ML18219D102
| ML18219D102 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/2018 |
| From: | Kent Howard Advisory Committee on Reactor Safeguards |
| To: | |
| Howard K | |
| References | |
| NRC-3817 | |
| Download: ML18219D102 (242) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Plant Operations and Protection Subcommittee Docket Number: (n/a)
Location: King of Prussia, Pennsylvania Date: Thursday, July 26, 2018 Work Order No.: NRC-3817 Pages 1-242 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
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2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
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PLANT OPERATIONS AND FIRE PROTECTION SUBCOMMITTEE
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THURSDAY JULY 26, 2018
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KING OF PRUSSIA, PENNSYLVANIA
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The Subcommittee met at the Nuclear Regulatory Commission Region I Office, 2100 Renaissance Boulevard, at 8:15 a.m., Gordon Skillman, Subcommittee Chairman, presiding.
COMMITTEE MEMBERS:
GORDON SKILLMAN, Subcommittee Chairman MICHAEL L. CORRADINI, ACRS Chairman RONALD G. BALLINGER, Member WALTER L. KIRCHNER, Member JOSE MARCH-LEUBA, Member JOY L. REMPE, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 DESIGNATED FEDERAL OFFICIAL:
KENT HOWARD STAFF PRESENT:
JACK GIESSNER, Acting Deputy Regional Administrator, Region I DAVE L. PELTON, Deputy Director, Division of Reactor Projects, Region I MICHELLE CATTS, Senior Project Engineer, Division of Reactor Projects, Region I MATT YOUNG, Branch Chief, Division of Reactor Projects, Region I STEVE HAMMANN, Senior Health Physicist, Division of Nuclear Materials Safety, Region I CHRIS CAHILL, Acting Branch Chief, Division of Reactor Projects, Region I GLENN DENTEL, Branch Chief, Division of Reactor Safety, Region I FRANK ARNER, Senior Reactor Analyst, Division of Reactor Safety, Region I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 CONTENTS Opening Remarks and Objectives.....................4 Region I Overview.................................10 Reactor Oversight Program Performance Summary .....24 Pilgrim Inspections Procedures....................50 Regional Communications...........................74 Backfit...........................................96 Engineering Program Inspections/Environmental Qualification Inspection Insights..........106 FLEX Equipment...................................133 Public Comments..................................161 Adjourn..........................................168 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 8:15 a.m.
3 CHAIRMAN SKILLMAN: Ladies and 4 gentlemen, good morning. This meeting will come to 5 order.
6 This is a meeting of the Plant Operations 7 and Fire Protection Subcommittee of the Advisory 8 Committee for Reactor Safeguards.
9 Im Gordon Skillman, Im Chairman of the 10 Subcommittee.
11 ACRS members in attendance today are Dr.
12 Ronald Ballinger, Dr. Walter Kirchner, Dr. Jose 13 March-Leuba, Dr. Michael Corradini who is also the 14 ACRS Chairman, and Dr. Joy Rempe.
15 Kent Howard of the ACRS is -- of the ACRS 16 staff is the Designated Federal Official for this 17 meeting.
18 A comment about who we are, what is the 19 ACRS? We are a group of approximately 15 20 professionals whose task it is to advise the 21 Commissioners on all matters nuclear, whether its a 22 change in regulation, change in policy, power 23 uprates, life extensions, changes in license, changes 24 in basic regulation.
25 My colleagues and I meet two times a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 month and, out of approximately 15 subcommittees 2 process this work collaboratively with our peers.
3 We review and advise the Commission with 4 regards to licensing and operation and production and 5 utilization facilities and related safety issues, the 6 adequacy of proposed reactor safety standards, 7 technical and policy issues related to the licensing 8 of evolutionary and passive plant designings and 9 other matters that has been referred to the ACRS by 10 the Commission.
11 The purpose for this briefing is for the 12 staff to discuss items of mutual interest, namely 13 regional inspection and operational activities.
14 We are particularly interested in 15 oversight of plant closures and plants that have been 16 admitted to 95002 and 95003 inspection oversight.
17 The Subcommittee will gather 18 information, analyze relative issues and facts and 19 formulate a proposed position and action, as 20 appropriate, for deliberation by the Full Committee, 21 if needed.
22 We are a portion of the Full Committee, 23 and in this Subcommittee meeting, we speak as 24 individuals, we do not speak for the ACRS.
25 The ACRS communicates through its letter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 reports and only through its letter reports, as we 2 are a Subcommittee and we are here as individuals on 3 the Subcommittee.
4 The rules for participation in todays 5 meeting were announced as part of the Notice of this 6 meeting previously published in the Federal Register 7 on July 16, 2018.
8 The meeting will be open to the public 9 attendance with exception of portions that may be 10 closed to protect information that is proprietary 11 pursuant to 5 USC 52(b)(4).
12 We have received no written comments or 13 requests for time to make oral statements from 14 members of the public regarding todays meeting.
15 A transcript of the meeting is being kept 16 and will be made available as stated in the Federal 17 Register Notice. Therefore, we request that 18 participants in this meeting, please use the 19 microphones located throughout the meeting room when 20 addressing the Subcommittee.
21 Participants should first identify 22 themselves and speak with sufficient clarity and 23 volume so that they can be readily heard.
24 A telephone bridge line has been 25 established for this meeting. To preclude NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 interruption of the meeting, please mute your 2 individual lines during the presentations and 3 Committee discussions.
4 I also ask that you please silence all of 5 your electronic devices.
6 As we begin, I want to acknowledge our 7 recognition of and appreciation for the regional 8 inspection organization and the inspectors for their 9 efforts and toil to inspect our nuclear facilities, 10 to enforce regulation. We see you as a critical part 11 of the NRCs team and key and central to protecting 12 our nations nuclear safety culture.
13 Thank you.
14 Im going to begin by simply saying, Im 15 Dick Skillman, Im Chairman of the Subcommittee. I 16 have 52 years of nuclear experience.
17 I interacted energetically often with 18 Region I in my years at Three Mile Island. And, I 19 noted in passing that Jim OReilly has just passed 20 away. Jim was the first administrator here in Region 21 I.
22 And, I worked with Jim, hold your socks, 23 Jim was a true inspector when Region I was in Newark, 24 New Jersey. And, Dr. Kirchner and I were officers 25 on the Nuclear Ship Savannah.
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8 1 And, Jim OReilly was the type of 2 individual that would visit the ship at 2:00 in the 3 morning, 4:00 in the afternoon, dinner time, 8:00 at 4 night, he would just simply show up and inspect.
5 And, he was making sure we were behaving and doing 6 our work properly.
7 So, we became very aware of what the word 8 inspection through Jim.
9 With that, Ill ask my colleagues if they 10 wish to introduce themselves. And, well start with 11 Dr. March-Leuba.
12 MEMBER MARCH-LEUBA: Yes, my name is Jose 13 March-Leuba. Im one of the newest members of ACRS, 14 not the newest member, but one of them.
15 And, my background is on the coal system 16 analysis instrumentation and such. So, if anyone in 17 the audience, anything you need, just call me, okay?
18 (Laughter) 19 MEMBER BALLINGER: My name is Ron 20 Ballinger and Im -- my area is fuels and materials.
21 DR. CORRADINI: Mike Corradini, I am in 22 the area of safety and thermohydraulics energy.
23 DR. REMPE: Hi, Im Joy Rempe. I -- my 24 background is primarily at the Idaho National 25 Laboratory in research areas of severe accident NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 research and instrumentation to support the DAST test 2 reactor.
3 DR. KIRCHNER: Walt Kirchner and my 4 background is reactor design and reactor safety. I 5 spent 30 years at Los Alamos and with Argonne. And, 6 as Dick mentioned, we were on the Savannah in the 7 1960s. So, that makes us ancient mariners.
8 (Laughter) 9 CHAIRMAN SKILLMAN: And, with that, we 10 will proceed with the meeting and I call upon Jack 11 Giessner, Acting Deputy Regional Administrator, 12 Region I to make his introductory comments, please.
13 Thank you.
14 MR. GIESSNER: Thanks, Mr. Skillman.
15 Can everybody hear me okay? And, welcome 16 ACRS to Region I.
17 My boss, Acting Regional Administrator, 18 Dave Lew, sends his regrets that he couldnt make it 19 today. Hes on a retreat with the leadership team 20 of the NRC in Chicago.
21 What I wanted to share with you was some 22 insights that we have that we think youll find 23 interesting and I think youll see a theme throughout 24 of the importance in the region regional inspection 25 activities.
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10 1 I think our independence and our 2 technical knowledge helps provide that insight to 3 you.
4 I know we had a good tour yesterday with 5 Matt and Scott at the NRC. And, a lot of the topics 6 we talked about, for example, FLEX and plants and 7 decommissioning, well talk about in more detail.
8 Were also going to share some additional 9 oversight that were doing on some plants that have 10 some performance issues. So, well talk about that 11 as well.
12 Before we get started, I wanted to share 13 a little logistics and safety. So, if we do need to 14 leave the building, youll be escorted but well go 15 out the doors you came in.
16 And, if we have to leave, well go down 17 the stairs that are directly to your right, my right 18 as we go out. And, we would exit the building.
19 If we had to stay inside, we would go to 20 an inside office if it was, for example, a tornado 21 coming.
22 Once we go outside, were going to ask 23 that everybody muster in the area of the circle which 24 is toward the center section. Our building is sort 25 of L-shape to go there so we can account for everybody NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 here, so from a safety and security standpoint.
2 Now, a little review on Region I. If you 3 see in that first bullet, it talks about our mission.
4 You know, using reasonable assurance to protect the 5 health and safety of the public, promote common 6 defense and assure the protection of the environment.
7 If you see several business lines, we 8 have the operating reactor business line, we have dry 9 fuel storage which we saw yesterday when we went out 10 to the pad, we have that business line.
11 We have decommissioning of power 12 reactors, we have decommissioning of complex 13 materials sites and we also have materials which is 14 not in the reactor business line for medical and 15 industrial.
16 In addition, we have our resource 17 management which is mission support which, again, is 18 another business line.
19 If you look at overall staffing, we have 20 204 employees. Last time the ACRS was here, it was 21 2013, its a 15 percent reduction in personnel, 22 mostly just due to reduction in the reactors.
23 We have qualified over a 100 qualified 24 inspectors in materials and reactors. And, some are 25 actually cross-qualified in both.
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12 1 I wanted to share a little bit on the 2 baseline inspections. Every site, I think, as you 3 know, gets baseline inspection additionally if a 4 plant has findings or violations that are more than 5 very low significance, they get additional 6 inspection.
7 95001 has listed there are that -- is 8 that first level, if you have a white finding or a 9 couple white findings, there was on the order of tens 10 of hours for follow up.
11 We do have Pilgrim which Michelle Catts 12 is going to talk about in detail where we do thousands 13 of hours of inspections when we do more of a 14 diagnostic look to see whats impacting the site.
15 Whats the causes?
16 And, finally, one of our core missions, 17 mission essential functions is responding to events, 18 which you saw there.
19 Yes?
20 DR. REMPE: So, ACRS just interrupts 21 speakers, Im not sure --
22 MR. GIESSNER: Thats okay.
23 (Laughter) 24 DR. REMPE: But, you said you had a 15 25 percent reduction in staff. How many plants have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 really shut down and then you acknowledge youre 2 doing a lot of inspections on Pilgrim.
3 I just am wondering about the balance of 4 the reduction in staff versus, you know, your need to 5 be still doing the inspections and if its 6 appropriate?
7 MR. GIESSNER: Well, I think as far as 8 the appropriate, were going to do the right 9 inspections to ensure that we ensure that Pilgrim can 10 operate safely. So, thats how I would enter that 11 argument.
12 And then, if we need assistance, and I 13 believe Michelle can make sure she nods or something, 14 can correct me, I believe we use resources from other 15 regions who also assist in that.
16 So, we have a team effort. And, it also 17 gives a different look between regions. Am I right 18 on that, Michelle? Okay, thanks.
19 MS. CATTS: And headquarters.
20 MR. GIESSNER: And, headquarters, 21 thanks.
22 MEMBER REMPE: Thank you.
23 MR. GIESSNER: A little bit on the 24 operating reactors, this goes into -- we have all 25 different types of pressurized water reactors. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 have Westinghouse, Western Engineer, BMW, different 2 types of BWRs.
3 If you look on ISFSI, I believe all the 4 reactor sites have ISFSI with the exception of Three 5 Mile Island, which is planning on building a pad.
6 CHAIRMAN SKILLMAN: Before you proceed, 7 let me go back to the last slide, please?
8 MR. GIESSNER: Yes, sir.
9 CHAIRMAN SKILLMAN: I have my 10 supplemental, four of the 95001, one 95003. Are the 11 four plants that are in 95001 part of a trend? Or, 12 are those just spontaneous events at four different 13 sites where they crossed into white territory for a 14 couple of findings?
15 MR. GIESSNER: If you could, now, of 16 course, Dave Peltons going to talk in detail about 17 the follow-up inspections.
18 CHAIRMAN SKILLMAN: Okay, I didnt know 19 that.
20 MR. GIESSNER: I would say that theres 21 no trend per se. but, hes going to talk about that 22 --
23 CHAIRMAN SKILLMAN: Okay.
24 MR. GIESSNER: -- in detail.
25 If you have a question after that, Ill NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 let Dave answer that.
2 CHAIRMAN SKILLMAN: Okay.
3 PARTICIPANT: Oh, lets wait until then.
4 CHAIRMAN SKILLMAN: That will be fine.
5 Thank you.
6 MR. GIESSNER: And, heres just a 7 geographic location of our power reactors where we 8 regulate.
9 CHAIRMAN SKILLMAN: Is there any 10 oversight at Wisconsin for Maine Yankee?
11 MR. GIESSNER: I assume -- oh for Maine 12 Yankee, yes. We have a dry fuel storage. Between 13 every two and three years, we do an inspection for 14 safety and security at all locations that have dry 15 fuel storage.
16 CHAIRMAN SKILLMAN: Thank you.
17 MR. GIESSNER: I wanted to show -- this 18 is materials, though theyre not part of the ACRS 19 charter, per se, but it gives a little bit of the 20 detail of material safety where we have a large 21 business line that license and inspect materials.
22 Now, we also have Agreement States. If 23 a state can show that they can support an 24 infrastructure, the NRC will authorize them to 25 perform the function for inspection and licensing.
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16 1 And, the NRC actually relinquishes the authority 2 there.
3 But, we periodically assess that and, of 4 course, we have an Agreement State officers that 5 check on that.
6 DR. CORRADINI: Maybe the less coal 7 mining -- and I think we might be asking the same 8 question.
9 So, you do some of the Region II 10 business?
11 MR. GIESSNER: Yes, to that, so, yes.
12 When it comes to materials and decommissioning, 13 Region I's area actually goes in.
14 For example, Crystal River is under 15 Region I's purview for decommissioning.
16 DR. CORRADINI: Okay.
17 MR. GIESSNER: And, for materials, 18 although most of the southern states are Agreement 19 States, you see that Puerto Rico is in there. And 20 so, that would be something thats under our purview.
21 Thats not an Agreement State and so, we inspect that.
22 CHAIRMAN SKILLMAN: What is in Puerto 23 Rico and what is in the Virgin Islands that you would 24 be inspecting?
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17 1 locations, they have gauges, they have different 2 industrial materials.
3 Remember, it can be as small as a gauge 4 thats used to determine the thickness of a road to 5 a medical facility or a blood irradiator.
6 So, theyre -- I dont know if anybody in 7 materials is here for the number of licenses we have 8 in Puerto Rico, is it a couple hundred?
9 (Off-microphone comments) 10 MR. GIESSNER: One hundred and -- I told 11 you I have some good clients that are going to help 12 me.
13 CHAIRMAN SKILLMAN: Salute, Im really 14 impressed. I did -- it just never crossed my mind 15 until I saw all this traffic.
16 And, thank you, thank you very much.
17 MR. GIESSNER: And, I wanted to -- I have 18 two more slides.
19 As we talked about, theres a lot going 20 on. We have oversight at Pilgrim which takes several 21 thousand hours.
22 We have multiple sites looking to shut 23 down, right? Oyster Creeks going shut down here in 24 September of 2018, Pilgrim in 2019, Three Mile Island 25 in 2019, Indian Point 2 and 3 in 2021 and 2022 or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 2020 and 2021 and Beaver Valley likely in 2021.
2 In addition, I talked about that 3 Agreement State status, it takes a lot of work for 4 the Agency to process an Agreement State and the 5 region has to support that.
6 So, theres a lot of change going on.
7 In addition, theres transformation 8 initiatives and process changes in headquarters.
9 So, with everything thats going on, I 10 like to say that, we still need to be grounded in our 11 mission. Thats our function here is to ensure the 12 adequate protection to health and safety of the 13 public.
14 And so, thats the stress that the folks 15 here that are going to speak and the support staff 16 and the inspectors look at on a daily basis.
17 And so, Id like to leave you with the 18 Region I mission if youll --
19 MEMBER MARCH-LEUBA: Before you get into 20 that --
21 MR. GIESSNER: Yes, sir?
22 MEMBER MARCH-LEUBA: Yes, we mentioned 23 before, I understand theres actually including what 24 made those figures? Who gave you the nuclear --
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19 1 so they can see those going.
2 MEMBER MARCH-LEUBA: You still didnt 3 ask that you were limiting and what was the experience 4 with fuel operations? Because thats what we based 5 it on.
6 And, for the background effort, whatever 7 are GNS or the GNS3 fuel line, there seems to be a 8 lot of the reviewing and then you forget about it.
9 And, its up to the region for -- and see 10 if there are any trends and failures.
11 So, I ask, what is the experience with 12 fuel leakers to Region I? Have you seen a trend with 13 the new fuels and new filters?
14 MR. GIESSNER: I think, Dave, do you want 15 to provide a little bit of data on that? I think we 16 are seeing a trend.
17 MR. PELTON: Do you want me to come up?
18 MR. GIESSNER: Yes, why dont you come 19 up and chat about that. We were going to let Dave 20 start, but let him talk now would be good.
21 MR. PELTON: Good morning. Dave Pelton, 22 Deputy Director of the Division Reactor Projects here 23 in Region I.
24 Thanks, Jack, and thanks for the 25 Committee for coming to day.
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20 1 In regards to fuel defects, we have seen 2 a recent increase in reported fuel defects from a 3 number of the licensees in Region I.
4 We believe our count is probably still 5 under inspection. We have a pretty good inspection 6 footprint. And, by virtue of that, we are engaging 7 with the licensees to seek to understand what actions 8 theyre taking both, are they conducting appropriate 9 power suppression testing to limit the impacts on 10 reactor coolant activity?
11 Are they operating -- continuing to 12 operate their plant safely and consistent with their 13 core operating limits report?
14 Additionally, we have experts here in the 15 region who are fuel heavy, say, they understand fuel 16 technology. They understand fuel defect history.
17 Weve been engaging with them to help the resident 18 staff to understand and get their arms around what 19 could be possible causes such as the licensee 20 explores whether its a foreign material issue or an 21 operational issue or a manufacturing issue. Do we 22 think those are reasonable conclusions?
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21 1 Clifford, who is a fuels expert and provides us with 2 a lot of support.
3 He is well aware of the sites right now 4 which brings these -- sites such as Nine Mile Point, 5 Hope Creek, Fitzpatrick, Calvert Cliffs actually, a 6 PWR.
7 So, weve shared this information with 8 him. He looks at these things individually, but also 9 globally. So, while I dont have a specific answer 10 as to what the licensees have included as our group 11 cause or a common cause, whether its new, used, 12 periphery fuel, thrice burnt fuel, theres a lot 13 thats still being looked at by the licensee.
14 Theres a lot we still have in inspections to look 15 at.
16 So, as we now go forward, we will 17 document that in our inspection report and thats the 18 update I have.
19 MR. GIESSNER: So, I think the summary 20 is, we are seeing a trend, no current safety impact, 21 a trend up. And, theres no current safety impact, 22 but were still evaluating that with our team.
23 MEMBER BALLINGER: When I hear the word 24 increase, it gets me worried because I always like to 25 hear from what to what. So, when youre saying an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 increase, how many?
2 MR. GIESSNER: I dont have a number.
3 MR. PELTON: Right now, were -- sorry.
4 MR. GIESSNER: Its a hand full.
5 MR. PELTON: Youve got to keep honest, 6 Im trying.
7 Right now, I believe were taking a look 8 at five known reported defects at four sites.
9 CHAIRMAN SKILLMAN: Have any of these 10 sites of the condensate polishers increased in 11 activity to a place where the area has become a 12 radiation area?
13 MR. PELTON: Not that Im aware of. Im 14 looking at the branch chief for the oversight for 15 these sites. I dont believe thats the case nor 16 have we seen appreciable increases in like reactor 17 coolant system activity that we monitor through our 18 performance indicator process.
19 So, we havent seen these issues bear 20 themselves out. Some of its because the licensees 21 have taken timely action to do power suppression 22 testing and to limit the impact of the potential 23 leaker.
24 CHAIRMAN SKILLMAN: Okay, thank you.
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23 1 point of view, Id like you to answer, my concern was 2 that Region I has an expert on fuels and Im just 3 thinking of this and done a great job.
4 Region IV hasnt. And I heard you say 5 that you communicate through headquarters. And, Id 6 like clear that because we dont want to have 7 disparity between Region I and Region IV.
8 MR. PELTON: Right. We will share 9 resources.
10 MR. GIESSNER: Oh, absolutely.
11 MR. PELTON: Yes, we would help our 12 brethren.
13 MR. GIESSNER: And, Im from Region III 14 and I know the location, so I know that it is.
15 MR. MARCH-LEUBA: So, thank you.
16 MR. PELTON: Yes, sir.
17 MR. GIESSNER: So, we wanted to leave 18 with our vision. With all the changes thats 19 happening, we need to stay focused and grounded on 20 our mission, you know, focused on the health and 21 safety of the public, ensuring the plants are run 22 safely, materials are used safely.
23 Well use our principles of good 24 regulation and our values to ensure that.
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24 1 as a region is thats what were going to do.
2 Now, if you see here, the key is 3 engagement. Im a firm believer that the team as a 4 whole is better than the sum of the individual parts.
5 And, you will see in our presentations 6 that, that we work as a team.
7 And, with that, unless theres any more 8 questions for me, Id like to turn it over to Dave 9 Pelton. Youre up.
10 MR. PELTON: Jack, Ill have to check my 11 notes and make sure that I captured everything you 12 tossed my way.
13 (Laughter) 14 MR. PELTON: Mr. Chairman and Committee, 15 its an honor to be able to talk with you today and 16 I really welcome you to Region I and appreciate the 17 opportunity to highlight the -- what the regions 18 bring in terms of safety and security and to highlight 19 the critical role of our inspectors, very important.
20 There was an earlier question about 21 plants where we had conducted an inspection procedure 22 95001 inspection and whether we saw some trends.
23 Ill talk about that, I have a slide that is a high 24 level performance -- plant performance slide. Ill 25 talk about that a bit there, if thats okay.
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25 1 Thank you very much, Anne.
2 So, by way of key message, and I hope 3 youll hear these messages, probably throughout the 4 day, but throughout my presentation, Im going to 5 start with one thats not on the board and that is, 6 as you heard from Jack, the plants in Region I 7 throughout this year have operated safely and 8 securely.
9 And, weve assured that through the 10 conduct of, and the implementation of the Reactor 11 Oversight Program. That program is a -- provides a 12 very effective framework for conducting inspections 13 and assessment of plant performance and allows us to 14 make sure that we can meet our mission of protecting 15 people and the environment.
16 The Reactor Oversight Program, we 17 believe, is a critical element of our ability to 18 assess plant performance. It gives us the 19 opportunity and the tools and the processes to be 20 able to conduct day to day inspections and assessment 21 of plant performance.
22 It allows us to respond to decreasing 23 plant performance through, you heard mentioned 24 earlier, reactive inspections and supplemental 25 inspections. So, it gives us tools to look more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 broadly or more focused at the plant to assure 2 licensees are identifying the underlying causes of 3 their performance problems.
4 But, it also provides us some unique 5 tools where we can look at plants that are, for 6 example, approaching a decommissioning. So, youll 7 hear later on, we have a presentation on Oyster Creek 8 where well highlight the Reactor Oversight Program 9 and the aspects it provides and tools for us to be 10 able to evaluate plant performance as we transition 11 from an operating reactor plant into the 12 decommissioning process.
13 The ROP is not a stagnant process. Its 14 one that evolves over time. And, later on in my 15 presentation, Im going to highlight a number of ways 16 that we continue to refresh and enhance the reactor 17 oversight process to make sure that it continues to 18 serve us well and continues to give our inspectors in 19 the field the right tools so that they can meet their 20 safety mission.
21 And, with that note, I just want to 22 highlight that the reactor oversight process, Im 23 probably going to refer to it as ROP. Its only as 24 good as our practitioners in the field.
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27 1 in the regional officer, at the sites, our senior 2 reactor analysts, these folks are the linchpins.
3 They are critical to the successful implementation 4 and oversight at our nuclear power plants.
5 They provide, collectively provide the 6 eyes and ears. Theyre the ones that are asking the 7 tough questions of the licensee. And, theyre the 8 ones making sure that safety and security continue to 9 be assured as these plants operate.
10 Consistent with those opening -- the key 11 messages, weve got a couple areas were going to 12 cover today.
13 Well talk about plant performance and 14 then well also mention the 95001 activities we 15 conducted through the year.
16 Well have -- I have a couple of key 17 examples of where inspectors add value and, you know, 18 they add value all the time with each of their 19 findings of violations and just being on the site on 20 a day to day bases.
21 However, from the couple example I think 22 C we think are worthy of sharing to highlight that 23 value.
24 And then, finally, Ill kind of do a 25 summary of enhancements and initiatives that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 ongoing to enhance the Reactor Oversight Program to 2 make sure that it continues to serve us well.
3 Its a fairly straightforward slide and 4 its both interesting and a bit misleading.
5 A common -- currently, with the exception 6 of Pilgrim, which youre going to hear about later, 7 the balance of the Region I reactor plants are all 8 operating in Column 1 of the NRCs action matrix.
9 Im presuming youre generally familiar 10 with the action matrix. And the -- its a tool we 11 use to assess, frankly, to assess the licensees 12 ability to identify problems at their sites and to 13 correct them in a timely manner.
14 So, by virtue of the -- most of our sites, 15 with the exception of Pilgrim being in Column 1, that, 16 you know, thats our statement that weve assured 17 these licensees are capable of identifying and 18 correcting their own problems.
19 Its interested because to be in Column 20 1, licensees -- their finding profile, if you will, 21 only will have green findings, green findings through 22 our risk and significance determination process we 23 determine were of very low safety significance.
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29 1 to you that everythings okay. Every finding, green 2 or otherwise, represents a performance deficiency 3 that the licensees are otherwise required to correct, 4 enter into their corrective action program and fix 5 for the future.
6 So, therein lies, you know, some recent 7 interest expressed from the industry at the 8 Regulatory Information Conference as we engage with 9 them periodically here through our Regional Utility 10 Group meetings, theres questions that come up about 11 the continued value of our green and white findings, 12 i.e., the low -- of very low safety significance and 13 those that are low to moderate.
14 You know, what value could they add if 15 theyre of such low safety significance? And thats 16 where the nexus will be to why, regardless of the 17 color, our engagement of our inspectors in these 18 processes does add value beyond simply a risk 19 characterization in terms of licensees taking actions 20 that enhance their programs and enhance safety.
21 CHAIRMAN SKILLMAN: Dave, Id like to 22 make a comment. Just to reinforce this notion that 23 identification of action on low level items is 24 critical to head off what can be the next item that 25 will not be considered minor.
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30 1 I have one son who worked for Transocean.
2 He and his ship plugged the Horizon hole. And 3 Transocean went through a huge change in culture 4 after the Horizon event to where every small item 5 that was identified and put into their version of 6 corrective actions, because the leadership of 7 Transocean recognized the importance of finding the 8 low level items, connecting the dots, and making sure 9 that those are not leading to the next event which 10 could be very serious.
11 And so there is great similarity in 12 companies that have gone through, or industries that 13 have gone through trauma and they realize that many 14 small events can lead to a significant event. If you 15 catch them early and act on them early, and 16 particularly if theyre self-identifying, you have a 17 different culture.
18 MR. PELTON: We couldnt agree more.
19 And, youre actually stealing a bit of my thunder as 20 I talk about the value added by inspectors. And, in 21 one case, theres actually going to be a 22 demonstration of how we believe we took action that 23 resulted in a licensee correcting a problem that, if 24 left uncorrected, would have become more significant.
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31 1 right on. I do want to address, though, Mr.
2 Chairman, your questions. You asked earlier about 3 the inspection procedure 95001 process. We have four 4 sites. And just by way of a real high level, Salem 5 actually had a white performance indicator for 6 numbers of scrams in a 7,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> operating cycle.
7 Ginna had a white finding for emergency 8 planning. Hope Creek had a white finding related to 9 their condition monitoring for their high pressure 10 cooling injection system, which is one of the 11 examples Im going to share momentarily.
12 And then, Oyster Creek had an electomatic 13 relief valve issue and a maintenance issue.
14 So, when we look at these issues, we did 15 not find a connection amongst all of them other than 16 poor performance. And thats not for lack of 17 looking.
18 We, as part of the Reactor Oversight 19 Program, had cross-cutting aspects that we evaluate 20 for each finding. And that gives us an opportunity 21 to look for common threads between human performance, 22 problem identification and resolution, and safety 23 conscious work environments.
24 So, by virtue of that process, were able 25 to dig deeper into each of these finds and to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 evaluate, are there commonalities that we should be 2 addressing, you know, more holistically?
3 So, in this case, we did not identify 4 that here. But, nonetheless, the 95001 process, its 5 essentially a problem identification and resolution-6 type style inspection, did ensure that the licensee 7 corrected these issues and took action on them.
8 MEMBER MARCH-LEUBA: And this -- Dick, 9 maybe you can follow up on this because you know more 10 about it than I do. One concern we have is that 11 getting green on the plant becomes the overarching 12 goal, not the safety of the plant, but making sure 13 you score green on every one of the points. And one 14 thing that Dick and I were discussing before is that 15 one of the green grades is ALARA. So you want to 16 minimize this portion to your employees. So, one way 17 to do that is not to do the inspections or minimize 18 the inspections in places where they need to be. And 19 that's something that the region has to be vigilant 20 that the students, the plants in this case, are not 21 just trying to get a good grade by not finding any 22 problems.
23 Maybe you can follow up on that?
24 CHAIRMAN SKILLMAN: No, your word 25 picture is excellent. Thank you.
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33 1 MR. PELTON: Yeah, Ill just highlight a 2 couple of things.
3 One, you know, you're looking at a team 4 of people here who pride themselves when they go and 5 find issues. And, regardless of how those issues are 6 characterized, you know, were going to evaluate them 7 consistent with Reactor Oversight Program and hold 8 the licensees accountable for their performance.
9 You know, Im going to talk a little 10 about how the Reactor Oversight Program is evolving.
11 Some of that evolution involves feedback from the 12 industry when they look at, you know, the numbers of 13 green findings. They look at the numbers of findings 14 in total and challenge, are we looking in the right 15 places? Why do we continue to focus in certain 16 areas?
17 So, what we have to do as practitioners 18 here in the regions, we have to help our headquarters 19 and program office balance efficiency and 20 effectiveness of the process with protecting people 21 and the environment and making sure that, while we 22 want to be efficient and effective, we also want to 23 make sure that we continue to inspect appropriately 24 in each of our important cornerstones.
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34 1 tension, I think, anytime youre trying to approve a 2 process but still meet a mission. So, I hope that 3 gets to some of your comment. But, thanks for that.
4 MEMBER MARCH-LEUBA: Yeah, the point was 5 that when you do the inspections, you, the guys in 6 the room, need to make sure not only looking at what 7 they're doing wrong but what they are not doing.
8 Theres a risk that inspections are 9 minimized and then you get green on not getting the 10 radiation dose and a green on not finding anything 11 wrong.
12 MR. PELTON: Did you two see my notes 13 before you got here? Because not only am I going to 14 have -- I have two examples I'm going to share. Ones 15 going to be an issue that, if not corrected, would 16 have become more significant. The others going to 17 highlight a licensees conclusion that their 18 performance was poor in one area, but failing to 19 recognize performance deficiencies in other areas.
20 So, thats similar to what youre saying.
21 So, I couldnt ask for two better straight men for 22 this presentation.
23 CHAIRMAN SKILLMAN: No, we did not see 24 your notes.
25 (Laughter)
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35 1 CHAIRMAN SKILLMAN: And, believe it or 2 not, we really have a thick magnifying glass in our 3 business among the members. And, we think about 4 these things. So, its not a surprise that --
5 MR. PELTON: Well, thank you for that and 6 we certainly respect and appreciate the way that this 7 Committee goes about its business and the skills, 8 abilities and experience you bring to the table.
9 So, thank you for that.
10 So, as I mentioned earlier, I do have a 11 number of examples, and throughout the rest of the 12 rest of the presentations, youll hear about other 13 inspection activities that occurred. And youll 14 probably be able to glean from those where our 15 regional staff and resident staff really added value.
16 I want to focus on the -- just the first 17 two because they do highlight the aspects that we 18 just talked through.
19 The first one was an issue thats -- and 20 both of these have been documented, by the way, and 21 they are publically available inspection reports.
22 So, the first example is a Pilgrim issue 23 where the operation staff was supporting a 24 maintenance activity. The core spray -- it was a 25 core spray system flush, seemingly a fairly innocuous NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 activity.
2 While that activity was going on, of 3 course, operators in the field conducted some 4 appropriate system arrangements and valve lineups.
5 Once the flush began, operators in the 6 control room noted about a 10-inch increase, 7 unanticipated increase in suppression pool levels.
8 They have a torus at Pilgrim.
9 Of course, they stopped the evolution.
10 They did a prompt investigation. They noted that 11 they exceeded tech spec limits for volume of water in 12 the suppression pool.
13 So, the operators took immediate actions 14 that were very appropriate with the conditions. What 15 they ultimately identified in the prompt 16 investigation was the, and using their investigative 17 tools, the licensee identified that there were human 18 performance elements, i.e., the valve lineup that was 19 conducted was not consistent with their procedure.
20 And that led to an inadvertent sluicing of water to 21 the torus.
22 So, our inspectors, as part of their 23 event follow-up process, they took a look at the 24 licensees conclusions, using some of the licensees 25 own tools. They have checklists and procedures for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 how to conduct an investigation.
2 We largely aligned with licensees 3 conclusions about the human performance element. So, 4 that is, you know, the problems with valve lineup, 5 the problems with how the job was briefed to the 6 involved staff and carries out.
7 However, the licensees review stopped 8 there. There was actually in their assessment 9 procedure, there is an aspect that says that expects 10 them to fully explore the role that instrumentation 11 or equipment problems could have played in the issue.
12 Well, their conclusion was there were no 13 equipment issues that contributed to the problem.
14 Our resident inspectors saw that 15 conclusion. They reached out to our staff in the 16 Division of Reactor Safety. They pulled information 17 from the plant computer regarding torus level, 18 regarding the valve lineup information, regarding 19 indications that were available in the control room.
20 By the way, there are two wide-range 21 level indicators in the main control room, Alpha and 22 Bravo that give the operators indication of torus 23 level.
24 And, what the -- what our inspectors 25 independently identified was that, in static NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 circumstances, those two indicators indicated 2 similarly, which you would expect.
3 However, under dynamic circumstances, as 4 that torus level was increasing by 10 inches, the two 5 indications diverged significantly. That was not an 6 aspect that was identified by the licensee.
7 So, in pulling a sting on that, what we 8 identified is that the -- the licensee ultimately 9 identified when we provided them that feedback was 10 that there was an air-entrainment issue with the 11 Alpha indicator that has -- was the result of previous 12 maintenance performing such that the Alpha indicator 13 had to be declared inoperable and would not have been 14 a suitable indicator in the control room available to 15 the operators.
16 So, in this case, it was -- this is an 17 example of our inspectors, you know, really showing 18 a strong determination and a questioning attitude, 19 identifying this problem that the licensee had not 20 identified.
21 And, the problem with the indicator, you 22 know, it could range from, you know, as a minimum, it 23 would create confusion to the operators if there was 24 a similar event occurred again regarding what is 25 actual torus level.
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39 1 At worst, it could actually result in 2 sufficient problems where operators may not take 3 appropriate or timely action to enter emergency 4 operating procedures based on torus levels.
5 So, that was an example of an issue that 6 could have been more significant if not correct.
7 But, it also is an aspect where the licensee did not 8 identify that particular equipment performance issue 9 and it ultimately was a problem.
10 So, you know, in this case, the licensee, 11 of course, reinforced with their staff the use of 12 their investigative tools to fully explore the causes 13 of problems and also understand what the relevance 14 was.
15 So, that was a real value add by our 16 inspection staff and we were really proud of the team 17 for that effort.
18 Any questions on that before I go on to 19 the second example?
20 The second example is a --
21 DR. REMPE: I do have --
22 MR. PELTON: Oh sure.
23 DR. REMPE: -- a comment.
24 MR. PELTON: Yes?
25 DR. REMPE: When you start reviewing as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 part of the ROP the SAMGS that have been inked up 2 after Fukushima, some of those kind of questions I 3 think will be important because of the reliance on 4 instrumentation.
5 And, I hope the staff continues their 6 questioning attitude because I think some of its 7 very plant-specific and impact of different systems 8 on the way the instruments read, I think is something 9 that needs to be really questioned.
10 If you look at the data that came from 11 Fukushima and the plants, there were large 12 discrepancies and it takes some good diagnostics to 13 understand what was going on with those.
14 MR. PELTON: Okay, great. Thank you for 15 that. I couldnt agree more. But, Im not just 16 saying that.
17 (Laughter) 18 MR. PELTON: Thats a great insight.
19 The second example I wanted to share was 20 a -- its a Hope Creek issue, also publically 21 available in the associated inspection report.
22 Hope Creek, like a number of boiling 23 water reactors has had some history of steam 24 admission valve leakage for their high pressure 25 coolant injection system and reactor core isolation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 cooling systems.
2 These are turbine driven pumps. The high 3 pressure coolant injection system capable of about 4 4,000 gallons per minute in an emergency core cooling 5 system capacity.
6 Reactor core isolation cooling, about 450 7 gallons a minute, also used for -- to address their 8 Chapter 15 accident analysis.
9 So, these are important -- risk important 10 and safety important pieces of equipment.
11 There has been some history of the -- so 12 theres a -- its turbine, so it runs from steam, 13 theres a steam admission valve thats normally close 14 and would open if the system was called upon.
15 That valve, the number of the boiling 16 water reactors has been somewhat of a historical 17 problem with leakage.
18 At Hope Creek, they had identified a 19 couple years ago that, for their reactor core 20 isolation cooling system, that that leakage had 21 resulted in steam entering, you know, at least some 22 limited amount of steam entering the casing of the 23 turbine.
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42 1 along the shaft of the pump into the bearing area and 2 co-mingle with the governor oil system and then 3 contaminate that system.
4 And so, they saw that previously and the 5 licensee had taken action to correct that problem.
6 They modified the steam admission valve for the RCIC, 7 RCIC, reactor core isolation cooling.
8 And, also, at that time, established a 9 conditions monitoring program where they said, hey, 10 we need to keep an eye on this -- on the governor oil 11 system because weve got to make sure that this 12 modification we did corrects the problem and is 13 stopping water from getting into the oil system.
14 The problem there is, is that water in 15 the oil had, in the past, led at some sites to 16 significant corrosion in the governor control -- the 17 governor and turbine control system, the valving and 18 other parts of the hydraulic system.
19 So, that was an action the licensee took 20 that, you know, at the time, we felt was very 21 appropriate and timely.
22 However, move forward a year, high 23 pressure coolant injection system testing happening 24 at Hope Creek. Rather than running the whole system, 25 they were simply testing the governor system and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 turbine governor valve to assure that it would cycle 2 as designed.
3 They started the hydraulic system, pumps 4 and associated equipment, energized it and the pump 5 -- and the valve failed to open.
6 Upon further investigation, they found 7 significant corrosion in the valve and in other parts 8 of the hydraulic system.
9 So, the licensee say, hey, didnt we just 10 live through this with our reactor core isolation 11 cooling system?
12 So, they said, hey, weve got -- still 13 have this problem with the steam admission valve 14 leaking by. Its still a phenomenon we need to get 15 our arms around. And, they took action specific to 16 that phenomenon.
17 Interestingly, in this case, the high 18 pressure coolant injection system had also -- youve 19 probably seen these turbines have quite a bit of 20 insulation on the outside of them because theyve got 21 steam and its a high temperature environment.
22 The way they installed the insulation 23 actually extended over the end of the bearing housing 24 on the end of the pump. And so, as the pump would 25 run during normal monthly surveillances, you get a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 1 little bit of steam leaking out through the -- through 2 that bearing seal.
3 That was collecting as condensate in the 4 insulation itself and providing another avenue for 5 moisture to get back into the oil system.
6 Interesting phenomenon that theyve since fixed.
7 So, the licensee recognized those two 8 phenomena and took action to address those.
9 So, along come our inspectors. We review 10 their investigation. We took a look at this issue.
11 And our inspectors were the ones who first noted, 12 hey, part of your corrective action program at Hope 13 Creek was to establish a condition monitoring program 14 where theyre sampling oil to see, is there water 15 getting in the oil system?
16 So, they asked the licensee, hey, can we 17 see the trends? Can we see the results of your oil 18 testing?
19 The licensee said, oh, well, we have some 20 examples, but nothing recent. Lo and behold, with 21 the help of our senior reactor analyst who was taking 22 a look at this, a former plant engineer, said, well, 23 lets talk with the system engineers who do system 24 performance monitoring.
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45 1 had actually been taken but never sent to the lab for 2 analysis. And, you know, I want to put this in the 3 right context.
4 While we were at the site, we also 5 observed polly bottles that had the water samples in 6 them. And, if I had one with me, you would see a 7 polly bottle, clear line of demarcation between water 8 and oil.
9 Licensee had calculated that it only 10 takes about 2,000 parts per million of water in the 11 oil of that system to cause a corrosion environment.
12 What was identified ultimately was somewhere in the 13 range of 15,000 parts per million. This was clearly 14 visible in the sample without having to analyze 15 anything.
16 So, that was interesting from a couple 17 perspectives. One, it was an inspector-identified 18 aspect of this that the licensee was not actively 19 pursuing.
20 Secondly, in characterizing the 21 significance of the issue, the licensee was, you 22 know, we oftentimes under the significant 23 determination process, well look at a failed -- a 24 test that fails and well say, hey, when was the last 25 time that test was performed successfully and then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 look at the fault exposure time to determine the 2 significance of the issue.
3 In this case, the licensee said, well, we 4 just ran this pump not too long ago. The fault 5 exposure time is not that significant. We think this 6 is probably a very low safety significance.
7 But, what we did, this was where our 8 senior reactor analyst, I think hes here in the room, 9 actually added a lot of value. He asked, hey, wait 10 a minute. It really isnt when you last ran the 11 pump, its when did you last create an environment 12 that was going to be -- that was a corrosion inducing 13 environment?
14 So, we used that as our start point.
15 And, by virtue of that, characterized the issue as a 16 low to moderate or a white finding.
17 So, I hope that highlights a few aspects 18 of where we really added value to appropriate 19 characterize significance, make sure the licensee 20 corrected issues before they became more significant.
21 And, ultimately, also made sure that if the issue 22 were significant that they didnt leave them 23 uncorrected and to be repeated in the future.
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47 1 like a generic issue. What steps has the region 2 taken to communicate with the other regions and 3 headquarters that the other inspectors should be 4 asking for those oil samples, too, in other plants?
5 MR. PELTON: Yeah, thats a great point.
6 So, I dont know all the specifics of what did and 7 Frank Arner, our SRA, probably has more detail.
8 But we certainly share these experiences 9 publically in our inspection report. They are shared 10 with NRR through the Operating Experience Group. And 11 they get shared more broadly. We have inspector 12 counterpart meetings where we share them amongst all 13 the regions here. And as senior managers, we meet 14 with our counterparts from the other regions once a 15 week.
16 So, through all those processes, we share 17 these experiences.
18 MEMBER MARCH-LEUBA: That's important, 19 because I'm sure every Monday morning you read those 20 inspection reports. But most people dont do that.
21 Its best to point out personally through 22 communications. Whenever you find something -- this, 23 the way you describe it, is something really 24 important and something generic. So you should 25 communicate it verbally to other -- to all the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 inspectors. "Hey, make sure you ask for those 2 samples."
3 MR. PELTON: Thank you for that. Thats 4 terrific.
5 CHAIRMAN SKILLMAN: Dave, your 6 presentation reinforces the importance of our coming 7 here, but it also highlights how much we appreciate 8 the diligence of the inspectors and we just encourage 9 them to not give up once they find that blip in their 10 thick magnifying glass.
11 Once they find it, I -- George Bush gave 12 a graduation speech some years ago. And one of his 13 primary messages was follow your instincts.
14 And those of us who have been in the 15 industry for a long time and have learned, in spite 16 of what the books say, and what the diagrams say, if 17 you think somethings wrong, something probably is.
18 And, wrongs not the correct word to use, 19 something -- if the pieces dont fit, keep digging.
20 And, thats what your individuals are doing and we 21 salute them for that.
22 I want to ask you to move along because 23 we really are -- weve got to hear from Michelle.
24 MR. PELTON: Yes.
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49 1 much for your presentation, sir.
2 MR. PELTON: Sure.
3 MEMBER BALLINGER: And, Id like to say 4 this quickly. What was the follow-through on this?
5 If somebody made a mistake, the person thats working 6 at the plant was asleep at the switch.
7 So, when this corrective action program 8 was taken, did you follow-through on it and make sure 9 that action -- the proposed action was taken?
10 MR. PELTON: Yes, for the -- for white 11 findings, thats the -- we refer to the inspection 12 procedure 95001, that is that process where we 13 follow-up on actions taken to ensure that, if its a 14 significant condition, or if its the quality that 15 prevent recurrence.
16 But, otherwise, yes, we do follow up on 17 those, even for green findings.
18 Okay, thanks again for today, I really 19 appreciate it.
20 CHAIRMAN SKILLMAN: Thank you.
21 MS. CATTS: Good morning.
22 CHAIRMAN SKILLMAN: Good morning, 23 Michelle.
24 MS. CATTS: Morning members of the ACRS.
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50 1 engineer for Pilgrim and Fitzpatrick.
2 Today, I will describe the staffs 3 assessment of safety performance at Pilgrim, the 4 NRCs oversight activities and the areas of focus for 5 the stations recovery.
6 Okay, key messages, during the calendar 7 year 2017, the NRC staff provided significant 8 oversight at Pilgrim, including more than 15,000 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> of direct inspections.
10 Based on our independent review, we 11 concluded that Pilgrim operated safely in 2017. That 12 progress and plant recovery is being made and that 13 overall plant performance is improving.
14 Ill provide more information later in my 15 presentation on this topic.
16 That being said, Pilgrim does remain in 17 the repetitive degraded cornerstone column, or column 18 4, of the NRCs action matrix. And, will remain 19 there until all confirmatory action letter items are 20 closed and Entergy conducted sustained performance 21 improvement at the site.
22 Pilgrim does plan to permanently cease 23 power operations no later than June 1st of 2019.
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51 1 -- permanent shutdown inspections.
2 Ill go into additional detail later on 3 the confirmatory action letter and our inspection 4 strategy.
5 We are seeing progress in some areas 6 including conservative decision making, operator 7 performance and the corrective action program as well 8 as margins to performance indicators thresholds.
9 We do continue to see some challenges 10 with procedure use and adherence and procedural 11 quality.
12 Okay, column 4 history. How did Pilgrim 13 get here?
14 As a quick background, in late 2013, 15 Pilgrim entered the degraded cornerstone column, or 16 column 3 of the action matrix through a series of 17 unplanned scrams, some with complications.
18 In 2014, we conducted our inspection 19 procedure 95002 inspection in which we concluded that 20 Entergys evaluation of the root causes and 21 identification of corrective actions were not 22 sufficient to fulfill the objectives of the 23 inspection.
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52 1 calendar quarters.
2 Then, during unplanned scram in 2015, a 3 safety relief valve failed to open on demand 4 resulting in a white finding, which is low to moderate 5 safety significance.
6 Question?
7 (Off-microphone comments) 8 MS. CATTS: So, this is additional white 9 input into the action matrix led us to place Pilgrim 10 in column 4.
11 Okay, inspection procedure 95003. The 12 NRC structured the 95003 inspection activities at 13 Pilgrim in a phased approach to ensure that continued 14 operation of the facility was acceptable until the 15 final phase of the inspection could be completed.
16 The intent of the 95003 inspection is to 17 provide the NRC a comprehensive understanding of the 18 depth and breadth of safety organizational 19 performance and safety culture issues at Pilgrim.
20 And, if present, the potential for a more 21 serious performance decline.
22 The Phase Charlie Inspection Team 23 reviewed Pilgrims recovery plan and independently 24 assessed whether the recovery plan identified the 25 underlying causes that led to the decline in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 1 Pilgrims performance as well as the necessary 2 corrective actions to address those causes.
3 As you can see, we sent 23 inspectors, 4 those did also include inspectors from all the 5 regions and headquarters and over 3,300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> of 6 direct inspection.
7 The team concluded that Entergys 8 recovery plan generally did address the right 9 problems areas that contributed to the stations 10 performance decline. But, they identified some 11 weaknesses.
12 The NRC inspection team added invaluable 13 insights in identifying weaknesses in the licensees 14 recovery plan that required revisions to the recovery 15 plan by the licensee.
16 Some examples include adjustments to 17 corrective actions, to address sustainable 18 performance improvement, inclusion of corrective 19 actions to address significant weaknesses identified 20 during the review of the root cause for the white 21 safety relief valve finding and a description of how 22 Entergy is planning to address gaps with rigor for 23 which senior licensed operators assure the plant is 24 operated within its design basis.
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54 1 recover plan based on our comments. The NRC staff 2 reviewed the revised recovery plan, found the changes 3 acceptable and issued a confirmatory action letter on 4 August 2, 2017.
5 CHAIRMAN SKILLMAN: Michelle, Ive got 6 to ask this question.
7 MS. CATTS: Sure.
8 CHAIRMAN SKILLMAN: The question I would 9 ask any plant oversight team that was dealing with a 10 plant like this. Did this come from a mom and pop 11 orientation where the plant had been out by itself 12 doing its own thing for years and years and, if you 13 will, they -- the operating organization became 14 infected by its own confidence and, hence, didnt 15 really need tech specs, didnt really need the FSAR 16 related in Chapter 15, really didnt need to obey the 17 design basis?
18 Or, I mean, this is a majority question 19 Im asking, but it kind of gets to the root of maybe 20 some of the things we think about when we are in full 21 committee and we hear a presentation and we wonder, 22 how did this happen? Where did this come from?
23 This almost sounds like a classic 24 situation where, for years and years perhaps, the 25 team was very, very successful but they were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 successful because they were trading on tribal 2 knowledge.
3 They were so comfortable they didnt 4 really need procedures? The corrective action 5 program was a pain in the neck because it required 6 paper.
7 Work management just came to mess 8 everything up because up until the work management 9 team came, Joe always took care of the lubricating 10 oil and went home at night.
11 So, Im just wondering, is that what we 12 really see that is a culture that is a legacy from a 13 plant that was out in the wilderness doing its own 14 thing and having its suspenders snapped to bring it 15 back into conformance?
16 MS. CATTS: So, Pilgrim is part of our 17 fleet, part of Entergy, as you are all aware which is 18 different than say, Palo Verde which is kind of the 19 mom and pop shop kind operating on their own.
20 So, Entergy was when they had performance 21 problems at Palo Verde.
22 For Pilgrim, they were part of a fleet.
23 But, what we found during our inspections is that 24 their corporate organization wasnt sufficiently 25 intrusive in their day to day operations.
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56 1 So, that was one of the things we 2 identified and out of all three and its one of the 3 things the licensees been working on.
4 CHAIRMAN SKILLMAN: My question goes 5 back to a long time before Entergy.
6 MS. CATTS: You want to answer? This is 7 my Branch Chief, Tony.
8 MR. DEMETRIADES: Good morning, Anthony 9 Demetriades.
10 Thats a good -- you have a good sense of 11 this. Entergy purchased the plant 19 years ago this 12 month. So, its not as if they entered a fleet two 13 or three years prior to these declines. Theyve 14 actually been part of a fleet for a while.
15 But, what Michelle said is right on.
16 There is a piece of the safety culture that you 17 mentioned and that she describe that they were 18 somewhat, we found, comfortable with their processes 19 and so on.
20 And, we didnt find that they didnt have 21 ample use of the fleet support. And, theyd been 22 taking actions the last year and a half to correct 23 that.
24 Does that answer your question?
25 CHAIRMAN SKILLMAN: It does, thank you.
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57 1 MEMBER MARCH-LEUBA: I have a question.
2 For the location, this process, the 95003, do we enter 3 in the two or three a year or once everything is 4 corrected? How many plants in the states?
5 Region I only has one?
6 MS. CATTS: Yes, Region I has one. The 7 one before that, it was Arkansas Nuclear One which 8 was a couple years ago. They just got out a year 9 ago, they just got out of column 4.
10 MEMBER MARCH-LEUBA: Its not very 11 common?
12 MS. CATTS: Its very rare.
13 MEMBER MARCH-LEUBA: What have you 14 learned from implementing this? I just thinking of 15 our -- maybe the assessing anything.
16 But, the danger is that this plant has 17 spent more time satisfying your needs of the 18 inspectors than actually clearing the plant.
19 And, Im seeing here 3,000 inspection 20 hours and 23 inspectors going around my plant the 21 licensee maybe was not doing what they were needing 22 to be doing instead of, well, yes, I can do better 23 work.
24 Is this -- Im just thinking aloud, what 25 do you think?
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58 1 MS. CATTS: Well, the NRC when we come 2 in for a 95003 inspection, the licensee is prepared.
3 Theyve got help from their corporate support. A lot 4 times they bring in contractors. So, its not just 5 the people that out doing the work that are that are 6 in the 95003.
7 The 95003 does interview a number of 8 people to make sure that theyre identifying all the 9 performance issues that are going on at the site as 10 well as they do a number of focus groups to look at 11 safety culture to see how the plant is operating and 12 how the people are dealing with safety culture.
13 So, you know, the -- I mean, our 14 inspection team, its a process the licensee was 15 planning for to have specifically a -- they have a 16 recovery team or a recovery manager thats working 17 specifically on that area.
18 So, its not pulling them from a 19 different job, theyre doing that job full-time.
20 MEMBER BALLINGER: Now, the Arkansas 21 plant was way different than Pilgrim. Is there a 22 potential that the fact Pilgrim is a merchant plant 23 as opposed to a cost of service where expenditures on 24 maintenance and things may be a little bit tighter?
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59 1 because of the difference between a cost of service 2 and an emergent environment?
3 MR. DEMETRIADES: So, as I mentioned --
4 I think what youre asking is, are there costs 5 involved because of being a merchant plant? Is that 6 what youre asking?
7 MEMBER BALLINGER: No, excuse me, 8 waiting for the green light.
9 No, I mean what Im saying is -- what Im 10 suggesting is or asking is, if its a cost of service 11 plant a lot of times money is not really that big an 12 issue in terms of spending on inspections and the 13 like.
14 Whereas, if its emergency plant, its a 15 different story. Do you see anything along those 16 lines where, in this case, one potential cause or 17 contributing factor that they have is its a bridge 18 and -- no? Yes?
19 MR. DEMETRIADES: Not -- thats not 20 really -- we dont believe that there was one silver 21 bullet that could have fixed this. There was a 22 number of areas that contributed to this -- to these 23 declines.
24 Part of it may have been that. One of 25 the things that we saw was equipment reliability, for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 example. So, not indirect relation is that part of, 2 you know, cost perhaps, but thats one.
3 The one thing that we saw is certainly 4 the safety culture that really hit it. And, 5 Michelles going to go into that.
6 MEMBER BALLINGER: Thank you.
7 MS. CATTS: Okay, the inspection 8 procedure 95003, another aspect of that inspection 9 procedure is to conduct or review NRCs oversight of 10 Pilgrim for the period leading up the placement of 11 the site in column 4.
12 So, consistent with NRCs emphasis on 13 continual learning, the objective of this review is 14 to determine whether the assessment process provided 15 sufficient warning to identify a significant 16 reduction in safety.
17 The NRC team conducting the review 18 consisted of Region I and headquarters staff who were 19 not previously involved with Pilgrim oversight.
20 The team determined that the NRC 21 appropriately identified the decline in performance 22 and transitioned Pilgrim to the NRCs action matrix 23 prior to a significant reduction in safety.
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61 1 associated with the Pilgrim plant.
2 Specifically, performance deficiencies 3 described in some of these reports were not 4 consistently evaluated and documented as findings or 5 violations in the period of 2011 through 2013.
6 In response, prompt actions were taken 7 including assigning the assignment of an NRC 8 executive to evaluate and develop actions in response 9 to the teams findings and observations.
10 Also, a comprehensive assessment was 11 conducted by a senior reactor analyst to determine if 12 not properly assessing licensee event reports would 13 have impacted NRC oversight at Pilgrim.
14 The review went a longer period to cover 15 2007 through 2014, included risk assessments of the 16 licensee event reports and determined that the 17 results did not impact Pilgrims placement in the 18 action matrix or NRC oversight.
19 The review also determined that this 20 issue was primarily associated with the 2011 through 21 2013 time frame.
22 Additionally, a team of inspectors 23 evaluated an extended condition for the rest of the 24 Region I sites. And, we did determine that this 25 issue was isolated to Pilgrim in that time frame.
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62 1 These results have been shared with the 2 other regions and with headquarters. And, 3 furthermore, the results are publically available.
4 MEMBER BALLINGER: I guess I wanted to 5 get back to answering Dicks original question about 6 is this something that corporate and Entergy would 7 seem to have the same sort of attitude towards other 8 sites or was this unique to Pilgrim?
9 When Dick asked the question about, I 10 cant remember how he characterized it, well call it 11 a single-unit site with a cultural history that was 12 good but wasnt following through.
13 Your answer to him was that it more a 14 lack of intrusiveness from corporate -- of Entergy 15 corporate.
16 Is that common in other parts of Entergy 17 or was this unique to Pilgrim?
18 MS. CATTS: In a way, we have seen that 19 other sites of Entergy. We looked at ANL, we ran all 20 fields from the other sites. And, I know that there 21 have been a number of corporate drop-ins from Entergy 22 and the headquarters to discuss face to face beyond 23 a corporate level to address, you know, their 24 problems with their power plants.
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63 1 answer my question, but in doing that -- so, to put 2 it -- take it off of Pilgrim and put it on Entergy 3 corporate, what is Entergy corporate committing to do 4 to change that culture?
5 MR. LORSON: Good morning. My name is 6 Ray Lorson, Im the Director for the Division of 7 Reactor Projects here in Region I.
8 That was an area that we did take at --
9 look at as the 95003 team and did identify that 10 insufficient corporate oversight in some of the key 11 functional areas like corrective actions was a 12 particular problem at the station contributed to the 13 problems that were experienced at Pilgrim.
14 I think as part of the corrective actions 15 Entergy did take some actions to strengthen the 16 corporate oversight of areas like corrective action 17 programs and also things like safety conscious work 18 environment programs.
19 Some of those actions were discussed 20 recently at the Commission ARM meeting that was 21 conducted back in May of this year.
22 And so, I think weve seen improvements 23 at Pilgrim. We havent seen the similar types of 24 problems at Indian Point which is also an Entergy 25 station.
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64 1 Did not see those problems at Vermont 2 Yankee.
3 And, I think that the key thing that I 4 would take away from that is plants that are operating 5 well in those areas tended to operate pretty well.
6 But, it wasnt necessarily due to kind of an 7 overreaching corporate strategy on how to manage each 8 of those individual sites at more of a corporate level 9 to ensure they were getting kind of a commonality in 10 performance across the fleet.
11 I think weve seen some improvements to 12 the strengthening in those areas across the fleet and 13 well continue to watch those areas as we do our 14 inspections here in Region I.
15 MS. CATTS: Okay.
16 Confirmatory action letters. The NRC 17 staff identified seven focus areas in our 18 confirmatory action letter that consist of 156 19 discrete action items.
20 If the action items associated with these 21 seven focus areas are effectively implemented, we 22 believe that the fundamental problem areas that led 23 to the NRC placing Pilgrim in column 4 will be 24 addressed and Entergys completed actions will 25 provide confidence in sustainability of Pilgrims NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 1 performance improvement.
2 Ive listed the confirmatory action 3 letter focus areas on the board.
4 CHAIRMAN SKILLMAN: Michelle, Id like 5 to ask this question. What prevented Pilgrim from 6 going into 0350?
7 MS. CATTS: So, part of the 0350 process 8 or the part of our process for the 95003 is to 9 evaluate whether or not they should be in shutdown 10 and should be shut down.
11 If there is continued performance decline 12 or if the performance decline has been arrested.
13 So, its one of the things we evaluate on 14 95003 and the 95003 team evaluated that.
15 Its also something we look at during our 16 quarterly assessment. So, every quarterly 17 assessment that we have for Pilgrim, we look at the 18 question of whether it should be shut down. Or, are 19 there other red and green findings?
20 Theres a number of factors that we look 21 at. And, every time, you know, weve been able to 22 answer that, no, they dont meet any of the criteria 23 for 0350.
24 CHAIRMAN SKILLMAN: Thank you.
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66 1 items and I can 1, 2, 3, 5 and 6 as being -- you 2 should be able to objectively determine that those 3 have been worked on.
4 But, 4 and 7, how do you define -- how do 5 you decide that theyve bene successful at improving 6 4 and 7?
7 MS. CATTS: Well, overall, when were 8 looking at success of whether theyre -- for the 9 confirmatory action letter items, were looking at do 10 they do what they say they were going to do in the 11 confirmatory action letter?
12 Did they take a specific action? There 13 are 156 items associated with these seven focus 14 areas. So, we look at their closure packages. Did 15 they do what they say they were going to do?
16 And then, also, when were on site, we do 17 our own independent assessment. So, were looking 18 at the metrics, what do the metrics say? You know, 19 is the metric data accurate?
20 Were looking at, you know, were out in 21 the field. Were doing observations. Were 22 watching work being done.
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67 1 performance improvement in these areas.
2 So, for instance, human performance is 3 broken down into two areas in our confirmatory action 4 letter, procedure use and adherence and operability, 5 determinations and functionality assessments.
6 Operability determinations and 7 functionality assessments were reviewed on a second 8 confirmatory action letter. Im going to go into 9 that in an upcoming slide.
10 And, basically, we determined that we did 11 see improvement in those areas. We saw improvement 12 with our independent observations and we closed out 13 that area.
14 Does that answer your question?
15 MEMBER BALLINGER: Yes, thank you.
16 MS. CATTS: Okay, the status of the 17 confirmatory action letter inspections. The NRCs 18 first quarterly confirmatory action letter follow-up 19 inspection was conducted in December of 2017.
20 During that time, we looked at 20 items, 21 8 of which were associated with procedural quality.
22 While the team concluded that Entergy 23 made progress in procedure quality, the team left 24 open two action items and concluded that additional 25 action was needed to ensure the clarity of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 1 acceptance criteria and precautions and limitations 2 in surveillance tests.
3 As a result, the focus area remained open 4 pending review of the two open items in procedure 5 quality.
6 The second quarterly CAL inspection, as 7 I discussed, was conducted in March of 2018 and 8 reviewed items related to the safety relief valve 9 white finding and operability determinations of 10 functionality assessments.
11 In total, we reviewed the 24 items 12 associated with those areas and we found all the items 13 to be acceptable. We closed those items out as well 14 as those two confirmatory action letter areas.
15 The third quarterly CAL follow-up team 16 inspection was completed in June. We reviewed 33 17 items associated with the corrective action program 18 and procedure use and adherence.
19 The results of this inspection are 20 currently being finalized.
21 We have scheduled two additional 22 confirmatory action letter inspections. Any 23 inspections beyond the five will be scheduled as 24 warranted.
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69 1 and into the beginning of 2018, we had noted progress 2 in Pilgrims recovery.
3 Our inspectors have observed continued 4 emphasis and reinforcement to the Entergy staff by 5 senior site leadership and standards, expectations, 6 conservative decision making.
7 And, consistent with that emphasis, we 8 have seen some examples of conservative decision 9 making.
10 For example, Entergy delayed startup of 11 Pilgrim and took a appropriate precautions including 12 the loading safety buses onto emergency diesel 13 generators for preparation for Winter Storm Skylar 14 earlier this year.
15 This action ensured the safety equipment 16 would remain available regardless of potential storm 17 effects on offsite power.
18 Our inspectors have also seen improved 19 performance by operators. During the 2017 refueling 20 outage, licensed operators with the assistance of 21 mentors external to the station demonstrated improved 22 performance with error free operation.
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70 1 the commencement of work.
2 Also, licensed operators responded 3 appropriately to a loss of an offsite power line on 4 January 4th of this year in which they promptly 5 inserted a manual scram.
6 We have also seen an increased -- there 7 have also been increased margins to performance 8 indicator thresholds.
9 There were no scrams in power in 2017 10 which is significant given that the performance 11 indicators that contributed to Pilgrim being placed 12 in column 4 were related to scrams and scrams with 13 complications.
14 There was a scram in January of 2018, as 15 I just discussed. However, plant equipment and 16 licensed operators response was appropriate and the 17 loss of the one offsite power line that led to this 18 scram was due to equipment not owned by Entergy and 19 was offsite from the plant.
20 The one performance indicator thats 21 close to the green/white threshold, the safety system 22 functional failures. However, that indicator has 23 started to turn and based on known licensee event 24 reports being submitted, that indicator is expected 25 to improve significantly after the second quarter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 data is reported.
2 So, while improvement has been noted, it 3 is not to say we arent seeing some continuing 4 challenges with procedure use and adherence and 5 procedure quality.
6 Although issues still exist in these 7 areas, theyre generally not to the level that impact 8 safety related equipment.
9 There was an example that Dave Pelton 10 gave earlier on the finding of the suppression pool 11 water level that resulted in increased water level in 12 the torus.
13 This event occurred in March of 2017, so 14 most of the issues we saw were back during their 15 fueling outage in 2017 and not recent examples.
16 Also, human performance or equipment 17 issues are not the case of significance of issues 18 identified in the past.
19 Okay, Entergys oversight and power 20 shutdown plans.
21 As you are aware, Entergy announced its 22 intent to permanently shut down Pilgrim on May 31st 23 of 2019.
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72 1 potential issues stemming from the announcement of 2 planned permanent cessation of operations.
3 These strategies for Pilgrim have been 4 integrated with those associated with the column 4 5 plan and are discussed enhanced quarterly assessment 6 reviews.
7 We have guidance and Manual Chapter 2515 8 Appendix G for every counted quarter inspectors 9 review site performance data which includes staffing 10 levels, operator work rounds, control and 11 deficiencies, maintenance backlogs to determine if 12 There are any potential impact by the announced plant 13 shut down.
14 To date, we have observed no adverse 15 trends in those areas.
16 The levels of licensed operator staffing 17 remain consistent with other single-unit plants.
18 Entergy continues to maintain a focus on timely 19 correction of operator work arounds and control and 20 deficiencies and maintenance backlogs have actually 21 slightly declined since January of 2017.
22 The NRC staff will continue to look for 23 potential issues as the date for permanent shut down 24 of Pilgrim nears and well make adjustment to our 25 oversight strategies as appropriate.
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73 1 Okay, next steps. What I want you to 2 take away from this presentation, and as described 3 throughout the presentation, the NRC has added 4 significant value in identifying issues requiring 5 additional actions by the licensee.
6 That includes findings by resident 7 inspectors, weaknesses that we identified in the 8 recovery plan, they are identified by a 95003 9 inspection team that required revisions to that 10 recovery plan as well as some insufficient corrective 11 actions to address the confirmatory action letter 12 items.
13 With respect to next steps, the NRC staff 14 will continue to provide enhanced oversight at 15 Pilgrim in addition to leveraging flexibility within 16 our baseline inspection program will continue to 17 conduct quarterly confirmatory action letter follow-18 up team inspections, will supplement the resident 19 staff on an as needed basis, and maintain increased 20 NRC oversight through expanded quarterly assessments 21 and increased management interactions and site 22 visits.
23 Increased oversight of Pilgrim will allow 24 us to effectively monitor and detect changes in 25 performance trends at Pilgrim.
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74 1 That is all I have.
2 CHAIRMAN SKILLMAN: Any questions for 3 Michelle?
4 Michelle, thank you.
5 MS. CATTS: Okay, Ill turn it over to 6 Matt young.
7 MR. YOUNG: Good morning, hows 8 everybody doing today?
9 Welcome Committee members, NRC staff and 10 members of the public.
11 My name is Matt Young, Im the Division 12 of Reactor Projects Branch Chief for Branch 6 which 13 incorporates Oyster Creek, Three Mile Island and 14 Beaver Valley. You can draw your own thread as to 15 why Im giving the decommissioning presentation for 16 those three units.
17 CHAIRMAN SKILLMAN: You said Branch 6?
18 MR. YOUNG: Branch 6, yes.
19 And, with me today, I have Steve Hammann.
20 He Is in the Senior Health Physicist. Hes in the 21 Decommissioning Branch and Independent Spent Fuel 22 Storage Installation Inspection Branch. So, well 23 be tag-teaming this.
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75 1 about when we transition into decommissioning in our 2 inspection activities.
3 Today, Id like to speak to you a little 4 bit about the operation side of the house, what were 5 doing up until the point that they decide that theyre 6 going to remove the fuel from the pool.
7 And then talk about the oversight 8 activities we have as a branch in Division of Reactor 9 Projects, some of the inspections that do on site and 10 how we adjust within the ROP, Reactor Oversight 11 Program, to account for changes at the facility up to 12 the date of shutdown.
13 Then, Ill turn it over to Steve. Hell 14 talk similarly about the Division of Nuclear Material 15 Safety on their oversight and inspection activities 16 throughout the decommissioning process.
17 And then, well touch base throughout the 18 presentation a little bit on communication both with 19 the licensee and public stakeholders.
20 Region I, as you know, has had Vermont 21 Yankee shutdown and decommissioning since about 2014 22 time frame. So, we do have a little bit of experience 23 in that arena at this point.
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76 1 one year of shutdown.
2 And then, also we have Three Mile Island, 3 Indian Point and Beaver Valley that have announced on 4 the upcoming years.
5 So, on this slide that you see here, 6 youll see that theres an operations side of the 7 house which is very small because were talking about 8 the transition.
9 And then, it rolls into decommissioning 10 where they can choose to do SAFSTOR or immediately go 11 into decommissioning and ultimately, land reuse at 12 the end.
13 So, Ill focus on the operations side of 14 the house. Steve will focus on the decommissioning 15 portion.
16 And then, well -- oversight and 17 inspection, we use Inspection Manual Chapter 2515 for 18 our inspection oversight process.
19 And, when we transition to within one 20 year of shutdown, we utilize Appendix G that which is 21 the baseline inspection guidance for power reactors 22 preparing to transition to decommissioning phase.
23 And, that provides a lot of good insights 24 on what inspections scopes we need to adjust and how 25 we need to use our resources to focus in on key areas.
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77 1 Michelle highlighted some of those areas.
2 And, again, we start that at one year 3 prior to the shutdown of the plant. So, for 4 instance, in Oyster Creeks perspective we are pretty 5 well along in that phase at this point.
6 Areas that we would look at that you can 7 see on the board, were looking at deferral 8 maintenance activities. So, the resident staff is 9 continually looking at the corrective maintenance 10 backlog.
11 Control room deficiencies is a good 12 indicator of whether or not if youve got more 13 deficiencies theyre obviously not fixing stuff at 14 the plant and that could hurt the safety side of the 15 house.
16 And then, were also looking at out of 17 scope reductions in maintenance windows that they had 18 planned. Are they taking out maintenance windows or 19 are they de-scoping stuff from outages a couple of 20 years in advance for some of these other facilities.
21 Attrition and staffing levels, a big 22 focus on this is keeping licensed operators, 23 emergency response organizations, security members.
24 So, we dont have a, you know, a hard 25 core inspection that goes out and looks at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 staffing levels, but the residents are pulsing that, 2 DOP management, myself, when were on site and phone 3 discussions, were asking continually how are they 4 ensuring that they still have the correct staffing 5 levels?
6 Reduction and corrective action program 7 usage. So, folks notified, theyre not going to have 8 a job in a couple of years. Maybe they stop writing 9 condition reports, incident reports.
10 One example Id like to give you is at 11 Oyster Creek this year, a couple months ago, our 12 resident inspectors came across a decline in incident 13 report generations right after the announcement to 14 shut down this year.
15 It was within a couple of weeks and they 16 noticed it, immediately brought it up to the station 17 management. Station management took corrective 18 actions, wrote another incident report and then 19 briefed out to the site the importance of the 20 corrective action program all the way through the 21 operation to shutdown.
22 So, we were intimately involved with that 23 process throughout and it was good value added by our 24 resident inspectors on site.
25 CHAIRMAN SKILLMAN: What was the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 consequence of that action by the station management?
2 MR. YOUNG: There was no consequence from 3 a regulatory perspective.
4 CHAIRMAN SKILLMAN: I wasnt suggesting 5 that, punitive action. Did the site get the message 6 and get back on the stick and get back into real modes 7 and are still operating --
8 MR. YOUNG: Yes, absolutely. So, Oyster 9 Creek in particular, once they were aware that there 10 was a decline -- and I say decline, it was a drastic, 11 you know, they went from 500 a week to 40 a week. It 12 was, you know, 500 to 450 condition reports. So, we 13 saw a decline.
14 They did arrest it. They are back up to 15 the normal generation route and we constantly 16 communicate that from a management side. Where are 17 you at? How are you ensuring that the people running 18 the plant safely and are focused everyday?
19 Thats a big attention. So, pre-job 20 briefs. We attend those quite frequently just to 21 ensure that their game face is on when theyre going 22 to attack the job.
23 CHAIRMAN SKILLMAN: Matt, was IMC 2515 24 created with input from stakeholders or is that 25 purely an inside NRC inspection manual chapter?
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80 1 MR. YOUNG: Are you talking about the 2 overall Inspection Manual Chapter 2515?
3 CHAIRMAN SKILLMAN: Yes.
4 MR. YOUNG: I believe probably when that 5 was created we had public involvement. I would 6 imagine it went out to public comment when it was 7 created.
8 CHAIRMAN SKILLMAN: Thank you.
9 MR. YOUNG: But, I can talk a little bit 10 about Appendix G real quick. So, thats at Vermont 11 Yankee and a couple other facilities.
12 We did take lessons learned from all that 13 and created Appendix G to kind of help us go through 14 the next transition.
15 We in Region I, because of the number of 16 decommissioning plants coming up, we were also taking 17 an initiative to take our lessons learned from these 18 couple that are coming up at Indian Point and Oyster 19 Creek and Pilgrim and were going to see if we need 20 to adjust Appendix G.
21 Some of our inspections have changed, 22 insights have changed. So, we may utilize that 23 through the feedback process and adjust what Appendix 24 G currently says in the future.
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81 1 bullet, for item decreased emphasis on radiation 2 protection, I would have thought that you would have 3 had an addition to deferral maintenance attrition 4 cessation of capital spending, reduction on end costs 5 or reduction only in focus in some areas.
6 But, there is an increased emphasis on 7 radiation protection.
8 MR. YOUNG; That is correct. So, when I 9 say decreased emphasis, we are maintaining the 10 increased emphasis on that. We are looking for a 11 decreased emphasis on radiation protection.
12 So, in those pre-job briefs, are they 13 still doing the same level of briefing of the 14 radiation areas such that workers are informed, fully 15 engaged, know where they can work, where they cant 16 work. Thats what I meant by that bullet.
17 CHAIRMAN SKILLMAN: So, those four items 18 that you show are really items that identify your 19 thick magnifying glass --
20 MR. YOUNG: Correct.
21 CHAIRMAN SKILLMAN: -- for those 22 specific areas.
23 MR. YOUNG: Thats correct.
24 CHAIRMAN SKILLMAN: Okay, I understand, 25 thank you.
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82 1 DR. REMPE: So, Im going to re-ask a 2 question I asked in the beginning when I heard, oh, 3 weve reduced staffing levels because we know theyre 4 going to be plants shutting down.
5 Yes, at some point, I can see that would 6 be true. But, to me, it looks like just because 7 theyve announced theyre going to shut down within 8 the year, why even be a need for increased staffing 9 levels to make sure they keep up with the good work 10 they should be doing plus get ready for the 11 decommissioning.
12 And, is that a true insight?
13 MR. YOUNG: So, currently, we do not 14 increase staffing levels just because they announce 15 that theyre decommissioning.
16 DR. REMPE: You shouldnt increase, but 17 you should keep up with the same amount. And, you 18 might have different inspections.
19 MR. YOUNG: Correct.
20 So, let me give you a couple examples of 21 what Appendix G tells us to kind of adjust and 22 trigger.
23 DR. REMPE: Okay, but is the number of 24 man hours the same as what you would do for an 25 operating plant or is it, you know, what is the -- do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 you have a feel for that?
2 MR. YOUNG: Yes, so the number of man 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from a resident perspective, we have two 4 residents on site. Nothing changes from that 5 perspective.
6 DR. REMPE: Nothing changes?
7 MR. YOUNG: Thats correct.
8 DR. REMPE: Just because theyre 9 announcing it?
10 MR. YOUNG: Only at the decommissioning 11 --
12 DR. REMPE: So, now youre borrowing them 13 from headquarters and other regions, but youre also, 14 because of Project AIM, having to reduce their staff.
15 And, Im just kind of wondering if there 16 is a misconception coming out. I mean, I hear 17 industry fliers saying, no, we have a reduced number 18 of plants, there should be a reduction in the staff.
19 And, Im wondering if thats a true 20 statement or maybe some push back is needed saying, 21 no, I dont think so yet.
22 MR. YOUNG: Yes, I think its crucial to 23 have the two resident inspectors on site all the way 24 through the decommissioning phase. And, we utilize 25 for Oyster in particular, Steves crew, theyre NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 1 already engaged with Oyster Creek.
2 And, either were already utilizing the 3 DMS inspection sources. Theyre actively involved 4 with discussing with the resident inspectors.
5 So, not only are we using the residents 6 in this case, were also tapping into the Division of 7 Nuclear Material Safety for their expertise and the 8 staffing --
9 DR. REMPE: It almost sounds like yo9u 10 may need -- then I guess Im -- I understand the 11 situation, you may need more resources for a while.
12 MR. YOUNG: If we see a decline in 13 performance, we will absolutely ask for more 14 resources. And, they could come from headquarters 15 and operations.
16 MR. LORSON: Ray Lorson again.
17 If I could just add a point of 18 clarification. I think the question kind of relates 19 back to regional staffing levels and how theyve 20 declined over the last several years.
21 DR. REMPE: Not just -- I have to wait 22 for the green light. Okay.
23 Not just regional but the whole agency.
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85 1 thats why Im kind of asking, yes, you can borrow 2 from other places, but they also have to reduce their 3 staff.
4 And, Im wondering if were putting too 5 much stress on the agency?
6 MR. LORSON: Good question. I would 7 offer that in the way of the inspection program that 8 we have for a plant thats entering near-term 9 decommissioning, its revenue neutral essentially 10 from an inspection perspective.
11 Its just our inspections are a little 12 more focused in the areas that we think are going to 13 be important to look at as a plant is approaching 14 decommissioning.
15 Are they deferring necessary 16 maintenance? Are they not having their head in the 17 game relative to the implication of the corrective 18 action program and your performance aspects?
19 So, its revenue neutral. We actually 20 dont lose the resources for a plant thats shutdown 21 until after the beginning of the fiscal year.
22 So, we maintain our full complement of 23 inspectors at the site up until the point they 24 actually shutdown and then they transition from the 25 operator reactor inspection program into the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 decommissioning inspection program which does have a 2 reduced inspection footprint associated with lower 3 risk of the plant thats in the shutdown condition as 4 opposed to the operating condition.
5 The other point that I want to make is 6 that some of these staffing declines weve seen here 7 in Region I over the last couple of years have not 8 necessarily always been due to just plant shutdowns, 9 but other factors such as Project AIM and other 10 factors have been driving down the staffing.
11 And it hasnt affected the inspection 12 footprint we have because our inspection program 13 requirements for each operating unit are the same.
14 Its just a question of reducing the number of plants 15 does translate to reduced number of staffing.
16 But other things, such as Project AIM, 17 efficiencies weve developed in the procedure or the 18 process related to things like inspection report 19 writing, and also, if we look historically, there 20 have been areas where we've received some staffing 21 and funding that we havent fully utilized.
22 And so part of the reduction has also 23 been taking back some of the staffing activities 24 werent using as fully in the past.
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87 1 resources that werent utilized in the past doesnt 2 bother me. Im just wondering when I hear what I 3 heard at the very beginning and I want to understand 4 it. Thank you.
5 MR. LORSON: Yes, thank you.
6 CHAIRMAN SKILLMAN: Please proceed and 7 be mindful weve got a break at about 10:00 a.m.
8 MEMBER MARCH-LEUBA: Yeah, so youll 9 have to talk faster.
10 (Laughter.)
11 MEMBER MARCH-LEUBA: For my education, 12 Im thinking at the moment this plant pushed the 13 switch into shutdown mode for the last time, June 14 1st, for example, do they lose their license?
15 MR. YOUNG: No. So, they will maintain 16 their license. What theyll do is ultimately remove 17 the fuel from the reactor vessel, put it in the spent 18 fuel pool, and theyll send us a letter saying that 19 theyre ceasing their operation.
20 And, at that point, we would send them a 21 letter back saying that you are transitioning from 22 reactor oversight into the decommissioning phase at 23 that point.
24 MEMBER MARCH-LEUBA: That wasnt my 25 question. What is the regulatory basis? What power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 do you have after they put switch into shutdown?
2 MR. YOUNG: It's in the letter that they 3 submit per 10 CFR. 4 MEMBER MARCH-LEUBA: Because right now, 5 we have a carrot and a stick. Your stick is, if you 6 dont do what I say, you shut down. After June 1st, 7 they're already shut down. So, whats your 8 regulatory power then?
9 MR. HAMMANN: Ten CFR 50.82 tells them 10 that they much submit a certification when they cease 11 operation and a separate certification when they 12 remove fuel from the reactor. So, there is a 13 regulatory requirement when they do that.
14 MEMBER MARCH-LEUBA: Yeah, so, after 15 they remove the core from the reactor and they put it 16 in the spent fuel pool, theyll go in a graded 17 inspection regime?
18 MR. HAMMANN: Yes.
19 MEMBER MARCH-LEUBA: Thank you.
20 MR. YOUNG: Skip forward real quickly and 21 just touch base on communications.
22 This is just to emphasize that we have 23 onsite resident inspectors. The region stays 24 continually engaged with the licensee as well as the 25 public stakeholders with outreach activities and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 annual assessments.
2 We also perform quarterly assessments 3 once they get within a year of the decommissioning 4 phase.
5 So, continued oversight is key and then 6 Ill turn it over to Steve to present on 7 decommissioning.
8 MR. HAMMANN: Okay, as Matt just 9 mentioned, you know, we just talked about they send 10 us two certifications.
11 The first one that they have ceased 12 operation; the second one when they have removed all 13 the fuel from the reactor.
14 At that point, we consider them to be in 15 the decommissioning program.
16 We will send them a letter saying you are 17 no longer in the reactor oversight program, you are 18 now in the decommissioning program. Oversight will 19 be in accordance with Manual Chapter 2561 which is 20 Decommissioning Power Reactor Inspection Program.
21 Okay?
22 Real quick, a few words about that. Our 23 core inspections that are required to be done every 24 year. There are discretionary inspections that can 25 be used as needed. And, Ill note here that we still NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 do security and emergency planning inspections at the 2 decommissioned sites.
3 Inspection effort is dependent on 4 decommission activities. Ill talk about that in the 5 next slide a little bit.
6 And, the program does provide latitude to 7 implement the program. Theres flexibility built in, 8 it doesnt tell us how often to go or how many hours 9 or how many inspectors or no limits on the 10 discretionary inspections. So, theres flexibility 11 built in to the program.
12 MEMBER BALLINGER: So, just a -- just 13 more of a historical question. Since 2013, weve had 14 one in Vermont Yankee and San Onofre and Crystal 15 River, if Ive got my numbers right.
16 Has the process that you have to go 17 through in terms of decommissioning and regulatory 18 oversight of the decommissioned site changed?
19 Because my impression would be that if 20 they havent changed, you -- maybe not on a regional 21 level, but on NRC wide level, its a known process.
22 MR. HAMMANN: Correct.
23 It has been a while since any of the sites 24 have shut down. So, when those three -- when the 25 first three, San Onofre, Kewaunee and Crystal River NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 shut down, the industry and the NRC had to kind of 2 take a step back and look at our process and go 3 through it.
4 And, from the NRC side, we actually -- we 5 did a revision of Manual Chapter 2561 because it had 6 --
7 MEMBER BALLINGER: Vermont Yankees 8 under the old -- Im thinking --
9 MR. HAMMANN: No, Vermont Yankee came 10 after Crystal River.
11 MEMBER BALLINGER: Okay, thats what I 12 meant.
13 MR. HAMMANN: So, that was before -- that 14 was done before, right. And, yes, we did revise 15 Manual Chapter 2561 when they shut down.
16 Okay, on the second part shuts down, the 17 resident inspector will stay on -- one resident 18 inspector will stay on site for a period of time 19 determined by management.
20 When they first shut down, theres a lot 21 of stuff going on. Theyre de-energizing systems and 22 draining systems. They might be doing some plant 23 reconfigurations.
24 Theres going to license amendments, 25 changes to the tech specs, changes to programs and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 procedures. So, theres a lot going on. So, its 2 important to keep someone there full-time. So, we 3 do have a resident inspector who stays on site for a 4 period of time.
5 While that resident inspector is there, 6 there will also be a decommissioning inspector who is 7 assigned to the site.
8 And, that decommissioning inspector 9 works in conjunction with the resident inspector, 10 goes out to the site multiple times, performs 11 inspections with the resident inspector and theyre 12 in constant communication.
13 After a period of time, when the resident 14 inspector does leave, decommissioning inspector 15 continues the inspections on site as well as in office 16 reviews of activities.
17 We always get asked that. Always, 18 always, always. Like the public and the state, do 19 you continue inspections on site? Yes, we do. Okay?
20 Frequency and duration of the 21 inspections, varies dependent on phase and 22 decommissioning, licensing performance, some 23 activities and safety.
24 The key driver here is activities, what 25 are they doing? Is the site going to go into SAFSTOR?
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93 1 Which is long term dormancy. Are they going to go 2 into active decommissioning?
3 That will drive what our inspection 4 program is.
5 Obviously, after decommissioning, much 6 more high risk. Theyre working with, you know, they 7 might be doing dismantling, cutting, grinding of 8 radioactive systems, so a lot more high risk 9 activities.
10 So, were there quite a bit more if 11 theyre, you know, if theyre doing active 12 decommissioning, we might be there one week a month.
13 If they transition to SAFSTOR, we might 14 end up only going once per year if theyve been in 15 long term dormancy for a while like Three Mile Island 16 or Indian Point or Millstone.
17 Okay, our communications that we keep 18 with the licensee pretty much pretty similar. Right 19 away, the inspection branch will set up a biweekly 20 call with the licensee.
21 This is especially important for when the 22 resident inspector leaves because we dont have 23 somebody on site, eyes and ears all the time.
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94 1 activities are and what the schedule is coming up.
2 Our branch chief will have his own 3 separate call with the licensee manager at the site.
4 That might be biweekly or monthly as needed. But, 5 he has his own call.
6 And, our division director may also have 7 a call set up with the site VP. Thats sort of an 8 as needed. For instance, we didnt do it with 9 Crystal River, but with Vermont Yankee, our division 10 director had monthly calls with the site VP.
11 So, it all depends on the situation.
12 Management site visits, again, this is 13 all dependent on phase of decommissioning. Branch 14 chief usually goes out multiple times per year.
15 Senior management or division director and our 16 regional administrators, a little less often.
17 I mean, I think in two weeks, Dave Lew, 18 our Regional Administrator, is going to Vermont 19 Yankee. So, they still continue to go out.
20 The takeaway there is that just because 21 they go into decommissioning, they dont fall off the 22 radar. Our senior management is still engaged and 23 still keeps up to date with whats going on at these 24 sites.
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95 1 meetings. I put a couple examples up here. The 2 post-shutdown decommissioning activities report 3 webinar and the PSDAR public meeting.
4 Both of these recently for Oyster Creek, 5 we had public meetings. We held a webinar with the 6 public and a webinar with the media.
7 And, the region supports those public 8 meetings. And then, over in Lacey County for Oyster 9 Creek, we had the public meeting for the PSDAR, and 10 again, regional support. The region goes out and 11 supports -- basically NRR and NMSS with project 12 managers. But, we go out and we support as well.
13 Support for public outreach meetings, 14 thats pretty much as requested. An example would 15 be Vermont has Nuclear Decommissioning Citizens 16 Advisory Panel which is set up by the state, we call 17 them the NDCAP.
18 If they request us to come out, we will 19 come out and support their public meetings.
20 And, then, last of all is media. Just 21 because a site goes into decommissioning doesnt mean 22 that the public interest stops. And, very often, for 23 certain sites, we get a lot of media requests into 24 our public affairs officers who have a lot of work to 25 do, you know, answering questions for the media.
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96 1 And, any final questions for Matt or 2 myself? No? Okay.
3 CHAIRMAN SKILLMAN: Colleagues, any 4 questions? Ladies and gentlemen, we are in recess 5 for 15 minutes. We will reconvene at 15 minutes 6 after 10:00.
7 Matt and Steve, thank you very much.
8 MR. HAMMANN: Thank you.
9 (Whereupon, the above-entitled matter 10 went off the record at 9:56 a.m. and resumed at 10:13 11 a.m.)
12 CHAIRMAN SKILLMAN: Please proceed.
13 MR. CAHILL: Okay. Good morning, my 14 name is Chris Cahill, I am the Acting Branch Chief in 15 DRP for Project Branch 1 so I'm responsible for the 16 oversight of Nine Mile Point, Ginna, and Calvert 17 Cliffs. My other full-time job is Senior Reactor 18 Analyst. We're kind of flexing out here to fill some 19 shortcomings until we have permanent staffing arrive.
20 Had I known that there were so many 21 Savannah people here I would have also put Third 22 Assistant Engineer, unlimited steam motor gas 23 turbine.
24 CHAIRMAN SKILLMAN: Okay, you're from 25 where?
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97 1 MR. CAHILL: New York Maritime.
2 CHAIRMAN SKILLMAN: Walt and I are peace 3 workers. Any other mariners in the room? And we 4 were true mariners, we spent years out there.
5 MR. CAHILL: And did you know the 6 Savannah was built here in Canada at the New York 7 ship building so the Government's home.
8 CHAIRMAN SKILLMAN: And for those of you 9 that don't know, maritime each year is quite a show 10 on the Savannah and she is in Baltimore at Camden 11 Yards, the last exit before you go through the tunnel 12 southbound and she had never done it. And she's 13 really beautiful.
14 She was launched in the early '60s, she 15 sailed through Vietnam, those of us who were on there 16 carried thousands and thousands and tons of cargo to 17 fulfil our army's obligation. She's quite a 18 showpiece if she ever had a chance. Maritime Day is 19 always in May.
20 MEMBER BALLINGER: Where I come from we 21 call them targets.
22 CHAIRMAN SKILLMAN: Just so you know, we 23 brought you your books, your bedding, your books, 24 your beer, your bagels, your bombs and your bullets, 25 we bring you everything you need, except your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 1 attitude. That's a merchant officer.
2 MEMBER REMPE: I think we have a 3 schedule.
4 MR. CAHILL: So I get it from both sides, 5 above and below the water.
6 Anyway, we talked about that and just a 7 quick overview of what backfitting is, what the renew 8 interest is, what actions we're taking, the CRGR 9 which is the Committee to Review Generic 10 Requirements, who oversees the backfitting process, 11 they're picking up additional roles, and some key 12 outcomes.
13 So just quick because I know it's a 14 public Meeting so there might be some folks that are 15 not familiar with backfitting.
16 It's defined as the modification of or 17 addition to systems, structures, components, or 18 design of the facility, or the design approval or 19 manufacturing of a licensing facility, or the 20 procedures or organization required to design, 21 construct, or operate a facility, any of which may 22 result in the new or amended provision in the 23 Commission's regulation, or a position of a 24 regulatory Staff position interpreting the 25 Commission's regulation.
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99 1 This regulation is either new or 2 different from previously applicable Staff positions.
3 And backfitting applies to several areas, mainly for 4 here in Region I.
5 Backfitting applies to us in the power 6 reactor area and in the independent spent fuel 7 storage. So there's some material application but 8 for this region but they don't apply to what we do.
9 So, why do we have a renewed interest?
10 Backfitting requirement is to provide 11 regulatory stability and help us to focus new 12 requirements in the most safety and security-13 significant areas.
14 However, we did have some criticisms from 15 the industry that were not always following our 16 process and many of the Staff have expressed the need 17 for practical interactive training that focuses on 18 how backfitting fits into their daily jobs.
19 So I wanted to initially hit those. The 20 EDO took this information and directed the CRGR to 21 assess the following areas associated with 22 backfitting requirements and guidance, and that's in 23 two documents, NUREG 1409 and Directive 8.4, how 24 we're doing with staff training and knowledge 25 management.
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100 1 So to improve guidance, Management 2 Directive 8.4 which is the management of backfitting 3 issues, backfitting and issue finality, has been 4 provided to the Commission for review and approval.
5 That was last updated approximately five 6 years ago and NUREG 1409, that's going to serve as a 7 one-stop shop for a guidance document to the Agency.
8 And that hasn't been updated in approximately ten 9 years. So that's right now out for public comment 10 and we're hoping to get those incorporated here soon.
11 Big changes to Management Directive 8.4.
12 first of all, consideration of adequate protection 13 backfitting is the first priority so if you get to 14 that stop and engage with that. Improved guidance 15 for implementing compliance backfitting and 16 requirements to consider cost and support compliance 17 backfitting determinations.
18 Also, we took additional training actions 19 to have the winter seminar time, we had a reset 20 training, we had senior executives come out to each 21 region and go over backfitting provisions to give us 22 a reset or refreshed interest in accordance with 23 backfitting.
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101 1 were approximately four hours in length. They were 2 provided in each of the regions and major headquarter 3 offices to go over the backfitting.
4 These were developed and implemented by 5 senior Members of the Staff including CRGR Members 6 that were actively involved in the development and 7 implementation of that.
8 Knowledge management backfitting 9 documents, there's a knowledge management website, 10 preparing a NUREG on knowledge management and CRGR 11 history and activities. And we created a backfitting 12 community of practice with the Office points of 13 contact.
14 So I'm the Office point of contact for 15 Region I and there's a share-point site where we have 16 a single collection point for all the documents so we 17 can readily assess this information.
18 The CRGRs take on additional roles and in 19 the chart is in the process of being revised and 20 they're going to have additional requirements for 21 approval of certain backfitting-related guidance and 22 activities.
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102 1 Meetings both on specific reviews and to obtain 2 additional feedback on general CRGR backfitting 3 requirements and to conduct some periodic 4 assessments. We actually engaged the CRGR.
5 We had a backfitting issue that came in 6 a few months ago from Salem and we engaged with the 7 CRGR in the informal review process and they showed 8 we were consistent with what the current guidance is 9 and what the intent of the future guidance was so 10 we're all on board with that.
11 So that was very useful, we got a second 12 set of eyes, we had a very detailed brief and went to 13 CRGR and that helped us really deliver an 14 appropriately-timed product.
15 So a key outcome so far, as I said, we've 16 developed a backfitting community of practice. We 17 refocused the Staff on a design and licensing basis, 18 and this was key. It's back to the fundamentals.
19 In order for us to effectively regulate 20 we have to understand what the current design 21 licensing basis of the facility is. And as you know, 22 you've got a dual-unit site and the licensing and 23 design basis can be significantly different for each 24 one.
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103 1 design and licensing that we approved at the time and 2 not apply current understandings to it. If we are 3 entering the backfitting process, that's fine as long 4 as we understand that we don't want to inadvertently 5 fall into a backfitting application if we don't need 6 to.
7 We instituted consistent Agency 8 processes once again with the NUREG-managed 9 acknowledgment. As I said, we've already 10 successfully engaged the CRGR and former backfit 11 claims. And the Agency goal was 85 percent and we 12 achieved a 95 percent training goal and we cast a 13 pretty wide net here.
14 For example, in the region, we're 15 engaging some of our IT specialists to leverage their 16 expertise and future cybersecurity inspections.
17 And although they're not reactor 18 inspectors, per se, they're going to be lending some 19 technical expertise and since they may be touching 20 into the regulatory process we wanted to be sure that 21 they had the training also. So we've been working 22 on that.
23 And that's the end of my presentation.
24 I just wanted to touch on one thing. Earlier, before 25 you mentioned the Horizon lines and you touched on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 1 Neil Farrell a bit, we have a very robust knowledge 2 management program here in the region and we don't 3 have blinders on just to the nuclear registry.
4 We took the NTSB findings from that 5 report, we circulate those and incorporate those in 6 knowledge management. There was a lot of activity 7 between risk-informed decision-making, training, 8 emergency preparedness, as you said, corrective 9 actions, all design issues, open life boats.
10 And this parallel we can draw on in our 11 industry. And also, there was a failure at the 12 turnpike, a major member of the Pennsylvania turnpike 13 connector bridge, so we brought in a member of the 14 Pennsylvania turnpike Commission engineer involved in 15 that.
16 Because structural failures don't happen 17 that often and when there are, there's lessons to be 18 learned from that and we incorporated those into our 19 trainings.
20 CHAIRMAN SKILLMAN: Chris, thank you for 21 bringing that up. I'm going to just pause here for a 22 minute.
23 If you remember, Dr. Kirchner asked about 24 how rigorous the region is in matters of applying 25 risk.
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105 1 I'm going to defer to Dr. Kirchner on the 2 question but it gets to the comment that you just 3 made in terms of how the region might assess what a 4 licensee is doing in risk space.
5 Walt, you want to take it from there?
6 DR. KIRCHNER: Okay, well, the simple 7 Members of the Committee in the past have discussed 8 more let me use the word holistic use of risk insight 9 into looking ahead to questions like -- since the 10 title of your talk was the fact that one is a major 11 capital investment needed to keep a plan within this 12 design basis for example.
13 And when there are issues like impending 14 economic pressures that may lead to early 15 decommissioning of a plant, not just you know it's a 16 year out by voicing it even sooner, how would you use 17 risk insights to inform your surveillance, 18 inspection, and other factors that would come in 19 this, come in play possibly in looking at a plant and 20 then adapting the inspection program accordingly.
21 And actually using risk insights, for 22 example, a certain system gives so much contribution 23 to CDF. If the maintenance on that system is 24 deferred, how does that impact the risk profile? Or 25 should that system be actually replaced which is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 major capital investment, not just maintenance?
2 So it's really not a question but maybe 3 a discussion, how is -- we always say we're doing 4 risk-informed this and risk-informed that. How 5 systematically is Region I using risk to help make 6 decisions about backfit surveillance, maintenance, et 7 cetera?
8 MR. CAHILL: Quite a bit. For example, 9 our inspection planning, the design basis 10 infractions, we focus on risk-significant components.
11 It's risk-informed but not risk-based so 12 we want to take a holistic review because you can 13 have failures of low risk significant systems but if 14 you have enough of those in the right area, you have 15 a problem. So we don't exclude those but we tend to 16 focus on the more risk-significant components.
17 Same thing for selecting fire areas for 18 inspections of fire protection areas, we know 19 switchgear rooms and cable spreading rooms and 20 control rooms, they can really be high-risk areas and 21 we look at those. Actually, we just had a lot of 22 insights for Pilgrim.
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107 1 definitely weighed the risk a lot heavier in one area 2 than another.
3 So we have those insights for later on if 4 there's any unfortunate discretions that come up or 5 any other enforcement actions, that we have that.
6 We have our SPAR models which also, not 7 only does the SPAR model do medical modeling and we 8 can work different case sets, it also has -- I forget 9 what -- we have a book up front that has risk-10 significant rankings in different components so 11 you're inspecting a plant, you can get a feel -- if 12 I'm going out to select a sample, I just have to 13 select which one might have more risk for it?
14 We're doing, as I said, discretions and 15 there's risk information there. Our daily morning 16 Meetings, issues come up, we do prioritization with 17 risk insights in mind. So we're incorporating risk 18 in a lot of ways.
19 5069 is a new entity that's rolling out 20 now. I think their license amendment is going to be 21 approved in the August timeframe and so we're going 22 to be engaged heavily with that because that's going 23 to be really reclassifying, changing the way we 24 thought about Part 50 in the past and how we're going 25 to be classifying things.
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108 1 So we're heavily engaged with that and 2 severe weather is going on, we've had a lot of 3 flooding right now so we know flooding at some sites 4 is a higher risk so we engage with the sites to make 5 sure they're following the proper engagement of flood 6 procedures.
7 CHAIRMAN SKILLMAN: Any further 8 questions? Chris, thank you very much, and now we're 9 going to hear from Glenn.
10 MR. DENTEL: I look forward to this 11 discussion. I'm Glenn Dentel, I'm a Branch Chief in 12 the Division of Reactor Safety and I'll be talking 13 about our engineering inspection program and I'll 14 talk about one of the engineering inspection programs 15 which is the environmental qualification inspections.
16 As part of the engineering inspection 17 program, I'll talk about our current engineering 18 inspections, I'll talk about an example that shows 19 the value added.
20 We've done a comprehensive review or a 21 holistic review of how we do engineering inspections, 22 both in the Division of Reactor Safety and the 23 Division of Reactor Projects, which includes 24 revalidating the purpose of this inspection.
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109 1 recommendations that we've made. Finally, we'll talk 2 about environmental qualification inspections.
3 So, if you look up there, included in 4 that chart is the DRS-led engineering inspections.
5 We also complete, resident inspectors conduct, 6 engineering inspections but they're more focused on 7 operations. It's a three-year cycle, it 8 has three team inspections, one completed per year, 9 and the DBAI is Design Basis Assurance Inspection 10 teams. That is more of a design-type inspection of 11 their SPAR protection, 12 Design Basis Assurance Inspection programs.
13 In this case, it's environmental 14 qualifications and then there's the other 15 inspections, heat sink, in-surface inspection, and 16 50.59.
17 So just to get a glimpse of how we'd 18 conduct these inspections, this was a recent 19 inspection in May at Millstone.
20 One of the key things is looking at the 21 design, and we called it a design triangle where you 22 look at how it's designed, the calculations and the 23 procedures, and actually the implementation. And 24 they all have to be congruent.
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110 1 things. They reviewed the design, they looked at the 2 procedures and implementation, and they did walk-3 outs. In this case, the emergency diesel generator.
4 And after questions, eventually they 5 identified that three of four penetrations were below 6 flood height or not sealed properly, and I'll get a 7 little bit into that.
8 That's a picture of one of the 9 penetrations and it's that conduit, and that outside 10 conduit is not a flood seal. It should be inside the 11 conduit.
12 This was identified previously six years 13 ago at Millstone that they didn't have the 14 documentation on these seals. It wasn't crafted.
15 They had some interim comp measures that were 16 inadequate which was revised on the conduit cover 17 plate if they're not designed for it to be water-18 tight.
19 In fact, whenever we asked questions, 20 they opened that up, there's a two-inch diameter 21 opening inside there that would allow water to pass 22 through. So this is value added from our inspectors.
23 The licensee's actions, they ended up 24 sealing the penetrations and the extending condition 25 was not just these three diesel seals, but there's 22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 1 other penetrations that were not properly sealed.
2 MEMBER MARCH-LEUBA: Glenn? Was this 3 efficiency a paper efficiency or was it a real two-4 inch hole that was under water?
5 MR. DENTEL: No, actually it was a real 6 thing. You'd just open that up because that's not 7 seal. There should be a seal inside, there was no 8 seal.
9 MEMBER MARCH-LEUBA: A seal was the 10 efficiency.
11 MR. DENTEL: Yes. There were some 12 paperwork deficiencies and I think that's what they 13 originally identified but they never went out and 14 actually checked.
15 MEMBER REMPE: So what was the root 16 cause? Is it lackadaisical with respect to what's 17 needed for penetration sealing?
18 You've caught them for the lack of 19 documentation and appropriately sealing the 20 penetrations but did someone find a root cause that 21 was a lack of safety culture?
22 MR. DENTEL: In this case, we looked at 23 what we said was the most significant contributor to 24 this, which would be our cross-cutting area. And 25 this was a corrective action program.
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112 1 They had gotten to the point where they 2 had identified a potential problem, they did the 3 right thing to identify it, but they didn't do the 4 next step in doing the evaluations and follow-through 5 on that. So that's one of our cornerstones.
6 They have a robust corrective action 7 program to identify, evaluate, and correct. They 8 didn't give those things and that's why we look at 9 corrective actions so closely.
10 MEMBER REMPE: Subsequent activities, 11 you guys have followed up with them and they are 12 documenting and completing the work for other types 13 of activities at the site.
14 MR. DENTEL: Every section actually has 15 to touch on corrective actions and so we --
16 MEMBER REMPE: Is it better now?
17 MR. DENTEL: Yes, that inspection, I'm 18 trying to think how many findings do we have, Mel?
19 Was it five findings? It was two months ago so there 20 are some challenges so I think it's a little premature 21 to say that correcting these issues overall would 22 probably be smaller work.
23 DR. REMPE: Thank you.
24 CHAIRMAN SKILLMAN: Glenn, what was the 25 consequence? Was this a green finding? Was this a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 1 white finding?
2 MR. DENTEL: This ended up being a green 3 significant finding. And as we looked into the risk, 4 although they're not flood seals, they would do some 5 delay in having the water enter.
6 It's also about a two-hour window where 7 the flood height is high enough. And they had a 8 large surface area on the floor.
9 So, I think they got up to six inches in 10 the room where seven inches was where you would really 11 impact the equipment. So, they were fortunate in 12 that case where there was some mitigating factors.
13 But, this is where, you know, and it was 14 going to conclude with this, but green is not good.
15 You know, just because it's fortunate you have some 16 mitigating factors, the room's big enough, and you 17 have a smaller window.
18 We saw at Fort Calhoun, we had some 19 significant findings on flood protection. And those 20 ended up being key that they corrected those prior 21 too actually with flooding conditions.
22 CHAIRMAN SKILLMAN: Well, I think it is 23 important to reinforce the point that you were 24 beginning to reinforce. And that is, it's dandy that 25 they caught this six years ago. Terrific.
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114 1 What did you do with the findings? And 2 the answer is, they didn't do anything.
3 And for that, you get a kick in the 4 behind. And so you're being gentle with this serious 5 green. Someone else might have said, heck with that.
6 I've had it. That's an amendment, it's a white.
7 And I understand you follow your rules.
8 You've got a whole scale. But to Dr. Rempe's point, 9 what broke down, and I would say it was the will to 10 fix.
11 At some point you have to say it's 12 deficient. It needs repairs. And let's stop 13 talking. Put it on the work list. Work management, 14 go fix it.
15 And that's the piece that was missing 16 here. One man's opinion.
17 MR. DENTEL: I would agree. All right.
18 So the next thing is, is engineering specs were 19 reviewed.
20 There was -- the latest change in our 21 engineering inspection was in 2016. And the again 22 in 2017.
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115 1 in the program.
2 A decision was made to conduct a 3 comprehensive or holistic review of the overall 4 engineering inspection program. Including the 5 inspections that I showed on the previous page.
6 But also other inspections like 7 maintenance rule, and the resident portion of the 8 modification specs. This group was led by Tony Gody 9 who was an SES in Region II.
10 And all four regions were represented by 11 branch chiefs. We collectively had over 150 years 12 of NRC inspection experience.
13 The major task was to evaluate how to 14 increase the effectiveness and efficiency of the 15 engineering inspections. And it hit some basic 16 questions.
17 Why do we conduct the inspections? Is 18 it still valid? Is there gaps in the program? Is 19 there overlap? How can we achieve the safety results 20 in a more effective and efficient manner?
21 And this was -- though our group had a 22 lot of experience, this was in a collaborative 23 manner. We engaged staff, management, licensee, and 24 the public.
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116 1 we're going to inspect, is why. What is the purpose?
2 Why do we do engineering inspections?
3 Is it needed in the inspection program?
4 Hasn't it been designed and reviewed enough already?
5 We get those questions. And so we went 6 into the purpose. We used our experience, but also 7 ROP basis document, manual chapter 0308 as some of 8 the faces behind our ROP inspections.
9 So the purpose is to minimize initiating 10 events. And ensure mitigating equipment will work 11 as designed.
12 And, you know, that seems simple. But 13 it has to be consistent with deterministic and theory 14 models.
15 This then becomes more important as we go 16 along. There's a heavy reliance on PRA in current 17 decision making.
18 And as we look at it, you have to make 19 sure that it's underlying assumptions in the PRA on 20 reliability of equipment. And the time frame on 21 these initiating events remains valid.
22 Or your decision that is based on that 23 PRA will not be appropriate. And also --
24 CHAIRMAN SKILLMAN: Let me ask this.
25 MR. DENTEL: Yes.
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117 1 CHAIRMAN SKILLMAN: To that first 2 bullet, verified licensees' programs flow. At least 3 my experience having sat in the engineering role for 4 many years, is there is this idea that engineering 5 sits over -- away from ops, away from maintenance, 6 away from security.
7 And they do their little whatever it is 8 thing. And their whole job is just to help the plant 9 management keep the plant running.
10 What is lost, and this really came to the 11 surface when Davis-Bessie was in 03 and 05 and trying 12 to get the keys back. Is how extensive the programs 13 are, and how interwoven they are.
14 For instance, you might start with 10 CFR 15 50. You would start with a quality assurance 16 program.
17 You would look at Criterion 16 for the 18 corrective action program. Then someone say, how 19 about those heat exchanges?
20 Well, how about the heat exchanger 21 monitoring program? The valve monitoring program?
22 The MOV program? The solid bell program?
23 And as it turns out, there are about 30 24 or 35 programs that are woven together into the fabric 25 that keeps the plant save. EQ, high energy line NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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118 1 break, maintenance role.
2 And they all, --they are integrated to a 3 point you can't tell when one stops and the other one 4 starts.
5 So, when you say engineering inspection 6 programs, I challenge you to identify precisely what 7 the balance of that is. Or are.
8 MR. DENTEL: I think the other challenge 9 is not just those individual programs. As we talked 10 about kind of that design triangle of you have to 11 design.
12 And you have your calculations. And then 13 you have the implementation. It goes across both 14 engineering, maintenance, and operations to ensure 15 that those design things are congruent across all 16 those measures.
17 And so when we're doing engineering 18 inspections, we're trying to look at all three of 19 those areas. And I'm going to talk about how we 20 said, how can we inspect that in a more effective and 21 efficient manner?
22 And we see that there were some gaps.
23 There were some areas that we can improve. But we 24 also saw some efficiencies that can be gained.
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119 1 to try to prioritize those inspections and those 2 resources to get the biggest gain.
3 The second part here is defense in depth.
4 You know, this is going to be important for 5 engineering inspections.
6 It's for high risk areas such as common 7 mode failures. And areas where there's potential 8 cliff edge effects.
9 Especially for like external events.
10 You see like for Fukushima, that they had a very low 11 probability event. But once you have the event, if 12 you don't have that defense in depth, you can have 13 catastrophic consequences.
14 As we step back and say why are 15 engineering inspections important, it's the only area 16 in the reactor oversight process that focuses on 17 identifying latent conditions that would only show up 18 during events.
19 That's of vital importance. And when I 20 say latent, normal operations or testing would not 21 reveal it.
22 Only actual events like a loco, or a 23 steam line break, or external events will you see it.
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120 1 can actually introduce it due to aging effects. You 2 can have new changes to procedures or maintenance or 3 preventative maintenance that can actually create a 4 latent condition that's not going to be identified 5 during your testing.
6 And so, we saw that yes, we do need to 7 conduct these inspections. And they're very 8 important to conduct this.
9 MEMBER MARCH-LEUBA: I'm waiting on 10 mine. And how do you do this? Because this is very 11 different.
12 I mean, is this to a frame of minds? Or 13 are we just reminding inspectors we have to go to 14 find, you're looking for this.
15 MR. DENTEL: Well, it's talking about 16 digging into, you know, issues. And I'll talk 17 through some of the areas that we think we need to go 18 into detail in our inspections.
19 But, is looking at, you know, that 20 activity. And I'm going to go through some later in 21 environmental qualification.
22 But, looking at the design, how are they 23 actually implementing it? Are they doing the PMs?
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121 1 calculations?
2 And I think the examples will show that.
3 That we verify that, and in some cases we show that 4 their, you know, current maintenance may not be 5 appropriate to maintaining equipment.
6 MEMBER MARCH-LEUBA: Yeah, but I think 7 in my mind is like well, we need to remind the 8 inspectors just is to keep on questioning anything.
9 And asking, what can possibly go wrong.
10 This is not just paperwork or check 11 boxes.
12 MR. DENTEL: Yeah. Actually I just came 13 back, I was in Japan doing a -- they're implementing 14 the RFP new.
15 And both Spain, Mexico, and Taiwan was 16 there to talk about their experience in the RFP. And 17 some of it is, it's how you conduct the inspection.
18 And a manager once said, the best 19 inspector is a five-year-old. They keep asking why.
20 And you know, if you've had -- been 21 around a five-year-old, they just keep asking well, 22 why is that? Why is that?
23 And you have to have that questioning 24 attitude. That thirst to go to that next level.
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122 1 outreach. It's been a yearlong process.
2 Involvement of licensees, NEI, the public including 3 the Union of Concerned Scientists, inspectors and 4 management.
5 We looked at each engineering inspection.
6 Is the basis still relevant, valid? Is there gaps?
7 Overlap?
8 We evaluated not just the individual 9 procedures, but also the overall program. And we 10 developed numerous options.
11 And what I'll present, is the 12 recommendations of the working group. And this was 13 iterative.
14 We, you know, got feedback from 15 inspectors early on. And then would bring back the 16 -- we got insights from managers, industry, public, 17 experts.
18 And there's a caveat on this. This is 19 the engineering inspection working group 20 recommendation, is what's presented here.
21 It's still in process. There's a SECY 22 paper on development. And it's expected to go to the 23 EDO and then to the Commission shortly.
24 So this is not a position for the EDO.
25 This is the working group recommendation.
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123 1 It is a -- we're recommending a four-year 2 engineering cycle with an engineering team inspection 3 each year. Which will give us assessment of the 4 engineering performance on site.
5 We'll continue the in surface inspection 6 every outage. The big changes are elimination of 7 several periodic inspections, including the 5059 8 inspection and heat sink inspections.
9 Development of a comprehensive 10 engineering team inspection and focus engineering 11 inspections. Which address some gaps in the current 12 inspection program and create efficiencies where 13 there was overlap in the previous inspections.
14 There's an overall efficiency savings of 15 about 16 percent. With a potential greater licensee 16 savings due to the reduction of the total number of 17 inspections.
18 There's also considering in the future, 19 incorporation of some licensee self-assessments.
20 But there's still a lot of work to be done in that 21 area.
22 I can't go through what we did in a year.
23 But I'll give you a glimpse of how we'd evaluate 24 things.
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124 1 appreciate the change. So I'm looking at your 2 previous chart, which you don't have to go back.
3 MR. DENTEL: Yes.
4 MEMBER CORRADINI: So, in eliminating 5 the heat sink inspection, what does that exactly 6 mean?
7 MR. DENTEL: All right. So, I'll go into 8 that -- the example is going to go into it. So that's 9 perfect.
10 MEMBER CORRADINI: Okay, fine. That's 11 perfect. Thank you.
12 MR. DENTEL: So, heat sink, we looked at 13 the basis behind that. The reason we were doing a 14 heat sink inspection was because of a high risk due 15 to the potential common cause taking out service 16 water.
17 But also, part of the reason we did that 18 was there was a lot of operating experience with 19 clams, grassing, and other industry issues. We 20 looked at it now, the risk is still there.
21 It's still a potential common cause 22 initiator. And it can take out all your service 23 water.
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125 1 address those clam issues, the grassing issues, and 2 we're not seeing problems in those areas.
3 We also -- we've also done significant 4 inspections so that the likelihood of any latent 5 issues in this area is low.
6 And so we determined that we did not need 7 to do a stand-alone inspection on this. But this 8 would be considered a sample that you could do during 9 the comprehensive engineering team inspection.
10 MEMBER CORRADINI: So, could do or will 11 do?
12 MR. DENTEL: Could do. In that if we 13 saw insights from the resident inspector, we would 14 consider that as one of the ones that we could pick 15 if it warranted.
16 But if we see no degradation in the 17 problems there, we don't think it would warrant the 18 time and the effort to look at that area.
19 MEMBER CORRADINI: So just so that I'm 20 on the same page, what would trip it to be a could 21 do? Is it something from the ROP?
22 Some other performance, operational 23 indicator that would say on an engineering, do you 24 want to bring that back in to look at?
25 MR. DENTEL: So, in this --
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126 1 MEMBER CORRADINI: That's why I'm trying 2 to understand the logic.
3 MR. DENTEL: In this case you'd have your 4 comprehensive engineering team inspection. They 5 would be doing their preparations to go onsite and 6 select their samples.
7 And they would use risk insights to look 8 at samples. They'd talk to the senior resident and 9 resident inspector to get their insights.
10 They look at some of the corrective 11 action documents. And so they would generate a list 12 of things that they would consider, you know, talking 13 to the SRA also.
14 And they would make a decision on what 15 samples they would conduct. And you know, if they 16 hear from the senior resident, you know, that we've 17 seen a trend with a number of CRs where they're 18 experiencing clam build up and problems with service 19 water.
20 Or there's a low margin in that area.
21 That would be a potential selection area.
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127 1 teams.
2 It also incorporates 5059. But, we want 3 to have a greater emphasis on our operating 4 experiences, changing in aging management while using 5 risk insights.
6 And when I say changes, sometimes people 7 think of just design changes. It's much more than 8 that. It's changes in the modifications. But also 9 procedure changes, maintenance changes, because some 10 of the more risk significant issues have been in those 11 areas.
12 The focus engineering inspections, this 13 addressed the ops in our current program. To review 14 areas that have not been evaluated in depth recently.
15 You know, Gordon, you talked about some 16 of those areas where there's a number of program 17 processes. Areas that we have not delved in detail.
18 And we see an opportunity to make a 19 bigger, be more effective in our review of those 20 areas. And we are going to select those using risk, 21 which is risk significance, common cause, cliff edge 22 effects.
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128 1 recent review.
2 And engineering challenges. We want to 3 look at where there is changing conditions. Whether 4 it's aging effects, impact of life extension, 5 significant modifications, or regulatory changes.
6 Any questions? That's kind of the year's 7 worth of our review.
8 MEMBER MARCH-LEUBA: Are you going to 9 address the next slide?
10 MR. DENTEL: I will go on the next slide.
11 MEMBER MARCH-LEUBA: Well, before you do 12 that, I wanted to --
13 MR. DENTEL: Okay.
14 MEMBER MARCH-LEUBA: No, no. Don't --
15 so, you're going to be talking about the 16 environmental qualification?
17 MR. DENTEL: Yes.
18 MEMBER MARCH-LEUBA: I wanted you -- so 19 a specific question. When we go there, is one 20 subtopic on that. It's digital IMC.
21 And specifically on the component with 22 embedded digital IMC components inside. Which 23 happen, I mean, almost everything you replace in your 24 house and in the power plant have embedded digital 25 IMC.
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129 1 How do you do environmental qualification 2 of -- on those new ones?
3 MR. DENTEL: It's interesting. And I'll 4 get into what I'm going to talk about at EQ.
5 But to answer that question is, the 6 environmental qualification rule is unlike other 7 regulations. For fire protection, whatever your 8 regulation was at the time, it will always be, you 9 know, you're in the code associated with 1970.
10 MEMBER MARCH-LEUBA: Um-hum.
11 MR. DENTEL: You know, and for 12 environmental qualification, if you replace a 13 component with a new component, you actually have to 14 meet the requirements of 5049. It's not the original 15 one that you were licensed to.
16 You have to actually meet the 17 requirements. And so, they would have to show how 18 they meet all the requirements under 5049.
19 And so we -- one of the areas that we 20 look at when we do the environmental qualification 21 inspection is, where have they changed components?
22 Have they done the appropriate review in 23 accordance with their program?
24 MEMBER MARCH-LEUBA: Um-hum.
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130 1 that properly?
2 MEMBER MARCH-LEUBA: Yeah, but you're 3 familiar with most relays for the DC generators that 4 have the flickering. Because they replaced the 5 relays with digital relays.
6 MR. DENTEL: Yeah.
7 MEMBER MARCH LEUBA: And when they were 8 placed on the improper environment, or unqualified 9 environment, they failed. So, do you guys have an 10 emphasis on that?
11 MR. DENTEL: We do. The, you know, the 12 industry still is -- in a lot of the areas that are 13 in harsh environments, they haven't replaced a lot of 14 them with digital equipment.
15 So, we haven't seen in our inspections, 16 a tremendous amount. Because in the areas where the 17 EQ rule applies, they haven't really replaced them.
18 MEMBER MARCH-LEUBA: Yeah, I think that 19 -- well, what I guess, is that if you're going to 20 replace something in the control room, they're going 21 to do a very good job.
22 Number one, the control room will have a 23 very nice EMI environment. And number two, they're 24 going to do a good job.
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131 1 auxiliary building, they probably are not going to 2 look at it very carefully. And you can end up with 3 these environmental issues that somebody walks with 4 a cell phone and your relay fails.
5 MR. DENTEL: Right. And there's two 6 parts. There's the EQ part. But there's also just 7 the modifications.
8 MEMBER MARCH-LEUBA: Um-hum.
9 MR. DENTEL: And doing the proper 10 maintenance. And there's a lot of initiatives in the 11 industry and the NRC on how to evaluate.
12 We recently issued a RIS that updated our 13 expectations for 5059. But there's also a lot of 14 work, as you know, ongoing in our transfer nation 15 initiatives to look at digital upgrades, what's the 16 process?
17 How can we do that in a thorough manner?
18 Our review is quite also, to make it efficient and 19 not unnecessarily cumbersome for the industry.
20 MEMBER MARCH-LEUBA: Oh, I agree with 21 that. I think on digital IMC upgrades, my particular 22 opinion is that we are overdoing it.
23 I mean, that most of the time you can do 24 it. It's just the environmental qualifications are 25 a very important step.
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132 1 MR. DENTEL: Yep. I agree.
2 CHAIRMAN SKILLMAN: Glenn, I'm going to 3 ask you to march very quickly to the end.
4 MR. DENTEL: Yep.
5 CHAIRMAN SKILLMAN: In about five or six 6 minutes, please.
7 MR. DENTAL: Great. All right. EQ, we 8 hadn't inspected this in a long period of time. It 9 is for equipment in harsh environments, radiation, 10 high temperature, steam.
11 And there's been a lot of changes.
12 License renewal, power upgrades, PM authorization, 13 and plant modifications.
14 And then we do use risk in selecting our 15 samples and operating experience. I'll give you two 16 examples where we've added value here.
17 One, the first one was at Pilgrim. This 18 was a merging inspection. They added a safety relief 19 valve, solenoid valve showed an open circuit.
20 This was during unrelated post-21 maintenance testing for a pilot valve replacement.
22 There was no maintenance done on the solenoid valve.
23 And this was during their 2017 refueling outage.
24 It's potentially very high risk because it's only one 25 of four SRVs at Pilgrim.
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133 1 You know, our management technical staff 2 engaged Pilgrim on the issue. They had a 32-year 3 equipment qualification life.
4 And it had been in service 20 years. We 5 challenged this. We asked a lot of questions. And 6 it came back that it really should have been ten 7 years.
8 They had an incorrect service temperature 9 use. And it was incorrect.
10 As I talked about, it was potentially 11 very risk significant. However, as mitigating, the 12 valve was determined to function even with the open 13 circuit as shown on the fluke.
14 They did testing offsite on this. And 15 they showed with sufficient voltage, the SRV would 16 likely function during normal operation.
17 So, you know, when we did our RIS then, 18 if it was green significance, because we assumed it 19 wouldn't function during those harsher conditions 20 during a LOCA. But during normal operations it would 21 likely function.
22 So, I think this is -- this kind of shows 23 you how easily you can introduce a latent issue where 24 if you don't do the PMs, and you make one assumption 25 that's wrong on a very risk significant component.
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134 1 Second issue was associated with the 2 design basis assurance inspection environmental 3 qualification at Millstone. We selected some high 4 risk components, solenoid valves for ox -- auxiliary 5 feed water discharge valves to the two lines going 6 in.
7 We reviewed all aspects, including their 8 maintenance history. We were persistent. We kept 9 at it.
10 And we eventually determined that they 11 cancelled the PM for theses valves. It had not been 12 performed in 25 years when it should have been, 13 actually should have been replacing these every 20 14 years.
15 They -- based on this, they conducted an 16 evaluation on current operability. They removed 17 some, the margin which they used actual temperatures 18 out there.
19 Unfortunate for them, they had a three-20 year plant shut down also in that period. And were 21 able to show they could go up to 26 years.
22 It was potentially very -- the 23 significance was very high because absent our 24 inspection, there was nothing in the process to 25 identify that they had cancelled the PM.
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135 1 It would only show itself during the 2 harsh conditions of an event, or until it degraded to 3 a point where it wouldn't not just not work during an 4 event, but during normal operation.
5 So, we assessed it to be green based on 6 its current operability. But, absent NRC inspection, 7 it's potentially much greater.
8 So, you know, I think Dave said we'd be 9 talking about what the impact is. You know our 10 inspectors are identifying issues that, you know, 11 impact the current plant conditions and current 12 behaviors.
13 You know, and we examine those against 14 their current -- their design and licensing basis.
15 We utilize risks throughout our inspections.
16 And not just your classical PRA risk, but 17 the, you know, where there's low margin, where 18 there's cliff edge affects, and other aspects.
19 And as I said before, green is not good.
20 Engineering inspections prevent more risk significant 21 events.
22 And in this all, we're not perfect. We 23 recognize there is always room for effectiveness and 24 efficiency improvements.
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136 1 look at all of our engineering inspections is.
2 CHAIRMAN SKILLMAN: Okay Glenn, thank 3 you very much. Colleagues, any questions or comments 4 for Glenn?
5 Hearing none, thank you sir. And we're 6 going to be hearing from Frank Arner on FLEX 7 equipment, please.
8 MR. ARNER: Okay. Good morning. My 9 name is Frank Arner. And I'm an SRA in Region I.
10 Here for two years.
11 You perked my ears up --
12 CHAIRMAN SKILLMAN: Frank, what is an 13 SRA?
14 MR. ARNER: It's a Senior Reactor 15 Analyst.
16 CHAIRMAN SKILLMAN: Yes, sir.
17 MR. ARNER: And we do the PRA work here.
18 So, you --
19 CHAIRMAN SKILLMAN: PRA, now does that 20 mean you've got the -- you've got the PRAs for all of 21 the Region's plants in your desk or on your computer?
22 MR. ARNER: Yeah. Pretty much. We have 23 the models.
24 CHAIRMAN SKILLMAN: So Walt, that's the 25 answer to your question. There's the resource.
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137 1 MR. ARNER: Yeah. So, that's the work 2 we do, helping the inspectors with risk. And trying 3 to figure out what to look at and that sort of thing.
4 CHAIRMAN SKILLMAN: Yes, sir. Thank 5 you.
6 MR. ARNER: So, you perked my ears up 7 with the mention at Kings Point. While I'm not at 8 Kings Point, my son was. And he still is.
9 He's been out five years. And it just 10 brings back a lot of memories of that first year, 11 about 30 letters written. I can just remember that.
12 But --
13 CHAIRMAN SKILLMAN: Frank, before you 14 proceed, I would like to introduce your assignment.
15 For the years that I was at TMI, and my colleagues 16 were down at Oyster Creek, from time to time we got 17 into a -- into some form of a contest on our license.
18 And we would be seeking exigent relief.
19 And very commonly the way that issue was resolved, is 20 by the GPU PRA specialist communicating quite 21 quietly, very subtly, with the Region PRA specialist.
22 And so what we would do is do our homework 23 to make sure we knew where we were in risk space.
24 And made sure that Region I was comfortable with our 25 knowledge.
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138 1 Of course they had their position.
2 MR. ARNER: Sure.
3 CHAIRMAN SKILLMAN: But the Region I 4 administrator would be briefed, and the residents 5 would be briefed. And by that method, we avoided an 6 awful lot of wasteful arm wrestling between 7 ourselves, the licensee, and the Region.
8 And that turned out to be one of the most 9 beneficial relationships and interactions that we at 10 TMI or we at Oyster Creek had. And I'm drawing on 11 15 or 20 years of experience.
12 MR. ARNER: Yeah.
13 CHAIRMAN SKILLMAN: That was truly a home 14 run for the Agency and also for the licensee. And 15 I've got to assume it is in dealing even today with 16 the Region I plants.
17 MR. ARNER: Yeah. That's an excellent 18 point. Communication is probably the most important 19 thing with the licensees, you know, dealing with the 20 PRA folks.
21 I mean, there's a lot of different issues 22 we get involved in. And they have their models, and 23 we have our models. And they should be close.
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139 1 so a lot of communication is required to do that. To 2 get to the right solution.
3 And that's what we try to do. So, but 4 thanks for that.
5 So anyway, today I'm going to be talking 6 a little bit about FLEX. I've been out on about four 7 inspections here in Region I.
8 You know, as SRAs we kind of appreciate 9 our management allowing us to get out on inspections.
10 We think it's important because we get involved on 11 the PRA side of things.
12 So to be able to see the FLEX strategy 13 and see how it works, then we can kind of figure out 14 okay, you know, when we get into talking about this 15 later, what kind of credit for FLEX can we give? It 16 kind of gives us some insights.
17 So, I want to cover today a little 18 background on flex. NRC inspection insights so far, 19 credit for FLEX. And then the challenges with 20 crediting FLEX. And then the path forward.
21 Why do we have FLEX? Well, the key 22 lessons learned from Fukushima, is extreme external 23 events do happen.
24 I mean, and nuclear power plants have to 25 be prepared to respond to the extreme conditions.
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140 1 We've had earthquakes down in Virginia, floods in 2 Kansas, so things do happen.
3 And so you know, FLEX is a means to 4 address it when things -- when we have the most severe 5 type of events that occur.
6 The conditions are for a FLEX are that 7 you lose all outside power. You don't have AC power 8 onsite either, and you lose all that.
9 And then the ultimate heat sink, which 10 you usually rely on, is gone as well. So, you're 11 faced with a dilemma in that you basically just have 12 DC batteries for a limited amount of time.
13 The objective of FLEX is to allow a 14 station to restore and maintain key safety functions, 15 containment integrity, core cooling and spent fuel 16 pool coolant. Those are the most important ones.
17 Background of FLEX. There is three 18 phases that have to be implemented. Phase one is 19 basically, you're using your installed equipment.
20 That means, I think you were out at 21 Limerick yesterday. They have the high pressure, 22 steam driven pumps. And likely the count on RCIC, 23 reactor core isolation coolant as their phase one 24 critical component.
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141 1 force. It needs batteries, that's all it needs. And 2 you're going to have batteries for at least six to 3 ten hours.
4 So that's how you can control your level.
5 And you safety relief valves controlled by DC. So 6 that phase one buys you time.
7 But you know that without any AC power, 8 you're going to lose that eventually. You're going 9 to lose control power to RCIC.
10 You'll lose the safety relief valves that 11 control pressure. So you know you have to move and 12 look at phase two within that first hour.
13 If you think you can't get AC power back, 14 you'll enter into this extended loss of AC power 15 procedure. And that's really phase two.
16 Is getting everything ready to transition 17 to onsite FLEX equipment. Generators, cables, pumps, 18 hoses, fans, communication equipment. It's all the 19 things that will take over for your installed plant 20 equipment when that goes away.
21 Phase three is simply just, you know, you 22 are contacting offsite sources. Additional 23 equipment is shipped from the National SAFR Response 24 Center.
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142 1 hours. And all of it should be there within three 2 days.
3 You also have help from other plants, 4 IMPO. So that's basically redundant equipment to 5 your phase two equipment. But it's even more than 6 that. Because it's you might have one megawatt 7 generators coming out to help supply your four KVs.
8 So the next picture here, I kind of made 9 up. But it's just a generic strategy for a BWR. And 10 it really is a phase two implementation.
11 So after phase one and you go to phase 12 two, and this is for a reactor pressure vessel make 13 up. It's like a deployment of hose route options.
14 So, if you just look at the red hose 15 there, and the FLEX diesel generator pump, that's 16 part of phase two equipment. This is probably a 17 depiction of a crew of three people. It might be a 18 control room operator, an equipment operator, and an 19 RP tech that are assigned to do this.
20 So, the control room operator, she may 21 have to remain out there to start the equipment. But 22 to get it out there, it takes some time.
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143 1 performed to be able to get the injection into your 2 vessel by this depiction.
3 And if you notice, they have to take a 4 look to see where they can deploy. They have to go 5 get the FLEX diesel generator pump.
6 They have to bring it out. They have to 7 hook up a hose to the intake structure there. They 8 have to hook the red hose up outside, going into the 9 reactor building, going through a door, hooking up to 10 a manifold.
11 And that manifold will allow them to both 12 feed the vessel, but also to feed spent fuel pool, 13 and go through the control rod drive system for vessel 14 injections.
15 And then you've got to amend flow path.
16 Because you always want to keep amended flow for your 17 pumps and to keep flow through those hoses.
18 If that doesn't work, you have the green 19 hose or an alternate strategy. Maybe something's 20 blocking that path.
21 So I can go through the building, into 22 the turbine building. And go right into feed water.
23 Hook up to a feed water connection. And there might 24 be a valve that I can control.
25 So that's like an alternate path.
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144 1 MEMBER CORRADINI: So, can I ask just a 2 question?
3 MR. ARNER: Sure.
4 MEMBER CORRADINI: This is very 5 instructive. The red line, is this something that 6 is -- that BWR owners group and then staff in checking 7 it, have agreed that this a, what I'll call a common 8 approach?
9 Or is it site by site, plant by plant?
10 It could be different.
11 MR. ARNER: Great question. It is 12 absolutely different site by site and plant by plant.
13 MEMBER CORRADINI: Okay.
14 MR. ARNER: You know, this might be a 15 depiction of let's say a BWR without HCIC or RCIC.
16 So, it might have isolation events or something like 17 that, where you don't see the isolation connectors on 18 here.
19 MEMBER CORRADINI: Okay.
20 MR. ARNER: But each site is going to be 21 different where they can deploy and hook up.
22 MEMBER CORRADINI: So my second part of 23 the question, so let's say it's plant X.
24 MR. ARNER: Yes.
25 MEMBER CORRADINI: And plant X runs the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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145 1 red line.
2 MR. ARNER: Yep.
3 MEMBER CORRADINI: What sort of 4 instrumentation, either external or internal, do they 5 need to make sure they're actually getting what they 6 thought they needed to get to the site out of 7 interest? Like where you going to make that?
8 MR. ARNER: Oh, okay. So once they go 9 out there and hook up all these hoses, they'll contact 10 the control room and, you know, they'll open the 11 valves up.
12 And then the control room should be 13 seeing level increase. So, you know, instrumentation 14 is so key as we know for our operators in this.
15 And that's a separate piece of this for 16 a FLEX diesel generator pump. We've got a FLEX 17 diesel generator basically which has to hook up to 18 the normal 480 volt safety-related supplies, which 19 supply the batteries.
20 Or you can have instrumentation. And 21 that's a key thing. That's not shown on here.
22 MEMBER CORRADINI: Okay.
23 MR. ARNER: But that's key where you've 24 got to set that up with cables and everything else.
25 So, there's another crew doing that at the same time.
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146 1 And so that's critical. But yeah. Does 2 that answer your question?
3 MEMBER CORRADINI: Yes.
4 MR. ARNER: So anyway, if you take a look 5 at this picture, you notice how some of the hoses are 6 outside. They run from outside and run into inside.
7 And I'll get into that in a little -- a 8 few slides from here.
9 MEMBER CORRADINI: So are the cables.
10 MR. ARNER: So are the cables. Yeah.
11 That's true.
12 So, some of our inspections today that I 13 want to talk about. We do team inspections, which 14 are called Temporary Instruction-191 Inspections.
15 About 88 percent of them are complete.
16 You know, the residents also do find 17 issues out there. Just through the condition report 18 systems.
19 All the issues of concern go through a 20 cross-regional panel. So, if you have a question and 21 you don't know if it's a performance deficiency, or 22 you think it is, it goes through all the Regions.
23 Like there will be a rep from each 24 Region, and a couple of people from Headquarters.
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147 1 if it's -- you think it's minor or it's more than 2 minor. Or if it needs to go into an inspection 3 report.
4 That keeps consistency among all the 5 regions on how to handle these issues. And I think 6 it's worked fairly well.
7 MEMBER REMPE: So with the 12 percent 8 that are not completed, is there a particular area?
9 Or is it just this is all you've gotten to do so far?
10 MR. ARNER: It's basically where the 11 plants have been ready to be inspected. Where we've 12 done our safety evaluations.
13 And they've done their final integrative 14 plans and they're ready to go. They're ready for the 15 inspection.
16 MEMBER REMPE: So it's a plant specific 17 --
18 MR. ARNER: Yes. It's plant specific.
19 MEMBER REMPE: Rather than a particular 20 area.
21 MR. ARNER: That's correct.
22 MEMBER REMPE: Thank you.
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148 1 maintenance plans for FLEX equipment, we've seen 2 that.
3 We've seen incomplete, inadequate 4 validation of connections and routing and procedures.
5 And one of the things that's come out of these 6 inspections is incomplete generator phase rotation 7 check.
8 That gets back to the FLEX generator 9 thing we mentioned. Several plants have actually 10 found that the vendor and the plants, when they got 11 the FLEX generator, didn't check the phase rotation.
12 So that it was out of phase with the 13 utility source. So then if you would hook it up, it 14 wouldn't be good, because motors would run backwards.
15 CHAIRMAN SKILLMAN: You know, that's 16 really alarming. Because when we were at SAFR and 17 we asked that question.
18 And we said how do you know your phases 19 are aligned? And he said see these colors, open them 20 up. Even a monkey can do it. We went really?
21 MR. ARNER: Well, that's a great 22 observation, because at one particular plant, they 23 had this issue. And they knew, they were smart 24 enough to write a condition report to say, we need to 25 contact SAFR, because they're not going to know this.
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149 1 You know, they're going to assume that 2 it's good. And it's not.
3 CHAIRMAN SKILLMAN: Well, it's a good 4 thing that you didn't injury anybody when they 5 started the equipment. I mean, if you put one in out 6 of phase, you can have some real serious mechanical 7 and electrical incidents.
8 MR. ARNER: Right. And keep in mind 9 these, you know, the phase rotations will be checked.
10 But in a lot of cases they won't run these FLEX 11 generators.
12 They won't actually power things up. It 13 will just be, not until you have an event, so.
14 CHAIRMAN SKILLMAN: Right.
15 MEMBER KIRCHNER: That's sort of what I 16 wanted to ask. How many of the plants that have 17 deployed FLEX equipment have actually loaded, 18 connected, and made hard connections with both cable 19 and hose, and actually put load on the equipment?
20 MR. ARNER: Well, that's a great 21 question. I don't know the answer to that. However, 22 a lot of plants will use load banks to test the FLEX 23 generators.
24 That doesn't answer your question, 25 because it's not powering the equipment in the field.
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150 1 That's correct.
2 I do know TMI has FLEX generators in the 3 field, in the plant. So they're a little different.
4 It's like almost permanent installed equipment in the 5 plant.
6 Which is kind of nice because they don't 7 have to haul it around. But as far as powering 8 equipment up, I'm not familiar with too many that do 9 that.
10 MEMBER KIRCHNER: Maybe. I'm going to 11 ask a little less demanding question. How many of 12 them actually connected the hoses?
13 MR. ARNER: Connected the hoses?
14 MEMBER KIRCHNER: Yes.
15 MR. ARNER: Well they've con --
16 MEMBER KIRCHNER: Basically.
17 MR. ARNER: Well, they've run the hoses 18 out and done what they've had --
19 MEMBER KIRCHNER: That's not what I'm 20 asking. How many of them connected the hoses to the 21 whatever header they are going to connect them when 22 they're actually on there?
23 MR. ARNER: Well, they'll connect the 24 hoses to the connections. But they will not run any 25 water through them.
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151 1 They'll make sure that they can connect 2 them.
3 MEMBER KIRCHNER: Okay.
4 MR. ARNER: Because in some cases, you 5 might run into where, you know, there's interference.
6 And so you've got to find that out.
7 You've got to figure out that you can do this. So, 8 they're pretty easy connections to make.
9 But as far as running flow through them, 10 they won't. They wouldn't have done that, so.
11 But, so it's involved, as you can see.
12 You know, FLEX is not a simple thing.
13 That second bullet there is failure to 14 adequately consider hose routing issues. That gets 15 back to your point and some of the things that we 16 found.
17 Or inadequate cold weather protection 18 evaluation. That's some of the things that we found.
19 Here in Region I, several of the findings --
20 MEMBER REMPE: Excuse me a minute.
21 MR. ARNER: Yeah?
22 MEMBER REMPE: Before you go on. You 23 stated that TMI One has installed the diesel 24 generators.
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152 1 the diesels to the seismic events or something that 2 could damage it? Rather than if they had it 3 protected in some of the structures we've seen that 4 are FLEX structures?
5 MR. ARNER: Yeah, excellent question.
6 Yes, the FLEX generators have to be protected. And 7 so, the structure they're in is protected for every 8 external event that you'd have.
9 Tornado, anything that could happen for 10 FLEX, it's been evaluated that they're going to work.
11 They'll be good.
12 MEMBER REMPE: Okay. Thank you.
13 MR. ARNER: Yes. Because they're 14 different. You're right. So, several of the 15 findings, extreme cold weather conditions and 16 preventative maintenance issue.
17 Indian Point, you know, we're doing a 18 team inspection. Found out the diesel driven 19 equipment could be challenged through the fuel filter 20 clogging at low temps.
21 Remember, these are extreme conditions 22 for FLEX. Hurricanes, tornados, they have to be 23 evaluated down at minus 15 degrees, plus 120.
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153 1 power event.
2 FLEX storage building, it can get down 3 all the way to minus six degrees. But more 4 importantly, when you deploy the equipment out to the 5 field, it may not be started for six, seven hours.
6 And it's out there. Well, if your fuel 7 cloud temperature is only 21 degrees, and you're out 8 in five degrees or zero, what happens is, you start 9 to build a paraffin, white cloudy crystal type 10 material within your fuel.
11 And it doesn't like that when you start 12 the equipment up. Because you can quickly clog the 13 fuel filters. That was an issue found.
14 Sure enough at Beaver Valley we found 15 something similar. There was a little bit of 16 difference here.
17 Beaver Valley is designed to go down to 18 minus 20 degrees. They did have a procedure to add 19 a fuel additive.
20 The only problem was, they thought they 21 were going to add it before they would take and deploy 22 the equipment. But, that's not what they did.
23 They first deploy the equipment and it 24 might be out there for 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. Then right before 25 they'd start it, they'd add the additive.
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154 1 The problem with that again is, it won't 2 work. Because if you add the additive after you've 3 got the crystals, you're going to have a problem.
4 During that inspection, the next day we 5 came in, we found out that night, they had put the 6 additive into all of their FLEX diesel generators.
7 Every one of them.
8 And ran them that night. So they 9 resolved that in their equipment.
10 Finally, Salem/Hope Creek. This gets 11 back to what Dave Pelton was talking about with the 12 lube oil samples in the water.
13 Where they found out, the residence once 14 again found out that the fuel samples for all of the 15 site FLEX diesel generators and pumps were either 16 never taken. Or not analyzed as required by the 17 licensee status procedures.
18 So, that's another issue that was found.
19 MEMBER CORRADINI: So let me run this 20 point, because maybe I don't understand the steps in 21 the process.
22 MR. ARNER: Yeah.
23 MEMBER CORRADINI: So, plant X has now 24 installed and finished their FLEX equipment. They 25 come to the staff, to Region I, and said, we're ready NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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155 1 for inspection.
2 Then you put it in the queue. And you 3 start inspecting it.
4 MR. ARNER: Yeah.
5 MEMBER CORRADINI: Do they, in between 6 that, actually test through all of this in some sense 7 prior to the inspection? Or do they test after the 8 inspection?
9 And then after they test, what is the 10 frequency of subsequent testing? So that in some 11 sense it's a new system.
12 MR. ARNER: Yeah. Yeah.
13 MEMBER CORRADINI: It's for an extreme 14 event. But yet because of the system, you've got to 15 get the kinks out of it.
16 MR. ARNER: Yep.
17 MEMBER CORRADINI: So, can you kind of 18 talk through that?
19 MR. ARNER: Yeah. They'll put a final 20 integrated plan together showing Headquarters, here's 21 what we're required to do. And here's what we did.
22 And here's why we think we meet the order.
23 They have testing, PMs designed according 24 to EPRI templates, manufacturer recommendations.
25 And they have it all set up.
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156 1 So they're pretty confident that they're 2 ready to go. And so everything that -- everything 3 they do is designed to be ready for our inspections.
4 We come in and simply try to verify 5 everything. So that they meet the NEI 1206 standard.
6 And we're still finding issues even 7 lately with some things going on.
8 MEMBER CORRADINI: Do you require a 9 retest?
10 MR. ARNER: Oh well, if they, you know, 11 if they fail a test, what they'll do is they'll 12 generate a condition report. And then they'll take 13 the equipment out of service and work on it.
14 And then they'll run the test again.
15 But, they might run equipment maybe once a year or 16 something like that.
17 So, I want to transition a little bit.
18 What does that mean? Areas of potential credit for 19 FLEX?
20 Okay, so we do these inspections of the 21 worst case conditions like for hurricanes, tornados, 22 all that stuff. However, a plant risk profile for 23 just internal events at a plant per year, Chris, 24 correct me if I'm wrong, about one in a hundred 25 thousand chance of core damage frequency for per NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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157 1 year. Okay? For internal events.
2 Now there's some plants where a LOOP, a 3 loss of offsite power, dominates that. Sixty-five 4 percent of that is caused by a loss of offsite power.
5 So, what causes that is you have the loss 6 of offsite power. You might have two diesels. They 7 might both fail randomly.
8 Your SBO diesel might fail. Now you've 9 got about eight hours to recover AC power or you're 10 going to core damage.
11 If you think about it, that event is 12 almost somewhat similar to FLEX. Because they're 13 going to be sitting there without any AC power.
14 They're going to enter these procedures.
15 So they're going to implement the FLEX. And that's 16 why, you know, that they're asking for credit.
17 And it kind of makes sense. And that's 18 why there are areas of potential credit for FLEX.
19 So, we're talking about incident 20 response. Maybe a diesel's found that it was out 21 five months. And we're going to evaluate whether to 22 send a team out there.
23 But they have FLEX in place. So, maybe 24 we'll look at that. What does it mean?
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158 1 performance deficiency. And it's, you know, somewhat 2 risk significant. Well, if they have procedures for 3 FLEX, how do we credit that?
4 Accident sequence precursor program, 5 license amendment requests, NOEDs, maintenance role.
6 If it's diesel related that sort of thing, you know, 7 they're going to be looking to ask for credit.
8 And since they have the procedures, PRAs 9 as built, that's what they would do. They'd enter 10 these procedures.
11 So, that's the thing we've got to look at 12 going forward. And we have done that already. What 13 are challenges with that though?
14 Collecting FLEX operating experience.
15 Why do we need that? We've got to develop equipment 16 failure probabilities.
17 The industry continues to gather data on 18 equipment, which will inform these failure 19 probabilities. And what I have seen, I have seen 20 where some licensees have put some stuff into their 21 models with a failure of five out of one thousand 22 attempts to start a FLEX piece of equipment.
23 I can tell you, this is just my opinion, 24 not the Agency's opinion, but that's not what I've 25 seen at some plants when they -- I mean, these things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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159 1 have only been started 15 times sometimes.
2 And they might have failed three times.
3 So that's something that we have to look at. And be 4 very, you know, critical of that. And look at that 5 hard.
6 Secondly, human reliability assessment 7 methods for FLEX are very complex. Very stressful.
8 You saw the one picture I showed. That's ten 9 different tasks to do that.
10 So, you know, our tools right now, it's 11 SPAR-H we call it, to evaluate human error 12 probabilities. It's not really mean for 13 transportation of vehicles, hooking up equipment, 14 hooking up hoses, that sort of thing.
15 So research is doing a great job. And 16 Headquarters, in trying to develop tools for us to 17 use as SRAs in our models.
18 And so they're looking at adding some 19 ways that will help us. Using expert elicitation.
20 All kinds of stuff.
21 EPRI had a workshop in February 2018.
22 Discussed HRA methods for FLEX actions. What they 23 think they consider to be appropriate.
24 So, a lot of talk and debate is ongoing 25 with that stuff.
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160 1 MEMBER REMPE: So, could you be --
2 MR. ARNER: Yeah.
3 MEMBER REMPE: A little more specific?
4 When you say RES is trying to help you do this, are 5 they giving you models that you can put into your 6 SPAR models?
7 Which is, I assume, what you're using 8 here, right?
9 MR. ARNER: Yes. Exactly.
10 MEMBER REMPE: Are they trying to use 11 this new ideas thing and trying to implement that?
12 MR. ARNER: Yeah. Well, that's exactly 13 what they're working on. And that is a very complex 14 evaluation they're doing. I mean, where they go 15 through each task. And so the issue with that right 16 now, it's really not workable for our models quite 17 yet.
18 So, it's being worked on so that possibly 19 our SPAR-H could be updated. Or these new 20 performance shaping factors for different things like 21 environment and transportation and errors, can all be 22 incorporated.
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161 1 on it.
2 MEMBER REMPE: So, you do think they're 3 taking the right approach to try and help you get 4 what you need for your SPAR modeling?
5 MR. ARNER: Well, that's, you know, 6 that's my opinion, yes. Yes.
7 So, path forward. Obviously we need a 8 consistent reliable approach to crediting FLEX among 9 all the Regions.
10 Resolving the two main challenges I 11 brought up. Oversight, we actually are beginning to 12 incorporate FLEX into our models.
13 I think about seven out of the 72 models 14 have now FLEX event trees build into them. They're 15 kind of being tested, that sort of thing.
16 And we're also looking at evaluating ways 17 to incorporate FLEX into the baseline inspection 18 program. Where maybe the residents go out and look 19 at testing and see if there's issues with that.
20 And we'll continue to engage internal and 21 external stakeholders. So, that's really the 22 presentation.
23 And again, I will remind everybody that, 24 you know, we're -- the SRAs, we do input to 25 Headquarters some of our concerns sometimes if we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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162 1 have these models.
2 And some of the models they might be 3 using N plus one as an and gate for like if a FLEX 4 generator fails. Well, we got an N plus one. So, 5 we'll just multiply the failure probabilities.
6 Well, that's not how it's going to work.
7 Because if you saw the time line, if you go out there 8 and you've got six hours, seven hours of battery, and 9 it takes you six hours to get a FLEX generator out 10 there to start it, if it doesn't start, you don't 11 have time to go back and get the other one.
12 You're not hauling them both out. So we 13 give that feedback to Headquarters. And they're 14 working on that, so.
15 CHAIRMAN SKILLMAN: Frank, thank you 16 very much. Colleagues, do you have questions for 17 Frank?
18 If none, Jack, it's your time to speak.
19 MR. GIESSNER: On behalf of Region I, I 20 wanted to thank the ACRS for spending time with us.
21 For listening to our presentation, for your questions 22 and your comments, those are great insights.
23 I hope you saw the passion that we had 24 for safety and security. It's really, you know, part 25 of our DNA, our culture.
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163 1 And I think a good message to leave you 2 with, is how do we keep that culture? Sustain it?
3 And how do we build it in new folks?
4 You know, how do we make sure that that 5 inspector has the right question or that gut feel 6 when you know something's wrong. How do you do that?
7 You know, it's part of our training 8 program. It's part of mentoring. It's part of 9 sharing communities of practice or operating 10 experience.
11 It's part of management. Walking 12 around, right? Sharing our expectations. And I 13 think that's going to suit us well. Because there 14 is a lot of change going on.
15 But with a strong culture that we have 16 here in Region I, we'll be able to weather the change.
17 And keep the core mission in focus.
18 With that, it's back to you Mr. Chairman.
19 CHAIRMAN SKILLMAN: Jack, thank you. I 20 would like to open the public line please.
21 MEMBER MARCH-LEUBA: I have a question.
22 CHAIRMAN SKILLMAN: Excuse me, Jose.
23 Please go ahead.
24 MEMBER MARCH-LEUBA: I couldn't find 25 anywhere to ask this question. So I'll ask you.
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164 1 CHAIRMAN SKILLMAN: Okay.
2 MEMBER MARCH-LEUBA: How does the Region 3 handle cyber security inspections? Because in my 4 opinion, cyber security is probably the largest 5 safety concern.
6 MR. GIESSNER: Well, I had a feeling you 7 were going to ask about cyber security. And Glenn 8 handles all the cyber security inspections.
9 And since I'm from Region III, I think it 10 would be appropriate for him to answer.
11 MEMBER MARCH-LEUBA: I don't need you to 12 answer it. As long as I know there is somebody that's 13 in charge of it.
14 MR. GIESSNER: Yes.
15 MEMBER MARCH-LEUBA: But please, go 16 ahead.
17 MR. GIESSNER: Yes.
18 MR. DENTEL: And just briefly. For the 19 Agency we did what we call a milestones one through 20 seven inspections.
21 Which was until they fully implemented 22 all of the requirements and rules, so we did a tiered 23 process to look at the progress they had made. And 24 we have been conducting since the middle of last year, 25 what we call whole implementation inspections.
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165 1 And we did Region I, three inspections so 2 far. And one is ongoing as we speak. But that's 3 looking as a four-man team.
4 Two from regional inspectors, two 5 technical experts or contractors. We also have in 6 service participation on these inspections to do a 7 thorough review on site.
8 MEMBER MARCH-LEUBA: We have anecdotal 9 evidence from licensees that come to see us that 10 licensees are taking this very seriously.
11 MR. GIESSNER: Yes. They are.
12 MEMBER MARCH-LEUBA: Even more than I 13 would think they would. But it's incumbent on the 14 Region to make sure that they continue to do so.
15 MR. GIESSNER: Yes, sir.
16 MEMBER MARCH-LEUBA: Tomorrow and next 17 year and ten years from now.
18 MR. GIESSNER: Thank you.
19 CHAIRMAN SKILLMAN: Jack, thank you.
20 Jose, thank you.
21 MEMBER MARCH-LEUBA: Um-hum.
22 CHAIRMAN SKILLMAN: Is the public line 23 open? Can I have feedback, please?
24 OPERATOR: Thank you. At this time if 25 you would like to ask a question or make a comment, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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166 1 please press star and then one.
2 You will be prompted to record your first 3 and last name. To withdraw your request, please 4 press star two.
5 Once again, to ask a question or make a 6 comment, you may press star then one now.
7 Hearing no comments, please close the 8 caller line. Are there any individuals in the room 9 that would care to make a comment?
10 If so, please step to the microphone and 11 speak up.
12 MR. ROBINSON: Hi. My name is Dan 13 Robinson. I'm an oil and machinery loss control 14 representative with NEIL, Nuclear Electric Insurance 15 Limited.
16 Welcome. I just want to make a few brief 17 comments. First, to answer your question from 18 earlier, I was a mariner at one time. It was in the 19 early 2000s. So a little bit after the '60s, so I'm 20 sure.
21 My experience is in environment changed 22 quite substantially from that. But also too, I was 23 stationed on a surface target as referred to earlier.
24 (Laughter) 25 MR. ROBINSON: So, I did want to make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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167 1 just one comment to some of the discussions earlier.
2 At NEIL, we notice the difference between merchant 3 plants and ones in regulated plants.
4 CHAIRMAN SKILLMAN: Please speak close 5 to your microphone, please.
6 MR. ROBINSON: We do notice from NEIL's 7 perspective the difference between merchants plants 8 and ones that operate in regulated environments as 9 knowledge of the plant side.
10 The -- and there are maintenance activity 11 deferrals, and funding for maintenance inspection 12 requirements on the balance of the plant sites. So 13 there is a difference from NEIL's perspective for 14 merchant plants.
15 To just give a brief overview of NEIL.
16 They ensure all the U.S. utilities for primary 17 property and accidental outage and business 18 interruption damage.
19 So they -- it's a mutual of all the U.S.
20 nuclear utilities. So basically how the business 21 model works is the plants pay premiums into NEIL.
22 NEIL has an investment department and 23 invests that money. At the end of the year, NEIL 24 maintains enough money on hand to pay out two full of 25 that office or 2.75 billion.
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168 1 The money above that, they return back to 2 the membership in the form of a distribution. So, 3 NEIL and the NRC -- and all the utilities are 4 ultimately working towards the same goals, safe and 5 reliable operations.
6 Yeah, if there's no losses, it's a good 7 deal for everyone. So NEIL's primary focus though 8 is on down to the plant site.
9 Most of their losses are transformers, 10 turbine generators, and some large projects. So, 11 NEIL heavily defaults to the NRC for their inspection 12 reports.
13 So we rely on them. We read them to help 14 NEIL understand what their risk is for reactor safety 15 and reactor operations.
16 So, it is appreciated. And the main 17 reason why I even attended here today, why I was asked 18 by my management is to understand how the NRC -- what 19 the NRC's perspective is towards plants that have 20 announced shutdown state, shutdown dates.
21 And how the NRC engages them after it's 22 shutdown. And so I thank you Matt and Steve, for 23 your presentation.
24 That was very informative and helpful to 25 me, what I was looking for. And I'll communicate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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169 1 that back to NEIL's management.
2 And the way that NEIL addresses plants 3 that have announced permanent shutdown states is that 4 they do categorize them as a higher risk of having a 5 loss. Due to those things that we talked about.
6 With personnel leaving. Lack of funding 7 for all the maintenance activities. So NEIL does do 8 increased inspections that focus on plants that have 9 permanent -- permanently announced shutdown states.
10 So with that, that's all the comments 11 that I had. Again, thank you for the opportunity.
12 CHAIRMAN SKILLMAN: Certainly. Thank 13 you very much. You were very instructive. Thank 14 you.
15 Colleagues, before we close, there might 16 be, do you have any final comments? Joy, do you have 17 one?
18 MEMBER REMPE: I just wanted to make sure 19 that we -- I'm sure you'll do it too. But we 20 adequately express our appreciation.
21 These visits are very important, I think, 22 for us to learn and to be educated by the region 23 staff. And I appreciate everyone's efforts to 24 prepare these presentations to facilitate the tour.
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170 1 arranging this.
2 CHAIRMAN SKILLMAN: Joy, thank you very 3 much. I went to reinforce Dr. Rempe's thank you in 4 a couple of different directions.
5 To the Regions, for taking your day and 6 taking your time to create these personations. This 7 is very helpful.
8 We've been to all of the Regions. We 9 learn something every time we go out.
10 But your hospitality and your willingness 11 to take the time to create presentations that conform 12 with our requests, for this we truly thank you for 13 excellent presentations.
14 I want to acknowledge Kent and Mark 15 Banks, and Quynh Nguyen, and Shandeth Montgomery.
16 Part of our team back on our home base. Without 17 these individuals this engagement for us would not be 18 as thorough or as comprehensive as it is.
19 And I would like to make my final comment 20 to the inspectors. We salute you for what you do.
21 You are our recon teams. We depend on what you do.
22 We read your inspection reports. I'm the 23 guy that does the annual update for performance. And 24 I work with several members on the staff to look at 25 all the plants in all the regions, to identify where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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171 1 performance has degraded or where performance has 2 been excellent.
3 And I recognize and we recognize this is 4 comes from your hard work. And having lived in the 5 industry now for many years, I realize how testy some 6 of these engagements can become.
7 And I've always been impressed at the 8 professionalism that the inspectors have somehow 9 managed to demonstrate. Perhaps even in spite of 10 themselves. We salute.
11 Thank you very much. Your work is 12 valuable. And we are always impressed when we're in 13 our own digs down in White Flint and members come in 14 from the staff, members come in from the utilities, 15 and we realize what excellent work you're doing.
16 With that, safe travels to everybody.
17 Thank you very much. And this meeting is concluded.
18 (Whereupon, the above-entitled matter 19 went off the record at 11:41 a.m.)
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Welcome and Overview of Region I July 26, 2018 Jack Giessner, Acting Deputy Regional Administrator Region I 1
Office Safety & Security
- Safety: Exit routes in red in event of an alarm
- Security: Visitors (without NRC employee badge), must be escorted if need to leave conference room 2
Muster Areas During Building Evacuation 3
Overview of Region I
- Inspect, assess and oversee the safety performance of 25 operating nuclear reactors, 19 ISFSIs, 6 nuclear reactors in SAFSTOR, 794 active material licensees, 1 Master Material License, and 5 complex decommissioning sites to provide reasonable assurance of adequate protection of public health and safety and to promote the common defense and security and to protect the environment.
- Staffing -
- 204 total staff in Region I (118 Qualified Inspectors)
- Oversight (Inspection & Licensing) -
- Reactor Inspections (CY2017 - ROP 18)
- Baseline Inspections - 110,995 hours0.0115 days <br />0.276 hours <br />0.00165 weeks <br />3.785975e-4 months <br /> of inspection and related activities
- 5 Supplemental (4 - 95001 & 1 - 95003) and 0 Reactive Inspections
- Responded to 6 declared events (all Unusual Events)
- Nuclear Materials Program
- 288 Inspections and 402 Licensing Actions (FY2017)
- Navy Master Material License (MML)
- Oversight for Agreement States 4
Region I Data - Number & Type of Licensees
- 25 operating reactors
- 12 BWR (7 Mark-I and 5 Mark-2)
- 794 active materials licensees & Navy MML
- 19 ISFSIs
- 13 Inside Protected Area (PA)
- 3 Within OCA, but Outside the PA
- 3 Stand-alone
- 6 Nuclear Reactors in SAFSTOR
- Complex Decommissioning Activities
- 5 complex material sites
- 1 Research / Test Reactor 5
Reactor Safety - Where We Regulate Materials Safety - Where We Regulate
- Region I Non-Agreement States are: Connecticut, Washington DC, Delaware, Vermont, West Virginia, Puerto Rico and the Virgin Islands
Agency/Industry Activities Impacting Region I
- Oversight of Pilgrims recovery from Column IV of the Action Matrix
- Multiple Region I sites scheduled to shut down between now and 2021
- State of Vermont to an Agreement State 8
Region I Vision Statement Region I continues to achieve our mission with a high level of credibility and competence. We will focus on enhancing individual and organizational versatility while fostering an environment in which each employee feels connected to the organization and to each other through meaningful and rewarding work.
9
Reactor Oversight Program (ROP) Performance Summary July 26, 2018 Dave L Pelton, Deputy Director Division of Reactor Projects Region I 10
Key Messages
- Reactor Oversight Program (ROP) continues to provide an effective framework for conducting risk-informed and performance based inspection
- The ROP continues to evolve and improve based on internal self-assessments, stakeholder feedback, and lessons learned
- Regional offices continue to provide technically qualified, independent, and robust oversight that contributes to the overall mission of the agency to ensure plants are being operated safely and securely 11
Areas to be Covered
- High level Region I plant performance
- Examples of inspectors adding value
- Initiatives to enhance ROP & implementation 12
High Level Region I Plant Performance Action Matrix Summary as of June 30, 2018 16 14 12 10 8
6 4
Pilgrim 2
. 0 Column 1 Column 2 Column 3 Column 4 Column 5 13
Examples of Inspectors Adding Value
- Inaccurate Suppression Pool Water Level Instrument Not Identified During Post Event Investigation (Pilgrim - See ML17226A0151 for Additional Details)
- Inadequate Implementation of Adverse Condition Monitoring Actions for the High Pressure Coolant Injection System (Hope Creek - See ML16319A2891 &
ML17033B5411 for Additional Details)
- Failure to Demonstrate Effective Preventive Maintenance Under 50.65(a)(2) for Instrument Air System (Limerick - See ML17041A1751 for Additional Details)
- Inadequate Assessment of Fire Brigade Performance during an Unannounced Drill (Susquehanna - See ML17214A7201 for Additional Details)
- Failure to Perform Testing of Emergency Diesel Generator Bypass Switches (Salem-See ML18099A0861 for Additional Details) 1Agency-wide Documents Access & Management System (ADAMS) Accession Number 14
Initiatives to Enhance ROP & Implementation
- Inspection Report Streamlining
- Resident Inspector Recruitment & Retention Study
- License Event Report (LER) Closure Review
- Engineering Inspection Program Assessment
- Inspection Procedure 95003: Evaluation of NRC Assessment &
Inspection Processes At Pilgrim (ADAMS Package No.
ML18158A1041) 1Agency-wide Documents Access & Management System (ADAMS) Accession Number 15
Oversight of Pilgrim Nuclear Power Station July 26, 2018 Michelle Catts, Senior Project Engineer Division of Reactor Projects Region I 16
Pilgrim Key Messages Operating Safely in Column 4-Sustainability remains to be assessed Pilgrim to Oversight strategy permanently includes Column 4 cease power and permanent operations no later shutdown than 6/1/19. inspections Progress in the licensees Recovery Plan being made Some challenges continue with procedure use and adherence and quality 17
Pilgrim Column 4 History
- Degraded Cornerstone for more than five quarters for exceeding both scram performance indicators and a 95002 that was not sufficient to fulfill the objectives of the inspection procedure
- White finding in September 2015 for not identifying and correcting a safety relief valve (SRV) failure
Inspection Procedure 95003 95003 Phase A Phase B Complete 1/15/16 Complete 4/8/16 Phase C Review Corrective Action Review overall Corrective Program to determine if Complete 1/13/17 Action Program operation of Pilgrim was performance since last NRC Review causes of decline.
acceptable. Problem Identification and Inspectors: 23 Inspectors: 4 Resolution Inspection.
Direct inspection hours:
Direct inspection hours: 155 Inspectors: 4 3389 Direct inspection hours: 161 19
IP 95003 Review of NRCs Oversight of Pilgrim
- An independent team reviewed the appropriateness of the NRCs oversight
- The team determined the NRC properly identified the decline in performance at Pilgrim
- The team identified some licensee event reports that were not evaluated as findings
- This issue did not impact Pilgrims placement in Action Matrix 20
Confirmatory Action Letter Focus Areas
- 1. Procedure Quality 5. Engineering Programs and Equipment Performance
- 2. Safety Relief Valve White Finding 6. Operational Standards and Leadership
- 3. Corrective Action Program
- 7. Nuclear Safety Culture
- 4. Human Performance 21
Status of Confirmatory Action Letter Inspections
- First and second CAL inspections complete
- 2 focus areas closed
- Safety Relief Valve White finding
- 42 out of 44 items reviewed were closed
- 8 inspectors, 506 hours0.00586 days <br />0.141 hours <br />8.366402e-4 weeks <br />1.92533e-4 months <br /> of direct inspection
- Third CAL inspection in progress
- 33 items reviewed - results being finalized
- 5 inspectors, 234 hours0.00271 days <br />0.065 hours <br />3.869048e-4 weeks <br />8.9037e-5 months <br /> of direct inspection
- Fourth and Fifth inspections scheduled 9/18 and 12/18, respectively 22
Current Performance at Pilgrim
- Some progress in recovery noted
- Conservative decision making
- Improved operator performance
- Corrective Action Program document quality
- Increased margins to performance indicator thresholds
- Sustainability continues to be assessed
- Inspectors identified continuing challenges with procedure use and adherence and procedure quality
- Pilgrim remains in Column 4 and will continue to receive enhanced oversight 23
NRC Oversight and Pilgrim Shutdown Plans
- NRCs oversight strategy considers potential issues stemming from announced permanent shutdown
- Enhanced quarterly assessments include both Column 4 and permanent shutdown strategies
- NRC will continue to monitor performance and adjust oversight as shutdown nears 24
Next Steps
- Implement and leverage baseline inspection program flexibilities
- Continue to perform quarterly CAL follow-up team inspections
- Supplement resident staff on an as needed bases
- Maintain increased NRC management oversight and site visits 25
Regional Communication/Interactions With Sites Going Through Decommissioning Process July 26, 2018 Matt Young, Branch Chief Division of Reactor Projects Region I Steve Hammann, Senior Health Physicist, Division of Nuclear Materials Safety Region I 26
Areas to be Covered
- Transition from Operating to Decommissioning
- Oversight and Inspection (IMC 2515)
- Oversight and Inspection (IMC 2561)
- Communication 27
Transition from Operating to Decommissioning 28
Oversight and Inspection (IMC 2515)
- ROP Inspection Plan adjustments
- Implement Inspection Plan 1 year prior to shutdown
- Areas potentially impacted by shutdown
- Deferral of maintenance
- Attrition in staffing levels
- Reduction in use of corrective action program
- Decreased emphasis on radiation protection
- Management oversight and quarterly assessments 29
Communication (IMC 2515)
- NRC and Licensee
- Resident Staff - continuous
- Regional Inspection Staff - periodically
- Branch Chief/Management - monthly
- NRC and Public
- Annual Assessment Meeting
- Public Outreach 30
Oversight and Inspection (IMC 2561)
- Starts with certification of fuel removal
- Decommissioning Branch sends letter to licensee stating oversight will be in accordance with IMC 2561
- IMC 2561 - Decommissioning Power Reactor Inspection Program
- Core inspections required every year
- Discretionary inspections as needed
- Inspection effort is dependent on the decommissioning activities
- Provides latitude to implement inspection program 31
Oversight and Inspection (IMC 2561)
- Resident inspector stays on-site for period of time as determined by management
- Decommissioning inspector will make multiple visits to the site prior to resident inspector leaving
- Post resident inspector - decommissioning inspector continues on-site inspections as well as in-office reviews of site activities
- Frequency and duration of inspections varies dependent on phase of decommissioning, licensee performance, site activities, and safety 32
Communication (IMC 2561)
- Decommissioning Branch Inspectors
- Management site visits
- Post Shutdown Decommissioning Activities Report (PSDAR)
Webinar
- PSDAR Public Meeting
- Support public outreach meetings
- Media - public affairs officers 33
Backfit July 26, 2018 Chris Cahill, PE, Acting Branch Chief Division of Reactor Projects Region I 34
Areas to be Covered
- Backfitting overview
- Renewed interest
- Current actions
- Committee to Review Generic Requirements (CRGR) additional roles
- Key outcomes to date 35
What is Backfitting?
Backfitting is defined as the modification of or addition to:
- systems, structures, components, or design of a facility;
- or the design approval or manufacturing license for a facility;
- or the procedures or organization required to design, construct or operate a facility Any of which may result from a new or amended provision in the Commission's regulations or the imposition of a regulatory staff position interpreting the Commission's regulations that is either new or different from a previously applicable staff position 36
Backfitting and Issue Finality Regulations
- Power reactors - 10 CFR 50.109, 10 CFR Part 52
- Licensees authorized to possess special nuclear material above a critical mass - 10 CFR 70.76
- Independent Spent Fuel Storage Installations -10 CFR 72.62
- Gaseous diffusion plants - 10 CFR 76.76 Note: Backfitting does not apply to Part 50 non-power production or utilization facilities or most materials licensees.
37
Why is there a Renewed Interest?
Our backfitting requirements provide regulatory stability, and help us focus new requirements in the most safety/security-significant areas.
However:
- the NRC has received criticism that, in some cases, we are not following our processes with enough fidelity; and,
- many staff have expressed the need for practical, interactive training that focuses on how backfitting fits into their daily job.
38
Current Actions The EDO directed the CRGR to assess the following areas associated with backfit:
- Requirements and guidance (NUREG-1409 and Management Directive (MD) 8.4)
- Staff training
- Knowledge Management 39
Action - Improved Guidance
- Management Directive (MD) 8.4, Management of Backfitting, Issue Finality, and Information Collection, has been provided to the Commission for review and approval
- Updating NUREG-1409, Backfitting Guidelines, which will serve as a single detailed guidance document - rather than individual office - or region-specific procedures 40
Action - Improved Guidance Proposed major changes to MD 8.4 include:
- Consideration of adequate protection backfitting as a first priority
- Improved guidance for implementing compliance backfitting
- Requirement to consider costs to support compliance backfitting determinations 41
Actions - Training
- Reset training was delivered in Winter 2017/2018 to provide a basic understanding of backfitting and heighten the staffs sensitivity to backfitting issues
- Interactive Backfitting Workshops were conducted, specifically targeting:
- Regional Reactor Oversight Staff
- Headquarters Reactor Oversight Staff
- Headquarters Reactor Licensing Staff
- Other Headquarters and Regional Staff with Backfitting Responsibilities 42
Actions - Knowledge Management
- Add backfitting documents to Knowledge Management website
- Prepare a NUREG/Knowledge Management document on CRGR history and activities
- Create a Backfitting Community of Practice with office points of contact 43
Additional CRGR Role
- CRGR charter will be revised
- Approval of certain backfitting-related guidance
- Consultation on facility-specific backfits
- Participation in review of formal backfit appeals
- Criteria for holding public meetings, both on specific reviews and to obtain feedback on general CRGR and backfitting activities
- Requirement to conduct periodic assessments 44
Key Outcomes
- A Backfitting Community of Practice has been established with clear points of contact
- Staff refocused on design and licensing bases
- Institution of consistent agency processes
- 95% of the targeted Agency staff completed the Interactive Backfit Workshops 45
Engineering Inspection Program /
Environmental Qualification Inspection Insights July 26, 2018 Glenn Dentel, Branch Chief Division of Reactor Safety Region I 46
Areas to be Covered
- Engineering Inspection Program
- Current engineering inspection program
- Value added inspection
- Engineering inspection review
- Purpose of engineering inspection
- Working Group recommended changes
- Environmental Qualification (EQ) inspection
- Key Messages 47
Current Engineering Inspection Program Year 1 Year 2 Year 3 DBAI - Programs Triennial Fire Protection BI: 192 Hours DBAI - Team Inspection BI: 240 Hours Resources: 3 Inspectors BI: 312 Hours Resources: 3-4 Inspectors Onsite Presence: 2 Weeks Resources: 4 Inspectors / 2 Contractors Onsite Presence: 2-3 Weeks Onsite Presence: 2 Weeks Heat Sink Inspection 50.59 Inspection BI: 40 Hours BI: 92 Hours Resources: 1-2 Inspectors Resources: 3 Inspectors Onsite Presence: 1 Week Onsite Presence: 1 Week Inservice Inspection Inservice Inspection BI: 30 - 100 Hours BI: 30 - 100 Hours Resources: 1-2 Inspectors Resources: 1-2 Inspectors Onsite Presence: 1-2 Week(s) Onsite Presence: 1-2 Week(s) 48
Value Added Inspection (Millstone, May 2018, IR 2018010, ML18197A091)
Flood Seals Not Installed in EDG and Auxiliary Building Penetrations
- Performance deficiency: Insufficient corrective actions from previous identification of unknown configuration of safety-related conduit flood seals.
- Inspector best practices: Trust but verify. Team requested confirmation of conduit status to close issue and observed inspection of conduit.
- Short-term corrective actions: Following inspections, open penetrations were promptly sealed.
- Safety and risk significance: Extent-of-condition (55 penetrations lacked documentation of flood seals, subsequent inspection found that 22 other penetrations had not been sealed). Fortuitous that large surface area in affected rooms and limited flood ingress duration minimized challenge to safety-related equipment.
49
Engineering Inspection Review Charter Tasks
- Increase the effectiveness and efficiency of engineering inspections
- Document bases for performing independent inspections
- Assess current program for gaps and overlap
- Determine more effective and efficient ways to accomplish
- Collaborate with stakeholders 50
Purpose of Engineering Inspection
- Verify licensees programs are minimizing the occurrence of initiating events and ensuring Structures, Systems and Components (SSCs) operate as designed
- Verify SSCs operate consistent with deterministic and probabilistic risk assessment (PRA) models
- Verify maintenance of defense-in-depth for common mode failures and external events
- Identify latent conditions which may only manifest themselves during events and may not be evident during normal operations and testing 51
Engineering Inspection Review - Continued
- Extensive Outreach
- 4 public meeting with industry and other public stakeholders
- Inspector input
- Management briefing
- Detailed team review
- Basis of each engineering inspection
- Gaps and overlaps
- Iterative feedback 52
Recommended Changes Year 1 Year 2 Year 3 Year 4 Comprehensive Focused Engineering Focused Engineering Focused Engineering Engineering Team Inspection #1 Inspection #2 Inspection #3 BI: 210 Hours BI: 210 Hours BI: 210 Hours Inspection Resources: 3 Inspectors Resources: 3 Inspectors Resources: 3 Inspectors BI: 350 Hours Onsite Presence: 2 Weeks Onsite Presence: 2 Weeks Onsite Presence: 2 Weeks Resources: 5 Inspectors / 2 Contractors Onsite Presence: 2 Weeks Inservice Inspection Inservice Inspection BI: 30 - 100 Hours BI: 30 - 100 Hours Resources: 1-2 Inspectors Resources: 1-2 Inspectors Onsite Presence: 1-2 Week(s)
Onsite Presence: 1-2 Week(s) 53
Recommended Changes
- New Comprehensive Engineering Team Inspection and Focused Engineering Inspection (FEI) with emphasis on operating experience (OE), changes, and aging management while using risk insights
- FEI areas selected based on risk significance, OE, potential for latent conditions, and engineering challenges 54
Environmental Qualification Inspection 71111.21N - Environmental Qualification (EQ)
- The NRC has not reviewed this area in detail since the 1980s
- Assumptions related to environmentally qualified components could be challenged by changes at plants (e.g., power uprates, license renewal)
- Samples are selected based on risk insights (e.g., PRA model, low-margin components, etc.)
- Inspection has provided value in Region I (see examples) 55
Value Added Inspection (Pilgrim, June 2017, IR 2017003, ML17319A158)
Failure to Conduct Proper Replacement of Safety Relief Valve (SRV)
Solenoid Valves
- Performance deficiency: Inadequate preventive maintenance schedule for SRV solenoid valve (32 year replacement established versus 10 year interval). Valve issue (high resistance reading for solenoid coil) identified during unrelated post-maintenance test
- Inspector best practices: Event response inspection. Questioning attitude, safety focus
- Short-term corrective actions: Conducted detailed testing that demonstrated the SRV solenoid valve would likely function during normal conditions
- Safety and risk significance: Potential impact of one or more SRVs (only 4 SRVs). Green as only assumed during LOCA based on testing. Mitigated by identification prior to full failure.
56
Value Added Inspection (Millstone, August 2017, IR 2017007, ML17256A586)
Failure to Maintain Auxiliary Feedwater Solenoid Valves
- Performance deficiency: Preventive maintenance task for replacement of solenoid coil and elastomer was not performed. Analyzed for 20 years; actually installed for 25 years.
- Inspector best practices: Review of requirements, trust but verify, persistence
- Short-term corrective actions: Conducted a detailed evaluation to extend the qualified life using actual temperature and operating history
- Safety and risk significance: Potential impact of both auxiliary feedwater injection paths. Mitigated by NRC identification and margin from actual operating history.
57
Key Messages
- Engineering inspections are important to identify issues before failures and events
- Engineering inspections have identified and mitigated potential risk significant issues
- Engineering Inspection Assessment is ongoing and seeking improvements in efficiency and effectiveness 58
FLEX Equipment Insights from NRC Inspections & Credit for FLEX July 26, 2018 Frank Arner, Senior Reactor Analyst Division of Reactor Safety Region I 59
Areas to be Covered
- Background
- NRC Inspections
- Credit for FLEX
- Challenges
- Path forward 60
Background
- Why FLEX?
- KEY lesson learned from Fukushima accident: extreme external events do happen and nuclear power plants must be prepared to respond to extreme conditions
- All off-site and on-site AC power sources lost for extended time
- Normal access to ultimate heat sink affected- normal method to move water lost
- All units on site assumed affected
- Objective: Allow station to restore and maintain key safety functions (containment integrity, core cooling, spent fuel pool cooling) 61
Background
3 Phases of Implementation:
- Phase 1 - installed equipment relied on, duration based on site specific analysis
- Phase 2 - transition to on-site FLEX equipment (generators and cables, pumps and hoses, fans, communication equipment, etc.)
- Phase 3 - Additional equipment shipped from National SAFER Response Center (first delivery 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; all equipment within 3 days) 62
Intake Structure FLEX DG PUMP Alternate RPV Makeup RPV Make-up Deployment Hose Route Options Primary RPV Make UP Min Flow Path SFP 3 way valve manifold Feedwater CRD Connections Turbine Building Reactor Building 63
NRC Inspections
- Temporary Instruction (TI)-191 Inspections
- Approximately 88% of the team inspections are complete
- All issues of concern go through a cross regional panel, including NRR, to assess whether a performance deficiency exists and if the issue will be documented as a finding
- Examples of Issues of Concern/Findings Identified Across Regions
- Incomplete/inadequate preventive maintenance plans or activities for FLEX equipment
- Incomplete/inadequate validation of installed connections and routing, and procedural implementation
- Incomplete generator phase rotation checks
- Failure to adequately consider hose routing issues
- Inadequate cold weather protection/evaluation 64
NRC Inspections - Continued
- Several findings - extreme cold weather conditions and a preventive maintenance issue
- Indian Point - all diesel driven equipment susceptible to run failures due to fuel filter clogging at low temps
- FLEX temperature range is (-15ºF to 115ºF), temperatures for FLEX storage building could drop to -6ºF
- Fuel cloud point temperature (21ºF) is well above required low temperature which could result in paraffin (white cloudy wax material coming out of fuel)
- Beaver Valley - diesel driven equipment procedures did not account for extreme cold conditions and potential for fuel crystallization or gelling
- Fuel additive not added before start of equipment (may sit idle outside many hours before starting equipment)
- Salem/Hope Creek - fuel oil samples for all of the site FLEX diesel generators and pumps were either never taken or not analyzed as required by established procedures 65
Areas of Potential Credit for FLEX
- Incident Response (Management Directive 8.3)
- Accident Sequence Precursor (ASP) Program
- License Amendment Requests
- Notices of Enforcement Discretion (NOEDs)
- Maintenance Rule 10CFR50.65 66
Challenges
- Collecting FLEX operating experience to develop equipment failure probabilities
- Industry continues to gather data on equipment
- This will inform failure probabilities within risk models
- Human Reliability Assessment (HRA) methods for FLEX are complex (i.e., challenging working conditions, managing stress)
- Developing basis for Human Error Probabilities (HEPs)
- Support from Office of Nuclear Regulatory Research to improve HRA modeling for FLEX manual actions
- EPRI Workshop in February 2018 discussed HRA methods for FLEX actions 67
Path Forward
- Consistent reliable approach to crediting FLEX
- Resolving 2 main challenges
- FLEX operating experience data and HRA method
- Oversight
- NRC is beginning to incorporate FLEX credit into our plant risk models
- Evaluating ways to incorporate into baseline inspection program
- Continue to engage internal and external stakeholders 68
Closing Remarks