ML20129J233

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Mgt Conference Regulatory Oversight,Oak Ridge,Tn
ML20129J233
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Site: Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date: 05/09/1996
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ENERGY, DEPT. OF
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Download: ML20129J233 (89)


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MANAGEMENT CONFERENCE Regulatory Oversight Oak Ridge, TN May 9, 1996 BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 9611060180 961030 PDR ADOCK 07007001 B

PDR

2 1

MR. JACKSON:

Let me first of all welcome 2

you again to Oak Ridge.

This is a management 3

conference.

The agenda for this conference is 4

very simple.

I intend to give us an introduction, 5

explanation of what we're hoping to achieve at 6

this management conference, what we plan to 7

address and accomplish, allow USEC to make a 8

presentation.

9 Following that, I recognize the Nuclear 10 Regulatory Commission has representatives here, 11 and I would welcome or encourage any comments that 12 they may have during this period.

And then we'll 13 take a break.

That will give us a chance to 14 caucus.

And then we can come back in and ask any 15 additional questions of USEC that we may need for 16 clarification from their presentation.

And then 17 we will adjourn.

18 As a matter of introduction, let me say 19 what this management conference is.

It's a 20 management conference.

Our program does not have 21 specific guidelines for a management conference.

22 It's not an enforcement conference though.

It's 23 not -- we've talked with USEC and our own staff 24 before, so this is not intended to be an enforcement conference where we go through the 25 BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

3 J

litany of issues and potential violations and 1

violations and to discuss those from a safety 2

3 significance.

We do want it to be a communication tool.

4 5

We do want open communication.

We can discuss 6

feelings.

We can discuss how we perceive things l

7 in this conference.

It's very important that we j

8 communicate what we're doing here.

And as I said, 4

we don't want to limit our discussion to the 9

10 examples we gave you.

They were to be 4

i 11 representative of concerns that we have'in my l

12 letter calling for the conference.

We hope you'll i

leave this meeting with a common understanding and 13 i

14 recognition of the problem and clear course of 4

15 action to help us get there.

i 16 From the overview standpoint, as our letter indicated, we see problems, issues, violations in j

17 l

18 areas of procedures, corrective action 19 dispositioning, and maintenance of and adherence I

20 to the authorization basis.

To reach this 21 conclusion, we have used the DOE site safety 22 representat'ives' input.

We have used our 23 inspection reports.

We have looked at your own i

~

24 problem reports.

We have looked at your own USEC 2

25 self-assessments.

I spent the last two nights i

BONNIE L. SMITH, RPR

}

MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 j'

Phone (423) 675-1471 1,

4 j

i 1

just refreshing myself.

And it's really 2

concerning the litany, the number, and the 3

repetitiveness of these violations, these issues, 4'

over the last several years.

5 It's our expectation that we can reach a 6

common understanding and that we can get an 7

agreement on a plan of action, of course, today, 8

recognizing that we've asked you in our letter 9

that you have till the end of May to give us a 10 formal written plan of schedule.

But we hope we 11 can get a clear understanding of it today and a 12 recognition of who's responsi. le.

13 Okay.

This is what I don't have.

This is 14 what this whole issue is about.

I don't have the 15 confidence I need to stand here as an effective 16 regulator in these areas.

I rely on my site 17 safety representatives.

They do not give me that 18 confidence in these programs.

I've spent a great 19 deal of time with NRC, both of the headquarters in 20 the region.

They seem to share or reflect some of 21 these same concerns.

And I'm not speaking for 22 them, but that's in my dealings with them.

23 In the next hour, you all cannot convince 24 me -- there's not enough time -- that we do not 25 have problems, that our violations that are BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

5 1

issued, inspection reports, your problem reporta, 2

the NRC observation reports, your own 3

self-assessments are wrong.

However, you can make 4

a lot of progress in relieving for me what I call 5

a burden with respect to ensuring safe operation 6

of these plants.

7 The part of the burden I share and I have 8

is that our program in the regulatory process was 9

set up to instill in your organization a sense of 10 taking management control of these things.

Over 11 this past year, I've allowed part of my focus to 12 go towards the application, the transition and 13 certification process.

And because of the 14 slipping of schedule, I have let myself depart 15 from our program.

16 Our program says, once you have repetitive 17 violations, once you have programmatic failures --

18 it's not a burden on me.

It's a process that we 19 go through to have enforcement conferences, issue 20 level two violations, issue civil penalties as 21 appropriate, and to get your emphasis, your 22 attention on these areas that way.

But I've 23 allowed myself to depart from that to, you know, 24 facilitate this process.

25 The burden I have is that I really feel BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

llll l

6 1

that we have spent a lot of time.

Progress in certain areas, and I think I've been willing to 2

3 recognize that progress in certain -- in many 4

areas.

I've recognized the efforts of Steve 5

Polston and his group with respect to the 6

Radiation Protection Prcgram.

I've recognized 7

with respect to Dale Allen in his program some of 8

his attention to OSR significance.

So I've tried 9

to recognize that as we go along also.

10 But my burden is that I feel that after 11 three years, roughly three years, there's been 12 millions of dollars -- I think I was at a 13 presentation yesterday where there was roughly 14 eight to ten million dollars spent on procedures.

15 And, quite frankly, I can't see it.

I can't feel 16 it.

I don't hear it from my site safety reps that 17 we're there.

I do not hear that we have good 18 procedures, that we have confidence in them, that 19 we know where we are, that we know we have fifty 20 three percent of the safety-related procedures in 21 place today.

f 22 I guess all I'm really saying is I want you 23 to use this meeting and the follow-up time between 24 now and the end of the month that you have to educate me if I'm the one that doesn't -- if 25 BONNIE L.

SMITH, RPR l

MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 i

j 7

i

- there's a lot out there that I don't know.

I need I

1

]

2 to be educated.- But it goes back to that one 4

L J

3 word.

I need the confidence that these programs

\\

4 are in shape.

Tnese are basically the points that~we're 5

i 6

concerned about, the development of.the new l

7 procedures, the implementation of the new 4

)

8 procedures, control, maintenance, adherence.

}

9 Corrective actions.

Repeat violations are 1

10 unacceptable.

They're unacceptable in nature and 4

i 11 the number and levels of repeat violations are 4

12 unacceptable.

I 13 Corrective actions, you know -- and, again, 1,

14 I'm going here from feelings.

I' don't have --

15 that's what this is.

This is not an enforcement 16 conference.

But I think our documentation and 17 your own seems to support this.

You know, it's --

4-l 18 to go to a regulated controlled configuration j

19 management system is hard.

And I think it is, you i

l 20 know, a difficult thing to change, but we're 21 almost three years into it.

So change, we feel, 4

i' 22 is required.

It's hard.

We understand that.

But i

23 at the same time, we've been I think as patient as 1

24 humanly possible.

[

25 As I've always said, the maintenance of the BONNIE L. SMITH, RPR j

MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 4

v.y..

y

-.m.

8 authorization basis, knowing where you are, 1

knowing and having effective controls and programs 2

3 as you

- you know, the JCOs are, in their simplest form, an extension of the authorization 4

basis putting controls on you and your imposing 5

6 controls on yourself.

I'm not talking about the technical issues with regard to JCOs, but the --

7 8

but the management controls that you impose on 9

those.

10 Management should know where all these 11 controls are, know where all the compensatory 12 actions are.

And I would think, as effective 13 managers, you wouldn't want temporary conditions 14 and compensatory actions.

You'd want those to a 15 minimum.

Overall, I guess what we're saying -- I 16 guess what we've said in our letter and what I'm 17 18 trying to express is that we don't feel management controls today are providing you with the tools 19 1

20 you need to effectively manage this.

I feel that

)

21 the management in this room is committed to safe 22 operation.

I feel the management in this room 23 wants these plants to operate safely and 24 effectively.

I feel the management in this room 25 knows that the two have to go hand in hand.

And BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

9 1

that's why I have confidence in that.

It's the controls and it's the flow of your expectations to 2

3 all levels of management and employees that we 4

feel needs to be there.

It's an issue of our 5

confidence to do that.

6 So I guess here in a moment I'm going to 7

turn it over to USEC to share this with us.

But 8

it's our expectations that we can talk this 9

through enough that we do have a common 10 understanding of management controls and we can 11 hear enough of your intended plan of action.

We 12 need to see some near-term measurable schedules 13 and accomplishments.

I think that would go a long 14 way towards giving us the confidence we need.

And 15 the third one or the final bullet is you have to 16

-- everyone has to know who's accountable.

It has 17 to be somebody's task to make it effective.

18 Okay.

Now I'd like to -- I'm going to 19 request that we allow USEC to do their 20 presentation.

If there's questions of 21 clarification, I would like our folks to feel 22 comfortable in asking those.

I would not like --

23 I would like this presentation -- for them to be 24 able to go through it and then let's -- for issues 25 that we do not feel accomplish what we in the DOE BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

need to hear, we're going to caucus after their 2

1 2

presentation.

So I would like -- questions other than 3

clarification questions are to be basically held 4

5 to the end.

I do want it to be a -- I do want us 6

to understand it.

And I didn't want to say that 7

to say don't ask the questions, but I also want it 8

to be -- us to maintain control of the meeting and 4

9 allow this to process through.

10 Okay.

Before I go on, I'm going to ask Joe 11 Parks and Liz Teneyck if they have anything to 4

12 add.

And then I would like us to go --

I'm not 13 sure everyone knows everyone in the room, so I 14 would like us to go quickly around the room and 15 identify yourself.

So, Joe, do you --

16 MR. PARKS:

Well, I -- I'm a person that j

17 has two missions, one is to support certification 18 and then the privatization as an aim of the 19 administration.

I fully support that and will q

20 encourage all of our people to support that 21 activity with all haste.

22 I have reviewed some of Jackson's reports 23 and feel that -- I encouraged him to have this 1

24 action and I feel that the second part is just as 25 important as the certification.

And that is the BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS l

12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 i

11 i

providing a safe environment for those facilitics 1

i while it's still under the Department's watch.

So 2

3 I do support both of those missions.

I do think, George, that -- seeing your 4

staff here -- that the attention you're bringing 5

6 to this is very encouraging to.

And I think with i

7 that and our dialogue today and the follow-up 8

actions -- I think we can address the concerns 9

that the Department has at this time.

Thanks for 10 coming everybody.

11 MR. JACKSON:

Liz, do you have anything to j

i 12 add?

13 MS. TENEYCK:

Well, I just might say that 14 we're really here as observers today.

I think our comments have been included in the NRC observation 15 16 reports, and we just feel that it's important for us to have a good understanding of the issues to 17 aid in the transition of regulatory oversight.

18 19 MR. JACKSON:

Thank you very much.

20 Okay.

Do you want to go around the room 21 and identify yourselves?

)

22 (Whereupon the audience introduced themselves.)

23 MR. JACKSON:

Once again, thank all of you 24 for being here.

25 MR. RIFAKES:

We have a formal BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

- ~ ~ _

12 1

presentation.

But before we give it, I'd lika to make a couple comments or remarks.

I sincerely 2

3 apologize if we haven't instilled the confidence 4

in you that's necessary.

And I think that's 5

probably a failure to communicate on our part, and 6

hopefully we'll start that process today.

I think we've come a long way in the area 7

8 of safety and regulatory compliance at these 9

plants.

That doesn't mean that we don't have a 10 long way to go, because we clearly do.

You said 11 that you're not convinced that there are no 12 problems.

Well, we're not here to convince you 13 that there are no problems, because there are a 14 lot of problems.

What we'd like to do today is at least get 15 started on the road of convincing you that we're 16 aware of those problems and that we are putting 17 measures into effect that will address them.

It 18 would be naive to believe that we will ever be 19 20 perfect, because nothing is.

Our goal is to 21 constantly improve rather than a goal of 22 perfection.

If we set that, we'll probably miss 23 the target and people will get discouraged.

I think we've put a lot of things in place, 24 25 and you'll hear about many of them this morning, BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

13 that are going to move us in that direction.

It'c 1

no secret that the plants have been in a state of 2

3 flux.

We've had a lot of priorities, some of 4

which may appear to be competing.

We have three 5

priorities that we've tried to keep on a par and 6

tried to address on the par, probably not 7

perfectly all the time.

But this is what we've 8

tried to do.

9 Those priorities have been safe operations, 10 meet customer requirements, and get certified so 11 that we can come under NRC.

I'd be kidding you if 12 I told you that achieving those has not stressed a 13 lot of people, because it clearly has.

Because 14 the same people who are charged with one of those 15 issues are charged with the other two.

And we, 16 like everybody else, are quite eager to get the certification behind us so we can go on to the 17 18 day-to-day operations and concentrate more on the 19 other two priorities that we've had the allotted 20 time to do.

l 21 I say we've made a lot of progress.

As you 22 probably know, we have an outside group that 23 oversees operations at the plants and criticizes 24 us and advises us and rates us.

They've been in 25 business for about a year now, and at a recent BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

14 1

meeting they were asked, well, how are we doing; 2

what have you seen in the past year.

And they set 3

up a series of criteria which are kind of like the 4

INPO criteria, the criteria that INPO uses when 5

they rate power plants, and they go to many of the 6

issues that you're concerned with.

7 Their ratings were fairly frank.

They 8

said, you know, when we came in here and we looked 9

at these things with these plants in light of i

I 10 these criteria, we gave you a rating of two.

11 Today we give you a rating of five on a scale of 12 one to ten.

You don't even begin to get good 13 until you get to an eight.

And don't get sanguine about the fact that you've moved from a two to a 14 15 five.

It's the progress a person makes from when 16 he's born till he learns to walk.

You've got a 17 long way to go before you're mature, and it's 18 going to take a lot of attention and a lot of 19 work.

And we're fully aware of that.

I think the presentations that you hear 20 21 this morning are designed to put the progress in 22 some perspective.

That is, where do we think we 23 started?

Where are we?

Where do we need to go?

And what are some of the things we're doing to get 24 25 us there?

And on that, I'll just turn it over to i

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

15 1

Jim.

2 MR. MILLER:

For those of you that I 3

haven't met, I'm Jim Miller.

I'm vice president 4

of production with USEC.

So obviously this 5

meeting is extremely concerning to me, important 6

to me.

I'm greatly concerned that there's a -- I 7

think a lack of confidence in our regulator.

But 8

I'd like to just cover some things briefly and try 9

to convey to you my tone, how I look at this task 10 ahead of us.

I'd like to cover some things very 11 briefly because we have a tremendous amount of 12 information that the two general managers will 13 cover today that I think will shed a lot of light 14 on areas that we have failed to communicate.

15 Now, just a couple issues on some of your 16 comments, Dale, that I think were on target.

17 George stated it.

I'll say it another way.

I don't think there will ever be a meeting that I'll 18 attend that I'll be able to stand up and say that 19 20 we have no problems.

I just don't see that in the 21 equation.

There will always be issues to deal 22 with.

It's continuous improvement and no 23 different in this business than any other 24 business.

25 Given that, I think we've failed to BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

16 1

communicate and convey, one, the progress that wa 2

have made.

And I think today we'll make a strong attempt to do that but not let that be the keynote 3

4 agenda here.

Obviously not.

Additionally, we've failed to communicate 5

6 clearly where we feel we have problems and I 7

think, as a follow-up to that, what are we doing 8

about those problems.

So I think that's going to 9

be a big part of the message that we deliver 10 today.

11 So part of our purpose today -- I should 12 say a big part of our purpose -- is to, as Dale 13 said, educate, but, as well, make sure that you understand that we understand where our weaknesses 14 The areas we're doing well in we don't have 15 are.

16 to worry about too much.

But the areas we're 17 doing poorly in, those are the ones we've really 18 got to focus.

So with that, let me just very 19 quickly look at a couple issues.

20 Management controls.

It's a big issue and 21 I think we're going to speak to that throughout 22 the two general managers' discussions toaay.

23 Progress during the past two years.

There 24 has been progress made during the past two years.

25 But as well and most importantly, there are areas BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

17

-that we are not making the progress we would like 1

2 to and, in fact, should.

Path to the future.

That's where I have to 3

4 be satisfied, comfortable, as well as Dale and 5

Joe, that we have recognized the weaknesses and

?

we've formulated a path to take us to the future 6

that will improve these areas of weakness.

~

7 8

I just throw this up because my message 9

there is I understand you loud and clear.

I don't d

think that when we talk about management controls 10 1

-- when I think of management controls, I 2

11 12 immediately think of process because, in any situation, what's most important I feel to achieve 13 in concert 14 regulatory compliance is that USEC, f

with our LMUS operators in the field, have process 15 16 and follow that process.

If the processes are correct and sensible and appropriate and we adhere 17 to them, we're ninety percent of the way there.

18 19 So that's the issue.

Do we have process and what areas do we not have adequate process?

20 21 We're going to talk today about what 22 controls are there.

Are they adequate?

Are they 23 in depth enough?

Where are we on the life cycle 24 of those process development issues?

What are our 25 weaknesses?

We have weaknesses.

No question BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

18 1

about it.

We're aware of those weaknesses, and we're doing everything we can to deal with those.

2 3

Are we satisfied with the rate?

No.

We'll never 4

be satisfied with the rate of progress.

Have 5

there been improvements?

From my perspective, 6

absolutely yes.

And I think when you see some of the discussion from the GMs you'll see that there 7

8 has been progress.

But be aware.

We've tried to 9

de-focus our discussions on showing progress and 10 concentrate on where we are weak.

11 What additional controls have been 12 implemented?

There are a number -- and I won't go 13 into them -- but there are a number of new areas 14 that we have gone back, reassessed, and attempted 15 to reorganize, redefine, and in some cases, 16 eliminate and totally relook at.

And I don't want 17 to get into them because there are three or four 18 key ones that play I think to a lot of Dale's 19 chief concerns.

20 Very briefly.

Progrer,s.

I've thrown up about four areas that I submit to you we have made 21 22 progress in.

I'm not going to say much more about 23 it.

Problem reporting, formality of operations, 24 self-assessments and organization and 25 accountability.

I can turn the other edge of that BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

19 sword on all four of those and point out 1

weaknesses that we have not climbed tne wall over 2

3 yet.

Problem reporting is the front end of a 4

5 good, solid, corrective action process.

The back 6

end of our corrective action process is clearly 7

not where we want it to be.

So Dale and Steve 8

will speak to that in detail today.

9 Formality of operations.

I've been in 10 operations for many years, and I've seen a 11 distinct change in the six months that I've been j

1 12 here at USEC in the formality of operations.

But 13 I am not at all satisfied where we are today.

14 We've got a long way to go and recognize it.

15 Self-assessments.

I think Dale's spoken to 16 over the past few weeks and months in his 17 assessment of our ability to look at our own 18 actions.

19 And, very importantly, organization.

We have made a major, major organizational change in 20 21 these facilities for the positive.

It's one of 22 the best things we could have ever done.

23 And I just mention accountability.

24 Accountability, we will speak to both the positive reenforcement concerning accountability and we 25 BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

20 i

will also show you the negative aspect -- or, tho 1

2 negative reenforcement that we provide in the 3

accountability area.

Now, there has been 4

progress.

But, as well, there are a lot of areas 5

that we, as I said, are not there.

6 Additionally today I'd like to speak -- or, 7

I should say the GMs will speak to the path to the 8

future.

Because all of this history is nice and 9

the fact that we've made some progress is good, 10 but we have a lot of obstacles to climb.

And I 11 think to instill confidence in someone, in anyone, 12 we collectively have to believe that USEC has a 13 plan for the future to get us there.

14 Now, I'm not going to speak in detail, but 15 I'd just say that there are some key ingredients 16 to having a plan.

And I think the first is to 17 capture your priorities in one arena in an 18 organized fashion, and we call that our quality of 19 operations plan.

It's a constantly living 20

' document.

And, in fact, recognizing that we 21 haven't made the progress we wanted to make, we 22 are in a process as we speak of stepping back, 23 looking at that plan, and reprioritizing our 24 focus.

And the GMs will speak to the details of 25 that.

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

21 1

Compliance plan.

I don't need to say a 2

word about that.

Dale and Joe and the NRC 3

understand that issue.

And that's a big piece of 4

how we go forward and improve our operation.

Nuclear safety upgrades has been a 5

6 tremendous program, a tremendous program.

I've 7

been very personally involved and will continue to 8

be in the nuclear safety upgrade program, 9

capital / major maintenance efforts, to make every effort to ensure that we're getting the most bang 10 for the buck and that we're completing these 11 12 issues in a timely fashion.

But I think the path to the future can't be successful unless we have a 13 commitment to provide the capital and major 14 maintenance moneys as a corporation to improve the 15 material condition of these plants, because our 16 real success is going to be the ability to adhere 17 to policy and procedure and to bring the material 18 condition of these plants to the right level.

19 20 We operate in a unique -- somewhat unique 21 in comparison to the nuclear power plants -- a 22 unique relationship with USEC/LMUS.

And so the 23 question immediately comes up are we jointly and 24 collectively one organization focussed on the same 25 goals.

My answer to that is generally in the past BONNIE L.

SMITH, RPR HILLER & MILLER, COURT REPORTERS 1280' Union Road, Knoxville, TN 37922 Phone (423) 675-1471

22 l

1 I think the answer has been yes, but there's many 2

questions that we've asked ourselves.

And in l

3 doing that, George and I have talked to this 4

subject at great length along with LMUS, and we've 5

determined over the past few months that we need 6

to refine this further.

7 So we are in the process as we speak in 8

revising and refocusing the USEC/LMUS contractual 9

relationships specifically in the arena of how do 10 we incentivise an individual to reach the goals 11 that we want them to reach.

So I think that's 12 very important and that will be ongoing.

Every 13 year we will relook at what is our contractual 14 relationship; have we incentivised; have we 15 provided the right vehicles to get everyone to 16 move towards a common goal.

17 I've said a lot.

I want to keep my portion 18 of this very short, but I wanted you to understand 19 that I do, in fact, view this as extremely 20 serious.

It's my job.

It's what I do.

It's what 21 I'm here for.

And I echo George's comments that 22 certainly our recognition of our weaknesses are 23 there.

We focus on our weaknesses more than we 24 sit and brag and gloat over our successes at 25 whatever level they may be.

But there's certainly BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

23 a commitment from USEC and from myself to be in 1

these facilities, to be in touch, to be on board 2

3 with what's going on day to day.

And with that, I'll turn it over to our regulatory affairs 4

5 manager from the Portsmouth plant, Ron Gaston.

6 MR.RIFAKES:

Ron is going to address a 7

specific issue, Dale --

8 MR. JACKSON:

Okay.

9 MR. RIFAKES:

-- that has to do with the 10 authorization basis, 11 MR. MILLER:

Yes.

Ron will speak to the 12 authorization basis.

13 MR. GASTON:

Once again, I'm Ron Gaston, 14 the regulatory affairs manager at Portsmouth.

I'm 15 going to talk to,rou about the maintenance of the 16 authorization basis, mainly focusing on two areas, 17 one being compliance with the authorization basis and the other one maintenance of the authorization 18 19 basis.

20 The first thing I was going to talk about 21 is the emphasis on verbatim compliance.

Over the 22 last eighteen months, which is approximately the j

23 same time I've been at the plant, I believe we've 24 made a step change in our enforcement on the 25 verbatim compliance with the OSR.

And that's BONNIE L. SMITH,.RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

24 1

evidenced by the number of OSR violations that 2

we've reported since I started keeping the 3

performance indicators.

4 As you can see, in 1994 at Portsmouth we 5

had two and in '95 we had thirty three OSR 6

violations that we reported.

I believe the 7

violations were there.

We were probably just not 8

emphasizing the strict verbatim compliance with 9

them.

And as you can see from the numbers, to 10 date this year through the end of March those 11 numbers have come down.

I believe we've made a 12 lot of improvement in that area.

A lot of the 13 problems that we've identified with the OSR as 14 we've come to you and requested OSR changes.

We 15 have a similar experience in the FSAR compliance 16 as well, as evidenced by the JCOs and enforcement 17 disbursing that we've had to come to you with over 18 the past eighteen months as well.

19 One of the things that's really contributed 20 to that is the OSRs themselves as far as, at 21 Portsmouth at least, the format of the OSRs.

22 There was a tiger team evaluation in '91 and then 23 a corporate audit in '92 that essentially 24 identified the fact that the OSRs needed to be 25 revised in order to improve the compliance with BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

25 1

the OSRs.

Some of those revisions were prepared 2

and submitted.

Some of them were approved at 3

Portsmouth, but due to the closeness in time to 4

the OSR to TSR transition, we chose not to 5

imple,aent some of the improved OSRs.

So some of 6

those will simply be resolved through the 7

transition to the TSRs.

But, overall, I believe 8

that the compliance in the area of OSR -- both OSR 9

and FSAR compliance has improved over the last few 10 years.

?,

11 I'm going to talk a little bit about FSAR 12 maintenance, sort of starting with a little bit of 13 history.

I guess at the time of the ROA 14 development, the status of the FSAR revision or the current revision of the FSAR at the time of 15 16 the ROA development was an item that was known and 17 established.

One of the unknowns, though, was the 18 degree of conformance that the plant had or the

~

19 position that the plant was in as compared to the 20 FSAR, and that was an unknown.

1 21 One of the things we also know, and that j

22 I'm sure you know as well, is that the 23 infrastructure that we had in place for 24 maintaining the FSAR at that time and still is 25

. deficient in a lot of areas as far as the BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

26 procedures and processes for maintaining that I

f 2

current.

There-are some oths. causal factors that 3

are also responsible for the FSAR not being 4

'5 up-to-date.

And after reviewing the information 6

notice 96-17, which for thosa of you that are not 7

familiar with it, it was the information notice 8

that was written on Millstone for the FSAR not 9

being up-to-date and in compliance with the FSAR.

10 And a lot of those causal factors involve laxity 11 with the rigor for keeping the FSAR up-to-date.

12 And Fema of those causal factors we share as well.

13 The other thing I want to talk about there 14 is our review process for the NRC application 15 where it created a special case where we-16 identified a large number of discrepancies between 17 the FSAR and what we submitted in the SAR.

A lot of those were to update the SAR to the way the 18 19 plant currently was reflected as compared to the 20 FSAR.

I believe at Portsmouth our last revision 21 on the FSAR was in 1990.

So there were a lot of 22 differences and things that were not incorporated, 23 changes that occurred over time that were not 24 incorporated into the FSAR at that time.

25 Both plants wrote a problem report which BONNIE L.. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

27 1

essentially identified the fact that there were 2

differences that needed to be dispositioned and 3

resolved.

The formal process requires for the i

4 as-found conditions that we, one, do a screening 5

  • c determine if there is a potential USQ and the 6

other is to do an evaluation for each of those 7

conditions.

l 8

At Portsmouth the lack of priority that was I

9 put on performing that part of it prompted DOE to 10 issue us an order for action and complete that j

11 action in a reasonable schedule.

We had 12 informally done some screening on the problem

~

13 report when we identified it, not documented those

-e 14 evalutions, and didn't put the right priority on

'l 15 getting the formal evalutions completed.

i 16 Since the issuance of that order, I can 17 assure you that proper attention has been given to 4

18 that.

The safety analysis manager is reassigned, 4

\\

19 given temporary duty for and responsibility for 20 ensuring that evalutions are completed on 21 schedule.

And those evalutions currently are on 22 schedule for that.

23 I think by now you've received our response 24 to that order in which we identified twenty 4

25 potential USQs of the six hundred and sixteen j

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 i

28 identified discrepancies that wo had thera.

Wa'ra 1

2 also performing a review.

At this time we're finalizing that review to determine which of those 3

4 actually constituted as-found conditions.

In some 5

cases, there was some level of detail that was 6

changed from the FSAR to the SAR.

We're going 7

back and verifying whether or not those actually 8

constituted as-found conditions.

In some case, surveillance requirements and 9

10 the like that were in the FSAR were not carried 11 over to the SAR.

So we're going through and 12 verifying which ones of those were actually 13 as-found conditions currently.

And all of the identified items from that prior report were going 14 to be evaluated per the plant procedure, H-45.

15 And we have reviewed that procedure, and there are 16 sufficient controls in there for dealing with 17 18 as-found conditions.

one of the things we did note is that the 19 20 procedure in the process itself is essentially 21 geared for the as-found conditions as you discover 22 them.

The review and the transfer to the SAR 23 created sort of a special condition whereby 24 comparing the two documents we identified a large 25 number at one time.

So it kind of choked the BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

29 L

1 process a little bit.

2 In the area of maintaining the

~

3 authorization basis, the -- in the application, j

j 4

one of the things we did is formalize the 5

responsibility and assignment for making changes s

4 6

to the TSRs and the SAR which is similar to the 7

FSAR and OSRs currently.

And that assigns 8

basically myself and Bill Sykes with that i.

9 responsibility,

i..

10 We're also assigned the responsibility for i

11 ensuring that all the commitments that are i

12 contained in both of those documents are I

13 accurately flowed down into procedures and i

14 validated.

And there are some other j

I infrastructure items as far as control of design 15 16 changes and how those are factored back into the t

I 17 FSAR that are contained in the compliance plan

}

18 issue twenty three.

And the procedures to ensure 19 that all of those take place are covered by those 20 compliance plan items at this time.

l 21

.And, overall, I believe with these i

22 improvements and our current program that we have i

23 the necessary procedures either in place or 24 planned through part of the compliance plan to i

25 ensure tha.t the FSAR or the SAR is maintained i

I BONNIE L. SMITH, RPR 1

MILLER & MILLER, COURT REPORTERS j

12804 Union Road, Knoxville, TN 37922 i

Phone (423) 675-1471 4

.. ~

30 J

1 current and up-to-dato in the futuro.

That's all 2

I had.

3 MR. POLSTON:

Dale and I will talk about --

4 the main focus is the points you had in the 5

letter.

We have -- we've gone beyond that in some 6

instances in talking about a total assessment he 7

and I did in February and March where we came to 8

the conclusion we had some weaknesses where i

l 9

performance had been improving but it leveled off.

10 And so the stage we're in now is looking at 11 revitalizing the progress and turning that slope 2

12 of improvement back up.

13 So we have -- as Jim Miller and George has 1

14 said, we have a mixture of things that have gone 15 reasonably well, but we have some specific areas 16 that we feel like that we need to raise the slope 1

17 of progress and improvement.

And we hope to begin 18 to share that and convince you of that here today, 4

I j

19 Dale.

20 My part of this today is to focus on 21 procedures, focus on the procedures program, and 22 demonstrate to you some key management control 23 steps we have taken since April of '94.

And we 24 will share both some of the perceived weaknesses 25 and real weaknesses, as well as some of the BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

31 1

progress.

Back in '94 DOE's concern was primarily 2

3 with the procedures.

It had to do with the adherence of procedures and attention to detail.

4 Now, we did a lot of follow-up analysis on that, 5

and we determined there were two obvious 6

7 conclusions about procedures.

One was that the And 8

procedures were inadequate in a lot of cases.

then in a lot of cases, we simply failed to follow 9

10 the procedures.

So those two -- with those two causal 11 12 problems, we have taken a lot of strong steps in 13 the way of management expectations.

I just want 14 to focus in on this process here, not looking to 15 convey everything on that chart, but I want to 16 tell you conceptually what we'se done.

In trying to lay down a definition of a new 17 culture, the culture required with procedures and 18 19 other management controls, we have defined at Paducah, as well as Portsmouth -- we defined 20 21 management's expectations starting with the 22 general manager and our senior management team.

23 This is in the form of ten expectations here.

We 24 then asked every supervisor and manager at the 25 Paducah site to sign off on this.

So at this BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

32 1

point we have their signatures.

Now, I will candidly say, because someone signs it, it doesn't 2

necessarily mean they're going to always act on 3

4 it.

That gap does exist.

But it does say that if 5

someone puts their signature on the line that raises the stakes and that does raise the 6

7 accountability.

So we have our culture -- expected culture 8

from a total management expectation outlined in 9

this form with everybody's commitment in writing.

10 11 For example, on the procedure front, if you look 12 at this one, it says that we will -- our 13 expectation is that they will never fail to follow 14 a procedure or policy.

And if they encounter something wrong with the procedure, that the 15 reflex is to stop the job and get it fixed.

And 16 17 there's no penalty to stopping the job.

There's a 18 great penalty if you fail to do that.

So that's 19 our expectation.

We've seen some progress in that 20 area.

21 Now, we've driven this in a number of ways.

22 Let's talk about the Paducah and Portsmouth 23 disciplinary action.

One of the ways that we've 24 dealt with failure to deliver on those 25 expectations is our disciplinary profile.

And you BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

33 can see that at both plants in the last year that 1

we've had well over a hundred instances where we 2

have administered discipline to managers and 3

4 workers.

And a major part of this was failure to 5

follow procedures and failure to follow policy.

6 So this is one of the ways that we've accomplished 7

an improvement.

Our number one root cause at 8

Paducah a year ago was lack of enforcement.

We 9

have dealt very forthrightly.

We have dealt very 10 aggressively with that.

And I think I can show 11 you some positive results of that effort.

Some of the key steps we've taken that I 12 13 believe you're familiar with -- some of you are 14 more familiar with it than others, but just let me 15 touch on those briefly.

At both plants we do 16 what's called crew briefings.

Crew triefings are

)

17 a defined presentation that's directed at some 18 particular issue or a set of problems and it's 19 delivered by the senior managers going out into 20 the area and meeting with the first-line managers, 21 the first-line supervisors and their crews.

So 22 it's a small group exchange.

And in that we get 23 feedback from the workers as to what they're 24 seeing and what the problems are that they're 25 having in complying.

So crew briefings are held BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

34 1

by procedure at Paducah now.

Wa'vo found thoto --

2 we've institutionalized those now.

We've found 3

those to be very effective.

We do those quarterly 4

and do topics that are selected and ultimately 5

approved by me.

6 The drill program we took from Portsmouth.

7 Portsmouth started the drill program in 1993 --

8

'92/'93 and we got on to it a little late.

We 9

started in December of '94.

The drill program is 10 primarily going out into the areas with a design 11 drill that checks our workers on some phaze of a 12 procedure or policy.

So today we have that across 13 all the operating divisions, cascade, chemical, 14 power and utilities, and we do on the average of 15 one a week.

So we get a couple hundred of these a 16 year.

17 From my standpoint, one of the ways -- one 18 of many ways that I communicate from a management 19 action / management control standpoint is what I 20 call cultural observations.

Now, this is taking 21 fresh data out of our problem reporting -- the six 22 thousand annual problem reports -- taking current 23 data, looking at patterns and seeing what kind of 24 issues and trends may exist there that we need to 25 talk to the work force about.

So we write these BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

35 1

up.

We cito rsal data.

Wo cito four or fivo j

2 problem r.eports that support what I'm saying.

And 3

then we lay down my expectations in terms of 4

improvement and turning that around.

You're familiar with the sweep teams back 5

6 in -- after the enforcement conference, we 7

implemented sweep teams to try to define what's 8

wrong with our procedures.

We had teams go out, 9

walk down procedures to ree if they're defective, 10 to see if workers were using them, what have you, 11 to see the problems.

Once we profiled that, after 12 a while we understood the kind of errors that were 13 being made and the kind of flaws that were there.

We discontinued the sweep teams in favor later of 14 15 our problem reporting system.

So one of our 16 principal data gatherers now is that problem 17 reporting system and our walking around and 18 observing.

19 Some of the training that we've done 20 specific to procedures is shown here.

This term 21 LES is leadership enhancement series.

It's directed at our first-line managers primarily and 22 23 our department heads.

We have trained almost a 24 hundred and fifty managers and supervisors 25 specifically in the care and feeding and the use BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

36 1

of procedures and our expsctations.

And so their 2

job then is to carry that message to the last level, which is their crews in the field.

3 As their operators come through the i

4 J

5 training school for the two-week annual refresi'er, 6

we get -- so far we've done specifically two 7

hundred and ten e those people in training that f

J 8

has to do with the absolute requirement of-l 9

following procedures or stopping the job and 10 getting the procedure fixed.

We do fact sheets.

11 These come out of the procedures organization at 12 both plants.

And they help carry the message out 13 of the requirement and the necessity of following 14 and correcting our procedures as we go.

The new blood that was referred to in the 15 16 organization -- and this is the Paducah story.

i 17 Dale has a similar story at Portsmouth --

18 primarily this came about in the reorganization.

19 And I agree with Jim's comment.

I think we have 4

20 found that -- already found that focus that we've i

21 gotten out of that reorganization to be very 22 positive.

But, as you can see, many of these j

23 commercial nuclear people that have recent 24 experience in the nuclear power plants we have 25 hired and put in your top management positions.

4 i

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 j

Phone (423) 675-1471

37 1

Most of th :a w ra dono this year and most of them 2

are already on the job.

We have one exception to 3

that.

This gentleman here will come to Paducah 4

June the 1st.

He's from Grand Gulf, and he has a 5

background in conduct of operations and 6

maintenance in that facility.

7 So we've gotten a good bit of leadership 8

already from these people in our plant. We 9

continue to use the coaches for the mid level to 10 help us with the mid-level managers and the 11 first-line managers.

So our coaches -- we had a 12 staff of eight coaches, and those people have been 13 instrumental in helping us get out to the rest of 14 the management team.

15 I'd like to switch gears and talk about 16 probably the biggest effort -- s'ngle effort in 17 our procedures world.

And that is the nuclear 18 safety upgrade that "e're doing on upgrading 19 procedures.

And I know, Dale, this addresses one 20 of your questions about where are you cnd all 21 that.

We'll have to do a better job starting 22 right now of communicating on an ongoing basis 23 with you and the site reps as to where we are in 24 these programs.

25 At Paducah, back in November of '94, we BONNIE L.

S~A I T H, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

38 1

started the procedures upgrado program, the 2

nuclear safety upgrade.

So we've been at it about 3

eighteen months now.

We've identified almost 4

fifteen hundred procedures that primarily are 5

upgrade of old procedures, but in some cases they l

6 are new procedures that are being developed.

But 7

the great majority of them is upgrade of old 8

procedure.

9 And so where are we today?

Today at i

10 Paducah we have finished -- what I call finished I

11

-- seven hundred and thirty five of these.

And 12 these are in the field and they're being used.

13 These have been implemented.

So these are new 14 procedures -- of this number here, these are new i

15 procedures that are in the field and they're 16 working for us now.

And I'll talk more about how 17 the quality of those procedures is coming along.

18 We've got some information, data that will show 19 you something about the quality of those 20 procedures.

This is some other information about 21 procedures, but principally I wanted to show you 22 the total, wanted to show you that we have about 23 half of those already out there trucking for us 24 now.

At Portsmouth --

25 MR. JACKSON:

Do you -- let me just ask BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

39 1

you.

Do you hSvc c fcol for -- you'ra showing 2

you're halfway there.

Is that the easy half or 3

the hard half or do you think it's pretty 4

representative of half?

5 MR. POLSTON:

Well, it's -- my view is that 6

it tends to be the hard half done.

And, I mean, 7

the experience -- I mean, certainly we're 8

learning.

For example, a year ago, four months 9

into it I looked at the quality of the procedure 10 upgrade program.

After four months I stopped the 11 program.

Dale, in turn, stopped it at Fortsmouth.

12 And we called a halt.

We retrained.

We were not j

13 getting human factor considerations in, et cetera.

So I'm not saying that we have an easy path 14 15 from here on.

I'm sure there's some bumps in the i

16 road, but I feel like it's somewhat linear from 17 here on.

18 MR. RIFAKES:

Some of the requirements have 19 been changing too as we've gone through the 20 certification program.

So procedures were written 21 and redrafted to meet changing requirements.

And 22 that's why we're not quite as far along as we'd 23 like.

That's one of the reasons.

It's not the 24 only one.

It's just a massive effort.

25 MR. JACKSON:

Go ahead, Steve.

I'm sorry.

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

.gg MR. POLSTON:

Now, tho Portsmouth story is 1

4 2

similar.

They got kind of a late start, as you see here in November of 1996, a misprint.

But 3

4 they're really sprinting.

They've done well since 5

then.

I apologize to Dale for that misprint.

I 6

discovered it last night on my viewgraph and-7 didn't have an opportunity to change it.

i 8

MR. JACKSON:

He didn't mess his up though.

9 MR. POLSTON:

Thank you, Dale.

Dale 10 Allen's already pointed that out to me this 11 morning.

i But Dale has a similar number, almost 12 13 sixteen hundred identified.

And as of April of i

14

'96, the current status is that they have 15 implemented seven hundred and thirty three of

)

16 these procedures.

And you can see some other 17 efforts that are going there.

18 Now, I'd like to talk about how that's 19 doing.

I mean, the real question is not how many 20 you've done, but how good are they.

We walked 21 down a lot of these new procedures.

I mean, 22 that's one of my areas of emphasis as general 23 manager and one of Dale's.

I've been personally 24 active in walking down procedures.

I may not be 25 the best at it in the plant, but I raise the most BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

41 1

hall about it whnn I find comething I don't liko.

I mentioned we stopped the job.

We stopped 2

1 3

it almost a year age and held it until we got it 4

right.

We're really anxious that the quality of 5

these procedures be outstanding.

What we know at 6

this point is what I've shown here.

Out of twenty j

7 six procedures we walked down in April, my l

8 assignment to our senior managers was go out and 9

tell me -- come back and tell me -- walk these 10 procedures down.

At the end of April I want you 11 to tell me whether or not you've got the quality 12 that we feel is necessary.

Don't come back six 13 months or a year from now and say, well, bad 14 procedures, terrible procedure writers and et 15 cetera.

Tell me now.

16 So basically all of our senior managers 17 went out and walked down.

They had some criteria 18 to go by.

They had a folder.

They walked down 19 procedures.

And the message we came back with is 20 that we found one that we would consider 21 unacceptable out of the twenty six.

And we're not 22 happy with that.

And that leads me to -- you 23 know, that always leads you to the next level.

24 The next level is -- this one failure had to do 25 with flow down.

It had to do with a lack of BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

42 1

proper flow down.

So our next concern is how do we know our process for flow down of all the 2

things that are -- that we want in our procedures 3

is working at a high-performance level and working 4

5 the way we want it to.

So our next stop with our line managers is 6

7 to go back and calibrate all that flow down and 8

see that what we wan~ in there is all there, 9

criticality, safet ', TSR, OSR, everything.

But 10 right now, at both plants, we would say that the 11 technical quality of the new procedures seems to 12 be reasonably good on the whole.

What does that mean at the bottom line?

13 The bottom line, the Paducah data -- Dale will 14 15 have a comment I think on Portsmouth.

But what we saw -- this chart here shows errors due to failure 16 17 to follow.

Somebody didn't follow the procedure.

18 For some reason, they didn't follow the procedure.

19 So what we saw is -- as we brought the problem 20 reporting system up and we began to get the real 21 picture, we saw an expected increase in the number 22 of these instances where we had procedure errors 23 due to failure to follow.

And they got up around 24

-- you know, real unnerving for us.

For us it got 25 up around sixty or seventy.

Since that time, I

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

43 4

1 we've seen some improvement.

2 Now, I'm going to tell you in a minute 3

we're very dissatisfied with this flattening out 4

and that it's still not acceptable.

It's still 5

unacceptable to us.

But what we've done -- this 6

improvement that we have seen has come about for 7

several reasons.

One is we've driven enforcement.

8 And I think probably that's the biggest single 9

component.

The number one root cause at Paducah a 10 year and a half ago was failure to enforce.

They 11 knew what to do, but they didn't do it for some 12 reason.

So we're seeing that improvement.

i 13 Secondl'y, I would say work packages has 14 been an instrument in improving this area.

Work 15 packages are coming along.

Both plants are not 16 what we want to be.

The quality's still in i

17 question on the work packages.

We're doing a lot 18 of work packages.

That's positive.

Now we've got 19 to work on the quality, because we're finding that j

20 some of the work packages are incomplete.

21 The third factor there I believe has to do 22 with pre-job briefings.

We have stressed pre-job 23 briefings to the hilt.

And we have driven that 24 point home, that before you start a job, you're a 25 supervisor and you talk to the crew head-on about BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

44 e

1 what's in that work package and what they need to i

2 be doing when they're going out doing a job.

l 3

Don't just send them out, you know, with skill of 4

the craft or seat of the pants.

5 In this area here, this flattening out, 6

we're still high.

I think it's primarily due to 7

now -- it's not -- it's not somebody knowing they 8

should follow the procedure and not.

There's a 9

combination of human factors.

There are some root 10 causes we don't fully understand yet.

We're 11 working this problem.

We don't have the total 12 answer.

But the yardage gets harder as you come 13 down.

I'm just here to tell you we're not 14 satisfied.

We've got more work to do on that one.

15 Now, this next one is -- before I put it 16 up, I've got to tell you that it's not a 17 declaration of victory in any form.

It's a 18 recognition that some of the more onerous things 19 that have happened to us -- and, frankly, have 20 been terribly embarrassing to me as general 21 manager, gotten in the newspaper type of things, 22 cold feeding, leaks in the feed facilities, 23 corroded pipe, the whole litany of things -- is 24 we've seemed to have -- to begin to turn a corner 25 on that.

And that's what I want to show you.

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

45 i

7

\\

This is sort of a macro look at things I l

1 2

call big events with a-name, things that are 3

serious, that are a potential -- are or will be a 4

potential safety problem.

And they embarrass us.

5 We've had -- we've collected about two a year down 6

through time of these, and I think you're probably i

7 as painfully aware of that as we are.

For j

8 example, in '93 and '94, we had the 37 building --

)

I 9

we lost the entire building because we had a 10 leaking roof in a pump house and we didn't attend l

11 to our business.

We allowed a leak to persist and i

12 it finally bit us.

These things all self-reveal.

13 The 37 building shutdown I mentioned.

The 14 thrown line shaft -- a thrown line shaft on the 37 15 4.3 compressor, a case where we didn't torque the 16 bolts properly bit us.

It became an expensive, l

17 unsafe problem and it was a big embarrassment for 4

18 us.

The UF6 leak, I mentioned the corroded pipe.

I 19 We lifted a cylinder without disconnecting the i

20 pigtail, and that's not the way we want it to be

[.

21 done there.

And that one made the national scene, 22 that news.

And then the cold feeding.

f t

23 But in the last eighteen months I think we 24 have seen -- because of the improvement in the l

25 procedures, because of the management

)

e BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 4

4

46 1

expectations, management control, I think wa havo 2

begun to turn the corner on some of these things 3

that were just, you know, basically scandalous 4

events that self-revealed and things we didn't 5

catch.

I'm not saying -- we still have serious 6

problems.

We're a ways away from perfection yet, 7

but we're driving in that direction.

And that's 8

our intent.

But I think this represents some 9

progress.

I hope I didn't belabor that too much, 10 but I wanted to put it in perspective.

11 Now, Dale and I will come back to this 12 chart, and I'm just going to flash it up to let 13 you know we'll jointly come back after he finishes and we'll talk about what we believe are the 14 15 highest priority weaknesses that we have 16 remaining.

I'd like to introduce him in this 17 fashion.

Dale's going to talk about the 18 corrective action process this morning.

And I've 19 got a little bit of a Paducah version.

It also is 20 an introductory statement to Dale.

This is the way we view the corrective 21 22 action dilemma that we have at Paducah.

It's one 23 of mixed -- it's a mixed story.

Some cases we 24 have progress that is promising and other cases 25 we've got significant weaknesses.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

47 l

In terms of the senior management, overall 1

2 commitment I think is good.

I think that 3

commitment is good.

I think we need to drive that

?

4 out into the mid level and front line more than 5

what it is now.

The discovery part of corrective t

i 6

action is coming along in both plants.

I think 7

we've had in the neighhorhoed of six thousand d

8 problem reports last year and we're on that pace 9

again this year.

So I think that part of it is i

10 promising.

11 We're coming along.

We're certainly not 12 where we want to be, but we're coming along on are 13 these things closed; are you staying on schedule 14 with them.

It's one thing -- I mean, initially we 15 had this huge backlog -- and it's sort of like Ron j

\\

16 Gaston was saying in his area -- huge backlog and all of the sudden you're looking at the big 17 18 mountain and you're way behind on closure.

19 We're beginning to make some significant 20 improvements there, and we've come from about 21 sixty percent on schedule with those problem 22 reports and their disposition to a little better 23 than ninety percent.

And then the problem -- it I think 24 gets a little more unhappy from there on.

25 our root cause determinations in a gross sense BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

48 1

about a year ago were valuable initially.

For 2

example, we identified the lack of enforcement.

3 We picked 'the easy fruit there.

But now we've hit 4

a stage where that needs refining.

It certainly 5

needs refining.

And Dale will talk more about 6

that and what our plans are to improve that.

But 7

that's a mixed story, and we're not in a strong 8

position with our root cause.

9 Corrective action is -- I mean, I can't say 10 any more than I feel that we're ineffective and 11 immature at this point.

In the actual selection 12 of a fix for the problem and targeting those 13 action steps to fix it once, we consider it a long 14 way to go.

We've got work to do there as well as 15 the verification.

16 With that, I'd like to introduce Dale 17 Allen.

18 MR. CRUM:

Steve, June 3rd, what is that?

19 Is that a workshop?

20 MR. ALLEN:

I'm going to be talking about 21 that.

22 MR. POLSTON:

It is.

It's a two-day 23 workshop.

24 MR. JACKSON:

I know several of you all are 25

-- we're pretty packed in here.

I don't really BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

49 want to take a recess, but would a five-minuto 1

2 stand-up break and a rest-room break be welcome?

3 I see an enough head shakes.

Dale, if you don't 4

mind, let's take a very short break.

5 (A break was taken.)

6 MR. JACKSON:

Dale, I apologize for the 7

interruption.

8 MR. ALLEN:

I want to go back to the 1994 9

management conference as kind of a base line, 10 because in that conference, in addition to the 11 procedure and attention to detail kinds of things 12 that Steve has just talked about, there was an 13 expressed concern with the lack of timely 14 characterization and reporting of events.

15 There was a notation that we've had several 16 events that led to personnel exposures that 17 exceeded the plant allowable limits.

There was 18 disc 2ssion in that enforcement conference about 19 the lack of commitment to corrective actions and 20 unacceptable implementation of corrective actions.

21 And I'm going to sort of move forward from that 22 conference on a base line and address some of the 23 things that we have done, our current activities, 24 and then Steve and I will wrap up with a quick 25 summary of the assessment that he alluded to BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

50 earlier of our needed focus for change.

1 2

The problem reporting piece, which is that 3

sort of second step in the corrective action 4

piece, has had some pretty strong management 5

support.

Two kinds of things.

The general 6

managers, Steve and I, drove the implementation of 7

the problem reporting system starting in March of 8

'94, and then we had a strong support from the 9

quality assurance side of the house which 10 eventually led to the creation of an SS&Q 11 organization which reports directly to the 12 executive vice president and helps us maintain the 13 focus on the reporting -- both the identification 14 and the reporting process.

15 These numbers simply indicate that up to 16 the time we initiated the problem reporting system 17 both sites were running with fairly small numbers 18 of problem identifications and then, from March 19 on, much larger identification of problems.

The 20 current rate in '96, as Steve points out, will put 21 us both at six thousand or above problems 22 identified, which is an indication that 23 self-assessment activities, identification and the 24 surfacing of those problems has improved 25 significantly.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

51 1

We're going to address this issue.

We set 1

1 2

up a criteria for screening problem reports and 3

determining significant conditions adverse to

\\

4 quality.

And you see a difference in the two 5

sites.

And I think that's an area that we've been 6

working on and we'll talk a little bit more to it.

7 We recognize that difference and that is a part of 8

this mixed results in the development of 9

corrective action plans as Steve alluded to.

10 Following the 1994 conference, we did do 11 some specific kinds of things.

Root cause 12 determination was loosely done by half a dozen 13 different methods or not at all.

And we 14 established the use of a comprehensive process.

15 It's called tap root.

It's a licensed process.

16 It's licensed at both plants now.

We've taught a 17 number of people in that root cause determination 18 method.

We did improve the development of some of 19 our actionc through our proficiency with tap root.

20 We use it for the significant conditions adverse 21 to quality determination of course.

We trained 22 selected individuals.

We used some people to help 23 assist in the investigation of incidents and 24 problem reports.

And we saw some improvement 25 there.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

52 In the area of corrective actions, 1

certainly over the last couple of months since our 2

3 reorganization, we've refocussed the corrective 4

action planning process itself.

And I mentioned 5

we used the tap root to help us look at the' root 6

cause determination.

But one of the kind of 7

sacred cows, if you will, that existed certainly 8

in our plant to even greater extent than in 9

Paducah, although we had similar issues there, is 10 that we had a system that quality organization was 11 responsible for the -- for the quality of the i

12 corrective action plan, for the development of the 13 corrective action plan.

The line management was 14 in a support kind of role.

And we've shifted now to where the line managers are responsible for the 15 16

-- not only the problem report screening but the corrective action development and implementation 17 18 process.

19 For the last couple of months at the 20 Portsmouth f acility, we've adapted from lessens 21 learned at Paducah a process where our senior 22 managers -- line managers meet at seven o' clock in 23 the morning and review the problem reports and 24 then immediately go into a corrective action 25 review board where the responsible line managers BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

53 1

bring those things that have been selected in to r.

2 look at the corrective action plan.

However, even with those actions, with the things we've taken, 3

8 4

we've had mixed results.

And Steve and I will both talk to the efforts that we think need to be 5

1 6

done in that area.

I mentioned already that the reorganization 7

O 8

of both plants along traditional functional lines 9

to increase accountability for actions was i

10

' accomplished in the December '95, January time 11 frame.

We sort of finished that up in the latter 12 part of February I guess at both plants.

]

13 And at Portsmouth, as at Paducah, we have 14 made significant numbers of changes in personnel.

i 15 We've changed out fourteen key technical sen.or j

16 and middle management persons with people with 17 commercial nuclear or Navy nuclear background.

1 I

18 And you see this in critical technical support 19 areas, maintenance, engineering, operations and 20 some of the support organizations.

So there's 21 been a specific move to change the way we do 22 business, the formality of the way we do business, 23 with the change of personnel.

24 In some selected areas, we've made some --

25 some notable progress.

In other areas, we're not BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS f

12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

54 satisfied with our progress and our correctivo 1

2 actions.

If I go look at the autoclaves, the 3

thirteen autoclaves in the three feed and transfer 4

buildings, we've had a series of problems.

And 5

you're aware, Dale, of the things we've done to 6

focus on the problem reports and looking at the 7

problems there and developing changes to improve.

8 We've just completed this month a 9

reliability study of the data from the period of 10 May '95 through April of '96.

And, as a result, 11 we've looked at our autoclave material condition 12 improvement as one of the focus areas for us.

13 We've incorporated the strategies of pulling back, 14 moving faster with the NSU upgrades program.

15 We've developed specific corrective actions to fix 16 some of the safety-related problem reports.

We're 17 working to do an even more in-depth inspection.

18 And we've been pursuing PM standards to improve 19 the reliability on none-safety-related kinds of 20 things on the autoclave.

And that's an area I 21 think that we've made some amount of progress in.

22 As Ron mentioned earlier, if you look at 23 the OSR violation trend at Portsmouth, this was 24 about the period I guess I talked to you about 25 verbatim compliance.

And we started implementing BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

55 1

the verbatim compliance and we did hit a high 2

level of OSR violations.

And as time progressed, 3

we came -- we tended to trend down.

But this is 4

unacceptable from my standpoint because there just 5

simply has to be OSR compliance on the part of our 6

operations because some of the areas that we see 7

here are out of the human performance arena.

8 This is an area that I mentioned to you all 9

earlier, the personnel error and failure to follow 10 procedure in Portsmouth.

This indicates a renewed 11 emphasis in the January time frame on our part to 12 try to get below the surface, to collect data and 13 do in-depth screening using the tap root 14 methodology of procedural errors.

And I mentioned 15 to you at the last reg affairs conference, the 16 reason that's of concern, if you look at our 17 problem reports, this indeed indicated an intent 18 to drive the problem reporting even deeper.

But 19 if you look at our total scheme, you see that 20 human performance problems represents the bulk of 21 our problem report areas.

22 The bottom one is the failure to follow 20 procedures.

This is a whole series of things.

24 And we use the -- again, using the methodology I 25 mentioned earlier to examine that.

And you dig a BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 I

l

56 1

little deeper into that, you see the human performance, personnel error kinds of trend codes, 2

inattention to detail, improper work practices, 3

l 4

inadequate communication in terms of pre-job 5

briefs, shift turnovers and scheduling and failure 6

to follow procedures.

That's the four big contributors to the things that we find in the 7

8 problem reports system.

We recently had a session with middle and line managers because our analysis 9

10 is that this is middle and front line manager 11 work, the enforcement of those kinds of things.

12 If you dig into the failure to follow 13 procedures a little deeper, do the root cause 14 analysis on just the failure to follow procedures, 15 this is the kind of picture that you see.

The biggest contributor over the first three months of 16 The 17 the year is enforcements less than adequate.

18 next biggest contributor is that management's not 19 strict enough in the enforcement of the standards.

20 The next biggest contributor is management's 21 accountability is less than adequate.

And that's

-- that comes out of looking at those individual 22 23 problem reports and racking them up.

So it says 24 that we've got some significant problems.

The OSR 25 violation that we had April the 26th here just a BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

57 i

I few days ago is a stark example of that pattern.

2 I'm' going to talk about that a little bit later.

3 Here's just sort of a graphical summary of 4

Portsmouth.

All this says is that we continue to j

5 take about twelve thousand urine samples a year.

6 So we're still, of course, looking at the -- at 7

the process.

This is samples requiring action.

8 This blip here in '92 is as a-result of heavy HEU 9

suspension work and it's an anomaly.

This is 10 probably a more honest pattern -- or, a more 11 practical tract because this is an unusual 12 circumstance.

13 But in '95 you see that the number of 14 actions -- in '94 we had twenty six urinalysis 15 samples that required some kind of a follow-up 16 action.

There was some anomaly.

You had to go 17 look at it.

In '95 there were only six.

So a big 18 drop in the performance of the program.

19 And in terms of people being restricted, in 20

'94 there was only one restriction.

That was an 21 anomalous issue.

The person had a one-time sample 22 that wasn't attributable.

It may have been a bad 23 sample.

And in '95 we've had -- and in '96 so far 24

-- we've had no restrictions.

So we think at both 25 plants we've been successful in that particular BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

58 1

area.

)

2 Of course, you're aware that both plants 4

3 continue to focus on the personnel lu]ury 4

business.

The lost workday cases in '95 for j

5 Paducah were 1.1.

At Portsmouth they were 1.6.

4 6

The recordable illness and injury rate at Paducah 7

was 4.5.

At Portsmouth it was 3.5.

Both plants 8

continued to show a trend and that's the trend in 9

recordable illnesses and injuries at -- this I

10 particular one is Portsmouth.

The Paducah chart i

11 looks the same.

RIIs continue to come down.

Lost i

12 workday cases continue to come down.

So we 13 believe we're continuing to maintain the emphasis 4

4 14 on people working safe from an industrial safe 15 standpoint.

16 The big issue really comes out of this 1

17 chart that Steve talked about in the corrective 18 action process.

At Portsmouth we're a little

~

19 behind Paducah in problem / issue tracking.

And 20 we're a little behind them in the root cause 21 determination and I think a little bit behind in 22 the enforcement arena.

We're in total agreement 23 that from here on up in the corrective action 24 process, the back end of the process if you will, 25 that we need a lot of work.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS f

l 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

59 1

We have developed an action plan of what to 2

do.

I mentioned that we have our senior managers 3

reviewing the corrective actions themselves and 4

are responsible for the implementation and the 5

verification of completion with checks by external r

6 folks. 'But we believe that there's a deeper sort 7

of learning and effort that's got to be done.

We 8

have worked out between Paducah and Portsmouth a 9

process.

On June the 3rd we're going to have a 10 two-day workshop run by professionals with Steve 11 and some of his line managers and me and some of 12 my line managers together to look at root cause 13 determination to see if we can't strengthen how we 14 decide what it is we're going to do, also to work 15 on our philosophies and sorting of the significant 16 conditions adverse to quality so that we can have 17 focus on the right kinds of things.

l 18 We've committed in an action plan that's in 19 our business planning system and in our QOP to 20 review the organization, to review the corrective 21 action -- to change the corrective action 22 procedures, to do an additional round of tap root 23 training with selected line folks, to do a 24 corrective action audit and an operational 25 evaluation program audit -- the lessens learned BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

=-m-ein i

,q 60

)

'l program -- in October of this year and, in fact, to relook at the entire corrective action process 2

a 3

to continue to break down what probably is endemic 4

in our culteral organization to continue to l

l 5

improve that.

By working through the process that l

4 f

6 I just stated, I think it will not only give us a 7

joint commonality of philosophy and process, but 8

it will take advantage of the lessens that have j

9 been learned between the two plants and allow us i

10 to move a little faster..

j 11

'As you said, change is hard, and there are j

12 some additional kinds of things that have to i

13 happen.

Steve mentioned some of the things that 14 are already in progress, but we think there-are 15 some additional focus areas.

Specifically -- I'll 16 use an example -- at Portsmouth adherence to 17 policy and procedures is paramount.

It's a cycle 18 of you have to get the procedures right and you 19 have to enforce the use of those' procedures and 20 you have to enforce people attending to the rules.

21 The recent OSR violation at Portsmouth led 22 to severe disciplinary action for a middle 23 manager, a front line manager, a systems engineer, 24 and'an operator.

In fact, we took that particular 25 issue and we called our middle managers together BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 i

Phone (423) 675-1471

61 1

and went through the particular event.

And our 2

middle managers, specifically those targeted at 3

those nuclear areas, were asked basically to 4

commit to enforcement, adherence of TSR and OSR 5

requirements, and to enforce the expectation to 6

adherence to procedures and requirements and their 7

responsibility for immediate notification and that 8

they would convey those expectations to the front 9

line managers who work for them.

But the 10 conveyance here was for them to say back to me 11 that I do understand that people make honest 12 mistakes, including myself and my subordinants, 13 and that the goal is identification and reporting 14 and fixing, not disciplinary action.

The goal is 15 to ensure that you're increasing the margin of 16 nuclear safety.

These milled managers were asked 17 to commit or to resign.

And the folks that are in 18 the nuclear business in that area have all 19 committed.

20 MR. JACKSON:

Dale, why did you 21 specifically focus on the middle managers and 22 below and not include everybody?

23 MR. ALLEN:

We had -- we have done a 24 similar kind of thing in the upper management 25 ranks already.

And if you go back and look at BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS

'12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

62 1

this issue of enforcement, strictness and i

f 2

accountability, we were looking at the particular 3

people that are able to effect that adherence to t

4 that policy.

5 We also ran this in our Open Line -- this 6

story in our Open Line on Tuesday of this week, a i

7 front-page article, to try to bring to the 8

attention of the people the real details of the I

9 incident.

This article talks about the fact that 10 an operator failed to make OSR required log 11 entries.

He made the -- logged missed entries at 12 the next reading time in the presence of a 13 front-line manager and a systems engineer without i

i 14 noting the entries as late.

Neither the senior 15 management nor the PSS office was notified as 16 required by the problem reporting procedure.

It 17 explains why the middle manager was removed from j

18 management, why the front-line manager resigned on 19 the -- he resigned on the spot as we began to talk 20 about the issue.

The systems engineer received a 21 written reminder for failure to follow the 22 requirements of the problem reporting procedure.

23 The bargaining unit operator received unpaid 24 crisis suspension and decision making leave for 25 failure to make required log entries and for his i

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

63 failure to voluntarily disclose that he had not 1

2 made the required log entries.

3 Now, two good things came out of this.

The 4

good thing was that the system engineer 5

volunteered to teach the problem reporting system J

6 and this incident to the systems engineering and 7

technical people by the end of this month and is 8

in the process of doing that.

The other thing 9

that came out of this that could not have come out 10 of it two or three months ago is that -- of l

11 course, we have a labor contract at Portsmouth now 12 as I think everybody's aware.

And when this 13 particular issue was levied, we had to look at the 14 operator in question and his experience.

He's a 15 person who has filed problem reports in the past, 16 which we appreciate and recognize, and that was I

17 kind of a mitigating circumstances.

18 The other mitigating circumstance is that 19 the union official and this operator are out in 20 the plant on shift telling this story and teaching 21 a prescribed set of log keeping things to the 22 people that have to keep the logs.

The union 23 officials I believe started yesterday.

And this 24 gentleman that received this disciplinary action 25 starts tonight.

And that was an agreed upon this BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 l

I

-.m.

1 64 I

1 is what we will teach in terms of log keeping.

i 1

2 2

And that has more impact on the peers on the floor j

i i

I 3

than probably anything else.

But it certainly is l

4 a step that's required.

5 The next step that's required has two i

6 things to do with.

One is the quality of 1

7 procedure and where we are in the procedures e

1 8

program.

And the second is adherence to 9

procedure.

And its in the OSR to TSR transition 10 phase.

Once you come out of the TSR transition, 11 once you implement the procedures that are i

12 required for the implementation of the TSRs, now I

13 you truly are through the hard part I guess you L

14 would say of the procedures within the safety

)

5 i -

15 umbrella.

The next piece is you want to make sure 16 that you adhere to those procedures through that 17 process because you are trying to make sure that 18 you are bringing a capstone to any kind of

]

i j

19 culteral change you're trying to do.

20 This is the OSR to TSR transition at i

21 Portsmouth.

That's similar at Paducah.

Just the i

22 names are different.

Our plan is to change in 23 three -- in three phrases and seven-oh-five, 24 three-forty complex cascade withdrawal and then 25 maintenance and support.

Sometimes a procedure i;

)

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 i

1

65 1

carries across facilities, so we broke those out 2

separate.

Sometimes they're specific to the 3

facility and sometimes they carry across the 4

facilities.

5 This is an indicator of the number of 6

procedures that are involved.

There are two 7

hundred and ninety nine procedures in that TSR 8

implementation on the floor that are involved.

9 And there's the number of people that are 10 involved, roughly five hundred people.

And 11 there's an implementation steering team for the 12 OSR to TSR transition at both of those sites, Ron 13 Gaston at our site and Jerome Mansfield at the 14 Paducah site.

They've been meeting and underway j

15 for several weeks.

Training on some of those l

16 procedures is already under way.

17 There's going to be an oversight team used 18 at the two plants there on the floor with people 19 when they're implementing the procedures with 20 people that are experienced with the TSR 21 requirements to make sure that people on the floor i

22 get immediate feedback.

The best performance 23 indicator to the guy on the floor is immediate 24 feedback so that you don't have to collect 25 performance indicators over three or four months.

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

66 1

We're also committed to doing performance 2

indicators so that we can transfer this learning 3

to the other processes and feed back and forth 4

between the two plants.

5 The change process will have to continue 6

and will have to be nurtured in a number of areas 7

for assurance that we continue to see improvement 8

in management controls and that we continue to 9

engender a thought process, a mind set if you 10 will, all through the organization for an increase 11 in the margin of nuclear safety.

12 Work control's been mentioned already.

We 13 believe that in December of '95 when we 14 reorganized the plant along functional lines we 15 captured work control at both sites in a major 16 organization role so that we can not only 17 integrate and utilize our resources correctly, but 18 we think it helps bring -- with the proper 19 emphasis on continuing to improve planning to 20 getting all of the things lined up before you do 21 the jobs.

Now, we've got a lot of problems in 22 that area.

We've got a heck of a long way to go, 23 but I think that's the right step.

24 We've learned some hard lessens at 25 Portsmouth from the view of management control and BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

67 1

accountability.

And they're lessens that I'm not 2

particularly proud of.

I'm like Steve with my 3

incidents with a name, and they don't seem to go 4

away.

We shut the seven-oh-five facility down in 5

November of 1994.

The trigger cause was the lack 6

-- an operator improperly using logs, in this case 7

not doing required calculations before the thing 8

was -- before he ran a particular operation and a 9

supervisor letting him.

i 10 But when we went into seven-oh-five, there 11 were a massive number of difficulties.

The 12 criticality safety procedures were inadequate.

13 The operating procedures were inadequate.

There j

14 were even hardware changes that we had to make.

15 We had that facility down for months before we 16 were able to get that facility operational again.

17 The PEH compressor -- I sometimes call it 18 the PEH compressor incident in June of '95 where 19 we didn't do proper prior planning and we simply 20 accepted the way we'd always done things and then 21 operated from an emergency standpoint.

And that 22 was a long and arduous process in terms of looking 23 at our management control things.

24 This OSR violation that we've just had is 25 another example of the need to increase rigor and BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

68 1

discipline.

And we've done that in some of our 2

processes.

In work control we're beginning to 3

increase the discipline.

In production support 4

when we reorganized we pulled health physics, the 5

quality control and the laboratory support kinds 6

of functions together so that you could bring 7

focus to those.

The technical integration and 8

engineering of the safety disciplines that you 9

need to get the technical design basis, make sure 10 that you are integrating those kinds of efforts, 11 we've improved those processes.

12 The plant operational review committee is 13 the safety committee that looks at the things that 14 are coming out of staff to make sure that we're 15 staying within the licensing basis, that we're 16 looking at safety things.

We have a management 17 analysis and assessment team and a corrective 18 action review board that works for them that's 19 looking at the corrective action system.

20 We recently implemented a mid managers 21 morning meeting.

At eight fifteen all the nuclear 22 middle managers get together and look at the work 23 control input, the problem reports, and the things 24 that they have to do so that that is coordinated.

25 In the communication arena, the floor level BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

69 1

sessions that Steve mentioned of us communicating 2

with people, problem reporting is the flow up.

3 Commitment letters from people at least indicate I

4 that they are willing to accept it.

But even with l

5 that rigor and discipline, we have a long, long 6

way to go.

And Steve and I, as he mentioned --

7 Steve, you might want to help me go through this.

8 In February and March, we looked at -- we did an 9

assessment of our quality of operations plan.

And 10 when we assessed the activities, we went out and 11 looked at the as-found condition against the plan.

12 Although we were meeting milestones, we didn't see 13 the results in some of the areas that we felt like 14 we needed.

And do you want to address the plan?

15 MR. POLSTON:

Yeah.

One of the things that 16 17 MR. RIFAKES:

You might tell them what the 18 symbols are.

19 MR. ALLEN:

Oh.

Red's bad.

Yellow is not

\\

20 too good.

And green means we're satisfied with 21 it.

22 MR. RIFAKES:

And the triangles?

23 MR. ALLEN:

And the triangle is some 24 indication of whether we think it's getting better 25 or worse.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

70 1

MR. POLSTON:

We looked at probably tho 2

same thing in the as-found on the floor.

So we 3

replicated Portsmouth on that.

But we also looked 4

at both plants at whether we were on schedule with 5

the quality of operations plan milestones, and 6

generally plants were.

So that said it wasn't a 7

matter of not doing those things.

It was either a 8

matter of we picked the wrong things -- and, 9

generally, we picked our action step -- or 10 corrective action was not tuned precisely to the 11 problem.

And so that led us back to where we are 12 now.

13 For example, here on the upgrading the 14 corrective action program, we found that the action plans themselves is not green.

The action i

15 16 plan that we had relative to the corrective action 17 program was weak.

We also found naturally then 18 that our results on the floor were not there, 19 partly because the plan itself was faulty and 20 partly because it was lagging behind -- even 21 lagging behind the plan.

So what Dale has 22 described as the major effort that we're 23 undertaking now to revitalize our corrective 24 action, a piece of that is the June 3rd and 4th 25 get together of the two plants to work the issue.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knonville, TN 37922 Phone (423) 675-1471 i

~.

I 71 I want to go back to reexamine our root 1

2 cause.

I want to reexamine the root cause 3

process, and we already know there's some fine 4

tuning that needs to take place in that.

So i

I 5

that's going to be an important time for us i

6 because, obviously, you can't have a weak root 1

7 cause.

I mean, you can take all kinds of actions, 8

but they're not tuned and they're not focussed.

I 9

They're not on the target.

So we're going to come 10 away from that period, at the second, third, and 11 fourth meeting with a new refined approach to 12 corrective action.

We're bringing in some outside 13 people to help us.

We've got people from both i

14 plants.

Portsmouth's coming to-Paducah.

So that 15 will be a very key time for us.

16 MR. ALLEN:

We've been in the process of 17 revamping the plans.

Steve and I met in the first 18 of March to take a look at the two plants and our 19 different problems and that is a joint list.

20 There's one different at Paducah, the --

21 MR. RIFAKES:

Do you want to quickly run 22 down what those are?

23 MR. ALLEN:

Sure.

24 MR. RIFAKES:

I don't think everybody can 25

' read them.

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

72 1

MR. ALLEN:

But it's a joint list.

We 2

agreed upon this between the two plants.

Improve 3

procedure quality and compliance; implement 4

upgraded, technically self-sufficient NCS program; 5

prepare GDP organizations to operate effectively 6

within NRC regulatory environment; effective 7

self-assessment; corrective action program; 8

evaluate and improve UF6 cylinder handling at the 9

GDPs; improve conduct of ops and maintenance; 10 implement upgraded technically self-sufficient 11 safety analysis and review programs; backlogs of 12 material condition deficiencies; improve the 13 maintenance work control process; develop teamwork 14 with the GDPs; and the OSR to TSR transition.

15 That's what we viewed as our top items for 16 success.

We started with a large number of items 17 18 MR. POLSTON:

About a hundred.

19 MR. ALLEN:

-- about a hundred and focussed 20 down on these so that we could direct our 21 activities on those things that we thought were 22 critical to our success in an attempt to focus our 23 resources and efforts on that particular piece.

24 Our staffs have been working on these plans now 25 since March --

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

73 1

MR. POLSTON:

Early March, yeah.

2 MR. ALLEN:

-- early March, February / March 3

time frame, and the meeting that Steve mentioned 4

is where we're coming together to take a look at 5

those to give them a sanity check to see if we 6

believe we have created a better action plan in i

7 view of the assessments that we have made.

8 MR. PARKS:

Dale, you might as well mention 9

the scheduling and execution of floor level 10 communications that will be kicked off in the 11 coming weeks.

12 MR. ALLEN:

Oh, I'm sorry.

Yes.

We've 13 been -- at Portsmouth and Paducah, we have been 14 working on a presentation that will be -- at both 15 plants will include Jim Miller and at Paducah is 16 led by Steve, at Portsmouth myself, with a message j

17 that we're going to take to these five hundred 18 people at Portsmouth and similar -- I think there j

19 are a slightly fewer number at Paducah -- that we 20 are going to deliver in small group sessions, 21 twenty to twenty five people, the importance of 22 the process in the OSR to TSR transition and the 23 implementation.

And we've set up scheduling and 24 that sort of thing to correspond to this 25 transitional phase.

i I

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

-~

74 1

1 MR. POLSTON:

A significant time there, f

1 2

too, for us in that we will sit with small groups, 3

I will, and I'll talk to them about not only what 4

-- not so much what and how we're going to do OSR 5

to TSR but why.

We've failed in the past to 6

really make people appreciate why the OSRs are so 7

important.

We want to take this opportunity -- we 8

think it's a great window of opportunity to ger 9

people tuned in on the relevance and why it's a 10 pivotal point for them and the plant to be in 11 total compliance with the TSRs as time goes on.

12 So that will take about thirty meetings to get all 13 those in.

So it will be a lot of small group.

14 meetings and we're using it as a big opportunity.

15 MR. RIFAKES:

I guess I'll wrap up.

One 16 question you asked was a question of who's in 17 charge of all this stuff.

I guess, if I talk to 18 my bosses, in the final analysis it's me -- but 19 that's not the answer you're looking for -- then 20 move down to Jim.

Reorganization was intended in 21 great extent to start identifying people who are 22 in charge.

23 The prior organization, I'm sure, had a 24 purpose and it met its purpose and outlived its 25 usefulness.

What it did do that I found 4

BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

~

75 1

troublesome was it tended to get us into matricos 2

to organize and run things, because we had 3

responsibility for functional areas disbursed j

4 across the plant.

What we've tried to do is 5

reorganize on a line basis where the line has f

6 authority and the responsibility to do things.

l 7

And we're starting to identify accountable people, f

8 And you've heard a little bit about that en who is 9

accountable.

10 We have not fully eliminated committees.

I 11 don't think it's a good thing to fully eliminate 12 committees.

In some areas they're appropriate.

13 But line management functions belong to 14 individuals.

And that's where the responsibility 15 is going to be.

And if you look at the 16 organization chart, some of the areas responsible 17 and the people responsible for the things we've 18 been talking about fall out relatively easily.

19 We started that in December.

I'm not 20 satisfied that we have fully implemented 21 everything.

We've implemented as far as we had 22 intended.

We plan to review it again and see 23 whether we should take it even further into the i

24 organization.

That's something that's on the 25 agenda for sometime later this year.

i BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

76 You've heard us talk a lot about our 1

2 concerns with ocr corrective action process.

3 That's clearly high in our scheme of things to do.

4 It's not only our concern.

It's your concern.

5 The PPRC, that's all they're talking about these 6

days is the effectiveness of corrective actions.

7 And they're giving us suggestions on what to do 1

8 about it.

9 Along with improving the process what we're 10 still lacking I think is a good measurement 11 process to measure the effectiveness of corrective l

12 actions.

I mean, you can go back and look and we 13 can do it kind of on an ad hoc basis, but we 14 really need to set up some measures to quickly 15 tell us where we're going and give us trends so 16 that we can early identify problems.

l 17 On the PPRCs, I trust you're all familiar 18 with the group that we have that's principally 19 outsiders with -- outsiders with operating and 20 regulatory experience advising us, bringing 21 lessens learned from other areas into the process.

22 We are adding another former regulator to that 23 committee in an attempt to even further emphasize 24 some of the processes that we have to identify and 25 add.

BONNIE L. SMITH, RFR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

77 1

And we're also refocusing the cor.mittee.

2 The committee for one year spent its time just 3

kind of taking a general look at the plants and 4

becoming familiar with the operations, because 5

they are unique and not many people had the 6

experience with what we're doing.

They've done 7

that now, and we are going to focus them on 4

8 specific areas.

For example, corrective action 9

will be one of the areas.

Procedure adherence 10 will be another area.

The safety cultures is 11 something that we need to get ingrained into 12 people.

It's something we talked about that still 13 isn't there.

14 A question was asked why the agreement to 15 adhere to procedures and to follow all these rules i

l 16 was not signed by upper management at the plant.

17 I've been fairly well convinced for some time that 18 the senior level managers understand the mission 19 and are committed to it.

I've also been convinced 20 that that word, although there's been a lot of 21 talk about it, has not filtered down into the 22 lower levels.

23 You hear talk about glass ceilings and how 24 people can progress so far up and they see the sky 25 but they can't get to it.

I think in these plants BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

78 1

we have a glass floor where we talk down there and 2

they kind of hear the noise, but nothing happens 3

beyond the talk.

So the focus, both in terms of 4

communication, the things that Jim and the plant 5

managers are going to do, is now getting down to 6

that working level.

7 The focus on strict adherence and requiring 8

people to adhere to the rules is being pushed 9

down.

Putting som? thing in the plant 10 communication that says scmebody violated 11 procedures and here are the consequences is a 12 message that we have to get out.

We have to get 13 serious about this stuff.

We have to get people 14 to realize that we're serious.

So that's why the 15 push has gone now from upper management, which is 16 something that we worked on and talked about for 17 the last year or year and a half, down to the 18 floor where the action is.

19 I personally think that we've made 20 progress.

And I think it's relatively 21 significant.

There's a lot to do.

A lot of the 22 commitments that you're looking for, Dale, I think 23 are already in the compliance plan.

When are we 24 going to finish the procedures upgrade?

When is 25 the proper training going to be in place?

Those BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

79 1

are things to do.

They're ongoing things and 2

they're yet to do.

So I'm not sure quite what j

3 you're looking for in some of these areas.

But 4

our commitment is -- and I think the presence of 5

the people here and hopefully these presentations 6

-- is to keep improving this process.

7 MR. JACKSON:

Thank you, George.

Our plan 8

at this time was to --

9 MR. PARKS:

Can I ask George a question?

10 MR. JACKSON:

Sure.

11 MR. PARKS:

He and I have touched on this 12 conversation from time to time.

You know, the 13 whole organization -- I guess all organizations 14 involved that you operate have been under a lot.of 15 pressure to produce a lot of paper, produce a lot 16 of changes, your organization to produce a product 17 that you can competitively market.

Are we 18 beginning to see some burnout?

19 MR. RIFAKES:

Yes.

I mean, I'd be lying to 20 you if I said no.

I mean, not only on our side, 21 but on everybody's side.

This has been a very 22 rigorous exercise.

It's been compressed.

And 23 there are people that are burned out.

There are l

24 some people that have asked to be relieved of some 25 of their duties because of this burnout.

And we i

BONNIE L. SMITH, %PR MILLER & MILLER, COURT XEPORTERS 12804 Union Road, Knoxv'.11e, TN 37922 Phone (423) 6/5-1471

l 80 1

are -- you know, within the resources, we are 2

trying to staff this thing.

We've brought in 3

outside help to the extent that it's useful.

4 Im concerned that it isn't over.

I mean, 5

take the certification, the day we get certified, 6

there's a whole knew series of knew work that's --

7 actions that we're going to have to take on.

I'm 8

concerned that we have several thousand people 9

that are transitioning from OSRs to TSRs, from one Ib set of objectives to a different set of 11 objectives.

I'm concerned, you know, that isn't l'd going to happen easily.

There are going to be 13 mistakes.

There are going to be people burned 14 out.

There are going to be people replaced.

It's 15 just the process that -- but it's there and we're 4

16 there.

We have to live with it.

There's no 17 getting away from it.

18 MR. PARKS:

You all don't feel that that's i

19 in any way affecting the overall safety of the 20 facilities?

21 MR.RIFAKES:

We do not.

22 MR. PARKS:

That always concerns me.

23 MR. RIFAKES:

You know, burnout comes from 24 a lot of reasons.

Expectations that aren't always 25 met is part of the burnout.

I mean, there are i

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

81 1

people that had hoped we'd be farther along on all 2

these things we've talked about.

And people have 3

their highs and their lows.

And a guy who. feels 4

burned out today gets a job completed and he's 5

re-energized.

We've seen some of that.

6 But as far as the plant operations are i

7 concerned, I mean, I think what they've been 8

telling you is that we're increasing the emphasis 9

on the safety.

We're not going backwards.

And, 10 you know, I regret there's a lack of confidence on 11 Dale's part on that because I don't think it has a 12 basis in fact to be honest with you.

13 MR. PARKS:

I think we're just reading our 14 instruments.

15 MR. RIFAKES:

Well, there are so damn many 16 instruments out there though, Joe, you can't be i

17 reading all of them.

And that's what we're trying 18 to tell you.

I mean, we have people here that are 19 committed to run these things safely and to 20 improve them.

And it would be nice if we could 21 have taken a snapshot of these plants over the 27 last several years to see whether they're going up 23 or down.

I'd be willing to bet my last bottom 24 dollar that the trend is upwards, not down and not 25 flat.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 1

Phone (423) 675-1471

82 1

MR. PARKS:

I concur with that.

2 MR. RIFAKES:

Well, that's -- you know, the 3

proof of the pudding is in the eating.

And it's 4

going to take time.

5 MR. PARKS:

Okay.

Are you going to take 6

your break now?

7 MR. JACKSON:

Okay.

What I'd like to do is 8

we'll leave this room available for the USEC 9

personnel.

My staf f -- and others feel welcome --

10 are going to adjourn to this next conference room 11 for a few minutes to ask -- or, what we'll be 12 looking for are any specific questions that we 1

13 need USEC to further address or focus on and then 14 we'll adjourn and I'll close.

15 (A break was taken.)

16 MR. JACKSON:

Okay.

I guess basically l

17 where we are is we feel there was a management 18 commitment here to make some things happen.

There 19 was a management commitment to relook at your 20 programs, your QOOP, to hold a June 3rd meeting to 21 relook at some things, to look at your accuracy of 22 corrective actions, et cetera.

Those are 23 positive.

24 I think what we see in the negative is 25 these things are still here.

These things are BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471 i

83

^

1 still with us.

The shipments of stuff off site 2

happen and at a number that is unacceptable to us.

3 It's -- we're -

you know, one analogy that I used 4

in there is, yes, I can tell my daughter that D is 5

passing, but I'm not -- it's better than an F.

6 It's safe.

It's passing.

But it's not good 7

enough, not what we expect.

It's not what you 8

want for your system.

And the department, NRC, 9

all regulators want to raise our standards as we 10 go along too.

As we understand things better and 11 we make things safer, our threshold goes up.

12 Someday D isn't good enough.

And that's part of 13 what we're dealing with here.

14 George and the rest of your organization --

15 one thing we did ask for here, I think you 16 acknowledged part way through, is the difficulty 17 in getting measurable actions.

These are 18 difficult, intangible things.

Some of your charts 19 that showed a downward trend, you know, we can --

j 20 we can reassess and analyze and reflect on them 21 different ways in different issues.

But we still

.22 need and we will look for your response at the end 23 of the month to focus on giving us detailed 24 descriptions of actions and schedules and things 25 you need to undertake.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS

)

12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

i 84 1

I still heard a -- in my staff and others 4

2 questions in our caucus in here is the concern for 3

your -- do you have resources to meet the things d

4 you're committing to?

We seem to hear, see, 5

slippage in schedules to corrective actions i

6 committed that we had very little to do with 7

telling you this needs to be done by April 15th.

8 We allowed you in your responses to say we can get 9

this done by April 15th, and then we look at it 3

10 and say that will be acceptable.

So we give you 11 generally the first option to pick your date.

And 12 when those slips continue to slip, it does look 13 like a resource item or a lack of commitment item.

14 You put us in the guessing or evaluation game as 15 to, well, why are we not getting this done; why is 16 this taking so long, especially for items that i

17 we've allowed you to make the commitment to.

18 We would look for -- I think you gave up 19 your chart that showed your top ten or top twelve 20 items, I think three of which are green now.

What 21 is your plan or goal to get them all green?

I 22 mean, you should have that.

I mean, what is your 23

-- you know, you should have some idea in your --

24 you know, in your mind or in your plan today.

Are 25 you expecting to have seven of them green by the BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

85 1

-- by September?

All of them green by December?

2 Or are you satisfied with the yellows and the 3

reds?

I don't think you are.

So what we're 4

saying here is we still want to see more in the 5

area of management control.

6 I think you've -- I'm hearing the 7

commitment.

We're all hearing the commitment.

8 And we want you to go back and continue to 9

self-evaluate, continue to do some of these things 10 and give us something -- I think you need the 11 tools first.

You need the measurable tools first.

12 And then let us see, you know, your measurement 13 tools to further instill this confidence.

14 And that's really I think all I want to 15 say.

I want to -- Joe, do you or Liz or George 16 want to add to or say anything to that?

1 17 MR. RIFAKES:

We'll respond to you by the i

18 31st, Dale.

You didn't say anything that 19 surprised us here in closing.

20 MR. JACKSON:

Okay.

21 MR. RIFAKES:

I believe we can respond 22 adequately.

23 MR. JACKSON:

Okay.

Listen, I do 24 appreciate all of you coming.

I appreciate those 25 of you in the crowded conditions that you've BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

86 1

beared with us.

It's -- I don't know, it's sort 2

of like -- sometimes it's almost like we're in a 3

war.

It's good to come and look at what you have 4

done, look at what'you've progressed on, and take 5

some pride in progress in these steps.

But, 6

remember, we're still all being shot at once we go 7

back into our tasks.

But I do have a lot of 8

passion for my job, for trying to uphold what I'm 9

supposed to be doing, and to demonstrate that we 10 do have knowledge and we do have a confidence in 11 your adequate safety preservations.

Perhaps the 12 wrong choice of words, but --

13 MR. RIFAKES:

I'd like to say one thing.

t 14 MR. JACKSON:

Yes, George?

15 MR. RIFAKES:

We appreciate this process.

16 I think this is a lot more constructive than 17 waiting until there's real trouble and then we 18 have to have enforcement conferences and NOVs.

I 19 would ask -- these next few months are going to be 20 difficult for everybody.

If you see a need or if j

21 you have a concern or a lack of confidence or 22 however you want to describe it, before the 23 trouble really gets there, I would ask that you'd 24 call another one of these --

25 MR. JACKSON:

Okay.

BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

i 87 1

MR. RIFAKES:

-- so we can hash these

[

2 things out in a more constructive manner than just 3

being responsive to a series of violations.

4 MR. JACKSON:

I really feel trouble has 5

everir opportunity to be lurking in the next 6

several months.

It's going to be -- it's going to 7

take every bit of your efforts to ensure the 8

regulatory process, which I'm going to consider 9

more important than the application, than the 10 other parts.

11 As Bob Cantrell said, when we were talking 12 about this, if the management control is the 13 brain, management control needs to determine do I 14 need to breathe or does my heart need to beat.

If 15 the heart is the safety protection and the lungs 16 are the equivalent of your application, your 17 operations, good management controls is probably 18 going to say you need to do both.

And the 19 management control should allow the process for 20 both of them to happen.

You've got to protect the 21 heart in safety and you've got to go on with your 22 other missions.

23 It's going to be difficult and it's my job 24 to ensure that you've -- and monitor and provide 25 oversight that you do it correctly.

So I BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471

88 l

l l

1 appreciate it.

Thank you all for coming.

l l

2 (Thereupon the meeting was adjourned.)

l 3

4 5

f 6

l 7

8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BONNIE L. SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union' Road, Knoxville, TN 37922 Phone (423) 675-1471

89 1

I 2

CERTIFICATE I

J i

3 4

I, Bonnie L. Smith, do hereby certify that the i

5 foregoing 88 pages is a true and accurate transcript of 6

the proceedings taken by me on the day of May 9, 1996.

7 This 20th day of May, 1996.

8 9

h7/12tl M1

)

10 I

11 Notary Public 12 My Commission Expires:

13 October 28, 1997.

14 15 1

16 17 1

18 19

)

20 21 22 23 24 25 BONNIE L.

SMITH, RPR MILLER & MILLER, COURT REPORTERS 12804 Union Road, Knoxville, TN 37922 Phone (423) 675-1471