ML20128N647
| ML20128N647 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/12/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20128N640 | List: |
| References | |
| NUDOCS 9610160468 | |
| Download: ML20128N647 (96) | |
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1 UNITED STATES OF AMERICA -
l 2 _ NUCLEAR REGULATORY COMMISSION l 3 +++++
l 4 PUBLIC MEETING 5 WITH 6 NORTHEAST UTILITIES 7 REGARDING 8 MILLSTONE UNITS 1, 2, AND 3 9 +++++
10 MONDAY 11 AUGUST 12, 1996 12 +++++
13 ROCKVILLE, MARYLAND 14
.15 The public hearing was held in the Nuclear 16 Regulatory Commission Auditorium, Two White Flint North, 17 11545 Rockville Pike, at 1:00 p.m., Phil McKee, Northeast 18 Utilities Project Director, presiding.
19 PRESENT:
20 Phil McKee 21 Jim Taylor 22 Bill Russell 23 Jim Milhoan 24 Hub Miller 25- Wayne Lanning " -
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'f' PRESENT (continued) :
1 2 Roy Zimmerman 3 Ted Feigenbaum 4 Bob Busch 5 Terry Harpster 6 Don Miller 7 Mike Brothers 8
9 10 11 12 13 14 15 16 17 18 19 20 21 l
22 l l
23 24 25 . .
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i P-R-O-C-E-E-D-I-N-G-S 1 2
(1:03 p.m.)
3 MR. MCKEE: If everybody could find a seat and 4 we'll try to begin here. It looks like everyone is about 5 settled. Thank you. .
6 Well good afternoon. I'm Phil McKee. I'm the l
7 project director in the NRC Office of Nuclear Reactor I 8 Regulation. I am responsible for the Northeast Utilities 9 facilities.
10 This is an announced meeting between the NRC 11 staff and Northeast Utilities, the licensee for Millstone 12 Station Nuclear Power Plants in Waterford, Connecticut.
13 All three Millstone units are presently shut down.
14 The purpose of this meeting is to discuss 15 independent verification actions needed to confirm the 16 effectiveness of Northeast Utilities programs to identify 17 and correct design control deficiencies prior to the 18 restart of each of the Millstone units. .
19 Seated at the table to my right is the NRC, 20 and the licensee persons to the left. We have here today 21 the executive director for operations, Mr. James Taylor, 22 the deputy executive director for nuclear reactor 23 regulations, regulatory operations and research, Mr. James 24 Milhoan, the director of nuclear reactor regulations, Mr.
25 Bill Russell, the associate director of reactor projdets -
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4 1 in the office of NRR, Mr. Roy Zimmerman, and the regional 2 administrator for NRC region I office, Mr. Hub Miller.
3 Also we have with us the director in Millstone oversight 4 team, Mr. Wayne Lanning, l
5 Mr. Feigenbaum, if you'd care to introduce the l l
6 people at your table, whoever you might. I 1
7 MR. FEIGENBAUM: Yes, I would. I'm Ted 8 Feigenbaum.' I'm executive vice president and chief 9 nuclear officer for Northeast Utilities. On my left here 10 is Robert Busch, who is the president of the Energy 11 Resource Group of Northeast Utilities.
12 To my right is Don Miller, senior vice 13 president of Nuclear Safety and Oversight. On my far 14 right is Michael Brothers, who is unit director for Unit 15 Three.
16 We will be joined by Mr. Harpster in a little 17 bit here. He had some plane problems. Terry Harpster is ;
l 18 the director of licensing services for Northeast _
19 Utilities. There are members of my staff to support us 20 behind me. )
i 21 MR. MCKEE: Okay. I might mention we too with 1
22 the NRC have a staff and a support group behind the NRC )
l 23 table here and some out in the audience. I 24 Thank you again. In accordance with NRC 25 policy and practice, this meeting is open to members bf NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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5 1 the public for observation only. This meeting will be 2 tr&nscribed, and copies of the transcript will be placed 3 in the NRC public document room and also in both the local 4 public document rooms in Connecticut as the documents 5 become available.
6 Following the conclusion of this meeting 7 between the NRC and the licensee, there will be a limited 8 period for comments and questions from the press, followed 9 by any comments and questions that the public may have.
10 Subsequent to that, there will be time for 11 media interviews with members of the NRC and subject to 12 the availability of the utility persons with them. NRC 13 public affairs is here. They will help support and 14 coordinate the interviews, at least for the NRC' staff.
15 , At the back of the room, just some 16 administrative items. I don't know if everybody had a 17 chance, anybody that's here. We have an attendance list.
18 We will try to include that when we publish the 19 transcript.
20 Also we plan one break during this meeting, 21 after the NRC has completed their presentation. We'll 22 take about a 10 minute break and reconvene. There will be 23 time for questions between Northeast Utilities and the 24 staff, followed by the questions and answers.
25 With that, I'd like to turn the floor up.;- Is -
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1 g .
1 there any questions on the protocol that we might have or ;
i 2 comments?
i 3 MR. TAYLOR: Just one. The company indicated I i
4 that they may wish to have a caucus at the end of the 5 staff's presentation to identify whether there are any I 6 additional questions that they want to have the staff '
7 address before we terminate the meeting. We are making i
j 8 arrangements for them to have a conference room for them 1
9 to caucus in.
10 So there may be a second break. That is, in l 11 the conduct of the meeting we may need to take a break for l 1
i 12 a short caucus to allow the company to formulate any 1 13 additional questions that they have.
14 MR. MCKEE: Okay. With that, I would like to 15 turn the floor over to Mr. Taylor for some opening 16 remarks.
17 MR. TAYLOR: Thanks, Phil. I will open with a 18 brief history which has some relationship to the design .
19 related problems involving Millstone Station that has led 20 to this meeting today. l I
21 As you may know, on April 4, 1996, NRC issued 22 a so-called demand for information letter under NRC 23 regulation 50. 54 (f) so that NRC could determine whether 24 Millstone Unit 3 was being operated and maintained in 25 conformance with the updated final safety analysis report -
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or FSAR license conditions, commission regulations. 3 2 Undergirding this request were NRC concerns 3
that the utility might have compromised safety through 4 failure to adhere to design. I would note that designs of 5 nuclear power plants are so complex and voluminous that 6
NRC could in no way review every portion of a plant's 7 design.
8 Nonetheless, in the late 1980s, NRC inspection 9 findings through special teams demonstrated that some 10 licensees had not adequately maintained their design basis 11 as required by NRC regulations. These issues prompted 12 many licensees to initiate design basis reconstitution 13 programs to identify missing information to selectively 14 regenerate documentation and to correct designs as 15 required.
16 NEI, then called NiR'3RC. developed design 17 basis program guidelines to provide a framework for 18 licensees to use in implementing design basis programs. .
19 Staff noted in a November 9, 1990 letter to NUMARC that 20 "the goal of any design reconstitution program should be 21 to establish confidence that the existing facility is in 22 accordance with the current design documents and that any 23 deviations are reconciled."
24 The staff advised the Commission that we 25 considered the NUMARC approach a useful framework that -
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8 1 would provide worthwhile insights to those utilities 1
2 undertaking design basis programs. The guidelines were i I
3 forwarded by NUMARC to their members to use on a voluntary i
4 basis. NUMARC also indicated that the majority of ]
l 5 licensees had begun,or were seriously considering - i 6 implementation of design basis reconstitution program.
7 During its review of these activities, the NRC 8 considered the need to promulgate additional regulatory 9 requirements to make the implementation of design document 10 reconstitution programs mandatory. The staff concluded in -
11 November, 1991, that additional requirements were not 12 needed because of existing regulatory requirements for 13 design control, specifically in 10 CFR 50.2, 50.34, 50.59,
, 14 and part 50 appendix A and B.
15 NRC also intended to continue inspection 16 efforts which would test the adequacy of engineering 17 activities by examining design products and plant 18 configurations. The approach on the part of the staff was 19 not to specifically review design basis programs, but 20 through its ongoing inspection activities should cases be 21 found where licensees were outside of their design basis, 22 the staff would then take enforcement action and require 23 that the design basis be updated and maintained.
24 Further, NRC modified its enforcement policy 25 guidance to encourage the voluntary identification of past -
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9 1 design engineering and installation issues.
2 In August, 1992, the Commission also issued a 3 policy statement which summarized existing requirements 4 under the regulations and the Commission's expectations 5 concerning availability and adequacy of design basis 6 information.
7 The policy statement the Commission emphasized 8 the importance that modifications to a facility only be 9 made after a thorough review had been conducted, and an 10 understanding of the underlying design bases had been 11 gained in order to assure appropriate design margins are 12 preserved.
13 As discussed in the 1992 policy statement, the 14 staff planned to issue a generic letter, which would 15 request that each licensee voluntarily submit information 16 about their programs related to assuring a design basis or 17 their rationale for not implementing such a program. I 18 In 1993, NRC decided to take no action on ,
I l
l 19 issuance of this generic letter. Based on issuance of the l 20 policy state which conveyed to the industry the l
21 Commission's concern about the importance of maintaining l I
22 the design basis and evidence that licensees recognized a 1
23 concern and were conducting such programs. Staff planned )
i 24 at that time to continue design related inspections.
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utility programs to improve and maintain the design basis 2
and the regulatory burden of team inspections reported in 3 the 1991 regulatory impact survey, NRC later reduced its 1
4 efforts on resource intensive design team inspections'and 1
1 5 shifted the balance to focus on operational safety. I j 6 We continued in the intervening years to focus 7 at all plants on operational safety versus areas, such as 8 design basis. Then in January of this year, based on 4
, 9 design and engineering information which we obtained, NRC
, 10 recognized that at Millstone the design basis was not
- 11 being appropriately maintained or adhered to. At that
(
i 12 time, I directed a special design and engineering 4
, 13 inspection be conducted at Millstone, led by Mr. Virgilio, i r j 14 who is here today, i
15 In summary, I wish to emphasize that the NRC j 16 position has been and still remains, that it is the i
4 17 responsibility of the individual licensees to have d
18 appropriate documentation that defines their design basis i
19 and to have procedures for performing necessary 20 assessments of design and procedure changes which are l 21 required by NRC regulations.
P j 22 The design deficiencies if stified at the 23 Millstone station represent a significant breach in
}
4 24 confidence we had placed on Northeast Utilities to
+
- 25 maintain the design and license basis.
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I believe that Bill Russell will now continue. I 2 MR. RUSSELL: Yes. If I could have slide 3 number one, please.
4 Since 1991, both NRC inspections, SALP 5
reports, enforcement actions, have indicated problems in a 6
number of areas at the Millstone Station. These relate to 7
configuration and design control failures that were just 8 discussed by Mr. Taylor, failures to implement corrective 9
action for known problems, failures to implement quality 10 assurance requirements, and failures to comply with terms 11 and conditions of the license.
12 These findings have been also verified by 13 licensee activities through a number of critical self 14 assessments performed by the licensee. The most 15 significant as it relates to design basis is adverse 16 condition report 7007, an Event Response Team report which 17 was completed and forwarded to the Commission in February 18 of 1996.
19 More recently, there has been an independent 20 root cause evaluation team which looked through the 21 history of the performance problems since the 1991 time 22 frame. That report was provided to the Commission in July 23 of this year.
24 There were earlier reports, in particular the 25 performance task group report in September of 1991, Which -
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12 1 identified some of the same root causes which exist today.
2 There have been others focusing on quality assurance 3 activities and other reviews performed by the licensee.
4 In response to these licensee internal 5 findings and discussions with the NRC and the enforcement 6 actions we have taken and issues discussed in SALP 7 reports, the company has had a number of corrective action 8 programs. These related to improving station performance 9 at Millstone Two, the utility's performance enhancement 10 program. There have been at least two substantial 11 management reorganizations associated with operations at 12 the Millstene Station.
13 This record shows that there has been a long-14 standing regulatory concern and a failure to follow 15 through on past corrective actions to ensure that they 16 were adequately implemented.
17 If you could move the slide up to the bullet 18 that starts Scope and Magnitude of the Problem.
19 This year, I issued a letter to the company 20 requesting that they identify for the first unit that they 21 propose to restart the detailed plan, along with specific 22 information about the degraded and non-conforming 23 conditions that they had identified to date. The company 24 responded, indicating that. Millstone Unit Three would be 25- the first unit that they propose to restart. " -
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13 3 1 They have made two submittals on Millstono 2 Three. As of the data for July 2, they had identified 3 approximately 1,200 non-conforming items, for which 4 approximately 600 they propose to address prior to 5 restart. .
6 Many of these changes are required to restore 7 operability as operability is defined in the facility 8 technical specifications. That is, be able to perform the 9 intended functions under conditions associated with design 10 basis.
11 These are not in the hundreds. Some of the 12 items may simply require correction of documentation to 13 correct differences between the as found plant and the 14 design basis documentation. There are a number, however, 15 which raise questions about operability and which are 1
16 requiring physical hardware modifications to the facility. ,
l 17 That is the background for this. What we i 18 would like to do now is discuss broadly two parallel ,
19 review activities. One which will be managed out of the l l
20 region with support from NRR, but will be the principle 21 responsibility of Hub Miller.
22 What I would like to do is turn the discussion 23 over to Hub Miller at this time, for some background on 24 the NRC's manual chapter 350 process, after which I will 25 " ~
come back and discuss the focus of this meeting.
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14 1 MR. MILLER: Thank you. Bill. Given the 2 significance and the persistence really of the issues that 3 Bill.has alluded to, NRC has found it necessary to 4 escalate its efforts in inspection and oversight of the 5 Millstone Station. Now I'll briefly review what that is, 6 focusing mainly on the part that the region plays a part 7 in.
8 First of all, at 'me beginning of this year 9 Millstone was added to the watch list as a plant requiring 10 increased monitoring. The inspection staff at the 11 Millstone Station, the resident inspection staff was 12 increased from four to six people. The agency conducted 13 the special inspection that Mr. Taylor talked about, led 14 by Mr. Vigilio.
15 We took such steps as dedicating a senior 16 manager, Mr. Wayne Lanning to my left, was designated as a l l
17 person from the regional perspective to provide full-time I l
I 18 guidance and oversight of the regional activities and to ,
1 19 be coordinating with the headquarters office.
20 After the plants were shut down, a l
21 determination was made that it would be appropriate for i 22 the agency to invoke the rigorous process that is laid out 23 in the manual chapter 0350. This is a process that is 24 intended to assure a very systematic and structured review 25 on the part of the staff, assure that there is - -
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15 N 1- completeness in our coverage of the issues, coordit.ation l
2 among_the various parties both in the region and in 3 headquarters that are involved, and very importantly, 4 assures that the process is conducted in a way that there 5 is' full documentation of the decisions that are made 6' before-restart of the plants are authorized.
7 All of this comes together in a restart action
- 8. plan that is developed under the guidance of a restart 9 panel. The restart panel is a team of headquarters and 10 regional people. Again, led by senior executives. In 11 this case, Mr. McKee and Mr. Lanning are the co-chairs of 12 the restart panel.
13 The 0350 process, however, also vests in-Mr.
14 Russell and myself as regional administrator, a'nd 15 reporting to the executive director of operations certain 16 responsibilities to oversee this process. In other words, 17 it lays out the roles and responsibilities of the staff to 18 assure a coordinated and thorough review. ,
19 Among other things, the restart plan calls for .
20 the identification of the issues that are to be focused ;
21 on. They are the sort of things that Bill talked about.
22 But it also calls for the identification of various 23 inspections that are needed to get assurance, that before 1 24 restart, the issues have been either resolved or that 25 there has been substantial progress sufficient enough to -
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1 warrant restart. l t
2 These inspections that we would expect to
'l 3
conduct prior'to restart include of course the continuing ;
l 4
inspection by the resident inspection staff, by the region I l
5 based inspectors on selected issues, and of course ,
6 continued oversight from headquarters.
7 It includes the independent corrective action 8 verification inspection that we will be talking about 9 today. I won't say anything more about that.
I 10 But finally, it will include an operational 11 readiness inspection which will be completed after the 12- company, the licensee has determined for itself that it is 13 in a position to~ restart, that it has resolved the issues 14 that are before us.
15 This inspection will be really a customized 16 inspection. It will of course in the scoping and the 17 focusing of this inspection, we will be taking account of 18 the findings of previous inspections and very importantly, 19 the independent corrective action inspection that we will 20 be conducting.
21 Its focus will be on the broader issues that 22 go beyond the design issues that will be the principle 23 focus of the corrective action verification inspection, 24' focus on human performance issues, issues of procedure l
.25 adherence, and that sort of thing. " -
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-4 1 It is important to point out also that 2 throughout this whole process, that there will be 3 extensive steps taken to assure public involvement and 4 public visibility on this process and the inspections that I
5 area conducted. '
6 I have listed a couple things here. We will l
7 continue to conduct our so-called exit meetings with 8 licensees upon the completion of inspections. Those will-9 be open to the public.
{
10 We will continue to conduct periodic public ;
11 meetings to review the status of our oversight activities.
12 There have been several meetings conducted by Mr. Lanning-13 in the vicinity of the site.
14 Meetings.with the licensee on significant 15 issues such as restart plans will be open to the public.
16 There was a meeting in fact held on the 24th of July and 17 another meeting to be held on August 19th, in fact on 18 restart plans. Those will be open to the public for '
19 observation. There is always opportunity presented to the 20 public to make comment.
I' 21 Lastly in this regard, we will continue to 1
22 provlie information through the public document rooms. We 23 in fact opened up a second public document room recently 24 at the Waterford L.brary to supplement the one already l
25 existing in Norwich. " ~
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18 i 1 I think also in this connection, I should 2 mention that the NRC has encouraged the State of 3
Connecticut to give strong consideration to observing i
4 inspections that are conducted under agreements that are 5 open to the states to sign, to specifically observe -
)
2 6 inspections. We expect that they will avail themselves of
) 7 that opportunity.
8 Lastly, I should say or I should mention that 9 the Commission recently following the most recent senior I
10,: management meeting made the decision that the Millstone 11 Station should be moved to category three on the watch 12 list, which means that before restart is approved or j
j 13 before restart occurs, the Commission must consider the
, 14 situation and make a conscious decision and approve 15 restart.
! 16 I should lastly mention that if restart is
- l
- 17 approved, that would not change the status of the plant on i
18 the watch list. That would remain an issue to be
- 19 considered through the senior management meeting process.
I 20 But that gives you an overview of the overall
{
21 process, focusing mainly on the role that the region 4
( 22 plays.
1 23 Bill?
A 24 MR. RUSSELL: Okay. What I'm going to do to 1
j 25 organize the presentation is first provide some backdtound
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19 1 on what an independent corrective action verification 2 program is. This is an overlay of the 350 process. That 3 is, it's an addition to. This activity will be overseen 4 out of headquarters.
. 5 It is based upon NRC experience with 6 independent design verification programs. These were 7 conducted typically in the 1980 time frame, post Three 8 Mile Island, in the period where we were having some 9 concerns about the quality of construction and 10 implementation of design during construction, was 11 typically used for facilities that were near-term 12 operating licenses to review and verify that the license 13 commitments were in fact appropriately incorporated into 14 the actual as-built as design facility.
15 The key elements of the independent design 16 verification program were first, it was conducted by a 17 third party. We'll come back to that to define what we 18 mean by independence and technical qualification. ,
19 The third party is contracted for by the 20 licensee. It is composed of highly qualified staff, with 21 experience typically in architect engineering activities, 22 including both design as well as pre-operational matters 23 associated with testing to verify that the design has in 24 fact been implemented through testing.
25 The team selection, that is, the independbnce ~
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20 1 and the qualification of the members, were reviewed by NRC 2 to' determine their independence and their experience, )i 3 breadth, from the standpoint of constitution of the team.
4~ Protocols were developed which resulted in l 5 parallel reporting of information as discovered to both l
l 6 the NRC and the utility. In this case, we.would look for 7 parallel reporting between the team and Northeast 8 Utilities.
I 9 The final part is that the NRC conducted its i
10 own parallel overview of what the team was doing, to 11 ensure that it performed an adequate scope and depth of l 12 review, and that the plans that the team developed were in 13 fact implemented. This typically consisted of reviewing .
I 14 products of work in process, but also may include some 15 independent calculations and did include independent plant l 16 walk-downs, verifications of information.
17 We have modeled the plan as it relates to an 18 independent corrective action verification program upon ,
1 19 the design verification program activities. The major 20 difference being that we are looking not at the original 1
21 design work that was done for initial licensing, but l
22 rather, how the design has been maintained with time since l I
23 initial licensing.
)
24 If I could have the next slide, please. What 25 are NRC expectations for the conduct of an independedt -
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7 21 1 corrective action verification program? First is to have 2 a well-defined plan for in-depth evaluation that is a '
- 3. vertical slice for the selected systems. That there t
4 should be a risk safety based criteria for the choice of 5 the systems. selected for audit.
6 There needs to be an audit plan to confirm 7 that the licensee review on the system selected for the 8 independent verification activity is representative. That 9 is, if there are, and I'll use numbers now. Let's say 10 that you have 20 risk significant systems based upon what 11 you have laid out in the maintenance rule implementation, 12 and that you have a total of 60 or 70 systems. I'm not 13 sure what the right number is that are associated with l
14 Millstone 3.
15 We would be interested in making sure that you 16 used a similar process on each of those, such that the 17 system chosen for audit is representative of the work 1 i
18 activity conducted on the other systems. We would expect l 19 that the independent corrective action verification team 20 effort would be able to audit that process and convince 21 themselves that the methods chosen for the systems audited 22 were similar to the methods used by Northeast Utilities in 23 confirming, and be able to confirm that conclusion.
24 We want a formal protocol for concurrent 3
25 reporting of in process and final results to both ths-NRC -
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1 and the licensee.
I' 2 By independent, and I'm now discussing as it 3 relates to individuals on the team, we would want no 4 current or previous employees or contractors who had been 5 involved, in this case specifically with Millstone 3 6 review activities.
7 No financial interest. That is, not own stock 8 in. What we would do is look to the NRC conflict of 9 interest provisions as they relate to contractors, would 10 be the area we'd be looking for standards in this case. ;
11 We will be interested in procedures for 12 reporting findings. That is, making sure that the ;
13 independence of the team as to how they present, so that 14 they are not presenting through the company to us, but in 15 fact, are able to present independently to the company and 16 the NRC at the same time.
17 There are some important issues also with 18 respect to phasing and timing of work, particularly as it 19 relates to you completing work under your restart plan and 20 your configu::ation management plan, such that some of this 21 independent review activity can start earlier when you 22 have gotten to the appropriate point in your review.
23 For NRC oversight of this activity related to 24 such things as reviewing the qualifications and 25 independence of the team, looking at the procedures 6 hat -
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23 S 1 have been developed for reporting concurrently to you and i 2 to the NRC, for looking at the scope of the plan, for 3 approving the systems that were chosen for audit, that 4 will be conducted by a team led by an SES manager from 5 headquarters with a, number of inspectors. That team will 6 be reporting to me.
7 So it will be independent of the 350 process 8 as it is being managed. So this is in addition to. Next 9 slide, please.
10 What I want to focus on for a few moments now 11 are elements of phasing of work, corrective action work, 12 under your restart plan. That is, the Millstone Station 13 restart plan and the configuration management plan as it's 14 applied specifically to Millstone 3.
15 For purpose of discussion, I have broken this 16 up into two phases. Phase I is what I will characterize 17 as problem identification. Not necessarily identifying j 18 the corrective action for a problem or designing a fix or 19 implementing it, but just going through whatever process 20 is used to identify the extent of the problems.
21 The first important point here is that we want 22 problem identification and operability assessments as l
23 needed on a system by system basis. We would like you to l
l 24 use the same definitions of systems that you are using for 25 the maintenance rule under 50.65, with the same inter' faces -
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24 i
1 that you have used to define for maintenance rule
, 2 implementation. That is to ensure that there's not i
3 confusion as it relates to boundaries and interfaces.
'4 We would like you to identify the non-5 conforming conditions that are associated with those 6 systems such that rather than as you did in your July 7 second submittal, where you indicated you had some 1,300 8 items or so, we would like you to organize it by system.
9 So a risk significant system may have for example, a total 10 of 50 non-conforming conditions, some number of which you 11 may decide need to be corrected for restart.
12 What I am talking about in phase I is 13 organized by system, that the non-conforming or degraded 14 conditions are identified and organized by system.
15 We would like you to focus on the most risk i 16 significant systems first. That is, by way of applying 17 your resources, don't start with the ones that are easiest 18 to accomplish first, but start with the more risk ,
19 significant first and work through.
20 You will see that that is important later, i
21 because as you have a number of systems completed in the 22 problem identification phase, we will select from those or 23 approve the selection of those chosen for audit. We want 24 that to be a reasonably representative sample such that we 25 can in fact randomly choose to decide which ones areNEo be ~
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25 0 1 audited. -
So it won't bs the first or necessarily the 'l 2 second system that you complete.
3 We are interested in making sure that a 4 consistent process is used in phase I for problem i
5 identification. Most importantly, we want line management l l
l 6 to have concluded that the discovery phase, if I use terms l 7 in a proceeding is complete, and that you have identified l l
8 the degraded or non-conforming conditions associated with l 9 that system using the boundary interface descriptions from 1
10 the maintenance rule.
11 When the line is done, we're going to be l 12 looking for the quality organization to also sign up 13 formally and say that problem identification is complete 14 and that this was done in a consistent manner with other 15 systems that are being evaluated at this point in time.
1 16 We do not want or it's not necessary to have 1
17 identified specific corrective action to be taken. It's l
18 not necessary to have completed the corrective action. ,
19 Those will be phase II activities. But we can start the l 20 review on the first portion, which is the problem 21 identification at the point where you have reported to us 22 a number of systems are complete and that you both based l 23 upon line reviews and quality reviews have concluded that 24 problem identification is sufficient.
25 " l What we are really looking for is that -
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26 '
i statement from the company that you are essentially done 2 with that phase and that you've got a punch list of what 3 are the non-conforming conditions. That would be the 4 starting point for the independent corrective action 5 verification team effort to go in and independently assess 6 whether that is in fact correct, that you have identified 7 all of the degraded and non-conforming conditions 8 associated with that system. Next slide, please.
9 Phase II. Phase II of your work involves the 10 identification of the corrective actions to be taken for 11 each of the degraded and non-conforming conditions. The 12 review for each of those items with a dispoaition could be 13 that it is acceptable as is, and you revise design basis 14 documentation and/or the FSAR in accordance with 50.59, or 15 it could be that you have concluded that there is a change 16 needed to the facility design or a change in procedures or 17 some type of reanalysis. Whatever is the appropriate 18 corrective action for each of the items, we would expect .
19 you to identify that.
20 For actions which are going to be deferred 21 until after restart, we would like you to identify the 22 basis for deferring that work. It could be on risk 23 significance or other matters.
24 For deferred work, if it's based upon risk 25 significance, you may not have to identify the explicit -
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1
1 corrective action you are going to take, but you clearly 2 have to provide a rationale for why the item should be 3 deferred and why that would be acceptable to remain p 4 deferred should restart be approved.
3 5 Our intent is for you to complete the 1
j i
6 corrective, not the corrective action implementation, but 4
7 the problem identification such that if restart is 8 approved, there is.not a surprise later by identifying j 9 some significant problem post-restart.
1: . 10 The context that we are discussing now is how j 11 much of the known problems need to be addressed at the 4
l 12 time of a restart decision and a rationale for those that-
- 13 are in fact deferred, i
14 NRC oversight. I mentioned some of this
- l. 15 earlier. What I want to do is highlight.that we have a 2'
- 16 350 process which is the agency procedure for restart i 1 17 approval. For members of the audience, we will have a l l
. l l 18 number of copies of NRC manual chapter 350 that will be . ,
. l 19 available in the back of the room such that they can see j 20 what is the scope of review as it relates to restart 4
i 21 approval. Also by way of background, there is a copy of 22 inspection manual procedure, chapter 25.35 on design 23 verification programs, both of which were discussed in l
l' 24 background.
l
- 25 Again, the responsibility for coordinatidn of -
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28 l 1 the 350 process is the regional administrators. To 2- implement that, two individuals have been assigned, both i 3 SES managers, one from region I, one from headquarters.
l l 4 That's Wayne Lanning and Phil McKee, to manager tha 1
5 activities. We do e,xpect that the NRC will have completed -
. 6 and issued its' restart plan prior to the meeting that's
. 1 7 scheduled, I believe Hub mentioned, I think it's the 19th l 8 of August.
9 Again, the results of the restart activities i
.10 for the NRC would be presented to the Commission and it
! 11 will be a Commission decision on restart. Next slide, 4
12 please.
13 The NRC has been developing internally a 14 minimum set of actions that we feel are necessary in the i 15 context of an independent verification of implementation
.l 16 of plans. This goes back to the information I discussed 17 in the opening comments. That is, we've had a history of 18 concerns. We have had previous plans from the company, .
19 previous reorganizations. There has been not a sufficient 20 follow through in implementation.
21 Given that history, we have concluded that 22 there needs to be an independent corrective action 23 verification program. It is our intention to issue an 24 order formally requiring the development and 25 implementation of an independent corrective action - -
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29 1 verification program. t 2 While we hope that such an order will simply ;
i 3 confirm the licensee's agreement to conduct a program )
4 along the lines that I'll describe in the next few slides, 5 there should be no doubt that absent agreement, we are 1 1
6 prepared to promptly issue an order directing the licensee 7 to undertake certain specified steps to provide the 8 necessary independent assurance that deficiencies have 9 been identified and that lasting cort '.ive action has
)
10 been taken.
11 The next two slides, slides seven and eight, 12 are identically the text that we would be proposing to 13 impose or confirm by order. This is the portion of the 14- meeting that if there is any question regarding what is 15 intended by the text for these slides, that this is the 16 opportunity to raise questions.
17 Let me go through them first. One, implement 18 an independent corrective action verification program ,
19 including first, conduct of an in-depth review of selected 20 systems design and design basis since issuance of the 21 facility operating license.
22 Develop risk safety based criteria for 23 selection of the. systems for review. Develop a 24 description of the audit plan to ensure that licensee 25 problem identification and corrective action on the. " -
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- 30 i
4 i selected system or systems are representative and i 3
consistent with other systems.
2 '
3 Four, develop procedures and schedules for l
1 4 parallel reporting of findings to NRC and Northeast i'
5 Utilities.
6 Finally, procedures for commenting on the i
7 licensee's proposed resolution of team findings and i
~
)
8 recommendations.
i 9 The concept here is that the team in i
- j. 10 developing findings or recommendations may do that based 11 upon information they have available. It may be that the j 12 company has additional information, that when that
- 13 information is brought to the table, that the team would i
J 14 conclude that the matter has been resolved satisfactorily 4
15 and there was not a non-conforming condition, that it was i
i 16 in fact satisfactory.
J i
j 17 We want to provide for that feedback loop, but 1
l 18 we want that to be a formal process such that it is well ~
19 documented and is publicly scrutable. Next slide, please.
l 20 What I just described is what I would call 21 process, how it would be conducted. What I want to do now 22 is discuss scope and depth of review.
23 Scope of the independent corrective action 24 verification program will include engineering design and 25 configuration control as required by NRC regulations'- -
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31 s
1 today. That's principally 50.2, which defines design-l
\
2 basis as well as 50.34, 50.59~, appendix B in particular,.
3 criterion 16, corrective action. program, and the others 5
4 associated with design control. So this is not imposing l l
5 any new requirement beyond the regulations that exist j 6 today.
7 Second element. Verification of as-built as j 8 modified conditions. Look at for example, the. design 9 changes that have been made to the system since initial l
10 licensing. Look at them both on an individual basis and 11 an integrated basis as to how they interact with each 12 other. Verification of as built to as modified 13 conditions. That is, a physical walk down of the plant to 14 verify that the as-built or as-modified conditions are 1
15 representative of the design basis.
16- Third, translation of design and licensing l l
17 basis requirements into operating procedures, maintenance-l 18 and testing. There may be a design change which puts an 19 interface into an operating procedure, as to how the new 20 design would be operated to make sure that those 21 interfaces are appropriately reviewed as a part of the 22 change process.
23 Four, verification of system performance 24 through review of specific test records and observation of 25 selected testing on the particular system. Whether this -
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32 1
is simply a surveillance test or it's a request to perform 2
a portion of an earlier pre-operational test based upon 3 modifications that have been made, that's the context that 4 we're talking about here. This is verification from 5 actual observation to the extent it's appropriate, either 6
looking at records or looking at subsequent testing.
7 The concept being that the earlier testing may 8 have been on a configuration that's different, is the 9 system still able to perform its intended design function 10 based upon modifications that may have been made.
11 The scope of this is principally to focus on 12 modifications made since initial licensing of a facility.
13 We're not talking about going back and redoing the initial 14 design basis. There may be cases where you discover that 15 the as initially designed facility is somewhat different 16 from records that you have associated with a facility 17 safety analysis report or other documentation. Those 18 matters need to be resolved consistent with the 50.59 19 review process.
20 You clearly have the option of either 1
21 conforming the documentation to the as-built plant through j l
22 50.59 review or modifying the plant to conform to the 23 licensing basis either is an acceptable resolution to 24 bring the two into conformance.
l 25 What I would like to do is pause for a moment -
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1 because this is really the meat of what we want to convey 2 in this meeting. That is, the concept of an independent 3 review, how it would be conducted from a process 4 administrative control standpoint, and scope and depth of 5 review as it's characterized on these two slides.
6 If you would like to -- let me go on.
7 MR. FEIGENBAUM: Why don't you continue to go.
8 MR. RUSSELL: Let me go onto slide nine. Then 9 if you want to caucus and come back for questions, we can 10 do that.
11 MR. FEIGENBAUM: Good.
12 MR. RUSSELL: Slide number nine. NRC 13 oversight of the corrective action verification program.
14 These are not explicitly called out in the 15 order, but these are elements which are either in the 16 background or in the phrasing in the order that says as 17 otherwise directed by the director of nuclear reactor 18 regulation.
19 But again, these are elements that I want to 20 make sure there's a clear understanding as to how we would 21 interact on these.
22 The qualifications and independence of the 23 individuals chosen to perform the review would be agreed 24 upon and approved by NRC, whether we indicate a no 25 objection to these individuals or we explicitly apprdte, -
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34 1 that's in the details to be worked out. But it's clearly 2 our intent to ensure that they are appropriately qualified
'3 and they are independent of past involvement with the 4 facility.
5 MR. FEIGENBAUM: May I ask one clarification?
6 MR. RUSSELL: Yes.
7 MR. FEIGENBAUM: That's any involvement at any 8 time in the past regardless of unit, regardless of time 9 frame?
10 MR. RUSSELL: We have not really addressed the 11 issue as to whether they may have been involved, for 12 example, on unit one but were not involved on unit three, 13 recognizing that you have different vendors for the three 14 units. At this point in time --
15 MR. FEIGENBAUM: On a case by case basis?
16 MR. RUSSELL: It needs to be addressed on a 17 case by case basis. There is or would be a provision in 18 the either order or confirmatory order for how that ;
19 approval process would be implemented. )
20 We will be conducting a parallel inspection. l
'21 The plan is to use people who had been involved with the 22 Virgilio team inspection, such that we don't have to have 23 people coming up to speed again with site access, badging, 24 et cetera, or learn your internal processes and procedures i l
25 or how to use your various computer based tools for " -
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^
35 1 determining information related to design basis '
2 documentation.
3 The team will conduct parallel inspections.
4 They will audit calculations. They may perform their own 5 calculations. They will review the corrective actions and 6 the implementation for the selected systems.
7 This is an area where we will not have 8 duplication between the 350 process and the independent 9 verification once the verification starts. Clearly, -
10 through the 350 process, there will be inspection and 11 monitoring of work in process. So there may be some 12 overlap before the actual system is chosen for audit. .But 13 once that is done, our intent is that there would not be 14 duplication of those activities.
15 . Any necessary coordination on questions we 16 have about whether something should or should not be 17 deferred until after restart or whether agree with that, 18 would be done internally within the NRC. ,
19 Most importantly, any conditions that are 20 required or actions that are required for restart would be 21 separately determined by the Commission. That is, this 22 order only addresses the scope of independent corrective 23 action verification. It is not something which upon 24 completion would necessarily be sufficient for a restart 25 decision. " -
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)
i
i 1 It is also not saying that there would not be "
2 a subsequent order that would lay out a schedule and i
3 requirements for things to be completed post-restart. !
4 What I am pointing out is that those matters will be the 5 subject of separate communication and direction. Those 6 matters will be decided by the Commission itself at the 7 time they vote on restart. l 8 That covers the items, with the exception of 9 scheduling. We think that it's important to complete this 10 process relatively quickly. We are requesting that you 11 caucus and decide if there is additional questions or 12 information that you would like to have. We'd like to 13 cover it in the context of this meeting.
14 If not, we would like to have correspondence 15 from you committing to the elements that were on the two 16 slides number seven and eight, in writing by close of 17 business tomorrow. If that reply is found to be 18 satisfactory, we would propose to confirm by order not ,
19 later than close of business on Wednesday.
20 If on the other hand, you conclude that you 21 are not able to commit to some element as we have laid it 22 out, we would be prepared to implement by order also to be 23 issued by close of business on Wednesday.
24 So unless you have any questions at this point 25 -- " -
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37 I' 1 MR. FEIGENBAUM: I have one or two just brief s 1
2 ones before we. caucus. We would like an opportunity to 3 meet privately and talk for a few minutes before we give j, 4 you any additional questions.
4 i 5 The question I have is regarding phase II i
- 6 resolution, where your first bullet there indicates l
- 7 necessary corrective actions identified, reviewed, and
- 8 implemented. I assume what you are saying there is that
{
j 9 on the selected safety systems a representative sample of i 10 the corrective actions would be identified, reviewed and 4
j 11 implemented?
i 12 MR. RUSSELL: That is correct. Obviously some j
}.
13 number have to be identified and through a process such f 14 that they could independent verify satisfactory 3
15 implementation, d
j 16 We would also expect that some of them would i
17 be more risk significant such that we could verify
- 18 satisfactory implementation of the more risk significant I
i'
! 19 modifications or more complex modifications, rather than j 20 you have completed the implementation on the ones that
.t 21 involve simply a change to the FSAR paper procedure, et 22 cetera.
9 .
d 1 23 We are interested in those that have interface f
- 24 with operations. That is, clearly we intend the scope to i.
- 25 include the interface with operations, how the procedure -
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l 1
~
38 1 changes have been processed, the appropriate training has 2 been conducted, and the fact that the people can in fact i 3 operate the as-modified system consistent with the design 4 basis.
5 But we do not intend for it to have all of .
6 them completed, but there needs to be a sufficient amount 7 of work done on the selected system for the independent 8 corrective action verification activities to address'the 9 sufficiency of it, consistent with your revised 10 configuration management plan and procedures.
11 Completion of all items required for restart 12 is back in the 0350 process. That's why I said those 13 would be presented to the Commission. It's through the 14 0350 process that we would be prepared to take a 15 recommandation to the Commission at the time when we 16 believe that that work is completed.
17 In the past, four facilities that have been 18 under the 0350 process, there is typically a period of 19 time between a Commission briefing and a decision and a 20' punch list that may exist at the time of the Commission 21 briefing. Then there are status reports as to how those 22 are completed. Generally the approach is.one that if the 23 Commission is satisfied, they then act, delegate to the 24 regional administrator to allow restart subject to certain
~
25 things being met with reports to the Commission from;the -
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39 l
1 regional' administrator at the time those final items have l 2 been verified.
3 That is a very consistent process with how we
? -
4 handle the issues associated with Watts Bar, for example.
5 If you look at the record on Watts Bar and how the l
l.
l 6 decisions will made, that this will clearly be a L
L l
7 Commission decision on restart for which the staff will be implementing guidance received from the Commission.
8 9 MR. FEIGENBAUM: Understood. Mr. Russell, 10 that is very helpful by the way. The second I question I 11 had had to do with when we submitted our initial findings 12 on July 2,'we noticed, we made you aware of the fact that l
i .13 there-were a number of programmatic issues. There were 16 14 areas that we needed to do more work in. One of them, for 15 instance, was our method for keeping vendor l
16 recommendations up to date.
17 Those kind of programs cut across all systems, 18 certainly all significant safety systems. Would those .
19 kinds of issues of resolving' vendor manual program, for l
l l 20 instance, would that be handled as a punch list item to be l
21 looked at by the 0350 process?
22 MR. RUSSELL: Our intent would be that those 23 types of issues which are generic, which cut across, would 24 be handled through the 0350 process. Assuming that you 25 have revised your procedures for implementing a corrective -
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40 ?
l 1
action change, then the observation of that work being ll i
2 done as it relates to the system would be the basis for 1 l
3 the independent corrective action verification.
4 We are focusing on end results completed l l
5 product, not process and commitments to do so in the 6 future. So if, for example, you are in the process of 7 revising your procedures as to how you handle vendor 1 l
l 8 information, and the vendor information is significant as '
l 9 it relates to potentially a degraded or non-conforming l l
10 condition from the licensing basis. Let's say it's l
11 associated with testing and/or maintenance on a system l l
12 where the system may be degraded or not operable, those j 13 kinds of issues would need to be followed either based 14 upon the process you have in place today or your~ revised I
15 procesa to judge the adequacy of the outcome. l l
16 So the independent corrective action l 17 verification is focusing on results, not on process and 18 procedure. The 0350 process will review and make 19 determinations generically as to whether you have an 20 adequate program for controlling information.
21 MR. FEIGENBAUM: What I was trying to get 22 clarification on is for instance, if we had an issue on a 23 vendor manual related to service water system, which is 24 obviously a safety significant issue, would that be held 25 up, turning over the service water system to the " -
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41 1 independent verification team, pending completion of ths
- 2 vendor manual program?
3 MR. RUSSELL: Not necessarily, provided you 4 have identified that that issue is open and that you are 5 addressing it. It's not part of the discovery phase.
6 What we are saying is you need to identify the 7 scope of problems at the time you turn the system over and 8 the line and QA have signed off on that.
9 The subsequent corrective actions may occur 10 over a period of time. What we don't want to do is wait 11 until all the corrective actions are done and then be 12 piling on at the end with additional unnecessary delay.
13 MR. FEIGENBAUM: So if vendor manuals for 14 service water system was an issue, that would be on our !
15 punch list. That would be looked at as part of that 16 process under the 0350. j 17 MR. RUSSELL: That is correct. For example, 18 your internal procedures for how you wish to control ,
19 vendor manuals in the future, where they are going to be 20 maintained, who is responsible for them, et cetera. That 21 would be done generically through the 0350 process review.
22 MR. BUSCH: Yes. Mr. Russell, I just want to 23 step back for just a second and make sure on the 24 independent corrective action verification program, I 25 understand the sequence. " -
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42 -
l l
1 If I understand it, it would be basically in ,
i 2 very large pieces. First we will get back to you 1
3 confirming our understanding of this and then the issuance 4 of an order. Then followed by our proposal of an 5 independent verification group or a firm or a body, 6 however it's assembled. You would then go through the 7 process of in some way approving that team of people to do 8 the work?
9 MR. RUSSELL: Yes. We would review their lo qualifications and their independence. If we find them 11 acceptable, we would issue a letter back indicating that 12 that is an acceptably independent and technically 13 qualified team to conduct the activity.
14 MR. BUSCH: Right. Next, they would basically 15 put the entire plan of action for their work together?
16 MR. RUSSELL: That is correct.
17 MR. BUSCH: You would then essentially 18 independent of the licensee, with them, review and in some 19 fashion concur with that plan of action?
20 MR. RUSSELL: That is correct.
21 MR. BUFCH: We would then start phasing the 22 actual work of the team in the two phases that you talked 23 about, first, the phase on discovery where they confirm 24 punch list items. Then finally, the second phase on those 25 punch list items their independent review of corrective -
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43 k 1 action.
2 Then as systems closed out and they closed out 3 corrective action, that would ultimately be the conclusion 4 then of their work.
5 MR. RUSSELL: That is probably correct, yes.
6 What we are going to try and do is be in a mode where 7 based upon the requirements of the order, information is 8 submitted. That is, a plan is submitted. Unless we find 9 that there is a problem with it, where it's not 10 appropriately independent, not properly phased, et cetera, 11 so that we are not on a critical path for approving.
12 But if we come back to you and say this needs 13 to be changed, we'll give you the rationale as to why it 14 needs to be changed.
15 So that the intent is, that they could be 16 developing some of the planning activities while you are 17 going through your internal work as it relates to phase I, 18 whatever the line and the quality organizations are doing 19 to identify the scope of problems on a system by system 20 basis and organizing that information.
21 MR. BUSCH: That would then fit together with 22 the 0350 process where probably this would be done prior 23 to the conclusion of the 0350 process?
24 MR. RUSSELL: That's the intent, that this 25 would be done before that point in time. It would provide -
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44 I 1 confirmation through an in-depth vertical slice, looking ,
l 2 at results to confirm that the processes that you are 3 using are satisfactory.
4 MR. FEIGENBAUM: Okay. If we could get a few 5 minutes.
6 MR. MILLER: Before we break, there's one 7 issue that I needed to just clarify. It has to do with 8 the restart plan and the August 19th meeting. I want to 9 clarify this. It's kind of a detail in a way, but there 10 is a lot of public interest in this.
11 The meeting on the 19th is a meeting to review 12 or it's a continuation really of the July 24th meeting we 13 had with you regarding your restart plan. We had to 14 terminate that first meeting and didn't have enough time 15 to go through all of that and give you comment. That 16 meeting of course is open to the public.
17 But there will be a second meeting on August 18 20th, where we will get additional public input. We have 19 made it known that we are interested in hearing from the 20 public regarding our restart plan, the restart plan that I 21 described in my remarks at the beginning.
22 So it's easy to get these things confused.
23 But on the 20th, there will be a separate meeting. It's 24 after that meeting on the 20th when we get public input, 25 that we will complete the development of that plan. 'Then -
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45 1 that will be made publicly available. I expect that will 2 be a living document, updated from time to time.
3 MR. FEIGENBAUM: That was our understanding.
4 MR. MILLER: All right.
5 MR. FEIGENBAUM: All right. I thought that 6 important, Bill, to clarify that. Thank you.
7 MR. RUSSELL: Let me cover one other aspect.
8 That is, the role of the line organization and the quality 9 organization as it relates to conduct of activities.
10 I want to illustrate with some dialogue that 11 Jim Taylor and I had with another company as it relates to 12 the role of the line organization, the quality 13 organization. That is the Watts Bar facility. The time 14 frame was the summer of 1994 through the fall o'f 1994, 15 .
We had a number of corrective action programs 16 that the company was implementing which they had put 1
17 through line reviews and quality reviews. During l 18 inspection activity, we found that the conditions that 19 they said had been completed satisfactorily, were not l
20 completed. Something on the order of eight different 21 examples. Then they got into what were the root causes of 22 that.
23 We also found that in fact, the interfacing 24 between the quality organization, line organization was 25 not visible to us. That is, we could not tell what dhe -
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46 1 quality organization was finding and returning back to the 2 line for corrective action as is described in appendix B, 3
as it relates to non-conforming conditions and how they 4 are documented. While that is done internally, there 5 needs to be some visibility.
6 Subsequent to that period of time, the 7 corrective actions that the company had was that basically 8 when the lines said they were done and they forwarded 9 something to the quality organization for review, we 10 started having periodic meetings where the quality 11 organization described how many packages they had 12 received, how many they find satisfactory, how many got 13 sent back, what was done, et cetera.
14 It was very important to get an understanding 15 of the quality organization and how it was functioning.
16 The best way to see how something is functioning is to see 17 the results of what they find and what they do.
18 It's desirable to have the first time through 19 a product be one that is satisfactorily done through the l
20 line organization. Given the history that you are dealing l l
21 with, that may not be as likely as you would like it to 1 22 be, at least in the early stages.
1 23 What we're saying is, we need some evidence as 24 to what they are finding because obviously, if we go in 25 and do an inspection, one of the questions we are gofng to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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47 11 be asking is did the line organization do a review in thig i 2 area. If so, what did they find? Did the quality 3 organization do a review in this area? If so, what did 4 they find?
5 If we find that they both looked and didn't I l
6 find something, and we look and we find omething 1 7 significant, that tells us how effective the oversight is.
8 Again,.I'm looking at results, not process, procedure. W
.e 9
want to focus on the results of what is identified.
10 So I think u la important for you to re-visit 11 and look at, particularls in iight of some of the recent 12 quality assurance findings by outsiders, how effectively 13 that function is being carried out.
14 So this is really for you, Mr. Miller, to 15 focus on those issues, particularly in light of the July 16 1996 conclusion by the root cause team as to how well 17 quality is working.
18 I have reviewed, Mr. Feigenbaum, your ,
19 directions. I believe they were dated August 1, to the 20 staff on your expectations. But given that history of 21 that function, we are going to be looking for some 22 evidence because that evidence that the process is working 23 and working well is what is going to be necessary to reach 24 conclusions about future operations once the immediate 25 problems are identified and resolved. " -
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l
i 48 1 MR. FEIGENBAUM: Understood. '
2 MR. RUSSELL: I'd also point out that the J
3 false starts between the summer of lo94 and the fall of '
i 4 1994 probably contributed to something on the order of a ,
- i years delay at Watts Bar.
- 5 .
6 Okay? Any other questions?
]
i 7 MR. FEIGENBAUM: We'd like to return in 10 or
! 8 20 minutes.
}
j 9 MR. RUSSELL: Let's make it at 2:30, and Steve J
j 10 Reynolds, my technical assistant, will take you to 1F79, 11 which is a conference room, so that you don't have to go 12 through security to get into that conference room. We'll j 13 break until 2:30.
, 14 MR. MCKEE: We'll go off the record now, but i
15 we'll be going back on the record at 2:30. ,
- ' 16 (Whereupon, the foregoing matter went off the i
17 record at 2:11 p.m. and went back on the 18 record at 2:38 p.m.)
19 MR. MCKEE: If everyone can start taking their 20 seats, we'll begin again. ;
1 21 MR. FEIGENBAUM: Mr. Russell, we have just a 22 small number of questions and comments and clarifications.
23 I guess the most significant of which that needs some 24 discussion is on page seven, which is the third sub-bullet 25 down that deals with the representative sample, the " -
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49 1 consistency of the review across the safety significant 2 systems.
3 I just wanted to step back and describe a 4 little bit of what we did when we did our initial 5 discovery review. We looked at the most safety 6 significant systems, of which we have 11, the most safety 7 significant systems that represent about 85 percent of the 8 core melt frequency of Millstone Three.
9 We did detailed vertical slices of those 11 10 systems to find problems in those systems, but also as a 11 diagnostic for all safety significant systems and all 12 systems in'the plant to find weaknesses in our programs 13 and procedures.
14 We looked at approximately 26 attributes in 15 those 11 systems when we did our vertical' slice. As I 16 indicated to you in the July 2 letter, and subsequently we 17 talked about it briefly earlier today, we did find 18 problems in about 16 of those 25 attributes which is 19 causing us to go back and re-evaluate programs and 20 processes on a generic basis for those areas.
21 When we select the systems that are most risk 22 significant for the independent verification team to look 23 at, some of those systems or when the team based on our 24 rationale picks those systems, they may pick some of those 25 syste;ms that had the vertical slice. They may chooss to -
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1 pick some systems, for one reason or another, that do not 2 have the vertical slice. Again, we use this as a 3 diagnostic tool.
4 So we think perhaps it would be beneficial to 5 modify the wording a little bit in this particular bullet 6 that talks about the consistency with other systems, 7 because based on safety significance and whether it was 8 chosen for a vertical slice or not, there may be 9 differences across all the safety significant systems, the 10 way we've reviewed them.
11 bltimatelythough, the 16 peaks and the 12 problems we found will be taken care of across the board 13 in all systems, but not all systems got the vertical slice 14 review in our review.
15 , MR. RUSSELL: The intent is can I use f.he 16 example of 20 risk significant systems, I believe, out ol' 17 some total number of systems, maybe 50 or 60, that the 18 process that ycu use for the 20 would be consistent. ,
19 We recognize that there may be a difference 20 between the process you would use on a risk significant 21 system from one to which is concluded to not be risk 22 significant. That's the whole concept that's embodied l
l 23 within the maintenance rule as to how you treat systems 24 differently.
25 One caution. That is, that the maintenadee -
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- 51 -
! 1 rule risk significant structure and organisation, and -
1 2 things which are'done using PRA are predicated upon the l 3 design having been maintained. So to the extent that if i
4 the design is not adequately maintained, if there's some 4
5 common cause failure, a system which would under random i
l 6 failure kinds of considerations or based upon prior 7 operating experience, be~ considered not risk significant, if there's some common cause failure problem, it would f
8 i 9' turn out that they could be risk significant.
l 10 That is, if you took a as-discovered condition i
11 and you modeled it in a PRA and said this system is not a
12 available, it cou d turn out to be potentially f 13 significant.
}
- 14 What we are talking about is a plan here that 15 would identify what the process is for auditing. So if 16 you have groups that you have used for your activity on-17 systems, that all the systems within a particular group '
l 18 are treated the same way.
19 If you have two different approaches, for
)
20 example, for BOP systems that are transient initiators,
- 21. you have one approach, for standby safety systems you have 22 another, for a system that's in operation continuously 23 that you can monitor its performance, you might have 24 another approach.
25 Whatever you do to group them to ensure t-hat -
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_ . _ . . _ _ _ _ _ . ._ - - - -~ ---- . - -- - - - - ~ ~ - - -
52 1 the design basis is consistent with the FSAR licensing 2 basis, and that the as-built, as-analyzed, is consistent 3 with that design basis. That is what we're interested in.
4 MR. FEIGENBAUM: So the fact that we are 5 taking our findings, our programmatic-issues, our 16 6 attributes that needed fixing across the board, and
- 7 folding those into all risk significant systems across the 8 board, that meets the intent of this word consistent, 9 because the independent team may pick a system that 10 received a vertical slice, and may review a system that 11 didn't get the personalized vertical slice, but got the 12 benefit because the attributes will now be folded into 13 that system and those programs fixed.
14 I just wanted to make sure that we understood 15 that that was acceptable to have a system that had a 16 vertical slice and a system that didn't have a vertical 17 slice, as long as the problems were found and corrected.
18 MR. TAYLOR: I would think if we get an 19 independent vertical look at a system, they'll find issues 20 that you may have missed, and that therefore, if they do, 21 and those problems could reflect elsewhere, that that's 22 what this means too. Do you know what I mean? That your 23 back look -- you start going in depth looking at a design 24 in a system, I would be surprised if they took some of the 4
i 25 11 that you did, I would be surprised if they don't ceme -
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1 up with some issues that just were missed in your revicw.
2 That is not meaning to be critical, but I am 3 speaking from experience of people reviewing.
4 MR. FEIGENBAUM: The vertical slice.
5 MR. TAYLOR: Exactly. So whatever they .
6 indicated with regard to your corrective action, you might 7 have to go back and make adjustments elsewhere. So I 8 think that's the independent aspect. That's the benefit i
9 of somebody that hasn't lived with it, hasn't -- you know, 10 coming in with a fresh look.
11 MR. RUSSELL: Yes. Let me -- I agree with 12 what Jim just described. That's why we're interested in 13 this being representative.
14 Obviously if we go in and we find that the 15 results are positive, that is, there are not new issues 16 identified, et cetera, then the processes that you have 17 implemented on those representative samples can be the 18 evidence that the process was sufficiently effective that 19 there is high degree of confidence that the issues have 20 been identified.
21 On the other hand, we you go in and you 22 sample, and you find that there are problems that were 23 missed, then it raises questions about the process that 24 was implemented. Now it may be that you have for risk 25 significant systems, that you have done a vertical sFice. -
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54 '$ '
1 From that vertical slice on 11 systems, you have 2 identified certain things that you need to go look at on 3 all systems, such that you don't have to repeat a vertical 4 slice on all the rest of the systems.
5 If that's in fact the case, then what we are 6 going to be looking at is did you adequately address those 7 attributes. Then if the issue turns out that when we do 8 our vertical slice we find out that there was an attribute 9 17 or 18 that turned out to be significant such that the 10 design basis wasn't maintained, that raises an issue as to 11 whether there ought to be either additional attributes on 12 the list, and then we know where to expand the scope for 13 potential conditions that need to be addressed.
14 MR. FEIGENBAUM: The bottom line is are we in 15 conformance and do we meet the requirements.
16 MR. RUSSELL: That's exactly it. All we're I 17 interested in is making sure that the process is not 18 skewed such that a few systems get a grade A pedigree .
19 review and others don't. We want to make sure that the 20 process you have implemented, for whatever the process 21 was, and it may change with time. You may learn based 22 upon the experience with the first few and find a more 23 efficient way of doing it.
24 What we're interested in is the consistency of I l
25 the result such that the problem identification is - '
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1 complete.
1 2 MR. FEIGENBAUM: I understand.
l 3 MR. RUSSELL: As it relates to that, we had i
4 some discussion while you were out as it relates to two l
5 items. One, when we would expect to start an independent i
4 6 review from the standpoint of phasing of your corrective 1
- 7 action as it relates to problem identification. l
, 8 I don't want to establish a rigid number, but !
9 we want to habe a sufficient number of systems completed i
4 10 there can be a representative sampling out of those l'
11 systems to make judgements on the process, whether that's a
12 approximately half of the systems completed or it's some
. 13 number of systems, I don't want to specify a percentage, 14 et cetera, because I would like to start the process as j
15 early as we can, as soon as there is a representative 16 number that you have completed.
17 So if, based upon what you have already done, 18 it is simply a matter of organizing the information, doing 19
~
some verification submitting it, that could start 20 relatively soon. Then choose from that set.
21 There are some logistics to go through by way 22 of getting agreement on the firm or organization or 23 individuals to do the work. They are developing their 24 planning, both their audit plan and communication 25 protocols, et cetera. So there is going to be some dime -
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56 i
1 before they are ready to physically start. So I would 2 hope that there could be a number of these that have gone 3 through the line and QA to say these systems with these 4 items at this point in time unresolved are the number of 5 issues that we have to deal with.
6 The second aspect is as it relates to findings 7 of this team, findings and/or recommendations, the 8 protocol that we're talking about with respect to a 9 feedback loop, that is, we expect you to decide whether 10 the findings are correct or not, whether a modification is 11' needed or not, or whether there's some other approach.
I 12 We don't expect you to simply accept their i 13 comments. We expect you, if you agree with the I
)
14 independent team's findings, to indicate you agree. If 15 you disagree, you disagree and what the rationale is.
16 The dialogue that I had earlier was your 17 resolution of disposition of their comments. We want to 18 have a process where the team can comment on this,.whether 19 they agree or not, whether something was missed.
20 That could'either be through the vehicle of a 21 meeting, it could be formal dialogue, but there needs to 22 be a protocol as to how that would be handled. If it's a 23 meeting, we would want to obviously have NRC people there 24 to observe the resolution. If it's written documentation 25 back and forth that's provided at the same time to both -
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57 1 the NRC and yourselves. It's in that context.
2 I do not expect this independent review team 3 to come up with recorc. mended corrective actions. They are 4 going to be making judgements about your recommended 5 corrective actions in phase II. If they find that some 6 are not sufficiently complete, they will provide the 7 rationale. You would either agree with that or disagree 8 with that with a reason. We would want them to be able to 9 coinment on your rationale to try and get closure so that 10 both can agree and it's an open observable process as to 11 how that resolution is handled.
12 MR. FEIGENBAUM: I just wanted to make sure I-13 understood when you said when we were about halfway 14 through, we had a representative sample of systems, you're 15 talking about a representative sample of risk significant 16 systems or half of the risk significant systems?
17 MR. RUSSELL: No. Let me illustrate with 18 numbers. I think you said you have 11 risk significant 19 systems. I don't know what your total number of systems 20 are. !
21 MR. FEIGENBAUM: Actually it's 39 total 22 systems. We did a vertical slice on 11 systems which are 23 the most safety significant.
24 MR. RUSSELL: Eleven out of 39 total. If you 25 have risk significant 11, and something on the order bf 20 -
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58 -
i 1
1 systems, some of which are risk significant, some of which l 2 are not risk significant, then you would have a 3 representative sample.to choose from.
4 So when you are about approximately halfway 5 through the discovery phase with respect to numbers of .
i 6 systems for which discovery phase would be applied, that 7 is phase I, at that point in time, they could choose from 8 approximately 20 systems. Some number would be risk- ,
5 9 significant, some would not be risk significant.
10 Okay? So it's not completion with five, that >
11 is, half of 11. 'But it's something on the order of 18 to 12 20 of which a number would be risk significant.
13 MR. FEIGENBAUM: Mr. Russell, on page eight, 14 we wanted to just make sure that we understood that the 15 second sub-bullet dealing with verification of as-built 16 and as-modified is related to the last bullet, sub-bullet 17 on that page, modifications made-to the system since la initial licensing. The fact that it was separated --
19 MR. RUSSELL: Yes. All of these are since 20 initial licensing.
21 MR. FEIGENBAUM: Okay.
22 MR. RUSSELL: We have on the page eight, or 23 seven at the top of the page, review of selected systems, 24 design and design basis since issuance of the facility 25 operating license. '
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59 1 So the starting point for the activity is not 2 going all the way back in time to initial design review, 3 design documentation, but rather, how it's been maintained 4 since initial licensing.
5 MR. FEIGENBAUM: On the first sub-bullet on 6
page eight, we understand that to be engineering design 7 and configuration control processes.
8 MR. RUSSELL: Yes.
9 MR. FEIGENBAUM: It's the processes you'll be-10 looking at. I 11 Bob, you had one other question?
12 MR. BUSCH: Yes. Again, Mr. Russell, I just 13 want to make sure I understand our process. Believe me, 14 I'm timid about going very far in this because as you 15 know, I'm not a lawyer. I'm an engineer.'
16 But my understanding is and your expectation 17 is that the company, licensee in this case, will now take i 18 these bullets, clearly add a few words simply along the ,
19 lines of those that Mr. Feigenbaum talked about to make 20 sure there's absolutely no misunderstanding about what the 21 process is'and what we're attempting to do. We will 22 provide you tomorrow with our confirmation of our 23 understanding of this language that's in here, essentially 24 to the extent possible maintaining as much fidelity with 25 these words as humanly possible. " -
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i l 1 We plan to turn these into sentences and -
l 2 paragraphs. That's all I am really saying.
4 3 MR. RUSSELL: Yes. Right. 1
) !
i
- 4 MR. MILLER
- Bill, isn't it true that if I 1
- 5 take the second item, for example, on the bullet that i i
I 6 addresses modifications, that that might include - .you l
} 7 mentioned processes, Mr. Feigenbaum. That might include I 8 looking back at calculations,'for example, and analyses to j
9 confirm that if let's say net positive suction had for an 10 emergency core cooling system pump was at issue, you would l
11 get confidence that as you modified that system or that 12 pump, that there wasn't a degradation in margin.
13 So that might take you beyond just looking at i
- 14 the process that you used to modify the plant, but it
! 15 might take you back to calculation and analysis.
j 16 MR. TAYLOR: I agree with that comment.
- 17 MR. FEIGENBAUM
- And I understood that from i
18 Mr. Russell's comments earlier in the day that the 50.59 ,
l 19 process --
] 20 MR. TAYLOR: If you have compromised, you j r
l 21 know, the original design and the only way you are going 22 to know that is through calculation. We have seen'over- i
} 23 loaded 1E buses. They weren't there to begin with, but as j l
24 loads were added, not taking into account starting 25 currents, you know that one. I saw that at a number bf -
l
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) I
7-61 1 plants in the last five or 10 years, actual 1E buses.
2 MR. BUSCH: That would really be contained in 3 the third bullet, the translation of the design and 4 licensing basis requirements. Correct?
5 MR. MILLER: I suppose it could be encompassed 6 within a number of those. The important thing is to --
7 MR. TAYLOR: You shouldn't hesitate to go back 8 and make sure.
9 MR. RUSSELL: No. Of course not.
10 MR. FEIGENBAUM: Well, Mr. Russell and Mr.
11 Taylor, Mr. Miller, and NRC staff, I just want to thank 12 you for this opportunity to meet in a public setting to 13 listen and understand the approach that we're going to 14 take to evaluate and test our own engineering design 15 reviews that have been underway at Millstone since April.
16 We clearly recognize that we have had 17 significant failures in maintaining our design basis.
18 Much needs to be done in this area. We are hard at work 19 at that, at that effort.
20 We hope that such an approach as described 21 today will help determine if our own evaluations have 22 identified all the areas that need to be addressed and 23 fixed on all the significant and risk significant and 24 safety systems in an appropriate way, and give a solid 25 basis for the potential restart of our unit. - -
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62 1 of course we recognise that it may also .
2 identify additional work that needs to be done before we
.3 can restart Millstone.
4 We also recognize that we'll be subject to 5 additional reviews by on-site staff and NRC staff and 6 regional staff, in accordance with manual chapter 0350 and 7 as described by Mr. Miller previously.
. 8 So we look forward to working with your staff 9 in the near future to identify an independent and 10 qualified party to do such an effort, and to perform the 11 reviews and develop the detailed scoping document by which 12 the reviews will be ccnducted.
13 As Mr. Busch said, we will obviously go back 14 and review this again in more detail. It is our 15 expectation that we will be able tomorrow to be able to 16 confirm in writing the understandings as outlined today as 17 how this kind of an independent review would be conducted.
18 So again, we thank you for this opportunity 19 and the ability to clarify these issues, and look forward l 20 to a prompt response from us to you and then you back to 21 us so we can get started on this work.
l 22 MR. RUSSELL: That's really, Ted, the essence 23 of the reason for the relatively short turnaround. It's 1
24 time to get this in place. It's time to start the work. !
1 25 So rather than protracted dialogue back and forth, ws.need -
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1 l
l
63 UE 1 to get the elements in place and provide the Commission, 2 the staff and the public, confidence that in this 3 instance, the work is done and completed based upon end 4 product result testing rather than process, procedures, or 5 commitments to plans. .
6 MR. FEIGENBAUM: We will name a project 7 manager for this effort and inform your staff of who that 8 is so that we can coordinate.
9 MR. MCKEE: Well, I think that cont.udes 1 the 10 portion of the meeting between NRC and the uti'.ty. The 11 record portion.
12 We're going to have, as I mentioned, following 13 this, we're going to have an opportunity for the press to 14 ask questions and then for the public to ask questions.
15 So thank you for this portion.
16 I want to mention just an administrative item.
17 There are some extra handouts available on the press 18 tables for the slides that we used. Also those that may j 19 have come in and didn't, we have a sign-up sheet by the ;
20 exit on my right on the way out, if people can assure that l 1
21 they are listed on that sigh-up sheet.
22 So this portion of the meeting is concluded.
23 We're off the record. j l
24 (Whereupon, at 3:00 p.m. the proceedings were l
25 concluded.) " -
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I
r CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
Name of Proceeding: MEETING WITH NORTHEAST NUCLEAR ENERGY COMPANY Docket Number: N/A Place of Proceeding: ROCKVILLE, MARYLAND were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
M ,
C'ORBETT RINER Official Reporter Neal R. Gross and Co., Inc.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE. NW (202) 234-4433 WASH &4GToN. D.C. 20005 (202) 23W33
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PUBLic MEETING BETWEEN
[ THE NUCLEAR REGULATORY COMMISSION AND
~
NORTHEAST UTILITIES t
REGARDING MILLSTONE UNITS 1, 2 AND 3 AUGUST 12,1996 1:00 PM
j . -- - ----~ ~~~~~~ ~~~~~~ ~~' m ^
BACKGROUND i
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- NRC INSPECTIONS AND LICENSEE INTERNAL AUDITS (SIN
= 1991) HAVE IDENTIFIED:
- CONFIGURATION (DES'lGN) CONTROL FAILURES
- FAILURES TO IMPLEMENT CORRECTIVE ACTION FOR KNOWN PROBLEMS I
- FAILURE TO IMPLEMENT QUALITY ASSURANCE REQUIREMENTS FAILURE TO COMPLY WITH TERMS AND CONDITIONS OF 1 LICENSE I
- SCOPE AND MAGNITUDE OF THE PROBLEM IS SiGNIFICANT
- MILLSTONE 3 1187' NON-CONFORMING lTEMS 597* PROPOSED FOR CORRECTION PRIOR TO RESTART
- DESIGN CHANGES ARE REQUIRED FOR MANY TO RESTORE OPERABILITY '
As or jut.Y 2,1996 1 -
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{ NRC INSPECTION _ OVERSIGHT
) *
- EXPANDED INSPECTION AND SENIOR MGMT OVERSIGHT k
j
- MANUAL CHAPTER 0350 PROCESS .
l - SYSTEMATIC, STRUCTURED PROCESS RESTART ACTION PLAN j -
RESTART PANEL
} lNSPECTIONS PRIOR TO RESTART i
- CONTINUING RESIDENT / REGIONAL /HQ OVERSIGHT l
- INDEPENDENT CORRECTIVE ACTION VERIFICATION INSPECTION
- OPERATIONAL READINESS INSPECTION TEAM
- FOCUS ON HUMAN PERFORMANCE j PUBLIC INVOLVEMENT
] - lNSPECTION "ExlT" MEETINGS i
- PERIODIC PUBLIC MEETINGS ON STATUS
- MEETINGS WITH LICENSEE (E.G., RESTART PLANS) i
- PUBLIC DOCUMENT ROOMS 4
- COMMISSION APPROVAL OF RESTART LAST STEP l
- IF RESTART IS APPROVED, PLANT WOULD REMAIN ON l
! WATCH LIST i
i
.1 l' 2 -
WHAT IS AN INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM (ICAVP)?
BASED UPON NRC EXPERIENCE WITH INDEPENDENT DESIGN l
VERIFICATION PROGRAM (IDVP) (MC 2535) 3 VERIFICATION OF IMPLEMENTATION OF LICENSING
- REQUIREMENTS 4
j i
- COMPARISON OF " DESIGN BASIS" TO "AS BUILT" AND i "AS ANALYZED" l
l KEY ELEMENTS: .
2 CONDUCTED BY A THIRD PARTY l
LICENSEE CONTRACTS FOR THE THIRD PARTY REVIEW.
l TEAM IS COMPOSED OF HIGHLY QUALIFIED AND j
- EXPERIEN'CED ENGINEERING STAFF j -
TEAM SELECTION IS APPROVED BY NRC TEAM REPORTS FINDINGS CONCURRENTLY TO NU AND '
NRC l
NRC OVERSEES THE ACTIVITIES OF THE THIRD PARTY ,
REVIEW 3 -
j
' NRC EXPECTATIONS FOR ICAVP HAVE A WELL-DEFINED PLAN FOR IN-DEPTH EVALUATION l OF SELECTED SYSTEMS RISK / SAFETY-BASED CRITERIA FOR SELECTION OF SYSTEMS l 1
AUDIT PLAN TO CONFIRM LICENSEE REVIEWS ON SELECTED !
SYSTEM IS REPRESENTATIVE
! PROTOCOL FOR CONCURRENT REPORTING OF IN-PROCESS l AND FINAL 7ESULTS TO NRC AND LICENSEE
- I j lNDEPENDENT i
j - NO CURRENT OR PREVIOUS EMPLOYEES OR i CONTRACTORS I
i
- NO FINANCIAL INTEREST
- - KEY HOLD POINTS, AS NECESSARY i
! - PROCEDURES FOR REPORTING FINDINGS i
l - PHASING AND TIMING OF WORK 4
l 4
NRC OVERSIGHT i
- NRC HQ TEAM (SES + INSPECTORS) TO OVERSEE THE i
ICAVP ,
2 b,
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LICENSEE PHASED CORRECTIVE ACTION NECESSARY i
d PHASE l - PROBLEM lDENTIFICATION 1
- PROBLEM lDENTIFICATION AND OPERABILITY I ASSESSMENT ON A SYSTEM-BY-SYSTEM BASIS, i
, FOCUSING ON THE MOST RISK SIGNIFICANT SYSTEMS i
- CONSISTENT PROCESS i
4
- LINE MANAGEMENT / QUALITY ASSURANCE OVERSIGHT [
COMPLETED AND RESULTS REPORTED i
- EVALUATION AND CORRECTIVE ACTION l lDENTIFICATION NOT REQUIRED t i !
s l
i .
)
I 4
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LICENSEE PHASED CORRECTIVE ACTION NECESSARY (CONT'D) j PHASE ll - RESOLUTION .
t
- NECESSARY CORRECTIVE ACTIONS lDENTIFIED, REVIEWED f
AND IMPLEMENTED l
- CORRECTIVE ACTIONS DEFERRED UNTIL AFTER RESTART j JUSTIFIED BY NU, REVIEWED AND APPROVED BY NRC NRC OVERSIGHT
}
- NRC OVERSIGHT WILL BE CONDUCTED USING MC 0350
- - REGIONAL ADMINISTRATOR, REGION I COORDINATES
- COORDINATION WITH EDO AND D:NRR i
- RESULTS PRESENTED TO COMMISSION
{' - RESPONSIBLE SES MANAGERS:
i W. LANNING, REGION I '
i P. MCKEE, NRR l
l 1
6 " -
l
ACTIONS TO BE ADDRESSED BY ORDER
- IMPLEMENT AN INDEPENDENT CORRECTIVE ACTION l VERIFICATION PROGRAM, INCLUDING:
CONDUCT OF AN IN DEPTH REVIEW OF SELECTED i
SYSTEMS' DESIGN AND DESIGN BASES SINCE ISSUANCE OF THE FACILITIES' OPERATING LICENSES i
- RISK / SAFETY BASED CRITERIA FOR SELECTION OF j SYSTEMS FOR REVIEW l - A DESCRIPTION OF THE AUDIT PLAN TO ENSURE THAT j
LICENSEE PROBLEM lDENTIFICATION AND CORRECTIVE
' ACTION ON THE SELECTED SYSTEM ARE REPRESENTATIVE
- AND CONSISTENT WITH OTHER SYSTEMS 4
i j
' - PROCEDURES AND SCHEDULES FOR PARALLEL REPORTING OF FINDINGS TO THE NRC AND NU i
PROCEDURES FOR COMMENTING ON THE LICENSEE'S l PROPOSED RESOLUTION OF THE TEAM'S FINDINGS AND
{ RECOMMENDATIONS I
l
{ 7 -
i
)
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ACTIONS TO BE ADDRESSED BY ORDER (CONT'D)
SCOPE OF THE ICAVP EFFORT INCLUDES:
ENGINEERING DESIGN AND CONFIGURATION CONTROL VERIFICATION OF AS-BUILT AND AS-MODIFIED l CONDITIONS
' TRANSLATION OF THE DESIGN AND LICENSING BASES REQUIREMENTS INTO OPERATING PROCEDURES, j MAINTENANCE AND TESTING 4
VERIFICATION OF SYSTEM PERFORMANCE THROUGH REVIEW OF TEST RECORDS AND OBSERVATION OF l SELECTED TESTING
} PROPOSED AND IMPLEMENTED CORRECTIVE ACTIONS FOR LICEE43EE-lDENTIFIED DESIGN DEFICIENCIES i
MODIFICATIONS MADE TO THE SYSTEM SINCE INITIAL
! LICENSING 1
k i
- " ~
+.
NRC OVERSIGHT OF ICAVP
- APPROVE TEAM QUALIFICATIONS AND lNDEPENDENCE OF ICAV
- APPROVE SYSTEMS SELECTED FOR ICAVP REVIEW
- NRC HQ TEAM WILL CONDUCT PARALLEL INSPECTION; AUDIT CALCULATIONS; REVIEW CORRECTIVE ACTIONS AND IMPLEMENTATION FOR SELECTED SYSTEMS
- CONDITIONS / ACTIONS REQUIRED FOR RESTART WILL BE DETERMINED BY THE COMMISSION e
1 9 -
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08/13/1996 14:32 2038482020 ORBIT DC PAGE 01 l .
gn4 i
Dt. Shirley Ann Jackson Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555 0001 l
I Donald W. Del Core, Sr.
4 Dnscoll Drive Uncesvdle, CT. 06382-1808 4
i Dear Dr. Jackson-Two important issues have come to my attention and I believe they need your immediate suention. De first deals with pubhc meetings twitween the NRC staff and NU being held at Ro&ville,
- MD. The second deals with Mr. William Rusacil of your staff allowmg NU to pick the members of an 1 '--;- - R Corrective Actaan Venficanon Program suggested by you during your recent v6 sit to our area.
l I lme u:ry deep conacras about the wracity of any program whereby the licensee tasked with
. venfying corrective action gets to select the " INDEPENDENT " party to accomplish the ver*=haal i
Clearly from information I have been supplied with, the selection process rules established by Mr. Rassell were not clearty denned. The process seemed to be a bit rushed to say the least. The egnestiaa of use of a i particular contractors for use on Mulamae Unit # 3, seemed to mn along the lines of whether or not the
- particular contractor was used for Unrt # 3 before. ne fact that they may have been used by NU before in any capacity seems to be a very important issue to the le ' ; *r e of any verincution. While I welcome
- your soggestion of an i=l -- - '--= verihiaa the veracity of the program is already in question.
Additionally, what possible good is %-- ;M--i by having a pubhc meeting between NU and
- the NRC staff on an issue that is so important to the restart process, in Rackville, MD. Why would anyone hie any mestag regarding public heahh and safety away from the arcs involvail Again if what the NRC and NU are trying to accomplish is reducing public trust, they are doing a goodjob of it.
I believe you and your staff may have missed the point of our public meeting last week. These tuu ismes seem to point out a comunued anogance on the part of your staff, and NU, with regard to our pubhc j involvement.
Dr. Jackson you seemed very smccre about your ianaatiaa< last week , please don't erode the early
- public trust you have gained, by alloning } cur staff to continue on the very path that got us to where we i are today. Thank yma very much in advance for your attention in this matter of deep concern to me.
- Sincerely, i
\
l Donald . Del Core, r.
.' 1 860 4 48-8124 1-860448 2020 Fax 1
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- Millstone will get safety review !
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MlHstore he.s corrected its prob not be expected to review aH plant .lemas w31 do a fair and impartial i
' ' from Ri " . ..e restart of a problem- designs because they are so 'etan-plex and voluminous." It is ulti- job. '
Northeast Utiltties wants to get
{
m - I_ t.very different," said mately up to the operator of a nu- its newest and largest plant, Mill- *
' Russell."Ifaunique in this tase." clear plant to make sure it is run sione a. hack in operat6on first. g At -the tneeting, representatives properly. NU's failure to do so was With hundreds of procedural and tn of NU agreed to support the use or NRC a
- breach I y placedofinthe theconDdence" the design problems to be corrected, company, said !
kn independent review team. Re. Taylor. company officials declined to t?
i start plans also will have to te re. The representatives of Nti ap- speculate as to when the plant may ?"i viewed by the NRC. rtreive approval to restart. It could The NRC has been criticized for peared contrite at the meeting,
. tiot cracking down sooner on Mill. asking for only a couple of techni. be a year or m
. stone.In January the agency placed cal clarifications and admitting NRC Chairwoman units land 2 go Shirley Anatack on line '
l the three Millstone nuclear reac- their mistakes. Robert Busch, pres . Jackson first announced the plans ident of the Energy Resources a tors on its list of problem plants. Group, said the company w91 for a third-party inspection team l I
I
.But the action carne only after sev. subniit 'a ' written enm=k==* during a visit to Waterford last '
' eral ymrs of r"weII<focumented" ' '
M,s . the Ct M
week.Jacksort said the agency was 1mhing the smusual step because of i
.I 1$rsely regu.
'espTrii ^ 't%gdgy piew teenfcon ,
~ i,. 3 'a%ck of pubilb cohinence both in
- Jatory tiIa'fiire - involving both The corisultants that A " . Northeast Utilities and the regula-the review will be selected by widespmnd failures to follow pro. Northeast Utilities, but must be tory agency ite, elf.
- cedural guidelines and a fausre to Russell noted th
- -t NU has pro.
' document design changes made to approved by the working NIfC' Nuclear for, or duced several plans over the years
.the plants over the. . years. This consultants who are, h'e'M111 stone intended to impmve t perfor-
.tllreakdown in regalatory cornplf- ham iMfidCt z
. anoe,,rtisultep.5 a reduced margin plants in' Lhe pad, Thiswill time,eqt be eligi-he said, raance,non the agency u of safety at tne MIDstone reactors, ble. The state wlR be )nvited to ap-executive point an observer to serve on the will "Tocus on end results, com-3 m *
- ealdf Jarnes M. Tay ,
f pleted. product"A*inafagement diremor for nuclear rations at review team.said be was confident plans, reorganizations and prom- l Russell l 8
' the NRC. Ises.
- Taylor said NRC inspectors can-
- M* > eW me may those selected to review whether. ~ . . .. _."..-
ee e * ' . * * * ' %_
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EDO Principal Correspondence Control '
l
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q FROMt DUE: 08/29/96 EDO CONTROL: GT96626 DOC DT: 08/13/96
' Donald W.-' Del Core, Sr. FINAL REPLY:
Uncanville, CT '
TO L
. Chairman Jackson FOR SIGNATURE OF : ** PRI **
CRC NO: 96-0886 Chairman Jackson ROUTING:
CONCERNS RE PUBLIC MEETINGS WITH NORTHEAST Taylor
' UTILITIES HELD IN ROCKVILLE & SELECTION OF Milhoan.
THE MEMBERS OF AN INDEPENDENT CORRECTIVE ACTION Thompson VERIFICATION' PROGRAM Blaha HMiller,.RI -
yr, OGC DATE: 08/16/96 ,
ASSIGNED TO: CONTACT:
NRR Russell SPECIAL INSTRUCTIONS OR REMM:'
NRR RECEIVED: AUGUST 16, 1996 NRR ACTION: DRPE:VARGA NRR ROUTING: RUSSELL _
l I
MIRAGLIA THADANI ACTION ZIMMERMAN DUE TO NRR DIRECTOR'S OFFICE ,.
E'"n BY w %3b - -
l 1
l l
i
f . F EDO Principal Correspondence Control l
jFROM DUE: 08/29/96 EDO CONTROL: GT96626 DOC DT: 08/13/96 iDonald W. Del Core, Sr. FINAL REPLY:
iUncanv111e, CT -
lTO 1 i
Chairman Jackson
}FOR SIGNATURE OF : ** PRI **
! CRC NO: 96-0886 i
Chairman Jackson
'.DESC:
ROUTING:
CONCERNS RE PUBLIC MEETINGS WITH NORTHEAST Taylor
]
" UTILITIES HELD IN ROCKVILLE & SELECTION OF Milhoan THE MEMBERS OF AN INDEPENDENT CORRECTIVE ACTION Thompson VERIFICATION PROGRAM Blaha l
HMiller, RI Cyr, OGC iDATE: 08/16/96
{ ASSIGNED TO: CONTACT:
NRR Russell i C lSPECIAL INSTRUCTIONS OR REMAR M i
NRR RECEIVED: AUGUST 16, 1996 NRR ACTION: DRPE:VARGA NRR ROUTING: RUSSELL
- MIRAGLIA d
THADANI AC1~10N ZIMMERMAN GRIMES B0HRER DUE TO NRR DIRECTOR'S OFFIC i
l 1
BY _hi o n1Q4b i 1
/
4 I
- - - . - ~ _ . _ _ .. . - . ..-. - . . . - - .. ._ . _ - . . _ . . . . . . . . . .
t
't OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET 4
PAPER NUMBER: CRC-96-0886 LOGGING DATE: Aug 16 96 ACTION OFFICE: EDO 4
AUTHOR: DONALD DEL CORES AFFILIATION: CONNECTICUT ADDRESSEE: CHAIRMAN JACKSON i
! LETTER DATE: Aug 13 96 FILE CODE: IDR-5 MILLSTONE 1
SUBJECT:
CONCERNS PUBLIC MEETINGS WITH NORTHEAST UTILITIES HELD IN ROCKVILLE AND SELECTION OF INDEPENDENT
, CORRECTIVE ACTION VERIFICATION PROGRAM MEMBERS ACTION: Signature of Chairman I 1 I i DISTRIBUTION: CHAIRMAN, COMRS, RF l I
! SPECIAL HANDLING: SECY TO ACK !
, CONSTITUENT:
NOTES: OCM #4874 DATE DUE: Aug 30 96 SIGNATURE: . DATE SIGNED:
AFFILIATION: ,
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