ML20209J325

Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl

ML20209J325
Person / Time
Site:	Byron
Issue date:	01/30/1987
From:	NRC COMMISSION (OCM)
To:
References
REF-10CFR9.7 NUDOCS 8702060283
Download: ML20209J325 (89)

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e- ORIGINAL. .

f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r

In the matter of:

COMMISSION MEETING Discussion /Possible Vote on Full Power

. Operating License For Byron-2 (Public Meeting)

Docket No.

Location: Washington, D. C.

Date: Friday, January 30, 1907 Pages: 1 - 72 0702060203 B70130 PDR 10CFR

- PT9.7 PDR ANN RILEY & ASSOCIATES Court Reporters 1625 I St., N.W.

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

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1 D I SCLA I MER 2

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5 6 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on a 1/30/87, .. In the Commission's office at 1717 H Street, 9 'N.W., Washington, D.C. The meeting was cpen to public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain f -

s, 12 Inaccuracles.

13 The transcript is intended solely for general 14 Informational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of epinion in this transcript 17 do not necessarily reflect final determination or beliefs. No IG 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 Cemmission may i 21 authorize.

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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 DISCUSSION /POSS.IBLE VOTE ON FULL POWER OPERATING 4 LICENSE FOR BYRON-2 5 ---

6 Public Meeting 7 ---

8 9 FRIDAY, JANUARY 30, 1987 10 1717 H Street, N.W.

11 Washington, D.C.

12 13 The Commission met, pursuant to Notice, 14 at 2:00 p.m.

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 NRC STAFF AND PRESENTERS SEATED AT COMMISSION TABLE 23 S. Chilk M. Malsch 24 C. Reed R. Querio 25 V. Stallo R. Vollmer

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e 1 PRESENTERS (Continued):

2 3 J. Keppler C. Norelius 4 L. Olshan J. Taylor 5

6 AUDIENCE SPEAKERS:

7 8 K. Ainger J. Hines 9 B. Boger P. Kanter 10 E. Rossi T. Sullivan 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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1 PROCEEDINGS 2 CHAIRMAN ZECH: Good afternoon, ladies and i

3 gentlemen. Commissioner Bernthal will be joining us shortly.

4 The purpose of today's meeting is for the Commission 5 o conduct its immediate full power effectiveness review of the 6 Byron-2 plant and to possibly vote to authorize the Director 7 of NRR, after making the appropriate findings, to issue a full 8 power operating license for the Byron facility.

9 The Commission will be briefed by Commonwealth 10 Edison and by the NRC Staff. I would like the Licensee and/or 11 the staff to specifically address the following during their 12 presentation. Briefly describe the Byron Unit 1 operating i 13 history; second, the Byron Unit 2 avant review summary; and 14 third, discuss any exemptions granted or requested with 15 respect to the license.

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16 I understand that slide handouts have been made i

17 available at the rear of the room. Before we proceed, do any 18 of my fellow Commissioners have any opening comments?

19 COMMISSIONER ASSELSTINE: Yes, Lando, just a 20 couple. Just one fairly brief comment to start with. I agree 21 with your question about the operating history and performance i

22 of Byron-1, and I think what I would like to do is broaden the 23 issue just a little bit farther than that. The staff got a l

24 little advance warning a couple of days ago about this issue; 25 I didn't give you any, Cordell, but I'll give you a minute or

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4 1 two to think about the issue a little bit.'

2 When I looked back over the past four and a half 3 yearsthatI'vebeenontheCommission,kvotedforevery 4 Commonwealth plant that has come up. There have been a number 5 of those over the past four and a hal'f years; in fact, one of 6 the first plants that I acted on was LaSalle-1. But when I 7 look back over the performance of,the system, I have to say 8 that I have some concerns. Cordell, I've talked about it 9 withyou,I'vetalkedtoJimO'Connor,theChoofthecompany.

10 LaSalle 1 and 2 did not perform we'll to ' start with.

11 Rough startup programs. They were listed by us as.one of 12 problem plants in the country. My own perception was that 13 Byron 1 had some trouble to start with although it's.doing 14 much better now. Dresden now does not appear to be a strong 15 performer; it's an item of concern to us and I think it's an 16 item of concern to the industry, and I~ hear from regional 17 staff that Zion may be on a downward trend.

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18 And I guess the concern and the question I have is, 19 is there a problem or a difficulty or a challenge'in the 20 overall management structure of this company for the nuclear 21 program, rather than some individual site-specific problems.

22 And if there is a broad concern or question about the overall 23 management of this large nuclear enterprise by our largest 24 nuclear utility, are we aggravating the problem by adding 25 another plant?

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o-1 And I guess that's one of the issues that I would 2 like to focus on both with the company and with the staff to j 3 understand both the company's assessment and the staff's 4 assessment of performance of the system as a whole over the 5 past several years, the degree of dissatisfaction or 6 satisfaction both of the company and of the staff with that

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7 level of performance, and the kind of assurance that we have 8 now that in fact we're moving in the right direction.

9 And I would say at the outset that I really think 10 the regional staff has done a fine job over the past several l 11 years in working with the utility and in identifying and 12 focusing on problems, and if there's a weakness it may well be 13 at the headquarters level. And part of that weakness may be i

14 due to the fact that, quite frankly, because this is one of

! 15 the leaders in the industry, we know many of the people, we 16 know Cordell quite well, we know the CEO of the company and we 17 deal with them quite often on a variety of industrywide 18 issues, and I guess what I'm wondering is are we being tough 19 enough on you, are we getting the kind of information and

20 performance that we need. And I guess what I'm basically i

! 21 saying is maybe this is a good opportunity for some straight 1

22 talk, plain talk and straight answers on where we stand, and i 23 maybe a good milestone to take a look at the level of i -

24 performance that we're seeing.

, 25 CHAIRMAN ZECH: Let me just say also that I would

6 1 ask you, in support of Commissioner Asselstine, to address 2 those broader comments in addition to my opening remarks, 3 talking about the operating history of Byron 1 and the even 4 review of Byron 2. If you would expand the remarks to the 5 broader commonwealth Edison issue, and we'll also ask the 6 staff to comment when they come forward on the same issues.

7 MR. REED: May I just ask,i for the first there items 8 it was my understanding that the staff had intended to talk 9 about that. Shall we do that in addition to the staff?

10 CHAIRMAN ZECH: Yes, I'd like your comments just 11 briefly on that if you would, not to elaborate. But also, I'd 12 like you to expand you'r comments to the broader issues that 13 Commissioner Asselstine has raised.

14 Are there any other comments from Commissioners?

15 [No response.]

16 Then when you're ready, Mr. Reed, proceed.

17 MR. REED: Thank you. My name is Cordell Reed, I am 18 Vice President of Nuclear Operations at Commonwealth Edison.

19 I will discuss our corporate support to Byron Station as well 20 as the performance of our other units, and it was already my 21 intention to do that. And Bob Querio, our Station Manager, 22 will discuss the Byron plant performance as well as how we 23 intend to start up Byron Unit 2 at the same time we are 24 refueling Unit 1.

25 In my view, Byron Unit 2 is having one of the best

7 1 startups in the country, and I believe it's due basically to 2 two reasons. One is because our station management there is 3 experienced and I think they have been effective in their 4 management of the station. Additionally, I think we've 5 provided very strong corporate support through our division 4

6 vice president, Ken Grazer, for Byron, Braidwood and LaSalle.

7 Ken was one of our best station managers, he had programs at 8 Zion that were very effective and he's provided an aggressive 9 leadership, and most important, lessons learned from our other 10 stations to Zion.

11 Byron Station has implemented action plans and goals 12 consistent with our corporate strategic plan for excellence in 13 nuclear operations. For instance, last September they 14 implemented our new outage management program by the 15 installation of a new position, Assistant Superintendent for 16 Work Planning and a dedicated outage management staff. They 17 will put into place our significantly improved modification 18 program. And without question, Byron is closest to our goal i

19 of having all of our plants in the top quadrille of industry 20 performance indicators.

21 I think that we are on an upward trend at all of our 22 cperating stations, and let me just review with you some of 23 the facts and figures that you don't have, and tell you what

24 we're doing to address the deficiencies that we do have.

25 First of all, I think it's really noteworthy that

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8-1 our last SALP reviews for Dresden, Quad Citics and Zion we had 2 no Category 3 ratings. I don't know what our ratings will be 3 at our new SALP, but as we look at our performance we don't 4 think that we will have category 3's. That's just my 5 subjective view.

6 We have had no civil penalties at Zion Station for 7 the past three years, or Dresden and Quad Cities for the last 8 two years. And with the exposure of all three of these plants 9 being two-unit plants, our exposure is doubled. We've had 10 some close calls, I think there's been some latitude that's 11 been given to us, but I think that these are two very 12 important indicators of significant problems.

13 We have had an upsurge in the significance of 14 personnel errors at Zion, especially during the last quarter 15 of last year. And I believe that Jim Keppler will agree that 16 we have attacked this problem aggressively and 17 comprehensively. We analyzed our problems at a very low i

18 threshold, we met in a management meeting with Mr. Keppler and 19 his staff last Monday, and we really have attacked this 20 problem to get us over this as well as to get us to excellence 21 at that station.

22 As you have pointed out, Dresden Station was rated l

23 low, the lowest category, by INPO as a result of their 24 evaluation last August. I agree with their evaluation. INPO 25 came back in October at our urging to do another review of the i

9 1 station, it was a mini-review. They noted at that point the 2 heroic effort that had been made to correct the deficiencies.

3 In just a two-month period they were not in a position to 4 change our ratings, but all of the short-term items that were 5 identified had been corrected and they certainly were 6 impressed with our attack at the long-term problem which, as 7 my station manager at Dresden says, it's people, people, 8 people.

9 Additionally, we have committed to significantly 10 improve all of our nuclear facilities over the next five years 11 to a state of excellence. As a matter of fact, we have in our 12 five-year budget over $100 million which is allocated 13 specifically to facility improvement; piping improvements as 14 well as plant improvements, and the chairman helped calibrate 15 us on what a good plant should look like. Byron we are proud 16 of, but it's our commitment in the very near term to improve 17 all of our facilities at our plants.

18 LaSalle County certainly was the subject of 19 regulatory concern due to its poor performance during 1982 i

20 through 1985, at least through mid-year. Our record at

21 LaSalle, in my view, has dramatically improved over the last i 22 18 months. It's been sustained over 18 months. We have not 23 had our SALP revicw on LaSalle. As I look at the record, --

24 and I would hope that it's the way the region looks at the 25 record -- in my view we have no SALP 3's.

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10 1 INPO did an especially careful look at LaSalle last 2 spring, and very candidly, INPO told us that they were very 3 satisfied with LaSalle, with the station's management, with 4 the station attitude, and that they felt that LaSalle was in 5 the broad middle of performance. Of course, we want to be in 6 the upper quadrille of performance.

7 Braidwood Unit 1, I think it's noteworthy that we're 8 experiencing an excellent startup on Braidwood, and we 9 certainly have not been thus far the subject of any regulatory 10 concern on the plant.

11 Commissioner Asselstine, I guess I could talk in 12 more detail, but let me acknowledge several things. I 13 acknowledge the fact that LaSalle county had a very poor 14 startup, and when the action plan by the region -- Jim Keppler 15 was identified to us in October of '85, and we took a massive 16 approach to correcting the ills at that station. And I can 17 tell you that I believe that that action plan has been 18 effective because when you look at the performance indicators 19 at LaSalle -- and it's not just six months, seven months or 20 eight months -- I think you'll see that that's improved.

21 The Dresden evaluation by INPO was really a blow, it 22 shook us. I could make all sorts of excuses; we were just 23 coming out of a nine-month piping replacement outage, but the 24 fact is that the station was in bad housekeeping condition, 25 and there had been some repeated things that INPO had told us l . _ _ _ . _ - _ _ - . . _ _ - . . - . . - - _ - - - - - . - - - - - - - - - - - -

11 1 that we had not accomplished such as changing out the makeup 2 demineralizer and doing some other physical things. And I can 3 just tell you I think that their rating of us was the best 4 thing that ever happened to Dresden because I have no doubt in 5 my mind now that Dresden is on a steep incline upward, and I 6 think it's going to be sustained.

7 Your comment about Zion. Our threshold is a very .

8 low threshold now, Jim, and I'm very proud of our station 9 management because we were looking at the same trends. The 10 number of personnel errors at Zion are not higher than you 11 would normally expect at any other stations; however, we noted 12 that there were five or six very significant events that 13 happened through September on that concerned the region and 14 concerned us. And we have instituted our error-free startup, 15 senior manager on shift, just some very dramatic things. An 16 important thing is we've analyzed ourself in a very systematic 17 method and our action plan keys to our ills, which are 18 operator awareness, personnel errors and improvement of our d

19 procedures.

20 I don't want to paint a rosy picture, but two things t 21 I want to go over. The Commonwealth Edison performance over 22 the last three years really has not been -- I don't know how 23 to put this in perspective. We've had a number of units and I 24 think the performance has been adequata with exceptions. And 25 I think that our startup of Byron 2 at the same time with

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12 1 Braidwood 1, at the same time of improving Byron l's 2 performance, and significantly, LaSalle's performance would 3 lead me to think that we are on top of the job.

4 COMMISSIONER ASSELSTINE: That's very helpful. I l 5 don't disagree with your goal at all; in fact, I think that's l

6 at least a good ambitious starting point of getting everybody 7 into the top quarter. And if there's an area of concern it 8 has been, to give you your due, when you focus on a plant 9 that's had problems or difficulties you seem to do quite well, 10 and I'm personally very pleased with the Byron 1 performance 11 over the past year or so.

12 But it seems that you focus on one and then all of a l

13 sudden we find out that performance is deteriorating at I 14 another one of the units or more than one of the units, and I 15 guess what I'm looking for is a sense of assurance that 16 sufficient changes and efforts are now underway throughout the 17 system that we won't see a fire drill kind of an approach 18 where you jump on one only to find out that another one is 19 sliding someplace else when you take the attention off of that 20 one and put it onto the others; you get the kind of systemwide 21 improvement in performance that you're aiming for.

! 22 MR. REED: I think the most significant thing that 23 we've done to improve our corporate support of the stations 24 was to introduce our two division vice presidents, putting one 25 over Byron, Braidwood and LaSalle, the other over Dresden,

13 1 Quad Cities and Zion. I didn't make the Dresden move until 2 April off this year. I think if I had done it earlier maybe 3 Dresden would not have slipped down. But these two guys, 4 we've taken the best plant guys that are in the stations one 5 or two days a week, they're reading to bring the corporate 6 support, and I really think we're keeping track of things a 7 lot better with this setup. .

8 COMMISSIONER ASSELSTINE: Is your sense that where 9 you've had the difficulties that they really are site-specific 10 or plant-level difficulties as opposed to a management problem 11 in the system? Or how much can you attribute to either?

12 MR. REED: I think they've been site-specific. We 13 have the same general organization and procedures, and you 14 know that it depends upon the chemistry of the people. And by 15 the time that LaSalle's performance was highlighted to us in 16 October of '85, I thought we had already started to climb out 17 of that.

18 But it's site-specific, it's the people. No 19 question that the attention of corporate management has been 20 diverted to plants under startup. This is the first time in 21 our history since mid-year last year that we're not manning a 22 new station, so we're becoming stable.

23 CRAIRMAN ZECH: Proceed.

24 MR. QUERIO: My name is Robert Querio, I'm the 25 Station Manager at Byron Station, and I had planned to touch

o 14 l 1 on the Byron Unit 1 operating history and some of the Unit 2 2 performance data in my prepared notes.

, 3 Our goal at Byron Station is to be one of the best 4 nuclear power plants in the world. The people that we have at 5 Byron are committed to excellence, our people have substantial 6 experience and we have had a good track record on our 1986 7 operations at Unit 1. We believe that we know how to handle 8 our plant now and how to handle situations in today's nuclear 9 business that would come up.

10 I would characterize our Unit 1 history as a slow, 11 struggling start, however following by what I would say is an i

12 aggressive recovery period. We have had exemplary performance 13 through all of 1986 on Unit 1, and I think that improved 14 performance even started in late summer of 1985, kind of at 15 completion of the Unit 1 startup testing program.

16 Regulatory data on Unit 1 I know will be shown on 17 some of the charts by the Region III staff, but in general 18 terms our performance from 1985 to 1986 was significantly 19 improved in the areas of safety injections, reactor trips, ESF 20 actuations and licensee event reports; significant 21 improvements there.

22 The latest SALP information for Byron which was just 23 issued this month -- in fact, we had the SALP review meeting 24 just this past week -- showed no number 3 SALP ratings in any

25 of the areas rated for Byron and there were two number 1

15 1 ratings and the remainder were all number 2's. Several of the 2 areas were identified as model areas during the SALP meeting,

! 3 and the SALP report commented that the improvement programs  !

l 4 that we have implemented at Byron over these various problem '

5 times have been very effective, and I believe overall that the 6 SALP report was a very good report for Byron Station.

7 The commercial data for Byron Unit 1 also has been 8 very good. In 1986, our equivalent availability for Byron 9 Unit 1 was 80.6 percent. Our thermal performance has been 10 good at 10,108 Btu's per kilowatt hour, and a statistic that 11 isn't finalized yet but we believe to be final data is that in 12 1986 Byron Unit 1 had the largest total gross electrical 13 output of any plant in the United States. We register 14 7,835,000 plus megawatt hours of total output and wa're pretty 15 confident that's the largest total electrical output of any 16 nuclear plant in the United States. And even additionally, we l

l 17 think puts us in the range of 12th to 15th or so in world 18 plants for total output. Byron had a good year in 1986.

19 This excellent performance on Unit 1 was achieved 20 while Unit 2 pre-op, fuel loading and startup testing was 21 going on at the same time, so I think it addresses the issue 22 of are we able to deal with two units at the same time.

23 The Unit 2 performance during this time was very 24 good, showed four licensee event reports on Unit 2, one ESF 25 actuation on Unit 2, one reactor trip that did cccur on Unit 2 t

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16 1 was due to an equipment failure. We believe at the station 2 that the Byron Unit 2 startup to date has been the best 3 performance of a plant in terms of reactor trips, event 4 reports, ESF's, and all of this has been accomplished with a 5 good time schedule also.

6 I think the credit for our successes at Byron is due 7 to aggressive implemen.tation of lessons learned. The Byron 8 Unit 1 experiences in the 1985 timeframe taught us a lot of 9 things. We did have some operating problems in terms of 10 trips, ESF's and LER's, and it resulted in our implementation 11 of various improvement programs in the operations area, rad 12 protection, security and most recently in the maintenance 13 area.

14 Also at Byron Station we continuously review 15 experiences at our other commonwealth Edison plants. We 16 review deviation reports that occur at other plants, event 17 reports, significant events. All of the management people at 18 Byron participate in the various meetings that are held with

! 19 our company people, and we have phone calls on a regular basis 20 to discuss problems at our other Edison plants. And then 21 additionally, we also try and closely follow industry 22 happenings through NRC communications and through INPO 23 communications. We believe we aggressively implement lessons 24 learned at Byron.

25 One of the more recent activities we have

17 1 implemented that was based on the good success that was had at 2 LaSalle Station and Dresden Station following their recent 3 startups in '86 was an error-free startup plan. Both Byron 4 and Braidwood Stations have error-free startup plans 5 implemented. These plans include principally communications 6 between all of the various parties and departments involved at 7 the plant, but specifically include a senior manager level 8 person on shift, include an additional SRO supervisor on our 9 startup plant, include an extra nuclear station operator, a 10 licensed control room operator on the startup unit, and 11 include a nuclear engineer on duty on the startup unit when 12 significant reactor activities are going on.

13 This error-free plan, along with our normal daily 14 planning activities, includes focusing on work priorities 15 for the day. We have had a big emphasis on a blackboard 16 annunciator program all through 1986 and it has been a very 17 effective program. And we also focus on all control room 18 distractions in terms of equipment out of service, 19 annunciators, meters and gauges that aren't properly working, 20 and we also focus on what we classify to be high risk 21 surveillance activities for the particular day so that we can 22 improve our performance. We try and emphasize top to bottom 23 communications at all times and I think that's a big part of 24 the lessons implementation for us.

25 In terms of people and staffing at Byron Station,

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18 1 our staff size is 680 people, plus we have additionally 200 2 security guards, and we have some additional contract support 3 available to us in the way of service specialists. This is l 4 our two-unit size. We've had this two-unit size for several 5 years. The point I want to make is that the people that we 6 have now all have Unit 1 experience from the several years and 7 the recent Unit 2 startup experience.

8 In terms of specific experience for our people, our 9 management people have an overall average of 9.8 years of 10 power plant experience, specifically 7.8 years of nuclear 11 power plant experience including commercial and military 12 nuclear experience. And the senior management people of the 13 plant, including myself through the several shift supervisors, 14 range from 10 to 20 years' worth of nuclear plant experience.

15 In terms of bargaining unit experience or the 16 non-management, the craft workers in our organization, they 17 average overall five years of power plant experience with 18 their nuclear experience being 4.3 years of commercial and 19 military nuclear. The field operators that we have, we call

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20 them equipment attendants, have 3.3 years of nuclear plant 21 experience. Our control room operators themselves average 7.9 22 years of nuclear experience, and the rad technicians that we 23 have have 4.7 years. So I think there's a significant 24 experience base in the people at Byron Station.

25 A recent question that has come up is how do we

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4 19 1 believe that we will be able to deal with the Unit 1 refueling i

i 2 outage coming up shortly; in fact, two weeks from today, and 3 the Unit 2 startup at the same time. And I think the 4 organization that we have in place is able to deal with this 5 kind of an activity adequately.

6 The Unit 1 activities are principally organized r

I 7. under one branch of the organization called a production 8 superintendent at Byron. He has an assistant superintendent 9 for operations, and the assistant superintendent for wcrk i

I 10 planning that Mr. Reed referred to reporting to him. We have i

11 a Unit 1 operating engineer that focuses on the day-to-day 12 planning for the unit, and our maintenance assistance 13 superintendent will deal with the maintenance activities 14 during the outage, and the three branches of the Maintenance 15 Department.

16 We have added resources available to us that include 17 our own technical staff, we have some extra rad chem 18 technicians available, and we have several service contractors 19 to support the principal outage work on our unit.

20 Furthermore, our Project Construction Department is 21 still mobilized on the site. They have site contractors 22 available to us and are able to supplement the work forces and 23 they can supply large amounts of bulk labor as necessary for 24 our refueling outage activities. We have the Station Nuclear j 25 Engineering Branch of our company that's available for

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20 1 support, and we have support from the Westinghouse 2 organization in terms of a site services manager that is 3 resident at the site and a site engineering team that is 4 there, and they can mobilize whatever offsite support from 5 Westinghouse might be necessary.

6 The Unit 2 activities, the startup activities, are

, 7 organized under a branch of the organization called the 8 Services Superintendent. We have the Unit 2 operating 9 engineer that focuses with the day-to-day activities on the 10 Unit 2 startup group with startup activities on the plant. We 11 have a Unit 2 startup group that is organized with a 12 Commonwealth Edison person as the lead person, belongs to the 13 Services Superintendent, and several key Commonwealth Edison 14 people in that group. Then it is supplemented by experienced 15 contract startup people that have experience at similar plants 16 around the country.

17 We have additional resources for the Unit 2 startup 18 in the form of our Maintenance Department, again being able to 19 work on startup support, principally instrument mechanics or 20 startup support. The construction Department is again onsite 21 with bulk labor as needed, and we have the Project Engineering 22 Department that is available for the Unit 2 startup 23 activities. And in both cases we are able to use Sargent &

24 Lundy, our principal architect engineer organization for 25 either the refueling or startup support where needed, and then

21 1 Westinghouse still is mobilized onsite with their own startup

'2 group that now focuses on the Unit 2 activities.

3 One feature that is in addition to the separation 4 between refueling work and startup work is that th+a operators 5 are common to both of the activities. We have a common 6 control room and the operators rotate from position to 7 position on a day-to-day basis so they're familiar with the 8 Unit 1 experiences and with the Unit 2 startup experiences.

9 The startup on Unit 2 has been accomplished in a 10 very satisfactory schedule performance so far. It's been done 11 in an orderly and organized fashion. We, in fact, completed 12 our 5 percent activities last week and were ready with all of 13 our test reviews last Thursday, and since that time we have 14 been doing some work in the next advanced schedule that could 15 be done still within the 5 percent power limit.

16 All of the separate groups we have have worked I

17 together in the past; they all participate in these daily i 18 meetings. Our principal meeting is each morning and focuses 19 on Unit 1 and Unit 2 operating and maintenance activities.

l l 20 And then when we have an outage going on -- and we will do 21 this when we get into the refueling time -- we have an 22 afternoon meeting that focuses principally on the outage l 23 activities. We have used this method through 1986 on several i

24 mini-outages and it has been very successful for us.

I 25 The error-free plan causes us to specifically focus l

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22 1 on actp.vities and help coordinate things. This involves a 2 bi-weekly meeting and it brings general office people out to 3 the site and meets with all of the station departmental people i 4 including the craft workers or bargaining unit folks.

5 The work planning group we have specifically watches 6 the two schedules for the refueling and for the startup to 7 send up a signal if there happens to be a major event planned 8 on either unit at the same time and we will delay whichever 9 one is appropriate. But it calls it to our attention.

10 Byron Station is committed to professional 11 excellence in all of our activities. Our approach to all of 12 our affairs is timely. We believe it's thorough, 13 comprehensive and aggressive. Our goals include being the 14 best plant in our company, in the United States and in the 15 world and we're not going to be satisfied until we have 1

16 reached those goals. I know that we have the people and the 17 commitment to work towards the goals. I know that we will 1

18 continue using the methods that we have used in the past, and

] 19 I believe sincerely that we can accomplish these goals at l 20 Byron.

21 The exemptions to the license include a request for 22 deferral of completion of the auxiliary building ventilation 23 system. That is due to the fact of not being able to complete 24 the test and balancing information because of interference 25 with Unit 1 operating activities in the fact that all of the

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23 1 conduit seals and things like that haven't been fully in place 2 so that they are some of the last things to go in place in the 3 Unit 2 construction, and we just haven't been able to complete 4 all of the test and balance; therefore, aren't able to 5 complete all the settings of all the dampers right now.

6 We have a commitment to do surveillance testing on 7 the ECCS leakage specifically before we go to 30 percent power 8 and to do the testing in an April timeframe again, and to do 9 the testing in I think a June timeframe again. The commitment 10 is to have all of the VA work completed by October --

11 completed before October of '87.

12 COMMISSIONER ASSELSTINE: Is that because you need 13 to get into the outage for Unit 1 to --

14 MR. QUERIO: That's right. The work during the Unit 15 1 outage will again disrupt the ability to do all the test and 16 balancing with floor plugs and major doors open and things 17 like that.

18 MR. AINGER: My name is Ken Ainger, I'm with the 19 Nuclear Licensing Department of Commonwealth Edison. I just 20 want to clarify what Mr. Querio was referring to here is not 21 an exemption that's included in the operating license, but 22 rather a temporary technical specification that allows us to 23 operate the plant without satisfying one specific surveillance 24 requirement in the technical specifications.

25 But I believe there is an exemption that we are

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

24 1 being granted regarding Appendix J leak testing of the 2 containment air lock. ,

- 3 CHAIRMAN ZECH: Do you want to elaborate on that at 4 all? Why is that being requested?

5 MR. AINGER: I don't think I could elaborate on 6 .that. Maybe the NRC Staff could.

7 CHAIRMAN ZECH: All right, we'll ask the staff about 8 that. Anything else then?

9 MR. REED: That's all we have. Let me ask my fellow 10 Commissioners if they have questions for Commonwealth people.

11 Commissioner Roberts?

12 COMMISSIONER ROBERTS: Is Sargent & Lundy your AE 13 for all your plants?

14 MR. REED: Yes. With the exception of Dresden 1 15 which I think is Bechtel. And although the Dresden and Quad 16 Cities units were turnkey jobs, they were the AE on the 17 electric.

18 CHAIRMAN ZECH: Commissioner Asselstine?

19 COMMISSIONER ASSELSTINE: Just a couple. Your 20 operators. Because you have a shared control room, do all of 21 your operators have hot functional experience or het operating 22 experience with Unit 1 for Unit 27 23 MR. QUERIO: Yes. We have 30 reactor operators.

24 They've been all experienced since September of last year on 25 Unit 1.

s 25 i -

1 COMMISSIONER ASSELSTINE: Good. And are you going 2 to have a plant reference simulator for Byron, at Byron?

3 MR. QUERIO: Not at Byron.

4 MR. REED: No. Of course, we have a plant reference 5 simulator at Braidwood and it is not our intent to put another 6 at Byron Station. We've looked at that but we don't choose to 7 do so.

8 COMMISSIONER ASSELSTINE: How long is it -- refresh 9 my memory -- in terms of travel and distance? A couple of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />?

11 MR. QUERIO: Two hours.

12 MR. REED: We really haven't had a problem in that 13 regard.

14 CHAIRMAN ZECH: I would like to follow on that if I i

15 may for just a minute. I recognize it's only two hours 16 perhaps, but still, I would commend you to make sure that you 17 make good use of that simulator because if you don't have one 18 on site, then it would seem to me that it's a management 19 responsibility to ensure that you really do use that simulator 20 and use it frequently.

21 MR. REED: We're sensitive to that. The problem we 22 had and why Bob and I smirk at each other because we've talked l

l 23 about this, we had a crunch with some Byron and Braidwood l

24 training, competing themselves, that we resolved 25 satisfactorily. We had options like a second shift and like i

26 1 .that. But I understand the thrust of what you're saying, but 2 with the two hours distance it has not been a problem. If 3 there was an event at the plant where we wanted to practice 4 some things on the simulator, we think we can get some people 5 out there pretty quickly to practice those things.

6 MR. QUERIO: And we have done those things. We use 7 the simulator very obviously for initial training for our new

+

8 licensed people. We have used it for requalification 9 training, and we just added in the 1987 year additional days 10 of simulator training for requal for all of our people. We 11 have called to the simulator to ask them to run things for us 12 that we wanted a change of parameter on, and we've gone there 13 ourselves and run special events at the simulator.

14 CHAIRMAN ZECH: The Byron people ought to think it's 15 their simulator as well as Braidwood's.

16 MR. QUERIO: And we do.

17 COMMISSIONER ASSELSTINE: I guess there are two 18 components to the question. One is the time distance, the 19 distance factor, and is that an inhibition to really using it 20 on a fulltime and effective basis. The other is the burden; 21 with four reactors and one simulator do you get enough time.

22 COMMISSIONER BERNTHAL: That's the key question, it 23 seems to me.

24 COMMISSIONER ASSELSTINE: That's more important than 25 the two hours, actually.

27 1 COMMISSIONER BERNTHAL: Actually, I would be 2 delighted if every plant in the country had a plant-specific 3 simulator within two hours. We don't need to gild the lily .

4 here, but my question was as a practical matter I'm curious to 5 know if you have a plant-specific simulator with one plant, 6 what's the duty cycle of it, ideally. And when you start 7 putting four plants on, it seems to me that thing would be 8 pretty well running around the clock, wouldn't it?

9 MR. QUERIO: Well, the procedures and the activities 10 for both the Byron and Braidwood plants are the same. We =

11 schedule the classes, they're mixed classes between Byron and 12 Braidwood people, and I don't think they're running 24-hour 13 operation there.

14 COMMISSIONER BERNTHAL: There's no --

15 MR. QUERIO:- We don't consider an inhibition, the 16 two-hour point. In fact, when we send people there it's 17 typically for a three multi-day activity, so they travel the 18 day before and come home when classes are done.

19 MR. REED: In fact, we would be looking to sell a 20 shift on our Byron and Braidwood simulator.

21 COMMISSIONER BERNTHAL: Is that right.

22 MR. REED: The problem we had was in late '85 and 23 early '86 during the initial training of the Byron and 24 Braidwood people, and we got through that okay, we didn't 25 exercise all our options. But the duty cycle will not fully,

_ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ A

28 1 take two shifts.

2 COMMISSIONER BERNTHAL: I see.

3 COMMISSIONER ASSELSTINE: You are running six shift 4 rotations?

5 MR. QUERIO: Both.

j 6 COMMISSIONER ASSELSTINE: Both plants?

7 MR. QUERIO: We will be.

8 MR. REED: We will be. I'm not sure about 9 Braidwood, if we're into six shift yet.

10 COMMISSIONER ASSELSTINE: So that will put a shift l 11 in training every five weeks, four weeks, something like that, 12 for a week or is it broken up in smaller chunks than that?

13 MR. QUERIO: It's broken up in bigger chunks than j 14 that. We have one shift in training for six weeks at a time ,

15 at Byron. And then we have additional periods when they do

{

[ 16 come up on their extra week of rotation where they go to 17 simulator time during those added weeks throughout the year.

18 COMMISSIONER ASSELSTINE: How many hours of 19 simulator training do the operators get per year?

I 20 MR. QUERIO: I think it adds to 12 days.

21 MR. REED: Yeah, about two weeks.

22 MR. QUERIO: Twelve simulator days.

23 COMMISSIONER ASSELSTINE: Are Byron and Braidwood 24 identical?

i l

25 MR. QUERIO: Virtually.

I 1

29 1 MR. REED: The reactor systems are virtually 2 identical. We promised ourselves never to say anything is 3 identical. You know of the balance-of-plant. differences at 4 the lake, but we've tried to have configuration control so 5 that the reactor systems are identical, and we think we are 6 about there.

7 COMMISSIONER ASSELSTINE: Does the simulator match 8 Braidwood?

9 MR. REED: Indeed.

10 COMMISSIONER ASSELSTINE: Okay. The differences are 11 essentially on the balance of plant.

12 MR. REED: Correct.

13 MR. QUERIO: For operating procedures, for emergency 14 procedures; we're committed to the same procedures for both 15 plants.

16 COMMISSIONER ASSELSTINE: Okay. So what you've got 17 is a Braidwood simulator which you think is very close to 18 Byron.

19 MR. QUERIO: Right.

20 MR. REED: No, I think we have a Byron simulator --

21 COMMISSIONER ASSELSTINE: That's very close to 22 Braidwood. All right.

23 CHAIRMAN ZECH: Commissioner Bernthal?

24 COMMISSIONER BERNTHAL: I'm still trying to noodle 25 out the difference between a temporary technical specification

30 1 and an exemption, but maybe our staff can enlighten me. I 2 don't have very many, I have no very specific questions, I 3 guess. ,

4 I am curious about the lessons that you might be 5 drawing, comparisons that you might have been able to make, 6 because of your' unique circumstance at Braidwood of having a 7 very, very long, drawn out startup time, somewhat beyond your 8 control I guess, but you've decided to do something there 9 that's different. And normally, you would have a considerably 10 shorter time. Are there any advantages to be gained by doing 11 things the way Braidwood has with this six-month or so nominal 12 period of startup? Long, drawn out, lots of time to do things 13 slowly. And I'm being quite serious about it.

14 Would there be a benefit in other plants perhaps 15 even there weren't the external circumstances to trying to run 16 parallel track with construction even perhaps and draw out the 17 plant startup and not do it in the normally shorter period of 18 time.

19 MR. REED: If I want to get a very specific answer 20 I would ask Ken Razer to come up here, who is at Byron and 21 Braidwood each year, but I've been a part of our reviews.

22 Braidwood would go slower than Byron 2 anyway because in fact, 23 the construction on Unit 2 at Braidwood has been an inhibition 24 as to how fast they can go. So they would be slower anyway.

25 The people being more inexperienced, we would go ,

31 1 slower. There's a little bit of frustration on Braidwood's l

l 2 part in that they would like to go faster. Byron 2 has just '

3 been phenomenal, it's been,beyond all of our expectations. I 4 But we could go faster on Unit 1 at Braidwood. We've used the 5 extra time to use our resources to complete more of the Unit 2 6 construction at Braidwood. As a matter of fact, we're ahead ,

7 of our schedule on Unit 2.

8 But clearly, we are going to end up on Braidwood 1 9 being held up maybe a month or two beyond where we think we 10 could be.

11 COMMISSIONER BERNTHAL: It may be too early to draw 12 any conclusions anyway.

13 MR. QUERIO: I was going to add on Byron Unit 2, we 14 fashioned an orderly and deliberate schedule for Unit 2 15 activities; we're not in a hurry with the plant at all.

16 COMMISSIONER BERNTHAL: No, I recognize that.

17 MR. QUERIO: But in fact, it has come along very 18 well, and I think it's because we just have learned well and 19 retained from the sister unit at the site and implemented the 20 things we learned in the pre-op startup procedures and it's 21 working very well.

22 COMMISSIONER BERNTHAL: You're the Station Manager.

23 I think it's fair to say in most respects, this is not one of 24 our more nettlesome plants and decisions here today, but there 25 must be something that -- or maybe some things -- that trouble

32 1 you most about the plant at this point. I would hope and 2 trust there are not major items. Maybe Mr. Reed will learn 3 something here too. But as the Station Manager, if I had to 4 ask you what single thing you aren't quite happy with at this 5 point more than anything else, what would your response be?

6 What is it you would most like to see improved? .

7 MR. QUERIO: I think the final completion of some of 8 the construction activities. We had a reactor trip on Unit 1 9 last September because of completing some of the fire 10 protection activities. That has in fact contributed to us 11 delaying the aux building vent work because we just said, hey, 12 we're not going to allow that work anymore; they were still 13 completing the fire stop, conduit seals and things like that.

14 COMMISSIONER BERNTHAL: Get these guys out of there, 15 in other words. '

,y.

16 MR. QUERIO: That's right, from an ideal side. But 17 from the pure operating part of the station I would like to 18 see construction out of there faster.

19 COMMISSIONER BERNTHAL: It's a favorite subject of 20 the Chairman's if I recall, that transition between 21 construction and operation. ,-

22 MR. QUERIO: And there's more to it. We've been 23 pretty proud of the housekeeping condition we've'put in place 24 at Byron Station, and it's just harder to keep the 25 construction craft people really attuned to good housekeeping

..- ~. '

33 1 than it is to keep the station organization people, so that we 2 would make that effort this year.

3 , COMMISSIONER BERNTHAL: Okay. I have no further 4 questions. Again, I think every time Commonwealth is here --

5 and they have been here a few times for a license -- I stress 6 that -- and I know you are sensitive to this - ,you're the 7 biggest in the business and you ought to be the best. You s 8 can't afford to be mediocre. I was pleased to see that your 9 SALP ratings have improved, and they should. I sometimes 10 worry that maybe the whole operation was getting too big. I 11 don't know why that has'to be true, but it was certainly a 12 very large program, and I know you're sensitive to the 13 important role you play in showing the way in this business.

14 We've had one other very big operation in this 15 country that has fallen on hard times, and the last thing in 16 the world that we need is a repeat of that, and I know that 17 you don't intend to do that and you certainly haven't done 18 that. But again, I want to emphasize how important it is that 19 Commonwealth be one of the best in the country in this I

20 business.

l 21 That's all I've got.

22 CHAIRMAN ZECH: Commissioner Carr?

23 (No response.]

24 I'll have some comments, but I would like to say 25 thank you and ask you to take your seats in the audience and l

, 34 1 we'll invite the staff to come forward, please.

l 2 Mr. Stello, you may proceed.

3 ,f MR. STELLO: Thank you, Mr. Chairman. What I s

4 q propose to do is to very quickly summarize where we are and 5 ,what our views are and then if we can, come to the question 6 Commissioner Asselstine raised at the end and have Mr. Keppler 7 r'espond directly to that question. He had indicated he was 8 gbing to ask it and we're prepared to do it, but I'd suggest 9 we put it off until the last.

10- CHAIRMAN ZECH: Sure, that's fine.

1

'll MR. STELLO: Dick, if you can, maybe you could 12 start.

13 MR. VOLLMER: We have a brief presentation and we'll 14 start out with Leonard Olshan who is the Project Manager for 15 this plant.

16 (Slide.]

17 MR. OLSHAN: Thank you. To start out>our 18 presentation we' intend to give you a little brief background 19- of the plant, discuss the plant design, the staffing which 20 ,' you've heard about already, and a little of the inspection 21 history and then our conclusion.

22 (Slide.]

l 23 Byron, as you already know, is owned and operated by 24 Commonwealth Edison, the owner and operator of four other l

25 operating plants in addition to the Braidwood plant. Byron 2 l

l l

l

O 35 1 is the second of the two units of the Byron Station. Byron 1 has been in commercial operation since September 1985 and has 2

3 had an availability of about 78 percent.

4 It's a standard four-loop Westinghouse plant. There 5 are about 19 other Westinghouse four-loop plants in operation 6 throughout the country, and it represents a fairly large body 7 of experience. There's nothing unique aboutethe site or the 8 population near the site.

9 [ Slide.]

10 This just briefly gives some of the plant design.

11 The important thing here again is that Byron and Braidwood are 12 duplicate units. When we said balance of plant is different, 13 actually, balance of plant 'is pretty much the same, it's only 14 site-specific areas that are different. The NSSS and the 15 balance of plant are almost identical.

16 [ Slide.]

17 And this is the staffing, the column on the left is 18 the tech spec requirements. The column on the right is the 19 actual staffing that Commonwealth Edison people have at the 20 Byron Station. As you can see, they meet or exceed all of the 21 requirements of the technical specifications. Every one of 22 the people on shift has Byron 1 hot operating experience, so 23 it's a well experienced crew. And as Mr. Querlo said of the 24 RO's on the bottom there, all 30 of them have had previous 25 Byron 1 hot operating experience.

~

36 1 That pretty much concludes what I was going to say.

2 MR. NORELIUS: I'm Charles Norelius, Director of the 3 Division of Reactor Projections, Region III. If we could 4 continue on then with the next slide.

5 (Slide.]

6 I should say, before I start talking about Unit 2, 7 that Unit 1 also had some extensive,looks at the construction 8 activities. NRC conducted an independent design inspection of 9 Unit 1, and Bechtel Corporation also did an independent design ,

10 review for Unit 1 as requested by Commonwealth Edison. And 11 the problems that were identified during those particular 12 reviews were applied; the corrective actions that needed to be 13 taken were applied to Unit 2 as well.

14 Also, Region III did a construction assessment 15 program of Unit 1 and there were some problems that were I 16 identified or at least questions raised with regard to 17 qualifications of QA/QC people. Corrective actions were 18 applied to Unit 2 as well.

19 With regard to Unit 2 itself, there were special 20 inspections conducted. There was a construction appraisal 21 team conducted by the Office of Inspection and Enforcement 22 that looked specifically at Unit 2. They found no pervasive 23 problems in terms of QA breakdowns, nothing of that sort.

24 There were three violations which were readily correctable.

25 In addition, the NDE Van conducted an inspection of

37 1 Unit 2 and again found no major concerns. That inspection 2 came out quite well. So from a construction

• standpoint, we 3 did our routine inspections as well and identified no 4 particular problems with regard to Unit 2.

5 For the pre-operational testing program the utility 6 established,a rather extensive lessons learned program from i

7 Unit 1. They started with,the basic Unit 1 pre-operational 8 testing procedures, they looked at the retests that they had 9 to make, the individual component tests, correspondence, their 10 own QA involvement, comments that we had made, deviation 11 reports, all the things that came up with Unit 1 testing and 12 put that all into a lessons learned program and included an 13 exchange with Braidwood, and they came with a very 14 comprehensive checklist type approach to do the Unit 2 tests.

15 And we looked rather extensively at that program and thought 16 it was a good one and as a result, actually backed off on some 17 of the specific inspections that we would normally do.

18 They also improved their pre-op test organization 19 using the key people from Unit 1, and so they gained from that 20 experience. So by and large, the pre-op test program went 21 quite well with Unit 2.

l

! 22 The number of allegations at Braidwood have been 23 roughly consistent with other plants in terms of numbers, l

24 other plants within our region.

l l

l 25 COMMISSIONER ROBERTS: You said Braidwood; you mean 1

38 1 Byron. -

2 MR. NORELIUS: I'm sorry, Byron. Have been 3 consistent with other plants within the region. We have 4 looked into all of the allegations that have been brought 5 forth and have concluded that there are no safety issues that 6 are, outstanding because of those allegations.

7 I might just spend a few minutes talking about one 8 that has gotten some publicity recently. An individual who 9 has a company that deals with detecting interferences by a 10 computerized method where he looks at as-built drawings has 11 raised an issue relating to the fact that certain of the 12 as-built drawings have errors in them.

13 And we met with that individual, he identified some 14 26 instances where he thought measurements were in error on 15 the drawings. Our people went to the plant, they looked at 16 912 separate dimensions on a number of different systems both

! 17 in Unit 1 and Unit 2 and in the aux building. These were 18 generally selected at random. They took measurements within 19 the plant, they looked at the analyses that were performed and 20 they found no instances of safety problems that existed.

21 We met with this alleger earlier this week to 22 explain what we had done. He was not pleased with our effort, 23 he disagreed with it, and the basic disagreement comes down to 24 the fact that he is looking for 100 percent accuracy in the 1

25 as-built drawings, and we did in fact find instances where the 1

i 39 1 as-built drawings had some errors but in those instances we 2 found that the measurements *themselves were proper, that the 3 measurements that had been used in the analysis were proper, 4 and that there was not a problem with the analysis as compared 5 with the plant as built. But we did find some problems with 6 the drawings there.

7 ,So we have satisfied ourselves that there is not a 8 problem of any safety significance, but obviously, the company 9 will have to correct the drawings where errors were made on 10 the final as-built drawings.

11 MR. KEPPLER: Chuck, let me expand on that if I 12 may. It's more than just looking at the 912 dimensions that's 13 involved here. We had an inspection conducted I believe it 14 was in 1984 by Mr. Yin, and he found a number of problems, a 15 number of concerns with Commonwealth's QA program in this 16 area, and that effort required the utility to make a number of l 17 corrections at that time.

18 So in retrospect, when you look at Mr. Yin's 19 inspection effort, the follow-up actions of the regions, the 20 fact that there was a construction appraisal team inspection 21 done, an independent design inspection done by the NRC, one 22 done by Bechtel, it doesn't surprise me that we didn't find 23 any real problems in this area.

24 We would have been satisfied initially doing maybe a 25 statistical sample, but because of the individual's concerns,

40 r

1 the fact that he has raised concerns before, we wanted to be i

• 2 extra sure. We expanded our sample, we looked at areas 3 critical to the design, and we really tried to go the extra 4 nine yards here on this.

5 COMMISSIONER ASSELSTINE: Did Isa's inspection focus 6 on the question of the accuracy of the drawings as compared to 7 ,the as-built plant or not?

8 MR. KEPPLER: I can't answer that. I think it was 9 broader, but it may have.

10 COMMISSIONER ASSELSTINE: I guess what I'm wondering 11 is if that was done a couple of years ago, why is it that

! 12 we're still finding those discrepancies now? Was it that 13 their program didn't work?

14 MR. KEPPLER: I don't know. I asked the question of 15 my people and my people tell me that up to date, accurate 16 drawings is a problem at all plants.

4 17 COMMISSIONER ROBERTS: Of course they are. It's a 18 terribly difficult thing to do. And they're never going to be

19 100 percent accurate. You strive for that.

! 20 MR. KEPPLER: And we haven't insisted on that. What 21 we've insisted on is that the total design documents that 22 relate to the as-built construction are consistent with the 23 design of the plant and the analysis that was done.

24 MR. NORELIUS: Apparently sometimes these things go 25 in parallel. You have a basic design document that's used

4 .i 4 41  ;

O  !

1 to do the analysis and that goes'one direction, and some of

. 2 the papersork goes off in another direction for final l

3 drafting, and this causes some of the problems when there are 4 then drafting errors and they turn up different than what was 5 used in the analysis.

6 COMMISSIONER ROBERTS: And how many as-built

, 7 drawings are there for this plant?

8 MR. KEPPLER: I have no idea.

9 MR. NORELIUS: Thousands.

10 '

CHAIRMAN ZECH: All right, so what is your 11 conclusion again, then?

12 MR. NORELIUS: Our conclusion on this is that there 13 are no matters outstanding or that we found during looking 14 into this allegation that represented a safety significant ,

15 problem for us.

16 CHAIRMAN ZECH: Fine. Proceed.

17 [ Slide.]

18 We'd like to talk a little about operational 19 experience, and as you suggested early on, I think in looking 20 at and considering a license for Unit 2 you have to look at l 21 the Unit 1 experience.

22 As has been mentioned before, the Byron Unit 1 plant 23 had a considerable number of problems in its startup. In 24 1985, its first year of operation, they had 24 unplanned l 25 reactor trips, 36 ESF actuations, 102 licensee event reports.

t

e 42 1 These are extremely high numbers. And when we did our SALP 2 prior to this one for the November '84 to November '85 time 3 period, we issued Category 3 ratings for operations, 4 radiological controls, surveillance and security.

5 We initiated some monthly meetings with the company 6 to try to define the problems areas, begin a system for 7 tracking and monitoring those to see if performance was 8 actually improving. And the Licensee initiated a conduct of 9 operations improvement program in the middle of 1985. They 10 began to develop a monthly report to track and monitor things, 11 they tried to improve communications, had additional shift 12 oversight attention around the clock at the plant, greater 13 interaction between the various organizations on plant, 14 controls to improve their surveillance program, improved 15 housekeeping, tracked LCO conditions. So they did a number of 16 things to begin to improve performance.

17 They also had some other problems that came up 18 periodically; the area of health physics, there were problems 19 there. We issued an escalated enforcement action on that 20 because of those problems. They then incorporated a health 21 physics improvement program as part of their conduct of 22 operations improvement program.

23 A similar story in security. They had some 24 stumbling that they went through there. They developed a 25 special improvement program for the security area.

i 43 1 And then this last summer, they had a problem in the 2 maintenance program. They had a code safety valve that was 3 taken out for maintenance. Part of the internal disc was 4 removed, it got mixed up with another valve and re-installed 5 with the internals removed.

6 COMMISSIONER ASSELSTINE: They weren't in at all?

7 MR. NORELIUS: Right, the disc was removed. They 8 did not have the one they were working on properly segregated 9 from others, they got mixed up, and they re-installed one 10 without having fully repaired it. We took an escalated

! 11 enforcement action on that particular issue.

12 The good news --

13 CHAIRMAN ZECH: How was it discovered?

14 MR. NORELIUS

The utility discovered that when it 4 15 would not --

! 16 COMMISSIONER ASSELSTINE: It didn't work.

17 MR. NORELIUS: It didn't work, yes. It started to 18 come up, it didn't work.

19 The utility did take prompt action on that l

! 20 particular one and developed their own maintenance improvement 21 program before we even had a chance to talk with them about 22 it. They requested an INPO assist visit. They developed a 23 group of corporate and other plant people to come look at 24 their maintenance program, and we were rather pleased with the 25 promptness and completeness of their actions in developing the

44 1 maintenance improvement program. ,

2 So all the areas that you see listed there they had l l

3 some problems in and developed programs to improve. And our 4 view is that they have improved their performance in each of 5 those areas. We just finished the last SALP, as the company 6 indicated, and we raised the rating from the Category 3 7 ratings in those four areas to 2 in all four areas because of 8 substantial improvement that we noted in all of their 9 operating areas.

10 Just to give you a view on improvements that have 11 occurred in Unit 1, I brought another slide that I would like 12 to put on.

13 (Slide.]

i 14 It's not in your package but this is Unit 1 15 experience, and the blue indications are licensee event I

16 reports, the red are reactor trips for Unit 1, and it's by the 17 quarter starting the first quarter in '85 through the last i

18 quarter in '86. And I believe you can see from that that 19 there has been a continuing trend that has come down and that 20 Unit 1 has improved in its number of reactor trips and also in 21 the licensee event reports over those past two years.

i 22 CHAIRMAN ZECH: I'd note, too, that there was a lot i 23 of room for improvement.

24 MR. NORELIUS: That's correct. Currently, Byron 25 Unit 1 is now in its 119th day of continuous operation, so l . .. - . - . - - - - - - - - - . - . - - . . . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

45 l o -

1 they seem to have picked up the latter end of this.

2 COMMISSIONER ASSELSTINE: Is that their best run so 3 far?

l 4 MR. NORELIUS: Yes.

5 [ Slide.]

6 Next I wanted to talk a little about a comparison of 7 Unit 1 versus Unit 2. This is also in addition to what we 8 gave to you in your slides. The numbers in red are Unit 1 9 numbers for the various mode changes, and this is the number 10 of event reports that they had going from the various modes, 11 and the number in blue'are the Unit 2 changes. And I believe 12 that this demonstrates that they did learn from their Unit 1 13 experience, and the licensee event reports are dramatically 14 lower for Unit 2.

l 15 (Slide.)

16 This will give you a graphic on the ESF actuations i 17 which shows essentially the same type of difference from Unit l

l 18 1 to Unit 2. And I think that demonstrates again that they i

19 have learned considerably in going from Unit 1 to Unit 2, so 20 we are pleased with those results.

21 COMMISSIONER BERNTHAL: Is this all attributable to 22 -- I'm sure it's not, -- but to human error, or was there a .

23 major portion of this that was hardware difficulties going on 24 the one path and those problems apparently not appearing on 25 the second?

. ._ . . _ _ _ ~ _ _

46 1 MR. NORELIUS: I think it's some of each. I don't 2 know what the breakdown is, but they have taken the lessons 3 that they learned from Unit 1 to Unit 2 I believe both in the 4

4 area of construction, testing and operations.

5 MR. KEPPLER: That big column on the left, a lot of 6 that was the nuclear instrumentation problems that they had 7 initially with Unit 1.

8 COMMISSIONER ASSELSTINE: How about trips, by the 9 way. Do you have one on trips? .

10 MR. NORELIUS: They've had two trips, and I will 11 ' talk about those.

12 (Slide.]

13 The next item that I had there was staffing. I 14 believe that has pretty much been covered by the utility so I 15 won't spend anymore time on that.

16 In terms of events, they have had two reactor trips; 17 one was a manual actuation by the operator when they were 18 first pulling rods. He found a difference between the 19 indication of one rod versus -- the demand position was 20 greater than what it should be and in our view took a 21 conservative action and manually tripped the plant.

22 CHAIRMAN ZECH: He did the right thing, didn't he?

23 MR. NORELIUS: Yes.

24 CHAIRMAN ZECH: Ought to give him a well done for l

25 that.

l - - _ - .. ... - --.-- -

47 1 MR. NORELIUS: The second one, they were doing 2 testing on an over-temperature, delta temperature loop logic.

3 They had one of the loops out to hook up some test apparatus 4 for startup and they had a failed resistance thermometer on 5 the second one which gave them the two out of four logic and 6 they tripped the plant.

7 CHAIRMAN ZECH: Manually tripped it?

8 MR. NORELIUS: No, that was an automatic.

9 The only other event that they've had of 10 significance is that they isolated the safety injection 11 system. This is a fairly significant event. They had one of 12 the pumps isolated for maintenance and they made an error in 13 reviewing that and in logging where they were on one of their 14 check sheets, so when they went from Mode 4 to Mode 3 they 15 violated the procedure. They were not supposed to have one of 16 those trains out at that time.

17 Subsequently, they isolated the other pump to fill 18 the accumulators. They discovered that themselves within 19 about 50 minutes of isolating the second pump, but obviously 20 for a time they did not have the safety injection system.

21 Considering the status of the plant it was not a safety 22 significant item but it is not the kind of error we would like 23 to see.

24 COMMISSIONER ASSELSTINE: Didn't they have the first 25 pump tagged out?

48 l, 1 MR. NORELIUS: They did, and they missed it on the 2 check sheet. As I understand, the individual who reviewed it l 3 just signed on the wrong line, got one line down in signing, 4 so he indicated that all the out-of-service tags were 5 satisfied when they were not. And somebody else reviewed it 6 and his initials were on that line. He knew -- he just missed l

7 it when he wrote it in the log, apparently. '

8 COMMISSIONER ASSELSTINE: But to isolate the second 9 train don't you have to isolate it from the boards? In which 10 case you can turn off the second -- isolate the second pump 1

1 11 right next to where the tag is hanging off the first one?

12 MR. NORELIUS: That may be. I would maybe ask 1 13 Julian or Bill.

14 MR. HINES: My name is Julian Hines, the senior 15 resident inspector at Byron Station. In this case, there are 16 no master tag-outs on the board for these pumps or valves, and 17 we experienced a loss of accumulator level and the isolation 18 of the second pump occurred in filling that accumulator. So 19 it was a combination of the error on the part of the 20 individual in signing off the wrong line and the filling of 21 the accumulator which isolated the second pump. But there's 22 no indication on the board of the tag.

23 COMMISSIONER ASSELSTINE: Is that a weakness in 24 their tagging procedure? Why wouldn't you want those things 25 tagged right on the board so that --

+

49 1 MR. HINES: We don't have any indicator for them on 2 the board. l 3 COMMISSIONER ASSELSTINE: Oh, okay.

I 4 MR. STELLO: I think there was a question on '

5 exemptions. Len will describe the one exemption outstanding, 6 and then we'll answer the question of Commissioner Bernthal's 7 if you really want to, if there is a difference. Perhaps 8 Marty can spend 30 seconds quickly.

9 MR. OLSHAN: The one exemption we are granting is to 10 the Appendix J requirement to test the air lock door seals 11 after each opening. This exemption has been granted on almost 12 every plant.

13 CHAIRMAN ZECH: Do you want to give us a brief 14 description?

15 MR. MALSCH: We could; it's just a small 16 difference. Ordinarily when people talk about exemptions they 17 talk about exemptions from requirements and regulations.

18 That's the normal nomenclature. A tech spec change would just 19 be a special kind of tech spec that would be a replacement of 20 another kind of tech spec. It's a kind of order.

21 MR. STELLO: Which we issue at the time of the 22 license.

23 MR. MALSCH: Right.

24 CHAIRMAN ZECH: And it's a normal procedure.

~

25 Routine procedure.

50 1 MR. MALSCH: A normal kind of thing.

2 CHAIRMAN ZECH: All right.

3 MR. STELLO: We are through and are satisfied that 4 all the requirements for issuance of a full power license have 5 been met. We did indicate we wanted to come back and answer 6 that general question that Commissioner Asselstine raised and 7 if we can we'll do that now.

g 8 CHAIRMAN ZECH: Yes, go ahead, please.

9 MR. KEPPLER: I think the Commission is aware that 10 on more than one occasion I questioned the effectiveness of 11 C::monwealth Edison's management structure for dealing with 12 the large number of plants that they have, the large program 13 that they have.

14 Commonwealth's performance over the years has been 15 checkered, spotty, and it is today to some degree. We talked 16 about the Byron plant today. I'm very pleased with the Byron 17 plant right now. Its performance is exemplary. I think at 18 LaSalle, we're seeing signs of improvement right now. Their 19 startup program for both Units 1 and 2 late last year, they 20 instituted an error-free startup program that was impressive.

21 But I think if you look at the total history of 22 LaSalle, I want to see more good months of operation before 23 I'm ready to say I'm satisfied there.

24 Quad cities plant, their performance has generally 25 been quite good. On the other hand, Zion is on a declining

51 i 1 trend right now, and I think that Dresden I would characterize 2 as somewhat average, at best. Mr. Reed mentioned that none of

-3 the plants received a Category 3 rating, but I will tell you i

4 that the operations category at Dresden was a marginal one.

5 It was one that was discussed and we wound up with a 2 but it 6 was a close call.

7 A year ago October when the regional administrators

] 8 met with the Commission I expressed considerable 9 disappo.intment over the performance of LaSalle and Byron 1 10 with you at that time. Commonwealth initiated a number of 11 actions, some of which were described to you today. They 12 created two division vice president positions, one to follow 13 Byron and LaSalle and Braidwood and the second one to follow 14 Dresden, Quad Cities and Zion.

15 And another key change they made was to strengthen I 16 the plant manager's position, and in effect, underneath him, I

17 created two levels of management, one for operations and one l

18 basically for technical support.

i l 19 We're beginning to 990 progress, and I think that's 20 most evident in the Byron situation, and LaSalle most 21 recently. And I guess one other point I would tell you.

22 Frankly, the adverse publicity that was associated with I

! 23 Commonwealth being -- with the LaSalle plant being i

24 characterized as one of the poorer performing plants had a big 25 impact on the company. The company's attitude is very strong l

52 1 right now not to have another plant identified that way.

2 I'm personally convinced that commonwealth is i 3 working harder today, more than ever before, to improve the 4 excellence of their programs. I think they've got a ways to 5 go. But I would give you one signal of why I feel the way I 6 do, and that is the declining trend with Zion.

7 Mr. Reed mentioned that they were in to see us 8 earlier this week on Monday. They laid out a very 9 , comprehensive program for dealing with the concerns. They 1

J 10 first of all identified the root cause problems, and they laid 11 out a rather comprehensive program for dealing with it. And 12 if you had to go back two to three years ago, that wouldn't 13 have happened. I would have had to call them in, I would have 14 had to convince them first of all there was a problem, then 15 we'd argue about that and then we'd get on to programs of 16 corrective action. And I think today it's pleasing to me to 17 see them take the initiative and move ahead without having to 18 be told.

y j 19 I don't have any reservations about licensing Byron-20 2. I think that the information with respect to the plant i

21 speaks for itself. I'd say I'm cautiously optimistic about 22 Commonwealth's efforts and I think the commission has to 4

23 realize that we confronted the issues at LaSalle and Byron I 24 think head on, we didn't wait to have something happen. I I

25 think we have accomplished something there, I think the

53 1 utility has accomplished something there, and the region is 2 going to continue to follow the efforts until we're satisfied 3 that they've upgraded their total operations. So that's how I 4 would characterize it in summary.

5 MR. STELLO: We're through.

, l 6 CHAIRMAN ZECH: Did you give your conclusion? I 7 guess you did. Give it again. ,

8 (Slide.)

9 MR. STELLO: I said what that slide says.

10 CHAIRMAN ZECH: What does it say?

11 MR. STELLO: The staff concludes that the Licensee 12 has satisfied all the requiremeur.s for issuance of a full 13 power license for Byron Station Unit 2.

14 CHAIRMAN ZECH: Thank you very much. Questions from 15 my fellow Commissioners? Commissioner Roberts? Commissioner 16 Asselstine?

17 COMMISSIONER ASSELSTINE: A few. Let me start with 18 a general discussion first. Jim, to what extent do you think 19 the problems that Commonwealth has had over the years can be 20 attributed to some individual problems at individual stations 21 that simply didn't get corrected, as opposed to weaknesses in 22 the management structure or the nuclear program?

23 MR. KEPPLER: I think it's a combination. One of 24 the things that I w6uld state in my view anyway as an 25 across-the-board management problem is that all six stations

l 54 i +

l 1 are allowed to operate somewhat independent of each other.

2 You can find one practice at one site and you can find a 3 different practice at another site. And I think in terms of 4 learning and applying lessons learned to each site, I think 5 that's a shortcoming. I think they've done better this way 6 but I believe they still have a ways to go.

7 COMMISSIONER BERNTHAL: Excuse me. When we identify 8 local autonomy, if I may use that word, as a possible problem, 9 it always bothers me a little bit because I've heard that 10 cited in previous times at one utility or another as a 11 solution to a problem; that you've got to give that local 12 station manager more authority and let him run the place.

13 Especially in a large organization, not have all decisions 14 having to funnel through some huge corporate headquarters 15 which in cases I could name have been compared to government 16 bureaucracies -- about the worst comparison you could make, I 17 suppose.

18 Are we convinced that we know that one is better 19 than the other, Jim? I'm not questioning your judgment here, 20 but isn't it true that you can make it work either way? Now, 21 if it's not working very well in this case, how come? I guess 22 that's the question I would like to know because it's clear 23 that in some other cases that local autonomy has been 24 suggested a's the management solution to a problem.

25 MR. KEPPLER: It may be, and I don't disagree that

55 .

1 it can work both ways. But I think there is something 2 fundamentally wrong when you have problems start out at one 3 site and repeat themselves at the next site.

I 4 COMMISSIONER BERNTHAL: I agree, I agree.

5 MR. KEPPLER: Now, what is wrong I'm not smart 6 enough to say.

7 MR. TAYLOR: I might say that I believe there is 8 some balance. I think our experience shows that in large 9 utilities, larger or large utilities, that if the corporate 10 doesn't set that overall tone and try to get practices the 11 same, even though the guy has plenty of autonomy to operate to 12 make the day-to-day decisions, then you suffer. And I think l 13 we see some of that in the TVA examples. And we see many 14 things in engineering and design control and that type of 15 thing where too much was given to the sites. Too much 16 individual autonomy and they lost control of what they were l

17 doing. In fact, we issued orders on that subject.

18 So there's a balance with particularly large outfits 19 where the central setting of what is required, how to control 20 that process, is very important. There's no question that the 21 autonomy to operate the station to make those day-to-day 22 decisions is important, too. So I think it's a balance.

23 MR. KEPPLER: One thing I would add. I was somewhat 24 pe'ssimistic when they created these two division vice 25 president positions. I wasn't convinced in my own mind that

+

56 1 that was the answer, but I agreed to give it time to see. And 2 I think the chapter is still out on this yet.

3 But I do believe that one of the things they are 4 getting is a sense of greater uniformity through this 5 procese. I particularly see that with LaSalle, Byron and 6 Braidwood right now.

7 COMMISSIONER ASSELSTINE: What has the enforcement 8 history been with Commonwealth, look back, say, over the last 9 five years.

10 MR. KEPPLER: Lousy.

11 COMMISSIONER ASSELSTINE: Civil penalties, how many 12 have been imposed and how would it rack up against other 13 utilities?

14 MR. KEPPLER: I think they've probably had more 15 fines than any utility. Of course, they've got more plants.

16 MR. TAYLOR: I had just a few minutes to push the 17 computer button before I came down, I could give you a l

l 18 printout. I think I'd have to do a little more analysis. Jim 19 is right, there's been a distribution of fines. I think I

l 20 Cordell Reed mentioned that some of their history has improved l 21 at some of the stations. So I'm really not prepared. I can 22 give you some followup.

23 MR. STELLO: Why don't we just send to the l

l 24 Commission a copy of their history.

25 COMMISSIONER ASSELSTINE: Sure, that would be fine, l

57 1 although Jim I suppose could give us an assessment for Region 2 III.

1 3 MR. STELLO: Could you do it off the top of your 4 head?

5 MR. KEPPLER: Yes. I would say I think three years 6 ago, 1983, 10 civil penalties against Commonwealth plants at 7 that time, which was -- ,

8 COMMISSIONER ASSELSTINE: Kind of a record other 9 than maybe'TVA.

10 COMMISSIONER ROBERTS: For how many plants?

11 MR. KEPPLER: That would have been for four sites.

12 COMMISSIONER ROBERTS: Four sites, how many 13 stations?

14 MR. KEPPLER: Eight. And I think that we still have 15 had, in my judgment, I would say the enforcement history has 16 been above average there in terms of too many.

17 COMMISSIONER ASSELSTINE: In terms of numbers, 18 right.

19 MR. KEPPLER: On the other hand, I think Mr. Reed 20 did characterize that several of the sites have gone now 21 without civil penalties over the last two years and that's an 22 improving trend.

23 COMMISSIONER ASSELSTINE: Okay. I think that covers 24 my general ones. I've got some more specifics.

25 One, does the staff have a view on the need for or

. 58 1 usefulness of having a plant reference simulator at Byron?

d 2 MR. VOLLMER: Yes, we do. Bruce Boger, do you want W

i' 3 to address that?

4 MR. BOGER: I am Bruce Boger from the staff.

5 Basically right now, we don't see a need for two simulators, l 6 The plants are identical enough with respect to procedures and 7 tech specs that we ,can conduct examinations on both. And j 8 we're satisfied that the training that the people are 9 receiving is adequate on the same simulator, just because of i 10 the nature of the two plants being so close.

l 11 COMMISSIONER ASSELSTINE: Okay. Is the number of 12 hours they get pretty comparable to other plants that have a

1. plant reference simulator at each plant?

1 14 MR. BOGER: I can't address that. The two weeks is 15 a typical industry timeframe for simulator training.

16 COMMISSIONER ASSELSTINE: When Byron 1 received its i

17 license we gave them an exemption from the requirement for j 18 having a full-scale emergency planning exercise within 12 i

! 19 months of having received the license. Can you tell me --

20 and with the idea that there was going to be at least a 21 partial exercise in June of '85. Can you tell me when the i

. 22 last full-scale exercise was and what the results were?

23 MR. VOLLMER: Yes, Paul Kanter of the staff will l 24 respond.

i 25 MR. KANTER: Paul Kanter of the Emergency

\

l

• 59 1 Preparedness Branch of the NRC Staff. The first full 2 participation exercise was November 15th, 1983. .They've had 3 another exercise which was observed by FEMA, I believe it was 4 either full or it might have had some lower state l 5 participation. That was June lith, 1985. And then they've 6 had a Licensee only exercise in May of 1986. We have received 7 FEMA lette,rs on each of the first two exercise indicating that 8 performance was satisfactory with no significant deficiencies.

9 COMMISSIONER ASSELSTINE: Now, the June of '85 one, 10 that's the one that I thought, at least in terms of the SER 11 supplement 6, that that one was listed as a partial exercise.

12 Have they not had a full one since '83?

13 MR. KANTER: If that is correct, they have not then 14 had a totally full exercise -- I think the partial applied to 15 the state of Illinois participation in '85, and the state of 16 Illinois has participated in many exercises at other plants.

17 COMMISSIONER ASSELSTINE: Oh, okay, fair enough.

18 But it did have full local participation.

19 MR. KANTER: Yes, sir.

20 MR. KEPPLER: Commissioner, one comment on that, 1

21 just expanding the subject of emergency preparedness. You've 22 probably noted that we rated them a Category 1 SALP in that i 23 area. But we hold up the Byron plant as the best plant in the 24 region for emergency preparedness, barring none.

1 25 COMMISSIONER ASSELSTINE: Onsite and offsite?

1 I

n

, . L 60 a  ;

1 MR. KEPPLER: Both. ,

- C.,

'm s s) 2 COMMISSIONER ASSELSTINE: Okay, very good.*'

3 On the license, Attachment 1,'the,ECCS leakage O.

4 issue. Could you give me a few c,omments on'that, the staff's 5 view on the -- why is it leaking'and what's the staff's

! 6 assessment?  ; [' ~

7 MR. VOLIMER: Areyoutalki[tgabouttheexception 8 which allowed -- - -

9 COMMISSIONER ASSELSTINE: Not the air lock, but Is -

_. s s 10 think I'm focusing on Attachment 1 -- the aux building.

11 MR. VOLIMER: The tech specs require some s -

12 demonstration that all compartments within the aux building s 13 havethesequarter-inch,watergaugenegativehressure.

14 Because of the turnover and the diificulty of getting'this

• 1 ,

done in a timely fashion, the basis for that,is that'they have 15 s

16 to demonstrate somehow that they" meet GDC-19 requirements for 1 -

17 operator doses in the minimum accident. '

t 18 Another way to do that uould be to assure that 19 subject to demonstration of that, that the leakage within the 20 building is kept at low levelt - So'that's a trade-off which 21 the staff feels gives equivalent safety in> allowing them to 22 defer meeting the tech spec requirement, s rveillance 23 requirement, until a more proper time,, of time when they can do 24 a better job of it. And they're trading that off with 25 assurance that the leakage will be kept low.

. 61 1 COMMISSIONER ASSELSTINE: All right. So you're 2 satisfied with the compensating measures to ensure that, in 3 fact, the leakage will be low until they can get everything 4 fixed up and do the complete test.

5 MR. VOLLMER: That's right.

6 COMMISSIONER ASSELSTINE: Okay. The draft license, 7 page 1-4, there's a note about the remote shutdown capability, 8 that that item was closed out in Supplement 7 for Unit 2. Is 9 there going to be a test of the remote shutdown capability for 10 Unit 1?

11 MR. OLSHAN: You're referring to the draft SER, 12 aren't you?

13 COMMISSIONER ASSELSTINE: This is the draft license, 14 page 1-4. No, I'm sorry, it is SER-8.

4 15 MR. OLSHAN: The remote shutdown capability test has 16 to be done above 10 percent power and it will be done for Uqit 17 2, yes.

18 COMMISSIONER ASSELSTINE: Supplement 5 to the SER, 19 page 5-4, you talk about the RHR system and you talk about the 20 Licensee's commitment on the natural circulation test but you 21 don't say what the commitment was. What was the commitment 22 and will they be doing a natural circulation test?

23 MR. OLSHAN: The commitment they made in the 24 original FSAR was to do the natural circulation test at the 25 end of the first -- start it from the first refueling of Byron

. 62 1 Unit I depending on the results of the Diablo Canyon natural 2 circulation tests. At present, we've reviewed the results of 3 the Diablo Canyon natural circulation test, and I understand 4 the safety evaluation is due out in the next month.

5 That safety evaluation will relieve Byron of having 6 to do the natural circulation test on their plant. The plants  !

7 are similar enough so the results would apply.

8 COMMISSIONER ASSELSTINE: Is Diablo the only plant 9 that's done one of these? I seem to recall we had the same 10 thing on Shearon Harris.

11 MR. OLSHAN: I think most everybody is tying onto 12 the Diablo Canyon results.

13 COMMISSIONER ASSELSTINE: The plants are really that 14 similar that you can do a natural circulation test on Diablo j 15 Canyon and have confidence that that applies for virtually all

16 of the Westinghouse four-loop plants?

17 MR. ROSSI: This is Ernie Rossi of the staff. One 18 of the things that each particular licensee has to do if they i

19 use the Diablo Canyon test is to come in and justify the fact 20 that their plant is enough similar to the Diablo Canyon plant 21 in those areas that affect natural circulation to be able to j

22 use the Diablo Canyon test. And recognize the fact that the 23 things that are important are heights of equipment and that 24 kind of thing, which in general are very similar among all the 25 Westinghouse plants.

r .,-w, -,=----m

, ----,.e , --, , , - - , - , , - - - , - - - , , , - - . . , - - . , - - - , . , - - - , - - -,._--,-v- - - - - , - - - - - e-- - , ne- , - - . , -- - - ,,

. 63 o

1 COMMISSIONER ASSELSTINE: And on page 15-2 also of 2 Supplement 5 you talk about the analysis of steam generator 3 tube failure and you talk about resolving the issue. And I 4 guess what I'm wondering is how was it resolved for Byron?

, 5 MR. VOLLMER: Well, they committed to certain 6 items. You might recall on Shearon Harris, that was a tech 7 spec condition I believe and it could have gone either way. I 8 raised that issus when I looked over this license, too, and we 9 felt that the commitment that they had made was perfectly 10- adequate to resolve that issue and we will wait for the 11 results that they will get from Westinghouse, and if further 12 action needs to be taken we'll do it.

! 13 COMMISSIONER ASSELSTINE: Okay. So the supplement 14 basically said it was all going to be done by May '85 and I i

i 15 take it it is not done yet. Sama problems.

16 MR. OLSHAN: The Westinghouse Owners Group has 17 submitted their topical report. That's the May '85. After we 18 issue our safety evaluation there may be some plant-specific 19 concerns that have to be addressed. That's what is left open.

l 20 COMMISSIONER ASSELSTINE: Okay. So I guess it's 21 more of a generic comment than something focusing on just this 22 plant, but it does seem like issues like that drag on for an 23 awfully long time. That one has been kicking around now for 24 several years and I think we ought to get to the bottom of it l

l 25 and get it settled one way or the other fairly soon.

l l

i

64 e

1 I had a question also on pipe supports and whip 2 restraints. I gather that this plant has had an effort to 3 eliminate some of the pipe whip restraints, and I guess I'd bo l 4 interested in your reaction to the December 17th ACRS letter 5 that raises concern in particular about pipe supports. It 6 basically says we shouldn't be authorizing anymore of these 7 removals of pipe supports until their concerns have been 8 satisfied. To what extent does that concern apply to this 9 plant, and to what extent does it apply to the removal of the 10 whip restraints as well as the supports?

11 MR. VOLLMER: This plant was given a schedular 12 exemption to allow them to come within the limited scope rule, 13 GDC-4, which is now an effective rule. So actually, the 14 exemption it turns out was not needed. But that only applied 15 to the primary system, only applied to those things that would 16 be needed to dynamically restrain a pipe in the event you had 17 a major break. That is, the type pipe whip restraints in the 18 jet impingement fields, and the ACRS comments were focusing on 19 component supports, and that issue is something the staff is 20 looking at now; it really has no effect on this particular 21 plant.

22 COMMISSIONER ASSELSTINE: Okay.

23 MR. VOLLMER: The broad scope rule it will have 24 effect on, and we will deal with that in that issue, but not 25 at this plant.

65 1

1 COMMISSIONER ASSELSTINE: So the things they're 2 doing, the relief they've been given so far --

) 3 MR. VOLLMER: The relief they've been given is not 4 affected by these comments, yes.

5 COMMISSIONER ASSELSTINE: Okay. On supplement 7 to 6 the SER there's a discussion on page 6-3 of the in-service 7 inspection program, and I guess the Licensee was given a -

8 period of time after the issuance of the operating license for 9 Unit 1 to submit their in-service inspection program. Have 10 they done that, and is the ISI program now set for both units?

11 MR. OLSHAN: Yes. They have submitted it on Unit '

12 1. Our review is not completed yet on Unit 1.

13 COMMISSIONER ASSELSTINE: Okay. Is that typical 14 that a couple of years after the issuance of the license you 15 are still arguing about what the elements of the in-service 16 inspection program will be?

17 }Gt. VOLLMER: I can answer that. It unfortunately 4

18 is typical, although the in-service inspection program is not 19 something that -- you know, it covers a fair period of time.

20 typically, ASME would give you 10 years to go through the 21 plant. But it is something that the staff is not always 22 finished with at the time of licensing.

23 COMMISSIONER ASSELSTINE: Are there any things in I

! 24 this first outage that would be affected by that, or is the 25 longer-term, the 10-year requirements that we're talking

s 66 D

1 about?

2 MR. VOLLMER: I'd ask Ted Sullivan if he might want 3 to comment on that.

4 MR. SULLIVAN: My name is Ted Sullivan. The program 5 for Unit 1 has been submitted, is that right? And it's under 6 review. When is the first outage scheduled?

7 MR. OLSHAN: The first outage starts in two weeks.

8 MR. SULLIVAN: I just wanted to know that.

9 Typically, there are a number of relief requests 10 that are included in these programs, and if for some reason we 11 should deny any of these relief requests there's plenty of 12 time within this program to catch up on any inspections that 13 would be required as a result of our denials. So it wouldn't 14 see any impact due to the fact that our review of this program 15 isn't quite finished yet.

16 COMMISSIONER ASSELSTINE: Are there inspections, 17 though, that cover like the first refueling outage?

18 MR. SULLIVAN: Yes, there are.

19 COMMISSIONER ASSELSTINE: Just as a general comment 20 again, it strikes me that it would be better to get those 21 items settled before two weeks before the start of the first 22 refueling outage rather than to be in the position of saying 23 well, obviously you're not going to make it now, we'll just 24 have to catch those up in future years.

25 MR. OLSHAN: No actually, our reviewers are aware of

67 1 the refueling outage coming up and I've looked at the program 2 in that light, to see if there are any things that stick out 3 that are not acceptable for this first refueling.

4 MR. VOLLMER: Typically, the reason for exemptions 5 are such things as impossible to get at something to inspect 6 it or the techniques don't cover pipes with such tight 7 curvatures and things like that, and those must be looked at 8 but often are routinely granted because there is good reason 9 for the exemption.

10 COMMISSIONER ASSELSTINE: Back to the remote 11 shutdown capability test. I gather the Licensee's position 12 had been they didn't need to do a test for Unit 2 because they 13 had done one for Unit 1. You rej ected that in SSER-7. Are 14 you satisfied that now there's no question but that they're 15 going to have to do it? You did put that in as a license 16 condition, I notice.

17 MR. OLSHAN: Yes.

18 COMMISSIONER ASSELSTINE: But I take it that it's 19 still in the FSAR.

20 MR. OLSHAN: It's still in the FSAR and they were 21 trying to exempt themselves from the FSAR requirement. We 22 turned it down, so they realize and the region realizes they 23 will have to conduct that test.

24 COMMISSIONER ASSELSTINE: Okay. I guess the last 25 question I have has to do with Appendix K to Supplement 7

68 I which talks about an evaluation of the Applicant's pre-service 2 inspection relief request. I guess the question I have is why 3 was that relief necessary, from the pre-service inspection 4 requirements?

5 MR. VOLLMER: Well, relief -- it sort of goes along 6 with what I just said before. They have to give proposed 7 alternatives, acceptable levels of safety and so on. But the 8 general reason for granting these is the pre-service 9 inspection sometimes can't be done.

10 Now if you're talking about finding of code defects 11 through the pre-service inspection program that were not 12 identified in the shop when the thing was constructed, then 13 you go through an evaluation (a) of the acceptability and (b) 14 whether or not you're better off trying to repair that in the 15 field or accept it as is when you go through fatigue analysis 16 and whatever is required. Often the decision is made that you 17 don't want to follow around with it, it's better off the way 18 it is.

19 And so the staff does look at all those.

20 COMMISSIONER ASSELSTINE: Okay, good. That's all 21 the specific questions I have. Maybe after the question 22 session I'll make a few comments at the time we vote.

23 CHAIRMAN ZECH: All right. Let me just make a few 24 general comments, mostly I guess to the utility. But I l

l 25 visited the Byron Station three times now. The first two l

69 1 visits focused on Byron 1. My assessment was that, of course, 2 the plant was adequate but I was rather disappointed in Byron 3 1 in the rather slow process of getting a hold of their 4 operational experience.

5 My third visit, though, recently focused mainly on 6 Byron 2 in which I did have a chance to review the Byron 1 7 performance and was certainly encouraging. And as noted from 8 the slides, it showed the improvement of Byron 1. Much 9 improved plant condition as well as attitude of the people. I 10 was impressed with what I saw. Byron 1 I think has indeed 11 contributed to the rather excellent performance of the Byron 2 12 unit, which has certainly been smooth as we have seen 13 characterized here today.

14 But the attitude and experience and pride that I saw 15 was certainly encouraging, and I think that it would lead me 16 to believe that all the Commonwealth plants can perform and 17 should perform as the Byron units are performing.

18 If we do authorize the plants to go to higher power 19 levels, it is certainly I think a challenge for the Byron 20 Station to take on the first refueling outage at Unit 1 at the 21 same time you're going into the power ascension phase for Unit 22 2. I think that is recognized as a challenge but it truly is 23 a challenge.

24 All I would say is be slow, cautious, take your time

, 25 and do it safely. Even though the plant and units and the l

70 1 people look like they're performing well and improving all the 2 time, it is a transition, in a way, from construction to 3 operation still. We've seen that time and again across the 4 country where it's not an easy transition. So even as well as 5 Byron Station is doing, I would caution a careful refueling 6 for Unit 1 and a careful and deliberate power ascension for 7 Unit 2. -

8 Commissioner Asselstine, you h'ad some comments to 9 make?

10 COMMISSIONER ASSELSTINE: Mine are very much along 11 the same lines as yours, Lando, and I think they're directed 12 more to the company than anybody else. I think when I looked 13 back over the performance of the Commonwealth system over the 14 past four and a half or five years, I see a company that all 15 too often I think has been sort of struggling in some 16 instances or striving for average performance and sometimes 17 not achieving that. I am pleased with what has happened at 18 Byron 1 over the past year or so and very pleased with what I 19 see so far in the performance of Byron 2, as I think you are.

20 And I think on the basis of that and on the basis of 21 Mr. Keppler's comments and the company's response to my 22 broader concerns, I'm going to go with Byron 2.

23 But I really am still concerned about the overall 24 performance of the system. I think there's a history of 25 enforcement performance here that has not been what we have a 1

71 1 right to expect. It's getting better and it seems to be 2 moving in the right direction but over the past five years or 3 so it's not what we have a right to expect and what we ought 4 to be comfortable with or what the company ought to be 5 comfortable with. And I think the downturn in performance at 6 Dresden and Zion is a real concern to me.

7 And I.would just say fair warning that before I act 8 on BraidWood 1, I intend to look very carefully at the 9 performance of the system to see whether the company really is 10 making real progress toward the goal that they have set for 11 themselves. It's the right goal, getting all of these plants 12 up to a level where they're in the top quarter of performance 13 at least, but I think that they are a long way from that. And 14 I really am concerned about adding to the burden of the system i 15 with, to some extent, kind of ambiguous indicators on the 16 overall performance of the system.

17 I am pleased with Byron and I think Byron 2 is 18 moving in the right direction, and largely on the basis of I

l 19 that I go with it, but I'm going to take a real hard look at 20 the next few months and see whether there are real strong 21 signs of progress throughout the system.

22 CHAIRMAN ZECH: Any other final comment?

23 [No response.]

24 I would like to thank Commonwealth Edison and the 25 staff for their presentations today. Now I will ask if my

72 1 fellow Commissioners are ready to vote. If so, those 2 Commissioners in favor of proceeding to authorize the Director 3 of NRR to issue, after the staff makes the appropriate 4 findings, a full power operating license to Byron Unit 2, 5 please signify by saying aye.

6 COMMISSIONER ASSELSTINE: Aye.

7 .

COMMISSIONER BERNTHAL: Aye.

8 COMMISSIONER ROBERTS: Aye.

9 COMMISSIONER CARR: Aye.

10 CHAIRMAN ZECH: Aye.

11 Those opposed?

12 (No response.]

13 The vote is 5 to O to proceed. We are adjourned.

j 14 [Whereupon, at 4:55 p.m., the Commission meeting was 15 adjourned.]

16 17 18 19 20 21 22 23 24 25

1 .

2 REPORTER'S CERTIFICATE 3

4 This is to certify that the attached events of a 5

meeting of the U.S. Nuclear Regulatory Commission entitled:

6 7

TITLE OF MEETING: Discussion /Possible Vote on Full Power Operating License for Byron-2 (Public Meeting) 8 PLACE OF MEETING: Washington, D.C.

9 DATE OF MEETING: Friday, January 30, 1987 10 .

11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken

(' 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.

17 /'

18 L---

19

/ Suzaded'.You 20 21 22 Ann Riley & Associates, Ltd.

23

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24 25

COMMISSION BRIEFING ON THE l

FilLL POWER LTCENSTNG

~

0F BYRON STATION, UNIT ?

JANilARY 30, 1487 CONTACT:

L. OLSHAN X?4937 i

PRESET!TATION OllTLINE ,

RACKGR0llND PLANT DESIGh' STAFFING .

Th'SPECTION HISTORY CONCLUSION SLIDE 1

BACKGROIIND OWNER AND LICENSEE

- COMMONWEALTH EDISON COMPANY, 0WNER/0PERAT'0P 0F 4 OTHER OPERATING STATIONS BYRON 1 OPERATION COMMERCIAL OPERATION - SEPTEMBER 1985 IINIT AVAILABILITY - 78%

GENERAL Pl. ANT DESIGN WESTINGH011SE 4 LOOP PWP ARCHITECT /ENGl.EER:

N SARGENT a LijNDY GENERAL CONTRACTOR: COMMONWEALTH EDISON SITE LOCATION: NORTHERN ILLIN0IS, 0GLE C0llNTY POPULATION ( 1980)

NEAREST TOWN: BYPON, ILLINDIS POPlllATInh!: 7,037 NEAPEST POPillATION CENTER: ROCKFORD, TLLIN0lS (17 MILES)

POPillATION: 139,211 SLIDE ?

PLANT DESIGN NSSS CHARACTEPISTICS RATED POWER: 3411 MWT, 1120 MWF CONTAINMENT CHARACTEPISTICS STEEL-LINED RETNFORCED CONCRETE FREE VOLIJME: 2,700,000 -

• DilPLTCATE OF BYRON 1 (BRAIDWOOD 1, 2 ALSD Di!PLICATES)

SLTDE 3

o SHIFT STAFFING SHIFT ROTATION: 8 HOUP SHIFTS - 6 SHIFTS .

SHIFT COMPOSITION T/S REQUIREMENTS ACTUAL (BOTH UN!TS OPERATING) 1 SHIFT ENGINEER (SRO) 1 SHIFT FOREMAN (SRO) 1 2 SCRE (WITH DEGREE) ~ 1 1 CONTPOL OPERATOR (RO) 3 37 AUX, OPEPATOR (FON-LICENSED) 3 11 l

TnTAL I.ICENSED OPERATOPS: SRO: 41 P0: 30 slide 4

HISTORY 4

CONSTRUCTION ACTI"ITrES:

- CONSTRIJCTION APPPAISAL TEAM (CAT)

NON-DESTPilCTIVE EXAMINATIONS (NDE)

VAN, PRE-OPERATIONAL TESTING: .

LESSONS LEARNED FROM IINIT 1 ALLEGATIONS 43 CASE FILES i

NO SAFETY SIGNIFICANCE SLIDE 5

OPERATIONAL EXPERIENCE UNIT 1 EXPERIENCF:

IMPROVEMENT PROGRAMS:

nPERATIONS HEALTH PHYS!CS ,

SECllRTTY

. MAINTENANCE UNIT 1/IlNIT 9 COMPAPIS0N I STAFFING COMMON TO ROTH Ub'TTS UNTT 2 EVENTS l

PEACTOR TRIP SAFETY INJECTION ISOLATION SLTOE 6 l

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d CONClliSTON THE STAFF CONCLllDES THAT THE LICENSEE HAe SATISFIED ALL REQtiTREMENTS FOR ISSilANCE OF A FULL POWER LICENSE FOR BYRON STATION, llNIT 2 i

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1/30/87 SCHEDULING NOTES TITLE: DISCUSSION /POSSIBLE VOTE ON FULL POWER OPERATING LICENSE FOR BYRON-2 SCHEDULED: 2:00 P.M., FRIDAY, JANUARY 30, 1987 (OPEN)

DURATION: APPROX l-1/2 HRS PARTICIPANTS: LICENSEE 20 MINS

- C. REED, VICE PRESIDENT COMMONWEALTH EDISON COMPANY

- R. QUERIO BYRON STATION MANAGER NRR 10 MINS

- H. DENTON

- L. OLSHAN REGION III 10 MINS

- J. KEPPLER

- C. NORELIUS

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