ML20149L374
| ML20149L374 | |
| Person / Time | |
|---|---|
| Issue date: | 07/18/1997 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3005, NUDOCS 9708010036 | |
| Download: ML20149L374 (380) | |
Text
fC.,g$F S006" Official Transcript cf Proceedings
'O NUCLEAR REGULATORY COMMISSION l
1 l
Title:
Advisory Committee on Reactor Sageguards l Plant Operations / Fire Protection Subcommittees ;
j TRO4 (ACRS)
! RETURN ORIGINAL TO BJWHITE l M/S T-2E26 l Docket Number: (not applicable) 41s-713o j THANKS!
l l l Location: Arlington, Texas t l0 -
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1 Date: Friday, July 18,1997 l l T m
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4 DO NOTREMOVE FROM ACRS OFFICE Work Order No.: NRC-ll77 Pages 1-241 l 9708010036 970718 PDR ACRS T-3005 PDR llll{ll{]ll',l ll{lll lll ll
. NEAL R. GROSS AND CO., INC.
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DI8 CLAIMER i *
- j. PUBLIC NOTICE l BY THE *
! UNITED STATES NUCLEAR REGULATORY COMMISSION'S !
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS i
JULY 18, 1997 4
5 i
The contents of this transcript of the proceedings of the United States Nuclear Regulatory D Commission's Advisory Committee on Reactor Safeguards on JULY 18, 1997, as reported herein, is a record of the discussions ,
recorded at the meeting held on the above date.
This transcript has not been reviewed, corrected and edited and it may contain inaccuracies.
I l
O I i
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION l
- k. ') 3 +++++
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) 5 +++++
6 PLANT OPERATIONS / FIRE PROTECTION SUBCOMMITTEES 7 +++++
8 FRIDAY, 9 JULY 18, 1997 10 + ++++
11 ARLINGTON, TEXAS 12 +++++
13 The subcommittees met a': the Nuclear Regulatory
(- -
bv/ 14 Commission, Region IV Headquarters, Suite 400, 611 Ryan 15 Plaza Drive, Arlington, Texas, at 8:00 a.m., John H.
16 Barton, Chairman of the Subcommittee for Plant Operations, 17 presiding.
18 SUBCOMMITTEE MEMBERS:
19 JOHN H. BARTON, Subcommittee Chairman 20 DANA A. POWERS, Subcommittee Chairman 21 MARIO H. FONTANA 22 THOMAS S. KRESS 23 DON W. MILLER 24 ROBERT L. SEALE
(~T.i r
(w/ 25 WILLIAM J. SHACK NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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2 1 ACRS STAFF PRESENT:
7- 2 JOHN T. LARKINS, Executive Director
! )
3 AMARJIT SINGH 4
5 ALSO PRESENT:
6 ELLIS W. MERSCHOFF, Regional Administrator 7 JIM DYER, Deputy Regional Administrator 8 DWIGHT CHAMBERLAIN 9 VINCENT EVERETT 10 T. PAT GWYNN 11 KATHLEEN HAMMILL 12 ARTHUR T. HOWELL 13 BILL JONES gg
\_J 14 JOCELYN MITCHELL 15 KEN PERKINS 16 DALE POWERS 17 JEFF SHACKELFORD 18 BLAIR SPITZBERG 19 20 21 22 23 f
24 y~.
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3 1 A-G-E-N-D-A
,3 2 Acenda Item Pace s i
('/
3 Opening Remarks by Subcommittee Chairman 4 4 Opening Remarks by Member Powers 5 5 Opening Remarks by Member Seale 7 6 Introduction by the Regional Administrator 7 l
7 Activities for Mair.taining Uniformity Among Regions 39
)
i 8 Fort Calhoun Steam Extraction Event 95 9 Region IV Interface with INPO 128 10 Fire Protection Issues 132 11 Senior Reactor Analyst Programs 145 12 Risk Associated with On-Line Maintenance 158 13 Region IV Inspection Program 178
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's>' 14 Decommissioning and Dry Cask Storage 224 r^s
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4 1 P-R-O-C-E-E-D-I-N-G-S 7-- 2 (8:00 a.m.)
'~
3 CHAIRMAN BARTON: Good morning. The meeting 4 will now come to order. This is a meeting of the ACRS 5 Joint Subcommittees on Plant Operations and Fire 6 Protection.
7 I am John Barton, Chairman of the Subcommittee 8 for Plant Operations. Dr. Dana Powers is the Chairman of 9 the Subcommittee for Fire Protection.
10 ACRS members in attendance today are Mario 11 Fontana, Thomas Kress, Don Miller, Robert Seale, and 12 William Shack.
13 The purpose of this meeting is to discuss i )
\. / 14 Region IV activities and other items of mutual interest, 15 including significant operating events and fire protection 16 issues. The subcommittee will gather information, analyze 17 relevant issues and facts, and formulate proposed 18 positions and activities as appropriate for deliberation 19 by the full ACRS committee. Amarjit Singh is the 20 cognizant ACRS staff engineer for this meeting.
21 The rules for participation in today's meeting 22 have been announced as part of the notice of this meeting 23 previously published in the Federal Register on June 17, 24 1997. A transcript of the meeting is being kept and will
(%
!. ,) 25 be made available as stated in the Federal Register NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 notice.
ps 2 It is requested that the speakers first j e
s j
l .
'/ 3 identify themselves and speak with sufficient clarity and 4 volume so tnat : hey can be readily heard. We have 5 received no written comments or requests for time to make 6 oral statements from members of the public. I l
7 On behalf of the Committee, we are pleased to i
8 have this opportunity to meet with members of the Region l l
9 IV staff. Some of the activities of the Plant operations 10 Subcommittee of the ACRS include visits to the various 11 sites and monitoring of regional activities. Yesterday, 1
12 the committee had an opportunity to visit Comanche Peak. l 1
1 13 At this time, I'd like to ask Dana Powers if l
(_) 14 he has any opening remarks. .
l 15 MEMBER POWERS: I'll make the opening remarks 16 about what the plans are for the Fire Protection l l
17 Subcommittee. The Commission does anticipate formulating 18 some sort of a performance-based alternative fire 19 protection regulations and review plans.
20 The Fire Protection Subcommittee and the POA 21 Subcommittee both have been following the development of 22 performance-based fire regulations throughout the world 23 over the last few years, and in particular concerned how 24 they might be applied to particular objectives of the NRC.
f~% 25 We are anticipating some heightened activity
(
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I 6
1 as the staff develops its plans in connection with a s 2 performance-based alternative to the current fire i
~'
) l 3 protection regulations, and so the Fire Protection l 4 Committee is in the business of gathering information in 5 anticipation of forming an ACRS position on these 1 1
6 regulations.
7 This is the first of our expeditions that we 1
8 anticipate making to the various regions to better 9 understand what the situation with respect to fire 10 protection.
11 CHAIRMAN BARTON: Thank you, Dana.
12 The chairman of the ACRS Committee, Dr. Seale, 13 is here also, and, Bob, would you like to say something?
lq t
'w_/ 14 MEMBER SEALE: Well, since we're starting a 15 little late, I'll hold my remarks to a minimum. I would i 1
16 like to say we're very pleased to be here. We had an 1
17 excellent visit out at Comanche Peak yesterday, and we I
18 look forward to talking to everyone here.
19 I'll give you a heads-up on one thing that you 20 might be -- you might want to know about. One of the 21 things we are also interested -- we are interested in is 22 the inspection program and how it's going to reflect some 23 of the performance-based regulation implementation issues.
24 It's a different process or at least we think it should 7
!\> i 25 be, and we would like to know how the regions are -- after
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7 1 all, they're the ones that -- where the rubber meets the s 2 road -- are tooling up to meet that somewhat modified )
l \
~'
3 challenge.
l 4 I think that's all I want to say, except I'm 1 5 glad to be here, and I really am looking forward to the 1
6 meeting.
7 CHAIRMAN BARTON: Also in attendance is John l
8 Larkins, who's the executive director of the ACRS/ACNW and l 1
9 Jocelyn Mitchell, representing the EDO's office.
10 At this time, I'd like to turn the meeting 11 over to Ellis Merschoff.
12 MR. MERSCHOFF: Thank you. Welcome to Region I
13 IV. We really are delighted to have you here, providing r~N s 14 an opportunity for the staff to tell you just what it is 15 we do and answer any questions you may have.
16 Unfortunately, we have some competing demands 17 for our time today. As you're probably aware, Hurricane 18 Danny spun up in the Gulf yesterday and came ashore at 19 3:00 a.m. near the Waterford site. We activated our 20 emergency response center to monitor the storm. We have 21 dispatched inspcetors to the site and have been following 22 that throughout the evening. I'll need to spend some l 23 amount of time today following that effort as well.
24 Right now, the storm remains a hurricane.
[)
(,,/ 25 It's sitting over the Delta, and the Waterford plant is in l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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8 l
1 mode 4, cooling down, but the conditions at the plant have '
I
,_.s 2 not been particularly severe. l
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( )
3 In terms of important things, lunch: You i
4 should have all received a blue envelope and the menu. As 1
5 early as possible this morning, if you could circle your I 6 choices, include any special instructions, information, 1
I 7 with or without mayo, include 8 percent tax -- !
l 8 CHAIRMAN BARTON: Welcome to the great State l l
9 of Texas. I 1
10 MR. MERSCHOFF: That's right. And restrooms: i 11 Restrooms are adjacent to the elevators.
12 Moving right along, we've prepared a wide- ,
l 13 ranging discussion today in terms of Region IV issues, (m / 14 covering the organization, our responsibilities, 15 uniformity among the regions, how it's maintained, some 16 particularly interesting events: the frazil ice instance 17 at Wolf Creek, the steam extraction line rupture recently 18 at Fort Calhoun, and various fire protection issues, 19 events, that the Region has responded to.
20 We have a discussion from our senior reactor 21 analysts in terms of PRA and how we're working that into 22 the regional inspection program, the SALP program, the l 23 master inspection plan, the PIM, the sorts of things that 24 are discussed and an important part of our program and in n
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1 9
l l
1 today.
I l ,-
- 2 It's fairly voluminous; it's fairly extensive.
ld 3 And we're extremely responsive to your interests. If you l l
4 want us to speed up, slow down, or change course, you've l I l
S got the right people here to do that.
6 The speakers -- and I'll go through their l
l 7 background here shortly -- are the right ones to address ,
1 l
8 your questions relative to the inspection program. They ,
l 1
9 have each been inspectors and involved in managing the i 10 inspection program through the year and currently have 11 that responsibility within the region. l l
12 Before I turn the meeting over to Jim, I'd I 13 like to go through briefly the key speakers that are I, i i
\~/ 14 listed on your agenda, so you get some sense of the 15 diversity of the leadership and management here in Region 16 IV and the experience that we bring to bear.
17 Jim Dyer is the Deputy Regional Administrator, j 18 14 years' experience with the NRC. Jim's been an 19 inspector in the office of INE; section chief for the 20 special inspection branch in NRR; regional coordinator and 21 chief for the EDO staff; a project director in NRR for 22 bench reactors and for Region III and V reactors. He has 23 been the director of reactor projects in Region IV, now j 24 the Deputy Regional Administrator and operating experience
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k) 25 in the Navy.
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10 1 Pat Gwynn is a presenter. Pat, who is
,, 2 probably up babysitting Hurricane Danny at the moment, is l \
,\
) 3 the Director of the Division of Reactor Projects here in 4 the Region. He has been with the NRC for 17 years. He 5 has worked at the Bettis Atomic Research Laboratory, been 6 a senior resident inspector at the Zimmer and Clinton 7 sites, a technical assistant to Chairman Zech, director of 8 the Division of Reactor Safety here in Region IV, and has 9 operating experience from the Navy. l 10 Art Howell, I believe, is with us. Art's 11 currently the director of the Division of Reactor Safety l
12 in Region IV, 12 years' experience with the NRC. He's !
13 been an inspector in the office of INE, member of the r~N, e
1
(_,/ 14 diagnostic evaluation and incident response branch in 15 AEOD, participated in numerous diagnostic evaluations.
I l
16 4e's been the deputy director of DRP and has operating 17 experience from the Navy. )
i 18 Dr. Blair Spitzberg, who'll speak this 19 morning, is not with us yet. As I said, there's a lot l 20 going on, so we'll have folks coming in and out. Dr.
21 Spitzberg's currently the chief of the nuclear materiale, 22 inspection fuel cycle and decommissioning branch. Dr.
23 Spitzberg has worked as a materials inspector, as a fuel 24 cycle inspector, and emergency preparedness inspector, and
,m 25 the chief of the nuclear materials and licensing branch.
(\.s)
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11 l
1 And Dr. Spitzberg will be speaking today on 1
decommissioning and dry cask storage.
,_s 2
/ i
'\ ,
'l 3 l
Additionally, our two senior reactor analysts, 4 Jeff Shackelford and Bill Jones, will be talking some 5 about that program and the use of PRA. Jeff who is here 6 has worked with Pickard, Lowe & Garrett in the development 7 of PRAs. He's been an inspector in the Region II-Atlanta 8 office. He's worked in NRR, in the PRA branch; currently 9 in Region IV as our SRA, and has operating experience with 10 the Navy.
11 And, finally, Bill Jones -- Bill is currently 12 in the emergency response center and has been monitoring 13 Hurricane Danny through the evening, as has Pat Gwynn, so i
_-) 14 your presentations from Mr. Gwynn and Mr. Jones should be 15 particularly interesting, considering they're done on a 16 minimum amount of sleep.
17 Bill has been the senior resident inspector at 18 both BWR and PWR plants and extensive inspection 19 experience here in Region IV.
20 Region IV has recently undergone a significant 21 change in terms of the managers. In fact, if you'll look 22 at the ten senior executive-level managers in the Region, l 23 only three of them were in the same position that they 24 currently hold that they had been a year ago. So in the 7-.s (w/ ) 25 course of the discussions in these areas, a question asked l NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l l 12 l
1 may well be answered by so.ieone else, because that person l
! 2 is the incumbent with t'le knowledge.
7-~
\' ,) 3 The corporate knowledge is here, and mixed 4 around, it makes for a stronger organizaLion in the long 5 term. But we are an organization undergoing change and 6 working in the sleep-deprivation mode for at least a 7 couple of the presenters.
8 That ends my opening remarks, and unless there 9 are any specific questions, I'd like to turn it over to 10 Jim, Deputy Regional Administrator, and step out and see 11 how my incident response is going.
12 CHAIRMAN BARTON: With a strong staff like 13 that, it sounds like your job is pretty easy.
/m i
\_-} 14 MR. MERSCHOFF: It is. I 15 MEMBER SEALE: We were arguing as to whether l
16 it was Hurricane Danny or Hurricane Dana. 1 17 MR. MERSCHOFF: It's a minimal strength 18 hurricane, so it must be Danny.
19 MR. DYER: Thank you. My name's Jim Dyer.
20 I'm the Deputy Regional Administrator for Region IV. And 21 just a point of clarification: Ellis presented a regional 22 organization that's a lot more stable than that. He said 23 a year. Actually the reorganization took place in 24 February to March, and so all of us have been in our job rx 25 about three months.
i(%.-)
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13 1 I guess just a bit of a geographic -- and I
,- 2 guess before we start off, I'd like to -- since we're
\ )
3 trying to catch up a little bit, if there's parts that you 4 want me to waive off, just give me a high sign, and we can 5 skip to the -- you know, the chase in that.
6 But overall Region IV, the major regulated 7 facilities within the Region, we have 14 power reactor 8 sites, 21 operating reactors at those sites, and two power 9 reactors that are in construction that were -- have been 10 subsequently mothballed and they're applying for 11 decommission up at the WNP facilities.
12 We have 20 test and research reactors that 13 were within the last two weeks have just been transitioned
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t/ 14 to headquarters for complete regulatory oversight. We l l
15 were the first region to transition all our non-power 1
16 reactor regulation activities back to headquarters, and we l l
17 just boxed up everything and finally got it shipped out j l
l 18 about two weeks ago.
19 We have two uranium fuel fabrication j 20 facilities, the General Atomics facility in San Diego and 21 the Siemens Fuel up in Washington, and 1,241 byproduct 22 materials licensees.
23 The history of Region IV is somewhat -- in l 24 April of '94, we transitioned where the consolidation of
()
p m.
25 Regions IV and V took place, and it created our Walnut NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 l 1 Creek field office; additionally followed up from that in 73 2 October of 1995, we took one site from both Regions III
( )
3 and II. The Grand Gulf site transitioned from Region II 4 to Region IV, and the callaway site transitioned from 5 Region III to Region IV.
6 The Callaway SALP just ended up -- the first 7 SALP in Region IV just ended up in -- last month, and that 8 was really the final part of the transition plan where we 9 fully transitioned total ownership for Region -- I mean, 10 for Callaway into the Region IV facilities.
11 The one unique aspect about those two 12 transitions were the States of Mississippi and Missouri, 13 as far as our state programs liaison goes -- Regions II 73 Y b
(_/ 14 and III still have ownership for those states, as far as l l
15 the material licensees and that our state interactions are l 16 limited to just for the reactor and emergency planning 17 focuses in that. So in this case, the way we regulate is 18 those two states have to deal with two different regions 19 within the NRC. I 20 MEMBER POWERS: How do they feel about that?
21 MR. DYER: They're getting used to it, but 22 it's not been -- that was probably the stickiest part of 23 the transition. When we did it in such a hurry, we made 24 the decision, and we did it -- getting state interaction
! f~
l (%) 25 was probably our biggest lesson learned for that.
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15 i
)
1 I think we did a much better job when we j 2 transitioned the non-power reactors recently, because we
( )
i
'/ l 3
went out -- once we had made the decision and came up with l l
l 4 a schedule, we interfaced with all the states that were 5 going to be affected. I think Dwight Chamberlain was the 6 principal -- and Charles Hackney were the principal go- l 1
7 betweens in those efforts and that.
l 8 But we alleviated -- answered a lot of the 9 questions, made them feel a little more like they were --
10 they had the right to refuse and that. I think, if I'm 11 not wrong, I think we only had one state really -- the 12 State of Kansas had some concerns, and they may write a 13 letter. But it was just because we increased their --
n is ,) 14 they had to get acquainted with new faces in dealing with 15 the NRC, and that was just the normal change process.
16 Overall, the Region's organized with four 17 di. visions, three line divisions that -- as the other 18 regions are -- three line divisions that support the 19 materials and the reactor facilities, and then our 20 division of resource management and administration, who 21 Kathleen Hammill is the division director. She's sitting 22 a the corner, and I invited her here in case there was 23 any questions about the DRMA support area and that.
24 Additionally, we also have the Walnut Creek n
() 25 field office, which has constituents or components from NEAL R. GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHODE ISLAND AVE., N W.
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16 1 each of the four divisions. They report to Ken Perkins in
,_ 2 the field office. He was the former DRP director and
( )
- 3 regional administrator in Region V when we consolidated 4 the office and that.
5 You know, the regional responsibilities, in G an -- probably an over-simplified, we have four principal 1
I 7 responsibilities: that of being inspection, enforcement, l
8 licensing activities, and, of course, incident response, l 9 which we're playing a role in significantly today. ,
l 10 MR. LARKINS: How large is the Walnut Creek 11 office?
12 MR. DYER: I think it's right around 30, 30 13 people.
(w
(- 14 MEMBER SEALE: What subset of the Region IV 15 reactors are -- work through the Walnut Creek office?
16 MR. DYER: We have -- well, you'll see it when 17 we get to the DRP organization. Nominally, we have the 18 four former Region V sites managed from the Walnut Creek 19 field office; the DRP contingent was there.
20 MEMBER SEALE: Yes.
21 MR. DYER: Because of the problems at 22 Waterford 3 site, we have dedicated a branch here in 23 Arlington to support Waterford, and because of the l
l 24 distribution of resources between Arlington and Walnut
, ) 25 Creek, we were able to -- we created a new branch in DRP, v
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17 l l
l 1 a temporary branch in DRP, for River Bend and Grand Gulf
/
s\ 2 that is currently managed from the Walnut Creek field I
\ )
3 office. j l
4 It's a temporary branch until we get through 5 the increased enforcement and inspection activities at the 6 Waterford 3 site. We just over-stressed our DRP i 7 organization here, and one of the things we learned --
l 8 The staffing levels of Walnut Creek, you know, i l
9 back in '94 when we collapsed the former Region V, if 10 anything, given the current budget cutbacks and that and i l
11 staff levels that the Region has gone through, as well as 1 12 all the other regional offices -- and the turnover has l l
13 been lower in Walnut Creek, so they're not stretched as
( ~
1 l
(.d' 14 thin as we are here in Arlington, and so we stretched them )
l 15 a little bit by transferring oversight for those 16 facilicies. l i
l 17 Walnut Creek has no incident response i 1
18 activities. Their incident response center was taken 19 down, and we manage all the incident response out of here 20 in Arlington. But the overall inspection work, sign-out, 21 enforcement preparations and that, we do from Walnut l
22 Creek.
23 The office of the regional administrator, 24 -
again, it has Ellis and myself. We also have a number of n
() 25 staff functions which support the various activities.
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l 1 1
18 i :
1 Again, some of those staff functions also have a l
2 contingent office out in the Walnut Creek field office, 7-
\'-') 3 namely the public affairs and the state liaison i
l 4 activities. !
5 I think in recent times, given the added 6 emphasis on public affairs, interaction with the states in ,
1 7 enforcement and allegation activities, this role of staff ,
i 8 functions' importance has grown significantly, I would )
9 say, in the past six months to a year. And so this is an I l
l 10 area that we're continually looking for new ways to :
l 11 improve the way we manage those functions in particular.
12 And the regional counsel's involvement with 13 the increased workload we have on allegations of willful j
/s ,
vs 14 cause, intimidation and harassment -- that's an area that 15 we're really not familiar as engineers and operating .
I 16 backgrounds in our dealings with, and we've been putting l 17 the stress on Bill Brown, in particular, to help the staff 18 in his participation in our weekly allegation review 19 meer'ngs and our -- all our enforcement activities and our 20 review of a lot of our OI activities and that has been 21 significant.
22 The current DRP organization, which I hope you 1
23 can find in your handout, because I don't think you'll be 24 able to read it from the -- on the slide, but our current 7-( ,) 25 DRP organization is one, as I said -- if I had to correct NEAL R. GROSS COURT REPORTERS AND TRANSCRIBEF.S 1323 RHODE ISLAND AVE., N.W.
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l 19 1 this slide, it would be that the Walnut Creek field office l
,-s
, 2 staff, which is in your left-hand, is really -- it's
(!
3 actually a component of the office of the division 4 director, as much as -- if you had to move that box, it 5 should have probably been right underneath or as part of 6 the office of the division director of DRP.
7 Ken Perkins, because of the supervisory 8 responsibilities, has a lot of the DRMA functions and that 9 are all assigned to this because of we have to have direct 10 oversight of employees and that for appraisals and 11 supervision and time and attendance reporting and that, so 12 for --
13 They take administrative supervisory oversight p.
> t
\~ 14 from Ken Perkins in the field office, but they take 15 program direction from Kathleen in -- here in Arlington, 16 Texas.
17 Additionally, as it's called out here, reactor 18 projects branch G is the temporary branch I spoke of. 4 l
19 It's in the lower right-hand corner, right next to I 20 technical support staff. Thf , branch we created towards 21 the end of February; actually, I guess, towards the end of 22 April time frame. And it was largely because of we have a 23 special branch.
24 We unloaded Branch D, which previously had the
.Q
's_j 25 three Entergy -- three of the four Entergy sites, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 we've had a significant amount of enforcement and safety
,_ 2 issue activity at the Waterford 3 plant recently, and as a 5 /
result of that, we had to unload the DRP branch.
3 We 4 just -- we weren't providing adequate attention to either 5 Grand Gulf or River Bend in that, because Waterford 3 was 6 simply dominating.
7 Overall, I guess, my over-simplification of 8 the role of DRP, you have some specific items in there, 9 but DRP is, in my mind, analogous to a general 10 practitioner in the medical profession. You know, as far 11 as maintaining cognizance of the health of the licensee, 12 they're the generalists.
13 They're responsible for all four SAL 73
- i
\s ,/ 14 functional areas. They monitor the implementation, 15 whether it's, you know, rad waste transportation, 16 engineering modifications, operations, any examinations 17 and that. They have to be the eyes and ears for the 18 Region, and their sensitivity as a generalists role is 19 to -- if they have a problem is to raise it through their 20 morning meetings and contact with their DRP branch chief, 21 and then we get the proper support, either from our other 22 divisions and DRS and DNMS or from the program office and 23 headquarters.
24 But the demands on the resident inspectors and 25 the DRP branch chiefs are to be our first line of defense, (a) i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 21 1 our screening filter, and to provide the first cut as to
,s 2 what we need to pursue and that. So -- and that's largely l \
3 their role.
4 Additionally, they have the incident response 5 responsibilities and site coverage activities that go on, l 6 that require around-the-clock coverage or back-up site 7 coverage.
8 DRS, on the other hand, is our -- is organized ,
1 9 on the -- based on the four SAL functional areas. We have 10 the engineering branch, maintenance, operations, and the 11 plant support branches. Art Howell, who is sitting in the 12 back, is the director of the division of reactor projects, l 13 and Dwight Chamberlain, who's handling the slides, is the i
,m I i
\_./ 14 deputy director of the division of reactor projects. l 15 The -- back -- hearkening to my medical 16 profession analogy and that, this is our specialist. They 17 pretty much conduct -- there's -- in the core and in the 18 regional initiation inspection activities, as far as plant 19 inspection goes, they do the planned programmatic reviews 20 in the various SAL functional areas., in accordance with 21 the inspection modules that have been issued from the 22 program office.
23 Additionally, they do a lot of reactive l
1 l 24 inspection activities that are in fcllow-up to either i'~
(h) v 25 events, allegations, or just something that the resident NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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22 1
1 1 inspectors stumble upon that either goes above their 73 2 abilities or the resources to get the work done, so we --
I 1
\ /
'~#
3 they tend to get redirected and aligned as far as 1
4 scheduling and that goes. They have to -- they get their j 5 ochedules changed on a routine basis.
6 MR. LARKINS: Jim, I've been away from this 7 for a while. Let me ask a quick question. On the project i
8 side, it looks like you guys have gotten away from the N-9 plus-one, and I guess it's sort of just placing residents 10 and others where -- as needed.
11 MR. DYER: No. We are at N-plus-one at -- I 12 think all our sites officially -- we just lost -- at 13 Comanche Peak, you know, we just issued -- our only four I i
\s/ 14 SALP 1 performer is now Comanche Peak. Callaway was a 15 four SALP 1 performer, but it was a single-unit site, so 16 we had two residents there for coverage.
17 Comanche Peak is a dual-unit site with four 18 SALP-1s. We are now requesting permission to go to N )
i 19 residents at Comanche Peak, but that's our only all SALP-1 20 performer.
21 MR. LARKINS: It looked Diablo Canyon and Palo l
22 Verde were.
23 MR. DYER: Diablo Canyon a four SALP-1 24 performer, and we withdrew it after their last SALP and (p) 25 went to N-plus-one, and as soon as we did that, the other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS .
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23 1 resident inspector who was already there got selected for l
, ,s
, 2 senior resident at WNP-2, and so we currently have an i \
'~
3 opening in that -- at that site.
4 And Palo Verde, we've had a tremendous 5 turnover in all our resident staff at Palo Verde. I think 6 we've lost them all within six months.
7 MR. LARKINS: Nobody likes Arizona.
8 MR. DYER: Actually, it was the alternatives 9 beyond Arizona that -- if we would have -- they would have 10 stayed there if we would have left them in Arizona. The 11 big question with the resident program is, of course, 12 moving.
13 MR. LARKINS: I guess basically you're saying
(~s
! )
\/ 14 you're still basically implementing N-plus-one.
15 MR. DYER: We are implementing N-plus-one. ,
i 16 MEMBER SEALE: You mean they stayed in i 17 Arizona, but they quit the Commission.
18 MR. DYER: Actually I think some of them --
19 they wanted to go farther west, but they weren't about to 20 come east. We aren't really posting and filling any 21 additional jobs in the Walnut Creek field office, and so 22 they have a choice. They can either go to another site, 23 or they could move east, and both alternatives were not l
24 acceptable. And so some of them have left to go to DOE; i em (jI
/
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24 1 and go back to school and that.
7- 2 Again, one of the things that is, as I said, 3 going through the major functional responsibilities within 4 DRS -- we use them in the four SAL functional areas, and 5 they are very focused, programmatic. They give us a 6 different cut set, too. Where -- I call it a silo effect, 7 with the DRP, where what we have is a generalists 8 understanding of all four SAL functional areas at that 9 site and can integrate across those areas for common 10 weaknesses.
11 DRS gives us a different type of cut set.
12 Because of the branch organizations, we can get a cut set i
13 of -- across the operations area, for instance, what is
/~T
-- l 14 the sense in operator licensing across all 14 of our 15 sites? And John Pellet, the operations branch chief, we 16 expect him to be able to give that different perspective 17 from what DRP has. DRP does not have that perspective, 18 except maybe at the division director level. And by then, 19 you're on data overload, and you just don't have enough of 20 a focused look.
21 So I think the valuable insights come from the 22 DRS branch chiefs in looking at each of the four SAL 23 functional areas and comparing and contrasting strengths 24 across all 14 sites.
/^\
One of the things that we focus on here in
(_) 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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25
- 1 Region IV in accomplishing the inspection program is we l
.- 2 try to do as many team inspections as we can. We've found
/
s i
'- 3 that we get sort of a synergistic effect if you can 4 combine, say, engineering, the individual engineering 5 modules, and go out and take a look, you know, in total in l
6 seeing -- you know, getting the feedback across the lines l
7 in multi-disciplined areas and as opposed to individual, l 8 discrete inspection activities done in the various areas, 9 so we try to do all our engineering activities or our 10 plant-cupport activities as much as we can in groups.
11 Some regions will do them individually and 12 discrete, and then integrate them back in the regional l 13 office. We try as much as we can to do it in a team l
('~\ l
,) 14 environment.
15 Overall, division of nuclear material safety, 16 who's Ross Perrano and Linda Howell, and both are out of 17 the office today -- as far as -- we have a nuclear 18 materials inspection branch, a licensing branch in the 19 materials area, and then we also have a contingent in the 20 Walnut Creek field office which sort of has all aspects of l
21 it.
22 I think as far as in the reactor interface and i
l l 23 that, we handle our decommissioning inspections activities 24 from the NMSS or DNMS branch, branches. Additionally, we g.
i V) 25 do our dry cask storage inspection, which I believe is NEAL R. GROSS QURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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26 1 Blair's subject this afternoon, from the division of
- 2 nuclear material safety.
!, )
3 Our division of resource management and 4 administration is, of course, the support groups that keep 5 us out of trouble, keep us in, you know, airplane tickets 1
6 and that, and keep the lights on, and all the activities.
7 I think as far as the inspection area where 8 we're changing the most and that is probably in the l
9 computer support areas and being able to effectively l
10 communicate between the sites and here, and to transfer 11 data bases between the regional office and headquarters is 12 part of a -- you know, the next panel discussions we're 13 talking about some of the activities that we do of
/~ 1
- k. 14 communicating our findings and maintaining uniformity 15 among the regions.
16 Probably key of that is the concept that's 17 relatively new called the plant issues matrices which has 18 been basically a reader's digest of the significant 19 findings within the Region at various sites and that by 20 functional areas.
21 And to get that data not only from the 22 regional branch chief to the division directors to the 23 regional administrators to the various projects and 24 headquarters management offices in headquarters is -- the 25 communication of that data in a discrete, accurate format
()
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7 27 1 that is -- that's really key to getting a proper 73 2 assessment and a focus that allows accountability, better
)
\m/ 3 oversight and that.
4 And right now, getting the information and 5 transferring it effectively from the site to regional 6 office and from regional office to headquarters is one of i
7 our major challenges that we're undertaking and facing in l 8 that. I i
i 9 MEMBER POWERS: I just wondered if the PIM has )
i 10 been set up so that everybody had access to it, or is it 11 still one of those things that's in the offing? l l
1 12 MR. DYER: Right now, we have it on our --
13 what we call our R-drive, I think is the -- and that's our i (TN
, _i i
\_d 14 read-only drive. And it's a manual operation that each of i 1
15 the divisions has it on another subdirectory drive where 16 they maintain it, and then they QA it, and then 17 periodically, which has been the discussion of how 18 periodically, it gets updated on the formal R-drive to 19 where it's cast in concrete.
20 But then the problem we've had is the data 21 base, when you put 18 months' worth of data in there, is 22 getting so large, it gets rather cumbersome and 23 transferring it and shipping it to headquarters. As far 24 as I can tell -- Kathleen, correct me if I'm wrong -- I q ,/ 25 believe the headquarters does not have access to our read-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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28 1 only drive. That's one of the data base issues and
,- s 2 computer support issues that we're still working on.
e
\
l 3 But that R-drive also has the electronic copy 4 of all our issued inspection reports and formal inspection 5 report responses and everything else, and typically, when 6 we get ready to do a periodic review, we're manually 7 transferring the data to headquarters. And if we transfer 8 all 14 sites, 18 months' worth of data, it's a load.
9 MEMBER POWERS: But I can -- right now I can 10 go through and scan Comanche Peak or something like that.
11 MR. DYER: You could if you were in this --
12 MEMBER POWERS: In this building.
13 MR. DYER: -- building.
i'3 iY 14 Okay. I think that completes my presentation 15 on the regional organization and how we're set up. I'd be 16 happy to entertain any questions you may have.
17 MEMBER KRESS: How many people do you have in 18 the whole region and how many are here?
19 MR. DYER: There's 203, I think, in the total 20 region. Kathleen, how many are here?
21 MS. HkAMILL: Well, there's 35 sites plus --
22 about 130 are here.
23 MR. DYER: About 130 people are stationed in 24 the Arlington office. We're on three floors, 3, 4, and 5, i
,s 25 here.
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29 1 (8:30 a.m.)
3 2 Any other questions?
'V 3 (No response.)
4 MR. DYER: Okay. That concludes my 5 presentation, and right now -- I made up the time. Do you 6 wish to continue, or do you want to take a break?
7 CHAIRMAN BARTON: We'll keep on going.
8 MR. DYER: Okay. I guess the next part of our 9 presentation is a panel discussion. I don't know if Pat 10 Gwynn -- the last -- we had a Commission briefing l
11 scheduled originally for 8:30 on Hurricane Danny, and then 12 Pat came in and said it looked like it got delayed till i
13 nine o' clock, so it may be that Pat's in -- !
(' ~a x- 14 CHAIRMAN BARTON: Why don't we take a break 15 then, and we'll see where Pat is.
16 (Whereupon, a short recess was taken.)
l 17 MR. DYER: I'm Jim Dyer, Deputy Regional 18 Administrator, and now we're doing the panel discussions.
19 I think by the way we were going to do the -- we set up to 20 do the panels, we assigned leads to the various topics and 21 that. As Ellis said in his introductions, because of our 22 recent job transitions and that, if you ask a question 23 that normally would be answered by the DRS director, it j 24 might get answered by the DRP director and that.
( ,) 25 Pat Gwynn is -- as I said, he's up doing a l
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30 1 Commissioner's t'ech assistance briefing on Hurricane
,- 2 Danny, so he'll join us in progrr.ss. I also have Dwight
(' )
3 Chamberlain, the deputy director of the division of 4 reactor projects, representing DRS, and he has specific 5 inspectors who will -- and branch chiefs to discuss the 6 various topics that you asked about.
7 I think overall, first of all, I was going to 8 discuss the activities for maintaining uniformity among 9 the regions and our training program, training and 10 development program, so I'll begin our formal 11 presentation. Again, we're very flexible. If you want to 12 cut to the -- you know, ask questions, however you want to 13 work it, we can --
O
(_,1 14 MEMBER POWERS: One of our members who was not 15 able to attend would interrogate you closely on your j l
16 training in the PRA area, so to assure his queries get l
17 answered, even though he's not here, you might touch on 18 the training in the PRA area.
19 MR. DYER: Okay. Where's Jeff Shackelford?
20 Join us. Jeff is one of our recent senior reactor 21 analysts, graduate and that, and can probably address the 22 level of detail to the inspectors and that.
23 MEMBER POWERS: I'm sure that we'd want to 24 explore the issues of not only what the training is but im 25 how they understand the uncertainties of PRA, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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l 31 1
1 incompleteness issues, the limitations.
,. _s 2 MR. SHACKELFORD: Just to give you a brief 1
\ )
l
l 3 overview of that, myself and my counterpart, Bill Jones, 4 who'll be giving you a presentation this afternoon, are 5 the senior reactor analysts in the Region, and I'm not l
6 sure how familiar you are with that program.
7 Basically every region now has two senior 8 reactor analysts and there are two at headquarters, and we 9 are the PRA designees, if you will, for the Region, and we 10 had an extensive training in PRA from the Agency.
11 My own -- in my own background, I worked for 12 Pickard, Lowe & Garrett for a number of years, and I have 13 a specific industry experience, and the other SRAs 7
h l (_ / 14 throughout the country have various backgrounds and so 1
15 forth, so we would represent, I guess, the highest level 16 PRA expertise that the regions have, and our job is to 17 coordinate risk-informed activities throughout the Region 18 and sort of support the rest of the Region.
19 MEMBER POWERS: I guess the question comes l
20 down to, what is the expectations for that expertise. Is 21 it a case of being knowledgeable about the current l 22 standards of application of PRA, or is it to be l
- 23 knowledgeable about the forefront?
24 MR. CHAMBERLAIN: You might want -- I don't r
(m,) 25 want to cut this off, but you might want to hold that l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 l
1 question for the presentation this afternoon.
I
- 7. 2 MEMBER POWERS: And if I ask questions that
(
) l 3 are appropriate to wait, I'm a patient --
4 MR. CHAMBERLAIN: Well, we're going to go into 5 what our expectations are and what we're trying to use 6 those people for.
7 MEMBER POWERS: Just to telegraph the kind of 8 questions that would be asked --
9 MR. SHACKELFORD: Bill has an entire 10 presentation tailored towards that very issue.
11 MEMBER POWERS: Very good.
12 MEMBER FONTANA: At some point, though, would 13 you discuss at all the implications of performance-based p
\_) 14 regulation on the Region?
15 MR. SHACKELFORD: It has a -- I don't know 16 that we have a specific session related to that, but I'm 17 going to be discussing the Fort Calhoun steam rupture here 18 shortly which has some maintenance rule implications which 19 are performance-based. That'd be a specific application 20 of that type of approach.
21 MEMBER FONTANA: Because I think it would be 22 of real interest of, you know, how do regions feel this 23 thing would be really -- the impact it would have on real 24 implementation.
r~x
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33 1 ac being a performance-based inspection, we did that to g- 2 some extent; I mean, not as informed, but that is an
\' ~ '
l 3 aspect that particular this region, in my mind, has always 4 been focused on is a performance-based orientation as 5 opposed to a programmatic review, paper review, to focus 6 on implementation, to focus on the consequences.
7 It was that very aspect that drove us, as I 8 said earlier, to the team inspection where we can -- you 9 know, if we find something, we can get an integrated look i
10 at it. What's this tell us about everything that's going !
11 on at the plant? And we had that to some extent.
12 I think the SRAs have provided a new dimension
]
1 13 that a lot of us dinosaur inspectors had never ever l l l'~h l k' 14 thrught of.
l 15 MEMBER FONTANA: Well, it would be interesting 16 to get their perceptions, because I -- the impression that 17 I've got is it means different things to different people.
18 MR. DYER: Do you have a specific example 19 you're thinking of?
20 MEMBER FONTANA: No. But we keep talking l 21 about it, and I'd like to say, Well, gee, you know, I'd 22 like to see one.
23 MR. DYER: You know, our perspective on, you 24 know, the performance-based inspection is that, yes, you
()
/w 25 focus on the implementation, on the consequences and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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34 l
1 results as opposed to focusing on whether or not all the l
, fs 2 process was followed and the procedures were adequate. ;
i(
) l 3 MEMBER POWERS: I guess that one of the things l l 4 that -- we would kind of like to use the maintenance rules 1
5 as starting force for a lot of performance-based 6 regulation that people are talking about nowadays. But 7 the question that comes to my mind is when I see drafts of l
1 8 these new performance either rules or reg guides or l i
9 standard review plans, is that there's a wide disparity in '
10 the interpretation of what performance means.
11 And in particular, there's a wide disparity in l
12 the amount of detail that you find in these. And so what 1
13 I would like to hear from you fellows is: What would you O)
\> 14 like to get? Do you want detail, like, Here's a 15 performance-based plan and it should have all of these 16 elements, in great detail? Or do you want something 17 that's much more flexible than that?
18 That kind of information and feedback, what 19 you're looking for when somebody says, All right; we're 20 coming up with performance-based rules, reg guides or 21 standard review plans, and -- or anything else, but those l 22 are the big three.
i 23 MR. SHACKELFORD: There's one example that I 24 think you may be aware. There's a move to change the O
( ,) 25 maintenance rules, the A-3 portion of the maintenance rule
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i 35 l
1 which now says that you should perform assessments and --
l i
7 2 MEMBER POWERS: Right.
'/
l 3 MR. SHACKELFORD: -- and the issues --
t 4 MEMBER POWERS: Says you shall or will or --
5 MR. SHACKELFORD: You will, you shall. And 6 the issue is: Should there be reg guides and so forth to l
7 tell you -- just making it a "shall" doesn't really make l
8 anything happen, and you need to know what we expect.
9 And we to some extent, the SRAs, are involved 10 in that. We maintain a counterpart relationship with the l
11 people who are working on these things, and so we -- you l 12 know, the Region doesn't make policy; we implement it. So l 13 we are cognizant of those activities, and that is
/~N l
(_j) t 14 something that's currently underway.
\
l 15 Dale Powers will be talking to you this 16 afternoon about the risks of on-line maintenance, and I 17 helped him a little bit with his presentation, and what 18 he's going to tell you is some of the results of some of 19 the maintenance real base-line inspections, with 1
20 particular emphasis on what people are doing in the A-3 21 portion of the maintenance rules.
i 22 And you'll see there's a wide range of l 23 approaches there, from very qualitative sort of seat-of-24 the-pants type assessments, all the way up to real-time s
( ) 25 calculations. And I think that's kind of what you're i
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36 1 driving at.
,, 2 MEMBER POWERS: Yes.
( \
~'
3 MR. SHACKELFORD: There's a performance-based l
4 aspect to --
5 MEMBER FONTANA: Yes. How do you guys feel 6 about it, and what do you think about what the 7 implications of trying to actually implement it are. Like 8 you say, you're already doing considerable amount of it, 9 but it seems to me that everyone -- it's in the eye of the 10 beholder. It seems to mean different things to different 11 people.
12 MR. SHACKELFORD: That is a very difficult 13 area, because I was on a lot of those early maintenance
/3
() 14 rule inspections. I just came to the Region from )
15 headquarters, as Ellis told you before, and I was heavily i 16 involved in developing the guidance that they use now to 17 assess that.
18 And given the fact that it says, should 19 perform the assessment, it makes it very difficult for an l 20 inspector to enforce that aspect of the rule, if nothing l
21 else. We can certainly go in there and make statements 22 about who's better than others. We can say -- you can 23 find weaknesses and give various approaches, but --
24 MR. CHAMBERLAIN: I think there's been, you n
() 25 know, complaints by the industry too that maintenance rule l NEAL R. GROSS l
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37 1 is supposed to be a performance-based rule, but we're --
-s 2 really our inspections are more programmatic, and that's p
\
)
3 probably a valid issue. In the earlier inspections at 4 least, we're looking at program, make sure they got the 5 programs in place.
6 For this new rule, hopefully -- we do discuss 7 performance-based issues. Every day when an issue comes 1
8 up, is that a performance-based issue and related to the 1
9 maintenance rule, whether we need to look at it in terms l 10 of how the maintenance rule dealt with that issue, so we 11 do that all the time.
12 But our maintenance rule baseline inspections 13 really are programmatic inspections.
rm I \ \
'Am- / 14 MEMBER POWERS: This is inescapable. Every 15 performance-based rule that I have seen put forward begins 16 by saying, Okay, you set up this program. Sooner or 17 later, somebody has to come along and say, Did you set up l 18 the p , gram and does it meet the requirements of the --
19 does it have all the elements of the program that it has 20 to have?
21 I mean, that seems to me that that's an !
22 inescapable thing that once that's in place, maybe the l 23 inspection's a good deal different after that, but at the 24 front end, you got to find out whether there's a program fm Q 25 or not.
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38 1 MR. SHACKELFORD: Well, the alternative to not 1
7s 2 looking at that would be to wait until something breaks.
I )
3 And we've said that we're not satisfied with that l
4 approach, so --
5 MEMBER SEALE: But even if you have a "shall" 6 rather than a "should" or a "will" rather than a "should,"
7 there's still the question of what the implementation of 8 that imperative is. Somebody -- everybody may implement 9 something, but it may not be the same thing.
10 MR. SHACKELFORD: That was brought up at the 11 Commission meeting on the maintenance rule where that was l 12 a big issue, and my comment was that the industry has 13 always assessed the risk of maintenance activities.
l f'~%
\/ )
i 14 That's what their SROs' job is, so there's no one out 15 there's going to tell you, We don't do an assessment.
16 The issue is: What is our expectation of that 17 assessment? And that's what I was saying, you know, that ;
18 the reg guides and the guidance that we need to develop 1
19 to, you know, sort of have a minimum threshold of what the l
20 Agency expects --
21 MEMBER SEALE: So in response to Dr. Powers' l
22 question about how specific should the guidance be, you l l
l 23 would say you would like to have reg guides and things I 24 like that which would give you a template, if you will, )
(% 25 for what these various implementation programs should be,
( ,/
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l 39 l
1 and then you can first verify that and then inspect I i
73 2 against it. '
, t I
\' ')
3 MR. DYER: Well, I think it should establish a 4 floor. I mean, I don't want to inhibit the industry from i
- 5 being smarter than the NRC and coming up with a better way 1 1
6 of accomplishing --
7 MEMBER POWERS: I have seen drafts that go all l
8 the way from, oh, for instance, in connection with steam- l 1
9 generator performance-based rule, they specify chapter and 10 verse on what the program should be. They let you fill I
11 in -- the licensee got to define the program, but it had 12 to have all these elements, and it was fairly detailed.
13 We recently got one in fire protection area
(~~.
I )
k/ 14 that says, You establish program, period. I mean, it gave 15 no specific guidance at all. And we already run into the 16 problem that what those programs will be will differ from 17 site to site to site by radical amounts or at potentially ;
18 could. ,
1 1
19 To give no guidance at all seems to me to be l l
20 just asking for an unenforceable, uninspectable,
! 21 uninterpretable -- ,
1 l
l 22 MR. DYER: It doesn't help with consistency. j t
l l 23 MEMBER POWERS: It doesn't help with 24 consistency. Yes, f3
(_) 25 MR. DYER: Okay. I think overall the first
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i
40 1 topic I'd like to cover is the activities that we have for
,_ 2 maintaining the uniformity among the regions in
'l 3 particular, and I'd broken up into two aspects. The first 4 slide is talking about some of the agency-wide initiatives 5 that are directed from headquarters that all the regions 6 implement, and then I specifically -- the second slide 7 talks about what we do in Region IV.
8 I think, thinking about this, the main thing 9 is that we have enough -- we also have a battle on, you 10 know, on the smaller level: How do we maintain 11 consistency among sites? And it's much the same way than 12 to make sure that once we get consistency among the sites, 13 then making sure that we're consistent among the regions.
/x
(,)\
i 14 And so I guess taking the top down look, some 15 things that -- the guidance that we've gotten from 16 headquarters, NRR in particular -- and I will say just --
17 Pat and Dwight can echo it, but I would say that it has 18 improved significantly in the last few years, and it's 19 starting to be considered a lot more than it previously 20 was.
21 I think getting the feedback from the 22 inspectors in the regions on a lot of the -- before the 23 program direction comes out has been most beneficial in 24 asking the implementation-type questions and doing some of
,w 25 the other activities about validating the inspection
( ))
\.
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41 l
1 procedures before they're issued has been a big help in l
, 2 that.
1\ )
! ' " ' 3 And I think -- I'm recently assigned as the 4 regional representative on CRGR, and I know now that I see 5 my principal role there is to raising that flag. Hey, 6 what's the inspection activities going to be when we get a 7 new rule or a new reg guide and that? So --
8 MEMBER POWERS: I mean, you're raising 9 interesting questions. We get a lot of -- when we get 10 these rules, reg guides, or standard review plans, then we 11 get a lot of testimonials from people that have looked at 12 them. But I don't know that we've routinely asked tor 13 inspectability-type questions.
.<~N i
'\ _/ 14 You know, I wonder if that's something that we 15 shouldn't be --
16 MR. DYER: Well, the regulatory analysis -- I 17 don't know if you get that as we get it as part of CRGR --
18 MEMBER POWERS: Yes, we do.
19 MR. DYER: It discusses what the impact, what 20 the assessment of the costs on the Region are going to be; 21 you know, for training inspectors, what the expected 22 extent of the inspection procedure, how many sites, how 23 you're going to accomplish the program, so it requires to 24 get through CRGR, at least a conceptual.
,/
( ,) 25 That is often not captured, and I think one of I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 42 l
! 1 the lessons learned that we've taken away from CRGR is i
,s 2 that we've got to start demanding from the staff that they
( )
'~'
3 be bringing this up in parallel and that. I know that NRR 1
4 is starting to work on it. It's a new concept, and when 5 the rule or the reg guide or the standard review plan 6 chapter is, you know, still in a state of transition and 7 review, it's somewhat difficult to figure out.
8 My bid position, at least from the CRGR 9 perspective, is, you know: Is this going to be a 100 10 percent maintenance rule type, visit every site, or is 11 this going to be a resident inspector go kick the tires on l
12 this rule and regulation, once we get it implemented and !
l 13 that, at least get the staff thinking in that general I
-/s ,
(_/ '
)
14 direction as to what the extent of the inspection would i
15 be?
16 I think overall the agency training programs 17 have significantly improved for inspectors. There is a 18 r cent manual Chapter 12.45 update to tighten up and 19 extend and identify the specific areas of inspection who 20 had done -- of course, the risk-assessment training for 21 inspectors and supervisors is coming down the pipe, and as 22 again, we've got --
23 You know, we just recently, within probably 24 the last six or eight months, got our senior reactor (tQ) 25 analysts back on the staff, and they're starting tc NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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43 1 convert some of us who didn't have an idea, you know.
,- 2 We're more the seat-of-the-pants type risk-assessment
\ l 3 types as opposed to the quantitative analysis and that, i
1 4 and their involvement in our day-to-day activities has l 1
5 helped out, but it's also identified, you know, from the l 6 need that we need to get the entry-level inspectors of the 7 future are going to have to have this as a critical tool.
8 MEMBER MILLER: What portion of your staff 9 have gone through any of the PRA training programs?
10 MR. DYER: I'd have to ask the divisions. I 11 can't remember, 12 MR. GWYNN: PRA basics for inspectors, every 13 one of the inspectors has had that course. But it's a
,im i )
(/ 14 very rudimentary class. It needs to be improved. It is 15 being improved, and that's the baseline, I believe, that 16 all of the inspectors have had.
17 The amount of specific training that they've 18 had beyond that depends upon the individual.
19 MR. DYER: We've done some IPEEE training, for 20 example.
21 MEMBER MILLER: How about, say, senior 22 managers? There's a course for management level.
23 MR. GWYNN: I attended the pilot for the 24 senior managers class that was held last year.
/ \
(v) 25 MR. SHACKELFORD: One of the headquarters SRAs NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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44 1 is currently developing a new course that's supposed to 3 2 take the place of what Pat just discussed. It's supposed
~
3 to be a two- or three-week more intensive course.
4 MEMBER MILLER: Related to managers?
5 MR. SHACKELFORD: For managers and for 6 inspectors, too, particularly residents who are on the 7 site.
8 MEMBER MILLER: So the regional administrator 9 here is willing to spend three --
10 MR. SHACKELFORD: I don't think that --
11 MR. DYER: No. Actually it came out -- you 12 know, we just held the senior management meeting, where he 13 came back, but that was one of the things that was l
/^\ 1 (s / 14 evidently discussed at the senior management meeting, 15 because when he debriefed Pat and Art and I on the results i
16 of the senior management meeting, it's -- you know, the i
17 expectation was made to put it in your training plan.
18 You're going to -- you know, you're not too !
19 old. You are going to learn about risk assessments and l 20 the tools and that that -- we are willing to dedicate the 21 time and the resources to get that done.
22 MEMBER MILLER: I went to the three-day 23 program here a few weeks ago, which is quite good, but 24 certainly could spend more days.
r I actually went through the (3_) 25 MR. DYER: Yes.
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45 1 PRA basics for inspectors in about 1984 when the Agency --
,_s 2 when it was back in I&E, and they did the initial -- and I I, I i
'~' 3 have flashbacks occasionally, but that's about it.
4 MEMBER MILLER: This would all bring it back.
5 MR. DYER: Yes.
J 6 MEMBER MILLER: I had a question on a l i
7 different topic just for a moment. A training program for 8 your -- I'm chair of the I&C subcommittee -- training for 9 programs I&C, has anybody here gone through those?
10 There's been a couple of programs at headquarters -- one 11 at the training center in Chattanooga and one at 12 headquarters. Have your regional inspectors been through 13 any of those?
y-
! i
( ,/ 14 MR. CHAMBERLAIN: I think we sent a couple of 15 inspectors to digital instrumentation.
16 MEMBER MILLER: Yes. Digital I&C.
17 MR. CHAMBERLAIN: Yes. We did that about 18 three weeks ago, a couple of our regional --
19 MEMBER MILLER: They do have a set program --
20 MR. GWYNN: That's a continuing process.
21 MEMBER MILLER: Right.
22 MR. GWYNN: They've been attending those 23 classes as they were made available over a period of time, 24 two people in the Region that are dedicated to that
!n)
'w .J 25 effort.
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46 1 MEMBER MILLER: So you have two on your staff 7s 2 pretty much that are going to be or are the experts in l \
s /
3 digital I&C.
4 MR. GWYNN: That's correct.
5 MEMBER MILLER: Okay. Thank you.
6 MR. DYER: Okay. I think overall program 7 office guidance, as I said, the inspection program 8 guidance has -- in my mind, has significantly improved 9 recently, and I would note that, believe it or not, the 10 inspection manual chapter 06.10 on inspection reports, the 11 expectations for inspection reports, was a critical 12 component of that.
13 A lot of times we think of inspection program m
s- 14 guidance, we think of the tis, the technical instructions, !
\
15 that come out, and we think about the inspection l l
16 procedures.
t 17 But I think the manual chapter 06.10 that l l
18 outlined what the expectations were in the various l 19 sections of the report went a long way to focusing our 20 inspectors as to, you know, directing their inspection and 21 the expectations for how much detail, the expectation for 22 implementation considerations, and that performance-based 23 aspect that Mr. Fontana was bring up and that, that it 24 served a good purpose in the Region.
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47 1
1 on the prior subject, do you intend to have people that 1
s 2 can actually do hands-on PRA analysis that you would I t
i
~~
3 develop in-house? I know you hired one over here, but -- l 4 MR. DYER: Well, Bill Jones is an in-house --
5 MR. SHACKELFORD: Yes. We actually -- one of 6 the things Bill's going to tell you is for every escalated 7 enforcement case, we do some sort of formal analysis. It 8 may or may not be quantitative, depending on the tools we 9 have available, but -- and for major events, we try and 10 come up with the risk significance estimate.
11 We have contacts at the licensees, and we 12 obviously don't have the tools and models that they do 13 here, and we recognize that. But we do communicate with p
! I
'w.) 14 them, to try and better understand the risk of inspection 15 findings or violations. So we actually do our own self-16 contained --
17 MEMBER FONTANA: Okay. I was just wondering ,
18 at what level you'd gotten to. Thanks.
i 19 MR. DYER: I think additionally the use of j l
l 20 what I call task-interface agreements -- these are TIAs as l 21 we refer to them here in the Region, which is where we ask l 22 the program office for direction. We've become much more 23 disciplined in doing that. i 24 In the past, we were good at picking up the
(~
25 phone and calling somebody you knew in the branch, at
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48 1 headquarters, if you had a question. It was all done 7- 2 informally. Now it's done formally. We request -- you l( )
~'
3 know, we get an answer back, and if Region IV asks for an 4 interpretation of a regulation or, you know, a TI or 5 technical instruction and that, or how we should do an 6 inspection, that goes to all the divisions and all the 7 regions. And so it gets a wider distribution of the 8 activities.
9 The plant performance reviews, this PPR 10 process and that, you know, I wasn't a believer at the 11 beginning, but I can tell you that that has significantly 12 helped in the assessment and in the direction activities 13 of maintaining uniformity among the regions and among
/ " 's
(_ I 14 the -- within the Region. That's a very valuable 15 document, because it's clear, and it allows an 16 accountability for the branch chiefs, for the divisions, 17 and among the regions during the senior management meeting j l
18 process.
19 Also as I'm sure you're aware, the recent 20 improvements to the senior management meeting process, the l
21 Arthur Andersen, the performance indicators, it's -- you j l
22 know, I'm not sure they're the right performance ;
23 indicators or not, but just that concept of having a view l
24 from 20,000 feet above, you know, the day-to-day grind i
f
( ) 25 that gives an overall data review, just asks the question N.s NEAL R. GROSS COURT REPORTERS AND TRANSCP.lLERS 1323 RHODE ISLAND AVE , N.W.
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49 1 and be able to answer it, is another --
I i
7s 2 CHAIRMAN BARTON: The committee has been 3
3 following that. In fact, we're going to get a briefing, I 4 think, on the status of that in September, end of August 5 or September.
6 MEMBER SEALE: Have you come up with any 7 predictive performance indicators that you'd like to throw 8 at the kitty?
9 MR. CHAMBERLAIN: If I did, I'd be making a 10 lot of money working somewhere else.
11 MEMBER SEALE: Ah, a realist.
12 MR. DYER: When I was a DRP director, mine was 13 how many two o' clock in the morning calls did I get, you-('D
\ s/ 14 know, for plant events.
15 MEMBER SEALE: Those are easy to count.
16 That's one thing about them.
17 MR. DYER: Sometimes they're not; that's the 18 problem.
1 19 Overall, again, program office coordination 20 and oversight -- we've seen the participation from NRR has 21 significantly increased, not only in audits and 22 oversights, but also in the decision-making and the 23 activities and that.
l 24 We've seen an increase for the project i r^N i
(~- ) 25 managers and their willingness to get the tech staff to ;
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50 1 support, you know, enforcement panels and our, you know, j 1
l
,_ 2 follow-up from tre morning meetings and that we hold here j Y2 3 in the Region and that, that that has been an increased l
4 emphasis and a focus, you can tell, from headquarters.
5 The periodic counterpart meetings, a lot of 6 times those have -- and I'll let Pat or Dwight talk about ;
l 7 the most current ones of that. But those have become a
)
8 vehicle for the program office to sort of calibrate the 9 regions all in one sitting, and we've gotten -- we get 10 high-level.
11 If you get the DRP directors for all four i
12 regions in a headquarters office in one room at the same I
13 time, you can pretty much get any individual who'll -- you
(
(_/ 14 know, in headquarters from the director of NRR to the EDO, 15 to the deputy EDOs to most division managers, and they 16 will emphasize their focus on what they want -- how they 17 want their program, and I think it's a very valuable tool.
18 It also allows informally a lot of the 19 interface with the various counterparts, and I know Ellis 20 and I, when I was a DRP director here in Region IV and he 21 was in Region II, we used to talk a lot about, you know, 22 how you manage the PIM, how you respond to events, how you 23 do that, and so it's s good lessons-learned vehicle that I 24 found very valuable, I ) 25 The SALP observation program and feedback, I LJ NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 1 think that's also -- you know, that's driven -- there's a l 1
7-.
2 mandatory for anybody chairing a SALP board is every 18
, I l
~
3 months you have to view, observe another SALP, the SALP I 1
1 4 process in another region, and that gave us particular 1
5 insights in that -- on how data's presented, how the l 1
6 assessment's made, and the feedback given to follow up l
7 various strengths and weaknesses in licensee performance.
8 MR. LARKINS: Jim, not to put you on the spot, 9 but I'm just curious.
10 MR. DYER: Sure.
11 MR. LARKINS: How do you see the coordination 12 between the EDO's office and the regions in terms of when 13 you need special inspections or things like that, when I i
(_/ 14 there is an event that comeu up where headquarters wants m ; to -- you have a team --
16 Do you see that process having improved in 17 terms of coordination?
18 MR. DYER: Actually, especially since 19 February, Region IV has a very good communication with the 20 EDO's office, sometimes more than Ellis and I would 21 appreciate.
22 No. By that, I guess I'm -- EDO office pretty 23 much doesn't involve itself, you know, with the exception i
1 24 of the major DETs and the approval for teams and that, and
, () 25 even before Joe left the Region, you know, Region IV was a NEAL R. GROSS COURT REPORTERS AND TRANSCR'BERS 1323 RHODE ISLAND AVE., N W.
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52 1 net donor to the Millstone, Dresden, Maine Yankee 7s 2 activities.
i
/( /
3 Outside that, I think the senior management 4 meeting process, where they get all this -- it's --
5 essentially there's a certain counterpart meeting flavor 6 to that, and having participated in one as an acting 7 regional administrator, there's a lot of activity that 8 goes on about getting the best and brightest to focus --
9 from all the regions, to focus on our problems and that.
10 And I think we're all willing to do it.
11 MR. LARKINS: I know you brought the 12 perspective, having been in EDO's office and having been 13 in projects and headquarters and also here at Region, so I gy
) 14 was just wondering about your perspective on the 15 coordination.
16 MR. DYER: And the EDO coordinators and that, 17 they're better now than when I was there as far as staying 18 plugged in to the morning, the daily meetings that we I 19 have, the calls and that, and -- but they're pretty much j l
20 on top. )
l 21 I think one of the areas that certainly l l
22 occupies a great portion of our time and that is in 23 uniformity, and it's probably the area that creates the l 24 greatest amount of feedback from the industry is in the (7
i 25 area of enforcement. i RJ l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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I 53 l 1 There is -- I think we're making progress in )
i es 2 that area. Overall, you know, the development of the I
'~
3 enforcement manual, the expansion of the regional l I
4 administrator's enforcement staff where we went from one i 5 enforcement coordinator to two recently, in the past year 6 and a half, and have our staff from the RA's office 1
7 involved with the various divisions that are, you know, I
8 largely issuing the non-escalated enforcement, and then 1 9 the coordination for the escalated enforcement, up through i
10 the regional administrator's office and that, and l 11 coordinating with Jim Lieberman's office in Office of 12 Enforcement in headquarters and that, that has facilitated i
13 a consistency. ,
l r'~N 1 I
I
(. / 14 I think it's trickling down right now. I I l
1 15 think the escalated enforcement process, we have a weekly l l
16 meeting with Jim Lieberman and the regional administrator l 17 every Thursday at 12:30, and we go through any cases that 18 we think could be potentially escalated, and we get a 19 headquarters read, and it's usually you'll have 20 representative --
21 We'll have our regional counsel; we'll have 22 the Office of Enforcement; and we'll have NRR on that 23 call, discussing whether or not this reaches the threshold 24 for escalated enforcement. And it's a very consensus-
! , s, lf j 25 building question-answer process and that.
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54 1 That does not take place anywhere near the s 2 extent for non-escalated enforcement, and so right now, I i
(\ /
)
'~'
3 think that's the area that we probably struggle the most 4 for, and utilities are very conscious now of severity 5 level 4 and 5 violations, 4 -- I mean, and minor 1
6 violations. e eliminated the --
l 7 CHAIRMAN BARTON: The enforcement language, l l
8 you said, is relatively new? What's in the enforcement 9 language? What are you trying to do with it?
10 MR. DYER: What's in --
11 CHLIRMAN BARTON: What's it's purpose?
12 MR. DYER: The enforcement manual is to just 13 issue a standard, you know, guidance for how to implement f
n i
(_) 14 the enforcement policy within all the regions and i 15 headquarters.
16 MR. GWYNN: It's very detailed in terms of 17 fire protection; there's a special section that relates to 18 fire protection. And there's a special section that 19 relates specifically to security and health physics.
20 And so it provides a baseline from which any 21 inspector can go to that manual, if they have identified a 22 violation in a specialized area, look at the criteria that
\
23 are laid out there for what constitutes a level 4, what !
24 constitutes a level 3, and so that really provides a basis j
,m (s_ ,,) 25 for consistency that we didn't have in the past. )
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55 l 1 And Office of Enforcement is continuing to
,_ 2 refine that manual, and as they refine it, then we get ,
( ) l
l 3 better at being uniform.
4 CHAIRMAN BARTON: Good.
5 MR. DYER: And, of course, this additional 6 staff is taking a look at -- we're auditing, doing 7 internal audits, and challenging the various divisions to ;
1 8 make sure -- and various inspectors, to make sure 9 everybody is handling it in a similar vein.
10 MEMBER SEALE: Your increased attention to 11 non-escalating cases brings up a very interesting issue.
12 I've heard the idea expressed that managers in some 13 licensees want to know about threshold-level, if you will, I
A e
(_,/ 14 violations, things that are below the level for 15 enforcement, and they want to be very -- be perceived as 16 very active in encouraging the reporting of those kinds of 17 things within the organization, as a symptom of concerns 18 that need to be addressed by the local management.
19 That is, this is, if you will, an activity or 20 an active indication that there's a problem that they need 21 to solve if something like that comes up.
22 The other side of that coin, though, is that 23 if you get in -- if it gets blown out of proportion and 24 all, you then go into the penalty phases and all of those h)~.j 25 kinds of things, and then there is obviously within some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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56 I 1 people within the organization a reluctance to lay your
-s 2 linen out there, for everybody to look at.
I l 3 Certainly you have as much right as anybody 4 else to look at sub-escalated level enforceable type 5 problems; that is, the things that happen but at below the 6 level of some kind of action.
7 On the other hand, there is the difficulty of 8 potentially sensitizing everyone to your interest and 9 turning off the desire or the willingness to bring these 10 into high profile within the licensee's organization, so 11 that they can be addressed in a constructive manner.
l 12 That's a tightrope; you're kind of walking on the ledge 1 13 there.
j'}
(_ ! 14 And I think you understand as well as anybody 15 that the licensee ultimately has to solve the problem, and 16 anything you can do to encourage them to solve it at the 17 low level phase should be in the cards. l 18 MR. DYER: And I think the recent change --
19 and I don't remember the date, but the recent change where 1
20 we got rid of the severity level 5 violations and we went )
1 21 to the minor violations, anything less than a severity 22 level 4, you know, conceptually a severity level 4 23 violation is significant enough that if left uncorrected, I 24 it could result in potentially far -- or escalated
( ,) 25 significant issue.
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57 1 MEMBER SEALE: Sure.
,s 2 MR. DYER: And so the threshold below that, i \
3 you know, getting it at that level, allowing us to get rid 4 of, you know, inadequate procedures that didn't result in 5 any problems type thing or wouldn't result in any 6 problems, to get rid of -- remove that burden from us was 7 a big help to us, because we were spending entirely too 8 much capturing the enforcement administration in that.
9 It also served as an incentive to licensees to 10 address it, and it allowed us not to have to address the 11 true nits, not important safety issues, that are out there 12 that we want licensees to be addressing at that level 13 before they get to that.
,m 1_ / 14 Additionally, the ability to issue a non-cited 15 violation as a 4, severity level 4, and typically the l 16 way -- when we would do that is when the licensee has 1
17 identified -- self-identified something that avoided a 18 problem downstream, and then often it's written up in the 19 inspection report as being a -- you know, an attaboy, if 20 you would, to the licensee and treating it as a non-cited 21 violation.
22 MEMBER SEALE: So really to present this 23 perhaps is as a very real form of regulatory relief.
24 MR. DYER: It is, but some of the outside o
25 entities that read inspection reports don't feel that way,
()
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58 )
l 1 and, you know, they count the number of NCVs and ask the 1
2 question why you didn't find it before you created it, you i
,s i
)
1 3 know. And our sensitivity is we feel very good when they l
l 4 find it before it finds them. l 5 MR. CHAMBERLAIN: Even in the escalated area, 6 too, we try to use -- you know, give them credit if they 7 identify it and they do the right things, you know. It l 8 goes down the path, you know, non-civil penalty, but we do 9 have to address those; every escalated case has to be 10 addressed.
11 MR. GWYNN: Even for some escalated cases, 12 where the licensee has really gone beyond minimum 13 expectations and been very proactive finding --
i l3 i
'k_ '
14 MEMBER SEALE: Truly intervened.
15 MR. GWYNN: Exactly. In those cases, we can 16 exercise discretion and not cite a significant safety 17 problem. We have done that on occasion.
18 MR. DYER: I think the next thing I'd like to 19 talk about is our Region IV specific activities, and these 20 are things that we in our conduct of day-to-day 21 activities.
22 Probably the first thing that may be unique to 23 Region IV, certainly the level of participation, is we 24 have a daily morning meeting, and that's a regional daily (n) 25 morning meeting, and it's at 10:00 a.m., because we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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59 l
i 1 to wait for the West Coast to wake up and get started and
-m 2 that. If we held it any earlier, I think the people at I i i /
l 3 Palo Verde would revolt, because I think they're heading l
4 in to the site at about 4:00 a.m. now to get plant status 5 for our morning meeting.
t 6 But that's a very detail meeting where we go 7 over plant status at all 14 sites, and by that, it would 8 be any significant LCOs or maintenance activities or any 9 significant findings the licensee has identified that 10 they're initiating corrective action on.
11 We get briefings on hurricanes; you know, I
12 anything -- and it's typically a region-wide meeting that l
13 the regional administrator will attend or the deputy in
- (_)
-) 14 his stead.
l 15 DRP sort of is the chairman of that meeting l 1
1 16 and goes through site by site, and DRS is in attendance l 17 and updates on any inspections they have going on, l 18 activities, and, you know, it's a forcing function. The l
19 branch chiefs lead the discussions. We don't connect the 20 sites unless there's a special briefing we want, but the 21 branch chiefs lead -- DRP branch chiefs lead those i
i 22 discussions, and it usually means that they're conducting 23 their briefing, site briefings, as early as 7:30 in the 24 morning and that to get prepared for it.
,m 25 MEMBER FONTANA: I'm just curious. Is that
( )
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60 1 video-conferencing or --
,_ 2 MR. DYER: We video-conference with Walnut
( i
\2 3 Creek field office, but we don't -- we have NRR on the 4 bridge. We hook up a bridge, and NRR participates in 5 that, and so does the EDO's office. They'll usually 6 attend. Jocelyn used to go down and attend the -- you 7 know, there's a headquarters connection that usually 8 occurs down in NRR projects.
9 MEMBER FONTANA: So they have to put their 10 ties on and everything.
11 MR. GWYNN: We find a lot of value from the 12 video-conferencing, and we're working hard to make that 13 happen with headquarters as well. We have had some video-O 14 conferenced Thursday calls with the Office of Enforcement,
(.. /
is and so we're initiating that process to try to expand the 16 video-conferencing further.
l 17 MR. DYER: I think we're -- we're even looking
)
18 at conducting our first individual enforcement conference 19 via video-conferencing, rather than, you know, having 20 individuals fly in and that or us fly out. It's this 21 week. I don't know if it's today or -- this afternoon? )
22 CHAIRMAN BARTON: You're going to have the l
23 public on the video-conferencing? j 24 MR. DYER: No. Individual conferences are r^x
) 25 closed.
L.:
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1 i
61 1 MR. GWYNN: It turns out that NRR and we have
,- 2 used our equipment.
)
3 MR. DYER: I think also on -- if I get the 4 dates right, let's see. I think it's Tuesday, Wednesday, 5 Thursday, depending on the -- we have what we call 6 inspection report debriefs, where, depending on the l
7 timing, it's usually sometimes before the exit, after the 8 exit, but certainly before the inspection report is ever 9 signed out, and we finalize it, it's a debrief of the l
10 findings, of the significant findings, to the regional 11 administrator or myself, and all the division directors, 12 to put it in perspective and to, you know, make sure that l
13 our enforcement perspective is provided.
,m k_- 14 Typically the comments will be that, you know, l 15 Wait a minute; you know, that's a violation, or, No ,
16 that's not a violation. Or, you know, You're making a big 17 deal out of nothing, or, you know, in the case of 18 performance-based, the inspectors have pretty much figured 19 out that if they mame in and'say that we found -- we're 20 going to issue a violation on a procedure for an 21 inadequate procedure, we'll say, What's the consequences, 22 and if it's --
23 The message getting back to the inspectors is, 24 Don't bring an in-office review to the regional
() 25 administrator or the division directors, you know, as
( )
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62 1 being your only issue. What's the consequences of that 7s 2 inadequate procedure? It can't be a hypothetical s
3 discussion. We want to see, you know, Did you go out and 4 verify when it was used, you know. Was the pump put 5 together right? Was the test conducted properly, you 6 know, things like that, in pursuing those lines of 7 questione, just --
8 And additionally at those morning meetings, I 9 would say that we -- by going through which equipment's 10 going out of service, which LCOs that are entered, it's 11 been remarkable how many times you'll find, you know, a 12 diesel -- the licensee will have a diesel and a schedule 13 for outage, and at the same time, they've got a turbine-
/~n I )
\_/ 14 driven aux feedwater pump or a transformer problem, or 15 we've heard there's thunderstorms in the area, you know, 16 and things like that.
17 You know, that's typically -- we'll assign --
18 management will assign follow-up either of the -- mostly 19 of the SRAs to say, Okay, has the licensee done a risk 20 perspective on this; have they followed. And many times 21 we'll find that it's a lack of coordination. The left 22 hand didn't know what the right hand was doing.
23 CHAIRMAN BARTON: Even though they did an on-24 line maintenance risk assessment?
(^%
MR. DYER: It's -- you know, they did (v) 25 Yes.
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63 1 this review, and they looked at all their tech specs and s 2 their safety-related equipment, but they didn't factor in ,
i b \
\
)
3 the fact that they've got a thunderstorm coming over or 4 the fact that their gas-turbine generators, which are !
I 5 controlled by the distribution crowd -- or work in the 6 switch yard is scheduled at the same time. j l
7 You know, it's the command control aspects !
8 that we sometimes pick up and ask questions on.
l 9 MR. LARKINS: It seems like there's an 10 increasing trend towards doing more on-line maintenance 11 instead of waiting until the outage and --
i 12 MR. DYER: Absolutely.
13 MR. LARKINS: We heard yesterday that folks
(\_-) 14 were -- although they're not pushing in that direction, 15 they're doing more of that and taking a look at the risk j 16 impacts of doing that, and it appeared that the risks in 17 some cases was lower for doing on-line than doing during 18 outage, and I was just interested to hear you say that you 19 guys do take a look at that.
20 MR. DYER: Oh, yes.
21 MEMBER SEALE: Have your senior reactor 22 analysis people in the PRA mode taken a look at that as a 23 kind of a generic issue, to identify up front, so to 24 speak, those kinds of things that you would consider to be
(~%
() 25 appropriate as a class; let's say, sort of have a first NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1
1 reaction, if you will, whether or not a particular 73 2 activity is appropriate for on-line or should be off-line
\ ,):
1 l
3 or vice versa?
4 MR. SHACKELFORD: I don't think that we have 1
5 what you'd call a checklist or anything for that. The 6 maintenance rule, A-3 type of look, is designed to give us 7 a perspective on how does the licensee perform their 8 assessment for on-line, as well as shutdown maintenance.
9 A-3, you know, runs together with mode, so we --
10 MEMBER SEALE: Well, I'll ask you a related 11 question then. You've obviously had -- you've 12 familiarized yourself with the IPEs or the PRAs as the l
13 case may be --
$q 4
k) m 14 MR. SHACKELFORD: Right.
15 MEMBER SEALE: -- for your plants, plants in 16 your region. Do you have an already identified synopsis, 17 I guess I'd call it, of the areas of concern that are 18 addressed in the IPE and the areas that are not addressed 19 in the IPE? For example, do you know that the Callaway 20 IPE will be helpful in addressing on-line maintenance 21 issues?
22 MR. SHACKELFORD: We don't have anything that 23 you would call formally set up like a matrix for that.
l 24 One of the things, again, that Bill hopefully will discuss
(~s 25 with you is what we are doing in that area. We're (V) i
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65 i
1 building a PRA library here that has that kind of stuff.
7_ 2 MEMBER SEALE: Okay. But it would be kind of
(
s '/ 3 a useful thing to have, to help you cut to the chase, if 4 you will --
5 MR. SHACKELFORD: Right. One of the things 6 that we want to do, Bill and I, is to visit each site. We 7 have the IPEs here which are essentially a summary 8 document --
9 MEMBER SEALE: Yes. We're --
10 MR. SHACKELFORD: -- very little detail.
11 MEMBER SEALE: We're painfully aware of that.
12 MR. SHACKELFORD: And what Bill and I were 13 going to try and do is establish a better line of
,fg
(_.l 14 communication where we can get more detailed, updated 15 information or access to it. When these issues come up, 16 typically the IPE won't address the nuances of a 17 configuration.
18 MEMBER SEALE: That's right.
19 MR. SHACKELFORD: And we have to discuss this 20 with the licensee, so we don't have in-house the 21 information always that's necessary. We do know the 22 questions that need to be asked, and we're comfortable 23 doing that, and then that's what Jim has been talking 24 about.
f~h
() 25 When these things come up in the mornings and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. ,
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i
66 1 we get assigned to look at it, we know who to go call to
,~ 2 discuss what assumptions were made. But we don't really
(\ ';
3 have all the tools that would be required.
4 MR. DYER: I think the last unique thing with 5 Region IV is, of course, our involvement with the 6 inspection exits. Additionally, we try to get our 7 regional branch chiefs out to a lot of the exits, and if 8 there are significant findings, either from headquarters
~
9 or region-based inspections, you know, we'll escalate to a 10 division director level to get our point across to the 11 licensees or whenever there's a significant program 12 review, such as some of the AE inspections that we did at 13 WNP 2 in Arkansas.
I ws l 14 And to put it in perspective and that, the --
15 also the overall inspection report preparation process and 16 that is again -- I echo that we, you know, conduct an 17 inspection report debrief at the division level mandatory, 18 you know, and usually at the regional administrator. The 19 regional administrator's office will carve time out of our 20 schedule to make sure we're at the debriefs.
21 If we're not and the division directors hear 22 the debrief, one of the screening factors from the DRP 23 director is, This is one you need to go talk to the RA 24 about. And that has happened, and the value of that is
/N
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67 1 from the site VPs who call in to just, you know, tell us 2 how good they're doing and provide, you know, Is there (7-
' ~ '
)
3 anything on our radar screen.
4 And it's these inspection report debriefs that 5 will something on our radar screen and file it away that 6 the next time the site VP from Cooper calls in, we're 7 going to talk about their performance on that notice of
, 8 enforcement discretion, or we're going to talk about their 9 performance in this last start-up and that, things that we 10 observed in that, and provide a critical feedback.
11 And it's a good sense, from our perspective, 12 as to whether or not our issues are percolating up through 13 their organization, because if the first time they hear kI 14 about an issue is from me or Ellis, then that's usually an 15 embarrassing point for them. And so --
16 CHICRMAN BARTON: Is this process you're 17 describing unique to Region IV?
18 MR. DYER: I think it is. It's a carryover 19 from when this was an eight-site region. You know, they 20 had the luxury of doing that back when it was the 21 Arlington eight sites, and it's one of the things that 22 we're carrying over, now that we're a big region, to a 14-23 site region, that in particular.
24 You know, when it was the Arlington eight f
' ))
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68 1 directors signed out all the inspection reports. Right
,_s 2 now, when there are 14 sites, that's a significant stress
\
i 3 on the division director, and we're in the process of 4 delegating it down with adequate controls to the branch 5 chiefs.
6 These debitefs are a critical component of 7 that delegation, if you would, and the quality controls we 8 can maintain through the PIM, plant issues matrix reviews, 9 are that. So we're in the process of downgrading that, 10 but --
11 MR. GWYNN: Just for information, I know that 12 Region I has a process. It's not face to face with the 13 inspector. It's an e-mail process, where the inspector,
/O
+ r
\_/ 14 when he returns to the office, prepares a bulletized 15 summary of the findings and provides it to the managers in 16 the office.
17 And then if it's an exception process, if 18 there are some findings that management has a strong 19 interest in, then they ask for a specific face-to-face 20 debrief. It's an exception process. So they're similar 21 functions, but just slightly different.
22 MR. DYER: It also allows the staff to -- it 23 eliminates any filters between the staff and regional 24 administrator, to know what's the regional administrator's
()
,/"
25 safety philosophy and what things will wind him up in a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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69 1 hurry.
,-s. 2 You know, I think everybody's pretty well
(,'~'j 3 sensitized that if a turbine-driven aux feedwater pump 4 goes down -- we don't need to know the risk numbers on 5 that. That's one that we want to have discussed and what 6 was the cause.
7 I guess the next thing -- and this may be --
8 we'll get Jeff in -- is our staff training and 9 development. The overall staff training and development 10 was the last topic that I wanted to talk about, and we've 11 got -- is this slide cut of sequence? I think it may have 12 gotten put in at the end later on. They snuck up and they 13 gave me this topic.
( )
\ /' 14 of course, the overall inspection and 15 qualification guidance provided by the headquarters i 16 guidance -- I spoke earlier of the manual chapter 12.45 17 which recently expanded and tightened up and become much 18 more specific in the direction given from the program 19 office with respect to qualifications.
20 The HOLB direction, operator licensing branch 21 direction for examiners. has always been fairly -- the 22 technical qualifications guidance and t.1at has been very 23 thorough historically, and then recently the development 24 of the resident inspector development program, the senior i ,%) 25 resident inspector development programs and the senior NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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70 1
1 reactor analyst programs --
l l
,_s 2 I think our overall view here from Region IV l
{ ) I
' 3 is that the senior resident development program was not as 1
4 successful as the resident inspector development program. l 5 I think the resident inspector development program, ,
1 6 bringing outside people in and getting a crash course on l l
l 7 how to become a resident inspector is -- we just didn't -- l l
8 we can't get enough. l 9 And making the leap from senior -- from j 10 resident inspector to senior resident inspector can 1
11 largely be done on on-the-job training, as acting for the j l
12 senior resident when the senior resident's not there or 13 assigned to a team inspection is probably as good if not
()
l l
(_ / 14 better training than a lot of the coursework and the 15 activities that were put into the senior resident 16 development program.
17 The senior reactor analyst program and that, I 18 think we're going to talk about later this afternoon, but 19 the overall -- I think we're just starting now to see the 20 benefit. It was a net export of talent certainly from the 21 Region for a long period of time, and now that we've got 22 Jeff and Bill Jones back, it's starting to pay off for us 23 in the Region.
24 One of the things that we found out in this A
l ) 25 region is that wher you screen for the senior reactor LJ NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 analysts and you take your best and brightest and put them
,~s 2 in the pipeline, it's a two-year pipeline. Before they
( )
3 get out, they're liable to be promoted or transferred 4 somewhere else. You know, they are enviable resources 5 that -- and so we took Jeff from headquarters, because he 6 was almost qualified, you know, but --
7 MR. SHACKELFORD: I'm glad they're 8 transcribing this.
9 (General laughter.)
10 MR. DYER: That's right, under your appraisal.
11 MR. LARKINS: Jim, on the resident program, 12 are you looking more for people with some experience, or 13 are you willing to take the right-out-of-college engineer?
,/ y
\
(_) 14 MR. DYER: No. We will not -- I mean, we 15 can't take an intern-level. We need to have -- I would 16 say right now, this region has really hemorrhaged in the 17 resident inspector ranks. I forget. Pat could tell how 18 many openings we currently have, but we have had a 19 tremendous turnover in the past six to eight months, and 20 it's -- you know, it has a trickle-down effect.
21 If you lose section chiefs, you know, or you 22 lose a senior resident, then the residents move up, and a 23 lot of our residents have moved to headquarters and taken 24 promotions and that, so we're running lean right now on
,a
( ,/ 25 site coverage.
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72
)
1 As I said, you know, the four residents at s 2 Palo Verde have had a complete turnover, I'd say, within
( \
\~'/
3 the last eight months. The same thing is going to happen ;
4 at Diablo Canyon, and WNP 2 is the same way, and River 1
5 Bend will be the same.
6 So, I mean, we're talking total turnover.
l 7 MEMBER POWERS: I mean, this is panic time. l l
8 For the eyes and ears, this is a non-trivial loss that 9 you're talking about.
l 10 MR. DYER: Yes. And I guess the good news '
11 part of it is we've been able to rob from other regions 12 and headquarters as much as they rob from us --
13 MEMBER POWERS: Yes. It doesn't serve the
[/
N- 14 problem integrally.
15 MR. DYER: It's just -- it's a four-month j l
16 transition period, while everybody starts moving, you 17 know, moving your household effects and everything that's
)
18 creating the anxiety attack. l 19 MEMBER POWERS: Some of these guys may want I
20 to move west too.
1 21 MR. GWYNN: Actually it's interesting. The 22 saying that misery loves company, well, I have three other 23 division directors of projects who have the same problem 24 that I have, so this is not unique to Region IV.
,r3
() 25 MR. DYER: Here also in Region IV, we have --
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)
73 I 1 we use a training committee. I'm the training committee 7s 2 chairman. It's comprised of the other division directors
() 3 and selected members of the staff for the support 4 functions, largely from the DRMA organization.
5 We issued -- we have a regional policy guide 6 that outlines our inspection, how we're going to implement 7 the inspector and examiner training and qualification 8 within the Region. It also provides our priorities for 1
9 training, how we're going to implement it.
10 We came up with a five-priority-level training 11 scheme, of training based on mandatory -- you know, 12 priority 1 is mandatory training to support 13 qualifications; then priority 2 is -- or I guess we used 7-s) 14 A, B, C, D, and E.
15 But priority B is mandatory training, 16 supplemental. It would be training supplemented by --
17 directed by the program office, such as continuing 18 education training for the supervisors, managers, or 19 requal training and that.
20 Priority C is developmental training for four 21 own current job. Priority D is developmental training 22 within the Region IV scope of work, so it may be an HP l 23 would want to cross-train as a reactor inspector and vice 24 versa.
(_) 25 And priority E is developmental, but within NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS (
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74 1 the scope of the NRC. And where this really comes into s 2 play -- I mean, we use it for judging, you know, which
~#
) l 3 training we support based on maintaining a minimum 4 critical staffing. We also do it -- l 5 The critical area that's really come into with 6 the budget cuts has been in our 368 money, which is our l
7 discretionary outside training, tuition, reimbursement, l 8 and our cash and that. That is -- we are being held to l
9 much tighter standards, and so that's where we really have 10 to make the hard decisions.
11 And those are done at the committee level, and 12 the divisions do the first cut, and they bring them to the 13 committee and the other divisions can challenge them on p.- .
w- 14 whether or not they properly classified the kinds of 15 training they want to do and that.
l 16 MR. LARKINS: And I think we see training 17 money being cut back agency-wide.
18 MR. DYER: Oh, yes. Yes.
19 MR. GWYNN: But this is very important. The 20 availability of 368 funds to supplement the technical 21 training division capabilities is important when you have 22 new technology that's being developed to support safety at l 23 the plants, like these high technology probes that are 24 being used in steam generators.
i
) 25 The TTD doesn't train on that, but our l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
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75 l 1 inspectors need to understand how that equipment works and l
2 what its flaws are, and they can only get that by l
f,,)
l 3 attending training that's given by others that costs l
4 money, dollars. And without the 368 money, we're in l 5 trouble.
6 MEMBER POWERS: That seems like that's a 7 particularly severe area in your work, Don, on digital 8 I&c. !
l 9 MEMBER MILLER: Well, I'd say add PRA without '
10 a doubt.
i 11 MEMBER POWERS: Well, PRA, I think, can be 12 effectively done in-house, because NRC has been so forward 13 in its contributions to the development of that
/m i )
(/ 14 technology, and they've got the expertise. They're net I l
15 exporters of that technology. j 16 But digital I&C, we're net users, and what we i
17 don't want to be is abusers of that technology. And I i
18 that's a place where you just don't have any trainers that 19 know -- I mean, what they know is stuff that's out of 20 date. They're behind the curve all the time on that.
21 It's not a failure on their part. They're 22 doomed to be behind the curve on that point.
23 MEMBER MILLER: The only good news in that is 24 the number of -- net number of people in the entire
, r3 l i,w) 25 Commission that need digital I&C is not very large. As NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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76 1 pointed out, there are two here, and that's certainly
,~ 2 quite adequate.
I i
\ /
3 MR. DYER: Sometimes I wonder.
4 MEMBER MILLER: Well, I would hope maybe --
5 hopefully down the pike, we'll have more digital I&C 6 upgrades, so maybe two will not --
7 MEMBER POWERS: It seems to me the reg guide 8 that I read required more than two just to through it.
9 MR. DYER: We've had a number of -- I mean, I 10 can think of Comanche Peak and their conversion to the 11 digital feedwater system; Arkansas, you know. Digital 12 feedwater at Arkansas in a B&W plant is critical, and we 13 had -- we're still trying to sort our way out of a
}
xs 14 major -- we consider it a major event.
15 We did a reactive inspection at WNP 2 where 16 they had -- they converted a digital feedwater system --
17 they went to digital feedwater and the adjustable speed 18 drive recirc pumps all in the same outage, and the system 19 interactions that that created and especially when they --
20 we finally convinced them towards the end of their 21 outage -- I mean, at the end of their operating cycle to 22 do a -- you know, to do the task that -- where they trip a l
i 23 main feed pump from 100 percent power and ensure that the 24 plant won't trip and stabilizing that, you know.
s 25 When they did it, it took them right to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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77 1 forbidden zone of their power-to-flow curve, and they had 7s 2 to trip the reactor. And when we -- Bill Jones led the
/ )
'~~'
3 team inspection that went out there, and we had all of our 4 I&C expertise, I think -- if they weren't on the team, 5 they were helping from the office here or wherever sites 6 they were during that activity, but just trying to sort 7 that out was a real challenge.
8 MEMBER MILLER: Now, headquarters used that 9 particular example or used that as an example in one of 10 our meetings. Now, headquarters is telling us that 11 they're heavily involved in all the digital I&C upgrades.
12 MR. DYER: They were on the team.
13 MEMBER MILLER: Yes. They probably -- I knew 5
rN 3
\w / 14 they were on the team. I suppose the question is:
15 Headquarters is telling us at our level that they'll take 16 all the tough problems, and the regions don't need to have 17 quite the in-depth expertise. Maybe we need to ask the 18 questions of the regions. Is that -- turn off the 19 transcriber. Is that indeed the situation? Or do we 20 really need to build more depth within the regions too?
21 MR. DYER: Well, I think -- and I'll let Pat, 22 because I'm -- if somebody can't translate it into simple 23 terms and convince me or Ellis what happened and do we 24 really understand the way this plant operates, there's 73
() 25 usually a lot of fur flying in the Region. ,
1 1
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78 1 I mean, it's --
2 MR. GWYNN: Really, in my view, it depends 73
- i 3 upon whether you want to be reactive or proactive. If you 4 want to be reactive, well, then headquarters-based 5 approach will work. If you want to be proactive, you need 6 to know what's going on in the plants and where there are 7 problems with what's going on in the plants.
8 And so having our inspectors in the plants 9 knowing what's going on and being able to understand it so 10 that they can translate that information and inform 11 headquarters -- that's what happened in this case.
12 We did a proactive inspection at WNP 2 where 13 we sent our digital I&C trained people out to take a look
,r )
(
\ss'1 14 at these two modifications before they restarted from the l
15 outage, and we saw problems.
16 And so with those problems, then we watched 17 the licensees restart from that outage. We watched how 18 the plant performed. We kept the pressure on the 19 licensee to demonstrate that the system would, in fact, 20 operate properly, and there was some questions over time 21 as to whether or not they were going to perform this feed 22 pump trip test.
23 It was a part of the original preoperational 24 tests for the plant, and so, you know, without the g3
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79 1 known until, you know, until it happened at the wrong j 7-~s 2 time, you know, and so then you're in a reactive mode. We
\ ,
N_) 3 were proactive in this case.
I 4 MEMBER MILLER: Didn't that delay their 5 restart?
6 MR. GWINN: From this most recent outage, I l
7 their corrective actions significantly delayed their 8 restart on this most recent outage. Yes.
9 MEMBER MILLER: One of the concerns I've had 10 is the -- at the resident level, the amount of training 11 you're getting. I think all they're doing is that manual 12 training workshop is all the residents, I believe, are --
13 MR. DYER: We had a speaker come out, and we p
k-) 14 had -- I can't remember who it was; I think the program 15 office came out during the resident meeting at one point.
l 16 MEMBER SEALE: Could I ask: Have you -- well, 17 I guess not "have." But will you suggest that they keep 18 track of the performance that the parts of those two 19 systems that were involved in this modification that gave 20 you the trouble, to see whether or not there's undue 21 maintenance required? Because that kind of thing is 22 exactly the sort of thing that makes equipment wear out 23 early.
24 MR. GWYNN: A performance-based rule will give es (v) 25 us all of that information that we need. They're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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80 1 monitoring that on a continuing basis, and when you have
,,, 2 maintenance-preventable functional fires or even a
/ \
3 functional fire, they have to review to determine if it's 4 maintenance-preventable, and they have to track that 5 information. So this is risk-significant equipment, and 6 they have that, thanks to the rule.
7 MEMBER MILLER: I guess the message I'm 8 hearing as the one who worries about training that we 9 maybe should review a little bit in more depth what we're 10 doing at the regional level with I&c. I guess the view we 11 , '.re getting was headquarters would take care of the 12 difficult problems. But you've got a good point on it.
13 Headquarters doesn't know about it until it 7~s
(' _j) 14 happens; you'd rather know about it before it happens.
15 MEMBER POWERS: As more and more plants make 16 these transitions, I think we'll need more and more --
17 MEMBER MILLER: As Dana just pointed out, we 18 have, as we're speaking, hopefully the standard review 19 plan for I&C is being issued. Unfortunately it's a little 20 thicker than we'd like to see it, and it's going to 21 require a little more effort to everybody to dig through 22 it.
23 MR. GWYNN: I guess there's another i 24 significant event that's occurred recently where I think
()
n 25 without our inspectors being involved, that the digital m-NEAL R. GROSS 1 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. l (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
81 1 I&C problem would not have come clearly to light for the
, ~s 2 Agency, and that was the steam generator dry-out event
! ) 1
%~/ !
3 where we had an augmented inspection team at Arkansas Unit 4 1.
5 There they had main steam relief valve, a 6 safety valve on the main steam system, that failed to 7 open, because it wasn't properly assembled, and so that 8 was the focus of a tension in terms of what occurred at 9 the plant.
10 But the reason that the dryout occurred was 11 because of a problem with the software in a digital 12 feedwater control system.
13 MEMBER MILLER: The Arkansas ones are B&W.
)
'w/ 14 Right?
15 MR. GWYNN: That's correct. And so we put a 16 lot of attention on that, and we got headquarters 17 involved, but we were again in a position where we had the 18 right people at the site to ask the right questions, and 19 then to get the right people from headquarters involved in 20 that activity.
21 MEMBER MILLER: When did Arkansas do the 22 digital feedwater upgrade?
23 MR. DYER: I think it was this spring outage, 24 and they had their --
25 MR. GWYNN: I think it was a couple of years (x_-)
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i i 82 l
l 1 ago.
! 7s 2 MEMBER MILLER: Yes. I thought it was --
3 because I think EPRI was heavily involved in that one.
l l
4 MR. GWYNN: It's a couple of years ago.
5 MEMBER MILLER: So that one, I'll try and make 6 certain those kind of issues -- there's a digital I&C 7 workshop that EPRI is sponsoring that might bring some of 8 these kinds of generic -- you've added to my list of notes 9 here.
10 MR. GWYNN: It was an analog digital interface 11 that caused noise in the system, and then the software 12 couldn't interpret the noise, so it locked up the control 13 system.
E- 14 MEMBER MILLER: B&W plants, as you know, have 15 extra problems in that area. of course, all the B&W 16 plants were going to upgrade all their systems to a l l
17 digital, but -- maybe you're not aware -- it being too 18 expensive, they've never done that. Or at least some have l l
19 done it and some not.
20 MR. DYER: Well, you know, my knowledge was 21 when I saw the digital feedwater cabinet located between )
I 1
two feedwater heaters on the turbine deck with no air 22 l
23 conditioning, it was -- l 24 MEMBER MILLER: That's not a digital I&C l
77
( ,) 25 problem; that's just a sensibility problem.
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83 1 MR. DYER: Yes. I mean, it's a harsh
, -~ 2 environment, that that is something that -- I mean, the
\' ' ' ' /
3 sensitivity --
4 MEMBER MILLER: SALP 1 engineering. Earlier 5 or yesterday, there was an issue brought up about 6 lightning, and we have a lightning guideline coming along.
7 But it seemed like in this region, you may have more 8 problems with lightning than, say, other regions.
9 MR. DYER: Comanche Peak and Grand Gulf 10 certainly.
11 MR. GWYNN: Grand Gulf has solved its problem, 12 and Comanche Peak has made a lot of progress towards 13 solving its problem, although I'm not confident. It g3 i i
's / 14 really hasn't been heavily tested yet.
15 MEMBER SEALE: Actually Palo Verde may have 16 more of a problem in that regard, because ground is harder 17 to find in the desert. Like it doesn't exist.
18 MR. DYER: We haven't experienced a whole lot 19 of events that I know of, but --
20 MEMBER SEALE: They're far enough away, I 21 guess, from the mountains, so they don't get quite as much 22 lightning as you get in the mountainous parts of the 23 state.
24 MR. DYER: I can tell you for a fact Comanche
(,,) 25 Peak is right in the thunderstorm pathway. It comes up.
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84 1 MEMBER POWERS: When you mentioned activities
/
( )
-) 2 during periods where there's thunderstorm in the area, do 3 you rely on digital indications of thunderstorms, or do 4 you use ground potential measurements?
5 MR. DYER: Actually I think we use the Weather 6 Channel. I think the individual -- the sites are very 7 sensitive to it now, and --
8 MEMBER SEALE: They're not monitoring ground 9 protections routinely?
10 MR. DYER: I -- quite frankly, I don't know.
11 MR. GWYNN: I can't answer that question. I 12 don't know.
13 MEMBER SEALE: It would be interesting to know p
t 4 km) 14 if they try to monitor current off those little whiskers 15 they have.
l 16 MEMBER POWERS: Measuring the ground potential 17 is such an easy thing to do, and it's -- I mean, in 18 explosives business, you do it routinely, because your 19 eyeball and the Weather Channel, good as it might be, is 20 usually not a good indicator how much lightning you're 21 going to have, and --
22 MEMBER MILLER: It may be too late.
23 MEMBER POWERS: Well, the problem is you get 24 lightning when there's not obviously a storm present. You
(\
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85 1 storm.
l
.. 2 MEMBER MILLER: As I've mentioned, there's l
\
'l 3 guidelines coming down the pike which we'll seen in 4 November.
5 MEMBER POWERS: We've seen a draft of it l
6 already.
7 MEMBER MILLER: We have? .
l 8 MEMBER POWERS: Yes. I have a draft of it.
9 MEMBER MILLER: Oh , I haven't seen one. That 10 is the one, of course, we emulated last fall.
11 MEMBER POWERS: I definitely ha're draf ts of it 12 already.
13 MEMBER MILLER: Any mention of nonitoring the
()
(sl 14 ground potential in there?
15 MEMBER POWERS: They do not.
16 MEMBER MILLER: We'll have to bring that up.
17 MEMBER POWERS: That's why we want to review 18 it.
19 CHAIRMAN BARTON: Before lightning stri'tes, 20 we're going to move on.
21 MEMBER SEALE: Could I ask one question? Dr.
22 Powers wrote me a little here, and I think it's worth 23 passing -- you're talking about your problems with your 24 inspectors, just keeping them. Are there any special
,/ m
( ) 25 incentives for inspectors?
,J w
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86 1 MR. DYER: Yes. You know, particularly for
,- 2 the resident inspectors, there is the bonus. There is a
?
' ')
3 bonus for the -- going into or coming off of a site.
4 MEMBER SEALE: But not while you're there.
5 MR. GWYNN: That's what we're trying to 6 address, because in the past -- and I was a resident 7 inspector; Dwight was a resident inspector. When we were 8 in the program, the resident inspectors were and continue
[
9 to be on a special pay scale, and that special pay scale, 10 if they were working in the regional office, they'd be 11 getting paid one level; if they're working at a site, they 12 get paid that much plus three steps in the pay scale. So i 13 it's a three-step increase, and that gave them an I
'(
a
/ 14 incentive; gave me an incentive to want to be in the 15 program and to stay in it.
16 But today, the Government-wide has gone to 17 locality pay, and the regional offices and headquarters 18 are usually in locality pay areas; the sites aren't. And 19 so there's been a significant erosion of that three steps, l i
20 such that today there's very little difference between the 21 salaries in the two locations. And with the relocation 22 bonus, it gives people an incentive to move out to a site, 23 but it also gives them an incentive to move back. j n
24 So if they don't have an incentive to stay,
/~T 25 the three-step increase which has been eroded, then x/
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87 1
1 there's a disincentive for them to stay at the site.
1 s 2 MEMBER SEALE: I guess my reaction is -- 1
( ) l MR. GWYNN:
3 We're working to fix that.
1 4 MEMBER SEALE: -- who was dumb enough to think 5 that you wouldn't have this problem when you went to that 6 approach?
l 7 MR. GWYNN: Well, the locality pay was not an 8 agency decision. l 9 MEMBER SEALE: I appreciate it, but, by golly, 10 that's something you didn't have to stand there and wait l
11 for the railroad to run over you to know you were in the ;
l l
12 track. '
13 MR. CHAMBERLAIN: They did add the moving
- 14 bonus to try to compensate, because they didn't have a 15 moving bonus before that.
16 MEMBER POWERS: But it's like he said. It's 17 now an incentive to go and then find another job.
18 MR. DYER: I think, you know, we'd like that, 19 you know. I mean, that was the thrust. We wanted to have )
20 mobile resident inspectors, maybe not as mobile as -- we 21 over-achieved. And I think that's what we're finding out l l
22 now, plus the fact that I think the -- given the l
l 23 experience drains with the early-out program and that, 1 24 there's been particularly from headquarters a lot of (D
( 1 25 movement out, and resident inspector experience is a n/ n l
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2
88 1 highly desirable attribute to have in headquarters as well
.s 2 as in the region.
\'~' l l 3 MEMBER POWERS: I think it is difficult to 4 train inspectors. It's an experience-based education i l
l that's 95, 90 percent, something like that -- the 5
6 education is just a frosting on that cake.
i 7 MR. DYER: I can say, you know, the bonus 8 comes -- carries with it a two-year commitment at the 1
9 resident -- at the site, and in the last six months, I've 10 signed two waivers for people to keep their bonus and 11 leave early, because they got promotions. And typically 12 it's a year to year and a half to qualify.
13 So, I mean, as far as getting full-time
,r~3 (sl 14 resident inspector support, you know, we've probably got 15 six months out of them. One of them we moved from one 16 site to another in a promotion.
17 Our overall qualification process: We have 18 mandatory training. You know, if you follow the program 19 office guidance on individual development plans, those are 20 optional. One of the things that we mandate within the 21 Region is a training plan, which takes a look at the next 22 one year's worth of training, and it's negotiated and 23 developed between the employee and his or her supervisor, 24 and it'll identify, you know, what the expectations are (y
( ,) 25 for the next upcoming year.
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89 1 That's our basis for budgeting and bringing to
,s 2 the training committee what the anticipated needs are for
( )
3 the Region. That's what we use for scheduling purposes ;
i 4 and that, to identify what we need. And so we've 5 implemented here in the Region a training plan that -- j 6 between the employee and his or her supervisor. l 7 We also have -- as part of that training plan, 8 we have a qualification, the qualification process for 9 individual inspectors and examiners, consisting of the 10 direction -- I mean, the ::equirements that are in the HOLB 11 guidance and the manual chapter 12.45. In addition, in 12 Region IV, we've identified some additional requirements 13 that we want to have on a regional basis.
I K_/ 14 Largely those are involvement with incident 15 response, where the -- one of the things that we think is 16 that -- where the inspector qualifications deal largely 17 with what does it take to be an inspector, we also have 18 the need for incident response, and that as part of your 19 inspector qualifications, because our inspectors are 20 providing site coverage during counterpart meetings.
21 Of course, our residents are first responders 22 normally, is that any inspector at any site could be 23 called upon to be the first recponder to a plant event 24 that we insist that they have experience, understanding,
()
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90 1 response coordinator, and a walk-through from our incident
,s 2 response center, and what the expectations are for, you
\ ,
3 know, a trip with complications, and they respond to the 4 site, who they call, when they call, and what kind of ,
I 5 information we're going to be wanting and insisting upon 6 here from the Region.
7 So that's where we -- we also have additional 8 requirements to make sure they understand the SALP process i 1
9 and a lot of the activities that are going on in the I
10 Region, and recently we enhanced the inspector j 11 qualification requirements in the area of allegations, to 12 make sure.
13 We found that most of our allegations come
'\s / 14 from interactions with inspectors on the sites, and if the 15 inspectors don't properly handle that initial encounter 16 with an alleger, we pay for it later, either by being 17 inefficient or having -- you know, not taking the proper 18 actions on an allegation, and that's the kind of rework we 19 just can't afford in our current climate of reduced 20 resources.
21 Additionally, one of the things that we've 22 done here in the DRS organization is all our examiners are 23 cross-qualified among different -- all the different 24 vendor-types and we've qualified the examiners as i
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i' 91 i
1 operating licensing branch, a particular weakness with our
,. 2 resident inspector program has been the sensitivity to
',' '/
3 proper reactor operations in the control room, what the 1
4 expectations are. I i
5 Our residents are in the control room daily, 1
I 6 and for them not to have a -- you know, they may overlook ,
l 7 things that a trained eye from the examiner and operator 8 licensing viewpoint would pick up as far as how the shift l l
9 turnover's conducted, how the operators walk down panels, 10 review of procedures, plant conditions, and things like .
1 11 that.
I 12 And we've found that in the course of our ,
1 13 examiners going out on inspections or in the conduct of r'%. I 5
i
(/ 14 exams themselves, that if we add a couple days on and have !
i 15 them cross-train some of our inspectors, particularly the l l
16 residents at the sites, we gain some benefits. ;
1 17 And we've got positive feedback from the 18 inspectors that said, you know, that after the examiner l 19 walked them through a shift turnover, they had about five 20 or things that they, you know, were totally insensitive 21 to. And it's just that different perspective that really 22 has paid off, and so we're continuing with that activity 23 here in this region.
24 MEMBER POWERS: I don't know what the t'%
25 experience is within NRC, but I know the experience within (v)
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92 1 Department of Energy that shift turnovers can be the s 2 biggest source of subsequent events of anything I can
/
N )i
l 3 think of. I mean, it's more than maintenance.
l 4 It's just amazing that amazingly complicated 5 events will be going on, and the guy just doesn't mention ,
1 6 it to his replacement. Oh, by the way, this thing's about 7 to die.
8 MR. DYER: I think the other thing that I 9 wanted to talk about, too, is that, you know, in the 10 program guidance for qualification, it talks about interim l 11 and final certifications. We -- you know, going through .
I 12 the board process and then the final interview with the I
13 regional administrator, and in this region, we -- it's a i e% i
( \ '
s/ 14 combined interview with the regional administrator and i l
15 division directors on the initial qual, and any subsequent l
16 qualifications, it's an interview with the regional j l
17 administrator. ],
18 Or if we hire in an inspector who's already 19 qualified from another region, and they go through their 20 site-specific quals or job-specific qualifications, then 21 before they recertify, they have a final meeting with the 22 regional administrator and maybe the deputy regional 23 administrator, but just to go brough what -- just for us l
24 to make sure we have a confidence from a management
, (O) 25 standpoint with the people we're qualifying inspectors.
I w./
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93 1 One of the things that we recently changed 7y 2 here is we found that we were getting sloppy as we did an
()
3 internal audit. The process in headquarters and used to 4 be in this region was to allow an interim certification.
5 In other words, you can get productive work out of a 6 trainee if you go out and qualify them on specific 7 inspection modules, particularly at the sites.
8 You know, certain modules, inspectors would 9 qualify on, and we would be allowed to capture their 10 inspection activities under -- as if they were a fully 11 qualified inspector, and then what happens is you find out 12 by the time they qualify on all modules, sometimes they 13 lost the emphasis or the branch chief did to complete the p
Y 14 qualification process and that, or particularly if you had 15 one senior resident --
16 I think the most embarrassing point when I was 17 a DRP director was that we had a senior resident who was 18 on his third site, and we had a branch chief turnover, and 19 when the new branch chief went in to review the training 20 records, he realized that the existing senior resident at 21 a particular site had never finished his qualification.
22 Everybody -- I mean, we all knew him. He'd 23 been a senior in the region before, and he had just never 24 had the final check-out from the regional administrator or
! 25 the new division director and that. And so as it turned u-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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94 1 out, I think we issued his four-year letter, which told 73 2 him he had one year left at the site, at the same time we
( )
~
3 issued his final certification as a qualified senior 4 resident inspector at that site.
5 And so as a result of that, interim 6 certifications are only good for six months, and they have 7 to be renewed by the -- with the regional administrator 8 now, and the division director gets to renew that, and 9 it's just a good tickler for us to put the heat from the 10 regional administrator's office on the divisions and the 11 divisions to the branch chiefs, that once you start 12 getting productive work out of the individual, you don't 13 forget about the qualification process.
(\
ss 14 And so that's it. Again, the other thing is 15 the fundamentals of inspection refresher course. One
, 16 aspect that we have here in this region with that is that 17 we accomplished that training via our counterpart meetings 18 and ou?. training weeks. You know, the requirements are 19 basically every three years, that inspectors outside of 20 their technical requirements receive ongoing inspector 21 training, four hours from a regional management 22 perspective and four hours from a program office 23 perspective.
24 And the way we accomplish again is that during em
'. j) 25 our counterpart meetings, we specifically track that for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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95 1 the individual inspectors and the attendance at the --
,~, 2 when we have an agenda for the counterpart meetings, there 3 are specific topics that are identified as part of the 4 fundamentals of inspection refresher course.
5 That completes my part of the panel. I've 6 taken most of the time. If there's any other questions on 7 those --
8 (No response.)
9 MR. DYER: Okay. Did you want to take a break 10 now, or did you want to continue? )
i 11 CHAIRMAN BARTON: How about a five-minute 12 break.
13 (Whereupon, a short recess was taken.) j 7-~8 4 1
(_)
14 CHAIRMAN BARTON: For sake of time, do you 15 want to start at the -- I think most of us know about j 16 frazil ice at Wolf Creek; if we've got time, we'll go back l
17 to it -- start with the Fort Calhoun steam extraction 18 event?
19 MR. CHAMBERLAIN: Jeff Shackelford's going to 20 give that discussion. He's the one that led the team 21 inspection there. You've already met him. He's an SRA.
22 So I'll turn it over to him for that discussion.
23 MR. SHACKELFORD: Okay. Before we start, I 24 just wanted to point out that I put this display board up
,3 25 in the corner over here. I don't know if you had a chance
(.v)
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l 96 !
l 1 to look at it. It has some additional photos and l l
1 2 information about the event. If you get time between the
/ - ,T ]
s j ;
'# sessions, you might want to take a look at it.
3 l l
4 We gave this presentation to the senior )
l l
5 resident and resident inspectors during the last ;
1 6 counterpart meeting, so it was an information-sharing type l l
7 event, so that they could take any lessons learned that we 8 found at Fort Calhoun for their sites, and, you know, one l l
9 of our methods of communicating this to the NRC and the l l
10 industry, and I have a slide on that later on, to show you l l
l 11 how we tried to -- our ongoing effort to communicate what l l
12 went on there. l l
13 On April 21 of this year, there was a rupture I r^s' i/m 14 in the extraction steam line at Fort Calhoun. Basically, 15 the fundamental cause of this was full accelerated 16 corrosion in one of pipe elbows there.
17 In terms of safety significance, this event 18 led to what we considered to be an unnecessary plant, 19 transient, and personnel hazard. Fortunately, there were 20 no people in the vicinity of the rupture when it occurred.
21 And I put a picture of the pipe rupture. I think you may 22 have seen a copy of it, and there's one up here. And I'm 23 real sensitive to -- when I've given this briefing several 24 times, I don't like it when people call it a steam leak,
./'N 25 so --
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97 !
1 This was not a steam leak. This was a steam 2 rupture. And Fort Calhoun recognizes that, and they are
',s l
) i 3 thankful that no one got hurt.
l 4 MEMBER POWERS: To be quite honest with you, I 5 the pipe picture is not as effective as the surrounding 6 equipment pictures. It makes it perfectly obvious.
7 MR. SHACKELFORD: Right. If we had more time, ,
I 8 the presentation we gave with the residents -- I actually i 9 have a video of walking through the plant. The plant was )
l 1
10 essentially inaccessible for about four or five days !
l l
11 following the event, due to asbestos contamination in the 1 l
l 12 plant. j 13 So there were a lot of side issues, you might
( ) !
\_/ 14 call it, other than what would have been the root cause 1 15 here of the pipe being ruptured.
16 MR. PERKINS: Maybe if we don't get a chance 17 to see that, we could get a copy, and I could show it l
18 during --
l 19 MR. SHACKELFORD: Sure. It's about a ten- or 20 fifteen-minute just --
21 MEMBER POWERS: That would be very helpful.
22 Yes.
23 MEMBER KRESS: Is this safety significance, l
24 which says it led to unnecessary plant, transient, and (n) 25 personnel hazard, is that a standard category of safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 l 98 l l
1 significance? I i
fx 2 MR. SHACKELFORD: I don't know about standard i/
i\
) i l
3 category. I guess what we mean there is we felt that this 4 pipe rupture was preventable, and we'll even discuss that 5 later on. But it caused the operators to trip the plant.
6 There were some other interactions later on. l 7 The fire protection, for example, was actuated due to some 8 steam heating of the fusible links. There was some 9 intermittent grounding on some switch gears. All of that 10 together, I guess, we considered to be an unnecessary 11 challenge to the plant and the operators caused by --
12 MEMBER KRESS: You don't have categories of 13 safety significance to check off and say, This is category N h
'v 14 1 safety significance --
15 MR. SHACKELFORD: Not in those terms. I mean, 16 the enforcement policy itself kind of tries to do that.
17 MR. GWYNN: In terms of the international 18 standard that's used, we don't -- we have not classified 19 this event.
20 MR. SHACKELFORD: Okay. The next few bullets 21 just kind of go along, describing the event. As I said, 22 on April 21, 1997, it was probably about 8:30 in the 23 evening; that's part of the reason that -- they weren't at 24 a shift turnover time, and most of the day people were l p/
(v 25 gone. That's one of the reasons no one was in the j
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99 i
l 1 vicinity.
l l
,s 2 This is a very high-traffic area where this
\
)
3 pipe is located, and if you've ever been to Fort Calhoun 4 or if you ever go there, you're almost certain to walk 5 right by this particular pipe.
6 But the operators heard a loud noise in the 7 turbine building and then a continuous, I guess, roar, you 8 might call it. They can look out -- they can open the 9 door from the control room and look out onto the turbine 10 deck, and when they did, they saw steam and the noise, so 11 they immediately tripped the reactor, and I think the 12 estimates were that it took them about 19 seconds to -- ;
13 between the time they heard the rupture and the time they
( l
\' ' 14 actually tripped the unit.
i 15 They really didn't receive any primary site l
16 indications in the control room. This is -- I don't know i l
17 how familiar you are with the secondary plant there, but 18 this is an extraction steam line that comes off the high 19 pressure turbine. Once they tripped the reactor and that, 20 in effect, tripped the turbine, and that had the effect of 21 isolating the steam rupture.
22 However, they didn't know at the time where 23 the rupture was, but they did have a fair indication they 24 might have steam rupture, so they went into their
,r x
() 25 emergency procedures and initiated emergency boration as a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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100 1 precautionary measure, just to ensure that they would have
, _s 2 adequate shutdown margins.
i 3 MEMBER POWERS: Where does that extraction 4 steam go?
5 MR. SHACKELFORD: It goes to the feedwater 6 heaters. It's part of the --
7 MEMBER FONTANA: It preheats the feedwater?
8 MR. SHACKELFORD: -- efficiency of the 9 secondary plant. l 10 MEMBER FONTANA: Regenerative feedwater i 11 heater. Right?
l 12 MR. SHACKELFORD: I guess you would call it l l
l 13 that. It's steam right off the main steam that's feeding i
/^\
(_,) 14 the -- heating the feedwater going back to the steam l
15 generators, a secondary site efficiency consideration. l 16 MEMBER SEALE: What pressure is that system ;
17 at?
18 MR. SHACKELFORD: 250 pounds, 400 degrees 19 Fahrenheit was what they estimated the operating 20 conditions. The design conditions are a little bit higher 21 than that. I believe it's 325, 425.
22 MEMBER POWERS: I take it you're fairly 23 supportive of the operators going to the emergency 24 procedures at this point.
t%
t-v j 25 MR. SHACKELFORD: Right. Later on in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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l 101 I i
1 discussion -- we ended up determining -- and I don't know 2 if you had a chance to read our inspection report. But we ;
i )
\
3 gave the operators, I guess, a thumbs-up, if you will. We 4 thought that they -- they probably, even though we don't 5 go on to speculate this in the report, but they may have 6 saved the plant additional damage and complication by 7 acting so quickly.
8 The plant did not trip automatically on this 9 eva.t, and it's not clear that it maybe ever would have, 10 or it might have been some time before it did, so by 11 isolating the steam leak or rupture, I guess -- I guess 1 12 I'm the only one who can call it a leak. By isolating the l 13 rupture early, I guess it would be safe to say that they
,a s
x_/ 14 probably did avoid --
l 15 MEMBER POWERS: What you know for sure is by 16 isolating early, you prevented any ancillary damage to 17 equipment --
18 MR. SHACKELFORD: Right.
19 MEMBER POWERS: -- from the steam flow.
20 MR. SHACKELFORD: Right. And --
21 MEMBER POWERS: And I think you emphasized 22 that in the report.
23 MR. SHACKELFORD: Right. There were 24 interactions with the primary site, I guess you can call
,ey 25 There are some switches and pressure transmitters in
() it.
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102 1 the blow-down path there that will feed the system, the
,s 2 emergency switch gear room that's just several away from i )
~'
3 the site of the rupture.
4 Part of our inspection and part of our initial 5 response was to determine what kind of primary site 6 indications or interactions may have occurred in terms of l
7 the risk significance of this event. Could this event 8 have gone on to disable equipment necessary to mitigate I
9 it, and that was our concern initially, because there were 10 grounds on some safety-related equipment.
11 And part of our follow-up was to look at how 12 that came about.
13 MEMBER POWERS: One of the areas that C\
'x / 14 persistently comes up in connection with fire events is if 15 you had a small event that gets put out, nobody thinks 16 about it. Smoke goes up, goes into the electronic 17 packages and things like that. Six months later you've 18 got a problem, because of corrosion of contacts and things 19 like that.
l 20 MR. SHACKELFORD: That's one of the ;
21 sensitivities of our regional administrator. He was on 1 l
22 board in Region II when Sequoyah had their steam rupture, 23 and one of the complications was, after all was said and 24 done, the moistures left in certain contacts and j e'
(x)
%s 25 transmitters that sets up corrosion circuit, if you will, I i
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103 1 and then later on, it comes back to trip the plant.
,s 2 And we made that very clear to Fort Calhoun,
/ \
3 that we wanted to know what they were going to do to 4 address that issue, and they were sensitive to that as 5 well, and part of their corrective action and commitment 6 going forward was --
7 They obviously inspected all of the applicable 8 equipment in the blow-down path, but they've also 9 instituted a program to periodically go back and check 10 various transmitters that even didn't have moisture in 11 them, just to make sure, because the moisture can be very l 12 hard to detect. You just really can't see it unless it's 13 really bad, so they are looking periodically at equipment i (o
! \_ '
i 14 out there to address that issue.
l l
15 I guess that's -- we felt like that's really i
l 16 all they could do, because they did do a comprehensive 17 walk-down of the damage, and they're continuing to look at 18 it.
19 As it says here, during the event, the fire 20 suppression systems actuated, and those -- basically the 21 fusible links on some of the heads were fused due to the 22 temperature of the steam and then sprayed down some 23 equipment, and the deluge system over the lube oil 24 reservoir, which is actuated by a rate of temperature
(%
(J) 25 rise, gave way, and it actuated.
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104 1 The complication here was that they realized I
,- 2 fairly soon there was no fire. They didn't need this ;
\ /
~
3 actuation, so they were attempting to isolate the affected 4 portions, and there was some confusion about the 5 procedures that should be used and how to do that. And 6 they ended up taking the entire fire protection system to 7 full lock to stop the unnecessary spray-down of the 8 equipment.
9 And that was a subject of another fire 10 protection issue that was just at issue with the plant. ,
I 11 We didn't fault the operators for that particular issue, l
because they did have a procedure in hand that allowed 12 l
13 them to do that. But we questioned whether or not that
[ :
\~- 14 procedure was appropriate.
15 Moving on, the rupture was in a 12-inch four-16 stage extraction steam line, and there you see the --
17 basically the steam conditions inside the line. It's a 18 fairly spectacular rupture. This is what they call a 19 large radius of sweep elbow, and it was probably about a 20 six-square-foot hole opened up in the side of the pipe.
21 This particular location was in the licensee's 22 erosion / corrosion monitoring program, How' er, it had 23 never been actually inspected by NDE techniques during the 24 , life of the plant. They were using what many of you are (A,) 25 probably familiar with as the checworks computer code to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1r3 RHODE ISMND AVE., N W.
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105 1 predict wear rates in various parts of various systems,
,- s 2 and then using that as a guide as to which locations to I' ') 3 inspect and not.
4 And at the time, they believed that this was a 5 relatively low wear rate location and that other locations 6 in this same system should be wearing at higher rates, and 7 they were inspecting those particular locations. As it 8 turned out, those locations they were inspecting did not 9 exhibit significant wear, so their belief was that if the 10 worst case is okay, then you don't need to worry forward.
11 MEMBER POWERS: The reason they don't get wear 12 at those locations is because they were getting the wear ;
13 upstream of it.
p
(_) 14 MR. SHACKELFORD: There's still, I guess --
15 there's even new information that's come to our attention 16 as late as this week about problems with Checworks and 17 their implementation of it. One of the problems at least l
18 was one of these otherwise high-wear rate locations, they l 19 have now determined was an elbow that they had replaced in 20 1985 and had not factored into their model.
21 So, in other words, their modeling program 22 thinks this is a 20-year-old elbow that hasn't worn out 23 very much; therefore, the other 20-year-old elbows are in 24 the same condition, when, in fact, this is not a 20-year-A
! l 25 old elbow, and so --
R/
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l 106 l 1 CHAIRMAN BARTON: Isn't this like a lot of 7s 2 other events? When you dig into it, you find out that I I
( {
'~'
3 they had found some fitting in some other areas by the i i
4 erosion / corrosion program and just didn't go far enough in 5 inspecting --
6 MR. SHACKELFORD: Right.
7 CHAIRMAN BARTON: -- and if they had gone to )
8 this elbow, they would have seen thinning at that point 9 when they replaced some other pipe and elbows a few years 10 ago? l l
11 MR. SHACKELFORD: Right. That's in their -- I 12 think you probably saw that in the inspection report. We l 13 determined that the next upstream elbow had been replaced I
<x '
i \
\~ / 14 in 1985 due to excessive corrosion.
15 CHAIRMAN BARTON: Accelerated corrosion.
16 MR. SHACKELFORD: Right. When they went 17 forward with their program -- I believe it was in -- I 18 forget the dates now, but when they instituted their 19 erosion / corrosion program in '88, they failed to really go 20 back and look at past history as well as they should have, 21 so their belief and checworks was telling them that this 22 large radius elbow won't -- is not going to be a big 23 problem for you.
24 They didn't remember, I guess you could say, (O,) 25 that they had a problem with a large radius elbow, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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107 1 would have -- no matter what checworks tells you, if 2 you've got plant-specific information, it's going to be i, s) 3 more valuable to you. So that was just another deficiency 4 that we noted there.
5 And that's why I say this was a preventable 6 event. I mean, we're looking in hindsight, and we're very 7 good at that. But these are not subtle issues. These are 8 right there, so -- and they acknowledge that. They're not 9 trying to, I don't think, take the high road on that.
10 But unfortunately the missed it, and the only 11 good thing about it, as I said, was no one in the vicinity 12 of the rupture when it happened.
13 MEMBER SHACK: Now, flow-assisted corrosion em
! l Y-) 14 is, you know, an area that the NRC decided to leave to 15 industry really to develop a program to react to. When 16 they developed their program, you presume will be 17 inspected in some way, that the program was satisfactory.
18 What did you use to judge the acceptability of the program 19 when they set it up?
20 MR. SHACKELFORD: Okay. I did a lot of -- I 21 became very fluent in erosion / corrosion during this time, 22 so I became knowledgeable about the history of this.
23 I was looking for regulatory requirements, and 24 prior to the maintenance rule, there were just -- to be m
k_,) 25 honest with you, I mean, there's a generic letter and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 1 there's a bulletin, and there are responses to the same,
,- 2 but none of those constitute a regulatory requirement.
)
'# 3 MEMBER KRESS: That's because this is a 4 secondary system?
5 MR. SHACKELFORD: Right. This is completely a 6 nonsafety-related secondary side system.
7 MR. CHAMBERLAIN: I think, Pat, you might have 8 some insight what kind of inspections we did, but I think 9 it was more performance-based. If there was problems, we 10 went out and looked. Why didn't the program detect it, I
11 but we did do those kind of reactive things.
12 MR. SHACKELFORD: There was an inspection, and 13 we looked at the results of that, and then the
,r s
_, 14 inspection --
15 MEMBER SHACK: Because it was looking at good i
16 elbows, said everything was terrific. i I
17 MR. SHACKELFORD: Right. j i
i 18 MEMBER KRESS: Does this use -- j 19 MR. SRACKELFORD: Primarily UT.
20 MEMBER FONTANA: You can actually inspect this 21 stuff. This has the type of insulation -- i 22 MR. SHACKELFORD: Right. It has reflective 23 insulation.
24 MEMBER FONTANA: Do you have to remove that?
,r n '
(~/ ) 25 MR. SHACKELFORD: Yes. You have to remove the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 109 l
1 insulation and grid the elbow. It's a labor-intensive l z_, 2 process to inspect each pipe. It is. But you can see
( )
'# 3 what happens if you don't, so --
4 But this particular elbow is estimated that 5 it, you know -- we're concluding after-the-fact readings 6 here, which could be somewhat distorted by the event 7 itself, but .05 inches for about two feet, so you've got a 8 two or three-inch wide, two-foot long strip that's about l
9 half the thickness of a penny, whereas t.le nominal wall l 10 thickness of that pipe is almost half an inch. So this is 1
11 a significant amount of degradation in that pipe.
l 12 In the follow-up, they inspected many other l l
l 13 elbows. Okay? You can imagine the type of follow-up l
~x l t a l x,/ 14 they've done. I should have brought in their corrective 15 action documents. It's a volume this thick, the things 16 they did and people they talked to. l l
17 They had Jim Taylor, the former EDO, there as 1
18 part of their advisory committee, so they really did an l
19 extensive follow-up. But they found another elbow 20 downstream of this -- the one that broke that was thinner.
21 It just didn't happen to rupture.
22 MEMBER KRESS: If you go back and plug in the 23 wet steam conditions and the flow conditions in the i 24 Checworks, will it after the fact tell you that you should I,,
) 25 have expected this kind of erosion?
- x. _/
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110 1 MR. SHACKELFORD: At the time, they did had
,s 2 EPRI on site and many other experts, trying to determine
( )
\ /
3 why Checworks had failed to predict this, and they 4 couldn't come up with any satisfactory answers.
5 The one thing that I did, you know, after the 6 fact, that -- and there again, it's hindsight, but I think 7 it's something that would have been obvious to someone 8 doing it.
9 You could have plotted the predicted values 10 versus the actual values on a graph, and Checworks tells 11 you to do that. And if you had done that, you would have 12 seen this large, diffuse cloud of points which, if nothing 13 else, would tell you you have no predictive capability in im.,
~- 14 this area.
15 Now, that -- you know, so that's not really a 16 black mark against Checworks at that point. It's telling 17 you, I don't know how to predict this line. If it's a 18 tight pattern of points, then you have some reasonable l l
19 prediction. They weren't doing that. So regardless of 20 how good or bad Checworks may have been predicting this 21 wear rate, they did have an ability to have detected that 22 that they had missed.
1
! 23 And, here again, they acknowledge that, and 24 it's a part of being able to use Checworks effectively. I O)
(, 25 mean, I read the Checworks manual and talked to the people l NEAL R. GROSS j COURT REPORTERS AND TRANSCRIBERS
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L
111 1 there, and it's in there, but this would be a more
,- 2 sophisticated use of the code, I think. I think it's sort 3 of a --
4 When we talk about generic implications, that 5 may be one of them is if you're going to use one of these 6 methodologies, you really need to know how to do it.
7 MEMBER KRESS: Is Checworks relied on for the 8 same information in other parts of the plant that may be 9 more risk or safety-significant?
10 MR. SHACKELFORD: I wouldn't say so. You ,
11 know, obviously the primary side is under the ISI program, 12 and they do some modeling there, too, but they rely on a 13 lot more --
l
,7
)
/ 14 MEMBER KRESS: Even there, they don't inspect l l
i 15 the full system. '
16 MR. SHACKELFORD: No. Checworks is used all l 17 over the world and all over the plant. l l
l 18 MEMBER KRESS: But we wouldn't expect this l l 19 kind of erosion from the primary system. l 20 MR. SHACKELFORD: Right. I mean, this is a --
21 you know, it's like a two-phase phenomenon.
22 MEMBER KRESS: It's a steam problem.
23 MR. SHACKELFORD: Right.
24 MEMBER SHACK: Well, no. You can have a
) 25 single-phase feedwater. I mean, Surry's got a great big NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
112 1 rupture.
~, 2 MR. SHACKELFORD: Right. If you look at the
>' \
~
3 industry guidance on *hle, NSAC 202 and some other 4 guidance documents tell you, what are your most 5 susceptible systems, and extraction steam is notorious.
6 You know, we'll get to that in a second when you look back 7 here. It is a bad actor in the world of flow-accelerated 8 corrosion.
9 Feedwater is really not. I mean, some of the 10 more spectacular events have occurred, and people got 11 killed at Surry and so forth and Sequoyah.
12 MEMBER SHACK: You're right. Hundreds of them 13 happen in extraction steam lines. I mean --
,e t
'/ 14 MEMBER SEALE: Let me ask you. Does anyone 15 use Checworks in fossil plants?
16 MR. SHACKELFORD: I believe they do.
17 MEMBER SEALE: I would be amazed if they 18 didn't.
19 MR. SHACKELFORD: See, Checworks is really a 20 suite of codes, and when I say Checworks here, I really 21 mean the flow-accelerated corrosion module of the 22 Checworks. They have modules for other applications, and 23 for instance, service -- you know, it's a large market, 24 and what --
,r 3
(,) 25 MEMBER SEALE: Especially if they use it in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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113 1 fossil plants. Yes.
,_ 2 MR. SHACKELFORD: They publish a textbook on
\
\I 3 this, and there's a lot of fossil-related events and 4 fossil-related applications. I obviously didn't really 5 get into that during this inspection, but I had the 6 impression that they had a pretty wide market.
7 If you wanted to go out and buy yourself a 8 copy of Checworks and model your home, let's say, you'd 9 have to pay about $150,000 for it. The EPRI members get 10 it free, but they have to pay $50,000 a year to be a 11 member of the users group and get the updates.
12 MEMBER FONTANA: That's one thing I thought 13 was kind of amusing when I read the report. You know, it O
(,/ 14 kind of cast aspersions on Checworks, and I get to the end 15 and want to find out more about Checworks, and it says, 16 Oh, it's proprietary.
17 MR. SHACKELFORD: Yes. It's all proprietary.
18 And I have some slides. I didn't realize this was going 1
19 to be a public meeting and transcribed, which I had some l l
20 slides that went into a little bit more detail about the l l
21 approach and algorithm that Checworks uses, but I had to l
22 take them out. But I guess if you're interested in 23 follow-up discussions or something, I might could probably I
l 24 do that.
l
,e~N
, t. ) 25 MEMBER KRESS: I think we planned on looking
, w; NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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114 i
l 1 into Checworks in one of our subcommittees. l l
, 2 MEMBER SEALE: But this may indicate we'll
, i \
' ')
[
l r l 3 have to close part of that meeting, so we can really dig i
i l l l 4 into the details.
l l 5 MR. SHACKELFORD: I think some of this recent l i 1 6 information that I was talking about -- I mean, in the l 7 beginning, I had a very negative impression of Checworks, l
l 8 because I couldn't find out anything the licensee had done !
l I
9 wrong, and yet in terms of the modeling and the l
10 predictions were still bad.
l 11 I still felt like they could have identified l 12 that the predictions were bad if they had evaluated the i
13 data properly, but, you know, they can only go so far. l 1
1 f~)
(_s/ 14 So -- but this new information does indicate that their l l
l 15 application of Checworks was less than stellar, so 16 Checworks itself may not be --
17 CHAIRMAN BARTON: Don't condemn the program; i l
18 condemn the implementation of the program. l 19 MR. SHACKELFORD: Checworks is probably a good 20 tool in the sense that they can't inspect every inch of --
21 MEMBER SEALE: Well, how old is the data l
22 presentation package part of it?
23 MR. SHACKELFORD: Excuse me?
24 MEMBER SEALE: The data -- you know, now
/s 25 you've done the calculation. If it's a fairly modern (U)
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(
i
115 1 code, it's likely that everything is plotted against
,_s 2 everything in all kinds of glory, and you can probably do
! \
() 3 the kind of interpretive analysis you're talking about on 4 line.
5 MR. SHACKELFORD: Well, see, one of my -- this 6 is something that obviously I wouldn't have put in the 7 report, but it was my impression of Checworks that 8 Checworks is a beautiful interface. I mean, you know, it 9 gives you color-coded graphs of the pipe and, you know, 10 very nice graphics and models, and --
11 MEMBER SHACK: You almost believe it.
12 MR. SHACKELFORD: You want to believe that, 13 and if you're not really a skeptical, sophisticated user, f)
(_ 14 then, you know, it's a computerized presentation of this, 15 and you need to really look at what it's telling you. I 16 think that was one of the lessons that Fort Calhoun may 17 have learned from this is that it's a vecy nice package, 18 and it is a valuable tool for them. Don't get me wrong.
19 But it requires the correct level of )
20 interpretation of the results to make sure that you l 21 understand what it's telling you. Just because it's a 22 color-coded rendition of the pipe doesn't mean that's the 23 actual condition that's there.
24 MEMBER SEALE: By the time they get through, O.
( ) 25 you think you're on Mars.
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116 1 MR. SHACKELFORD: I wouldn't go that far.
7
- 2 MR. MERSCHOFF: If I could interrupt you for a 3 minute, you made an excellent point in terms of this is an 4 application issue. Many plants have had good success with 5 Checworks. It's intended as an iterative process that 6 converges on the model. There was a problem with the 7 application of the iterative approach here.
8 Now, this is a subject of potential escalating 9 enforcement that we'll be meeting with the licensee on, in 10 fact, just Monday, so there's some aspects here that we 11 really can't get into, and the question's still open in 12 terms of the enforcement on just how good or how bad this 13 particular application was.
Ox l V
\/ 14 MEMBER SHACK: But that is a problem in the 15 sense of the way this was handled from day one, with sort 16 of a generic letter that said there was a problem here and 17 the industry was going to develop a program, and you sort 18 of -- then it kind of just sort of left floating in the 19 air until we're down to this very performance-based kind 20 of thing, you know, that when the pipe ruptures, there's a 21 real problem.
22 MR. SRACKELFORD: Right. And if you look at l
l 23 the enforcement history of pipe ruptures -- and I did 24 prior -- to this event, it's typically -- you're not able
,1~
(_,/ 25 to cite the problem which occurred. You're not able to go l NEAL R. GROSS COURT REPORTERS AND TRANSCHlBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 in and say, You had bad erosion / corrosion control, because 7- 2 that's not a regulation. You would have to find some
( )
3 obscure operating procedure or maintenance procedure that 4 they may or may not have done well, and then cite against 5 that, and you kind of lose the message somewhere along the 6 way, you know.
7 MR. MERSCHOFF: But there is a change. The 8 maintenance rule has brought this category of equipment 9 within the regulatory arena. This is equipment that can 10 cause a transient to trip, and ca now it's within the 11 performance-based arena in a regulatory sense, and is, in 12 fact, this particular issue that will be discussed at the 13 enforcement conference on Monday, the nexus between poor
,n If i
\~s/ 14 performance, a rupture, and the maintenance rule 15 requirements to monitor the condition of a system to l
16 prevent -- to assure that it can perform its function.
17 MR. SHACKELFORD: As I said, we felt the 18 overall operator response was superior. You know, the l
I 19 operators acted in a very timely decisive manner and 20 tripped the plant and worked towards stabilizing the unit l 21 there.
l 22 There was extensive damage in the vicinity of 23 the rupture. I don't know if -- if you have the 24 opportunity to look, one of the motor control centers was em
( I 25 significantly deformed by the blast of the steam, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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118 1 there was a lot of insulation blown about the building.
)
7_ 2 The report contains a brief kind of rundown of the damage '
i l
\
\) 3 which occurred.
1 4 MEMBER POWERS: One of the issues that 5 continues to arise in connection with BWRs especially, but 6 even in connection with PWRs, is contamination of sumps by 7 blow-down from pipe ruptures. It looks like we've got an 8 additional data base on the amount of material and how far 9 it flies out of this experience.
1 10 Is anybody trying to collect that data base? l 1
11 MR. SHACKELFORD: I don't know that they --
12 the licensee -- we didn't really look at that in our 13 report, I mean, the quantity, let's say, of asbestos that
- 3 7
(s,)4 14 may have gotten distributed throughout the turbine 15 building, but they brought in special skids of filtration 16 equipment, and I couldn't even begin to tell you how much 17 they probably had spent to clean up that building.
18 MEMBER POWERS: I'm sure the clean-up was 19 painful.
20 MR. SHACKELFORD: Right.
21 MEMBER SHACK: But it would be nice to know if 22 the code that predicts just how far this stuff will blow 23 was reasonably close to accurate.
24 ME:1BER SEALE: And particularly for the BWR r'5 (v) 25 people, where you have, you know, all those sumps to worry NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 119 1 about.
1 1
7_s 2 MEMBER POWERS: You know, it has gone beyond I l ,
3 just the BWR. We have the problem with PWRs, because once 4 they go into recert, that's where this -- draw from the 5 sumps, and they plug up just as bad --
6 MR. SHACKELFORD: Well, I mean, this just j l
7 strips the pipes clean. I mean, this type of rupture '
8 just -- i 9 MEMBER POWERS: That's what we expected it to 10 do.
11 MR. SHACKELFORD: And if it's there, it's 12 going to -- if it's in the path --
13 MEMBER POWERS: How far down that pipe did
,~
\,J 14 it --
15 MEMBER SEALE: And how far did the flying 16 insulation go?
17 MR. SHACKELFORD: And there was, you know, 18 quite -- as you might expect, this physical deformation of 19 tubing and some cable trays and things -- I guess overall 20 :here wasn't a lot of significant equipment -- I mean, 21 there was more physical damage than operational damage of 22 equipment.
23 They did extensive testing of the cables and 24 things in the area. As a matter of interest, those A
25 cables, even though -- they are the same cables that are ix-)
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120 j 1 in the containment essentially, qualified in just kind of
,3 2 a locus or a steam-leak in containment. So they did that
( )
3 in this case. I guess that's another data point that 1
4 might be of interest. l 5 MEMBER SHACK: You don't happen to know if l 6 anybody went back with the ASME code case that is, you l l
l 7 know, used to evaluate whether you can survive this j 8 thinning and found out whether it would have, in fact, ,
)
9 predicted failure of this elbow and said you were okay on j I
10 the one that measured 0 2- !
l 11 MR. SHACKELFORD: You know, I think as part of I l
12 the licensee's follow-up -- because I've been following --
13 I became very close to this event during this whole thing,
/'^
i kT) 14 and they're continuing to look and find things. And one 15 of the issues that came up at their plant.
- ra s -- and you l 16 can correct me here if I'm wrong, because this wasn't 17 something we inspected at the time, but it seemed an 18 interesting point was that there's this issue of a l 19 critical flaw in a component.
20 In other words, for a given pipe and set of 21 conditions, you don't have to postulate a rupture in this 22 particular pipe, because you don't think it can happen.
23 You have -- the largest failure that you are required to 24 postulate is something far less than what happened here,
(~
!. ) 25 and that's based on some ASME-type guidance.
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121 1 Here, you --
2 MEMBER SHACK: Well, that's -- you know, those 7-
! I 3 things are usually assumed based on fatigue cracks, you 4 know. Erosion / corrosion was something they really didn't 5 envision in the code when it was originally done, but 6 there is a code case now that does allow you to evaluate 7 thinned pipe rather than, you know, the nominal quarter t 8 flaw, 2t long that's --
9 MR. SHACKELFORD: I'm not --
10 MEMBER SHACK: You don't know whether 11 that's -- but even there, I mean, there's really 12 relatively little information to validate that. You know, 13 that's really an analyst's prediction of what would
(_ / 14 happen, and --
15 MR. SHACKELFORD: Well, Fort Calhoun has been 16 very active in the aftermath of this, trying to 17 communicate their findings to the industry. They've gone
! 18 to some EPRI meetings and conferences and -- they call it 19 CHUG, which is Checworks Users Group -- meetings. They're l 20 trying to do their part to communicate anything they've l
l 21 found, so they might be a good resource for that, i 22 MR. CHAMBERLAIN: I think what Jeff's talking 23 about, it was like the Hire-Linebrink [ phonetic] analysis.
24 You know, they didn't assume breaks in these kind of g3
( ,) 25 lines, so that was beyond that kind of analysis.
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122 1 MEMBER KRESS: But structural mechanic types, s 2 like you said, this would probably be duck soup to
(/)
s~
3 predict. Flaws don't enter into this. This was just a
\
4 structural failure.
l 5 MEMBER SHACK: I can predict anything. The l 6 question is whether it will -- Checworks predicts stuff, 7 too. Predictions are cheap. -
l 8 MEMBER KRESS: If you input the pressures and 9 the temperatures and the wall thickness distribution and j l
10 did a finite calculation, that's all you need. You hit in ;
1 11 on the button.
12 MR. SHACKELFORD: Well, Fort Calhoun brought 13 their own panel of experts in there. You may be familiar I
\- 14 with Dr. Chung Chu, failure prevention, and there u;ere 15 some incredible theories espoused early on, and, you know, 16 coining new phrases and everything. And none of them, I 17 think, in the end were proven. I mean, this - and the 18 bottom line was this was a 20-year-old pipe that had never l
19 been inspected. You know, that's getting down to what l
20 happened. That's where we at least --
l 21 CHAIRMAN BARTON: So much for Chung Chu's QV&P i
l 22 program.
23 MR. SHACKELFORD: He coined the phrase, the 24 amplified V vortex.
r~g kj 25 CHAIRMAN BARTON: He always comes up with new NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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123 1 phrases.
7- 2 MEMBER SHACK: Well, I mean, there are two
/ \
i
'- 3 problems here. One we're sort of predicting why it 4 occurred; the other one is -- if I knew it was .05 and 2 5 feet long and 3 inches wide, I could do it.
6 But the ASME code gives you simplified ways to 7 do that, and the question is, how well the simplified -- l 8 you know, especially with -- I assume the reason the .02 9 didn't go is it's a rather different geometry and 1
10 presumably is somewhat more localized. )
11 It would just be interesting to know whether l
12 the code case sorted them out right. l 13 MR. SHACKELFORD: Well, one thing of I
/3
(_,) 14 interest -- and I don't know if it's very clear in the 15 report; I hope it was. But the second stage extraction 1
16 line runs parallel to the fourth stage. The geometries 17 are almost identical, the run of the pipe and where they 18 go. The second stage showed no significant degradation, 19 and, you know, obviously there's some geometry 20 differences, but the piping material and the ventage are 21 all the same.
22 But what is significantly different is the 23 conditions inside the pipe. The second stage is a much 24 higher quality, higher temperature steam than the fourth f%
( ) 25 stage.
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124 1 1
1 So for what it's worth, you know, that was
,- 2 also a finding.
! )
\
'~' /
3 MEMBER SEALE: What's the over -- is there a 4 significance in the overall mass flow rate, not just for l
5 water content, but the overall mass flow rate? l l
6 MR. SHACKELFORD: I don't think it was a 7 significant difference. Checworks, as you say, should 8 take that into account, and part of the -- getting back to 9 what happened here, there was some modeling deficiencies, i 1
10 I believe, that contributed to the checworks -- you know, 11 the failure to identify it.
12 Even the modeling deficiencies 13 notwithstanding, the evaluation of the day-to-day -- even
(._ l 14 if you were modeling it poorly, once you start evaluating 15 your data, you ought to be -- that ought to generate 16 questions for you. You know, you'd say, Well, it's not 17 predicting well, so I shouldn't trust it. I don't know 18 why I shouldn't, but I shouldn't. And those kind of 19 issues are what we brought out in the report.
20 CHAIRMAN BARTON: I think we need to move on.
21 I think we've solved Checworks --
22 MR. SHACKELFORD: Okay. The next page really 23 just kind of -- we'll skip over that one for now, and 24 we'll skip the next two pages then, because we talked (o) 25 about root causes and contributing causes.
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l 125 l 1 The event follow-up activities: This is what 1
,_s 2 the NRC has done, and this is what the licensee has done.
/ \ I
\ l 3 And I have this meeting listed as one of the things we l l
4 have done. I mean, we've attempted to communicate what 1
5 happened at Fort Calhoun in order to let other people know 6 and to take what lessons they can learn from it. And I l
7 think that that's -- this might be a good example of j 1
8 hopefully closure of an issue.
9 I mean, something happened that was 10 unfortunate, but we inspected it, issued our report. We j 11 had a public meeting where Ellis came down and presented l 12 his views on the event to the licensee in no uncertain l 13 terms. This event has been briefed on the events
,a s
l (._ /
14 briefings that NRR conducts.
15 We've had several other meetings, a 16 maintenance rule workshop meeting, our own resident 1
17 inspector meeting, and I've been in contact with some of 1
18 your staff throughout this as well.
19 We're working on an information notice that we 20 hope will help to bring more of these issues to light, and l
21 then obviously we'll be conducting inspections, follow-up i
22 activities, to look at the long-term corrective actions.
23 The licensee has also done a lot. As I said, 24 they convinced me that they didn't want this to happen and s
(J h 25 they feel lucky that no one was hurt. They've done quite NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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126 1 a bit of self-assessment and communication to the
,3 2 industry.
)
'~'
3 In the last slide, I really won't talk about 4 it much --
5 MR. MERSCHOFF: Jeff, there's one error on 6 that slide. The public enforcement conference is really 7 7/21, not 6/21.
8 MR. SHACKELFORD: Okay. Yes. I'm sorry about 9 that. We have a public enforcement conference this coming 10 Monday.
11 MEMBER KRESS: What is a public enforcement 12 conference?
13 MR. SHACKELFORD: I guess the correct term is (3
k.s 14 predecisional enforcement conference. They come in, and w
15 we'll discuss the issue and what we -- go ahead.
16 MR. DYER: This gives them the opportunity to 17 present their side of the story. We've gone out, l
18 conducted our inspection. We held our internal panel and l 19 in our view, between us and the Office of Enforcement and l
l l 20 NRR, concluded that this has the potential to be -- reach l
i l
21 escalated enforcement.
22 As a result of that, then we -- I can't l
23 remember if we issued them a choice letter or what. We 24 decided to call them in for an enforcement conference, a (n,) 25 predecisional enforcement conference, before we make up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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127 1 our decision, before we make our decision on the I
fx 2 enforcement, and they can present their -- they can
,N]
3 either, you know, deny the violation, show what they've 4 done to mitigate it, or present their side of the story.
5 MEMBER SHACK: Part of due process.
6 MEMBER KRESS: Have you had these before?
7 MR. DYER: Yes. Essentially all our 8 predecisional enforcement conferences --
9 MEMBER KRESS: Do you expect -- who shows up 10 to these?
11 MR. DYER: A lot of times it's co-owners of 12 the facilities. Sometimes the states may. It really 13 depends on the nature of the issue.
k-- 14 MR. DYER: Intervenors show up?
15 MR. DYER: I don't believe we've ever had any 16 intervenors. Never in this Region.
17 MR. MERSCHOFF: In Region II occasionally 18 intervenors would show up. This was a new initiative that 19 the Agency took a couple of years ago, maybe three years 20 ago, to open the predecisional enforcement conference to 21 public observation, not participation, in order to be more 22 visible.
l l
23 After a trial period that ended recently, the 24 Agency elected to continue this indefinitely, with the O
( ,) 25 exception of certain issues that involve individuals where i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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128 1 privacy might be involved or safeguard of information, but
,. 2 the vast majority, absent a good reason why not, of those i
i
3 enforcement meetings would be open to public observation.
4 CHAIRMAN BARTON: There goes that DSI again 5 about getting the public more involved in a process that 6 we took exception to, said, no, no. You get, Yes,.yes.
7 MR. SHACKELFORD: That's all I really had on 8 the event. The last slide is just sort of a reference of 9 different erosion / corrosion events that have occurred and 10 the documentation of them.
11 CHAIRMAN BARTON: Are we ready to move on to 12 the next topic?
13 MR. GWYNN: I was asked to talk about the g
(_,/ 14 Region IV interface with INPO. I wanted to just 15 acknowledge up front that our -- the Agency's interface 16 with INPO is dictated by a publicly available memorandum 17 of understanding. The principal point of contact under 18 that memorandum of understanding is through the EDO's 19 office, and so the first point that I h. ave is that there 20 is no direct interaction between Region IV and the 21 Institute for Nuclear Power Operations.
22 However, there are a number of indirect 23 interactions, and they typically occur through the 24 headquarters office. For example, we receive copies of
/%
25 INPO's schedule, the schedule that they have for plant (N_s)
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129 1 evaluations and for those other activities, outage assist
,._. 2 visits, maintenance assist visits, training accreditation 3 visits. We get their schedule.
4 And so with their schedule, we're able to use 5 that when we schedule our inspections, and under the 6 agreement, we avoid scheduling our activities at the site 7 at the same time that INPO's at the site. If, in fact, 8 there are conflicts -- for instance, we may have an 9 inspection that's been scheduled for some time, and INPO 10 overlays one of its activities on top of our inspection --
11 then when those conflicts come up, we interact with the 12 office of the executive director for operations, and that 13 conflict is resolved at that level.
,g i
i j) m 14 Another way that we have an indirect 15 interaction with the Institute is through our resident 16 inspector monitoring of third-party assessment results at ;
1 17 the plants. Now, under the agreement, INPO is required to 18 bring significant safety findings to the attention of the i
19 Agency, and that's done at a high level.
20 If, in fact, in our routine inspections at the 21 plant our inspectors are required to review third-party 22 assessment results and to evaluate those results to make 23 sure that we have an understanding of them and that our 24 assessment of the results is consistent with INPO's, that (n)
%.J 25 there are no significant safety findings there; to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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130 l l
1 extent that there are significant findings in our view, 2 then those are communicated to the regional office, and if
' 7s i j s !
3 there are questions about those findings, well, those 4 would be coordinated through the headquarters office j 5 again.
6 The final point that I wanted to make here is 7 that from time to time, regional managers ale requested to l
8 observe the meetings of the National Academy for Nuclear )
1 9 Training Accreditation Board. That's a part of the l 10 Agency's interaction with the National Academy for 11 overview of training activities at the site.
12 INPO is a presenter to those National Academy 13 Loard meetings where the board makes its decision about
! 1
(,_/ 14 accreditation and re-accreditation of licensee training 15 programs, and we provide feedback to the program office 16 through the headquarters operator licensing branch, in 17 order to make sure that the Agency maintains a view as to 18 the validity and value of the accrediting board 19 activities.
20 And so those are the specific items that I 21 wanted to bring to your attention today, and I'd be 22 pleased to answer any questions.
23 MEMBER SEALE: Well, I think one of the l
l 24 reasons this issue came up is that there are certain
( ) 25 things that INPO does and certain things that the NEAL R. GROS $
COURT REPORTERS AND TRANS31BERS 1323 RHODE ISLAND AVE.. N W.
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131 1 Commission does, particularly, for example, in event
,3 2 analysis, where the perspective is such slightly
()'
3 different; the objective is quite consistent, commonly 4 shared, commonly held.
5 And I think there's been an increased 6 interaction between INPO and AEOD in those kinds of 7 results. And the question really arose was: Are there 8 INPO activities that you would like or you could use more 9 access to? Are there things you do that might be -- well, 10 there are certain things that you observed no doubt which 11 may not be directly in your turf, but INPO sticks its nose 12 in places where no one else does. And it might be 13 sometimes a cue would be a useful thing to sensitize those
,9
\-- 14 people to an issue really.
15 So really the question is: Is there a 16 profitable, enhanced interactions that are possible?
17 MR. GWYNN: Well, I know that through the 18 memorandum of understanding and our interactions with the 19 Institute from time to time -- for example, the chairman 20 or other commissioners talk directly with --
21 MEMBER SEALE: It's generally at that level.
22 MR. GWYNN: Yes. And so those types of 23 activities do go on. I know that there are interactions 24 between the headquarters office and INPO concerning
!3
() _
25 generic communications to avoid duplication of effort.
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l 132 l 1 But from time to time, because of the circumstances that
,3
, 2 you described about differences of perspective on issues, l t i
~
3 we go ahead with generic communications that may duplicate 4 some aspect of theirs.
1 5 So that's about all that I can say on that l 6 subject. l 7 MR. CHAMBERLAIN: I want to introduce Chris 8 VanDenburgh. He's our engineering branch chief, and he's l
9 going to be talking about fire protection, but 10 specifically the ANO fire and our follow-up to that. That 11 was a joint effort between DRP and DRS, and the follow-12 up -- the residents were kind of the first responders to 13 that, and then one of Chris's inspectors later on was
(_) 14 involved, so I think Chris kind of oversaw the whole 15 effort.
16 So, Chris.
l l
17 MR. VanDENBURGH: Thank you. Good morning.
l 18 This inspection occurred in October and '
19 November of '96. Phillip Qualls -- you probably remember 20 Phil. He was my fire protection engineer. Unfortunately 21 he's transferred to NRR. And Jim Melfi was the resident 22 inspector at ANO. He first came across this problem.
23 This was an interesting aspect to us, because 24 it was the first case we've seen recently involving (m) 25 wicking effect of lube oil leakage on fibrous insulation, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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133 1 and it caught the licensee by surprise, as you'll see as I
,_s 2 go through some of the sequence of events.
I i
\2 3 And it has highlighted to this region a 4 generic issue with lube oil systems and a lack of 5 understanding of many licensees concerning the collection 6 requirements of Appendix R. And since that time, we've 7 had issues at Fort Calhoun, at Diablo Canyon, at Songs, 8 and to a certain extent at Palo Verde.
9 In almost each case, the systems to collect 10 this lube oil leakage have not been maintained or 11 installed appropriately, and in some cases, specifically 12 the NO, modifications have been made to the reactor 13 coolant pumps, such that the collection system was not gs i \
(_/ 14 considered and didn't collect -- adequately collect the 15 lube oil leakage.
16 We issued the inspection report in February 17 '97, and we were concerned about the implementation of 18 their fire program. More specifically, the event showed 19 us a problem with the modification performed on Unit 1, 20 which replaced pump B and failed to install the adequate 21 collection system. Specifically they had not reviewed the 22 design change.
23 MR. SINGH: Do we have slides for this?
24 MR. VanDENBURGH: I'm sorry. No.
/~N ,
25 MR. SINGH: That's okay. Fine. l i\_-)
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134 1 MR. VanDENBURGH: Actually all we have is the
,, 2 inspection report. There are no figures or anything of
(' ' ')
3 interest that I could readily --
4 MR. SINGH: What's the number?
5 MR. VanDENBURGH: The inspection report dated 6 February 3, '97, was 96-27. On the docket on the NO, it's
(
7 53-13-368. There's also associated an enforcement action 8 number wich that.
9 As I was saying, they had modified the system 10 ;and didn't perform an adequate fire protection review, in 11 part because the design engineer who summarized the 12 modification did not adequately and fully describe the 13 modification. So when fire protection looked at this n
G) 14 short description in the mod, they saw no need to perform 15 any further detailed fire protection review, which would 16 have -- and the error, in our view -- identified the lack 17 of collection systems for this external lift oil pump that 18 was added.
19 MR. GWYNN: The modification was the 20 replacement of the reactor coolant pump motor with a motor 21 of different design.
22 MR. VanDENBURGH: Correct. The old motor had 23 a shroud that encompassed all the high-pressure piping.
24 The new pump did not, this level of detail was inadequate
,a 25 for fire protection to identify the fact that some high-()
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1 135 1 pressure piping was exterior to the shroud.
i I
,s
\
2 MR. GWYNN: Now, I think it's important to i
/
\'~') 3 note that this high-pressure lift oil pump only operates I 4 at two key points in the operation of the reactor coolant i l
5 pump. One is when you start it, and the other is when you 6 shut it down. And the lift oil pump is supposed to l 7 prevent excessive wear on the thrust bearing as the motor l 8 starts and stops.
9 MR. VanDENBURGH: Right. Basically a quick i 1
10 synopsis of the events of October 17: In the afternoon, l
11 they were heating up the hot stand-by after an outage, and 12 they noticed the fire on the steam generator B and the 13 reactor coolant pump B that's in the reactor coolant pump l
's) 14 enclosure.
15 They sent two fire brigade operators out at 16 the time to respond to the fire and declared it an unusual 17 event, because it was lasting longer than ten minutes. l l
18 And our inspectors observed some of the actions during 19 this unusual event.
20 After they got rid of all the smoke out of the 21 reactor building and cooled down, we walked down various 1
22 areas and inspected the reactor coolant pumps. We noticed 23 an oil film on the side of the steam generator B and on i
24 the side of the reactor coolant pump.
n
() 25 They later determined that the fire was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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136 1 caused, as I mentioned, by oil in the insulation, had s 2 accumulated in the insulation due to previous leak in this I l 3 piping, basically during a preventive maintenance pump run 4 of the high-pressure lube oil pump. They had noted a 5 cracked weld on the discharge line, the maintenance 6 technician did, so therefore he initiated a maintenance 7 work order to repair that cracked line, but failed to 8 recognize that there was oil soaked lagging in insulation.
9 It wasn't immediately obvious that the oil had 10 penetrated into the insulation. He had noticed the oil 11 leakage, because it actually sprayed upon him. He had a 12 little bit on his coveralls, so he cleaned that up, 13 cleaned up the general area, and issued the work request.
g
\ s': 14 They rewelded the cracked weld.
15 They later determined that the crack had 16 actually occurred prior to his maintenance run and his 17 activity, such that during the previous shutdown from the 18 outage, when the lift oil pump had been run. As the pump 19 was being secured is when they postulate that we lost the 20 lube oil, and it sprayed upon -- in the general area and 21 soaked into the lagging. And it wasn't immediately 22 obvious.
23 They had actually operated that pump for an 24 extended period of time when the reactor coolant system
,-~3 i
s ) 25 was relatively cool, as they shut down, around 250 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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137 1 degrees. That's why it didn't flash to fire due to the j l
l 2 wicking effect at that point in time.
( ~'-) l 3 And as Pat said, they normally only run these 4 high-pressure lube oil pumps during start-up or shutdown. i 5 They figured that a total of only seven gallons sprayed 6 out of the lube oil pump during that period of operation. l 7 It wasn't very -- a large quantity, and they have l 8 determined this from a difference in cil both prior to the 9 trip and afterwards. This was a forced outage due a 1
10 reactor trip.
11 And as I mentioned, they had not identified 12 any excessive oil visually obvious on the lagging. The 1
13 reactor coolant pump lube oil has a flash point of l
'/
~ 14 approximately 400 degrees and an auto ignition point of 15 approximately 700 degrees. So although the normal metal 16 temperature on the B generator at the time of the fire was 17 approximately 430, they concluded that it had to be due to 18 this wicking effect of the insulation. l 19 As you're probably well aware of, it increased 20 the surface area; the oil allowed for a decrease in the 21 flash point.
22 Their response, the actual response to the 23 unusual event, the fire, was quite good. We had a couple 24 of concerns concerning some personnel safety aspects which (m) 25 is probably really unrelated to this discussion. It had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE,, N W.
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138 1 to do with climbing up a ladder with a fire extinguisher 2 and the danger that that poses in terms of dropping it on t,,_s\
\ )
3 people below or just dropping it and knocking the nozzle 4 off. They hadn't considered the fact that they .-fould have 5 to fight a fire in that area.
6 One of the major concerns that drew us to an 7 enforcement conference and it resulted in an escalated i
8 action here, unlike some of the other lube oil collection '
I 9 problems we've seen, is the repeated opportunities for 10 this licensee to have identified this problem and fixed it !
1 11 earlier.
12 For example, a condition report, quality 13 assurance document, had not been initiated at the time
( s, ) 14 they found the lube oil leak during maintenance. We )
15 believe if they had done that in conjunction with some 16 other hindsight, they might have been able to recognize or 17 at least postulate when the leak had occurred or have 18 questioned themselves, was the leak present when the pump 19 had been operated earlier.
20 But because of their quality program, as it 21 related to fire protection and it wasn't a fire protection 22 deficiency, they didn't see the need to write a CR. On 23 hindsight, they recognized that as a program weakness.
24 So, therefore, the maintenance technician at r\
25 the time he identified the leak didn't write a CR, so (x_-)
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139 1 really nobody got an overview of the problem and could
-s 2 link it with other issues, other issues being radiation
/ T
\ )
3 techs -- health physics techs, that is, in the general 4 area had noticed oil drip and accumulation on the floor 5 underneath the reactor coolant pump on numerous occasions 6 and had actually cleaned it up two or three times, but 7 didn't bother to tell anybody, because they didn't see it 8 as anything more than a housekeeping issue.
9 In addition, a senior supervisor, an 10 electrical technician, in containment at the time of heat-11 up -- this was after the pump had been fixed -- noted in 12 their opinion excessive haze and smoke in containment, and 13 in fact, the electrical technician concluded that there 7
)
x_/ 14 was oil-soaked lagging that was causing this problem in 15 this general area.
16 They did the appropriate thing in one aspect.
17 They informed the outage control desk where they were 18 controlling these -- the activities of the forced outage.
19 They did not, unfortunately, write a condition report 20 which if reviewed in a timely manner could have been tied 21 to the other condition reports which, of course, had not 22 been reviewed or had not been initiated.
23 The outage desk talked to the fire protection 24 people, but only asked what the auto ignition temperature
()
(~
25 was of oil. Finding a temperature 700 degrees, much above NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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140 l l
1 RCS -- anticipated RCS temperature, they didn't see the l
,-s 2 need to be concerned about a fire.
'~
3 And, of course, they were unaware of a wicking
, 4 effect and didn't indicate to anybody that there was oil-5 soaked lagging, and it only affects oil-soaked fibrous 6 insulation.
7 So these combination of events, we believe, if l
8 a good quality program had been implemented and if they 9 .aad -- would have increased at least the opportunity for 10 them to recognize this problem.
11 Therefore, we considered this to be a more 1
12 significant regulatory issue, and we brought those folks 13 in for a conference and took action. But the issue itself 7
- 1 i N' 14 centers upon the unrecognized phenomena by the operators 15 and the people at the outage control desk of the wicking 1
16 effect, lowering the auto ignition temperature of the lube 17 oil.
18 And it is difficult to note oil-soaked l l
19 lagging, especially when they're encapsulated with the i 20 various reflective metal sheeting.
21 MR. GWYNN: There was an historical aspect 22 that was also important to me on this event where the 23 start-up of Unit 1 from its previous refueling outage, 24 they had had turbine lube oil spilled on lagging on the )
,m
( ,) 25 Unit 1 high-pressure turbine, and as the plant came up to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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141 1 rated power, temperatures on that turbine increased, and 7\ 2 they had a fire on the turbine.
3 And so they realized after that that they 4 needed better controls on the clean-up of oil spills that 5 occurred during refueling outages, and so this was a 6 precursor that they had had that they really didn't pay 7 attention to, because the problem had been inside 8 containment on a turbine.
9 MR. VanDENBURGH: In fact, they had considered 10 it, but they had isolated the concern to paper-backed 11 insulation, as opposed to fibrous insulation. There's 12 really no effective difference when you're talking about 13 this phenomenon, but their training from the root cause of k- / 14 the turbine was to worry about paper-backed. And when 15 they asked, there was no paper-backed in this area, so it 16 was not a problem.
17 CHAIRMAN BARTON: Also let me ask you: What's 18 the threshold of reporting deficiencies on a deficiency 19 report so you can be evaluated by appropriate people?
20 MR. VanDENBURGH: Well, that was one of the 21 main topics of this enforcement conference, and our 22 opinion was that this hazard was a commission adverse to 23 quality, in that not necessarily from the perspective of 24 the fire program, but its effect on other operable ta
, ( ,) 25 equipment.
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r 1323 RHODE ISLAND AVE., N W.
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142 1 And once put in that light, they recognized l f3 2 that they had a hole in their quality program that didn't
( )
l 3 ask for initiation of CRs. They actually had --
4 CHAIRMAN BARTON: What's their CR?
5 MR. VanDENBURGH: Condition report.
6 CHAIRMAN BARTON: It's like a deficiency 7 report?
8 MR. VanDENBURGH: A deficiency report. It's 9 the first level quality assurance document for 10 documentation. They had a rather elaborate system of 11 designating services, Q being safety-related, F being fire 12 protection-related to halon suppression, fire dampers, 13 fire suppression, fire detection. l
\~/ 14 And since this lube oil leakage didn't affect 15 those fire systems and it wasn't safety-related, they l 16 didn't have to initiate a CR.
17 CHAIRMAN BARTON: Something wrong with the 18 program. It's a basic deficiency that's -- you know, 19 should -- well -- i l
20 MEMBER KRESS: How did they know what was 21 burning? When they looked at the smoke?
22 MR. VanDENBURGH: Well, they actually saw 23 flames when the fire broke out.
)
24 MEMBER KRESS: Okay. But there was no
(~%
( ,) 25 instrumentation that detected a fire. Is that what I just l
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.I
i 143 1
1 heard?
,s 2 MR. VanDENBURGH: I don't recall a fire alarm i I
'~'
3 being received.
I 4 MEMBER KRESS: That s interesting.
5 MR. VanDENBURGH: There are fire detections --
6 MR. DYER: I think there are fire detection 1 7 capabilities -- I don't know what type -- in that 8 enclosure, but it would take a much larger fire to actuate 9 that --
10 MEMBER KRESS: You said it burned more than 11 ten minutes?
12 MR. VanDENBURGH: That's why they declared an l
1 13 unusual event. It was about 12 minutes. It was only
- a
(/ _ 14 about six inches tall and burned around the ring -- the l
15 feedwater ring on the steam generator. There's really no 16 safety-related equipment, and there was no collateral 17 damage other than some --
18 MEMBER SEALE: Must have made a lot of smoke.
19 MR. VanDENBURGH: A lot of smoke. Prior to f
20 the fire, actual flames, there was a lot of smoke. That's l 1
21 what alerted the electrical supervisor. His experience 22 was there should not be this much smoke. That's why he )
I 23 reported out, which is what you would expect him to do. !
l 24 That's a brief summary. I tried to keep us on
,/
(xj 25 time.
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144 1
The comment about damage 1 MEMBER SEALE:
.s 2 from -- subsequent damage from the smoke is -- that was
/
l
( )
l i
3 made earlier is also relevant here and something you might l l
4 want to be looking for.
5 MR. CHAMBERLAIN: On the long-term damage to 6 equipment that may have experienced the smoke. We talked l l
7 about that. l l
8 CHAIRMAN BARTON: Staff training and l l
l 9 development? Did we already cover that? It looks like 10 lunch break.
11 (Whereupon, at 11:45 a.m., the meeting was 12 adjourned, to reconvene at 12:30 p.m. this same day, 1 13 Friday, July 18, 1997.) l x_.) 14 15 16 17 18 19 20 21 22 23 24
('N t ) 25 Gs NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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145 1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N I
,q 2 (12:30 p.m.)
l )
'~#
3 CHAIRMAN BARTON: We're back in session. I'll 4 turn the meeting over to Dwight to introduce the next 5 presenter. j 6 MR. CHAMBERLAIN: Okay. I want to introduce i
7 Bill Jones. He's our other senior reactor analyst, along l 8 with Jeff Shackelford, and he's going to be talking about l 1
9 how we're envisioning using the SRA program here in the 10 Region. We have a policy guide still in draft, that's 11 being issued, so he's going to go through that with you, 12 and hopefully answer any questions you have in this area.
13 Thank you, Go ahead, Bill. i
./"N '
(_-) 14 MR. JONES: Thank you. l 15 My name is Bill Jones. As Mr. Chamberlain 16 indicated, I'm one of the two senior reactor analysts.
17 The other one provided a presentation this morning, Mr.
18 Jeff Shackelford.
19 There are two senior reactor analysts assigned 20 to Region IV. We are in the division of reactor safety 21 and report directly to the director and deputy director s
22 for division of reactor safety.
i 23 Mr. Shackelford and myself have both completed 24 the training program and rotational assignments for SRA
! ) 25 certification, and that process should be completed before NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLA"D AVE., N W.
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146 1 too much longer.
,_s 2 The SRAs have been involved in the
( )
3 dissemination and development of PRA resources in the 4 region. One element that is in process is a training ;
l 5 program under development by NRR to be provided to our j l
6 resident inspectors and some of the regional-based people, 1 7 about a two- to three-week training program to provide for 1
8 more in-depth PRA understanding.
9 In addition to that, the SRAs, we've been l 10 involved in the development and review of new Reg 1560 and ;
i 11 presentation of that material, particularly while we were l 12 involved in the office of research.
13 We're also involved in providing overviews of ;
(~h l
_ 14 several licensee IPEs to the resident and regional l l
15 inspectors. That is an area that we are continuing with.
16 However, we are looking at licensee PRAs now because of 17 the status of many of the IPEs not currently reflecting l
18 the facilities as they exist today. l 19 In that regard, we are implementing a PRA 20 library. This is a significant effort, because it is 21 designed to bring the regional capabilities up to the j 22 understanding of what the licensees, PRAs, and PSAs really l
l 23 tell us. )
24 We are currently looking at obtaining system
,m (tj ) 25 notebooks for the PRAs and PSAs. As I indicated, we do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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147 1 have the IPEs, the IPEEEs, the technical and staff
, ~s 2 evaluation reports. Those reflect, in many cases, two, i \
\)
3 three years ago and not necessarily the current plan or 4 current risk.
5 We're also involved in the risk-informed pilot 1
6 programs. In particular, we will be involved when they !
i 7 are approved and all licensees begin to implement those l 8 for many risk-based issues associated with those, graded 9 QA, IST, ISI that we'll be involved with. j 10 And those are the areas that we're gathering 11 information in our library and other risk background 12 information, human reliability analysis, and so forth.
13 We're involved in many performance-based risk I i
'is/ 14 assessments. This is an area that our management 15 emphasized when we first arrived back in the regions. It 16 was going to be our responsibility; that was clear to us.
17 These involve areas such as the notice of enforcement 18 discretion, enforcement severity evaluation, inspection 19 finding evaluations, event evaluations.
20 I'll go through each of those briefly. In the 21 area of notice of enforcement discretion, an SRA will be 22 made available for assessing licensee risk arguments and 23 coming forth with notification of enforcement discretions, 24 NOEDs. That has been mandated from the regional p
25 administrator himself, and we understand --
(J 1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 148 1 MEMBER SEALE: Is this unique to Region IV?
l
,s 2 MR. JONES: Region II does that also, that I
\
3 know of.
4 MEMBER SEALE: Thank you. ,
i 1
5 MR. JONES: Uh-huh. Enforcement severity 6 evaluations: LOE recently issued an EGM 97-11 which 7 mandates the SRA involvement in review and severdty 8 levels. That was actually in place in this region prior 9 to this EGM being put in place.
10 The SRAs review each potentially escalated 11 action. Some of them do not lend themselves well to risk j 12 assessment, but those that do, we're involved in the l 1
13 Region IV panels, either directly or through a memo
/~'s l v.- 14 describing our risk insights into that, or directly with i
1 15 predecisional conferences, and in review of licensee 16 responses to these violations.
)
I 17 In each of those cases, we have performed I
18 these activities. Like I say, we're new to this, but we l 19 have in each of those three that are -- or those two areas 20 I described, we have been involved there to date.
21 Other areas, inspection finding significant 22 evaluations: This is one where we have an ongoing effort 23 to get our -- for the resident inspectors and the regional l
24 inspectors to understand what our capabilities are as l
! (~N l
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( 149 l
l 1 far as questioning, What is tha risk of an event or an l
2 inspection finding.
r7._s\
3 These are -- we're starting to see more of 4 these, and we also receive input during our daily events 5 briefing or pipe meetings, pipe status meetings, as to 6 events that we will be involved in reviewing. We are --
7 have the capability of providing short-term turnaround on 8 the risk insights or areas where we may need to provide 9 additional inspection effort.
10 MEMBER KRESS: When you're talking about a 11 risk, are you talking about core damage, for instance?
12 MR. JONES: In the big picture, yes. But what 13 we look at is qualitative type insights that we may get.
f~'s I
(_,) 14 We have the capability in our training program and the 15 software and hardware to perform qualitative type risk 16 assessments. We have limited models at this time. We use 17 the ASP models, so we have the capability to actually go 18 in and develop fault trees or whatever, to actually come 19 up with a quantitative type insight.
20 The way we -- on a short-term turnaround type 21 items, we really provide the qualitative type review --
22 MEMBER KRESS: Because you don't have time.
23 MR. JONES: Right. That's really the purpose
, 24 of the SRA. The long-term accident or event importance t
[\ i 25 review, those are done by headquarters and by the national t
x_/
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l 150 j
1 labs involved in more extensive models than we have time l
l
,s 2 to look at. But we have the capability to provide within !
/ s 3 a day or two, short-term turnaround, risk insights into i 4 those type of issues, anything from equipment, human )
l 5 actions that may be important, any way they may need to go l
l 6 with that, and whether or not an event is really important !
l l
7 or not. l l
8 And like I say, those are mostly qualitative 9 type reviews. Matter of fact, those -- Jeff and I are 10 somewhat reluctant to provide quantitative reviews, 11 particularly with tne uncertainties involved in the models 12 that we have.
13 MEMBER KRESS: That was going to be my next r\
4 C/ 14 question.
15 MR. JONES: That's why I stress qualitative 16 type review. We're looking for orders of magnitude 17 changes and things of that nature.
18 CHAIRMAN BARTON: Your reputation precedes 19 you, Tom.
20 MR. JONES: I've also attended several ACRS 21 meetings when I was on rotation.
22 In addition to inspecting findings which we're 23 now getting input back, the events evaluations which we 24 find out about during our daily briefings on plant status,
( ) 25 we also sit in on the events briefings provided by generic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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151 1 communication branch, and these are for insights that we 2 can -- or provide for our own plants. )
i,,_ i
\'~ 3 For example, a lot of the level 4 instrumentation problems we've seen lately, Region IV has 5 had some facilities with level instrumentation problems !
l 6 involving reactor water storage pool and things of that )
l 7 nature, and we've seen similar problems with line control I 3 tank instrumentation --
9 These are the kind of things that we're 10 looking for, risk insights to provide to our Region IV 11 plants up front. In addition, we -- I didn't mention l
12 this, but biweekly we have a conference call with all the 13 SRAs. It's coordinated by headquarters, and this is to
- D
(_) 14 review the type of issues that we see coming up, and it's 15 just to keep that open link with the SRAs and headquarters 16 and ourselves.
17 The next item was the maintenance rule 18 equipment configuration evaluations. Mr. Powers is going 19 to talk about the maintenance rule next, but we have the 20 capability to do and we have participated in as the PRA, 21 so-called experts, the maintenance rule inspections in 22 several cases.
23 Development of equipment reliability and 24 availability for system and component performance, and
/
(3y 25 what we're looking for is differences between what was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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152 l
l 1 assessed in the PSA or PRA and understand why those s 2 differences occur, and then to extrapolate that out i \
3 through possible performance issues, as to whether or not 4 the licensee's maintenance program or whatever is causing 5 a difference between what we're seeing in availability or 6 reliability come out.
7 An area that we are tasked with by my 8 management is the outage risk reviews. This is one where 9 we've only done one of so far, but it's to review the 10 licensee outage controls, when they go into potentially 11 significant risk configurations during shutdown. This is 12 an area where qualitative is about the best that we can 13 do.
O
(- / 14 MEMBER POWERS: You don't have in your arsenal 15 much to supplement a general intuition in this area.
16 MR. JONES: On shutdown risk?
17 MEMBER POWERS: That's right.
18 MR. JONES: That is correct.
19 MEM3ER POWERS: Can you give me a feeling of 20 what handicap you feel, not having that, or what -- maybe 21 the other side of the coin, how much better off you would 22 feel if you had more of the support that you have for 23 operational risks available to look at the shutdown 24 configurations.
/~N
( ,) 25 I mean, in the operational area, you have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 153 1 wealth of information, a wealth of examples, done by the 7
-~ 2 NRC. I mean, the first line complete evaluations and
( )
~'
3 understanding of where the uncertainties are, an 4 understanding of where the incompleteness is, and we have 5 some opportunity to calibrate the results of those 6 analytic exercises against real experience. In the 7 shutdown, you just don't have that.
8 How much of a handicap that is, because --
l 9 especially things like just risk achievement worth and l
10 things like that, that even if you don't believe the exact l 11 numbers, at least you've got a number to calibrate your 12 experience with.
13 MR. JONES: Yes. We do have to rely Ch
)
\~./ 14 extensively on what the licensee provides vs. It would be 15 beneficial for us to be able to at least identify which 16 components are significant, particularly the ones that 17 aren't obvious. Fire protection is one of them.
18 MEMBER POWERS: That's right.
19 MR. JONES: That would particularly be 20 important during the shutdown risk, and that based on our 21 experience tells us that that's something that we want to 22 consider. But a shutdown risk model would identify that 23 or at least should identify that.
24 And that is a -- not a deficiency, but an area p
() 25 that we do have to look at is to think through on an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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154 1 operational side what type of equipment is important, why
,_ 2 is it important, and to get into the low-pressure modes of f
'- 3 what type of equipment is brought out as a result of that.
4 That would be an example.
5 We do have some -- we have to rely on the 6 licensee's analysis and try to understand and see that 7 they considered those type of areas.
8 MEMBER POWERS: Licensees, a lot of them now, 9 are using the Oram (phonetic] models. It suffers from 10 being a proprietary capability, I call it, quasi-analytic 11 capability, does not have the kind of peer review and 12 critique that you have. How do you go about looking at 13 Oram analysis?
(~'N
(_j' 14 MR. JONES: The only one I've looked at so far i
15 was Arkansas, so I haven't had an opportunity to get into !
16 that area. So I really can't provide an assessment of 17 what kind of problems we'll see when we get into that.
l 18 What I did for the Arkansas shutdown risk was 1
19 to essentially apply the operational type risk insights 20 and to carry them over into low pressure, what it takes to 21 maintain level and what kind of back-up you --
22 MEMBER POWERS: You kind of go to first I
23 principles --
24 MR. JONES: So to answer your question 25 directly, I don't know what it's -- what problems it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 155 j 1 going to cause.
2 CHAIRMAN BARTON: Does Arkansas use Oram? )
\' ' ' ]
3 MR. GWYNN: Yes, they do.
1 l
4 CHAIRMAN BARTON: They do?
5 MR. GWYNN: Yes, they do.
6 MEMBER KRESS: Would you focus on what it 7 takes to keep the core covered?
8 MR. JONES: It really doesn't speak to as much 9 the -- and, of course, you look at the ability to restore 10 containment integrity. That's an important one that came 11 out after Vogtle was those type of insights, that you see 12 that are incorporated into licensee shutdowns.
13 MEMBER SEALE: And, of course, the
,q
(_) 14 consequences of the containment being open in terms of the 15 availability of certain systems.
16 MR. JONES: When you open it up, you, of 1
17 course, lost any level 2 considerations, as far as '
18 assessment are concerned, so you are relying on the level 19 1, the type of systems that would mitigate core melt and l
20 the ability to establish the containment integrity within '
21 a period before you would end up with -- it would depend 1
22 on the ke and so forth, what evolution you're involved 23 with.
24 MEMBER KRESS: I think that's a good
(~%
(s ) 25 perspective.
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1 35
1 MR. JONES: That -- like I say, this is 2 thinking ahead, not having been involved extensively in
( )
\ ,_j 3 this.
4 In the overview that I did perform was an in-5 office; it was not a site. We try -- we will be getting 6 on-site tasks to perform these reviews. Mr. Shackelford 7 and myself have divided the facilities up in Region IV, 8 and we're going to develop specific cognizance of what i 1
j 9 their risk profiles are and why things are risk important. l l
10 And that's something which they're working to. j 11 I think I've been in place about four months, and I think l
12 Jeff's been in place about two months, maybe two and a '
l 13 half. These are all areas also that we have identified in :
+n 4 t ,) 14 our policy guides, and this policy guide was based on our 15 management's expectations and what we will be doing.
16 MEMBER KRESS: Do you think a shutdown rule 17 would help you right now?
18 MR. JONES: I know chere's a Commission 19 meeting coming up on us shortly. I plan on lie *ening to 20 that, so maybe I'll find out then.
21 CHAIRMAN BARTON: Okay. Any questions? That 22 trip is on our Sept ember meeting. Right?
23 MR. JONES: The next slide is inspection 24 planning and implementation. This is also a performance-rm 25 For example, we will ba involved with helping
) based area.
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157 1 to select systems for AE, the upcoming AE inspection.
7s 2 That is a large NRC resource, specific to looking at I )
3 systems and their design capabilities. And PSA, PRA 4 provides unique insights to which systems we may want to 5 look at.
6 As I mentioned earlier, we get to the point 7 where we're looking at the inspection programs for graded 8 QAs, our in-service inspection and in-service testing.
9 This region has several licensees that are involved in 10 these pilot programs: South Texas, Palo Verde, Comanche 11 Peak, ANO, and so we'll have up-front and probably lead 12 the way in looking at risk associated with these type of 13 activities and helping to develop the inspection process p
s- 14 from that.
15 The last one is operator licensing, and this 16 gets to the type of operator actions that are important 17 and understanding why they're important. And this goes 18 back to our library also, of understanding why certain l l
19 operator actions are included.
20 What we've seen in many of the PRA and PSA l l
4 21 updates from the IPEs is that actions that were important !
i 22 no longer are, or systems or components, their walls have j i
23 dropped off considerably. A lot of cases, that is due to l i
24 operator actions. This is an area that can be fed back C'\
} !( ) 25 into the operator licensing process for their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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158 l 1 consideration.
, -.s 2 That's what I had for what we're doing in the
. , 1 i /
3 Region. As I mentioned, many of these areas, outage risk 4 review and so forth, we have a long way to go on them. We 5 received the management support we need to go down those 6 avenues, and the expectation is there for us to look at 7 those.
8 Like I say, the Arkansas outage risk review 9 was more of an in-office review. Those areas will expand 10 out to get to the sites and really provide some meaningful 11 insights into these type of activities. We have a lot of 12 different activities on our plate right now, and we're 13 working through them.
,Q K- 14 MR. CHAMBERLAIN: I hope you get the view that 15 I have. I think we've got a lot of capability in our two 16 SRAs. If we can just keep that moving, keep that emphasis 17 going, I think we can really do a lot with it.
18 I guess Dr. Powers needs no introduction. Dr.
19 Dale's our maintenance branch chief, and he's been 20 responsible for all of our maintenance for baseline 21 protections, and I think that's his topic area, or at 22 least the risk of on-line maintenance portion of the 23 maintenance review.
l 24 DR. POWERS: I guess in this region, we've 7
) 25 found that our licensees have typical reasons for doing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
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l 159 1 on-line maintenance that we've seen elsewhere. But since
,_s 2 the development of the maintenance rule, we've seen more I' i
3 focus come on balancing availability und reliability, 4 clearly a benefit of the maintenance rule.
5 Our licensees are certainly interested in 4
6 extending structures and systems and component life by 7 balancing preventive maintenance against corrective 8 maintenance. In some situations, we've seen arguments I 9 where the risk associated with removing an SSC from 10 service during power operation may actually be less than 11 during an outage.
12 MEMBER KRESS: How do you judge those l 13 arguments as to whether they have any validity to them?
(m / 14 DR. POWERS: The validity to those?
15 MEMBER KRESS: Yes. How do you judge that?
l 16 DR. POWERS: I don't believe the Agency has 17 done a formal review on any one of those. We came close 18 to it with the Fort Calhoun application. They were going 19 to take down a diesel during winter months, to do a full 20 18-month tear-down, and we came close to reviewing that, 21 but it never happened. The utility at the last decided 22 not to.
23 We've seen amongst our Entergy facilities, 24 with declining resources, more of an interest in (n) mi 25 balancing -- not balancing, but in being efficient in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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160 1 utilizing their own staff resources, resource-sharing
,_ 2 amongst the plants, an effort to try to cut the workforce,
\ )
~'
3 so that they're not going into outages with just hundreds 4 and hundreds of staff to watch over, and along with that 5 comes less reliance on contractors. And, of course, 6 everybody shares economic benefits from shortened outages.
7 In regard to risk assessment tools, we need 8 these tools, because many of the regulations were l
9 developed at times when the industry's philosophy was to 10 do major maintenance during long outages, and now that i
11 that's evolved, we have plant -- I would call it plant l 1
i 12 baseline risk envelopes that are times of no major !
l l
13 maintenance that now have spikes associated with SSCs j
("N ,
(.. 14 being taken out for service.
l 15 And so we need to monitor those spikes to )
16 ensure that the risks remain acceptable. Our utilities 17 are using basically four different tools to assess risk.
18 MR. LARKINS: May I ask you a question?
l 19 DR. POWERS: Yes, sir.
20 MR. LARKINS: What's your criteria to say 21 this? Do you have a criteria to say whether those are 22 acceptable? You were talking about spikes in the risk.
23 Above what level would you say this is --
24 DR. POWERS: I think that's always a judgment p)
(~J 25 call. We don't have requirement --
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161 l
l l 1 MR. LARKINS: You don't have a requirement of I
,s
, 2 the curve requirement.
/ T s
3 DR. POWERS: No. There's no requirement for l 1
4 that. I think our expectation is 10-*, but, you know, I l l
5 think we would argue on some cases if we thought risk was i
6 too high for the benefits to be achieved that we don't l 7 have a --
8 MEMBER KRESS: You mean the amplitude of the l I
9 spike would be 10~'? l I
10 DR. POWERS: Uh-huh.
11 MEMBER POWERS: Do you have an allowed outage 12 time that -- the new reg guide's got one that has a 13 probable listing basis to it or more fairly, it can be c
)
k/ 14 converted into a risk capping. Do you think that has more 15 generality to it?
l 16 DR. POWERS: I do, sir. Yes.
17 MEMBER POWERS: It just strikes that it is a 18 rule that comes straight out of the existing rules. I 19 mean, it has its genesis back in the deterministic era, 20 but it has a -- you can have a probablistic interpretation 21 on it; it gives you a cap for the amount of risk you'll 1
22 tolerate during an equipment outage.
23 DR. POWERS: We have not, I believe, in this 24 region in the last decade or so had any particular issues l ( ,) 25 where we found risk to be unacceptable on any particular NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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162 1 maintenance activity. I think our utilities are getting
,~s 2 much more smarter, and they recognize the benefits of i i i'~/
3 keeping risk to a minimum.
4 If there's any message I would leave you with 5 today, it's the maintenance rule has been very beneficial 6 to safety. It has improved the control of risk in power 7 plants.
8 MR. CHAMBERLAIN: And the allowed outage time 9 on any one piece of equipment may be okay, but we want 10 theia to look and they are looking at the combined effect, 11 you know, what we talked about the storm and only one 12 piece of equipment, and is that acceptable.
13 MEMBER POWERS: Sure. That would be -- I A i
(/ 14 mean, what you -- you can -- is the allowed outage time to 15 give you a risk cap, and then you have to look at 16 everything else to see what the risk actually became.
17 MR. LARKINS: We heard yesterday that at least 18 Comanche Peak will also consider defense and depth 19 considerations in addition to the risk envelope, so either 20 procedurally or other ways, supplementing what they were 21 doing.
22 MR. CHAMBERLAIN: Licensees are getting pretty 23 sophisticated. Jim talked about we did see some examples 24 where we didn't think they did the right things, but I A
( ,) 25 think those are getting less and less. We just need --
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163 l
l l
1 DR. POWERS: The trend is definitely positive j , ~3 2 from a safety point of view.
I i $
l \ /
3 We've got four tools that are used in this 4 region. The first one there is qualitative judgment is l 5 the old way, widely used prior to the publication of the 6 maintenance rule, and it's commonly used today for non-7 risk-significant BOP, balance u. plant, SSCs.
8 Most of our licensees are using a matrix of 9 SSC combinations. It's simple, convenient, but it's two-10 dimensional, so it has a limited applicability to only 11 dual combinations of SSCs, and typically we see only the 12 high-risk significant SSCs that are addressed by the tech i 1
13 specs in this matrix. 1 x
') l
( '
k 14 I mentioned Fort Calhoun. They, for instance, 15 used a specific configuration calculatiow at one time.
16 Other licensees do too. It's slow, costly, and it's not 17 user friendly, and it takes trained PRE people to 18 implement.
19 What seems to be, in my view, the future in 20 this -- these tools is the latter, the computer-based 21 tool. In particular, all of our Entergy plants are using l
l 22 a model. They call it EOOS, equipment out of service, l
t 23 model, and it's basically a real-time model. It's in the 24 control rooms even.
/~N q) 25 And this model compares the proposed plant l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
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164 1 configuration and the associated risks against an average 7_
2 plant configuration previously quantified by the PSA l \
\# 3 model.
4 When I think of good attributes of on-line 5 maintenance risk assessments, I -- when I mentioned there 6 is no requirement for on-line risk assessments, we think 7 some of the good attributes that should be included 8 therein is -- they should address all maintenance 9 activities that affect reliability and availability, not 10 just corrective maintenance, but also preventive 11 maintenance, predictive maintenance, surveillance, and 12 post-maintenance testing.
13 They should account for the total SSCs that r^N k_ 14 are out of service, not just the risk-significant SSCs.
15 There are interdependencies of SSCs, and they should be 16 performed for all on-line maintenance, regardless of modes 17 of operation, and they certainly should be available for 18 use for emergent work. Everybody deals with frozen 19 schedules that at the last minute become undoable.
20 Our Agency's expectation for safety 21 assessments is basically given in the maintenance rule, 22 paragraph (a) (3) . It says -- and I quote -- "In 23 performing monitoring and preventive maintenance 24 activities, an assessment of the total plant equipment
( (/N_/n) 25 that is out of service should be taken into account to l
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165 1 determine the overall effect on performance of safety 2 functions." ;
(7_,) l 3 There is an April staff requirements l I
4 memorandum that instructs the staff to look at the ,
l
\
5 changing of the rule from "should" to "shall." My 1
1 6 personal view is we should, and I think it shall happen. !
i i
7 In terms of guidance for assessing on-line 8 maintenance risk, I think of two documents. In 1995, INPO i 1
9 sent to its members a letter on managing maintenance l
10 during power operations. That's a letter that embraces 11 the concept of on-line maintenance. It gives some 12 concepts for employing, but it's very short on details.
13 More recently, NUMARC has provided more 7
(_/ #
14 detailed guidance in NUMARC 93-01, and we have endorsed 15 the NUMARC guidance in our reg guide 1.160 as being an 1
16 acceptable way to implement the maintenance rule. It goes 17 far beyond risk; it considers all aspects of the 18 maintenance rule.
19 Over the last decade in Region IV, we've had 20 two opportunities to do programmatic inspections of on-21 line maintenance. Our first -- I believe first in Region 22 IV was the TI 126 on evaluation of on-line maintenance in 23 1994. We had the resident inspectors do the follow-up to 24 this TI, and they spent about a week each on looking at l O 25 all aspects of on-line maintenance. They weren't PRA l ()
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166 i
l 1 experts, and so you don't have a lot of PRA expert 4
_s 2 insights in those inspection findings.
[ )
s
' '/
3 More recently, we're in the process of using 1
4 the inspection procedure 62.706 to perform our maintenance 5 rule baseline inspections. These inspections are being 6 performed by teams out of the Region, and they include PRA i
7 experts from Brookhaven, INEO, and in some cases, our 8 senior reactor analysts as well. l l
9 I was going to tell the committee about our TI i 10 findings, but when I went back and looked, I found that l l
l 11 they really aren't germane anymore. The industry has come '
12 so far that those findings in '94 are basically worthless 13 today, and I can tell you about our baseline inspections, l 4
73
>V 4
14 though.
15 This region has 14 sites --
16 MR. LARKINS: Can I ask you a question?
17 DR. POWERS: Yes, sir.
18 MR. LARKINS: Would you say that's across the 19 board in the Region or are there outliers?
20 DR. POWERS: There's utilities that aren't 21 where they ought to be today. I'm convinced of that, and 22 I'll be explaining one real soon here. But I think that's 23 across the board, that everybody's improved greatly.
24 We've done six baseline inspections, and I
()
A 25 tried to characterize these into three categories:
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t 167 l
1 licensees with no programmatic weaknesses, licensees with 2 programmatic weaknesses, and what's probably more useful 1
,s (7-)
~'
3 to the NRR staff in 1 sponding to the staff requirements 4 memorandum is licensees with failures to perform risk 5 assessments.
6 I've not listed under these all of the risk 7 insights that are neutral: adequate, sufficient, l 8 acceptable; but I tried to list the findings that are 9 weaknesses, violations, or strengths.
l 10 Cooper is the first utility here. They're ;
11 using as a risk tool a matrix. When we looked at their j 12 program, we found that the operator knowledge was lacking 13 on their own requirement for evaluating the impact of A
i s
'w /' 14 plant status upon risk. We found the use of an 15 inappropriate standard performance criteria for l 16 reliability, and that had an adverse effect on the risk 17 ranking for SSC safety significance.
18 What I'm talking about there is MPFFs, 19 maintenance preventable functional failures. They were 20 only considering failures which does not consider demands 21 on a system, time in service, so they only had part of the 22 story there.
23 We found that they were not -- we found one l
l 24 example where they had entered into a predetermined risk-
' fm
! ,) 25 significant window without first performing a prerequisite i
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168 1 checklist. We found in regards to unavailability that
,e~) 2 they were not monitoring some risk-significant systems.
3 This included ADS, HPSI, emergency diesel generator and 4 RHR, and we found several -- probably about 20 -- examples 5 of failures to perform risk-significant risk assessments 6 on safety-related emergent work.
7 There were no high-risk significant examples, 8 and you might ask: How did we have enforcement in that 9 area, since risk assessments are not required? They are 10 actually required by the utilities program at Cooper.
11 They were in a quality procedure, and it was a management 12 expectation that it happen, and it had not been happening.
13 Overall, the risk assessment process at Cooper A
\ '?
14 at significant procedural weaknesses. We were quite 15 critical, some dozen or so examples of violations in that 16 inspection. We found the process did not address actions 17 when SSC failure occurred while in a risk-significant 18 window, did not address assessing risk when removing SSCs 19 of low risk significance, and it was unclear on the 20 responsibility of performing risk assessment for emergent 21 work.
22 The second licensee that we have here, we were l 23 on site last week, completing this inspection, Diablo 24 Canyon. They too are using a matrix. These decisions are O)
(_ 25 preliminary at this time, but the matrix we found did not i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l l
169 1 account for all risk-significant SSCs such as an aux l
p.- 2 building and switch gear ventilation, and we had one
( ')
3 failure to perform a risk assessment prior to removing l
1 4 from service a high risk-significant SSC, and that was the i
5 aux saltwater, very important system at Diablo Canyon.
i 6 overall, their risk assessment process was 1 1
7 considered adequate by the team. l 8 Third licensee in this category is Grand Gulf.
9 Grand Gulf is using the Entergy EOOS model, a very 10 sophisticated model compared to the other utilities.
11 However, we found some weaknesses here. Operators lacked l l
12 the sensitivity to the need for monitoring and tracking l
13 SSC unavailabilities and changing risk configurations.
n
! i 1
(_/ 14 This is important, because if your operators j i
15 aren't logging and noting for reliability and system 1
16 engineers what's happening to the equipment, then they 17 don't know.
1 18 We found availability was not being monitored 19 for some risk-significant SSCs. Included was the 1
20 instrument air, nuclear boiler instrumentation, and 1
21 control rod drive. l 22 We found that SSC performance criteria were 23 not established commensurate with the risk assessment.
24 What had happened was they did a sensitivity studies, and r~N l (j .
3 25 they found that if the plant was really operated at the NEAL R. GROISS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W.
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f 170 1 level of unreliability that was assumed by some of the l
2 performance criteria, that core damage frequency would
' 'i 3 double. So they went back and changed those criteria 4 obviously.
5 We found the SSC risk-ranking methodology was 6 lacking in that it did not assess unavailability and 7 reliability assumptions. Here the risk-ranking 8 methodology is used to determine what should be in scope 9 and then to determine what importance should be given to 10 that in your risk tool.
11 There was one failure to perform a risk 12 assessment prior to removing a diesel from service there.
13 But we thought that overall the risk assessment process l'3
\.._-) 14 was a good process. It's in the early stages of 15 implementation.
16 The second category I have here is licensees 17 with programmatic weaknesses, which include Palo Verde.
18 Their tool was a matrix. We found that the evaluation of 19 cumulative risk impact on multiple SSC outages lacked an 20 analytical basis and in some cases yielded nonconservative 21 estimates.
22 Overall, the risk assessment process had 23 procedural weaknesses. Its guidance for assessing 24 configurations not addressed by the matrix was weak. And
- "h l (m ) 25 the matrix did not address some BOP SSCs that were not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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171 1 modeled in the PRA.
fs 2 Another licensee with programmatic weaknesses
/ i
was WNP-2.
3 Their risk tool was something between 4 qualitative judgment and a matrix. It's just a procedural 5 listing of certain SSCs of high safety significance, and 6 that's for the operator and the engineer's consideration.
7 A positive note was that a risk assessment was 8 required to evaluate safety prior to voluntary entry into 9 tech spec action statements for corrective maintenance.
10 We found that unavailability was not monitored 11 for certain risk-significant SSCs that included the 12 nuclear condensate, reactor heat water, and 13 uninterruptable Ia. gower supply. Here again, they also
/S
(-) 14 had an inappropriate use of a criterion of MPFFs for 15 reliability.
16 Another positive aspect was that a risk 17 assessment on a frozen maintenance schedule was provided 18 for changes involving high risk-significant 19 configurations.
20 overall, the risk assessment process had 21 procedural weaknesses. It did not include all SSCs of 22 high safety-significance; it did not address the necessity 23 of performing a risk assessment for emergent work nor for 24 unanalyzed configurations. And it did not address the
,~
(v ) 25 impact on safety when low safety-significant SSCs were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N.W.
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172 1 removed from service.
,y 2 The last category -- and I have only one
- i
% i
~'
3 licensee in that area -- is programs with no programmatic 4 weaknesses: Waterford 3. Their tool is EOOS. We found a 5 positive aspect that they have an operations guide that 6 provides guidance for consideration of seasonal weather 7 conditions and quantitative assessments of switchout 8 activities. I expect that guide is pretty well thumbed 9 through by today with the hurricane nearby. i 10 Their SSC risk-ranking methodology was lacking ;
11 in that it did not address unavailability assumptions. We l l
12 also found the method for establishing unavailability l 13 performance criteria was lacking in that it did not fully i/ 14 evaluate the cumulative risk impact of all system 15 interdependencies.
16 They too were not monitoring unavailability 17 for certain risk-significanc SSCs that included 18 engineering safety features, actuation, plant protection, 19 core protection, calculators, broad-range gas monitors, 20 and containment polar crane.
21 overall their assessment process, though, was 22 considered to be as superior.
23 And I guess that concludes all I had planned 24 to say, but I wanted to leave you with the fact that we p
,w.-) 25 see real benefits to the maintenance rule. We see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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173 1 licensees monitoring NRC's inspection findings. They're s 2 on the Internet. And it's been our custom to get
/ \
\/
3 questions about findings at other plants from other 4 utilities that we have to deal with.
5 CHAIRMAN BARTON: Dale, you said you see 6 improvements for the maintenance rule. What do you think 7 utilities' perspective is on the maintenance rule?
8 DR. POWERS: Mixed bag, sir. I've had utilit*f 9 managers say it has been good for us; it helped us focus.
10 And I've also had some that indicated that it really 11 wasn't -- hasn't been that useful to them.
12 MEMBER POWERS: I guess we got mixed 13 perspective yesterday, which a little bit surprised me
(~,
(_ / 14 anyway, that -- my feeling was that -- had always been 15 that it was a focusing tool and that it allowed insights 16 that you wouldn't ordinarily get about your maintenance 17 programs, and that it was a pretty good example, a la stockinghorse, as I call it, for other performance-based 19 regulations coming down the pike.
20 Now maybe I'm not so convinced of that. So 21 I'm interested in any insight you might have on what a 22 performance-based rule really ought to look like, to make 23 your life easier, other people's life easier, my life 24 easier.
I fw
( 25 DR. POWERS: Well, I guess -- that's a pretty NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1 1323 RHODE ISLAND AVE., N W.
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i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ l
174 1 big question. We probably should not use "should" in
,3 2 regulations, for one thing.
N)i 3 MEMBER POWERS: I think we can take that as a 4 lesson learned.
5 DR. POWERS: This rule, I believe, allowed 6 flexibility for utilities to do what they needed to do to 7 comply with it, to draw upon existing programs. And it 8 was, I believe, very well communicated to the industry, 9 and it was pretty well endorsed by the industry. There 10 were a lot of workshops. A lot of people have benefitted 11 from it. A lot of operators know more about risk today 12 than ever.
13 And if those operators don't know what's
,a
(_) 14 important, their logs aren't going to reflect that for the 15 maintenance rule coordinators who come along and try to 16 determine, what's our risk like. But I'm not sure I want 17 to tackle your question.
18 MR. CHAMBERLAIN: I expect there's a lot --
19 you'll probably hear the licensees don't like the fact 20 that this opens up another window for us to take 21 enforcement, you know, and that's the negative.
22 MEMBER POWERS: That's the major objection l
23 that you hear? Yes.
24 MR. CHAMBERLAIN: That's the negative side, g~s 25 I'm sure.
{)
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175 1 MEMBER SEALE: Well, I think there's another es s 2 aspect to this, though. The jury is still out on what the
- )
\
/
3 full impact of the maintenance rule. I mean, it's clear 4 that we don't really understand it all. And a lot of the 5 utilities have a show-me attitude right now, because they 6 want to see more. And maybe if they keep asking for more, 7 maybe they'll get more.
8 DR. POWERS: We noticed that Southern 9 California Edison is basically in a state of dejection 10 over the maintenance rule. Their views were -- in 11 particular, Harold Ray, the CEO out there, had the view 12 that the maintenance rule was going to provide them relief 13 from regulatory requirements, and it has not.
7 i $
(s/ 14 And I personally don't see where he reads that 15 into the statements of consideration or the rule.
16 MEMBER POWERS: I think there's a lot of, This 17 is supposed to give -- a lot of things. This is supposed 18 to give us relief. I don't see that in the objectivas or 19 statements of consideration or anything. It's supposed to 20 give us focus, pay attention to what really is important 21 to safety, and if that saves resources for the Agency and 22 the licensee, so much the better, but that's not the 23 objective. It's supposed to give us focus.
24 MR. LARKINS: Do you have a feel for the py (w/ ) 25 relative level of resources that licensees are putting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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176 1 into some of these efforts, that there's any correlation
,-s
, 2 with your observations?
l )
3 DR. POWERS: Difference licensees are doing it 4 in different means. The depth that they have involved in 5 these programs differ greatly. For instance, I see Grand 1
6 Gulf having expended minimal effort to develop a good 1 7 product, but they're relying on just a very few key 8 people, whereas if you go to other places, like Waterford, i 1
9 they trained and developed a lot of staff, and maybe they 10 get more benefits out of that staff knowledge now.
11 They have depth in their program, where you l 12 don't in others, so that would make a big difference. But 13 I don't have a good feel for the resources.
(N
(_) 14 MR. LARKINS: What about Cooper?
15 DR. POWERS: Cooper? Cooper was our concern 16 for five years. We were encouraging that utility to get 17 ready, to get ready. We couldn't force the hand. And 18 basically in the last year before the rule took effect, 19 they scrambled and assembled contractors and developed a 20 rule that when -- we went there, because that was -- in 21 August of 1996, that was our second licensee to pick in 22 the Agency.
23 And the reason we went there was because the 24 program office, as well as the Region, was concerned about rN (v ) 25 the delayed implementation of the rule. We would have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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177 1 gone there first, but Palo Verde offered to host a team, s 2 and that team was a big team. There were 18 people that
/ T
\
'~~'/ 3 went, 6 inspectors and 12 people that oversaw to ensure 4 censistency. Cooper's our first example, I think.
5 MR. CHAMBERLAIN: We haven't done the baseline 6 at Comanche Peak yet.
7 CHAIRMAN BARTON: They told us that they were 8 waiting for you guys to come.
9 MR. CHAMBERLAIN: They've done a self-10 assessment, and they've looked at all the other findings, 11 so --
12 CHAIRMAN BARTON: Got you lined up.
13 MR. CHAMBERLAIN: They're ready, I think.
I'3
'(_/) 14 CHAIRMAN BARTON: Well, thank you. I think 15 we're on cur schedule for break, so -- until 1:35.
16 (Whereupon, a short recess was taken.)
17 CHAIRMAN BARTON: We need to stay on schedule.
18 We're doing pretty good so far.
19 MR. GWYNN: My name is Pat Gwynn. I'm the 20 director of the division of reactor projects here in 21 Region IV, and I've been asked to talk with you about the 22 Region IV inspection program.
23 It's a pretty wide-ranging discussion here.
24 As you can see from the slide, I want to start out talking
/^\
t
, ) 25 about the status of our plants, then go into the i
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178 1 inspection program in a broad sense, and talk a little bit
's 2 about the resident inspection program.
( 3 And if you're interested, I am prepared to l 4 talk a little bit about the details of what a resident i
5 inspector does, talk a little bit about the region-based l
6 inspection that we perform, talk about the plant issues 1
7 matrix, which is an enhancement to the inspection program i l
8 that's been implemented recently, the way that.that plant l l
l 9 issues matrix is used in plant performance reviews, and '
10 then the SALP program, and at your request, I have a 11 matrix of recent SALP scores here in the Region.
l 12 So with that, I'll go directly into slide l
13 number 2, which had just Region IV plant status report. l I 1
\- ' 14 That -- if you'll put the next one up, I have yesterday's 15 plant status report. This is difficult to see. I hope 16 you have a copy.
l 17 This status report is provided to us by the 18 NRC operations center every day. They get this 19 information by testing the emergency notification system 20 telephones with the control rooms and determine plant 21 status information.
22 I wanted to highlight a couple of items on 23 this status report. Callaway is operating at 95 percent 24 because of an axial-offset anomaly in their core. That
~~
( ,)
I 25 axial-offset anomaly is getting some interest on the part NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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179 1 of the Commission, and there's a meeting scheduled on the l
,s 2 31st of July with Westinghouse Electric to better l ) i 3 understand the nature and the potential safety 4 consequences associated with this anomaly.
5 MEMBER POWERS: Does the Region do core 6 analyses, or is that all done out of -- I 7 MR. GWYNN: Principally that work is done by !
8 headquarters, the reactor systems branch. From time to I 9 time, we work with them. We've done a recent inspection 10 at WNP-2 on core reload analysis. We've done a pilot 11 inspection at Palo Verde a couple of years ago, looking at 12 core reload analyses that were being done by that 13 facility.
i (m .
\~_/ 14 We have an individual on staff. I think he 15 just presented to you, Dr. Powers, who is our fuels expert 16 in the Region, and he helps us quite a bit in that area.
17 MEMBER POWERS: Did quite a little bit of 18 research in that area in the past. I know that. I 19 MR. GWYNN: Yes, he has. So we try to keep l
20 involved in understanding what's going on, but we rely 21 heavily on headquarters' expertise in thi s area.
l 22 The other plants, most of them are operating 23 at full power. San Onofre Unit 2 and 3 are coming back up 24 to power. Unit 3's been down in a refueling outage for '
,/~m, l
( ,) 25 some time. During that refueling outage, they found a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 180 1
! 1 problem with some check valves in their plant that had 73 2 potential implications for Unit 2. Unit 2 performed a 3 test, found that they had the same problem, and shut down 4 for a maintenance outage to resolve the check valve 5 problem.
6 CHAIRMAN BARTON: Were these the check valves 7 that were in the check valve program or other check 8 valves?
9 MR. GWYNN: These are check valves that are in 10 the check valve program. Yes, sir. It's a problem that 11 you would not normally expect to find. These valves had 12 been provided by Carrotest [ phonetic). They had 13 originally been provided with a spring that's a part of t'~'s 6 $
\_/' 14 the actuating mechanism.
15 They need to have balanced flows through two 16 check valves and some replacement valves that have been 17 provided by the manufacturer had a different spring, 18 without any information from the manufacturer that 19 indicated that the spring was difference. Because of 20 that, they were unable to balance flows through two 21 different charging lines in the plant, and unbalanced 22 flows were a concern for one specific design basis 23 accident, and so that caused them to take action to 24 promptly correct that problem.
rm (j) 25 South Texas, both units at full power. WNP-2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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181 1 is coming up out of its annual refueling outage. They're
,- m 2 the only plant in the Region that's still on a 12-month I
' ] 3 refueling cycle. And Waterford 3 has been shut down for 4 quite some time in a refueling outage. They are -- were l 5 about to restart. They've made a mode change and were j 6 starting to restore the plant to an operating status when 7 they were challenged by Hurricane Danny, and I believe the 8 regional administrator talked with you about that this 9 morning.
10 So that's my quick overview. One point that I 11 would make that is something that's come to our attention 12 recently: This report is now put on the Worldwide Website 13 for the Agency on a daily basis, and it gets quite a bit
(~N k- / 14 of interest, especially from the financial community, and 15 that's something that we get feedback on from time to time 16 from the plant owners.
17 Going on, the overview --
18 MEMBER POWERS: The plant owners like that or 19 don't like that?
20 MR. GWYNN: No. They don't like it, because 21 there's information here about projected restart dates, 22 and when the control room provides that information, it 23 sometimes can affect the spot price of gas, that type of 24 thing, so there's a lot of sensitivity and licensees are
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182 1 can see that it says " unknown" when Waterford will
,- 2 restart. In the past, they might have provided us a best-iV) 3 estiraate date.
4 MEMBER POWERS: They run into a fiduciary 5 issues on that, giving out false or misleading 6 information.
7 MR. GWYNN: Exactly. Okay.
8 The overview of the power reactor inspection 9 program: The objectives ar the program are laid out in 10 manual Chapter 25-15, and I brought a copy of it, just to 11 hold up. This is our Bible for the reactor inspection 12 program for the operations phase of power reactor 13 operations.
I i
\ s/ 14 Basically, we're charged to ensure that 15 licensees operate safely, that they identify safety 16 problems, and that they identify trends in performance, 17 and that's our charge. We do that through a combination 18 of core, regional initiatives, safety issue, and reactive 19 inspections.
20 And I'd like to try to make clear what the 21 difference is. Core inspection, we have a number of core 22 inspection procedures that these are the procedures that 23 are performed at every plant, every cycle; every SALP 24 cycle, we perform each of these procedures typically.
(~h i, p) 25 And so a core inspection is the minimum
)
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183 1 inspection program that we've committed to the Commission 7-~3 2 and the Commission has committed to the Congress that this N.] 3 Agency will perform at every operating facility in the 4 country.
5 Regional initiative inspections are 6 inspections that go beyond the core program and typically 7 focus in areas where we've seen problems in the past.
8 Safety issues inspections are specialized 9 inspections. Usually there are temporary inspection 10 instructions that are put out by the program office, NRR, 11 that tell us what to do in that area, in response to 12 bulletins, generic letters. We have temporary inspection 13 instructions. Recent examples are the vehicle barrier t j
\/ 14 system inspections at plants, access authorization 15 programs at plants.
1 16 Of course, I'm sure you're all familiar with 17 the TI 25-15.109 motor operated valve inspections that l
1 18 have been going on for quite some time. Those are safety )
I 19 issues inspections. l 20 And then whenever there's an event at a I l
21 facility, we go into a reactive mode, and reactive I l
22 inspections are in addition to the planned inspections l 23 that we have. So core, regional initiative, and safety 24 issue inspections are planned activities for the facility.
O)
(_ 25 We schedule those in advance. We work very hard to keep NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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184 1 coordinated with the licensee, so we minimize regulatory 2 impact on the licensee's organization while we're 7- i
\',/
3 performing our inspections. These reactive inspections, 4 they're not scheduled; they're not planned, and we perform 5 them as needed, based on facility performance.
6 Our inspection approach is to do a selective 7 examination or sampling of licensee activities. And those 8 sampling inspections are typically performance-based 9 inspections. We talked a little bit about performance-10 based this morning. ;
1 11 My best example of the difference between ;
1 12 performance-based and programmatic inspections were the 13 maintenance inspections, maintenance team inspections that
- ,, 1
(_) 14 the Agency performed a number of years ago. We went to --
15 and I don't like to use specific examples, but I think j l
16 that this one is well known -- went to the South Texas !
17 Project and performed a maintenance team inspection at 18 that facility.
19 The team came back with a colored chart that 20 showed licensee performance in each of the important areas 21 related to maintenance, and it was almost all green. It 22 was almost a perfect program. But when you looked at the 23 plant and the material conditions of the facility, it was 24 bad. The plant was shut down, both units, for over a
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185 1 at the plant.
,- 2 And so a performance-based inspection would
( j 3 identify that there was a problem with maintenance at the i
4 facility, that our maintenance team inspections -- that we '
5 thought that they had the best program around. So that's 6 how I try to define the difference between a performance-7 based and a programmatic-based inspection.
8 We also try, to the extent that we can, to use 9 risk information in planning our inspections at the i
10 facilities. We use it in selecting the sample. If there l
11 are risk information available that would indicate that we 12 ought to look one system or one comy.nent over another, '
13 we'll use that information in selecting our samples for
/~N i 1
'\_ / 14 these inspections.
15 Also, we emphasize the importance of licensee 16 self-assessment processes during our inspections, and we 17 give licensees credit for self-identification and 18 correction of problems at their sites.
19 When we find problems, our principal actions 20 in response to the finding of regulatory problems or 21 violations at the facility, we might issue a notice of 22 violation. If it's a particularly significant problem, 23 we'll have an enforcement -- a predecisional enforcement 24 conference, and make a determination whether a civil
(),,
25 penalty ought to be assessed.
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186 1 In that case, when there are situations that 7, 2 involve inoperable safety equipment or unsafe operation of 3 the facility, then we can get into other things like 4 orders to modify, suspend, or revoke the license, things 5 that are immediate safety problems at the facility.
6 We don't consider those to be enforcement 7 issues. They may turn out to be enforcement issues later, 8 but we treat those as safety problems, and we work on 9 safety problems first and worry about enforcement later.
10 And that's our basic approach to inspection, 11 We have a couple of other tools. In the event 12 that there's an agreement between us and the licensee that 13 there's a problem and that there are specific actions that
/~s '
(
Ns- / 14 they need to take to fix that problem, then we can use a 15 thing called a confirmation of action letter, where we 16 document an agreement between us and them on the actions 17 that they will take to correct the problem, specific time 18 frames associated with those commitments that they've made 19 to correct that problem, and we follow up on the i 20 confirmatory action letters, principally through j 21 inspection; may or may not involve enforcement. j i
22 We also have what used to be an order to show ;
23 cause. It's now called a demand for information under 10 24 CFR 50. 54 (f) That demand for information was used last i fm 25 fall to require licensees to submit information to the
() i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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187 1 Agency about the design basis for their facilities, f~ 2 So that's a quick overview of the program in
< 1 3 general. I'd like to ask if there are any questions at 4 this point, before I go into the resident inspector 5 program in particular. ;
1 6 CHAIRMAN BARTON: Is it just perception, or is ,
l l
7 there an awful lot of CALs being issued lately? I l
8 MR. GWYNN: Well, the Agency has changed its l 9 posture somewhat related to the implementation of 10 CFR 10 50.59. That's the rule that allows licensees to make l l
11 changes to their facility, as long as they don't involve 12 change to the technical specifications or an unreviewed I 13 safety question. l T^'s; l
(_/ 14 And today if a plant is shut down and the 15 licensee identifies or we identify that there is an 16 unreviewed safety question in their plant, well, then our 17 posture is that we will not allow that plant to operate 18 until they've corrected that unreviewed safety question or 19 the problem it's causing, the unreviewed safety question.
20 And that has resulted in a number of 21 confirmation of action letters where licensees and the 22 Agency have agreed on the action that's needed to correct 23 the conditions'that are involved.
24 Agency policy is still evolving in this area, g
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s 188 1 on that at this time.
2 CHAIRMAN BARTON: We've been following where
/
)
\ J 3 50.59 is going.
4 MR. GWYNN: I believe that the Agency is ,
1 5 working hard to draw a bright line between what's a 6 modification to the facility on the one hand and what's a 7 deficiency in the plant. And if we can get that bright i
8 line drawn clearly and understand that with the industry, l
9 then I think we'll be in a better position to handle these 10 types of situations.
l 1
l 11 Going to -- unless there are other questions? l i
i 12 MEMBER SEALE: In that regard, have you had 13 any -- do you have utilities that use the EPRI -- what is i i )
%/ 14 it? -- 215 -- 125 -- NSAC 125 approach to evaluating l
l 15 50.59? l l
16 MR. GWYNN: I would say that most licensees --
17 MR. CHAMBERLAIN: They were using that, and we 18 were actually using some to --
19 MR. GWYNN: -- have adopted that in the past, 20 and we did not object to their adopting --
21 MEMBER POWERS: Have you seen cases where 22 people have used it -- I won't necessarily ask you to say 23 properly, but conscientiously, and failed to come up -- or 24 came up with what you considered to be an improper
,, ~.
() 25 determination?
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189 1 MR. GWYNN: Well, we've had some controversy
, - 2 at one particular facility in the Region about margin to
~'
3 safety and the threshold that might be applied, and that 4 has caused some difficulties in our inspection at that 5 facility.
6 But we've dealt relatively well with those, 7 using assistance from the Office of Nuclear Reactor 8 Regulations.
9 MR. CHAMBERLAIN: You know there's a new reg, 10 too, out for comment right now, draft new reg 1600, that's 11 really kind of replacing that NSAC document.
12 MEMBER POWERS: Yes. We've written a letter 13 on that.
t i
\_ / 14 MR. GWYNN: But we're not implementing that.
15 It's out for comment, and we have very clear instructions 16 to our inspectors that although they may be aware of that, 17 we are not implementing that. We're implementing the 18 manual chapter 9900 guidance that we've provided to our 19 inspectors and the generic letter 91.18 guidance that's 20 been promulgated in the past.
21 CHAIRMAN BARTON: That's the operability --
22 MR. GWYNN: Operability be graded in j 23 nonconforming conditions. Yes. So those are the things 24 that we're using right now. We're watching as the policy
/%
( ) 25 evolves. I know that the Agency is about to issue a
%d i NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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t
190 t
l l 1 revision to generic letter 91-18, to help to define that s 2 bright line that I spoke about a few moments ago, i!,-)
1
\,'j 3 Other questions?
I 4 (No response.)
5 MR. GWYNN: Okay. Resident inspector program: )
1 6 This program really began in the late '70s. The concept 7 was put in place in about 1977, before the Three Mile 8 Island accident, and that -- the purpose of having a 9 resident inspector program was to provide a continual NRC 1
10 on-site presence at each power reactor in the country, to 11 provide for a rapid NRC response to plant events, to 12 increase inspection time and direct observation of 13 licensee activities at the plant --
/~N, k/ 14 During those days, the focus was almost all on 15 records review, and so this was a desire to increase 16 direct observation of licensee activity.
17 To provide us with enhanced knowledge of the 18 conditions at licensed facilities and a better basis for 19 some regulatory decisions. If you're basing your 20 decisions on the paper that exists rather than on the --
21 what actually exists at the plant, that can be misleading 22 at times, and so it was important for us to have an agency 23 expert on that plant. And this provided us that l
24 opportunity.
n
( ) 25 It allowed us to provide less reliance on
~
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1 l 191 1
1 records accuracy and more independent verification of
, ~\ 2 licensee activities, which in rare circumstances has been
' / i
'J 3
important to the Agency.
l 4 It's also provided us additional assurance l
5 that management control systems are effective and that
! 6 licensee performance is, in fact, acceptable.
l 7 Some of the key activities that resident 8 inspectors undertake include the detailed knowledge of the 9 facility and the regulatory requirements that apply to 10 that facility, license conditions and the technical 11 specifications in particular.
12 They conduct general and detailed inspections 13 of plant systems, operations, activities, and events at i t'h
\~ ') 14 the facility. They review licensee reports to assess 15 safety impact and accuracy, and these reports include 16 things like the condition reports that we talked about 17 this morning or other deficiency-reporting documents.
18 And so on a daily basis, it's not unusual to 19 find our inspectors reviewing the deficiencies that were 20 identified in the plant the day before, just to make sure 21 that we understand the current safety situation at the 22 plant and tvhere there are questions about that situation, 23 well, then they pursue those questions to make sure that l
l
- 24 we fully understand what the implications are for the r~N
( ) 25 deficiencies on ongoing plant operations.
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192 1 That -- the resident inspectors, he or she,
,e 3 2 they're required to maintain a knowledge of all t I
~
3 significant NRC inspector findings at their site, so they 4 are the owners of the NRC's issues at that facility.
5 Whether they're identified by the resident 6 inspector or by others, we expect them to know and ,
l 7 understand what those issues are, what the schedule is to 1
8 deal with those issues, who's responsible for those, both 9 in the licensee's organization and in ours, and then, of l 10 course, they prepare inspection reports that communicate 11 their findings to the licensee, to the NRC, and to the l
12 public. l l
13 They also interact with regional staff,
.f3 3 (s ,/ 14 headquarters from time to time, daily, in order to make 15 sure that they're clearly communicating their findings and 16 the results at the plant.
17 As Mr. Dyer indicated this morning, each 18 branch chief in the region has a morning call with the 19 resident inspector. That morning call in this region also 20 includes in the NRR project manager for the facility. It 21 typically occurs at 7:30 a.m. That's whether it's Central 22 time or Pacific time. It occurs at 7:30 a.m., and that's 23 what drives our morning meeting to be ten o' clock.
24 So that close coordination between the site,
/~
(N,) 25 the NRR program office, and our people here helps us to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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193 1 maintain a good understanding of what the safety situation g3 2 is at the plant and what the Agency needs to do from time
!vI 3 to time to ensure that we're acting promptly on problems 4 at the facilities.
5 I have a slide that talks about documentation 6 and inspection findings, but I'll go past that since Mr. ;
l 7 Dyer talked this morning about manual chapter 06.10 and l
8 its benefit that we've seen for our inspection program.
9 The resident inspection is the next slide, and 10 what I wanted to do was to just spend a few minutes to I
11 talk to you about what a resident inspector does, day to 12 day, at the plant. And his Bible, beyond manual chapter ;
1 13 25.15, is inspection procedure 71.707. That is plant .
/N i
'k /) 14 operations inspection, and that's where he spends most of 15 his or her time.
16 The resident inspector requirements are broken 1
17 down into daily inspections, biweekly inspections, 18 monthly, tri-monthly, semi-annual, and outage inspections.
19 And so these inspections and frequencies dictate what they 20 do day to day in their plants.
21 On the daily inspections, we expect them to 22 perform control room observations on a daily basis, and 23 during those control room observations, they'll be looking 24 for such things as proper control room staffing as i
n
- ( ,.) 25 specified by the license and that the access to the i
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194 9
1 control room's been properly maintained, that the
,- 2 operators are attentive to the controls, that there's
( ,)'
3 formality and communications in the control room, that 4 they're adhering to approved procedures and to the 5 technical specifications for the facility, and that they 6 know the status of lighted enunciators in their plant.
7 That means that they know what degraded 8 equipment that they may have. They -- our inspectors 9 review such control processes in the control room as their 10 shift supervisor and tag-out logs, operating orders, plant 11 trouble reports, and the control room log, to make sure j 12 that they're aware of, again, what's happening in the 13 plant.
N_ / 14 Jumper and bypass logs, determinations of 15 reactor coolant system inventory leak rate -- those are 16 important, and we sometimes verify that those are being 17 properly performed.
18 We also observe containment integrity and the 19 actions that the licensee is taking to ensure that 20 containment integrity is maintained.
21 CHAIRMAN BARTON: Are they required to observe 22 shift turnovers?
23 MR. GWYNN: Shift turnover is on my list.
24 Yes, sir. I should have had it at the top, because that's c.,
25 typically the first thing that they do in the morning is
( ))
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195 1 go to the control room, observe the shift turnover and get 7_ 2 the plant status for their 7:30 meeting.
(' )
3 They also look at equipment out of service.
4 They verify the operability of the reactor protection 5 system and other safety systems on a daily basis, and they 6 observe surveillance activities that are in progress in 7 the control room.
8 We also expect them to tour the plant on a 9 daily basis; in other words, to get out into the plant and 10 to know what's going on; inspect major components, looking 11 for general conditions that might degrade system .
l 12 operation, looking for control of fire hazards in the l l
l 13 plant, that there aren't accumulations of debris and other I f^h >
j
\_ ' 14 materials that might exceed fire loadings that are \
15 allowed; to independently assess the condition of safety l 16 equipment and the availability of plant equipment; observe 17 general plant cleanliness.
18 And oftentimes, they'll attend the licensee's 19 plant of the day meeting, and that helps them to schedule 20 their inspection activities and to keep us aware of the 21 important things that are happening at the plant that day.
22 On a biweekly basis, they perform a more 23 detailed evaluation of the operability of a selected 24 engineered safety feature train. Typically they use PRA p) t v
25 information in the selection of those systems, and some of NEAL R. GROSS COURT REPOhTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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l 196 1
1 the things that they look at when they perform these 7s 2 biweekly inspections are correct valve positions,
.?
l
(') 3 alignment of power supplies and breakers, verification
! 4 that power's been removed from some equipment if it's 5 required by the plant configuration.
6 For instance, if the plant's in reduced I 7 temperature operations, LTOP, low temperature over 8 protection, may be important. Certain pumps are required j l
9 to be tagged out, so that they don't over-pressurize the 10 plant components. And so they would verify that.
l 11 Verify or inspect major components for 12 leakage, proper lubrication, cooling water supply, and l 13 general condition, and verify that instrumentation and
, (~)
' (sl 14 support systems are available and operational.
15 Those are some of the things that they look at 1
16 during those ESF system walk-downs.
17 On a monthly basis, they independently verify 1
18 safety-related tag-outs. They look at the problem 19 identification system in more detail to confirm that it's 20 being properly implemented. They will verify a selected 21 portion of the containment isolation line-up, and they 22 keep informed of third-party audits. I talked about that 23 this morning.
l 24 This isn't just the activities of the fM
( ) 25 Institute for Nuclear Power Operations, but other third-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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197 1 party audits that may be performed at the facility,
,x,
, 2 looking at activities of off-site review committees and
( )
3 the site safety review committee.
4 On a tri-monthly inspection, they verify 5 overtime for licensed operators, and they verify notices 6 to workers are continuing to be properly posted.
7 On a semi-annual basis, they look at the 8 seismic monitors for the facility, to confirm that they 9 remain operable. And they do a detailed ESF system walk-10 down, which typically will mean that they'll break out 3
11 PNIDs, that they'll walk the system hand over hand with 12 valve lists, with breaker configurations. This is a much 13 more detailed walk-down than the biweekly inspection that
,~.
ss 14 I spoke about earlier.
15 MEMBER POWERS: Which one of these inspections 16 do they look at the security and safeguards?
l 17 MR. GWYNN: That's typically done on a daily !
18 basis, as they're making their plant tour. They're 19 required during their plant tour to look at such things as 20 health physics being properly implemented in the plant, 21 that the security system -- you know, every time that they 22 come into the facility, they interact with the security 23 system; they observe security activities in the access 24 areas for the plant; and so --
,/ y
() 25 MEMBER POWERS: Do they walk the perimeter?
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198 1 MR. GWYNN: They do on occasion. We don't ask j3 2 them to do that frequently, but they do walk the perimeter
( )
3 on occasion.
4 During outages, they'll take a focused look at 5 things that typically aren't happening day to day during 6 plant operations, and in particular we pay close attention 7 to reduced inventory operations and to other activities at l
8 the plant that may impact shutdown risk. l
)
9 And so if there's a diesel out of service, 10 well, then they'd look at switchyard access control, as an 11 example. All of the time, they're looking at the 12 implementation of work controls in the plant. That's a l l
13 part of their routine daily monitoring, but during l
/ 14 outages, typically there's a lot of modification 15 activities that are going on, and so they'd focus on the 16 modifications and the post-modification testing that's 17 being performed.
18 Containment close-out is an important activity 19 that's done during outages. Fuel handling is another one 20 that they'll observe during outage activities, and 21 verification of safety features that typically may not be 22 accessible.
23 And as an example, during the recent refueling 24 outage at the Cooper Nuclear Station prior to close-out of y^
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i 199 1 pressure vessel, looking at the control rod drive housing
,- 2 support configuration to verify that that important j f\ ') 3 passive safety feature was properly installed, and he l
4 found some things that needed to be corrected. So that 5 was a valuable activity.
l 6 We also look at the effectiveness of licensee 7 controls, their corrective action systems, the goodness of 8 root cause analyses that are performed, and scheduled I
9 audits and surveillances of control room activities and l 10 other activities at the plant, to confirm that their ;
11 independent oversight is operating properly and 12 effectively.
13 MEMBER POWERS: When one inspectors or looks
(')
\s / 14 at a root cause analysis to judge the goodness of it -- '
15 I'm not sure what goodness means in that case.
16 MR. GWYNN: That can be somewhat subjective, j i
17 and we sometimes have to get into discussions as to how 18 much in depth a root cause analysis is needed. It depends 19 upon the significance of the problem that's involved.
l 20 But if they're required to perform a root 21 cause analysis -- and they are for significant conditions 22 adverse to quality -- then we expect our inspectors to 23 look at those root cause analyses on a sampling basis, of 24 course, and when they look at them, see if the licensee rm 25 has utilized objective measures, perhaps an outside
()
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200 1 laboratory, to take a look at fracture surfaces that may 2 be involved.
(' l 3 You know, it depends upon the specific 4 situation, but to verify that the licensee has used the 5 tools that are available and that the conclusions that 6 they've drawn based on the objective information that's 7 available is consistent with good engineering analysis.
8 CHAIRMAN BARTON: I'm familiar with -- every 9 time I had an event at my station and we did -- put 10 together a group to go and do root cause analysis, we 11 always had one of the residents participate in that -- not 12 participate, observe, was an observer, and he usually sat 13 through most of the meetings that the root cause group
(~~'s
(_) 14 conducted. So they were really intimately familiar with 15 the process and what was going on.
l l
16 MR. GWYNN: Not only do you learn a lot about j 17 the goodness of that specific root cause analysis, but 18 licensee's self-assessment capability comes forward very 19 clearly in those activities, and that's why it's important 20 for us to observe those.
21 MEMBER POWERS: You opened your remarks by 22 indicating that you'd used risk information where you can.
23 And I'm thinking in particular of a couple of scoping 24 studies that the NRC has sponsored about shutdown risks.
(oI
~J 25 Do those provide you any particularly useful information?
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201 l
1 MR. GWYNN: Well, we were going to talk with
,__ 2 you this morning about the Wolf Creek draindown event.
! )
~~
3 That -- in that case --
4 MEMBER POWERS: That's not fair, because they 5 didn't cover that particular mode of operation, and it i
6 would stun me if they'd gone to that detail. l 7 MR. GWYNN: Most licensees do not have true 8 shutdown PRAs. But oftentimes they do have ORAM tip or 9 other similar tools that are available to them. We'll 10 look at the results of their analysis. Depending upon the 11 level of sophistication of the PRA program at the plant, 12 it varies considerably from plant to plant. We'll take a 13 look at those analyses; we'll look then based on what m.,
( ,)
_ 14 they've done, at the controls that they've put in place 15 for high-risk activities, and sometimes we'll do 16 independent verification under certain circumstances.
17 MEMBER POWERS: I think what you're telling me 18 is that generic studies or representative studies that 19 headquarters may have done would be of limited 20 applicability to a particular plant.
21 MR. GWYNN: Even plant-specific studies, if 22 they're too general in nature, are not useful in 23 conducting on-site inspection activities.
24 MR. CHAMBERLAIN: You know, I think the work i ) 25 that was done for preparing shutdown rules and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 202 l i
1 industry work and the NUMARC guidance that was put out, 1
7s 2 all that work was looked at, and we use that to some i k) 3 degree to go, when a licensee's going into an outage. You ,
4 know, are they doing the right things; are they keeping l 5 back-up power?
6 We're looking at that and seeing what the 7 licensee's doing really, and similar to what the shutdown I 8 rules might require. l 9 MEMBER POWERS: But the specific -- looking at 10 Surry, the trouble is they're too Surry. They're just --
l 11 I understand. I 12 MR. GWYNN: That is a quick summary of our 13 resident inspection program. Of course, we have resident l I
\~/ 14 inspectors at every plant in the Region. We're typically 15 staffed at N-plus-one for plants that are all SALP 16 category 1 performers. The Agency adjusts resources of 17 the plant appropriately. We're in the process of making a 18 recommendation regarding staffing at Comanche Peak.
19 CHAIRMAN BARTON: Now, who has to approve 20 that?
21 MR. GWYNN: That's approved by the director of 22 the Office of Nuclear Reactor Regulations, recommended by 23 the regional administrator.
24 MR. LARKINS: l'd be interested in knowing how n
() 25 much time is spent on 71.07 activities versus regional NEAL R. GROSS i
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203 1 initiatives and follow-ups, something like that. l 73 2 MR. GWYNN: That varies from site to site.
('~' ) i 3 The core program provides estimates as to the amount of 4 time that's necessary to perform each inspection 5 procedure. But those estimates are based upon the skills l
6 of an average inspector, and so if you have a high-i 1
7 performing inspector who really knows the plant well, who I 8 is very familiar with the inspection procedures, they may 9 be more efficient in the conduct of the inspection than l 1
10 another inspector who's just learning the plant, who --
11 even though he's been previously qualified at another 12 facility, isn't sufficiently familiar to be as efficient 13 as somebody who's been at that plant for a longer period
, ,, s i \
\j 14 of time.
15 So it's difficult to give you specific 16 breakdown. But, in general, I would estimate that a 17 typical resident inspector would spend about 50 to 70 18 percent of his direct inspection effort doing the core 19 program. They are, to a large degree, the Agency's core 20 inspector for the facility.
21 There are some other core inspection modules, l
22 inspection procedures, that are performed in EPHP l
l 23 securities. We have an additional core module for 24 licensee self-assessment programs that's performed out of rm
/ 1
() 25 the regional office.
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204 1 We have a core module for ISI programs that
,_ 2 are performed out of the regional office, but to the large 3 extent, the resident inspectors perform the core 4 inspection program for the Agency at each of the power 5 reactor sites.
l 6 Now, if a site only has a core program and l
7 does not have, you know, a regional initiative inspection 8 effort as scheduled and planned, then we from time to time i l
9 find ourselves with more inspection capability at a site 10 than what is needed to accomplish that core program. And 11 then that results in a management challenge for us to 12 provide opportunities for those inspectors to inspect at 13 facilities that have more than a core program.
r'N
! I k/ 14 And we've been more effective over the last 15 four to five years in accomplishing that part of the 16 inspection mission than what we had been in the 1980s and 17 early 1990s. Today I can't stand here and tell you that 18 that's a perfect program. We still have some facilities 19 where we do more inspection than what we had planned, and 20 we're continuing to look for ways to better manage that 21 inspection resource.
22 MR. CHAMBERLAIN: One you n't mention was 23 we've got a fairly large engineering core inspection, 24 which you may talk about later in the region-based.
e 25 MR. GWYNN:
~(v) Yes.
t NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W.
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205 1 MR. LARKINS: At one point it might be
,-~s 2 interesting for the committee as to how long it takes to
( \
\
'~' /
3 train -- get a resident inspector certified through the 4 board and everything.
5 MR. GWYNN: Typically from the time that an 6 individual is hired as an inspector, whether he's a 7 resident inspector or regional-based inspector, our 1
8 expectation is that they would complete that training and 1
9 certification process in no more than two years, but it's 10 our desire for them to finish that more quickly. Eighteen 11 months is a nominal time. Some inspectors, depending upon l
12 their level of expertise coming into the job, can complete !
13 their certification in a year.
/~N
~ 14 But anything under a year is rare and unusual.
15 There's so much training that's required and formal 16 training activities, and then the on-the-job training is 17 the most critical part of training an inspector, on-the-18 job not only at the site but in inspection techniques and 19 skills that they need to perform inspections.
20 In this region, we've considered that that 21 aspect of the job, the actual on-the-job practice of 22 inspection techniques is so important that we l
l 23 significantly increase the number of inspections under 24 instruction that are required for certification, n
(w/ I 25 Manual chapter 12.45 specifies four; we 1
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206 1 specify ten additional inspections under accompaniment 7.~ s 2 before an inspector can be certified, just because we i\ \
\~'! 3 think that that's such an important part of the program.
4 MEMBER POWERS: Have you identified skill base 5 or background that leads to particularly good inspectors?
6 MR. CHAMBERLAIN: We talked about that. We're 7 trying to develop a profile of what would be a good 8 inspector, and we know what they look like when we see 1
9 them, but -- '
10 MEMBER POWERS: A mean SOB, prerequisite 11 number one.
12 MR. GWYNN: Actually I've seen a wide range of 13 different personality types that use different inspection
() 14 techniques very effectively. We have one individual in 1
1 15 the Region who has a very dry British sense of humor who l l
16 very effectively utilizes that sense of humor in the 17 inspection process, and he can learn things that some l 18 other inspectors could never drag out of somebody, just by 19 utilizing his dry humor, and a very, very sharp intellect i
20 with a depth of technical knowledge in his area of 21 expertise that goes beyond most licensees. l 22 CHAIRMAN BARTON: Has the licensee smiling as l 23 he's writing the violations. Very effective.
24 MR. CHAMBERLAIN: It's interesting, too -- in e
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207 1 know, in inspecting, a certain type of inspector. A New 2 Yorker in the Northeast may do fine up there, but if he 73
] 3 'omes to the South and uses the same style, he can offend 4 someone, and that's --
5 MR. GWYNN: And then there are a lot of 6 inspectors that can't use the technique that I discussed 7 earlier effectively. It just won't work for them, so 8 it's -- in a large extent, it's personality-driven.
9 MEMBER POWERS: One of the areas that I 10 persist in being concerned about is if we try to quantify 11 human performance and the lack of performance and human 12 error is the -- if you do studies of human performance in 13 Sweden, does it do any good in the United States at all?
(/ 14 It's a very different culture, you know. What 15 affects the performance in Sweden, it's not obvious to me, 16 has any bearing on what affects performance in the United 17 States and probably nothing at all like Japan.
18 I just don't know how translatable human 19 performance is over fairly short geographical distances.
20 MR. GWYNN: I've had the opportunity to meet 21 and talk with some Swedish inspectors in the past, and I 22 can tell you that those individuals -- I don't know if 23 they're typical, but the ones that I met were very large 24 men, and --
n
( ) 25 CHAIRMAN BARTON: Intimidation works well wi NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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208 1 for -- 1
\
3 2 MR. GWYNN: It works well for them, so just 1
3 for what it's worth.
4 Going to the region-based inspection program, 5 the regional-based inspection program is carried out by -
l 6 inspectors that typically have a higher level of 7 specialized expertise than what our generalists resident I 8 inspectors have. l 9 They are based here in the regional office, 10 and they inspect all of our plants, and that's an aspect 11 of regional-based inspection that's important, that we 12 need to retain. Our resident inspectors have a very, very 13 sharp understanding of their plant, and in this region, we
/ \
- t. 1
14 require them to have a lesser knowledge of a back-up plant 15 for emergency response responsibilities, and so typically 16 they'll know two plants reasonably well, ona very well.
17 But these regional-based inspectors inspect 18 all of the plants in the Region, and so they have a broad-19 based understanding of licensee safety performance in 20 their area of expertise at every plant in the Region, and 21 they can bring value to the plants that our resident 22 inspectors can't bring.
23 And that's one of the major values of having a 24 regional-based inspection program. Also if there are p)
"s 25 events at a facility, to be able to bring that specialized NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOD!i ISLAND AVE., N W.
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209 1 expertise to bear, I think is important. In addition, we
,s 2 talked this morning about the value of being able to ;
( \ '
s /
3 identify problems before they become events, and sometimes 4 you need specialized expertise in order to do that.
5 I think we've seen some fire protection issues 6 that came forward as a result of having Phil Qualls, our 7 fire protection inspector, who we've now lost to 8 headquarters, and that's just an example of their 9 specialized expertise so valuable to the Region.
10 Also these region-based inspectors provide an 11 important independent check on our resident inspection 12 program. They may go to the facility and find that 13 conditions are different from what the resident inspectors l
I! m 14 had portrayed, and we utilize that separate view.
15 We encourage that separate view, and when we 16 go through our plant performance review process, which 17 I'll discuss a little bit later, having that separate view 18 available during the plant performance reviews is 19 important to ensure that our inspection program for the l 20 facility is being maintained viable and healthy.
1 21 MEMBER POWERS: Have you attempted to l
22 ascertain in even qualitative terms the value you bring to 23 the plant by having inspectors with a cross-sectional view 24 of a lot of different plants, that come into a particular (sv.) 25 plant? It seems to me they would inadvertently impart NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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210 1 information. Well, so and so is doing this a better way
- 7. _x 2 up at this other plant, and you might want to think about i r
\,VI 3 it.
4 Do you think you get any of that kind of 5 advantage?
6 MR. GWYNN: That was a major advantage in the 7 past. That happened a lot. We encouraged the inspectors 1
8 not to talk about specific plants, but to identify that 9 there are other practices that they've seen, and today, 10 that -- although from time to time, we still get value and 11 in particular under specific circumstances, we've seen 12 value from having that, but because the licensees have so 13 much involved themselves in cross-fertilization
(/ 14 activities, plant visits, looking at benchmarking other 15 facilities, that -- the value of that has cecome less over 16 time.
17 But there are still some plants where it's 18 extremely valuable. There are some plants that don't do 19 as much benchmarking and visiting other facilities, don't 20 get the value effect of cross-pollenization that the might 21 otherwise, and so there are some plants where that's still 22 of great value.
23 MEMBER SEALE: The INPO people use peer 24 evalaators from other plants much more extensively now
() 25 than they used to, and so there's just almost a continuous NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.
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211 1 feedback among them.
,_ 2 MR. GWYNN: We have a few plants in the Region
.\ ') 3 that actually have a travel budget for their operating 4 staff, because they want their operators to get out and 5 see how others are doing the same job and bring back their 6 learning experience, and while they're there, they impart 7 experience from their own plants. So that brings a lot of 8 value.
9 Dwight, would you like to add anything about 10 the region-based inspection program before I go on, 11 because, you know, I'm the projects director and the 12 resident inspectors report to me through the branch chiefs 13 and projects. Dwight is the DRS deputy director, and the
,/7
(-) 14 division of reactor safety is where all of our regional-1 15 based inspection is located.
16 MR. CHAMBERLAIN: I think our past management i
1 17 and our current management really want to have a strong l l
l 18 region-based program. They see a lot of value in it, and i
19 Joe Callan really stressed that and wanted an independent 20 DRS, not somebody that just serviced DRP. He wanted DRS 21 to be independent, issue their own reports, have their own 22 views, so you could kind of balance DRP, so that 23 everything's not driven by DRP.
l 24 And the way we've rotated our managers, I was
/N (uJ ) 25 an acting deputy in DRP. I was a branch chief in DRP.
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212 1 I've worked in DRS; I've worked in DNMS. So we all s 2 understand each other's role, and I think that made us
( )
3 stronger too.
4 MR. GWYNN: I'll to plant issues matrix -- I 5 MEMBER POWERS: There seems to be a i
6 percolation or iteration of the management structure )
7 within this regional office; I mean, a lot of changing of ,
8 jobs and things like that, to give --
9 MR. GWYNN: I was the deputy director in 10 projects. I went to be the director in reactor safety. I 11 was there for three years. I've been director in projects 12 now since March of this year. And I'm hoping that my next i
13 job in the Region will be the division of nuclear I
(~~N,
! i
\/ 14 materials safety.
15 MEMBER POWERS: Pretty thorough cross-section 16 by the time you're done.
17 MR. GWYNN: Well, I have some role models that 18 have --
19 MEMBER POWERS: You know what a successful 20 career type is here.
21 MR. GWYNN: The plant issues matrix is a 22 relatively recent addition to our tools that we have in 23 managing the inspection program for the facilities. It 24 really is only a chronological listing of plant issues.
(3
( ,) 25 It comes from inspection reports, from licensee event NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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213 1 reports, from event notifications that have been made by 7-3 2 licensees to the headquarters operations office.
( !
'~'
3 So it's a chronological listing of all of the 4 key issues for each of the plants in the Region. We have 5 an inspection manual chapter 3.04 that provides guidance 6 on PIM format, the information that's to be provided for i
I 7 each entry, and gives us some sense for the threshold that i
8 we're supposed to use in determining what belongs in the 1
9 plant issues matrix and what does not belong in the plant I 10 issues matrix.
11 We are working hard today to try to become l 12 more uniform in these plant issues matrices, because 13 there's still a lot of variability amongst the branches.
f3 i )
N/ 14 MEMBER POWERS: I'll have to admit I've heard i 1
15 about this PIMs about a year ago, I think, and then I got 16 another introduction to it at the regulatory information 17 meeting. I'd love to see one one day.
18 MR. GWYNN: I had a back-up slide. I was 19 going to put one up in front of you, and I lost it, so it 20 was an inadvertent, not an advertent, loss of the back-up 21 slide, so I apologize for that.
22 MEMBER POWERS: I'm beginning to suspect this 23 thing doesn't really exist.
24 MR. GWYNN: This has developed into a very O
(_,/ 25 valuable tool for us, and it's used as part of both the NEAL R. GROSS COURT REPORTERS AND THANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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214 1 time performance review and the senior management meeting 7_x 2 itself processes. This -- it identifies each of the items
/ \
\ )
3 by whether it's a strength of the licensee's program or 4 whether it's a violation.
5 MEMBER POWERS: See, this is an aspect that I 6 hadn't heard about.
7 MR. GWYNN: It classifies each of the items to 8 hel.p to make clear what we ought to take from the 9 information. It shows the source of whether it's an LER, 10 whether it's an inspection report, or whether it's a EN or 11 an event notification. It shows the source document. It
.2 has a brief description of what the issue is, and we're 13 trying to improve those brief descriptions so that they're g
(s) 14 meaningful by themselves. Sometimes you have to go to the 15 source document to get the full meaning. So --
16 And then right now we include a cause. If we 17 have information that relates to the cause of a problem 18 that's identified in the PIM, well, we'll try to bring 19 that forward there.
20 This -- typically if you'll look at an 21 inspection report today that's been prepared under manual 22 chapter 6.10, you'll see that it includes an executive 23 summary, and the executive summary -- many of the 24 executive summary statements become PIM entries; not all
() 25 of them, but the key findings for the facility, both the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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215 1 strengths and the problems, are brought into the plant n 2 issues matrix.
i ';
3 The PIM -- some of the problems, some of the 4 improvements that we need to make relate to the 5 consistency between technical divisions, the consistency 6 between the regions. There's still a lot of work to be 7 done in that area. The threshold for PIM entries, I 8 mentioned; the level of detail in these PIMs -- those 9 things are still evolving over time.
10 Another important aspect of the plant issues 11 matrix is whether or not it should be released to the 12 public. That's a question that's been asked by the 13 Commission. It's currently not publicly available. It is
,f
(_,) 14 a Commission decision as to whether or not that document 15 will be released to the public.
16 Right now, having it in a condition where it's 17 not publicly releasable, believe it or not, causes us some 18 problems, because we would like to be able to hand a copy 19 of it to the licensee when we go to their plant and talk 20 with them about the results of our PPRs, our plant 21 performance reviews, but we can't do that right now, 22 because it's not a publicly available document.
23 So that's the down side. Now, the other side 24 of the equation is that there's some trepidation that
(~s
( ) 25 there might be information in there that people haven't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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216 1
seen before, that -- you know, there are a number of 2
._s
's different concerns about the potential release of the PIM.
'~'
3 I think that those will be addressed as a part 4
of process changes that we're making right now, and 5
whether or not the PIM is released to the public, as I 6 said before, is a Commission decision. The --
7 MEMBER POWERS: Have no fear. I can't get 8 one. It's really secure.
9 MR. GWYNN: Typically it does go back 18 10 months or 24 months, whatever the typical SALP cycle for a 11 facility is, and it's an important compilation of 12 information that's already on the docket. There really 13 should be nothing in the PIM that's not already on the
,f'h
(_,I 14 docket and available publicly, so that's the format that 15 we're working towards.
16 The plant performance reviews under manual 17 chapter 03.04, these are also an improvement in our 18 process. The process improvement started in 1988, but we 19 really made major improvements to the plant performance 20 reviews in 1995 and 1996. The ru - plant performance reviews 21 are done -- they're required to be done on a semi-annual 22 basis.
23 And this is a time when we, as the Region, 24 come together at a table where the division of reactor lh 25 projects, the division of reactor safety; we have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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(
l 216 l
l 1 seen before, that -- you know, there are a number of
- 7. 2 different concerns about the potential release of the PIM.
( )
3 I think that those will be addressed as a part 4 of process changes that we're making right now, and 5 whether or not the PIM is released to the public, as I 6 said before, is a Commission decision. The --
7 MEMBER POWERS: Have no fear. I can't get 8 one. It's really secure.
9 MR. GWYNN: Typically it does go back 18 10 months or 24 months, whatever the typical SALP cycle for a 11 facility is, and it's an important compilation of 12 information that's already on the docket. There really 13 should be nothing in the PIM that's not already on the p
't,) 14 docket and available publicly, so that's the format that 15 we're working towards.
16 The plant performance reviews under manual 17 chapter 03.04, these are also an improvement in our l 1
18 process. The process improvement started in 1988, but we 19 really made major improvements to the plant performance 20 reviews in 1995 and 1996. These plant performance reviews 21 are done -- they're required to be done on a semi-annual i 22 basis.
l 23 And this is a time when we, as the Region, l l
24 come together at a table where the division of reactor I
p) t, v
25 projects, the division of reactor safety; we have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W.
y (202) 234-4433 WASH!NGTON, D C. 20005-3701 (202) 234-4433
217 1 Office of Nuclear Reactor Regulation on the telephone. We
,3 2 talk about performance insights that have been gained at
! )
'~
3 each of the facilities over the last six months. We talk 4 about those performance insights by SALP functional area.
5 And so it gives us a very quick -- and this is 6 not a SALP; this is not an in-depth assessment. This is a 7 quick look-back, to look for trends in safety performance 8 and to see if we need to make adjustments to our I
9 inspection program as a result of recent trends in safety l
10 performance at the plant. i 11 That plant performance review then will result 12 in adjustments to our master inspection plan which we 13 maintain for each of the plants in a region where it's 4
n, 4 i/ 14 appropriate to make adjustments, and these adjustments can 15 be to either increase or decrease inspection, depending 16 upon the trends that are seen at the time.
17 That inspection plan then, once the 18 adjustments have been made, we take the inspections off of 19 the plan that are scheduled over the next eight months.
20 We put those into a letter, and we send those to the 21 licensee. So we give the licensee on the docket an eight-22 month look-ahead on the inspections that we have planned 23 for their facility, and where we've made adjustments to 24 the plan.
,q
! ,! 25 If those inspections are inspections that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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218 1 they've previously been informed of and they're continuing l
73 2 to be on the schedule, well, we just include those, but i
~
3 where we've made adjustments to the plan and we've added l 4 inspections, then we would tell the licensee the basis for 5 the adjustments that we've made.
6 MEMBER POWERS: Recently the NRC commissioned 7 an outside consulting agency to look at performance 8 indicators and trending that were done out of the senior 9 management meeting; came back fairly harshly critical. If 10 NRC were to commission this same group to come in and look 11 at your trending and indicators that you do for your 12 performance plan, would they be as equally critical?
13 MR. CHAMBERLAIN: In terms of our supporting
's 14 our PPR process?
15 MEMBER POWERS: Well, their essential 16 criticism was that the decisions to move plants onto a 17 watch list were made late, that the trending information 18 was there, but the decision to actually act on that 19 trending information came in long after it should have by 20 any other -- by any objective examination of the trends.
21 MR. GWYNN: I really hesitate to speculate as 22 to what the results might be. I'm certain that there 23 would be some criticism of our process in terms of its 24 transparency, you know, and in particular an outsider Ch (v) 25 looking in might find it difficult, because we don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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219 1 maintain real careful records as to the discussions that
, 2 occurred.
'-)
3 We have some records. We certainly have 4 discussion papers that are used, but where we get into a 5 level of detail that goes beyond those discussion papers, 6 we don't maintain transcribed minutes or anything along 7 those lines concerning the information that supports 8 decisions that were made.
9 So I'm sure that there would be some criticism 10 of the process. On the other hand, this is looking back 11 six months, and in this region, we actually do it more 12 frequently than is required. At this time, we're doing 13 quarterly plant performance reviews, and we do that for a N 14 specific reason.
15 We found that both the plant performance 16 review process and the SALP process were dominated in the 17 past by the division of reactor projects and the resident 18 inspectors, and that was a criticism that the industry l l
19 laid on the Agency, and in response to that, some time 20 ago, quite some time ago in this region, we made changes l 21 to our process, so that the division of reactor safety was 22 much more involved in both SALP and the PPRs that we 23 perform here.
24 But we -- during the initial process of
,,-~.
25
( ) getting our reactor safety division more involved in plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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220 l 1
1 1 performance reviews, we found a lack of ownership on the .
l l
2 part of the regional-based inspectors, and so we went to 7
t \
\'-)
3 quarterly plant performance review to gain more ownership, 1
1 4 and so the division of reactor safety is responsible for l l
5 the Q PPRs; the division of reactor projects is 6 responsible for the other plant performance reviews that l
7 we perform, and that's -- l l
8 There's another aspect that we implemented at 9 tha same time that I thought brought a lot more value to ;
i 1
10 the plant performance review. At the semi-annual plant 1
11 performance reviews that are on a schedule that's l 12 consistent with the senior management meeting cycle, we 13 vertically look at each plant by plant, so there is a
- n\
( ,/ 14 discussion by plant -- each SALP functional area is 15 discussed, and the division of reactor projects leads 16 that.
17 In the Q PPR, we don't look by plant. We look 18 horizontally across functional area, and so the DRS branch 19 chief -- we have an operations branch, a maintenance 20 branch, an engineering branch, and a plant support branch, 21 and so each of those branch chiefs look across all of the 2.7 plants in the Regio.. and talks about performance of the 23 plants in each functional area, one functional area at a 24 time.
l(,s)
\
25 And so that provides feedback to the projects NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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221 1 division as to where we really ought to be concerned, and
,sx
, 2 it helps to levelize the playing field, and it helps us in
'~'
3 our allocation of resources process, to make sure that we 4 really are putting our resources at the plants where the 5 problems are most. And this PPR approach has brought 6 value to this region in terms of making sure that our 7 resource allocations are appropriate for the plants.
8 MEMBER POWERS: Okay. Now, just a comment 9 that, of course, one of the criticisms of the senior 10 management meeting was that it was dominated by the 11 regional administrators. It sounds like maybe you've 12 taken care of one of the potential criticisms --
13 MR. GWYNN: Well, there's no question. The
(
k/ 14 senior resident inspector at one time certainly did 15 dominate SALP. I remember when I did my first SALP as a 16 senior resident inspector, I prepared all of the briefing 17 materials. I prepared the draft report. I was the one 18 that made the presentation at the public meeting to the 19 licensee. And so the senior resident inspector dominated 20 that process.
21 MR. CHAMBERLAIN: That's not fair. When I was 22 a senior, I wrote the report too. Now my deputy director l
23 and I have to write it.
24 (General laughter.)
g
( ,) 25 MEMBER POWERS: Who said it was supposed to be NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W.
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222 s
1 fair?
fs 2 MR. GWYNN: This is an evolving process, and I
/ i
\
'~'
/
3 anticipate that we will continue to get better, and in 4 particular, we need to get more efficient in our plant.
5 performance review process.
6 CHAIRMAN BARTON: Are you going to tell us any 7 secrets on SALP or everything we already know?
8 MR. GWYNN: Everything that you already know.
9 I think that what I would do is put up the very last 10 slide, which is our SALP matrix for Region IV. And this 11 is just a quick overview of what the SALP ratings have i 1
1 12 been for each of the plants in the Region. I 13 The most recent SALPs that we've done have l
['T r
l k 'j 14 been at Comanche Peak and Wolf Creek and Callaway. Those 1
15 are the three. most recent. We just recently finished the '
16 San Onofre SALP, but those results haven't been published I l
17 yet, and so they're not -- what you have is results from 18 18 months ago for San Onofre.
19 If there are any questions, I'd be pleased to 20 address those, and I apologize --
21 CHAIRMAN BARTON: Very informative.
22 MEMBER POWERS: Let me ask you one question.
23 I look at this matrix of the plants, and I said, They hold 24 engineering to a tighter standard than they're holding n
( ,) 25 everything else. Why shouldn't I draw that conclusion?
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223 l
l 1 MR. GWYNN: No. That's -- I think that what l
l 2 you're seeing there is in the past the Agency has put a
(<
s) 3 lot of time and attention in the operations area. We have 4 a lot of time and attention in plant support, a lesser 5 extent in the maintenance area. But engineering, we 6 didn't spend a lot of time, and we really didn't have all 7 of the expertise that we needed to assess engineering 8 programs.
9 A couple of years ago, we changed our approach 10 to engineering inspections. The Agency increased the 11 amount of time that was allocated to engineering 12 inspections, and when they did that, we changed our 13 approach. We went to a team inspection of engineering in
/ $
\ ~/ 14 this region, and as a result of using team inspections, 15 using outside contractors as members of our team, using 16 vertical slice approaches to the first week of the 17 inspection with a horizontal look across the engineering 18 organization based on the results of the first week during 19 the second week of the inspection, we became better 20 equipped to assess engineering performance at the plants.
21 And as a result of that, we've had some 22 problem areas identified, and we're focusing on those.
23 MEMBER POWERS: I think Millstone and Maine 24 Yankee helped to --
i
/ \
l ( ,) 25 MR. GWYNN: Actually, to be quite honest with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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224 1 you, these SALP category 3s, except for the Wolf Creek
?73 2 category 3, were in existence prior to Millstone. Yes,
') 3 sir.
4 MEMBER POWERS: Were prior to the Millstone 5 and Maine Yankee?
6 MR. GWYNN: And WNP-2, prior to their most 7 recent SALP, also had a category 3 in engineering.
8 CHAIRMAN BARTON: Dwight?
9 MR. CHAMBERLAIN: Our next presenter is Blair I 10 Spitzberg, division of nuclear material safety. He's )
l 11 going to be talking decommissioning and dry cask storage 12 activities.
13 CHAIRMAN BARTON: Is there some way you can
(_, 14 get through these slides in about 15 minutes?
15 DR. SPITZBERG: I'm glad to have the l
16 opportunity to be here. I think it's appropriate that I l 1
17 go near the end, because I'm going to be talking about the !
l l
18 latter stages of the nuclear fuel cycle here.
19 After all of my predecessors' hard work is l 20 over with and the plant is shut down, then they're 21 confronted with the problem of having to decommission the 1
22 plant.
23 By the way, my name is Blair Spitzberg. I'm 24 the chief of nuclear materials inspection and l l
/~N
( ) 25 decommissioning branch. I'm in the division of nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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225 1 materials safety and safeguards.
,s 2 Just to give you an overview, we have in this i
3 region probably a higher number of decommissioning 4 reactors, I think, than the other regions. These are the 5 particular sites, and a handout that you don't have in 6 your handout is a map showing the location of our 7 decommissioning projects.
8 And what I'll do since we're on an abbreviated 9 schedule here is I'll try and walk through some of these 10 sites and only focus on those where I think there's the 1
11 major activities ongoing at the present time or some areas l l
12 that I think might be of interest to you.
l 13 The Trojan plant is in Oregon. It's a four- l r~w s
~-
l 14 loop PWR plant that's in active decommissioning now as we 15 speak. It has had the large component removal is 16 completed, so that the pressurizer and the steam 17 generators, reactor coolant pumps have been removed. The 18 reactor vessel and internals remain on site.
19 As I mentioned, it's actively undergoing 20 dismantlement and decontamination, and they expect to 21 complete that by the year 2002. They're not going to be 22 taking down the structure by that time. It's not going to 23 be a green field, I think, until about 18 years later 24 under the current plans.
I ) 25 They have proposed that the reactor pressure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 226 1 vessel be buried as a single shipment at Hanford as i l
lI 7-2 opposed to cutting up the reactor vessel into pieces and l \ ]
l 3 shipping them separately, and I'm going to come back to 4 that.
5 They have started the construction of a dry 1
6 fuel storage pad on site. I'm going to be up at Trojan 7 just next week, because they're going to be pouring the l l
8 concrete pad, and we're going to be looking at that.
9 MEMBER POWERS: I just can't resist asking why 10 in the world anybody would want to bury the Russell and !
11 Hanford -- why in the world, more precisely, why in the l l
12 world Hanford would want anybody to bury their vessel at l I
13 Hanford.
\_j 14 DR. SPITZBERG: Well, that's a good question, )
1 15 although I think it's not too dissimilar from the l
16 submarine reactor compartments that they're burying 17 routinely up there. I 1
18 By the way, let me -- before I forget, let me l 19 introduce Vince Everett over here, who's among my group, 20 and he's the lead decommissioning inspector and spent-fuel 1
21 storage project inspector for me. And I brought him along l 22 not only because he helped prepare most of these slides, 23 but also because hopefully he'll be able to answer 1
24 questions that I can't. l l
/'N '
l Ix_./) 25 As I mentioned, currently under review is an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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227 1 application submitted by Trojan to transport the reactor
,s 2 vessel filled with low density concrete to the Hanford
( )
3 site for burial as a single shipment, as opposed to the 4 alternative which is to cut the reactor into 54 segments 5 and ship via highway 6 The licensee has noted in their application 7 several savings in addition to just the monetary saving is 8 that it is a considerable exposure savings to not only the 1
9 plant personnel but also to the transportation personnel 10 as well as members of the public. It's a little bit -- l 11 not quite as significant.
12 But just, for example, the savings in dose to 13 the plant workers is expected to be -- well, if they ship
/3 i )
's_/ 14 intact, it's expected to be about 67 person rem versus 154 15 person rem if they have to cut it up.
16 In addition to that, the state of Washington 17 and the State of Oregon have gotten behind this request, 18 and at this point, have shown pretty strong support for 19 it.
20 Part of the problem with this request, as I 21 understand it is that in order for it to be shipped as a 22 type B package, there will have to be granted an exemption 23 to certain requirements of the type B certification 1
i j 24 process, and so I think this is the major technical hang-
/ h
( ) 25 up with the NRC. I don't know how that would be resolved.
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228 1 Before I leave Trojan, let me also mention one
,f x 2 other thing that we're going to be looking at next week
( )
3 and that is that they have a project that they're going to 4 be initiating in the next f et. weeks where they're going to 5 he burning some of the organic filters that have been used 6 to clean up some of the fuel debris in their systems.
7 And they have a process reformer project that 8 has been proposed where they're going to be actually 9 burning the organic material from these filters, so that 10 the residual activity can ce placed into dry storage on 11 site, and they have to eliminate the organic materials so 12 that they won't have a source term for gas generation in 13 the ISFSI.
/"'N, t ;
's / 14 Okay. Rancho Seco, I'm not going to spend 15 much time on this. This is a PWR, a Babcock & Wilcox 16 plant that operated from 1975 to 1989. It's currently in 17 a safe stcrage status.
18 MEMBER KRESS: I'm just curious. What kind of 19 organic filters?
20 DR. SPITZBERG: These are rubber filters that 21 were part of the -- as I understand it. there was some 22 fuel degradation that occurred in the past operations of 23 Trojan, and they did get seine fuel debris and particles 24 into their systems, and in order to clean up this, they (n) 25 passed the debris through filters which had some gaskets, NEAL d . GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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229 1 rubber organic gaskets, as part of the filters.
-s 2 And before they can put these filters with the
/ %
\' ,)
3 debris into dry storage, they have to eliminate the gas-4 generation potential of the organics.
5 Ranche seco is currently in SAFSTOR status, j l
6 although they have got some limited dismantlement l 7 activities underway in the turbine building; very low 8 potential for having to deal with contamination problems 9 at this point.
10 They expect to make a decision within a year 11 or so as to what the future pace of their decommissioning l
12 is. They have completed construction of an ISFSI on site. i l
i 13 They've completed the concrete storage module, but they l
(~)N
(,, 14 have not yet fabricated the storage baskets that will be l 15 used to house the fuel. The fuel is still in the spent-l 16 fuel pool. l 17 One of the reasons for this is because, as 18 you're probably well aware, there's been some concerns i i
19 with both the major spent-fuel storage vendors. Their i
20 vendor happens to be the Vector NUHOMS system, and there's !
21 some quality asourance concerns that are being addressed 22 now that has delayed the construction of their storage 1
23 basket.
24 Moving on to Humboldt Bay is an early design f i 25 of a BWR. It's located in Eureka, California, which is in
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230 l
1 a seismically active area. It operated from 1963 until '
l
~x 2 1976. This reactor is located in a subsurface caisson,
/ i
\ t 3 right on the coast, and it is in a SAFSTOR status with no 4 decommissioning or decon work going on except for some 5 work that is associated with some investigation and repair 6 work on the caisson. !
7 This is a depiction of the ractor caisson 8 here. One of the issues we've been dealing with over the 9 past several months ir that there has been an increase in 10 the rate of groundwater in-leakage into the reactor 11 caisson.
12 As noted on the next slide, the in-leakage in 13 1992 was between about 100 to 150 gallons per day. It
\_j 14 went as high as about 10,000 gallons per day within the 15 last year, and it's currently running about 7,800 gallons 16 per day.
17 If you put back the diagram, where they think 18 this in-leakage is coming in is if you look at the joint 19 in the base mat of the caisson and the suppression 20 chamber, they believe it's coming in in that general area.
21 The leakage is accumulating in a sump area of the caisson 22 and is being continuously pumped out.
23 Early on, they were detecting some low levele 24 of contamination in this water. They investigated and
', ) 25 determined that the contamination was coming from plant NEAL R. GROSS i
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i l
231 l 1 systems such as the sump and the sump grates that were !
i
,- 2 contaminated, so they -- about a year ago, they initiated
( ) l 3 a project to clean that up, and currently the water that's i 4 being pumped out of the caisson is below any tech spec 5 limits for release, and they're able to discharge it 6 directly into the canal.
7 They do have a process monitor on it, so they 8 are continuously monitoring it.
l 9 San Onofre, it is a PWR that operated until --
l l
10 from 1968 until 1992. It's in a SAFSTOR status. There's i
I 11 very little activity ongoing there from a decommissioning 12 standpoint. We were out there a couple of weeks ago.
13 Things are pretty quiet.
,, l
' _/
'x 14 Last summer we did have to deal with some 1
15 concerns expressed by members of the public over a spent l l
16 fuel pool leak that was discovered in 1986 and was 17 subsequently repaired, but nevertheless the spent fuel 18 pool now is showing very low leak rate, about 3 gallons 19 per week.
20 Fort St. Vrain, located in Colorado, this 21 plant is under the project management of NMSS as opposed 22 to the other plants that are under NRR project management.
l 23 It's a high-temperature gas-cooled reactor. The fuel is 24 in dry storage currently.
()
p.- .
25 There is a license termination letter is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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232 1
1 currently with the Commissioners, and we expect that if l
-~ 2 they concur in this letter, that this license will be --
7 V) 3 the 50 docket license will be terminated in the near term, 4 probably over the next month or two.
5 The other interesting aspect of Fort St. Vrain 6 is that the spent-fuel storage installation there is 7 being -- in the process of being transferred to the 8 Department of Energy under prior contractual arrangements 9 with Public Service of Colorado, and there is a pending 10 license application under review now with the NRC for that 11 transfer. And so we have been engaged in some 12 prelicensing inspections of the DOE to evaluate their 13 readiness to accept the transfer of this facility.
g
-- 14 MR. LARKINS: Are they going to leave that 15 fuel there for a while? Is that the current plan?
16 DR. SPITZBERG: That's the plan. Originally 17 the fuel was going to go back to INEL, but I understand 18 that that's not being considered at this time.
19 The last plant I'll just mention briefly is 20 Vallecitos. It's early G.E. test reactor in California, 21 and it's in long-term SAFSTOR, very little activity going 22 on site, and they have no immediate plans to go into 23 active decommissioning.
24 Let me just kind of go through a list of (O
v) 25 problem areas that we've been dealing with in the reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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233 l
1 decommissioning arena, and if you like, I can go into more l
l
,x 2 detail about them, but unless you have any specific kv) 3 questions, I'll just go through them quickly.
4 We've been seeing problems at most of our j 5 sites at one point or another with free-release surveys, 6 and part of the problem with free-release surveys stems 7 from the human factors part of doing repetitive surveys of 8 material that you receive and expect to be free of 9 contamination.
10 We've also had some issues at plants involving 1
11 paperwork discrepancies, doctoring of paperwork, l 12 instrument sensitivity issues, and while free-release 13 surveys, a problem in that area does not necessarily n
, i Nl 14 represent a significant risk to the public, it can be a 15 very flammable issue when it comes to public perception of l
16 what the decommissioning process entails.
17 MR. CHAMBERLAIN: Let me ask for a second.
18 Were you going to talk about dry cask storage?
19 DR. SPITZBERG: Yes.
20 MR. CHAMBERLAIN: Are you interested more in 21 that? Do you want to get a few minutes on that? I don't 22 know how tight your schedule is.
23 CHAIRMAN BARTON: Pretty tight.
I 24 MR. CHAMBERLAIN: Let me ship this and maybe
(~s
(,) 25 just quickly, two or three minutes, talk about dry cask NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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234 1
1 storage. Will that work? l
,_, 2 DR. SPITZBERG: That's fine. j
\
i>
~'
3 MR. CHAMBERLAIN: Let's do that. !
4 CHAIRMAN BARTON: It's not a lack of interest .
i 1
l 5 in this. It's --
l 6 DR. SPITZBERG: I understand. Let's go to the 7 dry cask storage. We currently have two facilities where 8 we have -- oh, this is a graph that is not in your handout 9 that I want to put up to illustrate the nature of the !
1 10 problem that's going to be confronting us on dry storage 11 of spent fuel is that if you look at this graph, we're 12 just at the low end of what looks to be an exponential 13 power curve on the need for spent-fuel storage capacity
(~
'w_,- 14 above and beyond the spent-fuel pools at this country's 15 operating nuclear power plants. l 16 You see it starts to go into an exponential 17 power curve about the year 2000 and shoots straight up 18 from there, and we're in 1997, so I just wanted to put 19 this up to illustrate the nature of the problem we're 20 faced with.
21 I think I mentioned the two -- that we have z2 two ISFSIs that currently have casks that are loaded.
23 This is a diagram that shows where our current or future 24 ISFSIs that we know about are going to be located, and
[)
v 25 obviously I think there will be more beyond this.
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235 1 Currently we have Arkansas Nuclear One as an
,- 2 ISFSI in operation as does Fort St. Vrain as I mentioned.
I i 3 I won't go over the plants that are proposing ISFSIs in 4 the near term.
5 Let me move on to ANO. You may be familiar 6 with some of the problems that have been surfacing with l
I 7 dry fuel storage in the recent months. ANO has been in 8 the center of some of this, not from any problems that are 9 unique to that utility, but more with problems that are 10 related to the dry fuel storage systems themselves.
1 l
11 ANO is currently under a confirmation of l l
i 12 action letter that causes them to investigate the nature l 13 of some weld cracking phenomenon that has been observed at gs I
(/ 14 ANO and other plants.
15 What happens is that the -- if we have -- do 16 we have a diagram of the ANO cask? This shows the cask 17 system in the concrete cask, but the problem that has been 18 occurring at ANO and Palisades involves cracks on the 19 shield lid which is the lower of the upper lids there on 20 the multi-assembly sealed basket.
21 And thele have been cracks that have formed l
22 after welding of this shield lid on two casks at ANO and 1
l 23 one at Palisades, and currently there is an intensive 24 effort ongoing with the vendor, the users, and the NRC to r'N.) determine what the cause and corrective actions necessary
- 25 w/
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l i
236 !
1 for this weld cracking phenomenon are. l l
7s 2 I don't know how much detail you want me to go l
()
3 into on that. I'm more than willing to elaborate.
i 4 MEMBER SHACK: What's the material that the 5 weld --
6 DR. SPITZBERG: This is carbon steel. l 7 MEMBER SHACK: What's the general nature of 8 the -- it's hot-cracking during the weld?
9 DR. SPITZBERG: Well, the cracking has 10 occurred at ANO during the repass and during the final 11 pass on the rhield lid weld. At Palisades, was it the 12 repass? And one of the concerns that we have is that our 13 expert has said that there is some evidence that it could i r~ s
! ) i km./ 14 be caused by hydrogen cracking. )
15 And hydrogen cracking has a phenomenon 16 associated with it which is unsavory for long-term storage 17 of fuel in that the cracks can occur in a delayed fashion, i l
18 up to a year after the weld, so theoretically if it is 19 hydrogen cracking, you could complete the weld, test the 1
20 weld, and have it pass the tests, only to have the crack 21 form at some later date.
22 So that's one of the concerns that is being j 23 investigated, to see whether or not it is hydrogen 24 cracking or delayed cracking as a potential.
(~m.
( ~/ ) 25 Let me move on to just the TMI fuel, because I l
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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a 237 l 1 wanted to -- if you could move over to the DOE TMI-2 fuel, 7s 2 we have a license application that's under review right 1 i 8 l
\~) 3 now from the Department of Energy for a dry-fuel storage
)
4 installation at Idaho National Engineering Laboratory, to 1 5 house the TMI-2 fuel debris.
6 This fuel debris is in various forms, anywhere .
l l
7 from intact fuel assemblies to fuel elements to fuel 8 debris and dust, and so there's three different types of 9 canisters. I've given you the diagram for the three types j 10 of canisters that are proposed for use.
i 11 One of the unique features of the TMI dry-fuel 1
l 12 storage, however, is that it will use commercial design by l
13 NUHOMS, but it will be a ventilated cask to allow for the
~~s
- )
\/ 14 escape of radiolysis gases from the fuel debris, which is l l
15 in contrast to the loss of sleep that we've had over the ,
16 weld cracks at ANO. l 17 If we go to the last slide, I'll just close up 18 with some of the problem areas that we've been seeing in l
19 the dry-fuel storage area, the welding of the lid, 20 hydrogen generation from the coatings. You're probably 1
21 aware of the issue involving chemical reactions between 22 the boron and the spent-fuel cooled water and the coatings 23 of the casks that lead to hydrogen generation and, in 24 fact, led to hydrogen emission event at Point neach; A
! 1 25 documentation of safety reviews, experience in loading and w/
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238 1 moving casks, and the upgrading of the crane capacities at l
,s
- 2 many of these facilities.
t V 3 So that's the speed record for going through 4 all these slides.
5 CHAIRMAN BARTON: Forty slides in 12 minutes; 6 that's pretty darn good. Sorry we had to rush you through 7 this part of the presentation, 8 DR. SPITZBERG: These will come in handy 9 another time, I'm sure.
10 MR. CHAMBERLAIN: I believe that wraps us up.
11 I did want to thank Laura Hurley for doing our slides 12 today. She wasn't expecting to have that job today, but 13 she --
/~N i )
's '
14 CHAIRMAN BARTON: She did very well.
15 MEMBER POWERS: This issue of sealing up fuel 16 into a cask and what goes on inside that cask, hydriding, 17 clad, forming hydrogen, producing gas, pressurization and 18 things like that -- it just seems to be a conundrum to me.
19 I just don't see how we can seal things up.
20 DR. SPITZBERG: Well, there's also a problem, 21 I think. Obviously there's -- we understand the problems 22 that DOE's been having in trying to get a permanent 23 repository, but we're going to find ourselves before long 24 with 100 high-level spent-fuel storage facilities in this
/^%
kj 25 country. Most of them are going to be sitting out next to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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239 1 our interstate highways for everybody to see, f~s 2 MEMBER POWERS: You might understand those t' )
3 problems. I don't understand their problems.
4 MEMBER KRESS: But I agree with Dana. We 5 really ought to leave them vented, I think.
6 MEMBER POWERS: Well, I just don't -- we 7 stored some fuel at Hanford, and lo and behold, now you 8 don't know what -- they have to get it out. I don't want 9 to open those casks for love nor money, because I know 10 that clad is very well hydrided, and it bursts into flame 11 as soon as I bring it out. It's just awful stuff to work I 12 with.
13 DR. SPITZBERG: That's the same type of
,e y
, e
, \m) 14 cladding that commercial -- 4 15 MEMBER POWERS: It's a uranium zirconium 16 excreted fuel, quite unlike commercial fuel, and it i i
17 hydrides very well, aggressively, and a little bit of 18 moisture goes a long ways, and here we've sealed it up. ;
19 It's nicely hydrided. You open that up; you get a fire. y 0
20 I mean, there's no two ways about it.
l i
21 Your problems in sealing up may not be nearly ;
22 as bad with commercial fuel, but you've still got -- I !
23 mean, you're radializing water to create these aggressive 24 oxidants and reductants. They're going to do their thing.
f3
( ,) 25 And that thing's usually bad.
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240 1 And so I just don't understand how you can s 2 seal things up. I mean -- burn it in the reactor. That's
~
3 the only answer to the problem. Keep the plants running.
l 4 Recycle that sucker. !
5 CHAIRMAN BARTON: Ellis, in closing, I want to l 6 thank you on behalf of the committee, thank you and your 7 staff for putting on a very informative day. I think we 8 learned an awful lot, have some appreciation for Region IV 9 and why Region IV is as well respected as it is.
10 I think you've got a lot of good people and 11 some good programs going here that we don't see. It seems 12 to be a forward-looking, aggressive region.
13 MR. MERSCHOFF: Well, thank you. The staff rm
( )
K/ 14 really worked hard on this, and I hope that it's provided 15 you the information you needed. We were a little 16 disjointed with people coming in and out, but it was just 17 due to the --
18 CHAIRMAN BARTON: It worked out fine; it 19 really did.
20 MEMBER SEALE: I was very pleased to hear some 21 of your reactor safety engineers mention that they had 22 managed to stick their heads in to some of our meetings 23 sometimes when they were back in Washington on rotation, 24 and certainly anytime anyone from Region IV is there while
( ,/ 25 we're meeting and they have an opportunity to come in, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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241 1 we'd be very pleased to have them look over our shoulders
,s 2 and so on, and say hello to us.
I V;
3 MR. MERSCHOFF: I'll pass that on to the 4 staff. It's useful to see how committees like this work 5 and the kinds of questions they ask, because you don't 6 want to learn that the first time when you're up there 7 trying to --
8 MEMBER SEALE: Well, and we appreciate the 9 fact that it helps humanize the interactions between the 10 groups, and that's important, too.
11 MEMBER POWERS: Well, I think they probably 12 did themselves no good service by the show that they put 13 on for us, because now we'll want to come back and see how r^x f 1
\_/ 14 some of these programs develop and what not, so they have 15 to put up with us again.
16 MR. MERSCHOFF: You're more than welcome here 17 in Region IV. We actually execute the programs that we 18 talk about. It's gone on for a long time. I've just 19 inherited --
20 CHAIRMAN BARTON: We want to think Linda 21 Osling and the administrative staff, because we know 22 without her work, none of this would have went as well as 23 it did go. Thank you.
24 (Whereupon, at 3:05 p.m., the meeting in the f's ,, 25 above-entitled matter was concluded.)
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l
/~ l
()T CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: I Name of Proceeding: ACRS SUBCOMMITTEE ON PLANT OPERATIONS /-FIRE PROTECTION Docket Number: N/A )
Place of. Proceeding: ARLINGTON, TEXAS ;
l were held as herein appears, and that this is-the original transcript thereof for the file of the United State's Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
As ~
o,
~~
9 ~~
'I'BERBARA J.' NA'LL Official Reporter Neal R. Gross and Co., Inc.
t -
v NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, NW (202)234-4433 WASHINGTON,D.C. 2000$ (202)234-4433
- - . _ _ . . _ _.._m .- _ . . _ - _ . - - . . . _ . _ . _ _ _ . - _ .. ___ ._
O INTRODUCTORY STATEMENT BY THE CHAIRMAN OF THE PLANT OPERATIONS AND FIRE PROTECTION JOINT SUBCOMMITTEE NRC REGION IV OFFICE 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TX JULY 18, 1997 The meeting will now come to order. This is a' meeting of the ACRS Joint Subcommittees on Plant Operations and Fire Protection.
I am John Barton, Chairman of the Subcommittee for Plant Operations, Dr. Dana Powers is the Chairman of the Subcommittee for Fire Prote,ction.
The ACRS Members in attendance are:
_.Geerge ";cctolahie, Mario Fontana, Thomas Kress, Don Miller, Robert Seale, and William Shack.
The_ purpose of this meeting is to discuss Region IV activities and other items of mutual interest, including significant operating events and fire protection issues. The Subcommittee will gather p information, analyze relevant issues and facts, and formulate Q proposed positions and actions as appropriate, for deliberation by l the full Committee. l l
Amarjit Singh is the Cognizant ACRS Staff Engineer for this meeting.
The rules for participation in today's meeting have been announced as part of the notice of this meeting previously published in the 3 Federal Register on June 17, 1997. I A transcript of the meeting is being kept and will be . made available as stated in the Federal Register Notice. It is requested that the speakers first identify themselves and speak with sufficient clarity and volume so that they can be readily heard.
We have received no written comments or requests for time to make oral statements from members of the public.
(Chairman's Comments-if any)
We will proceed with the meeting and I call upon Mr. Ellis Merschoff, Region IV Administrator, to begin.
I g$8 K88 Og UNITED STATES t NUCLEAR REGULATORY COMMISSION 8 o g $ REGloN IV 611 RYAN PLAZA DRIVE,SulTE 400
'g+9 S'8 AR LINGToN, TEXAS 76011-8064 I
June 26, 1997 RN 0119 - REGION IV MEETING WITH ADVISORY COMMITTEE ON !
REACTOR SAFEGUARDS (ACRS) SUBCOMMITTEE ON l PLANT OPERATIONS AND FIRE PROTECTION EFFECTIVE: Upon issuance CONTACT: L. A. Yandell
- DATE CANCELLED
- July 21,1997 DISTRIBUTION: Standard plus cc SUPERSEDES - N/A
/s/ Ellis W. Merschoff APPROVAL: I Ellis W. Merschoff, Regional Administrator j
A. Puroose/ Discussion i This Notice promulgates the agenda and assigns responsibility for the public ACRS subcommittee meeting in Region IV on Friday, July 18,1997, in the Training Conference Room on the 4th floor.
1 B. Action Personnel assigned responsibility in the attached agenda are requested to complete l
. their assigned tasks. The subcommittee will be visiting Comanche Peak on l 1 Thursday, July 17,1997. !
Attachment:
As stated I cc: l A. Singh, ACRS 4 RIV Coordinator, OEDO i
DOCUMENT NAME: R:\_RON\RN0119.DRP To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:C:DRP/ISS l PA0 l D:DRP l D:DRS l D:DNMS l LAYandell:df BWHenderson TPGwynn ATHowell RAScarano 6/ /97 6/ /97 6/ /97 6/ /97 6/ /97 DRA RA JEDyer EWMerschoff 6/ /97 6/ /97 0 0FFICIAL RECORD COPY
3 1 j '5 ,y f- MEETING AGENDA ACHS VISIT TO REGION IV JULY 18,1997 !
8:00 a.m. Opening Remarks John J. Barton Subcommittee Chairman l -
8:10 a.m. Introduction E!!is W. Merschoff i Regional Administrator 8:20 a.m. Region IV Organization Jim Dyer l
Organization & Responsibilities Deputy Regional Administrator I
Unique Aspects of Region IV 9:20 a.m. BREAK 9:35 a.m. Panel Discussion:
Activities for Maintaining Jim Dyer Uniformity Among the Regions (JD) Deputy Regional Administrator O- Current and east issues (AH)
Wolf Creek FrazilIce Event T. Pat Gwynn, Director Ft. Calhoun Extraction Steam Division of Reactor Projects j Line Break Event -
Fire Protection Issues Arthur T. Howell, Director Staff Training and Development (JD) Director of Reactor Safety interface with INPO (PG) 11:45 a.m. LUNCH 12:30 p.m. Senior Reactor Analyst Program Arthur T. Howell, Director Risks of Online Maintenance Division of Reactor Safety 1:20 p.m. BREAK i
1:35 p.m. Status of Plant Operations T. Pat Gwynn, Director
! SALP Program & Region IV Ratings Division of Reactor Projects Resident inspactor Program Master inspection Plan j Plant issues Matrix (PIM) b
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2:20 p.m. Decommissioning D. Blair Spitzberg, Chief Dry Cask Storage Materials inspection Branch 2:50 p.m. Closing Remarks John J. Barton Subcommittee Chairman i
3:00 p.m. ADJOURN l
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NRC REGION IV
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Arlington, Texas VISIT OF THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS JULY 18,1997 L .. . . . . . . . _ . . . . . .
O O O REGION IV l MAJOR REGULATED FACILITIES
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O Uranium Fuel Fabrication Facility (2)
Cur...oido: Reactors licensed to operate (21)
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$ Nonpower Reactors licensed to operate (20) i . - - -.- --- -- ------.-__--_--_-_-- -- __ _ _ _ _ _ _ _ _ __
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Region IV Data Number and Types of Licenses
- 14 Power Reactor Sites 21 Operating Power Reactors 2 Power Reactors in Construction (mothballed)
- 20 Research and Test Reactors
- 2 Uranium Fuel Fabrication Facilities
- 1,241 Byproduct Material Licenses
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(, V V REGION IV July 17,1997 .
REGIONAL ADMINISTRATOR DEPUTY REGIONAL ADMINISTRATOR I I I I l .
l DIVISION OF RESOURCE DIVISION OF NUCLEAR DIVISION OF REACTOR DIVISION OF REACTOR l MANAGEMENT i MATERIALS SAFETY SAFETY ; PROJECTS AND ADMINISTRATION
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!.__________________. WALNU CREEK FIELD .___________[_____________________________! ,
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OFFICE OF THE REGIONAL ,
1 ADMINISTRATOR l
F OFFICE OF THE REGIONAL g ADMINISTRATOR !
I Admistrator: E. W. MERSCHOFF l Deputy: J. E. DYER i M j OFFICE OF INVESTIGATIONS ,
INCIDENT RESPONSE CENTER ==o 4
Field Office Director: E. L. Williamson j l l l-l PUBLIC AFFAIRS REGIONAL COUNSEL STATE LIAISON ENFORCEMENT AND INCIDENT RESPONSE OFFICER OFFICER ALLEGATION COORDINATOR COORDINATION B. W. Henderson W. L. Brown C. A. Hackney M. F. Hammond twCFO) G. F. Sanborn E F Bater D. M. KunihirO (WCFO) R. Wise
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1 DIRECT SUPERVISION
= = = = = = = - COORDINATION
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- 7. P. Gwynn, Director Kenneth E. Brockman, Deputy Director Lucy Thomas, Div. Sec*y Deruse Freeman, Sec'y (PB-8, C TS)
Coneen Mumahan, Sec'y (PB-A, C5 I I I I REACTOR PROJECTS BRANCH A REACTOA PROJECTS REACTOR PROJECTS REACTOR PROJECTS BRANCH B BRANCH C BRANCH D J. Tapis, Chief Ron Kopnva, SPE B. Johnson, Chief E. Conins, Chief P. HarreN, Chief John Edgerty, PE David Graves, SPE Charles MarschsN, SPE Greg Pick, PE Ray Azua, PE Brad Smauridge, PE Greg Werner, PE CPSES Greg Womer Ecs CMS WAT-1 Harry Freeman Wayne Walker Mary Minor Lee Keller Vonna Ordaz vincent Gaddy Chns Skinner David Prodx Rebecca Nease Nancy Curley, SOA Shwiey Neddennep SOA Pat Smith, SOA Caroie Austin, SOA WC ARQ SIE Fred Rangwald Knss Kennedy David Loveless Brad Smantidge (10/97) Steve Burton Jack Keeton Shirley Auen SOA Jim Melfi Wayne Sifre Vicki High, SOA Lenora Reyna, SOA CAj, Dave Passehl Frank Brush Dawn Yancey, SOA I I I I WALNUT CREEK FIELD OFFICE REACTOR PROJECTS REACTOR PROJECTS REACTOR PROJECTS TECHNICAL SUPPORT (WCFO) BRANCH E (WCFO)* BRANCH G (WCM) STAFF BRANCH F (WCFO)*
INTE: 2/28/981 K. Perkins, Director L. Yandett, Chef H. Wong, Chief D. Kirsch, Chief Gary Johnston, PE Dyfe Acker, SPE R. Huey, Cheef Ray Azua, PE Maunne Smith. Sec"y Brad Olson, PE Dave Corporandy, Temp PE LO' ens Winiems Karen Hunko. OSA SONGS (NTE: 2/28/98)
JoAnn Hooker, OSA WNP-2 Jim Sloan Jo Bianche, Sec'y Scott Boynton John Russes BB George Replogie Jchn Kramer Ward Smith Helen Brownell, SOA Stefani Neidholdt, SOA David Proulx Pat Smith, SOA QC Of M,ke Tscniltz (Vac 7/97) Frank Brush (Act) G.Ca Don Anon Dan Carter J. Dixordiomty Vacant Vacant Kathy Weaver Jean Gaass, SOA Nancy Salgado Mary Jane Spivey, SOA Tarnmy Buchan, SAO 06/20197
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O O O MAJOR FUNCTIONAL :
RESPONSIBILITIES i
OF DRP:
i O COORDINATION OF THE OVERALL i
! NUCLEAR POWER PLANT INSPECTION PROGRAM AT NUCLEAR POWER SITES O MANAGEMENT AND IMPLEMENTATION OF THE RESIDENT INSPECTION PROGRAM O COORDINATION OF THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) PROGRAM i
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DIVISION OF REACTOR SAFETY.
A. T. Howell,111, Director D. Chamberlain, Deputy Director I. Barnes - Technical Assistant J. Shackelford, SRA W. Jones, SRA Cheryl Goines, Sec'y Lynn Berger, Sec'y Vacant, Sec'y ENGINEERING BRANCH MAINTENANCE BRANCH OPERATIONS BRANCH PLANT SUPPORT BRANCH (5th Floor)
D. Powers, Chief -
C. VanDenburgh, Chief Cliff Clark (WCFO) J. Pellet, Chief B. Murray, Chief Bill Ang (WCFO) Lee Ellershaw Laura Hurley Tom Andrews Paula Goldberg PaulGage Howard Bundy Tom Dexter Dave Periera (WCFO) Claude Johnson Ryan Lantz Bruce Earnest Mike Runyan Bill McNeill Steve McCrory Gail Good Linda Smith Chuck Paulk Tom McKernon Gilbert Gurerra Tom Stetka John Whittemore Tom Meadows Michael Hay Bill Wagner Mike Murphy Blair Nicholas Larry Ricketson Dennis Schaefer Michael Shannon 06/20/97
O O O MAJOR FUNCTIONAL
, RESPONSIBILITIES OF DRS:
l O CONDUCTING ENGINEERING / SAFETY INSPECTIONS AT OPERATING NUCLEAR POWER PLANTS 91MPLEMENTATION OF SPECIAL SAFETY INSPECTIONS IN RESPONSE TO OPERATIONAL EVENTS O ADMINISTRATION OF REACTOR OPERATOR LICENSE EXAMINATIONS O CONDUCTING HEALTH PHYSICS, RADIOLOGICAL EFFLUENT AND CHEMISTRY CONTROL INSPECTIONS O CONDUCTING PHYSICAL SECURITY AND EMERGENCY PLANNING LICENSING '
& INSPECTIONS
... - ~. .. -- . . . -. - . _ - - . .. . . .-
.SPECIAL TEAM JSPECTIONS e
SAFETY SYSTEnn FUNCTIONAL INSPECTION OPERATIONAL SAFETY TEAM INSPECTION MAINTENANCE TEAM INSi UCTION REGULATORY EFFECTIVENESS REVIEW QUALITY VERIFICATION FUNCTIONAL INSPECTION SAFETY SYSTEM OUTAGE MO:'IFICATION INSPECTION EQUIPMENT QUALIFICATION FIRE PROTECTION PROBABILISTIC RISK ASSESSMENT EMERGENCY OPERATING PROCEDURES AUGMENTED INSPECTION TEAM ELECTRICAL DISTRIBUTION SYSTEMS FUNCTIONAL INSPECTION i
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DIVISION OF NUCLEAR MATERIALS SAFETY R. Scarano, Director L. Howell, Acting Deputy Director Vacant, Technical Assistant J. Hornor, SAO(WCFO)
Vaca:t Div. Sec'y Nancy Hodges, Branch Sec'y Wanda Warren, Branch Sec'y NUCLEAR MATERIALS NUCLEAR MATERIALS MATERIALS BRANCH I
LICENSING BRANCH INSPECTION AND FUEL (WCFO)
- CYCLE / DECOMMISSION!NG C. Cain, Acting Chief BRANCH F. Wenslawski, Chief Vivian Campbell Dave Skov Jack Whitten D. B. Spitzberg, Acting Chief Beth Prange lackie Cook Bob Brown Jim Montgomery Lou Carson Mark Shaffer Joan Garcia Vince Everett Jeffrey Cruz Emilio Garcia Tony Gaines Bob E,<ans Kent Prendergast Christie Hernandez Richard 1 onardi Chuck Hooker Billie Gruszynski Bill Radcliffe Dean Chaney Linda McLean Judy Gartner, Sec'y 06/20/37
O MAJOR FUNCTIONAL e O RESPONSIBILITIES OF DNMS: .
t 9 MATERIAL LICENSEES *
- INSPECTIONS
- LICENSING S FUEL FACILITIES OVERSEE INSPECTIONS IN ALL AREAS i
- OPERATIONS / CRITICALITY CONTROL
- SECURITY ,
- RADIATION PROTECTION 9 URANIUM RECOVERY FACILITIES INSPECTION e DECOMMISSIONING OF ALL FACILITIES INCLUDING POWER REACTORS 9 AGREEMENT STATE PROGRAM t
. _ . . _ . . _ . . . _ . . . - . _ _ _ _ _ . _ - - . _ . . _ . . . - - - . . . . _ _ _-_ . . = . . . .
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DIVISION OF RESOURCE MANAGEMENT 1 AND ADMINISTRATION i K. Hamill, Director t
Carol Hill, Sec'y t
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PERSONNEL STAFF RESOURCE MANAGEMENT ADMINISTRATIVE BRANCH MANAGEMENT BRANCH K. League, RPO Joseph L. Lopez P. Krayer, Chief L. Ousley, Chief Connie A.Lano Yvonne S. Elko Debby Bacon Wanda L. Forns Caro Bartley Nancy Holbrook Robert Carpenter -
Dean Papa Glenn A. Ewald Michael Phillips 14 thy Gardin l Susan Pierard Judy Kilcrease Sandy Lindsay - Phil Longdo ;
i Stacey Rosenberg Jody Talbot i Arnold Wieder i
Contractors :
Jamye Prince Lanell Allen l James Buchanan 06/20/97
O O O MAJOR FUNCTIONAL RESPONSIBILITIES OF DRMA:
O MANAGING THE REGION'S RESOURCES:
O DEVELOPING AND EXECUTING THE BUDGET O COORDINATING LICENSE FEE INFORMATION O MANAGING REGIONAL TRAVEL O MANAGING ACCOUNTABLE PROPERTY O MANAGING PROCUREMENT AND CONTRACTING O MANAGING FINANCIAL ACCOUNTING G HUMAN RESOURCE MANAGEMENT O RECRUITMENT AND STAFFING O EMPLOYEE BENEFITS AND DEVELOPMENT O LABOR RELATIONS 9 MANAGING INFORMATION TECHNOLOGY O NETWORK ADMINISTRATION AND SECURITY O USER ASSISTANCE," HELP DESK" O UPGRADES AND EQUIPMENT REFRESH O COORDINATING COMMUNICATIONS INCLUDING VOICE, DATA AND VIDEO CONFERENCING O MANAGING THE MAIL, FILE AND LIBRARY SERVICES j i
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O O o ACTIVITIES FOR MAINTAINING UPJIFORMITY AMONG THE REGIONS ;
AGENCY WIDE-ACTIVITIES IMPROVED AGENCY TRAINING PROGRAMS j e FUNDAMENTALS OF INSPECTION AND CONTINUING REFRESHER :
e RISK ASSESSMENT TRAINING FOR INSPECTORS AND SUPERVISORS i PROGRAM OFFICE GUIDANCE j i
e INSPECTION PROGRAM GUIDANCE !
e INSPECTION PROCEDURES & TEMPORARY INSTRUCTIONS e TASK INTERFACE AGREEMENTS e PLANT PERFORMANCE REVIEWS e RECENT IMPROVEMENTS TO THE SMM PROCESS t
i PROGRAM OFFICE COORDINATION & OVERSIGHT e SPECIFIC INSPECTION PROGRAM MANAGERS S AUDITS / ASSESSMENTS OF REGIONAL OPERATIONS l
O PERIODIC COUNTERPART MEETINGS 9 SALP OBSERVATION PROGRAM / FEEDBACK l l
ENFORCEMENT COORDINATION AND OVERSIGHT ;
I e ENFORCEMENT MANUAL e . REGIONAL ENFORCEMENT STAFF '
9 ENFORCEMENT PANELS FOR SIGNIFICANT FINDINGS 9 OE AUDITS OF NON-ESCALATED ENFORCEMENT e INCREASED OE OVERSIGHT AND INVOLVEMENT IN NON-ESCALATED CASES I
O O O ACTIVITIES FOR MAINTAINING UNIFORMITY AMONG REGIONS REGION IV SPECIFIC ACTIVITIES ROUTINE ACTIVITIES e DAILY MORNING MEETING
@ BRANCH CHIEF MONITORING OF ACTIVITIES IN PROGRESS e INSPECTOR DEBRIEFS WITH REGIONAL MANAGEMENT e REGIONAL ENFORCEMENT STAFF INTERACTIONS MANAGEMENT INVOLVEMENT IN INSPECTION EXITS e BRANCH CHIEF OVERSIGHT OF RESIDENT INSPECTOR EXIT MEETINGS e DRS MANAGEMENT INVOLVEMENT IN REGION AND HEADQUARTERS-BASED INSPECTION e EXITS INVOLVING SIGNIFICANT ISSUES /EVENTE MANAGEMENT INVOLVEMENT IN INSPECTION REPORT PREPARATION 9 PERIODIC AUDITS BY REGIONAL ENFORCEMENT STAFF e PERIODIC COUNTERPART MEETINGS / TRAINING FOR STAFF e PERIODIC FEEDBACK FROM INDUSTRY 4 REGULATORY USER GROUPS
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l Appendix D
- i. IIT 96-002
! Photographs and Thermography Results 1
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- ] Appendix E
- Root Causal Factor Charts and Supporting Information
- Barrier Analysis of Inappropriate Actions
> Inaooropriate Action Barriers Effectiveness
- Bechtel letter instructed Bechtel controls for Not effective.
individual performing verification of Assumption not verified i
evaluation to assume design assumptions. and proved to be
- that the service water incorrect. Heat loads 4
will enter the ESW where inadequate to screenhouse through the raise ESW "A" warming
. warming line at 35F line temperature to 35F i (1976). during normal plant i
operation. Actual
, warming line j temperature ' was estimated to be 33F.
] Maintenance removed This event being packing gland follower evaluated by PIR
- /}
\ on TDAFP. When 96-0269) l
- reinstalled it was not in '
contact with packing ring.
Bechtel calcucation Bechtel controls for Not effective.
determines actual flow verification of Assumption not verified through ESW warming design assumptions. and proved - to be line will be 4413 gpm Also design models incorrect (line only runs with valves EFHV-39, 40, for determining flow approximately half full).
41, 42 closed and EFHV- rates.
38,38 open. Calculation assumed line would be full.
Procedure revision to STN Consideration of the Not effective due to ihe GP-001 to keep traveling impact a procedure lack of administrative screens in manual sloww revision will have on controls to provide for in cold weather to the plant design. an engineering review prevent surface ice from of operational changes O damaging screens. that could impact design.
. ___m _. . _ _ . _.. ... _ .. _ -._.._ . ,... ... _ _ _ _ _ _ _ . _ . . . . _ . . _ _ .
j.
O ^ 9aeadix e Root Causal Factor Charts and Supporting information j -Inappropriate Action' Barriers Effectiveness Operators opened ESW SYS EF-200 instructs Not effective due to j retu_rn ' to SW iso valves operator as' to procedure not being l EFHV-39, -40, -41. -42. correct line-up. used. .
Procedure not i Operators closed used due to imminent loss of service water.- !
l (throttled) ESW to UHS iso valves EFHV-37, -38.
. ESW system . operating Expectations that Expectations barrier not i
procedure not verified in procedures be_
adequate. A more j a timely manner. verified in a timely formal administrative ,
j manner. barrier may be appropriate.
l In transition from E-0 to This event is being i ES-2, copy of ES-2 was evaluated by PIR.
jh 3
not in the control room. 96-0278.
i GEN .00-005 Att. A No administrative contin ~ues to' be worked barriers identified.
4 before beginning GEN !
i 00-006 I i l ERO response recording Causes and !
said there - was no corrective actions i emergency when call for this issue are -
was made, being evaluated by PIR 96-0260. ~
Security did not make Causes and building announcement corrective actions until'30 - 40 minutes after for .this issue ' are pagers activated. being evaluated by PIR 96-0261.
O
d i
i iO FORT CALHOUN STATION l
i l EXTRACTION STEAM LINE RUPTURE EVENT l
l (April 21,1997) i l
i j
NRC SPECIAL INSPECTION REPORT NO. 50-285/97-09 j NRC INFORMATION NOTICE NO 97-XX
- O l
I O
L O FORT CALHOUN RUPTURE IN EXTRACTION STEAM LINE APRIL 21, 1997 PROBLEM l' RUPTURE IN EXTRACTION STEAM LINE.
l CAUSE EXCESSIVE PIPE WALL THINNING ATTRIBUTED TO FLOW-l ACCELERATED CORROSION (EROSION / CORROSION).
l SAFETY SIGNIFICANCE L RUPTURE OF PIPING LED TO UNNECESSARY PLANT TRANSIENT AND ,
I PERSONNEL HAZARD. POSSIBLE G$NERIC IMPLICATIONS O ASSOCIATED WITH PREDICTIVE METHODOLOGY (CHECWORKS).
l DESCRIPTION OF EVENT e ON APRIL-21, 1997, WHILE OPERATING AT 100 PERCENT POWER, CONTROL ROOM OPERATORS HEARD A LOUD NOISE IN.THE
. TURBINE BUILDING, FOLLOWED BY A VERY LOUD CONTINU0US NOISE.
l e THE OPERATORS CHECKED THE REACTOR INSTRUMENTATION AND NOTED NO ABNORMALITIES: THERE WERE NO CHANGES IN REACTOR COLD-LEG TEMPERATURE, STEAM GENERATOR PRESSURE, OR REACTOR POWER.
i o- THE SHIFT SUPERVISOR OPENED THE CONTROL ROOM D0OR TO lO INVESTIGATE AND NOTED A LARGE AMOUNT OF STEAM FLOWING FROM THE GRATING IN THE TURBINE BUILDING. THE REACTOR l
l WAS MANUALLY TRIPPED WITHIN 19 SECONDS OF THE EVENT.
Oe THE OPERATOR REALIZING THAT THE PLANT MAY HAVE BEEN EXPERIENCING AN UNCONTROLLED HEAT EXTRACTION EVENT ENTERED THE PLANT EMERGENCY OPERATING PROCEDURES AND l
INITIATED-EMERGENCY B0 RATION AS A PRECAUTIONARY MEASURE.
- DURING THE EVENT, THE FIRE SUPPRESSION SYSTEMS ACTUATED AND THERE WERE INTERMITTENT ELECTRICAL SYSTEM GROUNDS.
e APPROXIMATELY 40 MINUTES INTO THE EVENT, THE OPERATORS i ISOLATED THE FIRE PROTECTION SYSTEM.
i e APPR0XIMATELY 52 MINUTES INTO THE EVENT, SHUTDOWN MARGIN WAS VERIFIED AND EMERGENCY B0 RATION WAS SECURED.
O NO SAFETY SYSTEMS WERE AUTOMATICALLY ACTUATED. l l
! DISCUSSION l e FT. CALHOUN EXPERIENCED A RUPTURE IN THE 12-INCH LINE THAT CONNECTS THE FOURTH STAGE OF THE HIGH PRESSURE TURBINE TO THE FEEDWATER HEATERS. THE LINE IS FILLED WITH 92' PERCENT QUALITY STEAM AT 250 PSI AND 400 DEGREES FAHRENHEIT. THE " FISH-MOUTH" RUPTURE OCCURRED AT THE OUTER EDGE OF A 5 FOOT RADIUS BEND AND WAS APPR0XIMATELY 54 INCHES LONG AND 18 INCHES WIDE. I
'O i
i l O . THE RUPTURE LOCATION WAS NOT INCLUDED IN SITES
! INSPECTED.BY THE LICENSEE'S EROSION / CORROSION )
MONITORING PROGRAM. THE LICENSEE USES THE."CHECWORKS" l
COMPUTER CODE AS A TOOL TO AID IN THE IDENTIFICATION OF ,
l SITES TO BE INSPECTED. THE CHECWORKS METHODOLOGY DID ,
i L NOT PREDICT THE WEAR RATES WHICH WERE EXPERIENCED IN I THE SYSTEM. INDUSTRY-WIDE AND PLANT-SPECIFIC OPERATING EXPERIENCE WAS NOT INCORPORATED INTO THE
! EROSION / CORROSION PROGRAM (6 PIPE LOCATIONS IN 3
[ SYSTEMS WERE BELOW MINIMUM ALLOWABLE WALL THICKNESS) l
[ e THE OVERALL OPERATOR RESPONSE TO THE EVENT WAS
! SUPERIOR. THE OPERATORS ACTED IN A TIMELY, DECISIVE AND CONSERVATIVE MANNER.
iO i e THERE WAS EXTENSIVE DAMAGE IN THE VICINITY OF THE
[ RUPTURE. THE BACK PANEL OF ONE NON-SAFETY MOTOR j CONTROL CENTER (HCC) WAS DAMAGED DUE TO STEAM IMPINGEMENT. INSULATION, CONTAINING ASBESTOS, WAS l
BLOWN THROUGHOUT THE TURBINE BUILDING. NO PERSONNEL l
- WERE IN THE VICINITY AT THE TIME OF THE RUPTURE.
i e INTERMITTENT ELECTRICAL GROUNDS WERE OBSERVED ON TWO SAFETY-RELATED BUSES. THESE GROUNDS WERE ATTRIBUTED TO GROUNDS ON TURBINE BUILDING MCCs WHICH ARE SUPPLIED BY THESE BUSES. THESE BUSES ARE CONNECTED VIA CRITICAL QUALITY EQUIPMENT BREAKERS DESIGNED TO ISOLATE THE SAFETY BUSES IN THE EVENT OF GROUND FAULTS.
O (FT. CALHOUN OPERATES AN UNGROUNDED ELECTRICAL SYSTEM).
b) FOLLOWUP e THE NRC DISPATCHED A SPECIAL INSPECTION TEAM ON APRIL 23, 1997, TO INVESTIGATE THE CAUSES AND CIRCUMSTANCES SURROUNDING THE EVENT. A SPECIAL PUBLIC MEETING WAS I CONDUCTED ON MAY 2, 1997, PRIOR TO RESTART.
e THE LICENSEE CONDUCTED EXTENSIVE WALKDOWN INSPECTIONS I
TO IDENTIFY AND ASSESS POTENTIAL DAMAGE TO PLANT EQUIPMENT.
e THE LICENSEE IMPLEMENTED MEASURES TO INCORPORATE INDUSTRY-WIDE OPERATING EXPERIENCE INTO THE i EROSION / CORROSION PROGRAM.
I
([) e THE LICENSEE CONDUCTED EXTENSIVE FOLLOWUP ULTRASONIC TESTING OF OTHER LARGE RADIUS ELB0WS.
e THE NRC IS CONSIDERING THE NEED FOR AN INFORMATION NOTICE DISCUSSING THE ISSUES ASSOCIATED WITH CHECWORKS MODELLING PREDICTIONS.
O
- i 4
O ROOT AND CONTRIBUTING CAUSES Preliminary Results - Failure Mechanism ]
Flow Accelerated Corrosion (FAC)
Root Cause for the Failure to identify Significant Degradation
- Over-reliance on cibow radius as a predictor of relative wear rate, with insufficient consideration of plant.
history and industry operating experience.
b Contributing Causes O
- Failure to include the " sweep" elbows in the inspection program
- Lack of a proceduralized methodology for selecting inspection sites
- :ncomplete usage of plant history data
- Incomplete usage of industry operating experience and resources
- Lack of specific guidance on analytical model usage and maintenance
- Lack of adequate management / supervisory oversight l
)
O I l
l
O EVENT FOLLOWUP ACTIVITIES !
l l
NRC ACTIVITIES Special inspection (4/23/97-6/10/97)
Inspection Report (6/17/97)
Public Meeting (5/6/97)
Public Enforcement Conference (6/21/97)
Events Briefing (5/27/97)
Maintenance Rule Workshop Briefing (6/3/97)
Resident inspector Counterpart Briefing (6/18/97)
ACRS Briefing (7/18/97)
Information Notice (Proposed)
Inspection Followup Activities (TBD) 0 i LICENSEE ACTIVITIES l Self Assessment Team Industry Notification i Users Group Presentations !
Followup Activities !
O
l l
l l
m U EROSION / CORROSION CONTROL. PROGRAMS Reaulatory "Reauirements" Generic Letter 89-08, "&osion/ Corrosion-induced Pipe Wall Thinning" Information Bulletin 87-17, " Thinning of Pipe Walls in Nuclear Power Plants" 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" Industry Operatina Experience and References INFORMATION NOTICES:
82-22, " FAILURES IN TURBINE EXHAUST LINES"86-106, "FEEDWATER LINE BREAK" !
87-36, "SIGNIFICANT UNEXPECTED EROSION OF FEEDWATER LINES" 88-17, "
SUMMARY
OF RESPONSES TO NRC BULLETIN 87-01" q 89-53, " RUPTURE OF EXTRACTION STEAM LINE ON HIGH PRESSURE bl TURBINE" 91-18, "HIGH ENERGY PIPE FAP_URES CAUSED BY WALL THINNING" 97-XX, " RUPTURE OF EXTRACTION STEAM LINE PIPING" INPO NOTIFICATIONS:
i SOER 82-11, " Erosion of Steam Piping and Resulting Failure" SOER 87-3, " Pipe Failures in High Energy Systems Due to Erosion / Corrosion SER 6-95, " Condensate Pipe Break Due to Flow-Accelerated Corrosion" SER 187, " Erosion / Corrosion Induced Failure of Feedwater Piping" SER 88-84, " Extraction Steam Line Break" NRC Inspection Reports:
50-280/86-42 50-281/86-42 50-285/97-09 Industry Standards 14 SAC-202/L, " Recommendations for an Effective Flow-Accelerated Corrosion Program", (Proprietary)
CHECWORKS (Proprietary)
O O O STAFF TRAINING and DEVELOPMENT NRC REACTOR TRAINING AND QUALIFICATION GUIDANCE 9 NRC INSPECTION AIANUAL 1245 (INSPECTOR) 9 IlOLB - AIC-0170 (LICENSING EXAA11NER) 9 RESIDENT AND SENIOR REACTOR ANALYST PROGRAAIS TRAINING COAI A11TTEE OVERSIGilT 9 DIVISION DIRECTOR LEVEL PARTICIPATION O TRAINING PRIORITIES ESTABLISilED TRAINING PLANS AIANDATED FOR ALL EAIPLOYEES O QUALIFICATION , DEVELOP 31 ENTAL AND REFRESIIER TRAINING G REVIEWED WITil EAIPLOYEE APPRAISALS S SUPERVISORY AND 31ANAGE31ENT TRAINING INSPECTOR /EXAA11NER QUALIFICATION PROCESS 9 SUPPLEAIENTAL REQUIREA1ENTS BY REGION IV O QUALIFICATION BOARD 9 INTERI AI / FINAL CERTIFICATION O EXA AIINER CROSS QUALIFICATION FUNDAAIENTALS OF INSPECTION REFRESIIER TRAINING DURING COUNTER PARTS AIEETING AND TRAINING WEEKS
_ _ _ _ ..._a . _ _ _ . . . _ _ _ . . _ . _ _ . _ _ - _ _ _ . _ _ . . _ . _ ._____.____.__m _. __.___._.________-_.m__._ -__.- _ - __. ___ _ ____ ._. __._ ____ _ _ _ _ _ _ _ _ . _ __ _ _ _ _ . _ _ _ _ - _ _ _ . _ _ _ . _ _ _ _ _
i O
REGION IV INTERFACE WITH INPO
- NRC/INPO MEMORANDUM OF UNDERSTANDING
- NO DIRECT REGION IV INTERACTIONS O
- INDIRECT REGION IV INTERACTIONS
- OBSERVATION OF NATIONAL ACADEMY FOR NUCLEAR TRAINING - ACCREDITATION BOARD MEETINGS !
l; I
O
O O O '
REGION IV MEETING WITH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) SUBCOMMITTEE '
ON PLANT OPERATIONS AND FIRE PROTECTION BRIEFING ON REGION IV SENIOR REACTOR ANALYST PROGRAM William B. Jones, Senior Reactor Analyst Division Reactor Safety NRC Region IV JULY 18,1997 i
[
i
_-.--_____-_____---_-_______--.__.___-______-________-__--_-__-..__.---_______2
O O O DEVELOPMENT OF PRA RESOURCES e SENIOR REACTOR ANALYST (SRA)
- 2 SRAs established in Division Reactor Safety
. Training program and rotational assignments completed e IPE AND PRA INSIGHTS PROVIDED TO REGION IV STAFF
. Overview of NUREG 1560 (IPE Program: Perspectives on Reactor Safety and Plant Performance)
. Specific overviews of several licensee IPEs provided to resident and regional inspectors.
e IMPLEMENTING PRA LIBRARY
. Developing comprehensive library of licensee PRAs (system notebooks), IPEs and IPEEEs, technical and staff evaluation reports, risk informed pilot programs, and risk background information.
2
. . _ _ - - . ~ . - - . .. ..- .. . .- . . - . . _ . - .
O O O REGULATORY CONSIDERATIONS UTILIZING RISK INFORMATION e NOTICE OF ENFORCEMENT DISCRETION (NOED)
. SRAs are responsible for assessing licensee risk informed bases for NOED requests.
e ENFORCEMENT SEVERITY EVALUATIONS
. Enforcement Guidance Memorandum 97-011 establishes the guidelines for providing risk informed insights into the enforcement process.
. The SRAs are responsible for reviewing each potentially escalated enforcement action for risk insights and providing a perspective to the regional and Office of Enforcement (OE) enforcement panels.
. The SRAs are responsible for reviewing risk arguments presented by :
licensees during pre-decisional enforcement conferences or in their response ,
to apparent violations.
t 3
O O O i 7
INSPECTION FINDINGS AND EVENT EVALUATIONS L e INSPECTION FINDING SIGNIFICANCE EVALUATIONS ,
. The SRAs review, with the regional staff, inspection findings of potential risk 4 significance. Findings which warrant a more detailed analysis are reviewed with Region IV management on a case by case basis. ,
1
- The SRAs have the capability to perform independent risk assessments as needed using the NRC risk assessment tool IRRAS. The accident sequence ,
precursor models used can be modified to provide additional areas for review and discussion with a licensee.
e EVENT EVALUATIONS
- Attend weekly event assessment meeting chaired by the Events Assessment and Generic Communication Branch of NRR for potentially risk significant issues which may apply to Region IV plants.
l
. The SRAs provide short term review of potentially significant events. These findings are provided to NRC management for consideration in any follow up activities.
4 i
I
O O O ,
e MAINTENANCE RULE EQUIPMENT CONFIGURATION EVALUATIONS
- Equipment reliability and availability can be assessed for system and component performance which are not consistent with the licensee's PSA assumptions. This information would be considered in planning inspection, ,
i activities.
e OUTAGE RISK REVIEW I
- Licensee outage controls will be reviewed.for potentially risk important configurations and controls established (operator actions and/or .
supplemental equipment) to prevent or mitigate potentially significant events.
l' h
h
?
5 [
i 4
O O O INSPECTION PLANNING AND IMPLEMENTATION
- INSPECTION PLANNING AND PRIORITIZATION 1
. Provide risk informed assessments of plant performance reviews (PPRs),
plant information matrixes (PIMs) and inspection findings for inspection planning and prioritization.
. Implement inspection program based on licensee risk informed Graded QA (STP), inservice inspection (PV) and inservice testing (CPSES and ANO).
- OPERATOR LICENSING
. The SRAs will provide the operator licensing examiners with risk important operator actions which would be significant in mitigating an accident or in minimizing the failure of components and systems.
6
1 O !
I l
-L RISKS OF ON-LINE MAINTENANCE 1
- IN REGION IV NUCLEAR POWER PLANTS i l 1
i i !
i I I
I lO l
j DR. DALE A. POWERS 4
l MAINTENANCE BRANCH CHIEF DIVISION OF REACTOR SAFETY
- NRC REGION IV i
4
! ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MEETING t
i ARLINGTON, TEXAS
! JULY 18,1997 l
l
C REASONS FOR CONDUCTING ON-LINE MAINTENANCE !
l APPROPRIATELY BALANCE SSC AVAILABILITY AND RELIABILITY I
OPTIMlZE SSC LIFE BY BALANCING PREVENTIVE VERSUS CORRECT!VE !
MAINTENANCE I I
- IN SOME SITUATIONS, THE RISK ASSOCIATED WITH REMOVING AN SSC FROM SERVICE DURING POWER OPERATION MAY BE LOWER THAN DURING AN OUTAGE
- MORE EFFICIENT UTILIZATION OF ON-STAFF RESOURCES, WORK FORCE LEVELING, AND LESS RELIANCE ON CONTRACTORS !
ECONOMIC BENEFITS OF SHORTENED REFUELING AND MAINTENANCE OUTAGES' l
)
1 l
l 2
0 2
l 4
j I
1 O aisk assessment Too's roa on-'ine =^i"Tenance 3
i- Many regulations were developed during times when industry's maintenance philosophy was to conduct long outages involving significant maintenance activities. Now that this
- philosophy has evolved, plant baseline risk envelopes (without major maintenance) exhibit j spikes when SSCs are out of service.
l j QUALITATIVE JUDGEMENT Widely used prior to the publication of the Maintenance Rule 4
Commonly used today on non-risk significant BOP SSCs
+
MATRIX OF SSC CONFIGURATIONS
.t Convenient, simple reference
} Limited applicability to only dual combinations of SSCs, which are typically only the
) high-risk significant SSCs addressed by the Technical Specifications i O-
- l SPECIFIC CONFIGURATION CALCULATION i
- Slow, costly 1
COMPUTER-BASED MODEL
- Compares proposed plant configuration and associated risk against average plant
] configuration previously quantified by the probabilistic safety assessment model i
I I
1 1
1 1
4 k
i O 3
i I
l
- i. ,_ _ _ _ _ _ , _ _ _ __. - _ - . _.I
. - . . . - .. . - _ . . . . - . _ - - - . . _ _ . - . - - . - . . - . . . - . . . - . - ~ . . -
i l
O 0000 ^TTRIBUTES OF ON-LINE MAINTENANCE RISK ASSESSMENTS !
- . SHOULD BE PERFORMED FOR ALL MAINTENANCE ACTIVITIES THAT IMPACT SSC RELIABILITY AND AVAILABILITY i l'
Post-Maintenance Testing Surveillance Predictive, Corrective, and Preventive Maintenance i
- SHOULD BE PERFORMED FOR ALL ON LINE MAINTENANCE REGARDLESS OF THE I MODES OF OPERATION !
- SHOULD BE PERFORMED FOR EMERGENT WORK THAT WILL RESULT IN i CONFIGURATION CHANGES O
4
O NRC EXPECTATION FOR THE PERFORMANCE OF ON-LINE MAINTENANCE SAFETY ASSESSMENTS
( 10 CFR 50.65 MAINTENANCE RULE PARAGRAPH A(3)
"lN PERFORMING MONITORING AND PREVENTIVE MAINTENANCE ACTIVITIES, AN l ASSESSMENT OF THE TOTAL PLANT EQUIPMENT THAT IS OUT OF SERVICE SHOULD BE TAKEN INTO ACCOUNT TO DETERMINE THE OVERALL EFFECT ON PERFORMANCE OF SAFETY FUNCTIONS."
A change from "should" to "shall" is under consideration in response to the April 11, 1997, Staff Requirements Memorandum l O l
5
\
\
(] GUIDANCE FOR ASSESSING ON-LINE MAINTENANCE RISK
- " MANAGING MAINTENANCE DURING POWER OPERATIONS," INPO, FEBRUARY ,
17,1995 l l
l
- " INDUSTRY GUIDELINES FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS," REV. 2, NUMARC 93-01, APRIL 1996 Endorsed by Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Rev. 2 l
n L) 6
O PROGRAMMATIC INSPECTIONS OF ON-LINE MAINTENANCE
- TEMPORARY INSTRUCTION 2515/126, " EVALUATION OF ON-LINE MAINTENANCE," OCTOBER 27,1994 Performed by resident inspectors 1
INSPECTION PROCEDURE 62706, " MAINTENANCE RULE," AUGUST 31,1995 Being performed by region-based teams that include PRA experts !
l l
1 O i I
l 1
h !
7
4 O BASELINE INSPECTION EXPERIENCE WITH ON-LINE MAINTENANCE RISKS LICENSEE PROGRAMS WITH FAILURES TO PERFORM RISK ASSESSMENTS l
COOPER NUCLEAR STATION
- RISK TOOL - MATRIX a OPERATOR KNOWLEDGE OF REQUIREMENT FOR EVALUATING THE IMPACT OF CHANGES IN PLANT STATUS UPON RISK WAS POOR
- AN INAPPROPRIATE USE OF A STANDARD PERFORMANCE CRITERION FOR RELIABILITY HAD AN ADVERSE EFFECT ON THE RISK RANKING FOR SSC SAFETY SIGNIFICANCE (Violation of a(2)]
- ONE EXAMPLE OF ENTRY INTO A PREDETERMINED RISK-SIGNIFICANT WINDOW WITHOUT FIRST PERFORMING A PREREQUISITE CHECKLIST [ Violation of Criterion V]
- UNAVAILABILITY WAS NOT MONITORED FOR R!SK SIGNIFICANT SSCs ,
( (AUTOMATIC DEPRESSURIZATION, EMERGENCY DIESEL GENERATOR, HIGH I PRESSURE INJECTION, AND RESIDUAL HEAT REMOVAL) (Violation a(2)] l
- SEVERAL FAILURES TO PERFORM RISK ASSESSMENTS FOR SAFETY-RELATED EMERGENT WORK (NO HIGH-RISK SIGNIFICANT EXAMPLES) [ Violation of Criterion V]
- RISK ASSESSMENT PROCESS HAD SIGNIFICANT PROCEDURAL WEAKNESSES: IT ;
DID NOT ADDRESS ACTIONS WHEN SSC FAILURE OCCURRED WHILE IN A RISK- !
SIGNIFICANT WINDOW, IT DID NOT ADDRESS ASSESSING RISK WHEN l REMOVING SSCs OF LOW-RISK SIGNIFICANCE, AND IT WAS UNCLEAR ON !
RESPONSIBILITY FOR PERFORMING RISK ASSESSMENT FOR EMERGENT WORK i O
8
l
[V; . LICENSEE PROGRAMS WITH FAILURES TO PERFORM RISK ASSESSMENTS l
i i
DIABLO CANYON (DRAFT) )
l
- RISK TOOL - MATRIX l
MATRIX DID NOT ACCOUNT FOR RISK-SIGNIFICANT SSCs (AUXILIARY BUllDING i AND SWITCHGEAR VENTILATION) 1 ONE FAILURE TO PERFORM A RISK ASSESSMENT PRIOR TO REMOVING FROM l SERVICE A HIGH-RISK SIGNIFICANT SSC (AUXILIARY SALT WATER) [ Violation Criterion V]
1
- THE RISK ASSESSMENT PROCESS WAS ADEQUATE.
l l
I i
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9
, - . . - - . - . - - ~ ~ . . . - . . . . . . ~ . . . - . . . ~ . - . . - . _ . . . . ~ . . . . . - _ . - . - . ~ . - . - - - . _ - -
l t I i
\ \
LICENSEE PROGRAMS WITH FAILURES TO PERFORM RISK ASSESSMENTS GRAND GULF i i
- RISK TOOL - EOOS SOFTWARE FOR QUANTITATIVE EVALUATIONS l -* OPERATORS LACKED SENSITIVITY TO THE NEED FOR MONITORING AND ;
TRACKING SSC UNAVAILABILITIES AND CHANGING RISK CONFIGURATIONS l
+
,
- AVAILABILITY WAS NOT MONITORED FOR RISK SIGNIFICANT SSCs !
l (INSTRUMENT AIR [ Violation a(1)], NUCLEAR BOILER INSTRUMENTATION AND f l CONTROL ROD DRIVE INCVs]) !
L !
- SSC PERFORMANCE CRITERIA WERE NOT ESTABLISHED COMMENSURATE WITV t THE RISK ASSESSMENT [NCVs] .
- THE SSC RISK RANKING METHODOLOGY WAS LACKING IN THAT IT DID NOT l ASSESS UNAVAILABILITY AND RELIABILITY ASSUMPTIONS
- ONE FAILURE TO PERFORM A RISK ASSESSMENT PRIOR TO REMOVING AN EM RGENCY DIESEL GENERATOR FROM SERVICE FOR PREVENTIVE O + THE RISK ASSESSMENT PROCESS WAS GOOD i
[
f I
lO l
10
LICENSEE PROGRAMS WITH WEAKNESSES PALO VERDE NUCLEAR GENERATING STATION l
- RISK TOOL - MATRIX THE EVALUATION OF THE CUMULATIVE RISK IMPACT OF MULTIPLE SSC OUTAGES LACKED AN ANALYTICAL BASIS AND, IN SOME CASES, YlELDED NON-CONSERVATIVE ESTIMATES THE RISK ASSESSMENT PROCESS HAD PROCEDURAL WEAKNESSES: THE GUIDANCE FOR ASSESSING CONFIGURATIONS NOT ADDRESSED BY THE MATRIX WAS WEAK, AND THE MATRIX DID NOT ADDRESS SOME BOP SSCs l THAT WERE NOT MODELED IN THE PRA MODEL l
l l
1 0
O 11
4
/Q LICENSEE PROGRAMS WITH WEAKNESSES V
WASHINGTON NUCLEAR PROJECT - 2 RISK TOOL - A PROCEDURE LISTED CERTAIN SSCs OF HIGH-SAFETY SIGNIFICANCE FOR CONSIDERATION
= A RISK ASSESSMENT WAS REQUIRED TO EVALUATE SAFETY PRIOR TO VOLUNTARY ENTRY INTO TECHNICAL SPECIFICATION ACTION STATEMENTS FOR CORRECTIVE MAINTENANCE
- UNAVAILABILITY WAS NOT MONITORED FOR RISK SIGNIFICANT SSCs (NUCLEAR CONDENSATE, REACTOR FEEDWATER, AND UNINTERRUPTIBLE AC POWER SUPPLY) [ Violation a(1)]
- AN INAPPROPRIATE USE OF A STANDARD PERFORMANCE CRITERlON FOR RELIABILITY HAD AN ADVERSE EFFECT ON THE RISK EANKING FOR SSC SAFETY SIGNIFICANCE [ Violation of a(2)]
= A RISK ASSESSMENT ON A FROZEN MAINTENANCE SCHEDULE WAS PROVIDED FOR CHANGES INVOLVING HIGH-RISK SIGNIFICANT CONFIGURATIONS n
()
- THE RISK ASSESSMENT PROCESS HAD PROCEDURAL WEAKNESSES: IT DID NOT INCLUDE ALL SSCs OF HIGH-SAFETY SIGNIFICANCE, IT DID NOT ADDRESS THE NECESSITY OF PERFORMING A RISK ASSESSMENT FOR EMERGENT WORK NOR FOR UNANALYZED CONFIGURATIONS, AND IT DID NOT ADDRESS THE IMPACT ON SAFETY WHEN LOW-SAFETY SIGNIFICANT SSCs WERE REMOVED FROM SERVICE l
l i
,Q L
12
l (q/ LICENSEE PROGRAMS WITH NO NOTED WEAKNESSES l
WATERFORD 3 RISK TOOL - EOOS SOFTWARE FOR QUANTITATIVE EVALUATIONS l AN OPERATION'S GUIDE PROVIDED GUIDANCE FOR THE CONSIDERATION OF SEASONAL WEATHER CONDITIONS AND QUANTITATIVE ASSESSMENTS OF SWITCHYARD ACTIVITIES THE SSC RISK RANKING METHODOLOGY WAS LACKING IN THAT IT DID NOT ASSESS UNAVAILABILITY ASSUMPTIONS THE METHOD FOR ESTABLISHING UNAVAILABILITY PERFORMANCE CRITERIA WAS LACKING IN THAT IT DID NOT FULLY EVALUATE THE CUMULATIVE RISK IMPACT OF ALL SYSTEM INTERDEPENDENCIES UNAVAILABILITY WAS NOT MONITORED FOR RISK SIGNIFICANT SSCs (ENGINEERED SAFETY FEATURES ACTUATION, PLANT PROTECTION, CORE PROTECTION CALCULATORS, BROAD RANGE GAS MONITORS, AND CONTAINMENT POLAR CRANE) (Violation a(1)]
- THE RISK ASSESSMENT PROCESS FOR WAS SUPERIOR a
0 13
1 O
! REGION IV INS 3ECTION PROGRAV r
STA~~US O 3LANTS INSPECTION PROGRAM l
l RES:: DENT ::NSPECT::0N REGION-BASE) INSPECTION O PLANT ISSUES MATRIX PLANT PERFORMANCE REVIEWS SALP SALP 1ATINGS t
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. REGION IV PLANT STATUS REPORT i O ,
FOR 07/17/97 O
.- ~. - . . _ . -- . -- _ -~~ .- - ~ _ - _ _ . - - _ . . _ _ _ _ . . . - . .
i l
l NRC OPERATIONS CENTER
] PLANT STATUS REPORT FOR 07/17/97 UNEVALUATED INFORMATION PROVIDED BY THE FACILITY REG PLANT NAME PHCNE %PWR DOWN RESTART REASON OR COMMENT * #
1 4 ARKANSAS NUCLEAR 1 4563 100 i
4 ARKANSAS NUCLEAR 2 4563 100 l
4 CALLAWAY 1 4564 095 ADMINISTRATIVE POWER REDUCTION DUE TO AXIAL OFFSET ANOMALY 1
4 COMANCHE PEAK 1 4565 100
- 4 COMANCHE PEAK 2 4565 100 l
4 COOPER 1 4566 100 t ......__............._.................................................__.......
I 4 DIABLO CANYON 1 4567 100 4 DIABLO CANYON 2 4567 100 4 FT CALHOUN 1 4568 100 4 GRAND GULF 1 4569 100 4 PALO VERDE 1 4570 100
- 4. PALO VERDE 2 4570 100
>% w........ .. ........................___................................_...
HALO VERDE 3 4570 100 4 RIVER BEND 1 4571 100 4 SAN ONOFRE 2 4572 070 HOLDING POWER WHILE
- WORKING ON A MAIN FEEDPUMP
! 4 3AN ONOFRE 3 4572 001 MODE 2 - STARTUP
- CRITICAL BELOW THE POINT OF ADDING HEAT 4 SOUTH TEXAS 1 4573 100 4 SOUTH TEXAS 2 4573 100 4 WASHINGTON NUCLEAR 2 4574 087 INCREASING POWER
- 4 WATERFORD 3 4575 000 04/11 UNK MODE 4 - HOT SHUTDOWN REFUELING OUTAGE 4 WOLF CREEK 1 4576 100 I
, o r
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O NRC 30WER REAC-~0R INSPEC-~::0N 3ROGRAM l OBJECT::VES -
! MAS ~~ER ::NSPECTION PLAN 1
CORE i REG::0NAL ::N::~~IA-~::VE O SAFETY ::SSUE REAC-~IVE ::NSPECTIONS i
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AC--':0NS IN RES 30NSE ~~0 V::0LA- IONS l
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RESIDENT INSPECTOR PROGRAM i
l CONTIs UA_ h1C ONSITE 31ESENCE l
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10 1
)::1EC" 03SERVA" ION Or ACTIVITIES Eh 'A\ CE) \ RC 00WLE)GE Or C0s)I IONS l
3ETTER 3ASE 201 REGU _A"01Y DEC::SIO\S l -
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LESS RE_IAhCE Os REC 01]S i
GREATEl h RC I\ JEPEh JEhT VERITICATIO\
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INSPECTION REQUIREMENTS -
i JA::_Y ::NS3ECTIONS CON- R0_ ROOM OBSERVAT::0NS 1 3
_AN-~ TOUR l
0 BIWEEKLY INSPECTIONS l
! MONTHLY INSPECTIONS l
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l RESIDENT INSPECTION l
l TRI-F0\TFLY ':NS3ECTIO\S i
SEFIA\ L A_ INSPEC- IO\S
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RESIDENT INSPECTION i -
4 1
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O :0RVA_ IhS3ECTIO4 REPORT l
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O REGION-BASED INSPECTION l INSPECTORS WITH SPECIALIZED EXPERTISE i
l BASED IN REGIONAL OFFICES
! INSPECT ALL PLANTS O BROAD-BASED PERSPECTIVE NARROW TECHNICAL FOCUS INDEPENDENT CHECK ON RESIDENT O 9
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O PLANT ISSUES MATRIX (PIM)
CURRENT PIM PIM IMPROVEMENTS O RELEASE OF PIM f
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PLANT 3ERFORMANCE REV::EWS (IMC 0304)
OBJEC-~::VES 3ROCESS l
O RU-PUTS !
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11
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SYSTEMATIC ASSESSMENT OF LICENSEE 3ERFORMANCE ,
1 OBJEC-~IVES '
3ROCESS :
O OUTPUTS
!O 12 i-I . . . _ - .__
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l O COMMUNICATE RESU_TS l
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i SA _3 RA~~INGS i
- SALP REPOR~~ l 1
!O i MASTER ::NS3EC-~::0N PLAN 4
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i SAL) CATEGORY RATING JEFINITIONS CATEGORY 1 CATEGORY 2 O l CATEGORY 3 1
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_ _ . _ _ . _ _ . _ _ . _ _ _ . _ _ _ _ ._. . ~ _ . _ _ _ _ _
l O
L CURREN~~ SAL 3 FUNC"IONAL AREAS l
t 03ERATIONS V
AIN~~ ENANC E ENGINEERING ,
~
O PLANT SU3 PORT SAFETY ASSESSMENT /0UAL::TY VER::F::CA~~ ION lO 17
1 1
CURRENT SALP SCORES
- O FOR 1
, REGION IV FACILITIES 4
i SITE OPERATIONS MAINTENANCE ENGINEERING PLANT SUPPORT j 1-ANO 1 2 1 1 :
CALL 2 1 1 1 l
- CPSES 1 1 1 1
/O V
FCS 2 2 1 1 GG 1 2 1 1 PVNGS 1 1 1 2 RBS 2 2 2 1 SONGS 2 2 1 1 STP 2 1 2 1 WAT 2 2 3 2 WNP-2 2 2 2 2 WC 2 2 3 2 l
i 18
o o O i
REACTOR DECOMMISSIONING IN
. m. m:.. .
REGION IV Dr. D. Blair Spitzberg, Chief Auclear Materials Inspection and Decommissioning Branch l
l July 18,1997
o o 2 :
REACTORS IS' .
DECOMMISSIONISU
/ J '
- Trojan
- Ranc: 10 Seco i
- Humaoit Bay San Ono:,re Lnit 1
- Fort St. Vrain
- Va:iecitos l
o o 8 l
Region nV REACTOR DECOMMISSIONING SITES i
MN Region lll s_
Trojan x MT
,$h_,
I
-MA RO9 On i E
SD ID I t PA IN O T Humboldt Bay ? V D.C.
J
- pyy Rancho Seco MD VBWR OK Songs
- % l AK ;
5)7e Re9i on II
< Fort St vrain -
DBS4-18-97 ppt ,
I
O O O.
- TROJAN t
- Rainer, Oregon
- Westing: 1ouse L loop PWR
- 1153 Mwe
- OL issued - November 1975
- Commercial Operations - May 1976
- S:autc own - November 1992 i
o o o l
TROJAX STATUS l
- Active:y unc ergoing dismantlement and decon - completion by 2002
- Steam generators, pressurizer, and j coo ant pumps buried at Hanford
- Reactor pressure vessel burial as one unit :aas been aroposed
- ISFSI construction started
- current staffing is 274
- O O O TROJAX REACTOR VESSEL PROJECT c
- .
c
- Application suamitted to bury vessel at Hanford
- 2 milion curies activatec meta ,155
- curies inner surface contamination
- S:lippec as type B, exclusive use via
- barge up Columbia River
- Total weight of 1,013 tons t
o . e i
RANCHO SECO -
i
[
i
- Sacramento, California
- B&W Reactor
- 918 Mwe
- OL issuec August 1974
- Commercial Operations - April 1975 4
- Shutc own - June 1989
__..._.______._._.________-__...__.____.m____
o e s RANCHO SECO STATUS l
t
- SAFSTORwithlimited t l cismantiemeir underway in turbine aui cang
.
- Decision witun a year to pursue cismant ement Site issues invo:ve deterioration of faci:ity
- ISFSI near completion a
o e G ;
HUMBOLDT BAY .
I
- Eureka, Ca ifornia
- 65 Mwe
- OL issuec. - August 1962
- Commercial Operations - August 1963
- Shutc own - Ju:y 1976
. . _, _ __ _ . ~ _ _ _ _ . . . _ _ _ _ _ ._ . . _ _ _ _ _ _ . . _ _ _ _
t' t HEAT EXCHANGERS
~.
. CRANE REFUELlHG BLDG. F, "O, u gwg.
- %. J U R E SlN. JIS CRANE I EMERGENCY STORAGE. Zi PolSON '
TANK % "'
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.. . .:I.
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CASK EXCHANGERS '-
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REDT SECTION E-E f^
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FIGURE 3-11 EQUIPMENT ' LOC ATION
o O O HUMBOLDT BAY STATUS ..:
- SAFSTOR with repair work underway for in-leakage problem
- Stac( near containment has cracks
- ISFSI c.esirec. but imited by tsunami aotentia.
- Current staffing is 39 @lus 56 contractors on in-:.eakage work)
O o o HUMBOLDT BAY LEAK PROBLEM .
+ In-Lealage into caisson sump is current:y 7800 gpd
- Leve:s as : 1ig:1 as :.0,000 gpd occurred :ast summer
- Pump capacity is 43,200 gpd
- Cs-137 below release limits .
- Contingency plans established
O O O SAN ONOFRE
- San C:emente, CA
- Westing: 1ouse PWR
- 436 Mwe
- OL issued - March 1967
- Commercia: Operations - January 1968
- S:autc own - November : 992
O O O SAN OXOFRE STATUS i
- In SAFSTOR
- First : ea:cs in spent fuel pool :iner startec in 1986
- Apri: 1995 lea:( of spent fuel poo:
- iner of 2000 gal:.ons
- Current .ea:(rate 3 gpw
i o o o vg; ; ;.' . . ;. 2m'( '- _ -_
FORT ST. VRAIN
.? _.
- PLattevile, CO
- GA HTGR
- 330 Mwe
- OL issuec. - December 1973
- Commercia. Operations - January 1979
- Shutc.own - August 1989
O @ o FORT ST. VRAIN 13: . _ . .
~
STATUS
- Decommissioning complete
- License termination Letter with Commissioners
- Current staffing is 25 (15 are security}
I
.._.,_________-_.-_____--__-______.__._.m_ _ _ _ _ _ _ _ _ _ _ _ _ ---__.--_____.v_ - -
o o o VALLECITOS
- PLeasanton, CA
- OL issuec. - October 1957 S:autc own - December 1963
o O O
..u.
VALLECITOS STATUS t
t
- Long term SAFSTOR
- Some in-Leakage had occurred in the i past i
i
O O O PROBLEM AREAS
- Free Re: ease Surveys
- A: legations
- Spent fuel pool Leaks
- Licensee " going to sleep"
- Comp:iance with 49 CFR
- Maintenance rule applicability
- Deterioration of faci ity and equipment
o o o 1
ISSUES
- Fir a:ization of various regulatory guic ance c ocuments
- Ro~ e of XRR versus XMSS during decommissioning
- Inspections emphasis change (health physics, employee concerns, free release surveys, OSHA, heavy loads, spent fuel pool)
o o o STAFFING A:5D INSPECTIONS
- Current:y one.insaector and two 0;penings
- Typica:iy concuct semiannua:. .
insaections at SAFSTOR faci:ities anc! bi-montiy inspections at DECON fac11 ties
o o o l
l FLTLRE SHETDOWKS
- Deregulation or plant perform.ance issues coulc. drive any of the region IV plants into c.ecommissioning
- Currently, no additional plants are ciscussing cecommissioning with Region IV, l
O O O LICENSE l EXPIRATIONS .
21 operating plants
- 2008 Diablo Canyon L~ nit 1
- 2010 Diablo Canyon Lnit 2
- 2013 Ft. Canoun
- 2013 San Onofre L' nit 2
- 2013 San Ono:fre L nit 3
- 20~ L Arkansas Nuclear One L'ni': 1
- 20: 8 Ariansas Nuclear One L' nit 2
- 2022 Grand Gul:P
o o o .
LICEXSE EXPIRATIONS
. - = ~
continued
- 2022 Granc Gul:P
- 2023 Washing:on Nuc. ear Projec: L ni: 2
- 202z- Ca.laway
- 202z. Palo Verc e Lnit 1 ,
- 2022- Wa:erford
- 2025 Palo Verc.e L ni~: 2
- 2025 River Bend
- 2025 Wolf Creer
~
! o o o -
! LICENSE l - -; --: .. y q_ g _ y -
EXPIRATIONS continued
- 2027 Palo Verc e Lnit 3
- 2027 Sou:h Texas Pro'ec: Eni: 1
- 2028 Sou:h Texas ?rojec:L~ nit 2
- 2030 Comanche Peac Uni: 1
- 2033 Comancae Peak Eni:2 I
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0 0 0 ARKANSAS NUCLEAR ONE
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[h Ehlergy Operations - ANO 153
o O O ARKANSAS NUCLEAR ONE CASK CRACKS ,
Mg232-A-2y w >:ggN:s 2:21-ar:grer.:3yp2,am;mn xn e- y,~:wmgape;c:mm rnry,c::,mn hn:om ~ .x~4 Gusts.;w% aLcaLu e CAL in place requiring resolution of crac:(ing p;aenomena prior to ac cItiona .oacing
- Cas:( #1 - crac t in shielc. lid final welc.
e Cas:( #3 - crack in shield Lic root welc
o O O I
FORT ST. VRAIN
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e Foster Wheeler c esign
- e 1z 62 s; pent fuel elements in storage e nig1y enricaec. fuel in grapalte e Feb.1996 contract between DOE anc PSCo l e DOE Application submitted Dec 96
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o o o 1 TROJAN e Sierra Nuc~ ear Transtor Design e 36 casks are planned o Concrete pac under construction e Cas:( on aold because of cracking issue t e 1998 Loading planned
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O NUH 003 1.i.5 June 28,1996 Revision 4 A
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O V NUH-003 1.3 11 June 28,1996 Resision 4 A
l ROOF ATTACHWENT ASSEMBLY DRY SHIELDED CANISTER ROOF SLAB SEISWIC RETAINER .,.' '
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o o o :
DOE TMI-2 FUEL - _ _ _ _ _
e Located at IXEEL - Idaho ~ l e Vectra NUHOMS special design e fuel c.ebris in a vented cask e 30 casks (m.ocules) are planned e 1999 :oading p:annec.
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o o o m_________
WNP-2 _ _ . _ _ _ _ _ _
i e Initial bic.s requestec in Late 1996 e ALL bids were evaluated as inadequate e New bidding pLannec for this year e Loacing planned before 2000
O O O HUMBOLDT :
BAY /DIABLO CANYON e Jom. t effort und er d.iscussion .
e Very ear:y stages e Loading d. ate not determined.
e Humbolt wi: :aave :aard time p:. acing pad. onsite due to tsunami
- 30tentia_
o o o SAN ONOFRE , - = = - - - ~ - -
c_ - = = = - - - -
o Discussions unc erway witain company e Don't expect significant activity unti: a cas:(is avaiLaie for ~30ta shipping anc storage l
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_ = _ _ _ _ _
PROBLEM AREAS _- _ == _
e weling of Lic e :1ydrogen generation from coatings e c ocumentation of safety reviews e experience in Loacing/ moving casks e crane capacity 9
-_.h_-.a.-. . - .