ML20134D417
| ML20134D417 | |
| Person / Time | |
|---|---|
| Issue date: | 01/30/1997 |
| From: | NRC |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9702050131 | |
| Download: ML20134D417 (172) | |
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1250 I St., N.W.. Suite 300 Washington, D.C.20005
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9702050131 970130 PDR 10CFR PT9.7 PDR
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- DISCLAIMER
- This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on January 30, 1997 in the Commission #s office at One 4
White Flint North, Rockville, Marylar.d. The meeting was open to public~ attendance and observation. This transcript I
has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this j transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with the commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the commission may authorize.
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 - - -
4 BRIEFING ON MILLSTONE BY 5 NORTHEAST UTILITIES AND NRC 6 - - -
i PUBLIC MEETING 8 l 9 Nuclear Regulatory Commission i 1
10 One White Flint North l 11 Rockville, Maryland l
12 l 13 Thursday, January 30, 1997 14 l 15 The Commission met in open session, pursuant to 16 notice, at 10:00 a.m., Shirley A. Jackson, Chairman, 17 presiding.
18 19 COMMISSIONERS PRESENT:
20 SHIRLEY A. JACKSON, Chairman of the Commission 21 KENNETH C. ROGERS, Commissioner i
22 GRETA J. DICUS, Commissioner )
23 NILS J. DIAZ, Commissioner i
24 EDWARD McGAFFIGAN, JR., Commissioner 4
25 !
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1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE: ;
2 JOHN C. HOYLE, Secretary of the Commission 3 KAREN D. CYR, General Counsel 4 NORTHEAST UTILITIES:
5 3RUCE KENYON, President and CEO 6 DAVE GOEBEL, VP , Nuclear Oversight 7 JAY THAYER, Recovery Officer, Nuclear Engineering 8 and Support 9 JACK McELWAIN, Recovery Officer, Millstone Unit 1 10 MARTIN BOWLING, Recovery Officer, Millstone Unit 2 11 MIKE BROTHERS, VP and Recovery Officer, Millstone
- 12 Unit 3 13 NRC STAFF:
I 14 HUGH L. THOMPSON, JR., Acting EDO 15 FRANK MIRAGLIA, Acting' Director, NRR i 1-16 EUGENE IMBRO, Deputy Director for ICAVP, SPO, NRR 17 WAYNE LANNING, Deputy Director for Inspec'tions, 18 SPO, NRR ,
19 PHILLIP McKEE, Deputy Director for Licensing and ;
20 Oversight, SPO, NRR i 21 22 l
23 24 l
J 25 l
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1 PROCEEDINGS
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[10:00 a.m.)
3 CHAIRMAN JACKSON: Good morning, ladies and 4 gentlemen. The purpose of this meeting is for the 5
Commission to be briefed on the status of activities related 6
to the three Millstone Nuclear Power Plants. The Commission 7 will hear presentations today from both Northeast Utilities 8 and the NRC staff.
9 Millstone Unit 1 has been shut down for 10 approximately 15 months and Units 2 and 3 are approaching 11 being shut down for one year.
12 All three of the Millstone units were placed on 13 the NRC's watch list in January 1966, and in fact the NRC j 14 has stated that this action in retrospect was l' ate in 15 occurring.
16 The units were recategorized as Category III 17 plants in June of 1996.
This action necessitates Commission 18 approval for restart'of each of the units.
19 The NRC in November of last year created a new 20 organization, the Special Projects Office, to have 21 responsibility for all licensing and inspection activities 22 at Millstone to support an NRC decision on the restart of 23 those units.
24 This Commission meeting is the first of what are 25 planned to be quarterly meetings to assess the status of ANN RILEY & ASSOCIATES, LTD.
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1 activities at the sites. .The Commission is interested in 2 the recovery process the licensee is employing, the root 3
causes of the deficiencies and how these are being 4 corrected, and indicators and measurement tools the licensee 5 is using to verify progress.
6 The Commission has recently reviewed an NRC staff 7-paper entitled the Millstone Restart Process, which is being 1
8 made publicly available today.
9 The Commission looks forward to the staff's I 10 presentation in addition to the licensee's. We are 11 particularly interested in hearing from the staff on their .
12 planned oversight process for restart of the Millstone i
13 units.
14 I understand that copies of the presentation i 15 materials are available at the entrance to the meeting.
16 Unless the Commissioners have any comments, ;
17 Mr. Kenyon, please. '
18 MR. KENYON: Thank you, Chairman Jackson, 19 Commissioners. For the record, my name is Bruce Kenyon.
20 I'm President and CEO of Northeast Nuclear. I have been in 21 that position since September of 1996. Previously I was 22 President and Chief Operating Officer of South Carolina 23 Electric and Gas, which included responsibilities for the 24 V.C. Summer Plant.
25 Prior to six years at SCE&G, I was 14 years at ANN RILEY & ASSOCIATES, LTD.
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5 1 PP&L in various positions, including being Senior Vice 2 President-Nuclear, and responsible for the Susquehanna
, 3 units. I was previously with Northeast Utilities, six years 4 there, senior license on both Millstone Unit 1 and Unit 2, f 5 and I have navy experience as well.
l 6 My current challenge obviously is to fix 7 Northeast's nuclear program and recover the Millstone units. I i 8 Before discussing the status of the recovery 9
efforts and a review of certain issues that we want to 10 address today, I would like to make some introductions.
11 Seated with me is-Jack McElwain from PECO. He has 12 been Director of Outage Management, but he's with us as the
- 13 Recovery Officer on Millstone Unit 1.
14 Marty Bowling. He's Virginia Power Manager of 15 Nuclear Licensing, but he's here with us heading a team as 16 Recovery Officer of Unit 2.
17 Mike Brothers is seated at the table. Mike is 18 assuming the position of Recovery Officer of Millstone Unit 19 3. He succeeds John Paul Cowan, who is Vice President of 20 Operations and Engineering Support. He has been loaned from 21 CP&L. As I think you are aware, he's taking an officer 22 position at Crystal River, but he is here in the audience.
23 Also seated at the table is Jay Thayer. Jay is on 24 loan from Yankee Atomic, Vice President and Manager of 25 Operations, and he's filling the position with us of Vice ANN RILEY & ASSOCIATES, LTD.
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6 1 President of Engineering and Support.
2 Also seated at the table is Dave Goebel. He's a 3 recently retired rear admiral and he is Vice President of 4 Oversight.
5 We have a lot of others in the audience from 6 Northeast Utilities, but I wish to point out that Bernie Fox 7' is seated behind me; Chairman, President and CEO.
8 Also, George Davis chairs the advisory team to the 9 Nuclear Committee of NU's Board of Trustees. George is a 10 former navy vice admiral and previously CEO of Boston 11 Edison.
12 (Slide.] "
13 MR. KENYON: The agenda slide indicates what we 14 would like to do for the first of what you've already 15 indicated would be a series of quarterly presentations to 16 the Commission regarding our efforts to recover the 17 Millstone units.
18 For my portion of the agenda, and particularly 19 since this is the first of several meetings to talk about 20 where we are in our progress, I thought I would start by l
21 giving you my assessment of the root causes of the Millstone l 1
22 performance problems. I want to highlight the actions that 23 have been taken to address root causes and indicate the 24 progress we' re r.taking, and then as part of all that I want 25 to discuss certain issues that I think are relevant for this ANN RILEY & ASSOCIATES, LTD.
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7 1 particular meeting.
2 Other agenda topics will include Jay Thayer giving 3
you a status of efforts to reestablish the licensing and 4 design basis for each unit.
5 Dave Goebel, status of efforts to resolve employee 6 concerns issues.
7' Jack McElwain, status of efforts to establish an 8 effective corrective action program.
9 Clearly there are a number of other issues that we 10 coul,d talk about today, but in the interest of time those 11 are the issues that we selected that we thought would be 12 most relevant for this meeting. As we have other meetings, 13 we will want to discuss other issues as well.
14 [ Slide.)
15 MR. KENYON: Beginning with root causes, in my 16 judgment the fundamental problem was leadership. This was 17 manifested through four principal failures.
18 A failure to set and maintain high standards. By 19 that I mean instead of seeking standards of excellence, the 20 organization along the way defaulted to regulatory minimums.
21 The organization stopped benchmarking other utilities. As I 22 think we all understand, if the best you are doing is aiming 23 for regulatory minimums, then at some point you fall short.
24 The second was a failure to establish clear 25 accountabilities. The organization historically pursued a ANN RILEY & ASSOCIATES, LTD.
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8 1 highly centralized organization, more recently called the 2 Power of Five concept. You can organize a lot of different 3 ways, but this particu2ar approach had the significant 4 disadvantage of not establishing and enforcing in a good 5 sense who was accountable for what.
l l 6 As an example, if you are responsible for one of 7 the Millstone units as a unit director, in my judgment that 8 individual did really not have the full accountability that 9 that individual needed to have, did not have engineering 10 resources, did not have licensing resources, did not have a 11 lot of things to really make that person accountable. So 12 what you wound up with was a situation where 13 accountabilities did not truly come together until you got 14 to the top of the organization, and that was just too far 15 away from where the accountability needed to be.
16 There was also a failure to develop efficient 17 processes. The organization sought to solve problems by 18 developing additional controls as opposed to understanding ,
19 what the real problem was and solving the real problem.
20 They endeavored to prevent problems through controls on top I 21 of controls on top of controls. The effect of this was over 22 time to make the processes by which you do work increasingly l 23 inefficient and harder to get things done. Over time there l l
24 was a huge backlog of items not being accomplished, and this 25 gave rise to quite a number of employee concerns, as you l
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1 would understand.
2 Finally, there was a failure to identify true root l 3 causes. The fundamental problem was leadership. The 4 leadership at that time didn't recognize that the !
l 5 fundamental problem was them, and thus they endeavored to 6
pursue a lot of other things without the real problem being 7 solved.
8 So the picture that I think characterized the 9 Northeast Nuclear situation, particularly the Millstone 10 situation, was one of deteriorating performance, low 11 standards, falling further and further behind the industry, 12 a growing backlog of important work not accomplished,
- 13 unclear accountabilities as to who should fix what, a lack 14 of understanding of the true problems, increase in employee 15 concerns with some high profile cases not well handled, 16 growing supervisor and manager frustration, and thus, in 17 spite of many efforts and many programs to try and address 18 that, the organization, at least at the time I arrived, was 19 as close to a dysfunctional organization as I have ever 20 encountered.
21 Correcting a leadership problem requires new !
22 leadership.
23 (Slide.]
l 24 MR. KENYON: By new leadership, I don't mean one 25 or two individuals, but a substantial infusion. What we !
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10 1 have is a new officer team. Every person at this table is 2 new. We have two new hires, four loaned, shifting a little 3 bit with one losned individual leaving and Mike Brothers 4 picking up that responsibility. As was announced last week, 5 we have a new chief nuclear officer for Millstone, Buzz 6 Carnes. He's coming from Wolf Creek. He spent a few days 7
at the plant this week, but he really reports in halfway 8 through next week and will be able to do a lot for us.
9 CHAIRMAN JACKSON: What's your current estimate of 10 when these various recovery teams will hand off the baton, 11 as it were, to permanent management teams?
12 MR. KENYON: It's coincidental, because we have '
13 been working on the agreements, but going out this morning * '
14 is a press release indicating the following:
15 In the case of Unit 1, PECO has agreed to provide 16 a recovery team to manage the activities on Unit 1 on a 17 long-term basis, meaning through 9 artup into operation for 18 a period of time of at least two years with the opportunity 19 to renew.
20 CHAIRMAN JACKSON: Two years from now or two years 21 from startup?
22 MR. KENYON: Two years from March 1, to be 23 precise. But again, options to renew. Thus, what I'm 24 saying is that they've agreed to stay as long as we need 25 them to stay. In both these cases what we have is a letter ANN RILEY & ASSOCIATES, LTD.
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e s 11 1 of intent. We have some contractual details to work out, 2 but we have a signed letter of intent.
3 Also, on Unit 2, with Virginia Power to do exactly 4 the same thing. In other words, at least two years starting 5 from March 1 provide the recovery team, the leadership team 6 on Unit 2.
7 CHAIRMAN JACKSON: Does that involve the 8 individuals who are sitting at the table?
9 MR. KENYON: Yes, it does.
It will not 10 necessarily involve every Virginia Power or PECO individual 11 that is currently. We may shift some.
12 CHAIRMAN JACKSON: But the team leadership is not 13 anticipated to change?
14 MR. KENYON: That's right. The team leadership 15 that you see here sitting at the table is the team 16 leadership that is going to take these units through 1 17 start up and into operation. We are very pleased with that.
18 On Unit 3, we are transitioning from a CP&L led 19 team to an NU led team, and that NU led team will be led by 20 Mike Brothers. CP&L will be transitioning out. They are 21 willing to leave a few people on a longer term basis but not i
22 a full team. Thus, we will supplement an NU led 23 organization on Unit 3 with one or two or three CP&L 24 individuals.
25 In addition, as is going on with the other two ANN RILEY & ASSOCIATES, LTD.
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utilities that are supporting us, CP&L is. going to continue 2 -the practice of sending a very senior nuclear individual to i 3 the site on a monthly basis to look at what is going on and 4 be in a sense in an ongoing advisory-capacity to us as to 5 how they see things going.
6 Also, CP&L is willing to provide support in other i 7 ways, such as access to programs, such as a willingness to 8
have our people continue the practice of going and visiting 9 their plants so our folks can see how it's done somewhere j 10 else; access to programs and procedures.
11 I want to be sure that the impression is not left I l
12 that CP&L is just walking away. They're not. I'm 13 comfortable, but I concluded that the right thing to do was l 14 transition only one unit at this point and then transition 15 the other two units after startup, well into operation, 16 transition the units one at a time, not have on a Friday a 17 whole team there and then on Monday a whole team gone, but 18 gradually replace people so that both myself and obviously 19 the NRC can be assured that we are going to make a very 20 gradual and careful transition in leadership continuity. ;
21 CHAIRMAN JACKSON: What impact has this transition 22 had on Millstone and your restart plans there on Unit 3?
23 MR. KENYON: On Unit 3, contrary to what some l
24 people have speculated -- they speculated that CP&L 25 transitioning out will be a major setback. I don't see that ANN RILEY & ASSOCIATES, LTD.
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O a 13 1 at all. I think we've got a plan in place. i 2 I need to remind you what the initial commitment 3 was. It was to come in for six months. It's just John 4 Cowan that's leaving at this point. The rest of the CP&L 5 team is there and will be there through the six months and J l
6 then phased out after that. So we have a recovery plan in !
l 7 place that was put together by John and CP&L folks and Mike l 1
8 Brothers. !
9 Mike is an individual who is highly regarded by 10 employees, by the public that knows him, by the NRC folks, 11 as I understand it, who know him, certainly by myself, and I 12 think we can achieve a very smooth transition here. I don't j 13 see any significant loss of momentum, and thus I think we 14 fully intend to just keep right on doing what we need to do.
15 CHAIRMAN JACKSON: Okay.
16 MR. KENYON: In responding to your question I gave l 17 a sense as to what the recovery teams are doing. What I was 18 indicating was that what they do is a lot more than simply f 19 have a management team in place. By virtue of the fact that 20 they are here, they provide access to their home companies' ;
21 ' programs, their procedures, a working model of what 22 standards should be and how they work.
23 So there is a lot more going on than simply having 24 parachuted some folks in who are filling some leadership 25 positions. There are Northeast Utilities folks, operators, ANN RILEY & ASSOCIATES, LTD.
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14 1 shift supervisors, whatever, going back to those utilities 2 and seeing how things work there. ,
That has been a very 3 important aspect.
4 As I mentioned earlier, the company had stopped 5 benchmarking, but what is going on now is a lot of 6 interaction. Not solely with these supporting utilities, 7
but with others to get out and see how the industry really 8
'does things. That has just opened individual's eyes.
9 COMMISSIONER ROGERS: Roughly how many people from 10 each of the units have actually gone off site to look?
11 MR. KENYON: One hundred.
12 COMMISSIONER ROGERS: All told or from each site?
13 MR. McELWAIN: A relative number. About 100 from ,
14 a site.
15 COMMISSIONER ROGERS: From a site?
16 MR. McELWAIN: The whole site. ,
17 MR. KENYON: Millstone, yes. It's not a practice
, 18 that, well, we did it,, and that's the end of it. It's one 19 that we do as we need to do.
20 CHAIRMAN JACKSON: You are going to march us 4
21 through various things in terms of the higher order look, 22 but the highest order look involves the board itself.
1 23 MR. KENYON: Yes.
24 CHAIRMAN JACKSON: What confidence do we have that 4
25 the board is on board and fully supportive of what you are i
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. i 15 l 1 outlining here?
2 MR. KENYON: First of all, I would not have taken 3 this position if I did not feel I had the full confidence 4 and support of not just Bernie as CEO of Northeast 1 5 Utilities, but also the board.
6 CHAIRMAN JACKSON: Can I get Mr. Fox to speak to 7 that? I think it's important that the Commission hear from 8 you.
9 l MR. KENYON: Yes. Do you want me to give my !
l 10 answer?
I 11 CHAIRMAN JACKSON: I want both of your answers.
12 MR. KENYON: I'll answer and then I'll pass it.
13 I would not have taken the position if I didn't l 14 feel comfortable that I had the full support. I felt very 15 comfortable. I had it from Bernie Fox. I wanted and did 16 meet with a large number of the trustees prior to taking the 17 job, outlining what I thought the problems were, what I 18 thought I needed to do, and were they supportive of the game 19 plan. The response to that has been very positive.
20 As I think you are aware, the trustees formed a 21 Nuclear Committee. The Nuclear Committee meets twice a 22 month, which is quite unusual for this kind of thing. Once 23 by phone, once in person. The Nuclear Committee 24 periodically comes to the site.
25 As it happens, this was scheduled before this ANN RILEY & ASSOCIATES, LTD.
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16 1 meeting was scheduled. You're smiling, but it's true. The 2
Nuclear Committee met yesterday at Millstone, spent a full 3
day, got briefings from all the recovery officers, took the 4
time as part of their agenda to split up into teams, to go 5
into each unit, talk to managers, meet with employees, get 6
reactions, get their own direct impressions as to what is 7 going on and how well it's going on.
B In addition, the Nuclear Committee has input from 9
George Davis and the Nuclear Committee advisory team.
10 That's a strong group of consultants. They are critically 11 looking at all of Northeast's nuclear plants on a regular 12 basis and they are providing separate, independent reports 13 to the committee as to what they see are the issues and 14 whether or not George and his group feel that the 15 appropriate actions are being taken.
16 The points I am making are, first of all, they are 17 fully supportive. I've got a budget to do what needs to be 18 done that is almost embarrassing in terms of the amount of 19 money it involves, and they are very engaged in looking at 20 what in happening, questioning what is going on, and 21 receiving a lot of input. So I am extremely comfortable 22 that the trustees as well as Bernie are fully supportive of 23 doing what is necessary to get these units where they need 1 l
24 to be, ready to operate, and that they can be carried 25 forward in a safe and reliable fashion. i l
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O 6 17 1 I will pass.
2 CHAIRMAN JACKSON: Let me hear from Mr. Fox on l 3
behalf of himself and the board.
4 MR. FOX: Dr. Jackson, obviously I'm not going to 5
repeat many of things that Bruce Kenyon just mentioned, but 6 our very vigorous effort, both mine as the CEO and the 7
board's in their role as fiduciaries'and as leaders of the 8
corporation, has been to demonstrated both by ord and 9
presence full engagement and full support of Bruce, full 10 support demonstrated by the resources being made available.
11 And you're fully aware and I'm sure everyone in this room is 12 fully aware that that is a challenge, but it's a challenge 13 that we are committed to rising to.
14 In additon to that presence, by not only double 15 meetings of the board committee twice a month, but full 16 briefings of the entire board by the committee chair as well 17 as by Bruce on a monthly basis.
18 As he mentioned, it happened that our board 19 i committee had been scheduled to be at Millstone for a full l 20 day yesterday. And they were. Right now our plans call for 21 the committee of the board to spend a full day at Seabrook 22 next month. So we also recognize that although the high 23 focus is on the challenges at Millstone that we have other 24
'uclear facilities and we have to be sure that those nuclear 1 25 facilities also have the proper level of attention.
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> e 18 1 CHAIRMAN JACKSON: Thank you. !
2 MR. KENYON: In bringing in a new leadership team l 3 -- this is really what is happening to address the 1 4 fundamental problems -- what this leadership team needs to 1
- 5 do. I just want to emphasize this. Part of the issue has 6 been standards. So this team has to bring in what are the 7 right standards, set those standards, enforce those 8 standards. We have got to fix the processes that are not 9 efficient.
10 With regard to incumbent NU nuclear leadership, we 11 need to determine who are part of the solution -- in other 1
12 words, a keeper -- and who are not, and act aggressively.
13 We frankly do not have a lot of time for a whole bunch of 14 folks to have a get-well program. Either they pretty much 15 know what they need to do and can enforce the right i 16 standards and the right accountabilities and manage this 17 well, or we've got to get folks who can.
18 We clearly need to create a proper climate for 19 employee concerns, but our overall challenge is -- and this 20 is really what is most important -- we need to fundamentally 21 change how Northeast Nuclear functions.
22 I had intended to talk about the issue of 23 leadership continuity. I think we have covered that on the 24 basis of your question.
25 Another issue I wanted to address with you is the ANN RILEY & ASSOCIATES, LTD.
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i 1 issue of leadership consistency, a little bit different than 2 the question of continuity.
) 3 In bringing in three teams, they are obviously 4 coming from different utilities.
. There are some differences 5 in how those utilities do business. Those differences have
, 6 turned out not to be huge. They are very modest difference 7 in cultures. I am not insisting on an identical approach 8 for each unit, but I do want the differences to be 9
differences that I can rationalize and feel comfortable
. 1. 0 with.
- 11 It has been a challenge to do that and a lot of 4
12 the other things that I'm doing. As I already mentioned, '
13 hiring Buzz Carnes, bringing him in as Chief Nuclear !
I i
- 14 Officer, having the three recovery officers as well as Jay 15 Thayer and an officer who is responsible for some other l
] 16 support functions, really the Millstone leadership team at J
l 17 an officer level all reporting to Buzz Carnes. Dave Goebel 4
18 as the Vice President of Oversight will continue to report 2
19 to me because he has responsibilities for more than just 4
20 Millstone.
1 21 The intention here is to have a strong senior 3 22 level person that will assist in leading the recovery of 1
23 these units, ensure that we have a reasonable consistency of 24 standards across the units, and certainly pay very careful 25 attention to the management transitions.
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I made the statement earlier that our most 2 important challenge, in my judgment, is not so much the 3 execution of the particular items in the recovery plan, but i 4 really the most important challenge is fundamentally l 5 changing how NU functions. We, the leadership team, have 3
l j 6 spent a fair amount of time talking about what are the most ,
1 7 important objectives that we need to accomplish in order to l i
I t
make that fundamental change in how NU functions.
8 9 [ Slide.]
10 MR. KENYON: We have identified seven success 11 objectives as being the seven items that we believe are the I' 12 most important. We're not saying there aren't others, but 13 these are our top seven, so to speak.
14 We must be an organization with high standards and 15 clear accountabilities. I'm going to elaborate on each of 16 these. That means that we have incorporated maybe not all 17 but many of the best practices from other utilities. It 18 means that we are regularly benchmarking with other nuclear 19 utilities. It means that we have indicators that show 20 strong improvement toward excellence. I don't expect us to 21 be at excellence by the time we are ready to start up, but 22 we should be well on the way. And certainly we are meeting 23 our commitments.
24 Second, we must have a strong nuclear safety 25 philosophy, which means to me careful adherence to high ANN RILEY & ASSOCIATES, LTD.
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1 21 1
safety standards and conservative decision-making.
2 We must have an effective self-assessment process.
3 That is not just oversight. That is also line management 4
bei > able to critically look at what is going on, identify 5 and deal with problems. I think the fundamental measure 6 there that I would want and I think you would want is to the 7
extent that there are problems we find them, and you can 8 have confidence that we know how to find problems and deal 9 with them. 1
\
10 We must have an effective corrective action l 11 process, which means problems are prioritized and resolved i
12 in a timely manner, and that we have improved regulatory l 13 performance as demonstrated by decreasing violations and 14 licensee event reports.
15 CHAIRMAN JACKSON: Let me ask you'two questions.
16 One is, what is your assessment of plant personnel 17 embracing the need for change?
18 Number,one, so that we are not just talking 19 philosophically, in the course of your discussion are you 20 going to speak with any degree of specificity with respect 21 to what evidence there is of progress with respect to 22 self-assessment and effective corrective action?
23 MR. KENYON: Let me deal with the second question 24 first. One of our additional presentations is corrective 25 action. So we are going to talk about what we are doing and ANN RILEY & ASSOCIATES, LTD.
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1 c
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16 exc llenc e
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[ Slide.] e how this o n ne ds to be doo dly e captur rga iza tion fu ne to MR. KENYON: nctions.
To talk briefly about ANN the RILEY recovery 1250 I Cour&
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21 1
safety standards and conservative decision-making.
2 We must have an effective self-assessment process.
3 That is not just oversight. That is also line management 4
being able to critically look at what is going on, identify 5 and deal with problems. I think the fundamental measure 6 there that I would want and I think you would want is to the 7
extent that there are problems we find them, and you can 1
< 8 have confidence that we know how to find problems and deal 9 with them. 1 10 We must have an effective corrective action 11 process, which means problems are prioritized and resolved 12 in a timely manner, and that we have improved regulatory 13 performance as demonstrated by decreasing violations and 4
14 licensee event reports.
15 CHAIRMAN JACKSON: Let me ask you two questions.
16 One is, what is your assessment of plant personnel 17 embracing the need for change?
18 Number.one, so that we are not just talking 19 philosophically, in the course of your discussion are you 20 going to speak with any degree of specificity with respect
, 21 to what evidence there is of progress with respect to 1
22 self-assessment and effective corrective action?
23 MR. KENYON: Let me deal with the second question 24 first. One of our additional presentations is corrective 25 action. So we are going to talk about what we are doing and ANN RILEY & ASSOCIATES, LTD.
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l 22 1 the progress there. We have another presentation on 2 employee concerns and the progress we are making there. 1 We 3 flagged talking about the issue of oversight and we just 4 concluded we didn't have time in the agenda, but certainly 5 if you would like to talk more about that in deference to 6 something else, Dave Goebel can address it.
7 As to your first question on employees and the 8 extent to which they embrace change, certainly what you have 9 in any employee population is a continuum of opinion from 10 those who clearly embrace it and are enthusiastic and let's 11 get on with it. I find at the worker level the employees
. 12 want to get on with it: let's do what we need to do. If 13 things haven't been right, they accept it. When you're on 14 the watch list, when the plants are shut down, when you know 15 you can't start up, when you know you can't be in this 16 situation forever, I would say the workers are very 17 enthusiastic.
18 The layer that I'm more concerned about is what I 19 would characterize as middle management below this new 20 leadership team, above the employees who basically want to 21 get on and get things done. I think in that middle 22 management layer we have a mixture of folks, some who are 23 very good, committed to do it, some who need to be told, and 24 we are telling them what's the standard, here's how we want 25 you to do business; we are going to hold you accountable to ANN RILEY & ASSOCIATES, LTD.
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23
- 1 it.
i 2 I think we have some who are fairly entrenched in 3 3 a historic way of doing business which we have to f'x.
4 Well, we'll fix it.
- The question'is, do we fix it by j 5 teaching them how to do it or do we fix it by putting 6 somebody else in the position?
l 7
I think we are making good progress in reaching -
8 the broader population. I don't think we have at this point 9
as much of a sense of urgency as I think we need to have, j 10 and we are working on that. I don't think we have at this 11 point all our employees fully understanding the game plan, I 12 and we are working hard at communicating that. But in i
i 13 general we are not meeting any substantial degree of fi 14 resistance to the need to change. Employees know that 15 Millstone ist't in good shape and it needs to be in good 16 shape or they're not going to have jobs.
! 17 [ Slide.]
- 18 MR. KENYON
- Item five is reconstituted licensing j 19 and design bases with a process to ensure that they are 20 properly maintained.
{ We'll all know that on the basis of
- , 21 the ICAVP contractor determining that the bases have been j 22 restored. We also obviously have to demonstrate that we 23 have implemented effective configuration control processes.
s a 24 Six is an environment that supports the i
25 identification and effective resolution of employee i
)
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. . i 24 1- concerns. This will be characterized by very open and
'2 candid communication with employees, timely resolution of
- 3 employee safety concerns, and certainly, per your order, an 4 independent review of the employee concerns program and 5 whether or not it has reached a state of effectiveness.
t 6- Finally, number seven is a commitment to achieve
- 7 excellence in nuclear operations. What this means to us is j 8 that we will have to find what excellence means to us. We 9 will have a plan developed as to how we are going to achieve i
10 excellence. There will be demonstrated good progress, i
- 11 particularly on longstanding issues, and certainly issues 12 important to startup have been resolved.
- 13 CHAIRMAN JACKSON: That progress is important, 14 because every nuclear executive talF1 about commitment to 15 excellence. Excellence is as excellence does.
16 MR. KENYON: That's right. I don't disagree at 17 all.
l 18 Finally, we need to be able to show and 19 demonstrate that we have the resource commitments that meet 20 or exceed those of similar well run units.
21 I.believe these~seven objectives broadly capture !
22 the most important aspects of what needs to be done to i 23 fundamentally change how this organizatic. functions.
24 [ Slide.)
25 MR. KENYON: To talk briefly about the recovery ANN RILEY & ASSOCIATES, LTD. I Court Reporters I 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
1 25 1 plans, they consist of certain major elements. I want to 2
link as I go through this the success objectives with the 3 elements of the recovery plans. The recovery plans were i
4 developed on a unit by unit basis.
i 5 Recovery plans are laid out to achieve system 6
readiness, which means the licensing and design bases are 7 recovered. That's success objective number five, and that 8 will be the subject of a presentation.
9 The necessary design changes have been made; 4
- 10 system drawings are updated; operating, maintenance and test I 11 procedures are where they ought to be and properly reflect 12 the design basis; the material conditions of systems and l 13 equipment is proper, meaning corrective maintenance has been 14 accomplished; preventive maintenance is current. l 15 That's system readiness, but we all know there is
,' 16 a lot more co restart than simply the syetems being ready.
17 The second item, and this captures a lot of these i
, 18 other objectives, is organizational readiness. This is to 19 ensure that the broader aspects of the Millstone
- 20 organization are ready to support safe and reliable
- 21 operation. This means that we have set the appropriate 22 standards.
- 23 We are holding individuals accountable. That's
- 24 success objective number one.
25 We've established a strong nuclear safety ANN RILEY & ASSOCIATES, LTD.
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26 1 philosophy and people can see it in the decisions that are 2 made.
3 We have effective self-assessment.
4 We have an effective corrective action program. 1 5 We have the proper employee concerns environment, a 6 long-range commitment to excellence.
7 A lot of these success objectives go into J 8 establishing that the organization is ready.
9 There also needs to be operational readiness. i 10 This ensures that the systems and operating personnel are in 11 a final state of readiness. We'll talk more about this in a 12 future briefing. At a high level it means systems are 13 operable; it means the personnel have been trained; their 14 qualifications have been updated as appropriate; we've done 1
15 some special things to compensate for the fact that the 16 units have been shut down for a long time; we have the right 17 staffing.
18 Regulatory readiness means that all the 19 commitments that we made that are necessary to support 20 startup have been met. There is a good track record in this 21 regard, and it's characterized by extensive review and 22 interaction with the NRC at many levels in order to support i 23 a rebuilding of regulatory confidence.
l 24 Finally, communications readiness. Here the 25 objective is that, first of all, our employees have a good l
l l
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l 27
- 1 collective understanding of what we are doing and why, 2 particularly our standards. We have clearly communicated in 3 an open way, t
i 4 There are a lot of ways you can look at this, but 5
the fundamental measure is on the basis of face to face j 6 communication. I have the best sense of what is going on by 7 going out in the organization and talking to people and 8 looking at their attitudes, listening to their questions, 9 seeing what they are concerned about. That's how I judge 10 them. l 11 CHAIRMAN JACKSON: Let me ask you this question, 12 Mr. Kenyon. Since in many ways communications in that whole 13 area are at the heart of how you deal with employee l 14 concerns, and we are going to hear about that, you have the 15 face to face opportunity and you can have some comfort 16 relative to what your organization's state of readiness is 17 in that area. How are you going to communicate it to the 18 public and to us relative to a restart decision?
19 MR. KENYON: First of all, with regard to the 20 public, we are commencing a series of public meetings every 21 four to six weeks. The first one is in February. I'm not 22 sure I'm remembering off the top of my head the date. In fact, I think we actually have two in February.
23 A series of 24 public meetings. They are going to be topic-based.
25 The first one is going to be employee concerns, ANN RILEY & ASSOCIATES, LTD.
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28 1 but we are going to have other topics that we think would be 2 of interest to the public. We are going to invite the whole 3 world. We are going to have a leadership team; we are going 4 to have employees, depending on what the topic is.
5 For example, we have had this employee concerns 6 task force working on wist is a good employee concerns 7 program. At this meeting where we go through the employee 8
concerns issues we are going to have members of the employee 9 concerns task force participate in the communication of what 10 we are doing and how we are doing it.
11 So with regard to the public, it's a series of 12 meetings, and we'll do this for as long as it's productive.
13 We just have to communicate, communicate, communicate.
14 CHAIRMAN JACKSON: Do you have metrics to measure 15 success?
16 MR. KENYON: We have public opinion measures that 17 we take on a monthly basis. I think these measures can be 18 refined, but we do that.
19 This is more subjective. The reality is most of 20 the public believes that there is a new leadership team in i 21 place. My interaction with the public has been very 22 positive; my interaction with the media has been very 23 positive; and thus the general public is quite supportive of 24 "we want the units run well, we want the units run safely, 25 demonstrate that you can do that, bring these units back."
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- 1 There is a smaller group in the public that is 2 much more vocal, but even my interactions with them have 3 been good. We are going to make sure to the extent that '
i 4 group has issues -- I've gone on their talk show. They have I 5 their own TV talk show. I've gone on their talk show. So 6 we are going to have interactions with them.
T' Maybe I'm an idealist, but we are committed to do !
4 8 what is right. We are open and candid about what we are j 9 doing, and that is going to come across; it is coming
- 10 across; and I think we sense it a lot in terms of just the 11 nature of the interactions that are going on in addition to !
12 surveys that we take on a monthly basis.
l 13 With regard to the NRC, I think the key here is 14 that we have regular meetings, formal and informal, where we 15 just lay out what we are doing and how we are doing it, and 16 we have good dialogue as to what the issues are.
17 Certainly I'm looking for input from all quarters, 18 particularly including the NRC, and I think that if it isn't 19 clear already, it will be clear that we are very open, we 20 are very candid, and we're not trying to hide anything.
21 We're just going to lay it out there and have lots of 22 interactions. I think a quarterly meeting with the 23 Commission is excellent, and we welcome this opportunity.
24 Obviously the fundamental measure is performance, 25 and we intend to demonstrate that performance and then ANN RILEY & ASSOCIATES, LTD.
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30 1 communicate that performance.
2 To comment on schedules, first, we are committed 3 to do what's right. Standards are first; schedules are 4 secondary.
5 I have indicated that our most important challenge 6 is not so much the schedules as laid out in'the recovery 7- plan but to fundamentally change how the organization 8 functions. That is not something that can be readily 9 scheduled. Thus it's our belief, although subjective, that 10 we can accomplish these fundamental changes in the 11 organization within the time frames that are laid out in the 12 schedule. But that's an assumption.
13 I have stated that standards are first and 14 foremost. A companion statement is that I need to convey at 15 least on our part a sense of urgency. Having three units 16 down for an extended period of time is a significant 17 financial drain on the company, and we really do need to 18 restart'at least one unit this year. We just cannot keep 19 spending like this indefinitely.
20 My fourth point is that it's much easier to create 21 a schedule when the scope of the work is fully known, and we 22 don't know the full scope of the work because we are going 23 through a lot of reviews to see what needs to be done. We 24 have made allowances in our schedule for a reasonable number 25 of identified problems. We've made assumptions. We don't ANN RILEY & ASSOCIATES, LTD.
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31 1
know, for example, the sample size that is going to be 2 required by you of the ICAVP contractor. So whatever you !
{
3 have determined in that regard obviously can significantly 4 influence the schedule.
5 My fifth point goes to the issue --
6 CHAIRMAN JACKSON: Let me talk to you before you 7 go off of schedules. By what date do you foresee having a 8
workable restart issues list for each unit?
9 MR. KENYON: We have a workable restart issues 1 10 list now. It's just that as we find new things we add to 11 it. As we close things we take items off. So we have a i
12 . listing of items required for startup now.
13 I want to talk a little bit about the strategy of 14 endeavoring to restart the three units in parallel, which is l 15 a significant change from what was being done before I 16 arrived.
17 I think it's obvious to everyone that the most 18 efficient way to restart three units is to work all three in 19 parallel rather than one at a time. But I also fully 20 realize that there are potential interferences both within 21 NU and externally as to can you really do all three at once.
22 At the moment what we are trying to do is each unit working 23 what it needs to do, working those units in parallel, and at 24 some point there may be some interferences.
25 What I'm working to do and what the leadership ANN RILEY & ASSOCIATES, LTD.
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32 1 team is working to do is, as we see pinch points, we ,
2 endeavor to solve those: Can one ICAVP contractor do its i 3 review of three units almost on top of each other? We've 4 concluded no.
5 So we've submitted the contractor for Unit 3. We ,
6 will be submitting contractors for Unit 1 and 2 and we're 7- going to be adding one additional contractor so we have a 8 greater assurance that this workload can be accomplished.
9 We also know that there are challenges to NRC 10 inspection resources: Can the NRC do what it needs to do
-11 with three units coming back in parallel?
12 I want you to know this. I acknowledge that we f
l 13 may get to a point where it's necessary to select a lead 14 unit, but my desire is to not do that any sooner than we 15 have to. I'd like to work three units in parallel as long 16 as we can work them.
17 I realize that it is an impractical reality to 18 have three units arrive on your desk seeking permission to 19 restart at the same time, and that is not quite what the 20 schedules show anyway. They are not that far apart, but i
21 things are going to happen. We are going to encounter this 22 issue that we don't know about today or that issue that we 23 don't know about today.
1 24 I'd like to work these in parallel for as long as 25 we can work them. What we are asking of ourselves is, if we ANN RILEY & ASSOCIATES, LTD.
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33 1 ever get to a point that we've got to make some choices, 2 we'll make some choices. All things being equal, we'll pick I 3 the largest unit. The reality is all things are probably 4 not going to be equal, and then we would endeavor to pick 5 the unit with the greatest state of readiness, the highest 6 probability of success, and at some point it will be one 7 unit at a time going across the goal line.
8 We are sensitive to the challenges that we are 9 creating for the NRC and its inspection resources. Our 1 i
10 commitment is to work with you and try and figure out ways 11 that we could be supportive and cooperative of the 1
12 regulatory challenges that you and the staff have.
- 13 CHAIRMAN JACKSON: Do the schedules that you have 14 developed for each site include all the important 15 milestones? l 16 MR. KENYON: Yes. I i
17 [ Slide.] l 18 MR. KENYON: To wrap up, just quickly indicating 19 progress, a lot has happened in the last three or four 20 months.
21 We have established and communicated the root 22 causes of our nuclear proll. ems.
23 We have brought in a new leadershio team.
24 We have reorganized the nuclear organization to a 25 unitized concept with much clearer responsibilities.
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34 1 We have established a recovery team for each 2 Millstone unit.
3 We have developed a recovery plan for each unit I 4 and a recovery plan for oversight.
5 We have begun the process of raising standards and 6 improving processes.
7 [ Slide.]
8 MR. KENYON: The ICAVP contractor has been 9
selected for Unit 3 and we will be communicating shortly the 10 l recommendation for Units 1 and 2. 1 11 We've establisned a virtually new oversight 12 leadership team, and that includes a new director of '
13 employee concerns.
14 We have selected the employee concerns oversight I i
15 contractor.
16 We have a new employee concerns program developed 17 by the team. As I indicated, a lot of employee input on ;
18 this, and because we wanted to get the employee input and 19 because they really. wrestled with how this program needed to 20 be established, it took a little longer than we hoped, but ,
21 that submittal will be made tomorrow, and Dave Goebel will 22 talk more about the employee concerns program.
23 [ Slide.)
24 MR. KENYON: We have approved a significantly 25 improved corrective action program. Jack McElwain will talk ANN RILEY & ASSOCIATES, LTD.
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35 1 about that in more detail.
2 We have addressed the issue of leadership 3 continuity through startup. I've talked about that.
4 I haven't mentioned this up to now. We have 5 conducted a leadership assessment. In other words, 6 employees assessing their leadership on leadership i 7' characteristics, not technical skills. We just have the 8 results of that being communicated, but that's important 9 input to us on this question of who is part of the solution.
10 CHAIRMAN JACKSON: Are you going to talk to us-11 about the results?
12 MR. KENYON: No, because I have not personally 13 been briefed on the results yet. Some of these folks have.
14 If you'd like, they can. It's just that my briefing hasn't i 15 taken place yet.
16' CHAIRMAN JACKSON- I think it would be interesting 17 for us to hear to the extent you are prepared to talk about 18 it. You don't have to take a lot of time.
19 MR. KENYON: Marty.
20 MR. BOWLING: For Millstone Unit 2, as Bruce has 21 indicated, all employees who were invited, that is, 22 voluntarily, could rate their immediate supervisor and any 23 level up in the organization all the way to Bruce.
24 We have the results back on that. They have just 25 been received this week and we are just looking at them.
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36 1 The rating scale was between one and eight. On Unit 2 the 2 aggregate score for all supervisors was around a five.
1 3 CHAIRMAN JACKSON: What does one mean?
4 MR. BOWLING: One was the lowest. -
5 MR. KENYON: One means strongly disagree. In 6 other words, we asked 26 or 28 leadership questions. This 7 is a variation on what we did at South Carolina Electric and 8 Gas, a very important tool for us. There are questions on 9 leadership attributes and each employee basically has boxes 10 to check that range from strongly agree, because the 11 leadership characteristic is stated in a positive way, to l 12 strongly disagree, meaning my supervisor doesn't do that. i 13 If you get a score of one, that means you've got strongly 14 disagree on everything. The other end of the scale is 15 strongly agree on everything.
16 MR. BOWLING: So it basically came out on the i 17 average, but you can see for individuals deviations one way 18 or the other.
19 Another good feature of this, for each low rating i 20 the employee was asked to provide the major reason for that, 21 and there were three or four possibilities. The two most 22 prevailing reasons coming out for a low score is that the 23 supervisor doesn't have time or the supervisor doesn't 24 perceive this area that I'm working in as important.
25 CHAIRMAN JACKSON: What do you intend to do with ANN RILEY & ASSOCIATES, LTD.
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l 37 i
1 the results?
l
- 2 MR. KENYON
- I'm going to sit down with each of 3 the officers. We've solved the leadership problem at the 4
4 top of the organization. The next layer down for us is l
, 5 directors. We have changed out over half the directors.
i 6 The next layer down is managers and supervisors and so
! 7 forth.
t 8
A critical issue for us is we need to understand i
- 9 who is clearly part of the solution, who clearly doesn't get 10 it, in which case they go, and then to the extent that there j 11 is a question mark there and the leadership assessment is 12 input, then we have to decide how bad is the problem and do '
13 we think we can fix it in a short period of time or not. If {
14 we think it's fixable, there is a decent chance of fixing it 15 in a short period of time, we'll hang in with the l
16 individual. If we conclude it's not fixable in a short 17 period of time, then we are not going to hang in with the i 18 individual.
19 CHAIRMAN JACKSON: How are you defining short 20 period of time?
r 9
21 MR. KENYON: A couple months. We are going to do 22 a leadership assessment again in six months. Our objective 23 is a significant improvement in the leadership scores. For 24 whatever it is we got this time we want to see a significant 25 improvement next time.
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l 38 1 COMMISSIONER ROGERS: Before we leave this 2 progress topic, could you say just a little bit more about 3 your unitized concept? What activities are unit-specific 4 and what are shared by the whole site? For example, to what 5 extent is engineering unit-specific and maintenance 6 unit-specific?
7 MR. KENYON: I will give you some examples. I'm ,
B going to ask the other folks on the leadership team to throw 9 in some more. (
10 For example, on engineering, there is a 11 centralized organization that sets the engineering 12 standards, that sets the programs, but the accomplishment of '
13 the engineering is on a unit by unit basis.
14 Similarly with license. We have a centralized 15 organization that is going to set overall policy and 16 strategy, but to the extent a regulatory commitment is made, 17 it is almost always a unit-specific commitment.
18 This has been a problem in the past,.because a 19 centralized organization made a commitment that really the l 20 unit had to carry out, but the unit didn't own the 21 commitment because they didn't make it. So we've had a lot !
22 of problems with this outfit doing this and that outfit not j 23 living up to it. So regulatory commitments are going to be l 24 managed on a unit by unit basis, and thus if a commitment is i 25 not met, it's very clear who is accountable.
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i 39 1 We have a centralized training organization, but 2 the units have to be satisfied that they are getting what 3 they need. So training is support.
4 Jump in with some other examples.
5 MR. McELWAIN: A further example on the programs, 6 like the motor operated valve program, the erosion / corrosion >
7 program, those things are managed out of Jay's organization i
8 and implemented at the units. A different program is the 9 corrective action program that I'll talk about. It's a 10 site-wide program. So everything that we can now determine 11 still makes sense to be one program for everybody, like MOVs 12 and like corrective action, that's the approach we are 13 taking with that. ;
14 Each of the units where the central group will !
15 take a lead in trying to enhance the particular program, for 16 example, corrective action, was a three-unit operation to l 17- get it where it is today, but I get to talk about it because 18 I was assigned the sponsorship for that program.
19 That's how we have taken things that were very 20 cumbersome to do and were universal, if you will, and 21 sometimes we have unitized them and sometimes we've not.
22 The critical aspect is, if it applies to all units, we'll at 23 least pilot it on one unit and then make it common across 1 1
24 the three. It makes sense from a practical standpoint 25 rather than have three organizations trying to do the same l
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thing to have somebody pilot it, input from the other two 2
< units, make it common, and then manage it from there.
3 COMMISSIONER ROGERS: The engineering design basis 4 reconstitution, I'd like to hear about that. Not 5 necessarily.now but at some point.
6 MR. KENYON: That is a presentation 7
COMMISSIONER ROGERS: I'd like to hear how 8 unitized that is and how general it is.
9 CHAIRMAN JACKSON: Mr. Bowling, you were going to i 10 say something?
11 MR. BOWLING: Yes. i I think the approach is for ;
12 the unit to have those organizations in it which it needs to '
13 provide the conduct and support of operations and 14 maintenance. From the engineering perspective with the unit 15 are three_ key areas:
16 Design engineering for any modifications required
! 17 to the plant.
18 The technical support area, which is basically 19 system engineering, and also regulatory and technical 20 programs.
21 The third is the configuration management 22 restoration under 50.54 (f) .
23 MR. KENYON: At this point I would like to call on 24 Dave Goebel on employee concerns.
I i
25 MR. GOEBEL: Thank you, Bruce.
l i
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2 41 1 Just a short introduction of myself.
4 My name is 2 Dave Goebel and I'm a 34-year navy veteran, having spent 25
- 3 years of that in the Naval Nuclear Propulsion Program either 4 at sea or ashore. Eight of those years were in shipyard l
5 periods doing major reactor plant maintenance, refuelings, !
3 6 training for restart, and that sort of thing. And I had two 7 years as a senior member of the Naval Nuclear Propulsion I
8 Board doing examinations on reactor plants.
t 9 The remainder of my career was either in school or 10 working on national policy issues. I was fortunate to have 11 had the opportunity to work with General Powell in 12 concluding the START Treaty at the assistant secretary 13 level, and most recently have worked with DOE and the 14 j national labs and DP on sustainment of the nation's nuclear !
15 weapons stockpile without the benefit of underground nu'elear l 16 testing. ;
8 17 I was part of the navy's original retention 1
j 18 program that started back in the early and mid-1960s, and
- 19 throughout my navy commands the retention of my j 20 organizations has always improved.
i 21 And I've been with Northeast Utilities for four !
22 months now. I 23 [ Slide.]
i
- 24 MR. GOEBEL
- The subject that I'm going to talk 1
4 25 about today is the employee concerns program.
i i
i ANN RILEY & ASSOCIATES, LTD.
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42 1 The fundamental objective is the number six 1 2 objective which Bruce has just given you. We want to 3 establish an environment that supports the identification 4 and effective resolution of employee concerns.
5 (Slide.]
6 MR. GOEBEL: There are two prongs to that, the 7
first of which is the preparation of the comprehensive plan. ,
8 That plan was written with the assistance of the 9 employee volunteers. As Bruce has said, we put a call out 10 for volunteers, for people who would be interested in doing 11 that. We had 20 people come forward. We made no 12 selections.
13 We took those who sincerely wanted to work on it 14 and set them down for what started out as as month and then 15 ' ended up a little over two months with no real bounds on 16 them. They were free to suggest anything they wanted to 17 suggest, and it was done with the employee group essentially 18 with no oversight. They had the opportunity to say what 19 they felt and to line out a program.
20 We had two facilitators which we hired to bring in 21 to try and facilitate the discussion so that they would have 22 an idea of what good programs were in other utilities, and 23 they provided a program which has been the foundation for 24 what, as Bruce has said, we will be submitting tomorrow.
25 That plan provides for increased training for ANN RILEY & ASSOCIATES, LTD.
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43 1 members of the work force as well as members of management.
2 It works to improve the effectiveness of the ECP, I 3 that is, the employee concerns program, through a series of 4 process improvements.
5 We will be increasing the accountability of 6 individual behaviors of management. As part of that we will 1
l 7' have a system where we will do hot spot analysis. The 8 leadership survey will certainly help us in that regard, to 9 identify those managers who harass or intimidate.
10 Likewise, confidentiality is extremely important l l
11 to us, and this program helps set in place the protocols to 12 ensure we sustain confidentiality for those folks who have
- 13 concerns and who want to have confidentiality.
14 A key part of the program is the establishment of 15 an employee concerns oversight panel. The function of that 16 panel will be to oversee the employee concerns program 17 itself. That panel will consist of members from the work 18 force. They will additionally monitor for chilling effect; 19 they will monitor for harassment.
20 At the end of the day, when an employee has had 21 his concern dealt with in'the best way in which the program 22 thinks is appropriate and everyone has had their say, if the 23 employee is still dissatisfied, there will be a provision to 24 have a third party reviewer to come in, take a look at it, 25 and give judgment on the employee's issue.
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44 1
So we think that this particular employee concerns ,
2 oversight panel will go a long way towards helping ensure 3 that the concerns are properly handled.
4 COMMISSIONER ROGERS: How many people are on it 5 and do they stay on there? Or do they rotate? -
6 MR. GOEBEL: We are currently planning seven with 7 a full time administrator. There will be some sort of a 8
rotation plan, maybe after a year and a half to two years, 9 but it's going to be a reasonable period of time.
10 There is some question as to whether the panel j l
11 should have outside members on it similar tr ' nuclear !
12 safety assessment board. Those are being weighed now to try 13 and sort out what gives a fair, impartial effective panel to 14 take on the issue that may or may not come up.
15 CHAIRMAN JACKSON: Have you done any comparison of 16 your proposed program to programs in other industries or in 17 other companies?
18 MR. GOEBEL: We have in other companies. The team i
19 was encouraged to go out and sample other utilities, and j 20 they have done that. They went out as part of their 21 preliminary work, found out what other utilities had done, !
22 and our two facilitators for the group had come from a 23 background of very heavy involvement in employee concerns 24 programs. So they could provide some of that insight on 25 what were good programs, what were not good programs, what ANN RILEY & ASSOCIATES, LTD.
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4 45 1 really made sense to do and what didn't.
2 The team embraced them. They felt very 3
comfortable with the two folks that came in. As I said, we
! 4' stayed out of it. It was their process.
5 CHAIRMAN JACKSON: You've laid out the 6
comprehensive plan objectives, but I'm always performance 7 oriented. What are your metrics for knowing that you've 8 accomplished it?
9 MR. GOEBEL: "Show me."
10 CHAIRMAN JACKSON: But how are you going to know
! 11 you've accomplished those objectives and how will more than 12 Dave Goebel know that you've accomplished those objectives?
13 (Slide.]
14 MR. GOEBEL:
This slide and the next slide are ten J 15 objectives, and I won't bother reading them.
16 First off, it might help to understand where the 4
j 17 objectives came from. The objectives came from those 18 deficiencies that were outlined to us in two fundamental l 19 reports, the FCAT report, fundamental cause assessment team 20 report, which had been commissioned by the company, and the 21 Hanan report. Those reports went through and delineated in 22 some detail where historically we had failed to meet the 23 mark.
24 The program sets its objectives, and these were 25 the objectives that the team set out to satisfy, to look at ANN RILEY & ASSOCIATES, LTD.
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46 1 these things and to say, what does it take, what are inputs 2 that if we did certain fundamental actions would lead to a 3 correction of that deficiency. So they have devised a 4 series of 110 or 120 different types of things which should 5 be looked at in order to go through.
l 6 Those have been formulated into concrete packages 7 to lay out a process in which we will address each one of 8 those. When the plan is submitted, it will be submitted 9 with these objectives in it, and next to those objectives 10 will be elements which we carried out in order to satisfy or 11 meet those objectives.
12 Measurements will come in probably three ways.
13 One is the standard KPIs that will come out of it 14 and measure a number of concerns, how long they are open.
15 Just those types of things that show effectiveness of the 16 program.
17 A second measurement method will be through the 18 third-party oversight panel which has been directed by 19 order, and I'll talk to that. in a minute.
20 The third way is you go around and ask. Bruce has 21 plainly said this. We have got to establish the rapport 22 with the work force that management is interested in their 23 issues. We want to hear them, we want them to bring them 24 forward, and we will accept them and work with them in order 25 to solve the issues that they have. Whether they be safety ANN RILEY & ASSOCIATES, LTD.
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47 1 issues, personnel issues that affect the performance of 2
their job, we will help them see that those types of issues 3 get solved.
4 4
Although the fundamental focus of the program may 5 be safety issues, we recognize there are a lot of other 6 issues out there that the work force also has, and we will 7 facilitate getting those to the right section of the 8 organization.
9 CHAIRMAN JACKSON: Will the effectiveness of the 10 line managers in dealing with employee concerns all the way 11 up the line be part of the performance appraisal for those 12 individuals?
- 13 MR. GOEBEL: It will. One of the taskings that 14 will go out to the human resources development process is to 15 go back and modify job descriptions to make it a 16 consideration when hiring individuals, and it will go into 17 our internal evaluation system. So when you evaluate an 18 individual there will be a box there that says how does he 19 or she do in relation to handling employee issues, employee 20 concerns, or whatever. So every time your annual review 21 comes up you will be graded on that assessment to make a 22 determination as to how you as an individual have done.
23 CHAIRMAN JACKSON: Relative to the objectives that 24 you've laid out in this overall comprehensive plan?
25 MR. GOEBEL: There will be guidance that lays out ANN RILEY & ASSOCIATES, LTD.
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48 1 how they should do that process. Yes, ma'am.
2 (Slide.]
3 MR. GOEBEL: Unless there is interest, I won't 4 read those ten items. It's still line management's S responsibility to make this program work. They have got to 6 demonstrate that they have the willingness to talk to their 7- employees.
8 They have got to demonstrate that they have 9 established an environment where safety questions are 10 welcomed.
11 Additionally, the line is responsible for 12 championing zero tolerance for harassme , intimidation and 13 discrimination.
14 COMMISSIONER ROGERS: What does zero mean? What 15 does that really mean?
16 MR. GOEBEL: What it means is that, one, it is not 17 a tolerated management precept that if you harass a fellow 18 employee that that's an accepted mode of behavior, and they I 19 must work to root those out, have systems that help them i 20 identify that through their own management chain.
21 Some of it will be feedback from the employee 22 concerns program, either through this concerns oversight 23 panel which we have established or through just the handling 24 of the concerns themselves that will come out of the 25 process.
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49 But they have got to champion that and they've got 1
2 to make their people understand that in the course of doing 3 their business they will not tolerate that behavior in their 4 own organization. So in that sense it's zero tolerance. I 5 do not allow that here.
6 MR. KENYON: It means if we find it, we're going 7 to deal with it severely, up to and including firing the 8 individual.
9 [ Slide.]
10 MR. GOEBEL: The ECP program then becomes a safety 11 net for the line.
12 The ECP program will assist the line in handling 13 the concerns, acting fundamentally as a facilitator. I 14 In those cases where that doesn't work, then the 15 ECP program provides an alternate path. Today that path is 16 necessary. The. trust of some of the employees remains low.
17 We've got to regain that trust, and this program is one way 18 to do that.
19 CHAIRMAN JACKSON: Do you find there are new hot 20 spots emerging?
21 MR. GOEBEL: Not right now.
22 CHAIRMAN JACKSON: Have the old ones been 23 resolved?
24 MR. GOEBEL: There has been such a shift in 25 management that we have not seen new ones develop, and the ANN RILEY & ASSOCIATES, LTD.
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50 i
1 old ones that might have existed have not risen up.
i 2 As we go through this process of evaluating 3 members of the management team at all levels for leadership 4 characteristics and people are forced to walk the talk, we 5 are going to find out very quickly those that are on the
- 6 team and those that are not on the team, and if we have a 7 hot spot, it's clearly because we will have found in'an 8 organization an area where there is not someone on the team.
9 [ Slide.)
10 MR. GOEBEL: In addition to the plan, we have 11 submitted the name of a third-party oversight team, Little 12 Harbor Consultants. That's a ten-person team. In so doing l I
j 13 we have received inputs from over 20 different companies or l 4
14 individuals who wanted to be a part of the process as we 15 went through this. We asked eight companies for RFPs and 1
i 16 ultimately interviewed six, and the selectee out of that 17 process became the Little Harbor Consultants.
i l 18 Their function is clearly outlined in the order:
e
- 19 Provide an independent assessment.
20 The need to evaluate for improvement.
21 And they need to determine what the-needs are for
! 22 additional change.
23 After reviewing their qualifications, they came in 24 and briefed us, told us how they intend to conduct business, 25 how they intend to work to involve all the stakeholders, ANN RILEY & ASSOCIATES, LTD.
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1 including the public in the process. I think they've got 2 what it takes to do this job.
3 COMMISSIONER DIAZ: Excuse me. I have a question 4 on that. I'm sure when you evaluated Little Harbor you were 5 very concerned with their experience in handling employee 6 concerns. Was it clearly established that they had the 7 capability of correlating safety concerns with safety issues 8 in a manner that will be clearly and promptly identified?
9 MR. GOEBEL: Yes. I believe they have five 10 engineers who are specifically skilled in the areas. If 11 there is a safety concern and we fail to recognize it, they 1
12 certainly should be able to.
{
13 COMMISSIONER DIAZ: Thank you. I 14 [ Slide.)
15 MR. GOEBEL: The final thing I wanted to say is we 16 have had some successes in the recent past. So we are 17 making progress.
18 I cite on the slide that on the first of December 19 we had 44 concerns which were under investigation and the 20 oldest was up to four years old. In the previous two or 21 three years or four years our average closure time was over 22 200 days. Very long. Things just sat; they festered; there 23 was no satisfaction really given to the employee when he or 24 she had a concern that anybody cared. It's clear from the .
25 statistics.
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52 1 As of the 24th of January, a little less than two 2 months, we had 22 open concerns that were under 3 investigation. The oldest was about 22 months old, and that 4 includes what was a holdover from the previous number. But 5 those received since the first of December through the 24th 6 of January the average closure time was about 18 days.
7 So clearly there has been a prompt change in the 8- process. That I attribute to two things. One is a very 9 -senior level involvement on the part of the units. The unit !
10 recovery officers and the unit directors are personally 11 taking an interest in resolving these concerns.
12 That is filtering down through the organization. .
13 The organization then starts to see at the middle level the 14 concerns which Bruce has talked about. That is going to go 15 a long way towards improving the overall handling of these 16 issues and the restoration of the employee trust in 17 management.
18 I will say also that the submission rate of 19 concerns to the employee concerns program has increased.
20 Frankly, I don't take that as all bad. I want them to say 21 the stuff. I don't want them to be out there allowing these 22 things to fester and not come forward. We are trying to 23 generate an atmosphere where they truly know that we want 1
24 the concerns that they see; we want them to bring them l 25 forward; and we want to get them no matter how we get them; l 1
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l 53 1
we don't want them to sit there and fester. '
'2 If there are no other questions, that concludes 3 the briefing.
4 COMMISSIONER DIAZ: I just wanted to make a L 5 comment that since this deals with employee concerns and how 1 1
1 j 6 they are doing their jobs and you have changed from the 7 military to the civilian, we will not hold against you your 8 distinguished military career.
9 [ Laughter.] !
10 MR. GOEBEL: Thank you very much. I appreciate i
11 that. No further comment.
12 CHAIRMAN JACKSON: Commissioner Rogers.
- 13 COMMISSIONER ROGERS: Not on this. Thank you.
14 CHAIRMAN JACKSON: Okay.
15 MR. KENYON: Jay.
16 MR. THAYER: Good morning. I'm Jay Thayer. '
I'm 17 an electrical engineer by training. I spent 23 years in '
18 various technical and managerial positions in the commercial :
19 nuclear power industry in both engineering and operations -
20 areas of responsibility. I've been in executive management 21 for the last six years, most recently serving as the Vice 22 President of Engineering at Vermont Yankee Nuclear Power 23 Corporation.
24 [ Slide.]
25 MR. THAYER: The purpose of my presentation this i i
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54 l 1
1 morning is to cover what Bruce outlined as objective number l 2
five, and the measurement of that is we must have by restart 3 i restored licensing and design basis with processes to ensure 4 that they are properly maintained.
5 We are currently implementing our configuration 6
management plan to restore the design and licensing basis 7 for the three Millstone units, and the effectiveness of our
.8 efforts will be independently confirmed by the ICAVP 9 contractor.
10 A little bit about my role. As discussed before, 11 my organization is a standard setting organization. In 12 addition to some of the engineering programs that we manage, 13 we run the 50.59 procedure; the design control, program is 14 under my organization; the configuration management program 15 and technical programs as mentioned before, such as the MOV 16 program.
17 We have moved into a more active role in the 18 configuration management program. As the three units 19 developed the programs last summer and last fall, in the 20 last several weeks, since about the first of the year, we 21 have moved into a role of overseeing and trying to levelize 22 that effort.
23 One of the first accomplishments that we made was 24 we performed a self-assessment of the three-unit 25 configuration management plant, looking for consistency. We ANN RILEY & ASSOCIATES, LTD.
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55
. 1 understood going in that they would ncit be identical, but we 2 also understood we wanted some leve?., some standard set so 3 that when the ICAVP contractor came in or when your 4 inspection people came in there would be some common 5 understanding of what had been done to restore both the 6 licensing and the design processes.
7 Furthermore, as of about a week ago I've initiated 8 under the direction of Bruce Kenyon an independent 9 assessment as to the degree of consistency that will be 10 needed for the units in implementing the CMP.
11 My current plan is to bring in some of the outside 12 senior review people who have been engaged in reviewing the 13 50.54 (f) responses for the industry. I feel that the 14 knowledge that has been gained by those folks in the last 15 few months will be vital to us, number one, to benchmark our ;
16 efforts against the industry efforts, and also to achieve 17 this consistency goal that we are looking for on the 18 Millstone site between our three units.
19 [ Slide.) ,
20 MR. THAYER: The stated purpose of our 21 configuration management plan is very simple. It's to 22 provide a reasonable assurance that the future operation of 23 each unit will be conducted as specified in the terms and 24 conditions of the unit's nperating license, NRC regulations, 25 and the unit's updated FSAR.
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55 1 [ Slide.]
2 MR. THAYER: Getting back to the configuratd>n 3 management plan, this is our guidance document. It's simply 4
to tie our actions that we take in configuration management -
5 to the requirements of the 50.54 (f) letters, the various ,
6 letters that have been issued for the three Millstone units.
7 [Liide.)
8 MR. THAYER: This configuration management plan is 9 a high level document. t 10 It applies to all three units. '
11 It is implemented by a series of project i 12 instructions. Over the past month the effort has been to i 13 update the project instructions to more accurately reflect 14 what is going on on the three sites and to look for 15 consistency. i 16 CHAIRMAN JACKSON: Could you describe the l
17 availability of the design and licensing basis information p 18 at each site?
19 MR. THAYER: It varies and it varies primarily, as 20 you would expect, by the vintage of the plan, the vintage of '
21 the license, the type of the NSSS, and also, quite frankly, i 22 the time that the various configuration management teams 23 have been in place.
24 The level of investigation on Unit 3, for example, '
25 is ahead, primarily for two reasons. One, because the team i
I
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57 1 has been place longer; two, because the vintage of that unit 2 is such that a lot more of the design basis is more readily 3 recoverable.
4 On Unit 1, for example, the FSAR is simpler.
The 5 backup to that, the calculations, the design, the drawings, 6 there are fewer in number of them. So even though it is an 7' older unit, the amount of information to recovet s less. !
1 8 That has held true.
9 There are other idiosyncracies. We find pockets 10 of where certain parts of the design and licensing basis 11 have been particularly well maintained. For example, the 12 incidence of findings on the Unit 2 FSAR is lower for some 13 reason than the other two units, We don't understand that 14 yet; we don't want to attempt to explain it; but it's just a 15 finding as we have marched through the various design 16 documents and licensing documents.
17 CHAIRMAN JACKSON: Are you saying that you will or 18 you won't have a large reconstitution effort to do?
19 MR. THAYER: The reconstitution of information 20 will be taken on a case by case baels and it will be decided 21 based on the safety significance or on the ability for us to 22 prove the function of a particular system or the function of 23 a particular component. If it is deemed necessary to be 24 able to prove a design basis fact to reconstitute, then we 25 will reconstitute.
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4 4 58 1
[ Slide.)
2 MR. THAYER: We also understand that design basis 3
and licensing basis recovery involves ongoing processes.
4 These processes have not been done well in the past at 5
Northeast' Utilities, and we understand that the 6
configuration management plan is not a one-time. effort. In 7
recovering, reconstituting, documenting, collecting the 8
design basis and licensing basis we also have to put into 9
place robust programs which will ensure that these processes l
10 continue on or after restart and for the remaining life of 11 these plants.
12 [ Slide.)
13 MR. THAYER: To wrap up, the engineering programs '
14 and the documents that are being assessed. We will have by 15 the start of the ICAVP a significant amount of that 16 information corrected and updated. We provided the 17 remaining updates to the information prior to restart, an 18 update of all the engineering programs and the processes to 19 support the updating of those that I mentioned a minute ago, 20 well developed and implemented and validated prior to 21 restart.
22 CHAIRMAN JACKSON: Let me ask you this question.
23 You talked about a review of NRC commitments. What has your 24 early sampling told you? Where do you stand with respect to 25 that?
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- 59 1 MR. THAYER:
3
)
From the standpoint of access to the l 2 commitments, on Unit 1, for example, we have completed a 100 a
- 3 percent review of the commitments. So the first point is ,
4 they are easily retrievable. ,
i 1
5 The second point is we feel that that is the 6 discovery retrieval. We are going through the validation:
l 7 Have those commitments been carried out in the practices and 8 procedures on site?
9 CHAIRMAN JACKSON: i That's what I'm interested in. l 10 MR. THAYER: I don't have a good feel for that at j 11 this point. That is the validation process that we are I i
12 currently going through.
13 MR. BOWLING: I would add, Jay, that that's the 14 effort that is about to be undertaken on a large scale. So 15 over the next three to five months they will be validated 16 and results will be in.
17 CHAIRMAN JACKSON: So I should ask you again at 18 the next meeting?
19 MR. BOWLING: Yes.
I 20 CHAIRMAN JACKSON: With respect to the FSAR review 21 and update, what is your progress in that area and how would 22 you categorize the findings to date? If you could give a 23 few examples and talk about their risk significance.
24 MR. THAYER: The FSAR was one of the first areas 25 of review and discovery in the configuration management ANN RILEY & ASSOCIATES, LTD.
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GO 1 plan. Mike might want to talk about the Unit 3 progress in 2 that area because it's further along. But we have a 3 significant number of findings on all three of the FSARs.
4 Like I said, Unit 2 being less for some reason.
5 Right now we are going through a process of 6 prioritizing those findings: What is the impact? I won't 7 trivialize it by a typographical error. Does it impact the 8 ability for the system to satisfy the design basis fact in 9 question? Does it misrepresent a system design basis fact?
10 Does it not capture a critical licensing commitment?
11 These are being prioritized and screened right 12 now, and they will also be prioritized as far as which one 13 of those will go into our FSAR updates which will be 14 submitted prior to startup.
15 CHAIRMAN JACKSON: What improvements are you 16 looking to make in your 50.59 program?
17 MR. THAYER: We have made quite a bit of progress 18 in 50.59 already. In one of the early efforts last fall we 19 had an initiative by Unit 1 to perhaps adopt one of the PECO 20 50.59 processes. We put a team together, some of my folks, 21 the Unit 1 folks.
22 We looked at the existing Northeast 50.59 process 23 and came to the conclusion that the process of performing 24 the safety evaluations was fairly current; it was fairly 25 rugged; it stood the test against an industry benchmark; but ANN RILEY & ASSOCIATES, LTD.
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61 1 what we found was our screening process for when we should l 2 be performing 50.59s was terrible.
3 In other words, the 50.59s that we were doing, 4 most of those have been pretty good safety evaluations, but 5 we weren't performing safety evaluations on' changes and 6 issues that came up on operability determinations as were 7 others in the industry. So our screening process to tell an 8 individual when a 50.59 was necessary was broken.
9 That has been the major focus of the procedure 10 upgrade. That procedure has been revised, and training is I 11 going on right now with personnel to implement that 12 procedure. ~
13 CHAIRMAN JACKSON: When you speak of meeting the 14 !
50.54 (f) letters prior to restart, what do you mean by that?
15 And in order to have time for the NRC staff to review, you 16 have to resolve what prior needs in that regard?
17 MR. THAYER: We understand that. It's my 18 understanding that the formal letters have a seven-dsy prior 19 to restart commitment in them or request in them. That 20 obviously is not enough time to assure compliance with all 21 the requirements of these' letters. We have built in various 22 time frames in our recovery schedules for inspection 23 activities which would come after the ICAVP which would 24 monitor progress prior to restart. I don't have the exact 25 time frame, but there is a considerable --
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62 :
1 CHAIRMAN JACKSON: You've built in and resolved 2
those milestones with the NRC staff?
3 MR. THAYER: I wouldn't go so far as to say 4 they've been resolved yet. However, we have acknowledged 5
that it will take a finite amount of time and not seven days i 6
to resolve those kinds of issues.
T MR. BROTHERS: Chairman Jackson, Mike Brothers.
8 In terms of the official schedul'e that we are putting on the l 9
units, our schedule goes up to the point of when we are in 10 fact ready for restart. ,
In other words, when we submit that 11 letter to you. ;
After that there is no formal schedule.
12 CHAIRMAN JACKSON: Okay. ~
13 MR. McELWAIN: Good morning, my name jus Jack 14 McElwain. I'll keep the intro short. I've been with PECO 15 Energy since 1968 and I've spent since 1984 at Peach Bottom.
16 I've been here since October.
17 [ Slide.]
18 MR. McELWAIN: I'd like to talk a little bit this 19 morning about the corrective action program. !
20 We saw a need and the need has been obvious over 1 21 time that the corrective action program did not work. !
22 The first slide tells you the things that were 23 lacking in the corrective action process, i.e.
24 accountability, quality and timeliness of the evaluations.
25 We didn't have an effective issue and commitment tracking, 1
l ANN RILEY & ASSOCIATES, LTD. l l
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63
. I and we didn't do very much trending at all.
1 2 CHAIRMAN JACKSON: Was the QA involved in that?
3 What is the QA organization? Have they looked at this area 4 of issue trending recently, and what definition is there to 5 effectiveness in this context?
6 MR. McELWAIN: It's easier to say the opposite, 7 that they weren't effective because we didn't really do it.
8 CHAIRMAN JACKSON: That's ineffective.
9 MR. McELWAIN: That's just the way we were in the l
10 fall. But the oversight organization did do a corrective 11 action audit in November while we were in the process of 12 changing it, and they did validate that the things that were 13 happening in the past were still not fixed.
14 CHAIRMAN JACKSON: Does this mean your QA 15 organization needs reconstitution, or is there something 16 else, some other way? !
1 17 MR. McELWAIN: I think 'ne QA organization from l
1 18 the past is being reconstituted, and that is one of the i 19 recovery organizations that is happening in parallel with 20 us. So I don't think that is something new.
21 CHAIRMAN JACKSON: The first role is with the 22 line, but the role of the QA organization is important on a 23 going-forward basis. You have the corrective action 24 program. It's important, at least in my mind, that we 25 understand how that reconstituted QA organization and your ANN RILEY & ASSOCIATES, LTD.
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64 1 handling the corrective action program coalesce.
2 MR. KENYON: We had targeted that as a future 3 presentation. I think coming into this it's obvious that 4
oversight, meaning OA and other things, was not right. Dave 5 has done a lot to fix that. I feel much better about the 6 audit reports that we have today versus what we had a month I 7 or six weeks ago. We do plan on a future presentation to 8 give you.
9 CHAIRMAN JACKSON: So you want to talk to us today .
10~ about overall where you are planning to go in corrective 11 action but this is a commitment that you are going to talk '
12 to us specifically about the QA organization and how it fits !
13 into this. i 14 MR. KENYON: Absolutely.
1 15 CHAIRMAN JACKSON: Okay.
16 MR. McELWAIN: We did revise the corrective action 17 program to address these issues. But more importantly, we 18 took a management perspective at each of the units. We had 19 a management review team that looks at every adverse 20 condition report that is generated, and it used to be a '
i 21 different process than it is now.
22 I The process now is the management team looks at it !
23 every day. We determine the significance level of it. We l
24 assign it to a certain individual. We have established l 25 commitments, had people own up to those commitments and own l
l t
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65 i 1 that particular ACR and follow through to completion.
I I i
2 Historically you could have an adverse condition 3
report closed without all the corrective actions being 4 complete. We stopped that. No adverse cc ndition report j
1 l
5 -- in the new model it's going to be condition report -- i
! 6 will be closed without the corrective actions being 7 complete. It's a lot harder to lose track of_ things that 8 you said you were going to do versus did you do them.
9 That same cross-discipline team looks at all the 10 t
corrective actions and root causes on the adverse condition 11 reports to determine if they really meet the description of 12 the incident or the adverse condition itself. '
13 We also look at the proposed corrective actions l 14 and the timeliness of them to see if they fit where we think 15 they should be in the grander scheme of things.
l 16 [ Slide.]
l l 17 MR. McELWAIN: We have upgraded root cause l 18 analysis capability. It comes with the change in the l
! l i
19 process. For example, Unit 3. A whole lot of people have 20 been trained. What they are using is a vendor FPI process i
21 on causal analysis trending, how to do those particular 22 issues. That's captured in the procedure.
23 Unit 2 has a lot of people trained in that. Unit 24 1 has less people in that, but we're all going down the same 25 path. This is one program across the units, and that's how i
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we are going to make sure that we really do the right root ;
2 cause analysis of the right causal factors. :
3 A key to go hand in hand with a good corrective ,
4 action program is two issues.
5 One is a self-assessment. I don't mean ,
6 necessarily formal self-assessment as prescribed on a ,
7 bi-yearly basis like most utilities have. It has got to be ,
8 a constant way of looking at how you do business, whether !
9 it's how you did the performance that week or it's how an i
10 operator evolution went. It's constantly being critical in '
11 figuring out how to do things. Even if you did them well, j l
12 how to do them better. That's what I'm looking at as the 13 self-assessment piece. It has to becot..e generic to the site 1 14 l and the way we normally do business on a daily basis. '
15 The other part of that is a worker observation 16 program. What this implies is that management can't be 17 sitting in a different building. They have to be out in the 18 plant. They have 'co be observing the work activities. If 19 -they see somethin;. that is not correct, they have to take 20 immediate intervention on it, even if it's something as 21 simple as earplugs required. l 22 You talk to the people about what they're doing, 23 look at the procedures, see how they ala doing the work to 24 make sure that you do a one on one immediate intervention.
'25 Raising the standards is an easy way to do that. You get ANN RILEY & ASSOCIATES, LTD.
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67 1 out there.
i People become more engaged in the bigger picture 2
of how the power plant works if they are not stuck in their
- 3 particular office looking at paperwork, ACRs or AITTS, which 4
are the computer systems that track these issues. I think i 5 i
those two things are going to be important in allowing us to
- 6 s
have a better corrective action program going forward, j 7 [ Slide.]
8 MR. McELWAIN: The corrective action formal 9
program change is effective the middle of February. We 10 instituted from a management perspective the things that are 11 in there back in November, but this formalizes that and j 12 4
gives us time to train the people that have to do different
- 13 evolutionary steps in the process to allow it to be done in 14 a controlled, efficiency manner.
15 We also have established strong line management
. 16 ownership and accountability for the corrective action !
17 process.
It's one of the issues that I am the sponsor for 18 and the other unit recovery officers as well as Jay have i 19 issues that they are sponsoring.
20 It shows mainly if people understand that 21 management has an interest in it, they are the things that j 22 they are going to be interested in.
i This will also help 23 with employee concerns. If somebody identifies something, 4
24 we can fix it right and don't have it happen again. It 2
25 doesn't have to wait and fester and turn into a concern i
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68 1- sometime down the road. That also will help that program.
2 We have performance indicators presently for each 3
unit, by each organization to trend issues coming in at !
4 significance levels, whether they are overdue or not :
5 overdue; corrective action is being developed as well as ;
6 completed. It's a whole series of indicators that we go 7 over in house on a normal basis. Actually on a weekly basis 8 at Unit 1.
9 (Slide.)
10 MR. McELWAIN: The indicator I attached was just 11 to give you an idea. This is just raw data on the adverse ;
12 condition history since September of those that have come
13 in, which is the dotted line, and those which have been .
14 closed out, which is the solid line.
15 As you can see there is a screaming up the hill, 16 which is what we would expect it to do. The threshold is 17 very, very low. We get some things that could appear to be r
18 nonsensical in a certain environment. We don't treat them 19 that way. We don't say that can't be an ACR. We make it an 20 ACR. We go along with it. We give it the significant ,
21 level it needs. If it's something we can trend, something !
22 we use in the trending bin, something that requires 23 immediate action, we try to take that action.
i 24 In the solid line rising you see to match the 25 input there is a real time lag. There is a big backlog of t ANN RILEY & ASSOCIATES, LTD.
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4 69 1
- ACRs historically. When the recovery teams first got here 2
we set up with each individual who had responsibility for 3 these actions: When are you going to be done? We need your 4 commitment to do it. Tell us what resources you need and 5 we'll get them for you, i
6 Most of them, as you can see, kind of focused on
, 7 the end of the year, because we were asking this question in 8 early November.
i That rise in the closecut rate is based on
- 9 people starting to meet those commitments that they made to i
- 10 close those ACRs out. That's really all that graph is 11 indicative of.
12 CHAIRMAN JACKSON: Commissioner Rogers.
13 COMMISSIONER ROGERS: The correction action 14 program, of course, is very important. But it's sort of 13 implies that it's corrective, that something didn't go right 16 and it has to be fixed. In this worker observation program 17 you focused on management participation. Have you given any 18 thought to actually using workers to help to identify better 19 ways of doing things so that you avoid something that has to 20 be corrected?
21 MR. McELWAIN: Yes. In the new program there are 22 three levels. There used to be four. They used to be A, B, 23 C and D. Now they are 1, 2, 3. One and two are the real 24 issues that are corrective actions.
25 Category 3 is enhancements. You want to improve a ANN RILEY & ASSOCIATES, LTD.
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procedure that you don't have control of, that you can't l i
2 improve yourself. A work process you want to improve; l 3
something you think could be an enhancement no matter what l 4 it is. That's what the level 3's are going to be for. l 5 That's the formal avenue for doing that. That's l I
6 why we have to have everybody understand what that process 7 is for and why it's necessary to have these issues come out.
8 Even if they are enhancements and improvements, you capture 9 them, you assign some actions to them, and you track them to l 10 completion. l 11 The thought going into the change was the first 12 two are significant, could be plant, could even be people 13 issues, but the third is really for enhancements and 14 improvements.
15 MR. BOWLING: I would add something. The way that 16 we are getting at this is to bring from our utilities people 17 up on a temporary basis. For example, licensed operators 18 that then can observe what shift operations is and make 19 those type of observations to the right standards.
20 CHAIRMAN JACKSON: Mr. Kenyon.
21 MR. KENYON: Chairman Jackson, in the interest of 22 time I'm going to be very brief in my closing comments.
23 I think we have indicated that we belir..ve the 24 fundamental problem that has plagued Northeast and 25 particularly Millstone for quite a number of years has been ANN RILEY & ASSOCIATES, LTD.
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- 1 leadership. We have fundamentally changed out the i
2 -leadership at high levels and we are still working down in !
- 3 .the organization.
i 4
4 This team is cothmitted. This team is
- j. 5 enthusiastic. This team clearly understands the standards i
6 that need to be set. There is no doubt in my mind we can do 7 what needs to be.done.
i The issue is execution and how long 8 it is going to take.
9 We are working hard. We know that the key issue 10 here is demonstration of performance, and that's what we 11 intend to do. We also know that a key issue is 12 communication, communication with the public, communication
- 13 with you, the regulator.
14 You asked me an earlier question regarding do we 15 know what needs to be done. We do think we know what needs 16 to be done. We have not at this point fully communicated 17 that to the NRC. There are requests for what are your 18 action lists and that kind of thing. We will be responding 19 to those.
20 We do seek a couple of things that are maybe 21 obvious. One is an acceptance of this leadership team on 22 its merits. We know that there-is a lot of regulatory 23 history that represents how NU has behaved historically. NU 24 has been rather defensive, rather contentious, rather 25 legalistic, and that behavior produced understandable and t
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1 corresponding reactions by the NRC, and thus I think the I 2 regulatory relationships when I arrived were not good.
3 That's the company's fault.
4 I want you to know that that is clearly not what 1
5 this leadership wants. We intend to be fully open, fully l 6 candid, not defensive. We will share the information. We 7 know that there are regulatory challenges that need to be l 8 met, and we intend to fully work with you. So certainly we 9 want to be judged on the basis of what we do and the 10 performance we achieve and not be judged on a history that 11 at least this team did not create.
l 12 Second, we are hopeful and believe it's important l 13 that there be a sufficient commitment of resources to 14 support the inspection and regulatory resources to support l 15 the recovery of these units.
{
l 16 Certainly, based on the actions you took yesterday 17 in putting quite a number of plants on the watch list, we 18 know we're not the only ones with problems, and I'm not !
19 suggesting that misery loves company. We have been down for 20 a while. We need for a lot of reasons to get these units 21 back and we know that is going to take a commitment of 1
l 22 resources from the Commission. We want to work with you to l 23 be as supportive on that as we can.
24 We believe that this may constitute the largest 25 management turnaround in the history of the nuclear ANN RILEY & ASSOCIATES, LTD.
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73 1 industry. Maybe that's an arguable point, but that's what 2
we've got to do and that's what we are committed to do.
3 This concludes our remarks.
4 CHAIRMAN JACKSON: Thank you, Mr. Kenyon. .
5 Let me make a couple of comments to you.
6 Obviously everyone is aware of how long the units have been 7
down, what it costs for every month they're down. It can't 8
be more important to anyone than the company itself, its 9
shareholders, those who work at the company, as well as 10 those in the community that have a stake. You're the ones 11 who are going to have to rebuild the trust of that 12 community. We have our own job with respect to regulatory 13 confidence, but in the end you're the ones who.own and 14 operate those plants. So the stakes are highest for you.
15 I don't think there is any question but that the 16 Commission will accept the team on its merits, but what that 17 means is that the focus is on what you do, not what you have 18 been.
19 We all like to feel that if we come at something 20 with good reputations that we want people to believe that we 21 are going to do what we say we are going to do, but in many 22 ways how we got ourselves to here is taking promissory 23 notes. One should take what you say at face value, but in 24 the end, as we work our way along, what we are looking for 25 is measurable progress in each of the areas, particularly ANN RILEY & ASSOCIATES, LTD.
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. e 74 1 the ones that had gotten to points where we felt we had to 2 issue orders with respect to.
t
, 3 I think if we all understand that and you're 4 working with the staff and you're working with those in the l
5 State of Connecticut who are involved in good faith and 6 openness and with measurable progress, then we don't have a 7 problem. If it doesn't go that way, then you all have 8 stellar reputations, but in the end when we come to make our l- 9 decision it's going to be on the basis of what we see and 10 what we see has been done.
11 Unless there are any further comments from the j 12 Commission, I think we will hear from the NRC staff, who 13 will be given equal opportunity.
14 MR. KENYON: Thank you, Chairman Jackson. I l 15 couldn't agree more with your closing comments.
16 CHAIRMAN JACKSON: Mr. Thompson, you can begin.
17 Would you begin, though, by introducing the members at the 18 table with you, please, j 19 MR. THOMPSON: I would be delighted to, Chairman 20 Jackson.
21 To my left is Wayne Lanning, who is the Deputy 1
22 Director for Inspections for the Special Projects Office.
23 To my immediate right is Phil McKee, who is the 24 Deputy Director for Licensing, the Special Projects Office.
25 He will be giving the briefing this morning. Unfortunately, ANN RILEY & ASSOCIATES, LTD.
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i a d-75 1 Dr. Travers had a death in the family and is not able to be 2 with us this morning.
3 To Mr. McKee's right is Frank Miraglia, who is the 4 Acting Director of the Office of Ni. clear Reactor 5 Regulations.
6 To his right is Mr. Gene Imbro, who is the Deputy 7 Director.of Independent Corrective Action Programs.
8 They will be prepared to respond to any questions 9 that we may have today. Phil McKee will actually lead us 10 through the staff's briefing.
11 As you know, in November of 1996 this new 1
12 organization, the Special Projects Office, was established
- 13 w:tthin the Office of NRR with responsibilities to include 14 al.1 licensing and inspection activities required to support 15 an NRC decision on the readiness to restart each of the l 16 three Millstone units. I was pleased by Bruce Kenyon's 17 recognition that their approach to move in parallel will add 18 a significant and a real workload challenge to the NRC 19 staff.
20 I think with that I will just turn it over to 21 Phil.
22 MR. McKEE: Thank you.
23 (Slide.]
24 MR. McKEE: As mentioned by Hugh Thompson, the 25 primary reason the Special Projects Office was created is to ANN RILEY & ASSOCIATES, LTD.
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provide a specific management focus on future NRC activities 2
associated with the Millstone units.
3 The new organization serves a primary function of 4 integrated Headquarters and Region I resources for 5 inspection, licensing and oversight.
6 As Hugh mentioned, Bill Travers is unfortunately 7* not able to be here with us today. He's the Director of 6 Special Projects Office.
9 Reporting to him are the three deputies here at 10 the table. We are responsible for the key oversight 11 activities.
12 CHAIRMAN JACKSON: So the director assumes the 13 roleofboththeregionaladministratorandtheassociabe 14 director of the projects?
15 That's correct, the region, and the MR. McKEE:
16 projects are integrated and focused to the Special Projects 17 Office director.
18 The regional arm of the Special Projects Office 19 includes a branch chief, resident inspectors, and the region 20 project engineer.
21 In January of 1996 each Millstone unit was 22 allocated a senior resident and resident inspector position.
23 Since then two new resident inspectors have been assigned 24 for Units 1 and 3 and we are in the process of selecting the 25 senior resident for Unit 2.
l 1
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, 77 i 1 I might mention that two of the residents are here l'
i 2 today, and also the branch chief, Jack Durer, and also the 3 resident for Millstone Unit 3, who is Tony Cerni, and the 4 resident for Millstone Unit 1, who is Ted Eastly.
5 CHAIRMAN JACKSON: Are you telling us that each of 6 the senior residents are new?
7 MR. McKEE: That's correct, since January. By the 8 time we select the third senior resident, which should be 9 shortly, they will all be new senior residents.
10 Special Projects Office is utilizing a minimum 11 number of full-time staff. However, the staff will be 12 supplemented, depending on ongoing activities by regional +
13 inspectors, headquarter technical staff, and contractors.
14 (Slide.]
15 CHAIRMAN JACKSON: Let me ask you a question. Go.
16 back to your first slide.
17 [ Slide.)
18 CHAIRMAN JACKSON: You have there that you will be 19 using contractor resources. They are going to be used in 20 what areas?
21 MR. McKEE: We are kind of bloating, depending on 22 license activity resources, but contractor resources are 23 going to be needed for a number of functions.
24 We are looking at contractor support for our staff 25 and for the independent corrective action verification ANN RILEY & ASSOCIATES, LTD.
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> a 78 1
program activities that the NRC will do on our oversight of 2 that program.
3 Also contractor support is needed for inspection 4
areas and maybe follow-up on some of the allegations that 5 the NRC receives.
6 Further, we are looking at some contractor support 7
even in the employee concerns program area to support some 8 follow-up activities and monitoring activities we have 9 planned there.
10 CHAIRMAN JACKSON: And they are going to be 11 independent of any organization or contractors that the 12 licensee uses in those same functions?
13 MR. McKEE: Definitely. We will be independent of 14 those organizations.
15 Back to the second slide, please.
16 (Slide.)
17 MR. McKEE: Although my presentation will focus on 18 staff activities to establish NRC's programs for assessing 19 the licensee's corrective actions and restart readiness, I 20 want to first emphasize that our primary responsibility at 21 Millstone continues to be the day to day assessment of the 22 licensee's safety performance. Most important' given the 23 status of the facilities, is our continuing assessment of 24 the licensee's safe shutdown operations.
25 As you heard from the licensee's presentation, ANN RILEY & ASSOCIATES, LTD.
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there have been a significant number of recent management
- 2 changes at the Millstone station. Staff has not had 3
sufficient time to assess the effects of all the changes 4 being implemented by this new organization.
5 Further, the licensee is still in a peri -?
6 discovery related to many issues, and in particular those 7 related to design and licensing basis.
8 Although it is premature to comment in any depth 9
on the recent performance, I would like to mention that our 10 inspection activities have identified improvements in 11 control of site work. Most significantly, schedules, 12 although some may be ambitious in our estimation, and 13 prioritization for major work activities have been developed 14 for all three units.
15 However, one area which continues to be an issue 16 and which has been identified in recent NRC inspection 17 reports is the licensee's follow-up in correcting identified 18 issues. Since corrective action processes is a very 19 important and critical issue, we plan to closely follow 20 licensee progress in this area.
21 (Slide.)
22 MR. McKEE: The staff is structuring our oversight 23 program in accordance with Inspection Manual Chapter 0350.
24 That manual chapter provides a process, including check 25 lists covering most every contingency, for assessing restart ANN RILEY & ASSOCIATES, LTD.
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.1 readiness of plants which are shut down-for complex events, 2
significant hardware issues, or significant management 3 weaknesses.
'4 The elements that I have listed on the slide 5 include some major activities and they are customized for i l
6 the Millstone review. I will just discuss a few here
'7 briefly.
8 Consistent with the manual chapter's guidance, we 9
have established a restart panel and restart assessment plan 10 focused on Unit 3.
11 The restart evaluation process specifically 12 includes Commission involvement. At Millstone that
- 13 involvement is substantial and encompasses periodic status 14 reports, including a quarterly briefing of the Commission 15 and restart authorization.
16 Regarding ACRS review, plants shut down for longer )
l 17 than one year are typically considered for review by ACRS.
{
18 However, ACRS at their option can be involved to the extent i 19 that they think is appropriate.
20 Public participation is a very important aspect. )
21 In most all of our oversight processes, including employee 22 concerns area and the ICAVP -- I'll keep using ICAVP.
23 That's one acronym I'll use, because it shortens it quite a 1 24 bit -- multiple means are available for public 25 participation.
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, 1 CHAIRMAN JACKSON: Do you have a long-range time 2 line formulated as yet that in some sense schedules, at i
a 3 least in a relative sense, each of the milestones associated i 4 with each of these pieces and that has some logical :
5 methodology for picking locations for public meetings? !
1 6 MR. McKEE: The processes for ICAVP and employee i
j 7 concerns identifies specific times. In those processes 8 public participation is specifie'd. Our goal is every six l 9 weeks or so to have a public meeting if it's not held for i
10 some other reason.
, 11 As we mention here and the licensee mentioned, 4 12 schedules are fairly open and haven't been well established 13 yet. So we really try to use those periodic meetings that 1
a 14 we have to pick up the issues of the time. In February we 15 are having a meeting with the public to discuss the ICAVP 16 and employee concerns. We are also including another issue j 17 that we are discussing there.
18 I think our interaction with the public is quite 19 substantial and fairly well laid out.
20 MR. IMBRO: Further, on the ICAVP we are al 21 planning to solicit public comments on the audit plan or get 22 public input on the audit plan when it's submitted by the 23 licensee. We will take those public comments into 24 evaluation in our approval process.
25 CHAIRMAN JACKSON: Are you doing that through ANN RILEY & ASSOCIATES, LTD.
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82 1 public meetings?
2 MR. IMBRO: Meetings with the public, Dr. Jackson. ;
3 We usually meet with the public in the evening and solicit ,
4 their input.
5 Also, we have committed to have periodic status 6
meetings on the conduct of the ICAVP or progress of the 7- ICAVP with the public. We want to keep them apprised of the 8 status. ,
1 9 MR. McKEE: Getting back to the assessment plan, 10 the plan also provides for coordination with other agencies 11 as appropriate, and organizations. This may include FEMA, $
12 Department of Justice, and the state as necessary.
, 13 .
Most importantly, the process results.in a 14 documented basis for NRC's restart readiness evaluation.
15 This basis is to be used by the NRC senior management and 16 the Commission in making decisions regarding the restart of 17 any of the Millstone units.
18 (Slide.]
19 MR. McKEE: The core of our planning is documented 20 in the restart assessment plan. In particular, the plan 21 identifies areas where regulatory emphasis is needed. The 22 plan is a living document and will be revised periodically 23 as we go along.
24 The first two items listed, the ICAVP and employee 25 concerns, are major elements of the plan, and I will discuss i
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! 1 these later in a little more detail.
2 However, it needs to be emphasized that the i
i 3_ employee concerns and ICAVP elements, as important as they 4 may.be, are only elements of a much larger plan. Many of 5 the other elements, such as corrective action -- and I think j 6 that was discussed by the licensee here -- work planning and 1
7 controls-and quality assurance and oversight, are equally 8 important.
9 The plan also includes a significant issues list 10 that specifies individual items. These items are typically 11 identified in inspection reports which the restart 12 assessment panel has determined require documented 13 verification prior to restart of any of the units.
14 Like the plan, we expect this list to evolve as 15 the discovery process continues.
16 CHAIRMAN JACKSON: Is that going to be made 17 publicly available?
18 MR. McKEE:- The significant issues list, the ones 19 we have identified at least for Unit 3, is publicly 20 available in our restart. It's an attachment to our restart !
l 21 assessment plan. i 22 CHAIRMAN JACKSON: That will be true for all of 23 the -- i 24 MR. McKEE: Right, and it will be true for the 25 other two units. l ANN RILEY & ASSOCIATES, LTD. ;
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. . i 84 1 CHAIRMAN JACKSON: Let me make sure I understand.
2 Are all of the significant issues restart issues?
3 MR. McKEE: All of the significant issues require 4
certain resolution, our inspection, the NRC follow-up prior 5' to restart. So they do involve restart issues, yes. Some 6 are like corrective action plans. You won't be able to 7 resolve necessarily every aspect that might be included.
8 MR. MIRAGLIA: It will at least articulate the 1
9 scope of the issue for restart and would could remain for 10 later.
11 CHAIRMAN JACKSON: I guess all I'm really asking 12 is relative to a point of clarity. Since I have confusion, 13 and I think about the public, I think it's very important 1 14 that we're clear if we have what we call a significant i 15 issues list what the overlap of that list is relative to 16 what are the issues that have to be addressed before restart 17 so that there is no confusion.
18 MR. LANNING: Let's clarify it to make sure we all 19 have the same common understanding. The significant issues 20 list are those issues that the staff has identified as the 21 einimum required that the licensee must address and complete 22 to our satisfaction prior to restart.
23 There is an additional list that the licensee has 24 which is much larger than that, which is also a source of 25 confusion. We only have completed this activity for Unit 3 ANN RILEY & ASSOCIATES, LTD.
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a 85 1
.to date, because that's the only list that we have received 2 from the licensee concerning restart. !
l
} 3 CHAIRMAN JACKSON: Let me make sure I understand.
l 4
The licensee has its restart list.
l 5 MR. LANNING: That's correct.
- 6 . CHAIRMAN JACKSON: Is our significant issues list i
7-a subset of that, or it could be but it goes beyond it?
8 MR. LANNING: Our list is a subset of the i j 9 licensee's list.
d 1 10 CHAIRMAN JACKSON: I'm sorry to belabor the point, 11 i
but every issue that is on our significant issues list by 12 definition is on the licensee's restart list?
J 13 MR. LANNING: That's correct.
l 14 CHAIRMAN JACKSON: Commissioner McGaffigan.
15 COMMISSIONER McGAFFIGAN: In the inspection 16 j
report, how quickly does the licensee get to start working
- 17 on coming up with a way to resolve the issues? Do they have ;
l j 18 to wait for us to write the report, or is it orally l
1 19 communicated at the time? How does that work just in
!. 20 general?
21 MR. MIRAGLIA: Wayne.
22 MR. LANNING: The significant issues list is 23 articulated in the restart assessment plan. That has been 24 published; it's available to the licensee to start work on 25 immediately.
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l 1
COMMISSIONER McGAFFIGAN: You also said earlier 2
it's an evolving document; you are going to come up with 3 l additional issues, and as they said, they are going to come ;
4 up in discovery. I think that was the word used. How are i
i 5 additions made?
6 I'm just trying to understand the process so 1 l
7 that's it's a prompt process, that it doesn't wait for an {
8 every three month commission meeting or something in order 9 that they know what they have to fix.
l 10 MR. MIRAGLIA: The issues are identified. In the 11 course of inspections there are usually exits. So the I 12 information in terms of the issue is identified to the 13 icensee at the conclusion of the inspection. 1 14 The licensee will make its evaluation as to is 15 this a restart item or not, share that with the staff, and 16 we either agree or say it needs to go even further.
17 That's the process that is done by the 0350 1 18 restart panel. There are periodic meetings of those. They 19 are done in public meetings. Those lists are shared with 20 the utility on a fairly frequent basis. ,
21 I don't know what your current meeting schedule is 22 right now.
23 MR. LANNING: We're averaging about one a month.
24 As thev have made progress we can have more frequent 25 meetings.
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COMMISSIONER McGAFFIGAN: And it's up to the 2 licensee to propose how to resolve the issue once it's
- 3 identified? Then it's up to the panel to decide whether 4 that resolution is acceptable?
5 MR. LANNING: Absolutely. They have to list each 6
of the issues and provide us a package certifying l 7
essentially that they have completed the actions that they 8 think are necessary for the NRC to close that issue. They 9 provide that to us so that we can inspect it.
10 CHAIRMAN JACKSON: Okay.
11 MR. McKEE: If we can go back to slide four.
i I
12 (Slide.]
13 MR. McKEE: One item listed is the operational 14 safety team inspection. It's an intensive independent 15 evaluation to be performed just prior to the restart of each 16 of the Millstone units. The inspection focuses on 17 licensee's capability to safely operate the facility. It 18 involves eight or more inspectors who will be on site two or 19 three weeks to perform the inspection.
20 I need to point out that prior to December 1996 21 the licensee had been focusing on Unit 3 as the lead plant 22 for restart. For that reason, the NRC restart action plan 23 is directed at Unit 3 activities. Now it appears, I think 24 as was discussed and you hea d today, that the licensee is 25 focusing restart act ~ for all three units on a ANN RILEY & ASSOCIATES, LTD.
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1 parallel path. This revised approach could have 2
considerable resource impacts on the NRC, particularly in 1
3 considering the scope and depth of NRC activities associated '
4 with the restart assessment for each of the facilities.
5 Also, there are many actions and milestones 6 required by the licensee to be completed prior to NRO 7- conducting its review and assessments. I know the licensee 8 spoke to this issue a little bit in their presentation, ;
9 including the many assumptions that they have made in doing 10 their things. I think they reflected that they are not 11 certain on some what NRC may require in certain areas. So 12 there is a little interchange that needs to go on here, 13 l Given the licensee's ambitious schedules and :
1 14 parallel effort for the units, the staff questions the !
15 licensee's capability to meet all the necessary milestones t
16 for providing staff with necessary submittal packages and 17 the information to support NRC activities.
18 It is very.important that the licensee prepare 19 supportable and integrated schedules with clear intermediate 20 milestones for the three units. I heard some of that today, 21 but that needs to be very carefully done so that we can 22 proceed with our work also.
23 This is essential for the staff to plan and muster l 24 necessary resources to evaluate licensee programs. !
25 As an aside, I want to mention last October the ANN RILEY & ASSOCIATES, LTD.
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89 1 staff did request some information, more details on the 2
operational readiness plan and schedules of important 3 milestones for Unit 3. Although we received some 4 information, we really haven't yet even received docketed 5 information on that request. So we are still waiting for 6 certain information for us to proceed.
7 CHAIRMAN JACKSON: Let me take you back for a 8 quick minute. You mentioned that the Manual Chapter 0350 9 process explicitly provides for your interface with other 10 appropriate agencies and organizations, and you mentioned 11 FEMA, DOJ, and state agencies. The question I have relative 12 to the state is, have you in fact articulated what your '
13 interfa,ce is going to be with either state agencies or state 14 organizations or state groups? Have you in fact articulated 15 that?
16 MR. IMBRO: I can answer that, Dr. Jackson. For 17 the ICAVP we have solicited observation of the process by 18 the NEAC, Nuclear Energy Advisory Council, I believe it is, 19 and that organization is constituted by the Connecticut 20 state legislature. We have memorandums of understanding 21 from four of the individuals, the two chair people plus two 22 alternates, and they will be involved in keeping abreast of 23 the ICAVP and our status so they will understand the process 24 and know what is going on. So to that extent the state has 25 been involved with the ICAVP.
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MR. MIRAGLIA: In terms of the public meetings, I 2
believe there has been conversation with Dr. Travers and the 3
state that they would like to be kept informed of briefings.
4 If they need more than~they would get at public meetings, 5
we've even arranged for opportunities to be briefed in that 6 regard as well.
7 MR. LANNING: That's_right. We have committed to 8
brief the state representatives monthly on the status.
9 MR. MIRAGLIA: So there has been contact at a 10 number of levels.
11 MR. McKEE: If I could have the fifth slide.
12 [ Slide.)
13 MR. McKEE: The independent corrective. action 14 verification program has been required for each Millstone 15 unit by order issued in September of 1996.
16 J
The ICAVP is intended to provide independent 17 confirmation that the licensee has identified and addressed 18 design and licensing basis deficiencies. i 19 f The ICAVP will also confirm that the licensee has 20 processes in place that will ensure continued conformance 4
21 with their license basis.
22 The order requires the licensee to contract for an 23 independent organization to carry out the ICAVP.
24 The order specifies that NRC review and approval A
25 is required for several of the elements.
i 1
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91 1
NRC staff will review and approve the independence 2
and technical qualifications of the proposed ICAVP 3 organization.
4 Individual member's independence and their 5 technical qualifications.
6 And the audit plan rhich must be submitted by the 7 ICAVP organization.
8 As part of our review of the ICAVP audit plan, the 9
staff will determine the scope and depth of the ICAVP audit, 10 including which systems are to be evaluated.
11 CHAIRMAN JACKSON: What criteria are you using to 12 ensure an adequate sampling of systems?
13 MR. MIRAGLIA: As described in the Commission 14 paper that was referenced early in your remarks, Chairman 15 Jackson, which will be made public today, the licensee has 16 the primary responsibility to look at all systems within the 17 context of the 0350 process and conduct the problem 18 identification phase, resolve issues, and then institute 19 corrective actions. The ICAVP will also then select a 20 number of systems.
21 In early meetings with the utility in August 22 preceding the order relative to this, we talked in terms of 23 looking at risk-significant systems, those that would be 24 covered by the maintenance rule, and at a point in the 25 process where the utility has completed its problem ANN RILEY & ASSOCIATES, LTD.
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identification and instituted corrective actions propose a 2 number of systems that are ready for ICAVP review. Then, 3 within the context of the process the ICAVP will decide a 4
number of systems to be looked at, and then that plan will 5
be submitted for the staff to review and audit.
6 CHAIRMAN JACKSON: So the number of systems and 7 the basis on which they are to be chosen will come to the 8 NRC for approval?
9 MR. MIRAGLIA: Yes.
10 MR. IMBRO: We will specify the number of systems.
11 I think the next slide really addresses the scope of the 12 ICAVP in terms of the multi-tiered effect not only to review 13 four systems as was stated in the Commission paper, but also 14 the fact that we need to look at the accident analyses to 15 make sure the other systems that get engaged to mitigate 16 accidents function the way they are supposed to, and then 17 also to look at the change processes that have resulted in 18 plant configuration getting to where it is since OL to make 19 sure that those have not introduced any modifications.
20 CHAIRMAN JACKSON: Have you begun your discussion 21 of the ICAVP? You're up next, right?
22 MR. IMBRO: No. Mr. McKee was going to handle the 23 whole presentation. I was trying to respond to your 24 question.
25 [ Slide.]
l
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3 93 i i
. 1 MR. McKEE: On the next slide we are going to talk i
{
2 about conduct.of the ICAVP.
l 3
As I mentioned before, the staff is required to I
j 4 approve it. We have given a lot of consideration to those i
- 5 i elements of what we think should be considered in the ICAVP. l j
6 In general, staff has determined that the ICAVP 7
should include a.three-tier review. u i
I 8
I Tier 1. This is the plan for Unit 1 as we have I l j
i 9 identified in the paper, but likely will apply a similar j 10 process to the other units. The contractor would perform an 11 extensive vertical slice evaluation of design and operation 12 awpects of a-sample of safety-related and risk-significant '
13 systems. I think the original thought was four, as Gene 14 mentioned.
15 In tier 2 other safety-related or risk-significant 16 systems would be evaluated and the focus would be-on 17 critical active functional attributes necessary to mitigate 18 postulated accidents analyzed in the FSAR.
19 In tier 3 design change processes such as those j 20 involving procedural changes, calculation changes, drawing 21 changes, tech spec changes would be sampled.
22 CHAIRMAN JACKSON: So when we are looking at tier 23 1, tier 2 and tier 3, how many systems, at least at this 24 stage of the game, are you talking about looking at?
25 MR. IMBRO: It's a little bit hard to answer. For ANN RILEY & ASSOCIATES, LTD.
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1 94 1 tier 1 it clearly is four systems. The four-system review 2
is a vertical review looking at all design aspects and 3
making sure that the systems conform to the licensing basis i 4
but also that the design requirements flow through to the 5
operating, maintenance, surveillance procedures,. testing, et 6 cetera. So there is a complete top to bottom review of four 7 systems.
8 Tier 2 I wouldn't necessarily look at on a system 1 9 basis but more on an analyzed accident basis. In other 10 words, we are going to start with the Chapter 15 accidents 11 and the FSAR and go through each accident and look at what 12 has been taken credit for in terms of performance of all the
- 13 sy. stems and make sure that those functions can be performed 14 by the systems by going back to look at the design bases for 15 those particular attributes.
16 So the tier 2 is not necessarily a system review 17 but an accident analysis review focusing on the critical 18 attributes of the systems that need to come into play to 19 mitigate the consequences of the accident.
20 And tier 3 is not a system review at all but is a 21 broad review of processes.
22 MR. MIRAGLIA: And it's the results of all of 23 these and the outcomes of these that will say is that 24 enough. You have to put those together and make the 25 judgments that those three processes have provided the ANN RILEY & ASSOCIATES, LTD.
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95 1 information to say and to make the inference that the ICAVP 2 is going to have to say that the licensee has done enough 3 and independently verified corrective action.
4 MR. McKEE: Finally, on that slide, the ICAVP 5 would not begin until the licensee has completed the problem 6 identification phase of the configuration management program 7 for at least one half of the risk-significant systems.
8 If I could have slide seven, please.
9 [ Slide.]
10 MR. McKEE: This provides a little more 11 information on the tier 1 evaluation. We may have covered 12 some'of this already.
13 The tier 1 scope as identified by the staff for 14 Unit 3 includes a multi-discipline vertical slice review for 15 several systems comparable to an integrated design 16 inspection. Licensee review includes approximately 80 17 safety-related or risk-significant systems.
18 Tier 1 will encompass the adequacy of original 19 design for the unmodified portions of the selected systems 20 as well as all the modifications since issuance of the 21 operating license.
22 CHAIRMAN JACKSON: Let me ask you a quer, tion. I 23 just want to make sure I'm clear. Did you say the licensee 24 has identified 80 systems?
25 MR. McKEE: I think 80 represents the full scope ANN RILEY & ASSOCIATES, LTD.
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j 96 1 of all the systems that the licensee is looking at, not ones 2 that necessarily will come under the ICAVP.
3 CHAIRMAN JACKSON: I understood that. I'm asking 4 you a question. You said 80 systems, right, and you said 80 5 risk-significant systems? !
6 MR. MIRAGLIA: It's the 80 systems that would fall 7 under the criteria as they are implementing the maintenance 8 rule.
9 CHAIRMAN JACKSON: The ICAVP at this point will 10 look at four in this tier 1 process?
11 MR. IMBRO: That's correct.
12 MR. MIRAGLIA: And the 80 is applicable just to '
13 Unit 3.
14 CHAIRMAN JACKSON: Is the 80 for one unit or for 15 all three?
16 MR. IMBRO: The 80 is for Unit 3.
17 CHAIRMAN JACKSON: So the four is for Unit 3?
13 MR. IMBRO: Exactly, yes. l 1
19 COMMISSIONER ROGERS: What is the thinking here of 20 your focus on the original design for unmodified systems?
l 21 What are you looking for there?
22 MR. IMBRO: What we are looking for, Commissioner 23 Rogers, is, starting with the reality of the system as 24 installed in the plant, making sure that that is in 25 conformance with its licensing basis. For the unmodified ANN RILEY & ASSOCIATES, LTD.
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portions of the system the supporting documentation is the
, 2 original design. For the parts of the system that have been ,
3 modified, it's the supporting documentation of the 4 modification packages. We want to look at the total design 5
package that supports the system as it exists today to make 6
sure that's in compliance with its licensing and design 7 basis.
8 COMMISSIONER ROGERS: 'The problem I have here is-9 just understanding what sort of things you think you might 10 turn up there. It looks to me as if what you may find or 11 the purpose of this would be to see whether the original 12 design complied with the original FSAR. Is that right?
13 ,
MR. IMBRO: That's right.
14 COMMISSIONER. ROGERS: This would go back to your 15 one then.
I 16 MR. IMBRO: Exactly.
17 MR. MIRAGLIA: The second thing is that given the i 18 modifications -- .
19 COMMISSIONER ROGERS: I understand the 20 modifications. It's the unmodified portions. l 21 MR. IMBRO: There have been examples where 22 original design problems have been uncovered. Therefore we 23 felt like we needed to go back and look at the adequacy of 24 the original design. That is something that is a little bit 25 unusual in terms of how we review things, but we felt for ANN RILEY & ASSOCIATES, LTD.
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98 1 Millstone this was necessary. i 1
2 COMMISSIONER ROGERS: But then this is sort of a L
3 sampling process in a certain sense of the original design 4
conformance with the FSAR for the four systems. That's how 5 you are tuking the sample in a sense. It really doesn't '
6 relate to the modifications; it relates to the original 7 design.and FSAR conformance.
8 CHAIRMAN JACKSON: Let me make sure I understand, !
9 because now I'm confused. My perspective was that there 10 were these four systems that you were picking based on some I 11 set of criteria, . risk significance included.
12 MR. IMBRO: That's right.
13 CHAIRMAN JACKSON: Having picked those, some 14 portions of the systems may have been unmodified since the 15 beginning and some portions may have been modified.
16 MR. IMBRO: That's correct.
17 CHAIRMAN JACKSON: In taking this vertical slice i 18 I you are doing both things. You are not picking the four {
19 systems based on never having been modified or having been 20 modified. You're picking them on some other criteria, and 21 in taking this slice you have to do both of these.
22 MR. IMBRO: That's right. One of our criteria 23 would be also to look at the number of modifications and the 24 complexity of modifications that are made to a particular 25 system.
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- CHAIRMAN JACKSON
- To make sure that we are j 2
, touching base with what his question is and mine, within a 3 given complicated system there are aspects of both.
4 'MR. IMBRO: Exactly.
5 MR. MIRAGLIA: You're picking a system and you're 6 saying did it meet the original design as modified. The 7' answer is yes.
l' 8 CHAIRMAN JACKSON:
4 Commissioner McGaffigan.
9 COMMISSIONER McGAFFIGAN: This is just a language 10 question and perhaps everybody who went through the 11 maintenance rule knows. When you use safety-related or i
12 risk-significant, are they the same, or is risk-significant .
a 13 systems that are not safety-related?
14 MR. MIRAGLIA:
i Within the context of the 15 maintenance rule, it is risk-significant and it would 16 include safety.
17 COMMISSIONbR McGAFFIGAN: So risk-significant 18 includes safety systems?
19 MR. MIRAGLIA: In terms of the maintenance rule, 20 it would be the broader context.
21 MR. IMBRO: Some of the safety-related systems are 22 not really risk-significant. It gets complicated.
23 CHAIRMAN JACKSON: We don't want to go off the 24 map, but.there are at least four operative phrases that come 25 up that I think actually need clarification at some point.
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They are safety-related; we say safety-significant; we say 2
important to safety; and we say risk-significant. And they 3 don't all mean the same thing. Am I correct?
4 MR. IMBRO: That's correct.
5 MR. MIRAGLIA: That's right.
6 CHAIRMAN JACKSON: For the purposes of 7
Commissioner McGaffigan's question, what are you saying?
8 [ Laughter.]
9 COMMISSIONER McGAFFIGAN: They've been very good 10 about using the terms safety-related or risk-significant all 11 through the briefing. So I've been very impressed.
12 MR. IMBRO: From my knowledge of Unit 3, the 13 li.censee has approximately 220 or 230 systems total in the 14 plant. They have divided those into four categories. I 15 will focus on the first two because I'm not sure I know the 16 definitions for the other two. The first two comprises the 17 80 systems that we just discussed or made reference to.
18 The group one systems are risk-significant and 19 safety-related, and I think the total number is something 20 like 39, more or less.
21 The group two systems are safety-related or 22 risk-significant. In that category there are approximately 23 42 systems, I believe. Some of those are safety-related but 24 not risk-significant, and others, one or two systems, are 25 risk-significant but not safety-related. I think the two ANN RILEY & ASSOCIATES, LTD.
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non-safety-related systems that are risk-significant have to 2
do with availability of offsite power kind of things that 3 are not typically safety-related.
4 CHAIRMAN JACKSON: Maybe you could just give a 5 quick definition of safety-related.
6 MR. IMBRO: Safety-related would be those systems 7
that -- I guess as a first cut, those systems that are 8
necessary to mitigate the consequences of an accident or to l 9
prevent accidents such as the primary pressure boundary.
10 CHAIRMAN JACKSON: Just for the record.
l 11 COMMISSIONER McGAFFIGAN: Sorry.
12 CHAIRMAN JACKSON: No. That was a good question.
13 MR. McKEE: To finish on this slide, I was going 14 to mention something about our selection process, but I 15 think we've already covered that. It's based on a number of 16 factors. So let's move to the next slide, please.
17 [ Slide.)
18 MR. McKEE: As far as NRC oversight of the ICAVP, 19 staff will provide oversight of that process by reviewing on 20 a sampling basis the ICAVP processes and findings and 21 conducting separate design-related inspections of a couple 22 systems.
23 CHAIRMAN JACKSON: Those systems are different 24 than the four the ICAVP will cover?
25 MR. IMBRO: No, not totally. One will be within ANN RILEY & ASSOCIATES, LTD.
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102 1 the scope of the ICAVP. So one of the systems that was used 2
to do a vertical slice on ourselves will be within the scope 3 of the ICAVP and would be one of the four systems. The 4 other would be not be within the scope of the ICAVP but one 5- of the remaining of the 80 systems that is done by the 6 licensee but not necessarily addressed by the ICAVP.
7 CHAIRMAN JACKSON: And that's one of the things 8 that we are going to end up using contractors for?
9 MR. IMBRO: Exactly, yes.
10 MR. McKEE: Staff intends to keep the state and 11 public well informed on ongoing activities, including 12 invitation to the state representative to observe NRC 13 inspections. We are going to have multiple meetings with 14 the licensee which will be open to the public. And we're 15 going to have specific meetings with the public on this 16 topic.
17 [ Slide.)
18 MR . McKEE :- Just to give you a quick status of 19 where we are on ICAVP. I 20 In brief, the current status of the program is the 21 staff is reviewing the proposals by the licensee to use 22 Sargent & Lundy at Units 1 and 3. We have requested some 1
23 additional information from the licensee and we plan i
24 separate meetings with the licensee and the public in the l 25 near future. February 5, I think, is when we planned those.
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The meeting with the licensee, which will be open 2
to the public, will be to discuss their proposal and 3 selection process.
4 In our meeting with the public we plan to solicit 5 the public's comments on the contractor selection.
6 CHAIRMAN-JACKSON: Will the comments that you get-7 from the meeting be addressed prior to or as part of the 8 decision-making process?
9 MR. IMBRO: It will be part of the decision-making 10 process.
11 COMMISSIONER McGAFFIGAN: Could I ask one 12 question? '
13 CHAIRMAN JACKSON: Sure.
14 COMMISSIONER McGAFFIGAN: Perhaps Mr.,Kenyon can 15 answer. His chart read the same way, that there was a 16 contractor for Unit 1 and 3, but in his oral presentation he 17 said that they had chosen un ICAVP contractor for 3 and they 18 were soon going to do 1 and 2. I guess I should have asked 19 it at the time. I'm just wondering whether you have chosen 20 the Unit 1 ICAVP contractor and submitted it yet or whether 21 your oral remarks were right and you are still working on 22 that.
23 MR. KENYON: We have chosen but not submitted.
24 COMMISSIONER McGAFFIGAN: Chosen but not submitted 25 the number 17 ANN RILEY & ASSOCIATES, LTD.
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104 1 MR. KENYON: That's right.
2 CHAIRMAN JACKSON: Where does the thing stand for 3 Unit 27 4 MR. KENYON: The same. We have internally chosen 5 both and we will shortly be submitting them.
6 CHAIRMAN JACKSON: So the only one that has been
? submitted is Unit 3 at this stage?
8 MR. KENYON: That's correct.
9 I'm sorry. I'm out of date. Unit 1 has been 10 submitted also.
11 MR. IMBRO: There is a difference in date.
12 Submittal on the Unit 1 was the 15th of January.
13 MR. McKEE: That completes the ICAVP. I want to 14 shift over to employee concerns. If I could have slide 10, ,
15 please.
16 [ Slide.)
17 MR. McKEE: As a result of past failures in the 18 licensee's programs for the handling of safety issues raised .
19 by its employees and NRC concerns about the treatment of 20 employees who brought safety concerns to msnagement's 21 attention, NRC issued an order in October of 1996 requiring i 22 the licensee to take a number of actions. The licensee did 23 discuss some of these and I'll kind of cover those briefly 24 again.
25 The principal actions specified by the order ANN RILEY & ASSOCIATES, LTD.
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1 include licensee submittal for NRC review their own 2
comprehensive plan for reviewing and disposition of safety 3 issues raised by their employees.
4 The order also requires the licensee to propose an 5
independent organization to oversee the comprehensive plan.
6 Once the NRC approves an independent organization, 7
that organization will develop and provide for NRC approval 8 an oversight plan. All these actions are required prior to 9 the restart of any of the Millstone units.
10 Once in place, the independent organization would 11 provide reports at least quarterly to the NRC. These 12 reports would be made available to the public. We are still 13 considering how we might discuss that, and that would be 14 presented quarterly, including participation by the public.
15 CHAIRMAN JACKSON: So at this point you don't 16 necessarily require any progress relative to the plan before 17 restart. You just said that the plan has to be approved 18 prior to restart.
19 MR. McKEE: That's correct. The oversight plan 20 has to be approved. That's the independent group. That 21 plan has to be approved prior to restart. As far as 22 implementation of their comprehensive plan the oversight 23 group will be doing, that's one purpose of that function, 24 and then of course the NRC would be doing, also similar to 25 the ICAVP, some other higher tier level oversight and ANN RILEY & ASSOCIATES, LTD.
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106 l 1 assessment of employee concerns.
2 CRAIRMAN JACKSON: \
I'm just trying to clarify '
3 those. Whereas with ICAVP there are certain things that 4
specifically have to have been done before restart, you are {
5 not putting in any requ'.rement that there are specific 6
things that have to have been done in the employee concerns 7 areas.
8 MR. McKEE: You're correct. The order does not 9 specify. The order specifies that they have to have the 10 oversight plan in and we approve it prior to restart, 11 CHAIRMAN JACKSON: But you have to bring it to us 12 and convince us.
13 MR. McKEE: That's correct, yes.
l 14 MR. LANNING: But as a practical matter, the 15 licensee will have to demonstrate that they've made progress 16 in dealing with employee concerns prior to restart. That is 17 a startup issue.
18 CHAIRMAN JACKSON: That's something you should 19 keep in mind in coming to the Commission. i 20 MR. McKEE: My last point was that the NRC plans 21 to assess the effectiveness of this plan and bring that to 22 the Commission and discuss that with the Commission prior to 23 restart.
24 Next slide, please.
25 (Slide.)
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107 l
1 MR. McKEE: The status of the employee concerns 2
order activities is similar to the status for the ICAVP. Of 3 course we don't have three separate programs. The employee 4 concerns is a station program rather than an individual unit 5 program.
6 The licensee has submitted a proposed 7 organization, Little Harbor Consultants, and we are 1
8 reviewing the qualifications and independence aspects of the 9 organization and individuals. ,
10 Similar to the ICAVP contractor selection process, 1 11 we have requested some additional information from the 12 licensee. A letter just went out today on that.
13 CHAIRMAN JACKSON: Are there any particular issues 14 that are you requesting information about?
15 MR. McKEE: We're requesting some further 16 information on Little Harbor Consultants, some further I 17 information on some of the individuals, assurance of their 18 independence from Millstone, and financial independence from 19 Northeast Utilities.
20 We are also curious about some of the construction 21 of that organization, how the people will be placed at site, 22 what will be their availability and kind of their dedication 23 of time, since it looks like a specially formed organization 24 for this purpose.
25 Again, we are having a meeting with the licensee ANN RILEY & ASSOCIATES, LTD.
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108 1
concurrent with the ICAVP meeting on February 5, and that 2
meeting will be open to the public for them to discuss the i 1
3 issues that we have asked them and the additional questions.
4 Also that evening we are having a meeting with the public to 5
receive-their comments or any input on the proposed 6 organization.
7 CRAIRMAN JACKSON: Let me make sure I understand.
8 This meeting to receive comments on the proposals relative 9
to the ICAVP, is that a meeting that the NRC is holding on 10 February 5?
11 MR. McKEE: On February 5 we actually have two 12 meetings. We have one meeting that the NRC is holding, and
- 13 it's a meeting with the licensee. That meeting will be in 14 the afternoon of the 5th.
15 CHAIRMAN JACKSON: 'Is that going to be open to the 16 public?
17 MR. McKEE: That will be open to the public. That 18 meeting will include discussions of both the ICAVP and the 19 employee concerns.
20 CHAIRMAN JACKSON: Then separately the NRC is 21 having a public meeting on February 5th in the evening?
22 MR. McKEE: Correct. In the evening we are having 23 a meeting with the public off the site. I guess in the 24 Waterford Town Hall. A meeting with the public to discuss 25 both those programs.
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109 1 CHAIRMAN JACKSON: When do you foresee a decision 2 being made relative to the ICAVP and our acceptance?
3 MR. McKEE: If I could have the next slide. ;
4 (Slide.]
5 MR. McKEE: But that won't provide a definitive 6 answer. kctually the next slide we tried to identify some 7 milestones that we expect or anticipate will be accomplished (
8 prior to our next briefing to the Commission.
9 We anticipate after this meeting, if we get 10 additional information that progress will be made and 11 subject to meeting the criteria that we are looking for, 12 approval of the ICAVP organizations as well as the employee -
15 concerns organization.
14 If that's true in the next three months the order, 15 at least in employee concerns, which I know a little bit 16 better, after approval of the organization, they have 30 17 days to submit their oversight plan. If that works out and 18 we select within the next several weeks the employee concern 19 contractor, we should be at a point even three months from 20 now for looking at an approval well in the process of that 21 oversight plan.
22 I think the same is true also for the submittal of 23 the ICAVP plan.
24 MR. IMBRO: For the ICAVP, we hope that within 25 several weeks after we have our meeting on the 5th and we 3 i
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110 1 evaluate-the information as presented and consider the 2
public comments that we receive from the evening meeting, 3 then we would be in a positiod to provide feedback back to 4 the licensee.
5 MR. LANNING: And to help the public provide 6
meaningful feedback, we have provided copies of the 7- correspondence between Northeast Utilities and NRC in the 8
local public document room, which is the Waterford library, 9 such that the public can get copies of that documentation 10 and prepare themselves for the evening meeting.
11 CHAIRMAN JACKSON: Okay.
12 MR. McKEE: We've really covered most of the items 13 that we have on there that I will call the near term, the 14 next three months.
15 The last item. Of course we plan to keep the 16 Commission informed, and we will work our agenda and see 17 what we need to talk about at the next meeting.
18 That concludas my remarks.
19 CHAIRMAN JACKSON: Thank you.
20 MR. THOMPSON: That concludes the staff's 21 presentation. We would be prepared to answer any questions.
22 CHAIRMAN JACKSON: Commissioner Rogers.
23 COMMISSIONER ROGERS: I have no additional 24 questions. I thought it was very excellent.
25 CHAIRMAN JACKSON: Commissioner Dicus.
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l 111 1
i COMMISSIONER DICUS: No, thank you, i
2 CHAIRMAN JACKSON: Commissioner Diaz.
3 COMMISSIONER DIAZ:
, I do have a couple of little
, 4 questions. Again, you're going to have to excuse me, j 5 because they were very simple, but when the discussion on 6 safety-significant and risk came in they got a little more 7 complicated.
- So I had to write something down quickly just i 8 to make sure that my question comes out clearly.
1 9 You go through this entire document. I am certain 10 that in every one of the staff actions safety is behind it.
] 11 Paraphrasing Chairman Jackson when she finished her remarks, 12 we.do not manage utilities; we regulate utilities regarding
- 13 their safety significance. I think that is an important j 14 issue.
i 15 And we know we have this major massive effort on 16 the design basis reconstitution, which I guess constitutes a
} 17 significant portion of the efforts.
18 However, in going through all of these documents, l
a 19 and I'm sure I missed not only this but all the others, I 20 wonder if I could ask the staff.
i j 21 In all of these vertical, horizontal and diagonal 2
22 slices we have taken have you identified an individual, l 23 independent, very safety-significant, risk-significant issue 24 at Millstone which would have had or could have impaired the
- 25 capability of the systems to perform its intended safety i
4 4
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112 1 function?
2 MR. MIRAGLIA: I think what led up to and prior to 3
the 50.54 (f) letters on each of the units there were special 4 inspections. In fact, there was a self-assessment by the 5
licensee relative to concerns that led to technical 6 specification shutdowns because they could not meet the 7 licensing basis.
I believe Unit I was the first unit to be 8 shut down.
9 As a result of those concerns, we had a special 10 inspection team sent to the Millstone station with a focus 11 on Unit 1. Then we looked at Unit 2 and 3 as concerns were 12 identified based upon the licensee's own self-assessment. i 13 And also within the context of Haddam Neck. So we had a I 14 20-plus-person team looking at the safety and operation i 15 within the licensing basis for the facility. And other 16 issues were identified where they couldn't make the 17 appropriate operability call, so it led to the shutdown of 18 the other units.
19 Those reports are on the docket, in the public 20 document room, and form the basis. It was the licensee's 21 own judgment based upon their assessments and our inspection '
22 results that led to the shutdown of those units and the need 23 for a reconfiguration to assure operation.
24 . COMMISSIONER DIAZ: I couldn't agree more with the 25 need for reconstitution of the design basis. Being ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
113 1 simpleminded, that really was not my question. My question 2 was, have we identified an independent issue?
3 MR. MIRAGLIA: I believe we can identify from the 4 findings in the special inspecticn at least two or three 5 significant safety issues at the units that led to the 6 shutdown, and we can provide that and highlight those T' reports for you.
8 COMMISSIONER DIAZ: Would you, please. I will ask 9 the staff to do likewise.
10 MR. THOMPSON: We will be glad to provide that to 11 the Commission.
12 MR. McKEE: We had an enforcement conference with 13 the licensee in December. That enforcement conference 14 included a number of the issues that were identified at the 15 inspection we were talking about plus issues that were 16 identified by the regional inspection program. So what we 17 provide will probably include a lot of that. That included 18 a number of significant issues.
19 COMMISSIONER DIAZ: I have gone to the significant 20 issues list. I don't see many of them that I would call 21 really safety-significant and risk-significant.
22 MR. MIRAGLIA: Mr. Imbro can give one example.
23 MR. IMBRO: One issue that comes to mind, I 24 believe on Unit 2, was the size of the containment sump 25 screen mesh. That was larger than the orifice size for the ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
l 114 1
high pressure injection throttle valves and created a i j
2 potential for blockage of high pressure injection because 3
debris coald pass through the sump screens that was larger 4
than the orifice size. That is one issue that comes off the !
s 5 top of my head. .
1 6 i MR. LANNING: An additional issue is Unit 2 7
concerning the turbine driven auxiliary feedwater pump.
! 8 They.had disabled that pump at certain times contrary to 9
l tech specs, which is a very significant finding by this 10 team.
11 COMMISSIONER DIAZ: I remember that one clearly.
12 But I think it would be important that we identify 13 those significant issues clearly and separate; all of the 14 issues dealing with design basis and with everything else is is something that we need to have up front.
16 MR. MIRAGLIA: It's already documented within the 17 reports. We could highlight those. I think it's those 18 issues that indicated that we had to do an extensive fix. ;
19 CHAIRMAN JACKSON: Why don't you just take what 20 you have and highlight it and provide it to Commissioner 21 Diaz.
22 MR. MIRAGLIA: Yes. We'll do that.
23 CHAIRMAN JACKSON: Are there any further questions 24 or comments?
25 [No response.]
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115 1
1 CHAIRMAN JACKSON: I would like to thank both 1
3 2 Northeast Utilities and the staff for briefing the 3 Commission on the processes being used to address readiness
! I 4 for restart of the Millstone units.
j 5 The Commission recognizes that much effort has l 6 been expended by the licensee and the NRC staff in i.
I 7 determining what the deficiencies are, analyzing them for 8 root cause and categorizing them for safety significance.
9 Clearly, however, there is a lot of work yet to be done.
l 10 To reiterate, from the NRC's perspective the i 11 decision-making process has been formalized by the following i
12 things.
13 First, issuing orders related to an independent 14 corrective action verification program and the establishment
{ 15 of a third-party oversight of the employee concerns program.
16 Secondly, creating the Special Projects Office to 17 oversee all-licensing and inspection activities.
18 Third, updating the NRC's staff guidelines for' 19 restart approval, namely, the Manual Chapter 0350 process, 20 specifically for the Millstone units.
21 Fourth, formalizing Commission involvement by :
1 22 necessitating a vote for final restart approval and in the l 23 interim conducting routine meetings to track progress which l 24 at this point are scheduled on a quarterly basis. l 25 However, the plan is dependent also on the ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
1 116 1 licensee's schedule, and so I encourage the licensee to work 2 closely with the staff in establishing a schedule however 3 draft a schedule that may be and as promptly as possible 4 finalizing a list of restart issues.
5 NRC resource allocations, as we have all spoken 6 to, must be planned accordingly. And although the licensee 7-has indicated the desire to work all three units in 8
parallel, I believe the Commission would greatly benefit by 9 having a draft time line with significant milestones 10 annotated for each of the three units.
11 The commission does not presuppose that any of the 12 plants will restart by a certain date or not restart by a 13 certain date. However, the Commission must be prepared to 14 ensure that adequate resources are employed to ensure 15 adequate review in a timely manner and to ensure that the 16 public health and safety concerns are addressed.
]
17 The Commission looks forward then to more detail, 18 more meat on the skeletons of these plans and these l 19 processes at each subsequent Commission meeting.
20 As an aside, with respect to the regulatory 21 lessons learned from this process, I note that the NRC 22 continues to study improvements to be made in its processes 23 and to have those processes reflect appropriately risk and l
24 safety significance. The Commission is currently scheduled 1
25 to be briefed on Millstone and Maine Yankee's lessons l
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117 l 1 learned on February 19.
2 Unless any of the Commissionerc have any closing 3 comments, we stand adjourned.
4 [Whereupon, at 12:40 p.m., the briefing was )
5 adjourned ]
l 6
7 8
I 9
10 11 12 . I 13 l 14 15 16 17 l
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19 20 21 22 23
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24 25
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. . 1 l
CERTIFICATE l
This is to certify that the attached description of a meeting of the U.S. Nuclear Regulatory Commission entitled:
]
l TITLE OF MEETING: BRIEFING ON MILLSTONE BY NORTHEAST UTILITIES AND NRC - PUBLIC MEETING PLACE OF MEETING: Rockville, Maryland DATE OF MEETING: Thursday, January 30, 1997 ,
was held as herein appears, is a true and accurate record of the meeting, and that this is the original transcript thereof taken stenographically by me, thereafter reduced to typewriting by me or under the direction of the court reporting company l Transcriber: /N/r[Nh
/
(([11/)
I Reporter: Michael Paulus
Northeast Utilities Briefing for the U.S. Nuclear Regulatory Commission NRC Headquarters Rockville, Maryland January 30,1997 Northeast
[V Utilities System
Overview Bruce Kenyon President & Chief Executive Officer Northeast Nuclear Energy Company t
df Northeast '
"# Utilities Systext: MC C mmission
, Meeting 01/30/97 -i
i i
Agenda
- Employee Concerns Dave Goebel
- Licensing and Design Basis Recovery Jay Thayer ,
- Corrective Action Jack McElwain .
- Closing Remarks Bruce Kenyon i
i & Northeast F/ Utilities Systen: NRC Commission ;
, , Meeting 01/30/97
i i Root Causes of Millstone Decline
- Failure to set and maintain high standards
- Failure to establish clear accountabilities
- Failure to develop efficient processes
- Failure to identify true root causes t
l Northeast
! Utilities Systein: "C C ""I88IO"
, Meeting 01/30/97 -
i
e b
e Leadership Solutions
- New Officer Team
- Recovery Teams , .,
- Use of Other Loaned Individuals i
l
$ Northeast !
9/ Utilities System NRC Commission Meeting 01/30/97 t
i 8 i
i
i 1
! Success Objectives
- 1. High standards and clear accountabilities
- 2. Strong nuclear safety philosophy
- 3. Effective self-assessment
- 4. Effective corrective action process
& Northeast i f/ Utilities Systein: NRC commission
, Meeting 01/30/97 -[
_ _. - . - _ _ _ . . _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ . - 4
Success Objectives (continued)
- 5. Licensing and design bases restored ,
with process to ensure they are properly maintained
- 6. An environment that supports the identification & effective resolution of employee concerns
- 7. Commitment to achieve excellence in nuclear operations j A Northeast 9/ Utilities Systein NRC Commission 7 Meeting 01/30/97
l
- Recovery. Plans Flements of Readiness in Fach Phase i
- System
- Organizational
- Operational
- Regulatory
- Communications !
Northeast Utilities Systen- Mc Commission
, Meeting 01/30/97 -
-l
~
Progress
- Established and communicated root CauSOS
- Established new nuclear leadership team
- Reorganized to a " unitized" concept
- Established recovery teams for each unit
- Developed Recovery Plans and schedules for the site
- Raising standards and improving processes
, 8" Northeast
"# Utilities Systen. MC Commission 9 S N
Progress (continues)
- Selected ICAVP contractor for
! Units 1 & 3
- Established new Oversight leadership team
- Selected Employee Concerns Oversight contractor
- Submitted new Employee Concerns Program ,
8' Northeast Y Utilities Systen:
MC Commission Meeting 01/30/97 i . !
1 Progress (continuem i
,
- Implemented improved Corrective Action Program
- Established longer-term leadership team for each unit .
.
- Conducted leadership assessment ;
i g"' Northeast f Utilities System NRC Commission \
Meeting 01/30/97 l
0 A
Employee Concerns .
I Dave Goebel Vice President - Nuclear Oversight i
, Northeast Utilities Systen: NRC Commission i 12 meeting 01/30/97 -
-l t
Program Goal t
An environment that supports the identification & effective resolution of employee concerns.
t i
i i
Northeast ;
Utilities System NRC Commission ;
13 Meeting 01/30/97
A Comprehensive Plan...
- Was Written with Assistance of Employee Volunteers
- Provides for increased Training
- Improves the Effectiveness of ECP through process improvements
- Increases Accountability for Individual
- Behaviors
- Establishes an Employee Concerns l Oversight Panel l Northeast Utilities Systen- MC commission u Meeting 01/30/97 -l
~
l
.[
- Comprehensive Plan Objectives
- Exercise Effective Leadership
- Establish and Maintain High Standards
- Strengthen Leadership, Management &
Interpersonal Skills
- Establish Effective Problem Resolution .
and Performance' Measures l
- Increase Sensitivity to Employee Needs '
8' Northeast f Utilities System Mc Commission
,, Meeting 01/30/97 L
Comprehensive Plan Objectives
! (continued) 1 l
- Freely Admit Mistakes
- Develop Supportive Management
- Styles & Support for Concerned Employees '
i
,
- Develop Effective Communications .
and Teamwork
- Establish Accountability
- Establish an Effective ECP 3
Northeast !
Y Utilities Systein MC commission Meeting 01/30/97
,, -l l
Line Management is Responsible For...
l l
- Establishing an Environment Where Safety Questions are Welcomed.
- Championing 7ero Tolerance for Harassment, Intimidation or~
Discrimination.
! i 8" Northeast i F// Utilities Systext: NRC Commission g Meeting 01/30/97
ECP is the " Safety Net" for the Line
- Assists the Line in Handling Concerns as Facilitator
- Provides an Alternative Path for Concerns
-the trust of some employees remains low 8"' Northeast f/ Utilities Systein: NRC Commission
,, Meeting 01/30/97 -
.j
Third-Party Oversight
- Little Harbor Consultants, Inc. l' nominated by NNECO on 12-23-96
- Independent assessment of '
environment .
- Evaluation of improvement effectiveness j
- Determine need for additional change Northeast Utilities Systen. NRC commission
,, Meeting 01/30/97 i
ECP Case . Resolution
- On 12-1-96, ECP had 44 concerns under investigation, the oldest was up to 4 years old.
, - average closure time was over 200 days.
l
- As of 1-24-97, ECP had 22 concerns
- under investigation, the oldest was was ~ 22 months old.
- average closure time was ~18 days.
- Submission rate to ECP has increased.
8" Northeast Nac commission
! F/ Utilities Systen:
Meeting 01/30/97
, -l
.I i
i 1
Licensing and Design Basis Recovery Jay Thayer -
Recovery Officer - Nuclear Engineering and Support 8'" Northeast
"( Utilities System EC gommission Meeting 01/30/97
i 4
Licensi~ng and Design Bases l Recovery
- Role of Support Recovery Officer Configuration Management Plan (CMP)
- Ongoing Initiatives to Meet the CMP '
- Restart / Long Term improvement Scope A Northeast 9/ Utilities Systein: MC Commission
,, Meeting 01/30/97 -
- Role of Support Recovery Officer
- Manage Common Engineering Programs Develop Overall Licensing Strategy Ensure Appropriate Consistency
. Among the Units Facilitate Communications Between the Units l
dif Northeast V Utilities Systen: NRC Commission n Meeting 01/30/97
Configuration Management Plan (CMP)
- CMP Objective:
... provide reasonable assurance that the future operation of each unit l
wilibe conducted as specifiedin the terms and conditions of the unit's operating license, NRC regulations and the unit's UFSAR."
8"" Northeast f/ Utilities System MC Commission u Meeting 01/30/97 i
-l Configuration Management Plan Identify and resolve design and licensing bases deficiencies Ensure the design and licensing bases documentation are maintained Ensure station activities are consistent with applicable regulations and the ,
design and licensing bases
- Northeast f/ Utilities System MC Commission
,, Meeting 01/30/97
Configuration Management Plan
- High-Level Document .
- Applies to All Three Units i
Implemented By Project instructions (Pis)
- Prioritized by Risk Significance
- Accommodates Differences in the Units
-design and licensing bases
-vintage
-NSSS and A/E i
8'" Northeast Y Utilities System NRC commission 26 O S '
-l l Ongoing Initiatives o to Meet the CMP
!
- FSAR Review and Update
- Review of NRC Commitments Prioritized Document Updating
- Training
- Walkdowns i
1 i
- Northeast "f Utilities Systen: NRC Commission Meeting 01/30/97
,7 4
Restart and Long-Term Improvement Scope Improve Configuration Control Program Prior to ICAVP Improve 10 CFR 50.59 Program Prior to ICAVP
- Meet the 10CFR 50.54(f) letters Prior to i Restart Ensure Continued improvement After Restart 1
Utilities Systein " C C * *I88I " :
,, Meeting 01/30/97 -l
.I
~
Corrective Action Program l Jack McElwain Recovery Officer- Millstone Unit 1 ,
i t
' I Northeast Utilities Systen: NRC Commission 2e Meeting 01/30/97 t
f I
Corrective Action Program
- Revised Corrective Action Process
- accountability
- quality and timely evaluations
- effective issue and commitment i tracking ;
- effective issue trending .
8' Northeast Y Utilities System NRC commission Meeting 01/30/97
Corrective Action Program i
- Upgraded Root Cause Analysis Capability
- Self-Assessment Program
- Worker Observation Program Northeast I Utilities Systen: NRC Commission
,, Meeting 01/30/97 ;
Corrective Action Program
- Comprehensive Training to Ensure Employee Understanding of Program
- Establishment of Strong Line l Management Ownership and Accountability
- Performance Indicators to Status Program Health i
8'" Northeast f/ Utilities Systein: MC commission
,, Meeting 01/30/97 -l
f ACR History 1 200
+
l i t
- i 150
\
/
100 /\ l !
\
l V .s l :
N f 50 %
/ J l 1
l I I I i
9/29 10/27 11/24 12/22 1/19/97 i
j
i I
i
^
Closing Remarks Bruce Kenyon
\
President & Chief Executive Officer
! Northeast Nuclear Energy Company Northeast l Utilities Systen: NRC Commission u Meeting 01/30/97 i
y p* g>R reg%
g o
- i COMMISSION BRIEFING Millstone ;
January 30,1997 i
.i
'i SPECIAL PROJECTS OFFICE (SPO)
COMPOSITION e Director: Assumes Role of Regional Administrator and Associate Director for Projects, NRR e Deputy Directors for inspection, Licensing, and ICAVP Oversight e Resident inspectors and Regional Project. Engineers Included in SPO e Minimal Staff, Additional NRC Resources Matrixed as Needed, Contractors Also to be Used
- 25 FTETotal/21 Management andTechnical
- Matrixed NRC Resources
- Contractor Resources '
I
e.,.
i RECENT PLANT PERFORMANCE e Principal Focus is Assessing the Day-to-Day Shutdown Risk to Ensure Public Health and Safety e Work Controlimprovements i e Licensee's Corrective Action Processes Remain a Significant issue '
- Closeout of Licensee Identified issue's
- LER Commitment Followup
- Commitments in Response to inspection Reports
.:i f
2 !
i
1 4
OVERSIGHT OF READINESS TO RESTART MANUAL CHAPTER 0350 PROCESS (FOR SHUTDOWN PLANTS)
- Common Framework, Tasks, and Criteria e Restart Panel / Restart Assessment Plans
- Commission involvement
- Independent ACRS Review
- Public Participation e Other Agencies and Organizations ,
t e Documented Record of Approval Basis i
3 l
1 2
RESTART ASSESSMENT PLAN
- Independent Corrective Action Verification Program
- Employee Concerns
- Corrective Action Program
- Work Planning and Controls
- Procedure Upgrade Program ,
- Quality Assurance and Oversight
- Significant issues List
- Operational SafetyTeam inspection
- Enforcement l
- Others j 4
.l l
,i t
ICAVP e Intended to independently Confirm That the Licensee .
has identified and Addressed Design Basis Deficiencies.
.e Independent Organization
- NRC Review and Approval Required:
= Organizational Independence and Technical Qualifications
= Individual Members independence and Technical Qualifications j
= Audit Plan 5
1 CONDUCT OF ICAVP e NRC will Approve the ICAVPTeam and Review Plan Prior to implementation e ComprehensiveThreeTier Review will be Conducted by ICAVP Organization Tier 1 - Vertical Slice Review of Systems Tier 2 - Verification of Critical Functional Attributes Relied Upon in UFSAR Accident Analysis Tier 3 - Sample Review of allVarious Design Change Processes e Begin After Licensee Has Completed the Problem -
Identification Phase of the Configuration Management
- Program for Approximately 1/2 the Risk Significant Systems l
~
6 -
I
CONDUCT OF ICAVP (CONTINUED)
TIER 1 SCOPE
- Multi-Discipline Vertical Slice Review Comparable to an integrated Design inspection
- Adequacy of Original Design for the Unmodified Portions of the Selected Systems l
- All Modifications Made to the Selected Systems Since
- initial Licensing e Adequacy of Licensee's Corrective Actions for Design-Related Problems identified by the Licensee and the ICAVP Organization j i
7
i NRC ICAVP OVERSIGHT ~ -
,
- Review on a Sample Basis the Material Reviewed by the ICAVP Organization to Verify Their Findings and Conclusions
- NRC Design-Related Inspections (2 Systems)
- Public Visibility of NRC Oversight Process
- State and Advisory Council Invited to Observe NRC Oversight Team inspection Process
- Multiple NRC/ Licensee Meetings Open to Public
- Multiple Meetings with General Public
- Input to NRC'S Restart Decisionmaking Process
- l
ICAVP STATUS e Licensee Proposals to Use Sargent & Lundy as ICAVP Organization (Unit 3 - December 18; Unit 1 - January 15) .
e Staff Reviewing Proposals for Independence and Technical Qualifications i
e Request for Additional Information (January 13) e Licensee Meeting to Discuss ICAVP Organization (February 5) e Meeting with General Public to Receive Comments on Proposals (February 5) j 9 I
i EMPLOYEE CONCERNS ORDER
- Licensee Submits; NRC Reviews:
- Employee Concern Program Plan
- Licensee Proposes; NRC Approves:
- Independent Organization to Oversee the Plan
- Independent Organization Oversight Plan Requires NRC Approval Prior to implementation i
- Independent Organization Reports at Least Quarterly to NRC !
- NRC Assessment of License ~e's Program Effectiveness Prior to Restart I
10
OVERSIGHT OF .
EMPLOYEE CONCERNS ISSUES STATUS i
- Licensee Proposal (January 23) to Use Little Harbor Consultants, Inc. as 3rd-Party Organization j i'
.* Staff Reviewing Proposal for Independence and Technical Qualifications t e Request for AdditionalInformation
- Licensee Meeting to Discuss 3rd-Party Organization (February 5) l
- Public Meeting to Receive Comments on Proposal (February 5) 11
l NEAR TERM PROPOSED MILESTONE (FEBRUARYTHROUGH APRIL)
(Dependent on Licensee Schedule) 1 .
l
l
- Approve Employee Concerns 3rd-Party Organization ,
- Review Licensee's Comprehensive Plan for Employee Concerns
- Approve Employee Concerns 3rd-Party Oversight Plan e Briefings to General Public: Approximately
! Every 6-8 Weeks '
- Review Recovery Plans and Punchlists
- Unit i ICAVP Projected to Start t
- Quarterly Commission Briefing 12 *
- i ddMILLST@NE STAT @N AH S UCCESS. OBJEC TI VES i
HIGH STANDARD 4 & CLEAR ACCOUNTABILITIES *
+ incorporate many best proctices from other utilitoes 1 + Regularly benchmark with other nuclear utohtees .
4 Indscotors show strong improvement toward excellence
+ Commitmenu are met STRONG NUCLEAR SAFETY PHILOSOPHY -
+ careful adherence to h,ch nuclear safety steadoals
+ Conservatove decision makmg I
- EFFECTIVE SELF-ASSESSMENT I
<- Sign #ficant issues are identified by NU rather than the ' #
regulator .
i 4
EFFECTIVE CORRECTIVE ACTION PROCESS _
4 .
Corrective actoons & commitments are pnorstned & respived in o
+ timely manner
+ Improved regulatory performance as' demonstrated by decreases ,
m NRC violations.ond LERs
- ~
RESTORED LICEI4 SING & DESIGN BASES -
I WITH PROCESSES TO ENSURE THAT THEY ARE PROPERLY ,
MAINTAINED 5, + ICAVP contractor confirms that the hcensing d design bases -
hays been restored -
=
s + implemented effective configurotron control processes A
l AN ENVIRONMENT THAT SUPPORTS THE I -
IDENTIFICATION & EFFECTIVE RESOE,j,pTION .
l "
OF EMih.OYEE CONCERNS l + 'Open & condid communecetions l ? % + Timely resolution of employee safety cotecerry l + Independergprevsew of employee safety concerns confirms effectiveneW ,.
I r
' COMMITMENT TO ACHIEVE EXCELLENCE IN l
- NUCLEAR OPERATIONS - '
l N
+ Excellence has been defined, e plan to echieve has been j
developed ondithere es good denyonstrated progwss .
+ lssues 6mportcht to startup Aove*been resolved *
' + Resource commitments meet or exceed those of similar ,
well run untts .
l ss
%ucicar imesy '
N y .- -
!~ - _ _ . . - . . - _ - . _ _ . - - - - _ _ - .
.e deM LLST o NE STATI o N l
AM s UCCESSL OBJECTIVES l HIGH STANDARDS & CLEAR l ACCOUNTABILITIES ,
+ Incorporate many best practices from .other utiletses
+ Regularly benchmark wrth other nuclear utshtres '
+ Indicators show strong improvement toword excellence I <- Comm<tments are met STRONG NUCLEAR SAFETY PHILOSOPHY
+ Cortful adherence to high nuclear safety stonderds
+ Conservateve decesion making
\ EFFECTIVE SELF-ASSESSMENT
^
i
+ 5egneficant assues are identified by NU rother'than the regulator e
. EFFECTIVE CORRECTIVE ACTION PROCESS 4o + Correctrve actoons & commrtments are proorutsied & resolved in a tomely manne'r
. + improved regulatory perf m NRC vsolatoons and i ERs onc e os demonstrated by decreases RESTORED LICENSING & DESIGN BASES WITH PROCE55ES TO ENSURE THAT THEY ARE PROPE'RLY . A MAINTAINED 5 '
+ IC AVP contractor confirms that the hcensing & design bases have been restored -
+ imp {emented effective configurotson control processes i AN ENVIRONMENT THAT SUPPORTS THE IDENTIFICATION & EFFECTIVE RESOLUTION .
i OF EMPLOYEE CONCERNS ,
+ Open & conded communotatoons -
+ Tomely resolution of employee safety concerns
+ Independent review of employee safety concerns confirms effectsveness
~_ .
j COMMITMEN'T TO ACHIEVE EXCELLENCE IN
] -
NUCLEAR OPERATIONS i \
+ E xcellence has been defoned. o plan t,p ochieve has been
{ , developed and there es good demonstreted progress
+ lssues umporjont to startup have been resolved
+ Resource commstments meet or exceed thosg of similar well run unets *
~,,
%,+.w
%wlear imeeg, o '
e s g -
i-
TRANSMITTAL T0: Document Control Desk, 05C-12 ADVANCED COPY T0: Public Document Room, L Street DATE: d N/M FROM: SECY, Operations Branch Attached is a copy of a public Commission meeting transcript and related meeting document (s). They are being forwarded for entry on the Daily Accession List and placement in the Public Document Room. No other distribution is requested or required.
-b)'l0inR, On /!)lllStme EV ,Abr*W
~
Meeting'T1 tie:
Urilmks anO Alte -flJHc. Aeeb s Meeting Date: //30/99 Item
Description:
- 1. TRANSCjllP,T t Al/l/lekAl'dDn3 u i flASIhaQ b /
h A O n lvs-
- 2. M,4 ~ 99 -cc 3 -
& /
l 3.
I 4.
5.
l 1
l 6.
l i
- PDR is advanced one copy of each document, two of each SECY paper.
- Origina7 transcript with attachments is filed in Correspondence & Records i Branch.
1 050016 j