ML20237D632
| ML20237D632 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/24/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20237D525 | List: |
| References | |
| NUDOCS 8712240092 | |
| Download: ML20237D632 (62) | |
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION Sec50T&I 2 OFFICE OF HUCLEAR REACTOR REGULATION ,
3 4 MEETING WITH BOSTON EDISON )
COMPANY RE: PILGRIM STATUS AND )
5 ACTIVITIES LEADING TO RESTART ) No. 50-293 READINESS )
6 )
7 Room 114 Phillips Building 8 7920 Norfolk Avenue Bethesda, MD 9
Thursday, 10 September 24, 1987 l
11 i The above-entitled matter came on for hearing,
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12 pursuant to notice, at 1:22 p.m. I 13 i llh BEFORE: RICHARD WESSMAN 14 NRR, Project Manager for Pilgrim '
15 TOM MURLEY 16 BILL RUSSELL 17 JIM TAYLOR 18 APPEARANCES:
19 On behalf of the Nuclear Regu':: tory Commission:
20 S. J. COLLINS 21 J. WIGGINS C. WARREN 22 V. HERSES B. A. BOGER 23 O. P. GORMLEY R. BLOUGH 24 T. MARTIN F. MIRAGLIA 25 (Continued on the next page)
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2240o92 970924 T ADOCK 05000293 PDR
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APPEARANCES: (Continued) 2 ,
H. B. CLAYTON 3 D. B. MATTHEWS C. B. TINKLER 4 J. KUDRICK R. T. HOGAN 5 S. GAGHER W. GODGES 6 C. MILLER G. FELGATE 7 T. P. GWYNN J. P. BANGARRA, JR.
8 G. THOMAS 9
10 On behalf of Boston Edison Company:
11 R. E. BIRD R. A. LEDGETT 12 K. R. ROBERTS D. G. GILLISPIE 13 J. E. HOWARD
() 14 R. A. VARLEY J. FULTON E. D. ROBINSON 15 i 16 17 18 19 20 21 22 23 24 r
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'b(f l' PROCEEDINGS E'
2 MR. WKSSMAN:. Okay, this is a meeting between Boston 3 Edison and the NRC to provide the opportunity.for Boston Edison-4 to'brief the staff regarding the current status of.the Pilgrim 5 facility and their. plans regarding making.the facility. ready i 6 for restart.
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7 Before we turn the meeting over to Boston Edison,RDr.
8 Murley has a few remarks,.and I believe Bill Russell does also.
9 .DR. MURLEY: Yes,'We want to set the stage for'the 30 meeting and presentation so we all understand what the meeting-11 is and what it isn't.
12 This a status briefing on the improvements and the 13 status of the plant at Pilgrim. There will be no decisions on O. 14 restart today. We are not discussing that.
15 As you know, the plant was shut down on April 12, ;
16 1986, so we are some 17 months after shutdown. There were some [
17 specific equipment problems which caused the shutdown, which -
18 caused NRC'to request that the plant stay shut down. In the 19 ensuing months, other problems developed and, in addition, 20 Boston Edison had difficulty establishing stable management 21 team at the site.
22 I have testified in hearings in the State of 23 Massachusetts, in Boston, that we in NRC must see clear 24 evidence of improvement before we will allow the plant to 25 restart. In fact, I have said there are clear things that must
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'4 1 be; fixed beforefthe plant'can restart.
2 We in NRC talk in terms of three categories.of 3 issues. The first category is the plant technical and 4 management issues, and perhaps Bill Russell can elaborate a 5 little bit on those.
6- The second category are what we call the safety 7 enhancement program. I'm sure we will hear a bit about those 8 today. Those enhancement actions being taken by. Boston Edison 9 are voluntary. They are not required by NRC by our 10 regulations, and not for restart. ' Nonetheless, we have to make; l 11 sure that these enhancements have not themselves introduced'new l^
12 ' problems or--introduced new failure modes. So we are reviewing 13 them and we are particularly interested in the proposed direct l
O > 14 torus' vent system. We have a number of questions that we want 15 to review carefully before we approve this change.
16 The third category of issues are the off-site 17 emergency preparedness issues. FEMA issued a report to the NRC 18 on August 6th of this year. They concluded that the 19 Massachusetts' radiological emergency-preparedness plan was no i 20 longer adequate to protect the public. We are interested in i 21 hearing today what progress is being made in dealing with the !
22 six issues that FEMA identified.
23 I should point out that FEMA is unable to attend the 24 meeting this afternoon here. Boston Edison met this morning i
25' with FEMA. The NRC staff attended as observers, and Dick
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1 Wessman will briefly summarize what was discussed today. There 2 were no commitments, and I understand the same material was 3 presented -- will be presented this afternoon in more-detail.
4 Congressman Studds and Senator Kennedy have sent a 5 letter which I just received today. They sent it to the 6 chairman, requesting public meetings on Pilgrim. We have been 7 and are always agreeable to such public meetings. In fact, we 8 have had -- it's hard to count, but I can remember at least 9 about a half a dozen such meetings.
10 We do have plans for at least four more, as I 11 understand it. A panel meeting that Bill Russell will~ talk 12 about, maybe two panel meetings. We understand that there are 13 plans for a larger public meeting in Plymouth, and if we were
' s] 14 invited, we would be glad to attend that and answer questions.
15 And then there will be a public commission meeting with the 16 commissioners. We have not set the agenda for that, and so I j 17 don't know just what the format would be. But clearly it would i
18 be a meeting to discuss with the commission any final l 19 recommendations that the staff might have.
20 Those meetings, particularly w&th the one with the 21 commission, are not scheduled at this time. There are still a 3 1
22 lot of issues that have to be resolved. j j
23 It will be the regional staff who will do the special 24 inspections and assess the readiness of the plant for restart.
25 And so Bill Russell will talk about some of those plans.
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-1 MR. RUSSELL: I would like to spend a few moments to-2 describe the process the staff is using and how we,have 3 organized this' review.
4 We have established a restart assessment panel which-5- is made up.of senior members from the region and from the 6 Office of' Nuclear Reactor Regulation, to review both the plan-7 submitted by the company, the various safety evaluations'that 8 are being prepared, the results of the inspection activities 9 and, in fact,.the entire scope of the NRC review.
10 The panel's principal function is to gather this 11 information and bring issues promptly to senior management-for ;
12 resolution such that thereLis a vehicle in place to promptly 13 address significant concerns.
O 14 In addition, the panel will.be conducting public 15 meetings in.the vicinity of the site to obtain at the-first 16 public meeting feedback from interested parties on the plan as 17 it has been submitted by the company. We are principally 18 interested in areas of concern, or areas which need to be _
19 ' addressed.
20 To the extent the concerns are directly related to 21 restart and not related to generic issues that may be beyond 22 the scope of the assessment panel's charter, we would attempt 23 to address those concerns directly in the evaluation that the 24 staff is completirq 25 We would then meet again a second time to provide
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, 7 1 feedback to the public or interested parties on the disposition L
2 of the various comments or concerns which they raise at the 3 first meeting.
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4 The third meeting is the one that Dr. Murley l
5 discussed, and that is at a point in time after the staff has 6 completed the main part of its review and has a position, but 7 prior to that position being finalized, we would meet in the 8 vicinity of the facility to have a meeting with Senator Golden 9 and others who have indicated a desire to have that type of 10 meeting.
11 There are a number of things which must be 12 accomplished prior to restart, and I'm going to use as a 13 starting point when the company says that they are ready and O 14 they have completed their own internal assessment. From that 15 point in time, the NRC will conduct in-depth inspection 16 activities to assare ourselves that they have indeed made 17 progress and resolved some of the longstanding issues. ;
18 We are not at this point prepared to accept as a 19 basis for restart commitments or programs. We must see 20 results, and we will measure those results after the company 71 has said they are done.
22 We will use a team inspection approach, and there 23 have been requests for a State observer, and we are negotiating 24 with the State who that observer will be to actually observe 25 the inspection activities.
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8 1 That process we cannot provide a schedule for, but we 2' will notice as we reach completion with the initial step being j 3 the company's submittal of their plan.
4 There have been some improvements, and there are some 5 good indications, and I believe that we will hear some of those 6 today based upon the status reports that we have had from the 7 panel thus far.
8 That concludes my opening remarks. Dick, do you want 9 to summarize the meeting this morning?
10 MR. WESSMAN: Let me very briefly summarize the 11 meeting between Boston Edison and FEMA that occurred this 12 morning.
13 I think the day before yesterday FEMA advised us and O 14 the utility that they could not be available this afternoon, e v a l . Lk, 15 but identified they could make themselvespfor about an hour or 16 so, so that they could at least get that status briefing. 4 17 Boston Edison met with FEMA for about a half an hour this 18 morning and briefed them on the status of the emergency 19 preparedness activities, and basically that briefing, as I 20 understand it, is identical to what we will hear this 21 afternoon.
22 Basically it touched on the atmosphere of cooperation 1 23 between the State and the towns and Boston Edison. It l 24 discussed the efforts that the utility has had underway to help 25 the state upgrade emergency preparedness plans, and to work
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9 1 towards resolution of the FEMA-identified issued, and Boston 2 Edison touched upon their plans for an annual on-site exercise 3 scheduled for December of this year, and their request, which 4 they have filed with the commission dated September 18th, I 5 believe, for an exemption from the requirements for the 6 biennial full-scale exercise which would be normally required 7 before the end of this year.
8 Again, no commitments or policy issues were 9 discussed. It basically was a status briefing, and again Mr.
not 10 Krimm sent his regrets that he could A be with us all this 11 afternoon.
12 Before I turn the meeting over to Boston Edison, let
,, 13 me at least identify one additional individual that came into V 14 the room, and that's Jim Taylor half-way down the table there, 15 deputy executive director for regional operations.
16 With that, I think it's your meeting, Ralph.
17 MR. BIRD: All right.
18 (Slide) i 19 What's being passed out is a copy of the slides for 20 those that wish to refer to them, or those in the back of the 21 room that can't quite see what I've got up here. 1 22 Good afternoon, this slide outlines what we plan to 23 cover here today. I am Ralph Bird. I am the senior vice 24 president, nuclear. 1 joined Boston Edison on the 1st of 25 January of this year. After an intensive training on boiling Heritage Reporting Corporation (202) 628-4888
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10 f 1- water reactor plant. systems and Pilgrim-specific systems and 2 design, I assumed my responsibilities at the end of February.
3 ' Shortly'after that when the vice president of. nuclear' 4 operation's position became vacant, I also assumed those 5' responsibilities, and I plan to leave that position vacant 6 until after. restart. I am spending most of my time at the 7 plant, where I can be closer to the people and to the_ problems.
8 Some of my background may be of interest to you. I~
9 am a Naval Academy graduate.. I retired in 1984 as a rear 10 admiral after spending most of my career in nuclear submarines.
11 My Navy experience in a variety of assignments, all of which
, 12 included responsibilities for leadership and management, helped 13 to prepare me for my present job.
14 My-background also includes training, safety 15 evaluations, and personnel and material support. A few 16 examples are a command of a nuclear-powered submarine, chief of 17 staff of the Pacific submarine force. I also served as senior 18 member of the Pacific fleet nuclear propulsion examining board 19 where, with a small. team of officers, we annually assessed the 20 ability of each nuclear-powered ship in the fleet and its crew .
l 21 to operate their reactor plants safely during the forthcoming 22 year.
1 23 As a naval officer, I was continually involved in l l 24 training my officers and crew. But I also was involved in 25 establishing the chief of naval operations, senior officer ship Heritage Reporting Corporation (202) 628-4898 i .s --- - - - - - - - - - - - - - - - - - - - - - _ _ _ o
11 1 material readiness course. The objective of that course was to 2 teach flag officers and senior captains who were e,n route to 3 major commands about oil-fired propulsion plant operation and 4 maintenance, to apply the lessons that we had learned in the 5 nuclear-powered Navy over a number of years, to apply those 6 lessons to improving the performance of the rest of the fleet.
7 And I served as the senior instructor of that course for the 8 first three classes.
9 After leaving the Navy, and before joining Boston 10 Edison, I was a consultant at several nuclear power plants, and 11 I also worked for Westinghouse as an employee and as a 12 consultant.
13 When I joined the company, the CEO and the board of
.O 14 directors made it very clear to me that I had their complete 15 support. Their close interest and their support have 16 continued. The CEO and chairman, who is the same individual, 17 visits the site about once a week. Each board meeting includes 18 a review and a discussion of Pilgrim status, and the board will 19 inspect the plant and evaluate our progress before we seek 20 restart approval.
21 As a further example of their support, I am under no 22 arbitrary cost or schedule constraints. My only goal is to 23 make the plant right. Only after we are satisfied with our l 24 progress and have the approval of our CEO and our board of 25 directors will we seek commission approval for restart.
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s 12 1 This afternoon I will discuss briefly my assessment 2' of the situation when I assumed my position at the end of 3 February, including some of'the problems and the root cause.
GL And I will discuss our correct actions and our restart plan.
5 In assessing the situation at Pilgrim, I was pleased 6 to find some strengths. These included operators who have 7 consistently demonstrated their competence through their 8 performance in examination and during special NRC reviews.
9 Another strength is engineering. The design basis is 10 in_, tact and the configuration management is sound. This has 11 been confirmed by NRC's safety system functional inspections.
i and by our own safety system functional inspections and QA.
12 13 audits, and these inspections continue.
O 14' So what went wrong? Well, there was a large backlog 15 of work, including administrative, programmatic and maintenance 16 issues. There was a patter of deficiencies in radiological 17 controls, in security and in fire protection. A common thread 18 was inattention to detail, lack of critical self-assessment and 19 effective follow up and unresponsiveness to NRC observations 20 and inquiries.
- 21. The plant was not unsafe, nor has any knowledgeable 22 observer said it was. But the number and the scope of 23 deficiencies, even though they were generally minor if taken 24 one by one, in the aggregate were a source of concern.
25 The result was a loss of confidence in the plant
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1 management both by Boston Edison's senior management and 2 directors and by the NRC. The plant was shut down in April, 3 19,k and a confirmatory action letter was issued.
4 Now what is the root cause of Pilgrim's problems. In 5 my view, there are three essentials in managing a complex EndT1 6 operation: the standards, plans and controls.
7 We must establish plans to meet the standards, and we i
8 must have effective controls to ensure that the plans and the 9 standards are met. There were some weaknesses in each of these 10 essential elements. But the most fundamental root cause of the 11 problems at Pilgrim was the lack of well-understood 12 consistently applied standards of excellence and the resulting
,. 13 inattention to details. There were several contributing 14 factors.
15 The majority of people at Pilgrim had been employed 16 only at this plant, and thus they did not have a reference 17 based on their background and experience against which to 18 assess their performance. Emphasis was on compliance rather 19 than on rising standards of excellence.
20 Plant management focus was inward rather than looking 21 out to seek ideas for improvement. The general result was an 22 inability or an unwillingness by plant personnel to 23 self-assess, to identify problems, and to take effective 24 corrective action.
25 Corporate management had provided a great deal of 1
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14 i 1 money.for repairs'and for capital improvements. And as'a 2 result, plant operation was improved over time, bgt more slowly 3 than the industry' average was improving.
4 The organization did not function well to determine, 5 plan, assign and control work. The span of control for the 6 managers was uneven and too broad in some cases, with the 7 result that some key managers were over-loaded. Accountability 8 was sometimes unclear, and there was_some sense of frustration-9 among the people at the plant.
10 We believe that the actions that are described in our 11 restart plan are correcting the root cause and its symptoms.
12 And I will. talk about the restart plan in two steps. First, 13 how we' propose to work with the NRC to reach a restart
.O 14 decision. And second, the restart plan elements which are the 15 basis for the restart decision.
16 Our_ proposed decision-making logic and sequence have 17 been reviewed _with senior Region I management and the. restart 18 panel, which as you have heard is composed of people from NRC 19 Region'I and from NRR. We have reached agreement in principle l 20 on the process, the sequence, and schedule milestones for ]
21 restart decision making. This is depicted on the restart plan 22 flow chart.
23 To cover some of the key points. On July 30th, we 24 submitted the restart plan that described Boston Edison's 25 programs, plans and actions for a safe and reliable restart and
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q, 15 1- 1 for. continued operation. The NRC reviewed an inspection of.
2 major specific elements of the plan that are ongoing and will 3 continue through' start-up preparations through restart and 4- through_ power ascension.
5 .Six weeks before restart, we will submit an. interim i
- 6. readiness assessment report. This will be a set of results 7 appendices that make up Volume II of the restart plan. We
- 8. expect to submit-these appendices within the next two weeks.
9- And Ron Ledgett will tell you more'about these this. afternoon.
10 Four weeks before restart, the NRC.will begin a 11 diagnostic inspection which will take about ten-days to-12 complete. And we will keep the NRC informed of-our progress so 13 that inspection does not start before we are completely ready O. 14 to support it. j 15 Three weeks before restart, we will complete our .
1 16 final readiness assessment report and eubmit it toEthe NRC.
. 17 This should occur around the midpoint of the diagnostic, and 18 thus can be available for consideration as the NRC team 19 prepares its report which will be finished about two weeks 20 before restart.
21 We will. respond as necessary to the diagnostic. If 22 the results are positive, I will then seek Boston Edison's CEO 23 and board approval to request Commission restart approval. If 24 all goes well there, we will then meet with NRC senior 25 management and with the Commission as permitted by your-
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16 l 1 I 1 . schedules. j
-2 When we obtain your approval to' restart,,we will 3 proceed with the power ascension program. This program will 4 provide first a mechanism _for interpreting or integrating the 5 ' Boston Edison management review of readiness. Second, a q 6 structural framework for NRC and Boston Edison review of i 7 management, operation and plant performance during the power 8 ascension phase. And Ken Roberts will be telling you more 9 about that this afternoon.
10 Turning now to the contents of the restart plan, 11 Volume I provides Boston Edison's action plans and the bases 12 for restart readiness assessment. Volume I of the plan is 13 organized into four basic categories of programs, and plans and
'O 14 actions for a safe and reliable restart and continued 15 operation. Management, operational performance, plant and 16 equipment performance, and the bases for readiness assessment.
17 Our management improvements are comprehensive, and 18 are backed by a strong commitment from our top management and ,
19 our board. Several highlights of these improvements are worth 20 mentioning.
21 Under senior management changes, there are four key 22 changes in the organization. I am the senior Boston Edison 23 nuclear manager. I report directly to the CEO and chairman of 24 the board. I am also holding the job of vice president of 25 nuclear operations and spending most of my time at the site to I i Heritage Reporting Corporation (202) 628-4888
17 1 maintain closer touch with the problems and the people.
2 The executive assistant to the senior VP,, Ron 3 Ledgett, has oversight responsibility for activities at the 4 site, and functions essentially as a deputy to me. He joined 5 Boston Edison in January 1987 as a consultant, and then became k
6 a permanent employee in May.
7 Don Gillispie, the Director of Planning and Restart, 8 has assumed the responsibility for oversight of restart 9 activities and the planning and work controls to complete the 10 outage. He joined Boston Edison in May of this year.
11 The Station Manager, Ken Roberts, who was formerly 12 our outage manager, assumed his current position in February of 13 1987.
O 14 Major organizational changes include eliminating the 15 divided chain of responsibility between outage management and 10 the station manager that was criticized in the most recent SALP 17 report. Outage management now reports to Ken Roberts.
18 Fire protection, security, emergency planning and 19 training are realigned, so that they all report directly to me.
20 A systems group was added to the plant technical section. This 21 group follows the dedicated system engineer concept which is 22 endorsed by INPO, the Institute for Nuclear Power Operations, 23 as an industry good practice. And we are aggressively 24 implementing this program.
25 A series of other key management changes were made I
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18 1 within the nuclear. organization to enhance the experience and 2' ~ skill levels within the organization. Some of the key changes 3 were the operations section manager, the' radiological section ;
1 4 . manager, the security section manager, the fire protection and l I
5 group leader.
6 In emergency planning, Ron Varley, who is my 7 assistant, is overseeing this area, and he will talk to you
'8 later about off site emergency planning issues. We have also 9 ' created ~the systems group leader and his group. You will find 10 summaries of the backgrounds of these people in Volume I of the 11 restart plan.
12 Turning now to the operational performance 13 improvements, our objective in this area is simple To provide 14 the tools and the capabilities, and to use them effectively to 15 improve human performance at the plant.
16 There are five basic sub-areas within the operational-w e_
17 performance category that warrants some attention. First, they 18 need to increase staffing and experience levels in certain key 19 areas that was identified as a persistent problem in the last 20 two SALP reports. We have addressed the problem directly.
21 We have filled the maintenance supervisor vacancies.
22 We have implemented controls on operator overtime, and expanded 23 the number of operators, and upgraded operator training. So by 24 the end of the year, we will have enough reactor operators to 25 support six shifts.
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1 Fourth, we have expanded and refined performance 2 assessment techniques for measuring and controlling performance 3- at Pilgrim. Examples include a weekly report which shows key 4 indicators for measuring progress toward the performance goals 1
5 which we have set for ourselves for restart. Any more j l
6 comprehensive report of key performance indicators is also 7 generated weekly for each major organizational element.
8 Fifth and certainly by no means last in importance is 9 we place major emphasis on improved control over the outage 10 work, on prioritizing the work, and on improving planning, 11 material availability, and work progress monitoring at Pilgrim.
12 Don Gillispie will tell you more about this later this 13 afternoon.
O 14 Turning from human performance to plant and equipment 15 performance, our objectives are to upgrade and control the 16 plant material condition over the lifetime of Pilgrim. Our 17 improvements are in several areas, maintenance, radiological 18 controls, fire protection, security, surveillences, system 19 restoration and return to service, and power ascension 20 programs.
21 Three general observations before I discuss these 22 areas. Our improvements in maintenance are essential to reduce 23 our work backlog and to keep it under control in the future.
24 Radiological controls, fire protection, security, and 25 surveillences were SALP 3-rated areas where we have made strong
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19 1 We have recently put in place a chief radiological 2 scientist and a radiological assessor. These are,new 3 assignments. We have also established a highly experienced 4 independent radiological oversight committee that reports to me 5 and provides a strong independent check on our ongoing efforts 6 to upgrade radiological controls.
7 We have expanded fire protection and authorized staff 8 from'one person to six. We have added people to provide 9 qualified Boston Edison security supervision on each shift.
10 Within our contractor force, we have doubled the supervisor-to-11 guard ratio to provide more and better supervision.
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12 In. quality assurance, two actions are particular1y.
13 important. We have expanded the on site surveillance group O- 14 from two to ten full-time people. We have improved management 15 responsiveness to QA findings. My own active participation in 16 this area includes weekly meetings with QA managers and with 17 the station manager to review quality related issues and 18 trends.
19 Third, the training has been expanded and improved, 20 and recent results have been good. INPO accreditation of all 21 of our training programs was completed last month. The SALP 22 indicated that the best measure of the effectiveness of our 23 operator training program would be the pass rate. The results
-24 of NRC exams for our last class were released in June, and the 25 pass rate was 100 percent, eight of eight passed.
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- i. - 1 improvement efforts.
2 Our processes for system restoration and returning 3 the systems to service and the power ascens' ion program are the
.4 means for demonstrating our improved performance and readiness 5 to ourselves and to_the NRC..
l 6 Now I-will-highlight some of our major efforts in 7 each of_these foregoing seven areas. First, our maintenance 8 objectives ~are to reduce the backlog.to within the range of 9 goals stated in_our restart. plan and to implement an 10 improvement program to assure that we keep control of 11 maintenance in the future.
12 Through strong efforts.that we have made in 13 prioritization, data work' plans, and monitoring of performance
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- t 14 indicators, we are now trending down towards the goals that we 15 set for ourselves. We need to improve further, but the' trends ]
16 are positive.
17 To assure continued control, we are implementing a 18 material condition improvement action plan which is a full .
l 19 scale plan of action resulting from a very extensive review and j 20 self-assessment that we conducted this spring.
21 Now this plan differs from previous corrective action 22 plans that I know about at Pilgrim, because it focuses ~on !
l 23 specific results and it includes continuing assessment and 24 feedback to assure effectiveness over the long-term. It is not it 25 just a punch list of items where we check kf of f when we do it
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I 22 1 and forget about it. It is focused on results.
2 A copy of this plan was submitted with Volume 7 of 3 the restart plan, and we are tracking the effectiveness of <.
4 these actions closely under Ron Ledgett.
5 Second in the area of radiological controls, there 6 are three activities that stand out. We have been working hard 7 at improving communications and stressing individual 8 responsibility for radiological controls, through daily and 9 weekly meetings between the radiological and production people l
10 and by assigning experienced radiological controls people to ,
11 the maintenance organization. These people do work planning .
12 and training of the other maintenance people.
, 13 The idea is to build in the radiological controls at 14 the front of the maintenance planning rather than to try to 15 place it in at the end.
16 A major goal is decontamination of 90 percent of the 17 plant areas. This is tough, but we are getting results. We 18 can now enter areas in street clothes that historically 19 required full anti-Cs and respirators.
l 20 Finally, we are in the advance stages of developing a j 21 new radiological action plan. This will provide a specific set 22 of short-term and long-term actions in the model of the 1
23 material condition improvement plan, again focused on results l 24 and not long-term effectiveness. And this should finally close 25 outtheNRCfrderinthisarea. We expect to have this i
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radiological a,' tion plan completed witnin the next two to three 4
2 weeks, and we'will provide a copy to the NRC. ,
3 Third, our increase in staffing and management 1
4 attention in fire protection appear.4 to be paying off. A l 1
b recent NRC 19 5pection showed fewer problems and a more ponitive 6 tone. We are seeing a trend in the proper dir ection cr. che 7' backlog of work in fire protection. Fire brigade tra'ining is t
8 better, and Appendix R modifications are getting done.
'l o Fourth in security, two observat ions stard out, the 7_
10 security hardware improvements and more responsivc security 11 syt. tem maintenance thould reduce our reliance on compensatory 12 measures. Pr67 ress is clearly evident, hv+ this area need's and I 33 uill get continuing close management attent ion.
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.s The fif th item 31n the .arer.' of su'rteilleneq3pwomajoz e
15 actions should crd7 to resolve the' problems of missed or
< 16 incorrect surveillences. We have placed the surveillance 17 program under a single point of control in the plant techti.cn3 , ,
18 sec;.lon . And we2have upgraded the mast +,r surveillance tiacking 19 program in accordance with the INPO tood practice on chie s
e s 20 subject. The new system is now running in parallel with,;ne 21 old cne and the switchover to the new system is scheduled for 22 November of thim yeer.
23 Sixth, we have implemented two major processes for 24 nssaring that plant equipment and syst3ms are i;n good shape 25 whep they are restored to service. We save a detailed plant
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i 24 1 operation condition check 1J st, and this process was -
2 successfully used at the end of our last r9 fuelling outage, and 3 has been expanded for use at each major restart milestone for 4 this outage Our new group of dedicated system engineers is 5 proving to be. valuable in reviewing system readiness for field 6 load, and as wr! approach restart, we expect this group to 7 ' provide much better technical support than we'have ever had in 6 the past at Pilgrim.
9 Finally, the porer ascension program, we'll integrate 10 our management readiness and provid:s t.he framework for 11 oversight and review, and for NRC independent oversight and 12 review of power ascension. And Ken Roberts wil] tell you more 13 about that program this aftfrnoon.
O 14 In conclusion, I would like to outline how we intend 15 to pull together our management, our operational performance, 16 and the plant performance improvements, then assess our 17 readiness to restart, and present that assesswant to the NRC 18 for decision.
19 Our readirtess assessment process will consist of 20 seven basic steps. We will first complete the restart actions E
21 identified in the restart plan. fhen, using the assessment 22 bases stated in chapter 5 of the plan, our senior nuclear 23 management team will review our results against those bases and 24 docmaant our overall conclusions concerning readiness. We will 25 then close out all of the necessary items from our checklist
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25 1 and from our systems group reviews, and. complete the 2 walkthroughs and training preparatory for power ascension. We 3 will review and respond to the results of the NRC diagnostic.
4 If that all goes well, then I would seek: approval from our CEO 5 and Board of Directors to file a. formal request to restart.
6' We'll.then go before senior NRC management and the 7 Commission with our results, which will demonstrate our' ability 8 to support safe and reliable restart and safe and reliable 9 continued operation of the plant.
10 This concludes our summary of Volume I of the restart 11 plan. Ron Ledgett, the Executive Assistant to Senior Vice
'12' President, Nuclear, will now cover the major elements of V'olume 13 II of the restart plan.
O ~ 14 DR. MURLEY: Why don't we take a few questions here 15 if there are any on your presentation, Ralph? I've got one --
16 I guess a comment.
17 MR. BIRD: We can do that, but we'd probably be 18 anticipating questions to come in the rest of the program --
19 DR. MURLEY: Yes, but I want to make sure when we're 20 going through the rest of it that your schedule ; hart that you 21 have and restart flow chart, we accept as a chart that issues 22 the major logic things that have to be done.
23 But we're.not bound by the times involved here. And 24 we'll take whatever time it needs to do our own diagnostics and 25 our own evaluations and so forth.
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26 i 1 MR. BIRD: We understand that. These have been 2 discussed extensively with the restart panel and with other 3 members of NRC staff, so we think they are good estimates. We !
4 recognize that our estimates could change a little bit, too as 5 of our progress.
6 DR. MURLEY: We're not bound by that chart, is the 7 point I want to make, and I hope everybody understands'that.
8 MR. BIRD: Okay. Are you ready for Ron now?
9 MR. LEDGETT: Thank you, Ralph.
10 Good afternoon. I am Ron Ledgett, Mr. Bird's 11 Executive Assistant. And I will start by giving you a brief 12 summary of my experience: I graduated from Stanford Unive'rsity 13 in 1961 with a Master's Degree in Electrical Engineering and I 14 spent the next 25 years with the Navy Nuclear Propulsion 15 program. Twelve of those years were at headquarters in 16 Washington, and the remainder were in shipyards, constructing, 17 repairing, and refuelling nuclear propulsion plants.
18 Much of my time in recent years has been devoted to 1
19 evaluating industrial operations, identifying underlying causes 20 for poor performance, and getting the problems fixed at 21 shipyards, prototype land-based reactors, and fleet repair 22 activities. I've been at Pilgrim, as Mr. Bird mentioned, since 23 January, and I joined Boston Edison in May. .
l 24 I will now briefly discuss the process for closing j 1
25 restart commitments and the function of Volume II of the
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! L 1 restartLplan.- The following considerations led to the process 2 that I will describe. ,
3 .First,. meetings and correspondence affecting restart 4 at Pilgrim date back more than a year,.and second, management 5 changes, self-assessments, external assessments, during this 6 period have increased our understanding of the iesues.and'the l 7 number of commitments potentially affecting restart.
8 We need to confirm that the many commitments were 9 consistent and address the issues of concern. To do.so, we 10 established a. management process which accomplishes the 11 following: it identifies the commitments and actions which 'are 12 related to restart at Pilgrim; keeps the responsibility with 13 line managers; specifies' clear closure criteria for each O 14 action; independently checks that the closure documentation is 15 complete; independently checks that the effectiveness of 16 certain actions is there; and independently checks that certain 17 actions are sustained.
18 We were careful to keep the responsibility for a sure 19 thing action for completeness and effectiveness with the line 20 mangers. The independent reviews by staff and a senior manager 21 provide feedback on the performance of line managers and 22 specific examples for counselling managers when improvements 23 are needed.
24 The function of Volume II is to present the results 25 of the process. Volume II consists of 12 appendices, which
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( 1 track completion of Boston Edison initiatives and commitments 2 to the NRC for restart at Pilgrim. Company commitments and 3 initiatives to the NRC which are not tied to restart are not in 4 these appendices. The issues that are concerned with restart 5 are prominently listed along with each of the actions being 6 taken to deal with that issue. The status of each action is 7 reported. The source of each action is identified for ease of 8 tracking.
9 Examples of sources for actions include the company's 10 material condition improvement action plan, or the NRC Meeting 11 86-41 concerning restart actions. For ease of review, two 12 appendices are included which list actions in the format o'f lette
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13 Confirmatory Action 4 86-10 and Management Meeting 86-41.
() 14 In addition, issues and actions now organized in a 15 common data base which has enabled managers to better assess 16 the adequacy of actions for a given issue and to assess the 17 consistency of action commitments over time.
18 Where changes are needed to prior commitments because 19 of inconsistencies or other problems, these changes are 20 specifically identified in Appendix II, with the basis of the {
21 change. The appendices which form Volume II are being updated )
l 22 at Pilgrim Station and are available on-site for NRC review.
23 Revision One to Volume II of the restart plan will be l l
24 issued in the next two weeks with the latest Appendix updates. l l
4 25 I'll give you a brief status: the bulk of the restart action '
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( 1 commitments are contained in Appendix 6 which applies to our 2 material condition improvement plan, and Appendix,10, which 3 tracks the NRC commitments for restart.
4 The status for the material condition improvement 5 plan is as follows: there are 89 restart action items. Sixty-6 four are closed and are being periodically checked to make sure 7 that the actions are sustained and are producing the desired 8 results. Eleven items are considered complete by line 9 managers, and presently are being independently checked prior 10 to closure. Fourteen items still are in progress.
11 The status of NRC commitments is as follows: there 12 are 416 NRC restart action items. Ninety-one of those items 13 are closed. Two hundred and fourteen items are considered 14 complete by line managers and closure documentation is being 15 independently checked. One hundred and eleven items still are 16 in progress.
17 An additional result of the closure process is j 18 training of line managers. The independent checks and feedback 19 keeps attention focused on achieving the desired results. The 20 independent checks are finding that the managers are upgrading 21 their standards as a result of the feedback.
22 The power ascension program, which originally was to [
l 23 be an appendix, now will be submitted separately in about two 24 weeks. I now would like to introduce our station manager, Ken l
l 25 Roberts, who will discuss the power ascension program, j
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1 MR. ROBERTS: Thank you, Ron. Good afternoon. I'm 2 Ken Roberts, Pilgrim Station Manager. I am a graduate of i 3 Northeastern University College of Business Administration, the 4 Executive Management Development Program at Andover. I have 5 over 22 years' nuclear experience, including six years in the 6 Naval Nuclear Submarine program.
7 My commercial experience includes holding senior 8 reactor operator licenses on both pressurized and boiling water 9 reactors. I spent.approximately seven years with Northeast l 10 Utilities at Millstone I; I served as a Net Senior Reactor 11 Operator during construction and test and' commercial operation, 12 of Millstone II. I was employed by the Power Authority of the 13 State of New York as Refuelling Manaaer and Senior Reactor l
() 14 Operator. I was the Senior Reactor Operator when the operating 15 license responsibility was transferred to the Power Authority 16 of the State of New York.
17 I was employed by the Nuclear Regulatory Commission l
18 in Region One as a Resident Inspector. I joined Boston Edison 19 in 1980 as Chief Maintenance Engineer. I was promoted to 20 Director of Outage Management in 1983 and directed Pilgrim's 21 very successful recirculation pipe replacement outage. I i 22 assumed my responsibilities as Station Manager in February of j 23 this year.
24 The power ascension program is the final phase of our
'l 25 restart plan. It is the mechanism by which Boston Edison will
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31 i i demonstrate the effectiveness of our actions. This 2 demonstration of effectiveness will prove to ourselves, the 3, NRC, and the public, that Pilgrim is operating at standards of 4 excellence. I'll cover the following: the objectives, testing 5 sequence, and the readiness and performance assessment process, 6 including the organization and process structure.
7 The objective of the program is to bring this station 8 to full power in a careful, deliberate fashion. More 9 specifically, the program will demonstrate readiness for 10 criticality, and confirm performance of the nuclear 11 organization in-plant during power ascension.
12 The testing sequence: this sequence is a logical 13' progression for approaching criticality through 100 percent
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14 power testing. The sequencing of the test recognizes the !
15 following factors: it must follow the normal plant operating 16 sequence, which is dictated by design and recognizeipoints of 17 stability. It must satisfy technical specification 18 requirements. It must provide assessment review periods during 19 which management can evaluate performance, take corrective 20 action, and determine that we are ready to proceed. ~This is 21 not to infer that immediate actions will not be taken as 22 appropriate. ]
1 It must provide evaluation points as requested by the j 23 24 NRC. It must provide for the training of our recently-licensed 1
25 reactor operators. It must be recognized that all of them I
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32 l- 1 should be identified in the sequence as early as possible. And s
g 2 prior, relevant industry' experience must be considered.
3- Your handout has a more detailed description of the
'4 major' activities that will occur at the various steps. The
'5 first Boston Edison management evaluation and NRC approval 6 point is just prior to criticality. Once management.and NRC J
7 . approval are obtained, the reactor will be taken critical; the 8 plant will be slowly heated -- as we are raising temperature t
9 .and pressure we will be conducting routine tests, as well as a 10 test of the. main steam isolation valve's ability to open with' 7
11 normal differential pressure across it. This test is a 12 verification that we have corrected one of'the problems 13 relating t,o our confirmatory action letter.
(). 14 We will also' conduct tests that monitor a low-15 pressure system for in-leakage from the reactor. This test 16 identifies a second problem -- this test addresses the second 17 problem relating to our confirmatory action letter. This inner 18 system leakage test will-be' repeated throughout the power 19 ascension program. i 20 When we have achieved normal operating pressure and 21 have duplicated normal shutdown conditions, we will then .
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22 initiate a normal shutdown, shift the mode switch to start iup, 23 and then decrease reactor pressure-to test the mode switch.
24 This is.the third problem relating to our confirmatory action 25 letter. If the main steam isolation valves remain open, and
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a 33 h 1 they.should, we will then. return to approximately 25 to 30 2 percent power to build-in some decay heat. The decay heat will j J
3- allow us to properly conduct our shut-down from outside the
'4 control room test. We will also conduct training for new f
5 reactor operators at this time.
6 This brings us to the second Boston Edison management 7 evaluation and NRC approval hold-point. Once Boston Edison 8 management and NRC approval is obtained, we will proceed'with 9 our shut-down from oute'ide the control room demonstration. A 10 full walk-through and briefing will occur prior to commencing 11 this demonstration. It is possible that management may elect 12 to proceed to= cold shut-down at this time in order to cond'uct-13 any corrective maintenance that has become necessary during the
.O 14 initial operation of the plant.
15 We will then proceed to 50 percent power and conduct 16 normal testing and calibrations, as well as conduct new reactor 17 operator training. This is Boston Edison's third management 18 assessment evaluation point. When we have completed these 19 activities and received Boston Edison management approval, we 20 will proceed to the 75 percent power and again conduct normal 21 tests, calibrations, new operator training.
22 Boston Edison's fourth management evaluation training 23 is also an NRC approval point. With Boston Edison management 24 and NRC approval, we will proceed to 100 percent power, conduct 25 normal testing calibrations and Boston Edison will perform its
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a 34 1 fifth management evaluation.
2 The management assessment process: to ensure that 3 the objective is met, the managmenet assessment process 4 includes assessments of: management performance; operational 5 performance; plant and equipment performance. The only_
6 organ 1zation that will exist during the power ascension phase 7 from) dust prior to criticality through completion of 100 8- percent power testing consists of three elements: the normal 9 operating element; the normal, post-refuelling modification 10 ~ outage test element; and an additional oversight assessment 11 element
. 12 I have emphasized " normal" on the slide to ensure 13 that we understand the normal line organization structures are O 14 not inflated such that our self-assessment process would be 15 invalidated.
16 Pilgrim start-up organization. The normal operating 17 elements include: shift operating crews and their normal 18 management; technical support / maintenance; health physics; 19 chemistry; security; fire protection; quality control; and 20' oversupport organizations, is required.
21 The post-refuelling modification outage test 22 organization indicated by shaded boxes on the transparency, is 23 a normal matrix organization that Boston Edison has utilized 24 during start-ups from complex outages. This practice resulted 25 in a very successful start-up from our pipe-replacement outagqg)
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35 1 We have recognized that our equipment operators do not have the 2 extensive experience with the plant in operation who will 3 provide additional experience and guidance in this area. We 4 will have an additional senior reactor operator on each shift 5 who is designated as Assistant Watch Engineer. He will provide 6 additional direction and guidance to these auxiliary operators.
7 The senior management oversight organization. Senior 8 management will provide oversight of major evolutions during 9 restart and power ascension. The senior management oversight 10 organization has six members. They are: the Senior Vice 11 President, Nuclear; Vice President, Nuclear Engineering Quality 12 Assurance; the Executive Assistant to the Senior Vice 13 President, Nuclear; the Director of Planning and Restart; the O 14 Nuclear Engineering Manager; the Quality Assurance Manager.
15 Senior management oversight support includes on-shift 16 individuals with current or previous boiling water reactor 17 senior reactor licenses or certifications. They will act as 18 on-shift operations observers. On-shift watch billet 19 assignments are for highly experienced and qualified 20 specialists in such areas as radiological controls and 21 maintenance, to observe specific evolutions of interest and to 22 report results to senior management oversight organization.
23 The readiness and performance assessment process --
24 Boston Edison will implement a structured process for 25 management self-assessment of: one, our readiness for initial Heritage Reporting Corporation (202) 628-4888
36 I criticality; two, performance of a nuclear organization and 2 plant during power ascension. ,
3 As previously indicated, Boston Edison evaluation 4 points are specified at prior to criticality after recovery l l
5 from mode switch testing during 50 percent reactor engineering 6 tests; 75 percent reactor engineering tests; to 100 percent 7 power. We have proposed NRC approval points at criticality.
8 After recovery from mode switch testing, and after the 75 l
9 percent reactor engineering tests, j 10 The Boston Edison readiness assessment process before 11 criticality will consist of the following three elements:
l 12 first, senior management will formally review and approve of 13 restart prerequisites following certification by a responsible f-V 14 line management. Second, restart prerequisites to be completed i
15 will include: the restart plan, Appendix 10. Those are the 16 regulatory responses. The plant operating condition checklist, 17 number 6, which is the pre-critical test plant start-up 18 checklist. This includes a review of plant system status prior 19 to new systems review, the systems group, and an approval of 20 the checklist by the operations review committee.
21 The restart actions and the material condition 22 improvement plan. The restart actions and the radiological 23 action plan. Third, the restart plan, chapter five, 24 established a basis in management assessment and readiness for 25 criticality. This is a structured, but necessarily ,
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O ~1 -- qualitative, assessment. Input to this assessment includes the 2 prerequisites, and the results, of the programs, plans and 3 actions of the restart plan.
4 The Boston Edison process for performance assessment 5 at each evaluation point will consist of the following five
.6' elements: performance will be evaluated by line management on 7 a.real-time basis. The senior management oversight 8 organization will perform independent evaluations'with input 9 from observers assigned to support them. The observers will be 10 designated by senior management and will consist of personnel 11 experienced in operations and maintenance, radiological 12 controls and.other pertinent disciplines.
13 Performance standards are being developed to guide.
O 14 these evaluations. Guidelines for follow-up and feedback l 15 lessons. learned will be developed. This will include guidance 16 for determining the immediacy of feedback. Observers will be 17 trainedtothestandardsandfeedbackguidelines)'[riorto 18 entering a given evaluation period in which they will 19 participate.
20 The performance assessment process described above 21 will address the following types of questions: [rethe' 22 operators operating the plant safely and conservatively? Is 23 the plant equipment operating reliably? Is assessment and l
24 feedback of lessons learned effective? Is the organization 25 ' functioning as a team? Is management oversight effective and 1
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38 I 1 are they knowledgeable about current plant and organizational ,
to 2 conditions? ,
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3 We are developing a written submittal on the power 4 ascension. program, and plan to have it completed in about two-5 weeks. I would now like to introduce Don Gillespie who will 6 discuss the outage scope.and schedule.
7 MR. GILLISPIE: Thank you, Ken. Good afternoon. I'm 8 Don Gillespie, director of planning and restart at Boston 9 Edison. I'd like to give you a few minutes of my background 10 before I get started. I have over :20 years of nuclear 11 experience.. I have a B.S.' degree in Electrical Engineering.
12 I'm SRO-certified on a Westinghouse pressurized water reactor; 13 and I spent six years in the Nuclear Navy program.
O 14 My commercial experience includes experience with two
- A 15 utilitiesA in the Institute.of Nuclear Power Operations. The 16 two utilities were Duke Power. I spent time out at Occonee in 17 the early start-up and operation there, and with TVA at Brown's 18 Ferry and Sequoyah.
19 My last seven years prior to joining Boston Edison 20 was with INPO and my last position there was deputy director of 21- the plant support division of the evaluation and assistance 22 group. I was responsible for plant evaluations and health 23 physics, maintenance and outage management. Prior to that I 24 was a manager of nuclear engineering and construction at Rancho 25 Seco, on a loan program at which INPO loans a manager'to /I ;
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39 'j 4 .1 utilities on an improvement' program. That was a pilot program 2 by INPO. .
3 Other experience at INPO I was the Manager of the 4 Events-Analysis Department, and I worked jointly with the 5 ' Nuclear Safety Analysis Center at the Electric Power Research 6 Institute to. develop the' industry's operating experience 7 program, the CN program. I was'also qualified as an INPO' ,
8 plant and' corporate team manager, an instructor in INPO's 1
'9 Senior Nuclear Manager's. Training Course. j i
' 10' I'd like to talk about the outage scope-and outage- j i
11 schedule. Scope first. The most fundamental management task 12 in the restart effort was to identify and characterize 13 outstanding work items such as maintenance request and plant O 14 design changes. While we expect to complete approximately 15 8,000 maintenance requests, and install approximately 150 plant 16 design changes, including such things as the safety enhancement 17 program, which Ed Howard will status later, security system 18 upgrades, Appendix R, hydrogen water chemistry program, which 19 is hydrogen injection into the feedwater.
20 We installed analogue trip systems, replaced HFA 21 relays, installed a plant-specific sin s tator, and a new process 22 computer, and many others that I won't mention at this time.
23 Rather than to give you the details of how we plan to 24 accomplish that work, I think it would be appropriate to c ov 6t-3 25 discuss briefly our approach in scoping the outage. It eeste a
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40 1" large' amount of work and expanding scope. The managers and the 2 systems'at-Boston Edison-are heavily loaded, as you heard Mr.
3 Bird mention. To help relieve this situation, vna established' a 4 temporary organization titled " planning and restart" to develop 5 scope, plan,__ schedule, identify resources, and progress the 6 outage work. This organization does not dry-production or
.e .
7 suppliant the normal line management. As you also heard, we.
8 have~an outage manager who reports directly to the plant 9 manager, which is responsible for plant outage production.
10 .The planning and restart group is comprised of'four 11 primary functions. First, work authorization'and control,
.. 12 which is simply an organization set up to control methodology 13 and a process for identifying scope of the outage. The;next
( )D 14 step, after. identifying the scope, is the planning and 15 estimating group, is simply the group that develops the l
l 16. integrated plans and schedules for the outage.
i 17 The next one we set up was material readiness, 18- because approximately 25 percent of the maintenance requests at
.I 19 Pilgrim were on hold because'of material problems. We !
i' 20 established.the group to procure, expedite and stage materials 21 for work.
22 And last, but not least, the work progress group, 1
23- which is a kind of a management oversight group to help 24 identify problems and assist line management in resolution of j
25 these problems to progress the outage. Interesting enough, l C
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l 41 1 these functions correlate with my INPO experience in the outage ,
2 management and the problems that -- excuse me, in. plants that 3 get into long, delayed outages, exclude those and we get 4 involved in major equipment replacement, such as steam radu.\c.%
5 generator or resourse piping. These are the areas that 6 generally bring down plants on our outage schedules.
7 The planning and restart group is made up of 8 experienced managers both from Boston Edison and from 9 organizations th'roughout the nuclear industry. For example, we 10 have a Vice President of Engineering from a major architect 11 engineering firm; an assistant construction manager from a 12 major architectural engineering firm; and several executives 7, 13 from small to medium-sized consulting firms, to help us.
V 14 It is made up of approximately 20 people with over 15 400 to 500 collective man-years of experience. To extend our 16 benefits from this temporary group, we plan to integrate into 17 the permanent organization the new and revised systems, 18 procedures and functions developed during this outage, as well 19 as some of the better contractors, we hope, i
20 Now, I would like to talk about cur outage scope 21 approach. This is actually three steps. Our initial step was 22 to develop guidelines for inclusion of work in the outage.
23 These guidelines were designed to prioritize work items 24 according to their impact on the safe and reliable operation of l
25 the plant. These can be found in the restart plant in chapter l
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42 1 3 on page 27. They cover three broad areas. First, plant 2 technical, and a few questions, example questions,in there I'll 3 read: "if the item fails, will the plant safety degrade? Will 4 .the plant be put in a limited position for operation? Will 5 plant availability be severely impacted? What is the 6 probability of failure between outages? If the item is 7 identified during operation will the plant be shut down 8 immediately?"
9 Under another broad area, external requirements and 10' commitments, such questions as, "is the item an NRC requirement db 11- from technical. specs or'fFSAR? Is the item an NRC commitment,
..- 12 particularly a restart commitment? Is the item an INPO 13 commitment, or an American Nuclear Insurer commitment?" And then the last broad area was Boston Edison's own management
-14 15 commitments.
f 16 Next, we reviewed the outage work' items. This was 17 done in two ways, with the vertical reviews and the horizontal
.18 reviews. vertical review was simply the line organization 19 reviewing open work items against the guidelines and assigning 20 priority. For example, both operations and maintenance 21 reviewed and prioritized corrective maintenance work requests.
22 In addition, we established horizontal reviews to get 23 another look, using our system engineers, our newly formed 24 system engineering group, to review outstanding work items on a 25 system-by.-system basis utilizing the same guidelines.
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43 1 And last, but certainly not least, is the approval 2 process. We established a work scope review committee to 3 facilitate management identification, review and approval 4 particularly, of work to be included in the outage schedule.
5 This committee included the manager of O/A, the Plant Manager, 6 the Engineering Manager, the Outage Manager, the Training 7 Manager and a planning and restart representative.
8 The Plant Manager was the chairman. This committee 9 reviews all plant design changes and priority one MRs. 'And of 10 course, the final step on selected items, approvals are 11 required by the Senior Vice President, Nuclear.
12 The process, by the way, using the guidelines, 13 reviews, and approvals, is continuing for emerging work, and 14 will so until the outage is complete. The work scope review 15 committee meets as necessary and generally two to three times a 16 week.
17 Last, I'd like to talk about what is remaining in the 18 outage schedule. The whole background on our philosophy of 19 scheduling, we have chosen to develop a tight, no-contingency j 20 schedule to shorten our overall outage time. While this has 21 down-side, we believe it is the best approach to bring our 22 production skills up quickly and help break the construction-23 outage syndrome that plants tend to get into when they've been 24 in long outages.
25 The remaining schedule you see contains the following
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44 1 major milestones, which~are pretty normal for this vintage ,
- . 2 plant at this stage
- reload; vessel reassembly; hydro; j 3 integrated' leak-rate testing; remainder of our surveillance and j 4 modification post-work testing; and.our' checklist, which you 5 heard mentioned earlier. And we're ready for start-up. ,
.6 Any' problems identified along this leg, and most of 7 this is testing -- there is also a whole test block underneath
- c. A l 8 this -- ped to the. time. The six-a-week to 12 weeks you see 9 there'has really been'our history. Our range has historically 10 .been between six and 12 weeks to complete this.
11 In comparison, our last outage, when we were down for 12 approximately one year for recire pipe replacing, took eight 13 weeks from the start.of refuel to restart. We expect to start O 14 loading fuel this weekend.
15 And now, I'd like.to introduce Ed'Howard, our Vice 16 President of Engineering and Quality Assurance, to discuss the 17 safety enhancement program, and our emergency procedure 18 upgrade.
19 MR. HOWARD: Thank you, Don. Good afternoon. I am 20 Edward Howard, Vice President of Nuclear Engineering and 21 Quality Assurance for Boston Edison. I have a bachelor's of 22 science degree in engineering physics, and have 32 years of 23 nuclear experience. I began my career at DuPont in 1955 as a 24 shift supervisor of the reactor operations department at I 25 Savannah River.
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1 I joined Yankee Atomic Electric Company in 1957 where 2 I participated in the nuclear design, safety analysis and 3 licensing of the plant at Rome, Massachusetts. I obtained an I 4 AEC operator license and later a senior operator license when 5 the regulations moved to the two-part licensing at Yankee, and 6 served as reactor engineer at the station during initial 7 start-up and testing of that facility, and remained on the 8 plant staff until 1963 through several refueling outages. I 9 was later assigned to the home office to work on the design and 10 safety analysis for the Connecticut Yankee plant.
11 I joined Boston Edison in 1966, learned something 12 about boiling water reactors, and have been involved in the 13 design, safety analysis, licensing, start-up and operation of 14 the Pilgrim plant since that time.
15 Boston Edison is implementing a safety enhancement 16 program which includes both equipment modifications and 17 procedure improvements. While Boston Edison has expended -
18 significant resources on the safety enhancement program, these 19 proposed improvements generally exceed present NRC 20 requirements, and therefore should not be a restart 21 consideration. I intend to present today only a brief update 22 on the current status of implementation for these improvements.
23 We submitted a report to the NRC describing our ;
24 proposed modifications in early July of this year, and we j 1
l 25 received a request for additional information from the staff in
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1 late August. Responses to these questions are in preparation 2 and will be provided to the staff next week on all 3 modifications with the exception of the direct torus vent 4 system. Additional analyses are required to provide the 5 information requested on the direct torus vent.
6 Installation of the direct torus vent has been placed eila e 7 on hold based on the NRC's direction. Installation of eer 8 modifications is proceeding. Construction is expected to be 9 complete with the exception of the new emergency diesel by the 10 end of October, and the new emergency diesel is scheduled for 11 completion in November.
12 Upgrade of our emergency operating procedure,as based 13 on Revision 4 of the boiling water reactor owners group O 14 emergency procedure guidelines,is also in progress. We expect 15 to have these improved emergency operating procedures in place 16 at restart. These Revision 4 guidelines were developed by the 17 boiling water reactor owners group as a comprehensive upgrade 18 of earlier revisions, and is responsive to open items from 19 previous NRC of Revisions 2 and 3.
20 We have elected to proceed with early implementation i
21 of new emergency operating procedures, because they are ]
22 technically superior to the earlier revisions. We recognize 23 that additional changes may be necessary in the future when the 24 NRC staff completes their generic review of Revision 4.
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25 . However, we judge the benefits from using Revision 4
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s 47 Y~ 1 as approved by the owners group and General Electric to be 2 sufficient to justify proceeding properly even though we may be 3 required to make additional improvements in the future.
.4 The appropriateness of this approach from the 5 regulatory' prospective was informally reviewed with the staff 6 last spring, and we received encouragement to proceed with 7 early implementation. Our plan for implementing improved
.8 emergency operating procedures was reviewed with the staff at a 9 meeting on August 4th, and again the staff endorsed our 10 proceeding with our effort on Revision 4.
11 We are proceeding to implement the plan that we
.. 12 described at that meeting. Plant specific technical guidelines 13 and new emergency operating procedures have been prepared.
14 Preliminary verification and validation has been completed.
15 Classroom training for operators has been completed, and 16 simulator training for operators is scheduled to be completed-17 at the end of next week.
18 Staff has requested another meeting in mid-October,
- 19. 'and we are coordinating scheduling to provide an opportunity 20 for additional discussion on emergency operating procedures, 21 and to provide an opportunity for them to observe the use of 22 these procedures on our simulator.
23 That completes my status report. Our next speaker is 24 RonVarley,whowilldiscussof((kiteemergencyplanning.
25 MR. VARLEY: Thank you, Ed. I am Ron Varley, staff
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48 1 assistant to the Senior Vice President, Nuclear. My background 2 and previous experience includes nine years in the Navy's 3 nuclear propulsion program, three years with Westinghouse l 4 Hanford at the Fast Flux test facility initially as an l
5 instructor for operator training, and then as their first site 6 emergency preparedness coordinator.
7 I spent five years in the consulting field providing 8 emergency preparedness consultation to Waterford 3, Beaver 9 Valley, and finally at Shoreham during the initial 10 establishment of the LILCO/LERO off site emergency planning I 11 program.
12 Most recently, I worked two years at the Toledo 13 Edison Davis-Besse facility as the emergency preparedness 14 manager, and oversaw a major revision to their emergency 15 preparedness program there.
16 I joined Boston Edison in June of this year, and was 17 given the assignment for assessing and resolving the emergency 18 preparedness issues that surround the Pilgrim Station.
19 This afternoon, I would like to touch on three areas 20 which are the essence of the emergency preparedness issues at 21 Pilgrim. These are the current atmosphere of cooperation 22 between the Commonwealth, the towns, and Boston Edison; the 23 efforts underway to upgrade the state of emergency 24 preparedness; and to resolve the FEMA self-initiated review 25 issues; and our emergency preparedness exercise schedule.
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l 49 1 Within the past few months, we have seen a 2 significant improvement in the relationship and the level of 3 cooperation between the Commonwealth, the towns, and Boston 4 Edison. This spirit of cooperation is having a significant 5 positive effect on the efforts underway to upgrade the Pilgrim 6 off site emergency preparedness program and in addressing the 7 FEMA self-initiated review issues.
8 As examples of some of the areas where Boston Edison 9 is participating in this upgrading effort, we have four 10 professional planners who are actively assisting the 11 Commonwealth civil defense officials in upgrading the ,
12 Commonwealth's plans.
13 Two Boston Edison planners per town are actively 14 assisting the local authorities in upgrading their emergency 15 response plans. And in addition to that, Boston Edison has 16 offered to fund full-time civil defense staff positions in each 17 of the emergency planning zone towns and the reception center 18 communities. To date, four of the five towns in both of the 19 reception center communities have accepted our offer.
20 We are providing assistance in upgrading and 21 renovating the towns' local emergency operations centers, and 22 we have offered to provide compensation to all of the emergency 23 workers for classroom training attendance and for their 24 participation in drills and exercises.
25 To ensure that all of the parties involved in this
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1 upgrade effort are adequately informed, we are having weekly 2 meetings between senior Boston Edison management and senior 3 Commonwealth officials. And also on a weekly basis meetings 4 are being held at the working level between the Boston Edison 5 emergency planners, town civil defense representatives, and 6 Commonwealth civil defense officials.
7 As part of the overall effort to upgrade the off site 8 emergency response program, the Commonwealth, towns, and Boston 9 Edison have agreed upon and are implementing a program for 10 addressing the FEMA issues. The activities currently underway 11 have been documented in our action plan and schedule which was
.. 12 transmitted to the NRC on September 18th. This was in reply to 13 Mr. Varga's letter to Mr. Bird on August 18, 1987.
(~) 14 It needs to be pointed out that a significant amouit 15 of updated planning information is already available and is 16 currently being utilized to address the FEMA issues. Some'of 17 this information includes an updated evacuation time estimate, 18 beach shelter studies, and a survey of the special needs and 19 transportation dependent populations within the emergency 20 planning zone.
21 With respect to the FEMA self-initiated review, FEMA 22 has identified six basic emergency planning issues, as we have 23 illustrated on this transparency. When we revlewed FEMA's 24 report, we further subdivided their six primary issues into 25 several sub-issues and prepared an action plan and schedufe
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9 3 Letters of agreement will bd ql.ltnined as necessary to 10 fouclizel.heagreementswithtranspoyte.tio3hroviders, and l
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14 availability. We are currently evaluati 9 +.hd feasibility of 15! s using;.iwo reception centers while the Cominonwealth continues ?s 16 sea pn f,nr a third center. We expect that the analysis of the t .
17 avellability and ucability of the two reception centers will be 18 completed by abmt October 1st. N ,
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l 1 about December 15th- l 2 FEMA issue number four deals with specidl needs 3 popuistion planning. We unpect to complete the process of 4 identifying all special mobility impaired persons by about 5 December 15th, and will develop, procedures for keeping this l
6 data base up to date. J 7 Issue number ilve relates to transport.ation dependent
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8 populations. And in this area, we have developed the estimated )
9 number of transpc tation dependent persons in the emergency i
10 planning zone, and are currently refising the necessary plans,
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l 11 and we expect that<to be completed by about October 31st.
12 The sixth issue is essentially an administrative 13 ishue which we feel will be reversed by virtue of the fact of 0' ! 14 the extensive work that is being done in the town and state 15 plans over the course of the next several months. I 16 In terms 7.sf established goals for resolving these 17 issuen, the town plan revisions including.all of the changes 18 necosaary to adcress FEMA's self-initiated review issues should 19 be. completed by about October 31st. The efforts will not stop )
20 there.
21 The goa.1 is to have all of the procedure revisions 1
22 and the state plan modifications completed by the end of the !
l 23 year, and the majority of the personnel training accomplished 24 by tald-February of 1988. With continued cooperation amongst j 25 the" parties, we think that this schedule can be met. We are
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53 1 working closely with the state, and the state is-maintaining 2 close touch with the FEMA region to bring about.the orderly-3 resolution of the planning issues.
.4 With respect to Pilgrim's exercise schedule, Boston
.5 ' Edison has scheduled an on site exercise for the week of 6 December 6th. 'There will be limited Commonwealth participation 7 in the exercise process when they will demonstrate some of the 8 aspects of their off site planning program. Boston Edison 9 transmitted a letter to the NRC describing our program schedule 10 and the objectives on September 18th.
1 11 .Although 1987 was to be a full scale exercise year,-
_- 12 we believe that a much more beneficial and meaningful full 13 participation exercise can be conducted af ter the pending of f-(5) 14 site program improvements and facility upgrades are made. It 15 will be prudent to have the biennial full participation 16 exercise rescheduled in order to permit the extensive off site 17 upgrade efforts underway to continue at the pace that they are 18 continuing, and to be effective in resolving FEMA's concerns.
19 Accordingly, in order to reschedule the full 20 participation exercise, Boston Edison submitted a request for 21 an exemption from the biennial full participation exercise 22 requirement on September 18th.
23 To conclude, there is a strong degree of cooperation 24 between the Commonwealth, the towns, and Boston Edison that is 25 manifesting itself in the effort to upgrade the of f-site F
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54 1 emergency response program and to address FEMA's issues. l 1
2 Boston Edison believes that the program presently underway will l
3 result in the effective resolution of FEMA's concerns, and more 1
4 importantly in a significantly improved overall off site 1
5 emergency planning program for Pilgrim.
6 MR. BIRD: Well, that concludes what we have prepared 7 to tell you. Can I deal with any questions from the NRC staff?
8 DR. MURLEY: I'll start. I guess I'm pleased to see 9 the logic well-layed out, and that you are addressing all these 10 issues and that there are signs of improvement all the way 11 through, including emergency preparedness improvement.
. 12 Again, we're -- I guess I've seen signs of 13 improvement all along for the last two or three years, only to 14 see something slip back. We don't expect that this time. But 15 I only say that to caution you that we're going to be very 16 skeptical and we're from Missouri.
17 MR. BIRD: We are acutely aware of that from your 18 reputation, believe it. And we are determined that we will not 19 have that reputation in the future.
20 DR. MURLEY: Okay. Now, let me ask the staff if 21 there are any questions here that anyone has? Dick?
22 MR. WESSMAN: I have one. I guess I'll direct it to 23 Ron Ledgett and I guess it relates to the restart plan. I 24 guess I'm not clear how you are differentiating those issues i 25 that you are going to deal with and close before the restart
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-t l' and those that you will elect to defer until after the restart?-
2 Because clearly;the. staff is interested in those which you 3 elect to' defer, and why? Can you help me out in what your 4- plans are in that area?
l L' ~5' MR. LEDGETT: There are two major. points on'that one.
6 In the Boston Edison self-initiated review in the material-7 area, the criteria for identifying' items that should be 8 complete prior to restart and those after stated in the 9 foreword to that. I think they are quite clear.
10 In the regulatory data base, which is basically.
11 Appendix 10 of Volume II, all of the. existing licensing
.- 12 commitments and all other correspondence associated with the 13 potentially associated with restart, up over some 3,000 items
'O 14 or more were reviewed by a team of senior Boston Edison people 15 to identify any item that could conceivably have an impact on 16 restart. And that is what basically formed the items that are 17 in Appendix 10.
18 MR. BIRD: If there was doubt, we put it in.
19 MR. LEDGETT: Exactly.
20 MR. WESSMAN: Will we be able to see what is not put 21 in so that we can take a look and make a decision?
22 MR. BIRD: Absolutely. Any time you want to.
23 MR. LEDGETT: Yes, you can. and let me lay that out. l 1
24 Basically, anything that is in any one of program documents, j 25 like 86-41, is in there. Any of the periodic management )
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f 1 meeting minutes we had there for a while -- those items have 2 all been put in there. There of course is the normal licensing 3 and compliance tracking system and there are quite a large 4 number of that at any given time. Those are being processed in 5 the normal fashion.
6 Some of those come up and are restart items. Where 7 they are we add them to the hopper, but many of them aren't.
8 They have their own schedule associated with them.
9 MR. BIRD: But there are examples?
10 MR. LEDGETT: But they're easily reviewed.
11 MR. BIRD: I&E notices that have come in? For 12 example on some order brackets that we felt we would like to 13 look at before restart, so we did. As those things come in, O 14 each new item is assessed, whether we should add it to the 15 audit scope or not.
16 MR. WESSMAN: Okay, thank you.
17 MR. BIRD: Any other questions?
18 DR. MURLEY: Yes. Ed, you didn't discuss, I guess, 19 in detail, your plans for addressing the questions on the torus 20 vent. Were you going to do that as -- are you going to deal 21 with those questions as part of this restart issue, or are you 22 dealing with it with the G-E owners group as part of the Rev. 4 23 broader issue?
24 MR. BIRD: Does that microphone work? Just pull it 25 over and see if it works.
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~1 MR. HOWARD: We're not planning to seek to. resolve 2 that in a restart time frame. So we will both be' proceeding to i
3 do' additional analyses on our'own plant-specific basis, but.
! 4 Lthen working with'the owners group to see if we can't help 5 support a more generic base. response.
l 6 MR. WESSMAN: So we may be talking in terms of months 7 instead'of weeks?
8 ME. HOWARD: I don't'think it will be weeks. I don't 9 have a schedule yet for what'is involved in our own effort,but
. 10 in order to be responsive to the kinds of concerns that have 11 been expressed, we felt that it was important to go back in our 12 own modelling and be sure long-term recovery actions were more:
13 carefully modelled.
~() ' 14 In implementing the procedures if recovery;took j
q 15 place, then the procedures would work properly. But we may be, .
I 16 unless we model that carefully we may be overstating the 17 frequency with which mending is a benefit and I think that-18 would not be supportive of the kind of information that was --
19 MR. BIRD: Can everybody hear the questions and 20 answers if the respondents remained seated? Can you hear down 21 at the end? It's easier that way.
22 MR. WESSMAN: Ed. Let me ask you to summarize the j 23 physical configuration of that direct torus vent? Where it is 24 in the plant and exactly, you know, what it physically looks 25 like and where you have left it at this point in time?
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l r 58 1 -MR. HOWARD: The install'ation of the system, the
'2 vent system is-proceeding with the exception.of the valve j
3_ installation. The valve will not be' installed and the. piping .
.1 4 penetration will be Blank-flanged, double-gasketed and' ,
5 subjected to the normal containment leak rate testing. In d 6 essence we've got stub-ends. If the generic' review of EPGs
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l 7 determined if this issue were to be resolved in the course of l- 8 review of the generic EPGs, then I believe we would be able to .f 9 . proceed with. installation later in a fairly easy way.- It would
'i 10 probably take an outage. It wouldn't be long. l
. 11 MR. BIRD: Ed, about how long would it'take to
. 12 complete the installation?
- 13 MR. HOWARD: After we went into operation? I'm not-- .
O- 14 MR. BIRD: If we chose to do it afterward.
15 MR. HOWARD: Well, it wouldn't take'long to install 16 the valve, but there may be other questions arise in the 17 detailed design review. We've proposed a. revision to'the I
18 design to simplify the isolation controls, and therefore deal j i
19 with some of the concerns that were expressed. And there were
-20 features in the original design that had some advantages. At 21 this point in time we're not proceeding with any implementation 22 of the isolation system. We've got a much simpler design.
23 We're basically proceeding with the mechanical system in blank 24 flanging. So if other features of the design as-proposed are 25 attractive, then more time, would be required.
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i-59 i 1 MR. BIRD:L Okay. I don't think that microphone has 2 any value.
3 MR. WESSMAN: It-is. It helps the Reporter.
4 MR. GILLISPIE: Would you like an estimate on'-- we 5 sort of talked about an estimate on it. We don't think it 6 . would take'long. We think.less than a week. Probably.three
, 7- ' days, four days at'the latest on the'outside.
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- Let me ask folks again to identify I
9 themselves when we do exchange questions so the court reporter 10 is able to keep track of who's speaking.
11 MR. BIRD: The last response was from Don Gillespie.
.- 12 MR. RUSSELL: I'd like to go back the restart plan 13 flow chart, if we can have that'one --
O- 14 HR. BIRD: Put back up?
15 MR. RUSSELL: -- put back up for just a moment. And
, 16 what I want to do is I want to emphasize some of the 17 assumptions were that went into this schedule, and the 18 principal one being that the NRC would schedule it's diagnostic 19 inspection at the point in time when we had sufficient 20 information to be a meaningful inspection. Now, the assumption 21 on the part of the company is that when the appendices to 22 volume II come in, that they would have sufficient detail and I
23 sufficient completion status that we would be able to conduct I I
24 that inspection.
25 MR. BIRD: Correct.
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60 1 MR. RUSSELL: If-that turns.out to not be the' case, 2 the inspection will be scheduled when the facilit and the 3 . equipment is complete.
4 The second observation is that we have a substantial 5 amount of. inspection activity going on throughout. We've been 6 expending in excess of 6,000 inspection-hours per year at'the 7 facility. The diagnostic team inspection, as contrasted to the 8 on-going inspection activities, is intended to be an assessment 9 of how-well things have come together at the end. And it will 10 include participation from NRC as well as the region, and as I 11 indicated earlier, we are having some dialogue with a 12 representative of the state being an observer at that 13 inspection.
O 14 MR. BIRD: For the benefit of.the observers, perhaps 15 you could consider that diagnostic as a final' examination?-
16 MR. RUSSELL: It would be in part. It relates
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17 principally to category one issues that Dr. Murley described.
18 Issues associated with plant readiness -- management, et 19 cetera. Category two being the enhancement program, the 20 modifications that are associated with licensing review; and 21 then category three is, of course, the emergency preparedness 22 issues. So that the diagnostic team inspection is sort of the 23 final exam for category one, to put it in that context.
24 MR. BIRD: Okay. Other questions?
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25 DR. MURLEY: It looks like not, Ralph, so we thank Heritage Reporting Corporation (202) 628-4888 L_-___ _ ___1 _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ ___ _ ._ _ ._ _ _.
61 1 you very much for coming. It's been an informative meeting for 2 us. We appreciate the time you have put in on it 'and the logic 3 and the planning that has gone into this. So the meeting is 4 adjourned.
5 MR. BIRD: Thapk you very much.
6 [Whereupon at 3:00 p.m. them<d* Marih was concluded.)
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CERTIFICATE I 1
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This is to certify that the attached proceedings before the (
4 United States' Nuclear Regulatory Commission in the matter of:
5 Name: MEETING WITH BOSTON EDISON COMPANY re: Pilgrim Status and 6
Activities leading to Restart Readiness ;
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7 Docket Number: 50-293 8 Place: Bethesda, Maryland 9 Date; September 24, 1987 10 were neld as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and,
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13 thereafter reduced to typewriting by me or under the direction 14
,s-of the court reporting company, and that the transcript is a
\J 15 true and accurate record of t e for ng proceedings.
16 /S/ A I s 1 Mu i
17 (Signature typed): KENT ANDREWS '
18 Official Reporter 19 Heritage Reporting Corporation 20 l
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