ML20237F108
| ML20237F108 | |
| Person / Time | |
|---|---|
| Issue date: | 12/17/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8712290360 | |
| Download: ML20237F108 (95) | |
Text
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ORIGINAL se UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
Periodic ariefing on status of operation Reactors and Fuel Facilities Location: Nashington, D. C. 1 Date: Thursday, December 17, 1987 O Pages: 1 - 79 ) l l Ann Riley & Associates Coun Reporters \\ 1625 i Street, N.W., Suite 921 ~ Washington, D.C. 20006 (202) 293-3950
1 ) 1 O I SCLA 1 MER 2 S 4 5 i 6 This is an unofficial transcript of a meeting'of the 7 United States Nuclear Regulatory Commission held on 3 12/17/87 In the Commission's office at 1717 H Street, 9 'N.W., Washington, D.C. The meeting was open to public to attendance and observation. This' transcript has notL been 11 reviewed, corrected, or edited, and it may contain ? ( 12 inaccuracies. 13 The transcript is intended solely for general j i 14 informational purposes. As provided by.10 CFR 9,103, it is { 15 not part of the formal or informal record of decision of the i 16 matters discussed. Expressions of epinion in this transcript-. 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in-i 19 any proceeding.as the result of-or addressed to any statement i 20 or argument contained herein, except as the Commission may 21 authori=e. 22 23 24 25
I l t d 1 s' 1 UNITED STATES OF AMERICA i 2 NUCLEAR REGULATORY COMMISSION 3 i 4 PERIODIC BRIEFING ON STATUS OF OPERATION REACTORS 1 i 5 AND FUEL FACILITIES 6 7 PUBLIC MEETING i I B I 9 Nuclear Regulatory Commission 10 Room 1130 11 1717 H Street, Northwest i 12 Washington, D.C. k 13 14 Thursday, December 17, 1987 I 15 i l j 16 The Commission met in open session, pursuant to 17 notice, at 9:20 o' clock, a.m., the Honorable LANDO W.
- ZECH, 18 Chairman of the Commission, presiding.
19 COMMISSIONERS PRESENT: i 20 LANDO W.
- ZECH, Chairman of the Commission 21-THOMAS M. ROBERTS,. Member of the commission-I 22 FREDERICK M. BERNTHAL, Member of the Commission 23 KENNETH CARR, Member of the Commission 24 KENNETH ROGERS, Member of the Commission i
25: l
0, e 2 s'- 1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE: 2' 3 S. CHILK 4 M. MALSCH 5 V. STELLO 6 T. MURLEY 7-B. DAVIS 8 J. MARTIN 9 -B. RUSSELL 10 R. MARTIN 11 N. GRACE 12 H. THOMPSON 13 14 AUDIENCE SPEAKERS: 15 16 E. GORDON 17 J. AXELRAD 18 .F. MIRAGLIA 19 20 21 22 33 24 25
-) 3 t' ' 1 P'R 0 C E E D I N'G S 2 CHAIRMAN ZECH: Good morning,. ladies and gentlemen. 3 Today's' meeting is a periodic briefing by the Staff 4 concerning.the status of operating reactors and materials and 5 fuel facilities. I' understand that part of-this meeting'will" l 6 involve identification and discussion of thoseLlicensees that-7 the Staff has determined require increased'NRC attention and' 8 resources.- I understand the Staff will also include a brief 9 discussion of the operating reactors.orfother licensee 1 10 facilities the Staff.has determined can'be given reduced NRC ) 11 attention, including the level of NRC, resources generally' 12 applied-to such plants and the reason for the-Staff's 13 determinations. 14 I understand'that each of our Regiona1' Administrators ~ 15 and the Director, Office of Special Projects 'are.here'with us 16 today and are available to answer questions that.we may havee 17 I'd like particularly to welcome Mr. Bill Russell,- 18 Region I. I think this is the first of these meetings'that 19 you've attended. l And I understand Mr. Ebneter is here? 20 MR. STELLO: No. ) 21 CHAIRMAN ZECH: He's=not here. 1 22 MR. STELLO: His Deputy is here. 23 CHAIRMAN ZECH: All right. ' Jean' Axelrad is here. 24 Well, welcome to you, Jean. It's the first meeting that we've 25 had Special Projects. attending,-too, I believe. l i I u______________________________________-_
4 s' 1 I understand copies of the slides to be used today 2 are available at the back'of the room. 3 Do any of my fellow Commissioners have any opening 4 comments to make before we begin? 5 COMMISSIONER BERNTHAL: Well, I just want to make the 6 comment that I see that Staff has developed a fairly formalized 7 list here of categories for plants and status of those plants, 8 and I want to make clear that that is a staff categorization; 9 that's not a Commission position. We have learned by difficult 10 experience that the Commission should really take no position 11 on these matters. I appreciate this is a working document of 12 the Staff, and I will treat it and take it as such. 13 CHAIRMAN ZECH: And that's exactly what it is. I 14 would agree, this is a Staff presentation to the Commission, 15 and I think its value is to show us the priorities that they 16 are using and focusing on certain plants are reduced here or 17 increased in another area. I think it's a responsible action 18 to take. It will allow us at the Commission to give the Staff i 19 any particular direction we may give, and that's, of course, l 20 the purpose of the meeting, to hear from the Staff and their 21 views. 22 Are there any other comments? 23 COMMISSIONER BERNTHAL: Let me just make one further 24 comment. i 25' COMMISSIONER ROBERTS: 1 I have some specifics along. i s
7 Gr-5 s' 1 Fred's line when we get to some of these categorizations, 2 because you can't put these things into bins, and I will quote 3 Tom Murley, your quote on Tolstoy, and you'll know precisely 4 what I mean: "Every unhappy family is unhappy in its own way." 5 It is not workable to take this hundred-some-odd 6 plants and conveniently and bureaucratically put each one in a 7 bin. It won't work. 8 CHAIRMAN ZECH: Any other comments? 9 COMMISSIONER BERNTHAL: I have one other comment I 10 want to make, which I am sorry I neglected to bring up. l It's I 11 quite a separate matter, but one I think which may interest 12 certain individuals on the other end of Pennsylvania Avenue, 13 the far end, the east end of Pennsylvania Avenue, who currently 14 are wrestling with a single Administrator bill and the 15 provision therein for an independent Safety Board. l l 16 And I would just note here that Staff has compiled a 17 list, without any coaching certainly from me and I think not 18 from the Commission, of incidents and accidents having a major 19 impact on regulatory activities over the last 16 years, and I 20 would suggest that although the threshold may not be quite the 21 same, that this would represent the kind of threshold or the 22 neighborhood thereof that one would expect an ind.ependent 23 Safety Board to operate under. 24 l' And what's the number here, Vic, about 16 years, and -25 you've got two, three, four, five, six, seven, eight -- it
6-s' 1 looks like about 16, 17, maybe 18 incidents. 2 MR. STELLO: Seventeen. 3 COMMISSIONER BERNTHAL: That's about one a year. I 4 just want to make that comment. I think it speaks'for-itself. 5 It's a separate issue, but one I think'that.is going to undergo '6 quite a bit of d1scussion in the weeks and months ahead. 7 CHAIRMAN ZECH: Any other comments? 8 [No response.] 9 CHAIRMAN ZECH:- If not, Mr. Stallo, would you'begin, 10 please? 11 MR. STELLO: Thank you, Mr. Chairman.- 12 The comments that are made with respect to the idea 13 of generating the list, I don't want to spend a great deal of-14 time on it, but we need to have a way in which to identify the 15 plants that we believe we need to examine,' decide whether the 16 actions we're taking are appropriate are not; if not, what more 17 we ought to do about it. We try to find those plants for which 18 -- ade we'll be talking about those that have attributes that~ 19 we could learn from and perhaps incorporate those kinds of 20 attributes into our regulatory program to advance a state of 21. excellence amor .11 utilities. s 22 It's unfortunate that this can have connotations of 23 this; it's a natural product of trying to examine such a large 24 collection-of reactors, to identify those that need further 25 attention and why.
) 4 7 s' 1 As you-are aware, we've been engaged in this activity 2 now for the past two years. We're not as good at it as we \\ 3 ought to be. We're getting better each and every time we do l 4 it. 5 I think it is very, very important and very 6 fundamental to the-safety mission of this agency to be able to 7 do the.best job we can in identifying problems. I'm not going l 8 to sit here and tell you we're perfect; we're not. But we're 3 9 i going to do the best job we know how with the objective in mind a 10 that should there ever be any other incidents, we will at least 11 have been able to examine for ourselves whether or not all'that 12 should have been done at that facility, was it done? 13 That's the primary goal we keep in mind. We do not 14 ) want to be in a position and answer the question later after an 15 incident: Was there more we should have done? We want to 16 answer it now, and that's basically the primary purpose that 17 we're about. 18 COMMISSIONER, ROBERTS: Vic, I don't dispute your 19 motives or your motivation. i I just would do it slightly 20 differently. 21 MR. STELIO: Well, we: accept'any. help we can get to 22 guide us as a matter of policy from the Commission. We're more 23 than anxious to have it and certainly want it. 24 I have with me today, as you already pointed out, the 25 Regional Administrators and thesDeputy from the Office of
l 8 i J 1. Special Projects and Dr. Murley_ and Hugh Thompson,. who will' 2 take us through the' discussion. 1 3' What I'd like to be.able to do, if possible, iso be 4 able to go through the. briefing _ fairly quickly, and then come-5 back to any questions, because there's a story that we're going 6 to try to unfold, because this is'more of a briefing to give 7 you a little bit of the background on how we got here and the 8 results of what we had in the last meeting. 9 With that and no further introduction, I'll ask Dr. 10 Murley to begin, and when he's finished, then Htgh Thompson 11 will start with materials licenses. 12 CHAIRMAN ZECH: All right. Please begin, Dr Murley. 13 i MR. MURLEY: -Thank you, Mr. Chairman. 14 The senior managers of the Staff _ met in Atlanta 15 November 16th to 18th, and we discussed the performance of 16 operating reactors. Prior to that meeting, my senior staff in ) 17 NRR and each of the Regional Administrators ~and their senior 18 staff met on separate meetings back in September, and we 19 reviewed the performance of each reactor in the country. 20 From those screening meetings, then, we selected I 21 plants that we thought needed to be discussed and analyzed in i 22 more detail with all the senior. managers. 23 Ken, could you crank up the machine back there, 24 please? 25 [ Slide.] j
9' i 1 Today I'm going to discuss the highlights-of that-2 meeting and the plants that we discussed, but 'irst some f 3. historical background. 4 The second chart, please? -5 [ Slide.] I 6 As Commissioner Bernthal. mentioned, this charts shows 7 a selected list of incidents and accidents that have-had a 8 major impact on regulatory activities over:the years. .It's.not-9 meant to be exclusive; it's more illustrative of some points I 10 1 want to make, and that is, back in'the early '70s, the 11 incidents seemed to be focused on technology issues and design 12 issues. For example, the first one, 1971, a semiscale test out 13 in. Idaho led to questions about the efficacy.of emergency core s 14 cooling systems, and that led to lengthy ECCS hearings and so 15 forth. Likewise there were some. fuel densification issues and g 16 those sorts of technology issues. l 17 i Later as we moved into the mid '70s'and even the late i l 18 '70s, the incidents seemed to be focused on operational events - 1 19 and accidents like the Browns Ferry fire and, of course, the 20 TMI-2 accident, and that led to a set of regulations.- i The most 21 important of them, I think, were better operator training 22 qualifications, and improved emergency procedures. 4 23 Now we seem to see in.the mid-1980s that the 24 incidents are-focusing on management issues at a few plants i 25-In fact, the last five or so on the list, starting with Davis - l L l ~ ' - '
.i 1 10-A*- 1 Besse and the TVA and Rancho'Seco seem to have management-problems as their root cause. .i 2-3 Of course, we still see technology issues from time' 4 to time, and I would mention the North Anna steam generator 5-tube: rupture, which is not on this list. But'it's not quite of. 6' the same magnitude'that we saw in the early '70s, let's say. 7 t It was the Davis-Besse event in June.1985 that caused 8 us and the Staff and the Commissiontto look introspectively at 9 whether we could do better.in diagnosing the problems atlthese 10 plants. For example, at Davis-Besse,.the Region was quite. 11 awa.re of the poor operating performance and had so designated 12 in their SALP reports. NRR, on the other hand, was' aware'that. 13 they had a poor design of'the auxiliary feedwater system, and 14 AEOD was aware that they were having poor statistics on events 15 a high rate of events. 16 But I think we concluded that.we weren't effectively 17 integrating all of this information and drawing some 2 18 conclusions from it. 19 At the same time -- and that was 1985 -- the TVA s i 20-problems, serious problems, came-to light. There was a Rancho-21. Seco' event in December of '85 and some events at Pilgrim-in. 1 i 22 April of 1986. 23 So all of this came together, and it'was about that 24 time, late 1985 and early '86, when.this introspection that we-25 vent through caused us to focus our senior management meetings j w-~______-__-.-___
11 1 s on assessing plant performance in a lot more detail'than we had 2 done heretofore. It brings together all of the information 3 that we have available to us on the Staff, and by that, I mean 4 regional assessments of plant operations, the SALP history, the 5 SALP reports, our performance indicators, the enforcement q 6 history of each plant, generic issues, and any PRA insights l 7 that we've gotten about each of the plants., 8 This need, I might add, was -- for a comprehensive. i 1 9 assessment was reinforced by the TVA lessons-learned report j 10 that came out in late 1986. 11 We now have had four such meetings under our belts 12 starting in April of 1986, and what one can say about the way 13 we've analyzed it, I think,'is that the regional assessments 14 have tended to be fairly consistent over the years, and that's 15 because they have a history of doing these kinds of SALP 16 appraisals. I 17 The Headquarters input is, I think, improving 18 substantially, because back in our first meeting in April of 19 '86, we had not had experience of pulling all of this 20 information together plant by plant. Now we're doing that, 21 things like performance indicators and status of generic issues 22 for each plant. 23 COMMISSIONER BERNTHAL: Tom, I don't want to distract 1 24 too much from the central point here, but you made the comment 25 that this list was illustrative and not exclusive. ______ - _ a
1 o 12 1 MR. MURLEY:. Yes. COMMISSIONER ' BERNTHAL: - 'I have made~the comment from i 3 time to time, again getting back to_this concept of the_ Safety' 4 Board, that it'appearedcto me that there~have not-been and. i 4 5 would not be~more than a'ccuple of events per year that might- ~ 6 merit the attention of such &~ board, should it ever be 7 constituted. I 8 What can you say further about this. list? Aretthere i 9 more such events that you would throw into this. category, then,. l l 10 than'you've shown here? There are,17 here, I believe, or does 11 this pretty well represent the -- 12 MR. MURLEY: I really haven't-thought about it, ~ 13 because this was meant to illustrate the' impact that it had on i 14 the Staff and on the agency, and not so much -- like,~for. 15 example, the North Anna steam generator tube rupture,-I'didn't 16 put on because we know how to handle steam generator tube 17 ruptures. i 18 COMMISSIONER BERNTHAL: Yes, I agree. - I agree. 19 MR. MURLEY: But that might be.something'that 20 somebody might want to investigate. 21 COMMISSIONER BERNTHAL: More: an industrial accident. ] 22 But in this general category, though,-is it a? fair statement' 23 that you would not expect that list to'more than double if you 24 took a-hard look at it? 25 MRi STELLO: I'll give you a stab at-it. i ' ' ^
i 13 1. COMMISSIONER BERNTHAL: Okay. 2 MR. STELLO: I~wouldn't think it would be as longuas it is right here in terms of issues that'the Board would look 3 4 at. i 5 COMMISSIONER BERNTHAL:.Okay. That's -- 6 MR. STELLO:.For example,. Peach Bottom.is on here. I 7 don't-know what issue that would be to the Board. That's this 8. agency's business in taking the corrective action.- So I would- ) 9 cross that off.. 1 1 10 The Pilgrim shutdown, the management problems, I 11 think that's this agency's business. t I would tend'to cross { 12 that off. 13 I think the idea is that the Board would look'at real 14 incidents and accidents, and those are things that riso to 15 issues such as the Browns Ferry fire. 16 COMMISSIONER BERNTHAL: Everything is this agency's-17 business, of course, but that's not really the criterion. 18 -MR. STELLO: Well, I meant would not be the business i 19 of an Incident or Accident Board investigating management 20 issues. I think that that would so stretch'the. capability of a-21 board, I.can't imagine'that a board:would look into,'you,know, { 22 really management issues. 23 COMMISSIONER BERNTHAL: I don't really want to debate l 24 that issue. I'm just trying to get a bound-on the.-- 25 1 MR. STELLO: Well,.I'm answering you.
1 l 14 l 1 COMMISSIONER BERNTHAL: Yes, I appreciate -- l 2 MR. STELLO: It would be less than what's-on here. 3 COMMISSIONER BERNTHAL: You think it would be less 4 than what's on here. 5 MR. STELLO: Yes. 6 t COMMISSIONER BERNTHAL: It's a fair statement, it 7 certainly wouldn't be more than a few more, at least, in any 8 event than what's on here in this category. i I 9 MR. STELLO: If you take two per year over this span 10 of time,.I thing you would have bounded it, yes. 11 COMMISSIONER BERNTHAL: Okay. Thank you. 12 MR. MURLEY: To continue with the analysis that we do 13 in these meetings, I should point out that the new organization 14 that was put in place in April recognized the need to focus on 15 operating reactors and to evaluate their performance. Our 16 analysis, I think, is going to continue to get better as the 17 new organizational teams just have some time working together. 18 Now, what emerges from these meetings is a general 19 staff consensus on those plants that need NRC attention. 20 Usually we have already been focusing attention on it. In some 21 cases, the EDO may direct there be special diagnostic-22 evaluations be done and these would be done by AEOD for plants 23 that we discuss. 24 There are those plants that we talk about whose 25 performance we conclude is not satisfactory. These, we don't
15 1 hesitate to take action to shut down. I-think you know which 2 ones those are, the TVA plants, Rancho Seco, Pilgrim, and Peach 3 Bottom. Once we are satisfied that they have solved their 4 problems, we then of course will come to the Commission with 5 our recommendations and if the plants are approved for 6 restarting, of course, we will continue to monitor them 7 closely. A plant in that category would be Davis-Besse. 8 There are other plants that we feel are below average i 9 in performance or perhaps their performance is declining as we 10 determine from our meeting, and there we notice that NRR and 11 the Regions take our concerns to the licensees. They 12 frequently have programs already in place to improve and we 13 conclude that we have to keep our eye'on them and monitor their 14 performance closely. 1 15 By far, of course, most reactors are performing 16 satisfactorily in this country. There are several quite 17 excellent plants that one can say are world class performers. 18 We don't dwell on those at any length in our meetings. I will 19 talk about a few of those briefly at the end of my talk today. 20 l In the past, NRR and the Regions have told the 21 licensees of our concerns and of any new concerns that came out 22 of the meetings. We have done that as well. This time, as you 1 l 23 know, the EDO sent a letter to each licensee, where he clearly 24 communicated the concern that the staff had about the 25 performance of each plant.
] 1 16 1 Could I'have the-next slide, please?' 2 [ SLIDE.] 'l 3-MR. MURLEY:. As. plants improve, we decide from time' 4 to time that.no further NRC special. attention'is required.~ .i One i k 5 of those plants.this time was the Palisadesfplant.. InLApril of I 6 this year, it returned to operations'after an.11 month outage. 1 .7 .The problem there had been the poor material' condition of the-8 plant-and what we regarded as an ineffective maintenance 9 program. During the outage, the licensee upgraded the plant, ) 3 implemented a number of new programs',.like' material condition 10 ^ 11 task force, augmented surveillance. program, those sorts of 12 things. 1 13 The staff believes there is a new attitude in the 14 plant regarding maintenance and reliability..The most'recent 15 SALP gave a Category 3-in maintenance and quality programs. We 16 clearly think they can improve. Nonetheless, overall, we think -i 17 their performance has been good since the~ start-up and'that we 18 don't need to give it any special attention other than: normal 19-inspection coverage by the Region. 20 I should add that it is public knowledge that-i 2 11 Consumers < Power is negotiating with the Bechtel Corporation, 22 where Bechtel might purchase part ownership of a plant. We do i 23 .not have any application to that effectLin. front of'us. When 24 we do, of course, we will review it. We don't see any basic 25-fundamental regulatory problems with that. _,.. _.. _ _. - -. - - - - ~ ~ - - - -
I 17 \\ 1 COMMISSIONER BERNTHAL: Tom, did I hear you say the f 2 problem up there was primarily one of management? I guess they 3 all are in one sense or another. 4 MR. MURLEY: It was manifested with what we believe j 5 was neglect over the years, of the material condition of the 6 plant. That is not uncommon. A lot of their focus was on i 7 Midland, as you know, over the years. They seemed to have let 8 Palisades go into a state of neglect and they have now upgraded 9 substantially the condition of the plant and also their 10 maintenance program. 11 Could I move to the next chart, please? 12 (SLIDE.] 13 MR. MURLEY: There are plants that for one reason or 14 another, we conclude that we have to give special attention to, 15 and that is both Headquarters' attention and the regional 16 attention. Dresden 2 & 3 is one such plant. Each one of these 17 has different reasons, different problems. The bottom line is 18 we do focus special attention on them. Dresden, we find that 19 over the past year, the staff has had growing concerns about 20 the material condition of the plant, personnel errors and 21 operator attitudes and a continuing what I would call mediocre 22 to poor SALP history. 23 COMMISSIONER ROBERTS: How could one possibly, having 24 heard that and read the press release of December 14th, how in 25 the world could you fail to put Dresden in-the next category?
18 1 My point is the difficulty of assigning these things very i 2 neatly to little boxes. If you read this press. release, except 3 for the fact they have not shut down, Dresder,would clearly 4 fall into the next category. 'i 5 MR. MURLEY: I'm sorry. 'I didn't read the: press ] i 6 release. I think wa-concluded that Dresden has programs in 7 place to improve, but let me get to that. l 8 COMMISSIONER ROBERTS: Are you going to tell'me that 9 Sequoyah does not have programs in place? That's what the 10 slide says. It says "The following plants do not have programs ~ 11 in place for improvement." i Are you going to tell me after the 12 years that we have struggled with TVA, they don't have a-13 program in place for improvement? 14 MR. STELLO: That's correct. There are still issues 15 with Sequoyah for which we have not yet agreed are adequately ( 16 resolved. When we are at that point,.probablyLin the next 5 17 month or so, we will be scheduling a meeting'and saying, we are 18 now satisfied and recommend to the commission that plant can 4 19 start up. That could conceivably.be in the next couple of 20 months. 21 There is one principal issue remaining yet with 22 Sequoyah that deals with basically the cable issue, and we will 23 be ccvering that in a moment. Until that's resolved, we are 24 not prepared to come to the Commission and tell the commission 25 we are satisfied and recommend to you to let them-start up.
19 1 With respect to Dresden, it's~ entirely different. We 2 are satisfied-now that all of the programs that'are needed1are 3 in place, the issue becomes one of. execution, are they now 4 going to really execute all those programs, the results of the 5 diagnostics were in factikind'of upbeat. Wo.are convinced that 6. they have turned that plant around and that the company-is 7 committed to keeping'it. turned around. I think the reason it got'to the problem is again because of the considerable 8 9 .I construction they'had going on at other plants. This plant had: 10 become neglected. They. fixed it. They have put' considerable 11 emphasis, effort, money and resources in everything we think 12 they need to have. It's there. We are satisfied. i 13 COMMISSIONER ROBERTS: The point'is the difficulty in 14 these categories. Look at the press release, the report l 15 questions whether "significant and-sustaining improvements will 16 occur." 17 MR. STELLO: l That's why wa are going to be watching 18 it. 19 COMMISSIONER ROBERTS: Why are they in the same 20 category as the next group? 21' i MR. STELLO: Because we are satisfied 1that,all'of' i 22 what they need is there and now it becomes a matter of' 23 execution. Are they going to execute successfully all'the ] 24 programs they have put in place and continue to improve'that 3 25 plant. They have committed the resources. I've met with the l.
20 1 licensee. I'm convinced they understand our concern. They 2 understand we are going to be watching them. We are satisfied 3 the plant is safe and can operate. 4 But, we have a reservation. We want to monitor-it 5 very closely to make sure they in fact do it. There's a big. 6 difference between Dresden and Sequoyah. 7 COMMISSIONER BERNTHAL: I think Commissioner Roberts' 8 point is how much of a program does it take to resolve this 9 question of cable pulls. You tell me. I was under the 10 impression that is a fairly well bounded problem. I have to 11 agree with Tom, if you come to me and tell me that~an utility 12 or a plant does not have the programs in place yet to run a 13 good operation, I sure wouldn't think we.would be talking about 14 six or eight weeks. I might say months. I don't think that is 15 what we are talking about down there, but maybe I'm wrong. 16 Is it time for the regional administrators to say 17 something about this or are they potted plants? 18 MR. STELLO: Why don't we let Bert comment.on whether 19 we do or do not believe Dresden has everything in place and it 20 is an issue of monitoring. 21 CHAIRMAN ZECH: Before he does, let me say as.far as 22 I'm concerned, the staff has taken very responsible action. I 23 think it is difficult to place plants in categories. That's a 24 judgment call. Of course, it can be questioned. The fact that 25 there is a' difference between putting a program in place and
l 21- \\ 1 being satisfied that program is well executed is very 2 important. I think the staff has acted very responsibly in-3 this matter. This is their views, not necessarily ours. We 4 can guide them or tell them what we want. As far as I am 5 concerned, it is very valuable. i 6 With that, let's hear from Region III. 7 COMMISSIONER BERNTHAL: I don't want to quibble over 8. that. I'm disturbed that if there is not a program in place 9 yet in this particular case, I would like to hear from the 10 regional administrator down there. 11 CHAIRMAN ZECH: On Sequoyah? 12 COMMISSIONER'BERNTHAL: Yes. 13 COMMISSIONER ROBERTS: The licensee.has yet to fully 14 -- split infinitive -- establish and implement a viable program i 15 for correcting the problems. That's what it says in plain 16 English. 17 CHAIRMAN ZECH: That we are satisfied with. It makes 18 sense to me. 19 COMMISSIONER ROBERTS: It says they haven't 20 established the program. We are not talking about 21 implementation or the efficacy of the execution. It is not 22 established. 23 CHAIRMAN ZECH: I understand it differently. 24 COMMISSIONER ROBERTS: That's what the plain words 25 say.
k. u,n g:q / 3 y 22 lhj, L'~ '1 CHAIRMAN ZECH:- " Established" means'something - they. 2 can'always put'a paper program down, but it has.to be somethinge 3 in my view, not only the programLhas to be established-but we-i 4 must be satisfied it is a sound program.; If we are not' a } 5' completely satisfied yet, it makes sense to me'thatc we should 6 monitor that plant very carefully. 7 a n 7 COMMISSIONER BERNTHAL: I would like~t Ynaar-some Y \\.h 8 comments both on the.Dresden; situation,:because--- l ) 9 CHAIRMAN ZECH:' Go ahead. q 10 COMMISSIONER BERNTHAL:- -- it hats gone on a long time 11 and then also on the sequoyah situation. I'm: disturb d'if o.g 12 there is not a satisfactory program in place yet., h J~ 13 MR. STELLO: ~ \\ Can-we get: the andaler?on Dresden and - a, 14 then get to special projects, to give you a bri'ef thumbnail 1. 15 sketch of the status of the programs where weido not yet have 16 agreement and have approved? 'd 17 CHAIRMAN ZECH: Fine. s a h 18 COMMISSIONER ROGERS:- Mr. Chairman,,I.'m.a little 19 concerned about where we are going here. I think we are going 20 in 16 directions at once. Respectfully cognizant of:my other. 21. Commissioners' interests.in the, details of theseJindividual 22 situations, I wonder if the staff could be given the 23 opportunity to make a rather quick presentation of these= 24 categories, of these plants, why they think they are in there 25' and then give,us<an opportunity to go back after that ande ask.
) l,. [ e g r l 23 1 1 questions-in as much detail p we want about thati 7 structure and: k 2 what it means. d I 1 Ihave\\senseherethatthemeaningofthese-- - y j q' ' t q.,. 's ( cyegories and the hifficulty of putting plants in them will be. i 4 A 4 s cqarifiset if.we can go through this in some overvie'w fashion, 5 6 togetanideaof.whatitisyouaretryingto.dbknc 7 establishingthesecategories,whyyoufeelthekare-usefulfor
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q examplep and,why you put these plants in them, and give us an \\/ un{t{t g.0gobackandaskfordetailsaboutwherethese 9 / opp individuabplantsstand. 10 ,11 It is just a suggestion but I think;it.might help.us to proceed to(so'ae kind of a closure before the end of'the day.. 12 [13 CHAIRMAN ZECH: I think it is a good suggestion' A4 myself. If there isn't any serious objection, wodid agree j 15 that we should finish the briefing and then we will have plenty 16 of timc I'm sure, to address individual plants. 3 ( / 'l 4'
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COMMISSIONER BERNTHAL: 17 t l. \\, I don't know how staff had b 18 7 planned to proceed.- .i 19 MR. MURLEY: I am going to briefly'go through each of 20 the plants arQthen I think a picture will emerge that mighit-g 21 pull this.together. ,l -(CHAIRMANZECH: 22 I think it might'be helpful if we finkh thh briefing. Let?s go. 23 ggz
- s, 24
, t, MR. MURLEY: In our meeting Q.ast Dune, we judged that' ) e 25 Dres 1 should be a plant that+va monitor closely. We havn ot i u t al ? -u %} e ' f k. d'- w;---J,- o r-- a- ~
n 24 1 donoethat., In fact, the EDO directed that a diagnostic 2 evaluation be done by AEOD. That was done in August. They 3 found, as Vic said, that;over the years, there hadn't been p 4 enough corporate attention to the plant. There were resource 5 limitations. They appArartly had been paying most attention to / 6 tht plants'they 6till had under construction over the years. 7 Ati Dresden, it had Involved into a poor maintenance 8 program, poor in stetica tasting program, and operator 9 requalification programs. 10 Based on NRC and in this case also INPO findings, the 11 . licensee has made anveral changes in the past months. They 12 havs formed new vice' president positions for PSRs and BWRs. 13 '? hey have a new.ibyer of corporate management oversight. They 14 have a new plant manager at Dresden, several new supervisors at 2.5 the site. They hava'a maintenance action plan in place and t 16 reveral other important improvement programs in place. 17 It is our judgmont this plant should receive close 18 regional attention which it is doing, and also some team 19 inspections are being planned in December and January for 20 N.eadquartern and the region. 21 The next plant on the list is Fermi-2. They, as the i 22 Commlasion knows, have had recurring problems of personnel 23 errors and equipment failures since the plant was licensed in f4 1985. We attribute many of the problems to the lack of 25 sufficient BWR operating experience on the staff at that time.
) \\ 25 1 1 i of course, this has only become clear in retrospect. 2 The management of the control room operations seems 3 to be weak; that is, in the past it did. 4 1 They have made several changes at Fermi. They've got ] 5 a new Vice President for Operations; they have a new Plant ( J 6 Manager; and they have an Operations Improvement Plan in place. i k 7 The Staff has watched them closely. We authorized restart from 8 an outage October 9th, up to 50 percent power. They operated 9 at that level for some time, and on December 5th, we authorized 10 them to go to 75 percent power, and they are close to that 11 level today. 12 I There are signs of improvement in operations. There 13 are many areas where we believe they still require improvement. I 14 They agree with that. And NRR and the Region are going to 15 continue to monitor their performance closely. 16 Fort St. Vrain is a plant that the. Commission has 17 been briefed on in the past. They restarted this past April 18 from an ll-month shutdown. They've had before that several 19 years of poor to mediocre performance. For example, in May of 20 1986, they had six Category 3 SALP ratings. 21 Here again, we see that the licensee:has made many 22 changes. They have a new Vice President for Nuclear; they have 23 a new Quality Assurance Manager; and they have a Performance 24 Enhancement Program that they have in place and working. We 25 see improved performance pretty much across the board in this l
4 26 1 plant. 2 on october 2nd, however,,there was a' hydraulic. oil 3 fire in the turbine building that caused the plant to be shut-4 down. They had to fix it. They also. corrected the basic 5-problem. The NRC Staff reviewed it. We' agreed with them,-'and 6 we allowed the plant to restart last week. They are now up to 7' 12 percent power today. 8 The Staff here will continue to monitor the 9 operations closely at. Fort St. Vrain. l 10 Turkey Point is somewhat of a perplexing plant.- 1 They 11 have had several years of mediocre performance in operations, 12 in training, security'and' engineering. support. - Their 13 performance indicators are well below~the industry average. 14 For instance, in the past four quarters, they have had 13' 15 safety system failures and four significant events, which is, 16 as I said, well below'the industry. average. 17 They have a poor enforcement history. There are four 18 civil penalties and an order just during the past year -- or 19 this year, 1987. 20 There has been a previous onsite management legacy of 21 minimal compliance that seems to have led to an attitude 22 problem at the site. We see signs of lack of professionalism 23 in the control room and a failure to follow procedures and poor 24 internal communications at the plant. .25 The reason I say it's perplexing is that the e e -_------__--___-.___-__-u-_s._--
'l 27 .1 . corporate management has committed to improve, and they have-1 '2 done this.over the last year or.two. 'In fact,1they have.now a a I 3 new site Vice President,La new Training. Manager. They've j 4 committed somel$700 million in capital. improvements at the 5 plant, including a simulator. They've got a' comprehensive 6 Performance' Enhancement Program that's been in place at the 7 site. 8 Tuesday of this week, Vic Stallo and I and'some 9 others met with the Chairman of the Board, the President and. 10 Executive Vice President of the utility and' indicated'to them, '.1 although we do see signs of improvement, for some reason the 12 intentions of the senior management does not seem to be getting 13 down to the plant level, and that it's going to take close 14 attention for some period of-' time, we'believe, to. change the-15 attitude at the site. 16 I should add that we'have issued an order-on October-17 19th to -- Licensing -- to require continuous on-shift l 18 management coverage, just to. watch ~this control room-1 19 professionalism issue that we talked about. We've also ordered i 20 that there be an outside audit of their operations, and'so that 1 21 should be completed in the spring. When it is, the ADO 22 contemplates that there will be a diagnostic evaluation done on I 23 that plant. 24-Could I have the next slide, please? .25- [ Slide.)
i 1 28 l 1 The plants on this slide are well-known to the j 2 Commission. They've been briefed several times,.particularly 3 the TVA plants, Browns Ferry and Sequoyah. The problems or the 4 shutdowns are fairly well-known. We believe there's been a. 5 management breakdown in their nuclear operations.- In addition, { 1 6 a number of operational and equipment problems at the plant. i 7 At our meeting in November, Jim Keppler, before he l l 8 left, briefed us on the activities of Special Programs, and 9 l they are going to continue their intense oversight of these. 10 plants. One problem in particular that was mentioned was the l 11 Sequoyah units. We believe that we still have to look into and 12 resolve problems with silicone. rubber cables. i There are p11ns l 13 to do that. l We in NRR are working very closely.with the L 14 Special Projects Office, because it may have some generic 15 implications as well. 16 Shall I move on? 17 t CHAIRMAN ZECH: Yes, I think you can. I 18 MR. MURLEY: The next one on the list is Peach 1 19 Bottom. Here again, the Commission was just recently briefed j 20 in past months. In 1985 and '86, we noted declining 21 performance trends in operations, in maintenance, and in-22 security at Peach Bottom. We concluded there was ineffective 23 site management and a poor attitude among the Operations staff. 24 This culminated in a shutdown order last March that 25 was precipitated by operator inattention and lack of:
29 j 1- ' professionalism in the control room. 2 We have had many meetings with. licensee management, 3 and there have been extensive management' changes at the site,- 4 as you know. They have developed a commitment to Excellence 5 Plan last August. We found that there were some deficiencies 6 in that, l and that plan has been withdrawn, and it is being j 7 resubmitted in two parts now. 8 The-first part that they have resubmitted-is a 9 comprehensive corporate organization, reorganization plan. 10 This contemplates that all the nuclear activities of the 11 company will be put under a Senior Vice President for Nuclear, 12 and that there will be Vice President positions created for 13 each site. 14 NRC is reviewing these plans now. The Peach Bottom 15 site organization plans are going to be submitted later. We 16 are continuing our close review of these plans, and in 17 particular, the operator retraining activities that are going 18 on. 19 I should add that we have no projected schedule to 20 come to the Commission for a restart decision. 21 Pilgrim, again we've discussed with the commission-22 before. In 1985 and '86, there was continued poor performance 23 in operations, radiological controls, security, and emergency 24 preparedness. In April of that year, 1986, there were some 25 equipment problems that caused the plant to shut down. NRC at
30 1 that time required the plant to be kept shut down to deal with 2 the broader problems, and as they looked into these broader 3 problems, they. decided themselves that they wanted to make some' 4 substantial improvements overall. 5 They have made extensive management changes. There's 6 a new Senior Vice President for Nuclear in the company, a new-7 Plant Manager. 8 We see significant improvements at Pilgrim in 9 maintenance, surveillance, and licensed operator staffing, as 10 well as fire protection. They have given us yet no firm date 11 on plant readiness for restart. We expect it will be in early 12 1988. 13 A FEMA report to the NRC in August of this year 14 listed six major deficiencies in their offsite emergency plan, 15 and FEMA concluded that it was an inadequate plan. The 16 licensee has been working with the Commonwealth of 17 Massachusetts and with local authorities to upgrade those 18
- plans, 19 The public interest in Pilgrim is very high in the 20 State and in the local communities around Plymouth.
The NRC 21 has committed to have several public meetings at Plymouth to 22 discuss this. We've already had several meetings. 23 Once the utility notifies us that they believe the 24 plant is ready, physically read for restart, we will send down 25 a readiness team to conduct inspections and draw our own
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31 3 l' conclusions.. Here again,;there is no-target'date for a ~ i 2 Commission meeting'on1 restart. l i 3 COMMISSIONER BERNTHAL: What 'is the. principal-issue-t 4' that leads you to say that they're notiready-for res't' art? 5 'Now physical preparedness,.of course, is different 6 from the' emergency planning problem. 7 EMR. MURLEY: Yes. It's the physical preparedness.. 8 There is a list of maintenance items that they.are'still 9 working off. They're installing some new equipment.that's not 10 ready yet'and tested. It's things like.that. 11 Also their Board of Directors has'said that they'want I 12-to be briefed and totally. involved in the final decision to' ) 13 declare to the.NRC that it's ready'for restart.. They have not 14 gone to their Board yet with such'a conclusion. So.it's mainly 15 physical preparations at the plant. 16 COMMISSIONER BERNTHAL:- And is the amargency planning 17 difficulty primarily a difficulty with the licensee ~cne a 18 difficulty with.the State in carrying out its respor.sibility? 19 MR. MURLEY:.It's difficulty with the State. 20 COMMISSIONER BERNTHAL: That was my understanding, 21 too. This is Pilgrim. 22 MR. MURLEY: It was a very severe report that~ FEMA' l -23 issued, probably the worst.I've read of any.of the State Plans 24 that we've seen. 25-Rancho Seco-is the next'on the list.- The, Commission-1 1 n - i, i
L l 32 ~ 1' 'has.just recently been briefed:on that plant. IAs you.know, tl 2 there have been extensive management' changes all throughout the 3 licensee organization,-and_there have been extensive plant- { 4 modifications. 5 We have noted_ considerable progress s'ince.our last. 6 meeting in June. Engineering work has improved. The 7 preventive maintenance program has been developed and isfin 8 place, and they've done some good' test planning for:their power-9 ascension program. 10 Nonetheless, theres a lot of' work that remains to be 11 done by the licensee. They've got a large number of'open 12 items. They have diesel generator problems that they need to 13 work on, and I think they recognize that they have to have a 14 readiness of the operational staff for restart, ) and they have a -] 15 lot of work to do in that regard. 16 The NRC Staff as well has a large amount of. work. We 17 have to put out a safety evaluation report that will be quite 18 ccuprehensive that covers our review of all of the plant 19 modifications and program modifications that have been done 20 over the last couple years. In addition, we vill send in an 21 readiness inspection team when we judge:that it's appropriate. 22 The target schedule for readiness for restart'is late 23 January or early February. We.will come'to the Commission, of i 24 course, with our recommendations at that time, and if there is-25 a decision to restart, there vill be extensive NRC inspection o j ___________._______.________D
33 1 ' coverage during that time. 2 I should add that INPO plans aLteam' inspection.of' 3 their own in mid-January at Rancho Seco. 4 COMMISSIONER BERNTHAL:Are we going to go through. 5' all of these other points, or are we going-to.be able to' talk 6 about problem plants now first? 7 MR. MURLEY: Do you want to pause here? 8 COMMISSIONER'BERNTHAL: I would prefer,to focus.the' 9 discussion now specifically on the difficulties here'before we 10 go on to the good actors and that sort of thing. 11 CHAIRMAN ZECH: Well, I think that's fine. That's. 12 fine.. I think we can do-that. We do have a bit.more to go 13 through that I think is valuable, some of the new~ operating 14 plants and some of the plants that-have shown a good 15 performance record. I would think that's valuable. l 16 COMMISSIONER BERNTHAL:- I agree. I agree. 1 17 CHAIRMAN ZECH: But we can stop now and briefly go 1 18 through -- 19 MR. STELLO: We can take.about five minutes. l 20 CHAIRMAN ZECH: Let's stop now and go through the 21 problem plant areas that we've discussed, and perhaps we can: 22 ask you to be -- respond as briefly as you can, as directly as 23 you can. But let's stop now and go through the problem plants, 24 and then we'll move along. 25 MR. STELLO: We have two questions pending. If I ____--__-_-_L
1 o 34 1 can, I'll try to get answers to those. I will ask Mr. Davis to i 2 speak to the Dresden issue from his perspective. I will ask 3 Mr. Jordan, who is responsible for the diagnostic 1 evaluation to a i 4 comment next, and then I'll ask Jean Axelrad to deal with the 1 5 issues on Sequoyah and' programs that we haven't agreed to, so 6 that you can see the clear difference between these plants, if 7 I can. 8 CHAIRMAN ZECH: Let's do that, and then we'll. move i 9 ahead. i 10 COMMISSIONER ROGERS: Mr. Chairman,.could I just ask l 11 a clarifying question here? 12 CHAIRMAN ZECH: Yes, go ahead. 13 COMMISSIONER ROGERS: If you just took all of these { 14 statements about these plants away and just looked at'these two 15 groups, am I correct in categorizing them in a totally 16 different way in that the first group is'a group of' plants that i 17 are authorized to run, and the second group of plants are a 18 group of plants that are not authorized to run; is that 19 correct? i i 20 MR. STELLO:- Yes. 21 COMMISSIONER ROGERS: Well, why do we need these-l 22 explanatory notes about them, then, that get everybody all 23 upset and confused? 24 I mean, if that's really the case, then that's all we 25 have to know, is that this group from Dresden to Turkey Point
35- .{ 1 are authorized to run. You're' going'to be looking.at them and; j
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2 so on and so forth, all of your comments. The other group of 3 plants are not' authorized to run, and that you have certain l 4 things you're going to look at before-you authorize them. I 15 Then we don't have to argue about some of these other 6 questions.about what's in place and isn't in place, and is. ) 7' something established or not established when it has not been I i 8 demonstrated or it has been' demonstrated.. 9 I mean, it'seems to me that we may be getting into lo subsidiary issues here, when we really have two clear 1 11 categories, those authorized to run, those not1 authorized to 12 run, and those that are authorized to run that you feel were ~ 13 very much improved. As you pointed out, Palisades. 14 CHAIRMAN ZECH: I think that.we don't want to spend a ] 15 lot of time on -- and the categorization is correct. I think, 16 Mr. Rogers, we certainly are aware that-we -- there's a large-17 difference between those that are shut down and those that are 18 authorized to run. 19 I think we did have a specific question on Dresden. i 20 Perhaps we can answer that very quickly, very briefly, and then i i 21 move along. Let's do that, but please be brief. I 22 MR. DAVIS: All right. With respect to Dresden, in 23 mid to late 1986, as a result of a number of. team inspections. l i 24-by NRC and also INPO findings, it was. determined that there 25 were many problems down there. The company' began to develop a l
i 36 1 number of-improvement programs which are beginning to be 2 effective, in our opinion. 3 In addition to the improvement programs, they've made 4 major management changes, as Dr. Murley indicated. They put-in. l 5 Vice Presidents over PWRs -- a Vice President.over PWRs and a 6 Vice President over BWRs. They brought in a new Plant Manager. j 7. They've made a significant number of other management changes 8 at the plant. They have put in an INPO Coordinator to 9 coordinate the improvements that INPO identified-needed'to be i 10 made. They've put in a Superintendent of Improvement Programs I 11 as a result of the diagnostic evaluation team. i 12 It's my opinion that the improvement programs are 13 beginning to work. The plant is beginning to improve. I see 14 it in the direction of becoming at this point a good, solid l 15 performer. The company thinks it will become an excellent l 16 performer, and I'm certainly hopeful of that, but it's going to 17 have to be demonstrated. la. But I see management changes, programs that are 19 beginning to work, hardware that is getting better, personnel 20 error reductions. And based on all that, we feel that they're 21 in'the right direction, but they're just getting off the 22 ground, and because of that, it needs NRC continued attention, 23 which we will give it. 24 CHAIRMAN ZECH: Fine. 25 MR. STELLO: I was going to give a synopsis of the i ___.__m-
4.. .'37L 1l press releases,'the diagnostics evaluation,'very quickly. 2 CHAIRMAN ZECH: Identify yourself for the Court-3 Reporter,EEd. l 4 MR. JORDAN: Ed Jordan, AEOD. Director. 5 The diagnostic that was done was as Commissioner -i 6 Roberts indicated, subject to'a press media release. It' 7 summarized the findings of'that particular diagnostic, which 8 ' identified certain problems the utility had. The utility has 9 committed as' discussed.to a' substantial improvement program.- 10 Based on that commitment and.cn1 the actions'they have taken 11 already, that was the basis for us finding they fit in this 12 middle category. 13 MR. STELLO: Now I would give the answers to 14 Sequoyah, if we can. 15 MS. AXELRAD: Jane Axelrad, Office of Special. 16 Projects. 17 On the Sequoyah plant, TVA has put in' place many 18 programs in the last few years and on most of the programs, NRC 19 and TVA are in agreement that the programs are acceptable. The 20 staff's acceptance of the program would be documented in'an 21; extensive safety evaluation report that we expect;will be 22 issued in January. However, there are a few program issues l 23, that have not yet been completely resolved'in terms of 24 agreement on-how to handle the issue. 25-On a couple-of the programs we are waiting.-for 1 .Il
38 1 -submittals from TVA that we need before we'can finally accept ~a. 2 . program-and issue a safety evaluation. On two'of'the issues,. l 3 .there are still open issues on how we are going to resolveJit. 4 One is the cable issue and we have been receiving'submittals sur L 5 recently as a week or two ago and'we are still expecting.a 6 final submittal,from TVA documenting all of their work and 7 drawing their. final conclusions.. 8 We will be reviewing.that. We are working on 9 developing a staff position on what'our response will be on-the_ 10 cable issue. i' 1' 11 The other issue that.we are not in complete agreement 12 on is the follow-up on the IDI; inspection. 'On.that one,-we are 13 close to a resolution. 'There have been follow-up. inspections i i 14 at the site on the IDI.- There are additional submittals coming 15 in from TVA and a further follow-up inspection'is going to be 16 scheduled for late January. 17 1 TVA is in the process of conducting'its valve 18 alignments and expects to begin non-nuclear heat up in early 19 January.and will request. start-up in mid-February. 20 CHAIRMAN.ZECH:- Thank you very much. 21 COMMISSIONER ROGERS: Just one' question, Mr. i -22 Chairman. On the question of whether a silicon cable problem 23 is a generic issue or not, could you say something about that?- 24 That is something I've been concerned about and I haven't heard 25 very much about it lately.. What can you tell us on that?: 1
39 1 1 MR. MURLEY: Unfortunately, I don't;have=the answer' 2 today. We have met with the Special Project; staff,.NRR staff 3 has. We have a contractor who is looking into this very 4 question. .They are scheduled to talk to'us with their 5' conclusions in the next couple of weeks. 6 COMMISSIONER ROBERTS: Who is the contractor?l 7 q MR. MURLEY: The contractor is FranklinL Research Lab - l! 8 l up in Philadelphia. They have been in this area for quite some 9 time. They are quite capable. 10 I can't give you an answer today.- What I can say is 11 we are looking into it. 12 COMMISSIONER ROGERS: Have you got a list of 1 13 everybody else who has used this cable and where it is? Do you' 14 know where this stuff is installed around the country? 15 MR. MURLEY: We.are developing that list. We: don't 16 have it yet, l 17 i COMMISSIONER ROGERS: I would urge you to get that 18 together pront.o. 19 MR. MIRAGLIA: Frank Miraglia, NRR. I 20 It may be helpful to the Commissioners to recognize-21 that the TVA did inform the staff under Part 21 of the silicon 1 22 rubber issue, that resulted in information notices. All the 23 industry has been provided with an information notice relative 24 to the concerns the staff had. In addition, we have identified 25 the-three manufacturers of concern.and are developing:the
C 40 1 specific list. As-a.Part 21 notification, therafis: follow-up 2 from the industry and also to the utility. i 3 COMMISSIONER BERNTHAL: You know these. cables have 4 been used f.n other plants? ( 5 \\ MR. MIRAGLIA: There is indications, yes, based on 6 i manufacturer, whether that same specific lot or type of rubber 7 by manufacturer, that these manufacturers have provided cable 8 to other facilities. What systems they are used in and how l 9 much is something we are trying to develop. 10 ~ i COMMISSIONER BERNTHAL: Who would you say has a I 11 program more in place to deal with this problem, TVA or the 12 other plants where the cable has been used? j 13 MR. MIRAGLIA: I'm not familiar with what TVA has i i 14 done, Commissioner Bernthal, so I cannot answer that kind of 15 question. l 3 16 i COMMISSIONER BERNTHAL: i It seems to me the answer is 17 obvious. They know they have a problem. The others don't know 18 it yet. 19 MR. MURLEY: Wait a minute. We haven't-concluded 20 there is a problem with these cables. The staff has not. 21: COMMISSIONER BERNTHAL: What are the programs not in 22 place that we have a problem with? 23 MR. STELLO: You are trying to get us to give you 24 responses to questions we really haven't had a chance to get 25 to, but let me try to give a rough cut. You recognize that
41 1 this problem evolved out of.an issue where TVA did not use good i I 2 procedures and care in pulling the cables. 3 COMMISSIONER BERNTHAL: .I understand that. I 4 MR. STELLO: The cables could be damaged. 5 COMMISSIONER BERNTHAL: Is that the-programmatic 6 problem we are talking about? 7 MR. STELLO: That is the origin of this~ problem. 8 These particular cables were then found to be particularly 9 sensitive if you were not careful in pulling them, where_they 10 could be damaged and have the ability to carry the prescribed 11 voltage across the insulation. 12 COMMISSIONER BERNTHAL: I understand the origin of 13 the problem and I think I understand the nature of the problem. 14 I'm talking about the indication that they don't have a program i 15 in place to deal with these difficulties. It is clear they are 16 ahead of anybody else who has these cables right now, i 17 MR. STELLO: They have a particular aspect of the i 18 problem that is unique to the facility, and that is cable pull. 19 We don't know that other plants have had cable pull problems 20 yet. If they have these cables, we have a concern, because 21 they are more sensitive. Are they going to be a problem in 22 another facility, to what extent, we don't know. 23 We do know they have been a problem in the Sequoyah i 24 facility and perhaps the reason for it is in fact due to the i 25 cable pull procedures that were followed.
j ~42' 1 COMMISSIONER BERNTHAL: My point is the one that i 2 Commissioner Rogers has mentioned. It didn't escape my view 3-either that every plant that requires substantial improvement, i -l 4 I'm suspecting is by. definition a plant that is shut down.. I 5 do not see a great deal of difference quite frankly but for the il 6 fact they have had an incident'and are shut down between 7 certain plants in the first category that we are monitoring 4 8 closely and certain plants in.the second category. 9 i I hope that we are not simply as a matter of policy, { 10 if there is an attempt to create these categories, saying-that 11 well, by definition, any plant we have shut down is a real 12 problem and any plant that isn't shut down, we can't put in the 13 same problem category. I just don't think that hits.the. mark 14 quite frankly. I suspect some of the plants that are currently 15 shut down may have by this time fewer systematic problems, i 16 systemic problems I should say, than some.of the plants we are 17 monitoring closely. 18 That's the difficulty I have with these. .Is it an 19 accident that it turned out this.way or was that a decision 20 that was consciously made that well, the ones that are shut 21. down are the ones that require substantial improvement by 22 definition? 23 MR. STELLO: Let me get a little different angle on 24 it. 25 COMMISSIONER BERUTHAL: Was it an accident or did'you
_q .i + 43: j I 1 decide to do it that way? 2 MR. STELLO: It was' intentional, that if we had to 3 shut a plant down -- 4 COMMISSIONER BERNTHAL: Then I agree-with ) 5 Commissioner Rogers. We ought to' call them;that.. 6 ,ER. STEL10: You can't, except for the first category 7 of plants _we are monitoring.- I think you need'a'little more 8 substance as to how'you' define'that'a little better. \\ 9 With respect to the plants shut down, theLissuails a 10 very simple issue. We are not prepared to come'to the 4 11 Commission and tell you,we think it is okay to start:it up ., a. c., ~ ,. - ~. ~ ~. ~ ~.. ~ ~ - - - ~ ~. - ~ - 12 because there are problems that are outstanding. We'are not-j 13 satisfied. Until they are, until that time, we believesthey 14 are going to be in that kind of.a' category,.whatever~you call 15 it. Maybe an easier definition:is plants for:which we areinot 16 prepared to come to the Commission and tell you'it-is okay. 17 COMMISSIONER CARR: Not only that, they aren't even i 18 prepared to come to the staff and say'they are ready to start. I 19 MR. STELLO: By definition. 20 COMMISSIONER BERNTHAL: There is a special 21 circumstance for a plant that has had a serious. problem and has. 22 been shut down. For example, we will hear from Jack'and I want-23 to hear from Jack on-Rancho Seco, I was under the impression 24 they had made substantial and significant improvements. I am 25. under the impression we have:had. substantial, I' hope i
4 44 1 substantial and significant improvements at Sequoyah, and I 2 thought and I hope at Pilgrim as well. 3 All^I am saying is I entirely agree with the point-4 that if there is a conscious decision here, as long as we are 5 going to be creating these bins, let's just call it what it'is. 6 The ones that are shut down are the ones that are % 4 permitted 7 to operate. The ones that aren't are something else. 8 HR. STELLO: The ones that are shut down I think are 9 easy. You can call them just that, plants that are shut down 10 and will require. substantial change before we come to the 11 Commission or before they come to us. 12 The second category is the plants we want to monitor 13 carefully. They are very judgmental. I am not suggesting 14 there is any easy way to come at it. I think yousneed a little 15 more definition. I think those are basically plants that they 15 have now taken the action, the action that'we wanted is there, 17 and we are going to be monitoring them fairly carefully. 18 We may have a plant that we put in monitoring very l 19 carefully that just never needed to be shut down. 20 COMMISSIONER CARR: The second category are the 21 plants we are trying to keep from falling-into the shut down 22 category. 23 MR. STELLO: That's a very good way to put it. 24 That's exactly our intent. We are unhappy over the performance 25 and we want it changed.
- b 45
'l '{ 1 CHAIRMAN'ZECH:' I.think it is very important for the 2 Commission to be aware of the~ plants you are concerned'about.- l .i 3 They'are operating. That is very important in my-judgment-- 4 The ones that are shut-down are pretty safe. If we have some-l l 5 that are operating that.you have concerns about,'that'you are-6 monitoring closely, it,is responsible action on your part to 7 inform us, and I think it is responsible action on~our part,.to 8 know which plants those are. That is what we are trying-to do 9 and I think that is very important. 10 COMMISSIONER BERNTHAL: I agree.- My only point, and 11 I'd like to talk about substance.and get off this kick,'but my 12 only point is that I think there are plants in this " monitor 13 closely" category that have bigger problemsLthan some of them-i 14 we have listed in the shut down list. That's all I'm'saying. 15 That's the only point I want to make. 16 MR. STELLO: That's.very possible.- When a planttis 17 just about ready and we are ready to come down to the 18 Commission, some of those, and I think TVA, Rancho Seco will 19 be examples of whether you have really done a very, very good .l 20 job turning things around, and when they get to that point , you \\ 21 are right, but until they get to that' point. 22 CHAIRMAN ZECH: Let's move along. I 23 COMMISSIONER BERNTHAL: Let's talk about substance. 24 CHAIRMAN ZECH: Let's go to the next slide. 25 [ SLIDE.] l
46 4 1 MR. MURLEY: The next. chart,.the operating experience' 2. of new plants. .3 COMMISSIONER BERNTHAL:. I'm sorry. I'want:to hear 4 about Rancho Seco. I can do that now or-later.- Where are we? 5 CHAIRMAN ~ZECH: You canido.it now;.b'riefly. I 6 MR. J. MARTIN: I would.say'since our last meeting, l l 7 Rancho Seco has resolved,a number of the things'I'was: concerned-l 8 with at the time. For example, the~ preventive maintenance-i 9 program. i I think it is now well-defined and in place. -A 10 testing program has been defined that I think meets our - 1 11 expectations. A number.of the items they were late,on have i 12 been resolved. 13 on the other hand, the remaining --LI.would.say that 1 14 the physical condition of the plant-is probably better today 15 l than it probably was when it was: delivered to them. In 16 addition, they have made some major modifications to.give it'a { 17 lot more safety margin and technical depth. 18 The main issue at the moment is that with the i'i 19 tremendous effort that went into improving the plant and 20 getting the design modifications made, it is time now to focus 21 on operations. i They are having the same' kind of difficulty 22 that you would see in a new plant making that transition from-23 construction to operations. They think the plantLwill 24 physically be ready for restart towards the end of January. 25 Whether the people will be ready to restart it or not-is a
47' 1 .different question and they'have yet to. draw that' conclusion .A, 2 themselves. =I thinkLthat isithe major focus.of attention at ] 3- 'the moment. 4 CHAIRMAN ZECH: Thank_you very much. 5 COMMISSIONER'BERNTHAL:- Are you : able: to proj ect any ' 6 kind of time table at this point? 7 MR. J.-MARTIN: I'think the end of January, just' 8 because it is a lot of people that need to get into'an-9 ) operating mentality. That's hard to do in a short time period. I 1 10 My guess is it is not going to be.the end of January; probably? 11 February sometime. l ) 12 COMMISSIONER BERNTHAL: You;think th's management 13 stability now has finally arrived? 14 MR. J. MARTIN: Yes. 15 COMMISSIONER CARR: Let me say'one thing _and ILdon't 16 want Commissioner Bernthal's remark to go without some comment. 17 If I thought in that four plant list, that they had bigger 18 problems than the plants shut down and'it affected public 19 health and safety, I would vote to shut them down, Fred. 20 CHAIRMAN ZECH: So would I. 21 COMMISSIONER BERNTHAL: They-don't have bigger. 22 problems than when we first shut them down_but today, I'm not - 23 so sure. My point is I think we are looking, for example, at 24-Rancho Seco here, where we are-being told that within six: weeks. 25: we expect a start-up. We have just heard that apparently in'as ---_-----_----u-_--w--
48 1 ' good a condition at least as of the' day they bought the plant, 2 in terms of physical condition. One would hope that if they 3 have done their homework, that should be a very well running 4 plant. By definition, there is a good chance, a reasonable 5 chance, and I won't pick Rancho Seco necessarily, that.one or 6 two of these plants within three months will immediately be 3 7 ahead of some of these monitored closely plants.- 8 COMMISSIONER CARR: That's fine but it is on them to i 9 come and say they are ready to run their plant'and they haven't 10 done that yet. These other four plants say they are ready to 11 run. 12 COMMISSIONER BERNTHAL: That's true but it doesn't 13 necessarily say anything about the magnitude of the problem, i in f 14 my judgment. 1 15 CHAIRMAN ZECH: We could argue that point, and I'm 16 not so sure it would be of great value. But it's very 17 important, as far as I'm concerned, though, to make sure that 18 we're satisfied that the plants that are operating are 19 operating safely and are safe to operate. And that's why it's 20 important, I think, for us to be informed of the plants that 21 you are monitoring closely and you're concerned about. 22 We're trying to prevent accidents, as well as 23 exercise our safety obligations. We don't want any accidents. 24 And it's.important, in my judgment, to be informed of the 0.5 plants that have concerns. And I agree, if those concerns on
49 1 those monitored-closely plants become-large.'enough, that we 1 2 'l would shut them down, and I.think_that's very important.' I 1 3 think it's very important to discuss that. I 4 But I would like to-move along:if;we-could.- 5 i MR. MURLEY: Yes. Wa discussed-the. performance:of 6 the newly licensed plants, ten-recently licensed plants.- [This 7-was not because we suspected that there were. problems or that a 8 we particularly were looking for problems, but'rather more as a- .\\ 9 sheer diagnostic evaluation. 10 i The Staff issued -- AEOD issued NUREG-1275 some six-11 months ago, and there they discussed the. performance of new 12 plants and provided some lessons for improvement. i The~ range of 2 13 performance of these ten plants on the list is similar to those 14 that were studied in NUREG-1275. 15 We have seen cases, for example, where the lessons 16 learned by a utility on.the first; unit's startup have clearly j 17 improved the performance of follow-on units.- l Two'that~come to 18 mind are Byron-2 and Palo Verde-2, ~ and that tell us then that 19 there can be performance improvements, and there can be lessons, 20 learned. 21' INPO has just recently held' ai workshop on December ~ 22 loth on lessons learned from new plant performance,.and their 23 lessons parallel ours quite closelys. It is a: good report that 24 they've put out, and several utilities have been involved.
- We 25 think that there is a good potential-for this effort by INPO-
'l i l
y 50 for. transferring.information.fromone'u[til)1tgto,another,soi ]- ' 11 2' that'they can' improve' plant performance"that way. 4 3 There was onexplant in our' discus,sionsLI should' ' f, w j; 4 mention, and-that.is Perry. We discussed'thisiak,ccme length. .ru, 5 We don't believe it's a1 problem: plant, but yet the) statistics 3 ~ ' 3; 6 are showing us that it hasn't quite settled down'yet from its'9 7 new plant startup performance. So we' agreed thatLRegion III-8 and NRR will keep an eye on Perry, again not because we believ-e ti 4 ) 9 it's a problem, but we want 'to ' understand why,it hasn't seht$pd' 4 10 down yet. a,'.. o h 11 The next chart, please. p 12 [ Slid'.] s .O!']Y' 13 t ;v I mentioned earlier at the'beginning of"Act' discussion " 14 that there are a number of very well run plants. u, We don't 15 spend a great deal of time in our meetings analyzing plants at 16 this end of the spectrum. Nonetheless, we do focus.;on good 17 practices, attributes of good plants, and some-initiatives'that 18 such plants have taken. I hava. listed here. examples that we 19 believe are in this category: Kewaunee, Oconee-1-2-3, Perry 20 Island-1 and 2, St. Lucie-1 and 2, Susquehanna-1 and 2. 21 A couple of examples of good practices, good 3 J s 22 performance, that come to mind are, at Susquehanna, y/ n' nbhelievq es t 23 that they have an' exemplary. management development program. 24 The~ list'is not meant to be exclusive. 'For exampis, 25 Virginia Power, although we didn't put plants'on thisclist, -[b O -_- 0
i' '( n s s s 51 O 1 ithey did a comprehensive analysis. and an extfaplary job in ) 1 m .2 disseminating to the public their findir4gs on the Eurrey i I 1 tI feedwtf:erpiperuptureandontheNorthAnnatheruptureevent-3 4, of last July. s a l 9 5 So there were, as I said, a few examples that-we L 3 6 looked at of good practices, andspeoftheseplantsare 1 7* listed here. 'e 8 So that concludes my m1mmary, then. l 1 ~l ) 9 CHAIRMF# ZECH: All right. 'O \\\\ ~ 10 U. MR. TV"ELLO: We're ready to go withIthe NMSS program. 11 CHAIRMAN UICH: Let's go through NMSS,.and then we'll t ii 12 have some time for questions. i,\\ j 13 MR. THOMPSON: Thank you, Mr. Chairman., l k I 14 As the Commission directed in the-Staff requirements 15 memo that we lotD. not onlyiat reactors but also the materials 16-licensees in looking at performance, we do have some less l 17 information available to us. We don't have the SALP program. 18 We don't have the statistical analysis of activities. We don't 19 have Resident Inspectors for the 8000 licensees that we have. 1 20 But we do have the same fundamental principle that we do in the-k 21 reactor end,arpd that is where we identify performance -- that 22 is, the Regions and NMSS -- where we don't have assurance that, 23 a licensee is; going to safely operate and adequ, ate' ly prcrdct
- t..,
, t y (24 'g& public health and safety, we'take actions to suspend'the \\ 25-operation, suspend their license and, if necessary, revoke it, e i ( y
j, F l, .); .s, g[l' ) J + b 52 si 1 and likewisuiif there are some individual -- ir?ividuals'on a c c. 2 license, we ad id;timove those individuals for awhile. 9 ?.. i; What we tried to do at the meeting in November was ykindoffocusontwomajoractivities,someprogrammatic c4 i 5 l activities that we'were taking to address some problems we had t 6l-w th class of licensees, as well as identify a couple or three 7 performance' indications where we had to taka action in the past f 8 to suspend their operations and to make sure the Regions 9 communicated their success in taking those actions, and so that i 10 we were aware of those. 11 So if I could have the first slide, which kind of j 12 focuses on more of the programmatic activities that we had 33 discussed. 14 (Slide.) 15 The first one we dealt with was the industrial and 16 medical nuclear safety initiatives. There, you know, the 17 Commission had given us approval to initiate the lessons i j 18 learned and the actions recommended by the Materials safety ~ l 19 Regulatory Review Study Group, and we identified the program { 20 that we had laid out for actions to implement that program in 21 the EDO's Noismber 15th memo to the Commission. I did' identify 22 at that time some of the initiatives that were being 23 potentially delsy9d due to the lack of resources due to the 24 high-level waste program being -- having to reprogram FTEs back 25 into that program at that time, and identify what some of the
I 53 1 impacts would be both on what at that time we'll call the l 2 performance indicators, the radiological safety program, and 3 the team inspection activities. I I I 4 I would note that since that meeting, the Commission I 5 has directed that additional resources be placed back into this l l 6 activity and that, in fact, most of those programmatic 7 activities will be -- effort will be started back up to 8 implement those as best we can. We are obviously on a schedule i 9 delay, but most of the activities now will be reemphasized to I 10 get those programs back on track. 11 We also then focused on what we would call prevention of degraded performance by materials licensees. I 12 At one time, 13 this was kind of referred to as the performance indicators, i but 14 as a result of a number of meetings that we've had with the SES 15 managers, there was a concern that we not identify these with 1 16 the same terminology that we used on the reactors, and we 1 17 haven't really settled on the right name, but for lack of a 18 better name right now, these will be symptoms of degraded 19 performance or something along those lines. 20 And we identified the success of the program that we 21 had in Region III, which had implemented a program from June to 22 September looking at about 15 major s,'rmptoms on about 100 23 inspections that they did in the Region. In fact, they 24 identified 13 out of the 98 particular licensees that were 25 inspected that had identified these symptoms that needed
l 54-1 additional attention by;the' Region, by the' licensee management, in order to correct.their performance early on in order.to have 2 3 some assurance that we didn't haveLa major problem. 4 Just as a kind lof a summary of those 13, it ended up 5' to being seven industrial type licensees, five medical-6' licensees, and one radiographer. In each of these casesJwhere 7 the inspectionLactivities have' identified potential problems, 4 8 Region III took initiatives to have meetings.or discussions 9 with the licensees to make sure that the management were well 10 aware of our concerns. In certain cases, they. increased:the -) i 11-frequency of inspection of these licensees.and got commitments 12 from the licensees to take actions to improve their 13 performance. 14 The two key things that were identified by these 15 inspection activities was lack of senior management involvement ! l 16 i of the licensee and overloading the Reactor Safety Officer with: 17 too many duties, too many activities, that he was not able to i 18 effectively carry out his inspection activities. 19 Region III and we both think that was a~very 20 successful activity.. We recommended that to the extent the. 21 other Regions were'able to: implement the pilot program, that it-i 22 move-forward on that, and it's cue where I think it really 23 shows some promise for increasing the performance of the 24 licensees in this area. 25' Likewise, we looked at the class of radiographer. 4 i
55 1 1 You know, that's one where we have, oh, maybe 700' licensees 2 between NRC in agreement states, but it involves some 25,000 3 individuals in carrying out_those activities throughout the l l l 4 United States. It's a problem often that individuals =are. 5 licensed both in' agreement states and NRC, and we have' 6 experience over the past fiveoor six years of-about 15- ^! 7 overexposure per year. 8 We discussed the success that we.were havingfin the 9 third-party certification approach with the American Society 10 for Non-Destructive Testing. They've agreed to assist in:the. 11 1 potential. development of a third-part certification program 12 along the lines that we had discussed with the Commission and' 13 also identified the fact that the State of-Texas now has' 14 implemented a third party certification, and they'are J 15 developing an examination with NRC support that would provide j 16 possibly the mechanism for the American Society t'o adopt the 17 Texas approach. 18 The last major area that we addressed was the low-19 level waste disposal at reactor sites and the status of where 20 the states and' compacts were-in meeting their. January 1st' 21' commitments to have in place a site. selection and-be members of 22 compacts, identified the problems that New England was having, 23 particularly with the New England states joining compacts or I 24 even the individual states being able to select sites.- i 25s i The key area that we' discussed:was the potential in i
56 1 the State of Maine to want to use the Maine Yankee reactor site 2 eventua]ly as the low-level waste disposal site, and we 3 discussed the mechanisms and the problems that we would have to 4 use to address that. But the underlying key factor was that 5 any site would have to meet our current regulations. That's 6 the Part 61 regulations. And we elected to explore 7 opportunities to really put that issue on the table, and if 8 Maine Yankee wished to come in with a topical report addressing 9 how that site met the Part 61 requirements, that we may conduct 10 a review to assist to see whether that is a reasonable approach 11 for the State of Maine to take in addressing this low-level 12 waste disposal facility. 13 The three licensees that we addressed at the meeting 14 are on the next slide. 15 [ Slide.] 16 The first one, I think really demonstrates some of 17 the problems that we've had with the material radiographer in 18 the United States, and it's U.S. Testing. 19 U.S. Testing, the problem was first revealed by an 20 overexposure incident, and I guess in Arizona with some again 21 allegations about the quality of the personnel training and 22 qualifications, but it was one in which Region V immediately, 23 once becoming aware of the problem, took actions because their 1 24 headquarters are in California. They met out there with the 25 licensee. And then we, using Region V as the lead, had a
57 ~1 nationwide coordinated inspection activity, which was conducted 2 in all Regions and in eight of the agreement' states, to try_to 3 really understand the comprehensiveness of the problem that we 4 face with U.S. Testing in the. training-and qualification areas. 5 Again, this is one where we started this activity-in 6 early February. By the end of March, we had.done the 7 nationwide survey and inspection of all the' activities and 8 really had identified a number of the actions that we felt'were 9 going to be necessary-to have this operation at U.S. Testing to 10 continue.- Their activities were suspended until they were able 11 to racertify to the various Regional administrators and to Jack' 12 Martin that they had initiated at the sites and at those 13 licensed activities, they had in place the trained and i 14 certified people necessary to conduct the operations. In~ fact, 15 part of the inspection activity revealed that:they had been 16 conducting thousands of radiographing activities with 17 uncertified individuals throughout the United States. 18 Here again, we have I believe identified and put in j 19 place the corrective actions and have-allowed the facility to !j 20 restart and issued a confirmatory action letter to allow that 21 to continue. As you know, we are'having independent audits. 22 They were completed in November of 1987 and the independent 23 audit findings are under review by NRC. 24 I would note in this particular case, there is a i 25-continuing OI investigation, which I think you aresfamiliar
1 with, separately. 2 Likewise, Finlay Testing is a more focused particular ~ 3 licensee. It is primarily in the state of Hawaii, although 4 they do have some activities elsewhere. That was a case where. 5 there was some shipping of radiography sources on: passenger 6 airlines,' lack of radiation surveys, lack of utilization of.the: 7 source logs, use of unqualified individuals.- InLthis case, the-8- license was suspended in September, September 21st,- There has 9 been a request for a hearing. We have held a meeting.with the 10 licensee and again, this.is'one in which there are ongoing 11 investigations right now, but it is again an example'of where. 12 we took the action to suspend operation of' licensees where we-13 did not have reasonable assurance they were complying with the t 14 rules and regulations established for protection of public 15 health and safety. 16 Finally, the third licensee that we discussed was 17 Precision Materials Corporation up in-New Jersey. That is an 18 irradiator which had been experiencing I guess financial 19 difficulties. We also had information they were net keeping 20 NRC currently informed of some problems they were.having with 21.. the irradiation pool and leakage. 22 The Region did have some early indications that not 23 only they didn't have plans of preparation ~for the control and 24 disposal of radioactive material, but there were key 25; individuals at that facility whose position.was being
59 1 terminated, individuals were resigning because of the lack of 2 an effective, viable corporation, and'the Region promptly took 3 action in early September to have them suspend operations, to 4 place the cobalt 60 radiation source in a shipping cask and 5 dispose of it. That was completed by the end of September. 6 Again, it pointed out the activities that we are monitoring of: 7 the licensees to see if someone who had a potential problem 8 that could have created a bankruptcy aspect in which we would 9 have had no funds, we didn't'have assurance that the sources 10 could be adequately protected. 11 We took the action in order to make sure the public 1 12 was adequately protected. Those are primarily the activities 13 ( we discussed although there were some other activities that 14 coulu have been discussed. 15 CHAIRMAN ZECH: Thank you very much. I have to take 16 a phone call. I will ask Commissioner Roberts to take the 17 gavel. 18 I think it would be useful perhaps before we go on 19 with any questions to hear very briefly from the other Regional 20 Administrators that are here that haven't had a chance to say. 21; anything, to see if they have anything to add. You don't have 22 to give us a two hour speech. If there is anything you would 23 like to say that you think may be useful, it would be useful to 24 hear from you now. Those who have had a chance to speak as 25-well as Ms. Axelrad, perhaps if you want to add anything, I
60 1 think.it would be:important to do so. 2 Just-briefly,'is'there anything you'would'like to go on with or you would like us to hear while you are here today? j 3 ] 4 I think it would be-useful for us to'give'you that oppor'tunity.. 'l' 5 ~Mr. Martin? l 6 MR. R. MARTIN: Very quickly, the comment I would 7. want to make is this effort to sit down with the other 8 i Administrators, the other-program office-directors and 9 comprehensively look on.a comparative basis at all the-plants-10 in the country has been a very helpful, very productive,-very. 11 useful exercise, I believe,'-for us. 12 I am speaking personally. I.think it is a good 13 (- exercise to go through, despite whatever shortcomings any of us 14 or you may feel about the final outcome, the. effort to try to 15 do this and look at these plants in such a comprehensive 16 fashion is extremely valuable, and I would not want to see the 17 opportunity to do that, us precluded from being able to do 18 that. 19 COMMISSIONER BERNTHAL: I don't disagree with one 20 word of what you have said. That 1:s not the! question. I 21 wanted to-maketthat very clear. I.have31ong* advocated that.we 22 have just this type of meeting with all of you coming in and 23 telling us what you know about any plants you want to say. 24 something good or bad about. That is not the issue I am having 254 some difficulty with here.
61 1 It is as Tom puts it, the boxes. I entirely agree 2 with you on the point you made. 3 MR. RUSSELL: In addition to discussing problem 4 facilities, I think an important part of our discussion is also i 5 the discussion of noteworthy initiatives and plants which are 6 performing well. I would suggest that area is as important 7 from the standpoint of discussion at a meeting like this as is i B problem facilities. Those plants which are doing well, where 9 there is some attribute of their operation which we want to 10 provide visibility for, such that others have the benefit of 11 that, I would suggest that is rather significant. 12 I would point out in the Susquehanna case, they have 13 had a five year plan for some time. They have a very exemplary 14 program with respect to implementing goals and objectives that 15 are not unlike what the Commission is trying to do itself now 16 with its own strategic plan and five year plan. They have a 17 very aggressive management development program which involves 18 use of rotational assignments, both within nuclear and within 19 the non-nuclear activities and are quite effective. 20 I believe that kind of discussion is as important and 21 probably worthy of discussion at a Commission meeting.' 22 MR. GRACE: I sympathize with the comments about 23 categorization of plants. However, I think we haven't had that 24 problem particularly in Region II with our plants. True; there ] 25 is-a complete spectrum of plants. It is difficult to put them l )
i $2 1 in boxes. I worry about'all of them. I think they.are-all at 2 least potentially problem plants.- I worry about-the five or 3 six plants that INPO has classified as Category 1.. They are_on 4 my watch list for fear of complacency setting in. 5 In' Region II, the plants that'have stood out I think' 6 are clearly separate from the-rest. The TVA plants, NFS Irwin 7 'has been a problem. I think'they are out of the woods.. Turkey 8 Point may be coming out of.theLwoods. The big' change in all 9 these problem areas has been a change in' top management. At 10 NFS Irwin,.they brought. in a new site manager. He has' turned 11 things around' remarkably well. They are soon going to come off 12 our watch list as far as a fuel facility is. concerned. 13 TVA, hopefully. At Turkey Point, I have met 14 periodically with the Chairman of the Board-and the new 15 President. They now realize their problems, while they focused-16 a lot of time and a lot of attention and_a lot-of money into 17 hardware improvements at Turkey Point, they have come to i 18 realize that the problem has been strong leadership, lack of 19 strong leadership at.the site in particular, and to a certain 20 extent at corporate headquarters. They have turned that.around 21 or they are beginning totturn it around'in that'they.havex 22 installed a new site VP who seems to be an improvement. Of - 23 course, that is tentative. We will be watching it. 'The proof 24 4 of the pudding is in performance, the bottom line. They.are 25c also bringing in a-new corporate VP'from the'outside. This.is __...___._)
U 63 i l 1 significant because this'is the first key person:they. brought 1 2 in from the outside. 3 The solution of all the other problem plants around 4 the ccuntry has been to bring in some new blood. TVA is 5 included. NFS Irwin is included. Peach Bottom,-Davis-Besse 6 and so forth. 7 I do agree that we have struggled with the' problem of -{ t i 8 putting the plants in boxes but in Region II, it has been a 9 pretty clear separation. 10 CHAIRMAN ZECH: Thank you very much. Are there'any. I 11 other comments from others? 12 MR. J. MARTIN:- I think one of the things we talked 13 about at the meeting that I thought was very useful and it 14 troubles me a great deal is the quality of technical and 15 engineering work being done at utilities. I went through a 16 number of examples. It is a topic that interests me a great 17 deal. It is not a strong component of our inspection-program. 18 Looking into it in my region, it is pretty j 19 discouraging. We did discuss that to some degree and are 20 starting to get our thoughts together on whether we should 21 probesinto that more-deeply >on argeneral basis. I think thatL 22 is something you will probably be hearing more about in the 23 near future. 24 MR. MURLEY: I might add, Mr. Chairman, that is a 25' goodipoint. I was not comprehensive in everything. We covered,
64 1 other things in our meeting. Jack reminded me that is a good 2 example where we are going to revise our inspection program, { 3 working with the regicas. We will be putting more emphasis on i i 4 engineering. 5 CHAIRMAN ZECH: Very good. 6 COMMISSIONER BERNTHAL: Let me ask a question on that 7 point. I understand, is it Regions I and II, are not using 8 engineering support as a SALP category. 9 MR. MURLEY: Yes. We have a manual chapter pror .zd 10 that will make that an uniform category. ) 11 COMMISSIONER BERNTHAL: It should be; yes. 12 CHAIRMAN ZECH: Mr. Davis? 13 MR. DAVIS: I guess I just have one short comment. I 14 feel reasonably good about the fact that I believe, at least in 15 Region III, there is a general upgrade in the overall 16 performance of the plants. I think that has come about as a 17 result of the additional attention that the plants are getting 18 from everybody. 19 There were times when I would sit and wonder, are we 20 putting the right emphasis, are we putting too much emphasis on 21 a particular plant. I found it helpful to be able to request 22 for example, a team inspection, of new eyes to go to a plant 23 and take a look at it, to see whether or not the Region was 1 24 doing the right thing. Since the reorganization and 25 everything, I feel better about that.
65 1 I guess there is one other comment I would make and 2 that is -- I said this at the management meeting. I feel that 3 the Palisades plant, which was removed from the list, I feel 4 that was an NRC success. We found that there were a number of 5 equipment problems up there. We worked with the licensee which 6 caused a shutdown for 11 months. We worked very closely with 7 them while it was down and there were major improvements made. 8 I think they are on an upgrade now towards a good 9 solid performer and they tell me they are going to become 10 excellent. 11 We did that without them having to have an event like 12 Davis-Besse had. I think we are going in the right direction. 13 CHAIRMAN ZECH: Thank you very much. Ms. Axelrad, 14 would you like to add anything? 15 MS. AXELRAD: Nothing to add, Mr. Chairman. 16 CHAIRMAN ZECH: Thank you very much. Mr. Stello, do 17 you want to conclude with anything before we ask some 18 questions? 19 MR. STELLO: We are ready to answer any questions. 20 CHAIRMAN ZECH: All right. Questions from my fellow 21-Commissioners? Commissioner Roberts? 22 COMMISSIONER ROBERTS: No questions. 23 CHAIRMAN ZECH: Commissioner Bernthal? 24 COMMISSIONER BERNTHAL: I've asked a number of 25 questions already. Why don't we let.the others have a shot
1 here and I may have a couple afterwards. 2 CHAIRMAN ZECH: Commissioner Carr? 3 COMMISSIONER CARR: I would only like to say one word 4 about the boxes. I've looked at six of those nine sites that 5 you have in boxes, and from my personal observation, they are 6 in the right box. We don't have to be perfect in this 7 evolution, if we have somebody in the wrong box, we would be 8 perfectly happy to have the utilities prove it to us and we 9 will move them into any box they can work their way into. 10 Having said that, I'll quit. 11 CHAIRMAN ZECH: That's the idea. Good performance 12 across the board to improve public health and safety. 13 Commissioner Rogers? 14 COMMISSIONER ROGERS: Well, just that I think these 15 categories that you've established here are useful. I think 16 the problems really came from the little explanatory paragraphs 17 and the titles on top of them. If you took those off and 18 started the discussion, I think we probably would have moved 19 along a little more quickly, because I think they are useful 20 categories, and I think that this one, the plants that you have 21 to monitor closely, really you have to do that. I think we 22 should know who they are, and I think it's very proper for you 23 to identify them. 24 Just a comment. I've been to three out of those four 25-plants, and my own observation is very much -- excuse me -- I'm
1 67 1 looking at the wrong list. I'm looking at the list of those l c 2 that are doing very well, wherever that is, the plants that 3 received comparatively less attention. 4 I've been at, I guess, four out of the five on that 5 list, and one observation that I made is that there's more than 6 one way to run a plant very well. There's more than one way to 7 do it, and that if anything, I came away with the feeling that 8 those plants that really tailored the solutions that they 9 developed in their style and techniques to their own 10 situations, where they brought their people together in a way 11 that was most effective and appropriate for them and with an 12 excellent result, is something that we have to pay attention 13 to, because it's so easy to think that we could establish one i 14 good way, and there is no one good way. i 15 Several of these plants are doing very well. I quite 16 agree with your own assessment of them, just in the little time 17 that I spent there. It was very obvious that they were doing 18 things quite differently from each other. And if you try to 19 impose some of the programs at one at another one, they just 20 wouldn't work for five years until they learned how to do that. 21 So just a4 cautionary note that these good plants that 22 you've cited here are good because they really have solved 23 their own problems in their own way and have achieved a result 24 which is satisfactory to us, and it tells us that there's more 25 than one way to do it, and it's results that count, and if we i
68-1 really focus on;the.results,Lwe wont'be'in a big' disagreement 2-as to style. 3 CHAIRMAN ZECH: Let me just say, I certainly agree 4 with that. There's no perhaps one specific way to manage'a-5 plant, and I think it certainly should be left to.the utilities 6 to establish the management through their own strengths,'and 7 that is important. 8 On the other hand, it does seem to:me.that it might 9 be useful to look at.these plants that have~ performed very well 10 for a considerable period of time and to'see if there aren't 11 any common threads through it. 12 For example, one of the common threads might'be -- 13 and I've visited a number of them, too -- one of the common 14 threads certainly might be strong management involvement in all 15 phases of the operation. That seems to me to be a common 16 thread of the plants I've visited, and frankly some of'the 17 plants that are not performing as well as others, perhaps-the 18 management involvement hasn't been as strong. 19 Now certainly the styles can be'different, but if the 20 management involvement is strong, and if that iss a. good -- if. 211 that comes out in these better performing'plantsi itimight"be-22 useful. 23 There might be other things. How about the 24 maintenance program? In my view, maintenance can be improved 25. in this industry. I also found that some of the,better
69-l' performing plants seemed to have a reasonably good maintenance 2 program. 3 .Another thing that's impressed.me with some-of the 4 plants you have on this list and others I've visited, too, is a 5 very strong outage program and planning program for outages, 6 that they plan ahead of time for' outages. 7 If we could conclude that some of those lessons or 8 . practices are' common, I think that would'be useful. I 9 certainly agree with Commissioner Rogers,-though;~the style of 10 putting them across and even the execution should certainly be-11 left to the utilities and not be'prescriptively described by-12. this regulatory agency. 13 But if we could' find some general ~ good principles of 14 operation from these better performing plants, that, I think, 15 might be useful in a broad sort of way and then allow the 16 utilities to execute them in any way they see fit. 17 Commissioner Bernthal, you had other comments? 18 COMMISSIONER BERNTHAL: I just'have one or two minor 19 points I wanted to inquire about yet. 20 Correct me if I'm wrong. I visited -- I.want to: talk 21-about a good plant heret -- I visited'oconee tw' or'threefyears. o 22 ago, I guess. I did not recall th#1 they were uniformly so 23 great at that time, at least, in their SALp ratings. 24 Has that situation since changed? 25? MR. GRACE: Yes. In the last SALP that we-conducted-
70-1 a month or two ago, we gave them six Category 1s. 2 COMMISSIONER BERNTHAL: Okay. 3 MR. GRACE: And that's a big credit to the Plant 4 Manager. I 5 COMMISSIONER BERNTHAL: Very good. Yes, that's good. j 6 MR. GRACE: It's also a credit to Duke Power's system 7 for developing managers and rotating managers. Mike Tuckman is 8 going to be there another year, year and a half, and he'll have 9 five years in. He's going to move on; he's been told. And 10 also their Maintenance Manager, who, when we gave them a 11 Category 1, and he said, "Yes, but we've got a long way to go." 12 He's the man that's going to move over and take over Catawba 13 shortly. 14 So it's a credit to their management system, their 15 rotation and development of key people. 16 COMMISSIONER BERNTHAL: I agree. In fact, one of the 4 17 most difficult things is to go from pretty good to very good, 18 and I think Duke, as we all know, for a long time has been 19 pretty good, maybe a little better than pretty good. But 20 certainly Oconee has always been more than adequate, but it's 21 very pleasing;to hear that they've'found the approach, the 1 i 22 formula, the secret to, apparently, excellence in operations. ) 23 MR. GRACE: i And it's been a challenge with three B&W i 24 plants. 25 COMMISSIONER BERNTHAL: It certainly has, i ...a
71 1 I wanted to ask Hugh' Thompson a question'about the 2 materials licenses -- licensees, rather. The sense that I get. i is that we are picking up a lot more things in Region III than. 3 4 we are in the other Regions. 5 Is that because of the fact.that you -- well, there 6 may be several things. One, there may be many more licensees 7 in that Region. Secondly, you do have some special pilot 8 efforts going on there, as I understand it, trying to.evaluato 9 a kind of performance, if you will, a performance indicator,.if 10 you will, for materials licensees. 11 Is it because you're do'ing things more. fastidiously 12 there, because you have more licensees, or what's going on? Is 13 there something we ought to'be transferring to the other 14 Regions? 15 MR. THOMPSON: Well, let me say first.that-Region III 16 and Region I are our two biggest regions, and'I think you.will 17 find most of the problems that are being identified, other than 18 Region V seems to have their fair share recently-per number of t 19 licensees, but it is an area that I think we've got.a very 20 effective, aggressive program in Region III with the 21' performance indicator program. In fact, that was one of the. 22 recommendations that came out of this meeting, was to take the a 23 performance indicator approach that had been the pilot program 24 in Region III and identify and apply that into Region I to the i -254 extent ~that we have some resources available, and I think' I. i '}
72 l' obviously the commission's actions recently to provide more 2 resources to this activity is one that will be of assistance to 3 all of the Regions in being able to conduct the type of 4 inspections that have-been done there. 5 Region III -- I mean Region II, for example, though, 6 has done some very first rate inspection activities at some of 7 our broad scope licensees. 8 My general view is that there are enough licensees 9 out there that the harder the inspection activities that you 10 do, the more effort that you're doing and to do a thorough 11 inspection, right now we're going to identify a large number of 12 problems. I mean, it's just the fact that we have been so 13 resource-limited in some of the inspection activities. You 14 know, we do hospitals like once every three years. 15 But we're able when we go out -- and one of our 16 licensees, typically we're able to do a more complete 17 inspection of the activities than in the reactors which, you 18 know, we have a major inspection program and modules to do. 19 But let me-see, Bert, you might want to give any 20 thoughts on the program as you see it. 21, MR. DAVIS: Well, I appreciated the comment'that the 22 Region III program is aggressive, and I guess I would say that 23 it was. But my view is, if I were to rate us on a scale of one 24 to ten with ten being outstanding, we're probably around a six 25+ as far as getting to the point where I think we should-be and
73 1 -need to be in the materials' program. 2 I think there's just a:large number of problems'out 3 there. I think we have missed a lot of them in some of'our-4 past inspections. I think the performance indicator -- 5' symptoms of degraded performance program -- that's hard-to say 6 7 MR. THOMPSON: We'll be working on that name. 8 MR.. DAVIS: Is very good,.and I think it's helped us 9 a lot, and we're really using that now in Region III. But 10 we've got a long way to.go, and there_are a lot of problems. 11 MR. THOMPSON: I guess'I would add, my sense'is'that 4 l 12 every Region seems to be identifying their' fair share.- Maybe j 13 we haven't kept the commissi'on quite as informed. I I know that 14 Region IV has just got a handful of them, particularly in these 15 radiographer and, you know -- they maybe just-don't get quite 16 the level of attention at the Commission that you might like, 17 and if that's the case, we'll need to keep you= informed of 18 that. 19 Again, it's one of the areas that is effectively 20 decentralized, so much of the licensing activity,cas well'as. 21; the< inspection activities, are in the Regions,.and'it is a 22 program, though, I think, that maybe some of the. Regions, you. 23 don't get quite the level of attention on it'. 24 COMMISSIONER BERNTHAL: Okay. I'just have one last 25s comment. It will be no' secret obviously by now,.that I have _ = - __-.
74 1 never favored this trying to toss things into formal 2 categories. I have always favored coming in and letting the 3 chips fall where they may, and your coming in and discussing i 4 the plants, because I think then the context is provided. The 5' Commission hears the good, the bad, the indifferent, and the k 6 shadings of opinion on each plant, and that's the way it should 7 be. 8 Frankly I think, since obviously I'm not likely to 9 prevail on that point, there has been an artificial 10 distinction, though, in addition now that has been introduced 11 here that I would just suggest we dispense with, and that's if 12 we're going'to continue to see all shutdown plants and all the 13 others in two sharply separate categories, I see no basis for 14 that, and I would just suggest that we toss them all in one bin 15 and hear about them all the next time. We all know which ones 16 are shut down, and there's no point in trying to describe them 17 somehow in a special way, other than that they're shut down. 18 I would be confident that two or a couple of those' 19 plants on the shutdown list, shall we say six-to nine months from now, are going to be ahead of some others on the previous i 20 i 21 list of plants that are still operating that we're' monitoring 22 closely. And that, I think, is the key criterion: Who is 23 going to find their way out of the woods more quickly?- 24 I frankly would no longer make the distinction 25-between the4 shutdowns and"the others. It's just a suggestion.
7 51 i 1 COMMISSIONER CARR:. I wish I had you as a professor. 2 COMMISSIONER BERNTHAL: I won't comment. 3 (Laughter.] 4 MR. STELLO: Mr. Chairman, I think'we are finished. 5 I think it has been a very important meeting. I would hope 6 that the one issue that comes out of this is the continued 7 support of the Commission for.us to have these meetings, to 8 have these discussions, because I think they are extremely important to the very mission of this Commission, which is 9 10 safety, the ability for meLto be able to bring the senior 11 managers together, to.have the kind of interac't' ions. The 12 meetings are very good, very important and'I think they.are' 13 serving a very vital purpose. I would just urge that the-14 Commission continue to support us going forward with such 15 discussions. 16 CHAIRMAN ZECH: Thank you very much.- Any'other 17 comments from my fellow Commissioners? 18 COMMISSIONER ROGERS: Just one with respect to these 19 materials licensees. There seems to me there is an enormous 20 body of ignorance out there in how to deal safely with the 21 materials they are using every day and using in their 22 businesses and so forth, and I know that trying to take on an 23 educational program would probably be too much for us, but it 24 seems to me that something has to be done to constantly refresh 251 a realization of thetkinds:of responsibilities that these
76 1 licensees have, must exercise and the careful attention.they-2 have to apply to what they are doing. 3 We see that even in some of the more distinguished 4 universities of this country, they seem to forget how to handle 5 the materials which are their basic bread and-butter'in some C areas. I would urge you to think a little bit about'any way. 7 that you can use.your leverage to encourage' refreshment of 8 knowledge with respect to handling these materials on the part. k 9 of these licensees, either through some kinds of professional i 10 societies, trade groups, whatever, where they are using 11 principally their own resources and we are using our leverage-12 to help encourage that to take place, so we.are not trying to 13 pay.for it all, that we are somehow poking at it, probing at 14 it, and encouraging a regular program of information 15 transmittal to the smaller. licensees who all I suspect belong 16 to some kind of a trade or professional association, if you 17 talk about the radiographer or whatever, or the well logging i 18 people or whoever. 19 Some of the absurd things we hear about from time to 20 time with regard to carelessness, I suspect largely comes about 21 through real ignorance of what they are dealing with, astlarge 22 a degree as it is, threugh willful neglect, although I am sure. 23 there is some of that. 24 Just to try to use our influence, our' leverage to-2 5.- keep that kind of a program going, it isn't enough just to do I l
77 l' it once, because the people change-and the-little booklets that e 2 are around and they-have disappeared and.they used to have 3 H something but nobody can find it or what have you, when.the new 4 man or person shows up on the job, but just to try.to keep up-5 an educational approach on these matters, using our own 6-resources to a minimal degree and someone else's resources;to a 7 maximum degree. i 8 MR. THOMPSON: We will certainly do that. i 9 CHAIRMAN ZECH:. If there are no'further comments,~1st f 10 me just thank the staff and the regional administrators for ) 11 being here. I think this'was a very valuable session. I 12 certainly believe one-of our primary responsibilities is1to be-13 knowledgeable of the concerns of the staff and the resources 14 you are putting to bear on the various plants. I think it is 15 extremely important. The categories and so forth, we all know 16 are judgmental. Focusing on priorities and' improved 17 performance, allowing us to be aware of your concerns and your 18 priorities is very valuable and responsible' action on our part. 19 I do think, too, that bringing in the materials 20 licensing part of it at this session allows us to focus on that-21-very important responsibility we have. I recognize Mr. Davis i 22 pilot program and he has very candidly told us it could be' j 23 improved, too. I think that is a valuable action. i I would 24 encourage other regional administrators to be. knowledgeable of 25-it. t
l 'l 178 ) l' I'do think'whereas we spend'most of'our: focus'on 2 reactor plants that more people in our country are hurt, 3 occasionally killed by the materials licensing. program.- i ,] I 4 think the commission has by its actions demonstrated to the 5 staff that we want to focus more on that program. d m 6 Your being here today, Mr. Thompson, is'am'important' t /1 7' 3.. recognition of our interest in that responsibility that we 8 have. I do feel _there is room for improvement--in that' area [ N y 9 across the board, just like there is room for improvement in!! 10 \\ our reactor plants. 11 Let me just conclude by again thanking the staff for' 12 a very responsible action. Your meetings,.where you get. 13 together and hear from each other, I think that is' valuable 14 also. It has to be because you can hear from your own peers 15 and learn from their experiences, too. 16 I think Dr. Murley and Mr. 5tallo as senior managers 17 here at Headquarters, have done an absolutely superb job in 18 gathering together this kind of information and focusing on it i 19 yourselves and presenting it to the Commission. -) L 20 With that, let me thank you.for a:very, very. valuable-21; presentation and-certainly;I for'one:would;hopesthat your. 22 program would continue with whatever modifications you feel or. 23 we feel is necessary but the primary purpose _of all this is'to 1 24 see what we can do, perhaps to prevent accidents'and thereby 25" contribute to the public health and safety. ___x-- - - - - - - ' " ~ ' -I
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.-}i -L', j ] c-te .. v- 'l <,. '( a t ./ 79' -1 , Taang you very much for a' valuable pre's {'tcation. L e W 2 stand. adjourned.! N,.. 4 3 [Whereupon,.at 11:28 a.m.,'the meeting was a 4 adjourned.) 1 } 5 a ./ 4 6 6 ,7 i g s \\ s, a l ' 't I ~ /. .g 10j t a'l !\\ 4 e 11' 12
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4 1, e4 2' REPORTER'S CERTIFICATE 3 'l 4 This is to certify that the attached events of a 5 meeting of the U..S. Nuclear Regulatory Commission entitled:- 6 7 TITIR OF MEETING: Periodic Briefing on Status of Operation 8 PLACE OF MEETING: Reactors and Fuel Faciliti'es-Washington, D.C. 9 DATE OF-MEETING: Thursday, December 17, 1987 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken f 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the-16 foregoing events. i 17 ./ 18 /. [7 -- LYzMn7 /*fY"6 19 ( (/ ' [s i 20 21 1 22 Ann Riley & Associates, Ltd. 23 24 25 .1
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