ML20246M819
| ML20246M819 | |
| Person / Time | |
|---|---|
| Issue date: | 08/30/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1752, NUDOCS 8909070256 | |
| Download: ML20246M819 (285) | |
Text
_ _ - - _ _ _ _ - _ _ _ _
A cR.ST=/782 JLGL N A O
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE 011 REACTOR SAFEGUARDS l In the Matter of: )
)
SUBCOMMITTEE ON REGIONAL )
PROGRAMS, REGION 1 OFFICE )
O m
".'m - Retain x Anr(SOf&c vi .- ...
f0fIh8Lijeeibte00mlTEBB Pages: 313 through 557 Place: King of Prussia, Pennsylvania Date: August 30, 1989
___.,____________________________________________________~..
HERITAGE REPORTING CORPORATION O onkwRepeters 1220 L Street, N.W., Suite 600 Washington, D.C. 20005 sc,o 070z.e. s: oe -o (202) 628-4888 FfiR M Ri .
T-17% F[it
1 PUBLIC NOTICE 3Y THE-
!t
- [--}
'- . 2 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 August 30, 1989 5
~6 7 The contents of this stenographic transcript of 8 the proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Reactor Safeguards 10 (ACRS), as. reported herein, is an uncorrected record of the 11- discussions recorded at the meeting. held-on the above date.
12 No member of the ACRS staff and no participant at 13 this meeting accepts any resi, isibility f,r errors or-14 inaccuracies of statement or data contained in'this 15 transcript.
16 17 18 19 20.
21 22 23 24 ,
25 Heritage Reporting Corporation (202) 628-4888
, -- -_ _ = - _ . . _ _ _ __ - _ _ - . _ - - _ _ _ _ _ - - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ -
313 V UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS In the Matter of: )
)
SUBCOMMITTEE ON REGIONAL ')
PROGRAMS, REGION 1 OFFICE )
Wednesday, August 30, 1989 Conference Room 475 Allendale Road King-of Prussia, Pennsylvania The meeting convened, pursuant to notice, at 8:30 a.m.
BEFORE: DR.'FORREST J. REMICK Chairman, ACRS Associate Vice-P;tesident for Research Professor of Nuclear Engineering The Pennsylvania State University
. O_ .
University Park, Pennsylvania ACRS MEMBERS PRESENT:
DR. WILLIAM KERR Subcommittee Chairman Professor of Nuclear Engineering and Director of the Office of Energy Research University of Michigan Ann Arbor, Michigan MR. JAMES CARROLL Retired Manager, Nuclear Operations Support Pacific Gas & Electric Company San Francisco, California MR. CHARLES J. WYLIE Retired Chief Engineer Electrical Division Duke Power Company Charlotte, North Carolina
(~ Heritage Reporting Corporation 5
(202) 628-4888
~
h; 314 I: I( '
_ ACRS MEMBERS PRESENT:- -(Continued) l: MR. DAVID A. MARD:
l :,. Research Manager:on Special' Assignment E.I..-Du.Pont de Nemours E' Company Savannah River Laboratory. '
-Aiken, South Carolina l DR. IVAN CATTON' l-, Professor of Engineering l- Department of Mechanical, Aerospace & Nuclear' Engineering .
School of Engineering and Applied' Science University of California Los Angeles, California ACRS COGNIZANT STAFF MEMBER:
PAUL BOEHNERT
~O
. Heritage Reporting Corporation (202) 628-4888
1 315
(-
3-1 EB2QE&R1HGH I
2 DR. REMICK: Good morning, gentlemen, the meeting 4 I
3 will now come to order. l l
4 This is the second day of the meeting of the <
5 Advisory Committee on Reactor Safeguards, Subcommittee-on 6 Regional Programs.
7 I am Forrest Remick,-Subcommittee Chairman. And 8 the transcript-from yesterday's meeting indicates the 9 members of the subcommittee that are present.
10 One announcement: we.will need to plan to adjourn 11 today at 3:30. There will be an airport limo at the 12 entrance that + came in at 3:45 to pick up those who need 13 to go to the airport.
() 14 And the first topic on the agenda for today which 15 is actually a matter that was on the agenda for yesterday 16 and that is diacussion of the systematic assessment of 17 licensee performance, SALP.
18 (Slides being shown.)
19 MR. KANE: My name is Bill Kane, I'm Director of 20 the Division of Reactor Projects. And what I would like to 21 do first is to give you an overview just to set the stage 22 for some of the questions that I know that we've got on the 23 agenda that you're interested in.
24 But I would like to just briefly run through the 25 SALP process just to remind everybody how it works and then
' Heritage Reporting Corporation (202) 628-4888
316
- !jD L
1 we can get to the questions.
^2 First or all, the manual chapter that addresses 3 SALP is 0516 and it is, in fact, a periodic report card, if 4 you will, of utility performance for each plant.
5 The scope is based on the inspection and licensing 6 activities and those are collectively integrated into the 7 SALP process. It is, in fact, all of the inspection reports 8 for the plant and all of the licensing activities that are 9 assessed periodically and then an overall assessment made at-10 the end of the period.
11 Now, the period is typically one to one and afhalf 12- years and we adjust that cycle depending upon the status of 13 the plant. In a case of a plant like Seabrook, for 14 instance, we have extended the period out to 23 months, 15 basically to collect the observations from the startup 16 period. So it's adjusted to maximize the observations --
17 the important observations so that we can develop the 18 necessary overall conclusions for plants that are on the so-19 called " watch list," they will be assessed typically at one 20 year intervals.
21 The objective of the agency is to average -- have 22 an average of about 15 months for all of the plants. And we 23 track that and make sure that we're reasonably close to that 1
24 time period.
I l 25 The objectives are three. You've heard them i
() Heritage Reporting Corporation (202) 628-4888 l
l l
u_________ - )
'f 1 l' before but I think it's worth going over them again. To 2 improve the NRC regulatory program by making sound decisions 3- on NRC resource. allocation penalty. We discussed that 4 yesterday to some extent.
'S Basically, how we adjust resource allocations with 6 SALP are largely three areas that I would say. First of 7 all, we talked about the plan clearly adjustment to the 8 inspection program. That means that we get in' requests from 9 the residents based on their observations of activities.
10 And then we take those requests into account using in part 11 the SALP process and the SALP grades in determining --
12 because we have a limited resources, we can't honor all of 13 the requests. We have to have some way of discriminating
() 14 amongst those requests to determine where we should apply 15 the resources.
16 So as Gene explained yesterday, those SALP grades 17 are a very important part of making that determination.
18 Another aspect of how we use it is in terms of 19 scheduling team inspections. Not so much that these team 20 inspections won't be done, but it in part is used to 21 determine the order in which they're done. In other words, 22 we certainly would want to conduct those inspections at 23 facilities that were weak in that particular area first and 24 then kind of move on down the list. But eventually you 25 would cover all the plants. So it's used in terms of Heritage Reporting Corporation O (202) 628-4888
l l , . ,
318 1 ordering that approach. }
i 2 And then finally, in terms of reactive 3 inspections, when there is an event or a problem at a 4 facility we tend to use what we know about the performance 5 of the utility. Again, in SALP space, if you will, in terms 6 of determining whether we need to go to an expanded approach 7 sending a team or whether the licensee, in fact, is capable 8 of, in our view, of following up the issue on its own. It 9 demonstrated a good ability to go in and establish root 10 cause and develop a good set of corrective action.
11 So to some extent it will influence even the 12 approach that we take in reaction to events.
13 Improve licensee performance. What we do through 14 SALP is to try to indicate areas where we think improvement 15 could be made, and those areas are outlined in the report 16 and discussed with the licenses.
17 Diagnosed performance trends which is an important 18 part of the process is to try to understand where the 19 licensee may be going. And that's maybe the most important 20 part of SALP because we try to understand whether there's an 21 improving trend or a declining trend and it's really a 22 perceptible change. And improving trend, clearly, on the 23 part of the Board where we sae that in the next period they 24 continue on their current track they will be in the next 25 cctegory; that then is used in the inspection scheduling Heritage Reporting Corporation f~)'
s- (202) 628-4888
\1 319
(~)
'w/ 1 process to determine resources again, 2 Certainly, to improving is a lower priority for us 3 in terms of assigning resources than a category _2. So it is 4 used discreetly in the scheduling program. J 5 On the other hand, a 1 declining is certainly 6 something that we focus on as well as the 2 declining.
7 Those are indicative of a slip that we need to pay attention 8 to through the inspection program and so the resources are 9 again compensated for by that trend.
10- The summary of the process, just quickly, the 11 inputs to the SALP report come from all of the divisions 12 here, the senior resident and also to Nuclear Reactor 13 Regulation. The report typically prepared by the senior
() 14 resident inspector. The initial review by the section chief 15 and branch chief, many of whom you have met here.
16 The report then is reviewed by a SALP Board, which 17 I will get into the constitution of that Board later on.
18 The Board report then is carefully reviewed, not just 19 issued, but reviewed by the regional administrator and then 20 issued.
l 21 DR. KERR: Excuse me.
p 22 MR. KANE: Yes, sir.
l
?3 DR. KERR: Did you say that the first draft and 24 report is prepared by the senior residents?
25 MR. KANE: Yes, sir.
Heritage Reporting Corporation O (202) 628-4888 l
l L______-_-_----
320
. i
'# 1 DR. KERR: Thank you.
2 MR. RUSSELL: Bill, there are actually sections of 3 the report that are prepared by other site --
4 MR. KANE: Oh, yes, I should have.
5 MR. RUSSELL: You need to clarify that; it's not 6 totally a senior resident product.
7 MR. KANE: The integration of the entire report is 8 done by the senior resident. But if you go through the 9 functional areas, there are three functional areas prepared 10 by the division of radiological safety and safeguards: the 11 emergency planning section; the security section; and the 12 radiological control section.
13 The division of reactor safety prepares the t'h
() 14 engineering and technical support section. NRR prepares the 15 safety assessment and quality verification section; and 16 senior resident prepares the operations and the maintenance 17 and surveillance, those two sections.
18 But the entire report which includes the 19 background, the operating history, the assessment of trips 20 and unplanned shutdowns, the assessment of LERs, and all of 21 the supporting data pulled together by the senior resident, 22 and the entire package is pulled together and coordinated at 23 that level. So there are many inputs to it, but the overall 24 coordination is with the senior resident.
1 i 25 MR. CARROLL: Now, the process you're dercribing, l
l Heritage Reporting Corporation
(">}
% (202) 628-4888 i
(
'321
,m k' I that's the way it's done in all the regions?
2 MR. KANE: No. . It is done in a variety of ways, 3 and I'm not sure that I could explain.them all. We took the 4 -- in many cases, the other regions have the safety.
5 assessment and quality verification section is pulled 6 together by the' region. In this instance,'we have made an 7 agreement with NRR to try to develop more of an interaction-8 in that area which tends to be a summary of -- not a summary 9 but developed inputs from many other areas plus licensing 10 that it's an appropriate area for them to pull.together.
11 So what we have attempted to do here in this 12' region is to have ownership, if you will, of individual 13 sections of the report by all of the major contributors to 14 the report.
15 So NRR has that section, as I've said, DRSS has 16 three sections, DRS has one, and project develops two.
17 Then the other difference that you will see as you 18 go to different regions is, who preperes the report? In 19 many regions the technical support staff actually pulls 20 together the report.
21 We think that the way we do it is good, but that 22 doesn't suggest that the way other regions htindle it is not 23 also good. We like to have all these focussed -- this 24 activity with the senior resident, that's already been done 25 here and I'm very comfortable with that and we will continue 1
("3 Heritage Reporting Corporation j
\/ (202) 628-4888 t
1 322 l
[~T i 1 to do it that way.
2 MR. CARROLL: Does NRR really have the background ,
3 on the plant operation and all the aspects, I recall, that 4 are covered under safety assessment, quality verification?
5 MR. KANE: Well, they don't do this in the -- in ;
I 6 fact, none of the sections are developed completely by any <
7 one particular unit. If you look at our original 8 construction, all of the other divisions that's appropriate l 9 can provide inputs to the individual sections of the report.
10 For example, just in the emergency preparedness 11 area there are programmatic inspections conducted by DRS of 12 the preparedness programs. There are, in fact, they have a 13 major input, as you get into emergency exercises, they're fs
(_) 14 there in bulk. But they are not there during actual events.
15 And the principal input from actual events would obviously 16 have to come from the senior resident inspectors. So that's 17 important input into that particular section.
18 And one that we attach a lot of significance to, 19 really, the response to actual events. The actual 20 implementation of the plant.
21 In the case of safety assessment, quality 22 verification, the other inputs to the report are used by NRR 23 in the development of that section. So they have access to 24 all of the other information. In addition to that, there 25 are certain inspection modules that we have arranged for
,/~N Heritage Reporting Corporation
'd (202) 628-4888 E__ _ _
l..? '
L j -323
\' 'l ' 1 them to conduct. NRR, project managers have, in fact, 2 conducted; inspections. They are there at'the plant 3 periodically involved in understanding what's going on, 4 communicating with the residents on a daily basis. So I 5 'think that we're probably not where we want to be on'that 6 particular section which is a new one. We' re still trying 7 to work some of.the bugs out of it. But I'm satisfied that 8 the process is working reasonably well and that they have 9 access to really all the information.
'10 MR. RUSSELL: When you cover the process of the 11 Board meeting and how the Board handles each area and in the 12 interaction that Bill will be going through,.I think you'll 13 also get a better feel of the inputs from the other
() 14 divisions ~are considered and the methodical process that's 15 going through evaluating against each of the factors for 16 each of the areas.
17 MR. KANE: As you think about all of the areas, 18 the senior resident inspectors obviously have an input to 19 all of the areas, security issues for example. I mean, 20 they're exposed to the security system every day they're 21 there and if there are security events and how they're 22 responded to.
23 The first response is -- and the understanding of 24 that response is by the senior resident inspectors. The I 25 radcon area of the -- actual working of the latter program O Heritage Reporting Corporation (202) 628-4888 l
.. 324 Y jf ( t 3 9 1- and actual projects. Again,'the resident inspectors have an 2 . input into that.
3' So.there is -- that synergism, if you will, that's 4 important and that.has to be an integral part of the 5 preparation of a high quality SALP report.
6- RDR. REMICK: Who provides the region-to-region
.7 consistency; is that NRR?
8 MR. KANE: Yes. The Commission -- help me out, 9 Ken.
10 MR. MARTIN: That's a human factor --
11 MR. KANE: Yes.
12 MR.' RUSSELL: The division of licensee performance 13 and quality evaluation.
14 MR. KANE: Quality evaluation.
15 And, in fact, Gene is going to touch on this in
.16 one of his slides. One of the things that we did just 17 recently, I guess three or four months ago, they had a 18 meeting in which all of the regions came in and we went over 19 the implementation of the new SALP manual chapter and how it 20 was working and tried to provide some mid-course corrections 21 to the program and there are going to be changes, minor 22 ' changes as a result of that. That is a periodic process 23 that we go through.
24 The management meeting is certainly one of the 25 highlights of the process because it's at that point where Heritage Reporting Corporation O- (202) 628-4888
- 325 i
~
l' we can communicate at the senior levels of the egancy with 2 the senior members of the licensee's organization and get a 3 full dialogue in terms of what we're trying to tell them and 4 how they view the report, how they read it, and whether they 5 agree with it or disagree with it, understand it.
6 But more importantly, to understand what they have 7 done or plan to do in response to the report, if anything.
8 DR. REMICK: Those are opened to the public?
9 MR. KANE: Yes. In fact, those meetings were not, 10 I guess, widely attended in the past because it was not 11 publicized, only through our meeting notice that goes into 12 the PDR.
13 Recently -- I guess not so recently, perhaps a 14 year ago, we started instituting or we instituted a press 15 release and that press release now is the time to place the 16 meeting. And the fact that it's generated significantly 17 more activity in terms of the press and the public.
18 But I must say the -- I think that that has -- I 19 don't notice a large change in the interaction that takes 20 place at the meeting as a result of this increased 21 attention. So I think that's a positive part of it.
22 MR. WYLIE: Was that a decision by region?
23 MR. KANE: By this, yes. Although I believe at 24 least one of the other regions -- I believe it's Region 3 25 does it.
/~ Heritage Reporting Corporation k-} (202) 628-4888
.)
I'. 326 L.
- ('T ki- 1 MR. RUSSELL: That'was a decision that was made:by_
2 me in the' region. We did discuss that approach at the 3 senior management meeting and it has been agreed that the 4- other regions will also adopt'that practice.
r
! 5' DR. REMICK: And it's held at the site; is that 6 cc,rrect?
7 MR. RUSSELL: It'e generally held in the' vicinity 8 of the site. I've had a few'here at the_ region, butlin the-9 main they're at the vicinity of the site.
10 MR. KANE: Our practice is to hold them at the 11 sites. Now, there may be some.-- there are variations off 12 of that. For example, the recent ones at GPU that involved 13 Oyster Creek and TMI that happened to be completed roughly
()
14 at the same time, we held that particular meeting in the 15 corporate office. It varies. But we like to have them 16 really at the licensee's organization so that they can 17 maximize the number of people that they can bring to the 18 meeting and share with us some of the things that they're 19 doing and hear firsthand, you know, what our key issues are.
20 A letter from the licensee, although I have 21 encouraged licensees to respond to the report -- to the 22 entire report, not just those areas in which we have 23 identified weaknesses or an opportunity to improve, but 24 really to the entire report because I think that -- and that 25 is really the final agency document that includes their
- (~ Heritage Reporting Corporation
\ (202) 628-4888
i 327 1 response. And to the large extent, it puts what we are 2 saying into context. And also, at times we will provide a 3 clarification or even correction of a statement that was 4 made in the report.
5 So, although the final report doesn't get as much 6 . play, if you will, as the original report that goes out that 7 precedes the public meeting it is, in fact, the key report 8 from my atandpoint because that includes their response to 9 the report. And that's what we review and take cognizance 10 of at the next cycle.
11 MR. CARROLL: If the licensee's response points 12 out something where you agree, you made a misstatement, do 13 you change that in the final report?
() 14 MR. KANE: Yes. In fact, that's -- in the final 15 report if there is a need to clarify the report, correct the 16 report, or even in one instance that I can recall we had 17 third factual material that was not represented to the Board 18 properly and it resulted in a grade change. So wherever you 19 get the situation we've got some pivotal kind of information 20 like that where you are sitting on the borderline.
21 But, in fact, those three things happen: changed 22 pages are lined out and new pages are inserted so that it's 23 clear what the original report says and what we changed it 24 to and those are included in the final report.
25 MR. CARROLL: Is that the practice in all regions?
/^s Heritage Reporting Corporation
(_) (202) 628-4888
{-
r h
[ .
328 j
~ \~# 1 MR. KANE: That is the practice of all regions.
i p.
2 MR.. RUSSELL: In fact, in~ addition to just the f
3 change there-is a reason why the change.was made that's 4 included in the report. So there is a record of the 5 licensee response; the change that was made; and why that h 6 change was made.
7 MR._ CARROLL: You mentioned this meeting where the 8 regions got together and' looked'at how. things were going 9 with'the new manual chapter. How did you feel. coming-out of 10 the meeting, did you feel that. Region 1 was or that all the 11 regions were implementing it in a fairly consistent fashion.
12 or were you surprised that Region X took a quite different-13 view of a particular element of the program?
-( ) 14 MR. KANE: No, I think I left there with the 15 impression that we were reasonably consistent.. I did leave 16 there with some assurance that the other regions were 17 struggling somewhat in putting this safety assessment, 18 quality verification section together. That'a been --
19 everybody was working hard.
20 In fact, the maintenance and surveillance section, 21' combining those two into a single section was something that 22 all the regions are going through the throes of trying to 23 pull those together into the proper waiting of the two 24 areas: engineering and technical support. We've been doing 25 that for a long while up here in this region. The other Heritage Reporting Corporation (202) 628-4888
7--
- n. .
4 >. 329 p.s,
~
-' 1- regions, I guess, have added that as a result of a new 2 manual chapter.
3 I left there with a reasonably' good feeling that 4 we were in the same format. Trends was an area that-Gene
.5 reminds me of that if we decided to make a change on, we had 6 ; typically then -- and-my slide in there will indicate the 7 old methods, it need' to correct .that when I get to it -- but 8 we had.been-looking at a snapshot of the last quarter of.the 9 period, in a'16 month period would be roughly the last four 10 months we looked at to.see if there was a clear trend that 11 we ought to assign.
12 And, in fact, the new manual chapter or at'least 13 as a result of the meeting we decided that we don't need to 14 confine'it to that particular period because what it does 15 is, areas like the emergency planning and security which, 16 you know, you're taking a shot at the middle of the period.
17 You measure inspection activity and it's not quite fair to' lL 8 judge that on the last four months when your observations 19 aren't as tense.
20' So what we have decided is that we can take the 21 whole period into account. And really the big decision is 22 only on the Board's part reflecting their performance trend 23 that we see during the period, whether legally that's going 24 to result in the next period, if that trend continues, a 25 grade change. That was one of the adjustments made at the Heritage Reporting Corporation
[]~'- (202) 628-4888
330 L 1 meeting.
2 MR, CARROLL: By all the regions or by Region 1?
3 MR. KANE: No, by all the regions. We all got 4 together and agreed that that was the kind of approach'that 5 we would like to take and it was agreed to by the program 6 office and it's going to be reflected in our upcoming 7 revision.
8 MR. CARROLL: But that was the major one?
9 MR. KANE: Well, the others were somewhat 10 mechanical. And one was the length of the SALP. I think 11 all the regions agreed that ' the objective of the senior 12 management of the agency was try to reduce in size the 13 volume.of the SALP, get the written material down to an area t( ) 14 of 25 to 30 pages. The assessment, we all agreed that that 15 was a good goal and that we would do that.
16 Also, the timeliness of the SALP, we agreed that 17 we should shoot for a goal of 90 days from the close of the 18 assessment period to the meeting with the licensee 19 management. So those are more in the administrative area..
20 Now, Gene, were there others?
21 Oh, we -- there was some discussion as to whether 22 we should go to five grades rather than three because of the 23 difficulty of trying to distinguish a weak 2 from a strong 2 1
24 and so forth.
25 I think there was general agreement that the Heritage Reporting Corporation (202) 628-4888
, 33't
- xJ 1 historical' base that exists, which has always been the 1, 2, 2 and 3 really weighed against that. Also, that there may be 3 a tendency to be-dominated by the 2s, 3s, and 4s, rather
~
4 than the is and 5s. Those were some of the considerations.
5 I think everybody agreed that we should keep.on the grading 6 system that we had now.
7 MR. CARROLL: One thing that occurred to me about 8 the present SALP situation is that, I guess you can look at-9 the report as an overall management report card. Was there-10 any discussion of possibly putting a category in on 11 management performance?
12 MR. KANE: There was not -- I guess there wasn't a
~
13 whole lot of discussion on that. You know, I think we kind 14 of see the safety assessment, qualit3 verification areas as 15 being sort of a surrogate for that discussion.
16 We did it a little differently here years ago and 17 tagged an area that was perhaps more of a management report 18 card. But I think -- that's where we're trying to focus 19 that particular section of the report and I think we 20 generally agree that that's the place for it.
21 MR. CARROLL: It's sort of a funny name for 22 management performance.
23 DR. KERR: I guess it would seem --
24 MR. KANE: Gene, certainly the next point, you 25 know, if you look at the first evaluation criterion of the Heritage Reporting Corporation (202) 628-4888 I
L-- --- _ _
b3 332 i; Ly %
b-) 1 seven that we used, which I'll get to a little later, that l
2 focuses strictly on that area.
3 MR. RUSSELL: Bill, would you highlight also the 4 rotational program that we have for senior SALP managers 5 'between regions to ensure consistency.
l l
6 MR. KANE: .Right, that's another good point.
7 We try to -- I guess I got the SALP Board 8 composition up.here. Typically it's. chaired by either the 9 director or the deputy director of the Division of Reactor 10 Projects. And the members are typically as shown there. I 11 must-say that in order to maintain a balance we tried to 12 assure that we had -- we don't have an excess of people from 13 reactor projects on there, so that -- this is typical --
() .14 it's not a typical Board, but it's a typical people that-15 could be represented on that Board.
16 And as Bill points out, what we also have is a 17 goal of rotation policy -- not a rotation policy, but a goal 18 of having those individuals, in particular, people like 19 myself or my deputy director Sam Collins attend other SALP 20 Boards in other regions and serve as a member. That, in 21- fact, provides a couple of things.
22 One is, how are we grading relative to other 23 regions? And also,. are there good ideas in the conduct of
- 24 the Board that we can bring back and apply? And we have 25 done that. Most recently Ed Greeman, my counterpart in Heritage Reporting Corporation (202) 628-4888
333 3
(
/ 1 Region 3 was here and sat on the Peach Bottom SALP Board, 2 that report we haven't issued yet.
3 But I guess one of the things that was sort of 4 amusing to two of us was how consistent our individual 5 scoring of the functional areas was. Following that meeting 6 he also took a trip down to Peach Bottom and-toured the 7 plant and got a good understanding of how consistent the 8 inputs were with his understanding of the plant, which was 9 favorable.
10 MR. CARROLL: All the regions are doing this7 11 MR. KANE: Well, I can't say. I suspect that they 12 are. I believe it's a goal to do it, and I assume they are.
13 We are doing it. Region -- I know all the big regions are n
- (-) 14 doing it. And that's -- although occasionally some of these 15 have to be canceled out because of other reasons. I know 16 Sam was scheduled to go down to Region 2 for one and had to 17 pull out of it. He's been to one, Region 3.
18 So it's a good process and I think we benefit by 19 that interaction and exchange of information.
20 DR. KERR: I just want to comment briefly on 21 management performance. It seems to me, if I understand 22 what you're doing that, you can't have a much better 23 indicator of management performance in the way the plant is 24 operating. I would think that concentrating on that makes 25 sense.
Heritage Reporting Corporation
(]-
' (202) 628-4888
I 334 I I_ i
> 2 MR. KANE: Well, I'll do a little matrix here 2 later on and I'll show you how to do the scoring and how we i
3 can look to individual areas of overall weakness or l 4 strength.
5 I would like to turn to functional areas now and 6 go through those briefly with you. You're probably aware of I 7 them, and we've talked about them from time-to-time.
8 There are seven; and then there are the others as 9 needed. Occasionally we will get into a situation where 10 there's a - principally we'll do this if there's a problem 11 and not if there's a strength, although certainly we could.
12 But let me give you an example of one that we 13 might pull out and deal with separately. Perhaps an area
() 14 like fire protection which cuts through many of these 15 functional areas. If that area was experiencing some 16 difficulty you would probably find it sprinkled throughout a 17 number of these areas. For example, plant operations, 18 maintenance and surveillance, engineering and technical 19 support.
20 And if there was a reason to pull that out 21 separately to make a more clear case to the licensee, we 22 have the opportunity to do that. That really hasn't been 23 employed recently.
24 DR. KERR: What would be an indicator that fire 25 protection was having difficulty? That one was having too r~N Heritage Reporting Corporation U (202) 628-4888 l
L __
f 335
]
\ _
7s).
1 many fires?
2 HR. KANE: Well, that's one possibility. Another 3 possibility may be, there are too many fire watchers,.which 4 might be an indication of equipment being allowed to degrade 5 or remain out of service for a long period of time. There
.6 might be associated problems with fire watch training.
7 Those are the kind of indicators that we would look to.
8 DR. KERR: How do you know how many fire watchers.
~
9 are too many?
l 10 MR. KANE: Well, I think we look at the control of 11 those fire watches. Certainly, you can look at the number 12 of-people that are needed to staff them. You can look at 13 perhaps their attentiveness. As you go around through the
() 14 plant sometimes you see for fire watches that are there for 15 a long period of time. At one of the plants that was the 16 case, longstanding fire watches result in people sitting 17 there for long periods of time in areas that eventually they 18 become perhaps bored with the job. They fall asleep. And 19 you typically see that for fire watches-that are employed 20 for long periods of time.
21 So the real objective would be to, from out-22 standpoint, would be, you know, obviously those things are 23 needed at the time for good reason. And what we would look 24 to would be to make sure that those equipment gets fixed and 25 the fire watches are removed.
Heritage Reporting Corporation
[] (202) 628-4888 1
s- 336 1 MR. KELLY: Another answer is, that's typically a 2 tech spec surveillance, once you've got an LCO on a barrier 3 down and you have a watch. If you have an excessive number l 4 of watches, compensatory-wise, you increase the likelihood 5 of missing the surveillance and you start to see an 6 increased incidence of LERs say "miss surveillance, fire 7 watch late by ten minutes or got to get to this barrier 8 within an hour." That's another indicator that maybe there 9 is too many barriers down. Maybe there's too many things 10 being compensated.
11 So an increase in LERs that report missed 12 surveillance due to fire watches is a classic indicator.
13 MR. KANE: The evaluation criteria I will go r^s
(_) 14 through next, just to go through them. And the waiting of 15 these I would say is not equal.
16 The first one is assurance quality including 17 management involvement and control is one that I referred to 18 before. Approach identification and resolution of technical 19 issues from a safety standpoint to responsiveness to NRC 20 issues, enforcement, history, events, staffing, and 21 effectiveness of training and qualification. I don't know 22 whether you want me to go into what each of these mean. If 23 you have any questions about what do we look to, I will be 24 glad to answer them.
25 DR. REMICK: I think just respond to any questions
(~)
\/
Heritage Reporting Corporation (202) 628-4888 l i J
l t
337 UA . 1 the. committee has.
2 DR. KERR: What is meant by " responsiveness to NRC 3 initiatives?"
4 MR. KANE: Responsiveness to NRC initiatives is 5 what you're asking me.
6 What I pointed to earlier was things like 7 bulletins, information notices, generic letters, any of the 8 things that the NRC issues for action, we look to how the 9 licensee has responded to those and how well they've done.
10 That's the principal --
11 DR. KERR: So in a real sense that could be folded 12 into the number 2.
13 MR. KANE: I'm sorry?
14 DR. KERR: I said, that in a sense could be folded 15 into number 2 because I would assume that a good many NRC 16 initiatives of the kind you describe have to do with 17 technical issues.
18 MR. KANE: Well, to an extent, they're all 19 somewhat interrelated. If they do too bad a job they end up 20 with enforcement problems as well. But we reserve the 21 second one to really look to basically how they're doing in 22 identifying issues and resolving them on their own. So it's 23 more of a self-generated type of not waiting for the NRC or-24 someone else to identify problems, but the kind of program 25 that they've got in place to identify their own problems and
[~h Heritage Reporting Corporation
's# (202) 628-4888
1 -
1 k' : L
- j- .
338 1- to take care of them or'someone.else brings them to them.
2 'So it's a different looki Obviously,.it'is,-as
-3 you say, interrelated.
4 I would point out that in'the manual chapter,Lif 5: you take a look at it there's a whole set of. things that you 6 'look for under each'of'these individual criteria that have 7 to be examined. It'gives you, not prescriptive guidance but-8 the kinds of things that the SALP' Board might look at when 9 they're reviewing a report.
10 MR. CARROLL: Let's take a hypothetical situation 11 hero. Suppose there's bad relationship between plant
- 12. . management and a resident inspector in the sense that the 13 resident uns all these wonderful ideas about'what the
() 14 plant's priorities.ought to be. And the plant manager, you 15 know, says, look I'm running this power plant, I know what 16L my priorities are. If I did every wonderful idea you'came
.17- up with, Mr. Senior Resident, I would have my whole staff 18 tied up round the clock.
- 19. How does a situation like that get resolved in the L20 SALP process?
L 21 MR. KANE: That's the wrong place to resolve that j 22 issue.- If it has to be resolved there, then there has been E 23 a management failure long before you get there.
24 But if, in fact, that did occur the issue would l.
25 have to be, if they were such as the licensee did not
~
l Heritage Reporting Corporation L 1 -
(202) 628-4888
lY',' -
l3 339-('"h,- ; .
' ' '11 -respond to my little list of good things that I want'done, L -2 that is'something that the Board by virtue ofLits I, -3 . independence'fromthatparticular=facilityis'charhedwith-4 having.the wherewithal knowledge, the capability of' dealing 5 with those kinds of issues.
6- .If they're important and they can be' defended, 7 they will. stay in there. If they can't, then they won't.
8 And that's how we deal with it. And in many instances, you 9 .know, I'll be the first to tell yoa that. some things that 10 are written.into these reports initially that are reviewed.
11- by the Board aren't all that important to us. They are 12 isolated problems and net something that needs to be,
.13 perhaps, even addressed in a SALP report. And those things b 14 are just automatically eliminated by the Board,.where.the
- 15. Board doesn't feel they're appropriate. And that's our 16 charge.
17 That's why we review it at a Board. If it weren't 18 for that we could issue a set of unrelated individual 19 sections to a licensee, and I don't think that would be.very-20 useful because it would be to some extent dominated by the 21 individual who did the preparation.
22 Let's go on to --
23 MR. WYLIE: Let me ask a question, to pursue Jay's 24 question a little bit further regarding management.
- 25 Regarding actions that may be taken by corporate manag.; ment l }' .
Heritage Reporting Corporation (202) 628-4888
\ I
.r
= _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ = _ _ _
.340 pg) - I that may eventually go-up but hasn't yet such as austerity 2 programs, cutbacks in personnel, and how these are handled 3 in the corporation end in the plant, it may cause 4 deterioration of plant morale, for example.
- 5. How are these detected or how would they be )
6 detected then? Would the SALP process be the_way?
7 MR. KANE: Well, then it's the SALP process would
.8 certainly punctuate that in a more visible and significant 9 way. But again, SALP report is a recording of --
10- MR. WYLIE: Of your history. I
- i 11 MR. KANE: -- of history to some extent, and a l 12 simulation of that history into some overall conclusion. ;
i 13 But again, that process needs to be detected much earlier
() 14 than that. Again, it's not the purpose of the SALP Board to 15 identify ongoing rr s but previous indicators of declining i 16 performance. That's the function of the inspection process I l
17 to do that and the function of the management that's j l
18 reviewing the inspection reports to pull out these issues. !
19 and highlight them.
20 EB McCabe yesterday talked about silver bullets !
21 and big issues that need to be targeted very clearly and 22 concisely to the senior management inspection report cover )
23 letters, and you know that would be a typical one.
24 Now, we can put back on the previous slice, Monty.
25 But how would some of those things be reflected?
J #s Heritage Reporting Corporation l .
(202) 628-4888 l.
L L_i -_ _.__ _.
341
\ '3-1 In the bottom line one area would be staffing. If you were 2 to see, for example, operators not coming into the pipeline, 3 you know, you could have an early indication of some future 4 problem, although there may be a six shift rotation where 5 this would be, you know, a pretty sound kind of operation.
6 There could be some early indicators that a year or so from 7 now or two years you may be building a problem by not 8 bringing enough people into the pipeline.
9 So that's the kind of thing we look for as an 10 early indicators. Again, we should be getting that out of 11 inspection reports and punctuating that in the SALP report, 12 pointing out that this is an apparent weakness and a sign of 13 future problem.
14 The effectiveness of training and qualification is 15 another area where we could probably see it in the reduction 16 in the training budget, that sort of thing would be an 17 indicator of where you might see a problem developing.
18 MR. WYLIE: What about morale of plant employees 19 and things like that, do you get feedback like that?
20 MR. KANE: Yes, very definitely. And you will 21 look in any SALP report you will see areas like that. And 22 the classic problem, the kind of problems that we look for 23 are between operators, HP, maintenance, security. And you 24 can, through the inspection process, understand whether 25 there are morale issues that are being developed. And that Heritage Reporting Corporation
()) (202) 628-4888
342
,,s}
k- 1 is an irportant part of our process and if we see that we 2 will make a point of it.
L 3. NR. WYLIE: You would suggest this in your )
)
4 management meetings with the utility? ]
5 MR. KANE: Yes,. sir.
6 MR. KELLY: Just one-point, Jim, on your question 7 about the potential that responsiveness initiatives means 8 you didn't do everything I wanted you to do this past year.
9 You shouldn't underestimate the 10 HR. KANE: report process as well. Virtually 11 everything that's in the SALP has to come from the 12 inspection report finding. We don't invent things.
13 And second, the inspector has to document those in
() 14 the report and go through his section chief'. And there's a
'15 screening that goes on right at that level about, you know,'
16 whether this is really a safety issue or your idea of the 17 way it works. And then that report gets a pretty good 18 scrubbing before it's over released and it's approved by a 19 branch chief, a manager.
20 So there's an awful lot of things that go on long 21 before the SALP Board is presented with what they think are 22 the important findings to documents. And that's probably 23 more than likely where those issues get addressed rather 24 than ending up --
25 MR. KANE: As I was saying, it's too late for the Heritage Reporting Corporation 1
't (202) 628-4888
g 343-
'\ '
1 SALP Board - you want to have those issues developed'in the 2 inspection reports and reviewed by management. We get into 3 the SALP Board and identify a problem, something has failed 4 along the way.
5 DR. REMICK: Do you ever seek to confidentially-6 get information from the licensee to evaluate the senior 7 resident and resident? Do you seek out information?
8 HR. KANE: Well, one of the things that -- I don't 9 want to make a broad statement that I.always ask,.but one of 10 the things I'm always interested in and periodically ask is, 11 we go.around to visit with the plants is precisely that 12 interaction with inspections? What are your views? What 13 are your observations? Are there issues? Are there
() 14 concerns that you have identified? And, in fact, they tell
.15 them, call me if there is any sort of an issue or problem.
16 I don't go into the specific examples. But we do get calls.
17 I get calls with a question, you know, asking me to 18 undertaka a review of a specific issue that the licensee or 19 senior official may not fully understand or agree to. In 20 each instance we respond to that. I do, because I think 21 it's -- I'm interested in hearing those observations.
22 Because there's one of two things, either it's a 23 problem or it's a misunderstanding. And both of which are 24 problems.
l 25 DR. REMICK: I think licensees feel that's a Heritage Reporting Corporation v (202) 628-4888 1
344-
!~
k/ 1 considerable risk to raise some issues, like if they have a 2 resident perhaps pushing too far. If they feel that that's 3 the case, do they feel open to come to the region and 4 discuss those?
5 MR. KANE: I sense that they do. I sense that 6 they are because I don't -- we have certainly' utilities in 7 the region -- I don't believe that the senior management-8 level if they had an issue or a problem that they would have 9 any reluctance to come and discuss it.
10 MR. RUSSELL: My experience has been that they 11- have not hesitated to bring those kinds of issues because I 12 have had a number of them brought to me. And we've looked 13 into them. They've been brought to Bill. We encourage them
() 14 to have discussions with the managers in the region and if 15 there is an issue, then they relate to inspector objectivity 16 or an inspector attempting to manage the facility rather 17 than reacting to the facilities initiatives. So those kinds 18 of things have come up.
19 Other examples have been the utility identifies an 20 issue, brings it to the attention of the resident and the 21 resident turns around and writes it in his monthly 22 inspection report.
23 The utilities were concerned that they were being 24 beaten upon for identifying issues. So in reality-wise if 25 the resident was identifying those issues so that the r' Heritage Reporting Corporation
( (202) 628-4888 f
l 345
, ; 4 K/ 1 utility could take credit for their self-identification 2 program. l 3 So we've had everything from solicitation of 4 employment to disputes regarding how issues should be 5 handled and they don't hesitate to bring them to me or to 6 Bill.
7 MR. KANE: Yes, I can give you an example of one 8 without mentioning -- it doesn't always work out to their 9 advantage; sometimes it does and sometimes it doesn't.
10 The one that was brougt.t to my attention, I was 11 asked to look at a reporting issue that was identified or 12 was about to be identified in an inspection report, I guess 13 it was discussed in an exit, they disagreed with it and I rs
(,) 14 agreed to undertake a personal review of the issue and get 15 back to them on it.
16 My review of the situation was that the licensee 17 did not fully understand its obligations under our reporting 18 system. It was developed -- in fact, I thought it was 19 conducting a personal review of the matter probably more 20 serious than we were expressing it in terms of the report.
21 And, in fact, we went to great detail in the report to 22 explain the reason why they had the report certain equipment 23 that they had found through their own independent review 24 cast some doubt as to the fact -- not cast some doubt, but 25 determined that a particular piece of equipment was
(~N Heritage Reporting Corporation s_) (202) 628-4888
. 346 h' 1 inoperable for some period of time, albeit it had been-2- . fixed. The reporting of it was made to the resident 3 inspector and pointed out that, you know, there's a more ,
L4 general use of that reporting information than just within i- 5 the region or just within -- by the resident inspector.
6 That issue then was subsequently turned into an 7 agenda item for mid-cycle SALP review and discussed at 8 length with the licensee.
9 So, you know, we -- it was a very good issue, they 10 raised it, but it was one in which they were not. fully 11 cognizance of their responsibility. .In fact, that issue has 1
12 now been very' thoroughly aired. The response that I 13 received back from the utility was that they understood now.
'( 14 They had the wrong impression and that they were satisfied 15 with where they were.
16 It's an example of where we take each one that we 17 get very seriously.
18 DR. CATTON: Are there counter examples?
19 MR. RUSSELL: Yes, there a number of counter 20 examples where it has gone the other way.
21
. KANE: Well, you know, I think the good 22 example was - I won't go into the plan -- but the one that 23 I cited earlier where, in fact, they presented information
- 24 that suggested that we were wrong about our analysis of a 25 particular event that resulted in a change to a SALP score
/' Heritage Reporting Corporation (202) 628-4888 1
s 347'
.U- 1 on a plant.
2 That's probably,-you know, a good example --
3 counter example, if you will.
4 MR. RUSSELL: There have been~other cases where we
- 5. have taken personnel actions as well. So it goes the whole 6 spectrum. We've even had request to hold enforcement 7 conferences at the site on issues to make sure that 8 management could see the issue and understand it, put it in 9 context because they didn't feel they were getting a fair 10 shake through the process.
11 There's a wide spectrum and I have not cetected 12 hesitancy on the part of licensees to bring those kind of 13 issues to management. .That's just judging based upon the L( ) 14 issues they bring to me or to Bill.
15 MR. KANE: But it's important that they do go both 16 ways.
17 The performance rating, I guess you're familiar 18 with. If you look at -- we discussed this a little bit 19 earlier, the gradation of category 1, 2, and 3. All, as you 20 pointed out, defines with the regulation. But the different 21 degrees of performance measured off of that --
22 DR. KERR: It's a little interesting that on 23 catego.y 1 the last sentence says: " Reduce NRC attention 24 may be appropriate." And the last sentence in category 3 25 says: "l'RC attention should be increased. "
r% Heritage Reporting Corporation i
1 1
- 4) (202) 628-4888
t
, 348 i '-' )
1 MR.-KANE: Yes. And I can answer that, at least 2 from how we apply it here. We have -- we measure 3 performance and based on that performance we also have to 4 make some judgment as to how we're going to inspect.
5 An example of a category 1 performance that would 6 not necessarily result in inspection may be, where there has 7 been a long history of -- let's say, category 3, category 2 8 performance and the utility has presumably finally turned 9 the corner and is, in fact, operating at that level.
10 The SALP Board may decide and has in some 11 instances to maintain inspection levels at the current level 12 through the next cycle, essentially to confirm that, in 13 fact, this has really occurred.
-)
14 Now, for those facilities that have been operating 15 at a category 1 level for long periods of time and where the 16 next SALP indicates that they're still there, certainly, we l' would not increase. There may be some justification for the 18 example that I cited. In the second cycle it's still 19 category 1 to then reduce the inspection reuources.
20 So it's a judgment that we have to make based on 21 -- because you're measuring performance and you're also 22 measuring how does that apply to yo"ar inspection program or 23 how do you want it to apply. So that would be an example 24 where we may not reduce resources.
25 In the case of category 3 I think it's very clear Heritage Reporting Corporation
(~)/
'- (202) 628-4888 i
- - - ~ ~ ~ _ _ _ - _ - _ _ _ _ _ _ _ __ _
b 349
' f( 1 that we believe they're operating at that level. When it m
i; k
2 .says "should" I think that's what we have done inia 11 3 instances, and I don't know of any -- I can't come.up with 4' any example of why we would not increase inspection.
5 DR. REMICK: Gentlemen, I look and realize that 6 we're on yesterday's agenda yet, we've got to find some ways 7 .of speeding up.
p 8- MR. KANE: Okay.
,- 9 The trends: the only change I would make here is, 10 certainly the long-term trend we try to look at. You know, 11' we have seven or eight SALPs now we can look back on, and I 12- think the long-term trend is a good indicator of how 13 utilities deals with a particular area.
() 14 Intermediate-term trend is just what I call SALP 15 to SALP. In other words, what was it last period? What was 16 it this period?
17 The recent term is really -- and I said there 18 during the last quarter of the current SALP period, but as I 19 indicated earlier that's no longer true. But it's to give 20 us an indication of where we think the licensee is. going.
21 There's a clear trend and depending the Board it's going to 22 result in change in grade.
23 Next slide is just some time frames. I know that 24 you've raised issues before about the timeliness of these 25 reports, that they're out well after the close of the
N
/ Heritage Reporting Corporation (202) 628-4888 I 4
I I
l
h 350 y
[.q)1 1- period. 90-days is the target to meeting with-the licensee.
E 2 Those goals are' interim goals that maybe deal with -- and i
3 the total span'of the entire period is 150-days from the 4 close of.the period to the issuance of final report.
5 We go to'the next slide, again,~this is how we 6' look at each of these functional areas. We will take the 7 seven functional areas, the seven' criteria, evaluate those 8 in the Board of 1, 2, or 3, discreetly. And at you complete 9 this entire chart during the course of a day or more, you 10 may see some -- as you cut through all the functional areas 11 -- you may see some trends that point to the problems.
12 For example, staffing may be generally weak. And 13' that's the kind of thing we look for. Is there a
( 14 significant trend looking vertically through all those 15 functionar areas.
16 That's all that I had. Gene was going to provide 17 a summary of results and if he can get through that quickly, 18' then we'll try to respond to these other questions that you 19 have.
20 (Slides being shown.)
21 MR. KELLY: What I would like to give you is 22 basically the process, you know, what we produced out of 23 SALP here in the past year or so. Also, the results; and 24 finally some initiatives.
25 Sam Colline will be up to talk about what kind of Heritage Reporting Corporation
(']
k (202) 628-4888
351 g
NJ
- 1 effectiveness we're getting out of the process.
2 Tim will address PUC actions and some of the 3 philosophical questions about SALP. So a lot of it's raw 4 data and the way we do it.
5 The first slide basically talks about how we're 6 performing with respect to lengths of the period, how 7 quickly it takes us to get a report on the street.
8 The chapter, the manual chapter asks that the 9 average be 15, that nothing be longer than 18 months, 10 basically we need that. Some of the plants that we have 11 special concerns about we shorten periods. Plants that we 12 don't have concerns for the periods are longer.
13 You can see that -- for example, I have put up
() 14 Peach Bottom, basically about a year, Nine Mile; Millstone 15 and Susquehanna go out longer, that's -- 23 months is a typo 16 up there for Susquehanna; Seabrook -- Seabrook and Limerick-17 2 were special cases against Seabrook because of its special 18 condition, and what we were assessing we drew out the period 19 longer than normal. And in Limerick-2's case I think we're 20 going to be ready for the first joint review of both
{
21 Limerick's Units 1 and 2 this coming year and that was an 22 attempt to bring them both on to the same cycle, whereas in 23 the past they had been in construction, the last 24 construction facility.
25 We've had internal goals to attempt to get that Heritage Reporting Corporation
,/~S)
(_ (202) 628-4888
352 k_) 1 initial report from the Board published to the licensee 2 within 60-days from the close of the period.
3 We have also attempted, as Bill mentioned earlier, 4 to go to the management meeting within 90-days and, of 5 course, fold the whole process in so that that final report l 6 is out in 150-days.
7 During the last year we basically met those goals.
8 This basically gives you a feel for what we do in a year's 9 time frame. We obviously don't do all 23 sites in a year 10 because the periods are longer than 12 months.
11 Anywhere from 15 to 20 Boards are held in a year.
12 This particular 12 month period up to the end of this month, 13 we've had 16 Boards. It basically takes us 49-days in the
() 14 average to get into a Board. We have issued 13 initial 15 reports with an average of 14-days or 74 days. We've had 15 16 management meetings conducted in a year and it's basically 17 averaging about 92-days to get into that meetings. And 18 finally, 16 final reports issued with an average of 153.
19 Those numbers have all been trending down over the last year 20 and a half as well. And again, the new goal in the manual 21 chapter will simply say, get to a management meeting within 22 90-days and we'll still go for those others.
23 Bill mentioned earlier that there has been a move 24 in the agency to improve the readability of the report by 25 reducing the total length. I'll say a person or anybody Heritage Reporting Corporation f^)s
(,, (202) 628-4888 l __
L:
I i 353 l
(~h i
\~ l that has ever tried to write one of these SA1 P, SALP is 2' tough. Assessment is tough, but it's not always easy to do l
3 it,.but we do strive to put out a goal that each function )
1 4 area assessment will be no more than three pages, and 5 there's obvious exceptions.
6 We've also had initiatives in the last year in 7 this region to reduce the tabular data and the statistics.
8 We've also had a move that came out of the counterpart 9 meeting Bill talked about in June where all the regions met 10 to discuss how we are doing with SALP, basically pushed the 11 boilerplate to the back. Push a lot of the tables or 12 overviews to the back so that you can get the read right to 13 the overall assessment in better focusing.
A
(_) 14 So we've averaged those numbers now. We basically 15 average about 35 pages of assessment; 10 pages of tables; 16 and those numbers have been grinding down steadily for the 17 last six months.
18 And finally, Bill may not have mentioned it in his 19 presentation, but he has done estimates that indicate that 20 SALP basically cost the manager in this region about 25 21 percent of his total time. We talk about reviewing the 22 initial reports and the other reports. Going to a Board 23 which lasts a full day, sometimes two full days. Getting to 24 management meetings including travel. You're talking about 25 a commitment of almost one-fourth of management's time in
/~5 Heritage Reporting Corporation
% (202) 628-4888
l L; '
s.
- 3541 1 this: region'to go SALP. . Pretty telling statistics.
- 2, MR. WARD: What do you( mean by managen.ent- time? -
3 Bill'Kane,.for' example --
4 MR. KELLY: Yes, Bill Kane'-- I guess to'a lesser.
- e. 5 extent, branch chiefs, Bill' Russell, but principally. Bill 6 Kane. He's speaking personally 25 percent of-his, time.
7 MR.. RUSSELL: It's mainly evenings and weekends,
- 8. too, to do the reviews, the reports,'plus the. time for'the 9 Board meetings. It is very resource-intensive for
'10 management.
11 MR. KELLY: 'Next slide.
12 This'next slide'is just a pretty slide that.Monty 13- put together'that basically shows.you how we do plant-by-( )< 11 4 . plant in getting to the Board. Getting.the first report 15' out. Getting.to management meetings. And getting the final 1
16 reports out.
17 This next. slide shows you a distribution of"the 18 ratings. If'I look at the Boards that have been conducted 19 in this region since last March with the exception of, I 20 think, Yankee Rowe and Susquehanna'were all conducted under 21 the new manual chapter. I mean the new manual chapter, I 22 think you're aware we revised the 0516 manual chapter in NRC 23- and went to seven functional areas.and other changes; and 24 that came out in June of last year.
25 So basically for those Boards that were conducted Heritage Reporting Corporation (202) 628-4888 il
-s 355 )
()
1 since March of which there were 22 plants, you multiple 22 J
2 times 7 and you have 154 possibilities. Here is the spreads l
l 3 of the scores by functional area.
l 4 I guess one of the more important things to note 5 on that chart is if you look at the 2 declining the 3 6 improving and the 3s, we're not talking about a whole lot of 7 scores.
8 Monty, the next slide I think shows this as well.
9 There are relatively very few category 3s in this 10 region or 3 improving or even 2 declining.
11 DR. REMICK: We had heard you're soft to the 12 licensee; is that true?
13 MR. KELLY: Are we soft to the licensee? I won't
( 14 fall into that trap.
15 DR. REMICK: The record probably show that I have 16 a smile on my face when I said that.
17 MR. KELLY: Tongue in cheek.
18 I would like to think the word proactive is 19 probably a better word, the operative word there. I don't 20 think we can afford to wait to get to a 3 and do something.
21 Management's response, I've seen it in many, many 22 different arenas it's word proactive; it's getting ahead of 23 problems.
24 DR. REMICK: So is that the reason?
25 MR. RUSSELL: I would suggest you need to ask the
'T Heritage Reporting Corporation (J
k (202) 628-4888
f~s, 356
,5 t
^
1 licensees as.to whether'they feel we are soft on licensees.
2 DR. KERR: One of the objectives of the process is l3
, 3' to have all the plants be above average; and one can see 4 that they are moving in that direction.
5 (Laughter) 6 DR. REMICK: In fact, SALP at one time was average 7 above and below, that's how they were --
, 8 MR. RUSSELL: No, the criteria for rating the 9 plants.are described and we go through a judgment process, 10 and I would like to characterize that we have more plants 11 that are above the minimally acceptable level so that the 12 margins between safety that's in the regulation and where 13 the plants are performing isLimproving.. And I think the 14 safety trends by other indicators show that.
- 15. Three needA to be meaningful and when we use it we 16 do get their attention.
17 MR. CARROLL: How do.your ratings, if you know, 18 correlate with INPO's rating, fairly well?
19 MR. RUSSELL: I can only comment on the, few cases 20 where utilities have shared that information with me where 21 it has been a problem facility. I'm not aware of any 22 correlation that has been done. INPO's information is 23 pretty closely held. Ours is widely publicly available.
24 And I do not know how they compare.
25 I do know that cases where we had plants that have L Heritage Reporting Corporation k (202) 628-4888
H g '
.. 4 J:
357
-) 1: shut down either'under order or under confirmation of action.
'2 -letter have been extended outages that the evaluations of ;
3- the problems between the NRC's views and INPO's views have 4 bean. fairly consistent; and'I've had that feedback from the-
[
5 renior management of the utilities and-to some extent 6 discussions I've had with INPO managers.
7 HR. KELLY: Next slide, Monty.
8 This is-at an attempt to look how SALP affects our l-9 prioritization of inspections; we talked about some of this.
I:
l 10 yesterday.
11 I guess the thing I would like to offer here other 12 than the idea that SALP does drive some of those reactive, 13 discretionary initiatives, not necessarily the teams, core,
() 14- and other things which everyone gets, is something that Bill 15 brought up earlier that a trend may have as much if not more 16 important effect on an inspection decision than a pure 17 number, a score.
18 When we see a 2 declining I suspect that we are a 19 lot more concerned than a 3 improving, and that our 20 inspection resource decisions reflect it.
21 So trends are real important. The dynamics of the 22 situation is probably a more concern than pure numbers.
-23 Next slide, Monty.
24 Region 1, there's a couple of initiatives taken on 25 the last slide. This particular slide shows you a letter we Heritage Reporting Corporation
-\ (202) 628-4888
I 358 y) it E- : 1- sent~out this'past December to all the licensees in this-v.
2
' region. It was in part the-result'of a conference we had.-
'3- withLlicensees the year prior and.some of their feedback to 4 us that said, we would like you'to know the good things
~
-5 we're doing, so that they may be factorable in the SALP.
6 And in that' spirit we sent a letter to.all our 7 licensees'that prompted them to share.thsir self-initiatives l 8 :with us. And also, to give them.some time in the SALP
.9 management meetings to make presentations on those 10 initiatives.
11 Coupled with this the new inspection program has a 12 core requirement that basically has us go in roughly midway 13 to a SALP cycle to see how the licensee's quality programs 24 -are doing, how effective they are. This region has taken a 15 tact to attack that module with some meetings and some 16 assessments that basically have the licensees let us know 17 what they're doing and where the problems are.and we share 10 the information.
19 DR. REMICK: Suppose the question -- suppose the 20 licensee doesn't formulate he's taking the self-assessment 21 and a particular day there's a certain meeting snat he's 22 having outside consultants come in and so forth, does a 23 resident inspector feel that he's authorized to attend those 24 meetings by right, by law?
25' MR. KANE: Well, I think the relationship is that, Heritage Reporting Corporation (202) 628-4888
-359.
.i l
. \ ') .
l' that if there is such an activity going on typically, you
' 2L know,.the' resident will be informed and invited to them. I
, 3 think that's the way the process works or the resident
?
'4 became aware of something like that going on would ask the-5 licensee if they would mind he or she attended.
6 So the answer is that in general, yes, they could 7 attend.
8 DR. REMICK: What if the licensee said, no. 'There 9 is some risk there the licensee opening up his own
< 10 weaknesses and determined to the NRC that he fears then 11 might cite him and concentrate in those areas?
12 MR. KANE: Well, I think we would have to review 13 the reasons _and~if they made -- if for some reason that was
) 14 our participation or our attendance it'might, in their view, 15 inhibit the process I think we would give that 16 consideration.
17 DR. KERR: Suppose that in response to that letter 18 I'just saw'a management wrote back and said, yes, we have a-
, 19 self-assessment program and it occurs every. day, that's part:
20 of management; would that be an appropriate response in your 21 view?
22 MR. KANE: Well, that's part of the response. But 23 the idea of what we're doing here was to schedule our 24 activities -- our inspection activities so they were more 25 effective.
/ Her age Reporting Corporation (202) 628-4888 i__________----_--_--_----- )
p 360
\ :
1 I wanted to give you an example of why that would 2 be. We talked about safety system functional inspections 3 yestarday, and all of the licensees, to the best of my 4 knowledge, in this region are involved in that initiative.
5 Now, if in fact the licensee has scheduled a 6 majors safety system functional inspection for the third 7 quarter of the year and we had developed a plan to go in and 8 conduct a safety system functional inspection in the third 9 quarter of that year, to my way of thinking that's not an 10 efficient use of our resources as well as a burden -- it 11 could be a burden to the licensee.
12 We would opt to defer that inspection based on 13 that initiative that the licensee is taking one at a time.
/"')
(_/ 14 DR. KERR: If that's what you meant by that letter 15 as a managstent person and a utility, I would not have 16 understood what you meant by that letter.
17 KR. RUSSELL: Let me describe how the letter came 18 about. We had a workshop that we sponsored on SALP and we 19 had about 150 utilities attend. One of the continuing 20 themes throughout that was, you're right about'the things 21 that we're not doing well and your inspection program finds 22 and identifies the negatives, but you don't write about the 23 things in SALP that we're doing that are very good.
24 We have initiatives ongoing to improve our 25 performance and you have not inspected them or you have not Heritage Reporting Corporation
(^)
'- (202) 628-4888
361
.O'1
~
looked into them.
2 The response to that was to essentially offer to 3 ' utilities that'if they wish to identify their programs that-L l' 4' they thought were effective to take a little bit of risk, 5 describe what those programs are,.what they're doing, tell 6 us what their approach is, and we would evaluate that for.a 7 period of time and if it provided results, performance-8 based, then we would give them credit for that in the SALP 9 process. That's the purpose of the mid-SALP cycle meetings.
10 That was the purpose for the letter for licensees to have an 11 opportunity to describe what they were doing based upon what 12 they had found to encourage self-assessments by licens6es.-
'13 It was not to impose a requirement. Some have
( 14 chosen to do that, have described their programs to us. In 15 general, there seemed to be a consensus amongst the 16 utilities in Region 1 this was a good idea. And we did have 17 a good healthy feedback both ways during that workshop. It 18 was about two days here at the Sheraton with about 150 to 19 175 people.
20 MR. KELLY: The slide we showed yesterday on 21 inspection planning, for those sites that we know have major 22 initiatives going on like they're going to do their own SSFI 23 on high pressure injection system, and they' re going to do 24 it in June, we have it up there on the site Millstones. We 25 sviually have a new line on the plants for licensee Hreitale Reporting Corporation
/]-'
\ (202) 628-4888
362-p
't :
'N :
- 1. initiatives.
2 And it is'too prompt: one, to know what they're
_3 _doing to give proper credit, if that's the case in SALP 4- considerations.- And two, that we avoid conflicts. If we're 5 thinking about setting a major SSFI, if we know they're 6 doing their own or ones in a certain time frame we will 7 avoid that kind of planning. So it's as much the former as 8 it is the latter and we explicitly have it 1n) our inspection 9 plans now.
10 The next slide is some of the initiatives we have 11 undertaken in the region.- The first one, as you mentioned, 12 where the seed-to this idea for sharing self-assessments-13 were born. It was a workshop in March of ' 88.
(* .
( 14 That was followed up later on. You see all the 15 way down to the bottom of this slide,_with a Region 1 SALP 16 workshop held with licensees this past April. Two days, it 17 was over here at the Hilton'and there was a large number of 18 good ideas.and interactions that went on in that meeting, 19 which we have attempted to factor into our process.
20 Some of the other initiatives here I'll go over 21 briefly. We have distributed the authorship of the SMLP 22 document. By that I mean, we've taken a different tact in 23 this region and some others to assign primary authorship, 24 for instance, safety assessment to NRR. We feel that's the 25 best way to get the integrated approach to the document.
1:
( Heritage Reporting Corporation (202) 628-4888
[
= _ _ _ - _ _ _ _ - _ _ - _ _ _ _ _
i l:
p
~
.363 7-m -N "
1 It's not been without some difficulties,;but it will get 2 there.
3 DR. KERR:- Excuse me. When NRR is mentioned that 4 .means-NRR headquarters?
5 MR. KELLY: Projects, yes. 'The Division or the 6 old Division of License.
7' DR. KERR: Thank you.
8 MR. KELLY: Because if you look at those seven 9 categories right now the prime authors are primarily'in 10 regional. offices. DRS has prime authorship on engineering 11 and tech support. Main and surveillance is OPS, DRP, et 12 cetera.
'13 MR. KANE: Maybe in answer to time we can just
) 14 take questions, if you have questions on any of these 15 initiatives. That one that I discussed earlier meeting --
16 the counterpart meeting is next to the slide bullet on the 17 slide here.
18 MR. KELLY: Are there any questions on any of the 19 initiatives we have up?
20 (No response) 21 DR. REMICK: I see none or hear none.
22 MR. KANE: I guess at this point we were prepared' 23 to respond to the questions -- the additional questions that 24 you have here on 2 and 3, the impact of SALP on licensee 25 performance and the comment on potential for regulation by
-(] \
Heritage Reporting Corporation (202) 628-4888
L 364 (mj 1 3 alp, 2 Tim was going to talk about the impact of PUC 3 actions and Kurt was here to talk about the effectiveness of 4 plant safety. But we didn't have a planned presentation on 5 items 2 and 3, but I can respond to any -- try to respond to 6 the questions.
7 DR. REMICK: But you do on 4 and 5; is that what 8 you're saying?
9 MR. KANE: No , we're ready to respond to 10 questions.
11 DR. REMICK: Let's open up then on questions 2, 3, 12 4 and 5 if any members of the subcommittee have questions 13 they would like to pursue in those areas.
(m) 14 MR. CARROLL: You did have a presentation on 5 or 15 no?
16 MR. KANE: We do on 5.
17 DR. REMICK: Let's take up questions on 2, 3, and 18 4 and see if there are any.
19 DR. KERR: Well, I' d like a two or three minute 20 dissertation on the effect of SALP on plant performance.
21 DR. REMICK: Okay.
22 DR. KERR: If somebody is prepared to comment.
23 MR. KANE: Well, I guess I believe that the impact 24 has been positive. And the reason I say that is because it 25 gives you the opportunity to form, to discuss with senior
("'i Heritage Reporting Corporation
(_/ (202) 628-4888
, ')
1 licensee management -- our senior management just what it is 2 about the operation of the plant that we think is strong in 3 that part -- about the operation of the plant that we think 4 is weak.
5 It also gives us an opportunity to better 6 understand as senior management level some of the things 7 that the licensee is doing and why they think they're 8 important.
9 It is - probably opens up another area but is it 10 a major input to the senior management meeting to take place 11 -- agency senior management meetings that take place twice a 12 year and provide an overall assessment of licensee 13 performance. And, in fact, a product of -- one of the
(,) 14 products of those meetings is what we're going to discuss 15 next which is the watch list plants.
16 So I think it's effective in focusing the agency's 17 attention on the areas of plant operation that really 18 deserve our attention and on particular plants that deserve 19 more of our attention from an agency. standpoint.
20 So that's what I think the -- that's how I would 21 characterize the benefits for the SALP.
22 DR. KERR: So you would expect then that as a 23 -
result of the SALP process you would be able to deal with 24 problem plants or watch list plants much more effectively 25 and without it and that the watch list plants would move out
("j Heritage Reporting Corporation
\/ (202) 628-4888
~~ 366
l
\
1 oL' the watch list much faster than without SALP.
2 MR. KANE: Yes. And I think in looking at the 3 broad spectrum of plants I would expect the SALP -- I expect 4 that the SALP process should have improved overall 5 performance of all the plants, generally, by better 6 communication, at a high level of, again, the strengths and 7 weaknesses. And I think, in fact, a part has contributed to 8 a better performance of plants which I think has been 9 discussed with the ACRS I believe and the Commission by 10 headquarters organizations.
11 But 1 believe there has been an overall 12 improvement. You know, I can - you know, just going back 13 to t.be time when I first joined the region, which was in k_)s 14 1985, sitting down looking at the SALP reports and analyzing 15 trips and unplanned shutdowns, on some plants we used to go 16 to two pages of trying to examine individually what happened 17 to operators -- is it a design issue.
18 I can tell you that in the past four years it has 19 just been a significant reduction in the size of that input 20 to the report. In fact, a number of instances we're seeing 21 just one or two entries for SALP cycle. So I have not seen 22 anything that resembled --
23 DR. KERR: And you attribute most of that to the 24 SALP process?
25 MR. KANE: No, I do not attribute most of it to
'"1 Heritage Reporting Corporation
-) (202) 628-4888 i
i P
367
- fx; L .f o ,
'V 1
~
the SALP process. I attribute part of it to the SALP <
l 2 process; part of it to our emphasis. I think a majoi part 3 of the credit goes to.the other mechanisms, even the 4' industry initiatives, but'not even but particularly the, 5 industry initiatives.
6 But I think the SALP is part of it. It deserves l
7 part of.the credit, but I certainly wouldn't sit here_and 8 tells you that it deserves all the credit. I think it 9 deserves a major part of the credit.
10 MR. RUSSELL: My own personal review is that the 11 SALP report is one of the most effective tools we have for:
12 communicating with licensees on what are the priorities that 13 we see related to their performance. What areas you're
() 11 4 doing well and which ones are weak.
15 I know for a fact that utilities have paid close 16 attention to them. They respond positively to them. I 17 think there has been some concern over a use of SALP reports 18 by outside activities in manners that was not originally 19 intended, developing average scores and potential for abuse 20 by others.
21 But for the purposes of the agency it is a vehicle 22 to commute to senior managers. It's a very effective tool.
23 And one which I think is getting better with time as we use 24 it.
25 DR. REMICK: Are there questions on items 2, 3, or Heritage Reporting Corporation O (202) 628-4988
L L .-
~368 h grs.
D 1 47 2 MR. CARROLL: How about the impact of PUC actions
- 3 in this particular. region, has-that been a problem?
4 MR. MARTIN: ' Jay, I've had limited discussion with 5 utility-representatives since I took this position. Every
~
6 ~one of them reassures me that in no way will any PUC action impact the safety of the plant and they just will'not accept
'^
7 8 any impact.
9 I also have to tell you, though, that I'have an 10 underlying feeling that there are places where the PUC 11 'doesn't provide them necessary funds or threatens them with 12 prudency hearings or things like that. It may trim areas 13 that don't have an immediate impact on safety. But a long-(f 14 term impact. I'll give you some examples.
15 The amount of money that is available for 16 preventive maintenance programs. The amount of money that 17 is available for capital. improvements, they'can be delayed 18 in some cases, but some of them were being -- enhancements 19 that would be nice to have.
20 The amount of money available to fund additional 21 staff positions to address some long-term problems. We have 22 a mix of utilities in the northeast. Some are wholesalers 23 and therefore have some insulations from PUC with the FERC 24 being the regulatory. But then they have to come to the 25 support of their owner utilities in front of their PUC. So Heritage Peporting Corporation O'- -
(202) 628-4888
369 c,
-) 1 there is some insulation, but it's not perfect.
2 We have some PUCs that use prudency hearings. And 3 I can tell you that there's some apprehension about those 4 prudency hearings. We know of a couple of cases where 5 utilities entered into negotiations which ultimately
- 6. affected available funds to avoid those prudency hearings.
7 Again, those utilities will make it very clear to 8 us, we'll cut our non-nuclear opts before we will impact 9 upon the safety of the nuclear operations. But that 10 balancing type act is not a palpable place for utilities to 11 be in. Personally, I don't think they should have to do 12 that balancing act on safety.
13 MR. CARROLL: How does SALP impact the PUCs?
() 14 MR. RUSSELL: There was a proposal at one time by 15 a member of the New York Public Service Commission to use 16 the SALP scores as a part of an incentive program which 17 would affect such things as salaries to employees; bonuses 18 or lack thereof. That has not gone in place even though it 19 was discussed.
20 The more subtle effect I think of prudency 21 hearings is in information communications. When a utility 22 is having problems and they' re identifying their own 23 problems, they would like to characterize them in a manner 24 which does not appear imprudent to a reader who may have a 25 different agenda or view.
('] Heritage Reporting Corporation
(_/ (202) 628-4888
.. 370
.f)
I \/ 1 We've been strongly encouraging self-assessment L 2 activities identification of problems, development of 3 corrective actions,.and then allowing the NRC to monitor
-4 that.
L 5 We don't have many incentives that we can use to 6 encourage it. The SALP process is one; enforcement 7- discretion is another. But I think licensees are coming to 8 believe the importance of that and the fact that NRC~wants
- 9. to handle self-assessment activities in a professional way 10 and that.we are not out trying to penalize them for it.
11 Where those processes identify serious problems 12 and they get into prudency or disallowance activities, 13 there's a tendency to have a chilling effect on the
'( )
l .14 character and the communications. And all of our 15 communications are very public. That I think is a subtle 16 effect that needs to be considered as it relates to 17 identifying problems.
18 If you're not going to get the money to fix the 19 problem or if you're going to be penalized financially for 20 identifying problems, then that reduces the residual 21 resources you have available to do with them. That effect 22 is real, and that tension exists between the financial 23 regulator and their activities and the safety regulator and 24 its activities.
25 We're watching it closely. We're looking for Heritage Reporting Corporation O (202) 628-4888
'371
,(',_) l
- 1. examples or evidence where there has been a decline in 2 safety performance. We have not identified any specific 3 areas. But we have utilities that are openly discussing 4 that and they have discussed it in some Commission meetings.
15 MR. CARROLL: A corollary question: I guess I.
6 can't think of examples in Region 1, maybe you do have some, 7 but there seems to be, at least in the midwest, a trend 8 towards states wanting to get into the safety regulation 9 business and co-regulate; is that not a problem here?
10 MR. RUSSELL: I would say we have probably more 11 interest on the part of the states in NRC activities in the 12 northeast, notwithstanding what's going on in the midwest 13 with one state that actually would like to enter into an
( 14 agreement and have NRC regulatory authority passed to the 15 state.
16 There are other states which through the policy 17 statement and cooperation with states are active in other 18 areas of the country.
19 But we are to the point where I have actually 20 assigned division directors lead responsibilities for states 21 to try and keep current with what's going on. And we have 22 the equivalent of state resident inspectors at Maine that is 23 being considered. At Massachusetts there is a very high R24 level of interest. Also in New Hampshire at this point with 25 Governor Greg recommending that they get more involved.
Heritage Repo~ ting Corporation (202) 628-4888
(
i D' . -372
- f l.
131 1 Maryland is very interested in getting involved in following 2 Calvert Cliff issues and Peach Bottom issues.. Pennsylvania-3 .has the equivalent of on-call inspectors assigned lead for 4 each'of the plants in Pennsylvania and we do have an 5 agreement with Pennsylvania on inspection onsite as it h 6 relates to waste packaging.
7 In fact, I can't think of a state with the l '8 possible exception of Rhode Island that doesn't have a b 9 reactor that is not actively involved and frequently meet 10 with senior representatives of the states including 11 governors, based upon their interest in what's going on.
12 And they, of course, want to have their people providing 13 them information directly.
(f 14 So interaction with states is a very high tempo of 15 activity in the northeast and it takes time on the part of 16 myself, my deputy, and the division directors with each 17 division director having lead responsibility for some 18 states.
19 DR. REMICK: Further questions?
20 MR. KARD: Yes. I wanted to ask Bill to go back 21 to the agenda item 3, regulation by SALP. This says, 22 comment on potential for regulation by SALP.
23 Bill, as I heard you describe you feel as the 24 effectiveness of a SALP process for communicating to
.25 licensees, what it is you want them to do; it looks like Heritage Reporting Corporation
(~)'
\_ (202) 628-4888
I 373 7
1 that is a reality that there is regulation by SALP to a 2 certain extent, a l
3 Now, do you see that -- maybe that's appropriate 4 and maybe it's necessary today. Obviously in the agency 5 believe it is. Do you see this as a permanent approach to l
6 regulation or do you think that eventually it's going to be 7 possible to return or to -- well, I'll say return a more 8 traditional regulatory approach where the experience of 9 operation, overseeing operation, and the SALP process will 10 lead you to develop some more explicit regulations that you 11 want to apply to operation.
12 Somebody mentioned the attempt several years ago 13 of general operating criteria parallel with general design
() 14 criteria and that effort didn't yield anything, as I recall.
15 But that was several years ago. Today, do you think there 16 is any potential or need for this? Are you interested in 17 it?
18 MR. RUSSELL: I think there are two pieces to the 19 question. One is, do I believe that the SALP process as we 20 are using it today is, in fact, part of the regulation of 21 licensees? I think that it is. We are, in fact, 22 communicating with them as to why the CR areas are 23 important. We're assessing their performance. It's a part 24 of the process. I can't point to a particular regulation in 25 10 CFR that says, have a SALP process. But I think in
(")
V Heritage Reporting Corporation (202) 628-4888
- a n
E , -- 374
[.
l
d 1 reality-it'is quite' effective and it did grow out of the l ..
L 2' corrective actions from the Three Mile Island' event.
3 As it relates to the issue of whether I see some 4 ' regulations in the future which would be comparable:from the 5- standpoint: of l assessing effectiveness of operation as K
6 compared'to design and construction approval processes.-
7 I would submit that even if we had general 8 operating criteria today of the nature that we proposed back 9 in.1983 '84 time frame, that there would still be subjective 10 evaluation against those broader concepts'and that.you would-11 need to have a process like a.SALP to determine whether 112 'those objectives were being met.
13- I personally don't think that the very detailed
-( ) 14 prescriptive approach that we have used in the past has been 15 as effective because a lot of issues get lost. And I'think 16 the management controls and the process of SALP of 17 identifying overall'what are the strengths and weaknesses, 18 highlighting those to senior managers and letting managers 19 develop the appropriate corrective actions form; and then:
20 judging whether they work well or not based upon performance 21 is an appropriate regulatory approach for judging 22 operations.
- 3 2 So I don't think we're into a process where we 24 would-see something like a SALP disappearing, because I 25 think it's appropriate to assess periodically using all of 4
O As Heritage Reporting Corporation (202) 628-4888
{
j
, _x 375 1 the management resources we have put into it, licensee 2 performance and not go back to a mode where we have 3 individual inspection reports of individual areas.
4 One thing that I do see as a personal view, the 5 SALP is historical somewhat. It is not a snapshot in time 6 as to how is the utility progressing at that particular 7 point.
8 I can see that as we develop improved techniques 9 for team inspections that in an approach which would include 10 a team inspection at the end of a SALP to judge where.
11 they're going, to have it be a more comprehensive look like 12 we do for some of the integrated assessment team 13 inspections, that in conjunction with a review through a n
(_) 14 SALP process of what had been the individual pieces of the 15 inspection program prior to that time may be benef:!cial.
16 I personally believe that the value of team 17 inspections and interaction is going to continue to improve.
18 We're going to get better at it, hopefully, when we get more 19 efficient. But I think that process of looking at the whole 20 utility at one time and combining it with the SALP may be a 21 future trend for assessing performance. It's closer to what 22 INPO does with their looks. I think something like that 23 that's announced, that's known, where the cycle is known, 24 where the utility understands we're coming in and we can 25 accommodate schedules is one that I'm not apprehensive about
(~'; Heritage Reporting Corporation s- (202) 628-4888
376
.m
)
s> 1 a utility prepping for an inspection. I mean, you just 2 can't turn things around if we go in and do a comprehensive 3 look. So announcing it does not appear to be a problem to 4 me.
5 So I would see more of a trend toward' changes in 6 our techniques of inspection or assessment, whether we get a 7 maintenance rule, that was one of the general operating 8 criteria that we were proposing. Training, I think, is 9 being handled through an accreditation process quite well, 10 whether the industry would propose accreditation of 11 maintenance whether we need those tools, I think is 12 something that is going to be sorted out with time.
13 MR. WARD: Thank you.
7%
i ) 14 DR. REMICK: I suggest we go on. I've had a 15 request to have a brief presentation on the effectiveness of 16 plant safety review.
17 (Slides being shown.)
18 MR. COWGILL: I'm a project section chief in 19 Region 1. I've been with Region 1 for 10 years. My i
20 background is, I'm a graduate of the Naval Academy of 1967, !
1 21 Navy nuclear power, submarines for 11 and a half years. One 1
22 ship I was chief engineer. Subsequently came to the NRC.
23 I've been senior resident at two plants, and a project 24 section chief in the division of reactor projects since j i
25 1987.
Heritage Reporting Corporation
(~}
s_- (202) 628-4888 j
i
[<
x
[ 377 1 On.the effectiveness of safety review committees, 2 I chose'to discuss that in conjunction with the 3 effectiveness of safety review activities in general.
4 And as all of us know the responsibility for the 5 safety of the plant rests with line management and
'6
[ committees and organizations are tools by which they use to 7 help them in their mission.
8 And classically, the safety review committees 9 statutorily are the onsite safety review committee composed 1
10 of the plant staff.
11 Offsite safety review committees which include-12 corporate and in many cases today consultants from the 13 outside and quality assurance organizations that provide "Y
(4 14 audits for utilities.
15 DR. REMICK: What fraction is offsite safety 16 review committees in Region 1 would you say do have outside 17 membera?
- L 8 . MR. COWGILL: Of the utilities.that I deal with, 19 all three of them use outside consultants. Broader than 20 that I can't really tell you. But I think it's a growing 21 trend that most people are using outside consultants to help 22 them in various areas.
23 DR. REMICK: At one time PP&L and PEPCO apparently-24 exchanged members of those committees, does that still go 25 on, do you know?
I gw Heritage Reporting Corporation t) (202) 628-4888
. L "Le~
378.
.1 .
MR. CONGILL: I can't commen on PEPCO and PP&L,
~
'2 but I can tell you that GPU Nuclear still maintains'three-I 3 outside members of their board of directors and an.
i, 4 independent onsite committee that actually' reports to those L 5~ three board of directors to assist in their activities.
p
-6 A number of new' initiatives that have been
{ 7' developed.within the last 10 years with'the. advent of the.
~
8 NTOL' plants require by regulations were independent-safety;
.9 engineering groups which did independent reviews --~which do 10; ' independent reviews of technical specification changes,~ flat; 11 design changes. They look at'NRC. activities for trends and 12 so forth.
13 DR. REMICK: Do you happen to know if there are 14 -- other than NTOL -- that have established ICI: groups?
[
15- MR. CONGILL: Yes,.both Three Mile Island and-16- Oyster Creek.- Three Mile Island, in response:to.their 17 restart order; and Oyster Creek because they're a GPU' 18 Nuclear plant they're' treated the same way. So they both 19 have independent safety oversight group.
20 MR. KANE: And there are others that have done so.
- 21 Typically they have been -- those organizations
- hat --
22 , DR. REMICK: They have an NTOL --
23 MR. KANE: But there are others. We just met t
- 24 with, for example, Calvert Cliffs yesterday and they've 25 instituted ICI. And there are others, I just don't recall.
Heritage Reporting Corporation (202) 628-4888
-a__ .a_.-______:_-__-___-___i_ _ - - _ - _ - - - - - - - - - _
l 2 l LL, 379
% 1 DR. REMICK: So would~you say a majority of plants 2 in the region have ICI?
3 1R. KANE: I would say what we loor t, we have 4 that.
5 MR. WARD: Why do the other half resist that?
6 What are the negatives'they see?
7 MR. KANE: I'm not sure that I'm in a position.to 8 tell you exactly why. I think they all.have certain 9 ~ comparable activities going on, but as.to why they haven't 10 instituted those organizations, I'm not sure I can tell you 11 .in general what the answer.is.
12 MR. COWGILL: A number of other new initiatives, 13 one sponsored by INPO which we believe is going to have a
() 14 significant impact is the human performance evaluation 15, system that looks at -- takes detailed looks at operating 16 events to determine root cause and propose corrective 17 action.
18 Also, a number of utilities are beginning safety 19 system functional evaluations to assist them in their self-20 assessment capabilities.
21 The ways in which we review the safety committee 22 activities and evaluation activities is through our routine 23 resident inspector program. We generally confirm the 24 effectiveness of the committees. Also, on a bimonthly basis 25 we examine QA/QC surveillance activities with respect to Heritage Reporting Corporation O' -
(202) 628-4888
x.
380
- n. O,m 1 control room performance.
w 2 Also, in our mid-cycle SALP reviews'we heavily 3 review the self-assessment and the safety assessment 4' capabilities of the plant.
~
5 Also, we observe onsite and offsitevsafety review.
6 ' committee activities and look at the corrective actions-they 7 impose.
8 The bottom line really is that, in our experience 9 those utilities with effective self-assessment and
'10 corrective action program in general achieve much better 11 performance than other utilities.
12 DR. REMICK: Questions?
13 DR. KERR: Well, it's an interesting presentation 14 but it does not seem to me respond to the agenda item to the
'([
15 effectiveness of safety review committees, I thought.
16 DR. REMICK: I thought the bottom line was, but 17 perhaps not. Do you have specific questions?
18 DR. KERR: Well, it just says, if one has 19 effective self-assessment and corrective action programs 20 achieved by the performance.
l 21 MR. CARROLL: And safety review committees are 22 part of that.
l E23 MR. COWGILL: Yes, sir, that's the implication.
l-24 DR. KERR: So the safety review committees at l
25 least don't do any harm.
Heritage Reporting Corporation
.O (202) 628-4888 Y_ _:_.
h'y 381
- n w 1 MR. COWGILL: No, I believe the safety review 2 committees are an important aspect, but in today's 3 environment with the number.of procedures and evaluations 4 that the utility has, by statutory .' ,its the safety review 5 committees are made up of the plant ma. ger and senior 6 department heads. And if they were the only activity they 7 would be continuously tied up in review committee meetings 8 and not performing their necessary line management 9 oversights.
10 A number of these other self-assessment and 11 initiatives assist them in the function of review of their 12 activities.
13 MR. KANE: Let me try, maybe we haven't been as
() 14 responsive as we should be. I guess the way that we like to 15 look at it is that they are an element of the overall, what 16 we call, assurance quality process which starts with, 17 obviously, with the line management and their ongoing daily 18 assessment of activities.
19 MR. CARROLL: It starts with the doer.
20 MR. KANE: I'm sorry, you're absolutely right.
21 I'm talking about the line -- I should have said, not line 22 management, but the line organization. These tend to be 23 independent -- the independent processes which are one we i
24 focus on in the safety assessment, quality verification area !
25 to try to understand how they're doing.
, i l
/~1 Heritage Reporting Corporation
(/ (202) 628-4888 u _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - - - - - _ _ _ _
. = _ - _
i: ' .s
- l. ,
o L4 382 I ' 7~'T
(_J < 1 In many instances which will' point to.the onsite
'2 committee and give them an assessment of whether we feel 3 they're overloaded, whether they're doing a good job, 4 whether they're taking on too much, whether there needs to l
5 be subcommittees of that unit to look into material before L 6 they get it. And it's one element of the process that we-7 look at.
8 DR. CATTON: What about whether or not they're 9 being listened to or should be listened to?
11 0 DR. KERR: If they were eliminated, and.there are 11 generally two of these apparently, in-plant and out plant, 12 if they were eliminated do you think safety would suffer 13 significantly?
() 14 MR. COWGILL: I can give you an example. GPU 15 Nuclear several years ago submitted a technical 16 specification change and did eliminate specifically the 17 onsite/ ffsite safety review committees statutorily and they 18 put in place an independent review system and peer review 19 system to take their place where they were not committee 20 activities but they were independent. And the re.Aews of 21 their procedures and their activities, and we haven't seen 22 safety suffer from that. GPU Nuclear as well, they have 23 what they call the General Office Review Board which meets 24 on about a quarterly basis, which is an oversight committee 25 which has heavily -- which heavily uses outside consultants r Heritage Reporting Corporation (202) 628-4888
c 383
~
l 7
'- 1 to provide an oversight of site activities.
f 2 But there is one case I specifically know of that 3 the onsite and offsite safety review committees have been 4 eliminated.
5 MR. CARROLL: You know, historically the whole 6 notion of this safety review committee started with the idea 7 of test reactors where you were doing experiments. And you 8 get a broad group of guys together and figure out whether 9 this experiment was going to be bad or not. And it sort of 10 got into the power reactor business that way and the 11 original tech specs in the early ' 60s.
12 A lot of these committees turn into jokes. It's 13 not where the real work is done, they're just sort of rubber-() 14 stamping things because the committee is in the tech specs.
15 I would very much encourage the kind of thing GPU 16 did. I think they're very good alternatives that accomplish 17 the same purpose in a much better way.
18 MR. RUSSELL: We've seen SALP assessment processes 19 that have involved task forces, consultants, others coming 20 in. The ones that have worked well have been the ones that 21 have been used by the line organization with effective 22 review by the plant operations review committees or the 23 offsite committees.
24 We've seen cases where those committees have 25 gotten bogged down because, quote, "all procedure changes go Heritage Reporting Corporation
(">}
t (202) 628-4888
384 i )
f 1 through," and they just end up spending all day long in l 2 meetings. And they don't prioritize their activities. They 3 don't overview operations.
4 It's design should be to handle issues at the 5 interface and let the line organization work and then 6 provide some oversight.
7 So it's very much a function of the utility as to 8 how effective it is; how well it performs; and whether it's 9 performing valuable use. So I would not characterize that 10 in the main they are ineffective.
11 -I believe that in the main that they are effective 12 in causing communications, coordination of activities, and 13 have, in fact, assisted utilities.
/~T
(_) 14 MR. CARROLL: Yes, but I guess my point is that a 15 plant staff review committee is really the management of the 16 plant. And when they put their hat on and say, we're plant 17 staff review committee and we're going to do this list of 18 things required by the tech specs in this formal meetings so 19 the NRC can see the minutes, it's kind of a joke in the 20 sense that they could just as well be doing it and carrying 21 out their normal management functions with their hat on as 22 plant manager, maintenance, whatever.
23 I think without growing the committees; I think 24 we' re more sophisticated than that nowadays. Particularly 25 if you're going to inspect them on a performance basis.
(')
t/
Heritage Reporting Corporation (202) 628-4888
P 385 1- DR. REMICK: Is there some benefit, Jay, though of 2 those people getting togother even though they're doing --
.3 MR. CARROLL: Well, they do every day, they have a 4 staff' meeting every' morning.
5 MR . RUSSELL: He is suggesting that normal good 6 management practice would result in these things occurring
.7: anyway, and why do we.need to institutionalize the 8 requirement for a committee. If we had all good management' 9 at all utilities that would probably be the case and we 10 wouldn't need to have that.
11 DR. CATTON: Wouldn't need NRC.
12 MR. CARROLL: Yes.
13 DR. KERR: But the comment that some organizations r
4 14 use committees effectively I think is very appropriate. Lnd 15 universities always refuse to solve problems by appointing 16 committees, so I'm familiar with committee activities.
17 And there are people who have used -- there are 18 managers who can use committees very effectively if they are 19 good managers they will, and if they' re poor managers, no 20 matter how good the committee is, they won't use them well.
l l 21 I don't know what the answer is. My guess is that 22 Jay may be close to the truth in a good many situations, but 23 he has had a lot more experience than I've had in reactors.
24 I've had a lot more experience in university committees, so 25 my experience may not be very valid as far as reactor
('\ Heritage Reporting Corporation Al (202) 628-4888
l 386
(-) 1 operations is concerned.
2 DR. CATTON: Well, I don't know about that.
'3 Having attended a utility meeting last week I think they're 4 the same, if not a little worse.
5 DR. REMICK: Anything further on this item?
6 (No response) 7 DR. REMICK: If not, I suggest.we take our mid-8 morning break returning quarter to 11:00.
9 (Whereupon, a break was taken.)
10 DR. REMICK: Moving right along on yesterday's 11 agenda our next item '.s watch list plants, Bill Kane again.
12 (Slides being shown.)
13 MR. KANE: What I would like to do is give you an
() 14 overview of the steps in the restart process. Most of the 15 plants that we're talking about here today have been
- 16. shutdown, and what I sense that you're interested in is 17 what's the process? How do we organize to respond to the 18 plant?
19 I want to just go through this. You're familiar 20 with some of this, I'm sure, from Pilgrim and Peach Bottom 21 which have been through the ACRS, but subsequent to my 22 general presentation we will discuss the four plants 23 specifically that are on the watch list in this region and 24 what we are doing with respect to those four plants. That 25 is: Pilgrim; Peach Bottom; Hine Mile Point; and Calvert i
f Heritage Reporting Corporation
\ (202) 628-4888
p.
&^,
i
(
~J 387 p.
\~ 1- Cliffs,~in.that order.
2 DR. KERR: I guess I was'almost equally,'if not-3 more,' interested in how they get on the watch list. Are you
[ ~4 going to talk about that st. all?
'S MR. KANE: .That's not something that we can speak l 6 completely to here with the presentations we've got. I 7 think I touched on it earlier as to the senior management-L 8 process and the SALP being an input to that process and the 9 ~ decision'is developed in the senior. management reviews which' 10 are conducted each year.
.11 DR. KERR: I didn't realize.
12 MR. RUSSELL: I can address that from being an 13 attendee at the senior management meetings, and I'll'take
'14 that up following this presentation and describe the process 15 that we go through and how we do it.
16 MR. WARD: Because I think the question some of us 17 had is that there seemed not to be a correlation between the 18 watch list plants and SALPs.
19 MR. RUSSELL: To some extent that can be because 20 the SALP scores are looking back at history, and where you 21 see a trend in performance, a decline, the senior managers 22 and the' staff are becoming more proactive in describing that 23 and attempting to get it turned around before it degrades.to 24 the point where you have a significant number of category 3 25 ratings and/or unacceptable conditions at the plant.
Heritage Reporting Corporation
('-] (202) 628-4888
,_x 388
/ 1 The one facility that probably had the most l..
2 discussion is the Calvert Cliffs facility, maybe we can take 3 that up as an example of what the process was and how we 4 decided that, following the discussion on Calvert Cliffs.
5 MR. KANE: Given that the plant is on the list and 6 I'll vary it from there and go through the steps that are 7 involved in this process.
I 8 Typically, a confirmatory action letter is issued 9 to really define the expected licensee actions, and 10 ' basically that's a document that is developed in conjunction 11 with the licensee as to what needs to be done prior to 12 restart.
13 DR. KERR: Now, this assumes that no plant is on
-s
(_) 14 the watch list unless it's shutdown, because you're talking 15 about restart here?
16 MR. KANE: The plants that we are currently 17 talking about that we will be talking to you about today are 18 currently shut down. No, they were shut down at one point 19 in time and this is Pilgrim and Peach Bottom were shut down, 20 and this is the process that was used.
21 DR. KERR: But plants are not put on the watch 22 list unless there is also a shutdown or going to be 23 shutdown?
24 MP. . KANE: No. We have essentially two categories 25 that we use for plants on the list. Category 1 that we use Heritage Reporting Corporation C'" s (202) 628-4888
l l 389-1 or refer to is one that performance is improved to the point-2 where you can remove the plant from the NRC's watch list.
3 Category 2 is essentially a plant which may or may l
4 not be operating for which senior managers deem the 5 significant improvement performance is needed,'and as a 6 result that the plant bears close monitoring on an agency-7 wide basis during the next period between senior managament 8 meetings.
9 For a plant which is category 3, that is a plant 10 which is shutdown for which the staff woulf bring'a 11 recommendation to the Commission regarding restart and the 12 Commission would become involved and would, in fact, vote on 13 whether that plant should be permitted to restart.
() 14 Category 3 plants are plants like Pilgrim, Peach 15 Bottom, the TVA plants.
16 Category 2 plants are plants like Nine Mile Point 17 1 and 2, which Nine Mile 2 was operating at the time when it 18 was placed on the watch list. Nine Mile 1 was shut down 19 from a previous feedwater transient in December of ' 87; it 20 was put on the list in the summer of ' 88.
21 Calvert Cliffs was operating in December when it 22 was placed on the watch list. And continued to operate. It 23 has subsequently shut down for a number of reasons and we 24' have subsequent, too, is being placed on the list negotiated 25 a CAL with Calvert Cliffs regarding what actions are going Heritage Reporting Corporation O (202) 628-4888
t 390 x
/ 1 to be taken prior to restart of either unit.
3 MR. RUSSELL: Confirmation of action letter. With 4 the exception of Peach Bottem these agreements have been 5 handled with confirmation of action letter, essentially an 6 agreement between utility and the staff that they would take 7 certain actions which were reduced to writing in a letter 8 that they had agreed to. Had they not so agreed we would 9 have had the option of going to an order or some other 10 vehicle to obtain the necessary actions the staff felt were 11 appropriate.
12 In the Peach Bottom case we did issue an order.
13 So it's not a straightforward answer to say, operating or
( ) 14 not operating. At this point in time Pilgrim and Peach 15 Bottom have been moved from category 3 requiring the 16 Commission vote and approval for restart to category 2 and 17 they are being -- continue to be monitored closely by the 18 staff and they are operating.
19 Nine Mile 1 and 2 are both category 2 plants with 20 unit-1 shut down under a confirmation of action letter as to 21 what actions they're going to take prior to restart. With 22 unit-2 operating.
23 Calvert Cliffs 1 and 2 are both shut down under a 24 CAL, and also are category 3. They may be permitted to 25 restart based upon staff determination. It does not require e- Heritage Reporting Corporation
()g (202) 628-4888
391
- p M .1 a Commission vote for a category 2 plant.
G 2 DR. KERR: So this simply. refers to those that are 3 shut down?
4 HR. RUSSELL: That's correct.
5 DR. KERR: Okay.
6 HR. KANE: Which applies to really a set of all of 7 these facilities really. It applies to all the 8 presentations that you're about to hear. And with the-9 exception, as Bill pointed out, there was one plant that was 10 shut down by an order.
11 But the process is, since it involves the
.12 significant action on the part -- interaction on the part of 13 NRR in the region that we typically. constitute a restart
. "( ) 14 panel or a panel to oversee the activities associated with 15 the plant. And that may be chaired by -- within the region 16 or it may be chaired by NRR. We've got cases of both. But
~17 it does involve managers from both organizations to make 18 sure that, one, that the resources can be -- decisions can 19 be made quickly and resources applied and actions can be 20 taken in an integrated fashion.
21 A major part of what we look at is the licensee's 22 . action plan to respond to the CAL. The panel is charged 23 with review and approval of the restart action plan. And 24- that's not necessarily all done by the panel, but it's their 25 responsibility and I'm sure that that does get done. The Heritage Reporting Corporation x (202) 628-4888 l-t-
% 3
.g 392 y[
A- 1: overall approval process would be through correspondence 1
2 with the licensee, typically would be signed out by the
>r- .3 regional administrator.
4 The review of -- another major element of the 5 process is the licensee's assessment of its readiness. In E 6 other words, what we look to is the licensee to conduct its 7 own.self-assessment of where it stands and then provide that 8 to us, and basically saying, they have assessed their 9 readiness to restart, here is the product of that 10 assessment, and they provide that-to us before we get
' ll 'i nvolved in inspection activities.
12 We've got paper-first. Basically, a paper plan.
13 Then the implementation of that plan. The assessment by the
.() 14 licensee of the implementation of that plan and its 15 effectiveness. And then finally, our inspection which is 16 the integrated assessment team inspection which again is a 17 look at the entire operation, rather intense look which 18 we'll discuss how we have done that by a relatively large 19 team over a several week period to get an independent
- 20 confirmation on our part that they are ready.
21 Then the panel would recommend to - provided it 22 was satisfied with the results of that inspection, would 23 make recommendations to senior management that the CAL would 24 be lifted and then there would be an extensive NRC g 25 monitoring program of the startup, power ascension program Heritage Reporting Corporation <
(202) 628-4888
1 y.
393
( JL' -following that to assure that, in fact, we were confident 2 that that plan was being implemented.
3 There are two other aspects to this which aren't" 4 shown on this slide and are variables. One is the ACRS 5 involvement. ACRS has been involved in two of these y '6 facilities, that we're going to talk about, and that has 7 been typically a subcommittee meeting and a full committee
~
.8 meeting'with the committee reviewing the results, typically, 9 of our integrated assessment team inspection along'with the
~ 10 licensee's approach.
11 There are also public meetings at which -- there 12 were thres at the -- the first three were then to discuss or 13 to receive public comment on the licensee's plant for
() 14 recovery. And that process would involve, depending upon 15 the facility, one or more public meetings to receive their 16 comments; and then we take those comments into consideration 17 in terms of our overall review and approval of the plant.
18 So that's the general approach. And then I'll 19 have Randy Blough first talk about Pilgrim and followed by.
20 Jim Lindale on Peach Bottom, Jim Wiggins on Nine Mile Point, 21 and Lou Tripp on Calvert Cliffs.
22 DR. KERR: Can you tell me why it is that 12 3 somebodyc I don't know whether it's the headquarters or 24 rogions, adopts these hold points, 25, 50, and 75 percent of 25 power for rather long periods?
. Heritage Reporting Corporation
- (202) 628-4888
394 r i 1 MR. KANE: Well, the basic reason for that is to 2 . provide a point in time at which the licensee and the NRC, 3 recognizing that this program is - power ascension program 4 is extensively covered by our inspectors as well as their 5 own assessment team, the licensee's assessment team, gives 6 us an opportunity to stop, compare notes, understand whether 7 there is a comment understanding of weaknesses, again, 8 strengths, things that should be -- if there are any changes 9 that need to be made.
10 DR. KERR: No, I guess I didn't make my question 11 very specific. I recognize that you need to do that sort of
'12 thing, but why can't you do that by going directly to 100 13 percent power rather than going to 25, 50, 757
(_) 14 MR. KANE: Well, in most of the hold points are 15 established -- some of these f acilities have been down for a 16 long period of time. The idea was to establish various 17 power levels at which they could achieve stable operation 18 for a period of time, so the operators would get back to and 19 used to normal operation. And the concept was to, cfter 20 that period of time get together and make sure there was a 21 common understanding of performance during that period.
22 DR. KERR: But since the plant --
23 MR. WARD: This seems to be based on an assumption 24 that the plant is inherently safer at 25 percent power than 25 it is at 100 percent power; do you believe that?
(~'N Heritage Reporting Corporation Al (202) 628-4888 l
l l-L_ _
395 7y vV 1 MR'. KANE: The power levels that have been 2 d selecteor done so with an understanding that it is safe to
~
3 ' operate at those levels, although --
4 HR. WARD: Is it safer?
15 MR. KANE: There have been some adjustments to 6 those programs over time. I think in the case of Pilgrim 7 they were -- they had selected on their own, I believe, thes 8 25 percent, although they didn't have the full complement of 9 the feedwater heaters I guess at that point, and then there 10 was some consideration, I guess, in Peach Bottom to 11 establish a higher power level.
12 We look at the selection of those levels first for
~13 the' licensee to take a look at it to where they want to-stop
() 14 and conduc't their assessment. And the selection of those 15 power levels is done so in conjunction with the licensees.
16 DR. KERR: But since the plants are designed to 17 operate at 100 percent power and they generally operate 18 better on 100 percent power than they do at lower powers, it 19 is nocuous to me why presumably it is safer to go through
- 20 this ascension program the way it normally is, then it is to
'21 go directly to 100 percent full power.
22 MR. RUSSELL: If I could comment. I guess I 23 disagree with your premise that the plant is safer at 100 24 percent power than it is at a lower power level.
25 DR. KERR: I said, I think it's safe at 100 r Heritage Reporting Corporation
( (202) 628-4888
396
,3
- (_) 1 percent than it is at 25,'50 or 75.
L 2 NR. RUSSELL: That will be a debate that we can 3 'have, but I --
4 DR. KERR: It's designed to operate at 100 percent 5 power, Bill.
6 MR. RUSSELL: It's designed to operate at 100 7 percent power and the margins in that design at 100 percent 8 power are smaller in some cases than the margins at lower 9 power level, based on upon components and operation, decay
< 10 heat.
11 DR. KERR: But the stability, the pump 12 performance, the valve performance all can be affected at 13 lower flow rates and lower powers; we've seen examples of Oi v
14 that.
15 MR. RUSSELL: There have been some examples of 16 that. But we have, for example, plants that are operating 17 right now that have only one transformer available and 18 they' re operating quite stably at 60 some percent power at 19 Oyster Creek. There are component failures, feedwater 20 pumps, we've had problems with them operating in parallel, a 21 single feedwater pump with a single control system is just 22 as stable at 50 percent power as two pumps operating at 23 parallel at 100.
24 DR. KERR: I still say these plants are designed 25 to operate at 100 percent power. That's their principal
,rq Heritage Reporting Corporation ts ,/ (202) 628-4888
- . . _ ______________J
l' 397 p .("V .
p - (/
. ;l design criteria. And I do not believe that anybody has 4
2' looked carefully to demonstrate that it's generally.true Iu 3 that they're safer.at 75;or 50 or 25 percent than they are 4 at 100. I have seen no such analysis and I have asked for 5- this'for some time.
t 6 MR. RUSSELL: Well, I would point you to the 7 analysis then that was done for operation at 25 percent 8 power at Seabrook -- not Seabrook, Shoreham which was one of' 9 the considerations we used in establishing 25 percent power.
10 DR. KERR: And it showed it was safer at 25 than 11 at 1007 12 MR. RUSSELL: Yes, as it related to offsite dose 13 consequences, source term, and other effects. The equipment 14
.(f operability issues, the design of the plant.
15 You're addressing the issue as to what are the 16 margins during routine operation with lower flow rates 17 stratification in lines, things like that; those factors, to 18 the best of my knowledge, have not been considered at 19 length, but it is not uncommon to have lengthy periods of 12 0 time during startup test programs for operation at lower 21 powers or as a result of equipment fcilures of other 22 components.
23 And I don't believe that the operating experience, 24 at this point, shows that there is a deleterious or a 25 detrimental effect. And I believe the resulting reduction Heritage Reporting Corporation (202) 628-4888
b f]t 398
. 11'- -in-' source term and decay heat is significant and it'provides-s J2 much more time for operators to' respond if you have three l?
b :3. l percent decay heat as compared to seven percent decay heat.
L h '4- So that the time-frame'for operator response <
,, 5 repair intervention is much greater.
6L DR. KERR: -I would like.to see a good analysis of:
~
7 all?the features that go-into this, and I don't believe one l 8 has been done. Well, you guys are convinced, I guess, thatL 9 it's safer to go through these steps. I sure would like:to.
10 see some detailed. analysis.
'll - If a licensee came to you with a proposal'to'do 12 this, it had no more docuc'ntation than this has, I don't 13 think you would accept.it.
() 14' MR. RUSSELL: The plant is. licensed to operate up 15 to 100 percent power and it can operate. They take water 16 boxes out, work on condensers, do other things at' lower 17 ' power levels.
18 DR. KERR: That is very true. But they don't do 19 this for very long periods and they don't do it unless.they 20 are forced to. In the main one operates these things at'100 21 percent. I know their load following situations. One gets 22 in trouble sometimes from operating these plants on load 23 following sicoations.
24 MR. RUSSELL: My understanding is the difficulty 25 involving a load following is xenon and core Heritage Reporting Corporation
( (202) 628-4888
. ;_g 399 1/ L
\-2 1 characteristics, the ability'of the reactor' respond.
2, DR. KERR: You have unusual transient. situations, 3 that's right.
4 MR. RUSSELL: We have thermal. plants that have a 5 balance of plant equipment that are very similar to nuclear 6 power. plants that operate in low flow,-operate at 7 intermediate powers with essentially similar designs.
~8 I just don't know.that the operating experience 9 would support a conclusion that it's less safe to operate
- 10. for sustained periods of time at 50 percent power.
11 DR. KERR: I didn't say that it would. I just 12 said, I don't think a detailed analysis has been done and 13 I'm surprised that one hasn't been. Since this seems to
( j) 14 influence what the NRC is requiring, that it is safer to go.
.15 to 25 percent, then 50, then 75 percent. I have seen no 16 detailed justification for this.
17 MR. RUSSELL: The factors that were most 18 significant to me in the discussions with the utilities 19 regarding this were the decay heat being much less, 20 providing much more time for operator response and action.
21 And, in fact, having a --
22 DR. KERR: I repeat, if that is the only kind of 23 analysis that a utility came to you with when they wanted to 24 do something, I don't believe you would accept it. I think 25 you would ask them to go back and do_more work on the other
( Heritage Reporting Corporation (202) 628-4888
I i
~
400-
- d. ~1 considerations it might enter.
2 MR. CARROLL: I don't share Bill's view on this, 3 at least totally, but I do have a problem with'an arbitrary.
4 25 percent.
5 lMR. RUSSELL: If I had it to_do over again I would-6 not pick 25, because the feedwater trains and the water 7 level control systems are not fully operational at that' 8 point. .At about 30 or 35 percent the entire balance of the 9 plant'is in normal automatic mode of operation without being 10 bypassed. And that's why we indeed chose a higher power 11 level:of'35 percent on Peach Bottom based upon the 12 experience at Pilgrim of not being able to put the complete 13 feedwater heater system in service.
() 14 And, in fact, some feedwater heaters were in a 15 vacuum based upon thei r being aligned to the turbines and 16 not all stages of the turbine being loaded.
17 (Slides being shown.)
18 MR. WIGGINS: Good morning, my name is Jim 19 Wiggins, I'm the Project Branch Chief, I work for Bill Kane. -
20 I_have under my responsibility both Nine Mile and Calvert 21 Cliffs, which you will hear today among other facilities.
22 I'm here to give you a brief rundown on Nine Mile 23 recognizing that NRR staff is currently in negotiation with 24 your staff for a more thorough briefing in the sub and full 25 committee meeting in the future, next month or two.
/
Heritage Reporting Corporation e
(202) 628-4888
1 Ll 401
! 'i' bl .
1 The first slide basically goes over the chronology 2 of events that led up to Nine Mile 1, remaining down and 3 having a confirmatory action letter issues.
4 It essentially starts in December 1987 when the 5 feedwater vibration problem with the utility involved 6 elected to hold the plant down.
7 While the plant was down being repaired, the staff 8 looked at an ongoing SALP history of performance problems.
9 A couple items of specific nature came up. Both had to do 10 with operator licensing. Both had to do with 11 requalification type training.
12 The first one had to do with the program needed to 13 maintain the license through requal. The ability of the
() 14 licensee to certify that individuals had been, in fact, 15 enrolled -- there were some instances where people may not 16 have gotten all the training they should have gotten through 17 the utility's established program for the maintenance and 18 the license.
19 The second issue dealt with the ability of 20 operators to deal with emergency operating procedures and 1
21 real-time scenario which we picked up on a simulator 22 inspection.
23 The first problem we issued a confirmatory action l 24 letter 88-13. The plant was then placed -- was place on the i 25 category 2 list.
l l
Heritage Reporting Corporation C -
(202) 628-4888
p4 .
a . 402 L
1 The second problem.was dealt with an additional
- 2' CAL, 88-17 and,iin fact, superseded the first one and added
'3 some of the performance related items in.it in addition to 4 the specifics that we identified so far as.the operator 5 licencing - operator requalification.
- 6 DR. REMICK: Does Nine Mile still heavily use 7 contractor training? For many years.they had a contractor 8 perform a lot of their training.
9 MR. WIGGINS: The answer is, yes.- '
10 The confirmatory action letter 88-17 looks more 11 along the lines of the one you saw for Pilgrim in our 12 earlier briefings in the ACRS in Pilgrim ma'ter.
t It had in 13 it the things that the licensee should be doing and had
() '14 volunteered to do, had agreed to do in order.to address more 15 of the root causes for the problems we had seen.
16 Specifically we did ask for a root'cause analysis 17 of the problems. We asked for a submission of restart 18 action plan, which should be a blueprint for how those 19 problems would be. addressed. And we asked for a submission 20 of readiness for restart report. A later slide will tell 21 you exactly where we are in process.
22 A restart assessment panel was formed in September 23 of ' 88 for Nine Mile. It was formed in a manner similar --
24 currently operates similar to the matter that the panels for 25 Pilgrim and Peach Bottom operate. These particular panels, Heritage Reporting Corporation l
(()~T (202) 628-4888
c= . .
i /
, 403-1- the restart assessment panels is an. agency or staff-wide L
- 2. effort to try,to organize and coordinate the efforts'that 3 we' re. performing as a staff, not only inspection activities L
4 in the region, but also has an NRR membership in it, either 5 the project director or the AD level.and projects. That's 6 so we can coordinate our activities across regional lines.
7 Nine Mile Point did submit a. restart action plan 8 in the end of December. We've gotten subsequent revisions 9 of that' based on staff comments. The latest revision was 10 issued July 11, 1989, 11 The staff has taken a position based on a review 12 that the restart plan was found to be implementable-and 13 suitable for use while we completed our approval process.
14 The' licensee has been implementing -- completing the 1(])
15 implementation of the plan while we're completing our 16 approval process.
17 One element in the approval process that just 18 recently occurred, last week we did hold a public meeting in 19 Oswego, New York and that meeting was to expressly to accept 20 public comments on the restart action plan. And we did 21 complete that, and there are transcripts here. We got them 22 yesterday and my staff will get to review the transcripts 23 and understand what the comments were. Similar meetings 24 were held in Pilgrim and Peach Bottom.
25 DR. KERR: Do you anticipate a change in the Heritage Reporting Corporation (202) 628-4888
h<
b j 404 .]'
H
[f'}-
k' 1 restart plan as a result of public comment?
~
h 2 HR. WIGGINS:- That's too early for me to really.
l' .3 answer that. I have to see what the comments-are. There-is 4 at'least one issue that has made a lot.of media interest 5 recently and that has to do with a problem that we now 6 believe occurred in 1981 where a reasonable amount of water h
7_ accumulated in a sub-basement in the rad waste building. -We 8 sent an augmented inspection team up there and they started 9 work on the 23rd of August, last week, they visited their 10 site work and they are now compiling their report. One of 11 'the things that we will have to do as a line function facing 12 the review of tha . report is to examine what that team found.
13 One of the things they were supposed to be looking at was
() 14 the licensee's' corrective action. And one of the' decisions 15 we will have to make is, should any of-that be considered as 16 we lookiat the restart action plan for inclusion in it. We 17 haven't reached that determination yet. But it would be 18 something that we will have to consider.
19 When we get to discuss the restart action plan 20 later on at the ACRS meetings I think you will find that the 21- way the licensee set this up, and we somewhat agreed to it, 22 is that the restart plan dealt with underlying root causes 23 and it dealt with a given fixed list of specific issues that 24 existed as of the time they submitted the plan initially.
25 Any ongoing issues are handled in our normal Heritage Reporting Corporation (202) 628-4888
= _ _ _ _ _ -
405
(_) 1 practices. So this may either be one of these ongoing 2 issues that we handle normally that we will get to the 3 bottom of and understand what the licensee's plans are or we 4 may have to decide that something has to be done to the 5 restart plan or the more broader plan that the licensee has 6 for longer term improvements which is a nuclear improvement 7 plan. So that's one of the things we have to do. I would 8 anticipate we would have that answer before we meet with the 9 subcommittee.
10 DR. REMICK: How do you handle the natural 11 tendency, I think, of regulators at this point when your 12 plant is down and you're negotiating an confirmatory action 13 letter not to sweep in all the things that people think,
() 14 well, we got them now, we should include it, kind of TMI 15 action plan, how do you handle that? It's a natural 16 tendency.
17 MR. WIGGINS: In the formulation of confirmatory 18 action letters?
19 DR. REMICK: Yes.
20 MR. WIGGINS: The confirmatory -- well, let me 21 more generally discuss it. The confirmatory action letters 22 that were issued for Nine Mile, for Pilgrim and for Peach 23 Bottom were high profile confirmatory action letters, a lot 24 of people know about them. But they, by no means, are the 25 only ones that are going to issue. The region has been Heritage Reporting Corporation
'q f-)S (202) 628-4888 j
{
)
1
W l'
E . 406
- (' .
1 ~ issuing confirmatory action letters for a long time, as long-2 as I've been here.
I' 3 They typically more times than none are highly.
- 4. specific. And our tendency in-a confirmatory action letter 5 is to leave specifically what we're after in the 6 confirmatory. action letter and not open it up to a wholcsale 7 inclusion of every problem we think exists.
8 I think the other way I would answer that is, I 9 think we have learned something after Three Mile, the 10 formulation of the action plan. We learned that these type 11 of events are not always the best to throw the laundry list 12 of things in. I think we're pretty careful about what we 13 put in.
- f 14 A utility would have to have a reasonable history 15 report of performance before we include in the CAL a thing 16 as broad as you see for Pilgrim and Peach Bottom and Nine 17 Mile. I think we're cognizance of it at my level and I know 18 Bill Russell is cognizance and Bill Kane are, and they're 19 the individuals with some account. So I think we're just 20 sensitive to that.
21 MR. RUSSELL: I would like to also comment that in 22 the Nine Mile case there are two plans. One is the plan 23 that addresses the issues necessary for restart and the 24 other is a plan that addresses one term improvement.
25 Calvert Cliffs is similar, they have a short-term 3 Heritage Reporting Corporation
/ (202) 628-4888
55 -
L
[
407-n
%- l'- response under the CAL and then a longer term improvement
.2 ' program.
L 3- So we do bend things into whether it's needed for 4 -restart or not or whether it's'something that can be a part 5 of a longer term program. And that's a conscious decision
/
~
'6' on our part to make sure that the list'doesn't grow with 1'
7 time without-conscious decisions being made that this is-8 .indeed an issue for restart. And we look to the licensee to 9 make that judgment first and then we respond to it, so that 10 we don't -- we try not to lead them as to what issues need 11 to be addressed.
12 MR. CARROLL: I don't want to focus on Nine Mile-13 Point, I would rather speak more generally. When do you (f 14 make the judgment it's bad enough to keep a plant shut down?
- 15. Why can't -- couldn't these problems or similar. problems be 16 dealt with on a long-term basis in the second part --
17 MR. RUSSELL: Well, that relates directly to the 18 summer of 1988 time frame on Nine Mile-1 at which time we 19 had evidence that the operators could not effectively 20 implement emergency operating procedures. We had 21 substantial issues with respect to in-service inspection, 22 fire protection, other technical issues. And the sum of 23 those items were such that we concluded the plant should not 24 operate until they had been addressed.
25 It was a very conscious decision. It was an issue Heritage Reporting Corporation
(-
1) (202) 628-4888
_ = - - _ _ _ _. ._
g
- T
? . .408 g,p.
- JN_f 1 that was reviewed'at the senior management meeting. So I
'2 had the benefit of. discussing the' issues with my. peers:and
- 3. other senior managers and was very much a_ judgment process'.
4- Following that meeting Mr. Stello and I met on 3 ' site with their. management and, in fact, with most of the-6 operating crews and we at that time delivered.the-CAL and 7 discussed the reasons why we felt it was appropriate.-
8 MR. CARROLL: So'the bottom line, the agency made; 9 the judgment'to permit the plant to continue to operate
. represented a clear and present danger to public health and 11 safety..
12- MR. RUSSELL: That's correct. And we felt that 13 their-agreements to do it under a CAL were sufficient and we-14
[]) didn't need to use an order at that point in time,.although 15 we were prepared to do so had they not agreed.
16 MR. CARROLL: Was there~any effort to develop 17 ' criteria to translate into that so that these aren't H18 subjective sort-of seat of the pants judgments?
19 MR. RUSSELL: That issue has come up most recently 20 in request from Senator Mikulski and there was a GAO review 21 and audit from us. There's a GAO report. There is field 22 guidance from the executive directors, two regional
~
23 administrators on how we follow that process.
24 Essentially all boils down to judgment of senior 25 mangers to the issues that you're dealing with constitute a Heritage Reporting Corporation 4 (202) 628-4888
zg--
-g -
r 1
~409f
. ,x --
..;(,h 1 significant enough' concern that it warrants keeping the 2- plant shut down. And that's essentially-what they boil down 3 to is that judgment and the process that you follow to.
4 assure that the judgment is fairly reached. And then we 5- need to be able to articulate the' reasons for which we do.
6 MR. CARROLL: Okay.
7 MR. WIGGINS: As we discussed before the general 8 approach that-the staff has in review or Nine. Mile was to 9 assemble.a restart assessment panel and focus our inspection 10 licensing resources on Nine Mile restart action plan.
11 That' panel does meet periodically to go over the 12 licensee status and where-we are with that status. As I 13 said, we have membership on that panel from region and NRR,
{} 14-15 bothLaanagement and technical staff.
.MR. WARD: Who chairs that -- in the case of Nine 16 Mile who chairs that?
17 MR. WIGGINS: Bill Kane is the chairman. The co-18 chairman is project director for NRR, Bob Kaplan.
19 This is the site Bill Kane used earlier in the 20 process, so we can just briefly go where we are with Nine' 21 Mile and follow the slide and get a little bit more detail.
22 As we saw the CLA, confirmatory action letters
'23 were issued. The licensee has submitted a restart action 24 plan for our review. The panel has been -- is getting to 25 the final stages of the completion of the review of that l
4 Heritage Reporting Corporation j
() (202) 628-4888 j J
l l 410
(,, 1 plan. We've been through the plan several times, as I said 12 before'and found'suitcble for implementation. We're looking 3 at final approval cycle right now.
4 The licensee is currently in completing its self-5 assessment, driving toward issuance.of a readiness for 6 restart report which we expect to see sometime early 7 September.
28 As a parallel I think it would be worth looking at
.9 the licensee's current plans for power ascension program 10~ . testing. They have discussed it with us conceptually. We 11 haven't seen a lot of detail yet on it, we're still working 12 with that. What we've seen so far though it will be a
- 13. tiered approach, there will be stop points for licensee's 14 assessment'of activities.
15 We do have a plan, the conduct of an integrated 16 assessment team inspection, so that we can put the cycle of 17- making a decision one way or the other on re, tart.
18 This slides just goes over some af the rarrent 19 activities. Like I said, the final approval is waiting the 20 results of our review of the public meeting outcome. And 21 we're working through the issues that have been in the 22 restart action plan, particularly the specific issues. The 23 architecture of the restart plan talks about fundamental 24 root causes with actions against-those and then some 25 specific technical line itetns that you can take off as you fS Heritage Reporting Corporation V (202) 628-4888 l
i
\
i
411
(~;
(_ 1 1 would saying that TOL is approaching a licensing decision, 2 he has an outstanding technical issues and need it resolved-3 for the SER process.
4 Similarly, the inspection licensing issues that 5 exist at Nine Mile -- for Nine Mile-1 that, we' re looking our 6 way through.
7 Lastly, we talk to the utility, a tentative 8 schedule, they'rP not looking to reload until somewhere in 9 September with the plant restart in November.
10 Some of the other NRC activities associated with 11 Nine Mile, we just last week finished an inspection that 12 looked at possible instances of intimidation of employees.
13 That was completed last week, that's in documentation phase
()
v 14 now. That was an outfall of problems that were originally 15 brought to our attention in 1986.
16 We did discuss the augmented inspection team, that 17 report is in preparation now. We will review and complete 18 the review of their restart action plan, I would anticipate 19 somewhere in September we will be in position to make a 20 decision on this approval.
21 We are looking self-assessment ratings for 22 restart. We will get the licensee's report in on their 23 readiness for restart. We will review that report including 24 probably an onsite phase for about a week with a small group 25 of individuals looking at how the utility arrived at the g3 Heritage Reporting Corporation
(,) (202) 628-4888
n ;-
p 412-3,q g< k 'l- conclusions'they arrived at.
t b .2~ -Once we get'a' favorable outcome on that* type of-
~
[ 3 inspection'then we commit to-resources to the integrated 4- ' assessment team' inspection.: The earliest appears that the 5 .AITI concurs in October.
.6 We still need to look at the power ascension 7 program for unit-1 and come to an agreement,with them-or at' 8 least feel.that that's an adequate power. ascension program 9 given the situation at hand with the plant being down for:as C
10 long as it has now.
11 If we do and when we do give restart approval for 12 the facility we would intend to provide'some augmented 131 coverage of the restart and the initial 1-- and the power-
[14 ascension test program which would involve some 24-hour
'( )
15 coverage and some special targeted coverage of particular-16' activities, somewhat similar to what we have done with 17 Pilgrim.
18 We haven't yet decided what kind of resource load 19 that's going to need. We'll have to see what the licensee 20 thinks they need to do through their power ascension 21 program, and then we will have to do something that's 22 responsive to the activities they have in that program.
23 That's the end of my prepared remarks.
24 DR. REMICK: Any further questions?
25 (No response)
Heritage Reporting Corporation (202) 628-4888
g
'413
.. ;W
\-) 1 DR.'REMICK: Hearing none,.let's move on.
2 MR. WIGGINS: I guess the next man uplwill be 3 Randy Blough.who'will speak on Pilgrim.
i :.
4 (Slides being shown.)
5 MR. BLOUGH: AsLJim said, my name is Randy Blough, 6 I'm a Reactor Project 'Section Chief. My responsibilities 7 include. Pilgrim plant and two others. I've.had the' Pilgrim 8 plant since September of 1987.
9 I've been a project section chief for four years.
10 Before that I was in a resident inspection program for six-11 years, total of nearly 10 years with NRC. Before that I was 12 an officer in the nuclear submaririe program for a little 13 over six years.
i() 14 I have two slides and a short-presentation here in 15 light of the fact that you've -- most of you are fairly.
16 familiar with the Pilgrim situation.
17 Pilgrim has been an interesting case. It's a 18 utility leading to the extent it shut down, had a history of 19 poor performance and also had staffing problems, reluctance a
20 to acknowledge a number of the problems. And also had a 21 weak self-assessment capabilities.
22 Of course, after the shutdown deficiencies in 23 offsite emergency planning were determined to be an emerging
)
24 issue that required a lot of attention, also.
25 The licensee has gone through and is still, in
,Q
, Heritage Reporting Corporation v (202) 628-4888
414 i ,1 1 fact, in the latter stages of a process -- the release 2 process. The release process is back to the standard track 3 and it is then up to the regional administrator.
4 They. changed the structure on the staffing. They 5 changed the programs, upgraded hardware and material 6 condition of the plant, and have been continually working to 7 rehabilitate the safety culture at the plant.
8 Their process, as well as the NRC's process, has 9 been fairly similar to the generic problem plant process 10 that Bill Kane has outlined.
11 Of course, during the extended -- some of the 12 unique features of Pilgrim are the fact that during the 13 extended outage they had they underwent a safety enhancement 14 program that involved several major modifications, mostly
("J3 N
15 geared at the fact that it's a MARC-1 containment, BWR.
16 A unique factor in the Pilgrim process both for 17 the licensee and for the NRC is the uniquely high level of 18 public and local and state elected official interest in the 19 plant as well as the very complex situation related to 20 offsite emergency planning at the facility.
21 As I stated the NRC's process is really these 22 standard Region 1 approach to problem plants with those 23 additional considerations.
24 The NRC's involvement started really as an effort 25 on our part in late ' 85 and early ' 86 to -- in view of the Heritage Reporting Corporation
()
-s (202) 628-488B 1
1
U
[. 415 p).
~
(. . .
l . problems.that we suspected that-the licensee'had toidiagnose-l 2 -; and understand the licensee's level of performance,.' the
-3 reasons for that performance, and the problems that they;
'4 had.
t 5 over time early-on we spent a large amount of
, 6. effort to get the licensee to actually acknowledge their own~
7s problems. Over the last years we have;gone through a slow 8 transition to a situation where we could stand back:
9 somewhat, although still obviously very much. involved and 10 - evaluate the licensee's self-assessment process and to 11 - independently improve their programs and-assess their own 12- results.
13 Throughout this program there has been extensive Ll4 - NRC senior management involvement.- Also involvement on the'
-( )
15- - part.of the ACRS, the Commission itself in' terms of 16 . Commission meetings, a lot of Commissioner staff interest' 17 and several Commissioner tours of-the site.
18 We've had an extraordinary-level of staff effort 19 both from the inspection standpoint and related to the 20 emergency planning situation and responding to the outside 21 -- various outside interests and all issues associated with 22 Pilgrim.
23 our efforts have been coordinated by the restart 24 panel. That activity has been -- the activity of the panel 25- and the efforts and coordination we have been able to 1
Heritage Reporting Corporation 1
(202) 628-4888 m m._ __.__ _m. .
- _ _.-m._m -_m____m____. _ _ .m
416 1 achieve and I believe are quite beneficial and quite 2 successful.
3 We are currently, as you look to the bottom of the 4 slide, in the power ascension program. The licensee is now 5 at the 75 percent power plateau and conducting -- they 6 completed the testing at 75 percent which is really minimal 7 and are non in the self-assessment process in preparation 8 for making their own determination that they're ready to go 9 to full power and then approaching the NRC.
10 We're operating with a restart staff onsite under 11 a detailed staff operating plan. Of course, the restart and 12 power ascension program was sucmitted by the licensee and 13 proposed including the NRC approval points that have been
() 14 discussed earlier and accepted by the licensee.
15 The additional unique feature of the power 16 ascension evaluation and deliberation process is the 17 Commission's involvement. At the time the Commission voted 18 on the restart of the Pilgrim plant they -- in the staff 19 requirements memo they directed the staff to provide the 20 Commission with information papers prior to the release from 21 each approval point. And that information paper includes 22 both the discussion of the NRC staff evaluation and the 23 plant and personnel performance; and aleo an update on the 24 status of emergency planning.
25 After the Commission has received that information Heritage Reporting Corporation
(~)/
K- (202) 628-4088
.f, t
~,
1 2' ,
I417~
=
3 . paper and had a: chance to review;it, then the release lt 1 : processLis backlto the standard track where_it is then:up.to-3 the regional administrator:and he basica11y'has the'say._on!
4 'when'the licensee-would be released from approval point.-
5 DR . : REMICK: Questions?
6' Excuse me, are you finished, Mr. Blough?-
7- MR. BLOUGH: Yes. I'm ready;for.your questions,'
- 8 sir?
9 .( No response) 10 RDR. REMICK: Hearing none, we thank you.
11' .MR. BLOUGH: Thank you.
12 Next is Jim Linville on Peach' Bottom.
13 '(Slides being shown.)'
14 MR. LINVILLE: Good morning,.I'm Jim Linville, 15 Project Branch Chief responsible.for oversight inspection 16 program at the Peach Bottom facility.
17 For-the past two years I have been the section F ,18 chief responsible for Peach Bottom inspection program. And 19 was a section chief for a couple years prior to that of 20 another section. A senior resident inspector for.five 21 years, both boiling water and pressurized water reactor 22 sites. A couple of years in industry before that, an lc l 23 architect engineer, and seven years in nuclear programs
, 24 before that.,
1
- M5 I just have the one slide here. These two Heritage Reporting Corporation (202) 628-4888
418 n.
4/ 1 previous briefings with the committee since the Peach Bottom 2' shutdown. An order was issued in March of 1987. That order 3 was. triggered by allegations-of widespread licensed operator 4 inattendanceness in the performance of their duties in the 5 control room at Peach Bottom which was substantiated by us 6 in late March'and resulted in an issuance of the' shutdown 7 order.
8 I might add that prior to the issuance of the.
9 shutdown order Peach Bottom's performance record was rather 10 dismal. They had a number of escalated actions related to 11 operational performance, poor SALP readings for the previous 12 couple of periods. They had a diagnostic inspection which 13 is indicated that there were management attitude problems at 14 the site and they had developed the performance improvement
)
15 program and were presumably in the process of implementing 16 it when these allegations came in.
17 So the triggering event was really the last straw 18 in the progression of problems that had been seen over the 19 preceding couple of years at Peach Bottom.
20 But the principal issues in the order were the 21 inattendanceness of the operators and the failure of the 22 utility management to correct the problem.
23 And the order required that the licensee shut the 24 facilities down and maintain them in that condition until we 25 may determine that they were suitable for restart.
Heritage Reporting Corporation O <2o2> 828-4888 I
l I
i 419 !
- p(
\~ /' 1 In developing their restart plan the licensee did 1
2 a root cause analysis. And they developed a corrective i 3 action program initially which after a great deal of 4 discussion and review was subsequently totally revised to 5 focus more on the specific root causes. And one root cause i
6 .that they didn't initially address which was the I 7 responsibility of corporate management in the program or in 8 the problems. The corrective actions associated with 9 recovery-from the situation which existed there. .i i
I 10 The principal issues addressed in the restart plan 11 were widespread management changes all the way from the 12 shift superintendent who was the senior individual on chift 13 at the facility to the chief executive officer of the j
() 14 company. Those changes occurred over the year following- 'i 15 shutdown.
16 In addition, they reorganized to create a nuclear 17 dedicated organization which they didn't have prior to that 18 time. And to focus the attention of management on the !
I 19 nuclear plants themselves and have other arms of the company )
l 20 work on focusing on problems associated with non-nuclear I 21 parts of the company.
22 The other principal issue in the corrective 23 act: tons for the restart plan was that of training. They i
24 provided extensive training to improve the attitudes of the j l
25 licensed operators. And they also performed extensive
'n Heritage Reporting Corporation (J (202) 628-4888 i
l i
i I
i
b '
420 f s ,g_y)
P l' : operational performance training for the new-shift crews 2 which were formed following-the shutdown, because they 3 brought in new shift managers who had been previously j 4 licensed but not on shift in the past. And in order to l
5 assure the competence of these crews they performed 1
l- 6 extensive training in the simulator to assure that the new ' ,
7 shift crews were ready to operate the facility.- l 8 When they completed the restart plan they perform j 9 their own self-assessment program. We performed an j 10 evaluation of.that program which I will mention later. This l 1
11 involves senior management review of the corrective actions ;
i l 12 taken to address the problems, not only in the specific 13 areas of concern but in all the areas where they felt they
(} 14 had problems that needed to be addressed before. restart. It l
15 covered all the functional areas and more than we normally l 16 break out in the SALP process, l 17 They also submitted to us a restart power testing ,
I 18 program including three hold points 35, 70 and 100 percent 19 power. The purpose of those being to do self-assessments, l
20 provide opportunities for operator training and of j 21 evolutions on an operating plant since they had not been 1
22 operating for over two years, and to perform post-23 maintenance and equipment testing that was required in the 24 course of a normal restart from an extended outage.
25 The NRC response involved the formation of a panel Heritage Reporting Corporation
([qf (202) 628-4888 l
f-421 7-k/ 1 chaired by Bill Kane and including representatives from the 2 region and NRR to coordinate the activities associated with
~
3 the review of the Peach Bottom situation.
4 It included three rounds of public meetings. And 5 it included a meeting in each of the three counties 6 surrounding the plants. The first two rounds were to 7 receive comments on the licensee's first plan and then their 8 second plan, also. And the third war to provide the public 9 with the NRC evaluation of the plan and response to the 10 licensee's program, i
11 DR. KERR: Were the restart plans changed I 12 significantly as a result of the comment?
13 MR. LINVILLE: It's hard to separate the impacts I I
(> )> 14 think of all the players that were involved in the process. j 15 Certainly the public picked up on a lot of things that had 16 been identified by the NRC and had been talked about in the 1 17 media by the press. !
l 18 I don't recall any specific issues they raised l 19 that were new to us in those meetings. Certainly, their
! 20 involvement may have heightened interest and delighted some 1 ,
21 more impetus to take broader actions. It's really hard to l 22 separate the effects of the state involvement, public 23 involvement, our involvement, INPO's involvement. So I 24 really can't say thtt they had any large impact.
25 DR. KERR: Thank you.
i l I
(^s Heritage Reporting Corporation
(-) (202) 628-4888 '
1 1
1 u_-___-_-..-
l i
i 422
/ s 1
(,/ 1 DR. REMICK: Are those moetings held more for I L 2 3nformation? Does the licensee present his restart plan, l 3 summarize that? How are they conducted?
4 MR. LINVILLE: As I indicated, the first two 5 rounds of meetings and there were two because they submitted 6 one plan initially which we found unacceptable and then they 7 submitted another. So in conjunction with each plan they 8 held meetings.
9 After copies of the plans has been placed in 10 several libraries in the proximity of the plant and the 11 public had been notified that the meetings would occur and 12 have an opportunity to review those plans. Those meetings 13 were held to receive public comments on the adequacy of the 14 plant. Certainly, we got a lot of comments but not relevant
/[ }
15 to what was going on, but we did get some comments related 16 to the plant.
17 The last round of meetings we held to describe our 18 safety evaluation report which is the next item on the slide 19 there. What we had done and why we thought that the 20 licensee was ready to proceed with a restart activity. So 21 it was to provide feedback to the public on our 22 determin.stion.
23 And it also -- the safety evaluation report 24 included specific responses to the types of comments that 25 were made in the public meeting.
e Heritage Reporting Corporation
( (202) 628-4888
J t
423
- ,/ m
(_) 1 DR. REMICK: So the first one is a public input 2 meeting. It's not a meeting between the NRC and the 3 ' licensee of which the public is invited; it's an~ input 4 meeting.
5 The second one is the NRC to tell them what.you Ei plan to do and why?
7 MR. LIH7ILLE: Right.
8 DR. REMICK: Okay.
9 MR. KANE: These meetings.we are talking about, 10 they do not involve the licensee.
11 DR. REMICK: I see.
12 MR. LINVILLE: They were -- the states were 13 present at the meetings and, you know, helped us coordinate 14 setting them up in the local areas, but they were our
['))
15 meetings.
16 Moving on to the state involvement, both the 17 Maryland and Pennsylvania were actively involved in this 18 process. We had several status meetings in the State 19 Capitols, the state officials on the activities associated, 20 the reasons for the shutdown and the activities that were 21 going on.
22 We asked for comments of the states on restart 23 plans and received written comments from the states on the 24 plans. And we also had active participation by state 25 representatives in the team inspections in assessing the Heritage Reporting Corporation
() (202) 628-4888
N' 424
~
- '- : 1 readiness of the licensees for restart, both Maryland and 2 Pennsylvania representatives were involved in those.
3' DR. REMICK: Is that unique for the agency?
4 MR. RUSSELL: We've been having observation on b 5 'inspection activities for some time. It's covered in.the 1
6 policy statement and even with letters of agreement that 7 we've had in the past.
8 It occurred to a much greater extent on Peach 9 Bottom, Pilgrim, but we've also had it on Shoreham during 10 observation of training, inspections in other facilities.
11' So it's.not unique. I think it is much more 12 aggressive in Region 1 than I understand from my 13 counterparts in other regions as far as state involvement.-
() 14 DR. REMICK: Do you worry about carrying it too 15 far?
16 MR. LINVILLE: I think in general their behavior, 17 at least on the Peach Bottom situation, I was a team leader.
18 on the integrated assessment team inspection, I was 19 generally responsible. They were very interested on what 20 was going on, had a lot of questions. But didn't really 21 impede our process. And they were so involved the whole way 22 through the process that I think that it didn't affect the 23 outcome of the inspection or the effectiveness of the 24 inspection.
25 DR. REMICK: These are DER people?
Heritage Reporting Corporation O (202) 628-4888
i l'
I I 425
) 1 MR. LINVILLE: Right. DER representatives from 2 Pennsylvania and similar representative from the State of 3 Maryland.
4 MR. RUSSELL: We've actually had experience, also, 5 with others who are generally on the opposite side of the 6 nuclear issue. We had Steve Sholly up at Pilgrim and at 7 Shoreham. And our experience generally is that if you open 8 the process up and they see the depth and the thoroughness 9 of the inspection and they have firsthand information 10 regarding what's going on that they provide factual and 11 carry feedback back to the state officials.
12 DR. REMICK: They're only observers?
13 MR. RUSSELL: They're only observers. They are 14 there observing the staff process. And we negotiate with
(' }
15 them in an agreement up front which they sign agreeing not 16 to release information prior to the NRC completing the 17 inspection process and to interact with the team leader and 18 to the extent they have comments or other issues to brin 19 that to the team leader's attention and to provide any 20 comments in writing which they have and we would attach 21 those to the inspection report and make it available at the 22 time.
23 So my reaction from a policy standpoint is that it 24 has been generally favorable. It provided access to the 25 states so that the states can meet their needs as far as
-- Heritage ReporL_ng Corporation
(),
(202) 628-4888
I I
426 i) s 1 presence and the.need for senior officials within the state
- 2. to- have someone there that's directly observed for them.
3 It is resource intensive.- It takes time. But on 4 balance our experience has been positive.. We have not.had 5 occasion where it has been used for other agendas other than 6 simply observing the process and recognizing what is going 7 on and what is happening.
8 DR. REMICK: In what capacity would Steve Sholly 9 have participated?
10 MR. RUSSELL: The process is one, in both cases, 11 ths governor appoints a state liaison officer and 12 representative and within the state process they can 13 designate who is going to be the observer. In the Shoreham
() 14 case they designated that Steve Sholly would be the observer 15 and it was similar in Pilgrim.
16 The state subsequently had a new employee that was 17 also a participant in Pilgrim, I believe they had two then.
18 At Peach Bottom we had two, one each from the 19 States of Maryland and Pennsylvania.
20 There is an onsite representative of the State 21 Public Service Commission in New York at Nine Mile Point who-22 was assigned protocol for observation of inspections. This 23 is actually fairly common in Region 1 to have observers l
24 and/or the equivalent of resident inspectors.
25 As I indicated earlier yesterday the states are Heritage Reporting Corporation
.O (202) 628-4888 L _ _ _ _ - - - - _ _ _ .
l 427 7.
(_) 1 very involved in Region 1 activities.
2 DR. REMICK: Thank you.
3 MR. LINVILLE: The next group of activities, we 4 have a number of team inspections running the process, they 5 were to assess the effectiveness of the licensed operator 6 attitude, improvement, and their shift performance on the 7 simulator.
8 Just prior to making a recommendation for restart 9 we did an integrated assessment team inspection to assure 10 that the plan had been adequately implemented and the 11 facility was nearing readiness to actually startup.
12 That was followed by subcommittee and full 13 committee ACRS briefings and a briefing of the Commission on
[).
/
14 the readiness for restart.
15 Then when the licensee actually did the startup we 16 had a restart team process that's been ongoing since the 17 startup began in April. It's still in process now. At this 18 time the licensee is at or the facility is at full power --
19 this is unit-2 right now is at full power. They are 20 completing their last SALP assessment program today, and 21 within the next couple of weeks we will complete our 22 assessment at full power and be in a position to make a 23 determination on the final release from the order.
24- DR. REMICK: Questions?
25 (No response)
Heritage Reporting Corporation
( (202) 628-4888
L ii 428
~
L 1 DR. REMICK: We thank~you very much.
2 Calvert Cliffs I guess is next.
3 MR. TRIPP: . Good morning. I am Lowell Tripp. I'm 4 a project section chief.
5 Since Calvert Cliffs is the newest plant in Region
- 6. I to be on the watch list, I thought I'd cover a little bit 7' more. background and history.
8- The declining performance at Calvert Cliffs was 9 reviewed by NRC senior management in the meetings in 10 December of 1987 and June 1988.
11 Those first reviews, the primary emphasis was on 12 the perceived decline in performance rather than on the 13 absolute performance level. And, at that time, it appeared 114 to us that the main weaknesses were in the engineering area-(}
15 and in the general support area, and some staffing 16 deficiencies.
17 Then in 1988 we had a series of events. In June I- 18' 1988 the voltage regulator for one of the emergency diesel 19 generators was improperly placed and left in the manual 20 mode. This caused the diesel generator to be inoperable.
21 Then the next during Unit 1 startup from the 22 refueling outage in July of 1988, an improper adjustment was-23 made to the Delta T power indications which are inputs to 24 the reactor protective system.
25 In September of 1988, a fatality occurred due to Heritage Reporting Corporation O (202) 628-4888
_ - _ _ _ _ _ _ - . l
429
,m x_) 1 asphyxiation or drowning during entry into a condensate 2 storage tank which had a nitrogen blanket to repair a tank 3 level indicator. The people making the entry were not aware 4 of the nitrogen blanket. That was due to a series of 5 inadequate controls and so forth.
6 These and several other lesser events reflected 7 inadequate controls of work activities. In December of 1988 8 then, at a NRC senior management meeting, Calvert Cliffs was 9 added to the NRC watch list as plants that still were 10 allowed to operate, but required close agencywide 11 monitoring.
12 And following that senior management meeting, the 13 NRC Executive Director of Operations, Mr. Stello, met with 14 BG&E management at the CEO level and requested that BG&E
(^)T 15 develop a comprehensive plan to turn around and improve 16 performance.
17 MR. WARD: Lowell, a question. Do you think that 18 the events of mid-1988, the LCO violations and the fatality, 19 would have led to the sort of action that the agency took 20 without the prior I guess observation that there seemed to 21 be some problems developing?
22 MR. RUSSELL: I guess I can respond to that having 23 been involved in the senior management meetings. We 24 actually had three of them before that time. So we 25 discussed it at three consecutive senior management meetings Heritage Reporting Corporation
()
(202) 628-4888
i 430-1 with a concern about declining performance and escalated 2 enforcement actions.
3 It's my view that absent that prior history we 4 would likely not have taken the action we did.
5 It was the prior history over the previous 18 6 months issues with respect to both engineering issues, 7 equipment qualification, material control accountability, 8 issnee with reliability of aux. feedwater systems and how 9 they were testing them, issues with reliability of emergency 10 diesels and gassing in the water jackets, loss of offsite 11 power. There was a total loss of offsite power.
12 So that combination of engineering issues, 13 performance issues, escalated enforcement, which had been
() 14 discussed at three prior management meetings, and concerns
'15 about procedures, and then a series of events in the Summer 16 of 1988 that had their roots in procedural compliance and 17 attitudes toward procedures, that was sort of the straw that 18 broke the camel's back. We recognized we needed to do 19 something.
20 And at that point in time, even though we had had 21 three prior meetings at the Stello level with the CEO, to 22 discuss declining performance, and had been given assurance 23 that they recognized it, that they were taking action,to 24 turn it around, we hadn't seen the evidence of that. So it 25 was that combination of events Heritage Reporting Corporation r]
(_- (202) 628-4888
i 431 L j' 1 There was an OSART review. There were positive I 2~ things in the OSART. There were some negative comments in j 3 the OSART.- The reports, if you carefully read them, 4 identified issues which were of concern. I 5 In fact, one of the issues that I've been 6- concerned about is whether we aggressively enough identified 7 the problems early, got to the right levels of senior 8 management, or whether their past history and good 9 performance caused us to somewhat delay in getting the 10 appropriate actions.
11 It appears that their recent actions demonstrate 12 that they understand what the issues are and they are taking 13 appropriate actions to address them.
(} 14 DR. KERR: How do you account for the fact that a 15 plant that had such good operat ing history went into a 16 decline? Was it a change in management, a change in 17 resources?
18 HR. RUSSLLL: There are two issues, I think. One 19 is complacency and the other is that they were cutting back 20 on cost and expenditure at the plant. They were clearly 21 emphasizing production.
22 And one of the issues that I worry about is a 23 plant that is what is called a " steamer," one that operates, 24 that emphases production over process and quality.
25 They relied a lot on their people. Tnay had very
- Heritage Reporting Corporation (202) 628-4888
432
! ). 1 good technical capabilities within the maintenance 2 . departments, I&C, the operators performed quite well. And L
3- they were being asked to do more with less. And I think it 4 is an axiom of life that you can't do~more with'less. You 5 do less with less.
6 And when they started reducing budgets and cutting
' ~
7 back, they were sending signals to the staff with their 8 actions that were emphasizing production rather than 9 emphasizing process, even though the broad policy statements 10 were there, " safety first," poster campaigns, et cetera, 11 they were sending signals to their staff with what they were 12 doing that causer u.e to be an emphasis on getting the job 13 done.
14 Staff level people felt that procedures were
(}
- 15. impediments. We knew how to get the job done, and they.saw l
16 it as something they had to cope with but found other ways 17 around it.
18 And that comes out.quite strongly in the special 19 team inspection and some of the self assessment activities 20 on the part of the licensee.
21 DR. KERR: Well, they clearly have to follow some-22 sort of procedures. And if they had good staff and knew 23 what they were doing, were the procedures wrong and should
' ;2 4 have been change 6?
25 MR. RUSSELL: Yes. In fact one of the major Heritage Reporting Corporation O (202) 628-4888
433
(,
- )_
1 activities that they have ongoing now is a procedure upgrade j 2 program. They had ambiguities in procedures, procedures i
f 3 that had technical errors in them. And that is probably one 4 of the controlling path items for the company, both in the 5 short term and from an expense standpoint in the longer 6 term.
7 DR. KERR: So in a sense they should have been 8 ignoring the procedures because they were no good, but they 9 certainly should have changed them.
10 MR. RUSSELL: They were relying on the skills and 11 the capability of the people, who were finding ways around 12 procedure inadequacies. And they had not institutionalized 13 the process controls and the procedural controls to have the
{} 14 organization work together well.
15 There were also some issues, interdepartmental, 16 with departments not working well together between 17 engineering and operations and operations and maintenance.
18 Some confusing signals were being sent.
19 So it is a series of events for which we are 20 learning some lessons. I think the licensee is recognizing 21 what the problems are. Unfortunately, we don't have much 22 evidence at this point in time based upon completed work.
23 They have established fairly thorough review processes 24 before they say they are ready. And we are at this point 25 waiting for them to tell us that they have completed their s Heritage Reporting Corporation
(_) (202) 628-4888
434 kJ
- 1 corrective actions and are ready for us to come in and 2 review.
3 DR. KERR: Is it proper for me to ask if the 4 recommendation for shutdown came from the region or would 5 you rather not discuss that?
6 MR. RUSSELL: In this case, I'll discuss it, 7 because it was one that we considered a test of the 8 licensee.
9 When we started seeing concerns in April, March 10 and April, associated with control at work and a series of 11 issues associated with containment integrity, questions 12 during fuel movement, loss of condenser vacuum that nearly 13 caused a plant to trip, and other issues, we were quite p) q 14 apprehensive. That information was coming together about 15 the same time we were seeing the NRR special team intoection 16 report which gave us another input.
17 As well, the company was seeing those issues. The 18 company found the problem with the pressurizer heaters on 19 Unit 2. It chose on Friday afternoon to shut down Unit 1 to 20 inspect it to see if they had indications of leakage from 21 the pressurizer heater sleeves. They did not. They chose 22 to keep the plant down.
23 In fact, they proposed to us to address the issues 24 for restart for both units and identified concerns with work 25 control, with attention to detail in following procedures, Heritage Reporting Corporar. ion
(')
(_ (202) 628-c888
435 1 issues with system status and issues.with the pressurizer.
)
2 And-they sent us a letter first' telling us what j 3 they were going to do_and then we subsequently confirmed 4 that by CJ60 so that the process was one where we were 5 looking'to see what action the licensee would take and 6- whether they understood the need to demonstrate not only to 7 the NRC but to their own staff their interest in safety 8 first and not productivity.
9 And I think'in this instance the company took 10 appropriate actions and kept the plants down.
11' DR. KERR: At some point there was a change in 12 middle management in the process as I remember.
13 MR. RUSSELL: That's correct. There were changes.
() 14 DR. KERR: I don't know whether it was middle 15 management.
16 MR. RUSSELL: Oh, their middle management would be 17 more senior management based on the way they are structured, 18 but they made some organizational changes in the summer of 19 1988 which we don't feel were fully felt at the time they 20 had the events in the Summer of 1988.
21 They have made further management changes after 22 the first of the year, with a new vice president in shortly 23 after the first of the year.
24 DR. KERR: Is he an Admiral, a retired Admiral?
25 MR. RUSSELL: No. They brought people back from Heritage Reporting Corporation O (202) 628-4888
436 k, . 1 other parts of Baltimore Gas & Electric Corporation that 2 were either previously involved in Calvert Cliffs or had 3 turned around other parts of the company's operation quite 4 successfully.
5 So George Greel came from fossil operation and 6 maintenance and had an early relationship with Calvert 7 Cliffs in the original design. And they have now brought 8 Chris Poindexter back who is now a vice chairman of the 9 board, with sole responsibility for overseeing activities at 10 Calvert Cliffs from a board level. He was involved in the 11 early project management activities and operation at Calvert 12 Cliffc.
13 So they have done a number of things to address 14 the management issues and they are approaching I think quite
(/')
s 15 well the issues associated with pressurizer heater problems.
16 But there were signals. The information was 17 contained in reports and while we were seeing a declining 18 performance and we were discussing it internally, that was 19 not known well outside the NRC, although I did have meetings 20 at the Secretary level in Maryland discussing our concerns 21 with Calvert Cliffs.
22 DR. KERR: I'm sorry. What is the Sacretary 23 level?
24 MR. RUSSELL: Cabinet level. Reporting to the 25 Governor, s Heritage Reporting Corporation s,) (202) 628-4888
437
~n.
,b' 1- DR. KERR: Thank you.
2 MR. RUSSELL: With Secretary Walsh and Secretary 3 Brown, the two. Cabinet-level officers in Maryland that had 4 responsibility for overseeing that for the Governor, so that 5 there has been communication. But I don't think we 6 ' completely convinced the company and expressed our concerns 7 to them as well as we could until after we placed them on 8 the NRC's problem list.
9 I know we had some meetings, with Tom Early and I 10 meeting directly with their senior managers in a one on one 11 kind of situation, and candidly discussed our concerns, both 12 plant performance and people performancewise.
13 DR. KERR: Thank you.
() 14 MR. WARD: Bill, could I make a comment? Bill, 15 what you have described is a situation where an institution, 16 in the face of changing environment, changing situation, has 17 failed to upgrade its procedures and controls and decided to 18 get by with the talents of skilled and experience people.
19 And that didn't work.
20 What I am comparing that with is regulation by 21 SALP. And I'm just still worried about that, concerned 22 about it.
23 You aren't doing that sort of thing at your 24 institution?
25 DR. REMICK: I couldn't help seeing the analogy, r~x Heritage Reporting Corporation i
l-U (202) 628-4888 E__
7 1
-l I
438
(~m
()
m 1 too, asking is there a lesson for this agency to learn from i
i 2 the fact outdated procedures, hence outdated regulations, 3 and therefore people find ways.around them to accomplish 4 what they want.
5 Is there a lesson there for us?
6 MR. WARD: Yes.
7 MR. RUSSELL: I think there clearly are some 8 lessons to be learned. And the staff is looking at the 9 OSART experience and what had been the history with Calvert 10 Cliffs. That's ongoing now.
11 But I would submit that the, if you look at the 12 enforcement history and the other things that we were using, 13 the other tools that we had available, including SALP
() 14 reports, that we were identifying declining performance and 15 trends, were taking a harder look at operations, were 16 emphasizing people issues over design issues and hardware 17 fixes.
18 MR. WARD: I don't think I made my point.
19 DR. KERR: I don't think he got through to you, 20 Bill. Try again.
21 MR. WARD: Maybe it's a little obscure.
22 But you know, we've been, during the course of the 23 last two days, I think you've found some skepticism in the 24 committee about the process of regulation by SALP.
I 25 You've found that you don't have the regulatory f^ Heritage Reporting Corporation
'(,,) (202) 628-4888
g-..
p,
'439' y.
L)/ " :1 - tools to make clean, clear judgments about whether the L 2 _ plants are safe enough and so you are depending on the 3 skills and talents and experience of the people in the 4 regulatory institution to make judgments, some more
, 5 subjective judgments.
6 DR. KERR: You have had to circumvent ambiguoL1 7 regulations. Procedures, let's say.
8~ MR. RUSSELL: We have regulations that require 9 that we have procedures.
10 DR. KERR: No. I'm saying, an analogy. In your
.1:L case they are regulations. In their case they were 12 procedures. Each was out of date. They had to find a way 13 to get'around them. You've had to find a way to get~around
.14 them.
15 This may work temporarily. But is it a good 16 longterm practice?
17 MR. MARD: In the face of declining resources.
18 MR. RUSSELL: In the face of declining resource 19 bases. I described earlier one of the major concerns I have 20 in the region is the ability to staff and get quality 21 people, and as you've been hearing for the last several 22 days, that have that experience base before they come to the 23 agency.
24 It's a good question and one that I'd like to 25 think about before responding. And I think it is one that Heritage Reporting Corporation O (202) 628-4888
440 f-)y
( - 1 would be good to pose to Headquarters.
~
2 I recognize your concern. I guess I haven't taken 3 the longer view yet. I do feel that regulations should be 4 less prescriptive in their detail.
5 I don't want to go to what the FAA does, for 6 example, in maintenance, where we have 200 pages in the Code 7 of Federal Regulations describing how to perform 8 maintenance. We don't have standard plants. We don't have 9 standard designs. But should some alternative approach be 10 considered as a part of the advanced reactor standard design 11 process or approach? It's a good question.
12 MR. TRIPP: Mr. Ward, I would.also like to try to 13 address your question.
()
14 We've been doing soul-searching and post-mortem 15 analysis. And we go back and look.at history of Clark 16 Cliffs. We have had instances for several years with 17 procedural errors problems, weaknesses in procedures and so 18 forth. They didn't lead to high visibility sorts of 19 violations, LCO violations, unsafe conditions.
20 We perhaps could have done a better job of pulling 21 .these together and highlighting them in the SALP process.
22 We could be criticized in that area for not having picked up 23- on this earlier. We were seeing this for some time.
24 In support of what Mr. Russell was saying, in 25 hindsight, hindsight being wonderful, this licensee has Heritage Reporting Corporation
/]s) (202) 628-4888 1
i
-441 1 historically had weak procedures. Even today we think that 2- they generally have good people. For a long time the good 3- people overcame the deficiencies in.the program, the
'4 weaknesses and unclear procedures, and obscured, perhaps to 5 some degree, the underlying weakness.
- 6. And then when problems started occurring because 7 the operation became more complex,.the interfaces and the 8 communications became more complex, people didn't have the 9 basic procedures and'the basic programs to support them.
10 And in fact, in some of these events.I have just
- L1 discusse'd, well meaning people went out to try to resolve 12 existing problems and compounded the problems then, by not 13 following procedures because they didn't have procedures
'() 14 that really applied, not getting procedural. changes, not 15 getting other departments involved.
16 MR. CARROLL: Let.me follow up with Bill on a 17 hypothetical. This has nothing to do with Calvert Cliffs.
18 .But there is a utility out there that has a 19 consister.t track record of performance with substantially 20 big regulatory requirements. And one' day their CEO comes 21 to you and says Bill, we are changing things. I just simply 22 cannot afford the present cost of operating and maintaining 23 my power plant. I am going to scale back. We are going to 24 cut budgets, we are going to get rid of some people. We 25 fully intend when all is said and done to be a Category 2
('T Heritage Reporting Corporation
(.) (202) 628-4888
y ;n - --- - ,
li?
l k_/ 442 0 "Y p A,_f 1. . plant. We have been a Categcry 1 plant. We.are going.to 2 have declining performance for the next several years under 3 :- this policy,that I am instituting.
, 4 Are you going to accept that?
5 MR. RUSSELL: Well,'until you said we would be 6 satisfied with Category 2, it wasn't a hypothetical case,
~
71 because I have had utility executives come to me with 8 facilities that are top performers in the region, who have-m 9' been very. aggressive, who' find that because of economics 10 that they have to improve the efficiency of their' operation.
11 They tend to characterize it that we're looking.
12 for areas where.the program is not as efficient, where 13 change: needs to be cut out. But they characterize it that 14 we're not going to impact the quality of operations, we are-(}
15 just going to try and maintain that quality but do it more
-16 effectively.
17 We watch those. closely. We want to understand 18 what the changes are. But to date I have not had anybody 19 come in and say I'm satisfied with Category 2, we're going 20 to let our safety performance decline.
21 MR. CARROLL: What would you say to that?
22 MR. RUSSELL: I'd probably react very adversely to 23 that if someone came in and said they were intentionally 24 going to let their safety performance decline.
25 MR. CARROLL: But only down from 1 to 2.
Heritage Reporting Corporation (202) 628-4888
_ _ _ _ _ _ _ - = _
$ ' if <
i 443
.. l
, . , . , .)
~
l'- MR. RUSSELL: My concern is how do you turn that.
r 2 ' trend around? ;Once you start.down that' declining trend 3' side,.you: start-eroding margins,. at what point in time do.
4~ ~they go.below minimally acceptable.and start.having 5 . significant events?
F
', MR. CARROLL: Trust me. I'll have some. events.-
7 But trust'me. ~I'm going to'be,ableLto turn it.off'right' 8 where.it's performance above that needed to'meetiregulatory" U 9: requirements.
- 10 Now, is.that okay with you?
11' MR. .MARD: That's still good.
12 MR.' RUSSELL: You're talking about-SALP 2, right?
13 MR. CARROLL: Yes.
)
- 14 MR. RUSSELL: I think your Categories 1, 2 and 3 15! were different, :right, ~for watch plants?
, 16 MR. CARROLL: We're talking Category 2 SALP, not
- '17 Category 1,.2'and 3 on the watch list.
- 18. MR.-RUSSELL: Okay. My reaction to that is that I 19- .think it would be extremely difficult to do. .And the 20 difficulty would be in the --
21' HR.. CARROLL: It's my problem, though, not yours.
-22' MR. RUSSELL: -- in the message'that is delivered 231 to the employees of that company and how it is perceived. I 12 4 think that would be the most difficult part in that process.
-25' It would be a difficult feat to carry out.
'~
L Heritage Reporting Corporation (202) 628-4888
L 444 1 MR. CARROLL: Well except, you know, I worked'for 2 a utility company for 35 years. And maybe once every five 3 years-the edict would come out that'we've got some problems, 4 we are going to defer unnecessary maintenance, we are going 5 to defer capital expenditures for the next couple of years.
6 It's a way of life in utilities, it isn't anything new or 7 unique.
8 MR. RUSSELL: All I'm saying is that the way that 9 had been characterized to me, and it has come up in quite a 10 number of cases, and I have had meetings with presidents of 11 companies and senior executives within the companies where 12 they have described what they are doing to improve their 13 competitiveness with independent power producers to respond 14 to rate actions by public service commissions and others,
{)
15 and they characterize it that they are going to look at-16 their operation, reduce those areas which are not effective 17' where on a cost benefit basis they are not as effective in 18 providing results, look at ways of improving efficiency, and 19 assuring me that they are going to continue to perform 20 effectively and safely.
21 I've not had the hypothetical case yet of the 22 first person coming in and saying I'm going to be satisfied 23 with declining from all SALP 1 to SALP 2.
24 And my concern would be that the SALP scores 25 reflect what history is and if he's dropping down to the Heritage Reporting Corporation O (202) 628-4888
445 i h 1-/ 1 point where he is changing programs, doing things that are 2 less safe than they were before, that would be very hard to 3 turn around and stop.
4 And when you cross across the line of no longer 5 striving for excellence, but instead being satisfied with 6 being mediocre, that's an issue I haven't had to face, but 7 I'd be very uncomfortable with it.
8 DR. KERR: No , wait a minute. 2 is not mediocre.
9 MR. WARD: 2 is good.
10 DR. KERR: 3 is mediocre.
11 MR. RUSSELL: I'm characterizing it in the context 12 of how it would be received by the organization, the staff 13 and others.
(A) 14 DR. REMICK: Gentleman, your Chairman is going to 15 rule. Mr. Tripp is getting tired, I'm getting hungry, and 16 lunch is ready.
17 So let's finish this up.
18 MR. TRIPP: Okay. Bill Russell stole most of my 19 next remarks. So I'll zip right through those.
20 And as we left off, Calvert Cliffs was still under 21 license in the senior management meeting is December.
22 Senior management also directed a special team diagnostic 23 type inspection be performed in Calvert Cliffs. That 24 inspection was performed in March. It confirmed widespread 25 problems with procedures and ineffective corrective actions.
(~ Heritage Reporting Corporation
(_}/ (202) 628-4888 L _-- _
-n- -- - - -
l 446 f r~x -;
's-) 1 It also focused on management weaknesses as reflected in the 1 2 overemphasis on power production.
s 3 Also during the March-April time frame, additional 4 problems involving procedural adherence and control of work 5 activities occurred.
6 They resulted in events like a loss, partial loss 7 of condenser vacuum during a condenser air and leakage test 8 which nearly led to a reactor trip, and led to a couple 9 cases of ESF actuations, led to two losses of containment 10 refueling integrity during core alterations, and there was 11 an incident in which a diver entered in intake structure 12 while a saltwater pump was still running because he thought 13 it was tagged out of service and a breakdown in the tagging n
({) 14 controls.
15 In early May of 1989 during the Unit 2 refueling 16 outage, BG&E identified numerous indications of primary 17 system leakage near pressurizer heater penetrations.
18 On May 6, 1989, Unit 2 was also shut down to look 19 at pressurizer heaters.
20 Could I have the next one please?
21 Although Unit 1 saw no indications of pressurizer 22 heater leaks, on May 23, 1989, BG&E committed to not restart 23 either unit until the root cause of the pressurizer heater 24 penetrations leaks had been resolved and corrective actions 25 had been taken to improve performance in three main areas.
("] Heritage Reporting Corporation
\_/ (202) 628-4888
447
,~.
(_) 1 That is, better control of system status, better control of 2 work activities, and better procedural errands in control of 3 procedure changes.
4 Those commitments that they made to us in that May 5 23 letter are then confirmed in a confirmatory action letter 6 issued by NRC the next day, May 24. And this CAL also 7 discusses the agreement that the Regional Administrator 8 concurrent or agreement is needed before they restart either 9 unit.
10 On June 21, 1989, the licensee also agreed to 11 address some of the special team inspection issues before 12 restart.
13 With respect to the longer term corrective actions
() 14 and improvements, the licensee submitted their first version 15 of their performance improvement plan, or their PIP as we 16 call it, on April 7. That remember was in response to a 17 request from the EDP back in December.
18 This performance improvement plan was updated on 19 July 31 to include more detail about implementation and to 20 reflect current corrective action plans.
21 In NRC we have an assessment panel to evaluate and 22 review this PIP and that panel has met twice in August with 23 BG&E to better understand the PIP and its basis, how BGGE 24 determined root causes of problems, and to better understand 25 implementation plans. All those things to assist us in our
(~3 Heritage Reporting Corporation (m/ (202) 628-4888
448 V 1 ongoing review.
2 Could I have the next slide, please?
3 In the way of future plans, we are finishing 4 completion of a restart action items list. The licensee has 5 a restart action items list. We will be comparing ours with 6 theirs.
7 It covers basically actions in response to three 8 things then. There is the confirmatory action letter, there 9 is the special team inspection findings and there are a 10 couple of other issues that have come up that are considered 11 significant enough that they need to be finished before 12 restart.
13 They are in the process of currently completing 14 and verifying completion of individual restart corrective f( )
15 a tions. I think they just finished the first five or so.
I 16 There are nearly 50 items on their list. They turned over 17 packages for about the first five last Friday.
18 We will be inspecting these packages, their 19 completion of individual actions. We will finish that 20 inspection and assess overall adequacy of BG&E corrective 21 actions, including their readinens for restart.
22 When all the restart issues are satisfactorily 23 resolved, then the Regional Administrator will concur with 24 restart plans.
25 We will also do some sort of augmented inspection ,
i (N Heritage Reporting Corporation
(_) (202) 628-4888
h>
[!{,, '
di 449 L
"_ y sG ti- . coverage, augment the normal coverage during restart to l . .
i 2i ' closely monitor.their_ performance.
3 And of course, last but:not least, the Calvert 4' L Cliffs Assessment Panel will continue its review process.of 5- the performance improvement plan,.again'the performance 6.
~
improvement' plan being something that is to lead to longer 7 . term corrective actions and longer term performance l,
'8. improvement.
.9 That is the.end'of my prepared remarks.-
10 . DR . REMICK: Any questions'of Mr. Tripp'or.any 11 final questions on the watch list plants?
12 '(No response) 13 DR. REMICK: I think you can understand why we get j) R14 such-a good turnout at these regional meetings. It is a 15, good chance for the committee to rap with regional staff and 16 also pull the regional administrative chain. We appreciate 17 the responsiveness and the opportunity to exchange views 18 with you.
n 19 We will break here in a minute for lunch. We 20- originally were planned to have tours at 1:00. Do you.want 21 to still continue those or take up operator licensing at 22 that time? What's your pleasure?
23 MR. RUSSELL: I would suggest we take up operator 24 licensing since some'of the members have seen the facilities 25 and we can do that either on an individual basis again, and fs Heritage Reporting Corporation A_ (202) 628-4888
'f i 450
.y I _I J.. 1- that way we.can get through the presentation for those who
~
H 2' might have'to catch airplanes.
3 :DR. REMICK: All right.- Let's break for lunch and 4 return at 1:00 o' clock, take up operator. licensing.
5 (Whereupon, at 12: 30 p.m. the lunch recess was
.6 taken, the meeting te resume at 1:00 p.m. on the same day, 7 Wednesday, August 30, 1989.)
8 9
10 11 12 13 14.
-15 16' 17 18 19 20 21 22 03 24.
25 Heritage Reporting Corporation
-pd (202) 628-4888
, ~ _ _ __ _. . - _ _ _ __. _ __
451 n
() 1- AEIEEH22H EEEE12H 2' (1:00 p.m.)
3 DR. REMICK: Let's reconvene.
4 MR. GALLO: Operator licensing. I tried to follow 5 the agenda items that were provided to us and be responsive 6 to the specific issues. If you want to go quickly through 7 any of them, we can do_that.
8 The first item was program status. And what we do 9 regarding program status in Region I, we have a quarter of 10 the region for the Regional Administrator. And what we talk 11 about is the staff resources.
12 Our budget from NRR for operator licensing 13 specifically is about 12-FTE. There's kind of little extras
() 14 in there thrown in for generic activities.and things like 15 that. It's about 12 people.
16 I have one licensing assistant who works-directly 17 for me.
18 What we have really on the staff, besides what the 19 budget allows us, we have two sections, a b6111ng water 20 reactor section and a pressurized water reactor section.
21 And that's two section chiefs.
22 Rich Conte will talk later on one of his slides 23 and Pete Eselgroth, who is trying to repair the overhead, 24 has the pressurized water reactor section.
I 25 In those two sections there are an additional 19 '
I
() Heritage Reporting Corporation (202) 628-4888
t
[.
452
(,- ) 1 professional people assigned right now. Sixteen of those 2 tre certified examiners and there is one licensing 3 assistant.
4 Six of the examiners were previously licensed at 5 commercial reactor plants. Actually, five of those guys are 6 certified right now and one of them is in training. So 7 there are six people with that experience.
8 Now, we have some other activities that they do 9 that we'll talk about later on. They don't do only 10 examination activities. These people are called operation 11 engineers and they do inspection activities.
12 MR. WARD: Oh, is that the reason for the 13 difference between the 12 FTE and the 207
/~T 14 MR. GALLO: Yes, sir. The operations engineers LJ 15 are expected to support, pull their load as far as some 16 inspection activities, too.
17 MR. WARD: Okay.
18 MR, GALLO: Some areas have assigned inspections.
19 A lot of the inspections we'll be doing are reactor 20 inspections to support problem plants. But there are some 21 specific assigned areas, too.
22 DR. REMICK: How many consultants do you use in 23 the region?
24 MR. GALLO: We have one consultant, Dr. Robinson, 25 and we have contractors that are supplied through NRR Heritage Reporting Corporation
(- ) (202) 628-4888 C _ - _ . . _ . _ _ _ . _ _ _ _
453 t 1
<> 1- operator licensing branch from PNL, Pacific Northwest Lab, 2 EG&G in Idaho, and there is a commercial contractor in New 3 London, Connecticut. And there are about 30 examiners there 4 total I believe that are certified people. And we draw them 5 through a request system, first come-first served, 6 basically. But they are used quite readily on all the 7 exams.
8 The NRC ground rules are basically that NRC 9 examiner is the chief examiner, but contractors can make up 10 the rest of the team, basically.
11 The examination performance for fiscal year 1989 12 through August 7, we started a new requal. exam methodology.
13 We actually did a pilot in June of 1988 at Salem. For 1989
() 14 we are going fairly steadily on doing requal exams. And 15 through August 7 we have completed 159 individual requal 16 exams. The projected total we've got for the first ten 17 months of the fiscal year was 120.
18 Basically, for this year, we are trying to do 10 19 percent of the operators, requal exams.
20 I put a note on there, scheduling is controlled by 21 the NRC. And that is pretty much true. We have to try to 22 fit in with the licensee's own requalification annual exam 23 schedule. But we're trying to do it on a week when they are 24 dong their own exams and we substitute our exam for what 25 they would do. So we' re trying not to do it in the middle A
(_) Heritage Reporting Corporation (202) 628-4888
l:!=
w
}
lu
! 454
{. .,%
() 1 of'an outage or time when there is no training going on.
2 And the training program, most facilities usually shut down 3 for a month or two in the Summertime.
l 4 DR. REMICK: How do you justify only the 10 ll 5 percent if you are supposed to give everybody a requal exam
'6 every six years?
7 MR. GALLO: Well, the goal for the next year is 8 going to be approximately 25 percent. If we get 25 percent 9 in the next four, 1990, 1991, 1992, 1993, we will be able to 10 make it, we.should be able to make it.
-11 DR. REMICK: Do you have the resources to reach 25 12 percent?
13 MR. GALLO: With contractor support at its current r^i . 14 levels and the NRC examiner at current levels, and where d
15 we're supposed to be, I think yes.
16 There has been recently a fairly large increase in 17 the number of examiners at Pacific torthwest Labs. They 18 hired quite a few people from Westinghouse that worked at 19 the Richland facility. I think it was about 25 of them that 20 were intended on becoming examiners, and I think most of 21 them are through that program.
22 MR. CARROLL: This does represent declining 23 performance, though, as we were discussing this morning.
24 MR. GALLO: By the NRC7 25 MR. CARROLL: Just kidding.
'. Heritage Reporting Corporation (202) 628-4888
[
l l ,_s 455 i
1 MR. GALLO: The other part of the exam workloads 2 other than the requal exams, which really right now is a 3 little bit bigger workload, is the initial exam process, or 4 initial or replacement exams. We are talking about people 5 who are not previously licensed or SRO upgrades.
6 For the year so far we had projected a number of 7 about 240 and we have conducted 219 of those type of exams.
8 And that really is not readily scheduled. The schedule is 9 controlled more by the licensee, still, than it is, this 10 fiscal year anyway, than it is by us. They control 11 absolutely the number of applications. We get a generic 12 letter out once a year and we do get responses that say how 13 many people they think they will have for new exams in the
((% ) 14 next three years. Those numbers rarely are exact. So they 15 may predict a class of 15 and by the time the exam comes 16 around it may be only 10 candidates that are really ready.
17 I did make a change on here on program stature.
18 The fiscal year 1990 projection, I figure we could 19 do 300 requal exams next year. I'm not sure whether NRR is 20 going to come out and tell us exactly how many we should do.
21 The original slide said 1400. I went back and counted 22 again. The number of licensed operators at power reactors 23 is about 1310 today. It changes every day by a couple, or 24 at least a couple days a week it changes. But we are not 25 doing requal exams at non-power reactors right now.
I
'\-}' Heritage Reporting Corporation (202) 628-4888
1 3
)
~~
456 i 1 DR. KERR: What is the failure rate of requal 2 exams currently?
3 MR. GALLO: It's on a later slide. For Region I 4 it's about 17 percent. And nationwide it's about 16 5 percent. That's basically this fiscal year.
6 MR. WARD: These numbers here, 300 and 1300, are 7 your region?
8 MR. GALLO: Yes. That is what I'm anticipating, 9 in the next fiscal year we'll have to do 300. In order to 10 get those 1300 people that are licensed now an opportunity 11 to have a requal exam by 1993, we're going to have to do 12 approximately 300 a year, plus we'll be doing about 180 13 probably this year, or we won't be able to meet that.
I) 14 Of course, it's a continuous feed and weed 15 operation. 2here's some peopic always coming in and there's 16 people always learing. So it's kind of a tricky activity to 17 keep track of the peo ple. You have to not only look at hov 18 many people are licensed out when their license expires and 19 make sure they get an exam before their six-year license 20 expires. So it will be interesting.
21 The other staff activities at the boiling water 22 reactor and PWR section activities have been involved in 23 Nine Mile I and Peach Bottom operator evaluations. These 24 were not considered requal exams, they were considered 25 inspection activities. The Peach Bottom was a result of the
('s
\s Heritage Reporting Corporation (202) 628-4888 l
l L__.___.___.
4 457 l
(') 1 large training activities, large turnover, restructuring 2 crews at Peach Bottom. And in Nine Mile I the real impetus 3 'for our' crew evaluations came from an EOP inspection which
~
4 is the next thing down on the, the third thing on the list-5 there.
6 EOP inspections were conducted at the boiling 7 water reactors by Region I and Headquarters did some of the 8 EOP inspections. And the only problem that we found any 9 significant, the only plant where we found any significant 10 problem with the operators was at Nine Mile I. . They were 11' identified as being particularly weak in.the performance of 12- the EOPs.
13 DR. REMICK: How many plants were included in thac 14 -effort?
15 MR. GALLO: All the plants are intended to be
.16 done. The boiling water reactor Mark Is were all done as a-17 priority directly by NRR. So we took the lead on the 18 boiling water reactors and then Tom Early put on the 19 additional requirement to do all the Mark Is in the last 20 fiscal year.
21 But we did some of them and Headquarters did the 22 rest of them. And we're still doing, I think we have three 23 boiling water reactors yet to do and probably about half a 24 dozen pressurized water reactors. We're doing about one or 25 two a quarter, still.
() Heritage Reporting Corporation (202) 628-4888
I 458
! I
\'
1 DR. REMICK: So or all the ones 6. hat have been 2 done, though, the only problem wcs Nine 1(ile I?
I 3 MR. GALLO: Well, that was the only place where 4 there was a particular problem of operators. There were 5 other problems with the procedures. But they are not nearly 6 of the significance of what we saw with the problem at Nine 7 Mile I.
8 I think every inspection report identified 9 problems, mostly in the human factors area. The EOPs 10 themselves technically are quite good. How they've been 11 treated is not always as well as the originators when they 12 were designed.
13 MR. WARD: What do you mean, how they've been
/m i_,) 14 treated? I don't understand.
15 MR. GALLO: They haven't been carefully updated.
16 Human factors process never seems to, in those plants, human 17 factors part of the procedure hasn't been well done. The 18 verification and validation procedure, things outside the 19 control room, particularly, where things have to be manually 20 operated and those types of things.
21 DR. KERR: You mean to say that the guidelines are 22 good but the --
23 MR, GALLO: The technical guidelines are quite 24 good.
25 MR. WARD: You mean the EPGs?
(
l ' Heritage Reporting Corporation (202) 628-4888
459
2 MR. WARD: But you said the EOPs.
3 MR. GALLO: The EOPs are also quite good, until 4 you get to the, if you look at the technical aspect of it.
5 If you look at the human factors,-like how do I get boron 6 out of a warehouse and get it into the power plant, and 7 nobody has maybe sat down and thought about that one. It's-8 'in drums or barrels and it's buried in the warehouse 9 somewhere. But the procedure calls for its use. And a lot 10 more minor things, such as plant labeling'has been a problem 11 just about everywhere. When the procedure labels it one 12 way, and you go into the plant, particularly outside'of the 13 control room, and you find components are labeled 14 differently.
15 DR. KERR: Yo's mean there needs to be a procedure 16 to tell somebody how to go get boron out of a warehouse?
17 MR. GALLO: Well, the procedure says insert or 18 inject the boron. And where is the boron? The boron is in 19 the warehouse. So somehow that has to be programmed in to 20 how it gets from the warehouse over to the power plant in 21 fairly rapid timeframe.
22 I don't know if you want to call it a procedure.
23 But somebody has to know who is in charge of doing it. And 24 we found that people didn't know.
25 MR. RUSSELL: There are two potentially more Heritage Reporting Corporation s (202) 628-4888 1
Y-___- _ _-
f ,,.-
'460 1 fundamental areas that relate to use of the symptom-based 2 emergency operating procedures that have come up on some 3 plants.
4 The first is the issue o' sre these procedures 5 which should be followed rigorously or are these guidelines 6 which you can deviate from on the fly and substitute your 7 judgment for those who develop the procedures. That's come 8 up in a number of facilities. That's been a training issue.
9 The second element, while it doesn't relate to the
?s approach to procedures, is the human factors of the ability 11 to use the procedures easily. Foldout pages, flow charts, 12 how they check them off, keep track of where they are in the 13 procedures as they are being used in the control room.
n)
(_ 14 And we have had cases where people did not 15 understand that the critical functions of the foldout pages 16 should be followed in ten same manner that you follow steps 17 and procedures. It wasn't clear which steps could be done 18 in parallel, which ones had to be done in series, which ones 19 were done from memory and subsequently confirmed and checked I
20 off, which ones were read and checked off.
21 So we are having human factors problems in the 22 execution of the procedures and how the people are using 23 them and we are also having issues with respect to are these 24 guidelines or are they in fact procedures to be followed l 25 rigorously within the context of what the procedure l
[)
'k' Heritage Reporting Corporation l
(202) 628-4888 1
jq 4611
~; V;
'l' describes. . And that is still a continuing issue.
2 MR. WARD:~ Does Nine Mile I have.these elaborate 3 flow chart procedures?.
4' MR. RUSSELL: All those have. I think Unit I had 5 not. Do you remember, Rich? I think one of them had-not 6 been upgraded.
7 MR. WARD: What about the plant-specific 8 simulator?
9 MR. RUSSELL: They both have a plant-specific 10 simulator. .It's' state of the art. I'm not sure whether 11 it's certified yet to ANS 3.5 but it should e close.
12 MR. WARD:- Okay. But that was.in use, when you 13 had the problem with the operator requal, it was with the 14 plant-specific simulator?
15 MR. RUSSELL: Yes.
}
16 MR. GALLO: With the plant-specific simulator.
17 MR. RUSSELL: And it was probably, they had other 18 problems. There were operator attitude problems, 19 . interpersonal issues between training department and 20 operations, plus the inability to effectively use the 21 procedures. And Nine Mile I was by far the most serious 22 problem that we've seen in that area out in the EOP 23 inspections. And based upon discussion with other Regional 24 Administrators in the senior management meetings I think it 25 is the worst that we've seen.
13 V Heritage Reporting Corporation (202) 628-4888 l
~ - - _ . -- --
p+
r
- {
462 t' - . .
,1 MR. WARD: When'you examine' operators on the 2 simulator, do you1 examine them as a group? I mean, is it an-3 intact crew?
4 MR. RUSSELL: On the requal exam, yes, sir,. it is.
5' MR. WARD: Okay.
6 MR. RUSSELL: We can talk a little bit more about 7 that later.
8 MR. WARD: All right.
9 MR. RUSSELL: How the crew is constructed in the-10 simulator.
11 MR. GALLO: Next slide. Item B. We are asked to 12 address.the impact of Part.55 changes. And some of them are 13 fairly obvious. But some of the' obvious changes turn l out to
(} 14 be very subtle side effects of after-effects.
15 The six year versus the two year licenses. One of.
16 the effects of that here in the region is the administrative 17 processing of license renewals is essentially, or.did dry-18 up; as of May 26, 1989, there were zero more renewal 19 applications. That means our administrative paperwork load 20 went down quite a bit and we did transfer one of the 21- licensing assistants to another position.
22 Site specific simulator, it says mandated there.
23 If you read the rules, it really says a simulation facility 24 is required. The simuJ ation facility is defined as a plant 25 reference simulator or the plant itself or another
() Heritage Reporting Corporation (202) 628-4888 L
1
f p
V
- g. 463
' l. ' simulation plant; approved by the NRC. A plant reference 2 simulator can be certified through a prescribed process. If i: 3 it's using the plant, that's another that's got to be 4 approved.
t 5 DR. REMICK: What is Oyster Creek going to do?
6 MR. GALLO: I believe everyone as far as I know in 7 Rcgion I has ordered a simulator.
8 DR. REMICK: I see.
9 MR. GALLO: They've got them on order. They don't 10 have them in hand, but they've got them in the factory.
11 DR. REMICK: Even including Yankee Row?.
12 MR. GALLO: Yankee Row, Beaver Valley, I think 13 Beaver Valley II are the kind of last two. Beaver. Valley II i
_(,
,&) - 14 was going to try to. depend on Beaver Valley I's' simulator.
15 And it just is not that.close in design. So they are going.
16 to build another simulator. And Yankee has recently made 17 the decision.
18 MR. RUSSELL: In fact, Indian Point II is building 19 another new simulator andinew building, so even though 20 they've had a simulator for some ten years up at Indian 21 Point II, they are building a new one that meets the ANS 3.5 22 standards.
23 MR. CARROLL: Not uncommon throughout the country.
24 MR. GALLO: Okay. The next couple comments are 25 more I think subtle.
Heritage Reporting Corporatio:
(202) 628-4888
- 1 Licensee middle and upper level management
[O
- 2. attention and involvement to licensed operator training 3 program has been, really been focused, partly because of the 4 rule ar_d partly because of the requal exam activity that's 5 been going on. It's just a requirement that the person an 6 annual operating test and a written exam every essentially 7 two years. And an NRC-administered exam for renewal has 8 gotten quite a bit of attention.
9 Enhanced or redirected licensee resources toward 10 licensed operator requalification training program.
11 I think in the past, especially in this region, 12 there have been a lot of new plants coming online, with the 13 Limericks and the Susquehannas and the Hope Creeks and all 14 that sort of thing, with a lot of emphasis by the NRC and by 7e3 U
15 the utilities on the initial license program, and now 16 Limerick is the last plant probably expected to come online.
17 We have seen a lot more emphasis being traded 18 over. And I think the number of replacement operators is at.
19 equilibrium level, but there are some going to be leaving 20 all the time and some replacements, but it is not increasing 21 like it was only five, six years ago.
22 The requal exam provides an adequate basis to 23 evaluate technical qualifications of individual operators 24 for license renewal and to evaluate ten adequacy of licensee 25 requalification training programs. They are two of the main Heritage Reporting Corporation
(~}
(- (202) 628-4888
465 i' i 1- purposes of the requal exam activity that we do.
2 Substantial NRC resources are being dedicated to 3 requal exams in order to support the six-year license 4 renewals.
5 We are doing approximately one requal exam per 6 year, at most facilities. I think in fiscal year 1990 we've 7 got all but two facilities scheduled for a requal exam.
8 There's a couple of plants, Shoreham, we have not done one 9 yet; Seabrook we haven't done one yet. And there are a few 10 others that we examined this year that we will probably be 11 able to skip next year.
12 NRC re-exams of requal exam failures within six 13 months. That was a program decision that was made that when
() 14 anybody fails an NRC requal exam that the licensee can, if 15 their program is satisfactory, considered satisfactory by 16 our criteria, then the licensee can remediate the individual 17 and return him to licensed duties. But the NRC would also 18 come back and re-examine that person in the areas that were 19 failed within approximately six months of the original 20 failure. We're still trying to catch up with some of the 21 original failures.
22 Now, the next bullet is referring to the programs 23 that are unsatisfactory. If there is unsatisfactory requal 24 program, the NRC, through our examiner standards, we've 25 determined that we need to re-examine those individuals l
l l (~)'
'- Heritage Reporting Corporation (202) 628-4888 l
1 l
w-
466
~
- ((-)/j .1 before they go back on shift.or return to licensed duties.
2 We have two facilities in that category right now, 3 at Ginna and Nine Mile II. .That presents some additional.
l 4 workload that is hard to budget for.
L 5 Tracking of individual licensed operator status L
6 and requal exam for license renewal if necessary. And we
'7 are doing that now, and it is-something we hadn't had to do-p 8 before.
9 DR. REMICK: This appears to be taking a 10 tremendous amount of NRC resources, if you think you'have 11 the resources to even increase it further. What do you 12 bhinkoftheideathatisproposedthatmaybecertainhighly.
13 qualified SROs at facilities be authorized by the NRC to 14 conduct these and the NRC just audit rather than perform 16-([
15 2/3rds percent, 16-1/3 percent, I. guess?
16 MR. GALLO: Well, with the way we are doing 17 business right now, I really see a lot of safety benefits 18 from the way the NRC is examining individuals. And I guess 19 I'm not quite sure how to balance that with certified 20 examiners.
21 What we are doing now, right now one of the things 22 we are doing is using plant evaluators in grading in 23 parallel. So we are seeing how they conduct their own 24 evaluations. And we are getting some feel for how the 25 licensee would do that or could do that.
/ Heritage Reporting Corporation (202) 628-4888
.J L ,
N -q .467.
. -)~ -
~1 But rightLnow I personally. don't feel that'that's p
, . .2 the way the NRC ought to be going..
L 7 3 I think once ve get over this monstrous, large
~
t '4 hump here, that the equilibrium situation is not going to be 5 that difficult to handle.
6 The methodology we.are using may change in.the 7 future but I personally am not in favor of giving over the 8 process to certified licensee employees.
9 MR. RUSSELL: I would like to comment I think we 10 have come-a long ways toward the concept of the check
~
11 operator in'that the examination is developed by the 12 utility, we select'the simulator scenarios. We may modify 13 them slightly. The utility develops the written
() 14 examination. They do the job performance measures for the 15 walkthrough-exam. They grade it. We' compare our grading 16 .with their grading.
17 Whether we get to the point where we could use one 18 examiner in a simulator scenario with three utility 19 examiners and conduct that type of an audit instead of a one 20 on one may be a direction that we would end up with in the 21 future. But I think at this point until we get more 22 . experience we will probably continue to be involved on the 23 monitoring process. And it is clearly required as it 24 relates to the regulations at this point for an individual 25 to have passed an NRC requalification exam.
Heritage Reporting Corporation (202) 8-4888
i I
468 !
lr~s .
's l' Even'though that exam is developed and b
V . ..
L2. = administered by the. utility, it is graded by an NRC person
~
3 Lin parallel with the utility grading. So we would be, 3t 4 .would' require a rule change, and I think potentially as we f
5 -get experience with'this process, where we have confidence
-6 in a, utility program, it seems appropriate it me to 7 potentially rely on facility grading for their -uditing i
8 process rather than conducting all of them.
g l9 DR. REMICK:- And you aren't concerned about'having 10 qualified people to do-this? Apparently you do have now an .
11 influx of contractors, but long term --
12 MR. RUSSELL: In fact, back on Bob's first slide 13 that he showed, we have more certified examiners because we
() 14- use examiners also as inspectors. And I think that there is 15 a tremendous' benefit to the NRC in having. people.that have 16 that experience and capability and understanding of the 17 plant to be able to make judgments in real time as to 18 whether the activities are safe or not.
19 DR. REMICK: No question about that. I firmly 1
20 believe that. I'm just wondering, you talked about the 21 difficulty of hiring and retaining people because of "oc 22 being able to be competitive salarywise, and these are very
- 23. valuable people elsewhere also.
24 MR. RUSSELL: We've obtained six SROs now, for six 25 people that were previously licensed. Whether we are able s
Heritage Reporting Corpor.ation (202) 628-4888
_ - .___---_--------________J
t 469 7-
\_) 1 to keep that up or not I think is an issue that the agency 2 and the Government and all are going to have to come to 3 grips with as to whether we are willing to pay our employees 4 comparable to that which they are worth on the outside.
5 DR. KERR: Are you reluctant to depend on the 6 inplant operator because of prejudice, dishonesty, lack of 7 qualifications, or none of the above?
8 MR. RUSSELL: I think it is none of the above. I 9 believe the issue is that the NRC presence in the 10 observation has resulted in improvements to the process. I 11 think the joint effort to improve the requal exams has been 12 beneficial. And I just don't think we have enough 13 experience yet at this point where the staff is willing to I
() 14 back out.
15 DR. KERR: Well, it seems to me that a person is 16 perhaps best able to judge the competence of an operator if 17 he himself is a good operator and is thoroughly familiar 18 with the plant.
19 Now, maybe you don't have any people like that in 20 operating plants nowadays. But suppose you did? It's hard 21 for me to see how an NRC examiner could be any more 1
22 qualified than a local well qualified SRO in order to judge 23 the person's competence.
24 MR. RUSSELL: The process that we are using is 25 that there is a local well-qualified candidate either from
(,,) Heritage Reporting Corporation (202) 628-4888 1
a_______-
$ 470
- 1. ~the-training organization or someone who is previously 2 licensed who is involved in this day to day with the
-3 facility ~that does the evaluation as well as-the NRC. So 4 you've got two in parallel.
5 >DR. KERR: I recognize that. But I gather you 6 'somehow would not be willing to rely on that individual 7 alone.
8 I'm a little puzzled,'because again.the airline 9 analogy is not very good, but the --
10 MR. RUSSELL: I think the record wall show that as.
11 an. individual I felt that a utility program where we found 12 that the program was adequate and we had confidence in that-13 program through some other mechanism should be allowed, and
( .
14 it was not necessary for the staff to examine each operator 15 each six years. That view did not prevail.
16 So I understand the policy. I understood what the 17 . pros and cons were. I expect that as we gain experience we 18 will be able to back away and maybe use one examiner with 19 three utility examiners. I don't see this as a fixed 20 situation for a long time. But I think we need some 21 experience with it now and we need utilities to show us that 22 they can maintain their requalification programs.
23 And right now we are having a high failure rate by 24 NRC and by utilities. We are not seeing differences in 25 grading between the NRC grading and utility grading. The Heritage Reporting Corporation (202) 628-4888
W M s
477 j#})
~
11 programs have not maintained operator performance at-a-F. '
%~
2: satisfactory level and'the failure' rates are running 15, 16, .
3' 17 percent.
4 DR. KERR: I was'goingLto ask about that, because
~
~'
5- -it' strikes me that that is.rather high. And this wou1d11ead 6 me to wonder if the. examinations are the examinations that F 7 ought to be given. -But that'afanother question.,
~
- 8 .But back to the. check operator thing. The few
-9 airline: pilots who know who fly' commercially tell me 10 uniformly that they and their airlines would not depend on 11 FAA examinations to choose their pilots, that their 12 ' qualifications are much more severe than-the'FAAs'for 13 licensing.-
L es) 14 And thet is because they are very concerned about~
15:
~
their aircraft and the people that fly in them.
16- Now, perhaps utilities don't share that concern-17' about their plants and the public. But I would guess that 18 most of them want #eirly high-qualified operators and would 19 not pass people, in fact I would think that they might be 20 less likely to pass people even than the NRC.
21 MR. RUSSELL: I would like to think that is the 22 case also but I am aware of examples where because of 23 negotiated agreements with unions people are able to bid 24 into the training program and they are put up for an exam 25 and if they pass the exam they get the position, and even i Heritage Reporting Corporation o 1 -
(202) 628-4888 L
_ _ _ _ _ _ _. - i
U ,
i 472 i N; !
('; 1 though the utility would like to screen them out or wash I L.) )
2 them out, have not.
1 c
3 So there are a few examples of that nature. !
4 I believe that most utilities screen and are very 5 interested just for the same reason the airlines are 6 interested in the quality of people going in.
7 DR. KERR: Nobody has a stronger union than the 8 ALPA. And those guys do not depend on FAA examinations, 9 when they choose their pilots.
10 MR. CARROLL: It's a different situation, Bill.
11 What Bill is referring to is where a guy, unless you can 12 find a reason t's disqualify him, gets into the program. In 13 the case of the airline pilots, you don't join that fm \ 14 fraternity until, and unless you are a qualified individual.
1
' Q,)
15 So there is a difference there.
16 DR. KERR: I'm simply saying that in each case 17 there is a very strong union. And unless those guys are 18 qualified, and by the way, they don't qualify, for example, 19 as copilots immediately. They frequently start as flight 20 engineers. And they can wash out. But I'm probably 21 overdoing this.
l 22 MR. RUSSELL: FAA, we did studies comparing FAA l
23 practices. We did look into the check pilot concept at 24 length. I recognize that there are strong views on all 25 sides of the issue.
Heritage Reporting Corporation
(~)
ss (202) 628-4888 I
l l
L _ __--
i 473 1 It's my personal view that until such time as the L 2 results start demonstrating good agreement, that programs 3 are maintaining people, that we are going to continue to be 4 involved in it.
5 We are right now seeing good results, good 6 correlation between NRC grading and utility grading. We are 7 not seeing significant differences. So I don't see the 8 grading as an issue. I don't see the difficulty of the 9 examination as an issue. That has not been a contested 10 issue in about the last year or so. Utilities are not 11 taking exceptions to the exams. They are not taking 12 exceptions to the grading. Rather, they are focusing on the 13 people and performance.
i'3 (j 14 DR. KERR: Is the operator examination procedure 15 similar to the SALP procedure in that in order to continue 16 to pass an operator has to get better continually?
17 MR. RUSSELL: No, I don't believe that is so. The 18 operator has to stay current with industry operating 19 experience. He has to stay current with changes in his 20 plant. So to the extent the plant becomes more complicated, 21 you put more burdens on the operator, he has to get better 22 to do his job.
23 But it is intended that the examination come from 24 a systematic approach to training which includes a 25 description of what the job is, the key learning objectives (3
\' Heritage Reporting Corporation (202) 628-4888
474 g 3
'/ ' 1 for thejjob, training on that, in this case the 2 requalification program training, followed up,by candidate 3 . evaluation and then feedback-back into the process based 4 upon'results.
H 'T DR. KERR: It puzzles me that when one has already L 6 in place a fairly selective process in the original operator 7 examination that you get, you still get a 16 percent, that.
8 is about one out of six, failure rate on the requals.
9 MR. RUSSELL: You have to understand that a lot of' 10 the major upgrades that have occurred in training since INPO 11 started the accreditation process were focused on initial 12 candidates.
13 It has not been focused on requalification.
' '( ) 14 Whether you are talking about continuing training for 15 maintenance crafts or you are talking about continuing 16 training for licensed operators, that has only been a focus 17 in the very recent past.
18 DR. REMICK: Yes, once Part 55 was changed, 19 because 55 previously, Appendix A, was prescriptive on what 12 0 was in requalification training and it was not performance 21 based.
22 So many licensees did not want to change their 23 requalification programs to performance based when they had 24 an approved plan by the NRC which was prescriptive.
25 So it lagged. And although shocking in some ways, O~ Heritage Reporting Corporation (202) 628-4888
475 g
h - 1 I have to admit I think the requal program were not as good L
2 as I personally thought perhaps they were.
3 I have had an opportunity through serving on ten 4 accrediting board to talk to licensees whose people failed 5 the new requal exams and also to talk to INPO people. And 6 unanimously they say that the new requal exams are fair and 7 where people failed they should have failed. And I have not 8 found anything different than that. So I think both sides 9 are pleased with the requal program.
10 DR. KERR: It sure seems to me to be a high 11 failure rate considering that they passed the initial 12 operator exam.
13 MR. RUSSELL: The issue becomes one of when did (O) 14 they take that operator exam, was that operating exam 15 performance based, was their training performance based.
16 We have had a long history of very prescriptive 17 training requirements that were embodied --
18 DR. KERR: What you are telling me is if they took 19 today's operator exam they might well not pass it. Is that 20 true?
21 MR. RUSSELL: I'm shying that someone that 22 qualified through a program that was accredited that was a 23 performance based training program, that that person should 24 do well on a requalification exam. And I'm hoping that as 25 they start improving the continuing training that we see an
/
Heritage Reporting Corporation (202) 628-4888
l
'476- )
-1 . upgrading of the older candidates who are-grandfathered who
-( }
2 did not go through that training.
3 And I think that in the main, the high failure i 4 . rates have-been of the older job incumbents. And you also 5 have to recognize there have been a number of major changes.
.6- in the approach operators take in operating plants.
7 Symptom-based emergency operating procedures are very-8 different from the old event-based procedures. Some of the 9 tools are different.
10 So there has been a lot of' training and requal.
11 Some of it has not been effective.
12 MR. CARROLL: So you are saying people that 13 receive licenses today when they come up for requalification-f- 14 you expect --
15 MR. RUSSELL: I'll expect them to do better.
16 MR. CARROLL: -- near 100 percent?
17 MR. RUSSELL: I think the initial examining 18 statistics are somewhere between 90 and 95 percent pass.
19 MR. CARROLL: I'm talking about.this guy that.then 20 comes up for requal, and say chances are --
21 MR. GALLO: I think we would expect them to do 22 better. I agree with Bill, a lot of the exam failures we've 23 seen are SROs. I think I do have the numbers here. There 24 have been quite a few SROs that have been around for a long 25 period of time that have lost their sharpness.
Heritage Reporting Corporation
\ (202) 628-4888
f 477
1 MR. RUSSELL: And in fact some of them, unless 2 you've got a new candidate that has recently gone to a crew 3 throagh a new licensing process, you pick crews and crews 4 have some new people and some old people -- not old -- who 5 have been licensed for a longer period of time. You go me 6 yesterday on those issues. But I think that in general we 7 are seeing that the people that have been licensed recently 8 or came up through the newer training programs are 9 performing better. They underetand job performance 10 measures. They understand the approach. And I think the 11 examination process is much fairer. And the apprehension 12 that existed of quote "the unqualified NRC examiner 13 examining somebody and substituting NRC judgment for utility
() 14 judgment" no longer exists. It's a utility exam monitored 15 closely by NRC. We may change some things in it. The 16 written exams are reviewed and approved. And so I think the 17 process is one where the examination is very much job-18 related and the content of the exam is one that is reviewed 19 and approved by the utility before the examination is 20 administered. And we are still seeing high failure rates.
21 And we' re seeing unsatisfactory programs.
22 DR. CATTON: And Jay, in answer to your question, 23 I would answer yes, I think they will more of them pass in 24 the future, for the reason Bill indicated, their initial 25 training is performance based, but also the requalification
,e k- Heritage Reporting Corporation (202) 628-4888
478
' I-1 programa are now performance based also, so that in time I 2 think we will see a change.
3 DR. KERR: Is much of the failure taking place in 4 the area of emergency operating procedures? From something 5 you said I gather that's right.
l 6 MR. RUSSELL: I would say yes. .
7 DR. KERR: So in terms of their likelihood of B getting into trouble, the old experienced operators might be 9 better. But in terms of knowing what to do once you get in 10 trouble, the new operators might be better?
11 MR. RUSSELL: There have been a few exceptions.,
12 Some utilities have had high failure rates on the written 13 examinations. On Nine Mile Point II, whose program was
!os) 14 unsatisfactory, had a high failure rate on written exams, 15 plus they had a high failure rate on EOPs and a few failures 16 on a plant walkthrough. So it varies form facility to 17 facility.
18 DR. KERR: Are you involved in the training 19 programs?
20 MR. RUSSELL: We attempt to stay out of the 21 training programs. Part of the process that was agreed to 22 by the Commission with the rulemaking was to accept 23 accreditation as prima facie evidence that they had a 24 training program that was performance based. And this was 25 gone through generic letter and through rulemaking. If they
/ ^g
'sl Heritage Reporting Corporation (202) 628-4888
\
q b i 479
^
1 send that in then we accept that and they can substitute 2 that training program for what existed in the FSAR or the 3 Appendix A to Part 55.
4 We do have reactive processes that we can go in 5 and look at training programs. We do have guidance by way 6 of inspection modules that have been used to evaluate 7 accredited programs in the - _t and this was an ongoing work 8 effort between the NRC and INPO. Those guidelines were 9 looked at by INFO. I think they have been used on the order 10 of 20 times. So we do have the capability to review 11 training programs and we do have inspection modules for 12 using them. But they are in a reactive mode, or where we 13 suspect there is a problem, where we see a concern and there l'~ 14 is a need to go in. We don't do that as a routine matter.
(
15 DR. REMICK: You also monitor the INPO effort?
16 MR. RUSSELL: Yes.
17 DR. CATTON: So INPO tells you how well they 18 scored at the particular plant's training program?
19 MR. RUSSELL: No.
20 DR. CATTON: No? So you have no idea?
21 MR. RUSSELL: They send us a letter and they tell 22 us they are accredited or they are not. And we do have 23 procedures now that we follow in the event that INPO puts a 24 program on probation or withdrawn accreditation. And how we 25 would respond to that, in those instances, we do have Heritage Reporting Corporation (202) 628-4888
480
,N
(,/ 1 inspection modules that we'can use to judge ourselves 2 whether the programs meets our standards or not.
3 DR. CATTON: Is there a correlation between the 4 failures and INPO3 accreditation'or nonaccreditation?
5- MR. RUSSELL: I' d say, and Forrest, I've sat 6 through many accreditation boards'as the NRC observer. And
'7 I've been at boards where accreditation has been deferred.
8 That is, there was some element that did not appear to meet 9 the board's standards.
-10 But the process is a pretty rigorous one where the 11 INPO staff doesn't even take it to the board until they 12 think it is ready and has a high likelihood of passing.
13 I characterize the process as I've seen and I 14 follow plants all the way through including observing the
. ()
15 two-week onsite inspection, the subsequent followup 16 inspections. And there is an NRC term, they are assist 17 visits or evaluations, in INPO's language, and I've observed 18- board meetings. So I understand what the process is. We 19 have other staff that have done that. People from the 20 regions have done that. We have probably observed the 21 majority of the accreditation board meetings. We have done 22 our own inspections on about 20 percent or so of the l
23 proJrams. And we are confident we know what that process 24 is.
25 So when we get a letter from a utility that says
() Heritage Reporting (202) 628-4888 Corporation L._.___.___._ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~
7
.i p
481
1 their program is accredited, we know what that means. And 2 we accept that by rule now as prima facie evidence that they 3 have a training program which is a systems approach to 4 training and is performance based.
5 If we subsequently get evidence that that is not 6 working if we observe performance on the job or high failure 7 rate or requal exam or something like that, then we do have 8 the ability to go in and inspect and look at the program or 9 the process. But we want to focus more on results at the 10 end.
11 DR. CATTON: I guess what I was asking is there 12 are correlations between INPO's accreditation and the 13 failure rate.
() 14 MR. RUSSELL: Most of these are accredited. INPO 15 right now because of what Dr. Remick described, until we 16 modified the rule to allow substitution of an accredited 17 program for an NRC-mandated by the regulations requal 18 program, utilities were not willing to change their 19 programs. They would have been in violation of the 20 regulations. That happened in May of 1987.
21 INPO added Program 11 to their accreditation 22 process shortly thereafter and they are now going through 23 with their next rounds of accreditation which is a four year 24 cycle and actually including requalification as a formal 25 program to be accredited.
k- Heritage Reporting Corporation
, (202) 628-4888
l: 4 2
.t, 482 So at this point in time, not all requalification-
-{) ~1 2 programs are accredited by INPO and I do not know tha 3 statistics from ten requal exams ac to how the failure rates y 4 correlate between accredited requal programs and non-
~
5 accredited requal programs. I just don't know that 6 information.
7 DR. CATTON: Are you looking for it? JN; seems to E 8 me that that is kind of a key point, isn't it?
9 MR. GALLO: I think once the programs are renewed, 10 ev3ntually they all become accredited, though. Eventus?.ly 11 they get through the process.
12 DR. CATTON: If you got high failure rates and all 13 ports of other thinga going on, it seems to me that
.r 14 something might be trong with the training programs.
D 15 MR. RUSSEhL: I don't know for example on Ginna 16 and Nine Mile II why those programs were accredited for.
17 their requal programs. Their initial training program were 18 accredited. They had trainers who understood how to do 19 candidate evaluation. They do that for new candidates as 20 well as requal programs. So the evaluation process has been 21 good but we concluded that the programmatic aspects of how 22 they kept people up to speed, job incumbents, was 23 unsatisfactory.
24' DR. CATTON: How could they do part of it right 25 and not the rest?
Heritage Reporting Corporation O (202) 628-4888
k'I; I - - 483 1 MR. RUSSELL: Because you train people to evaluate 2 new candidates as well as job incumbents. I mean,.they know 3 how to --
4 DR. CATTON: So it's the evaluation alte that's 5 fouled up, not the training site.
6 MR. RUSSELL: No. ~ Just the opposite. As a result 7 of accreditation for new programs to get new people 8 qualified to hold licenses or perform jobs, one element of 9 that is candidate evaluation.
10 So a otility that knows how to evaluate a new SRO 11 also knows how to evaluate an SRO who has'been an SRO for
- 12 eight'to ten years.
13 And we don't see differences in candidate' grading
'( ) 14 for candidate evaluation. What we see is that they have not 15 done a good job of maintaining that person's level of 16- knowledge since he was initially licensed in the past 17 current with today's requirements and expectations. So 18 there has been a degradation since initial licensing, or the 19 initial licensing examination process was not completely 20 adequate given today's standards.
21- DR. CATTON: And it is that other piece that INPO 22 is accrediting now?
23 MR. RUSSELL: Yes. It is that continuation of 24 training for job incumbents that INPO is now accrediting and 25 there are some number that are through that process. I just O Heritage Reporting Corporation (202) 628-4888
_ _ _ _ _ - - _ - - _ - _ _ _ - - . - - - - _ - - - - - _ _ _ _ _ _ _ -. l
FT 1 ]
g 484 ,
- 1 don't know what the statistics are at this point in time.
( J' 1 2 MR. CARROLL: Ask your question in four years and 3 I think you could get an answer.
i 4 MR. RUSSELL: Yes. i 5 DR. CATTON: Well, I might get a more complete 1
6 answer.
7 MR. RUSSELL: Four years from May of 1987 they 8 should all be accredited.
9 DR. CATTON: I guess I just don't understand. If 10 I know how to train tne person to paes the exam at the 11 beginning, why don't I know what to do with him so that he 12 can pass it in a couple of years?
13 Either there is an attitude problem on the part of
/~ 14 the person and he doesn't give a damn once he's got his t
15 license, or somebody is just not paying attention. Because 16 the training should be relatively the same.
17 MR. RUSSELL: It's not necessarily the case.
18 DR. CATTON: Does your requal exam have elements 19 that are quite different than the initial exam? I mean, 20 it's not like a driver's license where you take the san.c 21 eram each time.
22 MR. RUSSELL: There are differences, yes. And 23 what you train a person to do to learn how to do the job the 24 first time may include such things as watch relief and 25 turnover and how to make a turn of the plant and other f) Heritage Reporting (202) 628-4888 Corporation
485 rx
' v')
1 things.
2 DR. CATTON: Certainly. But --
3 MR. RUSSELL: There should be no difference as it 4 relates to their ability to handle emergency procedures and 5 emergency response.
6 DR. CATTON: So the requalification exam is a part-7 of the initial exam? J1o? It's differert?
8 MR. RUSSELL: 1 s it relates to evaluation of the 9 ability to use the EOPs tley are essentially identical.
10 DR. CATTON: Okay. Where are they different?
11 MR. RUSSELL: The continuing training program may 12 result in an on the job candidate getting some amount of 13 time in a simulator and not as much as a new candidate gets p
(_) 14 going through an initial training program. That initial 15 training program may take two years. On a continuing basis, 16 you may have equivalent of one day out of six or one day out 17 of ten in training, depending upon what your watch rotation 18 is and how many days off you have. And the simulator 19 training may be one to two weeks in the course of a year.
20 So there is a significant difference, and it is 21 recognized that there are differences in content for a 22 continuing training program from an initial training 23 program. You don't retrain on everything.
I 24 DR. CATTON: Well, you don't have to. Some things 25 you will remember.
i i'
r's
- Heritage Reporting Corporation (202) 628-4888
3 486 '
1- MR. RilSSELL: Operating events are a key area,
(~)T
- 2- lessons. learned.from industry experience, emergency.
'3 procedures, are key elements of a continuing training 4 program.
5 MR. CARROLL: Wouldn't you say another factor is-
- 6. the training departments in those plants are concentrated on 7 getting accredited and putting a lot of their emphasis on 8 in!.tial training as this requal thin 3 .. ; ;;;1 rod and 9- perhaps to some degree --
10 MR. RUSSELL: The utility through NUMARC was to 11 enhance initial training, candidates coming in the pipeline.
12 Some-utilities on their own chose to expand that to job 13 incumbents, and did so on their own.
j-14 It is now being done for licentcd requalification V 15 It has not been ? greed to yet by training across:the board.
16 the_ industry as a whole to do it across the board for other 17 categories of employees.
18 L?. CATTON: So is it just that the plant. won't 19 give the operators the time to spend in the training?
20 DR. REMICK: No, that's not it. They typically 21 spend 12 to 20 percent of time in continuing training.
22 I think the point you are missing, until Part 55, 23 Appendix A was changed, and then subsequently INPO added 24 requalification as a credit program, new people are being 25 trained in current performance based systematic approach to Heritage Reporting Corporation O'.
(202) 628-4888 L___ _- _ -.
487
{} 'l training.
2 On requalification they had NRC-approved plans 3 that by the regulations specified what you had to train 4 people. They were spending roughly on the average 15 5 percent of their time on that. They could not give them 6 another 15 percent to give them performance based 7 requalification --
8 DR. CATTON: Which they needed to pass'the exam?
9 DR. REMICK: Yess 10 DR. CATTON: Okay.
11 DR. REMICK: But that is all changed now, it's 12 behind us. And it will probably be a couple of years before 13 we can accurately answer your questior. has it had an impact 7- 14 on the ability of people to pass requalification
(,
! 15 examinations?
16 MR. RUSSELL: That's true in the licensed operator 17 ranks and true also for STAS. It is not true at this point 18 in time for mechanics, I&C. Their the commitment for 19 continuing training is a carryover from initial training and 20 in some cases utilities have made the commitment to take 21 people who are grandfathered, provide them the sane kind of 22 training, and other utilities have chosen not to do that.
23 It is across the board commitment through INPO now 24 to do that for all licensed operators and tr upgrade 25 continuing training for licensed operatore.
Heritage Reporting Corporation
/^}
L (202) 628-4888
- 488-g fm >
1 MR. GALLO: Okay. Let's go on to Slide C, 2 -requalification exam benefits and problems.
3 Some of the benefits we've seen, I believe it is' 4 more, I said performance oriented, which is I think, true, 5 It is operationally oriented exam, than the replacement
'6 exam. We don't have a separate written exam section that 7 tr.7ks about theory. What we do normally is we have a crew 8 t3gether, expect the crew to be as they operate and as they 9 train. That is not always exactly possible, because a lot l
10 of facilities these days use more than a tech spec number of 11 people on shift. And it is pretty hard to put six or seven 12 or eight operators on the simulator.
13 So we normally end up with four is probably the
() 14 optimum licensed operators in a crew and that is the way 15 most of the facilities train wit.. more operators on a crew 16 in the simulator.
17 There is an NRC licensee team that prepares the 18 exam, normally four certified examiners and whatever number 19 of people the facility needs to prepare the different parts 20 of the exam. Most of the written exam questions have been 21 prepared in advance. Job performance measures are prepared 22 in advance. And simulator scenarios are prepared in 23 advance. And the NRC examiners modify them. We are by 24 program allowed to modify 20 percent of the program 25 substitute questions or scenarios and we usually end up Heritage Reporting Corporation (202) 628-4888
f!,
lL h
489
! l . modifying' pretty much I'd say most of_the parts of the exam L 2 without' replacing too much of the exam questions.
3 The grading process is done in' parallel. In the 4 simulator we are trying to grade a team, how the team 5 performs, and also trying to look at individuals.- And that E 6 is tricky but it can be done.
7 In a simulator, if_you have_four. operators,-the 8 licensee might have four evaluators and the NRC right now is-9 using normally three examiners. So you are going to have a
, 10 minimum probebly of 11 people in the simulator and that can.
11 get crowded. But so far it's worked out quite well.
12 One of the concerns that has been expressed.to ur 13 is that the NRC is not helping the licensees'with their exam 14 material enough.. I think we are helping plenty and probably 15 doing more than we, more than I expected we'd have to do'as 16 far as preparing the exam material.
17 DR. CATTON: Do you' qualify,the simulator, too?
18 MR. GALLO: I'm sorry?.
19 DR. CATTON: Do you qualify the simulator?
20 MR. GALLO: Qualification of the simulator is done 21 through another process. That's being done by operator 22 licensing _ branch in Headquarters. And it's basically a 23 certification process from the utility information to the 24 NRC in accordance with the rule. And the NRC has done some 25 selected inspections of simulators that were requested to be Heritage Reporting Corporation
()1 (202) 628-4888
l' 490
- i. ,,-
- (,) 1- certified. . At this time it is not intended to be 100 2 percent inspection of the simulators as they certify. But 3 it is being managed by the operator licensing branch. They 4 are only planning on inspecting simulatore where there are 5 problems that have been identified by either the utility 6 themselves or the region.
7 DR. CATTON: There were a lot of questions about 8 the fidelity of the simulator and differences between the 9 way it behaved in the plant.
10 Like I recollect Ginna, the simulator they worked 11 on, it behaved quite differently than the plant actually 12 did. Has all this been sort of resolved?
13 MR. GALLO: There are still some problems. But
(~] 14 generically most of the simulators we've used I don't think v
15 we've had any major problems. A few of the old ones like 16 Indian Point II that don't take you nearly far enough in the 17 EOPs, but we haven't had any major problems particularly 18 with the newer simulators.
19 DR. CATTON: Comparisons have been made with 20 something or other to --
21 MR. RUSSELL: That's part of the certification 22 process. And most utilities, even those that bought 23 simulators for the ANS 3.5 standard are finding that it is 24 about a two year plus process to complete that 25 certification, to show that you meet the standards of plus
/*)
t s_
Heritage Reporting Corporation (202) 628-4888
491 1 or minus 2 percent for normal operations and 10 percent for
(/
\.-
T 2 upsets, and alarms come in and parameters turn in the right 3 direction for serious events. And there's integrated 4 testing, group testing, and they have to maintain that 5 configuration. And as they make changes in the plant, 6 change the simulator, and there is a two year cycle for 7 doing that. And that's all part of the ANS 3.5 standard.
8 And I don't bmw what the numbers are now. They have until 9 May of 1991 to complete certification. But there were some 10 carrots that we put in the rulemaking and the major one is 11 if you had a simulator certified and you had an INPO-12 accredited training program you substantially reduced the 13 amount of material you had to present to the NRC as a part 14 of the application. You checked a couple boxes. And you
,' -)g
\
15 need to provide all the description of training programs and 16 other materials.
17 DR. REMICK: I might add something I saw very 18 interesting a few months ago out in Idaho where they have 19 developed a simulator for EBR-II. It's on the EG&G side but 20 they have done it for EBR-II, and where you can basically 21 lie, make a comparison of the reactor response with the 22 simulator response on a screen.
23 And the reason they are doing this, they are 24 slowly losing instrumentation on EBR-II and they want to 25 have e good model for EBR-II that they can trust tha' if
("] Heritage Reporting Corporation
\_/ (202) 628-4888 l
492
/~~ 'i .
(/ 1 they lose that instrumentation that the simulator will be 2 tole to predict what EBR-II is doing. So it is an 3 interesting driving force. But as a result they have 4 developed a technique of on the screen you can compare the 5 predicted versus plant response.
6 DR. CATTON: They can feed that simulator with 7 empirical data directly from the plant. And I just don't 8 know that that's ever been done with these others. There 9 were opportunities like with Summit Scale but it never 10 happened.
11 MR. CARROLL: Well, on a lot of transients, 12 particularly during initial startup testing, and so forth, 13 utilities get the data out as to how the real plant
() 14 performed and then use that to fine tune their simulators.
15 MR. RUSSELL: That is required. They must match 16 within certain tolerances actual plant test data to the 17 simulator.
18 DR. CATTON: But that fine tuning is on one end of 19 the spectrum of things that go on in a plant. There's no 20 two-phase flow, there's no this, there's no bubble in the 21 head, there's none of these things.
22 MR. RUSSELL: They're not intended to simulate 23 accidents.
24 DR. CATTON: That's right. Now, you move over to 25 the accident side is when these simulators begin to come Heritage Reporting Corporation (202) 628-4888
i' 493 l <m
, ) 1 unstuck._ They've always done good for you in that regime.
2 MR. CARROLL: That's correct. You are suggesting 3 somebody --
4 DR. CATTON: No. I'm just asking. Because there 5 were studies made by a number of people. Brookhaven, in 6 particular, they've showed the time rates of pressure decay, 7 this, that and the other, were all quite different.
8 And I don't recollect seeing anything more, at 9 least nothing in the past few years.
10 But I'm glad somebody is doing something to 11 accredit them, the simulators.
12 DR. REMICK: Maybe Paul can get you a copy of the 13 reg guide on the certification.
14 DR. CATTON: I remember the reg guide, but that 15 was supposed to go through 1980 or something.
16 MR. RUSSELL: No, the recent one --
17 DR. CATTON: I haven't seen the recent one.
18 MR. RUSSELL: -- into the certification process.
19 But it does not go into accident space, as you are 20 commenting. And you have to use a plant analyzer or a track 21 or fast track and a super computer to do that in real time, 22 and you just don't do that in a simulator.
23 DR. CATTON: No, you don't. But there are things 24 you could do.
25 MR. GALLO: The next thing I want to mention, in
() Heritage Reporting Corporation (202) 628-4888
3s c
(M ,
-494-
- ['Il .
L'i l '- comparison to replacement exam, the examiners-are spending.
2- more time administering the. exam'than in preparing.for:it.
i f 3 It makesEit'more efficient. >
j.
E4. DR. KERR: What is the replacementiexam?
5~ MR. GALLO: I keepEswitching terminology. Initial;
_6 Lexam and replacement exam is really the same thing.
7 DR. KERR: Requal exam?-
8 MR. GALLO: No. A requal exam is for a licensed'
'r :
9' . operator . - Initial and replacement, we are talking about new.
- 10 operators.
'11 DR. REMICK: Replacing old operators with new .
- 12 operators.
13 DR. KERR: Oh, okay. I thought you were replacing 14 an exam.
- 15 MR. GALLO: No, replacement of the individuals'. . I 16 That'makes us a little more efficient. But I also listed it.
17 on the'next page as the first problem area, the separate
- 18 preparation;and exam weeks on site for a one-week exam,1to-19 do approximatelyLone week on site in preparation and then 20 'one week. examining. So the additional NRC and contractor 21 travel time and out of the office time is taking effect, 72 particularly on the contractors that express some concerns 23 about the'large amount of travel time for requal exam 24 . compared to the past where they were writing a full fledged 25 exam, say spending two or three weeks in the office writing i
~~.
V Heritage Reporting Corporation (202) 628-4888
_ _ _ _ - - _ _ = _ _ _ _ _ _ _ _ - _ _ __
[.'
L 495 I
> I~
ks) 1 the exam and then go to the site to give the exam and then 2 are back in the office rating the exam and writing the next 3 one. ,
4 I think one of these contractor examiners resigned 5 particularly because of this reason, they expressed it in 6 writing.
7 One week for preparation and validation of the 8 exam material could be reduced or eliminated after the 9 initial round of exams.
10 I'm talking about after we get to each facility 11 once hopefully the validation of the exam material by the 12 NRC persons, we may be able to do it strictly in the office, 13 though we may still have to go and do the simulator scenario
( 14 on their simulator, but that could possibly be done the same
- 15. week sa the exam. We'd like to move in that direction.
16 Program pass / fail criteria needed to address 17 licensee examination validation problems.
18 What I'm talking about really is the next bullet, 19 during the pre-exam reviews, the NRC has made substantial 20 comments and done a lot of work on the requal exam content i
21 in order to meet the examiner standard 601.
22 The first round, there seems to be a lack of full 23 understanding of the ES-601 methodology by the licensees.
24 And what we are trying to do in that area, before we do any 25 requal exam in the region, would be hold a meeting with the
/*)
(/ Heritage Reporting Corporation
{
(202) 628-4888 '
i
_______..__.d
496 (9) I training representatives and operations representatives. We 2 have a meeting with some of them tomorrow afternoon.
3 Particularly to go over ES-601 and what we expect them to 4 provide us from the exam material.
5 There have been some case of poor licensee reviews 6 on contractor or inhouse produced material.
7 We've gotten on occasion contractor material 8 delivered directly from ten contractor to the NRC, without 9 much -- for any licensee review we found it to be very poor.
10 I should say at ten opposite end there have been a 11 couple of facilities where we received the material and made 12 essentially no changes, and it was outstanding material.
13 And in those cases it was generally prepared by the
/~*g 14 facilities themselves.
LJ 15 The results. I mentioned this before. There have 16 been 159 exams, and it says 1400, it should be really 1300, 17 for the power reactors.
18 Exam failures have been 27. That is a 17 percent 19 failure rate. There are 10 ROs and 17 SROs who failed. And 20 the exam sections failed are more than 27 because if you 21 fail one section you fail the whole exam. If you fail three 22 sections, you fail the exam. But the written and the 23- simulator sections seem to be the main failure areas. Job 24 performance measures were kind of walked through out in the 25 plant, half outside the control room and half in the control
() Heritage Report ing Corporation (202) (28-4888 i
i
497 j cm
- ()- 1 room. But hands <nt manipulation by the individual being 2 observed by individuals.
l 3 DR. REMICK: Were those mostly people that were 4 engineering staff or somebody that had SRO license and 5 weren't heavily involved in the plant operation?
6 MR. GALLO: At some facilities that's been the 7 case. The staff people have been weaker. At other 8 facilities the staff people hava been equal to or at least 9 as good as the shift workers.
10 At Nine Mile Point there were a couple of staff 11 people that failed but there were also a couple of shift 12 SROs who failed.
13 At Indian Point II the only two failures were 14 staff people.
}
15 At Ginna there were the two senior operators on 16 the shift both failed the exam. And I think there was one 17 other SRO.
18 So it's been not necessarily distinguishable by 19 staff people. It's not really clear. At some facilities it 20 is. But at Ginna the biggest problem we had was that 21 everybody in one crew failed. They had all worked together 22 as a crew and all four individuals failed, individually all 23 failed and they all failed as a crow, too.
24 The programs evaluated so far in Region I have 25 been 11 evaluated, two unsatisfactory programs.
7.s
(' ,) Heritage Reporting Corporation (202) 628-4888
498
' 4 1 We have two more to do this year, Indian Point III 2 and Millstone III.
3 DR. REMICK: Fiscal year you are talking about?
4 MR. GALLO: That's fiscal year. Yes, sir. We 5 have probably about 24, 25 scheduled for next year. We're 6 trying to become a little more efficient also, we're going 7 to try to do two weeks of requal exams back to back to we'll 8 get 12 people one week and 12 people the next week. Some 9 facilities such as Yankee only have 30 operators. We did 12 ,
10 there and that's 40 percent of the staff. We don't need to 11 go back there. But other places like Calvert Cliffs have 12 about 70 operators and somebody else has 70. There aren't 13 many of those unit facilities in Region I. That's going to (N _j 14 cause us a little bit of a problem, because we've got common 15 sites but not common facilities, like Millstone, three 16 units, three different types of plants and three different 17 requal programs and that's three times the work, not one 18 third the work.
19 okay. The next section is the national theory 20 exam. I believe Rich Conte was going to address that, 21 unless there are some more questions on requal exams. There 22 is a SECY paper about to be signed out on requal exam 23 resulta nationwide. I think it's a quarterly report.
24 DR. REMICK: Thank you very much.
25 MR. GALLO: Pardon me, Rich, come on up. While
,~
k- Heritage Reporting Corporation (202) 628-4R88 l-I f
l
r c i;;
499
- f'& . . .
Os /l l< we're talking.about the national theory exam, the generic-2 fundamentals, is part of the initial replacement exam. .The 3 written exam has alwa(s been site specific. In the last 4 year we've done two generic fundamental exams and that's in 5 section 1 of that exam. So if a person passes that section' 6 they don't have to take the section 2.
- 7. MR. CONTE: Good afternoon. 'I'm Rich Conte. I'm 8 Chief of the Boiling Water Reactor Section, Oivision of
.9 Reactor Safety.
10 I've been with the region since 1976.- I just came 11 back into.the: region as Senior Resident from TMI-I.
'12- Real briefly, the generic fundamentals exam has-13 been successful as a pilot program. To us it represents i() 14 savings in resources. Primarily the replacement exam is 15 . composed of three parts, a theory section, system section 16' and a procedures, events, plant operations section.
17 The parts are not'of equal percentage. The theory 18 section for the RO, SRO are generally about 25 percent. So 19 it represents about 25 percent of the point value that we 20 don't have to give anymore.
21 This program is being instituted for this upcoming 12:2 fiscal year. The first of a series of three exams for the 23- next fiscal year will be October 4 and February and June
.24- subsequently.
25 Basically the region will support that exam I Heritage Reporting Corporation (202) 628-4888
v: -
h
. .. 500 A L 1 providing facility in this very room. We can accommodate i-2 about 80 candidates using an A and B sequence of exams.
3- It is a standardized. test on common knowledge 4~ related to.the theory of nuclear power operations.
5 Primarily tha plant type. In the morning we'll give the 6 boiling water reactor exam,.in the afternoon the precagrized 7 type.
8 I think for some unique theory aspects such as for
,9 .a B&W plant and once through steam generator concept, I 10 think that could still be handled. That is not addressed in 11 the fundamentals exam but it could still be handled using 12 the site-specific examination, which is really those other 13 two sections, the system and the procedures section.
O' f( / 14 How happy are you with the multiple DR. REMICK:
15 choice questions? Does this actually explore the depth of 16 knowledge of the theory?
17 MR. CONTE: Well, if you poll the examiners in 18 this region I think maybe a majority of them may say they 19 are not happy with them. Multiple choice is harder to 20 produce. The impetus there is to come up with objective 21 type questions, multiple choice or matching or fill-in, fill 22 in the blank, rather than short answer. It's a lot easier 23 to write a short answer in the upfront but experience I 24 guess has shown that in the back portion of that, the 25 grading exercise, you may get all sorts of acceptable
/}~
- v. Heritage Reporting Corporation (202) 628-4888 L-_ _ _ _ _ _ - __ -
~
501
,rs
' _)
s 1 answers compared to the answer key.
2 And so the shift by policy is to go to about 75 3 percent of the objective type question, the matching, 4 multiple choice, fill-in. We still 2.cve the option of 5 inserting about 25, up to 25 percent short answer in this 6 next fiscal year by NRR policy.
7 DR. KERR: Are the exams given open book or closed 8 book?
9 MR. CONTE: The generic fundamentals is closed 10 book. There is some reference material such as steam 11 tables. Some basic formulas are given in ten exam itself, 12 in the generic fundamentals exam.
13 MR. RUSSELL: The requal exam, there is a
() 14 simulator portion that's written and there is an open book 15 portion where they have all the same reference materials 16 they would have available to them in the control room. So 17 that written that we talked about in the previous 18 presentation is a combination of open book. It's not from 19 memory.
20 MR. CONTE: Once again, the pass / fail -- I'm 21 sorry, resources, I think I've already emphasize that. Our 22 interest is the savings in resources. We'd rather put up 23 with three times a year setup of facilities here rather than 24 for each candidate having to come up with a theory section 25 of the replacement exam.
rw
(,) Heritage Reporting Corporation (202) 628-4888 l
502
() 1 The trading on the generic fundamentals is 2 numerical. It is a 70 percent criteria. But basically what 3 the candidates will get is a pass / fail result. It will not 4 be a numerical score.
5 The rest of the exam, which we are now calling the 6 site specific exam, the other two sections, we are getting 7 guidance from Headquarters, which we Lre working on at this 8 point, that it will really become one exam and lose its 9 identity of two individual sections with a pass criteria in j 10 each section of 70 percent and an overall pass of 80 11 percent.
12 That site-specific exam will now have only one 13 criterion, and that is passing of 80 percent. There will no
" ~ '
14 longer be an individual passing of 70 percent.
}
15 So fundamentals exam criteria will be at 70 16 percent. The site specific overall or cumulative is 80 17 percent.
18 And that's about it. The pilot program has proved 19 to be successful. It's been a fairly good pass rate. We 20 are putting some restrictions on the candidates who sit for 21 that exam. The facilities will have to certify that they 22 have been trained to the fundamentals theory and that they 23 are active participants in a training program.
24 So in other wordis, this exam will not be a 25 screening criteria for lice;nsees to put up people and say t() Heritage Reporting Corporation (202) 628-4888
503 V
(")
'\ '- ~
I well, if he makes he makes it and if he doesn't then he's 2 eliminated.
3 Obviously, it will save us resources, in terms of 4 grading and handling this, processing this particular 5 candidate.
6 Are there any questions?
7 MR. CARROLL: On this exam you have a question 8 bank so you can change the exam every time?
9 MR. CONTE: Yes. We have access to the national 10 exam bank and utility material, and anything is fair game, 11 basically.
12 DR. KERR: An alternative to that that we use at 13 universities is to keep the same exam and change the 14 answers.
15 (Laughter) 16 MR. CARROLL: One issue that has always bothered 17 me, and that is, there are people in this world that are 18 damn competent operators that are not very good written exam 19 takers. Or at least they take a long time to get through a 20 written exam.
21 And I guess the last time I talked about this was 22 down in Region IV. I guess the plant specific exam is still 23 a timed exam.
24 MR. CONTE: Yes. It will be no more than four and 25 a half Iaours.
(j' Heritage Reporting Corporation (202) 628-4888 I
i
504 i d
1 MR. CARROLL: I was told that at least some h.s .-
2 thought was being given to making it unlimited time. 'That 3 hasn't happened?
4 MR. GALLO: We're not planning that'right now. We 5 split the generic fundamentals exam. That is going to be 5 one time period. People have not-had a problem with taking i 7 that generic fundamentals exam as far as timing. The rest 8 of the exam is going to be, it used to be six hours when we 9 had the fundamentals in. Now it could be four and a half 10 hours for the site specific.
11 MR. CARROLL: Do some of the training' managers 12 have a problem with that? Is that a common complaint?
13 MR. GALLO: No, it's not a common complaint.
.14 There have been a few people on specific exams who haven't 15 been able to finish. I would say that is a very small 16 minority, maybe 5 percent range, that cannot finish the 17 exam.
18 MR. CARROLL: You may be excluding some good 19 operators.
20 MR. GALLO: In the future the exam, one of the 21 things we're going to that Rich has mentioned, is that 75 22 percent of the questions will be objective type questions 23 and I think you could answer those a lot more quickly than, 24 at least you can put down an answer. It may not be the 25 right answer.
Heritage Reporting Corporation
]) (202) 628-4888
i.
505
() 1 MR. CARROLL: As opposed to organizing your 2 thoughts to create an essay.
3 MR. GALLO: To create a paragraph, to write about 4 something.
5 DR. REMICK: Jay, you remind me of something. The 6 other is true, too.
7 I remember, I was a consultant conducting an 8 operational QA audit at an unnamed plant, and happened to be 9 going over requal exams and looking at them. And I was 10 impressed. One person passed the requal exam with a 97 11 percent. I was very favorably impressed. And lo and behold 12 the next day when I was in the control room I met a person 13 and the name sounded familiar.
14 And I finally put the name together with the 97
}
15 percent. But when I asked him if he could explain to me how 16 the plant was lined up in the outside world at that time he 17 couldn't do that.
18 And then later on, when he was telling me how the 19 diesel generators would start automatically, and I said but 20 if they didn't start from the control room what would you 21 do? And he did not know that you could go out in the diesel 22 generator room and start them, too.
23 So there are people who do very well on written 24 exams --
25 MR. CARROLL: I know that.
() Heritage Reporting Corporation (202) 628-4888 l
h-
.506 7%,
TsI 1- DR.'REMICK: -- that don't know the plant very 2 well.
3 MR. CARROLL: I know that. But I guess I've met a 4 few guys that don't have a lot of education that are;just 5 ' good, intuitive operators, that have an awful hard time with 6 the timed written exam.
7 MR. GALLO: We'd like to make sure they can read 8 the EOPs and tech specs and other normal procedures.
9 HR. CARROLL: That's true.
10 MR. GALLO: I'd like to go on to the next section.
11 The next section, I will ask Mr. Pete Eselgroth, who is also 12 the section chief, and one of your agenda items is to talk 13 sbout maintaining consistency of operator exams among the 14 regions.
15 MR.-ESELGROTH: I am the Chief of the PWR Section 16 of the Division of Reacto" Safety. I have been with the NRC 17 .about five years. Before this I've been Chief of the Test 18 Prograds and before that I was Senior Resident Inspector.
19 Prior to that I spent four years with UNC Nuclear industries 20 at the end reactor at Hanford as a program manager in 21 operations as well as training and before that about 11 22 years with the Naval reactors staff, the last three of which 23 were the Manager of Operations out at the Idaho Naval 24 reactors facility.
25 This section addresses consistency of exams
~
l ) Heritage Reporting Corporation (202) 628-4888
507-
' (_) 1 between regions which we hold to be important, so that we 2 come across to the industry as one agency and not many 3 agencies.
4 And I will talk about the elements of th? program 5 which I think help us drive towards and maintain that 6 consistency.
7 First of course is the examiner standards. And 8 they are standard throughout the country. They are of 9 course evolving, but the evolve at the same time in each 10 region.
11 The operator licensing branch training program is 12 a centralized training program so all of the new people to 13 each of the regions are receiving the same instruction.
7"~T 14 I would have to say this was not always the case.
()
15 So we can look upon this as something which is further 16 driving consistency, making us more consistent than we have 17 been in the past.
18 The key training programs there of course, there 19 is one on written exams and there is a set which is a week 20 long and there is a separate one that is two weeks long 21 which is addressing simulator and plant walkthrough. 1 22 We also have inter-region examiner training which 23 really means that when we have new people during the year 24 that they are certifving they do also visit other regions 25 and that cross pollicization helps to level out
() Heritage Reporting Corporation (202) 628-4888
._-______-______a
l 508
- . () l' inconsistencies.
2 We also have the annual audits which are done by 3 the operator licensing branch of each region. And we are 4 particularly interested in their being consistency, so where 5 they see inconsistencies they highlight those. Also they 6 include on the teams individuals from the other offices 7 which also helps with regard to consistency.
8 And during the past year or so there has been a 9 weekly conference call that has been implemented. Once a 10 week all the regions are on the phone with Headquarters, 11 talking about current issues, exchanging ideas on p:coblems 12 and talking about new initiatives and different ways of 13 doing things.
() 14 I would saf when I first got involved in this 15 area, this conference call did not exist and I think the 16 presence of the conference call is a very important facter 17 in consistency.
18 Next slide.
19 Just going briefly into the written and the 20 operating test, things that drive consistency.
21 The same vehicle that we have for striving for 22 content valid questions, which is really the knowledge and 23 ability catslog, it being common among the regions also 24 serves as a vehicle for consistency.
25 The various questions types that you are familiar
.A.
.i) _
Heritage Reporting Corporation (202) 628-4888
509 l[ 1 with basically boil down to memory, comprehension,' synthesis 2' or analysis.
, 3 We are always striving where possible to have 4 questions which are of the synthesis and analysis type, 5 recognizing that all. questions have some memory' involved in 6 them, but we are striving to not have memory-only type
- 7. questions.
8 And as Bob had mentioned we are going to be going 9 to starting the new fiscal year criteria of baving 75 10 percent of the - quote ungt ote " objective" which are the 11 multiple choice, fill-in and matching. And as far as 12 consistency concerns, the one thing that does is get away 13 from the subjectivity that goes along with the grading of 14 the short answer questions.
15 Lastly on here within the last year approximately 16 the operator, or operational part of the exam on the 17 simulator has had some more structure added to it in terms 18 of what are called rating factors, and associated with 19 those, human factors people have felt were called behavioral 20 anchors. And those are all spelled out. They weren't in 21 the past. And they are equated to a numerical system for 22 coming up with an answer.
23 You certainly never totally eliminate the 24 subjectivity. Subjectivity is closely linked with judgment.
25 ' It's not eliminated by any means. But this structure, this
() Heritage Reporting Corporation (202) 628-4888
U l
510 c(l 1 matrix approach does give us a more consistent way I think
\_/
2 of doing the grading.
3 So this is another step, an important one, that 4 has been taken in the direction of consistency.
5 That's the last slide I have. Any questions 6 concerning that? 4 7- DR. REMICK: Do you still hold the annual license 8 examiner conference?
9 MR. ESELGROTH: Yes.
10 DR. REMICK: At one time they used to have an exam 11 that all the examiners graded to see consistency on grading.
12 Do they still go through those exercises?
13 MR. ESELGROTH: No, not recently. And the annual fg 14 conference is another factor. Like we have the weekly V 15 conference calls that are I think much more plugged into one 16 another than we have in the past, and I think we are much 17 less reliant upon the annual conference for consistency than 18 we have been in the past. But it is still a useful 19 function.
20 DR. REMICK: Thank you.
21 MR. GALLO: Thank you. That's all we have on 22 operator licensing. Are there any other questions?
23 DR. REMICK: There is one. You probably know that 24 the ACRS has taken the position several times that it could 25 see no technical basis for degrees for all senior reactor
(~ Heritage Reporting Corporation
\ (202) 628-4888
y e $-
p 511
,q
, V_ 1 operators.
2- I was wondering either from'a regional ~ perspective 3 or your personal perspective do you feel the ACRS was wrong, 4 or do you agree or have some other view on that?
5 MR. GALLO: The one good data point that I think 6- exists is the Peach Bottom rearrangement or realignment of 7 'their shift operating crews where they put a shift manager 8 on watch instead of what they used to call a shift i
9 superintendent.
10 The shift manager is a degreed licensed operator.
.11 I think that has done quite well at Peach Bottom. And of l 12 course they were pretty low on the totem pole of course when 13 they were shut down by the order, and they needed something l
. <>4 !
() 14 along the shift nanager concept to really help bring them 15 back up to standards. !
16 But that is really a particularly good result of ;
17 having a licensed degree operator on shift, with noticeably 18 better performance than their predecessors.
I 19 DR. REMICK: Do you feel that is better than all 20 SROs having degrees? ;
, 21 MR. GALLO: I do. Yes, I do. I think if we go in 22 any direction I'd like to see us have licensed operator, at 23 least one licensed operator on shift with a degree. Whether 24 he's the STA or not would be an option of course.
25 DR. REMICK: We found it interesting that in Heritage Reporting Corporation (202) 628-4888 a _- _ _ _ _ _ - _ _ _ -
L. 1 V -
k 512 w
[
{ 1. ; Limerick II they did not follow that same --
2 MR..GALLO: Limerick has not dope.that. There are-
.3 some other facilities that are going to STA, licensed STA on- )
i L 4 shift. And one of those of course is Nine Mile II where we 5 once had a requal program. They've implemented that lo:
L* 6 concept. So.there's some good news and there's some bad
'7 news.
' 8. DR.'REMICK: Any words of wisdom on that, Bill?
'9 MR. RUSSELL: It's an issue that you and I have 10' ' discussed many times.
11 My view was that progress was being made under the 12 policy statement. I understood the pros and cons of it. I 13 think what type of-degree the person has could also be p.g 14 significant. And it is the issue of education and
\d 15 demonstrating ability to get through that process, and 16- whether the person has the ability to aspire to higher 17 levels in the organization.
18 I think that the position that came out is the 19 best one. I think there were strong views on both sides.
20 But in fact since the policy statement has been around, 21 there has been an increase in the number of senior reactor 4 22 operators that have licenses, and we looked at the 23 statistics from about 1980 on and they increased from in the 24 low teens to in excess of about 30 percent that actually had
~
25 degrees.
Heritage Reporting Corporation f~T x/ (202) 628-4888
N l L l 513 I em 4
(_) 1 So the industry is moving in that direction. I l I
2 think that the shift manager concept is a valuable one. I 3- think that the number of activities that go on on shift and 1
4 managing those activities, particularly during outages or 5 other times, particularly two units, with one unit operating 6 and one unit in an outage, and on backshifts, and how that 7 is handled, and the training that is obtained and the 8 experience obtained during that period of time is valuable 9 for the organization and provides a career path for ops 10 managers and ultimately senior executives.
11 So I'm in favor of it. I don't think it has to be 12 for everyone. I think the position we came out with 13 ultimately is the right one.
,(} 14 DR. REMICK: Any other questions or comments on 15 operator licenses?
16 MR. CARROLL: A few people on ACRS even agreed to 17 it without additional comments.
18 DR. REMICK: Yes, Bill.
19 DR. KERR: Are you happy with the present 20 examination in the sense that you think it takes care of 21 most of those things that need to be taken care of in 22 choosing qualified operators?
23 MR. RUSSELL: I think the examination is much more 24 performance based and it is, and you are able to show a
.25 relationship between what an individual is required to do,
() Heritage Reporting Corporation (202) 628-4888 .
514 R : p%,^
1 and,know,fand his abilities for performing'the job, and the-2 examination.
3 I'm hoping someday we will actually have a.
4 candidate who faile an exam who agrees that yes, that wac:
5 .the right stuff I was supposed to know to do the job. But 6 I'm not sure we're there yet. But I think it is getting 7 much better and with time I think it has improved and 8 Amproved significantly. It's a better measure of the 9 ability to perform on the job.
10 DR. KERR: I was thinking partly of the problem
.11 that existed at Peach Bottom where presumably ~a great. deal 12 had to do with operator attitude. And it was my impression
, 13 indeed, and I may be wrong about this, that before
) 14 permitting operators who had been there to continue, some 15 effort was made to do psychological testing or psychological 16 analysis of some kind.
17 HR.-RUSSELL: There was a major retraining program 18 to address that and we were not talking about technical 19 skills or abilities or the knowledge of what they should be 20 doing. It was'the desire on their part to do that.
21 DR. KERR: I recognize that. And both of course 22 are important. And that is what I wondered about. Do you 23 think the existing operator exam picks out people who have 24 the appropriate attitude? Because if it doesn't, there may 25 be a number.of other operators out there somewhere that are Heritage Reporting Corporation (202) 628-4888
= - _ - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _ -
p t-515
, f~') I potentially in the same boat as the people at Peach Bottom.
v 2 HR. RUSSELL: That is the whole concept of 3 professionalism and safety culture and it needs to flow from 4 the top of the organization right on down. And if the 5 person does not have that appropriate attitude or character 6 I would hope that the licensee process would screen them !
7 out. We're sensitive to that. We watch for it. And we 8 don't test that through our examining' process.
9 Although I must admit, the Ginna experience with 10 the one crew that failed badly was in the opinion of the 11 examiners some elements of that related to the attitudes and 12 the ability of the shift supervisor who subsequently left 13 the company.
14 DR. KERR: I certainly don't pretend that I have l
15 any idea how to do the sort of testing that might,'if there 16 is such a kind of testing, but it would seem to me that at 17 least on a longterm basis, you would want to be giving some 18 thought" to possibilities that might exist.
19 MR. GALLO: I would make one comment. On requal 20 exams particularly I'm very sensitive, if I hear anybody 21 that has expressed to me that the feedback is that that guy 22 has a bad attitude, we ought to do something about it, if he 23 passes or fails. If he fails, maybe that's what he should 24 have done. If he passes it's a more difficult situation.
25 DR. KERR: I would not expect existing exams to be Heritage Reporting Corporation
/^)
\~ (202) 628-4888
516
['l 1 able to screen on that basis. And as I said, perhaps there
%)
2 isn't any exam that '
3 MR. RUSSELL: Sometimes the interpersonal skills 4 that eccur between the examiner and the candidate and the 5 comments that are made in the course of an examination 6 identify what I will call attitude attacks on the part of 7 the individuals and some of that comes through. We're 8 sensitive to that. I think facility examiners are sensitive 9 to that. And I would hope that company management is also 10 sensitive to it.
11 Tha situation existed for a long time up at Nine 12 Mile Unit I and there were a few vocal individuals who were 13 driving the issue and becoming negative role models. And it
,e-3 14 took some time to get control of that. And manager. at was
'w) 15 not forceful, even though some levels of management wo.re 16 aware it was going on. And that is rat'.ier well described in 17 the special inspection because there were actually cases of 18 disruptive behavior and unprofessional behsvior that 19 occurred while NRC was present and watching it. And we*
20 promptly brought that to the aV:ention of senior management 21 and it had a history of going on and being tolerated.
22 DR. REMICK: Between training and operations.
23 MR. RUSSELL: Yes, sir.
24 We have a number of other items on the agenda.
25 DR. REMICK: And I think we are at a point where I
(% Heritage Reporting Corporation
\- (202) 628-4888 1
w.
v 517 l yk_), ' l. will'ask the subcommittee, we have the topic of radiological
~ l l '2 controls, Item Number 12, and emergency planning, Number 15. d l- '
3 What is your preference? We have'just an hour left.
4 DR. CATTON: Emergency. planning.
5 DR. REMICK: Emergency planning is suggested.
l6 .Anybody differ with that?
7- MR. RUSSELL: There is the on6 unique program that 8' was under the radiological controls which links to the TLD 9 program and you had a number of questions on QA and'what the 10- QA program is that we apply in that area. You may be 11 interested in hearing that piece.
12 MR. KNAPP: I have a suggestion you might want to 13 consider.
14 DR. REMICK: All right.
15 MR. KNAPP: In light of our understanding that the 16 schedule would be compressed, we have compressed the talks, 17 and we could give you approximately 30 minutes on 18 radiological controls with time for questions and answers 19 and about 30 minutes on emergency preparedness, if you would
'20 like us to do that.
21 DR. REMICK: What's your pleasure? All right.
22 Let's split it. I'll be tough on that 30 minutes. All 23 right?
24 MR. KNAPP: All right. Ron, would you like to 25 come up so that you can lead off?
I )I Heritage Reporting (202) 628-4888 Corporation
518
() 1 We're going to start with our radiological 2 controls. And we are gong to split the radiological 3 controls further into two areas: facilities radiation 4 protection and effluents protection. And we are going to 5 start off with facilities work with Ron Nimitz. And I 6 think he can accept you being tough. In his case now we're 7 lowr. to about 15 minutes.
8 MR. NIMITZ: My name is Ron N3mitz. And what I am 9 going to do is give a few minute overview on what the 10 radiological controls group does here in Region I.
11 Basically the group, ten Facilities Radiation 12 Protection Section is in the Division of Radiation Safety 13 and Safeguards.
14 And the basic function of our Reactor Health
(-)
%s 15 Physics Group, which is a Facilities Radiation Protection 16 group is to inspect and oversee applied operational 17 radiation safety programs at power reactors.
18 We also work with research and test reactors and 19 fuel fabrication facilities.
20 It is really inplant, ongoing radiological 21 activities that we look at.
22 We also in the area of research and test reactors 23 and fuel fabrication facilities look at environmental 24 monitoring, rad waste transportation, and effluent 25 monitoring and control.
(~} Heritage Reporting Corporation j ks (202) 628-4888
_ _ _ _ _ _ _ _ _ i
u . ..
519 N
~N,(~/Y 1- We also' examine control room bebitability aspects..
k l2 We look at. post-accident sampling. And we-get extensively.
i 3.- involved in supporting other elements of the region 4 emergency planning and supporting.them.
5 lAs far as our' reactor health physics. areas, 1
6 basically we visit the plants onlthe average ofgtwo or three
-7 times-a year and we'll visit the-plants more often in 8 response to'any incidents or events or any special 9 directions from the SALP Board, or any Regional-10 Administrator-requested initiatives.
11 lAs far as'the areas we look at, we look at 12 staffing, organization staffing; we look'at selection, 13 qualification and training of personnel; we focus heavily.on-l ) 14' audits,: assessments, surveillance and problem' resolution; .
a 15 and internal and external exposure controls; rad material 16 and contaminated material control; and outage planning,
~
17 preparation and control; and also ALARA.
18 One of the things that-the group tries to d', is to 19 perform performance based audits and reviews. We try to
.20 look at things actually in a performance based manner and 21 see what is going on at the time and try and actually
~
22 oversee ongoing work activities.
23 We focus very heavily on the licensees' 124 capabilities in the area of audits, assessments, .
25 surveillance and problem resolution.
Heritage. Reporting Corporation (202) 628-4888-
L
( 520
, \_/ 1 We try to have the licensee identify their own 2 problems and get them corrected.
3 A major area that we look at is outage planning 4 and preparation.
5 During outages, a radiation protection group at a 6 reactor can quadruple in size going from 30, 40 individuals, 7 up to close to 2-300 people on site just to support 8 radiation protection.
9 So we look heavily at the staffing, selectito, 10 qualification and trr.laing of those personnel and the 11 overall outage planning and management.
12 And really, we do a lot of independent 13 measurements. We look at internal exposure controls. We
() 14 have phantoms that we use to test the licensees' 15 capabilities, we look at the TLD and external monitoring 16 program, instrument calibration, basically anything that the 17 licensee does in the area of radiation protection and 18 control we look at and try and provide our own independent 19 measurements and assessments of their capability.
20 This area is a big part in the SALP assessment so 21 when we are finishing our inspections and assessments we 22 provide a significant input to the SALP.
23 That is all I wanted to say, in order to keep the 24 time moving, this is a?.1 I wanted to say on what wa did, 25 what kinds of things we did. ,
(,)
(~%
Heritage Reporting Corporation (202) 628-4888
521 l'l 1 MR. CARROLL: One subject of current ACRS interest LJ 2' is the-hot particle issue.
3 Are you aware of ACRS's letter to the Commission 4 on that? Do you generally agree with the position we took?'
5 MR. NIMITZ: I was at the ACRS meeting and gave a 6 little presentation.
7 MR. CARROLL: I remember.
8 MR. NIMITZ: We really disagree with, at least 9 from the regional perspective, we disagree with that and we 10 have made some comments and there has been some additional 11 discussion with NUMARC through NRR in terms of disagreements 12 on fact and instancas of hot particle control.
13 MR. CARROLL: Our recommendation basically was
- 14 that the NRC, whatever that is, ought to get their act k,
15 together and let NCRP finalize their report and then issue 16 an interim standard based on NCRP, not based on what the 17 staff thinks is appropriate.
18 MR. NIMITZ: Oh. The NRC as a whole really had 19 similar conclusions, but there were disagreements with the 20 NCRP.
21 .The NRC, within the NRC, agreed that we needed 22 some more information, and that is why there was a contract' 23 let with Brookhaven to try and get some more information 24 from NCRP to support some of the conclusions and 25 recommendations.
i
Heritage Reporting Corporation k'--)N (202) 628-4888 l
i 522
(~)
11 1 The original draft 101 standard was really, didn't 2 have sufficient information to support the basis, and the 3 recommendations they were making in the report. That was 4 our major problum, was ws could not support their 5 recommendations. The dat a wasn't there to support it.
6 DR. KERR: Excuse me. In the qualification and 7 training how much weight if any do you give to certification 8 by I guess it's the Health Physics Society that cercifies 9 health physicists?
10 MR. NIMITZ: Really the only, in terms of training 11 and qualification, we allow some credit for years of 12 experience for a radiation protection manager.
13 However, the current qualification standards,
() 14 which is basically ANSI 18-1 and ANSI ANS 3.1, for the 15 majority of the people within the radiation protection 16 group, there is limited credit given for training and 17 qualification, because, particularly in the operational end 18 where you need the actual experience to understand what is 19 going on, to have worked in the plants and understand the 20 problems.
21 On the technical support end though, the ANSI 22 standards do allow credit for education to be qualified.
23 But just on the technical support end, not the operational 24 line organization that actually oversees ongoing inplant 25 activities.
(7 k/ Heritage Reporting Corporation (202) 628-4888
523 l(~'(f k,/ l' DR. KERR:. I think the answer to my. question'is i
2 none, isn't it?
3 MR. NIMITZ: -Very little. Very little, with the 4 exception of the RPM and some technical support personnel.
5 DR. KERR: Thank you.
6 MR. WARD: Ron, let me ask a question about ALARA.
7 I've recently heard that, at a meeting, that some licensees 8 are spending on some activities what amounts to about 9 $35,000 to reduce one man rem which is considerably in-10 excess of $1,000 a man rem which is often used for a, has 11 been used in at least some studies, as an expression of what 12 reasonable means.
13- Are you aware of any numbers like that? Is the
() 14 NRC forcing utilities into this?
15 ER. RUSSELL: Dave is that in 1975 dollars or 1988 16 dollars, 1989 dollars?
17' MR. WARD: Good question.
18 MR. NIMITZ: With the exception of the $1,000 that 19 is in Appendix I, we are not really imposing or forcing 20 licensees into any fixed number. In my experience in the 21 industry it ranges from like $1,000 to $10-20 thousand. A 22 lot of it has to do with management's willingness and 23 efforts, self initiated efforts to reduce exposure. Some, 24 SALP Category 1 facilities have spent substantial amounts to
, 25 reduce, to same a man rem or a person rem.
(- Heritage Reporting Corporation (202) 628-4888
_____L'____________________
? 4, p.s. .
524
'1~ MR. MARD:; Is that good? I mean to get a SALP 1
- 2. do:you have to spend $35,000 to reduce a man rem?
3 MR. NIMITZ: We weren't implying that. I'm just
~4 saying that some licensees are willing to do that and they 94 5' do this on their own initiatives. Other licensees, based on 6 their cost benefit analysis,-they feel it,is reasonable to 7 just' spend this, spend $1,000 or $2,000.
8 So there is nothing that we use as sort of
- 9 criteria that says if this guy spends $30,000 he's SALP 1.
10 We don't do that. We look at the aggregate exposure and how 11 much they are doing and what is current standard-industry 12 practice for reducing exposure.
o 13' MR. WARD: What does ALARA mean to you?
14- MR. NIMITZ: I can get into my next slide.here,.
q F: 15 which should help us on that.
16 MR. WARD: I don't mean programmatically. I mean 17, conceptually what does ALARA mean to you?
18 MR. NIMITZ: It is trying to reduce exposure in a 19 cost beneficial manner. And how can one -- it is really, it 20 is somewhat objective, or subjective, in that you have to 21 look at each situation and try'and figure out what is the 22 best way to reduce exposure.
- 23 For example, plant decontamination. You can set.
24 up all kinds of decontamination facilities and systemts to 25 decontaminate a plant. But you will sustain more exposure Heritage Reporting Corporation
( )-
(202) 628-4888 j
L m._ __ _ _ _ _ . _. _ _ _ . _ _ . _ . _ _ _ _ _ .
[N. 525 g' . .
zr~) -'
putting the equipment:in and setting-up than you would if V
?
2 2 you'just allow the job to go.
3 So there is a cost benefit to ALARA.- It's what 4 .you need to do to reduce the exposure.
p 5 DR. KERR: So to you ALARA means that they are 6 trying to do something?
7 MR. NIMITZ: They are trying to reduce the 8 exposure consistent with good practices.
9 DR. KERR: One, it seems to me, could obtain am as 10 low'as reasonable achievable status without trying to reduce 11 exposure. If you have reached something that is as low as 12 reasonable achievable, you don't have to reduce any more to 13 be as low as reasonably achievable. Unless ALARA means 14 something else to you.
15 MR. RUSSELL: I think that this is an area 16 probably where the INFO. initiatives and the tracking of 17 total man rem exposure and some of their commitments, as 18 visible as it is made, is having an influence on how 19 utilities are responding and the senior levels of management 20 responding to ALARA issues. They have a very aggressive 21 program.
22 We look at how utilities set goals, we're 23 interested in how they conduct jobs and how they control 24 exposure to their workers. And in some case big jobs are 25 exceptionally well planned and routine jobs are not, and you 1
S Heritage Reporting Corporation (202) 628-4888
526
\- 1 pick up more exposure on routine jobs.
2 So it's a broad spectrum. It's more a concept of 3 both planning for the job and then the attitude of the 4 worker that's conducting it to keep his own personal 5 exposure as low as he can in conducting the job, and 6 training for it and doing it right the first time. You'd 7 almost double your exposure if you had to double and do the 8 job again.
9 MR. CAPHOLL: I guess my perspective is I don't 10 like our terminology we've adopted in the United States. I 11 think the foreign terminology of exposure optimization is a 12 heck of a lot better than ALARA.
13 MR. NIMITZ: It's interesting that a number of
() 14 licensees have obtained and are utilizing the Nordic report, 15 that 86 Nordic report on optimization, and a number of 16 facilities in Region I are looking at what they call the 17 DRAs, the dose reduction' actions, to try and optimize 18 exposure.
19 And they are using these kinds of, these, 20 principally focusing on source term control and reduction, 21 reducing the amount of cobalt in the facility if they have 22 to replace a valve or repack a valve, they look at trying to 23 reduce the overall source term. Worker awareness and 24 involvement. A lot of licensees are getting, instead of 25 having workers perform jobs in 200 MR per RPO, they move the rm
(-) - Heritage Reporting Corporation (202) 628-4888
y, I
I'f .
'527~
'1' equipment and'everything is moved.. ALARA goals and-2; objectives:are looked.at~and are used to try.and gauge where 3 they are within the' industry.
4 Two p1 ants, one p1 ant can be a high person rem 5 plant and,the other one can be low doing the same work.
6 Something must, there must be something wrong or something,.
7 someone must be doing something right and someone wrong.
-8 So we compare and look at similar facilities
- 9. performing similar work activities to try and understand the 10 difference in exposures.
11 We look to see if there is something that a 12 licensee can reasonably do to reduce the exposure.to ALARA.
13 Performance monitoring and we look at program O 14 estah11shment and img1ementation.
15 What we are finding is overall exposure is coming
-l'6 down and the thing that is really, the last couple things 17 'that are rea11y, licensees are working on is the source term 18 control and reduction to try and get a handle on that. That-19 is what is causing the exposure, that and training the 20 workers, worker awareness involvement.
21 This is another major aspect that we look at in 22 our group. We try and look at it in a reasonable manner, 23 not impose unwarranted sanctions on licensees.
24 MR. CARROLL: Another way to reduce exposure would-25 be getting a timely. resolution of the hot particle problem.
O- Heritage Reporting Corporation (202) 628-4888 1 1
t 528~
/3 kl l' MR. NIMITZ: 'Well, again, I don't'want to belabor 2 the hot particle' thing. But --
- 3 MR. WARD: Mr. Carroll does.
4 MR. NIMITZ: It's not -- I think some of the 5 information that was presented at the ACRS meeting is not
- 6 consistent with what'the NRC understands, actually having 7 been at the facilities.
8 And we have had separate meetings with NUMARC
'9 after that ACRS meeting to discuss those differences.
10 MR.. CARROLL: I'm quite aware of that. There is a 11 real exposure problem in some plants.
12 DR. REMICK: I think we better move on.
13 MR. NIMITZ: That's really it in terms of rad
) 14 controls.
15 MR. KNAPP: We will now hear frem Bob Bores with 16 respect to effluents.
17 MR. BORES: Let me just indicate that the 18 Effluents Radiation Protection Section has a number of 19 inspection programs. I have a slide, but in the interest of 20 time I am not going to put it up, in terms of the inspection 21 programs.
22 Yesterday we heard from Jerry Roth relative to the 23 facilities, fuel facilities, that is part of this section.
24 Our section also takes a look at the gaseous and 125 liquid effluents through process monitors, and calibrations
(.
Heritage Reporting Corporation (202) 628-4888
529
[~)-
v 1 'thereof.
2 We have the waste treatment systems, the 3 solidification systems that we review, the transportation of 4 radioactive waste. And we also do what is called 5 confirmatory measurements, that is, the radiological l
6 measuren. cats , at the facilities.
7 And we have a cold chemistry inspection program.
8 That is, we take a look at how well the licensees' 9 can analyze cold chemical parameters within the primary 10 systems or secondary sys'. ems.
11 And a prime interest in terms of doing this of 12 course is that we are finding more and more things such as 13 copper and other types of induced corrosion, and the e- 14- licensees' capability of doing the measurements of these bs) 15 parameters is sometimes not very refined at all.
16 In all of the inspection areas we take a close 17 look at the staffing, the organization, the training, 18 facilities and equipment, and of course the quality 19 assurance that goes into these.
20 In terms of the confirmatory measurements program, 21 I'll just indicate a little bit more on that. We have a 22 mobile radiological laberatory which is equipped with the 23 camera spectrometry system and the ALPA beta gamma counting, 24 the strobe counting system as well.
25 We take the laboratory to the sites. he are h Heritage Reporting Corporation
(~l (202) 628-4888
C k- : ~
p 530
,p
( /' .1 scheduled to utilize them at reactor facilities about every
, 2 other year, that sort of frequency.
3 We go up'to the site. We ask the licensee to take 4 regular snaples that they are required to take by tec'
'S specs, of the filter, vent filters, cartridges for iodine,
.6 radwaste primary samples, liquid radwaste samples. We will 7 help the licensee analyze those samples and we will take the 8 same sample'cr a. split of that sample, we will analyze it in 9 our laboratory onsite and if there are any disagreements, we 10 can compare them right on the site and get resolution.
11 We also split the samples that require wet 12 chemistry. Such things as if you are looking for iron 55 or 13 technetium 99, strontiums. And we will send those to our eg (y 14 contract laboratory which is Riesel out of Idaho, and they 15 perform those analyses for us, so that we can compare those 16 wet chemistry samples as well.
17 Riesel also is our means of maintaining 18 accountability or accreditability in terms of 19 standardization with NIST. So we utilize them for preparing 20 standards for us if you will, for doing round Robins with i 21 all the other regions on the same one, so that we can 22 maintain compatibility.
23 Okay. The second -- The other aspect of the
- 24 inspection program of course is the envzconmental inspection 25 as well.
J GT. l k_) Heritage Reporting Corporation (202) 628-4888 l
l 1
gr J I' .
531
/ r;i( " p.
' ~
/' 1 We do look at, in terms of our confirmatory
- i ,: .
2- measurements, also the phantoms that are used for the whole 3 . body counting systems that Ron had just mentioned here 4 before.
5 The section also performs a service function for
- 6' the rest of the region in terms of the laboratory, so if any 7 of the sections bring back samples, whether they be liquid 8 samples, whether they be wipe samples, materials or any 9' other group coming back in, we perform the analyses for them 10 so that they can indeed have the independent assessment.
11 You are certainly invited to take a tour of the i
.12 laboratories if you do have the chance after these 13 presentations. Our mobile laboratory is currently up in
) 14 Millstone, so I won't be able to show you that one.
15 However, pretty basic functions I think of our laboratories 16 is first of all, the one I mentioned here is to verify the 17 licensees' capability of performing those measurements.
18 So if they report effluents of a given nature or releases 19 from the site, we have some confidence that they in fact can 20 do that.
21 And with that, with the mobile laboratory, for 22 example, some of the things that we wculd never know without 23 taking the laboratory to the site do crop up, in using 24 improper standards, a solid standard for example, when they 25 are measuring gas, a gas sample. We would not know that if Heritage Reporting Corporation (202) 628-4888 e
L I I
- 1-
~
we didn't-measure it.
2 In one instance recently'a utility was analyzing 3 cartridges. We look at the cartridge with our mobile
~4 laboratory and we found the front.and back, for example, ths l
5 same, which means'that in fact the iodine was uniformly 6 throughout the cartridge.
H 7 It indicates that the cartridge had a breakthrough' 8 problem. And in fact it was the whole gas stream that 9 really was improperly monitored. We would have not known i
10 that had be not utilized the van.-
- 11 Okay. So there is the independent measurement-12 capability that we have that way of doing assessments.
13 Reacted inspection, you know, what is in.any given 14 file of material that somebody calls in'about, or some other
(]}
15 allegation. We could follow up on that independently.
16 And the. third thing of course is the, emergency
, 73 17 response.
- 18 We have, in terms of facilities downstairs, a 19 sample prep lab and a separate counting lab, and the mobile 20 laboratory.
21 Let me now get into the TLD program just briefly.
22 Our section performs the service for the NRC 23 nationwide of providing the dosimeters and the network, as a 24 matter of fact, for monitoring each of the power reactors or 25 each of the power reactor sites within the nation, the l
f()' Heritage Reporting Corporation (202) 628-4888 l
p.'l 4
p, ,
u H'
.,.... 533-I?
0: 1- 11ceesed po.er reactors.
2- We have'three non-reactor. sites. We have 3' approximately 30 to 50 or so TLDs at.each of the reactor
-4 facilities. ~They are~ arranged generally in two concentric L- 5 circles so that.we cover pretty much each of tne 16 compass.
l' lM 6 sectors, those that are not over' bodies of' water.of. course.
7- But basically we are covering each of the sectors.
8 Part of the program is to again look at'the
'9 quality of the licensees' own monitoring efforts here so wa 10 can directlyLcompare a. number of these.
~
11 Some of the stations are also co-located with l ' 12 state program TLDs in which case we get another cross 13 comparison. But this is the only system which is nationwide.
i-iO 14 a =e111= ** - *to eve 1e vroc a r ror aei=9
- 15 al of these. And we public a report on quarterly. basis:
16' after'each cycle. 'nd these are' published as NUREGs and 17- updates.
18 And again/ this is traceable, the standards are 19 traceable to --
20 DR. KERR: What is it that you consider you are 21 measuring?
23 DR. KERR: What is it that you think you are 24 measuring?
m
- 25 MR. BORES: We are measuring in most cases simply Heritage Reporting Corporation (202) 628-4888 l
I 534
\_/ ' ,1 'thefambient radiation, the gamma basically.
2' DR. REMICK: . We have'just a couple'more minutes 3 for this.
4- MR.-BORES: The third thing I did'want to mention 51 is:that our section also is responsible for what we call the 6' state contracts program.
7 This is a cooperative agreement that-we have.with 8 I guess probably three quarters of our states for doing some 9 independent assessment primarily of the environmental 10 programs.
11 In the program, the contracts program, we provide 12 some monies to the state for which they set up an 13 independent or their own air sample station adjacent to a
() 14 licensee's station, they collect vegetation or whatever from
- 15. the same locations as the licansee does and they also in 16 many instances exchange the dosimeters for us at the various 17 locales under the state contract program.
18 So for the TLD program they are our basic staff in 19 most instances.
20 Also, for the state agreement, the states do l
21 provide us an annual report in which'they compare the 22 licensees' environmental measurements with their own at 23 these co-located stations and flag to us any anomalous 24 measurements-so that we and they can follow up on them. So 25 it gives us a heads up on it.
Heritage Reporting Corporation (202) 628-4888
l-535
(_) 1 In monitoring these state contracts of course it 2 does foster a degree of cooperation with the states and it 3 is also a means of states gaining confidence in what the 4 Feds can do and likewise gives us some idea of their 5 capability.
6 So if we have to respond to an incident, we go in 7 knowing at least the capabilities.
8 So if there are any questions, I'll address those.
3 Otherwise, this will complete my presentation.
10 DR. KERR: What would an anomaly be that a state 11 group might see?
12 MR. BORES: I think what we generally -- It is 13 spelled out in our contract and I don't have it in front of
{} 14 me. But I think it is something like it might be 25 percent 15 higher than a certain reading in the environment.
16 In other words, when they compare their own 17 measurement with the state measurement, if one or the other 18 sticks out fairly high, and we are talking about real 10 numbers as opposed to dealing with minimum levels of 20 detection of course, so that those numbers will be flagged 21 to us.
22 I can't give you a precise number.
23 DR. REMICK: Thank you very much, Mr. Bores, for a 24 concise presentation.
25 We will now turn to emergency planning and Bill
() Heritage Reporting Corporation (202) 628-4888
I r
536 j~')
\s/ 1 Lazarus will be making the presentation.
2 MR. LAZARUS: My name is Bill Lazarus and I-am 3 Chief of the Emergency Preparedness Section in Region I.
4 Briefly, some of'the responsibilities of the EP 5 Section are, the three principle responsibilities include 6 evaluation of the onsite licensees' emergency planning 7 program, which includes, typically that process is one 8 routine inspection per SALP cycle, and observation of one 9 exercise per year for each of the power reactor licensees.
10 In addition to that, one of our primary support 11 functions is technical support to the Federal Emergency 12 Management Agency in their evaluation of the onsite planning 13 process around each of the power reactors.
() 14 And finally, the section responsibilities include 15 the regional incident response program, maintenance of that 16 program.
17 In our own incident response area we typically 18 will participate in three or four exercises per year with 19 ten licensees in NRC Reg 3on I.
20 To get into the areas that you wanted to discuss, 21 on the agenda, one of the items expressed an interest in the 22 NRC region's involvement in the exercise process.
23 Basically, the power reactor exercise process 24 involves development of scenario by the licensee typically 25 submitted to the NRC C to 70 days prior to the exercise.
?
k Heritage Reporting Corporation ]
(202) 628-4888 j l
l l
p, p
b b 537 1 If it is a full participation exercisc,.which 2 occurs every two years, FEMA also receives.a copy and both 3 FEMA.and NRC then evaluate the scenario to see if it tests 4 the major observable portions of the licensee's emergency' 5' plan and includes all the necessary things-for us to 6 evaluate major portions of-their plan.
7 During the every other year cycle where the 8 licensee is performing an onsite exercise only, we encourage 9 a little more' realism in their exercise scenario development 10 than they are able to do during the full scale exercises 11 since they must drive a very large release to. test the 12 offsite agencies during that full sale exercise.
13' So in the off years they may not get to a general 14 emergency. They may, we want to encourage them to test
(])
15 their own staff's mitigation of the accident rather than be' 16 frustrated as they typically are on a,fu11 scale exercise 17 -where nothing they do is going to work right and it is going-18 to go to a core melt situation.
19 We've found licensees are very responsive to that 20 because they are aware of a negative training issue involved 21 with always running the exercise to the core melt situation.
22 On the scenario development process, the 23 confidentiality of the scenario must be maintained so there 24 is a small cadre of people on the licensee staff who are 25 aware of that. We maintain the confidentiality during our
() Heritage Reporting Corporation (202) 628-4888
.S l 538
[) review process. It goes into the public document room after v -
1
.2 the exercise is completed and we've had our report.
3 Exercise evaluation process. We will typically 4 have a team of four to six inspectors-onsite observing the 5 licensee's principal emergency operations' facility areas.
6 Next slide, please.
7 The areas that we evaluate would be the licenseo's 8 ability to classify the events whether or not they can make 9 timely notifications and provide the appropriate information 10 to the offsite authorities, whether they can call in their 11 own people and augment their emergency response 12 organizations in a timely manner, the efforts that they take 13 to mitigate the accident, their ability to perform dose 14 assessments, dose projection, and to use all that 15 information, including both the reactor status and dose 16 assessment numbers they come up with to make protective 17 action recommendations to the offsite authorities.
18 And then finally, once they have developed those 19 protective action recommendations, their interface and their 20 ability to communicate those to the offsite agencies.
21 Exercise findings. We typically do not cite 22 licensees for violations during an exercise. It is partly a 23 training process. So we identify exercise weaknesses, areas 24 where they could perform better. Caser where a violation 25 might be issued is when a licensee totally demonstrates that 4
Heritage Reporting Corporation
(-) (202) 628-4888
= _ _ _ _ - . _ . _ _ - _ ._ __ _-. _ _ - _ _
539
.n
-) I they are not able to. implement their plan.
2 If they do so poorly that they can't implement 3 their plan to protect health and safety of the public would 4 find a violation appropriate in that case.
5 In addition to identifying weaknesses and areas 6 for corrective action we will make an overall determination 7 that the licensee demonstrated the ability to protect the 8 health and safety of the public through the development of 9 protective action recommendations that they provided the 10 offsite authorities.
11 During this time if it is a full scale exercise, 12 FEMA is performing similar tasks offsite making sure that 13 the sffsite agencies, state and local governments, can take
() 14 the information they receive from the licensee, analyze 15 that, do their own assessment and implement protective 16 action recommendations made by the licensee.
17 Are there any questions on the licensee exercise 18 process before I go on to some of the areas of perspective 19 on licensee programs?
20 (No response) 21- DR. REMICK: Hearing none, continue.
22 MR. LAZARUS: Okay. Perspective on licensee EP 23 programs. Some of the strengths that we've seen just as far 24 as generic issues in emergency planning. The fact that 25 licensees now have detailed plans and procedures and we 1
i
_f .
(
Heritage Reporting Corporation (202) 628-4888 J
.540 3
As- - ' 1. ' require extensive' training and demonstration through' drills 2 and_ exercises makes both the licensees and'the NRC and state 3 'and local governments much'more comfortable with the 4' knowledge that they could implement these plans and really 5l ' protect the health and safety of the public.
~
6 Many of the licensees are switching to the use of -
.;, 7 the simulator to train operators during the exercise.
8' 1 initially didn't think that this'was much-of an 9 issue until we started noticing that those people on the 10 simulator had a much more difficult time of implementing the 11 emergency plan and controlling the plant than those who just 12 simulated controlling the plant while they broke out the 13 emergency procedures.
14-( You can identify quickly that, yes, I:am shutting 15l the plant down and I'm also calling the state and I'm doing-16 these things.
17 When you are actually manipulating the controls-18 and trying to get on the telephone, you understand, I think 19 I need a couple more people in the control room to get this 20 done right.
21 The licensees have spent a lot of time and effort 22 in support of the offsite authorities, working with the L 23 states and local governments and establishing plans,
- 24. providing them with equipment, working with them throughout 25 the year and especially during the exercises to give Heritage Reporting Corporation (202) 628-4888 p
l _ _ _ _ _ _ . _ _ _ _ _ _
541 p}
u- l everyone the confidence that they know how to plan work and-2 they know what to expect from the licensee and that they can 3 implement those plans.
4 Some weaknesses that we have identified recently.
5 We have found a couple of cases where we've identified 6 ineffective audits by licensees. Their own program wasn't 7 able to identify the weaknesses in emergency planning and 8 then they were not able to'take the appropriate corrective 9 actions.
10 We have found some problems in emergency 11 classification systems where you have to have a means to 12 classify in the four classification systems that we depend 13 upon to implement both offsite programs and the NRC's
() 14 incident response capability.
15 We are encouraging licensees to go to a hybrid 16 system where they use a barrier-based analysis in 37 conjunction with an event-based system which many of them 18 are using now to get a system that is both easy for the 19 operators to use, through human factors, and will get them 20 to the correct point quickly in their classification 21 process.
22 A few of the licensees have been installing siren 23 verification systems so that when the alert notification 24 system is activated if there is a siren malfunction they 25 will know immediately that a particular siren in a certain
't.- Heritage Reporting Corporation (202) 628-4888 1
1
542 (f 1 area has' malfunctioned and then they can take compensatory 2 action to alert the public in that area.
3 Presently, there are only two or three licensees 4 in Region I that do have that system.
5 Methods for public alerting. Principally we find 6 fixed sirens are used. There are a few cases where notifier 7 teams or route alerting is used, particularly in areas 8 beyond five miles where additional time is allowed for 9 notifying because of the distance from the plant. We are 10 encouraging those licensees, in particular in this case, 11 Maine Yankee, to get a system installed that will provide 12 for 15-minute notification for the emergency planning zone.
13 Some problems have been identified in the r^T 14 licensees' ability to augment their emergency response i) 15' organization. We have been taking a closer look at their 16 ability to call our their people, get them into the plant on 17 a timely manner and staff up. Really we find if you can't 18 get your staff in to augment your organization, you're going 19 to have problems implementing the plan.
20 Similarly, if you can't classify the events to 21 activate the offsite authorities at the right level you 22 would have a major problem.
23 DR. REMICK: What is FEMA finding with the ability 24 of offsite authorities to bring their people together in a 25 timely fashion, realizing they have a longer time?
i
() Heritage Reporting Corporation (202) 628-4888
_____________e
d i i r 543
- n
- 1 MR. LAZARUS: The way that is tested is during an 2 unannounced exercise and right now the unannounced exercises 1
- . 3 are rather artificial. The criterion is the week is 4 announced to everyone who knows they are involved in the i i
5 exercised cancels their vacations, stays in the area, has )
6 their beepers on. So we have not gotten to the point of I' 7 really testing a real time augmentation offsite.
8 MR. BORES: I just want to add a comment there.
9 What FEMA does look for here of course is the ability of the 10 utility to notify the offsite decision maker or someone who 11 is capable of making a decision usually through the rad 12 health individual and then his contacts with the emergency 13 management folks in the government. But in terms of the p %
(,) 14 state's need to staff up immediately it is usually not as 15 necessary as it is for the utility because you have a 16 decision that can be made and then you can get the message 17 out over EBS if necessary to act immediately. So it is 18 important to get the assessor and be able to reach the 19 decision maker. And those things are looked at closely and 20 each of the plans I do believe have capability for --
21 MR. LAZARUS: The contacts from the licensee are 22 to a 24-hour manned point in each case. They are the ones 23 who will get the ball rolling and if it is a fast breaking 24 accident plans are developed, procedures developed for the 25 decision making in the interim where they are staffed up s- Heritage Reporting Corporation (202) 628-4888
h
! 544 1 offsite.
2- One of the areas.that I am sure you are aware of 3' -is lack of cooperation from~certain offsite authorities, 4 particularly Massachusetts. We have had, because of the 5 Seabrook' emergency plan in particular, Massachusetts has 6' withdrawn from that. Seabrook had to develop a compensatory.
7 plan for Massachusetts, similarly for Shoreham, since New 8 York did not develop a plan for that area, Shoreham had to 9 develop a licensee plan.
10 Those plans will work. We verify there are a lot 11 of advantages. They have complete control of the training.
12 They know where the people are. It's not volunteers. They 13 generally have a much better background than the volunteers h 14- do offsite.
15 The problem areas are the fact that you don't work 16- with the people who you really expect through realism you
- 17. are-going to interact with in a real situation. So that is 18 not tested except through controllers and control cells 19 where someone pretends to perform that interface. function.
t 20 I already mentioned the lack of realism in some of 21 the full scale exercises.
22 One of the topics on your agenda was to discuss 23 burden of EP exercises on local governments.
24 Though we are not aware of any specific complaints 25 in NRC Region I. I am aware that it is an issue with some of I Heritage Reporting Corporation (202) 628-4888
i 545 I f~T i
(> 1 the governments. Basically the process right now requires 2 that local governments participate in an exercise every two 3 years. The state government must participate in an exercise 4 with one licensee in their state every two years.
5 Some states, particularly New Jersey comes to mind 6 where it is a state law that the state and local government 7 must participate in every exercise so they exercise every 8 year with the licensees. And many of them do in the off 9 years whether they are required to or not just for the 10 training.
11 Most of the emergency workers offsite are 12 volunteers. And the biggest impact occurs on the volunteers 13 that are trying to -- they have to take time off from work
'( 14 to participate in the exercises. Some states try to 15 schedule the exercises on weekends to alleviate that problem 16 so the people aren't missing work and trying to get excused 17 by the boss to participate. I know Connecticut does that, 18 sometimes Maine does it.
19 One of the things that I learned recently is that 20 the volunteers are affected by criticism in the FEMA reports 21 when they get evaluated offsite. They will feel sometimes 22 they have been unfairly criticized and their responses will 23 then be I'm a volunteer, I don't have to put up with this, 24 and they drop out. So then you had a fairly large cadre of 25 people willing to play, people dropped out because of l
,Q ll Heritage Reporting Corporation (202) 628-4888 i
l'
546
()J 1- criticism that at times they felt was unfair.
2 MR. CARROLL:' What is an example of a volunteer?
3 .Aren't they typically people that. work for the county for 4 example?
5 MR. LAZARUS: To a large extent they are not.
6 Normally the county. person will be the person in~ charge in a 7 local county emergency operations center, but he depends on 8 a transportation person, a medical person, they try to get a 9 doctor or nurse to volunteer for those positions.
10 One of the items on the agenda was a discussion of 11 a letter written by Mr. Sutton concerning the inadvertent 12 siren activation.in the Three Mile Island Emergency Planning 13- Zone of the Merc County siren. The siren activated I q[ R14 guess it was about 11:00 O' clock last March I believe, was 15 on for about 50 minutes. Mr. Sutton contacted the county 16 dispatcher on the 911 telephone number and listened to the 17 EBS radio station but no one, he got information from the 18 dispatcher that the county didn't activate it and that
-19 should have clued him in that it did not involve any 20 emergency at the site but the dispatcher was not very 21 explicit in what he actually told him. He could have said 22 it was a siren malfunction.
23 The word was also put on a broadcast but they 24 picked the radio station that was most widely listened to 25 rather than one of the EBS stations. One of the problems jlh Heritage Reporting Corporation I (202) 628-4888 L- . - _ _ _ _ _ _ _ _ - - - - - _ - -
t p
547 k_) 1 with using the EBS stati es is the fact thht they are not on 2 the air continuously and the only way you can activate a 3 message on them is to activate a recorder and then it's on
, 4 the air for eight hours until someone comes in to shut it I
5 off. So they did what they thought was the best way to j i
6 handle the situation by putting it out on the widely
)
7 listened to radio station. I 8 I think there was enough information in the 9 process that Mr. Sutton should have been able to figure out 10 that it was a siren inadvertent actuation.
11 MR. WYLIE: Was that an isolated case or has this 12 happened before?
13 MR. LAZARUS: It has happened before. The l
() 14 licensee believes they have identified the cause of the l 15 siren malfunctions through the design of the circuit boards l
16 and are working to correct that. In addition I've 17 encouraged them to look at the public information brochures 18 to put something out to the public, you know, how do you 19 determine if it is an inadvertent actuation. They can 20 listen to the EBS station and by default if there is no 21 message within five minutes or 15 minutes you can assume 22 that it is an inadvertent actuation but you don't really 23 know for sure unless somebody comes out and says that.
24 MR. CARROLL: That wouldn't make me feel very 25 good, though.
( Heritage Reporting Corporation (202) 628-4888
w 548
['y
?ss' 1 MR. LAZARUS: I agree with that. I think there 2- .should be some explicit description if the siren goes off 3 you can cal this number to verify that it has nothing to do 4 with an emergency at Three Mile Island.
5 MR. WYLIE: Do you make any attempt to find out 6 how effective the public information that is distributed is 7 understood.
8 MR. LAZARUS: FEMA does that. They evaluate the 9 public-information brochures, they have a contractor who 10 evaluates them for human factors and for reading level and 11 for content.
L 12 MR. WYLIE: Do they sample people to find out 13 whether they really understand?
e~ cmg
()' 14 The reason I ask, after this thing happened, I 15 asked a few questions around in areas where they were within 16 evacuation zones, and the people I talked to really didn't 17 seem to know what to do.
18 MR. LAZARUS: I think the information is there.
19 It's very difficult to make sure the people read it.
20 MR. WYLIE: Well, the information is there but 21 there is no concentrated effort to make sure people look at 22 it.
23 MR. LAZARUS: People even in the emergency 24 planning zone still believe, many of them believe that the E.
25 siren goes off, you evacuate, instead of turning on the EBS
'O. Heritage Reporting Corporation (202) 628-4888
H ,, ,
m h
h lL ' station andflistentag for'a message.
'I 2 MR. WYLIE: . That's what they'think, yes.
p
'3. MR. LAZARUS: I know the licensees and-the states-W: 4 and~ local governments spend a lot of time and effort trying 5' to get people to understand that. I don't'know what the ;
l'l i
'6- answer is. You.can lead a horse to water so to speak but.
7 you can't make them drink. We get the information'out 8- there. We try to get it to its appropriate level that's 9- understandable and I. think that the large percentage of the 10 population in the emergency planning zones do understand, 11 DR.-KERR: You base that on what?
12 MR. LAZARUS: I think it is really based on FEMA 13 has done surveysLduring exercises to --
, h -14 DR. KERR: Surveys? Okay.
15 MR. LAZARUS: -
you know, call people.to find'out' 16 if'they've heard the sirens and understood what it meant.
l 17- So that is part of the process.
18' MR. CARROLL: The Headquarters FEMA guy that gave 19 -us a briefing on this a while back said that they could not
-20' get money in the budget to do that kind of thing.
21 MR. LAZARUS: It's typically done in the initial
, 22 process for approval of the offsite plans for the formal 23~ approval of the plans. It's not a routine evolution that 24 they do during every exercise.
1.
25 MR. BORES: Well, it depends on the FEMA region.
Heritage Reporting Corporation (202) 628-4888
550
,m
- i. ) 1 But some'of the FEMA regions typically will have someone ask 2 a sampling of people, a small sample, ask if they know what 3 to do when or if they hear a siren. So it is nothing like a 4 scientific study with a huge sample. That they have not 5 been able to do.
6 MR. LAZARUS: A siren verification system might 7 have been something that could have speeded the response for 8 Three Mile Island also rather than waiting for a citizen to 9 call in and say the siren in my backyard is going off, 10 what's going on, if they had a verification system they 11 would know immediately if one of the sirens activated.
12 That brings us to discussion of the NRC's incident 13 response programs unless there are other questions on any of I) 14 these issues? i V ,
15 (No response) 16 MR. LAZARUS: In incident response, the primary 17 ro.les of the involved organizations, the licensee has the 18 immediate, primary and continuing responsibility to limit 19 the consequences of the accident. The state is responsible l l
20 to assure the protection of the public. And the NRC is the I
21 regulatory agency and we are involved in monitoring the I i
22 licensee to assure that their protective action 23 recommendations are appropriate and we agree with them. We l 24 support the licensee through technical analysis with reactor l 25 cafety teams and through the protective measures team to 1
() Heritage Reporting Corporation (202) 628-4888 l
< u m .. . 551
, p/
i
% - 1 analyze the' conditions and make sure that we-are all in
, 2 agreement.as to1what is going on and what the appropriate j 3' ' course of. action is.
4 DR. REMICK:. So FEMA's only . role is really to-5 evaluate and' advise the NRC, they:have no operational 6 function?
L, 7 MR. RUSSELL: In a real' event, if we got~to the 8- . point where we were into the Federal emergency response 9 plans, then FEMA does have a role. Bill' mentioned earlier 10 that we exercise three or four. times a year.- When we do 11 that it-involves on the order of 50 staff playing roles of-12- implementing a base' team plus a site team and it depends 13 .upon. whether we exercise with Headquarters or not, and we .gp>-
() 14 through an exercise.on four plants. That's.what'he's-
. talking about now. g
.15 '
16 'Other than the full field exercise that was'done 17 at Zion and the earlier one.in Florida,'.St. Lucie,-I am not 18 aware that FEMA has fully exercised with the NRC. We 19 exercise our response capabilities with licensees and it's 20 quite a shock to their system when all of a sudden NRC is l
l 21 there playing a role and they exercise all the other cases 22 without us. So we get to each one about on a five-year 23 cycle. We do three or four a year. And it takes us about-12 4 ' five years to get through all the sites.
25 MR. LAZARUS: One of the issues that there was Heritage Reporting Corporation (202) 628-4888
552 q.
k/ 1 some sensitivity expressed at the ACRS subcommittee meeting 2 two weeks ago was the actual role of the NRC, particularly 3 the resident inspector, during an emergency, talking about 4 Seabrook emergency planning. The issues that were discussed 5 were how big of a role does the NRC take as far as going 6 beyond advising the licensee and supporting them and taking 7 over as far as doing something stronger than a suggestion as 8 far as an accident decision.
9 The authority for issuing an order for the 10 ' licensee to do something at least with Chairman Zech remains 11 with the Chairman. We don't know yet whether Chairman Carr 12 will delegate that to a director of site operations or not.
13 But typically that is very closely held and we
() 14 remain in an advisory process. We can certainly question 15 the licensee to determine whether we believe that they have 16 addressed all the points and we think they are pointed in 17 the right direction. But the actual authority to issue an 18 order at present at least remains with the chairman.
19 Basically, there are four emergency classification 20 levels which trigger both offsite response and NRC response 21 and those classification levels are tied to the NRC response 22 modes. Unusual events normally would not do anything except 23 to track the information. If the incident went to an alert l
24 condition we would typically be in a standby mode where we l
25 are partially activating our response center in the region, i
[N
! k) m Heritage Reporting Corporation l (202) 628-4888 l
l l
w._-_____-__ _ - _ . _ _ _ _ _ _ . ___ _ _ - _ _____-__ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
553 (x-) 1- we are maintaining contact with the licensee, determining 2 what the status is. If it continues to escalate to a site 3 area emergency we would then go into initial activation 4 which means that we would be dispatching a team to the site.
5 At that point, Headquarters' executive team would 6 have overall control while that team is enroute at the point 7 of general emergency and we would have a site team in place 8 with a director of site operations who has been briefed by 9 the licensee and feels that he is up to speed and ready to 10 take over for the NRC, he will contact the chairman, tell 11 him he is ready. At that point when the chairman 12 relinquishes those authorities that he chooses to delegate 13 to the director of site operations, we would be in expanded l( ) 14 activation.
15 Standby is basically just a reiteration of what I 16 mentioned as far as the role of the agency during standby.
17 We would be monitoring, verifying what the licensee is 18 doing, making sure that we are in agreement as to the 19 posture they have taken and the appropriate classification 20 of the incident.
21 Initial activation. Again we have coordinated 22 with Headquarters gathering a team, dispatching it to the 23 site and preparing to support the licensee and the NRC 24 through that presence onsite.
25 Headquarters team roles pretty much mirror what Heritage Reporting Corporation (202) 628-4888 L __ __
, _ _ _ _ _ _ - _ - - - - - . - - _ . - - - - _ _ _ _ - . - - _ - - _ _ - - ~ _ _ _ _ - - . - - _ _ _ _ _ - - - - . ._
Y l 554:
x
! ,H l' the NRC would be doing except that it occurs at the'
.2- 'different' points while we are enroute to the site. The 3 Headquarters team would have the primary, would have a lead 4 for the NRC. When.we arrive on site then the director of 5 site operations assumes those responsibilities and be
'6 supported by both the region and Headquarters. ,
7 I don't know 'if this will make your eyes glaze 8 over or not. It's just basically an overall sketch of the 9 interface between the director of site operations with his' 10 team, with the ' executive team at Headquarters and how each 11 of those are supported.
12 MR. RUSSELL: That's why the director of site 13 operations needs a deputy to assist him, which during O 14 rcis s ae eta tai =es z ro==a ta t s e a rv 15 effective, so-that you can focus on what is going on and not 16 get involved in so much of the details of the 17 communications.
18 MR. CARROLL: Yes, I guess I have served as 19 recovery manager two or three times and I had exactly the 20 same experience, and I always insisted on having somebody ;
21 that did the --
22 MR. RUSSELL: -- summaries out, press releases, E 23 communicating, talking to people on the phone. It is just i 24 too many direct reports. You need a deputy to assist you.
25 We are still working on that issue. Most of the O Heritage Reporting Corporation (202) 628-4888 l _ __ ___ __ _ --________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __-- _ _ - - - - _ _ - - _ . - - - _ _ _ _
-___j
r 555 (3
N) 1 Regional Administrators who get into that position feel the 2 same way and I know Burt Davis when he was in the FFE III 3 felt that he really needed a deputy.
4 MR. CARROLL: I would suggest you encourage that 5 for the 2tilities that haven't perceived that yet.
6 MR. LAZARUS: I'm out of slides. So if there are 7 any questions, I'd be glad to answer them.
8 DR. REMICK: That's certainly one of the 9 advantages of drills, to come to those type of conclusions, 10 that you do need help.
11 Any questions?
12 (No response) 13 DR. REMICK: Thank you very much for expediting
() 14 the process.
15 Bill, on behalf of the subcommittee I want to 16 thank you and your staff for some excellent presentations.
17 We really welcome the opportunity to come to 18 Region I.
19 .ss I indicated earlier, we find these highly 20 beneficia and refreshing. And I think my colleagues will 21 agree we are very impressed with your staff, with the 22 enthusiasm and the openness and directness in responding to 23 some of our questions. We do find that refreshing.
24 So we thank you very much. I 25 Do you have any concluding comments that you wish
,- l
(- Heritage Reporting Corporation (202) 628-4888
556 I to make, or do any of my, colleagues wish to make miso?.
2 MR. RUSSELL: I don't have any other than the fact
- 3 the incident response is set up.
4 I know some have to catch airplanes, but closing _
5 on that, if you would like to see what our facilities look L
l::
'6 like and where a base team manager would be sitting, and how 7 we handle the various_ teams, that is available, and it is 8 pretty much on the way out, leaving spaces.
L 9 DR. REMICK: I had the pleasure of seeing that 10 about three weeks ago, but others might have an interest, if-11 they have the time.
12 Any comments from my colleagues?
- 13. (No response)
'( ) 14 DR. REMICK: We thank you very much. And it's a 15 pleasure meeting your staff and your nice facility.
16 We are pleased to see you have such nice 17 facilities.
18 MR. RUSSELL: As I indicated in my opening 19 -remarks, I look forward to this, particularly to encouraging 20 a lot of staff members to participate and give presentations 21 because I think we are doing some good things up here. And 22 I like the staff to get an opportunity to talk about what 23 they do and not just have senior managers do all the 24 talking.
25 DR. REMICK: I think that is wise. We appreciate Heritage Reporting Corporation (202) 628-4888
557 1 that.
2 Meeting closed.
3 (Whereupon, at 3:45 p.m., the meeting was 4 adjourned.)
5 6
7 8
9 10 11 12 13 O 14 15 16 17 18 19 20 21 22 23 24 25 l Heritage Reporting Corporation (202) 628-4888 1-
p t.
I k_)s : 1 CERTII ICATE 2
3 This is to certify that the. attached proceedings before the 4 United' States Nuclear. Regulatory Commission in the matter 5 of: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 Name: SUBCOMMITTEE ON REGIONAL PROGRAMS, REGION 1 OFFICE 7.
8 Docket Number:
19 Place: King of Prussia, Pennsylvania 10 Date: August 30, 1989 11 were held as herein appears, and that this is the original.
12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me-and, 14
( ). thereafter reduced to typewriting by me or under.the
'15 ' direction of the court reporting company, and that the
. l fi transcript is a true and accurate record of the foregoing 17 proceedings.-
18 /s/ IRWIN L. COFFENBERRY 19 (Signature typed) :
20- Official Repouter 21 Heritage Reporting Corporation 22 23 24 2S Heritage Reporting Corporation (202) 628-4888
yr::,1 : ,
.s e; . , . .
t-
[y,[,
[ Af h'
i SALP I 6 '. B .1) RESULTS'T0-DATE FOR REGION I PLANTS-m
- 1,
< :: , ' PROCESSINGLTIMES'AND PERIOD LENGTHS DISTRIBUTION OF SALP RATINGS h- EhFECTONINSPECTIONPRIORITIZATION NID-CYCLE REVIEWS AND LICENSEE SELF-ASSESSMENT' CONSIDERATIONS o
REGION l' INITI ATIVES
'i .
GENE KELLY DIVISION OF REACTOR PROJECTS TECHNICAL SUPPORT STAFF g
O
- , ?. .,
N :
L D
SALP PROCESS LENGTH OF CYCLES RANGE FROM 11-18 MONTHS WITH AVERAGE OF k 15 MONTHS, EXAMPLES ARE PEACH BOTTOM 'll MONTHS), NINE MILE t POINT.12 MONTHS), MILLSTONE (17 MONTHS), AND SUSOUEHANNA' (23-MONTHS). SEABROOK~(23 MONTHS) AND LIMERICK UNIT 2 (8 MONTHS) ARE SPECIAL CASES.
- PROCESSING TIMES HAVE, AS GOALS, ISSUANCE OF THE~ INITIAL REPORT WITHIN 60 DAYS, CONDUCT OF A MANAGEMENT MEETING WITHIN 90 DAYS, AND FINAL REPORT ISSUANCE WITHIN 150 DAYS.
- DURING LATEST FULL 12 N0hTN F5210D (9/1/88-8/25/89), THE FOLLOWING ACTUAL TIMES WtRE ACHIEVED FOR. ACTUAL.SALP ACTIVITIES:
l MILESTONE AVERAGE TIME FROM END OF PERIOD O 16 BOARDS HELD 49 DAYS 13 INITIAL REPORTS ISSUED 74 DAYS 15 MANAGEMENT MEETINGS CONDUCTED 92 DAYS 16 FINAL REPORTS ISSUED 153 DAYS REPORT LENGTH 'HAS BEEN ADDRESSED BY A GOAL OF 3 PAGE ASSESSMENTS (PER FUNCTIONAL AREA) AND REDUCTION OF " BOILER PLATE" AND STATISTICAL DATA OR TABLES TO IMPROVE READABILITY. CURRENT REGION I AVERAGES ARE 35 PAGES OF ASSESSMENT AND 10 PAGES OF DATA PER REPORT, AND THESE ARE TRENDING DOWN.
- REPORT REVIEW, BOARD DELIBERATIONS AND MANAGEMENT MEETINGS (INCLUDING TRAVEL) AS ESTIMATED TO INVOLVE 25% MANAGEMENT TIME.
()
- _ _ _ _ - _ _ _ _ _ _ - _ - i
S E
M -
I T -
G NI S
S -
T E -
O Cu -
Ol - L RaV C C
O P 3 8
N P -
H L #
A l S W V
B E 3 V
I W
1 T L C Z F
A R Y
U S
H S
, 0 '0 0 0 , 0 0
, 0 2
8 1
6 1
M 1
2 1
_ . 4 2 O i l
4 "L '
REGION 1-SALP RATING DISTRIBUTION 22 PLANTS RATED (BOARDS' CONDUCTED FROM 3/88 THROUGH 8/89)
FUNCTIONAL AREAS
-SAFETY
/ ENG & ASSESS /
PLANT RAD MAINT & EMERG SEC a TECH- QUALITY RATING OPS CON SURVL PREP SAFE -SUPPORT VEhiFI 1 12 8 5 12 17 5 6
' l DEC 0 0 0 1 0 0 0 2: IMP 2 1 1 4 2 3 3 2 4 11 15 5 3 11 11
- 2-DEC 2 0. 0 0 0 0 0
- 3 IMP 1 'l 0 0 0 2 1 3 [ 1 1 0 0 1 1 I O i
O Cn C a O O M
e) O g
< s a N 5 O
i h
h8 -
O@
Ao m si
<H%
g ; g a.
- cn u /l .e
<7 k 0 o ae ' $
Z '
lf,yl . t ll1 &Eb O N ,U If l?N'!$h ~ .c 8 c oo
'z x o N 2; a. y& .%
/
/ Y plh
,'hy w h?
y
,, e .E 8
8 8 Om MN
, E, g' f jjifl!, g lll gh'! &:h
$ {$.
o 2:E y'
M i _ ,
! E' d C '2 '; S E r
i ~e si! .
M
& 5$
CD H
O A
7 E' ,
\ .
{'
EFFECT OF SALP ON INSPECTION PRIORITIZATION
- BOARD REPORTS PROVIDE RATINGS, TRENDS AND RECOMMENDATIONS.
RECOMMENDATIONS MAY PROPOSE INCREASED, DECREASED OR'SPECIAL TEAM INSPECTIONS.
SALP REPORTS CONTAIN INSPECTION STATISTICS BROKEN DOWN BY FUNCTIONAL AREA. THE STATISTICS ARE ANALYZED FOR (AND THE RESULT OF) APPROPRIATE APPLICATION OF INSPECTION RESOURCES WITH RESPECT To SALP RATINGS.
SALP RATINGS DIRECTLY INFLUENCE THE PRIORITY OF A PROPOSED INSPECTION; AS MUCH A DECISION OF ORDER, AS OF "GO-NO G0".-
A RATING CATEGORY l DECLINING MAY RECEIVE HIGHER PRIORITY THAT A CATEGORY 2 IMPROVING. A DECLINING TREND, WHICH-(]) INDICATES A POSSIBLE RATING CHANGE EARLY IN THE NEXT SALP PERIOD, IS A TRIGGER FOR NRC T0' APPLY PROACTIVE INSPECTIONS SO'AS TO OUI'CKLY ASSESS EMERGING SAFETY CONCERNS. IN THIS SENSE, A TREND HAS A STRONGER INFLUENCE THAT THE RATING.
THERE ARE OTHER INFLUENCES (BESIDES SALP) WHICH MAY CAUSE AN INSPECTION TO BE CONDUCTED, SUCH AS: RECENT EVENTS, RECOMMENDATIONS OF RESIDENT INSPECTION STAFF OR NRC MANAGEMENT, PRA RESULTS AND STUDY OF PERFORMANCE INDICATORS.
- 9 9
O
r_ _ ,,
-;', 7
,/y 'c, E UNITED STATES -
[L v( i NUOLEAR CE2ULATORY COMMISSION I '
. mecoN r 475* ALLENDALE ROAD
=...* x NG OF PRUS$1A, PENNSYLVANIA 1 Hot x]
Docket N:;. 50-219 1 E Obb kh[
GPU Nuclear Corporation. ..
ATTN: Mr. Eugene E. Fitzpatrick Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, New Jersey. 08731 Gentlemen:
Subject:
Self' Assessment Initiatives Region 'I .is aware that many licensees have implemented or are planning to conduct self-assessment programs to enhance their awareness of the effectiveness of activities that.could affect safe plant operations. NRC fully, supports such initiatives and is interested in factoring consideration of such programs into our inspection program planning for future SALP cy:les.
/~' - To tha't end,. I request that you provide the NRC, via tne Senior Resident Inspector, your curre*t schedule including dates and topics for self-assessment activities, Additionally, at futuee SALP fratagement meetings, we request that you provide your best estimate for self assessment activities to be. conducted
-in the next SALP period. In this way, we will better be able to schedule our inspection activ' ties avoiding conflicts and making more productive use 'of available inspection resou*ces.
This request does not constitute a regulatory requirement, but rather it is made in ar attempt to enhance N;iC's inspection process by giving appropriate consideration to licensee self-assessment initiatives.
Should you have any questions regarding this request, please feel free to contact either me or the responsible Region I DRP Branch or Section Chief for your f acility.
Thank.you for your cooperation with us in this matter.
, Sincerely, p W am .' n rector g Division of Reactor Projects
(
_ - 4
~~ ~
r .,
. L REGION I-SALP: INITIATIVES
$([) (OVER PAST 18. MONTHS)-
Alls / UTILITY-REGION'I WORKSHOP IN MARCH 1988- 1 RESIDENT COUNTERPART ROUNDTABLE SESSION IN APRIL 1988 -
ISSUED TEN' GUIDANCE MEMORANDA FROM MAY-AUGUST 1988, AS TRANSITION TO REVISED SALP MANUAL CHAPTER TO:
DISTRIBUTED AUTHORSHIP SIMPLIFY TABLES AND STATISTICS ACHIEVE CONSISTENCY IN APPROACH (FORMAT AND PROCESS)
- INVOLVE NRR, OTHER REGION I DIVISIONS AND FORMALIZE
, FEEDERS' CLARIFY VOTING PROCESS USING MATRIX TO BETTER FOCUS ON OVERALL
SUMMARY
LBETTER SPREAD OF SALP SCHEDULES TO MINIMIZE TIME IMPACT-AND O'- IMPROVE:00ALITY AND TIMELINESS OF REPORTS REGION I SALP WORKSHOP HELD WITH LICENSEES IN APRIL 1989 INTEGRATION OF SALP WITH PLANNING AND SCHEDULING AND-NRC SENIOR MANAGEMENT MEETINGS l USE OF Two DRAFTS PRIOR TO BOARD MEETING TO MINIMIZE EDITORIAL COMMENTS AND FOCUS THE BOARD ON ISSUES PILOT TRIAL OF PRE-BOARD MEETINGS MID-SALP CALIBRATIONS UNDER PROCEDURE 35502
-MANAGEMENT MEETING PRESENTATIONS BY DRP SECTION CHIEFS AND LICENSEE INITIATIVE PRESENTATIONS l
LC NRR SALP COUNTERPART MEETING IN JUNE 1989 FOR CONSISTENCY BOARD CHAIRMANSHIP SPLIT BETWEEN DRP DIRECTOR AND DEPUTY
h EFFECTIVENESS OF SAFETY REVIEW ACTIVITIES-0 ORGANIZATIONAL COMPONEllTS INVOLVES IN SAFETY REVIEWS.
CLASSICAL ON-SITE SAFETY' REVIEW COMMITTEES >
0FF-SITE SAFETY REVIEW COMMITTEES QUALITY ASSURANCE ACTIVITIES NEW INITIATIVES INDEPENDENT SAFETY ENGINEERING GROUPS HUMAN PERFORMANCE EVALUATION SYSTEM SAFETY SYSTEM FUNCTIONAL EVALUATIONS 10 0 NRC EVALUATION METHODS OPERATIONAL SAFETY VERIFICATION GENERAL CONFIRMATION OF EFFECTIVENESS BI-MONTHLY (APPR0X ) EXAMINE REVIEWS OF CONTROL ROOM ACTIVITIES EVALUATION OF SELF ASSESSMENT CAPABILITY
'0N-SITE AND OFF-SITE REVIEW COMMITTEE ACTIVITY REVIEWS MID SALP REVIEW 0 NRC EXPERIENCE - UTILITIES WITH EFFECTIVE SELF ASSESSMENT L AND CORRECTIVE ACTION PROGRAMS ACHIEVE BETTER PERFORMANCE LO l
I L .
g L STEPS IN THE RESTART PROCESS
--- ISSUE-CAL TO DEFINE EXPECTED LICENSEE ACTIONS p --- RESTART-PANEL CONSTITUTED 1.
L --
LICENSEE SUBMITS A RESTART ACTION PLAN PANEL REVIEWS AND APPROVES THE RESTART ACTION PLAN PANEL REVIEWS THE LICENSEE'S SELF-ASSESSMENT PROGRAM l
PANEL REVIEWS THE LICENSEE'S POWER ASCENSION TESTING PROGRAM LICENSEE SUBMITS A READINESS FOR RESTART REPORT NRC CONDUCTS AN INTEGRATED ASSESSMENT TEAM INSPECTION PANEL RECOMMENDS TO SENIOR MANAGEMENT THE LIFTING OF THE CAL CAL IS LIFTED NRC AUGMENTED INSPECTION TO MONITOR RESTART OF THE FACILITY AND THE POWER ASCENSION TESTING ACTIVITIES I
O sn k2
__ .z.. - _
1 r .
D: ,
a PILGRIM
- ISSUES LEADING TO EXTENDED: SHUTDOWN.
-- : - HISTORY 0F.P00R. PERFORMANCE.
l IMPROVEMENT $FFORTS INHIBITED BY:
Y (1) INCOMPLETE STAFFING (2)- ORGANIZATIONAL VIEW THAT:PAST IMPROVEMENTS HAD 4
. CORRECTED PROBLEMS
- -(3). RELUCTANCE TO~ ACKNOWLEDGE NRC-IDENTIFIED; PROBLEM
, (14 )' WEAK SELF-ASSESSMENTS -- DEPENDENCE ON THIRD PARTIES T0; IDENTIFY PROBLEMS Q EMERGENT ISSUE DURING OUTAGE 0FFSITE EMERGENCY PLANNING.
LICENSEE' ACTIONS MANAGEMENT CilANGES PILGRIM RESTART PLAN i
SAFETY ENHANCEMENT PROGRAM SUPPORT T0 0FFSITE EMERGENCY PLANNING
- LICENSEE SELF-ASSESSMENT LICENSEE POWER ASCENSION PROGRAM O
--- ----___._...._w_ . . , _ _ _ _ . _ . _ _ _ _ _ _ , , . _ _ . _ _ _ _ . . . . .
e 9
NRC ACTIONS DIAGNOSTIC INSPECTION /SALP/AIT/ CAL
. MANAGEMENT MEETINGS RESTART ASSESSMENT PANEL AUGMENTED INSPECTION PROGRAM MAINTENANCE TEAM INSPECTION PUBLIC MEETINGS EMERGENCY PLANNING REVIEWS O
INTEGRATED ASSESSMENT TEAM INSPECTION ACRS BRIEFINGS RESTART READINESS ASSESSMENT REPORT COMMISSION-BRIEFINGS AND MEETINGS RESTART STAFF INSPECTIONS OF POWER ASCENSION NRC APPROVAL POINT DELIBERATIONS AND COMMISSION INFORMATION PAPERS O
I
_.-__.__..,.____m_--c_ _ _ ___. _ _ _ _ - - -
2 L l k Lh
~
, PEACH BOTTOM
- -- SHUTDOWN ORDER LICENSEE RESPONSE
, '- RESTART PLAN
. MANAGEMENT CHANGES
' REORGANIZATION
,-TRAINING-
~ READINESS ASSESSMENT RESTART POWER TESTING PROGRAM
' NRC RESPONSE
. PANEL-h -
'PUBLIC MEETINGS STATE INVOLVEMENT SAFETY EVALUATION REPORT TEAM INSPECTIONS TRAINING.AND OTHERS INTEGRATED ASSESSMENT TEAM INSPECTION RESTART TEAM INSPECTION ACRS BRIEFINGS COMMIS.SION BRIEFINGS O
lO A[
(
L u -
^ v BACKGROUND 12/87 .6/88 --
CALVERT CLIFFS DISCUSSED AT NRC. SENIOR MANAGE -
MENT MEETING AS PLANTS WITH DECLINING PERFORMANCE MID 1988 --
TWO TS LC0 VIOLATIONS'WHICH RESULTED IN INOP-
^
ERABLE D/G AND DEGRADED RPS 9/88- -- FATALITY;0CCURRED DURING ENTRY INTO A CONDEN-SATE STORAGE TANK 9
12/16/88 --
- CALVERT CLIFFS IDENTIFIED AS STATION REQUIRING CLOSE AGENCY-WIDE MONITORING-EDO MEETS- WITH CE0 AND REQUESTS COMPREHENSIVE Q112/20/88 PLAN TO TURN AROUND DECLINING PERFORMANCE 3/89 --
SPECIAL TEAM INSPECTION (STI) -IDENTIFIED NUMEROUS DEFICIENCIES AND WEAKNESSES IN PRO-CEDURES, INCOMPLETE CORRECTIVE ACTIONS FOR IDENTIFIED PROBLEMS AND A MANAGEMENT STYLE THAT PLACED PRIMARY -EMPHASIS ON POWER PRODUCTION 3/89 --
PROCEDURAL ADHERENCE PROBLEMS CONTINUE
~
o LOSS OF VACUUM
.o ESF ACTUATIONS O ,
- f. '
~
/ '; BACKGROUND (CONTINUED) 2 v
4/89 --
WORK CONTROL AND TAGGING PROBLEMS o LOSSES OF. CONTAINMENT INTEGRITY o DIVER.IN INTAKE STRUCTURE I
5/89- --
PRESSURIZER HEATER LEAKS DETECTED IN UNIT 2, UNIT 1 ALSO SHUT DOWN ON 5/6 9
l L)
)
l
_- -- J
K yr y ;
r l.
!'t CORRECTIVE ACTIONS 5/23/89' --
-LICENSEE PROPOSED CORRECTIVE ~ ACTIONS BEFORE RESTART
. 0F EITHER UNIT 5/24/89 --
' CAL 89-08~~ CONFIRMS LICENSEE COMMITMENTS L .
.6/21/89- --
LICENSEE-ALSO COMMITS TO' RESOLVE CERTAIN STI ISSUES.
BEFORE RESTART L. 4/7/89 --
REVISION 0 0F LONG-TERM PERFORMANCE IMPROVEMENT PLAN-'(PIP) 1 7/31/89 PIP IMPLEMENTATION PROGRAM SUBMITTED Q 8/4/89' 8/28/89 MEETINGS WITH LICENSEE TO DISCUSS PIP i
I e
i' O
_..m_.__ __ _ _..__._---.__.___.a__ -____.__.________-_.-_--__.-__-_m-----_-
ii}
FUTURE PLANS o ~NRC COMPLETES DEVELOPMENT OF RESTART ACTION ITEMS LIST H o- BGEE COMPLETES CORRECTIVE ACTIONS-FOR RESTART
- o BGEE- PRESENTS ITS' CONCLUSIONS TO NRC ON- RESTART READINESS o NRC INSPECTS'TO VERIFY; IMPLEMENTATION AND ASSESS ADEQUACY OF-BG8E CORRECTIVE ACTIONS o' CAL RELEASE FOR UNIT 1 RESTART BY REG'IONAL ADMINISTRATOR
' REGION ~I o UNIT 1 RESTART - NRC. PROVIDES AUGMENTED RESIDENT COVERAGE' C '
o CALVERT LCLIFFS ASSESSMENT PANEL - CONTINUE EVALUATION OF THE BGEE LONG-TERM CORRECTIVE ACTION PLAN .(PIP) FOR PERFORMANCE IMPROVEMENTS 4
4
- Q i l
_ z. __ _z___---- _____ __- - - - - . - J
mm m .
- I;b j [24'.
~
May
' g[
(
4 , ,
, 9l;';f e
4..
p ~ ~ '
V
- 3. ,
ViilhI '
,, :i.
F
' O W RATOR LICENSIf0' Jl A.- PROGPAM STATUS-i ).
o/ 3j. ,
~~
- 1. . . STAFF ESOURCES s
. >: ' ~
BUDGET CURRENT STAFFING 10A EXAMIER FTE- 2 SECTIONS (2SC'S)L p
y 1: LICENSING ASSISTANT 19 PROFESSIONALS
. J (16 CERTIFIED. EXAMIERS).
\'
11.9 TOTAL FTE' 1 LICENSING ASSISTANT:
SIX EXAMIERS PREVIOUSLY HELD C0WERCIAL EACTOR OPERATOR LICENSES e
Q e__ __ - -- - _ .
fpf 9 f N
-s
/
OPERATOR LICENSING 1
l..>.
E A. PP0 GRAM STATUS
! -2. EXAMINATION PERFORMANCE FY 89 (THROUGH AUGUST 7) 1 I
- REQUAL EXAM: 159 CONDUCTED 120 PROJECTED v
SCHEDULING CONTROLLED BY NRC
\
- INITIAL EXAM: 240 PROJECTED 219 CONDUClED APPLICATIONS CONTROLLED BY FACILIT( LICENSEE 3 0 (v
g y .__ __
s i- .
l[p'i(
- i
)__
, r A '. PROGRAM STATUS a- FY 90 PROJECT 10il 300 REQUAL EXAMS
^
G0AL IS'TO C0WLETE 1400 BY VAY-1993-1 t.
3.
- 3. OTER STAFF ALTIVITIES -
g: -
WP1 AND WACH BOTTOM OERATOR EVALUATIONS
' \.
PILGRIM AND KACH BOTTOM RESTART INSRCTIONS-
- E0P INSPECTION TEAM LEADERS
- . SEABROOK STARTUP TESTING INSKCTIONS 1
A u-_m - _ _ _ - ._a____ ____.__u__..__.___sm_m__.m._-.m___m___ _m._..____ .__-_ _
o B, IMPACT OF 10 CFR 55 CHANGES' SIX YEAR VS lWO YEAR LICENSES AININISTRATIVE PROCESSING 0F LICENSE REEWALS STOPRD UNTIL 1993 SITE SKCIFIC SIMJLATOR MANDATED -
INVALVABLE TPAINING/ EXAMINATION TOOL FORCED LICENSEE MIDDLE AND [PPER LEVEL MANAGEENT ATTBITION AND IllVOLVEEiff TO LICENSED OPERATOR RE0'JALIFICATION TRAINING PROGRAM O -
ENHANCED OR REDIRECTED LICENSEE RESOURCES TOWARD LICBISED OPERATOR s REQUALIFICATION TPAINING PROGRAM L
L
.O
n ... j l ,
I e
N, , (
B. IMPACT OF 10 CFR 55 CHANGES (C0fRINUED)
EQUAL EXAM PROVIDES ADEQUATE BASIS TO EVALUATE TECFNICAL
, QUALIFICATIONS OF INDIVIDUAL OPERATORS FOR LICBiSE RENBVAL AND TO.
EVALUATE ADEQUACY OF LICENSEE QUALIFICATION TPAINING PROGRAMS SUBSTANTIAL NRC RES0tJRCES BEING DEDICATED TO EQUAL EXAMS IN ORDER TO SUPPORT 6 YEAR LICENSE REtH ALS ONE EQUAL EXAM PER YEAR AT M)ST FACILITIES g -
NRC E-EXAM 0F EQUAL FAILUES WITHIN SIX PUGE
\ --
NRC E-EXAM 0F INDIVIDUAL AND CREW FAILUES AT FACILITIES -
WITH UNSATISFACTORY EQUAL- PROGPAMS PRIOR TO PETURN TO LICENSED DLTTIES -
TRACKING 0F INDIVIDUAL LICBGED ORRATOR STATUS ON EQUAL EXAM FOR LICBGE REND!AL IS NECESSARY Q
_ - _ - -- - - - - - - _ -- - ~
1
- h. ,
C. REQUAllFICATION EXAMINATION BBEFITS/ PROBLEMS i
- 1. BDEFITS-MDPE PERFORMANCE ORIElffED EAN TE EPLACEENT EXAM -
GOOD INDUSTRY ACCEPTANCE OF ETHODOLOGY - NRC/ LICENSEE TEAM PREPAE EXAM, GRADING DONE IN PARALLEL EM1ANCED AND MBE FEDUENT VIEW OF LICENSED OWPATOR PERFORMANCE AND LICDISED OPERATOR TRAINING PROGRAMS GOOD STARTING POINT FOR MDE DIAGNOSTIC EVIEW OF TRAINING PROGRAMS AS ERECTED IN flRC INSRCTION PROGRAM
\
- IN QWARISON TO EPLACDDIT EXAM, DA' MINERS AE SPENDING MDE TIE ADMINISTERING TE EXAM TilAN IN PEPARING FOR IT O
L ..
- r. .
1 C. PEQUAllFICATION E/ AMINATION BBEFITS/ PROBLEMS
- 2. PROBLEPS SEPARATE PREPARATION AND EXAMINATION HEEKS - ADDITIONAL NRC. AND C0fflRACTOR TPAVEL TIE ER EXAMINATION OE hEEK FOR PEPARATION AND VALIDATION COULD BE REDUCED OR ELIMINATED AFTER TE INITIAL ROUND OF EQUAL EXAMS i
- A PROGRAM PASS / FAIL CRITERIA EEDED TO ADDRESS LICBiSEE EXAMINATION VALIDATION PROBLEMS
-t DURING PRE-EXAM REVIEWS SUBSTANTIAL COtMENTS AE PADE BY llRC EXAMINERS ON EQUAL EXAM CONTBR TO EET liiE INIENT OF ES-601 FIRST ROUND - LACK OF FULL UNDERSTANDING OF ES-601 E110DOLOGY BY LICENSEES POOR LICBISEE EVIEWS ON 00NTRACTOR OR "IN-HOUSE" PRODUCED MATERIAL
.O ,
/
U C. PEQUALIFICATION EXAMINATION BBEFITS/ PROBLEMS
- 3. PESULTS TliPDUGH AUGUST 7,1989 PEOUAL EXAMS ADMINISTERED - 159 (0UT OF 11400 LICB4 SED OEPRATORS)
INDIVIDUAL EXAM FAILUPES - 27 (17%)
10 PEACTOR OPERATORS 17 SB110R REACTOR OPEPATORS
,0 -
EXAM SECTI0fE FAILED WRITlBl .15 s SIMULATOR 15 JOB PERFORMAt1CE lOSURES 6 PROGRAMS EVALUATED 11 UtiSATISFACTORY PROGRAMS 2 O
I Cm_m_____ . _ . . _ _ _ . ~ _ . _
~D . P.ATIONAL lEDRY EXAMINATION (GBERIC FUNDAMENTALS EXAMINATIONS)
~-
, GIVEN THREE TIES A YEAR (OCT/FEB/JUN) l STANDARDIZED TEST ON C0 HON 1(NOWLEDGE ELATED TO llE TrEORY OF NUCLEAR POWER ORRATIONS-(50 MULTIPLE CHOICE QUESTIONS)
SNCIFIC TO PLAKT TYK (BWR 8 PWR)
RESOURCES ALLEVIA1ED FROM REGIONAL STAFF PREPARATION ON THIS SECTION OF TIE EDLACDOIT EXAMINATION AND GRADING T
PASS / Fall GRADE (NifERICAL - GEATER THAN 70%) -
OPTICAL SCAN GRADING HIGHLY SUCCESSFUL PILOT PROGRAM l
O-
por
.; + . ,
,c, ,
- pp
- . s..
. i, . ~ j .,
1 L
_ ji i
'[}- . - .
Q n E. . L%INTAlulNG CONSISTENCY OF OPERATOR EXAMINATIONS AMDRG EGIONS" <
1 L
1 l
/.
EXAMINER STANDARDS (NUREG 1021) 1 OLB 1 RAINING PROGRAMS /TTC
~
- WRITTEN EXAM TEONIQUES
- . SIMULATOR AND WALK-TliRU TECHNIQUES ItffER-EGION EXAMINER TRAINING
{' OLB AffiUAL' AUDITS
.( - -
EA01 EGION AUDITED TEAM PARTICIPATION BY OTER EG0lNS i-WEDlY OLB 00NFERENCE calls
.O.
l
y w=r- : ., ;
%;x ,-: : ..
M '
~, ^
- -) .
s.
,-c 1 j
/ *, j(). ,
n.
p h b E;1LWRITIBf EXAM CONSISTENCY w n
. - CONTDIT/VAllD QUESTI0tS.
r e , --
K/ACATALOG(NUREG'1122/1123)-
t QUESTION 1YK EMDRY COMPRBEGION SYNTESIS
-y u ANALYSIS
-( ALL QUESTIONS INVOLVE SOE EMBRY-c 75% ORIECTIVE OVESTIONS
- 2. OPERATING TEST CONSISTBJCY i' NLPERICAL GRADING USED 10 DETERMINE COMPETANCY ON SIMULATOR L- - PORTION OF TEST 1; , '
R l'
O 4
k ,
u a __-._ ___-_ - .
4
t 'b i
b F. NATIONAL EXAMINATION SCEDULE WITHIN TE FISCAL YEAR EA01 PLANT IS ASSIGIED TWO 10NTHS FOR EXAMINATION NEEDS i
. - EXAMINATION ftEDS: EPLACDelT, QUALIFICATION, ETAKES FOR FAILUES (IN PARTICULAR FOR QUALIFICATION FAILUES) ASSIGfED EXAMITER CAN BECOME MDRE FAMILIAR WITH FACILITY SET M0ffiliS ENilANI EGIONAL/ LICENSEE PLANNING FOR EXAMINATIONS SPREADS OUT MDE UNIFORMLY C0fRRACTOR UTILIZATION i
FOR CERTAIN PLAIRS TE M0im1S AE OUT OF SYNC WITH EQUAL ERIODS-g AND/0R REPLACEMETE CLASS TRAINING COMPLETION DKiES
- LICENSES, IN'GBERAL, CAN!10T ACCOMODATE REPLACDelT AND EQUAL EXAMS FOR LARGE NJEER OF CA!0lDATES WITHIN WEEKS OF EACH OTER.
O
(k
[ 9)S g .t i
.D l
- 12. RADIOLOGICAL CONTROLS (60 min)' 11'00
- a.m.
M. Knapp.
E A. ' REACTOR HEALTH PHYSICS INSPECTIONS -R. Nimitz
.B. ALARA R.-Nimitz I C. EFFLUENTS: INSPECTION AREAS R. Bores D.. LABORATJRY PROGRAMS R. Bores I .
O.
i LO
n .- -- - - - - - - - - - - - - - _ _ - -
LO INSPECTION PROGRAMS
- CONFIRMATORY MEASUREMENTS
-WITH MOBILE LABORATORY
- COLD CHEMISTRY
-BNL STANDARDS TO ASSESS LAB PERFORMANCE 10 -COMPARISONS WITH INDllSTRY/NRC ACCEPTED STANDARDS AND PRACTICES
- LIQUID AND GASEOUS EFFLUENTS
-OPERATIONAL RELIABILITY OF MONITORING SYSTEMS l
0 -
~- _ -.
'* #5 a
~'" .;
g P
-g L),: a i
l INS _PECTION-PROGRAMS (CONTINUED)
- RADWASTE
-MIXED WASTE MUST BE STORED ON SITE
-LOW LEVEL RADWASTE DISPOSAL (1/1/90 AND 1/1/93 DEADLINES)
-0CCASIONAL PROBLEMS WITH WASTE SOLIDIFICATION
- TRANSPORTATION
- ENVIRONMENT l
O C - - - ---
y.7 7, ,- - -, - , , , , ,,,, , ,,.- -
x, , , , _ ,, . _ _ , , , ___ ,_
m_,,,,._,,_,_
l <
I,
- m. t L LO
. REGION I RADIOLOGICAL LABORATORIES PURP')SE: INDEPENDENT MEASUREMENTS TO VERIFY LICENSEE'S MEASUREMENT CAPABILITY; NRC INDEPENDENT ASSESSMENT CAPABILITY;
'NRC EMERGENCY RESPONSE TRACEABILITY TO NIST THRU RESL SAMPLE PREP LAB COUNTING LAB-MOBILE LAB O
r ;.
. ;3.. ,c,.
l -' .
[..{.
l-L.
NRC TLD' DIRECT RADIATION MONITORING NETWORK
'72 'NRC LICENSED POWER REACTOR SITES (3 NON-REACTOR' SITES)-
- REGION.I CONDUCTS PROGRAM FOR-NRC
- CALIBRATION TRACEABLE TO NIST a
L i
lf l
O L
- e. 7, w i.
4 .,
J<
f}
n- -
l' l
STATE CONTRACTS PROGRAM ~ ,
l:
l
- COOPERATIVE AGREEMENTS WITH-STATES-
- INDEPENDENT ASSESSMENT OF LICENSEES' ENVIRONMENTAL PROGRAMS
- ASSISTANCE TO NRC IN TLO PROGRAM O
- DEVELOPMENT AND ASSESSMENT OF STATE CAPABILITIES O
y I a
f l
s g o n r i t i
n n a ol ~
r C o T s r -
t d l l a n d n o -
S n a t r i r o -
C a n t eC s
I S o n e C Mad n Y D o c a
H E i t n n e r d
~
P a a o n ~
l i
u e W i cit l e u s t
ai o
H E f
gl i
vl opi o n ta I
a r T V n u s x r N
L E i f
u Q S R eE map a
AR E
f a .
l t
n e t ,
s a r HS S nt o n e mn r C oP A d i
t el e ,
R E n c mb o t
xd g
OR a l e s r E ni n T A e sP a n C nS o
e s
d e a n -
n A i t
l s
aiP vl E a eA n
t R z n l e
e i ,
a c n a s ,
a gA -
t a si r i aR g r d ed t A
r e u t a uL -
)'
OP A InR OA -
I'm:
Illi -
n o
i t
a t
n e
n
- ot n m i
t e
e l
c p u m d e i m
e v Rl o s d v v e n A d ni a nit O R a c gt n
L A d e n L
l nji r e o a b A-t r .Otom ih n s n s o sd oi e n l C n e
aMba mr r al s et s c E e w a n TA o a G
e r m m a r
c eA o r r k Rf g u r A r o o oL e r SWAPP O * * * * *