ML20140C432

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Transcript of Commission 860319 Periodic Briefing by Regional Administrators in Washington,Dc.Pp 1-72.Supporting Documentation Encl
ML20140C432
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Issue date: 03/19/1986
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REF-10CFR9.7 NUDOCS 8603250355
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ORIGINAL .

UNITED STATES OF AMERICA -

I NUCLEAR REGULATORY COMMISSION In the matter of:

COMMISSION MEETING Periodic Briefing by Regional Administrators (Public Meeting) i Docket No.

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k Location: Washington, D. C. i Date: Wednesday, March 19, 1986 Pages: 1 - 72

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l 8603250355 860319 PDR 10CFR PDR PT9.7 ANN RILEY & ASSOCIATES Court Reporters I s_ 1625 I St., N.W.

Suite 921 Washington, D.C. 20006 (202) 293-3950

I 1 D I SCLA I MER 2

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This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on s 3/19/86 .

In the Commission's office at 1717 H Street, 9 N.W., Washington, D.C. The meeting was open to public 10 attendance and observation. 6 This transcript has not been 11 reviewed, corrected, or edited, and it may contain i

12 inaccuracies.

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The transcript is intended solely for general l

14 informational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorire.

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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3

4 ------

5 PERIODIC BRIEFING BY 6 REGIONAL ADMINISTRATORS l 7 ------

8 9 Public Meeting 10 11 1717 H Street, N.W.

12 Room 1130 13 Washington, D.C.

14 Wednesday, March 19, 1986 15 16 The Commission met in open session, pursuant to 17 notice, beginning at 10:15 a.m., the Honorable Nunzio 18 J. Palladino, Chairman of the Commission, presiding.

19 COMMISSIONERS PRESENT:

20 Nunzio J. Palladino, Chairman 21 James K. Asselstine, Commissioner 22 , Frederick M. Bernthal, Commissioner 23 Thomas M. Roberts, Commissioner 24 Lando W. Zech, Jr., Commissioner i 25 l _ _

2 1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:

2 V. Stallo 3 H. Denton 4 T. Murley 5 J. Martin ~

6 J. Tayl'or 7 M. Blume 8 A. Bates 9

10 AUDIENCE SPEAKERS:

11 J. Partlow 12 G. Cunningham 13 J. Zwolinski 14 15 16 17 18 19 20 ,

21 22 1

23 24 25

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1 PROCEEDINGS 2 CHAIRMAN PALLADINO: Good morning, ladies and 3 gentlemen.

4 This morning the Commission is meeting with the 5 Agency's regional administrators for Regions I and V. The 6 meeting with the administrators of Regions II, III and IV is 7 scheduled for next Wednesday.

8 The Commission holds these meetings periodically to 9 discuss topics of mutual interest such as major 10 accomplishments, current and planned improvements, 11 region-specific problems and highlights of specific plant 12 activities.

13 Our last such meeting was held in October 1985.

14 In the first part of our discussion this morning, 15 Dr. Tom Murley, regional administrator for Region I, will 16 discuss emerging new inspection approaches, including 17 PRA-guided inspections and intensive operational team 18 inspegtions.

19 Then Mr. Jack Martin, regional administrator for 20 Region V, will discuss the augmented resident inspection  !

21 program, regional team inspections and program management.

22 I expect that if there are any problems or issues 23 that they feel need Commission attention in the near future, 24 the regional administrator will identify them.

25 Unless other Commissioners have opening remarks at

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1 this time, I would propose to turn the meeting over to 2 Mr. Stallo, the Acting EDO, who will make some preliminary c

! 3 remarks before the regional administrators begin. '

! 4 Do other Commissioners have opening remarks?

5 COMMISSIONER ASSELSTINE: No.

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1 6 COMMISSIONER ZECH: No.

4 7 CHAIRMAN PALLADINO: Vic.

8 MR. STELLO: Thank you, Mr. Chairman.

9 We have in addition to Tom Murley and Jack Martin, 10 Messrs. Denton and Taylor, directors of the principal program 11 offices responsible for'many of the programs conducted in the 4

12 region,.and they are sitting here at the table with us today, 1

13 and I expect they will participate in some issues that are 14 going to come up.

15 One of the things that I think you will see in the 16 discussion today that is evolving is the recognition that 17 there are some new ways in which to approach inspection of 18 these plants, different than we have done in the past, that 19 are starting to appear to have significant benefit in being 20 able to define-the kinds of problems that we have had in the 21 past, and put them into focus in a way that maybe will lead us 22 to being able to get these problems resolved faster than we i 23 'have in the past. It is one of the things that you recall we

24 have dealt with over a long period of time, in talking about 25 some of the plants in the past like Davis-Besse, what is it l

5 1 that didn't allow us to get problems corrected sooner.

I 2 We will be talking about some of the things that 1 3 help us to make sure we understand that better, and then at 4 the end of the meeting perhaps we could spend a few minutes 5 about how we are going to try to come to grips with are there 6 some new ways of going about trying to solve those problems.

7 With that, let me turn to Tom Murley to start, and 8 he's got some new things that have been going on in Region I 9 that are now starting to show some insights I think are very 10 important.

11 Tom.

12 MR. MURLEY: Thanks, Vic.

13 Mr. Chairman, in preparing for this meeting, I 14 guess, we started to ask ourselves where is the inspection 15 program heading, and in the early days -- that is back in the i

< 16 old AEC days, even -- it was primarily a compliance-oriented 17 inspection program; that is to say, the inspectors' main goal 18 was to ensure compliance, determine compliance with NRC j l

19 regulations and ensure compliance.~

20 We still do that, of course, but my sense of things 21 is that more is being expected out of our program today. Vic 22 alluded to the Davis-Besse situation. .When I read the 23 newspapers, when I read what Congress is asking, and even what 24 the Commission sometimes asks, is why didn't you find out 25 these problems. Why didn't you take some steps to correct l

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6 1 them. And so what seems to me is that the inspection program 2 is being expected to be able to diagnose operational problems 3 at plants, and even management weaknesses, to some extent.

4 And this is driven, I think, more and more, by the 5 SALP process. We find that we are spending a large fraction i 6 or a large amount of time preparing the SALP reports, and what 7 we find is the toughest part -- at least from my point of view j 8 -- is trying to make some kind of overall management judgments 9 on what does this all mean.

10 We get a mass of inspection reports throughout the l

11 year, but to try to put it together and find weaknesses --

12 some are obvious, but frequently they are not. And so where 13 this all is leading is, I think, to more emphasis on 14 diagnostic type inspections as opposed to what I call 15 compliance-oriented inspections.

16 We can use to some extent performance indicators, 17 and we get some help from NRR and from AEOD in that regard as l

18 to how plants stack up with regard to trips and various other 19 indicators. But, really, that is only one input. I think 20 there is no substitute for a kind of management overview of 21 what the inspection reports mean.

22 So this change in expectations has led us in the 23 region to try some new things, and I guess the first one I 24 want to talk about is what are called an intensive operational 25 team inspection.

We tried it at TMI-1 in the restart last

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7 1 October, when the plant was given the final go-ahead to 2 restart.

3 We had a team there of inspectors led by a senior 4 manager, and we followed it around the clock pretty much, 5 either 24 or 16-hour coverage for three months. The intent 6 was to focus on how well they were operating and how well the i 7 plant was operating and so forth.

8 We had never really done this before, at least on 9 this scale. We had in the team 11 different resident 10 inspectors from eight sites. We found that it was important 11 -- at least I wanted to get the broadest possible evaluation 12 of how this Licensee and this operation stacked up with other 13 plants, particularly B&W plants.

14 CHAIRMAN PALLADINO: You say eight -- 11 resident 15 inspectors?

16 MR. MURLEY: 11 resident inspectors, not all at 17 once, but during the three-month period. And they came from 18 not only TMI, but Calvert Cliffs, Oconee, Arkansas, Crystal 19 River, Turkey Point, McGuire and Wolf Creek.

20 4

CHAIRMAN PALLADINO: And which plant did you do this 21 on?

22 MR. MURLEY:- This was on Three Mile Island 1. And, 23 of course, as you can tell, we had inspectors from Regions II, ,

l 24 III and IV, plus the Chattanooga Training Center, in addition 25 i to our own inspectors, and in addition we had five examiners l

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. j 8 I 1 that came from Idaho Lab and Pacific-Northwest Lab.

2 So, all in all, we had 30 different inspectors there 3 during this period, and we put in 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> of inspection 4 time on site during the three-month period. That is roughly a 5 level or a factor of four higher than we do normally.

i 6 The Staff, after this was all done -- of course, we 7 had to make decisions during the time. There were six hold 4

8 points that we had during the restart of Three Mile Island 9 where I had to give them approval to move on to the next level 10 of their start-up. So I was very much involved.

11 I also had a senior SES manager, Bill Kane, who was 12 there on site full time, who coordinated all this, and helped 13 me make sense out of it.

14 COMMISSIONER BERNTHAL: You said this was three 15 times the normal effort compared to what?

16 COMMISSIONER ASSELSTINE: Operating plant.

i 17 MR. MURLEY: To a normal operating plant.

4 18 COMMISSIONER BERNTHAL: What kind of inspection are 19 we talking about?

20 MR. MURLEY: Actually it was four times the 21 inspection hours that we give to a normal plant.

22 COMMISSIONER BERNTHAL: In the SALP type evaluation?

23 MR. MURLEY: Yes. In every SALP we list the number j

l 24 of inspection hours, and it's typically 3000 for a year. Here 25 we have 3000 in three months.

9 1 COMMISSIONER ZECH: And 30 total inspectors, is that 2 what you said?

3 MR. MURLEY: Yes.

4 My staff is unanimous that this inspection was 1

5 effective and worthwhile. Of course, we can't do it for every 6 plant. We don't have the resources.

7 The resident inspectors were enthusiastic about it 8 because they saw the value of it and, furthermore, they like 9 it because they are relieved of a lot of the paper work 10 burden. They come in and their sole job is to poke around the 11 plant, wherever their nose leads them.

12 Sometimes we give them assignments to look in 13 certain areas like maintenance. Other times we just tell them 14 to follow their noses. And because each resident brings to 15 such an inspection a different perception from his own plant, 1 16 we get a good cross-fertilization. Some inspectors like to 17 look at fire protection; others look at procedural compliance;

! 18 others look at maintenance and so forth.

19 CHAIRMAN PALLADINO: Is there any effort to make 20 sure that the total spectrum of activities is looked at?

l 21 MR. MURLEY: Yes, we do draw up an inspection plan 1

22 ahead of time to make sure that the things that we think need 4

j 23 to be covered -- that is, the management -- are covered.

4 24 So this.I characterize as a success from the point 25 of view of an inspection program. We looked at how well i

10 1 operators performed and followed procedures; of course, how 2 well the equipment itself performed.

3 I think we were able to get a good handle on the 4 overall strength of the company policies and procedures and 5 how well the people at the top set the tone for the whole 6

operation on the island and did it filter down to the working 7 level.

8 And then finally, of course, the management 9 involvement on the site. '

10 CHAIRMAN PALLADINO: Did you look at middle 11 management? That's often where problems seem to occur.

12 MR. MURLEY: Yes, that seems to be where the 13 residents like to focus; that is, the shift supervisor, 14 operations manager level. They deal a lot at that kind of 15 level.

16 In summary, then, I think that that team inspection 17

-- I call it intensive team inspection -- at TMI was very 18 useful and was going to serve as a prototype for other cases.

19 To follow on, we have done a similar -- just 20 completed a similar inspection on a less grand scale at 21 Pilgrim.

The impetus for this was a SALP report in early 22 January that when I got the draft of it, I was a little 23 concerned, because it showed poor performance in operations, 24 and in some areas they had been backsliding from previous 25 i years, and I wanted to make sure, first of all confirm, that

11 1 the findings in the SALP report were real; and second, to see 2 if there were any other problems that maybe we hadn't looked 3 at during the year.

4 So we set up the same kind of a team that this time

! 5 was headed by a branch chief from the region, and we did it 6 for a three-week period that just ended March 4th, and we had 7 24-hour inspection coverage. Here we had five resident 8 inspectors totally from the region, but from other plants that 9 had not been involved with Pilgrim. They were from Vermont 10 Yankee, Oyster Creek, Yankee Rowe, Susquehanna, in addition to 11 the Pilgrim resident. Plus we had some region-based 1 12 inspectors that joined them.

13 I expect the inspection report will be out next 14 week. They did find that the safety of the plant operations 15 was adequate. There was no reason to be concerned about 16 knmediate plant safety. But, of course, they did find a 17 number of problems, and I think in general they confirmed the i

18 SALP findings, and I was kind of pleased that that -- we 19 didn't set out to do that, but --

20 CHAIRMAN PALLADINO: This wasn't the SALP 21 evaluation?

I 22 MR. MURLEY: Totally independent of SALP. In fact, 23 to some extent, it was almost orthagonal to it. It's'a 24 different group of people coming in, looking -- as I said, 25 they find that this around-the-clock coverage, where you can

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I 12 1 look at the back shifts and see how people do surveillances 2 when nobody is looking, so to speak, is important. The plant 3 management is not on site at that time, the senior plant 4 management, it's the shift supervisor.

5 And those kinds of inspections do, I think, reveal 6 just how well the operation of the plant is being conducted.

7 I'm not ready yet to draw any final conclusions. I 8 think clearly Pilgrim is a plant that we have to put some more 9 time in on, and I want to be talking with Vic and Harold and 10 Jim Taylor to tell them our conclusions and also get their 11 conclusions and see where we go on that.

12 I have met with the utility management at Boston 13 Edison and at the SALP meeting they did have the senior 14 =anagement and some members of the board there. And so they 15 are aware of our concerns and we will be talking with them 16 more.

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17 But in summary, I and my staff are convinced that l

18 this type of inspection,'although very resource-intensive, is 19 an effective tool that we can use to augment our normal 20 inspection program and our normal SALP process, and I expect 21 we will be using this more, even.

22 CHAIRMAN PALLADINO: Particularly where you think 23 you have problems.

24 MR. MURLEY: Yes.

25 CHAIRMAN PALLADINO: I'mean it's particularly a good

13 1 tool in those kinds of circumstances.

2 MR. MURLEY: Where you have problems in operations, 3 yes, and the maintenance and surveillance and that kind of 4 area.

5 CHAIRMAN PALLADINO: You said it was an effective 6 program at TMI, and that could accomplish a lot of things.

7 You put out a report. In whataway was it effective? Because 8 it found a lot of new information? Because it jacked up the 9 people that were working?

10 MR. MURLEY: Well, I meant it-in the sense of 11 cost-effective, because even though it was four times more 12 intensive than normal, and we used a lot of help from other 13 regions, I think it provided me-with the basis I needed to 14 make the kinds of decisions --

15 CHAIRMAN PALLADINO: I could see it where you had 16 those decisions to make.

17 MR. MURLEY: Yes. And it was, I think, effective 18 almost in a negative sense for what it didn't find. It didn't '

19 find the kinds of problems that we have since seen at Pilgrim 20 and at other plants. It gave us a confidence, I think, that j 21 the management improvement that they have made at that site 22 over the years has been effective. I think that is useful to 23 know, to have.

24 And to have it from so many different viewpoints, 25 different regions and different plants, is what gave me the

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14 1 confidence, I think. So I meant it from a cost-effec'tive 2 point of view. And even we have burned up 3000 inspection 3 hours, I think it was well worth it.

4 COMMISSIONER BERNTHAL: What did the -- I don't 5 suppose TMI is the right place to inquire in Pilgrim -- have 6 you had any utility feedback on -- I say TMI, because it was 7 such an abnormal situation, but have you had utility l 8 management feedback on your findings on the effectiveness and j 9 thoroughness of this kind of heavy-duty inspection effort?

10 MR. MURLEY: Well, we have from TMI.

] We are not l 11 finished yet at Pilgrim. At TMI, they were apprehensive about j

12 the scope of coverage overlaid on their own. I mean they had 13 their own audits going on at the same time, and we had someone 14 in the control room virtually the whole time we were there, in 15 addition to people walking the plant, and they thought it was 16 going to put such a stress on their middle management that it

.. 17 would have a negative safety impact, and they were quite l 18 candid with me about it up front. But as we got into it, and 19 at the end of the program, they concluded that it was not I 20 disruptive, .and that in fact -- although I am not sure we will l 21 hear them say it in these words, I think we did them a good-22 consulting service, because we did point out problems that i

23 needed to be looked at, and the management there -- they have 24 a vice president on site, Mr. Huykill. He appreciates a 25 different set of views coming up to him that he can deal with.

15 1 So all in all I think at TMI they would view it as 2 positive.

3 At Pilgrim, I think they had even more apprehension 4 because they knew ahead of time that we had some problems with 5 the plant, and they were -- as some of our residents said --

6 kind of on their best behavior for the three-week period we 7 were there.

8 Nonetheless, I think we did get a fair cross-section 9 of the operation and it is too soon to tell whether -- and I 10 haven't gotten back to the management yet to find whether they 11 think it was useful or disruptive. It's just too early to 12 tell.

13 CHAIRMAN PALLADINO: Tom, how in concept does this 14 differ from PAT or CAT in their respect of the spheres of 1

15 activity?

16 I MR. MURLEY: That's a good question. There are, of

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course, a number of diagnostic type inspections that are done j l

18 already. Jim Taylor's staff runs construction team 19 inspections and those, of course, are totally different. They 20 go in with experts and electrical-mechanical QA and so forth, 21 and judge how well the plant is being built and how well it is 22 being managed.

23 CHAIRMAN PALLADINO: Was the performance appraisal 24 team for operation?

25 MR. MURLEY: Yes. Jim, why don't you --

16 1 MR. TAYLOR: The PAT concept was to take a group of t

2 people and sometimes including region people and go in and 3 look at management controls through the whole spectrum. It 4 was not the type of coverage of hour by over overview of 5 operations. Each individual in the PAT discipline looks at 6 the training and goes through that whole process and tries to 7 establish first of all are they meeting basic requirements on 8 the effectiveness of'the training program?

9 Operations is one of the areas done, but that's 10 usually one person. So clearly it is around the clock. They 11 . dig into the back-up to operations, the management support to 12 operations, the up-to-date drawings, the up-to-date 13 information. Do the operators really know what's going on, do 14 they know the status of the plant, do they know that a pump is 15 down when a pump is out of commission.

16 CHAIRMAN PAILADINO: Some of those things could 17 overlap.

18 MR. TAYLOR: They could overlap, but the concepts 19 are somewhat different. Now, of course, as you know, we are 20 using basic PAT resources to go much deeper with appropriate 21 support to the engineering aspects, and there is, as requested 22 by the Commission, that type of inspection going on right now l 23 at Three Mile Island 1. It-is a different look, but we were l

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24 asked by order -- you know, the start-up business -- to do 25 that.

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17 1 So Tom had the view from the hour-by-hour 2 operations. In a few weeks we will be giving you a view from 3 a slightly different perspective. I think we are looking at 4 the effort in a generic sense that Tom has developed as 5 another diagnostic approach to put in our possibilities and 6 applying it, and we supported what he was doing. Certainly we 7 knew full measure why at Three Mile that was so important, 8 because of the situation with that plant.

9 We knew we couldn't afford to support him to that 10 degree at Pilgrim, but again we look at it as a diagnostic 11 method, and will look to its applicability in other regions.

12 You can't quite tell in ops, and surveillances, particularly, 13 what's going on, maybe you go to around-the-clock for a few 14 days, a week or two or something, to try to. add to the depth 15 of your information.

j So that's the way we are looking at 16 this.

17 COMMISSIONER ASSELSTINE: Is this similar to the 18 kinds of reviews that INPO does in terms of their periodic or 19 annual site evaluations?

20 MR. MURLEY: It's the closest thing that we do to 21 what INPO does, and I'm not, I guess, sufficiently familiar 22 with just exactly how they -- but they come 'in for like a- two 23 to three to four-week period, and they do cover the site and 24 watch things in progress. I don't know that they go on back 25 shifts so much.

18 1 COMMISSIONER ZECH: They do.

2 MR. MURLEY: And so I guess it's similar.

3 COMMISSIONER ASSELSTINE: It might be useful for 4 you, when you get your inspection report for this effort, to 5 compare it to the most recent INPO report on Pilgrim and see 6 whether they identified the same things that you identified, 7 whether they identified different problem areas, or whether 8 they just didn't pick up en some of the points.

i 9 MR. TAYLOR: A lot of what INPO does is some 10 combination of that PAT type look at management controls.

11 They have a few more people usually in an INPO team, and so 12 they get deeper than PAT does in the hour-by-hour and back 13 shift checks and things like ops.

14 So, again, they are using sort of a marriage, as I 15 look at it, of the two methods.

16 COMMISSIONER BERNTHAL: Do we routinely get access, 17 though, to all of the INPO conclusions?

18 COMMISSIONER ASSELSTINE: Sure, they're at the 19 sites.

20 COMMISSIONER ~BERNTHAL: I was under the impression 21 we didn't have full access.

22 COMMISSIONER ASSELSTINE: We don't get copies of it, 23 as I understand, we don't get the underlying notes of the 24 people that they take when they are actually.out at the site, 25 but we get access to the report that they write based upon

19 1 their visit.

2 MR.' TAYLOR: Commissioner Asselstine is right --

3 excuse me -- we have formalized our process by instructions to 4 the regions on how the individual inspectors at the plants, 5 branch chiefs, section chiefs going out to Duane Arnold, for 6 example, just to take a plant, at how to look at the INPO 7 reports and materials which are there on the sites, you know, 8 some number of months after INPO had been there.

9 COMMISSIONER BERNTHAL: My concern was that there is l 10 enough information that you can get a comparison.

i 11 MR. TAYLOR: Yes, and we have worked with the 12 regions to be sure we get a uniform process.

13 COMMISSIONER BERNTHAL: Well, if that is the case, 14 then after several comparisons, does this become a duplicative ,

15 effort? That question arises. '

16 MR. MURLEY: I don't think, quite frankly, that we 17 will ever totally agree with INPO.

They are always going to 18 find things that we don't find and vice versa.

19 COMMIS9IONER BERNTHAL: Sure.

20 MR. MURLEY: And --

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21 COMMISSIONER BERNTHAL: But you'd find things if a 22 third party similarly did an inspection.

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23 MR. MURLEY: You see, the resident inspectors are a 24 unique resource for this agency. They spend full time at a 25 plant, and so they learn to know how it works in their morning

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1 meetings, how they approach issues and problems at a plant.

2 INPO people, insofar as they only spend a few weeks at a 3 plant, don't have that.

4 So when I get together a group of a half dozen 5 resident inspectors, let's say, they bring to it a kind of 6 synergism that we have to take advantage of, it seems to me, 7 in being able to look at the overall operations.

8 COMMISSIONER BERNTHAL: Yes, that's a good point, i

i 9

It's true that they are the only people that work for the NRC, 10 I guess, that on a daily basis observe and are in the presence 11 of plant operations.

t 12 MR. TAYLOR:

i INPO only gets there every 15 months or 13 so, too, remember.

14 COMMISSIONER BERNTHAL: Yes.

15 COMMISSIONER ZECH: But it might be useful when we 4 16 get INPO up here the next time to ask them about their 17 inspection procedures so we get a feel. It is my 18 understanding that they do go about it in a little different 19 way, and you could expect perhaps different results.

I 20 But also I think it's important, at least -- and my 21 understanding is that even your SALP review of Pilgrim came to 22 somewhat different conclusions than this all-resident j 23 inspector team, and there were different type of assessment in 24 some areas. Is that correct?

25 MR. MURLEY: There were two areas that jump out

21 1 where this team found a little bit different -- they found a 2 strength at the first level of management at the plant that we 3 had not realized, and that I didn't know about from our SALP 4 evaluation. That is to say they said that the shift 5 supervisors and that kind of level were actually very good at 6 Pilgrim, and that insofar as there were problems, they seemed 7 to be higher up in management.

8 COMMISSIONER ZECH: But this also was something that 9 your resident inspectors obviously had not concluded. I i

10 presume they were part of your SALP review, so that was an 11 interesting observation, I think, on the part of the team in 12 that it was different from what your resident inspector's i

13 annual SALP group had concluded.

14 MR. MURLEY: Yes. The resident at Pilgrim very much 15 welcomed this and he learned something, too.

16 COMMISSIONER ZECH: But my point is there is value 17 in different viewpoints.

18 MR. MURLE5: Absolutely.

19 COMMISSIONER ZECH: And we shouldn't necessarily  ;

20 expect them, each group, to come up, INPO, your group, 21 residents, SALP, whatever. But I do think the other thing to 22 realize is that it's important to do these kinds of 23 inspections, especially at the so-called trouble plants, l

24 because it does show you a different perspective, and I think 25 there is great value in the different perspectives, and l

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22 1 different people coming in, and I think we have seen that 2 apparently at Pilgrim and other places, too. So I think we 3 should not necessarily, even though there probably is in some 4 areas some duplication, it's at least my experience that the 5 type of inspections that we are talking about, like the CAT, 6 the PAT, the SALP, the special inspection groups, that's our 7 job, and I think there is value in watching that we don't 8 duplicate too much of a degree, but that we get the judgment 9 call, and it comes to you, it should be extremely valuable, 10 and it seems to me that these inspections, although we also 11 should always discipline them to the extent that they prove 12 productive, we should not necessarily expect to always come up 13 with the same results. And I think it is valuable, especially 14 for your plants that you have some concerns about.

15 MR. MURLEY: Yes.

l 16 COMMISSIONER ASSELSTINE: I agree with that, Lando.

17 The only reason I expressed av C;terest was because it would 18 just be interesting to kncy Q4 ' HA check, both on the INPO -

19 process and on our own --

20 CHAIRMAN PALLADINO: I think it would be worthwhile 21 to make that comparison. That's the point I wanted to 22 confirm.

23 COMMISSIONER ASSELSTINE: But where you have a 24 problem plant, where we have seen some problems, were there 25 problems that we didn't focus on that were identified by some

23 1 of these other efforts?

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Or, conversely, do we see problems 2 that others didn't pick up on? It would be useful just to 3 know that'as a check. But I agree, there is a value in having 4 this range of efforts with different perspectives.

5 MR. MURLEY: Could I caution that you don't push us 6 too hard on that. Because if you wind up insisting that we 7 cross-compare and have to justify every time we don't miss --

8 or we miss something at INPO, then we're going to wind up 9 reading their reports before we go and finding the same things 10 that they found, and vice versa. So I hope we keep our 11 independence.

12 CHAIRMAN PALLADINO: I think you should keep your 13 independence, but it's worth a check.

14 MR. MURLEY: I understand.

15 COMMISSIONER ASSELSTINE: It's an after-the-fact 16 check.

17 CHAIRMAN PALLADINO: Well, why don't we try to go 18 on to the second item.

19 MR. MURLEY: Now we kind of shift gears a little bit 20 and talk about something that I don't have immediate results 21 to show, and I think I'm talking about a long-range l 22 development of inspections that use the safety insights that 23 come from the PRA risk assessments.

24 One of the things that struck me most when I went to 25 the region was just how different the perspective is than from

l 24 l l 1 back here at headquarters, and one of.the differences is that 2 here's a third of the agency, in terms of resources, and an 1

3 increasingly important part that has almost no involvement at 4 all with risk assessment and --

,' 5 CHAIRMAN PAILADINO: With the what?

6 MR. MURLEY: No involvement or awareness, even, of

. 7 the risk assessment tools'and insights that have been gained 8 over the years, and a lot of the important research results 9 have been used to develop these risk assessments, we find, are 10 not being used in the regions.

11 Furthermore, I'll go even further. They are not 12 being used very much at the plants themselves by the operating '

13 staff. It tends to be -- the risk assessments that have been 14 done by the utilities tend to be done by an engineering group i

15 back in their headquarters and they deal back and forth with 16 Harold's staff, and you find that it's not really filtered i

17 down to the operating staff, the plant manager and his staff.

18 So a couple of years ago, I. started to get our own 19 staff to develop how can we use these safety insights, and we

20 have done a couple of prototype inspections, and I'll tell 21 you, I see here also the benefits coming to us and to the i

22 Licensees, but it is going to be a long term process.

1 23 A PRA-driven inspection, we call it, or guided 24 inspection, has the same features as other team inspections; 25 namely, multi-disciplinary teams, so we get the synergism, and l t

u

25 1 it looks in depth at certain systems.  ;

2 The feature that is unique to these is that it uses i 3 the PRA insights to tell us what is important at that plant to 1

4 look at; what are the high risk -- or I should say at least j 5 the' dominant accident sequences. If it is station blackout, I

6 loss of AC power, then we know to concentrate on the diesel 7 generators, on the power generation system and that sort of 8 thing.

9 We have looked at Calvert Cliffs, where we took an 10 accident sequence from the PRA that was an important one, loss

, 11 of DC power, combined with a small loss of coolant accident,

, 12 and we followed the sequence through asking ourselves what 13 kind of equipment needed to be operational to mitigate it; 14 what was the maintenance procedures; how often was 15 surveillance done. We looked at the human factors. If an 4

16 operator had to go out in the plant and manipulate some 17 equipment, did he know how to do it. You can see by following 18 through an accident sequence like this, it's a different type 19 of inspection than we normally do, and it can illuminate some l

20 weaknesses that we might not find. '

21 And, furthermore, there is no artificial distinction l 22 here between safety-related and balance of plant. We look at 23 everything that is important to risk in terms of these 24 accident sequences.

25 We have done a similar one at Millstone on loss of

- _ - _ - . _ - - . . . . - _ - - _ - . -- . . , . _ ~ _ . -

26 1 AC power, and we are planning some'other ones. Also, I should 2 point out that these risk assessments tell us'that there is 3 generic safety problems, or that we ought to be concerned 4' about generic safety problems like Event V, the intersystem 5 LOCA between high pressure and low pressure' systems. Rather 6 than try to guess _whether that was a problem in every one of 7 our plants, we took a look at all of them, and we looked at 8 the valve line-up, how many isolation valves, how many check 9 valves, what was the maintenance procedure, and so forth.

10 We did a quick look of all the plants, and we have 11 concluded that there is about a half dozen, I think, BWRs that 12 we want to go back and look at in more detail with teams 13 because they seem to have some susceptibility.to human errors 14 to defeat this system of valves between the high pressure and 15 low pressure system.

16 The benefits that we see from these types of risk 17 assessment inspections are -- I guess there's three. The  ;

18 first one is, it's going to get our own inspectors to be aware

{

19 and sensitive to what are the important risks at the various i 20 plants, because it's really different from plant to plant.

21 Each one is unique.

22 Second is it gives them a better preparation in 23 going out on their inspections. They know exactly what they 24 are going to look at and why, and they know how this certain 25 component has to function during the accident, and so it's not i

j '

1 l

. - - - - - - - - - - - - ~

l i 1

. v 27 I 1 like, well, this time I'm going to do a maintenance inspection 2 so I'll just-look at all the maintenance records. Here they 3 are looking at maintenance on a particular piece of equipment 4 and they want to know how it's going to behave, what kind of 5 maintenance was done on it, surveillance,.and so forth.

6 And I think finally a key benefit could be it's 7 going to focus the attention of the plant operating staff 8 itself on the safety insights from risk assessments.

9 The one plant I went to first was the Calvert. Cliffs 10 plant and they didn't have a risk assessment on site and they 11 didn't really know in any kind of depth at all what it said 12 for their own plant. And I think if we can get those kinds of 13 -- if NRC emphasizes something, then by definition almost the 14 Licensee and the plant staff have to pay attention to it.

15 So by us doing that, I think we can get the 16 information and the insights out into the plant where it 17 belongs.

18 So, in summary, that's a second longer range type of 19 inspection. I think I don't want to oversell it at this stage 20 because we just don't have enough experience yet under our 21 belts to tell, but I'm encouraged that this is where we need I 22 to be spending more of our effort.

23 MR. TAYLOR: I think what --

24 CHAIRMAN PALLADINO: Excuse me. Go ahead. I 25 MR. TAYLOR: I was going to say the headquarters l

28 1 inspection program staff has been working with the region on 2 these efforts. Not every place has a PRA, and so we are 3

looking to -- there are a number of efforts to look at -- and 4 Tom, of course, is going to plants where there are -- as to 5

how do we take the PRA. type of information and begin to look 6

at it generically on the various plant types and develop the 7

inspection process along the trial basis that Tom has been 8 doing.

9 We also -- and this has been going on for quite some 10 time -- recognize that the average inspector was not familiar j 11 with a PRA approach and what it was and what'it meant. So we 12 have set up courses -- I can't give you a count of who all has 13 been through, but working with the -- you know, Research had 14 various types of courses going, and we tied in with Research 15 quite some time ago to get a PRA course for hands-on 16 practitioners, so to speak, and not for somebody who is going 17 to have to do a PRA.

18 CHAIRMAN PALLADINO: You don't really have to be 19 expert in PRA in order to --

20 MR. TAYLOR: No, you don't.

21 CHAIRMAN PALLADINO: -- the program, as I understand 22 it, but it does identify the scenarios that --

23 MR. TAYLOR: But you have to understand what the --

24 both the benefits and the limits are, and that's what we have 25 tried to set-up in the base training of several days for

29 1 inspectors.

2 So we have been working with the region to get this 3 program developed and again it's a slightly different 4 approach, and I think -- Jim Partlow, would you like to add 5~ anything? Is there any point on this that perhaps you wanted 6 to tell the Commission? Jim is there.

7 MR. PARTLOW: No, sir, Jim, except you might mention 8 the use of the computer and the program that Arkansas is

'9 working on.

10 MR. TAYLOR: Right. Working again with Research, if 11 you have seen PRAs, Research, using one of the national labs, 12 has been developing a computer type program that can be used 13 with the PC type IBM.--

14 COMMISSIONER BERNTHAL: Which program?

15 MR. TAYLOR: Do you remember which lab it is, Jim?

16 I've' met the people, but I can't remember which lab is doing 17 this work for Research.

18 MR. PARTLOW: It's a private contractor.

19 MR. TAYLOR: Oh, is it? Okay.

20 COMMISSIONER BERNTHAL: What is the program?  !

21 MR. PARTLOW: It's called PRISM. By JBF Associates.

22 MR. TAYLOR: Okay. And I gather they have some lab 23 people working with them. In any event --

24 MR. PARTLOW: I think Oak Ridge has been involved.

25 MR. TAYLOR: Okay. In any event, they have taken a

.--.----~r -

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i l

l 30 l 1 PRA for Arkansas, they have used it and used this computer 2 program. The object is to take all that information from the 3 PRA, computerize it and then make it available for the 4 resident or region-based type inspector to learn how to use 5 this program and to look at dominant sequences, to know how 6 important it is, if one of the two auxiliary feed pumps is 7 down and what does it mean, and what should he be sensitive 8 to?

9 So that program is being run on a trial basis 10 because that will be another tool, besides the big PRA, will 11 be a computer program, and Research has been very active in 12 supporting the inspection program in this area.

13 COMMISSIONER BERNTHAL: You know, I have to say I 14 guess you're wise to caution against early enthusiasm here, 15 but I am very encouraged by this kind of effort. We commend 16 you especially for some innovative thinking on ways to attack 17 problems.

18 I re' call that we talked some time back in connection 19 with the severe accident policy statement and consideration of 20 so-called smart PRAs, the thinking being that, well, now that 21 we have said what we think about severe accidents, what are we

, 22 going to do about it, and it's not clear to me yet what we 23 have done about it in respect to doing so-called smart PRAs, i

I 24 at least, which I know the Staff doesn't like the terminology,  ;

25 but until you give me a better one, I'll use it, anyway. The

l l

31 1 idea being --

2 CHAIRMAN PALLADINO: That implies there are some not 3 so smart PRAs, and you might be right in that.

4 (Laughter.)

5 COMMISSIONER BERNTHAL: But the idea there was to go 6 out and do a quick smart -- quick and dirty, maybe, PRA on the 7 plants that you know, because of your expertise are the ones 1

j 8 that we ought to look at carefully first.

4 9 It strikes me as interesting that in a sense you are 10 approaching the problem from the other direction and it may be 11 a better direction, now that I think about it, rather'than 12 number-crunching at the front end, you ara simply taking what, 13 as I gather is, taking what we have in hand on PRAs, applying 14 them to the plants that you think need application, and using 15 that to guide your inspection. I think that's exactly the way 16 to go, with what we have now, and it's a very good idea. I'm 17 really pleased to hear that kind of approach is being used.

18 CHAIRMAN PALLADINO: I, too, would like to commend 19 you for very innovative ideas. I appreciate that they are 20 labor-intensive, but we can deal with that after we have the 21 ideas, because the ideas may in the and help us in using our 22 resources most effectively.

23 COMMISSIONER BERNTHAL: But that's what PRAs are 24 really for, I think.

25 CHAIRMAN PALLADINO: I was thinking both of these.

! 32 1 COMMISSIONER BERNTHAL: Yes, and this is what we 2 ought to be doing, and it is also something that escaped me, 3 we sit here-on this side of the table and oftentimes don't 4 know what's going on in detail, and it escaped me that the 5 people out in the trenches that are at the plants doing the 6 inspections'on a regular basis sort of very rarely, 7 apparently, ascend to this esoteric realm of PRA analyses and 8 the number-crunching and the sophisticated programs, and

! 9 somehow the talk about technology transfer to pract'icality --

10 it sounds like that's what we're doing.

11 MR. TAYLOR: That's what we're trying to do, because 12 it is that --

13 MR. DENTON: I'd like to inject a similar thought.

14 I think we can have a very powerful effect on improving safety 15 if the inspections and the headquarters review and the l 16 Licensee actions can all get focused on what we agree are the 17 problems. If the Licensee gets pushed by inspection to 18 improve one area, and headquarters is pushing.one other, and 19 he wants to improve still a third, progress isn't very fast.

4 20 And what we have tried to do in branches like John Zwolinski's 21 -- sort of a pilot case -- meet with all the owners of Mark I 22 GE designs and develop a strategic plan, say using the PRAs i

23 for this class of plants, the worldwide experience, the 24 design, the weaknesses and strengths of that design, all the i

25 inspection results and AEOD results and research results, what

l 33 1 should those owners of that class lay out as where we want to l

2 be in the next year or two years or three years. l 3 And I think the agency is tending to focus that way l 4 so that eventually we will be able to have a plan that is 5 driven by the PRA or more safety-driven in a sense, as we all 6 perceive it from different perspectives.

7 John, do you want to comment on how you see that 8 coming with your group of plants? Which includes Pilgrim, 9 incidentally.

i 10 MR. ZWOLINSKI: I'll take a shot at it.

11 Number one, I have the older and what I consider the 12 better operating facilities in my group.

13 [ Laughter.)

14 I met with the utilities' representatives on January 15 30th, along with my staff, to try to seek a common agenda as 16 far as resolution of technical issues, more to the generic 17 sense. The Mark I's in general have problems, can we put the 18 common agenda on the table and seek common resolution, 19 expedite the resolution of generic issues that remain.

20 I was looking at our multi-plant actions that have 21 lingered for some time, the older issues that have not been 22 resolved. How can we apply our resources more effectively to 23 this class of plants to facilitate and put behind us the 24 troubles of yesterday, and I have laid out what I feel is a i

25 common agenda for the next three years, hoping to declare a I

i

, 34 4

1 victory on the generic issue side of the house, still 2 browbeating the utilities, to some extent, to push the 3 plant-specific items. Also the generic safety concerns of 4 yesterday need to be put behind us, and I felt that was the 5 first step in accomplishing that.

l 6 I have also attempted to prioritize this for our 7 technical review groups.

8 CHAIRMAN PALLADINO: We have another regional 9 administrator to go, but I.did have three questions, and maybe 10 I should have indicated it at the beginning in a little 1

11 different tack.

12 Are you having any special equipment qualification i

13 problems in your region? Are you having any special fire 14 protection problems in the region? And do you have any feel 4

15 about whether or not problems in the region,would increase if 16 the modifications now being proposed for tech specs are 17 implemented?

18 , That's about 45 minutes worth, but I just want a few I

i 19 minutes on it.

20

MR. MURLEY
I'll have to kind of duck the last one 21 on tech specs. I haven't thought about it and I'd rather not i 22 give an off-the-cuff view.

23 With regard to fire protection, I think fire

! 24 protection is getting under control. That is, we have done a 1

25 number of inspect' ions at the plants and we are finding some i

i

l

. . i 35 1 problems. Some are okay, but by and large I think we are 2 getting that behind us.

3 We are now starting into the equipment qualification

> 4 type of inspections. Those are generally still under the 1

5 direction of I&E headquarters teams, so we are working with 6 them, and I think we are going to go through the same kind of, 7 ch, pains that we did with fire protection, and we are going c

8 ta find problems, we are going to have to decide what do we do 9 about enforcement and so forth.

10 so I think we are in the kind of early stages.

11 CHAIRMAN PALLADINO: But as far as getting 12 compliance from the utilities, do you have any special 13 problem? I mean up to the point where they --

14 MR. MURLEY: If you are talking about big broad 15 serious problems, no. I haven't seen them.

16 MR. TAYLOR: I think Tom described it, because we j 17 have the discipline in the contractor support, we have been 18 j

working closely with the regions to get the people trained up 19 and we are providing the bulk of the resource at this time to 4

, 20 continue those inspections, and we do plan ultimately to turn 1

3

! 21 it over when appropriate. But it does take a set of very i

j 22 special disciplines to do this, and that's why we have 1

23 continued.

24 I don't think we are -- I think you have been aware

! 25 of some problems. I don't.think we are finding anything I

i

36 1 overwhelming. I'd say, as Tom described, we are finding 2 difficulties and I believe we are going to be shortly making 3

recommendations on enforcement in that area to elaborate on 4 what we already have. So I think I agree with him.

5 CHAIRMAN PALLADINO: I recognize we still have Jack 6 Martin. Let me see what questions the Commissioners have.

7 COMMISSIONER ASSELSTINE: I have a couple.

8 First of all, on the PRA-based inspection and the 9 other enhanced or augmented team inspections, I think those 10 are good ideas, Tom. I agree with the comments that Joe and j 11 Fred raised. 1 i

12 It strikes me that particularly on the PRA-based 13 ones, this is a way to try and deal with the problem that you 14 seem to have found at Calvert Cliffs.

That is, a PRA gets 15 done and then the corporate people may use it, but as far as 16

the plant is concerned, it gets put on the shelf and nobody is 17 paying attention to what needs to be done to make those 18 predictions come'true in terms of the day-to-day operation, 19 maintenance and testing of the plant and the equipment.

20 So I think it is particularly useful from that t 21 standpoint. l 22 (Commissioner Roberts left at 11:05 a.m.)

23 COMMISSIONER ASSELSTINE: This is way of making sure l 24 that some of those predictions come true about what the 25 dominant sequences are and are not.

1

. _ _ . - . , . - - . - - . - - - - - - - - = - - - - - - - ~ -

- * ~ ' ~ * ' ' ~ ~ ' ' " ' ' ~ ' ' ' ~ ~ ' ' ~ ~ ~ ' ~ ' ~ ~ ~ ~ ~ ~ ' ~ ' ' ~ ' ~ ~ ~ ~ ~

37 1 One question I had was to what extent, if at all, l

2 would this kind of an approach help in terms of identifying a 3 potential common mode failure that creates problems in terms 4 of performance of the system? Say like the check valves at 5 San onofre. Would this help you pinpoint in any way this is 4

6 an area where we need to focus on this particular piece of 4

7 equipment because if we have these multiple failures, here is 8 what can occur. Does it help at all in that or not? '

9 MR. MURLEY: Well, I guess I'll have to answer that

, 10 it could, but it depends on the skill and the inquisitiveness 11 of the inspector. If he goes out and he sees -- you know, if 12 he just happens to have that insight and he sees the weakness

13 for a common mode failure, then it could help.

14 Now the only way he can get that -- I can guarantee 15 the inspectors now don't have it, at least in my region, '

) 16 because they haven't been used to thinking that way as a i 17 rule. But as they get more trained and some experience on

, 18 looking at things from a PRA and accident sequence point of i

19 view, I think they are becoming more and more able to spot 20 those kinds of things.

21 In fact, we had one example at calvert cliffs where 1

22 the resident inspector came back on one of his monthly reports 23 -- this is months later -- pointing out a weakness that we 24 found in the PRA team inspection that I am sure he would not i

25 have been sensitized to.

I i

I

. _ _ , , . _ . - _ - . _ _ _ . . _-.m .__.-. . _ _ _ _ . . _ _ _ . _ _ _ , . _ . _ _ _ _ - . . . . _ , _ _ . _ _ . - . . -_ ... ... _.v.. _ ,

i l .

38

1 I can't guarantee, I hate to oversell this, but I  !

I 2 think there is at least an opportunity.

3 (Commissioner Roberts entered at 11:07 a.m.]

) 4 COMMISSIONER ASSELSTINE: The second question, you 3

5 mentioned Pilgrim as a plant where you have some concerns.

6 I'd be interested in hearing your assessment of are there 7 other plants that we should be concerned about in Region I, j 8 either because of continuing poor performance or downturn?

1 9 And second, on the other and of the' scale, are there some l 10 plants, because of the performance you have seen over the past 11 couple of years that stand out as truly outstanding examples

! 12 of high quality, consistent high quality performance, that

! 13 should serve as models to the rest of the industry?

I 14 MR. MURLEY: Well, yes.

i The last time I was here,'I 1

15 mentioned the big improvements that we have seen in Salem, and

! 16 that continues. I am very pleased with'the operation that

{ 17 they are doing there and what they have done on Hope Creek. I 18 guess we talked to you a couple of months ago about Hope i

) 19 Creek, but there is an example where they have had a 20 turnaround in the last year or two.

4 21 Yankee Rowe and Millstone 1 and 2 continue to be 22 very good performers, good, solid depth up and down the line.

l 23 I'm getting some signals about Peach Bottom 2 and 3 in terms i

24 of concerns, and again I haven't put it all together yet.

25 It's a little early to tell, but I think we are in the final

39 1 stages of preparing a SALP report on those two plants, and I i

t 2 will just have to see how that turns out. But there is at 3 least some signals there that all is not well.

4 COMMISSIONER ASSELSTINE: One last question. It's 5 not on a reactor, it's a materials licensee. And I know, Joe, 6 you have sent a memo on Radiation Technology. Joe, I know you 7 have sent a memo to the Staff asking a bunch of questions 8 about the enforcement action. I piggybacked on that from a 9 concern based on one of the press clippings I saw. Let me 10 tell you my concern and get your reaction and, Jim, yours as 11 well, since I think you are the ones that have been involved, 12 particularly based upon the history and recent press clippings 13 I have seen.

j 14 I get the impression that here is an unrepentant and 15 recalcitrant licensee. The approach that seems to have been f 16 taken is to take as much authority away from them as you 17 possibly can and put somebody else in, in terms of the 1

18 day-to-day responsibilities for what is going on.

19 I guess my question is, is that a wise approach, and 20 in the interim unril you get back to us with some more 21 information, are you really comfortable in terms of resumed 22 operation of that licensee with that kind of an attitude? Or i

23 am I wrong about your attitude?

i 24 MR. MURLEY: Let me characterize it just slightly 25 differently. The company is run by a very hard-driving i

O

j 40  !

1 1 businessman, and he has made it a success. He is an 2 entrepreneur, and I respect that, and he drives his people and 3 his equipment to meet schedules, and he's got a lot of 4 perishable food that comes in that's got to be irradiated and 5 moved out.

6 I think what is not built into the system is some

7 safety checks where somebody says whoa. They've got equipment l
8 there that's kind of ramshackle. They bypassed some i 9 interlocks. They tried to put some compensatory measures in 10 place to do that, but I think, quite frankly, just because of 11 the force of the man's personality and his drive to get the 12 company going, he's overridden some safety concerns, and 13 that's where we have stepped in and said whoa. We want 14 somebody in there who can say stop when we think it's safety.

15 And that's what we've done.

! 16 We haven't tried to totally remove him or his line 17 of all responsibility -- at least that's how I view it.

We 18 just want a separate --

19 MR. TAYLOR: I should add, too, that there is an

! 20 ongoing OI investigation which is referred to in the orders, 21 and I think some of the things that are bothering you may be 22 well addressed in that work.

23 COMMISSIONER ASSELSTINE: Okay.

j 24 MR. TAYLOR: And what we did, the region recommended 25 that they felt like we put them down, and then he agreed, and

, - - . . _ . . , _ . - - , - - _ _ . . . , . - . , _ - _ _ _ - . _ . . _ , - _ - , - , _ . , . .m._ _ _- ,-.

. - . = -.- -_ .. - _- .. _. ._-- - .--

I 1

41 i i

i we modified the order because of the financial burden and felt i

2 there were sufficient safeguards with this other group in 3 there to allow them to operate in this period of time.

J 4 COMMISSIONER ASSELSTINE: I can tell you what 5 troubles me, and that is the statement that was quoted in one

6 of the press clippings I saw from the vice president that l

7 basically nobody was endangered here, there weren't any big i

i 8 safety problems here, and this was after you hit them with the i

i 9 suspension order. And it just boggles my mind.that the 10 attitude of the corporate management would be that, hey, you a

11 know, nobody was endangered here, there wasn't a big problem, 12 after you have hit them with a big suspension order.

{ 13 CHAIRMAN PALLADINO: Well, I think we need to follow

} 14 up on this, but what I'm getting concerned about is our time, 15 because we want to give Jack Martin a chance to give his

! 16 presentation. But that is a very important problem. I wasn't i

l 17 trying to detract from the importance of the problem, and I

/

18 think follow-on by I6E could help us on that.

19 Were there any other burning questions for --

20 COMMISSIONER ZECH: I would just like to say I 21 emphasize the great importance of Harold Denton's comments

]

l j 22 regarding getting utilities focused on their problems together 23 with our various headquarters and region focus on coming up

,' 24 with something -- an agreed-upon position, it seems to me that i

i 25 is something perhaps the Staff should take on at the EDO level i

4

. . , . . _ . , _ _ . _ . _ . - - . , _ . . , - _- . - _ . , , - , , . - , _ , . . - _ _ , _ . , _ _ . .~._ .., . . _ . , , . . , _ _ _ _ . . _ . , , , - . _ _ , _ _ . . _ - _ . . . . _ . -

-. . - =- -, .-.

42

)

1 or something. I think Harold's point was very important, and l

2 perhaps it would indeed help us to keep from letting some of 3 these things go on and decisions not to be made. Very 3

4 important point. I hope we don't let that one fall through 5 the cracks and we get some kind of a disciplined system for 6 looking at that.

7 CHAIRMAN PALIADINO: Okay. Let's turn the meeting 4

8 over to Jack Martin.

i l 9 MR. MARTIN: All right. Thank you very much.

l

! 10 The last couple times I've been here, I have focused i 11 mainly on three or four plants in the region and talked about l

12 them in some detail. I don't plan on doing that this time, ,

13 mainly because you either have heard about it or shortly will,

, 14 most of them of concern.

I 15 Yesterday you heard about San Onofre and a couple of '

16 weeks ago about Rancho Seco, and I think Palo Verde is coming-17 up here in a few weeks. So I hadn't planned on saying a lot 18 about those.

I 19 I will say~a couple of words ab'out Diablo Canyon. '

t I j 20 think probably you haven't heard too much about them-lately, l

i 21 mainly because nothing bad has been happening. The first year q 22 l or so, my understanding is they set a record for reliability 23 of a Westinghouse plant and the statistics one looks at in 12 4 terms of scrams and availability-and number of hours of

, i

25 generation have been quite good, and so we are happy about l

l l

43 e

1 that, yet still trying to be vigilant.

2 So what I thought I would do is focus a little bit 3 instead on some things that we have been doing in the region 1

4 to better deal with some management challenges, much the same l 5 thing that Tom talked about, and to talk about some of the i

6 management tools we have used, and some of the concerns I 7 have, unfinished business that I look forward to the next

8 year.

9 We have done a couple of things working with Jim 10 Taylor and his people to try to figure out how can we do more j 11 with less. This is something we started thinking about i

12 shortly after I got to the region.

l 13 COMMISSIONER BERNTRAL: Let us know when you find 14 out.

1 l

15 MR. MARTIN: We have instituted a couple of I 16 experimental programs. I'd like to give you some sense of how 17 they are working out and some of the strong positive things, 4

18 and also some of the negative things.

l 19 I guess having been a resident myself in a little

20 bit different program, but having done that sort of thing l

21 before, I put a great deal of emphasis on the_ residents, and l

22 in the three years I have been there, have arranged to put our

]

23 very best people at the sites, people that look like they are 24 coming along and will eventually be good managers, and have 25 put many more of them there than we normally would do. Each

,,n en- - - , - - - , , ,-- ,-,.-.,-,n, ~.~n, - , , , -- - - - ,,- .---e, . - - - - - , - , - - - , - . - - - - - - , , - - - - ,,--.-.,w,-..-,--,,--,+,-~ ..-----,w.,

44 1 of the single reactor sites now has two people. Diablo Canyon 2 has four. There are five at San onofre, and five at Palo 3 Verde.

4 So we have roughly a third of the inspection effort i

i 5 done by the residents. That has several advantages, it turns 6 out. Some of them I hadn't thought about before we did it, 7 but it's a fact of life, you get about twice as much 8 inspection out of a resident as you do somebody from the 9 region. So essentially what we have done.is created eight 3 10 more inspectors by doing that, and it is interesting in the l '

11 last year we have had about 5000 more direct inspection hours I

12 than we would have otherwise, and cut'about $50,000 out of the 13 travel costs.

l l 14 COMMISSIONER BERNTHAL: Good.

15 MR. MARTIN: So I am kind of happy with that.

16 The other thing that is interesting is in our region 17 at least when I came out there, the vast majority of-the 18 effort was construction, and it has gradually turned to most l 19 of it now is either testing or operations, and we had an i

20 enormous problem on how do you retrain people and reorient 1

21 them from construction to operations. And I find that that is 22 very difficult to do sitting in the office, looking through i 23 manuals and that sort of thing, and it's been really a godsend 24 l to be able to send these people out to the site.

4

{ 25 In a sense it's like trying to get a drink out a i

)

! i i

O

  • 45 1 fire hose, but many of them have done quite well, for either 2 construction people that need to reorient their thinking 3 towards operations or for new inspectors. We have hired quite 4 a few new people. We have been lucky with internes and summer 5 coops that have hired on. So you vill see quite a few young 6 faces in the resident offices, and there's no better place to 7 train them.

8 CHAIRMAN PALLADINO: Do they undergo a training 9 program, aside from --

10 MR. MARTIN: Oh, yes, they go through the normal i

11 school and that sort of thing, but it's interesting that we 12 get a very large proportion of the findings out of people that 13 ask dumb questions because they don't know any better, and so 14 I'm quite happy with some of our less experienced people.

15 They seem to turn up some very significant issues.

16 It is also interesting that we have had a great deal 17 more luck retaining people at the sites. It's expensive to 18 live in the Bay area. It's less expensive to live at the 19 sites, and for some reason the people that have gone there 20 have been happy to stay there. The losing them to consulting 21 firms and that sort of thing has been small, relative to 22 people in the office. i l

23 Well, there are some negative aspects of this as 24 I well. You know, when someone is at a site, they require, I '

25 believe, a great deal more supervision so they don't lose

, 46

\

1 their identity and it's important that we spend a lot more i l

i 2 time with management contact so that people can remember who 4

3 they work for and what their purpose is and not identify too 4 much with the Licensee.

5 I have done a number of things by having more 6 frequent trips, personally, to these sites. The management in j 7 the office gets out more often. I have each of the senior 8 residents call me once a week, so at least once a week he's 9 got to think of something significant that he did that week, l 10 and --

11 (Laughter.]

12 MR. MARTIN: It seemed to work for me, so I figured 13 it would probably work for them, and it does. So that's one.

j 14 on the other hand, with putting more people at the 15 sites, that depletes the cadre of technical experts that we j 16 can hold in the region to look at plants at a multi-site 17 basis. It's nice to have a group of people that look at a i

18 technical problem at several sites to see how they all 19 compare.

20 In our case, we have a few number of plants and 21 there is sufficient diversity that I see that as a 22 disadvantage, but not a.very strong one.

23 So I see some advantages in terms of more presence 24 at the site, yet some disadvantages in that you really have to l 25 spend more time tending and giving personal attention to the 4

!.. ~ - --- - - - - - - - - - - - ' - - ~ ~ - - - ~ ~ ~ ~ ^ ' ' ~ ~ ~ ~ - ~ " ~ ~ "

l r

47 1 people.

2 \

t But so far, on balance, I think it is working out '

t 3 well. It is not clear to me how that would apply to a much 4 bigger region. If I had 20 sites to worry about, that may be  ;

I 5 a -- I may come to different conclusions, but I am happy.

j 6 In counterpoint, we have put about another third of l 4

7 our effort into team inspections that are made up of regional 1

J 8 inspectors, of people from other residents, from other sites, 9 headquarters people, contractors. It's usually easy to get t

10 people to want to come out to do inspections in our neck of f

j 11 the wood. We have been quite happy with the response. And so

12 we try to do a major team inspection at each site once a year, l

13 and the approach we have taken is much like Tom suggested. I i

14 think only one of our sites has a PRA, so we haven't been 15 quite as scientific as Tom, but we have gotten with people l

{ 16 that have comparable plants that have PRAs and tried to i

i 17 identify two or three systems this first round of inspections

] 18 that are highly safety significant, and it usually turns out

19 to be the auxiliary feed system and one or two others, and
20 take this team of people and look in great detail at all 21 aspects of t' hat system: knowledge of it by the operators, 22 operating history, physical condition, maintenance records, <
23 training records, design modifications, the entire spectrum as I

j 24 opposed -- as applied to say the auxiliary feed system.

\

l 25 I guess my personal point of view is that if there t

i i_____.___-____.___________ . _ . _ _ _ , _ _ _ _ . _ _ _ _ . . _ _ _ _ _ , _ _ , . _ _ . _ . . . _ , _ _ _ . _ _ . , _ . _ . _ . - _ _ . .

48 1 is something seriously wrong at a plant, it tends to show up 2' in many different places, so that if one takes a single system 3 and thoroughly shakes it down, any serious problems at the 4 plant are likely to turn up by just looking at that one 5 system, and indeed we found some rather significant things.

6 I'm hoping over a period of five yaars to have i

7 looked at all of the significant systems in some depth, 4 8 starting with those that appear to be most significant at 9 first blush.

I 10 CHAIRMAN PALLADINO: How many plants do you have in 11 region?

. 12 MR. MARTIN: Six sites.

13 CHAIRMAN PALLADINO: Six sites?

14 MR. MARTIN: Yes. And then there's a couple that 15 are in a construction limbo. We are not spending a lot of 16 time on them.

j 17 COMMISSIONER ASSELSTINE: Nine operating units?

I

  • 18 M2. MARTIN: I'd have to count them up.

19 COMMISSIONER ASSELSTINE: Palo Verde 2 is not in 20 operation yet?

i I

21 MR. MARTIN: No, not -- well, it's in low power 22 operation, so --

23

! COMMISSIONER ASSELSTINE: You have nine.

j 24 MR. MARTIN: Yes.

i 25 CHAIRMAN PALLADINO: You say you do this for each

49

, 1 plant once a year?  !

2 MR. MARTIN: Each site.

3 CHAIRMAN PALLADINO: Each site?

l 4 MR. MARTIN: Each site. And like at Palo Verde, for' l

5 example, the first time we concentrated on Unit 1, the second 6 time we concentrated on Unit 2. We have to use a little --

i 7- for example, Palo Verde is easy because all the plants are 8 identical and they were all built by the same guy and the same i

9 contractors, and so if there is any generic stuff, it's easy 10 to pick up. Where WPPSS, on the other hand, only has one 11 plant, but it was built by everybody under the sun and it's 12 hard to pick anything that's representative.

13 (Laughter.]

l 14 MR. MARTIN: So we have had to use a little -- be a 15 little bit shrewd, but --

16 CHAIRMAN PALLADINO: Are you going to indicate your l 17 manpower usage in this team inspection, generally?

18 MR. MARTIN: Well, in general we are using about a 19 third of our total inspection resources there.

20 CHAIRMAN PALLADINO: I see.

21 MR. MARTIN: And the last third is with the normal 22 region-based inspectors that look into rad protection and 23 those sorts of things that are best done across the board.

24 So --

25 CHAIRMAN PALLADINO: That covers two-thirds, doesn't l

j .

50 1 it?

2 MR. MARTIN: Well, no, it's three-thirds. You have

! 3 the residents as a third, the team inspections are a third, i 4 and the regional inspectors are a third. I have tried to 5 foster a little anxiety among these groups to where if the 6 team inspections find things the residents weren't worried i

7 about, then that takes some explanation, and hopefully that 8 will be healthy. So far, it's been a useful thing to do.

9 So I try to personally attend the Exit interviews, s i

10 and like Tom said, the team inspection frequently is having 11 trouble at the and trying to knit together what does all of 12 this mean. There's a lot of findings, it's hard to decide 13 what is the management significance of it, so I try to get 14 there a day or two ahead of time to help them knit all that 15 together and provide editorial comments to the plant 16 management at the end.

17 So that's a couple of inspection techniques that I 18 think are providing at least more direct inspection time. I 19 think we are using it wisely.

20 It's the things we've done in the region that I find 21 significant, when they are basically things that we did at 22 NMSS when I was here, that I tried to graft'onto the region.

23 When I got there, I found it very difficult to reconstruct 24 what we had spent our resources for. It was hard for me to 25 tell readily what inspections had been done, which had not

a 51 1 been done, how much of the budget was spent where it was l

2 intended to be spent. It was difficult for me to tell and I i

3 was supposed to be running the place. So it was definitely l

4 difficult to communicate with the program offices for whom we 1 5 are supposed to be the agents, whether we were doing the 1 6 programs or not, and if so, to what degree.

7 And it was particularly difficult when conditions 8 changed. We had allegations we had to deal with, fire drills 9 several places, and it was difficult to communicate properly; 10 if we are going to put more emphasis on Diablo Canyon, what 11 suffers and are we making intelligent choices as to what is a 12 decrease.

13 So we put together an operating plan that was based 14 mainly on John Davis' plan that starts with the PPG and the 15 budget and lays out in detail all of the work to be done on 16 every plant. And it is fairly voluminous. But over the last 17 couple of years we have been able to work it out to where we 18 have planned for the entire year everything that we know we 19 have to do and roughly scheduled when it is supposed to be  !

20 done, which includes the resident work, the team inspection  !

21 work, all the routine inspections and ample allotment for 22 independent inspections, and an ample allotment for unforeseen 23 circumstances which gives us a -- and this is updated every 24 quarter and it's on a computer system, so it makes it 1 25 relatively easy then for inspectors to call in and say, hey, I l

52 1 don't want to do this, conditions have changed, I want to do i

2 something else. And then everyone has something they can look 3 at and clearly understand how the changes fit into the overall 4 plan, and it is much easier then for us to deal with Jim l

l 5 Taylor's people and Denton's people, to reach agreement why we i

6 are going to do something different than we originally 7 anticipated at the beginning of the year.

8 So it has been difficult to get people to accept 9 this. I think most of us would like to work in a completely 10 unfettered atmosphere and sort of go by gut feel. But we

! 11 gradually started with the supervisors. They have been much 12 more enthusiastic about it and gradually now the Staff as a 13 whole has come to accept it, and it is being used regularly.

14 Another thing I did, which I was a little nervous 15 when I first got there, because the best I could tell, the i

16 only one that was accountable for accomplishing anything was 17 me. I mean it was my performance appraisal was the only one i

18 that actually' required anything specific. Everybody else I l

19 would sort of do inspections or put forth effort or something i

20 like that. There wasn't much of a bottom line that anybody 1 21 had to meet. So --

L 22 COMMISSIONER ASSELSTINE: Not performance-based.

23 MR. MARTIN: No. So during the last couple of years 24 we have rewritten everyone's performance appraical to tie back 25 to the operating plant. I am just amazed this has been able

_ _ _ _ _ _ _ _ . - _ _ _ . _ - . _ . . . _ _ _ . _ _ _ _ _ . . , _ _ _ _ _ _.__J

53 !

1 to be done without a lot of hard feelings.

2 So as it stands now we have got sort of an 3 integrated system that proceeds from the budget to an 4 operating plan of people's performance, which makes the whole 5 operating plan a little more personal to people, and that's, I 6 think, working fairly well. We haven't had any really 7 negative reactions to that yet. And it's been in place now 8 for well over a year. So I feel a little more comfortable now 9 that there are more people anxious other than me on getting 10 some of this work done.

11 Another thing we have done that's turned out to be 12 usef.ul is that there's a lot of detailed stuff that gets to be 13 a real irritant and takes up an awful lot of management time 14 when it's not being handled properly Like, for example, we 15 have a goal of issuing our inspection reports within 20 days 16 of the inspection, and it seems like that is almost impossible 17 to do. And we are supposed to take action on operator

, 18 licenses within 25 days of actually giving the examination, 19 and we have goals for how much direct inspection time we 20 should be doing.

21 I found we were spending a lot of time discussing 22 this with headquarters and amongst ourselves, and so I got our 23 administrative people to start putting out some management 24 information reports. They are little reports that come out 25 about once a week or two weeks, depending, sometimes monthly,

l 54 l

.1 that give sort of a graphical account of how we are doing. I 2 And it's amazing that once these reports started coming out, 3 inspection reports tend to now gravitate right to the 20 days 4 they are supposed to, and the operating licensing things are 5 almost exactly right at 25 days, and direct inspection time, 6 so that it's had an effect of getting people to do the things 7 that -- on a routine basis, so it sort of frees up my --

8 CHAIRMAN PALLADINO: How often is that put out?

1 9 MR. MARTIN: Well, depending. I've got several of 1

10 them. Some are every month, some are every week.

11 CHAIRMAN PALLADINO: When you say "some" --

12 MR. MARTIN: Well, I have several of these lists.

13 CHAIRMAN PALLADINO: A sort of series, or is it --

14 MR. MARTIN: I have one on direct inspection, and 15 another one on our performance in issuing operator licenses, J

16 another one on how are we doing on open items. Each region I 17 has hundreds of open items to look at, and plotting those 18 graphically helps in establishing a goal.

19 CHAIRMAN PALLADINO: What do you call those?

20 MR. MARTIN: - Just management information reports.

21 And that has cut down a lot on supervisory people having to 22 spend a lot of time running around keeping'after their people 23 to do the routine administrative stuff. And I hope it gives l'

24 them more time to think about some of these more abstract 25 problems, like what's about ready to happen next.

4

, ec -r - ,c-- ,-, y y , ,_---_,-m - --

55 1 Another thing that we have done is to institute a 2 fairly vigorous internal audit program where we have one or 3 two people in the office that are good at this and they spend 4 part of their time doing audits of, oh, such things as -- we, 5 of course, have a routine training program for inspectors that 6 frequently people have a hard time getting done, and so we 7 audit that periodically. We audit open items, and so I think 8 that by that combination of things the basic management of 9 resources has been improved and puts us all in a position to 10 explain what we did and particularly explain how to deal with 1 11 changing circumstances.

12 A couple of things that worry me'that I really don't l 13 have any answers for, at least in our Region, we have been 14 making this transition from plants in construction to plants 15 in operation with an attendant degree of interest on the part 16 of Public Service Commissions in rates, and we've lost a large 17 number of capable people to consulting firms that assist 18 Public Service commissions in identifying areas to disallow 19 costs.

20 Well, you know, we all lose people, but I guess the 21 thing that bothers me here is that on the one hand, it's 22 difficult to try to-establish an open and completely 23 transparent atmosphere with utility management, and then have 24 the people then disappear and go to work for a consulting firm 25 whose job is to try to disallow their costs.

56 1 COMMISSIONER BERNTHAL: What is the timeframe for 2 that sort of a job transition? We obviously have some 3 restrictions against people moving directly into working for a 4 utility, for example, in areas that they've been responsible 5 for regulation.

6 Is there no such prohibition against becoming 7 directly involved in matters that pertain to PUC activities?

8 COMMISSIONER ASSELSTINE: I don't think there is.

9 MR. CUNNINGHAM: I don't think there is, 10 Commissioner. The principal thrust of the conflict of 11 interest statutes and regulations deal with switching sides 12 and coming back and representing the License vis-a-vis us.

13 COMMISSIONER BERNTHAL: That is, it seems to me, a 14 serious oversight in the law.

15 CCMMISSIONER ASSELSTINE: Why? What's the conflict 16 of interest?

17 COMMISSIONER BERNTHAL: There is a clear perceived 18 conflict of interest, it seems to me, whether real or not.

19 It's a clear perception of conflict of interest.

20 CHAIRMAN PALLADINO: You mean for somebody~to go to 21 work --

22 COMMISSIONER BERNTHAL: Absolutely. I mean, it cuts 23 both ways, Jim. It's not just the utility. This happens to 24 be a different entity with a different mission, an economic 25 mission.

. =

57 l

1 COMMISSIONER ASSELSTINE: That's why I don't see the 2 conflict.

3 CHAIRMAN PALLADINO: Jack said they were going to L

4 consulting firms that deal with Public Utility Commissions, 5 where I think their thrust is perhaps different.

6 COMMISSIONER BERNTRAL: I'm sorry. I just simply 7 can't buy that. I think it's a clear appearance of something 8 that our people should not be moving directly into.

9 MR. MARTIN: Well, as I said, I don't have any 10 answers to this. It's something that annoys me a great deal.

11 I think the other thing that I'm giving a great deal 12 of attention to -- I don't want to alarm'anybody, but I think 13 over the years, certa' inly since I've been in the Region, my 14 attention has been primarily on construction and operations 15 problems, and I've never paid a whole lot of attention to 16 security and safeguards, and in looking over some statistics 17 and in looking into things, I've gotten the impression that l

l'8 perhaps we are not being as aggressive as some of the other l 1

19 Regions in seeking out problems in this area.

l 20 CHAIRMAN PALLADINO: As aggressive as other Regions?

21 MR. MARTIN: Yes. You know, if I look at the number 22 of violations-we've had versus others, they're lower, but I 23 looked at one plant, for example, that had a couple of l l

l 24 incidents earlier this year that certainly weren't consistent 25 with the SALP rating we gave them, and we've taken enforcement i

58 1 action. But I've laid out a program with a good deal of l 2 Headquarters help to do a special safeguards team inspection i

3 at each site during the next several months to see if, in 4 fact, this is a problem or simply a calibration.

5 It's difficult to tell, because many -- the security 6 plans for these sites vary so much, it's hard to say which is 7 better and which is worse. But that's an item that I've

8 targeted for a lot more personal attention during the next 9 year.

10 And again, I don't think you need to do anything 11 about it, but it's something that I'm worrying about at the 12 moment, and I just don't know whether it's a problem.

13 MR. TAYLOR: We have supplied people from 14 Headquarters to work with Jack. We've seen this once or 15 twice before in parts of our program where we see a particular 16 area like this that seems to be not getting the degree --

17 that's the other way to put it -- of attention, and so we've l 18 used Headquarters people to' team up with the appropriate 19 Regions just to bring in that different perspective, and we 20 i have a few experienced people who cross all the Regions, j 21 either in our office or NMSS. i 22 MR. MARTIN: That really summarizes what I had to 23 say. I can deal with'any questions.

24 COMMISSIONER BERNTHAL: Well, I'd like to get more 25 information on this point you raised, Jack. I don't want to l

I i

59 1 jump to conclusions, b'ut I would like to know the extent to 2 which people who are involved in regulatory matters, not 3 involved in economic. matters one day, and have out there 4 somewhere this -- what is a natural adversarial conflict, to 5 be sure, between a governmental entity on the one hand with an

~6 economic interest and a private or perhaps municipal entity on 7 the other hand with an economic interest -- the extent to 8 which our folks whose job is safety regulation then walk out 9 the door and one day or the next day, rather, are involved in 10 taking sides on those issues.

4 11 And to me, that's a difficulty that I'd like more 12 information on.

13 MR. STELLO: Commissioner, do you mean by names?

14 COMMISSIONER BERNTHAL: No, I don't care about 15 names. ,

I want to know about what kind of activity is going 16 .cn. That is what I would like to know.

17 MR. STELLO: We have people who have left the agency 18 and done consulting work directly for PUCs.

19 COMMISSIONER ASSELSTINE: Yes, sure.

20 COMMISSIONER BERNTHAL: That's what I'm talking 21 about.

22 COMMISSIONER ASSELSTINE: That's right. That's what 23 he's talking about.

24 CHAIRMAN PALLADINO: One of them was a Commissioner.

25 (Laughter.]

i

60 1 COMMISSIONER ROBERTS: That, in fact, is an accurate 2 statement.

3 (Laughter.]

4 MR. MARTIN: I didn't have him in mind.

5 [ Laughter.]

~

6 COMMISSIONER BERNTHAL: No, I'm quite serious.

7 Maybe I'm the only one here that sees a difficulty, but the 8 point you mention is a valid one, I think. One day you're 9 doing one. thing, and you're supposed to be developing a 10 certain relationship with one side of this adversarial~

11 relationship, and the next day the possibility exists that you 12 go out and work for the other side. I just think that there's 13 an inherent difficulty here.

14 MR. STELLO: Well, we don't work with the PUCs at 15 all, ever? We have no'hing t to do with them?

16 COMMISSIONER BERNTHAL: But we are regulating one 17 side of this separate economic --

18 MR. STELLO: Okay.- With our regulations, strictly 19 with the utilities, there are interactions with the utilities, 20 and we have to a degree an arms-length attitude towards 21 dealing with the PUCs. We have been subpoenaed to testify 22 from time to time.

23 COMMISSIONER BERNTHAL: I realize all this, Vic. As 24 I say, if I'm the only one who can see a problem here, then 25 there must not be a problem. But I think Jack has pinpointed 1

61 1 something that deserves at least-passing attention.

2 COMMISSIONER ASSELSTINE: I thought Jack's problem

3 was that he was losing people and he wasn't able to retain --

4 MR. MARTIN: Well, that's partly the problem. But 5 the other part of the problem is, it's difficult to get the 6 company management to completely level with you on what their 7 problems are, and when they do that, and then they find out 8 the PUC is investigating them --

9 CHAIRMAN PALLADINO: I'm'sorry, Jack. I missed the 10 part where you said --

11 MR. MARTIN: I think it's difficult to get a utility 12 manager to completely bare his soul about what all of his 13 problems are and the troubles he's having and the difficulties 14 he's having, if he knows that you may wind up trying to 15 disallow all of his costs a few weeks later with a different i

16 job. That's my point.

17 CHAIRMAN PALLADINO: To put a little different 18 perspective on Fred's problem, I think it's something that --

19 COMMISSIONER BERNTHAL: It's not my problem.

20 CHAIRMAN PALLADINO:

No, I'm sorry. The problem you 21 identify, you and Jack identify, I think there is an aspect-22 here that at least we might have ELD look more closely into.

23 They may find there is no real problem. l 24 COMMISSIONER BERNTHAL: Well, I suspect you're going 1

l 25 to find pretty quickly you've got a legal problem.

. =

62 1 CHAIRMAli PALLADINO: Or OGC.

2 COMMISSIONER ASSELSTINE: Or both of them together.

3 CHAIRMAN PALLADINO: Or both of them together.

4 MR. STELLO: The reunified office.

5 CHAIRMAN PALLADINO: No, but there may be a real 6 problem here that we're not just identifying. If the utility 7 people are worried that if they give information to some of 8 our employees, and then our employees go to a PUC where the 9 information is used against them, there may be a more 10 significant problem than we first --

11 COMMISSIONER BERNTHAL: Well, what good does ELD do 12 us? This isn't a legal question.

13 CHAIRMAN PALLADINO: Well, they at least can find 14 out what the laws are. You know, this is America where people 15 have some freedoms of choice, but then where we find conflicts 16 of interest, we set up protective measures. So this is 17 involved with the protective measures provided by the law.

18 There may alse be some other things that are identified in 19 looking at this problem that maybe we can do, and that again l

20 comes to be a matter of a' law.

i 21 COMMISSIONER ASSELSTINE: You know, sometimes these 22 people go to work for the utilities and help the utility 23 justify their costs.

24 CHAIRMAN PALLADINO: I appreciate that.

25 MR. MARTIN: Well, that's true.

63 1 COMMISSIONER BERNTHAL: It's the same problem.

2 CHAIRMAN PALLADINO: Well, let me suggest OGC and 3 ELD consider the matter to some extent.

4 There was one item, Jim, when we were talking about 5 security,'and maybe it's a little off the point, but we get 6 the daily reports, and it doesn't say much, which I 7 understand. But what I can't understand is when it doesn't 8 say much, and it says " Press Interest" or " Media Interest."

9 And I said, "We ought to know at least as much as was released 10 to the media to generate that interest," but that's an aside, 11 MR. TAYLOR: Let me loch at that, sir. I 12 understand.

13 CHAIRMAN PALLADINO: Jack, do you have any comments 14 on fire protection or environmental qualification?

15 MR. MARTIN: Well, we started out when I first got 16 to the Region with Trojan, and Trojan did not do a very good 17 job, and on the other hand, it was very murky because 18 apparently we didn't do a very good job on promulgating the 19 requirements. So that one was kind of a sore point, but since 4

20 then things have been basically okay.

21. I believe -- now I'm going from memory, but I 22 believe that things have been thrashed out on Trojan, and 23 that's --

24 CHAIRMAN PALLADINO: On what?

~

25 MR. MARTIN: On fire protection. And Palo Verde has

64 1 completed their inspection and passed.

2 Rancho Seco had, you know, the full team' inspection 3 last summer, and no major problems were found, and we just 4 finished the WNP-2 inspection last week ~and are still trying l 5 to sort out what it means. It looks like there might be some 6 problems there.

7 On equipment qualification, again San Onofre was 8 done. If my memory serves me properly, there were not any 9 major problems found. Rancho Seco was also finished, and no 10 problems were found.

11 Because of the concern that I've had for Rancho 12 Seco, we targeted them pretty much first to look at in both of 13 these things, using the full Headquarters Regional team, and 14 both of them passed fine.

15 So I guess at the moment, I don't have a major 16 burning concern in equipment qualification.

17 CHAIRMAN PAILADINO: Let me see if other 18 Commissioners have questions?

19 COMMISSIONER ASSELSTINE: I've got a couple.

20 Jack, you mentioned Diablo Canyon, and I guess my 21 sense.was much-the same as what you conveyed, that they've had 22 i a very successful start-up and operational program, certainly 23 for the large Westinghouse plants.

24 What do you attribute that to?

25 MR. MARTIN: Well, I think there are several

65 1 causative features that are somewhat interrelated and hard to 2 separate.

3 First of all, they had an awful long time to get 4 ready.

5 [ Laughter.]  !

j 6 MR. MARTIN: And especially on Unit 1, the people 7 have essentially been maintaining the plant as an operating  ;

l 8 plant for a long time. j 9 But the more important consideration, I believe, is  !

i 10 a very high level of management anxiety. I think they l

i 11 realized early on that if they had as rocky a start-up as San 12 Onofre did, that it would be untenable. And we, I think, 13 helped it along by having a dozen or so inspectors there 14 during the start-up for about a month, and it was quite 15 obvious that from the highest of levels, there was a great l 16 deal of interest. People were there all the time and not just  ;

17 standing around, but walking around, talking and probing.

18 COMMISSIONER ASSELSTINE: At the NMSS level?

19 MR. MARTIN: Yes. And it's interesting. When they 20 do that, things-tend to go well, and things did go well.

21 The major challenge that I know of right now -- and 22 I've told them; it's no secret -- is, you know, when people do I 23 well, they tend to get cocky, and I would hate to see all of l 24 the specs slide some in the next year or so, so we've been 25 thinking of ways to try to keep the blood pressure not too

~

l 1 ev ww 'a 1 -1

l

. . )

66 1 high, but reasonably high.

2 Unit 2 has not gone as well, but it is still quite 3 acceptable, but they've had more SCRAMS, more problems, partly 4 .because it had not been in that high state of readiness for a 5 long time and partly because perhapt some letdown, but both of 6 them have been quite acceptable compared to, say, start-ups at 7 San Onofre.

8 Palo Verde surprisingly for an inexperienced outfit 9 has done well. It's lasted so long that you get the 10 impression that things have been very rocky there, but if you il sit down with a pencil and note down all'of the things that 12 you try to use as indicators -- SCRAMS, safety injection's, 13 major incidents, operator errors -- there are very few.

14 COMMISSIONER BERNTHAL: Dces a pattern or an 15 impression begin to develop on plants like Palo Verde -- I 16 don't know whether Diablo is in that class, but the one in 17 Missouri, callaway, Wolf Creek perhaps -- does any of this 18 experience have to do with -- at least, for most of the plants i

19 I mentioned, I guess, being latest generation? Do you think 20 -they're better, easier plants?

21 MR. MARTIN: No. Palo Verde is a first of a kind.

22 It is the first, I believe, of that style of --

23 COMMISSIONERrBERNTHAL: That's exactly what I mean.

24 Not that there are lots of them, but that it's the latest --

25 MR. MARTIN: I think in their case, it's been a l

l

67 1 source of a real headache. I mean, all kinds of things --

2 COMMISSIONER BERNTHAL: Oh, is that right?

3 MR. MARTIN: -- have gone wrong during -- I mean,_

4 equipment problems.

5 COMMISSIONER BERNTHAL: Well, early on, yes. BU' I 6 guess I'm asking about the fundamental underlying plant layout 7 and design has made it easier. It. sounds like you're saying 8 no. That's discouraging in a way.

9 COMMISSIONER ASSELSTINE: Jack, my other question 10 goes to the other end of the scale. You've had two plants now 11 that had two of the three significant cperating events last 12 year, apart from TVA, both Rancho Seco and San Onofre Unit 1.

13 Have you had a chance to sort of scratch your head 14 on those and ask yourself, what does that mean about my 15 inspection program? Does it point to. areas where there are

, 16 some deficiencies? And have you thought about what it means 17 in terms of the initiatives in inspection that you've been 18 implementing over the past couple of years?

19 Is that helping or hurting?

20 MR. MARTIN: Well, I don't have an easy answer to 21 that, but I think we have to keep this in perspective, that 22 both of those plants have been surfaced as major issues for 23 some time.

24 And take San Onofre, for example. This waterhammer 25 thing was the third major issue that happened within the-last

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68 1 year. The first' two were the subject of major enforcement, 2 and, you know, calling in the IIT and making a big deal out of 3 it was a conscious choice on the part of the staff, you know:

4 Should we or shouldn't we? Is it time to escalate the thing a 5 little further or not?

6 I think you have to view it in that context. We 7 debated a great deal, does this really rise to the level, and 8 is it as rich with significance as really merits this, and we 9 decided, well, you know, given the progression, it's probably 10 worth doing, and we did it.

11 So I think I view this IIT issue and finally using 12 this as a pretext to force this plant material condition 13 review that they talked about yesterday, which was not their 14 initiative, we just couldn't lose that opportunity.

15 So I guess I view it more as an initiative rather 16 than a reaction.

17 COMMISSIONER ASSELSTINE: Okay.

18 MR. MARTIN: The same with Rancho Seco. You know, 19 the problem, without rehashing the event, the Staff made a 20 conscious decision that, you know, it's time to make a big 21 deal out of this and have the IIT and again raise this one, 22 you know, as a follow-on to several things.

23 So I think the preparation, in a sense it was 24 because of the groundwork that had been done in the inspection 25 program. There's always' room for improvement, but I guess I

69 1 would not sea it as something that happened out of the blue,

'2 that was r.ot with sufficient preparation or foresight.

3 COMMISSIONER BERNTHAL: Are you getting real good 4 management surveillance, high-level management surveillance 5 and management supervision now down there?

6 MR. MARTIN: Where? San Onofre?

7 COMMISSIONER BERNTHAL: San Onofre, yes.

8 (Whereupon, at 11:55 o' clock, a.m., Commissioner 9 Roberts left the hearing room.]

10 MR. MARTIN: Yes. It varies. You know, San Onofre 11 is a funny place. Although there are three nuclear reactors 12 sitting side by side, Units 2 and 3 are fully in the decade of 13 the '80s. Unit 1 is still, you know -- I hope it's up to the 14 mid '70s or.so now, but it's historically been given a

15 different level of attention.

16 COMMISSIONER BERNTHAL: Exactly.

17 MR. MARTIN: And so I would say, yes, there's a high 18 degree of attention to 2 and 3, and hopefully one of the 19 thoughts behind the IIT report was to greatly increase the 20 amount of attention to Unit 1, and I think you see from the 21 presentation yesterday, at least now they are very, very much 22 there. ~

23 COMMISSIONER ASSELSTINE: It should like what you're 24 saying is that the inspection program really was telling us 25 how bad things were at both of these plants.

70 l l

1 MR. MARTIN: Oh, yes. l 1

2 COMMISSIONER ASSELSTINE: And if there was a 3 failing, maybe what we need to look at is what enforcement 4 tools we were using to try and raise the visibility of these 5 things and the extent to which we were able or not able to 6 raise that visibility until something serious happened.

7 CHAIRMAN PALLADINO: Fred, do you have any more?

8 COMMISSIONER BERNTHAL: No, thank you.

9 CHAIRMAN PALLADINO: Lando?

10 COMMISSIONER ZECH: Just a quick question for the 11 Staff really. You don't have to answer it today, but it seems 12 to me it would be important for us to know, was the threshold 13 that the Regions are using to determine whether or not to send 14 an augmented team to a plant to investigate an event or to go 15 for purposes of special concern you may have for operational 16 performance, and also at the same time, it would be helpful to 17 learn, what are the indicators that you used to evaluate to 18 help you make that decision?

19 I'd be interested in knowing about that. I don't 20 want to elaborate here today, but I really would like to hear 21 about that.

22 MR. STELLO: I think that would be a good question 23 for us to keep in mind for the Regional Administrators next

24 week, since they have augmented it. As I recall, neither 25 Region I nor V have had any --

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71 1 COMMISSIONER ZECH: Maybe you could alert them to be 2 well-prepared.

3 MR. STELLO: We will and we'll deal with it next '

4 week. I think that would be a better way to deal with it.

5 COMMISSIONER ZECH: Okay, that's fine. Good.

6 MR. STELLO: Because I don't think either of these 7 three has focused on that yet.

8 MR. STELLO: That's fine.

9 CHAIRMAN PALLADINO: I would be interested in the 10 reaction of the Regions insofar as it affects their programs 11 that might arise by modificatien of tech specs and putting 12 information in licensing conditions or FSARs or wherever they 13 come out.

14 MR. STELLO: Yes. Okay.

15 COMMISSIORER BERNTHAL: I'd just like to comment 16 that it's a good presentation, and we were really encouraged 17 by some of the quality of the management and ideas and things 18 that we seem to see out in the field.

4 19 CHAIRMAN PALLADINO: Well, having said that, I don't 20 have to say it. I do want to commend your people for some 21 original thinking, and we look forward to seeing that brought 22 into effective use throughout the agency when it's l 23 appropriate.

24 Okay, if there's nothing more, we will stand 25 adjourned.

72 1 (Whereupon,.at 11:58 o' clock, a.m., the Commission i 2 meeting was adjourned.]

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l 4 6 1 CERTIFICATE OF OFFICIAL REPORTER 2

3 4

5 This is to certify that the attached proceedings 6 before the United States Nuclear Regulatory Commission in the

.7 matter of: COMMISSION MEETING e

9 Name of Proceeding: Periodic Briefing by Regional Administrators (Public Meeting) 10 11 Docket No.

12 Place: Washington, D. C.

13 Date: Wednesday, March 19, 1986 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.

  • 18 ,

(Signature) 1 19 m i fu >

(Typed Name of Reportsr) Ann Riley 20 21 22 23 Ann Riley & Associates, Ltd.

24 l l 25 l

- 3/19/86 SCHEDULING NOTES TITLE: PERIODIC BRIEFING BY REGIONAL ADMINISTRATORS SCHEDULED: 10:00 A.M., WEDNESDAY, MARCH 19, 1986 (OPEN)

DURATION: APPROX l-1/2 HRS SPEAKERS: DR, TOM MURLEY, REGION I

  • EMERGING NEW INSPECTION APPROACHES

- PRA GUIDED INSPECTIONS

- INTENSIVE OPERATIONAL TEAM INSPECTIONS -

MR, JACK MARTIN, REGION V

  • AUGMENTED RESIDENT INSPECTION PROGRAM
  • REGIONAL TEAM INSPECTIONS
  • PROGRAM MANAGEMENT

- MASTER INSPECTION PLAN ~

- PERFORMANCE APPRAISAL

- MANAGEMENT REPORTS / REVIEWS

- INTERNAL AUDITS i

I l

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