ML20133E179

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Transcript of 961205 Pre-decisional Enforcement Conference Re Nene
ML20133E179
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 12/05/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
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ML20133E153 List:
References
NUDOCS 9701100229
Download: ML20133E179 (152)


Text

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Vr.RUATIM PROCEEDIllGS 1

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NUCLEAR REGULATORY COMMISSION PRE-DECISIONAL ENFORCEMENT CONFERENCE RE: NORTHEAST NUCLEAR ENERGY COMPANY l

DECEMBER  ?>, 1996 1

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i MILL 3'IONE S IMULATOR AND 1 RAINING F AC IL.I TY ROUTE 156 W4TERFORD, CONNECTICUT l

l l>OOT REPONIJNO SE RV I C f. j

, HAMDLN. CI (GOO) 202 1102 l l

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9701100229 970102 PDR ADOCK 05000245 T PDR

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY ,

DECEMBER 5, 19>6 0 1 . . . Verbatim Proceedings of the Pre- 6 2 Decisional Enforcement Conference of the Nuclear 3 Regulatory Commission Re: Northeast Nuclear Energy 4 Company, held December 5, 1996, at 9:00 A.M . at tho l 5 Millstone Simulator and Training Facility. Route 156, I

i l 6 Waterford. Connecticut. .

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! 10 11 MR. JACQUE DURR: This is a pre-decisional 1

12 enforcement conference between Northeast Utilities and 13 the Nuclear Regulatory Commiccion to discuss a series of 14 violations. Th3s enforcement conference is open for 15 public observation. A session will be held at the end -

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16 the NRC will make themceives available for public  ;

i 17 questions into this. So if the public would hold their I i

10 comments or questions until that t i me'? I i

19 1*m ,Jacque Durr. I'm the Oranch Chief for 20 the Incpection Branch for Special Projects which has i 21 oversight for the Millstone facility. At this time I'd 22 like for all the participants ceated at the tables to 23 introduce themselves for the benefit of all 24 participating.

POST REPOR1ING 3ERVICE HAMDEN. CT (800) 262-4102

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY [

DECEMDER 5, 1996 1 MR. MARTY VIRGILIO: Good morning. My 2 name ic Marty Virgilio. I was the Manager responsible 3 for leading the specini inspection of engineering and  !

l 4 licensing activitiec.

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l 5 MR. WAYNE LANNING: Good' morning. I'm I 6 Wayne Lanning. I

  • n, the Technical Director for  ;

I 7 Incpections from the Office of Special Projects.

8 MR. HUBERT MILLER: I'm Hubert Miller.  ;

l 9 Regional Administrator, Region 1.

l 10 MR. JIM LIEGERMAN: I am Jim Lieberman, l

11 the Director in the NRC Office of Enforcement.

12 MR. BILL TRAVERS: I'm Bill Travers and i l 13 I'm the Director of a relatively new organization at NRC, l

14 Special Projecto Of fice in the Of fice of Nuc. lear Reactor 15 Regulation.

16 MR. DAN HOLODY: My name ic Dan Holody, 17 E nf orcement, Region 1 NRC.

l 18 MR. DAN McOONALO: I'm Dan Mcdonald. I'm i

19 the Project Manager for Millctone Uni t 2. Office of 20 Cpecial Projectc.

21 MR. GTEVE REYNOLDS: I'm Steve Re':."wids.

22 I'm the Technical Assistant to the Special Projects 23 Office.

l 2 <1 MR. I E N PLIOCO: I'm Loten Plisco. I POST REPORTING 3ERVICE i HAMDEN. CT (800) 262-4102 1

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4 t RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996  !

P 1 wac the team leader for the special inspection of  ;

2 engineering and licensing. l 3 MR. TONY CERNE: Tony Corno, Senior l

4 Resident Inspector for Unit 3 for Special Projects. l l 5 MR. DAVE DEAULIEU: Dave Beaulieu, acting l

l 6 Senior for Millstone Unit 2.

'7 MR. TED EASLICK: I'm Ted Easlick, Senior i G Resident for Uni t 1.  !

9 MR. JACK ticELWAIN: Jack McElwai n, Unit 1 l

10 fietovery Of f icer.

l 11 MR. MARTIN BOWLING: Marty Bowling, Unit 12 2 Recovery Officer.

13 MR. BRUCE KENYON: Bruce Kenyon, President i 14 and CEO of Northeast Nuclear. I 15 MR. DAVID GOEDEL: Dave Goebel, Vico 16 President of Nuclear Oversight.

17 MR. JOHN COWAN: John Paul Cowan, the i

10 Recovery Officer for Unit 3.

19 M R ., JAY FERR: Jay Ferr, the Nuclear  !

20 Engineeri ng and Support Recovery of f icer.

21 MR. MIKE BROTHERS: Mike Grothers, Unit 22 Director of Millstone Unit 3 23 MR. PAUL GROSSMAN: Paul Grocsman, 24 Engineering Director. Uni t 3.

POST REPORTING GERVICE HAMDEN, CT (800) 262-4102


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5 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5 1996 M

i MR. PETE RICHARDSON: Pete Richardson, 2 Unit Director. Millstone Unit 2.  !

3 MR. RAY NECCI: Ray Necci, Engineering i 4 Director for Millstone 2. i 5 MR. PAUL HINNENKAMP: Paul Hinnenkamp, -

6 Unit Operations Director. Unit 1,, I l

7 MR JIM ARMSTRONG: Jim Armstrong.

O Engineering Director, Unit 1. i 9 MR. DURR: Thank you.  !

10 I'd like to announce that this meeting is. J 11 transcribed and a transcription will be made available in

1. 2 our public document room when they're completed.

13 Alto, depending on the length of this 14 conference, arrangements have been made that where a I J

15 convenient point arices, we may break for lunch. Lunch j i

16 will be a one-hour break, assuming that the conference '

17 goes that long 18 Wi th that, I would like to turn the podium I l

19 over to Mr. Miller for Regional Administrator remarkt. '

20 MR. MILLER: Good morning. Inspections

'21 and invettigations conducted over the pact year have i

i 22 revealed numerous significant failures of Northeact l

l 23 Utilities to meet regulation and licenting requiremonte 1

( 24 in f or co at the Millstono station.  ;

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POST REPORTING SERVICE HAMDEN,, CT (800) 262-4102

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMGER 5, 1996 i The number and nature of the violationc 2 identified, the breadth of problems uncovered, have 3 revealed ceriouc management deficiencies at the station 4 and at the corporate level.

5 Many facets of plant operation are 6 involved. Our incpectionc, f ollow-up on allegations and 7 employeet concerne that have come to our attention and c 3 your own Northeast Utilitiec ascessments which were l

9 initiated largely in recponce to problemo identified by 10 others, have uncovered a number of dicturbing patterns.

11 Thece include wideopread f ailure to accure 12 that plant configurations, operating procedurec, ,

13 maintenance and testing practice are concictent with l

14 plant licencing and decign bacec, ac thoce are f ound, for 15 example, in the updated final safety analycio report i l I l 16 We have found a frequent willing, cc to 17 live with, rather than cquarely face and fix, probleme 1

18 and non-conforming conditions. Frequently, more energy 19 seemc to have been devoted -- more energy, ef f or L and 20 resources have been devoted to explaining away and j 21 rationalizing problemc than fixing them. ]n many 22 instancec. there appears to have been a dicrogard for 23 1icencina commitments.

24 Mr Lanni 9 in a moment will review the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 C

U 1 details., the detail of the specific violationc that we 2 will be discuccing today, and they cover a wide spectrum ,

3 of issuec, decian control, failure to do adequate cafoty 4 evaluations, inoperable equipment, failure to meet

  • 5 technical cpecificationc, problemc with tecting 6 procedures, maintenance of records, event r epo r t i ng ,,

7 accuracy of information provided to the agency.

8 Underlying all of thic 10 a standardo l ,

l l 9 iccue. Failure of top management of the utility to 10 establich and to concictently enf orce adequate standards, il failure to create an environment that is conducive to I

1 l 12 finding and reporting problems, failure to implement i

13 offective corrective action programs. And here I'm l 14 cpeaking of a fundamental problem with the line l

15 organization's inability to effectively get work done.

16 I mean thic is engineering in termo of getting to the I 17 bottom of incues. And it's the maintenance organization 18 and the failure to productively f[v equipment problems, l

19 Overall, the celf-acccccment procesc,,

I 20 prococsec at the Millctone station have been weak. And 21 here again I'm ref erring to the line organization f ailure 27 to be celf-critical and introspective, as well as f ailure 23 on the part of the organizations within the company who 24 have a r esr>onc i b i l i ty for ciua l i ty verification and POST REPORTING SERVICE l

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8 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMGER 5, 1996 G

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U 1 oversight, the quality assurance organization, for 2 examplo.

3- Instead, in many respects there has been 4 an environment that is hostile to raising of icsues. I 5 think this Ic exhibited or is shown by the persistent 6 failure or inability of the utility over the years to 7 deal effectively with employee concerns.

C 1t's probably use f ul at this poi nt to tal k j

? a little bit about the context of this enf or coment 10 conf erence, provide a bit of history and perspectivo. As 11 you know, much hac happened over the pact year at i 12 Millstone f rom a regulatory poi nt of view. '

l 13 A little over a year ago, in part prompted 14 by allegation; and employees concernt, NRC intensified l 15 Its oversight of Millstono activitiec. In addition to l l

It. increating resident incpection office staffing and l

17 providing on-site senior management overcight at 18 Millstone, we initiated several large team inspection l

19 efforto.

20 One significant effort, a large team who j l

21 were on cite over a several-month period examined the l 22 methods by which the licensee handled degraded and non-23 conf ormi ng condi tions. This is the special incpection of l

24 engineering and licencing that was headed by Mr.

POST REPORTING SERVICE HAMDEN, CT 0300 ) 262 -4 l o'i

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! 9' RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 C

1 Virgilio, who ic a Genior Manager f rom our Headquarter c 2 Office. That team was compriced largely of people 3 outsido the region and in all casec people who were 4 independent of activities at the Millstono station.

5 Another inspection was conducted to acscsa l

1 l 6 the handling of employce concerns. As an appreciation l l l 7 f or the significant scope of problems emerged f rom these l l l

, 4 l 8 ef f orts on a number of occasions NRC required Northeast l 1

l 9 Uti1ities to take steps itself to more ful1y investigate 1 l

10 matters, to determine the depth and scope and root causec l l

11 of problems as thic is necessary to assure corrective i i

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'12 actions are complete. These are the so-called 50.54(f) 1 13 letters, the demands f or inf ormation that were made on a 14 number of occasions, I think on four separate occasions l 15 over the past year.

16 As the programmatic weaknesses and design 17 and configuration management became clear and given 18 continuing failure of your internal Northeast Utilities 19 oversight and quality verification processes to detect 20 significant compliatico problems , on AuguGt the 14th NRC 21 losued a confirmatory order requiring an independent 22 thir d-party review of the decian basis and configuration 23 management iccuec.,

24 A similar order was iconed on Oc tobor the

, POST REPORTING SERVICE HAMDEN, CT (8001 262 110'i

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 C 1 24th, requiring the company to develop a plan to deal l

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2 with employee concerns more of f ectively and to require a l l

3 third-party oversight of that plan and its execution. l l

4 Ac you know also, Millstone was designated 5 a watch list plant, a Category 3 plant, that requires 6 that specific Commicolon approval be given before any of 7 the three plants are restarted. l l

8 And as Dr. Travers mentioned a moment ago, '

9 a special of fice was octablioned to f ocus speci fically on 1

10 Millstone. Thic office is comprised of both people in 11 our Headquarters group as well as people who are in the 12 inspection area in the region and here on site.

13 We iccued on November 13 a Ictter which 14 lays out the specif Ic violations that we have identif led.

15 There are come 60 or so violations. And this meeting 16 providen you an opportunity to comment on those 17 violations but, more importantly perhaps, to have us be 18 able to discuss and review the root causes and the 19 corrective actions that you plan, 20 We have held of f - throughout all of this 21 activity that I've talked about we've held off on 22 onf orcement becauso we f elt it important to establish the 23 pattern 0 and to be complete. And so we have held off to 24 this point, this meeting. ThlO is an important meeting PO3T REPORT]NG SERVICE HAMDEN. CT (800) 262--4102

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11 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY I

l OECEMBER 5, 1996

("i 1 becauce we will take the results o' thic meeting and what j

2 you present and concider that as we detie rmi ne what 3 onforcement is appropriate, given the many violationc 4 that I*vo talked about.

5 Now, there*c a history of problems at

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l 6 Milletone. And while wo*ll be focucing a lot today on I l 7 engineering issuec and issues related to compliance with '

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l 8 the licencing basis, the SR and the like, there have been  !

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l 9 16 civil penalties iccuco at Millstone in the 1990'c. ,

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l 10 I think this Is an Indication of the kinds 11 of problems that have existed at the station. And thece 12 civil penalties have covered the gamut or the spectrum of 13 things. Again, degraded and inoperable equipment, I

14 Inadequato corrective action, problems with procedures l l

15 and cafety evaluations, discrimination for raising of 16 cafety iccues.

17 So there's been this history of material 10 condition problems and things that go beyond the types of 19 things that we will be talking about here today. And, of l 20 cource, thic is what ic - you know, it's what you're 21 focusing on r ight now. You have made management changec. I 22 We are, of cource, aware of those You are in the 23 procecc of developing plans for recovery. And very 24 importantly, you are still in invectigation through the l

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12 I RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY ]

DECEMDER 5. 1996 U l U l 1 ef f orts that respond to our specif ic requirements and the ,

i 2 orders and the demands for information. But, more 1

3 broadly, as you bring in your -- as you brought in your l i

4 new management team. l l l t

l 5 Go there may out of thi? new things that i

j 6 are found. But we feel at this point it is an 7 appropriato point to pauce and to look back and to do an 8 accounting of the violations that have occurred and to i  !

9 make our decisions regarding enforcement at this point. l l

l 10 Now, we are still reviewing a number of I 11 mattorc and invectigating various things. We will not, i 12 for example, be here talking today about harasoment and I i

13 intimidation concerns as those evict. That will bo 14 handled at a later point.

15 Well, the scope is very laroc, as I j 16 mentioned, 60 violations. And so what we propoco to do 17 is to not go through each and overy violation. But, l

18 rather. what I will do in ask Mr. Lanning to briefly 19 review f or us the broad areas of violation and to provide 20 come examples of those violations to set the stage. And j 21 following that, we will ask you to respond.

22 Mr. Lieberman has some comments.

23 MR. LIEDERMAN: Thank you, Hub.

24 I am Jim Lieberman, the Director of the i

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l 13 I RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY

, DECEMBER 5, 1996 G 1 NRC Office of Enforcement. As Mr. Miller said, the 2 apparent violations we are discussing today aro very 3 They cover I serious. a broad range of regulatory  :

1 4 requirements.

5 Gimply stated, the apparent violations 6 demonstrate unacceptable perf ormance and inef f ectiveness 7 in controlling licensed activities. You failed in my i 8 view to achieve a safety-conscious work environment.

9 Mr. Kenyon, I appreciate that you're new 10 to Northeast. But the management team at Northeast lot 11 down the public, including your employees, in that you  !

12 did not demand a questioning attitude, did not insist on 13 taking necessary corrective action, did not respond to 14 indications of problems in your performance and did not 15 insist that the f acilities operate within the regulatory 16 envelope. I 17 As I said yesterday during the enf orcement j 18 conf erence f or Haddam Neck, i n the 70's KMI was a wake-up  !

19 call to the nuclear industry. Performance at Northeast, 20 at Haddam Noch and Millstone is a wake-up call in the 21 90's. The performance of the Millstone station, as 22 evidenced by the violations we'll be discussing today, 23 serve as an example of how nat to operate a nuclear 24 facility. It's a notice to all licensees of the need to POST REPORTING GERVICE HAMDEN. CT (800) 262-4102

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4 14 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 19?6 C

U 1 avoid similar problems.

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2 Some have said that NRC is at blame for  ;

3 the problems at Northeast that we'll be discussing today 4 and we discussed yesterday., NRC clearly has lessons to i

l 5 learn and we'll be improving our efforts. But the l

6 pe r f carma nce issues that we're discussing today were 7 caused by Northeast.

8 As Mr. Miller stated, we'll be focusing I 9 today on root causes and corrective action. I look 10 forward to your presentation as to why we should have i 11 confidence that you have identified and understand the

! l 12 root causes of these violations, why there was not a j 13 cafety-conscious environment, why corrective action was 14 not taken, why it was acceptable to live with your 1 l

15 problemt, why there was not a questioning attitude, why

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16 we should have confidence in your corrective actions will 17 effectively address these root causes when in the past 1

18 Northeast has not been offective in achieving lasting I 19 corrective action.

! 20 I will be particularly interested to hear 21 f rom you i f you believe that management expectations need 22 to be changed as part of your corrective actions. What l 23 wore the past management expectations or messages that 24 you were not satisfied with? Why were those standards I

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L5 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996

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1 allowed to occur and be maintained?

l 2 We need to understand the fundamental 3 causes of how you got to the cituation you're in today.

4 Decauce without that understanding, we will not be in a 5 poci tion to judge the expected offectivenecc of your 6 corrective actionc.

7 At this point. Dan Holody, the Region 1

( 8 Enf orcement Officor, wil1 discusc the enforcement 9 prococc.

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! 10 MR. HOLODY: Thanks. Jim.

l 11 Ac Mr. Miller indicated earlier , today the l

l 12 NRC ic conducting this pre-decisional enforcement 13 conference with Northeact concerning the apparent 14 violations identifled during coveral NRC incpections.

15 including a cpecial team inspection that was led by Mr.

16 Virgilio. The incr>ection reporto wet e issued previously.

17 Like yesterday *c conf erence concerning i 18 Haddam Neck, the conference 10 open for public ,

j 19 observation. Go, ther ef ore, I'll take a few minutec to l 20 briefly provide come background on the enf orcement policy l

21 program and prococo.

22 The enforcement prococc begins with the 23 NRC evaluation of the findings of the incpection.

24 including the apparent violations. Baced on their Gaf ety POST REPORT INGi SERVICE HAMDEN. CT (GOO) 262-4102 l

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16 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 and regulatory signi f icance, the apparent violationc are  ;

2 preliminarily categorized by the staff either 3 individually or collectively at severity level -- into 4 one of f our severity levels, with Severi ty Level 1 being 5 the most significant and Geverity Level 4 being the leact

, 6 significant, For any potential Geverity Level 1, 2 or 3 l

[ 7 problem or violation, the licencee ic normally of f ered a l

8 pre-decicional enforcement conference.

9 The conference it eccentially the lact l

1.0 step of the procons prior to the NRC deciding the i

i 11 appropriate enf orcement action. I n thic cace, there were l

! 12 numerous apparent violationc identifled, ac alluded to 13 carlier, which were documented in those i ncpec ti on 14 reports and also in that November 13 letter providing the l 15 format for thic confcrence.

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16 That letter also provided a listing of the 17 broad typeo of deficiencice that the violationc 18 represented, as previoucly summarized by Mr. Miller and 19 ac Mr. Lanning will go into in more detail.

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! 20 The primary purpoce of thic pr e-decisional i

! 21 enforcement conference, like yacterday*c conference i l

22 concerning Haddam Neck, ic to focus on the causes of 23 those broader problems, NU's corrective actions f or thoce I l l 24 problems, including the actions to pr event r ocurrence, an I

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17 1 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY i DECEMBER 5, 1996 '

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C" 1 well ac their overall significance  !

1 2 Ouring the conference the NRC will explore ,

l 3 any inf ormation it deems relevant to either mitigation or 4 occalat.4on of any reculting enforcement sanction In 5 addition. Northeast can provide any information it 6 considerc relevant to the NRC decision., Northeast can 7 take iscue with any of the fact findings or apparent i

j 0 violations described in the inspection report The bacon 7 for any challenges will be discussed.

l l 10 It's not the purpoco of this conf erence to 11 negotiate an enforcement sanction. Rather, the 12 conference provides information that will be considered )

i 13 by the NRC in the decision-making procecc concerning what 14 onforcement action will be taken.

15 While additional i ncpect i o n or 16 investigation could occur, if needed, and apparent i

! .17 violations may be subject to change, a final decision l

18 regarding appropriate enf orcement action will be made by l

i 19 the Region in coordination with our Headquarters Of fice.

20 Prior to turning the meeting over to Mr.

l 21 La nni ng , I note that the ctatements or opinions made by  ;

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i 22 NRC staff- at this conference chould not be taken ao a l

l 23 f inal NRC position nor should the lack of an NRC response 24 to an NU ctatement be viewed as NRC acceptance of their l POGT REPORTING SERVICE f

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r 18 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY ,

DECEMBER 5, 1996 l r

l m-1i l 1 position.

f 2 Prior to the conclusion of this l

3 conference, the NRC may take a short break to meet I i

4 internally to ensure a full and common understanding 5 prior to concluding the conference.

6 Finally, for those who desire, we have t 7 loft at the entrance to the conf crence room a one-page ,

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8 handout that pr ovideo a cummary of the NRC enforcement '

9 program. In addition, as already indicated, after the 10 conference the NRC will be available to answer any i

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' l il questions concerni ng the procces, j 12 With that said, I'll turn the meeting back l I

l 13 over to Mr. Lanning.

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j 14 MR. LANNING: Good morning. I'm Wayne  ;

15 Lanning, Deputy Director of Inspections in the Office of 16 Opecial Pro }ccts. I'm going to be discuscing some of the l 17 most important safety-cignificant examples of the 18 violations. About half of these violations - we can't I 19 see that. By the way, copies of thic handout are 20 availabic in the back of the room.

21 About half of these violationc were i

22 identi f f.ed by the special team inspection and the 23 remai nder were identi fied by the resident i ncpectors and 24 other in0pectors from the Regional Office.

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19 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY I DECEMBER 5, 1996  !

O 1 The details of these violations are '

2 contained in the special team inspection report and the 3 integrated resident inspection reports that we iccue 4 about every cix weeks.

5 The first one is failure to control 6 decian. This is really contrary to Criterion 3 and 1 i

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i 7 Appendix B to Part 50 whose title ic Quality Accurance f

I l 0 Criteria for Nuclear Power Planto and Fuel Cycle l

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l 9' Facilitiec - Fuel Procencing i acilitier. l 10 I'll be referring to violationc of other '

11 criteria during my precentation today. But they're all 12 contained in Appendix G unlecs I otherwice note. i 13 There were 21 examples of the violation of 14 thic criterion. At Unit 2. there were inadequate design

! 15 controlc available to ensure that poot-TMI requirements i

16 for hydrogen monitoring, post-accident sampling and 17 containment radiation monitoring were implemented.

l 18 Concequently, these cyctems Were unable to perf orm their l

19 intended decian function. Fundamental design i

20 conciderations cuch ac sample pointo, flows and sample 21 times were not adequately considered.

i 22 At Unit 3, Unit 3 was , hut down in March l

23 becauce of inoperable containment icolt ; ion valvec in the I

24 auxillary feedwater system The application of thoce POST REPORTING DERVlCE l

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20 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY l OECEMOER 5, 1996 i m

U 1 valves was contrary to the vendor manual and inadequate 2 coritrols permitted theco valves to be placed in service 3 during construction.

4 In addition, your failure to octablish i

5 design controls to verify the adequacy of these valves'  !

6 capability permitted their continued use until this year.

7 In addition, there was significant 8 operating experience available to identify that those 9 valves were not appiopriate for containment isolation 10 f unction and would not be able to perf orm thic important 11 cafety function.

1 12 The next broad category was the f ailure to j 13 make changos properly to the facility. Of particular 14 concern woro changoc that were made to the facility 15 without adequate saf ety evaluations. This could lead to 16 a failure to identify an unroviewed safety concern.

i 17 The opecial team found numerous examples l

l 18 of FSAR dicerepancies. At Unit 1, for example, the 1 19 standby gas treatmem heater design shutoff temperature 20 was changed from 125 to 150 degt ecc back in 1989, but no  !

21 saf ety evaluation was perf ormed until 1995.

22 At Unit 2, you recognized that the 23 hydrogen moni tors were not cinale-f ailureproof . You used j 24 j umperc, which is a temporary modification, and procedure POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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21 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMDER 5. 1996 1 I changes, but you never performed an adequate cafcty .

j 2 evaluation of this temporary mod. This mod did not moot i

l 3 the design basio f or the i odepe nde nce ,, rodondancy a rid

! l

, 4 single-failuro criteria. In fact, you may have 1 4

5 introduced additional failure modes that were not i

6 identified.

) 7 At Unit 3 there were numerous examples to i 1

1 8 ill ustrate this violation. For example. Contrary to what 9 was stated in the FSAR, the design of the station i

10 blackout equipment and procedures were never contictent J

. 11 with the description contained in the FSAR. Similarly, )

12 one of the outer star cignalc for the turbine-driven t 1 13 auxiliary feedwater pump was removed without a saf e ty 4

14 evaluation.  !

15 One of the moct signifIcant desian changes 1 16 that was not adequately evaluated was the closure of the 17 turbine-driven auxiliary f eedwater pump discharge valves 18 during low-power operations. This wac a corrective 19 action for a high-energy line break concern for the I

j 20 turbine-driven auxiliary feedwater train that rendered 21 the train inoperable and you failed to recognize that 1

22 this was contrary to a technical specification 1

23 requirement.

24 There were 18 examples of where you f ailed POST REPORTING SERVICE HAMDEN. CT (800) 262-1102

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMDER 5, 1996 0 1 to take prompt and adequate corrective actions. Thic is 2 contrary to Criteria 16. At Unit 2 the special team 3 inspection found gaps between the doors and the door ,

4 seals for circulated motor-control cabinet enclosures 5 The environmental qualification of the motor-control 6 centero had been an engineering concern since 1992 when 7 operability determinations wer e first made. However,, your 8 corrective action procesc f ailed to identif y and correct I 9 the excescive gaps that compromised the environmental 1

i 10 integrity of the cabinets Here again there were l

l 11 operating experience available identifying thic i 12 deficiency, i

13 Also at Unit 2, there were design i

14 diccrepancies identified in the containment cump strainer 15 that should have resulted i t. the identification of the i 16 excessive mcch cize that led to the Unit 2 chutdown in 17 February. These deficiencies were identifled in 1980.

l 18 These came design def iciencies rendered ECCS i noperable.

19 A failure to take timely corrective actionc.

20 Another cigni ficant example at Unit 2 was 21 your f ailure to test dual-f unction containment icolation l 22 valves. In response to a notice of violation issued by l 23 the NRC in 1993, your corrective actions were to identify l

l 24 and test cuch valvet. It was a commitment that you made POGT REPORTING GERVICE I

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23 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMGER 5, 1996 )

" 1 to tne NRC. The special team inspection identi fied that 2 you had not implemented this corrective action Ac a 3 result, come 70 valves were not tested during this three-4 year period.

5 At Unit 3, in 1990 ac part of the 6 corrective actions for a fire protection concern, a l l

7 bypacc )umper, another temporary modifIcatlon, was 1

j Et inctalled in the cervice water booster pumpc. T hi n 9 defeated automatic actuation and alignment functionc.

10 Some were identified, othere were not identified. )

11 Numerouc opportunitiec oxisted to identif y l l

1 12 the unacceptable modification f or cix yearc, including i i

)

13 the review of bypasc jumpers by Engineering, Operations 14 Manager, the plant Operating Review Committee, the Unit  !

15 Director and the VP of Operations.  !

16 There were three failures to meet the  !

l 17 technical specification requirements. This is part of  ;

,1 15 your licence. Thece are violations of your licence. For 19 example, Unit 1, the on-site emergency gas turbine was 20 inoperable due to both fuel transfer pumps being 21 inoperable. Operators accepted degraded conditionc for 22 theco pumps f or two yearc and never really questioned why 23 it was acceptable.

24 In addition, there were timec when the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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24 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996

)

C .1 other on-site emergency source, the emergency diesel

)

2 generator, was also inoperable. And during these times 3 when both of those emergency equipment was inoperable.

4 your on-site emergency supply system was unavailable and 5 inoperable.

l 6 Last winter at Unit 2 both trains of the 1

i 7 service water system were inoperable due to freezing. l l

, 8 Operators failed to initiate action to place the unit 9 into cold shutdown pursuant to the tech specs. And this l 10 resulted in another toch spec violatior.

11 There were four examples of failure to i

12 test equipment properly. This is really contrary to )

13 Criterion 11. At Unit 2. the steam emission valves to 14 the turbine-driven auxiliary feedwater pump was not 15 tested per proceduro. As a result, incorrect test I

I 16 acceptablo critoria were used and that led to l 17 questionable design capability for this and 23 other l I

1.8 . motor-or>erated valves. )

I 19 There was an example at Unit 3 where you )

20 did perf orm the test af ter a modification, but you really 21 f ailed to evaluate that data af ter you received it. Thic  !

22 was af ter you had made a modif ication to a saf ety-r elated i I

23 cooler for the motor-control centers.

l

! 24 There was an example of whero Unit 3 i

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l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY  ;

, DECEMBER 5, 1996 '

,! i failed to implement vendor recommendations for 2 luorication of the turbine-driven auxiliary feedWater a

j 3 pump. This is an example of failure to establish j 4 procedureo pursuant to Criterion 5.

t .

I 5 There were numerous examples identified  ;

t '

6 where you had failed to update the final safety analysis '

1 I l 7 report. This ic required as part of our 50.71. For I s

f 8 example, at Unit 1 in 1989 you received a RERAC amendment 9 to perform one-third core offload rather than a one-10 fourth core offload. However, you did not update the 11 FSAR until four years ]ater.

12 The cpecial team inspection f ound numerous 13 deficiencies where the updated FSAR was different than O 14 what actually existed out in the plant.

I 15 There was a significant f ailure to procenc i

1 16 non-controllina parts. Thic is contrar y to criterion 15.

l 17 For example, at Unit 1 you completely lost control of the j l

18 non-conformance reports and you used them improperly.  !

19 You used them for reasons where they were not intended.

20 Concequently, operator determinations were not timely and 21 thece NCR*c were not trended and evaluated properly 22 There was a failure to maintain recordc.

23 You have requested and roccived the tech opec change, 24 tech spec amendment. When our inspectors were to POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

t 26 I RE: CONNECTICUT YANKEE ATOMIC POWER COMF'ANY .

DECEMDER 5, 1996 i

b 1 1 evaluate the technical bacic for that tech spec chango, l 2 it could not be found. It wac lost. l 1

1 3 There wac f ailure of the quality accurance 4 program, contrary to Criterion 3 -- Criterion 2. Excuse 5 me. At Unit 1, you made modifications to the chutdown 6 cooling cystem without ensuring that quality equipment l

7 and quality standards were part of design modification.

9 On ceveral occacions you f ailed to report 9 events in a timely manner purcuant to 50.73. L.ER': were 10 cubmitted late, sometimes ac long ac 30 days af ter which l

11 they were due. And even then, come of those required 12 update accessments were late.

13 And finally, there was a failure to 14 provide adequate inf ormation. Gener ic le t ter 89-10, thic l l

15 addrecces the motor control -- motor-operated valvec i n j l

16 the plant I t r equires a closure document. Escentially, 1

17 you certify to the NRC that all the valves are able to '

18 perform their intended function. l 19 Your report you Onbmitted to uc 20 inaccurately deGcribed the deciqn capabi11ty of a number 21 of cigni f icant motor-operated valves. The data that was 22 provided was not up-to-date or did not reflect the 23 recu]ts of dynamic tests.

24 In closing, I've touched on just a cmall POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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27 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 ,

1 number of the violations. But these examples illustrate 1

l 2 the broad-based issues and the programmatic f ailures that 3 must be addressed.

l 4 I'll turn it back over. I l 5 MR MILLER: Well, as I said, there are a l

l 6 lot of issues here. And many of these issues have been

! 7 already discussed and aired in various public meetings, 1 I

O in fact. But it is important to tie them together in a J 9 coherent way and to have this discussion today as we 10 considor enforcement. 30 there may be some r ehashing of 11 issues that we've talked about before and there will be 12 other meetings. There's a meeting in a couple of weeks l l

13 on your restart plans. We recognize that,.

14 But at this point lot me turn it over to 15 you, Mr. Kenyon.

16 MR, KENYON: Good morning. I'm going to 17 start a little bit difforently than I had intended. In 18 listening to the remarks, I think f rom my perspective it 19 would also be helpf ul to put my remarks lo some sort of 20 context.

21 Gack in the summer of this year , Northeast 22 leadership made a decision that it was ;i us t not being 23 successful in solving its nuclear problems and, thus, a

, 24 fundamental change had to be made. It had to be made at I

l POST REPORTING 3ERVICE HAMDEN, CT (000) 262-4102

20 I RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 the top of the nuclear organization. And, thus, they 2 went through a recruiting prococs and I was hired and I 3 arrived here, oc you know, in early September. And, 4 thus, I've been here for about three months.

5 The challenge over that period of time han 6 been, in an obvious way, to understand what the situation 7 here and then to begin to take actiono to addresG it.

G Now, the reality is I think I had a pretty 9 good understanding of the situation here bef ore ar riving 10 I exprecsed to the Board. I expressed to the Chief

)

11 Executive Officer of Northeast Utilities that the 12 fundamental problem was leadership and that leadership 13 had to be changed.

14 And I received from them a commitment to 15 do that. 1 outlined to them my basic approach. And, j 16 thuc, what we have today is a new leadership team, new in .

1 17 the cente that the officers, the recovery officers t!iat i

18 are going to addrecs you are all individuals who have I

19 come from other utilities. They come from nuclear 20 operations that are today well-regarded. Most of them 21 have experience in bringing nuclear cituations back f rom  ;

22 troubled timec. Many of then: have experience with plante 23 being on the watch list 30 what we have here today to 24 talk to you beyond the remarks that I'm going to make is POST REPORTING GERVICE HAMDEN, CT (800) 262-4102

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{ RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY I DECEMBER 5, 1996 j

l C i Li 4 1 a team of people that really represents new leadership. )

i j 2 Now, as I have said in various remarks to J

} 3 the public, to our employees and less formally to the 4 NRC, changing out the officer team, which ic basically j 5 what we have done. We have the recovery officers that l

l 6 I've indicated. There are no officers that are part of 7 Northeast Nuclear that have a longevity in their current I

d j 8 pocitiono earlier than February. Go they really are not l 9 the individuals who got Northeast to where it ic.

  • i 4

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i 10 We have also made a number of changes at i

i 11 the next level down. We're partway through that procesc 4

g 12 in terms of asscosing people. In addition to bringing in i

13 recovery of ficers, we have brought in f rom the sponcoring 14 utilities a lot of their own folkc., And, thus, at the 15 Director level, which is our title next further down, 16 roughly slightly more than half are either different 17 people or people in more appropriate positions. And we 18 have not finished with that prococa.

19 So, Hub, when you talk about -- as you 20 talked in your opening remarkc about serious management 21 deficiencies. I absolutely agree with that. And as 22 you'll hear as I get into my remarks, there's no question 23 in my mind that one of the key underlying issues was the 24 fact that standards were not properly set. Standarda to POGT REPORTING SERVICE HAMDEN, CT (800) 262-4102

n 30 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 control design, Otandards to deal with an effective

)

i 2 corrective action program, ctandards on setting the right 3 environment and properly handling employee concerns, 4 standards on the effectivene-o of oversight, standards 5 when problems happen, t'ow do you dig into them? How do 6 you f ind out what the r oot cauces really then? And then 7 developing offective corrective action from there. The 8 ctandards juct have not been there.

9 Jim Lieberman in his remarks indicated --

1.0 and I agree with this - that the performance of past 11 Northeast management let down the company. It let down 12 the pubic. It let down our own employecc., nnd I agree 13 with that. And I would add that I think we also let down 14 the industry and I think we let down the NRC. We just 15 did not perform to appropriate standards.

16 Go it's a difficult time for us. No 17 organization likes to be in a situation where you just 1

18 have to "fecs uc that what management hac done hasn't i 19 been right. It hasn't been right f rom a lot of different i

20 per spectivec. But that's exactly what we're doing today.

l l

21 Go we're not here to contest any of the violationc.

22 We are not here to tell you that the 23 fundamental issues are fixed. Because they're not.

24 We're only partway into the pr ocess which will be a long POGT REPORTING SERVICE -

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31 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY I DECEMBER . 1996 0 1 process to not only be cure that we underctand all of the i

2 problems that exist within the organization, but these j, 3 are issucc that developed over years. And I think

<1 they're obvious to all of us that there have been 5 perf ormance problems at Hillctone f or years. And, thuc, i

6 the arrival of the leadership team, the actions that  !

7 we're taking -- in my judgment, they're appropriate  !

i 0 actions. But we are -- we have the challenge of f

I l

! 9 f undamentally changing how this organization performt.

a

{ 10 We're not here to discuss a new program.

E l

l 11 1 mean Northeact has talked about its problems f or years. '

1 12 Northeast has typically responded, "Well, here's our 1

13 program to deal with it" The answer is not another )

j 14 program. The answer is f.,3damentally changing how the l 15 organization functionc. The answer is fundamentally i

~

16 putting in leadership that works. The programs of the 4

17 past generally have not beeri of f ective, generally have

! 10 not even been pushed through to f ull implementation.

l 19 We're not here to tell you that we've 20 worked out all the details of what needs to bo done.

i l

21 We're going to chare with you our conce of the problemc.

1

)

i 22 We're going to share with you a broad outline of what we f

l 23 think we need to do to addrecc those. But as each day i

! 24 goes by, We're turning over more rockc. We're looking at i

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32 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY I DECEMBER 5, 1996 l

4 I how the organization works, how programe work, how i 2 standards - you know, where are standardo today versuc 3 where they need to be. And we can't inctantly raice a 1

j 4 standard from here to here. We have to move it up and

! 5 move it up and move it up. And we are about the tack of a

j 6 doing that.

t 7 And I don't think we're b:re to tell you 8 that at thic point there are lots o' obviouc signe of

? ma}or change., What we have been focusing on is putting 10 in place the f undamental building blocks on which we can 11 create the change that's neccesary. I am ctorting to see I

12 change. I don't think our employees in general at this 1 13 point arc seeing a lot of chango because what's going on i 14 ic a lot of the inf rastructure behind the ccones. Out it j 15 is starting to take place. )

i  !

j 16 Dut what I waat to do ac part of my '

17 remarks is procent in broader detail how I see the 18 leadorchip iccucc. There are a lot of ways to 19 characterize leadership iccuec. Dut as I look at the i 20 problemc that have affected the performance of thic 21 organization, if I boil them down to one cause, that one 22 fundamental, bottom-line cauce, that cause would be 23 leaderchip. Northeast Utilities has j ust not done a good 24 job.

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY  !

DECEMBER 5, 1996 l l

U 1 Let me ctart with what - how I woul d 2 characterize f our leadership issucc. One ic the one that  ;

I 3 both the NRC and I've already referred to and that ic I i

4 inappropriate standardc. Management failed to pursue 5 nuclear excellence. And in doing that, what happened was 6 that juct satisfying regulatory minimums became the 7 objective. And, thus, the company ctopped benchmarki ng 8 against other utilities. Ac perf ormance in comparison to j l

9 the rest of the industry started to clip, in other words. l 10 there wac a broader and broader performance gap, the 1.1 organization attempted to defend itself.

12 It defended itself by rationalizing what 13 was going on. It defended itself in some conce through 14 attitudes of arrogance and technical argumente and 15 denial, even come legalistic kinds of maneuverings.

I 16 Employecc, seeing the growing pervasive 17 tolerance of low or inappropriate c ta rida r ds , expresced 18 many valid concerno. I mean thic is what you would 19 e >< p e c t employees to do. And they exprecsed them to a 20 management that either couldn't solve the problems or was 21 j ust basically unrecponsive. And this obviously led to 22 many of the whictle-blower iccuec.

J l

23 Many managero and cupervisorc in the l 2 <1 organization who knew what wac going on wacn't right but I

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i j 34 1 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY

! DECEMBER 5, 1996 J

iC 1 were in an envi ronment where they really couldn't get the j 2 support they needed to solve the various issues, became i

! 3 increasingly frustrated.

i 4 So we have employees f rustrated We have

?

{ 5 management frustrated. But my overall point is that one I 6 very serious leadership f ailuro was the f ailure to strive 7 for excellence. And w heri you make that fundamental

} S choice of not going f or high standards, then you have set  ;

j 9 yourself on a path that ultimately loads to the kind of' t

10 situation we have today.

11 A second issue - agairi, this is under the ,

! 1.2 heading of leadership. A second issue was unclear 13 accountabilities. Management of Northeast Nuclear has i 14 operated with a highly centrallzed organization, a l

j 15 concept that was most recently called the power of five, 1

I 16 a fundamental weakness of which was a lack of clear I 1

17 accountability.

t

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l 18 As an example, if you were to ask who j li 19 real1y was accountable for the porformance of any 20 particular Millstone unit, you had to go all the way to 2.1 the top of the organization before you would find 22 scmebody who had within his span of control most of the i

23 resources and the responsibility necessary to ensure that 24 tha t unit could perf or m properly. That's not a good way POST REPORTING SERVICE HAMDEN. CT (800) 262-4102

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l i 35 RE: CONNECTICUT YANKEE ATOMIC DOWER COMPANY DECEMBER 5, 1996 1 to run an organization.

2 And, thus, with accountabilities not 3 clear, there were a lot of problems. And there were many 4 symptoms of these problems which I think are fairly 5 obviouc. One cymptom which was very obvious to me on 6 almost the day after I arrived was I went to a first

7 mee ti ng. It was a huge meeting. Almoct every meeting 1

l 3 I've been to has been a huge meeting. You have to gather 1

9 co many people in the hope that you've got all the baccc 10 covered in trying to understand who really is in charge l 11 of what.

12 We have the situation - and this ic j ust 13 anecdotal. But we have the situation of ACR's many timos 14 being accigned to Unit 1 out of default because the 15 organization - that's just been the default position.

1.6 If you don't know who to accion the r>roblem to, ocsion it 1 17 to Unit 1.

18 Now, that - you know, you and I can sit l 19 here and cay that doesn't make any conce at all. Bu t:

20 that's how the organization has f unctioned. A lot of not

  • 21 knowing who really was cupposed to do things.

22 Another examr>1e -- and i t ' ': 1ed to a 23 number of the violationc that they're dealing with today 24 - licensing with good intentionc. but as a centralized POST REPOR TING SERVICE HAMOEN. CT (800) 262-4102 l

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36 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 C

1 organization would make commitments that would involve 2 one or more uni tc. And the unito, either not recognizing 3 it through inappropriate communication or not I

4 acknowledging it or saying, "That's - you know, we  ;

5 didn't do that. Licensing did that." So here we have 6 commitments to make changes, whether it's updato 7 procedures or make a design change or whatever. And a a lot of them just didn't get done because the folks who 9 were really cupposed to carry it out were the particular 10 unit people who felt they didn't own that, they didn't 11 make that commitment. That wac those other guys.

1.2 Another example of accountabi1ities not being Well 13 ectablished.

14 A third issue has been the inability to 15 solve problemc. The organization han done lotc and lott 1.6 of :.tudico. And the studies over the years - and, you 17 know, you can go back through the 90*c. You can even go 18 back into the mid to late 80's. They identify an awful 14 lot of the prob) ems, maybe not al] of them and maybe not 20 fundamentally getting to the issue of leadership My 21 cuspicion that may have been taboo. But it got to a lot 22 of the problems. But after that, what happened?

23 lypically, effortt;.. ;were made, but the 24 or ganization really never got to the heart of the iccuo.

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37 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMOER 5, 1996 0 1 never really colved what needed to be colved.

2 A f ourth iscue - and, you know, I can go 3 with other leadership iscues. But j uct - these are my 4 top four. The fourth issue has been very inefficient L work procesces. And thic came about, in my judgment. I I

6 because of the difficulty in solving problemc.  !

l 7 When any organization has a problem, has l 3 events occur where you need to take some corrective 9 action, but if the only corrective action you can think I

10 of, because you're not really getting to the heart of I 11 things. Is -

and I'm generalizing -- but if the only I l

l 12 corrective action you can think of is "Let'c revice the i i

13 prococo. Let's add more controls. Let's add controlc on 14 top of controlc", so we're not really solving the I 15 problem. We're trying to prevent the problem from l 1.6 happening. And those are two difforent things.

17 I mean comotimec revising a procedure is 18 the right thing to do. But if you're not really dealing 19 with the fundamental iscue that were people properly 70 trained, did they have the right equipment, were the 21 standardo right. I mean on and on and on, the anower ic 22 not add more controlo. The anower is truly solve the 23 problem.

74 Well, ac the organiz.ation has laid on POST REPORTING GERVICE HAMDEN, C1 (800) 262-4102

, i 38 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 control after control af or control, the prococces for 2 getting work dono have gotten more and more and more 3 inet ficient, to the point that it's gotten very hard to 4 got work dono. And, thus, even with management's good 5 intentions on the need to deal with variout iccues, the 6 organization becamo just a logjam of not being able to 7 process the work through it.

8 Management became frustrated. The 9 employees became f rustrated. That led to more concerns.

10 So you can see that thece issues are all interrelated, 11 fundamentally leadership problems And what I'm giving i

12 you is various examples of how this played out.

13 So, recapping the leadership iscues from 14 my perspective, management has not set appropriate 15 standards. Management did not make accountabilitico 16 clear and then aggressively hold people responcible when 17 performance was not right. There's been an inability to 18 solve problems. And even if you know what needed to be I 19 done, you had such an inefficient work procots, that it 20 was juct hard to get it through.

21 You know, there have been questions about 22 whether Northeact got too focused on cost controls and 23 that hat contributed to it. My view of that is that 24 Northeact applied resources that they f elt were -- I mean POST REPORTING SERVICE HAMDEN, CT (800) 262M102

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, 39 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 '

! 1 they looked at how many millions of dollarc were being I i

2 spent by other companies to operate their plants. And, 1

3 in general. Northeast applied thoco dollare. j 4 The problem was that the organization was 5 to inefficient in productively using those dollars that 6 the work wacn* t getting done. It wasn* t that the company 7 was not willing to commi t appropriate recources.

8 So bef ore I call on the recovery of f icers 9 and the other members of management to addrect the 10 various categories of dofleioncies, I want to discuss the 11 broad strategies which I believe are necessary to address 12 the basic locues. j 13 Let me pause here and give you what I 14 concider to be a very important and fundamental 15 statement. Now, I absolutely believe that we can -- by 16 we I mean the leaderchip team that we have here now. We 17 can over time confirm the licensing bases f or each of the 18 Millstone units. We can re-et.tablich the design basic.

19 We can make appropriate modif Ications to correct various i

20 ~ conf]guration problems, cyctem problems, equipment 21 problems., We can make sure that we have good material 22 co nd i t i o ri . We can update procedures and we can retrain 23 personnel.

24 But my statement it that if tha t's all we l

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i 40 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 do, in my judgment we won't be ready to rectart these 2 Millstono unito. The eccential challenge - and I know l

3 we have a meeting on the 17th to discuss our rectart l 4 plans. But - and we'll lay out for you, you know, what '

5 we see at the genera) I procest But the escential ,

6 challenge is fundamentally l to change how Northeast l i

7 Nuclear functions. And that's hard to reduce to a l 8 er itical path l l

? We view that ac maybe the more important l 10 or the more limiting thing that we have to do as opposed 11 to j ust plowing through the various thingc that bring the 12 plant, the proceduret, the personnel, to an appropriate 13 condition of readinecc. If we haven't fixed standards, 14 if we haven't fixed toe procejtsoc. If we haven *t fixed 15 leadership, if we don't have clear accountabilitico, in 16 other words. I f we haven't f undamer changed how thic 17 organization doec businecs, then w t ready and wo 18 won't cock to achieve permiccion f rom the NRC to restart 19 thece units until we're comfortable, we, the leaderchip 20 team, are comfortable that we have re-established the 21 proper way for this organization to do business, 22 To achieve these fundamental changec in 23 the f unctioning of the organization, certain iscues muct 24 be successfully addressed. We have to addreco the POST REPORTING SERVICE HAMDEN, Cf (800) 262-4102

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY  !

DECEMBER 5, 1996 '

1 loaderchip iccue. I've tal ked to you about we've changed

? out the officerc. Some of us are now hires. Some of us ,

3 are loaned f'rcin other utilities. We've made changes at 4 the next level down. And we're going to continue to make 5 changes from there., l 6 Part of how we have done that has been a I 7 peer asseccment. We've accecsed each other. That -- you {

8 know, I acked for that the day I chowed up. "I want the  ;

9 officers and the directors to access cach other." And q

10 that contributed to a lot of the deciclons that have been l 11 made,.

I 12 Out another key aspect it we're asking 13 cmp]oyecc - and we did this over the pact ceveral weekt.

lA Through a leaderchip assectment, we are asking employces

, 15 to access up. I mean mycelf and the ]cadership team are l

16 accccsinq down. And we're making changec as we conclude 17 who is part of the colution and who icn't i n the position 18 they're in. But it's also very imr>or tant that employees 19 have the opportunity to accccc up. And, thus, we wil.1 i 20 have the resultc of these c urveys in September and wc

  • r c l

21 going to start dealing with the .i sc ue , the iccues that l

22 come out of that survey.

23 If the employcoc, through their 24 accessment, Indicate that an individual - and what we're i \

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! RE: CONNECTICUT YANKEE ATOHlC POWER COMPANY DECEMBER 5, 1996 (m

i 1 acking the employee is 26 questions which in reality go i 1

2 to 26 leaderchip attributec. We're not asking about, you  !

1 3 know, how technically qualified the individual ic. We're 4 acking about leadership attributes, l l l 5 So if we get f rom employecc on the upward i l I 6 assecsment a sence that an individual is not a good

)

7 leader, that individual probably is not a good leader. '

8 And, thus, we will need to deal with that. Is it a 9 matter of ctandardc? Is it a matter of expectations? In l 10 it a matter of a little bit of training? Or Ic it a )

1

.11 matter that the percon just doecn't have the right 12 attitude or the right skille and ability? But, you know, i

13 we'll work our way through that. I l 14 But my point ic that the process of i

.15 cotabliching the right leaderchip for this organization

! 1.6 is not one where the only change is come in, change out 17 the officers, come in, change out a few directorc and i

18 everything elce from here on Ic fine. That's not where 19 we are. We are going to continue to test. We'll do i 20 another leadership accessment in six months and see what 21 kind of progrecc it made. And we're juct going to 22 continue to deal with who ic part of the solution and who l

l 23 isn't. But we clearly have t o get to a strong leaderchip 24 team before we feel we're ir a good position. And that'c j i

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l 43 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY l DECEMBER 5, 1996 O

ki 1 essential to achieve excellence in the long haul.

2 The issue of high staridards really is 3 derived from having good leadership. Good leadcrchip 4 knows what the standards need to be. And that's why we

, 5 have in here recovery officers from other organizationc l

l 6 who do know what industry best practiccc are, who do know 7 what high standards are and who are committed to put

8 those standards in place within their or ganization and to i

! 9 help me in doing that acroco the broader Millotone I l 10 or ganization.

11 Clear accountabili ties. We have gone f rom 1

12 a highly centralized organization to one that, to use a I l

13 term, that's unitized. This has greatly improved l 14 accountabi1itios. It has not solved al1 clarification of i 15 rocponcibility iccuec. We are, myself and my team are j 10 gradually ferroting out what else isn't clear and let'c 17 get it nailed down and go forward from there.

18 We are --- o f ficient processes. We are in 19 the very early Stagoc of taking a corrective action 1 4

l 20 program that has been pointed out has not been ef f ective,,  ;

1 1

21 has not worked. We abcolutely agree It's largely 22 broken. And we' re goi ng to put in place one that works.  !

! 23 And that's going to be piloted on Unit 1 and then we'll l l 24 see how that goes and then we'll expand it to the other l

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44 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY l DECEMBER 5, 1996 C 1 units.

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2 So to summarize where we are on what I'm I 3 characterizing as the f undamentalc. I think we have made 4 good progrecs toward establishing appropriate leaderchip 5 and much cicarer accountabilities. But we have clearly 6 more to do in those areas.

'7 I would also say that we are f airly early 8 in the prococo of ectablishing the right s ta nda rdo ,,

9 enforcing those standards, and we're also very early in 10 the process of developing efficient processes. So I 11 think we've got a long way to go in those two f undamental l

12 areas, whereas we have made good progrecs but not l l

1 13 completed in the first two arcac.

14 1 now want to introduce -- and they kind 15 of introduced themselves to you as recovery officers.

l 16 But speaking following me will be Marty Bowling. Marty I I

17 is the Recovery Officer from Unit 2 and comes from l l

1 18 Virginia Power. So he hac a team of folks on Unit 2.  !

I 19 Jack McE] wain from Peco is the Recovery l l

20 Officer from Unit 1. He hac also a team of his folks j 21 largely managing Unit 1. And he'c going to addrest  ;

l 22 declan control issues. Marty it going to add r ee,s  !

23 management and organizational iscucc. l 24 John Paul Cowan is from CP&L. Recovery POST REPORTING GERVICE HAMDEN,, CT (800) 262H 102 1

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I 45 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY i DECEMBER 5, 1996 l r,

i 1 Of ficer f or Unit 3. He has his team on Unit 3. And he's l

l 2 going to address how our correctivo actions fit into our I l

3 longor-range effort to' recover.

4 Dave Goebel, who ic our now Vice Precident )

1 5 of Oversight. Will talk to you regarding quality l <

6 assurance icsues. ,

l I

! 7 With regard to the specific corr ective l

8 actions for the individual violationt, we have -- you 9 have at your placec a notebook containing material which  ;

I j 10 addresses cach of the proposed violationc. A I've l l 11 already stated, wc*ro not contecting any of the 12 violations.

13 The challengo - and you've said this in l 14 your remarks and I'm juct concurring with it. The 15 challenge ic to reach beyond the specifics of the 16 violations and underotand what the f undamental iccues are 17 and, thus, what needs to be done to addrecc it.

10 So., unless there are questions f or me. at 19 thic point what I would like to do is tui'n the meeting 20 over to Marty, who will talk to you further about 21 management and organizational iscucc.

22 MR. LIEBERMAN: Mr. Kenyon?

23 MR. KENYON: YecT l 24 MR. LIEBERMAN: Could I ask a quoction l I

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(~ l 1 concerning the leadership accessment process? j 2 MR. KENYON: Yes. I i

j 3 MR. LIEBERMAN: Or will comeone else be l

t 4 talking about that in more detail later on today? j l

5 MR. KENYON: I don't think any -- I'd be  !

, 6 happy to addresc questionc.

l l 7 MR. LIEDERMAN: I wasn't cure when you l l

O said that the firct leadership assecsment procesc would l

9 be evaluated.,

10 MR. KENYON: The challenge was to do the

! 11 assessment in November. I expect to have the results of i

12 it in December. I mean I haven't said December 15 or i

1 13 December 21. But our HR people now are pulling it all 14 toge t he r ., We have to have a certain number of responses l 1

15 on each individual -- because it has to be anonymous. So l l

16 we have to have at least three responses on each J 17 individual. And, you know, there's certain other rules.

I 18 Out I expect before the end of the month to get  !

! I 19 inf ormation on the results of the leaderchip assessment.

20 MR. LIEBERMAN: Were individual employeen I i

1 j 21 . assessing supervisors - just their own supervisors or i

22 their chain of command or supervicorc in general? How l l

I i 23 did that work?

1 l

24 MR. KENYON: The minimum that I wanted the )

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47 i RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 lC l

1 HR f olks to do, because I wanted it done f airly quickly.

l l 2 was to asscos the immediato supervision. Now, we talked j 3 about a possible cchome becauce now it*c getting more l "

4 complicated. If you have a first-line supervisor in j 5 maintenance and, thus, you want the maintenance f olks to 6 assecs that first-line supervisor, those maintenance .

l )

f 7 people who work for that first-line supervicor, well, 1

i a there are a number of other people in the chain of l 9 command that go all the way up to the Uni t Director or ,

1 10 perhaps even the Recovery Officer. And I want to know l 11 what those individuals think about higher up.

l l

l 12 Now, how do you do that with the group of (q/ 13 maintenance cupervisors? One way to do that that we've 1.4 talked about was to - if you got 50 people and, you 15 know, five - I'm making this up - five layers of

]

16 management, you know. In total, well, then ask ton 17 percent of them to accect comebody in that chain, 1

18 recognizing that there's a broader group out there that 1 19 also will do their piece of it. '

l 20 I don't know whether we were able to pull 21 that off for thic one. But the commitment - you know, i l

22 the commitment that -- or the accionment that 1*ve made l 23 to the HR folkc was if that's too complicated to do for 1 l

24 this fitst one, I want that incorporated for the second PO3T REPORTING CERVICE O sa"oe" c1 cooo) 2e=-41o2 I

48 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5 1996 f~

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1 on" . And we're going to do the second one in six monthe 2- becauce it is important for employees to be able to 3 exprecc opinions not juct on the immediate layer but 4 higher up in the organization to some point.

5 MR. LIEGERMAN: Thank you.

6 MR. BOWLINCi: Before starting on the 7 management presentation, I wanted to address your letter l l '

i l 8 of November 13 and the categoriec that Mr. Lanning went 9 through. In our acccccment of thic, we have bacical]y j 10 put them into criterion: Criterion 1, organization and l 11 management, which I will be speaking to, and Criterion 3.

l l 12 design control, which Jack McElwain will be speaking to, l

13 Okay. Becauce of the declining l 14 perf ormance at Millstone, several high-level ascocements I 1

15 have been conducted over the past year or so. These were i

16 conducted by groups ranging f rom wor-king-level Northeast 17 Utilitiet employees to external concultants recognized l 18 throughout the industry. l l 19 Ac a recult of these acccccmentc. the l

l 20 primary root cauce was management. And the failure of 2.1 prompt - the failure of management was the performance 1

22 of senior management. Specifically, they cent l 23 conflicting meccagcc on cocts and scheduling., compliance l

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l 49 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 R

1") 1 of oversight. They f ailed to addrecc both internal and 2 external feedback, virtually all of which was telling 3 them that the program was not worki ng, 4 They did not encourage a questioning 5 attitude or teamwork and they made commitments which were  ;

6 nct met. Specifically. .they set low standards and 7 expectations which did not keep pace with the level of t

i 8 change required and which were taking place throughout J l 9 the industry over the last five or to yearc. l 10 Ac a result, operating standards became l

11 unacceptably low but were tolerated by management at all

( 12 levels The results of this toleration of low standards 13 wac manifested by non-conservative decision-making, 14 degraded conditions, ineffective oversight and celf- )

l

, 15 assessment, loss of configuration and management, and, at l l

16 already discussed, numerous non-compliance of regulatory 17 requirements and licensee commitmentc.

l 18 I wanted to make clear on the first item, j

19 non-conservative decision-making, that I do not know that 1

j 20 anyone intentionally contt ibuted to any uncaf e practice.

1 A

21 However, I do believe an extremely complacent environment

! 22 oxicted, an environment characterized by a lack of a i l l 23 questioning attitude and a belief that just becauce i 24 "That's the way we've always donc it, then it must be POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l , , . . - - - . . , , . . --, ..,,- . . -- - - - - , ~ . , . . . . -

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} RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY 3 DECEMGER 5, 1??6 iO 1 1 The first step in establishing 1, .

i j 2 accountability ic to octablish responsibility f or the l

] 3 performance of the unito. Druce Kenyon talked to thic '

I j 4 iscue. And I want to let you know that I am responsible -

l j 5 and accountable for Unit 2 and Jack McElwain for Unit l' I i.

, 6 and John Paul Cowan for Unit 3.

! 7 Then we must align our cupport

.i J 8 organizationo consistent with those responsibilities.

1 4

l 9 Inherent in thic is the establishment of programo and ,

j 10 procesc OWhershipc. Once ownership 10 established, then l 11 accountability can be enforced. The primary measure of '

1 i 12 accountability will be our meeting of commitments.

13 The firct step in offcctive overcight in 4

i j 14 self-ascessment by line management. The second step is j 15 an ef f ective independent oversight organization which in 3 ,

l 16 focused on the offectivenecc of 11he management self-1

] 17 ascessment.

?

! 13 To do this,, not only muct line management 19 accept overcight, it must champion the procent. Davo i

! 20 Goebol will speak later about the plans f or recovery of

21 the oversight organization. But no matter how good it l

I 22 does, it will not be enough if line management does not i

! 23 champion the oversight process and support it with ito 4

24 best people.

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1 The third step i n an ci f ective nuclear ---

l 4

l 1

i 2 is an effective Nuclear Safety Ascessment Board which  !

1 l

l 3 muct f ocus on two key things; first, the ef f ectiveness of I

4 the nuclear oversight group, and, second, lino f

j 5 management's ability to address and resolve safety- <

6 cignificant' issues.

)

1 7 I will speak further about the key line )

1 I

S management rocponsibilities of celf-accessment and 9 corrective action next To have an offective self-  !

10 ascoccment program requires all of these attributes Two l i

l 11 are key. First, we must instill a ques tioning at titude., l 12 We must challenge the status quo and the notion that if

1. 3 it's not broken, we do not need to improvo it. Second. I 14 we must lower the threshold of what is being identified 15 Thic requires getting over the mindset that identifying 16 thi ngs is bad. Quite to the contrary, the more potential 17 ie. sues that are Identified and resolved, the more likely 18 we are to prevent incues f rom becomi ng more signi ficant.

19 What we must do, as hac already been 20 stated by the NRC and by Dr uce Kenyon, ic we must 21 initiate a offective correction actionc program 22 Inherent in this is resolving regulatory and safety-23 significant issues. And I will address thoce in a few 24 minutes POST REPOR1ING SERVlM HAMDEN. CT (800) 262-4102 I

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53 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1.996 b" 1 We need to restore configuration 2 management. And Jack McElwain will discuss that issue.

3 And theri we need to return the units to the highest 1

4 standards of equipment and material condition and l I

5 housekeeping. And John Paul Cowan will address that

! 6 during his presentation.

7 MR. LIEBERMAN: Mr Bowling?

l l 8 MR BOWLING: Yes?

9 MR. LIEDERMAN: Can you go back to the 10 previous slide? You made a comment, "We have to change 11 the mindset that identifying problems were bad."

12 M R ., GOWLINO: Yes  !

l 13 MR. LIEDERMAN: Why was there that l 1.4 mindset? What have the employees told you and, you know.

15 the new management team why that mindset was there?  ;

16 MR BOWLING: There -

17 MR. KENYON: Let me try it.

18 MR. DOWLING
Okay.

19 MR. KENYON: I talked about the f act that 20 managemont wac having difficulty in dealing with the 21 problems. And, yoii know, if you just follow the 22 psychology of it, If you can't get problems fixed, at 23 some point you don

  • t want to hear about it. I think that l 24 was a lot of i t ., Now, whether it was all of it or not, l

l 1

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4 54 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 I don't krow.

2 A comment that I meant to make is that in 3 our remarks we are - you know, we're the new team. Wo 4 weren* t here when a lot of the r>act problems were really 5 created or developed into worse problems. And, thus, we  !

6 have not spent a lot of time on the hictory of it. And, 7 thus, in our remarks we're not going to spend - we'll do S it a little bit. But our intention ic not to spend a lot 9 of time trying to explain past management. I mean it

  • c l l 10 not a very fruitful exercice from our perspective.

11 We think we know what good leadership is.

12 We think we know what needs to be done And we're 13 plowing on to do that, not with total disregard to the 14 history of thingc because we do have to be mindful that 15 there are some past programs out there that exist ac j i

l 16 commitmente this company made in variouc documents which l- l'1 have come valid points to them, but not all There are  !

l i

18 some past commitmento that either are not the most  !

19 appropriate thing to do baced on how we currently I j 20 under stand the issucc or they're really not the right i 21 thing to do baced on how we currently understand the l

22 issues. And, t h oc ,, we have an obligation to clean that l l 23 up from a regulatory per spective no you know which j 24 commitments we're still going to follow throu;h on and,

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55 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY I DECEMBER 5. 1996 1 thus, those we will incorporate into our recovery planc. 1 2 Out we also need to tell you which commitments we just )

3 don't think are all that relevant to what we think we l 1

4 need to do to solve the problems.

5 Now,, I've digressed a little bit f rom your )

l 6 question. Out going back to your question, there's not 1 7 a lot that we're going to spend time on, at least from l l

8 our perspective, on explaining past management practices.

9 We ' 'e a new team. We're here to do what we think is ,

l 10 right.  ;

1 11 MR. GOWLING: Let me f ollow on and perhaps i

12 get at the eccence of your question currently. The '

13 connection between identif ying and resolving problems and 14 the raising of standards has not been -- was not made.

15 30 it appeared to many that the identifying of problems 16 was simply creating work for comeone else. And that's 17 the mindset that we need to change.

18 MR. MI L.L ER : Yes. I think it is 19 important. And I think what Jim is perhaps focusing on 20 here, it is important to understand what those mindsett, 21 were and a bit about what the genesic of those thoughts 22 were. Arvj 1 guess it will be important as you do these 23 surveys, for example, you know, to hear what people havo 24 to say and to make certai n that you are taking that into POGT REPORTING SERVICE HAMDEN. CT (800) 262-4102

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  • RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 l

1 account as you roll out your expectations so that you're -

t 2 euro to addrecs any carryover, if you will, from the '

3 past. j 4 And I wouldn't disagree with what you're 5 caying Mr. Kenyon, about your primary f ocus hac to be on 6 setting out what you know le the right thing to do on a 7 go--f orward bacis and establiching standardc. We'll l 8 comment as wo disagree with what you're setting or 9 cotablishing expectations But I thi nk that that ic -

i 10 - that ought to be your primary focuc It's j uct that, i

l 11 you know, in looking back there may come carryover and --

12 because what you have is you do have a skeptical work l

13 f orce in many respects. And ac you caid, it's renconable

! 14 that they are skeptical, given the pact And so you have 1

15 a communications problem here of corts of convincing thic 16 staff, your staff and your work force, you know, that l

l 17 this is different. This is not just another -- there 18 have been managers who have come and gonc in the past.

l 19 And we've -- I wacn't i nvolved I'm new to thic region.

20 Out I know that there have been many enforcement 21 conf erences. And a part of the precentation wac that 22 we're all new and this is a new program. Go I think 23 that's the eccence of what Jim i" asking about 24 And ao much as anything, t.'s perhaps a POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 f

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l 57 I RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996

- I U 1 caution. You know, I don't know what answer you can give I

2 here. But I think it's in that vein that we ask thic )

3 question. l 4 MR. KENYON: And I understand. And 1 5 don't want to leave you with the improccion that we are 6 not endeavoring to make sure that as we think we know 7 what the answer is, that that needs to be calibrated with G 2.ome retrospective looks. Ac an example ,, in the employee 9 concernc area I think I know what a lot of the problemt, 10 were. Out I have taken the time to have two f airly good-11 cized meetings with employecc where the eccence of the 12 meeting was not me walking in saying. "Now, I think these 13 are the six fundamental problemc. Do you agree or you 14 dicagreeT" It was, "Come in. Hero's a blank sheet of 15 paper. Let's talk about how you see the problem. " So wo 1

16 had a lot of good dialogue with the employecc. We wound i 17 up with -- you know, whether it was stated exactly the 18 came way, wound up with virtually my list, but also wound 19 up with come nuances that I thought were in.portant.

20 So I'm not tr ying to leave the imprescion 21 that we're not trying to calibrate what wc* re doing with )

1 1

22 come sense of hictory and curr ont employee attitudes. I l

1 23 was trying to cay that --- I'm not goi ng to Opend a lot o f I 24 time defending -- I i

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58 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 e-- -

I 1 MR. MIL.LER: Yes. And I think we 2 appreciate that. And I think that there are many forms 1

3 and many ways to get f eedback. And I think this approach l 4 that you've talked about of getting assessment, if you I

5 will, not just "Here are my technical concerns", but l

l' r 6 "Here's my assessment of leadership assessment", that 7 that is - that should provide you como good insights.

J O And that's very important. And I think that, you know, l 9 out of that may come, you know, a bit of insight again 10 about past hangups that you need to contend with and deal l

l 11 with.

l 12 MR. BOWLING: I've gone through a series 13 of issues on what we must do. This lays out the basic 14 approach f or what the Recovery Of ficers are doing to make 15 the long-tc rm Northeast Utilities organizational changes i

16 that Gruce Kenyon has referred to.

17 Now I'd like to updato you on actions 18 being taken in key areas. Now, these areas you will l

19 recognize as previous commitments by Northeast Utilities l 20 in the Improving Station Performance Program.

21 First, let me talk about nuclear safety l 22 and reactivity management. We will be implementing a l

23 nuclear safety philosophy for the Millstono station.

24 This philosophy will be based on a simple tenet. Each POST REPORTING SERVICE HAMDEN, CT (800) 267-4107 l

I 59 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY l DECEMBER 5, 1996 i

1 per son at this station must have a prof ound respect f or 2 the reactor coro. Inherent in this tenet is the need f or l

3 defense in depth and conservative decision-making.

4 Specific guidance will be provided. But it is our 5 expectation that management at all levels will be guided 6 by thic policy 7 Gocond, each of us, although in a 8 different way, have elevated the importance of nuclear 9 cafety and regulatory compliance in our organizations 10 that we have taken over on October 1.

11 Third, moct important point, we are re-12 assessing the role of our Nuclear Safety Assessment 13 Board, the NSAB, which is our third level of oversight.

14 It needs to be more f ocused on management issues. After 15 all, management issues is what has gotten us here today, j 16 To accomplish this, we have placed senior i

1 17 management on the Board, including the four new Recovery i 18 Officers. And we'll add additional highly-qualified 19 external members.

20 In order to raise standards, we must start 21 with our management team. This requires development of i

22 their leadership capabili ties. This is done primarily by 23 clari f ying organizational roloc. and responsibilities and 24 recovery team mentoring.

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60 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996

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U" 1 This slide and the next slide provide 2 specific areas of training and development that are being 3 utilized by one or more of the units. I will not go into a detail of these. Gut I would say that each recovery team 5 is bringing its best practicos to their unit. This 6 provides an excellent opportunity for Millstone to 7 evaluate and ultimately reflect the best of the best.

8 With proper leadership, accountabi1I ty can 9 be established. We will utilize this basic model. Key 10 to this model are the following steps. And I want to 11 share with you where I think the recovery t ea m+.;. a r e in i

1 12 this process. 1 i

l 13 Fir st, as Bruce said, we need to set high 14 standards and expectations. This is what we're doing ll 15 currently. Then we need to establish organizational 16 roles and assign appropriate resources and priorities. l 17 You cannot hold anyono accountable if ,

i 18 they're at too low a standard and they don't have clear i

19 under standi ng of what they're rocponsible for and they 20 don't have the resour ces to do the flob. You cannot ho]d ,

21 them accountable. You must set the right standard. You

'22 must ensure that they have ownership and responsibility 23 for their area and you must provide them the right 24 resources. T hen you can go to rigorous accountability,,

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l 1 61 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY OECEMBER 5, 1996 7T U 1 that is meeting our commitments.,

i i 2 Once that's done, the cycle Is repeated. j 3 We raise the standard, we adj ust organizational roles and 4 recpons.ibilities and recourece as required and we hold

5 them accountable, 1 1

I 6 Now, where are the teams after the first l

7 two monthc? Our major of f ort to date has been to set the 8 standards We are also in the process, particularly in

-9 our engineering'organizationc, of looking at the roli 10 and recponsibilities, particularly with respect to 11 Maintenance Engineers, Syctem Engineere, Component 12 Engineers. Those are the drivers which Influence work 13 control and either make work control work or it doesn't.

14 Once we complete that prococc, then we believe we will 15 have an accountable organization.

a 16 Corrective actions. There has been como j

.17 improvement in corrective action in two primary ways.

18 One., there has been a unit organizational f ocus. That is 19 the unito have accumed ownership of the corrective action

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20 program. And, second, the root cauce program has been j i

21 enhanced and a cyctematic ceries of root cause t rai ni ng

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22 is under way.  !

j 23 However, the corrective action program 1 24 still needc improvement. Your recent inspection reports l

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1 clearly indicate that the corrective action program ic l 2 not ef f ectivo. Our own internal nuclear oversight audits ,

3 which have been ongoing and will exit lator thic week l 4 also indicate that the program is ineffective.

l 5 I have opent time with those auditorc to 6 understand why. And the primary reason is a lack of l 7 accountability and ownerchip. '

l

! 8 We understand that the clock for res,ta r t 9 will not start until we can demonotrate to you that the  !

10 correctivo action program ic working. We fully 1.1 understand that we have no higher priority.

12 MR. DURR: I would obcorve that the 13 corrective action program, although we know it*c 14 chronically demonstrated ac to be ineffectivo, but what 1 l

15 my concern ic f rom a caf ety perspective is you have three l 16 power plants out there today that pose safety threats if

)

t 17 they're not properly managed. even in the condition that 18 they're in. And I've been waiting patiently sinco early 19 this summer when we cent you a Ictter that said the l 20 Corrective action program wag broken, don't rectart. And l

21 as I flipped through the notebook that you provided us, 22 I see a lot of planned thingc. which meant that the 23 violations that we're talking about today have not been 24 cor rected, either; that they'r e still out there. They're l

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 1 still lingering out there and thinge., are not being done  ;

2 And so from my perspective, I'm a littlo 3 concerned that while you are reorganizing the leadership 4 team, you *;ill have the day-to-day respo nsibili ty for 5 keeping these plante cafe. And the corrective action l

6 progr'im is a fundamental part of that process. And I l

! 7 don't get a sence that there*c a lot of motion in that l

8 direction today to fix the corrective action program.

9 Now, that may be a mit. perception on my part. But I ctill l

l 10 don't see that there's been a lot of motion in that l

l 11 direction. And from our inspections, we're still 12 continuing to see that things are not being completed l 13 comprehensively and thoroughly.

14 Go I would like some assurance beforo we l

15 leave here today that that corrective action program -- l i 16 that there is a -- is movement in that direction. And 17 I'm not cure that we can wait until -- because changing 18 the Icadership and some of the attitudes within your l I

l 19 organization is a time--dependent thi ng. It*S not going l l

20 to happen overnight.

21 Cut we need some assurance, I think, in 22 the immediate f uture that those things that are lingering ,

l 23 out there -- some of these things affect the spent fuel l

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24 pool and you have fuel in there. So -- and I cce that )

1 1

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l 64 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY '

DECEMBER 5, 1996  ;

I 1 they're still planned. And come of those things linger 2 f rom 1995, violationc that we've identif ied in 1995. So l 3 I'm a little distrecced to see that come of these thingo 4 haven *t been completed, that they*re not finished.

5 So can you addroce that part of it f or me?

6 MR. BOWLING: Tho question can only be l 7 addresced from the standpoint of the way we're l 8 approaching it. We need to get accountability and l l 9 ownership onto the corrective action program. That we  ;

10 nave recently dono. For Unit 2. I am responcible and 11 accountable for the corrective action program. And the j l 12 recovery team of f icert. on the other two units, likewise.

i We are 13 in the process of making the l i 14 organizatiori understand what the standard 10 for 15 corrective action and meeting of commitments. And we're 16 eligning the recourcoc in order to allow the organization l

l 17 to work on them. And that is happening. That is 18 currently happoning.

19 I t 10 -- we have no higher priori ty, which 20 means this is what we need to be working on now. And 21 that's our intention.

22 MR. KENYON: Okay. But I think t he 1

23' more that needs to be caid. I mean we clearly recogni.e 1 24 we have a recponcibility for the plantc' shutdown and be l

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65 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 saf ely operated ac they are now., And, thus, I don't want 2 to leave you with the impreccion that what's going on is 3 that the exicting management team does not recognize what 4 thingt aro identified on a day-to-day basis and, you know 5 -- I'm going to - .you know, whether Marty does it or j 6 Jack or one of the Recovery Officers. I mean we have a 7 management procese in place now that is looking at what*c I 8 -- where these plants are on a day-to-day basic and we're 9 dealing with those icsues.

10 The bigger picture is that the broad i l

11 program doesn't work the way we want it to work. And, l i

1.2 yes, there's come things out there that rieed to be l l

13 addrecced With difforent degrees of priorities. B u t ---

14 Jack, I'm just going to pick on you. I mean what do you l 1

15 do on a daily basic to deal with thoce i ss uec's .

l 16 MR. McELWAIN: On a daily basic what we do 17 at each of the units is to have a morning management 18 meeting where overy identified issue is gone over. It's 19 assigned to a specific individual. And we do track thoce 20 itemc. We have follow-up itemc at a morning meeting to  ;

21 come back and talk about them. We have enhanced and 22 accolorated the quection about if there's an operability 4

23 determination required, how long it can take. Even  !

1 24 though the proceso is not yet to the point where it i

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I 66 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 l

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J L 1 defines the crispness needed to come back with 2 operability determinationc 50.59 reviews or corrective i

3 action, we are enforcing that ahead of the program

! 4 actually being to the point where it's endemic in the l \

S program. i l l l

6 I think you would find that we spend a lot l 7 of time in the morning and we also have weekly management l

8 teams to look at corrective actions, both proposed ac

! l 9 we.ll at those completed. And we've been raising the lo standar d on being critical about 'those issues, making 11 sure that the root causes are reflected in the corrective 12 actions. Correctivo actions are planned to be done in a 1

13 timely manner. And i f- there's immediato response 14 required, we will work around the clock, if necessary,

.15 which has been donc at all the units. to reco1ve incuec 1

l l 16 as they come up so we don't wind up with a lingering i l l 17 problem that j ust gets put in a pile and looked at later. I i

18 For those issucc, we accign people 19 responsibility and accountability for making thoce 20 cortective actions happen. We alco have, ao Marty wat 23 alluding, unitized corrective action manager for each 22 Unit.

23 MR MILLER: This may be difficult to get 24 i nto, you know. details here. And I wouldn't propoco to 1

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67 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1976 0 1 try to get into details. But I think it is essential --

2 and surely you recognize that while you are in the 3 process of this f undamental change in management approach 4 and all of the things that you talked about -- and we 5 would agree. I mean it is, essential.

6 You talked about perhaps the limiting 7 thing for restart being putting in place a management 8 team and an approach that will give us all confidenco 9 that any change you make is going to be long-lasting as 10 opposed to having it be a one-time thing that later f alls 11 back to the same ways. That is vital and we wouldn't 12 argue with that l 13 I think what --

perhaps what Jack is 14 talking about is that at the same time it is encumbent 15 upon you, of course, as there are things that are 16 immediate, to deal with those things on an immediate 17 basis. And certainly f rom our side, our job is to -- and 18 I went into great length on this yesterday in the Haddam 19 Neck discussion. Our f ocus is r eally, as yours needs to 20 be, both long-term and short-term, of course. And 21 anything that impacts on the ability of systems to 22 perf orm their function has to be dealt with on an 23 immediate basis. And so I'll make certain that we take 24 up any of those with you if we have them. That's l

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1 f RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY l l OECEMBER 5, 1996 C 1 paramount. I think you would agree with that.

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! 2 MR. BOWLING: Yec. And let me just 3 reiterate one of the earlier points in terms of the 4 organizational changec. I mentioned that each unit, l 5 although comewhat differently, elevated the role of I

l 6 nuclear safety and regulatory compliance in the 7 organization. That is to accure that we are aware at the

! 8 top management levels of what the iscuec are and whether ,

1 1

9 the right decisions and determinations are being -- and 1 10 actionc are taking place with current-day iccuec.

11 Go my answer to your question is there*c 12- more senior line management involvement in nuclear saf ety 13 and regulatory compliance issues today.

14 Let me move to employee communications 15 then. And each unit hac developed a comprehencive 16 communication plan. The primary purpoce of thic is for 17 management to start regaining the truct of its employeen 10 through open and honest two-way interaction.

10 Our expectation is that line management 20 will be the avenue of choice for recolving employee 21 concernc., Thic expectation can only be met when 22 management is recponsive and timely to employee iGGucc.

23 We do recognize that honest and 24 profeccional disagreements will occur. In these cases, POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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69 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5,, 1996 C' 1 it is management's responsibility to be forthright in 2 addreccing these disagreemente and make conservative 3 decisions based on sound technical facts.

4 Alco, management must encourage employees 5 to identify and report potential icsues. Only in thic

) 6 way can management positively identify, pro-actively a

! 7 identif y and resolve iscues before they become more 8 significant.

9 With recpect to the last two areas, 10 procedure development, work control, we are starting to 11 make progress. A number of items are listed on these two 12 clidec. And I will not go into detail unless there are 13 specific questionc.

14 In closinq, I want to say to you that the 15 recovery teams from CP&L, f'oco and Virginia Power are 16 committed to Millstone. Just as TMI was a watershed for 17 the nuclear industry, so will be Millstone. We must 18 emerge stronger and clocer to our goal of excellence as

.19 a result of this experience. If we are to achieve this 20 goal of allcoce, then we must stop tolerating low 21 ntandards and ctart raising them. Only then can we be 22 trusted, 23 If there are no more questions, I'd like 24 to turn it over at this time to Jack McElwain for POST REF'OR T ING SERVICE IlAMDEN. CT (BOO) 262-4102 l

70 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 J 1 Criterion 3, design control. l l

2 MR. LIEBERMAN: Mr. Bowling, could you 3 give us a little insight in how you're actually 4 communicating those new standards to the workers who have l 5 to implement these new standards and how you're measuring

! 6 - how you intend to measure whether those standards are 1

7 bei ng - are, in f act, understood and bei ng implemented?

8 MR. BOWLING: Well, let me use a l

! 9 corrective action as an example. The standards being l

10 communicated is that we will meet commitments. If we l 11 make a commitment, we will meet the commitment. Inherent l

l 12 in that is determining who is the owner of the commitment 13 and do they have the resources necessary to do the job.

14 In terms of Indicators, there are a number l 15 of indicators that can be used to measure the status of I

16 corrective actions. And these are not total numliers of  ;

17 items that are being identified. But these are the 18 indicators such as number of open items, say, with I l

1 19 condition reports or the number of overdue . items, as well 20 ac the commitment dates to the NRC f or issues that are to 21 be responded back to you, as well as our schedules f or -~

I 22 that will be in the recovery plans for making i 23 modifications and material hardware improvements to the l

24 plant, working off,of the wor k order and saf ety-related l

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71 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996

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1 work order backlogs would be typical types of indicators.

2 MR. LIEDERMAN: But how are the standards 3 getting to the troops? Is it by memos? Is it by 4 procedures? Is it by lectures? Is It one on one? I 5 mean how are you actually getting the word to the people ,

6 who need to get the Word?

7 MR. DOWLING: The basic approach being 8 uced is a top-down. In other words, the recovery teams j 9 are mentoring and coaching and setting the standard to j 10 the management of each unit until they underctand and can l 11 internalize what the standard is. Then with the 1

l 12 communication plan, our expectation and what is happening 13 is they're carrying it down to the next level and then to 14 the next level. j 15 In addition, as Bruce Kenyon indicated, j 16 each of us are meeting with all of our employees to i1 17 communicate what our expectations and standards are. For 18 example, on decision-making, which ic one of thoce areas 19 that I have communicated to all the employees on Unit 2, )

20 my expectation is that we must make decisions. We cannot l

l 21 move forward without making a decision. No decision is 22 not an acceptable f orce. I understand that people don'L i 23 alwayc make the right deciclon. We're human. We make 24 mistakes.

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1 72 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMDER 5, 1996 1 The standard, though, is that wo 2 understand. You make your best effort and you make a 3 mistake. We learn from that and we move on.- We don't  !

4 have - we don't punish you for making a mistake If j

L you're giving your best Offort.

6 Go those are the standard? and ex- the l I

7 types of standards and expectations that have been 8 commur icated. Non-punitive management so that decision-I

? making, which is obviously crucial to moving f orward, can l 10 be made in an open and - open, free environment.

11 MR. LIEGERMAN: Are you speaking to the 12 employees - are the various recovery managers speaking 13 in large groups? Small grouos? Are you walking the 14 plant? l 1

15 MR. BOWLING: All different ways. Large i

16 groups, certainly using the written media to every 17 extent, way.. daily newsletters, newsletters from each of l i j 18 the recovery officers signed by cach of the recovery )

i j 19 officers. We' re meeti ng wi th small groups of employees, i

J i 20 Just for example, I have mot with every, I think every, i

j 21 system engineer individually on Unit 2 for two reasons.

} 22 I want to let them know that I consider them an important i

23 player to our problem resolutions. Second, I want to 24 know what the material condition of my systems are. And I POGT REPORTING SERVICE HAMDEN, CT (800) 262-4102 Y

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C 1 I met with each one of them individually.

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2 We've met in cmall groups with small sub-3 departmente, met with departmento, met with all handc, 4 that in the entire unit. I have met with - meetings 5 with j ust the first-line supervisor and above just for 6 this purpose of communicating'to them what the standard 7 and expectation ic and what they needed to do with their 8 employeen.

9 nre there other -- John Paul, do you -

10 MR. COWAN: Yes. To answer your question  !

l 11 on both what are we doing individually and collectively, 12 a part of the recovery plan which I'll speak to has a 13 communications plan. As indicators, as Marty said, a key 14 indicator is do we receive or achieve the results. And l l

15 although we've talked a lot about the top-down appr oach, 16 the results come at the bottom. So if we achieve the 17 results, the standardc are right. And I'll talk some 18 through standards, as Marty caid, cpecifically material 19 condition and others. Then we can be f airly cer tain that  ;

20 the bottom underctands what's expected.

21 There are hard objective indicators, such 22 as corrective actionc being achieved. There are 23 sub}cctive indicatorc, but clearly measurable. Are the 24 bottom of the organization aligned with the top of the POST REPORTING OERVICE HAMDEN, CT (000) 262-4102

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j 74 l i RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY I OECEMBER S, 1996 i0 j 1 organization? Who does a communication force? For i

} 2 example, to the pubile, yes, we'll all have meetings in 1

{ 3 some f ashion with the public. I've al ready boon involved 1

i j 4 with a number of the public forums. But ultimately it i 5 will be our employees. And we will have the employees be f 6 our principle communicators of our standards and 7 measurements. And I think that will become obviouc.

8 My experience at the Grunswick plant wac 9 - and it was noted in the readiness assescments by the 10 NRC, as well as ourselvec - that we were all in synch 11 from top to bottom. Anyone in the organization can be 12 acked any question and it will align with our overall 13 objectives.

14 Mycolf I meet individually with luncheons 15 with 12, 10 to 12 people. I've met multiple times with 16 the employees to both tell them where we are going and 17 listeni ng to them, what they have., As late as yesterday, 18 I aricwered to all the employees in Unit 3 the lict of I 19 iccues that they had brought to my attention and where we 20 are i ndividually on those issues. And I committcd to 2.1 f ollow up with that. And that was sent out both in paper 22 form as well as electronic mall.

23 So I think, as Marty caid, it's a multi-24 faceted approach. And I'll be talking a little bit more POST REPORTING DERVICE HAMOEN, CT (800) 262-41.02

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4 1 75 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY l DECEMBER 5, 1996 I

1 to that and addressing your point. 1 2 MR. LIEBERMAN: Okay. How about with Unit l

3 I?

4 MR. McELWAIN: We have at Unit i utilized I

5 the same process, the same small groups, large groups, '

l 1

6 cleanup day, being out there cleaning up the plant with '

7 the people, talking to them while we'ro talking i t ,, .

8 talking about standard" l

9 And one of the things that John will 10 probably cover later is that we actually have to model 11 the behaviors we expect people to assume and to be 12 comfortable with. We have to have a questioning gv 13 attitude. We have to be able to embrace an issue when i l

14 it's raiced and to help come to resolution with that.

]

15 And that's also part of that face-to-face, one-on-one, i 16 one work group on one or group on group, as far as that 1

17 could be, communication. It's not just talking to the  !

18 people. It's modeling what we expect. It's telling  !

19 people clearly what we expect of them and what we expect i

20 of ourselves and then showing that we actually do do 21 that, model that behavior.

22 MR. MILLER: I think that's the vital 23 point right there. I mean it is escential that you are 1

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f DECEMBER 5, 1996 I m

1 issuing guidance documents and the like. Dut in the end.

2 far more important in communicating your standards is 3 going to be what you do, how you react to problems. I 1 l

4 mean we consistently see that. You know, what I 5 distinguishes poor perf ormers f rom good perf ormers is not 6 what top management says. Unif ormly - and I'm f amiliar l l

7 with more than half the plants in thic country. Many of j i

8 them good performers, many poor - a number of poor 9 performers. And it *c hard to distinguish between what ic 10 said at the top and what speaks louder than anything is i 11 what does top management do when problems arise. And to 12 that's, I think, a key point, Mr. McElwain. ,

1 13 MR. BOWLING: One other comment to add to 14 this. Ac I indicated bef ore, we have three organizations 15 behind M i l l s t o ne ,. And we are using those as i 16 opportunities not to j ust talk about the standard but to l

17 cee the standard. And to ther c's numerous benchmarking 18 opportunitlec which we have alr eady taken advantage of to 19 have Millstone employees go to the three utilities and j 20 see for themselves what the ctandard ic.

21 Any other questions?

22 MR. McELWAIN: Good morning. Ac you'll 23 see, the themet that I'm going to run thr ough today are 24 c0sentially another alignment piece, the things that PO3T REPORTING OERVICE HAMOEN, CT (800) 262-4102 1

77 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 G 1 We're talking about, modeling behaviors and those other 2 issuec are about leadership. 30 as we go through this, 3 you'll see this particular clide is one you've seen 4 before.

5 Marty talked specifIcally about the 6 management side of thic piece and how it relates to the 7 performance problems. And what I'm going to talk a O little bit about now is the design piece, the control of 9 configuration management, ac well ad other design iccues.  !

10 nc you can see and as is plainly evident 11 In both the NRC correspondence as well as the internal

.12 and external accoucments that have been done over the 13 past year or more, we failed to properly implement an 14 effective decign control procecc. Along with that, we l 15 also had inadequato maintenance of deGign basis documentG l 16 a rid ineffective 50.59'O. I think Wayne talked 17 specifically about thoce iccuec and cited several i l

10 examplec that we do not take an exception to today.

1. 9 Some of the cauces are IIsted on the next 20 couple of clidec. And they also, all of theco, 21 Incorporate the management iscues that were discucced 22 earlier. And, again, it's more about leaderchip than i t 1

23 is, quote,, management. l 24 The design basic wac not maintained.

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1 Plant configuration was not maintained to the standards 2 it should have been, certainly We didn't have a good 3 design change process. And resource allocations and i i

! 4 deficiencies, Bruce talked a little bit about it. We did

5 spend the normal amount of money, if that's the right l 6 phrace, for a normal utility. But we obviously did not l 7 spend the resources to do things properly that s houl d i

G have been done.

4 9 And, again, we also mentioned earlier, as 1

10 wel1 as did Mr. Lanning, about juntifying doficiencien i

l 11 rather than solving the problem. And that has

, 12 hie.torically been a documented issue here. )

i i

I j ~'N 13 One of the basic tonote that we didn't do  ;
(O I

! 14 well was not orily did we not have suf ficient ownership of- 1 l 15 the FSAR. I don't believe we had suf ficient understanding 16 of what the value of the FSAR is and how it has to be a 1 1

j 17 living document, how it has to be maintained. And that's j i  !

j 18 clearly documented in both NRC correspondence and again

) 19 in our own NU documentation about looking at it 20 internally as well as having either the FCAT or the NCAT 1

l 21 document, ACR 7007. All thoco issucc were clearly 1 22 identified and obviously this is j uct a restatement of 1

1 j 23 thoso.

3 j 24 In the time here, it's been obvious to me 4

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\'-^4 1 that all of those iccuec are absolutely right on And

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2 the fundamental causes addrocced in all theco documents l

3 are the iccucc that we're attacking.

I l l 4 Some of the things we must do, just to l

l 5 keep the came theme no we go through here, is we 6 definitely have to improve the 50.59 process. We 7 currently have initiated a deep, broad 50.59 training 3 prococo and we have had three clasces thic week and we'll 1 \

l 9 have three claccee for the next covera] weeks until we j l

\

l 10 have everybody understanding what the 50.59 process is i

i 11 about, that it'c not j ust looking at the tech specs, you l l

12 know, and drilling down through the FSAR, the SAR, the 13 commitmento that we've made in the past and looking at j 14 how we fundamentally perform SO.59, both screening ac l 15 well as an evaluation, full-blooaed cafety evaluation.  ;

t l l 16 As I'm sure you're aware and ac 10 well l

l 17 documented, that is comething that has not traditionally 18 been either concictently done here or in some cacec well 19 done.

i l 20 Along with that, we have to improve the 21 linkage ofthe 50.59 prococc to operability 22 determinations. The process did not absolutely require 23 that for an operability determination you should do a l

l 24 50.59 screening or a full-load determination if the POST REPORTING SERVICE HAMOEN. CT (800) 262-4102 l

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i 80 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY i DECEMBER 5, 1996  !

I screen yields those required results.  !

1 2 The configuration management program, we j 3 definitely -- this has been repeated earlier. Establish 4 and understand a iIconsing basis, establishing ownership l

5 for that. And establish programmatic oversight of our l  ;

I 6 ability to both maintain and establish a licensing basis. '

l 7 Design control process improvements,. We l

! O nave revised the design control manual. Wo continue to i 9 revise that. It's not a perfect document. And as we go 10 through with the 50.54(f) offort and other thinus that 11 will be related to in the ORP in this meeting on the  !

l 1

12 17th, we will definitely have to keep moving that j 13 document to a higher level as issues, other issues, are 14 uncovered, as Bruce said and Marty alluded All the 15 issues at Millstone are not yet uncovered I

  • rn cure 16 there will be other things that we'll have to look at to 17 improve the process that we have already revised several la times but are now goina to look at to continuously 19 improve, like we WIll all the other processes that were 20 undertaken.

21 The FSAR maintenance was obviously a big 22 issue. I keep saying "obviously" because it is we l .1 23 documented in the documents that I mentioned earlier.

24 And we will have to develop and are in the process of POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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i 81 j RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY 4

DECEMBER 5, 1996 f

4

' I

^

j u .1 developing a procedure that has been recently issued to

]

i 2 maintain the process of FSAR upda ting, making sure it's l

. s accurate. How do you do that? What's the process for

}

! 4 where in the change in the design, for example, does an i

j 5 FSAR change update come? When do you do it? How do you 1

j. 6 do it? When do you submit the FSAR change documentation I

7 to the agency, for example? And all the things that are i

j- 8 required along that process. So we have issued that.

i

{ 9 Wo are looking at NCR process changos, as i

l 10 again Mr. Lanning r>oint out. The NCR process, one of the t i

j 11 issues with it was it did not require an operability i

12 determination procedurally. We're changing the process.

l 1

13 We're going to change the f orm to require, for example, 1

14 an operability determination which will tie back into a I

l 15 50.59 scrooning review, as well as a saf ety evaluation i f i

i 16 it's required. Those processes are changing as we speak j

, 17 and we ; e developing that Again, we'll pilot that in 18 Design Engineering Unit I working with the other Design 19 Engineering organizations to put together one document l 20 We'll all use it. IL wil1 all be done the same way.

21 And it will be a standard that we're used 1

(

i 22 to seeing at either Virginia, Carolina or Peco or 23 anyplace else that we've been on how an NCR proccon i

j 24 should work, how an operability determination is done, i

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S2 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 .1 what the 50.59 screening process is and what a good 2 safety evaluation looks like.

3 MR. DURR: Mr. McElwai n, you -- to digrese 4 for just a moment, you Indicated that the design control 5 process was deficient and the 50.59 processes were i 6 deficient. Are those fixed today?

l I 7 MR. McELWAIN: Are they perf ect? No. But )

O are they -- we believe we have presently, for example, a l 9 50.59 process. The procedure has not been complete]y 1

10 changed to reflect what are normal standards f or a 50.59, l f

l 11 1.e. the screening er iter ia. But we have produced in the 12 r ocent past some recent saf ety evaluations that cover the 13 basics, the fundamentals. But it's hard to get there 14 because the people don't - as has been documented I l

15 carlier in different documents, the thorough  !

16 understanding on what that process is supposed to do and l

17 what the end result is going to be is what we're really  !

l 18 working on There are some recent safety evaluations  ;

l l 19 that are good.

20 MR. DURR: Go you're doing safety 21 evaluations. But, yet, the procedure is deficient yet or 22 the people are not trained? Or which is it?

23 MR. BOWLING: In the present procesc -

l 24 well, the people are in the process of being trained on POST REPORTING GERVICE HAMDEN, CT (800) 262-4102 l

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83 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 C" 1 the depth of what the process means. The safety 5

2 evaluation process and procedure at Millstone is usabic.

~

3 It can produce a good product. What it doesn't have is 4 a screening criteria and it is complicated and complex to 5 go through, as opposed to what we're used to seeing. But 6 you can get a good product out of it. But it is way too 7 hard to do it. It is too complex and it requires an 8 awful lot of effort that isn't necessary to do.

9 But, to answer your question in another 10 vein, when you're looking at the FSAR and the SAR and the 11 commitments that we've made when you're doing a safety 12 evaluation. as you know, the FSAR is an issue. That's A 13 why we're having 50.54(f ) issues and there's going to be V

14 new things that como out of that. So to say that ue 15 would do a safety evaluation, based it on the present 16 design that we have, the documentation we have f or it and 17 as f ar as you can look until the 54 effort is done, yes, 10 you'ro doing them, but you always can como back and say, 19 "Well, we changed the design basis on X system because of 20 Y calculation and, thereforo, the safety evaluation you 21 did didn't reflect that."

22 Until all those issues are cleared up, 23 we're not going to have a perfect environment to do 24 safety evaluations and have them done cleanly, crisply, POST REPORTING SERVICE HAMDEN, C1 (800) 262-4102

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84 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 C 1 without all the extra offort it takes to dig into that.

2 MR. DURR: What my concern is is that '

3 you're processing things in an imperf ect system. And I'm 4 -- and we're striving for como degree of perfection, 5 especially in design control conf iguration management and I

6 the 50.59 process which changes tects and experiments.

7 So, f rom our rierspective. I j ust want some accurance that 8 the things that are currently going through thic 9 imperfect procccc are going to be adequate from our 10 standards when they como out the other side. And I'm 11 just trying to understand how you're doing that.

I 12 MR. BOWLING: Jacque, let me try to 13 address that.

i l

14 MR. DURR: Okay.

l 15 MR. BOWLING: The 50.59 or any identified t

J l 16 potential safety issues. As I indicated earlier, each of i 17 us has elevated in our organization the importance of 18 nuclear saf ety and regulatory compliance. That gets more j 19 management involved. In addition, the recovery teams 20 themselves are putting people with that as mentors and 21 coaches.

22 We have started to and made progrecs in 23 putting i nto this firct line station management managers 24 in the Director level who make up the management review POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

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85 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 1 teams and the plant Operating Review Committee, what the 2 right standard and expectation for 50.59 is, what the 3 right way to review a potential icsue f or operability and 4 for potential cafety concequences and repottability.

5 So we're at a higher standard with our 6 management team now with reviewing all of thece typec of 7 i n c ue s ., In addition, we're completing safety analyse 0 8 that are approved at the unit level. 100 percent of them ,

9 are bei ng reviewed i ndependently by the sub-commi ttee of 10 the Nuclear Saf ety Assessment Board. And I, myself, have 11 inquired into this, this effort, as they reported their 12 monthly meetings on this icsue and I have confidence that 13 that kind of review is technically effective.

14 MR. DURR: Thank you.

15 MR. McELWAIN: The next clide pleaseT l

16 One of the key things that we all believe I 17 in as a team is holding people and ourselves accountable l

18 for what happens at Millstone. And what Marty talked -

19 about earlier, as well ac Bruce, when the procecs and the 20 standards are finalized and the training is complete -

21 again, that's part of the picture that we'll show in the 22 next s1ide. That's when people can be held accountable.

23 That's when standards can continue to be raised. That's 24 when we can be ~ in a mode of coaching for continuous 1

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l 86 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER S. 1996 0 1 improvement rather than taking the larger stepc that are 2 required based on where the organization is today and 3 where it was in the past.

4 Some of the actions that have been taken, 5 the design change manual has been revised to address the 6 FSAR updatec Distant review for procedure program 7 impact and the operability determination process hac also j 8 been implemented and enhanced. Enhanced again using 9 requirements for a 50.59 screen as a minimnm doing 10 operability determinations.

11 Another key to where we go is how we l

l 12 measure ef f ectivenesc. Obvioucly, in the industry there l

l A 13 are many key performance indicators. Most utili ties do V

14 focus around these particular issues. The training and l

15 qualifications. repeat ictues, trending the incues, 16 backlog prioritization and reduction in all areas.

17 That's not just a work order reduction. Regardless of 18 which work group it is, we have to prioritize those 19 backlogs and work on reducing them to manageable levels.

20 Look at the number of non -conf ormances.

21 Measure colf-identified issuos by having someone else 22 outside the line management identify them for us. And 23 look at the design review reiection rate.

24 And aqain to follow along with what both POST REPORTING SERVICE l lIAMDEN. CT (800) 262-4102 1

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I 87 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 I

O 1 Bruce and Marty have alroady talked about, we must and i

2 will do periodic self-assecsments where we will do an 3 inward look and be very critical. We all come from an l

4 onvironment where that's the normal practico. That's

what's expected and that's the way we expect to l

j 6 continuously improve all the prococccc and the changeo l

t 7 that we'll put in place over time.

1 8 Rely on the oversight activities to again i

9 look at our self-ascessment, to look outcide that area,,

10 too, to see if there's something wo missed in a self-11 accessment. Take everything that'c given to us as an 1.2 opportunity to it 9 and to f urther enhance the way we're 13 poing to do businecc.

14 The prococo proceduros will be revised to 15 reflect configuration management program that, once we're 16 through all the issucc that we do have on configuration 17 management, specifically the biggest being the 50.54(f )

18 issues, which wo*ll again talk about on the 17th when wo 19 discuct our plans f or the f uture.

20 M R ., TRAVERS: Mr. McElwain?

21 MR. McELWAIN: Yes, sir.

22 MR. TRAVERS: One of your previou3 slides 23 indicates under things you must do are enhancements to l

24 some of the basic engineering skills and knowledge I POST REPORTING SERVICE HAMDEN. CT (800) 262-4t02

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1 88 j_ RE: CONNECTICUf YANKEE ATOMIC POWER COMPANY j DECEMBER 5, 1996 lG i

i 1 don't know If I heard you touch on that much. But

} 2 certainly that is an essential component of getting your

!' 3 arms around thoce design and licensing bacos iscucc.

4 In fact, we had a similar discuccion j 5 yesterday on the Haddam Neck project. I wonder if you

! 6 could touch on some of the weaknecces that you've i 7' identified in that area and what you're doing to bolster I

I l 8 that support?

l' 9 MR. McELWAIN: Well, one of the weaknocces l

(

4 10 or areas for improvement, I'll call it, that relatec 11 di r octly to that is the 50.59 process, the training on

! 12 that, the bacic f undamental understanding of the intent 3

13 of the 50.59 screen, ac well as a well-documented, well-j 14 thought-out, thorough cafety evaluation.

I 15 But also it's as simple as understanding 16 What the F SAR is f or, that it is a living document, that i

j 17 it lo part of the design of the plant and it's to be l

1 16 maintained, to be referenced, to be updated. Those 19 things are fundamental in an engineer ing e nv i r o nme n t .,

l a

j 20 And if those fundamentals aren't clearly understood.

21 obviously -- maybe i t's not obv ious., We do have to train l 1

l 22 people on tha t. And we are in the process of doing that i 23 And the system Engineering recponcibilities and roles, 24 Design Engineering responcibilities and rojec, here in POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i

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89 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 G 1 the past they have been muddled. There are several 2 issues out there about the work load of the System i

-3 Engineers or System Managers, being such that they 4 couldn't f undamentally devote enough time to under stand l

5 the health and safety or the health and well-being of 6 their system and how it would impact the plant 7 operations. So, clearly defining those responsibilities.

8 giving people the training that they need to become a 9 f undamental, good System Manager , for example, or a good 10 Design Engineer. That's what those things are about.

11 And they are also documented in the root causes, as well 12 as the agency documentation also. Does that addroso your 13 question?

14 MR. TRAVERS: Okay.

1 15 MR. McELWAIN: Okay. In the absence of I l

16 any other questions. John Paul Cowan? l I

17 MR. HOLODY: I do have a question. And l 18 it's not with design. I guess backing up to expectations 19 and standards. I'd like to hear f rom the Uni t Directorn 20 themselves on the standards and the expectations that 21 have been communicated down by the Recovery Of f icers and 22 the kinds of standards and expectations that you feel 23 have been communicated to the staff, to you and your 24 staf f , that you f eel are being understood and those kinds POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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8 i 90 )

i RE: CONNECTICUT. YANKEE ATOMIC POWER COMPANY  !

j DECEMBER 5, 1996 i

1 of standards and exoectations where you think there*n  ;

e '

) 2 still a ways to go. 1 o

I

.i 3 MR. RICHARDSON: I can - I'm the Unit

4 Director for Millstons Unit 2. In working with the i l 1 5 Recovery Office, Marty Bowling and the team that he's I

d 6 brought in f rom Virginia Power, we have a number of areas d

7 that they have pointed out to us through coaching and 8 mentoring that as the Unit Director and the management i

i 9 team need to look at getting a more questioning attitude,

{

10 actually asking each other, applying peer pressure at the 11 managemerit team level, to get more involved, to be more 12 accountable and to have a higher ownership for issues 4

j 13 And we have been continuously coached on that as examples j

14 of what we should be doing as a management team. That's 5

15 an example on Unit 2.

)

4 16 MR. BROTHERS: Yes. Mike Grothers, 1

'l 17 Millstone Unit 3, Unit Director. I guess my answer to j l

l 4

18 your question, sir, is the management team is starting to i i

19 understand the standards that are now being imposed or '

L

20 correctly imposed on the units. I believe that for 21 various dif f erent degreet, people have gottch the message I

22 and are beginning to get it.

23 1 can say, however, that at the troop

} 24 level, it's not there yet. And it's something that we i

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91 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY OECEMBER 5, 1996 O

i"' i recognize. John Paul Cowan and myself and the CP&L team 2 are wor' king to do that. But we have numerous examples of 3 where the standards for tech spec comp)iance have not 4 been mot. Timelinesc of actions and respect for material S condition are not where we need them to be. We're trying 6 to move them and we think we can move them and that's 7 where we're heading.

i 8 MR. HINNENKAMP: Paul Hinnenkamp f or Unit l i

9 1. 1 guess an example for me would be the expectation l 10 f rom Jcck and Druce and the others around leadership and 11 mentoring and coaching. So, for example, I personally 12 have gone out into the field with first, second and 13 third-level supervisors in Operations, in Maintenance, in 14 HP, and j ust opened dialogue with them around standards 15 in the plant, around the standards of their work teamc 16 I will go out and monitor work activities in progress.

17 And I will provide them feedback on that and get an open 1G dialogue going. So, for me, that would be an examplo of l

19 some of the standards that Jack and the recovery team and I l

20 Druce have pushed down onto myself and my staff. l 21 MR. BOWLING: Let me give one other 22 example, although you didn't exactly ask me. But in l 23 terms of benchmarking and setting expectations and j l

24 standards, we currently have ongoing in Unit 2 --- a nd I l

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I 92 f RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY

DECEMBER 5, 1996

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! 1 know the other units plan to do comething similar -- i n l 2 observation tr aining. So we have people up f rom Virginia J

i

! 3 Power that are working with first-line supervisor and 4 above and the Nucicar Oversight group that's assigned to 5 Unit 2 on what to look f or, what the utandard is, so that 1

{ 6 you know when you're not seeing the standard. And so 7 that type of activity 10 taking place.

3 8 MR. CERNE: Before you go forward, a 9 further question on design control. I know Mr.

?

10 McElwain's precentation was mostly f orward-looking. But

11 coveral of the violations relate to past deficiencies

! 12 which weren't current in time but let to current i

13 problemc. Like current opernoility issuec related to 14 past Inappropriate decign control deciclons or procosces.

15 I know that's part of your 50.54 offort.,

16 But could you explain, anybody, Mr. McElwain, Mr. CONan, 17 anybody, explai n the degree of recearch that 's being done 1FJ to uncover such problema such that there aren't any

.19 current operability incues relating to pact problems?

20 Particularly, this would be important as you go forward 21 with your independent review offorts and, you know.

22 further discovery.

23 MR. NECCI: Yec. I'm Ray Necci, the 24 Director of Engineering for Millstone 2. I think to i

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1 93 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 1 address Tony's quection, the overall plan hits all the 2 areas that include documchtation. physical plant, walk-3 downs and the research going backwards. And I believo a that the 50.54 effort and the overall configuration 5 management startup plan as it's covered in most of the 6 units restart plans will hit the historical iccues. And 7 1 think we're seeing that already. We have evidence that 8 we are uncovering historical issuco in addition to what's 9 been put into the enforcement itemc right here.

10 MR. McELWAIN: If I could add something to 11 that? If you look at the prompt reports that we've been 12 making, a lot of them are based on looking at the impact 13 of things we've done in the past on present syctems.

14 whether it be the diesels or whether it be the gas l 15 turbine. So it's not necessarily just a programmatic 16 look. Every iccue that comes up, we seem to drive back j 17 to looking at how we got there. A lot of it does turn 1

1.8 out to be previous decign iscues, the impact on present~ l 19 day operability. That's one of the r easono there's a lot 20 of prompt reports about being outcide the design basis, 21 as well as having operable conditions at the unit.

22 MR. MILL.ER : Bef ore you begin, Mr. Cowan, 23 let me interject a very mundane point of procedure here 24 Just judging by the thicknees of the paget turned over POST REPORTING SERVICE HAMDEN. CT (800) 262-4102

s 94 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1990 (d 1 and the pages that have yet to turn over, it looks like 2 you're a little more than halfw . But do you have a 3 sense f or how much longer? Decause, you know, we ca n ---

4 what I'm trying to get a sense for is how to proceed.

5 I'm going to propose not to take a break right now. Dut 6 recognizing that we've been at this f or a couple of hours 7 now, I do want to invite anybody who ocods to use the 8 facilities, for example, to just do that ac we proceed.,

9 Dut I would propose not to take a break right now and 10 just keep going through. And as I guesc when we get l l

l 11 clocer to 12:00, we can decide how close you are. I mean 12 it's hard, I know, to project, with all the questions 13 that we're asking. But am I right you're a little more 14 than halfway thr ough, I guecc7 Is that -

l 15 MR. KENYON: I would say we're comewhat I i

16 more than halfway. 1 17 MR. MILLER: Yes. All right.

18 MR. KENYON: There's a poccibility we can j 19 wrap up by noon or shortly thereafter.

20 MR. MILLER: All right., Well, we'll make  ;

21 that j udgment later on. But the mai n thing here is j us t 22 if folkc need to uce the facilities, they can do that.

23 Why don't you proceed, Mr. Cowan?

24 MR. COWAN: Thank you. The purpose of my POST REPORTINO SERVICE HAMDEN, CT (800) 262--4102 1

95 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 1 presentation is to take what both Marty and Jack and 2 Bruce have said and put into context where that fits in 3 our recovery plans. So this is a f orward-looking review.

4 We recognize on the 17th of this month we 5 will have a public meeting. So it is not my intent to go 6 into much detail as to how the recovery plans physically 7 work. However, I do want to touch on a number of I 8 details.

9 In addition, as you, Mr. Miller, as you i

10 indicated that we are still in discovery, if you will, l 11 and as Bruce Konyon indicated that we will continue to )

i 1

12 find issues and as we find issues, we will adapt our 13 recovery plan. However, our recovery plan provides the 14 f ramework f or us moving forward.

15 Our recovery plan has really three phases 16 to it. We've overly focused perhaps on restart. The 17 phase probably most important is the longer-term 18 performance, which, as Mr. Kenyon said, we need to keep 19 in our vision, in our fiold, the vision of nuclear 2

~0 excellence and what that takes us.

21 But we do have three phases. We have tho l 22 readiness f or restart phase and then we have a startup of 23 power accension phase and then, finally, the long-term 24 improvement.

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i 96 1 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY OCCEMBER 5. 1996 l r- -  !

1 Out perhaps the most important word on the  ;

t i 2 slide Ic that word of "recults". Mr. Lieberman asked, 3 "What makes this plan different2" Let me give you five 1

4 reaconc that we believe thic plan ic difforent. l l

l 5 Fi rst, the plan f ocuses on results and not l 1 l i

6 ac t iv i t i cs ., Let me give you an example., Our performance  !

l l

7 indicators that we'll have on many of the older planc - '

O and I have looked a t the pr eviouc plans - were added on., 1 l

9 In fact. one of your frustrations expressed in many of l l

1 10 the public meetings I looked back on, "Where are the 1 l

11 indicators 2" You don't build indicators in at the end. j 12 You put them in in the front. l 1

13 An example of the indicators that were out

)

14 there, for example, those that were there were not 15 aggressive enough. A speci f ic example is bypass j umpers.,

)

16 For Unit 3,. prior to October 1. . we had an ob)cctive and l

~

17 a goal that bypass jumpers would be fewer than 11 that 18 were greater than two cycles old. Our new indicator will l

l 19 be we will establish a number for startup, we will 20 ectablich a number for the power operations, but our j 21 longer-term objective is there will be no bypass j umpers 22 out there greater than one cycle. Because bypass j umperc l 23 are a temporary modification. And the objective ought to 24 be to remove that modification, often which time takes o i

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97 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 refueling outage to complete. ,

2 Go the indicators that were there were not l 1

3 aggrective enough. So, not only focusing on resultc 1

4 versus activities, the second r eason that we believe this

! 5 plan is difforent is the plan is structured after the 6 success that we've experienced ac three cucceccful I 7 utilities involved with problem planto and moct recently l

l 8 used the same procecc in the recovery of the Grunswick I 9 nuclear plant.

10 The third rcacon we belicvo this plan is 1

11 dif f orent is the key is the people and the environment in 12 which they operate. And I think vou've heard both Gruce 13 Kenyon and Marty and Jack talk about the f act that we are 14 committed to changing the environment.

15 The f ourth reason - and I touched on it 16 at the beginning -- is that we're focused on long-term l

.17 performance not short-term objectives.,

l 18 And the fifth reacon is there's new i

.19 leadership in the organization and it otarts at the top 20 of the nuclear group.. Now -- with Mr. Kenyon.

21 Now, I'm sure you're aware there are plane 22 at some point that the three nuclear utilities that are 23 here today, Virginia Power. Poco Energy and Carolina 24 Power & Light, will depart. But the actions being taken l

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98 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY OECEMDER 5. 1996 C 1 and what we're doing are more than just coming from 1

)

2 ourselvec. We are changing. And you heard f rom the Unit

, ]

l l 3 Directors what we're changing. And the Unit Directorn j l

4 are key And as we act down to changing the people, '

5 those changes will be fundamental. And I have no doubt 6 that the same process and the same reacon that led Mr., I i

7- Kenyon to bring in three organizationc that have 8 demonstrated leaderchip qualitiec will be the same thingt 9 that Mr. Konyon looks at as the future leaders in the l l 10 organization and the came things that we are actively I l

l 11 involved in Gelecting the people who run this I

! i 12 organization,

( )

13 so thoce are the five reasons that we  ;

! 14 believe the plan will, i ndeed ,, be different in the I

i 15 future., Now, lot me go through thoce thr ec phases and i 16 talk about what they do. I

! 17 Thece olomonts, cyctem readinecs, i

l 18 organizational readineco, operational r ea d _ ne s s. .,

l l 19 r ogulatory readinocc and our communications plan provide l

l 20 the framework through which we'll move through the ,

i 21 futuro.  ;

i l

, j l 22 Now, what they'll do and what I'm going to l l

23 do in the timo remaining io go through these elements.,

24 tha system, organizational, operational, regulatory and  ;

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r 99 t RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY l DECEMBER 5, 1996 r

U .1 communicationo, and take and put into context the what  ;

2 that Marty and Jack said and put it to where it fitc in 3 our recovery plan. Because ac we move forward, we'll  !

4 revisit the recovery planc and we will see the same 5 format in each meeting. And I want to make cure that i

6 there is a connection, a nexuc between where we are and' j 7 what we're talking about in this violations and where i

8 we're going. Go today I'm going to focuc simply and 9 directly on the violations and where we're going to take 10 the corrective action in the recovery planc.

11 System readinocc. In our view, 12 system readinecs is where the meat of phycically making I  ;

13 the plant ready lies. It's where we cet the standards of 14 the physical readiness. It involvec, ac Jack talked l

l 15 about, the configuration control iscuec. And you'll cee 16 thece items tha t are up there. That's where we'll be l

17 talking about our engineering action plans to addresc l 18 50. 54 (. f ) . T hat 's where we've already talked about in 19 Unit 3 and public meeti ngt system-cpecific accessments or l-l 20 more commonly referred to ac 3GA's. That'c where we'll 1

21 be talking thic.

22 We'll rectore the plant material condition 23 and set standardc. It*t important to us and our 24 employees that we cet phycical standards in the plant l

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 C 1 that are high. They are the vicible signs of what we 1

2 expect to do. Some of the other items we talk about, l I

3 things like accountability, those are dif ficult conceptc 4 to relate to on a daily bacis.

l l 5 But the' physical condition, material l

6 condition, as Marty said, the houcekeeping of the plant i

7 is a visible reminder of what we expect from our 8 employees. So we are f ocucing and will continue t'a f ocuc 9 on that area.

10 The second area is organizational i

l 11 readinoss. And organizational readiness is where we l l

12 really touch on most of the issues that come across the l

13 unitt. And we recognize there'are a number of questions 14 of in thic unitization and that offort, how do we keep 15 the units in synch? Well, part of the answer is through  ;

i 16 our readinecs plans. j l'7 In organizational readineos there are 18 basically two itemc. One, the one that Jack tal ked about 19 or the technical . And l

  • ll go through that some, but you
20 can read the slideo. And the second are the managerial 21 items, the softer issuet, if you will. that Marty talked 22 about. And I'm j ust goi ng to Show - go through where 23 these lie.

24 First we have the programmatic POST REPORTING GERVICE HAMOEN, CT (800) 262-4102 I

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i 101 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY  !

DECEMBER 5, 1996 1 improvemente The programmatic improvements wc*vo tal ked 2 through. the changes to the facilities, the design '

3 changec, the 50.59's and the other itemc I think if you ,

4 reviewed thoco against the violations in the slideo that f

.5 Jacque D u r'r put up earlier and then you talked to 6 relativo to the items, you would find that these are 7 incorporated in these O We also have the follow technical l 9 specifications. The question of why don't we follow 10 technical specifications was alluded to earlier. And I 11 think it wac anowered aptly We Opend too much time ,

12 focused on why something does not apply instead of  ;

13 getting on and moving forward with juct fixing the 14 problem.

15 But It's under this item that we have --

16 where it talks about complete and accurate inf ormation, 17 ovent reporting and that. That's where we build our 18 credibility back, not just with the regulator but with 1.9 our employees. It's where we have the visible signc.

20 other than material condition, of what accountability 21 meanc 22 When people cay what they're going to do, 23 we need to hold them accountable as a management tcani 24 that they do what they say they're going to do when they POST REPORTING SERVICL HAMDEN, CT (800) 262-4102

102 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY s DECEMBER 5, 1996 i rR 1 cay it* c going to be done. Through that, we'll build the 2 tr uct back with the regulator and with our employees. '

I 3 Another key aspect to organizational )

4 readinesc is the management area. And that's where thece I 5 items such as accountability and truct, celf-accessment 6 apply.

, ~7 I want to f ocus or mantion three of these l

8 that we believe are key to getting back the trust of our l

9 employees. And a key question is how do we go about l

l 10 reducing employee concerns? I think there*c three key 11 elements on the clide. First is accountability. Second l

12 de celf-acsessment. And the third and most important 13 one, which we've talked about extensively, is the l

14 corrective action program.

15 If we can have an effcctive corrective 16 program which includes accountability and we then can l

1 17 follow up with ourselves and make sure we hold ourselves l I

18 to the higher standard under the model that both Jack and l i

l 19 Marty talked to, we will noi; the second item on t he r e .,

20 And that*c developing the truct of our emplovecc.

I 21 If we develop the trust with our employees l

l 22 and we have an atmosphere where employees will raise 23 issuec -- and ac Bruce Kenyon caid, one of the rcaconc 24 that both the management gets f ructr ated without being POGT REPORTING SERVICE HAMDEN. CT (800) 262-4102 l

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1 103 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 19?6 j

C 1 able to - without the ability to solve problems .so do l

4 2 cmployees get frustrated with raising issues that don't 3 get addressed.

i i 4 So wo believe those three will bring us to 5 the trust level and that's where we'll get our 6 fundamental changes. And Marty talked extensively about i

7 some of the things that we're doing.

8 Another item under erganizational 9 readiness, that's where we'll be talking about the t .

M

10 nuclear oversight, the management. It's really where il we'll be talking the integration of the oversight  !

12 or goniza tion into our processes in the units., That's 13 where the employee concerns and the audit programs and I 4

14 the quality assurance programs will be discussed as we 15 move forward.

l 16 So the real heart of what we have to do is 17 in the system readiness. That's the physical work. And 18 the organizational readinoss. That's the people work.

l 19 Dut where, as we say, the rubber hits the road or where i 20 we culminate is in the or>e ra t i o na l readiness. Are our 21 operators and our people ready to operate the plant? Go l l

22 we will f ocus extensively talking about what we do on the 23 17th on how to got there. l 24 A f ourth area is regulatory readiness. As l

.l 2

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104 i RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY

DECEMBER 5, 1996

" )

i 1 Marty said, we need to demonstrate improvements. That's i.

2 the differonce., As you said, Mr. Miller, It is what we

)'

3 do. not what we say we're going to do. We need to 1 l

4 demonstrate we did what we said we were going to do. l 1 I

. 4 5 These will be come of our mencurements. .

l  !

1

6 How effectively do we complete commitmentc7 How  !
l 4 i

! 7 etfectively do we ancwer the 50.54(f) responce? How I l

8 effoctivolv are we ready for the assecsmonto that are 9 donc?

10 Our objective is not to get ready for 11 those accesoments Our objective it to get the plant 12 r' e a d y . And those assocsments are the measure of how well 13 we did, other thari our own i nter nal ineacurements. l 14 Dut we believe that we will set higher 15 standards and our performance will be up to the task of 16 your r eviews when we get to that point. And we will talk 17 about each one of these items ac we get ready under the 18 regulatory readiness part of our recovery plans.

19 The last area, and probably one of the I

20 most important, is communication strategy. Ac you l 21 indicated earlier, Mr. Lieberman - and a question war 22 "How do we communicate?" -- so I won't go through all of j 23 those things. I 1

24 Out let me talk a little bit about our  !

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105 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996

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/  !

Q 1 recovery plans and one of the objectives and one of the l

l 2 comments made in the past was it seems wc*rc always i

3 changing planc. And you can't tracn one plan to the j 4 other plan. )

i l

r 5 What we intend to do in our -- ac we move l 4

i i l

6 forward under the recovery plan ic every month or  !

i l  !

l 7 whenever we meet, you will see the same f ormat, the come t

i I

8 status, the came flags movi ng along where we are in our j l

I 9 progress, so there *c a concistency in meccages, not j uct l l 10 to the regulator but to the employees and to the public.,

! 11 As far as meeting with our people and '

12 meeting with the public, 1 guess you could look at thin t ,

1 l 13 ac we want to be like that airlino pilot. I'm sure many 14 of you fly. And how many times do you get off the

1. 5 airplane and the Captain is there? Well, we want to be 16 like the Captain standing at the line wiching you a good <

17 day and thanking you f or flying with us and being vicible 18 in both the soft, the good and the hard landings. We i 19 need to be there in the good and the bad to our employeco 20 can have confidence in uc and the public can have 21 confidenco in us. Wo don't believe it will be hard to 22 find uc l 23 Our recovery plan will have success 24 measures, f our success mencurec. First, key performance POST REPORTING SERVICE IIAMDEN, CT (800) 262-4102 1

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l l 106 j RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 U 1 1 indicators Key performance indicatorc, many of those l

l 2 will be adopted from our previous planc. However, as I )

! 3 indicated earlier, there will be changec. Some of them I

4 are going to be dropped. Quite frankly, I don't know l j u

i 5 what they Were trying to measure. Some of them measurted f

6 ac t iv.i tice . For example, how many of X'c have been l

l 1

7 validated? That's an activity We need to f ocus on what I I

j F3 10 the ob jective of the validat ion and f ind measurements j 9 for those. And we are doing that And on the 17th, we 3

}

10 will diccuss some of the indicators. .

j 11 Not only will we have indicators, we will i

1 12 have workoff rates or targets, not juct a final target, i

13 but where ic it we expect to be on a month-to-month bacic i 1

j 14 co we could be meacured. It'c important not just to be l

) 15 meacured externally, but internally co we can adj ust our l

16 performance against where we think it would be.

l

! 17 And, f i nally, we need to have commitments i l j j 13 f or each phace. "We will be at thic number f or thic item j 3

19 before we rectart." Those kinds of commitments are

) 20 commitmento we will make to our employcec.,

j I

21 A second item ic frequent progrecc j 22 reporting. And I'm not talkina about progreco reporting t

j 23 on the monthly bacic. I'm really going back to the l 24 quection of communicationc to our employeec. The j

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107 I j RE
CONNECTICUT YANKEE ATOMIC POWER COMPANY j DECEMBER 5, 1996 1

l h"~ I employees need to know where we stand. And as Druce 1

4 2 Kenyon indicated, at the present time our employees ,

j j

3 ctruggle with where are we and where are we going., And i

3 l

! 4 that's the purpoce of our plan. So we need that f requent -

i l

1

5 progrecs reporting, something that'c casily understood.

]

6 Third, we need to achieve the results.

I i 7 I've talked about that. )

4 1

! 8 And then the fourth is we have to have l 9 critical colf-acsossment. As Marty said ear 1ler, colf-1 10 accecsme rit is how we determine whether we're meeting our 2

j 11 objectives on come of the items that don't have hard j 12 targetc and also whether --- it's a meacurement of how our j i \

j 13 targets -- whether our targets are the correct targets 3 14 for what we're trying to achieve. On the 17th, we will l 1 ,

, l 4 15 go through many of these items. j 16 As acked before is how do we know our l i \

17 employees have the message, we believe it's through the

18 results we achieve And we bolic vc that the results that 19 we will achieve will be towards that vicion, as Mr 20 Kenyon mala, nuclear excellence.

2.1 I've talked about the recovery plan and I 22 the f ive elemento., And really there are three phacec, as 23 I i ndicated, the readinocc for restart. I just want to 24 briofly cover the power ascencion and the longer-term I POST REPORTING SERVICE 1 HAMDEN.- CT (800) 267-4102

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l 108 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 C

1 performance.

2 The power ascension Of course, we want 3 a conservative and deliberate startup. And probably the 4 most important item on this in terms of the regulatory 5 space and the regulatory issues that you brought up in l

6 this particular enforcement conference is the last item 7 that talks about the testing requiremento. This is where j 8 We will do the maintenance tectinq, the modification 9 testing, in a logical, well-sequenced format, 10 It is generally our intent when we do 11 power accension, startup and power ascension, that wo 12 will only do the maintenance necessary to keep the plant l 13 f ocused on its objective at that time. As f ar as loriger-14 term corrective maintenance,, we will postpone that to l 15 focus on achieving what we said we would do as far as l l

16 equipment reliability and testing. l I

17 And, f inally, our recovery plan would not )

I 18 be complete unless we look at lonqer-ter m objectives. )

J l

19 And you'll notice both at that last slide which had 1 l

1 20 assessment hold points and in this slide you continue to j I

21 see the word " assessment" As Marty and Jack both caid. l l

22 assessment is going to be key to make suro we're on the I 23 right track. And it's the key, as Mr. Kenyon said, to I 24 our continued improvement that we'r e establishing within l

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f 109 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY

, DECEMBER S. L996 1 our three units.

2 In closing, I'd like to say that - and to 3 reiter ate what Bruce Kenyon said, the plan does 4 i ncorporate the enf orcement items, but, more impor tantly.

5 the plan is what we're going to use to establish our 6 vision to keep us on track for longer-term improve.monts.

7 Continued improvement is something that Virginia Power, a Peco Enargy and Carolina Power & Light have como as a way l ,

l 9 of 1if e is something that we need to establich here. And 10 that's really the objective of our longer-term recovery i

11 plan.

I 12 I'll take any questions you have on where 13 we're going. Dut, as I said, we will discuss this in 14 more detail on the 17th.

1 15 With that. I'd like to turn it over to l

16 Dave Goebel, who will talk on nuclear oversight.

17 MR. GOEBEL: First slide please.

18 Those are the subjects I'd like to cover 19 today in the order indicated. I'll go over a quick 20 background. Most of that has been covered. I don' t want 21 to dwell on that. But I do want to dwell a little bit on 22 what Oversight is doing today and how we h- ' to correct 23 the ills of the past and brighton the ship, as you might 24 c a y .,

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, RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY  !

4 DECEMBER 5. 1990  :

i l IC 1 Next Olido please. Gackground I think is I

1 1

k i  ? clear Oversight was iner f ective. I don' t think there's 1 )

j 3 any doubt about that. There are some key problemc in

(

l 4 that that I view One was that the management was spread

]

l 5 thin and there were staff capabilitics that were low, t

6 We had situationc whero we had people in i

i 7 positions who just were not able to carry out the l 3 aosignmonto which they were given. Standardc were 1

9 inadequate. I don't think I need to dwell on that any 10 more. Bruce has covered that in some detail.,

l 11 The problems went unidentified. I want to l

L2 discucG that juct very brfefly. One of the reasons I 13 hold for that is that the organization was not involved 14 in the day-to-day activity of the plants. We did not I 15 have people down in the plants. We were not working with j 16 the line organization to try and root out the 10succ.

17 And I'm not caying that what I'm looking for in the 18 organization, that the relationship with the line 10 one 19 that we are friendo to the end. Thic is a critical i 20 accesoment process. We are there to support the lino.

1 21 We are a suppor t organization. Out it't. Critical support 22 and I expect my r>eople down in the units to provide that 23 critical support.

24 The corrective actionc which we had taken POST REPORTING GERVICE HAMDEN. CT (800) 260-4102

- l 111 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5', 1996 l

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l 1 ourselves were inef f ective or flat we didn't take them at ,

i 2 all., When we go out and do audits or assessments and i 3 find dif ficulties that we then relate to the line, there ,

4 has to be a willingness in the line to take up those j 5 issues and colve those problemc. Likewise, t heres needs 6 to be a capability within the unit to come back behind  :

the corrective action line where, if a corrective action I 7

8 line was not takon, to assess that issue again and then 9 addrote with the line whether or not their corrective f 10 actions were successful.

l 11 All in all, our relationship with the 12 line, in my view, was not one of value added. And I I

g ,

13 think that if you're looking f or something that - which 14 I certainly am - that leado to the question of why there 15 was not a questioning attitude, I think you end up in a l .

i 16 process here where oversight is not value added to the '

3 I

I 17 line organization, then ne organization does not rely t

18 on any input from line -- rather, from the oversight J 19 group. So even if the overcight group gives a valid 20 assessment on a deficient condition, the mindcet within l l

! 21 the li ne or ganization is to ignore it because they don't l 22 know what they'r o talking about. And that ic a key issue l

23 that we have got to addrecc.

)

24 And I think that I can addrecs that by 4'

t i PO3T REPORTING SERVICE  :

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j 11s RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 1 them, then the oversight organization needs to step in >

J i 2 and provide that line of defense, that next line of i 1 4

1 3 defense, i'

1 i

4 MR. KENYON: Lot me add to that One of  !

i 5 the distinguiching attributes from a management 6 perspective between what I see historically at NU and 3

7 what I cee at nuclear plants that run well ic that in 8 other planto oversight quality hac been viewed as an l i 9 important management tool to help you understand where i

10 the iscuos are and what you need to do. I f you don' t get j 11 the issues on the table, you're obviously not going to 12 solve them. I 13 I don't know whether this is totally f air 14 or not But in my judgment in looking back -- and, 1

! 15 again, I'm not trying to say I can perf ectly characterizo I s  !

i 16 past managemont attitudoc. Dut I've gotten a lot of I

17 sence that overcight and quality were viewed ao i

18 regulatory requirements, not important management tools. l

?

! 1.9 30 we ' r e t ry i r e] to make a very f undamental 1

20 shift in however that attitude wac, but clearly to the i 21 I ight attitude that these are important toolo of a well-22 run organization. And getting that understood begino 23 with management attitudes and begino with having good 24 quality people in t hc- organization and i t begins with i

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1 114 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 getting those people out in the organization so that they l

2 can soo this functioning the way it ought to be 3 f unctioni ng.

l 4 MR. DURR; Okay. Thank you.

5 MR. MILLER: I agree with you completely.

6 I agree with you completely on that assosoment. It's i

I l 7 clascic. I mean the plants that had QA organizationc 8 because NRC required QA organizations, rather than I 9 becauce it was another way to get direct intormation --

10 this is top managemont now - getting direct inf ormation l

11 on what is happeni ng at the plant. In thoto situations, j 12 QA has always been a failure. And it leado to a 1

13 cituation where staffing of QA becomes very weak. In l 14 fact, it becomeG a place to cond people often that, you 15 know, can't -- are not viewed as top performors. And 1.6 inctead of being a stepping point along a career path, it 17 ic viewed as an anathema, the last place comebody wanto  !

18 to go l l

19 And so I guest the quantion 10 rcally -

20 and I don't want to get i nto personalities. Out I mean l 21 where are you in terms of staffing that organization?

22 And I'm going to cuspect that it hasn't been staf f ed with 23 people with high -- you know, with high competence and 1

24 deep technical expertise who can really be of f ective and PO3T REPORTING ?ERVICE lO f

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115 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 ,

1 credible, as you cay, credible with the line.

2 MR. GOEBEL: We are - that's one of the

, 3 carly-on things that we started the procesc in doing, wac l

4 to inf use some line experience, some high technical line

( 5 experience into the organization. We are working the 6 agreements now to get transfers from the line on a 7 rotational basic into overcight and then back to the line 3 units. We are conding some of our own people rioW through 9 licensing school so we make come of the people who have  !

l 10 come out of the - who have experience, a depth of I l

11 experience in the oversight organization, through l l

12 licensing, make them available to the units to move into

)

13 the higher management clots in the line.

14 I think by the methods that we have 15 undertaken now to provide tnat line experience, t ha t 16 h i gh-clua l i ty line experience in our organization, we're 17 going to be able to do something which I was going to say 1.8 later but I'll say now. We need to anticipate the 19 problems, not lag them. If you look in my review of 20 historically where we've been -- and, frankly, since we 21 have not got the line infused today, we're still in this 22 problem of logging the issue. When an event occurs, we 23 run real quick and ansess the event and can tell you -

24 do a root cause analysis and can tell you why it l POST REPORTING GERVICE HAMDEN, CT (800) 252-4102

116 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 U-u 1 occurred. Out that's not the function of the 2 organization. i i 1 3 The organization's f unction is to be there I 4 carly, review the procescos which are going on so that - l l \

j 5 to assist the line in trying to find the weak cpots 6 bef ore the problem occurs. And if I have an organization 7 which does not understand the processes which the line 8 organization is going to use' and cannot anticipato some i

9 of those pitfalls, historical pitf alls that they've seen  !

l 10 in their exporionce at they como down the line, then l

11 we're not going to be able to anticipato. We're going to

\

12 continue to lag the issue and come around and mop up j 13 after it's donc as opposed to prevent the problem before 14 it occurs.

1 15 So I'm hoping --- and we've discussed this j 16 in great detail and have plans to rotate people f rom the i

17 line in. And that 10 going to start in the very, very 18 near future.

19 HR. MILLER: Thank you.

20 MR. BOWLING: Let me add comething to 21 Dave's answer. It's not j ust hic responsibility to the 22 staff, the Nuclear Oversight Organization. It'c my 23 responalbility and Jack'c. and John Paul's. Ac I said in 24 my earlier remarks, it's line management who makes POST REPORTING SERVICE I HAMDEN, CT (800) 262-4102

l 117 .

RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 1 oversight cuccessful by championing them and providing )

2 some i ts beGt people. And that's what we're planning to i

3 do. t l

l 4 MR. GOEBEL: Next slide pleaso? I 5 To increace the effectiveness of the 1

6 oversignt. we likewise have a recovery plan which we'll )

7 be briefing to you. Wc are concentrating on come

! 8 specific issuec. And I'll get into the objectivec of the )

l l 9 overcight next.

10 Next slido pleace. Within our over sight 1.1 plan -- and these will just be a broad run-through 12 becauce I don' t want to - thic shoulci not be the end of l 13 it. There will be a more in-depth diccuccion later. But 14 develop and implement an organization that provides colid 15 oversight of the NU nuclear units. I think that goco 16 unsaid. And those are things that I've already 17 addrecced.

18 We need to enhance the ability of NU 19 nuclear line ! idividualc, work groups, s upervicion and co 20 f or th so that they can identi'y tho0e problems. And that 21 is -- as I naid earlier, that is a f unction of the line 22 to go out and identify ind correct those deficiencies.

23 But oversight's role in that is to come along behind and 24 to support that offort and to -- in a way which is .

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i 118 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 '

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l I constructive, help them guide -- help guide them through l l

2 those arcac which they're not able to identify by I

3 themselves. 1 l

4 Provide oversight of the nuclear unit l t

[ 5 recovery units, of the plans that they're going to l

! 6 Implement That's a clear responsibility of mino.

7 There*c already been an addressal of the Employeer.'

! O Concern Program. This la something that I am vitally l 9 interested in. As you know, we have -- we're under the 10 NRC order to have the third-party oversight team. We are i

11 likewise going to obtain some assistance in writing the  !

i l 12 Employecc' Concerns Program which is going to be utilized l

13 on the site. That is going to be done from the conse 14 which utilizes a cooperative effort between the work ,

15 force --

we've gone to the work force and asked for  ;

)

16 volunteers and have a serioc of individuals, men and

! 17 women, who have agreed to devote their effort' to help  :

! l 18 work with a facilitator which we'll bring in to develop 19 that plan. So it's not management's plan on how to run 20 an Employecc' Concerno Pragram. It will have all the l

21 attributes of a quality oversight - quality Employeec '

22 Concerns Program which has been succeccful elsewhere.

23 But the trappings on the program will be those things 24 that the work force feels are needed in order to correct POST REPORTING SERVICE i HAMDEN. CT (800) 262-4102 i .

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119 i RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY l OECEMBER 5, 1996 l 1 the deficiencies that they see at their level in the 2 oversight -- in the Employees' Concerns Program.

3 MR. LIEBERMAN: In that regard, are you 4 going to make sure that you get input f rom a broad space 5 of the different type activities within the company?

l 6 Becauce I believe one of the issues in the past when l

t 7 Northeast has attempted to get employees to be involved l 8 in the Employees

  • Concerns Program, to be representatives 9 to the Employecc" Concerns Program, that the company 10 hasn' t gone to use employeec in areac, f or example, where 11 there's been a lot of concerns. So I think it's 12 important to make sure that INC, Engineers, you know, the l l

i 13 broad spectrum of people are involved in giving you ideas '

t

! 14 In thic area.

! l 15 MR. GOEBEL: Yes. That's a very valid 16 point. It's one of the concerns that we have. And the  !

l 17 team that we will bring in to help us with the plan will

! 18 be charged to make sure we seek out each one of those 19 individual areas. And I think that -- although I'm not i

l 20 in a position to announce the team today through some i i

21 contractual issucc, I think when the team is announced,  !

i 22 you'll f ind that it's comcone who - it's a gathering of 1

23 people who can do j ust that and do it very effectively.

I 24 Out it is a valid thing we have to do. l I

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120 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY

{ DECEMBER 5, 1996 1

0 1 MR. LIEBERMAN: Another question on your i

2 objectives. Is i t your role to measure the performance j 3 indicators that others have talked about today or is the  ;

1 i 4 line organization going to be monitoring the perf ormance 5 indicators of both?

j 6 MR. GOEBEL: Well, they will have their i

f 7 performance indicators which they will need to track 8 through. One of my responsibilitioc will be in the 9 oversight role to monitor their perf ormance, their plan, 10 which meann monitoring the performance of them to their 11 own internal commitments. But that is clearly their i

12 responcibility.

13 MR. LIEDERMAN: Can I ask a question about

, 14 your reporting relationship?

4 15 MR. GOEBEL. : Ouro.

16 MR. LIEBERMAN: I presume you report to

} 17 Mr. Kenyon?

?

l 18 MR. GOEBEL: I report to Mr. Kenyon.

19 MR. LIEBERMAN: Do you have the authority 20 to, if necescary -~ I hope it might not be. But if it 21 does become necessary, go directly to the Doard?

22 MR. GOEBEL: I do. I gave a brief to the 23 Board two weeks ago and I think I said a couple of thinac 24 he wasn't expecting. So --

)

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l 121 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY r

DECEMBER 5, 1996 I

1 MR. KENYON: No But let me add to that.

2 The Board very much not only wants to hear from line i

3 management, the Board wants to hear from the individual 4 that's in charge of oversight., And our current plan ic --

l 5 - and this is -- you know, it's not what most utilities I

6 are doing right now. But we're not in the cituation that

! 7 most utili ti es are i n,.

Es The Nuclear Committee of the Board wants l

9 to hear from Dave on a quarterly bacis. And, you know,

)1 10 my style of management is to be very open and very i )

11 candid. Go I'm not worried about whether Dave -- 1 i

12 evpect Dave to come in and cay what he thinks.,

13 MR. HOLODY: Mr. Bowling had indicated l 14 carlier in a clide that - and just recently, that line l I

l 15 management championed the overcight organization and 16 cupported oversight with como of its best people Has i

17 that -- I'd like to got a conce from you in the chort 18 period., What do your people feel about that? Do they 19 cence that the line people feel that way?

20 MR. GOEBEL: Feel that they want to help? )

l 21 MR. HOLODY: That the line ic championing 22 - the line management ic championing the oversight?

23 MR. GOEDEL: 1 don't thi nk they feel that 24 way right now. I think that It's comething that we have l POST REPORTING SERVICE HAMDEN, CT (800) 262--4102

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122 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY -

DECEMBER 5, 1996 0 1 to continuo to work on. There are - I think i t's been 2 said by most of the people who have stood up here and 3 spoken today that we are continuing to work the iccues.  !

4 You, yourselves, have talked about we're still in the 5 diccovery phace. I think we are. We have a different --

6 the senior management team workc very well together, in l 7 my opinion. That needs to get pushed down to the folko l 1 l 8 that work on the day-to-day basis and rub shoulders. We '

l i

l 9 aren't there yet. I think each one of thece three i 10 gentlemen have talked about the planc in their own areac, l

i J

l 11 as supported by the Unit Directors, on plans that they're 12 taking to try and pull that together. So I'm not any 1

13 different than the rest of the guyc. We have some 14 problems in trying to pull all that together. But I'm l 15 abcolutely confident it's going to work I

16 MR. KENYON: Let me add, though, you know, l'

17 with all of this there are communication issues. And as 18 an example, I sat down, not with Dave, just myself with 19 all the folkc who run the Employecc' Concerns Program.

20 And one of the concerns that they exprocced wac " Bruce, l

21 are you really behind having a programT Because we've l

22 heard you say it's line management's responsibility to 23 effectively deal with employee concerno." And I caid.

24 "Yec , t ha t 's wha t I 've said., But you need to underctand.

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMDER 5, 1996 l sm l

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l 1 I really don't have an expectation that, even though I 2 didn' t need a f ormal Employecc" Concern Program at South 3 Carolina Electric and Gac, I don't have any expectation l

l l 4 that any time in the realistic f uture wo* re not going to l

5 have an Employecc Concerns Program. Go we nood the j 6 program., We need the people. We need high-quality i

! 7 people " And I think they felt better, you know, after 8 that. But i t's those kinds of thinac where we're still l 9 communicating internally and endeavoring uc as a cenior i 10 team to understand what employeen understand and what 11 they don't understand and then do that., So we've got a i

12 lot more communicating to do to work -- you know to got, i

13 as . John Paul said -- you know, eventually we need to oct t 14 where everybody from top to bottom pretty much han the 15 came cence of where we're going and why. And we don't 16 have that yet.

l l'7 MR. GOEDEL: Next slido please. I 1

18 The fifth objective is to enhance the ]

l 19 offectiveness of the NSAD., That*c been talked to by a l 20 couple of the other cpeakerc. We have just about 21 finrilized those plans. We have additional outside 22 contributorc who I've contacted and who I hope will give 23 me --- come back to me on Monday of this coming week as to l

24 whether they're on board or not.

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124 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 0 1 But I think that it's not just the people 2 on the NSAB that make the NSAB successful I mean that

( 3 is certainly part of it. But it's how the NSAD conducts 4 1 its business, how it delves into the issues and how the  !

1 5 issues are received by senior management. All that 1

l t

6 contrit>utos to the ef f ectivencos of the NSAD.

I l 7 We are getting the people in place. The l 8 last meeting we had, a week or so ago, a week and a half 9 ago, was a very <1ood meeting, a solid meeting The next 10 one in January I'm looking to be better yet. We arc l l 11 going to look at revising the format of the meeting in 12 order to ensure it's more intrusive.

l 13 My predecessor was the Chair of that )

14 group. I will not chair the group I think that's 15 inappropriate. The organization is supposed to oversee 16 Oversight as one of their responsibilities. Difficult 17 for the head of Oversight to run that organization and 18 then have -- expect it to be critically -- provide l 19 critical assessment of the oversight organization. So 1 l 20 backed out of that. I'm a member, but I do not sit in 21 the Chair.

22 MR. MILLER: Who is the head? Who is the 23 Chair of that board?

t 1

24 MR. GOEBEL: Dr. Mario 01naca.

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j 125 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMDER S, 1996 '

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1 Provide oversight of the recovery 2 activities. And then the final item, begin a continuous 3 improvement process no we can transition the elemento

) 4 back to the 1inc. And I say a continuous improvement 5 process because the inductry standards continue to 6 improve and this organization has to have the ability to

, 7 understand and track that improving proceso co that when 8 we give our comments to the line, we can assist them in 9 their upward trend and conctant ef f ortc to impr ove their i 10 performance.

11 MR. DURR: One of the things that I think 12 the agency it interested in and has kind of perplexed me i

13 to some degree is it's our expectation - and I think I'm 14 saying things that have been said to Northeact before 15 But then they have a new cast of players. That the NRC 16 expects oversicht to be integral part of the rectart 17 prococc cuch that we have confidence when we get to the 18 end or you get to the end, that you have a stable 19 organization that's functional and that you can provido

< 20 u t, come accurance that thi ngs are working properly, the 21 way they're supposed to be.

22 And so I'm a li ttle concerned that at thic 23 point in time you're still trying to stabilize your 24 organization as the line organization is trying to POOT REPORI'ING 3ERVICE HANDEN, CT (800) 262-4102

126 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 m

b 1 stabilize itself. And at some point, you're going to l

l

. have to becomo effective. And we need some history, if I

3 you will. So where in your mind in time doec oversight 4 become ef f ective and start the oversight f unction of the 5 recovery process. Where in time in your mind does that

! 6 occur?

l 7 MR. 00EDEL: Well, elements of that we're 8 doing now. We already have people who are assigned to i 9 the units and are down in the units on a day-by-day l

l 10 basic. They go to all the units and are Intimately 11 involved in the deciclon-making within the units.

12 We are working with the units in doing l

23 their 50.54(f) work. We're looking not at the end

.14 product at thic stage. We're looking at a process by i

I 15 which you go about doing the way. So that under the l 16 principle that if the procesc by which you do a 17 particular step ic a valid process, take any one of the 18 elements, take procedurec, take calculationc, take any 19 par t of it, if you go off- en the procecs by which their 20 engi neerr, are going through and doi ng that, if that is a l

21 valid process and if they follow that in each and every l

f 22 case, will it lead them to the correct' cace? We're at 23 that stage. So we're involved down in the unito right 2 <1 now. And they are taking our results. They're taki ng POST REPORIING SERVICE IIAMOEN, CT (800) 262-4102 l

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i 127 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 .

1 our answers, So I think that -- are we where we want to i

2 be? No. Are we started already? Yes.

3 MR. DURR: What form of report, if you 3

4 will -- how will you capture that feedback cuch that you 5 can present that up to the management chain? Is there a 6 report that Oversight ic going to generate? How is that l

7 going to be --

l

[ O M R ., GOEGEL: Well, we put out a weekly 1

9 engine ering assurance report right now that goes to the l

10 management. It talks about the actiona and the process -

11 - the cuccessec and the f allures that have gone on during 12 the week. We have that richt now.

13 Now, what over and above th2t, I'm not i n 14 a position to say right now. I think the issue is really 15 how do we provide a measurement tool to enable the line 16 to understand - for us to give the line a vote on where 17 we think they are. I don't have that right now.

18 MR. DURR: Okay Obviously, one of the 19 very critical aspects of the oversight io the feedback i

I 20 mechanism, getting that information to line management. j 21 MR. GOEGEL: I think we've got a colid  ;

I 22 cor- for feedback organization established. What we 23 don't have at this stage is an agreed-upon periodic I J

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' RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 m

i 1 that's necoccary. The communication certainly is. A 2 written report - we'll have to sort that out. But the 3 idea of how we work with the units, the feedback to the 4 people who are doing the job at the time the job ic 5 getting done, we're working very hard on that. And I 6 feedback to thoce gentlemen.

7 MR. DURR: Okay.

8 MR. GOCDEL: In the recovery units, we 9 feel we need to hold the units to the best industry 10 standards. I talked about that briefly. But we clearly 11 recognize that succccc requi res continuous improvement.

12 And we need to have a way to both trend that, anticipate 13 that and work within that optic. And we need to build an 14 organization that ptovides intrucive value added 15 oversight and, as we caid, line experience ic mandatory.

16 And we've already been through that as to what we're 17 going to - as to how we're going to handle that.

18 Next slide pleace. We have to be actively 19 intrucively. I've reaaly been through these bullets 20 before. We need to have a tyctem where we work with the 21 line so that we are in there anticipating the problems, 22 not lagging the problems. We need to, through the more 23 i nvolved, long-rcrm audit process, pick up those icchemic 24 creeping problems that otherwise go unnoticed and then POST REPORTING SERVICE HAMOEN, CT (800) 262-4102

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RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5. 1996 l

l O 1 lead to prob] ems downstream, such as in configuration I'

2 management. Those types of things ought to got picked up 3 through a quality audit program within mi ' organization.

4 Next slide ploace. Currently, we in the 5 role of revamping the organizational structure. And

)

1 6 that's about done. What I've done f undamentally is I've i 7 otripped away the responsibilities from a whole team of a re0ponsibilitiec t ha t have been tacked on to the people 9 who do the audit job and to those who do the surveillance 1

10 and the QC, the in plant process work. So I've stiipped l 1

11 the additional jobs away from those people so they can 12 concentrate $uct on thoco elements. So the senior 13 management can got down there, work speci fically with the 14 audits, worry about whether or not the audit is proper ly )

15 structured, worry about whether it's complete enough,

)

16 wor r y about whether or not you've gotten them all, you've l 17 done all the requi rements and worry about whether or not  !

18 you've looked far enough ahead to anticipate oncoming 1

19 work to cay what areas ought to be audited 50 you can i 1

20 anticipate the problems before t. hey cccur.

)

21 And the came thino is true on the l

22 surveillance and the QC offortc. We're very much trying I 1

23 to get into the lead not lag issue.  !

24 We're recruiting staff with strong l POST REPORTING SERVICE l HAMDEN. CT (800) 262-4102 I i

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i 130

' RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DCCEMBER 5,. 1996 1 1 technical capabilitles. I've talked about that t

j 2 Rota tional f olks on the line we've talked about. Our own 1

3 administrative work, we're in -- have to rewrite the

]

i 4 topical, obviously, and come of the other internal t

5 procedures that we have co that our job is done more 1 i

. 6 effcctively.

[ 7 And we're developing a comprehensive l i 1 l

1 8 training and qualification program. And that was j 9 something you knew already that we're well into a i

10 training program where we've taken our individual membero 11 of the overcight organization and have walked them i 12 through why we are where we are, looking at particular i

13 elements, the 50.59, those typec of thingc, to ao through 14 and explain and make cure the oversight organization, the i

15 Individual members of the oversight organization )

16 understand how the cyctem is lached together and what ,

17 they should be looking for when they go look. It's very 18 important that they understand that I

19 We are li kewise developing key per f ormance )

20 indicatorc. I don't have that done yet. That it.

21 something that ic in the partial completion stage And 22 we're trying very hard to strengthen the Appendix U 23 Program to address the past defleienciec. And I don't 24 want to leave you with the impreccion that the Appendix POST REPORTING SERVICE

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131 i 4 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 ,

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2 U 1 B issues are the only ones we're looking at. But it's ,

2 cr ucial that the olements of Appendix 0 get specifically 4

3 cingled out and we devote the right amount of attention ,

l

  • i 4 to including thoce elements within our audits and '

l 5 surveillarice program.s

)

2 6 MR. LIEDERMAN: As part of your oversight, I l

4 7 are you going to make cure that the line response to your j O recommendatione and finding; are tracked and f ollowed up?

I 9 Because i n the pact there's been a lot of findings made, i l

10 but thcy were dropped. You know, they weren't followed 4

1 11 up. i 1

12 MR. GOEBEL: No. You're right. And 13 that's clearly my job to do that. Some of those issues 14 are becauco of this issue that Bruce mentioned about 15 accigning the site-wide dof iciencies to Unit 1. Unit 1*c 16 job was then to paGS them out. We're s topp i rig that.

17 That*t inappropriate.

18 We'r e going to chanac the way we wr ite the 19 audit reports Go that it's eacier for the individual 20 units to know what their deficiencier and they have a 21 much better view on how to take corrective actions. The 22 way come of the past andi t reporto have been written, it i

23 requires the i ndividual uni ta to not t through and i n one 24 sence or another divine which is their responsibility to 4

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132 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 C 1 go fix and, in some caces, they even had to go back out 2 and re-look to find out if that was really their 3 deficiency or not. A lot of that was covered --- would be 4 covered in an out-brief. But it's got to be in the 5 written word because the written word io the only thing 6 that gets to 99.5 per cent of that organization. They've 7 got to see how it's written so that they can go out and 8 take the cor r ective action. Otherwise, the people that 9 come to the out-brief get the f ull explanation ac to what 10 the issue was but it doesn't get down to the person 11 that's got to make the correction because of the 1.2 communication layers. So we're taking como changes to 13 pull that together.

14 MR. LIEDERMAN: But then tracking to make I 15 sure the corrective actions, in fact, were done'?

l 16 MR. GOEDEL : Yeu. Yes. We are tracking - '

I 17 MR LIEBERMAN: You're not using -- i 18 MR. GOEGEL: No. We ~- and, a s i;t matter 19 of fact, now I provide these gentlemen on a weekly basic l 20 a 1istino of what's overdue from past audits and 21 survel1]ances.

l 22 MR. LIEBERMAN: And then wha t 's your role 1 23 if they are overdue?

24 MR. GOEBEL: Well, my role is to go after l

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I 133 i RC: CONNECTICUT YANKEE ATOMIC POWER COMPANY ,
j. DECEMBER 5, 1996  !

5 1

1 -- go after them and find out why they're overdue and j 2 push them to take corrective actions. There are levels 3 of coverity, obviously, as you know, in deficiencies 4 And the most critically deficient onec they ought to j ump

}

5 on right away. But I don't need to tell them that. They I 6 already know that. And they are doing that.

1

} 7 What we have to correct as a team, we've I i 1 i

1 i

1 8 got to correct all the pact ills. And we're in the 9 process of doing that. And the thi ngs that I'm giving j 10 them on this 1ict ic not something t ha t ' '; not available l 11 to them, the came as it'c available to me. But what I'm

{

! 1. 2 doing to just highlighting to them that becauce of the i l 13 pact things and the way things were let to clide, that i 14 every month a new serles of things comes up that is 15 required to be completed that is not completed and is not 16 completed because there was no tracking process in the l 1 l r  ;

j 17 past. And so we're communicating on these issues to go l 4 I l

.f 18 off and correct those itemc. l r

19 MR. BOWLING: Yec. Let me add one thing, i 20 Mr. Lieberman. One of the key t h i ncr2 that line 21 management has to do to make that prococo cuccessful i r.

I 22 define who the owner of the programs and ptocescoc 10.

i 23 That, as much as anything, 10 the explanation of why 24 things have become overdue, because ther e were no ownerc.

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1 134 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 I O 1 And the other thing that gocc with that, if there are no  !

i 2 ow ne r s ,, then you can expect the program to be i 3 ineffectively empty. i i

4 MR. GOEDEL: Do I have another - I do .,

l 5

Now, John Paul Cowan addressed three phaces of recovery.

6 And the operational readinecs is only one. But in a I 7 sense, it embodies the other two.

9 Thece are the elements that I think we 9 need to do to support the uni ts to get ready f or reLtart, 10 for the operational readiness. And I won't read them to 1.1 you. Dut, basically, it amountc to supporting them in 12 their offorts as they go forward. They have a lot on

.13 their plate. My job is to come beyond them and spot-14 check, make sure that they're moving in the right 15 direction, make cure that the thingc that they say are 16 done are, in fact, done, that itemc that are listed as 17 deficiencies through the ACR program or some other method 18 that and up in our tracking system. I see that those are 10 finished Sample a certain percentage of those to 20 deter mine whether or not we'r e making cor rective actionc 2.1 and we' re fixing them and we're t.nyi ng it's done and that 22 it is, in fact, done, I have a recponsibility to both 23 Bruce and to the line managers to go back and do that j 24 acaccsment and provide them that input.

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135 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY

! DECEMBER 5. 1.996 i 1

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I l

i 1 And we've talked I think at length'about i 2 the NSAD. So I won't go any further into that. And 3 we've talked a little bit about the Employect' Concerno I 4 Program. I'm Willing to go into any of those later if i

l 5 you'd like.

6 Next slide? Bacically, as the three i

l 7 Recovery Officers have stated, they ar e the key to l 8 getting thece units started again. A very big measure of

?

l 9 the success of the oversight organization ic going to be l

, 10 the r>erformance of the line organization.

l 11 If we are successf ul in our role to 12 anticipato and not lag the problems, then I think the j 13 line organization will be more effective. If we're 14 unsuccessful in that role, then we'll continue having l 15 conf erences like thic pr oceeding f orward. And one of the 16 largest goalc that I have is to make sure that the line 17 ic. in fact, succeccful. That's our job.

10 Next. Lact slide ploace? So we're 19 begi nni ng to communicate more with the li ne organi zation.,

20 ac I've said, We are being critically cupportive of the 21 worh that they're doing. We need to self-actecs our own 22 performance because that is critical to constant 23 improvement. And we're working o ri correcting those j

?4 deficiencies withiri the organization which have existed i

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4 L 1 in the pact.

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2 I'm subject to any further quections.

] 3 That concludes my discuccion. )

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J 4 MR. MILLER: There*c a fine line -

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5

! there's a fine line on como of thic. I assume when you t

6 talk about being critically supportive. What you're j 7 tal king about ic that the support you provide is critical 9 accecoment.

9 MR, GOEGEL: Right. ,

10 MR. MILLER: How, there have boon --- I've i 11 soon at some plants a view where OA begins to have Ito 12 agenda driven a bit by line. Now, I think it ic  !

13 appropriato for lino managere to on occacion say, "Oce, 14 it would be helpful if you would come in and take a 15 critical look at this, that or another topic." But in  :

16 the end, vou have few recoutces, relatively speaking. I 1 ~7 mean you're like us, trying to oversee a vact and very 1

18 complex organization. And in the end, it's going to be 19 important that you determine your own aqenda, that that 20 agenda is one that really 10 let's face it, focused on 21 where you think the problemc are most likely to be.

22 Can vou talk a little bit, you know. about 23 What it means to be critically supportive?

24 MR. GOEDEL: Supportive in a critical PO3T REPORTING SERVICE HAMDEN, CT (800) 262-4102

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1 sence, which is what you caid in the firct place. That"o i

1 2 what I think we have to be. I do think there are timec, 1

! 3 dependent upon accetc available, that when the line says 4 -- would come to us and r equest to go look a t something, i S there noods to be a determination made whether 1 have the j 6 acsets to do it, whether it's truly value added or

7 whether i t's something they ought to be doing themselvec i i a 1 don't - I'm not in a pocition to take on line work and 9 I don't think the gentlemen would want to parc it to me I l
10 unless they felt I could truly contribute comething in 11 the area.

12 Out. like I caid, we have - we have l 13 mandatory items that we have to look at. 'Thoce are I 14 dictated to us. There are also - thoro have to be a 15 series of other things over and above that that make 16 sense to the ove r";. ight organization to go and look at.

17 We need to preplan those and tell them we're coming But 10 I intend to 90 look anyway. And we have alt cady had 19 c a r,e s where we have said we are going to go look at 20 comething and they've said, " Don't look at it. It'O 21 broke. It's not worth your while ' Well, it was worth 22 our while and it was worth tholt while for uo to go take 23 that look, to establish a base line, tell them where they 24 had some strengths and where they had r.ome weaknecces.

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138 I RE: CONNECTICUT YANKEE AiOMIC POWER COMPANY DECEMBER 5, 1996 l

l Ym 1 And we will continue to do busineco that way. We will be 1 l

l l 2 supportive in a eritical conse. j l

3 MR. MILLER: Yec. I think that*c l

l 4 impor tant. And, also, it may be that - again, on the 5 face of it it would seem always appropriate to - if the l 1 6 line is asking you to come in and look, to at times turn 7 that down because there are more important other things O to have your limited recourcec focused on. You accept 9 that at - l I

10 M R ., GOEGEL: Yec.

11 MR. MILLER: Thank you.

12 MR. GOEDEL: All right.

13 MR. LANNING: May I ask you a question?

14 MR. GOEBEL: Certainly.

15 MR. LANNING: Do you have a recovery team 16 of outcide experience cimilar to what's occurring in each 17 of the three units? I l

18 MR. GOEBEL: I have a gentleman from 19 Gouthern Nuclear who in assisting me directly and hac 20 been almoct since I've been here and helping me ferret 21 out come of the dif ficulties in the organization, come of 22 the perconnel iscues, come of the training issuec, which 23 I think are crucial to try and figure out. 1 24 One of my concerns is are the people that POST REPORTING SERVICE

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139 l RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 1 I have adequately trained and adequatoly okilled? In )

2 other words, 10 there a contributing factor to the lack 3 of line r espect or line cooperation? The fact that I'm 4 conding comeone into the plant to do a job who is less S qualified than the person who 10 doing the job. I need 6 to figure that out.

'7 I have a serice of - a small team right Et now - and if it pans out, it will grow. Out a group i

9 from another utility of engineering services. But I've l l

10 asked them to cend only utility-experienced, very recent 11 experienced people from the utility, to come help me l

12 better access the skill level of the individualc down I 13 working the actual jobs.

14 Do we have a full team cimilar to what

1. 5 they have? The an wer to that is No. Do I have people 16 who are here who can provide come accictance and bring 17 the proper standard? The answer ic Yes.

18 MR. COWAN: If I may, alco, Mr. Lanning?

19 I know on Unit 2 and in my case I havo the current Hart ic 20 Nuclear Accessment Manager, which is our quality 21 accurance, on my team. And I have a corporate 22 performance evaluation, which is a corporate On percon, 23 on my team. And I have the former Robincon plant QA 24 Manager on my team.

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Y'~~9 1 l And one of those individualo is working or i

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2 has been working with Davo's organization since we 3 arrived to help also, you know, formulate the support 4 that we need from a line organization,.

5 The person who performs the Harris nuclear 6 accecome nt ., he doesn't have a current line f unction on my 7 teau. He wac brought in to make sure that we do get the 8 overcight and then work with Dave to help him formulate 9 his.

10 MR. BOWLING: Yes. I would add, on the 11 Unit 2 recover team we have a QA Manager from Missouri, 1

12 a QA Manager from Northampton. Those are people that l 13 have held that position. And one currently in the QA 1.4 organization at Surrey. And'as John Paul ac indicated,

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l 15 we have also made that resource available to Dave Goebel 1

16 and the oversight oroup at all levels of their I i

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1 ~7 management.

13 MR. L ANNING: Well, I guesc I'm inferring i I

19 from your diccussions about how you're rec rui t i nft 20 technical expertise from within the staff of NU that you 21 are going to have more of a permanent organization than I 22 currently exicts at the other unita. But I guecs what 23 I'm hearing ic you really have a recovery organization 24 for come period of time hero to get started POST REPORTING GERVICE O "a"oc" c' cooo) 2c2-42o2

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l 141 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5 1996 C 1 MR. GOEBEL: I think we -- I think - it'c l

l 2 not exactly that. We have people who are more into the i 3 mentoring as opposed to occupying the pocition.

4 MR. LANNING: That's the same f or a couple l

l 5 of the other unitc, alco. I 6 MR. GOEBEL: I have nobody from outside 7 .acupying a pocitiori of leadership. In that way, I'm j i

G difforent. Now, am I using outcide skillc? The ancwor l 9 it Yes. But there is that clight difference. I don't 10 have anybody today in a leader shir> role from outside.

11 That may change. But today that is not the case.

12 MR. LANNING: Okay. All right. Thank O " "-

14 MR. KENYON: I want to move some brief i 15 ciocing remarks for NU. As I said at the outset, the 16 underlying pr oblems which have led us into thic situation 17 have been incues of leadership. Cuccessfully addressing 10 those lcuoco requires some very impor tant and f undamental 19 actions.

20 Firct, it requiroc a full and open and 21 candid acknowledgement of the depth and breadth and 22 extent of the problems and their caucoc. And recogni zing 23 we've been f unctioning at comewhat of a high level in 24 this meeting, lot me - you know, my belief is, my 1

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L 1 accortion is we have done that in thic forum. We have i

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2 done it less f or mally in other f orume I've donc i t with l 3 the Board. Go I don't think -- if the Board was i

1 4 litorally sitting here. I don't think they would -- and 5 a do have a reprocentative of NCAT -- that's some 6 advicors to our Nuclear Committee - here. I don't think

7 they would be hearing anything that's really curpricing i

8 I mean I think we have ac kriow ledged our problem. So 9 that*c fitst.

i 10 second ic having the full support of the 11 company to do what's necoccary to correct the problemo 12 and return those units to operation with a strong 13 commitment to saf ety and reliability. And I'm aboolutely 14 convinced that we have this support.

15 Third is a celection of a new leaderchip 16 team. Thic has been largely but not fully accompliched.

17 Thic team is necoccary to cet the high standardc. to 18 octablish the clear accountabilitiec and to develop the 19 officient procccccc which are necoccary for a highly 20 functioning organization.

21 lo state it bluntly, Northeact has done a 22 poor job In managing its nuclear recponsibilities. And 23 while arguments can be made that a large portion of the 24 Specific violationc that ore the basis for thic POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i

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143 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY I DECEMBER 5, 1996 l

1 enf orcement. conf erence have minimum saf ety significance, 2 I'm not choocing to make those argumente because I 3 believe the overall situation clearly has safety 1

4 Significance. '

! S We have reptecented here a large 6 accumulation of violations of regulations. That's 7 unacceptable. We have clearly had situations where l 8 safety margins have boon diminished. That*c

! 9 unacceptable.

10 So while argumente could be made. I'm not il going to make those arguments. You, the NRC, clearly 12 have discretion in terms of what enf orcement actionc you  ;

1 13 ultimately take. And obviously, whether you chooce to 14 use that discretion pocitive or negative is up to you. l l

l '., But I believe we have identified our 1 16 problems. I believe Northeast is now on the r ight path. j 17 I believe that important progress has been made. But I 18 also believo we've got a long way to go. We're not here l

19 today caying that all of these problemt that have led t o 20 the violationc have been fixcd.

21 It's my resolve and it's the recolve of 22 this leadership team that, you know, regardlecc of 23 whatever discretion you may or may not use, we're going 24 to do what's necescary to fundamentally change how thic l

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! l 144 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMBER 5, 1996 b" 1 organization operatec. I mean that"c j ust what we have 2 to do.

l l 3 This will mean finally solving the 4 problems which have plagued this organization f or yearc.

5 It means regaining the confidence and trust of the 6 regulator, the public and, obviously, our own employees.

7 And, thuc, it ultimately means returning thece units to 8 cafe and reliable operation.

9 Mr. Miller, that rcally concludes our 10 presentation based on the iccues.

11 MR. MILLER: Thank you, Mr. Kenyon.

12 As I cald at the beginning, wc* r e not- here l

l 13 to make decisions today. But we do want to make cartain 14 that there are no questions that we should be asking 15 today ac we go forward now and make decisions on l

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.16 enforcement, as well as we can give you come reaction. i i

17 We've reacted, obviously, as we've gono along with our 18 auestions and comments.

19 Out what I want to do now is take about a 20 10-minute break to havo us be able to caucus and make l 21 certain that we don *t leave here today with questions 22 that we can ask today. I mean there may be questions 23 that come later. And that would be all a matter of 24 public record. But let us take 10 minutes. And then 1

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145 RE: CONNECTICUT YANKEC ATOMIC POWER COMPANY DECEMOER 5, 1996 1 we'll be back in about 25 minutos until 1:00. Thank you.

2 (Off the record) 3 MR. MILLER: Okay. I appreciate your 4 patience with us. We've had a fairly thor ough airing 5 here of things. And we really don't have any additional 6 questions at the level that we're speaking. Obviously, 7 we have many, many questions ul timately about what the 8 performance will be and the real meaningful discussions 9 along that line will really occur as we do our detailed 10 inspections.

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11 I think we've talked -- I'm going to give l 12 you some general reactions. And much of it repeats what 13 we've discussed in the give-and-take., Gut, you know, the 14 NRC has watched tornarounds at a number of plants. The i 1

15 star ting point f or any turnaround is f ull conf ession and 16 recognition of problems.

I 17 Honestly, that's sorw times difficult to l l

18 gauge. I think you've - - - I mentioned in one of the l 1.? exchanges that, you know, [ have seen plants that are 20 poor performers. And if I were to talk to the top 21 management of those companies and if I didn*t know that 22 they were associated with the plant having poor 23 performance. I wouldn't be able to tell and distinquish 24 what they said Irom what the top perf vi nii ng plant PO3T REPORTING GERVICE HAMDEN, CT (800) 2c.2-4102

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1 management Was Oaying. ,

2 Go what I guccs I'm caying ic that it's 3 one thing to be able to talk at thic level and it's 4 another thing to, you know, implement it and carry it 5 out. So you - co we think you've taken the first step.

l 6 Out we will watch.

l l 7 Also, I do feel, though, and I can allow 1

i O that as you have spoken here today, you have -- mont of 9 the :peakers. if not all of the cpeakerc, have talked 10 realistically about where you think you are right now 11 with respect to, f or example, having the staf f understand 12 fully what expectations are. So we get the sence that 13 you are realistic about that.

14 I think we, in fact, get nervous when a 15 licencee in a situation like thin talks about the plans 16 and tal ks optimistically about quick change,. Where tha t 17 takes place, again we're vor y skeptical becauce, you 10 know, after a long period of having low standardc, these 19 plants are too complex, the organizations are too complex 20 to think about quick turnarounds It'c just not t ha t 21 kind of thing. And in some respectc, the hardware isOues 22 are more soluble and more cacy to make progress on than 23 are the softer issues that underlie. the leadership 24 issues, as you've termed them.

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147 RE: CONNEC T I CU T YANKEE ATOMIC POWER COMPANY DECEHOER 5, 1.996 O 1 And co what we expect, we expect that 2 you ' r e go i rig to continue to have problems. The iccue 3 isn't whether you will have prob] ems. The iscue ir. how 4 you'll react to them. And to come ex terit, are the number 5 and the nature of the problems steadily decreasing with 6 time? That's i mpo r ta ri t .

7 There are some thing: that we will be very a i mtt.i t l e n t about. The identification of pioblems, if 9 we' r e i n the plant, f or example, and wo see problems that 10 you're not picking up, I think that's something that wo 11 can fairly s iticize you for and being demanding and 12 impatient about.

13 I think we talked about equipment., I 14 gueur it's no-brainer that anything that affects the i

15 operability of equipment that is important to spent fuel 16 pool operation and to other thingc that involve i

17 radiological hazards that you have to conterid wi th even 18 in a chutdown condition, that you must deal with those lo immediately. But that's the eacy pa r- t I

20 I think we need to be demandinq also witii 21 recrect to the backloqu because while you might say that 22 i the backlog; don't contai n any orio thing that impactr on ,

23 operability, large backlo<:rs equa te to r educed margina of l

24 ca f e ty ,. And so I think while you ar e in thie- proces of PODI REI'ORTING CERVICE liAMDE N . CT (800) 262-4102 l

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1 rebuilding and reforming, at the came time we will be i

2 impatient about your making progrecs on thoce backlogo.

, 3 And that's also appropriate.

I i 4 You're in an invectigation ctill. We've l

i 5 talked about that. And in discovery. Much of it is l

l 6 going to be guided by the prococces that you'll put in l 7 place f ollowing up on these orders. Out a lot of it also 1

8 comes from the management teamc that you've br ought in, .

9 new eyes and cars looking at the situation, questioning 10 the way things are done.

1

11 It's important to point out here that we j

j 12 will make a dictinction - we need to make dictinctione i

1 13 between those things that come to light, violations that 14 are identified that reflect upon pact activitice or that 15 have roots in pact years and those things that relate to I A l 4 16 work you do now. Obvioucly, thoto two thingc are

] 17 different.

18 We will be oncouraging you to f ort et out I

j 19 and find the old problems from thic point forward d

20 1 hat *G good performance. Where it reflecto upon i

i <

j 21 activities that are currently going on, then we will be I J

) 22 critical. ]

1 23 Well, you know, we ' r e - you know, where j 24 is Millstone headed? Time will tell. There is i <

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i 149 RE: CONNECTICUT YANKEE ATOMIC POWER COMPANY DECEMDER 5, 1996 i

I 1 experience in the industry, though, of plants who have 2 hit bottom and who have been in very bad chape, not j ust 3 on, you know, single icsues and single evento, but as 4 reflected by very brcad problems and situations like what 5 we've talked about here today, that have recovered. Some 6 have recovered to an aver age level. A number have puuhed 7 par,t the average level and have become top per f ormer:: .

O I won't speculate on where you will end 9 up. t1u t I will observe that the experience i ?. out there 10 t ha t. Millctone can recover and there 10 exporfence of 11 achievi ng top-level perf ormance af ter at one point being 12 in a or oblem statuo.

1 13 0 14 intense.

Our Again, assecuments will continue to be I'm new to thir region and in some 15 recpects I'm on the side lities and the region is on the i

10 side lines and it's Dr. Travers and his staff, both the 17 f olkc who repor t to him directly f rom Mr. Lanning here in 10 the region and others in Wachington. Dut our 19 a::acSCme ntc , you know , must continue to be very intance.

20 You know, we wi11, for example, on t he f ollow-op and the 21 overoiqht of your efforto under the indepenaent

?2 corr ective action veri f ication program be conducting some 23 very deep vertical clice inspections of the detailc, of 24 the detailed aspects of docion basis, configuration 3 POST REPORTING 3ERVICE N At1DE N . CT (8001 262-4102 l

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I o 1 management, all of those things that you will be looking 2 at. And we will be doing that. Our resident inspectors 3 are here. We will continue to have the expanded staf f in.

4 the residents office to be looking at day-to-day 5 activities and on more operational aspects.

6 And curely you con appreciate that, again.

7 NRC, as 1 mentioned -- you've been in enforcement 8 conferences at leact 16 timoc in the past five, six }

l 9 years. And I'm sure that many of those conferences were i 10 like this in many re0pects. And so it is only f

11 appropriate that we remain skeptical. And we will look 12 bard.

1.3 At this point, tha t - did you want to -- 1 14 thic ends the enf orcement conf erence. I appreciate your 15 precentations. And ac I say. If there is more that we 16 need f rom you, we will be getting back to you in a f ormal 17 way to r equect that information 18 1 hic ends t.he enf orcement conterence. The 19 memberG of the NRC team will be in the area f or a period 20 of time if there are memberc of the public who want to 21 approach us with any comments or questionc.

22 Thank you very much.

23 (Whereupon, the conference wac adjourned 24 at 12:52 P.M.)

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p CERTIFICATE O

I, Paul Landman, a Notary Public in and for the State of Connecticut, and President of Pon Reporting Service, Inc., do hereby certify that, to the best q  !

of my knowledge, the foregoing record is a correct and verbatim transcription I of the audio recording made of the proceeding hereinbefore set forth.

I I further certify that neither the audio operator nor I are attorney or I counsel for, nor directly related to or employed by any of the parties to the action and/or proceeding in which this action is taken; and further, that neither

,g the audio operator nor I are a relative or employee of any attorney or counsel i employed by the parties thereto, or financially interested in any way in the  !

outcome of this action or proceeding.

l In witness whereof I have hereunto set my hand and do so attest to the i

above, this 27th day of Dec. , 19 96 l

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o Paul Landman, o President

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