I think you did a good job in response to my first question of 15 talking about how the 0350 process because we can design what we need there 16 in terms of an inspection process, we need some aspect, again, of our oversight 17 not to be so regimented that we -- you do need, in my view, something like an 18 0350 because you're always going to find yourself in unique circumstance, plant-19 specific, that we need to have aspects of our program that allow us to do -- to 20 design something that fits for the circumstances and that's some of how 0350 at 21 the time was explained to me by Eric Leeds and others, and you're nodding your 22 head to that, I think that was a point you emphasized earlier in response to that, 23 so I think the other question that, you know, I -- again, Im saying we have many 24 performance indicators, and when I went to our website and looked at a lot of the 25 different areas of performance, it did look like, you know, things were green, but
21 1 there were some areas where the trends were downward in some areas, and the 2 findings that we had were of various levels of safety significance, so it sounds 3 like in light of that, coupled with the extreme flooding event, 0350 just made a lot 4 of sense to you.
5 ELMO COLLINS: Well, I think that's correct. Being in Column IV 6 with a significant operational event speaks to significant performance issues that 7 warranted the additional verification prior to plant restart, and 0350 gives us a 8 process to accommodate that.
9 COMMISSIONER SVINICKI: And my last question is my other 10 understanding is that an aspect of if plants are shut down for whatever reason for 11 extended periods, we don't have the inputs to populate the ROP indicators. How 12 do we go about regaining that? Is -- I don't so I know, as Bill Borchardt 13 emphasized, were in early stages of this process, but how do you go about at 14 the point where we're convinced that restart is appropriate? How do they move 15 out of this, and back into the ROP?
16 ELMO COLLINS: Good, that is one of the assignments of the 0350 17 oversight panel, is develop that transition plan, I'll let Troy address some of the 18 details.
19 TROY PRUETT: A lot of that hinges on what's in the plant issue list 20 and the restart checklist. Through our review of the facilities comprehensive 21 assessment, we'll come in with a fairly large team, do a validation of that 22 assessment, from that we'll develop the additional items to fill out the restart 23 checklist at our plant issues list, and we'll work through those and we'll go back 24 and do additional validation inspections to make sure each of those items has 25 been resolved to ensure safe restart of the facility, and then once we're confident
22 1 that we can do that, we've -- in that decision, we'll develop an inspection plan to 2 go through restart, post-restart, and we'll go in and we'll brief Elmo, we'll make a 3 recommendation that we believe the facility is safe for restart, and then Elmo, in 4 consultation with NRR, will sign off on that.
5 COMMISSIONER SVINICKI: Okay, it looks like we'll be hearing 6 more about that in the future. Yes, John?
7 JOHN LUBINSKI: One point is in 0350 is it allows us and is 8 designed that way -- that we would continue under the 0350 process even after 9 restart for some period of time so that we could address your specific issue there, 10 so that we can understand that the performance is sustained performance 11 moving forward. And we could look at a couple months and that would be 12 determined by the restart panel, how long that would be, of performance indicator 13 data to determine what would be the best place to put them back into the action 14 matrix.
15 COMMISSIONER SVINICKI: Okay, thank you. Thank you, Mr.
16 Chairman.
17 CHAIRMAN JACZKO: Sure. Commissioner Apostolakis.
18 COMMISSIONER APOSTOLAKIS: Thank you, Mr. Chairman.
19 This Column V, is that a recent addition to the ROP? And I notice that some of 20 you even skipped it. Is it -- from IV we went to 0350. So was it last Monday or a 21 year ago? When was it added? It wasnt there in the beginning. Column V.
22 JOHN LUBINSKI: It wasnt recently added to the action matrix and 23 that -- as we thought -- the exact timeframe of that? Fred Browns going to give 24 you the exact timeframe, but as hes coming up, as we talked about it, the entry 25 condition even in 0350 specifically says if a plant is in Column IV or Column V we
23 1 can transition to 0350. So the process is designed such that its an enhanced 2 oversight process customized to the condition of the plant based on performance 3 issues and the current plant issues. Current -- the timeframe, please.
4 FRED BROWN: Yeah, Fred Brown, NRR. Column V was an 5 original part of the SECY-09-0007 formulation for the reactor oversight process.
6 The change that was made to the ROP in the management directive about five 7 years ago was to specifically add 0350 and how the 0350 process interrelated 8 with Colum IV and Column V. But the original ROP did have five columns, and 9 the unacceptable performance was I believe in --
10 COMMISSIONER APOSTOLAKIS: So a plant can be in Column V 11 without going to 0350?
12 FRED BROWN: No, if a plant goes to Column V, we handle it in 13 0350.
14 COMMISSIONER APOSTOLAKIS: Okay, okay. So its automatic, 15 then?
16 FRED BROWN: Yes.
17 COMMISSIONER APOSTOLAKIS: You have to go to 0350. You 18 mentioned that there were multiple degraded -- repetitive degraded cornerstones.
19 I wonder how the plant reached that state. I mean, I thought part of the agencys 20 adopting the ROPs are there would be early warning that things are not going 21 well. And yet we end up with a plant that has multiple repetitive degraded 22 cornerstones, and then we move on to 0350. Does that mean that we dont have 23 enough leading indicators in the ROP to warn us so that well never reach that 24 level? Or what does it mean?
25 ELMO COLLINS: Thats a question were going to ask ourselves
24 1 and were going to have to answer. We have the same question. Ill just -- and 2 so thats going to be part of the process, is to take a look -- lessons learned on 3 the regulatory aspects of this historically. Well, Ill give you my personal 4 assessment. I mean, the site had a degraded cornerstone in 2007/2008 and we 5 completed the supplemental inspection and gave it an up-check. Here we set 6 2010 another degraded cornerstone, same cornerstone. And so for the same 7 cornerstone to become degraded over course of three or four years, thats 8 probably -- in the big picture thats telling you something about organizational 9 performance. And the reactor oversight process doesnt carve that out 10 separately for consideration, but looking back on it, historically that was an 11 indicator to us. You know, that that cornerstone degraded again and doesnt 12 register in the action matrix, but its a historical fact that I think well have to give 13 consideration. And this time we saw additional findings of significance on top of 14 that, and the significant operational event, and thats what led us up to today.
15 BILL BORCHARDT: Yeah, you know, we -- every couple of years 16 we start talking about leading indicators, and we just dont have one, never have 17 had one. I hope someday we will, but its not on the horizon. So its a challenge, 18 but this is a rare and unusual event. It hasnt happened in 10 years. Its far more 19 often that a plant goes to Column II, maybe goes to Column III, addresses the 20 issues and ends up ultimately back up in Column I. So thats by far the more 21 normal path.
22 COMMISSIONER APOSTOLAKIS: But there will be some 23 reevaluation of the ROP after the --
24 BILL BORCHARDT: Well, we do that annually. I mean, and thisll 25 certainly be a major part of the annual assessment, to figure out the sequence of
25 1 events that led to this exact situation.
2 JOHN LUBINSKI: And as an input to that, as part of our process 3 plan for the oversight panel we will be looking at the Lessons Learned of the way 4 weve implemented this and looking back at the record to provide information on 5 our annual reassessments of the reactor oversight process.
6 COMMISSIONER APOSTOLAKIS: Okay. Thank you. Mr. Pruett, 7 you said that among other things the panel that youre chairing will have to 8 decide that the safety culture is good, there would be a survey, and -- before you 9 give the go-ahead. How did you decide that?
10 TROY PRUETT: Thats part of the process. Fort Calhouns 11 required to complete an independent safety culture assessment. So theyve let 12 out a contract with an outfit to come in and perform that review for them. Our --
13 the Human Factors Group in NRR will validate the process, the survey tools, and 14 the types of questions that that group will use at the facility. And then our 15 inspection follow-up team will go in and look at those results from that team.
16 Well compare those to our results that we obtain through the inspection. And to 17 the extent that theres alignment between what they found and what we found --
18 COMMISSIONER APOSTOLAKIS: But presumably there are two 19 cultures here. One is before they enter 0350, and the other would be afterwards.
20 I mean, there would be some changes. So which culture are you looking at?
21 The one after?
22 TROY PRUETT: Well want to get a perspective on the historical 23 safety culture to make sure that the corrective actions that they took were 24 appropriate to get the behavioral changes that they wanted at the facility. And 25 well also take a snapshot of the current-day safety culture, as well. A lot of times
26 1 in the focus group sessions, the people that sit there around the table, once you 2 have a conversation with them, they talk about -- Heres how things work, the 3 facility. Heres the meaningful changes that weve seen as weve developed 4 aspects of our integrated improvement plan. So --
5 COMMISSIONER APOSTOLAKIS: We still dont know what a 6 good safety culture is, though, do we? I mean, that will be your judgment that, 7 Yeah, theyre okay now.
8 TROY PRUETT: Right. Right.
9 COMMISSIONER APOSTOLAKIS: Right? Okay. And then you 10 say, They will return to the reactor oversight process. They will return to which 11 Column? All green?
12 TROY PRUETT: Well, the oversight panel --
13 COMMISSIONER APOSTOLAKIS: Or they will return to the 14 process itself.
15 TROY PRUETT: Yeah, yeah. The oversight panel --
16 the oversight panel will make a recommendation as to which column to place 17 Fort Calhoun Station back into. Itd be speculative right now, though. But I 18 believe the recommendation that the panel would come forward with eventually 19 would be -- were going to have a Confirmation Action Letter thats open, 20 traditionally with a 95003 plant thats in Column IV. That would remain in Column 21 IV until completion of the Confirmatory Action Letter, and then they would 22 transition back into Column I or II, or whatever the findings supported at that 23 time.
24 COMMISSIONER APOSTOLAKIS: So they will return to Column 25 IV?
27 1 TROY PRUETT: Possibly.
2 COMMISSIONER APOSTOLAKIS: Pretty serious.
3 TROY PRUETT: Right, right. Possibly. Right.
4 COMMISSIONER APOSTOLAKIS: Well thank you, Mr. Chairman.
5 CHAIRMAN JACZKO: Commissioner Magwood.
6 COMMISSIONER MAGWOOD: Thank you and good morning.
7 First let me say I appreciate, you know, Elmo and Troy and the Region IV staff 8 and the work theyve put into this, as well as the NRR staff. This is something 9 that Ive been following for a long time, and Elmo and I have talked about this on 10 multiple occasions and I appreciate the amount of work thats gone into preparing 11 for this stage and the amount of work thats going to go forward in seeing this 12 through.
13 I wanted to ask a couple historic questions first, just to get some 14 orientation. And hopefully -- and Elmo you look old enough to have been around 15 long enough, so maybe you can answer some of these questions. But as I look 16 back, I -- we really havent had plants in 0350 very many times. Its been less 17 than a dozen times in the history of the agency. As you look -- as you -- and 18 maybe youve looked at this as youve gone into this process, but Im curious as 19 to whether 0350 is most often activated by a particularly large operational 20 problem of a well-defined nature, or is it generally lots of operational problems in 21 lots of different areas? When you look back, is there a pattern that you see with 22 the plants that end up in 0350? And feel free to chime in.
23 ELMO COLLINS: Okay. Ill start, and then my boss will follow-up.
24 My recollection -- you know, and Im -- is usually theres some acute occurrence 25 that was of such significance and spoke to the facility performance that really
28 1 became the seed or the catalyst to really prompt us to seriously consider 0350.
2 And thats similar to what happened here. It was the fire on June 7th that 3 affected both trains of safety related equipment that really had risk significance 4 and safety significance.
5 BILL BORCHARDT: Yeah, and Id say -- you know, the vast 6 majority, almost 10 of the issues, preceded ROP. So this was back in the days 7 of SALP and some of the words that have been banished from the regulatory 8 dictionary. And it -- at least half of them I would say, just based on my general 9 recollection, were just long-term, sustained, nagging issues that the Regional 10 staff and they -- had developed numerous inspection findings. We didnt have 11 the rigorous methodology that the ROP affords us, so it was kind of more of a 12 lingering issue of problems not being fixed that at least on half of the occasions 13 led to entry into 0350.
14 COMMISSIONER MAGWOOD: And thats what I guess I would 15 have expected, because its -- and Im going to come back to that for a moment, 16 but let me sort of ask Elmo to sort of emphasize -- to talk about something you 17 just emphasized, which is you talked a lot about -- you talked about the fires 18 being sort of the large operational issue that kicked it into this mode. In your 19 discussion with Commissioner Svinicki you talked about that, as well. Let me ask 20 the question a little bit differently from the way that Commissioner Svinicki asked 21 it, and know this is again looking at the situation more theoretically as opposed to 22 what actually happened, but are you saying that the plant is in 0350 because of 23 the fire or is the plant in 0350 because of the fire and all the other things that 24 were happening, as well? Understand your --
25 ELMO COLLINS: I think, if I understand your question, I would say
29 1 the latter. There were a number of factors. The fire, the significant operational 2 event being one, which entered into the decision the process -- the criterion of 3 0350 walked us through that.
4 Ill just add, we actually asked ourselves this question early on, 5 what was the right oversight process? 0350? We have another Manual Chapter, 6 0351, which deals strictly with extended shutdown periods. So we could have 7 accommodated the performance indicators in the baseline programs through that 8 program. And until we got on site in September and October and really got the 9 facts laid out and got a good grasp of the significance, I had thought thats where 10 we were headed. But then the significant operational event tipped the scale over 11 and made us reconsider 0350.
12 COMMISSIONER MAGWOOD: So, let me -- that sort of brings me 13 back to Bills point that generally, historically, it wasnt just the one singular event, 14 it was sort of a nagging, long-term list of problems that led to plants generally 15 getting into 0350. And I guess my question really is, is that really more of what 16 were seeing with Fort Calhoun as opposed to the single operational event? Is 17 this -- and to sort of use the word, is this a safety culture problem that we really 18 have at Fort Calhoun, as opposed to an isolated set of circumstances?
19 ELMO COLLINS: I think -- my best guess is I think theres quite a 20 bit of work to be done to really frame the answer to your question and with a 21 systematic and defensible analysis. But yes, there are the cultural aspects at the 22 facility, as well, that are coming into play. That -- a program -- if -- in Column IV, 23 thats kind of the given. If you get to Column IV you have to do an independent 24 safety culture assessment. Its almost assumed that if you reach that level of 25 performance that somewhere in the organization, to some degree, likely of
30 1 significance, there are cultural issues at play.
2 COMMISSIONER MAGWOOD: And one would think that thats the 3 hardest to assess and the hardest to fix really if you look long term. The last 4 couple of plants that went through this process I think spent about three years in 5 0350, something like that?
6 JOHN LUBINSKI: The timeframe for the last plant that went 7 through was three years, from the time they entered until the time they 8 terminated the 0350 process. On average, the plants before that -- and its a little 9 bit different, as Bill said, because the majority of those were before the ROP. But 10 somewhere -- two, two-and-a-half years on average going through the process.
11 COMMISSIONER MAGWOOD: Largely because it wasnt just 12 fixing one or two operational issues. Its really looking at the -- it really becomes 13 the safety culture, organizational performance. Its a broad issue.
14 ELMO COLLINS: Thats correct. I -- let me elaborate a little bit. In 15 my analysis, if you have the significant events, theyre almost always the causes.
16 And when you really trace the roots back, they go pretty far and are going to go 17 pretty deep into the organization. This fire in June 6th was -- I mean, it was a 18 modification. It was actually well-intended, to improve the reliability of 480 volt 19 breakers. But what resulted was a condition that was an unreliable configuration 20 and actually induced conditions. And just that characterization gives me pause 21 and so, I mean, whats going on in that organization when you set out to 22 accomplish something, to make it better, and you actually get the opposite 23 result? Thats going to trace back into --
24 COMMISSIONER MAGWOOD: Yeah, I had the exact same 25 reaction. I was also looking at the significant -- the yellow they got on failure to
31 1 maintain external flood procedures. And one of the sentences in the discussion 2 of this says, The finding was determined to have a crosscutting aspect in the 3 area of problem identification and resolution, corrective action program, failure to 4 take appropriate corrective actions to address safety issues and adverse trends 5 in a timely manner. Sounds like safety culture issue to me. And so I guess --
6 when I look at this, you know, I think its -- you know, I think that you -- I think 7 youve been saying this in different ways as this got started, but this really isnt --
8 this isnt about the flood, its not about the fire, its about the organization, its 9 about the safety culture at Fort Calhoun. And so I think its important as we go 10 forward looking at this to not overly focus on those specific operational 11 challenges, but to really focus on the overall performance of the organization. Is 12 that a fair way to look at it?
13 ELMO COLLINS: I agree completely, Commissioner. We -- in our 14 articulation, maybe we refer too much to the events and the incidents in the 15 findings, but the reactor oversight process is very event incident-driven. We --
16 its not -- doesnt have leading indicators. We react, engage based on the 17 significance of what we see and increase when the significance increases. And 18 thats what weve seen at Fort Calhoun Station.
19 COMMISSIONER MAGWOOD: Well -- and I -- and thats not to --
20 and I appreciate Commissioner Apostolakis discussion about that aspect of it.
21 And I recognize the ROP doesnt limit itself to those kinds of -- you know, I guess 22 I say canaries in the mineshaft. But we do have the resident inspectors and I 23 would think that one aspect of the resident inspectors presence on site would be 24 to give you, personally, some indication as to whether we are having 25 organizational and safety culture issues. I -- did -- were you able -- has this --
32 1 before we got to this stage, did Region IV have indications of issues? Even if it 2 hadnt reached this point, but were you -- were there issues that you were 3 concerned about?
4 ELMO COLLINS: I have two answers to that question. Yes and 5 no. You know, we are as true as we can be to implementing the guidance and 6 procedures of the reactor oversight process. One of the values it brings is to put 7 discipline in potentially numbers and guidance to any issue, what it means, and 8 what it doesnt mean. And so resident inspectors follow that, and were true to it.
9 So if its not there, you know, its not going to surface as increasing engagement 10 in the ROP action matrix. Its just not. And even substantive crosscutting issues 11 dont change the action in the action matrix. I will say that it is a fact, and I rely 12 heavily on the context and insights that resident inspectors develop at a facility.
13 They understand whats going on there and they can put context around an issue 14 and a problem that youd never get from the regional office, and never get from 15 black and white guidance. That does bring value and insight to us, and we try to 16 use that. And that points us, then, to how we focus our inspection efforts. And 17 we were seeing that at the Fort Calhoun Station.
18 COMMISSIONER MAGWOOD: Thats a fair answer. Appreciate it.
19 Thank you very much.
20 CHAIRMAN JACZKO: Commissioner 21 COMMISSIONER OSTENDORFF: Thank you, Mr. Chairman. I 22 want to --
23 CHAIRMAN JACZKO: Moment of forgetfulness there.
24 COMMISSIONER OSTENDORFF: Thanks. I want to thank 25 Region IV and NRR. Elmo, I want to go back to your comment you made in your
33 1 opening statement about kind of three major challenges, one maintenance and 2 design, two corrective action program and three, dealt with organizational 3 effectiveness. I want to ask a couple of questions in those areas. Can you talk a 4 little bit about this breaker replacement and the testing? That got my attention 5 and I wanted to maybe understand a bit more about what happened and what 6 should have been done.
7 ELMO COLLINS: The 480 volt breakers at Fort Calhoun Station --
8 Im going to let Troy provide some details here. Or Jeff.
9 COMMISSIONER OSTENDORFF: Im very interested in what test 10 did not occur that should have occurred or any inspection --
11 ELMO COLLINS: Specifically, what I was referring to there was --
12 well, and let me back up and describe the mod slightly. They were replacing the 13 breakers, but they were of an older design. The newer breakers were not 14 identical and they were actually smaller, physically smaller for 480 volt breakers.
15 And so the licensee opted on a path to retain the cabinets and the bus bar 16 arrangements, and fit the smaller breakers inside a larger cubical, which resulted 17 in the need to design a -- I call it a -- its called a cradle. I call it transition piece.
18 But the breaker has stabs which go into the transition piece. The transition piece 19 has another set of stabs which are inserted into the bus bar arrangements. And I 20 believe that there are inspection and licensee review. In that installation they 21 didnt measure the electrical resistance between the cradle and the bus bars. Is 22 that -- and Ill let the -- Jeff Clark speak before I say more than I know here.
23 JEFF CLARK: Good morning. Im the branch chief from the 24 Division of Reactor Projects that has Fort Calhoun oversight. As Elmo specified, 25 in that modification it was going from one breaker style to another. You had to
34 1 come up with this transition piece, as Elmo said, to have stabs. What we have 2 determined through our inspection is there wasnt a rigorous process to 3 determine that proper engagement of those multiple stab pieces. The actual 4 location of those within the breaker cabinets was such that it couldnt be seen 5 easily. Youd have to do some disassembly of the back portion of the cabinets.
6 Some other things, such as resistance checks, thermography, or whatever, were 7 not done to validate or verify that those connections were actually properly made.
8 And that the modification then in turn would be effective going forward.
9 COMMISSIONER OSTENDORFF: I assume theres quality 10 assurance paperwork or some kind of a work completion form that would have 11 some testing or some post-installation checks on this?
12 JEFF CLARK: There was. And one of the complications we saw in 13 there was that it was a misunderstanding with some of the craft and some of the 14 QA, that they felt that some of those observations and readings should only be 15 taken on the visible portion of the modification and were not done because of the 16 complexity of getting to the back panel.
17 COMMISSIONER OSTENDORFF: This doesnt sound like it 18 should be rocket science. I mean, I guess Im -- Ive replaced lots of breakers 19 over many years in the Nuclear Propulsion Program. Its pretty straightforward 20 just to do resistance -- and this is, you know, not complicated. So Im trying to 21 figure out, is this an unusual set of circumstances here because of the pieces are 22 not visible? Im just trying to fathom the absence of the testing of this. Thats --
23 and maybe theres no answer for that.
24 JEFF CLARK: Again, theres -- the specific answer to that is going 25 to be, you know, part of our follow up --
35 1 COMMISSIONER OSTENDORFF: Yeah.
2 JEFF CLARK: -- inspection to that as to why you didnt actually get 3 into that aspect.
4 COMMISSIONER OSTENDORFF: Okay.
5 JEFF CLARK: But, again, it fell in with the complexity of getting to 6 the actual connections.
7 COMMISSIONER OSTENDORFF: Okay. Thank you.
8 ELMO COLLINS: Ill add two points. One, this is the first time 9 these have been -- this actual process and mod have been done at Fort Calhoun 10 Station, so -- now, there were -- evidently there were some translation 11 weaknesses or misses with how those were put in and how they were tested. Ill 12 also add, just to -- we got to issue our inspection report on this, so -- well, were 13 very close to issuing, and I would -- Im a little hesitant here to --
14 COMMISSIONER OSTENDORFF: I understand.
15 ELMO COLLINS: -- discuss it.
16 COMMISSIONER OSTENDORFF: Well, I guess -- but I 17 understand this is a potential significant contributing cause to the fire. Is that 18 what I heard from you? Is that correct?
19 ELMO COLLINS: Thats correct.
20 COMMISSIONER OSTENDORFF: Okay. Let me go on to the third 21 challenge you mentioned, Elmo, in the area of organizational effectiveness. And 22 I appreciate you or anybody else at the table commenting on the existing Fort 23 Calhoun managements capacity to address the situation with 0350 and 24 strengths, weaknesses, areas for improvement on the management ability to get 25 their hands around these issues.
36 1 ELMO COLLINS: Ill start just by saying this is a significant 2 challenge for the site, organizationally. Just being in Column IV by itself would 3 be a challenge to any organization. This station is also challenged by the 4 external event that they experienced with the flood. And so -- and we believe 5 with the fire and the significant operational event, that that adds to the challenge 6 a licensee has. So, by any measure, this is going to be very challenging for the 7 organization. I think we need to see, you know, how they move through this with 8 their cause analysis, the extent and condition for some of the equipment issues 9 theyve seen, and the extent of causes and thats something well have to take a 10 look at. Im not in a position to say how thats -- too much uncertainty around that 11 right now. Too many unknowns.
12 COMMISSIONER OSTENDORFF: Is the licensee getting any 13 external assistance from other industry sectors or any industry coalitions?
14 ELMO COLLINS: Yes, I believe they are. They have entered into 15 a contract with an Exelon corporation and I believe theyll probably speak more to 16 you about that, though, when theyre at the table.
17 COMMISSIONER OSTENDORFF: Okay. Thank you.
18 ELMO COLLINS: Theyre getting external assistance.
19 COMMISSIONER OSTENDORFF: All right. Thank you, Mr.
20 Chairman.
21 CHAIRMAN JACZKO: The -- as we go forward, there are, as I 22 think -- Elmo, as you talked about, a couple of pending, potential, greater-than-23 green findings. To what extent do those factor in at this point, as they -- if theyve 24 moved into Manual Chapter 0350, do we then keep -- you know, if these come 25 out as more whites than yellows, does that have an impact on the ROP or what
37 1 do those mean going forward?
2 ELMO COLLINS: I think moving forward -- technically, Fort 3 Calhoun Station has been removed from the reactor oversight process, but we 4 will develop those findings and make an assessment of the significance. And so 5 what practically will happen is they will then, once theyre finalized, be handed to 6 the Restart Panel for consideration of inspection and evaluation for licensee 7 corrective action. Its not going to change our level of engagement at this point in 8 time.
9 CHAIRMAN JACZKO: Given -- or, I dont know, Troy, did you want 10 to add anything?
11 TROY PRUETT: Just to say if those findings that we believe would 12 result in a greater-than-green result, those would go to the panel. The panel 13 would add those to the restart checklist for resolution prior to restart.
14 CHAIRMAN JACZKO: Its -- and I guess, as I understand, based 15 on the different potential findings, that its possible that we could see them then 16 with degradation in possibly four cornerstones. Have we ever had a plant in a 17 situation like that? Well I mean, again, not putting them into the ROP but --
18 TROY PRUETT: Yeah, there hasnt been, and again there are a 19 number of findings that are working their way through the process right now. I 20 dont believe we would hit four degraded cornerstones, based on where they are 21 in the process right now.
22 CHAIRMAN JACZKO: Okay. John, did you want to --
23 JOHN LUBINSKI: If I can just add, just -- no we have not had a 24 plant in that area, and as we move forward, as Elmo said, the -- when we 25 characterize these, we would not be characterizing them as additional degraded
38 1 cornerstones. The more important part is when we have plants that have a 2 degraded cornerstone is how do we react, how do we do our inspections? And 3 thats the purpose of the oversight panel, is to take the information from those 4 findings, the risk significance of those, also determine the connection to the other 5 items that have been identified, to verify that, number one, the licensees plans 6 for addressing and identifying the extent of condition and corrective actions are 7 appropriate. And then from our standpoint to make sure our inspection efforts 8 that were -- our enhanced inspection efforts under 0350 are adequately 9 addressing not only the issues themselves but any crosscutting nature to them.
10 CHAIRMAN JACZKO: Well, thank you. I appreciate that, and I --
11 you know, I think to some extent the ROP is a very useful tool for communication, 12 so -- and I appreciate -- because I think moving to 0350, we dont really follow it, 13 but I think there is some value of, to some extent, tracking these things as to 14 where they would have been in the ROP even if -- you know, because if we see 15 another yellow, we see additional whites, that seems fairly significant from plants 16 that Ive experienced in the time that Ive been on the Commission, to see that 17 many findings with that level of significance.
18 ELMO COLLINS: Ill just add, I mean, communication is a very 19 importance piece of Manual Chapter 0350, as well. And so we will have public 20 communication about what we believe the significance is. What 0350 adds is --
21 an ROP would change the level of significance by different columns of the action 22 matrix. That's not going to change our level of engagement because we're 23 already what we believe is maximum engagement with the 0350 oversight panel, 24 and for communication purposes, there's a series of, you know, public meetings 25 that we'll be conducting to talk about where we're at and how we're moving
39 1 forward through the process.
2 CHAIRMAN JACZKO: And Commissioner Svinicki asks a number 3 of really good questions about the 0350 process, and I think for all of us, this is a 4 little new. And, I think, when I was on the Commission, Davis-Besse was coming 5 out of their 0350 maybe, or maybe they had already, but they were still wrapping 6 up, I think, the CAL items, so they may have already been out of the 0350, but 7 were wrapping up the CAL.
8 Is there an extent in which, I mean, is there a difference, let's say, 9 at this point, with the additional issues that would be identified if they had some 10 high degree of significance that would be equivalent to yellows or possibly even 11 red findings if they were under the traditional ROP? Is there a difference? I 12 mean, do we go back and reevaluate effectively Column V, or is there really no 13 difference at this point between being in Column V, being in 0350, and being shut 14 down?
15 ELMO COLLINS: Yeah, technically, Fort Calhoun's been removed 16 from the reactor oversight process, so those algorithms that are constructed to 17 determine NRC engagement with the action matrix are not applicable in Manual 18 Chapter 0350. In lieu of that, we have the oversight panel, which looks at each 19 issue and its significance to determine how it needs to be addressed.
20 So, what we rely on in 0350 is getting the right items and to restart 21 for safety is getting the right items in the restart checklist and getting those items 22 resolved and addressed appropriately, and to provide that additional verification 23 of safety before the plant returns to power.
24 CHAIRMAN JACZKO: Would there be more tools if we were to 25 terminate 0350, put them back in the ROP, and put them into Column V than
40 1 tools that we have available now under 0350?
2 TROY PRUETT: No, I dont believe so. Column -- if you hit 3 Column V, you automatically transition into 0350, and you go into this process, 4 so the process wouldn't be any different.
5 BILL BORCHARDT: And I think the bottom line is that the licensee 6 needs NRC approval to restart, I mean, so, that's -- and we won't give 7 authorization to restart until the startup checklist is done, we're satisfied that all 8 the corrective actions have been taken for all the issues identified, and, so, it's -- I 9 think there's a very strong regulatory footprint on the process from this point on.
10 CHAIRMAN JACZKO: Great. Well, thanks. One last question on 11 that. Do we have any preliminary results on the -- have we run the fire event 12 through the ASP at this point? Do we know? Is there plan to be an ASP 13 analysis?
14 JOHN LUBINSKI: There will be analysis. We have not run that yet.
15 CHAIRMAN JACZKO: Yeah. Okay. Any expectations of what that 16 -- is there a potential to be a --
17 JOHN LUBINSKI: Don't want to --
18 CHAIRMAN JACZKO: -- significant precursor, or --
19 JOHN LUBINSKI: Don't want to prejudge at this point. We'd have 20 to run the information first.
21 CHAIRMAN JACZKO: Do we have a timeframe for when we would 22 likely do that?
23 JOHN LUBINSKI: Do we have a time frame --
24 RANI FRANOVICH: Eighteen months.
25 JOHN LUBINSKI: Eighteen, I'm sorry.
41 1 RANI FRANOVICH: Eighteen months.
2 CHAIRMAN JACZKO: Have we started?
3 JOHN LUBINSKI: Rani, if you could just come to the microphone.
4 Rani Franovich is the branch chief in charge of our performance assessment and 5 program.
6 RANI FRANOVICH: Yeah, Rani Franovich. Research does the 7 ASP review, and they do a screen each year, but it can take 12 to 18 months to 8 have the final outcome. I believe they probably are reviewing it, but we don't 9 have any indication of where they are and what the results are indicating.
10 CHAIRMAN JACZKO: Okay. Thanks. Again, maybe we can just 11 confirm or let us know if they are actually doing it or --
12 RANI FRANOVICH: We'll take that action, Chairman.
13 JOHN LUBINSKI: We'll do that, sure.
14 CHAIRMAN JACZKO: Great. Thanks. Okay. I think those are all 15 the questions I had, so, again, thank you for your presentation for the work that 16 you've done. I think this is a very appropriate action on the part of the agency, 17 and I look forward to continued updates on progress. Thanks. Well take a quick 18 break.
19 [break]
20 CHAIRMAN JACZKO: Okay. We'll continue meeting and get a 21 presentation from the Omaha Public Power District. Gary, I'll turn to you to begin 22 and however you want to proceed.
23 W. GARY GATES: Thank you, Mr. Chairman. I'd like to introduce 24 the people at the table with me. Dave Bannister is the chief nuclear officer and 25 vice president of our company. I'm Gary Gates, president and CEO, and John
42 1 Herman's our division manager of engineering.
2 I'd like to open with a few opening comments, and then for the 3 sequence, Dave Bannister's going to go over in some detail our recovery plan 4 which will cover the points that we heard earlier in the meeting as we go through 5 this as well.
6 First, I'd like to cover a couple of things, what we're here to do and 7 what we're not here to do. First, I want to assure you that we understand the 8 seriousness and the scope of these issues. We have a sense of urgency to 9 return Fort Calhoun to sustained high levels of performance. I intentionally did 10 not say a restart, I said sustained levels of performance. That'll be action-based, 11 we dont have a time table. We want to share the elements of our recovery plan.
12 It's taken a long time to develop this plan. We will get it to the 13 restart committee with Troy very soon, and the reason it's taken us a long time 14 are two: As we surveyed the industry on similar situations, our advice was take 15 your time up front, do the plan very well, do it very detailed, and have all the 16 corrective actions in it that you need; a second is we want to kill this issue 17 completely as we move forward.
18 We're clearly not satisfied with our performance. We'd like to 19 assure you we have the support of our entire company. I can talk at any level of 20 detail about that and our board for resources. Also, the majority of the workforce 21 at Fort Calhoun are experienced, long-term employees. They have operated at a 22 high level of performance. We lost our edge. The workforce at Fort Calhoun is 23 very willing and anxious to make any changes needed and have already started 24 that process.
25 I'd like to cover what we're not here to tell you, that we've
43 1 completed all our discovery. We have more to come in that, as was mentioned 2 earlier. We do not want a short-term fix. We're a work in progress. We're 3 challenging ourselves, questioning everything. We're doing deep dives to get 4 root cause identified. As we find those deep dives, other issues will come up.
5 We anticipate that, and we'll deal with them. Changes, we will make. You have 6 my personal and the company's commitment on that.
7 We're not assuming that we have the capacity to do these efforts 8 without outside help, to ensure our sustainable performance. Dave will cover 9 that in his presentation on the additional resources that we've brought in to help 10 us.
11 My last comments would be, as you listen to Dave's comments and 12 to our presentations today and our answers, please do it in this context: We have 13 a long-term goal of sustained performance. We understand we have let the 14 industry down and we have let ourselves down with our performance. We have 15 the drive, commitment, and heart to return this station to high performance.
16 Performance recovery is in progress. We've done a lot of individual 17 root causes and have those results. We have interim actions in place to deal 18 with, specifically as mentioned earlier, safety culture and those issues. But, 19 additional items with improvement will be needed and are in our overall plan.
20 I'd also like to assure you that the industry has rallied to help us.
21 We were very involved on a national level. I can say across the board -- and I 22 think it's unique to the nuclear power industry -- the amount of help we've been 23 offered and taken to return our station to high performance. We will be a high-24 performing unit. Dave, would you please go through our presentation?
25 DAVID BANNISTER: Okay. On slide one, first of all, I'd like to
44 1 thank the Commission for the opportunity to talk about our performance in a 2 public setting. On side two, I'll talk about the key areas I'm going to discuss this 3 morning and cover.
4 First of all, an acknowledgement of our performance issues and our 5 accountability to them, the key objectives of our performance improvement plan 6 and really our actions that dictate them going forward, and then finally some 7 specific details about the plan itself. Okay. Slide three.
8 As Gary indicated, Omaha Public Power District understands the 9 significance of the position that we're in, and we hold ourselves responsible for 10 our unacceptable performance. We're committed to do what's necessary to 11 identify, analyze, and resolve our performance issues.
12 Our performance issues were revealed by violations of color and 13 other internal findings. Violations dealt with -- and you've already been briefed 14 on those -- our flood preparation procedures, a failed electrical contact interactive 15 protective system, some handling of some historical security-related information, 16 and our corrective action program culture.
17 To date, we've done causal analysis on each of these issues and 18 put forth detailed, corrective actions. We've rewritten our flooding procedures, 19 fabricated, upgraded flooding gates and plates as a positive protective feature, 20 and upgraded our flooding strategy.
21 We recognize we have more work to do. This was revealed at our 22 specific flooding readiness inspection that we had in early February, and this 23 resulted in some additional revisions to our flood procedures, and in the process 24 of evaluating a safety class of a particular equipment in our intake structure.
25 We've replaced the failed contactor in our reactor protective system
45 1 and the three backup contactors in the other channels, and this was done last 2 February. We've improved our handling and storage of security-related 3 information and we've instituted stronger management oversight in our corrective 4 action program.
5 Our event, which we've talked a bit about, is a breaker failure that 6 occurred on June 2nd, or, excuse me, June 7th, and we anticipate that there is a 7 finding of significance on this issue. To date, we've replaced that breaker in the 8 load center and we have testing in progress.
9 We clearly understand that we must improve, and we've 10 established a sense of urgency in our organization to improve not only our 11 performance with safety but also from a regulatory perspective. We're taking 12 strong management actions to continue to strengthen our leadership and 13 management of the station, improving our oversight and rigor into our technical 14 decision-making, and improving our human performance. Next slide.
15 Next, I'll discuss some key objectives of our integrated performance 16 improvement plan, and they are as listed to improve and sustain station 17 performance, equipment reliability, and risk reduction; to identify and correct 18 human performance issues; to ensure ownership in the improving initiatives; 19 reestablish regulatory confidence; and reinforce public confidence.
20 And we talked -- as Gary Gates had talked before our focus is 21 really a long-term approach to performance improvement and not taking a short-22 term view of this. We do that by being rigorous in our analysis, digging deep in 23 the discovery of our issues, and then recognize that the plan has taken time to 24 evolve. However, we want to ensure that we do this right the first time, that the 25 analysis has the right breadth and depth, and that ensures that we clearly
46 1 understand the issues and put forth a correct -- smart, corrective actions.
2 Slide five talks about some of the improvement plan attributes, and 3 these are really the attributes that will make the plan successful. First of all, site 4 engagement. This is at all levels of the organization, whether people are 5 participating on the performance improvement team; identifying and 6 implementing the corrective actions; or being part of the analysis and part of the 7 discovery.
8 Next, a strong, external support. Gary Gates indicated that we 9 have reached out to the industry and have gotten a tremendous amount of 10 support. One of those are from Exelon nuclear partners -- and I'll talk more about 11 them in terms of leading our performance improvement efforts -- the Institute of 12 Nuclear Power Operations, and other industry experts.
13 We've also employed internal and external oversight, both from our 14 internal quality organization, our nuclear safety reviews, our independent offsite 15 review committees, and line organization assessments. We've also increased 16 our internal and external communications really with a focus on being transparent 17 and open in our communication and our messaging.
18 And, finally, our projects scope, which is much, much broader and 19 much more focused on sustained improvements rather than just meeting the 20 minimum requirements associated with startup.
21 The next slide, I'll talk a little bit about the organization, and this is 22 our performance-improvement team, and these are really the keys to the 23 organization. First of all, a dedicated, blended team of OPPD, Exelon, and 24 external experts. The organizational accountability as you see in the chart 25 directly to the chief executive officer of the improvement team.
47 1 The team is largely self-contained. It has the right expertise 2 embedded on the team to analyze and resolve technical issues and assist with 3 the implementation of corrective actions in a number of areas, being it with safety 4 culture, identifying and correcting deficiencies, reactor system reviews, the 5 corrective action program, or analysis of engineering and maintenance issues.
6 There's a representation on the team from every line organization at the station.
7 The next slide shows some of the major elements of the integrated 8 plan, and I'll talk briefly about each one of those. These elements were selected 9 to ensure that we have a complete understanding of our performance issues and 10 that we develop the right actions in place to address them. The elements are, 11 first and foremost, are our flood recovery plan, and that really recovers the 12 physical plant and really ensures we harden our flooding strategy and take care 13 of any issues of any impact the flood may have on the plant.
14 A detailed reactor safety system review, detailed assessment of the 15 processes and behaviors used to identify and correct our deficiencies at the 16 station, an independent assessment of our nuclear safety culture, detailed 17 assessment of our corrective action program, and then, of course, review of 18 selected engineering and maintenance processes. And these were processes 19 that were identified doing some of our internal assessments and some inspection 20 activities.
21 Next, I'll go on to provide some more detail on each section of the 22 plan, which I've just laid out here. On slide eight, first of all, the flood recovery 23 plan, and really, the plan analyzed and addressed the physical impacts that the 24 flood had on the station in six broad areas. The actions from the flood recovery 25 plan have been put into our integrated plan. We felt that was necessary.
48 1 First of all, the site restoration, that deals with the physical cleanup 2 and recovery of the site in and around the station. It also deals with the recovery 3 of the load center and the fire that occurred on June 7.
4 Plant systems and equipment assesses any flood-related impact 5 that the plant systems and equipment had due to having water on site for nearly 6 100 days. The equipment reliability looked at any long-terms effect the flood may 7 have on station equipment and the site itself. This is where you would see the 8 geotechnical or soil evaluation. The design and licensing basis assessment 9 really looks at the configuration and licensing basis changes that we may need to 10 look at as a result of the flood.
11 The emergency plan basically assessed and corrected any 12 equipment deficiencies or responses that were impacted by the flood and any 13 necessary changes we would make -- need to make long-term. And then, finally, 14 the security aspect is to ensure that we've restored the physical security system 15 and then looked at if there's any enhancements we need to make going forward.
16 On slide nine, it talks about the reactor safety review, and this is an 17 intrusive assessment into selected safety-related functions, subsystems, and 18 processes really to verify that we can fulfill their safety-related functions. We also 19 look cross-functionally to evaluate if any safety organizational performance 20 issues exist with the maintenance design or the operation of the system that 21 we're looking at.
22 As part of that review, there's a couple of key attributes that I'll 23 touch on. In the design equipment performance and configuration control 24 attribute will verify that the system can fulfill its intended safety-related function 25 and we'll do that by doing a detailed review of the design basis, the operation,
49 1 and any past modifications that we made. We'll also, as a part of this review, do 2 a latent issue review. We'll also assess the effectiveness of any corrective 3 actions that we've done and look at any performance deficiencies that have 4 evolved with the system and any testing methodologies we'd use to prove 5 operability of the system.
6 We'll also verify proper configuration control of system by doing 7 plant walk downs, design document reviews. We'll also look at our work control 8 process to make sure that we properly evaluate risk when we're doing 9 maintenance or upgrades on any portion of the system.
10 Next, in the human performance attribute, we'll assess our 11 effectiveness of identifying and correcting issues dealing with human 12 performance. We'll give specific attention to any attribute identified in a cross-13 cutting aspect really to evaluate its impact on work control, decision-making, 14 work processes and practices, resources, and ALARA planning.
15 In the procedure review attribute, we'll assess how effective we are 16 in identifying and correcting deficiencies dealing with plant procedures, and we 17 won't limit these just to operational procedures, but we'll take a broader look, 18 including things like emergency preparedness procedures. And, finally, we'll look 19 at the effectiveness of the emergency response organization readiness.
20 On slide 10, I'll discuss the processes that we'll use to evaluate the 21 things that we do to identify and correct performance deficiencies at the site; 22 sometimes this is called an IACPD review. Purpose of this review is to determine 23 whether our systems were identifying and correcting performance deficiencies 24 are really adequate. To do this, we'll evaluate a number of processes and 25 programs.
50 1 We'll look at our performance improvement programs. This 2 includes a corrective action program, our causal analysis program, 3 benchmarking, trending, self-assessment, and the use of operating experience.
4 We'll also evaluate our performance goals and metrics to ensure they're 5 appropriately set and how well known they are throughout the organization. We'll 6 evaluate any greater than green finding to validate that we've done a good depth 7 of analysis and we've got the right corrective actions in place.
8 We'll also review our employee concerns program. Part of this is to 9 ensure that employees are free to raise concerns without any fear and also that 10 each of those -- if there was a concern brought forward, that it was appropriately 11 inspected, evaluated, and actions put in place.
12 And, finally, we'll conduct what we call a historical data review, and 13 this is -- we do this by doing document reviews and what I would call this, a 14 binning process, really, to take a look to ensure that actions that we have taken 15 and issues we have had in the past were properly characterized and acted upon.
16 And, of course, any deficiency we find in there will be corrected.
17 On slide 11, is the third-party safety culture assessment. That will 18 be performed by Conger & Elsea; they're a nationally recognized firm that 19 provides root cause analysis and safety culture assessments. The assessment 20 is a very important part. We recognize that and really consists of three key 21 elements: behaviors and practices, safety culture, and employee concerns. And 22 the idea of this, the assessment really allows -- we want employees to open up 23 and encourage them to raise concerns and offer opinions about how we do our 24 business at Fort Calhoun.
25 We really recognize the importance of culture and the role that
51 1 safety culture plays in our day to day operation. That's why we've implemented a 2 lot of interim actions, you know, regarding culture and how we get this 3 information. We have daily discussions on a safety culture attribute. We utilize a 4 safety culture advocate, a person that sits in some of our higher-level 5 management-level meetings to just focus on safety culture, where we may have 6 missed an opportunity to utilize and discuss safety culture in a decision-making 7 process.
8 We also do abbreviated safety culture surveys to try to get insights, 9 and a lot of this deals with our messaging and communication to a site to make 10 sure that we're keeping on top of that and seeing what impact safety culture may 11 have on our decision-making interactions. And, with all that knowledge and 12 information, we still recognize that this is an opportunity for us in an area that we 13 have to do better in.
14 Regarding our third-party safety culture assessment, just to give 15 you some perspective, this will be done with survey, individual interviews, and 16 focus groups. And the target population will be all Fort Calhoun Station 17 employees and any consultants or contractors have been on site for greater than 18 six months. The surveys start on the 27th of this month, and we expect the final 19 report in early May.
20 The performance improvement team provides line ownership of the 21 safety culture process and survey, and the key element of our involvement is to 22 make sure that it's an independent assessment. That's got to be key. And then 23 the final report we issue will be rolled up to and factored into our integrated plan 24 and our action moving forward.
25 On slide 12, our corrective action program improvements are vital
52 1 for us because we -- based on our analysis, our corrective action program hasn't 2 served us in the mean that it should. It hasn't been doing the things that we 3 needed it to do. Key elements of our corrective action program culture 4 improvements include a causal analysis that we've done, and really to pinpoint 5 where our corrective action program deficiencies lie. Some key interim actions 6 that we have taken to date primarily deal with more oversight and focus of senior-7 level management, management of the station on corrective action.
8 I've personally given my expectations to all station leadership 9 regarding CAP, the importance of the program, the fact that it is core business. It 10 demands our attention each day, and there's no tolerance for shortcuts.
11 We're demanding higher standards in our analysis and our 12 corrective action oversight, and we're coaching lower thresholds and writing 13 corrective action documents for the entire site. We also are conducting training 14 as part of our causal analysis. We have done an upgrade of our corrective action 15 program. We're actually conducting training on that revised program and the 16 culture aspects of that today. You know, part of that training includes the fact --
17 and what does it mean when we say that corrective action program is core 18 business and how we expect it to be the corrective action program to be used at 19 the site, the fact that we're instituting higher standards for causal evaluation, 20 action item closure, and the level of documentation that's required for closure, the 21 amount of senior management oversight we put in the corrective action process, 22 and our expanded use of training to identify issues early before they become 23 larger issues.
24 On slide 13, I'll discuss some of our plans for assessing selected 25 engineering and maintenance processes and issues. We identified a number of
53 1 engineering and maintenance programs and processes that, in all cases, weren't 2 meeting our needs and expectations. Each area is being thoroughly analyzed 3 and evaluated to identify any past discrepancies and actions that we need to be 4 taken to correct and strengthen the processes and behaviors going forward. The 5 findings in these reviews will be evaluated in the aggregate, and then actions will 6 become part of our integrated plan.
7 Some weaknesses that we are investigating and will continue to 8 investigate really include our degraded non-conforming condition process, our 9 operability evaluations, use of vendor manuals, and the upgrade of those 10 manuals, our configuration control of safety-related equipment, our equipment 11 service lives, safety evaluations and 5059 screenings, and our oversight of 12 vendors.
13 Now, on slide 14, we recognize that our integrated plan will identify 14 our issues, and yet the overarching objective of the entire plan is to improve our 15 performance long-term, and we really ensure this by doing an collective 16 evaluation of each of the individual elements of the plan and then rolling those 17 analysis up and then doing an overall analysis of all the issues. We also do this 18 by developing smart, corrective actions with the appropriate management 19 oversight of the review and implementation and closure of each of those actions 20 by implementing management changes to strengthen and challenge our 21 oversight of the station and our recovery efforts. We also do this by employing 22 external sources. We talked about some of the folks and the help that we've 23 gotten from the industry, and that actually, to lead an oversight our improvement 24 activities and also provide us counsel and direction. Also, by providing long-term 25 oversight, and these are both by internal and external sources of oversight, and
54 1 then we provide check and adjust points within our action plans and interim 2 actions to make sure that we're staying on the path and we're making the 3 improvements at the rate that we expect.
4 Now, what's different today? Well, we're utilizing the systematic 5 approach to evaluate where we are. We recognize that our performance issues 6 are broad, and we have to dig deep to be able to get those on the surface so we 7 can get forth the right actions to correct them. And, really, it's looking at the 8 cultural level and getting it in at the cultural level to ensure these are sustained 9 long-term.
10 Before I turn this back over to Mr. Gates, there's a couple of points I 11 want to reinforce to you. I clearly understand the significance of the position that 12 we're in, and I hold myself responsible for our unacceptable performance. I've 13 never been in this situation before, but you have my word, I will fix it.
14 We're taking a long-term approach, and really, that's looking at this 15 from a performance-improvement perspective, and it really starts with digging 16 deep to get these issues uncovered and then put forth the right action to correct 17 it. I commit to you that we'll focus on nuclear safety each and every day; that's 18 our primary value, our primary focus, and we won't deviate from that. I'll turn this 19 back over to Mr. Gates.
20 W. GARY GATES: Thanks, Dave, and, to you, Mr. Chairman, and 21 the Commission for giving us this opportunity to speak to you today on our plan.
22 As Dave said, and the whole OPPD team, we're serious about safety. We 23 understand that. We understand our obligations to the industry and our 24 responsibilities.
25 I have the privilege of working in this nuclear industry for almost 40
55 1 years now, and I know what Fort Calhoun Station is capable of. I know what the 2 people are capable of there, and with personal interaction, I know their 3 willingness to do the right thing.
4 We will not return Fort Calhoun to operation until we're satisfied and 5 recommended along, I know, with the CAL process from the NRC's point of view.
6 You have my commitment, personal commitment, CEO and Gary that we'll get 7 this fixed. We'll do it right. We'll do it in a very thorough, very professional, and 8 very transparent manner. Thank you and we would appreciate your questions at 9 this time.
10 CHAIRMAN JACZKO: Thank you for that presentation. We'll start 11 with Commissioner Svinicki.
12 COMMISSIONER SVINICKI: Well, my thanks to each of you for 13 the messages that you've delivered here today and for the update you've given 14 on the status of actions at Fort Calhoun Station. I had a chance to visit there. I 15 can't recall specifically when it was. It was probably over a year and a half ago, 16 and it was well before the flooding event and some of the recent events that the 17 NRC staff panel talked about, and I appreciated the opportunity, though, to visit 18 the station and talk to the women and men who worked there.
19 I'm going to touch on a few items, and I want to acknowledge that I 20 know that we're, as the NRC staff panel indicated early in the process, so I 21 acknowledge that up front, but I'm still going to ask some questions, and please 22 respond to the extent that you have the information or details, and you can give 23 some indication of where things stand.
24 I'll start with a very general question. Mr. Gates, you had 25 mentioned that your board and others are fully supportive of making the
56 1 resources available that the station needs to take the actions that will be 2 necessary, and I appreciated your commitment to that. That will obviously be 3 key if things aren't resourced, they can't be accomplished. However, I know as 4 we look forward on some post-Fukushima actions, Fort Calhoun as other stations 5 may be receiving requests for information and other compulsory actions, are 6 there areas where you feel that your response to what NRC might require on 7 those items, which, again, to some level of detail about those actions has already 8 been communicated from the NRC staff to the industry, so you must have some 9 general awareness of what you're looking at in terms of a post-Fukushima 10 response to the NRC. Do any resources, in terms of key niche expertise 11 compete with things that you have, commitments you will have to make under 12 this 0350 process, and, if so, how will you balance that?
13 W. GARY GATES: Let me start that, Commissioner, if I could. The 14 way we're going to handle those capacity requirements to handle both 15 Fukushima -- we're also in the process of transitioning to NFPA 805. We have 16 the emergency preparedness rule that's out that we're working through. We 17 have the cyber and all those issues. We're specifically bringing those separately 18 out of the organization to be managed -- and in concert with the line organization 19 but in a separate function so we get the right focus on it, we devote the right 20 resources to it. As a matter of fact, we have set ourselves an internal goal that 21 we want to lead the country in one of the Fukushima items, which is increasing 22 our station blackout time. As we recover from this effort, we think thats a 23 proactive message and also one that our plant can get its arms around and 24 execute. It being a smaller PWR, weve got a lot of options in that area. So we 25 plan on leading those efforts and not just reacting to them as a unit. Id let Dave
57 1 input some more color around that, but we do understand the additional capacity 2 and we provided that structurally in the organization as well as resource-wise.
3 DAVID BANNISTER: As Mr. Gates just pointed out, its exactly 4 what we have done. Weve -- I dont want to say compartmentized, but we have 5 designated people in the organization focusing on just the Fukushima pieces, 6 going to the various working groups and committee meetings, looking broadly 7 across the industry on the input on what are other sites doing? In some cases, 8 doing the analysis or whats the best practice to be able to implement the right 9 structure or right process. Were doing the same thing with all the other 10 initiatives. One Ill also point to is the security order. And, you know, that is 11 going down the path and has been. Even -- if you can believe this, even during 12 the flood we had activities that were still going in terms of planning processes, et 13 cetera, to get ready for our actions as soon as the flood waters receded to get in 14 there and do the work for the security order. So thats all ongoing.
15 COMMISSIONER SVINICKI: Okay, thank you. And to continue a 16 bit on this theme, but turning now to external support, which youve indicated 17 that, where appropriate, you will supplement your efforts, you have a partnership 18 with Exelon. Id like to turn to the concept, though, of sustainability in recovery 19 versus external support. And Im not saying that external support should be 20 spurned. Theres a lot of really valuable external support, both Exelon and other 21 industry-wide sharing of lessons that you can tap into. As a matter of fact, one of 22 the things I recall from my visit to Fort Calhoun Station, which is in walking from 23 one part of the facility to another I spoke to one of the station executives about 24 the fact that he had an opportunity through INPO to be at another station and 25 how valuable he and others at Fort Calhoun found those opportunities. Again,
58 1 its a comparing of, as he put it, How we do business versus how other people 2 do business. And so obviously reaching out and not becoming insular is very 3 important, but you do need all of your measures to be sustainable for Fort 4 Calhoun Station over the long term. Its this peril of having, you know, fixers 5 come in but then they havent really, once they depart, had you -- really have you 6 invested in something that will be very enduring for the station. How are you 7 approaching that?
8 W. GARY GATES: The -- and Ill let some more comments be 9 made, but the way were approaching that -- thats an excellent point. As Dave 10 said, we integrated the recovery crew. Right now its about two-thirds OPPD 11 people and one-third outside resources. So we want our folks to learn the 12 lessons and then come back into the line organization. Our plant manager, Tim 13 Nellenbach, is going on loan to INPO. And hell be spending his time in a very 14 detailed program in our cooperation with INPO to raise standards and 15 understand whats going on around the country. Because as a single unit, single 16 operated unit, being insular is something you really have to guard against. And 17 we have put those into our plan, as well. So we have integrated crews with the 18 folks.
19 And the other piece is we are going to stay with an outside support 20 as long as necessary until were satisfied that we have the unit sustainable. And 21 it may be a prolonged period of time. Were not sure what thatll be. We are 22 starting those discussions. But we recognize that, particularly in a single unit of 23 our size, it is always going to be a challenge for insularity -- if thats a word. I 24 may have just invented one. I hope not. Or the fact that we will always be 25 capacity-challenged in the degree of -- the way we looked at this, you know, you
59 1 have a station staff thats running and typically every unit has excess capacity 2 that they use for special projects and everything. So we put in new steam 3 generators and head in 2006, and we grew capacity with a single vendor, it was 4 Bechtel at the time. And then we reduced down to our normal staff and we were 5 putting in projects. But if you -- the ones you just mentioned, Fukushima and the 6 other ones we alluded to, take additional capacity, and then layering on top of 7 that. So were going to always be, I believe, in a position to need additional 8 capacity beyond what we have. We had a lot of additional capacity due to our 9 extended power uprate, which we were pursuing, and we have now suspended 10 to focus those resources on this recovery. As a matter of fact, that extended 11 power uprate has provided us some great information because we were doing 12 system reviews to do that, to raise the power level. So we have a lot of 13 information from deep dives, from the extended power uprate that will serve us 14 well as we go through this recovery effort. Dave, I -- but were internalizing those 15 lessons.
16 COMMISSIONER SVINICKI: Okay. Thank you.
17 DAVID BANNISTER: Yeah, we had actually a lot of discussion 18 upfront because we were concerned with the same thing. That, you know, once 19 the cavalry leaves, you know, what does that leave the rest of us? And so my 20 analogy is that the ramp-up is very quick to bring on the additional resource, but 21 theres a slow decay curve of getting those resources out. And the intent of that 22 is that theres a -- that learning has to take place, that theres oversight and 23 challenge as we continue -- once the plant is up and performing at the level that 24 we expect, we want to continue that. So theres a slow removal of this external 25 resource. As were building, you know, our knowledge, improving our
60 1 performance, and really culturally sustaining that new type of culture we want in 2 our organization.
3 COMMISSIONER SVINICKI: That sounds like a very appropriate 4 way. You dont want an abrupt removal of external support, because its gradual 5 removal I think will allow the station to adjust back over time. In military sense 6 we call that surge capacity. But -- the additional capacity that youre talking 7 about. The challenge, of course, will be that with the actions that NRC has under 8 contemplation for Fukushima, all of the industry will be surging at the same time.
9 So theres going to be limited, as I call them, smart nuclear people across the 10 country to put on some of these questions. You have a very near-term need in 11 terms of your recovery process from the 0350. So it sounds like youve done a 12 lot of thinking about that upfront and I appreciate that.
13 In my brief remaining time Im going to ask you -- although its not 14 really central to todays meeting, I cant help but have a curiosity about the 15 extreme flooding event that you experienced. As you think about that at a high 16 level, do you feel that there are generic lessons for the industry that youre going 17 to be able to draw from that extreme natural event, and is there anything that you 18 could share in terms of kind of inter-organizational or inter-agency cooperation, 19 state, FEMA, and others? Will you be looking on any Lessons Learned there that 20 you could feed back into other peoples Lessons Learned system?
21 W. GARY GATES: We have a detailed Lesson Learned document 22 thats still under development but has quite a bit of legs under it to address those 23 issues, and we certainly will. We do have -- we think we can offer to the industry 24 some insights. And I would just give one, in the interest of time, and Dave may 25 have others. I think its the length of time that you may be in an external event.
61 1 Most plant events, pretty quick, typically. But external events can end up being 2 very, very protracted. And that brings on a whole new set of challenges, as when 3 the Chairman was out seeing us, I mean, to the point where youre carrying copy 4 paper in by hand just to run procedures for operators to use and those kind of 5 things. So I think the looking at the length of time is just an example of one of the 6 insights.
7 COMMISSIONER SVINICKI: Did -- Mr. Bannister, just quickly, did 8 you want to add anything?
9 DAVID BANNISTER: And I know the Chairman was out and saw, 10 we actually met at the Corps of Engineers Head Office, which is only four or five 11 blocks away from our corporate office. And that was the one thing that I saw, is 12 very early on when we started -- you know, because every day -- we live on the 13 river, so every day were looking at their websites, were looking at the river, 14 looking at the National Weather Service, and we were seeing this. And then its 15 that dialogue upfront and early. Thats what gave us the early indication that, you 16 know, this wasnt something that was, one, going to go by quickly. And thats 17 why, in our dialogue with them -- even though they werent necessarily projecting 18 the river levels that we saw eventually, with that early insight we took early 19 action. And so that gave us time and really allowed us -- the safety part of the 20 plan is easy to protect, because thats what the procedures designed to do. But 21 we protected all the, you know, millions of dollars of asset around the site. And it 22 was that early dialogue and early conversations that we had with the Corps of 23 Engineers, the National Weather Service, and other state agencies and federal 24 agencies that helped us make those decisions.
25 COMMISSIONER SVINICKI: Okay. Thank you. Thank you, Mr.
62 1 Chairman.
2 CHAIRMAN JACZKO: Commissioner Apostolakis?
3 COMMISSIONER APOSTOLAKIS: Thank you. Mr. Bannister, you 4 had a series of slides where you described your integrated performance 5 improvement plan, flood and recovery, reactor safety, correcting performance 6 deficiencies, and so on. Actually, what I would be more interested in is to know, 7 in your opinion, what were the top two or three areas where you feel you went 8 wrong and you ended up in this unhappy situation?
9 DAVID BANNISTER: Well, I would call it more than an unhappy 10 situation.
11 COMMISSIONER APOSTOLAKIS: Unfortunate?
12 DAVID BANNISTER: Yeah. What I really point down to, the one 13 issue is our corrective action program culture, our -- and its a culture that 14 evolved over time. We looked at it more of a work driver, more of a -- you know, 15 its a way to manage the system rather than being this is the work that we do, its 16 finding and correcting our performance deficiency. That is the work that we do 17 in our business, and so if I can point to one thing, that is the one area, where 18 over time, that we didnt hold a high standard there. The other is, really, it falls 19 upon the shoulders of leadership. We werent holding our people accountable, 20 particularly with the corrective action program, to identify issues at a low level 21 and kill them dead. And wed continue to have these issues reappear or wed 22 have an -- whether it be an equipment deficiency or, you know, our procedural 23 item or a behavior. That we did not jump on that. You know, and thats a 24 leadership issue, and that also requires some cultural change within the 25 organization. And, quite frankly, it involves some management change at our
63 1 site. One of the things that weve also done is by bringing on Exelon Nuclear 2 Partners, they recognize they have a significantly different culture than we do, 3 and thats not by accident that we reached out to them to give us that type of 4 insight.
5 COMMISSIONER APOSTOLAKIS: You are part of the USA --
6 what is it?
7 DAVID BANNISTER: Utility Service Alliance?
8 COMMISSIONER APOSTOLAKIS: Yeah.
9 DAVID BANNISTER: Yes.
10 COMMISSIONER APOSTOLAKIS: You are part of it.
11 DAVID BANNISTER: Correct. Correct.
12 COMMISSIONER APOSTOLAKIS: So did you have outside input 13 or support from your fellow members?
14 DAVID BANNISTER: We do. And its -- some of it is prescribed 15 that we have, and its -- you know, its -- you know, that we get monthly, 16 quarterly, et cetera. Much of it, though, is on demand. When we ask for it, you 17 know, they come in and provide it. And, you know, what I will tell you is that in all 18 cases that didnt get to the right level. You know, now I see that. Its very clear 19 to me that, you know, with management and leadership and in some cases 20 sharing of those leaders, having them go to another site, see what they do with 21 related -- whether it be engineering or corrective action, and then bring that 22 information back. We need to do a better job of that.
23 COMMISSIONER APOSTOLAKIS: Yeah. Im curious, because, 24 Mr. Gates, you mentioned the potential for insularity. And being a member of 25 USA probably thats a way of fighting against it. But evidently it didnt work very
64 1 well.
2 DAVID BANNISTER: Well, certainly we didnt apply it in the right 3 areas. We do a very good job in the areas of training and qualification. Maybe 4 with particular operator performance issues and how we evaluate them, and the 5 standards with crews. We needed more work on just -- you know, I would call 6 the blocking and tackling, of finding and fixing our issues and killing them dead.
7 There was an opportunity of course that we missed.
8 COMMISSIONER APOSTOLAKIS: Yeah, yeah. Well, its 9 interesting that you identified the corrective action program is the number one. I 10 mean, weve always believed that this was the cornerstone of a good culture, a 11 good performing plant, and so on. So you confirmed it once again. Well, thank 12 you very much, Mr. Chairman. Back to you.
13 CHAIRMAN JACZKO: Commissioner Magwood.
14 COMMISSIONER MAGWOOD: Thank you. And, welcome. This 15 is a -- you know, first, I appreciate Commissioner Svinicki mentioning the flood.
16 Lets just go into -- you know, indicated -- as that situation unfolded, you know, 17 we like many other people in the country were watching you deal with that. So I 18 just wanted to say I appreciate that, you know, the unusual circumstances, you 19 know, beyond the performance issues we talked about today, of just dealing with 20 that natural disaster and -- not just for the plant, but obviously for the people that 21 work at the plant, who live in the region. And I have no doubt that there were 22 people who were personally affected by the flood, so I just wanted to pass on 23 that --
24 DAVID BANNISTER: Thank you.
25 COMMISSIONER MAGWOOD: -- you know, certainly that was
65 1 something we were -- in our thoughts during that time. The -- one thing I wanted 2 to -- and Commissioner Apostolakis, he often steals my questions because he 3 gets to go before me. So hes done that again. But one thing -- as he was 4 having the dialogue about what were the issues you thought got you to this 5 place, one thing that Mr. Gates in his remarks was, you know, That we lost our 6 edge. And Im just curious, because, you know, while we have a very 7 systematic way of thinking about nuclear safety performance, nuclear culture, 8 theres always, as leadership, you have a sense as to where things -- or when 9 things are going right and when things are going wrong. And Im just curious, do 10 you -- and you dont even have to give me the answer if you know what it is, but 11 do you have more or less a gut feeling as to where things started to go wrong, 12 where things started to go off the tracks? Were there personnel changes, 13 organizational changes that you can think back and identify that led you down the 14 path to where we are today?
15 W. GARY GATES: Let me start with that. I think it was so subtle 16 and so slow in many cases, that I think -- and something made sense very 17 recently to me, I believe from a presentation given to you by Ed Halpin on faint 18 signals of human performance. How do you pick those up? And its best picked 19 up by being present and talking to people and that sixth sense. I think our 20 performance, if you look back at our indicators, and Commissioner Svinicki 21 indicated -- I mean, we -- if I just looked at data, we had a lot of good operations 22 up until perhaps even the flood time. But if I look back in the context of those 23 most recent comments -- which Im reflecting a lot on my role in this and how we 24 got here and what we need to do for the future. I think it was those faint human 25 performance signals that we missed. I cant point to a specific personnel change
66 1 or a specific watershed kind of an event. As Ive reviewed it, going forward, I 2 think, you know, the flood is not the reason. It was a factor, but it was there. But 3 we -- when I said, Lost the edge, its to what Dave referred to as our 4 accountability to our systems. Its all about people and its all about leadership at 5 the end of the day. And so thats where the issue is, is we missed some signals 6 along the way, that we are -- and what have already corrected and what we will 7 correct in the future -- paying attention to those faint human performance signals.
8 That really resonated with me when Ed talked about that.
9 COMMISSIONER MAGWOOD: I dont know, Mr. Bannister, 10 anything to add?
11 DAVID BANNISTER: You know, I -- and Ive read the same 12 document about the faint signals, and as a matter of fact Ive read that document 13 on the plane ride here. And -- you know, and I thought back about the same 14 types of things and, you know, is there a particular point in time where, you know, 15 Hey, things arent going quite right? I couldnt necessarily pinpoint that. But I 16 can go back and think about, you know, there were things, you know, with the 17 contactor issue, with the M2 contactor protective system. That, you know, our --
18 we tend to look at our process and providing and supporting us, but in some 19 cases those are leadership and management decisions that, you know, even 20 though we had worked through our process and said, you know, it was 21 acceptable to go repair it, you know, as a leadership team we should have said, 22 Well, wait a minute. This isnt right. And those are the types of things, the faint 23 signals that we got to keep asking ourselves. And, you know, thats -- what I 24 impress upon the staff is to look -- I dont necessarily call them faint signals, but 25 look for the signs. If youre asking yourself -- you know, constantly asking
67 1 yourself this question, Well, boy, that doesnt seem right, thats telling you 2 something. Go act on that. Go pursue that. And then get the staff together and 3 sit down, because chances are theyre saying the same things, Boy, this doesnt 4 seem right. And thats that whole cultural learning for the entire organization.
5 John, do you got anything to add there?
6 JOHN HERMAN: I would say the early signs for me, the condition 7 reporting system backlog was too big, and we knew that and we didnt address it.
8 The number of root causes and apparent causes that we were required to do 9 was higher than normal, and we didnt address that. When we looked at our 10 corrective actions that came out of those root causes and apparent causes, 11 frequently we found we were shooting maybe 85, 90 percent, but we missed one 12 or two things. And then the timeliness issue. Things were scheduled, the right 13 things were there; eight or nine of them got done, but not all 10. Those were the 14 early signs for me looking back on it saying, What did we miss? We allowed 15 that. So what you had was a number of very low-probability events that were 16 unlikely to escalate, but when you had enough of them on the table, somethings 17 going to occur. So the need to drive those numbers down, keep the backlogs 18 low, and resolve things in a timely fashion so that you take them off the table.
19 There isnt that one item out of 10 thats still hanging out there.
20 COMMISSIONER MAGWOOD: I appreciate that. Really quite --
21 very interesting. You mentioned earlier that -- you talked about the external 22 resources youre bringing in to help right the ship, so to speak. And I thought you 23 had a good dialogue with Commissioner Svinicki about that. But one aspect of 24 that I wonder about is you look at where these external resources are coming in 25 to supplement your staff, are there areas where your staff was actually lacking in
68 1 experience or expertise that concern you now that you have those resources in 2 place, now that you can see what others are bringing to the table? Are there 3 areas where you now know that you need to build staff?
4 W. GARY GATES: I would say -- and Ill start this. I can -- John 5 will probably add to this, but our engineering group -- weve got about half of the 6 engineers that are new there. And if I looked broadly at the utility, theres some 7 interesting statistics. And Im not trying to change the subject, but just the 8 numbers for us for utility, for when I started this would be an unusual number, but 9 in the next five years over half of our folks will have less than 10 years 10 experience in the whole utility; and that is also mirrored at Fort Calhoun Station.
11 So what we have found is weve gotten some external resources in that have 12 more layers of experience, particularly in Johns area where he is taking on a 13 very aggressive task of qualifying our new engineers. And theyre well-trained 14 and qualified. Whats the experience factor and how much does that add in, and 15 how do we transfer that? Thats going to be the key issue. But thats one of the 16 key points for me. And that kind of change that I think were not unusual in going 17 through, having a very high percentage of new people. And how do you transfer 18 that experience factor?
19 COMMISSIONER MAGWOOD: And I -- actually, I dont think that 20 changes the subject. I think thats probably a large part of it, because theres a 21 big demographic shift thats taking place in the industry. Its a big demographic 22 shift thats happening here at NRC. And there is a transition, and managing 23 those transitions -- you know, we have a big knowledge management program at 24 NRC, trying to transfer the knowledge and experience as best you can from 25 people whove been around for -- you know, for decades to people who just
69 1 graduated perhaps five years ago. And thats not an easy matter. So I know 2 thats something the whole industrys dealing with, and perhaps as you go 3 through this thats an important lesson learned for others. Because its probably 4 one of those subtle things that doesnt leap out in your ROP, but there certainly is 5 an ongoing trend that can affect performance. But, again, well be watching very 6 closely. I do appreciate the personal commitment that youve talked about today.
7 I think thats where recovery begins with the leadership and I think that thats 8 exactly the right kind of message to be sending. So appreciate your comments.
9 Thank you.
10 CHAIRMAN JACZKO: Commissioner Ostendorff?
11 COMMISSIONER OSTENDORFF: Thank you, Mr. Chairman. I 12 want to thank you all for your candor today. I didnt expect anybody to come in 13 here and make any excuses. Ive had some dealings with you all in the past. I 14 know youre all pretty straightforward people, accept responsibility and 15 accountability. So I just wanted to echo the importance of that, but I appreciate 16 how you presented yourselves. My colleagues raised some great questions and 17 points, I think. Commissioner Apostolakis on corrective action program piece, 18 which was the question I was going to ask, and I think that was really my 19 experience in the Naval Reactors Program goes to the heart. If you dont have a 20 way of going about methodically fixing problems, then any list of actions to take is 21 just -- its not worth the paper its printed on. And then Commissioner Svinicki 22 and Commissioner Magwood talking about sustainability piece. I know its of 23 critical importance to you as a single unit operation, and I think we all appreciate 24 the challenges that you have when you have just that one unit thats part of your 25 organization.
70 1 And I know that others have addressed this issue, as to how youre 2 using Exelon, INPO, and so forth. Let me just provide a data point, because 3 were all creatures of our experience, that really framed my experience as a 4 submarine officer. It wasnt until after I had finished being a commanding officer 5 of a submarine, so I had 19 years of Commission service. In the four years after 6 that, I went to sea on 30 different submarines: Atlantic fleet, Pacific fleet. And I 7 was observing the ships cleanliness formality of operations, torpedo shooting, 8 missile launch abilities, et cetera. I was shocked at the wide spectrum of levels 9 of performance in those 30 submarines. But it wasnt until after Id been captain 10 of my own ship that I had the chance to go do that.
11 And so as a single unit operation you probably dont have a whole 12 lot of flexibility to send people elsewhere, but to the extent you have an 13 opportunity to send some midlevel managers for periods of time. And, Dave, you 14 already talked about that a little bit in your presentation that caught my attention.
15 Id just say, I think thats very valuable to see how are others doing it well? Its 16 easy to say, Well, this is screwed up over here. This is not the way of doing it.
17 But seeing a positive example as to how these operations, whatever aspect of 18 your operations youre talking about, how are they being done well? That, to me, 19 is -- pays huge dividends. Im not trying to lecture you, but providing an 20 analogous experience Ive seen work in a different setting.
21 Gary, let me ask you a question. Given all thats been said today 22 and Ive heard a lot of comments that seem to me to reflect significant self-23 assessment reflection by you and your team, how do you assess your 24 workforces receptivity to making the changes that you think, as the CEO, are 25 necessary in order to get to where you want to go?
71 1 W. GARY GATES: I appreciate that question, because thats one 2 thats near and dear to me. And Ill tell you exactly how I do it. I go out and ask.
3 Theres nothing more than personal contact thatll allow you to assess that. So 4 Im out in spaces, Im understanding -- asking people about it. Weve had direct 5 meetings with all our unions and all their E-boards, and even though they may 6 not be working at Fort Calhoun, theyre working in other parts of the company.
7 The entire company is willing to help Fort Calhoun get better. And its by 8 personal interaction that I make that assessment. There are other more formal 9 areas. Ive started a practice called Sunrise Meetings. I think it gets its name 10 because they start at 6:30, and theyre very structured in the sense that all 11 groups are there to go over information and specific questions. They vary from 12 meeting to meeting.
13 The second thing I do is I walk down a system with a system 14 engineer and take operators and find out what theyre thinking about it, as well as 15 a system engineer. I found that that allows the system engineer to have a 16 candidness when the operators standing there talking about the system and its 17 operation, as well.
18 And then the third, I go to training and I assess by interaction with 19 the training staff and with operators there what their willingness to change is. So 20 its by personal interaction, Commissioner. And they are willing to change.
21 COMMISSIONER OSTENDORFF: Okay. I dont have any other 22 questions. Im not going to say good luck, because that -- you know, you dont 23 get out of bad situations by luck. Its just by hard work and persistence. So I 24 wish you well in your endeavors.
25 W. GARY GATES: Thank you.
72 1 CHAIRMAN JACZKO: Well thank you, and I dont have any other 2 questions, either. I think many of the issues have been covered already and the 3 staff I think has a good process and I encourage you to continue to interact with 4 them, and theyll interact with you, and heed their areas of focus and well, Im 5 sure, have an opportunity to interact in the future as you continue to make 6 progress on your recovery. Thank you.
7 W. GARY GATES: Thank you, sir. Thank you.
8 [Whereupon, the proceedings were concluded]