ML20217C108

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Transcript of 980304 Verbatim Proceedings in Matter of Northeast Utilities,Millstone,Units 1,2 & 3
ML20217C108
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Issue date: 03/04/1998
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' V> VERBATIM PROCEEDINGS NUCLEAR REGULATORY COMMISSION PUBLIC MEETING IN THE MATTER OF NORTHEAST UTILITIES, MILLSTONE UNITS 1, 2 AND 3 g ..

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2 l MEETING RE: MILLSTONE UNITS  !

MARCH 4, 1998 l

1 . . . Verbatim Proceedings of the Public 2 Meeting of the United States Nuclear Regulatory 3 Commission in the matter of Northeast Utilities, 4 Millstone Units 1, 2 and 3, held March 4, 1998, at 7:00 5 P.M., at the East Lyme Community Center, East Lyme, l 6 Connecticut. . .

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12 CHAIRPERSON WAYNE LANNING: Good

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l 13 evening. My name is Wayne Lanning. I'm Deputy 14 Director for Inspections in the Special Projects j l 15 Office. And welcome to all of you. l 16 This is our periodic meeting between the 17 NRC and the public. The purpose of this meeting is to l

you ll 18 inform of recent NRC activities concerning 19 Millstone, to solicit your feedback on the restart 20 process, and answer your questions or receive your f

f 21 comments concerning that process.

' $. 22 With me tonight on my left is Jacque 5

23 Durr. Jacque is the Branch Chief for the inspection l

24 activity. On my right is Dr. Bill Travers. Bill is O

U POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

2 MEETING RE: MILLSTONE UNITS l

i MARCH 4, 1998 1 the Director of the Special Projects Office. On his l

2 right is Phil McKee. Phil is in Headquarters and I 3 Licensing. He also provides oversight of the Safety 4 Conscious Work Environment. On his right is Gene 5 Imbro. Gene oversees the Independent Corrective Action 6 Verification Process. And on his right is Jim Leuhman, 7 who was a -- the Team Leader for a recent ICAVP 8 inspection which we'll talk about tonight.

9 And, of course, we also have the Senior 10 Residents with us here in the front row and other NRC 1

R 11 staff in the audience. I 12 This meeting is being transcribed. So V

13 when it comes time to ask questions or make comments, I 14 would ask that you identify yourself.

]

15 We're told that we must be out of this 16 nice facility by 11:30 tonight. So we must strive to 17 meet that deadline.

j 18 I want to briefly describe our agenda 19 tonight. We have a really full agenda. After I 20 describe the agenda, Dr. Travers is going to summarize

$ 21 some recommendations for improving this meeting. He'll

!. 22 be followed by Gene Imbro, who will give us a status of g 23 the Independent Verification Program and introduce the 24 Team Leader, who will summarize some recent inspection l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

4 l MEETING RE: MILLSTONE UNITS

l. MARCH 4, 1998 1 results.

2 Following Mr. Leuhman, Mr. McKee will 3 give us a status of the Safety Conscious Work 4 Environment activities and introduce Little Harbor 5 Consultants, who will also provide us an update of some 6 recent activities that they have completed.

7 Following that, Mr. Durr will summarize 8 the results of a recent inspection, the Corrective 9 Action inspection, that was completed on site last l

l 10 week. And there will also be the opportunity for you l

lg 11 to ask questions about our most recent Resident

'9 12 Inspector, the Inspection Report.

13 So, with that, I'll turn it over to Dr.

14 Travers.

15 DR. BILL TRAVERS
Thanks, Wayne.

16 I've put in the back of the room -- and l

l 17 I don't know if anybody or everyone has had a chance to ll 18 get it. But there's a handout that describes the 19 structure that we're intending to use for this meeting.

20 I should start out by saying that, as

$ 21 Wayne indicated, two of the key objectives that we have sa 22 in conducting these meetings are to present to the l

5 l 23 public in the evening a status of our activities in our 24 oversight program at the Millstone station. And the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

5 MEETING RE: MILLSTONE UNITS s MARCH 4, 1998

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1 second one is to provide an effective forum, really, 2 for your input, for your questions, for your comments.

3 And to do this effectively, from time to 4 time we've actually changed the way we've conducted 5 these meetings. To give you an example of that, when 6 we first started conducting these meetings, we had 7 sign-up lists for people who wished to make comments.

8 And based on input we got from people who had been 9 attending these meetings who felt that that wasn't 10 appropriate, we did away with those sign-up lists.

e 11 We also used to carry out these meetings C

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12 in a way that started with a complete set of O 13 presentations by NRC before any questions or comments 14 were allowed or permitted within the structure of the 15 meeting. And, again based on input we got from members 16 of the public who attend these meetings, we changed 17 that, such that the conduct of our meeting today is one l 18 where we discuss each individual agenda item and then 19 follow each individual agenda item with a discussion 20 period on that topic, followed at the end of the f 21 meeting by a discussion of miscellaneous Millstone i

. 22 topics. Just about any topic related to Millstone that E

g 23 people wish to raise or questions which they wish to 24 ask are served up at that time.

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6 1 MEETING RE: MILLSTONE UNITS

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O "^aca 4 1998 i

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1 We have received additional input since l 2 our last meeting and that input indicates that there 3 may be a problem in the perception of some in the way 4 we conduct these meetings. And to address that, we're 5 going to change the structure of our meeting once 6 again, at least on a trial basis, to see how it works 7 and perhaps change it, depending how well or not it 8 works.

9 The problem, simply stated, that has 10 been raised is that using the structure of the meetings

.R 11 -

they had been conducted for the last three months or a

'I 12 so, what occurs is the agenda items or at least some of O 13 the agenda items that we address have not been 14 addressed until very late in the meeting, sometimes l

15 well after 11:00. So while we may address two or three )

l 16 of the agenda items, if we have an agenda list of five l

l 17 or so items, very often, because of the way we (l 18 structure our meetings, people who are interested in 19 topics that come late in the evening really can't stay, 1

20 really can't spend the time to participate in our l$ 21 meeting and lose the benefit of whatever information I0 - 22 they might have heard by virtue of us getting to it lE

[ 23 quite late.

24 To address that, and recognizing that POST REPORTING SERVICE i HAMDEN, CT (800) 262-4102

7 MEETING RE: MILLSTONE UNITS D MARCH 4, 1998 (G

1 people just can't stay in every case that late, we are 2 going to institute at this meeting a structure that 3 will -- and I hope most of you have this -- that will 4 begin, once again, with an introduction by us, followed 5 by a discussion, a presentation by us of the first 6 agenda item, whatever that is. This is not an agenda 7 for this evening's meeting. It's, rather, a structure 8 for how we intend to carry out the meeting.

9 That agenda item as we have been doing 10 for months now will, in fact, be followed by a period g 11 of time wherein people can ask us questions or they can 6

12 make comments. But in order to get through the agenda 13 item list in a reasonable amount of time, we're going 14 to limit to about five minutes any individual questions 15 or comments on that agenda item and we're going to 16 limit the total time that we spend on each agenda item 17 to about 30 minutes so that we get through the whole l 18 agenda.

19 But, following that, as we have often i 20 done, and even when we're -- when we're not limited to 0

,, 21 11:30 -- some of you may know that we've stayed until ll= 22 after midnight sometimes. Tonight we are limited to l5 (l 23 11:30. But in instance where we have a hall until as 24 late as it goes, we're willing to spend as much time as O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 it takes at the end of that meeting to take your 2 questions, again, on any of the topics that we've 3 already covered or on any other miscellaneous Millstone

, 4 issue that you'd like to raise.

1 5 So the objection here is to be fair to j 6 the greatest number of people who wish to participate L

7 1 41 our process and to react, really, to a problem that l

l 8 has been raised, one we recognize, frankly, but one 9 which hadn't been raised until recently. And that is l

i 10 simply that by virtue of the way we had been g 11 structuring the meeting, we had not allowed for many N i 12 people who wishes to participate in all'of the agenda '

O 13 items to hear them and to comment on them fairly. I 14 So we need your cooperation in this l 15 because we recognize that at times it's difficult to 16 limit your own time. We're going to try to run the l 17 meeting in a structured way. We're going to ask you to 18 cooperate with us in that regard. And, again, we'll l

19 try to stay for as long as we possibly can at the end 20 of the meeting to address any remaining questions you

[ 21 have.

I 22 So, again, we're going to limit the time l 23 you have at the microphone to five minutes. At the end 24 of the meeting, we'll also limit it to five minutes.

O' POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

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MEETING RE: MILLSTONE UNITS (O

%J MARCH 4, 1998 1 But as we cycle through the audience, you can come back 2 for as many questions and comments that you care to 3 make.

l 4 So I hope most of you view this as an l

5 effective way to approach the meeting. We'll see. As 6 I said, we've changed the meeting in the past. It's l

7 possible we'll change it again. This is a trial. And i

8 we'll see how it works. Buc we thank you for your 9 cooperation.

10 CHAIRPERSON LANNING: Okay. We want to .

1 g- 11 get right into our agenda. We've had several meetings 9

r 12 this week. And so what I'd like to do is just give you 13 a capsule version of what occurred in some of those i

14 meetings.

15 We had a meeting chaired by Mr. Imbro l 16 concerning the Independent Corrective Action 17 Verification Process for the contractors. And we'll

{ 18 hear more about that tonight. So I won't talk to that.

19 In addition, there was a meeting with 20 Little Harbor, talking about the Safety Conscious Work j

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$ 21 Environment. And we'll hear more about that tonight i

, 22 from Mr. McKee.

l 23 This morning, we had our periodic 24 meeting with Northeast Utilities concerning the restart O

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10 MEETING RE: MILLSTONE UNITS O a^aca 4 1998 1 activities. So what I'd like to do is just sort of 2 summarize some of the high points that were pointed out 3 during that meeting this morning.

4 In addition to talking to the Safety 5 Conscious Work Environment, we talked to Unit 3 status.

l 6 And that' what I'm going to dwell upon for the next 7 five minutes here.

8 We talked about the restart readiness.

9 We talked about the independent oversight assessment of 10 the readiness for restart. We saw for the first time 9 11 an integrated schedule of activities. We talked about 8

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12 the deferred items list. These are the items that will O 13 be deferred until after restart.

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14 We also talked about how that backlog of l 15 those deferred items will be managed after restart. l 16 And they provided some response to some of the findings 17 that were identified during our Corrective Action l 18 Inspection, which Mr. Durr will talk about a little 19 later in the agen6a.

f 20 Mode 4 Readiness. Mode 4 is really the l0 21 time at which they're beginning to pressure and heat up i

e 22 the reactor coolant system. They're projecting that E

l 23 that's going to occur -- start occurring this weekend.

24 That means they'll start a reactor coolant pump and POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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11 i MEETING RE: MILLSTONE UNITS l MARCH 4, 1998 l

'l start pressuring the system. j l

2 In order to do that, they will have to 3 have completed all physical work that pertained to l 4 those syrtems required for Mode 4. And they think --

5 they believe they've got a plan to have that physical j 6 work completed this week. So that's a milestone, i

7 A VOICE: Sub-critical?

8 DR. TRAVERS: Pardon?

9 A VOICE: Sub-critical?

10 DR. TRAVERS: That's sub-critical, not - l

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R 11 - the reactor is not critical. This is just heating up 1 0 I 12 the permanent coolant system. ]

13 All modifications, as I indicated, will l

i l 14 be complete this week. Overall, there's been some -- a l

l 15 little over 200 modifications required to be. completed 16 during this outage. And so they've completed all the 17 physical work, although there's still some ,

i l 18 documentation, maybe some emerging issues. But that 19 work is complete.

!f 20 They continue to make progress in

$ 21 reducing the work orders, the corrective actions that

'!. 22 must be completed prior to going into Mode 4. So that 5 1 l 23 backlog is still reducing. They still have something  !

{ 24 like 600 items to be completed prirr to Mode 4.

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12 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 Is that right? 600 or 400? 400? 417 2 is the number, yes, before Mode 4. l l

3 There are things called NRC commitments.

4 These are items that they've told the NRC that they 5 will fix or will implement or something. And they were 6 like initially a little over 700 of those and there's 7 currently 79 remaining to be done. And 25 of those 79 I

8 need to be completed prior to them going to Mode 4. I 9 And Mode 4, I should mention if you'd 10 like to understand better, reactor coolant conditions l l

R 11 is when the temperature is -- exceeds 200 degrees.

12 That's what we call Mode 4.

13 As many of you know, we have in our 14 restart assessment plan a list of things called 15 Significant Items List. These are the minimum sub-set 16 that the NRC staff believe was necessary to be 17 completed prior to restart.

l 18 There were some 216 packages or issues 19 to be addressed in that list of a little over 100  !

l 20 items. We have completed 182 out of the 216.

l[ 21 Northeast Utilities still owe us about five packages.

1

. 22 So considerable progress has been made in closing out a E

23 significant number of those items.

l 1 24 We've talked in the past in our meetings Os POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

13 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 about the Demand for Information letter, the 50.54f 2 letter we've talked about. We've talked about the 3 punch list and the deferred items list.

4 The restart list, which is part of that, i

5 are the things that were going to be completed prior to l 6 restart. And they have a little over 250 of those 7 items remaining to be done prior to Mode 4.

! 8 They have made -- they continue to do l

9 self-assessments both by Oversight and various 10 organizations. For example, in Operations we saw that 11 progress has been made in Operations itself and also in l

12 Licensing.

l 0 13 If you recall, there were some windows 14 that we've used and talked about in the past, yellow l 15 and green type windows. And so we -- if it's green, 16 it's viewed to be satisfactory and ready for restart.

17 And so, for example, the yellow items still remaining ll 18 for the organizational readiness include engineering, t

ii jl 19 work control, maintenance planning and training.

I 20 There's also some management issues in there. So

$ 21 they've changed two of those windows from yellow to 1

. 22 green during this past month and, since the last time E

l 23 we met, discussed some of these things.

24 We went through a number of key IO POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

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14 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 indicators. These are the things that's been tracking 2 over a period of time that shows the backlog and work 3 to be done, et cetera, before restart.

4 Generally speaking, all of those 5 performance indicators are trending in a positive 6 manner, indicating that progress is being made. l l

7 That's sort of a capsule of a three-hour 8 meeting we had this morning. Are there questions on l

9 anything that I said? i 10 Okay. So we'll just move right into the l$ 11 first agenda item. Mr. Imbro will talk to the status l0 12 l of the Independent Corrective Action Verification 13 Process.

14 MR. GENE IMBRO: Good evening. My name l 15 is Gene Imbro. I'm the Deputy Director of ICAVP 16 Oversight. What I wanted to try and do tonight is go 17 over a couple of areas. I wanted to, first of all, try ll 18 and give you some status of the ICAVP's on Units 2 and 19 3. And I wanted to turn the presentation over to Jim 20 Leuhman. Jim Leuhman was the Team Leader for the Tier e

. 21 1 In-Scope Inspection from Sargent & Lundy. He looked 1

- 22 at the slickers and the RSS. Then I'll take -- resume.

E l 23 I'd like to discuss briefly Level 4 DR's and the 24 process for handling Level 4 DR's.

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15 MEETING RE: MILLSTONE UNITS MARCH 4, 1998

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1 So let me first start Dy giving you a 2 little background on the Unit 2 or the statns on Unit 3 2. Unit 2, as you know, is lagging, lagging Unit 3, 4 and we are beginning our inspections. We have to date 5 approved Parsons as the independent contractor to do 6 the ICAVP review. That was quite a while ago.

7 We've also --

NRC has also approved 8 their audit plan and has done an implementation 9 inspection to verify, to assess how well they're 10 implementing the audit plan. And that also was done 11 last year. And I think the conclusion from that 12 inspection was that we felt that Parsons was doing, you 13 know, a thorough job in implementing the audit plan and 14 was doing it as we had expected based on what we had 15 seen at that point. l l

16 Right now as a part of our inspection 17 program, starting this week another team is on site to 18 look at Unit 2. And they're doing an out-of-scope I.

l 19 inspection. Out-of-scope means they're going to look 20 at -- we are looking at a system that has not been,

o 21

, will not be reviewed by Parsons. But the system has

'l 22 been, of course, reviewed by NU and has gone through l.

ll l l 23 the NU Configuration Management Program. And so we are l 24 going to -- by this inspection, we'll be able to assess POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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16 l MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 the thoroughness with which NU has done their reviews.

! 2 And by that I mean if we find things that they missed, 3 then that's an indication of the thoroughness or lack 4 thereof of the review they conducted.

5 So the system that's under review now is 6 the reactor building closed cooling water system. And 7 we're looking at a very similar inspection, if not 8 identical, to what was done on Unit 3. But before we 9 do on-site inspection plus in-office review, a total 10 inspection time probably of in the neighborhood of four g 11 to five weeks.

U 12 Given that, inspection is ongoing. I 13 can't really tell you, you know -- it just started this 14 week. It's really premature to say anything. It's 15 really just getting started, getting geared up. But 16 can tell you that the inspection is similar to what we 17 call a safety system functional inspection.

l 18 And for those of you who don't know that I

. 19 terminology, that's basically a very in-depth review of  ;

f 20 the system design and a verification on the sample that o

, 21 we look at of the system documents, that the plant or l 22 and

the system is in conformance with its design 5

l 23 licensing basis.

24 So as a part of that, we look not only O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

17 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 at design, but also some operating procedures, some 2 emergency procedures and do pretty much of an i 3 integrated look at the total system and some of the 4 interfaces with it.

5 That's what we're doing. Let me now 6 turn to -- give you a little bit of a status of what

, 7 Parsons has been up to. They, of course, are in the 8 process of doing their ICAVP review. And just to give 9 you an idea of where they stand to date in terms of 10 Discrepancy Reports, they have to date issued 305

$ 11 preliminary Discrepancy Reports.

s 12 Now, those -- and again I have to stress 13 that's preliminary, which means that NU has not 14 completed their assessment of them. And so there's 15 going to be interaction that takes place.

16 But, in any case, as preliminary DR's, 17 there are five Level l's. And again let me explain l 18 what -- when I talk about Level 1, 2, 3, 4. Level l's 19 are the --

what we would classify as the most 20 significant. And that would be an instance where a o

. 21 system, recognizing that systems have two redundant

!= 22 trains, that both trains of the system, the entire i

5 l 23 system would not be able to perform its safety 24 function. A Level -- and they have -- so essentially i l POST REPORTING SERVICE {

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18 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 five Level l's preliminary.

2 One preliminary Level 2. And then Level 3 2 would be an instance where only one of the two 4 redundant trains would not be able to perform its 5 safety functions. And it says one of those, 6 preliminary.

7 141 preliminary Level 3's. Level 3's 8 are instances where the plant is not in conformance 9 with its design and licensing basis but the system can 10 still perform the safety function. I'm referring to,

$ 11 say, there's enough margin between what the system is 9

12 supposed.to do in its design / licensing basis, so that f 13 even though it does not meet its design / licensing 14 basis, the system can still perform as expected.

15 And Level 4's, the lowest, lowest of the 16 tiers and least significant, are issues where it's not 17 an issue of compliance with design and licensing bases, 18 but it's really below that threshold. And -- but, 8 19 nonetheless, they are errors. And I'm going to talk (f

l 0 20 about some of those later. And we've been categorizing them as examples

, 21 of those kinds of things, 1

= 22 typographical errors, inconsistencies between E

l 23 documents, et cetera. But, yet, even with the fact 24 that it is an error, the plant is still not outside its O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

19 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 licensing basis. And so, again -- so there's 148 Level 2 4's -- 158 Level 4's.

3 MS. ROSEMARY BASSILAKIS: 158?

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l 4 MR. IMBRO: Yes. So it's five l's, one 5 2, 141 3's and 158 4's. And those are the preliminary i 6 as of yesterday.

l 7 There are -- of the --

of those -- I 8 didn't -- oh. Of the 301, 30 have been closed and 20 9 are pending. But let me --

let me --

it's a 10 complicated process. Let me just take a minute here.

l 11 Closed means that NU agrees with Parsons l

12 that it is a problem and they also agree with the 13 corrective action. DR's that are pending means that 14 there's agreement between NU and Parsons as to the 15 significance level, 1, 2, 3, 4, but the corrective 16 action is still under review by Parsons. So, yes, it's 17 a real problem. Both parties agree that it's a

'l 18 problem. They agree to the level. But there's still 19 some review to be done on corrective action. So it's 20 not -- it's not in the closed category. So it's O

, 21 pending. There are 30 closed, 20 pending. A lot of l

= 22 numbers and maybe it's confusing. But I'll try -- if l E

l 23 you want, I can repeat these or you can catch me later 24 and I'll go through them again.

t'}

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MEETING RE: MILLSTONE UNITS f( ) MARCH 4, 1998 l

1 Of the 30 that we said were closed, 12 -

l 2 - 12 are confirmed, which means that they are really --

3 they are a problem. Both -- acknowledgement on both 4 sides that they're a problem. 11 of the 30 were 5 previously identified by Northeast Utilities and that i

6 was during their --

during the Northeast review.

7 They'll be fixed, but they don't really count in a l

j 8 sense against the CMP program, if you will. And seven i

9 of the 30 were deemed to be non-discrepant, which means l 10 that Parsons does a review based on the information

g 11 they have. They think -- they think there's a problem.

9 12 NU will -- could send them back more information. Then

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13 basically, if they agree that it's not really a problem I

14 after all on looking at the new information.

15 And so the bottom line here is there's 16 really -- of the whole 305 so far, 12 confirmed, 20 17 open, pending -- or pending, and of those, of that l 18 population, one is a Level 3 and 31 are Level 4's. So 19 -- and, again, Level 4's are the least significant and i

l 20 really issues that are not design / licensing basis O '

, 21 issues.

- 22 Okay. Move to Unit 3. Unit 3, we E

l 23 completed the Tier 1 in-scope inspections. We're going l 24 to talk about that in a minute. We had a public exit l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

21 MEETING RE: MILLSTONE UNITS MARCH 4, 1998

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1 meeting last meeting at the Training Center in the 2 foyer, j 3 We also have an inspection that's in I 4 process now on Unit 3. And that's what we call a 5 Corrective Action Inspection. And a team is on site 6 now. This is the second of -- second of four weeks.

7 What they're looking at is they're 8 looking at many facets here. But the most important j 9 thing is they're looking at issues that were identified 10 by NU as a part of their Configuration Management Plan g 11 and looking at the action the licensee has taken to i c'

12 correct these self-identified problems.

(

13 They're also looking at or will look at 14 -- they haven't done it yet. But they will look at the 15 corrective action in response -- that was performed in 16 response to the Sargent & Lundy Discrepancy Reports.

1 17 They will be looking at issues that we raised during 18 our inspection, Jim's and others', to look at the l

19 corrective actions with regard to those. So it's quite 20 a broad-scope inspection.

O l , 21 But just to go back to the statistics l

!- 22 for a minute, again, we met with Sargent & Lundy, as I 5

l 23 said, and the same time with Parsons yesterday. And 24 let me go through a quick summary of where Sargent &

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l 22 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 l

i 1 Lundy stands. And they're, you know, pretty much

, 2 winding down. Their review is essentially complete 3 except for some late mods that NU is performing on RSS 4 reactor -- excuse me -- recirculation spray system, i

5 Statistics now on Unit 3 are, so far, l

6 946 preliminary DR's issued. 419 were accepted and 7 closed. Again, based on the definition as I had 8 before, you understand what closed -- what we mean by 9 closed. Of the 419 closed, 255 were confirmed 10 discrepancies. So these were issues that were not g 11 identified by NU and both agree that these are issues d

12 that are problems. There were 59 that were previously 13 identified by the licensee and 105 of the 419 basically 14 non-discrepant, which means that they thought there 15 were problems but turned out that they weren't.

16 MS. BASSILAKIS: How many non-17 discrepant? I'm sorry.

l 18 MR. IMBRO: 105. j 19 Okay. And now, of the 255 confirmed, f 20 seven, seven Level 3's, 248 Level 4's. And, again,

?

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, 21 there's five that are pending in this population. And l 22 there are four, four Level 3's and one Level 4. So, g

5 l 23 essentially, there's 260 confirmed and pending, 11 24 Level 3's, 249 Level 4's, if you add up those two POST REFORTING SERVICE HAMDEN, CT (800) 262-4102

23 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 groups of numbers.

2 So that's where --

that's where the 3 Sargent & Lundy is sitting right there. They've been - l 4 - they're winding down their review. They project a 5 final report to be issued the end of this month on the 6 ICAVP. It may be a little bit late. I think, you 7 know, there's still -- there's still some issues that 8 they're working through with the licensee. So it may 9 be delayed somewhat. But, in any case, their target is 10 for the end of the month.

g 11 So, with that, with that little status, 12 let me turn it over to Jim Leuhman to discuss briefly 13 the Tier 1 in-scope inspection that he performed.

l 14 MR. JIM LEUHMAN: Okay. As Gene said, i 15 we performed the in-scope inspection as opposed to the 16 out-of-scope inspection. Now, the in-scope inspection I

17 is where we looked at a system -- actually, we looked )

l l 18 at more than one system that Sargent & Lundy had i

.I 19 reviewed previously. I spoke at one of these meetings 20 about the out-of-scope inspection, which Gene, I think, e I

. 21 explained is going on in Unit 2. But I -- my team

!- 22 performed one, an out-of-scope on Unit 3.

E l 23 The out-of-scope is where we look at a t

24 system in the plant that the licensee has completed  !

l O' POST P.EPORTING SERVICE HAMDEN, CT (800) 262-4102

, i

24 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 their CMP on but was not a part of the ICAVP contractors review.

~

2 l 3 This inspection, the in-scope, is. So 4 on this system not only was CMP performed -- or on l 5 these systems not only was CMP performed by the 6 licensee, but the contractor also looked at the systems l

7 that we looked at.

8 Now, the systems that we looked at in l 9 this in-scope inspection were the recirculation spray l

L 10 system, the quench spray system. We also looked at a l

11 portion of the plant ventilation, which was a 12 combination -- some portions of the plant ventilation CE) 13 that operate during emergencies. It was the auxiliary l

14 -- the auxiliary building ventilation for the charging l

15 pump cubicles and other highly contaminated areas in 16 that -- in the auxiliary building, as well as the 17 system which is the supplementary leak collection and i 18 release system which takes potentially highly j . 19 contaminated air in the engineered safeguard building 20 and the reactor containment enclosure building and o

. 21 filters that before it's released.

l

- 22 Real briefly, to talk about what -- I l

1

.5 l- 23 talked about what those systems do. The quench spray 24 system is a system that takes water from the refueling i

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

t I.

I

l 1 l

l l

25 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 water storage tank, which is a large reservoir of i 2 cooled water. The question spray system then sprays 3 that, that water into the containment if there's an 4 accident.

5 Then the recirculation spray system is a 6 multi -- is really a multi-purpose system as far as in 7 an accident. What it does is it starts when an '

8 accident signal is received. But initially it doesn't l 9 operate. What it -- where it takes its -- where it i

10 gets its water supply is it gets its water supply from i$ 11 the containment sump. And the way the water gets into 9

r~s 12 the containment sump is the water is put there by the d 13 quench spray system, spraying the containment to reduce 14 pressure. And also from the systems that inject 15 directly into the reactor. Obviously, that -- in a 16 loss of coolant accident, that water is going to then 17 run out of the reactor and accumulate in the l 18 containment sump. And the recirculation spray system 19 is then going to take that water from the sump, inject 20 it into the reactor and, also, it will perform a spray 0

, 21 function because at some point the water's going to run 1

- 22 out in the refueling water storage tank. The quench E

l 23 spray system is going to stop. And the recirc, 24 recirculation spray system, will then be spraying the O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

26 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 containment and it also will be taking out water and 2 injecting it back into the reactor. So it's really the 3 long-term accident cooling system.

4 We also, like I said, in addition to 5 those, we looked at the ventilation systems that I )

6 described and we also looked at the emergency diesel I 7 generator sequencer. The sequencer is nothing more 8 than an electronic device that sequences loads, 9 electric loads, onto the diesel generator if an --

10 after an accident if the diesel generator was called on g 11 to have to supply power, you can't put all ths -- you 12 can't put all the electrical loads necessary on at 13 once. They have to be sequenced on so that the diesel 14 won't get overloaded. And that's the function of the 15 sequencer.

16 We chose to do more than just one 17 system, one in-scope system. Well, really because the

{ 18 quench spray and recirc spray system really go 19 together, we chose those. But we chose these other l 20 systems because in our out-of-scope system we looked at

$ 21 some portions of these systems, the quench spray and 1 22 recirc our spray system, already just as a part of 5

[ 23 interfaces with our out-of-scope system.

24 So, having done that, having done that POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

I 27 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 l 1 review already of the refueling water storage tank, of 2 some of the recirculation spray system which interfaces 3 with the charging system, which is the system we looked l 1

4 at, we expanded our scope a little bit because some of 5 our inspectors in the various disciplines would have 6 had some extra time because, obviously, they -- part of 7 their time would have been devoted to re-inspecting 8 some of the things that we had already looked at.

l 9 So we chose to look at a little bit of l

10 the reactor plant under the ventilation and the l

$ 11 sequencer as well. All of these things were part of lU 12 the in-scope system that Sargent & Lundy had.

j 13 That was really the -- that's the first 14 three weeks of our inspection. The fourth week of our l 15 inspection we spent at Sargent & Lundy's offices in 16 Chicago and we reviewed what they did on these systems.

17 The results of our three weeks on site l 18 are documented. I mean the initial -- our initial

i. 19 findings are documented in what we call a quick-look

! 20 letter. It was a letter that was sent to the utility o

. 21 February 18. And it sort cf -- it gives a preliminary l l

= 22 summary of our findings.

5 l 23 Obviously, the letter says -- and it's 24 still true tonight -- that even though I'm going to POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l l

l l 28 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 summarize the findings, the findings may change between 2 now and the time the final Inspection Report is issued.

l 3 We still have ongoing dialogue with the utility on some

! 4 of these things and, also, consultation with our l

l 5 Headquarters staff on various technical issues. So my l 6 -- the final report may differ somewhat from the quick-7 look letter.

8 But, in summary, we found what we j 9 consider to be five, five issues. I think individually 10 -- at least it's my judgment as the Team Leader, that l $2 11 none of these were individually significant. Some of 12 them may be violations and we're evaluating that. But l 13 I'll summarize those issues really quickly.

14 The first was in the auxiliary building I 15 ventilation. We found a condition where there was l 16 circuitry for the auxiliary building ventilation fans )

17 where there was the potential for loss of power when l 18 the fans attempt to restart because of the way the 19 circuitry design was designed; that under certain l

f 20 limited conditions, the circuitry from one fan may o

, 21 inhibit the other fan from starting and vice versa and l

1 l = 22 you could end up in a condition where neither fan E

l 23 restarts. That's a condition that the likelihood of it 24 is fairly small, but, nevertheless, it did exist.

POST REPORTING SERVICE i

HAMDEN, CT (800) 262-4102

29 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 In the instrumentation and control area, 2 we -- the licensee had performed a modification to the 3 recirculation spray system which changed the operating 4 condition of some recirculation valves for the 5 recirculation spray pumps.

6 In their design of the modification of 7 the circuitry there was the potential for the valves to 1 8 cycle. And what I mean by that is that the valves 9 would be actuated to go from their starting position, 10 which was closed, to an open position under certain g 11 conditions.

2 12 What we discovered is that on the 13 failure, the potential failure of an input signal, the 14 way the circuitry was designed there was the potential 15 for these valves to cycle from open to closed and then 16 from closed to open or -- excuse me -- from closed to 17 open and then from open back to closed and continue to 18 cycle that until-the operator intervened.

l 19 And that's obviously not a desirable 20 condition because of -- if this valve, this particular

$ 21 valve, is open, then some of the flow that's supposed 1

- 22 to go from the pump into the reactor would be being 5

l 23 recirculated. In other words, it wouldn't be being 24 injected. And, alse, there's the potential that O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

30 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 eventually the overloads on the motor of the valve 2 would kick in because the thermal overloads. The motor 3 would overheat.

4 We addressed that condition with the 5 licensee and they made some additional modifications to 6 that circuit.

7 We also found a condition where some --

8 on the ventilation --

on the ventilation charcoal 9 systems. The charcoal -- they actually use charcoal 10 filters to filter the ventilation and remove any g 11 radiciodine. And we found a condition where there was d

12 some leaky valves in the fire suppression system for 13 the charcoal.

14 And the potential existed that, 15 obviously, if that water leaks onto the charcoal, that 16 it will reduce the efficiency of the charcoal, its 17 efficiency for removing radiciodine. That's one other l 18 condition that we found.

19 There were two procedural problems that 20 we found. One had to do with the way the licensee f 21 controlled --

controlled two fans, controlled I

. 22 maintenance or operation of some fans. Basically, I

l 23 there was -- there would be a limited time where both 24 fans, when being performing maintenance on one fan, O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

31 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 because of the interrelated circuitry between the two 2 fans, for a short period of time that both fans would 3 be inoperable and the licensee -- and it was at least -

4 - it's our view that the licensee wasn't taking the 5 proper precautions to ensure for that couple of minutes 6 that the fans were both inoperable, that they were 7 controlling that adequately to ensure that it got 8 restored properly.

9 And then the final finding we had was 10 that there was a line-up in the recirculation spray 1

R 11 system when filling the CO head tank for the CO water  ;

6 '

12 for the recirculation spray pumps where a -- where they 13 would make a line-up such that there would be direct 14 communication between the containment and outside the i 15 containment.

16 And, again, a condition like that is 17 allowed. However, you have to take proper controls l 18 when you open the -- when you breach the containment 19 boundary. And it was -- it was our view that the 20 procedure as written didn't do that.

O

, 21 Again, I would stress that these are our

!- 22 preliminary findings from the on-site. We have a 5

l 23 couple of other findings that we're discussing or 24 potential findings that we're discussing with our O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

32 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 technical staffs in Washington. So if you have read 2 our February 18 quick-look letter, the final report may 3 be slightly different than the -- these findings that 4 are summarized here.

5 The second part of our inspection was 6 when we went to Sargent & Lundy to review the 7 activities that they had done on the same systems that 8 we had looked at.

9 I guess to summarize that, in general we 10 found that Sargent & Lundy had done an adequate job in g 11 implementing their audit plan. They had a number of g-) 12 findings that were -- while not exactly what we found, l v

13 they were looking in the -- we felt that they were 14 looking in the right areas at the right things. I 1

l 15 mean, obviously -- I mean I think the one thing you 16 have to understand is in these plants, which are pretty i 17 complex, that, you know, two engineers, two electrical l l 18 engineers, two I&C engineers looking at the same piece l l

. 19 of equipment are going to look at it differently and

(

f 20 they may not find exactly the same thing.

O

, 21 Having said that, we found, though, that i 22 there was good correlation between the types of things l 23 that Sargent & Lundy was finding on these systems and 24 the types of things we found.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i

l MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 For instance, on the fire protection, 2 the leaky valves in the fire protection, while Sargent 3 & Lundy didn't identify that, they did find another 4 potential problem with that same piping and the seismic 5 qualification of that piping. Again, that indicates to 6 us that, you know, they were doing their reviews in a 7 manner very similar to ours and finding the types of 8 things at the depth we would expect them to find.

9 Obviously they had a lot more findings 10 than we did because they had a lot more, upwards to 100 g 11 people working on this for like eight months. So, 9

p 12 obviously, their look was a lot more comprehensive than l CJ I

13 ours was.

14 We did find a few what we considered 15 isolated problems with Sargent & Lundy's review. In 16 the structural and piping area, we found that they 17 failed to review the -- some calculations or all -- all v

l l 18 the qualification calculations for one fan in the 19 systems we looked at. That appears to be -- that 20 appeared to be an isolated oversight on their part.

Lo. 21 And they got those calculations and did the reviews.

l i

l' n 22 Based ont that, we did look at other l 5 l 23 disciplines to make sure that -- and we went and looked 24 at the rest of the structural to make sure that they POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102

1

)

i l

l l

34 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 I

1 had good tracking systems for making sure that they did j 2 all the reviews that they were supposed to do. And we 3 were satisfied that this was an isolated problem.

4 They also --

in the same structural 1

5 area, they had a problem with one of their implementing )

6 procedures. Many of the components in the plant, big 7 tanks and things like that that are in safety-related 8 applications, have to be seismically qualified, in i

! 9 other words, against earthquake. They're then !

10 supported by metal beams or such. And then those are {

l 1 i

g 11 anchored to the floor, to the walls using embedment 9 >

12 plates.

13 We found a problem in Sargent & Lundy's l

14 procedure where they had a group looking at the seismic 15 qualifications of the tank, a group looking at the 16 seismic qualification or the qualifications of the l 17 embedment plates, but not in all cases -- it appeared l 18 that, you know, one group was expecting the other group 19 to look at the intervening steel between those two.

f 20 And in some cases, neither group looked at some of C

, 21 those calculations.

I= 22 Again, we felt this was isolated. They E

l 23 went back and corrected that.

24 The other area where Sargent & Lundy --

l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

I

35 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 that we did ask Sargent & Lundy to do some additional 2 work was based on our finding in that fan circuit that 3 there was the potential for the two fans to prevent 4 each other from restarting on a loss of power.

5 We asked Sargent & Lundy to go back and 6 find -- and look at similar -- other similar electrical 7 circuits to ensure themselves that they had done a 8 thorough job of looking for potential single failures 9 in the circuits. And they committed to do that.

10 The other thing that Sargent & Lundy --

1 g 11 and I think Gene alluded to it -- still had to do was

! S!

l 12 there were a number of modifications to the 13 recirculation spray system that were approved and 14 implemented in just the last few months. And under the 15 protocol, Sargent & Lundy had not received those 16 modifications for review. We informed them that there 17 were additional modifications that they needed to look l 18 at. And they requested those documents and are now 19 performing those modification reviews.

f 20 Again, overall we felt that Sargent &

O

, 21 Lundy is implementing -- they implemented, with the few

= 22 exceptions that we found, their audit --

or has 5

l 23 implemented their audit plan based on our inspection.

24 And we feel that the systems that we looked at that we G

kJ POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

36 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 found -- at the plant that we found just a few 2 discrepancies and that the types of discrepancies that 3 we found correlated well with the type of discrepancies 4 that Sargent & Lundy is finding in these same systems.

5 And unless anybody has any questions, )

l 6 that's it. j

{

7 MR. IMBRO: I just wanted to -- '

8 MR. LEUHMAN: Wait. There's a question 9 in the back.

10 MR. IMBRO: Well, hold on a second. As R 11 Mr. Travers explained, we're going to go through all of 12 our ICAVP talk and then we'd be happy to answer 13 whatever questions you might have.

14 So I just wanted to add two things to l

15 what you said before. I'd just like to talk quickly l

{

16 about Level 4 DR's. I think that in the areas where we 17 had identified some weakness in the Sargent & Lundy

-l 18 review, I think they were very prompt in accepting this 19 -- our findings and, as Jim said, went back and did the 20 additional work. And I guess -- it's my understanding

$ 21 now that most of that work is completed and no new I. 22 issues were identified and no new discrepancies were 5

[ 23 identified.

24 Also, I would say that, as Jim POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

37 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 mentioned, we found some things that Sargent & Lundy 2 didn't find. And I think when you look at the 3 magnitude of the review, I think, you know, you also 4 have to 2cok at what is the significance of the things 5 we found. And I think as Jim appropriately 6 characterized them, I think they were areas that were 7 minor in significance. And so I don't really think that 8 these things, you know, impugn the credibility of the 9 Sargent & Lundy review. I think that other engineers 10 would -- could go out there and then they'd find even g 11 yet additional things.

2 gs 12 But I think you have to look at the T

13 significance of the things that are found. And I think 14 that I have a high degree of confidence that if another 15 review were conducted, for example, that problems may 16 be found but also at a very low level of significance.

17 I don't think Sargent & Lundy missed any major issues.

l 18 With that said, let me -- let me go to a 19 little bit of discussion on Level 4 Discrepancy 20 Reports. I know that I told Dr. Travers that I'd try 0

, 21 and keep this to a half-hour, but I'm probably going to

!- 22 shoot the schedule here a little bit. I'll try and be 5

l 23 brief.  ;

24 But the reason -- let me just -- again, O~- POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

1

38 MEETING RE: MILLSTONE UNITS MARCH 4, 1998

\

1 to repeat, Level 4's are the lowest in the hierarchy of )

1 2 significance level of Discrepancy Reports. And, again, I 3 these Level 4 Discrepancy Reports are issues that do 4 not represent a non-conformance with the licensing )

5 basis. In other words, the plant, even though these l

6 are areas which will be fixed, they're not errors-that

( 7 put the plant not in non-conformance with its licensing l 8 basis.

i 9 Why we are looking at these things is '

10 because we had tried to make the process as thorough as J

\

jg 11 we could. And we're trying to capture Level 4's not in j !! t 12 a -- more for -- to look at trends. And so if there  !

O 1

13 are minor -errors, even many minor errors, that would 14 indicate a trend in a particular area, that may suggest 15 that something that was not looked at could have 16 potential safety significance.

L 17 So we're looking even at the area that's jg 18 below the level of licensing / design basis to see if 19 there are any trends that would indicate that there may 20' be some problem that hadn't been looked at that would l[ 21 be a non-conform -- an issue where the plant was in i 22 non-conformance with the design / licensing basis. So

!E l 23 it's a thoroughness of the review.

24 We have been characterizing Level 4 DR's

, POST REPORTING SERVICE I HAMDEN, CT (800) 262-4102 l

39 MEETING RE: MILLSTONE UNITS

( }' MARCH 4, 1998 1 -- and just to add another piece of this, Level 4 DR's, 2 since they are issues that are below -- do not put the 3 plant in non-conformance with the design and licensing 4 bases, are typically issues or issues that would 5 typically be deferred, which means that they would be 6 or could be corrected after the plant starts up.

7 So I'd just -- again, I just want to 8 make clear exactly how we're handling Level 4 DR's 9 because there are -- they are -- they do represent 10 errors and they do represent, for the most part, things g 11 that are going to be deferred until after restart. And 12 we've been characterizing these -- I mean as examples 13 we keep saying, well, they're editorial errors or minor 14 calculational errors which really don't impact the 15 results of the calculation. But in reality, as you 16 look through the Level 4 DR's, they're eally other 17 areas that sort of reveal themselves as other examples l 18 of what Level 4's would be.

19 So I wanted just to give you an idea 20 that -- just quickly go through some of the other areas l$ 21 just to let you know that there are more than editorial

'I. 22 or minor calculational errors that comprise the l

i5 ll 23 population of Level 4 DR's.

24 For example -- and I'll touch on four O- POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102

40 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 areas here quickly. Inconsistency between facility 2 drawings. And one thing that we've seen several 3 instances of are in the electrical area, logic diagrams 4 and schematics don't match. Talk about it a little bit 5 later.

6 But the logic diagrams, for those who 7 are interested, are more high-level diagrams that have 8 -- try and lay out how a system works with a series of 9 logic and correlates that if this happens, then this 10 happens, you know, simultaneously, then something else g 11 happens, et cetera. So it's a sort of high-level a I 12 representation of how the system works. The schematics 13 are actually more detailed electrical diagrams with 14 relays and other things that really lay out in detail 1

1 15 how it works.

16 There are also -- so that's one. So one l 17 area was inconsistency between facility drawings.

l 18 Another area would be inconsistency between facility 19 drawings and this configuration. And there's some 20 categories of those, too, even within that, within that l$ 21 set.  !

'1- 22 For example, there's been several areas, l- 23 instances where cable tray ground conductors that were 24 shown on drawings were not installed. There's a 1

POST REPORTING SERVICE RAMDEN, CT (800) 262-4102

41 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 variance between the configuration of cable trays that 2 are actually in the plant and what's on the drawings.

3 There are some discrepancies with plant labeling. The 4 label is supposed to say something and it says 5 something else or the label's not there.

, 6 In some instances, installed --

l 7 installed wiring differs from schematics. Okay. So I 8 another -- so that's -- that would represent instances 9 of inconsistency between facility and drawings. 1 l

10 Another instance or category would be l

)

g 11 things -- there are assumptions made in the FSAR with t!

12 regard to system performance which are input to the 13 accident analysis. In some cases, the documentation 14 that supports those numbers was not readily apparent to 15 Sargent & Lundy. So they wrote a DR saying "The flow 16 in the FSAR was represented as some GPM but we can't 17 find any documentation that supports that." And then l 18 they wrote that as a Level 4.

.19 Other -- another category would be minor 20 inaccuracies in the FSAR. And one example of that I f 21 can think of off the top of my head was the FSAR said 1

- 22 that a certain structure was chrome, chromized steel, E-l 23 but in reality it's stainless, 409 stainless. So 24 there's kind of minor -- minor things.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

42 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 So those are some examples of what Level 2 4's would be. But let me -- let me also try and 3 explain to you the process that NU is going to deal 4 with Level 4's and then quickly what we're going to do.

l 5 When a DR comes in, be it Level 4 or any 6 other higher significance level, a Condition Report 7 gets written by the licensee. And that's part of their i 8 system. And the Condition Report then is screened for 9 operability, reportability. They look at it whether or l

l 10 not it's a personal or plant safety _ issue or would jg 11 affect plant operation. And they do that -- that ,

12 screening is done within 24 hours after the CR is

]

j 13 written. And that's part of the procedure. i; 1

14 CR's were also -- I'm using shorthand.

15 The Condition Reports are also evaluated as to whether 16 or not they're pre- post-restart. So even though 17 Sargent & Lundy may characterize this as a Level 4, the

'l 18 plant themselves makes their own independent 19 determination as to whether or not they think that this f 20 is a pre- post-restart item. And, in fact, some of the o

.- 21 issues that have preliminarily been identified as Level i

= 22 4's the licensee has looked at and has decided that E

l 23 these things may need to be completed before restart 24 and had moved them up to the Pre-Restart List.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

43 MEETING RE: MILLSTONE UNITS l MARCH 4, 1998 '

1 MS. BASSILAKIS: Gene, are you saying 2 pre- post-restart? Is that what you're saying? I i 3 can't --

4 MR. IMBRO: They moved it --

those --

1 5 some particular issues they moved from the post-restart J 6 area to the pre-restart area.

7 MS. BASS 1LAKIS: Okay.

8 MR. IMBRO: Because even though they 9 were then defined as Level 4's, licensee in their 10 screening felt like these were things that they needed I 11 l g to correct before -- before restart. So they moved 1

,9 12 things from post- to pre .

13 MS. BASSILAKIS: Okay.

14 MR. IMBRO: Okay. Again, these issues 15 are real errors. And, you know, we would expect and we i

~

16 will be checking that this happens; is that the l 1 17 licensee, when they recognize that there is a )

l 18 difference between what's in the plant and what's on a 19 design document or an independelt documentation, that 20 they themselves would be doing some kind of a O

, 21 reconciliation and to make sure that what the h 22 configuration that exists in the plant is within the l 23 design and licensing bases. So even though these come 24 in as preliminary Level 4's, the licensee will need to O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

s 44 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1 and is doing a review to make sure that, even though 2 these appear to be minor errors, that the configuration 3 is within -- within the bounds of the analysis so that 4 it's in conformance, the plant is in conformance with 5 its licensing basis. Now, if-they find that it's not l 6 in conformance, then these things would certainly be l

l 7 moved to the pre-restart list.

l 8 Okay. And, again, what's going to i

l 9 happen here is, as I said, the Level 4 -- Level 4 DR's 10 typically would be things deferred until after restart.

I g 11 But, again, you know -- I keep saying this again. But 2

12 they are -- you know, they are real errors that need to 13 be fixed in the documentation.

14 And so what we have asked the licensee 15 to do is to enter it into -- they have a tracking 16 system that's controlled -- quality grade tracking 17 system. And I believe it's called grids.

j' 18 And so when anyone of the plant would 19 need to use this documentation that they know is in 20 error, before they get to which documentation -- with C \

, 21 this drawing, for example, that they get that's an 1

- 22 error, they will also get a package, a change package 5

l 23 that has been initiated, not completed, but initiated 24 that would tell them, "If you use this drawing, you POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

f 45 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 l

1 know, this is the problem that's wrong with it. It's 2 not a safety problem. But be aware that this is 3 something that's wrong here."

1 l 4 And what the licensee has committed to {

I 5 do for these deferred Level 4 CR's is that the first 6 time someone picks up one of these documents to use 7 that has one of these Level 4 DR's associated with it, 8 they are -- they would be obliged to correct, update 9 the document. And, also, besides that, they have also 10 committed that all Level 4 DR's -- the corrective y 11 action for all Level 4 DR's would be completed before 3 9 \

p 12 the next refueling outage.

O 13 So that kind of, I think, to me lays out 14 the process that -- these -- before these things are l 15 deferred, they do make sure that these Level 4 DR's are 16 not licensing / design bases issues. They have a system l 17 in place that will let people know what the errors are l 18 when they go to use one of these documents and they 19 also have committed to correct these documents on a 20 timely basis after restart and report to us quarterly G

, 21 to give us a status of where they are in correcting.

l = 22 And, again, we will -- we, NRC, will be looking at

!5 l 23 these and doing our own -- this will be looked at as a 24 part of our corrective action inspection.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

46 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 So as I -- what my intent here was just 2 to try and put it in perspective a little bit what 3 Level 4 DR's are. Yes, they're errors. We think 4 justifiably they could be -- they can be completed 5 after the plant restarts because they're not of a high-l 6 level safety significance or have no safety 7 significance, for that matter. But they represent 8 errors. And we will be -- we'll be monitoring the 9 licensee's progress in correcting these, correcting 10 these problems.

g 11 So, with that, I think I will turn it 9

12 over and open the floor up for questions on any of the 13 things that we've said. Someone had a question on 14 ICAVP before?

15 CHAIRPERSON LANNING: Yes. Just a 16 reminder. We'll be implementing our new process 17 tonight. So we'll spend the next 30 minutes with each j 18 speaker having about five minutes to ask their 19 question.

20 I'd also point out there's some chairs 21 up front for those of you in the back who would like to 1 22

- have a seat. There's also some extra chairs over to my l 23 right.

24 Okay. Who has the first question? If O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l 47 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 you prefer to sit, we can get a chair up here.

2 MR. IMBRO: You can sit at the table, if '

3 you like.

4 MS. NANCY BURTON: This is fine.

5 MR. IMBRO: If that's more comfortable --

, 6 MS. BURTON: This is fine for me. Thank l-7 you. Can you hear me? No?

8 MR. IMBRO: Yes. .

J 9 MS. BURTON: Okay. Can you hear me now?  !

10 MR. IMBRO: Yes. Thanks.

1 R 11 MS. BURTON: Okay. Thank you. Good 12 evening. I'm Nancy Burton. And I'd like to address a 13 question first to Mr. Leuhman.

14 Mr. Leuhman, I would like to know when  ;

l l 15 you first discovered the five issues which you 16 identified.

17 MR. LEUHMAN: Our inspection -- I can't l 18 tell you specifically when each issue was identified.

4 19 But our inspection on site went from January, January 5 f 20 through I think the 30th of January we were on site.

S

, 21 So it was during that time period, 5 January to 30 l

1 22 January encompassed the three weeks we were on the l 23 site.

24 MS. BURTON: So, in other words, during POST REPORTING SERVICE-HAMDEN, CT (800) 262-4102

48 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 the two-year period that the plants have been shut 1

2 down, you only recently discovered these five issues?

3 MR. LEUHMAN: Yes. That's correct.

I 4 MS. EURTON: Now, I thought that down in 1 5 Rockville, Maryland on February 19 it was pointed out 6 that your Issue No. 2 concerning the RSS, the 7 recirculation spray system, is an issue that was 8 identified actually back in 1986 as being a problem.  !

9 Are you aware of that?

10 MR. LEUHMAN: Well, the recirculation --  !

g 11 I mean one of the -- I think one of the reasons that 9

12 the recirculation spray system was chosen as the I 13 recirculation / slash /I should say quench spray because i 14 they really operate together, was chosen as the in- !

15 scope system that we decided to inspect. One of the 16 major criteria for choosing that system was the number 17 of ongoing or the number of problems that the licensee

'l 18 is having with that system since the plant was licensed 19 in 1986. So I think it was a recognition on the part f 20 of the NRC that we wanted to inspect this system which i 21 the licensee has modified extensively and had k 22 operational problems with since the plant was licensed.

l 23 MS. BURTON: So your amending your 24 answer. You didn't first become aware of this just O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

49 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 within the past short period of time, but, actually, 2 you've known about it for something like 12 years.

3 Correct?

4 MR. IMBRO: No.

5 MR. LEUHMAN: No. The individual 6 findings that I discussed tonight that apply to the 7 recirculation spray system we only discovered during 8 the inspection that took place during January. The 9 larger issue of the recirculation spray system, I don't 1

10 think -- I wouldn't characterize that the NRC has felt

$ 11 that the prob -- that the system was a problem since 0

12 the plant was licensed. What I guess I would 13 characterize it is looking back and -- looking back l

14 since the plant's been shut down at the number of 15 modifications that were made, the changes that have 16 been made to the system and the problems the licensee's 17 had with it, that that made it a candidate for us to l 18 choose it as the in-scope system.

' I. : 19 MS. BURTON: This is the system that 20 requires a licensing amendment. Correct?

l0.

, 21 MR. LEUHMAN: Yes. There is going to be

'i

- 22 --

there is going to be a license amendment on the 5

l 23 recirculation spray system.

24 MS. BURTON: No. That was to --

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

50 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 A VOICE: No.

2 MR. LEUHMAN: Oh , excuse me.

3 MS. BURTON: (Indiscernible) 4 MR. IMBRO: Well, I -- I don't -- as far 5 as I know -- and Phil can correct me if I'm wrong. I 6 don't think there's an issue here that's going to 7 require a license amendment to correct. I mean I think 8 that it's fair to say that -- and I would agree with 9 you. You know that there have been historic issues 10 with the system, even going back to, you know, to 1986.

$ 11 There's some question about --

about the licensing 12 basis of the system back in 1986 and how that was ,

13 changed under the 50.59 process. And I think that the 1

14 staff is presently looking at those issues. And we '

15 have -- we are, you know -- we're looking at them now.

16 MS. BURTON: Is Mr. Jim Anderson here 17 this evening?

l 18 MR. PHIL McKEE: No. But I can answer 19 that.

20 MS BURTON: Actually, Mr. Jim Anderson, o

. 21 I think, could answer the question because he told me 1

- 22 last week that an application would be filed for a E

l 23 license amendment.

24 MR. McKEE: Right. Yes. I'm Jim POST REPORTING SERVICE HAMDEN,-CT (800) 262-4102

51 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 (

1 l 1 Anderson's supervisor. And there isn't a licensing 2 amendment that's required prior to restart. There will 3 be -- there is -- or I guess there will be a submittal l q

4 for an amendment and a request related to this issue.

5 And that's an amendment that we will have to process l t

)

6 and approve. 1 7 MS. BURTON: And that is because there's 1

l 8 been a determination by NU that you agree with that

! l 9 this involves an unreviewed safety issue. Isn't that 10 correct?

lg 11 MR. McKEE: That's the reason that -- '

,f

,q 12 MR. IMBRO: That's the question that's

(/

13 on the table.

14 MR. McKEE: And that's what they're ,

l 15 going to submit. When there's an unreviewed safety 16 question, by our process that requires that there is a 17 licensing amendment associated with an unreviewed l 18 safety question.

19 MS. BURTON: So when do you anticipate 20 that the amendment application will be filed?

O

, 21 MR. McKEE: I think it's -- it's -- just b

= 22 it's in. Yes.

l 23 MS. BURTON: Oh, it has been filed?

24 MR. McKEE: Yes. Today or just -- yes.

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

i 1

52 MEETING RE: MILLSTONE UNITS l

() MARCH 4, 1998 1 MS. BURTON: Because I had spoken with l

l 2 the Public Affairs Officer --

l l

l 3 MR. McKEE: Right. We just --

4 MS. BURTON: --

today in the Region 1 5 offices --

6 MR. McKEE: I think we just received it.

7 MS. BURTON: -- and she informed me that 8 as far as she knew, it hadn't yet been filed.

9 MR. McKEE: Oh, I think we just received  !

10 it today.

l

[g 11 MS. BURTON: Now it will have to go 2

12 through a public process, won't it, with registration 13 and the Federal Register?

14 MS. BURTON: Yes. Any license amendment

'15 requires notification and, you know, publication in the 16 Federal Register. Correct.

17 MS. BURTON: I know I'm running close to l 18 my five minutes. But I wonder if I could just ask you 19 how you could consider amending the plant to go into 20 Mode 4 without a resolution of this yet-unreviewed O

, 21 safety problem?

l

= 22 MR. McKEE: Well,Twe do have to review i 5 l

.l 23 that issue. And prior to restart, we will be reviewing 24 aspects, you know, of that amendment as far as the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 I

53 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 function of those system, yes.

2 MS. BURTON: Well, my question was how 3 would you permit the plant to go to Mode 4 without a 4 resolution of the amendment issue?

5 MR. McKEE: The amendment doesn't have 6 to be issued prior to restart. But we would have to 7 have resolution of that issue, yes, prior to restart.

8 MS. BURTON: I'm talking now, for the 9 third time I've asked you about Mode 4.

10 MR. McKEE: Oh , for Mode 4? l I

R 11 MS. BURTON: Mm-hmm. l b

12 MR. McKEE: Not with respect to the 13 amendment. The amendment won't have to be issued. We 14 will review that and look at the system functionality 15 prior to that going to Mode 4.

16 MS. BURTON: Well, I guess I'11 try to 17 come back to that. Thank you.

l 18 DR. TRAVERS: And we'll be here. Thank l 19 you.

20 MR. IMBRO: Other questions? There's a

$ 21 hand up in the back. Okay, Mark.

8 22

- MR. MARK HALLOWAY: Good evening. Mark 5

l 23 Halloway. A couple of quick ones here. I don't think 24 I'll take five minutes.

r~s POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

54 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1 Gene, what is the date at which all DR's 2 will be moved from the preliminary status to either a 3 confirmed or non-discrepant status?

4 MR. IMBRO: Well, I don't know that 5 there's -- he asked a question of what date that all 6 the DR's would be moved from the preliminary status to 7 the finalized closed status. I don't think there's a 8 particular date in mind. I think it depends on how i 9 quickly the licensee can respond to the issues and how 10 -- and then how quickly Sargent & Lundy can review R 11 them.

12 MR. HALLOWAY: Will --

f-)

U 13 MR. IMBRO: Process -- they will all be 14 -- all of the DR's will be resolved prior to restart.

15 MR. HALLOWAY: Okay.

16 MR. IMBRO: But I can't tell you it's 17 going to be next week or next month.

l 18 MR. HALLOWAY: So they'll all be either 19 confirmed or non-discrepant --

20 MR. IMBRO: Right.

$ 21 MR. HALLOWAY: -- before restart --

1 22

- MR. IMBRO: Right.

l 5 l l 23 MR. HALLOWAY: -- is approved. Okay.

24 Jim, this one's for you. The five areas POST REPORTING SERVICE i

HAMDEN, CT (800) 262-4102

' 55 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 that you found in the in-scope inspection that you 2 judged to be worthy of concern but not individually 3 significant --

4 MR. LEUHMAN: Yes.

5 MR. HALLOWAY: I'm paraphrasing a little 6 here.

l 7 MR. LEUHMAN: Okay.

8 MR. HALLOWAY: Are those collectively 9 deemed significant?

10 MR. LEUHMAN: No. I think that they

g 11 aren't, t

12 MR. HALLOWAY: They aren't?

g~)g

\_ i 13 MR. LEUHMAN. They're -- they appear to 14 be, you know -- like I said, one of them is an I&C 15 issue. One of them is an electrical issue. There are 16 two procedural issues. And then there's an issue that 17 has to do with fire protection. So I mean at least at 18 this point -- and we're still in the process of writing l l 19 the report and reviewing it. So I mean, as I said in 20 my presentation, our -- my views and the views of my 0

, 21 management may change when we get everything finally

k. 22 written and get all our technical inputs. But at this 5

l 23 point, we don't seek any linkage between any of the 24 issues.

~h (d

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 MR. HALLOWAY: And three of the five 2 issues were in the circuitry wiring areas.

3 MR. LEUHMAN: Right. That would be more i 4 of a problem. Again, I said there are two procedural 5 issues. And I guess we will look at those procedural 6 issues to see if there's anything common there that --

7 but the other ones, I think, are -- at this point we 8 feel are fairly isolated.

9 MR. HALLOWAY: Thank you.

10 Wayne, a quick one for you. I meant to g 11 ask this before. You mentioned something on Unit 3, u

12 that there were 250 items remaining to be completed 13 before Mode 4?

14 CHAIRPERSON LANNING: Tasks. It was 15 tasks. About 400 tasks to be completed before Mode 4.

16 MR. HALLOWAY: Eefore Mode 4?

17 CHAIRPERSON LANNING: Yes.

l 18 MR. HALLOWAY: Did you -- was the start-19 up for Mode 4 -- did you say was that this weekend?

20 CHAIRPERSON LANNING: I said that they l

c

, 21 were going --

they were planning on heating up,

$ 22 i - increasing the coolant system pressure this weekend.

lE l 23 MR. HALLOWAY: Okay.

24 CHAIRPERSON LANNING: But not changing POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

{

l 57 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1 modes.

2 MR. HALLOWAY: So that wouldn't be --

3 they're not going into Mode 4 this weekend. That's 4 just the beginning stages of increasing it 200 degrees.

5 CHAIRPERSON LANNING: That's correct.

6 MR. HALLOWAY: Thank you.

7 CHAIRPERSON LANNING: All right.

8 Thanks.

9 MR. IMBRO: Susan?

10 MS. SUSAN PERRY LUXTON: Hi. I'm Susan g 11 Perry Luxton, Waterford. Three questions. One is 9

12 about the recirc spray system. 1986 was when they 13 changed the system? They did a mod to the system? Is 14 that correct? And --

15 MR. IMBRO: I think so.

16 MS. PERRY LUXTON: Well, supposedly an 17 unreviewed safety question. And they can't make l 18 changes unless they go through the unreviewed safety 19 question process and get the NRC's approval. Isn't 20 that right?

O 21 MR. IMBRO: As much as -- here's what I 1 22

. -- we can tell you. There is a question right now --

5 l 23 this is two issues. Back in 1986, we were looking back 24 there and the issue was did they change the system and O/

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

58 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 f}

1 make that system not in conformance with its licensing 2 basis? So there's kind of -- so an historical USQ 3 question back to 1986. That's what I was saying, I 4

mentioned before when I -- whether or not there's a USQ 5 on the table, on the --

6 MS. PERRY LUXTON: What is USQ?

7 MR. IMBRO: Unreviewed Safety Question.

8 MS, PERRY LUXTON: Oh. Okay.

9 MR. IMBRO: Okay? I mean that --

10 essentially what that means is that if the licensee g 11 makes the determination that the change that they make 9

12 to the plant is not what is design-wise as represented 13 in the FSAR, then they need to come back to the staff 14 to get approval to do that.

15 MS. PERRY LUXTON: My understanding was 16 they ask three questions -- they have to answer three 17 questions.

l 18 MR. IMBRO: That's right.

19 MS. PERRY LUXTON: If any one of those 20 questions is yes --

f 21 MR. IMBRO: That's right.

i.

I 22 MS. PERRY LUXTON: -- then they have to 5

l 23 --

24 MR. IMBRO: Right. Does it create a new f'

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

59 MEETING RE: MILLSTONE UNITS I~h MARCH 4, 1998 V

1 accident -- and is it -- does it reduce the margin --

2 yes. And then --

3 MS. PERRY LUXTON: Let -- okay. Explain 4 the three questions. You're taking up my time, though, 5 Gene, so -- but go ahead.

6 MR. IMBRO: No. That's all right.

7 MS. PERRY LUXTON: The three questions.

8 MR. IMBRO: The three questions are --

9 MS. PERRY LUXTON: Did they ask the 10 three questions?

g 11 MR. IMBRO: Yes, d

12 MS. PERRY LUXTON: And what happened?

i.

13 MR. IMBRO: They asked the three 14 questions and they decided that --

15 A VOICE: The answer is no.

16 MR. IMBRO: They decided that it was not 17 an unreviewed safety question.

l 18 MS. PERRY LUXTON: Okay. But --

19 MR. IMBRO: This was back in 1986.

20 MS. PERRY LUXTON: Right. But we've

$ 21 decided -- you've decided now that there's possibly an

i. 22 unreviewed safety question?

l 23 MR. LEUHMAN: They've decided.

24 MS. PERRY LUXTON: They've decided now.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

1 60 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1 All right. I guess my question is why has it taken 2 this long? Where was the NRC? How could the NRC have 3 missed and NU have missed the RSS prob -- this whole 4 question with that system for the last ten years?

5 MR. IMBRO: Well, I don't --

6 MS. PERRY LUXTON: I want him to answer, 7 Gene.

8 MR. IMBRO: Well, I don't know if he's 9 the right one that's qualified to answer.

10 MR. JACQUE DURR: Can I? Let me shed a e 11 little light on the process. What Gene told you so 8

~

12 far, in 1986 they recognized that they needed to change O 13 the system. They did it under 10 CFR 50.59. They 14 determined then, whatever rightly or wrongly, they 15 determined it was not an unreviewed safety question and 16 they could do it under 50.59.

17 MS. PERRY LUXTON: Didn't you check? l l 18 MR. DURR: I wasn't there. I don't --

5 l 19 MS. PERRY LUXTON: All right. But 20 didn't the NRC check?

O 21 MR. DURR: But let me -- but let me --

8

- 22 but let me --

let me finish. I don't know what E

23 happened in I can't address that. But let me l 1986.

24 tell you what happened this go-round.

A 5J POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

I l

61 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1 The Resident Inspection staff, because 2 we knew we had problems here, brought this issue up.

3 MS. PERRY LUXTON: Okay.

4 MR. DURR: And I said, "Let's now get 5 the NRC to review this because we never have." So l 6 we've put in what we call a Task Interface Agreement.

! 7 The Senior Resident wrote this thing up, sent it 8 through the channels and it went to MRR. Management l

9 recognized this may be a big deal. It was selected 10 during ICAVP as a system to review because we knew we lg 11 had a lot of questions. So that's how it got brought i G rm 12 to the fore today. What happened in '86 I can't

's 13 address.

l 14 DR. TRAVERS: But let --

l 15 MR. CUNLIFFE: Don't you think it ne.eds 16 to be addressed by the NRC Inspection Team then in '86?

l 17 DR. TRAVERS: Let me --

l l 18 MS. PERRY LUXTON: Why isn't there a I7 19 mechanism that they make sure that these unreviewed  !

f 20 safety questions -- if the company says No to all the O ,

, 21 questions, maybe you should check then with the '

1

- 22 company.

E l 23 DR. TRAVERS: And the answer to your 24 question in the most straightforward, concise way I can I i

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 I

l l

1 i

1 i

62 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 l 1 give it is we don't check every one of those. We 2 don't. But we do sample inspect a number of those in )

3 any given year. The process the 50.59 affords 4 licensees is one that sort of underscores our principle 5 expectation on the part of licensees that they carry 6 out their activities firstly in conformance with the 7 regulations, they ask the right questions, they come up 8 with the right answers. We --

9 MS. PERRY LUXTON: Right. So --

10 DR. TRAVERS: We inspect, but we don't g 11 inspect and we don't have, frankly, the resources to d  !

g 12 inspect each and every time they use those kinds of l (J

13 thought processes and decision-making conclusions. We 14 just can't.

15 MS. PERRY LUXTON: But haven't we gotten 16 to this level before on this Millstone issue, though, 17 Dr. Travers? Hasn't this come up before? Don't look l 18 at your watch now, Dr. Travers. This is pertinent, I 19 feel, because this is -- is there a lesson learned for j 20 the NRC in this or not?

f 21 DR. TRAVERS: The lesson --

I don't 1

- 22 know.

5 l 23 MS. PERRY LUXTON: Oh.

24 DR. TRAVERS: I mean the answer -- the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l \

l i

63 MEETING RE: MILLSTONE UNITS l MARCH 4, 1998

(]}

i 1 answer to your question is what I gave you. We don't 2 look at each one.

3 MS. PERRY LUXTON: Okay. Fine. Then --

4 DR. TRAVERS: And we can't. We have to 5 rely, and we do , on licensees. And when we find --

6 when we find that they don't do a good job, we take 7 enforcement action to underscore that expectation. We 8 simply can't review the kinds of issues that we're 9 talking about this evening in every case. We --

10 MS. PERRY LUXTON: Okay. But this is a g 11 very serious system. It's an important system,

\ U 12 probably one of the top five important systems. It's a 13 little too late ten years down the line for someone .

I 14 living in the community to hear that answer from you.

15 But, anyway, second question --

16 DR. TRAVERS: It's an honest one and

17 it's the answer that --

l l 18 MS. PERRY LUXTON: But it isn't 19 acceptable because you have to rely on the licensees li[

20 again.

O l , 21 DR. TRAVERS: Well -- but what we do do 1

- 22 is we have to prioritize the kind of expenditure of 5

l 23 resources that we make. We do, in fact, focus our 24 resources on the most safety significant questions.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l 64 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1 And we prioritize what we can bring to bear on those 2 issues in that fashion.

3 What we can't do, unfortunately, is --

4 because of the thousands that -- I don't know how many 5 people work at Millstone. But we can't and we don't 6 look over the shoulder of every decision and every 7 conclusion that a nuclear power plant licensee makes.

8 We have to prioritize and we do, to focus our resources 9 on the most safety-significant issues that we can. We 10 do that.

g 11 MS. PERRY LUXTON: Okay.

12 12 DR. TRAVERS: And we have to move on, 13 I'm sorry to say. But we will be here for further 14 questions.

15 There's a question in the back.

16 CHAIRPERSON LANNING: Yes, sir?

17 MR. JOE SANTOS: Joe Santos. I'd like l 18 to ask you a question. How r.iany people are involved in 19 the control room -- in the control applications, either 20 putting --

O

, 21 MR. IMBRO: Excuse me. Joe, we're

= 22 talking about ICAVP.

5 l 23 MR. SANTOS: Oh. I can't talk about 24 that now?

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

65 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 MR. IMBRO: Please.

2 MR. SANTOS: Will I have a chance --

3 MR. IMBRO: We'd like to have your 4 question, but --

5 MR. SANTOS: Okay. Will I have a chance 6 later?

7 MR. IMBRO: Yes.

8 CHAIRPERSON LANNING: Yes. Absolutely.

9 MR. SANTOS: Okay. Thank you.

10 MR. IMBRO: Sure.

$ 11 Rosemary?

9 12 MS. BASSILAKIS: Good evening. Rosemary 13 Bassilakis with Citizens Awareness Network. I'm. going 14 to go back to Wayne, if I may. Back to the Mode 4, you 15 said there was 417 items to be completed before 16 entering Mode 4. Where does Mode 4 actually begin?

17 Once it's reached --

l 18 CHAIRPERSON LANNING: At 200 -- at 200 19 degrees.

20 MS. BASSILAKIS: So once you've reached 3

. 21 200 degrees, that's Mode 4?

I- 22 CHAIRPERSON LANNING: You've changed to 5

l 23 Mode 4 from Mode 5. Mode 5 is below 200 degrees.

24 MS. BASSILAKIS: And they'll start that O POST REPORTING SERVICE RAMDEN, CT (800) 262-4102

66 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 this weekend.

2 CHAIRPERSON LANNING: That was --

3 MS. BASSILAKIS: So when you're saying 4 that 417 items need to be completed, you mean by the 5 time they reach 200-and-some-odd degrees?

6 CHAIRPERSON LANNING: Before the exceed 7 200 degrees.

8 MS. BASSILAKIS: I see. Well, because 9 if it was this Saturday, they'd have to do about 17 per 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

l$ 11 CHAIRPERSON LANNING: Yes. No. That's 9

12 not -- if I misled you, I didn't mean to.

l 13 MS BASSILAKIS: I would like to know 14 whether or not the NRC is going to approve or !

15 disapprove --

is there any kind of approval or 16 disapproval process prior to entering Mode 4?

17 CHAIRPERSON LANNING: No. The NRC does l 18 not approve their entry into Mode 4.

19 MS. BASSILAKIS: I'm a little surprised.

20 Mr. Imbro, you said regarding Unit 2, o

. 21 preliminary results were that there were five Level k

= 22 l's?

E l 23 MR. IMBRO: That's right.

24 MS. BASSILAKIS: That is a lot of Level O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l l

67 1 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 O('N 1 l's. I'm sure you agree.

2 MR. IMERO: Yes. But, again, they're 3 preliminary, so --

i 4 MS. BASSILAKIS: I understand that.

5 MR. IMBRO: They may wind up going --

6 MS. BASSILAKIS: I understand that. But 7 at this point, they have about a 40-percent rate of 8 preliminary DR's being confirmed. So even --

9 MR. IMBRO: Well, you know, even -- we 10 can't speculate on how it's going to turn out, e 11 MS. BASSILAKIS: In regards to Unit 3, 8

12 you know, we talked a lot about the different level t

13_ DR's, the number -- the number of confirmed DR's, which 14 is about 61 percent. I haven't heard anybody talk l 15 about increasing the scope or what kind of work will be 16 cone as far as looking after the systems possibly, 17 looking for generic problems --

18 MR. IMBRO: Well, we consider -- we l

19 periodically consider whether or not they should be 20 increased based on what we found and what Sargent f &

3 21 Lundy has found and Parsons has found. But, to date, l

' l

. 22 we don't -- we don't really see any need, any need to E

l 23 increase the scope. But I mean that's something that 24 we continually evaluate. But part of it really,  ;

/~)#

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

68 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 particularly for the Level 3 issues, depends on the 2 promptness and the depth at which the licensee does 3 corrective actions.

4 So, for example, if there is a Level 3 5 issue that gets identified and the licensee really does 6 a good job in exploring the breadth of the issue, where 7 else it might apply and doing a thorough job in 8 assessing the whole implications of it, then based on -

9 - baced on what the licensee does, we may feel that 10 that corrective action is thorough and appropriate and g- 11 we would not necessarily see a need to expand the d

12 scope. So a lot of it --

13 MS. BASSILAKIS: But --

14 MR. IMBRO: --

you know, with the Level 15 3's is really dependent on how well the licensee 16 attacks the issue and explores it as fully and corrects 17 whatever problems they find.

l 18 MS. BASSILAKIS: Okay. Just like they 19 could do a real good job, the other option is they may 20 not do a thorough job and you may need to increase the  ;

$ 21 scope.

- 22 MR. IMBRO: And then we might expand the 5

l 23 scope.

24 MS. BASSILAKIS: I'd just like to hear O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

69 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1 both sides of it to --

2 MR. IMBRO: That's right. And then we 3 might -- you're right. And then we might expand the 4 scope. But, also, not only -- we're not going to, 5 again, just sit back and hear what the licensee has to 6 say- in terms of what they've done. We're going to 7 actually go out and look at the corrective actions to 8 verify the things that they've told us.

9 MS. BASSILAKIS: Well, we're counting on 10 that, just --

l@ 11 MR. IMBRO: Okay.

l 9

l. 12 MS. BASSILAKIS: Jim, you had mentioned j 13 these five items. And I think you said that they t

14 weren't necessarily significant. Did I also hear you l 15 say that there were some violations that are being 16 issued in regards to these five items?

i 17 MR. LEUHMAN: Well, I think what I said I l

l 18 --

I said we are considering some of them for 19 violations, yes. But, you know --

20 MS. BASSILAKIS: So the NRC classifies -

f 21 - will classify something a violation even though it's

'I

. 22 not a significant issue.

l 23 MR. LEUHMAN: Well, I mean significant 24 is a relative term in the NRC, you know, jumping from O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

I 1

I

70 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 the DR process where we have Levels 1 through 4, 2 Similarly, in the NRC enforcement policy, we have -- we 3 have Levels 1 through 4 in our enforcement policy. The 4 criteria for what meets a Level 1 and what meets a 5 Level 4 are different.

6 But, you know, typically a severity 7 Level 4 is a violation. There's a violation of a 8 licensing or design basis requirement. But that's a --

9 that's a severity Level 4 is, by definition, the least 10 significant of those.

lR 11 MS. BASSILAKIS: Right.

'Z~

12 MR. LEUHMAN: So I would say --

0 13 MS. BASSILAKIS: But still significant.

l 14 I'd --

15 MR. LEUHMAN: Well --

16 MS. BASSILAKIS: I guess I had a hard 17 time hearing not significant and violation in the same l 18 sentence. It was very confusing. But you know what?

19 I want to just go on because I had one more question.

20 And I know you're going to run me off the microphone.

f 21 MR. IMBRO: No, no.

1 22 MS. BASSILAKIS: I just --

I have 5

l 23 trouble with the Final Safety Analysis Report, Level 24 4's not being significant and deferring them until some O. POST REPORTING SERVICE i HAMDEN, CT (800) 262-4102 l

71 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 later date. And I just need to say that I don't think 2 a reactor can be run efficiently and effectively when 3 you have to go to a drawing, then see that it's not 4 accurate, figure out what the corrected drawing is.

5 And in a time of a crisis or something like that, you 6 don't want to be finding these little yellow stickies 7 in your report saying " Disregard, you know, cable tray 8 No. 4. It's not accurate" and things of that nature.

9 MR. IMBRO: No.

10 MS. BASSILAKIS: And the reason the NRC R 11 instituted the need for update of Final Safety Analysis 12 Report was very significant. I believe it followed the

'\

13 Millstone 3 -- Freudian slip --

Three Mile Island 1 l

14 accident. And I just -- I have a hard time with that, 15 deferring that.

16 MR. IMBRO: You should. I 17 MS. BASSILAKIS: And I think that the l l 18 Final Safety Analysis Report --

. 19 MR. IMBRO: Let me --

20 MS. BASSILAKIS: -- is very significant.

!O, 21 MR. IMBRO: Let me try and respond to at

! != 22 least part of that. I think, you know, things we're E

l 23 talking about are things that really don't have safety 24 significance. But, also, you have to recognize that O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i

72 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 f]

l 1 the plant has probably more than 100,000 drawings. Of 2 those 100,000 drawings, there's a certain set that they 3 call critical. These are things that the operators 4 rely on because they -- they're referenced in or have 5 information that -- some emergency procedures, things 6 that they need to operate, things that they need to )

7 immediately assess problems. Those get corrected I 8 won't say immediately, but very -- they get -- they get 9 marked up in the control room almost immediately, 10 probably within the shift. They also have a process g 11 where the actual drawing gets redrawn within 30 days.

e 12 So that, you know, it's not -- we're not talking about 13 those things that could affect the plant safety or the 14 operator's ability to operate the plant. Those things 15 are going to get done before restart. And, you know, 16 we'll recognize that that needs to be done. What we're 17 talking about are things that are basically of no l 18 safety significance --

19 DR. TRAVERS: Not FSAR level.

20 MS. BASSILAKIS: Not FSAR level stuff?

e  !

, 21 DR. TRAVERS: Level -- the DR's don't b

= 22 refer in many instances to the FSAR.

5 l 23 MR. IMBRO: Well, yes, but the example -

24 - I mean let me give you an example. I did say that it POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

73 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 was some non-safety significant FSAR changes that --

)

2 although they wouldn't be implemented before restart, 3 the licensee is going to write the change paper. The 4 FSAR is not going to -- you know, it won't physically 5 be upgraded because, really, you know, whether it's 1 6 Type ACL or Type DCL, you know, from a regulatory 7 standpoint, you know, not always, but probably doesn't ,

1 8 make any difference. Okay?

9 And so, yes, it's going to be fixed.

10 Does it need to be done before restart? No. Is the g 11 change paper going to be written? Yes. And so that n' I p) u 12 there's a process to do that where they periodically 13 update the FSAR. I mean, again, if it was an issue, 14 FSAR issue, that was -- turned out to be an unreviewed 15 safety question and that puts it into a whole other 16 category, and those are done pre-restart. But for 17 these, you know, minor errors, then those, you know, i l

l 18 can be deferred.

19 MS. BASSILAKIS: Well, you did say that j f 20 the licensee has to look to see whether there's any 0

, 21 non-conformance issues with these Level 4's, for the i

e 22 systems that have been identified as Level 4's. But 5

l 23 we're not really talking much about all the other 24 systems that haven't had the Level 4 violations or not A

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

74 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998

)

1 violations, but discrepancies identified in them. And 2 I'll --

3 DR. TRAVERS: Well, but they are looking

4 broader at the corrective --
5 MS. BASSILAKIS
They are looking 6 broader?

7 MR. IMBRO: Well, yes, I mean for the --

l 8 DR. TRAVERS: Trending.

l l

9 MS. BASSILAKIS: You didn't talk much l

10 about trending tonight.

l R 11 MR. IMBRO: Yes.

b 12 MS. BASSILAKIS: Tonight?

13 MR. IMBRO: Well, no. I didn't. I was 14 trying -- I was trying to be brief. But maybe I wasn't 15 brief. But I'll talk about trending for a minute. I 16 But, again -- well, we did talk a little bit about it.

17 Part of the reason why we're trending is l 18 to try and -- try and find areas where there may be 19 some potential weakness or where they may be, even f 20 though the errors are minor errors and not putting the

$ 21 plant in a non-conformance condition, would lead you to z i

- 22 -- you may want to look further to see if there are 1

[ 23 other conditions'that maybe would affect licensing 24 basis.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l 1

75 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 So, for example, you know, if they found 2 a lot of calculational errors, but particularly in, ,

i 3 say, pipe support system, to take an example, and they 4 found a lot or most of the calculational errors were in 5 the pipe support area, well, even though these things -

6 -

the issues may be Level 4 issues, that may suggest 7 that there's some kind of programmatic problem with 1

8 pipe supports and maybe we'd want to look further, I 9 mean depending on what the issues are. So I mean 10 that's how we're going to handle that kind of --

l lg 11 MS. BASSILAKIS: Fill us in as you come 9

12 to --

13 CHAIRPERSON LANNING: Okay. We're going 14 to move on -- excuse me.

l l 15 MS. BASSILAKIS: I know. Fill us in on 16 this when you make a decision.

17 MR. IMBRO: We will.

ll 18 CHAIRPERSON LANNING: All right. One 19 last question on the Independent Corrective Action f 20 Verification Process. Last one.

f 21 MR. MIKE LAMBERT: Mike Lambert. What I I

- 22 had to ask you about wac the five Level 1 complaints.

5 ,

l 23 And I wanted to know what those problems were. j 24 MR. IMBRO: Well, again, they're rg' POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

l J

76 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 preliminary. I don't know if I know all of them off 2 the top of my head. But one involved pressure, 3 pressure locking of the gate valve, doubled gate valve, 4 so that the valve essentially wouldn't open if it got 5 pressure-bound. As the pressure builds up between the 6 two disks and the motor is not strong enough then to 7 open the valve. So that's one, one issue.

8 DR. TRAVERS: But just to make a general 9 comment, just for your information, on the Internet, if 10 you have access to it, these preliminary findings are

, g 11 being posted as they are identified. We probably can't u

,g

- 12 list even one of them right here tonight. But we make

(>

13 them public in a number of ways. One is putting them 14 on the Internet. Another is -- I think they go on the 15 PDR as well.

I l 16 MR. IMBRO: Yes.

l 17 MS. BASSILAKIS: You can list the ones l 18 you know off the top of your head.

19 DR. TRAVERS: Well, he's given an l 1

20 example.

l f 21 MR. IMBRO: That was one. And Level 1 L 1

= 22 has to do with problems at the steam generator, steam I E l l 23 generator level, and the measurement of the level as l I

24 it's an input of that level into the reactor protector O)

\- POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

)

i 77 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 system. There was an issue with the steam generator 2 level set point.

3 Another issue' involved -- had to do with l

4 plans. I don't remember what it was. I can't think of 5 them all off the top of my head. 'I'm not intimately.

6 conversant with all of them. Some of them are rather 7 complex.

l 8 Another -- another involved a tech spec 9 setting on the reactor FIP for low reactor coolant 10 flow. Anyway, so it was -- I've named at least three g 11 out of five.

i9 12 MR. LAMBERT: So the Level 1 are the l l 13 most significant? l l

14 MR. IMBRO: That's right. But, again, 1

15 they're preliminary. And let me explain what I mean by 16 preliminary again. Maybe you're new here. I haven't 17 seen you before.

ll 18 But preliminary means that --

these are 19 Parsons issues. If Parsons, the ICAVP contractor for f 20 Unit 2, believes there is a problem that would cause

, $ 21 the system not to be able to perform the safety 1

- 22 function -- now, that's their belief based on what 5 I l 23 documentation they have. )

24 Now, they, in fact -- then they send O POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102  !

78 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 f')T 1 this -- they issue a DR to NU and NU will evaluate that 2 and they will either agree and say, "Yes, it's a 3 problem" or they'll say, "No. Here's additional 4 information that demonstrates it's not a problem" or 5 they will say, "Yes, we knew about that. We found 6 that, you know, when we did our CMP." And so -- and {

7 they're already planning to fix it.

8 So the most concern for us would be is j l

9 if there's a Level 1, that it was not previously 10 identified by the licensee. But, again, these five are R 11 still being discussed. So tune in and we'll fill you 8

l l r 12 in on how it turns out. I mean I can't tell you any i \_3) 13 more than that now because I don't really have --

l 14 MR. LAMBERT: You said the NRC found 15 something around, I think, 400 problems and 200 were 16 un-discrepant or not real problems? l t l l 17 MR. IMBRO: No. We -- those are not )

I 18 things that we found. Those are things that Parsons il 19 found. I guess you're still talking about Level 2 -- I 20 mean Unit 2.

$ 21 No. What I said was -- all right. 400, t= 22 Maybe that's Unit 3. Yes. There were 419 accepted and l 23 closed DR's for Unit 3. I guess -- which -- I said a 24 lot of numbers before. Tell me what you're referring O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

79 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 to and I'd be happy to try and clarify it for you.

2 For example, on Unit 2, there were 305 3 total preliminary DR's issued.

4 MR. LEUHMAN: Thus far.

5 MR. IMBRO: Thus far. They're still 6 going.

l 7 MR. LAMBERT: Okay. That's it.

8 MR. IMBRO: Okay. Thank you, Phil.

9 All right. Let's move on to the next 10 topic then, l R 11 MS. BASSILAKIS: Where are we on the 8

12 agenda?

p) 13 CHAIRPERSON LANNING: We are now going j l

14 to discuss the Safety Conscious Work Environment. 1 l

15 MR. McKEE: I'11 try to be -- l

16. DR. TRAVERS: This is not on the agenda.

17 This is just -- would you like to hear what the agenda l l 18 is one more time?

19 MS. BASSILAKIS: I would love to hear 20 the agenda.

$ 21 DR. TRAVERS: We'll do that.

1

- 22 CHAIRPERSON LANNING: Okay. We'11 5

l 23 discuss next the Safety Conscious Work Environment.

24 Mr. McKee will lead that discussion. And he'll POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

80 MEETING RE: MILLSTONE UNITS fl

%) MARCH 4, 1998 1 introduce Little Harbor Consultants. That will be 2 followed by a very short break. And then Mr. Durr will 3 talk about results from recent inspections. This is 4 corrective action inspection and a most recent 5 integrated Resident Inspector report. And then after 6 that, we'll go into the general question-and-answer 7 session.

8 Okay. Phil?

9 MR. McKEE: Good evening. I'll try to 10 be fairly quick so we can give more of an opportunity lg 11 to ask some questions in this area.

U 12 At our last meeting with the public --

13 and I don't think all of you were there because we have 14 more here tonight -- we talked about some of the NRC 15 activities. I'm going to briefly go over some of the 16 NRC activities. And one thing we talked about at the 17 last meeting is the NRC had just completed a team l l 18 evaluation that went on for a week in December and then

!I

! 19 following on a week in January, 20 That evaluation evaluated the licensee O

, 21 programs and their specific Employee Concerns Program l

- 22 area. And the only concerns, really, that come outside 5

l 23 the line organization through this, Northeast Utilities 24 organization deals with those issues. And also looking A

5J POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

81

-MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 at the broader aspect of the Safety Conscious Work 2 Environment and programs they had in that area at the 3 utility.

4 I'm not going to get into detail. We 5 discussed it last time. I think -- suffice it to say 6 that we really found-that the Employee Concerns Program 7 aspect had made improvements and we thought at that 8 time it was operating effectively.

9 Looking at the Safety Conscious Work 10 Environment, there have been a lot of recent changes R 11 and we considered improvements in that area, although 0

12 we did identify in that area a couple of areas, 13 weaknesses in areas that we thought where some 14 additional action may be needed'and improvements may be 15 needed.

16 Also during that evaluation, we looked 17 at the third-party oversight organization, Little l 18 Harbor, who provides oversight of the licensee 19 programs. And we found their activities in general 20 were good and their oversight in following events. And a 1

. 21 we identified some areas where we felt maybe some 1 I

1

- 22 additional efforts might be needed by them.

5 l

l 23 I'd also like to --

well, since that I 24 time -- and we have a program where we have continuing O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

f 82 l MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 on-site evaluation and monitoring through some NRC 2 people, folks, and some contractors that we have 3 looking at that, those activities. And periodically we 4 have three-way meetings between Northeast Utilities, 5 the NRC and Little Harbor Consultants to discuss the i 6 status of activities.

7 And I want to mention that yesterday we 8 had a meeting in this regard. I'm going to let Little I l

9 Harbor probably describe a lot of what they've done in ,

10 their activities. And they're done an important j

)

R 11 activity recently with some of their structured

,b )

12 interviews of site personnel.

13 But, also, I'll just quickly mention 14 that the licensee made a presentation of that and 15 identified in their determination was presented at that 16 meeting, that they had been making significant progress 17 in their programs and Safety Conscious Work i l 18 Environment, Employee Concerns Program. Again, I won't 19 go into a lot of the detail.

20 In addition to their needing by their o

. 21 program to get concurrence from their Employee Concerns

= 22 oversight panel, which is an internal organization at 5

l 23 the site that provides oversight of the activities in 24 that area, and also concurrence from Little Harbor, O

POST REPORTING SEPVICE HAMDEN, CT (800) 262-4102 l

l 83 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 they've identified four basic criteria that they feel .

2 need to be satisfied for -- to support restart. I 3 And in three of those areas, they think 4 that their progress is satisfactory. And I'll just 5 quickly say that those three areas are for employees to 6 raise concerns, ability of employees to raise concerns; 7 the second one, line management handles issues 8 effectively; and the third one, Employee Concerns 9 Program is effective.

10 The one area that they identified I

R 11 themselves as tracking dissatisfactory was recognizing l$

12 and addressing a problem with focus areas in their 13 organization.

14 Also, Northeast Utilities discussed at 15 this meeting their process. And they have a more 16 detailed process on how they handle harassment, 17 intimidation, discrimination- issues as they come up in l 18 their organization either through -- through either 19 process, primarily through the Employee Concerns 20 Program. And they outlined a pretty detailed process O

, 21 of how they dealt with this. This was an area that had

! 22 been identified in several of our evaluations and by g

s l 23 Little Harbor as an area that was weak and needed some 24 strengthening. And they covered a pretty extensive POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

1 84 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 program in dealing with that.

2 One thing I do want to mention, though 3 I'm certainly not going to get into detail on that, is 4 one thing in our monitoring. We monitor activities and 5 follow on events and other things that go on at the j f 6 site. And I guess recently -- and it's been in the 7 press -- there was an issue that occurred back in late 8 January where at the meeting in the oversight 1

9 organization some talking points were distributed. And I 10 those talking points included words, at least in

'R 11 retrospect, that were inappropriate and could have 12 implication that really were not conducive to a safety 13 conscious work environment and possibly encourage 14 employees to address issues.

15 Since that time, as identified, there 16 has been a number of actions, including investigations 17 of that event done by the Northeast Utilities. They l 18 also have taken some additional actions, including, I

. 19 think -- and recently that has been in the news media.

20 There's a personnel action. I'm not going to get into o

. 21 that. I brought it up principally as part of the NRC 1

= 22 role.

,.5

'l- 23 With respect to that, we issued a letter 24 to the licensee because that matter, particularly with

' O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

85 MEETING RE: MILLSTONE UNITS MARCH 4, 1998

(])

1 the environment and our earlier concerns in other 2 programs and Employee Concerns Program area, we wrote a 3 letter to the licensee having --

questioning that 4 memorandum and what it meant. And it does raise the 5 potential of a violation of a certain portion of NRC 6 regulations dealing with potential discrimination and 7 also our concern with regard to the chilling effect 8 that that letter may have on other employees. So we 9 ask in that letter for Northeast Utilities to provide 10 us a response to those elements. And actually, we're g 11 due a response here shortly, by the 10th or soon 0

12 thereafter, their response to that.

13 Also, one of the concerns that we 14 addressed in that was their handling of that memorandum 15 after it was distributed and how it was returned and 16 processed after that. So we're expecting that 17 information soon.

l 18 And I also might mention that Little 19 Harbor has observed and followed the licensee's process 20 and how they dealt with that issue as it arose and how

$ 21 it was dealt with subsequent to that happening. ,

= 22 With that, as I mentioned, Little Harbor 5

l 23 has a -- okay. I don't know if I can continue on that 24 note.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

86 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 A VOICE: No. We need to stop. He 2 needs to set up his --

3 MR. McKEE: All right. What I was going 4 Eto do now was to let Little Harbor describe some of 5 their activities and results of some of their recent 6 ongoings at the site. And I think they need about five 7 minutes to set up for their presentation. So do you i

8 want to --

9 CHAIRPERSON LANNING: Yes. Everybody 10 take a five-minute break and then we'll continue.

g 11 (RECESS) e 12 MR. JOHN BECK: Okay. I'm going to 13 start the presentation. We're going to cover two 14 things tonight. First we're going to talk about the 15 structured interview results. As indicated earlier, 16 there are handouts in the back of the room that contain 17 all of the slides that we were going to use before we l 18 had a technical problem. And we cannot use the 19 projector tonight.

20 The second part of the presentation is

$ 21 going to be a revisit of our view of where we think 1- 22

- Northeast Utilities stands with regard to the success 5

l 23 criteria that they have established for their restart 24 effort.

O POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102

87 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 I'll cover the first part and Billie 2 Garde will speak to the second aspect.

3 As you recall, our first set of 4 structured interviews were conducted last June and July 5 and reported on in a meeting similar to this on July 22 6 of last summer. The interviews we're going to discuss 7 tonight were conducted between February 2 and February 8 20.

9 The second slide in your handout will 10 give you the basic framework for our interviews. We g 11 used essentially the same questions this time as we did 2

12 last summer. Some of the questions were slightly 13 reworded for clarification based on the experience we 14 gained in the first set of interviews.

15 This time we interviewed 298 workers at 16 Millstone. Out of the 298, 24 volunteered to be 17 interviewed and 18 happened to be contractors. The l 18 information we'll present this evening includes all 298 19 interviews.

20 We performed an independent evaluation

$ 21 of the volunteer responses and determined that the i

- 22 results which you will have in these handouts are 5

l 23 essentially unchanged whether you have the volunteers 24 included or not. In other words, there was no bias O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

88 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 associated with the volunteer responses as opposed to 2 those individuals we chose to be interviewed.

3 We selected those to be interviewed to 4 include a representation from all work groups at the 5 site and selected different people from those 6 interviewed last summer. A few of the volunteers were 7 people who had been interviewed before.

8 Little Harbor did the selection, made 9 the contacts with the individuals at the site and 10 scheduled all the interviews. The interviews were g 11 voluntary and we have taken every precaution to assure 12 that there's no attribution to comments made during 13 those interviews.

14 We asked those interviewed to answer 15 several questions using a scale of 1 to 5, the same 16 scale we used last summer. We also asked questions 17 that provided textual responses. One of the handouts i 18 in the back of the room contains all of the textual 19 responses that we got during the interviews.

l 20 It's important to remember that what

$ 21 you're about to -- we're about to discuss is what 1 22

- members of the work force told us. The results are 5

ll 23 what they are and are a snapshot or a view of how these 24 298 members of the Millstone work force felt at the O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

i 89 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 time of their interviews.

2 So let's talk about the results. Slide 3 3 in the handout was in response to the question, "If 4 you became aware of a problem that could affect the 5 safe operation of the plant, would you raise that 6 concern?" 100 percent answered that they would raise 7 the concern. The overwhelming majority indicated they 8 .would raise the concern to line management. There were 9 two or three who indicated they would use an 10 alternative route, the Employee Concerns Program, the g 11 NRC or perhaps the media.

d 12 100 percent also indicated that they 13 were not aware of any safety concern that had not been 14 previously raised. These were the same results as we 15 obtained last summer.

16 Slide 4 in the handout responds to --

17 when asked about any concern as opposed to a safety l 18 concern, what is the comfort level of raising that 19 concern. And this was one of the questions where we 20 asked for a response from 1 to 5, 1 being Very

[ 21 ' Uncomfortable and 5 being Very Comfortable. The 1 22 average, as you'll see, was 4.3 this time around, which  !

l 23 is the same as we obtained last summer.

24 The next slide, when asked about O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

I i

90 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 conditions where someone would not be comfortable about 2 raising a concern, we received several responses. And 3 these are some of the examples of the typical answers.

4 The textual responses will show all of the answers in 5 that regard. There's still room for improvement in 6 this respect, in our view. I J

7 The next slide looks at the increase in 8 the number of people that responded Yes -- and it was 9 initially a surprise to us. "Has anyone told you that 10 raising concerns to the NRC could delay restart?" was g 11 the question asked. 93 percent said no. Seven !

W 12 percent, yes.

13 We did a detailed analysis of those i 14 positive responses to that question, including l

15 recontacting some of those we interviewed to better l

l 16 understand their reasons for having said Yes. In no j I

17 case did anyone in a management position tell anyone l 18 that raising a concern would delay restart. The Yes 19 responses were a reflection of water cooler discussions f ~20 or discussions between peers. No one indicated that

$ 21 this would prevent them from going to the NRC with a 1

22 concern.

5 l 23 The next slide, Slide 7, indicates that 24 98 percent indicated a willingness to raise a concern O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

91 MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1 to the NRC. The primary reason cited for not going to 2 the NRC was the belief that the concern would be 3 addressed before it would be necessary to take it to 4 the NRC. But there were a few who indicated a lack of 5 confidence in the NRC.

6 The next slide, Slide 8, reflects an 7 increased confidence in getting a nuclear safety 8 concern addressed and subsequently resolved. Last June 9 the rating was 4.3. This past month, 4.5 to that 10 question.

R- 11 Slide 9 talks about confidence that 6

12 going a particular route would result in resolution of 13 the concern. And we asked about three primary paths 14 for concern resolution; using the line management, 15 going to the ECP or the NRC. As you can see from the 16 slides, all three increased from last summer, the 17 confidence that resolution would be attained going in l 18 any one of these directions.

19 Slide 10, we asked if there was any 20 reason they would not use the Employee Concerns

$ 21 Program. 93 percent responded they would use the ECP.

1 22 And

- some of the No responses were as indicated on this 5

l 23 slide.

24 Slide 11 was a follow-up question of "Do O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

\

l

92 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 you know anyone who would not use the Employee Concerns I

2 Program?", an answer that resulted in 85 percent saying I

(

3 no, they didn't. And this was a decrease from last 4 summer.

5 This slide also provides some examples 6 of the reasons for not using the ECP. Given the 7 improved confidence as shown in the two previous 8 slides, we don't believe this difference is 9 significant.

10 Slide 12 talks about questioning R 11 attitude. And this is a very critical attribute of the b

12 safety conscious work environment. And we asked people l

13 to rate the questioning attitude of themselves, their 14 work group and the site as a whole, in their opinion.

I 15 The results were Improved from last I

i 16 summer, with a slight number, however, being the same 17 as it was.

l 18 The next slide, Slide 13, talks about

i. 19 the understanding and awareness of self-assessment.

.f 20 And in this case, it showed a marked improvement. As O

, 21 you can see, each of the three questions showed l- 22 significant improvement. Self-assessment having been I

l 23 discussed in the work group going from 82 to 94 24 percent. "And if it has been, is it being actually  !

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

l

I 93 ,

MEETING RE: MILLSTONE UNITS l

() MARCH 4, 1998 l 1 done .in your work group?", 98 percent said yes this l 2 time as opposed to 79. "And' have you seen useful 3 results?", 92 percent yes as opposed to 58 last summer.

4 These were marked improvements.

5 Slide 14, we asked about the Corrective 6 Action Program and again saw a marked improvement on 7 the part of the workers at Millstone and the confidence 8 they have in the Corrective Action or CR process as l 9 reflected on this slide and the next one, Slide 15.

l 10 Slide 16 reflects a measure of 1

iR 11 confidence and trust between workers and their

'~

12 supervision and is improved from the round of 13 interviews that we did last summer.

14 Slide 17 talks about a response to two l 15 questions; "Do you feel that you are making a 16 contribution to the overall goals of Millstone?" 99 l 17 percent of the people interviewed said Yes. "Do you

l 18 know or are you aware of employees who have been -- who 19 have raised concerns and were rewarded and praised for l 20 it?" A marked change from last summer, 48 percent then iO

, , 21 and 78 percent now.

' I= 22 Slide 18, probed the attitude of l 23 workers, supervisors and managers toward people who 24 raise concerns. Again there was improvement in each O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

L 1

94 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 area from last summer.

2 Slide 19 talked about "Do you know 3 employees who have raised concerns and suffered 4 repercussion?" A slight increase in knowledge of 5 people or people who felt they knew someone who had.

6 "Have you ever felt reluctant to raise concerns?"

7 Essentially the same answer, 74 percent last summer, 76 8 percent now said they had not felt reluctant. Excuse 1

9 me.

10 Slide 20 talks about when asked to rate  ;

{

R 11 the presence of the chilling effect at the site. Again {

~ l 12 the response was improved slightly. Remember in this I O 13 case, a 1 is the total absence of a chilling effect and 14 5 being pervasive presence. Last summer we were 1.8 15 and this time 1.7, a slight improvement.

16 Slide 21 talks about the level of 17 teamwork and cooperation that exists at the site. And i 18 in each case, within a work group, between work groups l 19 and at the site as a whole there was a slight increase f 20 in people's views of the level of teamwork and O

, 21 cooperation.

1

- 22 Slide 22 talks about awareness and E

l 23 understanding of Mr. Kenyon's expectations for employee 24 concerns. 99 percent were familiar with it. And with s

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

95 MEETING RE: MILLSTONE UNITS

(]') MARCH 4, 1998 1

j 1 regard to Millstone success objectives, 97 percent.

l l 2 Slide 23 talks about communications.

i 3 "How effective is management in communicating their 4 expectations regarding raising concerns at the site?"

5 And in each instance, each level of management 6 reflected improvement. We think this is due, at least i

7 in part, to the training that's been recently conducted i I

l 8 for managers and supervisors that has caused a 1

9 substantial increase in how they're viewed as to their 10 effectiveness in communicating with those who work for j$ 11 them.

' 2 12 Slide 24 and the next several slides are l

l 13 intended to probe how individuals feel about their job 1

14 and the general work environment at Millstone. And as l 15 you see by examining 24, 25 and 26, people feel 16 generally more positive in each one of those areas of l 17 questioning.

l 18 In summary, the interview results I. 19 reflect across-the-board improvements, the largest

! 20 improvement seen in the awareness of management's O

. 21 expectation, confidence in the Corrective Action l

l

- 22 Program and the utilization of the self-assessment E

l 23 process.

24 The results of these interviews confirm O POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102 l I' l

96 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 l 1 observations by Little Hsrbor with regard to the

]

j 2 willingness of this work force to raise concerns. In 3 fact, we believe that, at least with respect to raising f 4 concerns, this is currently a very empowered work 5 force. .

J 6 The bottom line as- a result a these i l

7 ' interviews, we believe the work environment at !

l 8 Millstone has improved since last summer. I also want i 9 to caution you that this improvement could be tenuous 10 and a continued improvement will require the same level g 11 of communication and commitment going forward as has t!

12 been made over the last several months.

13 That concludes the. presentation of the 14 structured interview results. I'd like to move to 15 Billie's presentation of our evaluation of their I

16 success criteria. And then we'll take. questions on 17 both points. i

'l 18 MS. BILLIE GARDE: Thank you.

19 This presentation will be a little bit f 20 more difficult to do without the slides because we used o

, 21 the colored windows. So if you have the handouts, the 1

= 22 handout that I'm working from is called Status of a E

l 23 Safety Conscious Work Environment at Millstone. )

24 And just to repeat for those who are not O POST REPORTING SERVICE l

HAMDEN, CT (800) 262-4102 I

~

97 MEETING RE: MILLSTONE UNITS f MARCH 4, 1998 1 familiar with our grading process or evaluation 2 process, we have, as you'll see in Slide No. 2, five 3 basic ratings. The top rating, if you saw the slides 4 in color, would be green. The bottom rating would be ,

l 5 red. The two ratings below the line are not acceptable j i

6 for restart. The ones above the line are acceptable 7 for restart.

8 At the public meeting yesterday, we 9 talked a little bit about these and tried to re-explain 10 a little bit more our rating system. And Mr. Griffin 11 used the example of the info grading system for those

,- 12 of you who are familiar with that, where you have a1 13 to 5 scale that info rates certain categories on.

t l 14 Another scale, which we don't like to 15 use because it isn't really reflective of how we 16 arrived at these processes, but one that pretty much 17 matches up with the five windows is a grading scale if l 18 you consider the top grade an A, the green; the second 19 a B; the third a C; below the line a D and an F. That f 20 roughly also matches in in-gradation how we're

$ 21 approaching this. And that might help as we go through 1

. 22 these, 5

l 23 And I'm going to just do a very short 24 summary of the windows and then answer questions. And

(

POST REPORTING SERVICE HAMDEN,- CT (800) 262-4102  ;

i 1 i i i

98 {

MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 by that, what I'm going to do is give you the four l l 2 success criteria that NU measures and our -- we have 3 12. Our 12 roll up into their four. And I'm going to 4 point out the ones that changed within our 12 and our 5 conclusions on the four as opposed to reading all the 6 slides. All of it is in this material. And if you 7 have any questions, I'll be glad to answer them.

8 The first NU success criteria, that is

)

9 " demonstrate the willingness to raise concerns", there 10 was a slight change. That is it went from a neutral g 11 yellow or a C to a B, which is a yellow with a plus 2

12 sign. And we believe that is trending upwards.

13 The basis for that move as set forth in 14 our Slide 4 as a list of positive factors which we've 15 included on that slide, first of all we've seen the ERB 16 review process continuing to be very effective as a 17 check-and-balance. And by that what we mean is we've -

l 18 - the Executive Review Board is a process that the 19 company set up to review proposed disciplinary actions 20 of employees from the written -- proposed written l 0 I

, 21 reprimand up to termination. j

i. 22 That process has been started over the 5  ;

l 23 last couple of months. We see it now becoming a very j 24 effective check and balance that is giving a lot of l 1 -

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l i

99 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 insight to management and allouing the process to 2 really play itself out. That's been very effective.

3 The oversight event in which the mid-4 level managers raised objections, strenuous objections, 5 to the use of the terms " cynics" and the negative

! 6 attitudes or negative managerial comments we viewed as 7 very positive. It also appears in the negative slide 8 where appropriate. But the fact that some 30 people 9 who were in supervisory positions immediately reacted l 10 to that memo when they saw it, immediately responded, i

ig 11 and as an organization brought that issue to a close 12 within that group was very positive. This was not a 13 group of mid-level managers who sat silent when they 14 saw something happen and didn't react to it, respond to 15 it or stop it.

16 We've also seen increased recognition 17 and rewards by management for people who raise concerns l 18 and bring those concerns forward. And then the results 19 of the structured interview on the question of 20 willingness to raise questions were very positive.

O.

, 21 The second NU success criteria, Slide 5, j i

= 22 remained the same, essentially a B. Demonstrates that E_

] 23 issues are being effectively resolved by line 24 management. This is our slide that looks at or our O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

100 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 window that looks at the Corrective Action Program at 2 the site. And that essentially stayed the same.

3 The third success criteria, which is on 4 Slide 6, demonstrates that the ECP is effective. That 5 has -- that stayed the same, although, for those of you l 6 who may not have been at earlier meetings, it fairly 7 recently moved up from basically a D to a C if you use 8 that terminology. And that has stayed the same.

9 The -- we've included on Slide 7 some l 10 positive and negative factors in regards to the ECP g 11 status. Those are listed on Slide 7. Just a few that

!d i

12 I would like to highlight.

13 The customer satisfaction issue, which 14 was one of the main reasons that the ECP fell behind 15 for some period of time, is up to 83 percent on the 16 basis of Little Harbor's review of customer 17 satisfaction.

l 18 We've seen the ECP be responsive to some 19 of our earlier concerns. And in the context of the 20 ECP's participation in closure panels and the executive O

, 21 review process, we've seen the ECP become a very b

22 independent organization willing to point out issues, l 23 stick behind their findings, advocate on behalf of the 24 employees who had substantiated their concerns, O. POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

101 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 explained that to management and hold their ground.

i 2 We've been very happy with that.

3 The negative factors -- and by that we 4 mean the factors that have held it back, why it's still l 5 not higher than it is. Interpersonal skills, we need -

6 - we see the need for continued improvement between ECP

! 7 investigators and the employees that they're working l 8 with.

l 9 And we -- the second negative factor is l 10 timely and coordinated response to potential chilling g 11 effect. This is something that in January we

! d 12 recommended -- one of our recommendations was that they )

13 establish a protocol to deal with both the Human i

14 Resources Department and the Safety Conscious Work l 15 Environment to develop coordinated responses. There 16 has been a lack of coordinated responses in some recent l 17 cases. They need to get that together.

!l 18 The time period that it has taken the

! 19 company and the ECP to come to some agreement on how 20 they were going to handle what we call 10 CFR 50.7 0

. 21 allegations, it's taken too long to get to that

- 22 conclusion, although they now are.

5 l 23 And then the last negative factor is 24 there has been some inconsistent handling of O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

102 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 allegations within what the company refers to as the 2 HIRD allegations. And that means within -- within ECP 3 itcelf, investigators were handling these things much 4 differently from investigator to investigator. Again, 5 that's a recommendation we made last month.

6 The last success criteria, Item No. 4, 7 which is on Slide 8, is -- was a change. For the last 8 several -- in fact, all of the windows since we started 1

9 rating the company, this item has been in the red or an j 10 F. It's moved in this evaluation or analysis up to a 11 D. It's still not acceptable for restart, but it has 12 moved up.

O 13 And the next two slides, Slide 9 and 10, i'

l 14 list both the positives on Slide 9 and the negatives on 15 Slide 10 that went into our evaluation and decision 16 process to move it up a notch.

17 I can go over some of those. Let me I jl 18 just point out a few of them that you may not be 19 familiar with. And I'm going to first go to the 50.7 20 evaluation criteria and process. I just said in the

O i

, 21 slide before -- and we kind of dinged them because it 1

-- 22 took so long to figure out a process by which everybody 5

l 23 agreed on they were going to use.

! 24 However, on the positive side, the O- POST REPORTING SERVICE f HAMDEN, CT (800) 262-4102

103 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 process they have now adopted is, if not the leading 2 process in the industry, very close to the top in the 3 industry. They have set themselves an extremely high 4 standard for the way in which they receive and process 5 allegations of harassment, intimidation, retaliation 6 and discrimination.

7 And although it took them too long to 8 make final decisions in this area, it's a positive 9 factor that they ultimately chose the hardest possible 10 avenue and the highest possible standards of which to g 11 hold themselves to. And so we credit that as a plus, d

12 The other things, which I've somewhat 13 talked about before, the ERB process continues. They 14 are using organizational effectiveness consultants.

15 That is they've brought basically professionals trained 16 in the area of how to make organizations more effective 17 from outside of this company in to help work with their 18 organizations. That -- we see progress in that area.

l 19 And in the recent month to the six 20 weeks, we have started to see some significant changes o

.. 21 in expediting the resolution of some long-standing

! l

= 22 employee issues. That's been done with the ECP and 5

l 23 also with the help of bringing a Senior Vice President 24 in to the HR arena.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

104 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 l

1 The negative factors on Page 10, they 2 still have a high number of l HIR&D complaints. Those 3 concern numbers are still very high. It's l unfair and 4 probably inappropriate to just look at raw numbers. j S But they still have very high numbers in that area.

l 6 It's a negative factor that the oversight event 7 happened at all. And it's captured there. And they l 8 still have a lack of a written protocol between the 9 SCWE, Safety Conscious Work Environment, HR and ECP l l 1

10 Departments. That's the roll-up. i g 11 Within out 12 attributes, there are --

l :!

l 12 other than the ones I've pointed out, I just want to go I pd 13 over which ones we've changed. On Page 12 -- on Page i i

14 11, our Attribute 7 went up. " Positive recognition 15 given to employees" went up a notch. On Page -- I l 16 MS. BASSILAKIS: Excuse me. Could you 17 repeat that? I'm sorry.

l l 18 MS. GARDE: Yes. On Page 11 --

3., 19 MR. BECK: Page 10.

20 MS. GARDE: Oh. I'm sorry. It's on my IO

, 21 Page 11.

1

- 22 MR. BECK: Slide 11.

Y l l 23 MS. GARDE: Slide 11, where it says "LHC I 24 attributes contributing to NECO set criteria No. 1", do l f

k POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

(

l

r 105 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 you have that page? Okay. On that page, Item 7 --

l 2 A VOICE: I still don't --

3 MS BASSILAKIS: It was Page 10 or Slide 4 10?

5 MS. GARDE: I'm sorry.

6 MS. BASSILAKIS: I think you mean Slide 7 10.

8 MS. GARDE: I don't have anything about 9 10 on mine.

10 MS. BASSILAKIS: Slide 11.

11 MS. GARDE: I mean Slide 11.

12 MS. BASSILAKIS: Right.

13 MS. GARDE: Sorry. Page 6.

14 MS. BASSILAKIS: Okay.

15 MS. GARDE: Thank you for the quality 16 control.

i 17 Okay. Page 6, Slide 11, Item No. 7, l 18 Positive recognition is given to employees. That went l

I. 19 up a notch.

20 A VOICE: Wait a minute. It doesn't O

, 21 match with ours.

1

= 22 MS. GARDE: Still? Oh, dear. I don't 5

rl 23 know why that doesn't match up.

24 A VOICE: Slide 20 on Page 10.

O- POST REPORTING SERVICE RAMDEN, CT (800) 262-4102  !

I l

l I

106 4 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 A SECOND VOICE: Yes.

2 MS. GARDE: You're -- I'm looking at a 3 slide that has the five success criteria on one page.

4 I hope that we have the same -- that you have the same 5 handouts.

6 A VOICE: Well, before this --

7 A SECOND VOICE: Page 15, Slide 30.

8 MS. GARDE: Okay. Let's do this. I'll 9 tell you what they are. You can right them down and 10 then we'll find them. All right? Because there's only R 11 -- I think there are only three -- four. There's four.

'0 12 One goes up. Our Item 7, Little Harbor Item 7, 13 " Positive recognition given to employees" goes up a 14 notch. Okay?

15 Little Harbor Attributes No. 8 and 9 go 16 from red to yellow minus or from an F to a D. And our 17 Item -- where's the training one? Our Item 3, " Senior 18 management provides training to all managers", this one l

19 went down a notch. Well, it didn't go down a whole 20 grade. It went from an up arrow to a horizontal arrow.

$ 21 What that means is that we do not see continued I

' k. 22 improvement. It changed to horizontal. And largely 5

l 23 that stems from the responses regarding a 24 recommendation that continued training has to be given O- POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

107 MEETING RE: MILLSTONE UNITS Il N/ MARCH 4, 1998 1 to new supervisors. Although the company has made a 2 commitment to do that, we don't see that it's being 3 timely enough to capture the new supervisors as they 4 come in to the site. And that's why we dropped the 5 arrow from up. ,

1 6 Now, I know that was very confusing.

7 And I'm very sorry our machines don't work. Is there 8 any questions on this presentation? I also have a few 9 other points I want to make.

10 Yes?

g 11 A VOICE: Both of your presentations?

0 12 MR. McKEE: Yes. I think what we're

\ l 13 going to do here now is go into our routine of 30 l 14 minutes and that will apply to both presentations 15 because we have two other topics after this to cover. I 16 MS. GARDE: Yes?

l 17 MR. McKEE: The questions can be for l l 18 either NRC or Little Harbor.

19 MS. KAREN NORTON: Thank you. I take it 20 that the status of a safety conscious work environment o

, 21 at Millstone, those conclusions are based on the 22 structured interviews? Is that correct?

l 23 MS. GARDE: Well, it's based on a lot 24 more than the structured interviews. But the

(~

POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

108 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 structured interviews certainly are factored into our 2 gradations and evaluations. It includes all of our 3 other observations, all of our reviews of the work 4 within the ECP, our reviews of the problem areas. We 5 are constantly doing a lot of activities. One of the 6 activities we performed twice are the structured 7 interviews.

8 MS. NORTON: Okay. Well, my only 9 information I have about how you came up with the 10 conclusions you report is -- I want to focus on the

$ 11 structured interviews because that's really the only 9

12 thing I know too much about.

13 I had a few questions about -- well, 14 first, would it be correct to say that you feel 15 confident of your results? You've said that you 16 consider them quite significant, but there are some --

17 that you feel that they've made quite a bit of l 18 progress. Is that -- that's the general flow of what 19 you were saying. Correct?

f 20 MS. GARDE: I mean you've asked two o

, 21 questions. Are we confident in our results? I kind of k=

22 take that question as meaning are we confident in the 5

l 23 process that we follow as being reliable.

24 MS. NORTON: Yes.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

109 MEETING RE: MILLSTONE UNITS

({} MARCH 4, 1998 1 MS. GARDE: The answer to that is yes.

2 Are they showing progress? Yes.

3 MS NORTON: Okay. I just want to ask a 4 few questions about the psychology of the interview l 5 process. For example, I'm curious about how you did 6 your sampling. You conducted 290 interviews. And how 7 many employees at Millstone?

8 MS. GARDE: John, you can answer.

l 9 MR. BECK: There are approximately 3,000 10 people from the pool that we chose the 300.

$ 11 MS. NORTON: Okay. Which -- you say all

-9 12 work groups were represented. So can you give a few 13 numbers like in terms of, like, how many contractors 14 were interviewed and how many -- I'm just curious about 15 the total end because I don't see any of that in here.

16 I'm just --

l 17 MR. BECK: I believe I mentioned they l 18 were -- out of the 298, 18 happened to be contractors.

l. 19 The rest were NU employees. And we selected people on 3
20 a roughly proportionate basis to the number of people

! o l . 21 in the various work groups. So it's a fairly even I i

- 22 spread, with the singular exception that when we had 5

l 23 areas that had been previously identified as problem 24 areas for some reason, we tended to have a few more O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 .

I I

1

110 MEETING RE: MILLSTONE UNITS l () MARCH 4, 1998 1 people selected from those areas that had been l

2 designated problem areas to be sure that we had a ,

3 representative look and a weighted basis in that 4 respect. l 5 MS. NORTON: So your proportionate size 6 of your sample is what, about 10 percent or so?

l 7 MR. BECK: Approximately, yes.

I 8 MS. NORTON: And how long did -- what j 9 was the duration of the interviews?

i 10 MR. BECK: They ranged from -- probably

$ 11 the shortest was about 25 minutes when the answers came 9

12 real quick and people had nothing to add, to as long as

)

13 two hours and ten minutes in one case.

14 MS. NORTON: I'm wondering --

my .

f 15 recollection is that when you conduct the interviews, 16 you call the people away. And how do you assure that l 17 they -- they have anon -- anonymity? Whatever that l 18 word is. Yes. I think that you were discussing that

i. 19 before, that you were basically saying the people were

!r 20 aware that so-and-so was being called in. And with I

O

. 21 such a small sample size, I mean it's pretty obvious 1

5- 22 who is being talked to. And I'm just curious how --

5 l 23 you know, with the atmosphere, I'm really not -- I 24 would like to not feel so cynical. But in light of all O POST REPORTING SERVICE t

HAMDEN, CT (800) 262-4102 M

111 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 the pressure to restart and the impetus is there and 2 everybody wants to restart -- so I guess I really have 3 to -- I feel very -- that these results are, at least 4 from the interviews, seem very questionable to me 5 because I feel like everybody -- you know, they feel 6 they're -- first, they feel eyes are on them and, 7 second, that their interest is in restart.

8 MR. BECK: Well, let me respond to what 9 I think I heard in light of your question. Actually, 10 ten percent sample in the intensity in the kind of

$ 11 interviews we did is a fairly significant and, I think, d H 12 quite reliable way of finding out how people feel. We 13 didn't say they were confidential. Clearly, they were l 14 not. I mean people came to be interviewed. They could 15 be seen doing that. What I did say is that the results 16 of what people said were without attribution. I don't 17 think even with the textual responses that were handed l 18 out -- it would be difficult to identify any individual

l l . 19 as having said any one thing or another.

! lr 20 It's also important, I think, to l 9 l . 21 understand that in a structured interview process of

'I = 22 this sort, it's not so important what a single person

' .5 l 23 contributes. It's the whole that matters. It's' the 24 average of the 298 opinions as to how they regard their O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

1 1

)

l l

112 l MEETING RE: MILLSTONE UNITS l MARCH 4, 1998 j 1 supervisor, for example. So it's the aggregate weight 2 that is of far more importance than any given 3 individual's contribution.

4 MS. NORTON: Well, sure. And I 5 understand that. I also understand that ten percent is 6 a fairly standard sample size. But, also, when you're 7 dealing with 3,000 people and you're interviewing that 8 many folks and you have that many departments, the 9 amount of people that you've interviewed in each 10 department is really quite small. Isn't it?

$ 11 MR. McKEE: We'll let that be your last 13 12 question. We have to move on.

13 MS. NORTON: Okay. Isn't it? I mean --

14 MR. BECK: It's still in the ten percent 15 range or more.

16 CHAIRPERSON LANNING: Would you identify 17 yourself before you leave?

ll 18 MS NORTON: Oh. My name is Karen 19 Norton.

20 CHAIRPERSON LANNING: Thank you.

O

. 21 MS. NORTON: Thank you.

= 22 CHAIRPERSON LANNING: I believe this 5

-l 23 gentleman back here --

24 MR. JAY GIANNETTI: Good evening. My O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

113 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 name is Jay Giannetti from Niantic and I'm an employee 2 of Millstone station. A group of us from Millstone 3 would like the public and the regulator to know that 4 things are different at Millstone.

5 In less than two days, we have gathered 6 at least 1,540 signatures which support the following 7 statement, and I quote. "We, the undersigned workers 8 at Millstone station, pledge to you, our neighbors and 9 public officials, that we can and will operate the 10 station safely. We further want you to know that the E la management of Millstone station treats us with respect

(} 12 and we are confident that any safety issues will be 13 completely addressed in a timely manner." Close quote.

14 We are hard-working, dedicated workers 15 who want to return our nuclear units back to service in 16 a safe and efficient manner. We are proud of our 17 efforts and look forward to your successful return to l 18 service from all three units.

19 Thank you.

20 MR. PETER BOWMAN: Good evening. My 0

. 21 name is Peter Bowman. I'm from New Haven and I'm with I

g 22 a group called Always Connecticut. I've been concerned l 23 for many, many years about nuclear issues.

24 Like the lady that spoke earlier there, O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

114 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 I have some questions about the subjectivity of the 2 interviews. And I tried to look at it as fairly as 3 possible. But when you interviewed these people, I 4 think you said last summer, there was some indication 5 that the plants were going to go on line in '97. I 6 think we talked about a September start-up. I'm not 7 absolutely sure of the date line. But the people at 8 that time, you know, psychologically I'm trying to look 9 at this, that they felt, "Well, the plants are going on 10 line. We're going to express our concern because the

$ 11 jobs are there. The plant's going to go and, you know, d

12 maybe we'll get some of these concerns and that

(

13 addressed."

14 So time goes by and now we re-interview 15 quite recently, I take it, and it appears that there's 16 been an improvement, so called. But, to me, there's a 17 psychological factor in there which, I don't know, l 18 maybe you did take it into account. You'd have to tell 7

19 rae . But the improvement that suddenly there's a 20 concern by the employee, like the people outside of the O

, 21 plant, that these plants are in real trouble, thousands l 22

=

and thousands of unresolved issues. The chance of them E

l 23 going back on line are pretty slim. The company's on 24 the edge of bankruptcy. And the whole situation of the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

115 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 restructuring of the electrical industry and the 2 competitive edge that gas and these other fuels are 3 going to have is going to work, if I was the employee, 4 it would be working on my mind and I'd say, " Hey, this 5 job ain't going to last too long. What's the answer 6 they want? They want to see an improvement? Okay.

7 Things are going great now. Put it down."

8 I mean what I'm getting at is it seems 9 to me that it's not really a true statistical analysis 10 of the situation because of the psychological

$ 11 subjectivity in there which I don't think you took into U i 12 account. Am I right?

13 MS. GARDE: Well, is there a -- are you j i

14 asking a question? Are you asking us if we took that, 15 the psychological factor -- l 16 MR. BOWMAN: Well, one of the -- my 17 question is is this just a straight-out question-and-l 18 answer by one employee and then nine months or six

. 19 months a question-and-answer to the same employee? I ig 20 mean were these different employees or --

G

, 21 MS. GARDE: It's different employees.

!= 22 MR. BOWMAN: Different employees. But 5

l 23 did you take into account the possible subjectivity of 24 the answers with relation to the status or the supposed O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

116 MEETING RE: MILLSTONE UNITS O aracu 4 1998 1 status of the plants at that time?

2 MS. GARDE: We certainly took into 3 account the -- as we developed the questions and the 4 way in which we prepared and administered the 5 structured interview process, that the employees needed 6 to be probed on what their views were in a variety of 7 areas.

8 Now, that said, I want to respond to the 4 9 premise of your question; is that essentially 300 10 employees would come into the interviews and pretty 11 much all have -- react in a way in whien they would lie

]

j 12 or present misinformation about their true views on the 13 subjects of the questions, which you have, to create a 14 false impression about the work environment in which 15 they're worked on so that we would reach a false 16 conclusion. That premise is false because, first of

.17 all, you couldn't get 300 people -- this is a very I 18 independent work force. They have learned to speak

l
19 their mind and they do. And not all the answers were l
\

r 20 sugar-coated yeses.

O

. 21 As you read through there, you're going

]

! 22 But these employees are not to see a lot of candor.

ll 23 going to, and we don't believe did, come into the 24 interviews to create a false impression. In fact, what O POST REPORTING SERVICE  !

HAMDEN, CT (800) 262-4102

117 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 we saw in the interviews is what we see in the 2 workplace. It reflects two sets of data. One set of 3 data is what we ask people in questions. The other set 4 of data is does it match what's happening across the 5 environment? And it does.

6 MR. BOWMAN: I'm not arguing. This is 7 probably what you would see. But I'm not saying it 8 doesn't -- to me, it doesn't address the issue of plant 9 safety and the addressing of safety procedures because 10 this atmosphere would prevail as the crisis situation

, $ 11 approached, which you have now, d

12 MS. GARDE: That would assume that the 13 employees would not tell the truth. And I'm not 14 willing to accept that.

15 MR. BOWMAN: Well, psychologically --

16 there's a psychological, sub-conscious drive, not 17 necessarily a direct lie. They're saying -- to me,

! 18 from a psychological, statistical analysis, it doesn't

i. 19 hold water. You know? That's all I have to say. Very i

e 20 poor.

O

. 21 CHAIRPERSON LANNING: Go ahead.

I g 22 MS. MARIE CARTER: Very short.

l 23 CHAIRPERSON LANNING: We have a few 24 minutes. Okay?

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

i l

118 MEETING RE: MILLSTONE UNITS f')

s-MARCH 4, 1998 l

1 MS. CARTER: Very short. Marie Carter.

2 Yesterday, Billie, you used the word " tenuous" -- j 3 MS. GARDE: I did.

4 MS. CARTER: -- many times in describing I

5 the improvement within management. So would you I 6 elaborate on that please?

7 MS. GARDE: Sure. I will. And I had 8 been asked by a couple of other people to summarize my 9 statements at the end of the presentation yesterday.

10 And I'll do that. It's not cutting into your five R 11 minutes.

0 12 But I essentially made four observations 13 yesterday, kind of from an overall perspective, about 14 the differences in the work environment now from when I 15 arrived and began working in this project about a year 16 ago.

17 The first observation was that this l 18 management team knows their work force and the areas 1 19 and its leaders much better than you would see at a 20 normal site. That is there are so many checks and o

. 21 balances, people watching people, organizations I

g 22 watching organizations, that the executive management l

'5 l 23 has more management data, more progress data and more 24 feedback as a result of all of this information.

r)

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119 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 The second observation was that the work 2 force, as I see it, has become very empowered with 3 respect to the issues that affect their work 4 environment. I don't see the feelings of helplessness 5 and frustration I saw a year ago.

6 People are no longer afraid to challenge l 7 their management when there's a decision that's made 8 that's wrong, about issues they believe are wrong.

l 9 This work force will not tolerate being harassed or l 10 intimidated. If it's happening -- and I'm not saying

$ 11 it never happens because there have been -- continue to 9

{) 12 13 be incidents. When that look like that, sound it happens or when events happen like that, people won't put 14 up with it. They will voice those opinions They will 15 challenge those actions. And they will raise those 16 concerns. They'll push back.

17 The third observation I made was that l 18 what I see as mid-level management has become far more 19 responsive to their employees as opposed to simply ir 20 responsive to upper supervision. They're listening.

o

. 21 They're advocating for their employees. They're 1

= 22 supportive. I've seen mid-level managers stand up to E-l 23 their officers and directors and say, "I'm not going 24 back and telling my group that. I can't do that.

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120 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 That's not right. We can't do that." And so that has 2 led to a very healthy debate between mid and upper 3 management about what's the right thing to do, taking l 4 into account the workers' environment.

5 All of that said -- and this is what I 6 said yesterday -- this is a very tenuous situation.

7 It's tenuous because it didn't -- it didn't get sick l

8 over a short period of time and it's not going to get i 9 better over an immediate period of time.

j 10 And you could have a very few incidents,

$ 11 high-profile incidents, and you could be way back down 9

12 the mountain and have to climb it all over again. And '

l 13 because of that, it's very, very important that this l

14 company not take these positive recognitions as a pat 15 on the back that this fight is over. This is going to l l

16 take daily reinforcement and constant vigilance to 17 continue progress and to maintain the progress that l 18 this company has made. It's not going to continue

. 19 unless it gets the continued attention, ir 20 And so, although these things are very 0

, 21 positive and I think employees feel very positive, it's I= 22 now and not something that you can just turn the page 5

l 23 go on to other issues. Everybody, management, 24 employees in this room, managers in this room have all O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

)

l 121 MEETING RE: MILLSTONE-UNITS

() MARCH 4, 1998 1 got to continue to work at it. You've done a great job 2 and you should be congratulated. It's been tough. But 3 you've got to keep it up.

4 CHAIRPERSON LANNING: Yes?

5 A VOICE: Go, Mary, go.

6 MS. GARDE: Go, Mary.

7 MS. MARY KUHN: Mary Kuhn, Waterford. I 8 have had some thoughts similar to the previous speaker 9 about the tenuousness of the situation now and the fact 10 that it could be quickly lost.

R 11 It is encouraging and particularly 0

12 because of --

for instance, with this oversight 13 problem, the way that the -- would this be mid-14 management --

15 MS. GARDE: Right.

16 MS. KUHN: -- had really stood up in 17 that situation.

l 18 MS. GARDE: Correct,

i. 19 MS. KUEN: So some of the things that 20 you're seeing are encouraging. But I'm still very 0

.- 21 nervous because of the fact that this is a plant that's i

= 22 asking for restart very soon. Otherwise, I think that 1 5 l l 23 I would feel much better about the situation. l 24 Especially because even though they're improving, the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 I

122 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 unacceptable colors or slots are HIRD. So that's --

2 that's very worrisome.

3 And I guess I want to know, can you 4 understand my nervousness? And I know that you have 5 advice for the company. Does NRC, which -- you know, 6 your track record has not been so great in the past.

7 Do you -- are there any guarantees that you can give us 8 for protecting us? That is for -- for example, keeping 9 a consultant, you know, Little Harbor or someone like 10 them on indefinitely or longer than six months if ,

{

R 11 that's going to be needed?

0 gS 12 Ed Morgan, who is our big hope right

\) i 13 now, I think he's given us a lot of reason to hope. He I 14 has slots that are empty. Can you guarantee for us 15 that those will be filled? These are the questions 16 that I would ask. Do you have any other suggestions 17 for us for things that we can do to make us feel more l 18 comfortable?

I. 19 MR. McKEE: Okay. Let me try to address ir 20 that. Some of the issues -- I know we've talked about 0

. 21 this before and you've asked this question before. You

! 22 mentioned the six months. We did have --

for g

s l 23 continuation at least of Little Harbor. Let me just 24 explain that a little bit for some of the others out O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

123 MEETING RE: MILLSTONE UNITS

{} MARCH 4, 1998 1 here.

2 In our evaluation, you know, the NRC's 3 assessment plan, we identify and even the order 4 recognized that even following the restart of any of 5 the Millstone units that there would certainly be a 6 need to maintain third-party oversight of activities 7 just for the very reasons that you talked about as 8 concern that the programs could slide back or, you 9 know, wouldn't be maintained.

10 We put into that plan that there would g 11 be certainly a period and we put as just a starting 9

12 point estimate that we thought that that would be at 13 least six months, with identification that even l 14 following that six months there may be a need 15 periodically to have either Little Harbor or some other 16 oversight --

independent oversight organization come 17 back periodically to look at the program, i

l 18 Now, that's a determination that we'll 19 just have to look at the circumstances when we get to l

l f 20 that point of when. And the NRC is in a position by 0

. 21 the order to make the determination of when the I= 22 oversight can be terminated.

l 23 As another aspect -- and I mentioned 24 that before --

one of the points that we have O' POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

l

r 124 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 identified, again, for the very concern that you've 2 expressed, is that there is the development of -- by 3 the licensee of an extended plan. What are their 4 plans? How are they going to transfer or go into the l

l 5 longer-term organization? We know a lot of efforts and l

l 6 other things have been going on and happening. But how 7 is this going to work in the future as 'far as 8 maintaining ECP? How will Human Resources be 9 developed? How will they continue their l 10 investigations, provide the continued support of

'$ 11 investigators as they need them?

  • \

12 Now, there might be a need that they '

13 don't need as many investigators as time goes on in the l

14 line organization and other processes. Again, that j 15 remains to be seen. But the plan should address some 16 continued monitoring of the programs and how they plan 17 to continue monitoring. And that might include surveys j

'! 18 and other things that they're going to do, just to

l. 19 address that aspect.

!r 20 MS. KUHN: And you could guarantee that?

O

< 21. You see, part of my concern, too, is that when you run l= 22 up against tough questions, you say, "Well, there iE l 23 aren't enough of us." You know, et cetera, et cetera.

24 "And our resources are limited." You know. That O POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102

125

_ MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 concerns us.

2 MR. McKEE: Well, we can never guarantee 3 anything absolutely. But I can assure you that we're 4 going to look at that long plan and that will part of 5 our consideration.

6 MS. KUHN: I see.

7 MR. McKEE: Thank you.

8 Let's get somebody -- this gentleman in 9 the brown shirt.

10 MR. TONY PORTABONO: My name is

$ 11 Portabono. I work for Unit 3, Work Planning. My 1*

l 12 remarks are to you. I resent your --

i 13 DR. TRAVERS: Oh, wait a second. Could 14 you make remarks to us because we're --

15 MR. PORTABONO: My remarks -- )

I 16 DR. TRAVERS: We're not accepting '

17 comments to people in the audience. If you have a i l l 18 question or a comment to the people at the table,

. 19 please make it. If you don't --

ir 20 MR. PORTABONO: Okay.

O

, 21 DR. TRAVERS: -- let's move on.

I= 22 MR. PORTABONO: I resent this 5

l 23 gentleman's implied implications of some sort of 24 psychological conspiracy on my fellow co-workers to POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

126 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 mislead Little Harbor Consultants during the interview 2 process to arrive at any false conclusions.

3 DR. TPAVERS : Thank you.

4 MR. PORTABONO: Thank you.

5 MR. McKEE: The lady in the gray, the 6 gray sweatshirt please.

7 MS. LOIS BAILEY: My name is Lois Bailey I I

8 and I work with the Citizens Regulatory Commission. I 9 have a comment to direct to Little Harbor, to Mr. Beck 10 and Ms. Garde, particularly Ms. Garde. I'm very

$ 11 confused and highly disturbed by the very sharp

, 2 12 discrepancy that I hear between the systems of rating 13 that you have and the results on the Employee Concerns 14 Program.

15 Mr. Beck, you gave, presented a 16 presentation in which you had a 1 to 5 rating. You 17 gave a very -- a series of high scores that were in the l 18 4's or rose from last summer from 4.3 to 4.5 out of 5

i. 19 and gave an overall strong conclusion on your positive ir 20 conclusion on your views at the end of your O

, 21 presentation of the condition of the work force. You 1

22 say, "I think we have a strong work force."

l 23 Ms. Garde, subsequent to that, you used 24 -- particularly, you referred in your section to an A O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

127 MEETING RE: MILLSTONE UNITS .

MARCH 4, 1998 1 through F designation rating. Your results did not 2 accord with Mr. Beck's. And how do we trust you if 3 they don't agree?

4 You mention again and again that things 5 rose from an F to a D, which is hardly much of an l

6 improvement, particularly in HI&D, particularly when

! 7 you're dealing with nuclear power with its inherent l 8 tremendous dangers. And I'd like to know particularly 9 when your comment on che raising from an F to a D of 10 the HI&D section of the confidence in the company's lR! 11 ability to resolve those types of issues, it hasn't 12 risen much. And there were several other categories in

, 13 which that was also true.

l 14 So how do you make sense of this please?

15 MR. BECK: Okay. Let me take the first 16 part having to do with the structured interview 17 results. Those are not our numbers. Those are the l 18 numbers that represent what people said to us. All we 4

i. 19 did was add them up and divide by the number of people 20 interviewed. So it reflects the opinions of the work o

. 21 force at Millstone. How do they feel about the l

= 22 effectiveness of the Employee Concerns Program? Those I

l 23 are the kinds of questions. You can see exactly what 24 that is.

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128 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 All we served as were to ask the 2 questions and record the results and faithfully do the 3 calculations accurately and present them to you and the 4 company and the NRC.

5 Now, with regard to how we may have 6 utilized, in whole or in part, the- results of the 7 structured interviews to arrive at our judgments with 8 regard to where we said they are in the HIRD area, I'll 9 pass it to Billie.

10 MS. GARDE: First of all, let me say g 11 that I used the letters, the grading letters, really 9

12 simply because our computer didn't work. And so I l

i i 13 couldn't show on the screen the colors from green to l

14 red. That may have not been an accurate -- and it's 15 certainly not the way we talked about_it when we did 16 our consensus ratings. I simply did that to try to --

17 as an ease or a tool to understand that. Otherwise, l 18 I'm talking about all kinds of empty boxes and colors 19 that aren't there. If that was confusing, I apologize.

20 That said, I think what you're asking me O l

, 21 is if his ratings are so good, why are we -- why have 1 l

= 22 they just come from an F to a D in the area of HIRD -- .

l 5

l 23 MS. BAILEY: Yes.

24 MS. GARDE: -- and how do I rate that as POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l

\

l 129 MEETING RE: MILLSTONE UNITS

(]) MARCH 4, 1998 1 improvement. Is that what you're --

2 MS. BAILEY: Yes, that's basically it.

3 MS. GARDE: Okay. The windows or the 4 grades for the different categories are arrived at by 5 looking at the whole picture, all of the circumstances 6 that we are observing on a daily basis. And as you 7 know, they've been in the red -- that is the lowest 8 possible rating -- and not ready for restart in the 9 area of harassment, intimidation, retaliation and I

10 discrimination, which basically is a combination of the R 11 number of incidents that occur and how they're handled, i $ ,

12 That's basically what it is.

13 And over the last couple of months, we 14 felt there were too many incidents and they took too 15 long to respond to them, even though, I think for the 16 most part, they got to the right result. In the last 17 two to three weeks, we've seen growth in that area.

'$ 18 They've responded better. And when they had a very g 19 high profile incident that was very painful for the l 20 company as a whole, they ultimately took action which o

j . 21 held accountable the management involved, which

!= 22 directly addressed to the workforce and the community.

i l 23 They were honest about it. They put it out on the 24 street as soon as it happened. They promptly O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

130 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 t

1 investigated it and they took the right action. That !

2 was a very posicive thing which --

3 MS. BAILEY: In HI&D?

4 MS. GARDE: Yes. It was -- it was an 5 incident that would have fallen under that category. I 6 Other incidents -- and I haven't gone into all of the i I

7 details. That would take too long. And I'd be glad to l I

8 talk to you after the meeting or in private.

9 But other incidents, we have seen the !

l i

10 same thing. We've seen management start to anticipate '

$ 11 and prevent harassment and intimidation, plan for 2

12 transfers. When a supervisor wants to discipline 13 somebody or remove them, instead of executive 14 management just rubber-stamping that action, there's 15 meetings. We go to those meetings. At those meetings, 16 we see the right discussions and we see management 17 saying, "No. You don't -- you can't support that. And l 18 I'm not going to support that.

. 19 So we have seen growth. They're still f 20 under the line, not ready for restart. And that's what l0. 21 I said about being tenuous. We've just seen that in ll=

22 the last month. It could change tomorrow. I hope it E l l 23 doesn't. I hope a month from now I can give you more 24 examples. But it hasn't been sustained enough for us O l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102  !

I

131 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 to have the comfort level that it will continue with 2 the same growth rate. l 3 So we moved them up a notch in 4 recognition of their processes and the things they've 5 done. They're still below the line.

6 MS. BAILEY: If you'll pardon me, I-7 think you use euphemisms if you say there's been much

)

8 improvement between an F and a D. And I'm very upset 9 because you spent a great deal -- the most specific  ;

I 10 referrals you made to your study were made to the

$ 11 structured interviews with the 1 to 5 ratings. And 9

12 those were the ones that came out fairly positive, 13 perhaps, for all I know, as Peter Bowman mentioned, 14 because some of the questions as you mentioned them 15 were obviously almost rhetorical in that it would 16 prompt most workers to say, "Why, yes, of course I feel 17 free to raise concerns." Most workers would want to l 18 say yes. That's a positive thing to say yes.

l. 19 But the point is those results do not 20 accord with an F to a D. And my question is what kinds O

, 21 of indices and investigations specifically did you 1

= 22 engage in other than the structured interviews?

( l 23 Because if you raise them from an F to a D overall, 24 that means that it had to have been outside the O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

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132 MEETING RE: MILLSTONE UNITS

'( ) MARCH 4, 1998 1 structured interviews, which are mostly positive, that 2 you got that negative results. What were the nature of i

3 those investigations in detail outside of the 4 structured interviews? You haven't told us very much.

(

5 And where can we get a copy of all the reports that  !

6 you've got on what you've done other than the 7 structured interviews? Since that, obviously, had a 4

8 poor result. A D is hardly anything to boast about.

9 MR. McKEE: You have to --

10 MS. GARDE: Well --

P 11 MR. McKEE: I was going to say after the 6

12 response to that one, we're going to have to move on to 13 somebody else.

14 MS. GARDE: I gave you one example. And 15 there are more. We'll be glad to collect for you the 16 Little Harbor reports on other studies that we've done.

17 And I'll be glad to spend time with you either this l 18 evening or another day to go over those examples, if 19 you want to do that. And I'll be glad to do that.

f 20 MS. BAILEY: Okay. Thank you. But I o

. 21 don't see how we can really trust you if you seem to l

= 22 speak out of both sides of your mouth and say one time 5

l 23 they've made improvement, but they really haven't.

24 CHAIRPERSON LANNING: Okay. Thank you.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

133 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 One last --

2 MR. McKEE: Okay. I think we have time 3 for one last question. And I'm not trying to avoid 4 anybody. We're trying to get new people at least for 5 this first round. I might mention at the end of this 6 process, we're going to have an opportunity for 7 additional questions, this line of questions or on any 8 topic. So you'll have a second chance.

9 Yes, sir?

10 MR. RON McKEOWN: My name is Ron R 11 McKeown. I live here in Niantic. I just have a simple 12 question. I'm not a nuclear engineer. There's all 13 this talk about not trusting the NRC.

14 Could you tell us, those of us who are 15 in the public here, how many employees throughout the 16 nation you guys moni+> and watch or are responsible 17 for and how many nuclear facilities? I l 18 And people are talking about a lack of l

I- 19 trust here. You know, I just would like to say as an

!r 20 adjunct to that that my experience is for every one O

. 21 person that says they don't trust you, there's 500 that k=

22 do.

E

'l 23 But if you could just tell us more about 24 the NRC, I'd appreciate it.

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l 134 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 MS. BASSILAKIS: It's not really 1

2 pertinent.

3 MR. IMBRO: I think we -- the NRC, as 4 far as operating reactors, has over 100 facilities. I 5 think it's 109 or so that --

and some are, you know, 6 the Millstone units. There are also plants 7 decommissioning. We have another side of that, also.

8 There's all kinds of other licensees. So there are a 9 large number of facilities.

I 10 Employees? Employees are similar for g 11 the facilities -- there's -- you know, if you look at 9

12 the on-site employees and the backup and corporate 13 office, you're talking about many thousands of 14 employees.

15 And I think we'll just move on from l

16 that. We've got to get to the rest of our agenda.

17 And, Wayne, I think we'll move on to the next topic?

l 18 CHAIRPERSON LANNING: Yes.

I 19 MR. IMBRO: Thank you, Little Harbor.

7 20 CHAIRPERSON LANNING: The next agenda O

, 21 topic is -- results from the recent corrective action

! 22 inspection. And Mr. Jacque Durr will summarize that l 23 results.

24 MR. DURR: Thank you.

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135 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 It looks like everybody's leaving.

2 Probably standing, then.

I 3 There was an inspection performed by the 4 NRC. We characteristically called it 4-0-500, which is 1 5 the number of an inspection procedure. That inspection 6 procedure essentially describes the purpose, to 1 7 evaluate the effectiveness of licensee controls in 8 identifying, resolving and preventing issues that I 9 degrade the quality of-plant operationu or safety.

10 So the purpose of that was to look at 9 11 the licensee's Corrective Action Program. In 12 conjunction with that, we added some other facets, such 13 as management and management interactions and 14 communications with employees, self-assessments and 15 oversight groups.

16 There was a team of eight people for two 17 weeks on site. In the management area, we generally l 18 found that communications throughout the organization I. 19 were very good, both horizontally and vertically.

20 We found, though, that as far as a O

. 21 strategic plan and visions from upper management to l= 22 lower levels, that that had not been issued at the time I-l 23 of our inspection. We found that to be a weakness. We i

24 feel that at this point in the recovery of the process '

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i

l l

136 MEETING RE: MILLSTONE UNITS l MARCH 4, 1998 1 that management should have clearer communications of 2 their strategic oversight and long-term visions to the 3 employees.

4 We did find, though, similar to Little 5 Harbor Consultants, that management is receptive to l 6 problems brought forward by the employees. And we also l

l 7 found that they have a very good system of key l

8 performance indicators that they use to manage the 9 processes with.

10 We had two findings relative to the l

11 technical specifications. And these relate to Section 12 6 of the Technical Specifications, one of which was --

13 we found that the radiation protection manager reports 14 to the maintenance manager. And the technical 15 specifications specify that this be an independent 16 reporting process. And we felt that that was too close 17 to the people that he interacts with on a daily basis.

$ 18 And so we didn't believe that'that complied with the

i. 19 technical specification.

20 Likewise, we also found in Section 6 of e

. 21 the Technical Specifications there was a group called l

= 22 the Independent Safety Engineering Group. We call them E

l 23 I-S-E-G or ISEG. And their function is twofold. One 24 is tc look at operating experience from other

.O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

137 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 utilities, from NRC information notices and bulletins.

2 And it's also -- and to review those for applicability 3 to Millstone.

4 Their other function is to look at human 5 performance issues in the facility and to look at 6 activities in the facility and do independent audits of 7 those.

l l 8 We found that they were really not l

9 looking at the human performance aspects in an

! 10 independent role. The utility has human performance l$w 11 people that they bring in to the ISEG from time to time 12 to do that. But those people were essentially I 13 revie' wing their own work. So we didn't feel that that 14 was independent.

15 We also looked at some of the safety 16 conscious work environment. And as with Little Harbor 17 Consultants, we found that that was beginning to show

$ 18 signs of improvement. I would note, though, that that 19 observation needa to be integrated with a lot of other 20 things that are going on in that area. So we just made O

, 21 that observation.

!- 22 Corrective actions? We looked at the E.

l 23 Corrective Action Program. And if you looked at our 24 Restart Assessment Plan, corrective actions was one of O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l l

l 138

l. MEETING RE: MILLSTONE UNITS O. "^aca 4 1998 1 the big areas that we felt was -- had major problems l

back 2 in the early days of the recovery process. And i i

3 that's one of the main reasons why Millstone is still i l 4 shut down, is that they didn't have a good mechanism 5 for identifying, resolving safety issues and ensuring 6 that they did not recur.

7 We now l find that they have a very low <

8 threshold for the identification of problems. There is 9 a large number of what they call Condition Reports that l l

I

( 10 any employee can identify a problem and bring it to

]

lR 11 management's attention for resolution. So there's a b

12 very low threshold for the issuance of those.

13 There is a management review team that (

l 14 looks at all of those and dispositions them. And we l 15 found that the management review team was very i

16 effective.

17 We found several CR's that we had l

ll 18 problems with. It wasn't a perfectly clean inspection, 19 if you will. We did find some condition reports that ir 20 we felt that the licensee had not applied the lO

, 21 appropriate level of severity. They have Levels 1, 2 1 -

22 and 3. Level l's would require a root cause analysis i E

l 23 and more rigorous action. A Level 2 is less than that 24 and Level 3's were really kind of an enhancement. We POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 j

139 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 found that they had made some things Level 3's that 2 really should have been Level 2's.

3 Additionally, in root cause analysis, 4 they've shown substantial improvement in that area from 5 the mid-1996 time frame.

6 We did find, also, inappropriate closure 7 of CR's. And there were several of those. An example 8 of that, there were five of them that fell into that l

9 category. For example, tools to support emergency 10 operating procedures. Throughout the plant, they have

$ 11 tool boxes and special tools that are needed to support 9

12 emergency operating procedure activities. And those 13 tools were not controlled in a proper fashion and 14 inventoried regularly. And we found that to be a 15 problem.

16 We also found a problem with the boric 17 acid storage tank level and the fact that they had 18 changed that level inappropriately, which was less 7

19 conservative than their technical specification.

20 I would caution you that in the O

. 21 corrective action area what we've found is that we are l

= 22 beginning to see improvement, but there are other E

l 23 aspects of our ongoing inspections that we need to 24 bring in and integrate with this. For example, the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 L

(

140 MEETING RE: MILLSTONE UNITS O a^aca 4 1998 i l

1 Operating Safety Team Inspection, which'is due to occur  !

2 shortly after the plant goes to Mode 4, will look at 3 certain aspects of this. The Independent Corrective l 4 Action Verification Program is out looking at l l 1 5 corrective actions. That needs to be integrated. And,

! 6 certainly, we still have to close the issues in the i 7 Significant Items List.  !

8 So all of those things are additional 9 pieces that we will use to factor into our decision on 10 the Corrective Action Program.

$ 11 We looked at independent oversight. The 12 plant has by technical specification what's called a l 13 Nuclear Safety Assessment Board. This is upper-level 14 management and some independent contractors that review 15 plant operations and ask very pointed questions, if you 16 will, about how management has dispositioned things.

17 There is a Site Operating Review l 18 Committee which looks at site-wide procedures. And I. 19 then there's a Plant Operations Review Committee which Ir 20 reviews plant operations, approves critical procedures i O

. 21 and this sort of thing.

1

= 22 We looked at those and generally found E

l 23 that they are effective and working very well.

24 We found that the independent safety O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

141 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 engineering group was providing high-quality reviews.

2 We note that they're strained. There's only four 3 people by tech spec requirement in that group. They 4 went in -- they went over some 300 operating experience 5 reports last year. And they also, as I said before, 6 had this charter to look at plant activities. We found 7 that they had spent a lot of their time locking at 8 these operating events and their review, internal 9 audits of plant activities had dropped from 24 in 1996 10 to only 12 in 1997. And we made the observation that

$ 11 the management needs to take a look at the workload in d

12 that organization and make sure that it's equitably 13 distributed.

14 Nuclear oversight. This was another 15 one. Nuclear oversight, if you recall, back in the 16 early days was deemed to be ineffective. And that was 17 by several organizations, including joint utilities l 18 management audit that was performed several years ago.

7 19 We find that nuclear oversight is a much 9

l 20 stronger presence on site. They are providing O

. 21 meaningful reports to line management. They are really

!= 22 line management's conscience. In today's meeting, we 5

l 23 found that line management had made an assessment of 24 where they think they are relative to going to Mode 4.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

142 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 And nuclear oversight has a different opinion, which is 2 less positive than line management. And they're 3 reporting those things to line management.

4 Line management is recognizing that they 5 are giving them some good insights that they wouldn't 6 otherwise have the benefit of.

7 Lastly, we did Inspection Report 97-208, 8 I believe it is. It's the last inspection that we did.

9 And if anybody has any questions regarding that 10 inspection report, we'll be glad to answer those.

$ 11 So, with that, I'll turn it over to 12 questions and answers.

13 CHAIRPERSON LANNING: Does anybody have 14 any questions? Susan?

15 DR. TRAVERS: Would you like us to 16 arrange it so you can sit down there?

17 MS. PERRY LUXTON: It's not as l l 18 comfortable out here as it is in Waterford.

19 DR. TRAVERS: No, it's not. That's why 20 I asked.

O

, 21 MS. PERRY LUXTON: We get to sit down.

k=

22 We get to --

l 23 DR. TRAVERS: It's better --

24 MS. PERRY LUXTON: This is -- there's no O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

143 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1996 1 slides. This is like the Dark Ages.

1 2 Okay. Could we talk about tech specs?  !

3 You talked about tech specs a couple of times --

4 MR. DURR: Yes.

5 MS. PERRY LUXTON: -- in the inspection.

6 MR. DURR: Yes.

7 MS. PERRY LUXTON: Nc , this might not 8 fit in, but I think it does. They've asked for a lot 1

9 of amendments and tech spec changes. Now, who is 10 coordinating -- and then there's ICAVP walk-downs and

$ 11 stuff. Doesn't all this have to be coordinated so it d

12 fits in before restart? Like my question is, I guess, 13 how do you make these, you know, various pieces fit 14 together so you make sure that you know the different 15 tech specs or mods they've asked for and amendments?

16 And there are about 30 or 40 of them. Can you 17 elaborate on that?

'l 18 MR. DURR: Well, the -- it doesn't have 19 anything to do with what we're talking about. But let l 20 me try to answer your question.

O

, 21 MS. PERRY LUXTON: It doesn't?

l!

'E

= 22 MR. DURR: Well, not really.

l 23 MS. PERRY LUXTON: Okay.

24 MR. DURR: The tech spec amendments and

-') POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

144 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 changes that we're talking about go through the 2 licensing arm, nuclear reactor regulation, which is Mr.

3 McKee's area.

! 4 MS. PERRY LUXTON: Okay.

5 MR. DURR: Okay? Those are all 6 submitted and they go through a legal process down in-7 Washington.

8 MS. PERRY LUXTON: I know. But I mean 9 as far as hardware and stuff goes with the plant.

10 MR. DURR: Okay. Well, when it goes to lR' 11 the hardware in the plant, now you're talking about the 3 12 inspection staff.

l ,

13 MS. PERRY LUXTON: And isn't that what 14 you just did, though? You're talking about your

15 corrective action inspection?

16 MR. DURR: I'm sorry?

17 MS. PERRY LUXTON: Wasn't that what you l 18 were just talking about, your --

, . 19 MR. DURR: Yes. It was a finding in the i 20 corrective action inspection where we looked at Section O

, 21 6 of the Technical Specifications to verify -- there

!= 22 are certain requirements in there. One of them is that 5

l 23 the licensee had an independent safety engineering 24 group. And we verified that they, in fact, have that

,0 POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

145 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 group. Unit 3's technical specification. We verified 2 that they have that group. And then we found some t

l 3 difficulties with that they weren't implementing 4 verbatim compliance with that technical specification.

5 DR. TRAVERS: But -- if I can answer 6 very quickly your big question?

7 MS, PERRY LUXTON: Yes. Go ahead.

8 DR. TRAVERS: If I don't do a good job, 9 you can ask another question.

10 You asked in the interval where does it 11 R all come together --

(% 12 MS. PERRY LUXTON
Right.

1 13 DR. TRAVERS: -- at NRC. And basically, 14 in this room you're looking at the people who, from the 15 NRC staff side, are bringing it together in the context 16 of our restart assessment panel.

17 MS. PERRY LUXTON: Okay.

l 18 DR. TRAVERS: That ultimately, of I

19 course, goes to the Commission, as you know.

l 20 MS. PERRY LUXTON: Right. So the )

io  !

I

! , 21 restart assessment panel then will --

l

- 22 DR. TRAVERS: Integrate -- 1 5

l 23 MS. PERRY LUXTON: Okay. Integrate.

24 Okay.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

146 j MEETING RE: MILLSTONE UNITS l

(]) MARCH 4, 1998 1 Now, we're talking about the Corrective 2 Action Program. I need to clarify a couple of things.

3 You talk so fast, Mr. Durr. And you can't ask 4 questions while you're talking. So when -- you said 5 the Level 3's, there were a couple of Level 3's that )

l 6 should have been Level 2's.

1 7 MR. DURR: Yes.

! 8 MS. PERRY LUXTON: Okay. Now, that was 9 in NU's deciding when they disposition this what i

! 10 significance level it was?

l l

$ 11 MR. DURR: Yes.

2 12 MS. PERRY LUXTON: Okay. Has this 13 always been an ongoing problem with them? Did they --

l 14 or is this something that they're improving on?

15 MR. DURR: Well, I think --

16 MS. PERRY LUXTON: Go ahead.

( 17 MR. DURR: Yes. The significance of l 18 that in these particular cases, I think that they were 19 really low-level things and they're judgment calls.

20 MS. PERRY LUXTGN: Mm-hmm.

lI G

. 21 MR. DURR: And if you look at their b -

22 criteria, they're screening criteria. And when they go I

l 23 to this panel,there's a set of screening criteria that 24 they put these through. For instance, things that they O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i

147 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 would consider enhancements to the plant are Level 3's.

2 Things that are minor safety significance are Level 3 2's. And things that are significant are Level l's.

4 Okay?

5 So when they categorize certain things -

l 6 - and let me give you an example. There were some NRC 7 commitments that we found that they had categorized as l

8 Level 3's. We believe those should have been Level 2's 9 by their own criteria.

10 MS. PERRY LUXTON: Okay. Well, I just lg 11 thought that was something that they've had a problem i 2 12 with.

I 13 MR. DURR: Yes. it's not like they 14 weren't going to do anything. It's just that they l 15 hadn't categorized it at a significance level that they 16 should have within their own process, as far as we're 17 concerned.

l 18 MS. PERRY LUXTON: Okay.

7 19 MR. DURR: But it doesn't mean that the 1 20 process is, quote, broken.

r o

. 21 MS. PERRY LUXTON: Okay. And this 1

l

- 22 inspection report says -- the one you just talked

!l5 l

23 about,97-208 --

24 MR. DURR: Yes?

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

l 148 MEETING RE: MILLSTONE UNITS

()

l MARCH 4, 1998 1 MS. PERRY LUXTON: It says Unit 3 --

2 however -- it says " Review of the SIL closure packages i 3 continues to confirm a deliberate and gradually 4 comprehensive approach on the part of your staff to l

5 complete and validate the effectiveness of corrective l 6 measures. However, we remain concerned that several 7 procedures still require revision and that personnel 8 training, particularly where licensed operators has 9 been delayed by the completion of plant mods" -- now, 1

10 we had -- we talked about this once before. Are they

$ 11 going to be trained to these new mods? Okay?

0 12 " Procedural changes and other program 13 enhancements still in progress. We note that SIL items 14 remain open in areas of procedure adequacy, fire 15 protection, operator training and overall corrective l 16 action effectiveness."

17 MR. DURR: Yes.

! 18 MS. PERRY LUXTON: Okay. Well, about i -

I 19 the -- the first thing I want to talk about there is 9

l l 20 the procedure upgrades, the revising of procedures.

O

. 21 Okay? Now, they've been revising a lot of procedures

!= 22 over the last year or whatever. Right?

5 l 23 MR. DURR: Mm-hmm.

24 MS. PERRY LUXTON: Are you checking the O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

I l 1

i

)

MEETING RE: MILLSTONE UNITS

(")

MARCH 4, 1998 1 revision of those procedures, the hundreds and 2 thousands of procedures they're doing?

3 MR. DURR: We're checking some of them.

4 MS. PERRY LUXTON: Okay.

5 MR. DURR: Not all of them.

l 6 MS. PERRY LUXTON: All right.

l 1

7 MR. DURR: But some of them. We're j i

8 doing audits of that process, yes. l 9 MS. PERRY LUXTON: And how is that 10 working out? l l

l9 11 MR. DURR: Right now -- what we have l

,r') 12 been looking at in the past has been -- there was the

'w/

13 Procedure Upgrade Program.

14 MS. PERRY LUXTON: Right. PUP.

15 MR. DURR: Right. PUP. And we've i 16 looked.,qt that and that's essentially complete. That's 17 one of the things that got -- if you look at our l 18 Restart Assessment Plant, that's what got procedures in l

. 19 there was the PUP. They had back in the early 90's --

1 20 MS. PERRY LUXTON: Right.

r O

, 21 MR. DURR: -- said "We're going to fix 8

= 22 all these procedures." Well, guess what? They're just 5

l 23 finishing them now. So we were holding their feet to l 24 the fire to finish that thing. They just couldn't go

()

POST REPORTING SERVICE (800) 262-4102 HAMDEN, CT

l l

150 l MEETING RE: MILLSTONE UNITS

(} MARCH 4, 1998 1

{

i on ad nauseam with that.

]

i l

2 We've also looked at some --

3 MS. PERRY LUXTON: So that's -- that's 4 finished?

5 MR. DURR: For all intents and purposes, i

l 6 that's very close to being finished, yes.

! 7 MS. PERRY LUXTON: Okay.

l 8 MR. DURR: And it should be before they i 9 restart, if it isn't already done. We haven't looked l 10 at it within the last several months that specifically.

11 MS. PERRY LUXTON:

l It's not a condition 12 of restart, is it?

13 MR. DURR: Yes.

14 MS. PERRY LUXTON: It is?

15 MR. DURR: Yes. They're --

16 MS. PERRY LUXTON: Because that's on the l

17 Restart Assessment --

l 18 MR. DURR: They're going to -- yes.

i 4-

'l 19 That's in the Restart Assessment Plan.

Ir 20 MS. PERRY LUXTON: Okay.

O l . 21 DR. TRAVERS: Thanks.

!= 22 MS. PERRY LUXTON: Thanks.

l 23 MR. DURR: Thank you.

24 DR. TRAVERS: Any other questions on the O POST REPORTING SERVICE l

HAMDEN, CT (800) 262-4102

i l 151 i MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 inspection reports? Okay. We'll go into the -- I'm i'

2 sorry?

l 3 A VOICE: A question back here in the 1

l 4 corner.

l l

l 5 MR. JOE NAZAR: Just a brief one.

6 DR. TRAVERS: Can you come down to the 7 front please? We know you hate to that,.but --

8 MR. NAZAR: In regards to the Condition 9 Reports that you're talking about, the ones where you

! 10 had found the problem where Millstone had perhaps been

,g 11 too lenient in grading it, that would have been on the e _

12 order of something like half a dozen, I'm gathering, or )

13 --

14 MR. DURR: No, it wasn't that many.

l 15 There were only like three or four that we found that t

, 16 were in that shape.

I 17 MR. NAZAR: Okay. The reason I ask is 1 Il 18 to put that into a context. I gather in 1997, a rough 19 estimate on my part is something like over 3,000 f

O 20 Condition Reports were, in fact, written.

, ,_ 21 MR. DURR: I think it's more like six.

'!- But -- 6,000 in 1997.

22 Yes.

5 l 23 CHAIRPERSON LANNING: What was the 24 sample size?

O POST REPORTING SERVICE RAMDEN, CT (800) 262-4102

l I

l 152 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 DR. TRAVERS: What was the sample size?

2 MR. DURR: And our sample size was 3 probably in the neighborhood of 100.

4 MR. NAZAR: Okay. So, as I think even 5 as you had said, in the bigger scheme of things it's 6 unfortunate to see that, but it's not an overwhelming l 7 thing, j 8 MR. DURR: Exactly. That's what I'm 9 saying. It was a completely clean inspection. We did 10 have findings.

l 11 MR. NAZAR: Okay. And perhaps to over-l0@

12 clarify, but the levels you talked about in the 13 Condition Reports have nothing to do with the levels of i

14 the DR's.

! 15 MR. DURR: That's correct. A totally 16 separate system.

17 MR. NAZAR: Okay.

l 18 CHAIRPERSON LANNING: Thank you.

19 MS. NORTON: I seem to recall from the 20 summer --

l 0 l

. 21 CHAIRPERSON LANNING: Name please?

!= 22 MS. NORTON: Karen Norton. I seem to 5

l 23 recall from the summer that you were saying that you 24 were sampling about two percent of all the -- I'm l

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l

I l l

l l

153 MEETING RE: MILLSTONE UNITS l () MARCH 4, 1998 i

f 1 blanking on the word. But all the components, all the 2 -- help me. Hmm?

l 3 A VOICE: Systems?

4 MS. NORTON: Systems. Thank you. And 5 what I gather is that -- and this is where I'm so very i l 6 confused because I recall that you said that you had 7 settled on that small amount of sample because it was ,

! 8 do-able. And this could be my memory, but it -- that 4 j 9 that was do-able. The sample size that you had chosen 10 was do-able. And you absolutely guaranteed that all

($

\0 11 those aspects would be reviewed.

12 There were many systems that weren't 13 being reviewed. But the ones that you were sampling 14 would all be reviewed and all be okayed before restart.

15 And it doesn't sound like we're at that point yet.

16 And, yet, it sounds like now you're saying that it's l

l 17 okay; we can go on to restart anyway.

'l 18 DR. TRAVERS: I think, if I'm reading lh . 19 your question correctly, that you may be referring to 20 discussions we've had in the past about the ICAVP

! o

, , 21 program and the sample size, specifically the number of l1 = 22 systems that the ICAVP is looking at in detail. And of l 23 80-- 85 or 88? Of 85 systems, that ICAVP effort is, at 24 least in Tier 1, looking at 15 of those 88 systems.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l 154 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 l

1 Many more systems are being examined in less detail.

2 But in great detail, 15 of those 88 are being examined. ,

l 3 We are sampling in many other areas, l

\

4 including corrective actions and the effectiveness of 5 corrective actions outside of the ICAVP effort. So 6 much of what you're hearing tonight in terms of i

7 inspection report findings on this side of the table 1 8 have to do with related but separable issues of l

9 different sample sizes of different things. l l

10 But the bottom line is we're trying to I g 11 gather a level of confidence in all of the programs to 9

- 12 address each of the restart items that we've laid out 7]

(>

13 in our Restart Assessment Plan before we go to the 14 Commission with a recommendation. So all of those 15 issues, from our perspective, have to be addressed 16 adequately, closed out, before we're going to go to the 17 Commission and argue that this plant is ready for i 18 restart.

i

. 19 MS. NORTON: Have you changed your 20 standard since last summer or whenever?

21 DR. TRAVERS: No.

B

= 22 MS. NORTON: I mean have you -- you 5

l 23 don't feel that you have?

24 DR. TRAVERS: I know we haven't.

l POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l 155 MEETING RE: MILLSTONE UNITS

() MARCH 4, 1998 1 MS. NORTON: That's reassuring.

2 DR. TRAVERS: Okay..

3 CHAIRPERSON LANNING: All right. We're 4 now in the general question-and-answer session. So are 5 there questions on any topic? And we'll stick to the 6 five-minute session.

l l .7 Yes, Ma'am.

l 8 MS. BURTON: Hello. Nancy Burton again.

l 9 Dr. Travers, do you have a date for restart?

10 DR. TRAVERS: No.

l$9 11 MS. BURTON: No anticipated date for 1 12 submitting a recommendation to the NRC?

13 DR. TRAVERS: No.

14 MS. BURTON: I wonder if Billie Garde is

[ 15 still here --

16 MS. GARDE: Yes.

17 MS. BURTON: --

because I have l

ll 18 _ questions.

19 DR. TRAVERS: Yes, they are. Little 20 Harbor is still here.

O

, 21 MS. BURTON: Because I had a few

,=

I 22 questions about that presentation.

l5 l 23 DR. TRAVERS: I'll slide down. We're --

24 just for your information, we're still trying to cycle O POST REPORTING SERVICE j HAMDEN, CT (800) 262-4102 i

156 MEETING RE: MILLSTONE UNITS '

MARCH 4, 1998

( 1 through the audience in five-minute -- 2 MS. BURTON: I understand. 3 DR. TRAVERS: That's fine. l 4 MS. BURTON: I hope you didn't count i 5 that motion -- 6 DR. TRAVERS: Not at all. 7 MS. BURTON: Okay. Thank you. 8 DR. TRAVERS: But it is a confused -- 9 it's kind of confusing the first time. 1 l 10 MS. BURTON: Well, I tried it before. Q 11 Okay. l 12 DR. TRAVERS: Yes. 13 MS. BURTON: I wonder if in your survey 14 you spoke with George Galatis? l l 15 MS. GARDE: No. 16 MS. BURTON: Well, I wonder if you 17 recently read an article that appeared prominently in l 18 the New London Day -- 19 MS. GARDE: Yes, f 20 MS. BURTON: -- about Mr. -- you did O

  ,     21 read it.

kn 22 Did you read it, Mr. Beck? 5 l 23 MR. BECK: Sure. I 24 MS. BURTON: I think in that article -- I POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

157 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 I don't have it with me. But I recall reading 2 something to the effect that Mr. Galatis thought that 3 it was essential before there be any serious 4 consideration to restarting these plants that some 120 5 members of the management staff of NU be discharged. 6 MS. GARDE: I saw that statement that he 7 made, yes. 8 MS. BURTON: Now, I wonder if you have 9 done anything to go about interviewing any -- well, let 10 me go back. Have you reconsidered talking to Mr. i$$ 11 Galatis? 12 MS. GARDE: Well, it wasn't our decision 13 not to talk to Mr. Galatis. I wanted to talk to Mr. 14 Galatis. It was his decision not to talk to us, one 15 which I tried to get him to reconsider a couple of l 16 times. But ultimately it was his decision not to speak l 17 to us and I respect that decision. l 18 MS. BURTON: Have you spoken -- tried to I. 19 speak with him since the article came out in the New 20 London Day? O

 ,    21                  MS. GARDE:   No. But I've talked to his

!i= 22 lawyer. 5 l 23 MS. BURTON: Since the article came out 24 in the New London -- O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l f I- 158 l MEETING RE: MILLSTONE UNITS l O "^aca 4 1998 1 MS. GARDE: His lawyer and I went to law 2 school together. Juld I have a good relationship with' 3 him. And I have spoken to him since the day it came 4 out, i l 5 MS. BURTON: Since the article came out? 6 MS. GARDE: Yes. ! 7 MS. BURTON: I wonder if you could tell ! 8 me if you interviewed other whistleblowers who were 9 discharged unfairly and illegally by NU as part of your l 10 study? g 11 A VOICE: We want to be precise. 12 MS. GARDE: Yes. The structured 13 interviews are only of current employees, measuring j 14 current work environment. So we would not have talked 15 to former employees in that study. That said, when we i i 16 began our -- when Little Harbor began our work, we j 17 collected all of the written information, cases, l 18 decisions,' briefs on all of the employees who had filed 19 whistleblower complaints both in State, Federal or 20 administrative courts. I read all those files and

  ^O
   ,     21 attempted to interview all of them.
     !-  22                  I   think-there's       only four,    other than l  23 Mr. Galatis, who either I couldn't find or was not able           ;

24 to interview because they aren't in the area any POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l-

l l 1 159 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 longer. 2 All of that data went into the 3 development of Little Harbor's plan of how we were 4 going to assess and review the work environment. And 5 I've kept contact with a good number of those 6 employees. 7 MS. GARDE: Did those employees include 8 Mr. John Delcore? 9 MS. GARDE: John Delcore is one of the l 10 people I have not talked to. He's one of the four. g 11 MS. BURTON: Do you know where he's 9 12 located? 13 MS. GARDE: Here. 14 MS. BURTON: Where? 15 MS. GARDE: I don't know where 16 physically. But he's located in the area.  ! 17 MS. BURTON: But you were not able to 'l 18 make contact with him? 19 MS. GARDE: He and I had a meeting set f 20 up on one occasion which was cancelled because of his 21 family problem. Since that time, my invitation is -- !l- 22 we have not yet connected. I have not tried to connect l 23 with him since getting back from the holidays. 24 MS. BURTON: Have you contacted Mr. Pete O POST REPORTING SERVICE RAMDEN, CT (800) 262-4102

1 1 1 160 j MEETING RE: MILLSTONE UNITS I () MARCH 4, 1998 1 Reynolds? 2 MS. GARDE: Yes. I've had lengthy l l 3 discussions with Mr. Pete Reynolds. I 4 MS. BURTON: Have you had discussions ' 5 with Mr. Tim O'Sullivan? 6 MS. GARDE: Some discussions with Tim l i 7 O'Sullivan.  ! 8 DR. TRAVERS: Is this -- 9 MS. GARDE: I don't know. 10 DR. TRAVERS: Is this relevant? I mean lR 11 -- 1" 8 12 MS. GARDE: I think what you want to 1 13 know is do we know the past histories of people who 14 have gone through experiences at Millstone. So -- i 15 MS. BURTON: No. 16 MS. GARDE: Okay. Well -- i 17 MS. BURTON: No. My question is this.  ; l 18 I would like to know what you have done as part of your i 19 investigation as to what retaliation and harassment is 20 continuing against people who were illegally discharged O

  ,    21 from their jobs at Millstone.

1

  -    22                 MS. GARDE:    Little Harbor --

5' l 23 MS. BURTON: Can you answer that 24 question? O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l l 1 l ! 161 l l MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 MS. GARDE: Yes, I can. 2 MS. BURTON: Is that part of your study, 3 investigating current harassment of former illegally l 4 discharged employees? I 5 MS. GARDE: If those current allegations 6 -- if the allegations of current harassment have been j 7 given to the Employee Concerns Program -- and some 8 have. And those files have been opened -- we have 9 reviewed and included how those issues have been 10 resolved. And that has included some former employees.

 $     11                  We   have  not   independently     undertaken 6

12 investigations nor am I aware of investigations -- of (~)

   %.)

13 current harassment of former employees outside of 14 either what's reported in the newspaper or what's come 15 in through an ECP file. 16 MS. BURTON: Have you ever asked or 17 independently sought to determine if there is l 18 continuing harassment of these people?

 . 19                  MS. GARDE:     Every   person I talk    to, I  l f     20 ask   that question of. Every person I     talk to, I ask O
 ,     21 the   question,   "Are   there   current   effects    of   past 1
 -     22 retaliatory    conduct?    And   is there    current   actions 5

23 continuing?" And got an answer from every person I ll l 24 talked to. POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

162 [ MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 MS. BURTON: Have you investigated the l 2 officials at Northeast Utilities who were warned l 3 officially by the United States Labor Department some 4 six months after Mr. Delcore's decision was issued by 5 the Second Circuit Court of Appeals concerning his 6 illegal discharge? 7 MS. GARDE: I mean I'm familiar with the 8 decision. I know what the factors are. I'm not -- we 9 did not undertake an independent investigation nor do I 10 think we -- that was within our charter, of those past g 11 activities unless those past activities were raised as d gg 12 having a current effect. And those issues, to the ( ,/ 13 extent that they are captured, we did look at. 14 MS. BURTON: Well, then I would suggest 15 that it would seem that your mandate is far too limited 16 and very, very far less than what I heard Dr. Shirley 17 Jackson say had to be the mandate of this entire l 18 process, which was to be very comprehensive. 19 MS. GARDE: Okay. Let me -- 20 MS. BURTON: I really --

 $     21                  DR. TRAVERS:     And that will be the last.

1

 -     22                  MS. BURTON:     I just have a couple.

l 23 DR. TRAVERS: Yes. You can come back. 24 But we've been over five minutes. So let her -- r-

  \~                         FOST REPORTING SERVICE HAMDEN, CT     (800) 262-4102

1 163 . MEETING RE: MILLSTONE UNITS MARCH 4, 1998 l l 1 MS. BURTON: .May I come back? 2 DR. TRAVERS: Let her answer and please 3 come back. We want to go through the audience and be 4 fair. 5 MS. GARDE: Yes. Let me respond to 6 that. Little Harbor was not here to determine whether j 7 or not justice was done or whether or not people were 8 unfairly terminated in the past. That's not our job. l 9 We were not a war crime tribunal. 10 That said, the factors that went into j i jg 11 deciding how Little Harbor wrote their charter 12 absolutely included a review. And I spent countless . 13 hours doing a review of all the past cases and those -- 14 that information was factored into what we're doing. 15 In the event I heard "Yes, there's a l 16 current event", that got referred to the ECP. ECP did l 17 an investigation and we reviewed it. And those !l 18 included some of the past practices, some of the past 19 events. And that's why you've seen some changes. f 20 MS. BURTON: Please don't go out the !o. 21 back. B 22

 =                       DR. TRAVERS:    Any other questions in the 5

23 miscellaneous Millstone-related topics of discussion? 24 Questions? Please. O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

i l 164 MEETING RE: MILLSTONE UNITS (} MARCH 4, 1998 l l 1 MR. BOWMAN: Peter Bowman. It's more of 2 a clarification, I guess. Going back to earlier, we 3 were talking about Level 4 Discrepancy Reports. And 4 someone said there were discrepancies between the logic 5 diagram and the schematic diagram. What I've been 6 thinking about -- somewhere between the logic and the 7 schematic, originally there was a design -- let's say, 8 for instance, it was a relay that was in question. 9 There is a designer who selected a relay and the 10 draftsman or whoever has put it onto the schematic and g 11 then drawn the logic. And then in actual fact someone d 12 has come along and placed the relay in place wherever bs 13 it goes. So there's these four stages, the design, the 14 schematic, the logic and the placement of the component 15 in the circuit. 16 Now, what you said was that you're going 17 to put off these discrepancies possibly until after the l 1 l 18 plant starts. What I'd like to know is -- from what I ) it li 19 know, there are many thousands of discrepancies like 20 this and they're going to take time to resolve these. ,O

  ,   21 What   kind    of time     frame    do  you    expect that    these l l$
  -   22 discrepancies     will be      resolved?     I    mean before   the l l   23 license expires on this?          Or do you have some      kind of 24 time frame, six months or a year?

O V POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 L

165 MEETING RE: MILLSTONE UNITS (} MARCH 4, 1998 1 MR. IMBRO: I -- yes. Let me try and 2 respond to that. First you have to recognize that 3 these discrepancies are not anything that's operations 4 critical. They're not -- they're not things that are 5 in conflict with -- 6 A VOICE: Could you define operations 7 I critical? i 8 MR. IMBRO: Operations critical are  ! l 9 things that are relied upon by the operatore to operate ] 10 the plant, to make quick decisions in case of any kind g 11 of an emergency. So those would be things like single )j a \

 }e3   12    line          electrical   diagrams,    piping
  %-)

diagrams, et ) 13 cetera. And so -- but the kind of things we're talking 14 about here are things that -- the logic diagrams, for 15 the most part, are historical documents anyway. So the 16 people would not be relying on those to make operating 17 decisions that affect the safety of the plant.

 $     18                       That said,   what we need to     -- what has I
 !     19    to   be done, though, even though -- even though -- and, 20    again,     as   I said   before, these    do represent    -- you O                                                                             l
 ,     21    know, they      represent errors or inconsistencies.        So I 1           mean the licensee, when faced with this
 -     22                                                     inconsistency, i

l5l 23 needs to decide " hell, which is the right diagram? Is 24 the logic right or the schematic right?" And then they h~# POST REPORTING SERVICE RAMDEN, CT (800) 262-4102 I I L_____

166 MEETING RE: MILLSTONE UNITS ] MARCH 4, 1998 1 need to correct that. But they also need to make sure 1 2 that the plant matches that as well. 3 Now, if -- if in doing that, that 4 reconciliation, if you will, they find that this is not 1

                                  ~

5 a trivial error but it could really affect the plant 6 operation, then those would be things that they would 7 do before restart. 8 MR. BOWMAN: That's right. 9 MR. IMBRO: Okay. So what we're talking 10 about are the things that are deferred are those things

    $  11 that really don't -- don't affect the safe operation of 9

12 the plant, don't put the plant in a non-compliance 13 condition with their licensing basis. I 14 MR. BOWMAN: Now, then -- 15 MR, IMBRO: And you asked about how -- 16 how long it's going to take to resolve these issues. 17 And, as I said, the licensee has committed that they l l 18 would resolve all these issues before the next

 .. 19 refueling   outage, which        would be    essentially a   year f  20 after they're allowed to restart, whenever that is.

l 'O j , 21 MR. BOWMAN: Okay. Well, what you're

    -  22 saying is   some of    these deferred        items, we   may find E

l 23 down the road that they do become significant -- 24 MR. IMBRO: No, no, no. They make that O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

167 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 f] 1 -- that determination is made before the plant starts 2 up. 3 MR. BOWMAN: Okay. 4 MR. IMBRO: That deter-- the 5 determination of significance is made before the plant 6 starts. 7 MR. BOWMAN: Well, you've got 100 -- you 8 said you had 100,000 drawings to go through. I mean 9 this is -- 10 MR. IMBRO: Well, but there's -- yes. tg 11 But all 100,000 drawings are not affected. I mean 12 we're only talking about a handful, literally, I mean 13 relatively speaking of these drawings that there are, 14 you know, discrepancies against them. 15 MR. BOWMAN: But they all will be 16 examined before the start-up? 17 MR. IMBRO: They will be examined before l ll 18 the start to assess whether or not they're truly not 19 safety significant. And if the determination is that 20 they're not safety significant and will not affect safe 21 plant operation, then those can be deferred until after 1 22

  =       the plant restarts.

5 l 23 MR. BOWMAN: I guess I didn't ask the 24 right question. How long will it take to examine these O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 u___

168 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 prized data? I mean there's a time frame and --

     -2                  MR. IMBRO:     It   doesn't -- you     know, I 3 don't   know. It   will take as    long -- I     mean I can't 4 really answer that.      It. will take as long as it takes.

5 I mean the plant's not going to start up until these 6 things are -- I mean until all these types of questions t 7 relating to safe operation are resolved. Then once 8 they're resolved, then there's some logical basis to 9 say that these things can be deferred post-restart 10 because they've already made the determination that g 11 they' re not safet.y significant. 2 l l-12 DR. TRAVERS: That's one reason I didn't i 13 have a restart date. I mean it's going to take what it ' 14 takes for us -- for them to complete their actions -- 15 MR. BOWMAN: So when NU is talking about l 16 April 1, we can take that with a grain of salt because 17 it doesn't appear, to me, you know, that you could, I

J 18 looking at all these issues in that short a period --

19 DR. TRAVERS: We're just going to give f 20 you our perspective. And it's the one we've just 0 i

  ,  21 described. And that is   we have a    plan, an approach.     .

I 22 We've identified the issues. And we are going to g 5 l 23 ensure that the issues are closed before restart. 24 MR. BOWMAN: All right. Thank you. O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

169 MEETING RE: MILLSTONE UNITS i MARCH 4, 1998 1 CHAIRPERSON LANNING: Susan? 2 MS. PERRY LUXTON: I'd like to talk for 3 a moment about the oversight situation that happened. 4 If the NRC was concerned about the intent of the memo, 5 why didn't it begin an immediate -- why didn't OI begin 6 an immediate investigation? 7 DR. TRAVERS: We, as we often do, don't 8 speak about investigations. But I'll tell -- I'll give 9 you an answer, that we believe that based on what 10 occurred and our knowledge it, the letter that $ 11 requested, demanded -- it's a demand for information in d

 ,    12 the most legal sense.

(q_) 13 MS. PERRY LUXTON: Right. I saw that. 14 DR. TRAVERS: Was -- was exactly the 15 appropriate response in a regulatory sense. But we 16 don't -- we don't talk about investigation that either 17 are or could be under way. So --  ; l 18 MS. PERRY LUXTON: So you're not telling 19 me if there is an investigation under way. Because 20 that letter asked NU to provide information to the NRC. O , 21 DR. TRAVERS: Well -- != 22 MS. PERRY LUXTON: I'm saying it -- why l 23 didn't you start an investigation? 24 DR. TRAVERS: As we often do -- even, O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

i 170 l MEETING RE: MILLSTONE UNITS (} MARCH 4, 1998 1 you know, whether we did or we didn't, I'm not going to 2 address. But we have to do when we make judgments of 3 this sort is we have to prioritize our resources with l 4 'an understanding of a lot of information, including the 5 fact that this licensee indicated that they were hiring i 6 an outside investigator to assess the issue. 7 Very often when that's the case, not 8 always, but very often when that's the case, if we know l l 9 and demand information, we get that information and we 10 decide if we need to do something more. It's just a 'g 11 matter of weighing the significance of the issues as we 9 12 understand them against the priorities that we have and 13 the resources we have to bring to bear on the issue. l l 14 MS. PERRY LUXTON: Okay. l 15 DR. TRAVERS: Could I answer something l 16 that I don't think I did a very good job of earlier? l 17 And that is the question of the USQ -- l 18 MS. PERRY LUXTON: US-what? l 19 DR. TRAVERS: Q. Unresolved safety 20 questions. f 21 MS. PERRY LUXTON: I was going to get to 1

 -   22    that.

5 l 23 DR. TRAVERS: Were you going to get to 24 that later? POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

171 MEETING RE: MILLSTONE UNITS s. MARCH 4, 1998 1 MS. PERRY LUXTON: That was going to be 2 one of my questions. 3 DR. TRAVERS: Okay. Then let me -- let 4 me hold off because we can go -- 5 MS. PERRY LUXTON: Okay. 6 DR. TRAVERS: We can go -- 7 MS. PERRY LUXTON: Yes. Hold off, 8 because I'm on a roll. I have something I want to talk 9 about.  ! 10 DR. TRAVERS: Okay. g 11 MS. PERRY LUXTON: Now, so the answer to 2 g- 12 my question was -- I was disappointed in that answer. (>g 13 But that's okay. Now -- okay. I'd like to know -- 14 NRC's statistics show that there are -- I think you've 15 told us there are about 20 open allegations of NRC. I 16 would like to know at Millstone now how many open 17 allegations are there? You're shaking your head no, I l 18 Mr., Lanning. 19 CHAIRPERSON LANNING: About 50. 20 MS. PERRY LUXTON: There's not 20? !o i l, 21 CHAIRPERSON LANNING: About 50.

                                                                           ]

'I- 22 MS. PERRY LUXTON: 5-0? i 5 I l 23 CHAIRPERSON LANNING: Yes. j 24 MS, PERRY LUXTON: 50. All right. Can POST REPORTING SERVICE [ HAMDEN, CT (800) 262-4102 i 1

i 172 ' MEETING RE: MILLSTONE UNITS O "^ac" 4' 1998 1 we know the subject matter of those investigations? 2 CHAIRPERSON LANNING: No, Ma'am. 3 MS. PERRY LUXTON: Do you know the l 4 subject matter? l l 5 CHAIRPERSON LANNING: Yes, Ma'am. We l l 6 don't talk about the subject matter or the sources or l l 7 our actions concerning allegations until -- i l 8 MS, PERRY LUXTON: Until when? l 9 CHAIRPERSON LANNING: Until after it's j 10 finished and closed and the alleger tells you himself. !g 11 MS. PERRY LUXTON: Okay. My concern l$ 12 with that is maybe there is some -- when are they going 13 to get closed by? Are they going to be closed before 14 start? Because maybe there's some allegations to the 15 NRC that directly impact what -- you know, the status l 16 of the physical condition or whatever of the plant at j 17 this point in time. And it seems like it would be wise

i 18 for you to close those up before -- you're shaking your 19 head --

20 CHAIRPERSON LANNING: Yes. That's why 0

 .. 21 it's on   our Significant    Items List.      We're going     to b

22 review all of the outstanding allegations prior to l 23 restart to do just exactly what you're asking; to make 24 sure that there's no issue there that bears on restart. POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 (

I l 1 173 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 They should be addressed first. 2 MS. PERRY LUXTON: Okay. You're going 3 to tell us what it is? 4 DR. TRAVERS: But to finish -- 5 MS. PERRY LUXTON: You're not -- 6 DR. TRAVERS: -- finish your comment -- 7 MS. PERRY LUXTON: Okay. 8 DR. TRAVERS: -- what that does is it l 9 weighs where we are in the process. It means that the 10 process may not be completed, but we're going to make a 11 deliberate decision about where we are in the process,

 ~

12 what the issue is and what its nexus, if any, might be O 13 to restart. It doesn't mean the process will be 14 completed before restart. You didn't mean to imply l 15 that. 16 MS. PERRY LUXTON: But the public 17 doesn't get to know the subject matter of any of those? l 18 CHAIRPERSON LANNING: No. 19 MS. PERRY LUXTON: Why? Why not? 20 CHAIRPERSON LANNING: It's -- well -- 21 MS. PERRY LUXTON: I'm not saying i 22 confidentiality. I'm not saying names. l 23 CHAIRPERSON LANNING: Well, it's really 24 based -- that's the basis of it. O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

174 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 l l l 1 MS. PERRY LUXTON: I'm saying subject i t l' 2 matter. I l 3 CHAIRPERSON LANNING: No. That's the l 4 basis. We have to be very careful to protect the 5 identity of the alleger. And just revealing 'the 6 subject matter sometimes could do that. So it's our 7 policy in dealing with allegations that we keep that 8 information confidential. 9 MS. PERRY LUXTON: You're looking at me 10 with a straight face, but all I can do is laugh because

  $  11 we know the reputation       of the NRC as far       as allegers.

ld 12 You've given -- you've given allegers' names back to 13 the utility. Why can't you give it to the people? And 14 I don't want names. I just want subject matter. l l 15 Because I want to make sure -- that's a check and l 16 balance for you. I would become -- we would become in 17 the public a check and balance to the NRC. ll 18 DR. TRAVERS: Sorry. We just don't do 19 that. 20 MS. PERRY LUXTON: Okay. Next question O

  ,  21                   DR. TRAVERS:      You've got one more before 1

22 we have to cycle through the room again. l 23 MS. PERRY LUXTON: Okay. 24 DR. TRAVERS: Thank you. O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

i f i t 175 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 MS. PERRY LUXTON: Well, why don't you 2 cycle through? 3 DR. TRAVERS: Thanks. Okay. 4 CHAIRPERSON LANNING: Somebody had their 5 hand up. Yes, Ma'am? 6 MS. BAILEY: Lois Bailey of CRC. I'm 7 not going to take very long. I know it's getting late. 8 But I wanted to express, as I have on previous l 9 occasions, particularly last summer in July, my extreme 10 horror at your allegation that you're being thorough in R 11 your investigation for restart. 0 12 The very premise on which ICAVP is 13 founded is simply inadequate. Now, a moment ago Mr. 14 Peter Bowman rose and asked about deferred items. And 15 I think that Mr. Imbro, who answered the question and 16 said that if you reviewed and found that certain items 17 were risk significant, then they would not be deferred

 'l       18 but would be resolved now, and after         restart, the rest 19 would be resolved.

20 The only trouble with that is it makes o

   .      21 it sound very    pleasantly as if you're really         going to I=     22 catch   all the   risk-significant systems.         But   by the l     23 very definition of your     whole ICAVP program, if you're 24 only checking 15     in Tier 1 out    of 88 risk-significant POST REPORTING SERVICE HAMDEN, CT    (800) 262-4102 o

176 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 l 1 systems, what happens to the others? 2 We cannot have, gentlemen, confidence in 1 3 restart of Millstone nuclear power plant or vindicate 4 the memory of the employees, George Galatis, Pete 5 Reynolds, John Delcore. If you're going to try to lose 6 us in a mesh of detail, well, essentially seducing us, 7 unfortunately, into not looking at the forest but 8 looking at the trees, the forest is that we are not 9 looking at a situation of thoroughness but of extreme 10 random sampling. There is absolutely no way that you

 $    11 can assure us of safety.      It seems to me the only green

!d

  ,   12 forest because we can have      power in the NRC as    far as 13 improving   the   NRC's   performance   for a   change,   for 14 heaven's sake, to levy the fine, that you're given        the l

15 penalties, to up them, to levy them, with people like l 16 Bernie Fox, where people get transferred with a golden i 17 handshake to some other plant and don't get punished ll 18 for their crimes, levy the fines heavily on them, on <7 19 departments. Don't wait time after time for corrective '0r 20 action. Levy them the first time. If you really did o ,, 21 that vigilantly, you'd have enough money and resources l 22 to be more thorough than you are. It just is not -- it l 23 is not sufficient. It terrifiec me. (Indiscernible) 24 CHAIRPERSON LANNING: Does anyone else l'h POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

t 1 l 177 l MEETING RE: MILLSTONE UNITS l MARCH 4, 1998 ! I have a general question? This lady. I 2 MS. MITZI BOWMAN: It's not a question. l

                                                                          )

3 It's a comment. 4 CHAIRPERSON LANNING: We welcome those, i i ! 5 too. I l 6 MS. BOWMAN: I seem like Alice in 7 Wonderland looking at the Mad Hatter's tea. You're 8 spending millions of dollars and you're getting good l 9 salaries. You've got a good career. That's nice. And 10 you're examining parts of a plant of an industry that R 11 should have been shut down before it was built. And 12 now you're going to go away, having brought it back on 13 line, allowed it to go back on line.  ; l 14 The first thing that's going to happen 15 is the management is going to be under pressure to do 16 exactly what they did before. It's going to happen i 17 again. And the next thing that's going to happen is l 18 there's going to be a scram. There's going to be an 19 accident. There's going to be a this and a that. f 20 You're go'ng to come running back. And eventually 0

  ,  21 there's going to be     that thing that we're not        -- that
 !-  22 we're    all   worried     about,     the   master     Chernobyl 5

l 23 situation. 24 In the meanwhile, people are going to O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

I 178 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 get contaminated because a lot of garbage is going to 2 be released, as it was before and as it will continue 3 to be. And people will be eating it and drinking it 4 and getting cancers. Your workers are going to be 5 getting cancers after they leave, not while they're 6 still working, of course, because then it would go into 7 the statistics. It won't be in the statistics. 8 And this -- this ridiculous technology 9 is being supported by you because you've got careers 10 and salaries. And, boy, it's hard to say "I'm not i R 11 going to take this filthy money." r-- 12 So it's a madhouse and I feel as though V) 13 I'm in a madhouse. 14 DR. TRAVERS: If I could respond just to 15 a few things you said? One factual error is that we're 16 going away. We're not going away. 17 MS. BOWMAN: Oh? l l 18 DR. TRAVERS: We're going to be here. d 19 And the second thing I'd like to respond to from a 20 p- ;snal perspective -- O

 ,     21                  MS. BOWMAN:    Yes?

l= l 22 DR. TRAVERS: -- is that we have a !E {l 23 commitment, each one of these people have -- they do, 24 too. I'm talking from NRC's perspective. And I've got , POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102

179 MEETING RE: MILLSTONE UNITS (} MARCH 4, 1998 1 to tell you, we don't often get a chance and we don't 2 often express the distress we feel when we haven't been 3 able to convince people -- and we don't -- we're not 4 able to convince everyone. But in our view, we're 5 going to tell you and I'll tell you tonight that we 6 have a commitment and it's the one we've been l 7 expressing at these public meetings, to do our job to ! 8 ensure that before this plant returns to operation, 9 that we've assessed, and continue to assess after 10 restart, the problems that have led to the shutdown of i l@ 11 these facilities. 9 12 So I'm sorry I can't convince of that. 13 And I -- j 14 MS. BOWMAN: You yourself -- 1 15 DR. TRAVERS: I won't even try. ' l l 16 MS. BOWMAN: You yourself have said that 17 you can't -- I j l 18 DR. TRAVERS: But I just wanted to let l 19 you know that because I feel strongly about it. f 20 MS. BONMAN: Yes. All right. I know 0

 ,    21 what you said. But  you yourself have      said that    you l
 . 22 cannot   possibly    examine   everything.        You    cannot E

l 23 possibly be everywhere. You have 100-and -- what was 24 it? 107 plants to oversee? Many of which are doing O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l l l l l 180 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 the same dirty things that this plant -- that this 2 industry did here. And people are being sickened all 3 over the country because of it. 4 And so you yourself admitted you can't 1 5 cover all this even .if you wanted to. 6 DR. TRAVERS: But -- but you went 7 further than that. l 8 MS. BOWMAN: You bet I did. 9 DR. TRAVERS: You impugned us 10 personally.

 .g    11                 MS. BOWMAN:     Yes.

9 12 DR. TRAVERS: And I wanted to' respond to 13 it, j 14 MS. BOWMAN: Yes. 15 DR. TRAVERS: I've done that. 16 MS. BOWMAN: Okay. You've done it. I l 17 Thank you. But this is a Mad Hatter's tea party. And ,l 18 I pity us all. 19 CHAIRPERSON LANNING: Any other f 20 questions? Joe? Okay. Come up. Mary, come up. O j

  ,    21 That's fine. Just trying     to -- we'll     get you    next,
  !.  .22 Joe.

E l 23 MS. KUHN: I hope this will be quick. 24 You're with the Special Projects? Okay. That means POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 L_

i l 181 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 l 1 that you are going to continue an operation after 2 restart? 3 DR. TRAVERS: The NRC. I don't know in 4 what form. Special Projects -- let me just respond 5 fully to the question. The Special Projects 6 organization is a temporary one. It's one that has 7 been used before, even in the same name, to address 8 problem areas in problem plants. And it's my 9 expectation that it won't exist forever. But what will 10 exist is the same commitment that I tried to express g 11 just a minute ago in the body of the persons who are 10

     ~

12 going to be on the job, from Resident Inspectors to k_)g 13 Region-based Inspectors to Region management and -- 14 MS. KUHN: So that means that -- 15 DR. TRAVERS: That same essential body 16 of expertise and commitment is going to remain -- 17 MS. KUHN: But the number will be cut l 18 back to what, six, seven?

19 DR. TRAVERS
The numbers will certainly 20 be cut back at some point.
 $     21                   MS. KUEN:    I see. Okay. And then I had 1

answered because sometimes

 -     22 one --   maybe this has been E

l 23 you use one term and I don't understand it. But 24 Chairman Jackson suggested on the recirculation spray O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 x

t 182 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 system that maybe the deferral list needed review. And 2 she suggested NU to do that. And has that been done? 3 And have you reviewed it? 4 DR. TRAVERS: You're talking about RSS? 5 MR. IMBRO: No. The deferral list. 6 Reviewing the deferral list. 7 DR. TRAVERS: Oh, the deferral list? l l 8 MR. IMBRO: Yes. They told us that 9 today. 10 MS. KUHN: Yes. R 11 DR. TRAVERS: Yes. Well, it's not l ,$ l 12 entirely done. We have, in fact, been reviewing it. I l 13 think three inspections have been conducted to date. 14 We expect at least one more to be conducted. But, in 15 addition to that, NU in a letter we received very 16 recently has indicated that they are looking at their 17 plan, the backlog management plan, and how they l ll 18 themselves characterized the items that they've 19 intended for -- but that's their plan. They're going ! 20 to provide us with their plan of commitments to the t O

    ,    21 extent they think they need to make them.

1

    -    22                  But we're continuing      in our efforts and l$

l 23 expect to continue to review the deferral list. We've 24 been looking at each item on the list. We haven't O POST REPORTING SERVICE f HAMDEN, CT (800) 262-4102

i l 183 MEETING RE: MILLSTON" UNITS l () MARCH 4, 1996 1 looked in detail at each item on the list. But we've 2 looked in detail at a number of items. And we expect i 3 to continue to do that. You may know that we've l 1 4 actually identified in some cases issues where we l 5 thought items needed to be done before restart that l 6 were currently on the deferred list. And we intend to 7 continue to keep looking at that 8 MS. KUHN: I see. Okay. Thank you. 9 DR. TRAVERS: Joe? 10 MR. JOE BESADE: Joe Besade, Waterford, y 11 Connecticut. I'm going to repeat something that I said 9 12 at the Radisson in New London. And that was from

    \

13 Attorney Gerry Spence. That you could not take and put 14 our corporation in prison, but the CEO's could be held 15 accountable. Also, the overseers, which is the NRC, I 16 believe haven't been as accountable as they should have 17 been. l 18 I believe now that you shouldn't be

  . 19 worry about the financial      end of NU and you     should be 0     20 taking and    looking at    additional systems.      The fines r

o

  . 21 that you levied of     the two and a half     million dollars l=    22 is peanuts of what they really should have been.

E t l 23 I realize that you people rely on your 24 fines and your license fees for your existence. I'd POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

184 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 like to see that you look into it a little further. 2 But all these decisions that are being tabled or being 3 investigated by -- who else is looking into the 4 improprieties? Maybe you can enlighten me. You're 5 under investigation. Am I not correct? l 6 CHAIRPERSON LANNING: Well, we don't 7 really talk about investigations and who is doing them

                                                                        )

8 and -- I 9 MR. BESADE: Well, I'd like to see them 10 answered and taken care of and let the public like I l$ 11 myself understand that it should be taken care of .O \ 12 before this -- these plants would be allowed to start. ( 13 Am I not allowed to ask that? 14 DR. TRAVERS: I think I understand then. 15 I would respond this way. While we don't talk about 16 investigations, whether we do them or someone else does 17 them -- l 18 MR. BESADE: I see. I 19 DR. TRAVERS: -- I can tell you what the f 20 Commission is asking of the staff in the context of NU lO . 21 investigations that won't be completed or that are l! i5 g 22 pending either within or without the NRC. l 23 And that simply is for an evaluation of 24 those issues, where they stand, what they involve and O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l l

185 MEETING RE: MILLSTONE UNITS

     '()-                             MARCH 4, 1998 1 what, if    any, nexus they have to the Commission making l

t 2 restart decision. And the Commission is receiving that j 3 information from the staff in closed session by the l 1 4 very nature of the issues themselves. That's just a l 1 i 5 privacy consideration. l i 6 But they are very interested in the l 7 question I think you're raising. And that simply is 8 given the pending status of some investigations and i 9 issues of this sort, how should this Commission make 10 its judgment about restart? And they are factoring -- R 11 factoring that question into their deliberation. 12 MR. BESADE: Okay. The other thing is 13 everybody that's been investigating, the independent 14 contractors and Little Harbor, everybody's being paid 15 by -- this money comes from the utilities. Correct? 16 DR. TRAVERS: That's correct. 17 MR. BESADE: And then it's passed on to 18 us as consumers. And some of it, NU's part, I'm happy

       . 19 to say, that they're not -- the consumers aren't paying ie    20 for   it. But they have another     way to write it off at O
       ,   21 the end    of the year as    a tax expense. And the money I=   22 that   they do   get   to   pay   fines  comes   out   of  the
    'E l   23 consumers. So right around, it goes right around       back 24 to us. It comes out of our pocket.

O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i.

I i i 186 MEETING RE: MILLSTONE UNITS ('T MARCH 4, 1998

   %-)                                                                       \

1 I know you don't want to get into 2 deregulation and all. But that's in the near future. 3 As far as all these things should be taken into 4 consideration before they allow this boondoggle to 5 continue over here on Millstone plant. 6 Thank you. 7 CHAIRPERSON LANNING: Thank you. l 8 Are there any other questions? Susan? 1 9 After Ms. Burton. ' 10 MS. BURTON: Thank you again. I just

 $     11 want to get back to Mr. Beck again and Ms. Garde.

0

  ,    12                  So   is it correct to say that you do not 13 and you have not identified       the 120 people Mr. Galatis       l 14 talked about in his interview with the New London             Day?

15 Is that a fair statement? 16 MS. GARDE: That's a fair statement. 17 MS. BURTON: Okay. Now, did you 'l 18 interview the Admiral who was in charge of writing the 19 memo before he wrote the memo? Was he part of your 20 interview effort? .O

, 21 MS. GARDE
You mean have -- we have not
 !     22 done an independent investigation on the --

>=5 l ll 23 MS. BURTON: No. No , no, no. Before 24 the incident. POST REPORTING SERVICE [ HAMDEN, CT (800) 262-4102 1 i

187 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 MR. BECK: Was he part of the structured 2 interviews? No, j 3 MS. BURTON: Before the incident. 4 Perhaps you can answer that, Mr. Beck. 5 MR. BECK: Is your question was he one 6 of those interviewed in the structured -- 7 A VOICE: Microphone please. 8 MR. BECK: -- structured interviews? 9 MS. BURTON: Yes. 10 MR. BECK: No, i lg 11 MS. BURTON: Okay. Thank you. And do I i9 j 12 understand that you, the two of you, consider that 13 personnel reaction to that incident to have been a 14 success because you understand that the Admiral was 15 removed from his position, that the process worked 16 properly? Because I understood that the process only 17 worked properly because it took a conscientious ,$ 18 reporter for a newspaper to break the story to put the ll 19 pressure on the forces at play. Do you have a f 20 different understanding of the sequence of events? 3 .$ 21 MS. GARDE: Well, the memo became public l1. 22 both on the site -- on the site the day before the l 23 newspaper article came out. I don't see that the 24 newspaper article motivated the company in the context POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 I 1 l 1

188 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 of the. actions that they took. But the oversight 2 provided by both the press and organizations, citizens l l 3 groups, certainly has been a factor in the overall view 4 of.the company's actions. They know they're going to 5 be held accountable to the public. That clearly is  ! 6 part of the factors that have gone into their decision- f 1 7 making. 8 Based on our understanding of the facts 9 as they unraveled, it was not responsive to the 10 newspaper that they took the actions that they did. It R 11 was responsive to the event. i 0 l 12 MS. BURTON: Some of us will have a hard

                                                                        )
13 time agreeing with you on that.

14 Mr. Beck, do you stand by your statement 15 at an earlier session that these plants need not meet 16 world-class standards to be in operation? 17 MR. BECK: Our view is that the plants l 18 do not have to be all green on criteria that we 19 evaluate ii. order to resume operations. That's 20 correct. l0 L-, 21 MS. BURTON: That's not what I asked. ll '5

 =  22                  MR. BECK:    Green is world-class.       That's l  23 correct.

24 MS. BURTON: You stand by your O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

i l l I 189 MEETING RE: MILLSTONE UNITS i () MARCH 4, 1998 i 1 statement? 2 MR. BECK: Yes, I do. 3 MS. BURTON: Okay. I -- 4 MR. BECK: That's the opinion of the l t 5 entire team. Consensus view, not just mine. 6 MS. BURTON: I want to talk about safety l l 7 -- excuse me -- health and safety because I haven't l 8 heard health brought up by you people at these 9 meetings, although I have heard you cut other people l-l 10 off who wanted to bring that up. And I'd like to -- l lg 11 DR. TRAVERS: I don't think we cut id

12 anyone off, i

13 MS. BURTON: Pardon me? 14 DR. TRAVERS: I don't think we cut l 15 anyone off. 16 MS. BURTON: I was present when you cut 17 two people off. I saw it happen. l 18 DR. TRAVERS: I don't think -- I'll !4 19 disagree with you, f 20 MS. BURTON: Not here tonight. On that I l

  $     21 issue. I have the tape.

1 22

  -                        DR. TRAVERS:     And so do I have the tape.

E' l 23 MS. BURTON: You can -- you can make a - 24 - I'd be happy to bring you over -- 0*~/ POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l l

190 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 j 1 DR. TRAVERS: We disagree. Let's agree I 2 to disagree. 3 MS. BURTON: Fine. I'11 hold onto my 4 tape. 5 But on the question of health, I would  ; i 6 like to ask, as part of your preparations -- it seems 1 7 as though you've made the decision for restart, because 8 anyone analyzing the language that's come off this 9 table tonight would hear not "if restart" but just 10 plain " restart". g 11 So I'd like to ask if you are in a 2 12 position now to assure us members of the public and 13 living beings, if you can assure us that if Millstone 3 14 restarts that there will be no release of radiation 15 into the atmosphere from the plant? j 16 DR. TRAVERS: No. Just the opposite. I 17 MS. BURTON: Would you explain that i l 18 please? I i 7 19 DR. TRAVERS: I'd be glad to try. If a f 20 nuclear -- well, in the operation of any nuclear power e , 21 plant, there are some releases of radioactive material. 0~ - 22 The objective of both the operators, firstly, because E l 23 they run the plants, and the NRC regulatory structure 24 and processes second, because we oversee in our O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

191 MEETING RE: MILLSTONE UNITS (} MARCH 4, 1998 1 regulatory responsibilities aspects of public health 2 and safety issues, there are releases, but the 3 objective is to make those as low as reasonably 4 achievable. And that's the structure of our 5 regulations and it's the structure of what goes into 6 our expectations about how nuclear power plant 7 operators operate their facilities. 3 8 MS. BURTON: So that -- just to that I'm 9 being fairly sure that I understand, you are really 10 assuring me that if that plant does go into operation, g 11 we all can enjoy radioactive releases from that plant? 9 12 DR. TRAVERS: I didn't say it that way, 13 but I'll say what I said. And that is -- 14 MS. BURTON: I accept your assurance. 15 Thank you, Dr. Travers. 16 DR. TRAVERS: No. But I'll finish, if 17 you'll let me, because you seem -- but what I said, $ 18 simply, is that if you know anything about nuclear 19 power plants -- and I think you do -- the answer is a 20 quite simple one. There is associated with the O , 21 operation of -- the operation of the power plants, the - 22 use of nuclear materials in medical applications, the I 5 l 23 use of nuclear materials in just about any application, 24 some potential, expectation even, of a release in the POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l \ l [ 192 MEETING RE: MILLSTONE UNITS \ O us MARCH 4, 1998 ! 1 environment. 2 The objective in the safe use of these 3 materials is to utilize them in a responsible way that 4 limits their discharge iti the environment and acts to l 5 protect public health and safety. And that's what our 6 regulatory structure is designed to do. 1 7 MS. BURTON: Okay. But I'm addressing 8 myself to Millstone 3. You have assured me that 9 Millstone 3 when it's operating properly will release l 10 radiation into the atmosphere -- , R 11 DR. TRAVERS: I haven't assured you. I \ b 12 just said that that may be the case.

13 MS. BURTON
It will. It will.

l 14 DR. TRAVERS: There will be some release l 15 -- 16 MS. BURTON: It's designed to release 17 some level of radiation. Isn't that -- if it's working l 18 properly? 19 DR. TRAVERS: Yes. 20 MS. BURTON: Thank you. So that leads ! O

 ,    21 me to   the next question of     what you have done     in the b

l - 22 way of assuring worker safety, including monitoring of l 5 l 23 worker safety both during employment at the plant and 24 later. For instance, people who have left the utility, (- POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 i I l

f. i ' 193 MEETING RE: MILLSTONE UNITS ()- MARCH 4, 1998 1 don't work there any more, what have- you done to 2 monitor their health? 3 DR. TRAVERS: There are no NRC 4 requirements that I'm aware of that speak to any 5 monitoring of nuclear power plant workers after they 6 leave employment. 7 MS. BURTON: So would it be fair to say 8 that there is no -- 9 DR. TRAVERS: I think that's fair. Now, , i 10 there have been -- I'll just -- and you may be aware of g 11 this. There have been studies of populations of people 2 12 who have worked in nuclear -- l 0 13 MS. BURTON: That's not my question. I 14 could ask that, but -- 15 DR. TRAVERS: But I think -- 16 MS. BURTON: I'm not -- 17 DR. TRAVERS: I think -- l 18 MS. BURTON: I'm not asking that i 19 question. And I'm limited here with time. , 20 DR. TRAVERS: I think it directly 0

    . 21 responds  to your    question; that     since we    don't have i
    =    22 requirements of that    sort and don't, as      a function of 5

l 23 our regulatory responsibilities and authority, we don't 24 conduct anything of that sort. O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l l 194 l . MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 MS. BURTON: Well -- I'll go on to my l l 2 next question. I am aware that there are 11 pending 3 amendment applications for Unit 3. Two haven't yet 4 been presented, possibly three that need to be 5 presented? l 6 MR. McKEE: I don't think that -- l 7 there's not 11 related. Currently, at least associated 8 with the restart of the units, there's -- by my 9 numbers, there's, I believe, around -- there's three or 1 l 10 four that we are in the process -- that are under R 11 review and have been submitted. And we anticipate, 12 actually, the fourth one -- we just received one we 13 talked about earlier and one additional one that we 14 expect to receive. So -- 15 MS, BURTON: Mr. McKee -- pardon me. I 16 didn't mean to interrupt you. Are we to believe you or 17 your Public Affairs Office which told me today there l 18 are 11 pending amendment applications -- 19 MR. McKEE: Well, I think -- 20 MS. BURTON: -- two yet to be presented o

  . 21 and an additional     one?     Who is telling        us the      truth
 !=    22 here, Mr. McKee?

5 l 23 DR. TRAVERS: I believe that -- 24 CHAIRPERSON LANNING: We'11 get fou the O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

l l 195 1 MEETING RE: MILLSTONE UNITS l MARCH 4, 1998 l 1 right number, if that would make -- 2 MS. BURTON: Excuse me? 3 CHAIRPERSON LANNING: We'll get you the 1 4 correct number. l 5 MS, BURTON: Who will get it? , 6 CHAIRPERSON LANNING: Right now. 7 MR. McKEE: The 11 you're referring to j l 8 was a number that we presented at our Commission j 9 meeting and' it referred to licensing issues which 10 included amendments in other licensing actions that , i R 11 were taken. So that's what our Public Affairs Officer, 12 I believe, was referring to. I lO I 13 MS, BURTON: So she was correct? 14 MR. McKEE: She was correct,- but that's 15 11 places of amendments and other actions as you l 16 characterize it. I don't know the exact terms used in I I 17 your conversation. But -- tl 18 DR. TRAVERS: Did you understand what he 19 said? Licensing issues include license amendment's and 20 other licensing activities. That's these. And so when i o ! , 21 you heard the answer, you thought you were hearing, I 1

 =    22 believe, license amendments.        What was being stated is 5

l 23 there are, what, 11 licensing issues. 24 MR. McKEE: Issues. O-POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

196 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 I 1 DR. TRAVERS: Some of those are 2 amendments. In fact -- how many? Four? 3 MR. McKEE: Yes. Four of those are -- 4 DR. TRAVERS: I wanted to make sure you 5 got it because it is complicated. 6 MS. BURTON: Well, since you weren't 7 privy, I assume, to my conversation today with Diane 8 Scranci, I must tell you that that's not what she told 9 me. And, therefore, there's still some confusion here 10 on a very serious issue. g 11 DR. TRAVERS: We're doing our best to 0 12 enlighten that and clarify it right now. 13 MS. BURTON: I also understand that 14 there was a request made to Dr. Jackson in advance of 15 this meeting specifically on the issue, the important 16 issue of the RSS, which is a safety backup system. And 17 I know most of you were in Rockville, Maryland when you l 18 heard Dr. Shirley Jackson express her sincere concern 19 about the issue. 20 And so there was a request that was O , 21 presented to her that, for purposes of public = 22 enlightenment this evening, the NRC present in some way 5 l 23 that is accessible to a public understanding of this 24 issue a presentation of what is wrong with the RSS O- POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

197 MEETING RE: MILLSTONE UNITS I MARCH 4, 1998 1 system that is sought to be corr ted retroactively by 1 2 this licensing amendment. And I haven't seen that l l 3 visual presentation. I wonder if you could please tell I 4 us why. 5 MR. McKEE: We had, actually the same 6 day, following the Commission meeting, we received a l 7 licensing submittal that we requested that they provide 8 infonnation that would describe their integrated 9 assessment of that system. That was a meeting open to 10 the public. $ 11 There was also additional information, I 2 12 think you referred to, that we just received, is the 13 amendment and the identification of the unreviewed 14 safety question and the licensing amendment associated 15 with that. We have that material. And that is in our 16 possession and for our review. 17 DR. TRAVERS: We're going to have to go l 18 to the next person because we've gone well over -- 19 MS. BURTON: Okay. Well, I just want to f 20 say that that didn't answer my question at all. And I I o . 21 think that it would have been very helpful if the NRC 1 - 22 had responded positively to this request for 5 l 23 information from a conscientious of the public. 24 And I would like an opportunity to come l l t POST REPORTING SERVICE j HAMDEN, CT (800) 262-4102 ) i

I I 198 MEETING RE: MILLSTONE UNITS ( MARCH 4, 1998 1 back with a final question. 1 2 CHAIRPERSON LANNING: Well, it may not - l l 3 - well, we're running right up against our deadline 4 here of being out of the building by 11:30. l 5 A VOICE: Let her ask her last question 1 6 please while she's here. 7 DR. TRAVERS: Yes. Why don't you -- 8 CHAIRPERSON LANNING: All right. Go 9 ahead. 10 A VOICE: She's got one more question lg 11 for you. i q 12 CHAIRPERSON LANNING: Yes. Please. O 13 A VOICE: Ten minutes of questions -- 14 MS. BURTON: My question is how, with l 15 all these pending issues, legal issues that mandate a l 16 proper, reasoned public review process, can you l 17 contemplate allowing this plant to go to the closest ll 18 phase to going critical in this community, in the state 19 of Connecticut where we are, not to be chauvinistic 20 about it, but, you know, the best state in the country? I lO , 21 We have the most recklessly mismanaged nuclear power

k. 22 center in the country. For years, Millstone has been E

l 23 top of the list of all the bad-boy problems. All the 24 charts put Millstone right up at the top. O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

199 MEETING RE: MILLSTONE UNITS () MARCH 4, 1998 1 You told us, Dr. Travers, that more 2 complaints are filed against cperations at Millstone 3 than any other plant 4 What I hope to convey to you is that [ 5 your thoughts and your language here tonight is very 6 immature. We expect you to follow the law and follow 7 all the processes that are mandated because we are a watching. You're being -- maybe the radiation isn't 9 monitored. But you people are being monitored and 10 being monitored closely for what you say, how you say g 11 it and what you don't say. And we're watching you. 9

      ~ 12                 Thank you.

13 CHAIRPERSON LANNING: Thank you. l l 14 DR. TRAVERS: Thank you. 15 CHAIRPERSON LANNING: I'm going to take f 1 16 your question and one more and we'll have to vacate the 17 premises. l 18 MR. NAZAR: Okay. One thing. I just 19 wanted to get a quick clarification. I believe you had 20 said -- one of you had said earlier that the punch list O

, ,     21 to allow Mode 4 is something like 417 items.

l

    =   22                 CHAIRPERSON     LANNING:      Tasks  to    be 1    5 l   23 completed prior to Mode 4, yes.

24 MR. NAZAR: Okay. And to move the plant O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 1

I MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 out of Mode 5 into Mode 4 does formally require l 2 acceptance by the NRC?  ; 3 CHAIRPERSON LANNING: No, it does not. 4 DR. TRAVERS: No, sir. NU tests 5 identified by NU as to what they need to accomplish 6 prior to' Mode 4, 7 MR. NAZAR: Okay. l 8 DR. TRAVERS: Not NRC. 9 MR. NAZAR: All right. And just for 10 clarification of the public, I was wondering if one of 11 you could perhaps clarify what is and is not occurring 12 when a plant moves from Mode 5 to Mode 4. 13 CHAIRPERSON LANNING: Sure. I'll take a 14 stab at that. Essentially, all that's different from 15 the current status is that the primary coolant system 16 is pressurized. There's no rod movement. There's no 17 approach toward criticality. There's no movement of l 18 rods. It's just a pressurization and an increase in 19 temperature of primary coolant system. ' f 20 But what is significant about Mode 4,

 $   21 passing through that Mode 4 threshold, is that numerous 22 safety   systems must be operable.         And so,    in order t l's l   23 get those safety      systems operable, surveillances        must j     24 be done, of course, all the mods have to be done and so O                         POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

r 201 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 forth. But the systems have to be determined to be ) 2 { operable by the licensee prior to going to Mode 4.

                                                                             ]

3 MR. NAZAR: So then the only change 4 really you're seeing is the heat being added by the 5 pumps stirring the water and forcing the water around 6 the primary site and associated secondary sites? 7 CHAIRPERSON LANNING: You're correct. l 8 And the pressure. [ 9 MR. NAZAR: Okay. l l 10 CHAIRPERSON LANNING: Okay. g 11 MR. NAZAR: One other thing I wanted to ! 13 12 clarify. This goes back a couple of hours. But I 13 believe you all were talking about safety eval-- 50.59 14 safety evaluations being written on some modifications l 15 to the plant that were made for Unit 3 circa 1986. I l 16 And to the best of my understanding, 17 copies of the safety evaluations for all plant l 18 modifications are gathered together and sent to the NRC 19 every year in an annual report from the plants, f 20 DR. TRAVERS: Yes. What I -- I answered

  $  21 the question     in the context of       the detailed technical
  !  22 evaluation of      all -- of    all changes in       the processes k

l 23 used by 50.59. NRC gets a summary of 50.59 24 evaluations. ~And we audit in our inspection program in O POST REPORTING SERVICE HAMDEN, CT (800) 262-4102

202 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 1 more detail the underlying technical judgments that are l 2 applied by the utility making those decisions. 1 3 MR. NAZAR: Right. But -- and even back l i l 4 then or even now, you're certainly free at any time to I 5 go back and -- l 6 DR. TRAVERS: Yes. I 7 MR. NAZAR: -- look at the subject to 8 the greatest -- 9 DR. TRAVERS: Yes. You're right. My 10 answer was to make clear that we don't look in that g 11 kind of detail at all of those decisions. And we j

 $                                                                            l 12 don *t.                                                             !

13 MR. NAZAR: Okay. And I guess my 14 absolute final question is I'm wondering if you could 15 clarify or expand on exactly what is meant by an 16 unreviewed safety question and the implication that if 17 it's unreviewed, intrinsically it must be unsafe. l 18 DR. TRAVERS: Yes. And that -- that's 19 not correct. USQ is a term of art and it has to do f 20 with a process, the 50.59 process, that is used and O

 ,     21 allows, really,    licensees    to make      changes    to   their b

s 22 facilities. And the process is a decision-making 3 l 23 process that either results in a required NRC approval 24 or not. f~'\ i POST REPORTING SERVICE l HAMDEN, CT (800) 262-4102 i

203 MEETING RE: MILLSTONE UNITS MARCH 4, 1998 l 1 An unresolved -- an unreviewed safety ) 2 question is the outcome of the answer to three 3 questions. And we talked about those earlier. If one 4 of those questions is answered in the positive, you 5 have by definition an unreviewed safety question. You 6 don't necessarily have a safety issue resultant from 7 that determination. j l 8 What you have is a requirement that the 9 issue and the change you're proposing to make needs to 10 be reviewed before you make it and approved by the NRC g 11 before you do it. It doesn't mean that you have a 0 12 safety significant problem. And that's an important 13 point that I don't think I made very clear to Susan 14 earlier. So I'm glad to have the opportunity. 15 It's a term of art that we use in our 16 sometimes overburdened and complex regulatory scheme as 17 to how licensees can sometimes make changes to their l 18 facility without NRC pre-approval. 19 CHAIRPERSON LANNING: Who wants to ask 20 the last question? Anybody? O

 , 21                   Mr. Markiewicz. Has to be a short one 1
 = 22 now.

5 l 23 MR. JOHN MARKIEWICZ: It is. 24 CHAIRPERSON LANNING: All right. POST REPORTING SERVICE HAMDEN, CT (800) 262-4102 l l

204 MEETING RE: MILLSTONE UNITS (} MARCH 4, 1998

1 MR. MARKIEWICZ
John Markiewicz from 1

2 Waterford. I think the new format worked well and you 3 ought to continue it. 4 CHAIRPERSON LANNING: Well, thank you. 5 All right. Okay. We're going to 6 adjourn this meeting. That kind soul in the back room 7 wants to go home early, 11:30. Thank you very much. 8 9 (Whereupon, the meeting was adjourned at 10 11:13 P.M.) h e O i ir O d i 5 O POST REPORTING SERVICE RAMDEN, CT (800) 262-4102 l

I . CERTIFICATE O,. l I, Paul Landman, a Notary Public in and for the State of Connecticut, and President of Post Reporting Service, Inc , do hereby certify that, to the best of my knowledge, the foregoing record is a correct and verbatim transcription of tire audio recording made of the proceeding hereinbefore set forth. I further certify that neither the audio operator nor I are attorney or counsel for, nor directly related to or employed by any of the parties to the action and/or proceeding la which this action is taken; and further, that neither i the audio operator nor I are a relative or employee of any attorney or counsel  ; employed by the parties thereto, or financially interested in any way in the outcome of this action or proceeding. I I In witness whereof I have hereunto set my hand and do so attest to the above, this 26thday of March ,19 98-k_i w- g L y -x Mul Landman, President 5 POST REPORTING SERVICE

 .                                         1-800-262-4102

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