ML20214D319
| ML20214D319 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8611240019 | |
| Download: ML20214D319 (70) | |
Text
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.a GRIGINAL C
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Briefing on Improving Effectiveness of Initial Startup Programs (Public Meeting)
Docket No.
Location:
Washington, D. C.
Date:
Friday, November 14, 1986 Pages:
1 - 55 ANN RILEY & ASSOCIATES
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1625 1 St.,,
N.W.
C,ourt Reporters hog 12 0jk061114 Suite 921 PT9.7 PDR Washington, D.C. 20006 (202) 293-3950
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4 1
D I SCLA 1 MER 2
3 4
5 6
This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on 3
11/14/86 In the Commiss,lon's office at 1717 H Street, 9
'N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may cont &in 12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of de' cision of the 16 matters discussed.
Expressiens of opinion in this transcript 17 do not necessarily reflect final determination or befiefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.
22 23 24 25
i
/
4 1
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 BRIEFING ON IMPROVING EFFECTIVENESS OF 5
INITIAL STARTUP PROGRAMS 6
7 PUBLIC MEETING 8
9 Nuclear Regulatory Commission 10 Room 1130 11 1717 "H" Street, N.W.
12 Washington, D.C.
13 14 Friday, November 14, 1986 15 16 J'.e Commission met in open session, pursuant to 17 notice, at 10:02 o' clock a.m.,
LANDO W.
ZECH, Chairman of
~
18 the Commission, presiding.
19 20 COMMISSIONERS PRESENT:
21 LANDO W.
ZECH, Chairman of the Commission 22 THOMAS M. ROBERTS, Member of the Commission j
23 FREDERICK M. BERNTHAL, Member of the Commission 24 KENNETH M. CARR, Member of the Commission 25
/
s 2
1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
2 S.
Chilk 3
W.
Parler 9
4 J. Taylor 5
J. Partlow 6
F.
Hebdon 7
G. Holahan 8
AUDIENCE SPEAKERS:
9 M. Williams 10 11 12
^ s.
13 14 15 16 17 18 19 20 21 22 23 24 25
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3 1
PROCEEDINGS 2
CHAIRMAN ZECH:
Good morning, ladies and gentlemen.
3 Commissioner Asselstine will'not be with us this morning.
His 4
assistant is here, I note, and I am sure he will have the 5
opportunity to read the transcript.
6 This is an information briefing by the NRC staff on 7
the subject of improving the effectiveness of initial startup 8
programs.
9 The scope of the briefing addresses the activities 10 that take place in the period beginning with preoperational 11 testing and continuing through the first year of full power 12 operation.
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The NRC staff produced a report entitled. evaluation 14 of new plant experience dated August 21, 1986.
This report 15 identified the early operating experience at a newly licensed 16 nuclear power plant and noted that this experience has been 17 less than exemplary.
18 Since the experience shows that the licensees have 19 concentrated on the construction and preoperational testing 20 parts of the program and perhaps have not concentrated as much 21 as they might have on the full power testing and initial 22 operation phases, the Commission thought it would be 23 appropriate to hear from the staff in a little more detail on 24 this matter.
25 Do my fellow Commissioners have any opening
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A 4
1 statements?
2
[No response.]
3 CHAIRMAN ZECH:
If not, Mr. Taylor, will you 4
proceed, please?
5 (SLIDE.]
6 MR. TAYLOR:
Yes, sir.
Good morning.
The staff is 7
prepared to address the topic of the plant performance during 8
startup programs and during the early years of operation.-
9 This is a combined office briefing.
10 We have Jim Partlow here from IE to talk about IE 11 programs and the inspection effort related to plants in 12 startup.
Fred Hebdon is here from AEOD to talk about some of 13 the experience and information gathered during the early 14 startup period.
Gary Holahan will talk about some of the 15 activities in NRR.
16 We have worked together across the offices on this 17 subject and I believe you are aware that we talked about this 18 a bit at the last senior NRC management meeting.
So we in the 19 staff are conscious of the issues and we have various 20 activities currently underway within staff on the subject.
21 I will ask Jim Partlow to start the briefing.
i 22 CHAIRMAN ZECH:
Before you start, Jim, let me just l
i 23 say that I hope that we can confine ourselves to the allotted 24 time this morning.
Frankly, we have quite a busy schedule i
25 today.
At least, I think we really should do what we can to
a 5
1 finish by 11:30 and perhaps even before that.
So I would ask 2
you to be crisp and give us your key points and give us also 3
the opportunity to ask you some questions but please do your 4
best to stay within the time and beat that a little bit if you 5
can.
6 MR. TAYLOR:
Yes, sir.
7 CHAIRMAN ZECH:
Thank you.
8
[ SLIDE.]
9 MR. PARTLOW:
Thank you, Mr. Chairman.
On the first i
10 sheet of our briefing sheet, improving effectiveness of 11 initial startup programs, this summer in preparation for the 12 NRC senior management meeting this past October, the EDO asked 13 the staff offices to begin bringing together quantitative k'
14 information to use in help evaluating all operating plants.
15 That information came from IE's work on performance 16 indicators, from AEOD's trends and patterns programs and 17 Mr. Chairman, you mentioned the August report focusing on new 18 plants and from the work done by Mr. Holahan in the NRR 19 cperating reactor assessment data.
20 This data was brought together over the late summer 21 and during the October management meeting and it showed that 22 as a class newly licensed plants have been experiencing a l
23 relatively high level of operational events following their OL 24 issuance, the number of. plant trips, the number of technical 25 specification violations, ESF ac'tuations and so forth.
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6 1
So our purpose this morning is to give you a bit 2
more of that data by AEOD and then to tell you briefly what 3
the various staff offices are doing and how their programs 4
work as they relate to new plants.
5 Also, I think it is clear that a plant with not 6
necessarily having an outstanding record in construction or in 7
pre-operational testing does not necessarily translate into or 8
always result in good operational performance as they start 9
up.
10 So with that as an introduction then, if I could 11 please go to slide two.
Fred Hebdon is going to point out 12 some of the major highlights of their study.
r-13 COMMISSIONER ROBERTS:
Is there any difference
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14 between these two sets of slides, the one that I was given 15 yesterday and one that is on this table today?
16 MR. PARTLOW:
There should not be.
17 MR. TAYLOR:
I would use the one from today if you I
18 would, sir.
)
19 MR. PARTLOW:
The Secretariat put a set out this 20 morning.
21 CHAIRMAN ZECH:
You want us to use the one that was 22 on the table when we came in, is that what you are saying?
23 MR. TAYLOR:
YEs, sir, if you would, sir.
24 CHAIRMAN ZECH:
All right.
Go ahead, please.
25 (SLIDE.]
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7 j
1 MR. HEBDON:
The purpose of this slide is to 2
demonstrate that new plants are, in fact, different from old 3
plants.
AEOD recently conducted a study of the operational 4
experience of 13 plants and we looked at their experience 5
during their first year of operation.
6 We then took that information and we compared it to 7
the results of the performance of more mature plants during 8
1985 and as you can see from the data, we found that the new 9
plants tend to have more scrams, they tend to have more ESF 10 actuations and they also tend to have more tech spec 11 violations.
12 Now we feel that this is a cause for concern because 13 first of all there is obviously an elevated risk associated s
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14 with the higher rate of scrams and ESF actuations that are 15 occurring.
16 There is obviously a risk associated with each scram 17 and the more scrams the plant would have, the more risk would 18 be involved.
19 Also in our study we found that the plants that have 20 high rates early in their life tend to continue to have the 21 high rates later in life so we found that the plants that 22 start out with a high rate of scrams, for example, if we look at them later on in the life of the plant we find that they 23 i
24 generally tend to be in the higher groups of scram rates at 25 that point as well.
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1 CHAIRMAN ZECH:
Before you go on, that is a pretty 2
important observation.
3 COMMISSIONER BERNTHAL:
That's right.
4 CHAIRMAN ZECH:
Frankly, that has not been my view.
5 I will be very anxious to hear what you have to say about 6
that.
It seems to me that we have had some plants that did i
7 have a number of problems during the startup phase, but 8
settled down and really performed quite well afterwards.
9 The second point I would like to make is the fact 10 that we should be concerned about scrams.
We should be i
11 concerned about ESF actuations and so forth but the startup 12 phase and the testing phase is indeed just that, a testing
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13 phase.
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14 We expect to have for the first time when you start j
15 the plant up, experience has shown us that we always are going f
16 to have some things to show up and that is what the period is 17 for.
It is a testing period.
18 Whereas, we would rather have it operate without any i
19 problems at all, we, I think, have to recognize that there 20 probably will be some problems.
I think the thing that 21 concerns me most is that when we have those problems, we solve 22 them and as soon as possible performance levels out and 23 performance improves and especially improves during the 24 operational period.
25 So that is at least what I think we should -- that t
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1 is our goal and I would be interested to hear at least some of 2
your thoughts on the problems we are having in perhaps trying 3
to achieve that goal.
4 MR. HEBDON:
The point I would make is that there 5
are certainly exceptions to the rule of problems that have a 6
lot of plants early seem to have a relatively high number and 7
certainly there is a learning curve and their rates later in 8
life are lower than their rates early in life but relative to 9
plants of a similar age, we find that they do tend to cluster 10 and obviously, there are certe. inly exceptions to that.
11 CHAIRMAN ZECH:
We want to see improvement, no
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12 question about that.
But all I am saying is that we kind of 7
13 expect that there will be some period during the startup and 14 testing period where we are going to learn things that we 15 haven't been able to check out at all until the plant comes to 16 life so-to-speak.
17 So when you do bring the plant to life, you for the 18 first time are able to check certain instruments and check 19 other things that you know you have to adjust.
You expect an i
20 adjustment period.
The adjustment period sometimes relates to 21 more problems than you would hope to have.
22 On the other hand, it is a testing period and it 23 seems to me we should recognize that and the key thing then is 24 that it should improve after that.
So improvement is what we 25 are looking for.
But, please, go ahead.
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10 1
MR. HEBDON:
Yes, sir.
The other point that we 2
found of interest in the study was that we did find that there 3
are new plants that seem to have relatively low rates.
We 4
find that some of the new plants when they come on line, their 5
experience with respect to scrams and ESF actuations, for 6
example, are comparable to some of the more mature plants.
7 One of the things that we are doing in our follow-on 8
study is to try to get a better understanding of why the 9
different plants are different.
We are trying to get a better 10 feel for why some plants seem to come on line without the 11 problems that other plants have.
12 CHAIRMAN ZECH:
Sure.
That is the valuable part of 13 your study, I believe.
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14 MR. HEBDON:
Yes, sir.
15 CHAIRMAN ZECH:
And that is what I believe is 16 important for us to focus on those aspects of it.
17 MR. HEBDON:
The study that we have done to date was 18 based primarily on the data that we have received.
19 The second phase of the study, we are actually going 20 out to the plants and we are taking a sample of plants ~that 21 seem to have high rates and plants that seem to have low rates 22 to try to get a better understanding of why the different 23 plants are different and to get a feel for why some plants 24 seem to come on line with fewer problems than other plants.
25 CHAIRMAN ZECH:
Sure.
Those are the lessons learned ^
J 11 1
that are important to us.
2 MR. HEBDON:
Yes, sir.
3 CHAIRMAN ZECH:
But also, I think you ought to point 4
out if you can our regulatory responsibilities in this period, 5
are there violations that happen that should not have happened 6
and will they lessen in time and experience, too?
7 But you go ahead, please, and we will perhaps 8
discuss that with some of your colleagues as we go along.
9 MR. HEBDON:
Yes, sir.
The remaining point that I 10 did want to make is that we are conducting a follow-on to our 11 initial study and the purpose of the follow-on is to go to the 12 plants that have high rates and some of the plants that have 13 low rates to try to get a better understanding of why the
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14 different plants perform differently.
15 CHAIRMAN ZECH:
Fine.
Very good.
16 MR. HEBDON:
We hope to have that study finished 17 early next year.
18 CHAIRMAN ZECH:
All right.
i 19 MR. HEBDON:
The hope is that that will provide some 20 insight into why some of the plants seem to come en line with 21 relatively few problems and other plants seem to have more 22 difficulty.
23 CHAIRMAN ZECH:
Very good.
I 24
[At this point in the proceedings, Commissioner 25 Bernthal exited the Commission meeting.]
12 1
(SLIDE.]
2 MR. HEBDON:
The next slide is merely a graphical 3
presentation of some of the information that we have already 4
discussed.
What this slide is is taking just the scram rates 5
and then it is the percentage of plants that have the various 6
scram rates.
7 The cross-hatched bars are the older plants and the 8
solid bars are the newer plants.
As you can see, I think the 9
two points that are of interest from this is that there is 10 some overlap.
11 There are some new plants that are comparable to 12 some of the more mature p'lants.
The other thing, of course, 13 is that the distribution is different.
There is obviously a s,
14 spread, the newer plants tend to have the higher rates and the 15 older plants tend to have the lower rates but there is some 16 overlap.
17 CHAIRMAN ZECH:
What does new mean?
18 MR. HEBDON:
A newer plant is generally within the 19 first year of operation is the definition that we use.
20 CHAIRMAN ZECH:
But it is after the operational 21 testing phase at the beginning of generating commercial power, l
22 is that when you start that?
23 MR. HEBDON:
The period of time starts with the 24 initial operating license issuance and we have taken a one 25 year period from that date.
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13 1
CHAIRMAN ZECH:
In other words, you have included
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2 all the testing and startup in the scram rate for the new 3
plants.
4 MR. HEBDON:
We have included the --
j 5
CHAIRMAN ZECH:
The pre-operational phase, too.
6 MR. HEBDON:
It is from the issuance of the OL.
i 7
CHAIRMAN ZECH:
All right.
8 MR. HEBDON:
Prior to commercial operation.
9 CHAIRMAN ZECH:
So you would expect some of these 10 scrams.
4 11 MR. HEBDON:
That is true.
12 CHAIRMAN ZECH:
More for the new.
All right, go i
13 ahead.
14 MR. HEBDON:
You would expect more but the point 15 that I think is of interest is there are some plants that are 16 down there fairly far.
17 CHAIRMAN ZECH:
Sure.
18 MR. HEBDON:
This is on a per thousand critical hour 19 basis.
20 COMMISSIONER CARR:
Which skews it because some of 21 those early problems aren't of the critical type.
You have a 22 lot of problems before you go critical.
23 MR. HEBDON:
But these scrams are cases where the l
24 plant is critical.
25 (At this point in the proceedings, Commission
s 14 1
Bernthal re-entered the Commission meeting.]
2 COMMISSIONER CARR:
If this is from the OL, that 3
isn't when it goes critical.
4 MR. HEBDON:
No.
These are all scrams when the 5
plant was critical.
6 COMMISSIONER CARR:
Then you have excluded those 7
problems that occurred, well, naturally -- you don't have the 8
scrams that initiated when -- just a scram signal.
9 MR. HEBDON:
That is correct.
Those were not 10 included in the count.
11 COMMISSIONER CARR:
So these are operating scrams.
12 MR. HEBDON:
They are operating scrams and in some 13 cases startup scrams, scrams that occurred while the plant 14 was in the process of starting up.
15 COMMISSIONER CARR:
All right.
16 CHAIRMAN ZECH:
But you don't differentiate that.
I 17 think that is a very important point.
In other words on the 4
18 dark line, the new scrams if you look at all of them, I would 19 assume offhand that towards the left where you have just l
20 perhaps one to 2.5 scrams in the black and where they overlap, 21 perhaps those are plants that have gotten further along in the 22 operational phase and if that is true, then those over to the 23 right of that that are having more scrams might be in the 1
24 initial phases of testing and startup.
25 In other words, you don't differentiate the new.
It i
15 1
could be the very first time you go critical to the time when 2
you reach power.
3 MR. HEBDON:
In general, it is the first year of 4
operation of the plant for the plants that have had a year of 5
operation.
6 CHAIRMAN ZECH:
You don't start until after you have 7
had a year of operation, is that what the new means?
8 MR. HEBDON:
In general, yes, sir.
9 CHAIRMAN ZECH:
I am confused.
I thought you said 10 the new starts were from the startup phase.
11 MR. HEBDON:
No.
It starts from the period of where 12 they received their OL and it takes a one year period from 13 that.
14 CHAIRMAN ZECH:
But when they receive their OL at 15 the beginning of that period, there is a lot of testing that 16 goes on and it doesn't just jump right up to full power.
17 There is a long period.
18 MR. HEBDON:
That is true for all of the plants.
19 CHAIRMAN ZECH:
I understand that.
20 MR. TAYLOR:
Mr. Chairman, I think you are 21 suggesting tha' a further refinement of the data to go back 22 and that could be done rather than the grouping of the first 23 year.
24 CHAIRMAN ZECH:
Exactly.
25 MR. TAYLOR:
You may be able to separate out better
16 1
that test time in real startup.
2 CHAIRMAN ZECH:
That's it.
3 MR. TAYLOR:
The first time it is going critical, 4
the first ascensions.
5 CHAIRMAN ZECH:
Exactly.
6 MR. TAYLOR:
Is that really the real trouble and I 7
think the staff can do that.
8 MR. HEBDON:
We have done that in detail in the 9
study.
10 CHAIRMAN ZECH:
That would be meaningful because it 11 would essentially break down the dark curve and perhaps we 12 would learn something significant from that breakdown.
13 MR. HEBDON:
We have done that in the study itself.
14 We have broken it up by power level and different phases of 15 operation.
16 CHAIRMAN ZECH:
But I think it would be meaningful t
17 to show that.
l 18 MR. TAYLOR:
To show that data, yes sir.
l 19 CHAIRMAN ZECH:
,All right, go ahead.
{
20 COMMISSIONER BERNTHAL:
If I may say so 'etting back g
21 to your initial point though, Lando, we started out here by 22 saying that it turns out apparently from your data that the 23 plants that start out with problems continue to have problems.
24 That seems to me to be an entirely different point 25 than the point of the EDO's letter that went out to the t
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utility saying we are having too many plants that have trouble 2
with startup.
That is almost a separate matter.
What you are 3
really'saying is that we can predict if you are going to have 4
a poor operation within the first two months and you are going 5
to continue to have a poor operation if you have a poor 6
startup.
7 Those are two very, very different messages.
8 MR. TAYLOR:
Sir, I think you are right.
He tried 9
to clarify that that is in some cases.
I think we are going 10 to have to look harder at that data.
Fred, are you ready to 11 say that?
In all cases, you are not.
12 MR. HEBDON:
No.
As I said, there are certainly 13 exceptions to that and what we are trying to do in the 14 follow-on study is to get a better understanding of the 15 performance of the plants and, of course, we have the 16 performance indicator program as well that is very much 17 involved at looking at the performance of all plants.
18 That is the type of thing that we are trying to do 19 in the follow-on study is to get a better understanding.
The 20 initial study was done primarily just with the data.
21 CHAIRMAN ZECH:
I would just caution you to not jump 22 to that conclusion until perhaps you need to.
i 23 MR. TAYLOR:
I think that is appropriate.
24 MR. HEBDON:
Yes, sir.
25 CHAIRMAN ZECH:
Further work is needed.
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COMMISSIONER BERNTHAL:
That is really key.
2 MR. TAYLOR:
Right.
3 COMMISSIONER BERNTHAL:
Because if the point you 4
first made is true, then this doesn't necessarily have 5
anything to do with startup.
It has to do with that 6
pa'rticular utility or that particular plant.
7 MR. TAYLOR:
I don't think we are quite ready to 8
make that jump.
9 MR. HOLAMAN:
I think if you look at the 10 distribution on the chart, you will see that those plants 11 which you might say have a problem scram rate later in life 12 are really the ones that would be on the tail of the 13 cross-hatched curve and none of those is actually all that 14 bad.
None of them looks anything like the experience for the 15 new plants.
16 CHAIRMAN ZECH:
All right.
Let's move along, 17 please.
18 MR. HOLAHAN:
So it is a minor variation.
19 CHAIRMAN ZECH:
Go ahead.
20 (SLIDE.]
21 MR. PARTLOW:
Moving along to slide number four now 22 we are wanting to get into what some of the programs going on 23 in the staff offices and clearly in our regulatory programs, 24 we need to look at it from two aspects, first, for plants i
l 25 coming along, are they ready to operate, have they finished 1
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19 l
1 the construction phase, the pre-operational testing and are 2
they ready to move into power operations and then second, of 3
course, watching their performance from the time of initial 1
4 operations and on up.
5 So activities are going on in IE and regional 6
programs, by AEOD as you have heard with oversight being 7
conducted by the NRR, the licensing program office, and 8
finally that note that the EDO has requested that NUMARC pay 9
attention to the events at new plants.
10 COMMISSIONER CARR:
How are you going to evaluate 11 the adequacy of the inspection program and the SALP?
What is 12 your measuring stick?
13 MR. PARTLOW:
I have a slide a little bit later on
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14 that, Commissioner.
i 15 COMMISSIONER CARR:
All right.
16
[ SLIDE.]
17 MR. PARTLOW:
Moving on to slide five now'and the j
18 inspection program and what is done in the regions, first I l
19 wanted to note to you that we do place heavy inspection l
l 20 emphasis on plants during their pre-operational phase which we 21 consider to be about 18 months prior to the issuing of the 22 initial operating license and then for the first two years of 23 operations following their OL.
1 24 So for a typical single unit sight being 25 constructed, tested and operated, these are the round numbers
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of how much inspection time by budget we would devote to these 2
plants.
3 So note that it builds up to its peak during those 4
18 months prior to licensing.
That is the time when the 5
construction punch list is still being worked out.
The heavy 6
pre-operational testing is going on and so forth.
j 7
Although it does drop down at the start of 8
operations, it is higher relative to the level that we use at 9
a more mature plant, about 4.6 man years for two years fo'llowing OL and then down to about 4.1 man years.
So there 10 11 is inspection emphasis during pre-operational testing and 12 during the first two years of operations.
13 That two year figure comes from the Commission's 14 policy guidance that the staff pay extra attention during the 15 first several years of operation.
16 COMMISSIONER CARR:
But your heavier inspection time 17 is before this data bank starts?
18 MR. PARTLOW:
Yes, sir.
19 MR. TAYLOR:
That is dedicated because so many 20 systems are being checked out and just the sheer volume of 21 work requires more man power.
It is literally an intensive 22 period, the system turn over and checked out.
23 COMMISSIONER CARR:
But to solve the problem we are 24 looking at, you only have another half man year?
25 MR. TAYLOR:
Right.
This is, of course, the mean
21 1
and then what you will find that if a plant has problems, it 2
goes up.
The region diverts.
3 COMMISSIONER CARR:
That average is across all 4
plants.
5 MR. TAYLOR:
Right.
This is the planned number but 6
you will find, I think, --
7 j
COMMISSIONER CARR:
Some have two, some have six.
8 MR. TAYLOR:
-- Right, that in the first two years, if a plant is having some difficulties, the region shifts 9
10 resources to that plant, right, Jim?
11 MR. PARTLOW:
Yes.
We will cover that now on the 12 next slide, slide six, more about the inspection program.
13 (SLIDE.]
14 MR. PARTLOW:
After the issuance of the OL during initial plant startup and testing, we implement the operating 15 16 reactor inspection program and then on top of that is the 17 inspector's review of startup test procedures, witnessing of 18 selected tests and reviewing the evaluation -- evaluating the 19 results of tests.
20 We have dedicated coverage on each shift by 21 inspectors during selected periods when there is initial i
22 criticality, power ascension and so forth.
23 Now as Commissioner Carr noted, the budgeted numbers 24 are average inspection times.
We do not expect that amount of 25 time to be spent at every new plant.
We expect it to be
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22 1
modified by' performance and by events so that one plant might 2
be getting double that amount.
3 An extreme example would be Comanche Peak which is 4
really in the pre-operational testing but clearly we are 5
putting more people there than at other plants.
6 But during these first two years of operation are 7
guidance to the region is that they should not go below that 8
4.5 man years during those first two years of operations.
If 9
there ar,e probl,em at t, hat plant, they should ins'ect at a p
10 heavier level than that but not go below what we call the 11 basic inspection program during the first several years.
12 Now in the SALP program which evaluates performance, e
l 13 we also try to conduct those more frequently for new plants.
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14 We arrange to have a SALP conducted about six months prior to l
15 the operating license date as an input into the licensing 16 decision and then we ask the regions to conduct the next two 17 SALP's at 12 month intervals which is relatively frequent 18 during those first two years and then shift over to the more' 19 general schedule as for old plants of conducting them every 12 20 to 18 months depending upon the need, performance and so 21 forth.
22 COMMISSIONER CARR:
Is that the answer to my 23 question?
24 MR. PARTLOW:
No, sir.
I 25 COMMISSIONER CARR:
All right.
1 I
o
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-,,,-,.,,e
--,v,,
~
23 1
[ SLIDE. ]
2 MR. PARTLOW:
On slide seven, some other things that 3
are going on now and I hope this is the answer to your 4
question, commissioner.
5 Over the past several years and we are still doing 6
it now, we go back over our inspection procedures to try to
'7 emphasize the real quality of implementation of programs out 8
there as opposed to the paperwork or as opposed to the 9
program, emphasizing implementation as opposed to program 10 adequacy.
11 We have done this recently in our inspection 12 procedures on training and on maintenance and a new inspection k
13 procedure on corrective actions, one that we hope to get out 14 soon on the quality assurance organization.
15 So Commissioner, this is what I meant by 16 re-evaluating our whole inspection approach and trying to more i
17 and more turn it towards being the actual observation and 18 evaluation of performance and not, dwelling so much on whether 19 or not all the "i's" are dotted in the program plans.
20 MR. TAYLOR:
In the QA area as an example, we are 21 emphasizing for whatever attributes the quality organizations i
22 can contribute to this period that they get people with 23 operating experience helping in their overview and auditing of 24 activities, a very simple-minded thing.
25 But very frequently QA organizations don't take O
_~ _
4 24 1
advantage of technical expertise or get it to apply to their 2
activities in overviewing what is going on.
It seems 3
illogical if you ara going to overview operations, you get 4
people with ops. experience to augment the normal QA process.
'5 CHAIRMAN ZECH:
I agree.'
That is a very important 6
point.
7 MR. TAYLOR:
I get very upset to find that this sort 8
of simplistic thing gets mixed so often in quality assurance 9
organizations.
10 CHAIRMAN ZECH:
It is a matter of coordination.
11 MR. TAYLOR:
Yes, sir.
You borrow people.
A 12 CHAIRMAN ZECH:
And cross-fertilization, that's 13 right and it is a very important point and things learned i
14 during your quality assurance program especially during this 15 early phase is sometimes correlated directly in my view to 16 operations, maintenance, other areas and certainly should be 17 taken advantage of.
I certainly agree with you.
18 MR. PARTLOW:
Now another program that we think is 19 going to help in our communication of our concerns with 20 industry is the performance indicator program.
The 21 performance indicators that have been established and now in 22 the future we will look at new plants as a class as well as 23 new plants in relation to old plants.
24 So we are going to have information about how the 25 trip rates are going and so forth on a quarterly basis so that
25 1
it won't be at the end of their whole start-up period or the 2
end of one year or two years that we say to that utility, 3
" Gee, you had a terrible record over the past two years."
4 Now we will have this information on a quarterly 5
basis.
We can talk to them about it and we will have the 6
basis to show them that maybe their are an outlyer compared to 7
their brother plant and so forth.
8 So we think that that will give us trend information 9
that will allow us to ask questions and to communicate with 10 the industry.
11 Finally the new plants will continue to be a 12 separate subject with the semi-annual NRC management meetings 13 in the future.
14 Now that completes the IE inspection regional 15 aspects and now we will go back to Fred Hebdon talking about 16 additional studies in AEOD.
17 CHAIRMAN ZECH:
Before you go into that, let me just 18 make a note on the performance indicator statement you made.
19 As you know I support that program but it has not fully been 20 approved by the Commission yet.
21 If it is approved by the Commission, I would 22 certainly hope that you could look at this startup period and 23 how it does correlate and it would be a very difficult 24 performance indicator to come with, I submit, but it would_be 25 very valuable if you could point out so we would know early on a
26 1
in the life of the plant perhaps to concentrate on a certain 2
plant.
3 So it would be a very valuable performance indicator 4
if in time you develop enough information to conclude that 5
there would be a correlation.
)
1 6
MR. TAYLOR:
Yes,. sir, to break the data down even 7
further as you have indicated.
8 CHAIRMAN ZECH:
Right.
Thank you.
All right, let's 9
proceed.
10 MR. TAYLOR:
Yes, sir.
11
[ SLIDE.)
12 MR. HEBDON:
As was mentioned earlier, we did 13 conduct a new plant study, the first phase of it, and that
(
14 report was issued in August of this year.
We are conducting a 15 follow-on study as I mentioned earlier.
16 It is based on visits to the plant rather than on 17 the data received from the plant as was the case with the 18 first phase and we hope to finish that study in early 1987.
19 As I mentioned earlier, the point of it is to try to determine -
20 why the new plants,are different and to determine why some 21 plants seem to have a low rate even as a new plant.
22 the other item is the increased participation in the 23 plant readiness activities.
The two types of things that we 24 are trying to do is that as a plant approaches its readiness 25 review, we try to insure that we provide to the people
i i
j 27 1
conducting the review information about other units at that 2
site.
3 For example, if it is a unit two, we will provide 4
information on the startup problems that occurred at u it one 5
to make sure that they have been addressed for unit two.
t 6
The other thing is to try to just provide general'.
~ 7 information on the kinds of startup problems that we have 8
observed in the data to make sure that the plant has, in fact, 9
addressed the various problems that might confront them as s
10 they get ready to startup.
l
\\
11 The idea again is to try to feed the operational 12 experience from this plant and from other units back into this
(
13 readiness review approach.
(
14 The other thing is that we are working with the 15 other offices to consider many of these other options that are 16 being discussed by IE and by NRR to' insure that we do have a 17 good program for the new plants.
18 MR. TAYLOR:
Gary.
19
[ SLIDE.]
20 MR. HOLAHAN:
I would just like to take a few 21 minutes to talk about some of the NRR activities on'new 22 plants.
The word " oversight" will show up a few places and 23 basically what we are talking about is not a new elaborate 24 program but it is really just a matter of focusing the normal 25 resources and coordinating activities on new plants.
^,
., ~ -,
28 1
It is a matter of using the project managers and 2
technical reviewers in cooperation with the regional people in 3
monitoring new plant activities and trying to understand what 4
is going on at those plants and eliciting corrective actions S
where it seems appropriate.
6 The process really starts with reviewing operating 7
experience on a day-to-day basis, picking out problems whether 8
they are new plants or old plants on a day-to-day basis as 9
opposed to performance indicators where you might wait three 10 months for a set of data or, in fact, several quarters to see 11 a trend in the data.
12 For new plants, their learning experience is so 13 rapid that if you want to understand it, you need to be in 14 contact with the utility much more frequently than on a 15 quarterly basis and so in the normal course of reviewing 2
16 operating experience.
17 Day-to-day we do keep track of what is happening on 18 the new plants, have that information fed back to the project 19 managers and the technical people in NRR who are dealing with 20 the original licensing of the plant and kind of an ongoing dialogue with the resident inspector and the regional people 21 22 involved.
23 As you know in the licensing process between the time of low power licensing and full power licensing, the 24 25 staff does look at the experience that occurs at that point
1 29 1
and normally bring it to the Commission before full power 2
licensing.
3 Frequently, that is only a matter of one or two 4
months but it is usually important to see how the licensee is 5
performing at that time.
In fact, performance at that period 6
is usually not what you would expect of an older plant.
We do 7
see many startup problems but basically what you are looking 8
at is startup problems compared to the startup problems of 9
other plants.
10 Are they going through their low power phase in an 11 adequate basis so that you think you are prepared to give them 12 a full power license?
That is a normal part of making the 13 decision about readiness for going above five percent power.
7 I
s 14 COMMISSIONER BERNTHAL:
I have to say so far I have 15 seen very little data.
We saw data on scrams.
I see the data 16 that was published in "Inside NRC."
That is about it.
I am 17 just wondering what kind of correlations you may have made or 18 you may have between these startup problems, correlations 19 between plant vintage and the startup problems, plant vendors i
j 20 and the startup problems.
1 l
21 So far I am not very convinced.
I am hearing a lot 22 of words but I am not seeing much data and the basis of this 23 ought to be data it seems to me.
24 MR. HOLAHAN:
I think there are volumes of studies 25 on new plant experience versus old plant experience.
I know
i 30 1
NRR has produced a few, AEOD has several.
The reason you 2
don't see it today is because the intent of the meeting was 3
not to present data but to talk about programs.
4 Perhaps it would be better if we supplied that 5
information separately.
But there is a lot of data available 6
and basically it shows a decreasing trend of problems through 7
about the first two to three years and then a clear leveling 8
off phase looking very much like the older plants.
Is there a correlation 9
COMMISSIONER BERNTHAL:
t 10 between older vintage plants and newer vintage plants?
Are 11 the BWR-6's having more trouble than the BWR-3's?
What are we 12 getting out of all of this?
13 MR. HOLAHAN:
I don't have all the data at my hands 14 but my recollection is that all of the studies are reasonably 15 similar in that the major variable that correlates is the age 16 and experience of the plants, that is, there may be minor 17 differences between BWR's and PWR's but the major difference 18 is between the plant in its first quarter, second quarter, 19 third quarter-versus the older plants.
20 So they all go through a learning phase and they are 21 all fairly similar.
22 COMMISSIONER BERNTHAL:
I am looking, for example, 23 at your ranking for Waterford which is one of the large BWR's 24 and it is low on your list.
It is clear down at 12 and yet it 25 has an 82-percent capacity factor and then I look at WPPS-2 l
l l
31 1
which is 14th and has a 42-percent capacity factor and then I 2
look at Susquehanna which is ranked almost the highest and has 3
a 68-percent capacity factor and I can't tell whether callaway 4
is a problem or not.
5 Callaway is a SNUPPS plant, apparently had a lot of 6
scrams and a lot of difficulties on your ranking scale and yet 7
I am told that they have excellent SALP's.
8 MR. HOLAHAN:
I am not sure whose ranking scale you 9
are quoting.
I am not familiar with it.
10 COMMISSIONER BERNTHAL:
I am reading from what the 11 press has from "Inside NRC," October 27, ranking, one, two, 12 three up through 16.
It is an AEOD ranking.
,m 13 CHAIRMAN ZECH:
Supposedly.
l.
14 COMMISSIONER BERNTHAL:
Right, supposedly.
Is that i
15 a reduction of data from us?
You didn't do that, I take it?
16 MR. HEBDON:
I think that is a reduction of the data 17 from the study.
18 MR. WILLIAMS:
Mark Williams from AEOD.
Apparently 19 McGraw-Hill put in the capacity factors.
Our study did not 20 have that data in it.
The capacity factors --
21 COMMISSIONER BERNTHAL:
Oh, it is not a ranking on 22 capacity factors.
It is -
23 ER. WILLIAMS:
It is kind of hybrid, I think.
24 COMMISSIONER BERNTHAL:
I think it is based on the 25 number of scrams and basically the things that you have
32 1
mentioned at the beginning of this talk as the guidelines for i
2 who is doing well and who wasn't and Saint Lucie-2, whoever 3
did this, Saint Lucie is one, Susquehanna is two and at the 4
bottom we have Byron and callaway and yet Callaway had 5
excellent SALP's and a pretty good capacity factor.
6 MR. HEBDON:
The purpose of the follow-on study is 7
to try to get a better understanding of this.
We looked at 8
the data and we took the data basically at face value for the 9
first phase of the study and we convinced ourselves of some of 10 the things that we have discussed but now in the second phase 11 of the study, we are going to these plants.
12 We are going to Byron and Callaway and Susquehanna 13 and Saint Lucia and some of these different plants and we are s..
14 trying to get a better understanding.
For example, with 15 respect to callaway, is callaway's problem just some unusual 16 design feature that was giving them a problem and they have 17 since fixed it or to try to understand better why the data l
18 looks the way it does, why Susquehanna and Saint Lucia seem to 19 be at one end of the spectrum and some of the other plants 20 appear to be at the other end.
21 MR. TAYLOR:
I think, Commissioner, you are raising 22 a point which I think any of these statistics lead you to.
We 23 dealt a bit with this with our first effort at performance 4
24 indicators.
We saw some of this very thing that 25 intellectually is disturbing to you as it is to us and that
33 1
is plants like Callaway and others by strict statistics of l
i 2
trips and some of the other things may lead you to raise 3
questions and yet their general performance as a licensee has 4
been rated quite high in SALP.
5 So you have these disparities and again, I think 6
this is very good at what you are doing and then you mentioned 7
capacity factors and WNP capacity and you know at times WNP-2 8
has been held down because there was a surplus of power in the 9
northwest.
I happen to know that because I got that somewhere 10 in the data.
11 So you have to go behind some of these things to 12 truly understand what the statistics are telling us.
13 COMMISSIONER BERNTHAL:
My point is that we are not
(
14 getting the kind of correlative data that it seems to me would 15 make a briefing like this more interesting at least to me.
I 16 misspoke by the,way, my staff reminds me that Waterford is a 17 Combustion plant.
I was confusing it with River Bend which 18 didn't look so good in terms of the number of problems they 19 had.
20 MR. TAYLOR:
Right.
21 COMMISSIONER BERNTHAL:
Frankly, the correlations 22 that I am not seeing would be very interesting, I believe, 23 and you don't need to go to the plant to get those 24 correlations.
They are in your data somewhere and I will tell 25 you what my gut instinct is and I may be dead wrong, it is
..-,.,.,,-v-n.
m w,...------v-
34 1
that these very newest design, very large plants, have tended 2
to have a lot of problems that the older design two-loop 3
Westinghouse PWR's, for example, startup and run.
4 Now I don't know whether that is true but those kind 5
of correlative data, it seems to me, would be very nice to 6
have.
7 MR. HOLAHAN:
We do have one piece of data.
I don't 8
have a slide but I do have a chart with me.
Maybe I can hold 9
it up.
10 Perhaps we are not prepared to get into as much
't 11 statistics on the data as you would like but this is a chart 12 showing basically frequency of reactor scrams for year of 13 startup first, second and third years where the modern plants
(
14 which are those licensed within the last two to two and a half 4
15 years are compared with the very early experience of plants 16 licensed before 1972.
17 The general trend is very similar, I would say.
18
[At this point in the proceedings, Commissioner 19 Roberts exited the Commission meeting.]
20 COMMISSIONER BERNTHAL:
That is still different.
4 21 The thing that I was pin-pointing is --
22 MR. HOLAHAN:
There may be subsets within those.
23 COMMISSIONER BERNTHAL:
-- I want to see earlier 24 vintage plants that have just come on line compared to these 25 very new and complicated plants that have just come on line.
l l
35 l
1 That is something different again.
\\
~-
2 MR. HEBDON:
As Gary mentioned, there is a 3
considerable amount of data behind the information that we 4
provided and we haven't presented it today because I think the 5
feeling was that the emphasis was on the programs and the 6
activities that are going on to address the new plants.
l 7
But there is quite a bit of data.
We looked at the 8
data and we tried to cross-cut the data in a lot of different 9
ways to see what various areas indicated differences and which 10 areas didn't indicata differences.
A lot of that has been l
11 done.
1 12 COMMISSIONER BERNTHAL:
I guess I would like to see 13 some more of that kind of correlation.
14 MR. TAYLOR:
Yes, sir.
I think you are asking 15 reasonable questions but the staff has not had in all cases 16 the opportunity to cross-cut it.
l 17 j
COMMISSIONER BERNTHAL:
Here is another one, for 18 example.
It looks like "Inside NRC" has done a pretty good 19 job here of correlating some data.
They have also listed 20 which licensees here are first time and which have previous 21 experience.
22 MR. TAYLOR:
That is another way of cutting it.
23 MR. HEBDON:
That type of analysis in many cases 24 comes from the study that we did and we could certainly 1
25 provide a copy of the study that has a lot of that data
_-._.m,_
y
_ -... -. _ _ _ - - _ ~,. ~, -..,, -.
4 36 1
cross-cut in many different ways.
2 CHAIRMAN ZE H:
I agree we need more data and it is 3
just not a matter of you giving us more data.
I think the 4
whole subject is an extremely important one, a very valuable 5
one to us and what we are trying to focus on, too, is how we 6
can benefit most from the data we have.
So we need to look at 7
the data but we also need to analyze it and see what 8
conclusions we can draw being very careful not to draw the 9
wrong conclusions because some of the data we recognize does 10 not correlate and where it doesn't, then we say why.
i 11 That is the important question to ask, why doesn't 12 it.
Maybe we can learn something from that and as you point 13 out, there are certain places where there are good reasons why 14 it doesn't correlate but that is important for us to know and 15 then if we find out we can determine why it doesn't correlate, 16 then indeed we will have something quite valuable because we 17 will know why it doesn't and why it does at least within some e
18 wedge of reasonableness.
2 19 That in itself is valuable.
So the data is 20 important to assure us with confidence that you are on the 21 right track, the same as you want to do, too, but also then 22 carefully, very carefully, drawing any conclusions you might i
with whatever caveats you need asking the question why when it 23 24 doesn't correlate and so forth.
25 So the whole effort, I think, is a very valuable L. -
s 37 1
effort in order to determine the lessons learned from the 2
experience we have received so far in order to benefit, 3
especially benefit, those newer plants still coming on line 4
and assist them in pointing our areas that they should 5
emphasize as well as we should emphasize in our inspection 6
program.
7 MR. TAYLOR:
Perhaps I could summarize it by saying l
8 that the staff really isn't prepared to give you good answers 4
9 on all the data.
We are at the stage where we are conscious 10 and have become more conscious as more and more plants have 11 come through this phase of an increased frequency of issues 12 and now we are at the stage of trying to correlate all that 13 and put it together.
14 So I don't think we are here today in any way able 15 to say we have answers.
In fact, some of us have looked for i
16 the easy common answers in some of this and haven't gotten l
17 it.
Do you agree with that, Gary?
l 18 MR. HOLAHAN:
Yes.
19 MR. TAYLOR:
Gary has been agonizing on this for 20 some time but I don't think we have those answers.
I 21 CHAIRMAN ZECH:
We don't want the easy answers.
We 22 want the good answers.
~
23 MR. TAYLOR:
No, I understand.
24 CHAIRMAN ZECH:
The right answers.
25 MR. TAYLOR:
Yes, sir.
l s
38 1
CHAIRMAN ZECH:
The best answers.
4 2
MR. TAYLOR:
The important thing is we are trying to i
3 tell you that the staff is trying to get into this to get the 4
kind of answers you would like to have.
5 COMMISSIONER BERNTHAL:
I have to say that as we are 6
headed, clearly headed, more and more into operations here and 7
evaluation of operations, the Chairman has taken an initiative 8
here to try and do something with these mountains of data that 1
9 we collect in this agency.
10 If you are going to have the data, you ought to do l
11 something with them and get some use and some value out of 12 them and the performance indicators, I think, are an attempt i
13 to do that.
i J.
14 But it occurs to me based on what I am seeing here 15 so far and also in the performance indicators business, how 16 many statisticians do we have around here and I don't mean the 17 guys that have advanced degrees.
I mean the people who 18 understand applied statistics and the practical aspects of how 19 to use data and make data meaningful.
i 20 You don't have to answer that right now but it 21 strikes me that we may need to look more carefully at our 22 capabilities in this area so we aren't kind of i
23
" seat-of-our-pantsing" the way through here.
24 MR. HEBDON:
We have a number of people within our i
25 office who have excellent backgrounds in statistics and one of
39 1
the things that we have been doing particularly within our 2
Trend and Pattern Program is trying to take people that have a 3
good background in engineering and people that have a good 4
background in statistics and put them together so that we get 5
the synergism of the engineer and the statistician to try to 6
do the kinds of analysis and cross-correlations.
7 COMMISSIONER BERNTHAL:
Good.
8 MR. HEBDON:
As I said, we have done a lot of that.
9 A lot of that has been done with the data and is available.
10 COMMISSIONER BERNTHAL:
Good.
l 11 MR. HEBDON:
Unfortunately, we didn't-realize that 12 that was the emphasis of your concern today.
13 COMMISSIONER BERNTHAL:
Then the real challenge is -
k, 14 make us something that we can understand.
15 CHAIRMAN ZECH:
Right.
16 MR. TAYLOR:
Me, too.
17 MR. HEBDON:
The next phase is to try and go out and look at some of the things that don't seem to make sense.
For 18 19 example, the anomaly with Callaway where it seems to be a very 20 well managed plant, very high SALP scores but seems to be 21 having a rather large number of transients and that is the 22 type of thing that we are very much trying to look into in the j
23 second phase of our study is to try to get a better 24 understanding for why that kind of situation exists.
25 COMMISSIONER BERNTHAL:
Al right.
1
.,,. - -.. ~. - - -.,,. _.
,i 40 1
CHAIRMAN ZECH:
All right, proceed.
2 MR. TAYLOR:
Gary.
3 MR. HOLAHAN:
I would just like to pick up on a few 4
of the programmatic activities in NRR.
There have been 5
several occasions in which concerns have arisen during the
]
6 startup power ascension phase of new plants and some 7
additional operating experience reviews and studies were 8
undertaken.
Those were done at Fermi-2, Palo Verde, Catawba I
9 and River Band.
10 One of the other activities going on is what we are
^8
{
11 calling the BWR oversight review teams and basically for all i
12 of the new boiling water reactors, a team which really means 13 the project manager with a few additional technical resources
,k I
have been closely monitoring their operating experience and 14 15 cross-correlating that information between recent BWR's.
1 l
16 (At this point in the proceedings, Commissioner 17 Roberts re-enters the Commission meeting.)
18 COMMISSIONER CARR:
That is a headquarters team i
i 19 then?
)
20 MR. HOLAHAN:
That is a headquarters team but 21 basically they have been looking at data available at 22 headquarters and then going, talking to the regional offices l
23 and then visiting the sites.
l 24 So it is really a cooperative effort with the l
x 25 regions and headquarters.
These sorts of activities don't
. _. _ _ _ _. _ _... _ _. _ _, ~ _ _ _. _ _ _ _. _ -.. _. _ _ _ _ _. _. _ _ _. _.. _. ~. _. _. _ _. ~. _..
i i
41 1
work very well when headquarters doesn't coordinate with the i
2 regions.
3 What we are discovering is when we put more 4
attention on it, the licensees in parallel are putting more 5
attention on it and so these new boiling water reactors are 6
beginning to organize together.
7 They are beginning to set up meetings to share 8
common experience and there is something of a miniature BWR 9
owners group for the new plants that is coming about at least 1
10 in part out of this activity.
11 So there is a lot of learning that can be done from 12 each other's experience and the staff is trying to learn from i
13 each plant's experience and we are encouraging the licensees 14 to learn from each other's experience.
i i
15 one of the other activities that has gone on is the l
I 16 augmented inspection teams have been sent out on occasion to i
1 i
I i
17 new plants basically in response to an event that needed 18 some additional resources to be investigated.
i 19 It was done on Palo Verde, Catawba and Hope Creek 20 and in each case it was somewhat of a complicated reactor j
21 scram.
The Catawba one involved a loss of control room test 22 that was being performed where a number of difficulties arose.
I 23 These inspections are regional inspections augmented a
24 by headquarters resources and basically they were for he 25 purpose of finding out the root cause of those problems and
42 1
what corrective actions were to be taken.
2 But at least in part, the feeling that some 3
additional resources were needed at that time was probably 4
driven by the fact that some prior problems had occurred at 5
those plants.
6 So Palo verde had a number-of problems with their 7
on-site AC power and then when they had an event involving AC 8
power problem and the problem with some of their pressurizar 9
spray controls, additional resources were put on that to 10 investigate causes of the problem.
11 You may remember that back in 1984 an industry 12 working group proposed a position on SRO operating experience 13 which the staff and commission approved through the issuance 14 of Generic Letter 84-16.
15 In effect, what this has called for is to have on 16 shift an SRO with at least six months hot operating experience 17 and at least six weeks hot operating experience above 18 20-percent power.
So it has been an effort to put additional 19 experience in the people on shift during this early phase.
20 I think now we have come to the point where all the 21 plants currently being licensed have more experienced 22 management in the control room than was previously the case.
23 The last item I would like to' mention on this slide 24 is management meetings.
Basically what we are looking for is 25 improvement in licensee performance and that is really
43 1
something that the licensee has to accomplish.
4 2
So licensee management /NRC management meetings to 3
discuss staff concerns and licensee programs are an important 4
mechanism for allowing the licensees to understand what our 5
concerns are and have us understand what their programs are 6
for improving performance during their startup phase.
7 On the next slide, I would just like to point --
i l
8 CHAIRMAN ZECH:
Excuse me, if I could make just a l
9 comment on the management meetings.
I think it is important 10 to me during these meetings with the utilities that we try to j
11 offer specific areas where we see concerns rather than 12 generalities.
i 13 In other words, management really is the 14 responsibility of the utility.
Where we see areas of weakness i
15 or areas that need improvement, there is where we should point 16 out the areas to management so that management itself can take j
17 the responsibility.
18 In other words, I think we should be somewhat 19 careful not to be telling him how to do it and so forth, but 20 we should be pointing out areas and let him take the 21 initiative to make the corrections.
22 We should be careful here in this area not to 23 overstep as far as I think it'is important to recognize -- I I
24 am sure you do that, but I just emphasize it because I think 25 we can indeed.and we do have responsibilities in my judgment i
l
= -
44 1
to point out areas of management weakness and improvement.
2 That is our responsibility.
3 If we are asked for suggestions perhaps, that might 4
'be appropriate or might not be appropriate but I think we 5
should not try to assume management responsibilities.
It is 6
important in my view that we keep that in mind.
7 MR. HOLAHAN:
Yes.
I agree entirely and I have had 8
a discussion with a number of the teams before they went to 9
have some of these management meetings and I think there is a 10 strong feeling along the lines you mentioned.
11 CHAIRMAN ZECH:
I think it is important though that 12 the leadership of our agency, you people, recognize that and
]
13 continue to instill that emphasis in the people that you send 14 to the plants.
15 MR. HOLAHAN:
Absolutely.
16 (SLIDE.]
17 MR. HOLAHAN:
I would just like to point out three 18 examples of these kinds of activities dealing with new plants, 19 Palo Verde, River Bend ind Catawba.
i i
20 In the case of i~ lo Verde back in 1985, there were 4
21 some site visits following a series of problems with the 22 on-site AC power system.
23 Because some of these concerns led to questions 24 about the licensing basis, they were, in fact, issued a l(
25 50.54 (f) letter expressing the areas of concern and asking
45 1
them to address each of those concerns.
2 One of the specific areas was the design 3
requirements for the auxiliary spray system and there was some 4
concern about their being unclear communication between the 5
licensee and the staff as to what exactly the design 6
requirements are for that system.
7 So the letter was issued in order to get our 8
concerns formalized and the licensee's positions on the record 9
as well.
10 Following some discussions with the licensee, the 11 licensee in effect offered to provide a report on their 12 operating experience and their activities to address staff 13 concerns and they have done that.
There have been additional
,f 14 management meetings with the licensee.
15 Palo Verde is an interesting case because they still 16 have a third unit to license and, in effect, the staff has had 17 two kinds of concerns with Palo Verde, one being a desire to 18 have the unit with the license operate smoothly and learn 19 the lessons as quickly as possible but we are also interested 20 in making a licensing determination about a second unit and 21 having done that about the third unit.
22 So it has been important to talk to the licensee and 23 have commitments that corrective actions that were taken on 24 the first unit from operating experience, in fact, are being 25 factored into the second and third units before those problems
s 46 1
occur.
2 That is one of the valuable things about monitoring 3
operating experience and dealing with them early on.
If there 4
is another unit involved, it is a way of solving those 5
problems before they occur.
6 In fact, when we look at some of the statistics we 7
find that in most cases where there is a second unit on the 8
same site and, in effect, it is a very similar plant, 9
statistics like scram rates tend to be significantly lower, in 10 some cases maybe only half of the problems that occurred on 11 the first unit.
12 So some of the learning that is done on a first unit 13 can be carried over to a second unit and our discussions with
\\
14 the licensees are trying to ensure that that is done to the 15 maximum.
16 In the case of River Bend, this is a somewhat 17 unusual case in that River Bend has had an unusually high 18 number of reactor scrams.
However, those reactor scrams have 19 almost never been complicated by any other system failures.
20 So the system seems to perform very well when 21 challenged although the challenge rate seems to be higher than 22 one would like.
23 On a number of occasions we have sent the project 24 manager and other NRR staff to speak to the licensee, talk to 25 the regional office and, in fact, we have been very pleased
47 1
with their corrective action programs.
They seem very 2
responsive.
They seem to do an excellent review of their own 1
operating experience.
They look at the root cause of the 4
problems and they tend also to look very well at the generic 5
implications and to other systems and other equipment.
j i
1 6
Interesting enough, the quality of the program 7
doesn't seem to have produced the rapid reduction in the scram 8
rate so this is part of what I think Jim Taylor was l
9 mentioning, the difficulty.
10 COMMISSIONER BERNTRAL:
We have four of these plants 1
11 now, River Bend, Grand Gulf, Clinton which is having a little
~
12 rocky path trying to begin power run-up now --
l 13 MR. HOLAHAN:
And Perry.
\\
14 COMMISSIONER BERNTHAL:
-- and Perry which we don't 15 know much about yet, I guess.
Are these plants appearing to i
16 be hard to startup and run?
17 MR. HOLAHAN:
That is hard to tell.
There may be 18 some peculiar problems and these plants do tend to have 19 perhaps an overly sensitive isolation on the reactor water clean-up and you see that repeatedly but in terms of reactor 20 21 scrams, I think the reason we are seeing them is because we 22 are looking more closely.
It is not that the scram rates are 23 higher than any other plants have ever been.
i 4
24 I think it is the amount of data available and the 25 amount of resources put into looking at them is simply greater 4
~. - -
i 48
)
i 1
than before and if we had looked at Oyster Creek and Nine Mile 2
Point-1 a decade ago, I think we would have seen a similar 3
learning curve and we are starting to go back and look at the 4
data to try to understand what is a normal startup, what is a 5
normal learning curve.
6 I suspect that, yes, these new plants are large and 7
complicated but that similar experience existed on the older, 8
smaller plants.
a j
9 MR. TAYLOR:
We will have to look at the i
10 comparability, the very question you are asking, as these 11 plants that are very similar start up.
12 MR. HOLAHAN:
The last plant I would just like to j
13 mention is Catawba where an augmented inspection team was sent
(
14 to look into a problem that occurred in their loss of control 7
l 15 room test.
Basically this is the test to show that if the 16 control room needs to be evacuated that the plant can be i
l 17 safely shut down from outside the control room.
18 They had several difficulties during that test.
1 19 There was a team led by the region supplemented by headquarters expertise so considerable attention was given to 20 P
l 21 that startup test.
j 22 In addition, there have been a number of management 1
23 meetings with Catawba to look into their experience program, 24 look into their program for monitoring their own experience,
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25 for taking corrective actions.
These are not one time 4
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49 1
activities.
2 What we find is that these are kind of on-going 3
dialogues established between the staff and the licensee and 4
this is probably the normal process of a startup.
5 Those are the only items I had to mention.
6 MR. TAYLOR:
Mr. Chairman, I know you may have j
7 additional questions but I think just in conclusion to the l
8 staff specifica, we have perhaps generated more questions than 9
answers on this.
I think that we are showing heightened 10 sensitivity to plants during this period.
l 11 The EDO as you know wrote a letter to NUMARC really 12 because I think behind it was the understanding that as a body 7
13 this information indicates a need for attention and that the
!\\
14 industry with its broad capabilities perhaps could bring its 15 capabilities to both analyze and understand and perhaps get 16 the answers.
l 17 I think that could be important because the staff as 18 it goes through may come up with answers and getting something i
19 done about it in performance is really the job of the industry 20 and so if they come to some of the same conclusions and
~
21 answers from an analysis across these plants, more to the 22 better of actually getting something done about it.
23 I don't think we have those kinds of answers.
l 24 CHAIRMAN ZECH:
All right.
Does that conclude your i
25 report?
l l
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a 50 1
MR. TAYLOR:
Yes, sir.
That concludes the staff 2
report.
3 CHAIRMAN ZECH:
Thank you very much.
Questions from 4
my fellow commissioners, commissioner Roberts?
5 COMMISSIONER ROBERTS:
No.
6 CHAIRMAN ZECH:
Commissioner Carr.
7 COMMISSIONER CARR:
I would just like to make a 8
statement.
In my opinion, you are going to spend a lot of 9
time and a lot of trouble and you are going to find out that 10 after the initial test problems and anomalies are discovered 11 and corrected that people make the difference.
12 By that I mean that those people who take a 13 procedure and review it and walk through it before they 14 startup, the training overall with a special training on 15 startup, people with previous startup experience of both their 16 operators and their companies and those people who don't have 17 a philosophy that we have to hurry and get through with this 18 thing and have turned their systems over to their operators 19 long enough for them to have them well checked out, you are 20 going to find that that is the difference.
21 I don't know how much data you are going to have to 22 get together to prove that to yourselves, but my data is all 23 banked for a lot of years of looking at plants.
24 MR. TAYLOR:
Yes, sir.
25 CHAIRMAN ZECH:
Thank you.
Commissioner Bernthal.
-= ----
i o
51 1
COMMISSIONER BERNTHAL:
I just want to make one i
2 comment.
I am looking forward to more data, more basis for 3
proceeding here than what you were able to present today.
I 4
recognize that you have inaugurated a program that I think is 5
a very good program.
You should be attempting to ferret out 6
the reasons why people are having difficulties if they are.
7 So go on with it.
From the standpoint of what I 8
have heard today, I want to know more though and generally i
9 speaking, if you come before the Commission and are proceeding 10 in a program based on data, I want to see the data and somehow 11 we don't have that in front of us today.
12 So I would hope that you would supply more 13 information.
I think your program is a good one and the idea
\\
14 is good and the intent is good but if you haven't done a lot 15 of these correlations, they need to be done so you know where 16 you are going and the Commission would also like to know.the 17 basis on which you are proceeding and I think we haven't quite 18 reached that point here today.
19 That is all I have to say.-
20 CHAIRMAN ZECH:
Following up on that, it might be i
21 useful the next time you come to talk to us about this to i
22 bring one of your top statisticians as well as the data that 23 can give us a feel for how the data was used and that might be 24 very useful.
25 MR. TAYLOR:
Yes, sir, i
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CHAIRMAN ZECH:
Let me just say I agree with 2
commissioner carr's comment and will let you come up with your 3
own conclusion but it has been experience too that if you 4
follow the procedures in startup very diligently and if you 5
pay attention to detail and if you have a disciplined i
6 organization, if you have formality, if you really understand i
j 7
you are dealing with a demanding technology, if you are 8
careful about what you are doing, you are going to have a 9
better startup than if you don't do some of those things.
10 Then when it is all done, even though you anticipate 11 some problems and you will probably have some, when it is all 12 done if you have learned those lessons, you are going to have 13 a smoother operation as you go into the future and it is 14 people that count.
15 It is people and it is also again as far aa I am 16 concerned attention to detail, attention to procedure, a i
17 respect for the fact that you are doing something that 18 requires your very best diligent performance and also I would 19 like to emphasize one other thing during a startup period and i
20 that is teamwork, teamwork in the real sense of everybody 21 knowing what he is doing and knowing what the other persons 22 are doing so that there aren't any surprises during the 23 startup period.
24 Teamwork is awfully important.
We can talk about 1
25 it, but does it happen.
That is the main thing and that is t
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53 1
again people working together and recognizing that they have a 2
big responsibility.
So I don't think that some of the things here are so 3
4 mysterious.
My own view is that you will probably conclude 1
5 and I agree with Commissioner Carr but I would like to see 6
what you do conclude.
We certainly don't want to foreclose 7
your work but you could well conclude that it is not any
?
8 mystery, it is not magic, it is not anything but plain hard 9
work and attention to detail and perhaps more formality and i
10 discipline than we are using in our system.
11 Everybody has to work together and teamwork again'is 12 important in this whole endeavor.
I know people try to do j
13 these things but sometimes it has been my experience, too, 14 that the startup period comes right after a very hectic and of 15 construction period and I have seen control rooms that are I
l 16 just about ready to get into the startup period that are just 17 too noisy, too crowded, too much going on, too much j
18 activities, the operators are somewhat distracted by all the i
19 other last minute things going on.
20 It is a period of making sure the operators are 21 rested enough before they go into it and all kinds of very 1
22 fundamental things that, I think, are worth consideration but l
23 if you go through that in the construction period and then l
24 with a great respect for shifting from construction to operations, again it h's been experience that this is still 25 a
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not being done as well as it should be but there is a
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2 difference between operations and construction.
3
~If they really understand that and that is very
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4 fundamental again, a whole different mentality, but if you 5
have people experienced who have done it before, people 6
respecting the fact that there is a lot of difference when 7
that plant goes critical than when*it is inert and they are 8
still putting it together, if they really respect that they 9
will probably do a-batter job than thinking that operations 10 is a continuation of the construction period.
11 Operation and testing is completely different and it j
does require in my judgment a mentality effort and that comes 12 4
13 from experienced people and when you don't have experienced 14 people in the managment of the plant, then is where you have 15 to be very careful because again it has been my view that that l
16 experience comes very hard.
If you have never done it before, 17 it is awfully hard to understand what is going to happen.
18 So if you have experienced people, you should be I
19 able to go through that phase better but again it takes the 20 experienced people putting their effort and their experience 21 into that and down the line.
22 So even experienced people are guaranteed to do it 23 well.
They have to really work at it but people who are not f
24 as experienced have to work even harder.
It is an important i
j\\
25 thing you are doing.
l i
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j 55-1 I think it is worth another briefing here same time 2
in the future when you perhaps have more data.
I think you 3
have a lot of data now.
It is a matter of correlating a lot 4
of it.
I would caution you to be too careful from drawing 5
conclusions because they are very important but perhaps next 6
time you can give us some tentative conclusions, at least you 7
will be showing the path vou are going down and I think it 8
would be very worthwhile for you to continue this.
9 I am pleased that we have a cross-section of our 10 staff involved in it because I think all of you, the various 11 disciplines in our staff, can make a contribution.
It is not 12 just AEOD compiling a lot of data.
It is all the other parts 13 of our staff working together so I think that part is 14 important that we pursue also.
15 If there are no other comments, the meeting is 16 adjourned.
17
[Whereupon, the Commission meeting was adjourned at 18 11:15 o' clock a.m., to reconvene at the call of the Chair.)
19 20 21 4
22 23 24 25 I
o i
1 2
REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5
meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7
TITLE OF MEETING:
Briefing on Improving Effectiveness of Initial Startup Programs (Public Meeting) 8 PLACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING:
Friday, November 14, 1986 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken
.f 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 D O '- - - - - - - - - - - - ' ' S 2 '- - - - - - - - -
Marilynn M. Nations 20 21 22 Ann Riley & Associates, Ltd.
23 24
(_-
25
Y a
COMMISSION MEETING BRIEFING ON IMPROVING EFFECTIVENESS OF INITIAL STARTUP PROGRAMS NOVEMBER 14, 1986 s
~
IMPROVING EFFECTIVENESS OF INITIAL STARTUP PROGRAMS OPERATING PERFORMANCE DATA
- ON ALL PLANTS REVIEWED AT OCTOBER 1986 NRC SENIOR MANAGEMENT MEETING.
DATA INDICATES THAT, AS A CLASS, NEW PLANTS ARE EXPERIENCING A RELATIVELY llIGH LEVEL OF OPERATIONAL PROBLEMS FOLLOWING OL ISSUANCE.
- PLANT TRIPS
- TECH SPEC VIOLATIONS
- ESF ACTUATIONS
- PERSONNEL ERRORS
- EQUIPMENT PROBLEMS EXPERIENCE SHOWS THAT SUCCESSFUL CONSTRUCTION AND PRE 0PERATIONAL TESTING RECORD DOES NOT NECESSARILY TRANSLATE INTO GOOD INITIAL OPERATIONAL PERFORMANCE.
'IE INITIAL PERFORMANCE INDICATORS, AEOD TRENDS AND PATTERNS, NRR OPERATING REACTOR ASSESSMENT DATA.
1 i
IMPROVING EFFECTIVENESS OF INITIAL STARTUP PROGRAMS (CONT'D)
NEW PLANTS VS. MATURE PLANTS
- o REACTOR TRIPS
- NEW PLANTS HAD 4.5 TIMES AS MANY SCRAMS [3.6/1000 CRITICAL HOURS VS. 0.8/1000CH) i
- TESTING PROBLEMS AND PROCEDURAL DEFICIENCIES ARE MORE PREVALENT THAN IN MATURE PLANTS
- 25% OF SCRAMS ARE ACCOMPANIED BY ADDITIONAL FAILURES (HUMAN OR EQUIPMENT) FOR ALL PLANTS o ENGINEERED SAFETY FEATURE ACTUATIONS
- NEW PLANTS HAD 4.6 TIMES AS MANY ESFs [5.5/ MONTH VS. 1.2/ MONTH 1 i
o TECHNICAL SPECIFICATION VIOLATIONS
- NEW PLANTS.HAD 2.8 TIMES AS MANY TECHNICAL SPECIFICATION VIOLATIONS I2.2/ MONTH VS 0.8/ MONTH) j
- BASED ON FIRST YEAR DATA FOR THE 13 NEW PLANTS ACTIVE DURING 1984/5 VS 76 OLDER PLANTS l
2
l TOTAL SCRAV RATE OLD VS NEW SCRAVIS PER 1000 CRITICAL HOURS LEGEND FM OLD 3...
4/*'
NEW
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IMPROVING EFFECTIVENESS OF INITIAL STARTUP PROGRAMS (CONT'D)
PROBLEM NEEDS TO BE ADDRESSED FROM TWO ASPECTS:
- LICENSEE READINESS TO OPERATE (PRE-OL), AND
- LICENSEE PERFORMANCE DURING INITIAL OPERATIONS.
CURRENT STAFF ACTIVITIES
- IE EVALUATING ADEQUACY OF INSPECTION PROGRAM AND SALP.
DEVELOPING PERFORMANCE INDICATORS.
- REGIONAL OFFICES EMPHASIZING INSPECTION PLANNING TO ENSURE INSPECTION EMPHASIS BASED UPON PERFORMANCE.
- AE0D CONDUCTING ANALYSIS TO FURTHER UNDERSTAND CAUSES OF NEW PLANT PERFORMANCE PROBLEMS,
- NRR EXERCISING INCREASED OVERSIGHT AT SELECTED NT0LS/NEW PLANTS.
- EDO HAS REQUESTED NUMARC ATTENTION, l
i CURRENT INSPECTION PROGRAM FOR NEW PLANTS
- INCREASED INSPECTION EMPilASIS DIRECTED AT PLANTS DURING PRE-0P AND FIRST TWO YEARS OF OPERATION
- AT SINGLE UNIT SITE:
PHASE INSPECTION FTE CONSTRUCTION 4.2 PRE-0P (18 MONTHS) 6,3 START-UP (24 MONTHS) 4.6 OPERATIONS 4,1 5
~
CURRENT INSPECTION PROGRAM FOR NEW PLANTS (Cont'D) i
- DURING INITIAL PLANT STARTUP AND TESTING, INSPECTION COVERAGE INCLUDES:
- IMPLEMENTATION OF OPER4 TING REACTOR INSPECTION PROGRAM
- REVIEW 0F STARTUP TEST PROCEDURES, TEST WITNESSING, AND TEST RESULTS EVALUATION
- INSPECTION COVERAGE FOR EACH SHIFT FOR SELECTED POWER ASCENSION TESTS
- DURING FIRST TWO YEARS, INSPECTION PROGRAM IS NOT REDUCED BASED UPON PERFORMANCE, BUT CAN BE INCREASED.
- SALP CONDUCTED ABOUT SIX MONTHS PRIOR TO OL DATE.
NEXT TWO SALPS CONDUCTED AT 12 MONTH INTERVALS.
SUBSEQUENT SALPS CONDUCTED AT 12-18 MONTH INTERVALS, DEPENDING UPON PERFORMANCE.
\\
6
i IE PROGRAM PLANS o
RECENT NEW/ REVISED INSPECTION ~ PROCEDURES HAVE EMPHASIZED PERFORMANCE OVER PROGRAM ADEQUACY (TRAINING, MAINTENANCE, CORRECTIVE ACTIONS, OA).
THIS APPROACH WILL BE CONTINUED.
o PERFORMANCE INDICATORS WILL BE MONITORED FOR ALL NEW PLANTS AS A CLASS, AS WELL AS IN RELATION TO OLDER PLANTS.
QUARTERLY EVALUATION OF DATA WILL ALLOW STAFF TO ASK MORE TIMELY QUESTIONS AND RESOLVE ISSUES.
O SEMI-ANNUAL'NRC SENIOR MANAGEMENT MEETINGS WILL ADDRESS NEW PLANTS.
l 4
4
)
7 i
'4 l
AE0D f
- INITIAL NEW PLANT STUDY ISSUED AUGUST 21, 1986 A
- FOLLOW-ON STUDY IN PROGRESS s
- INCREASED PARTICIPATION IN PLANT READINESS ACTIVITIES
- WORKING WITH OTHER OFFICES TO CONSIDER FURTHER OPTIONS TO IMPROVE NEW PLANT PERFORMANCE l
8
=.
O NRR s
4 MECHANISMS FOR OVERSIGilT REVIEW 0F NEW PLANTS DAILY REVIEW OF EVENT REPORTS /0PERATING REACTORS EVENT BRIEFING REVIEWS OF OPERATING EXPERIENCE DURING LOW POWER LICENSE PERIOD - ALL NEW PLANTS SELECTED REVIEWS OF EXPERIENCE DURING POWER ASCENSION TESTING FERMI-2 PALO VERDE 1 CATAWBA 1
[
RIVER BEND BWR OVERSIGilT REVIEW TEAM SITE VISITS AUGMENTED INSPECTIONS INCREASED REQUIREMENTS FOR SR0 OPERATING EXPERIENCE ON SHIFT (GENERIC LETTER 84-16)
MANAGEMENT MEETINGS 9
l
~
NRR 4
PLANT-SPECIFIC ACTIONS o
PALO VERDE NRC OVERSIGHT TEAM VISIT TO UNIT 1 10/85 FOLLOWING SERIES OF EVENTS MEETING WITH LICENSEE AND 50.54F LETTER ISSUED REGARDING SPECIFIC STAFF CONCERNS UNIT 1 STARTUP EXPERIENCE
SUMMARY
REPORT ISSUED BY LICENSEE AT STAFF REQUEST (2/86)
ADDRESSING STAFF CONCERNS MANAGEMENT MEETING WITH LICENSEE (10/86) TO REVIEW UNIT 2 STARTUP PROBLEMS LICENSEE TO ISSUE REPORT ON CORRECTIVE ACTIONS o
RIVER BEND OVERSIGHT TEAM VISITS TO SITE 1/86 AND 7/86 MANAGEMENT MEETINGS 5/86, 7/86, 11/86 I
0 CATAWBA AIT SITE VISIT IN RESPONSE TO' 6/27/86 LOSS 0F CONTROL ROOM EVENT MANAGEMENT MEETING (8/8/86) REGARDING UNIT 2 PERFORMANCE 10
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SECY Correspondence & Records Branch 3:
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Attached are copies of a Commission meeting transcript and related meeting 3 !,
document (s). They are being forwarded for entry on the Daily Accession List and placement in the Public Document Room. No other distribution is requested or j
required.
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