ML20207Q476

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Transcript of Commission 870114 Briefing in Washington,Dc Re Status of Palisades.Pp 1-85.Viewgraphs & Supporting Documentation Encl
ML20207Q476
Person / Time
Site: Palisades 
Issue date: 01/14/1987
From:
NRC COMMISSION (OCM)
To:
References
REF-10CFR9.7 NUDOCS 8701270410
Download: ML20207Q476 (127)


Text

"

"0RIGINAL UNITED STATES OF AMERICA

{

NUCLEAR kEGULATORY COMMISSION In the matter of:

COMMISSION MEETING Briefing on Status of Palisades (Public Meeting)

Docket No.

l Location: Washington, D.

C.

Date: Wednesday, January 14, 1987 Pages:

1 - 85 87012 0 870114 p77,7 PDR ANN RILEY & ASSOCIATES Court Reporters

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1625 I St., N.W.

Suite 921 Washington, D.C. 20006 (202) 293-3950 1

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1 1

D I S CLA I M ER 2

3 4

5 6

This is an unofficial transcript of a meeting'of1the 7

United States Nuclear Regulatory Commission held on 8

1/14/87 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

=

f 12 inaccuracles.

13 The transcript is intended solely for general-14 informational purposes.

As provided by 10 CFR-9.103, i t.is :

15 not part of the formal or informal record of decision of the 16 matters discussed.

Expressions of opinion in this t r a n s c r.L p t 17 do not necessarily reflect final determination or b e l i e f;s.

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 authorl=e.

22 23 24 l

25

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4 1

1 UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

4 BRIEFING ON STATUS OF PALISADES 5

6 Public Meeting 7

8 9

WEDNESDAY, JANUARY 14, 1987 10 1717 H Street, N.W.

11 Washington, D.C.

12 13 The Commission met, pursuant to Notice, at 14 10:00 a.m.,

CHAIP. MAN LANDO W.

ZECH, JR. presiding.

15

.~

16 COMMISSIONERS PRESENT:

17 LANDO W. ZECH, JR., Chairman of the Commission 18 THOMAS M. ROBERTS, Commissioner 19 JAMES K. ASSELSTINE, Commissioner 20 FREDERICK M. BERNTHAL, Commissioner 21 KENNETH M. CARR, Commissioner 22 23 24 l

25

. ~

4 4

2 1

STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:

2 3

S. Chilk W. Parler 4

V. Stello J. Keppler E

J. Taylor C. Norelius 6

F. Miraglia 7

W. McCormick F.

Buckman 8

J. Firlit J. Reynolds 9

10 11 12 13 14 15 16 17 18

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19

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20 21 22 23 24 25

e

's 3

1 PROCEEDINGS 2

CHAIRMAN ZECH:

Good morning, ladies and gentlemen.

3 Commissioner Asselstine will be joining us shortly.

4 This morning, the. commission will be briefed by the 5

Staff and Consumers Power Company on the status of Palisades 6

Nuclear Power Plant.

There's no vote associated with the 7

meeting this morning; this is an information status briefing.

8 Following the reactor trip that occurred on the 19th 9

of May, 1986, Palisades has been shut down.

On the 21st of 10 May, 1986, Region III issued a confirmatory action letter 11 documenting Consumers Power Company's agreement to go to cold 12 shutdown to conduct further reviews of the trip and to 13 evaluate the operability of other safety-related and 14 balance-of-plant equipment.

15 This event, combined with the other operational 16 problems at the plant, an NRC systematic assessment of 17 Licensee performance reports, Region III briefings and review 18 of Palisades' inconsistent operating history caused me to 19 visit the Palisades plant in June of 1986, and other 20 Commissioners have visited the plant before and after that 21 time.

22 The NRC has also conducted an augmented inspection 23 of the plant to investigate the multiple equipment failures, 24 maintenance problems and operational practices noted during 25 the May 19th trip.

Additionally, an NRC safety system

i-t4 4

1 functional inspection was conducted on the high pressure 2

safety injection system.

3 Consumers Power Company has indicated that they have 4

recognized and identified many of their current problems and 5

have corrective programs underway to address them.

In order 6

to assure the Nuclear Regulatory Commission that the problems 7

have been fully and properly addressed, a 10 CFR 50.54(f) 8 letter was issued on the 20th of November, 1986.

9 The purpose of today's meeting is to hear from the 10 staff and from Consumers Power Company about the status of the 11 Palisades Power Plant.

Do any of my fellow Commissioners have 12 any statement or opening remarks they'd like to make?

13 (No response.)

14 If not, Mr. Stello, would you proceed with the

, _ __ 15 discussion?

,_ 36 MR. STELLO:

Thank you, Mr. Chairman.

I think.

17 you've given a fairly full description of the background and 18 the history since the trip in May.

We are prepared to go -- _ _

19 and Region III will go -- into more detail on the history and 20 some of the problems we have found in the past and what the 21 status is of problems we've identified since that time and 22 what we're doing about them.

23 As you are aware, we discussed at great length the Palisades facility at our October management meeting and 24 25 concluded this was a plant that indeed needed further

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1 regulatory attention and one for which we believed we expected 2

to see some substantial improvement in the operation of that 3

facility.

4 We are not prepared today, as you've already said, 5

to recommend to the Commission any action, and this is simply 6

a status briefing and we expect that we will be back to the 7

Commission before the plant will be restarted and give you a 8

complete, total briefing of where we stand on each issuo.

We 9

don't have all the answers today.

We will give you simply the 10 status and try to do that crisply, and Chuck Norelius has 11 indicated he needs about 15 minutes to go through that status 12 briefing and will do that now.

13 CHAIRMAN ZECH:

Fine, thank you.

Proceed.

14 (Slide.)

15 MR. NORELIUS:

I want to just go through some of the 16 history and I will try to add a little bit to what you have'

~~

17 said, Mr. Chairman.

Starting back even before 1981 we had

~

18 some ongoing regulatory concerns with the Palisades ~ facility, 19 and although there were several, none of those were of great

~

l 20 significance such that we might consider stopping the 21 operation.

22 In 1981, however, there were some issues that came 23 up that concerned us enough so we did consider issuing a 24 shutdown order.

The utility at that time developed its own 25 fairly comprehensive corrective action program, and the staff 1

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1 issued a confirmatory order at that time.

That order and 2

actions were fairly heavily oriented toward plant operations.

3 But we did see improved performance in the 1982-83 4

time period, and it may be in hindsight that we over-estimated 5

the full scope of that performance; we thought it was quite 6

good at the time.

But as you see in the history of the plant 7

as you go into the 1984-85 period, we developed some 8

additional concerns.

9 Now part of the problems that Consumers Power had at 10 that time dealt with company financial and morale problems 11 that were related because of the cancellation of the Midland 12 facility, and the company may talk a little more about that.

13 But we developed concerns specifically at that time on the 14 maintenance program and on the plant condition in general.

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.15.-

And so we conducted a couple of special team assessments of 16 the maintenance program and through a confirmatory action:

tr 17 letter reached agreement with the company on a corrective

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18

-action program directed at maintenance.

r-19 So the company initiated steps at that time.

i 20 However, I believe that the problems they had were probably 21 more extensive than what either of us probably anticipated, i

22 and so some of the maintenance problems began still to show 23 themselves even more as we got into early 1986.

I L24 Early on in 1986, the plant was started up and they 25 had a number of valves that leaked, problems with the primary l

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1 coolant pump seals, and because of that and after discussions 2

with us, they agreed to shut the plant down and fix those 3

problems.

4 Then they started up a second time and because of 5

excessive plant leakage, they were required under the Tach 6

Specs to shut down again and repair those leaks.

And those 7

two were prior to the May 19th event which you mentioned.

8 Then in the May 19th event the plant tripped.

9 Again, there were equipment problems that followed on, and our 10 concerns at that point sort of went beyond just equipment but 11 also to how it affected operations.

The operators had to work 12 around some things; not that it was a major problem buc I 13 believe in cur past experience with other plants, especially 14 Davis-Besse, we know that multiple equipment problems just get 15 you into a lot of problems and that was of concern to T2s.

16 So as you indicated, we initiated an-augmented-17 inspection team and issued a confirmatory action-letter.

The-18 Licensee at that time also developed a special material 19 condition task force to evaluate the condition of the plant, 20 and they will give you more details on that so I will not go 21 into it.

22 As they began pursuing plant problems, however, they 23 also found problems in the design area.

And in looking at the 24 low pressure safety injection system they found one of their 25 two pumps that was less than -- the flow was less than the

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8 1

FSAR requirements.

This had resulted because a replacement 2

impeller was not properly backfiled.

They found problems with 3

the component cooling water system.

There were under-sized 4

heat exchangers, and that affects their post-accident 5

containment cooling, shutdown cooling and spent fuel cooling.

6 Now, they have evaluated that problem and the flows

~

7 that they have I believe are adequate until the next refueling' 8

outage.

When they get the new fuel they will not be able to 9

restart-up because of spent fuel pool cooling considerations, 10 and that will be a problem next fall.

11 Also, they found problems with the essential service 12 water system.

They have problems with flow distribution, they 13 have problems with the flow being less than the FSAR 14 requirements, and this affects several pieces of equipment I

15 required to mitigate the consequences of a design basis cr:

16' accident.

t 17-The items that are being considered now with regard 18 to that -- they are considering the isolation of one i

19 containment air cooler, they will have to use fire pumps'as.

20 backups for that system, and also are considering a reduction 21 in the service water inlet temperature to be less than 53 1

22 degrees to meet their design requirements.

23 So you can see by that that even if that analysis is 24 acceptable, that still is only an interim fix because Lake

- 25 Michigan water temperature will exceed 53 degrees sometime 1

v 9

1 come this spring.

2 Those issues are currently being evaluated by the 3

NRR Staff, and the changes on the essential service water 4

system will require some Tech spec changes, so those are 5

currently under consideration.

6 Also, you mentioned that the staff conducted a.

'7 safety system functional inspection, and while I think the 8

findings were not atypical of other similar inspections at 9

other plants, they did show some additional design-related-10 problems which added to the items that the plant had already

~

11 found.

And as you indicated, because of the multiple.-

~ '

-12 equipment problems that were found, because of the -

13 design-related concerns that had surfaced, and because the j plant had developed corrective action systems, a number of

'i5 ' ' 'different ones which they will explain to you and some R - - ~'~

2' 2

16 starting at various times, the staff issued a -50,54 (f) letter, 17-

'the purpose being to get a comprehensive understanding of what.

18 all the problems were so we could look at them all:together in.

-19 a comprehensive sense; also look at what their corrective!

20 action programs were and how they fit together so we could.

21 make a determination of their readiness for restart.

22 Subsequent to that in December we did meet with the 23 utility to discuss their response, and we requested additional

, information which they still owe us.

~:~--

- - (Slide.)

1r-i

D e

10 1

I just want to relate briefly our plans in terms of 2

assessing the readiness of the plant to restart.

We're really 3

looking at it in two phases and we are in the middle of the 4

first phase.

We are trying to assess the plant readiness, i

5 hardware, equipment conditions and so we are looking at their.

6 programs for the material condition task force.

They have a 7

safety functional evaluation system which they.will describe 8

for you.

We are looking at that.

We will look at the testing 9

that they have completed and have yet to complete.

And so the 10 whole first segment is designed to look at the plant readiness.

l 11 from the hardware standpoint.

12 Once we are satisfied that the plant is.raady from.

13 the hardware standpoint, then our second phase is going to be 14 to look at the operational readiness.

That will.be more to

15. -

look at how they interface, how the operating crews. work..

16.

They have been down now since May.

We will look.at_the.

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- 17 training that they have been given, whether that inc.orporates. ;;,

18 changes in procedures that have occurred during that time.. _

7 19-We will look at the maintenance program;from.the.... 7; 20 standpoint then of how do they fix new problems._that come up.._.

21 If the operators identify new problems, how is that l

-22 transmitted to maintenance and what's the turnaround time; the

_... 23 readiness, from a surveillance standpoint.

c I

24 And so when we get finished with those.two._ _.

25 particular inspection activities, then we will be able to give 1

i 11 1

our view in terms of their readiness for restart.

As I say, 2

we are in the middle of Phase I at this point, so that's who're 3

we are in the region.

4 As I mentioned, from the NRR Staff's side, they are 5

still evaluating the information and once they complete that 6

they will have to make a judgment on the changes with regard-7 to design.

So that's where we stand today from the staff's 8

standpoint.

9 MR. STELLO:

We are through, Mr. Chairman, and we~

10 are ready for questions.

11 CHAIRMAN ZECH:

All right, fine.

Questions from my 12 fellow Commissioners?

13 COMMISSIONER ASSELSTINE:

Maybe a comment and then a 14 question.

The comment I think is, Lando, I agree with your

~

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opening statement.

I visited the plant in July of last year I' '

i 15 16 think a little bit after you visited it, and guess'I hid~

7 l

17 targeted this plant to go visit as a result of the staff's 18 SALP report back in February of 1986.

And I thisk, for l

19 myself, that the staff is to be commended for focusing

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20 attention on this plant and for spotting it as a problem plant-21 before we had to wait for some significant or serious 22 operating event to point that out.

I think that the staff's 23 efforts on this particular plant have really been in the right 24 direction and it's an example of a more forward-looking

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25 approach that I think is very worthwhile.

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CHAIRMAN ZECH:

I agree.

2 COMMISSIONER ASSELSTINE:

I think the staff's 3

efforts are commendable.

4 When I visited the plant, there was a lot of talk 5

about changing attitudes and improvement programs, and I think -

6 some of the efforts that the staff has just briefly described 7

were just either really getting underway or in the planning- -

8 stages at that time.

And I guess what I'm particularly 9

interested in hearing from the staff is have the attitudes 10 really changed.

Is there a recognition that the kind of 11 deterioration that occurred at this plant just is unacceptable 12 in terms of providing a level of safe and effective plant 13 operations?

Are they getting on top of the maintenance 14 problems, are they identifying the design basis questions-and:

15

.getting those things fixed, and are we seeing the kind -of: -. -,

.:L6 effectiveness from these programs that we really have to_-pee n

3-

-jl7.

before this plant ought to be allowed to_ go back.into

- 18 operations?

= - - -

19 I guess what I'm really interested in is your.

20 assessment of are we seeing more than just a lot of talk and l

21 good words; are we really seeing the kind of performance that 22 we want to see, are they really chopping down the maintenance 23 backlog, are they getting things fixed, is there an attitude 24 on the part of the plant personnel that they recognize that 25 what the company wants is a well-maintained and-high quality

l 13 I

condition plant, that the company expects and insists upon the 2

identification of problem areas, and do they operators expect j

3 that in fact if they identify problems that they will be 4

rewarded for doing that and that in fact the things will get 5

fixed?

More of an assessment of is there a real change in the 6

attitudes and performance of this company.

7 MR. NORELIUS:

I think that we have seen a_ change in 8

the management's view in terms of what they need to do to get 9

the plant running.

I'm not sure we agree exactly at this 10 point at what level that should be, but I think it's fair to 11-say that they have changed their attitude from.what I.would.

12 have viewed at six, eight months ago to now.

13 Secondly, down in the operations area, the company e has done some of their own interviews of operating personnel.;

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- 15 They have made it a point in their corrective: action programs. :g e

3 16.-

to.have operators represented to make sure that-the. things are 17 being fixed that the operators think should be_ fixed, and
I.

7-18 think that is a positive part of their program._ 3 -

L

- 19 The operators' view at this point is that they hav.e-I L.

20 -

seen a change, they have seen a number.of things. fixed that didn't get fixed before.

They I think still believe that

- maintenance could be more effective in the way it.does its 23 business but they have seen an improvement.

4 2-r :-24 On the other hand, I think the operators.have t-- __ expressed -- and I think this is our view, too;-- that-it's

.,,_.__-.,_._.,-._m._

o 14 1

going to take some time to see if that viewpoint holds 2

throughout an extended period of time.

I mentioned earlier 3

that in the 1982-83 timeframe whan we saw improvements, I 4

think we may have been overly optimistic about the long-tern 5

effects, and I think we're going to be more cautious because 6

of that and I think we will wait.

You know, we'll have to 7'

look a year from now really to see if that attitude is 8

maintained.

But I think we're conscious of it and we will 9

look to determine that.

~

10 Also, as part of our readiness inspection, we plan -

11 to interview operators and maintenance people to see if their -

12 perception has changed with regard to plant conditions 13 MR. KEPPLER:

Let me add a comment.

The attitude of 14 the company I think is good and it's been good and improving 15

since the new CEO came onboard.

~ '

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2'

~~

' ' 56' CHAIRMAN ZECH:

When was that?

~~

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  1. ~

'17 MR. KEPPLER:

A year and a half ago.

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18 The biggest concern I have is that the plant itself,

~ 19 the condition of the plant, the operability of the safely

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20 systems, the design capabilities of the plant, I think were 21 worse off than any of us anticipated, and trying to satisfy 22 ourselves today that we have our arms totally around the 23 problem -- that's the concern I have.

And one which we're not

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24' ready to say we're there yet.

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I think definitely the company is on ~th's right -~

1

i 15 1

track.

I think they want to make it a good plant.

I'm 2

convinced they want to operate it well, but I think satisfying f

3 ourselves that we really have an understanding of all the l

4 problems there is an important element right now.

5 COMMISSIONER BERNTHAL:

If I may ask you, Jim, along 6

that line.

One of the things that becomes increasingly 7

apparent to anyone who sits here even as long as I have,. let 8

alone as long as Tom has, is that the good old days weren't 9

all that good in many respects back in the late sixties and 10 early seventies.

1,1 Palisades -- since I lived in Michigan during that 12 era -- had a very, very difficult and rocky startup.

I think 13 you probably remember that.

To what extent have you been able 14 to evaluate what may be there that is attributable to that 15 history of the plant, to an earlier era where perhaps the 16 construction and inspection standards were not what they.are 17 today, to many of the startup problems and difficulties.

Do__.

18 you have any sense for whether there are scue things that date 19 _

back to the earlier days of the plant that may need to be 20 looked at carefully?

21 MR. NORELIUS:

Well, I think many of the problems 22 that they face today are as a result of that, the problems 23 they dealt with initially.

I think by.anybody,'s standard the 24 plant has not had a good operating record over the years.

If,

.. 2 5.

you go back, it was the first Combustion Engineering plant of _,

1

16 1

the new era.

I think the interface between the utility, the 2

AE and the nuclear steam system supplier was not the best.

3 The plant had a lot of equipment problems, a lot of growing 4

pains initially, and instead of having the benefit of a going i

i 5

maintenance program, I think in many ways the plant was 1

6 band-aided and problems were fixed on a piecemeal basis.

7 COMMISSIONER BERNTHAL:

Well, are you comfortable

~

l I

8 that you have your arms around that aspect as yet?

9 MR. NORELIUS:

No, I'm not, and that's one of the l

10 reasons that I said what I did earlier.

I feel today we're 11 paying the price of a lot of things that happened a long time

~

^

12 ago.

And this plant was not a well cared for plant.

13 COMMISSIONER BERNTHAL:

A familiar story.

14 MR. NORELIUS:

So that's the challenge, as I see it;

~

~

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2 ' '-

l5 to make sure that we do have our arms around all'of tha 2'

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' ssues.

i 16

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17 COMMISSIONER ASSELSTINE:

Just to foll'ow up'on that 18 last point, I guess in terms of attitude one of'th's things

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~

that I sensed was that while there was a recognition that'ther--~

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19 20 had some problems and things had to be done, certainl'y there ---

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~

I-21 was a conscious effort to try and improve the appearance of 22

~the plant; a lot of paint had been applied about idsa time I 23 was out there.

1

~

24 But I guess one of the concerns I had 1s~ are

~

~they'both focusing really on identifying the equipment 25

17 1

problems and getting the equipment fixed in a way that is 2

likely to remain fixed, not the old band-aid approach that 3

we've seen in the past.

And do you have enough of a sense of 4

that yet that in fact the approach and the corrections really 5

are aimed at making sure that this plant is brought back up to 6

a situation of high quality, and that if there were problems 7

.. they are fixed in a way that is likely to insure that there 8

aren't problems in the future.

9 For example, the water problem, the water

' 10 temperature problem.

Are they approaching that problem in a 11 way that isn't something that says well, we can patch it up

,7 12 enough to get by and get the plant running again, but we 13 recognize we may have difficulties in dealing with that

__ 14

. situation as time goes on.

Or is it an approach that says 15_,

. look, we want to get this fixed once and for all so that when.

16 we run this plant it will run reliably and well and won't be a

, 17.

_ source of continuing difficulties and problems for us..

_ 1,8 _

MR. MIRAGLIA:

I think with respect to some.of those.

19..

issues, they recogniz'ad the interim nature of the solution 20 that they're proposing right now.

Their focus has been on 21 those, from the interest of returning the plant online.

They 22 also are looking at a number of alternatives to get the 23 "long-term" resolutions and they haven't really shared much as

,2 4..

to'what alternatives and approaches they've been taking.

.. 2 5...

In the dialogue with them we felt it was important _

l

18 1

for them to identify to us what~the long-term plans arer if 2

not sharing exactly the design passing, what kind of schedule, 3

what kind of dates.

We'd like to have an idea of where 4

they're going and how they're going to try and get there.

And 5

I think they recognize that.

6 One point to indicate the change in attitude in the 7

company's attitude, I think they're asking themselves the 8

kinds of questions they should have been asking themselves 9

previously.

When they saw the flow problems with some of the 10 pumps, they went back and did a pump test program and looked 11 for other problems and found other problems.

So that the 12 indication of applying the band-aid, fix the pump-that we know 13 has the problem, they're asking themselves those questions and 14 their programs are heading down those paths.

^

15 '~-

~

So I think there are indications that the attitude--

21 6

' has changed in those kinds of areas.

And as Jim. has '-said, -

'7

~

GL7 there's probably a lot of problems out there and.they've; ~

lL8 existed for a long time and they're probably going to have a

~ - 19 ~

long time resolving some of them, but hopefully we-can make

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20' sure we identify them all with eventual resolution of them 21 all.

22 COMMISSIONER ASSELSTINE:

One last question.

In

.3-

'this case, several other cases, where we've looked at plants 2

~

24--

of an earlier vintage'and where the kinds of design basis ~~

l 125 reviews and safety systems functional reviews have been

19 1

conducted -- and Turkey Point comes to mind as well -- we 2

found surprises or the utilities found surprises when they do 3

.these reviews.

They found either that for some reason, 4

subsequent modifications to the plant or simply mistakes that 5

were made early on, ir, some respects that plant doesn't meet 6

the original design basis, some of the safety systems wouldn'.t

-7 perform as originally intended, or wouldn't satisfy the 8

requirements.

9 I guess the question -- and one of the comments I've 10 heard from some within the industry, particularly some who --

11 have experience in doing these reviews -- is that well,.we'.re..

12 not that different than other plants of thia vintage;. in -fact,-

13 if they did these kinds of reviews they'd find the same kinds 14 of surprises.

That seems like a plausible view to me.: Should-c' r - 11 5 '

-we be asking other plants, plants that went into operatiori in;-

~

7 146 - = -the late sixties, early to mid-seventies, to do: these-kinde cdE s+

- 17 reviews?

Are we finding sufficient surprises when we look at 1

-18 what is being done at Turkey Point, what is being, done-here,_- :

~ ~ ~ -

19 -- what was done at Davis-Besse, to say you know, every_ one of - _.: -

2 :

-20 these plants has probably got some problems in these areas,_

21 particularly given the number of modifications that have been

~22 made to them, the way the systems have been maintained,: and we : --

i 23 ought to find out about those now by doing a review rather

~-

~2 4 '

than waiting for serious operating events to point them. _out-to--

r' 125 us.

Is that a lesson that we should be learning.from.all; oft :

20 1

this?

2 MR. TAYLOR:

We've tried to spread this concept 3

because I think the Commission understands where we've done 4

these types of reviews we go in and pick a particular safety 5

system and then do a little bit of expanding to pick up 6

associated electrical equipment, batteries and thatJtype of -

~7 thing.

And in each case, we've besn distributing that-8 information in a widespread fashion across the industry.

9 -

Duke, as an example, when we finished Ocones, acknowledged 10 there were surprises that existed in that plant that they

~

really hadn't doped out, and has started taking some'round 11 12' turns with the rest of their plants.

~~~ ~

13 We have not -- and I've made numbers of speeches at 14 industry gatherings to try to stimulate this type of review. ~

~~ ~

~ I haven't tried to poll all the plants.

We did one at Trojan --

15 l'6' as an example, which is an older plant.

And as a followup ~to:

  • L' l

17 that, Jack Martin tells me there's been a very' aggressive ~

~'

l

~

18 change to re-establish the design basis at Trojan.

Money ~is -

i 19'

'being spent, the weaknesses that were pointed out there-are ~

'20 being amplified to look in the other systems; the same type'of

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'~

21 in-depth review will have really run under all the adverse 22 conditions that you might get into.

23 So I can tell you that it is -- I haven't tried to i--

24 poll and I guess I'll have to defer giving you'a's'pecific

~ ~ ~

"' answer, but this type of look is being applied.

+2

^

25

21 1

I think some of what is going on at Rancho, which 2

you'll hear from later on, is a bit of some of that type of 3

review.

We have some people out there right now.

4 But I know that doesn't answer your specific 5

question.

Nor have we tried to impose and say you must do 6

this type of review.

It is a rather extensive effort.

We're 7

trying to find where we think there may be symptoms of the 8

problems, which we did here.

The company had already begun to 9

identify when Jim Kappler and I decided well, we'd better go 10 in and start to amplify.

They had been in the aux feedwater 11 system.

We went in and hit the high pressure safety-12 injection.

We did find some safety-significant design 13 questions and issues related with that system.

Source of 14 water, continuous source, you know, and you switc.h f. rom the 15 tank to the sump and then get a signal to go back becausa.the --

16 recirc flow, you may be locked in to that low wat_er.. -- _

17 condition.

You know, it's that type of thing..

18 Now, that type of casualty hopefully the-plant won't 1

19 see, but it better be ready in case it happens. _This is fo_r 20 all the safety injection water.

l 21 COMMISSIONER ASSELSTINE:

I don't want.to belittle 22 your efforts, Jim, and I know that not only have you been 23 giving speeches but you and others in the staff have been 24 fairly strong in encouraging some of these utilities to do these kinds of reviews, and I think that th intensive team, -

25

22 1

type inspection programs have turned up a lot of these.

2 Your reference to the Oconee one is interesting 3

because there's a plant that's not a problem plant as we have 4

typically viewed it, and it's been viewed as a very good 5

performer, and yet you found the same kinds of difficulties 6

there.

The Trojan review found problems, as I recall, in the 7

RHR system as well as a couple of others.

~

8 And I guess what I'm wondering is it seems to be 9

that when we find these problems, some of them at least get 10 dealt with, but we seem to be finding these problems just 11 about everyplace we look and is it time to say~maybe the 12-speeches aren't enought maybe we're finding enough of these

~

13 things that we ought to be telling all of the plants, 14

- particularly the older plants, enough is enough, you have to

~

. : : : 15' 2 2 : :do'a review.

~~

~

~
16 -

MR. TAYLOR:

Well, Arkansas turned out' pretty well 17 when we did that.

There were some issues, but comparatively,

~~

" we~did the AFW system down there.

And also Pilgrim where~ws -

18T

" ' ~ -

~ 2 19

-did the high pressure.

Surprisingly enough we'didn t'get many i

20 of those design-specific issues when we reviewed that.

There l

21

- were water hammer issues and some others, not unimportant but '

22 not to the depth that I began to worry about the functionality l

=

23' long term.

So we've had some plants where we haven't really

~~

-- 24 ~ ~rhad the same kind of results.

I'm just giving you the

22-

.. J -255-

- contrast.

l l

7 23 1

COMMISSIONER ASSELSTINE:

Okay.

But again, that's 2-based upon an inspection that looks at one system.

3 MR. TAYLOR:

That's correct.

I 4

MR. STELLO:

Let me make just a brief comment, I 5

don't want to belabor the issue, but I think there's a general 6-feeling that the plants that were licensed early in the

'7 process -- and there are probably a dozen to 20 of those --

8 that you logically expect more of these kinds of issues to get 9.

raised because we were maturing in terms of our review lo-process, and as you look at some of the later.ones like 11-Arkansas you tend to find you don't have that kind of -a 12 problem.

e--;.

13 I can't say that we've done all of the_20, but 14 you've got to understand there's a lot of them that.have been 15 done that are in that vintage.

And we do have the-inspection 16 - -

program now with a number of them under our belts and we're.

17 starting to look at where are the right ones to;go and expect 18

.that we will pick up those that are necessary.. And as_wo-e-

19 learn more there may be a need to expanf

to at..least-that 20 sample size in the 20 and get them a3 And I think 21 eventually we probably will.

22-I think right now, the word is going out.

We have a 23

- lot of plants that are doing extremely sweeping - -Jim did not

.24-mention Northeast Utilities, for example, and on their own 25 initiative they've got an extremely comprehensive-program S

- - ~.

24 1

going back.

And the word is getting out and they are doing a 2

lot more, so Jim's speeches and the results of'these 3

inspections are spreading around, and we're starting to see 4

that the industry is responding itself, which is really what 5

you hope to have happen.

And it is encouraging.

But we're 6

not done.

We're going to do more and we're not ready.to say 7

where that end is yet.

So maybe we need to visit this-later.-

8 COMMISSIONER ASSELSTINE:

Okay, that's all I had.

9 CHAIRMAN ZECH:

Commissioner Bernthal?

10 COMMISSIONER BERNTHAL:

I just want to focus for a.

11 minute on the point that I guess Commissioner Asselstine.made 12 when he said that it was the SALP ratings that tipped him off 13 that something seemed to be amiss at the plant.

What was it 14 that caused you, Jim, -- and I agree that this is a good 15 example of where you got in ahead of the curve and moved -

1 16 before I think anybody except maybe the Licenses and some of 17 your people were aware that there was a problem because there c

18 hasn't been a serious high profile at least incident.

What 19 was it that tipped you off?

Was it the SALP systems or was it-20 something beyond that?

21 MR. KEPPLER:

I think the thing that first tipped me l

22 off was visits to the plant by my deputy and by Chuck 23 Norelius.

They came back with the view that the plant was in 24 terrible condition, it just did not look like a well-run power 25 plant and that morale was bad.

And we were aware when we sat i

25 1

down to do the SALP process; it came out during that time that 2

the plant had really deteriorated in performance in a number 3

of areas.

It wasn't just any one area; it was several.

4 And while I'm gratified that we're dealing with this 5

plant in this timeframe ahead of a serious incident, I was 6

somewhat dismayed that it took us as long to realize we had

_c 7

the problems as it did.

i 8

COMMISSIONER BERNTHAL:

Well that's what I'm trying '

~

9 to get at here.

As you know, we're, as an agency, groping for 10 ways to see problems coming before they become major 11 incidents, and I had to note back when we were-discussing..

12 performance indicators, as I'm sure many of you did, that if.I-13 had looked at Palisades in terms of the performance. indicators:

14 that we have set up and compared it with the industry 4 -

averages, I would have drawn a blank.

There 's-nothingr therer-16 that would have pointed to that plant as a problem planti_ - trre::

17 -

MR. KEPPLER:

I think that's correct.

e:-

c_

a e t :-

18 COMMISSIONER BERNTHAL:

Now, when I go through:.the i s: ;..-

-19 performance indicators that we've selected, many of them are-~ -

20

-- I will just read them -- scrams, significant events, forced --

21 outage rate, which by the way was not too good but still-not: - ' _

22 that bad by the industry standard at Palisades, enforcement 23 action.

Many of these things are things that we already do:on:

24

..our books, so to speak.

- 25 And I guess my question is what is it that watre

-r..

26 1

missing?

Is there something in this performance indicator 2

business, without getting into a complex matrix of 50 things 3

that we're trying to look at, that's already in the SALP 4

system or that anybody knows anyway or that just isn't that 5

important?

Is there something else that ought to be there, 6

like -- I'm looking at some of the other things-here.

7 Obviously, safety system failures is something we monitor, but-8 what about balance-of-plant failures?

Are there things that 9

should be in here substituting perhaps for some of-these.

10 things in performance indicators that would have_ pointed to 11'

- this plant, or is SALP the best we've got?

Want to comment on-

- 12 that?

13 MR. STELLO:

Let me comment.

I don't think you can 14' put your finger on any one of those and rely on them

'~~5:

1 57 ~

exclusively because you would have a major problem'if you; _

1 -

5 - Tr : 16 c did.

A SALP performance indicator or anything:elser J'

17 I think what it does take is what we have now:-

1.

'18 '

- instituted; a periodic management meeting to go back and. visit:

- 19

'those questions and get all of that input and-talkrabout it-20 and understand, through that process, whether-there's.

21

-something that suggests a need for further looking.

It's 22

bringing it all together, getting it all on the table and'then 23 understanding it to the best of your ability to.make that 24 judgment.

1 --

- '25 We've just begun that, as you are aware, and I-see

27 1

that process as a very healthy process for which all of the 2

issues that you raise get on the table, through all of the 3

mechanisms -- balance of plant, LER reviews, outstanding 4

issues, a list of equipment mods that are not done.

5 Everything is brought up.

And when you take it all together,,,

6 is when I think you are best prepared to make that. kind of.a 7

judgment and avoid having any one of these things mislead you.

8 COMMISSIONER BERNTHAL:

Well, I do recall, by the 9

way, that Turkey Point I think is in the same category; you 10 wouldn't have concluded a thing about Turkey Point by looking.

11 at what the performance indicators --

12 MR. STELLO:

At any one thing.

13 COMMISSIONER BERNTHAL:

Well, looking at that.

14 package that we hope will give us some early indicators._.They 15 just didn't deviate that much from the industry mean..

16 Is the message here that the truly objective.... _. ;. 7_,.

l 17 criteria -- and this is a guess, I don't know -- is the,.,.

18 message that things like scrams and significant. events and,,_,,

i 19 safety system actuations surprisingly enough are not as._

20 affective as subjective judgments and inspections by people 21 that walk through the plant?

Is that the message that we're.

22 getting, or are we getting no message out of all of this?

23 MR. STELLO:

No, I think the message you're getting, 24 is if you look at the performance indicators, they.can tell 25 you where to ask questions for sure, but don't suggest.that.

=. _ -.

28 1

you can stop there.

You can't.

You've got to look at the 2

rest of the process, inclu' ding the judgment that's coming back 3

from the people that have been inspecting the plant, what do 4

they think; the people that are in NRR that have been 5

reviewing license applications, what signals do they pick up o

6 and what's their judgment; the data that we get from the LER 7

system, balance-of-plant system and what is it indicating to 8

you.

9 You really need to have all of those things on the 10 table and discussed to make the judgment.

I think if I'm 11 giving you one simple answer it's that you can't rely on.any 12 one of them.

~

^~

13 COMMISSIONER BERNTHAL:

Well, I agree with that.

14 MR. NORELIUS:

Can I make two comments that relate 15 to your question I think.

+

16 COMMISSIONER BERNTHAL:

Sure.

15 ::.

- 17 MR. NORELIUS:

One, in terms of finding :it,.Jin-said :-

18 Bert and I had been out there.

We were out there.-because

(

19 their senior resident inspector, whom we had just moved there : - -

l l

20 in '84, Eric Swanson, when he got to the plant he said-l 21 something's wrong with the maintenance program.

And I think

- 22 that's one important part of our system for early detection:

23 and we have to give Eric credit for that.

~:_..

- 24 The second point being on numbers that we : track. - We - -

25. : :

have been tracking in the region for sometime some maintenance -

.r,

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

29 1

backlog numbers.

One of the things you have to recognize, 2

though, is we take the numbers that the utility gives us and 3

if they have not identified all the maintenance problems then 4

the numbers have very little meaning.

5 COMMISSIONER BERNTHAL:

Sure.

6 MR. TAYLOR:

Sir, I should mention that at Turxey 7

Point it was knowledge of the age of those plants and also 8

input from residents.

There were concerns down there with 9

some issues in the aux feed and air systems that the residents 10 couldn't quite get their hands around -- technical design and 11 other issues, which helped to stimulate the decision by Grace 12 and myself that we'd go there.

That was one of the inputs; 13 the residents.

Very important input.

14 COMMISSIONER BERNTHAL:

Okay, that doesn't surprise 15 me.

I have to say that when it's all said and done it. seems ~ _;

16 to me that the strength of our resident inspector system _i~m'- ~

r-17 just clways going to be the first line of defense, and those M: _

18 are the people that, as we all know, you've got to rely on and 19 are going to be far more important in :the long term I think--

20 than any paper evaluations we can do from Washington.

21 A question about balance-of-plant systems.

Do you 22 feel that you have the authority you need in dealing with 23 these balance-cf-plant issues, in dealing with systems that 24 are important to safety rather than safety-related, which is 25 an odd misnomer but important to safety is less-important to

30 1

safety than safety-related, for the benefit of the press by 2

our system --

3 COMMISSIONER ASSELSTINE:

Not necessarily.

4 COMMISSIONER BERNTHAL:

Not necessarily, but by our 5

system of regulation it is.

Terminology, I should say.

6 So do you feel you have the authority you need to

-.7 deal with these balance-of-plant questions and that you're a.

8 able to categorize systems that are in the second tier of 9

safety considerations that ife call important to safety as 10 such, when you need to?

11 MR. MIRAGLIA:

I think an indication of that might 12 be, as chuck indicated, back in early February they had some 13 startups from an outage and we had concerns about what we were 14

. :seeing.

Some of the concerns didn't deal with safety-related-f :..

-15 equipment, dealt with balance-of-plant equipment.

And-it __

~.16 e

.wasn't one valve, it was more than one valve. -And,it was-.

.17

. because of those kinds of concerns that.we were seeing.in 18

._ balance of plant, based on the numbers,_that NRR and the-

-19

-region talked and said we don't like what we're-seeing, and we.. -.

20 want to talk with the utility and tell them we -don't like what 21 we're seeing.

22 And it was a result of those kinds of discussions --

23 I don't know if the question of responsibility or authority

r -

24 really entered our minds.

We didn't like what.we were seeing,

.- 25 :...we expressed our concerns to the utility and elected to; shut-

.y..__.,-_

31 1

down and repair.

2 MR. STELID:

I think he's given you the long answer; 3

let me give you a short answer.

Yes.

4 COMMISSIONER BERNTHAL:

You think you do have the 5

necessary --

6 MR. STELLO:

Yes.

There's no question in my mind 7

that whenever we have a problem we think that's creating a 8

safety problem for us, I don't care if it's the heads don't 9

work right or whatever it is, we can get it fixed.

10 MR. TAYLOR:

I'd certainly agree with that, sir.

11 COMMISSIONER BERNTHAL:

Good, glad to hear it.

~

12 Are any of the actions that you might propose here 13 going to be impacted by the backfit rule at this point?

Any 14 of the fixes, any of the measures that you might recommend 15 here -- is the backfit rule applicable or are you going 16 through -- have you thought about it?

Whether any of the i

17 changes you might order have to go through this~ routine?

18 MR. NORELIUS:

We took that into consideration when 19 we issued the CAL in May to agree that they would shus the 20 plant down until they fixed it, and we wrote the analysis 21 following the backfit rule.

So we have thought of it; not 22 beyond that in terms of specific fixes, but we have considered 23 it as we've been working through this.

24 MR. KEPPLER:

I think in terms of the ongoing' 25 programs right now that they're working with, I view that as

32 1

not involving the backfit issue but more demonstrating the 2

design capability and the operability of the plant.

3 MR. STELLO:

The biggest problem here is compliance.

4 COMMISSIONER BERNTHAL:

I understand.

5 MR. STELLO:

Compliance with existing requirements 6

and with the application.

No one is even talking about 27

' imposing anything beyond what's already there.--Our real

~

8 problem is making sure that what they were supposed to have 9

there is there.

That's not a backfit at all.

10 COMMISSIONER BERNTHAL:

I don't recall; did you say 11 that this water temperature problem, for example, was that in 12 the original --

~

13 MR. MIRAGLIA:

Their current Tech Specs right now I 14 think have a 70 or 75 degree number and they can't beat it.

15 '

~ So they're trying to return it back to-that level.--

~

~-

l 16

^

MR. STELLO:

But again, the issue is Eompliah~ce.

-- 2 17 ~

COMMISSIONER BERNTHAL:

All right.

One other

~

~

i l

18 question that's more generic I guess, and that is to l'nquiis

~

~

I 19 how you view this, or any lessons you might feel-that: we' can 20 draw from this for the Commission's consideration ^of~a 21 maintenance policy or the need for a maintenance policy.

Have l

22 you thought about that or are there any conclusions that you

~

l 23 can draw?

Would it be better or worse-if we tried to develop 1~

24 some general criteria for maintenance?- Is th,t necessa'y? E ~

2~

r l

I 25-MR. STELLO:

Our recommendation is to go with-the- ~

^" ~

.,----,.-r

33 1

policy.

I told you that the industry doesn't believe that but 2

we do.

We think we ought to be moving in that direction.

3 COMMISSIONER BERNTHAL:

And you think that would 4

have assisted in the early reccgniticn of difficulties in this t.

5 case?

?

6.

MR. STELLO:

No, I don't really think so.

I think 7

what we're looking for is the future, as to having a clear 8

sense of direction.

These plants are you going to be managed 9

by the industry and they've got to do the right job and we 10 have got to give them an understanding of what our policy is

. 11

.related to that matter and move in that direction and cause 12 them to move in that direction.

13 If we have to go into a lot of detailed,

~

. -14 proscriptive requirements to make this happen, that I think

_15 would be a very troubling path to follow.

It's got to come "

-16.
from within, and that's what I think you'll be seeing when yciui:

=17 have the Licensee come up here and go through.

~'~I'~

18.

COMMISSIONER BERNTHAL:

So you're saying that 'that -

is-policy as you proposed it, in your judgment, would have

20.-

assisted the utility then, let's say, in recognizing-that it

- 21 wasn't meeting the standard.

.22: -

MR. STELLO:

I think if they looked at their policy 23 and took it to heart, then yes, it would.

24 -

CHAIRMAN ZECH:

Thank you.

Let me just make a

25. -

couple comments.

I know we want to bring the Licensee up and- _

o 34 1

we've taken a bit of time here already.

2 First of all on performance indicators, I think 3

we've got to realize that performance indicators are just 4

getting started, it's maturing, there's lots of room for 5

improvement, they are just a tool but they're a very important 6

tool.

For example, maintenance itself.

You know, we're going 7

to wrestle with how best can we get a performance indicator 8

that really points out maintenance.

In this particular 9

area'it sounds like it would have been very useful to have.

.l 10 Eventually, -- I think we've got right now kind of 11 the easy performance indicators, the obvious ones.

Eventually 12 I think we should work towards the more subjective ones, the 13 -

more difficult ones, and when we get that we'll have something

- 14 that's very valuable.

We're just getting started right now.

15 -

I don't think we should recognize that we don't have a long f

16 way to go.

17 I do think that eventually they can be a tool --

-18 they'll always only be a tool.

People and human judgments are

. _19 always going to be what really affects our decisions, I'm 20 sure.

But I think they can be a useful tool.

21 One other thought before we ask the Licensee to come 22 forward.

It does seem to me that -- I'm encouraged by what 23 you tell me about the direction the Licensee is moving.

There l

l 24 is room for improvement, we recognize that, real improvement.

_.c

-25 I guess one of the things that bothers me as much as anything i

35 1

is the fact that we need to insure that there is what I would

~ ~

2 term an integrated approach to their analysis of problems, and 3

a root cause effort rather than just fixing specific, isolated 4

areas.

I hope that's taking place.

I get the sense from 5

what you're telling me that it perhaps is.

6 When the Licensee comes forward perhaps they can-

~

7 elaborate a bit on that because it does seem to me that we-

~

8 should be stepping back to see what are the big issues, rather-

~

9 than just fixing one thing at a time.

For example, the 10 off-site power events they've had that would indicate that' s't'ation blackout is something they should be focusing on. ~

~~

11 12

'That's a larger issue than just the issue itself; it affe6ts

~

13 other things.

14 So I'd like to think that there's integrated root

^

~

~cause, analytical looking at the problems rather than jusE

=

El-15' 16 fixing the specific problems.

2 ~

I 17 I'm assuming from what you told me that you think

~

~

18 they're moving in that direction; is that corrict?

And-I'

~ 19 would like the Licensee perhaps to comment on that whos'the '

~

~

(

20 come forward.

1 21 With that, I think we'll ask the Licensee to

~

~

22 come up and thank the staff very much.

2 23 COMMISSIONER ASSELSTINE:

While they're doing that 24 ~" ~~ lit me just add I think you're right in the perfcrmasce

" ' ~ '

L- !

~

~

' 25 indicator area that what we've got right now is sort of the T

o 36 1

bare bones.

I think one of the areas that we didn't come up 2

with performance indicators on because of the difficulty of 3

designing was in the maintenance area, --

4, MR. MC CORMICK:

Exactly.

5 COMMISSIONER ASSELSTINE:

And I think that's an area 6

.where we need to point out some of these things.

i 7-CHAIRMAN ZECH:

I agree.

Absolutely.

8 COMMISSIONER ASSELSTINE:

I think whether it's a policy or a requirement or whatever, I think that in the 9

10

. maintenance area one of the objectives has to be.to make sure

,5

_. : 11 _.

that in the future utilities don't let the plants get run.down_,..

12 to.the point where we don't have any basis for. confidence.that.,

13 the equipment is going to function as intended.

That's. pure

.and simple.

That's what it has to be.

14

15...

CHAIRMAN ZECH:

I agree.

We have to do.that.3,

_. _.;7 l

16 Please proceed, Mr. McCormick.

3___;.,.

n

, 17 MR. MC CORMICK:

Mr. Chairman, Commissioners,;I am; _...--

I

- - s

-18

- Bill McCormick, I am Chairman and Chief Executive of Consumers _;,,..

- - 19 Power and although sometimes it seems like I've been there:.a_,;

20 year and a half or more it's only been 14 months.

So I. wanted 21 to set that straight.

22 Let me introduce our top management team.

Jack.

l 23 Reynolds on my right is Executive Vice President and is.in -.

. 24

- charge of all of our power supply systems in the company.-

.,25

. Reporting him to is Fred Buckman who is Vice President o,f.....

3

37 1

Nuclear Operations, and reporting to him is Joe Firlit on the 2

left who is our Plant Manager at the Palisades plant.

3 Also behind us are several other members of our 4

management team.

Jerry Slade who is Executive Director of 5

Quality Assurance, Bob Rice who is Plant Operations Manager, 6

Richard Orosz, Engineering and Maintenance Manager, and: Dave 7

Joos who is head of our planning and administration.

T i~;

8 I'm going to give a brief overview and address some 9'

of the issues that the Commission has raised during the 10 discussion with the staff, and then turn the presentation over' 11'

'to Fred Buckman who will do the bulk of the presentation and 12~

will discuss what we found at the plant, the significant-13 issues that have been identified and what we want to do-about 14 resolving them and what we have done.

1 2: 15~

CHAIRMAN ZECH:

Before you go, I know we've cutkinto

' ~ ~

16 your time a bit but we are trying to attempt to concludeiby:

c' 17 11:30 if possible.

I know we have taken your time and':we'll -

18

give you a little more time if necessary, butiI.ask:yousto

'19 nove along crisply.

What you're going to tell us is very: :-

3 20-important to us but please try to move crisply.

21 MR. MC.CORMICK:

I'll certainly do that.

If you'll'

- 22 turn to the fourth slide, I won't bother going through-the' 23 performance history.

I think Chuck Norelius has done that. '

i-tr 24~

(Slide.]

~

-- 77" 25 But I do want to emphasize that the plant:

l

1 38 i

1 difficulties that were encountered in the 1983-84 timeframe 2

were quite severe and were in connection really with the whole 3

shutdown of the Midland plant.

I think the Commission knows 4

that there were very substantial financial difficulties of the 5

company at that time which reflected itself really not just in 6

the nuclear operations but throughout the company..And this....

7 resulted in a deteriorating maintenance program and very high, 8

personnel turnover, which I'll discuss in a minute.

9 Obviously, there was an attitude problem, the.

10 company was in difficult shape and this reflected itself at 11 the plant.

12 At the very and of 1984, Joe Firlit was installed as;.

13 the new plant manager, and I think at that time the plant 14 began a new cycle of improvement.

The plant ran at a.90 15-

- percent capacity factor during most of 1985 and then shut down-3-

: c.--

16-at the and of 1985 for a scheduled refueling outage.

2._

17 When I arrived at the company in late 1985 it was 18 pretty obvious to me from looking at the basic. numbers of the i

19 plant, the maintenance backlog, the control room deficiencies.

20 and many of the other indicators that we had some significant 21 maintenance problems, and while Joe and his team at the plant 22 had been in place for almost a year and had made significant 23 progress on those, thera was still quite a bit left to do.

24 In February Fred Buckman, to my left, was installed

(

. _ 25 as the new Vice President of Operations.

Fred has had a.long I

p---g

.-,e.

m

,,.n

_ - ~,, - - -

39 1

experience with the plant, was away from the company for 2

several years but we managed to get him to return.

3 I won't get into the specifics on the plant trip; 4

Fred will cover those.

But during the plant trip we 5

discovered several things.

Of course, there were specifics 2~~

6 related to the trip itself, but we also learned that the plant-~ -

~

7 material condition was probably worse than we had realized. --

n n 8

We knew it was bad, we were brinning the maintenance backlog 9

down but we discovered it was worse than we thought and'we.

1.

10 also discovered a few design-related issues as well, and Fred...:

11 will addreas those.

12 -

With my remaining time, I want to just summarize and

'=:

~ ' 13 highlight some of the accomplishments that the company has 4

~ ~14 achieved during 1986.

As I think you are all aware now, we -

--
~ 17-15^'

~ have been in this maintenance outage for eight: months.r : Wen-'

! 20:

7-16-have had a very, very comprehensive review of allithe systems -

-17 in the plant and I think have made some significant

=.

18' -

accomplishments, and I will address those very-briefly.

~ ~ ~19 - - -

~

(Slide.)

n rr

'20 on page 6, we have resolved and tested-the specific 21 trip-related problems.

Our maintenance work orders at the end -

22' of 1984 were 4000; we reduced those to 2350 in '85, and at'the i

23 end of 1986 we were down to 1077.

So in effect,'we:'ve cut

~'

-~~Iur maintenance backlog by a factor of four.

of those 1077; r-

~

2

24' -

c I

~ T*

~25'

'-there are roughly 200 that have been completed that won't be

--e-i l

40 1

1 able to be tested until we bring the plant up.

We now have an 2

eight-week inventory.

3 Our control room deficiencies.

At the end of '84 we 4

were 161; we reduced that to 65 in 1985, and by the and of

~ - ~-

5 last year in 1986 we were at 7.

As I mentioned, we've

= ~ -

6 resolved the design-related issues although we haven't 7

completely taken a count of them.

We've identified them, 8

indicated what we're intending to do.

Some of them have been 9

fixed and others are awaiting the implementation of the plan.-

10 We've streamlined the plant management.

Wo.'ve 11 increased the maintenance personnel very significantly at 12 Palisades.

13 (Slide.]

14 On page 7 you can see we've reduced our radwaste

- 1^'

- 15 production at the plant by roughly a factor of.3, from 18 r000 1_

' 16 ~ -

cubic feet down to 7,000.

i 17 We have received INPO accreditation of -five of. our.

18 programs last year.

The others are completed._ajnd now await _ing_.

19 INPO action.

'20 Getting to the employee turnover, I will highlight.

21 this again.

In 1984 we had a 17 percent turnover at the 22 -

plant.

In 1986 we reduced that to 3 percent.. I won't get I

23 into all the issues, but this churning of people was really a 12t:

. very serious problem at the plant.

l We established what we believe is one of the

27125

41 1

toughest fitness-for-duty programs in the industry.

We have 2

unannounced, random drug and alcohol testing for all employees 3

in our nuclear operation and on a random basis twice a year.

4 And we achieved the best safety record of any of the large 5

combined electric and gas utilities in the United States last 6

year for the second year in a row.

And at the Palisades plant.

7 particularly we have gone three years without a lost-time; 8

accident.

9 That's an overview I think of some of the 10 accomplishments that we've made in the last year.

I want to 11 emphasize before I close that we have recognized;that we'.ve 12 had some serious problems.

I think we're taking the steps 13 that we need to take to address them.

We realize we aren't 14 -'

through all of them, but I think from the indicators I've

~

15 - r given you you can see that we have made some very-significant 3,

16 strides in the last eight months since the outage _ started,- -

17 So with that, Fred, if you could quickly go through _

18 your material.

,r-3:

19 MR. BUCKMAN:

Certainly.

Mr. Chairman,

-20 Commissioners, thank you.

21 (Slide.)

l 22 Bill mentioned three issues that were important for l

23 us to resolve; trip problems that came out of the May 19th 24 trip, I think material condition problems and design-related-l 25 issues that emerged from the outage.

us_;;..

I

~

42 1

The May 19th trip was caused by a failure in the 2

secondary part of the plant.

We lost power to the 3

electrohydraulic control system.

We had several problems that 4

were identified during that trip, mostly secondary plant.

5 Individually they were not particularly significant problems 6

but collectively, I think they raised questions. about plant 7

natorial condition, about the effectiveness of;our_ maintenance 8

programs, and led to a decision to do a much more_ thorough 9

review of where we stood with the plant prior to restart.:

10 I don't intend to say much about the trip-problems 11 themselves except that they have been resolved.-- They've-all 12 been taken care of, they've all been fixed.

I_do intend..to, - c-13 cover in somewhat more detail what we have done both to 14 address the issue of material condition and also to; address 15 design-related issues that have come out of the. outage,

-. n.- sac 16

[ Slide.]

-_.:n n-

..e

_3n t 17 There was a lot of soul-searching done with regard :-

..t.

18 to why plant material condition had deteriorate _d_.:

We-th. ink 4

19 that we can focus on three issues.

One is that we had 4 realp _

j 20 loss of morale and a loss of experience in our: operation; i

21 during that period of 1984-85; that we ended up with t

22 maintenanca problems both in terms of quantity and quality. of_ -

23 the maintenance that was performed, and that we had some 24 organizational and programmatic weaknesses that inhibite$ us-25 from doing all of the maintenance that should b_e.;done r

-..,n._._-..,..,

._y,,

.n.

43 1

Included in that would be things like lack of preventive 2

maintenance work on the secondary side of the plant, a 3

willingness on the part of Operations to accept standards of 4

operation that were lower; that "in my opinion, it should.be 5

accepted," things of that nature.

6 But there was a recognized need I think on the part 7

of Consumers before the trip to address the problems, initiate-8 efforts and improve material conditions.

Some of the reasons 9

for that were to assure reliability, minimize. operator 10 work-arounds and to reduce inventory.

11 -

(slide.]

-L-12 On page 10 there's a list of some items'that. ware 13 initiated prior to the May 19th trip, and I don't intend to 14

-spend a lot of time on them.

I'd like.to focus.on things

~ ;

I' - 15 G we've done since the trip.

But there was a significantil'::

ss se 16 reorganization that took place with new plant management and

- 1 71

- ^' transfer of a lot of staff from the general office to the.

' plant.

The implementation of a Maintenance Order-Task-Force

- 18

!-~

~ 19 ~

to'go after programmatic difficulties in the Way'we handle - : :~

' 20 maintenance orders.

An effort to reduce maintenance inventory 21

- -we had before this trip reduced it from over~4000~to less.

22 than 2000 in backlog.

The implementation of a: system engineer 23 program that I think is largely patterned after one that I saw 24--

~ at Prairie Island and one thing I think is very effective =in 2: 25 terms of developing sponsorship for each plant system in the i

44 1

engineering ranks.

2 A system assessment program where the new plant 3

management went out and walked the plant to make a personal 4

identification of what it was that needed to be done.

The 5

implementation of an advanced maintenance management system to

~

streamline the way in which we dealt with our maintenance 6

---~7 orders.

8 The conduct of an operational readiness assessment; S

this is something that was discussed briefly in'an earlier 10 part of the presentation.

Back in April, I commissioned a 11 group of people to do an SSFI type of inspection at both; Big 12' Rock Point and Palisades, and at Palisades we focused on the

~

13 main feedwater.and auxiliary feedwater systems, but had 14 started the process of identifying design-related issues and "15 -

configuration management issues prior to the trip.-

1" I~

"~

l

~

~'l6

~

We had started the formalization of a preventive

~

~~

7 17 maintenance program and had involved our Maintenance 16 Department, both supervisors and actual-repairmen 1n the-

~~ ' ~ '

~

19 formulation of this program, and we had taken iction to' deaf i

20 with our turnover by implementing a competitive' salary program-21 which allows us to retain good people.

22 COMMISSIONER ROBERTS:

Are you saying you were not 23 competitive in salaries prior to this?

2'4~

~

MR. BUCKMAN:

Well, during the time of the~-

I

^2"

~

7 2

25 difficulties we were having with Midland that led'~to the

45 1

shutdown, we went through a period where we reduced people's 2

salaries, we froze wages, postponed salary increases, and I j

3 think in a relatively short period from maybe mid-1983 until 4

the end of 1984 lost a lot of ground with the industry.

i 5-MR. MC CORMICK:

And a loss of good people with it, 6.

by the way.

7 MR. BUCKMAN:

Indeed.

8 I'd like to focus more on actions that were taken 9

during the current outage.

10 (Slide.]

'~

11 The actions involving material. condition, I have~

1: ~

-12.

five bullets listed including a task force, improvements in 13-the maintenance program, improved material condition, a 14 testing program and a functional evaluation.

And for purposes-

~

15 of material condition, I think I'll restrict my- ~ focus" t'o' the~ ' li?"' '

16- :-. first three bullets; the task force, maintenance prograd and'-

5~1"1I

. material condition.

'l

~

U~

-- - ~~72U 1-18

[ Slide.]

2 17 ' t ' ~

22

  • CC 19-Now, the goals of the task force, as we "see: on~ page Il--

~ ~ '

20 12, were really to assure that when we put the plant back~in -

21 service that we have proper system operation for all of those l

22 systems which are either important to reliable operation, ~~

23 important to safety or safety related.

~ ^

~

24 In order for us to collect a complete picture o'f

~ ~ ~

25-

- what it took for us to do that, I have almost a-cartoon here~

~=

l

46 1

which shows the kinds of things that we did to make sure that 2

our list of things that we needed to do was complete.

In 3

addition to going through the work order history we went 4

through plant trip history, control deficiencies, we went 5

through interviews with system engineers and with our 6

operators.

We went through an operator concern list, we went 7

back through our corrective action system looking three years-8 back to see what kinds of problems had been recurring problems 9

in plant operation.

A very thorough review.

10 From that review we developed a set of issues that

. - we thought were appropriate to address.. Some of them had to:::

12

.be addressed, in our view, prior to plant startup; somanof 13 them are longer-term issues that are I think more related to 14

, making this plant a top performer in the United-States than to 15

--meeting standards that would allow us to put the plant.back.in: -

i 16 operation.

-=: ::::_

____2::

17 We took all of those issues and presented them to.an 18 executive management review committee consisting of two.vice 19 presidents; me and one other vice president, and the plant :._

20 manager.

And over a period of about three days, reviewed 21 every issue, every action on the list, and the real purpose of 22s the executive review committee was to ask the question:

why-23 can't we do it now.

If there's something that we -can do now,--

c-

- 24 let's do it now rather than postpone it and do it later.

(Slide.]

47 1

on page 13 I have a list of the gsnaral guidelines 2

that were used in figuring out which actions we should do 3

prior to startup, which ones we could postpone either until l

4 the next refueling outage or include in a five-year plan.

i

.5, The guideline effectively was that those deficiencies which 6

relate to proper system operation should be done now;_those 7

things which involve more things like modifications.or..

8 long-term reliability or things that if we didn't have, parts, 9

hadn't done engineering we might be willing to postpone.until 10 the next outage.

And those things which involved enhancements 11;,

to bring this plant to our goal, which is one of the top ten 12 plants in the United States, were things that in some.

13 instances we wanted to put on a five-year plan to allow us to 14 avaluate fully and determine what option was the best. option n,. 3 5;

..to allow us to deal with the specific problem.-...

.g.....

16 I'd like to give ycu an example of that. _one of the

_.17 systems at Palisades that's been a recurring bad actor is the

. 18 instrument air system.

It's a non-Q system non safety-related_

. 19..

system and yet it's an important system in terms of both 20.

normal operation and responding to plant casualties.

21 Prior to startup we decided that we would rebuild 22 -

one of the air compressors that had been a problem and that we 7

23..

would go through a full preventive maintenance program on the.

_24_..

other two.

We decided that prior to the next startup after 25 the refueling outage, we were going to replace at least one;of

\\

- ~ _. _

48 1

those compressors with a new compressor that we thought would 2

have a higher reliability and more capacity, and if we had 3

good success with the operation of that compressor that we

~4 would replace the other two within the five-year plan type of 5-horizon.

That was the general type of philosophy that was 6 ^

used in assessing what kinds of things we did.now and which 7

kinds of things we did later.

8

[ Slide.]

9 The result of this material condition review was the 10 identification of 222 issues; 14 of those issues we determined 11 required no action, that while it was an issue:it was an issue' 12' that had been dealt with at some other. time. 1159-issues were :=~

13 issues that had to be resolved prior to startup,:and 49 issues.

l'4

~

were to be resolved after startup, although on most of those

-~~r-'-

15 49 issues there was at least come action taken during this:

r e.. -;

16.:: outage.

1 77-(Slide.)

50.--

t The next page shows a breakdown of thei49 issues.

- - 2:

18 19 -- that are resolved after startup, and really the only purpose-

~

^

~ 20 here is to point out that these are issues that -- or actions 21 that represent primarily improvements and not corrective

- ' actions that are necessary to fix.

I think we're doing a lot--

-2 3-

'- better job of root cause determination and recognizing that if 3 T '2 4

~ we really want a top performance, that it's not good enough

~~

~

~~-

E'

2 5r - - simply to fix a piece of equipment but you have=to'go after

.-,_..n

,--_,,..,,.,,,-__.-.w.,

,a.,

e

_,__a---_-_,._

49 1-some long-term improvements in this plan to get there.

- - 2 (Slide.]

3 In addition to a Material Condition Task Force, we 4

- also -- the second bullet on my slide of things I wanted to i

-. : : -' 5-address in material condition had to do with an improved-6 maintenance program.

We recognized that our maintenance-7 program really wasn't up to the standards that we needed in 8

order to run this plant effectively.

Some of the problems 9 ~

that needed solution were I think problem identification-and-10-root cause determination, our diagnostic process for

L1 maintenance; some deficiencies that we have in maintenance:...

c-2 - skills I think particularly in the valve area;.our J'

12 :

13 post-maintenance testing program, our preventive maintenance; J

~

14' and the prioritization of work.

i' i c Li-21513:

Now, we've taken a lot of actions to addressethese.;

16 problems already during this outage.

We have connleted a 17 reorganization in our Operations Department to enhance the...

-~~ 18

- -maintenance diagnosis problem.

We have.a group of peopleein -

' 19-

" Operations whose full-time job is to work with-maintenance -and:

20

. help in the diagnosis of problems; doing testing-to_ determine-I 21' what actually is the cause of a specific deficiency;.to help l

22.-

~ -in the prioritization, which of the issues that are out there l

23 -

are issues which are most important to operators; and to I

- 24::

provide the plant in the proper condition to allow a.

j 25 -- 1 post-maintenance testing when the maintenance is-complete,:

'l l

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

50 1

We've enhanced and formalized our post-maintenance 2

testing program, we've increased our work force in mechanical 3

maintenance by 50 percent, from 38 to 57 people.

We 4

streamlined the maintenance organization; we've eliminated a 5

level of management to get the supervisors and repairmen 6

closer to management so that the ability to transmit standards 7

through the organization is improved.

We also happen to have 8

done that in the operation. area; in fact, since this new 9

management team has been on site they've removed two levels of 10 management in the operations area with the same purpose, and

- 11

-that is to get the standards of the plant manager closer to-12 the worker.

13 We've increased the use of contractors at the site 14 to supplement the plant expertise and to help deal with

- - :-. :15 = = 1 the lack of skills that we have in certain maintenance

- --16+

functions.

And we've put in place a training staff._on site.to; ; g

-17 deal with mechanical maintenance.

We have a skills training

18 -

. program off site but we decided that we wanted.to supplersnt

- :19 that with some on-site training.

We've added two mechanical 20 trainers, an electrical trainer and an industrial safety b

R21 trainer on site.

We have two classrooms in South Haven and a

'22 laboratory to deal with this on-site skills training.

i 23 COMMISSIONER BERNTHAL:

The objective I assume is 24 eventually to replace the contractors with your own. people..

25 - -

MR. BUCKMAN:

Yes, it is.

At this point, -- and.I:

- - i - - -

e f

-,_w,.,.

-n.

51 1

will cover it in a couple of minutes, I think the major 2

contractor issue in 1987 is going to be in valve maintenance.

3 And we would like to have a skilled group of our own people to 4

deal with valve maintenance by the end of this year.

Part of 5

the contractor purpose is to do some on-the-job training of_.

6 our own people.

7 (Slide.]

... -. _z. _

c.

8 Page 17 shows some actions which are.still in.

9 progress in the improved maintenance program area.

We are..~

10 accelerating the full implementation of our preventive 11 maintenance programs we expect to have it implemented by -

12 mid-year.

We are now in the process of implementing-an l

13 equipment monitoring and trending program.

We are doing that_.._.

14 with some equipment; we don't have it with all equipment yet is.-

- - 15 but we do expect to have it pretty well completely.implementeA.

c.-

.16 by the end of this year.

_. r_
r. :

.e c3 17 We have a valve maintenance program that we're

7._r.

18.

undertaking right now with an outside vendor... e have..the_.

_y, W

19 vendor on site under contract and are starting that work. - ;;-

20 We expect to achieve accreditation of our training.

21 programs in electrical and mechanical training by about the

.22 third quarter of this year.

We've done the things that we 23-need to do, taken company actions and expect INPO action-about - ~-

24

-the third quarter.

And we've implemented and are acting upon.

25 --

a system engineer training program, getting our system

52 1

engineers training in both plant systems and, in some cases, 2

getting them licenses, SRO's.

3

[ Slide.)

4 I have a slide here, page 18, on results.

I think i

5 that someone else earlier said that really the results will be-

~

6 seen when we put the put the plant back in service and see how 7

it runs.

8 One item I do want to mention is that we did heat 9

the plant up in November to do some hot testing, do some

~

10 post-maintenance testing and things of that nature, and I l

11 think it was a pretty successful heatup.

Those operators who 12

~ participated in it said it was one of the smoothest heatups' 13 they had seen at the site.

We had a low primary coolant leak

~ rate which has been a recurring headache for Palisades; it was ~

'14'

.e;.

i 15 less than a tenth of a gpm.

And of the work orders that we-.-

16 did our post-maintenance testing on, we had about 270 of;them" in the queue that we tested and only about five require.d 17

' ~~

18 '

rework.

We view that in terms of the effectivenes's of our~-

1h maintenance program and we're seeing some improvement over'

~

= ~ ~

20 what we have seen in the past.

21 But really -- and I think the operators expressed

~

22 this best -- we want to see the plant in operation, and that will be our best measure of whether or not there's really~a 23 f

~

~~'24

" payoff in what we've done here.

~~

~

2

~25 CHAIRMAN ZECH:

But you've got to be reasonably - ~

~

53 1

confident that you've made some improvements, some real 2

improvements, before you start it up.

3 MR. BUCKMAN:

I'm confident that we've made 4

improvements, and I've been out and I've talked with four of

~

~~5 the five shifts of operators about their level of confidence.

~

6 I think their level of confidence both in the quality of the-7 plant and the quality of the maintenance process is quite 8

high.

9 CHAIRMAN ZECH:

But you've got to see some results 10 if you possibly can before you just start up the plant.

11 MR. BUCKMAN:

And that's also part of_our testing.

12 program that we'll talk about.

It's not an attempt simply to 13 turn the key and go to full power.

14 CHAIRMAN ZECh:

That's what you call a hot test, you

- 15 know.

Sometimes that's not the best way to do it.

-You've.got --

16' to be confident ahead of time.

17:

MR. BUCKMAN:

We're going through a lot _of cold _ :

i

- - 18 testing and we'll do some hot testing., There are_;a lot of-

  • 19 things that we want to do.

CHAIRMAN ZECH:

Okay, good.

20 21 MR. BUCKMAN:

There are some measures of l

22 accomplishment that I think we can point to, and slide 19 is a

~23 graphic picture of what Bill McCormick mentioned earlier in l

24 terms of reduction in the number of open work orders.

i

- J:25' (Slide.]

I'. T' l

t

54

?

We really have made a lot of progress in terms of 2

the maintenance inventory at that site.

3 (Slide.)

4 slide 20 shows a breakdown of where those open work 5

orders are.

We've got about 1077 -- these are December 31st, 6

1986 numbers.

1077 was our total list of open work orders.

7 of that, we had 208 in post-maintenance testing and 53 that 8

had been completed that hadn't been signed off.

9 Go down the list, and really the corrective work 10 order backlog was 663 work orders.

Then I have a 11 _

sub-breakdown that shows of those 663, where do they sit.

.As; 12

.-you can see, the lead item is valves and valve. operators,.a_nd 13 that's the reason for this comprehensive valve program in 14- _. 1987.

We still think that there's a lot of progress we.can 15

.make there.

37_ _;.,

l 16 Our goal, by the way, for 1987 is to reduce;this.3..

.33.

17

. corrective work order backlog to 300, and we think that_that's7;.

18 a pretty ambitious goal because at the same time;that we.'re.,,

19 trying to beat this open work order inventory down, we're also i

j 20 raising our standards with regard to what ne ask people to--

1 21 identify.

And we're asking them to be more demanding in 22 making sure that things work right and that small. leaks are 23.

identified before they're big leaks and things of that 24 nature.

And so we're putting a lot of heat both.on the.

j 25 Operations Department and Maintenance Department.

9 y---.--.

-e--

,.-.,.-y...,r....

,_,,,,,_v_w,,_,,.__y,w__,m.

._...,,._____,,,..,_._,,_m._,.

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

55 1

But we think we have to get this corrective work 2

order backlog down in order to do the things we want to do 4

3 with preventive maintenance.

4 COMMISSIONER BERNTHAL:

Excuse me.

Do you think 5

your plant has enough in the way of modern diagnostics to 6

permit you to do that?

Are you satisfied with the diagnostic -

7 capability you have?

8 MR. BUCKMAN:

Well, I do think that there is enougn 9

diagnostic capability to support the kind of goal we're:

10 talking about here.

I do think, however, that this plant is 11 deficient in a couple of areas that do inhibit our. ability to

-12 do all the things we'd like to do.

And some of the-action.

13 items from the task force address that.

-14 This plant wasn't built to allow us to do 15 post-maintenance testing.

We don't have test-taps-onreither 16

- side of the valves in a lot of cases that would allow us.-ton.

- 17 pressurize one side and see if we've solved the -leak. problem.-- :-

f.

.- 18 We've got check valves that in order to repair you-have:.to. :.

- 19 take.them apart and the seat comes out with a-bonnet.: You-can_. _

20 do all the lapping and blueing that you want but the fact is- - -

.21 you put it back together and there's no way you can inspect

. 22.

whether or not you've got a good seal until you get the plant

- hot and do a pressure test to see whether or not you've been-

-, effective.

c-

r-.25 So from that standpoint, this plant is.not.as modern--

,.__._,-m

,.._,,-__,.,c4_.

__..,,.m,__

)

56 1

as some of the later plants are.

But there are other plants 2

of the same vintage that are doing a better job than we're 3

doing, and I think that our standards -- you know, we're doing l

4 a better job now than we were doing a year ago, and I think a 5

year from now we need to be doing even a better job than we're i

6 doing today.

7 COMMISSIONER ASSELSTINE:

Fred, in terms of the 1

8 number of corrective work orders, how do you compare the

.J 9

number of work orders written in 1986 as compared to '85 and 10

'84?

Are your people identifying more things?

'll MR. BUCKMAN:

I thin they are,~although I don't~have

~

the numbers with regard to the numbers that have been 12 13 identified.

But I think the level at which they're 14 identifying things -- whereas two years ago, I feel that if an f5 ~

" operator had walked by a valve which had a small ahoint'of

~

16 ~ ~

boric acid but no visible water, he might have' walked by~that

~

f 17' and said that's a no, nevermind.

The standard that we're f

18 trying to get drilled in today is that that's a' problem; that f~

~

if you.can see boric acid on it, let's write it up, let's

" ~

19 20 allow an engineer to go out and look at it and'let's figure 21' out where it belongs in the priority of things that we're 2'2 going to do here, but let's not miss it.

l 23 And part of what you mentioned earlier with regard l

24 to paint and polish in terms of the plant, recognize that some l

~-~~~^25 of %hht may be a bit cosmetic, but we are trying to do a

57 j

1 couple of things in terms of making it easier to identify 2

problems.

And the cleaner the plant is the easier it is to 3

identify problems.

4 Also, I think that the cleaner the plant is the more 5

pride people have in the plant and the more willingness they 6

have and motivation to identify these small things and go do 7

something about them.

8 COMMISSIONER ASSELSTINE:

I agree with that.

9 (Slide.)

10 MR. BUCKMAN:

Slides 21 and 22 are I think other 1

11

.measur6s of material condition that we've concluded are-12 important.

Slide 21 shows the same evidence on control room 13 deficiencies that we showed in work order backlogt down from 14 _.

161 at the end of 1984 to 7 at the and of 1986.

Now this is 15. ; _ _ an area where I think we've made a lot of success.._We have. _,

. 16 _

our control room deficiency numbers down to the point where __

17

_they're being managed individually rather than managed by --

_18 let's see what we can do to drive the numbers..down.

We now l

19 have a number of people at the plant who can walk around.and.

20 tell you what each individual deficiency is and what their 21 role is in taking care of it.

And I think that's what we're 22 trying to achieve in a number of these areas that are good _

23 measures of material condition.

.24 (Slide.)

_ _ 2_5 Slide 22 is the same information although it onlyz

58 1

shows 1986 data on jumper link and bypass control.

It happens 2

that that's the only year that we have this kind of detailed 3

data on but it happens to be a personal issue of mine; it's

- 4 the extent to which the plant has temporary modifications

.5

. associated with it, and I think even at 24 it's.not as high as

-6 I want it to be but we've shown a lot of progress from where 7

we were earlier this year and we expect to see.-that number.

8 continue to go down.

That's a number which I think is already 9

relatively low by industry standards but it's not low enough 10 for my standards yet.

-. 11:

COMMISSIONER ASSELSTINE:

Do you have'a-goal for

. - 12 : - - -

1987?

~

13 MR. BUCKMAN:

We're talking about a goal; we~ haven't 14 set it yet,.but the goal we're talking about is around 10.

The topic I've just talked about is material

- :.. ;: 515 c.
- - - condition.

I'd like to shift gears for a momentrand: talk i

17-about design-related issues.

.+

c r

- 18 (Slide.)

i+

- 19..

There are two kinds of design-related-issues-that-

--- 20

- have emerged out of the work and inspections from. this 21 outage.

One is conformance to design; is the plant built ~the

- 22 way it was designed.

And the other is, is the design that we 23 have there adequate.

And I have up there a couple.of examples 24 of each of those kinds of issues that have come out of this.

.-:25 In terms of conformance to design -- and the first;.

. _ _ =. -

_ ~. -

59 1

one of these to arise was a finding that one of our safety 2

injection pumps was giving us low flow.

We also found, as was

^

3 mentioned earlier, heat exchangers in our component cooling l

4 water system that were undersized, and we found as a result of 5

some additional testing that we did that the service water system was giving us low flow.

j 6

7 In terms of adequacy of design, the kind of issues 8

that I would raise -- and there are some here th'at were raised 9

both by our own people and some that were raised by the NRC 10 through inspections.

We have three half-capacity service 11~

water pumps that we split between two diesels, and I don't ~

12 care how you cut that flow up, it's hard to find yourself in a 4

13 situation where you can get 100 percent flow with one diesel 14' in service.

15'-

Now, we have done some things'to -- there werd'some~~#

' ~~

~

things done in the original design of this p15ni^to-5 meliorate '

~~

16 17 that problem in terms of emphasizing containme'nt~ air coolers-

~~

i 18 when we're on one train of electric power, emphasizing l

'19'

~ containment sprays when we're on another train of emerg5ncy

~

"~

~

power and things of that nature which allow us to kind of ~

~

20 21 slide by in a minimal fashion.

But in'ay view it's not the

~

'way we'd like to have this plant in the long term.

W5 really 22~

1 need more service water capacity; that's a fundamental 23

~~

~'

i 24' problem.

~

I

'25-~

We found the problem with our recirc actuation i~

t

,__m.,__,

60 1

system logic when we had a DC failure that was found with some 2

engineers when they were up playing on the simulator and they 3

said let's try what happened to be a relatively odd sequence 4

but nevertheless a believable sequence, and it didn't behave 5

the way they thought it would.

As we started pulling on the 6

string we found that there were really some problems that 7

needed to be dealt with.

They have been dealt with.

8 There were some SSFI items that I've listed up here 9

that were identified during the SSFI inspection in terms of 4

10 failure to lock in a signal on recirc actuation, the fact that 11 we have valves that have dual position responsibility in g

12 certain kinds of safety events and yet they're powered off i

13 instrument air which is a non-safety system.

A check valve 14 testing problem at the boundary between high prescure and low f

15 pressure air', and the fact that we had two breakers that were 16 classified as non-Q breakers but were performing a safety 17 service function.

18 (Slide.)

19 In terms of resolution of those issues, I don't 20 intend to -- unless you'd like to go into them I don't intend to talk about the resolution of each item, but to say that all 21 l

22 of those things that we know about were taken care of prior to i

23 plant startup.

And most of them were taken care of with l

24 hardware changes; there are a few of them which were taken i

25 care of by analysis or by Tech Spec change where we've got I

61 1

what we think are really long-term issues to deal with.

2 Service water, for instance.

There was talk earlier 3

about the Tech Spec asking'for 53 degree service water 4

temperature limit.

We're also, at the same time, going back 5

and backfiling our service water impellers, and we expect that 6

prior to startup we'll have the capability to run the plant 7

with 75 degree service water.

We haven't done the. testing yet

~

8 to support that, but we think that that's where we'll be.

9 But we also recognize that this three half-capacity 10 pump issue is a problem, and even if we can get back to 11 what was originally described in the FSAR we're not satisfied..

12 that's good enough.

1 13 With the CCW system and the undersized heat 14 exchangers we're satisfied that we can effectively retain the.

F: - cr -: 15 -

- safety margin that was described because we have-very low heat r-Hr--~

16 '

~1oads in our spent fuel pool, but that at the:next. refueling: -

l 17 outage we're going to increase the heat load in-the fuel: pool, l

18 increase the heat demand there and we need to take some action 19 by that time.

We haven't figured out what the best action is 20 to take; whether we ought to go in and beef up the heat-- -

21 exchangers and push more flow through, whether we ought to 22 isolate some other loads, whether we ought to add heat-23 exchanger capacity, pump capacity or what it ought to~be, but-r 24 we're committed to fix the problem.

But we need to"do7ther t ' il

~

'" c r 25

engineering first that will allow us to decide what the best -- ::

~

62 1

fix is.

~

2 There's also another question that we've tried to 3

face and we've tried to face head on and that is if we found 4

these problems that we've identified in terms of conformance 5

to design and in terms of adequacy of design, what are we-

=-

l 6

going to do about the ones we haven't found but what might' 7

still be out there.

And what we've done is we've implemented'

~

8 what I think is a multi-level approach to dealing with' this -

9 issue of safety assurance.

10 The first is that we implemented a pump testing

~

11

' program.

We knew we had a flow problem so we said okayP let's--

12 go out and test those pumps that are important? to us in terms -

~

13 of performing a safety function, whether they be safety -

~

~

'~'

{

14 re. lated or non safety-related pumps, and we tested them all.-

15 We also -- and I think that this is a 'ornerst6^no'f li J

"4 c

e 16

' our analysis for return to service -- are in the procesi ~of'3'-

2 F

17 completing a system functional evaluation and I'll talk 'about- ~

'18 that a little bit more later.

We also have an-integrated ~ test'-

~

~

22' 19 program, and I think that those first three items'ther~e,'the

~

pump test program, the system functional evaluation and the~

~

20 21 test program, form the basis for saying okay, we~have

~

22 confidence that we can put the plant back in service.

~

2 l

23 But we also think we need a continual-looking for

~

24 problems.

We don't want to stop and say okay, we'll~ deal withe ~ !!

25' them as they crop up.

We want to look for problems,-we'want

~1-

63 1

to re-establish the design basis, wa want to do a lot of 2

things that involve this configuration management issue, and 3

so we're also implementing a configuration management program 4

which we expect to be pretty long term.

5 I have some slides here on the pump test program 6

which I don't think we really need to go into; just leave it 7

to say that we've looked at all the pumps that-are important -

8 to plant operation or plant safety.

The status of that is 9

complete.

10 In terms of the system functional evaluation I have 11 two slides here and I think what I'd really like to do is 12 focus on Slide 27.

13 (Slide.]

14 What we've done here is we've taken all of those

=.

l 15 systems that were effectively the same systems that were used -- r 16 in the Material Condition Task Force, those systems which ara-

=u 17 important to reliable operation, important to safety,. safety 18 related, whatever, and we said what are the operating. --

r 19 requirements that we want to fulfill.

~ :- -

20 Now, there are two halves to this tree.

One is-21 normal operations; what do we want the plant to do simply to 22 be reliable, and there we've looked at operating procedures, We've looked at the FSAR, we've looked at the extent to~which 23

  • 24 we've maintained or modified these systems during this current-25 outage and we've come up with a list of~ operating

64 1

requirements.

2 We've done the same thing from a post-accident 3

standpoint by going through our emergency operating procedures 4

and looking at the critical safety functions that we try to 5

achieve; reactivity control, post-accident containment 6

cooling, water inventory, whatever, and said what are the 7

success paths.

Don't ack whether they're safety-related 8

success paths or non-safety related success paths, but what 9

are the success paths that we can use in order to get to that 10 success with those critical safety functions.

And with each" 11 of those success paths we've identified the system functions 12 that need to work in order to get there.

i 13 From that list of system operating requirements 14 we've gone back and looked at the test programs that we -

15 routinely run, either in terms of normal operation or~

16 surveillance or whatever, and said which of those operating.

17 functions are fulfilled by a normal testing function.

And l

18 we've come up with a set of exceptions, things-that we don't"'

~

19 routinely test, and for every one of those exceptions we're :

20 either going to do a test as parc of the testing program in :-

21 returning to service, or in some cases we're doing an 22 engineering evaluation to say that this is adequate.

23 And an example of an engineering evaluation, there's 24 one that I remember that has to do with a blowout pa..al on an '

25 instrument panel that when it gets to a certain~1evel'of' water-

65 1

behind the panel, the panel is supposed to fall out to keep 2

the water from going higher than that.

We're not going to 3

fill it with water to test that, but we are going back and 4

we're doing an inspection to see that there are no obstructions and doing an analysis of the retaining bolts to 5

6 see that they go at the right amount of head and that sort of 7

thing.

8 At this point, I think I'd like Joe Firlit just to 9

say a couple of words about our test program and then I'll 10 make a couple of concluding remarks.

.11 MR. FIRLIT:

What I'd like to point out here is that 12 Fred had talked about the test requirements that came out.of 13 the system functional evaluation.

There were about 103 items l

14 that came out of there, but I want you to bear in mind that.

i

.- 15 this is only a part of the overall test program._;We've 7..

16 developed a very comprehensive test program that goes,well

~ :

17 beyond our current Technical Specifications.

_18 (Slide.)

The objective of our test program of course is to 19.

20 assure proper operation of safety and other important systems 21 in normal operating and also in post-accident modes.

We will 22 do this by verifying the open issues that were developed out l

- 23.

of the system functional evaluations and we'll complete the l

.... 24.

Technical Specification surveillance test -- this involves l

.... 25

.our checklist and our normal surveillances that wa.do both on..

66 1

a monthly and a quarterly basis.

We'll complete an augmented 2

surveillance test on the secondary side of our plant.

3 One of the lessons that we have learned is the fact 2

4 that you have to pay attention to the secondary side of the

~

~

5 plant and we will do some extensive post-maintenance testing-

~

6 on our turbine bypass valve, our atmospheric valves; we'll do 1

7 some performance testing on things like our feedwater pumps, i

8 auxiliary feedwater pumps also, so we've learned our lesson-

~

9 from that perspective.

~

i 10 We will complete the post-maintenance testing.

-We-

~

- ha' ~e 208 items right now that have been completed and we will-- ~

~; '

~

11 v

~

do that during our test program.

We will perform integrated ~

12 13 systems testing for selected systems.

'~

14 (Slide.]

~

~ 'i~

57M'r 15 ~

The scope of our overall program will-involv67 cold Tiri 2 j rIT ~ ~ ~ ~ 16

- hutdown testing, hot shutdown testing, and also power "Er 2 50' s

~

17 escalation.

On the power escalation part of it I'want'y6u to~~ ~+

r 18 know that we're just not going to bring out plant right up-to

?F ^

~ ~ 19 100 percent power.

We have five levels that we're going't6"

l

~" 20

~ stop at; we're going to stop at 30 percent, 45,~60, 80'and 100-

~ 21 percant power levels. And what we'll do is we'11' assure- -

22'

'ourselves that all the systems work properly during this' power l

~ 23 level before we'll go to the next level.

~~

~

~

24-

~

For instance, we will take the main feed" pumps and'

~

-- 25 we'll have our system engineer people out ther'e'and also our' f

~

67 1

-operations people, and they will be gathering data and they 2

will be trending some of the trends on major pieces of 3

equipment.

4 So far in terms of status, we've done a substantial L__

5 amount of cold and hot shutdown testing.

Fred already told

.6 you the success of testing out 270 work orders and only.5 7

required rework.

From a plant manager's perspect_ive I feel _

good about that because that tells me that we solved one of 8

9 the problems that we had and that was the high rework that we 10 had at our plant, so it tells me the maintenance program is

_11 starting to work.

The program should address the system functional

.12 13 evaluation open items to be completed about mid-January.

We 14 are currently writing procedures.

We hired six combustio.n

,15, Engineering test engineers to help us write those test y

16.

procedures to address the system functi.onal ev_aluation-n

,, n

,, 17.. _. additional tests.

I

. 18.

The post-maintenance testing for approximately 200

,19 work orders remain open and they will be teste_d during cold 20 shutdown and also hot shutdown testing.

21 We have an integrated system test plan under development for six systems; they involve chemical volume

. 22.

23 control system, component cooling water system, main steam

_. 2 4.

supply, service water system, main feedwater and condensate..

, system and also the auxiliary feedwater. system.

... : _,-, g _7 25

68 1

The reason why we selected these systems if first of

-2 all mainly because of the quantity of work that had been done 3

on these systems in terms of maintenance.

The chemical volume 4

and control system, for instance, we did 157 work orders; we 5

essentially rebuilt that system totally.

And what we'll do 6

now when we bring it up in terms of an integrated test, we'll

, 7 walk down the system and check for any leaks, we'll-do a 8

dilution test, boration test, we'll check the pressure 9

regulators, we'll check the charging pumps and make sure that 10 the variable speed charging pump can pump between 33 to 53 11 gallons per minute.

That's an extensive test that we're going 12 to do during our integrated tests.

13 (Slide.)

14 Pictorially, what I've tried to point out to you

~..

.., 15 -

here is that the test program is in blue.

Normally;what we t.

.., 16 did before in the past is in green there, the-surveillance l

17 tests, and also the post-maintenance test.

And on this i

[.

. 18 startup here we'll do everything in yellow; that's above.andy j

beyond what's required by the Technical Specifications, But.

19 20 that doesn't mean it stops there.

This is also going to be 21 incorporated in our test program for future startups as well, 22 so it's not something we're just doing for this particular 23 program but something we're going to do from this point on.

I 24 -

(Slide.)

25 Let me skip quickly over configuration management..

69 1

Our objective is -- we run into the same problems that other 2

plants do; we need to reconstruct a well-documented design

[

3 basis, we need to verify that what is out there in the plant 4

actually does reflect our design basis.

We need to improve i

5 our administration controls and we're going to ensure adequacy 6

of design basis through SSFI type reviews.

We'll go through l

7-at least another 12 or 15 systems on our own to do this.-

c' 8

So far in terms of status, the scope is still under 9

development and will include the update of the FSAR, update of ~

10 our drawings and procedures, our test program that I talked ~

11 about there will be incorporated into our plan, our spare J

r-12 parts program will enhance that and we're goin~g t'o take ~o'f f: on

! =

I

~

l 13 some of the things that other plants like Davis-Besse have 14 done in terms of spare parts.

Le

r ;15

-r-(Slide.)

5+7-1515 ti

  • OEI' f

$-16=---

In terms of status, the project manager has been

- tai assigned.

He's sitting in the room behind us, Dick Gerhart is: - -

L

' ~ '18 his name.

He's in the process right now of assembling his i

- team.

So far, the scope, process and schedule to be developed 7 P'

20- ~

by March 31st.

To date they have visited Turkey Point,~

~

-21 Connecticut Yankee, Davis-Besse, INPO,-Westinghouse and

~ ' ~

22 ~

Combustion Engineering to get a flavor-of what these other : c 23 companies are going through so that we can learn from the'm.so 24 that we have a very comprehensive program.

25 We've planned a phased approach to address these ~

-_.___________.,_....m__-__.....

70 1

important systems and I can assure you that on a priority 2

basis the service water and component cooling water systems 3

will be involved at the top of that list.

4 Based on our estimate right now, we figure the 5

program is going to take anywhere from two to three years, and 6

that's sort of the feedback that we're getting from the

~

"I 7

industry as well.

~

8 (Slide.)

9 Now I'd like to shift to our restart schedule.

I 10 want you to know that we are not driven by a schedule at-this 11 point; we want to satisfy ourselves that this plant is safe.to 12 bring up and operate and that we have solved the' problems-and.

13 that we have reliable equipment out there.

~

~

14 Currently we're talking about plant heatup to hot 15 shutdown either in late January or the first part of

~ f ::-

16 February.

Heatup and hot shutdown testing will take

- t - ru ::

17 approximately two and a half weeks.

There's nothing magical ~

~

l 18 about that two and a half weeks; we'll satisfy ourselves that 19 the plant is safe.

We will not put the plant online until'we~~

2

~

20 are satisfied that we had a comprehensive review and the test 21 results from our test program are very adequate.

22 From that point on we go to power escalation-testing 23 which I described to you earlier, and than we'll reach tho' 24 100 percent power level.

~ ~ ~

i 25 With that, I'll turn the program back to Fred

~

i 1

-.,,.----..-,,,-,,.---,,..e,.

-,,c_.,,

..--,...-y---+-.---.....-,..ym

_y

,_m,<,..,_m,._,___

.-m_.,--.

71 1

Buckman.

2 MR. BUCKMAN:

I just have a couple of slides at the 3

tail and of this.

I know we've talked about a lot of things, 4

we've presented a lot of things in a very short time, and in 5

some of the conversations I've had with the region.I know-it's 6

been tough to keep track -- what is it you've done and.what is 7

it you're going to do.

And so I have here a short status i

8 review in which I've tried to separate out those actions which 9

we've completed, those actions which are underway and will be 10 completed prior to startup, and those actions which are 11 follow-up actions which we view as having a term which is 12 longer than that period between now and plant..startup.

13 In terms of things we've completed, we'.ve completed 14 our repair of the May 19th equipment problemst we've completed 15 our Material Condition Review and upgrade program; we've 16 completed the evaluation part of the System Functional tr:

17 Evaluation, we have not yet completed the testing..

)

i 18 We've completed our pump testing program-except for 19 a couple of minor things; we're going to ratest the service 1

20 water pumps as part of the startup testing after we've 4

21 backfiled the impellers.

And there's a small part of the high -

22 pressure safety injection pump testing.that we were unable to. -

2 23 do simply because we couldn't get the plant in the right 24 configuration until we get it hot.

We're going to do that in.

25 the hot testing.

j i

--.,--,--_.<-.__n--,-.

.,_______,,,,.,m__

,,--,._n

S 1

72 1

We've increased our maintenance work force, we've 2

streamlined the operations and Maintenance Departments.

Those 3

things are behind us.

4 (slide.)

I 5'

We also have some things which are underway but

~~6' which we expect to complete prior to startup. 'We have some "7:~

mechanical work that we're doing to address S8FI findings and a

providing backup air to some important valves.

The service 9

water pump backfiling will be complete prior to startup.

We 10 have an isolation act that we're taking on component cooling 4

- 11::

-water control to deal with the issue on recirc actuation.

i l

12 We've undertaken a piping erosion inspection as a 4

i j

13 result of the incident at Surry.

This is listed here as 14' -

underway to be completed; we actually have completed that.

I

~~1r15-think we completed it yesterday or the day before.- We did not i

h' ' ~ ~ ~ ~ 16' -

find any significant indications in what we ha'd don'e.

Part' of ::

I

~ 17 that work, it turns out, had been done during a refueling

~

l l

~

18 outage that took place about this time last year, but we l

I 19 -

completed the rest of the work.

Most of what had been done'~

20 was in the steam side and we did a lot of feedwater 21 inspection.

22 COMMISSIONER BERNTHAL:

Did you have any similar l

23 situations, similar pipe or material, similar flows, pressures l

24

~ and I guess 90 degree angle in the case of Surry?

25 MR. BUCKMAN:

I don't know the answer to that.

I do t

i 73 know the configuration that they had and I'm not aware of any 1

2 configurations we have like that where we've got the T and

{

3 then the elbow right after it and the very turbulent flow.

4 4

I have not reviewed our system to see whether we do have.that

(

5 or not.

i 6

But we did do an ultrasonic test of I think about 30 1

i 7-locations that were high risk locations and did.not find any 4

2 8

significant indications.

Then we have the testing to do.

9 In terms of follow-up actions, things which.have a 10 longer-term view to them, the Configuration Management Program 11

,,that Joe and I both mentioned is one that will be. underway..

12 We expect to have scope and schedule by the end of March..The i

1 13 Comprehensive Valve Maintenance Program, we've developed our...

14-scope and selected a contractor but that's -- implementation 7

- 3, 15

.wi_11 probably go through at least the first hal,f of 1987;.,...

3.,.

INPO accreditation.

Implementation of;our 16 g.. 3;.,.,

g..

, 17 Preventive Maintenance Program.

We've effectively gotten l

. 18 there on instrument control and we're almost there.on.the._,

1 19

-. electrical side; we still have a lot of work to.do in the.

20 mechanical part of preventive maintenance and we expect to.,,

r 21 have that fully implemented by the middle of this year, 22 6/30/87.

t j

23 And then of course we mentioned some continuing i

l 24 hardware improvements and I expect that to be an ongoing.

3.,

1 l

l. c::.

25 -

thing.

,n.,

i i

I

-en

- -,.,., ~ ~,,~ - - r,m

.-,n

--.-,,,.----w-.-,.--.-

w

74 1

(slide.)

2 In summary, I'd like to say that we've undertaken 3

what I think is a comprehensive review of plant materia?.

condition, and we've completed an awful lot of corrective i

5 action.

I still think we have some things to do but we've 26 come a long way.

i -

7 If we take a look at some of the indicators' that-I L.T 5

~

a presented to you earlier, I think it shows evidence.that the :

i 9

material condition of the plant has improved.

I think.it's' i

j-10 better than at any time at least in the last five years of-its" l

11 operation, and I think that at least by these indicators:it is?'

12

- above the average in Region III.

It's continuing to~ improve *

'r

13 and I think we're committed to continue that improvement.

14 We've completed a comprehensive review of plant-lrf 15

- systems for their functional capability, which I think!has ::

{ ~-

16 given us a good assurance that in spite of some of the design:rs;'~

- 17

"' deficiencies we've identified that we have a plant which is'ii 3

l' le '

safe to operate and it will operate reliably.

We've'got:a' hew:

19 -

management which is dedicated to continuing this type oft ti

-1 l

20 improvement that we've talked about today, and we have a

21 company which is recovering financially.

We've got I~think a i

22 very improved morale situation and we've taken care' of our

~~ ~

j 23 '

turnover problem.

~ 24

That completes our presentation.

1" l

i 25 CHAIRMAN ZECH:

All right, thank you 'very much.

k

75 1

Questions from my fellow Commissioners?

2 CONNISSIONER ASSELSTINE:

Just one or two quick 3

ones.

On the design issues that you found, both in terne of

.4 conformance to design, configuration management and control 5

and also adequacy of the existing design, do you think for 6

plants of your vintage that you stand out as exceptional in

-7 having those kinds of problems, or would you expect to.see a

those kinds of things at other plants of similar vintage?

And 9

if so, would you recommend that other utilities with that age

-10 plant take a look at those kinds of things as well?

Do those 11.

kinds of reviews?

- MR. BUCKMAN One of the things we've decided to do 13 as part of our Configuration Management Program is continue 14 the SSFI or operational readiness type of review into other

.15-systems, and in fact right now we're trying to prioritise - _

r.- - - 16 which systems make the most sense.

..a

..;17 I think that there are enough unique features of 18-

- what were found that it's hard to draw a conclusion based on 19-what we found that we would find the same things elsewhere.

l 20 It wouldn't surprise me if we were to find the same things 21 elsewhere, but in some cases what we found were situations

-22 that were kind of marginal; probably okay in 1970 but when you 23 look at it today it's on the other side of being okay, and the 24 question is why not fix it, why not make it okay.

e

+25-I think that if one puts himself in the situation...

w e'wwm

o 76 1

that existed in the 1968, 1969, 1970 timeframe when oil was 2

less than $3 a barrel and the competition for building these 3

plants was really capital cost and not reliability, that the 4

situation we have is one in which I think our primary system 5

has-a great deal of margin. It was the first Combustion plantt 6

Combustion did not want to fall on their face.

It's 7

effectively the same size, same capacities and everything else 8

as the 1100 megawatt plants.

9 The rest of the plant is more like what we've talked 10 about in the service water system where it got caught I think 11 in some changing standards and there were a lot of efforts 12 made to make the plant a relatively inexpensive plant. -We-13 don't have the testing capability, the diagnostic capability 14 or things like that.

And in order to get to the level of-15.

performance that we'd like to achieve we reallyistill have.a.

16 fair amount of work to do in that part of the plant.

3:.

17 But I think from what we found-it's hard to draw an 18 industrywide conclusion.

It would not. surprise:me,3though,-~to.

19 find it elsewhere.

20 COMMISSIONER ASSELSTINE:

I think that last comment 21 is right on the mark.

Your plant is not the only one to fall 22 into that situation, but your earlier comment as well that you -

23 wanted, in some instances, to look beyond the FSAR, look 24 beyond the design basis and see what needs tocberdone to fix 25

.the plant up to where it really will operate reliably and with -

_ _ - _ _ - _ _ =

77 j

1 few safety problems I think is exactly the right approach.

I

-2 commend you for taking that approach and I think you're

+

3 exactly right.

In some instances the time period and the coat 4

constraints that dictated some of the designs, particularly on I

5 the balance-of-plant is where a lot of the problem is.

6 MR. BUCKMAN That's correct.

7 COMMISSIONER ASSELSTINEt And you'reinot. going to.

i e

fix that until you take a hard look at those systems and say l

9 what is it we need to have a system that we can maintain well 10 and that will function and operate reliably.

1 11 i I guess the last point is just.a comment.

.I-12 appreciate the presentation.

I know we sort of condensed the 13 time on you and you've covered a lot of territory but it gives i

14 me a lot better sense for what you're doing in some of the 15.

objective measures of the performance and workiyoufve.beenu. -

l

)

. 16 able to do.

I appreciate it, it's a good presentation..

17 MR. BUCKMAN Thank you.

la MR. MC CORMICK Thank you.

.. -.. n-I 19 CHAIRMAN 2ECH:

Commissioner Bernthal?

1:

i j

20 COMMISSIONER BERNTHALt I agree.

I believe the word * :

I 21 was crisp, and that was a good crisp, comprehensive i

22 presentation and we all appreciate that.

I 23 Just one question.

I understand that you did spend

]

24 -

some years at Palisades at some previous point'in'your career

[

l

-l 25.

and left and have now come back.

I don't know what.your job 4

I< -

78 1

was earlier on.

You've answered this in part I believe but 2

would you have anything to add to the question of how did 3

Palisades get to where -- I don't want to say is today, but 4

was maybe a year ago?

Have any thoughts on that?

5 MR. BUCKMAN:

Yes, I do have some thoughts.

6 Actually, I was never at the plant but I was with Consumers 7

Power Company and I was in the nuclear operation for a period 8

up to about the middle of 1983.

And I think that when we look 9

back at this ten years from now what we will see is a 10 perturbation in what is a long uphill climb in terms of 11 performance that took place from about the middle or and of 12

'83 until the and of

'84, early '85, that was caused by a 13 number of problems which were outside the control of the plant 14 management in terms of morale and turnover and things,like 15

.diat.

n 16-But I also think that there were -- I happened to be.-

17 one of the people that was pretty closely associated with the-18 performance improvement program that took place in 1981 and 19 1982, and I think that if I were to design that program again 20 today there are a couple of things I would add to it that were 21 not part of that program.

One is that I think I would be more 22 insistent on developing objective measures of what performance 23 was and how you measured it, and I would insist that those 24-measurements take place and that people who are interested in 25 the performance looked at those measures and made sure.

I

79 1

I really think that part of what happened is we did 2

a pretty good job of measuring our performance improvement up 3

until about the and of 1982, and then the measurement 4

stopped.

And when the measurement stopped it was pretty hard 5

to catch small trends that took place that started turning 6

performance over, and it got pretty low before it was 7

recognized widely enough that action could be taken.

8 COMMISSIONER BERNTHAL:

That's all I have, thank you 9

very much.

10 CHAIRMAN ZECH:

Commissioner Carr?

11 COMMISSIONER CARRt I've got a couple of comments..

12 One, I also compliment you on your brief and would like to

- ~

13 tell you if you had given me that brief when I was out there 14 after Thanksgiving I would have left there with fewer concerns.

15 about how you were doing things.

And I an encouraged in that 16 I can, since that time, sense an attitude change in some of' x.i; 17 the ways you're approaching things, like you're going to fix

~

18 instead of what's essential to plant operation you've changed-19 the words to what relates to proper system operation, and I-20 think that's indicative of a good approach.

21 I think your point is well taken that one of the 22 indicators that we need to take a look at in pro'lem plants is 23 turnover of personnel.

If it's not a problem at the time, 24 it's indicative of a futura problem.

l 25 MR. MC CORMICK A leading indicator.

I

,_._-__.___.,,_.--.,_7._,._______y~.___

_,-..,__._,_m_.

40 1

CONNISSIONER CARR On page 15 you had a thing that 2

said " development of contingency plans," and you've said there 3

were three of those and that leaves me kind of blah.

I don't 4

know what a contingency plan was or what it was for.

5 NR. BUCENAN:

I don't remember what those are.either 4

but I think they have to do with things like recognising that

- 7 we have a component in service for which we can no longer-8 purchase spares.

And so we need to be thinking about what do 9

we want to do for a longer term.

If we've got a pump for 10 which we can no longer buy a motor, do we want to change that 11

pump simply so we can have spares in stock, and things of that 12 nature.

That's my recollection.

~

13 CONNISSIONER CARRt Okay.

And looking over some of 14

  • the paper you sent to us I notice that in the'past practice

<rriu15' you've had less than 5 percent preventive maintenance.

Do you~

is '

have some goal for that in the future?.

e.-

~

17-NR. BUCRMAN:

Our goal by the end of 1988 is to be 18

- 50/50, and that's part of what drives the corrective t

- '19 ^

maintenance down.

The feeling is that;in order fortus to get l

20 to 50/50 in preventive / corrective we need a goallof about 200 l

21 to 250 in the corrective maintenance pile.

Our objective for 22 -

1987 is to get down to 3001 our objective for-1988 is to get 1

23 down to 200.

I j

24 We have done quite a bit of surveying ~of people who i!-

25 are doing a better job of preventive maintenance than we are

~

. -. -. ~

81 1

and find that there are a few who have gotten above 50/50 and 2

some of those who have are now on the way back down.

50/50 3

seems to be a sensure that's receiving a fair amount of 4

industry acceptance.

5 COMMISSIONER CARRt Well, that's the first time I'd

_6 heard your number, and I noticed the other day that Oyster

7 Creek was going with 80 percent preventive maintenance and 20 I

s percent corrective.

That's great if they can hack it.

9 MR. BUCKMAN:

That's an individual choice, but I 10 think if we can achieve 50/50 I think that will be a major 11.

improvement.

12 COMMISSIONER CARRt I notice you had -- also in some 13 of the other paper -- a control deficiency goal of 30 and yet 14 you're down to 7; why don't you just set that at zero?

MR. FIRLIT The reason why our goal is 30 -

that's -- -

16 a corporate goal that we have for our own self.- What-happens,-

17 when you start your plant up your control and efficiencies are 18 going to come up.

Our goal is to have it down to zero.

19 COMMISSIONER CARRt Okay, I'll subscribe to that.

20 MR. FIRLIT But what we're saying is in fact this 21 year we've tightened it tighter than 30; we've tightened it 22 down to 20.

We said that during startup we'll have no greater 23 than 20, but that doesn't mean that when we hit 20 we're not 24-going to work those offs we're going to aggressively attack

_ 25-them.

_. _ _ _. _ _ - - ~

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

82 1

MR. BUCMMAN Of the 7 that were identified here, 2

there are 5 that we are not going to fix during this outage.

3 They all relate to temperature indication on primary coolant 4

pump motors, and for each of those we do have a backup.

It is 5

carried as a control room deficiency because it's a primary 6

indication, but until we tear down the primary coolant pumps

.7 and rebuild the motors, we won't be able to fix that problem a

with the temperature indication.

9 COMMISSIONER CARRt And one other question.

On 10 operator training on the changes and modifications and so 11 forth, I noticed you don't have that in either "already

. 12 completed" or "to be completed".

Where does that stand?

13 MR. BUCKMAN That's a continuing effort that's --

14 COMMISSIONER CARRt I'm talking specifically about

, 15

.. what needed to be done as a result of the things you've done-..--

16., - -,in this outage.

17 MR. BUCKMAN I don't believe that that training is -

18 complete but it will be complete prior to startup.

19 COMMISSIONER CARRt Okay.

And I guess one other -

20 comment.

I would like to remind you that you can wear one of 21 these plants out if you run them hard and you don't have a 22 good preventive and corrective maintenance program, and you've 23 got to combine that with a good configuration control 24

- program.

And it looked to me like, reading your performance, 25 when you were running you were running hard and performing

83 1

well, but when you don't stop and, as the man says on 2

television, pay me now or pay me later.

3 MR. BUCKMAN One of the decisions that we've made 4

for 1987 is that we are going to take a maintenance outages 5

not a refueling outage but simply an outage to continue making 6

the kinds of changes and improvements that we've started now, 7

recognizing that it will give us a chance to do some 8

preventive maintenance, it will give us a chance to do some 9

things that we would like to do now but which take a fair 10 amount of procurement and engineering to do.

And to the best 11 of my knowledge it's the first time that we've ever scheduled 12 a maintenance outage for Palisades.

13 MR. MC CORMICK:

Commissioner Carr, I want to add 14 one thing on the training.

We are in the process right now of C

.15 -

-- we had made some modifications in our emergency operating '

16 procedures and we are in the process of training our - "-* '

17

. sending our operator shifts back through that training progra~m'

'/ -18 prior to startup.

19 CHAIRMAN ZECH:

Let me just say I thank you al'so for.

  • 20 a very fine and crisp presentation.

I also believe that it 21 certainly sounds like you're on the right track and your 22 management involvement and your Executive Management Review 23 Committee seems to certainly be the right way to do.

"24 I also agree that your focus on improved maintenance 25 and your focus on design-related issues is certainly

e4 1

appropriate.

I hope you have priorities factored into that --

2 we didn't talk about that too much but I assume you do, and if 3

you don't I suggest you look at that real carefully.

4 What I think, -- as far as I'm concerned it looks

  • s also to me like your schedule is rather ambitious and perhaps 6

a bit optimistic.

It seems to me you still have quite a bit 7

to do.

I certainly would hope that you would-go e

conservatively and make sure that you get as much results as 9

you can possibly measure from the efforts that you've put 10 forward on these programs.

11 And I would ask Region III specifically as well as i

1 12 our headquarters staff to look very carefully-at Palisades 13 between now and the time you do start up.

I know -- I think I 14 speak for all my fellow commissioners when we need to see the P.-

C.15 confidence that some of these programs.that you've put into :

n

- 16

- effect are showing results and the plant can be operated.n tr-

- - 17 safely.

Those are the kind of things that I think we'll want is to see before you start up, so I think it behooves Region.III 19 perhaps to make an extra effort, and our staff here perhaps to :'

20 join with them, to make sure we do have the confidence that 21 there are regults coming from the programs that you've talked 22 about.

23 so that's the kind of thing that I would hope to see 24 and I think my fellow Commissioners have similar views!in that n...25 regard.

i..

i SS l

1 Are there any other final comments by anybody?

4 2

COISIISSIONER ASSEIATINE:

Just one, Lando.

My 3

understanding was that today was really just a status briefing l

4 on where things stand at the acaent.

f j

5 CRAIRMAN SECH:

Yes.

e COMMISSIONER ASSELSTINE:

So that I assume that 7

prior to the staff reaching a conclusion that the plant was r

i l

8 ready to restart that we'd hear again from the staff, at least 9

on what has been completed and the condition that justifies l

l i

10 their conclusion that the plant should be in operation.

11 CHAIRMAN SECH:

Yes, I think we do need to i

12 definitely hear from the staff with a final recommendation on I

13 -

startup, and certainly I would ask the staff to take that on 7

1

' 14 as a responsibility and action item for us.

j f

15 CONNISSIONER ASSELSTINE:

So we.can probably-keep in r: +

i r-14~. "

mind a time for another meeting.

.f.

f l

i 17 CHAIRMAN SECN Yes.

Ne need to hear from the: staff,-

i

, 18 and perhaps decide on whether another meeting like tJtis is i

I i

i j

19 necessary or not.

But be certainly need to hear from the-I j

S staff with a recossendation in that regard.

21 Nith that, we are adjourned.

f l

22 (Whereupon, at 11:57 a.m., the consission meeting i

e 23 was adjourned.)

24 1

t e

I 25 I

i l

I

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 MEETINGt Driefing on Status of Palisades (Public Meeting) 8 PLACE OF MEETINGt Washington, D.C.

9 DATE OF MEETINGt Wednosday, January 14, 1987 10 11 were held as herein appears, and that this is the original :'

1 12 transcript thereof for the file of the Commission.taken 7

(

13 stenographically by me, thereafter reduced to typewriting by 14 as or under the direction of the court reporting company, and

... n.15.

that the transcript is a true and accurate record of the;l' II' 16 foregoing events.

' e;t 17

  • ~

1_a tyr.L..

Je Suzadno D You 3,

20 21

.22 Ann Riley & Associates, Ltd.

23 24 25 6

NRC ACTIVITIES PALISADES OUTAGE Pro 1981 On-going Regulatory Concerns 1981 Confirmatory Order to Upgrade Facility Performance 1962-1963 Improved Performance 1984-1985 Concerns with Plant Condition and Maintenance

-Special Team Inspection

-Confirmatory Action IAtter Early 1966 Numerous Equipment Problems Surfaced l

May 1986 Concern with Status of Equipment l

-Augmented Inspection Team

-Confirmatory Action 14tter i

Summer / Fall 1966 Design Related Probleme Identified by Licensee i

November 1986 Safety System Function Inspection Found Additional Concerns i

Request for Information Under 50.54(f)

December 1986 Westlags and Followup Request i

l

INSPECTION PROGRAM FOR RESTART L

Plant Readiness [ ongoing) o Material Condition o

Maintenance o

SSFI Findings o

Safety System Evaluation o

Testing IL Operational Readiness (future)

i

._:=.

o Operations o

Maintenance l

o Surrelliance o

Trainins I

o Health Physics t

2 PRESENTATION TO THE NUCLEAR l

REGULATORY COMMISSION ON THE i

PLANNED RESTART OF THE l

L PALISADES PLANT BY

~n CONSUMERS POWER COMPANY JANUARY 14,1987 y.

CONSUMERS POWER PARTICIPANTS IN PRESENTATION Dr William McCormick, Jr, Chairman and CEO Dr Frederick Buckman, Vice President, Nuclear Operations Mr Joseph Firlit, Plant General Manager

~

OTHER COMPANY EXECUTIVES IN ATTENDANCE l

Mr Jack Reynolds, Executive Vice President, Energy Supply Mr Gerald Slade, Executive Director, Quality Assurance Mr Robert Rice, Plant Operations Manager Mr Richard Orosz, Engineering and Maintenance Manager Mr David Joos, Planning and Administrative Manager l

---,,-,-e

---.,,,,,,,,-n.__----,.,r w,

O 8

3 l

OUTLINE OF PRESENTATION 1

~

~

e introduction, Recent History and Overview

- McCormick e

Palisades Plant issues and Resolutions.

- Buckman e

Testing and Restart Program 3.

- Firlit i

i;.

e Summary

- Buckman

~~

4 INTRODUCTION AND RECENT HISTORY _

e Palisades Plant performance has been uneven throughout its history.

While plant performance in 1983 was improving, e

severe financial difficulties of Consumers Power, beginning in 1984 with Midland Plant shutdown,2 ~

~

i resulted in certain problems.

- Deteriorating maintenance

- High personnel turnover

~ =:

~

~ 5:"

New plant top management installed at end of e

l 1984 began new cycle of improvement.

90% capacity factor during 1985 operation e

New Consumers Power CEO elea.ed in November of 1985 and new Vice President, Nuclear Operations in February 1986

5 INTRODUCTION AND RECENT HISTORY (Contd) e in 1985 new management initiated programs to:

Improve safety Improve reliability i

Restore material condition l

Improve training

~*~

~

~

Reduce turnover

~

~

'~

Improve management

~~i e

The plant tripped on May 19,1986 with some equipment problems during shutdown.. This emphasized need for an accelerated effort to address overall plant material condition as well as specific trip-related problems.

During outage several design-related issues emerged

6 MAJOR PLANT ACCOMPLISHMENTS e

Resolved and tested trip-related problems e

Maintenance work orders reduced from 4000 in 1984, to 2350 in 1985, to 1077 in 1986 Eight-week inventory e

Control Room deficiencies reduced from 161 in

~

1984, to 65 in 1985, to 7 at present e

Resolved all design-related issues

~'

~~

~

Streamlined plant management while increasinc].

e maintenance personnel P

7 OTHER ACCOMPLISHMENTS e

Reduced radwaste production from 18 000 cubic feet in 1984, to 12,000 cubic feet in 1985, to less than 7,000 cubic feet in 1986

=:

INPO training / accreditation of 5 programs in e

December 1985, others awaiting INPO action Employee turnover reduced from 17%. annually o

in 1984 to 3% in 1986 Established Fitness for Duty Program infli86

_!-. [: -

e with unnanounced, random drug / alcoh'ol

~

~~

~~

testing, with each employee being tested at i

least twice a year

.;3

. g...

Achieved the best safety record; the safest..

~ ~

cornbined gas / electric utility inythe United.

States

8

e. e mo,.

~

PALISADES PLANT ISSU55

~

~

e MAY 19 TRIP PROBLEMS

+

=

e MATERIAL CONDITION

_2 3

u.

e DESIGN-RELATED ISSUES

._ _.. ~.

...?.

=

==.

1' l

. g a

n.,.-.

9 PLANT MATERIAL CONDITION e

Plant material condition had deteriorated because of:

- Employee turnover and poor morale Quantity and quality of maintenance performed Organizational and programmatic weaknesses e

Consumers Power Company recognized need and '

~

i initiated efforts to improve material condition in 1984 to:

u..

Assure plant and equipment reliability Minimize operator work-arounds and distractions Reduce work order inventory to a desirable level g

, - - - -w---

10 ACTIONS INITIATED PRIOR TO MAY 19 EVENT e

Nuclear Operations Department Reorganization e

Maintenance Order Task Force e

Maintenance Inventory Reduction

-n e

Systems Engineer Program e

Systems Assessment Program Advanced Maintenance Management System e

Operational Readiness Assessment

- i e

Preventive Maintenance Program e

Competitive Salary Program

11 ACTIONS DURING CURRENT OUTAGE o

Material Condition Task Force e improved Maintenance Program e improved Material Condition

=-

e Extensive Testing Program l

. =.

. =

e System Functional Evaluation 6

es tiiB

-.,_._y-,o_,.--_-.w.__

.____.__.,_..y-,

12 MATERIAL CONDITION IMPROVEMENT PROCESS i

CONTROL CORRECTIVE OPEN ROOM ACTION WORK DEFICIENCIES SYSTEM p

p ORDERS 1

WORK SYSTEM ENGR.

ORDER INTERVIEWS HISTORY 9

[

MATERIAL OPERATOR CONDITION INTERVIEWS PLANT TASK FORCE TRIP OPERA [OR HISTORY CONCERN LIST OPERATIONAL READINESS MAY 19 TRIP ASSESSMENT PROBLEMS i. " ': ~ ;

i If MATERIAL CONDITION CONCERNS 1f EXECUTIVE MGMT/

PLANT REVIEW COMMITTEE REVIEW f

13 CRITERIA FOR ACTION ITEM TIMING _

e Prior To Start-Up

[

bib 3 Repair all deficiencies which relate to proper

(

system operation Perform comprehensive testing program y-Initiate accelerated inspections and preventive maintenance to enhance reliability 3:_ _

=

~ ~ '

~

l Prior To End of Next Refueling Outage e

l Perform modifications or maintenance to enhance long-term reliability i

e include in Five-Year Plan Reliability or maintainability enhancements-which require additional evaluation for i

effectiveness and cost justification

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

-e-y

---m--.g.

+,--,,---w--m_--

14 RESULTS OF MATERIAL CONDITION REVI5W ~

~

i i

~

e 222 issues identified

~

i o

14 issues Required No Action g.

g.... __

l e

159 Issues Resolved Prior To Start-Up 49 Issues To Be Addressed After Start!UP ~

~'

l 39 issues will be addressed before the end i

of the 1988 REFOUT 2~:

~ : I;;

10 issues will be incorporated into til

~: '" 2 Five-Year Plan i~~

~:

'-Ti

.7

~.

I

-,-.r-----

.,,------_m.

o 15 l

lSSUES TO BE ADDRESSED 4

AFTER START-UP l

1 2

Modifications to improve ability to maintain or t

inspect 15 Modifications / equipment upgrades to decrease maintenance requ,rements i

l 3

Development of contingency plans 3

Equipment re slacements to improve spare _.

l parts availabiity

=-

)

~

i 2

Development or acceleration of PM activities 2

Maintenance / modification to reduce sup' port:

2.

i time / effort required of operators, security ;

5:: :I l

personnel, etc 12 Modifications / upgrades to improve long-term.I reliability l

6 Evaluations of equipment performance to define possible reliability improvements i

t 4

Equipment operability improvements 49 Total

.j i

l

16 IMPROVED MAINTENANCE PROGRAM ACTIONS COMPLETED l

e Operations Reorganization To Enhance Maintenance Diagnosis and Prioritization E

e Enhanced Post Maintenance Testing

~

~

e Increased Mechanical Maintenance Work Force From 38 to 57 Streamlined Maintenance Organization (([_

e e

increased Use of Contractors To Supplement Plant Expertise e

Instituted Plant Training Staff of 4 People for Electrical and Mechanical Repairmen

17 i

IMPROVED MAINTENANCE PROGRAM (Contd)

(

ACTIONS IN PROGRESS Accelerated Preventive Maintenance Program e

implementation Accelerated Implementation of Equipment

~

~

e l

Monitoring and Performance Trending

!l e

Comprehensive Valve Maintenance Program-INPO Accreditation in Electrical and Mechanical Training Programs e

System Engineer Training Program

~

i l

I ll

-r,,-.


n,,,-,-w--____,

18 IMPROVED MAINTENANCE PROGRAM (Contd)

RESULTS I

e Excellent Heatup in November

- Low Primary Coolant System Leak Rate

~

~

(Less Than 0.1 gpm) i i

- Few Rework Requirements - 270 Work Orders:-

~

Tested, 5 Required Rework t.

I e

improved Operator Confidence

- System Function

~:

i

- Maintenance Process

~E: TI :: r -

1 e

Expected Payoff 8;

l

- Plant Availability

- System Reliability

- Safety System Challenges 1

'i

19 PALISADES OPEN WORK ORDERS 4,250 4000*

4,000 3,750 3,500

'~'

g 3,250 wQ g

3,000 x

2,750 1

y z

2,500 g

2354 o

~

2,000 mo 5

1,750

_;_~

~.

m2 1,500 1 - E 1,250 1, qgj. ;

1,000 750 500 250 0

1984 1985 1986

  • ESTIMATED l

l

20 OPEN WORK ORDERS Total open work orders 1077

~

~ ~ ~

Post maintenance testing 208 Completed 53 Total active work orders 816 Preventive maintenance 75 Inspections 7

Adjustments / calibrations 59 Spare equipment 12 Subtotal-corrective work orders 663 Corrective work orders Valves / valve operators

?

~24t Gauges / indicators / switches 140 Heaters / ventilators 69 Pumps 65 Compressors / heat exchangers

~

~

36 Motors 34 Equipment / facilities 33 Miscellaneous 26 Tanks 18

.L-m~-

8 9

21 CONTROL ROOM DEFICIENCIES 170 161 160 150 140 130 g

120 E

-vz 100 EM

~~~

~

5 90- - --

g m.

O go ce Lu 70 65 i--

2 I ~ ~-

1 60 3

~

~

50 l

40 30 20 7

10 0

1984 1985 1986

i 1

i JUMPER LINK AND BYPASS STATUS i

80 i

1 72 l

1 70

)

70 63 E

l i

60 57 1

a

_55 m

as i

a 50 j

50 z

46 i

=.

_3 4

i n

O 40 i

u.

1 o

33 ac E

30 2

3 23 24 z

20 l

l 8

i i

10 4

j l

l 0

l' JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC t

l 1986 MONTHLY VALUES i

i l

u M

[

l

23 DESIGN-RELATED ISSUES epe g..

CONFORMANCE TO DESIGN

- ~ ~ '~~~~

e Low-Pressure Safety injection Pump - Low Flow Component Cooling Water Systenk - Undersized

- - -- - o -

Heat Exchangers

.....___.___e

- Service Water System - Low Flow l__

ADEQUACY OF DESIGN

{_7 3 Half-Capacity Service Water Pumps e-

~

e RAS Logic Failure on Loss of DC i.

[.

l e

SSFI identified items L-Recirculation Actuation System Lock-In

~

' ~ ~ ~ ~

Positive Control of Valves With Dual Position Safety Function High-Pressure Air / Low-Pressure Air Interface.

Non-Q Breakers for Safety Service

24 4

RESOLUTION OF DESIGN-RELATED ISSUES e

All Known issuesWill Be Resolved Prior To Start-Up l

e Multilevel Approach To Safety Assurance

- Development and Implementation 6f T ~ ' ::

Comprehensive Pump Testing Program

)l

- Development and Performance of Comprehensive System Functional Evaluation i

- Development of Integrated Test Program

~:-

- Development of an improved Configuration ;

Management Program

.__._.m,,..._

25 PUMP TEST PROGRAM OBJECTIVES i

Address generic concern following LPSL pu.mp._.__.____.

e P-67B findings 4

Verify performance of safety-related pumps to l

e FSAR requirements Provide head curves to support system. testing e

and balancing as required t

SCOPE

~

~

e Service Water Pumps P-7A, B, C j

t j

e Auxiliary Feedwater Pumps P-8A, B, C

3

,7-;-

l

{

e Component Cooling Water Pumps P-52A, B, C

.:-----=---

e Charging Pumps P-55A, B, C i

e Containment Spray Pumps P-54A, B, C e

Low-Pressure Safety injection P-67A, B e

High-Pressure Safety injection P-66A, 8 STATUS e

Complete

26 SYSTEM FUNCTIONAL EVALUATION i

OBJECTIVE Verify, system performance to support normal e

operation and critical safety function success paths i

SCOPE l

~

All systems required for normal plant operation e

~

or critical safety function success path and their-e _

supporting systems (26 systems)

STATUS Evaluation is complete and exceptions _ have e

been identified.

All exceptions will be~

~

~i-dispositioned through testing or engineering justification prior to start-up.

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l SYSTEM FUNCTIONAL EVALUATION SYSTEM

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OPERATING i

REQUIREMENTS l

P i

j NORMAL POST-l OPERATIONS ACCIDENT i

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l SYSTEM MAINTENANCE FSAR/

ACCIDENT

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OPERATING FSAR AND TECHNICAL

^

ANALYSIS PROCEDURES MODIFICATIONS SPECIFICATIONS MODIFICATIONS I

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TEST I

REQUIREMENTS l

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28 TEST PROGRAM i

OBJECTIVES Assure proper operation of safety and other

~

important systems in normal operating and post-accident modes by:

~

e Verify open issues from System Functional.

l Evaluation i

~

e Complete Technical Specifications Surveillance Tests i

~

2 l

'e Complete Augmented Surveillance Tests e

Complete Post Maintenance Testing o

Perform integrated system testing for selected systems l

x

29 TEST PROGRAM (Contd)

SCOPE Cold Shutdown Testing e

Hot Shutdown Testing e

Power Escalation Testing 3

e --

. :. 3 STATUS

.e Substantial Cold / Hot Shutdown Testing

~~

n complete e.

Program / Procedures to address System:-

5

-.--r-l Functional Evaluation open items to be

~

complete mid-January e

Post Maintenance Testing for approximately 200 work orders remains open I

e Integrated System Test Plans under development for six (6) systems 1

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TEST PROGRAM SFE TEST REQUIREMENTS 1

INTEGRATED HEAT-UP AUGMENTED AND POWER ASCENSION SURVEILLANCE l

SYSTEM TESTING i f SURVEILLANCE m

TESTS PROGRAM i.

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MAINTENANCE.

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31 CONFIGURATION MANAGEMENT-PROGRAM i

OBJECTIVES e

Reconstruct well-documented design basis Verify plant configuration conforms to design e

e improve administrative controls that maintain plant design Ensure adequacy of design basis through SSFII e

type reviews

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SCOPE

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e Still under development.

Will include:

FSAR Drawings and Procedures Test Program Spare Parts Program

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CONFIGURATION MANAGEMENT PROGRAM (Contd)

STATUS Project Manager assigned e

Scope, process and schedule to be developed i

by March 31, 1987 l

e Phased approach planned to address important i

systems first l

f-e Estimated 2-3 years for full program e

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33 RESTART SCHEDULE Plant Heat-Up to Hot Shutdown Late January Heat-Up and Hot Shutdown 2-1/2 Weeks Testing Plant On-Line Early February Power Escalation Testing l

100% Power Operation

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34 STATUS REVIEW ACTIONS COMPLETED Repaired May 19 Equipment P)oblems e

)

Material Condition Review and Upgrade e

System Functional Evaluation n :n : :

sr.

e Pump Testing Program 3

.3.__._

e increased Maintenance Work Force e

Streamlined Operations and Maintenance Departments

+

35 STATUS REVIEW (Contd)

ACTIONS UNDERWAY TO BE COMPLETED PRIOR TO START-UP Back-up Air Supply To Address SSFI Findings e

Service Water Pump impeller Backfiling e

e Auto isolation Of CCW Control Valve On RAS Piping Erosion Inspection (Surry) e e

Plant Testing FOLLOW-UP ACTIONS Complete Configuration Management Program e

Complete Comprehensive Valve Maintenance l

l Program Complete INPO Accreditation of Training o

Programs e

Fully implement Preventive Maintenance Program e

Continuing Plant Hardware improvements i

i

^

36

SUMMARY

~ ~ ~ ~

i Comprehensive review of plant material o

condition completed and numerous corrective

~

i actions taken e

As measured by the following indicators:

l Work Order Inventory Control Room Deficiencies

~

l Jumper Link and Bypasses Material condition of the plant is better than in past five years, above Region 111 average and improving.

1

.. i

- :-~ :

Comprehensive review of plant systems for o

system functional capability l

l e

New management dedicated to further improvements to bring plant among top performers e

Company is recovering financially.

Employee morale is improved and turnover is low.

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TRANSMITTAL TO:

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ADVANCED COPY TO:

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FROM:

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a l Attached are copies of a Consnission meeting transcript and related meeting 3 !

document (s). They are being forwarded for entry on the Daily Accession List and j l placement in the Public Document Room. No other distribution is requested or T

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