ML20205E863
| ML20205E863 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/20/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8703310031 | |
| Download: ML20205E863 (126) | |
Text
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0RIGINAL UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION
Title:
Discussion /Possible Vote on Restart of Palisades (Public Meeting)
Location:
Washington, D.
C.
Date:
Friday, March 20, 1987
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Pages:
1 - 96 Ann Riley & Associates
'# D' Court Reporters 1
1625 i Street, N.W., Suito 921 Washington, D.C. 20006
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(202) 293-3950 I
B703310031 070320 10CFR P,I i PDR
1 D 1 SCLA I MER 2
3 4
5 6
This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on 8
3/20/87 In the Commission's office at 1717 H Street, 9
'N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain
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12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may' 21 authorire.
22 23 24 25
1 1
UNITED F. FATES OF AMERICA 2
NUCLEAR R2GULATORY COMMISSION 3
4 DISCUSSION /POSSIBLE VOTE ON RESTART OF PALISADES 5
6 PUBLIC MEETING 7
8 Nuclear Regulatory Commission 9
Room 1130 10 1717 "H" Street, N.W.
11 Washington, D.C.
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12 f
13 Friday, March 20, 1987 14 15 The Commission met in open session, pursuant to 16 notice, at 10:05 o' clock a.m.,
LANDO W.
ZECH, Chairman of 17 the Commission, presiding.
l 18 19 COMMISSIONERS PRESENT:
l 20 LANDO W.
ZECH, Chairman of the Commission l
21 THOMAS M. ROBERTS, Member of the Commission 22 JAMES K. ASSELSTINE, Member of the Commission 23 FREDERICK M.
BERNTHAL, Member of the Commission 24 KENNETH M. CARR, Member of the Commission l
25
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l
1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
2 A. Bates 3
W.
Parler 4
W. McCormick 5
F. Buckman 6
J. Firlit 7
- v. Stallo 8
J. Sniezek 9
J. Taylor 10 B. Davis 11 C. Norelius 12 B. Guldemond 13 C. Thadani
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14 AUDIENCE SPEAKERS:
15 T. Wambach 16 17 18 19 20 21 22 23 24 25
3 1
PROCEEDINGS
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2 CHAIRMAN ZECH:
Good morning, ladies and gentlemen, 3
Commissioner Bernthal will be joining us shortly.
Palisades 4
has been shut down since the reactor trip occurred on May 19, 5
1986.
A letter issued by the NRC Region III on May 21, 1986 6
confirmed Consumers Power Company agreement not to restart 7
Palisades without the regional administrator's approval.
8 The purpose of today's meeting is for the Commission 9
to review the readiness of the Palisades plant to resume 10 operations after an extended outage and possibly to vote to 11 authorize the Region III administrator to allow the facility 12 to return to service when he is satisfied.
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13 The Commission will be briefed by Consumers Power 14 Company and by the NRC staff.
During the presentations, I l
15 would like the presenters to focus their comments as much as 16 possible on the results and effectiveness of programs and 17 actions discussed during our previous meeting here on January 18 14th.
19 I understand that copies of the slides that will be l
20 used during the briefing are available at the rear of the 21 room.
Do any of my fellow Commissioners have any opening 22 remarks?
23 COMMISSIONER ASSELSTINE:
Maybe just one quick 24 comment, Lando.
I agree and I hope that both the company and
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25 the staff will focus on the results of the efforts that we
4 1
have heard about.
2 We just received yesterday a copy of the December 22 3
Inspection Report from the staff on the Safety System 4
Functional Inspection and I have to say that for myself, that 5
report raises a whole series of questions about how effective 6
the performance program has been.
7 Now I realize that it has been three months since 8
that report was issued.
I think it is very unfortunate that 9
we got it yesterday, quite frankly, and for myself, I think I 10 want to go through those items in detail to understand whether 11 in particular these programs have really worked and we have 12 some assurance that the equipment in the plant is going to be
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13 able to perform its safety function.
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14 Again, I sort of apologize because I think it is 15 necessary to go through those in detail.
If we had gotten 16 this report a few days earlier or a week ago, it might have 17 been possible to restructure the thing in a little easier l
18 way.
But given the fact that we just got it yesterday, I 19 think it is necessary to go through it step-by-step.
20 CHAIRMAN ZECH:
This is my purpose, too, in asking 21 that you specifically address the effectiveness of the programs l
22 because as Commissioner Asselstine points out, we have just 1
23 received this document so you need both, Consumers Power company 24 and the staff to address those issues.
l 1
25 If they can satisfy us here today,.why that is what
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5 1
we would hope but we would ask you specifically to do that.
r 2
Are there any other comments from my fellow Commissioners?
3
[No response.]
4 CHAIRMAN ZECH:
You may proceed then, Dr. McCormick.
5 MR. McCORMICK:
Thank you.
Chairman Zech and 6
members of the Commission, Fred Buckman is with me who is our 7
vice presi, dent of Nuclear Operations and Joe Firlit who is the 8
plant general manager.
9
[ SLIDE.]
10 MR. McCORMICK:
If you would refer to the handout 11 material or the slides, if you flip to the next chart, please.
l 12
[ SLIDE.]
13 MR. McCORMICK:
I won't go through any of the 14 summary of what we presented on January 14th to the Commission 15 but we did cover in detail the material condition of the plant 16 and the various proposals and actions that we had taken to 17 date which had already included drastically reducing the 18 number of maintenance work orders, control room deficle'hcies 19 and other actions.
20 We have continued to make some progress in those 21 areas and I think as we indicated at that time that we had the 22 plant in a maintenance condition that we believe is better 23 than average.
24 We also identified a number of design-related 25 issues, identified the problems, discussed.with you the plans
6 1
for the resolution of'those problems and gave you a status 2
report on the progress toward resolution of those.
3 We also discussed with you our plans for a 4
comprehensive testing and restart program and we will get 5
into the results of the testing programs and some of the 6
issues, Commissioner, that you have just raised.
7 COMMISSIONER ASSELSTINE:
Great.
8 MR. McCORMICK:
Next slide, please.
9 (SLIDE.]
10 MR. McCORMICK:
Today, we are going to summarize all 11 fo the commitments that we made to you at our last meeting 12 with regard to items that we would have resolved prior to 13 startup.
We have completed those items.
14 We will also discuss the progress of our testing 15 program.
We have been in a rather comprehensive testing 16 program since early January.
We have completed the cold 17' testing.
We have just about completed the hot testing and we l
18 will discuss the results of those tests with you and discuss l
l 19 our plans for the restart of the plant.
I 20 I would now like to ask Fred Buckman to complete the 21 presentation and address the various items that I have referred 22 to.
23
[ SLIDE.]
24 MR. BUCKMAN:
At our meeting on January 14th, we 25 identified certain items that would be' addressed prior to E
7 1
startup.
The completion of these commitments, we view as 2
being only a milestone on the road to excellence.
3 What I would like to do is to start this presentation 4
by showing where we are on that road.
The commitments fall in 5
two major categories.
One is material condition and the other 6
is design.
7 We addressed both specific May 19th trip problems 8
and also issues identified by the material condition task 9
force review under material condition.
10 Under design, we addressed our improvements in root 11 cause assessment or really what we were going to do to fix l
12 problems rather than symptoms, a safety System Functional I
13 Inspection which Commissioner Asselstine, you.just referred
- i.
14 to, and our System Functional Evaluation.
15 This System Functional Evaluation is our 16 comprehensive review of system functional requirements for 17 both normal and emergency operations.
18 I have ty ) follow-up slides on the status of our 19 material conditionI, commitments and three follow-up slides i
20 which will follow n design related commitments.
21
[ SLIDE.]
22 MR. BUCKMAN:
First, let's address material condition.N On January 14th, I indicated,that all specific 23 24 prioblems that were identified in the May 19 trip would be 1
25 fixed.
They have and this is simply a chart which-shows that
8 1
all of those are completed.
2 There are a couple that I would like to mention 3
specifically.
The third item down on charging pump start 4
failure and number five on letdown pressure regulator are two 5
items which led us to the conclusion that we had nearly a 6
complete rebuilding job in front of us with regard to our 7
chemical volume and control system.,
8 We have completed that rebuilding.
All shifts have 9
participated now in the tuning and testing of that system and 10 have been very complimentary with regard to the success that 11 we have achieved in that rebuilding.
12 I think it is a real success in terms of the extent
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13 to which our operations and maintenance people have worked 14 together to solve the set of problems which neither of them 15 could solve by themselves.
16 I would also like to mention that the next to the 17 last item, the turbine bypass valve, is a problem which has 18 plagued us since the plant started up in 1971 and we have j
19 replaced that valve with a valve that seems to be functioning 20 very well.
l 21 our steam dump valves being sluggish was one in 22 which I think at least in my review with the operations people 23 is one I saw a lot of skepticism as to whether we could really 24 solve that problem without going through the same kind of 25 valve replacement.
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l 9
1 We do expect that we will be replacing those valves r-2 in the long term but we completed our test on those valves on 3
Wednesday.
They have performed very well and I received some 4
very complimentary remarks from the control room with regard 5
to the extent to which that maintenance had been performed 6
properly.
7 Next slide, please.
8
[ SLIDE.]
9 MR. BUCKMAN:
With regard to task force issues, 10 material condition task force issues, there were 159 issues 11 which we said we would complete prior to startup.
of those 12 159 items, we have completed 155.
There are four in which we
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13 are still in hot testing to close out.
L 14 One of those will be closed out prior to startup and 4
15 three will be closed out during power escalation.
We have i
16 concluded that in order to completely close them, we would 17 like'to do some equipment trending at low power operation 18 before we close it out.
19 While not a specific commitment, I did want to i
20 mention that I think that we have continued to improve our 21 housekeeping.
It is better now than it was at the end of the 22 year and it was better at the end of the year than when it was 23 when we shut down.
24 I still think we have improvement that we can make 25 but I think we are along the right road with regard to l
l
10 1
housekeeping not only from paint and cleanliness but also
!T 2
in terms of getting at the root cause.of some of the 3
housekeeping problems and we have valves, valve leakage, 4
pumps, pump seals, things of that nature.
5 I wanted to mention open corrective work order 6
status.
Our current status with regard to outstanding 7
corrective work orders is at about 695.
Control room 4
8 deficiencies is at about nine.
I have a chart here which 9
compares those to where we were at year end and also year and 10 1985.
11 While we have not made much numerical progress in 12 terms of total corrective work orders since the end of the
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13 year, I do think that in terms of plant condition we are l
14 continuing to make progress.
15 I think we are seeing some success in getting people I
16 to continue to raise their standards in terms of when they 1
17 identify things that need to be fixed and frankly in this open i
18 corrective work order backlog that exists right now, we are 19 seeing a lot of things which I think a year ago would have 20 been characterized as plant betterment.
The things we would 21 like to do sometime, we are not getting people to say, " Hey, 22 let's do it.
Let's write a work order on it and get it down."
23 I would also like to mention a couple of specific 24 accomplishments here in terms of things that we have done 25 which I think point to perhaps the effectiveness of the
r-11 1
programs.
2 One is in the area of the primary coolant system 3
unidentified leak rate, something which has been an issue of 4
con.tinuing concern at Palisades.
We brought this plant up in 5
about late November /early December for some hot testing in 6
which we saw a PCS leak rate of about 0.1 gallon per minute 7
which we viewed as being very successful.
Our tech spec is 8
one gallon per minute and in this 0.1/0.2 gpm, we think we 9
have made some progress.
10 When we brought it up this time about the first of 11 March, the PCS leak rate was also at about 0.1 gallon per 12 minute.
Through steps and continued attention to detail we 1
13 have now brought that down to the point where it is under a 14 0.01 gallon per minute.
It is as tight as I have ever seen 15 the system and I think it is the kind of standard that we are 16 very happy that we can achieve that kind of a result.
17 In terms of work orders and the re-work on 18 maintenance, I reported to you in January that of 270 work i
19 orders that we tested while we were hot, we found five that 20 required some re-work.
During this set of hot testing so far, 21 we have worked off about 180, closed out about 180 of those 1
22 additional workers and we found four that required some 23 additional maintenance.
24 None of the four were to re-wo k maintenance that
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25 had been performed earlier but simply to perform additional I
_m-.
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f 12 1
maintenance on something in order to bring it where we want it
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2 to be.
3 That is much better performance that what we have 4
experienced in the past and I think is indicative of the 5
extent to which our maintenance folks are serious about proper 6
diagnosis and conducting the maintenance that needs to be 7
perfdrmed so that, operations can do their job.
8 I would also like to mention that we have been 9
successful in changing a cracked charging pump cylinder head 10 block.
We don't have a belly band anymore.
We have three 11 good charging pumps.
12 Next slide, please.
13 MR. McCORMICK:
Fred, I might mention just to add on 14 that maintenance order backlog 690, I believe, the number was 15 that that represents for us a little over a five week backlog 16 because we were at about 125 or 130 maintenance corrective 17 orders per week so that is roughly where we are.
18 Just to put that in perspective, you may recall the 19 slide we showed last time that back at the end of 1984, we 20 were close to 4,000 work orders with a very high percentage of 21 them being corrective so we have really brought this down 22 significantly.
23 COMMISSIONER CARR:
How are you doing with those 25 24 that are older than 1985, five back in 1983 and ten in 1984 25 and ten in 19857
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l l
1 13 1
MR. BUCKMAN:
We still have some of those there and
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2 I don't remember, Commissioner, exactly what the number is but 3
some of those that are of that age, we have a number that 4
require that we be in a refueling condition in order to get at 5
them.
6 We have to un-load the core and we decided not to do 7
that during this outage.
I don't know that we have made a lot 8
of progress there but we have reviewed each and every 9
outstanding work order to look at its significance not only by 10 itself but in the context of all the work orders we have and.
11 have satisfied ourselves that we don't have a problem there.
12 (SLIDE.]
13 MR. BUCKMAN:
I want to shift gears from material 14 condition to design to talk about where we stand with regard 15 to commitments in this area and let me refresh your memory.
16 What happened during this outage is part way through the 17 outage as we were working on material condition issues, we 18 uncovered some design problems and our focus shifted somewhat 19 from material condition to design and design-related issues i
20 and the resolution of those issues is something that we l
21 needed to do and needed to do in a thorough way before we 22 brought the plant back up.
23 The first of the commitments had to do with making 24 sure that we fixed the problem rather than simply the symptom
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25 in what we had identified and I have four examples up here of 1
, -. -,,.. -..., - -...... -.., ~. _. -.
r 14 1
areas where we have done that.
2 One is in the restoration of low-pressure safety 3
injection pump flow, one is in the area of component cooling 4
water flow where we have completely balanced the system.
In 5
terms of service water system capabilities we have submitted 6
an interim technical specification.
s 7
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We'are going to operate under restrictions with,
8 regard to service water temperature but we also have analysis 9
that is now being reviewed by the staff which shows that, I 10 think, we can get back to a position where we have more margin 11 than was originally anticipated when the safety analysis was 12 performed.
13
{
We have completed a set of modifications on a 14 recirculation actuation system logic to make it perform the j
15 way it should.
16 Next slide, please.
17 (SLIDE.]
18 MR. BUCKMAN:
The second area I wanted to mention is i
19 that of Safety System Functional Inspections.
We had committed 20 to resolve nine issues prior to startup.
All nine of those 21 issues are resolved.
The work is complete.
22 I will mention that in the ninth one which is 23 improvement in electrical and mechanical repairman training, 24 we havo our training modules in place.
We have buildings and
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25 classrooms, equipment and instructors in place and we do have
I 15 1
people going through the training.
2 Next slide, please.
3 (SLIDE.)
4 MR. BUCKMAN:
As a result of what we had uncovered 5
and what the Nuclear Regulatory Commission had uncovered in 6
the way of design issues, design-related issues, we decided to 7
design and perform a System Function Evaluation and then 8
conduct whatever tests were necessary as a result of that 9
evaluation.
10 Our commitment was to perform the evaluation, do the 11 test.
We have completed our review.
We identified 107 12 requirements that were not covered by routine operations or 13 surveillance.
14 Our commitment was to then verify those 107 15 requirements.
To do that we developed test plans for 139 16 separate tests or inspections and we are now in a situation 17 j
where we have verified 97 of the 107 requirements.
We have 18 completed 129 of the 139 tests and the remainder will be 19 verified and performed prior to start-up and then power 20 escalation testing.
21 (SLIDE.]
22 MR. BUCKMAN:
That is a summary of where we start i
23 with regard to commitments.
Iwantedt$brieflycoverwith 24 you our plant restart plan and also our schedule.
We have i
25 developed a plan.
It is a formal plan'with. step-by-step
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16 1
reviews and approvals.
It includes all of our normal 2
surveillances, or checklists and also the additional testing 3
that we are doing during this outage.
4 We have plant review committee review, plant safety 5
engineering and plant management review and approval to pass 6
each of the major milestones which include our heatup, critical 7
approach.and then power escalation holds at 30, 60 and 8
80-percent power.
9 We also have in our plan the conduct of an i
10 independent operational readiness review by Consumers Power 11 Company's Nuclear Safety Board.
That review is complete.
12 They were quite satisfied with what they found.
There were 13 some extremely complimentary comments on progress that we had j
14 made, thoroughness and completeness of the documentation that 15 we had to support what had been performed.
16 There were eight findings that were identified and 17 five of those eight findings have been added to the formal 18 restart plan as part of the approach to return to power.
i 19 We have also put plant management en shift during 20 hot testing and startup to ensure that the kinds of standards 21 that we are trying to maintain in this plant are standards 22 which are communicated all hours of the day and night, 24 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> per day through this entire program.
24 (SLIDE.)
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25 MR. BUCKMAN:
I want to say just a few words about
17 1
testing.
There are four components to our testing program.
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2 One is post-maintenance testing.
Then there is system 3
functional evaluation test, surveillance test and integrated 4
system test.
5 (At this point in the proceedings, commissioner 6
Bernthal entered the meeting.
7 MR. BUCKMAN:
I'n terms of po'st-maintenance testing, 8
we have used our operations and maintenance interface group, a 9
new group that we have developed during this outage, along 10 with our systems engineers to design the test that will be 11 used for post-maintenance testing.
12 This approach to post-maintenance testing replaces r
13 what we had used in the past which was basically shift t
14 supervisor judgment or conduct of a standard surveillance test 15 to return a piece of equipment to service.
16 To the extent possible, wa are doing full function 17 testing.
We have put in place a trending program to monitor 18 test data and follow equipment performance and during this 19 outage, approximately 3,000 maintenance orders have received 20 this type of operability testing.
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j 21 With regard to system functional evaluation testing 22 which I have already mentioned, we have 139 developed tests 23 and inspections.
The testing program for the SFE has taken 24 about ten weeks.
We expect to finish it about Monday.
25
[ SLIDE.)
t
l l
18 1
MR. BUCKMAN:
In terms of surveillance testing, we 2
have conducted just over 1,000 technical specification 3
surveillances during the outage and we generated about 17 a
4 special surveillance tests including balance-of-plant important
-5 to reliable operation test which will be used, called up as 6*
needed in the future.
7 The fourth leg of our testing program, the integrated 8
system testing, is one where we will have identified six 9
systems for integrated testing.
They are listed on the chart.
10 The CVCs, auxiliary feed, main steam system, component cooling 11 water system, service water system, feedwater and condensate 12 system.
i 13 These systems were selected based upon the extent of l
14 maintenance and modification that was performed during the 15 outage, the previous history of the systems, the interactive 16 nature of the components that exist in those systems and the 17 valuable of these systems in terms of operator familiarization
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18 and operator comfort, in terms of helping to transfer to the j-19 operator the extent to which this plant has been improved I
i 20 prior to restart.
21 (SLIDE.)
I have a chart which shows our 23 schedule.
It shows where we are.
There are just a couple of i
l 24 things I want to. call out on this.
One is that in the 25 maintenance and modification area, the'two items which sort of l
I i
r.-.-e--
-,n.,-y-un.
-w-.-
,,,,-,-m_--__
--a.-
19 1
brought us out longer than we had expected were the
, 7..
2 installation of nitrogen backup air supply to air operated 3
valves.
This is to provide some redundant air capability to i
4 air operated valves that had been fed off our instrument air 5
system and the other was the charging pump head replacement 6
which we were able to complete during this outage.
1 7
In the system functional testing, I would only 8
mention that the procedure, development to make sure that we 9
were conducting these tests in a controlled and smart way took 10 us somewhat longer than we had expected and the cold shutdown i
11 testing also was more involved than we had expected when I was' 12 in here on January 14th to present to you our schedule.
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13 At this point, we are going through hot shutdown i
14 tests and hot shutdown testing is nearly complete.
15 In the plant startup, we would point out that we l
j 16 pressurized our system during the week of February 9th.
We 17 started hot system testing about the week of March 2nd and we j
la are now in a situation where we expect to be in a position to 1
19 take the plant critical about the 27th of March and to start 20 power escalation testing about the 30th of March.
I 21 One final thing I would like to mention is the 1
22 bottom line, an operator refresher line.
We decided to take 23 each of our five operating shifts, take,them back to the 24 simulator for a week of training on plant startup, on emergency l
25 operation procedures, on modifications that had been performed l
l
. ~ ~,
,__-._..,___,___---.m__
.m..
l 20 1
during the outage simply to make sure that they were all fully
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2 prepared and ready to go at the time that we were-going to 3
bring the plant back on line.
4 (S LIDE. ]
i 5
MR. BUCKMAN:
I would like to close by saying that I l
6 think that we have made excellent progress in improving the 7
' plant material condition, that,we have taken an ag'gressive 8
approach to improving plant maintenance processes, that,the 9
plant design issues that we have surfaced have been managed 10 with, attention to making sure that we conduct a thorough 11 investigation, that we are aggressive in both the remedial and 4
12 the corrective action and that we have conducted an extensive I
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13 program of testing and evaluation.
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14 Our testing program is nearly complete and we have 15 an aggressive program in place to make sure that the kind of 16 progress and the kind of performance improvements that we are 17 looking at here are things which are sustained and not simply 18 one time.
19 That concludes our presentation.
20 CHAIRMAN ZECH:
All right.
Thank you very much.
21 Questions from my fellow Commissioners, Commissioner Roberts?
22 COMMISSIONER ROBERTS:
No questions.
23 CHAIRMAN ZECH:
Commissioner Asselstina.
24 COMMISSIONER ASSELSTINE:
Yes.
I think basically 25 what I would like to do at this point if you all are able to
21 1
do that is to go through some of the items in the December t
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4 2
22nd inspection report and try to understand how these findings 3
fit in with the program that you have just described.
4 I have to say that my impression has been both in 5
previous presentations and in the current one that you had 6
really put in place a pretty comprehensive program to look at i
7 the equipment in'the safety systems, to look at the design 8
questions and also look at the material condition of the 9
plant and really get the problems that have been building up j
over the years fixed once and for all so that when the plant 10 11 started up, was in good shape.
i 12 Having read the inspection report, it at least 13 raised some questions in my mind that I hope you can resolve f
i
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14 now and I also apologize since I haven't seen your response.
i 15 All we got was the inspection report.
We didn't get your 16 response to it.
i f
l 17 MR. BUCKMAN:
I don't know what the status is.
I I
18 unfortunately don't have that in front of me but let me say a l
19 couple of things to put this in context and to give you my 20 impressions of this.
21 The SSFI was conducted starting about the third week l
l l
22 in September and went through late October.
i 23 COMMISSIONER ASSELSTINE:
Right.
24 MR. BUCKMAN:
It was at about this same time, j
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25 probably starting about the middle of August or thereabouts, 1
. _. _ _ _ _ _ _ _ _ _ _ _ _ _.. _. ~ - _. _. _.
I 22 i
1 and of August, that we started uncovering design related 2
issues and I think it was the combination of our uncovering of 3
design-related issues and the SSFI that led us from a program 4
which would have had the plant back on line addressing material 5
condition concerns sometime in September or October of November l
6 to one which has us here in March talking'to you about restart.
i 7
There are a couple.of fundamental reasons for it.
r one is that the SSFI raised a number of issues that we thought 8
a 9
ought to be fixed and the other is that both the SSFI and our j
10 own programs had raised a number of things that said, "What 1
11 else should we look at?"
12 COMMISSIONER ASSELSTINE:
Right.
13 MR. BUCKMAN:
That was really the purpose of the 14 System Functional Evaluation which did not start until after 15 the SSFI had been conducted.
i 16 COMMISSIONER ASSELSTINE:
All right.
1 l
17 MR. BUCKMAN The purpose of the System Functional I
I 18 Evaluation was to say, "What are all of the things that we 4
1 19 expect our systems to do both in normal operation and also in 20 response to plant casualties?"
We went through for plant 21 casualties, for instance, we went through our emergency t
i 22 operating procedures, looked at each success path, whether it I
t 23 be using safety grade equipment or non-safety grade equipment 24 and said, "What is the system function that we are looking 25 for?"
i
23 1~
Now once we had identified all of the system 7
2 functions in each of the success paths through all of the 3
critical functions in the EOPs, we said to ourself, "To what l
4 extent do we already perform tests, inspections or observations 5
which assure us that the equipment will perform as it is 6
supposed to perform?"
1 7
Where we found exceptions, where we found that we 8
did not perform a test, an inspection or whatever, then we 9
maid, "Okay, this is an exception that qualifies for either 9
10 the performance of a test or the conduct of additional 11 engineering or something like that to assure ourselves that we i
12 can perform all of these emergency functions through every 13 success path that we have identified to support continued 14 plant operation."
i j
15 It is this SFE which has been the lead factor from 16 an analysis and testing standpoint from about the first of l
17 November until now in terms of the development of the I
j 18 procedures, in terms of really the formulation of the process, i
19 the development of the procedures and the conduct of the l
l 20 testing.
I i
21 So I don't look at the SSFI as something which 1
22 condemns wh'at we have done but only forms a basis or one of l
23 the bases for defining all of the thing that we have done l
l 24 during this outage prior to restart.
~
25 COMMISSIONER ASSELSTINE:
That really goes to the i
i I
~- _- _.. - __ _., _,.-....__ _ __ ___.__.. -
1-
24 1
heart of the questions that I have and I think it is sort of a i
2 three-tiered approach.
3 One is, were the problems that were identified in 4
this inspection fixed and the problems that you identified 5
through your own follow-on review effort?
6 Second, did you understand what caused ' hose problems t
7 and have you fixed the root cause so that you have some 8
assurance that from now on these kinds of problems won't 9
recur.
10 Third, given the fact that this was a fairly narrow 11 look at one system of the plant, is it indicative of problems' 12 in the rest of the plant and did your functional review effort
[
13 sufficiently cover the other systems of the plant so that if 14 we went back and took another look now at something other than 15 high pressure safety injection system that we wouldn't find 16 the same kinds of problems, that we really have assurance that 17 the equipment in the other systems of the plant will be able 18 to carry out their functions.
19 MR. BUCKMAN:
The answer to those questions is that i
20 in terms of fixing -- the first question, have we fixed the 21 problems that were identified, to the extent that we and the 22 NRC staff thought it was appropriate to fix those problems 23 prior to return to service, yes, we have.
24 There was a slide up there to say that we have done
~
l 25 that.
25 1
The second question, I think, was a question saying,
/
2 "Do you have programs in place to find other problems like 3
this?"
The answer is, I think that the SFE is certainly part 4
of that but I think there is a longer term part of it that has 5
to do with how are you going to manage your business from this 6
time forth and when we were down here in January we talked to 7
you about the fact that we are implementing a configuration 8
management program, a part of which will be conducting similar 9
types of reviews to the SSFI in other areas of the plant.
10 In fact, prior to the SSFI consumers Power Company 11 had performed a similar type of vertical cut evaluation in 12 parts the auxiliary and main feedwater systems and we found 13 that to be a very productive way to look at the interaction 14 between our plant systems and our administrative systems in 15 terms of how we manage plant configuration, design basis and 16 things of that nature.
17 So I think there is a continuing part of this, 18 Commissioner, which will carry on for several years in terms 19 of continuing to look and it would not surprise no that if two 20 years down the lire in our process of continuing to look, we I
21 were to find something.
22 But I think in terms of the kinds of things that l
23 caused this to happen in the first place, most of the things 24 that were identified here were things that were from original
~
25 design of this plant in 1970 and the fact is that the standards
26 1
that were appropriate in 1970 and the standards that are 2
appropriate in 1987 are different.
3 Palisades is one of those plants that has gone
.i 4
through an intermediate review.
We went through SEP in the 5
late 1970's and identified some of these things.
Some of 4
j 6
these things were identified in that SEP review and were found 7
acceptable then.
i 8
But I think that as standards continue to change, we 9
need to continue to recalibrate the way we look at these kinds 10 of problems and assess whether or not it is appropriate to 11 make change.
12 As with regard to the narrow nature of the SSFI that j
13 was performed, while it was narrow in its definition in terms
('
]
14 of the high pressure safety injection system, the extent to 15 which it got into supporting systems, particularly instrument 16 error and the electrical power system, is such that I do think 17 that a much larger part of the plant than just high pressure 18 safety injection were examined in the process of going through i
19 it.
j 20 COMMISSIONER ASSELSTINE:
Good.
All right.
If you 21 could just sort of bear me and I don't want to be unfair since l
22 you don't have the thing in front of you, but if I could just t
23 walk through a few of these things and get a little better
{
24 sense for again how you have addressed the specific problem, i
l 25 how you have looked at the root cause of the problem and how I
~.
27 1
that has been factored into your overall evaluation program, 2
that would be helpful to me.
3 MR. BUCKMAN:
I will try.
4 MR. FIRLIT:
For the other Commissioners, you may 5
want to turn to page eight.
That will probably track right 6
along with that.
7 COMMISSIONER ASSELSTINE:
I think, yes, some of 8
those certainly were covered at least in summary in the 9
presentation.
10 on page two of the inspection report, there is a 11 discussion as to the lack of seal-in feature for the recirc 1
12 actuation signal and the report notes that the water source 13 for the high pressure safety injection, low pressure safety 14 injection and containment spray pumps may unintentionally 15 shift from a reliable and sufficient source to a nearly empty 16 source.
The air available may not be sufficient to reposition i
i i
17 those valves back to the reliable water source.
/
18 It sounds like the problem that was identified was
~
l 19 that the air system won't be sufficient to shift the systemf_
1 20 back to a source of water and you could end up burning out.;'
I 21 your HPSI pump because it doesn't draw on water.-
Theissuethereisthatistkssafety i
22 MR. BUCKMAN:
l 23 injection refueling water tank empties, thwre id alchift that 24 takes place from that as a water source t6 the contairiMant i
25 sump and there are air-operated valves that funrd' ion -co.,,
7 l
28 1
perform that shift.
, ~ ~
2 There is a back-up supply of air to those 3
air-operated valves.
The question that was raised is, if the 4
water level gets to the point of actuation and sort of sits 5
there and forces the valves to go back and forth several
-6 times, will it use up the back-up air supply in the event that 7
the instrument air supply is not available.
8 This is not something which was a mistake in design.
9 This was simply a design feature that as build presumed to be i
10 acceptable in 1970 and one of those things when we look at it 11 today, we say, "We would like a higher level of reliability."~
12 Our approach to this was to provide a seal-in 13 feature and we also looked to see where else in the plant 14 might this be a problem.
We did not find any other seal-in 15 feature problems with regard to air actuated valves.
We did 16 find one fast transfer circuitry in the electrical side that l
17 had a similar type of philosophical approach to it and we are 18 looking at making a modification there as well.
l,',
19.
COMMISSIONER ASSELSTINE:
All right.
Another one l~4*
20 weg overheating when the HPSI pumps are operated against a l
~
t 21 i shutoff head which is a probable occurrence during many
.~.
?
22'..
.saftlldorea el.dcn scenarios.
s.-
t,
l i
23 The f.nding was that the team was also concerned i
,. c 24 that the lich sse had not taken steps to demonstrate the i+ 'a
?
25 adequacp of'tha recirculation flow when confronted with
,y I
.6 i
s
l
- e l
29
'l evidence in 1984 and again in March 1986 that the recirculation jc 2
flow was not sufficient or may have degraded as a result of 3
. blockage.
4 I guess one of the things I'was concerned about is didyoulookatwhywheNyouhadthatinformationbackin1984 5
6 and earlier in 1986~you didn't follow up on it and address the 7
problem-and what have you done as.asresult of your review 8
effort to make sure that that kind of a practice doesn't occur 9
in the future and hasn't affected other equipment in the 10 plant.
T 11 M R..' B U C K M A N :- Isthink that the principal problem 12 there was one of recognizing the priority of,it and in the
.(
13-January 14th presentation, one of the things that I talked
\\
14 about was the extent to which this plant had undergone turnover 15 in 1963 and 1984 and 1985.
16 Frankly, we had some system engineers who were 17, pretty low on the experience curve and I don't think recognized 31 8 how critical this peint was.
We have managed to stabilize the 19 work force in terms of turnover.
Our system engineers are 20 frankly getting experience right now at the rate of about two 21
. or three years per year in what we are going through right now.
22 In terms of the specific issue, we have conducted 23 the test and verified the recirculation flow capability.
24 i
COMMISSIONER ASSELSTINE:
All right.
The next one 25 has to do with check valves in your air systems that isolate r
ew w-r
~
m- - -
-,-w,
-*y-,,_
_y, e.-,, -.
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em_m.,,,,g
,a-y_e g w_
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i
30 1
safety-related piping from non-safety-related piping and the y-i 2
finding was that those were not periodically tested to ensure 3
their ability to' perform their design safety function.
4 Now admittedly, those are check valves in air 5
. systems rather than water systems but we have been hearing a 6
lot about check valves and you'all have been hearing a lot 7
about check va,1ves ever since San Onofre.
8 I guess what I am wondering is, why was that one 9
still a problem in the fall of last year?
Is it something 10 you had not identified and again, if you didn't, what have you 11 done to make sure that that kind of operating experience 12 elsewhere gets picked up and you pay attention to it?
13 MR. BUCKMAN:
In terms of the specific question, we eg-14 had not identified it.
In conducting the tests, we found that 15 there were a couple of check valves that had enough dirt and A
16 grit and whatever in terms of obstructions that there was not 17 a tight seal.
18 So in addition to performing the test, we did a lot 19 of cleaning and refurbishment of our check valves and have 20 added all of the air check valves on a periodic testing 21 program to assure that they are tested.
22 As to why this had not been picked up, I think that i
23 there were two contributors neither of which is particularly i
24 helpful.
one is that they were air systems rather than water i5 25 systems and most of the focus had been on water systems and
31 1
the other is that these are identified as being part of a j
2 non-safety system and there is still some change taking place 3
in terms of culture within the plant with regard to the extent 4
to which we look at those differently.
5 I think that we are, making a lot of progress but we 6
are not 100-percent of the way there right now.
7 COMMISSIONER ASSELSTINE:
Another one was battery 8
surveillance and I guess one of the things that concerned me 9
was that the staff seemed to be saying that the problems they 10 found in your battery surveillance procedures were the same 11 kinds of problems that had been previously identified for 12 Palisades.
13 When you see those kinds of repeat performances or s
14 repeat problems particularly when you are mid-way through a 15 kind of a major upgrade program that gives me some concern 16 about whether the program is really working.
4 17 MR. BUCKMAN:
Well, the battery surveillance problem 18 is one that I think falls in a special category and that is 19 one where there has been a technical disagreement, a 20 professional disagreement, as to what is technically 21 appropriate.
l 22 Frankly, the plant staff has argued for a long time 23 that what they are doing is appropriate, it is consistent with 24 manufacturer's recommendations and that the rest of the world
~
25 is wrong.
This was sort of a straw that broke the camel's
v 32 1
back so-to-speak with me and I asked that we look at this from
.,(
2 another standpoint and that is, in the battery manufacturer 3
willing to accept the surveillance program that is used by 4
everyone else and if he is, let's do it rather than continue 5
to argue that what we are doing is more appropriate, let's 6
fall in step with the rest of the world.
7 MR. FIRLIT:
The basic difference there is that we 8
were going by the manufacturer's recommendation when we 9
discussed this and identified this problem.
The difference 10 here is that we were not following the IEEE standard.
We have 11 committed to just flip-flop and just go ahead and follow the 12 IEEE standard.
13 COMMISSIONER ASSELSTINE:
All right.
~~
14 MR. FIRLIT:
So that problem should go away now.
15 COMMISSIONER BERNTHAL:
Excuse me, you are saying 16 that the manufacturer's recommendation did not conform with 17 the IEEE standards?
18 MR. FIRLIT:
That's right.
l 19 COMMISSIONER ASSELSTINE:
Less stringent, yes.
20 MR. BUCKMAN:
It is not they are less stringent, 21 they are simply different.
22 COMMISSIONER ASSELSTINE:
Different, yes.
I 23 MR. BUCKMAN:
Ithastodowitgwhentheequalizing 24 charge is applied and the position that I have taken is, it is
~
25 no longer as important what the manufacturer recommendations
m 33 1
as the best way to do it, if he is willing to accept the IEEE
.s 2
standard as something which won't damage his equipment, that 3
is what we are going to do.
4 COMMISSIONER ASSELSTINE:
The next area that had 5
caught my attention was motor-operated valves, lack of a 6
preventive maintenance program and the program for controlling 7
torque swi ch and limit switch setpoints, the inadriquacies in 8
those areas.
9 Motor-operated valve problems have been around for a 10 while and again the concern I had was why is this something 11 that was still a problem as of September / October of 1986.
12 MR. BUCKKAN:
That is something that had been fully 13 picked up in our program earlier and had been identified as 14 part of the material condition task force.
15 In terms of addressing motor-operated valves, we 16 had, in fact, done a fair amount of work on motor-operated 17 valves in terms of inspections prior to the SSFI and coming 18 out of the SSFI was an agreement to do some additional work in 19 terms of non-qualified grease and inspection on, I think, four 20 valves with the remainder to be picked up as part of IE 21 bulletin 85-03, some work that we are intending to do in the i
22 September / October time frame.
l 23 We are planning on taking a maintenance outage in 24 the fall, had already planned on doing it at that time and I 25 don't think that there was a big concer'n with regard to i
34 1.
whether.we picked it up.
We were just talking about what the
/'
2 appropriate time frame was to do various types of work.
3 COMMISSIONER ASSELSTINE:
All right.
In terms of 4
the HPSI system not satisfying the single failure criteria 5
particular, I guess, with regard to the air system, is that j
6 something now that has been corrected?
7, MR. BUCKMAN:
I don't remember.
I don't remember 8
what the schedule is for dealing with that issue.
That is 9
just one that i's not at the top of my head.
1 10 MR. FIRLIT:
This is the one that deals with the 11 nitrogen bottles?
12 MR. BUCKMAN:
I don't know.
13 COMMISSIONER ASSELSTINE:
The finding was the HPSI 14 system was not single failure proof in that the minimum flow 15 recirculation valves CV-3027 and CV-3056 were both supplied l
16 from the same train of the high pressure air system.
This was 17 contrary to FSAR Section 6.1.4.8 which states that the safety i
l 18 injection system, including the fluid and instrument 19 subsystems, were designed to, meet the single-failure criterion.
20 MR. BUCKMAN:
I simply don't remember what the 21 answer is in terms of when that one is being addressed.
22 COMMISSIONER ASSELSTINE:
All right.
23 MR. FIRLIT:
Ken Berry might have the answer.
He is 24 here today.
25 COMMISSIONER ASSELSTINE:
A l l 'r i g h,t.
Maybe the
?
. ~
35
.1 staff can help out on that one when come up here.
('1 2
CHAIRMAN ZECH:
Perhaps the staff can respdnd to 3
that when you come up.
They indicated they can, fine.
4 COMMISSIONER ASSELSTINE:
Let's see.
Another one 5
was the failure of your voltage study to address motor control 6
center loads.
The dynamic voltage regulation studies that 7
were performed in 1983 and 1985 to evaluate tne ac system 8
during an accident were limited by the number of buses the 9
computer program could handle.
10 As a result, the smaller loads fed from the motor 11 control centers were grouped together as a single bus load.
12 This modeling technique apparently resulted in a less thorough 13 review of the individual loads fed from the motor control 14 centers.
15 I guess there again, I would be interested in 16 understanding how you fixed that problem.
17 MR. BUCKMAN:.And I don't know the answer to that 18 one either.
19 COMMISSIONER ASSELSTINE:
All right.
20 CHAIRMAN ZECH:
Maybe the staff can help with that 21 one, too, when they come up.
22 COMMISSIONER ASSELSTINE:
All right.
There was also 23 a comment on control of design calculat ons, that the inability 24 to identify the design bases of a system or component was 25 considered a weakness in the program.
1l --
36 l'
I guess, again, if you can't identify the design
,r ',
2 basis or component of the plant, isn't that a concern in terms 3
of assuring its safety reliability and how have you gone about 4
through,the corrective program to assure that you really do 5
understand the design basis for safety systems throughout the 6
plant.
s 7
MR.-BUCKMAN:
I think that is an important issue and 8
the way it was characterized for me at least is there were no 9
specific incidents or at least not many, I don't think tnere 10 were any, in which we could not retrieve the design basis.
11 The question was with the difficulty of doing so, that our 12 information is not kept in one place and in clear system 13 descriptions and in ways that you would really like to have it 14 today in terms of our ability to do that.
15 That is part of what we have put in our configuration 16 management effort is to reconstitute and clarify the design 17 basis for the important safety systems so that we do have it in 18 one place to facilitate safety reviews, facilitate modification 19 reviews and things of that nature.
20 COMMISSIONER ASSELSTINE:
Is that an effort 21 that has not only taken a forward look but has also taken a 22 retroactive look to satisfy yourselves that you really have 23 captured the existing design basis'for systems and components?
24 MR. BUCKMAN:
Yes, it is intended to do both.
25 MR. FIRLIT:
One of the things" thAt we did commit to
37 1
you is that by the end of March or when we went into a 2
configuration management program that part of that is the 3
design basis documentation.
4 Our plant as you know was built in the early 1970's.
4 5
We suffer from the same problems that your Turkey Point, 4
Connecticut Yankee, Rancho Seco and Davis-Besse suffer from.
6 7
We go back to the vendpr or the AE such as Bechtel and the 8
people that designed our plant are no longer with them so 9
we are going to have to go back and reconstruct how some of 10 those numbers were put into our FSAR so that we understand 11 what they are and what the safety margins are as well.-
j 12 COMMISSIONER ASSELSTINE:
Do you all have that 13 information now or is it still pretty well scattered among 2
14 vendors?
l 15 MR. FIRLIT:
We have files of some of the data on 16 the calculations and so forth and we are digging that out as 17 the configuration management team is starting to get in 18 place.
We do not have everything, I think, that we would like
-19 to have at this particular point and we will probably find 20 that out as we start going through our investigation.
l 21 COMMIESIONER ASSELSTINE:
The staff also looked at, a
22 I guess, a selection, it looks like eight of your 50.59 1
23 evaluations for plant modifications tha were done and out of 24 the eight, they found that three of them were deficient.
l 25 How have you gone about fixing'that problem?
Have 4
38 L
1 you taken a look back at the 50.59 evaluations that you have g
2 done for the plant over the course of its lifetime to satisfy 3
yourselves that you haven't adversely affected the design 4
basis of the plant in the modifications that have been made in 5
the evaluations that you have done on those?
6 MR. BUCKMAN:
I don't know that we have gone back 7
and looked'at the other 50.59's yet.
We have spent some time 8
counselling the people that conduct the 50.59's with regard to 9
this finding and addressed it more on a prospective basis so 10 far.
4 11 We are also right now looking at potential saninars 1
12 or classes or teachers or things that we might use to help us 13 in terms of improving this.
Again, to some extent this falls
~
14 back into the same area with regard to experience.
).
15 There are a lot of requirements for conducting 16 50.59's, some of which and up, I think, in the past have been i
i 17 done who don't have the same experience that I would like to 18 see in terms of who is doing them today.
19 I think that is part of that problem.
But to the i
20 best of my knowledge and Joe, you might be able to help me, I 21 don't think that we have gone back and looked at the past 22 50.59's that have been conducted.
23 MR. FIRLIT We have gone back,on a sampling basis i
24 to find out and have not uncovered any real major problems l
~
25 there at all.
}
1
}
39 1
COMMISSIONER ASSELSTINE:
All right.
2 MR. FIRLIT:
But in addition to that what Fred is 3
saying is that because of the turnover that we had in our 4
experience level, I have now limited the 50.59 reviews only to 5
those that are on the plant review committee.
So there is 6
really only about six to eight of us that can make that x
7 evaluation at this point.
8 COMMISSIONER ASSELSTINE:
So you have controls from 9
now on.
10 MR. FIRLIT:
We have controls until we bring somebody 11 into train us better on the 50.59's so we get more people 12 involved with that process.
f 13 COMMISSIONER ASSELSTINE:
All right.
I guess the 14 final point I would just note that the inspection report 15 wasn't all negative.
One of the positive findings was on the 16 qualifications and experience and knowledge of your operations 17 perr.onnel.
So I guess I would just note that, that the report 18 did have a positive finding on that one.
19 That is all I have, I think at the moment.
I want 20 to explore some of the same issues with the staff when they 21 come up here.
22 CHAIRMAN ZECH:
Fine.
Commissioner Bernthal.
23 COMMISSIONER BERNTHAL:
IthingIwon'tprolong 24 this.
I think I also would like to hear staff's response to a
~
25 number of the issues that were raised in this December
-~.
40 1
document.
2 How many of the Commission have been out there at 3
the plant?
4 COMMISSIONER ASSELSTINE:
I have.
5 COMMISSIONER CARR:
I have.
6 CHAIRMAN ZECH:
I think three.
7 COMMISSIONER BERNTHAL:
Good.
The reason I ask is 8
that my sense is that many of the problems that you had there 9
fall in the category and I think TVA experienced difficulties 10 of what I call cultural change is necessary and, in fact, you, 11 yourself, may have used that term.
12 I would also like staff to speak a little more
', (
13 broadly to the question, one of the sentences in this December t.
l 14 22nd staff report that commissioner Asselstine just quoted 15 from was that, I believe he did, that many of the safety I
16 related motor operated valves had not been re-lubricated in 17 almost 15 years.
18 That begins to sound a little too familiar a 19 pattern.
I believe that we saw a similar pattern at Rancho 20 Seco, a similar pattern at Davis-Besse and one begins to i
21 wonder whether it isn't time for everybody to take a careful i
i 22 look at how many such systems have not been maintained since 23 the plant was built.
l 24 As you know by now, you can get into trouble that 1
25 way.
I b
41
-1 MR. BUCKMAN:
I might comment that with regard to
. f' T
2 re-lubrication that while we did not re-lubricate them during-3 this outage, we did inspect the lubrication in all of the I
4 safety related valves and found that the lubrication was 5
adequate both in terms of level and also in terms of 6
consistency.
7 COMMISSIONER BERNTHAL:
All'right.
8 MR. FIRLIT Let me add a little bit on to what we 9
are going to do about the MOV's here.
In the fall when we 10 take our maintenance outage, we are going to go through all 11 the safety related Mov's that we have at the plant and you are 12 talking approximately at our plant of about 45 valves.
13 We have already contracted with Babcock and Wilcox.
14 They are on site currently right now and they are looking 15 through all the MOV's that we have.
We are trying to project 16 in advance what some of the parts may have to be in terms of 17 replacements.
We will go through the whole MOVAT test program, 18 the whole works.
19 In addition to that, one of the other things that 20 was in the SSFI findings there that you didn't mention there, 21 Jim, was the training of our maintenance people.
22 COMMISSIONER ASSELSTINE:
Yes.
23 MR. FIRLIT:
We have aggressively attacked that 24 problem.
Our training center is really over there at Midland,
~
25 Michigan.
It was built there because we had three plants and
42 1
that is why it was centralized over there.
If we built it 7
2 today, it would be over at Palisades.
3 What we have done is in South Haven which is only 12 4
miles from the plant, we have rented a building, we have 5
brought over 12 instructors, we have two mechanical guys that 6
teach our people how to repair valves, we have one electrical 7
repair instructor and one I&C individual.
8 In addition to that, we signed a $1.8 million dollar 9
contract with B&W to come in and help us train our people 10 right on the job.
11 so currently right now, we have four engineers and 12 four technicians that work side-by-side, one-on-one, to train 13 our people on how to repair these stainless steel valves and 14 you could ask, "How did it take you 15 years to get to that 15 point?"
I can't answer that.
All I know is that we had a 16 problem.
We are correcting that problem very aggressively.
17 In addition to that, when we have the maintenance is outage, what I plan on doing is that we will bring in an 19 additional 40 of the repair technicians from B&W, John Crane 20 is a subcontractor to them, and we are going to attack the 21 valves at our plant.
22 That is the major last issue that we have at our 23 plant is the valves in terms of the maintenance backlog.
24 COMMISSIONER BERNTHAL:
Good.
I look forward to 25 coming out and seeing the plant myself.' I remember hearing
43 too many things about Palisades in the early years of its 1
2 operation when I was living in Michigan.
I hope to come out 3
and see a plant that is considerably improved.
4 I have one question that might be silly but I am 5
going to ask it anyway.
It wouldn't be the first time I asked 6
& silly question.
7*
COMMISSIONER ROBERTS:
There is no such thing as a s
silly question.
9 CONNISSIONER BERNTHAL:
As I recall when this plant 10 was planned and built, it was probably in the late 1960's, mid 11 to late 1960's and I think the lake was about at a historic 12 low then and I believe that right now, it is about at a 13 historic high.
Does that make any difference for any of you?
14 Is there a potential for some problems there down the road?
15 MR. BUCKMAN:
Let me address that.
The answer is 16 yes and we have had some tough some problems particularly 17 during stormr..
Ne are on the east side of the lake so the 18 west winds and the northwest winds tend to bring in both lake 19 levels and also pretty high waves.
20 Ne have gone through a substantial shore line 21 protection project dealing with both the north and the south 22 shores, have just finished some additional work on the north 23 shore, have some sore work that we are going to do next year 24 on the south shore and we think we are in pretty good shape
~
25 with regard to it.
44 1
We went through a period in 1985 where we lost some 2
security fence as a result of a combination of high wind and 3
and I don't know whether there was ice involved with it at 4
that time or not, but it is a tough problem but I think that l
5 we have a way of -- you know, the amount of protection that we
{
1 6
have installed is such that it is less of a problem than it 7
might otherwise be.
i 8
MR. FIRLIT:
Let me expand a little bit.
We had 9
just installed a 1.2 modification to the north shore of our 10 fence line there and that was after it came out there.
We 11 completed that in the first week of December of 1986.
About 12 two weeks later we had a major storm in Michigan and the fence
(
line is still there and the improvement worked but it is a 13 14 concern of ours.
15 COMMISSIONER BERNTHAL:
Well, I hope to take a first 16 hand look.
Thank you very much.
l 17 CHAIRMAN 2ECH:
Commissioner Carr.
18 COMMISSIONER CARR Would you give me a few words 19 on personnel turnover since last Thanksgiving, how is your 20 personnel stability right now?
21 MR. FIRLIT Our personnel stability is very solid.
l 1
l l
22 I don't have the chart in front of me right now but I would say j
23 that we probably haven't lost more than five people at the very l
i 24 mose.t our,1 ant.
It has eeen very seas 111 ed.
i 25
.One of the things that you had' talked about was the l
l i
45 1
culture of the organization and that is something that we had 2
to do deal with over the last two and half years and I have 3
taken it upon myself to sit down with small groups of people.
4 I didn't want to use it as a filter to go through managers and 5
so forth.
6 I took it upon myself to accept that responsibility 7
and I sat down with small groups, procurement, operations, a
health physics, our engineers, our managers and the whole 9
works and told them how the world was changing and what the 10 expectations were from the NRC, from INPO and also from us and 11 we had to change.
12 I have seen a culture change at that particular 13 plant.
In fact, one of your NRC gentlemen from Region III had 14 been out there for two weeks and he came up there and said, 15 "There is a real attitude change on the part of your people."
16 In fact, he said, "One of your operators" quote, said that, ha 17 says, "You know, I complained about this plant for a long 18 time" and he says, "The management is absolutely listening to 19 us now and they have changed their attitude and they are 20 improving the plant."
21 He says, HI guess noW it is my turn to change my 22 attitude" and it is changing.
So I was very happy to hear 23 that not for myself going out there but from somebody from the 24 NRC, an independent party telling me that.
25 COMMISSIONER CARRt So you fee"1 the personnel
46 1
problems are behind you?
2 MR. FIRLITt I think our personnel problems are 3
behind us.
I think that they see a strong leadership in the 4
corporate management underneath Bill McCormick and that our 5
company is going to be a winner.
6 COMMISSIONER CARRt-All right.
The second comment I 7
would make is the routine that I beat on and that is, you keep 8
talking about taking care of your safety-related MOV's and 9
that leaves out a lot of them that you are not telling me 10 about.
11 MR. BUCKMAN:
It is only a question of timing.
12 COMMISSIONER CARRt All right.
I don't just like 13 those two-philosophy maintenance programs.
14 MR. BUCKMAN It is not a two-philosophy maintenance 15 program but there is a question of priority and what we are 16 planning on doing is doing the safety-related valves in the 17 fall of 1987 and the rest of the valves in the 1988 refueling 18 outage.
19 MR. FIRLIT We are fortunate from that standpoint.
20 We only have about 60-plus motor operated valves at our plant 21 and we thought we would break up the work load and get about 22 40 during the maintenance outage that are safety related and 23 do the non-safety related during the refueling outage but we 24 will get them all.
f 25 COMMISSIONER CARR It was the~phiAosophy that
47 I
worried me.
i 2
MR. BUCKMAN:
Let me say something about the 3
philosophy and that is that I an one of those people who feel 4
strongly that we shouIdn't do them all at once.
From what I 5
have seen --
6 CONNISSIONER CARA:
In case you are doing then 7
wrong?
8 MR. BUCKMAN:
People have been having as much or 9
more problems right after they go through and do a lot of 10 valves as they did before they did them that we simply are not 11 smart enough with regard to all this stuff that I am willing 12 to feel comfortable doing them all at one shot and I would 13 rather break it up into two pieces, do a good piece of them, 14 find out what we learned, what we can transfer to do the next 15 time and make it a step-wise process rather than a revolution 16 in the plant.
17 COMMISSIONER ROBERTS:
It sounds to me like you 18 ought to do the non-safety related first if you have that sort 19 of concern.
20 MR. BUCKMAN:
We thought about that but first of 21 all, there are some regulatory requirements that stand in the 22 way of doing that and secondly, I think that from a priority 23 standpoint, I really would prefer to do the safety-related i
j 24 valves first.
l\\.
25 I think that those are the one's th.at in cur plant, 4',, - - -, - - - -
48 1
the ones that if there are questions outstanding, basic 2
questions outstanding with regard to the ability to perform, 3
we would like to find it out first for those.
I am not 4
unhappy with the order but I do think that splitting it up and j
5 doing it in two pieces as we did with our turbine by-pass 6
valve and steam dump valves, those are five valves that are 7
all of a similar design.
8 We decided not to go through a wholesale' change out 9
on all five.
We are going to do one.
We are going to try i
10 it.
If it works, same type of valve is going to come in on 11 the other four and it is comparable philosophy here.
12 We are going to do part.
We are going to learn
^
f l
13 something.
We expect to stumble and make some mistakes and l
14 things like that and we expect to be better the second time 1
15 around.
16 CHAIRMAN ZECH:
Anything else?
1
/
17 COMMISSIONER CARRt No.
i l
18 CHAIRMAN EECH:
Could you discuss just a little bit 4
19 more in detail about your independent operational readiness i
20 review?
You mentioned it and you said you got a lot of that.
21 What did they do?
Can you just briefly give us some of the I
22 things that they did and some of the conclusions they came to?
i l
23 MR. BUCKMAN They came in for three days, March 24 9th, loth and lith and we had about six or eight people.
All
~
25 of them are people that do not have direct line responsibility
49 for the management of the plant, the head of our nuclear 1
2 assurance department which has safety analysis and quality 3
assurance, our manager of licensing, people who have long 4
operational experience but are not today involved directly in 5
the operation of the plant.
6 CHAIRMAN EECH:
Are they consumers Power company 7
people?
8 MR. BUCRMAN:
They were all Consumers Power Company 9
people and they looked at material condition, readiness of 10 systems for return to operation.
They looked at training that 11 had been performed both regard to general operator training 12 and also with regard to specific systems and modifications 13 that had been performed.
14 They looked at modifications that had been performed 15 with regard to documentation, with regard to safety reviews 16 and things of that nature.
17 CHAIRMAN 2ECH:
Did they go over this report that we 18 have been referring to here?
19 MR. BUCKMAN:
Yes, they did.
They went over that 20 report and went over other inspection reports, did system 21 walkdowns to look at specific systems and they identified 22 eight findings and we can go through all eight if you would 23 like but generally there was one with regard to cleanliness in 24 containment that they didn't feel that the same standards had
~
25 been applied with regard to cleanliness and containment that
O 50 I
had been applied in the rest of the plant.
2 There was a finding with regard to preventive 3
maintenance which was later dropped.
4 CHAIRMAN IECH:
Let me just ask you, when I was out i
5 there I was concerned a little bit about the follow-through on 6
some of your programs.
I think you will remember that was one 7
of my comments.
l s
Did they talk about that?
Did they talk about your 9
communications and your interrelationship with your 10 departments?
11 MR. BUCEMAN They did interview people at all 12 levels.
They interviewed operators.
They interviewed maintenance people.
They interviewed supervisors, system 13 14 engineers looking for whether or not the same systems or the i
15 same standards that Joe Firlit had and I had were the same l
16 standards that were being applied out on the floor.
i 17 CHAIRMAN 2ECH:
Did they give you an assessment of is how your people are working together, your various departments 19 working together or as they working as little fiefdoms?
j 20 MR. BUCEMAN In fact, there was a specific 21 observation that was given to as that the operations department l
22 and the maintenance department are working closer together than 23 they ever have at any time in the history of the plant.
24 MR. McCORMICX:
Mr. Chairman, I was over at the -
25 plant just a couple of weeks ago and spent,the whole day, went
~
f 1
i
51 1
through the plant, walkdowned some of the systems and spent
(-
2 some time in the control room with the operators and one of 3
the questions I had because I knew it had been a continuing 4
problem was the priority that nome of the operators were 5
giving maintenance items were not the priorities that in the 6
past that some of the maintenance people --
7 CHAIRMAN ZECH:
Let me just say that having reviewed 8
the situation fairly carefully, I think, most of us concluded that for a long time you were not operating at a level that it 9
10 was marginal, it was good, it was satisfactory but it was 11 below average or maybe a little below that.
12 MR. McCORMICXI Exactly, right.
13 CHAIRMAN ZECH:
And that was for a period of time.
14 So what my concern is, did this operational readiness review 15 focus on anything that you should be doing or that you are l
16 doing that will indicate that you have turned the corner and 17 you are now going to follow through on some of these programs.
18 programs are fine but they have to be executed, they 19 have to be implemented and so we have to have the confidence, l
20 at least I do, that you are implementing these programs that 21 you are talking to us about because your track record hasn't 22 been all that good.
23 MR. McCORMICX:
It hasn't been that good and I think 24 we have discussed at the previous meeting what some of the j
25 problems have been that caused that.
~
3 52 1
CHAIRMAN 2ECH:
Did this operational readiness
~g.,
2 review board give you an assessment that you are on track and 3
you are improving and give you the confidence that your 4
programs are being executed and implemented as well as just 5
put in place?
6 MR. McCORMICK Yes.
7 MR. BUCNMAN:
They looked at it, Mr. Chairman, from
,8 the standpoint of results.
9 CMAIRMAN 2ECH:
That is what I as talking about, 10 results.
11 MR. BUCNMAN In terms of the --
12 CHAIRMAN 2ECH:
Points on the curve not just talk.
1 13 MR. BUCNMAN These people were out looking at the
{
14 plant.
15 CHAIRMAN 2ECH:
That is what they looked at.
16 j
MR. BUCKMAN:
One of the people on this committee l
17 was a person who was the first operations individual assigned 18 to Palisades in 1968.
He caught me in'the hall on Monday of l
19 this week and he said, " Fred, that plant is in better condition i
20 today than at any time it has been in since 1968."
21 CHAIRMAN 2ECH Well, we would kind of hope so.
22 MR. BUCKMAN:
so do I.
But what I am saying is that 23 they looked at it from that perspective.
What does the plant 24 look like?
What do the systems look like?
25 CHAIRMAN ZECH So you think you got a good solid
~
53 1
candid evaluation from these people and it gave you'the r
2 confidence that you are on the right track, is that what you 3
are telling me?
4 NR. BUCENAN Yes, sir.
5 NR. McCORMICK Yes, sir.
I think the numbers speak 6
for themselves.
7 CHAIRMAN EECH:
Well, again, results count.
Numbers 8
count, yes.
I want to see points on the curve.
i want to see 9
results and follow-through.
That is what comes from programs 10 that are being implemented properly and in the past, it looks 11 to me like anyway that you haven't done that very well so we 12 need the confidence to know that now your programs are in 13 place and they are being implemented properly and that you are 14 following through and you are watching it.
15 NR. BUCNNAN We are measuring how we are doing and is I think that that is a key to continuing to improve.
17 CHAIRMAN 2ECNt All right.
Fine.
18 NR. McCORMICK Let me just say another word about 19 that.
I think it falls into two categories.
one is equipment 20 and the other is people and I think on the equipment side if 21 you look at the numbers, we have really reduced by a factor of 22 about four to five the number of outstanding work orders in 23 the plant.
24 We have cut the control room deficiencies from about 25 60 down to nine.
The jusper-link and b'y-pass numbers have
54 1
decreased very markedly.
2 I think if you look at the material condition side 3
of the plant the results over the past year have been dramatic.
4 CHAIRMAN EECH:
All right, fine.
5 MR. McCORMICK:
On the people side, I think our C
turnover has gone from double digits down to two or three 7
percent and I think we have a very serious management 8
commitment to make this plant operate well and keep it 9
operating well.
10 of course, part of that is the new management in the 11 company.
It has only been in place for a little over a year 12 and two of the three people here were not with the company a 13
{
year and a half ago.
14 Fred and I and we certainly have a commitment to 15 make this one of the better performing plants in the country.
16 CHAIRMAN ZECH:
All right.
Fine.
Any other 17 questions before we call the staff?
18 COMMISSIONER BERNTHAL:
I have one more question.
19 CHAIRMAN ZECH:
Go ahead.
20 COMMISSIONER BERNTHAL:
Consumers has gone through 21 some difficult financial times in the last year or two as 22 Mr. McCormick is acutely aware.
23 Mr. Buckman and Mr. Firlit, do you get enough money i
24 from Mr. McCormick to do what you feel needs to be done or are l
l 25 you financially constrained in any way'thema days or what is
,s i'
55-1 the situation?
2 MR. BUCKMAN:
I think we are fitdncially constrained 3
but I don't think it is standing in the way of progress.
I, 4
think that we are getting enough money to do what needs to bo 5
done.
6 CHAIRMAN ZECH:
Is it standing in the way of safety?
7 MR. BUCKMAN:
No, it isn't.
8 CHAIRMAN ZECH:
All right.
9 MR. FIRLIT:
In addition to that, I fool an i
10 obligation to my management to project beyond this year and, 11 next year and we have been working with Westinghouse and we t
12 will have a five year plan in place that I can sit down with 13 g
Fred and with Bill McCormick here and say, "Here is if we want s
14 to be one of the top utilities in the United States which we 15 want to be, here is what it is going to take" and it is my 16 obligation at this time to present that plan to them.
17 In terms of money, we went well over the budget last 18 year.
There was no restrictions on me at any time.
- f. can 19 tell you as a plant manager the other thing I had appreciated 20 is that when Bill McCormick came out to the plant and ha 21 said, " Joe, there is no pressure from me whatsoever to put 22 this plant back on line, you do what is right, you way to make 23 sure that you understand what the stand rds are.
When you 24 satisfy yourself, I am sure you are going to satisfy me and 25 you are also going to satisfy the NRC."
l
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1 So /that in the type of commitment that I have received ab, / plah,(tranag$rfrommyuppermanagementbothfr r
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3 Fred and fro $a Bi.ll'.
4
, q
. CHAIRMAN ZECH:
All right,. fine.
I think we should e.
E<
call the statf up;n$v unless there are further questions.
l
.G,.
Thank you very each.
We appreciate it.
i l'
S 27 Vic, ara /you going to lead off?
8 MR. STELLO:
Yes.
Very quickly, let me give you my j
9 bottom line and that is that we are prepared to after i
10 satisfactory completion of the hot functional test recommend i
j 11 that the Commissicn vota to allow the restart of the plant.
i 12 I will ask Jim in a moment to give you a run down of
(
13 the people are here and introduce them as well as what we are t.
lb 471ng to do in light of all the questions that came up on
' 15 the SSFI r.icults.
I 16 We h%d already included that in our presentation.
(
1*!
We did mention at the last Commission meeting that we had done j
18 it and we are preparod to go through the results and the 19 fo.llow-upithat we did with it but maybe what we ought to do is
[
20' to try to deal with the questions that were raised that i
J1 waran't answered und any other questions you might have.
'J 2 Ci! AIRMAN ZECH:
Why don't you do that first and then 2h get into your own presentation?
24 MR. OTELLos All right.
We will just start that 1
2b pt.ct of the presentation then.
~
I l
i
57 l'
CHAIRMAN ZECH:
Fine.
2 MR. STEIlo:
If We can, Jim, I will ask you to 3
introduce and to skip the presentation and start with the e
4 results if we can.
5 MR. SNIEZEK:
Fine.
Let me go across the table.
6 l' First at the end at my far right.is Bill Guldemond.- He is a b'
7 branch chief in Region III who is also the team leader of=the 8
readiness review inspection team.
Next to him is check $
t3 i
9 Norelius, the Region.III projects division director; Bert 10 Davis, you know.
' 3 11 On my left,is Ashok Thadani.
He is the branch chief 12 in NRR and Jim Taylor, you know.
Also in the audience, we n [~
13 have Tom Wambach, the project manager from NRR for Palisades.
! t 14 CHAIRMAN ZECH:
Stand up, would you please?
15 MR. SNIEZEK:
And Eric Swanson who is the senior 16 resident inspector for Palisades.
17 CHAIRMAN ZECH:
Thank you.
18 MR. SNIEZEK:
May I have slide one, please?
19 (SLIDE.]
20 MR. SNIEZEK:
What we are going to discuss today 21 basically are the resolution of design deficiencies and Ashok 22 Thadani will be discussing those covering the service water 23 design deficiencies and the component cooling water design 4
24 deficiencies as well as the program for resolution of other 4
(_
25 design deficiencies identified from the Saf,ety System
\\
5
-,.____,,-,.,,--m,,.
.--,~.-m...-.
4 58 1
Functional Inspection and during the licensee's configuration
/
2s management program.
3x Then Chuck Norelius will discuss the inspection 4
program for restart with' emphasis on plant readiness including 5
the status of the 50.54 (f) letter regarding the plant material 6
condition and also the operational readiness including the 7
Safety System F nctional Inspection results.
8 I would like to turn it over to Chuck first to 9
depart to discuss some of the SSFI findings that were 10 questioned by the commission.
11 CHAIRMAN ZECH:
Fine, thank you.
Proceed.
12 (SLIDE.]
^
13 MR. NORELIUS:
Let me just say generally that we 14 found 16 separate' findings.
They listed nine but there were 15 some sub-categories, 17 total but 16 of those that we thought 16 were appropriate that they should fix prior to restart.
17 They have fixed each of those-and Mr. Guldemond will 18 be happy to address in detail those fixes that you would like 19 to address and we can do that right now since that was the 20 essence of your question, if you would like, Commissioner 21 Asselstine.
22 CHAIRMAN ZECH:
Why don't we do that quickly if you
.23 can.
24 MR. GULDEMOND:
Commissioner, ould you care to 25 focus on one item or another or perhaps go.through your list
~
59 1
again and I can speak to them individually?
r
(
2.
COMMISSIONER ASSELSTINE:
Let me just say that my 3
broader concern is do we really understand what is there given 4
these kinds of inspection results, not just what was done to 5
fix these individual problems, but do we understand what is j
6 there in that plant, whether the design as it now exists is
.7 a,dequate.
8 Certainly we can go through some of the individual 9
items but that is the broad issue.
10 CHAIRMAN ZECH:
I think the broad question is the 11 one you want answerad.
12 MR. STELLO:
Let me deal with the broad question.
I 13 want to make sure.
There seem to be questions as to whether
.{
14 each and every one of those have been resolved adequately.
I 15 want to assure you thSt they have been.
We have looked at 16 them and we are satisfied.
17 COMMISSIONER ASSELSTINE:
All right.
18 MR. STELLO:
With respect to the broad question, one 19 of the things that I don't think is adequately understood, 20 this plant was reviewed with standards and a process that was 21 in place back in 1965, as I recall, 1966 and if you look at 22 the volume of information that we had for this application at 23 that time versus the volume you have to ay, you are talking 24 literally orders of magnitude in the type of information that i
25 we get today in terms of design information which is not only
~
i
60 1
information we get but information that we demanded at that 2
time that both'the manufacturers and the designers had'in 3
terms of the calculation and the techniques that were used.
4 What we are doing today is looking for a far more 5
comprehensive understanding than really existed.
It is a 6
shifting set of standards and you are talking over.20 years of 7
a shift.
So you have to expect that as you try to bring these l
8 plants up to where you have the kind of understanding we have i
9 today, this is going to be a very slow meticulous and difficult 10 process.
11 A lof of the things that we have today that we 12 require today, they don't even exist.
There are techniques 7
13 that are used today that were not used then.
14 COMMISSIONER BERNTHAL:
How many plants are in that 15 category today?
16 MR. STELLO:
I think it is a shifting set of 17 standards that goes over with time, Palisades, Oyster Creek, 18 Nine Mile, certainly Big Rock and Black Bar are even more so 19 than those and the standards and the review process and the 20 procedures that we have shifted with time.
21 COMMISSIONER BERNTHAL:
I am forgetting though, 22 would you say this was one of the first ten, Vic, or the first 23 20 or where did it come?
24 MR. STELLO:
It was probably, if I had to guess, it
~
25 was probably the first 15 or 20, in that ballpark.
i
E
\\
q 61 1
COMMISSIONER BERNTHAL:
Have we looked at the other 2
15?
3 MR. STELLO:
We can find out.
Part of the rationale 4
that we used_to present to the Commission a long time ago in 5
the early 1970's, 1973/1974 about the need to start an SEP' 6-program--
7 COMMISSIONER BsRNTHAL:
Severe accident policy?
8 COMMISSIONER ASSELSTINE:
No, a systematic evaluation 9
program.
10 MR. STELLO:
-- and that is how it all began.
11 COMMISSIONER BERNTHAL:
But the severe accident 12 policy is also in that?
13 MR. STEL10:
It gets into an even broader context.
14 But that is the rationale that was used of recognizing that we 4
15 had to do that.
So philosophically, there clearly is a 16 difference between some of these earlier plants and the later 17 plants.
18 COMMISSIONER ASSELSTINE:
In fact, that is what they 19 were given provisional operating license.
20 MR. STELLO:
There were a bunch of other reasons 21 behind the provisional as well, yes.
22 COMMISSIONER ASSELSTINE:
And it is still operating 23 under a provisional operating license.
It surprised me.
24 MR. STELLO:
That is a procedural process that is a 25 nightmare, too.
But that is the broad'phil.osophical answer
N o
62 1
to why you do see these kinds-of problems.
(,
2 We started our inspection, we are getting into the 3
efforts.
I think we are making a lot of progress but it is 4
.not going to come quickly.
I don't want to leave any false 5
hopes that even we know all of what to do to try to bring 6
plants up to a level of understanding according to where we 7
are today.
8 COMMISSIONER BERNTHAL:
You were not far off.
They 9
were number 18 to be licensed.
10 MR. STELLO:- Between 15 and 20, that is 17.5 was the 11 average.
12 COMMISSIONER ASSELSTINE:
Right on the mark, yes.
13 MR. TAYLOR:
Mr. Chairman, may I just add --
14 CHAIRMAN ZECH:
Please, go ahead.
15 MR. TAYLOR:
-- that in this type of look at these 4
16 older plants, Vic has characterized the past.
I think it is 17 very important to remember as the staff has looked this hard 18 and has found issues like at Turkey Point where we started 19 some of this and some of the other plants, the important thing 20 is that the company is taking the type of look that I think 21 Consumers is to re-evaluate, to look at the accident type 22 conditions and be sure that the systems will meet what was 23 intended and what is expected in the design.
24 That has been going on at Turkey Point as you are l
25 aware in a continuing way and they are identifying.and fixing
s 63 1
. issues that some of them are pretty subtle, but they are there
'2 and I think that is-the characterization that we have looked 3
at the way Palisades has attacked their problems.
4 MR. DAVIS:
And as they go into their configuration 5
management program, I would be surprised if they don't some 6
more things that need the same kind of attention and fixes 7
that Turkey Point has.
L 8
MR. TAYLOR:
As Mr. Buckman.
9 MR. DAVIS:
Yes.
10 MR. STELLO: ' One last one, I think there was a
~11 change in this industry that I have observed.
In the early 12 years and even not too many years ago, there was enormous
~, -
13 reliance on the vendors and the architect engineers and we as
(
\\
14 an agency didn't put a great deal of pressure on making sure i
15 that the utilities started to acquire and develop the kind of 16 design basis understanding in the facilities.
That emphasis 17 wasn't there.
18 Hence, they really relied and in fact, you have some 19 examples of not too many years ago where utilities were l
20 relying, they were literally just saying, "Okay, build me a 21 plant and then when you are finished,,give me the key and I 22 will operate it."
23 That kind of an attitude was one that was very,'very 24 prevalent in the beginning of the early application commission 25 of nuclear power.
That is changing and we,are forcing, if you
s 64 1
will, utilities'to make that change.
They are forcing it unto 2
themselves and that is why INPO, NUMARC and some of these 3
other things have been created to recognize the 4
responsibilities of the utility in that understanding.
5 It is, and we are in the middle of a process of 6
change.
So what I would suggest is that is the best answer I s.
7 can think of in terms of why it has happened but if there is 8
any question as to whether we have, in fact, pursued any of 9
those, if you will accept of telling you we have, they are 10 finished but any of them that you would like to go into any 11 more detail on, we would be happy to do that.
12 MR. NORELIUS:
Could I narrow down the responsa just 13 a little bit from what I think you asked?
14 COMMISSIONER ASSELSTINE:
Yes.
15 MR. NORELIUS:
We looked at this in terms of not 16 only specific corrective actions but also generically was 17 there anything that the SSFI told us that was not encompassed 18 by the other findings that they already had.
19 I think the answer is no.
It is just more of the 20 same types of problems and so our view in terms of Palisades 21 is that the system functional evaluation which they have gone 22 through would address the immediate concerns as to whether 23 these systems can meet their functional requirements and as 24 Bert mentioned, the configuration manag ment program yet to 25 come will more broadly address the design basis questions.
4 65 1
COMMISSIONER ASSELSTINE:
Let me focus on a couple,
(-
2 maybe just a couple of the instances.
One of your findings 3
was the high pressure safety injection system doesn't meet the o4 single failure criterion.
You say in the inspection report, 5
"This design deficiency will remain unresolved pending 6
follow-up by the NRC Region III office."
7 Could you tell me how that one has been fixe,d and 8
how you have satisfied yourself that the follow-on evaluation 9
by the company has ensured that, in fact, this plant. meets our 10 regulations and there aren't failures to satisfy the single 11 failure criterion?
12 MR. GULDEMOND:
The specific issue was the s
13 recirculation valves, main floor recirculation valves?
14 COMMISSIONER ASSELSTINE:
Yes, and the high pressure 15 air system, right.
16 MR. GULDEMOND:
The high pressure air was the unique 17 mode of supply to the valve.
18 COMMISSIONER ASSELSTINE:
Right.
19 MR. GULDEMOND:
The tact taken by the utility in 20 response to this particular issue was to add a back-up nitrogen 21 supply system which is of safety quality or "Q" listed.
22 They added this back-up supply system with check 23 valve isolation to these particular valves.
In addition, they 24 went back and they reviewed other valves and components which 25 were supplied by the high pressure air'syst.em exclusively s
.,..,,.,.,---..n,,---.~,-.
}
66 1
and/or other dedicated air supplies.
r 2
For example, nitrogen accumulators or air 3
accumulators and from that perspective, they added additional 4
back-up nitrogen supply systems to ensure a reservoir, a 5
dedicated reservoir, of compressed gas to operate those valves 6
post accident.
7 Recognize that in many of the ca'ses, there was air 8
available but if you lost a non-safety related instrument air 9
system, it could impact valve operations so they covered that i
10 tact as well.
So they took a broad look at those types of 11 valves to ensure that there was adequate air to operate the 12 valves in a post LOCA environment and modified the systems as
('.
13 appropriate.
\\
14 COMMISSIONER ASSELSTINE:
All right.
Does that i
15 address the broader concern on reliance on non-safety air l
16 systems as well?
I 17 MR. GULDEMOND:
Yes.
18 COMMISSIONER ASSELSTINE:
All right.
How about the 19 broader question?
How do you know that there aren't other 20 vulnerabilities just like that in other systems?
21 MR. GULDEMOND:
Single failures?
22 COMMISSIONER ASSELSTINE:
Yes.
23 MR. GULDEMOND:
The SSFI looked at a number of these 24 systems in terms of power supply availability and actuation 25 and did not identify any particular pro'blems in this regard.
.o.
67 1
The licensee looked at this as well.
2 One issue did come up recently on a containment 3
hydrogen monitoring system where there was a question on 4
redundancy and diversity of power supplies which indicates 5
that the licensee is looking very hard at this.
6 They identified that issue and they are in the 7
process of fixing it.
So there is evidence that they have 8
been looking for these types of problems.
9 CHAIRMAN ZECH:
Can we move along with the briefing?
l 10 COMMISSIONER ASEILSTINE:
Sure, that's fine.
We can 11 go back.
12 CHAIRMAN ZECH:
You can go back to anything you want 13 to pick up.
(
14 COMMISSIONER ASSELSTINE:
That's fine.
(
15 MR. SNIEZEK:
All right.
At this time I will turn 16 it over to Ashok Thadani who will discuss resolution design i
17 deficiencies.
18 CHAIRMAN ZECH:
All right.
19
[ SLIDE.]
20 MR. THADANI:
At the last briefing we identified 21 that there were two issues, design issues that we were still 22 working on that had not been resolved up to that point, two 23 issues related to the flow deficiencies in the service water l
24 system and the component cooling water system.
l (..
25 May I have the first viewgraph', please?
l
s.
68 1
(SLIDE.]
2
'MR. THADANI:
In terms of the service water flow 3
system, there are three pumps each capable of providing 4
50-percent of the required flows.
During testing that 5
consumers was conducting on this system they recognized that 6
the actual flow was somewhat lower than the design flow that 7
was expected from these pumps.
8 It was roughly six to nine percent less than 9
expected.
They backfilled the impellers and the current flow 10 is well in excess of the design flow right now.
That problem 11 has been taken care of.
12 Another issue that was raised during this period 13 related to the distribution of the service water flow since it 14 provides cooling to various loads.
They recognized during 15 their testing that flow to certain equipment may be 16 insufficient for certain accident sequences.
17 The specific accident sequence of concern was the 18 design basis accident, loss of coolant accident, followed by 19 loss of offsite power, followed by a failure of a specific t
20 diesel generator.
21 What this resulted in basically was elevated 22 temperature in a specific room, actually two rooms, which l
23 contained the ESF equipment.
Our judgm nt is that the issue 24 does not have significant safety concerns, nevertheless, they s..
25 did not meet their requirements.
~
L
69 1
The actions they have taken have been basically r
2 two-fold.
They have isolated flow.
They provided capability 3
to isolate the flow to certain containment air coolers which 4
. would not be available under this accident sequence anyway 5
because of loss of that specific diesel generator and they 6
provided capability in the control room so that service water 7
flow to'those coolers could be isolated and re-directed to 8
these rooms where more flow is required.
9 They have also-conducted very conservative analysis 10 to see what the room temperature would get to and concluded 11 that if the limit, the service water inlet temperature to 58 12 degrees that the design temperature limit for those rooms
(' ~
13 will not be exceeded and now this is the design limit.
14 They have added yet another margin of five degrees 15 to service water inlet temperature and proposed a limit of 53 l
16 degrees under which they would be operating.
17 We, of course, recognize that lake temperature is l
l 18 going to get warmer over the coming months and that we paed to j
19 resolve this issue for a higher inlet temperature.
20 They have recently had Westinghouse conduct a very 21 thorough, more realistic analysis which we are told is yet t-22 conservative but somewhat more realistic than the earlier 23 analysis.
24 We have a meeting with consumers and Westinghouse at 25 which they presented the results of these studies.
They
~
~ - --.-
y _ _.
O 70 1
believe that the service water inlet temperature can go up to 4
2 80 degrees and yet they would be able to meet all the necessary 3
limits.
4 We are going to pursue that issue with them some 5
.more over'the coming weeks and do anticipate resolv'ing this.
6 They have also should the analysis approach not 7
work, they have looked at alternative changes they could make, 8
design modifications they could make, so that in the coming 9
weeks and coming months they can go to an elevated temperature 10 limit.
't 11 Some of the ideas they have been thinking about have 12 been automatically isolating service water flow to coolers.
13 At this stage we are not convinced that that is a good idea 14 because we see some downsides to going forward with such 15 changes but the one that appears very promising is insulation 16 of piping but they are going forward and conducting studies 17 and, I believe, ordering necessary equipment that may be 18 needed should it be necessary.
4 I
19 It is quite conceivable and certainly I am optimistic i
20 at this point that the analysis would show that there really is 21 no problem, that we do not need to pursue other measures.
That 22 is the service water system issue.
23 May I have the next viewgraph, please?
v 24 (SLIDE.]
i 25 MR. THADANI:
Again, component coo, ling water system
~
l
71 1
also provides cooing to various essential and some f
-2 non-essential equipment.
This deficiency was also identified 3
by the licensee as part of the extensive look at the plant and I
4 what they found was that since 1971 certain valves had been
,5 throttled down such that the flow through these heat exchangers 6
was significantly lower than had been considered in the design.
7 The reason behind that throttling was that the heat 8
exchangers were undersized, significantly undersized.
They 9
went back and they re-looked, conducted a bunch of tests to 10 see what position they could get these valves at to get 11 maximum flow without causing flow induced vibration in these 12 heat exchangers.
- (
13 They had support from a heat exchanger manufacturer 14 in this process and they have modified the position of the 15 valves to prevent any vibration induced problems.
They have 16 also dona re-analysis to see with the existing conditions what i
j 17 would be the consequences.
l l
18 In this case we were particularly concerned about l
19 the containment conditions and they have shown to us, we have 20 reviewed the analyses and approved that the changes are 21 minimal in terms of the containment environment.
l 22 If the system had been performing as designed, we 23 calculated a containment pressure of 22 psig and temperature i
24 of 230-degrees.
The containment design limits are for i
s 25 pressure, 55 psig and 283-degrees Fahrenhet,t for a. temperature
~
l l
i
72 1
limit.
/
2 With this revised condition of the valve 3
repositioning, the calculations indicate a peak pressure of 27 4
psig which is still well within the design and the temperature 5
is 237-degreed Fahrenheit which is also well within the 6
design.
So we believe they still meet all the design limits 7
and we are satisfied with the situation as is as far as these 8
design issues are concerned.
9 So basically in summary we are finished with all of 10 our activities in terms of these design issues.
We do 11 anticipate some more work in looking at the service water 12 inlet temperature issue and the SSFI related design issues 13 have also been looked at by Region III and unless you have 14 other questions, we will go to the next phase of the 15 presentation.
16 CHAIRMAN ZECH:
All right.
17 MR. STELLO:
Chuck, do you want to pick up?
18 MR. NORELIUS:
If I could have the next slide, 19 please?
l 20 (SLIDE.]
l' 21 MR. NORELIUS:
When we were here before we discussed 22 with you the status of that time.
We were awaiting the j
23 licensee's final response on the 50.54( ) letter.
That has 24 since come in, been reviewed by us and we find that acceptable 25 so we have an acceptable description of.their programs for l
l l
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- - - = " - - - ' - - - - - ^ ' - - - - - - " "--*-^ - ~^~""~^ --'~" ~ "
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l 73 1
corrective action.
f 2
We also said that we had a two-phased approach 3
toward assessing the readiness of the plant to restart.
The 4
first which was in progress at that time we called plant 5
readiness.
That was the inspection led by Mr. Guldemond and 6
that was focused on hardware equipment issues to see if we l,
7 felt the plant itself was ready.
8 The second phase is what we have termed an 9
operational readiness and that is more oriented toward 10 personnel communications type things in terms of the plant 11 being ready.
We were over there with a team last week.
We i
12 plan to go back once the plant goes critical and goes up in 13 power.
14 So I want to go through each of the items under the l
15 plant readiness inspection.
Next slide, please?
1 l
16 (SLIDE.)
l 17 MR. NORELIUS:
To assess the material condition we 18 looked at the material condition task force report, the work i
19 order backlog, modification backlog, did some system walkdowns 20 and operator interviews and I will come back to those last two 21 a little bit.
l 22 But on the first three, the team did a line-by-line 23 item-by-item assessment of every item that was there and they 24 looked at it in terms of the resolution of the specific item.
25 They looked at how the priorities were"s<et.in terms of whether
O 74 1
it should be fixed now or whether it could be delayed after f
2 startup.
It looked at the schedule.
3 They also looked at it from a system basis to see 4
how many of these particular items might affect the operability 5
of a particular system and, of course, in the walkdowns and 6
all, just assess the general material condition of the plant.
7 We conclude that the material condition of the plant 8
is substantially improved especially the main power block 9
area.
We think there is adequate justification from a material 10 standpoint to support those items that have been deferred.
11 In making that assessment they looked at the safety 12 significance of items, whether or not they might inhibit an 13 operator in doing his job properly and deferrals are primarily 14 based on need for a further engineering review, availability l
15 of parts or plant conditions.
16 We believe they have prioritized the systems properly 17 and the company has already addressed the backlog and goals l
which we think are headed in the right direction and basically 18 19 under controls.
So from a material condition standpoint we are I
20 satisfied that the plant is ready to go.
21 Next slide, please.
l 22 (SLIDE.]
2 23 MR. NORELIUS:
In the maintenance program itself, we 24 looked at a number of administrative pr cedures.
We concluded 25 that the procedures are adequate althou'gh m,aybe somewhat 1
i
-y
-.,,,a.,-__
--.--.,..__,_,,--.,.-..-____..n-.-.-.
75 1
cumbersome at this point but they are adequate to provide a
,f 2
framework for the maintenance program.
3 The preventive maintenance program still needs some i
4 upgrading and the procedures there also need to be addressed i
5 but in general, the procedures were found to be adequate.
6 We looked at the organization for the maintenance.
7 The company has done two things that has increased their 8
effectiveness in this particular area that are worthy of 9
note.
j 10 They have put an interface group in the operations 11 department which reviews work requests, sets priorities, hold -
12 planning and scheduling meetings so that they now have them f
13 more in a confined, identified process, what has priorities,
\\
14 what can get done at particular outages, et cetera and that 15 has significantly helped.
16 secondiy, they have selected system engineers for 17 each of 33 major systems in the plant and they are in the 18 maintenance department and they are constantly there and can 19 understand the systems and better help in making changes and 20 so we believe that has been an improvement.
21 We looked at the staffing levels.
They supplemented 22 their staff to drive the backlog down.
We believe they have 23 an adequate staff to maintain that curre t once they get'it 24 down to the levels that they wish to.
'\\
25 We did identify some initial problems in inadequate
~
l
76 1
staffing in their planning and scheduling area.
They were 2
having a backlog of paperwork but they have corrected that' 3
over the last three or four weeks and there were about 100 in 4
there initially and that has been driven down to about 40 5
now.
So they are making progress in that.
6 We looked at equipment performance trending.
The 7
licensee has, instituted a rather comprehensive computerized 8
program and they now have it loaded with about three years of 9
equipment performance data.
10 They are just now in the process of being able to 11 use that to effectively trend the performance of equipment but-12 that is their plan and that information will be fed then into 13 their preventive maintenance program which is really just 14 getting off the ground'now.
15 You may recall their-goals are to have about a 16 50-percent break on corrective maintenance versus preventive 17 maintenance by the and of next year.
We believe they have the 18 tools in place now to develop that program properly.
19 We looked at training and I believe they have l
20 already addressed that in terms of their new facility at South 21 Haven for their maintenance people.
That is a positive 22 indicator so we are satisfied with the training program, also 23 with respect to the maintenance program.
24 Next slide, please.
s 25 (SLIDE.]
l
~
77 1
MR. NORELIUS:
We discussed the SSFI findings so I 2
will move past that one at this point.
We can come back to it 3
if you wish.
4 Next slide, please.
5 (SLIDE.]
6 MR. NORELIUS:
The major cornerstone I would say 7
really at this point.in terms of addressing whether the 8
systems generally function properly is the licensees system 9'
functional evaluation program.
10 This is where they took 33 systems and they went 11 through and identified the functional requirements, success 12 paths they have called them, to make these systems operate to
(',
13 meet FSAR requirements, tech spec requirements, emergency
\\
14 operating procedures, general operating procedures and then 15 they also evaluated the tests that had been performed to see 16 if they could demonstrate that the systems would meet those 17 functional requirements and where they had not performed tests in the past or they felt the tests were insufficient, they 18 19 identified special tests that were required to satisfy those.
20 We looked at the general methodology, agreed that it 21 was good.
For identifying the criteria for performance 22 functions and the testing, our inspectors looked independently 23 at five separate systems to see if we would come to the same 24 conclusion that they did.
25 We found some questions and some d,1fferences but our
~
78 basic conclusion is that those tests did satisfy the basic I
2 intent of the program and requirements that through that 3
review they identified the proper functions, they identified 4
the proper tests to demonstrate that those systems will
'~
5 perform their requirements.
6 Let's go to the next slide.
7
[ SLIDE.]
8 MR. NORELIUS:
I said I would come back to this.
9 The question has been raised here about attitude and we felt 10 that this was important and we interviewed initially two 11 complete shifts of people and last week have interviewed some 12 more people both in the maintenance and operations department.
{
13 The operators believe that the material condition of 14 the plant is as good or better than it has ever been as long i
15 as they have worked there and they are right now enthused 4
16 about that.
17 They also believe that the management is sensitive 18 now to their concerns.
Operators have been represented in 19 deciding what items need to be fixed and what don't.
They l
20 have had a voice in that.
i 21 They have been encouraged to lower their threshold i
22 in terms of identifying problems.
I believe the company has r
23 done that.
We have done that and they now believe that the i
24 attitude with regard to identifying and getting corrective i
25 action on material condition is very go~od.
79 0
1 They still would express, I guess, cautious 2
optimism.
They say that they would like to see that happen 3
over a little longer period of time before they would j
4 absolutely say that it has changed but for right now they see 5
a considerable change in attitude and in the plant operations.
6 Next slide, please.
7 (SLIDE.)
8 MR. NORELIUS:
We also did systems walkdowns and 9
that lists the systems that we looked at initially.
This was 1
10 especially for the purpose to identify material conditions.
11 Initially when we started the inspection back in late December, 12 we did find some items that we thought should have been tagged
,r 13 for corrective action.
'i 14 That was discussed with the utility and our later l
15 inspections have indicated that they have adopted a lower 16 threshold for identifying items that need to be fixed.
17 But based on this, we would say that the work order 18 backlog that they represented is a good representation of what l
19 is in the plant, that the problems are being identified I
l 20 appropriately and the numbers that you see are real numbers 21 that represent plant conditions.
22 Let me just mention without going back, I said that i
{
23 we do have an ongoing inspection which a more personnel i
24 communications oriented.
What we saw last week is that the i
25 communications are good.
They seem to be working as a a
i
80 1
1 consolidated team.
We get pretty good feedback on that part f
2 of the program.
3
.In the training we looked into a special concern was l
4 given the number of modifications and all, have the operators d
5 been appropriately trained in those.
The company told you l
i 6
what they were doing.
We went over and spent some time at the s
7 simulator and watched them and were convinced that they are, 8
in fact, providing pretty good training for the operators on i
9 the changes that have been made.
10 Before I go to the general conclusions and you can 11 put the.next slide up, let me just mention that on all of 12 these issues the staff currently is evaluating all these t'
13 findings with respect to enforcement that might be taken and 4
D j
14 that is currently under staff review.
15 (SLIDE.)
t j
16 MR. NORELIUS:
Our general conclusions first is that 17 significant improvements have been made in the power block material condition.
We specified power block and I didn't 18 1
19 mention earlier, there are a couple of out buildings that deal 20 with radwaste and feed water purity that have been put lower i
21 on the priority.
The company plans to get at those but they 22 are not in the same material condition as the main aux l
23 building, turbine building, reactor building areas.
24 We believe that the system fun tional evaluation 25 including the special tests some of whi'ch are still going on
81 1
provides reasonable assurance that the problems either have f
2
.been identified or will be identified through the testing that 3
still has to be done prior to startup.
4 We secondly conclude that the maintenance process 5
itself has been streamlined.
We believe that meaningful goals 6
have been established in terms of corrective maintenance, 7
preventive maintenance program, and that they are ongoing in 8
the right direction to achieve those goals.
9 We believe that management is exhibiting a 10 conservative attitude toward operations and material 11 conditions.
We believe that the licensee has adequately 12 addressed the issues that are necessary to establish the plant
(
13 readiness for restart and as I say, some of those tests remain
(
14 to be done.
15 We also are satisfied with the longer term 16 commitments that have been made for improvements.
I think the 17 configuration management program which has been discussed is a 18 major undertaking that will get to the questions on design 19 basis of the plant and the company has committed to provide us 20 with that program by the and of March at which time we will 1
j 21 meet with them and follow that along.
22 They also have a five year plan.
They have an 23 augmented surveillance program, a valve improvement program l
24 and are working on a preventive maintenance program.
All of I
25 these, we believe, contribute to our vi~ew o,n the long term
82 e
1 commitments which we are satisfied with'.
. s 2
From our standpoint, we plan to develop a program to 3
monitor the sustained improved plant performance.
When we i
4 were here before I began by describing a history of Palisades's 1
5 performance back from 1981 and I think we said that it was 6
spotty.
It had gone up and down.
l 7
So we are going to make sure that we have an a
augmented program to monitor each of these things that they 9
have in place to assure ourselves that it is not an up and j
10 down situation at this point but that it is one that progresses 11 on track based on the commitments which they have made to us.
12 Based on that, we conclude that we believe that it i
13 is appropriate to authorize and would recommend authorization
,k j
14 for restart of the Palisades plant.
15 MR. STELLO:
That concludes our presentation.
16 CHAIRMAN ZECH:
Thank you very much.
Questions from 17 my fel. low Commissioners, Commissioner Roberts.
18 COMMISSIONER ROBERTS:
No.
19 CHAIRMAN ZECH:
Commissioner Asselstine.
20 COMMISSIONER ASSELSTINE:
Just a few more.
If I 21 could go back to the provisional operating license question I
l 22 for a minute.
This plant, Fred tells me, received its 23 operating license in 1972 so it has been operating for 15 24 years under its provisional license.
W at are the outstanding 25 items to convert that to a full term li~cens,e and which ones s
83 4
1 are significant and when are they going te get resolved?
/
2-How long is this plant going to cperate under51 3
provisional license?
l 4
MR. STELLO:
Mr. Wambach, the project manager, will'-
5 answer that questions.
~
6 CHAIRMAN ZECH:
Fine.
Pleauiidebtifyyourself.
7 MR. WAMBACH:
Thomas Wambach, project ziareger frr;.m 8
the Office of Nuclear Reactor Regulation.
9 Palisades was one of the plants that vey in.the 10 systematic evaluation program.
Whenthesysteadicevaluation i
-11 program was started, it was determined that none cif the plants 12 that still had provisional licenses would have their licenses s -
{-
converted until the process was complete.
13 14 COMMISSIONER ASSELSTINE:
- Right, i
15 MR. WAMBACH:
We completed tho' process with i
16 Palisades, I believe our IPSAR was issued in 1982, supplement 17 in.1983.
There were some open items that we thought at the l
18 time were significant and for which we should wait to Eenvert 19 the license, j
20 One was possible single failure problem with the 21 main steam isolation valve.
Another nagging problem that we 22 have had over the years with it has been thair steam generators '
l.
23 which suffered degradation early on and ths plugging so that
~
1 24 they are about 25 to 27-percent plugged.
That degradation has 25 been slowed down.
~
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1 In fact, I believe in the last few refueling outages,
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2 there have been very little' additional deterioration.
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d Probably,, I think; right now we' have scheduled the provisional 4Y 3
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license to be conve,rted in 1988 if no other significant issues
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5, come up in the meantime.
(>
i 6
- i. i1 COMMISSIONER ASSEL3 TINE:
All right.
How many w
- 7 plants dih'you kmw offhanddare still running under provisional 7
1 d
x 8i 0.icensas?
(l, n
,e 9
$4R. WAMBACH:
I believe it is like about four.
10
, CG. THADEI:
Yes.
I think it is about four.
11 MR. WAMBACH:
Millstone was already converted.
N 12
.There is Lacrosse.,Tpere is San onofre-1.
There is Palisades
[
9
% :g 13 f
g and there is one other one.
l s
(
' 14 MR. STELLO:
We will get you the answer as part of l
25,
tha record.
We will send it down and we will give you the
(
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16
'cNplete list.
s
\\
s 17 4:OMMISSIONER ASSELSTINE:
All right.
Fine.
Could
?s
- 13 you give me a feel for when you look at the program at this
.r 19 pojnt how it compares to Davis-Besse at the time that that
[
plant was restarted and how it compares with Turkey Point 20
[
21 toda??
+
j,,
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22/
I guess what I am interested in is on material
~
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j
/ 23 condition and design _ questions in particular, how do you think l
,24 the scope and depth;of the programs at this plant stack up g
with what was done a't Davis-Besse and i~n terms of how much 25
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. _. _ _ _ _. ~. _. _. _ _. _ _ _., _ - _ _ _ _. _ _.. _. _ _ _
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- D 11 they have gotten done prior to this point in. time as compared r
2 to Davis-Besse'when that plant restarted?
- 3 MR. NORELIUS
I will lidit the answer to the 4
materia condition / design kinds of things because other than thattNayhadsomedifferentproblems.
5
'6' COMMISSIONER ASSELSTINE:
Right., But it strike me '
7
,} 7 th t those problems were fairly similar?
i 8[
MR. NORELIUS:
Yes, I would agree with that.
My 9
view is that Davis-Basse incorporated a number of additional 10 th ngs prior to restart that will be in the configuration 11 ma'nagement program that Palisades has.
12 On the other hand, I believe Davis-Easse's effort in s
i 13 terms of plant condition was a little more narrowly focused in 14 terms. of safety systems where I believe Palisades has taken 15 a little broader look in terms of balance-of-plant issues.
16 That is generally how I would compare their programs.
17 MR. DAVIS:
There is probably one other difference.
\\
e 13 I think Davis-Besse did the MOVAT testing on their motor 19 operated valves and this has been delayed.
20 COMMISSIONER ASSELSTINE:
Yes.
One of the questions 21 I wanted to ask is the valve work is being postponed here and 22 what you view the significance of that as being in terms of 23 the reliability of the valves.
.24 MR. NORELIUS:
Our EQ inspectors have been over to sb 25 Palisades and have looked at their response,to bulletin on the e
a 86 1
valves and are satisfied.
They did an inspection of the 1 ~
2 valves.
They did the re-lubrication.
They did a resetting of
.3 the torque switches ~and limit switches.
So they are satisfied 4-with what they have done at this point.
5 They are scheduled to do the MOVAT testing at the 6
maintenance outage in the fall.
7 COMMISSIONER ASSELSTINE:
Jim, maybe ou can give me 8
an additional statement.
u 9
MR. TAYIOR:
I would say that this is like a Turkey 10 Point program only Turkey Point has had longer to work their 11 engineering and design basis review.
They have actually done 12 more testing here than Turkey Point did in some of their 13 work.
In the meantime, where Turkey Point has identified
!k' 14 problems they are, of course, fixing them.
15 COMMISSIONER ASSELSTINE:
All right.
The last 16 question I.have and maybe it is the broader one, I don't think 17 I need to go through the details of the inspection findings l
18 very much but when I read the inspection report, the sense I 19 get is that you took a hard look at one of the safety systems l
and I think by the way that whatever concerns I may have about 20 l
21 the results of that inspection, that is precisely the kinds of 22 inspections we ought to be doing and I think the staff is to l
23 be commended for doing it, but when you look at the results, i
24 the results seem to show on the basis of an in-depth look at l
25 one system that the valves weren't main ~tain.ed, that.the
87 1
. system didn't meet the single failure criterion, that there
-r
,2 were questionable reliances on non-safety systems where'you 3
just couldn't depend upon the non-safety systems to ensure the 4
operation of the safety-related equipment.
5 There were problems in the calculations of voltages 6
such that you couldn't assure that the equipment would work i
7 based upon those calculations.
There were deficiencies on the 8
"Q" list.
Things that were supposed to be on the 9
safety-related equipment list weren't there.
10 Design calculations had not been controlled.
There 11 were problems int he 50.59 evaluations for safety-related 12 equipment for the plant that had been done, the ones that you 13 had looked at.
14 I guess what I am really asking and I think it is 15 particularly directed at Bert, you, and the two Jim's and Vic,
(
16 is when you look at all of that how much of a gamble is it to 17 let this plant start operating again before this design review l
18 work has really been done?
19 If that is what an in-depth look at one system 20 tells you, I will accept the proposition that you have fixed 21 all of those problems or you are satisfied that those 22 particular problems are dealt with, but how much of a gamble 23 is it for the other safety systems in the plant and how much 24 confidence do we really have that apart from the questions of 25 material condition and the people which I will gran.t you are 1
88 1
substantially improved, how much confidence do we have that 2
those systems are going to work if they have to until this 3
process has run its course and what is your basis for telling 4
the Commission that you have that confidence particularly 5
given the concerns that we have had about this plant in the 6
past?
7 MR. STELLO:' I guess I will start.
I guess the 8
question is, is the plant safe, maybe is_the way it translates.
9 COMMISSIONER ASSELSTINE:
Yes.
10 MR. STELLO:
I think we are convinced it is and we 11 are also convinced that the activity that the licensee is t
12 about is going to improve significantly the safety of the
(
.13 plant.
.\\.
14 The real issue becomes, well, there is a lot of 15 details that aren't there.
As you went back and you looked 16 and you asked the plant, what is the real safety significance 17 of these-things, it doesn't turn out that they are indeed that 18 major and I think one of the first points that Ashok made in 19 looking at some of the issues that arose in terms of what is r
20 the real safety significance, you down in a very, very low 21 probability range.
22 Would the plant have worked okay in the event of an 23 accident?
I think the answer is yes.
Would it have been 24 better if some of these things were fix d?
Clearly, the 25 answer again is yes.
~
x
89 I think adequacy is the test.
I think the element 1
2 that is here makes it almost like we are comparing today's 3
modern aircraft with an old DC-3.
A DC-3 is a DC-3.
This is 4
a plant that was designed nearly 30 years ago.
It is a 5
30-year old design.
Does it do the kinds of things that you 6
want in plants that you are looking at today?
No.
7 Does it mean that that design is in any way deficient
~
8 or inadequate or that the standards that were used were somehow 9
deficient or inadequate?
I think the plant is safe.
10 our concern has been more related to the attitude of 11 the people that have been running the plant and getting this 12 very uneven performance rather than equipment.
I think our 13 biggest safety concern has been derived from the performance 14 of the people.
15 I think on that problem we clearly have their 16 attention.
I think they have made that commitment and I think 17 we are persuaded that the attitudes have changed and we are 18 not going to be here and tell you that is done until we have 19 seen it changed over a sustained period.
20 I think our biggest concern was people and I think 21 that problem is now behind us.
l 22 COMMISSIONER ASSELSTINE:
Jim, the two Jim's, and 23 Bert, do you all have anything to add?
24 MR. TAYLOR:
No.
I think the esting, too, gives 25 you that added assurance that I think l'eads,the staff to its
90 1
conclusion and staff monitored that carefully from the region.
(-
2 MR. SNIEZEK:
I think also the configuration 3
management program that the licensee has embarked upon and 4
their upgrading of the 50.59 review process lands assurance to 5
the type of thing that Vic was mentioning that looking towards 6
the future, we would expect to see much better performance.
7-MR. DAVIS:
I guess I would comment'on a couple o,f 8
things.
There has been more looked at than just what the SSFI 9
looked at.
The Company looked at a portion of the aux 10 feedwater system and then they went into a pump testing 11 program whenever they found problems with some of their 12 pumps.
So they have expanded.
13
('
I also feel better and I know you didn't include 4
14 this in your question, but I feel better with the material 15 condition of the plant.
The May 19th trip showed a number of 16 problems.
We have done a lot of careful looking to try to 17 make sure that the material condition of the plant has gotten l
l 18 better.
So that makes me feel good.
l l
19
'I talked to the operators up there a couple of years 20 ago and they were pretty unhappy and concerned about the 21 condition of the plant.
I feel good about the way they feel 22 now and so I think that is positive.
23 The other thing that gives me some confidence, I 24 guess, is the system functional evaluation.
I think that was 25 a good move.
That is about the best you can do if you don't y,
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91 "l-complete the configuration management program.
They took all 2
those systems.
3 They looked at the FSAR, the tech specs and 4
everything sise to try to determine to the best that they 5
could what the plant was analyzed on, what~the bases were and 6
then they did a careful review of that and testing to see if 7
those systems would operate and then we took what, a half a 8
dozen or five of those, and did our own evaluation.
9 So putting that all together, it gives me reasonable 10 confidence.
I would sure feel better if the configuration 11 management program were done.
I guess I would say that it is-12 all right to let the plant operate and let that be done as we
(-
13 go along.
\\..
14 COMMISSIONER ASSELSTINE:
All right.
One last 15 question.
Knowing what you know about the high pressure 16 safety injection system, if the plant had been operating last 17 August and there had been a need for the high pressure safety 18 injection system to function and you had had a problem in the 19 air system, a failure in the air system, would it have worked?
l 20 MR.GULbEMOND:
My personal opinion is that yes, it 21 would have worked.
It would have required a rather convoluted j
22 set of circumstances for the single failure to affect the 23 recirculation valves and compromise the integrity of that high 24 pressure safety injection pump.
Somyheelingis,yes, it 25
'would have.
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1 COMMISSIONER ASSELSTINE:
All right.
That'is all I
-,s 2
have.
3 CHAIRMAN ZECH:
All right.
Commissioner Bernthal?
4 COMMISSIONER BERNTHAL:
I think I have covered 5
everything I need to ask.
6 CHAIRMAN ZECH:
Commissioner Carr.
7 COMMISSIONER CARR:
No.
8 CHAIRMAN ZECH:
Let me just say we all know that it 9
is an older plant but what we are really concerned about is lo safety.
I think the Consumers Power Company although they 11 have had a challenge ahead of them, they should be commended 12 for their commitment to improve performance and that is what 13 it is all about.
14 We are looking for results and I would like to ask 15 Region III to continue a very stringent monitoring program and 16 watch for results.
t 17 I would like to commend Region III, Vic, I think 18 they have done a good job here today and not just today but in 19 following this Palisades situation.
I think Mr. Norelius and 20 Mr. Guldemond did a particularly helpful job here today for 21 us, at least for me, and I know personally that they have been 22 following this plant very closely and I think they have done a 23 great service to all of us.
24 I guess to summarize, what we a e hearing is that 25 the licensee and the staff have concluded that the actions for
-. -_~~ -.. _. -,.- - - - --.-_. - _ -.-
e 93 1
restart have been identified and contingent upon completion of
(
2 any prerequisites that Region III may come up with or determine 3
that you are telling us that you believe that they should be 4
allowed to restart their Palisades facility.
'5 I would like to ask my fellow Commissioners if they 6
are ready to vote in that regard?
4 7
COMMISSIONER ASSELSTINE:
I am although I would like 8
to make a comment maybe on it as well, Lando.
9 CHAIRMAN ZECH:
Let me make it first.
10 COMMISSIONER ASSELSTINE:
Go ahead.
11 CHAIRMAN ZECH:
Then you can make it..
You may make 12 the same one.
(
13 COMMISSIONER ASSELSTINE:
Fine.
14 CHAIRMAN ZECH:
It would have been very helpful and 15 this is to the staff, it would have been helpful to me and I 16 think to all the commissioners if we could have gotten a 17 little more detailed bit of information particularly that 18 December report so we could have reviewed and perhaps had a 19 lot of the answers to the questions we have been asking here 20 today.
21 I would just like to ask that it would have been i
22 helpful to have a little bit better briefing package down here i
23 sooner.
This is a very important matter we are discussing 24 here today. one of the plants that has ot been performing as l
l N 25 well as we think it should, it has been shu,t down for a long I
94 1 ~
time and we have to have the confidence to make the right 2
decision.
3 So I would ask the' staff if at all possible to give 4
us a little stronger briefing package and get it to us as soon 5
as you can so we can have a little more time to review it.
It 6
might help us prepara better for the session today.
7, Commissioner Asselstine.
8 COMMISSIONER ASSELSTINE:
Yes.
I agree with that, 9.
Lando.
My comment is just a little different and it really 10 addresses the substance of the decision that we have to make.
11 I am going to go along with the staff's judgment and advice.
12 I think that it does make sense in this case.
13 Although I have to say, I think it is close.
I 14 think the company has done a lot.
It is to be commended for 15 the kinds of efforts it has put into place.
I think the 16 material condition program and stability of the people, I
17 getting some control over the situation up there is all in 18 the right direction.
The place where quite frankly I am still I
19 uncomfortable is on the adequacy of the design.
20 I recognize that it is an older plant.
I recognize 21 that there is an ongoing program in place but the inspection 22 report despite, I think, the good answers that both the 23 company and the staff gave us leaves me with a lot of 24 unanswered questions in my own mind abo t the rest of the 25 systems up there.
l tl.,,
4 95
=
1 I am going to give the company and the staff the 2
benefit of the doubt but I would second your urging of the i
3 staff to really closely monitor the situation up there and I 4
hope the company will get the evaluation of the safety systems 5
of'the plant done as quickly as possible so that any doubts or 6
reservations that may still exist get laid to rest as quickly 7
as we can.
~
8 CHAIRMAN ZECH:
Are there any comments before I call 9
for a vote?
11 0 COKNISSIONER CARR:
If I might make one comment?
11 CHAIRMAN ZECH:
Yes, Commissioner Carr.
12 COMMISSIONER CARR:
In all the 20-plus plants I have 13 looked at, you are one of the two that I came back worried 14 about and that was since Thanksgiving.
In those four months 15 you have, I can sense an attitude change on the management's 16 part certainly as well as it looks like your program has taken 17 hold.
I think you have realized what you have to do.
i 18 There is no doubt there is still a lot to be done, 19 but I do commend you for the change in approach from the time 20 you talked to me at Thanksgiving and the time you talked to us 21 today.
22 CHAIRMAN ZECH:
I agree with that and we are all 23 going to be looking for results.
All right.
Those Commissionersinfavorofauthorizingtberegional 24 i
l t 25 administrator to permit Consumers Power Company to restart i
1
96 n
1 Palisades when identified prerequisites to restart are
~
2 complete, please signify by saying, "Aye."
3 (Chorus of ayes.]
4 CHAIRMAN ZECH:
Those opposed?
5 (No response.]
6 CHAIRMAN ZECH:
The vote is five to zero to proceed.
7 We stand adjourned.
8 (Whereupon, the meeting of the Commission was 9
adjourned at 12:10 o' clock p.m.,
to reconvene at the Call of 10 the Chair.]
11 12 f
13 s
14 15 16 17 18 19 l
20 21 22 23 24 25 P
_. - _ - - - - - -., _ _ _ _ - ~
1 2
REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5
meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7
TITLE OF MEETING:
Discussion /Possible Vote on Restart of Palisades 8
PIACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING:
Friday, March 20, 1987
^
10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of.the Commission taken 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.
17 VRtl d,. ~ 7 h \\v4 >
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22 Ann Riley & Associates, Ltd.
23 24 25
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i SERVICE WATER FLOW DEFICENCY o 3 SERVICE WATER PUMPS o LOSS OF 0FF SITE POWER AND ONE DIESEL GENERATOR
- FLOW SHORTAGE FOR DBA o VERY LOW SAFETY SIGNIFICANCE o INTERIM SOLUTION
- BACKFILED IMPELERS TO INCREASE FLOW
- CLOSE ISOLAT10N VALVES FOR INOPERABLE AND UNNECESSARY C00UNG
- UMIT SERVICE WATER INLET TEMPERATURE T0 5::53*F o ADDITIONAL POTENTIAL MEASURES TO RAISE UMIT
- MORE DETA! LED THERMAL HYDRAUUC ANALYSIS
- AUTOMATE ISOLATION OF SERVICE WATER TO CONTA!NMENT COOLERS
- INSULATE PlPING IN ENGINEERED SAFEGUARDS ROOM
- INCREASE CAPACITY OF ENGINEERED SAFEGUARDS ROOM COOLER FANS
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l o STILL MEETS DESIGN BASIS AND SRP ACCEPTANCE CRITERIA o EQUIPMENT QUAUFICATION ENVELOPE ACCEPTABLE i
o MEETS TECH. SPEC. FOR 24 HOURS TO COLD SHUTDOWN i
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.-. -.~.-.-._-_--_.._-_---.- -._-_.,
Inspection Program for Restart I.
Plant Readiness (complete)
Material Condition Maintenance SSFI Findings System Functional Evaluation Operator Interviews System Walkdowns II.
Operational Readiness (ongoing)
Operations Maintenance / Modifications Surveillance Training Health Physics Testing i
1 l
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Plant Readiness Inspection Results I.
Material Condition Material Condition Task Force Report Work Order Backlog Review Modification Backlog Review System Walkdowns Operator Interviews i
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Maintenance Administrative Procedures Organizational Structure / Interfaces Staffing Levels Equipment Performance Trending Training i
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SSFI Findings Reviewed licensee resolution of immediate concerns on 16 findings that'were startup prerequisites Evaluated licensee resolution of generic issues represented by the findings.
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IV.
System Functional Evaluation Methodology Performance criteria generation Acceptability of identified testing Scheduled disposition of discrepancies P
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Operator Interviews Two shifts interviewed A0 through SS Focused on material condition and outstanding i
equipment concerns i
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Systems Walkdowns Component Cooling Water Service Water Diesel Generator (mechanical)
Fire Protection Instrument Air Chemical and Volume Control l
4 9
4 VII. General Conclusions Significant-improvements have been made in power block material condition Maintenance process has been streamlined Meaningful goals have been established Management is exhibiting a conservative attitude toward operations and material conditions The Ifeensee has adequately addressed those issues necessary to establish plant readiness for restart Adequate long term commitments have been made for improvement The staff will develop a program to monitor sustained improved plant performance Authorization for restart is recommended e
S
'I e
.s 1
PRESENTATION 1'
TO THE NUCLEAR REGULATORY COMMISSION
~
CURRENT STATUS l
ON PLANNED RESTART OF THE PALISADES PLANT BY CONSUMERS POWER COMPANY MARCH 20,1987 9
e
~
INTRODUCTION e
ITEMS COVERED ON JANUARY 14, 1987 MAY 19 TRIP PROBLEMS l
MATERIAL CONDITION DESIGN - RELATED ISSUES e
IDENTIFIED PROBLEMS e
PLANS FOR RESOLUTION e
PROGRESS TOWARD RESOi.UTION PROGRESS & PLANS FOR TESTING & RESTART
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s INTRODUCTION
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e ITEMS TO BE COVERED TODAY i
SUMMARIZE " PRIOR TO STARTUP" COMMITM'ENTS.
1 PROGRESS ON THESE COMMITMENTS i
PROGRESS ON TESTING PROGRAM PLANT SCHEDULE t
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MATERIAL CONDITION i
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l EHC POWER SUPPLY TRIP COMPLETED CONTROL ROD #34 COMPLETED BOTTOM LIGHT OUT l
CHARGING PUMP START FAILURE COMPLETED l
l PRESSURIZER SPRAY VALVE COMPLETED PARTIALLY OPEN l
l LETDOWN PRESSURE REGULATOR COMPLETED POSITIONER TURBINE BYPASS VALVE OPERATOR COMPLETED STEAM DUMP VALVE SLUGGISH.
COMPLETED s
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4 HOT TESTING o IMPROVED HOUSEKEEPING 1
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CURRENT YEAR END YEAR END l
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CONTROL ROOM DEFICIENCIES 9
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. COMPLETED COOLING WATER SYSTEM FLOW VERIFY SERVICE WATER COMPLETED SYSTEM CAPABILITIES
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- 1. RAS SEAL-IN MODIFICATION COMPLETED l
- 2. HPSI PUMP TESTING COMPLETED l
- 3. ADDITION OF BACKUP AIR SUPPLY COMPLETED TO DUAL POSITION VALVES
- 4. MODIFY CONTROL PANEL PLACARD COMPLETED 1
- 5. IMPROVE BATTERY SURVEILLANCE COMPLETED TEST
- 6. TEST AIR SYSTEM CHECK VALVES COMPLETED l
- 7. REPLACE UNQUALIFIED GREASE IN COMPLETED 4 MOVs
- 8. CORRECT SAFETY CLASSIFICATION OF COMPLETED LOAD SHED BREAKERS
- 9. IMPROVE ELECTRICAL & MECHANICAL COMPLETED
. REPAIRMEN TRAINING
~
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m DESIGN COMMITMENT STATUS o SYSTEM FUNCTIONAL EVALUATION REVIEW FSAR, TRANSIENT REVIEW COMPLETE;
- ANALYSES, NORMAL 107 REQUIREMENTS l
OPERATING PROCEDURES IDENTIFIED THAT
& EMERGENCY OPERATING AREN'T COVERED PROCEDURES BY ROUTINE l
OPERATIONS OR SURVEILLANCE l
VERIFY THOSE 107 DEVELOPED TEST REQUIREMENTS VIA PLANS FOR 139 TESTING OR JUSTIFY SEPARATE SYSTEM ACCEPTABILITY OF OR COMPONENT PAST TESTS TESTS 97 OF 107 REQUIREMENTS VERIFIED 129 OF 139 TESTS COMPLETED
.a P_LANT RESTART PLAN e FORMAL PLAN WITH STEP-BY-STEP REVIEWS &
APPROVALS e PLANT REVIEW COMMITTEE, PLANT SAFETY ENGINEERING, AND PLANT MANAGEMENT REVIEW
& APPROVAL TO PASS MAJOR MILESTONES:
HEATUP FROM COLD SHUTDOWN CRITICAL POWER ESCALATION HOLDS AT 30 %, 60 %, 80 %
l e
INDEPENDENT OPERATIONAL READINESS REVIEW BY CP Co NUCLEAR SAFETY BOARD PRIOR TO CRITICAL l
- PLANT MANAGEMENT IS ON SHIFT DURING HOT TESTING & STARTUP TO ENSURE HIGH STANDARDS
4 PLANT TESTING PROGRAM l
0 POST-MAINTENANCE TESTING OPERATIONS / MAINTENANCE INTERFACE GROUP &
SYSTEMS ENGINEERING FULL FUNCTION TESTING WILL BE PERFORMED TO THE EXTENT POSSIBLE TRENDING PROGRAM WILL MONITOR TEST DATA
- APPROXIMATELY 3,000 MOs RECEIVED OPERABILITY TESTING 1
o SYSTEM FUNCTIONAL EVALUATION TESTING 139 RECENTLY DEVELOPED TESTS / INSPECTIONS 10 WEEKS FOR TEST PREPARATION & IMPLEMENTATION e
4
~
1 i
PLANT TESTING PROGRAM e SURVEILLANCE TESTING 1,005 TECHNICAL SPECIFICATION SURVEll LANCES GENERATED 17 SPECIAL TESTS; INCLUDES BOP IMPORTANT TO RELIABLE OPERATION e INTEGRATED SYSTEM TESTING CHEMICAL & VOLUME CONTROL SYSTEM AUXILIARY FEEDWATER SYSTEM MAIN STEAM SYSTEM COMPONENT COOLING WATER SYSTEM i
SERVICE WATER SYSTEM FEEDWATER & CONDENSATE SYSTEM
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MAINTENANCE & MODIFICATIONS SERVICE WATER MODS 7//ME///ME/[/Mf///Md i
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NITROGEN BACKUP AIR SUPPLY I///Mf//Mf//MI////M I//Mf//Mf//M
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SYSTEM FUNCTIONAL TESTING PROCEDURE DEVELOPMENT Y////jf//) V//)V////j
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COLD SHUTDOWN TESTS (V//kV///)V//) V///Y////jI///4f//4
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PLANT STARTUP PRESSURIZATION Y
PRIMARY SYSTEM HEATUP HOT SYSTEM TEST:NG
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CRITICAL APPROACH 9
SYNCHRONIZATION Y
POWER ASCENSION TRAINING V//) V/)
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OPERATOR REFRESHE.R N
~
CLOSING REMARKS EXCELLENT PROGRESS IN IMPROVING PLANT MATERIAL CONDITION o AGGRESSIVE APPROACH TO IMPROVING PLANT MAINTENANCE PROCESSES o
PLANT DESIGN ISSUES MANAGED WITH ATTENTION TO:
THOROUGHNESS OF INVESTIGATION AGGRESSIVE REMEDIAL & CORRECTIVE ACTION EXTENSIVE TESTING & EVALUATION c
e COMPREHENSIVE TESTING PROGRAM 15 NEARLY COMPLETE i
e AGGRESSIVE PROGRAM IN PLACE TO ASSURE l
CONTINUOUS AND SUSTAINED PLANT IMPROVEMENT l
-, - _ _,. _ _ ~.
SCHEDULING NOTES TITLE:
DISCUSSION /POSSIBLE VOTE ON RESTART OF PALISADES SCHEDULED:
10:00 A.M., FRIDAY, MARCH 20, 1987 (OPEN)
DURATION:
APPROX 1-1/2 HRS SPEAKERS:
- CONSUMERS POWER COMPANY 20 MINS WILLIAM McCORMICK, PRESIDENT AND CHIEF EXECUTIVE OFFICER FRED BUcKMAN VIcE PRESIDENT, NUCLEAR d
JOSEPH FIRLIT, PLANT GENERAL MANAGER
- NRR 10 MINS FRANK MIRAGLIA
- REGION Ill 15 MINS CHARLES NORELIUS
~
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