ML20136B447
ML20136B447 | |
Person / Time | |
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Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
Issue date: | 02/25/1997 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | |
Shared Package | |
ML20136B446 | List: |
References | |
50-213-96-12-MM, NUDOCS 9703100283 | |
Download: ML20136B447 (283) | |
See also: IR 05000213/1996012
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U.S. NUCLEAR REGULATORY COMMISSION REGION I l ,
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Docket No.: 50-213
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License No.: DPR-61 l Report No.: Management Meeting l (Reference NRC Inspection Report No. 50-213/96 12) Licensee: Connecticut Yankee Atomic Power Company i P. O. Box 270 ; Hartford, CT 06141-0270 l Facility: Haddam Neck Station I
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I Location: King of Prussia, Pennsylvania l : ' Date: February 5,1997 Prepared by: R. L. Nimitz, Senior Radiation Specialist { , Approved by: John R. White, Chief, Radiation Safety Branch ] Division of Reactor Safety l Discussion: A management meeting was held at the NRC Region I office, King of Prust,ia, ) Pennsylvania on February 5,1997. The purpose of the meeting was to discuss the findings detailed in NRC Inspection Report No. 50-213/96-12 which described several , ' deficiencies involving the implementation of the radiation protection program relative to an event on November 2,1996. The event involved the potential exposure of two radiation workers in excess of regulatory limits during a work activity in the reactor cavity and fuel j transfer canal. During the meeting, the licei'see presented information and their assessment of the event, including causes ai d corrective measures to prevent recurrence ; ' and strengthen the radiation protection program. The meeting was open for public
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, i 9703100283 970225 i PDR ADOCK 05000213 i G PDR j ___ _ ._
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Report Details j I l
j 1.0 Attendees
Licensu ) I Ted Feigenbaum, Chief Nuclear Officer ! Jere LaPlatney, Unit Director
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Gary Bouchard, Work Services Director John Hasettine, Engineering Director Joel Goergen, Health Physics Manager
g Jeffrey Warnock, Quality Assurance Manager
Thomas Cleary, Senior Licensing Engineer Terry Harpster, Nuclear Licensing
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NRC r
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William F. Kane, Deputy Regional Administrator James T. Wiggins, Director Division of Reactor Safety (DRS) ! John F. Rogge, Chief, Reactor Projects Branch 8, Division of Reactor Projects (DRP) l John R. White, Chief, Radiation Safety Branch (RSB), DRS ! Robert J. Bores, Technical Assistant, DRS William J. Raymond, Senior Resident inspector, DRP
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' Ronald L. Nimitz, Senior Radiation Specialist, RSB, DRS Morton Fairtile, Haddam Neck Project Manager - Decommissioning
i 2.0 Purpose
. The purpose of the meeting was to discuss the findings detailed in NRC Inspection Report No. 50-213/96-12 which described several deficiencies involving the implementation of the radiation protection program relative to an event on l November 2,1996. The event involved the potential exposure of two radiation j workers in excess of regulatory limits during a work activity in the reactor cavity l
i and fuel transfer canal. During the meeting, the licensee presented information and l ! their assessment of the event, including causes and corrective measures to prevent '
recurrence and strengthen the radiation protection program. The meeting was open i for public observation. l
1 1 ! 3.0 Meetir o; Discussions and Presentations j
I Attachment 1 to this meeting report provides the NRC managernent meeting '
l transcript. The transcript provided is as received from the transcriber and has not
been corrected by the NRC. The transcript provides details of the discussions , between NRC staff and licensee representatives. Attachment 2 is a copies of the overhead slides and other materials that were provided by the licensee to support ' the discussion. i l
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. - . ~ ._. -.. - - - . - _ _ - - . . .. .- . ATTACHMENT 1
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 1 _ __
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In Re: CONNECTICUT YANKEE ATOMIC POWER COMPANY, Licensee
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Management Meeting taken by Cynthia j l First, Registered Professional Reporter and Notary
i Public, at the offices of the United States Nuclear
Regulatory Commission, 475 Allendale Road, King of Prussia, Pennsylvania, on Wednesday, February 5, 1997, commencing at 10:00 a.m. _ __ C~Y
_ _._ . i ! ! ! ~1 2 NRC: Welcome to NRC Region l; 3 1. I am John White, Chief of the Radiation Safety l i 4 Branch, Division of Reactor Safety. In support of ; 5 NRC's regulatory objectives, the Agency frequently 6 meets with licensee organizations to discuss 7 various regulatory topics and issues. Such 8 meetings are generally referred to as management , ! 9 meetings when they are at the request of the ! i
10 Licendee to present information relative to i 11 licensed activities, or requested by the'NRC to
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12 better understand technical issues, gain insights 13 into Licensee performance as a result of the 14' events or as revealed through NRC inspection 15 activities, or to otherwise discuss significant 16 observations and findings. 17 A management meeting is 18 distinctly different from a pre-decisional ) 19 enforcement conference, which the NRC may hold for 20 the purpose of gaining direct insight and j
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21 understanding of Licensee performance p;oblems,
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22 root causes, and corrective actions in order to 23 arrive at a proper enforcement decision. 24 Today's meeting is a 25 NRC-requested management meeting with the
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3 2 Licensee, Northeast Utilities / Connecticut Yankee 3 Atomic Power Company, for the purpose of 1 4 discussing the significant performance issues that 5 were apparent from our inspection of an event on ! 6 November 2nd, 1996, when two radiation workers 7 performed activities in the reactor refueling 8 cavity and fuel transfer canal that led to 9 substantial potential for exposure in excess of l 10 regulatory limits. This event prompted the 11 performance of a special inspection of the Haddam 1 12 Neck Plant during the period between November 2nd
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l l 13 and 27th, 1996. The inspection revealed 14 significant performance deficiencies involving the 15 implementation of the radiation protection program , 16 as applied to the specific work conducted in the 17 refueling cavity and fuel transfer canal. The 18 inspection also identified that response to the 19 radiological event, which effectively suspended 20 refueling progress for about 15 hours, resulted in 21 maintaining the facility in a state of acceptable 22 but higher relative risk, without that condition 23 being effectively recognized, managed or 24 controlled. 25 The findings of the
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2 inspection were previously reported in NRC 3 inspection report number 50-213/96-12, dated 4 December 19th, 1996. On December 5th, 1996, the l l 5 Licensee informed the NRC of its decision to ' 6 permanently cease power operations at the Haddam 7 Neck Plant and initiate plans for decommissioning 8 of the facility in accordance with 10 CFR 50.82. 9 Accordingly, our letter of December 19th, 1996, i 10 referred to our plan to meet with the Licensee in 11 early February to discuss corrective actions for
/~ 12 this particular radiological event, and staffing b) 13 and activities relative to future decommissioning
14 of the Haddam Neck facility. However, for 15 clarification, today's meeting is not intended as i 16 NRC's planned public meeting to discuss facility 17 decommissioning or any aspects of facility 18 dismantlement or decontamination. Such public 19 meeting will be held later, after the Licensee 20 submits its post shutdown decommissioning 21 activities report as required by 10 CFR 50.82. ' 22 Rather, the NRC's interest and concern in today's 23 meeting is directed toward the Licensee's ability
O (_/ 24 to effectively implement and maintain a radiation
25 protection program to support the radiological
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' 5 1 2 control of day-to-day activities involving 3 maintenance, surveillance, equipment operation, 4 and other endeavors that still need to be carried 5 out in the current shutdown condition to assure 6 that the facility is safely maintained, and that 7 essential maintenance and surveillance is safely 8 conducted with properly applied radiological 9 controls. Further, the successful implementation 10 of the radiation protection program will also be : 11 essential, as we've recognized, to support the (^ 12 Licensee's eventual decommissioning of the site. V} 13 Accordingly, the NRC is 14 interested in the Licensee's efforts to understand 15 the root causes of the specific performance 16 failures that occurred on November 2nd, and 17 establish corrective measures, taken or planned, l 18 and effect resolut.on. Within the context of this 19 discussion, we are most interested in the 20 Licensee's assessment and resolution of the human 21 performance and management oversight and control 22 deficiencies that were apparent in this event; 23 corrective measures taken to effect improvement in 24 dose assessment performance (including sensitivity 25 to radiological conditions and occurrences that
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h 1 l 2 have the potential to require prompt and effective
j 3 implementation of dose assessment follow-up ; F
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l 4 activities); actions taken to improve the ; l .
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I 5 identification, assessment, and communication of ! i ' i
- 6 radiological hazards and conditions to workers,
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7 including appropriate instructions and precc.utions
1 j 8 to prevent unplanned exposure; actions to to J I 9 detect and react appropriately to changes in , J
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. radiologic conditions that occur as a result of
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11 work activities; and the determination and
- 12 implementation of effective radiological controls
i i .13 (such as appropriate perscnnel monitoring L ! 14 equipment, work practices, radiological surveys, ! <
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j 15 and procedures) necessary to assure the j ! : ! 16 radiological health and safety of worke~rs.
17 In accordance with NRC 3
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18 policy, the meeting today is open for public
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19 We welcome members of the public and
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observation. j
- [ 20 media representatives to observe this proceeding. 1 . 21 Notwithstanding, the forum.today is a_ meeting only :
j- 22 between the NRC and the Licensee. Accordingly, we l
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, 23 will not be accommodating public participation () 24 during this proceeding, including questions or 25 comments from the public or media. However, after
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' l 2 the meeting in concluded, NRC representatives will , i 3 be available to answer questions or provide . 4 explanation of the NRC's process in this matter. 5 We appreciate your cooperation in this matter. i 6 Today's meeting will be 7 recorded by transcription. Our transcriber is ! 8 Cynthia First. The. transcription of the meeting l 9 .will be made available in NRC's public document 4 l 10 room, and copies may be acquired in accordance l ! 11 with the agency's policy regarding Freedom of 12 Information. ! 13 At this time I'd like to 14 take an opportunity, if you would, please, to 15 introduce ourselves across the table. 16 LICENSEE: Jeffrey Warnock. 17 I'm the Connecticut Yankee Quality Assurance 18 Manager. 19 LICENSEE: Joel Goergen. 20 I'm the CY Health Physics Manager. 21 LICENSEE: John Haseltine. 22 I'm the Engineering Director. 23 LICENSEE: Jere LaPlatney, 24 I'm the Unit Director, Connecticut Yankee. 25 LICENSEE: Ted Feigenbaum,
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2 and I'm the Executive Vice President and Chief l \ \ 3 Nuclear Officer, Connecticut Yankee. i l
- 4 LICENSEE
- Gary Bouchard,
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5 Work Services Director. '
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6 LICENSEE: Tom Clary,
a j' 7 Nuclear Licensing. ) 8 NRC: I'll start off for i i f 9 NRC. My name is Bill Raymond, Senior Resident ) 10 Inspector for Haddam Neck.
11 NRC: I'm John Rogge, the 12 Branch Chief Supervisor.
l 13 NRC: Ronald Nimitz, Senior ! l 14 Radiation Specialist.
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u j 15 NRC: Bill Kan, Deputy
- 16 Regional Administrator.
17 NRC: Jim Wiggins. I'm the 18 Director of the Division of Reactor Safety of the i 19 region. , l 20 NRC: I'm Morton Fairtile, I 21 NRC Project Manager for the Haddam Neck plant. 1 22 NRC: John White, Chief 23 Radiation Safety Branch, NRC. O* l' 24 NRC: I'm Bob Bores. I'm ! 25' Senior Project Manager, Division of Radiation l __ -. . _ _ - _ . _
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' 2 Safety. ! 3 NRC: Any comments, l 4 gentlemen? l 5 NRC: John, just a. point of 6 order. The purpose of the transcription is the 7. record the details of the meeting. As John said, 8 they're going to be publicly available. 9 Certainly, as with any information at a meeting 10 such as this, the transcription is also important 11. to us, so spend time focusing on what you're 12 saying and interacting instead of having to worry 13- about the notes. So I think in that context it's 14 not so important who specifically brings a point' 15 up or responds in terms of who the individual is; 16 rather,. if we -would just characterize it as . the 17 Licensee or the NRC. That would cut out a lot of 18 problems. 19 -- - 20 (Discussion off the record.) 21 --- 22 NRC: John read from a j l 23 prepared introductory remark. I'll lay that out 24 and make sure we've covered all the bases. I'll 25 ask the transcriber to include that in the record. I
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\_s 1 10' ' ; ; 2 Bill. ! 3 NRC: Well, the main thing
j 4- is to go through it to make sure we understand
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l S. what you're telling us. And in that vein, we've l
; 6 got.a lot of material to cover here, and we would i '
L l 7 like to have you move through it. If we see that :
! 8 we can't help'ourselves in terms of asking j; 9 questions, we will try to limit those to just j
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10 clarification of what you're talking about. And ! i , 11 if you've missed.anything, we will try to capture -12 it there. So, in particular, if you're going to
L 13 cover an issue or question that comes up later, . [ 14 please tell us that, and we'll move along. ! , 1
15 So with that, I'll turn it i 16 over to Mr. Feigenbaum for your opening remarks. , 17 LICENSEE: Thank you, ! !
l 18 Mr. Kan. Good morning. We do appreciate this * 1 !
19- opportunity to the update the staff on our , 20 corrective action activities related to the 21 radiological event, but also to update you on the i
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22 issues related to the Enforcement Conference that ! !
L 23 we held in December.
24 As you know, as a result of
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1 25 significant operational events that occurred ! ' .- , _ - - - . - , . , .- . -
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2 towards the end of last year, in addition to 3 reviews that we did in the Licensing / Design Basis 4 area, self-assessments that we did, as well as the 5 external reviews that the NRC did and provided to 6 us, we did identify a number of shortcomings in 7 our operational standards, in our management 8 oversight of the facility, I would say in 9 teamwork, as well, the configuration management e 10 programs, as well as overall programatic controls. 11 These deficiencies are
(~T 12 significant. It's taken us some time to fully O
13 recognize the extent of the seriousness of the 14 issues, but I'm convinced that we've begun the 15 process of internalizing the seriousness of them, 16 accepted the responsibility for fixing them, and , 17 have made the commitment to go ahead and address ' 18 these problems comprehensively and to ensure that 19 the resources are there to rectify the problems 20 effectively. And corrective action is well under 21 way at this point, and today we want to relay the 22 progress that we've made to date. 23 In addition, as Mr. White 24 indicated, late last year we did receive 25 disappointing news that the Haddam Neck facility
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2 did not pass certain economic tasks. As a result, ! l
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3 the Board of Directors took action to vote to - 4 permanently cease operation of the facility. This
- ; i 5 is a significant development resulting in ; i j 6 significant transitions for us organizationally, - "
. - 7 operationally, as well as, I would have to say, ; !
{ 8 emotionally, as well. i
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( 9 Since this decision, though, 1
10 I am very encouraged by my team's ability, the 11 people'here and the people who work for them, to
- 12 begin to effect a smooth transition to a long-term
13 defueled status, dealing effectively thus far with 14 the people issues and the dislocations that 15 inevitablely occur when you shut down a plant such 16 as Connecticut Yankee. But they are doing so and 17 effecting this transition, I believe, without I 18 wavering in our steadfast commitment and giving a 19 high priority to fixing the known and existing 20 problems that we're going to be discussing today: 1 21- The organizational issues, the programatic issues, i 22 the management oversight problems, such that we 23 have established the clear mission and goal and 24 standard; that before any significant ; 25 decommissioning activities are initiated, that we I 1
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2 must demonstrate a corrective action in these l 3 areas outlined from the operational events of the 4 licensing basis reviews, we must indicate that we 5 have taken effective action and be able to 6 demonstrate that we have actually achieved 7 corrective action in those areas. 8 This year, 1997, we are , 9 using to plan and improve. We are restaffing. We 10 are establishing high standards and ensuring that 11 the staff, in our defueled state, with people that
(~) 12 also maintain high standards and that have the U
13 high standards that we need to have to go forward 14 with decommissioning activities. We're looking 15 for people with the right attitudes and 16 commitment, and a special expertise and experience ' 17 that's going to be necessary in the next phase of 18 Connecticut Yankee's existence. We're improving 19 the processes that we use to do business and our 1 20 controls, which we'll talk about today; and, l l 21 again, we're planning extensively in 1997 for ' 22 future activities. ; 1 23 The team here, in this 24 handout, will go through the improvements and the 25 issues that we're dealing with in detail. But, l
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(9 1 14 \_) 2 briefly, I just want to discuss and touch on a few 3 of the things that I'm personally doing in the 4 management oversight area. First of all, with the 5 recent reorganizations at Northeast Utilities, 6 with the naming of the dedicated Millstone Chief
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7 Nuclear Officer, I am able to focus and dedicate 8 much more time to Connecticut Yankee activities 9 personally. And specifically in corrective action 10 areas, corrective action of these deficiencies
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11 we're talking about today, establishment and /~
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12 review of KPI's, and planning for decommissioning. 13 So I am more engaged now in doing these activities 14 than I have been in the past. 15 NRC: What's KPI?
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16 LICENSEE: Key Performance 17 Indicators. 18 NRC: I'm sorry. 19 LICENSEE: Additionally, 20 last fall, I added two directors to the
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21 Connecticut Yankee staff to assist and support the
! l 22 Unit Director, Jere LaPlatney. John Haseltine is
23 our Engineering Director and has, fortunately, 24 experience at Yankee Rowe in terms of the initial
. 25 phases of decommissioning. I think that's going !
15 1 2 to be very. helpful to support the Unit Director. 3 Gary Bouchard is also 4 dedicated full-time. Gary was previously Unit 5 Director of Connecticut Yankee and Services 6 Director and knows the plant back and forth in 7 great deal. So I think that experience, 8 historical experience, will be very helpful as we 9 plan for the years ahead and the future 10 challenges. 11 Also, I've established, or -('y 12 am in the. process of establishing, I should say, a V 13- separate Off-Site Review Board. Right now the 14 Connecticut Yankee Off-Site Review Board is 15 attached and included as part of the Millstone 16 Nuclear Safety Assessment Board. And we're going 17' to separate that out and include on this board 18 special expertise in radiological areas 19 definitely, environmental areas, and definitely 20 seed it with decommissioning experience, as well. 21 So that is underway and we should be forming that 22 very shortly. 23 In the Oversight area, I
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24 have requested and received a dedicated, 25 experienced r. tanager in the form of Jeff Warnock at
. _ _ . _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ . _ , . _ _ _ _ . _ . _ _ . _ . _ _ _ . _ . _ _ l l O 1 . 16 ! I l 2 the end of'the. table, who I know from my l 3 involvement in Seabrook. Jeff-came from Seabrook. i 4 He's experienced and and he's on-site on a daily l 5 basis. He has brought in also experience from ! ; 6 outside Connecticut Yankee, some industry ; 7 experience with heavy emphasis on radiologic 8 controls, which is going to be a very crucial area ' ) 9 going forward and certainly is the point of our ! . 10 discussion today largely. . l 11 Also, I am ensuring that we ! ,
- 12 have adequate resources, working with the Board of
13 Directors of Connecticut Yankee Atomic Power l 14 Company to make sure we have the necessary l 15 resources to do the job right, to make sure that l 16 going forward with decommissioning we have the l : 17 necessary resources to do the work right. : 18 So these actions and the ' t 19 numerous other improvements we're going to be l 20 talking about today, I think, should set us on the 1 *
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21 right course and result in meaningful and ;
, 22 observable improvement in our actions and in-our !
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i 23 processes. And when fully established and fully l !() 24 ingrained, I believe that we can ensure the
25 compliance with regulations that we are all ; <
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2 striving for and give confidence to us, i
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i- 3 . Connecticut Yankee personnel, and to the NRC that !
i w'e can safely' proceed with decommissioning down
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5 the road. Decommissioning provides unique and : ' 1 ;. 6 important challenges. They are different from 1 - 7 Operations, but they are important and serious i
- 8' nonetheless; and there are serious safety issues i
i 9 involved with decommissioning of a plant like 4
10 Connecticut Yankee.
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11 So with that introduction, I
{ . i 12 would like to move along and turn the presentation
13 and agenda over to Jere, Unit Director, who'is 1
i 14 going to walk through some of the specifics.
- 15 LICENSEE: Thank you, Ted.
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16 I am the Unit Director at Connecticut Yankee, Jere 17 LaPlatney. My presentation is going to be an !
1 18 overview of the performance issues and will not j 19 just talk about the events of the refueling canal ,
20 of November 2nd. As we have previously noted to !
j. 21 the NRC, we consider this to be another indicator i- ! 22 of deeper underlying problems, and that's the !
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j_ 23 perspective my presentation will touch on. After -
(~ [ (_) 24 I'm completed, Gary and John will present specific l
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25 details in certain events, but I'm looking at the
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'2 broader issues.
}- 3 So the history here is that
. -4 recent events-in the latter half of '96 do not 5 uncover underlying weaknesses in Connecticut !
' . 6 Yankee. The nitrogen events and the recovery, the l 7 poor recovery from that-event, the so-called i
8 Virigilio' inspection, which identified our Design 9 Basis issues, and the refueling canal event were 10 the most notable, but there were multiple other 11 smaller indicators that there were underlying (} 12 13 problems at Connecticut Yankee that have probably existed for quite a while in some cases, and in -1 14 other. cases may have been exacerbated by recent l 15 developments. 16 This presentation is not 17 laying out our plans. We already have our plans. 18 They're in place, and we'll show them to you; but 19 this is really an update of where we are today. 12 0 So this is not -- I don't want to just give the ; i 21 impression of laying out a new plan for 22 Connecticut. This is where we've been heading the i 23 last two months. But we are going to give you the
'O 24 overall schedule. I'll cover all the initiatives
! ' : 25 in summary form, like I said, but the other l
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2 presenters will give more detail specifically in : 3 the areas you requested relative to the radiologic 4 event.
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5 The underlying -- the major ' 6 underlying performance issues at Connecticut , 7 Yankee are the four bullets I've given here. > 8 We've found fundamental problems in Management 1 9 Standards. And Management Standards, by the , 10 simplest definition: What will management
11 tolerate, and is it acceptable. And we found,
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' (N \,,) 12 unfortunately, when we looked in the mirror time
, 13 and again that what we were willing to tolerate ! 14 was not acceptable, and that showed in many .
15 examples.
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16 The Corrective Action
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17 Program has degraded Connecticut Yankee, and I'll
l '18 give some background on that. That's a
19 cornerstone of any nuclear operations and it has 20 to be fixed.
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21 The Licensing / Design Basis , , 22 for Connecticut Yankee was found to be 4 23 inadequately documented, and we'll talk about : , N 24 that.
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25 And finally, Management
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20 l l l 2 tolerated these conditions. We accepted them. We j i 3 should not have. And we're here to tell you-how l 4 we're changing that. ! 5 Examples from the various l I 6 events that I've just quoted point to the issue of i ! F 7 Management Standards. I don't think I need to 8 build a big case, but clear indications of the l ! 9 kind of operations was not formal enough at 10 Connecticut Yankee. There were different 11 standards for a hundred percent power and the kind : 12 of surveillance, for instance, which was very , 13 formal, versus the shutdown operations where { ; 14 things were a lot more flexible and the procedures ! 1 15 were not detailed enough. l 16 So that leads right into the 17 next bullet. Procedure use was too flexible. We 18 had rules of use. People generally applied them, 19 but the standard was not high. Conduct of work 20 was not formal enough in the nitrogen event. We 21 had indications of that. And certainly in the 22 refueling canal event, the fact that the work was 23 being conducted on that shift, in this case on a 24 weekend, it was clear there was two different 25 standards for how work was conducted. Issues were -_ __ - - _ - . __ _ ___ , _ _ _.i
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i' O 1 21 l 2 not elevated to management-in a timely fashion. i ! 3 That should be a management expectari.on. It was '
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l 4 not clearly ingrained. !
5 Continuing with the second i 6 major areas of the Corrective Action Program, we l . > . , 7 put in the combined program with Millstone in ; I 8' 1995, this so-called ACR program. We've !
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i 9 significantly lowered the threshhold, which is a j I
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10 positive. We went from an average of about 300
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l - 11 PIR, the old system, to 1400, I think, in 1996, l i
- 12 ACRs, and roughly the same rate _in '95. The i
13 problem is that we did not change and manage'that 14 system well and the system became overwhelmed. We l i
L j 15 started developing a_very large backlog of
16 corrective actions. . ;
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17 The quality of analyses and j !
l 18 corrective actions specified by the people who did l 19 the evaluations of each issue were inconsistent. I
I 20 We had some~ people who did a very good job; we had 21 others who did not do as good a job. 22 And, finally, trending was i
i 1 ! 23 implemented. I got trend reports in October and
( 24 November of 1995. And then basically, due to the 25 backlog and the overwhelming workload, we could l
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h 1 22 2 not keep up with it and we lost the trending. So 3 the Corrective Action Program had significant 4 deficiencies. We'll be talking about short-term 5 actions and a long-term plan for that, as well. 6 The third area is Licensing 7 and Design Basis. Both sides of this table know 8 that the Connecticut Yankee's Licensing and Design 9 Basis is not adequately documented. That is a 10 fundamental issue that John will be covering in 11 great deal in his presentation. So the highlights 12 of that is the FSAR was not rigorously maintained; 13 design calculations lacked rigor; small safety 14 margins for this plant were not respected as they 15 should have been; and the 50.59 process has never 16 been used in Connecticut Yankee as frequently as 17 the industry standard. 18 The final slide is -- and I 19 guess I consider the most significant -- it is a 20 reflection on the management team. We tolerate 21 these conditions. There was some nistory, I 22 think, that's an unacceptable excuse, 50.59 23 evaluation being an example, where we historically
(G_) 24 had never done that. But that's no excuse for not
25 keeping up with the industry. And it's
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2 management's job to set standards. And the way
[ .3 you set standards is what you will. accept from i
4' your people. We'll talk about that coming.up.
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5. NRC: How did you come to --
- 6' this is Bill Raymond. How did you come to a
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- 7 conclusion relative to that? How did you
i 8 benchmark yourself?
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l 9 LICENSEE: The 50.59, I i ! i i i l_ 10 didn't really benchmark us against anybody. We
11 had folks come in from Seabrook, for example, and .
I( 12
13 they came in and said, Aren't you going to do the ~ 50.59 for that? We got a lot of input outside of 14 Connecticut Yankee of "We always do a 50.59 for 15 this type of thing." I think you'll remember the 16 FSAR. changed (inaudible). Additionally, Mr. Rogge i 17 touched on that topic. , 18 This next slide is the ! 19 50,000-foot view of what we're doing. We're 20 taking a three-prong approach to corrective 21 action. Given the fact that we still have a full 22 PAR license for Connecticut Yankee, albeit we're 23 giving you notification that we're ceasing ' 24 commercial operations, we have to maintain our *25 attention to our obligations; therefore, we need
. _ . . -. .....- -. -...-- .-.---._.--.-.-.._ -.- - - -..- _ - - -
l 1 l l
l i I ; . 24 l
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1
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2 to put in place some short-term interim actions l
l !
3 that would assure us that we wouldn't have any i ! 4 significant events as we go through the short- and !
L 5' long-term' actions. And I'll describe those next. l
6' Additionally, there are ! ! 7 short-term actions that are being completed by the ' i
..
8 first quarter of '97. I'll give you an update of 9- those. Then we have long-term corrective actions. 10 The significance of.this item is that it is our 11 intention to complete all long-term corrective ! ) 12 actions prior to putting in our PSDAR submittal.
l
} ' 13 The message there is that we will correct all 14 these problems before we tell you we are ready to 15 come into decommissioning. 16 -The immediate actions that 17 we did take -- and most of these are docketed. I . 18 have supplied you a copy of a previously docketed
I
19 letter dated December 9th. It talks about some
L 20 interim corrective actions. The immediate act' ions )
'21 were intended to stabilize the situation. If.you 22 think of them in terms of a~ power reactor's comp
!
23 . measures. In fact, we did have significant , ("5
i \-) 24 problems and we are not willing to tolerate any I
25 additional significant events until all corrective .-_ .. . - . _ . - - - - . - . ., - - . - -- - -, ..
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I- l , I l O 1-
25 2 actions have been implemented.
! 3 The two most significant are
- '4 we now require director approval of any activities
I 5 conducted after normal work hours. There was ;
i '
! 6 clearly a different standard for the kind of work
7 on day shift with everyone around and off hours. 8 So to preclude problems arising from that in the 9 short term, until we get everybody's standards 10 where they have to be, we're not going to let : 11 anybody work on back shift. If we do, we have 12 people here watching them. That policy has been 13 in place for almost two months, and I think I can 14 count on one or two fingers the times we actually -15 had back shift work. And I think it has helped 16 us. 17 Additionally, in the 18 radiological area, we do require director approval 19 of all significant radiological work. Again, 20 we've docketed what significant radiological work l
l 21 is in this December 9th letter under the area of 1
1 22 restriction of work in radiological control ares.. I
l 23 I won't read this to you. It's right in the
24 letter that I supplied to you. Those are --
!
25 NRC: You'll have an . _ - - _ - _ _ . _ _ . . - - . _ _ . _ _ . - -_. _. _,. __ _ _ - _ _ .- . _ _ _ _ <
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I i !
! 6
LC ) r i '
:
i 2 opportunity, Jere, to discuss some details of that ,
i
, 3 last, what is considered significant radiological i j 4 work? Will you have an opportunity later?
5 LICENSEE: Yes, we will.
i i 6 Gary will cover that. !- ! j 7 The second immediate action , i 8 is we did raise standards in immediately critical t
[ i
! 9 areas. It's a difficult thing to measure i , 10 standards, so I'm going to have to give you some , !
. 11 anecdotal evidence of that. Again, this is an l
e> i '
12 immediate action. It's not considered a long- or
- 13 sho.rt-term corrective action. ;
i
3 14 Every operational problem is j
>
)i 15 escalated to me, no matter the significance. And
'
, r l 16 I'll just go back to last week. There's a lot of
. 17 examples. The residents have been witness to a
]
< 18
'
lot of them. We had a small oil spill due to j
i
19 overfilling -- actually, we didn't overfill it. 20 We filled a tank. The tank heated up and put a 21 little bit of oil on the ground. Really not very 22 significant. It did not go to the waterway or it 23 did not leave the site. However, I knew about 24 that problem, I would say, in less than a half an 25 hour after it occurred.
_ _ _ . _ . . _ . - _ _ . _ . _ _ . _ . _ _ _ _ _ _ . . _ . . _ _ _ _ _ , ! e i !
/~ 27 ' (_)g 1
, 2 In the way Connecticut 3 Yankee used to do business, I may not have heard 4 about that until the next day. Anything that is ! 5 an operational issue is being escalated 6 immediately to the operators, the shift managers, 7 senior management. 8 There's a clear standard for 9 procedure use in place. It's in our ODIl 10 Reconnaissance Operations. Our standard for use 11 of procedures from the operator's perspective is '~ 12 if you're manipulating a component, there is a 13 specific step that specifies the component and I l 14 what to do with it. Our old procedures had ! 15 guidance that was a mix of specificity, like I 16 just told you, along with a more generic type of 17 guidance. We have taken thac flexibility out of 18 our procedures in a going forward basis. To date, 19 213 procedures have been upgraded to this new l 20 standard; and going forward, we're upgrading 21 procedures before we're using them in the field. 22 So that's a process. In fact, you'll even see 23 there's Key Performance Indicator for the 24 Operations procedure upgrade that we'll cover 25 later on.
_ _ . _.
,
I 1 l l i ( 1- 2 We are using a check 3 operator for a.self-assessment. The operators', 4 even with good procedures, can make mistakes and 5 may not see a problem in procedures; so we're , 6 using a second operator routinely for evolutions 7 to check up and provide feedback, offer 8 peer-to-peer type of feedback. And that's turned i 9 up a few problems, which is good. 10 Just another measure of 11 standards: Radiation exposure. I'm telling you 12 we're taking a hard line on dose. We're not 13 letting people get dose. We're very, very, very 14 conservative on that. And a measure of that is 15 provided here. We have 712 millirems.for January 16 '97. 17 Now, I've provided you here 18 again, just at your tables, a graphic here that 19 goes from 1989 to 1997, and this is exposure per 20 month, what we used to call power operations. 21 This is when you're not in a refueling, what would
'.-
- 22 be the average monthly exposure. Think of it as
I
23 on-line. You can see that '97 number comparing to - 24 the averages for previous years as a dramatic 25 drop. Our people are getting the message. We're l !
- 29
s) 1
2 counting the millirem and we're real serious about 3 keeping that dose down as low as we possibly can. 4 NRC: Jere, backing up, do 5 you have a specific procedure for performing 50.59 6 reviews, and does that procedure reflect the new 7 decommissioning rule, you know, about 8 environmental impacts and impacting with 9 decommissioning funds? 10 LICENSEE: I would defer 11 that to John.
r~% 12 John Haseltine. We have a L)
13 specific 50.59. It is Operations-driven right 14 now, and we are converting that to decommissioning 15 to put the three items in from the 50.82. That 16 should be done here within the month. ' ' . 17 NRC: Thank you. 18 LICENSEE: Going on to the 19 next area, another indication of improvement in 20 standards in Health Physics area -- most of those 21 first examples are Operations -- RWPs have been 22 upgraded. When we converted over to our January 23 1997 RWPs, significant upgrades were made in the
\_-) 24 quality and the specificity of those RWPs. And I
25 believe Mr. Nimitz has taken a look at those.
. _ . _ _ . . . . _ _ _ _ _ _ _ _ _ _ . _ . _ - _ _ . ._ _ . _ ._ _ _ __ _ _ . - _ . . . . _ _ . .
!- i l (:) 1
1
> 2 RWP pre-job brief standards l l 3 have been raised. And many of those pre-job ! L 4 briefs are now attended by a director, if they l l 5 meet the definition of significance.
6 HP's job has been reinforced 7 that their primary focus is to provide proper 8 radiological controls. One of the things that had 9 gotten away from us is the Health Physics
l 10 technicians, who have a job to provide people
11 access to radiologic areas, have taken the provide 12 accesr, miseion over and above the provide control
!O 13 mission. Ind we had to reverse that thinking. l
14 That was conducted -- Gary conducted an all-hands
l 15 meeting with the HPs, and I happened to be there
16 to attend that. And the message was driven home.
L 17 That's reinforced daily by management. HP's job
18 is to control. 1 19 additional immediate 20 actions --
!
21 NRC: Excuse me. Since 22 you're doing that and you're trying to change . 23 management behavior effects, what are you doing to
'
24 monitor that? , 25 LICENSEE: Bill, right now I ' ! _ _ _ - . . _ . _ _ _ _ . _.__ _ _ . - _ _a
.=_ - ._. -- __ ~ - _ _ - _. (-] 31 \_/ 1 2 can't hand you an indicator that says we have the 3 HP control where we want it. All I can tell you, 4 as an immediate corrective action, we reset 5 standards and we are monitoring, as you know, ' 6 significant jobs using the director to take a look
i
7 at it. We have no additional monitoring right now 8 at this point. ; ' 9 Additional Immediate
i 10 Actions, key management changes. Ted did indicate
11 that we have significantly beefed up the senior ,
i
(~' 12 management station. In February of 1996,
! l 13 Connecticut Yankee had three directors. Northeast i
14 Utilities reorganized. Two of those directors 15 left the site. In retrospect, that made life ;
l '
16 difficult, specifically for myself. And we 17 decided that we needed to restaff to the old way 18 of doing business with three senior managers
- 19 on-site. It has allowed me to step back and take
l ) 20 a more global view of things instead of being l l 21 right down in the fire all the time.
22 Operations Manager was 23 removed from duties after the nitrogen event, and f'\ (m,/ 24 the Radiation Protection Supervisor was removed 25 from duties after the contamination event.
_. __ .- . .
J
l (-) \_/ 1 32 2 LICENSEE: Jere, to further j l
,
3 elaborate on Bill's question, I think Jeff has ' 4 done a great deal in terms of monitoring the 5 impact of new standards for radiological cont.rols. 6 LICENSEE: I can do it now,
8
7 sure. We've brought in a number of people who I 8 have extensive HP background, and they have been l l 9 heavily involved in field work, reviewing the 1 10 programs, working with the individuals out ' 11 on-site. They've been at just about every p 12 radiological job that we've done in almost the LJ 13 last month and a half. And they have seen a 14 turnaround or progress being made in the HP area 15 where there is a greater awareness, particularly
16 at the pre-job briefs, the way the briefs are 17 handled, the -- how do I want to say it -- the way 18 the HP is providing information at the briefing 19 and the way they are controlling work.
4
20 Now, you know, this is for a 21 short period of time and it's just recently we've
<
22 seen this come up. But this is what we've been 23 providing. It's feedback. There's no numerical () 24 indicator or specific goal that we're looking at, 25 but there is certainly feedback. We've talked to
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:
'
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1 !
i 2 Gary, and in our surveillance reports we've )
I
i
indicated those areas where we feel there's been ^ 3
,
4 progress made. 5 NRC: You made a comment ; 6 earlier about there was one set of standards when ., 7 people were looking and another set of standards
[ ,
8 when they weren't. That's the way I understood 9 what you said. I guess what I'm trying to get an 10 understanding'of for the immediate action that j
l '
11 you're taking here, it' sounds like, if I
'
12 understand this correctly, you're going to go to a 13 strong aggressive oversight program, having i 14 somebody out there watching the job being l 15 performed. 16 LICENSEE: And management's l 17 direct involvement for the significant activities. ! 18 NRC: I guess I'm kind of I : 19 interested in, if you're trying to get some sort l 1 20 of an indicator of whether that's working, how do j 21 you know? I guess it's telling you if somebody is , ) l 22 watching, it's been done right. That's important. l 23 But.as you -- maybe you'll get to it, but I'm kind j 24 of interested in where this goes because, you ' 1 25 -know, you can't just say, Well, for the last three
l l 34 1 2 months we've had zero problems; so therefore we 3 can back off. 4 LICENSEE: You have to walk 5 before you run. 6 NRC: I need to know where 7 you're going and what kind of actions you need to 8 take or what kind of information you need to have- 9 to be able to reduce that oversight, or maybe you
10 don't intend to. I don't know. But I'm curious 11 about that. Do you' understand? 12 LICENSEE: Yeah, I do, Bill. 13 I think I can address that right now. There's two-
'
14 aspects of that. You're right. Oversight can't 15 be the answer. For instance, we have people 16 wearing hard hats. If I walk to the plant, I 17 won't see somebody without wearing a hard hat. I 18 think that's where you're getting at: How do we 1
! i
19 change the behavior fundamentally. I 20 We are right now 21 micromanaging. We don't let anything go on unless 22 we're aware of it. That's fine for the time 23 being, but for long-term actions, we need to 24 reingrain people the right standards for how we're 25 going to conduct work. And that's the real answer
l
) 1 { l 2 to your question. You've got to make people 3 accept what the right standard is and then hold 4 them to it; and then they'll do what they're ! 5 supposed to when you're not around. I don't want { 6 to make it sound like people were breaking rules 1 7 or the standards. ' 8 I'll tell you, explicitly 9 what happened in the contamination event was 10 formal schedule progress tracking during the 11 week -- the morning meeting required a work l 12 coordinator to be on site 24 hours a day. In that 13 event, they didn't have the morning meeting to 14 discuss what kind of work was going to go on that 15 day. The evening shift work control guy was given 16 the evening off. So did someone go out there and 17 break a rule? No. Did they drop their standard 18 of how they were conducting the work on Saturday? 19 Yeah, they did. 20 And that's really the nature 21 of what I'm talking about in the back shift work. 22 So we're going to have formality, and we're going 23 to have it all the time. And we won't do anything
Q(_- 24 without people here to make sure of that, you
25 know, period.
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l I
1
, . ,
2 LICENSEE: And when it's '
. 3 fully established and fully ingrained, we'll be
i
- 4 able to back off if that's appropriate.
5 LICENSEE: We may never have 6 to work back shifts, and this work can be i 7
[ conducted -- at most sites it's being conducted on i 8 a 40-hour week, the decommissioning activities. l
9 LICENSEE: But the oversight
10 now is intense and that's by design. 11 NRC: I hope that Gary gets 12 a little bit into that because currently, as I 13 understand the program and the controls, your Rad _ 14 Protection Manager and his supervisor are acting j ) 15 as gatekeepers. And using the T6 program, the ' 16 maintenance program, no work is performed in the 17 plant without those two individuals and this 18 fellow approving it. And that's currently where 19 you're standing now. And if your independent 20 review team has a bunch of corrective actions and 21 recommendations also -- and I hope Gary talks- 22 about where you're going with the program. I had 23 some question or our last visit up there, -(_ A) 24 particularly for minor maintenance control and j 25 other activities, to make sure it's adequately i :
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1
. 1
4
2 controlled and in the plan. But essentially since 3 .this event occurred, there's been perhaps two or 4 .three entries into any significant areas, and 5 that's been for surveillance. Is that correct? 6 LICENSEE: There's been 7 about a dozen entries into block high. rad' areas, 8 most of them for fairly insignificant activities. 9 We'll go on and see if we 10 answer your question or not, Bill. 11 NRC: Go ahead. 12 LICENSEE: That completes (} 13 the Immediate Actions. Short-Term Actions, again, 14 these are actions which we intend to have 15 completed by the end of the first quarter of '97. 16 The first action, and I think it's significant 17 because the plant, we've decided to decommission 18 it, we're in a very significant transitional 19 period. We have to reorganize the plant for a 20 decommissioning-type organization. The staff of 21 the plant is clearly going to be-concerned about 22 their futures. People are going to be thinking 23 about what they're going to do with the rest of 24 their lives. And therefore we need to make sure 25 we -- we have to put the horse before the cart
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! !
i
! a
1 .
- 2 here. So our first Short-Term Action is to j
r l 3 rebuild the organization into an organization that j
i l
!
/ 4 ultimately can support decommissioning. We've ! :
4 5 done.this in a phased approach. We have an
6 Interim Organization and then a final ! ' I
l
7 Decommissioning Organization. The Interim
i 8 Organization is designed to complete the j
- i
i 9 corrective action we're describing here prior to . . 10 entering into full-blown decommissioning. Again,
i
11 that's consistent with the message that we won't
,
12 submit the PSDAR until we complete all these
- 13 actions.
i j 14 Essentially all positions in , a
15 Connecticut Yankee are being reevaluated,
'
16 reposted, and we're able to select people to 17 construct the organization from scratch. 18 Incentives are being applied to attract the best 19 talent. What we're hearing -- we have talked to 20 all the plants on decommissioning, and the 21 important message from them is to make sure that 22 you retain experienced personnel who know the 23 plant well. So we have taken their advice. 24 Everyone on-site is focused 25 on -- and this is a typo. It should not be . ! )
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! l i
1 2 " decommissioning" -- is focused on the mission. 3 When we have an organization in transition, people 1 i 4 may be focusing on their families, their children, l 5 and rightfully so. When we've built the new 6 organization, once we've filled everybodyLin and 7 rehired them in and built this new organization, 8 we'll have people on-site that are focused on 9 where we're going, not on the past'or the history 10 of plant. That focus is an extremely.important. j ! , 11 organizational characteristic. And, quite j 12 frankly, right now there's no way we can claim we 13 have that. So right now we have to keep these 1 14' interim actions in place until we get to where we . I 15 are focusing. 16 We are minimizing the
l l
17 duration of the transition period. Obviously, 18 until we get the organization named, who is going 19 to stay here and get them focused on what we're i 20 doing, there is an elevated potential for ! 21 additional incidents. So one of the best ways to
, 22 reduce that is to reduce the time you're in ., ,
1 . 23- transition. We intend to complete the staffing of !
- - 24 the organization by the end of this month.
t '
25 The selection process for !
a
l
._ __ . _.
4
(^) 40 %- 1 2 our people is based on behavioral interviews. 3 Certain behavioral traits are -- this is something 4 -that came from our human resources books -- and 5 certainly desirable behavioral traits are revealed 6 in this process, which is past performance-based. 7 It's a very unique process, and I found it very 8 enlightening, and I think it's a strong process. 9 So the first thing you have 10 to do is build the organization up, given the fact 11 that we are now entering into the decommissioning. 12 In building the organization -- I'm on the second {~ 13 page of the Short-Term Actions -- we are bringing 14 in outside talent. Connecticut Yankee -- and 15 we've said this in tcis forum before -- 16 historically has been insular. We have brought in 17 people like John Haselt ine and other individuals 18 to bring in an outside perspective. We're going 19 to continue that trend and stand on it. We are 20 going to hire an HP manager from outside the 21 company. The Yankee Rowe has supplied us a plant 22 manager with experience on Rowe. That individual 23 will be able to help us in the future; but clearly 24 since we are right now focusing on corrective 25 actions, that's really down the road.
__. . . . _ _ _ . . _ . - . _ _ _ _ . _ _ . _ _ _ _ _ . _ _ _ _ _ _ . _ - .. ___ _ _ l 1 i 2 Our organization has a 3 Decommissioning Project Manager and a Business 4 Manager. Those are two new positions, and we've 5 gone outside the company for those positions. 6 These individuals will be able to do work for us 7 on a decommissioning side and allow us, the 8 current manager, to focus on making sure our i 9 corrective actions are effective. So bringing in 10 the outside talent is going to help us. i 11 NRC: Could I go back to the ; 12 previous line? There's a word on there that I'm { 13 wondering why you have it. I'm sure there's a 14 good reason. Essentially all positions are being 15 reevaluated. 16 LICENSEE: When we put the 17 organization chart up, we had five names on it, 18 three directors and two managers. So we retained 19 five individuals. When we first posted the
l 20 organization chart, every other position was
21 posted. It was an evaluation, but it was not the 22 same process we were using.
, , 23 NRC: Are we talking about
- ,
l 24 managers and supervisors, or with --
25 LICENSEE: It was only five ._ _
. _ . _ _ _ _ _ __ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ . _ _ . _ _ _ . . _ . _ . _ _
, . 4- l 42 1
2 people. It was Gary, myself, John and my , 3 Operations Manager.
! :
, 4 NRC: So the very high !
- 5 level.
, 2 6 LICENSEE: The very high j 7 level. And they were approved through a different
l 8 selection process. ! l- 9 LICENSEE: There was five 4 ;
- 10 people out of 177 for the interim organization.
J l 11 NRC: As long as you're
12 talking about selection of individuals and 13_ retention of people, bringing in new talent is 1 14 very important because you want to get away from i - i 15 some of the cultural stuff you have, but you also i 16 have -- when you're entering into decommissioning, I 17 you need to have some of the old-timers around to : 18 know some of what had happened over past ! 19 operations, because that sort of corporate memory 20 becomes very valuable sometimes. Have you looked - 21 at that,-as well? 22 LICENSEE: Yes. In fact, 23 that is the purpose of my bullet on incentives. I 24 can tell you now we've actually made the offers. 25 We have five of the shift managers, who are our - . _ - - . _ . , ,
. _ _ . _ . - - _ . - . - _. _. -._._ - . - _ _ . ..
, i
l
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( 1 " 2 most senior operators, have decided to stay. So
4 .
3 the five most experienced operators are staying
! 4 with the interim organization, as an example.
5 The final bullet, which I ,
i i ,
6 think is very important, we also have found that i I
!
7 the contract personnel be first engaged in the CMP 8 efforts at Connecticut Yankee. We found those 9 folks brought in some really good high-standards.
l 10. I think that they have been a valuable asset. ) '
i 11 John is going to cover what ~ 12 we're doing with the contract personnel. The
,' 13 bottom line is we're keeping an awful lot of them !
. 14- around. That's been very helpful in terms of -l
,
15 outside perspective, in terms of how to do '
i 16 business in the engineering area.
4
<-
17 Next Short-Term Action, we l
} 18 are having rigorous performance goals and i
19 monitoring. I've provided you.our Key Performance
. .
20 Indicators. That's.this little package here. We
{4 ' l 21 go through this every week on Wednesday at 10:00.
22 Attendance for all is mandatory. You'll see in
i i 23 here that we are looking at various types of f -
24 indicators, both performance indicators and
[ 25 progress, how you are doing on things. And unless
, .
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u m - n v
_. _ _ _ _ _ . _ _ . - . _ _ . - _ . _ _ _ . _ . _ _ . _ _ _ _ _ _ _ _ _ . _ . . _ . _ _ _ _ _ .
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t : ! . 1 l 2 there's any specific questions, I won't cover i' 3 these in any great detail. I'm going to cover one !' 4 that's relevant to another bullet later on. 5 We have work control issues, { 6 safety issues, and we're building -- we're adding ! 7 new indicators as we go along here. One thing ' 8_ that is not on here is indicators for the project 9 action plans, which will be included. You should ! ! 10 have that, Bill, right in front of you. These , .11 KPIs are looked at weekly, and we have management f (} 12 13 addressing the trends. ; We also have weekly project 14- reports from what we call th6 GRPI manual. I'm i 15 not going to define that term now. I'll let John 16 go through that when he goes through his ; ! 17 presentation. It is the core of all the action 1 18 plans, where we're headed. ! -19 Next Short-Term Actions, we 20 have to plan.the actions necessary to correct our 21 problems. We have a plan for each item. Bill, ) i 22 this may help you a little bit. You'll see when 23 John and. Gary go through the slides, we have l O 24 actually action plans of management standards with i t 25 responsible individuals and a plan on how to do I
45 1- 2 that. We have a schedule set for each item. 'It's 3 already completed. And we have accountable 4 individuals named. So we have already developed 5 the plans. 6 NRC: Jere, this slide here, 7- are you still referring to the generic problems, 8 the stuff that we covered in the December 4th 9 meeting, or is this focused toward the November
10 2nd? 11 LICENSEE: I'm glad you 12 asked that. The common cause is the Virigilio- 13 items. It also included the corrective actions 14 from the nitrogen event. And the IRT is the base 15 document for the response to the contamination 16 event. So it's all the issues and all the plans. 17 Gary has a matrix of corrective actions for the 18 IRT. John will show you the plans and the l 19 correlation for the common cause, l 20 The message here is we have 21 turned over not just four broad categories, but a l 22 lot of specific' items that have to be worked off, 23 and we have action plan, responsible individual 24 and schedule to address all of those. That's the l 25 purpose of this slide.
-.
46 . 1 2 Next Short-Term Action, 3 again, the adverse condition report system is our 4 corrective action program. We did do what was 5 necessary to go back since the inception of the- 6. program and do a comprehensive review of all the 7 backlog of this program. That has been completed. 8 We looked at the adequacy of 9 the documentation of the corrective actions. We 10 assessed it. If the adequacy of the documentation 11 on the corrective actions itself did not look 12 adequate, we reopened the issue. So as a result 13 of this review, the item was either closed, opened 14 or archived. Many of the issues are simply no 15 longer relevant to a decommissioned facility. If 16 they're programmatic, they were not archived, if 17 there were specific hardware issues for a piece of 18 equipment that is no longer necessary. 19 We had our Quality Assurance 20 organization audit the archiving process, and the 21 results were satisfactory. Currently there are- 22 343 of the 1,922 ACRs either in ti.e open or 23 tracked status. I'd like to go through this one 24 KPI, if you could pull your KPI books out. 25 There's two KPIs for this. One says Open ACR and
-. . - - - _ . . - _ _ , , _ . 1 2 the other one says Track ACR. The reason this 3 starts on 122 is before this we had a KPI for 4 going through the backlog for the 1,922, taking it 5 down to zero and doing the reviews. Now we've 6 characterized the backlog and we're going to track 7 the backlog. 8 You can see we have Open 9 ACRs. Those are ones we feel -- we have not
10 identified the issues and corrected them. We 11 started at 149. We have now 148; so we only 12 worked off one in the last week. 13 In the Track ACRs, one of 14 the problems we saw at Connecticut Yankee was we 15 were closing ACRs out to future corrective actions ! 16 tracked under other programs. And the other ' 17 program may or may not realized. We were ending 18 up closing items that we had previously identified 19 and dropping them, dropping them off the map. To 20 solve that problem, we created the track status. 21 And ACR and track. status really is complete in 22 terms of you've identified the cause, you've 23 identified corrective actions, but the corrective i 24 actions are not one hundred percent complete. It 25 doesn't come off this list until corrective
3 48
(~/ A- 1
2 actions are one hundred percent complete. That 3 was a programmatic improvement we've made as a 4 result of the problems we identified. 5 NRC: On the first slide, 6 before this one here, we were talking about 7 adequacy of documentation of corrective actions 8 assessed. We were going back and verifying that 9 documentation. What is the expectation that you 10 have in terms of what is an adequate complete ACR 11 package? What are you looking for?
('N 12 LICENSEE: The procedure V
13 describes how to do it. You either have to do a 14 root cause, apparent cause, or you can close an 15 item if it's a low enough level. And there is 16 some judgment involved in this thing. But if you 17 read either in apparent cause or root cause -- and 18 we had two people do this, I think -- we applied 19 consistent standard to just the quality. Does it 20 seem like, given the evidence -- the statement of 21 the problem and the statement of the cause in 22 either the apparent or root cause, does it pass 23 the common sense test that they actually found the 24 problem? It was a judgment call. We don't really 25 have a standard defined in words for the adequacy,
49 ) 1 2 but the standard is Will it prevent recurrence? 3 Did you get to the problem? ! 4 LICENSEE: And you do do j 5 trending. ! i 6 NRC: On the what? ; 7 LICENSEE: On the ACR's 8 causes, coming out of the ACR effort. 9 We do not have that 10 trending. That's.in the plans. I'm trying to 11 talk about where we are today. 12 LICENSEE: Maybe I can help
(}
13 you on this. One of the things we did is we went 14 through those. We took each one. We.had an 15 independent person look at this. Was the cause 16 identified and was there a solution that we could 17 find, physically find? And that's how we put them i 18 into different bins. If they didn't find a 19 solution or cause, they left it open. 20 NRC: Relative to these ACRs ! 21 that you have here in the backlog, do you have a 22 feel for how many of these were radiologically l 23' program-related? ' ! 24 LICENSEE: I can't answer 25 that question, John. I didn't come prepared with ._ _ . _ _ . - . _._ _ _ _ . ---
_. . _ . . ._. . . ._ - _ _ _ . _ . _ . . _ _ . . . i !
i
' !
4
50 2 l that level of detail. i 3 NRC: Maybe we can address ! 4 the question. It may be a higher concept for you. 5 In your plant, do you expect all the problems are
,
6 identified in ACRs? Is that a singular problem 7 identification program or are there other? 8- LICENSEE: Excluding
4
9 hardware issues, yes. Hardware issues, we have a 10 work order to do the repair; but other than that,
- 11 it is the singular system.
12 NRC: So this would be the
3 13 personnel process? l 14 LICENSEE: And hardware. If
15 a hardware deficiency occurs, an operator will
] 16 write an ACR. .
- 17 NRC
- So other than-those
4
18 two things, these are the two problem 19 identification systems?
,
20 LICENSEE: We have the UIR 1
l j
21 process that was specific to CMP.
<
22 LICENSEE: But anything that , 23 would be written in ACR. 24 NRC: Let me continue then.
, , 23 I think I'll get to John's question. A number of f~ i d
- . _ - -_ _ ._..
'
51 1 2 facilities have separate terms for Health 3 Physics-related problems. 4 LICENSEE: Radiologic 5 occurrence reports. 6 NRC: They used to be 7 radiologic occurrence reports or radiologic event 8 reports or things like that. Does that type of a 9 system exist at Haddam Neck or is Rad Protection l 10 also expected to use the ACR or TR system? 11 LICENSEE: We use the ACR 12 system now. We used to have radiologic 13 deficiencies reports. We now write ACRs. 14 NRC: Does that apply across 15 the board to other support functions, for 16 instance, security, emergency preparedness, fire 17 protection, and all those? 18 LICENSEE: Where we're going 19 is to bin those radiologic events, EP events, and 20 so forth, so we can trend those and see those 21 trends. We're not there yet. 22 NRC: That's fine. The next 23 question gets into kind of a trending question. I 24 guess, is it.right for me to assume that your ACR 25 program somehow categorizes the ACR so that you i , -n . - - , , . ~ ,
.. ._. -- . _ - . - . - -- . .. - ..
I
~'
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52 } 2 can determine those that you want to do a thorough 3 root cause versus those that'you just want to fix 4 the problems?
l
5 LICENSEE: The significant
i 6 levels, yes. !
7 NRC: And for those lower 8 significance levels that don't require a root 9 cause assessment, what do you do with those? Do
l 10 you trend those to see if there's a need for,
11 let's say, an ACR on a developing trend? Is that 12 how you process it?
i 13 LICENSEE: Jim, that's how
14 the process is supposed to apply, but I'm not
l 15 going to claim that we're a hundred percent on
16 that. I can give you three ACRs that did generate
l 17 from trends, but we have not consistently applied
18 them. 19 NRC: But that's essentially
l l 20 your vision for this program? Your program will l 21 require a detailed root cause given a certain i
22 categorization of ACR -- 23 LICENSEE: Once you get a 24 trip level -- 25 NRC: -- and below that .
.. . _. _ _ . . _ . ~.. _ _ _ .. . _ - . _ _ _ . _ _ . _ _ . _ . . _ . _ . _ _ . _ . . _ m _ 7._
l
l 1
i , ! 2 threshold? )
3 LICENSEE: Ones that are ) i
4 immediately closed out will be binned in various ! 5 barrels and trended. Then when you hit a wire 6 trip on the narrow, you would do a more global. 7 LICENSEE: It's also 8 important to point out at this point in the j 9 discussion that we've brought in outside 10 experience for this particular area, because we 11 haven't done this well for a while. And.the (} 12 13 individual we have put the program together at Fitzpatrick. And before we named him tc this, we 14 saw the Fitzpatrick report, which has the trend- 15 graphs that you're describing. And he had some
t i
16 generated. So that's exactly where we're headed. 17 We've hired a guy that's done this before. 18 NRC: Is that system 19 sensitive enough to indicate at what level a 20 problem was identified?? And is that trended? 21 What I'm looking at is in terms of (inaudible).
- 22 Is that trended in a way that you can measure how )
-
1 23 much better you're getting or how -- because 24 ideally you have them all identified at the first 25 level. That's ideal, obviously. 4 . .. . -. - . - -
. . . - - - - . . . - . . . - - - - - . . . . - - - - - - - - - - - - - - . . - i
l
l 1 ! t 2 LICENSEE: That would be a
l 3 good measure.
4 NRC: It's approachable, but 9 5 it's a way of getting at what I was talking about 6 earlier. You know, you have to kind of understand 7 how sensitive the organization is for identifying 8 its own problem and where. And if the problems ! ! 9 are all being identified at the second and third i 10 level, or most of them are at the second or third 11 level or worse, then you're not going -- you're
1
{} 12 13 going in the wrong direction. It should all be trending over time back to, probably never quite 14 reaching it, but the first level. But that seems 15 to me to be a way of. measuring. You know they're 16 being identified, I would assume. And the 17 question is, is it being tracked and trended. 18 LICENSEE: We're doing that 19 at Seabrook. And a long-term approach would be to 20 - do that at Connecticut Yankee, too, although we're 21 not there yet.
3
22 LICENSEE: So we're not
L
23 doing that right now, Bill. I'm trying to
i 24 remember the Fitzpatrick -- was that one of the i
25 indicators or not? It's the four levels of
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, _ _ . . - - . _ _ _ _ . _ . l l
* ! 1 2 quality. Was it in there? If not, Bill, we'll 3 make sure that's a point. 4 NRC: Could I ask another 5 question on the TR system? I'm pretty sensitive 6 to the multiple reporting systems. I've seen 7 those to be problems. It's not necessarily an
j 8 equilibrium equation. If you have multiple , ' I
9 reporting, it doesn't mean you have performance '
l l 10 problems. But every plant I've been involved with l ;
that had performance problems always, always had
'
11 ' {} 12 13 multiple reporting systems. Does the TR system have a 14 tracking mechanism to track trends that would give 15 you information with regard to how much rework -- 16 or how much you're having to redo the thing 17 because of mistakes in the first repair, or 18 globally is it looking for recurrent maintenance 19 activities that would suggest that maintenance 20 isn't the solution, maybe engineering is more of l 21 the solution? i 22 LICENSEE: It's not as good
. 23 as you just described it, but if you'll look in ! (> 24 your package of indicators, we do have a formally l l
25 defined rework indicator. It is tied into the TR . . , .
. - , . .-.. . . . - - .. . . _ . - . . - - . _ - . - . . - - . . _ r~ 56
? !
\_T) 1 2 system. And you can see how our performance has 3 been in that area. It's fairly good. 4 What you'll find, the link 5 that you'll find, though, we've seen that the
o l 6 operators -- if something doesn't get fixed the ! !
i 7 second time, the same guy will put the TR in 1 I 8 twice. They write an ACR on it and they elevate ! 9 it to the next system because they don't want to j l 10 put up with it. l
l )
' 11 I ' l .1 point out, in '95, I , 12 believe it was 1,400 ACRs. I'll give you the 13 number if it's relevant. But that should give you '
!
14 an idea of the level of detail you'll see as 15 compared to the old system. In '94, I believe it
l
16 was 300 and change.
l
17 LICENSEE: Your point is on- ) 18 the TRs, are we missing something so we can really
t
19 get a good trend? I think we need to take that
l
20 back and look at it. 21 NRC: Like I said, I just 22 have a personal sensitivity, that there were two
! 23 places to put stuff in. One may get in one and ! C
' 24 not get in the other. When that's the case, 25 there's a tendency or a possibility that those two
i ! _ _ ,
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- >
I
i 4
i i 1~ l
! '
I 2 things become decoupled. One system may be l 1
j 3. showing something that the other system isn't. !
I i
j 4 And maybe if the attention is on ACR as a higher I l
5 profile thing, TRs are kind of viewed or.may be -
4 L 6 viewed as this is how you just get equipment
7 fixed. There is a potential there for that
i '
8 repeated equipment problem to escape the higher ! 9 level manager's attention because it doesn't 10 become an ACR that works its way up to the point 11 of root causes or more thorough causes. That's ( 12 kind of a paper system that basically says -- it 13 really relates to another issue. And system 14 monitoring and.whether you have system engineers 15 now, are they going to continue through this 16 period or whatever. To me that's a subject of 17 another discussion. But, you know, let's leave it 18 at that. i 19 LICENSEE: Okay. 20 NRC: I guess one final 21 question. In that system that you have for : 22 identification, trending and closecut, is that a 23 system that's auditable? We talked about the one O 24 before, the Oversight organization would be l 25 capable of looking at that system independently
. . - . .. - . . . - .. -. I 58
(~'/) %- 1
2 and telling you whether it's working. , ) 3 LICENSEE: The ACR process? ' 4 Yes, it is auditable, and we have an outstanding 5 Level B ACR, which is our second highest. It's 6 actually a good lead-in to the part of the 7 discussion in which I'm going to cover it. The ; 1 8 bottom line in corrective action is we are forcing i 9 the current system to work and we're dropping the ! 10 backlog off, you know, using the existing system. i 11 But John has got one action plan to develop a ' 12 system that's a lot better. Again, the next 13 Short-Term Action is we've already characterized 14 the backlog. We're now in the progress of working 15 it off. 16 Another Short-Term Action is 17 we are reaching out to regain the public trust. 18 The performance issues at Connecticut Yankee in 19 the latter half of '96 have caused a very 20 significant public reaction. In response to this, 21 because decommissioning is such a large project 1 ' 22 that has significant public interest, we are 23 forming a Community Decommissioning Advisory
O
l 24 Committee. We have, in fact, written a charter 25 for that; we have selected a chairperson who has
, i i l 59 ! I 1 i 2 accepted; and we have, in fact, issued letters of. . 3 invitation to 17 entities to participate in this ) 4 committee. This is really a subject for another 5 meeting. The first meeting is scheduled to meet 6 in March. 7 The final Short-Term Action 8 is that management is, in fact, currently raising 9. standards by example. And, again, standards is 10 difficult to measure, but it's important. So I'll 11 have to give you some anecdotes of things that are 12 different today than they were, say, two months 13 ago. 14 About a month ago we had a , 15 situation where an Auxiliary Operator -- excuse 16 me -- a Nuclear Systems Operator, took manual 17 control of the feed to our auxiliary boiler 18 condensate receiver and increased the level in 19 this tank. It's a balance of plant component 20 which is a vehicle which supplies steam. It has 21 no safety significance. The individual took it to 22 manual because he thought the level should be a 23 little bit higher. He thought maybe it was not i O 24 operating properly in automatic. And so the ! ! I 25 intention was correct. Ile did not get anybody's l
e
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I'
i
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:
'. 60 l
, 1 ' 2 permission to do this, nor did he -- not only
f. 3 that, he walked away from it to take_some logs.
- 4 It's a very large tank.
t
- 5 Now, when he came back, he i
4
. ; 6 found the thing was overflowing. It's primary
i
f 7
' &
water. It's pure water. But it does go to a
i ! 8 drain that goes to the discharge canal. There is i L 9 no intermediate holding tanks.
- -
] 10 The' consequences of this j
: I
j 11 event were essentially zero. However, we reacted ; i 12 very strongly. First of all, we did take on the
- 13 individual's -- what gave him permission to bypass
l 14 this automatic control. We did address the issue i
15 of even though it was pure water, that was an
. 16 unplanned discharge to the environment. We ,
17 reacted to this very strongly, and it sends a
[ $ 18 message to people of what standards we're looking i 19 for. Even if you're working the aux, boiler, j 20 you're in a procedure, and there are specific ,
21 procedure steps to manipulate the component. And 22 we are not going to tolerate people manipulating 23 components without procedures. Procedure steps 24 will have specific component manipulations in 25 them, and that's the standard we're going to have.
. _ _ _ . . _ _ _ _ _ _ . - . _ ~ _ . _ . . . _ _ . . _ _ . . . . . . . _ . . . - . . .._____. _ i
I
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i t 1
, 2 Fuel transfer hatch retest, ! ! i
3 we had.a problem with putting the fuel transfer i i 4 hatch on with the number of bolts. In part of our i 5 investigation of this, we had identified the
I 6 retest for this fuel transfer hatch. While it was
7 technically okay and certainly met every l l 8 regulation, it was not rigorous and, in fact, it ' I
- 9- was not up to our standards. And we've called
l
10 that job off until engineering can provide an i 11 adequate retest. The consequences of this retest
I
12 simply would be that we'd have some dripping from (
l 13 the hatch if it was to leak. So, again, no , i
14 significant safety consequences, but we're not
15 going to tolerate an inadequate retest. l 16 In John's area, in the yard, j i 17 we have calculations of record for the yard crane
i 18 =that in our reviews, our engineer reviews of the
i 19 spent fuel billing, we determined that those 20 calculations were not adequately rigorous, and 21 we're redoing them.
o 22 NRC: Before you do any
i 23 heavy lifts using the yard crane, do you plan to
O 24 test it? i 25 LICENSEE: Yes. We'll have
i
.- - - _ , - -. .- _-. -. . - . - . - - . . -_- . - . - - - .._,_ . . e ;
! !
1- i 2 to. Right now with the limit on the yard crane, , t 3 until we redo the calculations and make sure that l ! 4 it can take a heavy lift, we don't have any heavy l 5 lift planned, either, but it will be tested. 6 Mort, there is a PM, a 7 requirement that we do a load test, and we always
! 8 do that prior to making those standards. It's a
9 hundred ton crane. We currently derated it to 20
l '
10 tons. 11 LICENSEE: Going into (} 12 13 Long-Term Actions now, these are the actions that when we complete, we feel will poise us to be 14 ready to go into decommissioning mode. We will 1 1 15 not submit the PSDAR until these actions are ! l 16 complete to our satisfaction. 17 The first thing is implement 18 formalized standards. I've been giving you i 19 anecdotes about standards. That's all we can do
-
20 for the short term, is try to give you examples of
l
21 how we're holding people's feet to the fire and 22 not accepting stuff. However, we do recognize we
- 23 need formalized standards. There is a GRPI, an
[ 24 action plan for this. And the way we're going to
, 25 do this is as we name the new managers, they're
J
_ _._ .. _ ._ _ . _ _ _ _ _ _ _ _ . _ _ __ _ _ . _ .. _. _ __ _ , ! i , 1 ! 2 getting a goal right in their annual reviews to : : 3 develop with their team, their management team in ' : 4 their department, a formalized set of standards. l
l 5 Operations, for instance, has ODI1, the kind of ! !
: . 6 operations. I want those managers and supervisors 7 to sit down with their people and say, How are we l
- ;
j 8 going to conduct business? They've written that l l ,
9 down and will roll them up to the station level to 10 review those, and we'll agree upon what are the
! ,
11 correct standards for each department. 12 So HP will be doing this,
!
13 operations, maintenance, et cetera. From those, ; ; . 14 we will roll up certain station standards. ! : 15 Everybody at Connecticut Yankee needs to have a ' i 16 questioning attitude. That isn't any specific ! 17 department. And we'll publish those station ; 18 standards. We're going to use a bottoms-up type , 19 of approach to gain buy-in of the people who 20 remain for this decommissioning. They're going to 21 live to these standards. And that's our long-term : 22 plan for how we're doing to get formalized written
'
23 standards of how we're going to conduct our
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24 business. :
L > l 25 The next thing is we're i l l
_ _ _ . . . _ . . _ _ . . _ - _ _ . _ _ _ . _ - . _ . . _ _ . _ _ _ _ _ . _ _ _ _ _ . . _ _ . . __..____ ._ i l
, -
l . . 1 I
-
2 going to eliminate the ACR backlog. It's not 3 acceptable to have 148 ACRs that are not resolved
l 4 yet. As you all know, ACRs, there will always be .
- 5 some living backlog because you've just identified
. j 6 it takes a certain amount of time; but there will
i 7 be no standing backlog of ACRs. We will keep the 8 KPI that you've seen to monitor the backlog once
9 we've eliminated it, so we can see if the backlog .
! 10 trend goes up again. So that KPI will be kept. , l l
11 I've talked about the l (} 12 13 Corrective Action Program, the ACR process, and frankly, it has an awful lot of process and not i 14 much quality. The trending and stuff has just not i 15 been there, and the program involved with that has I i 16 been quite onerous. We are going to revamp the 17 process. We're going to get less process and more 18 quality. Again, we hired a manager who has done 19 this at another site to do this for us; so he's 20 been through this before. ' 21 We are improving the 22' software at the same time. We're going to get out 23 of the AITTS business and have a simpler software. 24 We have trained evaluators. 25 We've run the gamut from training all engineers to
__ ._- ._ -. _. _ _ ._ - ._ - - . _ . ... . _ _ ... _.. _ _._ - . '
4
- i
1 2 training certain engineers. We're going to have
-
3 trained evaluators in each area, and they will be i
1
i 4 the designated folks to do the evaluations. We ; 5 will have a smaller group of people with whom we i 6 can make sure that we get a consistent standard ; 7 for the quality of evaluations. 8 Again, the KPIs will come 1 9 out of this, the Key Performance Indicators, and '10 they'll be reviewed by management. 11 We are asking for an 12 effectiveness review of the Corrective Action ( 13 Program by Oversight. l 1 14 NRC: Do you know whether ] 15 those evaluators will be part of the line work l 16 groups? l i 17 LICENSEE: Yes, definitely, i 18 Bill. That's exactly right. So HP would have an 19 evaluator or two; Operations would have one or 20 two. It's of that nature. But there would also 21 be some station, you know, some people who report 22 to Jim Foley who are trained evaluators. 23 Complete HP Program 24 Improvements. Gary is going to cover this in a 25 lot of detail, so I'll skip over it. But clearly i
. - . .. . - - - .. . - - - - . .. .. - .- .- . . . . _ - - . . - - .. -
! +
i :
! I-
1
1 .
.
4
: 2 more rigorous control; improved procedures and , '3 processes; training, not just for HP techs, but l
l 4 for rad' workers on expectations and standards; and !
! 5 then effectiveness reviews by oversight. , ] 6' We need to complete the 7 emergency plan improvements. We have 8 classification training, the PAR process. Gary is , 9 going to discuss these, again, in more detail, but- 10 the PAR process was a problem; classification was 11 a problem. We are in the process of making the 12 process improvements and we'11 train them-in doing (" } 13 the effectiveness demonstration. 14 Finally, in Long-Term 15 Corrective Actions is the complete reconstruction 16 of Licensing / Design Basis. I want to emphasize 17 that we're really starting from the ground up 18 here. John can give you more details. But we're 19 going right to the design basis of the pool, 20 calcs, et cetera, and we'll build the FSAR from 21 scratch as opposed to trying to justify what's i 22 already there. So the CMP for systems required 23 when defueled will be completed. John will give i 24 the details. We will submit a revised FSAR as one 25 of our action plans. I I
- . - - . . - . . = . .- - _ - - .- - . . - _ . _ _ - - 67 2 NRC: What does CMP stand 3 for? 4 LICENSEE: Configuration 5 Management Program. 6 NRC: I need to remember
j 7 these initials. l l 8 LICENSEE: Program , t i
i
l 9 improvements -- actually, there's two categories !
! 10 here. We did the program improvements we promised 11 last summer for an operating plant. John's gone
i
12 beyond that. He's also going to reconfigure the
l
13 program. And training for the engineers on the i 14 new system were provided. Again, effectiveness
L
.15 review by Oversight. i 16 As I said when I began, I've I
I 17 covered a number of responses to the global
18 issues. Gary and John now are going to cover the
i
19 specifics of the November 2nd event and updates on 20 the E-plan and the configuration management ; i 21 issues. That concludes my part of the ! 22 presentation. -23 NRC: Let me ask a question. ( 24 What's your timetable for the completion of the
I :
25 CMP and -- . , , - , .
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i 1 2 LICENSEE: John's going to 3 cover that in detail. ; 4 NRC: I'll wait. 5 NRC: Does Oversight have 6 the horsepower to do the effective review? 7 LICENSEE: Pardon me? I'm 8 sorry. 9 NRC: Do you have the talent 10 to do this effectiveness review of what's being 11 asked for? j 12 LICENSEE: In the one for 13 HP, yes, but-we will augment our staff on 14 engineering issues to be able to do that. We _, i 15 don't-have that on-site, but I'll be either using l 16 NU people or Yankee people or perhaps even 17 Seabrook people to augment the staff for specific 18 projects. We're already doing that in a 19 particular review that John has ongoing. 20 NRC: But in HP you feel 21 comfortable? . 22 LICENSEE: I feel , 23 comfortable right now. If I need more, I can go , 24 down to augment some people from the Oversight 25 group at Millstone who have already got
.. . . . - - . _ . 1 i /^T 69 (_/ 1 2 commitments that people will be available as I ' 3 need them. 4 NRC: I assume this is more 5 than a paper-type review of effectiveness? 6 LICENSEE: That's correct. 7 It's actually going out and taking a look at what 8 has been accomplished. Gary? 9 LICENSEE: Good morning, I'm 10 the Work Services Director, as I said before. One 11 of my responsibilities is the Health Physics
'
(~'} 12 Program. The Health Physics Manager reports to %.) 13 me. 14 I'd like to speak to you 15 about the November 2nd refueling cavity canal 16 contamination event and the weaknesses that it 17 revealed to us. I'm going to give you a 18 description of this event. I'll be very brief 19 with that, because I think most of you understand
'
20 it. Then I'll talk about the causal factors and 21 corrective actions. Then I'll talk a little bit 22 about staffing and briefly what the oversight 23 organization is doing to help in this area. 24 On Saturday, November 2nd,
l '
25 the reactor coolant system had been drained to
70 1 2 below the reactor. vessel flange. The reactor 3 vessel studs had been retentioned and removed, and 4 we were preparing to remove the head from the ! 5 cavity'on.the following Tuesday. Two men entered 1 6 the cavity to inspect the reac~ tor head and the -7 cavity area. At the completion of this they 8 entered the refueling canal to inspect the fuel i 9 transfer system. After inspecting the system, 10 chey proceeded to remove some debris from the 11 canal, placing it into a plastic bag. This was
( 12 primarily scraping the scale and a variety of
13 small items that they found on the floor. 14 The agitation of removing 15 - this debris created an airborne condition in the 16 canal and the cavity. The two workers became 17 internally contaminated. Our initial dose , 18 assessment was questioned. And after we looked at' 19 it, obviously this was anything but a fairly 20 simple calculation based on the geometry of the ! 21 debris in the bag and the airborne condition that i 22 was changing throughout the time the workers were 23 there. Based on that, we decided to report this j
O 24 and issued -- put out a 50.72 and then a 50.73
; 25 report. We alse notified the media and the two M -*v-* =,+e wy mar 7 -+Tt=- w --=+w y -t++ +- - - r-= y*w-rp- 7w-= m
, . . .- 71 (]/ N_ 1 2 individuals involved. We did, late in the year,
- 3 receive a final dose assessment from an
4 independent third party. This indicated that , 5 there were no overexposure to the individuals. 6 I'd like to talk about the ' 7 causal factors next. We had four sources of 8 information here. There were two root cause 9 investigations, an independent review team
.
10 investigation conducted by oversight and then an 11 NRC inspection, all of which provided detailed 12 reports and a lot of good information for us to (~} s- ) 13 work from. i 14 A bit of history on the I 15 canal. This is an area that's had a great deal of l ; 16 ' contamination and high rad levels throughout the 17 history of Connecticut Yankee, especially on the ; 1 18 floor beneath the tracks where the fuel transfer 19 cart runs. In recent years we had used a diver to 20 perform an inspection of this prior to moving 21 fuel, leaving the car covered with water to reduce l 22 exposure. Last refueling we had experienced 23 problems with this cart due to some debris that [s/ 24 the diver had overlooked. So this year we had 25 decontaminated the canal to allow an inspec 'on
:
( 1
2 dry and hopefully prevent the problems we've had 3 in the past and ensure a thorough inspection, the '4 absence of debris, and an unimpeded operation of 5 the fuel transfer system. 6 There were a number of 7 problems and causal factors. We did not have a 8 specific notation of this activity in the schedule ' 9 and this led to inadequate planning. This is 10 probably one that triggered a number of other 11 problems. We had an activity scheduled that was- 12 related to the inspection of the fuel transfer } 13 ' equipment and all the things that are done prior 14 to flooding up, but it was one long activity bar 15 and there was a detailed procedure that went with 1 16 that. But the schedule is what people in other 17 departments use to focus on and see what is 18 upcoming and what they have to prepare for. So 19 this detail was a very important piece that was 20 missed. I 21 We also had inadequate 22 surveys. They were not current and they were not _ 21 good quality. Another key error was the fact that 24 we had a very pour quality pre-job briefing prior i 25 to.that job. Key things that were missed, the ) ! .-- . .. - - , .-
. _ _ _ . . _ . - . _ . _ . . ~ _ _ _ _ - _. _ . _ . - _ . _ . _ _. _ _ . . __, !
b
1
1 2 workers did not communicate to the HP techs a 3 clear understanding of the work that would be 4 done, and the HP techs did not communicate a clear 5 understanding of the radiological conditions, 6 again, in part because of the survey problems. 7 The result of that was that the HP techs did not 8 provide the proper guidance to the workers about 9 what they could and could not do in this area. 10 .The RWP did not provide all the controls. 11 NRC: Can you hold up? 12 LICENSEE: Sure. ( -13 NRC: It is my recollection 14 and my understanding in this particular event that 15 all that you say are certainly true, but my 16 understanding of the event was that when you 17 collect all the people that had some knowledge of 1 18 this work activity, no one had the complete i 19 knowledge of all that was going on. And I 20 understood that, you know, when you talk about a i 21 bar chart, that's kind of your outage or your 1 22 overall planning. They had an idea that an 23 inspection or something was happening 24 LICENSEE: There was a huge l 25 misunderstanding between the maintenance force and l
_ . . . _ ._ _ _ - _ _ _ _ , _ . _ . _ _ . . _ _ _ .
. . _ - - . - - , I 1 2 the HP people as to what they would do. The HP 3 people thought they would go in there, do a visual 4 ' inspection, make sure there was no debris. If 5 they would pick up anything at all, it would be 6 something that had fallen during this particular 7 outage and it would not have been contaminated, a activated, et cetera. They were prepared to let j 9 them do that. Instead, the workers went far 10 beyond that and picked up some things that were 11 contaminated, things that had been there from the 12 past. 13 Part of this involves a 14 misunderstanding about how clean that area 15 actually was, Jim. Our HP department had been 16 very successful in taking areas in the primary l 17 side and the PAB end and fuel building and 18 decontaminating them, making them accessible. And 19 they had cleaned the canal and put out the word 20- about that, and there was a misconception about 21 what " clean" really meant. And it really created 22 a situation where the workers thought it was fully 23 clean. 1 24 NRC: Who, other than the 25 workers, knew or were aware of the fact that the l l 1 .
. .
l l
. ; ( 75 ( 1 2 workers going in there were going to actually pick
i 3 up stuff and including regreasing one of the
i 4 mechanisms in there? Who knew that that was l 5 happening? ! 6 LICENSEE: Only the workers 7 responsible for that. 8 NRC: And was that a worker i ' 9 misunderstanding of the scope of the job that was 10 supposed to be performed? , 11 LICENSEE: No. That was a ' 12 detail -- in my opinion, that was a detail they l 13 didn't bother to communicate; so it was not a 14 thorough comte.anication. 15 NRC: So based on your 16 reviews, what you're led to believe -- or what you , 1 17 believe is the two folks that went down in the l l 18 cavity thought that -- knew when they went down l I 19 that they were going to do everything that they ! i 20 did, or at least they knew they were going to look I 21 at things and they were going to pick stuff up. i 22 Is that what you understood?
l 23 LICENSEE: Probably what <
24 they were going to pick up might have changed as
,
25 they went along. I would say they didn't really
! 76 1 2 intend to pick up any contaminated activated 3 material. 4 NRC: They didn't think so. 5 But they thought clearly they were going down 6 there to pick up loose debris. 7 LICENSEE: If there was 8 something in the way, they would pick that up. 1 l 9 NRC: We're going to spend a 10 little bit of time with this because that was 11 principally what I wanted to talk about.
{} 12
13 I understand that also at least one of the workers. moved some grease or 14 regreased some of the transfer mechanisms or the . 15 up-ender mechanism. 16 LICENSEE: That's correct. 17 NRC: Now, how did that 18 person reconcile that? Did that person believe 19 that since HP had cleared the whole unit, that 20 included things like that? or is that a 21 knowledge, skill or ability failure? j 22 LICENSEE: I believe that's 23 more of a matter of past practice and the level of 24 detail that's relayed back and forth between the 25 work groups, to be honest. I don't think he saw ! l I
. . . _ _ _ _ . _ . _ _ _ _ . _ _ . . _ . _ _ _ _ _ _ . _ _ . _ _ _ _ _ . __ , 1 i 1 , 2 any harm in doing that. He saw the need to do it 3 and felt it was within, you know, the scope of i I 4 what he -- again, his understanding of the work 5 scope. 6 NRC: Control -- 7 LICENSEE: I think-the 8 cleanliness you can't underestimate. These 9 gentlemen -- the word was the cavity is clean. 10 Remember, Jim, in previous years you're down there 11 in plastics, respirators. It was a huge deal to
l
(} 12 13 go into a cavity. First of all, they did a very good job of cleaning compared to previous years.
l 14 Then people had gone through without incident for ; ,
1
L 15 a number of months. We had developed an incorrect ' 1 l 16 mind-set about the radiological conditions there.
i 17 NRC: My view, though, is 18 from my own personal perspective. Walking through !
l 19 areas of plants that are supposed to be clean, I ' I 20 have in the back of my mind that it's clean to a
l ! 21 certain extent. You have to be real careful about
, 22 what you're doing. It's clean to walk through. 4 l '
23 It's not clean to climb up. A number of plants
lO 24 have an eight-foot level. I've gone up in the
25 overhead. I know that that's not necessarily part
l
_ _ _ - - , _. -
- .- . - . - - - -. - . _ _ - . . . - . - . - . - - . .- __ . - - . - (~'g 78 (/ 1 2 of this clean idea. And certainly it excludes 3 picking _ things up or going in places that are not 4 necessarily in the normally traveled ways. 5 So if that's just because 6 I'm an NRC manager and I don't want to cause a 7 problem to the facility that I'm sensitive to 8 that. So was there really a rad worker knowledge 9 and skill deficiencies in both of these folks? 10 LICENSEE: These were both 11 extremely experienced people, people who have been T 12 through activities like this with us many times , 13 before. I believe, as Jere said, that there was a 1 14 significant misconception about how clean that I 15 area was. -16 NRC: I had heard also --
! '
17 Ron, maybe you can correct me -- that there was
l
18 some suggestion that the folks manning the control'
19 point at the cavity really didn't fully expect 20 this activity to occur, or there was some issue on
l 21 what they thought was happening or when they
22 thought. Is that true or was that just an
'
23 early --
I 24 LICENSEE: That's a weekend
25 issue of what Jere spoke of earlier.
l
!
(~) (_/ 1-
79 ' , 2 NRC: I have a distinct 3 recollection that these folks walked up to the 4 control point, and I guess it was contractor HPs 5 manning the control. point, and they looked at i 6 these folks and it wasn't what they were told was 2 7 the. schedule of activities. I may have been' 8 wrong. 9 LICENSEE: No. It came up 10 that morning, on a Saturday morning. That was the 11 first notice that HP had that this activity was 12 going to be done. 13 NRC: And they let them l 14 through anyhow. ! 4 15 LICENSEE: They accommodated 16 the work. That's another issue that culturally is ! 17 part-of the problem. 18 NRC: Their job is to 19 provide access versus control, which is what 20 someone else said. 21 LICENSEE: Yes. 22 NRC: One of the things that 23 you talked about was the miscommunication between 24 the rad folks and the workers on the cleanliness 25 here. How well did the HP understand the -
('3 80 () 1 2 conditions themselves? 3 LICENSEE: There were
L 4 surveys that show that there was contamination.
5 And from one individual to another, I've got to 6 think that the management people had a clear 7 understanding, but I can't attest that every HP 8 tech involved had a clear understanding. 9 NRC:
4
See, this is the very 10 reason we needed to talk to you, frankly, and that 11 is -- I'll tell you honestly, when this was {} 12 13 playing out, wh" 1 it played out, Ron Nimitz and Bill Raymond wara doing the reviews on it. I was 14 honestly thinking about, gee, although it's not a
.
15 day-to-day type of activity, certainly these type 16 of activities happen every refueling; so they've 17 occurred in the past. I grant you you may have 18 changed the mode that you did it, but it's not a 19 completely new or novel type of work exercise from 20 a maintenance and a radiation protection 21 consideration. 22 I was actually worried about 23 what the hell is this saying about your ability to (s- 24 maintain the plant and respond to problems in the 25 plant at that time, or ones that would ensue even -
_ _ . _ . . , . . . _ .._ _ _ _ _ _ _ _ _ _ .-___ _ _ _ _ ._ _ ._. ._- . - l ! 1 2 subsequent refueling activity, and what actions I 3 had you taken to do that. Because what I saw were 4 clearly -- these are, in my view, fundamental a 1 5 problems, very fundamental failures of the 6 individual and the individuals' parts that caused 7 this to occur, which also suggests what you've ; l 8 done in need for a management reaction to it, to ! 9 identify why that is the case. 10. Would you agree that these 11 are rather fundamental errors that were made that 12 apply in any mode of operation of a facility, 13 whether it's now or decommissioned?
l 14 LICENSEE: Yes, sir.
15 NRC: It's not necessarily 16 decommissioned that you're going to be confronted 17 with high dose jobs. 18 LICENSEE: Right. 19 NRC: You may have to do l 20 things now, whether planned or emergent kind of l ! 21 things. l 22 LICENSEE: This is not one 23 of those. And these were experienced people, too. 24 NRC: I think, if you would, 25- please, the thing that's been wrong with this -- - .. , . .-- . _ _ . _ . .. _ - -
! ! ; : i ; 1 i .I 2. and Jim and the rest of us have looked at this -- ) ! 3- and you mentioned the word " mind-set" earlier. In- l 4 my recollection -- I've read your independent 5 review team report. I think they address some ! 6 aspect of. mind-set. I don't see it referenced i i 7- here yet. But this canal was decontaminated in 8 August of '96, as I recall. j i 9 LICENSEE: Right. l 10 NRC: The survey was done 11 upon that decontamination. When I was up on the
( 12 site, and I think Ron was up at the site, one of
13 the things we noticed was that the e was a lot of, 14 upon the completion of that activity, for lack of 15 a better word, I'll use a celebra'. ton cf sorts. 16 This was some sort of a historical event, that 17 something of major epic proportions had occurred '18 relative to that cavity in t.he fuel transfer canal 19 that would now allow, for the first time in the 20 history of the Haddam Neck. plant, people to go 21 into that canal in that area with the. standard 22 issue of protective clothing, cloth covers, a pair j 23 -of rubber gloves and boots, and no respirators. ; 24 And I think that was even demonstrated by the RPM 25 at the time, and maybe another RPM supervisor who - . . __ _ _ .
_ _ . _ . - _ _ . _ . _ _ . . _ . . _ _ . . _ _ _ _ _ _ - . _ _ . _ _ . _ _ _ _ _ _ . .
I I i , !
1
i l
2 had actually walked the rails or walked into the , !
l -3 cavity upon completion of that decontamination to l
l
l 4 demonstrate to the world at that time that this
5 was was a clean area. 6 What's your assessment? Is
i
7 that the mind-set that was created by your own 8 organization, that this was a clean area? I mean, 9 they're demonstrating that this area is clean. 10 Because we've been struggling with this ourselves.
1
11 How would the senior techs, the senior workers 12 themselves, your maintenance supervisor and your 13 refueling specialist, people who had been in your 14 plant for years, how could they make such a 15 disastrous poor judgment regardless of what the 16 communication was between the HPs and the workers? 17 How could they make such poor judgments about the ! 18 conditions of that cavity? Can you address that 19 or what you've learned so far? Because it's 20 important relative to where we go from this point
y 21 on in terms of how that is set up and how that's , V i 1
! 22 corrected.
i. 23 LICENSEE: There's no doubt : I 24 that they miscommunicated and overstated the !
25 condition of the canal and that that led, to a
l'
_ _ . - - _ - _ _ . . _ _ _ . . _ . __ - _-- __
~ . .- -. .
' 84
(Q_/ 1 2 great extent, to people being willing to go down 3 there and do the activities that were conducted on
- 4 Saturday, November 2nd. How they came to have
5 such a poor understanding of that, well, this job 6 did catch them a little bit off guard. You know, , 7 it wasn't somet1.ing that was scheduled to be done 8 that day. I've got to hope and think that if we 9 had the organization intact during the week when 10 this came up, the re would have been initial 11 surveys, we would have seen the need for 12 respirators and further cleaning, et cetera, , (j~T \ 13 before the activity took place.
.
14 But I will agree with you 15 that certainly the HP department miscommunicated,
i
16 to some extent, that they had cleaned this place 17 up and respirators were not required. I agree
,
18 with you. 19 NRC: I want to get back to , 1 20 that issue. Maybe I'll just state the concern 21 now. Another thing that was certainly in my mind 22 and a number of other managers in this region at 23 this time is we saw, as this event became -- as we O k/ 24 learned more and more about the event, we decoded 25 it and unraveled what happened, at least from our l .
85 1 2 perspective, those of us that were involved fairly 3 deeply in the nitrogen event saw -- I don't know 4 if you want to call it similarities or analogies. 5 We saw -- at least at the top we see an analogy of 6 what appeared in the past to be folks that could 7 successfully do a particular activity now, all of 8 a sudden, made some fundamental errors in the 9 conduct of an activity that wasn't particularly. 10 unique. It's like Ted described it. You don't do 11 it every day, but it wasn't any type of a special (} 12 13 event. That was disturbing to us, too. What that did to us, in my , 14 mind, was it raised the bar. It raised the 15 standard that I think Haddam Neck had to achieve ! ! 16 in terms of providing additional interim controls j t 17 or measures to basically, you know, do something j 1 18 to get control of this thing, which is essentially 19 what I think you did when you communicated in this i 20 letter to us. You basically stopped a lot of l 21 things and put a real restriction on what was j 22 going to occur, so everything could be I 23 individually micromanaged. 24 But we're still, like Bill 25 was suggesting when he was talking about the
- . . _ _ _ .. , -. ..
_ - - _ . _ _ . . _ __ . _ _ _ _ _ _ - __. __ _ _ __ __ . . _ _ . _ . - _ _ b (~T 86
, s/ 1 1 t i
2 mind-set or the different performance based on . . 3 when things are getting management's attention and '
l L 4 when they weren't. We were worried about that. !
! 5 I'll put that out there. You can comment on it l i 6 now or you can continue with your presentation. j
i '
7 That was what was running through my mind and a ' 8 number of our senior folks. Now we're looking to 'I 9 say, we're next. If we see this thing happen now,
.
10 and if we see something analogously happen in i ) 11 supporting this type of a maintenance and rad con. 12 problem, where is the next thing we need to be j
,(}
13 concerned about? 14 LICENSEE: It is a standard l
'
15 issue across the board. It's a lot of areas. 16 That's why we need to communicate and reinforce 17 higher standards and put more controls on to 18 satisfy that the standards are understood and 19 ingrained in everyday work. 20 To answer John's question, , l 21 it is the workers' responsibility to have a survey ' 22 that is accurate, to know that there's
i l 23 contamination in the area regardless of what the i
24 company newspaper might say. When we're going
l l 25 into an area and we do work, you need to read the l
l . - . - . . .. -. .,
87 1 2 survey and understand what the situation is, and 3 to know fundamentally that picking up paint chips 4 is not necessarily allowed in these situations 5 that exist radiologically. 6 NRC: Let me also state, and 7 maybe you can consider this. We don't need to go 8 in a long discussion about it. I see it's not in 9 the rest of the agenda. When this nitrogen' issue
10 came about, we understood that. Then when this 11 issue of November 1996 came about, we learned what 12 we learned through that. 13 Like I had said, w'e know 14 about that stuff and that they can address'that. 15 We know that they can address that. Then you 16 start thinking, what could possibly happen now in 17 the plant. It was shut down. It was clear that- 18 you weren't going to operate soon at that point. 19 What are the more sensitive areas that otherwise 20 don't appear as sensitive because Operations 21 technicians overshadow the security? 22 I'll give you examples in 23 plants where they had the same thing of access 24 versus controls have come out causing a 25 significant_ program breakdown in one plant's
_ _ _ _ . . . - _ __ _ 1
2 security operations to the point where they let a
,
3 few people in that shouldn't have got in in the 4 facility and were late to react to that. That ;
'
5 specter came up in my mind in addition, because 6 you start looking at the plant conditions and 7 saying, especially after all the spent fuel pool 8 issues in John's presentation. 9 But what other things are of 10 interest? Well, security. Do they have the right 1 11 to look here? And actually, fire comes out to be ~T 12 a more interesting situation to look at, fire (G 13 protection, fire brigade activities. Those type 14 of things become more important, because if you ' 15 look at the types of work that you're going to be 16 doing at some point, whenever you start to do a 17 lot more work, there are going to be a lot of fire 18 initiators. I'm sorry. 19 LICENSEE: Industrial 20 safety, environmental. 21 NRC: Yes. That's where my 22 mind was going. I just wanted to bring that up 23 because it didn't appear to be in the [x- 24 presentation. 25 LICENSEE: The breakdowns we
__. . _ . . . . . _ _ _ . _ . _ . _ . _ _ _ . . . _ . . - _ . _ _ . - - . _ . _ . . _ _ _ _ _ . _ _ - . _ . _ i
.
I
1 i , l
1
l 2 saw in the Labor Day event in the nitrogen !
s 3 intrusion, we had a big focus on operations and i 4- operational issues. This was a wake-up call in
5 that those same kinds of common problems existed
i 4
6 in our HP program elsewhere, management oversight,
j: 7 from a big picture. So I think we've stepped
8 back. We've looked at both of these events and
!
9 there is a lot of commonality. We've got to fix
l I 10 things on a broad spectrum here. 1 -
1
- 11 NRC
- Okay. Is it going to ]
i i 12 touch on the other areas like security, fire, ! }
- 13 environmental? Will you touch on that, too?
i 14 LICENSEE: We will touch on i 3 15 that, too. We're not going to be discussing that i
- 16 today.
d ,
17 NRC: That's fine. You've
3
18 got to understand where some of us were coming
l
19 from. This seems to point a finger that, hey,
4 j 20 there seems to be some questions that should be
21 asked. i
, ] 22 NRC: Before you go on, I
- i
; 23 have one question I had to get in because it's
- ,
! 24 really related to something we've been talking < i
j 25 about and talking around, and that had to do with
'
a (
s
e- ,..w. ~ ,i-.w - .w.-- ,.-r
-- ....- - - -. . - - - -. -- - . - . - . . - - 1 l , 1 l *
O 2
2 the control of activities. You mentioned 3 accountability of the workers in an HP context. 4 But I think there's another. You said the workers . ! s 5 showed up there and they didn't understand the i 6 scope of the work. I think that suggests to me 7 there's a process problem. How did the work get - 8 scheduled? I haven't heard you address that. Are ; 9 you going to be addressing that? l 10 LICENSEE: Let me cover a - ! 11 couple things now. There were a number of causal l ., 12 factors. When we looked at those, we found that l 13 there were some things that were almost cultural , 14 in nature, part of the way we were doing work. 15 The schedule didn't have the detail it should have 16 had. We didn't have pre-job -- good pre-job I 17 briefings. And that wasn't one department. That 18 was the normal across the station. Some were 19 better than others. 20 We didn't see the detail in- 21 the procedures in every case. In some cases the 22 details were probably missing because we didn't 23 think we needed them; we had enough knowledge. In 24 other cases, we wanted a little flexibility. We 25 are going after these causes with solutions that
. . - _ . _ _ _ ._ . _ _ _ _ _ _ . . _ _ _ _ _ _ _ . _ . . . _ _ . . _ . _ . . . . . - - _ - .
l ) '
, , 1
,
! 2 apply across the station. We are making a serious l
t 3 effort. ! 4 I've met with everybody on i 5 the site to bring them the lessons from this event 6 and also to begin to tell them what the new , t 7 expectations are as far as pre-job briefings. 8 We've got a new procedure. It involves a ; We're ' 9 checklist that every department has to use. 10 putting a lot of emphasis on it and we're going to j
l
11 keep driving the message home. 12 It's not just a matter of
,{
- 13 changing procedure. We're out there watching
l
14 people and are going to keep working with them
l
15 until they understand exactly what we want, until
,
16 we get exactly what we want. And even after that
l 17 we're not going to stop. It doesn't matter if
l 18 it's fire protection or security or anything else. 19 What we're doing applies across the board. It's l 20 the basic things we do, how we communicate, how we
,
21 schedule, how we conduct pre-job briefs, those
! 22 types of things that are inherent to all the i :
23 different departments doing work on our site. And ' i, ' 24 I'll cover a little bit more of that as we go 25 along. i ! -- - -_ .. .__, - _ - -_ . . _ _ ,
? ! l /\ 92 , 1 i f 2 LICENSEE: As I said before i . 3 or started to say, the RWP did not provide all the [ 4 proper controls. In this case, if you wanted to , i 5 work in an area that was contaminated at that 6 level, it should have included respiratory 7 protection or perhaps more cleaning prior to when i 8 the work began. We had an inappropriate air ! 9 sample location which was not adequate considering 10 the people moving around. We noted some 11 procedural deficiencies and some procedural 12 noncompliances. A very significant item, we had
-{~}
13 very poor weak event management. Though we were 14 in a high risk condition, we did not restore i 15 access to the cavity quickly. Our disorganized 16 and ineffective response to this problem resulted 17 in being in this high risk condition for the 18 additional 15 hours. 19 NRC: Backing up to that l 20 inadequate air sample, you're probably going to 21 use the canal again in the future to handle some 22 of the highly irradiated reactive vessel 23 internals. You may cut them up in there or at v 24 least transport them through that same area. Is 25 it'too early in the game to be considering future
- - _ - . . _ . ~ . - - . _ . - . . -. - - . _ .. - - . . _ . . - . . 1 2 work that may be done in the canal? 3 LICENSEE: Well, I'm not 4 sure I understand your point. 5 NRC: Well, for instance, i I 6 you may remove pieces out of the reactive vessel, ! i various internal, and you may want them to end up ' 7 8 in the fuel pool. -9 LICENSEE: Right. So we I 1 10 ship them across via the transfer system. l 1 11 NRC: Right. And these will 12 be highly irradiated pieces. You'll have to do it 13 under water. You may even do some cutting in that 14 area. And I was just wondering if you need more 15 air monitoring, more air sampling. 16 LICENSEE: Yeah. I think 17 the solution, based on what we saw, was if we're
I
18 doing that type of work, we need lapel monitors or l 19 something that would actually give us a more ! 20 accurate description of what the people were 21 seeing, what they were breathing. ! ! 22 As far as, you know, the i
i
23 transporting of components and things like that,
,
24 that's a part of the plan we're building this j 25 year. I don't know whether we've used that avenue __ _ ._ _ .
m . . _ _ . _ _ _ _ _ _ . . _ _ - _ . - _ _ _ _ _ _ _ . . . - _ _ _ . - _ . - _ _ . ~ _ _ . _ - _ _ . _ _ _ . _ . . . _ _ ! , 1 1 2 or not. Some of those parts are pretty. big and, l 3 of course, the fuel transfer system is a fairly ) 4 small cross-section as far as moving things up. 5 NRC: Right. It was just 6 designed for fuel elements, fuel assemblies. 7 NRC: Let me ask another 8 question on the RWP. You talked about inadequate 9 controls. Were the radiological conditions 10 adequately reflected on the RWP? 11 LICENSEE: No. l !
{} 12
13 Next I'd like to talk about some of the Short-Term Actions that we took. When j l 14 I say Short-Term, I mean things done on a one-time ; l 15 basis rather than programmatic. Two workers were 16 restricted from accessing to RCA. We've j ; 17 commissioned root cause investigations. We l 18 provided some refresher training to all of the HP 19 techs to some of the matters related to this 20 event. 21 Work outside of our normal 22 schedule now requires the Unit Director's 23 approval. We implemented senior management
O 24 coverage on a 24-hour-a-day, seven-day-a-week
25 basis until we've completed offload. The Unit
l 95 1 2 Director has restated his expectations and 3 standards for the entire site and I have 4 specifically restated my expectations to the HP 5 department. One of the biggest changes there is 6 the control objective versus facilitating work and 7 performing work. 8 What I had seen in this 9 _ event and what became very apparent when we looked 10 at this was that for quite some time the HP techs 11 had been very focused on helping to facilitate
{} 12
13 work and had actually been overseeing some decontamination work. And we have gone back to, 14 and I have emphasized with them on several 15: occasions now and will continue to emphasize, they 16 can help people, they can facilitate when they're 17 in the planning and preparation stage those things 18 that should happen days prior to the work 19 activity. But on the day that the work activity 20 happens, they are to control, and control, and , i 21 nothing but control. And I've talked to them j -!' 22 about, you know, this is a new habit they have to 23 form. It's not going to be easy necessarily.
r (~)/- 24 I've asked them to help each other. I've talked
25 to every worker in the site to explain that this !
_ ... _ _ _ _ . - _ _ _ _ . _ . _ _ . . _ . _ _ .- _ . . _ . _ _ . _ _ _ _ _ _ _ . . - - . : i' i
l ,
1 '
-
2 change is going to take place, asked them to help. l
t- 3 We're heading in this direction. We should be l
4 there now. It may not be a habit yet, but there's
4
l
- 5 enough~ emphasis on it that that's the mode we're
a d j 6 in. ) 7 NRC: What kind of reaction ! . 8 do you get to that? q f b 9 LICENSEE: It was. funny.
10 The HP techs understood. It took a lot away from 1
i
11 their pride when this happened. They're still
j
{} 12 13 feeling a lot of pain from this; so that didn't bother them. And I told them that I didn't blame
! 14 them for what they were doing. I thought that
j 15 they were still following the direction, what } j 16 management'either told them to do or allowed them f. 17 to do. So I didn't want them to think that it was
j 18 their fault. They are coming around to this. l !
- -
.
19 Some of the other workers ,
1
20 ' asked, "Well, what does that mean for us? Are j
- 21 they going to be holding us up on jobs?" And I
a
- 22 said, "
Well, They'll hold you up if you haven't
i
- 23 done your work to plan and prepare. But if you've
- .
E 24 made the effort to communicate to them ahead of l 25 time what's going to happen, told them about the l } .
_. 3 y , ,. .y 1.-- - - . - . _ m . w._, -
.___ _ _ _ _ . _ _ . _ _ _ _ _ _ ..-_.- _ . _ _ . _ . _ . _. _ _ . _ _ _ _ l l 1 2 nature of the work, let them contribute to the 3 plan and preparation, it will go smoothly." 4 So that is really a part of 5 our overall emphasis on planning and preparation 6 and communication. 7 NRC: It has the potential ~8 then to set up some confrontation there. 9 LICENSEE: One of the 10 operators asked me if that meant that we're going 11 to have HP holding us up on every job like it was 1
'
12- 10 years ago. My answer to them is what I just (~} ! 13 told you, "No. If you talk to them ahead of time, 14 you tell them what's going on, they have some 15 notice and they can prepare for it, they will help 16 you. And on the given day that the work happens, 17 there will be no holdups." We've actually seen
l 18 that. On the activities that we've allowed to
19 happen, those jobs have gone very well. 20 NRC: These expectations 21 'that you just stated for HP personnel, are those
'
22 communicated and understood by the office and 23 maintenance?
, ,' 24 LICENSEE: All of what I
25 just said I have communicated to everyone on the
L c- -. .. -- - - -. -- -
. - - - .,-
. ._ _ .. _ _ _ _ . - _ _ _ _ _ _ _ _ _ . . . _ _ _ _ . _ . _ _ _ . . _
i 1
- 2 site, in individual department meetings, in work
- - 3 group meetings. And we're going to keep following
'
4 up on that and keep driving it home. I've covered
e
5 that material many times with the HP people.
' ,
6 LICENSEE: Bill, when you 1
4
7 said you've seen this, you've seen this at other
{ 8 sites or locations? Obviously, we were concerned , f 9 about that when we went in that direction. But ! 10 their job -- 4
- 11 LICENSEE: To the negative
12 or positive, because some conflict is good? It
J
13 keeps good --
- . 14 NRC: Just be careful that
l 15 you don't take that comment to the extreme. We've
l 16 seen it from running the chronology backward, i 17 where the HPs did view themselves as the control i 18- to the point of being the cop-type function, and
19 there was continual persistent conflict between
} 20 'those HPs and other parts of the regular operating
l 21 organization that was divisive and actually ended 2
22 up'as one of a whole slew of reasons. { 23 LICENSEE: We lived through b 24 some of that.
'
25 NRC: Same thing applies to
'
., _ , -. - . ._ - .
_ . . _ _ . . _ - . _ _ _ _ - _ . . _ _ _ _ . . _ _ . _ . . _ _ . _ _ . _ _ . _ _ . _ _ . _ _ . _ _ d
4 i
;
<
. 1 :
0 2 security. They have a-role-and they need to ,
3 . recognize'their role. If they go too far j
1-
)
. 4 overboard on it, that's also another problem. Any
' ' ;
, 5 time you make these changes, you can expect I 4 ' i
6 there's going to be some oscillation around the l l 7 norm that you want to reach. There's going to be
i ! 8 some overachievement and some under. But you'try -l
9 to keep the amplitude of that oscillation down to
-
10 a minimum by dampening it out real quickly based , ! 11 on the controls and oversight. And be really
l i 4
12 careful about watching what's going on and make [
l 13- sure it's playing out the way you hope. ,
14 - --
{ +
15 (Recess.)
l
- 16 - --
l1 17 NRC: I guess while we were l 18 off the record during a break, the Licensee and 4 [ 19 the NRC worked on a bit of a remaining agenda plan h 20 for the balance ofLthis meeting. And that agenda l 21 would be to conclude the discussions on the Health
22 Physics issues, and then to discuss Nuclear !
.
- 23 Oversight and an Emergency Preparedness, and then
1
1
f 24 the summary.and closure of the meeting. And the.
i
25 Licensing / Design Basis of the meeting, I believe j
-
i
i
,- , - . .-- . - - , . - - - - - ... - - - . . , - . , . - - - -
-. . . . - . ~ . - . ~ - . - . - . - _ . - . _ - . - . - - - . . - - - . - . - . _ -
9
!
i 4
1 - ;
J C ;
~ 2 that may be a topic better suited for a specific ' 3 meeting on that issue that we would consider and
'
4 set up separately.
.
5 We're in agreement with
.
6 that, right? 7 LICENSEE: Yes. 8 NRC: So we'll continue with 9 the HP, please. 10 LICENSEE: Okay. 11 URC: We are on slide -- 12' LICENSEE: We're still on ( 13 Short-Term Corrective Actions. 14 NRC: Before you leave the 151 slide, I'd like to ask a question. If you plan to 16- discuss it later in your presentation, I can wait. 17 But the other aspects that we were concerned about 18 is the dose assessment. Our observation in this 19 particular event was that because there was a 20 propositi of data available, a lack of surveys 21 available, there wasn't a lot of information on 22 which to base the dose assessment on. 23 However, this is our 24 impression -- and I want you to know where we're 25 coming from -- there was evidence, in our _ _ _ . - . _ _ . _ , _ .- . . - _
. . _ _ _ . - _ _ . _. _ _ _ . . _ _. i i i 1 ! 2 estimate, that.after your technicians and your I 3 management was aware that there was some sort of a '4 high-airborne contamination or airborne i 5 radioactivity involved, that that was not 6. immediately assessed directly. And as you 7 indicated before, Mr. Bouchard, that this is a 8 very complicated, complex effort to assess the : 9 exposures of these two workers'because of the I 10 nature of.this exposure, the type of information l 11 that would have been necessary to do that, such as 1 12 the bioassays, fecal sampling, that type of effort ( 13 was not initiated until days after the event had l 14 occurred, which makes the effort even more complex 15 and difficult to get back to the estimate of i 16 actual dose assessment. l .! 17 I looked ahead in your ! 18 slides. I don't immediately see a. bullet for 19 this, but it is an important aspect relative to i 20 our view of this event, and if you have some -21 information in terms of corrective measures or how 22 you assess your dose assessment response. And if 23 you would identify some improvements there, we ' 24 would appreciate hearing about that. j 25 LICENSEE: There are some
_ _ . __ , . _ . . _ - __ _ _ ._
,
[h V 1 102 2 minor things in my presentation; so let me go 3 through that, and we'll come back to that question 4 at the end, if you don't mind. Would you like to
4
5 cover it now? 6 LICENSEE: I think I can 7 address it. A couple things. First of all, the 8 bioassay, we're really talking about bioassay for 9 alpha, because we did some pretty quick bioassays ' 10 as far as the beta gammas go. So one of the 11 things we're doing is we're going to have fecal
, ; 12 sampling at a much lower threshold than we've had.
13 The other thing we're looking at is when we get 14 into some of these higher risk environments, is 15 doing some really good characterization of the 16 contamination, sending it off, getting it analyzed 17 ahead of time before we start digging into some of 18 the activity areas. Does that answer your 19 question? Does that help? 20 NRC: I guess you may want 21 to elaborate on your task force that you've 22 involved, the alpha exposure control task force, 23 for the folks that are coming from Yankee and (\ ') 24 Millstone. And they're developing that program. 25 That's the kind of thing we're looking for.
m. __ . . _ . _ _ _ _ _ _ -. _, -.
'
i ! )
I i !
.
i 103 ' (x 1 l l
1 l 2 LICENSEE: We do have a task 1 l
,
'
, 3 force in place that's made of people from ! l i : 4 Millstone and also Connecticut Yankee and I
J !
. 5 -corporate staff. And they are supposed to have !
~
: 6 recommendations out, yes. l'
4. I
, 7 NRC: And that's to address !
1 l 8 that issue on the dose assessment. i .
9 LICENSEE: That's correct. l
' 1
10 That's still one of the corrective actions that :
} ' f 11 I'll come to eventually in this presentation. ! . '
12 NRC: Let me ask just one - !
-
13- question on the fecal analysis themselves. These
! j 14 were done by a company called ThermoNutech (;ph) , I
- 15 guess.
4
_ 16 LICENSEE: That's correct.
I j 17 NRC: Have they been doing i 18 work for you before? i 19 LICENSEE: That is the first
- 20 time they did work for us, as far as I know.
, 21 NRC: Okay. What sort of , 3 22 quality control or acceptance did you submit to i' # 23 them? i /^T 4 (/ 24 LICENSEE: I really can't
3
25 answer that exactly. We did do a quality
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- - . - . _ . - . - . . . . - _ - - . . - . . - - - - . - . _ _ _ - . - . . _ - !
' l~ ! ' (~ l) 1
4 l 2 assurance check with them, but I don't remember i ! : 3 exactly what we did. I ! 4 NRC: On alpha? l ! 5 LICENSEE: Yes. l 6 NRC: And transuranics? ;
t 7 LICENSEE: Yes. We did ! *
8 address the quality assurance issue.
l
~t 9 NRC: So you did some level i 10 or some sort of acceptance review of them as being i !
l 11 capable of doing an analysis report? ;
! 12 LICENSEE: That's right. 13 NRC: At some level. ' 14 NRC: This was prior to 15 accepting them or was this at the time? I 16 LICENSEE: This was at the , 17 time. 18 NRC: We'll probably come 19 back to this after some more questioning later. 20 LICENSEE: Okay. Another l 21 Short-Term Action, I imposed a restriction on
!
22 gaining access to do work in the high rad areas. 23 This really constitutes the majority of the areas
, 24 not only that are high rad levels, but are any l
25 substantial amount of contamination. This ._- .-- - - - _ _ - _ _ _ - . - - - - - _ - .
. - _ - . . . . - . - . . . - . - . - . . _ ~ . . - . - _ _ - . . . . . . . _ . ~ . . _ . - . . - . _ ~ . . . - . - . . . . . >
. .
. 1 !
i 1 2 restriction. continues.
3 I will say that this is
- 4 working well. It gives me an opportunity to meet ;
E 5 with the people that are going to perform work and ,
6 the HP people involved prior to actually having
' 7 the work scheduled. I review whether or not the
,
8 work really needs to be done. If I can, I try to
i 9 put.that off until some of the other corrective
10 actions in the HP area are completed. If it is 11 going to go forward, I make sure.that all the
I
{} 12 13 planning and preparation steps have been taken and that the work is going to be performed without any
2
14 other. kind of problem.
f
15 This has given me the
a 16 opportunity to actually reinforce our expectations
- 17 again, as far as planning and preparation. This
! j 18 will stay in place until we have all the 1 j 19 corrective actions from the IRT implemented. And ,
20 then the HP manager is going to have to justify to
i
- 21 me that I can remove this restriction above and
.- 22 beyond those corrective actions. So I anticipate
j 23- that that.will be in place probably for a couple
i
! 24 more months at least. ?
25 I held a number of lesson
- , ,.__, . . - , _ _ . . - , , . . . . _ . _ , ... _ _ . _ . . . - . ._ _ . .
! 106
-
1 i 2 learned meetings, as I said earlier. These were- 3 very effective in communicating to people what we , 4 did learn from this event and what some of our l j 5 expectations are for the future. I've asked Jeff 6 to conduct an effectiveness review. That's'a 7 two-part review. He will very soon go forward and 8 -look to make sure that everything we said we would - 9 do has been done. He'll then come back toward 10 midyear when we've had some time to let these 11 things sink in and verify that they are, in fact, 12 effective. 13 Another Short-Term Action at 14 the time we pulled back the RWPs, we reviewed 15 them, we updated them, made them better, included 16 appropriate rad data, deactivated the ones we 17- didn't-think we needed to use. 18 Before I go on, I want to 19 make sure everyone understands. When we first had 20 this event, there were some people that thought 1 21 this was a one-time slip, that we still had a very I .l 22 good HP program and good staff. I want to make i 23 sure you really understand that that is not our 24 impression; that this event revealed a number of i 25 weaknesses. We know our program has slipped and ' _. -_. . _ _ -. . _ _ _
-. -- . - . . . . . . - . - , - . . - . - . . . . . . - - _ .
. I t i 1
- (" 107
' \,)) 1
2 has degraded and we need to get it back up. 3 That's the stance we're taking and the position 4 we're looking at, the actions we're taking. So
I
5 we're not going to just go out and do what the 6 independent review team identified as corrective '
i 7 actions. We'll do more than that. That's a good
. -
8 start. That's what we'll do first. And then '
j 9 we'll continue to look across the entire' program, ,
10 across the entire staff, and find out what else we 11 need to do to make this a topnotch program. 12 In the area of Long-Term
j
} 13 Corrective Action, we have reviewed and upgraded ;
i l 14 our philosophy on RWPs. We do include survey
15 information on the RWPs now. Crossing over to
,
16 other RWPs is not allowed. That was something
. 17 that occurred on Saturday, November 2nd, part of
18 the reason there was a problem. Specific RWPs are
- 19 required for all tasks with unique radiological
'
20 conditions. 21 RWPs and surveys are being 22 reviewed at pre-job briefings, as I said before. 23 We are developing and will be using a radiological ! 24 risk assessment procedure to define and control 25 high risk evolutions. We have developed a survey
1
r .. _ ._ ,_ _
._. _ _ . . _ . _ . _ . _ - _ . _ _ - _ _ - _ . _ _ _ _ _ .____ - . . . . _ _ _ _ . _ E ! : i : ! t () 1 , ' 2 matrix for routine surveys. This determines the i 3 survey frequency to general access to RCA ] 4 locations based on a number of variables. 5 Specific pre-job surveys are required for all high
l 6 risk evolutions. And as I said, survey data is on
7 the RWPs and available at the control points. 8 Being able to quickly access
j 9 documents is important, and we need to do better 1 l
10 in this area. The management of survey records 11 has been transferred to the HP Services Group. 12 -They will be revicaing and upgrading our 13 recordkeeping process. The ALARA Coordinator will 14 participate in evaluation of high risk work, not 15 just high dose work as in the past. We will
1
16 review cur confirmatory monitoring program. This i 17 will be used to verify our air saarling program is l
l '
, 18 adequate. We will do more samples and we will ) i 19 target those high risk jobs. 20 NRC: Just to clarify, 21 you're using the term " risk" as radiological risk? 22 LICENSEE: Yes,
f 23 NRC: As opposed to the !A 24 other risk issue about overall plant? )
25 LICENSEE: Radiological,
I -
, _ -.
._ . _ .. _ .. _ .... .. . _ . _ . . _ . _ _ .. .. _ _ _. _ _ _ . _ ___ _. _ _ _ ._ _ . _ ., ; ! I 1 . 2 yes.
, 3 We are working to' improve i ! l L ,
4 rad worker culture and knowledge. Our lessons
l l 5 learned meetings have taken a good step in this
1 6 direction. Obviously, as I said before, this is
L.
7 something that is going to continue to be an issue
- 8 for us. It's an area where we're going to have to
9 continue to provide emphasis and a lot of
I
10 interaction with higher management and the 11 workers. (} 12 We're also continuing to 13 clarify our' expectations to the HP Department. i !
j .
14 Again, the biggest issue here is control versus 15 facilitate, but there are a lot of other things, 16 the details of procedures, the quality of l
l
17 procedures, the compliance of procedures.
l 18 In the area of procedure
19 quality and adherence specifically, we have a i 20 assigned HP techs to be subject matter experts, i 21 giving each one certain procedures to be i 22 responsible for. Their initial charge here is to
! 23 develop refresher training, and.then they will go ,
24 on to be responsible for the maintenance of these ! 25 procedures in the future. ! l _ . _
. _ . _ - . _ _ . __. __ _- __ -_ _ . _ . _ _ _ . _ _ _ ._ _.. __. _ _ _ ; ; i 110 l / 1 ! i 2 We have developed standard i ; , 3 briefing books for certain high risk jobs, and : ;
j 4 we'll add to this as we go along. !
i 5 " Clean" is a term that we're t i 6 not using. A key point in the lessons learned , !
L
7 meetings, to both the rad worker population and ' ! 8 the HP text, that this is not a way to describe an f : 9 area in the RCA. There are numerical values. I 10 Everybody needs to be developing a habit to use { ; 11 those. If the workers, rad workers were ' i 12 accustomed to hearing " clean" or " contaminated" or 13 some other general term that's vague, they need to .14 get very quickly adjusted to hearing numbers, 15 because that's what they're going to hear. 16 We've eliminated the 17 practice of qualitative field counting of air 18 samples. We are now using only the counting room 19 equipment, which is obviously a higher and better ] 20 way to do that. Respiratory protection will be 21 used in all high ISbk alpha areas until all
l 22 airborne conditions are known and determined to be I I l 23 acceptable. As I mentioned before, we are ( 24 upgrading our air sampling program for alpha,
25 using industry data and a task force of people
!
., - . -
() 1 111 2 across our company. 3 NRC: One question on the 4 surveys themselves. I assume that there's more 5 communication via the job planning here, so that 6 what the surveys are specific for non-routine type
.
7 jobs, so that they know what the worker intends to
.
- 8 do and can zone in on areas of particular concern,
9 as opposed to giving a general room survey and
i
10 missing what, in fact, the worker's likely to do. 11 LICENSEE: That's true. And r 12 what we're seeing is that the HP Department is 13 rising to the occasion. If they are not prepared, 14 don't have the surveys, they tell the-people they 15 can't do the work. They tell them when they can 16 do it. They go get the surveys. They're ahead of 17 it. 18 We have the HP people fully 19 engaged in the planning meetings. They're getting 20 that.information through both the schedule and the 21 discussions that take place which are lower, less 22 significant activities. Those surveys are 23 happening before people do the work. 24 LICENSEE: I am requiring 25 pre-job surveys for any non-routine.
. _ . . . . . _ _ _ _ _ _ . _ _ _ _ - _ _ _ _ . - _ _ _ _ . . _ . . . _ _ . . _ : .
l. 112 l 1 { l l :
2 NRC: And they are ! ! 3 job-specific?
l 4 LICENSEE: They are {
5 job-specific, that's correct. 6 LICENSEE: We've developed a
L 7 matrix that you'll see on these next couple of i
8 slides. I only put it here to show you. I'm not '! \
l 9 going to read through it. This is helping us to
l ,
i 10 make sure that we have all of the corrective ! 0
11 actions compiled in one location. It also is ;
!
12 enabling'us to make sure we have some_ good }
- 13 programmatic solutions for everything, that we're
t
14 not dealing with just one-time solutions for these
! 15 certain areas. I'd like to think that.this is
16 going to give us a very effective way of compiling :
l 17 and integrating all of these specific actions into l 18 one much better program.
19 I'd like to talk a little 20 bit about staffing, because along with all the 21 procedural and programmatic changes, obviously we
- 22 have to have a good HP staff to continue to make
< l 23 these effective. And we are committed to doing i i j 24 that. We also are counting, at least initially,
25 on having a very effective oversight organization
.
_ _ - . . - - .
. . - - .--- -.- . . - . .----_-- - . - . - . . . - - .
, e
I () -1 ! 2 to second check us and to help us as we build a ! l 3 stronger program.
!
I 4 Our ongoing selection !
!
5 process that is a part of establishing the
J
6 decommissioning and interim organizations has
,
7 given us a good chance to recheck the capability 8 of the individuals in our supervisory roles in the
i
9 HP department. We've made a couple changes there.
j 10 We have a new Radiation Protection Supervisor for i 11 Operations, we have a new supervisor for the Rad 1 [ 12 Engineering Group. A couple of the other people
13 have been retained in their current roles. But 14 this is a good overall check that we have the
j 15 right people.in these important positions.
16 We recognize that HP is very 17 important to decommissioning as we go forward. If 18 you look, we have not significantly reduced the l 19 staffing. We are cutting back on a couple of rad j 20 waste technicians based on anticipation of less 21 waste in the next year or two. But essentially j 22 this department is intact and will stay that way j 23 throughout the decommissioning. 24 As I said, oversight is 25 another important element here. Jeff will talk
114 1 2 about it more when he talks about oversight, I 3 know, but I want you to understand the connection ! ! 4 here. We have a certified health physicist in the i 5 Oversight organization, as well as a couple other j ; 6 people who have different kinds of certifications 7 in the HP area. This has'been already a very big ! 8 help to us. They have taken part in the meetings 9 that I've held that have required a lot of work, 10 particulary in the high rad areas; they're out on 11 the jobs; they're in the pre-job briefs. They're ; 12 giving us already some very, very good feedback. . 13 I guess, in closing -- and : 14 I'd still be happy to answer any questions you - ; ' 15 have -- but I hope you understand that we know we 16 had an event here and it was a significant l 17 problem. It could have had potentially an ,) 18 overexposure. We were fortunate that it wasn't 19 that. We believe we understand what caused this 20 problem. We think we have a good plan to correct ) 21 the weaknesses that were identified. We are 22 committed to having a topnotch HP program again, 23 and the people in that department will be working
) 24 to accomplish that in the shortest possible time.
25 NRC: Just one question _ _
. _ . _ . . . _ _ _ _ _ _ _ _ - _ _ _ . _ _ . _ _ . . _ . _ _ . _ . _ _ _ . _ . _ _ _ . _ .
l
! ; , ;
l 115 l
1 2 here. In the HP area -- maybe you're going to be :
i 3 covering it in the oversight. But didn't you have r
; 4 any sort of recollection or anything coming out of i 5 the oversight self-assessments that are done out 6 of corporate office of the program that you may ; 7 have some weaknesses in the program or slippage? : 8 Any indications of where you're going? l : 9 LICENSEE: Prior to this l 10 event? I 11 NRC: Yeah. l l ,
,
12 LICENSEE: There was nothing 13 that was enough to trigger any kind of management - 14 attention. 15 NRC: Have you looked at why 16 not then, and what you need to do with that 17 process to make sure? 18 LICENSEE: Well, I think 19 what he we've done is brought in people who are 20 experts in this particular area, and then given 21 them directions to spend an appropriate amount of
l 22 time on that subject. So I think we've done that l l 23 maybe without consciously thinking through it. 1
( 24 We've recognized that we didn't have a lot of ; 25 expertise in that area and we brought them in.
l
_ _ _ .
_ . _ . _ _ _ __ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . . _ . . _ _ _ _ _ _ _ _ _ _ .
J
, 116 5 1 '2 NRC: I think there is a '
3 legitimate question here that we could put on the 4 table, or anyone could put on the table and say, 5 you know, you do a lot of activities that are 6 required by either us or by your internal 7 controls, in terms of audits or surveillances of 8 activities, self-assessments, whatever. And the 9 intent of all those is to provide you insights 10 about performance or the adequacy of programs and 11 ability of the individuals to carry them out to ; i 12 meet your. expectations. I guess what I hear is ' 13 that none of those ongoing programs brought you 14 anything that you can latch onto as a valid 15 precursor of that event. Is that what I heard you 16 say? 17 LICENSEE: That's what I 18 said. And I shouldn't ignore the value of looking 19 at that more seriously. Obviously, we'll do that. 20 But my opinion at this point is that we didn't 21 have anything coming from the oversight i 22 organization previously that was enough to trigger 23 any kind of concern on the part of management. 24 NRC: And that's what 25 precipitated Bill Raymond's question. That's .
117 1 ! 2 certainly something that should be asked, is "Why ) ' 3 not?" 4 LICENSEE: I know Gary 5 indicated that maybe it was unconscious or 6 subconscious that we brought in people with a lot 7 of radiological HP experience, but the fact is we 8 did change out manager of the quality program 9 on-site. That was my action. And he did, in 10 turn, bring in a team with HP experience, 11 recognizing the seriousness of this issue, the i
(} 12
13 fundamental breakdown, the fact that they had not screamed and yelled and brought it to our j l 14 attention in the way they should have. i 15 Now, like Gary said, I think 16 we need to go back and look and see -- there were 17 messages sent, but they were not strong enough and 18 consistent enough and reinforced enough to make 19 something happen. That by itself is a problem. 20 NRC: And it may lead to 21 other areas. There could be a lot of questions ' 22 raised-in terms of we could have asked that 23' question about the nitrogen and what we were being
O* 24 told by your own people that you're supposed to-
25 provide the managers some insights as to early
a l 'l !
O' 118
- 1 l ; 2 signs of things going astray, what happened there. 3 And you certainly have these other support areas 4 that, as I've mentioned before, you wonder what -- ! ! 5 it raises a question of whether you're really ; 6 getting the quality of information you need to 7 take prompt action to address issues before they , 8 become real glaring problems. -j 9 LICENSEE: And the purpose 10 of changing the makeup, the charter, if you will, 11 of the offsight board is the same purpose, to load ,
(}
, 12 it with people who are heavy in environmental and 13 fire protection and safety and radiological i i 14 control so that they can watch not only what is i 15 happening in the plant, but watch what Oversight , 16 is doing, as well. This is a good segue to you, I 17 Jeff. : 18 NRC: One other follow-up on 19 that is have you determined that, in fact, the 20 organization hadn't identified issues? Or, in 21 fact, have issues been identified, not I 22 communicated in the right place, or have they been 23 communicated and simply not acted on? Have you
O 24 made identification here as to what the cause is?
: 25 LICENSEE: If I go back into i
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1
; 119 l 1
i
i 2 ' the way the organization, the quality organization , t 3 was set up in the past, and take a look back at t
4 some of the past audits that they've performed, i 5 they were really basically more programmatic j 6 oriented. They did not get down into the ! i 7 performance-based, getting to look at how the i 8 program was implemented in the plant, and spending ] 9 more time out on-site; and then throughout the 3
> L i
10 course of the year, performing a number of i 11 surveillances that would essentially feed in or ! 12 provide an additional basis for.where you should. 13 go and look when you're doing your programmatic l
,
1
l 14 audits. That was really not all tied.together. I
15 In fact, for the HP area, it was literally 16 nonexistent, or a very, very small number of any (
l 17 small audits that were performed. ' i I
18 NRC: So it was sort of a
l 19 compliance with requirements on it, as opposed to
'
1 '
20 the assessment of program? 21 LICENSEE: Programmatic,
- 22 that's right.
.
23 NRC: I have a few things we
- 24 need to get back into. Let's reopen the issue of l
25 dose assessment. When we were talking about that, i ,
. . . . . -.. - - - . . . - . - - - . .. - . - - - - .. _.-
. , ,
- C) 1
2 I heard from your staff -- and I think I can agree
- 3 with you that this is a fairly -- it's not a
l 4 simple deal. It's not a simple activity. There's j "
i 5 some sophisticated stuff that you have to get into l 6 to make the correct call. I guess that leads to a
j 7 question I really wanted to get your answer on. ? l
8 Are you confident you have 9 the necessary knowledge and skills in your
. 10 resource set in the area to make those types of ; i i i 11 calls? Have you looked at that? Is your skill ! i
{} 12 set sufficient with the folks you depend on to 13- make those dose assessment calls for events like i
14 this? Do you believe they have those skills you l
,
15 need? 16 LICENSEE: I believe they 17 have some good quality people. We have some
4 18 certified health physicist people at CY. We have i
19 access to some at Seabrook, as well. We did in
!
20 this case reach out to a couple of gentlemen from
, 21 Lowell University. We don't intend to let go of ;
22 that link. We will have them available and i .i
J 23 probably access them more in the future. That's
24 what we would like to see done to check. 25 This is the kind of thing
. - . - . . . .. . .. .- ... .- _ _ - _ - - - . _ . - . - - - - - . - - - - !
i
J
i 4
- 1
2 where the entire outcome can change dramatically 3 based on the assumptions you make when you start
i
- 4 into this calculation. There is no set procedure
j 5 for how you bill those sets of assumptions. And
l 6 regardless of the quality of a person, I think in
7 the future we're going to see we want this thing
l 8 double checked. And if it is a potentially
9 significant problem, we want to see it checked
2
10 with'an independent party with some very good 11 credentials. I'm not personally concerned that we 12 don't have good, capable people. I feel we do ( 13 have some.very good people in the company. ,
- 14 NRC
- It is true that we -- l
l 15 principally Ron, who is also working the issue -- l 16 we got ourselves inserted quite early in the dose l 17 assessment piece relative to NRC space. We were 2
18 here since we heard about it. But I recollect -- 19 isn't it true, Ron, that at least one of the
20 individuals, the contractor individual who was in l
j 21 there, had already left the site and was somewhere } 22 else? I kind of remember Ron tried to track the i 23 guy down. l
- 24 LICENSEE: One of the 25 contractor HP techs had already left the site. 'We
_. . . . - _ _ . _ . _ _ . _ _ _ _ _ _ _ . . _ _ . _ _ _ . _ _ _ _ _ _ . . _ . _ _ _ _ ,
-
. i
2'
i !
-
:
122 ! 1 2 were ,ble to access him and talk with him. i
-
t
3 NRC: I don't recall, so. ! < 4 I'll ask you for my information. Did your. ! - , 5 organization have control of the two individuals : 6 who potentially were exposed to amounts more than : 7 they thought and quarantine them until they sorted 8 it out? !; 9 LICENSEE: I do recall we l 10 did restrict them from the RCA. ! ! 11 NRC: Was that done when you l 12 guys first got involved? Or was anything done 13 back in the 15-hour or so time period, . prior to 14 the time it got percolated up to you? This is a l 15 valid question because -- 16 LICENSEE: Are you saying 17 was that done during the first 15 hours? 18 NRC: Was it done during the 19 period of time your individuals got involved. ! 20 LICENSEE: The people that i 21 were there at the site that day, did they restrict j l 22 them? ! i 23 LICENSEE: Yes. They were j O 24 essentially restricted. They had intakes. They 1 25 couldn't actually pass an exit monitor. !
123
- 1 ,
2 NRC: Let me clarify that' . 3 They were restricted because they went'into the 4 RCA and they couldn't get out of the RCA without l 5 alarming the monitors due to the intakes. Are we 6 looking at the intake assessment three days or 7 four days after the event? And by that time at 8 least one of the individuals had been permitted to 9 reaccess the'RCA without a proper dose assessment. 10 NRC: Do you agree with 11 that? Do you accept that as -- 12 LICENSEE: Let me clarify. 13 They're' initially barred from the RCA. At a point 14 three or four days later when Ron was there, 15 they're able to pass through the exit monitors. ! 16 We allowed them access to the RCA. And then the i 17 issue came up that we have possible overexposure. ! 4 18 Then we barred them again from the NRC. In that l 19 period of time, it was about a day. 20 NRC: But did you bar them ) 21 after we got involved in this or did you bar them 22 based on information that your staff -- that's ) 23 where our involvement gets fuzzy in trying to back ) 24 out our influence over your action. It was fuzzy 25 from here, because it looked very coincidental. _ . ~ .
1 i
.(s -
1 124 -! i i 2 When Ron actually went up and started probing- ! 3 on-site, there was a guy who was let in and'now ! 4- ought to be brought back out again. 5 LICENSEE: We clearly didn't 1 : 6 see the overexposure at the time until Ron -- or i 7 potential overexposure until Ron had brought it to l ! 8 our attention. That's when we learned of it. , 9 LICENSEE: That gets me back { : 10 to the original question. Are you confident that l 11 your staff in this activity has the requisite 12 skill sets to make those type of reasonable calls, 13 or do they tend to be a bit conservative, not l t 14 ultraconservative, but to make reasonable calls on i 15 how to do these dose assessment models? What i 16 should we assume so that we don't get a repeat of i ; 17 this? Or are there guys let in until some i 18 questions have been asked by outside parties, and 19 then basically you've got to call the person back 1 20 out again? 21 LICENSEE: I think the ' 22 assessment was fairly close. I'm not concerned 23 about that. It sounds like what happens after an
.
t 24 assessment, we need to treat things more ! 25 conservatively, allowing for the fact that it
. . . . . . . . . - . . _ _ - _ _ _ . . - . _ _ . _ _ . . _ . . _ . . . . - _ _ . - . . _ _ _ . . . _ _ , ) , l l 1 2 could be more, until we are confident. I don't 3 think it's the assessment itself that I would 4 question. 5 NRC: Yeah, but -- 6 LICENSEE: Maybe how we 7 react, how we respond after we have that 8 information, if it is in fact an inhalation or ; 9 something that requires follow-up. 10 NRC: Well, the assessment, 11 if I may, was based on an air sample that was {} 12 13 taken -- the folks that did the assessment did an air sample that really, in our opinion, wasn't ' 14 representative of breathing of the highest air 15 sample. The individual.who performed the 16 assessment really didn't recognize the significant l
.
17 potential for transuranic intake in the canal
l 18 until we brought that to their attention. l 19 I guess the question Jim is I
i 20 bringing up, in terms of the capabilities and the l ! 1 21 expertise, is one week prior to that event there
, 22 was a signific. line organization change within ! l 23 the HP organization. In fact, the rad engineering i
24 manager, who normally I think would spend a lot of 25 time looking at it,.became the acting RPM. There 1 l , _ , , - _. . - _ _ _
1 l ) i 126 i 1 l . 2 was a technician that was upgraded to the existing 3 rad post supervisor. So I guess there are some 4 valid questions in terms of when something like I 5 this does occur, pending whatever corrective ! 6 actions, who is going to be in charge of, in fact, 7 assuring that the assessment is adequate based on l ! 8 immediate work area surveys or appropriate ' 9 assumptions or if those surveys aren't available? } 10 That's the question. l 11 LICENSEE: Okay. Your point I g 12 is that although the assessment, the final 13 assessment is done by the independent party, it l 14 came out close to the original assessment. Until ! 15 we had completed that review and had full ' : 16 evaluation of all the parameters, it may not have j 17 turned out that way. 18 NRC: Correct. 19 LICENSEE: And to be more 20 conservative, we should have barred people until 21 we thought that through. We need to do an 22 independent review. Is it sufficient what we've 23 done? And I can see the point. I definitely can
,
N- 24 see the point. 25 NRC: You can understand l
127 1 2 where we're coming from. We don't have all the 3 data you folks have,.the way this sets up 4 chronologically. You can imagine if you were on 5 our side of the table, you'd have some questions 6 about this. 7 LICENSEE: That would have 8 been a wrong call to let them back in. 9 NRC: Yeah.
10 LICENSEE: I'd like to 11 answer this from a real-time standpoint. Your 12 point is valid. Let me tell you, we are not 13 there. We're not going to beat our test and say 14 that we do have the best dose assessment. I 15 believe for the activities we will engage in until 16 we have a manager on-site and we're able to 17 improve the programmatic deficiencies identified, 18 that not through having any strength in this 19 area -- I don't think that we're horribly weak, 20 but I don't think we have the strength that we 21 should have -- what we'll do is we'll meet the 22 challenge. The same thing in the weakness in 23 planning in other areas. 24 LICENSEE: Back to the 25 standard issue again, conservative standard. I
. _ .
.. . .. 1 2 think going out to the third party at Lowell was 3 the right thing to do. And Ron raised some good l 4 issues that caused us to think about that, but we j 5 should have done that ourselves. We should have 6 done that ourselves, and we should have, if we had 7 the right standard, barred these individuals from 8 going back in till that was done. A point well ; 9 taken. 10 NRC: One other question on 11 the report. You submitted the third party report. 12 Did that receive a critical review by our own dose 13 assessment folks? l 14 LICENSEE: Yes, it did. , 15 NRC: So you agree with 16 everything there or don't agree with some of it? 17 LICENSEE: Yes. As a matter 18 of fact, we went back and forth several times. We 19 didn't agree with some things or we had some
I
i 20 questions that needed to be clarified. '
! It took a !
21 while to get that report to where we accepted it. 22 LICENSEE: The Chairman of 4 23 our Board of Directors Nuclear Committee was very 's- 24 interested in that report, and I sent to her a
!
25 summary of it. She was very interested.
i
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,
! 1
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1 2 NRC: That's also a general 3' theme you probably continue to hear from us, is 4 when we go out to an outside expert, there's still 5 a need for the Licensee to take a look at that at j 6 some level to make sure an outside expert didn't . I 7 make a mistake, at least in the assumptions and 8 models and that what this analysis looks like '9 actually matches the conditions of the plan. 10 LICENSEE: I just want to 11 say she is a certified health physicist, so she is (} 12 13 qualified. NRC: l And I do know the 14 people here. I've worked with these guys quite 15 often. 16 NRC: So on that piece, I 17 think we ought to also note we also want to do 18 more work on the ingestion of the transuranic ] 19 piece. And we'll get some help from headquarters i 20 people to do it. 21 Any other dose assessment l 22 questions? I want to move to a couple more i 23 points. I want to follow up on a point that he , O 24' made. When you've had this external work done by ! 25 anyone, really, an analysis performed by, you ; ; . _ - -
_ ._.._ _ _ . ____...____m.____._ _ . _ . _ _ _ _ _ . _ _ _ . _ . . _ . _
.
? i
13
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(:) 1
l 2 know, a piece of equipment, it's important that
3 you look at that with healthy skepticism. And a 4 good test is if the answer comes back as favorable 5 to you, do you look at it with the same degree of 6 skepticism as when it comes back unfavorable, with 7 an unfavorable answer? A lot of times these 8 Licensees get a favorable answer from a reputable 9 contractor, they just jump to, Okay, we're happy; 10 and then you have another party come in and take a 11 look at it and find some fundamental flaws with (} 12 13 it. So is it tested and being reviewed with the same skepticism? I ! \ 14 Let me see if I can get both ! 15 of these out at the same time. If we go back on 16 slide 39, one of the conclusions was a Weak Event 17 Management. That's certainly one of the 18 conclusions you reached in the nitrogen: You have - 19 something occurring that wasn't expected. Once it ) 20 was identified that an unexpected condition ! 21 occurred, then why? And things didn't happen the 22 way we would expect them to do or you would expect l l ' 23 them to do. So there seems to be another one of 24 those type analogies there. It's now two data l 1 25 points, which you may have a more broader issue on
i
() 1
i : 2 response to unexpected events. But if you find a ! i 3 hole in the fence or a dugout out of it, how does ! : 1 4 that make its way through the organizations and 5 people react to it? If a fire starts, how does l 6 that make its way through? That's how we -- : 7 LICENSEE: That was a real I 8 disturbing aspect on this thing. And people will l l 9 identify stuff, but there was no escalation on ' I 10- real-time. It happened on both of those events. l 2. It was a glaring issue. I 12 Basically we stated our 13 expectations in writing, told people face to face. l 14 And I've tried to give the example, everything is ! 15 getting escalated-immediately now. That's the way ; 16 it has to be, escalated to me. l \ 17 NRC: Until you're confident j 1 18 you've got folks where you want them. l ' 19 LICENSEE: Maybe forever. , 20 NRC: Let me ask another ! 21 spinoff question. Let's just particularly look at i 22 the restrictions that you've put on work control 23 or, in particular, the rad con. What would happen . l 24 if there is a need to do something that ends up ! 25 it's not an emerging issue, but an emerging event? _
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<Q(/- 1
132
l 2 How would you expect your staff to react? Would l
1 3 you expect them to continue to hear this and make 4 sure that that won't preclude a prompt action to
l
5 remedy the situation, or would you 'npect that 6 they take this and immediately understand that
,
7 this wasn't written for this condition and go off, 8 which has down sides also? 9 LICENSEE: I'd like to 10 answer that. First of all, I would expect to know 11 about it immediately myself, or the director -- we 12 always have a director who is the duty director. } 13 One of us is always in the area 24 hours a day,
I
14 seven days a week. My expectation is we would use 15 his guidance for everything except an immediate i 16 fight a fire type of casualty. 17 NRC: That was one of the i 18 things in my mind, a fire and charcoal filtration ' 19 system, something like that. : 20 LICENSEE: In those events, j 21 quite honestly, Jim, the operators are trained. I
! !
22 think, as you well know, they have to sift through
l l 23 priorities in the events. I'll go back to the i j' 24 best example I can remember was the Rowe event in l
25 1992, where they had a fire. All at the same time i
.. _ .- . - . _ _ _ _ _ _ _ ._ _ I' I 133 (_-) 1 2 the shift manager had to make some decisions. I <
.
3 am confident the shift manager would fight a fire 4 and make sure they protected the safety of that 5 fuel in the pool, and that he would take this into 6 consideration, but he'd have to weigh his options . 7 as the field commander. He's your representative. 8 NRC: I don't want to make
,
9 recommendations, but I'll tell you, if I were in ; 10 your seats, from my point of view, looking at 11 these two events that occurred, I'd be damn sure 12 that the key people in the organization there all ( 13 the time running the facility for you understand 14 clearly what your expectations are on this
4
15 particular issue. One of the down sides, whenever 16 you restrict things, is you don't know what people 17 think about what you really meant by that 18 restriction. And if you want them to be able to 19 take prompt action to stabilize the situation, you ! 20 need to tell them that; you need to go into some j
] 21 way of describing what you mean by that, so you i 22 don't end up with, you know, someone inadvertently
- ,
23 getting caught. "I don't know what to do here. k- 24 I've got this one memo that says restricted. This i 25 other thing indicates I ought to take prompt l
,e~.
134
k- 1
l 2 action." You get freestyle then. God knows i 3 what's going to happen. ! 4 If you haven't done that, I 5 really recommend that you kind of think that 6 through and maybe have some discussions with your 7 staff to make sure that the key people on the ! 8 shift and various organizations, that they're all l : 9 on the same sheet of music on this and understand ' 10 exactly what you expect from them. I agree with 11 you. I expect that someone has to make a judgment
(T 12 and you have to make a judgment of the gravity of \_/
13 the event to decide whether you have to react 14 quickly to stabilize conditions or if there's 15 enough time to be in a huddle. 16 Typically, in operating 17 events, you know there's things you can't wait to 18 get a huddle on to get a procedure on. And then 19 there is some time in the sequence where you can 20 eventually call those other folks to come in to 21 get some help. You never know. I just think it's 22 imperative that you folks clearly understand what 23 your vision is if those things occur.
('T k/
- 24 LICENSEE: It goes to the 25 tension between micromanagement and controls,
.. - -- - - - - _ . - .. . - - . _ -
"
i
! 2 , 1
2 controls we put on versus giving Operations
'
3 flexibility.
4 LICENSEE: We'll check that. 5 I came from the Operations background. They've :
-
6 pulsed us on these letters. They've asked
'
7 questions, but I've not explicitly covered the ' 8 situation. We'll take a look at that.
i 9 NRC: Give them a situation l 10 and see what they would do. Come up with this ! 11 fire type of thing and see what would you do. See 12 if it matches your expectation. That would be a {} 13 test. And if it does, you can go into a 14 discussion about why it does. 15 LICENSEE: I think they 16 would give the right answer. We'll check. l ' 17 NRC: Anything else on.HP? 18 NRC: One thing. I guess 19 when we were up there last, one of the questions 20 we brought up was in terms of the work restriction 21 memorandum. It basically spoke of high radiation 22 areas. And what we wanted to emphasize was not 23 only did it include high radiation areas, but the n/ N- 24 alpha areas, transuranic areas. And the reason 25- we're bringing this up is mostly the systems you
, l l l
r^ 136
, kT) 1 l 2 have that are high rad here, they have the alpha
3 potential there. But the transuranics has a
l 4 propensity to incorporate into corr'osion films.
5 If you had transuranics migrate through the
l 6 primary system, it may not be in the area, and you
7 could have transuranics incorporated in the 8 corrosion film. If you try to get a survey, it's 9 not there. Assuming the first guy strikes -- 10 (inaudible) boom, it's airborne. So I think we 11 discussed that last, that even though it doesn't 12
'
appear to be in an area that you've met, you can 13 take a look at that. Or any primary system that 14 does have --
j 15 LICENSEE: If they do hot
16 work or anything that could cause airborne 17 potential. 18 NRC: It's not currently on 19 this list. 20 LICENSEE: There are a
l 21 couple of things we're considering as far as
*
l
22 changes: the oversight, radiography on the site. 23 Joel had been looking at this one. We've got a g) ' 'w 24 meeting scheduled to talk about the radiography. 25 NRC: That seems fair. The
- . - - - . . . .. ~.- -- . . . . - . - - . . - . - . - - . . . . . . . - . . .
! l \
1 2 more you get out of follow-up to this type of j 3 event, you've just applied the lessons learned in ; 1 4 this type of. restrictions or whatever actions, 5 your interim corrective actions, short-term stuff )
l 6. needs to evolve to conform to the information ;
- i
L 7 you're bringing in. I think that's the general ' L l 8 description of what Ron said. I wouldn't q , 9 concentrate a lot on the specifics of it. That's l l I l
10 a general point.that seems like motherhood. As 11 you learn more, you learn more where the problems 1 {} 12 13 were, and then you have to take a look a your own actions in a way that people can apply in the
l
- 14 field and not some esoteric type of discussion.
l
15 Nuclear Oversight is next on
l 16 the agenda.
17 LICENSEE: Thank you. Let's 18 start off. I think last year for Oversight it was 19 kind of a traumatic year. Certainly we share in a
l 20 lot of the problems that occurred both at CY and
21 at Millstone for not having what I could call a 22 robust organization or being intrusive enough in a
i 23 lot of areas that we could either identify some j i O
\/ 24 precursors or perhaps delayed, you know why we
, j 25 were here today. We could have identified areas ! ?
l
i
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i i
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! ; -' ~ 138
, !
1 i
l >
2 th'.t clearly could have been brought forth to l 3 management. ! l 4 I think, looking back in ! 5 * hat, there.was an assessment that was performed . 6 back last summer, the independent assessment of l ! 7 Oversight. And then there was a joint utility 8 management order that was performed last summer 9 also. They clearly identified that there were 10 particular areas that needed to be enhanced or , 1 1.1 ugraded within the oversight QA organization, ; , 12 particularly in the expectations and the talent 13 and the ability of the organization to identify 14 issues, to' bring the issues up to management; and 15 then also for management to be able to take those
l
16 issues and march forth and correct them. 17 Those two documents, if you 18 will, kind of form the basis for the direction ! 19 that we are heading here. And the first thing l 1 ' 20 that we did is we took a look at the CY 21 organization. And we brought in some additional 22 people, knowing that we were going to be in a l
l 23 defueled state and we would be heading in toward I l f)- I s- 24 the decommissioning mode sometime in the future.
- 25 The key areas that we needed to address were in !
I
y- , -w -. - - g - ,.c% . ,e .- w --.y , w ,
_. . . _ - _ . . _ ,
- !
:
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> ) 1 1
. > i '2- the areas of Health Physics and was directly.after '
'
1 3 the November 2nd event. It was also
4 environmental, industrial safety. We needed
j I
5 particularly in waste management, which is going ! ' i
j 6 to be a big area in the future, we needed the j i
7 talent and the individuals with experience. So we ' 8 brought in.-- actually, we have four people, three 9 of them worked for Yankee, and the contractor who $ ! 10 currently works for us and who will be picked up. l ! 11 by Yankee. Atomic and who will be and are assigned l ! 12 to the site and work directly for me. We retained 13 three individuals from the NU site. We have one l ! 14 engineer an auditer and an inspector. I have one ! i 15 NSC, Nuclear Safety engineer and an I&C group ! ! 16 engineer working for me. And we also have.one i 17 contractor from combustion engineering who is a 18 holdover from the CMP effort. We have started to 19 gear up for that. And when that was essentially 20 disbanded, we retained his services to help in the 21 engineering effort as we go forward and look at a 22 lot of the engineering studies and changes, tech 23 spec changes, design changes, what have you, in 24 the engineering realm. ! 25 So it totals up to 10 i i !
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l l , 6
140 1 2 personnel on-site. As I said, the qualifications, 3 there-are a number of them. Our engineers -- we 4 have three of them -- are registered Health 5 Physics personnel. One is a certified Health 6 Physics individual. They are continuing to
l 7 provide daily support, daily assistance. We're
8 attending all the briefings. We're reviewing the 9 programs. We are involved on a daily basis with l 1 10 all the activities, key activities and on-site. 11 The qualifications that we i 12 .have, as I said, they have a lot of experience and 13 they-are not afraid to bring up issues and get l l 14 them forth and get them before management.
! 15 The audit and surveillance ! 16 process, we have promulgated in 1997 an audit l l
17 schedule that came out this week. Basically the 18 schedule is geared towards the current conditions 19 of the plant, but we are going to meet all our ; 20 Appendix B commitments, all our tech spec 21 requirements. And as changes are made in the : '22 future, then we will change and adjust our audit 23 schedule. 24 As we look at the 25 surveillance process, I look at it as a mini audit i . _ __ . - _ _ __
1
l
2 process. It's a process where it's more
l 3 performance-based than you may in some cases see
4 for an audit. Whereas if you're doing one 5 particular audit for a particular time, activities 6 may not be being performed that you can assess at 7 that particular time; so there's a window of lost 8 opportunity in any audit that may not be 9 available. However, throughout the year we.'re 10 developing an audit schedule that will be out 11 within a week or so that will address and look at 12 a lot.of activities that are either going to be-
,
' (")] % , e 13 event-driven or. scheduled during the year, that'we ! i 14 can actually go out and measure the performance ,
l '
r 15 and take a look at the activities that are 16 ongoing. We're already doing some of those
i
17 activities right now. )
i !
18 The emphasis -- and I really 19 do want to emphasize the three areas that we have 20 up on the board there. We are assessing 21 compliance with programs, procedures and 22 regulatory requirements. That's the bare minimum. 23 That gets us to where we want to be and in just in 24 the bare minimum operating space. Above and 25 beyond that, our reviews, our assessments are L
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c
l l s !
142 '
! i
. 1 -
l
2 geared towards assessing management's -- adherence 3 to management's expectations. I know Jere and i 4 Gary have been putting out a lot of expectations '
l 5 almost on a daily basis at the morning meetings. , L 6 They've clearly indicated to Operations personnel l 7 what they expect of them. And the Oversight folk, : l 8 the QA folks have been hearing that and they know l
9 what's expected of the Operations. If there's a 10 question in their mind, they bring that j 11 information forward. ! l 12 So we're looking at not only 13 hard issues, but soft issues also. And on a soft 1 14 issue basis, we'll be bringing them up to the 15 appropriate manager. And.if resolution isn't 16 forthcoming, it will go directly to the 17 appropriate director or to Jere. Or if I need to, 18 it will go directly to Ted. I have direct access 19 there. And if really all that doesn't get the 1 20 action that I feel I need, then I can go up )i 21 through the chain of command, up through Dave 22 Gable and the Oversight organization. ; i
l '
23 NRC: To whom do you report )
i
! t
i 24 directly? j t
25 LICENSEE: Directly I report
l !
_
l 143 ; l 2 to Pete Richardson, who is the Director of Perform ! 3 enhancement. He's based out of Millstone 4 NRC: So your reporting 5 level is above Jere? i 6 LICENSEE: Yes. It's ! 7 independent, completely independent of Jere. It's 8 through the Oversight organization. But when I . 9 say I report, I mean I report the problems to Jere
10 on his level. !
l
11 NRC: I'm not talking about 12 that. I'm talking about who is your boss? ;
.
13 LICENSEE: Dave Gable, the 14 Vice President of Oversight. !
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15 NRC: This is a little 16 bit -- my experience in reviewing classical audit 17 QA activities back 10 years ago, 15 years ago, and ,
!
18 even recently, is those things that are supposed ! 19 to be bringing management here insights are more . 20 bringing them issues, and they tend to be this
\
21 particular thing was wrong, this particular thing i 22 was wrong, this particular thing was wrong. But i 23 they don't often -- or they may say the program ; 24 has some problems. 25 But what seems to me the t
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! ! !
144 2 real -- there's something else about a quality 1 3 insight that those aren't it. You know, the idea j
l 4 of, hey, here is an insight that's a leading
5 indicator of an issue that there are some things 6 going on that the organization needs to address 7 before they manifest themselves in problems or 8 events. Whats your expectation personally? Is 9 that something you think your new organization is 10 going to be better at?
l '
11 LICENSEE: Definitely. I 12 think they're already doing that. The new
l
13 individuals are. We're working with the
l 14 individuals who have been there for a period of l 15 time to get them to understand that, you know, l
16 it's not just to tick off the individual problems;
j 17 it's really taking a look at what the individual l 18 problems are and what they're telling you overall i 19 about performance and about the way the
20 organization behaves in solving the performance. 21 NRC: Let me give you an 22 example-of that, because it's on your slide. If
'
23 you look at, I think what Jim is talking about, if U 24 you look at number 2, Review Performance To 25 Management Expectations / Standards, that's kind of _ ._ - _
_. ._ . _ . _ . _ _ . . . _ _ . . . _ . _ _ _ _ _ . _ _ _ _ . _ . . _ _ . . . _ _ _ _ . . _ _ . _ < i ; ( 1 i 2 a lagging indicator. You've found that they made !
i.
;
! 3 a mistake. I
- !
4 LICENSEE: Right.
l :
i
- 5 NRC
- Maybe the thing that's
' 6 more of interest is to review the understanding of
4 i l 7 the staff of management's expectations and 9 [ 8 standards which would identify maybe a problem. j i ; i
9 that exists in communications before it results in I
1' 10 a performance issue. I !
.
{' 11 LICENSEE: I think Tuesday j t i
12 we had an exact example of that. Jere had ( f 8
13 indicated to the operators over a period of time '
! 14 that if anybody had reservations concerning a
15 particular job, that they should bring that issue
- 16 forward so that the job would not, you know, go .
i i
17 forward blindly. Actually, the expectation would I
- 18 be that they would correct the problem.
- 19 The Oversight folk also had
20 some reservations. They went and talked to the
) 21 operators, found out the operators had some i
22 reservations and they were looking at it. We went
i 23 to Jere as a side, meaning Operations was also
24 going. So essentially they were coming forward on 25 some indications before the job had started to
i
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_ __ . _ . .. .-._ -- ___ . _ . ._._.~ _ ___ . _ _ _ _ = _ .
i. 4
O 1 146 2 bring Jere the information -- I'mean, to me -- to
. 3 Jere the information that, wait a minute, maybe .
4 there's some additional planning in this
. j 5 particular activity that needs to be done so'that 4 ,
6 the job is clearly understood by all and the 7 sequence of events that have to take place are 8 clearly understood by all, and there would be no
] [ 9 glitches in the job. That occurred on Tuesday .
10 morning. We were involved in some sampling and 11- manipulation of equipment. / 12 NRC: To me, the overall 13 area of management expectations is a very 14 important area, but some of it's harder to do than 15 others. It's necessary, but in the'long range 16 relatively easy, to develop an expectation. It's 17 relatively easy to articulate that at some level. 18 What gets a lot' harder is i 19 translating that expectation into implemental 20 actions that the folks down at the tech level need 21' to know that that's what they're supposed to do, j 22 this is what they do, and that meets this 23 expectation. That's where you really get the . 24 effectiveness kick out of that whole process. 25 They're effective when they can translate that
1 147 ) i 2 expectation into something that's real to them in 3 what they do. 4 That becomes an interest 5 area where a quality organization can provide that 6 insight so you're not always, like Bill said, 7 trying to look at performance indicators of 8 problems -- and we'll use root cause analysis -- 9 to say, Well, they never really got it, or they 10 didn't apply the standard correctly to this piece ; 11 of activity. Unless the things are seriously I ' ' 12 ; broken, most of the individuals on plant staff 13 want to do what managers want them to do. They 14 can have difficulty translating that expectation. 15 LICENSEE: I understand. 16 NRC: Which sort of leads 17 into, what are the performance indicators that you 18 have for your organization? 19 LICENSEE: Right now we're 20 in the process of sending out a number of 21 expectations. We've just pushed them out within 22 the last two weeks of what we expect of the 23 individuals. Pod-number-type performance
r
/ 24 indicators, we haven't developed them yet. 25 The organization has been in
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' 148 1
- 2 effect for essentially about a month now, since
. 3 January 8th. So we haven't progressed to the
4 point where we're looking at hard indicators, but
.
5 a lot of the expectations are that, you know, when
- 6 you identify issues, you identify problems, you
7 don't wait and wait until the job is over to bring 8 them forward; you bring them out right then and
A l 9 there; you are intrusive; you are an arm of I
I
- 10 management. You bring those issues up, get them
l 11 resolved to make sure that, you know, whatever is
12 needed is taken care of at that point in time. {
i 13 If I was to go back and look 4 ) 14 at specific indicators, one of-them that we're 1
- i
j
15 going to be looking at is audit responses; how I
- 16 well are the audit responses accepted; how well-is i
17 the information given back to us in a timely
l 18 fashion. We'll have a number of those relative to
19 the interface between, say, the line and
j' 20 Oversight. We haven't developed the hard ones l l 21 yet, though.
22 NRC: Maybe that partoof the l
.
23 table can address this. The oversight role going l C
j 24 to be performed for you is a very important ,
25- function. In fact, I'm glad I hear the depth '
1
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149 1 i
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. 2 throughout your presentation of what you're going i
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3 to rely on Oversight for, because that addresses a
j 4 concern that I articulated before about, why can ! ! j l- 5 you have any confidence that the day-to-day. stuff L
6 will go on. I think there's confidence.
i
- 7 But what do you see as his
i l 8 role? Is it mentor for the staff? Is it a coach? ,
\ 9 Is it a monitor? How do you expect his folks.to i . 1
L 10 interact with your staffs? Or is there a lot'of i
- o
11- monitoring and all monitoring, no' coaching? - Or l
1 '
r^s 12 mix and match? Or what? What are you really j Q' 13 expecting him to do? 14 LICENSEE: The Oversight's- 15 role, as I see it, Jim, it is definitely part cop. 16 There is a set of standards out there, and someone 17 has to measure and has to project those standards. 18 So you have to have that element. 19. Additionally I expect from 20 Oversight intelligence, not just_-- basically what 21 Bill was talking about. If Oversight gives me 22 nothing but you have 15 TPCs that were late by one : 23 day, that's really not very useful information. () 24 So they have to glean some intelligence of that. ; 25 In a mentor role, I think
i ! 1 . - _. . _ _ _ . _ . _ , _ _
; i ! 150 1 2 there's some room for that, but I'think you're 3 starting to cross the line of independence. : 4 You've got to be careful in that area. One thing 5 that no one's mentioned here on our side -- so I'm 6 going to segue to it, not quite answering your ] 7 question. One of the things that's changed'in : : 8 oversight, which I think you guys should be asking 9 and.I think I'm hearing, why is Oversight I i 10 different today than what you've been telling us l ! 11 in the last two years? i i 12 We had an Oversight
'Os i
13 organization that I would say the staffing was 14 pretty stable. There's a lot of new. insights i 15 coming in from the new faces of different l 16 ' organizations. If you'll look at the surveillance 17 reports that he's talking about, there are new 18 issues being raised. Well, that tells me'that we 19 are looking. They're willing to say if something i . 20 is good. It's-a balanced perspective. If there's- 21 something wrong, they say it's wrong. If there's l 22 something good, they say it's good. They don't 23 demoralize the staff. They give an accurate ) 24 picture. ! i ' 25 LICENSEE: And my
; i
( 1
2 expectations are I do expect the oversight ) 3 organization to coach and mentor up to a point, up 4 to a point where they don't cross the line and i 5 become part of the line organization. And I've ; i' 6 seen Jeff act in this role at Seabrook. He ; 7 coaches and mentors, and he comes up to the point. 8 But if they're not towing the line, he has the 9 ability to come up to senior management and say, ! 10 "Look, it's just not happening. I'm trying." And l j 11 he does this. i 12 In terms of my view, and we 13 have to talk about this some more on KPIs and 14 performance indicators, my view is that although , , i 15 you can develop some KPIs for your own group, that 16 overall, the same KPIs that we're looking at is 17 what I'm going to use to judge the effectiveness 18 of the oversight organization. If it's happening 19 in the field, if it's happening overall in the 20 organization, then they're doing something that's 21 working. If the indicators are-negative and not i 22 trending right, then there's something not right 23 in the Oversight organization, as well. We're not 24 taking action fast enough. So we're all going to 25 be using similar indicators. --
1 l ;
/ 152 l \ 1
2 NRC: I'm not suggesting 3 that these folks are your coaches and mentors. If , i 4 you needed that, there's a whole different 5 construct that you ought to be looking at. What ; i 6 I'm really looking at is if you play the card too 7 much on the independenceindependence front, two l 8 very adverse things could occur: A, you have a ! 9 really high conflict situation going on, to the 10 point that they can't do their job to get you what 11 you need because your folks won't work with them.
(~} 12 And the second is that if you play this \_/
13 independence to the extreme extent, it becomes 14 decoupled and they have no relationship in the 15 extreme. That's more of what I construct as the 16 old classic QA organization. Everybody emphasizes 17 independence to the point that they sat in the 18 building and they were working as though they 19 weren't a plant. 20 LICENSEE: That's not where 21 we are. I asked Jeff and his people to be very 22 involved in pre-job planning because we're trying 23 to emphasize more planning and preparation. They ,'~T (./ 24 come to the pre-job briefings. They come to the 25 meetings I'm holding with people before we go to
- . - . - . - . - - - - - - . . - . . . _ - . . . . . . - . - . - . . _ . . ~ . . - . . - - . f , , 153 l O- l' ' : 2 work in:the RCA. I told them you've got to give ; 3 us' feedback on'that.before we move to the next i 4 phase of the_ job. They've given us a lot of good 5 feedback. I'm sure it's building a good 6 relationship because it's intelligent. It's a lot 7 of' good information. - 8 NRC: I'm getting to the -9 managers down below the staff level. They need to 10 see that the organization is providing value. l 11 It's helping them rather than policing them. If 12 staffs get a view that these people are sitting 13 there because the mission is just to find that - 14 they screwed up and bring that forward, they're 15 not going to be real happy with that, _you know. 16 If it works healthy, there's enough_ interchange 17 down at your staff and the plant staff level that 18 they can see, yeah, they have a role, they've got
l 19 to call the shots as they see it, that's the
20 independence piece. 21 on the other hand, if your
, 22 staff sees that they're a vehicle that -- they're i. [ 23 one of the many vehicles that can express a .( i
24 concern, they haven't gotten to the level yet to :25 bring it up through the organization, it's another
i i !.. , - _ _ - , , _ _ _ _ . . . , . , - . . _
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1 i
j 2 outlet for them to say, Well, you know, I really '
3 don't understand how to apply this here. And i
, 4 that's not that bad. The person is admitting , 4 ' <
5 that, you know, there's a lack of understanding.
! 6 LICENSEE: They have I
7 expertise that.we can tap. )
j 8 NRC: That may tell you f:
- 9 something.
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4 . , 10 LICENSEE: But my comments
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11 come from an organization where, quite frankly,
1 12 we're a pretty strong team, family culture, and
13 inclusiveness happens pretty easy at Connecticut 14 Yankee.
-
15 LICENSEE: Which is part of
i 16 the reason we decided to bring in people from i
17 another organization. It's a positive and a l l 18 negative. ' . I 19 NRC: There's no easy 20 solution. ' , 21 NRC: Let me ask a question j 22 on the organization. Are you responsible for the j 23 tech spec audits, for example, of the ! () 24 environmental? 25 LICENSEE: Yes, that's i l )
155
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1 2 correct. 3 NRC: So your work is 4 essentially in the off-sight review committee, 5 stuff that was defined in the tech specs? 6 LICENSEE: Even though 7 they're defined in the tech specs, they always 8 have delegated the responsibility to perform the 9 audits to the audit group. And typically, in 10 Northeast, the audit group that was based out of 11 Millstone usually sent people out to do those 12 particular audits. And they would come in from 13 the outside. At CY we're going to control the 14 audits from the CY, for myself, and then we will 15 bring out some additional people as we need to 16 fill out the audit team to perform those audits. 17 So we're controlling from CY. 18 NRC: I just wanted to 19- understand the organization. 20 LICENSEE: We're changing 21 the philosophy on who does it and when we do it. 22 NRC: I'think we spent all 23 the time we can really afford on that. Obviously () 24 oversight is an important role. I'm sure we'll be 25 observing and measuring the overall effectiveness
. _ _ _ _ _ . _ _ . . _ . _ - _ _ _ _ _ . _ _. _ ____- _ _ . -. _ _.. _ _ . I f :
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() 1 l ' 2 of the performance of your organization there. ; 3 I think Bill's got a
4
4 constraint that he needs to leave. .
l 5 NRC: I'll take a quick ,
6 couple of minutes. If you can keep it high level.
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7 LICENSEE: Basically as Work )
j 8 Services Director, I am also responsible for.EP. !
1
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9 I'm the site director responsible. We have had a 10 couple of problems with our exercise this past l 1
, 11 year. There were two weaknesses identified: One { d
12 with classification using the EAL tables,.the
l 13 other with the Protection Action Recommendation.
i 14 We've commissioned the Root Cause. The director ,
15 committed to demonstrate effectiveness. We
f
16 docketed our corrective actions in a letter. l
1
17 One of the Long-Term Actions
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I
! 18 is to conduct a job task analysis of the SERO '
19 organization. That has been completed. We are
4 20 looking at the output of that. We've got a good l ,
21 picture now of where the overlap was as far as 22 classification of PAR tasks, and we're planning to )
4
23 work on the organization based on that. We're , 24 also going to use the task analysis for our future
( )
25 selections of people in the SERO organization. , _ .__ _
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1' 157 (, 1
2 Another action was to 3 conduct an analysis of' simulator utilization. ; 4 We've done this. We have determined that that is 1 5- effective in reemphasizing and teaching emergency 6 plan scenarios. We're going to continue that. As 7 long as we're using the simulator, we'll also be ~8 enhancing it to make some aspects of it more. 9 realistic, especially in the area of interference l 10 calls and. things like that that are distractions , 11 that haven't been provided before. 12 Another objective is to 13 train'those members of the SERO organization to -14 classify. We have trained people in three 15 positions. There is a training that's been 16 provided. We've got a few people that have not j 17 yet completed that training, but they will 18 complete it prior to assuming any SERO 19 responsibilities. 20 Another objective was to l 21 establish E-Plan Self-Assessment Program. We have ' 22 the-procedure in place. There is a schedule for 23 assessments for the year. Assessments are'in ) 24 progress and, in fact, a couple have been 25 completed. !
158 1 2 Another' objective is to 3 periodically review EAL tables to incorporate 4 clarifications and future enhancements. Our EAL 5 tables were reviewed in January. Changes are in 6 progress. There are some clarification documents 7 that are being generated relative to the time. 8 With respect to Protective 9 Action Recommendations, we had projected high 10 doses, 6500R. Based on this there was a lack of 11 proper consideration for on-site measures and the 12 lack of proper consideration for those off-site 13 measures that were beyond the 10 miles. ) 14 The objective there is to ' 15 include the state DEP personnel in the redesign of 16 the PAR process. They did work with us on the ! I 17 root cause investigation and the redesign of the 18 PAR procedure. This procedure will use current ! 19 plant conditions for generation of the initial 20 PAR, rather than the projected dose rates. This !
~21 is one that's done in a restricted time period.
22 And we believe-that using the plant conditions, as 23 most of the industry does, is a better way to go. 24 NRC: You realize you have 25 an expectation of default condition for certain ! ,
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I l 1 ' I 2 services, right? ; i , 3 LICENSEE: Yes. 4 NRC: For general emergency { \ 5 plus -- I forget exactly what the words are. ! ! 6 There's a default kind of evacuation, a limited ! : , 7 evacuation. I 8 LICENSEE: I believe that's t 6 9 still in the procedure. I'll make sure. ; ! 10 Another objective is to l 11 redesign.the communication-interface with the DEP ) i 12 personnel at the state armory. We have the
!
13 conceptual design for this. There will be a
l 14 direct phone from the DSEO to the DEP in Hartford. l l
15 .This is something that we've tried different ways 16 over the years and we really haven't had an , ) 17 effective solution. It sounds like we finally j 18 have it.
l
19 Another objective is to j'
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20 design appropriate training materials. We have a I ; 21 lesson plan developed for the PAR procedure. As l
! 22 that procedure goes through approval, I anticipate. j
- 23 . we'll probably have to make some adjustments to
() 24 this, but it's ready to go other than those 25 changes. , - - - . . . - ._ .. _ . - - - - _ - - . . . . . - _ - . ,,
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r^s 160 (,). 1
2 Another objective was to 3 verify effective SERO expectations regarding 4 understanding of the level of use categories for 5 EP PAR procedures. We have included in continuing 6 training an element that will put this message 7 forth effectively. 8 Also, in addition, I have 9 again asked Jeff to do an effectiveness review on 10 the corrective actions, the same two-part that I 11 asked for the IRT: One, to make sure it's done,
r^S 12 and one several months later to make sure they are V 13 effective. That's all I've got on this subject.
14 Any questions I'd be happy to answer. 15 NRC: I had one burning 16 question at the time of that exercise. What is 17 the emergency response of the organization? It 18 seems almost unbelievable that the dose assessment 19 shows significantly high levels of defense line at 20 the 10-mile point, and everyone at the 21 organization is satisfied with the 10-mile 22 evacuation procedure. Can you find out why that 23 was the case? It puts a lot of speculation in my
O) (_ 24 mind. (Inaudible.)
25 LICENSEE: I didn't
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1, '
s 161 1 '
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! 2 understand that. When I probed it, I got the '
3 impression that it was more of a time constraint. ; 4 And then the people actually doing the calculation l
~
5 took all the conservative measures. That's the ,
,
l
- 6 only way you get to a number. That means that q
: 7 basically all the radioactivity goes through a 8 narrow plume all at one time. And then there was j 9 not enough time. It was a rushed situation, again
i , 10 using projected dose. So it really didn't get the -
11 time that it should have had for people to give it (g 12 a sanity check. There should have been a common
- (_/
> 13 sense evaluation, is this a reasonable number. I
1
l
, 14 think it was more of a time constraint. We've l
i
j 15 eliminated that. We're into using the barrier '
16 analysis, the conditions, and letting that through
' !
17 a flow chart drive what that recommendation is.
i ! 18 NRC: Once you have a
i
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19 number, what does it all mean?
I
20 LICENSEE: I think people
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21 will rush into -- we had set a goal to get this
i
' 22 PAR out and get it out quick. As you guys know, 1
2
23 we have probably the most onerous process in the l ) 24 industry to do a PAR. Our people were going to
4-
25 get that PAR out in a timely fashion and they
_ . _ _ _. . . - . -
162 1 2 didn't do the simple sanity. questioning checks 3 they should have done. 4 NRC: We understood the 5 person who was going to make a PAR made that 6 conclusion already in the dose assessment. 7 Information just came about that there was already 8 a PAR conclusion. 9 LICENSEE: I didn't see 10 that. -11 NRC: It's a certain 12 position that the key player that makes a call on 13 the PAR finally decides what it is -- (inaudible). 14 Consider what was going on in the plant to make 15 the call. What I understood from our evaluation 16 force that that person had actually been ahead of 17 the dose assessment people and his kind of general 18 view of the situation indicated to him clearly 19 that it was time to go to a general emergency and 20 recommend a 10-mile 360 evaluation. And that was ;21 in his mind, from what it appeared from our 22 observation, he didn't even need this dose 23 assessment because he just said the plant :24 condition. Here is the plant condition, and he 25 got technical input, and it was not likely that
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A
163 ;
i 2 the core was going to remain covered and.we were
! - , -3 going to be' recovering that. So he knew where !
l 4 that was ending up. I don't think we have too ' . '
5 much fault with that. I think he's heading in the ! .6 right direction. But then the dose assessment
- 7 comes and now the numbers are outrageous. I think
.
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8 to say they're conservative assumptions is to.be ;
' \ ,
- 9 polite. 'They're beyond that. They're like '
- 10 ultraconservative. That's a whole different issue j
4 d
11 than normal. So when that comes in, I know, the
.
/ 12 . decision frankly had already been in somebody's- l
[ 13 mind. That's what we can't really understand in , j 14 our mind. How could people that are knowl dgeable i <
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15 know if you got, whatever it was, a 100R or a ,
1
16 10-mile boundary, obviously a 10-mile-evacuation
t -
17 doesn't make sense. 1 ~
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i 18 And the-on-site piece is-
f 19 just another interesting piece, considering you l p ,
20 have field teams and all that. It just didn' t ; 1
[ -
21 hang together at all. We couldn't even come up ,
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22 with'any practical hypothesis that seemed 4
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23 -practical. It just seemed like folks just got the
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24 numbers and didn't look at them and connect other 25 considerations. That was the problem on-site.
t t
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; 164
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2 Now, off-site, the State did ? raise some questions. Those questions were kind 4 of being handled by what turned out to.be that
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j 5 group that was within the State area. It would , .
I
6 normally be several single persons that would --
'7 it was actually a group and they were dealing with
1 8 the answer. ! 8 .
J 9 This group that tras at the
- 10 state AOT almost functioned as a tech support -
4
- 11 center, doing their own thing as opposed to j
i
12 doing -- the function that the State really needs
. 13 is to explain what's happening at the plant. .
, 1 14 LICENSEE: As it appeared to l 15 us. I 16' LICENSEE: Yeah. That's i 17 what it certainly appeared to be. And they were ) , 18 not very helpful in trying to determine the source l 1 19. of 6500 or.anything else. 20 LICENSEE: They're doing a 21 lot in this area, and I think you'll see in the , ~22 redrill some improvements. I 23 NRC: But you have our '24 letter on the exercise report. We had our i 25 technical people here in headquarters take a look ! i
. . 1 2 at the current plant condition. These are not i , 3 issues that are current problems. These are 4 Operations-type problems. Where you are now, it's
,
5 difficult to drive an effect. (Inaudible) EP 1 6 space, reasonable planning, reasonable assurance.
l l
7 LICENSEE: We want to get it 8 right. We want to understand it fully. 9 NRC: I'll just leave you 10 with that. We're still mystified by how that
l
11 occurred. You wanted to go to a summary? ! 1 l 12 LICENSEE: Okay.
l{~
v Jim, this
l 13 is only two slides, and it's really just to bring
14 you up-to-date where we see we are. Immediate I l 15 actions have been complete. The terms of the !
l 16 immediate actions again are to provide reasonable
- 17 assurance of no serious problems during the
l l 18 interim period, to undertake the corrective
19 actions. Short-Term Actions, some are complete,
L 20 And they set the stage by putting the
21 organization, goals and processes in place to 22 correct our problems. That's how we view the 23 Short-Term Actions. (3 (_/ 24 And finally the Long-Term
l 25 Actions are the follow-up that when complete will , i ,
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I i I- l 166 l l' ! L l 2 put us in position to successfully commence ;
3 decommissioning. At this point is when we will
l
4 submit the PSDAR. That's how we see the overall
l 5 plan.
6 LICENSEE: Jim, what I l
L 7 wanted to say is we wanted to review the distinct
8 impression that we're not taking a minimalist 9 (inaudible) our defueled state and we're moving i 10 into the decommissioning. We are stepping back, 11 looking at these operational events, and trying to
iO 12
13 get broad corrective action here so that we can start out with a credible team and credible 14 processes, good controls, strong oversight, so 15 that we can move forward with decommissioning the 16 right way, and everybody will feel comfortable 17 about it. So not only in terms of minimalist, 18 we're actually adding strength to the 19 organization, with Jeff and his Oversight 20 organization, and the three directors, and we're
l 21 retaining the experience that we need to go l L 22 forward. So we are trying to take comprehensive 1
23 corrective action. I think we've got some good
L ) 24 measures we're taking here. We may need to do '
25 more, but this is the approach we're taking right
i _
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167
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2 now. 3 NRC: Does the staff have 1 4 any questions? I 5 NRC: The LER response, we j ! 6 asked for you folks to provide us a supplemental l 7 response. Is that a corrective action? J 8 LICENSEE: What's*the status ' 9 on that? ! 10 LICENSEE: That is ongoing. 11 Was a date given on that one?
/~' 12 NRC: I don't think there k_)s i
13 was a date. That's why I was bringing it up. I 14 LICENSEE: I do know we owe 15 you a supplemental on that. We're very good on 16 doing the supplementals. We have a formal 17 tracking system whenever we check the box, 18 supplemental ELS. We'll get a date when we get 19 back. . 20 NRC: Anything else? 21 NRC: Yeah, I csked twc- 22 questions on the CMP and updated revision. I'm ._ 23 looking at slide 79 and 80. Is there two quick
(' 24 answers to that?
25 LICENSEE: Yes, there are.
. _ , _ . _ . _ _ _ . _ . _ .. _ . _ . _. . . _ . _ . _ ~ _ _ _ - . _ . . _ . . . . . . . _ . . _ . _ _ _ . . _ . ! ; ! ~ 168 O 4 2 NRC: Just give me the quick i answers. ' 3 . 4 LICENSEE: There should be i 5 an FSAR in here somewhere. I'm looking for it 6 right now. The FSAR, we're scheduling that for - 7 August. What was.the second question? l 8 NRC: CMP. q 9' LICENSEE: CMP. If you look ; 10 at the Licensing / Design Basis, we're really 11 scheduling that to be complete by the end of June.- ; 12 NRC: Okay. And what I 13 didn't ask was you talked about the redrill for ' 14 April. 15 LICENSEE: April is what we 16 had heard from Mr. Lesher tentatively. 17 In April John is coming up 1 18 to evaluate people on the simulator, looking at . 19 the classification' capabilities of shift manager 20 and DSEO. That's all that's been determined yet. 21 There's nothing else that's scheduled. 22 NRC: As long as things are
- . 23 the way they are in the full. PAR 50 license, you
24 still have full participation? 25 LICENSEE: Yes. My , . - .. - -
_ _ _ _ . _ . , _ . - _ _ . . _ _ _ . _ . . _ _ _ _ _ , _ _ ~ _ _ _ _ _ . _ _ . _ _ . _ , __ rs 169
l 1- i
2 understanding is there is still some discussion 3 between Pete Stroop and John about the timing for
i 4 .that and exactly what's going to be tested and i
5 what's not. There is an action plan in here. 6' NRC: Let's be sensitive to 7 what is and is not an exception. Don't get
l
8 yourself behind the eight ball and then deciding i
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9 what you really need to do is something else.
l 10 It's not just a schedule thing, but a kind of i
11 scope change. You don't want to give us that at
l 12 the last minute. Because if we. don't answer, the
13 answer-is no.
L 14 LICENSEE: We_have a plan
- 15 for submittal of deductions. There's two things
16- here. There is the current E-Plan that we owe you 17 a demonstration of remedial actions; and we'll do
g 18 that. John Lesher and Pete Stroop are determining
i 19 exactly what that means. Additionally, we will I 20 pursue the decommissioning activities per our 21 schedule, and I think we've got to complete one
1
22 and complete the other two. I th' ink both of them l ,
4
23 have to be completed, i 24 NRC: Just keep all this 25 straight here, and just understand that things get i .__ __ . _ _
1 i ! : i '
(:) 1 i
1 '2 out of whack if delays occur. - 3 I Guess overall, I guess ; I 4 we're done. I appreciate you coming down here for , 5 this meeting. The meeting talked about, frankly,. 6 _more than I thought it was going to talk about, I 7 but there was a lot of good information exchanged l 8 in it. l l 9 I would continue to ; 10 challenge you to look at areas that you might [ , i 11 foresee problems. We've mentioned other types of l 1 12 areas where you may have some susceptibility to
0 13 some issues that would not be right, not be
i ! ; 14 helpful to the problems. ! : 15 And while we have your 16 overall corrective actions, we have your interim 17 corrective actions, we'll certainly internally ! 18 talk about that. If there's any need for more i 19 discussion or if we think there's more things that ) l 20 ought to be done, we will certainly communicate 21 that. And I guess that's it for the presentation. 22 Just some administrative 23 matters here. Know that we have this transcribed. 24 The transcription is going to be part of the 25 public record. The purpose of the transcription
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i i i i
rm 171 k_/ 1 2 was a convenience matter, and that's compared to ) I 3 an evidenciary process. This isn't a hearing. 4 It's not an evidenciary thing; so we're not going ! l 5 to ask you nor are we going to spend a lot of time l l 6 screening the transcript and making corrections. ] 7 We might spend some time looking over it, but 8 we're not going to -- I'm not going to either~ask 9 you to do it or not going to commit for us to do 10 that. So for the record, there may be some 11 transcription errors in the record. We typically
,
12 in these meetings talk a lot-of jargon that normal
'
13' human beings don't understand. And sometimes even ; 14 a "can" or "cannot" or "will" or "will not" may be 15 in there. I'm not committing either organization 16 to spending the effort to screen it at that level. { ! 17 LICENSEE: We'll view it as 18 notes. 19 NRC: I guess it would be l l20 helpful, at least it has in the past, dealing with ! 21 transcriptions, if you have a clean copy of your 22' slides. We will make a correction, since you did 23 indicate it, on the slide 15 it talks about i 24 everyone on-site is focused on the mission. So
1
25 we'll indicate -- we'll need, John, in our copy, - _ - -
172 1 2 we'll need-to indicate that as a change, focused 3 on the mission. We'll indicate it's a_ typo. That 4 could get interesting if that typo get out there. 5 It could raise a lot of questions about what we 6 were really talking about. 7 These letters and documents 8 that you hande'd out that we were looking at, we 9 will include in the transcript so we have all that 10 in one package. We, of course, will be issuing 11 everything. We'll issue those slides as we , l 12 normally-do and the transcript, like we said. 13 With that, I guess we'll close the meeting.
'14 (.At 1:25 p.m., proceedings
15 were concluded.) 16 ___ 17 18 19 20 21
22 23 24 25
_ . . . _ _ . _ . , _ _ _ _ _ - - . _ _ . . _ _ . . . - . _ _ . . _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ . _ _ ! t ; ! -; O !; ; ; ; 7 -i i ! l 173 CERTIFICATE ! - , ; , I, CYNTHIA FIRST, RPR, , hereby certify that the proceedings and evidence are contained fully and accurately in the notes - taken by me in the above cause and that it is a correct transcript of the same. b CYNTHIA'FIRST, RPR Professional Court Reporter .
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Connecticut Yankee Atomic Power Company 0t O 1 i MANAGEMENT MEETING - February 5,1997 - ! . Y & 1
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Agenda . * Opening Remarks T. Feigenbaum Performance J. LaPlatney ~ * , - Health Physics G. Bouchard - Licensing / Design Basis J. Haseltine - Emergency Preparedness G. Bouchard * Nuclear Oversight J. Warnock .; ~ * Summary J. LaPla.tney - Closing Remarks T. Feigenbaum 2 h
_ _ _ _ _ _ _ . - _ _ _ _ h t ! t t ! ! ! Opening Remarks , [ t ! . : t T. Feigenbaum , ! Executive VP & CNO - ., ^ - - ; [ l I , ! t
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_- -- - _ -__ _ _ _ _ _ _ _ _ _ - _ _ _ - - , - . Performance Update . ! .
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. I J. LaPlatney Nuclear Unit Director . . ' ! i : - ! l : 4 ! _ _ -_ -_______-_-______-____--_______ -__________ _______________ - - _ _ _ _ _ _ _ _ _
. . - . . - . - _ . - . . - - - . . h 4 , Performance Issues ~ * Management Standards - Corrective Action Program * Licensing / Design Basis . * Management tolerated these conditions ~ , ,
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Management Standards ~ - - Conduct of operations not formal enough - Procedure use too flexible - Conduct of work not formal enough - Issues not elevated in a timely fashion - - - t , , , r
_ _ _ _ __ -.. Corrective Action Program . -
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New program (1995) lowered threshold - system overwhelmed
Quality of analyses and corrective actions inconsistent .
Trending implemented, then not continued e O z CV
_ __ - . __ h t Licensing / Design Bssis .
FSAR not rigorously maintained
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Design calculations lacked rigor
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Small safety margins not respected
50.59 not used as frequently as industry . standard . . ~ '
_ _ _ _ _ _ _ _ Management Tolerated . These Conditions
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Some history (50.59 evaluation standard)
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We simply failed to set high enough standards . 4
_ _ _ _ _ _ - - _ . . - . s CYAPCO Acoroach . .
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IMMEDIATE ACTIONS - Complete
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SHORT TERM ACTIONS - Complete 1st Quarter 1997
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LONG TERM ACTIONS - Complete prior to .i PSDAR Submittal . , 10 - . _ .
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, l l lMMEDIATF ACTIONS
. * Stabilize the situation (compensatory measures) , -Director approval of all activities worked after normal work hours -Director approval of all significant radiological work -; * , , _ - - - - _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ _ - - - _ - _ _
. _ _ _ _ _ _ _ - _ _ _ _ .__
i IMMFDIATF ACTIONS ! * Raise standards immediately in critical areas - Operations, Health Physics -Every operational problem is escalated immediately, no matter the significance -Clear standard for procedure use is in place- upgraded procedures support this standard , -213 Operations procedures have been upgraded to the new standard . ] -Check operator used for self assessment -Radiation exposure for January 1997 712 mrem 12
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IMMEDIATF ACTIONS . . . -RWP's have more' specificity -RWP pre-job brief standards have been raised . 1 -HP's job is to provide proper radiological controls -! . . -. i ! , 13 , i . ___________ __ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ -- ____ __ _ _______ _ __ _ __
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, ; - IMMFDIATF ACTIONS . - - . b Key Management Changes -Director of Engineering - Director of Work Services ! -Operations Manager -Radiation Protection Supervisor -l * [ ' ! l I i 14 , . . _. __ _ -_ . ..
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i SHORT TFRM ACTIONS i i * Rebuild the Organization -Interim Organization designed to complete
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corrective actions prior to decommissioning , '
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-Essentially all positions re-evaluated -Incentives applied to attract best talent -Everyone on site focused on decommissioning . -We are minimizing the duration of the transition period . , t -Selection Process - behavioral interviews . , --
, SHORT TERM ACTIONS - . - Bring in outside talent , -HP Manager -Yankee Rowe Plant Project Manager -Decommissioning Project Manager . -Business Manager . . -Experienced Contract Engineering Personnel - , 16
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, 5 SHORT TERM ACTIONS . , . Y - Rigorous Performance Goals and Monitoring ; : - KPI's -Weekly Performance Review Meeting -Weekly Project Reports - - , . . O i i
_ _ . _ _ _ _ _ _ _ . _ . h SHORT TFRM ACTIONS - .
Plan the actions necessary to correct our , problems -Plan for each item (Common Cause and IRT) . -Schedule set for each item - Accountable individual named . O G *e - _
_ _ _ - _ _ _ - _ _ _ - - - - - - - ! - _ - - . . . - - l SHORT TFRM ACTIONS : - ; - - Accurately Characterized ACR Backlog -Comprehensive review since inception of ACRs (1,922 ACRs) - - Adequacy of documentation of corrective . actions assessed
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-Items either closed, opened, or archived . -QA audit of this' activity requested, results satisfactory -Currently 343 open or tracked ACRs 19
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SHORT TFRM ACTIONS . - , * We are working off ACR Backlog -In progress - KPI, reviewed weekly . - . . < , I ; - - - . - _ - - . __ __________--- _ ______-_-_____ - - -_- - - - -____-_2
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SHORT TFRM ACTIONS , - * Reach out to regain publi$ trust -Community Decommissioning Advisory Committee (CDAC) ' -Chairman selected -First meeting in March " - : 21 i --- _
_ _ _ _ . _ . _ - _ SHORT TFRM ACTIONS .
Management Raising Standards - Auxiliary Boiler Condensate Receiver -Vague steps in procedures -Fuel transfer hatch retest -Yard ~ crane calculations .! - . - ~ 22
. _ - _ - - _ _ _ _ _ _ LONG TFRM ACTIONS * Implement Formalizec Standards -New Department Managers Goals . - Department Standards i -Station Standards
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- Eliminate ACR Backlog d - ACRs resolved in a' timely manner ' - ACRs tracked until action complete - - .. -Keep KPI to monitor backlog
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. -. . . - _ _ _ _ _ --_ _ __ . _ __ ! . . I ONG TFRM ACTIONS - . * Implement Improved Corrective Action Program -Less process, more quality . -Improved software -Trained evaluators -Trending with KPls .; -Effectiveness review by Oversight . - . 24
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I ONG TFRM ACTIONS .
Complete HP Program Improvements -More rigorous control -Improved procedures , -Training . -Effectiveness review by Oversight . . - . t .. \ i 25
-- __ _ -__ _ _ - _ - - - _ - 8 , L . I ONG TFRM ACTIONS. : ~
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' * Complete Emergency Plan improvements -Classification training - PAR process improvement and training ; - Effectiveness demonstration ' ' - . b t 26
_ _ _ _ _ _ - - _ . I ONG TFRM ACTIONS . . ' .
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Complete reconstruction of Licensing / Design Basis -CMP for systerns required when defueled -Submit revised FSAR - Program improvements . -Training ~ . -Effectiveness review by Oversight - 27 _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ ___ _ _ _ _ - _ __ _ _ _ _
. ___ ____ __-- e SUMMARY * Immediate actions are complete - reasonable assurance of no serious problems during the interim period - Short term actions - some are complete, set the stage by putting organization, goals and process in place to correct our problems . ' i ! 28 -
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f L . ~ SUMMARY Cont'd I ! * Long term actions - when complete put in a position to successfully commence decommissioning - PSDAR will be submitted after these actions are complete ;
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Health Physics . . Gary Bouchard O 5 e t 30 :
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Health Physics : . t * Refueling Cavity Canal Gontamination Event Description ; Causal Factors ! Corrective Action Short Term . Long Terrn ~ * Staffing . i ~ ~ Quality 32 h
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Health Physics . - Plant Status * Description - November 2,1996 -Mode 6 (Refueling) -Two- Workers inspect Reactor Head . 1 and Cavity Area and Refueling Canal Prior to Core Offload , t t 1 _ -_______ _-______ _ _.
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-- Health Physics . . . . * Description (continued) - Agitation of Debris Created Airborne Condition in Canal and Cavity -Workers Became Internally Contaminated i -Initial Dose Assessment Questioned . as W , .
- _ - _ - _ _ _ _ _ . - -_ Health Physics .
Description (continued) - Notification (50.72, 50.73) to NRC Potential Overexposure -Notification to Local News Media and Two individuals involved . .! -Final Dose Assessment by CYAPCO and Third Party Indicated No Overexposure to Individuals , , i 34 -
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( . Health Physics . - ' * Casual Factors -Sources Two Root Cause Investigations . Independent Review Team Investigation .; NRC Inspection 96-12 .
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. Health Physics * Casual Factors (continued) -Degraded Materiel Condition of Transfer Canal -Schedule Deficiencies -Lack of Proper Work Planning -Inadequate Surveys . .
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, i e
. Health Physics . . *
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Casual Factors (continued) I -Communication Breakdown - Maintenance /HP '
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-Failure to Inform Workers of Rad Conditions in Cavity and Canal .
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- -Inadequate Gyidance to Workers Regarding Actions in Canal . - --- - --- --_--- -- - - ----- _ _ . .
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- ~ . Health Physics , k * Casual Factors (continued) -RWP Controls for High Rad Risk Environment Were Inadequate -RWP Invalid for Entry into Canal -Inappropriate Air Sample Location : i 38 -
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f Health Physics . . . t * Casual Factors (continued) -Procedure Deficiencies -Procedure Noncompliance ' -Weak Event Management - - - i ! ~. i ; i . I
_ _ _ _ _ _ _ _ Health Physics . - * Corrective Actions - Short Term . - -Two Workers Restricted Access to RCA Pending Dose Assessment - Root Cause Investigations initiated ' -Read and Sign for HP Techs l & E Notices. - Other Pertinent Events , Overview of This Event so $ ,
_ _ _ - _ _ - - - _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ __ - _ _ _ - - - - _ _
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- Health Physics . . ~ * Corrective Actions - Short Term (continued) -Weekend Work Suspended Unless Approved
l by Unit Director
-Senior Management Presence During Core
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Offload . . -Unit Director Restated Expectations and Standards ~ i i -Work Services Director Restated Expectations of HP personnel ' 4, h -_
___ . . _ _ _ _ _ _ _ _ . '
2
Health Physics , - : * Corrective Actions - Short Term (continued) . -High Rad Area Work Restricted -Lessons Learned i !
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-Effectiveness Verification , i ' - All RWPs Rev[ewed, Updated With Appropriate ~
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Rad Data, or Deactivated to Prevent Use - - 42
__ __ _ . - _ - _ _ _ _ _ _ . _ _ _ _ - - Health Physics - t i i - Corrective Actions - Long Term
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-Reviewed and Upgraded RWP Philosophy i -RWPs and Surveys Reviewed at Pre-Job ' Briefing : -Use a Radiological Risk Assessment Procedure i to Define and Control High Risk Evolutions - i Management Participation Will Be Required
t
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ______ _ _ _ __ - __ _ ___ __ __. ..
______--__--. , Health Physics : . ;
Corrective Actions - Long Term (continued) . -Survey Matrix Developed for Routine Surveys , ; -Pre-Job Surveys Required for All High Risk ! Evolutions . ~ -Survey Data on RWP and Available at Each Control Point ' - ~.
. _ _ . . _ _ _ _ _ . - _ _ _ _ , Health Physics
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* Corrective Actions - Long Term (continued)
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-Management of Survey Records Transferred to HP Services Group -Review and Upgrade Record Keeping Process i - ALARA poordinator Will Participate in Evaluation of .! High Risk Work .
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l -Review Confirmatory Monitoring Program .
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- - -_ --- _ - - - _ - - - - - - - _ _ Health Physics , - ' . . * Corrective Actions - Long Term (continued) -Improve Radwo~rker Culture, Increase Awareness and Accountability, Reinforce Expectations, Make RWPs and Surveys
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Readily Available, Document High Risk ' Evolution Briefings ; -
* 46 1 ! _ _ _ _ - _ - - _ _ _ - _ _ _ _ _ _ _ _ _ - _ . _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _
- _ _ _- _ - . t
> 1
- Health Physics .
- . * Corrective Actions - Long Term (coritinued) -Clarify Expectations, insist on High Standards -Procedure Adherence ' Procedures Assigned for Review and Subject Matter Experts Assigned " - Zone Coverage" Implemented to increase Knowledge, Ownership, and Continuity - , ! 47 ! , ___..___._.___.________.__.___.__.______m_.._._ _ . _ _ _ _ _ _ _ .___ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _
. Health Physics . . e - Corrective Actions - Long Term (continued) -Standard Briefing Books Developed for Certain High Risk Evolutions " - Clean" No Longer Used to Describe Work Areas - Actual Activity Levels Are Being Used -Eliminated Practice of Qualitative Field Counting of Air Samples l <a &
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. . Health Physics . . * Corrective Actions - Long Term (continued) -Respiratory Protection Will be Used in All High Risk Alpha Areas Until Airborne Conditions are known and Determined to be Acceptable ~ -Upgrade Air Sampling Program for Alpha - .. 49 - ;
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_ Programmatic Issues Matrix CORRECTIVEACTION E SOURCE CHANGES
Ali RWPs reviewed and updated with appropriate IRT Rec.1 & 2
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radiological data or deactivated to prevent use. Apparent Vo. 2d Review and upgrade RWP philosophy g 7g IRT Rec.1 & 2
Apparent Vio. 2c,2d
Specific RWPs will be written for tasks that present IRT Rec.1 & 2
W h2
unique radiological hazards. App &ent Vio. 2b RWPs & surveys will be reviewed at pre-job briefings. g IRT Rec.1, 2, & 3
Apparent Vio. 2a,2b
High risk evolutions will be defined & specific controls Root Cause Rec. 2,4
RPM 2'1-2
delineated through the use of a Radiological Risk IRT Rec.1, 2, 5 Assessment procedure. MarkW participation will Apparent Vio. 2b be required. Frequency of routine surveys has been reviewed and a IRT Rec. 3
RPM 112
survey matrix developed Apparent Vio. 2a ' Representative pre-job surveys will be required for all IRT Rec. 3 high risk evolutions.
M11-Z RPM ZM Apparent Vio. 2a
Survey data is now included on the RWP and available' IRT Rec. 3
RPM 11-2
at each control point. Apperent Vio. 2d Responsibility for management of survey remrds has IRT Rec. 3
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been transferred to the HP Services group. Self- App &ent Vio. 2a Assessments will be performed to ensure RWP compliance with survey documents.
50 - -
- - -
Programmatic Issues Matrix - CORRECTIVEACTION * SOURCE CHANGES Review and upgrsde records keeping process IRT Rec 3 RPM 1M Apparent Vio. 2a ALARA Coordinator will participate in evluation of high Root Cause Rec. 3 RPM 1.5-2* RPM 1.5-10 risk work. Designation for respcisibility of IRT Rec. 4, 5 implementation of ALARA reviews will be clarified. Confirmatory monitoring program will be reviW 1RT Rec. 6 RPM 1.4-3 Change radworker culture - awareness, accountability, IRT Rec.1,2, 7 RPM 21-E RPM 212* expectations. RWPs and surveys will be readily Apparent Vio. 2b available. Briefings for high risk evolutions will be RPM 2.5-4 documented. Clarify expectations, insist on high standards IRT Rec. 8 Department Standards . Document Assign procedures for review and assign subject App rent Vio. 2c RPM 1.6-9 matter experts. " Zone Coverage" implemented for health physics Apparent Vio. 2c RPM D 2 techniaans. . Standard Briefing Books developed for certain high risk Root Cause Rec.1 RPM 2M evolutions to ensure consistency. Apparwd Vio. 2b The word " clean" will no longer be used to describe IRT Rec.13 RPM 2 M work areas. Actual activity levels will be given. Apparent Vio. 2b ' 51 -
_ _ Programmatic Issues Matrix . . . CORRECTIVEACTION SOURCE
Eliminated the practice of qualitative field counting of Apparent Vio. 2a
M 22-M
air sarnples. Respiratory protection will be used in all high risk alpha Apparent Vio. 2a
W 11-2 ,
areas until acceptable airbome conditions are determined. Upgrade air sampling program for alpha. RPM 2.2-5, RPM 22-7
e Rm 5 . . . . E
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. Health Physics . - Staffing -Current - Future Interim . D~e commissioning . - Quality .. _ . _ . _ . _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ ___________m_ _ . __
Licensing / Design Basis Issues
. Update J. Haseltine Director - Nuclear Engineering . . -
Licensing / Design Basis issues - Agenda . * Management Summary * Common Cause Assessment Corrective Actions * Organizational Issues Corrective Actions - Programmati.c issues Corrective Actions ' ~ * Schedule . -
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Licensing / Design ~ Basis Issues - Management Summary : * Maintain a High Level of Involvement in Key Improvement Activities ' * 29 Action Plans (GRPIs) Approved , Monitor Daily Progress ' * ~ * Weekly Status Reports on Action Plans . . * Schedules Established for All Action Plans . ' * A.ssure Recources are Available se - _ .- - - - - - - - -a
Licensing / Design Basis issues , Common Cause Assessment
- Summary of Findings . - Programmatic issues - Organizational Issues * Corrective Actions . * Applicability to Defueled Mode . ' . u & L Y
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. Licensing / Design Basis Issues . Organizational Issues 1. Management Standards and Expectations 2. Change Management and Resource Management 3. Training Programs
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-- - - . Licensing / Design Basis issues . Management Standards and Expectations - Corrective Actions i
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Action Plan Established (GRPI 29)
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Establish and Publish Standards of Performance
- Communicate and Implement Standards -
Establish Key Performance Indicators for Standards
- Benchmark These Standards against Industry Leaders
- _ 59 .
-- - -- Licensing / Design Basis Issues Management Standards and Expectations - - Corrective Actions . - Selection of Engineering Management Based on Behavioral Interviews -Planning and Organizing (Work Management) - Analysis (Problem Identification) -Information Monitoring -Work Standards - - Ability to Learn
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-Initiative 60
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-- % ' ~ CY Inter'm Organization ENGINEERJNG DikECTOR . 1 D HASELTINE (I) [21) m ADMINISTRATIVE INTERIM SECRETARY (1) RESOURCES . EPCINEERING M ANAGER ENGINEERING PROGRAMS I M T NSIMi (1) [19l 5tMRYiSOR (l) 187l StMRTISOR 11) l17) ~ ENGIM1R3 SM1A (S)
Ill t'lkk'.\1 E NGINEl RING MECILUllCAL $YSil.Lis MECllANICAL ENGINEERING _
ELECTRICAL DESIGN gy;gg.1k - s111RVisok (1) [17l SUPERVISUR (l) [l7l SUPERVISOR (t) l17] SUPERVISOR (1) [14l (RRE PRO 1B Tkel) (1) . - ^ ENGINEER (3) - ENGIM.E R ' , (CIVfL) (t) ENGINEER _ ENGIER _ MGER - gege) ggy (4 TRESS ANALYSTS) (t) (IAC) (3) ~ ENGINEER ($YSTDA) (1) ENGINEER ENGINEER ~ DESIGNER ~ (ELECTRICAL) (2) ~(APPL;EDMECHANICS) (1) (ELECTRICAL) (2) ENGINEER - (15Lt3T) (1) ~ DE31GNLR * (MECllANICAL) (1) lit shim M ~ tt 'lVlf >MI t11 %Nis ' \1 ) (1) _ (takiNIM'llk (2) 61 ____ ____ ____-_________ - ______. __ _ -. _ _ _ _ _ - . __ _- _
__ - - Licensing / Design Basis issues Change Management and Resource Management - Corrective Actions , * Assess and Provide Resources for: - Spent Fuel Storage - Updating of Program Documentation * Improve Change Management for New Programs and Processes -l - .
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- Training - - " Buy-In" of Personnel i 62 ' _ _ - - _ _ _ - _ __ . . _ _ _ ___ _ . . . _ _ _
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Licensing / Design Basis issues Training Corrective Actions - - - Revise and improve Configuration Management Training Programs - Explain Design Basis - Address New Process Linkages ~ - Incorporate Revised Technical Guidance ~ - Reinforce Expectations 65 . - - _ _. - ___ .--
_. . _. _ _ _ . t I
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Licensing / Design Basis Issues . Programmatic Issues :. 1. Licensing / Design Basis Information : 2. Configuration Control 3. Corrective Action Program . ' 4. Procedural Deficiencies 5. Design Control Process - . i 66 . _ _ _ _ _ _ _ _ _
- - - - _ _ _ - _ _ _______ _ _ , E 4
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Licensing / Design Basis issues
- Licensing / Design Basis Information Corrective ~Abtions
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- Configuration Management Project (CMP) to identify and Verify Licensing / Design Basis - CMP Group Still Organized / 38 People Dedicated to CMP - No Short Cuts .; - Engineering Funda~mentals . - Find and Correct issues - 87 h _---- _ ---
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. , Licensing / Design Basis Issues ~ Licensing / Design Basis Information Corrective Actions . * CMP Elements: - Defueled System Reviews - Topical Area Reviews . - Commitment Review and Tracking - Chapter 15 Analysis Reviews - UFSAR Revision 68 v
__ _ - _ - - - Licensing / Design Basis Issues Licensing / Design Basis Information Corrective Actions
.
* Defueled System / Topical Area Reviews (GRPI 30) - Establish Licensing and Design Basis - Identify important Attributes - Validate Design Basis and Attributes -' - Reconcile Design Basis and Attributes with UFSAR, Procedures, and Technical Specifications _ - 69 i . _ _ . _ _ _ . _ _ - _ _ _ _ . _ - _ _ _ _ _ _ _ . . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ . _ _ _ _ _ _ _ __ __ ___ _ _ _ _
__ _ _ _ _ _ _. __ Licensing / Design Basis Issues Licensing / Design Basis Information Corrective Actions
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Commitment Review and Tracking (GRPI 19) - Identify Commitments in Docketed Correspondence - Enter 29 Parameters into a Database - Identified 10,000 Commitments to Date ~ - Procedure Will Be Adopted to Capture Future Commitments - 70 .
_ __ __ - - . i Licensing / Design Basis issues Licensi.ng/ Design Basis Information Corrective Actions , .
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Chapter 15 Analysis Review (GRPI 13) ; - Identify important Parameters Used in the UFSAR Chapter 15 Accident Analyses - Validate Parameters by Calculations, Specifications or Evaluations - Review Parameter Values in FSAR, Technical Specifications, Plant Procedures, and Setpoint List 71 _ _ _ _ _ _
_ _ _ __ ___________- _ _ . ! Licensing / Design Basis I Issues . Licensing / Design Basis Information Corrective Actions i > : ' UFSAR Revision (GRPI 5) - Following Licensing ~and Design Basis Reviews, UFSAR Will Be Updated for Defueled Conditions - Systems and Components No Longer Required
for Defueled Condition Will Be Removed - Discrepancies between the Detailed Licensing / Design Basis Information and the UFSAR Will Be Corrected 72 e ---r- - *uw'
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Licensing / Design Basis Issues - . Configuration Control Corrective Actions * Implement Programmatic / Organizational Changes to Maintain Linkages (GRPI 22 and 26) - Accident Analysis Process - Plant Design Change Request Process - 10CFR50.59 Safety Evaluation Process - Maintaining Programs - Design Calculation Process - Licensing Basis Document Change Process 73
.. - Licensing / Design Basis Issues - - Corrective Action Program Corrective Actions
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Established Action Plan (GRPI 12) - Define Process . - Revise Procedure - Benchmark Against Other Utilities - Develop Software - Develop KPis u &
_ . _ __ . _ _ _ _ _ _ _ __ __ __ . l . Licensing / Design Basis . Issues Corrective Action Program
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Corrective Actions . ! i . - Establish Action Plan (GRPI 12) (continued) ' -Software Validation and Verification -Training -Trend Reporting 75 - _ _ - _ _ - - - - - - _ _ - - . - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ - _ _ - - .
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Licensing / Design Basis lSsueS . Procedural Deficiencies ' Corrective Actions * Revise Procedures to Assure a Correct and Consistent Approach to Engineering Activities (GRPI 22 and 26) - Non-Conformance Reports - MEPL Procedure .
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10CFR50.59 Safety Evaluations - Inventory Database Updates - Setpoint Calculations 77
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Licensing / Design Basis . ~ Issues Design Control Process
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Corrective Actions
- Revise Design Control Manual (GRPI 22)
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Review and Validate Defueled Setpoints (GRPI 26) - Review and Validate Defueled Hydraulic Calculations ' (GRPI 26) - :
- Review and Validate Defueled Electrical Calculations (GRPI 26) ' f
'
t
e-. _ ., % 4 a. .a_ d -_,ha4p_ -q _ .m.4 .% . - m. _me.4...d. a CONNECTICllT YANKEE DEFUELED PROJECT SCHEDULE JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 1997 1997 1 ACCIDENT ANALYSIS d_ _ _ _ _ _ _ _ _ _ d 2 OFFSITE DOSE CALCULATION d_ _ _ _ _ _ _ _ _ _ d 3 SF HEATUPIDECAY CALCULATIONS d. _ _ d , 4 SYSTEMS CATEGORIZATION g------ A S CORRECTIVE ACTION PROGRAM g~~~~----------- f 6 CORRECTIVE ACTION g~~~~----~~~~~~~~ A IMPLEMENTATION l . t - 7 SYSTEMS CLASSIFICATION - QA g~~------------------------- f 8 DCMI 10CFR50.59 g--------~~----------------------- f 9 LICENSING COMMITMENTS g---------------~~---------------- f
10 LICENSING BASISI
DESIGN BASIS g----~~--------~~~~~-------------- f 79 f . _ . . _ ._.___ . _ __. _ _ . . _ _ . _ _ _ - . _ . _ _ . . _ _ _ __ __ _ _ _ _ _.-_ _ _ _ _ _ . . _ _ _ _ . _ _ _ . _ _
.,4 .,&. 4J._h.A.at.-4 1.O.4 w- - a = _.ua 4 E. , A... , ,.,,.tA 4 m - S a 4 E CONNECTICUT YANKEE DEFUELED PROJECT SCHEDULE l JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 1997 1997 .
11 QA g----~~~~~------------------------
TOPICAL f MAINTENANCE
12
RULE g--------------~~~---------------------- A
13 NUCLEAR ISLAND
STUDY g------------------------------------ g
14 SECURITY g____________________________g
guy
15 EMERGENCY
PLAN d.___________________________d TECH SPECSI TECH REQ MANUAL d____________________________d . FIRE PROTECTIONI TECH REQ MANUAL d____________________________A
18 INSURANCE g--------------- g
EXEMPDON
13 NPDES PERMIT
RENEWAL g--------------- g ~
20 ENERGY EFFICIENCY
STUDY g--------------- A 80
- - - _ _ _ _ - _ _ _ - _ - _ _ _ _ _ _ _ _ - - -
'$
, Emergency Preparedness * i l ! ! ' Gary Bouchard , Work Services Director ; i .! , t 81 i , . _ _ _ - - _ _ - _ _ _ _ _ - - _ _ - - _ _ -
_- -- - _ _ _ - _ _ _ _ - _ _ - _ .
Emergency Preparedness Exercise Weaknesses - .
.
IR 96-07 Identifies Two Weaknesses
~
- t -Initial Classification and Confusion with Use of Emergency Action Level (EAL) Tables -Protective Actions Recommendation (PAR) Process L . _ _ _ - _ -
________.__-______-__ _ __
Emergency Preparedness ~ ~ Short Term Action ~ - ; * Commissioned Root Cause Analysis -Classification -Protective Action Recommendation (PAR) Process * Committed to Demonstrate Effectiveness of .: Corrective Actions , - Docketed corrective action commitments in , letter dated November 25,1996 83 h - - -- - - _ - _ - _ - _ - - -- - - -- - -- _ - - -- N
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ i Emergency Preparedness
- Event Classification
Corrective Actions Status - * Conduct SERO job task analysis to determine most capable and effective positions to make EAL classifications (January 1997)
,
' Status: Task analysis was completed January 31,1997. Recommendations under review Conduct an analysis of simulator utilization as a training and evaluation tool to improve EAL classification skills (January 1997) Status: LORT training effective and will continue 8< & ' --_ - - - - - - - - _ - - - -
_ _ _ _ _ _ _ _ Emergency Preparedness Event Classification Corrective Actions Status -
-
Train those members of the SERO that classify events using the EAL tables. Include bases information and clarifications in the lesson plans (January 1997) Status: ADEOF, AMRDA, MRDA training : programs have been provided
Establish an E-Plan self assessment program and evaluate its effectiveness within 6 months (January 1997 - July 1997) - Status: Self assessment procedure is in place, schedule issued, assessments in progress 33 @ -
_______________ Emergency Preparedness Event Classification Corrective Actions - Status t
Periodically review EAL tables to incorporate clarifications and future enhancements (Annually) ! Status: EAL tables were reviewed in January, 1997 - Changes in progress ! l 86 . !
_ _ _ _ _ _ _ _ _ _ _ _ . Emergency Preparedness Protective Action i Recommendations ~ I
-
Projected High Doses (6500R at Site Boundary)
-
Lack of Consideration for Onsite Measures Based Upon Projected Dose
-
Lack of Consideration df Offsite Measures Beyond 10 Miles Based Upon Projected Dose 87 - - - - - - - - - - - _ _ _ - - - - _ - - - _ _ _ _ - _ . _ _ _ _ _ _ ___ ___ _ -
Emergency Preparedness Protective Action Recommendation Corrective Action Status - * Include state DEP personnel in the redesign of the PAR process (December 1996) , Status: DEP personnel involved in the Root Cause determination and PAR procedure development Procedure uses current plant conditions for '
l generation of initial PAR l
* Redesign the communication interfaces with the state DEP personnel (January 1997) Status: Design Complete 88 h - - - - - - - _ - - - _ - - _ _ - - - _ _ - - - - _ _ - - _
- _ _ _ - _ -___________ . Emergency Preparedness
,
Event Classification ' ; Corrective Actions - Status i - Design appropriate training materials. (January 1997) : Status: Lesson Plan Developed - Verify effective SERO expectations regarding procedure utilization and compliance. (January - 1997) ; Status: Included in Continuing Training i 89 ._ -___-_ _____ _-_____-_ _________ _ __ __---_______-__-_______________l
- - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . Nuclear Oversight . I Jeffrey Warnock . N 9
_
r .
CY-QA for DEFUELED MODE
'
- QA ORGANIZATION-Enhancements - PERSONNEL - . -QUALIFICATIONS - AUDIT and SURVEILLANCE PROCESS -EMPHASIS ASSESS COMPLIANCE OF PROGRAMS, PROCEDURES, REGULATORY
-
REQUIREMENTS l REVIEW PERFORMANCE TO MANAGEMENT EXPECTATIONS / STANDARDS t ASSESS EFFECTIVENESS OF CAs 91
_ - .._ __ _ . _ . _ . . . _ . . _ _ _ _ . . _ . _ . _ . . _ _ _ _ . . . . _ _ _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ . _ _ _ _ . . _ _ . _ - . _ . _ _ .
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NRC/CY ,
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,
MANAGEMENT MEETING l
- FEBRUARY 5,1997
i i $
- 4
i
KEY PERFORMANCE INDICATORS .( (PIs )
i ,
' ..,n
_ . . _ . . . . _ _ _ _ _ _ _ . _ _ . . _ _ _ . . . _ _ _ _ _ _ _ _ . . _ . _ . - _ . . . . _ _ . _ _ . - _ , . _ _ _ _ _ . . . _ _ . _ _ _ _ _ - - --- _ . _ _ _ . . . . . _ _ . _ _ _ _ _ _ _ . . . , _ _ . _ . _ .
- . . -i
i
: I ! t l _ .- _. _ _ _ _. . _ _ _ _ _ . . . _ _ , . _ _ _ . _ . _- i
,
TR BACKLOG
'
I . 500' ~ , i ! , __ _-.S 450 t' ! , l TOTAL TR BACKLOG i 400 ' L _ _ - -_ __ __ _ _ ._ J . t L t ' i 350 - l t , i 300 - - i . l o ; ,. . 4 250 f; I !
! . l 200 i !
! l 150i ! ' ! 100 Contact Doug Heffe, man x3685 r i ' ' i , 50 i 4 1 .i - ! ' 0 . - - - , * - - - - - - - ~ ~ -- *--r- * *--+---- - ~ - - - * n N " " : - - - - a - a - n - " - a a a S a a a ,. ..,_._,_-ms . l .*
_ _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ---- _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ . _ _ _ _ _ . _ . _ _ . , . -[ ; . ! ! [ ; h - - - - -- . . . . . . - ~ . _ . i , :
-
AWO BACKLOG ! t t
-
f 1 t , 3500 3250 ; , _ _ _ . _ . . .<
1
l 3000 i, TOTAL AWO BACKLOG l . 2750 -- -- -- -- - i , i 2500 ; , i , 2250j i i i : 2000 ! , I 1750 ! ! !
,
1500 -
i
t 1250 >
I
1000
; 750
, ' .
I ' 500 Contact: Doug Heffeman x3685 , - i , 250 t
i I
O ' ' -~~ " ~'~~~~~~^--+~~-~~-~'-~' ' ' ."e + - - e- -- I . o s ,, . - e e m m e a m e e a m e C Q Q N R C Q N N C D D N C b " C D - ,. . - a m - m - - - - N" N A m n - - - - -- i
.*
- - - - - _ - - - - - - - . - - _ . . _ _ - - - - . _ _ - - - --. - _ . - - _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ - - - - - _ . - . - - - - - - _ - - - - - _ . _ _ _ _ _ _ - - - - - - - - - _ _ _ - _ _ _ _ - _ - - - _ - - - , - _ _ _ - - - - - - _ _ _ _ _ _ _ _ . . . - - _ _ _ - _ _ _ - - - - _ _ _ - - - - _ _ - - - - _ _ _ _ , - - - _ _ - - - - - - _ _ _ - - - - - _ - - _ - - _ - _ _ - _ _ - . - _ - -
_ _ . _ _ _ , ._ . . _ _ _ . _ . - . _ _ _ . = - . . - - . . . _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ . . _ . _ _ _ _ . _ _ _ . _ _ _ _ . _ _ . _ . - _ _ . _ _ _ . .
. -! ! ! ! . - . - _ - - - _ . _ . . - -_ - . - _ - . - WORK DEFERRAL l ' I ' i I l l 15 ! l : L ! i ; j ! % AWOs NOT COMPLETED AS - ; * SCHEDULED l t . _ _ . - . . _ , , ! ! 1 l , ' to ) l i : ; ! ! I ; i i 4 5- [ , ; l ' !' ' I I . ! ' . ; l Contact: Doug Heffeman x3685 ; i _a ! ! J ; i ! t ^ ! Qf , . , , , , . . . - . .. . , . .4- + * t---+---+-- ---r ----t- - - + - . - - - + -1 ; ; ; ; - 9 - 9 w- - - - ~ ~ ~ a n n .. , ! [ _ __ _ _ _ _ . _ _ _ _ . . _ _ . . _ _ _ . _ _ _ _ _ _ _ _ _ __ _ _ . . _ . . . _ _ . _ _ . . . _ . _ : r
-
?
.- . - .. ..- _ ._ . . . . . _ _ . _ . . _ _. o ; ~ - - . - . - - - . . - - _ _ . _ _ _ _ _ _ - - - . _ - _ _ _ _ _ _ , REWORK , , , 10 ' ; . : 9, ! ! ; 8 * . ; 7l ! ! 6, t ! ! 5 . - . . . - . ---- . _ . 1 . # OF REWORK AWOs PER WEEK 4I REWORK DEFINED IN WCM 2.2-1 ' i t . . _ - _ _ _ - - - - _ . _ _ _ . _ . _ _ _ 34 1 1 - ! 2ii Contact Doug Heffeman x3685 l l i ' i i ' ' 0 t- -- , - - + - , - - - + - --m--r--+-- -----v- F----+----+-+--+----+- - - + - - - - + - - - - , M O N v ,- CO LO ,- 00 m N G m N G @ m N CD @ C Q Q $ C C U N 5 C U U,- S A" C n Q n 5 C n C n Q n - - ,- ,- ,- ,- n,- a,- n e- - ,- e- .- -.. -._ ._ .- i i t
e
- - - - - - - - - - - - - _ . _ - . _ - - - - - - - - - - - - - - - _ . - - - - - - - - - . - - - - - - - - . - - - - - - - - , - - - - - - - - - - - - - - - . - - - , - - - - _ - - - - -
-..- - - - . _ - . .. -- - _ _ - . - - - - - - - .. - - _ .. ._-____-.--.__..-_ . -.--- - ....-- _..--...-.-.-- - .. . . . - - - - - _ _ _ ! . _ _ _ _ _ _ . _ _ _ _ _ . . . _ _ _ _ . _ __ . _ _ .. ,
4
A/Rs OPEN ' .- . - . . .. TOTAL OPEN A/Rs 1800 I-- - - - - - - - - - - - ' ' ; l I l' , 1500 - ,
! !'
I 1200i
l ,
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i
900 @ l ' , Contact: Jim Foley x3049 600 - : 300 . ! ., Q , . .. 3 4 i - . 4-. 4 j- 9 v. 9- w-+__.,---- -t--t--" - - v - - f - r -- - t - - + - - t--- -- -1 -- t - 4 e o ~ x-. -..~e m m e e m m e e ,
- - c
- - - - - - i I . _ _ _ .~ _ . _ _ ___ _ _ _ _ _ _ _ _ . . . _ . _ . _ _ _ _
, i
i
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. ---y---.-~~~-.~,----.. - - - . . _ . . - - . - - . _._ _. . . . _ _ .. _ A/Rs LATE ~
! .
TOTAL LATE NRs ; t._-__. 600 j - i I > l 500 l ' ,
$ 400
;5 DATA NOT b 300 AVAILABLE O Contact: Jim Foley x3049 ,,, , _ ! 100 i .
i O , ..+ _, p_y y 4__,- +. + -t - + + - r - -- t - - H 4 -- r ---t - - - - H- - v t - 4-- + ---- + - - -9 - - 4 n o s v - e m -m o a m o m m o e a m o i I
l -
- - - - - - _ i _ _ _ _ i
~
:
_ _ _ _ . _ . _ _ _ . _ . _ . _ . _ _ . . -_. ._ _ . _ . . ._ .______.____.___.._1 - OPEN ACRs 200 _ _ _ _ _ _ _ ! t STARTED AT 149 * 180 , , ACRs PRIOR TO 10/9/96 THAT i L - I ' ARE IN , , OPEN 160 ! STATUS . . OPEN - 18 (95),130 (96) ; t :to ! l. __. . ._ . . _ \. 120 I 100 80 , ' ' l so , - - i , ! ' i - i , 40 i f I . ! ' l i l 20 i 4 . -i - ! I l 1 i i , I i 0 - - - e - e- - - - - - - - - - - - - -- +----+--"----4--- +---+-----+-------+--- - - - - t , n o N y e e m e e m N G m N m W O N O O ! $ C * U 5 ~ C U N $ C N b C C U K e Q e Q e e N h A e e - e h" N R n n R , e e e e e w ,
' . - - - . . . - - --
, t ; l ! . - - - - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ ____._________.____________________________________________________s. , .- ,s- -
... _ . _ _ . . . _ _ _ . . . _ _ _ . _ _ _ _ _ _ _ _ . . _ . _ _ . _ _ _ _ . _ _ _ - ._ . _ _ ._ _ . _ .. _ __ _. _ . _ . _ _ _ ... _ ____ _ . __.. . _ _ __ _ _ . ~ i, t 1 1 . . t i ! -- -- _ _ _ _ . _ _ _ . - . _. . . _ _ . _ . _ _ _ _ _ TRACKED ACRs I . ! 250 . - . STARTED AT 194 225 j ; ._ _ . _ _ _ _ . _ _ _.. ! i I . i ACRs PRIOR TO 10/9/96 THAT 200 1 t i ' ARE IN . TRACKING STATUS - t , 175 t ' i' l ! j 59 (95),132 (96) ' t 150 I t t i
'
125 ! I : too ! i i ! 75 - i i l - l' : l ! , * ! 50 . , , 25 .c , i l I h' 0, - --- - , - - - - - - - - + - - - + - - ~-+- - - - - + - + -r-- -+-n--+---+- +---+--c---+-w-+ - l. n o s v - e c - e e n a e a a e e a m e D D N C C S N C D D N " N N D C - - - - ~ - ~ - - - - - n n" n u" a" n . - - e c - - _ _ . - - - _ - _ - _ _ - - . . _ . . t . - ___ . . _ . - - - - _ . - i I . t e _____s_ ._._-_______.____m.___ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ .__________ _ -_ _ _ _ _ _ _ _ _ _ _
._ . . _ . _ _ _ . _ _ . _ _ _ _ . . . _ _ . . _ _ _ - - - . - . _ . . _ _ . _ _ _ . . . . - . _ _ _ _ _ _ _ _ _ . . _ . _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ , . , ,. ..- ~.. .._ . , . . . . , . , . , , , _ , , , ! OUTSTANDING NCRs
' ' . 200
! 175
.
.. . - . - - . _ . - . . - . . , . . _ . . _ '
, TOTAL OUTSTANDING NCRs
. 150 _ . - . - . - - . - . . . . . _ . _ . . . . i 125 i s tu z 100 DATA NOT o q}' AVAILABLE o >4 i 75 ~ ! 50 Contact: Tom English x3089 l . i 1 ! I i 25 j ; i - l 1. . ; , l i 0 , 4 - ' + 4 * - - ' - - - - " - - , - - --r-- t +- " " E S * 0 $ O R S T N O N $ $ U $ $ = - = - = - 0 a - - a - - " - a a 8 a a n - .. I I i' . !
_ . . . _ . . _ _ _ _ . ._._....._ _ _ .. _ _____ _. _ _._ ._________. __ _._ _____.___._ ._ _._._. _ , .I - - . . - . . _ , ~ . _ . _ _ _ _ . . . _ . . _ _ _ _ _ . . . _ . _ . . . . . _ _ _ . _ . . _ . . , _ _ , , . _ _ . , OPERATIONS PROCEDURES FOR REVIEW I ' 200 , . . _ . _ _ _ . . . i ! ! THIS KPl WILL START WITH A NEW 180t NUMBER EACH QUARTER __._._.-_.._._._, _ __ _ _ _ _ _ _ _ _ _ _ _ ; j STARTED AT 184 160 i ! FIRST QUARTER 1997 i i _ ._ _ ___ _ . .__ t 140 . t
n .
! 120 t i ; 100 t 80 Contact: Michele Marin x3185 i ~ 60 . - i ; 40 + - l ! , . l---- -+ A ' 20 f 7 l I I ' ; Oi 4 - - - - - - - - - - - -- - * + ---~~--* --+--+-'~-~ ~ + ~~-- + - "-- ' - * ~ ~ ~4 I . 0 0 *? E $ = = - - = c a a S - - - - - ; - - a a S a a n i i ~ * _ .__ . , . - . _ . - - - . - - _ . _. _ ! ? i - :
- . -. . -.. . . _ . . . - . _ _ - _ _ . . . . - . . . . . . . . - .. .. -. - -_.. . . - - ~ . - _ - - - . . - . . - . . . . . . . - - . . - . - . , I ! CY 1997 Cummulative Exposure , 5- b * 45- ,o . , * ** * 4- - * t * ACTUAL , e = * I = " GOAL , 35- - -TARGET * # - , * .* a ' * , * # **** pa* ' * # E, e , * c=** I - 4 * , * ,,,,**# ! g25- , p- ! e - , * * *** * A * * ,# ***a=*" . 2 , 6 , * e * .** ,,* # i * * .a** 1.5 - , .s** . * * **=* t * .saa* , e / I * a .==* , .aa * * wa ** * * .s** * **** 05; , .a** , f e Za n* ~ 0 - 1/1 1!S 1/12 1/19 1/26 2/2 2/9 2/15 2/23 3/2 3/9 3/16 3/23 3730 , Week Starting Date !
.*
, _ _ _ _ _ _ _ _ _ _ _ . . _ . . _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ - _ - - _ _ _ . - - - _ . _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _-__ __ _ _ __
.__ ._ . _ _. ..__. ._._._ _ .__ . _ _ _ . . _ _.._.. _ _. _ _ __ .. _ _ _ _ _ . _ _ _ _ . . _ _ . . __ ; ! : i -- -- - - . . _ _ . . _ _ . _ . _ _ . _ _ _ _ _ _ _ _ . _ . _ . _ _ _ _ . _ _ _ , , _ _ _ _ . < ACCIDENTS i 10 , i f I t ' 9i l - ! ; ! ! 8i : t t - l j EMPLOYEE & CONTRACTOR ; 7i ACCIDENT REPORTS PER WEEK i t - _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ > l 6' , i 5', k i ! i 4i , I ' . , 3 - i - ! i . I ! 2 Contact: Jim Lubs x3631 i l i i i l i ! - 1 0 , -- -- t -- -- r-- e F + + I+ 4 I*,FH--H--e +--+---e---4 4 ; ! o o s , ,- m o ,-- m o m m o n m e e n e e ! ! C D D N E E D N N E D D N " D N C C D - - .- - m - a - m - - - - N N" N m m o ,- - - _ _ _ . _ _ _ . - . _ _ _ _ _ . _ . . _ . _ _ _ - . _ _ - 1 l
.-
__.m..- -_.-.._-_.-_______m.____.______-____._..__._m.. _ _ _ _ . _ . _ _ _ . _ _ _ _ _ _ . . _ _ - - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ . ____
_ . . _ _ . - _ - _ _ . _ - - _ . _ . . . _ _ - _ - - - - - _ - _ _ . -- . _._._ ---_. -- -_ - - -- - - . _ - - - - - - - - .- -_- -.
, 4
- Connecticut Yankee
Non-Refueling Yearly Average Monthly Exposure Comparison
J
& D 7.000 -- 6.000 -
, 5.000 - - . -
e
i 4.000 - -
E - e 3.000 --
.
. 2.000 --
! <
. . . 1.000 -- -
! , - l .
. 0.000 --- + + + + + 4-- + + H
i j 89 90 91 92 93 94 95 96 97
Year l Note: data excludes exposures from forced shutdowns, refueling periods and projects - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ - _ _ - _ _ _ _ _ _ - _ _ - _ _ _ - - _ _ . . _ _ _ _ _ _ _ _ - _ _ _ _ - _
,
@ CONNECTICUT YANKEE ATO MIC POWER' COMPANY
G HADDAM NECK PLANT
362 INJUN Hollow ROAD e EAST HAMPToN. CT 06424-3099 December 9,19 Docket No. 50-213 - B16058 * Re: 10CFR20 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Haddam Neck Plant Interim Corrective Actions The purpose of this letter is for Connecticut Yankee Atomic Power Company (CYAPCO) to provide a description of key interim corrective actions CYAPCO has taken related to the November 2,1996 refueling canal contamination incident at the Haddam Neck Plant (HNP).
/ tj CYAPCO takes very seriously the Health Physics Program weaknesses uncovered as a
result of the recent contamination incident. CYAPCO has completed two root cause investigations and is in the process of conducting an Independent Review Team investigation. Corrective actions have been proposed and are under management review. Upon cor,ip'etion of these investigations, long-term corrective actions will be implemented, Until such time, CYAPCO has implemented many interim corrective actions. Provided below, are the key interim corrective actions that have been implemented. Backshift and Weekend WoIk 1. The only backshift and weekend work that may be performed-is that which is in direct support of the operations shift; 2. The Unit Director must approve any work conducted under item 1; 3. Any work performed on backshift or on weekends must have appropriate supervisory and managerial support; 4. The formal 6-week look aberd scheduling process and the tracking of schedule adherence has been reinctituted; and 1026-3 REV 2-91 l .
' h. 4 . . U. S. Nucle:r R guir, tory Commi:sion - B16058/P;ga 2 . ,; . +0hp 5. The Key Performance Indicators for the cc.1 duct of work in progress will c. <c.. . . _ _._ . ... be monitored on a weekly basis. Restriction of Work in the RCA (Radiological Control Area)
.I '
No work will be performed in the below listed areas except for routine operator rounds and Technical Specification suiveillances that are due: , 1. Spent Fuel Pool
'i
2. Reactor Cavity 3. Any Technical Specification Locked High Radiation Area, which currently consists of the following: * RHR Cubicle ~
d
* PAB Pipe Trench * lon Exchange Pipe Trench * Spent Resin Facility * CTMT Loops Areas * Regenerative Heat Exchanger Area O * Pressurizer Spray Valve Area 'V * Drumming Room Demineralizer Area This restriction will remain in effect until appropriate long' term corrective actions - have been implemented. If work must be performed in the above areas prior to the implementation of the long-term corrective actions, it must be approved by the Work Services Director or the Unit Director. Prior to approval, the director will verify the need to perform the work at this time and will verify that the job is adequately planned and prepared for. The backshift and weekend work interim corrective actions were implemented by memo from J. J. LaPlatney (Unit Director) on November 25,1996. The restriction of work in the RCA interim corrective actions were implemented by memo from G. H. Bouchard (Work Services Director) on November 26,1996. * The interim corrective actions dealing with the backshift and weekend work; and the restrictions on work in the RCA will remain in effect until the long-term corrective actions are implemented. , .
. . . . - 1
, U. S. Nuci:rr Regul:: tory Commi:sion
B16058/Prga 3 l
By restricting backshift and weekend work, the root cause of insufficient management oversight and insufficient task preplanning is temporarily alleviated. The restrictions on < . work in the RCA assure that the root cause of inadequate Health Physics controls is not repeated, l
i' The following are CYAPCO's commitments made within this letter. Other statements
within this letter are provided as information only. ' B16058-1: l Upon completion of these investigations, long-term corrective actions will i be implemented. I B16058-2: The interim corrective actions dealing with the backshift and weekend work; and the restrictions on work in the RCA will remain in effect until the long-term corrective actions are implemented. , ' B16058-3: The Key Performance Indicators for the conduct of work in progress will be monitored on a weekly basis. : If you should have any questions, please contact Mr. G. P. van Noordennen at '
a (860)267-3938. -
Very truly yours, ; i CONNECTICUT YANKEE ATOMIC POWER COMPANY .
'
k T. C. Feigenbaurff
Executive Vice President and
i
Chisl Nuclear Officer cc: H. J. Miller, Region 1 Administrator , S. Dembek, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident inspector, Haddam Neck Plant Mr. Kevin T. A. McCarthy, Director Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street P. O. Box 5066 Hartford, Connecticut 06102-5086 O V 9
}}