ML20212R025

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Transcript of 870415 Briefing by Ofc of Special Projects in Washington,Dc.Pp 1-58.Viewgraphs Encl
ML20212R025
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Issue date: 04/15/1987
From:
NRC COMMISSION (OCM)
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References
REF-10CFR9.7 NUDOCS 8704240220
Download: ML20212R025 (73)


Text

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ORIGINAL

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

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Title:

Briefing by Office of Special Projects (Public Meeting)

Location: Washington, D. c5 Date:

Wednesday, April 15, 1987 ll Pages:

1 - 58 l

Ann Riley & Associates Court Reporters 1625 i Street, N.W., Suite 921 Washington, D.C. 20006 (202) 293-3950 l

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This is an unofficial transcript of a meeting of the 7

United States Nuclear Regulatory Commission held on s

4/15/87 in the Commission's office at 1717 H Street, 9

'N. tJ., (Jashington, D.C.

The meeting was open to public 10 attendance and observation.

This transcript has not been*

11 reviewed, corrected, or edited, and it may contain

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12 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 opinion in this transcript 17 do not necessarily reflect final determination or beliefs.

No 10 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.

1 22 23 24 25

o 1

1 UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

4 BRIEFING BY OFFICE OF SPECIAL PROJECTS 5

6 PUBLIC MEETING 7.

8 Nuclear Regulatory Commission 9

Room 1130 10 1717 H Street, Northwest 11 Washington, D.C.

12 13 Wednesday, April 15, 1987 14 15 The Commission met in open session, pursuant to 16 notice, at 10:03 o' clock a.m.,

the Honorable LANDO W. ZECH, 17 Chairman of the Commission, presiding.

18 COMMISSIONERS PRESENT:

19 LANDO W. ZECH, Chairman of the commission 20 THOMAS M. ROBERTS, Member of the Commission 21 JAMES K. ASSELSTINE, Member of the Commission 22 FREDERICK M.

BERNTHAL, Member of the Commission 23 24 25

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STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:

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2 J. Hoyle 3

W. Parler t

1 4

V. Stallo 5

K. Keppler i

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C. Grimes s

7 S. Ebneter.

8 J. Axelrad 10 l

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PR0CEEDINGS g.

2 CHAIRMAN ZECH:

Good morning, ladies and gentlemen.

3 Commissioner Carr will not be with us this morning.

The 4

purpose of today's meeting is for the office of Special 5

Projects to brief the Commission concerning the establishment 6

of the new office and to discuss its role and specifically to

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7*

discuss the status'of TVA's Sequoyah nuclear plant.

8 This new office of Special Projects was brought into 9

being by the NRC to provide a central NRC focus for management 10 responsibility and accountability of all aspects of the TVA f

11 and Comanche Peak projects.

12 We heard from Mr. Steven White of the Tennessee 13 Valley Authority several weeks ago concerning the status of 14 Sequoyah nuclear plant.

During the presentation this morning, 15 Mr. Keppler, I would you to specifically address your views on 16 the Sequoyah design control and verification issues if you are 4

17 ready to talk about that and perhaps some didcussion of your 1

18 views on the TVA schedule as you see it for Sequoyah.

19 I understand that copies of slides are available in 20 the rear of the room.

Do any of my fellow commissioners have 21 any opening comments?

22 (No response.)

23 CHAIRMAN ZECH:

If not, Mr. Stallo, you may proceed.

24 MR. STELLO:

I will let Mr. Keppler start in a f

25 moment.

What I wanted to do is to first indicate that the new 4

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1 office has now been working for about six weeks and I feel

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2 that it is moving crisply to takirg over and finding out what 4

3 the problems are associated with both the Comanche Peak and 4

the TVA facilities and I feel comfortable that we have a crisp 5

management function and decision making that is there and l

6 things are starting to fall into place, the obvious concern 7

being as we look to' restart of one of these facilities at TVA, 8.

there is still a great deal to be done and we want to be sure 9

that we don't become a critical path issue for the review.

10 But nevertheless, we have reminded TVA and I know 11 the commission has that don't just dump all that stuff on our, i

12 desk at the eleventh hour and we are going to do what we can r

13 to avoid that but the Commission needs to know that that is a i

14 big problem and we are concerned.

15 CHAIRMAN ZECH:

We are well aware of that, too.

16 COMMISSIONER BERNTHAL:

Mr. Chairman, I will make 17 one comment.

i 18 CHAIRMAN ZECH:

Certainly.

19 COMMISSIONER BERNTHAL:

We have a new office at this i

20 table for the first time and I wish I could take credit for 21 the idea but I can't.

I guess it was Mr. Stallo's idea.

I 22 note that Ms. Axelrad is now the deputy to Mr. Keppler and I 23 think those are two excellent appointments for the tough job 24 of Comanche Peak and TVA.

25 I don't know who takes credit -for that but in any

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case, it was a good idea and I congratulate you for it.

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2 MR. STELLO:

I won't take full credit.

Mr. Keppler 3

and I chatted about it during the reorganization.

He strongly 4

urged it, too.

5 COMMISSIONER ROBERTS:

Did he volunteer for the job?

i j

6

[ Laughter.)

7 MR. 'EEPPLER:

Let me answer that.

The answer is no.

8 MR. STELLO:

I need to be truthful.

The answer was 9

that he said that he would do it.

He did volunteer.

10 (Laughter.]

11 COMMISSIONER ROBERTS:

It is like volunteering in 12 the military.

13 MR. KEPPLER:

You have a strange memory, Vic.

l 14 (Laughter.)

j 15 CHAIRMAN ZECH:

I agree with Commissioner Bernthal 16 though and I am impressed frankly, I must say, with the 17 caliber of people that we have selected for this office.

I 18 think, Jim, you have not only a fine assistant in Ms. Axelrad 19 but you also have some very fine other people I have noticed.

20 You have a lot of talent.

I hope you put them to good use.

I 21 feel confident that you will but I do agree with Commissioner 22 Bernthal that I think it is the right decision to make 23 recognizing that we are giving you some very serious 9

24 responsibilities.

25 So I think, Mr. Stello, you may continue.

6 1

MR. STELLO:

Mr. Kappler is ready to begin.

i 2

CHAIRMAN ZECH:

All right.

Thank you.

3 (SLIDE.]

4 MR. KEPPLER:

Thank you.

Good morning.

As 5

Mr. Stello said, the Office of Special Projects has now been 6

in existence for a month and a half and I wanted to schedule a 7

Commission meeting as early in the game as possible even i

8 though we in many ways still don't have our arms totally 9

around all the issues that we have to deal with.

10 But I thought it would be useful to the Commission 11 to get some of our initial assessments concerning the projects 12 and as you stated, Mr. Chairman, I am going-to focus largely 13 on TVA's Sequoyah.

14 My intent is to keep the briefing somewhat of a big 15 picture briefing this morning but it is my plan to schedule at 16 least two more Commission meetings on Sequoyah before we will 17 be in a position to recommend restart; one, to go over the 18 issues in rather much detail and the second meeting to sort of 19 tell you we are at the end of the line on it.

20 So that is my intent on dealing with this.

May I 21 have the slide on the office, please?

l 22 (SLIDE.]

23 MR. KEPPLER:

The Office of Special Projects was 24 first established by Mr. Stello on February 9, 1987 and in l

25 fairness, it is fair to say that I volunteered for the job but

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I when I initially recommended this, I had in mind that it might

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2 be somebody else and I took it after Mr. Stallo made some 3

changes there.

4 But I am glad to be on board.

I think it is a very 5

challenging assignment and I hope to be in a position to help 6

not only the Commission but to help the industry this way.

7 COMMISSIONER BERNTHAL:

It is always a great. hazard 8

to suggest a new office that badly needs a new director.

]

9 MR. KEPPLER:

The Office has been functional since 10 March lat.

We have our staff as it exists today on board with 11 us at the end of March and we have just been consolidated this.

1 12 week into the East-West Towers so getting everybody together 13 is a plus.

14 I would like to take the opportunity just to 15 introduce my senior people if that is al: right with you.

16 CHAIRMAN ZECH:

Fine.

17 MR. KEPPLER:

On my right here is Stewart Ebneter 18 who is heading up the TVA project for me.

He was, as you are 19 aware, was up in Region I as the division director for the 20 division of reactor safety.

21 Where's Chris?

Why aren't you up here?

Get up next 22 to Jane.

Chris Grimes is heading up the Comanche Peak effort 23 and Chris was formerly in NRR as the program director for the 9

24 ISAP program.

4 25 You have singled out Ms. Axelrad and I certainly

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1 want to thank the Commission for the support you gave me in

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getting Ms. Axelrad.

3 Also, I have some key people here on the TVA project; 4

John Zwolinski over there with NRR and B.D.

Liaw and Steve 5

Richardson as Stu Ebneter's deputy and Phil McKee is Chris 6

Grimes' deputy.

7 Our present staffing plan calls for in the ballpark 8

of 100 people.

We will add or subtract depending on our 9

needs as we assess them.

Roughly we have about 70 people tied 10 to the TVA project and about 24 people on Comanche Peak.

11 our organizations are about 90 percent established 12 right now.

We chose to keep some positions open rather than 13 fill them where we had some concerns about the capabilities of 14 individuals because as you pointed out, we are trying to put 15 together a first-class organization here.

16 Another innovation that we are doing is to go for 17 expanded on-site facilities with both TVA and with Comanche 18 Peak.

My feeling there is that we need to get our engineers, 19 our licensing people down at the sites working with the 20 engineering people of the utilities where decisions can be 21 made in a more timely manner and the issues dealt with more 22 timely.

23 The initial efforts of the program directors and 24 myself have been aimed at trying to establish effective 25 working relationships with the utilities and knowing of the

9 1

Commission's interest in these projects and the need to be 2

.kept informed, I have invited the Commissioners' technical 3

assistants to listen in on our weekly staff meetings and many 4

of them have been doing that.

So I hope you are getting some 5

feedback that way.

6 Could I have the next slide, please?

7 (SLIDE.]

8 COMMISSIONER ASSELSTINE:

Jim, in terms of people, 9

are you getting the kind of support you need from the rest of 4

10 the staff?

When you set up a new office and you start raiding 11 other offices for the kinds of people you need, there is 12 always a reluctance to provide the best people.

Are you 13 finding that you are able to get the people you need?

14 MR. KEPPLER:

I think the process went well.

15 COMMISSIONER ASSELSTINE:

All right.

16 MR. KEPPLER:

I certainly have had the support of 17 Mr. Stello and if we could have just picked people and walked 18 away with that, that would have been nice but I think looking 19 at'the good of the Agency, I am happy with the way the 20 organization came out.

I 21 COMMISSIONER ASSELSTINE:

Good.

22 MR. KEPPLER:

I feel comfortable with the people we 23 have and where we didn't feel comfortable, we left vacancies.

24 COMMISSIONER ASSELSTINE:

All right.

25 MR. KEPPLER:

I am not. going to say too much about

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Comanche Peak today because the project is still in~ litigation

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2 before the Atomic Safety and Licensing Board but I will just 3

highlight the status of it for you.

Construction at unit 1 is 4

97 percent complete.

Construction at unit 2 is 85 percent 5

complete.

6 There has been and is a major design reverification 7

program underway at the site and this effort borders on 100 8

percent reverification.

9 There is also a major construction reverification 10 program underway at the site.

That effort is less than 100 11 percent but large by today's standards.

12

' COMMISSIONER BERNTHAL:

You say the two units are 90 13 and 85 percent complete?

14 MR. KEPPLER:

Ninety-seven and 85.

15 COMMISSIONER BERNTHAL:

Ninety-seven and 85 but that 16 almost makes it sound as if these two projects are going to be 17 finished in neck-and-neck fashion.

Is that the case?

18 MR. KEPPLER:

No.

There is about a six month lag.

l 19 COMMISSIONER BERNTHAL:

Well, six months.

I would 20 call that awfully close together.

21 MR. KEPPLER:

It is but I can tell you today.that 22 efforts on unit 2 have almost dropped to a standstill and the 23 major effort is being focused cut unit 1 right now.

The 24 project if somebody had reported to you the status of the I

25 project a year ago, they might have told you that it was 100 l

1

11 1

percent complete and the 97 percent is more reflective of the 2

amount of re-work that is going on.

3 COMMISSIONER BERNTHAL:

Well, that is my point.

The 4

lagging of unit 1 seems to me probably means that unit 2 comes 5

hard on its heels at some point or maybe that is not the 6

case.

We don't need to worry about it today but starting two 7

units up six months apart is a pretty formidable challenge.

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8 MR. KEPPLER:

It is and I guess I would say'on the 9

issues that we are worrying about at the present, I haven't-10 gotten to that stage yet.

11 COMMISSIONER BERNTHAL:

It is not high on your 12 agenda yet.

13 COMMISSIONER ASSELSTINE:

In fact, I think I visited 14 the plant two or two and half years ago or so and those 15 completion numbers are very similar to what I was told at the 16 time in terms of what they were claiming.

17 MR. KEPPLER:

Well, I think the effort over the past 18 couple of years has largely been on rechecking the plant.

19 COMMISSIONER ASSELSTINE:

Yes.

20 MR. KEPPLER:

But it is interesting.

The project 21 has 8,600 people on site and when I went down there, I was 22 flabbergasted by the effort.

23 COMMISSIONER ROBERTS:

Eighty-six hundred and the 24 work going on at unit 2 is virtually at a standstill?

25 MR. KEPPLER:

Yes, and they have some 11,000 people

-s 12 1

overall on the project so it gives you some feel for the 2

amount of effort there.

3 The hearing effort for the project, I would just 4

summarize to say, is substantial in my view.

It is a major 5

effort right now but my staff and I do not intend to go to the 6

hearing until we are sure that we can perform adequately at 7

that stage and if that means delaying it, I will delay it.

8 The licensee schedule right now calls for 9

construction completion in March of 1988 with fuel load for 10 July of 1988 and I can tell you that the NRC effort lags that 11 of the utility considerably at this stage so we have a lot of 12 catch-up to do with that project.

i 13 May I have the next slide, please?

14

[ SLIDE.]

15 MR. KEPPLER:

TVA.

This slide shows the priorities 16 and schedules as prepared by TVA.

17 COMMISSIONER BERNTHAL:

Jim, I am sorry, that last 18 comment you made that the NRC effort lags the utility, I hope 19 that is not in diagnostics but rather in verification.

In 20 other words, I hope that we are not lagging in the sense that 21 there are lots of questions that we haven't resolved but 22 rather that the utility is leading us in things they think 23 they have resolved that we now have to verify.

Is that a fair 24 statement?

j 25 MR. KEPPLER:

I think it is more the latter, yes.

l l

13 1

COMMISSIONER BERNTHAL:

All right.

2 MR. KEPPLER:

But I don't want to leave you with the 3

impression that it is totally that way.

I can't be anymore 4

specific than that with you at this stage.

5 COMMISSIONER BERNTHAL:

I would hope that we would 6

clean up the front end of the problems quickly.

7 MR. KEPPLER:

You have to realize that when you have 8

an effort like what is going on down there of 100 percent 9

design reverification and a large construction reverification 10 program, that takes care a lot of the loose ends of the past.

11 I would say the biggest question in my mind is the 12 adequacy of the construction verification program and whether 13 what has been done is sufficient enough but that I am not 14 prepared to talk about at this stage.

1 15 All right?

16 COMMISSIONER BERNTHAL:

Yes, thanks.

j 17 MR. KEPPLER:

With respect to TVA, I would say that 18 the company has it set up such that Sequoyah is the pacing 19 plant and I think you are aware of that.

Unit 2 will be the 20 first plant they intend to start up and the company has an 21 announced schedule of July 31, 1987 with unit 2 to come four 22 to six months later.

23 Now t'he subsequent projects, I am not going to spend 24 much time on but I will tell you that it is my perspective 25 that they will become increasingly more complex to deal with i

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14 1

as we have to go through them.

Brow's Ferry will be more difficult to deal with 2

n 3

than Sequoyah and Watts Bar will be very difficult to deal 4

with also.

Bellefonte, I don't have any comments on it at 5

this stage.

6 I can tell you or should tell you that the staff has 7

under review right now construction permit extensions for both 8

Watts Bar and Bellefonte and we will inform the Commission 9

before we send those out.

10 The majority of our staff effort is clearly focused 11 on Sequoyah right now consistent with the efforts that the 12 utility is having.

13 Could I have the next slide, please?

14

[ SLIDE.]

15 MR. KEPPLER:

I have just listed here what the 16 thrust of our efforts is.

We are trying to determine the 17 adequacy of the scope of TVA's programs and the verification 18 of the implementation and then the subsequent determination of 19 operational readiness.

20 COMMISSIONER ASSELSTINE:

Jim, one quick question on 21 the dates and schedules both for Comanche Peak and for the 22 various TVA plants.

Did we get from that and particularly 23 your understanding of the situation at the current time, that 24 we should look at the Office of Special Projects as something 25 that has a fairly longer term scope?

This is not something

15 1

that is going to be over in a couple of months?

2 MR. KEPPLER:

I think that is fair.

All how the 3

the Office of Special Projects has to remain in effect is, I 4

think, a debatable question at this time but I certainly do 5

not feel that we will be in any kind of a position to have 4

6 things on a track before the end of the year at this stage and 7

it could be longer.

8 COMMISSIONER ~ASSELSTINE:

All right.

9 MR. KEPPLER:

Could I have the next slide, please?

10

[ SLIDE.]

11 MR. KEPPLER:

I am going to go through in some 12 detail the major issues at Sequoyah which are broken down into 13 the management / organizational issues, technical issues, what I

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14 will-call allegations and operational readiness.

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15 Could I have the next slide, please?

16

[ SLIDE.]

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17 MR. KEPPLER:

Oh, let me just say that coming into a 18 project like Sequoyah and for that matter even Comanche Peak, 19 it is very interesting to try to understand all that has

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20 happened in th past, try to make sure that things haven't 1

21 fallen in the cracks and that you are getting your arms around 22 every issue.

1 23 But I want to assure the Commission knowing the 24 sensitivity of these projects that my st'aff and I will review 25 every technical issue very carefully and I will personally be i

i i

16 1

satisfied before I aven go to Mr. Stello to suggest readiness 2

for the plant'and then before we come to the Commission.

So I 3

want you to realize that.

4 Let me talk about the organization.

The basic 5

premise that we are working with on TVA's organization is that 6

NRC must have confidence that there is a management 7

organization and structure in place and functioning before any 8

plant can restart.

That is the groundrules in which we are 9

working under.

10 Now TVA has submitted the latest version of its 11 corporate plan to us.

Our review of that is nearing 12 completion.

13 We will be meeting with TVA next Monday down in 14 Chattanooga to discuss that plan and I would tell you that we 15 will either following that meeting approve that plan or tell 16 them what needs to be changed to make the plan acceptable-to 17 us but I am that close to approving the corporate plan and 18 focus on the word, " plan."

We still have the implementation 19 to verify here.

20 CHAIRMAN ZECH:

And I hope you are looking at that 21 organization from a longer range viewpoint because I expect j

i 22 that you will look into the permanency of an organization, not 23 just an organization that is going to get it started but an 24 organization that is going to remain there so we'will have the 25 confidence in the management for the future as well as the

17 1

short range.

2 MR. KEPPLER:

That is a very important issue with 3

us.

I think Mr. White has discussed the organization with 4

you.

He has brought in a lot of permanent people to TVA.

He 5

has also brought in a number of contractor people.

6 It is important to us, first to see that this 7

organization works well but secondly the point you make that 8

it won't be disrupted by people pulling out after a year or 9

two is a vital concern to us.

10 CHAIRMAN ZECH:

We have heard from him and we know 11 what his plans are to bring in permanent people and all that 12 but what I think the Commission needs to do is to hear from 13 you and make sure that you are confident that that permanent

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14 organization is going to be in place.

15 MR. KEPPLER:

That 'is why I said to you before what 16 we will approve is the plan right now but the implementation 17 of that plan and the longer term commitments of.that plan will 18 have to be demonstrated to us before we come in and recommend 19 restart.

20 CHAIRMAN ZECH:

Fine.

21 MR. KEPPLER:

So I think we are on the same 1

22 wavelength, Mr. Chairman.

1

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23 CHAIRMAN ZECH:

Fine.

24 MR. KEPPLER:

But I would tell'you that I think that 25 TVA has done a lot in this area.

I think some of the people

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they brought in are very experienced and I think that clear

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2 lines of authority have been established, responsibility and 3

accountability established and there is a good. management 4

structure there right now.

5 on paper, it looks good to us.

The implementation 6

is the key.

7 I think I can tell you that the plan does fully 8

address the concerns that have been addressed previously by 9

the Commission, the concerns addressed by the ACRS ad hoc 10 subcommittee and by the staff.

So in approving the plan, 11 those types of concerns will have been addressed.

12 As far as the station plan is concerned, that is I

13 under review by the staff right now.

TVA has strengthened the f

14 organization at the plant and station management and staff are 15 pretty well in place now.

16 There has been an interface established between the i

17 corporate structure and the station that looks good to us and 18 at the moment the staff is working very closely with the 19 utility to come to grips with what will have to be completed 20 prior to restart.

21 I would just tell you at this stage that I haven't i

22 personally been involved in the restart criteria yet.

I will 23 be before I approve it but my staff feels that the restart 24 criteria are reasonable, are probably on a par with what was 25 approved for Davis-Besse and that is important to me to be

19 1

consistent with what we have done in the past and I will look 2

at that.

3 But that will be coming down to the point that I 4

hope that I can approve that fairly soon.

5 COMMISSIONER ASSELSTINE:

Jim, is the meeting this 6

coming week focused on the corporate plan or is it also the 7

Sequoyah plan as well?

8 MR. KEPPLER:

It is going to focus on both, is it 9

not?

10 MR. EBNETER:

Right, primarily the corporate plan.

11 COMMISSIONER ASSELSTINE:

All right.

12 MR. EBNETER:

But the interface will be discussed.

13 COMMISSIONER ASSELSTINE:

All right.

14 MR. KEPPLER:

I would say that as far as potential 15 issues with the organization that there are probably three.

16 Most importantly is the OI investigation that is ongoing with 17 respect to the quality assurance issue at Watts Bar but the 18 Commission should know that there has been a lot of discussion 19 on the part of the staff over span of control with the 20 organization set up by Mr. White.

21 My view on that is that I am going to look at how 22 that organization works as whether or not that is an issue to 23 me.

To me, span of control is a judgment call and I think management has a right to set up an orga'nization the way they 24 25 want to do it and I will judge the effectiveness of that

20 1

organization and if I think there are problems that way, then I

2 I will deal with it accordingly.

3 The last issue which has surfaced fairly recently is 4

the fact that the procurement activities do not fall under I

5 Admiral White and we are going to look very closely at how the 1

6 interface between engineering and procurement works.

If we 7

feel there are complications that way, we may advise TVA to 8

change that.

9 Could I have the next slide, please?

10 COMMISSIONER ASSELSTINE:

Jim, on the span of 11 control question is that just Mr. White's direct supervisory 12 authority or are there broader questions than that?

How many 13 people report directly to him?

14 MR. KEPPLER:

I believe it is the reporting to 15 White.

16 MR. EBNETER:

That is the primary issue.

17 COMMISSIONER ASSELSTINE:

All right.

The issue of 18 where TVA has sort of gone back and forth.

When White was

]

19 gone, they narrowed the span of control and when White came 20 back, the expanded it back.

21 MR. EBNETER:

Yes, then they decentralized it.

22 COMMISSIONER ASSELSTINE:

All right.

23

[ SLIDE.]

i 24 MR. KEPPLER:

What I have listed here are a number 25 of technical issues that are probably the most important l

l

21 1

issues as they relate to Sequoyah and I apologize in advance, 2

I reordered t' hat slide if it confuses you.

I decided to put 3

QA up at the top and change around a couple of things.

4 But let me just briefly run through this.

In terms l

5 of quality assurance, TVA has revised its QA program developing 6

and implementing systems for problem identification and 7

, corrective action.

That program, that topical report of 8

TVA's, was approved before this office became effective.

It 9

was approved in January, I believe.

4 10 But more important to us, I think all of these plans i

11 look good on paper but more importantly will be the 12 implementation of it and that is something that we have under 13 ongoing surveillance with our activities.

14 In terms of design, I haves listed three things, the 15 design control area which surfaced as a problem from a number 16 of sources, came out of employees concerns; it came out of 17 audits done by TVA; INPO had some findings as well as NRC.

l 18 TVA not has a revised program in place that appears acceptable 19 to the staff so we feel that the forward look of design 20 controls is acceptable at this stage.

f 21 In terms of the design baseline verification program, 22 that was the program TVA put into place to assess the adequacy 23 of past modifications and correct deficiencies.~

That program, 24 the full scope of that program, is not clear to the staff yet 25 So in answer to your question,- do we find that l

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program acceptable, the answer is, I don't know yet.

I will 2

tell you or you probably are aware, Commissioner Asselstine 3

wrote a memo to Mr. Stello regarding the scope of that program 4

and I have sought TVA's input before responding to Commissioner 5

Asselstine's letter.

6 My feeling to you is that we are going to take a 7

hard look at whether the scope is acceptable and if it isn't, 8

we would have to require some additional efforts that way.

9 CHAIRMAN ZECH:

But it is a big issue.

10 MR. KEPPLER:

It is a big issues.

There is no 11 question.

It is one of the biggest issues that is affecting 12 restart as far as I am concerned.

13 CHAIRMAN ZECH:

We need your solid review and 14 analysis and assessment of that program.

15 MR. KEPPLER:

I would say to you it probably is the 16 single biggest issue in the technical area that we will have 17 to come to grips with.

18 CHAIRMAN ZECH:

It seems to me that it very likely 19 is.

20 COMMISSIONER BERNTHAL:

Well, I agree, it is a big 21 issue but I would find it very interesting once we begin this 22 process of design verification for you to get a calibration by 23 picking randomly another plant of similar vintage, similar i

24 type if we have any and offering for free to do a similar 25 design verification on that plant and see how much they

o 23 1

differ.

/'

2 In other words, you understand my point.

I want to 3

make sure that we are being even-handed here because I suspect 4

that if we pressed a number of older plants to the wall on 5

original design verification in this country, we would show up 6

with a similar situation in other plants.

7 MR. KEPPLER:

Let me respond by saying that I have 8

considerable allegations relating to whether or not the plant 9

meets its original design intent and was whether it was 10 constructed properly consistent with the FSAR that I think 11 warrants the kind of look that deals with those allegations.

12 Whether or not the existing program --

13 COMMISSIONER BERNTHAL:

I had posed two different 14 questions; whether it was constructed according to design is 15 one thing and constructed properly is one think, I am sorry, 16 and that can be a different thing from whether it was 17 constructed in accordance with the original design.

18 MR. KEPPLER:

'But, again, I have allegations that 19 say that the design of the plant is not consistent with the 20 design specified in the FSAR.

21 COMMISSIONER BERNTHAL:

I understand that.

Right.

22 MR. KEPPLER:

So these allegations to me will have 23 to be explored and, of course, right now the issue I am 24 looking at and seeking some feedback from TVA is that while the stated design baseline verification program only goes 25 l

24 1

from the licensing stage on, I am told that-the actual conduct 1

2 of that program dealt with a considerable amount of 3

pre-licensing verification.

4 So I need to understand first what TVA has done.

s 5

Then I need to assess what we have done and look at how the i

allegations fit into that to decide whether if what is done is 6

4 7

adequate or whether more needs to be done.

8 COMMISSIONER BERNTHAL:

Right.

My point is that 9

there are allegations not only for this plant but for other 10 plants from time to time that the plant was not built according 11 to the design, that somehow there are deviations from the 12 design and that question is one that I want to make sure that 13 we are dealing in an even-handed way with for all of our plants 14 including the TVA plant.

i 15 The other question is whether the construction is 16 simply inadequate and I must say that that is probably-the 17 more common, that they attempted to build it in conformance 18 with the design but somebody did something wrong.

It seems to l

19 me there is a distinction to be made there.

The second i

i 20 category is the more common one that we are used to pursuing 21 almost as a matter of everyday practice around here.

22 The first one is one that gets into the question of 23 reviewing old plants in a generic way, I would say, and I 24 would just want to ensure that we are dealing with this plant 25 in an even-handed manner when compared with many other plants.

l

\\

25 1

MR. STELLO:

Let me try to sharpen the issue if I I think"the real question to take it one more cut is 2

can.

3 they sent us an application.

In there, they committed to how 4

they would design and construct a plant.

5 COMMISSIONER BERNTHAL:

Exactly.

6 MR. STELLO:

The issue is, did they depart from that 7

and they can and if they departed, did they do so properly.

8 COMMISSIONER BERNTHAL:

Right.

But you see the 9

point, construction practice is one thing but departure from 10 design is another matter.

11 MR. STELLO:

That is what I was talking about.

I am,

12 sharpening it.

13 COMMISSIONER BERNTHAL:

All right.

14 MR. STELLO:

It is an issue of the commitments that 15 were made in the application, were they followed and where a

16 they were not followed, was there a system in place that says 17 that the departure was done properly.

18 COMMISSIONER BERNTHAL:

I understand.

19 COMMISSIONER ASSELSTINE:

I gather from at least 20 some of the inspections that we have done, we have found where 21 there were deviations and where those deviations raised some 22 questions and the big concern is, is it an isolated or limited 4

23 problem or is it more widespread which I think really is the 24 crux of Fred's question.

~

25 MR. STELLO:

Now you have both-questions.

Once you i

26 1

get to the deviation, is what they did okay.

f 2

COMMISSIONER ASSELSTINE:

That's right.

3 MR. STELLO:

Then you still have the process 4

question.

5 COMMISSIONER ASSELSTINE:

Yes.

6 MR. STELLO:

Did they, in fact, pursue allowing that 7

de'viation. correctly or was it just a field modification where i

8 it didn't go back into the design.

9 COMMISSIONER ASSELSTINE:

That's right.

10 MR. STELLO:

Then you get the two issues.

11 CHAIRMAN ZECH:

But you have to look into both.

12 MR. STELLO:

Both, that's right.

13 COMMISSIONER ASSELSTINE:

Yes.

14 CHAIRMAN ZECH:

That is important and that is what 15 you are doing, Jim?

16 MR. STELLO:

Yes.

17 MR. KEPPLER:

Yes.

18 COMMISSIONER ASSELSTINE:

That's right.

I think you 19 also have to take into account, Fred, I think you are right on 20 the fairness question but you also have to take into account 21 what we also know about how the overall TVA nuclear 1

22 organization was operating during this time period, 23 particularly the working relationships between engineering, 24 design and construction; people making design changes or 25 changes in the plant in the field.

-e

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27 1

I suspect that as we learn more about that 2

interaction,'that provides at least a basis for some question i

3 or concern in addition to what we see in terms of the specific 4

hardware.

5 MR. STELLO:

That is probably what created the 6

problem.

x 7

COMMISSIONER ASSELSTINE:

That's right, yes,, no 8

doubt about it.

9 COMMISSIONER BERNTHAL:

This plant was constructed l

10 when?

What are the years of construction again?

I guess I 11 should know.

12 MR. EBNETER:

Early 1970's to--

13 COMMISSIONER ASSELSTINE:

To late 1970's.

7 t

14 MR. STELLO:

Yes.

15 COMMISSIONER ASSELSTINE:

Sequoyah 1 got its low 16 power license in 1980, I think.

17 COMMISSIONER BERNTHAL:

Do you all have a high 18 degree of confidence that we would not find simi2ar problems i

19 in other plants constructed by other organizations in the early/mid-1970's timeframe?

20 21 COMMISSIONER ASSELSTINE:

You said, " Pick a i

22 comparable plant."

Pick Mcguire 1, take a look, see what you 1

23 think.

l 24 COMMISSIONER BERNTHAL:

I said' randomly, i

25

[ Laughter.]

t

__.-4-,

__...-.--...._,.m..

28 1

COMMISSIONER ASSELSTINE:

You said a similar plant 2

in the same t'ime frame.

Take Mcguire 1.

~

3 COMMISSIONER BERNTHAL:

I think I said randomly.

I 4

think you are picking non-randomly.

I would agree.

I wouldn't 5

expect to find that at Mcguire, I hope.

6 MR. STELLO:

You would find something.

I think I 7

would make the judgment tha't you will ftpd problems of that 8

type at every --

9 COMMISSIONER BERNTHAL:

For plants constructed in ll 10 that time frame.

11 MR. STELLO:

Yes, and the further back you go with 12 time, the more that you are going to find.- If you look at 13 going way back, just think for a minute, an application and I j

14 remember reviewing them in 1966, they were this thick.

15 COMMISSIONER BERNTHAL:

That's right.

16 COMMISSIONER ASSELSTINE:

Yes.

17 MR. STELLO:

How much can you get in a bunch of 18 paper that thick?

Today, they are that thick.

So what they 19 committed to today is this much and what they were committing 20 to in designs in the late 1960's and early 1970's is that 21 thick.

]

22 COMMISSIONER BERNTHAL:

Two wrongs don't make a 23 right.

Because we have problems perhaps that we are unaware

]

24 of elsewhere certainly doesn't mean that you overlook problems j

25 here but I do want to make the point that we should make sure l

I I

29 that there is a sense of equity in the way we treat them.

1 2

MR. STELLO:

That was a preamble to my final thrust 3

of my comment.

We are not going to move forward until we are 4

satisfied it is safe.

5 COMMISSIONER ASSELSTINE:

That is the question.

6 MR. STELLO:

The magnitude of the documents and the 7

degree to which there was confusion.as long as the and result 8

it that it is safe, it is okay, we are satisfied.

9 COMMISSIONER ASSELSTINE:

That's right.

i 10 MR. STELLO:

If we are not, they have to fix it 11 before we are going to be satisfied.

The end result is that 12 is what we are after.

We are not going to be worried, yes, i

13 there are problems.

We know there are problems.

We don't s

4 14 have to go far to find that out.

We know.

Now we have to i

15 find out did they create questions on safety.

If they did, we 16 have to get them fixed.

17 COMMISSIONER BERNTHAL:

And I would hope that we 18 proceed a pace under the severe accident policy to do similar 19 studies of other older plants.

i 20 COMMISSIONER ASSELSTINE:

I am a big fan of doing 21 those kinds of studies of the other older plants.

I think 22 they are outside of the scope of those individual plant f

23 evaluations to a certain degree.

These are the kinds of 24 things that Turkey Point and some of thN other plants are 25 doing on their own.

1 I

{

30 1

MR. STELLO:

I am sure we could devise a program of 2

such magnitud's that we couldn't do it.

We have to decide what 3

we do to make sure that the program is manageable and 4

reasonable.

If we keep adding everything to it and.it will 5

just collapse under its own weight.

6 COMMISSIONER BERNTHAL:

We at one time used the term 7

at this table " smart PRA."

This isn't PRA exactly applied to 8

older plants.

This is " smart reevaluation" of some kind, I 9

guess, or verification and I think, I don't want to depart 10 from the subject too much, but that is what we are doing in 11 this case.

We have probable cause to carry out a verification 12 and I suspect if I sat down and talked with Mr. Stallo and 13 Mr. Keppler they could suggest other areas where we might look i

14 more profitably so that is my point.

15 MR. STELLO:

Yes, and that we are doing.

l 16 CHAIRMAN ZECH:

All right.

Can we proceed?

17 MR. STELLO:

Jim, go ahead.

18 COMMISSIONER ROBERTS:

Talk about NUREG-1150.

19 MR. KEPPLER:

I am going to talk about NUREG-1150 20 versus the individual plant evaluation.

The staff as I think i

21 the Commission is aware, the staff PRA has identified Sequoyah 1

22 as out outlier and TVA had an individual plant evaluation 23 performed by Westinghouse which suggests the issue is less j

24 serious.

'l 25 I just listed it here.

I don'-t have a position on 5

31 1

it at this time.

The staff has it under review and it is an 2

issue that we'will have to come to grips with to decide 3

whether or not it is a restart. matter or not.

4 COMMISSIONER ASSELSTINE:

Are you doing that, Jim, 5

or that being done by someone else?

6 MR. KEPPLER:

No, that is being done by Research.

7 COMMISSIONER BE'RNTHALi I have one question in that 8

regard and I only now just finally got a partial copy of this 9

Westinghouse PRA.

It is a little hard to look at it quickly 10 here but is there a sense of how Research is going to handle 11 that because research certainly has a stake in its own results 12 in NUREG-1150.

13 Is that going to be contracted to an independent t

14 outside reviewer or how are we going to do that?

15 MR. KEPPLER:

Stu, can you answer that?

16 MR. EBNETER:

I am not totally sure however in our 17 discussions about transferring the task to them, my 18 understanding is that the contractors will compare the results 19 of the IPE with the 1150 and identify the differences and then 20 try to account for these differences.

21 Some of the differences we know already are lack of 22 information that we used that was available to Sequoyah.

23 Apparently it was not the staff's difficulty, it was just the 24 difficulty in getting that information during the 1150 study 25 but their contractors will be involved in the study.

32 1

COMMISSIONER ASSELSTINE:

I would suspect, Fred,

,r 2

that you concern would be directed.more towards the contractors 3

since the original sequoyah study like the others were all done 4

by contractors.

i 5

COMMISSIONER BERNTHAL:

That's right.

6 COMMISSIONER ASSELSTINE:

Those were all farmed 7

out.

Probably what you would want is a fairly heavy 8

involvement by the research staff itself to. basically be the 9

arbiter to decide who is right on these various things.

10 MR. EBNETER:

We need some safeguards *to ensure that 11 it is objective.

12 COMMISSIONER BERNTHAL:

I wasn't under any allusions 13 that we were going to do it in-house here, but that is exactly 14 right.

15

. COMMISSIONER ROBERTS:- NUREG-1150 is a draft.

16 MR. KEPPLER:

I understand that.

17 COMMISSIONER BERNTHAL:

It sure is.

18 MR. KEPPLER:

But it is an issue that I think we all 19 have to come to grips with.

~

20 COMMISSIONER ASSELrf7e?:

that's right.

21 MR. STELLO:

I did it.

I am responsible for that 1

22 happening.

Let me tell you what my thinking was.

We have a 23 draft document and what it shows is for one of the plants, we 24 have a very intense review going on right now.

The risk

)

i l

l 25 profile from that plant has two attributes.

One was higher I

l

33 1

than the others and I put that aside because that isn't 2

especially the issue here.

t 3

There were clearly a number of things procedurally 4

in the plant for which if they did them, they could make a 5

significant change in risk.

We didn't require it but I felt 6

clearly we had to call that to the licensee's attention.

It 7

is their plant and they may, in fact, in the end result 8

notwithstanding whatever we have by way of debate do things to 9

the facility that makes the whole issue a non-issue.

10 I don't know whether they will or not but we are not 11 telling them they have to but a sense of fairness to me 12 dictates us not coming out with that report and giving 13 opportunity to the licensee to be aware of it and to make 14 decisions for himself.

15 Now I was unaware that they had this other work done 16 until after the fact and we ought to sort it out but I don't 17 know whether that whole exercise may turn out to be academic.

18 I don't know.

If it were my plant, I would look at it and ask 19 myself, if you look at what are the significant contributors i

20 to the risk are things that are not that profound to deal with 21 that can change the profile.

22 I think it is important when we put out these 23 studies to get them to the licensees.

After all, they are 24 their plants.

j 25 CHAIRMAN ZECH:

All right.

Can we proceed?

l

34 1

MR. KEPPLER:

The procurement area listed three

/

2 things,.the p'iece parts program which is TVA's look at the 3

fact that they procured a lot of commercial grade material for 4

parts replacement and safety-related components and that could 5

involve a major effort.

That is ongoing.

6 The design' output engineering procurement interface 7

is the issue I mentioned earlier with the procurement i

8 department not reporting to Admiral White.

9 I have listed the problem with material traceability 10 which we really haven't heard too from TVA on, but there has 11 been a heat code traceability related to small bore piping 12 that potentially could be an issue.

13 In the electrical area, the sizing of cables to 14 handle the amperage was identified as a potential problem by 15 INPO at Bellefonte and TVA is involved with a fairly 16 substantial effort to replace cables down there, some 50,000 17 to 100,000 feet of cable is being replaced, and some 130-plus 4

18 circuits will be replaced.

1 19 Cable installation was an issue that came out of the i

20 employee concerns program, mainly concerns with short bends on 21 the cables and tensioning during the pulling operation and TVA 22 has proposed a test program for dealing with that that we are 23 looking at.

24 The fuse replacement program is an issue in terms of 25 the adequacy of control power fuses and-TVA has replaced some 1

35 1

3,500 fuses to deal with that.

2 Environmental qualification, that was the issue that 3

initially caused TVA to shut Sequoyah down where a review 4

conducted by TVA and a consultant determined that TVA was not 5

in compliance with the Commission's rules on equipment 6

qualification.

e 7

A major effort has been ongoing in that area in 8

terms of upgrading ~their program, procedures, records have 9

been upgraded, documentation of compliance and there have been 10 a number of hardware modifications or replacements.

11 The staff's review of that is still not complete but 12 I think coming al'ong in the right direction.

13 May I have the next slide, please?

14 Let me just say, I listed those technical issues but 15 I don't want to leave you with the-fact that those are the 16 only issues.

17 COMMISSIONER ASSELSTINE:

Yes.

18 MR. KEPPLER:

I got a page full of other technical 19 issues.

20 COMMISSIONER ASSELSTINE:

Welding, concrete and 21 other fundamentals.

22 MR. KEPPLER:

That's right, but these are the ones 23 that I think are the more pacing ones, the ones that are 24 bigger and there are other issues that have been generated 25 like operator licensing failures.

We have a lot of licensing i

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36 1

changes to make on the plant and I will mention but we do have 2

a lot of alle'gations to deal with to.

3 May I have the next slide, please?

4

[ SLIDE.]

5 MR. KEPPLER:

Just summarizing on the allegations 6

issue, TVA formed an employee concerns task group effort to 7

deal with the issues generated by the Commission's 50.54 (f) 8 letter and to date, there have been in excess of 8,300 concerns 9

to be evaluated.

If my numbers are right, we have some 6,300 10 evaluated to date.

i 11 All have been reviewed, all of the 8,300 have been 12 reviewed, for applicability to Sequoyah and the staff has looked at TVA's criteria that way.

I will tell you that I 13 t

14 have some uneasiness still about assuring ourselves that all 15 of the Sequoyah related issues have been identified and I will i

16 want to look a little more further into that program before I 17 bless it.

That is an area that the NRC staff has to deal 18 with.

l 19

. Of the 8,300, there have been 1,200 concerns 20 applicable to Sequoyah and TVA has provided us with their l

21 evaluations of almost all of these concerns right now so the 4

1 22 ball is in our court to deal with.

i 23 The new employee concern program at Sequoyah, there 24 have been since that was instituted a little over a year ago, 25 there have been about 110 concerns generated and TVA's review 1

i i

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of that is 85 percent complete.right now.

1 ?

2 On intimidation and harassment issues, the TVA 3

Inspector General or the --

4 CHAIRMAN ZECH:

Excuse me.

Does the new employee 5

concerns program seem to be effective?

You gave us the 6

numbers but does it seem to be doing the job it is supposed 7

to?

8 MR. KEPPLER:

I think so.

If you look at' the rate 9

of issues coming in, it does seem to be effective and 10 furthermore,_the issues that are being generated of late are 11 not the kind of issues that suggest major quality concerns 12 from our point of view.

13 CHAIRMAN ZECH:

Fine.

1 14 MR. KEPPLER:

So if that is an indicator, I would 15 say it seems to be working.

16 CHAIRMAN ZECH:

I think you ought to keep watching i

17 that program and make sure that you are confident that it is 18 doing what it is supposed to do.

19 MR. KEPPLER:

I think the program is sound.

I think 20 the disposition of issues is still a question.with me.

21 CHAIRMAN ZECH:

all'right.

22 MR. KEPPLER:

As far as the intimidation and 23 harassment matters, either OI or the TVA Inspector General 24 have been investigating those issues to" determine whether any i

25 of the managers at Sequoyah need to be replaced prior to I

38 1

restart, r

2 All 'of'the technical issues that have grown out of 3

those, we have satisfied ourselves that they are into TVA's 4

hands for appropriate disposition.

TVA management has 5

instituted a program to prevent and address intimidation and 6

harassment and again, if you will look'at the rate of those 7

~ issues, that is looking good, but I.will tell you that we

{

8 still are seeing examples of intimidation and harassment 9

reported.

10 We will review the work that the TVA Inspector-11 General has done prior to wrapping up this issue.

I will tell

{

12 you that I have met with Mr. Zigrossi, the Inspector General 1

13 for TVA, and I came away from that meeting feeling pretty good s.

j 14 about the efforts ongoing down there.

j 15 With respect to allegations, there are some in j

16 excess of 100 open allegations that NRC is dealing with and 1

17 when I give you that number, I don't have a lot of detail in i

18 the sense of whether there are 100 specific single issues or I

i 19 whether they have branches to them.

I am concerned that this

\\

j 20 is a pacing item with us.

21 The NSRS concerns have to be dealt with and I can 22 tell you that I spent about two minutes with my_ staff talking l

23 about NSRS concerns to' realize we don't have a good handle on 24 those yet and we will have to deal with'that issue as well.

25

[ SLIDE.]

I l

i

39 1

MR. KEPPLER:

Operational readiness, I mentioned

/

2 that the TVA plan is under review by the staff.

Some of the 3

issues that we will deal with are maintenance where the 4

company has made some major improvements in the area of 5

maintenance.

6 But based upon our inspections and the inspections 7

conducted by TVA itself, the shortcomings have been identified 8

to lead me to believe that while'the program still looks 9

solid, the implementation is behind schedule at this stage.

4 10 Surveillance instructions, this was an issue that wa 11 developed by our own inspectors.

TVA has found in excess as 12 part of their review of some 600 or 700 surveillance 13 instructions, they found violations on the order of 75 with 14 their program, so they have a major effort underway to upgrade 15 their surveillance instructions and at this stage, we think 16 that could be well' a pacing item for them.

17 The start-up test plan which, of course, is very j

18 important for this plant, TVA has really just started to get i

19 involved with that effort.

I can tell you they brought in 20 some people who were involved in Davis-Besse which I think is j

21 a good move knowing the extensiveness of that program that was 22 looked at.

23 I would look for the Sequoyah effort to be as 24 extensive as Davis-Besse's because all of those operability i

l 25 questions that existed there are not applicable here but I 3

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40 1

1 certainly am looking for a comprehensive start-up test program 2

and bringing 'in those kind of people, I think, is a step in 3

the right direction.

4 Regarding operational readiness review, TVA will 5

conduct a major effort in that regard but I want to assure you 6

that NRC will as well.

7 May I have the next slide?

8

[ SLIDE.]

9 MR. KEPPLER:

What I have tried to do here is to 10 give you a feel for how I see the plant recognizing a lot of 11 things could change.

The coding is to say and this is working 12 toward TVA schedule of the end of July.

13 column "A" is to say we have no problems with the f

14 TVA-is handling the issue and we think that our review is on i

15 schedule with that July date.

The middle column, column "B,"

j 16 is to say that we have a basic agreement on the problem but 17 either we think TVA's schedule is too optimistic or we believe i

18 that we have considerable work to do and we will be, if that 19 schedule is met, we will be a factor on it.

20 Lastly are the areas that I have listed where we 3

21 still have some questions regarding the disposition of the 22 problem.

Now if you would like, let me just take the column 23 B's and the column c's a minute.

1 3

24 The cable installation one, we'believe TVA's schedule l

25 is too optimistic for that.

The surveillance instructions, we I

3 i

41 1

believe TVA's schedule is too optimistic.

The maintenance

' ~

activities, w'e believe TVA is not on track with their schedule 2

3 there and the allegations and employee concerns, NRC is the 4

bottleneck on that one and we have a lot to do in that area.

5 CHAIRMAN ZECH:

Are we going it?

6 MR. KEPPLER:

We are, yes.

But TVA has dumped all

]

7 of that effort into us.

I 8

CHAIRMAN ZECH:

It takes time and we have to review 9

it properly.

It does take it.

10 MR. KEPPLER:

We have to do it and we will do it as 11 expeditiously as we can but it will be a quality job.

12 CHAIRMAN ZECH:

You have to do it carefully and 13 thoroughly, too, and they should know that.

j 14 MR. KEPPLER:

And they do.

15 CHAIRMAN ZECH:

Are we putting the resources on it 16 that we are making progress?

17 MR. KEPPLER:

I can't tell you that I am. satisfied 18 with that point yet.

I really haven't looked at whether we i

19 are doing everything we should but I assure you I will.

20 CHAIRMAN ZECH:

All right, and we have to do it 21 right, too.

So we do need the time.

All right.

Go ahead.

i 22 MR. KEPPLER:

Now with respect to those in column C, 23 the issue with the design baseline verification program, we i

24 have discussed.

The key question there'is the scope of the 25 program and I am just not prepared to advance any position on

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42

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that right now.

1 f

2 NUREG-ll50, as I said, that is under staff review, 3

what we need to do.

I 4

The piece-part procurement program is in column C 5

because -- well, I am not sure.

Do you know?

1 6

MR. EBNETER:

Part of it is the interface between 7

engineering and procurement, are the designed outputs adequate 8

to the procurement and it is involved with QA, also.

We don't 9

have the full details on that yet.

TVA is moving on them but 10 we need to allow for implementation and review.

11 MR. KEPPLER:

I guess that is the point.

We really 12 don't have their plan for implementation of that replacement.

13 That is what is holding us up there.

I just didn't understand 4

4 14 my notes.

15 The design procurement interface we have talked 4

l 16 about.

As an organizational issue, we are waiting to see.

17 Material traceability, we are still waiting on TVA 18 for their position on that but again that deals with the small 19 bore piping and the test plan down at the bottom, TVA still 20 has not submitted their comprehensive test plan.

21 Now these issues can shift as we learn more but it 22 is my intent to try to come to grips very quickly with those l

23 in column C and with respect to those in column B to put the l

24 resources onto it so that the NRC is not the hold-up on those.

)

i 25 CHAIRMAN ZECH:

All right.

~

1 i

l

43 1

MR. KEPPLER:

That is what I was prepared to say.

e

~

s 2

COMMISSIONER BERNTHAL:

I wouldn't want to let you 3

get off this piece of paper without explaining to me wh. ether 4

"ampacity" is now a part of the English language or is it a 5

new technical word that I am unaware of or am I seeing language 6

evolve before my eyes here?

7 COMM,ISSIONER ROBERTS:

I dare you to try to look it 8

up in the dictionary.

9 COMMISSIONER BERNTHAL:

I assume that means amparage 10 capacity or something like that?

11 MR. EBNETER:

Yes, that is essentially it.

12 COMMISSIONER BERNTHAL:

That is common terminology 13 though.

14 MR. STELLO:

Size of the cable.

15 COMMISSIONER BERNTHAL:

Right.

16 MR. EBNETER:

It probably isn't in the dictionary.

17 MR. KEPPLER:

We will use cable size for the next 18 briefing.

t

)

19 (Laughter.)

20 COMMISSIONER BERNTHAL:

It is all right.

I just 21 wanted to be brought up to date.

I don't like being behind on i

22 these things.

23 MR. STELLO:

That's it.

We are through, l

24 Mr. Chairman.

25 CHAIRMAN ZECH:

All right.

Fine.

Questions from my

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

44 i

1 fellow Commissioners.

Commissioner Asselstina?

/

2 COMMISSIONER ASSELSTINE:

Just a couple.

When you 3

look at the status of issues, Jim, and where you stand at the 4

present time, what do you think about the realism or 1

5 feasibility of the July 1987 date and if you had to put bounds 6

on the time table at this point depending upon the resolution 1

7 of some of these questions, particularly the design question, 8

where could they go?

9 MR. KEPPLER:

I would say that we felt from the 10 beginning when TVA made the announcement that it was an

)

11 optimistic schedule and I have tried to refrain a little bit t

12 from guessing how optimistic until we could see where we stood 13 on each one of these issues and get them into the licensee's 14 program.

1 i

15 But I guess if I were to give you my instincts 16 having dealt with problem plants before, I will be happy to 17 get Sequoyah licensed by the end of the year or back in 18 operation by the end of the year.

1 19 COMMISSIONER ASSELSTINE:

All right.

My second j

20 question is on the allegations.

You mentioned some concern 21 about the employee concerns program or at least the criteria i

i 22 and how they are being applied.

Most of the employee concerns 4

23 at least the old ones were Watts Bar issues since that is 24 where all the interviews were conducted.'

I 25 I guess what I am looking for is some sense for how

~..

45 I

1 far along you think TVA is.

Have they at least identified

/

2 what they think is the scope and extent of each of those 3

problems and have they written that down anywhere, and do we 4

j 4

have a feel for whether that is right or wrong or generally in 5

the right ballpark and what the causes of those problems were to be able to understand whether TVA's criteria really are 6

t 7

screening the right ones out and if not, how are going about j

8 resolving that and when do you think that you are going to be

]

9 in a position to try to settle what appears to me to be a l

10 fairly fundamental issue?

11 MR. KEPPLER:

Let me say that my staff has expressed j

12 a high degree of comfort with TVA's efforts in the employee 13 concerns area.

They feel that the issues have been sorted 14 properly, are being looked at properly and from what I am 15 told, that we have inspected TVA's criteria for sorting and 16 aven looked at areas that were not considered applicable to 4

17-Sequoyah.

We have looked in that bin and concluded that the i

i 18 sorting was proper.

19 Why I expressed my hesitancy on that issue is that I 20 still have what I consider to be very credible allegations in 21 that area that suggest that at least suggest to me that I need 22 to look at it further.

23 COMMISSIONER ASSELSTINE:

All right.

24 MR. KEPPLER:

Now you asked what am I doing.

I 25 recently put out a memo to both Mr. Ebneter and to Mr. Grimes i

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46 1

and I intend to sit down on one issue a week, one key issue a

/

2 week, with each one of these gentlemen and their staffs and I t

3 am going to go through this as comprehensively as I can and 4

play the devil's advocate over how we have handled these 5

issues so that I can be convinced with my background that we 6

have done a proper job of looking at them.

7 I feel that will test our system.

It will get me up a

8 to speed and it will put me in a position where I can convince j

9 my boss that these issues have been done properly so that then 10 we can come to the Commission and we can all sit up here 11 intelligently and tell you what has been done.

12 COMMISSIONER ASSELSTINE:

Good.

1 13 MR. KEPPLER:

So that is the way I am approaching 7

~

14 it.

15 COMMISSIONER ASSELSTINE:

Great.

I must confess i

16 that I have heard some instances in which TVA's explanations 17 for why an issue is a Watts Bar issue and not an issue anywhere 18 else and they are perfectly plausible.

They make a lot of t

19 sense.

20 But on others, my instinct tells me that Watts Bar 21 was very similar to Sequoyah.

It was the same organization, a

22 the same kinds of managers were involved in the overall 1

l 23 efforts and my gut reaction tells me if those problems were 24 there at Watts Bar, some of them may have been there at 4

25 Sequoyah as well.

i I

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47 i

1 I think this is an area that really deserves careful l

t

2 attention.

3 MR. KEPPLER:

I don't have any problem with the 4

concept that TVA has used, the sorting.

5 COMMISSIONER ASSELSTINE:

Yes.

6 MR. KEPPLER:

But it behooves us to make sure that 7,

that effort was comprehensive.

8 COMMISSIONER ASSELSTINE:

I think that is all I 9

have. Lando.

10 CHAIRMAN ZECH:

All right.

Commissioner Roberts.

11 COMMISSIONER ROBERTS:

No questions.

12 CHAIRMAN ZECH:

Commissioner Bernthal.

13 COMMISSIONER BERNTHAL:

One or two questions, one of 14 which, I guess, relates to our own management structure here.

15 I assume and the sense I get from the way we are operating, 16 what do we have, 90 people are something like that, Jim?

17 MR. KEPPLER:

About 100.

18 COMMISSIONER BERNTHAL:

And since you pull these 19 from various offices and ranks throughout the Agency, this 20 would be sort of a matrix management organization in the 21 traditional sense, I guess.

The question that always arises 22 then somebody mentioned whether you are really getting the 23 good people, I guess Jim before, that is the first question 24 that always arises in that kind of organization.

25 The second one is how you interact then with the e

i.

48 1

existing organizations, for example, with the regions.

Could

?

2 you give me a little sense of how you are working with them 3

and I specifically have a question that I would like to ask 4

Chris in a minute about Region IV but I would like someone to 5

give me an overview?

6 MR. KEPPLER:

Yes.

I am sorry I didn't discuss that 7

in more detail because it is a good comment.

First of all, t

8 our organization is intended to be self-sufficient.

The 9

regional people report to me.

They do not work for Region II 10 or Region IV.

They report to the Office of Special Projects.

11 COMMISSIONER BERNTHAL:

Let me stop a minute.

For 12 anyone that you count in your 90 people, they are now in 13 effect full-time employees for you.

14 MR. KEPPLER:

That is correct.

15 COMMISSIONER BERNTHAL:

Good.

16 MR. KEPPLER:

Now in terms of what help I may seek 17 from other components of the Agency, Mr. Stello has counselled 18 me very strongly that I am accountable for what is done in 19 these projects and that he would prefer that I do very little 20 of handing out work to other parts of the Agency.

l 21 He would rather have me get people who I need and 22 bring them in for periods of time to do the job.

Now there 23 are certain things that will not make sense to do that.

For 24 example, operator licensing work.

It would be simpler to just 25 have tasked that to Region II or Region IV.

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

49 1

But for the most part, it is our intent to handle

/

2 all of the work within the office and even for any work that I 3

get down by other components of the Agency, they will submit 4

their product to us for review and we will be the ones to 5

accept t nat effort and deal with it.

6 MR. EBNETER:

May I add a comment?

7 COMMISSIONER ROBERTS:

Sure.

8 MR. EBNETER:

When Jim said the Regional Staff works 9

for us, that is the project management staff and resident 10 inspectors.

We are still relying to a great extent on the 11 technical specialists from the Regions to support us as a 12 resource pool.

Those people to the inspection plans and the 13 reports through our organization, and they report to us as we i

14 need them, but we don't have enough people to have a QA expert 15 on every panel or a welding expert.

16 MR. KEPPLER:

Maybe you and I have a little 17 misunderstanding, and we need to talk about this, because --

18 let me leave it that way.

19 (Laughter.)

20 MR. EBNETER:

I don't want to mislead you.

The 21 Regional Staff does not report to us.

22 MR. KEPPLER:

It's embarrassing.

23 COMMISSIONER BERNTHAL:

You understand the reason 24 for the question and my concerns that ha've always attached to 25 that kind of superstructure organization or overlay over e.

-w-,-

50 1

another organization.

j' 2

MR. STELLO:

We hold fully accountabElity, 4

3 responsibility, and authority.

4 COMMISSIONER BERNTHAL:

Well, those words are all i

5 good,-but let's make sure they work.

6 MR. STELLO:

That is the way in which the

~

l*

7 organization is set up, It is that way.

i 8

COMMISSIONER BERNTHAL:

I think the right idea, 9

though, is the one that you mentioned, that those 90 people i

f 10 for the duration work for you, because when they start getting 1

11 split loyalties, then things start falling apart.

l 12 MR. STELLO:

Correct.

l 13 CONNISSIONER BERNTHAL:

Now maybe the other question 14 I had in that regard has been answered, but I want to focus

{

15 specifically on comanche Peak and some of our own internal 16 difficulties, which were well aired in public last week.

17 Chris, can you give me a sense of whether that is

[

18 causing any difficulties at all in carrying out the j

19 responsibilities that you have with respect to Comanche Peak?

l 20 Are we in a --

f 21 MR. CRIMES:

I'll be quite frank, sir.

I have what 1

22 I view as one of my principal obstacles in getting the Comanche 23 Peak efforts organized is to try and deal directly with the l

24 morale problem.

For the inspection staff, we have assumed --

25 we're working right now to try and get Bill Forney out of r

i

51 1

Region III to go down to the site and head up the inspection t'

2 staff there, and I expect that I'll spend quite a bit of time 4

3 over the next month just trying to deal with the attitudes and 4

the concerns that that issue sort of clouds for the inspection 5

people.

4 6

COMMISSIONER BERNTHAL:

Well, I'm not surprised.

7 M'. STELLO:

The issue is broader than that, and R

8 morale is the pits in Region IV.

j 9

COMMISSIONER BERNTHAL:

Okay.

That's a straight 10 answer, and I don't guess I need to say that that bears some 11 attention.

12 MR. STELLO:

Thursday, I hope we can have the l

l (

commission's focus on that point.

13 14 COMMISSIONER BERNTHAL:

Good.

i 15 COMMISSIONER ASSELSTINE:

Very soon.

t 16 COMMISSIONER BERNTHAL:

One specific question about 3

j 17 the EQ problems at Sequoyah.

I hope you haven't answered this 18 already.

But do you have a sense for how many of the problems, j

19 rough percentage maybe or qualitative view, how many of the 20 problems in EQ down at Sequoyah were truly hardware problems l

21 that, in fact, could have affected plant safety and performance 22 under accident conditions, as opposed to how many now are l

23 appearing to be sloppy documentation which initially, at least, I

i 24 was the focus.

I I

25 MR. EBNETER:

I don't have a percentage, but the i

i

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52 1

majority of the problems were paperwork supporting that i

^

2 justification or qualification.

There were some hardware i

3 changeout cables in particular.

They had to replace some 4

cables.

5 COMMISSIONER BERNTHAL:

Right.

4.

6 MR. EBNETER:

Some replacements of materials within x

7 components that didn't have sufficient age, but the bulk of the problems were paper-oriented.

8 4

9 COMMISSIONER BERNTHAL:

Okay.

I guess that's 10 somewhat encouraging.

11

)

I guess that's all I have right now, Mr. Chairman.

12 j

COMMISSIONER ASSELSTINE:

Lando, I had --

13 CHAIRMAN ZECH:

Yes, go ahead.

i 14 COMMISSIONER ASSELSTINE:

I have two others that 15 arose out of Fred's.

4 16 On this accountability and responsibility question, 17 I take it, based upon the previous discussion, that NUREG-1150 18 is not your responsibility?

Or is that your responsibility

)

19 and you're stuck with the research?

i f

20 (Laughter.)

21 COMMISSIONER BERNTHAL:

That's our responsibility.

l 22 COMMISSIONER ASSELSTINE:

Or is that something 23 you've got to sort out?

24 MR. STELLot I've answered the question as best I l

25 know how.

I don't know what we're going to do in terms of

53 1

requiring it.

I wanted to be sure the Licensee had the

?

2 report.

When'he got it, he had other information we're 3

unaware of.

It isn't clear to me we need to require anything 4

yet.

That's a major policy question for the Commission.

5 Aside from answering that policy question, when I 6

saw the report, it was apparent to me that the Licensee ought 7

to have it.

8 COMMISSIONER ASSELSTINE:

Yes.

I don't disagree 9

at all with that, Vic.

10 MR. STELLO:

What we do with it is another matter.

11 COMMISSIONER ASSELSTINE:

My only question is --

12 MR. STELLO:

So I'm responsible; yes, I'm responsible i

13 for --

14 COMMISSIONER ASSELSTINE:

That is research to you 15 and to us.

i l

16 MR. STELLO:

That's right.

J

]

17 COMMISSIONER ASSELSTINE:

Okay.

18 MR. STELLO:

And you are.

19 COMMISSIONER ASSELSTINE:

Good.

4 20 MR. STELLO:

You will have to make a decision.

21 COMMISSIONER ASSELSTINE:

Sounds great.

Okay.

I 22 just wanted to clarify what was and wasn't in Jim's bailiwick.

23 The other question had to do with Comanche Peak.

I 9

24 The people you're using now on the Comanche Peak review, the i

i 25 people you've brought into the Office of Special Projects, how t

8

54 1

many of those people are the people from Region IV that have

(~^

2 been involved in the Comanche Peak project for an extensive 3

time, versus how many are new people that you've brought in 4

from other Regions or from Headquarters or whatever to focus 5

on the problem?

6 MR. KEPPLER:

Let me answer that first.

I want to

~

7 give you a general view first.

8 COMMISSIONER ASSELSTINE:

Okay.

9 MR. KEPPLER:

Right now, the intent was to use the 10 people on the project because of the hearings situation.

11 They've got the history.

12 I decided that I was going to bring in outside 13 supervision for the site, and that still is my intent.

14 COMMISSIONER ASSELSTINE:

Okay.

15 MR. KEPPLER:

For those inspectors that are down 16 there at the site, I'm going to give them an opportunity to 17 prove themselves.

If they don't cut it, I'm going to remove 18 them.

19 COMMISSIONER ASSELSTINE:

Okay.

Good.

That's all I 20 have.

21 CHAIRMAN ZECH:

It sounds like although you've got' 22 your organization in place, you still have a few lines of 23 authority to clarify, and I presume you will do that soon, 24 because it.is pretty fundamental. 'And I recognize it's new, 25 and it's not surprising that you're not completely clear.

But

55 j

1 it is important that you get those decided rather quickly, and 2

I know Mr. St'ello will help you, Jim, if you need some help in l

3 that regard.

i 4

Also a new organization like this, it's Special t

5 Projects.

I've dealt with them in the past, too.

It is a j

6 different arrangement.

What's important, I think, is that you 7

do get the support from the rest of the Staff, and I recognize 8

you touched on that briefly.

9 But, you know, you have a good number of fine 10 people, I know, in your new organization, but you also have j

11 the whole rest of the Staff, or certainly a great deal of the 1

12 rest of the Staff, to call upon if you need them for help.

So i

13 I appreciate the fact that you're trying to, you know, have l

l 14 within your own organization the talent you need to do the 15 job, but as you point out, in the examining situation -- and i

16 there are others, too -- there are other parts of the Staff, j

17 research and other areas, that certainly you can call on if 18 you need help, and they don't have to be directly under your l

l 19 control.

1 20 So these are kind of, as I think, kind of fundamental 21 things, so you should not feel like you are completely confined i

22 to the people in your crganization, although I recognize that i

23 Vic is trying to make you feel the responsibility and authority f

24 and accountability, and I think that's Appropriate.

25 But again, you have a lot of talent to call on this j

i i

i

56 l

1 agency, and you should feel that you can do that and work f' ~

2 those possibilities out.

3 Again, though, I guess the last thing I would like-2 4

to emphasize is the importance of taking the time that's 5

necessary to review the TVA proposals and procedures and plans 6

and so forth, as well as do your inspecting and verification i

7' and all that.

8 This is a time consuming process, and we have -- we 2

l 9

must have more time than just getting it the last minute and 10 being expected to review it.

And here at Headquarters, the l

11 help you might ask in various organizations, too.

It takes 12 time to do this kind of reverification properly, and I think 1

13 we need to take the time.

14 So certainly we want to be as responsible and as l

15 responsive as we can, and I think that's exactly why your 16 organization is in place, and I fully support it.

But I just

{

17 want you to know that you should not feel that you're under a 18 strain to buy off on anything in a hurry.

You should feel 19 confident that if you need the time, take the time.

I think i

f 20 the Commission supports that, and certainly I do.

I j

21 MR. KEPPLER:

I appreciate those comments.

22 CHAIRMAN ZECH:

Unless there are any other comments i

23 from my fellow Commissioners -- yes?

24 MR. STELLO:

There's one thing'that I've been l

25 reflecting on, and that was Jim's speculation for when this l

4

- ^ - - - - - - ^ - - - - - - ' - - - - -

57 1

plant would be ready.

We have the Licensee's estimate.

It's

(~

2 thought out aIs best they can, and Jim's judgment is, it's 3

optimistic.

4 When Jim speculates on another date, there's the 5

suggestion that that's based on any kind of analysis or 6

whatever, and I assure you that we have no basis upon which to 7

say that we have a systematic analysis that leads us to 8

conclude any date.

The date that we're going to have to 9

eventually come to is when the Licensee is ready and we're 10 finished.

11 COMMISSIONER BERNTHAL:

It's too late, Vic.

The 12 headline is already written.

I 13 (Laughter.)

14 MR. STELLO:

It may be, but at least if we're asked, 15 what was the basis for that statement, it ought to be fair 16 that it's just a guess.

We don't have any analysis.

17 MR. KEPPLER:

And I think I phrased it that way.

18 COMMISSIONER ASSELSTINE:

Yes.

I think Jim did, 19 too.

t I

20 But I guess my only concern is, obviously we get 21 asked about things like this.

The Chairman was asked or the 22 Commission was asked at the last Appropriations Committee 23 hearing, and basically I think t'aat we want to do is have some 24 feel for the current Staff thinking, you know, couched and 25 qualified,as much as is appropriate, because we were asked

o 58 1

point blank:

This July date, is it realistic?

f 2

And the Chairman's response was, "I think it's kind i

3 of optimistic, maybe in the right ballpark, but I think it's 4

4 kind of optimistic."

We don't want to mislead people.

5 MR. STELLO:

I think, as regulators, that's fair.

6 An answer that is not fair is one when you replace their date 7

with yours, and you don't have an analysis and the milestone 8

charts that back it up.

9 COMMISSIONER ASSELSTINE:

Sure.

10 MR. STELLO:

It certainly leaves the impression that 11 we have some sort of a basis upon which to come to some other 12 date.

lr 13 COMMISSIONER BERNTHAL:

How about December, plus or 14 minus six months?

i l

15 (Laughter.)

16 MR. STELLO:

That would at least include their date.

17 CHAIRMAN ZECH:

All right.

I think we've taken care 18 of this one.

19 Thank you.

The meeting is adjourned.

20 (Whereupon, at 11:28 o' clock, a.m.,

the meeting was 21 adjourned.)

l l

22 23 24 25 l

l.

- - - - - - ~ - ' -

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:

Brjefing by Office of Special Projects 8

PLACE OF MEETING:

Washington, D.C.

9 DATE OF MEETING:

Wednesday, April 15, 1987 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken i f 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and i

15 that the transcript is a true and accurate record of the 16 foregoing events.

17 18

-MdW quewdf:?l 9 542._____

Marilynn Nations 19 20 21 22 Ann Riley & Associates, Ltd.

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0SP - TVA PRIORITIES & SCHEDULES 1-SEQUOYAH RESTART - LICENSEE SCHEDULES:

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UNIT 2 - 1988 UNITS 1 & 3 - LONG TERM OUTAGE 3-WATTS BAR - LICENSEE PLANS To DEFER OL RE-EVALUATION AND REWORK EXPECTED TO TAKE TWO YEARS (1989) 4-BELLEFONTE - LICENSEE PLANS To DEFER OL To EARLY 1990S PLANTS IN LAYUP e

3

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OSP - TVA THRUST 1

DETERMINATION OF SCOPE OF WA PROGRAMS l

VERIFICATION OF IMPLEMENTATION 4

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SEQUOYAH MAJOR ISSUES MANAGEENT - ORGNUZATION TECHNICAL ALLEGATIONS OPERATIONAL READINESS 5

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TECHNICAL QUALITY ASSURANCE QA PROGRAM (TOPICAL APPROVED)

QA PROGRAM IMPLEMENTATION DESIGfl DESIGfl CONTROLS DESIGN BASELINE VERIFICATION PROGRAM NUREG-1150 vS IPE PROCUREMENT PIECE PARTS DESIGN OUTPUT - PROCUREMENT INTERFACE MATERIAL TRACEABILITY blECTRICAL CABLE DESIGN - AMPACITY CABLE INSTALLATION FUSE REPLACEMENT PROGRAM ENVIRONMErlTAL QUALIFICATION PROGRAM RECORDS HARDWARE (SPLICES, CABLES) e 7

ALLEGATIONS EMPLO'EE CONCERNS (EC)

OLD EMPLOYEE CONCEPfi PROGRAM AND OTC NEW EMPLOYEE CONCERNS FROGRAM s

INTIMIDATION AND HARASSMFlfT ALLEGATIONS NSRS CONCERNS 4

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-ORRATIONAL READINESS J

VOLUME II 0F TVA PLAN MAINTENANCE SURVEILLANCE INSTRUCTIONS START-UP IEST PLAN WA OPERATIONAL READINESS REVIEW-1 i

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4 4

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A."

STATUS OF ISSUES ISSUE A

]l C

CORPORATE PLAN X

QUALITY ASSURANCE X

DESIGil CONTROLS X

DESIGN BASELINE VERIFICATION X

NUREG-1150 X

PIECE-PART PROCUREMENT X

DESIGN PROCUREMENT INTERFACE X

MATERIAL TRACEABILITY X

AMPACITY X

CABLE INSTALLATION X

FUSE REPLACEMENT X

EQUIPMENT QUALIFICATION X

SURVEILLANCE INSTRUCTIONS X

MAINTENANCE X

TEST PLAN X

ALLEGATI0ftS/ EMPLOYEE CONCERNS X

A.

NRC AND TVA IN AGREEMENT RE HAtlDLING OF PROBLEM.

NRC REVIEW SCHEDULE CONSISTENT WITH LICENSEE SCHEDULE.

B.

NRC AND TVA Ifl AGREEMENT RE HANDLING OF PROBLEM.

LICENSEE SCHEDULE OVERLY OPTIMISTIC OR NRC REVIEW IS BEHIND SCHEDULE.

C.

QUESTIONS EXIST RE HANDLING OF PROBLEM.

10

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Document Control Desk, 016 Phillips

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3 ADVANCED COPY TO:

The Public Document Rocm 3

DATE:

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SECY Correspondence & Records Branch h"

E Attached are copies of a Commission meeting transcript and related meeting AA i

document (s). They are being forwarded for entry on the Daily Accession List and E

placement in the Public Document Room. No other distribution is requested or h

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required.

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Meeting Titie:

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