ML20129E696
| ML20129E696 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 07/30/1996 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20129E638 | List: |
| References | |
| NUDOCS 9610280141 | |
| Download: ML20129E696 (84) | |
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1 k 1 UNITED STATES OF AMERICA 1 d.
2 NUCLEAR REGULATORY COMMISSION l
3 +++++
4 PUBLIC MEETING WITH MAINE YANKEE TO DISCUSS 1 5 ISSUES RELATED TO RELAP5YA 6 +++++ j l
7 TUESDAY, 8 JULY 30, 1996 9 +++++
10 ROCKVILLE, MARYLAND 11 +++++
12 The Public Meeting was held in Room 12B-11, 13 One White Flint, Rockville, Maryland at 10:00 a.m.
14 I
l 15 16 PRESENT:
17 ED TROTTIER 18 W.T. RUSSELL i
19 JOHN ZWOLINSKI 20 ROBERT C. JONES l f 21 JACK E. ROSENTHAL 22 JOHN KOPECK 23 JOSEPH TAPIA 24
- 25 96102E0141 961007 NEAL R. GROSS PDR ADOCK 05000309 COURT REPORTERS AND TRANSCRIBERS T PDR 1323 RHODE ISLAND AVE., N.W.
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2 1 UTILITY: l l
.C 2 C.D. FRIZZLE 3 G.D. WHITTIER 4 MARY ANN LYNCH 5
6 ALSO PRESENT:
7 VICTOR H. RANSOM 3 ULDIS VANAGS 9 DAVID STELLFOX l l
3 10 JAMIE NORINS 11 TROYE JENKINS 12 PAMELA NEWMAN 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 ,
1 P-R-O-C-E-E-D-I-N-G-S !
t 2 (10:36 a.m.)
3 MR. TROTTIER: The utility asked for this !
4 meeting -- requested this meeting today to discuss i 5 RELAP5YA issues. We have scheduled it from now until 6 noon. The meeting is being transcribed, as you see. The l
7 transcription will be made publicly available at the l
8 earliest possible opportunity. That should be within 9 about seven working days.
10 If anybody has any quick questions, ask them, !
11 please, now. Otherwise, I'm going to go ahead and -- -
t 12 MR. RUSSELL: One comment as it relates to the ;
13 ground rules of the meeting. That is, there are still l
14 matters which are under formal investigation, and while !
15 it's appropriate to look at lessons learned as it relates 16 to corrective action, vis-a-vis future activity, there l
17 will be no comment on issues that relate to matters that f 18 are currently under investigation.
L 19 MR. FRIZZLE: That's understandable. !
20 MR. RUSSELL: While we're discussing issues, 21 the current review that's under way is not a RELAP5YA 22 review. It's the Siemens review, etc. But there may be 23 implications from the standpoint of internal procedures or i
! 24 processing. In the discussion I had with you on the l 25 phone, that was the focus for today's meeting.
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i l l 4 l
\* \
l '
l 1 MR. FRIZZLE: That's absolutely correct.
- l. l l 2 MR. RUSSELL: Okay. I i
3 MR. TROTTIER: Okay, and that does it for the 4 introduction.
1 5 MR. ZWOLINSKI: Ed, very quickly, can we get 6 around the room and everyone introduce themselves? i l
7 MR. FRIZZLE: I'm Charlie Frizzle, President l 8 a'nd Chief Executive Officer at Maine Yankee Atomic Power 9 Company.
10 MR. WHITTIER: I'm Doug Whittier, Vice 11 President of Licensing and Engineering, Maine Yankee.
12 MR. RUSSELL: Bill Russell, Director of NRR.
13 MR. ZWOLINSKI: John Zwolinski, Deputy 14 Director, Division of Reactor Projects.
15 MR. JONES: Bob Jones, Acting Deputy Director, 16 Division of System Safety Analysis.
17 MR. ROSENTHAL: Jack Rosenthal, AEOD.
18 MR. FRIZZLE: Okay, as we indicated, the 19 purpose of this meeting is to discuss Maine Yankee lessons 20 learned and improvement initiatives related to the so l
21 called RELAP5YA issue. We are not here to discuss l l
22 RELAP5YA. Anyone that is here to learn something about '
23 RELAP5YA at least from a technical standpoint isn't going l l
24 to learn anything about it from me this morning.
25 We're here to talk about lessons that we have l NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1 1323 RHoDE ISLAND AVE N.W. )
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l
5 1 learned as a result of our inspections and investigations 2 regarding RELAP5YA, particularly management lessons, and 3 what we intend to do in the future to avoid this same kind 4 of circumstance again.
5 By way of agenda, we're going to talk very l
6 briefly about the lessons learned, at least the major 7 categories within which we have learned lessons. We want 8 tb spend most of the morning talking about the initiatives 9 that we will put in place to address these lessons 10 learned. And the focus for those initiatives will be Doug 11 Whittier, the Vice President of Licensing and Engineering 12 for Maine Yankee.
13 And I'll be back up again at the end to 14 provide some very brief remarks and conclusions. Maine 15 Yankee has conducted several assessments related to the 16 programmatic and management aspects of the whole RELAP5YA 17 incident. We initially -- immediately upon receipt of the 18 allegation letter put together a response team to 19 investigate the circumstances.
20 That response team's work was independently 21 reviewed by an independent review team -- people within
'22 our -- again within our house, but people that had no 23 vested interest whatever in RELAP5YA. And finally, we put 24 together a RELAP5YA self assessment report to gather up 25 our lessons learned and make recommendations for what we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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6 1 intended to do in the future.
2 We learned an awful lot from these j 3 investigations. There's an awful lot of things that we '
l 4 flat did wrong, could have managed better, should have i 5 managed better. And it's the intent of these lessons 6 learned and our initiatives as we go down the road to make ;
i 7 darn sure we do things better in the future in this area. I l
8 In contrast to these other investigations, the 9 almost infamous now Morgan, Lewis & Bockius r' port, I want 10 to emphasize, focused on the very narrow issue of criminal 11 wrongdoing. That's all that report was intended to 12 address. That's all it did address. And it has no 13 bearing essentially on what we put together to respond to I i
14 the RELAP5YA issue.
15 That was intended purely to focus on the 16 criminal wrongdoing aspects that were alleged in the 17 allegation letter, and that's all.
18 As I indicated, we've identified a number of 19 lessons learned based on these various assessments. The l
20 lessons learned fall into four general areas -- the 21 interface between Maine Yankee Atomic Power Company and 22 Yankee Atomic Electric Company. We recognize that 23 throughout the whole development of that RELAP5YA 24 incident, there were problems at the interface between our 25 two companies.
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7' 1 You will hear this morning later on from --
2 well, later on from myself, and then following up on that 3 will be Doug Whittier -- how we intend to improve that 4 interface to avoid these problems down the road.
5 Communications with the Nuclear Regulatory 6 Commission were not nearly as tightly controlled as they i
7 should have been throughout this process, and we have some l
8 s'ignificant improvements in place in that regard. Control l 9 of our licensing basis is an area that we need to address.
10 And finally, management issues.
11 As I indicated, Doug Whittier will go into the 12 areas of improvement that address these four general 13 categories. Before I turn it over to Doug, however, I 14 want to introduce one -- excuse me.
15 MR. RUSSELL: Could you -- on the 16 communication with NRC issue, there are formal 17 requirements for reporting and formal vehicles for written 18 notifications, interactions. There are also what I will 19 characterize are informal communications that are needed -
20 - pick up the telephone, talk about the status of review 21 and what's going on. The scope of what you're talking 22 about addresses both?
23 MR. FRIZZLE: Both, yes. We've learned that 24 we need to tighten up our formal communications, number 25 one. Also, we've learned that -- with respect to informal NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 f
] 1 communications, especially when they result in changes to i 2 commitments, we need to document those informal !
3 communications so that both sides agree as to exactly what 4 the result of that communication was.
i i 5 As I indicated, before I turn this over to ;
6 Doug, I want to address one relatively significant change j l
- j. 7 that has gone into effect, as a matter of fact, in just
't
- 8 the last couple of days. And it has to do with the manner 4
g l 9 in which Maine Yankee is organized, structured, especially I
- 10 in terms of its relationship to Yankee Nuclear Services 11 Division, or Yankee Atomic Electric Company.
l 12 This is the organizational chart as it existed i
13 up until a few days ago. You'll notice it shows a direct I 14 officer level link between myself and Andy Kadak at Yankee i
15 Atomic Electric Company. Just a little bit of history l i
? I i 16 here so that people understand how this organizational i i
17 chart evolved. Prior to 1980, Yankee Atomic Electric 18 Company operated Maine Yankee. l i.
J 19 Maine Yankee has always held the license. l l 20 Maine Yankee has always been the licensee. But Yankee l 21 Atomic Electric Company actually operated the plant up 22 until about 1980. At that point in time, what we now call 23 our Vice President of Operations was called Operations 24 Manager, and that individual physically resided in.
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9 1 employee.
2 They actually operated the plant. Around 3 1980, the owners decided that we had to do one of two 4 things. Either transfer the licensee to Yankee Atomic 5 since they were running the plant, or take over 6 responsibility for our own operations. And we did the 7 latter. We took over responsibility for our own 8 operations. I was the first manager of operations who was 9 not a Yankee Atomic Electric Company employee.
10 I was an employee of Maine Yankee Atomic Power 11 Company. Later we evol e.d into a vice president of 12 operations situation similar to what we have shown on this 13 chart. At that point in time, in 1980 when we made the 14 change with respect to who was responsible for operating 15 the plant, in discussions with the regulator at the time, 16 we sensed a fairly significant level of nervousness with 17 respect to Maine Yankee taking over responsibility for its 18 own operations.
19 Yankee Atomic Electric Company had operated 20 the Rowe Plant for 20 years very successfully. Very 21 respected operator. And there was concern that we were 22 " divorcing" ourselves from this very strong operator with 23 a long and successful track record. There were concerns 24 that we were separating too far from Yankee. So the 25 decision was made to leave Yankee Atomic Electric Company NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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10 f..
/
1 in a corporate position.
~
2 The senior officer at Yankee Atomic Electric 3 Company, their President, was our Vice President, Nuclear 4 Services. And it has remained that way until just last 5 week. The problem with this is that it creates confusion 6 both for ourselves within the licensing and engineering 7 branch, and within Yankee. Who is ultimately responsible 8 fbr the technical work that's being done by Yankee --
9 being done on our behalf?
10 Ultimately we're responsible. There's just no 11 doubt about that or should be no doubt about that. But 12 this dual reporting line creates confusion as to where the 13 responsibility lies. That confusion shouldn't exist.
14 MR. RUSSELL: Charlie, that's not unique to 15 Maine Yankee. There are a number of facilities that have 16 contract relationships with other firms to provide 17 services. There have been cases where we've had 18 contractor employees working within the organization under 19 contract, and then it generally is a function of the terms 20 and conditions of the contract --
21 MR. FRIZZLE: Right.
22 MR. RUSSELL: -- that describe the reporting 23 relationships, the responsibilities. So the issue is more 24 one of how it's implemented and executed, and I recognize 25 that it certainly clears up the lines of communications to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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11 1 have them all report directly to the same group that's 2 cutting the paychecks. But it's also the case that we 3 have several others that have done this successfully, and 4 there have been performance in the past where it's been 5 done successfully.
6 So when we look at the technical 7 qualifications to operate, which you were talking about 8 bsck in the 1980 time frame, there could be concerns both 9 within the context of operating experience and also in the 10 context of maintaining access to design information.
11 MR. FRIZZLE: Right.
12 MR. RUSSELL: And as you're aware, we imposed 13 requirements following the Salem ATWS event in 1982-83 14 time frame to require, in fact, close coupling between the 15 principal vendors who were involved in supplying 16 equipment, supply services such that that information was 17 maintained current as a part of the access to technical l
18 information related to operations.
19 MR. FRIZZLE :: Right.
20 MR. RUSSELL: And there are -- all I'm 21 commenting on is that there are a number of contract 22 relationships. There are even cases where -- from other 23 organizations such as INPO come in and operate for up to 24 two year period of time where they're still an employee of 25 INPO but they're functioning in that position. It just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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12 I has to be clear that the duties'and responsibility flow to
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2 the organization, not necessarily the doubl~e-hatted 3 situation.
4 So, while Andy Kadak was President of Yankee 5 Atomic, he was also Vice President of Nuclear Services in 6 your organization -- double-hatted.
7 MR. FRIZZLE: That's right, that's right.
8 O*ver the years, since 1980, the real working relationship 9 between Yankee and Maine Yankee has evolved to this level 10 here -- the project manager who works very closely with 11 Doug Whittier. That's how the relationship has evolved.
12 The reorganization that we just implemented last week 13 simply reflects the way things work today.
14 We no longer have a separate officer, Vice 15 President, Nuclear Services. Doug Whittier is the Vice 16 President, Licensing and Engineering; and he is 17 responsible for all of the engineering and technical work 18 that's done on Maine Yankee's behalf, including that which 19 is done by YNSD. We're not taking any work away from 20 YNSD. We'll have just as much work done there as we 21 always have in the past.
22 But it's very clear how the responsibility 23 lies at this point in time, and that's the way we want it.
24 MR. RUSSELL: This is different than 25 contracting engineering services to an architect engineer.
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13 1 These are actually considered your employees?
2 MR. FRIZZLE: Yes and no. There's a -- from a j i
3 business standpoint, Yankee is not a contractor because l 1
1 4 we enjoy a non-profit relationship with them. We are a l 5 sponsor of Yankee. So they -- in the business world, they l
6 can't be called a contractor. We are a sponsor of that
)
i 1
7 company. The ownership of Yankee is the ownership of '
8 Maine Yankee -- same owners. l l
9 Different proportions, but roughly the same )
l 4
10 owners. We enjoy a sponsor relationship for that company.
l s
11 But the way the work is managed on a day to day basis, and 12 Doug is going to get more deeply into this, is going to 13 look an awfully lot more like the relationship with the a 14 contractor. l I
15 MR. RUSSELL: So this is similar to some of l
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16 the things that are going on now in support services for 17 plants where you have several licensees get together -- l l
18 MR. FRIZZLE: Buy a service company, yeah, l
19 MR. RUSSELL: -- entity, or buy an entity to 20 provide service, whether it be in spare parts procurement 21 or security services, etc.?
22 MR. FRIZZLE: This will look very much like 23 that. But --
4 24 MR. RUSSELL: And -- share based upon your 25 percentage ownership in the company, and so in that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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i 14 1 context it's not a contractor; it's a pooling resources --
2 MR. FRIZZLE: Right.
3 MR. RUSSELL: How you manage the work is done 4 through a projects organization.
5 MR. FRIZZLE: Right, right. And that's very 6 much the way this is going to function. But the reason we 7 have gone to this depiction on our organization chart is 8 that it makes the lines of responsibility very clear and l 9 very direct.
10 MR. ZWOLINSKI: Are you going to get into the 11 details, Doug?
12 MR. FRIZZLE: Yes, Doug is going to get into ,
l 13 more details as to how we manage at the functional 14 interface. And with that lead in, I'll turn it over to 15 Doug Whittier and we'll get into that. By the way, I have 16 copies of these slides. Not enough, but some.
17 MR. TROTTIER: Those will be attached -- for l
18 everyone interested, those will be attached to the meeting 19 summary and the transcript. So you'll get to see these 20 when we publish it.
21 MR. RUSSELL: I can see one area that could be 22 a complication from a formal reporting relationship. That 23 is, if you're contracting for services and it's safety 24 related services in which in here design and review is a 25 safety related service, that activity falls within the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 15 1 scope of 10 CFR Part 21 and imposes requirements on the 2 contractor. ;
3 And the officer is -- the responsible officer i 4 of the contractor is to do necessary evaluations and )
\
5 determine reportable -- but at the same time, it provides f r
6 an option for them to inform the licensee who procured the 1
7 services of a problem. And if they're satisfied that that :
8 r'e porting is completed, it relieves them of any obligation i 9 to report directly to the NRC.
10 But it does mean that you have to be quite 11 careful in how you specify evaluation and how issues 12 related to defects and failures to comply, as those words 13 of art are used, in 10 CFR 21 are in fact implemented 14 where you have not a contractual. relationship, but a 15 shared ownership relationship.
16 MR. FRIZZLE: We recognize that.
17 MR. WHITTIER: Thanks, Charlie. As Charlie 18 indicated, I'm going to be talking about primarily various 19 improvement going forward. These -- I'll be talking about 20 steps that we have taken already and steps that we're 21 still trying to take in this area. I'd like to talk more 22 first about the Maine Yankee / Yankee interface.
23 As Charlie alluded to, we are looking at 24 managing the interface along functional lines. And I have 25 a plan under development for improving the management of NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS l
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16 1 the interface. And that plan's in draft, and I expect to 2 have it issued internally within the next couple of weeks.
3 And what I'm going to be talking about is some of the high 4 points in that plan.
5 And the first is to move or complete the 6 transition to management of the interface along functional 7 lines. And let me talk a little bit more about what I 8 m'ean there. I'm going to show you another organizational 9 chart. This shows what Charlie depicted, expect a little 10 bit more detail -- basically a level below, Pete Anderson.
11 And it shows down into my direct reports. And this is 12 labeled functional relationship because this is in fact 13 the way we found ourselves working for the most part even 14 before the most recent reorganization.
15 And what it shows is most of the functional 16 areas of support that Yankee provides us technical 17 services in. And what I've been doing over the last 18 couple of years is aligning my staff -- and these are 19 Maine Yankee employees now -- in a similar area. And 20 moving toward a situation where I can point to a Maine 21 Yankee manager or section head who would have in essence 22 line responsibility for these services from Yankee and 23 responsibility for managing the interface.
24 And this alignment as I've shown here -- so I 25 can point to the manager of corporate engineering, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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17 1 clearly stated, that individual -- you're responsible for 2 basically management oversight of Yankee engineering 3 services. And that's pretty well happening right now and 4 just needs a 1ittle bit more refinement.
5 Down here in this licensing and engineering 6 support department, I have several sections that interface 7 with Yankee -- point to the nuclear engineering group.
8 Ahd nuclear engineering group lines up with the nuclear 9 engineering group at Yankee. And I've gone to Dave 10 Boyton, who is the section head of that group, and said 11 you're responsible. You're responsible for complete 12 oversight of Yankee Nuclear Engineering Services.
13 Now in the past, Dave had provided oversight 14 of some of the nuclear engineering services, primarily in 15 the core design and safety analysis as associated with 16 design of a specific core. But he did not provide 17 oversight of safety analysis activities in general and did 18 not provide oversight of the -- for example, the treat 19 analysis that's done in support of the EOP's.
20 The treat work basically went directly from 21 the operations side of the house directly over into 22 nuclear engineering. That's the way that interface 23 worked. And personally, I'm not comfortable with that. I 24 would prefer -- I think it's going to work better if I can 25 point to a Maine Yankee nuclear engineering person to say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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.._-._.m_ m._ . _ . _ _ _ . . . . - - . . , _ . _ _ _ _ . _ _ _ _ _ . . _ _ _ _ . _ _ _ _ . _ . _ . _ . . .
'18 l
! 1 you're responsible'for managing that work that Yankee's l
- i. .
- 2 doing and also making sure that you interface back with i
- . i
, 3 the operating side of the house. )
I :
l 4 So in essence, we're setting ourselves up in j i
1 l 5 engineering -- Maine Yankee engineering to be, if you l
6 will, a conduit between the Yankee services and the folks t i ,
! 7 that operate the plant. There has been some tendency in !
4
[ 8 the past -- I know Graham Leitch complained to me that he !
1 i
I 9 occasionally feels that he's dealing with two engineering l 10 organizations because he'll hear from the Yankee j i l l 11 organization and he'll hear from us. l l
! 12 But the way I'm aligning this is we will speak 13 with a common voice at that point -- all the engineering 1 l
14 services through myself, as Charlie indicated. So that's l
15 a concept. In order to affect that, particularly in the 16 nuclear engineering area, we intend to add staff. As I 17 look at the interface and look at this concept, we are 18 pretty well lined up in the engineering area to accomplish 19 this.
20 And the other areas, again, as I look at 21 nuclear engineering, the majority of the -- we have a
- 22 relatively small staff in nuclear engineering. Yankee has 23 a relatively large staff. And I believe if we' re going to 24 be effective in providing management oversight of Yankee, 25 I'm going to have to add staff to my own nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W. I (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
]
j
- . - - - ~ _ - . _ -
19 ;
1 engineering section.
2 And Charlie has given me the go ahead to do i 3 that, and I hope to have people on -- hired by the end of 4 this year to do that.
5 MR. RUSSELL: Doug, what you've described 6 sounds to me that the nuclear engineering that you had was 7 mainly reactor engineering looking at core design, 8 r'eloads, fuel cycle optimization, those kinds of issues 9 which are directly tied to procurement of fuel, dealing 10 with fuel vendors, etc.
l 11 MR. WHITTIER: That is right. l 12 MR. RUSSELL: And yet, the area where there is 13 -- and you use the example -- the heavy interface with 14 safety analysis as it relates to emergency operating 15 procedures, and in fact the generic safety evaluations 16 that were done to support the emergency operating l i
17 procedures with respect to a complete understanding of 18 those so if there are needed plant specific differences, 19 if those differences are reviewed, determined to be 20 acceptable, that's a safety analysis review, not 21 necessarily an operations review.
22 It may result in operational constraints that 23 you then have to train -- modify in your procedures. But 24 the underlying analysis that says that's the right thing 25 to do sounds like what you described is operations working NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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1 20 {
1 directly with Yankee Atomic.
2 MR. WHITTIER: That's the way it was. That's 3 exactly the way it was. And again, as I look at that, I'm 4 not comfortable with it. And that's the area that -- that 5 probably needs the most change.
6 MR. RUSSELL: That parallel also applies then 7 to code work and other aspects of safety analysis because 8 the EOP's are principally based upon code analysis of how 9 the plant would respond under certain challenges.
10 MR. FRIZZLE: Those are basically the two 11 areas where Doug has decided he needs more help in the 12 engineering department. He'll get it.
13 MR. RUSSELL: Okay.
14 MR. WHITTIER: ThJ next step --
15 MR. RUSSELL: Could you describe what's the 16 role then of the -- back to your organizational chart, you 17 showed a section that had what I'll call reactor 18 engineering rather than nuclear engineering. Eat you also 19 had licensing, which is the interface with us. So you 20 basically had a licensing staff interfacing with Yankee 21 Atomic and interfacing with operations as it relates to 22 matters that are currently under review.
23 MR. WHITTIER: Yeah, let me put the other org.
24 chart on.
25 MR. RUSSELL: I'm trying to understand the --
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21 1 MR. WHITTIER: When I reflect back -- you said 2 you don't want us to reflect back much.
3 MR. RUSSELL: That's why I used examples other 4 than the one that's the issue of concern. You picked 5 EOP's. If you want to use a different one, choose it.
6 I'm trying to understand the interfaces.
7 MR. WHITTIER: Let me describe the way -- the 8 way the EOP interface worked was directly between 9 operations and Yankee Nuclear Engineering. That's the way 10 that interface worked in the past. Now the way the --
11 some of the interfaces worked where licensing was involved 12 where there was a licensing activity that involved Yankee 13 safety analysis worked -- the way that communication 14 flowed was a. communication would typically go from this 15 group -- nuclear engineering group within Yankee -- up to 16 the project manager -- management office within Yankee.
17 And then typically over to the licensing group 18 within Maine Yankee. And then it would go to the NRC.
19 And if you've ever played the childhood game of sitting 20 around a room and somebody whispers in somebody's ear and 21 you see what, comes out the other end, there is a potential 22 for -- with those number of interfaces to have information 23 lost or understanding lost as you go from one to the next.
24 So my belief is that if I tighten up this 25 connection right here so that we make sure that Maine NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISI.AND AVE., N.W.
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22 i
1 Yankee people have good, solid understanding of the work 2 that's being done here, I'm always going to have an 3 interface. So I have to manage this interface for these i
4 folks to physically sit right next to each other.
5 And then I'll have the interface, of course, '
6 between you and the -- between ourselves and you folks. ,
f 7 And I'm going to talk a little bit more about 8 communications with the NRC. But the other thing, since -
9 I'm on this track, is I have directed our licensing people ,
10 to make sure that when we're getting into matters of some q 11 technical import, that we make sure that we have technical 12 staff that's party to those conversations on our side and i
13 encourage you folks to do the same thing.
J 14 I just think that aids in understanding. I 15 MR. RUSSELL: Who on the organizational chart 16 is charged with the responsibility of maintaining the 17 design basis of the facility?
18 MR. WHITTIER: The design basis -- this 19 individual right here, manager of corporate engineer;.ng.
20 Now part of -- I'm getting a little bit ahead of myself, 21 but parc of what we're doing is really on the next -- if I 22 can take the slide off and go back to here, one of the i 1
23 things we're doing is clarifying responsibility. Because 24 what Charlie described was an evolving relationship 25 between ourselves and Yankee.
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23 1 And this evolved over time. And quite 2 frankly, it's changed over time. And as you might 3 imagine, when that happens and you all of the sudden stop 4 and you ask yourself okay. who's responsible for this and 5 who's responsible for that, you get lack of clarity. You 6 get different answers from different people.
7 And that, quite frankly, isn't acceptable. So 8 ohe of the steps we're doing is at each of these 9 functional interfaces is to make sure there's clarity of 10 understanding as to who's responsible for what. Earlier 11 this year we had started a process, and we've been side 12 tracked a bit because of ongoing inspection activities.
13 But we started a process of listing all of the tasks, if 14 you will, or functions or responsibilities within 15 engineering -- Maine Yankee engineering and Yankee 16 engineering -- listing them all.
17 And then -- we've gotten that far. And the 18 next step would be to assign who's got the responsibility 19 for each and every one of those. And sometimes it's dual 20 responsibility. For example, for a program, EQ program, 21 you might have one group that's responsible for the 22 development, maintenance of the program; and you might 23 have another group that's responsible for implementing it 24 in the field.
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1 24 -
- 1 to finish that type of activity by the end of the year --
i
- 2 is to finish going through each and every task and making ;
3 sure there's clarify of understanding as to who in our 4 organization is responsible. We have -- earlier this year 5 I issued a couple of memos to Yankee on this point.
'6 There seemed to be some confusion in the 1
7 licensing area. There seemed to be some confusion whether 8 or not, for example, the Yankee safety analysis people had 9 responsibility for making sure their work met all legal !
10 requirements. And I made it very clear that anybody
)
11 that's providing technical services, whether it's our own 1
12 people or Yankee, is responsible for making sure that the 13 work that they do meets applicable regulatory 14 requirements, guidance, license conditions and the like.
]
1 15 As you know, the detailed requirements l l
1 16 associated with LOCA are simply too intensive to expect a l 17 licensing individual to catch those or for a licensing 18 individual to tell an analyst each and every-thing that he 19 or she must do in order to be in compliance. And again, I 20 sense a little bit of confusion, at least with some 21 people. And so, we've clarified that. l 22 And the other memo clarified responsibility ,
1 1
23 for reporting. There was questions about Yankee's 24 responsibility and our -- Maine Yankee's responsibility, 25 vis-a-vis reporting -- for example, 50.46 and other l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS !
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25 1 issues. And I made it clear that we, Maine Yankee, are
'2 responsible for issuing a report to the NRC. But it's 3 Yankee's responsibility to clearly bring to our attention i
4 I
, anything that they believe might be reportable so that we l 1
3 5 can-screen it, and as appropriate, notify you folks.
i 6 Another step that's in this plan is to ensure i I 7 that at each of these interf aces that the procedures me.sh i.
- 8 w'ith each other. They're not inconsistent, the flow well
< l 9 together. And short of dictating that Yankee has to use 10 Maine Yankee's procedures in that case. but that needs to e
i 11 Pe a consideration. We need to complett that evaluation i
j 12 and make necessary changes.
13 Again, I hope to have this done by the end of 14 the year. Commitment tracking -- in the past, -- )
i 15 MR. RUSSELL: Can we go back to -- j l
16 MR. WHITTIER: Sure. I 17 MR. RUSSELL: -- a related question?
18 MR. WHITTIER: Sure.
i 19 MR. RUSSELL: Yankee Atomic has a quality 20 assurance plan that's been filed with the NEC. It's been 21 reviewed, approved. Processes exist for making changes to 22 it.
23 MR. WHITTIER: That's right.
24 MR. RUSSELL: Maine Yankee has a quality 25 assurance plan that governs conduct of activities.
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26 1 MR. WHITTIER: Yes. .
l 2 MR. RUSSELL: Does your review include looking 3 at, for example, potential differences between tnose two 4 to see whether they are in fact either consistent with I 5 each other at achieving the objective or whether there's a l 6 potential based upon the way you're structured and 7 organized for doing things in Maine as compared to what l
8 they're doing that there may be something missed as a 9 result of having two different procedures as well as two 10 different organi2dtiona.L ctructures?
11 MR. WHITTIER: It will in the future. I have l
12 asked -- despite of this functional alignment that I '
13 talked about, I didn't specifically talk about QA; but the 14 funct1onal alignment applies there also. And I've asked 15 the -- our manager, Maine Yankee's manager of quality 16 assurance -- I've asked him to take responsibility of 17 quality assurance oversight of not only Maine Yankee 18 activities, but Yankee activities that are performed for 19 Maine Yankee and the interface.
20 As we all know, interfaces are typically the 21 way you find problems. Now I've asked him from a 22 programmatic standooint to make sure that he personally is 23 comfortable with the quality oversight of that entire 24 area. In the past, I believc he would have said his area 25 of responsibility was simply the Maine Yankee piece, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE.. N.W.
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i 27 l 1 we tended to rely on Yankee -- the Yankee program for the 2 Yankee piece.
3 And again, with a functional area of 4 responsibility concept, I want to be able to go to the QA 1
5 manager and say you're responsible for corporate level 6 oversight of that entire package. And so that's a model 7 for the future.
8 MR. FRIZZLE: One of the lessons learned 9 coming out of this, Bill, was that we had probably become 10 too reliant of the fact that Yankee had a "NRC approved QA 11 program." And it's a very good program, no doubt about 12 it. But we had never inspected the interfaces carefully, 13 never done much to make sure our program was integrated 14 with theirs. They both made sense, etc.
15 We're going to be significantly increasing our 16 oversight of the Yankee QA program, at least with respect 17 to work done on Maine Yankee's behalf.
18 MR. RUSSELL: And there are things that are 19 done to provide controls on the quality of the product 20 that's being delivered -- independent checks, sign offs, 21 etc., hold points in review process if it's 22 proceduralized. There's also the quality assurance 23 activity as it relates to self assessment and oversight l l
24 and the quality assurance activity supporting one. !
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28 1 level in the organization, and it's typical that there is 2 a plan to assess areas based upon interaction back and 3 forth with line and others, as well as independently going 4 into ferret out whether there are problems or not. And i 5 taking -- based upon your comments that you're looking at 6 the latter -- that is, to what would be the oversight type 7 activities, the audits, the reviews, to determine whether 8 the programs are in fact implemented appropriately, !
l 9 problems are properly dispositioned, etc.
10 MR. FRIZZLE: That's the area we want to get -
11 -
)
12 MR. RUSSELL: As compared to the mechanics of )
13 how particular calculation is done, subjected to '
l 14 independent review, what kind of documentation goes with i
15 it, what goes in the file, etc. The quality records ;
~
)
16 associated with conduct of an activity is more in the QC '
17 documentation and control retrieveability area. I'm )
18 talking about the management oversight of the processes 19 and going to audit to see whether they are in fact
-20 achieving the objectives that you had laid out.
21 MR. FRIZZLE: And that's the area we need to 22 beef up.
23 MR. WHITTIER: To some extent I'm talking 24 about maybe both functions, because the line organization 25 -- I'm talking my line organization now -- has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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,_)
29
- 1. responsibility for the quality of the product. So they 2 need to be comfortable that the management systems that 3 Yankee has in place to deliver the second checks and some l
l 4 of the things you mentioned are appropriate.
l l 5 So there's accountability for quality in the l
l l 6 lin- nrganization from my staff as well as responsibility l
7 for programmatic quality oversight that you're talking 8 about by the Maine Yankee quality assurance function.
t l
l 9 MR. RUSSELL: Don't take my comment out of 1
10 context. I expect the line to do whatever the.line needs l 11 to do to ensure that the products delivered meet 12 requirements.
13 MR. WHITTIER: Right.
l 14 MR. RUSSELL' Okay, but the concept also is l
i 15 that there is an oversigh' activity --
16 MR. WHITTIER: Yes.
17 MR. RUSSELL: -- with access relatively high 18 in the organization such that if there are interface i 19 problems or other issues, that they can be appropriately 1
20 dispositioned_and evaluated.
l 21 MR. WHITTIER: Right. And the manager of QA l l
l 22 for Maine Yankee reports directly to the president.
l 23 MR. RUSSELL: In the past, have you had any j 24 instances where the second checks are done in your j i
l 25 organization, or has it always been essentially through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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- . = .
. . . . __ l
30 1 Yankee providing completed product including the second 2 checks, the QA, QC --
3 MR. WHITTIER: In the engineering area, we 4 would just often -- I don't want to say all the time, but 5 often will do second checks. And in the area of nuclear 6 engineering I talked about earlier, the core design area,
? our own technical people would take a recommendation from P
8 Y'ankee and look at it. And ultimately -- and that's the 9 model I'd like to get to. Ultimately, they would bring a 10 decision or recommendation to myself from Yankee and my 11 own technical staff may agree and sometimes they'd 12 disagree with the Yankee recommendation.
13 So there are checks and balances in, for 14 example, the core design area. But again, as I indicated 15 earlier, those checks were not present in the safety 16 analysis area. And I want to put those in place.
17 MR. RUSSELL: Okay. This gets back also to 18 the point of making sure that the two plans that you have 19 and the assignment of responsibilities are clear, because I
20 it sounds like there could be some instances where a Maine 21 Yankee employee is performing the second check role 2L function under the Yankee QA plan, --
I j 23 MR. WHITTIER: Yes.
24 MR. RUSSELL: -- and it may be different then 25 the practices that they have in your main QA plan. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
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.__ _ _ . ._- _ .-._ _ _..._. _ . . . . _ _ _ _ _ _ _ _ _ . . _. __m . _ _ _ _ _ .
31 1 it's very difficult for them to know which hat they're 2 wearing and which procedure they're following. j 3 MR. FRIZZLE: That's why we've got to make !
i sure the two programs mesh very carefully.
4 5 MR. RUSSELL: Okay, what you've described is a !
- 6 situation which provides a lot of opportunity for issues l
7 to be dropped. It relies on communications and j 1
- 1 8 MR. WHITTIER: That's why I want to make sure 1 l
9 there's clarity of understanding at the interface and try .!
l l
10 to manage each interface on its own. Clarity of 11 understanding of procedures and clarity of process. The l 12 process has got to work together. And this work has yet l
l 13 to be done.
l l 14 MR. RUSSELL: And you indicated earlier you 15 exnect that to be completed toward the end of the calendar i 16 year?
l 17 MR. WHITTIER: Yes. I'm just looking at where 18 I was. Commitments -- in the past, commitments -- and the 19 way I'm using the term is when Maine Yankee writes a 20 letter to the NRC and promises to do something in the l
i 21 future, that's what I'm -- that's what I'm talking about 22 is a commitment. In the past, if those commitments failed 23 to Yankee Atomic, there was a tendency for Maine Yankee I
24 not to track those.
i 25 That's been changed. Any commitment that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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I 32 1 falls to Yankee Atomic is now tracked in a Maine Yankee 2 tracking system. And I'm going to talk a little bit more 3 in the future, but we've also expanded our definition of l
l 4 commitment. We used to have a fairly narrow definition, 5 and now it's been expanded. But I'll talk more about that 6 later.
7 MR. ZWOLINSKI: Can you amplify that i
8 d'efinition, Doug, to your other vendors that you may 9 acquire services, so on and so forth? You're accepting 10 responsibility for all of these commitments, not just --
l 11 MR. WHITTIER: Yes, that's right. Typically 12 if that department hires a contractor to do work and l
- 13 there's an obligation that we have, and that obligation I'
14 would flow to that department to make sure that it's done 15 through the contractor. It doesn't matter how it's done, 16 but that obligation would flow to that department head.
17 The point is it's tracked.
18 MR. ZWOLINSKI: Is the identity of it being a 19 Yankee Atomic support issue or some other contract support 20 issue start to become blurred and it's really Maine Yankee 21 that's accepting full responsibility for any commitment 22 across the board, and whoever is doing the work for you is 23 kind of secondary?
l j 24 MR. WHITTIER: Yes. Because -- a Maine Yankee i
25 tracking system. And if it was a Maine Yankee commitment, l
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l l
l 33 j 1 we need to make sure it gats done.
2 MR. RUSSELL: Obviously a $64 question. Now 3 that you've laid this out and you've educated us that 4 there may be potential for some commitments that were in 5 the other organization not being fully tracked and 6 implemented, does your plan include what you're doing to 7 look back at the past to see that something hasn't gotten 8 m'issed? I mean, --
9 MR. WHITTIER: Yes.
10 MR. RUSSELL: -- it's one thing to tell me you 17 have a problem and you're going to fix it in the future, 12 but what are you going to do to look back and fix the ones 13 that may have occurred in the past?
14 MR. WHITTIER: I'm getting ahead of myself. I 15 was going to talk specifically about the safety evaluation 16 report. So, --
17 MR. RUSSELL: Okay, I'll let you cover that 18 first and then come back to it. As long as you --
19 MR. WHITTIER: Okay, I will come back to that.
20 MR. RUSSELL: -- answer before we break up.
21 MR. WHITTIER: I wanted to mention procedure 22 and design basis screens. That's a process that Maine 23 Yankee uses on the engineering side of the house to 24 evaluate issues that involved potential discrepancies with 25 a design basis, to evaluate them, and ultimately make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHoDE ISLAND AVE., N.W.
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4 34 -
1 reportability determinations, feed them -- they're 2 screened for bringing them to the control room for 3 operability determinations, that type of thing.
4 So we've had that process in place in 5 engineering for several years. And it's been very 6 effective. Earlier this year I directed Yankee Atomic to 7 implement the same process. So now they -- if they, in 8 t' heir organization, uncover an issue that potentially 1 l
9 impacts the design basis and etc., they have some time to ;
l 10 evaluate it and then they need to bring it to us. I 11 So basically it's a mechanism to bring issues 12 to us, let us share in the evaluation of the issue, and 13 make sure that it, as appropriate, is reported to the NRC; 14 and as appropriate, gets reported to the control room so 15 that we can make operability determinations. And again, 16 that is in place. j l
17 MR. RUSSELL: There is a guidance on timing 18 for conducting those activities. Recognize that our time 19 clocks start with the term "when discovered," particularly l 20 if it relates to a time clock that's specified in tech 21- specs. And so how you screen something and evaluate it as <
22 to whether it is degraded or non-conforming, when you do l 23 operability evaluations, there is some urgency with 24 respect to those which have very short time clocks.
25 So the fact that the organization is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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35 4 1 evaluating it, they ought to be evaluating it with an 3
)~ 2 expectation that at the end of that evaluation, it would 3 be concluded to be operable. If that's not the 4 expectation, they need to do it relatively quickly in a 5 time frame less than the allowed outage time in the tech 6 specs. Because obviously if you evaluate it and later 7 determine it's inoperable and it's taken you two weeks to l
8 make that conclusion that it's inoperable, the time clock i i
9 starts when you discover the condition, not when you 10 complete the evaluation.
11 And so you could have the situation where 12 you've been in violation of a technical specification 13 requirements for some period of time just because of a 14 protracted length of evaluation.
15 MR. WHITTIER: Right.
16 MR. RUSSELL: So the guidance -- and it's 17 contained in a NUMARC document which the staff formally 18 reviewed and endorsed and talked about the screening 19 process and the timeliness of it -- we debated back and 20 forth whether it should be in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. We said time 21 frame consistent with the allowed outage times in the tech j 22 specs. And you've got some things in tech specs that are 23 one hour, some things are one day, some things are seven 24 days, some things are longer periods of time.
25 So -- and generally the longer time relates to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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1 36 1 the safety significance of it. Obviously you find an i
I 2 issue that's associated with batteries -- it may result in l
3 batteries being declared inoperable. You've got a 4 relatively short time clock to conclude whether it is or 5 is not -- so you need to make sure that your processes, 6 particularly since you've got more interfaces now.
7 You've got Yankee doing it.
8 MR. WHITTIER: Right.
9 MR. RUSSELL: We've had experience with other 10 facilities where it's been in the same organization but 11 it's at a remote site. l 12 MR. WHITTIER: Right.
13 ~MR. RUSSELL: 80-90 miles away. Corporate's l
14 doing something, they're working it. They haven't reached 15 a final conclusion yet, but it doesn't get communicated i 16 and there's information that either the operators know or 17 others in on site engineering know that if they were 18 simply aware of the problem would have had a different 19 urgency associated with bringing it to resolution. '
20 That communication interface has been a 21 significant contributor to facilities having difficulties 22 in regulatory space in the past.
23 MR. WHITTIER: I'm going to have to look at 24 that timing aspect. Right now I have a five day limit on 25 any kind of an issue.
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37 1 MR. RUSSELL: Understand that I'm pointing out 2 that five days won't work if you've got a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO 3 that's operable.
4 MR. WHITTIER: Right.
5 MR. RUSSELL: Or a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or something --
l 6 like a 303 issue that says do something within six hours, 7 five days won't work. So depending upon the issue, that 8 means the people need to understand what portion of the 9 tech specs or the license requirements they're dealing 10 with to understand whether they have a need to complete an 11 evaluation on a faster basis than five days.
12 MR. WHITTIER: We're going to have to look at
- '13 that. Because like I said, right now I have a five day 14 clock. It takes time, as you know, with many issues to 15 begin to understand -- ecpecially do the homework 16 associated with understanding what it is you have.
17 There's a five day start under my system from the day that !
18 anybody brings forward a question -- the first question.
i 19 But like I said, I'm going to have to look at 20 the system that we have in light of the guidance that you 21 just referenced.
22 MR. RUSSELL: It's formally in Generic Letter 23 9118 and it's in the formal endorsement of the NEI i
24 guidelines on design basis. It's also contained broadly 25 in the Commission's policy statement on retrieveability,
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38 1 accessibility of design basis information. Obviously if 2 it takes you five days to find the design basis 3 information, --
l 4 MR. WHITTIER: We apply that clock right now 1
5 to the operability determination. In other words, once 6 engineering has done a screen and we feel that it's 7 something that needs to be brought to the control room, 8 then the control room'must make an operability call within 9 the guidelines that you just described. I'm quite sure 10 that's the logic we use.
11 MR. RUSSELL: I understand. I'm just pointing 12 out that it's all one organization the way you've 13 described it.
14 MR. WHITTIER: Yes, yes.
15 MR. RUSSELL: The fact that it's shifted from 16 one part of the wiring diagram on the organizational chart 17 to another chart, it's still one licensee that's 18 responsible for doing it within the time frames laid out.
19 So you need to relook at those issues. And we did agree 20 with screening processes.
21 MR. WHITTIER: Right.
22 MR. RUSSELL: And the expectation is with the 23 responsible person looking at it that it would more likely 24 than not be operable when it's subjected to that test.
25 MR. WHITTIER: What I have is a screening NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 39 1 process. And I have clear guidance that if at any time in 2 the screening process you believe you're dealing with 3 something that's inoperable, then you take it to the 4 control room immediately. And then you have a five day 1 5 limit on anything.
6 You've got to exercise engineering judgment 7 within five days of what it is you have -- is it okay or 8 not okay. That's the way the process is set up.
9 MR. FRIZZLE: If within the five days the 10 engineer determines or suspects that there's a likelihood 11 of inoperability, then the clock stops and it goes 12 immediately to operations.
13 MR. WHITTIER: We can discuss that further, 14 you know, in some detail with your staff just to make sure j 15 that we're --
16 MR. RUSSELL: I'm focusing in on the context I
17 of the interfaces. We identified that this process had 18 been going on between engineering -- I would assume site ;
19 engineering, corporate engineering have a dialogue on 20 these issues and then bring it to the control room.
21 MR. WHITTIER: Yes..
22 MR. RUSSELL: That's all within one 23 organization. It's starting in the context that you've 24 now recently imposed similar requirements on a portion at 25 Yankee, and how those interfaces work and whether the time NEAL. R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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40 1 frames are consistent with --
2 MR. FRIZZLE: The only new requirement on 3 Yankee is that they use our process and our paperwork to 4 process these so that they are addressing them within the 5 same context that Doug was just describing with respect to 6 the five day window, the immediate operability 7 determination, etc.
8 MR. RUSSELL: Okay.
9 MR. ZWOLINSKI: Your ECCW issue would fall i l
10 under this category.
11 MR. FRIZZLE: It came through that process.
12 MR. ZWOLINSKI: When was it known and when did 13 you determine that you had a problem and then how quickly 14 did you move forward in --
15 MR. WHITTIER: I can't give you the time line.
16 We developed a time line. But that was an issue that did 17 come from Yanke6.
18 MR. ZWOLINSKI: Is that right?
19 MR. WHITTIER: Yes, it did. And I believe it 20 got to the control room within a matter of two or three 21 days of initially being -- the questions first being asked 22 at Yankee. But again, we're developing a time line.
23 MR. ZWOLINSKI: Okay.
24 MR. WHITTIER: Now I'm going to shift gears a 25 bit and talk a little bit about communications --
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41 1 meaningful communications with the NRC. I have directed 2 my licensing staff not to make verbal commitments. That's 3 an area that's been a little bit problematic for us in the ,
i 4 past because our policy in the past was not to track l l
J 5 verbal commitments. !
6 So I've tightened that .. p . And my feeling is I
7 today that any time that we feel a need to make a formal 8 commitment with you folks, it ought to be in writing.
9 That way there's clarity of understanding both on our part 10 and your part as to what it is we're committing to. So 11 that's been a change. Changes to commitments will be 12 managed in accordance with NEI guidance.
13 And again, for a commitment that has not yet 14 been fulfilled, my typical -- my normal. expectation would t 15 be is that we'd be writing you another letter to change 16 the commitment. In other words, if we tell you we're 17 going to have X done by the end of the year and it turns 18 out that now it looks really more like the end of January, 19 I would expect that we'd write a letter to you saying it's 20 going to be the end of January.
21 As I indicated earlier, I've directed the 22 licensing staff to make sure where appropriate they 23 include the appropriate technical personnel on -- with the 24 NRC. And again, I would encourage the NRC project manager 25 to do the same thing. And this is an effort to ensure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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42 ;
1 clarity of understanding of the information that's being !
2 discussed. ,
3 I also was going to talk a little bit more 4 later on the management issues, but I've directed the ;
5 licensing staff or informed them that they have a duty to 6 make sure as best they can that there is understanding on ,
7 the other end of the phone call of the issues that are 8 b*ing e discussed.
9 In other words, it's not good enough just to 10 say something, but we really need to try -- we really need 11 to try to make sure that there's clarity of understanding.
12 Reportability under 50.46 we've touched a bit on, but I've 13 clarified with Yankee that they have responsibility for ;
14 bringing potentially reportable issues to our attention. !
15 And in the past, we've had a position that under 50.46 we 16 would -- a report for the limiting accident --
in our 17 case, large break.
18 And I've directed our staff in Yankee to 19 report 50.46 issues for both large break and small break; ;
20 which is, I believe, in alignment with your expectations.
I 21 MR. RUSSELL: Let me clarify. ]
1 22 MR. WHITTIER: Yes.
1 1
23 MR. RUSSELL: We're not talking about a rule. l 24 The rule requires reporting when you have more than a 50 25 degree change in the peak clad temperature for the )
i NEAL R. GROSS I COURT REPORTERS AND TRANSCRIBERS )
1323 RHoDE ISLAND AVE., N.W. 1 (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 2344433 l
i
43 1 limiting break.
2 MR. WHITTIER: Right.
3 MR. RUSSELL: If you determine, based upon 4 analysis, that a different break could be limiting and 5 it's actually tied to the analysis of record that was last ,
l 1
6 approved, so it's typically -- for most plants it's a 7 large break LOCA based upon some analysis, methodology, 1
8 etc. for which there is a safety evaluation on the docket
]
9 saying here's what's approved.
10 If --
11 MR. JONES: If I could clarify?
l 12 MR. RUSSELL: Yes. '
13 MR. JONES: The rule requires all changes to i 14 be reported.
15 MR. RUSSELL: Absolutely. I'm separating out 16 prompt reporting versus 30 day reporting versus annual 17 reporting because there are different thresholds depending 18 upon how big the number is when you recalculate. But the 19 issue is it starts from some base where there's been some 20 review and approval, and let's presume on plant X that 21 it's a large break LOCA and using particular models you 22 calculate 1600 degrees F.
23 Lots of margin to the 2200. And you then make 24 modeling changes. You define -- you identify some -- and 25 cumulatively, with these changes over time, you may have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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44 l 1 individuals that are less than 20 degrees for changes.
~
2 You may make some change in reload analysis, whatever --
3 change in modeling.
4 You trip a 50 degree total change based upon 5 the series of smaller changes. That becomes reportable, 6 and that gets reported at the time you exceed 50 degrees.
7 Within 30 days I think it is. If, at any time, you exceed 8 the 2200 degrees, you're into prompt reporting.
9 MR. JONES: Sure.
10 MR. RUSSELL: It could be that in the course i
11 of analysis you find that some other transient is limiting l 12 that is no longer the large break. And the new number is 13 calculated to be 1650 degrees for new analysis versus 1600 14 degrees in what was previously thought to be limiting. j 15 That's a more than 50 degree change. It's a new limiting -
l 16 - so what I'm commenting on is whatever is limiting, l
17 whether it be small break or large break, there is a 18 margin of record that's based upon what was believed to be 19 the limiting analysis at that time.
20 If you make changes in operation, change your 21 procedure, change your modeling, and you now calculate 22 broadly for emergency core cooling under a spectrum of 23 breaks that there is something greater than 50 degrees 24 above that last approved limiting break number, you're 25 into reporting.
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45 1 If it's less than that, it could be in your 2 annual updates. Or some plants do it with their core 3 operating limits reports when they're redoing their ECCS 4 analysis if they need to. Different vehicles it can be 5 done. I'm not concerned about the annual reporting 6 requirements in that context.
7 But recall, we used to have the typical Friday 8 a'fternoon flap where somebody found that they had an error 9 in a correlation or analysis or whatever, and Friday 10 afternoon somebody would say I've had a small change. The 11 rule used to be 20 degrees when we had the flap. We 12 relaxed it to 50 degrees. And it's not 20 degrees above 13 2200, it's 20 degrees above whatever the last number was 14 that was calculated in the record that was reviewed and 15 approved and accepted.
16 And it relates to margin and reduction in 17 margin.
18 MR. FRIZZLE: The one case that -- and maybe 19 I'm dense here, but at any rate, the one case that I'm not 20 certain of the guidance that you just provided -- let's 21 suppose -- and this is not an atypical situation -- you 22 have a large break LOCA analysis of record that projects a 23 peak clad temperature of 2000 degrees.
24 MR. RUSSELL: You shifted back into that group 25 you started with.
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46 4
1 FIR . FRIZZLE: Peak clad temperature of 2000 2 degrees. You have a small break LOCA analysis -- limiting i
- 3 predicts a peak clad temperature of 1400 degrees -- pick a 1
4 number. Later on you're doing some modeling changes. !
5 Maybe you've made a physical change to the plant, l t
6 whatever. You redo your small break LOCA analysis and it '
l 7 comes up 1450 degrees.
i l j 8 You haven't changed your limiting analysis. ;
i 9 MR. RUSSELL: Correct. You're not under the !
.i j 10 obligation to report under the rule yet because it hasn't j i
11 been an increase of more than 50 degrees in a limiting.
4 j 12 But if that small break LOCA turned out to be 1650 ,
l 1
13 degrees, 50 degrees higher than what was previously j 14 thought to be the limiting analysis, ie. new limiting l i
15 break, --
16 MR. FRIZZLE: The gentleman over there with 17 his hand on his forehead, I'm not sure he agrees.
18 (Laughter.)
19 MR. RUSSELL: We have had licensees --
20 MR. FRIZZLE: I want to be clear.
21 MR. RUSSELL: The statement of considerations 22 with the rule and the other things lays this out. It's 23 back in whatever it is -- 1988?
24- MR. JONES: 1988.
25 MR. RUSSELL: '88, '89?
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__ _ . -. _ -- __. . . _ . . . . _ _ . _ _ _ .-_.--_________.__._--._______.__-_._-s
- 47
, 1 MR. JONES: It does go right through the
~
2 models.
3 MR. RUSSELL: Oh, yeah, obviously. ,
, 4 MR. JONES: And it limits for an individual I
~
5 model. So if you've changed models going large to small - .
j 6 - report for that specific model.
i i 7 MR. FRIZZLE: That's what we're going to do. j 8 MR. WHITTIER: That's what we're going to do 9 in the future. That's not -- that wasn't our l
I 10 understanding in the past. We tended to stick with the 11 limiting transient for like large break. And if a small 12 break changed but it wasn't limiting, we wouldn't report.
13 And it's my understanding today that if a small break l \
] 14 changes by -- since this is a different model -- if it i
i
- 15 changes by 50 degrees, it's reportable.
l
- 16 MR. RUSSELL
- That is the practice today, 17 that's correct. And it's because of using different
- i. 18 models.
f 19 MR. WHITTIER: Right.
i
! 20 MR. RUSSELL: If you had a model that was able j 21 to handle the full spectrum of breaks, then the earlier 22 example I gave you is the correct one.
i l 4 23 MR. WHITTIER: That's right.
i
) 24 MR. RUSSELL: When you're into different i- 25 approved models, then you've got a difference -- because )
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48 1 different models may have different degrees of 2 conservatism depending upon what you've done by way of 3 Appendix K analyses or whether you're doing a best 4 estimate large break LOCA but you're still in Appendix K 5 for small break LOCA.
6 I mean, --
7 MR. WHITTIER: Right.
8 MR. RUSSELL: But you may be under different 9 portions of regulations depending upon what model you're 10 using.
11 MR. WHITTIER: The next slide on this category 12 is we're in the process of improving our experience level 13 of Maine Yankee licensing personnel. I've recently hired ;
14 somebody that had ten year's experience at another 15 facility. Apparently advertising for a section head 1
16 position. Training -- I found that there was lack of i 17 clear understanding on many of the engineering people both !
i 18 on my staff and the Yankee staff about some of the fine 19 points of regulatory requirements.
20 And we conducted -- it was about a four hour I 21 class for virtually all Maine Yankee engineers and all 1 22 Yankee Atomic engineers. Or at least provided -- I think 23 I got most of the people. I don't want to say each and 24 every person was there, but I got most of them -- were 25 provided a four hour training class in regulations.
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50 1 is required by NRC -- let's say it's something required by 2 the regulations but it's not necessarily a license 3 amendment -- some other type of approval, code relief, 4 etc.
5 In your submission, you ider.tify the rationale 6 as to why this should be accepted, approved, granted if 7 it's in the context of a license amendment. Those types 8 o'f commitments for something you're going to do in the 9 future are in essence an application that describes how 10 you would operate, maintain, design and etc. for the 11 portion that's within the scope of that particular 12 request.
13 There are regulations that govern how those 14 are handled. The regulation is 50.59. And if you look at 15 -- and we went through this a week or so ago, Charlie. If 16 you look at 50.34, it defines content of an FSAR. Not 17 necessarily a document. It's based upon content, types of 18 information. So if the FSAR is not complete, if it's 19 missing some information, that's not a basis for not 20 having appropriately looked at something under 50.59 just 21 because it's not in the updated FSAR.
22 That is the scope of activities looked at. So 23 when you're looking at commitments, if you're putting 24 something in a licensing document that's coming in that is 25 a description of how the plant will behave, initial NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 1 conditions, assumptions for a safety analysis, the fact 2 that those need to be consistent with the way the plant 3 is operated, etc. ;
l 4 Those types of things have a higher standing.
1 5 And the vehicle for making changes to those is a 50.59 l l
1 6 process under the regulation as compared to the NEI )
l 7 process which there was a basis for screening and 8 jhdgement if they were clearly things which didn't impact.
9 So, you need to --
10 MR. WHITTIER: I understand that. !
l 11 MR. RUSSELL: -- reflect on that and the 12 difference between the two. Because while they may not be 13 license conditions, per se -- that is, they're not like 14 tech specs where you've got to have an amendment or a 15 licensing action to make a change to it, it needs to be 16 controlled under the 50.59.
17 And some of those commitments are in fact in 18 essence applications for an approval. And under the act 19 and the regulations, there are specified processes for 20 making changes to them. And so while you can make those 21 changes and that's appropriate, you can review and you can 22 change your mind -- you can say I want to do it 23 differently.
24 You just have to make sure that you follow the 25 right process. And there may be a need to inform us about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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52 1 it clearly at least at an FSAR update, but depending upon 2 what the outcome of the review is, it could require a 3 prior approval before you can implement it. And that's a 4 subset of the commitments. But you might want to capture 5 it -- if you said you're relooking at your licensing 6 procedures, if licensing is sending something in in a 7 letter to NRR -- we're making this change, we're doing --
8 hsre's the basis for why this should be accepted.
9 You're in a different space than if you have a 10 reply to a notice of violation and you say this is what 11 we're going to do to get back in compliance. We will 12 still track and follow up it. That's an inspection 13 activity, and there are rules and other things about how 14 those matters are handled.
15 So just make sure that within your internal 16 procedure you can differentiate between the broad set of 17 commitments, some of which may be -- or maybe I'm going to 18 submit this to you for your review so everything from 19 resources, timing, scheduling to this is something that'e 20 a part of an application which results in some type of an 21 approval -- at the time of approval, 50.59 governs.
22 MR. WHITTIER: Right.
23 MR. RUSSELL: As compared to the NEI 24 commitment tracking process.
25 MR. WHITTIER: Let me make sure that our NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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53 1 process for changing commitments makes that distinction.
~
2 I want to just shift gears a again and talk a little bit 3 about control of the licensing basis. And hopefully get 4 at question you asked earlier. With respect to SER's, 5 obviously SER's have been at play in the past. And in the 6 past, we did not interpret SER's as containing a 7 commitment, if you will; or information that needed to be 8 tracked.
9 That has been changed. We have a process now 10 that will require that SER's coming into'the company are 11 reviewed and commitments or conditions will be identified 12 and tracked to ensure compliance. And we're also in the 13 process of implementing a review for accuracy. And that 14 is, in the-past we have sent SER's out to a responsible 15 department head for review, but we never really asked for 16 kind of a return confirmation that that review had 17 actually occurred.
18 And what we're going to be doing in the future 19 is putting these SER's into our tracking system to make 20 sure that we get a comment back that says yeah, I've 21 reviewed this and there are no problems, or here are the 22 problems, just to make sure that that review takes place.
- 23 MR. RUSSELL
- We need to be quite clear in 24 this area. Safety evaluations do not impose requirements.
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54 I 1 be based upon a written record. It's back to your 1-t 2 original point. If it's a part of application for an.
3 approval or if it's in response to a 50.54F letter --
4 let's say we issue a generic letter on some subject, you i
5 reply to us as you're obligated to do under 50.54F and you
- 6 say in that reply these are things why you don't need to l 7 do something or you're doing something less than what was i
j 8 requested, etc.
i l 9' Those kinds of things are information that we l l 4 ,
j 10 rely upon in making judgements about whether your license !
i should be modified in some manner.
~
11 Those types of issues, !
]
! 1 12 when they are reflected in the safety evaluation report, l 13 should be identically things that you have submitted to us 14 in writing.
l 15 MR. WHITTIER: Yes.
16 MR. RUSSELL: So that the safety evaluation 17_ legally has no standing except in a proceeding where there i
-i 18 are obligations upon licensing boards and others and it's ;
1 19 the record that's being used documenting what the staff 20 review is. That is, it should not impose anything that 21 you've not already told us. It should simply be saying 22 you said this and this corresponds, and we found that 23- acceptable.
24 So it's your application for the approval or 25 application for the request that is the source of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 l 1 requirement to track. I have no problem with defense in 2 depth. That is, if you look at something in our safety
, 3 evaluation and it says you're going to do something and 4 that's the basis for our conclusion that it's acceptable J
5 and you can't find that in your documentation saying you 6 were going to do'it, it may have been something that came
) 7 in verbally, i
l 8 MR. WHITTIER: Right.
l i
, 9 MR. RUSSELL: It may have been in the course l
- l
) 10 of a meeting summary or something else. It would be very
]
i 11 nice if everyone tracked back to something in writing so 1
i j 12 you could manage it. But in the past, we have allowed ;
i !
13 verbal inputs, documentation in a project, manager's phone 14 log -- this is what you said. And then it gets into the
]
i 4 I i
2 15 safety evaluation. We're going to try and also move away I i
16 from that.
17 I don't want to rely upon verbal communication 18 as a basis for concluding something is acceptable. 20
- 19 years ago when I was a project manager, that was the way i
i 20 that you got issues expedited. You said on the phone, we
- 21 put it in our phone log, we documented that you said this 4
22 on this date, and it's expected that you're going to do 23 it.
24 But the legal standing of the safety 25 evaluation report is that it cannot impose requirements.
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56 1 If we want to impose something, we use orders or other l
- 1 1
2 vehicles to do it.
l 3 MR. WHITTIER: I understand. And that's some I
4 of the rationale why I don't believe we tracked these in 5 the past. We tracked the document that went into you.
6 And it was cor belief that the commitments should all be 7 there.
8 MR. RUSSELL: But if there were some that were 1
1 9 made in the course of meetings or in reviews or there is l l
10 something based upon a question that information is 11 transmitted verbally and there is an acceptable criteria 12 that's in the standard review plan and in the course of a 13 phone conversation, you describe how you meet that i i
14 acceptance criteria and the staff says okay and writes it 15 down.
16 MR. WHITTIER: That's right.
17 MR. RUSSELL: Hopefully it's just a 18 description of what already exists. But there may be 19 other information that's supplied within that that is key 20 to the staff's conclusion that it's acceptable. If you 21 find many of those where you find something in a safety 1
22 evaluation that you can't point to the underlying document
! 23 that had Yankee Atomic or --
24 MR. WHITTIER: Maine Yankee.
25 MR. RUSSELL: -- Maine Yankee on the NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N.W.
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e 57 1 letterhead, then either your process or my process is 2 broken.
3 MR. WHITTIER: Right.
4 MR. RUSSELL: Because it should be on the 5 docket as a part of the application. It should be 6 referenced in a letter dated so when you read the safety 7 evaluation it cites the chain of correspondence, some 8 place in that chain of correspondence should be everything 9 that we relied on that's discussed in the safety 10 evaluation report.
11 MR. WHITTIER: I agree with that. I continue 12 to think though that a check on the back end is valuable l 13 and to make sure that there's clarity of understanding.
14 Because if there's something in there that doesn't ring 15 true to us, then I think we have a duty to bring it to 16 your attention. j 17 MR. RUSSELL: I also agree with that. And so 18 I have no problem with using this as a second check. It's 19 probably also worthwhile to do, as it relates to issues as i l
20 to how well commitments have been tracked and controlled i 21 from the standpoint of a look back -- I 22 MR. WHITTIER: Here's another aspect of SER's, 23 and that's what I might call a conditional acceptance.
! 24 That if an SER could -- has language in it that says it's ;
25 okay to proceed provided that you do the following, in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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_ - - .y .gm
l 58 1 past we would not have tracked those types of things 2 because of my belief in what you just said that an SER !
3 does not contain additional requirements any more than 4 what was provided on the front end. :
i 5 But if tho staff writes what I would call a l
6 conditional acceptance --
7 MR. RUSSELL: What we should have written ;
I l 8 would be an order accepting in part and imposing in part l 1 '
l l 9 some additional requirements. If you haven't put the I l
10 additional commitments on the docket, the only vehicle for )
11 imposing them on you is a formal process.
12 MR. WHISTIER: Or ask us to submit. !
l i
13 MR. RUSSELL: Correct. '
14 MR. WHITTIER: And that would be the way --
t 15 MR. RUSSELL: And we ought to hold up issuing i
16 the piece of paper until we have your document.
17 MR. WHITTIER: Absolutely. That would be a 18 tighter way to do it. We are in the process of also l 19 performing our review, although I may rethink it after 20 this discussion; but we're in the process of reviewing 21 past SER's to identify any discrepancies we might find.
22 We're about five years back, and so far this is in l
l 23 progress. But so far, we haven't identified anything i
l 24 significant, but we're working on it -- working our way I
i 25 through that.
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_ = _ . . _ . - _ . _ _ . _ _ _ . _ _ _ _ . _ _ . . . _ . _ _ _ _ _ _ _ . . ._. _ _ , _ . _ _ . _ . - _ _ _
59 1 MR. ZWOLINSKI: Those are SER's that were used 2 for amendments that were approved or other topics of a 3 generic nature or both?
! 4 MR. WHITTIER: Both.
l '
l 5 MR. ZWOLINSKI: Okay.
6 MR. WHITTIER: The circle was drawn around all ;
7 the SER's -- anything that was identified as an SER in our ,
8 files, we have commended a review. Now, I know that in l
9 time that will become problematic because I remember back 10 in the early 80'2 when SER's were written that said the l
l l 11 licensee ought to be required to do thus and so with 12 respect to some of the post-TMI items.
! 13 And the requirements may never have been l
l l
14 imposed. And in fact, we went -- the licensee went and l 15 did something else to resolve a particular issue. We're 16 ,' going to have to work our way through those when we get
, I' l
l 17 back. I l 18 MR. RUSSELL: It's less of a concern as it l 1
19 relates to what I will characterize are exemptions and I
20 formal licensing actions, amendments, formal approvals l
21 that are required where it's a pre-implementation finding 22 that we make. There are a number of generic issues that 23 are in the context of compliance matters where a generic i 24 letter or a communication is issued under the compliance 25 exception, the back fit rule. i NEAL R. unv;; ,
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I l 60 1
l 1 And we make it a post-implementation review.
2 And you submit stuff to us telling us what you're going to 3 do to get back in compliance, and we review it to conclude 4 whether you have or have not met the positions described 5 or whether the exceptions to the position described are I 1
6 acceptable. l l
7 And that's been an area where there's been a 8 16t of give and take. It relies upon the premise that i
9 when the item was imposed, it was properly imposed as a )
4 10 compliance back fit. That is, there is an underlying j 1
11 regulation which we're requesting information to determine l 12 whether you are still in compliance with that regulation, 13 requirement, whatever it was.
14 There's another message in my discussion, and 15 that is both you and the industry broadly need to pay 16 much closer attention to how generic communications go 17 out, whether it is something which is an enhancement.
18 That is, it's a -- on a cost benefit basis imposing a new ;
19 requirement is appropriate or whether it is something 1
20 which is a compliance matter even though there's been an
)
21 estimate of the cost of compliance, and that's been done.
22 It is a big difference in licensing space as 23 to whether you ask something to show how you still comply 24 based upon some new operating experience or understanding 25 or it may be a change in staff position as to what is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 4
1 necessary to comply as compared to imposing a new 2 requirement through a regulatory analysis process. And 3 that's where we've run into some difficulties with some of 4 the generic issues, TMI requirements in the past.
5 But there is, in most cases, an underlying 6 regulatory requirement for each one. If the operating i 7 experience indicates that that requirement was not being i I
8 s'atisfied, then we need to understand how that operating j l
9 experience can be factored back in so that you can come 10 back in compliance with the higher level requirements, 11 the rule, etc.
12 That nuance is not always understood, and it 13 is in fact something which you don't deal with generic 14 communications and how requirements are imposed. There 15 could be a request for information that is obligatory for 16 you to describe how you in fact still conform with some 17 requirement.
18 That can be missed, and that's important for 19 your licensing managers to understand, and that's going to 20 be an issue for us to address as well as it relates to all 21 of the activities going on now. Because there may be 22 changes in how we process some of those things to make it 23 even more explicit. Where it's a compliance back fit, 24 what is their regulatory requirement that potentially is 25 not in conformance, etc.
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l
l 62 1
l 1 And that's ongoing now. That's part of our 2 own internal lessons learned.
3 MR. WHITTIER: Yeah, I understand the l
4 distinction. I don't think we had focused on that in the l
l 5 past -- that distinction, and we need to. FSAR updating 6 procedures and processes -- we found that as we looked 7 back at our process for updating the FSAR and keeping it 8 up to date that with respect to operating procedures and l 9 design changes, the process was pretty good.
1 10 But with respect to changes in the analysis l
11 that did not have an underlying hardware change, the l 12 process was lacking. So that needs to be beefed up. And 1
13 we also have reviews of the FSAR under way. Some of this l
14 work is more lessons learned really from Millstone than it 1
1 15 is really coming from RELAP.
1 16 And we have a process under way to h:ve 1
l 17 operations, engineering and safety analysis people review 18 the FSAR and identify any issues. The last topic was --
19 MR. RUSSELL: This is something I mentioned at l
l 20 the meeting the other day, but I'll just repeat it so 21 there's a clear understanding. Content of the FSAR is 22 defined in the regulations as to what should be the 23 content. The regulation did not require for the FSAR -- a 24 back fitting to standard format and content. That is, you 25 can put the information in in the appropriate section to l
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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1 63 1 the extent new information is generated, which should be 2 in the'FSAR update as defined by the regulation for 3 content by the FSAR. !
! .. 4 We have seen a number of cases where changes l
5 were made or particularly under 50.59, or in some cases 6 even where there's an amendment that the updated '
7 information does not get in unless it conflicts with old ,
I 8 ihformation that's in the FSAR, and then the correct ,
9 information is put in. That's not the way the rule reads.
10 Obviously it needs to be complete and accurate for the ,
11 information that's in there.
12 But if it's missing content that's required by 13 the regulation, it's also -- that's incomplete by omission 14 as compared to wrong by inclusion of information that's no 15 longer accurate. So when you're doing your FSAR review, 16 make sure you look both at the accuracy of the information 17 that's already described and also look at it with respect 18 to the regulation, vis-a-vis the information that's 19 supposed to be in it and whether you have missing 20 information.
21 And I expect this will be an area where there 22 will be additional guidance probably in the form of a 23 regulatory guide that will more explicitly articulate, 24 instehd of the broad terms that are in the rule as to what 25 the content should be, the specific examples. It's clear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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- . . - . - . ~-..-. - ..- -..-. .. ..
- . _ . . - . . . - . . - - . _ . . - - . _ . . ~ .
J 64
. 1 that. changes made under 50.59 get incorporated in the l 2 updates. It's_ clear that amendments get in there, and 4
l
'. 3 it's also characterizes information submitted to the i i 4 Commission as a result of a regulatory requirement to i.l 5 submit that may be the basis for a conclusion of no action 6 on the part -- that is, you characterize what the status l l
- 7 quo is, and we say okay. )
1 1
8 If we've relied on it, we expect you to follow '
i l
3 9 that as if it's part of the FSAR until you change it in 10 accordance with 50.59. So for an example, if you send i 11 something in in reply to a 50.54F request and you describe
! 12 the plant or you describe a safety analysis, you describe i
. 13 operator's ability to respond to an event based upon a
- 14 procedure, those things are part then of the description 15 of the facility -- would be governed by 50.59 changes in 16 the future.
17 And we would expect that those would be i !
.- 18 followed until such time as they're changed through an i
19 appropriate process. And we have not listed other than 20 standard format and content Reg. Guide 170 for new i 21 applications how this is done as it relates to updating
! 22 requirements of the 50.71. I expect that will be an area 23 that we will be involved in corrective action to put out 24 guidance.
25 MR. WHITTIER: The last topic area that I i
1 i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
l j (202) 234-4433 WASHINGTON. D.C. 20005-3701 (202) 234-4433 J
65 I wanted to cover was what I referred to as management 2 issues. And the first category, I've held meetings with 3 nuclear engineering and licensing staff and talked down 4 through lessons learned, some of the things that didn't go ,
5 as well as maybe they could have with the benefit of ,
i 6 hindsight. '
7 But more importantly, discussed expectations - l
- ~
8 - a lot of the things we've been talking about here today.
4 9 The importance of communications; clarity of 10 communications at different points; the importance that we 11 make sure, as best we can, that there's understanding on I
12 both sides of the phone call; the expectation for l l
13 licensing that would be rigorous in our communications.
14 If we rely on something -- if something's i 15 important to make a commitment, it needs to be in writing.
16 We prefer communication for important issues be in 6
17 writing. For the nuclear engineering folks, we talked 18 through the new alignment, the function alignment, and 19 what their accountability is. And also, the importance 20 for them in licensing to make sure that they clearly 21 communicate. j i
22 Because otherwise, all I've really done is ]
23 transferred a communication breakdown perhaps from one i
24 location to another. That's not the intent. So we stress !
25 with nuclear engineering, you know, the responsibility for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
(202) 234 4433 WASHINGTON D.C. 20005-3701 (202) 234-4433
66 e
- 1. communications.
2 Upgrading procedures -- Yankee has upgraded 3 their procedures in the area of safety analysis in the 4 early 90's, and we're looking at those now and asking them 5 to make further upgrades. Basically just to tighten up 1,
j 6 the control and safety analysis process.
i j 7 And the last area we already talked about, and l 8 that is the quality assurance oversight. We've asked the i 9 manager of quality assurance to consider as part of his l 10 job oversight not only of Maine Yankee activities, but l 11 Yankee activities performed for Maine Yankee with a i
i 12 specific focus on the interface.
13 That completes my part of the presentation.
I 14 If you don't have any questions, I'll turn it back over to i
j 15 Charlie.
i -
16 MR. RUSSELL: I think we interrupted you 17 enough.
18 MR. WHITTIER: Thank you.
19 MR. RUSSELL: I'd like to make sure we got the 20 issues -- well, the timing was right.
21 MR. WHITTIER: Thank you.
22 MR. FRIZZLE: It's already past noon, and I'll 23 keep these conclusions very, very brief. Obviously as a 24 result of our various assessments of RELAP5YA, we have 25 learned that things -- in retrospect, a lot of things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
67 1 could have done better, could have been manac t better.
2 And we are determined to make sure that we implement l 3 improvements as appropriate to see to it that they --
4 these same issues don't recur in the future.
5 All of these initiatives -- and this is I 6 something relatively new -- all of these initiatives are 7 currently being captured along with our Maine Yankee 8 division into what we intend to use in the future as a l
l 9 consolidated business plan such that in the future when 10 Doug's people, for instance, take on a new commitment, 11 that commitment will be taken on in light of its priority 12 with respect to all the other commitments we have on the l 13 table in a consolidated or integrated approach -- is i 14 applied to all of these various improvement opportunities.
15 With that, I'll turn it over to whatever 16 questions you have remaining.
17 MR. RUSSELL: Let me ask a question about 18 communications, both with the ITRC staff on site and with 19 the regional staff. While what we've talked about has 20 principally been in the area of interaction on licensing 21 manners, code reviews, things that are typically done out 22 of headquarters, it appears that there are lessons to be 23 learned that apply to the interface between other areas as 24 there are reviews that are done for QA oversight, for 25 example, in the region.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON. D.C. 20005-3701 (202) 234-4433
68 1 There are reviews that are done for emergency 2 operating procedures where you have interfaces between 3 licensing, engineering, operations, training, etc. We 4 clearly evaluate engineering performance in the context of 5 support to operations.
6 MR. FRIZZLE: Yes.
7 MR. RUSSELL: We're now inspecting and 8 evaluating engineering in its role of assuring maintenance 9 of the design basis and in the FSAR. Some of these 10 lessons learned and activities that you have under way 11 relate to those matters as well. Do you have any plans to 12 go into the regional office and brief the regional 13 administrator and others similar to this briefing?
14 Have you had dialogue with the on site staff 15 to describe to them what some of the changes are that 16 you're looking at and how they would be working?
17 MR. FRIZZLE: With respect to on site 18 communications, we have communicated virtually all of this 19 to the on site organizations at this point. I hesitate 20 for just a moment because the announcement with respect to 21 the organizational change that I mentioned right up front 22 went out this morning. It was effective last week, but 23 the formal announcement to my own people went out this 24 morning.
25 But these changes and improvement NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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_ _ _ . . - - . _ _ . . _ _ . _. _ . . .=_-- _ _ _ . _ _ _ _ . _ _ _ _ _ _ . _ . ._
69 1 opportunities have been discussed with our staff. We have 2 not put together a formal presentation yet for the region.
l 3 This was first on our priority list to talk to you people 4 since this was basically -- NRR was basically the focus 5 with respect to RELAP and whatever miscommunications might !
6 have taken place, whatever mismanagement on Maine Yankee's i l
7 part took place.
8 The focus was NRR. We wanted to talk to you l
9 people first about these improvement opportunities. But l 10 we will do this in the region as well.
l 11 MR. RUSSELL: I think it's important in light 12 of some of the comments about lessons learned related to 13 Millstone and activities you have under way and looking 14 back at safety evaluations because the regions -- while 15 they aren't legally binding imposing requirements, the 16 regions, for example, on generic issues, use the safety i
17 evaluation as the point of departure in the conduct of 18 their inspection activities.
19 They use the FSAR, and have since February, j 20 for every inspection that's conducted -- look at the 21 relevant sections of the FSAR. And as you're aware, 22 you're now getting an inspection report that has a write 23 up that is based upon the activities conducted. Was it 24 consistent with or not consistent with the FSAR, etc? So-25 there are a number of related interface issues that would NEAL R. GFM)SS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON. D.C. 20005-3701 (202) 234-4433
--- - . _ . . . . - . - . ~ . . . . . - . - . . ~ . .. . . . . - - = - - . . .
70 1 be appropriate to describe to them, particularly in the 2 context of the engineering functional area as it's 3 described in SALP and as it's being evaluated and 4 assessed.
5 MR. WHITTIER: Many of these areas have been 6 discussed with the resident, and I encourage my individual 7 managers to, meet with the resident about every inspection
- 8 c9cle -- about ev.ry month and a half to specifically go 9 over initiatives that we have in our play and any concerns l 10 that he may have just in an effort to be pro active in 4
11 communication.
12 So a lot of what I've talked about today has
) 13 been discussed in difference pieces. But we'll make sure 14 the entire package is communicated. !
15 MR. RUSSELL: Okay, thank you very much.
)
16 (Whereupon, the meeting was adjourned at 12:11 ;
i 17 p.m.)
18 19 20 21 22 j
i 23 24 i
! 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234 4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
l CERTIFICATE This is to certify that the attached f i
proceedings before the United States Nuclear l
Regulatory Commission in the matter of:
Name of Proceeding: PUBLIC MEETING WITH MAINE YANKEE TO DISCUSS ISSUES RELATED TO REIAP5YA [
Docket Number: N/A l Place of Proceeding: ROCKVILLE, MARYIAND 1 1
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.
1
'pOff
@icial Y%ReporterINS Neal R. Gross and Co., Inc.
I l
l I
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, NW (202) 234 4 433 WASHINGTON. D.C. 20005 (202) 234 4433
.~ _ . . . . ~ - - . . . .. -. - - - . . . - ~ . . _ _ _ . - . - - - -
- y. - -
MANAGEMENT ISSUES ,
MEETINGS HELD WITH NUCLEAR ENGINEERING AND LICENSING PERSONNEL DISCUSS LESSONS LEARNED DISCUSS EXPECTATIONS l
i UPGRADE PROCEDURES FOR DEVELOPMENT OF SAFETY ;
I ANALYSES l i
UPGRADE QUALITY ASSURANCE OVERSIGHT OF SAFETY ANALYSIS AND MY-YNSD INTERFACE l
l l
l Q:4DW@dPROVE.GDW l
i AREAS OF IMPROVEMENT s
l MY/YNSD INTERFACE MY COMMUNICATIONS TO NRC CONTROL OF LICENSING BASIS r
MANAGEMENT ISSUES QXiDWJMPROVE.GDW I
4 l MY[YNSD INTERFACE I
- PLAN FOR IMPROVING MANAGEMENT OF THE l INTERFACE UNDER DEVELOPMENT i-l
- COMPLETE TRANSITION TO MANAGEMENT OF INTERFACE ALONG FUNCTIONAL LINES :
! l i
ADD STAFF TO M.Y. NUCLEAR ENGINEERING TO l IMPROVE OVERSIGHT OF YNSD SAFETY ANALYSIS ACTIVITIES CLARIFY MY/YNSD RESPONSIBILITIES i
I j j -
MEMOS ISSUED BY V.P., L&ES, IN JANUARY &
j MARCH 1996 TO CLARIFY YNSD 4 RESPONSIBILITIES PLAN TO DOCUMENT MY/YNSD l RESPONSIBILITIES AT EACH FUNCTIONAL i INTERFACE i
4 4
i QMIDWa4 PROVE.GDW i
MY/YNSD INTERFACE (continued)
! . ENSURE INTEGRATED PROCEDURES AND l PROCESSES IN EACH FUNCTIONAL AREA b l l -
CONDUCT REVIEW IMPLEMENT REQUIRED CHANGES 1
i 1
i
- . COMMITMENTS ASSIGNED TO YNSD ARE NOW l TRACKED BY MY YNSD NOW USES MY PROCEDURE ON DESIGN BASIS SCREENS ENSURES IMPORTANT ISSUES ARE BROUGHT
- TO MY FOR EVALUATION AND REPORTING IF
- REQUIRED I
1 l
1 i
4 i
Q:\GDWJMPROVE.GDW f
MAINE YANKEENNSD FUNCTIONAL RELATIONSHIP
- =
President !
J Med QA We PrenWore Vice PreeWent Licensing & Engineering Operations
" - PM Enginsehg Outage Manager p,
- Enginsedng -
E
' Plant Manager
-Nuclear E ; .
Supped
- Ptere a gpon - Licensing operesione Manager
- C_.;"m
"" Engineenne Maineenerr.e Manager EsmeanrnerW Emegency Planrdngf Technical sepped Ermeerunereal Enginsedne Menager Enginsedne Q%verheadO71196.vsd - CompiAers
I MY COMMUNICATION TO NRC MY POLICY ESTABLISHED REQUIRING COMMITMENTS TO BE FORMALLY SUBMITTED
- CHANGES TO COMMITMENTS ARE REQUIRED TO BE
- MANAGED IN ACCORDANCE WITH NEI GUIDANCE l l l LICENSING PERSONNEL DIRECTED TO INCLUDE
- TECHNICAL PERSONNEL ON NRC TELECONS WHERE APPROPRIATE 1
RESPONSIBILITIES FOR REPORTING UNDER 50.46 HAVE BEEN CLARIFIED
. 1 EXPERIENCE LEVEL OF MY LICENSING PERSONNEL l BEING IMPROVED REGULATORY TRAINING PROVIDED FOR MY AND YNSD l PERSONNEL i ,
LICENSING PROCEDURES BEING REVISED QTrDWIMPROVE.GDW l
CONTROL OF LICENSING BASIS CONTROL OF SER'S ENHANCED TRACKING REVIEW FOR ACCURACY REVIEW OF PAST SER'S UNDERWAY UFSAR UPDATE PROCEDURES TO BE REVISED TO IMPROVE CONTROL OF ANALYSES r
UFSAR REVIEW UNDERWAY Q:GDWBfPROVE.GDW
MAINE YANKEE MANAGEMENT MEETING
~WITH NRC ON MAINE YANKEE'S LESSONS LEARNED AND l IMPROVEMENT INITIATIVES RELITED l TO ,
RELAP5YA 1
July 30,1996 i
i I
4 AGENDA ;
4 l
i l
i 1
! l r
RELAP5YA LESSONS LEARNED
)
MAINE YANKEE INITIATIVES fi J
J
! CONCLUSIONS 1
i 4
1 O
RELAP5YA LESSONS LEARNED Maine Yankee has conducted several assessments related to the programmatic and management aspects of the RELAP5YA incident:
l RESPONSE TEAM INDEPENDENT REVIEW TEAM l RELAP5YA SELF-ASSESSMENT REPORT l In contrast, ML&B assessment narrowly focused on wrongdoing issues. l Maine Yankee has identified lessons learned based upon these assessments.
Lessons learned fall into the following areas:
MY/YAEC INTERFACE COMMUNICATIONS WITH NRC CONTROL OF LICENSING BASIS MANAGEMENT ISSUES Areas for Improvement 1
s.
CONCLUSIONS Maine Yankee's RELAP5YA Assessments have Identified Lessons Learned.
Maine Yankee has Initiatives in Place to Achieve Improvements for These Lessons Learned These Initiatives are being Captured wita Maine Yankee's Mission and Vision Statements to Form a Consolidated Business P:.an i
___ _. . . . . - . . . . . . . _ . . . - - - - ~
i w- ._ -
OFFICERS AND DEPARTMENT MANAGERS
- Acting Chairman Board of Ditectors D. T. Flanagan !
i Administrative Psesident/
Assistant 11 Chief Executive Officer - SecretarI& Closk I j
W. M. Fm.n 8.J.Padavana ;
C. D. Frizzle - Assistant Secretary A. M. Pare !
Vice President. Nuclear Services .
A. C. Kadak i (President, Yankee Atomic)
Vice President Vice President Vice President l L.lconsing & Engineering Finance & Administration __ _ Operations Psoject Manages P. L Anderson G. D. Whittier P.S.Lydon G. M. Leach i
GmrW h d 7teasurer/ Manager - -
g Financial Seevices l M A. Lynch 8*"i ' Manager. Plant Manage:
M.E. Thomas og R. W. Blackmore C.R.Shaw
~~ insiages- Manager, Corporate ~ Comptrollet and
__ Erigpung, _ _ _ , , Manager Accounting Put>Nc & Govt Affairs' _
, j L R. Deen ^ S. E. N6chols M. K. Chipman, Jr. Manages Outage L. , 6, process R. L Bickford A.R Shean j Manages 9PW Manager, L.8E Suppoti
. Straltgic Platitilfig_ -
y et J. C. Frothinghun J. R. Hebert y a,n .
Trairung - - - -
M.J.Ve:Reux !
R. M. Hayward i
_ _ . . . _ _ Manager, Plant Enguisesing M anages !
E.D.Soule Operations S. P3rruth
,s T Z
( Manager k 3 E9 Technical Su. pport.
.. k,
~
b9 J M ConneB ;
.R 6 f
1 i
_ . _ , - . a. _.. .m -..- _ m .m - - ... ~ - _ -- --..= - - -_ - - . - --. - - -- - ...- - - - - -._. - - - - ..-.-..--~.m - - -
- m. ; .
OFFICERS AND DEPARTMENT MANAGERS Cheltman !
T Board of Directors !
l D. T. r_ ; - -
Administrative Presidentf Assistant 11 Chief Executive Officer B.J.Padawana C. D. Frterte
[
l l
l Vice President Vice Presider t Vice Presi4nt Vice President I
& General Counsel Licensing & EngL.M.g Finance & Adm',ilmh*%e Operations l G. D. WNetter P.S.Lydon G.M. Leach l l
._ Assistant Secretary Treasurermanagw Project Manager !
to the Board Financial Services (YNSD) _
~
P L Anderson M.E.Thomme PI*"I E*"*0 s*"i # ""*'*#*
C.R.Show R. W. Blackmore R. M Heyward M anage' l Manager, corporals (Ig Pubate & Govt Affairs
! Engineering -
L R. DieN j
] S. E. Nichols M. K. CNpman, Jr. 3 Manager Learnine Process _
Manager, Outage i i
A.R.Shean R. L MM 1
Manager QPDF Manager, LSE F,oppo,eI
_ _Ekateanc Plannine _
J. C. Frothingham J. R. Hebert ""*8 g
M. J. Veiseux l Manag*t, Plant g Engineering a E.D.Soule "*"*8*'
Operations ;
S. P. Se Manneer sg Technical support i J.M Connes -
i l
l
- . _ _ _ - _ _ _ _ - _ _ - _ - _ _-_