ML20214E791
| ML20214E791 | |
| Person / Time | |
|---|---|
| Issue date: | 05/13/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8705220252 | |
| Download: ML20214E791 (65) | |
Text
,
7 ORIGINAL I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
Periodic Briefing by INPO (Public Meeting)
Location:
Washington, D. C.
Date:
Wednesday, May 13, 1987 Pages:
1 - 61 Ann Riley & Associates Court Reporters 1625 i Street, N.W., Suite 921
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Washington, D.C. 20006 (202) 293-3950 BM52i89R*7 PT9.7 PDR
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f D I SCLA I MER 1
'2 3
4 5
6 This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on 8
5/13/87 In the Commission's office at 1717 H Street, 9
'li. tJ., Washington, D.C.
The meeting was open to public i
10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain f;
(
-12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcript.
17 do not necessarily reflect final de t erra i na t i on or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.
22 23 24 25
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1 1
UNITED STATES OF AMERICA 7,;
2 NUCLEAR REGULATORY COMMISSION 3
4 PERIODIC BRIEFING BY INPO 5-6
[PUBLIC MEETING]
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Nuclear Regulatory Commission 9
Room 1130 10-1717 H Street, Northwest 11 Washington, D.C.
12
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Wednesday, May 13, 1987
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14 15.
The Commission met in open session, pursuant to 16 notice, at 2:04 p.m., the Honorable LANDO W.
ZECH, Chairman of 17 the Commissioh, presiding.
18 COMMISSIONERS PRESENT:
i 19 LANDO W. ZECH, Chairman of the Commission i
20 JAMES K. ASSELSTINE, Member of the Commission
.21 FREDERICK M. BERNTHAL, Member of the Commission 22 KENNETH CARR, Member of the Commission 23 24 lC 25
4 2
1 PARTICIPANTS AND PRESENTERS SEATED AT THE COMMISSION-TABLE:
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3 S. CHILK 4
W. PARLER 5
P.M. BEARD 6
W.
F. CONWAY 7
Z. T.
PATE 8 ~.
K. A. STRAHM 9
P. W. LYON 10 11 12.
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21 22 23 l
24 25
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3 12 PROCEEDINGS
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2 CHAIRMAN ZECH:
Good afternoon, ladies and 3
gentlemen.
Commissioner Roberts will not be participating 4
today.
Mr. Bernthal will be joining us shortly.
5 Today's meeting is an information briefing for the 6
Commission by the Institute of Nuclear Power Operations, 7
INPO.
This is a discussion and briefing and no Commission 8
-decisions are anticipated in today's briefing.
9 Both INPO and the NRC have the goal of continued I
10 safe operation by the licensed nuclear power plants in the 11 United States.
It is very important and a goal that we share.-
12 We have that goal and come at it through'the role of 13
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regulatory and requirements backed up by the law'and of 14 course, the industry, INPO, comes at that goal throdgh a 15 different role, that is through instruction, maintenance, 16 operation and management of these nuclear power plants.
17' Although our roles are different, our goal is very 18 similar.
19 In accordance with the plans that we have worked out 20 together, the lead in implementation of a number of programs 21 has been given to INPO.
You have taken a number of initiatives 22 to encourage excellence in nuclear power plant operations and 23 to obtain a higher level of performance.
l 24 I think the Commission has certainly developed great i
ss 25 respect for the INPO organization and h'as & feeling of i
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confidence that the industry, since Three Mile Island, having
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2 instituted INPO, has taken on a very responsible initiative.
3' I personally think that's important and INPO I think deserves 4
a great deal of credit for the programs that they have 5
instituted that-have'indeed in my judgment contributed to an 6
industry that is improving.
7 Mr. Zack T. Pate, President of the Institute of 8
Nuclear Power Operations, is here today with some of his 9
senior executives to brief us.
Before we start, do any of my 10' fellow Commissioners have any opening remarks?
11 COMMISSIONER ASSELSTINE:
No.
12 COMMISSIONER CARR:
No.
13 CHAIRMAN ZECH:
Mr. Pate, would you begin, please?
14 MR. PATE:
Yes, sir.
Mr. Chairman, Commissioners, 15 we appreciate this opportunity to provide you with an update 16 on sema of INPO's key activities.
As the Chairman indicated,
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17 I'm Zack Pate, President and Chief Executive Officer of the 18 Institute.
With me today are INPO's four group Vice 19 Presidents, on my left, Pat Beard, who heads the Evaluation 20 Assistance Program; Bill Conway, who heads Industry and 21 Government Relations; Ken Strahm is the Director of the
- 22 Training and Education Division and the Director of the 23 National Academy and Pete Lyon, who heads our Analysis and 24 Engineering Division, t
25 This afternoon, we plan for Ken to.brief the
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Commission on several aspects of training, including an update-
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2 on accreditation and activities of the National Academy.
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will follow Ken by a brief discussion of an initiative in.
4 operating training including the use of simulators.
Bill _
S Conway_will discuss INPO's involvement with the review of the 6
Chernobyl accident and actions that we are taking that we 7
think are complimentary to actions of the NRC staff in that J
I will describe briefly some activities;to strengthen 8
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9 our analysis program and we will describe two new initiatives, 10 one for NTOL plants and the second for maintenance, an area i
11 that I know we all think is important.
12 We plan to limit our remarks to less than 45 minutes 13 leaving ample time for questions by the Commissioners.
With 14 that, I will ask Ken to start.
t 15 CHAIRMAN ZECH:
Thank you very much.
Go ahead, 16 please.
17 MR. STRAHM:
Mr. Chairman and Commissioners, the 61 18 nuclear power plants that loaded fuel prior to 1 January 1985
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19 and committed to have their 610 training programs ready for 20 accreditation by the end of 1986, as of December 16, 1986, all i
21 610 of these self evaluations were submitted to INPO and were 1
22' deemed as ready for accreditation.
Of this 610 as of today, 23 385 of them are accredited.
60 of the 61 plants have their 24 operator programs accredited and the accreditation of operator l\\
25 programs at one plant was daferred.
Al'1 61.did get to the
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Board.
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All the accreditation team visits for the 61 plants 3
will be completed by the'end of 1987 and we project they will 4
all be accredited by about May or June of 1988.
We are now.
5 closely monitoring the accreditation progress of new plants.
6 We-have a number of those self evaluations in and 19 of those 7
programs are already accredited.
8 As part of this process, thare is an NRC monitoring 9
and oversight.
Of 118 accreditation team visits, 19 of them 10.
have had either staff people or region people on the visits, 11 so that is continuing.
Of the 32 Accrediting Board meetings, -
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12 which is usually about once a month, and INPO, 28 of those 13 have been observed by NRC staff or region people.. Things in 14 this area are going smoothly as far as monitoring.
We aren't 15 having any problems.
16 The National Academy for Nuclear Training; the i
17 recognition of the Academy in its comprehensive effort in
~18 promoting professionalism within the nuclear power industry 19 is increasing.
There is still a ways to go but we are working 20 on it and it is increasing.
There are 12 full members of the 21 Academy as of today and 65 branches.
22 As you recall, a member has to have all 10 programs 23 accredited at all of their operating plants to be a member.
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24 Any time a site gets any program accredited, they become a I
n 25 branch so they can start issuing gradua'te c.ertificates.
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-Along that line, utilities are requesting I
2 certificates for their' graduates and also we have certificates J
3 for instructors of accredited training programs.
4 The second senior nuclear plant management course 5
has been completed, just two weeks-ago, and this-is also 6
sponsored by the Academy.
The purpose of this course, as you 7
will remember, is to enhance the ability of senior nuclear 8
plant managers to identify, analyze and solve management 9
problems.
There are two additional courses this year, one on 10 August loth for five weeks and one on october 12th for five 2
11 weeks.
We are filling in the people for those courses.
There-j 12 will probably be nine in each course.
So far, we have 17 i
13 graduates.
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14 Both classes were able to visit with some of the 15 Commissioners and-with key members of the NRC staff.
The 16 graduates really felt these meetings were important, they got 17 a lot out of it and we agree with them, and we hope to keep 18 that up.
19 The second round of accreditation.
Here's'the 20 latest brochure for the National Academy for Nuclear Training.
l 21 There are a number of these brochures on the back table also.
22 The second round of accreditation which is coming on 23 us this summer, will focus on implementation of training and 24 maintaining the quality of the previously accredited programs, s
25 very important.
Our emphasis will be place.d on training,
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effectiveness evaluation, maintaining the resources that.have
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.been committed by management and implementation of the 3~
continuing training programs in all areas.
It is a very imp $rtantpartoftheprogram.
4 5-Plan-evaluations will also provide an ongoing look 6
at.the accredited programs.
7 MR. PATE:
As an initiative to enhance accreditation 8
in the second round, we are now planning to review licensed 9
operator continued training, including simulator training as a 10 separate program.
I know the commission is aware that the 11 number of simulators in use around the country has grown 17 enormously from 10 at the time of Three Mile Island to 58 13 today with a number more on order.
x 14 At the same time, the industry with help from owners 15 groups, the four owners groups and extensive review by the NRC 16 staff, has developed symptom based emergency operating 17 procedures.
We have a situation today where virtually every 18 plant is using the new EOPs, as we call them, and virtually 19 avery plant has access to a full scale simulator.
I think the 20 Commission knows the exception like Big Rock and the smaller 21 plants.
22 The operators have an opportunity to use the new 23 carefully thought out EOPs to practice emergencies in a 24 simulator, go through what they might face in a real plant, to 25
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a far greater extent today than they could.a few years ago.
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We are looking at that in evaluations but we plan to look at
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that in greater depth and ensure that INPO is able to see 3
actual shift crews working as a team and practicing the use of 4
EOPs in going through a number of the scenarios that they 5
might face in a real emergency.
6 We have recently issued a guideline in. training, we 7
had 13 guidelines when we began accreditation, and the new 8
guideline stresses the importance of practicing emergencies in 9
the simulator and stresses the importance of the shift' crew 10 working as a team. -We think that is very important.
We will 11 be looking at that closely in accreditation and in the 1
i 12 evaluation process as well as an effort to strengthen a very 13 important part of the whole training business.
11 4 We would like to shift now and have Bill Conway talk 15 for a few minutes on Chernobyl and what we'at INPO have done 16 in response to that.
We have followed the work of the NRC 17 staff very closely and Bill has participated in an industry i
18 group led by Byron Lee to take a look at all aspects of 1
19 Chernobyl and INPO was assigned the operational chapter of l
20 that industry report.
That's complete.
Our significant l'
21 operating experience report is on the street and the 22 recommendations are being implemented.
i 23 We think that our work closely compliments the work 24 of the NRC staff and our emphasis on the need for taking a 25 close look at management controls and a'her.ence to procedures d
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is consistent with what the NRC staff believes-are the 1
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important outcomes'from Chernobyl.
3' I would like Bill to give the Commission a brief run 4
down on that, because it is an important part of the whole 5
history and the whole picture.
6 MR. CONWAY:
Thank you, Mr. Chairman and 7
Mr. Commissioners.
8 I will talk briefly on the technical reunion that 9
Zack referenced, which was headed by Byron Lee, and this was 10 established under the auspices of UNPOC back in May of 1986, 11 shortly after the event.
It was originated in principal to 12 serve as-the. focal point for the industry assessment of the
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13 Chernobyl accident, and it consisted of representatives from
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14 utilities, architect engineers, and nuclear steam suppliers, 15 members of academic, EPRI INPO, AIF, ANS, various owners 16 groups, as well as the USCEA, NUMARC, DEI, and ANEK.
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17 Its product consisted of two documents, one called a 18 position paper on the accident, and secondly and perhaps more 1
19 importantly, an industry' plan of response.
Both of these were 20 submitted to UNPOC as the leading authority and approved by 21 that entity.
22 The position paper reviews the group's assessment of 23 the accident.
The general conclusion is that the accident was 24 the result of significant design weaknesses; however, coupled 25 with human factor breakdowns by both management and operators.
11 1
The plan of response states that there are three
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major objectives that the industry would like to pursue and
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4 The first is to continue to do all that it can to 5
protect public health and safety through continuing dedication f
6 to operational excellence, as wellLas technological 1
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7 improvement.
8 Secondly, to continue to review future available 9
information for an subtle lessons that can be learned.
i 10 And thirdly, to use the accident to reemphasize 11 major actions taken by industry in recent years in order to 1
12 improve the relationship with the regulators as well as the 13 general public.
e 14 The plan addresses efforts already taken and those 15 that need to be considered by industry for future action and I.
16 defines three particularly levels of response.
17 The first level is an evaluation -- or the evaluation i
18
-- of the accident and the identification of findings, which 19 has been accomplished.
20 The second deals with challenges to the industry o
21 resulting from the Chernobyl experience.
22 And the third level suggests increased participation 23 by industry in the international nuclear scene, and I know 24 that's of interest to you, Mr. Chairman.
25 Industry organizations have been assigned task f-i
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the. initiatives identified in the plan, and as Zack indicated 3
earlier, INPO has the lead in the operational area.
4 Let me switch quickly.to the work that has been done
- 5-internal to INPO as a result of the event.
Based on our 6
review of-the Chernobyl accident, and I guess additionally 7
related work, done by IDCOR, we have developed an internal-l:
8 action plan for INPO, and we believe in this way we can impart 9
information on an international basis to all members through 1
.10 our evaluation and casistance process.
11 Under this initiative, we have identified actions we 12 can take to further assist utilities to reduce the probability 13 of a core-damaging accident and/or mitigate the effects of a 14 core-damaging accident if one should occur.
And I'd like to 15 take a brief few minutes to describe three of these actions.
16 Initially, we have put together a plan that would 17 reduce the probability of a core-damaging accident, and one of
. 18 those actions involved is to improve our focus during our
- 19 plant evaluations on management control in several very 20 important areas, one being safety system availability, the O
21 bypassing of safety systems, management control involvement 22 in changes involving reactivity, as well as the conduct of 23 tests during special evolutions, analyzing and approving 24 changes to plant equipment and procedures, and preventing 25 distraction of operators or managers from attention to overall
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' Secondly,'we are upgrading our simulator evaluations, c
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a's Zack mantioned'Warlier to more thoroughly assess the shift a.
4 crew's abili+f to prevent core damage by proper use of the
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5 emergency operating procedures, as well as diagnostic 6-training.. Secondly in that particular area, we will be looking e
7' at the effectivenenseof control room management techniques, as 6-well as the teamwork involved in the control room.
Y " j.y. 9 Our third; action is to review and revise as necessary 10 our guideline for t. raining to recognize and mitigate the.
11 consequences of a core-damaging accident and base a lot of
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12 that principally on the results of the IDCOR study.
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Thank you.
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. CHAIRMAN ZECH:
Thank you.
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'15 MR. PATE:
Now I would like to describe two 16 enhancements to the event. analysis program that INPO runs, the b
business of getting the descriptions of events from U.S. plants 18 throughout-the country, as well as many plants international 19 and analyzing those events and trying to, in the best way, 20 disseminate the lessons learned to the industry, as well as to 21 our international participants.
'22 As we've reviewed our whole program and reviewed our 23 efforts in this area over the past several months, we've 24.
realized that we weren't doing enough to promote what we call
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25 the case-study concept, for lack of a bette.r term, and that is
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creating a situation where operators or a group of managers or P:
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a group of technicians review an event at another plant in 3
sufficient detail that they feel a part of the event.
They 4
feel like in a small way they've participated in the event, so 5
that their memory of what happened and their appreciation of 6
the pitfalls is greater than just the -- as usually imparted 7
by the technical report or by a classroom lecture.
8.
Other businesses use the case-study approach 9
extensively.
For example, Harvard Business School and now 10 today many other business schools.
It's used extensively in 11 the aviation community.
I know it's used in the legal 12 profession and in the medical profession.
13 What we find is that although those of us who 14 remember the details of the TMI accident know that the improper 15 control of a tag-out of auxiliary feedwater blocking valves 16 contributed in a substantial way to the accident, we find that.
17 that's not reviewed with operators on a routine basis, so the
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18 operator tends to forget or tends to lose sight of the vital 19 importance of tag-outs and the proper taking of equipment out 20 of service and the restoration of equipment to service.
In the 21 case of TMI, the blocking valves for auxiliary feedwater were 22 left shut after tags were removed, where they should have been 23 open, so that feedwater system was not available to help in the 24 cooldown.
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25 So it's our firm belief that having the operators go
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back through and talk that in detail and a little bit relive
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2 TMI increases their appreciation of the vital importance of 3
' properly handling tag-outs, and we all, I think, know what I 4
'mean by " tag-outs" -- removal of equipment from service and 5
the posting of typically a red tag to make sure that it 6
doesn't get repositioned and then later on putting it back in 7
service and taking the tag off.
The operators gain a greater 8
appreciation when they're exposed to that kind of detail.
9 In a similar way, other crafts, like, for example, a 10 radiation protection technician, if they read about the guy a 11 number of years ago who got a hot particle in his hear and 12 went deaf in that ear as a consequence, that lives in your 13 memory for many years, as it has in mine, and then you're
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14 careful to frisk your hands and not be a victim of a hot 15 particle being caught under your fingernail or in your 16 clothing.
17 So there are many examples that we could talk
.18 through, but the important thing is that we're trying to 19 develop case study materials for historically important 20 events, like TMI, like Chernobyl and many others that are less 21 significant -- for example, the Davis-Besse event of June the 22 9th, 1985 and the Rancho Seco event of December 26, 1985, the 23 overcooling event, and put those into a training package that 24 can be used to create the environment I describe.
25 We furnished the first set of'thos.e, having to do
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with reac,tivity accidents, reactivity mismanagement, including W
2 Chernobyl, at the last plant managers' workshop and asked 3
every plant manager to take a copy, and over the coming 4
months, we'll be mailing copies of those to the industry for 5
use in training, and we will furnish copies of those to the 6
NRC.
7
'That's,one important enhancement.
The second is 8
that looking back over the history of the event analysis-l 9
program, during the first years from '80 to
'85, we reviewed 10 over 40,000 events, mostly in,the U.S.,
but many from other 11.
countries, and as a result of that analysis and review, we 12 wrote just over 400 recommendations in, I believe, 66 hard-copy 13 significant operating experience reports, and these reports are
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14 all furnished to the NRC, and of those 400 recommendations, 15 we've been trying to put that first six years' history into a 16 manageable form.-
17 We went out with special teams and looked to see how 18 well those 400 recommendations were implemented, and what we 19 found was that hardware changes were implemented and had 20 remained implemented.
For example, one of the early 21 recommendations was to install a larger drain line for the 22 SCRAM discharge volume for PWRs after the failure to SCRAM at 23 Browns Ferry several years ago.
Well, you can go look in the 24 plants and see this big, six-inch stainless steel header, and 25 you can see that it's installed, and yo^u have great confidence s
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that's-not going to be taken out.
So that recommendation is
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implemented for.the long term.
3 But what we found is that some places a 4-recommendation in training, although it had been put in the 5
training program, somehow it got lost.
Or change in a
.6 procedure got put in a procedure, but later on it got taken 7
out.
So there was enough of that that we went back and picked
-8 82 recommendations from that first six' years to be the subject 9
9 of ongoing review indefinitely, and the others we were able to 10 close out as being implemented on a long-term basis.
11 So_we put together a volume that encompasses the 12 distilled experience from that first six years, these 82 J
13 recommendations, and we'll 1Hb checking those on a recurring 14 basis to ensure that we don't lose those lessons as an 15-industry.
16 And then the second thing we're doing as a result of 17 that 400 recommendations in the first six years, a number of 18 times you find a new recommendation -- there's fewer and fewer 19 today -- so in the past year and a half, we've issued a total 20 of only 23 recommendations.
We are just following up more 21 rigorously in each plant evaluation to see that those are 22 '
properly implemented by our members.
23 I just wanted the Commission -- and I know the Staff 24 is already aware that we've gone through a considerable s
25 initiative at INPO to capture the essen~ce o,f that first six t
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- 1-years of. experience and then to rigorously follow up to see
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3 I'd like to describe now the last two new 4
initiatives, the work on new plants or work with new plants, 5
and the maintenance initiative.
6 Assistance to plants that are entering the 7
operational phase has always been a part of INPO programs, and 8
we have heretofore treated them almost on an equal basis with 4
9 operating plants in terms of the allocation of our resources.
10 But as we look back at the and of this past year at where we 11
'are and where we're going, we conclude that in '87 and probably 12 on into
'88, the new plants really deserve a disproportionate f:'
13 share of our resources for a couple ~of reasons, the foremost i
14 being that the IDCOR study shows'that a new plant has some four or five times the risk of an older plant during its first 15 16 couple or three years of operation, just from a simple reactor 17 safety standpoint.
18 And of course, we all see the experience that new 19 plants tend to have more SCRAMS, tend to miss more l
i 20 surveillances required by the NRC.
They tend to have lower j
21 plant availability and higher forced outage rates.
22 To try to compensate for that and to apply the 23 resources in the best possible way for safety in the industry, 24 we've developed a systematic approach to the remaining new s_
25 plants that takes a closer look from a poin.t about 18 months
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prior to fuel load right through to about the three-year point
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2-on.a case-by-case basis.
3 For example, we will go with a full assistance team-4 at about the 18-month point and review their preparations for 4
5 operation, and that is strictly in the form of an assistance 6
. visit, and then we'll come back again.at four to six months g
7 prior to fuel load and give them a fullfledged -- in effect,-
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.an evaluation; we call it a review and assistance visit -- but i
9 we give them racommendations, and we identify.specifically and 10-in. writing those-things that we think that the plant needs to 11, do before startup, and then we ask for and receive a report 12 that those items are done or implemented before the plant I
13 starts up, and each of those looks includes a look at simulator
-14 training of the type that I described earlier, to do our best 15 to see that the operators for the new plant can, indeed, use 1
16 the new emergency operating procedures and can handle 17 emergencies in the simulator.
-18 And then after the plant starts up, we'll go back 19 three to six months after full power is achieved for a full 20 evaluation, a regular INPO evaluation, and then we keep that 21 plant on a short cycle until we're comfortable that they're 22 kind of up to speed with the better operating plants.
l 23 We're giving priority to the accreditation of 24 operator training programs at new plants and pushing to get j
25 those done prior to fuel load, and we'r's giving priority to
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. the senior managers within the plant, at the new. plants, in 2
scheduling their attendance to the senior nuclear management 3
course that Ken described a few minutes ago.
And then lastly, 41 we're paying particular attention to the implementation of the 5
SLER recommendations that I described a few minutes'ago to see 6
that the new plant has capitalized on that operating exper(ence 7
that's been accumulated over the years.
8 And the1 final action is, we are putting together a 9
booklet-of the generic lessons learned that will-be shared 10 with all the plants that go through this phase, and ideally we 11 should have done this earlier, but here we are, and it is 12 something we are right in the midst of doing.
13 Mr. Chairman, the last area that I'll discuss is an.
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- i 14 area that I know that you and the other commissioners, as well 15 as the staff, believe is vitally important to the whole 16 industry, and that's maintenance.
17 For example, the NRC maintenance surveillance 18 program plan, Phase I, concluded that maintenance continues to 19 be a significant contributor to industry reliability problems, since INPO believes that safety and reliability are directly 20 21 coupled, and it has a potential to impact safety.
22 INPO's evaluation program has looked at maintenance 23 since the beginning, and we've made that as comprehensive a 24 look at we could, but we've usually had -- I'd say typically 25 had two evaluators spend two weeks at the p.lant looking at
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. maintenance, and that, because of the complexity of p,
2 maintenance, is a rather limited look.
3 So what we've begun doing just in recent months is 4
changing the approach to the evaluation, recognizing that
<5 maintenance is different, whereas in, say, operations we can 6
go. watch a shift turnover, we can go in the simulgtor and 7
watch them handle casualties, we can go in and see them test c
8 the diesel, similarly in chemistry we can watch them take a 9
sample and analyze it and see the result and see them record 10 and plot the result and trend the chemistry, so we have a good 11 sense through the evaluation process of how they handle 12 chemistry, how they handle shift turnover, and today how they
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handle the simulator.
But getting at the heart of maintenance 14 is just simply more difficult.
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i 15 How does a guy really go about fixing this pump?
16 Sometimes it takes three days, and three shifts will work on 17 the pump.
So INPO doesn't see the details of that.
It takes 18 a lot of planning and scheduling in advance.
Somebody has to j
19 order a part; somebody has to get the QC arranged; somebody i
j 20 has to get the radiation protection measures set up.
I 21 So it's much more difficult to get our arms around
'22 that, and we've come to a recognition of that, undoubtedly in 23 considerable measure because of prodding by the NRC.
24 To address that, we're doing two things, and that is i
k.
25 we have asked every utility to do their own.self-assessment
~
i l
22 1
using a maintenance guideline that we published, and the
-- gx 2
. feedback that we get on the guideline from four pilots is that 3
it really is right_on the mark in describing the baseline 4-maintenance program.
Every utility has been asked to do that
'5 self-assessment and to give us a copy or a summary of their 6
plan by the and of this year.
7 Separate but complementary to that, we have formed 8
two~ maintenance teams that will visit a number of plants 9
around the country, good plants and some that aren't doing 10 quite so well in maintenance.
And the composition of these 11 teams is far greater in resources than the INPO evaluation.
12 For example, the team will include a team manager and four, r^
13 five or six other people from INPO.
\\_.
i 14 It will include a handpicked person from the NSSS 15 suppliers, like Westinghouse or GE or Combustion Engineering, i
16 Babcock & Wilcox.
And I made the phone calls personally to 17 ask the top managers in those companies to pick a person who 18 is knowledgeable in plant maintenance to go with us on our 19
' teams.
20 It will include a representative from EPRI who will 21 be involved with the Nuclear Maintenance Assistance Center 22 that's being established -- it's already established by EPRI 23
-- and last and perhaps most important, it will include 24 industry representatives from plants that have good 25 maintenance.
4 23 1:
For example, we've just had a-team at Grand Gulf,
.r>
2 and one of the members of the team is the Maintenance j
3 Superintendent from another plant -- Zack, you could probably 4
tell me where that's from -- and in addition, the team ~will 5-include.a representative from their own utility, carefully 6_
picked by an executive in the ugility.
7 So the result of that is, for example, in this one I.
8 just mentioned, we identify some 30 recommendations wherein 9.
the INPO evaluation, more in recent history, we've found --
10 we've had maybe thren, four, five or six findings.
11 So the utility will use that review and assistance j
12 visit result, which they participate in, to develop their plan
~
13 that ties right into their own self-assessment.
So that's a brief description of the key element of 14 15
.the.new maintenance initiative where a team of carefully 16 selected people focuses, and the team spends three weeks l
17 working on this project, two at the site, helping the utility I
18 really get at the heart of maintenance.
1 19 Just to summarize, four utilities conducted pilots 20 to see that the self-assessment process that has been developed 21 will actually work.
Those were Florida Power, Middle South, f
22 Georgia Power, and Duke Power Company.
All utilities we expect 23 will finish the self-assessment by the end of this year, and we 24 expect our two maintenance teams to get around to the plants 25 that we have scheduled by early in
'88.
And I'm confident that
24
- l
.these couple of initiatives will give us some further steps of
'p, 2
progress in a intenance.
3-
-We believe the utilities, EPRI, the NSSS vendors and
.4 NUMARC as well are supporting these initiatives.
The goal 5
we're all seeking is improved station maintenance; and 6
therefore, improved safety and reliability.
7 Mr.. Chairman and Commissioners, this concludes our 8
formal remarks on INPO programs and activities, and we would 9
be pleased to try and answer questions.
10 CHAIRMAN ZECH:
Thank you very much.
11 Questions from the Commissioners?
12 Mr. Asselstine.
J 13 COMMISSIONER ASSELSTINE:
Yes, just a couple in 14 several different areas.
Let me start with accreditation.
15 To what extent -- one of the things I've been
'16 concerned about, I guess since we learned of the Peach Bottom 17 business, is to what extent the utility training programs 18-focus not only on technical competence, but also on attitudes, i
19 understar. ding the importance of following the rules and 20 following procedures, and attitudes towards safety.
To what i
21 extent is that built into the training programs?
To what 22 extent do you all look at that as part of the accreditation 23 review process?
And what's your overall perception in terms 24 of where we are on that?
v 25 And I guess one of the things'that.I have in mind in
25 1
particular is, I gather in the case of Philadelphia Electric, p.
2 that was a utility that you singled out for some, in some 3
sense, special recognition in their performance on improving 4
training; and I guess I wonder how you think that squares with 5
the Peach Bottom experience in terms of what at least what we 6
know of it now.
7 MR. PATE:
Let me answer just one part of that.
I 8
think it's fair to say that the special recognition afforded 9
by INPO was only in the sense that Peach Bottom was one and 10 Philadelphia Electric was one of the first 12 utilities to 11 become a full member of the Academy with all programs 12 accredited.
And that is a fact that is -- in fact, I think 13 they were about third or fourth in that process.
14 But with that introduction, let me ask Ken to address 15 the attitude, and particularly with respect to the role of the 16 National Academy for Nuclear Training.
17 MR. STRAHM:
If I miss any of your questions, I'm 18 sure you'll ask them again.
But really to start with, what 19 does the training program process do?
20 One of the reasons for starting the National Academy 21 for Nuclear Training was realizing that training can't do 22 everything, because the National Academy for Nuclear Training 23 isn't the training organizations, it's really the utility; and 24 it's the line management throughout the utility and using the 25 training organizations.
~
r 26
- L The training programs can work on attitude.
It can 2
work on professionalism and it can work on those things.
But 3
they really only have the-people for a small percentage of the 4
. time; and then when they go into the plant, then, they are 5
really being coached and trained by their first line
-6 supervisor, second line supervisors and managers all the time, N.
7 either correctly or incorrectly.
8 So, the training departments, yes, they can work at 9
it, and they are working at it.
And, yes, we do observe that 1.
j 10-both during plant preparation and during accreditation.
We t
11 sit on a program, sit in on the sessions, watch the simulator.
a 12 evaluations, we look at that.
And we make comments on that if r-
-13 it's not going -- if that is not happening, during their
(.-
14~
Accrediting Board visits.
15 Then one of the things that the Accrediting Board probes into is the support of line management, because when 16 i
17 they come before the Board, then the vice president of Nuclear, 18 line manager, plant manager, say if it's maintenance, it would l
19 be the maintenance manager, and also the training people that 20 had to do with the program are there answering questions of the 21 Board.
And the Board really hones in on the responsibility of 22 management, you know, to trains that they are out to have 23 trained and professional people.
l 24 Let me stop and let you ank your next question.
N 25 COMMISSIONER ASSELSTINE:
I gu~ess,that sort of was l
l
c.
27 1
my sense for where we were.
And I guess on the attitude
'p 2
thing, I wonder whether that's something that you can bolster 3
your look at, either through the training programs or whether 4
you ought to focus more on the evaluation visits and the-5 effectiveness of management performance as a way to try and' 6
get at identifying those kinds of problems.
7 MR. PATE:
We're.saying that training can do so 8
auch, but line management has to really take the line share of 9
this responsibility for attitude.
It can in part pass the 10 buck, if that be it.
So let me ask Pat to take a shot at 11 that, and then I'll try.
12 COMMISSIONER ASSELSTINE:
Great.
rs 13 MR. BEARD:
During the evaluation -- during our
-(
14 plant evaluations incorporate also, for that matter; one of the 15 key things that we look for is the management control, the 16 fostering of a questioning attitude, adherence to standards, 17 following procedures.
I might also add that while we're at a 18 plant, until we typically spend 20 to 40-hours total of 19 evaluator time, and the back shifts, for example.
20 And then when we see an apparent lack of management 21 inquisitiveness, holding people accountable for their 22 standards, a. lack of questioning attitude; those are the types 23 of things where we will probe deeper and ask the next 24 question.
Then that relates to attitude.
't 25 And I think that we see the pr'oper, attitude, you
28 1
arrive.at that in a plant through line management doing those D
2-things that I mentioned; being involved, holding people 3
~ accountable to the standards that they expect.
4 So that's a very important part of our plant 5-evaluations.
6 COMMISSIONER ASSELSTINE:
When we heard the staff's, 7
at least, initial report to us on Peach Bottom one of the 8
comments that they made in the public sessions as well as in 9
the private one was that the situation seemed to be that 10 these operators behaved-themselves when we were around and 11 when you were around, and when we weren't, they didn't.
I know 12 that's something that is of concern to us in terms of how to 13 tailor our inspection program, so that we really do get a fair 14 assessment to how people are performing and what their 15 attitudes are.
16 I guess I wonder if you have been thinking about the j-17 same things.
For two or three weeks you're there day in and 18 day out, and if everybody is behaving themselves you don't 19 spot these kinds of problems.
There are ways to try and l
20 compensa*e for that difficulty.
Is that something you're I
21 thinkity about as well?
22 MR. PATE:
We have given a great deal of thought to 23 that.
And I should say that, notwithstanding our comments l
24 about what we're doing and who is responsible, we feel a l
25 shared responsibility for the situation at, Peach Bottom, and
e 29 1-we don't excuse it in any way, and it wrenches ~our insides s.
2 when we think about it and realize that that situation existed 3
or exists or existed.
4 I think that the -- I think it's common knowledge
-5 that'the NRC staff had concerns about the line management-6 organization that supervised Peach Bottom, and that INPO did 7
as well, And I think that we saw a lot of symptoms that the 8
climate wasn't right.
And I think that just reinforces the f
9 idea that the line management has to establish a climate, and 10 has to set'the standards, and has to assume the' front line 11 responsibility for seeing that the operators carry out all of -
.12 their duties to high standards.
13 People have proposed steps since that happened, that
(
j 14 might solve the sleeping problem, but wouldn't solve the 15 overall problem.
For example, I've heard proposals to have 16 the security guards go and check that people are awake.
- Well, 17 that might see that they're awake, but if that climate exists l
18 that we are all worried about, if they don't sleep they may do 19 something worse.
j 20 So, we really have to get at that climate and that 21 attitude through the line management organization, and through 22 things that we work on like the National Academy of Nuclear 23 Training that pushes professionalism above all else.
And like 24 l
Pat described, we've got to have the inside to pick up in the x,
25 INPO evaluations when the total line ma'nage. ment organization
.._.-_.-._--._.,,,~._.__.__-.-_.,--,_.-r_,-,-..
,.--,__...__.,___m..-.
3 30 ll.
is not setting the necessary standards, and something like.
- >f
'S y
i 2
-that, or even something worse.
3 We see'the signals that something is' coming.
I know i
4 the NRC staff is working hard on that.
5 COMMISSIONER ASSELSTINE:
Back on accreditation.
6 Ken, my impression is on the new plants that most of the new 7
. plants are really charging right along, that if anything, they 8.
tend to be running well ahead of the commitment.
Is that 9
pretty much right?
10 MR. STRAMM:
Yes, that's true.
lL1 COMMISSIONER ASSELSTINE:
So, they're running well 12 ahead of the two year limit or vnatever it is for each one.
13 MR. STRAHM:
Yes, sir, they are.
That's correct.
14 COMMISSIONER ASSELSTINE:
One other question on 15 operational reviews.
And it picks up, Zack, on the point you 1G just made about the effectiveness of line management.
We l
17 certainly identified or indicated that there were a group of 18 plants that we're concerned about along those lines; ones that 4
l
.19 we think really need to bring about fairly significant 20 improvement, may have programs underway, but we haven't yet l
l 21 seen demonstrated effectiveness on those.
22 I just wanted to make sure that, from your standpoint 23 we're focusing on the right plants, that there aren't others 24 out there that you all think fall in that category that we may w.
25 not have picked up on yet.
Are we zero'ing.in on pretty much 4
-, - - - - -.... ~.. -..., - - _,. - - -,. -
.,.-,..-...,..,n..
.-n_,...---,.n_.,.,-..,nn.-_,-,,,_,-_
31 1
the right group?
b 2
MR._PATE:
I.think it's fair to say that the plants 3
with the most troublesome situation with respect to supervision 4
of operation are shut down.
9 5
So, I'think the system collective.1y with the NRC 6
being the strongest part of the system is, in some sense, c.
7 working.
And I d n't -- we, for example, have just completed 8
an evaluation and have asked that utility to communicate to 9
the NRC the concerns that we had.
And that I know has been 10 done to the region and to the cognizant person at 11 headquarters.
12 So, there's a recent case where we did an evaluation 13 and the situation was troublesome; and we asked them to s
14 communicate.
In fact, provide a copy of the concerns that s
15 we enumerated in very clear terms to the commission at the 16 appropriate levels.
So, when that happens we do communicate 17 it to the Commission.
18 COMMISSIONER ASSELSTINE: ' Good.
Good.
The new 19 plants, Zack, I agree very much with your comments.
I suspect 20 they are getting a disproportionate share of the effort within 21 the industry.
They may be from us as well'and with somewhat 22 good reason.
In fact, I guess one of the ones I have been 23 keeping track of most recently ir Vogtle, and I guess as of 24 yesterday they were up to about 12 trips in a span of little
(.
25 over a month, which indicates that the new plants ought to be
~
32 1
getting probably a heavier dose of attention both from the
- p 2
industry and from the NRC.
3 I guess one of the interesting things that I've seen 4
over the past few months is the AEOD report of start up.of 4
5 plant operations; and one of the more interesting conclusions 6
was, how a plant does the first few months of its operating 7
experience pretty much dictates how that plant is going to do 8
over the next several years. 'Has that been pretty much your 9
perception as well?
I was curious of what you thought of that 10 conclusion from INPO -- I mean, from AEOD?
11 MR. PATE:
I have not specifically thought that 12 through, and I haven't yet seen that AEOD report.
So, let me 13 ask Pat and/or' Bill to give me a hand with that.
14 MR. BEARD:
I've read parts of the report and I 15 think we would tend to agree to that with a premise to --
.6 certainly to some extent.
In fact, one of the specific 17 initiatives of our new plant or elements of our new plant i
initiative is to put an enhanced operational event review on 18 19 the new plants and try to spot these trends that emerge, if 20 they emerge early, and then go do something about it.
And 1
21 Pete's group is working on that.
22 Bill, do you have anything to add?
23 MR. CONWAY:
I guess I would only say that I think i
24 it is very -- I've read the report myself personally, and I j
s, 25 think I agree fundamentally with what it says.
And I think l
l l
l
-- ~._ _ _ _...,_. _,.
33 l'
one of the things that has to be precluded, perhaps, is to try n
~
a=
2 to turn.around whatever mindset can get in place with respect-3 to having scrams,'so they don't become a way of life, short 4
circuit that rather quickly.
5 COMMISSIONER ASSELSTINE:
Is it possible to take 6
that kind of a review maybe a step back and try and identify 7
what are the root causes that can get you into a situation 8
where you experience'several years of more troublesome start 9
up operation, so that as you're doing these early reviews, 10 when you visit a plant six months or so before it's ready to 11 go into operation, you can try and say, " Wait a minute, are 12 these guys really on the right course.
Is this the kind of 13 operation that's likely to lead to a very successful start up, 14 good first few years of operation, or are they on the course 15 that may likely lead to a much more bumpy road and some 16 potential bigger problems."
And are you looking at that 17 kind?
18 MR. PATS:
That's one of the things that for sure we 19 hope to identify in the booklet that we described earlier thnt 20 capitalizes on common experiences.
One of the things that 21 we've seen at some new piants is a very slow shift from the 22 construction, get it built, move any obstacle to finish the l
23 system and get it tested and start operating to a quite I
i 24 different climate that needs to exist, smooth troublefree l
(
25 operations.
I think we've seen that as a pitfall in several
34 1
places.
C 2
Now, Ken just points out three plants that have some, 3
rough edg'es in start up, but pretty soon doing pretty well.
4 4
So, there are some --
5 COMMISSIONER ASSELSTINE:
Exceptions.
e 6
MR. PATE:
-- exceptions to that.
7 And, Pete, did you have anything to add to that from j
8 the review of events that sometimes some of the plants are --
9 MR. LYON:
We are now looking at the new plants in a 10 very similar fashion, the way we look at our operating plants 11 going back through the history of events that the new plants i
12 have had during start up phases.
And for similar type plants
- (~
13 taking that type of information from our database and providing 14 it to the new plants in an early enough manner that they can 15 learn from that experience, like we do our operating plants.
16 And getting in early enough before the start up phase, so they 17 can train their people and point out the pitfalls of these l
18 previous incidents.
19 So, we're trying to give them the benefit of the l
20 learning experience that other new plants have had during i
' 2:L start up.
I 22 COMMISSIONER ASSELSTINE:
Good.
Good.
I think 23 that's a very useful exercise.
When I look back over the past l
24 few years I find that I was probably right or wrong as many ix -
25 times as I was right in terms of my initial perceptions on how
- t' E*.
35 1
plants would do, on both sides, ones that I thought might have
[
2 a rougher time and others that I. thought would do quite well.
3
'And to the extent that we can learn those lessons and share 4
them with, at least, the few other plants that are still 5
coming down the pike would be useful.
6 I have another question on maintenance.
Based upon 7
the self assessments that have been done and the results you 8
have seen thus far, to the extent there are weaknesses or room 9
for improvement in the current maintenance programs, are you 10 able to identify what the root causes are and do they reappear 11 in several cn one or more of these programs, are they, for 12 example, the people and their basic qualifications'or the 11 3 training, the equipment, the manufacturers' directions on how 14 to do the maintenance, the design of the plants or a 15 combination of all those kinds of things?
16 MR. PATE:
I think in the many evaluations we have 17 done to date, we have concentrated primarily on management 18 controls, and that's part of what I was talking about earlier i
19 when I said we really hadn't gotten into the heart of l
20 maintenance activities, which is the kind of thing I know you 21 are talking about.
22 We put a lot of attention to tag outs, to the work 23 order control system, where the items that were broken in the l
24 plant, really in the system, and did they have a reasonable
'(
25 priority, when equipment was worked on, was it taken out L
F 36 1
service properly, going back to the TMI thing, was it properly 1
2 tagged out, and'when the work was done, was it properly 3
restored.
Was the test' equipment that is used in maintenance 4
properly calibrated.
Those things are more amenable to the.
5 INPO evaluation process, through the new initiative.
6 We haven't done enough to really be able to answer 7
the kind of question you raised as yet, but I think it is just 8
a matter of months until we have some further insight into 9
that.
10 Many, many times we wrote the finding that 11, supervision of maintenance activities needs improvements, 12 needs to be upgraded and so on, when we saw examples of 13 technicians that were waiting on parts or that put the packing 14 in three times and still didn't get it in in the right 15 sequence, the supervisor didn't show up.
We have seen that as 16
-a generic problem in many places and we have pushed on that, 17 to get the supervisor out of his office and out in the field.
18 That cures a lot of problems but not all of them.
l 19 I think we have to defer to give a better answer to 20 that question.
21 COMMISSIONER ASSELSTINE:
The last question I have, 22 Zack, you mentioned hot particles.
I had a conversation with 23 one of our health physicists not long ago who brought to my l
24 attention that we have sort of seen a rash of these at several
[(
25 plants.
I wonder if you all have looked at that problem, if I
r
37 1
you have-some ideas on why you think we are seeing those.
'2 Is it these new portal monitors or frisking devices 3
are a whole lot more effective and better than the hand held 4
ones, is it a-problem that has probably been there for a long 5
period of time and we are just picking it up or is there 6-something new that is going on that is causing these 7
difficulties?
8 MR. PATE:
We have seen the same pattern that you 9
are talking about.
The extremity, over exposures that have 10 occurred, and I know we are looking at that.
11 MR.ELYON:
I think it's a little bit of everything 12 that you said, commissioner, that is contributing to it, with 13 the high sensitivity portable monitors being a big part of 14 it.
These have probably been around for a while and we were 15 unaware of it.
There are a couple of other contributing 16 things that we are working on.
17 one is the contamination levels of the systems, of 18 the plants, trying to maintain cleanliness of the systems 19 through better fuel integrity, better maintenance procedures 20 as far as cleaning up after maintenance work so you don't 21 leave the particulate matter within the primary systems to 22 become contaminated and then become a maintenance problem when 23 you have to do work on the valves.
24 All of this ties into the overall problem of
(
25 maintaining better work habits and tighter. procedures during
=.
38 1
maintenance.
There is more we can do and we are looking at
[
~
.2 it..We will put out a significant event report in the near i
3 future that shows the trends of these recent events that we 4
have seen.
5 COMMISSIONER ASSELSTINE:
How big a challenge is it J
6 to get those things cleaned up, to the extent that there is a 7
problem out there?
8 MR. LYON:
As far as the contamination goes, that is 9
a long term process, changing work habits and then taking time l
10 to get the primary coolant cleaned up is a slower process.
I' 11 COMMISSIONER ASSELSTINE:
I gather these are pretty 12 small particles.
13 MR. LYON:
Some of them are not even visible to the 1
14 eye.
15 MR. PATE:
One of the plants calls them fuel fleas.
16 I think the problem is addressable through training and i
17 awarsness.
We are working on a product in the event analysis 18 program to get several that have occurred out to industry as 19 an insbructional process.
It is not a new phenomenon but the i
20 number that have occurred represent certainly a new trend.
21 MR. BEARD:
Zack, I am going to add two things that 22 relate to that.
In the evaluation process, we are putting 23 more attention on the specific techniques, particularly when 24 you are working in containment, doing fuel handling or cutting s.
25 stuff, techniques that you can use to minimize a hot particle l
i 39 l-instance, and secondly, we are working with the industry in
. p 2
the local of fue,1 integrity, enhancing and improving that-3 aspect, lower activity in the fuel.
Therefore, you could say 4
a lesser probability of having a fuel particle, a fuel flea.',
5 COMMISSIONER ASSELSTINE: -Are these pretty much 6
traceable to fuel failure problems in the past, basically?
7 MR. BEARD:
I'm not sure.' Pete?
8 MR. LYON:
I think it is a combination of that and 9
the maintenance, contaminated particles from maintenance.
10 COMMISSIONER ASSELSTINE:
That's all I have.
'V 11 CHAIRMAN ZECH:
Thank you.
Mr. Bernthal?
y 12 CCMMISSIONER BERNTHAL:
Just a question or two.
I 13 apologize for being late.
I had a noon time commitment that 14 got a late start.
15 I wanted to ask a question about performance 16 indicators.
You have your own set of performance indicators 17 and criteria.
The NRC has now approved a set that appears to
[
18 correlate rather highly with the criteria that INPO is using.
19 The question arises as to exactly what the purpose l
20 is of that apparently rather duplicative effort.
Could you 21 speak a little bit to whether we should view that as a valuable i
22 cross check or whether with some exceptions perhaps we really 23 should be seeking a different set of indicators and perhaps 24 with your suggestion and vice versa for that matter, are the I
- - (_ _,
25 NRC's better able to look at a particular indicator or perhaps L
40 s..
1 empowered by law to look at a particular indicator where it 2
would b,e more appropriate here than at INPO and vice versa?
3 I remember when we first agreed to begin the program 4
here, what finally turned up was a set of criteria,' performance 5
indicators, that looked remarkably similar to what INPO was 6
using.
Maybe you can give me some sense of whether we are
~
7 headed in the right direction and this should be viewed 8
as a kind of cross check.
9 MR. PATE:
We have been working recently with the
.10 staff on that.
I think some communication has just been sent 11 to the commission that represents hopefully a cooperative 12 approach to the matter.
We have been working on performance 13 indicators now for about six years.
We have come around to a 14 set of ten that we call overall performance indicators and we 15 stopped calling all the other things performance indicators 16 and we call them other indicators, the things that we think 17 are more appropriately management tools for the industry.
18 It turns out that what the staff came around to is 19 close to the same kind of conclusions that we drew.
I think 20 the staff ended up with seven.
The staff did not choose some 21 of the ones that IllPO chose for reasons that I think from the 22 staff's vantage point were valid.
23 For example, the staff didn't use industrial safety.
24 The staff didn't use fuel reliability of thermal performance, 25 where those are part of our set.
Those are overall management l
s
41 1
indicators but'not safety indicators lite safety system g-s 2
unavailability, which the staff did choose.
3 As it turns out, the staff chose seven and four were things that we already collected data on an'd then there were 5
two or three others that are kind of unique to the regulatory 6
process and of the nature you described.
7 We have been working with the staff o try to come 8
to an agreement where we give you the data for the ones we 9
already have and you get the data for the ones that you want 10 that we don't'get, so you have the data, plant specific data, 11 for all the seven that the staff wants to review and I know 12 the Commissioners will want to review it, and you use those in 13 your own in-house programs to track and trend the plants.
14 We think it's important that we use the same data 15 because if it is collected independently, there will be 16 inconsistencies and we have sean that, and then people will 17 focus on the minor inconsistencies instead of the important la things that the data tell you, if INPO is publishing one set L
19 and NRC is publishing another.
We know that happens if we are 20 not consistent so we think it is important to use our own set.
21 We think it is important that the NRC use these 22 indicators, what we just described in general terms, at the 23 senior management levels, and not have things like numbers of 24 scrams become a part of SALP reports because that puts undue c
- x..
25 pressure at the working level in a plan't, t.o try to reduce the
... _, -,_,....._ _ _._.~_.,.. - -. -. _.-... - -- _. _. _.. __
._., _ _. _.... _- _ _ ~ ~_- --___
42 1
number of scrams, or try to eliminate a scram.
We think_that
. (-.
2 has potential and direct safety implications where someone.at 3
the working level knowing it is a SALP judgment factor, and we 4
don't put that in our evaluation r'aports, just trying to help 5
his management, some operator or technician is trying to help 6
his management reduce scrams and he takes a non-conservative 7
step.
8 We think that is a vitally important aspect of this 9
whole cooperative effort on the performance indicators and 10 those indicators should be used at the senior management level' 11 within the NRC and not become a part, for example,_ of SALP 12 reports in the case of scrams.
~-
13 COMMISSIONER BERNTHAL:
Isn't that a pretty 14-idealistic hope?
It seems to me that when it is all said and 15 done, you are going to get a qualitative, subjective impression 16 if nothing else from a set of data that INPO might communicate 17 with our staff, and obviously our own staff gets a similar 18 subjective impression from its own data.
I think ultimately 19 that is bcund to influence performance indicators.
20' MR. PATE:
I think it's a haalthy thing for the 21 industry to use performance indicators to establish their own 22 goals to reduce scrams.
(
23 COMMISSIONER BERNTHAL:
I'm sorry.
I didn't mean 24 performance, I meant SALP ratings.
Let me back up.
(..- -
25 Ultimately, the subjective, qualitative' imp.ressions that I as l
l
- _. _ _ -. _. _ _ _. _ _ _ _. _ _.. _. _ _. =. _ _ =. _ _.,.. _,, _ _,
43 1
a staff person, if I were one, might gather from INPO's data
'p 2
and our data on performance indicators, it seems to me it is 3
inevitable that creeps into the SALP ratings; does it not?
4 MR. PATE:
If it creeps into the rating in the sense 5
that the NRC's overall assessment of how a plant is doing is 6
thus and so and part of that decision and part of that 7
conclusion is knowledge of the performance indicators, that's
- 8 one thing, but when it shows up in a paragraph in the SALP 9
report that says such and such a plant has had an excessive 10 number of scrams and that's right in the SALP report, the 11 utility already knows that because they already have a goal, 12 and everyone of them has a goal, and then the message that' 13 transmits to the working level in the utility is that the NRC 14 is mad at my. plant and my management because of an excessive i
15 number of scrams, not because of some directly related safety 16 EJoblem like findings in the SALP report that have to do with 17 a lack of reliability of safety related systems or mis' sed 18 surveillance tests or other things that have to do directly 19 with safety.
20 A scram is a safety function.
Scrams in the final 21 analysis are a necessary part of what we do, and if the 22 regulator transmits a message to the working level that these i
23 things have to be avoided and reduced, we really worry that i
24 the technicians and operators may take a non-conserv.ativa
\\
25 action.
f
_ _. ~
44 1
That doesn't happen when a SALP report focuses on p
2-say maintenance or focuses on proper shift turnovers or 3
focuses on missed surveillance tests and those kinds of 4.
things.
i 5
'That is where we think the use of performance 6
indicators at the working level by NRC people can have an 7
adverse safety impact.
Therefore, we think it is important to 8
cooperate'in the effort, to exchange data in the effort.
We 9
think it is important that we use the same indicators where 4
l' 10 the data is common.
We still have some more work to do to 11 work out a cooperative agreement with the staff but we feel 12 very strongly encouraged to do so and to work out an agreement 13 that is. acceptable to the staff and the Commissioners to use
(
14-these indicators in the proper way in industry.
15 We still think there is some work to be done to 16 achieve that.
t' 17 COMMISSIONER BERNTHAL:
I guess it's unclear to me i
l 18 why in those four areas, and I don't guess I can name them l
19-right now, that we have the same indicators, you would expect 20 signifit' ant differences.
I'm sure we won't have differences 21 that are significant once we get the act together in gathering 22-the data.
i 23 You also mentioned maintenance.
Why wouldn't the 24 ratio of planned or scheduled to unscheduled maintenance, for I -
25 example, be a perfectly legitimate performance indicator that l (.
b.,'
45 1.
I can argue as well as not belongs in the domain of INPO and
(~,
2 in fact INPO may be in a better. position to gather data on 3
something like that than the NRC.
(
4 Why shouldn't that be one of your performance 5
indicators, in other.words?
6
.MR. PATE:
Well, let's take-the example of 7
maintenance work on a hacklog, and we've listed that all'the
~
8 time as one of what we call the other indicators.
And we i
9 encourage our members to track maintenance work on a backlog.
10 We don't use the maintenance work on a backlog as an indicator 11 of how the plant is doing and stress that in our work with our 12.
members for the following reason; it's easy to change the 13 number that represents your maintenance work on a backlog.
,f 14 For example, you can put one leak, one' fluid system 15 leak on-one work order; you can put 60 on the same work order 16 just by attaching a list.
So, you can reduce the number of 17 maintenance work orders by-60 by thd administrative process.
18 But when you do that, you may not get the quality control or-19' the radiation protection measures or the ordering of parts 20 under the careful control that you would have if you had 60 l
l 21 separate work orders.
22 So, the utility leans toward a step that isn't I
23 supportive of good maintenance as having a higher number of 24 work orders in that case.
\\~z 25 We think that's something that management at the
... _ _ _ _. _ _ _ _, _ _ _ _ _ ~
46 1
utility has to get right in the middle of and has to understand
' p" 2
.how many of those work orders are on lawn mowers and how many 3
of them are on auxillary feedwater pumps, and the plants mix 4
those up.
I mean, we have seen a maintenance work order on a 5
lawn mower right in there with one on a piece of equipment in 6
the plant.
7 So, the management has to get into that detail and 8
determine what is an acceptable maintenance work order 9
backlog.
Frankly, at some places 2,000 maintenance work order 10 float isn't so bad; and in another place it's 500 that's 11 acceptable.
So, wa-think it's important for the utility to 12 trend it.
But we just found it impossible to use that as an 13 outside measure of performance.
~
14 COMMISSIONER BERNTHAL:
One short answer, I hope, 15 question.
How well are you doing in achieving some of the-16 goals that you set for your members?
I have a document in 17 front of me here, for example, that I guess dates from late 18 1984 where you had set goals for capacity factor and forced i
19 outage rate.
20 One also again might ask a planned to unplanned 21 maintenance outages, what's the progress been since late 1984; 22 are you getting anywhere close?
23-MR. PATE:
Let me just take them one-by-one, and 24 I'll take seven of the key areas where the industry set 1990 a k-25 long-term goals.
s
~
47 1
We take on plant scrams while critical.
The trend I'
.2 is nicely down with the 1990 goal.
I realize this is not the
.3 scale, this is farther out.
I won't show this because the 4
Lwhole audience can't see it, but let me just talk them 5
through.
6 In the case of scrams, we've gone from 7.4 per unit 7
as an average in 1980 to 3.9 in 1986.
So, we're making good 8
progress in that one.
I'm going to name the ones where we're 9
making good progress and and it on a note of the problem lo areas.
11 On plant safety system actuations is showing a 12 favorable trend.
Forced outage rate is not, and I'll.come 13 back to that.
Thermal performance has come from 10,504 to i.----
' 14 10,315 with a 1990 goal being 10,260.
So, that's showing a 15 nice favorable trend.
16 Collective radiation exposure, the BWR plants has 17 come from 1230 per unit per year to 622; it has been cut in 18 half.
The 1990 goal is 469.
It's surely within reach of that 19-trend.
The same thing with PWRs where we've come from 600 in 20 1980, 707 in
'82, down to 397 in 1986.
l 21 Low level radioactive waste has come from 1100 cubic 22 meters for the average BWR in 1980 to 403 in 1986.
23 Now, industrial safety has come from 1.35 per 24 200,000 man hours worked to.4 in 1986.
It has been cut by a l
l(,
25 factor of more than three.
And the 1990 goal is achievable by l
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48 1
that trend.
fy 2
The place where we're having trouble is forced 3
outages.and' availability.
And the trend this year, for 4
example, in forced outages is down, that is, more forced 5.
outages'in the previous year.
6 And then availability, I'll give you the explicit 7e numbers.
Availability, we started out in 1980 with an 8
industrywide average availability of 59.3 percent.
We got to 9
a peak of 63 percent in 1985; and we're down to 60.3 percent-10 in '86.
And as an industry, our goal in 1990 is 76 percent.
11 Now,.we have not done so for any formal record 12 keep'ing, but if you take five or six plants that are shut c
13 down, like the TVA plants and Rancho Seco' plants for almost 3
14
. institutional reasons, if you take those out of the-database 15 the number goes to 66 and a fraction percent for '86.
16 So, I think the key to success in the forced outage 17 case and'the availability case is to get to the point where we 18 work our way through these institutional problems that exist 19 at TVA and other utilities.
If we can do that, we have a good 20 shot at making the 1990 goals in many of these categories.
I 21 COMMISSIONER BERNTHAL:
I agree that in a way it's 22 not quite a fair comparison to compare France, for example, 23 with -- what is it 55, 60 odd utilities that we have where 24 there would be a few of them get in deep trouble
(,
-25 institutionally.
So, they aren't even"trying to run the
(
49 1
plants at that point, in effect.
p 2
Thank you.
3-
' CHAIRMAN ZECH:
Commissioner Carr.
4 COMMISSIONER CARR: 'On accreditation,.when are we 5
going back and check accreditation; do you have a program for 6
maintenance of accreditation?
e 7
MR.'STRAHM:
Yes, sir.
In fact, I even have a 8
schedule.~
9 COMMISSIONER CARR:
Have you looked at anybody 10 already that has been accredited once?
.' 11 MR. STRAHM:
The first self-evaluation will be 12 coming in, in July and that's of Oconee, which was the first 13
. plant accredited.
And then right after the first of the year 7.;
14 Arkansas is due and then Sequoyah is due right after that; 15 they were the first three.
And then we get about the summer 16 of '88 is when it starts getting heavy; that's the worse.
We
- tart this summer, yes, sir.
17 s
18 Basically, we reaccredit them about every four 19 years.
It's going to be a little different, some people are 20 going to get it a little earlier right here at the beginning, 21 and that's just because about where we got when everybody got 22 started.
And so some of the programs -- and we're also 23 planning to do half the programs every two years, so that 24 we'll actually visit every plant every two years and we'll s.
25 look at half their programs each time we lo.ok.
50 3
3 1
COMMISSIONER CARR:
We had a briefing the other day 2
from the industry and the EPRI gent-said that in the Surry 3
incident, as soon as they had the Surry incident that they got 4-a lot of information from everywhere on incidents that had 5
happened'like that, and I asked him why he didn't get it
~
6 before Surry, so we could do something'about it.
And he said,
'7 "Well, it came from fossil fuel plants."
8-Do you have any look at fossil fuel plants to feed 9
that'into your database?
i 10 MR. PATE:
No, sir.
11 COMMISSIONER CARR:
Well, that's the first I had 12 heard of it, that there was some database in fossil fuel that 4
~
13 suddenly became available after the Surry incident and that 14 particular case, you know.
2 15 MR. PATE:
We'll have to look into that because we 16 were aware that, at the time the Surry event occurred, it 17 occurred in what was thought to be a single phase, that is, 1G-all water system.
And we had quite a bit of axperience, I 4
19 think we-had three reports out on erosion in two phase 20 systems.
But we frankly didn't expect erosion of the type 21 that occurred at Surry.
22 And I think the NRC staff was --
4 23 COMMISSIONER CARR:
I think they're surprised, but the implication I got from the EPRI guy was, the data was 24 k-
'25 there, nobody had asked for it or nobody ha.d bothered to look
51 1
at it., And I don't know how much other data is sitting out f
2
-there that we need to look at; and I don't know how to go 3
about getting it, but it's an area you might look into.
j 4-MR. PATE:
I was unaware of that, and we will 5
certainly.look into it.
It's good feedback.
6 COMMISSIONER CARR:
We are working on a policy 7-statement on control room decorum.
As you may or may not knta 8
we had a radio playing in the control room which we took out, 9
and which we have now decided to put back in.
Do you all have 10 a position on something like that?
11 (Laughter.]
^
12' MR. PATE:
Yes, sir.
13 COMMISSIONER CARR:
I'd like to hear it.
' k 14 MR. PATE:
At the risk of entering into a -
1
]
15
. controversy, which we generally try to avoid in these 16 meetings.
17 COMMISSIONER CARR:
We're already on that.
18 MR. PATE:
We think --
19 COMMISSIONER ASSELSTINE:
That's all right, you've 20 got both sides represented here.
21 MR. PATE:
We have a criteria that speaks to the 22 control room decorum and it's pretty general.
And we have 23 written findings in previous cases when our members had a 24 radio over the sound system in the control room; and we think
(-
25 it's inappropriate to have that kind of sys. tem in a control
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2 In fact,.after I read the Commission discussion on 3
that matter, the article that we read said that the. radio
'4 would go back in the control' room, I personally called that 5
CEO or that member' utility and he assures me he's not going.to 6
.put it back in the control room.
7
' COMMISSIONER CARR:
That's a good decision.
8 CHAIRMAN ZECH:
I think so, too.
-9
_ COMMISSIONER CARR:
Thank you.
.10-MR. PATE:
But that's a standard of excellence.
And 11' I think I can take that position without advocating what the 12 NRC should do.
13 COMMISSIONER CARR:
Thank you.
k.. '
~14 COMMISSIONER BERNTHAL:
The question is how we do it 15 in this case.
16 CHAIRMAN ZECH:
Lat ma just ask you a little bit 17 about performance indicators.
First of all, I have not 18 changed my mind on how I feel about them, I still feel that 19 they are a tool for regulation.
Of course, they're only a 20 tool; I've stated that so many times.
21 I think they can be used, though, with other tools 22 such as inspections and analysis and reviews.
And they can be
'23 used to evaluate and compare plant performance.
I think 24 that's their basic value.
But I've always emphasized that
(
25-they're only one tool in the whole appr'oach., and that they can
- =-
~.
53
~
.1 be used, especially to give you a signal, perhaps, that A
2 something may be' looked into a little more carefully.
Not by 3
-themselves are they a primary tool, but they're one of many 4
tools we all have in this business of analysis, evaluations, 5
inspections and so forth.
6 And it seems to me that-they still could be used as 7-a tool to trigger an inspection that could lead to a commitment 8
on the.part of industry, part of a utility, to take actions to 9
improve.
10 How do you feel about that; does that make sense to 11 you?
Is.that kind of the way you look at it?
12 MR. PATE:
Mr. Chairman, I would say th'at's close.
r' 13 I think that, from-our experience, there is a considerable
(
14 time' lag between the time that the indicators show a trend 15~
.toward a problem, and when the management problems or the root 16 cause of that trend really develop.
17 So, what we find is, we find' problems during the 18 evaluations, and the performance indice. tors either help
- 19 corroborate or maybe don't corroborate what we see in the 20 plant evaluation process.
21 We think they're a valuable aid.
We think they are 22 well worth tracking.
We think the most important use, and I 23 really believe this, is by the utility line managers in 24 setting their own goals and developing their own programs that
(-
25 promote improvements and the kind in a broa.d range of
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54 l'
indicators thatLwe have just talked.
,s
(
.2-So, I think that you or.I are in close philosophical 3-agreement as to the importance and the use of the-indicators.
4 I think that probably the, maybe a slight difference in view 5
is the' emphasis that we both think should be placed on 6
reserving them for use as a management tool by the industry 7
executives, as point one.
And the enormous time lag between 8
when there's a root cause in the management, the line 9
organization of a problem, and the manifestation of that 10 problem by the performance indicators.
11 CHAIRMAN ZECH:
Well, I certainly agree, they should.
12 be used by management, utility management as a tool. 15y the 13 same token, I think they can be used by us, regulator as a i,
14 tool for regulation, not again by itself,' but with other tools 15 that we may have.
16 So, I think we are very close in the way we're 17 looking at it.
18 I also think that, although they do, the time lag 19 you're right, is something that is there.
And as you trend i
20 performances, though, in my judgment, my experience, there is 21 a trend occasionally that you can see that can be very valuable I,
22 to you, even though it's not a sharp steep curve.
If it's a 23 sharp steep curve, of course, it tells you something very 24 quickly.
If it's not a sharp steep trend, a rather gradual L_.
25 trend, it still could be very valuable to you.
l I
.. ~
55
'l And-those kind of things,-I think,-as a tool -- I C
~2_
-emphasize only one tool -- used with other things, I think can 3
be very valuable.
14 It's true that the time lag is something that must.
5 be watched, and that's every good reason why they cannot be 6
used alone, because they can be used,-though, to trigger 7
inspection,.to trigger evaluation, to trigger analysis, in my 8
judgment, that could indeed show that you have real problems.
9 And, of course, what I would hope is, we could 10 develop some kind of a system that would help us foresee 11 problems in the. future.
I'know how hard that is, but I think 12 the effort is worth it, to prevent serious problems.
g.
13 so, if we approach utility after an inspection 14 followed by performance indication, perhaps, and the utility 15
-would respond promptly'and successfully, that's what you would 16 hope would happen.
If you would not, though, and if they 17 would not respond, then I think you would cause yourself to 18 make' increased inspections, increased concern, and perhaps, 19 aven shut the plant down, hopefully, ahead of time if it was 20 going for a serious problem.
21 So, I think it's a very real merit to the whole 22 program, but I agree that we should continue working closely l
23 together on it.
And I think we can come up with something 24 that will be useful.
But I think we're making progress.
It's
.(
25 an effort that's worth making.
.. - - -.---.-- =.- -- -
[
56 1
MR. PATE:
Yes, sir, absolutely.
(:
2
. CHAIRMAN ZECH:
I agree, too, on the scrams, and I 3
think that we should be mindful that the scram is a safety 4
. measure for plants; and we should not discourage, especially 5-for manual SCRAMing.
Those shouldn't count at all in my 6
judgment.
.7 COMMISSIONER ASSELSTINE:
They don't, do they?
8 CHAIRMAN ZECH:
I hope they don't.
9 COMMISSIONER ASSELSTINE:
They're either ours or 10 the industry's.
~
11 CEAIRMAN ZECH:
I don't think they do.
But the
-12 point is the SCRAM itself, even if it isn't a manual SCRAM, we 13 should look at very carefully, because that's --- we want the
\\
14 plants protected.
We want them safe.
15 So, by -- we shouldn't even inadvertently encourage 16 people to think it's a bad mark against them if'the plant 17 scrams.
Sometimes you can tell if you're getting near a scram 18 condition.
It's better that the plant does scram or to scram 19 manually or even to scram by itself than to try to do something 20 that will keep it going and put it in an unsafe condition.
21 So, I think that's what you're saying, and I would 22 agree with you 100 percent.
r 23-Would you just discuss just a little bit on, perhaps 24 focusing on the Peach Bottom problem, management involvement I
(
25 think is so important.
To the many pla~nts,that all of us have
57-l' visited, I think most of us would' agree that one of the most p
2 significant safety measures, really, is the management 3
' performance itself, management involvement in the whole plant 4
performance.
5 You have inspected and evaluated a lot of plants.
I 6
know you've got a system of doing that.
How do you evaluate 7
management performance?
How do you evaluate management 8
involvement?
How do you get an assessment of management 9.
involvement, and by that I mean, specifically, for example, 10 attitude.
We've talked about it briefly.
I know how hard 11-that is to get, but attitude, responsiveness to INPO, 12 responsiveness to NRC, responsiveness to other industry
,e 13 utility. events.
In other words, an attitude of w.
14 professionalism, do you get a sense for that or do you try to 15 get a sense for some of those management professionalism, 16 those management involvement views when you visit your plants, 17 and how do you do that?
Can you explain just a little bit, 18 first of all, your views on the importance of it; and second l
19 of all, how you might make an assessment of that?
l l
20 MR. PATE:
Mr. Chairman, as I know you already know, i
21 that is a very tough question.
I will try to answer it in two 22 parts.
I think the importance we attach to that could be 23 maybe best addressed by going back to a speech I gave the 24 chief executives in our 1985 conference, which would have been
[
(_.
25 about 18 months ago now, where I tried to m.ake the point that i
~
p 58 1
unless the -- I used as an example the typical one nuclear 2
station utility realizing that the bigger utilities have to be 3
addressed in a separate kind of way, but a single station 4
utility to get excellence in nuclear plant operations, you 5
really have to have a top flight manager in the position of 6
chief executive officer, in the position of what we call a 7
senior nuclear manager, which is typically the vice president 8
of nuclear, and in the case of the station or plant manager.
9 If all three of those are pretty solid and if they 10 don't work as a team, then excellence is beyond your reach and 11 you really need to have one of those three as a hard charging,-
12 to borrow Lee Iacocca's expression, fire in the belly kind of 13 guy to manage this technology to the high standards that we 14 all expect.
15 We attach great importance to that.
We think in 16 addition to those three, which are so vitally important, that 17 the plant manager needs a couple of assistants uhat have the 18 ability and potential to do his job.
That's the audience we 19 are addressing in the senior nuclear management course.
20 If we knew how to run a similar course for the other 21 managers like the nuclear VP, we would probably set that in 22 motion, but the range of people in those positions vary so 23 greatly that it is very difficult to run a course.
We can run 24 a course for the people who will be plant managers and nuclear 25 VPs in the years to come.
v.
.~..-
L.
59 lL-I know the commission and the Executive Director, I
~
Vic Stallo, are supportive of that as manifested by the time 2
3 you have taken to talk to that audience-of people.
We attach 4
great importance to that.
-5 The question of how we ascertain how well the 6
management group is working as a' team and whether they have 7
the right standards and the right attitude, I'd have to'say we 8
look at every possible indication we can get, including how much'they have supported the National Academy in having their 9
10 programs ready for accreditation, what kind of response they 11 give to the events analysis reports that are furnished and 12 give them the training material and other material to 13 capitalize on mishaps at other plants, and of course, how they
't
-14 support using the evaluation to their advantage at their 15 plant, which is what we seek to get them all to do, and how 16 they participate in the exit meetings and most importantly, 17 how well they participate in the responses to the findings and i
18 the responses in a broad sense to the problems we identify and 19 others identify.
20 Those things are a direct reflection on the total 21 commitment of any management team.
As we all know, since 22 safety is such a powerful word and such a great concern, 23 virtually all the managers in the industry have the right 24 attitude toward safety and are supportive of developing good 25 training programs, and supportive of using.the training i
E.
-.~
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60 1
' material that comes out of an event analysis, and supportive
(;
2 of good responses to the report..
3 It is the actual implementation in the plant and-4 what is really done at the working level that is the true test 5
of that team's ability, that management team's ability.
6 I'd say we rely on what we see at the working level 7
.and what we see in actual practice in the plant as the best.
8 Our experience' tells us that is the best manifestation of how 9
that. team is working and what kind of attitude they have 10 managed'to instill in the minds of the plant people.
l 11 I realize that is not a complete answer but I think 12 the best way to say it is looking at everything we'can put 13 together when we sit down in preparation for an exit meeting, 14 and Ken has just pointed out that of course we concentrate a 15 lot in the evaluation process on observations of people at 16 work, like the observation of how is a diesel run, how is a 17 shift turnover done, and-in observing a shift turnover, you 18 get a pretty good read out right there of attitude and 19 observations of what is done in the-simulator and so on.
20 We put tremendous emphasis on measures of what is 21 being done in the workplace as in the final analysis being the
- 22 best measure of the question that you raised.
23 CHAIRMAN ZECH:
I think it is a good answer.
I' 24 agree it is a tough question.
It's such an important aspect 25 of our operations, at least it has been'my, experience in s_
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visiting the plants that those plants must have management r
2 involvement in a real business like professional, formal, 3
discipline sort of way.that really is attending to business 4
and do have that kind of a strong commitment to safety ar d 5
reliability and competent performance.
6 It's not easy to generate that kind of a real 7
commitment on a full time basis every day, 100 percent of the 8
time.
That is the key, it seems to me, if there is any key.
9 I think your continual observation of that important 10 element is very important.
I just encourage you to keep 11 management involvement at the top of your list when you are 12 continuing all of your assessments.
I know you will.
13 Are there other questions from my fellow 14 Commissioners?
15 (No response.]
16 CHAIRMAN ZECH:
Thank you very much for a very fine 17 presentation.
We appreciate it.
l 18
[Whereupon, at 3:35 p.m., the meeting was adjourned.]
19 l
20 l
l 21 22 23 24 25 s.
0 o
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
TITIS OF MEETING:
Periodic Briefing by INPO 8
PLACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING:
Wednesday, May 13,,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.
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 l
16 foregoing avents.
17 i
18
-- - 2 ' '
Joan Rose 19 20 21 22 Ann Riley & Associates, Ltd.
23
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24 25 l
1 1
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N Occum:nt Control Dask, 016 Phillips il 3
ADVANCED COPY TO:
The Public Document Rocm 5,15 i W1 DATE:
- j FROM:
SECY Correspondence & Records Branch lI Attached are copies of a Commission meeting transcript and related meeting i
document (s). They are being forwarded for entry on the Daily Accession List and i
.j-placement in the Public Document Room. No other distribution is requested or j
required.
Meeting
Title:
9e.A* A.! 4-3Me.b hu MiD I
t w
Meeting Date:
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