ML20148E162
| ML20148E162 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/30/1997 |
| From: | NRC |
| To: | |
| References | |
| NUDOCS 9706020311 | |
| Download: ML20148E162 (226) | |
Text
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.r Y 1 V
VERBATIM PROCEEDINGS l
l NUCLEAR REGULATORY COMMISSION PUBLIC FORUM IN THE MATTER OF NORTHEAST UTILITIES, i MILLSTONE UNITS 1, 2 AND 3 l E
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APRIL 30, 1997 )
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8 fs WATERFORD TOWN HALL Ioa r 15 ROPE FERRY ROAD T\ .
ll WATERFORD, CONNECTICUT I
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NRC FE.E CLW COPY QQOd7h
. POST REPORTING SERVICE
! HAMDEN, CT (800) 262-4102
!' 9706020311 970430 PDR ADOCK 05000245 T PDR
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l 2 !
l HEARING RE: MILLSTONE UNITS l
() APRIL 30, 1997 1 1 . . . Verbatim Proceedings of the Public 2 Forum of the United States Nuclear Regulatory l 3 Commission in the matter of Northeast Utilities, 4 Millstone Units 1, 2 and 3, held April 30, 1997, at
, 5 7:00 P.M., at the Waterford Town Hall, 15 Rope Ferry l
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! 6 Road, Waterford, Connecticut. . .
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7 l 8 9
10 R 11 MR. JACQUE DURR: Tonight we'll have a 8
12 discussion by our senior residents of the recent ;
13 inspection findings from our last inspection report.
14 They will hit the highlights.
15 Additionally, Dr. Travers will give a 16 discussion of his perceptions of what transpired at the 17 Commission briefing by the staff and Northeast
! 18 Utilities on the 24th, I believe it was.
! 19
- And, additionally, we'll talk about the 20 Restart Assessment Plan and its status, Employees o
- 21 c oncerns, allegation process. And here we're going to )
I g 22 give you really some insight into what is the --
l 23 everybody talks about the allegation process. And we 24 just wanted to share with you a little bit about what i
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HEARING RE: MILLSTONE UNITS a
(~} APRIL 30, 1997 1 is that process and the mechanics of what happens when ;
2 we do receive an allegation.
3 Mr. Imbro will discuss the ICAVP status. ,
l 4 For those of you that don't deal in acronyms or in i
5 initialisms, ICAVP stands for Independent Corrective 6 Action Verification Program.
l 7 And lastly we'll open the floor then to 8 questions and answers.
! 9 So, with that, I'll turn it over to Mr.
10 Easlick, who will give you some -- a description of the 2 11 inspection findings for Millstone Unit 1.
12 MR. TED EASLICK: Let Wayne --
13 MR. WAYNE LANNING: Before you start --
14 again, we're going to entertain questions on the topics 15 as we cover them. So, for example, as people present 16 their topics for discussion, we'll take questions just 17 on that topic. You have to work with us now to limit l 18 your questions to the topic that we just discussed.
1
- 19 And at the end, guys, when we go to -- after our formal 20 presentations, we'll have a general question-and-answer 0:
. 21 session where anything is free to be asked. Okay?
'22 Great.
5
'l 23 Ted?
24 MR. EASLICK: Good evening, everyone.
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HEARING RE: MILLSTONE UNITS l
(} APRIL 30, 1997 l
l 1 Again, my name is Ted Easlick.
l I'm the senior resident
! 2 from Millstone Unit 1. -And we'll be discussing some !
j 3 findings out of 97-01, our. most recent inspection l l t 4 report. i 5 In that report, for Unit 1 we did
^
6 document one Severity Level 4 violation. It had to do 1 7 with an inspection by one of our region-based l
l 8 health / physics inspector, Joe Furier. The issue had to 9 do with a potential unmonitored release pathway having 10 to do with the ventilation system in the rad waste )
E 11 storage building. This was considered a Level 4
.2 12 violation. There was a violation of the 10 CFR Code 0 13 which required licensee to make surveys of radioactive 4
14 material effluent releases to unrestricted areas.
15 For this specific instance, one of three 16 rad waste exhaust fans was not exhausted to the main '
17 stack. Unfortunately, that was from the original
! 18 design. Since it didn't go to the main stack, it did ,
- 19 not have a monitored release path. The other two fans
'20 were directed to the stack and, therefore, their G
. 21 releases were monitored.
g 22 The inapector reviewed operational l 23 history for that particular building. In this case it 24 was a solid rad - te building that had been taken out
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HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 of service since 1980. Did not see any evidence of any 2 operational events or situations that would have led to 3 any releases. Therefore, we determined that this was a 4 Severity Level 4 violation according with our policies.
5 Also during this period, the licensee 6 had put an underwater camera in the spent fuel pool for 7 Unit 1 and had identified significant amounts of debris 8 and discarded components such as fuel -- excuse me --
9 control rods which had been discarded in the pool, 10 which were in the process of, for lack of a better 11 term, cutting up for disposal.
] fS 12 We were very concerned about that.
V 13 There was a significant amount of debris. We concluded 14 that it obviously represented a long-standing lack of 15 concern for what we call FME or foreign material
^
16 exclusion. There was no program for that, obviously.
17 That's why that amount of material had wound up in the
! 18 pool.
h
- 19 We felt that it was low standards that i
t 20 allowed the accumulation of this debris and we felt O
< 21 that there was a potential significant impact for the i 22 fuel that's being stored in that pool.
g l 23 What we did was we spoke with management 24 and we got them to formally commit to some additional t'%
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6 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 inspections before such time as that fuel could be 2 moved to the vessel in the course of a start-up. In 3 particular, we want the bottom of the fuel inspected.
4 We want fuel assemblies to be fully seated in all the 5 racks -- that was part of the problem -- before any 6 fuel movements occur.
7 Additionally, we felt that if the spent 8 fuel pool had a problem with foreign material 9 exclusion, we had an equal concern about the reactor 10 vessel itself because during refueling operation those E 11 areas communicate with each other. So we felt that 12 certainly additional inspections of the accessible 13 areas of the reactor vessel should be done before they 14 would even think abcat moving fuel to the vessel. And 15 they agreed and we formally documented that in our 1 16 inspection report.
17 There was an issue having to do with
! 18 licensed operators during this period. The licensee i
- 19 performed an independent review team that was formed to ,
Ir 20 review what the root cause of operating licensing 6 l
< 21 failures in the recent exam, recent NRC licensing exam, j b l g 22 where six or seven operators failed that exam, l l 23 In the course of that review, the 24 licensee looked at personal qualification statements or POST REPORTING SERVICE HAMDGN, CT (800) 262-4102
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t 7 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 what we call NRC Form 398's. These forms are used to 2 document the candidate's successful completion of their 3 training program. That might be watch-standing. That ,
4 might be on-the-job training, reactivity manipulations.
5 All those things are documented on this form and 6 they're submitted to the NRC when a candidate and 7 licensed applicant is coming for an NRC exam.
8 In this case, what the independent 9 review found was that information on these forms was 10 not completely accurate. In some cases, the candidates R 11 did not have the required training, although the form 12 was signed by the individual, by a member of the 13 training staff and by a member of senior plant 14 management. We're very concerned with that. That is 15 an open issue.
16 In the cases where there were 17 individuals that were actually standing watch, those
! '8
. persons were removed from watch-standing for the period l
l l ; "9 of time it took them to review the actual discrepancies 20 that were on these applications and get that resolved.
O
< 21 We're continuing to look at that and we k
g 22 are investigating the issues that led to those forms l 23 being . inaccurate. And we'll, again, keep that 24 unresolved.
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. HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 l
1 Finally, we documented in our inspection 2 an issue concerning closure packages. You may have ;
3 heard that term before. We had asked the licensee to 4 provide us corrective action closure packages for NRC 5 items that were open. In the case, for instance, there 6 might be violations. There might be unresolved items.
7 They might be inspector follow-up issue. These are all 8 kept on a list. They're open until we can get back to t-9 inspect them.
10 In Unit 1, for instance, there's over E 11 100 open items. So what we asked the licensee to do R
12 was put together closure packages. They should go look 13 at the issue to decide what the resolution is, what the 14 corrective action is and put 'that in a package and 15 present that to us.
16 In December of '96, they sent us a 17 letter, described what those packages would look like.
! 18 In the course of the next few months, we started
- 19 receiving packages. We looked at the first two and ir 20 found that they were not acceptable. They didn't O
. 21 provide enough information for an inspector to close I
g 22 that issue.
ll 23 We relayed our concern to the licensee.
l 24 We tried to make it very clear what we needed to close f () POST REPORTING SERVICE i HAMDEN, CT (800) 262-4102 l-
9 HEARING RE: MILLSTONE UNITS
([} APRIL 30, 1997 1 a package. And we tried to make it even more clear 2 that it would be evidence of their ability to actually 3 provide corrective actions and it would really speak to 4 the health of their corrective action program.
5 They initially gave us a list of dates 6 when these packages would be ready. Based on our 7 !7itial reviews, they withdrew those dates and gave us 8 a new schedule with more realistic dates with some 9 additional time to develop the packages that we felt 10 would be appropriate for closure.
11 And that's it for Unit 1. We can go to 7-s 12 Unit 2 and pick up questions afterwards.
( 13 MR. DAVE BEAULIEU: Hi. I'm Dave 14 Beaulieu. I'm the Senior Resident from Millstone Unit 15 2. We've got three issues that we'd like to discuss l 16 with you tonight that were all covered in Inspection l
17 Report 97-01. One of them is a violation that we
! 18 issued. The other two are issues that were significant 1 19 enough to make our Significant Items List, which means i
e 20 they're considered restart issues by the NRC that the O
. 21 licensee has to address prior to restart.
- h I
g 22 First we'll discuss the violation. The l 23 violation dealt with an individual entering 24 radiological controlled areas without the property C'~ POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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() APRIL 30, 1997 1 dosimetry. When folks enter radiological areas, 2 there's a couple of pieces of dosimetry that they're i 3 required to wear. This is one of them, called a TLD.
4 It picks up any radiation. And once a quarter or so, l
5 they'll read this and they'll be able to determine what
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6 dose you've picked up for that quarter. ;
)
7 Another piece that they're required to !
8 wear when they enter an RCA -- I don't have one here.
9 But it's a digital readout and it will provide the 10 worker an instantaneous readout of what the dose rate 11' is at that particular time, f- 12 That's the issue that they had at A
13 Millstone 2, is that a number of individuals were 14 entering the RCA, radiological controlled area, without 15 wearing their digidose.
16 The inspection report documents three 17 instances where this occurred. Since the inspection I 18 report ended and the report was issued, there have been I 19 several more instances where individuals have entered
[
20 the RCA. So right now there's a total of seven i O
= 21 instances. And the NRC is very concerned about the i
g 22 recurrent aspect of this. And we've had several b 23 meetings with our management with their management that 24 it's just a problem that they need to address.
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( 1 The next issue is a Significant Items l
2 List issue. Normally, when you think of 50.54ff, you l
3 consider -- what pops into your mind is how the 4 physical plant differs from what the design basis says, 5 where the physical plant doesn't match what the paper 6 says.
7 An issue that gets a lot less air play 8 is that the FSAR also describes a lot how systems are 9 operated. And so it's also -- it's important that the 10 operating procedures reflect how the FSAR says that the R 11 system is operated. And it's not really covered by the (3 12 design control process. It's really covered by
%-)
13 procedure change process. So if your operating 14 procedures are changed, you have to make sure that 15 you're still covered by your design basis.
16 That's what the issue is here. There's 17 been a number of instances where operating procedures
! 18 were not correct. The inspection report documents this 1 19 and will be evaluated
- as a restart issue prior to l
r 20 start-up, o
a 21 The third issue deals with a loss of DC 1
g 22 bus event where operators didn't recognize that they l 23 were losing a third channel of wide-range nuclear 24 instrumentation, which means they didn't enter an POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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12 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 action statement out of the tech specs. That was 2 characterized as a non-cited violation. The real issue '
3 of concern that's on our restart list is the fact that l
4 operators didn't have the necessary abnormal operating 5 procedures to deal with the loss of DC bus. And that 6 was a primary factor in not entering the tech spec 7 action statement.
t .
8 So that's the issue, is to make sure 9 that the licensee, as well as the NRC, both review to l
10 make sure that all the required procedures that are l
i jE 11 required by tech specs are, in fact, in place and are lE
( .
12 adequate.
I 13 That's all we had for Unit 2.
14 MR. TONY CERNE: Good evening. My name 15 is Tony Cerne. I'm the Senior Resident Inspector for 16 Millstone Unit 3. For this inspection period in Unit i
17 3, I'd like to discuss some positive observations and
! 18 also some areas where there was some continuing i: 19 concerns. There were no violations identified in Unit ie 20 3 during this period.
I O
-< 21 In operations, we found. good contingency I
g 22 planning and conservative decision-making in both the
! -l 23 planned operational evolutions and the emergency j J
1 24 shutdown conditions.
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1 With the plant shut down, all the units '
i 2 have a shutdown risk model. And in the case of Unit 3, 3 we're finding that they're using- that shutdown risk l 4 model very conservatively in determining how work is 5 done, how it's controlled and in deciding what ,
6 components to take out of service so they maintain a l 7 safe margin in their shutdown condition.
8 In the area of maintenance, they've '
9 adopted what some other plants around the country have 10 adopted. It's -- they used the acronym FIN or WIN, Fix 2 11 It Now team. Some people call it Work It Now team, 8
12 WIN.
13 The FIN team at Millstone is a dedicated 14 group of maintenance personnel with some operational 15 people involved in getting on the problems in real 16 time, space, working them as they're found and getting 17 them corrected and any issues dispositioned properly to I 18 restore tle components quickly back to service.
- 19 In reviewing this FIN process for the 20 first time at Unit 3, we found that it has been O.
. 21 implemented and is working well in a conservative I.
g 22 manner.
l 23 In terms of the third area, plant 24 condition, based on walk-downs of the plant we've found
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14 HEARING RE: MILLSTONE UN3TS
() APRIL 30, 1997 1 that there are significant improvements in Unit 3 in 2 the areas of housekeeping, material conditions and work 3 controls.
4 And finally in the area of positive 5 observations, in the area of oversight, what's called 6 nuclear safety and oversight, which is traditionally 7 called quality assurance, we observed increased nuclear 8 safety and oversight involvement in performance 9 monitoring, interfacing analysis and support of all 10 three --
all Unit 3 management and line staff 3 11 p activities.
n
-~ 12 So those observations we feel are U
13 positive. And I'll give some assessment at the end 14 when I -- after I go through a couple of negative 15 areas 16 The three areas we found that we need to 17 watch as continuing areas of concern, one in the area
! 18 of engineering was in the case of overlap testing.
- 19 That terminology is used to describe a system where the 20 plant is obviously designed to run properly during O
= 21 normal operations but also respond to accident a 22 conditions. And you don't -- you can't test for an 3
l 23 accident in a sense that you have an accident happen.
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! 15 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 electrical components and watch how the systems l
l 2 respond. And that perturbs the system. By the very 3 . fact you're inserting the signal, you're perturbing ;
l 4 something, as it wouldn't happen in a normal accident.
L 5 So the way they control such testing -- and often there
! 6 is corresponding equipment that has to respond to such 7 signals -- they do overlap testing. They'll test part 8 of the system. Then they'll back out and test another 9 part of the system. And the overlap implies that you ,
10 catch all the responses that are required.
R 11 In this area, one of our visiting R
12 specialist inspectors found that the overlap test 13 reviews conducted in 1993 were not adequate. The '
14 licensee failed to identify the deficiency and ,
15 concluded that the '93 reviews had properly responded !
16 to the NRC generic letter 96-01 which was written 17 specifically to cover this area. So the response to
! 18 that previous NRC identified generic concern was not
- 19 adequate. .
20 In the area of procedures, you may have O
< 21 heard the term PUP. Well, that acronym is the ;
I g 22 Procedures Upgrade Program. This program has been in l 23 effect for about five years. And, again, one of our j 24 visiting inspectors looked at it and found that i i
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16 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 l
l 1 although there are procedural upgrades occurring and I
- 2 some of them are going well, the quality of the l 3 procedures varied among the various procedures in use 4 and a number of condition reports, which is the 5 licensee's way of documenting deficiencies, indicated 6 that technical problems were still being found in some 7 of the procedures that had already been upgraded, which 8 indicates that it's not an effective a program as we 9 would like to see.
10 And, finally, another term I'll use is g 11 seismic two-over-one. All the safety-related ;
n 7s 12 components in a nuclear power plant are designed to
'd 13 withstand a seismic event, an earthquake. The non- !
14 safety related components which are not required to 15 function during an earthquake still have to have an 16 important structural function and that is not to fail 17 in a way that will adversely affect safety-related
!o 18 cc3ponents. For example, if you have a non-safety-f 19 related fan sitting over a safety-related motor, that 20 non-safety-related fan has to be designed in a way so o
. 21 the earthquake won't shake it free and have it drop on g 22 the safety-related motor and, therefore, cause some l 23 adverse effect.
24 Again, in walk-downs through the plant, l 1%
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i 17 HEARING RE: MILLSTONE UNITS
(]} APRIL 30, 1997 l
.1 we identified that there were some unrestrained l
2 components. In this case, there was a trolley and ,
i 3 chain-fall type device which was located in proximity 4 to some safety-related components. And in reviewing 5 this, we found that this component had been installed ;
6 in the first refueling outage back in 1987 and had l 7 never been removed. This called into question how they 8 were controlling their seismic two-over-one program and r 9 was a repeat of some of the issues addressed in l 10 Inspection Report 96-201, which was a big inspection we :
R 11 did about a year ago, looking at various areas in Unit 8
12 3.
O 13 The theme here is, I think you'll see, I
i 14 in the positive areas that were identified we're 15 finding that current licensee performance is being l 16 handled well in the sense that they're running the )
17 plant well. They're controlling shutdown risk.
I 18 They're addressing the problems as they're identified.
I 19 Where they're having their more significant problems is
- l
, 20 in the historical areas, finding the problems, making e
< 21 sure they've generically covered them all and !
l l t
g 22 dispositioning them properly. !
- 'l 23 In the cover letter to this report, we l
l 24 documented that fact and we highlighted'it with the i
l
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18 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 concluding J.entence that "Such continuing concerns in 2 these diverse problem areas highlight the need for 3 renewed emphasis on the self-assessment of programmatic 4 areas of concern, as well as the effectiveness of 5 already-completed corrective actions."
6 Finally, the three areas I mentioned 7 that were problems, those are all individual line items 8 in our Significant Items List for Unit 3, which is a 9 public document attached to the Restart Assessment Plan 10 which was issued -- the most recent edition was issued R 11 about a month ago.
8 12 That concludes the assessment of Unit 3 13 and all three Millstone units during this last 14 inspection period. And if there are any questions, I 15 guess I'll turn it back over to Jacque Durr to 1
16 moderate.
i 17 MR. LANNING: Let's take the questions
! 18 on technical jargon first. If you heard a term you h
- 19 don't understand, let's talk about that first.
! lr 20 Everybody understand what a bus is? It's yellow with O
< 21 black letters on the side.
22 A VOICE: Explain it please.
{
l 23 MR. LANNING: Fuse box. Fuse box.
24 How about technical specifications?
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HEARING RE: MILLSTONE UNITS' APRIL 30, 1997
(}
l 1 It's part of the operating license. It sort of sets i 2 the limits, safety limits, for example, tells what the 3 limitations are on equipment can be out of service and t
! 4 that sort of stuff.
l 5 What other jargon did we use that we l l
l 6 ought to make sure we cover? Oh. Licensed operator.
7 That's the personnel who physically operate the l 8 controls of the reactor. They're licensed separate 9 from the utility, separate from Northeast Utilities.
I 10 They are licensed to operate a nuclear power plant.
R 11 There's both licensed and non-licensed operators.
R 12 Any other terms?
13 MR. GENE IMBRO: FME. FME. Foreign 14 material exclusion.
15 MR. LANNING: Yes. Foreign material 16 exclusion, FME. That's junk, simply stated. It's 17 trash. It's in a place where it's not supposed to be.
! 18 And at Unit 1 it's in the spent fuel pool. -
j
- 19 Okay. With that ten-cent lesson, any
' 1 20 questions _for the residents?
le O
< 21 Mr. Markowitz?
b g 22 MR. JOHN MARKOWITZ: I don't want to put ll 23 anybody on the spot, but on the 6:00 news tonight, the I 24 news on Channel 3, Channel 8 reported that the Hartford POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
20 HEARING RE: MILLSTONE UNITS
) APRIL 30, 1997 ,
1 Courant is reporting the licensed operator problem in 2 Millstone 1 with attributions to NRC spokesmen that 3 records were falsified. We're probably going to read 4 about it or hear about it tomorrow. I was wondering if 5 you could -- is there anything more you could say about 6 that issue *.o this group so that when we read the paper 7 or hear the radio or television tomorrow, we have a 8 frame of reference from which to understand what is 9 being reported? Thank you.
10 MR. EASLICK: Certainly. What an E- 11 individual has signed for on that form is that he has 8
12 received the required training. The form isn't 13 specific as to how many hours of classroom training, 14 how many reactivity -- it doesn't actually say that on 15 that form. What he's signing for is the fact that he 16 received the required training to sit for a license.
17 Now, what some of the individuals I 18 potentially were relying on was the training supervisor l ~l
- 19 to keep track of those hours and to ensure that, in 20 fact, the operator / candidate did everything he needed i-O
- < 21 to do to be in compliance with an application to sit L $
g 22 for an NRC license. That individual still signed his l~ 23 name to that form acknowledging the fact that he was 24 complete. The onus, of course, is on that individual l ( POST REPORTING SERVICE I HAMDEN, CT (800) 262-4102
21 HEARING RE: MILLSTONE UNITS i APRIL 30, 1997 1 to know what he's signing for.
2 You have a training supervisor. His 3 name is on the form. You also have a senior manager, 4 plant manager. His name is on that form, also 5 attesting to the fact that this individual that's going 6 to come before the NRC for a license has received all 7 the applicable training that's required.
8 Now, the training center has received 9 accreditation from INPO, Institute of Nuclear Power 10 Operations, and their program is what's called SAT or 2 11 Systems Approach to Training. And the NRC has accepted R
12 that as a valid training program.
13 So when we see that the applicant is ;
14 taing trained on an SAT program, we accept that as a 15 valid program and we accept the fact that he has j 16 received the required training. Therefore, it's not l I
17 specifically laid out on that form. And, obviously, we i
! 18 have to accept that individual's signature for the fact
- 19 that that training went on. So --
20 MR. LANNING: Some of the examples of O
. 21 the training for certifying --
1 22 MR. EASLICK: For instance, some of
{ the !
l 23 wamples would be that the individual needed to have 13 24 weeks on shift operating under instruction, so that he O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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i 22 HEARING RE: MILLSTONE UNITS
(() APRIL 30, 1997 1 would tag along with a qualified operator for 13 weeks.
2 In some cases, they found an individual in Unit 1, for 3 instance, only had three weeks. And they found that 4 out by reviewing the Control Room logs where they 5 actually have to sign in on -- they have to sign their 6 name to the log to prove that they were there.
7 It might be reactivity manipulations 8 where the requirement would be that an individual had 9 to make five reactivity manipulations. That just means 10 he has to change reactor power five times. And there's R 11 some guidance as to how much reactor power has to 8
12 Some
() change. individuals did not meet that l
13 requirement. They may have only had three.
14 A VOICE: Confirmatory action letter.
15 MR. EASLICK: I'm sorry?
16 A VOICE: You might mention the CAL that 17 was written.
! 18 MR. EASLICK: In response to this and 1
19 our investigation, the licensee sent us a letter i
r 20 identifying what had been done, what ongoing reviews O
. 21 were taking place. What we did in response to that was I
g 22 issue a confirmatory action letter or CAL, if you heard ll 23 that term. And the CAL clearly delineates what the 24 agreement is between NU and the NRC concerning this r~g POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
23 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 {
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1 issue. And in the CAL there are commitments to perform 2 reviews, do whatever inspections are required to 3 determine what the scope or the extent of the problem i
4 is, and then come up with a corrective action plan l l
5 which needs to be reviewed by us prior to restarting I l
6 any training or requal training, initial training that 7 has to go on. So that CAL is out there right now.
8 With respect to 'how the inaccurate 1
9 information got there, that needs to be reviewed and l 10 that needs to be inspected and assessed. It would be R 11 easy to say that it was falsfied willfully. We don't M
12 know that yet. That is a possibility. Certainly is a .i 13 potential. But until we do an investigation, we can't l
14 make that call. But, clearly, an individual signed his
- 15 name to an application that said that he did something.
16 If he didn't do that, which is in some of the cases, we 17 don't know if that was a bureaucratic problem or if 1
! 18 that was a paperwork problem or that individual, in l ll
- ; 19 fact, knowingly and willfully put his name down when, l
20 in fact, he had not received it.
O
< 21 I hope that answers your question. I
.k 22 was a little long-winded.
lg l 23 MR. DURR: Yes. There's one additional
- 24 piece of information I'd like to add to that. And that O POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102 I l
.I
l 24 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 is on our Significant Items List that he alluded to 2 earlier, this is a line item for all three units at 3 Millstone. So that will entail additional inspection 4 to make sure that when everything comes to conclusion, 5 that we'll go in and ascertain what were the facts and 6 there will be an inspection to ensure that the 7 operators are, in fact, qualified to do the job.
8 MR. LANNING: Yes, sir?
9 MR. PETE REYNOLDS: I'm Pete Reynolds 10 from Waterford. First I want to make a correction.
- E 11 FME, foreign material exclusion, is not just junk and t R 12 garbage and trash.
.-) It also includes tools that are not 13 supposed to be in that area, parts of the equipment 14 that's not supposed to be in that area. So, just 15 square that away.
16 Solid rad waste. You said according to 17 your report that Northeast Utilities said it is out of
! 18 operation since 1980?
19 MR. EASLICK: That's correct. That was
!r- 20 -- I was told that, yes.
O
. 21 MR. REYNOLDS: Okay. When they say it I-g 22 was out of operations, what did they Laan? That
-l- 23 nothing --
was it used for anything to do with l
24 radioactive material or anything?
l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
25
! HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 MR. EASLICK: It was used for storage.
2 So that the original intent was, I believe, cement 3 solidification process. That was not going on.
4 Apparently that's what was stopped back in the 80's.
5 The building was used for storage.
6 MR. REYNOLDS: The building also was 7 used to clean decontaminated tools and it was closed, I 8 think, in '94, '93 or '94, due to a fire. But they've 9 used it since I was there in 1980 after they closed it 10 up for the original intent. So they lied to you.
2 11 The exhaust fans that was used to carry 8
(s 12 away the acid fumes and the radioactivity that was O
13 washed off of these tools was vented right outside. It 14 did not go through the stack. So you can check up on 15 that.
16 They had a fire, I think it was 1993, !
17 that -- and they ran acid into the drain pipes and so l
! 18 forth. So that's why it's closed up now. Just clarify l 19 that.
!r 20 MR. EASLICK: Okay. Thank you.
O
< 21 MR. REYNOLDS: It also said that the I
g 22 fuel rods in the spent fuel pool would have to be h 23 inspected, the bottoms of them, to make sure that they ,
1 24 didn't pick up any foreign material. l f\
' ~
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i 26 HEARING RE: MILLSTONE UNITS
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APRIL 30, 1997 I
1 MR. EASLICK: Right. I 2 MR. REYNOLDS: How do you propose that 3 they're going to do that?
4 MR. EASLICK: They would be using an 5 underwater camera to do that. The camera would have to l 6 look underneath from the nose cone looking tp into the 7 fuel.
l 8 MR. REYNOLDS: And what percentage of 9 view are you going to accept? A 50-percent inspection 10 or an 80-percent?
E 11 MR. EASLICK: You mean of the individual K
g3 12 fuel assemblies? l
\,) \
13 MR. REYNOLDS: Right.
14 MR. EASLICK: We'd be looking for 100- l 15 percent inspection for each assembly.
16 MR. REYNOLDS: You're not going to get 17 100 --
you're not going to get 100 percent with a l 18 camera.
- 19 MR. EASLICK: No. You mean number of h 20 r fuel assemblies or --
O
. 21 MR. REYNOLDS: No.
k g 22 MR. EASLICK: --
the fuel assembly l 23 itself?
24 MR. REYNOLDS: The actual view of the
(
/~T
' ~
POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
27 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
-(])'
1 assembly --
2 MR. EASLICK: Yes.
.3 MR. REYNOLDS: -- and if there was any 4 material --
5 MR. EASLICK: Right.
6 MR. REYNOLDS: --
attached to the 1
7 bottom. l 8 MR. EASLICK: You won't get 100 percent 9 of the entire fuel assembly. That's correct.
10 MR. REYNOLDS: I'm talking about the R 11 bottom.
R
. 12 MR. EASLICK: Yes.
13 MR. REYNOLDS: Because of the way it's 14 shaped with the fingers, a piece of metal or anything 15 could get in and lodge on the shelf of these fingers.
16 So if you just take a view of this, you're not going to 17 be able to get a full view.
18 MR. EASLICK: You mean up inside the f ;
l f 19 channel area? l 20 MR. REYNOLDS: Right.
O
.- 21 MR. EASLICK: Yes.
I g 22 MR. REYNOLDS: Right on the bottom.
l 23 MR. EASLICK: I believe we recognize 24 that.
( POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
28 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 MR. REYNOLDS: So you're not going to 2 have 100 percent.
3 MR. EASLICK: Not of an individual fuel 4 assembly, no.
5 MR. REYNOLDS: And that's the critical 6 part.
7 MR. EASLICK: Mm-hmm.
8 MR. REYNOLDS: So if you don't have 100 9 percent and you've got a piece of metal in there that's 10 going to distort the electrons as they're supposed to 2 11 go through their path, then you could have a different R
fS 12 reaction than you're expecting.
LJ 13 MR. EASLICK: I'm not sure if I 14 understand you.
15 MR. REYNOLDS: With the metal in there -
16 -
I'm not sure exactly how it works. I'm not a 17 scientist. But I know enough about it that if there's I 18 metal, some type of metal or some foreign material in 1 19
- the bottom of these fuel assemblies, it could affect 20 the way that they set down. And it also, with the way O
. 21 the electrons flow and all that and neutrons and, you I
g 22 know, they hit each other, you knov, the whole physical l 23 process, that this metal can cause hot spots. So if 24 you can't do 100-percent inspection of it, you could O'N POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 j
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29 HEARING RE: MILLSTONE UNITS i
(])' APRIL 30, 1997 l l
1 end up with hot spots. And, believe me, there has been 2 a lot 01: metal dumped in both the reactor cavity and f
, 3 that fuel pool that's unaccountable, that they haven't i I
4 accounted for. So you better do a close inspection of l 5 it.
6 The other is training the people i
7 responsible for signing off on these fraudulent claims i
i 8 of proper training for the licensed reactor operators. )
9 What has happened to them?
i I
- 10 MR. EASLICK
- The individuals who signed j R 11 off?
IM i 12 MR. REYNOLDS: Yes. I 13 MR. EASLICK: Right now it's still in 14 investigation. So nothing's been done to- the 15 individuals.
16 MR, REYNOLDS: Just --
17 MR. EASLICK: The operators were removed l 18 from shift until they can assess --
I
- 19 MR. REYNOLDS: It's under investigation 20 just by the NRC?
O
= 21 MR. EASLICK: Well, no. The licensee i 22 also is doing their investigations.
g l 23 MR. REYNOLDS: And the licensee?
24 MR. EASLICK: And they're providing that O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
30 HEARING RE: MILLSTONE UNITS
(') APRIL 30, 1997 1 information to us as part of the confirmatory action 2 letter.
3 MR. REYNOLDS: Is this an infraction of 4 Federal law, falsification of these records?
5 MR. EASLICK: That is an infraction of 6 Federal law, yes. 50.9.
7 MR. REYNOLDS: So has the Justice 8 Department been called in on it?
9 MR. EASLICK: I'm sorry?
10 MR. REYNOLDS: Has the Justice 11 Department been called in on it?
f-s, 12 MR. EASLICK: I'd have to --
V 13 MR. DURR: Yes. Let me field that. Any 14 time there is a violation of Federal law, the Office of l
l 15 Investigation is notified by us, our Office of )
l 16 Investigation for Criminality. Any time that the l
17 Office of Investigation gets involved, where there's l i ! 18 likelihood that there is criminal wrongdoing, they will l -
19 notify the Department of Justi.ce. And the Department 20 of Justice then will determine whether they want to get i O
= 21 involved or not. So all of those things will happen if g 22 there's any smacking of wrongdoing.
$ 23 But the thing you have to --
let's 24 remember we're in America and it's you're innocent O
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l 31 !
HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 '
l 1 until proven guilty. So the onus is now to prove 2 somebody guilty. And we haven't done that. And so 1 3 that's ongoing. And so until you prove somebody's 4 guilty of something, you really can't do anything to 5 them. l 6 Now, where it was obvious that the I
7 licenses were infringed upon, then we took action with i
8 the operators and the utility took action with the 9 operators unilaterally. They did that. But we were
- 10 obviously interested that they do something.
! 11 But -- so I guess the point to be made 12 now is that the Department of Justice, whether they're 1 O 13 involved or not, is beyond what we can talk about. And 14 all I can tell you is our Office of Investigation has i
15 been notified. That's all I can tell you. And you l 16 have to let it run its course.
17 MR. REYNOLDS: Okay.
l 18 MR. DURR: Okay?
I. 19 MR. REYNOLDS: While you're standing lr 20 there -- '
l O
i 21 MR. DURR: Sure.
I g 22 MR. REYNOLDS: -- does this include the l 23 infractions that the. operators had in 1991 when they 24 falsified entries into certain areas for doing their I
)
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! HAMDEN, CT (800) 262-4102 i
32 HEARING RE: MILLSTONE UNITS
) APRIL 30, 1997 1 rounds?
2 MR. DURR: That was all looked at -- I'm 3 familiar with the issue, but I don't know the details 4 or what took place in that time frame. But that was a 5 national problem. It wasn't just a localized problem.
6 We found that at a lot of reactors. And what took 7 place and what happened there, I don't have personal 8 knowledge of.
9 MR. REYNOLDS: Okay. And still talking 10 about training, while I was there I was a maintenance 11 mechanic. We went to school all the time. And I feel l 12 that the whole training program, not just with the I l
13 operators, but with everyone involved, should be looked l 14 at because 99 percent of the time when we went to l 15 school to learn how to work on a certain type of valve j 16 or pump or something like that, we was not allowed by 17 management to apply those procedures in the plant. The
! 18 equipment or the valve, particular valve, might have
- 19 been a generic valve and it didn't even apply to ones 20 at Millstone. And I feel that the whole training O
< 21 process there should be looked at. If you're going to k
g 22 be trained to operate a valve or work on a valve, it l 23 should be the valve that's in the plant.
24 MR. LANNING: I agree with you. And the O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
33 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
( }) -
1 training of other personnel, system engineers, 2 mechanics, health physicists, part of a bigger training 3 question is also part of our restart assessment list.
4 MR. REYNOLDS: Okay.
5 MR. LANNING: So it's there.
6 MR. REYNOLDS: That's enough on Unit 1.
7 You said on Unit 2 they had -- I have to defend 8 Northeast Utilities a little bit on this. They didn't 9 have a dosatech?
10 MR. BEAULIEU: Correct.
E 11 MR. REYNOLDS: When I was there, unless 8
12 the policy's changed -- and I don't think it has -- you
(~)
G' 13 could either use a dosatech or a pick.
14 MR. BEAULIEU: Yes, Dosatechs are more 15 of a high-tech version of the pick.
16 MR. REYNOLDS: Right. So --
17 MR. BEAULIEU: Provides a digital l l 18 readout of --
- 19 MR. REYNOLDS
- So they had neither one
!r 20 on, neither --
l 0
- . 21 MR. BEAULIEU: Correct.
' b g 22 MR. REYNOLDS: Okay. That's very l 23 unusual because your pick usually stays with you no
, 24 matter what.
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1 34- j HEARING RE: MILLSTONE UNITS
} )- APRIL 30, 1997 i
1 MR. BEAULIEU: Yes. That's not the case
- 2 now.
! 3 MR. REYNOLDS: Yes. Okay. The DC bus i
4 event that you mentioned, they didn't have the proper ;
5 procedure? With the licensed operator, they're !
i 6 supposed to know the procedures. And what I didn't 7 quite understand about it was they didn't have the i
j 8 proper procedure, the procedure was wrong, or they j 9 didn't know how to interpret the procedure?
i j- 10 MR. BEAULIEU: Tech specs require that i
i2 11 the licensee have certain operating procedures and .
l M 12 abnormal operating you
() procedures.
3 If look, i
13 technically they -did have a procedure. It just I- 14 provided just a minimal amount of guidance for the ,
j- 15 operators. So, in essence, the operators had to think i 16 on their feet, if you will. You expect them to always
- 17 be thinking. However, on the other hand, to the
- l 18 maximum extent possible you expect them to lay it out, 19 the steps that you really expect them to take in 20 advance and have it pre-thought-out for them and have S
. 21 the procedures laid out to the maximum extent that you k-g 22 can. That's the problem that we have at Unit 2. And l 23 they're developing like 12 new abnormal operating 24 procedures to deal with loss of DC bus evenc.
POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l
35 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 MR. REYNOLDS: Okay. That's what I 2 figured. But the problem with the procedures at Unit 3 1, 2 and also at Unit 3 is that a lot of them are 4 generic, like I mentioned of a certain valve. It will 5 say how to take apart a relief valve, which is a 6 generic thing. But each relief valve, depending on the 7 manufacturer, is different. And this is what's 8 happened to these procedures. Because I was in the 9 procedure rewrite group until they fired me. And a lot 10 of them are generic, not just on the critical R 11 procedures, but all the procedures and they don't 8
12 pertain to a particular type of equipment that they .
l 13 have, especially to do with valves and pumps and 14 motors. So the whole procedure process, like you said,
- 15 has been in effect for five years and there was a 40-l 16 million dollar price tag on it. And I imagine it's l
l 17 probably up to 100, 200 million by now.
l 18 MR. BEAULIEU: Yes. Tech specs, just 1.l . 19 about all tech specs that I'm aware of are -- reference 20 Regulatory Guide 1.33 and that's the document that o
,. 21 lists the procedures that licensees are required to
'l g 22 have. One of the pieces of that under maintenance l 23 procedures, they specifically allow for skill of the 24 trade. Like if your mechanic in your local garage J
9
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l 36 i HEARING RE: MILLSTONE UNITS I
) APRIL 30, 1997 l
1 doesn't need a step-by-step procedure to do -- change 2 spark plugs, for example. In other words, there's a !
3 certain amount, a level of knowledge that you can ;
4 expect and that's subjective. And you'll see --
t 5 MR. REYNOLDS: Maybe you better stop 6 before you get in too much trouble.
7 MR. BEAULIEU: I think I'm on --
8 MR. REYNOLDS: I agree with what you're 9 saying. But the way things have been and what you 10 people have been doing is not following procedures.
! R- 11 They've been hounded for that, which in a lot of cases
!R 12 it's true. And being a mechanic or electrician or INC l Os .
! 13 control technician, we were not, towards the end, the l 14 last few year, not allowed to be able to think. If it 15 wasn't on the procedure, you were wrong. That was NRC ;
16 violation of that. So you've got to make up your mind 17, which way you're going to go. Either you're going to
! 18 have strict procedures or you're going to have the 1 19 knowledge of the mechanic doing the procedure, l
ir 20 MR. BEAULIEU: The level of detail in I0 l < 21 any particular procedure, like I said, is subjective l g 22 and you'll see --
it can be an acceptable level of l 23 detail and, like I said, some licensees would choose to 1
l 24 have a greater level of detail. And it's a judgment POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 3
37 HEARING RE: MILLSTONE UNITS
-( ) APRIL 30, 1997 1
1 call in many cases on the part of the licensee as well 2 as the NRC to what level is necessary to have an
'l 3 . adequate procedure. l 4 MR. REYNOLDS: Is that true throughout 5 the whole industry?
6 MR. BEAULIEU: Yes.
7 MR. REYNOLDS: So if you have somebody )
8 coming from another plant to do some inspection of 9 Millstone, their requirements where they've been l 10 working before could be more detailed on the procedure R 11 and, if Millstone doesn't have it, then they're written !
12 up for it? It's a judgment call? !
13 MR. BEAULIEU: It's --
14 MR. REYNOLDS: You can't have it both 15 ways, 16 MR. BEAULIEU: It's a possibility.
17 There are many things that you expect, the skill of the l [ 18 trade, right-tighty, lefty-loosey, of nuts and bolts.
! h 19 You could proceduralize that. You could get to an 20 extreme level of detail. And it varies and it depends o
- 21 on the training program and it depends on the judgment I
g 22 of the procedure writers at the time.
l 23 MR. LANNING: Mr. Reynolds, let me -- I
, 24 understand your point. We're really getting into a i
(:) POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
38 HEARING'RE: MILLSTONE UNITS 4 l .
APRIL 30, 1997 i
1 much broader area than we want to tonight. ,
i 2 MR. REYNOLDS: Well, the major point is !
3 that some of the equipment is critical and you've got
! 4 to know whether a nut is right or left-hand thread.
- 5 MR. LANNING: Right. .
l 6 MR. REYNOLDS: And the detail is needed. ,
7 MR. LANNING: Some details are needed.
8 Yes. You're right. l 9 MR. REYNOLDS: Okay.
l l 10 MR. LANNING: Okay. Any other
.R 11 questions?
j 12 MR. REYNOLDS: Just a ccmment about Unit O 13 3. You said they had improvement on their procedures
! 14' and everything that they've been doing. I just jotted 15 down a note, "Any improvement is better than they had ;
16 in the past." So I don't know how great the l 17 improvement is.
l 18 MR. LANNING: Any other questions of l'- 19 residents?
20 MS, SUSAN LUXTON: Hi. I'm Susan Perty O
< 21 Luxton from the Citizens Regulatory Commission in 1
i g 22 Waterford. I have a couple of questions. I'd like to
-l 23 get to the Unit 2 debris in the spent fuel pool.
I 24 MR. EASLICK: Unit 1.
3 i
- O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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39 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
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1 MS. LUXTON: Unit 1. Sorry. Unit 1.
2 And how it was, based on this information, the 3 acceptability of the degraded canditions in the spent 4 fuel pool will be unresolved pending NRC review. I 5 want to know why -- or, actually, why you're allowir.g 6 them to not clean it up until their next refueling 7 outage, which --
I lost the paragraph now. But 8 whenever the heck that's going to be. Why don't they 9 have to have that cleaned up now? Because riy 10 understanding is --
and correct me if I'm wrong.
3 11 Doesn't that affect the spent fuel pool conditions gg 12 presently with all that debris and whatever junk is in V
13 there? Why wouldn't you have them do it now? Why do 14 they have to wait? Why can they have all that time?
15 MR. EASLICK: Currently how it affects 16 the fuel is that there are fuel assemblies that are not 17 seated properly in the fuel racks. l l 18 MS. LUXTON: Right. I I
- 19 MR. EASLICK: Some of them have to do ir 20 with channel locks being caught on the rack where the o
21 l l
. fuel assembly might be three inches above. But others g 22 are unknown reasons. So we can only assume that it's l l 23 debris. So what we are requiring and what we asked for 24 a commitment from them was not to move any fuel until POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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40
) A RkL 30 l 1 all those assemblies have been seated.
2 So in the process of seating those l 3 assemblies, there will be some cleanup going on. It -
4 has to be.
l 5 MS. LUXTON: So --
but it won't be l 6 resolved then until they've seated them all?
l
- 7. MR. EASLICK: That's correct.
8 MS. LUXTON: And that goes into what Mr.
9 Reynolds said about at that time you'll be doing the l 10 looking with the camera at the bundles.
i R 11 MR. EASLICK: Right.
1 E
12 MS. LUXTON: And you said that you 13 wouldn't be able to do 100-percent assurance that -- he '
14 brought up a point that you wouldn't be able to see 15 them properly with the camera. So how are you going to 16 convince us in the public or assure us that you'll be 17 able to have 100-percent knowledge of what the 18 situation is like?
I
- 19 MR. EASLICK: I think what they're going h 20 to have to do is when they find out what is holding up r
C
. 21 these bundles or what's preventing to see them, they'll g 22 get a better idea of what the extent of the trash or l
23 how that affects the fuel assemblies. I think 24 certainly with what we know now we would accept a l
l
(:) POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
l
' 41 HEARING RE: MILLSTONE UNITS
(')
v APRIL 30, 1997 1 visual look at the bottom of the fuel assembly.
2 If the avolution of setting these 3 bundles and removing the fuel to see what's in the 4 racks would indicate that there was further debris 5 impacting the fuel, I think we'd have to then question 6 to what extent the fuel had to be inspected. You 7 could, in fact, remove the fuel channel, which is the 8 square metal around the fuel bins, if you wanted to go 9 to that extent. That is possible. I think it would 10 really depend on what they find as to what the impact 11 is. And you won't know that until you get in and start
(-)
LJ 12 lifting those assemblies and see what's there 13 MS. LUXTON: Okay.
14 MR. LANNING: I think in part the answer 15 to the question is you don't want to stir up all of 16 this stuff prior to --
17 MR. EASLICK: That's another issue, yes.
! ". 8 MR. LANNING: -- fuel by cleaning it up.
B
- 19 MR. DURR: Let me help just a little .
E l
) 20 bit. The fuel -- the fuel racks set up off the bottom '
O
. 21 of the spent fuel pool.
g 23 MS. LUXTON: Don't stand in front of me l 23 like you do.
24 MR. DURR: I'm sorry.
[
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1 42 HEARING RE: MILLSTONE UNITS I
) APRIL 30, 1997 '
1 MS. LUXTON: Don't stand in front of me 1
2 like you do. !
1 l 3 MR. DURR: Where do you want me to l 4 stand?
l 5 MS. LUXTON: Because I get --
I don't 6 like it. It's a very intimidating posture to me.
7 MR. DURR: (Inaudible) ,
l 8 MS. LUXTON: Good. Okay. I know. But l 9 you did that last month, Mr. Durr, and I don't like l
10 that when I'm sitting here and you stand and start that
!R 11 stuff. Good. All right. Yes.
t R .
12 MR. DURR: The spent fuel pool is a O 13 large tank with a metal lining and it's concrete around l
14 it and it has racks in it.
l 15 MS. LUXTON: Right.
i .
16 MR. DURR: And there are just tubes that 17 you put fuel elements in. And it's a matrix, like a l 18 checkerboard.
i I. 19 MS. LUXTON: Right.
l 20 MR. DURR: And these fuel racks set up O
. 21 off the spent fuel pool floor. The debris, most of the l
- 22 debris, that we're talking about is laying on the 5
l 23 floor.
l 24 MS. LUXTON: Right. And sediment.
f POST REPORTING SERVICE KAMDEN, C'.' (800) 262-4102
43 .
A L3 ,
1 MR. DURR: It's sediment. It's stuff -- l 2 MS. LUXTON: Right.
3 MR. DURR: -- on the floor. ;
I 4 MS. LUXTON: Right.
5 MR. DURR: So what we're concerned about :
I 6 is things don't, through just natural convection, get ,
7 drawn up into these samplings and that these, as he j 8 explained, these fuel assemblies that are up off the c 9 bottom, that obviously are not seated down in, aren't i
10 sitting on something that's holding them up. .
R 11 Now, there could be any number of ;
R 12 reasons why these fuel assemblies aren't sitting down j 13 all the way. As he explained before, there's a clip i
- i 14 that sets on the side, that it may be caught on top so ;
15 that it won't let it go all the way in. It could be !
16 mechanical binding. It could be-a lot of things. It !
17 could be debris down'in there. !
! I- 18 We want all those fuel assemblies, the l I
j l
. 19 nozzle -- there's a big nozzle on the end. We want all l
20 those inspected before they put them back into the 5 O l
.- 21 reactor because we don't want any foreign material to i l 22 go into the reactor with fuels. So that's why we j
g l 23 wanted to do this visual inspection of the bottom of I j 24 these things.
i O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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I 44 HEARING RE: MILLSTONE UNITS i APRIL 30, 1997 ;
i 1 What they're going to do first is 2 they're going to inspect the reactor to make sure over
- 3 the years they haven't already transferred --
4 MS. LUXTON: Some of that debris.into --
5 MR. DURR: -- debris over there. ,
6 MS. LUXTON: Otay.t >
r 7 MR. DURR: They're going to inspect all 8 accessible parts of the reactor and they're going to 9 inspect the bottom pieces, nose pieces, and then 10 they're going to put the fuel back in the reactor.
11 Now, there's stuff still over here. But that's not ;
12 going anywhere. And so I don't care how long, you know 13 -- as long as they fix it before the next time they put 14 fuel in there and clean it up -- that's why we allowed 15 them to go to the next refueling outage. So with that i t, debris, they'll do the cleanup during that refueling -- ;
17 that operating cycle. And so the next time they put
! 18 fuel in, it will be clean.
- 19 MS. LUXTON: Okay.
20 MR, DURR: Okay?
O
< 21 MS. LUXTON: Good.
l j 22 MR. DURR: I'm sorry. I didn't mean to l 23' intimidate you.
24 MS. LUXTON: You can stay right here.
1 POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l
i
,n-, p r- ,
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45 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
.({}
1 All right. Now, my next issue, the next issue was --
2 the next issue was -- now bear with me. These reports 3 are very long and very trying. I had a question about 4 something on Page 6 of 41. And that was in Unit 2. i 5
And it talks about -- and I want to read this. And I 6 came in a little, teeny bit late, so I might have !
7 missed the explanation for Unit 2. Now, who is that? l 8 Is that Dave? .
9 A VOICE: Dave.
10 MS. LUXTON: All right. I think I spoke 11 to you on the phone once at one time.
12 "In addition to the physical plant O- 1 13 design controls, a long-standing NRC concern at Unit 2 !
14 was the operating procedures do not reflect the FSAR 15 and an NRC open item has existed since 1993 to address 16 this concern. This inspection report closes the open-- i 17 the old open item not because adequate corrective
! 18 actions have been taken but because this concern is
- 19 being addressed and tracked by more recent items."
k :
l 20 Okay. Now, "This issue includes an O l
.. 21 evaluation of the procedure change process as well as '
i b g 22 the design control process to ensure future operation l 23 is conducted in accordance with the FSAR."
24 Now, it tells you to go -- okay. All !
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1 46 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 right. It was cited as a non -- it was a non-cited 1 2 violation and the concern is being tracked by an I 3 unresolved item. And it tells you to turn to Page U-4 2.2, U-2.2. Now, I turned to U-2.2 to clarify that and 5 I couldn't find U-2.2 for the life of me. Darn it.
6 Now I can't find it now, either. These things are 7 ridiculous. U-2.2.
8 But, anyway -- darn it. I can't find U-9 2.2. But why, if something has been existing since 10 1993 and there were not adequate corrective actions, g 11 why are you allowing that to continue as an unresolved 12 item? Do you know what I'm talking about, Dave?
13 MR. BEAULIEU: I suspected that --
14 MR. DURR: --
deal with that, too, when i
15 I read it. )
- 16. MS; LUXTON: Do you know where U-2.2 is?
17 MR. DURR: Well, I don't know where it I 18 is. It's in there somewhere. But the point is --
- 19 MS. LUXTON: I found it. .
20 MR. DURR: Good.
O
. 21 MS. LUXTON: U-2.02. No. That was U-1 22 Ah. Okay.
} 2.01. Now, this violation is from an l 23 inspection report dated 50.33.6 96-05 which concluded 1
24 that the violation could not be closed because, I
1
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47 g HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 although the adequate --
the specific procedures 2 regarding thermal backwashing were adequately l- 3 ' addressed, the corrective actions were too narrow in 4 that they failed to address the possibility that other 5 plant procedures did not ensure operation was in 6 accordance with the plant's design basis. All right?
7 Now, you would think that if it was !
8 already in an inspection report as a violation before !
j 9 and there are seven outstanding violations including 10 escalated enforcement items -- there's a couple more l E 11 here which address plant operation that's inconsistent
,R 12 with the licensed basis -- why is this violation which 13 I talked about on Unit 2 being closed? It says it's 14 being closed, "not because adequate corrective actions 15 have been taken, but because this concern is being l 16 addressed and tracked by more recent items."
17 MR. DURR: The specific issue -- that jI 18 specific issue was addressed a long time ago. The
- - 19 reason it was kept open is because there was a more j ir i 20 generic aspect to it broader than that. They fixed the l
!O ;
!< 21 specific problem. But we asked the question, "What l l$
lg 22 about this bigger picture?"
ll 23 Since the original issue, we found other 24 issues similar to that. And we're saying this one is POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
. - - . - .- - - . . - - .- ..-.- .. . .- .. - ._ - . ~
l 48 HEARING RE: MILLSTONE UNITS O ^>a L 3o. 1997 1 no longer ~ relevant. because that specific issue was 2 addressed and the generic aspect will be covered by_
3 these other issues. So we just closed this one because 4 it was addressed. But that generic piece of' it is 1
5 still open and other issues still track that.
l 6 MR. BEAULIEU: Correct. 'Ae want them to
- t. 7 review the entire FSAR to see if there are other i l-l 8 examples of operating procedures that don't reflect ;
i l 9 what the FSAR says. So this inspection item addressed l
! i 10 one particular. item. But we've got many other items !
R 11 that address other specific items. But the issue and -l 2 l l 12 why it stayed open is to address the broader issue.
13 And the broader issue is not only addressed by several e i
i 14 other violations and escalated items, it's also on our j 15 Significant Items List as a restart issue. So I l
16 suspected this would prompt questions. But the broader l 17 issue that we were concerned about is definitely being Ll 18 addressed by many other references.
! -l 19 MS. LUXTON: Okay. My third thing is j 20 the training again, getting back to training. Now, you
'O l
= 21 said that you were going to make sure that they knew
'l 22 what they were doing, that they were trained properly g
h 23 before they restarted. But I was looking at the 24 transcript of the meeting, the briefing between the NRC
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-HEARING RE: MILLSTONE UNITS APRIL 30, 1997
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1 and NU in Maryland on the 23rd, and I noticed that they 2 were talking- about -- Chairman Jackson was talking to 3 NU about the fidelity of the simulator.
4 Now, I need you to explain to me. The 5 simulator is when they simulate accident conditions or 6 whatever's happening in the control room. Correct?
7 MR. BEAULIEU: Correct. ,
8 MS. LUXTON: Now, the question I have is 9 and the question she had is until we know that the' 10 plant, the in-ground plant, matches the documentation -
{
R 11 -
is that what she means by the fidelity of the
'R 12 simulator? Because the simulator may not be true if 13 it's not coordinated to the hardware. Is the what I'm 14 -- do I have that correct?
15 MR. BEAULIEU: Correct. Right.
16 MS. LUXTON: All right. So how are we 17 going to be sure in the public that there's -- what do l l 18 they call it? -- there's fidelity of the simulator? ,
-l- 19 Because if there isn't fidelity of the simulator, it
)
i 20 doesn't matter whether they train on that simulator.
O
> < 21 Are you going to -- is that a restart item or, you know b
g 22 --
l 23 MR. DURR: I think what you'll find --
24 we talked about that today in the meeting.
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50 HEARING RE: MILLSTONE UNITS
) APRIL 30, 1997 1 MS. LUXTON: Oh.
2 MR. DURR: Mr. Gable explained the fact 3 that they've done an audit of the fidelity of ~ the 4 simulator. j l 5 .MS. LUXTON: Who does? QA?
6 MR. DURR: No. The oversight -- '
l 7 MS. LUXTON: Oversight?
8 MR. DURR: Oversight, QA. And what they 9 found was that there's reasonable fidelity.
l 10 MS. LUXTON: Did you check this out?
lR 11 Did you make sure?
lR 12 l
() 13 MR. DURR:
MS. LUXTON:
Did I?
Yes. Does --
i 14 MR. DURR: Not me personally, no.
15 MS. LUXTON: Does the NRC have the right 16 to check this --
l 17 MR. DURR: The NRC does look at --
ll 18 MR. LANNING: We do periodically as part i . 19 of our operator requalification activities that we look 20 at. We look at the training of the operators. And one 0 1
. 21 of the things we look at as part of that review is 0
g 22 whether or not the simulator is an accurate l 23 representation of the real plant --
l 24 MS. LUXTON: Good. Because we know that i
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HEARING RE: MILLSTONE UNITS l APRIL 30, 1997 l . (]) 1 1 they've had problems with QA in the past. It's been a-l 2 very poor program there. So I want you to make sure 3 that you check this new QA group on this particular l 4 issue. Did you write that down?
! 5 MR. BEAULIEU: It's in our mandate to 1
6 check --
7 MS. LUXTON: It is? Okay.
8 MR. BEAULIEU: Yes.
9 MS. LUXTON: Okay. On each unit?
l l 10 MR. BEAULIEU: Yes. That's a generic .
jR 11 procedure for restarting a unit.
! R 12 MS. LUXTON: Okay. Good.
l (2) 13 MR. BEAULIEU: So we're covered.
14 MS. LUXTON: Okay. Thank you.
15 .R. LANNING:
M Thanks for reading our 16 inspection report. That's good.
17 MS. LUXTON: I'm trying.
1 i
18 MR. LANNING: We appreciate it.
i
. 19- MS. LUXTON: I'm trying.
20 MR. LANNING: We appreciate it.
'O
. 21 Any other questions of the residents b
g 22 before we go off in another, new category?
l l- 23 MR. DON DELCORE: Don Delcore, Bristol, l
24 Connecticut. I really wasn't going to say anything l
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52 HEARING RE: MILLSTONE UNITS
) APRIL 30, 1997 1
1 tonight because it seems like any time I read reports 2 and make comments before the NRC or NEAC somebody is
! 3 attacking me, either Kenyon or Carnes or somebody or
! 4 some member of my family. So I'm rather hesitant about 5 getting up here and commenting.
6 But I'm rather disturbed at the fact 7 that there's a whole bunch of fuel modules in Unit 1 8 that aren't seated in their holders because it seems to 9 me when we move fuel, there's a checklist and the 10 checklist says that that module is seated. Is that not l
R 11 true?
E 12 MR. LANNING: Do we know?
l
() 13 MR. EASLICK: I don't know.
14 MR. LANNING: We don't know that.
l 15 MR. DELCORE: I would imagine that we
- 16 ought to go take a look at that, guys.
p 17 MR. LANNING: Common sense would say l
ll 18 that, though. Right?
- 19 MR. DELCORE: Yes. Common sense would 20 say that if we go through all the checks we go through, O
< 21 if you're moving a rod from the cooler to the spent g 22 fuel pool, there's a checklist to make sure it's in the
'l 23 right spot --
24 MR. LANNING: Right.
{
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l 53 HEARING RE: MILLSTONE UNITS T APRIL 30, 1997
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1 MR. DELCORE: -- and it's seated, l-
- 2 MR. LANNING
- That's right.
3 MR. DELCORE: I don't understand how all l 4 of these are found unseated if they'd been following 5 their procedures and why you guys haven't cited them 6 since you know all of those are sticking up above where
! 7 they're supposed to be. Now, that doesn't make any l l 8 sense to me. Maybe they got an uncited violation. )
1 9 Maybe that's what they got. !
10 MR. LANNING: I don't know.
R 11 MR. DURR: No. They got an unresolved 3 1
! 12 item, which means we're not finished with this whole
(:) 13 process. It means it's still going on. It says ,
1 14 there's a potential violation tnere. But it's much 15 bigger than just these things not being seated. So 1
16 we've carried it as unresolved right now, l 17 MR. DELCORE: But when things aren't l 18 seated and an operator is moving a fuel bundle and it 19 doesn't -- it's not sitting in there right, not only is 20 there an issue of cramming something up under there O
. 21 which may eventually be brought back in and either I
22 interfere with the flow process, create heat problems, g
l 23 interfere with the nuclear process, possibly do damage i
24 to other fuel modules because it becomes a loose part
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1 j 54
') HEARING RE: MILLSTONE UNITS
( APRIL 30, 1997 l 1 that's kicking around with high flow rates, so many 2 things, it doesn't make any sense that we have a senior 3 license up there overseeing the movement of fuel and 4 somebody isn't making sure that that fuel is seated 5 properly.
6 Then you look at it from a seismic issue 7 because that has to be a seismic issue, also. Those 8 spent fuel pool racks are designed to have the fuel all 9 the way at the bottom seated. And so there's a seismic 10 issue right now.
E 11 MR. EASLICK: Absolutely.
R 12 MR. DURR: We've already discussed that l 13 with them. You're hitting on all the things we've 14 discussed with them. Yes.
15 MR. EASLICK: Including criticality )
16 margin --
l 17 MR. DELCORE: Sure. Kay effective,
, I 18 whatever else is involved.
I
- 19 MR. EASLICK
- -- inspection of the top i
e 20 rod itself on the fuel, on the rack. All these things Lo. 21 are all out there, are to be considered. You're I
g 22 absolutely right.
l 23 MR. DELCORE: Okay. I didn't really get 24 an answer as to why they're going to be allowed to wait l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
5 55 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
(])
1 until refuel 16. I don't think you guys really ever
] 2 answered that. You talked, you danced around it about l0 3 the debris being able to stay on the bottom underneath 4 the racks. But why aren't you making them clean it up?
5 I don't understand that. I mean if it's a violation 6 for it to be there, why isn't somebody there taking it b 7 out right now, three shifts? That's my question.
8 MR. ART BURRITT: I think the biggest 9 problem with doing something like that is you stand a 10 large chance of starting up things in the spent fuel g 11 pool and --
e 12 MS. LUXTON: They've got filters. They 13 got filters.
14 MR. DURR: No, no, no. It's not that 15 simple. You get it in -- see, what we don't want is if 16 they haven't already, we don't want to get that stuff 17 in the fuel. You just absolutely do not want any of
! 18 that in --
l: 19 MR. DELCORE: Mr. Durr, I'm not really lr 20 comfortable that that stuff isn't in the fuel already.
O
- 21 MR. DURR: Well, it's been there --
I g 22 let's put it this way. It's been there for years.
l 23 MR. DELCORE: Yes.
24 MR. DURR: And they've operated for O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
56 i HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 years without a problem. So the likelihood of it ,
2 having been just put in a fuel simply is fairly low 3 because we haven't had a lot of failed fuel from hot 4 spots and that sort of thing.
5 So if you go in there and you make them 6 clean it up now and stir up all the stuff, I don't want 7 that in --
8 MR. DELCORE: You mean that's not going 9 to settle before Unit 1 gets started back up?
i 10 MR. DURR: It's not going to settle 2 11 where?
12 MR. DELCORE: Right back where it came 13 from.
14 MR. DURR: I'm not --
15 MR. LANNING: But you run the risk of 16 spreading it elsewhere and inte the fuel assemblies.
17 That's the primary consideration here. They doctor the
! 18 spent fuel assemblies prior to putting them back in the 19 core.
20 MR. DELCORE: Okay. And that's the next O
. 21 question it leads me to. I still haven't heard a good g 22 answer about how we're going to verify that the camera ;
l 23 --
if the camera's unable to see 100 percent of the l
24 bottom of the fuel area where it sits in the bundle, j l
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1 57 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
(]) j 1 evidently something's in the way of the camera getting 2 there. And I'm not familiar with that particular 3 operation. So is there something that you guys are 4 going to require so that we see 100 percent of the 5 fuel? !
6 MR. LANNING: It's a good question and 7 we ought to address it as part of the inspection 8 process. I don't think we have a good answer to that.
9 Right?
10 MR. DURR: Well, they have finalized the 11 inspection process yet. All we've gotten from them so 12 far, we had a meeting with them and we said, "Look.
13 This bothers us big time." And so they brought their 14 engineers in because we've been finding -- see, the 15 reason we had the meeting -- I i
16 MR. DELCORE: Jacque, I'm not really -- )
l 17 I'm not really comfortable with the feeling that it l l
l 18 bothers you guys big time. j
- i. 19 MR. DURR: Well, we're giving you an 20 answer.
O
. 21 MR. DELCORE: I really don't. From what
_g 22 I've heard here tonight and what I've read in the l 23 report, I'm not real concerned that anybody's really 24 heavily concerned about this issue.
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58 i HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 MR. DURR: Well, that's the reason why 2 we wrote it in -- and I can't do much for your comfort 3 level.
4 MR. DELCORE: Okay.
5 MR. DURR: I'm not going to try to do 6 anything for your comfort level. All I can tell you is 7 the facts as they exist today. And the facts are that 8 it's been identified as a major issue. It's a line 9 item in the Significant Items List. The utilities made 10 commitments to us which we fed back to them in the
(
R 11 inspection report cover letter that we look at these as lE
- gg 12 commitments and we expect them to be done before they ,
1 \J 13 load that fuel back in the reactor. .
14 MR. DELCORE: Okay. So we're going to 15 look at every module that's going back into the core, ,
16 every fuel bundle?
17 MR. DURR: Northeast Utilities is, yes. ,
l
! 18 MR. DELCORE: And somebody's going to {
- 19 oversee that?
20 MR. DURR: I certainly hope so.
O
. 21 MR. DELCORE: No. I mean somebody from ,
i g 22 your organization.
l 23 MR. DURR: We certainly are going to be
)
! 24 involved in that. Yes.
l 4
1 -
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59 HEARING RE: MILLSTONE UNITS
(")i APRIL 30, 1997 m
1 MR. DELCORE: I mean that would give me 2 a little bit better feeling. You guys haven't been the 3 most credible in the world, but --
4 MR. DURR: These gentlemen right here 5 are the key identifiers of all this stuff. And that's 6 why we brought them here tonight is because they are 7 intimately involved in this process.
8 MR. DELCORE: All right. Now, so now we 9 have these bundles that are going back to be reused and 10 they're all going to be inspected before they're put in 11 there. Right? And we know which bundles those are.
12 MR. DURR: Yes.
r-)s k.
13 MR. DELCORE: And we also know what the 14 new bundles are. So why do we care about the spent --
15 the rest of the spent fuel modules with regard to 16 cleanup of the spent fuel pool?
17 MR. DURR: Why do we --
I 18 MR. DELCORE: They're going to sit there
- 19 anyway. They're going to sit there forever and ever i
e 20 and ever until they go to YACA or until they go to dry l 0
< 21 cad storage.
k g 22 MR. DURR: Well, RFO-16 they're going l 23 to put fuel back in the spent fuel pool.
24 MR. DELCORE: Right.
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l 60 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 MR. DURR: And I want it clean before 2 they do that.
3 MR. DELCORE: No. I understand that.
4 But I'm saying why can't they clean it now? Them i
5 modules aren't going to move anyway.
6 MR. DURR: Because I don't want it to 7 end up in the fuel assemblies that are going back in j l
8 the reactor.
9 MR DELCORE: Okay.
10 MR. DURR: And I don't think they do,
- R 11 either.
12 MR. DELCORE: All right. You win.
13 MR. LANNING: Rosemary? Let's let 14 Rosemary talk. She hasn't had a chance.
15 MR. REYNOLDS: (Inaudible - not ut3ing <
p 16 microphone) H l
i 17 MR. LANNING: Wait h minute. Wait, Mr. I l
l 18 Reynolds. Wait just a minute. I l; 1S MR. REYNOLDS: He said it was operated l
ir 23 safely --
.o
< 21 MR. LANNING: Wait just a minute.
b g 22 MR. REYNOLDS: -- spent fuel pool.
t 23 MR. LANNING: Bear with us now.
24 MR. DURR: I never said it was operated
(:)
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L 61 HFARING RE: MILLSTONE UNITS
({} APRIL 30, 1997 ,
1 safely.
l 2 MR. LANNING: Rosemary?
3 MR. REYNOLDS: Look at the transcript.
4 MS. ROSEMARY BASSILAKIS: Still on the 5 fuel pool. What would happen if there was a seismic 6 event at this point in time?
7 MR. IMBRO: Probably not much.
! 8 MR. BURRITT: It was analyzed by the 1
9 licensee. They looked at having these bundles raised 10 where they wouldn't cause a problem.
E 11 MS. BASS 1LAKIS: And did the NRC review R
12 the analysis that the utility did?
! 13 MR. BURRITT: We did not review in
(
- 14 detail that analysis. We did look at the analysis. We i
15 know it exists. ,
i 16 MS. BASSILAKIS: Because should it pose 1 l
17 a serious risk should there be a seismic event, then
! 18 why not just make them buy new fuel and fix it now or,
- 19 you know -- that's all. Why isn't that a thought? Why 20 do they have to keep that fuel pristine and jeopardize o
. 21 not fixing an old problem when they could just get new b
g 22 fuel?
.h 23 MR. BURRITT: Regardless of whether they
- 24 bought new fuel or not, you still want to have the 1
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l 62 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 existing fuel in the spent fuel pool seated, fully 2 seated.
3 MS. BASSILAKIS: But it doesn't have to 4 go in until it's going to be transferred.
5 MR. BURRITT: Correct. Most of the 6 bundles that are not fully seated are not bundles that 7 will be reloaded.
8 MS. BASSILAKIS: Oh. No. I know that.
9 No. I understand that. But the issue is that you're 10 not making them fix this because you're concerned about 11 the fuel that's going back into the core. So what I'm gg 12 saying to you is why not just rely on getting new fuel? ,
v 13 Fix it now. And if you're concerned about the fuel 14 that's going back in getting contaminated in some way 15 with debris, then they just get new fuel.
16 MR. LANNING: One reason that the --
17 that's of concern because the fuel assembly is not
! 18 fully seated in the rack, it sticks up above the 1 19 Okay? And
- others. if they're moving other fuel or ir 20 other objects above this rack, they run the risk of O
. 21 hitting that fuel assembly that's protruding above the g 22 others and they run the risk of damaging whatever l 23 you're moving plus the spent fuel assembly pool.
24 MS. BASSILAKIS: And what would you be POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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63 HEARING RE: MILLSTONE UNITS
'(]) APRIL 30, 1997 1 moving? I guess I don't understand why you're telling 2 me that.
3 MR. LANNING: Well, they move -- they I 4 move fuel across the pool. They move heavy loads.
5 They move all kinds of things, filters. And so one 6 consideration is you don't want to be hitting anything.
l 7 in the pool. Okay? And that just creates the
)
8 possibility you could. That has nothing to do with 9 buying new fuel.
10 MS. BASSILAKIS: Well, I'm -- then to me l
E 11 that means, well, then you should fix it.
R 12 MR. DURR: Rosemary, let --
tO 13 MS. BASSILAKIS: I don't --
14 MR. DURR: Let's --
let me )
15 recharacterize what you said. We are making them do l 16 comething. It's not like we're not going to make them !
l ,
j 17 do nothing. We're making them do the things that make l l 18 sense first; inspect the reactor, make sure there isn't I
19 any debris in the reactor, foreign material, inspect l 20 the fuel that's going back in the reactor. And we know
- o-l . 21 everything now that's going to be under power is clean.
0 g 22 And we have reasonable assurance that that stuff is
- l 23 safe.
24 Now, once they close off the reactor and d O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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t 64 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 i 1 seal- all that off, now you can get in 'here and play .
t 2 around in the pool. You stir up all this stuff. It's 3 not bcing transported.
I'm concerned about transport t
4 to all other areas of the reactor. The spent fuel pool ;
5 cooling system ~ is running now. They are running.
l 6 shutdown cooling which gets the likelihood of this 7 debris to end up in the pipes, in the pumps, in the 8 barrel. I don't want it all over the plant. We want i l
9 to confine it where it is. Once you've got the reactor 10 sealed off from it and the gates are in, now the pool ,
R 11 is by itself and it's not connected to the reactor any i 12 more. And if you clean it up now, it's no big deal.
13 And they could do that during the next operating cycle r
14 without endangering all this other stuff. ;
15 MS. BASSILAKIS: Thank you. That i 16 explains it better to me. j 17 MR. DURR: Okay. ;
18 MS. BASSILAKIS: But there is an issue i 19 that we don't know when refueling will be. So we don't
]
Ir 20 know how long this will be an open item. And I guess
-O l
i
. 21 my next question is what if Millstone 1 doesn't survive g 22 its economic analysis and will never start up? Will
.l 23 you continue increased scrutiny on that plant or will 24 it leave the watch list? I'm just curious on how 1O l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 I
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i 65 I HEARING RE: MILLSTONE UNITS t
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1 you're going to follow through should that plant never l
2 restart.
3 MR. LANNING: You're asking us to 4 speculate on something that's -- you know, we can't l 5 predict. But, you know, at the right time -- if it i i
6 comes down to that, you know, we'll be talking about i
i 1
7 that.
8 DR. BILL TRAVERS: But the bottom line 9 on even a decision, if it were made, to decommission 1
10 that facility, regulatory oversight continues. There R 11 will be a number of issues that will need to be 8
-w 12 addressed in the direction of decommissioning likely U 13 more so than operation. And this is one that I'm sure 14 would continue to be an issue that we would follow and 15 expect resolution.
16 MS. BASSILAKIS: Thanks.
17 MR. LANNING: All right. Any other
! 18 questions for the residents? We need to move on to the h
- 19 next topic. Okay? All right.
20 DR. TRAVERS: I'm Bill Travers and I'm o
. 21 the Director of the Special Projects Office. And I g 22 thought it might be useful at this time, since we just l 23 had a very recent meeting with the Commissioners last 24 Wednesday, actually, to give you a very brief summary O
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l 66 l- HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 l 1 and perhaps allow you, if you wish, to ask some 2 questions about that meeting. i 3 As background, the Commission asked for 1
4 a status briefing from both Northeast and from the NRC 5 staff on a frequency of about every three months. And l
6 so last Wednesday's meeting was the second of those 7 quarterly status briefings.
8 I brought with me -- and I think there 9 are about only 25 or so copies of the slides, at least 10 that I used at that briefing, available in the back. l E 11 But the way the meetings are set up 12 typically, at least, is that Northeast will go to the 13 table before the Commissioners and present a status l 14 briefing. Following that portion of the meeting, 15 Northeast's representatives will leave the table and 16 the NRC staff will go and sit down at the table with 17 the Commissioners and provide an assessment from our l
. I I 18 own perspective of the situation at Millstone and our i i 19 own planning for completing and implementing our lr 20 regulatory oversight program. l 0
= 21 At last Wednesday's meeting, Northeast's I
22 presentation included a very -- well, it included a l
h 23 number of items concerning their view of the status of 24 their recovery efforts at the three units.
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67 HEARING RE: MILLSTONE UNITS
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l 1 I don't intend to try to go over i
2 everything that was presented by Northeast. But I will 3 tell you -- and you may have read in the papers -- that l
4 the Commission was interested in a level of detail that 5 at least at that meeting was not provided. And so the 6 Commission gave a strong indication to Northeast that i 7 for the next meeting and probably even before then, I 8 think within 30 days or so, they're hoping to get some i 1
9 supplemental information direct to the Commissioners 1 10 themselves, not just the staff, but the Commissioners l E 11 of the kinds of information that would provide the 8
1 rm 12 Commission with a much more detailed view of the 1 U
13 progress, at least NU's view of its own progress in 14 establishing restart readiness for the three units. l 15 Typically after those meetings, the 16 Commission will issue a requirements memorandum which 17 is most generally directed to the NRC staff. But even f 18 at that meeting, they requested NU to be ready at the
- 19 next meeting to provide a great deal or at least a h 20 r significantly type of different meeting in terms of the o
< 21' level of detail that would be provided. And Northeast i
g 22 agreed to do that. So from every indication I have, l 23 they're planning to respond to the Commission request 24 for a meeting that will involve a much greater level of l O l
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l 68 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 i 1 detail in their presentation. I 2 For our part, the NRC staff gave an 3 assessment of the status of activities at Millstone, 4 largely focused on our activities. I provided an 5 indication of some of the positive things we were 6 seeir.g at Northeast Utilities in terms of programs that l
7 were at least being initiated, if not programs that we 8 had a substantial and significant opportunity to 9 evaluate at this point.
10 So I gave an indication of much of the R 11 activity that we have seen ongoing in the area of R
12 procedure upgrades, corrective actions, a whole host of 13 programmatic areas, quality assurance and so forth, 14 where the utility is taking a number of cctions to 15 augment their program.
16 But I indicated that it's early yet and 17 we really haven't had an opportunity to see a lot of
! 18 the output that we will eventually have to witness and
- 19 assess prior to any consideration for restart of any of j ir 20 the three units.
O !
< 21 I gave the Commission an assessment of b
l g 22 our own NRC Restart Assessment Plan. You may recall l 23 that as of a few months ago we had issued one Restart 24 Assessment Plan for Unit 3. Since that time and prior POST REPORTING SERVICE
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t 69 ;
HEARING RE: MILLSTONE UNITS 1
(]) APRIL 30, 1997 i i i 1 to the meeting with the Commission, we've issued '
2 Restart Assessment Plans for both Units 1 and 2. And I 3 gave the Commission an indication of some of the issues l ,
j 4 that are contained in those Restart Assessment Plans 1
i 5 for Units 1 and 2. l i
6 I gave the Commission a status report on 1
7 the efforts from NRC planning at least for the conduct '
8 of the Independent Corrective Action Verification 9 Program. Rather than go over that at this point, I 10 know later in the meeting that Gene Imbro is going to l
' E$
, 11 talk to you about the status of our activities in that )
l l 12 regard.
- O 13 I also gave the Commission a short 14 summary of the status of our activities related to 15 assessing Employee Safety Concerns Programs at 16 Northeast. And we talked a little bit about the status 17 of efforts to put into place a third-party oversight l 18 team required by NRC order to audit the effectiveness I 19 of Northeast's program.
i lr 20 I also discussed for the Commission a 4
l 0
. 21 rack-up of a number of licensing issues that we are I b g 22 aware of or -- either aware of or have under review for l 23 each of the three units. And I indicated that the l
24 number of licensing issues that are identified late in
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70 HEARING RE: MILLSTONE UNITS
[
APRIL 30, 1997
! 1 the process have a potential for delaying the schedule 2 for restart. We're not anticipating that that's going 3 to be the case, but we wanted to give an indication 4 that if the need for licensing actions are identified 5 by NU late in the process, they could result in some 6 delay in their hoped-for schedule. And that's largely 7 because of the very public process and the evaluation 8 time that we go through in assessing requests for 9 license amendments.
10 The last thing I covered for the 11 Commission was a description of our own project 12 planning schedule for Unit 3. We have -- and it's in 13 that package of slides -- developed for our purpose a 14 project planning schedule that lays out our best view 15 of what is likely to be achieved at Unit 3 given the 16 regulatory activities that need to take place between 17 now and the time the NRC staff goes before the l 18 Commission with a restart recommendation.
l
- 19 And as it stands now, our project 20 planning schedule indicates the possibility at least of o
. 21 a Commission briefing in December of '97 wherein all of ,
$ i g 22 the activities that we've been talking about at our 1 s
l 23 meetings in public have taken place successfully.
24 That's an assumption that I won't make now. But we l
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71 HEARING RE: MILLSTONE UNITS
(} APRIL 30, 1997 ,
1 have to plan. .And largely, and certainly the principal 2 focus of our planning is to be able to schedule our L 3 resources. Schedules are important, but they're not 4 our fundamental objective. Our fundamental objective 5 is tied, in fact, to the successful outcome of the 6 licensee's program and our verification of the 7 successful outcome of those programs.
8 But reality necessitates our planning to 9 carry out our regulatory program. And that's why we 10 put this thing together.
R 11 I'll point out that in some -- well, in R
12 the most significant measure, our project planning 13 schedule is dependent on two fundamental factors. E.nu 14 those are Northeast's own ability to complete programs !
15 that it has scheduled and, perhaps even more 16 fundamentally, the quality that is assessed, our 17 ability to verify that, in fact, they've successfully
! 18 completed programs like licensing basis, design basis,
- 19 reconstitution, that they've successfully resolved the I ir 20 items on the Significant Items List and our Restart O
, . 21 Assessment Plan, that all of the icsues we've been b
g 22 talking about, whether it be operator license and ;
l 23 training or you name it, quality assurance, corrective l
- 24 actions and so forth, have been addressed successfully.
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72 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 V(~T 1 So while we've got a schedule and while 2 it indicates the possibility of the staff going before 3 the Commission this December, it's tied fundamentally 4 to the completion by the licensee of its programs for 5 resolving issues and, secondly and even more 6 importantly, on the success of those programs as we are 7 able to verify that success.
8 And I would be glad at this point in the 9 program to take any questions you might have about 10 that.
2 11 Mr. Delcore?
12 MR. DELCORE: This is an old question.
Jg-13 With regard to the verification of the different 14 programs as we go along, one of the upcoming issues, 15 obviously, is ICAVP. I have still yet to see any 16 criteria in terms of what is acceptable and what is not 17 acceptable and what will influence or create an l 18 increase in the scope of the ICAVP. There is no I
- 19 definitive areas that describe, at least to my 20 knowledge, how many mistakes are acceptable and what o
. 21 those mistakes can be before they either fail or create k
g 22 an increase in the scope of the ICAVP.
5 l 23 DR. TRAVERS: Well, we --
24 MR. DELCORE: We've been asking for it POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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73 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 for a long time, but we haven't seen it.
2 DR. TRAVERS: When you and I last talked 3 about this, I indicated -- and it's still the case -- l 1
4 that we discuss specifically what we felt the criteria 5 for success of conduct of the ICAVP is. And that is 6 that the ICAVP would verify if it is successfully or, 7 rather, if the licensee's program has been successful, 8 that they are in compliance with their licensing and 9 design bases. And we gave some specific language to l
10 what a-defect might be in that sense and we pointed out g 11 that a significant defect in our findings would be 12 something like an unresolved safety ' question being
)
13 identified in the context of its definition in 50.59 of 14 our regulations.
15 But we also pointed out --
and I think 16 what you're driving at is -- that at this point in our i 17 planning for evaluating the results of the ICAVP, we
! 11 8 don't have a fixed, I'll call it automatic, criteria
' I
- 19 for expansion of scope or perhaps even the pullback and 20 cancellation for a time of our ICAVP effort.
, o l
<- 21 Rather, what we've said and what we plan 0
22 to do is to evaluate any and all findings that arise in l
l 23 the conduct of the ICAVP to make a judgment on the l 24 number and significance of those findings.
}
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I l-74 HEARING RE: MILLSTONE UNITS
-(]) APRIL 30, 1997 1 I'll give you an example. If we found a 2 very significant issue that-raised an unresolved safety 3 question, we might expand the scope. We might even '
4 pull back and say, "You're not ready." We might do the 5 same thing for lots and lots of little findings with 6 not very much-safety significance.
7 But we don't typically set up our 8 inspection program with automatic triggers for "If this 9 happens, da that. If that happens, do this." So what 10 we intend to do and what we think is the right thing to R 11 do is to evaluate the findings, assess the significance R
12 of any findings that arise and make judgments.
)
13 And, importantly, the other thing I 14 pointed out to you was that as we go along in the 15 process, we expect there's going to be a lot of 16 opportunity to come before you in a forum like this, 17 perhaps in quick-look reports that we might issue, to .
! 18 give you an indication of what our findings or what the h 19 third-party contractors' findings are or our own i
!r 20 findings are so that you can have in real time an O
= 21 understanding of what's coming up.
.1 22 MR. DELCORE: Well, with due respect to l
l 23 you, the reason why we're here looking at all of this 24 right now is because your organization harn't done its
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i 75 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 job. And so I don't have a whole lot of comfort level i
l 2 in the subjective evaluations that you've depicted.
3 I think there needs to be some very l 4 clear, definitive lines as to what's acceptable and 5 what is not acceptable so that the public can get a 6 credible view of what Sargent & Lundy in the case of l 7 Unit 3 is finding and whether we feel it's significant 8 or insignificant.
9 DR. TRAVERS: You'll be given an 10 opportunity-to make the judgment. What-we have laid l E 11 out and what we expect is to go in and look to see if 3
12 they have in their own program been able to adequately
)
13 confirm the design licensing basis. That's what we l 14 expect. And if we don't get that, we're going to 15 report it to you here and we're going to assess the. i 16 significance of it. }
17 MR DELCORE: Yes. But that's what's !
! 18 giving me heartburn is you're assessing it. You've I: 19 been assessing the significance of a pervasive problem f lr 20 that's taken place at three units. Not you O l
<- 21 particularly, but the NRC has been doing it for many, 1-g 22 many years and accepting carte blanche a statement from l 23 NU saying "It's okay. And if it isn't okay, we're l
24 going to commit to this program and we're going to fiv l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
! l 76 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
(])
l 1 it." And now you're asking me as a member of the l
l 2 public to accept that you're going to be able to i 3 objectively look at something and say, "Oh, yeah.
4 We'll be able to make a credible decision for the l
5 public that it's okay to continue on and we don't need 6 to increase the scope of this" or "We need to puli j 7 away." We don't have a warm feeling because we don't O 8 have any criteria.
9 DR. TRAVERS: Well --
10 MR. DELCORE: And it doesn't seem that E 11 difficult for you to lay it out. That's the problem we R -
, 12 have. {
13 DR. TRAVERS: Well, I guess we'll
-14 disagree on it. But what I intend to do is make 15 everything that either the ICAVP contractor identifies 16 or we identify available so that you can assess whether 17 you think we're doing the right thing or not.
.! 18 MR. DELCORE: So we're going to get I 19 their reports or we're going to get some regurgitation 20 of their report?
O
= 21 DR. TRAVERS: They'll be reported to the t i 22 public.
g l 23 MR. IMBRO: No. The findings will be 24 put on the bulletin board. It will be on the Internet.
i l
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t-77 A L3 l
1 DR. TRAVERS: Our findings and the ICAVP 2 findings will be public.
3 MR. DELCORE: So really the only thing i i 4 we're missing is some criteria. 1 5 DR. TRAVERS: The only thing you're 6 missing is something that I'm -- that we typically do 7 not do. And that --
8 MR. DELCORE: But we know that. But, 9 see, look at the problems that we're dealing with at 10 Millstone because you typically don't do that.
i! 11 DR. TRAVERS: But that's just not 12 correct.
13 MR. DELCORE: Yes, it is correct. It's .
14 absolutely correct, Bill. There's no question in my 15 mind about it, i
16 DR. TRAVERS: Well --
17 MR. DELCORE: We've been talking about I 18 it all night here in the inspection report. Same l 1 19 stuff. You The licensee
- allow it to happen. tells !
20 you, "We're going to take care of it." They don't take O i
- 21 care of it and it continues cn. And the problems have ,
g 22 been on and on and on and on for years. And I don't l
! 23 have a real high comfort level at what I'm seeing here.
24 I'm not comfortable with it.
'O l
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l 78 HEARING RE: MILLSTONE UNITS
-( ) APRIL 30, 1997 l 1 There's 86 or 88 systems or 83 systems, !
2 depending on who you talk to, that are systems that in ;
3 part either safety-related, risk-significant or a 4 combination of both and then some others thrown in that ,
5 have some significance anyway. And I've heard three 6 different numbers. We're going to look at five of 7 them. Four by Sargent & Lundy and two by you guys, but 8 one of the four of Sargent & Lundy's is going to be one 9 that -- one that the NRC is going to look at is one .
10 that Sargent & Lundy is looking at. So we're looking ;
g 11 at five systems out of 85 or 86 or 88. That's not a 12 whole lot to start with when you look at the pervasive ,
13 problem that's going on at Millstone for as long as it t i
14 has. We're talking about people being outside their !
15 license requirements since they were built.
16 DR. TRAVERS: Well, we disagree. I 17 think what we are putting into place --
! 18 MR. DELCORE: But I am the public and 1
19 supposedly Shirley came here and said, "We want you to 20 be satisfied. We want you to have trust back in our O.
< 21 organization." And I don't have any trust in your g 22 organization because of the way you are doing the ;
l 23 investigations and inspections. You're not providing a 24 bottom line that says "If you don't do this, then we're
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79 HEARING RE: MILLSTONE UNITS L () APRIL 30, 1997
! 1 going to do this." We haven't seen it. I've been ;
l 2 asking for it almost every ICAVP meeting. And you have 3 absolutely just ignored it.
} 4 DR. TRAVERS: No , I haven't ignored it.
5 I've just disagreed with you. What we have said -- and 6 I'll say it again -- is that to try in the kind of complicated review that we're talking about, to suggest i
7 8 that if we find "X", three X's and four Y's, that we're l 9 going to do this is something that's almost absurd. I i
10 mean it really doesn't give you an opportunity to j 11 assess what it is you're talking about.
12 The kinds of findings, frankly, that can 13 occur in this kind of very detailed technical review, 14 very substantially -- they -- I'll give you an example.
l l 15 They could range from an error in a calculation that in 16 the end sum again doesn't cause any effect on the 3
17 operation of the system.
! 18 MR. DELCORE: It may or may not, t 1 19 depending on what the calculation --
20 DR. TRAVERS: But that's a finding. And O
- 21 it's the kind of finding that we need to assess for its I
g 22 safety significance. We need to understand it.
h 23 On the other hand, the same kind of 24 problem of calculational error might be very ,
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I 80 HEARING RE: MILLSTONE UNITS
(])' APRIL 30, 1997 l
l 1 significant to the operation of a safety-significant 2 system 'that's required to mitigate the consequences of l
3 an accident. I want to, in the face of those kinds of ;
4 findings, be able to look at them, report here what '
5 they are and make a judgment as to what we think we l 6 should do about it.
7 MR. DELCORE: But the technical ability 8 of those people behind us right now is that they aren't i
9 able to discern that. And so they again have to accept 10 what they've been accepting for years and years and g 11 years. And all I'm saying is you need to come up with 12 a definitive criteria so then they understand, even 13 though it's a paperwork issue or even though it's a 14 configuration management problem in the way they 15 developed the management itself or one of the 16 attributes that they looked at or a typographical error 17 in the FSAR, then they understand that you said, "Well,
! 18 we're going to allow five of these or three of those or 19 ten of these." But right now they don't know that and lr 20 they can't weigh --
you know, I've been making O
= '21 complaints to the NRC for ten years and you guys have '
- l. '
g 22 been telling me none of them are safety-significant.
l 23 DR. TRAVERS: But that's why we --
24 that's why we intend and will come back and explain it.
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81 HEARING RE: MILLSTONE UNITS APRIL 30, 1997-1 That's where we're at.
2 MR. DELCORE: Thanks, Bill.
3 MR. MARKOWITZ: I'd like to ask Don's 4 question just a little bit differently. And that's ,
5 accepting the process that you just outlined as to. the 6 way you're going to do business and evaluate 7 incrementally the findings or the results of the third-8 party contractor, how do you answer the question, What 9 are you going to do if, after you've explained your 10 evaluation of the findings and Don or Susan or maybe g 11 NEAC disagree with the conclusions you draw? In other 12 words, if you conclude- that the findings are 13 insignificant or not of the quality that would put the 14 plant in a situation where the process shouldn't 15 continue but, in the absence of that criteria that 16 Don's looking for, we conclude otherwise That's the 17 box we sort of winded into it with this little "i", big I 18 "I" process. How do you explain -- you' re still going 1
19 to do it, I guess.
20 DR. TRAVERS: Well, I've got to just
-O
< 21 point out one thing so we don't lose sight of it. We g 22 have established a criteria in the Commission paper and b 23 in our discussions and planning for ICAVP. And it's i 1
24 that the NU process is successful in not putting the l
j.
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82 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 ICAVP team in a. position of finding deviations from 2 licensing basis, design basis. That's the criteria.
3 But there can be degrees of significance associated 4 with the findings that result in that. So that's 5 number one.
6 But in terms of process, when we 7 identify issues that have some degree of significance 8 against licensing basis, design basis, we're going to 9 assess significance. We're going to discuss them here 10 in the forum. We're going to discuss them with the 2 11 Commission, I imagine. And we have -- I have an K
(3 12 expectation that the Commission will be interestedsin
%)
13 NEAC and public views on their view of what we've done 14 in this program and whether or not in accepting 15 comments whether we've acted properly in assessing the 16- significance of the comments versus our own view of 17 where ICAVP or any of these issues are at any point in
! 18 time. In fact, the Commission has indicated that 19 that's the case.
ir 20 MR. MARKOWITZ: I understand your O
< 21 answer. And the concern that I still have is that i
j 22 there's that one line on the restart plan on your b 23 checklist that has the public comfort, if we will, with :
I 24 the restart process and I think the corrective action '
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83 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 verification process was kind of in there building that 2 comfort and you and I disagreed. with that 3 philosophically. But I think now we're walking down 4 the path of having to address if the public -- and I'm 5 not saying that NEAC will or won't. I think we're 6 going to be in a position to observe perhaps more than 7 some of the other public folks if we're funded.
8 But given that there could be an honest 9 disagreement and we could see things differently and 10 Don and Susan and CRC could see things differently, I
[e 11 think what's going to happen is the process is going.to i
12 continue and Don's not going to be happy -- and I'm not 13 predicting the future. But I'm saying that's kind of p 14 the way this thing plays out in the absence of some 15 other. mechanism. And I don't know how to get out of 16 the box we're in. I'm just making that a statement. I 17 understand.
I 18 MR. LANNING: Susan?
I
- 19 MS. LUXTON: Susan Perry Luxton, 20 Citizens Regulatory Commission. Guess what? I have o
. 21 the resolution to the problem.
I g 22 MR. LANNING: Good.
l 23 MS. LUXTON: No. I'm serious on this.
24 The resolution to the problem is we need -- we, the O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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i 84 l HEARING RE: MILLSTONE UNITS
(]} APRIL 30, 1997 1 citizens group, need the raw data. Do you understand i l
2 what I mean? The findings. We need the walk-down :
3 findings, the raw data. When they give it to you, they 4' give it to us. That way --
5 MR. CERNE: They will.
6 MS. LUXTON: That way we can assess it 7 and be the -- what do you call it? We'll be the check 8 and balances on you. Even though you say it's complex, 9 I think with the contacts that we have in the
! 10 community, nuclear people, we will be able to do an 3 11
- assessment of our own. How does that sound to you? '
l l 12 DR. TRAVERS: We want to make those !
(~)s
\_ l 13 findings available and we will. i 14 MS. LUXTON: Raw data.
15 DR. TRAVERS: That's the intent.
16 MS. LUXTON: Raw data. I mean raw data.
i 17 DR. TRAVERS: I'm not sure exactly what '
I 18 you mean.
I 19 MS. LUXTON: Well, I'll explain that.
20 Raw data does not mean summaries of findings. That O
< 21 mean at the beginning when they go in there and flesh I.I 22 out and check out if the, you know, plant and the ig
,l 23 ground matches the paper, when they go in and do their
- j. 24 walk-downs and everything, that's when we want the raw 4
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' 85 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 l
1 data, as-built condition of the plant to check with the 2 drawings and stuff. Do you understand what I mean?
l 3 Not after the fact. Not summaries. Raw data.
4 I know it's a lot of work, but I have a 5 lot of boxes. I can file it at home. I know there's a 6 lot of paperwork. But then we will have oer own prsople 7 do our own assessments. That's the only way we can be 8 assured in the public that -- you know, our comfort 9 level will be okay. We'll make our own conclusions.
10 Then we'll be able to have, you know, data to show you, 2 11 our own conclusions. And then you'll -- it will be R
gS 12 more credible what we say to you. It won't be just v
13 sitting here and you coming up with your assumption and 14 then we say, "We don't -- we're not comfortable with l i
15 that" and you saying, "Thank you very much." We'll i 16 have looked at the data. We'll have our own engineers.
17 And we've got them. We can do it. What do you say, I 18 Dr. Travers?
I 19 DR. TRAVERS: Well, maybe we need to I 20 talk to you about the level of information that we're
, O i - 21 talking about because what we have planned right now g 22 are to make all of the reports and the ICAVP contractor l 23 available publicly to make our inspection reports 24 available publicly. But there is warehouses almost of O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
86 HEARING RE: MILLSTONE UNITS
(' ]) APRIL 30, 1997 1 information that are part of the mix. And what needs 2 to be evaluated first by the licensee and secondly on 3 selected systems by the ICAVP contractor and thirdly on 4 the two or so systems that we're going to do that goes 5 well beyond what we have expected to put on the docket.
6 MS. LUXTON: Okmf. No. You're not 7 putting it on the docket, though. You're giving it to 8 us. I don't know about the docket.
9 DR. TRAVERS: That --
1
! 10 MS. LUXTON: That has happened before in 11 other ICAVP's. There has been other verification 12 programs at other plants in the country. I've been
{)
i 13 talking to citizens groups around the country. The l
14 precedent has been set. Other citizens groups have 15 gotten the raw data and have themselves done their own 16 verification of Sargent & Lundy's verification. And 17 all I'm asking from you is I want to have -- we want to
! 18 have the same opportunity, we deserve the same ;
I-19 opportunity, as stakeholders in the community to do ir 20 just what they did at other plants.
O a 21 DR. TRAVERS: I'm not sure exactly what l
- g 22 you're referring to. But maybe if you could find out
'b 23 some more, it would help me understand a little bit 24 better, you know, about exactly what level of
)
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87 HEARING RE: MILLSTONE UNITS l
( ). APRIL 30, 1997 l 1 information you're talking about.
2 MS. LUXTON: Okay. We'll discuss that.
3 DR. TRAVERS: We'll take a look 4 ourselves to see what has been done on a --
in a sort 5 of a precedent basis.
6 MS. LUXTON: Okay. And we'll discuss ;
7 that?
8 DR. TRAVERS: But I can tell you there's i
9 a lot of information that typically makes up the kind 10 of review that we're talking about that is not at this '
11 time the kind of -- or the level, amount of information !
L 1
12 I would anticipate that would be being put on the
)
13 docket. But let's look into it. Why don't you check :
14 and I'll check as well?
15 MS. LUXTON: Okay. Great. But you know
- 16 what I mean about resolving the issue? This sounds 17 like a resolution, a possible resolution, of this I 18 issue.
?
- 19 DR. TRAVERS: Thanks. '
ir 20 MS. LUXTON: Thank you.
O ;
- 21 MR. LANNING: Okay. Any other questions k
g 22 for Dr. Travers? Yes, sir.
24 couple of quick questions. By the way, my name is Al I
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88 HEARING RE: MILLSTONE UNITS
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1 Cizek. I live in Higganum. And with regards to Unit 3 ;
2 ICAVP, there's been some discussion that the number of l 3 systems which may be looked at is on the-order of four 4 or five, something like that, out of 85. And in.a past 5 meeting, maybe two months ago, you indicated that 6 that's been looked at and statistically that you feel 7 comfortable with that number, like four or five out of 8 85.
9 I still can't get comfortable with that l 10 myself. Also,:I realize that there are certain systems E 11 which are obvious candidates to look at. So it's not R
12 like it's a big guessing game as to what systems to 13 look at. I'd have to believe you're going to look at 14 RCS as a system. You're going to look at ox feed water 15 as a system. You're going to look at service water as l
16 a system. So we've got three right there. And after l l
17 that, you'll surely look at one of the engineered !
I 18 safeguards or multiple ones. So whether it be I
19 containment or hipsy-lipsy -- I mean you can really 20 narrow it down to just maybe less than ten systems. So O
< 21 this is really not a big guessing game.
I g 22 Bearing that in mind,'I would be very
{l 23 interested in looking at your position on this and how 24 you came up with that number. And I'd like to ask to i POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1
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HEARING RE: MILLSTONE UNITS
) APRIL 30, 1997 1 see something in writing if I could.
2 DR. TRAVERS: Well --
3 MR. CIZEK: How do you justify the four 4 or five out of 85? l
-5 DR. TRAVERS: First of-all --
6 MR. CIZEK: I'm not looking for the 7 answer. Okay? ,
8 DR. TRAVERS: Oh.
9 MR. CIZEK: I'm just saying I would_be 1 10 interested in reviewing how you came to that g 11 conclusion.
d t
12 DR. TRAVERS: Well, Commission Paper 97-13 003 is the Commission Paper that's in the public 14 document room that establishes sort of the philosophy u 15 that we used in setting up the ICAVP approach for Unit-16 3 and the other two units, even though it's largely 17 focused on Unit 3 in that paper.
! 18 MR. CIZEK: Right. .
I: 19 DR. TRAVERS: But you made a couple of 20 points and I'd just like to answer them very quickly, O i
- 21 if I can. Statistically, we didn't make an argument '
I g 22 that four of the 86 is, you know, a statistically sound l 23 basis for anything. What we said was the criteria that 24 -- first of all, I should point out that dependent upon O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
90 HEARING RE: MILLSTONE UNITS I
'(]) APRIL 30, 1997 1 the way you cut systems up and identify them, our ,
2 thinking on four versus the way they cut up 86 might i 3 not be a directly apples-for-apples correlation in 4 terms of strictly numerics. Just to point out that 5 four systems and the way we're going to expect the ,
6 ICAVP to carry them out is likely, based on what I've 7 seen, to be a much -- well, a larger fraction than 86.
8 In other words, they've cut up 86 systems -- [
9 MR. CIZEK: So you might look at 10 engineering safeguards as a system?
11 DR. TRAVERS: Yes. It may be a bigger 12 cut --
J 13 MR. CIZEK: So it's possible, something 14 like that --
15 DR. TRAVERS: Something like that.
16 MR. CIZEK: all right.
17 DR. TRAVERS: So it results in a little
! 18 bit bigger fraction. But it still doesn't answer your
{.k-19 question in terms of statistics.
20 Rather than statistics, we looked at an o ,
!- 21 approach that would be based on the safety significance ;
I l
j g 22 of the system, as you point out, based on the number of
{l i
23 past mods, based on the technical disciplines that
. 24 would have to be evaluated, you know, how many there
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l 91 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 were.
l 2 You've pointed out systems that are 3 candidates. They are candidates. But they'rc systems l
4 that may or may not be the ones that we ultimately !
5 identify.
6 We think +.nat the approach that we're 7 using, starting with the ICAVP contractor and the NRC 8 independent but related look, really gives us an l'
9 unprecedented, really in terms of anything we've ever l
10 done as an agency, opportunity to look at the adequacy 11 of what they've done. We think that the systems we're gS 12 going to select and the scrutiny, the level of scrutiny
%.)
13 that we're going to apply to it go beyond anything 14 we've ever done at a facility in the United States.
l 15 For each ICAVP, just to give you an l
16 indication, we're planning four team inspections. A 17 team is comprised of 13 individuals. It's -- in many l 18 cases, there are two, four, eight-week inspections, 1-19 inspection efforts that are planned at each unit that ir 20 are going to give us an opportunity to assess, in our
! O. 21 view, the adequacy of where they are in CNP. It I
g 22 doesn't mean it's the end of the game.
h 23 If we start to find significant examples 24 of where they have not done a good job or examples, we O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
92 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 expect we'll be in a position to consider expansion of 2 scope or even pulling it back, as we've discussed here 3 today. So there's an opportunity, if we think we need 4 it, to drop back, expand the scope or pull back and 5 tell them, Northeast, that they're not ready for this 6 kind of --
7 MR. CIZEK: Well, I'm kind of hearing 8 that your criteria for selection is kind of akin to 9 whether or not it passes or fails. It's going to be a 10 judgment call for the --
2 11 DR. TRAVERS: For the selection of R
12 systems?
(~b
\- \
13 MR. CIZEK: Yes. i 14 DR. TRAVERS: Well -- ,
1 15 MR. CIZEK: Not the specific selection, 16 but the number. I mean if you're comfortable with four 17 or five, that's what it will be? But what I'm hearing 18 is --
19 DR. TRAVERS: Right.
9 j 20 MR. CIZEK: --
if you're not O
< 21 comfortable, it may go to, you know, ten or something?
I g 22 DR. TRAVERS: It could go to -- yes. It l 23 could -- one of two things, as I envision it, could l 24 happen. If we go in or the ICAVP contractor goes in,
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93 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 things are either going to go very well or potentially 2 they're going to go very badly. If they go very badly, 3 that's when we would consider just pulling back and 4 telling them that they're not ready for this kind of 5 verification step. If they go -- if there are few 6 findings that we assess to not be too significant or 7 the few that are, we might say, "Well, to get a better 8 level of comfort on the success of the utilities 9 program, we need to expand the scope and add systems to ,
10 the ICAVP effort." So that's a possibility.
F 11 MR. CIZEK: So you're comfortable that 12 the utility won't out-guess you, basically? Or you 13 will do your selection such that there's no way they 14 could kind of prep for this?
15 DR. TRAVERS: Well, there's several 16 things that --
17 MR. CIZEK: I mean that's why I cited I 18 like ox feed water or whatever. l l
' h 19 DR. TRAVERS: Potentially you could l
l 20 attempt to guess which systems we're going to select.
l 0 j < 21 I don't know how successful they'll be or they won't b
l l 22 be. But, in fact, we've made public sort of the b 23 criteria in the Commission Paper that I referenced what 24 we view as the principal criteria that go into our POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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1 thinking on how we will select those systems. And, 2 yet, there are enough of them that I think we're likely 1
3 to surprise anybody who wants to try and pick them. l 4 MR. CIZEK: Okay. So your basis then is 5 documented and it's in 97-something or other?
6 DR. TRAVERS: 97-003. And there's 7 another element to that.
8 MR. CIZEK: Excuse me. What is that, 9 97-003?
10 DR. TRAVERS: Oh, that's a Commission 2 11 Paper that lays out our activities for the oversight of R
r~ 12 Millstone. It's been out for months on the docket and
.c '
l 13 it's available for PDR's. If you can't find it, let me 14 know. But --
15 MR. CIZEK: Is it on your Web site 16 perhaps?
l 17 DR. TRAVERS: You know, I don't know.
l 18 MR. IMBRO: I suppose.
- 19 MR. LANNING: I think it is.
Ir 20 DR. TRAVERS: Is it on the Web site?
O
< 21 MR. LANNING: Yes. I think it is.
g 22 MR. CIZEK: Okay. But I'll just point b 23 out one other important aspect as it relates to the 24 selection of systems. And that is that we've, in that l C:1 POST REPORTING SERVICE l
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1 paper, as a matter of fact, -identified in discussions. j 2 with the Nuclear Energy Advisory Council that one or 3 two systems will be selected by that group and not by 4 NRC for the conduct of ICAVP, one of the -- one or two 5 of the four systems out of the 85 safety-related or 6 risk-significant systems will be selected by -- so, 7 potentially at least, the NEAC can do its best to pick 8 systems on whatever criteria they think are reasonable )
9 within the group one and group two systems that may 10 likely stand a better chance of not being guessed at by le 11 the utility.
12 DR. TRAVERS: Okay.
13 MR. CIZEK: I've heard what you say P.nd 14 I'll be looking forward to reading that document.
15 And maybe I can just follow up with a 16 quick question on the fuel pool at Unit 1 with either i
17 Ted or -- unlecs anybody -- is that okay? Real quick.
l 18 MR. LANNING: Yes.
- 19 MR. CIZEK
- It seems to me that it would 20 be pretty obvious that that's also a procedural non-O
. 21 compliance issue, Millstone 1.
k g 22 MR. EASLICK: Yes.
ll 23 MR. CIZEK: I mean moving fuel obviously 24 is a process which will have a rather rigid procedure
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() APRIL 30, 1997 1 associated with it, sign-offs. So perhaps this will go 2 down the road of wrongdoing also? These are signing 3 off procedures. Right? ,
4 MR. EASLICK: Any procedure could go l 5 down that road. Yes.
6 MR. CIZEK: Okay. And the only other 7 quick question I have is who ultimately identified the 8 problem? Was it the NRC or was it the utility?
9 MR. EASLICK: It was initially 10 identified --
are you familiar with the Trident e R 11 problem, the filter that was in the pool? They removed R ,
gg 12 the blades.
\-)-
13 MR. CIZEK: Yes, some understanding of-14 that. Yes.
15 MR. EASLICK: When they were coming out 16 of that, they had an underwater camera that was being i
17 used to reposition blades and move that filter. While I 18 that camera was scanning by, it came across one of the 1 19 bundles at the edge of the rack that was
- sticking up.
20 They wrote a CR to identify that particular assembly as O
. 21 being --
I g 22 MR. CIZEK: A CR is the ACR process?
l 23 MR. EASLICK: Condition Report. Yes.
24 Same thing. And then we waited a week and nothing l (:)
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1
j ;- 97 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 happened. And then we -- I persona.tly went to the Unit 2 Director at the time and asked him what he was doing 3 about that fuel assembly. And he said, "Well, it's not 4 really an issue. We have a lot of them that are l 5 offset." And we said, "Oh, really? How many?" And i
6 that prompted him to put a camera in the pool. And at ;
7 that point, they identified 56. And we documented in j 8 our inspection report that we felt that management .
l 9 missed the target on that. "And, oh, by the way, what 1
10 are the other surprises in that pool?" That was in 96- 1 I
11 08. Then they put the camera in. And then the debris 12 issue came to light.
13 MR. CIZEK: I just bring that up because 14 I would say that's another example of the lack of the 15 oversight, oversight in general at Millstone working.
16 If there's as many as 56 and it's been known, 17 apparently, and just didn't click in their heads --
l 18 MR. EASLICK: Apparently not. And, in
' - 19 fact, there's more than 56.
20 as MR. CIZEK: I just might say if 6
= 21 recent as -- this was fall. Right? Last year?
g 22 MR. EASLICK:- Yes.
l 23 A VOICE: Use the mike please.
24 MR. CIZEK: Okay. It would seem to me
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' HEARING RE: MILLSTONE UNITS I'l APRIL 30, 1997 l V
i !
1 l 1 then that as of the fall that the utility hasn't woken l 2 up yet because they didn't come across it, they didn't 3 bring it up. Would you -- do you have a similar l 4 feeling?
5 IJR . EASLICK: For which part of it?
I 5 M2. CIZEK: Okay. The utility -- it was l 7 ultimately identified in the fall of last year.
8 MR. EASLICK: Right.
9 MR. CIZEK: Now, since they've been 10 working on restart now for, what, over a year, then it R 11 seems like they really haven't come full circle as they (m 12 say they have. I mean wouldn't this have been 13 identified much earlier?
14 MR. EASLICK: Yes. And we felt it 15 should have. And that's what we documented in the l l
16 cover letter of 96-08, I believe it was. 1 17 MR. CIZEK: All right. That's fine.
I 18 MR. EASLICK: We felt that they missed 1
19 the target on that.
lr 20 MR. CIZEK: All right.
\
O
< 21 MR. EASLICK: And certainly that was a g 22 management call.
l 23 MR. CIZEK: And would you say that's 24 also a failing or a rhortcoming of your oversight? Not )
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99 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 you personally, but the Commission's?
2 MR. EASL7.CK: I don't know that for a 3 fact. I don't know what inspections were-done.
4 MR. CIZEK: Because I know I've talked 5 to, well, a few of you guys and actually -- and Mr.
6 Lanning. And, you know, I've heard for some time now l 7 that the problem with the NRC is that they're 8 understaffed, a resource issue, just like the utilities 9 are going through. And I'm just wondering if this was
)
10 an example of where you guys kind of missed the boat )
i 2 11 here, too, because of a lack of resources. And I I E i 12 realize you can't check each and every thing. And, 13 again,' I'm not looking at you specifically. T am, but l
14 I'm not --
15 MR. EASLICK: No. I understand your 16 question. I would be speculating because I don't know 17 the answer to that question.
! 18 MR. CIZEK: Well, do you personally ieel
- I 19 that there's a resource issue within the NRC as far as 20 inspectors and time you can devote to --
. O l
= 21 MR. EASLICK: Well, the program is set l
l g 22 up so there are in most sites two inspectors, a Senior l 23 Resident and a Resident. And, again, it's no secret 24 that our inspection program was based on a sampling j i
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1 basis. If we had ten inspectors, certainly we'd see 2 more things. We'd get to see and inspect more items.
3 There's no question about that.
l 4 MR. CIZEK: Okay.
5 MR. EASLICK: But that's not the case.
6 MR. BURRITT: I'd like to add one other 7 thing to that. With those particulars, you can't 8 physically see them for the most part from looking down 9 into the pool. We don't have the capability to run 10 underweter cameras ourselves. So that's something we 11 rely on the licensee for. So even if you had the ten 12 inspectors to provide additional oversight, there's a 13 high likelihood that you would not be able to see a 14 deficiency like that.
15 MR. CIZEK: Okay. Okay. Thank you.
16 MR. LANNING: Mr. Cizek, I have a 17 personal copy of that Commission Paper.
l I f, MR. CIZEK: Thank you. Very good.
I LANNING:
- '9 MR. Ignore those notes in 20 there, o
< 21 All right. Another question? Yes, sir.
g 22 MR. TED QUINN: My name is Ted Quinn b 23 from Niantic. I guess I've heard a number of issues 24 tonight that relate to a point of confusion that I l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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i 101 HEARING RE: MILLSTONE UNITS
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1 think is fairly clear. I think there's a lack of
, .2 understanding of what the ICAVP is. And I'll just l
3 provide my quick comments on that. ,
l '4 What I heard you say a few minutes ago l 5 was the level of detail and I still think independent 6 of how you describe it, it's been understood -- it's 7 been not understood as to exactly what is an ICAVP.
l 8 In the history of nuclear energy, the 9 SSFI was developed, as I understand it, to go out and 1
10 do inspections and it was stopped in the early 90's for l E 11 one reason or another. But it was found to be very 8 ,
12 successful. And the process of having eight or ten )
)
13 people do an inspection was found to be very 14 significant. And when you did a vertical slice, you 15 ended up with issues that went well beyond that portion 16 of the system or the system that you went in, you 1
17 really had a good test, whether.you consider it as a l l
l 18 physician's level or you were really looking at much 19 more than that sample.
20 The ICAVP, as I see it, is looking at o
- 21 eight to ten --
eight times or eight specific j 22 investigations that are going to be carried on. Much b' 23 more significant, the inspections that have occurred in l
24 the past. And I think that the only thing I'd want to POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
102 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 underscore is I believe that this is the largest 2 inspection program in the history of nuclear energy.
3 And I think when you combine the 70 to 100 or more 4 people that are going to look at this, it's much more 5 than the 54 sites that we've seen eight or ten people 6 look at.
7 And I think the level of effort that's 8 going into this is going to point in -- directly into 9 the areas that it needs to look at. And that's what I 10 really wanted to comment on.
11 MR. LANNING: Okay. Any other questions S 12 for Dr. Travers?
{Q 13 MR. CHARLIE LUXTON: My name is Charlie 14 Luxton. I think I just heard you say that NEAC was 15 going to look at two systems or going to choose two 16 systems. Is that correct?
17 MR. IMBRO: Choose two.
l 18 DR. TRAVERS: That's correct.
I - 19 MR. LUXTON: Okay.
Ir 20 DR. TRAVERS: Up to. We said one or O
. 21 two.
b g 22 MR. LUXTON: What about Frank Rothen?
$ 23 DR. TRAVERS: What about him 24 MR. LUXTON: He's on NEAC.
i
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HEARING RE: MILLSTONE UNITS I APRIL 30, 1997 1 DR. TRAVERS: NFAC will have the 2 opportunity to select one --
3 MR. LUXTON: You're going to let Frank 4 Rothen be a part of that process?
5 DR. TRAVERS: I'11 ask NEAC maybe to 6 address that. That's really up to them how --
7 MR. LUXTON: Well, I have a very large 8 problem with that. !
9 DR. TRAVERS: Actually, it sounds like a 10 good question to me. i 2 11 MR. LUXTON: Okay. Now, as far as your '
R 12 choices of the systems, I think the number, despite 13 what I just heard, is really much too low, the number 14 of systems that you're going to review. I'd like a 15 higher number, even if it's slightly higher, and I'd 16 like the public, not NEAC, not-the NRC -- I don't trust 17 the NRC. I certainly don't trust the utility, for good l l 18 reason. I'd like the public to be able to choose at i
- 19 least two systems. And if I can suggest a method.
I 20 It's been talked about by me once before and I've also O
. 21 heard it mentioned by a member of NEAC. And that is b
g 22 there are 88 systems. You get 88 pieces of paper. You l
-l 23 write No. 1 to 88 on the pieces of paper, fold them in )
l 24 half. You put them in a hat and you let two members of l
i l
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104 HEARING RE: MILLSTONE UNITS
(]} APRIL 30, 1997 1 the public choose two numbers out of that hat. That's 2 a system that's fair. It's random. It's accepted l 3 worldwide in lottery systems and so on. And it's 4 pretty simple. And I don't think you're going to have 5 much in the way of resentment or doubt as far as it 6 being fair. And if I can suggest, I'd like my two kids 7 to be the ones to pick. They're seven and eight years i
8 old. And I think, you know, that's pretty fair, also.
9 So that's my opinion on that process.
10 And now I know that this issue hasn't l E 11 been brought up yet and we'll kind of revisit the past i R
( w 12 for a second, but it does relate to the present, I 13 think. And that is the Gladys issue. Did I hear "Eh"?
14 It relates to -- I'm going to --
15 MR. LANNING: You're getting off -- !
16 MR. LUXTON: No, no. I'm --
l 17 MR. LANNING: Because the Gladys issue I 18 hasn't really been breached here as a topic.
l -
19 DR. TRAVERS: But we're willing to stay 3 20 and at the end of the meeting -- because --
0
_= 21 MR. LUXTON: Okay. I do want to --
b
- g. 22 DR. TRAVERS: I'll tell you once again l 23 why we're doing it, just so you know. We've advertised l 24 an agenda. We want to give people the opportunity to e
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1 hear it.
2 MR. LUXTON: Okay. ;
3 DR. TRAVERS: And then we'll stay late, 4 as long as you'd like, and we'll talk miscellaneous :
5 questions at the end of this.
6 MR. LUXTON: Okay. All right.
7 DR. TRAVERS: I'm not trying to cut you i
8 off, 9 MR. LUXTON: Okay. Fine. Thank you.
i 10 MR. IMBRO: Since we had already started 2 11 the discussion on ICAVP, I think the thought is we go R
12 through and I give a little synopsis of where we are 13 with the ICAVP process.
14 But before I do that, maybe I want to 15 share a little bit of insight with you. And you'll ,
16 have heard a number of comments on, well, four systems 17 perhaps is not enough. But you have to think about I 18 what the vertical slice review does. It looks at many, ,
- 19 many areas that are common or processes that are common ir 20 to all the systems. For example, piping analysis. The ,
o
- 21 same type of methodology for piping analysis is used on l $ I g 22 all the systems. And so if we look at four systems and b 23 find that the piping analyses are okay, for example, 24 then it would be reasonable to conclude that the same -
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HEARING RE: MILLSTONE UNITS i APRIL 30, 1997 1 - since the same process is used on other systems, that 2 those systems would also be acceptable in that area.
3 So -- and there are many other areas like that. ,
4 Environmental qualification is another area.
l 5 But the system designs have some f 6- commonality even though the systems have somewhat 7 different functions. So when you look at four systems, 8 in a sense you're getting a snapshot of other systems I i
9 as well. And so you can't say, well, we're just 10 looking at four systems. I mean, clearly, if we found, l
11 E for example, to use piping analysis again,_ problems l 2
- 12 with the piping analyses in the systems we selected or 13 the NEAC selects, then, clearly, we could as one option l 14 expand the scope and look at that as a topic among or 15 across other systems. !
16 So, in a sense, looking at four systems l 17 really gives you insights into all or a large portion I 18 of other systems. And so when you think about, well, I
19 it's only four out of 88, you know, it's really more 20 than that.
O
= 21 In addition, one of the things the ICAVP i k g 22 will do is not really to focus on just the specific l 23 systems selected in terms of -- to get into -- well, in 24 terms of just if you drew a box around a system because O POST REPORTING SERVICE ]
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(]) APRIL 30, 1997 1 you're not going to focus just within that box. But 2 we're going to look at system functionality. And so 3 for the systems we select, we'll look beyond and the 4 ICAVP will look beyond those systems, for example, to 5 look at things like electrical power and how -- and so 6 that's sort of going into another system.
7 We're going to look at interface 8 requirements for those systems and how those are met.
9 So that again gives you a little bit of a look into 10 other systems. So by the time the process is done with R 11 the four systems, that alone would give you a very 8
12 reasonably -- well, a very broad look at many design 13 characteristics and processes that are common 14 throughout the plant.
15 The other consideration is that the Tier 16 Two review is also going to be a look not specifically 17 at systems per se but a look at accident -- you know, I 18 the accidents or hypothetical accidents that are
- 19 analyzed in the license or in the FSAR. And so we're 20 going to look at all the systems that get engaged in
' O
, . 21 those accidents in terms of looking at critical b
g 22 characteristics to make sure that those other systems,
!$ 23 again beyond the four or five, those systems can 24 perform those specific functions that support the
,()
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HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 accident analysis.
l 2 So when you say four -- yes, maybe we're l 3 doing ourselves a disservice when we advertise four
! 4 systems. In fact, if you look at the whole ICAVP, it's 5 far broader than the four systems. So, with that, let i 6 me -- let me go on and give you a little bit of a j l
l 7 stat.us as to where we are.
l l 8 You may have been aware that we have -
l l
9 approved Sargent & Lundy at least as an organization l 10 that's credible to do the Unit 3 review. Also for Unit I l l l E 11 1 as well. And that was documented in a letter to NU 12 dated, I believe, April 7. And that should be in the 13 public document room. And so that gives the basis for 14 our approval.
15 We have also been looking at the audit i
16 plan that was submitted by Sargent &'Lundy. And we've
! 17 had a meeting with Sargent & Lundy and NEAC was present l 18 at the meeting. And we met in Chicago. And we j i
19 discussed some of our comments on the audit plan. The 1 20 l r audit plans, we felt, were quite thorough and really a i
- O
' . 21 very good first cut at attacking the problem. What we k
g 22 felt -- or what hadn't been provided up to that point l 23 were detailed checklists as to really how the program
( 24 was going to be implemented in terms of specifics that i
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109 HEARING RE: MILLSTONE UNITS l
Q APRIL 30, 1997 1 were going to be looked at.
J 2 We have received all of those f
t l 3 checklists, I believe, today. And those are also in 4 the public document room. And so you'd be able to look i 5 at those.
6 We also are continuing now, since we 7 just received the balance of the checklists, to review 8 those checklists. And we have contractors with 9 specific technical expertise in various disciplines, 10 for example, mechanical systems, piping analysis, E 11 electrical system design and instrumentation and 8
i 12 control and also operations, looking at those 13 checklists. And we will be providing comments back to 14 Sargent & Lundy on those.
15 In terms of -- to switch gears now to go 16 to Unit 2, Parsons, Parsons Power Group has been 17 proposed by Northeast as the ICAVP contractor for Unit '
I 18 2. We're in the final processes of issuing an )
I 19 organizational approval also for Parsons. We have one ir 20 more item to look at in terms of financial O
. 21 independence, I think. And I just got the information g 22 today. But, basically, Parsons Power looks like also a l 23 very credible organization to be able to review Unit 2.
24 And, again, we'll go through the same O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
110 HEARING RE: MILLSTONE UNITS O APRIL 30, 1997 O
1 process with Parsons in terms of reviewing the audit 2 plan. And what I failed to mention also with Unit --
3 or with Sargent & Lundy was that in our visit to 4 Chicago, in addition to discussing the audit plan, we 5 also did a detailed or a thorough interview of all the 6 --
well, I say all -- probably about 40 of the people 7 that will participate in the ICAVP review. Our 8 contractors interviewed them. I interviewed some folks 9 myself. And we have, you know, a high comfort level 10 that the people are qualified to do the job. Again, we 11 missed a couple of people and those we'll -- we'll pick 12 those up on telephone interview because they were not 13 available. And, you know, essentially the same process 14 will be utilized in dealing with Parsons.
15 So that's essentially where we stand i
16 now. We heard today from Northeast Utilities that they i 17 believe that they will be ready for the ICAVP on the l
! 18 27th of May for Unit 3. Unit 2 is to be ready June 23
- i. 19 for ICAVP. And so at that point when Unit 3 declares ir 20 they have completed half the Group One systems in terms o
. 21 of the discovery phase, then we will select systems and l
g 22 start the ICAVP process.
l 23 So I guess that's kind of a quick li 24 summary of where we are.
(~h '
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111 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 Yes? Bill?
2 BILL: In looking at the handout that 3 you just gave us , I looked at the schedule and i 4 comparison of the time frame between how long Parsons
, 5 says they're going to take for Unit 2 and how long 6 Sargent & Lundy says they'll take for Unit 3. And I 7 found it interesting that Parsons' schedule is laid out 8 over a 33-week period and Sargent & Lundy says they'll 9 dc the same thing in 12 weeks. Is that because Sargent 10 & Lundy is so much bigger, they can put more people on le 11 it, Or is the assumption that the Unit 2 problem is so 12 much greater than the Unit 3 ptchlem?
13 MR. IMBRO: No. I don't think the 14 latter is the case. I'm not really sure what the '
15 answer to that question is. I think that if you look c 16 at the Sargent & Lundy revised audit plan or -- I 17 believe that their -- the duration of their plan is
! 18 probably going to expand a little bit beyond what they 1
19 proposed originally as 14 weeks. So it may be 20 something like 18. I'm not exactly sure what that 0 I a 21 number is. !
l g 22 But I don't really know how Parsons l 23 arrived at the 29 weeks. We haven't really looked at 24 that yet. I guess our only criteria would be that they
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I 112 HEARING RE: MILLSTONE UNITS
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APRIL 30, 1997 !
l 1 do a thorough job and we're going te oversee them to l 2 make sure that they do.
l 3 I would point out one thing, one piece 4 of information that I can share with you that I know; j 5 is that for Parsons, as I understand it, they are not f l
l 6 planning to develop the system checklists until they I 7 start the ICAVP where Sargent & Lundy has done that 8 work up front. And so that may contribute somewhat to 9 the fact that Parsons is going to take a little bit 10 longer. That's all I can offer. ;
R 11 Others? Don?
E )
12 MR. DELCORE: I have a question with !
13 regard to your assessment of what four systems out of 14 88 systems -- what reasonable assurance and percentage 1 15 -- in other words, if we did 88 out of 88, then we'd l i
16 have 100-percent assurance. And I understand that your I I
17 sense is that we're doing four systems but it's more l l 18 like doing more than four systems.
- 19 MR. IMBRO: That's right. j 20 MR. DELCORE: So if you could give me o
. 21 some sense of or give me assessment of what you feel I
22 these four systems -- what percentage that you feel we g
l 23 would. accomplish in terms of scope?
24 MR. IMBRO: Again, that really wasn't l
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HEARING RE: MILLSTONE UNITS APRIL 30, 1997
. (]) [
1 the point I was trying to raise. What I was --
i 2 MR. DELCORE: No. I know you weren't. [
3 I'm just saying I'm trying to put this thing in a 4 perspective -- [
5 MR. IMBRO: I'm not sure that I could 6 answer it that way. I mean just to pull a number out !
7 of the way I'm not sure does you or me any good because 8 I don't really have any confidence in the number. !
9 What I guess I wanted to try and point 10 out was that by looking at four or five or more ;
R 11 systems, you know, the processes in many. areas are R
12 similar. So if you look at four chosen in some random
.O 13 fashion or some objective manner and you find that for 14 that particular area that you look at that it comes out 15 clean, then you could have reasonable confidence -- and l
16 I don't what reasonable -- you know, I mean I can't put i 17 a number on reasonable. I guess we all -- that's i
! 18 somewhat subjective -- that those areas in those other i: 19 systems unreviewed are acceptable.
20 MR. DELCORE: I understand that. But, o
. 21 also, I. understand that there is going to be some I
g' 22 latitude and acceptance of certain things. As we l 23 pointed out before, as Bill pointed out before, to give 24 you an example, a calculation that may have an error POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1
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HEARING RE: MILLSTONE UNITS ;
) APRIL 30, 1997 !
1 but it doesn't have much safety significance or it has 2 little or no safety significance, so it's not j 3 important. But when I put that in perspective and say, 4 well, I looked at System No. 2 and I found a ,
5 calculation error which had to do with a set point of ,
6 something and it was insignificant but now I'm looking 7 at System No. 58 that hasn't been looked at, it has the 8 same calculation error, but in this case it 9 significantly affects some safety setpoint of some :
10 safety issues. So what I'm saying is I don't -- I lR 11 still don't get a warm feeling that we're addressing l l $
12 that issue. j t
13 DR. TRAVERS: Let me just take a shot at !
14 responding because I did make mention of something I 15 want to make sure you appreciate. And that is that I 16 said in addition to judging findings that have safety l 17 significance, we also are going to look at findings
! 18 that don't and, perhaps because there are numerous
' i: 19 findings of that sort, might suggest that because of '
1 r 20 the new -- you know, that there are a large number of C
- 21 findings that aren't very safety-significant, we might ;
22 want to expand the scope in any case just because of l
l 23 the fact that errors, even if they're judged not to 24 have great safety significance, lead you to question l
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HEARING RE: MILLSTONE UNITS '
}{} APRIL 30, 1997 1 1 any sample results that only involve some number of ;
i 2 systems of the total population. '
3 So there's findings that are safety-l l 4 significant that might cause us to expand the scope or 5 pull back and there are total numbers of findings that '
6 might lead us to question whether or not what we're ,
i 7 finding in our sample results are truly findings that {
8 lead you to make the conclusion that there's no safety ;
9 significance. They, in fact, in another system might 10 be safety-significant, as you point out. !
i E 11 MR. DELCORE: Right. And what I'm
! E 12 saying is suppose you don't find them in any kind of 13 numbers? You find one calculation. There isn't !
14 anything that assures me that that --
a similar 15 calculation in a system you haven't looked at does have !
i 16 safety significance. And if it's -- and if there's not i i
17 enough of those errors, you're not going to look at j l 18 them in other systems. And I'm concerned that that's a 19 problem.
20 DR. TRAVERS: But what we are doing, as O
= 21 I'll- point out once again and it doesn't give you much k
g 22 comfort,-is we are taking an unprecedented look at lots l 23 of things, lots of calculations both in the ICAVP and 24 the NRC review, and we think with very high confidence
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l 116 HEARING RE: MILLJTONE UNITS
() APRIL 30, 1997 l 1 that it's going to give us a good picture across the :
2 board in these systems in how good a job NU has done in >
l 3 its confirmation of all of the 80-odd systems. :
4 We think that we've devised a program !
1 l 5 that focuses on, you know, as I say, an unprecedented j 6 level of effort that we're going to put on it and the I 7 contractor will as well. It's not 100 percent, though. [
8 MR. DELCORE: I know. I recognize that, 9 you know, you're doing something much more than-you've i
l 10 done before. But license basis --
, E 11 DR. T: RAVERS: hit's a sample.
lE L 12 MR. DELCORE: -- design basis and FSAR's 13 are 100 percent. 98 is not acceptable. 90 is not l 14 acceptable.
15 DR. TRAVERS: Well, let me just point I
I 16 out that in licensing a nuclear power plant we 17 typically don't look at this level. When we do, we
!l 18 typically -- perhaps in very isolated instances for a 19 system in licensing phase we might look at one or two 20 of these systems. But the licensing review itself O
- 21 typically does not dive in at the level that we're --
l ll 22 as you know.
l 23 MR. DELCORE: And that's why we've got i 24 the problems we've got right now.
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({} APRIL 30, 1997 1 DR. TRAVERS: Well, I think in 2 substantial measure that's part of why we're post-3 Millstone assessing where other plants are in terms of 4 their design basis, licensing basis.
5 MR. DELCORE: You need to understand the
- - 6 reason why I'm concerned. The reason why I'm concerned 7 is because Maine Yankee recently went through a little 8 bit of an ICAVP and they -- or let's say a CNP review 9 and comparing some areas with their FSAR. And they 10 found that they were outside their FSAR and they found 11 that the changes were not put into the updated Final 12 Safety Analysis Report. All that information was 13 presented to the- Commission and they approved the 14 restart the last time. So that's why I'm concerned.
15 Because the Commission knew that they were outside of 16 their license basis but said, "Let's do it anyway,.
L 17 guys."
1
!a 18 And so that's why a guy like me wants to f 19 see 100-percent check and that's why a guy like me l 1r 20 won't take four systems out of 88. And there isn't any o
'- 21 way you can convince me that four systems is going to I
g 22 make me feel better. And that's the reason for it.
l 23 It's not that I'm up here trying to be negative or 24 criticizing you. What we've seen in the past has been, l
e
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I 118 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 "It's not ready, it's not ripe, but we're going to do 2 it any way." And I don't think that that's being fair 3 to the public in this area and it doesn't do a thing to 4 get us in a credible position with you guys at all.
5 And that's the reason why I'm up here banging on the .
1 6 table.
7 Thank you.
8 MR. IMBRO: Yes, Mr. Markowitz?
i 9 MR. MARKOWITZ: Gene, could you explain )
1 10 -- in both audit plans, Parsons and Sargent & Lundy, as l E 11 well as in the RFP that Northeast put together for the R
r~x 12 contractor, the ICAVP, there was a group called the U
13 IOT. Independent Oversight Team. I've read the plans 14 and I've also read the RFP. I'm a little bit familiar 15 with what it says. Could you share with us how you see 16 that working as part of the process? It's been very 17 silent so far on who are the members of that.
I 18 DR. TRAVERS: Yes. This -- maybe I can
! 19 take a shot at it, Mr. Markowitz. That was something 20 that we were given indication from NU that they were O
< 21 considering factoring into any program of oversight.
I g 22 And I think it had a public oversight element to it.
l 23 It's not part of what the order requires 24 or what we are in the business, frankly, of regulating.
/~N
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l l
t 119 HEARING RE: MILLSTONE UNITS O ^921' 3o 1997 1 Whether or not that occurs is really up to Northeast.
2 And I don't know whether today they are planning to 3 carry out the concept of that independent oversight 4 effort or not. But it's something that would be 5 separate from what we are going to require.
6 And, certainly, if they did, I think the 7 only principal concern or question we would have is how 8 it would work relative to what NRC wants out of the 9 ICAVP effort and that it wouldn't in any way create a 10 hurdle or burden to that effort.
L E 11 MR. MARKOWITZ: So my understanding is R
l 12 it is part of the audit plan and, therefore, it could 13 be part of the process but it will not be something 14 that the NRC will specifically look at. It is between 15 Northeast Utilities and Sargent & Lundy and Parsons.
l 16 DR. TRAVERS: Correct. It could be. )
17 And we're not reviewing it as part of our audit review, i l 18 except to the extent that if it were something that 19 they decided they were going to go forward with, we 20 would examine it from the context that I just O
. 21 described.
g 22 MR. MARKOWITZ: Thank you.
i l 23 MS. LUXTON: Hi. I'd like to comment on !
i 24 the Sargent & Lundy audit plan --
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1 MR. IMBRO: Please.
i 2 MS, LUXTON: -- that was in the public 3 library. I looked at it a little bit and I have some
- i 4 questions about ICAVP, Sargent & Lundy's process. '
l 5 Now, I'm turning to Page 19 of that j i
! 6 document and I see where it has 4.7, Processing 7 Verification Team Findings. They explain that when a 8 member of the VT -- okay. The VT is the --
l 9 MR. IMBRO: Verification team.
10 MS. LUXTON: The verification team
!R 11 identifies a discrepant condition which does not appear E
i 12 to meet the requirements, he shall initiate a discovery l 13 --
I mean a discrepancy report. That's called a DR.
14 Okay?
15 MR. IMBRO: Right.
16 MS. LUXTON: Now, the discrepancy report 17 document identifies things. Okay? That examples of I 18 discrepant conditions are a disagreement between the I- 19 system design basis and the FSAR, the as-built l' 20 configuration of a piping system and the piping l r i O. 21 analysis are a change to maintenance procedures which l
g 22 should have been made due to plant modification but was
'l 23 not. Okay? Now, I'm assuming this -- this is S&L.
l 24 This is Sargent & Lundy.
1 O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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d 121 HEARING RE: MILLSTONE UNITS
(]} APRIL 30, 1997 1 MR. IMBRO: Right.
2 MS. LUXTON: And when they find 3 something, they're going to do a DR. Right?
4 MR. IMBRO: Mm-hmm.
5 MS. LUXTON: Okay. Then other technical l l
6 -- all right. Wait a minute now. The DR document will 7 document the discrepant condition and the documents or 8 walk-down reports that were reviewed to arrive at that 9 conclusion. Other technical and administrative items 10 will be included on the DR form to help track, trend 11 and analyze the results of the verification program.
12 The DR will be signed by the VT member, verification l I
v 13 team member, and forwarded to the group leader. Then 14 the group leader leads a review of the DR. Okay? And 15 he decides with the team member the technical adequacy, 16 completeness, whether a specific issue has been 17 addressed by any other DR or by an existing NU l 18 corrective action document or whatever. And then he, 1
- 19 in effect, validates the DR for the VT.
h 20 MR. IMBRO:
e That's how I understand that O
< 21 it works. Yes.
I b g 22 MS. LUXTON: Okay. Right? Now -- then i l 23 he can validate it or not validate it. It can be not 24 validated by the VT group leader. Then it jumps POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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' 122 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1
1 another level to the group -- to the VT manager who can 2 either agree with the group leader and the team member i 3 or he can not validate what they just validated. All l 4 right?
5 MR. IMBRO: Sure. l l
6 MS. LUXTON: Now, what I'm getting at i
7 here is -- and it gets back to what we were talking 8 about before. I and the citizens group want that-l 9 information. We in the public need to know what that ;
10 original DR is. Okay? I don't want to -- because what
, E 11 this does is the group lead can make his own subjective R
n 12 assessment. The group manager can also then make a U
l l 13 subjective assessment about the group leads and the l
14 VT's, the original, i
15 MR. IMBRO: Mm-hmm.
l 16 MS. LUXTON: I don't want that. I want i 17 and the public -- the public needs to know the raw
,! 18 data. This is what I meant, Dr. Travers, by raw data.
- 19 I --
we want the DR's. Okay? We need the original ir 20 DR's when they're issued, not when they're validated by 0
. 21 the group lead or the group manager. Before that. We 1
22 want to'know. Because that's what they found when they
}-
!l 23 did the walk-down. That's the original raw data.
24 Okay. That's my first point.
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1 l 123 HEARING RE: MILLSTONE UNITS I~' APRIL 30, 1997 l \~-)
1 Then we can make an assessment of our 2 own whether we validate or not. Correct?
3 MR. IMBRO: Well --
4 MS. LUXTON: Get my drift?
5 MR. IMBRO: Yes. I understand what 6 you're saying.
7 MS. LUXTON: All right.
8 MR. IMBRO: But the only -- and I'm not 9 disagreeing. I'm just kind of -- I'm just thinking 10 that in order to really validate whether or not the DR R 11 is a problem or it's something that's not a problem, 1
12 you'd really have to have all supporting documentation.
13 For example, you may have to have all the drawings, all 14 the calculations. And so just by looking at the DR, 15 even in its kind of developmental form, you really 16 can't --
you couldn't really come to a reasonable I 17 assessment unless you had a lot of the background
! 18 information. And I'm not saying you shouldn't have it.
19 But I'm just pointing out that --
20 MS. LUXTON: Okay.
O
< 21 MR. IMBRO: --
there's a lot of b
g 22 information that's available.
l 23 MS. LUXTON: Well, that's something 24 we'll have to discuss.
A l
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124 HEARING RE: MILLSTONE UNITS j
) APRIL 30, 1997 1 MR. IMBRO: Yes. Okay. That's fine.
2 MS. LUXTON: That's a minor thing we'll 3 have to discuss.
4 MR. IMBRO: Well, it's not that minor.
5 MS. LUXTON: Well, it's not that minor.
6 But we'll have to discuss that.
7 MR. IMBRO: That's fine. Sure.
8 MS. LUXTON: I'm willing to discuss 9 that.
10 MR. IMBRO: 7tay. All right.
i R 11 MS. LUXTON: I do have a barn on the R
12 property. So'I do-have a large area for --
O 13 MR. IMBRO: Okay.
! 14 MS. LUXTON: I mean if I can get the 15 support, technical support --
16 MR. IMBRO: Okay.
17 MS. LUXTON: --
it's worth it to me l 18 because this is my -- this is my --
-19 MR. IMBRU: I understand.
! r 20 MS. LUXTON: You know what I mean. This iC j < 21 is my town. This is where I live.
'h g 22 MR. IMBRO: Okay.
l 23 MS. LUXTON: And everybody I know lives i 24 here. And I want to make sure this is safe.
4 1
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l 125 HEARING RE: MILLSTONE UNITS l
() APRIL 30, 1997 1 Okay. So, anyway, the next thing. I l 2 want to move on to Page 23 under ,.0, 8 Governing 3 Procedures. All right? This is another thing that I 4 think the -group needs. We need all these governing 5 procedures, 1 to 12. Okay? Do you have a. problem with 6 providing that, having S&L providing that to us, Mr.
7 Imbro?
8 MR. IMBRO: No. No.
9 MS. LUXTON: You don't have a p?;oblem.
10 MR. IMBRO: No.
E' 11 MS. LUXTON: Good. Next question. All 12 right. We move on to Page 24. Now, here's the thi.ng 13 on this. It says here at the bottom of Page --
14 MR. IMBRO: I'm not sure that they 15 weren't really in the -- aren't those in the PDR? I 16 thought they might be.
17 MS. LUXTON: Oh, no. I want to bypass
! 18' the PDR.
l 19 MR. IMBRO: Okay. Yes. Fine. ;
20 MS. LUXTON: I want to bypass the PDR
.O a- 21 now. '
- g. 22 MR. IMBRO: Yes. We'll get you a copy.
l 23 No problem.
1 24 MS. LUXTON: All right? Okay. Because l
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HEARING RE: MILLSTONE UNITS
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1 you're really sending me stuff. Every day I get a 2 manila envelope from you. I don't want to have to --
t 3 MR. IMBRO: I don't think so. !
4 MS. LUXTON: --
rely on the PDR any
! 5 more. I'm -- we're over the PDR. We're serious now. e i
) 6 Okay?
I' l
7 Okay. Are we ready?
l 8 MR. IMBRO: Yes.
l 9 MS. LUXTON: On Page 23, Mr. Imbro, it !
10 says at the bottom there, "The QA auditors will review l2 11 selected discrepancy. reports, DR's, identified by the lE 12 VT, by the
() -- what was the -- the verification team l I j 13 member --
14 MR. IMBRO: Yes.
1
! 15 MS. LUXTON: -- and will pay particular 16 attention to any DR's that are determined to not be 17 valid. A summary of the QA activities related to the l 18 ICAVP and their conclusions will be included as a part 19 of the ICAVP final report."
ie 20 So, actually in this audit plan they C
. 21 were planning on telling tia public because they were g 22 going to put it on the Worldwide Web. But the kicker - i (l 23 - but the thing is they were going to summarize it. So i 24 do you understand? I'm asking --
4
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APRIL 30, 1997 1 MR. IMBRO: Yes. I understand what you 2 want. Yes.
I 3 MS. LUXTON: --
to get before the 4 summary --
5 MR. IMBRO: I understand what you're 6 saying.
7 MS. LUXTON: Okay? Because the summary 8 is too late. So that's not acceptable for us. Right?
9 Is that clear?
10 MR. IMBRO: Yes. I understand.
lR 11 MS. LUXTON: Good. All right. Now, I'd !
lE 12 like to go to something else. I have another question 13 on this. And that is on the flow chart --
i 6
14 MR. IMBRO: Actually, we were going to ,
15 look at those, too, in terms of --
l 16 MS. LUXTON: Oh, well, shall I wait l
l 17 then? i i
! 18 MR. IMBRO: No. No. We can give them l 9 I!
19 to you. I mean we were going to do the same kind of 20 thing in our audit of Sargent & Lundy, is to look at o
. 21 the things that they thought were not valid findings 0
g 22 that got kicked out of the process as our own overcheck l 23 of Sargent & Lundy. Just for your information. But --
24 MS. LUXTON: Okay.
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r- 1 128 HEARING RE: MILLSTONE UNITS (f APRIL 30, 1997 1 MR. IMBRO: --
that's not to preclude 2 you getting the information.
3 MS. LUXTON: Are you going to look at l 4 the raw data, too, first or are you just --
5 MR. IMBRO: Absolutely. ,
6 MS. LUXTON: Right. You're going to ;
7 look at that, too.
8 MR. IMBRO: That's right.
9 MS. LUXTON: Well, then we'll look at 10 it, too.
i a j 11 MR. IMBRO: That's wonderful. 1 12 MS. LUXTON: All right. Now, the next 13 thing I have is the flow chart on Page --
and, 14 honestly, you need a magnifying glass for the flow l 1
15 chart. I can't imagine --
16 MR. IMBRO: Which one is that? l l 17 MS. LUXTON: --
how you could possibly I 18 do it. I did have a big magnifying glass at home, but I
- 19 I don't have it here. But, anyway, it's Exhibit 2, i
e 20 flow chart for ICAVP process. And it has, you know, O ,
< 21 55,000 boxes. But I want to circle in on the large l 3
g 22 vertical line of rectangular boxes at the very bottom.
l 23 Go to the left and you'll see "Were --
i
[ 24 MR. IMBRO: Were discrepancies r
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l APRIL 30, 1997 ;
- 1 identified?
2 MS. LUXTON: "Were discrepancies 3 identified" to Point A. Then there's a vertical arrow 4 down and there's a triangle or box there, whatever that L
5 thing is -- what is that thing? Is that --
l 6 MR. IMBRO: That's an or gate, I'think.
7 MS. LUXTON: Elongated triangle?
i 8 MR. IMBRO: Or. Or gate.
9 MS. LUXTON: Or gate?
L 10 MR. IMBRO: Yes. See, you have -- it's ;
lR 11 a decision point. If it's a yes, it goes one way. If (2 ,
l~ 12 it's a no, it goes the other way.
l i
13 MS. LUXTON: Right. Okay. All right.
14 "Were discrepancies identified?" Then you go Yes to l :
l 15 the left and it says, " Process DR's." Then it says 16 underneath that "All." Then it goes down to another 17 arrow vertically down and it says " Review Millstone 3's 18 disposition", then it goes "All." Then it goes down to i
- 19 another one of those shapes and it says, "MP3 20 disposition accepted?", question mark. Then it goes 0 1
. 21 Yes, down and then it goes over to the right with an I
g 22 arrow and then --
okay. That's the end of the j j l 23 situation.
24 Now, my question is what does "All" 4
C' POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
130 HEARING RE: MILLSTONE UNITS f APRIL 30, 1997 1 mean? Do you mean that all those DR's -- what does 2 "All" mean?
3 MR. IMBRO: All the ones that -- I mean 4 I believe in this context it means all the ones that 5 are deemed to be valid. In other words, after 6 discussion with Northeast with NEAC and ourselves 7 present it's decided that this is not really just a 8 question any more but it really is a valid instance 9 where the plant does not agree with its licensing 10 basis. So it's a valid deficiency. Okay? It's been 1
R 11 validated. Yes, it is a real problem.
8 g-) 12 MS. LUXTON: All right.
N~/
l 13 MR. IMBRO: And -- I 14 MS. LUXTON: Then the disposition -- l 15 MR. IMBRO: And we'll review all of 16 those. So those -- the way the process works then is 17 if it's a valid deficiency, then Northeast has to
! 18 respond and they say, "Well, this is how we're going to
- 19 correct this deficiency. We're going to do X,Y,Z."
i e 20 MS. LUXTON: Right.
O
. 21 MR. IMBRO: And then Sargent & Lundy l=
22 needs to review that response and decide whether or not l 23 that addresses the problem. Does it look at the root j 24 cause? Does it address the problem in sufficient l
l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 I
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l t
131 l
HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 breadth? You know, not just the specific issue but 2 also on sort of a generic basis.
]
l 3 MS. LUXTON: For other --
l 4 MR. IMBRO: For other -- yes, for other !
5 systems.
6 MS. LUXTON: Right.
1 7 MR. IMBRO: Or components. And so that ;
i 8 Sargent & Lundy then needs to be accepting or !
9 comfortable with what NU proposes, that that's a 10 reasonable fix to the problem and if that's R 11 implemented, then the problem is resolved.
R 12 MS. LUXTON: Okay. The question is then 13 if that's implemented.
14 MR. IMBRO: Yes.
i 15 MS. LUXTON: They're not --
so is that 16 what disposition means?
17 MR. IMBRO: No. No.
! 18 MS. LUXTON: Sargent & Lundy --
I-19 MR. IMBRO: What that means is just ir 20 exactly what I said. Sargent & Lundy will assess ;
O. l
< 21 whether or not the fix is reasonable to address the '
1 g 22 problem.
'l 23 MS. LUXTON: Okay. So will they have ;
24 implemented the fix?
l(:)
f POST REPORTING SERVICE l
HAMDEN, CT (800) 262-4102 l
l 1
l
i 132 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 MR. IMBRO: At this point, probably not.
2 And you're going to ask who is going to look at it.
I 3 We're going to look at that, i
j 4 MS. LUXTON: You're going to look at 5 that?
6 MR. IMBRO: Yes.
7 MS. LUXTON: And then -- so are you 8 going to make sure they implement that fix and then it 9 will be safe?
10 MR. IMBRO: Yes.
11 MS. LUXTON: So they're going to 12 implement the fixes --
13 MR. IMBRO: If it's something that needs 14 to be implemented before restart, they will implement ,
15 it and we will verify it.
i 16 MS. LUXTON: Thank you.
I 17 MR. IMBRO: Others? Yes, Mr. Luxton. '
,l 18 MR. LUXTON: Yes. Just a quick comment.
' I
- 19 Don Delcore made a wonderful observation and that is 20 that if you check 88 systems, you get 100 percent. ,
O i
. 21 Anything less than 88, you can't guarantee 100 percent. l
-l 1 g 22 Now, why as a member of the public -- I live a mile and I
l 23 a half downwind with two kids. My parents are in this 24 town. My sister, my wife's parents. Why should I I
j POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
HEARING RE: MILLSTONE UNITS
([) APRIL 30, 1997 1 accept anything less than 100 percent?
1 2 MR. IMBRO: Well, you can answer that. j 3 MR. LUXTON: These are safety-4 significant systems we're talking about. Right?
5 DR. TRAVERS: And I don't know that I 6 could possibly convince you that you should. But what 7 I can tell you is what we've been trying to tell you 8 for some time. And that is that the program that we've 9 laid out that cuts across three tiers, it's a sample 10 system.
R 11 MR. LUXTON: It's not 100 percent.
2
~g 12 DR. TRAVERS: It's not. It's not.
(G 13 MR. LUXTON: Well, what percent is it?
14 DR. TRAVERS: It's not 100 percent. But 15 it's a program, it's an approach that gives a high 16 confidence that what has been done on the part of the 17 licensee to assure its licensing basis has been
! 18 effective. And it's being done by NRC and the ordered
- 19 third-party contractor at, you know, a very significant l
Ie 20 level of effort. But it's not 100 percent.
O
< 21 MR. LUXTON: But it doesn't give me any I
g 22 confidence because it's not 100 percent. These are l 23 safety-related systems. My family is in this town.
24 You've got to understand where I'm coming from.
(3
~#
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l 134 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 DR. TRAVERS: I understand.
2 MR. LANNING: Okay. Let me get us back l 3 on schedule here. Okay. I want to get us back on 4 schedule, if I could.
5 I want to talk briefly about the status 6 of the Restart Assessment Plan. Remember? This is the 7 road map, if you will, for gathering objective evidence 8 to support restart. We initially issued this back in 9 September of last year. We revised it in December and 10 just most recently in March was the third revision of E 11 that plan. As we talked about previously, this is a
<s 12 living document and we revise it based on changes, lJ 13 either progress the licensee has made in resolving i
issues or new issues have been identified and added l
14 to !
i 15 the Significant Items List.
16 So the most recent revision to the 17 Restart Assessment Plan, the primary purpose of that
! 18 was to include the Significant Items List for Units 1 1
19 and 2. If you recall, previously it was focused 20 primarily, exclusively on Unit 3, although some of the O '
- 21 more broad issues, programmatic issues, had site g 22 implications.
l 23 In addition, in this version we show l
24 where some of the significant items list have been
( POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
-- - . . . - - . - ~ . . _ - . - - _ - - - . - _ . . _ - .
135 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 completed, have been inspected and that's noted in the 2 list. So I'm not going to say too much more about 3 that. It's about the status. Again, it's been made
.4 available for you.
5 But are there questions about what's in 6 it or what it does?
l 7 MR. DELCORE: When you do the recovery 8 evaluation or whatever you're doing to make the I 9 determination, where does the ICAVP fit into that? !
t 10 MR. LANNING: The ICAVP is part of the l
R 11 Restart Assessment Plan. l 12 MR. DELCORE: It is?
13 MR. LANNING: That's one part of it.
14 Yes. l 15 MR. DELCORE: Okay. Let us digress back 16 one second here. The ICAVP, the flow chart that Susan ;
1 17 was talking about which was Exhibit 2 --
! 18 MR. LANNING: Okay. i l
j l
19 MR. DELCORE: The only place I could 20 find you guys on there is up at the top in the j O i
< 21 beginning identifying the systems that are going to be i 1 l g 22 ICAVP. After that, we don't see you any more. So I l 23 don't know when you're going to increase the scope, 24 when you're going to make changes or where you're going POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
i 136 HEARING.RE: MILLSTONE UNITS ,
APRIL 30, 1997 l 1 to be in this review process. I recognize that this is 2 Sargent & Lundy's chart. >
l 3 MR. IMBRO: Well, that's right. And I 4 think that's really the answer to the e, astion.
5 MR. DELCORE: Okay 6 MR. IMBRO: But I think Bill tried to 7 lay out how we would participate in the process through l 8 our inspection process which we would be doing.
9 Approximately two-week implementation, inspection at 10 Sargent & Lundy to look at how they're implementing the g 11 audit plan. We'd be doing then the -- you know, the 12 other -- the out-of-scope system inspection, which is 13 really not related to~Sargent & Lundy. But the in-14 scope, we'd look at --
after Sargent & Lundy was 15 complete with their program, we would look at one 1 16 system in depth, an eight-week duration inspection with 17 -- you know, with -- l l 18 MR. DELCORE: Well, what I'm trying to 19 do is fix in my mind how it was going to connect with 20 this recovery decisions that you're making and how you o
. 21 were going to interject along in the different review l 22 areas.
g l 23 MR. IMBRO: Well, but this --
]
24 MR. DELCORE: Do you have your own flow O
l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
'i
! 137 HEARING RE: MILLSTONE UNITS-(]) APRIL 30, 1997 1 l chart so I can see where you're going to be coming in j l 2 and going out or not?
3 MR. IMBRO: I think we had something j 4 like that in the Commission Paper. But it's not maybe
- 5 in the detail you want. But I think we can probably l
l 6 provide something for you.
l l l 7 MR. DELCORE: All right.
l l 8 MR. IMBRO: But I think that how the 9 ICAVP fits into the wrap is that if the ICAVP is j l :
10 successful, then we should be able to conclude or, you E 11 know, we should be able to conclude that the plant --
t E
12 we have reasonable assurance that the plant is in
)
l 13 conformance with the licensing basis. And that's an 14 important input into the restart assessment panel and
! 15 something that needs to be considered prior to the fact i 16 that we decide that we can go to the Commission and 1
\
l 17 recommend restart, if that happens. )
l 18 MR. DELCORE: But that's only one I 19 aspect. I mean you've got some other things in your --
i l lr 20 MR. IMBRO: Well, I mean -- but in order
! O
. 21 to reach that conclusion, we're going to have to do 1 h g 22 many inspections and close oversight of the Sargent &
3 l 23 Lundy process.
l 24 MR. DELCORE: What I'm really trying to i
POST REPORTING SERVICE
- l. HAMDEN,-CT (800) 262-4102
138 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 say is I don't understand -- it seems to me that the 2 ICAVP needs to be done before you can review the -- to 3 give you an example, if you're doing -- if one of your 4 350 checks for this assessment is that you have to 5 verify the FSAR and the updated FSAR, okay, well, I 6 presume that the ICAVP has to be done before you can do 7 that.
8 MR. IMBRO: Yes.
9 MR. DELCORE: So it seems to me that 10 this has to be done long before all these other checks.
R 11 Yes?
M 12 MR. IMBRO: But that's an important l G, y 13 output from the ICAVP. I mean the ICAVP is going to 14 provide insights into those areas. So when the ICAVP l
15 is done --
16 MR. DELCORE: You're not going to know 17 if a maintenance procedure or an operating procedure or
! 18 an emergency procedure is valid until you validated the 19 systems.
20 A VOICE: That's right.
O
< 21 MR. DELCORE: So all of that is going to 3
g 22 be checked after the ICAVP. I'm not sure that those l 23 charts reflect that.
24 MR. IMBRO: Well --
C)
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139 HEARING RE: MILLSTONE UNITS f"T APRIL 30, 1997
\~) i 1 MR. DELCORE: What I'm saying is the NU l 2 schedule that we looked at a couple of weeks ago I'm not sure really reflects that. It seems to me that 4 you're --
5 MR. IMBRO: I'm not sure, either, but --
6 NR. DELCORE: They're coinciding with 7 one another.
8 MR. IMBRO: I would say -- I would point 9 out, though, that part of the ICAVP, though, is to look 10 at procedures, at least insofar as have any design E 11 aspects or design restraints -- are they appropriately R
12 captioned and operating and maintenance procedures, 13 emergency procedures and that type of thing. So the 14 ICAVP is going to do some look at that.
15 MR. DET: CORE: Four systems, though.
16 MR. IMBRO: Well, four systems.
17 MR. DELCORE: Four.
I 18 MR. IMBRO: All right. Yes. Four I
- 19 systems.
20 MR. DELCORE: But I'm interested --
O
= 21 MR. IMBRO: Yes, Mr. Markowitz? I i 22 thought we'd moved off the RAP. I mean do you want --
g l 23 is this ICAVP's?
24 MR. DELCORE: Well, it was really f]~
\
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' 140 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 directed at the recovery.
2 MR. IMBRO: Okay.
3 MR. MARKOWITZ: I think this is back on 4 the Restart Assessment Plan. This is sort of tied in 5 to what happened this afternoon. There was a lot of I l 6 data presented and key performance indicators and a 7 whole bunch of stuff. And I kept waiting to hear the 8 phrase that I'd heard at an earlier meeting that I 9 think is part of the Corrective Action Verification 10 Program or the restart process and I'm not sure. I l
, 2 11 think it fits in with the Corrective Action R
l 12 Verification Program as a prereq and it didn't get O 13 mentioned today.
l I 14 I'm not sure I understand it that well, 15 to begin with. But it would be nice to hear it or at I
16 least hear how it's being tracked or how you're i
l 17 assessing it. And the words I was listening for were l 18 "the 19 topical areas." And I don't even know what
!I - 19 that means. But it sounds like it's something that is 20 not -- wasn't tracked on any of those graphs we saw O
. 21 this afternoon. Maybe it was but wasn't covered.
I 22 g Could somebody talk about that and how that -- how l 23 you're tracking it or how NU is tracking it so that i 24 it's included or not included? Thank you.
i O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 I
141 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 MR. IMBRO: We are not tracking those 2 areas per se. But let me tell you what they are.
3 Those are areas, for example, like consideration for 4 high-energy line break, effects of high-energy line 5 break, consideration of flooding effects, fire 6 protection, MOV program, set point control program, 7 environmental qualification, seismic qualification. I 8 mean those are some of the 19 areas. I don't know them 9 all.
10 But what we have told NU -- and, by the R 11 way, those are going to be reviewed as part of the 8
12 ICAVP. So we haven't really been tracking them except 13 to the extent that we told NU that "In order for you to 14 tell us that -- for you to say that the systems are 15 ready or you are ready for this -- in half the Group 1 16 systems to start the ICAVP, those topical areas need to 17 be completed for those -- for the first 17 wave-one l 18 systems for Unit 3, for example.
I; 19 So we're going to verify those as part 20 of the ICAVP. I mean the ICAVP contractor will and O
. 21 then we'll verify on top of that. But -- and that's g 22 how we'll assure they're completed.
l l 23 DR. TRAVERS: And the reason the 24 question was raised in the first instance was they were C~
POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
i l
i 142 HEARING RE: MILLSTONE UNITS l
) APRIL 30, 1997 1 not necessarily. planning to have those and we said -- :
2 MR. MARKOWITZ: I understand that. And l i
l 3 I guess what I'm suggesting is that last view graph !
4 that Buzz Carnes put up sort of suggested if you got l
5 any key performance indicators they ought to be 6 considering, then you've got a chance to say something.
1 7 It sounds like the 19 topical areas ought to be a key ,
8 performance indicator that they're tracking to be ready 9 for the Corrective Action Verification Program. That's 10 where I'm coming from. I R 11 MR. IMBRO: Yes. Okay. Good. Thank .
R 12 you.
13 Yes, sir? '
14 A VOICE: The Corrective Action i 15 Verification Program starts at the conclusion of the 16 discovery phase, which means the deficiencies 17 determined in the Corrective Action Verification 18 Program are not complete when it starts. Now I'll
- 19 segue into the Restart Assessment Plan.
Ir 20 MR. IMBRO: Okay.
O
= 21 A VOICE: And that is knowing that there l
l g 22 are "X" number of deficiencies, some of them are minor ll
! 23 24 things that like paint can be scraped on a valve off and or something others are like that relatively POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
143 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
(}
1 significant and serious and need to be corrected, how 2 in the Restart Assessment Plan are you going to handle 3 the assurance that, in fact, the corrective action has 4 been completed for those items that deficiencies were 5 found and then determining that, in fact, now that the 6 action is complete, in fact, we are complying with the 7 FSAR and the design basis?
8 MR. IMBRO: Well --
9 A VOICE: It's all interrelated, I know.
10 MR. IMBRO: Well, you're right.
R 11 Exactly. But I mean what the ICAVP contractor would do R
12 and what we would do also on a sample basis is to look 13 at the proposed resolution. In other words, you're 14 correct in saying the problem phase -- the discovery 15 phase identifies a problem. It doesn't necessarily fix 16 them. It says, yes, these problems -- this universe of 17 problems is ont there.
l 18 What the ICAVP contractor would do and
- 19 again what we would do is to look at the proposed l 20 solution to see that, yes, this really fixes the
- o 21 problem. But then we would l . also -- so when we -- we b
g 22 would first conclude that the solution to the problem l
lh 23 brings the plant back into compliance with the l 24 licensing basis. Then, of course, we have to go out O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
l 144 l
HEARING RE: MILLSTONE UNITS O ^r21' 2o. 1997 1 subsequent to that and then verify that, yes, this, in l 2 fact, has been implemented. So we'll do all of those 3 pieces.
4 A VOICE: Okay. Let's say that the 5 solution to the problem is a procedural change in how 6 the operators operate the pump, the valve, the set 7 points, whatever. Since that's a change in procedure, 8 that means there has to be training conducted for the l 9 operators on the change of the procedure, i 10 MR. IMBRO: That's right.
11 A VOICE: And they should know that 12 training -- have that training done before restart.
13 How are you monitoring and tracking that particular 14 aspect of it in the Restart Assessment to ensure that 15 the operators have been trained not only on what -- on 16 casualties and so on but also on changes and that 17 they're up to date on changes? Some of the procedures
! 18 may not be frequently-used procedures, so, therefore, I 19
- it's not something that's on the top of their head and i
e 20 that they memorize and know every day.
O
< 21 MR. IMBRO: I mean I would -- maybe the b
j 22 residents could answer this better than I. But I mean j h 23 I'll take a shot, that in order for them to close out i
l 24 the deficiency or to resolve the deficiency, to close A
i U POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
l 145 HEARING RE: MILLSTONE UNITS Q APRIL 30, 1997
)
1 1 out the change package, that training would be an item )
2 that needed to be accomplished. So they wouldn't be l 1
3 able to close that out. In other words, it wouldn't be 4 totally implemented, even though the hardware was there 5 or the procedure was changed, until training was 1
6 accomplished.
7 A VOICE: And are you going to be )
8 monitoring the training -- ;
9 MR. IMBRO: Is that right?
10 A VOICE: -- area --
R 11 A SECOND VOICE: Yes. That's right.
t R
{
12 A VOICE: --
to ensure that, in. fact, 13 that correction in procedure has been reflected in the 14 training programs so that the training programs are up !
15 to date? Is that part of the restart assessment? !
16 MR. IMBRO: I mean in an ideal world we l 17 look at everything. I'm not sure how -- you know, I'm I 18 not sure -- I can't tell you right now that for every I; 19 item we're going to pull the string all the way. I lr 20 think we'd look at a sample.
l i o l
= 21 A VOICE: Well, we're pulling a string i
g 22 on the four systems. So, therefore, you'd pull the l $ 23 string on anything that came up in those systems or 24 what came up in the vertical slide or the accident and i POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1
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146 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 material review that's the other part of the Corrective l 2 Action verification Program. I'm hoping that the 3 answer to'that is yes.
4 MR. IMBRO: We would run some corrective 5 actions all the way to_ ground. -- !
l 6 A VOICE: Well, when they operate a ]
1 7 recall program, that stuff gets fed into the recall l 1
i 8 program.
9 MR. LANNING: We would run some 10 corrective actions all the way to ground, which would R 11 include chasing every part of the corrective action for 8 !
12 that mod or for that corrective action.
O 13 MR. IMBRO: Maybe not every one, though.
i 14 MR. LANNING: But not every corrective ;
15 action for every system'necessarily.
16 MR. IMBRO: Right.
17 A VOICE: Okay. Earlier in the first l
l 18 presentation the comment was made that because of the i 1 19 training deficiencies that were found in Unit 1, that ;
20 there was some sort of -- if you want to call it -- the -
O l
. 21 way I read it and wrote it down was training shutdown.
.l 22 But we glossed over that. So I want to look at is g
-l 23 there a training shutdown in effect at Millstone so '
i '
- 24 they can revamp? That either you imposed or the 1-() POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
L 147 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 licensee imposed on themselves. And what is the impact ,
2 of that on restart?
3 MR. LANNING: There was a temporary i 4 interruption of the requalification process. Northeast ;
5 is still in the process of evaluating root causes for 6 why the training program has degraded to the point that 7 it has. I forgot your question. But requalification ,
8 --
9 A VOICE: How are you guys tracking 10 this?
R- 11 MR. LANNING: --
training is still R
12 ongoing. We're coming -- after they complete their 13 root cause analysis and implement corrective actions, 14 we will be coming in and assessing the bigger training 15 program, which would include license, Town license and -
16 other staff in the plant.
17 A VOICE: As part of that training l 18 program assessment, do you monitor the sessions, the, 1 19 for want of a better term, the casualty training 7
20 sessions that they do and the trainer and that sort of O
. 21 thing? Do you monitor operator action?
I 22 l g MR. LANNING: For sure. We even look at l 23 lesson plans, how they're presented, test results --
24 MR. IMBRO: OSTI would look at some of l
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I 148 -
) ARkL30 1 that, too.
2 MR. LANNING: Yes. And OSTI, the 3 operational safety team inspection, that comes at the 4 very end of this process would also look at operators 5 and other staff's readiness to operate.
( 6 MR. IMBRO: Yes.
l 7 A VOICE: Okay. Thank you.
l l 8 MR. DURR: Let me -- I have a dimension l
l 9 here that you may not be aware of. The operator ;
I i
10 training program is divided up into multi facets.
E 11 There is an initial training program where you bring 3
gg 12 pecple in who are novice and train them to be U
13 operators. That's license initial training. And then 14 there is upgrade training where you're already a-1
! 15 licensed reactor operator and you upgrade to be a 16 senior reactor operator. And then there's l 17 requalification training which is a periodic cycling of 1
l 18 the operating crews through refresher training. So
- 19 there's all these different aspects to training.
20 The ones that were brought into question O
. 21 on the 398 form, potential falsification, is initial ig 22 training and upgrade training. And the requalification l 23 training was kind of a moratorium put on it, if I'm not i 24 mistaken, until they assured themselves that the requal
, O)
\-
POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l
i 149 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 I
i 1 training was really doing what it was supposed to be l i
2 doing. !
3 So, as I understand it today, the requal l
4 training, requalification training program is pretty l
l 5 much intact. But it's this initial training and this l.
I 6 upgrade training where the anomalies were found. Am I 7 on target here? So you need to understand that there's 8 --
it's broader than just any training program. It's 9 multi-faceted and there's different aspects to it.
l 10 Okay?
E 11 MR. LANNING: Yes, sir?
12 MR. MARKOWITZ: I've got one more 13 question from this afternoon. And, Wayne, I think you 14 were the person that addressed it at the presentation 1
15 when Mike Brothers was giving the status report of Unit !
l 16 3. There was this leap of faith that got us from the )
17 10,000 NRC commitments to about 350. And I think you I 18 questioned the methodology or something associated with I. 19 that. But I never got a warm, fuzzy explanation. It ;
20 was sort of like it to be discussed later or -- where O
. 21 do you think that stands? In other words, this 10,000 l
g 22 commitment thought process at one point and now there's l 23 a tracking program for 350 and there's a delta there.
l 24 And I guess I --
POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
l l j l
150 l
' HEARING RE: MILLSTONE UNITS I us) APRIL 30, 1997 I
l i
1 MR. LANNING: I'm as confused as you 1
2 are.
3 MR. IMBRO: No. Let me answer that. I 4 think I know the answer to that. Let me give it a 5 shot. l 6 MR. LANNING: Okay.
7 MR. IMBRO: And I guess I -- what I --
8 as far as I understand, when you talk about the 10,000 9 or so commitments on the docket, those are licensing i
10 commitments. And so those are things like equipment E 11 needs to be seismically qualified, et cetera, a litany R
12 of things.
13 How they got the sub-set of 350 -- and 14 those other commitments are presumably things that have l
15 already been implemented. The 350 commitments were l 16 things that were owed to NRC, that were open, as yet l 17 unresolved or they owed us an answer on those items. ;
I 18 But I guess -- and that's how I understood how they I; 19 parsed that 10,000 into 350. It's not that those 350 h 20 r were not valid. It's not that they disappeared. At o
. 21 least that's how I understand it. But that the 350 I
g 22 were those that were still open, where there was i
h 23 information due to NRC that we needed to evaluate.
24 But, again, that's what I think.
f^)
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HEARING RE: MILLSTONE UNITS APRIL 30, 1997 l ,
1 MR. MARKOWITZ: Yes. I agree with -- I 2 think that was characterization that I was left with.
3 And that sort of led me to the question of who is going 4 to check? Who is going to at least --
is the third-
! 1 l 5 party Corrective Action Verification Program going to i
j 6 somehow get that data base and track it against 7 whatever the system is, the systems that are picked?
! 8 MR. IMBRO: Oh, yes. Yes.
i 9 MR. MARKOWITZ: I'm not saying that I 10 they're fibbing. I'm saying okay, that's a big number.
g 11 I guess I believe it, but I think I'm going to check, 12 you know, just to verify.
13 MR. IMBRO: Well, but I mean the first -
14 -
the first thing that the ICAVP contractor will do is 15 try and --
well, we need to ascertain what the I
16 licensing basis is for those systems or components and i 17 then verify. So, yes, I mean as many of those 10,000 I 18 commitments get captured by that system, I mean that I 19
- will test the implementation of those commitments. I'm 20 not saying it's going to hit all the 10,000 O
i a 21 commitments, l
I g 22 MR. CERNE: There's another significant l 'h 23 presentation in that. The 350 was being tracked as a 24 dated commitment. And the point being there is if you lO P)ST REPORTING SERVICE
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152 HEARING RE: MILLSTONE UNITS I~D APRIL 30, 1997 U
1 have a licensee event report or a violation or 2 something where they're telling us that they need to 3 initiate corrective action, they're telling us when 4 they're going to initiate that and they were tracking 5 the efficiency with which they were meeting those 6 dates. And, therefore, some were late, we're calling 7 the -- lateness. The 10,000 is the larger picture of 8 the licensing basis which constitutes commitments in 9 the way the plant is being built. And that's being 10 reviewed by the Configuration Management Program and R 11 checked by the ICAVP.
R g-) 12 MR. MARKOWITZ: I think that answers the v
13 question. I just wanted a warm fuzzy that there were 14 9,650 items that somebody --
15 MR. IMBRO: Dropped off the face of the 16 earth?
17 MR. MARKOWITZ: That didn't drop off.
I 18 Can I ask one final question? There was I
- 19 mention this afternoon about a 13 May meeting?
I e 20 MR. IMBRO: Yes.
O 1
. 21 MR. MARKOWITZ: What is that? Could you i$
22 just tell us so we --
lgl 23 MR. McKEE: Well, I was going to cover j 24 that whenever I get to my presentation. So if you'll ,
1
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153 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 just hold on. .
2 MR. MARKOWITZ: Okay.
3 A VOICE: I have a few questions I'd 4 like to ask you.
5 MR. LANNING: Is this on the Restart 6 Assessment Plan now?
7 A VOICE: Correct.
8 MR. LANNING: Okay. Good. ;
9 A VOICE: On the Restart Assessment 10 Correction Plan, are you going to be looking at or 11 assessing the reliability of any computer software 12 programs or whatever computer software programs NU has?
13 Is that part of your plan? '
! 14 MR. LANNING: I think the answer to your 15 question is I don't think we'll be looking at any 16 reliability of computer programs. None that we know 17 of.
(
I 18 A VOICE: Well, I'm a reliability l
l- 19 systems engineer. One of the problems, of course, is l :
20 software reliability. It's a major problem. And the l0<
l 21 question is is anybody looking at how reliable their l
_g 22 software is? Something should be at least spot-4 l 23 checked, sampled. I think it's --
24 MR. LANNING: There are safety-related O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l
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154 HEARING RE: MILLSTONE UNITS
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l APRIL 30, 1997 ).
I 1 software that performs a safety function, maybe like on !
i 2 the CE protection system. That has been looked at i 3 previously for reliability and accuracy and such --
4 A VOICE: The gist --
1 1
5 MR. LANNING: I don't think -- l 1
6 A VOICE: The gist I get from you is it '
7 hasn't been. I kind of think you're a little caught !
l 8 unawares right now.
9 MR. LANNING: No. I'm trying to answer 10 your question. No. I'm trying to answer your R 11 question.
8 12 MR. DURR: Standard engineering programs 13 have been benchmarked.
14 A VOICE: Does that include software !
15 engineering?
16 MR. DURR: Yes. ;
17 MR. LANNING: Yes.
l ! 18 A VOICE: For analysis, yes.
1
- 19 MR. DURR: Yes. There are -- the NRC i
e 20 has run independent programs to validate some of these o
i
. 21 things.
I g 22 A VOICE: Well, when you say independent l l 23 programs to validate, are you using their actual 24 software?
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155 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 MR. DURR: For ins:ance, we have a j 2 program for fluid mechanics that is pretty much 3 recognized and everybody uses.
4 A VOICE: Well, what does that mean? l 5 You have a program for fluid mechanics. We're talking 6 about what Millstone has. l l
~
7 MR. DURR: Yes. But the utilities use 8 these programs. 1 9 A VOICE: Are they using that program?
10 Is that what you're saying? j g 11 MR. DURR: This specific one? I can't a '
- 12. answer that. I don't know the answer to that.
O 13 A VOICE: Well, that's the questions I'm l
l j
14 asking.
15 MR. DURR: What I'm trying to tell you 16 is that there are recognized engineering programs out 17 there that are validated by the NRC.
I 18 A VOICE: Yes, there are recognized 1
19 engineering programs. But the question comes down, 20 have those programs been modified in any way? And are O
. 21 they being checked to ensure -- are they being checked g 22 to ensure that they're up to whatever revisions? See, l 23 this is the point I'm making. I think it's an area ,
24 that needs to be looked ric and included in the ICAVP. i
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l i 156 7 HEARING RE: MILLSTONE UNITS (g APRIL 30, 1997 1 MR. IMBRO: I would think that -- but I I
2 think -- I don't think, I know that the ICAVP, a part 3 of their function is to look at the analysis techniques 4 of computer programs that are used to do the analyses ;
5 to assure themselves that it's an approved method, that l 6 it's an NRC-approved code.
I 7 A VOICE: Analysis techniques does not 8 mean that the computer software and the programming of 9 that software is reliable within certain confidence 10 limits. That does not guarantee that. What you're g 11 telling me is that there's analyses. Well, yes, there 12 is analysis, but --
13 MR. IMBRO: Well, but the analyses is 14 done by computer code. For example, if they model the 15 LOCA, loss of coolant accident, then those -- they 16 would have to verify that that was done with an NRC-17 approved code.
I 18 A VOICE: Well, let me just say this.
1 19 Okay? Let's say you have a computer software program.
20 MR. IMBRO: Yes.
o
. 21 A VOICE: Essentially it deals with I
g 22 zeros and ones.
l 23 MR. IMBRO: Yes.
l l 24 A VOICE: Let's say zero for --
l (m") POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l
157 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 A SECOND VOICE: The mike. Use the 2 mike.
3 A VOICE: I think you could hear me.
4 Can't you?
5 MR. IMBRO: But they can't. They can't 6 hear you.
7 A VOICE: Oh, you can't. Oh. They 8 can't hear me. Excuse me.
9 Hello. Hello. Can you hear me?
10 Let's assume that you have -- and I'm E 11 just being simplistic right now. Let's say you have R
12
() 13 strings reason of zeros a zero is out and ones.
of place.
And let's say It's for some either not a 14 parity or it's just not -- for some reason someone 15 changed something. Who is going in to verify and check 16 to make sure that that software program that's being 17 used -- on a spot-check basis. You're not going tc l- 18 check every software program. That what's supposed to
- 19 be programmed is, in fact, there and that's the way lr 20 it's occurring? It doesn't seem like in your program i o
.. 21 here you're doing that.
I g' 22 MR. IMBRO: No. We weren't going to do ll 23 that. But what we were going to stop at was to verify 24 that the analysis that they have done, that were done,
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v APRIL 30, 1997 1 were done with approved models, approved NRC codes.
2 A VOICE: Well, what I --
3 MR. IMBRO: But I would also say that --
4 I mean just -- I mean although we're not going to 5 verify this, all the computer programs have a 6 configuration control --
they're configuration 7 controlled, also. They fall under Appendix B. Any 8 changes made to them need to be documented. There 9 needs to be traceability.
10 A VOICE: So we're --
R 11 MR. IMBRO: I don't think we're going to R
gs 12 look at that. I
\~)
13 A VOICE: You're not going to look at 14 that. Well, that could be a major glitch because 15 everything, from what I --
16 MR. IMBRO: But all the changes would 17 have had to have been approved by NRC. So I mean I l
l 18 guess I would -- I would rely on the fact that NRC had l
. 19 previously reviewed those codes -- l 20 A VOICE: Well --
0
. 21 MR. IMBRO: --
and as long as I have k
22 confidence that they're using those codes, then I guess l 23 I would leave it at that, without going any further.
24 A VOICE: But what you're saying is POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
159 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
(~)'
1 you're not guaranteeing me that those things are on 2 line the way they should be. You're saying you're 3 presuming, you're assuming, but you don't know for a 4 certainty because you're not -- in your plan, you don't 5 have any provisions for spot-checking their computer 6 software to give you any confidence that those computer 7 systems are okay. Because, let's face it, most of NU, 8 most of its operations is computer-based.
9 So it would see to me that a fundamental 10 question that has to be answered is to make sure that R 11 the computer software programs are what they're K
73 12 supposed to be.
V 13 MR. IMBRO: Are you talking about 14 software to control equipment or software for analysis?
15 A VOICE: All the software of the 16 computer.
17 MR. IMBRO: All software.
I 18 MR. DURR: And engineering analyses I 19 typically -- Appendix B requires a design review. And 20 within the design review process, you do that by an o
. 21 independent check method.
g 22 A VOICE: But --
l 23 MR. DURR: So you get some reasonable 24 assurance that you're in the ball park. Although you O
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i 160 HEARING RE: MILLSTONE UNITS
( ). APRIL 30, 1997 1 don't do a detailed analysis that will get you the same 2 answer, you get a -- you do an independent analysis _to 3 get you in the ball park that says, yes -- you do a l I
4 sanity check on that --
5 A VOICE: Well, let me ask you a very 6 simple thing. Let's make it very simple. Let's make 7 it very simplistic. If you were to go into NU today, 8 Millstone 1, 2 or 3, I don't care, and you were to go !
9 to a specific system which is computer controlled, it 10 has software, it has manuals, tech manuals, so forth i R 11 and so on. Can you guarantee --
8 ,
12 MR. IMBRO: I'm not so sure that they ,
13 safety-related software, though. Do they? ;
14 MR. CERNE: No.
.15 MR. IMBRO: No , they don't. You're 16 doing with 1960's technology here is what you have to 17 understand.
l 18 A VOICE: No. I'm dealing with 1997 1 19 technology. '
20 MR. IMBRO: But they don't have it. The l O j . 21 plant's built ten years --
l= 22 A VOICE: There's got to be some kind of l 23 soft --
24 A SECOND VOICE: There isn't safety-O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 !
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l 161 l HEARING RE: MILLSTONE UNITS APRIL 30, 1997 l
1 related software.
2 A VOICE: There's got to be. Are you 3 guar -- the question is are you guaranteeing --
4 MR. IMBRO: I would defer to the !
5 residents because I don't have as much direct knowledge 6 as they do.
. 7 MR. CERNE: My perception is you're l .,
8 dealing a little bit in apples and oranges. And I'm by l l
9 no far means an expert in this. But in the area of l 10 engineering design, which is what Gene is talking to, 1
11 there are safety-related programs that are used in i
12 designing the systems, modeling the systems, checking 13 the systems and those are approved by the NRC, as was 14 mentioned.
15 In the operation of the plant, the plant ]
16 computer is not safety-related. The operators use it 17 but don't rely on it bottom-line if you lose power and l I 18 have other -- you have other indications, hard-wired I i
I 19 indications, in the procedures directly to them and you l l
20 run the plant in a safety-related sense in accident O
. 21 scenarios and events without reliance or without the g 22 need of the plant computer. In that sense, plant
!l 23 computer software is not safety-related.
24 MR. IMBRO: It's used to log data many O
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i l 162 I
A RkL 1 times.
2 A VOICE: Well, when I'm talking about' i 3 the computer software, I'm talking about all the 4 manuals for operation of the computer, whatever they 5 may be, the actual program --
t 6 MR. CERNE: The plant computer in the 7 control room is not safety-related.
8 A VOICE: It's not safety-related. So, 9 therefore, you're not going to look at it.
10 MR. IMBRO: That's right.
R 11 DR. TRAVERS: Right.
12 A VOICE: Okay. Now, I have another two 13 questions. It says here --
14 MR. IMBRO: Well, I mean but there would <
15 be no need to because it's not relied on by anybody to ;
i 16 do any safety function. So it's not an issue where the i i
17 health and safety of the public could be jeopardized by l l 18 it. Okay?
l l' 19 A VOICE: Would the public safety be 20 jeopardized --
O
. 21 MR. DELCORE: Well, end cores are run i I l g 22 off the computer and that's the basis for your thermal
!l 23 limits and the basis for your trip set points on the
- 24 RBS.
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163 ;
HEARING RE: MILLSTONE UNITS
(} APRIL 30, 1997 .
1 A VC:lCE: My point is if'a computer --
2 MR. DCLCORE: That's a main computer.
{
3 A VOICE: My point is if a computer is 4 being used to operate something and if that computer 5 goes down and it's a safety-related system, it could be '
i 6 -- it could create serious problems. !
7 MR. IMBRO: I agree.
8 A VOICE: Well, that's the point I'm -l 9 making. And it's -- l 10 MR. IMBRO: But the point is it's not i
R 11 safety-related. I mean let's --
8 .
12 A VOICE: All right.
13 MR. IMBRO: Let's move on please. '
14 A VOICE: The next question I have, it' 15 says you're going to review past maintenance 16 activities. You're going to check maintenance i 17 procedures for technical accuracy, so forth and'so on. !
18 Okay. One of the things involved with maintenance, of !
I
- 19 course -- and I suspect some of your safety systems in 20 terms of maintenance are time-critical. In other 3
. 21 words, there is a certain amount, a window of time 22 where it's absolutely essential that those repairs be g;
l l 23 initiated and completed. What are you going to do to =
24 verify mean times to repair those systems to see if O. POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i L
I
164 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 b)r 1 they're within any limits of analysis?
2 MR. IMBRO: I guess I don't know how to 3 answer that question.
4 A VOICE: The question is are you going 5 to check times to repair?
6 MR. LANNING: We ensure -- the plant 7 ensures that plant equipment is available pursuant to 8 technical specifications, for example. The OSTI, the 9 operational safety team inspection, will be looking at, 10 for example, the time equipment was out of service, for 2 11 example, maintenance procedures to repair that 2
12 equipment, as part of its looking at the Maintenance 13 Department, for example, and its readiness to support 14 operations.
15 A VOICE: But the question is has anyone 16 at Millstone ever done a mean-time-to-repair analysis 17 of different systems or sub-systems? I suspect they l 18 must have.
l
- 19 MR. LANNING: I don't know.
l 20 A VOICE: The safety-critical systems O
. 21 especially. Time is -- you cannot deny that time is of I
g 22 the essence in repairing certain --
l 23 MR. LANNING: Yes. That's part of the 24 maintenance role and it's characterized as availability ,
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APRIL 30, 1997 1 cf safety-related equipment I think is the answer to 2 your question. I think -- ;
3 MR. DURR: No. It's reliability-4 centered maintenance is what you're talking about.
5 MR. LANNING: Yes.
6 A VOICE: No. It's maintainability.
7 Maintainability is mean time to repair. And the 8 question is --
9 MR. LANNING: Availability --
10 A VOICE: That's part of availability.
11 Availability has two components, reliability and 12 maintainability. .Okay? That constitutes availability.
13 The question that I have is you have analysis, I 14 suspect, for mean time to repair. There's certain 15 windows. Some things repair things faster than others, i 16 In a safety-related system where time is critical to 17 repair -- okay? Time is critical to repair -- are you
! 18 doing any check to make sure that the Millstone
-19 operators can repair those systems in the allotted time h
r 20 required?
O
= 21 MR. IMBRO: It's controlled by tech
, b l
g 22 specs largely.
l 23 DR. TRAVERS: Yes, we are. And in the i 24 most critical sense for those --
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I 166 l HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 A VOICE: But I don't see it in the 2 ICAVP here.
3 DR. TRAVERS: Well, it's part of their 4 license.
5 A VOICE: But I don't see that in here
, 6 as part of the license. It's not been identified. I l
7 MR. LANNING: It's part 350
( of the 8 process in looking at whether or not they meet all 9 their technical specifications for operations.
10 A VOICE: Well --
lE 11 MR. LANNING: Whether they meet all R
12 their mode requirements.
( 13 A VOICE: Well, how about specifying it 14 as a detail in here instead of just saying it --
15 because all I have right now is your say-so. But I 16 don't see it in this document here.
2' MR. LANNING: Well, we could expand the l 18 line item that talks to --
I
. 19 A VOICE: I think that would be a very 20 good idea.
O
. 21 MR. LANNING: --
technical g 22 specifications, i
l 23 A VOICE: I think that would be a good 24 idea. Then it says that you're going to -- you're j.
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167 HEARING RE: MILLSTONE UNITS O APRIL 30, 1997 V
1 going to use criteria, selection criteria, for 2 approximately 10 systems. That's on Page 22 for 3 Millstone 1, I think it is. Yes, Millstone 1.
4 MR. IMBRO: What are you reading from?
5 A VOICE: This document here says 6 Independent Corrective Action Verification Program, 7 Millstone Unit 1, on Page 22 -- on 22 it says "These 8 criteria would be applied to the list of approximately 9 20 systems for which the NU line organization and NU 10 oversight organization will have completed their 11 review." And it says Sargent & Lundy's system 12 selection criteria.
13 The question I have is this system 14 selection criteria. Okay? Because everything we're 15 talking about in terms of the availability of the i
16 system is probability-based. So is there any ;
l 17 statistical analysis that's being used by Sargent & ;
i l 18 Lundy to make a determination that these are the 20 l l
- 19 systems that should be looked at? Or is the selection 20 criteria statistical-based?
O
. 21 MR. IMBRO: No, it's not statistical- I h
g 22 based. But, again, we, NRC in combination with NEAC l l 23 are going to select the systems. And at least for our 1
l l 24 part of the selection and I guess for the systems we
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i 168
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HEARING RE: MILLSTONE UNITS
) APRIL 30, 1997 1 identify in terms of the population of systems that we i
2 feel are reasonable to do an ICAVP on, we would use 1 i
3 rirsk insights. So those would be systems that are most 4 important to risk --
l 5 A VOICE: You say risk insights. But is l
6 that statistical-based risk insights? )
7 MR. IMBRO: I supposed. It's 8 probablistic in terms of probability to core damage.
9 What's the contribution of a system 'to core damage 10 frequency?
E 11 A VOICE: But is that probability-based?
, R 12 MR. IMBRO: Yes.
13 A VOICE: It is?
14 MR. IMBRO: Yes.
l 15 A VOICE: Do you have those analyses l 16 available for the public to'see? Is the selection 17 criteria available to the public?
-l 18 MR. IMBRO: The selection criteria, yes. l
- 19 In fact, it's probably articulated in the Commission. i 20 Paper. I'm not sure - I think we're talking past each O
= 21 other.
g 22 DR. TRAVERS: We're talking past each l 23 other.
24 A VOICE: So is t he selection criteria POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 ,
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169 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
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l 1 statistical -- probability-based? You said it is, i
2 DR. TRAVERS: In part.
3 A VOICE: Now it's in part?
4 DR. TRAVERS: Yes. What we have l 5 indicated and what we intend to do is select the
.6 systems, identify systems that NEAC may choose to 7 select as well based on a number of factors. One is 8 risk significance. What is their safety import in the j 9 overall when you compare systems that are important to 10 ensuring against core damage accidents or core damage?
E 11 Secondly, we indicated in the Commission
-12 Paper that we would use another factor and that is, for j 13 example, how many modifications to the system have been 14 made over time since the plant was constructed? That 15 would be a factor in how the configuration management 16 has been maintained over time.
17 Another factor we said we would utilize
! 18 is how many of the technical disciplines might be t
- i. 19 needed to assess that system. We said, well, let's not 20 look at simple systems, but let's look at systems that o
. 21 have multi-disciplinary issues that would be explored I 22 g in the conduct of the ICAVP or firstly in the l 23 licensee's own CNP.
24 Now, when you ask the question about l
l
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- 170 HEARING RE
- MILLSTONE UNITS 4-
) APRIL 30, 1997 1 ,
1 risk significance, the utility uses risk significance -
2 in the development of a probablistic risk assessment 3 for every unit which they have. I don't know what 4 level, Level 1, 2 or 3 they have it, but --
5 A VOICE: That's Level 1, I think.
6 DR. TRAVERS: Level 1 at least. But-7 we're looking at it as well. I mean we're going to 8 select the systems. We have the PRA. I don't know if I
9 it's on the docket or not. But we are looking at the 10 safety import of the systems --
i E 11 A VOICE: The IPA's on the docket.
E i 12 DR. TRAVERS: The IPA's on the docket. i 13 Okay. So the probablistic risk assessment for 14 Millstone units is available on the docket. And we 15 expect to -- we are using that in our thinking on which 15 systems we would ultimately select.
17 A VOICE: Okay.
l l 18 DR. TRAVERS: As one factor. ;
l
. 19 A VOICE: Okay. Thank you.
20 MR. LANNING: How about this gentleman l 0 l
. 21 back here who hasn't had a chance to speak? Do you ;
I g- 22 want to come up and use the mike pleatte, sir? And sign l 23 in please.
24 A VOICE: I'd just like to make one O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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171 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 brief clarification in regards to what the previous 2 fellow was talking about. And that's I think if you 3 sit there a moment and think, in fact, you do have l
4 safety-related systems or hardware at all three plants 5 driven by software in computers. You know, Rivelis, 6 ICCM are two that just come to mind. The emergency 7 system, your dispersion software and hardware I suspect 8 is another. ,
1 9 And having said that, perhaps to put I i
10 some of the words in your response, for those systems 11 they're all redundant. The software has been checked.
12 It's been benchmarked, et cetera, et cetera. So it's g-)s 13 not that the software sits there with no analysis.
14 MR. LANNING: Okay. Thank you. I I
15 All right. Yes. Sure. Mark Halloway.
16 MR. MARK HALLOWAY: Good evening.
17 MR. LANNING: Good evening.
I 18 MR. HALLOWAY: I was looking over the 1 19 Significant Items List from the restart plan for Unit 3 20 and I have a couple of questions for clarification.
,' O
< 21 Item 2 says " Determine FSAR status before restart."
b g 22 Now, to me, that's kind of ambiguous. So maybe one of l 23 you gentlemen could explain exactly what you mean by 24 that.
POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l
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172 HEARING RE: MILLSTONE UNITS
) APRIL 30, 1997 1 MR. LANNING: One of the things they 2 have to do is update the FSAR. One of the things they 3 have to do as a result of the CNP program and ICAVP is 4 update their FSAR. And the purpose of this line item 5 is to -- there's a place holder for us to go and look 6 at the adequacy and completeness of where they are in 7 terms of updating their FSAR.
8 MR. HALLOWAY: Well, it says determine 9 status. It doesn't say full update or update. Are you 10 going to require that FSAR to be fully updated before lm 11 restart?
pg 12 MR. LANNING: I think Unit 3 has V
13 committed to updating the FSAR up to some period of 14 time before restart, yes.
15 MR. CERNE: Yes. They've agreed to 16 update the FSAR in June of this year and then bi- 4 17 monthly after that. Obviously, there's a cutoff
! 18 between -- some time before restart you have to have 19 some reasonable -- they typically update their FSAR ,
!r 20 annually. Their normal annual update is in June.
O
< 21 They're going to update it again this June and then bi-G 22 monthly after that until there's some point before s
l 23 restart where you have to have a cutoff and then you go l
24 back to the normal annual updates.
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173 HEARING RE: MILLSTONE UNITS
(]} ' APRIL 30, 1997 1
I 1 MR. HALLOWAY: So when you restart, you 1
2 will look at this to -- l l
3 MR. CERNE: Yes.
I 4 MR. HALLOWAY: Before restart, you'll I
( 5 make sure that this is updated.
6 Another item that is listed here is l
7 closed and I was unsure exactly whether it was or not; 8 is the -- and I've read a little bit about it recently o 9 -- is the feed water hammer problem. This says --
10 MR. LANNING: What number are you on?
R 11 MR. HALLOWAY: That's ' Item'No. 29, Page l 12 30.
(2) l 13 MR. CERNE: The feed water hammer issue 14 that was addressed as the reference which is the issue 15 that happened I think back in like '95 and then they 16 had another repetitive issue earlier in '96, those two 17 inspection items have been closed. Yes.
l 18 MR. HALLOWAY: Okay. So this doesn't
. 19 refer to the -- any hammer problems with the recirc 20 spray valve?
O
-. 21 MR. CERNE: Not the recirc spray system.
ll
- g. 22 As a matter of fact, if you go to Item No. 85, in the l 23 references there we talk about other RSS and related j 24 design basis concerns. Within that large set. of 1
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l 174 HEARING RE: MILLSTONE UNITS
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1 references there'is the one you're talking about.
2 MR. HALLOWAY: Okay. So that's part of ,
3 that.
4 MR.'CERNE: And that one is still open. i i .
L 5 MR. HALLOWAY: C Nr' Thank you, l-6 MS. LUXTON: I'm talking about -- I'd t-l 7 like to talk about the Restart Assessment Plan. I have l 8 a couple of questions. Employee Concerns, 3.8, ,
l l
9 Employee Concerns. I'm talking about hiring an
- - s i
10 independent oversight body, which we know is now Little .
i R 11 Harbor Consultants.
R-6 12 I've wanted to know that -- I'm hopeful t
13 that this independent oversight does the job that the 11 4 order established them to do because I'm getting calls 15 still. I just got another call today -- yesterday, 16 concern. Okay? Which means that Employee Concerns 17 Tssk --
Employee Concerns Program newly, you know, I. 18 organized program is still -- it has a ways to go, 1
- 19 obviously, if I'm still getting a call. I haven't 20 gotten very many lately, but I did get one again O
<- 21 yesterday. So I -- just a comment.
k 22 MR. McKEE: Okay. And I'll be
{
l l 23 providing, when we get to it, some status and some of 24 those items. But I agree with you. And we recognize l-O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 I
175 HEARING RE: MILLSTONE UNITS O ^ea 3o' 1997 1 that it will take some time for that program to get in 2 full speed and to resolve --
3 MS. LUXTON: Right. Well, you know, 4 I've met twice with Little Harbor Consultants, the 5 Citizens Regulatory Commission, recently. And we will 6 meet again -- I meet with Billie Garde. And we're 7 going to meet with the -- an additional meeting with 8 more of the consultants, Little Harbor. So, you know, 9 I'm hopeful that things will go well with that. I 10 think that is going to be certainly advantageous for us 11 in the public and for employees if it works the way I p 12 hope they're going to have it work, d 13 All right. So the next thing I have is 14 -- and it's related to this concern that came in to me i 15 yesterday. And I'm not really clear on it yet. I need 16 to have more information. But this is a question that 17 I have about -- directly related to that.
! 18 Okay. There has been some concern that
- 19 there's inconsistent safety criteria, inconsistent 20 safety criteria on all three units. Are all three o
. 21 units held or -- I guess the word is not held -- but b
g 22 put up to the same margin of safety, each one? Because l 23 I received info yesterday which implied to me that 1 24 there are different safety standards being applied at b' POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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176 l i HEARING RE: MILLSTONE UNITS '
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1 each unit. Now, I know that's very broad of a l 2 question, but --
1 3 DR. TRAVERS: Each of the units has its 4 own individual licensing basis.
5 MS. LUXTON: Until I have more specific 6 information and I'll ask you once again -- but do you 7 understand that generally?
8 DR. TRAVERG: Each of the units has its l l
9 own individual licensing basis. And you might ask, 10 well, why might they differ in part? They differ in '
2 11 part because of the time frames when they were R
12 licensed. Some of the requirements that have been 13 developed since were not applicable at the time, for le example, Unit 1 had already been licensed. l i
15 Now, that having been said, what.is done i'
16 when new requirements are implemented at NRC is we look 17 backward at each and- every unit that's been licensed
'I 18 previously to make a judgment on whether those I 19 requirements should be back-fit on the older units.
20 MS. LUXTON: Okay.
O
. 21 DR. TRAVERS: And so in each and every
-1
.g 22 case where a new requirement comes up over time, that l 23 analysis is done to make a judgment about whether or 24 not it's a fundamental safety issue for that old plant O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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l 177 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
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1 or simply an enhancement that should be considered l 2 based on cost, risk / cost benefit. And so that's the l
3 reason why in some instances requirements that have l 4 been developed over time might not be applicable to an i 5 older unit. But each -- fundamentally, each unit has l l l 6 its own licensing basis. The fundamental basis is set 1
7 for each individual unit.
8 MS. LUXTON: Okay. Okay. I think I ,
9 need more information on this to clarify what he said.
10 But -- because he seemed to imply that -- I can't. I E 11 can't say it. I'll have to wait on that. Okay.
i E
12 I think I'll wait until the
.O 13 miscellaneous questions come up for my other questions.
14 Okay?
15 MR. LANNING: All right. Okay. We'll ;
16 go into more questions.
17 Okay, sir.
! 18 MR. DELCORE: For Unit 2 at least, the
- 19 computer is used in many safety-related aspects of the 20 plant. To name a few, a calimetric calibration, feed o
. 21 water steam flow. It's also used for the total b
= 22 megawatt output and the INCA program is used to correct l 23 the high-power trip, power to flow set points and so 24 forth. So there's a significant amount of the computer t
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i 178 HEARING RE: MILLSTONE UNITS
.( ) APRIL 30, 1997 1 that is safety-related and that is used on a daily 2 basis. So, therefore, somebody needs to take a look at ,
3 them.
4 Additionally, just off the cuff, most of 5 --
all the radiation monitors at Unit 2 are l 6 microprocessed and have their own programs. And 7 they're all safety-related. They're all SP procedures, 8 every one of them.
9 MR. CERNE: But what you have to 10 differentiate is we're not saying the computer isn't 2 11 used in normal operations and therefore they're not 12 important and they're checked in operating licensing 13 functions and so forth. The term safety-related means 14 hard-wired signals to a safety function, like through a 15 solid-state protection system. If you have a high-16 containment pressure signal that goes to the solid-17 state protection system and actuates an engineering I 18 safeguards feature. It may also to an isolation 19 amplifier -- what separates it from the non-safety --
i e 20 go to the enunciator on the control room board. That's
! O
< 21 not safety-related. That light coming on is not i 22
- g. safety-related.
l 23 MR. DELCORE: I understand.
l 24 MR. CERNE: The signal to the computer l
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l-l 1 is not safety-related.
l 2 MR. DELCORE: I understand that, too.
3 MR. CERNE: Okay. And the programs 1 4 you're talking about, the software programs are not l 5 safety-related in the sense that they're relied on for 6 mitigation --
7 MR. DELCORE: They are.
8 MR. CERNE: They're relied on -- l 9 MR. DELCORE: The INCA program for the 10 in-core detectors is 160 in-core rhodium detectors at 11 Unit 2. All right? And there are four rhodium 12 detectors in each rhodium assembly. And they supply 13 inputs to a program in the computer which ultimately 14 develops an INCA fudge factor which is applied to the 15 power range drawers on all four of those safety 16 channels, which ultimately determines the total power 17 output which tells the reactor when to shut down in an l 18 accident condition. It is, therefore, safety-related 19 because the calculation that's being used for that
!r 20 calimetric adjustment on a weekly basis for 2401e is O
- 21 coming from that program.
1-g 22 MR. BEAULIEU: Could I respond? You're l 23 right.
24 MR. DELCORE: I know I'm right. I've
!O l
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_m 180 HEARING RE: MILLSTONE UNITS
- () APRIL 30, 1997 1 done enough of them.
2 MR. BEAULIEU: If the computer fails, 3 that function can be performed manually. And they have 4 procedures to do it. So in that sense, it's not 5 safety-related. That's a true statement that the 6 software is not safety-related. However, if that 7 software is incorrect or the inputs into that software 8 are incorrect, operators are using that software on a 9 daily basis as sort of an operator aid, if you will, to 10 perform like the calimetric calculation. So if it's R 11 wrong, it's affecting a safety-related --
so it's R
12 important that the inputs are controlled and it's QA-13 checked and it's double-checked. You're right. And, 14 in fact, I have an unresolved item to address that 15 precise issue because I had the same exact question.
16 And it's still open. It's still open. Buc you're 17 right.
I 18 MR. DELCORE: Well, if you look at, you 5
l 19 know, throughout the plant, there's a lot of those type ir 20 issues that I think -- and I think that the gentleman O
< 21 that spoke about computer programs and computers to be g 22 verified, there's a legitimate reason for that, I l 23 really believe. I mean I've got the experience of I
l 24 working there. And I think there's a lot of items
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I 181 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 l 1 where those calculations are used constantly. And if l
- 2 they're .using them and they're applied to a safety-3 related procedure -- and as I recognize -- and it may 4 have been changed since I've been there. I haven't 5 been there since '91. But SP-2401e used that input 6 directly from the computer, used that calculation. And 7 I don't think there's a manual method in the procedure 8 to calculate it. That's all I'm saying. I don't know 9 if it still exists.
10 But, anyway, the point I'm trying to 11 make to you is that somehow there needs to be a 12 verification of that stuff and the NRC -- and I want to 13 get it on the record because I think it needs to be.
14 MR. LANNING: Okay. Any other 15 questions?
16 We want to move into Employee Concerns i l
17 status.
l
! 18 MR. McKEE: Okay. I know there were a 19 few questions earlier. Finally I get my turn here. I 20 just want to provide the status relative to two major O
= 21 elements of the NRC order that was issued on October 24 l
g 22 relative to Employee Concern safety issues at Millstone ll 23 Station.
24 And the first item deals with the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
182 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 licensee's comprehensive plan for handling employee 2 safety concerns. And that is one that was required to 3 developed and submitted to the NRC for NRC's review.
i 4 That plan was submitted in January 31. It contained 5 reference to additional things that had to be developed E
6 and those included some additional action plans in 7 specific areas. And we received some of those 8 additional sub-action plans.
9 The comprehensive plan was discussed at I 10 some previous public meetings. We did have -- staff E 11 has reviewed it and we included some members of the -- l 8
12 in that review of the independent --
Millstone 13 Independent Review Group. It was a review group 14 earlier led by John Hannon who looked at some employee ]
15 concern areas.
16 Following that review and comments that I 17 we received, we provided some questions and comments I. 18 regarding the comprehensive plan to the licensee. And I
- 19 the main purpose of that, since our job in this area is 20 to review the plan not to approve it necessarily, is we o
. 21 schedule -a meeting. And that's one meeting -- and I'm
-l g 22 going to discuss another meeting -- that we're having l
'l 23 the morning of May 13. And that meeting -- there's a 24 meeting -- it's going to be from 9:00 to 12:00. And it
!O l
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183 HEARING RE: MILLSTONE UNITS i
({} APRIL 30, 1997 l 1 will be specifically to discuss and for us to 2 understand some of the details and elements of the
! 3 licensee's plan for dealing with employee concerns. So l 4 that's one meeting. And I'll get to another one 5 shortly.
6 The second major element of the order 7 was the third-party oversight organization. And that's 8 the oversight organization that Dr. Travers mentioned 9 earlier, referring to -- that's going to review the 10 effectiveness of the licensee's implementation of their R- 11 plan and also gauge the performance of that R
12 implementation.
13 And with that, the NRC is supposed to --
14 is required by that order or specified in that order to 15 approve the organization and also, once we approve the 16 organization, approve the audit plan submitted by the 17 organization.
I 18 And the organization was proposed and I
- 19 sent to us December by -- December 23. There was some 20 supplemental information on that. And tnat --
the O
. 21 proposed organization was Little Harbor Consultants, b
g 22 That matter, too, and some of those elements on the l 23 organization were discussed at public meetings.
24 We had interviews by phone with the O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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184 HEARING RE: MILLSTONE UNITS l
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! 1 proposed members of that team and did some additional 2 reviews. We approved Little Harbor Consultants as the 3 organization to do the third-party reviews in a lettar
! 4 and correspondence dated April 7 recently. And I might 5 add with one exception in there, we approved the 6 organization and we did also approve relief to one 1 7 provision in the order that indicated that the team l 8 should not be composed of anybody with previous direct l
9 experience. There was one individual that had that l l
l 10 experience that -- well, actually, there was two. But iE 11 there was one that they proposed because of various l 12 reasons to be important to the completion of that task. !
(:) i 13 We reviewed that. We agreed with that licensee in that l 14 area because it dealt with somebody that had some 15 experience from kind of an employee perspective and 16 employee concerns. And we provided relief for that
! 17 individual to be a member of the team.
l! 18 And now it stands that once we've
!- 19 approved the organization, there's a 30-day time frame
-j !
r 20 for that -- for Little Harbor to provide us with their o
< 21 proposed audit plan. And the elements of what should b
g 22 be in that audit plan are fairly well outlined in the l 23 order itself. That date expires May 7. I understand 24 that the audit plan is essentially developed and we l () POST REPORTING SERVICE j HAMDEN, CT (800) 262-4102
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185 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
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1 should be in receipt of that possibly by the end of 2 this week.
3 That's where we are in those two major 4 elements. And I just want to quickly address some of 5 NRC actions. As I mentioned, one action we have is !
~
6 relative to the licensee's plan for handling employee 7 l l concerns. We're having a meeting on May 13. But, also 8 that same day, in a separate meeting that afternoon we i
9 plan to meet -- the NRC plans to meet with Little 10 Harbor Consultants. And part of that is to get a iR 11 status of their activities. But at that time, we 8
12 should have received the audit plan. And we may ask !
O 13 for some preliminary information on that, on their i
14 audit plan, to help us, assist us in our review. '
15 I might mention just quickly some of our -- i 16 NRC's major activities that are ongoing and upcoming.
17 And one is, well, particularly, review of the audit
-l 18 plan once we receive that. And a lot of the attention 1
- 19 will be on -- and a very important factor to us is the 20 items that they identify that can be done to measure o :
21
. the success of the program. In other words, kind of
.l
- g. 22 performance indicators. And that's one important ,
l 23 element that we expect to look at very closely in the i
j 24 audit plan'and to look at that's important to us.
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186 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 One last thing is we're also developing 2 what we might do to monitor the licensee's 3 implementation of the program. And future action is 4 towards some point in the process after implementation, 5 after meetings we'll have with the third-party is for 6 the NRC to do a more comprehensive maybe oversight, 7 . evaluation, inspection of the licensee's program kind 8 of as another look at that program to see if all the 9 pieces fit together.
10 So that, in a nutshell -- and I think I E 11 did it in about five minutes so we can all get out of 8
12 here possibly at some reasonable time this evening --
13 is a summary. So does anybody have any questions and 14 comments on this topic?
15 MR. DELCORE: Are the two upcoming 16 meetings in May going to be public viewing or public 17 iniolvement?
18 MR. McKEE: There will be -- I think we
- 19 scheduled them -- they will be -- the firct one will be 20 a meeting in the morning with the licensee, open to the e
. 21 public. And it's going to be in the training center, l' 22 the same location where the meeting was today that we g
l 23 had with the licensee. And we're also going to meet 24 with Little Harbor in the afternoon beginr.ing at 1:00 0 POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
187 HEARING RE: MILLSTONE UNITS
.O APRIL 30, 1997 1 in the same facility, location.
2 A VOICE: Is comment allowed? >
3 MR. McKEE: That will open to the public 4 like our meeting -- and we'll allow some comments or, 5 you know, as we do in those meetings that we have with !
6 various parties, discussions after the conclusion of 7 the meeting.
I 8 MR. DELCORE: So there won't be any 9 public comment allowed during the meetings?
10 MR. McKEE: That's not the intent right 1
g 11 now, no. Not for those two meetings. We will schedule 1
12 -- we plan for the audit plan to include an opportunity l
13 for a meeting with the public like we're doing here now 14 for more detailed comments on the licensee's audit plan 15 once we receive that.
16 Any other questions? Yes, sir.
17 A VOICE: I just want to ask you a l- 18 simple question on the Employee Concerns Program. I 19 guess every question I ask is not that simple. l 20 MR. McKEE: That doesn't mean a simple r o
. 21 answer.
b g 22 A VOICE: Have you ever given any l 23 consideration in the Employee Concerns Program to l
j 24 having psychological profiles as a requirement for r
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! 188 !
HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 those people involved in the supervisory chain of 2 command and giving consideration to that?
l 3 MR. McKEE: Not as part of that program.
4 But I might mention -- because of my past history, I'm 5 a little familiar with it -- for people getting access
- 6 authority to the site, there is a psychological aspect 7 to looking at people before they have unescorted access 8 to the site, which would include I think most all 9 managers, supervisors for the most part have access, 10 but not -- as far as I know and I haven't read the 2 11 audit plan and I just don't remember seeing that in the 12 comprehensive plan that that's a feature in those.
13 A VOICE: Well, I'm just bringing it out 14 because I think it would be a good idea who is in a 15 supervisory, managerial line of command throughout the 16 organization that there should be a base line, a base 17 line from which you operate as to probable reactions of
! 18 managers in the employee relations scenario. I think 19 it's something that should be really, really carefully 20 looked at because if employees are making claims, then ,
O
< 21 there should be some kind of basis that could be I
g 22 verified to the best of anybody's ability that their l 23 claims are potentially legitimate. And one way to do 24 that or one very good way is to take a look at the POST REPORTING SERVICE ,
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l l
l l
189 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 l- 1 psychological profile. And perhaps it's a 2 psychological profile done of these people not by just 3 one professional but maybe a couple of professionals or l 4 a team of professionals, however you wanted to set it 5 up But I think as part of an Employee Concerns 6 Program, that's one area that should be definitely 7 given consideration.
8 MR. McKEE: Okay. I hear your comment.
9 And, like I say, I don't know if that's part of it. >
10 But some of those elements of psychological profiling 11 are included I think in the assessment or arrangement
{
12 of training programs which they do have for managers 13 and others. But I --
14 A VOICE: I think you may want it across 15 the board, though. Thank you.
16 MS. MARY KUHN: I'm Mary Kuhn from 17 Waterford,- Connecticut. I want to, first of all, thank I 18 you folks for what must be a very, very, very long day.
I 19 And I comment you on that. I suppose one of the things 20 that I feel when I hear all of this is time f O
= 21 constraints. To hear the kinds of problems that exist i
.g 22 se111 and the fact that Nu is planning to restart b 23 hopefully in eight months is sort of mind-boggling to !
24 me. ,
l O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
l 190 HEARING RE: MILLSTONE UNITS i
() APRIL 30, 1997 1 The plans for the Employee Concerns are 2 elaborate, but they're still plans. And in the first 3 quarter, I understand, of 1997, there were still more i
4 concerns coming to the NRC than to the Concerns '
5 Program. So that, you know, since employee concerns l 6 were one of the main issues involved, that we are still ,
1 7 at this state with the schedule like the end of l 8 December is -- makes me very uneasy. )
9 Other things, too. There are no 10 criteria for pass / fail. And there was, you know, -
l 11 considerable discussion about that. But what it seems 12 to me is to make everything negotiable. And I think 13 that that's kind of murky territory, too. When I think 14 that corrective --
you know, corrective action also 15 concerns me because that is another one of the 16 absolutely weak points as far as NU has been concerned.
17 And what happens then in terms of this schedule if I 18 there's a corrective action that's going to take a 5
! 19 year, you know, do we again rely on NU's commitment, 20 "Oh, yes, we're going to fix it"?
O
< 21 Operators' training, another I mean g 22 crucial, absolutely crucial for a safe nuclear plant, h 23 still figuring out root causes for the operators' 24 training problems.
f~\
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_O. Arnt' 3o' 2997 :
1 And I suppose I was a little bit uneasy, 1 l.. ;
~
2 too, when it was mentioned that the spent fuel pool has 3 been there, you know, with regard to leaving it as it 4 is for a while, that it's been going on this long, you 5 know, presumably without accident. I think that's a -- i 6 that's something I don't really feel very comfortable l 7 about. !
8 The other, I guess, too, is how much !
9 good any of these citizen's efforts do. I- was ---the i 10 meeting with the NRC with Chairman Jackson and NU , I R 11 think Dr. Travers said we've actually completed the R
12 organizational approval for Sargent & Lundy for Units 1 13 and 3. And I think significantly I'd like to point out 14 that we got a number of comments from the public and t
15 we , in our '
approval, took efforts to address those in 16 the actual approval. Principally, they related to 17 questions about independence. Was the organization !
! 18 truly -- could it be truly viewed as independent from !
- 19 Northeast as opposed to technical qualifications and ;
20 that sort of thing?
O
.. 21 Well, you know, I think that probably ;
.l i g 22 there were efforts to address it, but I don't think it l
'l '23 really .-- too, Shirley Jackson really presents a 24 situation which was that really we were -- well, our ,
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t 192 HEARING RE: MILLSTONE UNITS
()
APRIL 30, 1997 1 suggestions were simply vetoed as far as being 2 independent is concerned and I don't think that the 3 public was really ever satisfied about that. So that I 4 am -- you know, I do have some misgivings about the 5 effectiveness of some of what we're able to do.
6 And I hope, I hope that something that j l
7 can come of all this because I think that everybody j 1
8 righe. now is pretty weary. And, again, I thank you for 9 being here.
i 10 MR. McKEE: Well, I know a couple of us )
R 11 may want to respond. You had a lot of things you 8
l s 12 stated there. I think a lot were comments. But one
)
13 thing I want to say as far as the effect of comments 14 and input by citizens, members of the public, I can 15 assure you that you do have an impact. I think you 16 just look around. A lot of what we're doing now is 17 based on input that we received from you. And I can
! 18 speak for Gene on this; that there were a lot of I
19 considerations and adjustments in the ICAVP, as well as 20 other programs, based on input and comments we've O
= 21 received here.
g 22 And just on the other items -- and I'll h 23 let other people chime in the areas. All those areas l 24 that you mentioned, we are -- those are areas that are
(~'\,
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193 HEARING RE: MILLSTONE UNITS Q APRIL 30, 1997
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l 1 on our programs that we, too, are interested in and 2 concerned about that they be completed to a certain 3 point. And we are wrestling with a lot of the areas.
4 For instance, Employee Concerns, how do you measure 5 their performance? And that's why I indicated that 6 developing performance indicators, which is not 7 something to do in a human issues area, is difficult, 8 but it's very important to us to gauge and look at how l
9 performance turns in that area.
10 MS. KUHN: Thank you. !
11 MR. .LANNING: And I just wanted to
{
i 12 assure you that we are not schedule-driven, that before 13 this -- any of the units at Millstone is permitted --
14 at least we recommend that it may be restarted, that 15 they do all that is necessary to restart safely and 16 then operate safely thereafter. And that's- not 17 schedule-dependent.
l
! 18 MS. KUHN: Thank you.
I; 19 MR. LANNING: Thanks.
20 Yes, sir?
O
<- 21 A VOICE: I read the original Little ;
h I g 22 Harbor proposal. I'm not aware exactly of the changes )
l l 23 .that have been made. So please -- my questions -- give l 24 me a little slack. The numbers may not be exactly
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194
( HEARING RE: MILLSTONE UNITS O ^>x ' 3o' 1997 1 right. But my questions are, number one, how come nine 2 out of eleven people who are doing this work are from 3 the. nuclear industry when the work itself is employee j 4 concerns? How come no more than one or two had any l
j 5 experience in Employee Concerns? And, number three, l
6 how come there's no one representing the employees on 7 this? It's supposed to employees' concerns, but I l 8 don't see how you have any input from employees. Those 9 are the three questions.
l 10 MR. McKEE: Okay. Maybe I'll go in R 11 reverse order here. That was important. That was the 8
12 one, I guess, relief that we provided in the order was -
13 on a representative, Ms. Billie- Garde, .to be a 14 participant in that effort. And we think that she has 15 -- her background does provide -- on your last issue, 16 has had experience to kind of provide some 17 representation of employees or employee perspective on
! 18 issues.
I 19 A VOICE: Close than anybody else maybe.
t 20 MR. McKEE: And I think there are --
I O
= 21 think there's more than two. I think there's three in I
g 22 several that were involved of the people on Little
- l 23 Harbor that were involved in pretty significant efforts 24 of Employee Concerns Program, similar issues that l
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I 195 HEARING RE: MILLSTONE UNITS
(]) APRIL 30, 1997 1 occurred at other facilities in Texas, I think, 2 Comanche Peak in south Texas, that have extensive 3 programs in that area. And they had fairly extensive 4 involvement. I think that provided in that aspect some 5 what we thought was good background.
6 As far as your first guestion as far as 7 -- I guess one emphasis was nuclear background. We 8 think that that's important for somebody that sets the 9 issues involved in nuclear, that people with a )
1 10 background in nuclear or the industry are an important l
11 factor and needed to appropriately assess some of the l
\
r~s 12 issues that may arise and the technical aspects in that
(_)
13 arena.
14 So we looked at that mix and with the 15 aspects that we stated in the order that we thought 16 needed to be covered. And there was also a couple of 17 individuals that are experts and, really, I don't think I 18 have too much exposure in the nuclear for doing i: 19 surveys, assessment, human relations, that aspect, 20 which we thought was an important feature and that was O
= 21 an important item that was identified in the order.
I g 22 So I think on the balance that all the h 23 areas, all of the areas were covered. Now, I agree.
l 24 We can discuss, well, maybe it could be slanted. There f /'T POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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196 HEARING RE: MILLSTONE UNITS l
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1 could be more in this area. That might be true. But I l
l 2 think as far as our review is concerned, the important l 3 areas were covered with people that had appropriate l ,
l 4 background in all of the areas that we wanted looked )
5 at. I 6 A VOICE: Well, nine out of eleven of 7 them being from nuclear the industry, their past )1 8 employment, their present employment and their futures j 9 dependent on the nuclear industry, I don't see how you f 10 can in any way call that an independent verification.
11 That's an opinion.
e~g 12 MR. McKEE: Okay. I --
(~/ 1 13 A VOICE: I think it's an opinion that's ;
14 shared by a lot of people, though. I 15 MR. McKEE: I understand that opinion.
16 We've heard that. And I understand your position. l 17 Any other questions?
l 18 MR. CIZEK: Yes. I have a cpestion.
i 19 How do you ensure, for example, with confidentiality 20 that, let's say, confidentiality is breached for some l 0
- 21 reason and NU finds out who the person is whc did the i
g 22 complaining? What kind of enforcement action ic taken
.l 23 against any individual, even beyond NRC, that may have l'
l 24 been found to have released that information?
I
()
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197 HEARING RE: MILLSTONE UNITS APRIL 30, 1997
({} j
. I 1 McKEE:
l MR. I think you're getting a 2 little off the Employee Concerns Programs of the )
3 licensee.
4 MR. CIZEK: But it's right in here. It 5 says confidentiality --
6 MR. McKEE: Yes. If there are issues .
l 7 like that -- 1 8 MR. CIZEK: If you're going to address I
'9 the issue of enforcement --
10 MR. McKEE: Yes. And we -- I don't want )
R 11 to defer it. We're going to have somebody talk about R
12 our allegation process. He may not cover that area.
13 But issues like that, if it's an appropriate action 14 according to our procedures, our Inspector General's 15 Office would -- that would be referred to them.to look l
16 at and review. And that -- where there have been cases l 17 like that, that's how the process has worked. There's l 18 been referred to them to look at.
I 19 MR. CIZEK: But don't you think it l 20 should be addressed in here or in your procedures as to o
. 21 what the enforcement action will be under the law? !
l
{ 22 MR. McKEE: We have how that will be lLl 23 dealt -- I don't think it gets into how it would be 24 addressed under the law. But we have how the process -
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1 -
and such cases, I believe, in some of our internal 2 procedures would be referred to IG --
3 MR. CIZEK: I didn't see --
4 MR. McKEE: I don't know. I'm not
.5 familiar with that document. I mean I don't know what 6 you have. I don't have my glasses on.
7 MR. LANNING: All right. Decision time 8 here. We had one more presentation concerning the 9 allegation process used by NRC. And we still have to 10 do the general question-and-answer session. With your !
R 11 agreement, I would propose that we delay the allegation R
12 process discussion until a future meeting and just pick -
13 up now with the general questions and answers. Is that 14 agreeable to everybody?
9 15 VOICES: Yes.
16 MR. LANNING: Are you disagreeing --
1i MR. DELCORE: No.
l- 18 MR. LANNING: Okay.
I 19 MR. DELCORE: I just wanted to ask an 20 ECP question, but I'll ask it in the general. It O
. 21 doesn't make any difference.
g 22 MR. LANNING: That will be fine. Okay.
l 23 Let's do the general questions now. And we'll pick up 24 the allegation process in a future meeting.
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HEARING RE: MILLSTONE UNITS APRIL 30, 1997
(])_
1 Yes, sir, Mr. Reynolds -- Mr. Delcore. '
2 Excuse me.
3 MR. DELCORE: I think an issue that I 4 raised about the ECP meetings that Mr. McKee referenced i
5 -- you know, first, we're sitting here at 11:00 at.
6 night discussing with yoa a bunch of issues about a !
7 meeting this afternoon. And I think that the public I 8 and the NRC and NU would be much better served if we 9 held these meetings with NU. And if that means that we I 10 need -- you know, in order to get the public in because i
l 2 11 everybody works, then that's fine. But I think to have l
- R -
12 a question-and-answer or to have a public meeting with l 13 no questions and answers to NU -- we come here and talk ;
L i
! 14 to you guys. We never talk to them.
15 MR. LANNING: I thought they had 16 initiated on their own public meetings.
17 MR. DELCORE: When is the last time you 1
l 18 heard that they had one? They were very quick to point 1 1 19 out that they had one to Shirley. They had scheduled ir 20 one and were going to have another one to Shirley 0
l
= 21 Jackson when they met with her on January 30. But, to b
g 22 my knowledge, we haven't had one since. Have we?
l 23 MR. McKEE: I know there's going to be 24 one on May 13 because --
4
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200 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 MR. DELCORE: Oh.
2 DR. TRAVERS: We honestly can't tell you 3 what there's going to be doings on. But our meetings, 4 at least some of our meetings, are working meetings 5 where we need to get information and query them and 6 find out what's going on so we can do our oversight 7 thing.
8 MR, DELCORE: I understand that.
9 DR. TRAVERS: So in that sense, that's 10 what we intend to do in some measure. But, in addition g 11 to that, you know, we're going to plan to continue to I e 12 keep the public as informed as we can.
13 MR. DELCORE: You know, the word public 14 meeting infers that there's some involvement by the 15 public. And there's absolutely no involvement allowed 16 by the public at public meetings.
l 17 DR. TRAVERS: Well, we have meetings
! 18 that are open to the public --
l
. 19 MR. DELCORE: With the licensee. I have 20 not been -- I think it's been one meeting that we were o
. 21 allowed comment and that was John -- the MIRG meeting g 22_ with John Hannon. That's the only public meeting where l 23 NU was there that I was ever aware that we were allowed 24 to ask or make comment.
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l 1 MR. LANNING: We'll take your 2 suggestion, I mean your comment and' pass it on to NU.
l 3 MR. DELCORE: Okay. Well, not only to t 4 NU. Pass it on to Shirley. I think Shirley Jackson --
5 I think she thinks these public meetings between you
- 6 guys and the licensee are we're making' comments. She's I
7 very mistaken about that. t 8 MR. LANNING: I don't think so. No , no.
9 I don't think that's accurate.
10 MR. DELCORE: If you don't sit in the l-R 11 afternoon and take notes, it's almost impossible to I 12 come here and ask you guys questions because what we '
13 .get is a summary, an overview, and we have no concept.
14 I didn't get to the meeting this afternoon and I have l
15 no concept about what went on except the little bit i
16 that you presented .us. And I really think it's an 17 injustice, an inservice to the public. I think that 18 they need an opportunity to be able to communicate with l : 19 both of you, not just you guys. And we're not getting :,
20 that opportunity. '
o
. 21 Thank you.
ll g 22 DR. TRAVERS: Thank you, il 23 MR. LANNING: Other questions?
! l j 24 Ms. Luxton.
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202 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 MS. LUXTON: Yes. I agree with that 2 completely. I think that's a marvelous point which I 3 forgot, is that the interchange between NU and NRC --
4 because you know what? When you come -- I've gone to 5 the afternoon meetings when I've listened and then at 6 night I come and listen to you do a recap to the public 7 and you don't do a very thorough job, really. You !
8 don't really do a thorough job.
i 9 DR. TRAVERS: Well, the meeting lasted 10 four hours. It might be difficult to go over the -- t E 11 MS. LUXTON: I know. But I mean even R
12 your summations, your summaries of them sometimes are -
)
13 - I think, gee, the people that are sitting here that -
14 didn't go there today, if they were .just hearing what 15 you said, they wouldn't get at all the flavor of what ;
16 went on. But that's just my point of view. So I agree 17 with that. I go for that, the three of us all
! I 18 together, the public, NU and NRC. ,
I 19 All right. Now, my two miscellaneous 20 comments are getting back to the spent fuel issue at O
= 21 Unit 1. And it's something that the gentleman on the i lb l lg 22 wall, over there next to the wall, said.
Il 23 DR. TRAVERS: Mr. Burritt. Art Burritt. j 24 MS. LUXTON: Art. What he said about --
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J 203 I HEARING'RE: ' MILLSTONE UNITS .
(')N APRIL 30, 1997 1 that we were looking -- we were going to do the filming !
2 of the rods in the pool. And someone said why haven't
'3 you noticed that in your inspections over a period of 4 time. And he said that they rely on the licensee's 5 documentation or info on their procedures. Right? On 6 their looking at this fuel pool. Correct? !
l 7 MR. BURRITT: We observe fuel paneling.
8 For instance, I've been up on the bridge when they move 9 fuel. But for something like this inspection finding, 10 you can't see it from up above. ,
' i! 11 MS. LUXTON: Right. i 8
12 MR. BURRITT: And when it was noticed 13 was when the camera was down adjacent to the fuel racks ,
14 and you could look across it. So what I was saying is :
15 we wouldn't necessarily pick that up in our normal 16 activities. '
17 MS. LUXTON: Right. And so you rely on I 18 the licensee providing you with the pertinent I
- 19 information.
lr 20 MR. BURRITT: It has to do with that O
= 21 inspection.
g 22 MS. LUXTON: Right. And providing you l 23 with the information, whatever it was. 1 l 24 DR. TRAVERS: And that's true very i
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1
l 204 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 generally in nuclear power regulation. In the first ,
i 2 instance we rely on licensees to maintain the safety of 1 3 their facilities. They are principally responsible and 4 relied upon !
5 MS. LUXTON: Correct. That's what i l
6 Shirley Jackson told us right here in ths.s room in 7 August.
8 DR. TRAVERS: That's absolutely true.
9 MS. LUXTON: That was her very first 10 comment. Right. The NRC is responsible -- I mean NU R 11 is responsible for maintaining the safe operation of 12 their --
13 DR. TRAVERS: They are the first line 14 people who are responsible for nuclear safety. That's 15 correct.
16 MS. LUXTON: Correct. So my point is in l 17 this roundabout way that we get back to the Gladys l l 18 issue. Charlie went home, so I have to pick up his I
- 19 question. The Gladys issue is very pertinent to this.
20 That 2.206 which started the whule ball rolling here is O
. 21 -- it alleged material false statements by the utility.
b g 22 Correct? Now, we still don't have a resolution. We l 23 have a partial, mind you. But we don't have a full l 24 resolution on that issue, that specific issue of POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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I HEARING RE: MILLSTONE UNITS
(]). APRIL 30, 1997 1 material false statements.
2 So how can we trust this whole restart 3 process if we don't know yet if they were making or 4 continue to make material false statements? So I think
- 5 and Charlie thinks and probably a lot of other people t
6 think that we need to have a resolution of that 7 material false statement part of the petition before we 8 can go any further on any of this because we can't rely 9 on them. They still could be lying to you. So why is 10 it taking so darn long to get this part resolved?
R 11 DR. TRAVERS: We can't discuss the g-) 12 specifics of why it's taking so long. It is taking a l
V 13 long time. You're absolutely correct. And I can tell 14 you that an aspect of our restart --
well, the 15 Commission's restart decision and our recommendation 16 will include consideration of whatever is pending in
( 17 that area.
I 18 MS. LUXTON: In 2.206's, you mean, or I
- 19 just that particular one?
20 DR. TRAVERS: All enforcement actions, o
< 21 all enforcement issues and what's pending, including
,l g 22 things that may be out of our hands and under review l 23 elsewhere.
24 MS. LUXTON: Oh. That's good. So am I l
- C:)
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i 206 HEARING RE: MILLSTONE UNITS r APRIL 30, 1997 l
1 hearing you say that's a restart issue?
2 '
DR. TRAVERS: It's a --
yes. It's 3 specifically a consideration in the restart decision ,
4 the Commission will make. In our realm, it's simply an l 5 accounting for what's still outstanding. The 6 Commission may be briefed by. OI or other parties-who -
7 are involved in this issue or other issues to give them 8 a specific sense. And usually those are done in closed 9 session becat.se they' re -- especially if they' re still !
10 pending. They're still -- you know, like I can't talk R 11 about it tonight. They would not likely if they're 2
12 pending be able to discuss that in a public forum.
13 But the significance of them and the 14 status of them will be specific issues that the 15 Commission will consider before it authorizes or 16 considers restart authorization.
17 MS. LUXTON: Okay. Okay. That's very il 18 good to hear. But it also, though, goes -- that's good
- 19 to hear. But, still, even right now, though, right now 20 it still is kind of an open-ended problem.
O
. 21 DR. TRAVERS: It's open.
g 22 MS, LUXTON: Don't you think?
l 23 DR. TRAVERS: It's open.
24 MS. LUXTON: Because we really don't iO l . POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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207 i
' HEARING RE: MILLSTONE UNITS I
(]) APRIL 30, 1997 l 1 know yet whether we can -- even though they say we can l
2 trust them, we just don't know, really. Even though, 3 like he said, like Mr. Durr said, they could be -- we 4 assume they're innocent until proven guilty. But --
5 DR. TRAVERS: Well, that issue is open.
1 6 But, in fairness, I mean we have a host of activities 7 that are ongoing in real time to assess the current 1 l
8 situation. And so while that issue you raise on Gladys l 9 partially responded, partially open is open -- and I 10 can't tell you when it will be closed ultimately.
R 11 MS. LUXTON: Right.
R 12 DR. TRAVERS: We're at the site. We're g-)3 13 at headquarters. We have mechanisms today to assess 14 where this utility is at, where it will be at when the 15 plant potentially is ready to restart.
16 MS. LUXTON: What do you mean when you 17 said real time, in real time? Is that -- l 1
! 18 DR. TRAVERS: Yesterday. Not just when l
19 the Gladys issue cropped up. There's been quite a lot 20 of activity since on our part.
O
. 21 A VOICE: Ongoing.
I g 22 MS. LUXTON: Okay.
l 23 DR. TRAVERS: It's ongoing and it will, 24 you know, continue to be ongoing. And I mean POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
r-l 208 HEARING RE: MILLSTONE UNITS
() APRIL 30, 1997 1 potentially, as I said, if there were problems of that 2 sort that need to be found out, we may find some more 3 of those out if they're there. So that's what I mean 4 by a real-time acsessment.
5 MS. LUXTON: Okay. Now, second 6 question. Second comment. I shudder to bring it up 7 because I know it always make everyone -- 442 valve. I 8 found out the other day that a utility executive from 9 NU who was directly related to or involved in the 442 10 valve non-conservative decision-making of 1993 at 11 Millstone Station has now, after spending time rx 12 underground at INPO, which is Institute of Nuclear
\~)
13 Power Operations, has resurfaced at another nuclear 14 facility in the Southeast called Robinson, which is at 15 Carolina Light & Power, if I think I'm -- am I right on 16 that?
17 MR. IMBRO: Yes. That's right.
! 18 MS. LUXTON: Okay. Right. The question
- 19 is from a citizens group perspective or from citizens 20 surrounding a nuclear power plant, how do we know that 0
< 21 these highly-touted recovery officers from VEPCO, PECO, k
g 22 Sunoco -- no -- whatever, you know, the ones that are l 23 at Millstone now in their recovery of 1 and 2, how do 24 we know they aren't one of these underground INPO
(
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209 HEARING RE: M1.LLSTONE UNITS Q APRIL 30, 1997 1 people who just resurfaced at Millstone? Because, you l 2 know, Keenan showed up. I sow, do they know in Carolina 3 that Keenan put us at rirk in Waterford in '93? Are
{
4 you getting my point here? I mean it's, you know, 5 tongue-in-cheek in a way, but it's very serious. I'm 1
6 serious about this. I don't mean to besmirch these
{
7 people personally, what's-his-name, in, you know, 1 and l 8 2. But this is a serious concern, isn't it? I mean 9 think about it, really. l i
10 I don't know what the resolution is. ,
11 But I think it's outrageous, to tell you the truth.
12 And I'm working on this somehow. I think -- you know, 13 I think there should be a citizens network, a group, a I 14 network throughout the country so we all -- when one i
15 utility executive gets booted from someplace else, when 16 he sh';ws up someplace else, we've got the goods. We 17 share the information.
18 MR. DELCORE: Just like the bad doctor
- 19 list. Right?
Ir 20 MS. LUXTON: Right.
l 0
. 21 MR. McKEE: It's called black-listing.
k g 22 MS. LUXTON: Sometimes you need a little ll t
23 levity in this issue, though. Don't we?
l
, \
I 210 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 i 1 you for providing it.
i 2 MR. LANNING: Yes, Ma'am?
3 You're her new best friend, by the way. ,
4 MS. BASSILAKIS: Just to pick up on what 1
5 Susan said, I think one way to resolve it is to hold 6 people accountable for their actions. And it's just 7 remarkable -- it's just remarkable that this person 8 hasn't been --
9 A VOICE: Arrested.
10 MS. BASSILAKIS: --
arrested. I mean 11 you know the details of that event. We don't have to 12 go in it. It was very serious. And to think he is at 13 another facility, perhaps in a manager position or 14 supervisor-position, that's very terrifying.
15 MR. DELCORE: Vice President of the 16 site. ,
17 MS. BASSILAKIS: So I think 18 accountability is important. And, also, when people --
. 19 when Northeast Utilities does bring in new leadership,
- 20 that you guys can do a little bit of homework and check o
. 21 out their background because our citizens group, our l.
g 22 network isn't up to speed yet. So we need to rely on l 23 you.
24 The other thing I have to say is just a O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
l 211-4
! HEARING RE: MILLSTONE UNITS I
- l. Q APRIL 30, 1997 !
i j 1 comment. I really don't know how you can respond to 2 this. But I looked over the transcript of the NRC/NU !
L 3 meeting that happened on the 23rd of April. And one l
4 thing that concerns me is Mr. Kenyon's desire to 5 increase prc.ductivity of the workers in order to stay 6 on schedule. And I really don't -- I'm not on the 7 inside. So I can't say. But I would just like for you 8 to keep an eye out. I mean maybe the workers can't 9 increase their productivity any more. I don't know. I 10 don't know how realistic that is. So just keep an eye 11 for burnout or being pushed too hard or being forced to 12 reach unrealistic schedules. So, you know, I know you 13 can't comment on that. But I definitely have concerns 14 about that.
15 MR. LANNING: Any other questions?
16, MR. CIZEK: Picking up on what Rosemary 17 said, I think it's -- and I don't know if you do this.
18 But.I think it would be a good idea to look at the time
- 19 cards of some of the employees on a spot-check basis to 20 see the total number of hours they're working to see if G
. 21 they're in a burnout phase. You know, if someone a g 22 working 80 hours a week in a nuclear power station, i
l 23 that's a point of serious concern.
24 But I want to make a comment here.
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t 212 HEARING RE: MILLSTONE UNITS
) APRIL 30, 1997 1 MR. DURR: May I address that?
2 MR. CIZEK: Go ahead.
3 MR. DURR: For people working in safety-4 related. applications, there are limitations and we put 5 out a requirement that they -- that the utility has to 6 adhere to. And don't quote me on the numbers, but it's 7 like you can't work more than 40 -- 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 8 given week or something like that. So there's 9 limitations on how much --
10 A VOICE: I think it's 72 in three days, g 11 actually.
e-12 MR. DURR: 72 in three days? It's tough 0 13 to do 72 in three days. But there are strict l
14 limitations on that. We've looked at that. It can be 15 a problem that they burn out.
16 MR. CIZEK: Does anybody spot-check to 17 make sure that they're in compliance? ,
I 18 MR. DURR: We have violations on at I: 19 least two occasions that I'm aware of and possibly 20 three.
O
< 21 MR. CIZEK: How often do you spot-check i 22 them?
g l 23 MR. DURR: How often do I --
24 MR. CIZEK: Well, how often does the NRC O POST REPORTING SERVICE HAMDEN, CT (800)-262-4102
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{ 1 spot-check them? j 2 MR. DURR: You have to ask my guys. 3 They do the inspections. It's not a regular thing. 4 But we are aware of it and we watch for that kind of 5 thing. Yes. 6 MR. CIZEK: But, you know, it's a 7 legitimate question. How often do you spot-check the 8 time cards or to see that they're working within -- in 9 compliance with the NRC requirements? 10 MR. DURR: Can you guys answer that? E 11 MR. BEAULIEU: It's part of Manual ' R 12 Chapter 0350. .; 13 MR. CIZEK: That's a nice number, but 14 how often do you check them? , 15 MR. BEAULIEU: It's something we're all 16 looking at. It's on our restart plan. 17 MR. CIZEK: Okay. I 18 DR. TRAVERS: I guess the answer is we 1 19 can't answer your question on periodicity of checking. 20 MR. CIZEK: Okay. Now, I have a comment , o ! . 21 that I'd like to make here. And I don't know if k i g 22 everyone -- and I suspect many people don't agree with l 23 me. I know many people don't even want to say this i 24 because it's not politically correct. But as a l ( POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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) APRIL 30, 1997 )
l l 1 proponent of political incorrectness, I'll'say it. 2 After listening for this number of years 3 and months to the NRC, NU, the newspapers, these 1 4 meetings, so forth and so on, and having been a 5 . professional engineer for over 30 years -- I'm retired 6 now, so I'm glad to see you guys are working -- I can l 7 safely say without any question in my mind at all that 8 it is impossible, it is virtually impossible for 9 nuclear power to ever be safe. Everything that I have 10 seen so far is a spit-and-chewing-gum, band-aid 1 R 11 approach to trying to correct problems which have the R 12 potential for enormous-catastrophe. 13 The fact that we haven't had it I think-l 14 is more luck than design. And I think, in my opinion, 15 the nuclear power industry has become a jobs program ! 16 for engineers. It's what it seems like. We're trying 17 to protect the jobs of engineers because of -- like l 18 Boeing and other companies, we throw them out into the . l
- 19 work force. Whoa. That's going to really affect the I
j 20 economy. It's an unfortunate thing, but I think it's o
. 21 reality and I think what I say is accurate and true.
g 22 And I think the sooner the public and {l 23 everyone, the government included, comes around to the 24 very hard realization that we have to get to j POST REPORTING SERV;:CE HAMDEN, CT (800) 262-4102 t
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l 215 - HEARING RE: MILLSTONE UNITS (]) APRIL 30, 1997 1 conservation and the sooner, the better, and we have to 2 seriously look at solar power and alternate sources, 3 -we're going to keep being belabored by an albatross. 4 Juni I think nuclear power -- I don't have a number > 5 exactly when. But I think in the future you will see 6 it will disappear. It will have to disappear. The 7 costs will force it to disappear. And the nuclear 8 waste issue, which will never be solved, will also 9 force it to disappear. 10 Thank you. g 11 MR. LANNING: Other questions? 1 12 MR. MARKOWITZ: just have I one quick ) l 13 statement. And it gets back to the discussion earlier l l 14 about software. Just from watching the body language l l 1 15 of how that discussion went back and forth, I didn't -- 16 I got the feeling that there may be an open issue 1 17 beyond Millstone regarding software that's used to l 18 produce safety-related calculations or information that I
- 19 sort of falls outside the configuration control i
e 20 program. 0 l , . 21 MR. IMBRO: No, i < 1 g 22 MR. MARKOWITZ: Well, the discussion fl 23 about the calimetric stuff earlier I thought was 24 something that said, "Yes, the data is used but nobody j i~ () POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l 1
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216 HEARING RE: MILLSTONE UNITS APRIL 30, 1997 1 really certifies the software and nobody validates this 2 configuration control item."
-3 MR. IMBRO: No. But it's --
the 4 software is benchmarked and it's certified. 5 MR. MARKOWITZ: But for plant computer, , 6 there is -- 7 MR. IMBRO: There's control under 8 Appendix B. 9 MR. MARKOWITZ: Okay. I got a different l l 10 impression. I got the feeling that there's an open [ 11 issue somewhere. n , i 12 MR. IMBRO: Well, Dave had an open 13 issue. But I'm not -- l 14 MR. CERNE: The answer is it can -- it 15 is non-safety-related. It's not relied upon. But it 16 can have an impact on safety if it's incorrect. 17 MR. MARKOWITZ: Yes. That's my point. 18 MR. CERNE: So it's important that it's 19 QC-checked and double-checked. In fact, it is -- when 20 I checked it out, it has been at Millstone 2. 0 4 21 MR. MARKOWITZ: Okay. What I was trying g 22 to get at is I don't know what else is out there in the b 23 industry and I don't know whether it's something that 24 you worry about. Okay? And I'm just trying to suggest O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
217 HEARING RE: MILLSTONE UNITS (]) APRIL 30, 1997 1 if, in fact, there is data that falls in that category, 2 that you may want to look at it from the NRC end should 3 there be some kind of configuration control validation 4 process, maybe even an appendix or something that says, 5 " Hey, if you've got this out, it's not necessarily 6 that's going to cause a reactor scram, but it could 7 leai up to that." And consider it. That's all. 8 MR. CERNE: I've got it on my list of 9 follow-up items. 10 MR. MARKOWITZ: Thank you. 1 2 11 MR. CERNE: Thank you. . E l 12 MR. LANNING: Okay, I think that was 13 the last hand. j 14 Yes, sir? 15 BILL: I'll make these pretty short and 16 sweet because it's pretty, I think, for everybody here. ! 17 Just getting back to that software issue that has been ) I 18 discussed, I think for sure the operators use I
. 19 information from the process computer to intelligently 20 make decisions. So from that aspect alone, it would O
. 21 need to be looked at. That's my common-sense t
k g 22 understanding or look-see at that situation. l 23 DR. TRAVERS: Yes. There's just a very 24 strong regulatory significance to the term " safety-(G _) POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
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l 218 js HEARING RE: MILLSTONE UNITS () APRIL 30, 1997 l 1 related" and this software doesn't -- 2 BILL: Yes. But -- 3 DR. TRAVERS: Does it have a nexus to 4 safety? It does. 5 BILL: Right. I mean -- 6 DR. TRAVERS: In that context, there's a 7 graded approach to -- 8 BILL: You know, the calimetric has been 9 brought up in the prior conversation. The NRI's are l 10 balanced against the balance of plant calimetrics or -- ' E 11 DR. TRAVERS: Just so you know, there E 4 12 are software systems, Eagle 29 and some of the new 13 advanced reactors, that use software in safety-related t 14 digital computer systems. They have almost a line item 15 requirement for code checks. 16 BILL: Right. Right. 17 DR. TRAVERS: That's a different thing, I 18 though. And this is not the kind of -- these plants , - 19 don't use that kind of software in their safety-related l 20 system. l r
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= 21 BILL: Also, with regards to what Mr.
I 22 Lanning had to say before, I agree in that a lot of the g ; l- 23 canned software out there, if you want to call it that, 24 has been validated. So I don't know if the issue per
- () POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l
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i l 219 ' HEARING RE: MILLSTONE UNITS f'/ s. T APRIL 30, 1997 3 j 1 1 se is whether or not that software is correct or 2 accurate. I think the issue may be has NU input the 3 proper information and have they interpreted the { 1 4 results properly? And I think that's really what you i 5 need to look at. l 6 DR. TRAVERS: Okay. l 1 7 BILL: I think that's how -- 8 MR. IMBRO: I think the ICAVP will look 9 at those. I 10 BILL: All right. Sure. And -- let's 11 see. Yes. I wanted to just follow up on one other 12 issue. Don Delcore made a comment that these public j
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13 meetings weren't really that public, so to speak, and l 14 that it was a difficult situation to be in when you're j 15 talking to the NRC only or you're talking to NU only or I l 16 even to I'll say NEAC only. And that I know for sure I 17 have several questions, several issues which I think
! 18 are important to raise and I really don't know the - 19 right environment to raise them in.
l 20 And I think if the NRC I'll say 'O
- < 21 requested, but requested perhaps in the form of a I
g 22 demand or an order that basically said "We'd like to l 23 have a joint meeting with you in a public setting" -- 24 because I think it would be very important or you O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
220 7g HEARING RE: MILLSTONE UNITS (,) APRIL 30, 1997 1 should have realized -- well, maybe you do realize 2 this. I don't want to be -- I don't mean to be cutting 3 here. You should realize that -- you should be 4 interested to hear the questions that the people have 5 or the public has to NU and how well they can answer 6 those questions. So you can just sit back and listen 7 to that interchange. . l 8 And I think for me to come up here and 9 to talk to you independent of NU and vice versa really 10 isn't that effective. So it would be my suggestion. R 11 MR. LANNING: All right. I'll take it 2 r~s 12 as a suggestion. We'll have to look at it. I know it ,
'uJ 13 was done in Maine Yankee, for example, the combination 14 meeting. So we'll look at it and evaluate it and see l l
15 whether we can accommodate it. i 16 BILL: What I might suggest also is that 17 it has to be done in the right setting. You may need a 18 facilitator so it can be a very productive meeting, for 19 example.
!t 20 MR. LANNING: Yes. You've opened up a O < 21 whole new arena of public meeting, so to speak. And, 8
ls 22 you know, as Bill said earlier, you know, this was
! 23 really an attempt to get public feedback to the NRC.
24 But we do monitor these public meetings that the ('h Y~ POST REPORTING SERVICE EAMDEN, CT (800) 262-4102
l 1 221 l HEARING RE: MILLSTONE UNITS (). APRIL 30, 1997 . I 1 licensee has and listen and take note of statements ) l 2 made. 3 BILL: It seems -- it's a difficult way_ 4 for me to present information to me. It's really 5 indirect. I would have to bring up an issue to NU, 6 challenge them on some issues, listen to their answer 7 and then hope you hear about it. I mean I'd rather not 8 do it that way. And I'd also rather -- 9 MR. LANNING: We keep track of their 10 issues. I mean we're open and receptive to -- lR 11 BILL: As far as allegations are R , 12 concerned, now that's a rough path. It's very -- it's l 13 a long process. I'm sure -- well, I'm sure -- I'm I' 14 guessing that my allegations will be addressed after 15 restart. So I really question, you know, what that l 16 really -- what the significance is of those. And I l 17 would like it to be more timely. I surely don't really l
! 18 want to use the newspaper. That's pretty kind of a ;
I 19 last-ditch effort to do. It's not productive. Kenyon ! 20 said he didn't want to use the newspapers. He thought O
< 21 that was inappropriate. He'd rather talk directly to ,
0 E 22 people. And what I'm just suggesting -- I think if 3 l 23 there was like a three-way exchange there, it would be
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24 much more valuable and I think we'd get down to () POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 )
222 HEARING RE: MILLSTONE UNITS () APRIL 30, 1997 1 business. 2 I mean I have some things to bring up 3 with respect to accountability in the sense that -- I'm 4 not talking about the accountability of the past 5 management. But I'm thinking -- I'm really referring 6 to the accountability of the present management and 7 some of the actions that they've done and some of the 8 decisions that they've made in recent months. And I 9 think that's important for you to hear what I have to - 10 - those questions from me and also hear their answers. 11 Because I'd like to challenge a couple of these guys fs 12 and see how they're going to answer these issues. U 13 MR. LANNING: I understand your -- 14 BILL: You know, the whole allegation 15 process, it gets buried. It goes into a black hole 16 forever. You go to a newspaper; ucually they get it 17 half-wrong. You talk to NU and they give you some k 18 bogus answer. And then people just get tired of being 19 here for four hours. So I think it would be much more 20 productive to have a three-way interchange, exchange of O
< 21 information and perhaps with a facilitator to make sure I
g 22 it's productive. That's all, h 23 Thanks. 24 MR. JOE BESADE: I'm Joe Besade. And my POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
e 223 i HEARING RE: MILLSTONE UNITS APRIL 30, 1997 (]) , 1 l 1 question is Employee Concerns. It's about'the double ; i 2 ' standards between Northeast Utilities and the outside
- 3 contractors' employees. I'm curious as to what will 4 happen to Un2 alleged violators mentioned in today's-l 5 Hartford Courant who lied on their qualifications. As l .
6 a union pipefitter steward approximately ten years ago, 7 I had a man with a slashed badge who worked a complete 8 outage and wanted a clear badge to be an escort at CY. 9 When I took him up to Security, I found out when he , 10 came out that they had found that he forgot to put down 2 11 that he had a DWI eight years earlier and that nothing R 12 was going to happen. But by the. time he left Security 13 and got back to our construction trailer, the word had ! 14 come down the man was to be terminated at the end of 15 the shift and banned from the site for one year. 16 My question is what, if anything, will ! 17 take place with these people if they're found guilty to I 18 I what's mentioned in today's paper? I 19 DR. TRAVERS: Well, it's 'under review. .; 20 So I guess I really don't like to speculate on what 0
< 21 could happen. But these are --
I guess these are
'l. 22 g licensed operators?
l 23 MR. LANNING: Yes, they are. 24 DR. TRAVERS: And there have been some O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
l i l 224 l HEARING RE: MILLSTONE UNITS l l () APRIL 30, 1997 1 past examples where licenses have been pulled by NRC. 2 And there have been, actually, examples of where people 3 have been banned from the industry, if I'm not 4 mistaken. 5 MR. BESADE: All right. 6 DR. TRAVERS: So while I, you know, I 7 don't speculate on the course of events that might or 8 might not take place in this instance, that is the kind 9 of option that's available to NRC, depending upon the 10 results of the evaluations that are under way. I l E 11 BILL: Okay. We will be having another l E ' r 12 meeting similar to this in another six weeks? 13 DR. TRAVERS: We'll be having another 14 meeting -- 15 A VOICE: Sooner. 16 BILL: I beg your pardon? 17 A VOICE: Sooner. 5 18 BILL: With the public. I 19 DR. TRAVERS: Yes. 3 E 20 BILL: Where we can come forward with O
= 21 additional questions.
Q 22 DR. TRAVERS: Sure. a b 23 BILL: Due to the hour, I think I'll let l 24 the rest of mine pass for this evening. And thank you ('T l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
225 HEARING RE: MILLSTONE UNITS I {} APRIL 30, 1997 1 people. l 2 DR. TRAVERS: Thanks. 3 MR. LANNING: Okay. I think we'll all 4 done. Thank you very much for coming. Appreciate the 5 questions. 1 1 6 l 7 (Whereupon, the meeting was adjourned at 8 11:21 P.M.) l 9 2 R , (~h
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i I 1 0 I e I b i l1 1 o O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102
t 1 CERTIFICATE I, Paul Landman, a Notary Public in and for the State of Connecticut, and President of Post Reporting Service, Inc., do hereby certify that, to the best ! of my knowledge, the foregoing record is a correct and verbatim transcription j l ! of the audio recording made of the proceeding hereinbefore set forth. 1 I further certify that neither the audio operator nor I are attorney or counsel for, nor directly related to or employed by any of the parties to the I action and/or proceeding in which this action is taken; and further, that neither lg the audio operator nor I are a relative or employee of any attorney or counsel E employed by the pariics thereto, or financially interested in any way in the l outcome of this action or proceeding. In witness whereof I have hereunto set my hand and do so attest to the above, this 20th day of May , 1997 l
$n S - Let =
Yaul Landman, President
- o i
i ii POST REPORTING SERVICE
] 1-800-262-4102
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